ML12276A076

ANS 3.2 Comp Side-By-Side 25

ML12276A076
Person / Time
Issue date:	02/04/2013
From:	Division of Nuclear Materials Safety III
To:
Rodriguez-Luccioni H
Shared Package
ML12276A061	List: ML12276A071 ML12276A072 ML12276A076
References
DG-1300
Download: ML12276A076 (81)

Text

ANS 3.2 Side-By Side Comparison Proposed ANS 3.2 Wording 7/25/2012 Staff American National Standard ANSI/ANS 3.2-2012 Comments/COLP Wording from ANS 3.2 1976 Wording from ANS 3.2 1982 Administrative Controls for the Operational Phase of Nuclear Verification power Plants

1. Scope, Applicability and Purpose 1.1 Scope and Applicability.

This standard provides requirements and recommendations for This Standard is intended to be consistent managerial and administrative controls to ensure that activities with applicable criteria for quality associated with operating a nuclear power plant are carried out assurance, including those given in Title without undue risk to the health and safety of the public. 10, Code of Federal Regulations, Part 50, "Licensing of Production and Utilization This standard provides requirements for implementing Facilities," Appendix B. [1]1 managerial and administrative controls consistent with requirements of 10 CFR 50, Appendix B [1].1 This standard is not specifically intended for application to test, mobile, experimental reactors, nor reactors not subject to U.S.

Nuclear Regulatory Commission licensing. Although the standard is based on USNRC requirements the approach is applicable with modifications to reflect the regulatory requirements in the country of application. Applicable sections of this standard may be used in those cases for activities similar to those addressed herein.

1.2 Purpose.

This standard contains requirements for managerial and This Standard fully and completely administrative controls for nuclear power plants during the describes the general requirements and operational phase of plant life. This phase is generally considered guidelines of American National Standard to commence prior to initial fuel loading at a time identified by the Quality Assurance Program Requirements owner organization. Certain initial construction activities may for Nuclear Power Plants, N45.2-1971, [2]

extend past fuel loading and certain operational activities may as those requirements and guidelines take place prior to fuel loading. The owner organization is apply during the operational phase of plant expected to identify those activities that are included in these life.

overlapping time periods and are expected to specify whether the 1

Numbers in brackets refer to corresponding numbers in Sec. 4, References.

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ANS 3.2 Side-By Side Comparison 7/25/2012 activities are to be considered as operational or as construction activities. This phase continues until the operating license is withdrawn.

The managerial and administrative controls of this standard promote safe, reliable and efficient plant operation. This standard may be applied to other activities consistent with the degree to which those activities affect plant reliability. In keeping with this intent, the provisions in this standard may be applied to operational activities other than those specified in the Scope, consistent with the degree to which those activities affect these functions, compliance with regulations specifying radiation dose and contamination criteria, or plant reliability. Applicable portions of this standard may also be used for activities at reactors specifically excluded in the Scope.

This standard is intended to be implemented together with the applicable elements of ASME NQA-1-2008 and the NQA-1a-2009 addenda [2]. ASME NQA-1 is the standard that provides the appropriate Quality Assurance requirements for all phases. This standard provides the managerial and administrative requirements needed to assure safe operation of a facility.

2 Definitions 2. Definitions 2. Definitions 2.1 Glossary of Terms 2.2 Glossary or Term 2.2 Glossary of Terms The terms defined in NQA-1 apply to this standard and are not duplicated herein.

experiments: performance of those plant operations executed Experiments. Performance of those plant Experiments. Performance of those plant under controlled conditions in order to establish characteristics or operational carried out under controlled operations carried out under controlled values not previously known. conditions in ord., to establish conditions in order to establish characteristics or values not previously characteristics or values not previously known.

known.

independent review: review completed by personnel not having Independent review. Review completed Independent review. Review completed by direct responsibility or direct involvement in the work function by personnel not having direct personnel not having direct responsibility 2

ANS 3.2 Side-By Side Comparison 7/25/2012 under review. responsibility for the work function under for the work function under review review regardless of whether they operate regardless of whether they operate as a as a part of an organizational unit or as part of an organizational unit or as individual staff members (see review).

individual staff members (see review ).

managerial and administrative controls: rules, orders, Administrative controls. Rules, order, Administrative controls *. Rules, order instructions, procedures, policies, practices, and designations of instruction&, procedures, policies, instructions, procedures, policies, authority and responsibility. practices and designations of authority practices and designations of authority and responsibility.

and responsibility.

owner organization: the organization, including the on-site Owner organization. The organization, operating organization, that has overall legal, financial, and including the onsite operating technical responsibility for the operation of one or more nuclear organization, which has overall legal, power facilities.

financial and technical responsibility for the operation of one or more nuclear power plants.

operating organization: the organization concerned with daily New Definition operation, maintenance, and related technical services. This organization may include personnel located off-site who provide operational support.

shall, should and may: the word "shall" is used to denote a shall, should and may. The word shall is requirement; the word "should" to denote a recommendation; and used to denote a requirement; the word, the word "may," to denote permission neither a requirement nor a should to denote a recommendation; and recommendation.

the word may to denote permission, neither a requirement nor a recommendation.

3 Requirements 3.1 Organization 3. Owner Organization 3. Owner Organization 3.1.1 General 3.1 General 3.1 General Managerial and administrative controls which comply with this NQA-l, Basic The owner organization shall establish an The owner organization shall establish an standard shall be established. The controls shall be in effect at all Requirement 2. Ok. administrative controls and quality administrative control and quality times during the operational phase. The controls shall require that assurance program which complies with assurance program which complies with 3

ANS 3.2 Side-By Side Comparison 7/25/2012 decisions are made at the proper level and with the necessary this Standard. The program shall be in this standard. The program shall be in reviews. The organization responsible for establishing and effect at all times during the operational effect at all times during the operational executing the administrative controls in accordance with this phase to assure that operational phase phase to assure that operational phase standard may delegate any or all of the work to others, but shall activities are carried out without undue risk activities are carried out without undue risk retain overall responsibility. to the health and safety of the public. The to the health and safety of the public. The program shall require that decision program shall require that decisions affecting safety made at the proper level of affecting safety are made at the proper responsibility and with the necessary level of responsibility and with the technical advice and review. The owner necessary technical advice and review. organization may delegate to other The owner organization may delegate to organizations the work of establishing and executing the administrative controls and other organizations the work of Quality assurance program or any part.

establishing and executing the thereof, in accordance with this standard.

administrative controls and quality but shall retain responsibility there for.

assurance program or any part thereof, in accordance with this Standard, but shall retain responsibility therefore.

3.1.2 Assignment of Authority and Responsibility. 3.2 Assignment of Authority and 3.2 Assignment of Authority and Responsibility Responsibility Lines of authority, responsibility, and communication shall be NQA-1, Basic It is essential that all members of the It is essential that all members of the established and defined for the corporate, plant operating, and Requirement 2. Ok. organization involved in operation of organization involved in operation of support organizations. These relationships shall be documented nuclear power plants, including those at nuclear power plants, including those at and updated, as appropriate, in the form of organizational charts, the highest management levels, recognize the highest management levels, recognize functional descriptions of departmental responsibilities and the necessity that the plants be operated the necessity that the plants be operated relationships and job descriptions for key personnel positions or in under a well formulated and detailed under a well formulated and detailed equivalent forms of documentation. administrative controls and quality administrative control and quality assurance program to assure safety and assurance program to ensure safety and efficiency. Lines of authority, responsibility efficiency. Lines of authority responsibility and communication shall be established and communication shall be established from the highest management level and well defined from the highest through intermediate levels to and management level through intermediate including the onsite operating organization level, to and including all onsite operating (including those offsite organizational units organization position with involvement in assigned responsibility for procurement, activities affecting the safety of the nuclear design and construction, quality power plant including those offsite assurance, and technical support organizational positioning under assigned activities). responsibility for procurement, design and construction, quality assurance and These relationships shall be documented technical support activities.

and updated, as appropriate, in the form of organizational charts, functional These relationships shall be documented 4

ANS 3.2 Side-By Side Comparison 7/25/2012 descriptions or departmental and Updated, as appropriate in the form of responsibilities and relationships and job organizational chart, functional description descriptions for key personnel positions or of departmental responsibilities and in equivalent forms of documentation. The relationships and job description for key owner organization shall specify in writing personnel positioned or in equivalent forms the authority and responsibility assigned to of documentation.

individuals and organizations involved in establishing, executing and measuring the overall effectiveness of the administrative controls and quality assurance program required by this Standard. The persons or organizations responsible for defining and measuring the overall effectiveness of the program shall be designated, shall be sufficiently independent from cost and scheduling considerations when opposed to safety considerations, shall have direct access to responsible management at a level where appropriate action can be accomplished, and shall report regularly on the effectiveness of the program to the plant manager and the cognizant offsite management. Persons or organizations performing functions or assuring that the administrative controls and quality assurance program is established and implemented or of assuring that an activity has been correctly performed shall have sufficient authority and organizational freedom to: identify quality problems; initiate, recommend or provide solutions, through designated channels; and verify implementation of solutions.

The organizational structure and the functional responsibility assignments shall be such that: (1) Attainment of program objectives is accomplished by those who have been assigned responsibility for performing work. This may include interim examinations, checks, and inspections of the work by the individual performing the work. (2) Verification or conformance to established program requirements is accomplished by a qualified person who does not have responsibility for performing 5

ANS 3.2 Side-By Side Comparison 7/25/2012 or directly supervising the work. The method and extent or such verification shall be commensurate with the importance of the activity to plant safety and reliability. In structuring the organization and assigning responsibility, quality assurance should be recognized as an interdisciplinary function involving many organizational component and, therefore, should not be regarded as the sole domain of a single quality assurance group. For example, it may be more appropriate for nuclear engineers to perform reviews of plant nuclear engineering activities rather than quality assurance engineers because of the special .competence required to perform these reviews. Quality assurance encompasses many functions and activities and extends to various levels in all participating organizations. From the top executive to all workers whose activities may influence quality.

3.1.3 Plant Operating Organization 3 .4. 1 General 3 .4. 1 General 3.1.3.1 General NQA-1, Basic A number of factors influence A number of factors influence Requirement 2. Ok. management in its decision regarding the management in its decision regarding the Management shall establish and periodically assess the adequacy of establishment of an onsite operating establishment of an onsite operating the plant operating organization and shall ensure that necessary organization.

organization.

changes to the organization are made in a timely manner.

When establishing the plant operating organization, the owner NQA-1, Basic These include the owner organization's These include the owner organization's organization should evaluate the physical size and complexity of the Requirement 2. Ok. established staffing policies, the physical established staffing policies, the physical nuclear power plant, the number of units, the extent of assistance size and complexity of the nuclear power size and complexity of the nuclear power provided by technical support organizations, and the extent of plant, the number of units, the extent of plant, the number of units, the extent of reliance on consultants and the availability of qualified personnel from other sources. assistance provided by offsite technical' assistance provided by offsite technical support organizations, the extent of support organizations the extent of reliance on consultants and the availability reliance on consultants and the availability of qualified personnel (room other sources of qualified personnel from other sources to assist in activities. such as initial to assist in activities such as initial startup startup, refueling. maintenance or refueling, maintenance or modification 6

ANS 3.2 Side-By Side Comparison 7/25/2012 modification work. work.

3.1.3.1.1 Requirements for the Plant Operating Organization 3. 4. 2 Requirements for the Onsite 3. 4. 2 Requirements for the Onsite Operating Organization Operating Organization The plant operating organization shall include one or more NQA-1, Basic The onsite operating organization shall The Onsite operating organization shall individuals knowledgeable in the following fields: nuclear power plant Requirement 1. Ok. include one or more individuals include. At a minimum, one or more operation; nuclear power plant mechanical systems; nuclear power knowledgeable in the following field. : individual knowledgeable in the following plant electrical systems; instrumentation and control (electronic) nuclear power plant operation; nuclear fields: nuclear power plant operation:

systems; nuclear engineering; heat transfer, fluid flow and power plant mechanical, electrical and nuclear power plant mechanical systems; thermodynamics; chemistry and radiochemistry; radiation protection; electronic systems; nuclear engineering nuclear power plant electrical and risk assessment; and quality assurance. chemistry and radiochemistry; radiation electronic systems; nuclear engineering; protection; and quality assurance. Initial heat transfer, fluid flow and incumbents or replacements (or members thermodynamics; chemistry and of the onsite operating organization and radiochemistry; radiation protection; and offsite technical sup. port organizations quality assurance. Initial incumbents or shall have appropriate experience; training replacements for members of the onsite and retraining to assure that necessary operating organization shall have competence is maintained in accordance appropriate experience, training and with the provisions of American National retraining to assure that necessary Standard for Selection and Training of competence is maintained in accordance Nuclear Power Plant Personnel, NIS.1- with the provisions of American National 1971 Standard for Selection. Qualification Personnel whose qualifications do not and Training of Personnel for Nuclear meet those specified in NlS.l and who are Power Plants, ANS UAN & S.1-l981.

performing inspection. examination, and testing activities during the operations phase of the plant, including preoperational and start-up testing, shall be qualified to American National Standard Qualifications of Inspection, Examination and Testing Personnel for the Construction Phase of Nuclear Power Plants N45.2.6-1973 . except that the QA experience cited for Levels I, II, and III should be interpreted to mean actual experience in carrying out the types of inspection. examination. or testing a being performed.

Staffing requirements for positions in the plants operating Staffing should be in The owner organization shall designate The owner organization shall designate organization that are to be filled by personnel holding NRC alignment with 50.54. those positions in the onsite operating those positions in the onsite operating operator and senior operator licenses are normally delineated in organization which shall be filled by organization which shall be filled by the plants Safety Analysis Report. These positions shall be personnel holding NRC reactor operator personnel holding NRC reactor operator specified. Requirements for the minimum number of personnel and senior reactor operator licenses. and senior reactor operator licenses.

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ANS 3.2 Side-By Side Comparison 7/25/2012 holding such licenses who are to be present at the plant under Requirements for the minimum number of Requirements for the minimum number of various operating conditions and situations shall also be specified, personnel holding such licenses who shall personnel holding such licenses who shall normally in the plants Technical Specifications. be present at the plant under various be present at the plant under various operating conditions and situations shall operating conditions and situations shall also be specified. also be specified.

3.1.3.1.2 Technical Support for the On-Duty Operating Staff 3.4.3 Technical Support of the Off-Duty Operating Staff.

The shift staffing shall include, or have available for consultation, individuals in technical areas that are related to the safe operation The owner organization shall establish of the facility. The technical areas include thermodynamics and provisions for assuring that the shift fluid flow, reactor engineering, systems engineering, transient and accident analysis, instrumentation and controls, quality assurance, organization includes, or has available for radiation protection, and chemistry and radiochemistry. consultation, persons with professional level expertise in technical areas that are related to the safe operation of the plant.

The technical areas include, as a minimum, thermodynamics/fluid flow, reactor engineering, systems engineering transient and accident analysis, radiation protection, and chemistry radiochemistry.

These personnel shall be available (at the station or on call and capable of responding to the plant within two hours) for the purpose of providing technical advice to the shift supervisor on a 24-hour-a-day basis. They may be part of the plant organization or they may be part of the offsite technical support for the plant staff, except that an individual appropriately Qualified in the first four areas listed above shall be onsite and capable of responding to the control room within ten minutes after the start of an emergency.

3.1.4 Operating Organization Authorities and Responsibilities 5.2.1 Responsibilities and Authorities Of Operating Personnel Responsibilities and authorities of plant operating personnel and Essentially, equivalent The responsibilities and authorities of the See 5.2.1.2 below.

those persons assigned to provide immediate support for the plant to 1976 version, plant operating personnel shall be operations personnel shall be delineated for both normal and delineated. These shall include, as a emergency conditions. The following requirements shall be 8

ANS 3.2 Side-By Side Comparison 7/25/2012 established: Section 5.2.1. Ok. minimum:

(1) The reactor operator's Authority and responsibility for shutting the reactor down when he determines that the safety of the reactor is in jeopardy or when operating parameters exceed any of the reactor protection safety system set points and automatic shutdown does not occur.

(2) 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 unscheduled or unexplained power reduction.

(3) 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.

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

(5) The responsibility to adhere to the plant's Technical Specifications.

(6) The responsibility to review routine operating data to assure safe operation.

3.1.4.1 Plant Control Responsibilities 5.2.1 Responsibilities and Authorities 5.2.1 Control of Plant Operations or Operating Personnel Responsibilities and authorities shall be established so that at all Essentially, (1) The reactor operator's Authority and Responsibilities and authorities of onsite times it is clear which individuals have responsibility for directing equivalent to 1976 responsibility for shutting the reactor down operating personnel and those person!

the various plant operating and control room activities. In assigned to provide immediate support for 9

ANS 3.2 Side-By Side Comparison 7/25/2012 addition, there shall be clear identification of the individual(s) version, Section when he determines that the safety of the the onsite operations personnel shall be responsible for determining the circumstances, analyzing the 5.2.1(1) & (2). reactor is in jeopardy or when operating delineated for both normal and emergency cause, and determining that operations may proceed safely after parameters exceed any of the reactor conditions. at minimum. These rules of an unexplained event or before the reactor is returned to power practice shall establish the following:

protection safety system set points and after a trip.

automatic shutdown does not occur.

(2) 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 unscheduled or unexplained power reduction.

3.1.4.2 General Authorities and Responsibilities of Operating 5.2.1 Responsibilities and Authorities 5.2.1.2 General Authorities and Personnel Of Operating Personnel responsibilities of Operating Personnel The general authorities and responsibilities of operating personnel Essentially, equivalent The responsibilities and authorities of the Rules of practice shall clearly delineate the shall be clearly delineated and shall include the following: to 1976 version, plant operating personnel shall be general authorities and responsibilities of Section 5.2.1(1) & (2). delineated. These shall include, as a operating personnel, including the (1) the authority and responsibility of licensed personnel for minimum: following:

shutting down the reactor when it is determined that the safety of (1) The reactor operator's Authority and 1) The reactor operator's authority and the reactor is in jeopardy or when operating parameters exceed responsibility for shutting the reactor down responsibility (or shutting down the reactor any of the reactor protection system set points and automatic when he determines that the safety of the when be determines that; the safety of the shutdown does not occur. reactor is in jeopardy or when operating reactor is in jeopardy or when operating parameters exceed any of the reactor parameters exceed any of the reactor (2) the responsibility to respond conservatively to instrument protection system set points and automatic protection system set points and automatic indications unless they are determined to be incorrect. shutdown does not occur. shutdown does not occur.

(2) The responsibility to determine the (2) The responsibility to behave and (3) the responsibility to adhere to plant procedures (see also circumstances, analyze the cause, and respond conservatively to instrument Section 3.5.1). determine that operational can proceed indications unless they are proved to be safely before the reactor is returned to incorrect (4) the responsibility to adhere to the plant's License Conditions power after a trip or An unscheduled (3) The responsibility to adhere to the and Technical Specifications. unexplained power reduction. plant's operational and emergency (3) The senior reactor operator's procedures. (see also 5.2.21.)

(5) the responsibility to review routine operating data to ensure responsibility to be present at the plant (4) The responsibility to adhere to the safe operation. and to provide direction for returning the plant's Technical Specification.

reactor to power following a trip or an (5) The responsibility to review routine unscheduled or unexplained power operating data to assure safe operation.

reduction.

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

10

ANS 3.2 Side-By Side Comparison 7/25/2012 (5) The responsibility to adhere to the plant's Technical Specifications.

(6) The responsibility to review routine operating data to assure safe operation.

3.1.4.3 Authority and Responsibilities of the Operations Shift 5.2.1 Responsibilities and Authorities. 5.2.1.3 Authority and Responsibilities of Supervisor Of Operating Personnel the Shift Supervisor The operations shift supervisor (sometimes called the Shift New addition. Ok. The responsibilities and authorities of the Rules of practice shall clearly delineate the Manager) shall manage the activities of the operating shift to Similar to 1982 version plant operating personnel shall be authority and responsibilities of the shift ensure integrated direction of all activities. The authority and 5.2.1.3. delineated. These shall include, as a supervisor during normal operation and responsibilities of the operations shift supervisor during normal emergency events, including the minimum:

operation and emergency events shall be clearly delineated and following:

shall include the following:

(1) The reactor operator's authority and (1) The shift supervisor shall have the (1) the operations shift supervisor shall have the authority and responsibility for shutting the reactor down authority and responsibility to direct all responsibility to direct all activities pertaining to plant operations. when he determines that the safety of the activities affecting the safety of the nuclear reactor is in jeopardy or when operating power plant. Transfer of authority and (2) the responsibilities of the operations shift supervisor shall be to parameters exceed any of the reactor responsibility to plant staff members in maintain a comprehensive understanding of operational protection System set points and management levels above the shift conditions that affect the safety of the plant as a matter of highest supervisor shall be predetermined.

automatic shutdown did not occur.

priority. Transfer of this authority and responsibility shall be documented for routine shift Control room command duties, responsibilities, and authorities (2) The responsibility to determine the turnover and emergency conditions.

shall be clearly specified. The operations shift supervisor shall not circumstances, analyze the cause, and become totally involved in any single operation when multiple determine that operation" can proceed (2) The responsibilities of the shift operations are required in the control room. If the operations shift safely before the reactor is returned to supervisor shall be primarily to maintain supervisor is temporarily absent from the control room area during power after a trip or an unscheduled or the broadest perspective of operational routine operations, a qualified licensed senior operator shall be conditions affecting the safety of the plant unexplained power reduction.

designated to assume the control room command function. as a matter of highest priority at all times.

The idea of command and control shall be (3) The senior reactor operator's reinforced and the shift supervisor shall be responsibility to be present at the plant instructed not to become totally involved in and to provide direction for returning, the any single operation in times of emergency reactor to power following, a trip or an when multiple operations are required in unscheduled or unexplained power the control room. If the shift supervisor is reduction. temporarily absent from the control room during routine operations, a lead control (4) The responsibility to believe and room operator shall be designated to assume the control room command respond conservatively to instrument function. Temporary duties, indications until they are proved incorrect. responsibilities, and authority shall be clearly specified.

(5) The responsibility to adhere to the plant's Technical Specifications. (3) During emergency conditions, the duty station for the shift supervisor shall be the 11

ANS 3.2 Side-By Side Comparison 7/25/2012 (6) The responsibility to review routine central control room. The shift supervisor, operating data to ensure safe operation. until properly relieved, shall remain in the control room at all times during such situations to direct the activities of control room operators.

In order to perform the preceding functions effectively, the Worded slightly 3.4.2 Requirements for the Onsite 3.4.2 Requirements for the onsite operations shift supervisor shall not be encumbered with different than 1976 Operating Organization Operational Organization unnecessary on-shift administrative duties. version, Section 3.4.2.

The onsite operating organization shall The Onsite operating organization shall Intent is the same. Ok.

include one or more individuals include. At a minimum, one or more knowledgeable in the following individual knowledgeable in the following field!!:nuclear power plant operation; fields: nuclear power plant operation:

nuclear power plant mechanical, electrical nuclear power plant mechanical systems; and electronic systems; nuclear nuclear power plant electrical and engineering chemistry and radiochemistry; electronic systems; nuclear engineering; radiation protection; and quality heat transfer, fluid flow and assurance. Initial incumbents or thermodynamics; chemistry and replacements (or members of the onsite radiochemistry; radiation protection; and operating organization and offsite quality assurance. Initial incumbents or technical support organizations shall have replacements for members of the onsite appropriate experience; training and operating organization shall have retraining to assure that necessary appropriate experience, training and competence is maintained in accordance retraining to assure that necessary with the provisions of American National competence is maintained in accordance Standard for Selection and Training of with the provisions of American National Nuclear Power Plant Personnel, NIS.1- Standard for Selection. Qualification 1971. and Training of Personnel for Nuclear Power Plants, ANS UAN & S.1-l981.

Personnel whose qualifications do not meet those specified in NlS.l and who are performing inspection. examination, and testing activities during the operations phase of the plant, including preoperational and start-up testing, shall be qualified to American National Standard Qualifications of Inspection, Examination and Testing Personnel for the Construction Phase of Nuclear Power Plants. N45.2.6-1973 (5]. except that the QA experience cited for Levels I, II, and III should be interpreted to mean actual experience in carrying out the types of 12

ANS 3.2 Side-By Side Comparison 7/25/2012 inspection. examination. or testing activity being performed. The owner organization shall designate those positions in the onsite operating organization which shall be filled by personnel holding NRC reactor operator and senior reactor operator licenses. Requirements for the minimum number of personnel holding such licenses who shall be present at the plant under various operating conditions and situations shall be specified. The Plant Manager shall have Overall responsibility for the execution of the administrative control.

and quality assurance program at the plant to assure safety. An individual or organizational unit knowledgeable and experienced in nuclear power plant operational phase activities and quality assurance practice: shall be designated and assigned the responsibility to verify that the program is being effectively implemented. Depending on the organizational structure, the individual or organizational unit may report functionally to offsite plant management or an offsite organization (see also 3.2). Reporting to onsite plant management is preferable since such an arrangement usually resulting in improved communications in identifying problems and initiating corrective action. The individual or organizational unit in this case may receive technical guidance from offsite support groups. This individual's or organizational unit's duties and responsibilities shall be such that the required attention can be devoted, as required, to verifying that the program is being effectively executed. The individual 13

ANS 3.2 Side-By Side Comparison 7/25/2012 or organizational unit shall report on the effectiveness of the program to the Plant Manager and to either cognizant management as may be designated. The activities shall be periodically audited by designated offsite personnel.

3.1.4.4 Responsibilities of Others in the Plant Operating 3.4.2 Requirements for the Onsite 3.4.2 Requirements for the Onsite Organization Operating Organization. Operational Organization The authority and responsibility of other personnel whose actions or New addition. Ok. The onsite operating organization shall The Onsite operating organization shall decisions could affect normal plant operations or exacerbate an include one or more individuals include. At a minimum, one or more abnormal or accident condition shall be delineated. As a minimum, §No discussion of the knowledgeable in the following individual knowledgeable in the following personnel performing maintenance or testing shall not work on plant role of the Plant field:nuclear power plant operation; fields:nuclear power plant operation:

systems and equipment unless permission has been granted by Manager, as in 1976 nuclear power plant mechanical, electrical nuclear power plant mechanical systems; designated operating personnel. and electronic systems; nuclear nuclear power plant electrical and version, Section 3.4.2. engineering chemistry and radiochemistry; electronic systems; nuclear engineering; radiation protection; and quality heat transfer, fluid flow and assurance. Initial incumbents or thermodynamics; chemistry and replacements (or members of the onsite radiochemistry; radiation protection; and operating organization and offsite quality assurance. Initial incumbents or technical support organizations shall have replacements for members of the onsite appropriate experience; training and operating organization shall have retraining to assure that necessary appropriate experience, training and competence is maintained in accordance retraining to assure that necessary with the provisions of American National competence is maintained in accordance Standard for Selection and Training of with the provisions of American National Nuclear Power Plant Personnel, NIS.1- Standard for Selection. Qualification and 1971. Training of Personnel for Nuclear Power Personnel whose qualifications do not Plants ANSI/ANs 3.1-l981 (SI Personnel meet those specified in NlS.l and who are whose qualifications are not addressed in performing inspection. examination, and ANS-3.1 and who are performing testing activities during the operations inspection, examination, and testing phase of the plant, including activities during the operations phase of preoperational and start-up testing, shall the plant.. including preoperational and be qualified to American National start-up testing. shall be qualified in Standard Qualifications of Inspection, accordance with the requirements of Examination. And Testing Personnel for NQA-1-1979, except that cited experience the Construction Phase of Nuclear Power shall be limited to actual experience in Plants. N45.2.6-1973. except that the QA carrying out the types of inspection.

experience cited for Levels I, II, and III examination, or testing activity being should be interpreted to mean actual performed. The owner organization shall experience in carrying out the types of designate the position in the onsite inspection. examination. or testing activity operating organization which shall be filled 14

ANS 3.2 Side-By Side Comparison 7/25/2012 being performed. by personnel holding NRC operator and senior operator license. Requirements for the minimum number of personnel holding such licenses who shall be present at the plant under various operating conditions and situation shall also be specified_

3.1.4.5 Transfer of Authority and Responsibility 5.2.1.4 Transfer of Responsibility Transfer of authority and responsibility to plant staff members in New addition. Ok. Rules of practice shall be established for management levels above the operations shift supervisor shall be the transfer of responsibility from one shift predetermined. The transfer of responsibility from one shift to Similar to 1982 to another, as well as the transfer of another, as well as the transfer of authority during emergency version, Section authority during emergency conditions.

conditions shall be documented and shall involve: 5.2.1.4. These rules of practice shall delineate:

(1) Persons authorized to relieve the operations shift supervisor. (1) Persons authorized to relieve the shift Only personnel meeting the qualification requirements of the supervisor.

operations shift supervisor position shall relieve the on-duty shift supervisor. (2) The line of ascension of authority during both normal and emergency (2) The line of ascension of authority. conditions when one or more persons of management authority above the shift (3) The authority and limitations of technical and management supervisor are present in the central personnel to direct activities in the control room. control room. Only personnel meeting the qualification requirements of the shift supervisor position shall have the authority to relieve the on-duty shift supervisor from the responsibility to direct activities affecting the safety of the nuclear power plant.

(3) The authority, and limitations thereon, of technical and management personnel to direct activities in the central control room.

(4) Interfaces between groups such as the utility's corporate organization, vendors, the architect-engineer, contractors and consultants, NRC and other local state or federal agencies.

To ensure that personnel on succeeding shifts have a clear New addition. Ok. See above understanding of the condition of equipment and systems, each on-shift duty station shall have procedures for the turnover of duties. Similar to 1982 These procedures shall include documented turnover action version, Section appropriate to the duty station acknowledging the status of the plant 15

ANS 3.2 Side-By Side Comparison 7/25/2012 and transfer of authority. 5.2.1.4.

Overall plant status, maintenance and test status, planned activities, and any identified trends applicable to the duty station shall be explained. In addition, the following items shall be identified:

(1) critical parameters that are not within normal limits, (2) systems that are not in their normal configuration, or are in a degraded mode of operation permitted by the Technical Specifications, and (3) any time that limitations are placed on continued operation.

3.1.4.6 Control Room Access 5.2.9 Plant Security and Visitor Control 5.2.1.5 Control Room Access Access to the control room shall normally be limited to on-shift New addition. Ok. Procedures shall be developed to Access to the control room shall normally personnel and other persons whose job function requires their Similar to 1982 supplement features and physical barriers be limited to assigned shift personnel and physical presence in the control room. Access to the control room version, Section design to control access to the pant and as other persons whose job function requires for the purpose of general familiarization and other non-work-related their physical presence in the control room.

5.2.1.5. appropriate to vital area within the plant activities shall be authorized only for good cause. This control shall be exercised by physical information concerning specification security controls and by administrative Slightly similar to 1976 designated features and administrative controls implemented by the shift version, Section 5.2.9. provision of the plant and visitors controls supervisor or other emergency procedures such as fences and lightings coordinators that have assumed control.

lock control for doors gates and Access to the control room for the purpose compartments ..the security and visitors of general familiarization and other non-work-related activities shall be authorized control for doors gates an challenging of only for good cause. To facilitate the strangers By operating crew and a program assistance by technical support personnel of reemployment screening (or potential to the shift operating crew in an employee. See American National Standard emergency, provisions shall be made to Industrial Security for Nuclear Power Plant, provide a technical support center for N18.7-1971, for guidance and provisions for these persons security measures adequate to protect nuclear power plants.

16

ANS 3.2 Side-By Side Comparison 7/25/2012 During emergency conditions, access to the control room should New addition. Ok. N/A See above also be limited. A technical support center, operational support Similar to 1982 center, and emergency operations facility are provided for support version, Section personnel.

5.2.1.5.

3.2 Program The managerial and administrative controls employed shall provide control over activities affecting the quality of safety-related structures, systems, and components to an extent consistent with the scope and purpose of this standard.

Managerial and administrative controls shall establish requirements pertaining to the conduct and control of plant activities such that affected personnel are provided with a clear understanding of operating philosophy and management policies, as well as methods and techniques for performing required work.

These controls shall be established in appropriate policies, procedures, and/or instructions for the operating and support organizations.

3.2.1 Operating Organization Review The operating organization shall provide, as a part of the normal .

duties of plant supervisory personnel, timely and on-going monitoring of operating activities to assist the plant manager in keeping abreast of general plant conditions and to verify that day-to-day operations are conducted safely in accordance with the established administrative controls. These monitoring activities are considered to be an integral part of the routine supervisory function and are important to the safety of plant operation.

The operating organization shall perform reviews periodically and as situations demand, to evaluate plant operations and plan future activities. The important elements of the reviews shall be documented. Such reviews serve a useful purpose but shall not take the place of the reviews described in Section 3.2.2, or audits described in Section 3.18. The onsite operating organization 17

ANS 3.2 Side-By Side Comparison 7/25/2012 shouldscreen subjects of potential concern to independent reviewers (see section 3.2.2.2 (1) through (8)) and perform preliminary investigations. The plant manager shall ensure the timely referral of the applicable matters discussed in the reviews to appropriate management and independent reviewers.

3.2.2 Independent Review 4.3 Independent Review Program 4.3 Independent Review Program Activities occurring during the operational phase shall be Activities occurring during the operational Activities occurring during the operational independently reviewed on a periodic basis. The independent phase shall be independently reviewed on phase shall be independently reviewed on review program shall be functioning prior to initial core loading. a periodic basis. The independent review a periodic basis. The independent review This Standard does not advocate any specific organizational program shall be functional prior to initial program shall be functional prior to initial structure for complying with the independent review function, but, core loading.

in lieu thereof, delineates essential elements of satisfactorily core loading.

comprehensive programs for review that shall be applied in the manner best suited to the owner organization involved. An Independent Review Body (IRB) as described in 3.2.2.3 or an Independent Review Committee (IRC) as described in 3.2.2.4 shall be used to perform the independent review function. The terms IRB and IRC are intended to be generic in nature and may be substituted with the specific owner organizations terms.

3.2.2.1 Personnel 4.3.1 Personnel 4.3.1 Personnel Personnel assigned responsibility for independent review shall be IAW NRC Safety Personnel assigned responsibility Personnel assigned responsibility specified, in both number and technical disciplines, and shall Evaluation for independent reviews shall be for independent reviews shall be collectively have the experience and competence required to ML050210276 specified, in both number and technical specified, in both number and technical review problems in the following areas: disciplines, and shall collectively have the disciplines, and shall collectively have the experience and competence required to experience and competence required to review problems in the following areas; review problems in the following areas; (1) Nuclear power plant operations (1) Nuclear power plant operations (1) Nuclear power plant operations (2) Nuclear engineering (2) Nuclear engineering (2) Nuclear engineering (3) Chemistry and radiochemistry (3) Chemistry and radiochemistry (3) Chemistry and radiochemistry (4) Metallurgy (4) Metallurgy (4) Metallurgy (5) Nondestructive testing (5) Nondestructive testing (5) Nondestructive testing 18

ANS 3.2 Side-By Side Comparison 7/25/2012 (6) Instrumentation and control (6) Instrumentation and control (6) Instrumentation and control (7) Radiological safety (7) Radiological safety (7) Radiological safety (8) Mechanical engineering (8) Mechanical engineering and Electrical (8) Mechanical engineering engineering (9) Electrical engineering (9) Electrical engineering (9) Administrative controls and quality (10) Administrative control and quality assurance practices assurance practices (10) Administrative controls and quality assurance practices (11) Training (10) Other appropriate fields associated with the unique characteristics of the (11) Emergency plans and related (12) Emergency plans and related procedures and equipment. nuclear power plant involved. organization, procedure and equipment (12) Other appropriate fields associated with the unique characteristics of the nuclear power plant involved.

An individual may possess competence in more than one An individual may possess competence in An individual may possess competence in specialty area. If sufficient experience is not available within the more than one specialty area. If sufficient more than one specialty area. If sufficient owner organization, independent reviews shall be supplemented expertise is not available from within the expertise is not available from within the through outside consultants or organizations. Provisions shall be owner organization, independent reviews owner organization, independent reviews made to assure that appropriate expertise is brought to bear in shall be supplemented through outside shall be supplemented through outside reviews of operational phase activities. consultants or organizations. consultants or organizations.

Provisions shall be made to assure that Provisions shall be made to assure that appropriate expertise is brought to bear in appropriate expertise is brought to bear in reviews of operational phase activities. reviews of operational phase activities.

Persons fulfilling the independent review function shall be IAW NRC Safety qualified as follows: Evaluation ML050210276 (1) Supervisor or Chairperson:

a. Education: baccalaureate in engineering or related science.

b. Minimum experience: 6 years combined managerial and technical support.

(2) Reviewers:

a. Education:

- Baccalaureate in engineering or related science for those independent review personnel who are required to review problems in nuclear power plant operations, nuclear engineering, chemistry and radiochemistry, metallurgy, nondestructive testing, 19

ANS 3.2 Side-By Side Comparison 7/25/2012 instrumentation and control, radiological safety, mechanical engineering, and electrical engineering.

- High school diploma or equivalent for those independent review personnel who are required to review problems in administrative control and quality assurance practices, training, and emergency plans and related procedures and equipment.

- Alternatives to the education requirements may be applied consistent with USNRC Regulatory Guide 1.8 [4].

b. Minimum experience: 5 years experience in their own area of responsibility (1 through 12 above).

3.2.2.2 Scope of Review 4.3.4 Subjects Requiring Independent 4.3.4 Subjects Requiring Independent Review Review The independent review function shall perform the following: The following subjects shall be The following subjects shall be reviewed by the independent review body: reviewed by the independent review body:

(1) Reviews proposed changes to the facility as described in the (1) Written safety evaluations of changes (1) Written safety evaluations of changes safety analysis report (SAR) and verifies that changes do not in the facility as described in the Safety in the facility as described in the Safety adversely affect safety and if a technical specification change or Analysis Report, changes in procedures Analysis Report, changes in procedures as NRC review is required. as described in the Safety Analysis Report described in the Safety Analysis Report and tests or experiments not described in and tests or experiments not described in the Safety Analysis Report which are the Safety Analysis Report which are completed without prior NRC approval completed without prior NRC approval under the provisions of 10 CFR under the provisions of 10 CFR 50.59(a)(1). This review is to verify that 50.59(a)(1). This review is to verify that such changes, tests or experiments did such changes, tests or experiments did not not involve a change in the technical involve a change in the technical specifications or an unreviewed safety specifications or an unreviewed safety question as defined in10CFR 50.59(a)(2). question as defined in10CFR 50.59(a)(2).

(2) Reviews proposed tests and experiments not described in the (2) Proposed changes in procedures, (2) Proposed changes in procedures, SAR prior to implementation. Verifies the determination of Proposed changes in the facility, or Proposed changes in the facility, or whether changes to proposed tests and experiments not proposed tests or experiments any of proposed tests or experiments any of described in the SAR require a technical specification change or which involves a change in the technical which involves a change in the technical license amendment. specification or an unreviewed safety specification or an unreviewed safety question as defined in 10 CFR 50.59(c). question as defined in 10 CFR 50.59(c).

. Matters of this kind shall be referred to the Matters of this kind shall be referred to the independent review body by the 0nsite independent review body by the 0nsite operating organization (see 4.4) following operating organization (see 4.4) following 20

ANS 3.2 Side-By Side Comparison 7/25/2012 its review, or by other functional its review, or by other functional organizational units within the owner organizational units within the owner organization, prior to implementation. organization, prior to implementation.

(3) Reviews proposed technical specification changes and license (3) Changes in the technical specifications (3) Changes in the technical specifications amendments relating to nuclear safety prior to NRC submittal and or license amendments relating to nuclear or license amendments relating to nuclear implementation, except in those cases where the change is safety prior to implementation, except in safety prior to submittal to the Commission identical to a previously approved change. those cases where the change is identical for approval and prior to implementation.

to a previously reviewed proposed change.

(4) Reviews violations, deviations, and events that are required to (4) Violations, deviations, and reportable (4) Violations, deviations, and reportable be reported to the NRC. This review includes the results of events which require reporting to the NRC events which require reporting to the NRC investigations and recommendations resulting from such in writing 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, such as in writing.

investigations to prevent or reduce the probability of recurrence of the event. Review of events covered under this subsection shall include the results of any investigations made and the recommendations resulting from such investigations to prevent or reduce the probability of recurrence of the event.

(5) Reviews any matter related to nuclear safety that is requested (5) Any other matter involving safe by the plant manager or any IRB/IRC member. operation of the nuclear power plant which an independent reviewer deems appropriate for consideration, or which is referred to the independent reviewers by the onsite operating organization or by other functional organizational units within the owner organization.

(6) Reviews corrective actions for significant conditions adverse to quality.

(7) Reviews internal audit reports.

(8) Reviews the adequacy of the internal audit program every 24 months.

3.2.2.3 Independent Review Body 21

ANS 3.2 Side-By Side Comparison 7/25/2012 A group may function to perform the reviews of 3.2.2.2 and is IAW NRC Safety described as an independent review body (IRB). In discharging Evaluation its review responsibilities, the IRB keeps safety considerations ML050210276 paramount when opposed to cost or schedule considerations.

One or more organizational units may collectively perform this function.

1. The IRB reviews shall be supplemented as follows:

a. A qualified person, independent of the preparer, reviews proposed changes in the procedures as described in the SAR prior to implementation of the change to determine if a technical specification change or NRC approval is required.

b. Audits of selected changes in the procedures described in the SAR are performed to verify that procedure reviews and revision controls are effectively implemented.

c. Competent individual(s) or group(s) other than those who performed the original design but who may be from the same organization verify that changes to the facility do not result in a loss of adequate design or safety margins.

2. The results of IRB reviews of matters involving the safe operation of the facility are periodically independently reviewed. This review is intended to support management in identifying and resolving issues potentially affecting safe plant operation. This review supplements the existing corrective action programs and audits.

a. The review is performed by a team consisting of personnel with experience and competence in the activities being reviewed, but independent from cost and schedule considerations and from the organizational unit[s]

responsible for those activities.

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

c. Results of the review are documented and reported to responsible management.

22

ANS 3.2 Side-By Side Comparison 7/25/2012

d. Management periodically evaluates issues they determine warrant special attention, such as deficient plant programs, declining performance trends, employee concerns, or other issues related to safe plant operations and determine what issues warrant the review.

e. Management determines the scheduling and scope of review and the composition of the team performing the review.

3.2.2.4 Independent Review Committee 4.3.2.1 Committee Composition When an independent review committee is assigned independent IAW NRC Safety When a standing committee is responsible review responsibilities: Evaluation for the independent review program. it ML050210276 shall be composed of no less than five

1. The independent review committee reports to a management persons, of whom no more than a minority level above the plant manager. are members of the onsite operating organization. Competent alternates are

2. The independent review committee shall be composed of no permitted if designated in advance. The less than 5 persons and no more than a minority of members are use of alternates shall be restricted to from the on-site operating organization. Competent alternates are legitimate absences of principals.

permitted if designated in advance. The use of alternates shall be restricted to legitimate absence of the principles.

3. Results of the meeting shall be documented and recorded and disseminated promptly to appropriate members of management having responsibility in the area reviewed.

4. Consultants and contractors are used for the review of complex problems beyond the expertise of the independent review committee.

5. During the period of initial operation, meetings shall be 4.3.2.2 Meeting Frequency 4.3.2.2 Meeting Frequency conducted no less frequently than once per calendar quarter. Formal meetings of personnel assigned to Formal meetings of personnel assigned to Afterwards meetings are conducted no less than twice a year. a standing committee functioning as an a standing committee functioning as an independent review group shall be independent review group shall be scheduled as needed. During the period of scheduled as needed. During the period of initial operation such meetings should be initial operation such meetings should be held no less frequently than once per held no less frequently than once per calendar quarter. Subsequently, the calendar quarter. Subsequently, the meeting frequency shall not be less than meeting frequency shall not be less than twice a year. twice a year.

It is intended that committee decisions 23

ANS 3.2 Side-By Side Comparison 7/25/2012 normally be made at formal meetings.

However, in extenuating circumstances where it is impractical to convene a quorum for a formal meeting within a necessary time constraint, alternative means such as a conference call are acceptable. In such cases, action taken shall be reviewed by a quorum of the independent review body at its next regularly scheduled meeting.

6. A quorum for formal meetings shall consist of not less than a 4.3.2.3 Quorum 4.3.2.3 Quorum majority of the members, or duly appointed alternates. The A quorum for formal meetings of the A quorum for formal meetings of the chairperson or duly appointed alternate shall be present for all committee held under the provisions of committee held under the provisions of meetings; and no more than a minority of the quorum shall have 4.3.2.2 shall consist of not less than a 4.3.2.2 shall consist of not less than a line responsibility for operation of the plant. majority of the principals, or duly majority of the principals, or duly appointed appointed alternates, and shall be subject alternates, and shall be subject to the to the following constraints: the chairman following constraints: the chairman (or his duly appointed alternate) shall be present (or his duly appointed alternate) shall be for all formal meetings; and no more than a present for all formal meetings; and no minority of the quorum .shall have line more than a minority of the quorum .shall responsibility for operation of the plant.

have line responsibility for operation of the plant.

3.2.3 Indoctrination and Training Qualification requirements for positions in the plant operating Refers to guidance in organization shall be established in accordance with the provisions NQA-1 of plant technical specifications, American National Standard for Selection, Qualification and Training of Personnel for Nuclear Power Plants, USNRC Regulatory Guide 1.8 [4]. USNRC Regulatory Guide 1.8 [4].or ASME NQA-1-2008 and the NQA-1a-2009 addenda [2] as applicable.

Training shall be in accordance with ASME NQA-1-2008 and the NQA-1a-2009 addenda [2].

3.2.4 Maintenance 24

ANS 3.2 Side-By Side Comparison 7/25/2012 Maintenance activities that may affect the functions of structures, systems, or components shall:

NRC did not endorse (1) be performed in a manner to assure quality, availability, and subpart 2.18 of NQA-1 reliability at least equivalent to that specified in the original or in RG1.33.

updated design bases and requirements.

(2) provide for the conduct of appropriate inspections and performance tests to demonstrate that maintenance has been properly performed. See note under section 2.2 (3) be planned and performed in accordance with written procedures, documented instructions or drawings appropriate to the Would affect the circumstances which conform to applicable codes, standards, Glossary.

specifications, and criteria.

(4) be documented in accordance with applicable codes, standards and regulatory commitments. This documentation shall be retained May be needed to as specified in 3.17.

support section 5.2.7 (5) be scheduled and planned so as not to violate plant Technical and 5.2.7.1 in ANS Specifications or compromise the safety of plant personnel or 3.2-1976 version.

equipment. Planning shall evaluate the possible safety consequences of concurrent or sequential maintenance, testing or operating activities. Equipment required to be operable for the prevailing mode shall be available, and maintenance shall be performed in a manner such that license limits are not violated.

Planning for maintenance shouldinclude evaluation of equipment out-of-service to ensure the increased risk is known and compensatory measures are taken when appropriate. Planning should also evaluate the use of special processes, equipment and materials, potential hazards to personnel and equipment and the benefits of minimizing equipment unavailability.

(6) contain general rules for the development, review, and approval, prior to use, of repair, replacement, recurring, and routine maintenance procedures consistent with the provisions of this standard.

(7) provide for a preventive maintenance program, based on performance and condition monitoring, that prescribes the frequency and type of maintenance to be performed. A preliminary program based on service conditions, industry experience with comparable equipment and supplier recommendations, should be developed prior to fuel loading. The program should be revised and updated as 25

ANS 3.2 Side-By Side Comparison 7/25/2012 experience is gained with the equipment. Equipment history files should be created, kept current, and periodically evaluated for adverse trends. The files should be organized to provide complete and easily retrievable equipment history.

(8) provide for the prompt determination, evaluation, recording, and dissemination to appropriate personnel of the causes of malfunctions or unacceptable performance (see also Section 3.16).

Industry experience with malfunctioning equipment shouldbe reviewed and evaluated to determine whether a component of the same type can be expected to perform its function reliably.

(9) provide requirements to implement appropriate corrective actions prior to replacement or repair of similar components in systems that performed unsatisfactorily.

(10) address aging, generic, and common cause effects to prevent possible recurrence and to inform appropriate industry communication organizations.

(11) provide assurance that replacement components shall receive adequate testing or shall be of a design for which experience indicates a high probability of satisfactory performance.

(12) evaluate phased replacement to permit in-service monitoring of new components thus minimizing the possibility of a hidden deficiency producing a systematic failure.

(13) evaluate implementing and monitoring an augmented testing and inspection program following a large-scale component replacement (or repair) until such time that a suitable level of performance has been demonstrated.

3.2.5 Housekeeping and Cleanliness Control Housekeeping and cleanliness shall be controlled in accordance NRC did not endorse with ASME NQA-1-2008 and the NQA-1a-2009 addenda [2]. subpart 2.18 of NQA-1 in RG1.33.

26

ANS 3.2 Side-By Side Comparison 7/25/2012 May be needed to support section 5.2.7 and 5.2.7.1 in ANS 3.2-1976 version.

3.3 Design Control Design activities, including modifications, associated with Essentially, equivalent structures, systems, and components (SSC)s shall be controlled to NQA- 1. Ok.

in accordance with ASME NQA-1-2008 and the NQA-1a-2009 addenda [2].

1982 version states to do IAW NQA-1. No unique additional requirements.

3.4 Procurement Document Control Procurement Documents shall be controlled in accordance with Essentially, equivalent ASME NQA-1-2008 and the NQA-1a-2009 addenda [2]. to NQA- 1. Ok.

1982 version states to do IAW NQA-1. No unique additional requirements.

3.5 Instructions, Procedures, and Drawings Instructions, procedures, and drawings shall be used in accordance with ASME NQA-1-2008 and the NQA-1a-2009 addenda [2]. Appendix A includes a listing of typical procedures that are considered to affect safe operation or the quality of SSCs 27

ANS 3.2 Side-By Side Comparison 7/25/2012 that shouldbe addressed through the managerial and administrative controls program. Specific requirements for operational procedures are as follows.

3.5.1 Procedure Adherence 5.2.2 Procedure Adherence 5.2.2 Procedure Adherence Procedures shall be followed, and the requirements for their use Essentially, equivalent Procedure shall be followed, and the Procedures shall be (allowed, and the shall be prescribed in writing. Procedures and changes thereto are to NQA-1. requirements for use of procedures shall be requirements for use of procedures shall controlled in accordance with Section 3.6 of this standard. prescribed in writing. Rules shall be be prescribed in writing. Rules shall be established which provide methods by established which provide methods by which temporary changes to approved which temporary changes to approved procedures can be made, including the procedures can be made. including the designation of 8 person or persons designation of a person or persons authorized to approve such changes.

Similar to 1982 authorized to approve such changes. Temporary changes which clearly do not version, Section5.2.2. change the intent of the approved Temporary changes which clearly do not change the intent of the approved procedure, shall as a minimum be approved by two members of the plant procedure, shall at a minimum be approved staff knowledgeable in the areas affected by two member of the plant staff by the procedure. At least one of these knowledgeable in the areas affected by the shall be a member of plant supervision.

procedures. At least one of these individuals For changes to procedures which may shall be the supervisor in charge of the shift affect the operational status of plant and hold a senior operators license on the systems or equipment. the changes shall unit affected. Such changes shall be be approved by two members of the plant supervision, at least one of whom holds a documented and if appropriate, incorporated senior operator' License on the unit in the next revision of the affected affected. Such changes shall be procedure. documented and, if appropriate.

incorporated in the next revision of the affected procedure.

In the event of an emergency not covered by an approved Essentially, equivalent In the event of an emergency not covered In the event of an emergency not covered procedure, or an emergency not following the path upon which the to ANS 3.2 1976, by an approved procedure, operations by an approved procedure, or an approved procedure is based, operations personnel shall be section 5.2.2. personnel shall be instructed to take action emergency not following the path upon instructed to take action so as to protect public health and safety, so as to minimize personnel injury and which the approved procedure is based, and minimize personnel injury and damage to the facility.

damage to the facility and to protect health operations personnel shall be instructed to and safety. take action so as to protect health and safety, and minimize personnel injury and damage to the facility.

28

ANS 3.2 Side-By Side Comparison 7/25/2012 Guidance should be provided to identify the manner in which Essentially, equivalent Guidance should be provided to identify the Guidance should be provided to identify procedures are to be implemented. Examples of such guidance to ANS 3.2 1976, manner in which procedures are to be the manner in which procedures are to be include identification of those tasks that require: section 5.2.2. implemented. implemented. Examples of such guidance include identification of those tasks that Example of such guidance include require:

identification of those tasks that require:

(1) The written procedure to be present and followed step-by-step Essentially, equivalent (1) The written procedure to be present (l) The written procedure to be present.

while the task is being performed. to ANS 3.2 1976, and followed step by step while the task is Either on paper or on a suitable electronic section 5.2.2. being performed or other display, and followed step by step while the task is being performed.

(2) Memorization of procedural steps. Essentially, equivalent (2) The operator to have committed the (2) The operator to have committed the to ANS 3.2 1976, procedural step to memory procedural steps to memory.

section 5.2.2.

(3) Verification of completion of significant steps, by initials or Essentially, equivalent (3) Verification of completion of significant (3) Verification of completion of significant signatures on check-off lists. Startup and shutdown procedures to ANS 3.2 1976, steps by initial or signature of \check off steps. by initials or signatures of check off are examples of procedures that require verification. section 5.2.2. list lists.

The types of procedures that shall be present and referred to directly Essentially, equivalent 5.2.2 Procedure Adherence Procedure The types of procedures that shall be are those developed for extensive or complex jobs where reliance on to ANS 3.2 1976, shall be followed and the requirement for present and referred to directly are those memory cannot be trusted, e.g., reactor startup, tasks which are section 5.2.2. use of procedures shall be prescribed in developed for extensive or complex jobs infrequently performed, and tasks in which operations shall be where reliance on memory cannot be writing. Rules shall be established which performed in a specified sequence, and emergency operating trusted. e.g. reactor startup tasks which procedures. Routine procedural actions that are frequently repeated provide methods by which temporary are infrequently performed, and tasks in may not require the procedure to be present; however, periodic changes to approved procedures can be which operation must be performed in a procedure reference may be needed to verify the adequacy of made, including the designation of a specified sequence. Procedural steps for procedures and task performance, and accurate adherence. Copies person or persons authorized to approve which actions should be committed. to of all procedures shall be available to appropriate members of the such changes. Temporary changes which memory include. for example, immediate plant staff. clearly do not change the intent of the actions in emergency procedures. Routine procedural actions that. Are frequently approved procedure shall at a minimum be repeated might not require the procedure approved by two members of the plant to be present. Copies of all procedure shall Those procedures that are necessary for use by the reactor staff knowledgeable in the areas affected be available to appropriate members of the operators shall be available and readily accessible in the control by the procedures. At least one of these plant staff. Those procedures which may room. If an electronic display is relied upon as the written procedure, individuals shall be the supervisor in be necessary for' use by the reactor a hard copy should be available as backup. If documentation of an charge of the shift and hold a senior operators shall be available in the control action is required, the necessary documentation shall be recorded as room. If documentation of an action is operators license on the unit affected.

the task is performed. required the necessary data shall be Such changes shall be documented and if recorded as the task is performed.

appropriate, incorporated in the next Examples of procedures requiring 29

ANS 3.2 Side-By Side Comparison 7/25/2012 revision of the affected procedure. In the verification are furnished in 5.3.4.1 and event of an emergency not covered by an 5.3.4.2.

approved procedure, operations personnel shall be instructed to take action so as to minimize personnel injury and damage to the facility and to protect health and safety. Guidance should be provided to identify the manner in which procedures are to be implemented. Examples of such guidance include identification of those skill that require:

(1) The written procedure to be present followed step by step while the task is being performed (2) The operator to have committed the procedural steps to memory (3) Verification of completion of significant steps by initial or signature of check off list The type of procedures that shall he present and referred to directly are those developed examples jobs where reliance on memory cannot be trusted. e.g., reactor "start-up tasks which are infrequently Performed any tasks in which operation) must be performed in a specified sequence. Procedure steps for which action should be committed to memory include, or example, action in emergency procedures. Routine procedural actions that are frequently repeated may not require the procedure to be present Copies of all procedures shall be available to appropriate members of the plant staff documentation of an action is required. the necessary data shall be recorded as the task is performed. Examples of procedure requiring verification are furnished in 30

ANS 3.2 Side-By Side Comparison 7/25/2012 5.3.4.1 And 5.3.4:2.

3.5.2 Content and Format Procedure format and content may vary from one owner See section 5.3.2 of organization, or group therein, to the other. However, procedures 3.5.1 on the ANS 3.2 shall include the following elements as appropriate to the purpose sheet or task to be described.

3.5.2.1 Title/Status Each procedure is given a title descriptive of the work or subject it See section 5.3.2 of addresses, and includes a revision number and/or date and an 3.5.1 on the ANS 3.2 approval status. sheet 3.5.2.2 Purpose/Statement of Applicability/Scope The purpose for which the procedure is intended is clearly stated See section 5.3.2 of (if not clear from the title). The systems, structures, components, 3.5.1 on the ANS 3.2 processes or conditions to which the procedure applies are also sheet clearly described.

3.5.2.3 References Applicable references, including reference to appropriate See section 5.3.2 of Technical Specifications, are required. References are included 3.5.1 on the ANS 3.2 within the body of the procedure when the sequence of steps sheet requires other tasks to be performed (according to the reference) prior to or concurrent with a particular step.

3.5.2.4 Prerequisites/Initial Conditions Prerequisites/initial conditions identify those independent actions See section 5.3.2 of or procedures that shall be accomplished and plant conditions that 3.5.1 on the ANS 3.2 are required to exist prior to performing the procedure. A prerequisite applicable to only a specific portion of a procedure is 31

ANS 3.2 Side-By Side Comparison 7/25/2012 so identified. sheet 3.5.2.5 Precautions Precautions alert the user to those important measures to be used See section 5.3.2 of to protect equipment and personnel, including the public, or to 3.5.1 on the ANS 3.2 avoid an abnormal or emergency situation during performance of sheet the procedure. Cautionary notes applicable to specific steps are included in the main body of the procedure and are identified as such.

3.5.2.6 Limitations and Actions Limitations on the parameters being controlled and appropriate See section 5.3.2 of corrective measures to return the parameter to the normal control 3.5.1 on the ANS 3.2 band are specified. sheet 3.5.2.7 Main Body The main body of the procedure contains the step-by-step See section 5.3.2 of instructions in the degree of detail necessary for performing the 3.5.1 on the ANS 3.2 required function or task. sheet 3.5.2.8 Acceptance Criteria The acceptance criteria provide the quantitative or qualitative See section 5.3.2 of criteria against which the success or failure of the step or action 3.5.1 on the ANS 3.2 (such as for a test type activity) would be judged. sheet 3.5.2.9 Checklists See section 5.3.2 of 3.5.1 on the ANS 3.2 Complex procedures should utilize checklists which may be 32

ANS 3.2 Side-By Side Comparison 7/25/2012 included as part of the procedure or appended to it. sheet 3.5.3 Plant Procedures Plant procedures provide instructions for controlling plant activities. Essentially, equivalent Typical examples of these types of plant procedures and their to ANS 3.2 1976, characteristics are as follows. section 5.3.4.

3.5.3.1 Administrative Control Procedures These include administrative procedures, directives, policies, Replacement for 5.1, 5.3.3 System Procedures.

standards, and similar documents that control the programmatic ANS 3.2 1976, more Instructions for energizing filling venting.

aspects of facility activities. These administrative documents general. No problems Draining, starting up. shutting down, ensure that the requirements of regulatory and license changing modes of operation and other identified. Ok.

commitments are implemented. Several levels of administrative instructions appropriate for operations of controls are applied ranging from those affecting the entire owner systems related to the safety of the plant Section 5.2 Rules of organization to those prepared at the implementing group level. shall be delineated in system procedures.

These documents establish responsibilities, interfaces, and Practice, replaced by Procedures for correcting off-normal standard methods (rules of practice) for implementing programs part 26 requirements. conditions shall be developed for those So ok to remove. events where system complexity may lead to operator uncertainty. System Section 5.2.1 is procedures shall contain check off lists elaborated in other where appropriate.

parts of the new ANS 3.2.

Different levels of detail than ANS 3.2 1976 version. Section 5.3.3.

3.5.3.2 Operating Orders/Procedures 5.2.3 Operating Order 5.2.3 Operating Orders Instructions of general and continuing applicability to the conduct of Similar to 1982 A mechanism shall be provided for A mechanism shall be provided for business to the plant staff are provided. Examples where these dissemination to the plant staff of dissemination to the plant staff of 33

ANS 3.2 Side-By Side Comparison 7/25/2012 are applied include, but are not limited to, job turnover and relief, version, Section 5.2.3. instructions of general and continuing instructions of general and continuing designation of confines of control room, definition of duties of applicability to .the conduct of business. applicability to the conduct of business.

operators and others, transmittal of operating data to management, Such instruction... ~, sometimes also Such instructions. sometimes also referred filing of charts, limitations on access to certain areas and referred to as standing orders or standard to as administrative procedures, standing equipment, shipping and receiving instructions. Provisions are operating procedures should deal with job orders or standard operating procedures, made for periodic review and updating of these documents, where turnover and relief, designation of confines should deal with job turnover and relief.

appropriate. of control room, definition of duties of designation of confines of control room, operators and others, transmittal) of definition of duties of operators and others, operating data to management, filing of transmittal of operating data to charts, limitations on access to certain management, filing of charts, limitations on areas and equipment, shipping and access to certain areas and equipment, receiving instructions, or other such shipping and receiving instructions. or matters. Provisions should be made for other such matters. Provisions shall be periodic review and updating of standing made for periodic review and updating of orders. operating orders.

3.5.3.3 Special Orders 5.2.4 Special Order 5.2.4 Special Orders Management instructions, which have short-term applicability and Essentially, equivalent A mechanism shall be provided for A mechanism shall be provided for issuing require dissemination, are issued to encompass special wording as ANS 3.2, issuing management instructions which management instructions which have operations, housekeeping, data taking, publications and their 1976 version, section have short-term applicability and which short-term applicability and which require distribution, plotting process parameters, personnel actions, or require dissemination. Such instructions dissemination. Such instructions, 5.2.4 other similar matters. Provisions are made for periodic review, sometimes referred to as special orders, sometimes referred to as special orders, updating, and cancellation of these documents, where appropriate. should encompass special operational, should encompass special operations, housekeeping, data taking, publication and housekeeping, data taking, publications their distribution, plotting process and their distribution, plotting process parameters, personnel actions or other parameters, personnel actions or other familiar material Provisions should be similar matters. Provisions shall be made made for periodic review, updating and for periodic review, updating and cancellation of special orders. cancellation of special orders.

3.5.3.4 Temporary Procedures 5.2.5 Temporary Procedures 5.2.5 Temporary Procedures Temporary procedures may be used to direct operations during Essentially, equivalent Temporary procedures may be issued Temporary procedures may be issued testing, refueling, maintenance, and modifications to provide wording as ANS 3.2, during the operational phase: to direct during the operational phase: to direct guidance in unusual situations not within the scope of the normal 1976 version, section operations during testing, refueling, operations during testing, refueling, procedures. These procedures ensure orderly and uniform maintenance and modifications; to provide 5.2.5 maintenance and modifications; to provide operations for short periods when the plant, a system, or a guidance in unusual situations not within component of a system is performing in a manner not addressed guidance in unusual situations not within the scope of the normal procedures; and to by existing detailed procedures or has been modified or extended the scope of the normal procedures; and ensure orderly and uniform operations for in such a manner that portions of existing procedures do not apply. to ensure orderly and uniform operations short periods when the plant, a system, or Temporary procedures include designation of the period of time for short periods when the plant, a system, a component of a system is performing in during which they may be used and are subject to the procedure or a component of a system is performing a manner not covered by existing detailed review process as applicable. in a manner not covered by existing procedures or has been modified or extended in such a manner that portions of detailed procedures or has been modified existing procedures do not apply.

or extended in such a manner that Temporary procedures shall include 34

ANS 3.2 Side-By Side Comparison 7/25/2012 portions of existing procedures do not designation of the period of time during apply. Temporary procedures shall which they may be used and shall be include designation of the period of time subject to the review process prescribed in 4.3 and 5.2.15 as applicable. Temporary during which they may be used and shall procedures shall be approved by the be subject to the review process management representative assigned prescribed in 4.3 and 5.2.15 as applicable. approval authority.

3.5.3.5 Engineering Procedures These documents provide instructions for the preparation of New section in line engineering documents, engineering analysis, and implementation with NQA-1 of engineering programs. This includes activities such as designs; requirements. Ok.

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. Additional criteria for these procedures are contained in ASME NQA-1-2008 and the NQA-1a-2009 addenda

[2].

3.5.3.6 Installation Procedures These documents provide instructions for the installation of New section in line components generally related to new construction and certain with NQA-1 modification activities. They include appropriate reference to requirements.

industry standards, installation specifications, design drawings, and Installation in operating supplier and technical manuals for the performance of activities.

These documents include provisions, such as hold or witness plants equivalent to points, for conducting and recording results of required inspections design and or tests. These documents may include applicable inspection and construction phase.

test instructions subject to the requirements for test and inspection procedures below.

3.5.3.7 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 New section similar to systems related to the safety of the plant. Actions to correct off- 1982 version Sections normal conditions are invoked following an operator observation or 35

ANS 3.2 Side-By Side Comparison 7/25/2012 an annunciator alarm indicating a condition which, if not corrected, 3.2 & 3.5.5.2.

could degenerate into a condition requiring action under an emergency procedure. Separate procedures may be developed for correcting off-normal conditions for those events where system complexity may lead to operator uncertainty 3.5.3.8 Start-up Procedures 5.3.4.1 Start-up Procedures 5.3.4.1 Start-up Procedures These documents contain instructions for starting the reactor from Essentially, equivalent Start-up procedures shall be provided that Start-up procedures shall be provided that cold or hot conditions and establishing power operation. This wording as ANS 1976 include starting the reactor from cold or include starting the reactor from cold or hot includes documented determination that prerequisites have been version, section 5.3.4.1 hot conditions and establishing power conditions and establishing power satisfied, including confirmation that necessary instruments are operation, with the generator synchronized operation, with the generator synchronized operable and properly set, valves are properly aligned, necessary to the line. Recovery from reactor trips to the line. Recovery from reactor trips system procedures, tests and calibrations have been completed, shall be in accordance with the start-up shall be in accordance with the start-up and required approvals have been obtained. procedure and shall be subject to the procedure and shall be subject to the determinations set forth in 5.2.1.1. determinations set forth in 5.2.1.1.

3.5.3.9 Shutdown Procedures 5.3.4.2 Shutdown Procedures 5.3.4.2 Shutdown Procedures These documents contain guidance for operations during Essentially equivalent Shutdown procedures shall be provided to Shutdown procedures shall be provided to controlled shutdown and following reactor trips, including wording as ANS 1976 guide operations during and following guide operations during and following instructions for establishing or maintaining hot shutdown/standby version, section controlled shutdown or reactor trips and controlled shutdown or reactor trips and or cold shutdown conditions, as applicable. The major steps shall include instructions for establishing shall include instructions for establishing or 5.3.4.2.

involved in shutting down the plant are specified, including or maintaining hot standby or cold maintaining hot standby or cold shutdown instructions for such actions as monitoring and controlling shutdown conditions as applicable. The conditions, AS applicable. The major steps reactivity, load reduction and cool down rates, sequence for major steps involved in shutting down the involved in shutting down the plant shall be activating or deactivating equipment, requirements for prompt plant shall be specified, including detailed specified, including detailed instructions for analysis for causes of reactor trips or abnormal conditions requiring instructions for the performance of such the performance of such actions as unplanned controlled shutdowns, and provisions for decay heat actions as monitoring and controlling monitoring and controlling reactivity, load removal. reactivity load reduction and cool down reduction, and cool down rates, sequence rates, sequence of activating or of activating or deactivating equipment, deactivating equipment, requirements for requirements for prompt analyses of prompt analyses of causes of reactor trips causes or reactor trips or abnormal or abnormal conditions requiring conditions requiring unplanned controlled unplanned controlled shutdowns, and shutdowns, and provisions for decay heat provisions for decay heat removal. Check removal. Check off lists shall be used for off list should be used for confirming the purpose of confirming completion of completion of major steps in proper major steps in proper sequence.

sequence.

3.5.3.10 Power Operation and Load Changing Procedures 5.3.4.3 Power Operation and Load 5.3.4.3 Power Operation and Load Changing Procedure. Change*

These documents contain instructions for steady-state power Essentially equivalent Procedures for steady- state power Procedures for steady-state power 36

ANS 3.2 Side-By Side Comparison 7/25/2012 operation and load changing. These type documents include, as wording as ANS 1976 operation and load changing shall be operation and load changing shall be examples, provisions for use of control rods, chemical shim, version, section provided that include, for example, provided that include, for example, coolant flow control, or any other system available for short-term or 5.3.4.3. provisions for use of control rods, chemical provisions for use of control rods, chemical long-term control of reactivity, making deliberate load changes, shim, coolant flow control or any other shim, coolant flow control or any other responding to unanticipated load changes, and adjusting operating system available for long or short-term parameters. control of reactivity, making deliberate load system available for long or short-term changes, responding to unanticipated load control of reactivity, making procedures, changes and adjusting operating deliberate load changes, responding to parameters. unanticipated load changes and adjusting

. operating parameters 3.5.3.11 Process Monitoring Procedures 5.3.4.4 Process Monitoring Procedures 5.3.4.4 Process Monitoring Procedures These documents contain instructions for monitoring performance Essentially equivalent Procedures for monitoring performance of Procedures for monitoring performance of of plant systems to assure that core thermal margins and coolant wording as ANS 1976 plant systems shall be required to assure plant systems shall be required to assure quality are maintained in acceptable status at all times, that version, section that core thermal margins and coolant that core thermal margins and coolant integrity of fission product barriers is maintained, and that quality are maintained at all times, that 5.3.4.4. quality are maintained at all times. that engineered safety features and emergency equipment are in a intergraded of fission product barriers is state of readiness to maintain the plant in a safe condition if maintained at all times and that engineered integrity of fission product barriers is needed. Maximum and minimum limits for process parameters are safety features and emergency equipment maintained at all times and that appropriately identified. Operating procedures address the are in a state of readiness to maintain the engineered safety features and appropriate nature and frequency of this monitoring. plant in a safe condition ( needed.. The emergency equipment are in a state of limit (maximum and minimum) (or readiness to maintain the plant in a safe significant process parameters shall be condition if needed. The limits ( maximum identified. 'The nature and frequency of this and minimum for significant process monitoring shall be covered by operating procedures. as appropriate. parameters shall be identified. The nature and frequency of this monitoring shall be covered by operating procedures, as appropriate.

3.5.3.12 Fuel Handling Procedures 5.3.4.6 Fuel-Handling Procedures 5.3.4.5 Fuel- Handling Procedures These documents contain instructions for core alterations, Essentially equivalent Fuel handling operations shall be .Fuel handling operations shall be accountability of fuel and partial or complete refueling operations wording as ANS 1976 performed in accordance with written performed in accordance with written that include, for example, continuous monitoring of neutron flux version, section procedures. These procedures shall procedures. These procedure shall throughout core loading, periodic data recording, audible specify actions for .core alterations, 5.3.4.5. specify instructions for use of refueling annunciation of abnormal flux increases, and evaluation of core accountability of fuel and partial or neutron multiplication to verify safety of loading increments. complete refueling operations that include, equipment, actions for core alterations, Procedures are also provided for receipt and inspection of new (or example, continuous monitoring of the accountability of fuel and partial or fuel, and for fuel movements in the spent fuel storage areas. Fuel neutron flux throughout core loading, complete refueling operations that handling procedures include prerequisites to verify the status of periodic recording of data, audible include, for example, continuous systems required for fuel handling and movement; inspection of annunciation of abnormal flux increases monitoring of the neutron flux: throughout replacement fuel and control rods; designation of proper tools, and evaluation of core neutron 37

ANS 3.2 Side-By Side Comparison 7/25/2012 proper conditions for spent fuel movement, proper conditions for multiplication to verify the safety of loading core loading, periodic recording of data, fuel cask loading and movement; and status of interlocks, reactor increments. Provisions shall be made for audible annunciation of abnormal flux trip circuits and mode switches. These procedures provide preparing specific procedures for each increase and evaluation of core neutron requirements for refueling, including proper sequence, orientation refueling outage and for receipt and multiplication to verify the safety of loading and seating of fuel and components, rules for minimum operable shipment of fuel. Plant procedures should, instrumentation, actions for response to fuel damage, verification of nonetheless, prescribe the general increments. Provisions shall be made for shutdown margin, communications between the control room and preplanning for the fuel-handling program preparing specific procedures for each the fuel handling station, independent verification of fuel and and its associated safety measures and refueling outage and for receipt and component locations, criteria for stopping fuel movements, and should identify those aspects of the shipment of fuel Plant procedures shall documentation of final fuel and component serial numbers (or other program for which procedures are to be prescribe the general preplanning for the unique identifiers) and locations. prepared for each refueling outage (1) fuel handling program and its associated Prerequisites. Prerequisites shall be safety measures and should identify those provided in the fuel-handling procedures that include, for example, the status of aspects of the program for which plant systems required for refueling; procedures are to be prepared for each inspection of replacement fuel, control rods refueling outage (1) Prerequisites.

poison curtains and internals; designation Prerequisites shall be provided in the fuel-of proper tools; proper conditions for spent handling procedures that include. for fuel movement; proper conditions for fuel example, the status of plant systems cask loading and movement; and status of required for refueling; inspection of interlocks reactor trip circuits and mode. (2)

Main Body. The main body of fuel hand line replacement fuel control rod!:, poison procedures shall include requirements for curtains and internals; designation of refueling; for sample, the status of the core, proper tools; proper conditions for spent instructions (or proper sequence, fuel movement.; proper conditions for fuel orientation. and seating of fuel and cask loading and movement; and status of components, rules for minimum operable interlocks, reactor trip circuits and mode instrumentation, actions to be followed in the event of fuel damage, rules for periods switches. (2) Main Body. The main body when refueling is interrupted, verification of of fuel handling procedures shall include the shutdown margin and the frequency of requirements for refueling; for example, determination, communications between the status of the core instructions for control room and the fuel loading station. proper :sequence, orientation, and seating independent verification of fuel and of fuel and components, rules for component location, criteria (or stopping minimum operable instrumentation, refueling and (or reducing the size of the fuel loading increment, and a containment actions to be followed in the event of fuel evacuation plan and its associated safe damage, administrative control of shift measures. Documentation of final fuel and changes rules for periods when refueling component serial numbers and locations is interrupted. Verification of the shutdown shall be maintained margin and the frequency of determination communications between control room and the fuel loading station.

Independent verification of fuel and 38

ANS 3.2 Side-By Side Comparison 7/25/2012 component location, criteria for stopping refueling and for reducing the size of the fuel loading increment and a containment evacuation plan and its associated safety measures.

Documentation of final fuel and component serial numbers and locations shall be maintained.

3.5.3.13 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 Essentially equivalent and recording results of required inspections or tests. These wording as ANS 1976 documents may include applicable inspection or test instructions version, section 5.3.5.

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 NRC did not endorse (such as protective clothing and radiation monitoring) will be 2.18 of NQA-1 in RG included. Additional maintenance procedure requirements are 1.33 addressed in ASME NQA-1-2008 and the NQA-1a-2009 addenda, Subpart 2.18 [2].

3.5.3.14 Radiation Control Procedures These documents contain instructions for implementation of the Essentially, equivalent radiation control program requirements necessary to maintain wording as ANS 1976 compliance with regulatory commitments, including acquisition of version, section 5.3.6.

data and use of equipment to perform necessary radiation surveys, Ok 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 39

ANS 3.2 Side-By Side Comparison 7/25/2012 and others.

3.5.3.15 Calibration and Test Procedures These documents contain instructions for periodic calibration and Essentially, equivalent testing of instrumentation and control systems, and for periodic wording as ANS 1976 calibration of measuring and test equipment used in activities version, Section 5.3.7.

affecting the quality of these systems. These documents provide Ok.

for meeting surveillance requirements and for assuring measurement accuracy adequate to keep safety-related parameters within operational and safety limits. Additional requirements for these procedures are contained in ASME NQA 2008 and the NQA-1a-2009 addenda [2].

3.5.3.16 Chemical and Radiochemical Control Procedures These documents contain instructions for chemical and Essentially equivalent radiochemical control activities and include: the nature and wording as ANS 1976 frequency of sampling and analyses; instructions for maintaining version, section 5.3.8.

coolant quality within prescribed limits; and limitations on Ok.

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.

3.5.3.17 Emergency Operating Procedures 5.3.9 Emergency Procedures 5,3.9 Emergency Procedures These documents contain instructions for response to potential Revised section. Procedures shall be provided to guide Procedures shall be provided to guide emergencies so that a trained operator will know in advance the operations during potential emergencies, operations during potential emergencies.

expected course of events that will identify an emergency and the They shall be written so that a trained They shall be written so that a trained immediate actions that should be taken in response. Format and operator will know in advance the expected operator will know the action he should content of emergency procedures are based on regulatory and course of events that will identify an Owners Group(s) guidance for the plant type that identify potential emergency and the immediate action he take. Since emergencies may not follow emergency conditions and generally require such procedures to should take. Since emergencies may not anticipated patterns. the procedures include, as appropriate, a title, symptoms to aid in identification of follow anticipated patterns the procedures should provide sufficient flexibility to the nature of the emergency, automatic actions to be expected should provide sufficient flexibility to accommodate variations. These from protective systems, immediate operator actions for operation accommodate variations. Emergency procedures may be based upon plant 40

ANS 3.2 Side-By Side Comparison 7/25/2012 of controls or confirmation of automatic actions, and subsequent procedures that cover actions for symptoms or plant event or both operator actions to return the reactor to a normal condition or manipulations of controls to prevent Symptomatic procedures specify operator provide for a safe extended shutdown period under abnormal or accidents or lessen their consequences actions based on the determination of the emergency conditions. should be based on a general sequence of plant status. Event procedures specify observations and actions. Emphasis should be placed on operator responses to operator actions based on the observational and indications in the control determination of the event. The content room that is, when immediate operator and format of symptomatic procedures are actions are required to prevent or mitigate not covered in this standard. An the consequences of a serious condition, acceptable format and content for event procedures should require that those procedures is given in 5.3.9.1. Emergency actions be implemented promptly. The procedures that cover actions for emergency procedure format given in 5.3.9.1 provides a basis for coping with manipulations of control to prevent emergencies and is an acceptable format accidents or lessen their consequences for prescribing operator observations and should be based on a general sequence of actions. Emergency procedures may observations and actions. Emphasis shall contain supplemental background be placed on operator responses to information to further aid operators in observations and indications in the control taking proper emergency action&, but this room; that is, when operator actions are information shall be separated from the procedural actions. It is extremely difficult required to prevent or mitigate the to distinguish between procedures consequences of a serious condition.

prepared (or the purpose of connecting off* procedures shall require that those actions normal conditions which in themselves do be implemented in a timely fashion.

not compatible actual emergency Emergency procedures may contain situations, but which conceivably can supplemental background information to degenerate into true emergencies in the absence of positive corrective action. and aid operators further in taking proper procedures required for coping with true emergency actions, but this information emergencies that have already occurred shall be separated from the procedural Some owner organizations choose the term actions. When initially available "Off normal procedure" for the same intelligence provided to operating purpose that others choose "Emergency personnel via instrument readings, Procedures." When initially available physical conditions, and personal intelligence provided to operating personnel via instrument readings, physical observations may not indicate clearly the condition&, and personal observations may difference between a simple operational not clearly indicate the difference between problem and a serious emergency, the a simple operational problem and a serious actions outlined in the emergency emergency, the actions outlined in the procedures shall be based on a emergency procedures shall be based on a conservative course of action by the conservative course of action by the operating crew. Departure from the operating crew. Considerable judgment on the part of competent personnel is required emergency procedure shall require the 41

ANS 3.2 Side-By Side Comparison 7/25/2012 before departing room the emergency prior approval of the off-duty shift procedure. supervisor or, if the on-duty shift supervisor is unavailable, the licensed senior operator in the control room.

Signals that initiate engineered 3.5.3.18 Emergency Plan Implementing Procedures 5.3.9.3 Procedure for Implementing 5.3.9.3 Procedure for Implementing Emergency Plan Emergency Plan These documents contain instructions for activating the Emergency Revised section. Implementing procedures for emergency Implementing procedures for emergency Response Organization and facilities, protective action levels, plan actions shall contain, as appropriate, plan actions shall contain, as appropriate, organizing emergency response actions, establishing necessary the following elements: the following elements:

communications with local, state and federal agencies, and for periodically testing the procedures, communications and alarm (1) Individual assignment of authorities and (1) Assignment of authority and systems to assure they function properly. Format and content of responsibilities for performance of specific responsibilities for performance of specific these procedures are such that requirements of each facilitys nuclear regulator approved Emergency Plan are satisfied. tasks to specific individuals or staff tasks to operating staff positions. (21 positions. (2) Protective action level and Protective action levels and protective protective measurers outlined for the measures outlined for the emergency emergency identified. (3) Specific actions to identified. (31 Specific actions to be taken be taken by coordinating support group.(4) by coordinating support groups. (4)

Procedures for medical treatment and Procedures for medical treatment and handling of contaminated individuals.(5) handling of contaminated individuals (5)

Special equipment requirements (or items Special equipment requirements for items such as medical treatment. emergency such as medical treatment, emergency personnel removal, specific radiation personnel removal, specific radiation detection. personnel doeimetry and rescue detection personnel dosimetry and rescue operations. procedures for making this operations procedures for making this equipment available, plus operating equipment available plus operating instructions for such equipment, and instructions for such equipment, and provisions for its periodic inspection and provisions for its periodic inspection and maintenance. (6) Identification of maintenance. (6) Identification of emergency communications network, emergency communications network, including communications required for including communications required for personnel identification and effective personnel identification and effective coordination of all support groups. (7) coordination of all support groups. (7)

Description of alarm signal in each facility. Description of alarm signal in each facility.

At sites with multiple units, alum signals At sites with multiple units. Alarm signals should be consistent from one unit to should be consistent from one unit to another. (Signals for initiating protective another. (Signals for initiating protective 42

ANS 3.2 Side-By Side Comparison 7/25/2012 measures should be clear and distinct from measures should be dear and distinct from process or operational alarm system to process or operational alarm system to avoid confusion. (8) Produces required to avoid confusion. (8) Procedures required restore the plant to normal conditions to restore the plant to normal or safe following an emergency (9) Requirements shutdown conditions following an for periodically testing of procedures emergency. (9) Requirements for periodic communications network and alarm testing of procedures communications systems to assure that they function network and alarm systems to assure that properly. they function properly.

See also U.S. Nuclear Regulatory For additional guidance see the following Commission (NRC) "Guide to the American National Standards: Facilities Preparation of Emergency Plans (or and Medical Care for Onsite Nuclear Production and Utilization facilities," Power Plant Radiological Emergencies.

ANSI/ANS 3.2.1-1979:

Emergency Control Centers for Nuclear Power Plants. ANSI/ANS 3.2 979: and Radiological Emergency Preparation Exercises for Nuclear Power Plants, ANSI ANS 3.2 1979.

3.5.3.19 Test and Inspection Procedures 5.3.10 Test and Inspection Procedures 5.3.10 Test and Inspection Procedures These documents provide the necessary measures to assure Essentially equivalent Test and inspection procedures shall contain a Test and inspection procedures shall quality is achieved and maintained for the nuclear facilities. The wording as ANS 1976 description of objectives; acceptance criteria t contain: a description of objectives; instructions for tests and inspections may be included within other version, section 5.3.10. used to evaluate the results; prerequisites for acceptance criteria that will be used to procedures, such as installation and maintenance procedures, but performing the tests or inspections including a evaluate the results: prerequisites for will contain the objectives, acceptance criteria, prerequisites for performing the test or inspection, limiting conditions, and conditions to be used. to simulate normal or a performing the tests or inspections appropriate instructions for performing the test or inspection, as operating conditions; limiting conditions; and t including any special conditions to be used applicable. These procedures also specify any special equipment inspection procedure. These procedures shall 1.0 simulate normal or abnormal operating or calibrations required to conduct the test or inspection and specify any special equipment or calibrations conditions: limiting conditions: and the test provide for appropriate documentation and evaluation by to conduct the test or inspection. Test and ins or inspection procedure, including or responsible authority to assure test or inspection requirements results shall be documented and evaluated by referencing instruction, for restoration of have been satisfied. Where necessary, hold or witness points are responsible authority to assume that test and the system to the condition consistent with identified within the procedures and require appropriate approval for the work to continue beyond the designated point. These requirements have been satisfied. the normal plant operating status,. If procedures provide for recording the date, identification of those applicable. These procedures shall also performing the test or inspection, as-found condition, corrective Where test and inspections are to be specify any special equipment or actions performed (if any), and as-left condition, as appropriate for witnessed, the procedure shall identify hold calibrations required to conduct the test or 43

ANS 3.2 Side-By Side Comparison 7/25/2012 the subject test or inspection. Additional criteria for these points in the testing sequence to permit inspection. Test and inspection results procedures are contained in ASME NQA-1-2008 and the NQA-1a- witnessing. The procedure shall require shall be documented and evaluated by the 2009 addenda [2]. appropriate approval (or the work to responsible authority to assure that test continue beyond the implanted hold point. and inspection requirements have been The test and inspection procedures shall satisfied. Where tests and inspections are require recording the date, identification of to be witnessing the procedure ,hall those performing the test or inspection. As identify hold points in the testing found condition corrective actions !Sequence to permit witnessing The performed, if any, and as-left condition. procedure shall require appropriate approval for the work to continue beyond the designated hold point. The test and inspection procedures shall require recording the date identification of those performing the test or inspection. As found condition corrective actions performed . If any and as-left condition.

3.6 Document Control 5.2.13.1 Procurement Document 5.2.15 Review, Approval, and Control Control of Procedures Document control activities associated with SSCs shall be Revision to 1976 Measures shall be provided to assurance The administrative controls and quality accomplished in accordance with ASME NQA-1-2008 and the version section that applicable regulatory requirements, assurance program shall provide NQA-1a-2009 addenda [2]. The following requirements apply to 5.2.13.1. Previous design bases and other requirements measures to control and coordinate the plant procedures utilized during the operational phase.

requirements were which are necessary to assure adequate approval and issuance of documents, addressed by NQA-1. quality are included or referenced in the including changes thereto which prescribe Ok. procedures for procurement of items and all activities affecting quality.

services. To the extent necessary, procurement documents shell require Such documents include those which suppliers to provide a quality assurance describe organizational interfaces. or program consistent with the pertinent which prescribe activities affecting requirements of American National structures, systems or components Standard Quality Assurance Program important to safety. These documents Requirement for Nuclear Power Plants, also include operating and special order N4.S.2-1971. Where changes are made to operating procedures emergency and off procurement documents, they shall be normal procedures, test procedures, subject to the same degree of control as equipment control procedures was used in the preparation or the original maintenance or modification procedures, documents. Procurement documents shall refueling procedures, and material control include provisions for the following. as procedures. These measures shall assure 44

ANS 3.2 Side-By Side Comparison 7/25/2012 applicable: that documents, including revisions or changes, are reviewed for adequacy by (I) Supplier Quality Assurance Program. appropriately qualified personnel and Identification of quality assurance approved for release by authorized requirements applicable to the items or personnel: and are distributed in services procured. accordance with current distribution lists and used by the personnel performing the (2) Basic Technical Requirements Where prescribed activity, and that procedures specific technical requirements apply, such are provided to avoid the misuse of as drawings, specifications, and industrial outdated or inappropriate codes and standards, they shall be identified by title and dates of issue in such Procedures for operational phase a way as to clearly set forth the applicable activities of a nuclear power plant reflect documents. Where procedural the conditions that exist at the time the requirements apply, in such areas as test procedures are written. These conditions and inspection needs, fabrication, cleaning include the technical information erecting, packaging, handling, shipping, available, industry experience. and in the and storage, they too, shall be identified case of the initial procedure fully for a new clearly and in such a way as to avoid plant assumptions made regarding the uncertainty as to source and need. detailed behavior of the plant that may not be fully known prior to operation_ In order (3) Source Inspection and Audit Provisions to ensure that the procedures in current for access to the supplier's facilities and use provide the best possible instructions records for source inspection and audit for performance of the work involved when the need for such inspection or audit systematic review and feedback of shall be determined. information based on use is required documents.

(4) Documentation Requirements records to be prepared, maintained, submitted or Each procedure shall be reviewed and made available for review, such as drawing approved prior to initial use. The specifications, procedures, procurement frequency of subsequent review shall be documents, inspection and test records. specified and may vary depending on the personnel and procedure qualifications, type and complexity of the activity and material, chemical, and physical test involved and may vary with time as a requirements ETC given plant reaches operational maturity.

Applicable procedures shall be reviewed following an unusual incident such as an accident an unexpected transient, significant operator error. Or equipment 45

ANS 3.2 Side-By Side Comparison 7/25/2012 malfunctions. Applicable procedures shall be reviewed following any modification to For the first time owners (or licensees) of a unit from a particular nuclear steam supply system (NSSS) vendor the initial issuance of fuel loading and post fuel loading startup test procedure emergency procedures related to the NSSS, and system operating procedures for systems important to safety shall be reviewed by the appropriate design organization prior to approval.

Plant procedures shall be reviewed by an individual knowledgeable in the area affected by the procedure no less frequently than every two years to determine if changes are necessary or desirable. This requirement for routine follow up review can be accomplished in several ways, including, but not necessarily limited to documented step-by-step use of the procedure, such as occurs when the procedure has a step-by-step check off associated with it or detailed scrutiny of the procedure as part of a documented training program. drill, simulator exercise. or other such activity.

A revision of a procedure constitutes a procedure review Procedures shall be approved by the owner organization before initial use.

Rules shall be established which provide for interdisciplinary review of procedures by knowledgeable personnel other than the originator and the approval of procedures and procedure channel by 46

ANS 3.2 Side-By Side Comparison 7/25/2012 authorized individuals.

Changes to documents shall be reviewed and approved by the same organizations that perform the original review and approval unless the owner organization designates another qualified organization The reviewing organizations shall have access to pertinent background information upon which to base its approval and shall have adequate understanding of requirement and intent of the original document.

Those participating in any activity shall be made aware of and use proper and current instructions, procedures, drawings, and engineering requirements for performing the activity.

Participating organizations shall have procedures for control of the documents and changes thereto to preclude the possibility or use of outdated or inappropriate documents.

Document control measures shall provide for:

(1) Identification of individuals or organizations responsible for preparing, reviewing, approving and issuing documents and revisions thereto (2) Identifying the proper document 1.0 be used in performing the activity (3) Coordination and control of interlace 47

ANS 3.2 Side-By Side Comparison 7/25/2012 documents (4) Ascertaining that proper procurements and proper revisions are being used (5) Establishing current and updated distribution lists The method, by which both permanent and temporary changes to approved procedures are made, shall be implemented through a procedure and shall include the designation of a person or persons authorized to approve such changes.

Plant procedures shall be reviewed by an individual(s) knowledgeable in the aspects of the technical content and of human factors affected by the procedure within six months following startup after the first refueling outage of the unit to determine if changes are necessary or desirable. Applicable procedures shall also be reviewed following an unusual incident, such as an accident, an unexpected transient, significant operator error, or equipment malfunction, or following any modification to a system, or prior to use if the procedure has not been used in the previous two years.

Technical review of documents affecting the plant should be Consider deleting this accomplished to verify technical accuracy and to determine that paragraph. This would no conflicts with Technical Specifications exist and no proposed be addressed by 50.36 changes require prior NRC approval. If a Technical Specification

& by the independent change is needed or prior NRC approval is required, changes proposed by the documents under review shall not be review requirements implemented until required approvals are obtained. The reviewers that are being moved to shall be other than the individuals who prepared the document. NQA-1.

The technical review is the first step in the formal review process.

The reviewer shall determine if additional cross-disciplinary review is required. Conflicts that develop shall be addressed and resolved prior to approval. Successful completion of the review shall be documented.

48

ANS 3.2 Side-By Side Comparison 7/25/2012 Procedures shall be updated, as necessary, based on the results of the above reviews, or when procedure discrepancies are found such as through normal use or QA audits.

3.7 Control of Purchased Material, Equipment and Services Addressed by NQA-1.

Ok.

Control of purchased materials and services including the procurement and dedication of commercial grade items shall be accomplished in accordance with ASME NQA-1-2008 and the NQA-1a-2009 addenda [2].

Procedure(s) shall be implemented to aid in the identification of New revision to counterfeit and fraudulently marketed products. As a minimum, standard. Adding procedure(s) shouldinclude selective inspections and testing of CF&SI guidance.

products to verify compliance with procurement requirements when Detail is sufficient. Ok.

products are suspect.

3.8 Identification and Control of Materials, Parts and Components Identification and control of materials, parts, and components shall Essentially, equivalent be accomplished in accordance with ASME NQA-1-2008 and the to NQA- l. Ok.

NQA-1a-2009 addenda [2].

3.9 Control of Special Processes Special processes such as welding, heat treating, chemical Essentially, equivalent cleaning, applied coatings, and nondestructive examination shall to NQA- l. Ok.

be controlled in accordance with ASME NQA-1-2008 and the NQA-1a-2009 addenda [2].

3.10 Inspection Inspection activities shall be accomplished in accordance with Essentially, equivalent 49

ANS 3.2 Side-By Side Comparison 7/25/2012 ASME NQA-1-2008 and the NQA-1a-2009 addenda [2]. to NQA- l. Ok.

With respect to inspection of operating activities (work functions Essentially, equivalent associated with normal operation of the plant, routine to NQA- l. Ok.

maintenance, and certain technical services routinely assigned to the onsite operating organization), the inspections may be carried out by personnel experienced in and knowledgeable of the scope, complexity, and nature of the work activity that they have not performed or directly supervised. For modifications and non-routine maintenance, inspections are to be conducted in a manner similar (frequency, type, and personnel performing such inspections) to that associated with construction phase activities.

3.11 Test Control Test activities shall be controlled in accordance with ASME NQA- Essentially, equivalent 1-2008 and the NQA-1a-2009 addenda [2]. Controls shall be to NQA- l. Ok.

established for operational phase surveillance, calibration, and in-service inspection and testing activities.

Tests during the preoperational period shall be conducted to demonstrate that the performance of facility systems is in accordance with its design intent and that the coordinated operation of the facility as a whole is satisfactory, to the extent feasible. The preoperational testing program shoulddemonstrate, as nearly as can be practicably simulated, the overall integrated operation of the plant systems at rated conditions, including simultaneous operation of auxiliary systems. It may be necessary to defer portions of these tests until nuclear heat is available.

Tests during the initial operational phase shall be conducted to demonstrate the performance of systems that could not be tested prior to operation and to confirm those physical parameters, hydraulic or mechanical characteristics that need to be known, but which could not be predicted with the required accuracy, and to confirm that behavior conforms to design criteria.

3.11.1 Tests Associated with Plant Maintenance, Modifications or Procedure Changes 50

ANS 3.2 Side-By Side Comparison 7/25/2012 Tests shall be performed following plant modifications or Essentially equivalent significant changes in operating procedures to confirm that the wording in ANS 1976 modifications or changes reasonably produce expected results version, section and that the change does not reduce safety of operations.

5.2.19.3 3.12 Control of Measuring and Test Equipment Measuring and test equipment shall be controlled in accordance Essentially, equivalent with ASME NQA-1-2008 and the NQA-1a-2009 addenda [2]. to NQA- l. Ok.

3.13 Handling, Storage and Shipping Handling, shipping, and storage activities shall be accomplished in Essentially, equivalent accordance with ASME NQA-1-2008 and the NQA-1a-2009 to NQA- l. Ok.

addenda [2]. Additional requirements are addressed in ASME NQA-1-2008 and the NQA-1a-2009 addenda, Subpart 2.2 [2].

3.14 Inspection, Test and Operating Status Inspection, test and operating status shall be accomplished in Items already accordance with ASME NQA-1-2008 and the NQA-1a-2009 addressed in NQA-1.

addenda [2]. The following requirements shouldbe employed Ok.

during the operational phase.

(1) Equipment shall be controlled, as necessary, to maintain Essentially, equivalent personnel and reactor safety and to avoid unauthorized to NQA- l. Ok.

operation of equipment.

(2) Control measures such as locking or tagging to secure and Essentially, equivalent identify equipment in a controlled status shall be required. to NQA- l. Ok.

Independent verifications shall be conducted to ensure that necessary measures, such as tagging equipment, have been implemented correctly. Tagouts shall be designed and installed to prevent obstruction of other controls or indications.

(3) The status of equipment undergoing inspections, calibrations, Essentially, equivalent maintenance and modification activities and tests shall be to NQA- l. Ok.

identified.

51

ANS 3.2 Side-By Side Comparison 7/25/2012 Essentially, equivalent (4) Control room indicators and operating devices that are to NQA- l. Ok.

out-of-service shall be appropriately tagged or labeled or provided by a suitable means when applied to electronic displays where affixing a physical tag would not be feasible.

Essentially, equivalent (5) Items which have not satisfactorily passed required inspections, calibrations or tests shall be identified. In cases to NQA- l. Ok.

where required documentary evidence is not available to demonstrate that items have passed inspections, calibrations or tests required by Technical Specifications, affected items shall be considered inoperable and reliance shall not be placed on them to fulfill their intended safety function(s).

Local identification of deficiencies in equipment which require correction should be provided.

5.2.6 Equipment Control 5.2.6 Equipment Control (6) Permission to release plant systems or equipment for maintenance or tests shall be granted by designated operating Permission to release equipment or Procedures shall be provided for control of personnel holding a senior operator license who have been designated responsibility for granting such activities. Prior to systems for maintenance shall be granted equipment, as necessary, to maintain granting permission, such operating personnel shall verify that by designated operating personnel. Prior to personnel and reactor safety and to avoid the equipment or system may be safely released, determine granting permission, such operating unauthorized operation of equipment.

how long it may be out of service, and determine what personnel shall verify that the equipment or These procedures shall require control functional testing or redundant systems are required prior to and system can be released and determine measures such as locking or tagging to during the out-of-service period. Granting of such permission how long it may be out of service, Granting secure and identify equipment in a shall be documented. Independent verification shall be provided to the extent necessary to ensure that the proper of such permission shall be documented. controlled status. Control room & gouts system was removed from service. This may be accomplished Attention shall be given to the potentially shall be designed and installed to prevent by checking appropriate equipment and controls, or by indirect degraded degree of protection when one obstruction of other instruments, controls, means such as observation of indicators and status lights. This subsystem of a redundant safety system or indicating lights. Procedures shall also requirement may be waived if the only way of accomplishing it has been removed (or maintenance, require that the status of inspection and would result in significant radiation exposure. Attention shall be tests performed upon individual items in given to the degraded protection available when a subsystem of After permission has been granted to the nuclear power plant be indicated by a redundant safety system has been removed for remove the equipment (room service, it the use of markings such as stamps, tags, maintenance or surveillance testing.

shall be made are to work on. Measures labels. Routing cards or other suitable shall provide (or protection of equipment means. Suitable means include and workers, Equipment and systems in a identification numbers which are traceable controlled status shall clearly identified. to records of the status of inspections and Strict control measures for such equipment tests. Procedures shall also provide for shall be enforced. the identification of items which have not satisfactorily passed required inspections Conditions to be considered in preparing and tests, where necessary, to preclude 52

ANS 3.2 Side-By Side Comparison 7/25/2012 equipment for maintenance include, for inadvertent bypassing of such inspections example: shutdown margin; method of and tests. In cases where require emergency core cooling,; establishment of documentary evidence isnt available, the B path for decay heat removal; temperature associated equipment or materials must and pressure of the system; valves be considered nonconforming in between work and hazardous material; accordance with 5.2.14. Until suitable venting, draining, and flushing; entry into documentary evidence is available to closed vessels; hazardous atmospheres show the equipment or material is in handling hazardous materials; and conformance affected systems shall be electrical hazards. When entry into a considered to be inoperable and reliance closed system is required, control shall not be placed on such systems to measures shall be established to prevent fulfill their intended safety functions.

entry of extraneous material and to assure that foreign material is removed before the Permission to release plant systems or system is reclosed Equipment, as equipment for maintenance or necessary, to maintain personnel and surveillance tests shall be granted by reactor l entry and to avoid unauthorized designated operating personnel operation of equipment.

Holding a senior operator license. Prior to Procedures shall be provided for control of granting permission, such operating equipment, as necessary, to maintain personnel shall verify that the equipment personnel and reactor safety and to avoid or system can be released. determine unauthorized operation of equipment. how long it may be out of service and These procedures shall require control determine what functional testing of measures such as locking or tagging to redundant systems is required prior to secure and identify equipment in controlled and during the out-of service period.

status. The procedure shall require Granting of such permission shall be independent verification where appropriate, documented. Attention shall be given to to ensure that necessary measure such as the potentially degraded degree of tagging equipment has been implemented protection when one subsystem of a correctly. Temporary modification such as redundant safety system has been temporary bypass lines electrical jumpers removed for maintenance or surveillance lifted electrical leads and temporary trip testing. In addition to the requirements of point settings shall be controlled by the Technical Specifications additional approved procedures which shall include conditions to be considered in preparing the requirements for independent equipment for maintenance or verification. A log shall be maintained of the surveillance testing include, for example; current status of such temporary shutdown margin: method of emergency core cooling; establishment of a path for 53

ANS 3.2 Side-By Side Comparison 7/25/2012 modifications decay heat removal: temperature and pressure of the system: valves between The procedures shall also require that the work and hazardous material; venting, status of inspections and tests performed draining and flushing; entry into closed upon individual items on the nuclear power vessels; hazardous atmospheres; plant be indicated by the use of markings handling hazardous materials; and such as stamps, tags, labels, routing cards, electrical hazards. When entry into a or other suitable means. Suitable means closed system is required, control include identification numbers, which are measures shall be established top vent traceable to records of the status of entry of extraneous material and to assure inspections and tests. Procedures shall that foreign material is removed before the also provide for the identification of items system is reclosed. After permission has which has satisfactorily passed required been granted to remove a system from inspections and tests, where necessary to service, it shall be made safe to work on.

preclude inadvertent bypassing of such Measures shall provide for protection of inspections and tests fn cases where equipment and workers. Equipment and required documentary evidence is not systems in a controlled status shall be available, the associated equipment or clearly identified, at a minimum, at any materials must be considered location where the equipment can be nonconforming in accordance with Section operated. When a system important to 5.2.14. Until suitable documentary safety is removed from service, evidence is available to show the independent verification shall be provided equipment or material is in conformance, to the extent necessary to assure that the affected systems shall be considered proper system was removed. This may be inoperable and reliance shall not be placed accomplished by checking appropriate on such systems to fulfill their intended equipment and controls, or by indirect safety functions. When equipment is ready means such as observation of indicators to be returned to service, operating and status light. This requirement may be personnel shall place the equipment in waived if the only way of accomplishing it operation and verify and document its would result in significant radiation functional acceptability, Attention shall be exposure. Reactor operators and the shift given to restoration of normal conditions, supervisor shall be informed of changes in such as removal of jumpers or signals used equipment status and the effects of such in maintenance or testing or such as re changes. Temporary modifications, such turning valves, breakers or switches to as temporary bypass lines electrical proper start-up or operating positions from jumpers, lifted electrical leads, and "test" or "manual" position". When placed temporary trip point settings, shall be into service the equipment should receive controlled by approved procedures which additional surveillance during the run-in shall include a requirement for 54

ANS 3.2 Side-By Side Comparison 7/25/2012 period. independent verification by either a second person or by a functional test which conclusively proves the proper installation or removal of the temporary modification. A log or other documented evidence shall be maintained of the current status of such temporary modifications. When equipment I, ready to be returned to service. Operating personnel shall place the equipment in operation and verify and document its functional acceptability. Attention shall be given to restoration of normal conditions, such as removal of jumpers or signal used in maintenance or testing or such as returning valves. breaker or switches to proper startup or operating positions from "test" or "manual position, and assuring that all alarms which are indicative of inoperative status are extinguished. For equipment important to safety, proper alignment shall be independently verified by a second qualified person unless all equipment. Valves. and switches involved in the activity can be proven to be in their correct alignment by functional testing without. Adversely affecting the safety of the plant. A second inspection is where such verification would result. in significant radiation exposure. The person who performs the verification of correct implementation of equipment control measures or proper alignment prior to returning equipment to service shall be qualified to perform such tasks for the particular system involved, and shall process operating knowledge of the particular system involved and its 55

ANS 3.2 Side-By Side Comparison 7/25/2012 relationship to plant safety.

5.2.6 Equipment Control 5.2.6 Equipment Control (7) In addition to limiting conditions for operation and allowed outage times in Technical Specifications, additional conditions Permission to release equipment or When equipment is, ready to be returned to to be considered in preparing equipment for maintenance or surveillance testing may include: shutdown risk; shutdown systems for maintenance shall be granted service operating personnel shall place the margin; method of emergency core cooling; establishment of a by designated operating personnel. Prior to equipment in operation and verify and path for decay heat removal; temperature and pressure of the granting permission, such operating document its functional acceptability.

system; valves between work and hazardous material; venting, personnel shall verify that the equipment or Attention shall be given to restoration of draining and flushing; entry into closed vessels; hazardous system can be released. and determine normal conditions, such as removal of atmospheres and ALARA considerations; handling hazardous how long it may be out of service, Granting jumpers or signals used in maintenance or materials; and electrical hazards. When entry into a closed system is required, entry of extraneous material shall be of such permission shall be documented. testing or such as returning valves. breaker prevented. Any foreign material shall be removed and the Attention shall be given to the potentially or switches to proper startup or operating removal verified before the system is re-closed. Foreign degraded degree of protection when one positions from "test" or "manual positions material may be allowed to remain if an analysis is performed to subsystem of a redundant safety system and assuring that all alarms which are demonstrate that the material would not adversely affect plant has been removed (or maintenance, indicative of in inoperative status are safety. extinguished. For equipment important to After permission has been granted to safety, proper alignment shall be remove the equipment (room service, it independently verified by a second qualified shall be made are to work on. Measures person unless all equipment, valves, and shall provide (or protection of equipment switches involved in the activity can be and workers, Equipment and systems in a proven to be in their correct alignment by controlled status shall clearly identified. functional testing without adversely Strict control measures for such equipment affecting the safety of the plant. A second shall be enforced. inspection is where such verification would result in significant radiation exposure. The Conditions to be considered in preparing person who performs the verification of equipment for maintenance include, for correct implementation of equipment control example: shutdown margin; method of measures or proper alignment prior to emergency core cooling,; establishment of returning equipment to service shall be B path for decay heat removal; temperature qualified to perform such verification for the and pressure of the system; valves particular system involved, and shall between work and hazardous material; possess operating knowledge of the venting, draining, and flushing; entry into particular system closed vessels; hazardous atmospheres handling hazardous materials; and electrical hazards. When entry into a closed system is required, control measures shall be established to prevent entry of extraneous material and to assure 56

ANS 3.2 Side-By Side Comparison 7/25/2012 that foreign material is removed before the system is reclosed. equipment. as necessary, to maintain personnel and reactor l entry and to avoid unauthorized operation of equipment.

Procedures shall be provided for control of equipment. as necessary, to maintain personnel and reactor safety and to avoid unauthorized operation of equipment.

These procedures shall require control measures such as locking or tagging to secure and identify equipment in controlled status. The procedure shall require independent verification where appropriate, to ensure that necessary measure such as tagging equipment has been implemented correctly. Temporary modification such as temporary bypass lines electrical jumpers lifted electrical leads and temporary trip point settings shall be controlled by approved procedures which shall include the requirements for independent verification. A log shall be maintained of the current status of such temporary modifications The procedures shall also require that the status of inspections and tests performed upon individual items on the nuclear power plant be indicated by the use of markings such as stamps, tags, labels, routing cards, or other suitable means. Suitable means include identification numbers, which are traceable to records of the status of inspections and tests. Procedures shall also provide for the identification of items which has satisfactorily passed required inspections and tests, where necessary to 57

ANS 3.2 Side-By Side Comparison 7/25/2012 preclude inadvertent bypassing of such inspections and tests fn cases where required documentary evidence is not available, the associated equipment or materials must be considered nonconforming in accordance with Section 5.2.14. Until suitable documentary evidence is available to show the equipment or material is in conformance, affected systems shall be considered inoperable and reliance shall not be placed on such systems to fulfill their intended safety functions. When equipment is ready to be returned to service, operating personnel shall place the equipment in operation and verify and document its functional acceptability, Attention shall be given to restoration of normal conditions, such as removal of jumpers or signals used in maintenance or testing or such as re turning valves, breakers or switches to proper start-up or operating positions from "test" or "manual" position". When placed into service the equipment should receive additional surveillance during the run-in period.

5.2.6 Equipment Control 5.2.6 Equipment Control (8) A plant system(s) or component(s) shall be made safe to work on after permission has been granted to remove it from service.

(See Above) (See Above)

Equipment and systems in a controlled status shall be clearly identified at any location where the equipment can be operated.

Control room supervision shall be promptly informed of changes in equipment status, including temporary modifications, and the effects of such changes. Equipment, which is in other than normal condition, shouldbe readily identifiable to the operating staff.

58

ANS 3.2 Side-By Side Comparison 7/25/2012 (9) Temporary plant modifications shall be clearly identified at the 5.2.6 Equipment Control 5.2.6 Equipment Control installed location(s) and at any location of operation which could be affected by the temporary modification. (See Above) (See Above)

(10) When equipment is ready to be returned to service, operating 5.2.6 Equipment Control 5.2.6 Equipment Control personnel shall place the equipment in operation and verify and document its functional acceptability. Attention shall be given to (See Above) (See Above) restoration of normal conditions, such as removal of jumpers or signals used in maintenance or testing or returning valves, breakers or switches to proper startup or operating positions from "test" or "manual" positions. Steps shall be taken to ensure that all associated alarms and indications are returned to normal.

(11) Proper alignment of equipment shall be independently verified Conditions to be considered in preparing When equipment is, ready to be returned to by a second qualified person unless all equipment, valves, and equipment for maintenance include, for service operating personnel shall place the switches involved in the activity can be proven to be in their example: shutdown margin; method of equipment in operation and verify and correct alignment by functional testing without adversely emergency core cooling establishment of B document its functional acceptability.

affecting the safety of the plant. Another exception is where such verification would result in significant radiation exposure. path for decay heat removal; temperature Attention shall be given to restoration of The person who performs the verification of correct and pressure of the system; valves between normal conditions, such as removal of implementation of equipment control measures or proper work and hazardous material; venting, jumpers or signals used in maintenance or alignment prior to returning equipment to service shall be draining, and flushing; entry into closed testing or such as returning valves. breaker qualified to perform such tasks for the particular system vessels; hazardous atmospheres handling or switches to proper ,startup or operating involved, and shall possess operating knowledge of the hazardous materials; and electrical hazards. positions from "test" or "manual positions, particular system involved and its relationship to plant safety.

When entry into a closed system is required, and assuring that all alarms which are control measures shall be established to indicative of in inoperative status are prevent entry of extraneous material and to extinguished. For equipment important to assure that foreign material is removed safety, proper alignment shall be before the system is reclosed equipment, as independently verified by a second qualified necessary, to maintain personnel and reactor person unless all equipment, valves. and l entry and to avoid unauthorized operation of switches involved in the activity can be equipment. proven to be in their correct alignment by functional testing without adversely affecting the safety of the plant. A second inspection is where such verification would result. in significant radiation exposure. The person who performs the verification of correct implementation of equipment control measures or proper alignment prior to returning equipment to service shall be qualified to perform such verification for the 59

ANS 3.2 Side-By Side Comparison 7/25/2012 particular system involved, and shall possess operating knowledge of the particular system (12) Equipment shouldreceive additional monitoring during an When placed into service the equipment 5.2.19.1. Preoperational Tests appropriate run-in period prior to being placed into service to should receive additional surveillance during perform its intended function. Final acceptance of equipment the run-in period, A component test is a functional, that is returned to service shall be made by the on-duty operational or performance test of an supervisor responsible for the unit. individual piece of equipment or unit system under prescribed conditions. Typical parameters to be examined are direction of rotation, bearing temperatures, vibration, time delays, and ability to operate with remote and local control. The procedure shall list checks to be made and provide acceptance criteria. Consideration should also be given to providing run-in period to minimize early failures during operation of the plant.

3.15 Nonconforming Items Nonconforming items shall be controlled in accordance with Essentially, equivalent ASME NQA-1-2008 and the NQA-1a-2009 addenda [2]. to NQA- l. Ok.

3.16 Corrective Actions Corrective action activities shall be accomplished in accordance Essentially, equivalent with ASME NQA-1-2008 and the NQA-1a-2009 addenda [2]. to NQA- l. Ok.

3.17 Plant Records Management Quality assurance records shall be controlled in accordance with Essentially, equivalent ASME NQA-1-2008 and the NQA-1a-2009 addenda [2]. to NQA- l. Ok.

60

ANS 3.2 Side-By Side Comparison 7/25/2012 A list of typical lifetime records is included in ASME NQA-1-2008 and the NQA-1a-2009 addenda, Part III, Nonmandatory Appendix 17A-1, 200, List of Typical Lifetime Records [2], and should be Nonmandatory considered for guidance purposes only. The list is not considered Appendix 17A-1 will be to be all-inclusive and the nomenclature of these records may endorsed through RG vary. For records not listed in Appendix 17A-1, the type of record 1.33 that most nearly describes the record in question should be followed with respect to its retention classification. The applicant or licensee itself shall ensure that it maintains sufficient records, both lifetime and nonpermanent, to furnish evidence of activities affecting quality The storage of QA records in electronic media shall be consistent In accordance with with the intent of US NRC Regulatory Issue Summary (RIS) 2000- NRC guidance.

18, Guidance on Managing Quality Assurance Records in Electronic Media, dated October 23, 2000 [4], and associated NIRMA Guidelines TG 11-1998 [5], TG15-1998 [6], TG16-1998

[7], and TG21-1998 [8]. The guidance of (RIS) 2000-18 shouldalso be applied to the record keeping and maintenance requirements in other parts of the regulations that accept the storage of records in the form of electronic media.

The use of optical disks for electronic records storage and In accordance with retrieval systems shall comply with the USNRC guidance in NRC guidance.

Generic Letter 88-18, "Plant Record Storage on Optical Disks." [9]

3.18. Audit Program Audit activities shall be controlled in accordance with ASME NQA- Reference to NQA-1.

1-2008 and the NQA-1a-2009 addenda [2]. Audit frequencies and Ok.

inclusion of functional areas for audit during the operational phase is a combination of quality criteria and management direction that are specific to the operation phase as described below.

3.18.1 Audit Frequency 61

ANS 3.2 Side-By Side Comparison 7/25/2012 3.18.1.1 Regularly Scheduled Internal Audits Internal audits of activities conducted during the operational phase should be performed in such a manner that an audit of applicable QA program elements is completed for each functional area within a Aligns with regulatory period of two years. Internal audits of activities conducted during the position in RG1.28 operational phase should be performed in such a manner that an audit of applicable QA program elements is completed for each functional area within a period of two years.

Internal audit frequencies of well established operational phase activities may be extended one year at a time beyond the above two year interval based on the results of an annual evaluation of the applicable functional area and objective evidence that the functional area activities are being satisfactorily accomplished. The evaluation shall include a detailed performance analysis of the functional area based upon applicable internal and external source data and due consideration of the impact of any functional area changes in responsibility, resources or management. The evaluation shall be considered a quality record and available for review by the regulator.

However, the internal audit frequency interval shall not exceed a maximum of four years. If an adverse trend is identified in the applicable functional area, the internal audit frequency extension should be rescinded and an audit scheduled as soon as practicable.

Internal audits shall include the following areas, along with the specific quality assurance program elements included in ASME NQA-1-2008 and the NQA-1a-2009 addenda [2] and the owner organizations QA program. The audits shall take into consideration applicable regulatory and license requirements, and associated record keeping.

(1) Compliance with and effectiveness of implementation (i.e.

performance) of internal rules and procedures, such as for operating, design, procurement, maintenance, modification, refueling, surveillance, and test activities.

(2) The conformance of facility operation to provisions contained within the Technical Specifications, including administrative controls and applicable license conditions.

(3) The performance, training, and qualification of the plant staff.

62

ANS 3.2 Side-By Side Comparison 7/25/2012 (4) The Fire Protection Program and implementing procedures. The audit shall include an inspection of fire protection equipment and program implementation utilizing either a qualified off-site licensed fire protection engineer or an outside qualified fire protection consultant at least every two years. This audit is not subject to the extension of the audit intervals described above.

(5) Corrective actions taken following abnormal occurrences.

Periodic reviews of other important areas, such as plant security, emergency preparedness, and radiation protection, may be conducted through internal audits.

3.18.1.2 Regularly Scheduled External Audits External audits, e.g., supplier audits, should be performed on a Aligns with regulatory triennial basis and supplemented by annual evaluations of the position in RG1.28 suppliers performance. A continuous or ongoing evaluation of the suppliers performance may be conducted in lieu of the annual evaluations provided that the results are reviewed in order to determine if corrective action is required.

If more than one purchaser utilizes a supplier, the purchaser may arrange for an audit of the supplier on behalf of itself and the other purchasers to reduce the number of external supplier audits. The scope of the audit should address the needs of all purchasers and the report shouldbe distributed to purchasers for whom the audit 63

ANS 3.2 Side-By Side Comparison 7/25/2012 was conducted.

Each purchaser relying on the results of such an audit remains individually responsible for the adequacy of the audit and for its use by their organization.

4.0 References The user is advised to review each of the following references to determine whether it, a more recent version, or a replacement document is the most pertinent for each application. When alternate documents are used, the user is advised to document this decision and its basis.

[1] Title 10, Code of Federal Regulations, Part 50, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants

[2] American National Standard ANSI/ASME NQA 2008 with NQA-1a-2009 Addenda, Quality Assurance Requirements for Facility Application

[3] USNRC Regulatory Guide 1.8, Rev. 3 (May 2000),

Qualification and Training of Personnel for Nuclear Power Plants.

[4] Regulatory Issue Summary (RIS) 2000-18, Guidance on Managing Quality Assurance Records in Electronic Media, dated October 23, 2000

[5] Nuclear Information and Records Management Association, Inc. (NIRMA) Technical Guide (TG), TG 11-1998, Authentication of Records and Media

[6] NIRMA TG15-1998, Management of Electronic Records

[7] NIRMA TG16-1998, Software Configuration management and Quality Assurance 64

ANS 3.2 Side-By Side Comparison 7/25/2012

[8] NIRMA TG21-1998, Electronic Records Protection and Restoration

[9] USNRC Guidance in Generic Letter 88-18, Plant Record Storage Optical Disks.

APPENDIX A TYPICAL PROCEDURES FOR PRESSURIZED WATER REACTORS AND BOILING WATER REACTORS The following are typical activities that affect safe operations and/or the quality of SSCs that should be covered by written procedures. This appendix is not intended as an inclusive listing of all needed procedures since many other activities carried out during the operation phase of nuclear power plants should be covered by procedures not included in this list.

1. Administrative Procedures a Authorities and Responsibilities for Safe Operation and shutdown

b. Equipment Control (e.g., locking and tagging)

c. Procedure Adherence and Temporary Change Method

d. Procedure Review and Approval

e. Schedule for Surveillance Tests and Calibration

f. Shift and Relief Turnover

g. Log Entries, Record Retention, and Review procedures 65

ANS 3.2 Side-By Side Comparison 7/25/2012

h. Access to Containment

i. Bypass of Safety Functions and Jumper (temporary modification) Control

j. Maintenance of Minimum Shift Complement and call-in of personnel

k. Plant Fire Protection Program

l. Communication System Procedures

m. Core Design and Configuration

2. General Plant Operating Procedures

a. Cold Shutdown to Hot Standby

b. Hot Standby to Minimum Load (nuclear startup).

c. Recovery from Reactor Trip

d. Operation at Hot Standby

e. Turbine Startup and Synchronization of Generator

f. Changing Load and Load Follow (if applicable)

g. Power Operation and Process Monitoring

h. Power Operation with less than Full Reactor Coolant Flow

i. Plant Shutdown to Hot Standby

j. Hot Standby to Cold Shutdown

k. Preparation for Refueling and Refueling Equipment Operation 66

ANS 3.2 Side-By Side Comparison 7/25/2012 I. Refueling and Core Alterations

3. Procedures for Startup, Operation, and Shutdown of Safety-Related PWR Systems Instructions for energizing, filling, venting, draining, startup, shutdown, and changing modes of operation should be prepared, as appropriate, for the following systems:

a. Reactor Coolant System

b. Control Rod Drive System (including part-length rods).

c. Shutdown Cooling System

d. Emergency Core Cooling System

e. Component Cooling Water System

f. Containment (1) Maintaining Containment Integrity (2) Special Containment Systems (a) Atmosphere (b) Subatmospheric (c) Double-Wall Containment with Controlled Interspace (d) Ice Condenser (3) Containment Ventilation System (4) Containment Cooling System 67

ANS 3.2 Side-By Side Comparison 7/25/2012

g. Atmosphere Cleanup Systems

h. Fuel Storage Pool Purification and Cooling System

i. Main Steam System

j. Pressurizer Pressure and Spray Control Systems

k. Feedwater System (feedwater pumps to steam generator)

I. Auxiliary Feedwater System

m. Service Water System

n. Chemical and Volume Control System (including Letdown/Purification System)

0. Auxiliary or Reactor Building Heating and Ventilation

p. Control Room Heating and Ventilation

q. Radwaste Building Heating and Ventilation

r. Instrument Air System

s. Electrical System (1) Offsite (access circuits)

(2) Onsite (a) Emergency Power Sources (e.g., diesel generator, batteries)

(b) A.C. System (c) D.C. System

t. Nuclear Instrument System 68

ANS 3.2 Side-By Side Comparison 7/25/2012 (1) Source Range (2) Intermediate Range (3) Power Range (4) Incore System u Reactor Control and Protection System

v. Hydrogen Recombiner

4. Procedure for Startup, Operation, and Shutdown of Safety-Related BWR Systems Instructions for energizing, filling, venting, draining, startup, shutdown, and changing modes of operation should be prepared, as appropriate, for the following systems:

a. Nuclear Steam Supply System (Vessel and Recirculating System)

b. Control Rod Drive System

c. Reactor Cleanup System

d. Liquid Poison System (Standby Liquid Control System)

e. Shutdown Cooling and Reactor Vessel Head Spray System

f. High Pressure Coolant Injection

g. Reactor Core Isolation Cooling System/Isolation Condenser

h. Emergency Core Cooling Systems

i. Closed Cooling Water System

j. Containment 69

ANS 3.2 Side-By Side Comparison 7/25/2012 (1) Maintaining Integrity (2) Containment Cooling and Ventilation System (3) Inerting and deinerting

k. Fuel Storage Pool Purification and Cooling System

l. Main Steam System (reactor vessel to turbine)

m. Turbine-Generator System

n. Condensate System (hotwell to feedwater pumps, including demineralizers and resin regeneration)

o. Feedwater System (feedwater pumps to reactor vessel)

p. Makeup System (filtration, purification, and water transfer)

q. Service Water System

r. Reactor Building Heating and Ventilation Systems

s. Control Room Heating and Ventilation Systems

t. Radwaste Building Heating and Ventilation Systems

u. Standby Gas Treatment System

v. Instrument Air System

w. Electrical System (1) Offsite (access circuits)

(2) Onsite (a) Emergency Power Sources (e.g., diesel generator, batteries) 70

ANS 3.2 Side-By Side Comparison 7/25/2012 (b) A.C. System (c) D.C. System

x. Nuclear Instrument System (1) Source Range (2) Intermediate Range (3) Power Range (4) TIP System

y. Reactor Protection System

z. Rod Worth Minimizer

5. Procedures for Abnormal, Offnormal, or Alarm Conditions Since these procedures are numerous and correspond to the number of alarm annunciators, the procedures are not individually listed. Each safety-related annunciator should have its own written procedure, which should normally contain (1) the meaning of the annunciator, (2) the source of the signal, (3) the immediate action that is to occur automatically, (4) the immediate operation action, and (5) the long-range actions.

6. Procedures for Combating Emergencies and Other Significant Events

a. Loss of Coolant (including significant PWR steam generator leaks) (inside and outside primary containment) (large and small, including leak-rate determination)

b. Loss of Instrument Air 71

ANS 3.2 Side-By Side Comparison 7/25/2012

c. Loss of Electrical Power (and/or degraded power sources)

d. Loss of Core Coolant Flow

e. Loss of Condenser Vacuum

f. Loss of Containment Integrity

g. Loss of Service Water

h. Loss of Shutdown Cooling

i. Loss of Component Cooling System and Cooling to Individual Components.

j. Loss of Feedwater or Feedwater System Failure

k. Loss of Protective System Channel

l. Mispositioned Control Rod or Rods (and rod drops)

m. Inability to Drive Control Rods

n. Conditions Requiring Use of Emergency Boration or Standby Liquid Control System

o. Fuel Cladding Failure or High Activity in Reactor Coolant or Offgas

p. Fire in Control Room or Forced Evacuation of Control Room

q. Turbine and Generator Trips

r. Other Expected Transients that may be Applicable

s. Malfunction of Automatic Reactivity Control System

t. Malfunction of Pressure Control System

u. Reactor Trip 72

ANS 3.2 Side-By Side Comparison 7/25/2012

v. Plant Fires

w. Acts of Nature (e.g., tornado, flood, dam failure, earthquakes)

x. Irradiated Fuel Damage While Refueling

y. Abnormal Releases of Radioactivity

z. Intrusion of Demineralizer Resin Into Primary System (BWR Plants)

7. Procedures for Control of Radioactivity (For limiting materials released to environment and limiting personnel exposure)

a. Liquid Radioactive Waste System (1) Collection, Demineralizing, Filtering, Evaporating and Concentrating, And Neutralizing (2) Sampling and Monitoring (3) Discharging to Effluents

b. Solid Waste System (1) Spent Resins and Filter Sludge Handling (2) Baling Machine Operation (3) Drum Handling and Storage

c. PWR Gaseous Effluent System (1) Collection, Storage, and Discharge (2) Sampling and Monitoring (3) Air Ejector and Stack Monitoring 73

ANS 3.2 Side-By Side Comparison 7/25/2012 (4) Ventilation Air Monitoring

d. BWR Air Extraction. Offgas Treatment. and Other Gaseous Effluent Systems (1) Mechanical Vacuum Pump Operation (2) Air Ejector Operation (3) Packing Steam Exhauster Operation (4) Sampling (5) Air Ejector, Ventilation, and Stack Monitor

e. Radiation Protection Procedures (1) Access Control to Radiation Areas Includ1ing a Radiation Work Permit System (2) Radiation Surveys (3) Airborne Radioactivity Monitoring (4) Contamination Control (5) Respiratory Protection (6)Training in Radiation Protection (7) Personnel Monitoring (8) Bioassay Program (9) Implementation of ALARA Program

f. Area Radiation Monitoring System Operation

g. Process Radiation Monitoring System 74

ANS 3.2 Side-By Side Comparison 7/25/2012

h. Meteorological Monitoring Operation

8. Procedures for Control of Measuring and Test Equipment and for Surveillance Tests, Procedures. and Calibrations

a. Procedures of a type appropriate to the circumstances should be provided to ensure that tools, gauges, Instruments, controls, and other measuring and testing devices are properly controlled, calibrated. and adjusted at specified periods to maintain accuracy. Specific examples of such equipment to be calibrated and tested are readout instruments. Interlock permissive and prohibit circuits, alarm devices, sensors. signal conditioners, controls, protective circuits. and laboratory equipment.

b. Specific procedures for surveillance tests, inspections, and calibrations should be written (implementing procedures are required for each surveillance test. inspection. or calibration listed in the technical specifications):

(1) Pressurized Water Reactors (a) Containment Leak-Rate Tests (b) Containment Isolation Tests (c) Containment Local Leak Detection Tests (d) Containment Heat and Radioactivity Removal Systems Tests (e) Containment Tendon Tests and Inspections (f) Service Water System Functional Tests (g) Main Steam Isolation Valve Tests (h) Fire Protection System Functional Tests (i) Boric Acid Tanks-Level Instrumentation Calibrations (j) Emergency Core Cooling System Tests (k) Control Rod Operability and Scram Time Tests (l) Reactor Protection System Tests and Calibrations 75

ANS 3.2 Side-By Side Comparison 7/25/2012 (m) Permissive-Tests and Calibrations (n) Refueling System Circuit Tests (o) Emergency Boration System Functional Tests (p) DNB Checks and Incore-Excore Flux Monitor Correlations (q) Emergency Power Tests (r) Auxiliary Feedwater System Tests (s) NSSS Pressurization and Leak Detection (t) Inspection of Reactor Coolant System Pressure Boundary (u) Inspection of Pipe Hanger Settings (v) Control Rod Drive System Functional Tests (w) Heat Balance-Flux Monitor Calibrations (x) Pressurizer and Main Steam Safety Valve Tests (y) Leak Detection Systems Tests (z) Axial and Radial Flux Pattern Determinations (aa) Area, Portable, and Airborne Radiation Monitor Calibrations (bb) Process Radiation Monitor Calibrations (cc) Environmental Monitor Calibrations (dd) Safety Valve Tests (ee) Turbine Overspeed Trip Tests 76

ANS 3.2 Side-By Side Comparison 7/25/2012 (ff) Water Storage Tanks-Level Instrumentation Calibration (2) Boiling Water Reactors (a) Containment Leak-Rate and Penetration Leak-Rate Tests (b) Containment Isolation Tests (c) Containment Vacuum Relief Valve Tests (d) Containment Spray System Tests (el Standby Gas Treatment System Tests (including filter tests) \

(f) Service Water System Functional Tests (g) Main Steam Isolation Valve Tests (h) Fire Protection System Functional Tests (i) Nitrogen Inerting System Tests (j) Emergency Core Cooling System Tests (k) Control Rod Operability and Scram Time Tests (l) Reactor Protection System Tests and Calibrations (m) Rod Blocks-Tests and Calibrations (n) Refueling System Circuit Tests (o) Liquid Poison System Tests (p) Minimum Critical Heat Flux Checks and Incore Flux Monitor Calibrations (q) Emergency Power Tests 77

ANS 3.2 Side-By Side Comparison 7/25/2012 (r) Isolation Condenser or RCIC Tests (s) NSSS Pressurization and Leak Detection (t) Inspection of Reactor Coolant System Pressure Boundary (u) Inspection of Pipe Hanger Settings (v) Control Rod Drive System Functional Tests (w) Heat Balance (x) Auto blowdown System Tests (y) Leak Detection System Tests (z) Axial and Radial Flux Pattern Determinations (aa) Area, Portable, and Airborne Radiation Monitor Calibrations (bb) Process Radiation Monitor Calibrations I (cc) Environmental Monitor Calibrations (dd) Safety Valve Tests (ee) Turbine Overspeed Trip Test (ff) Water Storage Tanks-Level Instrumentation Calibrations (gg) Reactor Building Inleakage Tests

9. Procedures for Performing Maintenance

a. Maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. Skills normally possessed by qualified maintenance personnel 78

ANS 3.2 Side-By Side Comparison 7/25/2012 may not require detailed step-by-step delineation in a procedure. The following types of activities are among those that may not require detailed step-by-step written procedures:

(1) Gasket Replacement (2) Trouble-Shooting Electrical Circuits (3) Changing Chart or Drive Speed Gears or Slide Wires on Recorders

b. Preventive maintenance schedules should be developed to specify lubrication schedules, inspections of equipment, replacement of such items as filters and strainers, and inspection or replacement of parts that have a specific lifetime such as wear rings.

c. Procedures for the repair or replacement of equipment should be prepared prior to beginning work. Such procedures for major equipment that is expected to be repaired or replaced during the life of the plant should preferably be written early in plant life. The following are examples of such procedures for major equipment:

(1) Repair of PWR Steam Generator Tubes (2) Replacement and Repair of Control Rod Drives (3) Replacement of Recirculation Pump Seals (4) Replacement of Important Strainers and Filters (5) Repair or Replacement of Safety Valves (6) Repair of Incore Flux Monitoring System (7) Replacement of Neutron Detectors 79

ANS 3.2 Side-By Side Comparison 7/25/2012

d. Procedures that could be categorized either as maintenance or operating procedures should be developed for the following activities. Instructions for these activities may be included in systems procedures.

(1) Exercise of equipment that is normally idle (2) Draining and Refilling Heat Exchangers (3) Draining and Refilling Recirculation Loop (4) Draining and Refilling the Reactor Vessel (5) Draining and Refilling Steam Generators (6) Removal of Reactor Head (7) Disconnection and Reconnection of Wiring Penetrating Reactor Vessel Head (8) Demineralizer Resin Regeneration or Replacement

e. General procedures for the control of maintenance, repair, replacement, and modification work should be prepared before reactor operation is begun. These procedures should include information on areas such as the following:

(1) Method for obtaining permission and clearance for operation personnel to work and for logging such work and (2) Factors to be taken into account, including the necessity for minimizing radiation exposure to workmen, in preparing the detailed work procedures but that must operate when required

10. Chemical and Radiochemical Control Procedures Chemical and radiochemical control procedures should be written to prescribe the nature and frequency of sampling and analyses, the instructions maintaining water quality within prescribed limits, and the limitations on concentrations of agents that may cause corrosive attack or fouling of heat-transfer surfaces or that may become sources of radiation hazards due to activation. These procedures should specify laboratory instructions and calibration of laboratory equipment. Extreme importance must be placed on laboratory procedures used to determine 80

ANS 3.2 Side-By Side Comparison 7/25/2012 concentration and species of radioactivity in liquids and gases prior to release including representative sampling, validity of calibration techniques, and adequacy of analysis.

81