ML14304A353

Independent Spent Fuel Storage Installation and Monticello - Request for Review and Approval of Northern States Power Company Quality Assurance Topical Report

ML14304A353
Person / Time
Site:	Monticello, Prairie Island
Issue date:	10/31/2014
From:	Murphy M Northern States Power Co, Xcel Energy
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
L-XE-14-019
Download: ML14304A353 (64)

Text

414 Nicollet Mall - MP4 Minneapolis, MN 55401 October 31, 2014 L-XE-14-019 10 CFR 50.54(a)(4)

ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Prairie Island Nuclear Generating Plant Monticello Nuclear Generating Plant Units 1 and 2 Docket 50-263 Dockets 50-282 and 50-306 Renewed License No. DPR-22 Renewed License Nos. DPR-42 and DPR-60 Prairie Island Independent Spent Fuel Storage Installation Docket 72-10 Materials License No. SNM-2506 Request for Review and Approval of Northern States Power Company Quality Assurance Topical Report Northern States Power Company, a Minnesota corporation, d/b/a Xcel Energy (hereafter NSPM), submits the enclosed Quality Assurance Topical Report (QATR) (Enclosure 1) for review and approval in accordance with 10 CFR 50.54(a)(4). The proposed change revises previously submitted requirements related to the conduct of Independent Assessments.

Specifically, this change divides the Independent Assessment function of the Nuclear Oversight (NOS) organization into two distinct functions: Independent Audits and Independent Assessments.

Currently, the QATR makes no distinction between audits and independent assessments. The Independent Assessment function of NSPMs NOS organization assesses both overall plant performance and regulatory compliance. Organizational changes will separate the assessment of the plant performance from the assessment of regulatory compliance via creation of a new audit function. The new Independent Audits will assess compliance with the Quality Assurance (QA) program and regulations. The Independent Assessments will assess overall plant performance in comparison to industry standards. Separation of these two pieces of the Independent Assessment program retains the operational effectiveness benefits currently

Document Control Desk Page 2 experienced through the implementation of the Independent Assessments while sharpening the focus for regulatory compliance through the new audit program.

Currently, NSPM is committed to NQA-1-1994 for the entire Independent Assessment Program. In the proposed change, the commitment to NQA-1-1994 is applied only to the new audit program, such that commitment to Basic Requirement (BR) 18 and Supplement 18S-1 is retained for the audit program and not applied to the independent assessment function.

Because the commitment to BR18 and 18S-1 no longer applies to the independent assessment portion of the QA program, this change is a reduction in commitment. As such, prior NRC review and approval is required to implement this change in accordance with 10 CFR 50.54(a)(4).

As required by 10 CFR 50.54(a)(4 )(ii), Enclosure 1 provides the proposed revision to the QATR (NSPM-1, Revision Sa) with changes annotated by side bars. Enclosure 2 provides a summary of all changes made to the QATR, identifies the changes which are reductions in commitment, and provides a brief basis for concluding the program, as changed, continues to satisfy the requirements of 10 CFR 50 Appendix B. Enclosure 3 provides background and additional evaluation of the basis for concluding the program continues to satisfy the requirements of 10 CFR 50 Appendix B. NSPM considers that the combination of the QATR, the summary of changes, and the additional evaluation fulfill the requirement of 10 CFR 50.54(a)(4)(ii) to submit "all pages affected by that change," and to identify "the change, the reason for the change, and the basis for concluding the revised program incorporating the change continues to satisfy the criteria of appendix B of this part and the ... quality assurance program description commitments previously accepted by the NRC."

NSPM plans to implement the revised QATR on January 1, 2015. In order to meet this implementation date, NSPM requests NRC review and approval within 60 days of this submittal, as allotted by 10 CFR 50.54(a)(4)(iv).

NSPM recognizes that NRC review of this submittal may require more than the 60 days allotted in 10 CFR 50.54(a)(4)(iv), and hereby waives its right to acceptance of the QATR within 60 days after submittal absent an acceptance letter from the Commission within the 60-day timeframe.

Milrtin C. Murphy~

Director- Nuclear Licensing and Regulatory Affairs Northern States Power Company-Minnesota Enclosures (3)

Document Control Desk Page 3 cc: Administrator, USNRC, Region III USNRC NRR Project Manager, PINGP USNRC Senior Resident Inspector, PINGP USNRC NRR Project Manager MNGP USNRC Senior Resident Inspector, MNGP

ENCLOSURE 1 Xcel Energy Northern States Power Company - Minnesota QUALITY ASSURANCE TOPICAL REPORT NSPM - 1 Revision 8a October 31, 2014 45 pages follow

Northern States Power Company - Minnesota Minneapolis, Minnesota Quality Assurance Topical Report NSPM-1 Revision 8a 1

NSPM-1 QATR, Rev 8a

Northern States Power Company Minnesota - Policy Policy Statement Northern States Power Company, a Minnesota corporation (NSPM), d/b/a Xcel Energy, hereinafter NSPM shall maintain and operate nuclear plants in a manner that will ensure the health and safety of the public and workers; NSPM retains ownership of the facilities.

Facilities shall be operated in compliance with the requirements of the Code of Federal Regulations (CFR), the applicable Nuclear Regulatory Commission (NRC) Facility Operating Licenses, and applicable laws and regulations of the state and local governments.

The NSPM Quality Assurance Program (QAP) described herein and associated implementing documents provide for control of NSPM activities that affect the quality of safety related nuclear plant structures, systems, and components. Reference throughout this document to NSPM refers to the nuclear organization(s) under the direction of the Senior Vice President/Chief Nuclear Officer. The QAP is also applied to certain equipment and activities that are not safety related, but support safe plant operations, or where other non-CFR NRC guidance establishes program requirements.

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

Timothy J. OConnor Signed ________________________________

Senior Vice President, Chief Nuclear Officer NSPM 2

NSPM-1 QATR, Rev 8a

Northern States Power Company - Minnesota Quality Assurance Topical Report NSPM-1 Revision 8a Approved by:

_Timothy J. OConnor _________ ____________

Timothy J. OConnor Date Senior Vice President, Chief Nuclear Officer

_Tom H. Taylor_________________

Tom H. Taylor Date Vice President, Nuclear Oversight NRC Approvals:

Revision 0 - Not Required Revision 1 - Not Required Revision 2 - Not Required Revision 3 - NRC Evaluation dated 07/09/2010 Revision 4 - Not Required Revision 5 - Not Required Revision 6 - Not Required Revision 7 - Not Required Revision 8 - [Required]

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Table of Contents Introduction 5 A. Management A.1 Methodology .. 6 A.2 Organization .. 8 A.3 Responsibility . 10 A.4 Authority .. 11 A.5 Personnel Training and Qualification . 12 A.6 Corrective Action 13 A.7 Regulatory Commitments . 13 B. Performance / Verification B.1 Methodology . 19 B.2 Design Control . 19 B.3 Design Verification .. 20 B.4 Procurement Control .. 20 B.5 Procurement Verification 22 B.6 Identification and Control of Items 22 B.7 Handling, Storage and Shipping .. 23 B.8 Test Control .. 24 B.9 Measuring and Test Equipment Control 25 B.10 Inspection, Test and Operating Status .. 26 B.11 Special Process Control .. 26 B.12 Inspection .. 26 B.13 Corrective Action .. 27 B.14 Document Control . 27 B.15 Records .. 28 B.16 Plant Maintenance 29 B.17 Computer Software Control . 30 C. Self-Assessment C.1 Methodology .. 31 C.2 Self-assessment 31 C.3 Independent Audit . 32 C.4 Independent Assessment 32 Appendices APPENDIX A - Plant Operating Review Committee . 36 APPENDIX B - Procedures .. 38 APPENDIX C - Definitions 42 APPENDIX D - Revision Summaries . 44 4

NSPM-1 QATR, Rev 8a

NSPM Quality Assurance Topical Report Introduction The NSPM Quality Assurance Topical Report describes the methods and establishes quality assurance program and administrative control requirements that meet 10CFR50, Appendix B and apply during the operational phase of plant life. However, this Quality Assurance Topical Report (QATR) is organized and formatted to respond to NRC Standard Review Plan (NUREG 0800) Section 17.3 (Revision 0 - August 1990). NSPM has chosen this approach because it best represents the NSPM commitment to the philosophy that each individual, properly trained and motivated, achieves the highest quality of performance of which they are capable. In addition, NSPM uses this emphasis on individual performance to reinforce the importance of self-assessments (by the group responsible for the activity) and independent audits and assessments (by groups not responsible for the activity) to achieving excellence.

5 NSPM-1 QATR, Rev 8a

NSPM Quality Assurance Topical Report A. Management A.1 Methodology The Quality Assurance Topical Report (QATR) is the top-level policy document that establishes the quality policy and assigns major functional responsibilities for plants operated by NSPM.

The following requirements apply to all organizations and positions under the direction of the Senior Vice President/Chief Nuclear Officer that manage and perform activities within NSPMs scope. The NSPM organization is committed to implementing these requirements. NSPM personnel engaged in supporting nuclear generation shall comply with the requirements of the Quality Assurance Program (QAP) described in this QATR. Contractors, or other organizations supporting NSPM, are required to comply with the QAP established by this QATR, or with their own programs having appropriate scope and controls in accordance with A.2. All facilities shall be operated in compliance with the applicable Code of Federal Regulations, NRC Operating Licenses, and the applicable laws and regulations of the state and local governments in which the facility is located.

The NSPM QAP comprises those planned and systematic actions necessary to provide confidence that structures, systems, and components will perform their intended safety functions. The QAP consists of the NRC approved regulatory document that describes the quality assurance program elements (the QATR) along with the associated headquarter, fleet, and site implementing documents. Corporate Directives establish high level responsibilities and authority for carrying out important functions. Fleet Procedures establish common practices for certain activities such that the activity is controlled and carried out in a manner that meets QAP requirements. Site and department procedures establish detailed implementation requirements and methods, and may be used to implement Corporate Directives and Fleet Procedures or be unique to particular functions or work activities. In addition, to provide a clear understanding of NSPM operating philosophy, NSPM establishes rules of practice pertaining to personnel conduct and control, including consideration of job related factors which can influence the effectiveness of operating and maintenance personnel, including such factors as number of hours at duty station, availability on-call of professional and supervisory personnel, method of conducting operations, and preparing and retaining plant documents. Such rules are contained within appropriate implementing documents.

6 NSPM-1 QATR, Rev 8a

NSPM Quality Assurance Topical Report The QAP applies to activities affecting the performance of safety-related structures, systems and components, including, but not limited to, design; procurement; fabrication; installation; modification; maintenance; repair; refueling; operation; training, inspection; and tests.* A list, or other means of identification, of safety related Systems, Structures, and Components (SSC) under the control of the QAP is established and maintained for each operating plant. The technical aspects of the items are considered when determining program applicability, including, as applicable, the items design safety function, results of probabilistic safety analysis, the ASME Code and the other references cited in section A.7.3 of this QATR. The QAP is also applied to certain activities where regulations other than 10CFR50 establish QA program requirements for activities within their scope. Thus, this QATR is applied to the important to safety activities of radioactive waste shipping and independent spent fuel storage, as defined in those NRC regulations, as allowed by 10CFR71.101.f and 10CFR72.140.d.

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

Activities affecting quality are prescribed by and performed according to documents (such as instructions, procedures or drawings) of a type appropriate to the circumstances and which, where applicable, include quantitative or qualitative acceptance criteria. Such documents are prepared and controlled according to section B.14. In addition, means are provided for dissemination to plant staff of instructions of both general and continuing applicability (e.g.,

dealing with job turnover and relief, designation of confines of the control room, limitations on access to certain areas), as well as those of short-term applicability (e.g., dealing with short-term operating conditions, publications, personnel actions). Provisions are included for review, updating, and cancellation of such instructions.

In establishing, implementing and maintaining the QATR, NSPM commits to compliance with ASME NQA-1, 1994, Basic Requirement 2. QATR revisions are reviewed by NSPM Senior Management and approved by the NSPM Senior Vice President, Chief Nuclear Officer.

Changes to this QATR will be governed by and made in compliance with 10CFR50.54(a).

In establishing procedural controls, NSPM commits to compliance with NQA-1, 1994, Basic Requirement 5. In addition, as stated in position C.1 of Regulatory Guide 1.33, Revision 2, NSPM commits to use Appendix A of Regulatory Guide 1.33 as guidance for establishing the types of procedures that are necessary to control and support plant operation. Requirements specific to procedures are also provided in Appendix B of this QATR.

• As NSPM retains ownership of the operating nuclear power plants and is not actively decommissioning, this QATR does not address decommissioning as an activity within its scope. Should NSPM become involved in plant decommissioning, this QATR will be revised, or a separate QATR developed, to assure appropriate programmatic controls are applied to that activity.

7 NSPM-1 QATR, Rev 8a

NSPM Quality Assurance Topical Report A.2 Organization This section describes the NSPM organizational structure, functional responsibilities, levels of authority and interfaces for establishing, executing, and verifying QAP implementation. The organizational structure includes headquarter functions and onsite functions at each plant.

Implementing documents assign more specific responsibilities and duties, and define the organizational interfaces involved in conducting activities and duties within the scope of this QATR.

The NSPM Senior Vice President, Chief Nuclear Officer has overall responsibility for establishing quality policy and implementation of the quality program. The authority to accomplish quality assurance functions is delegated to the staff as necessary to fulfill the identified responsibilities.

Personnel executing performance activities and those performing verification activities are functionally independent to the degree commensurate with the activitys relative importance to safety. The method and extent of verification is commensurate with importance of the activity to plant safety and reliability. The organization executing independent audit and assessment activities maintains independence from the organization(s) performing the activity being audited or assessed. Management positions are established both offsite and onsite for carrying out the independent audit and assessment functions. Individuals filling these positions:

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

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

• Have effective lines of communication with persons in other senior management positions.

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

Responsible individuals or organizations may delegate any or all of their responsibility. When work is delegated to personnel or organizations outside of NSPM, the responsibility for the program effectiveness and the work is retained by NSPM, and the delegation shall be identified and described such that:

• The organizational elements responsible for the work are identified.

• Management controls and lines of communication are established.

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

• Performance of delegated work is formally evaluated by NSPM.

In establishing its organizational structure, NSPM commits to compliance with NQA-1, 1994, Basic Requirement 1 and Supplement 1S-1. Management gives careful consideration to the timing, extent and effects of organizational structure changes.

8 NSPM-1 QATR, Rev 8a

NSPM Quality Assurance Topical Report A.2.1 Headquarter Organization The following positions have the described headquarter functional responsibilities for assuring that an appropriate QAP has been established and verifying that actions affecting quality have been correctly performed (detailed headquarter organizational structure is controlled by corporate directives). Specific functional responsibilities may be delegated to others as established in this document. Some titles and reporting relationships may vary, but in all cases there is a designated position to carry out the defined responsibilities:

A.2.1.1 Senior Vice President, Chief Nuclear Officer (Sr. VP/CNO)

This position has overall responsibilities for establishing quality policy and implementation of the quality program, and safe and reliable operation of nuclear stations operated by NSPM. These responsibilities include setting and implementing policies, objectives, and priorities to ensure activities are performed in accordance with QAP and other headquarter requirements. The Sr.

VP/CNO is designated as the Company Officer responsible for assuring that defects and non-compliances are reported to the NRC as required by 10CFR21.

A.2.1.1.a Vice President, Nuclear Oversight This position reports to the Sr. VP/CNO and is responsible for establishing, maintaining, and interpreting NSPM quality assurance policies and procedures; establishing the requirements for auditor, assessor and inspector certification; managing the overall independent audit and assessment processes; establishing quality control practices and policies for quality verification activities; and controlling and maintaining the QATR. Additionally this position provides for supplier evaluation; the conduct of supplier assessments or surveys (including their sub-tier suppliers); and verification that supplier quality assurance programs comply with NSPM requirements. This position entails Stop Work authority at the sites and headquarter offices.

A.2.2 Site Organization The following site NSPM management positions describe the typical site QAP functional responsibilities for assuring that an appropriate QAP has been established and verifying that actions affecting quality have been correctly performed. Functional responsibilities may be delegated to others as established within the QAP. Some titles and reporting relationships may vary at some sites, but in all cases there is a designated position to carry out the defined responsibilities. The on-site operating organization includes one or more individuals knowledgeable in the following fields: nuclear power plant operation; nuclear power plant mechanical, electrical and electronic systems; nuclear engineering; chemistry and radiochemistry; radiation protection; and quality assurance. Procedures provide detailed organizational descriptions.

A.2.2.1 Site Vice President (SVP)

This position reports directly to the Senior Vice President, Chief Nuclear Officer and is responsible for overall plant nuclear safety and the implementation of the QAP. This position is also responsible for station compliance with NRC operating license, governmental regulations, and ASME Code requirements, if applicable, and provides day-to-day direction and management of plant operations activities.

9 NSPM-1 QATR, Rev 8a

NSPM Quality Assurance Topical Report A.2.2.1.a Plant Manager This position is responsible for plant operations. This position assures the safe, reliable, and efficient operation of the plant within the constraints of applicable regulatory requirements, operating license, and the QAP. Functional areas of responsibility also include chemistry activities, environmental services, fuel handling (receipt, movement, and storage), health physics/radiological protection, operations and support, maintenance and production planning, and related procedures and programs. The Plant Operating Review Committee reports to the Plant Manager and provides review of plant safety and performance (see Appendix A).

A.2.2.1.b Site Nuclear Oversight Manager This position reports to the Vice President, Nuclear Oversight (offsite) and is responsible for site NOS activities. Significant safety or quality issues requiring escalated action are directed through this position to senior NOS management, as necessary. Functional responsibilities include conducting independent assessments of line and support activities; monitoring and assessing day-to-day station activities; stop work authority at the site; periodic reporting on the status and adequacy of the quality program; and providing quality verification and inspections.

A.3 Responsibility NSPM retains and exercises the responsibility for the scope and implementation of an effective QAP. Positions identified in A.2 may delegate all or part of the activities of planning, establishing, and implementing the program for which they are responsible to others, but retain the responsibility for the program's effectiveness. Decisions affecting safety are made at the level appropriate for its nature and effect, and with any necessary technical advice or review.

Senior management is regularly apprised of audit and assessment results evaluating the adequacy of implementation of the QAP through the functions described in section C.

NSPM ensures that the QAP is properly documented, approved and implemented before an activity within the scope of the program is undertaken. Management is responsible to assure that processes and procedures comply with QATR and other applicable requirements, and that employees comply with them. Individual managers ensure that personnel working under their management cognizance are provided the necessary training and resources to accomplish their assigned tasks. Managers and supervisors are responsible for timely and continuing monitoring of performance to verify that day-to-day activities are conducted safely and in accordance with applicable requirements.

As described in C.3 and C.4, Nuclear Oversight is responsible to verify that processes and procedures comply with QATR and other applicable requirements, that such processes or procedures are implemented, and that management appropriately ensures compliance.

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

10 NSPM-1 QATR, Rev 8a

NSPM Quality Assurance Topical Report In addition, operating personnel responsibilities include:

• The reactor operators authority and responsibility for shutting down the reactor when it is determined that the safety of the reactor is in jeopardy or when operating parameters exceed any of the reactor protection system set-points and automatic shutdown does not occur.

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

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

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

• The responsibility to adhere to the plants Technical Specifications.

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

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

In establishing QAP responsibilities, NSPM commits to compliance with NQA-1, 1994, Basic Requirement 1 and Supplement 1S-1.

A.4 Authority When NSPM delegates responsibility for planning, establishing, or implementing any part of the overall QAP, sufficient authority to accomplish the assigned responsibilities is delegated.

Regardless of delegation, NSPM retains overall responsibility.

Responsibility and authority to stop unsatisfactory work, as delineated in section A.2, includes authority to control further processing, delivery, installation, operation or use of nonconforming items. This assures that cost and schedule considerations do not override safety considerations.

In establishing QAP authorities, NSPM commits to compliance with NQA-1, 1994, Basic Requirement 1 and Supplement 1S-1.

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NSPM Quality Assurance Topical Report A.5 Personnel Training and Qualification Personnel assigned to implement elements of the QAP must be capable of performing their assigned tasks. To this end NSPM establishes and maintains formal indoctrination and training programs for personnel performing, verifying or managing activities within the scope of the QAP to assure that suitable proficiency is achieved and maintained. Generating site and support staff minimum qualification requirements are as delineated in each sites Technical Specifications. Other qualification requirements may be established but will not reduce those required by Technical Specifications. Sufficient managerial depth is provided to cover absences of incumbents. When required by code, regulation, or standard, specific qualification and selection of personnel is conducted in accordance with those requirements as established in the applicable NSPM procedures. Indoctrination includes the administrative and technical objectives, requirements of the applicable codes and standards, and the QAP elements to be employed. Training for positions identified in 10 CFR 50.120 is accomplished according to programs accredited by the National Nuclear Accrediting Board of the National Academy of Nuclear Training that implement a systematic approach to training. Records of personnel training and qualification are maintained.

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

• For Supplement 2S-1: Inspections, examinations or tests may be performed by individuals in the same organization as that which performed the work, provided that (a) the qualifications of the inspector for an activity are equal to or better than the minimum qualifications for persons performing the activity, (b) the work is within the skills of personnel and/or is addressed by procedures, and (c) if work involves breaching a pressure-retaining item, the quality of the work can be demonstrated through a functional test (Note: pressure-retaining items are components that comprise the pressure boundary of any ASME section Xl code class component or the pressure boundary of any safety-related component. The term "pressure retaining" is not applied to non-pressure boundary components such as shafts, stems, trim, spray nozzles, bearings, bushings, springs, wear plates, seals, packing, gaskets, valve seats and threaded joints).1 When a, b and c are not met, inspections, examinations or tests are carried out by individuals certified in accordance with Supplement 2S-1. Individuals performing visual inspections required by the ASME Boiler and Pressure Vessel Code are qualified and certified according to Code requirements. (Note: Quality of work relates to restoring the breach in the pressure boundary. If functional testing can demonstrate adequacy of pressure boundary restoration, then inspection by certified individuals would not be required. Quality of the work may, however, be defined to include critical characteristics beyond simply passing a pressure test, such as correct materials, absence of foreign material or correct fastener torque. These characteristics might be important for continued pressure boundary integrity or compliance with design specifications. If these are relevant considerations, then inspection by certified individuals would be necessary to demonstrate the quality of the work. The application of peer vs. certified inspections for pressure-retaining items is a case by case planning/engineering decision).1

• In lieu of Nonmandatory Appendix 2A-1, NSPM does not establish levels of qualification/

certification for inspection personnel. Instead, NSPM establishes initial qualification 1

Ref. QATR Interpretation 11-01, Rev 1.

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NSPM Quality Assurance Topical Report requirements and determines individual qualification through evaluation of education, training and experience, and through demonstration of capability in performing the type of inspections expected on the job.

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

• For Supplement 2S-3: The requirement that prospective Lead Auditors have participated in a minimum of five (5) audits in the previous three (3) years is replaced by the following, The prospective lead auditor shall demonstrate his/her ability to properly implement the independent audit process, as implemented by NSPM according to section C.3 of this QATR, to effectively lead an audit team, and to effectively organize and report results, including participation in at least one audit within the year preceding the date of qualification.

A.6 Corrective Action NSPM management, at all levels, fosters a non-punitive (no-fault) attitude toward the identification of conditions adverse to quality. This includes failures, malfunctions, deficiencies, deviations, defective material and equipment, abnormal occurrences, nonconformances, and out-of-control processes, including the failure to follow procedures.

NSPM implements a corrective action program to promptly identify, control, document, classify, and correct conditions adverse to quality. In addition, for significant conditions adverse to quality, the program provides for cause evaluation and corrective actions to prevent recurrence.

Provisions are also made to ensure that corrective actions for significant conditions adverse to quality are completed as intended and are not inadvertently nullified by subsequent actions.

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

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

Prior to installation, nonconforming items, services or activities are reviewed and accepted, rejected, repaired, or reworked, and are identified and controlled to prevent their inadvertent test, installation or use.

In establishing requirements for corrective action, NSPM commits to compliance with NQA-1, 1994, Basic Requirements 15 and 16, and Supplement 15S-1.

A.7 Regulatory Commitments A.7.1 Through this QATR, NSPM commits to compliance with the following:

• 10CFR50, Appendix B, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants"

• 10CFR Part 71, Subpart H, "Quality Assurance for Packaging and Transportation of Radioactive Material"

• 10CFR Part 72, Subpart G, "Quality Assurance for Licensing Requirements for the Independent Storage of Spent Nuclear Fuel and High-Level Radioactive Waste,"

• 10CFR Part 21, Reporting of Defects and Non-Compliance"

• General Design Criterion 1, of Appendix A to 10 CFR Part 50 13 NSPM-1 QATR, Rev 8a

NSPM Quality Assurance Topical Report

• 10 CFR 50.55a, Codes and standards A.7.2 When applicable, for Class 1, 2, and 3 items covered by Section III of the ASME Boiler and Pressure Vessel Code, the code Quality Assurance requirements are supplemented by the guidance of applicable regulatory guides (see A.7.3).

A.7.3 NSPM also is committed to carrying out the provisions of certain nuclear quality assurance industry standards, other than ASME NQA-1. The extent of the NSPM commitment to each of the Regulatory Positions of related NRC Regulatory Guides and Generic Letters is specifically described below. Commitment to a particular Regulatory Guide does not constitute commitment to Regulatory Guides or other standards that may be referenced therein, unless otherwise noted.

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

- NSPM commitments regarding qualification and training of personnel are described in Section A.5 of this QATR, which states that staff qualification requirements are as delineated in each sites Technical Specifications, and that training for positions identified in 10 CFR 50.120 is accomplished according to programs accredited by the National Nuclear Accrediting Board of the National Academy for Nuclear Training.

• Safety/Regulatory Guide 1.26, Revision (site specific) Quality Group Classifications and Standards for Water-, Steam-, and Radioactive Waste-Containing Components of Nuclear Power Plants - Commitment to Safety/Regulatory Guide 1.26 is site specific, as required by the approved UFSAR/License at each NSPM site. Sites not committed to RG 1.26 may use this guidance to assist in establishing the lists of equipment to which this QAP applies, or for other purposes.

• Regulatory Guide 1.28, Revision 3, August 1985, Quality Assurance Program Requirements (Design and Construction) (ASME NQA-1, 1983a) - NSPM does not commit to compliance with position C.1 of this Regulatory Guide; instead of establishing three levels of qualification provided in Nonmandatory Appendix 2A-1, NSPM establishes initial qualification requirements and determines individual qualification through evaluation of education, training and experience, and through demonstration of capability in performing the type of inspections expected on the job. NSPM complies with position C.2 for record retention times, and position C.3.2 for external audits, with the exception that for position C.3.2.2, NSPM will review the information described therein as it becomes available through its ongoing receipt inspection, operating experience, and supplier evaluation programs, in lieu of performing a specific evaluation on an annual basis. The results of the reviews are promptly considered for effect on a suppliers continued qualification and adjustments made as necessary (including corrective actions, adjustments of supplier audit plans, and input to third party auditing entities, as warranted). Additionally, results are reviewed periodically to determine if, as a whole, they constitute a significant condition adverse to quality requiring additional action. In lieu of compliance with Regulatory Position C.3.1, NSPM establishes independent audit frequencies as described in section C of this QATR. In lieu of NQA-1 1983a, NSPM uses NQA-1 1994.

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NSPM Quality Assurance Topical Report

• Safety/Regulatory Guide 1.29, Revision (site specific) Seismic Design Classification -

Current NSPM plants were designed, constructed and licensed based on criteria available prior to this Regulatory Guide being issued. The specific design criteria and seismic designations are reflected in each plants UFSAR, and in other docketed analysis. Thus, the commitment to Safety/Regulatory Guide 1.29 is site specific, as required by the approved UFSAR/License at each NSPM site. Sites not committed to RG 1.29 may use this guidance to assist in establishing the lists of equipment to which this QAP applies, or for other purposes.

• Regulatory Guide 1.30, August 1972, Quality Assurance Requirements for the Installation, Inspection and Testing of Instrumentation and Electric Equipment, (ANSI N45.2.4-1972/IEEE 336-1971) - NSPM substitutes NQA-1 1994, Subpart 2.4/IEEE 336-1985 for N45.2.4 in its commitment to Regulatory Guide 1.30. As noted in Regulatory Position C.1, Subpart 2.4 is being used in conjunction with NQA-1, Part 1, which replaced ANSI N45.2. As noted in Regulatory Position C.2, other industry standards may be referenced; the commitment in this QATR to NQA-1, Subpart 2.4 includes commitment to those standards to the extent necessary to implement Subpart 2.4 requirements. If NRC guidance applies to those referenced standards, it is followed.

Regulatory Position C.3 indicates that the requirements of the endorsed standard should also be considered applicable during the operation phase of the nuclear power plant.

This is addressed in sections B.12 and B.16 of this QATR, which also establish any necessary exceptions or alternatives to the provisions of Subpart 2.4.

• Regulatory Guide 1.33, Revision 2, February 1978, Quality Assurance Program Requirements (Operation) (N18.7) - NQA-1 contains quality assurance requirements equivalent to those of ANSI N18.7, and NSPM has included in this QATR the remaining administrative controls elements from N18.7 (1976). Therefore, NSPM does not commit to compliance with the requirements of ANSI N-18.7. As recommended by Regulatory Position C.1, NSPM uses Appendix A of RG 1.33 as guidance in establishing the types of procedures required for plant operation and support. Regulatory Position C.2 is no longer considered valid, as the referenced standards and guidance have now been incorporated into ASME NQA-1 1994, or are addressed specifically in this section.

Regulatory Position C.3 does not apply since NSPM does not use independent/offsite review. In lieu of compliance with Regulatory Position C.4, NSPM establishes audit topics and frequencies as described in section C.3 of this QATR. In lieu of compliance with Regulatory Position C.5, NSPM has established appropriate equivalent requirements within this QATR.

• Regulatory Guide 1.36, Revision 0, February 1973, Nonmetallic Thermal Insulation for Austenitic Stainless Steel - None of the current NSPM plants were committed to this Regulatory Guidance during original construction. Regulatory Guide 1.36 may be used for plant modifications on a case by case basis, but this QATR makes no generic commitment thereto.

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NSPM Quality Assurance Topical Report

• Regulatory Guide 1.37, March 1973, Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants, (ANSI N45.2.1-1973) - NSPM substitutes NQA-1 1994, Subpart 2.1 for N45.2.1 in its commitment to Regulatory Guide 1.37. As noted in Regulatory Position C.1, other industry standards may be referenced; the commitment in this QATR to NQA-1, Subpart 2.1 includes commitment to those standards to the extent necessary to implement Subpart 2.1 requirements. If NRC guidance applies to those referenced standards, it is followed. Regulatory Positions C.3, C.4 and C.5 recommend alterations to certain provisions of N45.2.1. The provisions of NQA-1, Subpart 2.1 establish requirements that are consistent with those recommendations.

Regulatory Position C.2 indicates that the requirements of the endorsed standard should be used during the operations phase when applicable. This is addressed in sections B.7 and B.16 of this QATR, which also establish any necessary exceptions or alternatives to the provisions of Subpart 2.1.

• Regulatory Guide 1.38, Revision 2, May 1977, Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Water-Cooled Nuclear Power Plants, (ANSI N45.2.2-1972) - NSPM substitutes NQA-1 1994, Subpart 2.2 for N45.2.2 in its commitment to Regulatory Guide 1.38. As noted in Regulatory Position C.1.a, other industry standards may be referenced; the commitment in this QATR to NQA-1, Subpart 2.2 includes commitment to those standards to the extent necessary to implement Subpart 2.2 requirements. If NRC guidance applies to those referenced standards, it is followed. Regulatory Position C.1.b modifies a provision of N45.2.2 such that the minimum load for dynamic testing to re-rate hoisting equipment for special lifts becomes 110% of the rated load. The Handling section (7) of NQA-1, Subpart 2.2 defers to the provisions of Subpart 2.15. NSPM does not commit to Subpart 2.15, as there is no current NRC guidance regarding the other provisions of this part.

For purposes of compliance to Regulatory Guide 1.38, Position C.1.b, NSPM commits to follow the guidance as stated (see section B.7). Regulatory Positions C.1.c, C.1.e, C.2.a, C.2.b, C.2.c, C.2.d and C.2.e recommend alterations to certain provisions of N45.2.2. The provisions of NQA-1, Subpart 2.2 establish requirements that are consistent with those recommendations. Regulatory Position C.1.d indicates that the requirements of the endorsed standard should be used during the operations phase when applicable. This is addressed in section B.7 of this QATR, which also establishes any necessary exceptions or alternatives to the provisions of Subpart 2.2.

• Regulatory Guide 1.39, Revision 2, September 1997, Housekeeping Requirements for Water-Cooled Nuclear Power Plants, (ANSI N45.2.3-1973) - NSPM substitutes NQA-1 1994, Subpart 2.3 for N45.2.3 in its commitment to Regulatory Guide 1.39. As noted in Regulatory Position C.1, other industry standards may be referenced; the commitment in this QATR to NQA-1, Subpart 2.3 includes commitment to those standards to the extent necessary to implement Subpart 2.3 requirements. If NRC guidance applies to those referenced standards, it is followed. Regulatory Position C.2 indicates that the provisions of section 3.2.3 of N45.2.3 are not part of the Regulatory endorsement. As NQA-1, Subpart 2.3, section 3.2.3 has the same wording as N45.2.3, the Regulatory Position is applicable and will be followed in NSPMs implementation of Subpart 2.3.

Regulatory Position C.3 indicates that the endorsed standard is applicable for housekeeping activities during the operations phase that are comparable to those occurring during construction. This is addressed in section B.7 of this QATR, which also establishes any necessary exceptions or alternatives to the provisions of Subpart 2.3.

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• Regulatory Guide 1.54, Revision 0, June 1973, Quality Assurance for Protective Coatings Applied to Nuclear Power Plants (N101.4-1972) - Commitment to Regulatory Guide 1.54 is site specific, as required by the approved UFSAR/License at each NSPM site.

• Regulatory Guide 1.94, Revision 1, April 1976, Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants, (ANSI N45.2.5-1974) - NSPM substitutes NQA-1 1994, Subpart 2.5 for N45.2.5 in its commitment to Regulatory Guide 1.94; however, Subpart 2.5 includes requirements for soils and foundations which were not included in N45.2.5, and the commitment to Subpart 2.5 herein does not include commitment to those requirements. As noted in Regulatory Position C.1, other industry standards may be referenced; the commitment in this QATR to NQA-1, Subpart 2.5 includes commitment to those standards to the extent necessary to implement Subpart 2.5 requirements. If NRC guidance applies to those referenced standards, it is followed.

Regulatory Position C.2 recommends using the general planning provisions of N45.2.5 in conjunction with Regulatory Guide 1.55, which has since been withdrawn; therefore, this position is no longer applicable. Regulatory Positions C.3 and C.4 recommend alterations to certain provisions of N45.2.5. The provisions of NQA-1, Subpart 2.5 are consistent with those recommendations. Applicability and use of Subpart 2.5 is addressed in sections B.12 and B.16 of this QATR, which also establish any necessary exceptions or alternatives to the provisions of Subpart 2.5.

• Regulatory Guide 1.97, Revision 3, May 1983, Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident (Table 1, paragraph 5) - In lieu of the Regulatory Guides listed in the Table, NSPM commits to the Regulatory Guidance and industry standards for quality assurance as described in this QATR. Commitment to the technical provisions of Regulatory Guide 1.97 is site specific as addressed in each plant UFSAR or other licensing commitments.

• Regulatory Guide 1.116, Revision 0-R, May 1977, Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems, (ANSI N45.2.8-1975) - NSPM substitutes NQA-1 1994, Subpart 2.8 for N45.2.8 in its commitment to Regulatory Guide 1.116. As noted in Regulatory Position C.1, other industry standards may be referenced; the commitment in this QATR to NQA-1, Subpart 2.8 includes commitment to those standards to the extent necessary to implement Subpart 2.8 requirements. If NRC guidance applies to those referenced standards, it is followed. Regulatory Position C.3 recommends using section 5 of N45.2.8 in conjunction with Regulatory Guide 1.68 for pre-operational, cold functional, and hot functional testing. While section 5 of NQA-1, Subpart 2.8 provides the same requirements, it is anticipated that NSPM plants, since they are already beyond these tests, will not need to implement Regulatory Guide 1.68. If testing in accordance with Regulatory Guide 1.68 becomes necessary, NSPM will comply with the guidance of the Regulatory Guide 1.116 position. Regulatory Position C.2 indicates that the endorsed standard should be followed for those applicable operations phase activities that are comparable to activities occurring during the construction phase. This is addressed in sections B.12 and B.16 of this QATR, which also establish any necessary exceptions or alternatives to the provisions of Subpart 2.8.

• Regulatory Guide 1.143, Revision 2, November 2001, Design Guidance for Radioactive Waste Management Systems, Structures and Components Installed in Light-water-17 NSPM-1 QATR, Rev 8a

NSPM Quality Assurance Topical Report Cooled Nuclear Power Plants -Compliance to the quality assurance guidance cited in Regulatory Guide 1.143, Revision 2, November 2001 is site specific, as addressed in each plant USAR.

• Regulatory Guide 1.152, Revision 1, January 1996, Criteria for Digital Computers in Safety Systems of Nuclear Power Plants - None of the current NSPM plants were committed to this Regulatory Guidance during original construction. Regulatory Guide 1.152 may be used for plant modifications on a case by case basis, but this QATR makes no generic commitment thereto.

• Regulatory Guide 1.155, Revision 0, August 1988, Station Blackout (Position C.3.5) -

NSPM commits to the quality assurance guidance cited in Position C.3.5, Appendix A.

Compliance with Appendix B and the remainder of the [technical] positions of Regulatory Guide 1.155 is site specific, as addressed in each plant UFSAR or License commitments.

• Generic Letter 89-02/EPRI-NP-5652 (March 1988, and supplements through March 1993) - NSPM commits to compliance with the endorsed industry guidance regarding selection and qualification of commercial grade suppliers and dedication of commercial grade items for use in safety related applications.

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

NSPM provisions for administrative controls for Fire Protection comply with site specific commitments, or with the provisions of Position C.2 of CMEB 9.5-1, Rev. 2, as specified in NRC approved site fire protection programs and the applicable NRC Safety Evaluation Reports. Application of the provisions of this QATR to fire protection activities provides elements of quality assurance that comply with site specific fire protection quality assurance commitments or with CMEB 9.5-1, Revision 2, Position C.4.

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

NSPM commits to compliance with Regulatory Guide 4.15.

• Regulatory Guide 7.10, Revision 1, June 1986, Establishing Quality Assurance Programs for Packaging Used in the Transport of Radioactive Material - NSPM commits to implement the quality assurance guidance for activities related to the packaging and transport of radioactive material that are under its control. Quality Assurance for the design, fabrication and licensing of shipping containers is the responsibility of the container certificate holders.

• Generic Letter 85-06, April 1985, Quality Assurance Guidance for ATWS Equipment That Is Not Safety-Related - NSPM commits to the quality assurance guidance cited in the Generic Letter.

• Regulatory Issue Summary 2000-18, October 2000, Guidance on Managing Quality Assurance Records in Electronic Media - Should NSPM choose electronic media storage as a means of maintaining required records, NSPM will comply with the guidance of this Regulatory Issue Summary.

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NSPM Quality Assurance Topical Report B PERFORMANCE/VERIFICATION B.1 Methodology Personnel who work directly or indirectly for NSPM are responsible for the achievement of acceptable quality in the work covered by this QATR. This includes design, engineering, procurement, manufacturing, construction, installation, start-up, maintenance, modifications, and operations.* NSPM personnel performing verification activities are responsible for verifying the achievement of acceptable quality. Activities governed by the QAP are performed as directed by documented instructions, procedures and drawings that are of a detail appropriate for the activitys complexity and effect on safety. Instructions, procedures and drawings specify quantitative or qualitative acceptance criteria as applicable or appropriate for the activity, and verification is against these criteria. Provisions are established to designate or identify the proper documents to be used in an activity, and to ascertain that such documents are being used.

B.2 Design Control NSPM has established and implements a program to control the design of items that are subject to the provisions of this QATR (see A.1). The program includes provisions to control design inputs, processes, outputs, changes, interfaces, records and organizational interfaces. These provisions assure that design inputs (such as design bases and the performance, regulatory, quality, and quality verification requirements) are correctly translated into design outputs (such as specifications, drawings, procedures, and instructions) such that the final design output can be related to the design input in sufficient detail to permit verification. The program defines the interface controls (internal and external between participating design organizations and across technical disciplines) necessary to control the development, review, approval, release, distribution and revision of design inputs and outputs.

NSPM design processes provide for design verification (as described in Section B.3) that items and activities subject to the provisions of this QATR are suitable for their intended application, consistent with their effect on safety. Changes to final designs (including field changes) are subjected to these controls, which include measures commensurate with those applied to original plant design. Design changes and disposition of nonconforming items as use as is or repair are reviewed and approved by the responsible NSPM design authority.

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

• As NSPM retains ownership of the operating nuclear power plants and is not actively decommissioning, this QATR does not address decommissioning as an activity within its scope. Should NSPM become involved in plant decommissioning, this QATR will be revised, or a separate QATR developed, to assure appropriate programmatic controls are applied to that activity.

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NSPM Quality Assurance Topical Report In addition, temporary design changes (temporary modifications), such as temporary bypass lines, electrical jumpers and lifted leads, and temporary trip-point settings, are controlled by procedures that include requirements for appropriate installation and removal verifications and status tracking.

In establishing its program for design control, NSPM commits to compliance with NQA-1, 1994, Basic Requirement 3, and Supplement 3S-1, Sections 1, 2, 3, 5, 6, and 7.

B.3 Design Verification The NSPM design control program includes requirements for verifying the acceptability of design activities and documents, consistent with their effect on safety. This includes design inputs, design outputs and design changes. Design verification procedures are established and implemented to assure that an appropriate verification method is used, the appropriate design parameters to be verified are chosen, the acceptance criteria are identified, and the verification is satisfactorily accomplished and documented. Verification methods may include, but are not limited to, design reviews, alternative calculations and qualification testing. Testing used to verify the acceptability of a specific design feature demonstrates acceptable performance under conditions that simulate the most adverse design conditions expected for items intended use.

NSPM completes design verification activities before the design outputs are used by other organizations for design work, and before they are used to support other activities such as procurement, manufacture or construction. When such timing cannot be achieved, the unverified portion of the design is identified and controlled such that, in all cases, the design verification is completed before relying on the item to perform its intended safety function.

The NSPM design verification can be performed by the designers immediate supervisor, provided (1) the supervisor did not specify a singular design approach or rule out certain design considerations and did not establish the design inputs used in the design, or (2) the supervisor is the only technically qualified individual capable of performing the verification, and (3) the need is individually documented and approved in advance by the supervisors management. The frequency and effectiveness of the use of supervisors as design verifiers are independently audited, as provided in Section C of this QATR, to guard against abuse.

In establishing its program for design verification, NSPM commits to compliance with NQA-1, 1994, Basic Requirement 3, and Supplement 3S-1, Section 4.

B.4 Procurement Control NSPM establishes and implements controls to assure that purchased items (components, spares and replacement parts necessary for plant operation, refueling, maintenance and modifications) and services are subject to quality and technical requirements at least equivalent to those specified for original equipment or specified by properly reviewed and approved revisions to assure the items are suitable for the intended service, and are of acceptable quality, consistent with their effect on safety. These controls include provisions such that:

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

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• Items are inspected (see B.12) and identified and stored (see B.6 and B.7) to protect against damage, deterioration or misuse.

• Prospective suppliers of safety-related items and services are evaluated to assure that only qualified suppliers are used. Qualified suppliers are periodically evaluated to assure they continue to provide acceptable products and services. Industry programs, such as those applied by ASME, NUPIC, or other established utility groups, are used as input or the basis for supplier qualification whenever appropriate. In addition, NSPM commits to Position C.3.2 of Regulatory Guide 1.28, Revision 3, for auditing and evaluation of suppliers, with the exception that for position C.3.2.2, NSPM will review the information described therein as it becomes available through its ongoing receipt inspection, operating experience, and supplier evaluation programs, in lieu of performing a specific evaluation on an annual basis. The results of the reviews are promptly considered for effect on a suppliers continued qualification and adjustments made as necessary (including corrective actions, adjustments of supplier audit plans, and input to third party auditing entities, as warranted). In addition, results are reviewed periodically to determine if, as a whole, they constitute a significant condition adverse to quality requiring additional action. NSPM considers that other 10 CFR 50 licensees, Authorized Nuclear Inspection Agencies, National Institute of Standards and Technology, or other State and Federal agencies which may provide items or services to NSPM plants are not required to be evaluated or audited.

• Applicable technical, regulatory, administrative, quality and reporting requirements (such as specifications, codes, standards, tests, inspections, special processes, and 10CFR21) are invoked for procurement of items and services. Documentary evidence that an item conforms to these requirements is available at the site before relying on the item to perform its intended safety function. These documents are considered records according to section B.15.

• Provisions are made for accepting purchased items and services, such as source verification, receipt inspection, pre- and post-installation tests, certificates of conformance, and document reviews. Acceptance actions are completed to ensure that procurement, inspection, and test requirements, as applicable, have been satisfied before relying on the item to perform its intended safety function.

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

• Commercial-grade calibration services may be acquired without performing an audit, accepting an audit by another licensee, performing a commercial-grade supplier survey, conducting inspections or tests following delivery, or conducting in-process surveillance during performance of the service, provided that a documented review confirms that the supplier is accredited by the National Voluntary Laboratory Accreditation Program (NVLAP), the American Association for Laboratory Accreditation (A2LA), or the ACLASS Accreditation Services, the accreditation is to ANSI/ISO/IEC 17025, and the published scope of the accreditation for the calibration laboratory covers the needed measurement parameters, ranges and uncertainties. Purchase documents for such services require reporting of as-found calibration data when calibrated items are found to be out of 21 NSPM-1 QATR, Rev 8a

NSPM Quality Assurance Topical Report tolerance, and require that the calibration certificate/report include identification of the laboratory equipment/standards used.

In establishing controls for procurement, NSPM commits to compliance with NQA-1, 1994, Basic Requirements 4 and 7, and Supplements 4S-1 and 7S-1, with the following exceptions:

• For Supplement 4S-1, section 2.3, which requires procurement documents to require a quality program that complies with NQA-1, NSPM may apply other nationally recognized and NRC endorsed quality standards, such as N45.2, as appropriate to the circumstances of the procurement, and may also elect to purchase items or services commercially available and then dedicate them for safety-related service per Generic Letter 89-02/EPRI NP-5652.

• For Supplement 7S-1, section 8.1, documentary evidence that items conform to procurement requirements need not be available at the site prior to item installation, but will be available at the site prior to placing reliance on the item for its intended safety function.

B.5 Procurement Verification NSPM establishes and implements measures to verify the quality of purchased items and services, whether purchased directly or through contractors, at intervals and to a depth consistent with the items or services importance to safety, complexity, quantity and the frequency of procurement. Verification actions include testing, as appropriate, during design, fabrication and construction activities associated with plant maintenance or modifications.

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

In establishing procurement verification controls, NSPM commits to compliance with NQA-1, 1994, Basic Requirement 7 and Supplement 7S-1.

B.6 Identification and Control of Items NSPM establishes and implements provisions for the identification and control of items to prevent the use of incorrect or defective items. This includes controls for consumable materials and items with limited shelf life. The identification of items is maintained throughout fabrication, erection, installation and use so that the item can be traced to its documentation, consistent with the items effect on safety. Identification locations and methods are selected so as not to affect the function or quality of the item.

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

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NSPM Quality Assurance Topical Report B.7 Handling, Storage and Shipping NSPM establishes and implements provisions to control the handling, storage, shipping, cleaning and preservation of items to prevent inadvertent damage, loss or deterioration. These provisions include specific procedures, when required to maintain acceptable quality, for cleaning, handling, storage, packaging, shipping and preserving items important to safety.

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

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

In establishing provisions for handling, storage and shipping, NSPM commits to compliance with NQA-1, 1994, Basic Requirement 13 and Supplement 13S-1. NSPM also commits to compliance with the requirements of NQA-1, 1994, Subpart 2.2, with the following exceptions:

• Subpart 2.2, section 2.2 establishes criteria for classifying items into protection levels.

Instead of classifying items into protection levels, NSPM plants may establish controls for the packaging, shipping, handling and storage of such items on a case-by-case basis with due regard for the items complexity, use, and sensitivity to damage. Prior to installation or use, the items are inspected and serviced as necessary to assure that no damage or deterioration exists which could affect their function.

• Subpart 2.2, section 5.2.2 requires receiving inspections be performed in an area equivalent in environmental controls to those for the level of storage of the item. At NSPM plants, receiving inspection area environmental controls may be less stringent than the storage environmental requirements for the item. Such inspections are performed in a manner and in an environment which does not endanger the required quality of the item.

• Subpart 2.2, section 7.1 refers to Subpart 2.15 for requirements related to handling of items. The scope of Subpart 2.15 includes hoisting, rigging and transporting of items for nuclear power plants. This scope exceeds the scope of the NRCs original endorsement of ANSI N45.2.2 in Regulatory Guide 1.38, and establishes requirements for which there is no NRC regulatory position. In lieu of compliance with Subpart 2.15, NSPM establishes and implements controls over hoisting, rigging and transport activities to the extent necessary to protect the integrity of the items involved, as well as potentially affected nearby structures and components. For re-rating of lifting equipment to allow special lifts, NSPM performs dynamic load testing over the full range of the lift using test loads at least 110% of the lift weight. Dynamic tests include raising, lowering and traversing the load. Where required, NSPM complies with applicable hoisting, rigging and transportation regulations and codes.

Housekeeping practices during normal operations and maintenance activities, including refueling, are established to account for the control of radiation zones and other conditions or environments that could affect the quality of structures, systems and components within the plant. This includes control of cleanness of facilities and materials, fire prevention and protection, disposal of combustible material and debris, control of access to work areas, protection of equipment, radioactive contamination control and storage of solid radioactive waste. Housekeeping practices assure that only proper materials, equipment, processes and procedures are used and that the quality of items is not degraded as a result. Necessary 23 NSPM-1 QATR, Rev 8a

NSPM Quality Assurance Topical Report procedures or work instructions, such as for electrical bus and control center cleaning, cleaning of control consoles, and radioactive decontamination are developed and used.

In addition, NSPM commits to compliance with the requirements of NQA-1, 1994, Subpart 2.1, to establish appropriate provisions for the cleaning of fluid systems and associated components; and Subpart 2.3, to establish appropriate provisions for housekeeping; with the following exceptions:

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

• Instead of the five-level zone designation in Subpart 2.3, NSPM bases its control over housekeeping activities on a consideration of what is necessary and appropriate for the activity involved. The controls are effected through procedures or instructions which, in the case of maintenance or modification work, are developed on a case-by-case basis.

Factors considered in developing the procedures and instructions include cleanliness control, personnel safety, fire prevention and protection, radiation control and security.

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

B.8 Test Control NSPM establishes and implements testing programs to demonstrate that items subject to the provisions of this QATR will perform satisfactorily in service, that the plant can be operated safely and as designed, and that the coordinated operation of the plant as whole is satisfactory.

These programs include criteria for determining when testing is required, such as proof tests before installation, pre-operational tests, post-maintenance tests, post-modification tests, inservice tests, and operational tests (such as surveillance tests required by Plant Technical Specifications), to demonstrate that performance of plant systems is in accordance with design intent. Programs also include provisions for establishing and adjusting test schedules and maintaining status for periodic or recurring tests. Tests are performed according to applicable procedures that include, consistent with the effect on safety, (1) instructions and prerequisites to perform the test, (2) use of proper test equipment, (3) acceptance criteria, and (4) mandatory verification points as necessary to confirm satisfactory test completion. Test results are documented and evaluated by the organization performing the test and reviewed by the appropriate authority having responsibility for the item being tested. If acceptance criteria are not met, retesting is performed as needed to confirm acceptability following correction of the system or equipment deficiencies that caused the failure.

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

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NSPM Quality Assurance Topical Report B.9 Measuring and Test Equipment Control NSPM establishes and implements provisions to control the calibration, maintenance, and use of measuring and test equipment, including installed plant instrumentation, that provide information important to safe plant operation. The provisions cover equipment such as indicating and actuating instruments and gages, tools, reference and transfer standards, and nondestructive examination equipment. The provisions assure that:

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

• Measuring and test equipment is labeled, tagged or otherwise controlled to indicate its calibration status and provide traceability to calibration test data or records.

• Calibrations are performed against standards that have an accuracy of at least four times the required accuracy of the equipment being calibrated. When this is not possible, the standards have an accuracy that ensures the equipment being calibrated will be within the required tolerance.

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

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

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

In establishing provisions for control of measuring and test equipment, NSPM commits to compliance with NQA-1, 1994, Basic Requirement 12, Supplement 12S-1 and Subpart 2.16 for establishing appropriate requirements for calibration and control of measuring and test equipment, including installed plant instrumentation, with the following exception:

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

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NSPM Quality Assurance Topical Report B.10 Inspection, Test and Operating Status NSPM establishes and implements measures to identify the inspection, test and operating status of items and components subject to the provisions of this QATR in order to maintain personnel and reactor safety and avoid unauthorized operation of equipment. Where necessary to preclude inadvertent bypassing of inspections or tests, or to preclude inadvertent operation, these measures require the inspection, test or operating status be verified before release, fabrication, receipt, installation, test or use. These measures also establish the necessary authorities and controls for the application and removal of status indicators or labels.

Equipment control provisions for workmens protection comply with applicable federal and state OSHA regulations.

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

B.11 Special Process Control NSPM establishes and implements provisions to assure that special processes that require interim process controls to assure quality, such as welding, heat treating, chemical cleaning, and nondestructive examination, are controlled. These provisions include assuring that special processes are accomplished by qualified personnel using qualified procedures and equipment.

Special processes are performed in accordance with applicable codes, standards, specifications, criteria or other specially established requirements. Special processes are those where the results are highly dependent on the control of the process or the skill of the operator, or both, and for which the specified quality cannot be fully and readily determined by inspection or test of the final product.

In establishing measures for the control of special processes, NSPM commits to compliance with NQA-1, 1994, Basic Requirement 9 and Supplement 9S-1, as well as the applicable ASME Boiler and Pressure Vessel Code provisions established via 10CFR50.55a.

B.12 Inspection NSPM establishes and implements provisions for inspections to assure that items, services and activities affecting safety meet established requirements and conform to applicable documented instructions, procedures and drawings. Inspection may also be applied to items, services and activities affecting plant reliability. Types of inspections may include those verifications related to procurement, as discussed in B.4 and B.5, such as source, in-process, final, and receipt inspection, as well as maintenance, modification, in-service, and operational activities.

Inspections are carried out by properly qualified persons independent of those who performed or directly supervised the work. (Note: QATR requirements can be met for peer inspection provided the individual meets the minimum qualifications for the task and was not the task performer or task supervisor. The individual can be assigned to the work order/job being inspected, provided the individual was not involved in the particular task subject to inspection). 2 Inspection planning (for those activities subject to inspection) identifies the characteristics and activities to be inspected, the inspection techniques, the acceptance criteria and the organization responsible for performing the inspection. Inspection planning identifies required hold points, beyond which work is not to proceed without the consent of the inspection 2

Ref. QATR Interpretation 05-02 Rev 1.

26 NSPM-1 QATR, Rev 8a

NSPM Quality Assurance Topical Report organization. Provisions for ASME Boiler and Pressure Vessel Code Authorized Inspections are included when required.

Inspection results are documented by the inspector and approved by authorized personnel. If acceptance criteria are not met, corrected areas are re-inspected.

In establishing inspection requirements, NSPM commits to compliance with NQA-1, 1994, Basic Requirement 10, Supplement 10S-1 and Subpart 2.4. In addition, for situations comparable to original construction, NSPM commits to compliance with the requirements of Subparts 2.5 and 2.8 for establishing appropriate inspection requirements.

B.13 Corrective Action NSPM establishes and implements provisions to assure that personnel have both the responsibility and authority to identify conditions adverse to quality, and the opportunity to suggest, recommend or provide solutions to resolve the condition. Provisions also include verification of resolution of significant issues (see also section A.6). Reworked, repaired and replacement items are inspected and tested to meet the original inspection or test requirements, or appropriately specified alternatives (see also sections B.8 and B.12).

If evidence indicates that common components in safety related systems have performed unsatisfactorily, compensatory or corrective measures are planned prior to replacement or repair of such components. Replacement components receive adequate testing or are of a design for which experience indicates a high probability of satisfactory performance.

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

In establishing provisions for corrective action and control of non-conforming items, NSPM commits to compliance with NQA-1, 1994, Basic Requirements 15 and 16, and Supplement 15S-1.

B.14 Document Control NSPM establishes and implements provisions to specify the format and content (see Appendix B for procedures), and control the development, review, approval, issue, use and revision, of documents that specify quality requirements or prescribe activities affecting quality or safe operation to assure the correct documents are being employed. These provisions assure that specified documents are reviewed for adequacy, approved prior to use by authorized persons, and distributed according to current distribution lists and used at the location where the prescribed activity takes place. Procedures governing generating site activities (see Appendix B) are reviewed by qualified persons, other than the preparer, as designated by the Plant Manager (Note: only safety-related procedures, and procedures important to safety as used in 10CFR71 and 72, from the types listed in Appendix B of the QATR require this review. Most administrative procedures (site or Fleet) would not require this review)3. Such procedure review includes determination whether additional cross-discipline reviews are required. Only safety-related procedures, and procedures important to safety as used in 10CFR71 and 72, from the types listed in Appendix B (pages 37-40), require this review. Provisions include establishing levels of use, such as requiring the document to be present at the work location. Documents subject to control provisions include, but are not limited to, drawings (design, as-built),

3 Ref. QATR Interpretation 05-01.

27 NSPM-1 QATR, Rev 8a

NSPM Quality Assurance Topical Report engineering documents (calculations, analyses, specifications, computer codes, Updated Final Safety Analysis Reports, Plant Technical Specifications), and procedures (administrative, operating, emergency operating, maintenance, calibration, surveillance, inspection, test). Other documents, such as those related to procurement, corrective actions, and assessments, are controlled as defined by the provisions and commitments cited in those sections of this QATR.

Controlled copies of instructions and procedures are made available to and used by the persons performing the activity covered. New or revised controlled documents are made available in a timely fashion to support ongoing work and preclude use of incorrect information. Superseded documents are identified or removed from availability. Each site maintains documentation that describes how implementing documents are maintained to assure that QAP requirements are met and are not inadvertently removed in later revisions.

Revisions to controlled documents are reviewed for adequacy and approved for release by the same organization(s) as originally did so, or by other designated organizations that are qualified and sufficiently knowledgeable of the requirements and intent of the original document. NSPM also establishes programmatic procedure preparation, review and usage controls that ensure procedures are technically and administratively correct. These controls ensure that procedures are reviewed when pertinent source material is revised (such as when Technical Specifications are revised), when unusual incidents occur, when plant modifications are made, and when significant deficiencies are identified. Procedures may also be reviewed because industry experience reviews, use during job execution or training, self-assessments, or independent audits or assessments identify deficiencies or opportunities for improvement. Revisions are made as necessary.

Temporary changes to approved procedures that do not change the intent are approved by two members of plant staff knowledgeable in the areas affected by the procedure. Temporary changes to procedures identified in Appendix B are approved by two members of plant staff knowledgeable in the areas affected by the procedure, at least one of whom is a person holding an active senior reactor operators license. Temporary changes are documented and, if appropriate, incorporated in the next revision of the procedure.

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

B.15 Records NSPM establishes and implements provisions to ensure that sufficient records of items and activities affecting quality are generated and maintained to reflect completed work. Such records may include, but are not limited to, design, engineering, procurement, manufacturing, construction, inspection, test, installation, modification, operations, maintenance, corrective action, assessment, and associated reviews. The provisions establish requirements for records administration, including generation, receipt, preservation, storage, safekeeping, retrieval and final disposition. For activities governed by 10CFR71 or 72, these provisions address the specific requirements of sections 71.135 and 72.174.

NSPM uses the list of records in 10CFR71.135, 10CFR72.174, and NQA-1 Non-mandatory Appendix 17A-1, supplemented by the recommended retention times established in Regulatory Guide 1.28, position C.2 (Table 1), to establish the types of records that will be created and retained in support of plant operation. Non-mandatory Appendix 17A-1 of NQA-1-1994 lists only those operations phase records having permanent (lifetime) retention; Regulatory Guide 1.28, Table 1, which provides for lifetime, 3, and 10 year (non-permanent) retention periods, does not 28 NSPM-1 QATR, Rev 8a

NSPM Quality Assurance Topical Report specifically list operations phase record types. NSPM establishes appropriate retention times for non-permanent operations phase records based on similarity to the same record types identified in Table 1 of Regulatory Guide 1.28, or consistent with other applicable regulatory requirements, such as 10CFR73 for Security and Access Authorization records.4 Thus, non-permanent records are designated for 3 or 10 year retention, as required by NQA-1-1994, Supplement 17S-1, sections 2.7 and 2.8. In cases where local or State retention requirements are more restrictive than the regulatory guidance, the local requirements are met. In addition, when using electronic media storage as a means of maintaining required records, NSPM complies with NRC guidance in RIS 2000-18.

In establishing provisions for records, NSPM commits to compliance with NQA-1, 1994, Basic Requirement 17 and Supplement 17S-1, with the following exception:

• Supplement 17S-1, section 4.2(b) requires records to be firmly attached in binders or placed in folders or envelopes for storage in steel file cabinets or on shelving in containers. For hard-copy records maintained by NSPM, the records are suitably stored in steel file cabinets or on shelving in containers, except that methods other than binders, folders or envelopes may be used to organize the records for storage.

4 Ref. QATR Interpretation 12-01.

B.16 Plant Maintenance NSPM establishes controls for the maintenance or modification of items and equipment subject to this QATR to ensure quality at least equivalent to that specified in original design bases and requirements, such that safety-related structures, systems and components are maintained in a manner that assures their ability to perform their intended safety function(s). Maintenance activities (both corrective and preventive) are scheduled and planned so as not to unnecessarily compromise the safety of the plant. Permission to release equipment or systems for maintenance is granted by designated operating personnel who are responsible to verify that the equipment or system can be released and determine how long it may be out of service.

This includes attention to the potentially degraded degree of protection when one subsystem of a redundant safety system has been removed for maintenance. Release is documented. When equipment is ready to be returned to service, operating personnel place the equipment in operation and verify and document its functional acceptability. In completing maintenance and restoring equipment, attention is given to restoration of normal conditions, such as removal of jumpers or signals used in maintenance or testing, or such as returning valves, breakers or switches to proper operating positions.

In establishing controls for plant maintenance, NSPM commits to compliance with NQA-1, 1994, Subpart 2.18, with the following exceptions:

• Section 2.3.a requires cleanliness during maintenance to be in accordance with Subpart 2.1. NSPM commitment to Subpart 2.1 is described in section B.7.

• Section 2.7 requires the application of Subparts 2.4, 2.5 and 2.8 for inspections of installation activities. NSPM commitment to Subparts 2.5 and 2.8 is limited to activities comparable in nature and extent to those during original construction (see B.12).

Inspections (verifications) of maintenance or modification activities are established, conducted and documented as required by Section B.12 to establish a suitable level of 29 NSPM-1 QATR, Rev 8a

NSPM Quality Assurance Topical Report confidence in affected structures, systems, or components. The inspection criteria in Subparts 2.5 and 2.8 may be used in establishing required inspections for maintenance and minor modifications.

B.17 Computer Software Control NSPM establishes and implements provisions to assure that computer software used in applications affecting safety is prepared, documented, verified and tested, and used such that the expected output is obtained and configuration control maintained. To this end NSPM commits to compliance with the requirements of NQA-1 1994, Supplement 11S-2 and Subpart 2.7 to establish the appropriate provisions.

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NSPM Quality Assurance Topical Report C. ASSESSMENT C.1 Methodology NSPM establishes programs for reviews, audits and assessments to verify that activities covered by this QATR are performed in conformance with the requirements established, review significant proposed plant changes or tests, verify that reportable events are promptly investigated and corrected, and detect trends which may not be apparent to the day-to-day observer. These programs are, themselves, reviewed for effectiveness as part of the overall assessment process, as described herein. Nuclear Oversight provides for independent audit and assessment of work carried out under the requirements of the QAP that is delegated to other (non-NSPM) entities.

NSPM uses self-assessment (performed by or for the group responsible for the activity being assessed) and independent audit/assessment (performed by the Nuclear Oversight organization) to monitor overall performance, identify anomalous performance and precursors of potential problems, and verify satisfactory resolution of problems. Persons responsible for carrying out audits and assessments are cognizant of day-to-day activities such that they can act in a management advisory function with respect to the scope of the assessment. Both self-assessments and independent audits/assessments are accomplished using instructions or procedures that provide detail commensurate with the assessed activitys complexity and importance to safety.

NSPM plants maintain plant operating review committees to review overall plant performance, and advise site Management on matters related to nuclear safety. Appendix A establishes the minimum requirements for these committees.

NSPM periodically performs independent reviews of matters involving the safe operation of its fleet of nuclear power plants, with a minimum of one such review being conducted for each generating site each year. The review addresses matters that plant and corporate management determine warrant special attention, such as plant programs, performance trends, employee concerns, or other matters related to safe plant operations. 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) from the organizations responsible for those activities. The review is supplemented by outside consultants or organizations as necessary to ensure the team has the requisite expertise and competence. Results are documented and reported to responsible management.

C.2 Self-Assessment NSPM uses self-assessments performed by or for the group responsible for the activity being assessed to identify anomalous performance and precursors of potential problems. When line organizations perform self-assessments, their approach is technically and performance oriented with focus on the quality of the end product as well as on compliance with procedures and processes. The objective of self-assessment is to verify compliance, improve performance and achieve excellence. Results of self-assessments are reported in an understandable form and in a timely fashion to a level of management having the authority to effect corrective action and verify satisfactory resolution of problems.

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NSPM Quality Assurance Topical Report C.3 Independent Audit NSPM has established a program of planned and periodic independent audits to confirm that activities affecting quality comply with the QAP and that the QAP is effectively implemented.

The organization performing independent audits (Nuclear Oversight) is technically and quality oriented, with its focus on the quality of the end product, compliance with established requirements, and the effective implementation of procedures and processes. Persons performing independent audits do not have direct responsibility for any area being examined, and do not report to a management position with immediate responsibility for the activity being audited. NSPM audit resources may be supplemented with technical specialists as needed. The independent audit program provides evaluations of activities and procedures. Planning for independent audits identifies the characteristics and activities to be audited and the relevant acceptance criteria. In addition, independent audits include examination of selected procedures to verify that the procedure review and revision controls of section B.14 are effectively implemented. As appropriate to the scope of an audit, these criteria include related plant Technical Specification requirements. Independent audits are then conducted using these predetermined criteria.

Independent audits are scheduled and completed such that:

• The performance of activities required by the QATR and to meet the criteria of 10 CFR 50, Appendix B, 10 CFR 72.140 and 10 CFR 71.101 is audited nominally* at least once every 24 months.

• Certain programs or activities, as identified in Table 1, receive audits at frequencies established by related NRC rules, or nominally* every 24 months if a rule does not establish frequency.

• *Nominally means that the audit may be completed within a period that is 25 percent longer or shorter than the period stated. Thus the next scheduled due date for a biennial audit could be no later than 30 months from the previous completion of the audit. The subsequent audit returns to the original schedule.

Results of independent audits are reported in an understandable form and in a timely fashion to a level of management having the authority to effect corrective action. Nuclear Oversight conducts timely follow-up action, including re-audit of deficient areas, as determined necessary to establish adequacy of corrective actions.

Independent audit results are documented and reviewed by Nuclear Oversight management and by management having responsibility for the area audited.

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

C.4 Independent Assessment NSPM has established a program of independent assessments and monitoring of overall performance to identify anomalous performance and precursors of potential problems, and verify satisfactory resolution of problems. The organization performing independent assessment (Nuclear Oversight) is technically and performance oriented, with its focus on the quality of the end product and the effective implementation of procedures and processes. Persons performing independent assessments do not have direct responsibility for any area being assessed, and do not report to a management position with immediate responsibility for the activity being assessed. NSPM assessment resources may be supplemented with technical specialists as 32 NSPM-1 QATR, Rev 8a

NSPM Quality Assurance Topical Report needed. Planning for independent assessments identifies the activities to be assessed and the relevant performance and/or acceptance criteria. Independent assessments are then conducted using these predetermined criteria. Scheduling and resource allocation for independent assessments are based on the status, performance, and effect on safety of the activity or process being assessed. Scheduling is dynamic to provide for response to developing performance issues and resources are supplemented as necessary when performance is in question. Performance of at least those functional areas identified in Table 2 is monitored on a regular basis and results used to determine where independent assessment should be applied to identify anomalous behavior, gaps to industry performance standards, precursors to problems, or to verify satisfactory resolution of problems to achieve improvements.

Results of monitoring and independent assessments are reported (such as via the corrective action program) to a level of management having the authority to effect corrective action.

Nuclear Oversight conducts timely follow-up action, including re-assessment of deficient areas, as determined necessary to establish adequacy of corrective actions.

In addition, Nuclear Oversight activities are periodically assessed for effectiveness. Results are documented and reported to responsible management.

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NSPM Quality Assurance Topical Report Table 1 Programs or Activities Subject to Regulatory-related Independent Audit Frequencies Program/Activity Frequency Basis Emergency Planning Annual 10CFR50.54(t)

Fitness for Duty Biennial* 10CFR26.41(b)

Access Authorization Biennial*

10CFR73.56(n)

(Contractor Programs) (Annual*)

Site Security (includes Safe- 10CFR73.55(m)

Annual guards Contingency Plans) 10CFR50.54(p)

Fire Protection Biennial* (includes use

• Prevention, Detection March 24, 2005 NRC approval of of a non-company, and Response QATR qualified fire protection

• Alternate Shutdown specialist)

Capability Radiological Environmental Biennial* RG 4.15 Monitoring Station Blackout Biennial* RG 1.155 Independent Spent Fuel Storage Biennial* 10CFR72, Subpart G Shipping of >Type A Radioactive 10CFR71, Subpart H Annual*

Waste RG 7.10

• Nominally; means that the audit may be completed within a period that is 25 percent longer or shorter than the period stated. Thus the next scheduled due date for a biennial audit could be no later than 30 months from the previous completion of the previous audit. The subsequent audit returns to the original schedule.

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NSPM Quality Assurance Topical Report Table 2 Functional Areas Subject to Performance Monitoring (monitoring not limited to these areas)

Functional Areas Operations Maintenance Engineering Radiological Protection Chemistry Training Performance Assessment 35 NSPM-1 QATR, Rev 8a

NSPM Quality Assurance Topical Report Appendix A Plant Operating Review Committee 1.0 General The Plant Operating Review Committee (PORC) is responsible to the Plant Manager for advice on all plant-related matters concerning nuclear safety. The requirements for personnel, committee composition, meeting frequency, quorum and meeting records are identified in implementing procedures. A general description of these areas is included below. (Note: Each plant may name this function differently. Regardless of the name, these requirements are met.)

In discharging its independent review responsibilities, PORC shall keep safety considerations paramount when opposed to cost or schedule considerations. Should a voting member at a particular meeting have direct responsibility for an item under review where a conflict of such considerations is likely, that member shall be replaced (to fill the quorum) by another voting member not having such potential conflict.

2.0 Composition PORC is comprised of a minimum number of members as designated by the Plant Manager and detailed in implementing procedures. All members are qualified in accordance with implementing procedure requirements that meet site Technical Specifications. Membership includes representation from at least the following disciplines: Operations, Maintenance, Engineering, Radiation Protection and Chemistry. PORC collectively has, or has access to, the experience and competence necessary to review the areas of (1) nuclear power plant operations, (2) nuclear engineering, (3) chemistry and radiochemistry, (4) metallurgy, (5) nondestructive testing, (6) instrumentation and control, (7) radiological safety, (8) mechanical and electrical engineering, (9) administrative controls and quality assurance practices, and (10) other fields associated with the unique characteristics of the plant. Consultants may be utilized to provide expert advice as needed.

Alternate chairmen and members may be appointed by the Plant Manager to serve on a permanent or temporary basis.

3.0 Meetings The PORC meets commensurate with the scope of activities, but minimal frequency requirements are specified in procedures.

Rules for a quorum are established and adhered to. However, no more than a minority of alternates may participate as voting members at any one time.

4.0 Review The PORC reviews at least the following:

(1) The Offsite Dose Calculation Manual (ODCM) and the Process Control Program (PCP).

(2) Proposed tests or experiments that affect nuclear safety.

(3) Proposed changes or modifications to plant systems or equipment that affect nuclear safety.

36 NSPM-1 QATR, Rev 8a

NSPM Quality Assurance Topical Report Appendix A Plant Operating Review Committee (4) Written 10CFR50.59/72.48 Evaluations to verify that changes to the facility or procedures, tests or experiments do not involve a change in the Technical Specifications or require prior NRC review.

(5) Proposed changes to Operating License and Technical Specifications.

(6) Reports covering violations of applicable statutes, codes, regulations, orders, Technical Specifications, license requirements, or of internal documents having nuclear safety significance.

(7) Reports of special reviews and investigations as requested by the Site Vice President, Director Site Operations, or Plant Manager.

(8) Events reportable in writing to the NRC according to applicable regulations.

(9) Any other matter related to nuclear safety requested by the Site Vice President, Director Site Operations or Plant Manager, selected by PORC members, or referred to PORC by other organizations, such as: plant operations to detect potential nuclear safety hazards, reports covering any indication of an unanticipated deficiency in some aspect of design or operation of safety-related structures, systems or components, and significant Nuclear Industry operating experience.

Reviews of items (6) through (9) include results of any investigations made and recommendations resulting from such investigations to prevent or reduce the probability of recurrence of the event.

5.0 Authority The PORC:

Recommends in writing to the Plant Manager approval or disapproval of items reviewed.

Renders determinations in writing with regards to whether items (1) through (5), or changes thereto, require prior NRC approval in accordance with 10CFR50.59/72.48.

Provides written notification to the onsite management level(s) above the Plant Manager of any disagreements between the PORC and the Plant Manager.

The PORC shall advise the Plant Manager on matters related to safe operation and overall performance. The PORC has authority to obtain access to records and personnel as needed to conduct reviews.

In carrying out its review responsibilities, the PORC may establish subcommittees or use designated organizational units to carry out the review. The subcommittees or organizational units regularly report results of reviews for full committee consideration and may recommend items for full committee review as warranted.

6.0 Records The PORC maintains written minutes of each PORC meeting, to include identification of items reviewed, and decisions and recommendations of the Committee. Copies of the minutes are provided to the onsite management position(s) above the Plant Manager, and to other onsite and offsite management responsible for the areas reviewed as necessary. PORC records are retained according to section B.15.

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NSPM Quality Assurance Topical Report APPENDIX B Procedures NSPM uses procedures to provide an approved, preplanned method of conducting activities affecting safety. As stated in position C.1 of Regulatory Guide 1.33, Revision 2, NSPM commits to use Appendix A of Regulatory Guide 1.33 as guidance for establishing the types of procedures that are necessary to control and support plant operation. Procedures are sufficiently detailed for a qualified individual to perform the required function without direct supervision, but may not provide a complete description of the system or plant process.

Guidance is established to identify the manner in which procedures are to be implemented, including identification of those tasks that require (1) the written procedure to be present and followed step by step while the task is being performed, (2) the user to have committed the procedure steps to memory, (3) verification of completion of significant steps, as by initials or signatures or use of check-off lists. Procedures that are required to be present and referred to directly are those developed for extensive or complex jobs where reliance on memory cannot be trusted, tasks that are infrequently performed, and tasks where steps must be performed in a specified sequence. When documentation of an action is specified, the necessary data is recorded as the task is performed.

The format of procedures may vary from plant to plant within NSPM; however, procedures include the following elements, as appropriate to the purpose or task covered. These elements are not intended to imply a specific format is required:

Title/status: each procedure is given a title descriptive of the work or subject it addresses, and includes a revision number and/or date and an approval status.

Purpose/Statement of applicability: the purpose for which the procedure is intended is clearly stated (if not clear from the title).

References:

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

Prerequisites: identifies those independent actions or procedures that must be accomplished and plant conditions which must exist prior to performing the procedure.

A prerequisite applicable to only a specific portion of a procedure is so identified.

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

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

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NSPM Quality Assurance Topical Report APPENDIX B Procedures Main body: contains the step-by-step instructions in the degree of detail necessary for performing the required function or task.

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

Check-off lists: complex procedures use check-off lists (aka checklists) which may be included as part of the procedure or appended to it.

Certain types of procedures governing generating site activities are common to all plants.

Individual plant terminology may vary from the following, and some procedure types may be combined. Sufficent procedures are maintained to provide appropriate direction for these activities. In amplification to the appropriate elements above, such procedures are further defined as follows:

System Procedures: contain instructions for energizing, filling, venting, draining, starting up, shutting down, changing modes of operation and other instructions appropriate for operations of systems related to the safety of the plant. Separate procedures may be developed for correcting off-normal conditions for those events where system complexity may lead to operator uncertainty. System procedures contain check-off lists where appropriate.

Start-up Procedures: contain instructions for starting the reactor from cold or hot conditions and establishing power operation. This includes documented determination that prerequisites have been met, including confirmation that necessary instrumentation is operable and properly set; necessary system procedures, tests and calibrations have been completed; and required approvals have been obtained. The main body includes the major steps of the start-up sequence, including reference to appropriate systems procedures. Start-up procedures contain check-off lists where appropriate.

Shutdown Procedures: contain instructions for operations during controlled shutdown and following reactor trips, and include instructions for establishing or maintaining hot standby or cold shutdown conditions, as applicable. The major steps involved in shutting down the plant are specified, including instructions for such actions as monitoring and controlling reactivity, load reduction, cooldown rates, activating or deactivating equipment, and provisions for decay heat removal. Check-off lists are used, as appropriate, for confirming completion of major steps in proper sequence.

Power Operation and Load Changing Procedures: contain instructions for steady-state power operation and load changing that include provisions for use of control rods, chemical shim, coolant flow channel control, or for any other system available for short- or long-term control of reactivity, making deliberate load changes and adjusting operating parameters.

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NSPM Quality Assurance Topical Report APPENDIX B Procedures Process Monitoring Procedures: contain instructions for monitoring performance of plant systems to assure that core thermal margins and coolant quality are maintained in acceptable status at all times, that integrity of fission product barriers is maintained, and that engineered safety features and emergency equipment are in a state of readiness to keep the plant in a safe condition if needed. Maximum and minimum limits for process parameters are appropriately identified.

Fuel Handling Procedures: contain instructions for core alterations, accountability of fuel and partial or complete refueling operations that include, for example, continuous monitoring of neutron flux throughout core loading, periodic data recording, audible annunciation of abnormal flux increases, and evaluation of core neutron multiplication to verify safety of loading increments. Procedures are also provided for receipt and inspection of new fuel, and for fuel movements in the spent fuel storage areas. Fuel handling procedures include prerequisites to verify the status of systems required for fuel handling and movement; inspection of replacement fuel and control rods; designation of proper tools, proper conditions for spent fuel movement, proper conditions for fuel cask loading and movement; and status of interlocks, reactor trip circuits and mode switches. These procedures provide requirements for refueling, including proper sequence, orientation and seating of fuel and components, rules for minimum operable instrumentation, actions for response to fuel damage, verification of shutdown margin, communications between the control room and the fuel handling station, independent verification of fuel and component locations, criteria for stopping fuel movements, and documentation of final fuel and component serial numbers and locations.

Maintenance Procedures: contain instructions in sufficient detail to permit maintenance work to be performed correctly and safely, and include provisions for conducting and recording results of required inspections or tests. Appropriate referencing to other procedures or vendor manuals is provided. Instructions are also provided, although not necessarily in Maintenance Procedures, for equipment removal and return to service, and appropriate radiation protection measures (such as protective clothing and radiation monitoring).

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

Calibration and Test Procedures: contain instructions for periodic calibration and testing of safety related instrumentation and control systems, and for periodic calibration of measuring and test equipment used in activities affecting the quality of these systems. These procedures provide for meeting surveillance requirements and for assuring measurement accuracy adequate to keep safety related parameters within operational and safety limits.

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NSPM Quality Assurance Topical Report APPENDIX B Procedures Chemistry-radiochemistry Control Procedures: contain instructions for chemical and radiochemical activities such as the nature and frequency of sampling and analyses; maintaining coolant quality within prescribed limits; limitations on concentrations of agents that could cause corrosive attack, foul heat transfer surfaces or become sources of radiation hazards due to activation; control, treatment and management of radioactive wastes and control of radioactive calibration sources, including shipping.

Emergency Procedures: contain instructions for response to potential emergencies so that a trained operator will know in advance the expected course of events that will identify an emergency and the immediate actions that should be taken in response. Format and content of emergency procedures are based on regulatory and Owners Group(s) guidance that identify potential emergency conditions and generally require such procedures to include a title, symptoms to aid in identification of the nature of the emergency, automatic actions to be expected from protective systems, immediate operator actions for operation of controls or confirmation of automatic actions, and subsequent operator actions to return the reactor to a normal condition or provide for a safe extended shutdown period under abnormal or emergency conditions.

Emergency Plan Implementing Procedures: contain instructions for activating the Emergency Response Organization and facilities, protective action levels, organizing emergency response actions, establishing necessary communications with local, state and federal agencies, and for periodically testing the procedures, communications and alarm systems to assure they function properly. Format and content of such procedures are such that requirements of each sites NRC approved Emergency Plan are met.

Test and Inspection Procedures: contain the objectives, acceptance criteria, prerequisites for performing the test or inspection, limiting conditions, and appropriate instructions for performing the test or inspection. These procedures also specify any special equipment or calibrations required to conduct the test or inspection and provide for appropriate documentation and evaluation by responsible authority to assure test or inspection requirements have been satisfied. Where necessary, hold or witness points are identified within the procedures and require appropriate approval for the work to continue beyond the designated point. These procedures provide for recording the date, identification of those performing the test or inspection, as-found condition, corrective actions performed (if any), and as-left condition, as appropriate for the subject test or inspection.

While not specifically a procedure type, Temporary Procedures may be used to direct operations during testing, refueling, maintenance and modifications; to provide guidance in unusual situations not within the scope of normal procedures; and to insure orderly and uniform operations for short periods when the plant, a system, or a component of a system is performing in a manner not covered by existing detailed procedures, or has been modified or affected in such manner that portions of existing procedures do not apply. Temporary Procedures include designation of the period of time during which they may be used.

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NSPM Quality Assurance Topical Report APPENDIX C Definitions NSPM uses the definitions of terms as provided in Section 4 of the Introduction of NQA-1 1994 in interpreting the requirements of NQA-1 and the other standards to which the QATR commits.

In addition, definitions are provided for the following terms not covered in NQA-1:

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

Emergency procedures: see Appendix B.

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

Independent Assessment: planned and documented activity performed to determine by investigation, examination, observation, or evaluation of objective evidence to identify anomalous behavior, overall performance gaps to industry standards, precursors for potential problems, and to verify satisfactory resolution of problems to achieve improvements.

Maintenance and modification procedures: written procedures defining the policies and practices by which structures, mechanical, electrical and instrumentation and control systems, and components thereof, are kept in a condition of good repair or efficiency so that they are capable of performing their intended functions.

Nuclear power plant: any plant using a nuclear reactor to produce electric power, process steam or space heating.

Off-normal condition procedures: written procedures which specify operator actions for restoring an operating variable to its normal controlled value when it departs from its range, or to restore normal operating conditions following a perturbation. (May be called Abnormal, Off-normal or other terms conveying the same intent.)

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

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

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

42 NSPM-1 QATR, Rev 8a

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

Review: a deliberately critical examination, including observation of plant operation, evaluation of assessment results, procedures, certain comtemplated actions, and after-the-fact investigations of abnormal conditions.

Supervision: direction of personnel activities or monitoring of plant functions by an individual responsible and accountable for the activities they direct or monitor.

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

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

43 NSPM-1 QATR, Rev 8a

NSPM Quality Assurance Topical Report APPENDIX D - REVISION SUMMARIES Change/ Basis for Meeting Revision/Section Reason for Change 10CFR50, Appendix B Revision 0, 03/31/2009, All NMC-1 deleted and replaced by Program is unchanged, NSPM-1, Rev 0 transition to NSPM from NMC.

Revision 0, 03/31/2009 Revised titles, changed Program is unchanged.

A.1 terminology and removed section on operating service agreements due to transition to NSPM/Xcel Energy Nuclear Department (from NMC).

Revision 0, 03/31/2009 Bullet item concerning use of NRC approval (dated 12/19/07, B.4 commercial grade calibration ML073440472) provided bases laboratories revised to include for accepting ACLASS ACLASS Accreditation Services calibration services as an as an alternative method. alternative method for qualifying suppliers.

Revision 0, 03/31/2009 Revised the audit frequency and Section 26.41 of the new rule C.3, Table 2 basis of the topic Fitness For renamed and amended the Duty to biennial (from annual) former section 26.80, thus due to new 10CFR26 rule changing the required audit change. frequency and section number.

[10CFR26.41(b)]

Revision 1, 09/16/2009 Added a statement to clarify Program is unchanged; added Policy Statement NSPM retaining ownership of clarification of NSPM ownership the nuclear facilities. of facilities.

Revision 1, 09/16/2009 Revised the note clarifying the Program is unchanged; added A.1 note purpose of NSPM (retain clarification regarding NSPM ownership of the nuclear power ownership of nuclear power plants/not actively plants.

decommissioning).

Revision 1, 09/16/2009 Corrected page numbers for Editorial only; program is B.14 Appendix B unchanged.

Revision 2, 03/25/2010 Revised the basis of the topic Section 73.56 of the revised rule C.3, Table 2 Access Authorization due to renumbered the former section 10CFR73 rule change. 73.56(g), thus changing the required section letter.

[10CFR73.56(n)]

Revision 3, 08/19/2010 Revised the bullet item for Approved per NRC A.7.3 Regulatory Guide 1.143 to Correspondence dated remove the broad commitment 7/9/2010.

from the QATR and utilize a reference to each site USAR as Quality Assurance Program for the basis for a commitment to Radioactive Waste Management Regulatory Guide 1.143 Systems, Structures and Revision 2, November 2001. Components will be in accordance with the QATR NSPM-1 in the absence of specific commitments in the Site USAR.

44 NSPM-1 QATR, Rev 8a

NSPM Quality Assurance Topical Report Change/ Basis for Meeting Revision/Section Reason for Change 10CFR50, Appendix B Revision 4, 12/29/2010 Updated title to Senior Director Program is unchanged, position A.2.1, A.2.2 Nuclear Oversight (from General title change only.

Manager Nuclear Oversight)

Revision 4, 12/29/2010 Revised the basis of the topic Section 73.55(m) of the revised C.3, Table 2 Site Security to state rule was renumbered, thus 10CFR73.55(m) due to the changing the required section revised 10CFR73 rule, effective letter.

3/31/2010.

Revision 5, 12/29/2011 Updated title to Senior Vice Program is unchanged, position A.1, A.2 President, Chief Nuclear Officer title change only.

(from Vice President, Chief Nuclear Officer).

Revision 5, 12/29/2011 Removed the word Site. Program is unchanged; removed A.2.2 wording for clarification of procedure used to provide detailed positions.

Revision 6, 8/16/2012 Added reporting relationship Program is unchanged; A.2.2.1 from Site Vice President to reporting relationship added.

Senior Vice President, Chief Nuclear Officer.

Revision 6, 8/16/2012 Removed the word "Specific". Program is unchanged; removed A.2.2 wording for clarification of functional responsibilities that may be delegated.

Revision 6, 8/16/2012 Added note and new appendix Program is unchanged, added A.5, B.12, B.14, Appendix E for referenced QATR QATR Interpretations references Interpretations. for additional clarification/information.

Revision 7, 12/20/2013 Added information from the Program is unchanged, added A.5, B.12, B.14, B.15 QATR interpretations. Added statements or wording from the note for referenced QATR associated QATR interpretation interpretations. for clarification.

Revision 7, 12/20/2013 Removed Appendix E. Program is unchanged, Appendix E Appendix removed as actual wording or statement from QATR interpretation was incorporated in place of the referenced QATR interpretation.

Revsion 8, Editorial corrections. Reduction Program changes submitted for in commitment to apply NQA-1 NRC approval.

audit requirements to newly described QA audit program, not to independent assessments as had been the case.

45 NSPM-1 QATR, Rev 8a

ENCLOSURE 2 Xcel Energy Northern States Power Company - Minnesota

SUMMARY

OF CHANGES TO QUALITY ASSURANCE TOPICAL REPORT October 31, 2014 11 pages follow

ENCLOSURE 2 Summary of Changes to Quality Assurance Topical Report Reason for Change/

Reduction in Current Revision Proposed Revision Basis for continuing to meet Commitment?

10CFR50, App B Policy Statement: Add the following after the No 10CFR50.54(a)(3)(vi)/

Second paragraph. No first sentence: Clarification regarding applicability of current text. Reference throughout this the QATR to non-nuclear NSPM document to NSPM refers to organizations. Control for delegation the nuclear organization(s) of activities to non-nuclear NSPM under the direction of the organizations is addressed in Section Senior Vice President/Chief A.2 and A.4. Does not affect Nuclear Officer. authority or freedom of persons performing quality assurance functions for nuclear activities.

Introduction, last sentence: and independent audits Yes Adds audits, retains assessments.

and independent and assessments Criterion 18 requires audits. NSPM assessments has been meeting this requirement with assessments, but will now perform both QA audits and independent assessments.

A.1 Methodology, ¶ 1, line 3: The following requirements No 10CFR50.54(a)(3)(vi)/

The following requirements apply to all organizations and Clarification regarding applicability of apply to all organizations and positions under the direction the QATR to non-nuclear NSPM positions that manage and of the Senior VP/CNO that organizations. Control for delegation manage and of activities to non-nuclear NSPM organizations is addressed in Section A.2 and A.4. Does not affect authority or freedom of persons performing quality assurance functions for nuclear activities.

Page 1 of 11

Reason for Change/

Reduction in Current Revision Proposed Revision Basis for continuing to meet Commitment?

10CFR50, App B A.1 Methodology, ¶ 1, line 7: Delete wording No 10CFR50.54(a)(3)(vi)/

, including Asset Owners, Since dissolution of NMC, there is only one asset owner (NSPM) involved in implementing the QATR.

This phrase should have been removed in earlier revisions. NRC was notified of the NMC change via letter dated 4/16/2008 and approved license transfer to Xcel Energy/

NSPM on 9/15/2008 via ML082240725 for Monticello and ML082240761 for Prairie Island A.2 Organization, ¶ 3, line 4: The organization executing Yes Adds audits, retains assessments.

The organization executing independent audit and Criterion 18 requires audits. NSPM independent assessment assessment activities has been meeting this requirement activities maintains maintains independence from with assessments, but will now independence from the the organization(s) perform both QA audits and organization(s) performing the performing the activity being independent assessments.

activity being assessed. audited or assessed.

Management positions are Management positions are established both offsite and established both offsite and onsite for carrying out the onsite for carrying out the independent assessment independent audit and functions. assessment functions.

A.2 Organization, ¶ 3, bullet and personnel as needed Yes Adds audits, retains assessments.

1: to perform audits and Criterion 18 requires audits. NSPM and personnel as needed assessments. has been meeting this requirement to perform assessments. with assessments, but will now perform both QA audits and independent assessments.

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Reason for Change/

Reduction in Current Revision Proposed Revision Basis for continuing to meet Commitment?

10CFR50, App B A.2 Organization, ¶ 4, line 2: Delete wording No 10CFR50.54(a)(3)(vi)/

, including Asset Owners, Since dissolution of NMC, there is only one asset owner (NSPM) involved in implementing the QATR.

This phrase should have been removed in earlier revisions. NRC was notified of the NMC change via letter dated 4/16/2008 and approved license transfer to Xcel Energy/

NSPM on 9/15/2008 via ML082240725 for Monticello and ML082240761 for Prairie Island A.2.1.1, last sentence The Sr. VP/CNO is No Administrative change 10 CFR The SVP/CNO is designated designated 50.54(a)(3)(iii)/

as Title change A.2.1.1.a.1: Vice President, Nuclear No 10CFR50.54(a)(3)(iii)/

Senior Director, Nuclear Oversight Title change.

Oversight A.2.1.1.a.1, lines 2 and 3: establishing the Yes Adds audits, retains assessments.

establishing the requirements for auditor, Criterion 18 requires audits. NSPM requirements for assessor assessor and inspector has been meeting this requirement and inspector certification; certification; managing the with assessments, but will now managing the overall overall independent audit and perform both QA audits and independent assessment assessment processes; independent assessments.

process; A.2.2.1.b Site Nuclear This position reports to the No 10CFR50.54(a)(3)(iii)/

Oversight Manager, line 1: Vice President, Nuclear Title change.

This position reports to the Oversight Senior Director, Nuclear Oversight Page 3 of 11

Reason for Change/

Reduction in Current Revision Proposed Revision Basis for continuing to meet Commitment?

10CFR50, App B A.3 Responsibility, ¶ 2: Senior management is Yes Adds audits, retains assessments.

Senior management is regularly apprised of audit Criterion 18 requires audits. NSPM regularly apprised of and assessment results has been meeting this requirement assessment results evaluating the adequacy of with assessments, but will now evaluating the adequacy of implementation of the QAP perform both QA audits and implementation of the QAP through the functions independent assessments.

through the assessment described in section C.

functions described in section C.

A.3 Responsibility, ¶ 4: As described in C.3 and C.4, Yes Adds section on audits, retains As described in C.3, Nuclear Nuclear Oversight is assessments. Criterion 18 requires Oversight is responsible responsible audits. NSPM has been meeting this requirement with assessments, but will now perform both QA audits and independent assessments.

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Reason for Change/

Reduction in Current Revision Proposed Revision Basis for continuing to meet Commitment?

10CFR50, App B A.5 Personnel Training and shall demonstrate his/her Yes (Deletes last sentence) Limits Qualification, ¶ 2, 4th bullet: ability to properly implement application of the exception to shall demonstrate his/her the independent audit persons leading audits. Paragraph 1 ability to properly implement process, as implemented by of this QATR section requires that the independent assessment NSPM according to section NSPM establishes and maintains (audit) process, as C.3 of this QATR, to formal indoctrination and training implemented by NSPM effectively lead an audit team, programs for personnel performing, according to section C.3 of and to effectively organize verifying or managing activities within this QATR, to effectively lead and report results, including the scope of the QAP to assure that an assessment team, and to participation in at least one suitable proficiency is achieved and effectively organize and audit within the year maintained. This requirement will report results, including preceding the date of still apply to persons performing participation in at least one qualification. independent assessments, but independent assessment or neither NQA-1, 2S-3, nor the audit within the year exception will directly apply.

preceding the date of Criterion 2 requires that persons be qualification. Also, replace trained and qualified consistent with the term audit throughout the functions they perform under the with the term independent QA Program. Both auditors and assessment. assessors will continue to be properly trained and qualified.

A.7.3, pg 14, 2nd bullet, 4th Sites not committed to RG No Administrative change (10 CFR line: Other sites may 1.26 may use 50.54(a)(3)/ Clarifies meaning of use other A.7.3, pg 14, 3rd bullet, independent audit Yes Adds audits, retains assessments.

penultimate line: frequencies Criterion 18 requires audits. NSPM independent assessment has been meeting this requirement frequencies with assessments, but will now perform both QA audits and independent assessments.

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Reason for Change/

Reduction in Current Revision Proposed Revision Basis for continuing to meet Commitment?

10CFR50, App B A.7.3, pg 15, 1st bullet, 6th Sites not committed to RG No Administrative change line: Other sites may use 1.29 may use (10CFR50.54(a)(3)/

Clarifies meaning of other A.7.3, pg 15, 3rd bullet, 12th audit topics and Yes Changes to address audits. Criterion line: frequencies as described in 18 requires audits. NSPM has been assessment topics and section C of this QATR, meeting this requirement with frequencies as described in assessments, but will now perform section C.3 of this QATR, both QA audits and independent assessments.

B.3 Design Verification, 3rd are independently Yes Shifts verification to audit program.

para, last sentence: are audited, as provided in Criterion 18 requires audits. NSPM independently assessed, as Section C of this QATR, to has been meeting this requirement provided in Section C of this guard against abuse. with assessments, but will now QATR, to guard against perform QA audits.

abuse.

B.14 Document Control, ¶ 2, ,or independent audits or Yes Recognizes audits as possible input lines 9-10: assessments to procedure revisions, in addition to

,or independent the other inputs listed. Criterion 18 assessments requires audits. NSPM has been meeting this requirement with assessments, but will now perform both QA audits and independent assessments.

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Reason for Change/

Reduction in Current Revision Proposed Revision Basis for continuing to meet Commitment?

10CFR50, App B C.1 Methodology, programs for reviews, Yes Text previously located at end of old

¶ 1, first sentence, audits and assessments C.3 was moved unchanged except for programs for reviews and addition of audit. C.1 is a better assessments New last sentence: Nuclear location for this text. Criterion 18

¶ 1, last sentence, add text as Oversight provides for requires audits. NSPM has been proposed independent audit and meeting this requirement with assessment of work carried assessments, but will now perform out under the requirements of both QA audits and independent the QAP that is delegated to assessments.

other (non-NSPM) entities.

C.1 Methodology and independent audit/ Yes Adds audits, retains assessments.

¶ 2, lines 2, 5, and 7: assessment Criterion 18 requires audits. NSPM and independent carrying out audits and has been meeting this requirement assessment assessments with assessments, but will now carrying out these and independent audits/ perform both QA audits and assessments assessments independent assessments.

and independent assessments C.1 Methodology Appendix A establishes the No Administrative change 10 CFR

¶ 3, last sentence: minimum requirements for 50.54(a)(3)/

Appendix A establishes the these committees. Clarifies these are minimum requirements for these requirements committees C.1 Methodology Text regarding commitment to Yes Commitment to NQA-1 is retained for

¶ 5, deleted from this section NQA-1, BR 18 and 18S-1 is the audit program. Criterion 18 moved to revised section C.3 requires audits. NSPM has been and the previous clarification meeting this requirement with to substitute independent assessments, but will now perform assessment(s) for the term both QA audits and independent audit is deleted. assessments.

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Reason for Change/

Reduction in Current Revision Proposed Revision Basis for continuing to meet Commitment?

10CFR50, App B (not in current revision) New section describing the Yes Requirements for the audit program C.3 Independent Audits NSPM quality assurance are explicitly established and (refers to Table 1) audit program, its focus on commitment to NQA-1 is retained for No current section on audits confirming that activities the audit program. Criterion 18 separate from assessments. affecting quality comply with requires audits. NSPM has been the QA Program, and meeting this requirement with providing auditor assessments, but will now perform independence requirements, both QA audits and independent audit process requirements, assessments.

identification of required audits and frequencies, and establishing reporting and follow-up requirements.

Provides commitment to NQA-1-1994, BR 18 and 18S-1 for audits.

(was C.3) Previous C.3 becomes C.4. Yes Requirements for the independent C.4 Independent Changes relate to de- assessment program are explicitly Assessment coupling of independent established, consistent with de-(refers to new Table 2) assessments from audits. coupling from audits. Criterion 18 Assessments focus on requires audits, now addressed in monitoring overall new C.3. NSPM has been meeting performance, identifying this requirement with assessments, anomalous performance and but will now perform both QA audits precursors of potential and independent assessments.

problems and verifying Independent assessment will not satisfactory resolution of implement Criterion 18.

problems.

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Reason for Change/

Reduction in Current Revision Proposed Revision Basis for continuing to meet Commitment?

10CFR50, App B Table 1 (was Table 2) New Table 1: Yes No changes to commitments for Clarifies that Fire Protection evaluation of these areas except that audit frequency basis is NRC audits will be used. New table approval of original QATR, continues to specify audit frequency and that fire protection basis. Criterion 18 requires audits.

specialist external to the NSPM has been meeting this company is required for this requirement with assessments, but audit. will now perform both QA audits and Adds audits of REMP, Station independent assessments.

Blackout, ISFSI activities, and Shipping of >Type A Radioactive Waste that were previously only discussed in section A.7 (via commitment to certain documents).

Clarifies nominal as applied to selected audit frequencies.

Page 9 of 11

Reason for Change/

Reduction in Current Revision Proposed Revision Basis for continuing to meet Commitment?

10CFR50, App B Table 2 (was Table 1) New Table 2: Yes No changes to commitment for Deletes Independent Spent evaluation of ISFSI except that audits Fuel Storage (included in new will be used as provided in 10CFR72, Table 1). Subpart G.

At minimum, the functional areas Identifies functional areas identified remain subject to subject to independent independent assessment per new assessment and performance C.4.

monitoring as described in C.4. Removed other detail that used to be in Table 1 to not specify activities within a functional area or imply that assessment would be limited to certain activities.

Appendix C Appendix C Yes Definition adjusted to more accurately Independent Assessment: Independent Assessment: portray independent assessment as it planned and documented planned and documented will now be used in coordination with activity performed to activity performed to the audit program. Criterion 18 determine by investigation, determine by investigation, requires audits. NSPM has been examination, observation, or examination or evaluation of meeting this requirement with evaluation of objective objective evidence to identify assessments, but will now perform evidence the adequacy of and anomalous behavior, overall both QA audits and independent compliance with established performance gaps to industry assessments.

procedures, instructions, standards, precursors for drawings, and other potential problems, and to applicable documents, and to verify satisfactory resolution determine the effectiveness of of problems to achieve implementation. improvements.

Page 10 of 11

Reason for Change/

Reduction in Current Revision Proposed Revision Basis for continuing to meet Commitment?

10CFR50, App B Appendix C Sentence deleted. Yes Commitment to NQA-1 is retained for Independent Assessment: the audit program. Criterion 18 Independent Assessment, requires audits. NSPM has been as used in this QATR, is meeting this requirement with considered equivalent to the assessments, but will now perform term audit. both QA audits and independent assessments.

Page 11 of 11

ENCLOSURE 3 Xcel Energy Northern States Power Company - Minnesota REDUCTION IN COMMITMENT REGARDING THE SCOPE OF THE QUALITY ASSURANCE PROGRAM AUDITS October 31, 2014 2 pages follow

ENCLOSURE 3 Reduction in Commitment Regarding the Scope of the Quality Assurance Program Audits Introduction The QATR for NSPM currently does not distinguish between audits and assessments in terms of their overall scope. The QATR submitted herewith does distinguish between audits and assessments in that audits will address regulatory and QA program compliance while assessments will address overall plant performance. The commitment to NQA-1-1994 BR 18 and Supplement S18-1 is retained for the audits only, and not the assessments. NSPM considers the retention of BR 18 and Supplement S18-1 for the audits only to be a reduction in commitment requiring NRC approval in accordance with 10 CFR 50.54(a)(4).

Background

In October 2003, Nuclear Management Company (NMC) submitted its QATR for NRC review and approval (Agencywide Document Access and Management System (ADAMS) Accession No. ML033070156), consolidating the QA Programs of the six plants it operated - Duane Arnold Energy Center, Kewaunee Nuclear Power Plant, Monticello Nuclear Generating Plant, Palisades Nuclear Plant, Point Beach Nuclear Plant, and Prairie Island Nuclear Generating Plant. This common QATR was structured to address the QA program elements as presented in NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition, Chapter 17.3, Quality Assurance Program Description, Revision 0. The NRC approved the QATR via letters dated January 13 (ADAMS Accession No. ML050210276) and March 24, 2005 (ADAMS Accession No. ML050700416). The QATR established the independent assessment process and controls, including commitments to implement the requirements of NQA-1-1994 regarding audits using the independent assessment approach. Subsequently, in 2008, NMC transferred operating authority of Monticello and Prairie Island to NSPM and the QATR was retained as the NSPM QA program description without changes to the assessment provisions.

Proposed Change The proposed revision to the QATR changes the existing Section C to add a new sub-section regarding a QA audit program and changes existing sub-section C.3 to coordinate with new the audit section. The commitment to NQA-1-1994 is moved from the existing sub-section C.1 to the new audit section such that the commitment to BR 18 and Supplement 18S-1 is retained for the audit program and not applied to the Independent Assessments, which are described in new sub-section C.4. Additional minor changes are made in other sections throughout the QATR, such as A.7, to address the audit program changes.

Page 1 of 2

The purpose of this change is to develop a distinct audit function within NSPM NOS separate from the NOS independent assessment function. The scope of the audit function will include compliance with QA program requirements and regulations. The creation of an audit function within NOS will provide assurance of nuclear safety through the application of a high level of rigor, formality, validation and completeness to assure regulatory and QA program requirements are met and implemented properly.

Basis for Continuing to Satisfy 10 CFR 50, Appendix B 10 CFR 50, Appendix B, Criterion XVIII, Audits, requires that licensees carry out a comprehensive system of planned and periodic audits to verify compliance with all aspects of the QA program and to determine the effectiveness of the program. NSPM has been satisfying this requirement, as described in the current QATR, via an independent assessment program. The QATR establishes specific methodology and controls for that program, including commitment to comply with NQA-1-1994, BR 18 and Supplement 18S-1 requirements. The NRC concluded in its Safety Evaluation Report of March 24, 2005 (ADAMS Accession No. ML050700416) that the proposed QATR continues to meet the requirements of 10 CFR 50, Appendix B and is, therefore, acceptable.

The proposed revised QATR continues to satisfy 10 CFR 50, Appendix B, Criterion XVIII in that it describes a comprehensive system of planned and periodic audits to confirm that the activities affecting quality comply with the QA program and that the program is effectively implemented. The QATR commits that the audit program will be implemented in compliance with the requirements of NQA-1-1994, particularly BR 18 and Supplement 18S-1, which is the current commitment for the independent assessment program. There are no specific requirements related to independent assessment contained within 10 CFR 50 Appendix B, although the proposed revised QATR retains that function and establishes controls for that program.

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