ML20024C297

Forwards Updated FSAR Section 1.7,describing Quality Program for Operational Phase,Per 10CFR50.54(a)(2).Info Will Be Incorporated Into Next Updated FSAR Annual Rev.Justification Encl

ML20024C297
Person / Time
Site:	Crystal River
Issue date:	06/10/1983
From:	Westafer G FLORIDA POWER CORP.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
3F-0683-01, 3F-683-1, NUDOCS 8307120495
Download: ML20024C297 (78)

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.P..o. .w. .e. . .r June 10,1983 3F-0683-01 Mr. James P. O'Reilly Regional Administrator, Region 11 Office of Inspection & Enforcement U.S. Nuclear Regulatory Commission 101 Marietta Street N.W., Suite 2900 Atlanta, GA 30303

Subject:

Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 Submittal of Quality Programs Description

Dear Mr. O'Reilly:

Florida Power Corporation (FPC) hereby submits, as Attachment A, the current descrip-tion of its Quality Program for the operational phase of Crystal River Unit 3. This submittal is made in accordance with the requirements of 10 CFP,50.54(a)(2).

FPC considers the Quality Program for the operational phase, previously accepted by the NRC, to be that prcgram described in Sections 1.7.6.7 and 1.7.7 of the Crystal River Unit 3 FSAR through Amendment 53, dated June 30, 1979. Changes made to that accepted Quality Program, since it was submitted to the NRC, are identified in Attachment A by a vertical line in the right hand margin. Attachment B presents the reasons and bases for those changes in accordance with 10 CFR 50.54(a)(3)(ii).

Our 1982 FSAR revision, per 10 CFR 50.7l(e)(3){i), reorganized the FSAR such that the Quality Program for the operational phase (previously described in FSAR Sections 1.7.6.7 and 1.7.7) is now described in Section 1.7. Attachment A replaces Section 1.7 of the current FSAR. The changes identified in Attachment A are annotated to correspond with justifications listed in Attachment B. An unannotated copy of Attachment A, subject to changes in accordance with 10CFR50.54(a), will be provided with ocr next annual revision of the FSAR.

FPC management and the Nuclear General Review Committee have reviewed the current description of the Quality Program and the bases for change included in that program. We conclude that the current Quality Program continues to satisfy the criteria of 10 CFR 50, Appendix B and the program description commitments previously accepted by the NRC.

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0 Mr. J. P. O'Reilly 3F-0683-01 Page 2 Please contact us if you desire any additional information regarding our Quality Program description changes.

Sincerely, o V G. R. Westafer Manager Nuclear Licensing & Fuel Management Attachment j

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F-e3 Attachment A l.7 ~ Ovality Procram (Operationol) l 1.7.1 Introduction l I

Florida Power Corporation (FPC) hos implemented a comprehensive Quality Program in order to maintain the high quality of plant systems and equipment during operation, maintenance, repair, modification, and refueling. Sections Table 1.7.1, l.7.2 (and Table 1-3),1.7.3 and 1.7.4 describe the FPC Quality Program during the operational phase. This program and its implementation are available for audit by NRC personnel. p I.7.1.1 Organization l FPC has established the functional responsibilities and authorities of 3 positions / organizations involved in the Quality Program. The qualifications of Audit the individuals responsible for directing and managing the Quality Program are described in FSAR Appendix 12A. In certain instances, duties and authority to execute and audit the quality activities are delegated to other organizations. In

all cases, FPC retains responsibility for the Quality Program for Crystal River Unit 3.

Verification of conformance to established quality requirements on safety- l i related structures, systems, and components is accomplished by those individuals 3

or groups who do not have direct responsibility for performing the work being verified. 4 Persons and organizations performing quality assurance functions have sufficient authority and organizational freedom to identify quality problems; initiate necessary oction to provide for resolution of nonconformances through l designated channels; verify implementation of solutions; and, control further processing, delivery, or. Installation of a nonconforming item until the proper disposition of the deficiency or the unsatisfactory condition has been opproved. 5 6

The following summarizes the functional responsibilities and authorities of positions / organizations involved in directing and managing the FPC Quality Program:

j l. President Ultimate responsibility for the overall effectiveness of FPC's Quality Program rests with its President. He has assigned the responsibility for the

, implementation of the program to the Executive Vice President.

l 2. Executive Vice President The Executive Vice President is responsible for the implementation of the l Quality Program. He has the authority and responsibility to resolve all l

problems related to the Quality Program when resolution cannot be obtcined at subordinate levels of management. He has delegated the l

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outhority for administering the program to the Vice President, Engineering Services.

3. Vice President, Engineering Services The Vice President, Engineering Services has the authority and responsibil-ity to administer the FPC Quality Program. He reviews and approves all program policies. This position provides on effective communications channel with all other FPC senior management.

4. Director, Quality Programs The Director, Quality Programs, reporting to the Vice President, Engineer-ing Services, has the responsibility to assure that the requirements of the Quality Program are implemented. He has the authority and organizational freedom to identify quality problems; to initiate, recommend or provide possible solutions; and to verify the implementation of solutions. He has the authority, which may be delegated to others, to hold up work that is nonconforming. The Director, Quality Programs, has the authority to take decisions regarding work that is nonconforming directly to other levels of FPC management. He is independent of groups or functions directly responsible for performing specific work octivities offecting quality.

5. Vice President, Nuclear Operations The Vice President, Nuclear Operations, reporting to the Executive Vice President is responsible for operations, engineering and quality control functions at Crystal River Unit 3. He concurs with Quality Program policies prior to their opproval.

6. Director, Fuel & Special Projects The Director, Fuel & Special Projects, is responsible for administering fuel fabrication contracts and for coordinating the fabrication and delivery schedules for reload fuel with FPC's fuel fabricator, Nuclear Operations, and Quality Programs Department, os applicable.

7. Nuclear General Review Committee The Nuclear General Review Committee, reporting to the Executive Vice l President, is responsible for performing the independent review of and maintaining a cognizance over the audit functions as required by Technical Specifications. The composition, functional responsibilities, and authority l

of the Nuclear General Review Committee are in occordonce with the i requirements of the Technical Specifications.

8. Plant Review Committee The Plant Review Committee provides advice to the Nuclear Plant i

Manager on matters related to nuclear safety. The composition, functional l

responsibilities, and authority of the Plant Review Cgmmittee are described in the Technical Specifications. ,

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l.7.1.2 Guality Program l This section (and the remainder of Section 1.7) describes the FPC Quality '7 Program for Crystal River Unit 3 during the operational phase. The operational phase began with the commencement of fuel loading and ends with plant decommissioning.

The Quality Program complies with the requirements of 10 CFR 50, Appendix B. 8 This program requires that all persons performing quality activities associated with the operation of Crystal ~ River Unit 3 comply with the program. FPC l

conducts or delegates the responsibility to conduct audits of the program activities.

FPC has on indoctrination and training program for the personnel performing quality activities to assure that they are knowledgeable of the Quality Program's procedures and requirements. The indoctrination and training program includes ,

appropriate procedures and personnel records. Personnel responsible for i performing quality activities are instructed as to the purpose, scope and

! implementation of the quality-related manua!s, instructions, and procedures.

Personnel performing quality activities are trained and qualified in the activity l9 being performed.

Quality activities such as inspection and test are done with appropriate 10 t

equipment and under suitable conditions. Housekeeping and cleanliness centrols Table

are implemented through procedures. These controls meet the requirements of

ANSI N!8.7, Section 5.2.10, ANSI N45.2.1 and ANSI N45.2.3 as each is defined in Table 1-3.

Quality control as defined in Section 1.7.4 is the responsibility of the department 11 i which performs the actual work; however, the quality control activities within a j department are performed by individuals other than those who perform the work.

These activities are performed in accordance with approved written procedures or instructions documented in the respective departmental procedures manual.

l These departmental procedures delineate the position (s)/ organization (s) responsible for quality control activities.

The FPC Quality Program applies to structures, systems and components as 12 defined in FSAR Section 1.6.4, equipment in the FPC "Sofety Listing" and may be applied to other equipment and activities ut FPC management discretion.

FPC regularly reviews the status and odequocy of its Quality Program through 13 periodic Corporate audits of the Quality Program at least once every two years.

In addition responsible management reviews audit reports and corrective actions of that part of the Quality Program that they are implementing.

Changes to the Quality Program which result in more stringent requirements will 14 be entered in appropriate implementing procedures within 90 days of the Quality Program change unless otherwise specified in the commitment / requirement to change the Quality Program or unless a longer period is evaluated and occepted

, by the Director, Quality Programs. All othcr Quality Program changes will be

reflected in appropriate implementing procedures at their next revision.

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r The FPC Quality Progrom meets the requirements of the Regulatory Guides and 15 ANSI Standards os defined in Section 1.7.2 (cnd Table 1-3). Table 1.7.l.3 Design Control l FPC's Nuclear Engineering Department provides for an independent review of l safety-related modifications which involve development of, or changes to, design dato or documentation. This review assures that the design activities associated 16 with modifications are in accordance with ANSI N45.2.1 I as defined in Table 1-3. Table Audit Maintenance or modifications which may offect safety-related structures, 17 systems, or components are performed in a manner that ensures quality requirements, material specifications, and inspection requirements are met.

Molntenance or modifications of safety-related equipment are planned and performed in accordance with written procedures, documented instructions, or drawings approprio+e to the circumstances which conform to applicable codes, standards, specifications, and criteria.

l.7.l.4 Procurement Document Control l Procurement documents are reviewed by qualified personnel, prior to purchase, 18 to assure that quality requiremenh have been specified. Individuals reviewing these procurement documents are not involved with the other phases of the procurement activity. These reviews are performed and documented in accordance with approved written procedures.

FPC's Quality Program contains provisions which require that: l

1. Procedures are established which clearly delineate the sequence of actions to be accomplished in the preparation, review, opproval and control of procurement docur-*'ts and which identify those positions or groups l responsible for perfor mng those functions.

2. Review of and concurrence with the procurement documents are performed l by qualified individuals knowledgeable of the Quality Prograrn to assure that the quality requirements are stated. This review is to determine that l 3

quality requirements con be inspected and controlled, that there is I odequate acceptance or rejection criterio, and that the procurement document has been prepared in accordance with FPC Quality Program procedure requirements.

j 3. Documented evidence of the review and approval of procurement docu-

ments is provided and available for verification. l

4. Procurement documents identify those 10 CFR 50 Appendix B requirements 19 that must be complied with by the supplier's quality program.

5. Procurement documents contain or reference, os applicable, basic tech-nical requirements such as regulatory requirements and design bases and l20 l

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i Identify the documentation to be prepared, maintained, submitted, and j20 made available to FPC for review and/or approval.

6.. Procurement documents contain the requirements for the retention, con-trol, and maintenance of records os oppropriate. l Procurement documents contain the right of access to vendor's facilities i 7.

and records for source inspection and audit by FPC.

8. Changes and/or revisions to a procurement document are subject to review l I

- and opproval requirements at least equivalent to those for the original il document. g 1.7.l.5 Instructions, Procedures and Drawings l 22 FPC's Quality Program contains requirements to assure that each of the 18 Audit criteria within 10 CFR 50, Appendix B are delineated, accomplished, and controlled in occordance with approved written procedures.

FPC's Quality Program contains provisions which require that instructions, l procedures, or drawings include appropriate quantitative (such as dimensions, tolerances, and operating limits) or qualitative (such as workmanship samples) acceptance criteria for determining that important quality octivities have been i

. satisfactorily accomplished.

Written procedures are adhered to in matters relating to nuclear safety. Written 23 procedures are present and followed step-by-step for complex or infrequently performed tasks. Such tasks are identified. In order to properly document that procedural steps are verified as required, a checkoff list system has been l- developed. Each step of the procedure requiring verification is included on the 24

! checkoff list.

L 1.7.1.6 Document Control l FPC has a document control system for documents which prescribe activities 25 Audit offecting quality.

FPC's Quality Program contains provisions which require that: l

1. Measures are established to review documents, such as instructions, procedures, and drawings (and changes thereto) prior to release to assure that the quality requirements are sufficiently, clearly, and occurately stated.

2. Changes to documents are reviewed and opproved by the same organiza-tions that performed the original review ond approval unless delegated by l

the oppropriate FPC organization to another qualified responsible i organization.

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3. The reviewing organization (s) has access to pertinent background infor-motion upon which to base its approval and has an adequate understanding of the requirements and intent of the original document.

! 4. Approved changes are promptly included with instructions, procedures, l drawings, and other oppropriate documents.

5. Obsolete or superseded documents are controlled to prevent their in- l odvertent use.

6. Documents are ovallable at the stort of the work for which they are needed.

l l 7. A method for identifying the current revision of instructions, procedures, 26 and drawings is established and implemented. This information is updated and distributed as necessary to predetermined responsible personnel.

As a minimum under this criterio, the controlled documents include: l

1. Design specificottons.

2. Design, manufacturing, construction, and installation drawings.

3. Quality Program manual and operating procedures. I

4. Manufacturer inspection and testing instructions. I

5. Procurement documents.

6. Maintenance, repair, and modification instructions, f

7. Test surveillance instructions.

8. Itefueling instructions. t_

9. In-service inspection instructions.

10. Other procedures per Regulatory Guide 1.33, as defined in Table 1-3 and 27 the Technical Specifications. Table 1.7.l.7 Control of Purchased Material, Equipment and Services l I

Vendor evaluation surveys to qualify potential suppliers in accordance with FPC 28 opproved written procedures and in compliance with ANSI NI8.7, Section S.2.13 Table and ANSI N45.2.13 as each is defined in Table 1-3, are conducted by FPC or Audit thrcugh qualified contractors. Suppliers' quality programs are reviewed and l

concurred with prior to implementation of activities.

FPC assures that quality requirements of the purchase document have been met, using source inspection, receipt inspection or document review, as oppropriate. l29 I-76

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l.7.l.8 Identification and Control of Materials, Ports and Components l FPC has established measures for the identification and control of materials, 30 parts, and components. Audit FPC's Quality Program contains provisions which require that: I

1. Procedures are established which describe identification and control of material, ports, and components, including partially fabricated assemblies. l31

. 2. Identification requirements are determined 63 ring the initial planning stages (i.e., during generation of specificatien and design drawings).

3. Identification is specified to the extent that the item identified con be I i traced to the ossociated documentation, such as drawings, specifications, purchase orders, manufoeturing and inspection documents, and physical or chemical mill test reports.

4. The degree of identification is specified on the design drawing or in referenced technical documents.

5. Measures are provided to assure that the location and method of identifico- l tion do not affect the function or quality of the item being identified.

6. Measures are provided for the verification of correct identification of materials, parts, and components prior to release for manufacturing, shipping, construction and installation.

l.7.1.9 Control of Special Processes l Porticipating organizations provide written procedures for performance of 32 special processes such as welding, heat treating, chemical cleaning, and non- Audit destructive testing and include the requirements for qualification of personnel performing the work.

FPC's Quality Program contains provisions which require that: I

1. Measures are established to assure adequate performance and control of special processes such as welding, heat treating, chemical cleanir.g and l non-destructive testing.

2. Measure are established to asst re that procedures, equipment and person-1 nel connected with special processes are qualified in accordance with the requirements of applicable code s, standards, and specifications.

3. Measures are established to ost ure that special processes are performed by qualified personnel in accordan:e with approved written procedures. These 33 procedures provide for rec arding evidence of verification and, if applicable, inspection and proc ess results.

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4. An octive file is maintained current on qualificatica records of all special l process procedures, equipment, and personnel performing special processes.

5. Special process procedures and the credentials of qualified personnel are I regularly reviewed to assure they are of the latest revision and that l l

personnel qualifications have not expired.

1.7.1.10 Inspections l Written procedures are required for the performance of in-process inspection. 34 Inspection personnel are qualified in compliance with the Crystal River Unit Audit No. 3 Technical Specifications, as applicable, or Regulatory Guides 1.8,1.58, and Table 1.146 as each Regulatory Guide is defined in Toble 1-3.

FPC's Ouclity Program contoins provisions which require that: l

l. Inspection personr.el are independent from the individual or group physically performing the activity being inspected.

2. Inspection procedures, instructions and/or checklists are provided which document the date performed, by whom and/or by what equipment, the l type of observation, the results, the data collected and its occeptobility.

3. Inspection procedures or instructions are available for use prior to per-forming the inspection operation.

4. Measures are provided for qualifying the inspectors and maintaining the current status of each inspector's qualifications.

5. Measures are established to assure that inspection equipment is within l calibration prior to performing on inspection operation.

6. Measures are provided for monitoring processing methods, equipment, and 35 personnel if inspection of processed material is impossible or disadvan-togeous, inspection and process monitoring are provided when control is inadequate without both.

7. Specific hold points are indicated in appropriate documents for mandatory witnessing or inspection beyond which work shall not proceed without the consent of FPC's designated representative.

l .7.1.1 i Test Control Required tests are performed in occordance with cpproved written procedures to assure compliance with design documents. Testing octivities are conducted during the operational phase to verify the compliance of components to design Audit requirements.

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l FPC's Quality Program contains provisions which require that:

l. A test progrom is established to assure that all testing required to demonstrate that the item will perform satisfactorily in service is identi-l fled, documented, and accomplished in accordance with approved written procedures.

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2. The test progrorn covers the required tests, including, where appropriate, ,

prototype qualification tests, proof tests prior to installation, preopero- -

tional tests, and operational tests. l36

3. Written test procedures are prepared which incorporate or reference the requirements and acceptance limits contained in applicable design and procurement documents.

4. The written test procedures include, as appropriate, instructions for test method and identification of test prerequisites such as:

a) calibrated instrumentation; b) odequate and oppropriate equipment; l

c) trained, qualified, licensed and/or certified personnel; l

d) preparation, condition, and completeness of item to be tested; and l

e) suitable and controlled environmental conditions.

Test results are documented and evoluoted to assure that test requirements [ 37 S. I have been satisfied.

Control of Measurement and Test Equipment l l.7.1.12 38 FPC has established and implemented oppropriate test and calibration Audit

procedures for test devices used to verify the acceptability of items within the Table Quality Progrom. Calibration records and controls are provided for measurement ond. test equipment in occordonce with the requirements of the Technical Specifications and ANSI Ni8.7, Section S.2.16, ANSI N45.2.4 and ANSI N45.2.8 as each ANSI Standard is defined in Tobie 1-3.

l FPC's Quality Program contains provisions which require that:

l. Procedures are established which describe the calibration technique, calibration frequency, maintenance and control of measuring and test instruments, tools, gauges, fixtures, reference standards, transfer

' standards, and non-destructive test equipment to be used in the measure-ment, inspection, and muniforing of safety-related components, systems, and structeres.

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Measurement and test equipment is uniquely identified and has traceability l 2.

to the calibration test dato.

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3. Measurement and test instruments are calibrated and maintained at specified intervals, based on the required occuracy, purpose, the degree of ,

usage, stability chorocteristics, and other conditions offecting the measurement.

Measurement and test equipment is calibrated on or before the designated 39 4.

due date or before use.

- S. When measurement and test equipment is found to be out of calibration, on i investigation is conducted and documented to determine the validity of previous inspections performed and the acceptability of those items previ-ously inspected.

6. Calibrating instruments have known valid relationships to o notionally recognized standard. If no national standard exists, the basis for calibro-tion is documented, g

7. Facilities used for calibrating sensitive or close tolerance measurement and test equipment provide on environment that is sufficiently controlled to allow the meosering device to be evaluated and calibrated to its required occurocy.

Handling, Storage and Shipping i l.7.1.13 FPC's Nuclear Materials Department is responsible for material handling, l storage, and shipping activities for plant spore ports and operating supplies in occordance. with approved written procedures. These procedures meet the 41 Audit requirements of ANSI N18.7, Section S.2.13.4 and ANSI N45.2.2 os they are Table defined in Table 1-3.

1.7.1.14 inspection, Tests and Operating Status FPC has approved written procedures to assure the proper marking of equipment l Audit i I denoting its status.

1 FPC's Quality Program contains provisions which require that:

1. Measures are established and documented to identify the inspection, test, and operation status of structures, systems, and components, which provide I

means for otsuring that required inspections and tests performed are known throughout manufacturing, installation, and operation.

2. Measures are established to control the use of Inspection and status indicators, including the authority for opplication and removoi of tags, markings, and labels.

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3. Measures to preclude bypassing of required inspections, tests, and other critical operations are provided through approved written procedures. l

4. The status of nonconforming, inoperative, or malfunctioning siructures, systems, or components is clearly identified to prevent inodvertent use. l l.7.1.15 Nonconforming Material, Ports, or Components I FPC has written requirements to be followed by persons performing quality r activities, including contractors, to identify, document, segregate, disposition Audit l and report to FPC, any nonconformance, deviation or other condition adversely l offecfing quality.

l FPC's Guolity Program contains provisions which require that: l

1. Measures md procedures are established to control the identification, I documentation, segregation, review, disposition, and notification of the offected organization of nonconformances. l

2. Documer.tntion is provided which clearly identifies the nonconforming i item, describes the nonconformance and disposition of the nonconfor-mance, inspection requirements, and includes signature approval of the I disposition.

3. Measures are established and documented defining the responsibility and I outhority for determining the disposition of nonconforming items and approving the disposition.

4. Nonconforming items are segregated from other acceptable items (where feasible) and uniquely identified as nonconforming until oroperly disposi-tioned for use.

5. Acceptability of " rework" or " repair" of materials, ports, components, systems, and structures are verified by reinspection and/or testing of the 42 Item in accordance with approved written procedures.

6. Nonconforming items which are dispositioned "use as is" or " repair" are formally controlled through approved procedures or design changes. l

7. Nonconformance reports are mode part of the quality assurance recards.

l l.7.1.16 Corrective Action l FPC hos opproved written procedures to be followed by persons performing Audit quality activities, including contractors, to assure that corrective action is taken to preclude the recurrence of nonconformeces, deviations or other discrepancies adversely offecting quality.

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l FPC's Quality Program contains provisions which require that:

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l. Conditions adverse to quality, such as failures, deficiencies, deviations, defective material and equipment, and nonconformances are promptly

• identified and corrected.

2. Evaluation of nonconformance and determination of the need for correc- l tive action are in accordance with opproved written procedures.

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3. Measures are established to determine the cause of the nonconformance and institute corrective action to preclude the recurrence of those significant conditions adverse to quality.

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4. Measures are established to follow up on corrective actions to assure i

proper implementation and close out of the corrective action dc::umentation.

5. Mecsures are established to document and report to appropriate levels of management significant conditions adverse to quality, cause of the conditions, and corrective oction taken.

Quality Assurance Records l 1.7.1.17 FPC has established and implemented a system for the collection, storage, and maintenance of quality assurance records os required by the design documents, Audit procurement documents, and Regulatory Guide 1.88 as defined in Table 1-3. Table

', Records transmitted to the quality files are done so in accordance with approved written procedures.

FPC's Quality Program contains provisions which require that: l I

l. Quality assurance records are of two categories, lifetime and nonpermanent. (Nonpermanent records are required to show evidence that on activity was performed in occordance with opplicable requirements but need not be retained for the life of the item. Lifetime records are required to be maintained for the life of the particular item while it is installed in the plant or stored for future use.)

2. Quality assurance records are those records that furnish documentory evidence of the quality of items and of activities offecting quality. (A document is considered a quality assurance record when the document has been completed.)

These records include the resuits of reviews, inspections, tests, audits, I monitoring of work performance and material analysis, the qualification of personnel, procedures, and equipment, training records, design drowings l44 and subsequent modifications, specification reports, procurement docu-ments, calibration procedures and reports, nonconformance and corrective 45 action reports, and other records required by Technical Specifications. The Table records are identifiable and retrievable per ANSI N45.2.9 as defined in -

Table 1-3.

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3. The inspection and test records contain the following:

a) Description of the types of operation, b)' Evidence of completing and/or verifying a manufacturing inspection or test operation.

4. Records are stomped, dated, initiated, signed, or otherwise authenticated l by authorized personnel.

5. Storage facilities are constructed, located, and secured to prevent destruc-tion and minimize deterioration or loss of records. FPC maintains quality 46 ossurance records either in a vault for single copy records or as dep!! cote records in remote locations.

l.7.1.18 Audits l 1

FPC and its contractors use opproved written procedures for planned audits of l FPC's quality activities.

These audits include provisions for obtaining resolution of all deviations from written procedures used to perform the activities being audited. Audit procedures also include provisions for the dissemination of audit results to proper monogement levels for resolution of nonconformances and evoluotion of the status of the Quality Program. The results of all oudits performed under this program are mode available to FPC for review and evaluation. FPC's Quality Programs Department will perform audits to ossess the effectiveness of the FPC Quality Program os contained in this documen'. The results of these audits are reported to FPC management. The Quality Programs Department maintains 47 records of audit results.

FPC's Quality Program contains provisions which require that: l A comprehensive system of planned and documented audits is used to l

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verify compliance with all aspects of the Quality Program.

2. Audits are performed in accordance with approved written procedures or l checklists and are conducted by appropriately trained personnel not having direct responsibilities in the areas being audited. ,

3. Audit results are documented and reviewed by management having respon-sibility in the area audited.

4. Deficient areas are reoudited when required based on the severity of 48 discrepancies, extent of corrective action required and significance to safety, performance, and reliability.

5. Audits include an objective evoluotion of quality-related proctices, pro-cedures, and instructions; the effectiveness of implementation; and the conformance with policy directives. ,

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6. Audits include the evoluotion of work areas, octivities, processes, items, and the review of documents and records.

7. The following types of audits are performed:

c) Internal oudits which provide a comprehensive independent l verification and evoluotion of quality procedures and octivities to assure that they are meaningful and are effectively complying with the Quality Progrom requirements, b) External audits of contractors, subcontractors, and vendors l I

performing activities under the Quality Program. These audits include verification and evoluotion of their quality progom, pro-cedures, and activities to assure that they are meaningful and are effectively complying with all aspects of the quality program and procurement requirements.

8. Audits are regularly scheduled consistent with Technical Specification l49 requirements.

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9. Audit personnel qualifications meet the requirements of Regulatory Guide Table 1.146, es defined in Table 1-3.

1.7.2 Proarom Commitment FPC is committed to comply with the requirements of those ANSI Standards and Table Regulatory Guides listed in Table 1-3 as defined in that Table, except for those alternative controls identified in the program description which fulfill flw requirements but which differ slightly in specific implementation. When Regulatory Guides or ANSI Standards are superceded by on opproved revision, that revision will not be implemented unless the docket is modified accordingly. 51 l

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! l.7.3 Guolity Assurance Staff 52 Persons performing quality assurance functions, as defined in 10 CFR S0 Appendix B, conduct reviews and audits of FPC departments, suppliers and contractors that perform safety-related functions in connection with the operation, refueling, testing, maintenance and modification of Crystal River Unit 3. These reviews and oudits are performed in occordance with approved written procedures and in compliance with approved minimum requirements for audit frequency. Persons performing quality assurance functions are authorized to identify quality problems and may recommend to FPC monogement that work be stopped under totally unocceptable conditions. Such persons have the l

i organizational freedom to effectively perform the quality assurance functions. 53 l

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l.7.4 Glossary of Terms Terms used in the FPC Quality Program are defined below or in those Reguiotory Guides and ANSI Standards committed to by FPC, as defined in Table 1-3.

1. Quality Activity The term " quality activity" is a general term used to describe activities within the total Quality Program. The 54

' purpose of using the term " quality activity" is to reserve Table the words " control" ond " assurance" for those specific functions of the Quality Program defined as " quality control" and " quality assurance".

2. Quality Control Quality control is the first level and the most detailed function of the Quality Program. Quality control octivities deal with the physical chorocferistics of materials, components, or systems. Quality control is a means of preplanned inspection, . testing, and documentation per opproved written procedures or standard practices. These procedures and practices assure conformance to specifications, drawings, codes, criterio, standards, FS AR, and Technical Specifications.

l I-85

Table 1-3 55 Florida Power Corporation Quality Program Commitments This table presents the Regulatory Guides and ANSI Standards endorsed by FPC as part of its Quality Program.

In each of the ANSI Standards, other documents (i.e. other Standards, codes, regulations, tables or appendices) required to be included as part of the Standard are either referenced or described in a special section of the Standard. The specific applicability or acceptability of these referenced Standards, codes, regulations, tables or appendices is either covered in other specific areas in the FPC Quality Program (OGAP) description, including this Table, or such documents are not considered as OQAP requirements, although they may be used as guidance.

When Sections of Standards are referenced within a clarification, it is understood that FPC shall comply with the referenced Sections as clarified.

Contents Regulatory Guide ANSI Standard Page 1.8 (2/79) ANSI /ANS-3.1 (78) l-87 1.30 (8/72) N45.2.4 (72) l-88 1.33 (2/78) N18.7 (76)/ANS-3.2 l-91 1.37 (3/73) N45.2.1 (73) 1-96 1.38 (5/77) N45.2.2 (72) l-98 l.39 (9/77) N45.2.3 (73) 1-103 1.54 (6/73) N101-4 (72) 1-105 l

1.58 (9/80) N45.2.6 (78) 1-106 l.64 (6/76) N45.2.ll (74) 1-108 1.74 (2/74) N45.2.10 (73) 1-111 1.88 (10/76) N45.2.9 (74) 1-113 l 1.94 (4/76) N45.2.5 (74) 1-11 6 l.Il6 (6/76) N45.2.8 (75) 1-il8 1.123 (7/77) N45.2.13 (76) 1-121 1.144 (9/80) N45.2.12 (77) 1-123 1.146 (8/80) N45.2.23 (78) 1-128 I-86

r NRC Regulatory Guide 1.8 " Personnel Selection and Training" (Proposed 55 Revision 2,2/79) - Endorses ANSI /ANS-3.1 - 1978 The Quality Program complies with those portions of Sections I,2,3.1,3.2, 3.2.1, 3.2.2, 3.2.3, 3.3, 4.1, 4.4.5, 4.7.2, 5.1, 5.3, 5.3.1, 5.3.2, 5.3.3, and 5.6 of ANSI /ANS 3.1 - 1978 that are opplicable to the Quality Assurance organization (both on-site end off-site) with the following clarifications:

A !) Unless specifically cddressed in other Sections of the FSAR, the Technical Specificottons of Crystal River Unit 3, or other commit-ments mode by or for FPC monogement, this Guide / Standard is not opplicable to other personnel in the FPC organization.

A 2) With regard to Section 2 of ANSI /ANS 3.1 - 1978 titled Definitions:

Definitions in this Standard which are not included in ANSI N45.2.10 shall be used; all definitions which are included in ANSI N45.2.10 shall be used as clarified in FPC's commitment to Regulatory Guide 1.74.

E 3) With regard to Section 4.4.5 of ANSI /ANS 3.1 - 1978 titled Quality Assurance: FPC's commitment to this Section is mode with the caveat that EITHER the Director, Quality Programs OR the onsite QA supervisor may meet the specified experience requirements.

A 4) With regard to Section 5.6 of ANSI /ANS 3.1 - 1978 titled Documento-tion: FPC shall maintain records in accordance with and to meet the requirements of Section 1.7.1.2 of the OOAP and ANSI N45.2.9 cs specified in Table 1-3.

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. l 55 NRC Regulatory Guide 1.30 " Quality Assurance Requirements for the Installation, inspection and Testing of instrumentation and Electric Equip-ment"(3/72) - Endorses ANSI N45.2.4 - 1972.

The Quality Program (OOAP) complies with the requirements of this Guide with the following clarifications:

G,N-7 l} For operational phase maintenance and modification activities which are comparable in nature and extent to similo' octivities conducted during the construction phase, FPC shall either control these activ-ities under this OQAP or under on NRC occepted Construction QA Program. When this OGAP is used, FPC shall comply with the requirements of the Reculatory Position documented in this Guide in that GA programmatic /odministrative requirements included therein (subject to the clarifications below) shall apply to these maintenance and modification activities even though such requirements may not have been in effect originally. Technical requirements associated with the maintenance and modifications shall be the original require-ments or better (e.g., code requirements, material properties, design margins, manufacturing processes, and inspection requirements).

The Scope of this Standard (Section 1.1) and the method of identifying calibration status (third sentence in Section 2.5.2) are defined in items 2 and 3 below based on two classes of instruments.

B,S-3 2) Portable items of measuring and test equipment (M&TE) and refer-ence standards shall be togged or labeled indicating the date of calibration and/or the due date of recolibration as well as the identity of person performing c.olibration. These items are in o calibration program which requires recolibration on a specified l frequency or, in certain cases, prior to use.

B,S-3 3) Instrumentation and electrical equipment in the categories of (I) instruments installed as listed in the Technical Specifications,

! (2) installed instrumentation used to verify Technical Specification-parameters, and (3) installed safety-related instruments and electrical equipment that provide on octive function during operation or shutdown; (i.e. vice being designated safety-related solely because the instrument is an integral part of a pressure retaining boundary) shall be in a calibratinn program. This program provides, by the use of status cords, computer schedules, or tags, for the date that i recolibration is due and indicates the status of calibration. The identity of person (s) performing calibration is provided on the cali-bration documents.

A 4) With regard to Section 1.4 of ANSI N45.2.4 - 1971 titled Definition:

Definitions in this Standard which are not included in ANSI N45.2.10 i shall be used; all definitions which are included in ANSI N45.2.10 shall be used as clorified in FPC's commitment to Regulatory Guide 1.74. -

D 5) With regcrd to Section 2.1 of ANSI N45.2.4 - 1971 titled Plannino:

' Planning requirements, when necessary, shall be incorporated into maintenance ar:d modification procedures.

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. NRC Regulatory Guide 1.30 (Continued)

A 6) With regard to Section 2.3 of ANSI N45.2.4 - 1971 titled Procedures f 55 and Instructions: Procedures and instructior.s shall be implemented as set forth in Sections 1.7.l.5,10 and lI of ine OOAP and by compliance with the Crystal River Unit 3 Technical Specifications and ANSI N18.7 as set forth in Table 1-3 to that Program in lieu of the requirements set forth here.

A 7) With regard to Section 2.4 of ANSI N45.2.4 - 1971 titled Results:

These requirements are met by implementing Sections 1.7.1.10, il and 17 of the OOAP and by compliance with ANSI N18.7 as set forth in Table 1-3 of that Program in lieu of the requirements set forth here.

A,B,D,F 8) With regard to Section 3 of ANSI N45.2.4 - 1971 titled Preconstruc-tion Verification: These requirements shall be implemented as follows: (1) They are required only for major modifications. (2)

They shall be implemented with the clarification that " approved instruction manuals" shall be interpreted to mean the manuals provided by the supplier as required by the procurement order - these manuals are not necessarily reviewed and approved, per se, by FPC.*

(3) No special checks are required to be made by the person withdrawing a replacement part from the warehouse -equivalent controls are assured by compliance with ANSI N45.2.2 as set forth in Table 1-3 of the OOAP. (4) They shall be complied with as stated, by individua! technicians as part of the maintenance / modification process.

• See FPC's commitment to ANSI NI8.7 in this Table for a description of how vendor manuals may be included in procedures.

C,D 9) With regard to Section 4 of ANSI N45.2.4 - 1971 titled Installation:

These requirements shall be implemented by inclusion, as necessary in the appropriate maintenance or modification procedure, where such procedures are used. Standard FPC maintenance pract.ces require that care be exercised in the six areas listed whether a procedure is required or not.

A,S-3 10) With regard to Section 5.1 of ANSI N45.2.4 - 1971 titled Inspections:

The requirements of Section 5.1, including Subsections 5.1.1, 5.1.2 and the first sentence of 5.1.3, shall be implemented as set forth in Section I.7.1.10 of the OQAP. The inspection program shall incor-i porate, as applicable, those items listed in these Subsections. The remaining sentence in 5.l.3 is covered in equivalent detail in FPC's commitment to ANSI N18.7, Section 5.2.6: The requirements as set

, forth in that commitment shall be implemented in lieu of the requirements stated here.

A,C,S-3 ll} With regard to Section 5.2 of ANSI N45.2.4 - 1971 titled Tests: The requirements of Section 5.2, including Subsections 5.2.1 through 5.2.3, shall be implemented as set forth in Sections 1.7.l.3 and Il of the OOAP. The test program sha!! consider the elements outlined in this Section, where applicable, when developing test requirements for inclusion in maintenance and modification procedures. In some cases, testing requirements may be met by post-installation surveillance

] testing in lieu of a special post-installation test.

I-89

l NRC Reaulatory Guide 1.30 (Continued) ~

53 A,H,S-3 12) With regard to Section 6 of ANSI N45.2h - 1971 titled Post-Construction Verification: This activity is not generally considered .

opplicable at operating facilities because of the scope of the work and the relat!vely short interval between installation and operation.

Where consideied applicable, the elements described in this Section shall be considered in the development and implementation of inspe.c-tion and testing progrcms as deshribed in Sections 1.7.1.3,10 and 11 of the OQAP.

F 13) With regard to Section 6.2.1 of ANSI N45.2.4 - 1972 titled Equipment Tests: The lost p'crograph of this Section deals with taggin.g and T55eTing. FPC shall comply with on alternotp last porograph 'which reads: "Eoch safety-related item of proce'ss instrumentctiun is identified with a ' unique number. This number; is utilized in instrument maintenance records so that current calibration sterus, including dato such.cs the dcte of calibration and identity of person that perforrred ,the c'alibration, con be readily determined. J5uch inforrnation rnay, tisp belcontained on togs or labels which may.be ottoched' to, installed Iristrumentation." , ' s F 14) With regard to Section 7 of ANSI N45.2.4 - 1971 titled Data Analysis and Evoluotion: These requirements shall be. implernented cs stated herein of ter adding jhe clarifying phror,e r "Where sed" at ' the beginning of the porcgraph.

A 15) With regard to Section 8 of the ANSI N45.2.4- 1972 -titled Records:

FPC shall maintain records in accordance with and to meet the i requirements of Section I.7.l;17 of the >OQAP and ANSI N45 2.9 as ,

specified in Table 1-3.) s t ,

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'. NRC Reaulatory Guide 1.33 " Quality Assurance Requirements (Opero- 55 tion)" (Rev. 2, 2/78) - Endorses ANSI N18.7 - 1976/ANS - 3.2 The Quality Program (OQAP) complies with the requirements of this Guide with the following clarifications: ,

A l} Porograph C.3 of Regulatory Guide 1.33 (and Section 4.3.4 of ANSI N18.7 which it references) shall be implemented as required by the Crystal River Unit 3 Technical Specificottons which define " Subjects Requiring Independent Review."

A 2) Parograph C.4 and subsections a through e of Regulatory Guide 1.33 (and Section 4.5 of ANSI N18.7 which they reference) shall be implemented as required by the Crystal River Unit 3 Technical Specifications which define the " Audit Program" to be conducted.

The audit program is further defined and shall be implemented as required by the commitment to ANSI N45.2.12 as stated in Table 1-3 of the OQAP.

A,D 3) Porograph C.S.o of Regelatory Guide 1.33 (and the second paragraph of Section 4.4 of ANSI N18.7 which it references) shall be imple-mented by meeting the requirements of the Technical Specifications for the Plant Review Committee (PRC).

C 4) Paragraph C.S.d of Regulatory Guide 1.33 (and Section 5.2.7.1 of ANSI N18.7 which it references) shall be implemented by adding the clarifying phrase "Where opplicable" in front of the fourth sentence of the fifth parograph. The Regulatory Guide's changing of the two uses of the word "should" in this sentence to "shall" unnecessarily restricts FPC's options on repair or replacement ports, it is not always procticable to test ports prior to use. For modifications where these requirements are not considered procticable, o review in accordance with the provisions of 10 CFR 50.59 shall be conducted and documented.

A 5) Paragraph C.5.e of Regulatory Guide 1.33 (and Section 5.2.13.4 of ANSI N18.7 which it references) shall be implemented subject to the some clarificottons made for ANSI N45.2.2 elsewhere in Table 1-3 of the OOAP.

F 6) Paragraph C.S.f of Regulatory Guide 1.33 (and Section 5.2.19(2) of ANSI N18.7 which it references) shall be implemented with the substitution of the word "proctical" for the word "possible" in the lost sentance.

C,E 7) Paragraph C.S.g of Regulatory Guide 1.33 (and Section 5.2.19.1 of ANSI N18.7 which it references) shall be implemented with the oddition of the~ modifier "normally" offer each of the verbs (should) which the Regulatory Guide converts to "shall." It is FPC's intent to fully comply with the requirements of this porograph, and any conditioris which do not fully comply shall be documented and approved by management personnel. In these cases, the reason for i the exception shall also be documented. The documentation shall be I-91

NRC Reaulatory Guide 1.33 (Continued) c

'3 retained for the some period of time os the offected preoperational test.

A 8) With regard to Section 3.4.2 of ANSI N18.7 - 1976 titled Require-ments for the Onsite Operatino Oraanization: Training Standards referenced in this Section shall be implemented if such Standards are included in Toble 1-3 of the OOAP or in Technical Specifications or are otherwise part of the license of Crystal River Unit 3. FPC's method of documenting and otherwise meeting the remainder of the requirements of this Section are set forth in Section 1.7.1.2 of the OOAP, in the Technical Speellfcations, and in other commitments for Crystal River Unit 3.

A 9) With regard to Section 4.1 of ANSI NI8.7 - 1976 titled General: The FPC oudit program shall be implemented in accordance with and to meet the requirements of: ANSI N45.2.12 os endorsed in Table I-3; Sections 1.7.1.16 ond 18 of the OOAP; and the requirements of the Crystal River Unit 3 Technical Specifications.

A 10) With regard to Section 4.2 of ANSI N18.7 - 1976 titled Procram 1

Description:

Two aspects are addressed in this Section: audits and independent reviews. The independent review program is Impfe-mented as required by the Technical Specifications for Crystal River Unit 3. The FPC oudit program shall be described in occordonce with and to meet the requirements of ANSI N45.2.12 cs endorsed in Toble 1-3 of the OOAP, the requirements of the Crystal River Unit 3 Technical Specifications, and Sections I.7.1.16 and 18 of the OO AP.

A,0 11) With regard to Section 4.3 of ANSI N18.7 - 1976 titled independent Review Process: The requirements of this Section, including all of its subparts, shall be met by compliance with the Technical Specification ,

requirements for Crystal River Unit 3.

A 12) With regard to Section 4.5 of ANSI N18.7 - 1976 titled Audit Proarams The FPC oudit program shall be implemented in occordance with and to meet the requirements of: ANSI N45.2.12 os endorsed in Table 1-3; Sections 1.7.1.16,17 and 18 of the OOAP; and the requirements of the Cryst.cl River (Jnit 3 Technical Specifica-i tions.

I i D 13) With regard to Section 5.1 of ANSI N18.7 - 1976 titled Procram

Description:

The fourth sentence in this Section required a "summari l

document"; FPC's OOAP (Chapter 1.7 of the FSAR) is organized in l

occordonce with the 18 criteria of 10CFR50, Appendix B. FPC interprets this FSAR description to fulfill the requir4ments for o

" summary document."

A 14) With regard to Section S.2.2 of ANSI N18.7 - i976 titled Procedure

! Adherence: The requirements of the Technical Specifications shall be used in lieu of the general requirements in this Section to control temporary changes.

l i

l-92 l

NRC Reaulatory Guide 1.33 (Continued) 55 l A 15) With regard to Section 5.2.6 of ANSI N18.7 - 1976 titled Ecotoment Control FPC shall comply with the " independent veridication" requirements based on the definition of this phrase os given under our commitment to Regulatory Guide 1.74.

B The third sentence of the fourth paragraph requires independent verificotton "when oppropriate." Although other cases may exist, it will generally not be considered "oppropriate" to require independent verification when significant exposure to radiation would result (to comply with ALARA requirements).

F Since FPC sometimes uses descriptive nomes to designate equipment, the sixth paragraph, second sentence is replaced with: " Suitable means include identificotton number or other descriptions which are troceable to records of the status of Inspections and tests."

l The first sentence in the seventh paragraph shall be complied with offer clarifying " operating personnel" to mean trained employees assigned to or under the control of FPC management at Crystal River Unit 3.

C,F,G 16) With regard to Section 5.2.7 of ANSI N18.7 - 1976 titled Maintenance N-7 and Modificotton:

In the first sentence of the first paragraph, FPC does not Interpret the word "originol" to modify " inspection requirements." Thus this sentence requires that technical requirements shall be equal to or better than the originol, but the original level of inspection require-ments (i.e. equal to that during construction) shall only be performed i when maintanonce or modification activities are similar in nature and i extent to original construction activities. This makes this Section

consistent with Section 5.2.17 of the Standard.

8 Further with regard to Section 5.2.7 of ANSI N18.7 - 1976 titled l Maintenance and Modification:

Since some emergency situations could arise which might preclude preplanning of all activities, FPC'shall comply with the following alternate to the first sentence in the second paragraph: "Except in emergency or abnormal operating situations where immediate actions are required to protect the health and safety of the public, to protect equl> ment or personnel, or to prevent the deterioration of plant maintenance or concitions modificationtoofoequipment possibly unsafe shall beor unstable level, preplanned en d performed in accordonce with approved written procedures. Where approved written procedures would be required and are not used, the activities that were accomplished shall be documented ofter-the-fact and receive the some degree of review as if they had been preplanned."

- B,C 17) With regard to Section 5.2.7.1 of ANSI N18.7 - 1976 titled Mainte-l ncnce Prooroms: FPC shall comply with the requirements of the first sentence of the fifth paragraph, where practical. This clarificotton is l needed since it is not olways possible to promptly determine the 1-93

1 NRC Regulatory Guide 1.33 (Continued) 55

' cause of the malfunction. In all cases, FPC shall Initiate proceedings ,

1 to determine the cause, and shall make such determinations

j. promptly, where practical. ,

F 18) With regard to Section 5.2.8 of ANSI N18.7 - 1976 titled Surveillonce Testinc and Inspection Schedule: In lieu of a " master surveillance l

"A ,

' schedu e," the following requirement shall be complied with:  !

surveillance testing schedule (s) shall be established reflecting the status of all in-plant surveillonce tests and inspections."

i A 19) With regard to Section 5.2.9 of ANSI N18.7 - titled Plant Security and l

Visitor Control The requirements of the Crystal River Unit 3 Security Plan shall be implemented in lieu of these general require-  !

ments. i A 20) With regard to Section 5.2.10 of ANSt NI8.7 - 1976 titled House-keepino and Cleonliness Control: The requirements of this Section, l

beginning with the lost sentence of the first paragraph and continuing >

l through the end of the Section, shall be implemented as described in FPC's commitments to ANSI N45.2.3 and N45.2.1 as set forth in

! Table 1-3 of the OQAP.

1 F 21) With regard to Section 5.2.13.1 of ANSI N18.7 - 1976 titled Procure-l i ment Document Control: The words "the same" in the last sentence ore reploced with the words "on equivaler:t."

B,C 22) With regard to Section 5.2.17 of ANSI N18.7 - 1976 titled Inspection:

With respect to porograph four, not oil inspections may require l

generation of a separate inspection procedure. Inspection require-l' ments may be integrated into oppropriate procedures or other docu-ments with the procedure or document serving as the record.

However, records of inspections shall be identifiable and retrievable.

I H 23) With regard to Section 5.2.19 of ANSI N18.7 - 1976 titled Test  ;

Control Item (1) of this Section is not considered opplicable since the FPC OQAP does not cover preoperational testing. .

B,C,D 24) With regard to Section 5.3.5(4) of ANSI N18.7 - 1976 titled Supporting Molntenance Documents: FPC may choose to include material from vendor manuals in any of three ways. (l) The applicable section of the manual may be duplicated, referenced in and atteched to the procedure. (2) The procedure may simply state that the manual or a specific section is to be followed for performing a porticular function; the manual must then be used in conjunction with the procedure for performing the activity, (3) The pertinent material from the manuol, either as originally written or as modified by the author / reviewers of the procedure, may be written into and become o port of the procedure.

In options (1) and (3) obcve, the material meets the requirement to receive "the some level of review and opproval as operating procedures" since the material is reviewed as port of the procedure review process. In option (2), the requirements shall be deemed to I-94

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E NRC Regulatory Guide 1.33 (Continued)

, 55 have been fulfilled by requiring a copy of the pertinent manual (manual secticos) to be available to and considered by persons conducting the review of the procedure.

A 25) With regard to Section 5.3.9 of ANSI N18.7 - 1976 titled Emeroency Procedures: As directed by the NRC, FPC is developing a format for emergency procedures which is " symptom" based as opposed to

" event" based as stipulated in Section 5.3.9.l.

B,C 26) With regard to Section 5.3.9.2 of ANSI N18.7 - 1976 titled Events of Potential Emers: NRC review of the FSAR has identified all natural occurrences which affect Crystal River Unit 3. Therefore, FPC shall interpret item (ll) to mean the natural occurrences which have been evaluated in the FSAR for Crystol River Unit 3.

A 27) With regard to Section 5.3.9.3 of ANSI NI8.7 - 1976 titled Procedures for implementing Emeryncy Plan: FPC's NRC accepted Emergency Plan for Crystal River Unit 3 shall be implemented in lieu of the requirements in this Section.

i l l-95 l

l _ -. .__-. -- -

NRC Reaulatory Guide 1.37 " Quality Assurance Requirements for Clean- 55 ing of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants" (3/73)- Endorses ANSI N45.2.1 - 1973.

The Quality Progrom (OGAP) complies with the requirements of this Guide with the following clarifications:

B,C,E l Throughout this Standard, references are made to cleanness associated with initial installation. For operations activities, qualified maintenance i deportment personnel shall determine what items within a particular  ;

cleanness level are appropriate. As on example, the Reactor Internals are initially classified as Level B. Section 3.1.2 requires this cleanness level to have " metal cleon" surfaces and either a visual inspection or a dry white-i cloth wipe. After use in the Reactor Coolant System, FPC does not intend to clean components removed for maintenance or inspection until they have a bright " metal clean" surface, nor do we necessarily ccmmit to performance of a dry white-cloth wipe. The chemistry within the system is

' designed to obtain a tightly odhering metal oxide film (which reduces the luster of metal) and ALARA considerations may preclude o dry white-cloth wipe.

1 Components which have been removed from a system shall be considered as being the same cleanness level as the system from which they were i removed. Such components need not be recleaned to meet initial

' installation cleanness levels prior to reinstallation. However, FPC shal!

assure that measures are token to prevent degradation of the previously established or existing cleanness state of the system.

G,N-7 1) For operational phase maintenance and modification activities which 4

are comperable in nature and extent to similar activities conducted during the construction phase, FPC shall either control these activ-ities under this OOAP or under on NRC accepted Construction GA Program. When this OOAP is used, FPC shall comply with the requirements of the Regulatory Position documented in this Guide in that GA programmatic /odministrative requirements included therein (subject to the clarifications below) shall apply to these maintenance i

and modification activities even though such requirements may not

' have been in effect originally. Technical requirements associated with the molntenance and modifications shall be the original require-ments or better (e.g., code requirements, material properties, design margins, manufacturing processes, and inspection requirements).

B-S-S 2) This Guide and Standard are applicable to those areas of the Qualliy Assurance Program oddressing on-site cleaning of materials and components, cleanliness control, and cleaning and layup of fluid systems during the operational phase: They do not cover off-site i

activities unless invoked in procurement documents.

F 3) With regard to Paragraph C.3 of Regulatory Guide 1.37: The water '

quality for final flushing of fluid systems and associated components shall be at least equivalent to the quality of the operating system water except for the oxygen and nitrogen content; but this does not infer that chromotes or other additives, normally in the rystem water, will be added to the flush water.

4 l-96

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D,F 4) With regard to Paragraph C.4 of Regulatory Guide 1.37: Expendable 55 materials, such as inks and related products; temperature indicating sticks; tapes; gummed labels; wrapping materials (other than polyethylene); water soluble dom materials; lubricants; NDT pene-tro'it materials and covolants, desiccants, which contact stainless steel or nickel alloy surfaces shall not contain lead, zinc, copper, mercury, cadmium and other low melting point metals, their alloys or compounds as basic and essential chemical consNtuents. No more than 0.1 percent (1,000 ppm) halogens shall be allowed where such elements are leachable or where they could be released by breakdown of the compounds under expected environmental conditions.

A 5) With regard to Section 1.4 of ANSI N45.2.1 - 1973 titled Definitions:

Definitions in this Standard which are not included in ANSI N45.2.10 shall be used; all definitions which are included in ANSI N45.1.10 shall be used as clarified in FPC's commitment to Regulatory Guide 1.74.

NRC Regulatory Guide 1.37 (Continued)

6) With regard to Section 5 of ANSI N45.2.I - 1973 titled installation Cleaning: The recommendation that local rusting on corrosion resistant olicys be removed by mechanical methods is interpreted to mean that local rusting may be removed mechanically, but the use of other removal means is not precluded.

7) With regard to Section 9 of ANSI N45.2.1 - 1973 titled Records: FPC shall maintain records in accordance with and to meet the require-ments of Section 1.7.1.17 of the OOAP and ANSI N45.2.9 as specified in Table 1-3.

1-97

NRC Reaulatory Guide 1.38 " Quality Assurance Recairements for Pock- 55 oging, Shipping, Receiving, Storage, and Handling of items for Water-Cooled Nuclear Power Plants" (Rev. 2, 5/77) - Endorses ANSI N45.2.2 -

19 '

The O ility Program (OOAP) complios with the requirements of this Guide with the following clarifications:

A l} With regard to Section 1.4 of ANSI N45.2.2 - 1972 titled Definitions:

Definitions in this Stondord which are not included in AN5FFM5.2.10 shall be used; all definitions which are included in ANSI N45.2.10 shall be used as clarified in FPC's commitment to Regulatory Guide 1.74.

D 2) With regard to Section 2.1 of ANSI N45.2.2 - 1972 titled Planning:

(First sentence) The specific items to be governed by the Standard shall be identified on the "Sofety Listing". However, the Standard (as modified by clarifications in Table 1-3) is part of FPC's OOAP and it shall therefore, be opplied to those structures, systems, and components which are included in that Program.

A 3) With regard to Section 2.3 of ANSI N45.2.2 - 1972 titled Results: The specific methods for performing and documenting tests and inspec-tions are given in Sections 1.7.1.10 and 11 of the OQAP. The requirements in these Sections shall be implemented in lieu of the general requirements here.

A 4) With regard to Section 2.4 of ANSI N45.2.2 - 1972 titled Personnel Qualifications: Specific requirements for personnel qualifications and training are set forth in Section 1.7.I.2 and in the commitments to training standards in Table 1-3 of the OOAP. These requirements l shall be implemented in lieu of the general requirements stated in this Section.

l E 5) With regard to Section 2.7 of ANSI N45.2.2 - 1972 titled Classifica-tion of items: FPC may choose not to explicitly use the four level classification system. However, the specific requirements of the Standard that are oppropriate to each class are generally applied to the items suggested in each classification and to similar items.

F,C 6) With regard to Section 3,2.1 of ANSI N45.2.2 - 1972 titled Level A l Items: As on alternate to the requirements for packaging and containerizing items in :toroge to control contaminants (Items (4) and (5)), FPC may choose o storage atmosphere which is free of harmful contaminants in concentrations that cou!d produce domoge 10 stored items. Similarly (for item (7)) FPC may obviate the need for cops and plugs with on oppropricte storage atmosphere, and may choose to '

protect weld-end preparations and threeds by controlling the manner in which the items are stored. These clarifications apply whenever items (4), (5) or (7) are subsequently referenced and to Section 3.5.I titled Cops and Pluas and Section 3.4 titled Methods of Preservation.

l l-98

NRC Reculatory Guide 1.38 (Continued)

F,C 7) With regard to Section 3.3 d ANSI N45.2.2 - 1972 titled Cleonino: 55 i

(Third sentence) FPC Interprets " documented cleaning methods" to allow generic cleaning procedures to be written which ore imple-mented, os necessary, by trained personnel. Euch porticular cleaning operation may not have an individuo! cleaning procedure, or which type (s) of solvent (s) may be used in a particular opplication.

F 8) With regard to Section 3.4 of ANSI N45.2.2 - 1972 titled Methods of

< Preservatieg (First sentence) FPC shall comply with these require- i ments subject to the clarifications of Section 3.2.1 (4) and (5) above, and the definition of the phrase " deleterious corrosion" to mean that corrosion which connot be subsequently removed and which odversely l

! offects form, fit, or function.

I

A 9) With regard to Section 3.6 of ANSI N45.2.2 - 1972 titled Barrier and Wrap Material and Desicconts: This section requires the use of l

nonhalogenoted materials in contact with oustenitic stainless steel.

Refer to Regulatory Guide 1.37 for the FPC position.

E,C 10) With regard to Section 3.7.1 of ANSI N45.2.2 - 1972 titled Con- ~

toiners: Clected, sheathed boxes may be used up to 1000 lbs. raiEer

• than 500 lbs. as specified in 3.7.l(l). This type of box is safe for, and has been tested for, loods up to 1000 lbs. Other national standards allow this (see Federal Specification PPP-B-601). Special qualifico-tion testing may be required fer loods above 1000 lbs.

B,C 11) With regard to Section 3.7.2 of ANSI N45.2.2 - 1972 titled Crates and Skids: Skids or runners shall normally be used on containers with a gross weight of 500 lbs. or more. Skids or runners are normally fabricated from 4 x 4 inch nominal lumber size, minimum, and laid

' flot except where this is improctical because of the small dimensions of the container. If forklift handling is required, minimum floor clearance for forklif t tines shall be provided. ,

l E,C 12) 'With regard to Section 4.2.2 of ANSI N45.2.2 - 1972 titled Closed Carriers: The use of fully enclosed furniture vans, as recommended in (2) of this Section, is not considered a requirement. FPC assures odequate protection from weather or other environmental conditions by a combination of vehicle enclosures and item packaging.

G 13) With regard to Sections 4.3, 4.4 and 4.5 of ANSI N45.2.2 - 1972, respectively, Precautions Durina Loadina and Transit, Identification and Markina, und Shipment from Countries Outside the United States:

FPC shall comply with the requirements of these Sections subject to the clarifications taken to other Sections which are referenced therein.

B,E,C 14) With regard to Section 5.2.1 of ANSI N45.2.2 - 1972 titled Shippino Domaae Inspection: Warehouse personnel normally visually scrutinize incoming shipments for domoge of the types listed in-this Section; this activity is not necessarily performed prior to unlooding. Since all required items receive the item inspection of Section S.2.2, separate documentation of the Shipping Domoge inspection is not I-99

NRC Reaulatory Guide 1.38 (Continued) 55 necessary. Release of the transport ogent after unloading and the signing for receipt of the shipment may be all of the action taken to document completion of the Shipping Damage inspection. Any nonconformance noted ,

shall be documented and dispositioned as required by Section 1.7.1.15 of

, the OOAP. The person performing the visvol scrutiny during unloading is  ;

not considered to be performing an inspection function as defined under Regulatory Guides 1.58 and 1.74; therefore, while he shall be trained to

perform this function, he may not necessarily be certified (N45.2.6) as an '

inspector.

D,C 15) With regard to Section 5.2.2 of ANSI N45.2.2 - 1972 titled item inspection:

The second division of this subsection requires six additional inspection activities if an item was not inspected or examined at the source. The Nuclear Engineering and/or Quality Progroms Department shall determine and document the extent of receipt inspection based on considerction of Section 5.2.2.

} F,C 16) With regard to Section 6.l.2 of ANSI N45.2.2 - 1972 titled Levels of 4 j Storoae Subport (2) is replaced with the following:

i

(2) Level B items shall be stored within a fire resistant, weathertight, and well ventilated building or equivalent enclosure. This building shall be i situated and constructed so that it shall not normally be subject to flooding; the floor shall be paved or equal, and well drained. If any outside waters should come in contoct with stored equipment, such equipment shall be labeled or togged nonconforming, and then the nonconformance document shall be processed and evaluated in accordonce with Section 1.7.1.15. Items shall be placed on pollets for shoring or shelves to permit air circulation. The building shall be provided with heating and temperature control or its equivalent to reduce condensation or corrosion.

Minimum temperature shall be 400F and maximum temperature shall be 1400F or less if so stipulated by a manufacturer.

S-l 17) With regard to Section 6.2.1 of ANSI N45.2.2 - 1972 titled Access to l

Storene Areas: Items which fall within the Level D classification of the i

Standard may be stored in an area which is posted to limit access, but other controls such as fencing or guards are not considered to be required.

E 18) With regard to Section 6.2.4 of ANSI N45.2.2

• 1972 titled Storaae of Food

and Associated items

This Section is reploeed with the following: "The

! use of food, drinks, and salt tablet dispensers in any storage area shall be controlled and shall be limited to designated orcos where use or storage is not deleterious to stored items".

F,C 19) With regard to Section 6.2.5 of ANSI N45.2.2 - 1982 titled Measures to Prevent Entrance of Animals: This Section is replaced with the following:

"Worehouse personnel shall be clert to detect evidence of rodents or small l animals in indoor storage oreos. If any such evidence is detected, o survey '

1 1-100 yr -y- t w a- ew-iye----mmm - wa --wrw--- e , ww w yew-w--er--m ,e vvw-wie ,w-se- ,i**e- w _--*-"w= *erm+*-=,-

' NRC Reaulatory Guide 1.38 (Continued)

! or inspection shall be utilized to determine the extent of any possible 55

' domoge or contamination. Exterminators, traps, poisons or other oppropriate measures shall be used to control these animals to minimize possible undestroble effects on stored materials."

I D 20) With regard to Section 6.3.3 of ANSI N45.2.2 - 1972 titled Storoce of Hozordous Material: This Section is replaced with the fol'owing:

4 "Hozordous chemicals, points, solvents and similar matericls shall be stored in approved cabinets which are not in close proximity to installed plant systems which are required for safe shutdown or long term cooling of the plant."

21) With regard to Section 6.4.2 of ANSI N45.2. - 1972 titled Core of '

items: The following alternates are provided for indicated subparts:

1 B (5) " Space heaters in electrical equipment shall be energized unless a documented engineering evoluotion determines that such space heaters are not required."

B (6) "Large (greater than or equal to 50HP) rotating electrical equipment shall be given insulation resistance tests on a scheduled basis unless o documented engineering evoluotion determines that l

such tests are not required."

B (7) " Prior to being placed in storage, rotating equipment weighing over opproximately 50 pounds shall be evoluoted by engineering personnel to determine if shaf t rotation in storage is required: The results of the evoluotion shall be documented. If rotation is required, l It shall be performed at specified intervals, be documented, and be i

conducted so that parts receive a coating of lubrication where applicable and so that the shaft does not come to rest in the some position occupied prior to rotation. For long shafts or heavy equipment subject to undesirable bowing, shaft orientation offer l

rotation shall be specified and obtained."

H,F 22) With regard to Section 6.5 of ANSI N45.2.2 - 1972 titled Removal of items From Storoce: FPC does not consider the lost sentence of this Section to be appl cable to the operational phase due to the relatively short period of time between installation and use. The first sentence of the Section is replaced with: "FPC shall develop, issue, and implement a proceduie(s) which cover (s) the removal of items from steroge. The procedure (s) assure (s) that the status of all material issued is know, controlled, and oppropriately dispositiened."

B 23) With regard to Section 6.6 of ANSI N45.2.2 - 1972 titled Storage Records: FPC shall comply with the requirements of this Section with the clorification that, for record purposes, only the access of non-FPC personnel into indoor storege areas shall be recorded.

Unicoding or pick-up of material shall not be cons:dered access, nor l shall inspection by NRC or other regulatory ogents, nor shall tours by l non-FPC employees who are accompanied by FPC employees. If

' warehouse personnel are not on duty, occess to and egress from the l Indoor storage area shall be documented.

1-101

NRC Regulatory Guide 1.38 (Continued) 55 B,F,C 24) With regard to Section 7.3 of ANSI N45.2.2 - 1972 titled Hoistino Equipment: Rerating of hoisting equipment is considered only when absolutely necessary. Prior to performing any lift above the food roting, the equipment manufoeturer must be contacted for his opproval and direction. The manufacturer must be requested to supply a document granting opproval for a limited number of lif ts at the new rating and any restrictions involved, such as modifications to be mode to the equipment, the number of lif ts to be made at the new rating, and the test lif t load. At all times, the codes governing rerating of hoisting equipment must be observed.

If rerating of hoisting equipment is necessary and FPC connot or does not contact the equipment manufoeturer as described above, the test weight used in temporarily rerating hoisting equipment for special lifts shall be at least equal to !!0% of the lift weight. A dynamic food test over the full range of the lift using a weight at least equal to tne lift weight shall be performed.

l-102

I

. l NRC Regulatory Guide 1.39 " Housekeeping Requirements for Water- 55 Cooled Nuclear Power Plants" (Rev. 2, 9/77) - Endorses ANSI N45.2.3 -

1973 The Quality Program (OGAP) complies with the requirements of this Guide with the following clarifications:

G,N-7 l} For operational phase maintenance and modification activities which are comparable in nature and extent to similar activities conducted during the construction phase, FPC shall either control these activ-ities under this OOAP or under on NRC accepted Construction OA Program. When this OOAP is used, FPC shall comply with the requirements of the Regulatory Position documented in this Guide in ihot GA programmatic / administrative requirements included therein (subject to the clarifications below) shall apply to these maintenance and modification activities even though such requirements may not have been in effect originally. Technical requirements associated with the maintenance and modifications shall be the original require-ments or better (e.g., code requirements, material properties, design margins, manufacturing processes, and inspection requirements).

A 2) With regard to Section 1.4 of ANSI N45.2.3 - 1973 titled Definitions:

Definitions in this Stanord which are not included in ANSI N45.2.10 shall be used: All definitions which are not included in ANS! N45.2.10 shall be used as clarified in FPC's commitment to Regulatory Guide 1.74.

E,S-3 3) With regard to Section 2.1 of ANSI N45.2.3 - 1971 titled Planning:

FPC may choose not to utilize the five-level zone designation system, but shall utilize standard janitorial and work practices to maintain a level of cleanliness commensurate with company policy in the creos of housekeeping, plant and personnel safety, and fire protection.

D Cleanliness shall be maintained, consistent with the work being performed, so os to prevent the entry of foreign material into safety-related systems. This shall include, as a minimum, documented cleanliness inspections which shall be performed prior to system closure. As necessary, (e.g., the opening is larger than the tools being used) control of personnel, tools, equipment,and supplies shall be established when major portions of the reactor system are opened for inspection, maintenance or repair.

I Additional housekeeping requirements shall be implemented as required for control of radioactive contamination.

A 4) With regard to Section 2.2 of ANSI N45.2.3 - 1973 titled Procedures and instructions: Procedures and instructions shall be implemented as set forth in Sections 1.7.l.5,10 and Il of the OOAP and by compliance with the Crystal River Unit 3 Technical Specifications and ANSI N18.7 as set forth in Table 1-3 of that Program in lieu of the requirements set forth here.

1-103

NRC Regulatory Guide 1.39 (Continued)

H 5) With regard to Section 3.1 of ANSI N45.2.3 - 1973 titled Control of I Site Area: Not applicable to the operational phase.

E,S-3 6) With regard to Section 3.2 of ANSI N45.2.3 - 1973 titled Control of Facilities: FPC may choose not to utilize the five-level zone designation system, but shall utilize standard janite 'ai and work practices to maintain a level of cleanliness commenwate with company policy in the areas of housekeeping, plant and personnel safety, and fire protecticq.

D Cleanliness shall be maintained, consistent with the work being performed, so os to prevent the entry of foreign material into safety-related systems. This shall include, as a minimum, documented c'eonliness inspections which shall be performed prior to system closure. As necessary, (e.g., the opening is larger than the tools being used) control of personnel, tools, equipment, and supplies shall be established when major portions of the reactor system are opened for inspection, maintenance or repair.

I Additional housekeeping requirements shall be implemented as required for control of radioactive contamination.

A,H,D 7) With regard to Section 3.3 of ANSI N45.2.3 - 1973 titled Materials and Equipment: The first paragraph in this Section is not applicable to the operational phase. Most of the items in this Section were written for construction activities. Maintenance and modification activities which are similar in nature and extent to construction activities shall be handled as set forth in item I above. The portions of this Section which are considered applicable by responsible maintenance supervisory personnel shall be complied with as stated.

A,H,D 8) With regard to Section 3.4 of ANSI N45.2.3 - 1973 titled _ Construction Tools, Supplies, and Equipment: Most of the items in this Section

, were written for construction activities. Maintenance and j modification activities which are similar in nature and extent to t construction activities shall be handled as set forth in item I above.

The portions of this Section which are considered applicable by

, responsible maintenance supervisory personnel shall be complied with

! as stated.

H 9) With regard to Section 3.5 of ANSI N45.2.3 - 1973 titled Surveillance, inspection, and Examination: Subporograph (1) is not applicable to the operational phase; (2), (3) and (4) shall be implemented.

A 10) With regard to Section 4 of ANSI N45.2.3 - 1973 titled Records: FPC shall maintain records in accordance with and to meet the require-l ments of Section 1.7.l.17 of the OQAP and ANSI N45.2.9 as specified in Table 1-3.

l i

I l-104

55 NRC Reaulatory Guide 1.54 " Quality Assurance Requirements for Protective Coatings Applied to Water-Cooled Nuclear Power Plants" (Rev.

O,6/73)- Endorses ANSI N101 1972 N-10 The Quality Program (OGAP) no longer specifies complionce with the requirements of this Guide, although the ANSI Standard which it endorses may be used for guidance.

d O

e 1-105 .

e.,

- 55 NRC Regulatory Guide 1.58 - Qualification of Nuclear Power Plant inspection, Examination end Testing Personnel" (Rev. I, 9/80) - Endorses ANSI N45.2.6 - 1978).

The Quality Program (OGAP) complies with the requirements of this Guide with the following clarifications: ,

A I) With regard to Regulatory Petition C.I (and Section 1.2 of ANSI N45.2.6 - 1978 which it references), the qualifications of each member of the facility staff shall be os set forth in Technical Specifications or in items 2 or 8 below.

A 2) With regard to Regulatory Positions C.2, C.3 and C.6 (and Sections 1.2 and 3.5 of ANSI N45.2.6 - 1978 which they reference), personnel performing inspections, examinations or tests which are NOT covered by item I above or items 8, 9 or 12 below shall be qualified as follows.

S-2 c. Persons performing nondestructive examinations (NDE) and other octivities covered by SNT-TC-I A-1975 shall be qualified as specified in that Standard and as may be required by Sections lll or XI of the ASME B&PV Code.

S-2 b. OC personnel performing activities at the Crystal River site, whether FPC_ personnel or contract personnel, sholf meet the require-ments of ANSI N45.2.6 - 1978 as clarified in this Table.

G 3) With regard to Regulatory Position C.4 (and Section I.S of ANSI N45.2.6 - 1978 which it references), FPC's generic clarification at the beginning of Table 1-3 is consistent with this NRC Position.

S-2 4) With regard to Regulatory Position C.5 (and Section 3.4 of ANSI N45.2.6 - 1978 which it references), FPC reserves the right to specify octivities which may be conducted by use of documented position descriptions rather than using the specific Level I, il and lit desig-

! nation used in the Standard. However, the qualifications of personnel performing similar activities shall be consistent with the qualifico-tion requirements of the Standard except as noted in items I and 2 above and item 8 below.

S-3 5) With regard to Regulatory Position C.8, FPC has on ALARA program which is applicable to all personnel performing activities at Crystal River Unit 3 os descr! bed in the Regulatory Position.

H 6) Regulatory Position C.9 is not cpplicable to Crystal River Unit 3.

l l S-2 7) With regard to Regulatory Position C.10 (and Section 2.2 of ANSI l N45.2.6 - 1978 which it references), FPC shall document exceptions to the qualifications requirements os set forth in the clarificotton of Section 3.5: Initial and subsequent evoluotion of other personnel shall be performed and documented either in required FPC personnel evoluotions or other suitable records.

l l-106

, . - - . - - ~ ar-,,.a w -- >+e -

.ww -----m- - - - - - - - - - - - ---i--- -

e NRC Regulatory Guide 1.58 (Continued) 55 A 8) QA personnel performing inspections, examinations and testing as part of their routine assignment as auditors or lead audi* ors shall be qualified as set forth in commitments to ANSI N45.2.23 elsewhere in this Table.

S-4 9) With regard to Section 1.2 of ANSI N45.2.6 - 1978 titled Applicabil-ity: The third paragraph requires that the Standard be used in conjunction with ANSI N45.2; FPC no longer specifically commits to l ANSI N45.2 in the OOAP. The fourth paragraph requires that the Standard be imposed on personnel other than FPC employees; the applicability of the Stondard to suppliers shall be documented and applied, as appropriate, in the procurement documents for such suppliers.

A 10) With regard to Section 1.4 of ANSI N45.2.6 - 1978 titled Definitions:

Definitions in this Standard which are not included in ANSI N45.2.10 shall be used; all definitions which are included in ANSI N45.2.10 shall be used as clarified in FPC's commitment to Regulotory Guide 1.74.

D I!) With regard to Section 2.S of ANSI N45.2.6 - 1918 titled Physical:

FPC shall implement the requirements of this Section with the stipulation that, where no special physical characteristics are required, none shall be specified. The converse is also true: If no special physical requirements are stipulated by FPC, none are con-sidered necessary.

S-2 12) With regard 'o Section 3.5 of ANSI N45.2.6 - 1978 titled Education and Experience - Recommendations: FPC reserves the right to use personnel who do not meet all the educational and experience requirements of this Section provided: The use of personnel who do not meet these requirements shall be the exception rather than the rule and each such case shall receive o documented management evaluation and justification for the exception. An example of a documented management evaluation and justification would be one which includes objective criteria (examination, review of octual work performed) to demonstrate that equivalent competence is possessed by such on individual.

l-107

NRC Regulatory Guide 1.64 "Guality Assurcnce Requirements for the .55 Design of Nuclect Power Plants" (Rev. 2, 6/76) - Endorses ANSI N45.2.11 -

1974.

The Quality Program (OGAP) complies with the requirements of this Guide l with the following clarifications:

C,N-7 l} For operational phase maintenance and modification activities which are comparable in nature and extent to similar octivities conducted during the construction phase, FPC shall either control these octiv-ities under this OOAP or under on NRC occepted Construction OA Program. When this OQAP is used, FPC shall comply with the requirements of the Regulatory Position documented in this Guide in that GA programmatic /odministrative requirements included therein (subject to the clarification below) shall apply to these maintenance and modification activities even though such requirements may not have been in effect originally. Technical requirements associated with the maintenance and modifications shall be the original require-ments or better (e.g., code requirements, material properties, design margins, manufacturing processes, and inspection requirements).

C,E 2) With regard to Paragraph C.2(l) of Regulatory Guide 1.64: If in on exceptional circumstance the designer's immediate Supervisor is the only technically qualfied individual ovallable, this review con be conducted by the Supervisor, providing that: (a) the other require-ments of the Regulatory Position are sottsfied, (b) the Justification is individually documented and approved by the Supervisor's management, and (c) quality assurance audits cover frequency and effectiveness of use of Supervisors os design verifiers to guard against abuse.

A 3) With regard to Section 1.4 of ANSI N45.2.11 - 1974 titled Definitions:

Definitions in this Standard which are not included in ANSI N45.2.10 shall be used; all definitions which are included in ANSI N45.2.10 shall be used as clarified in FPC's commitment to Regulatory Guide 1.74.

l A,S-3 4) With regard to Sections 2.1 and 2.2 of ANSI N45.2.li - 1974 titled, respectively, Establishment and Documentation and Program Pro-l cedures: Sections 1.7.1.16 ond 1.7.1.18 of the OQAP and commit-ments to ANSI N45.2.12 as set forth in Table 1-3 of that Program i

shall be met in lieu of the last parograph of Section 2.1 and items 6, 12 and 13 in Section 2.2.

N-5 S) With regard to Section 5.2.4 of ANSI N45.2.11 - 1974 titled Documen-tation: For the documentation of interdisciplinary design reviews, there must be documented evidence of the acceptability of design documents or portions thereof, prior to release (material, stress, physics, mechanical, electrical, concrete, etc.). The signature or initials of those who determine the acceptobility o,f the design relative to their respective disciplinary creo of concern should be on the document or on a separate form traceable to the document. A document that indicates the reviewer's comments need not be retain-ed.

1-108 I _. . ..

_ .. . - - - .. .-. - - . _ ~ _ - . . - - - - - . . .--. - . . - _ - - -

I NRC Reaulatory Guide 1.64 (Continued)

N-2 6) With regard to Section 6.1 of ANSI N45.2.ll - 1974 titled General: '

55 The third porograph in this Section stipulates certain requirements relative to "the results of design verification". FPC may comply with

, these requirements by having the reviewer (s) sign and date on l oppropriate document providing the following conditions are also

. mett l a) Documented engineering / design procedures are established which cover the extent of design review.

b) The procedures identify the duties of the reviewer and the

extent of his responsibility for which he attests with his signature.

[ c) The procedures specify the extent of documentation necessary for the type of design verification opplicable to the complexity of the design.

d) The signature and date is offixed in accordance with the procedures.

N-3 FPC shall also permit initials to be used in lieu of the signature required above IF o file is maintained to correlate chorocteristic initials versus individuals such that each set of characteristic initials can be traced to an individual. This correlation must be reodily I ovallable to NRC inspectors whenever the document is being used.

l N-4 7) The timing of design verification is not mentioned in the Standard.

l FPC shall perform verification in a timely manner. If other than by l

qualification testing of a prototype or leod production unit, verifico-l tion should be completed prior to release for procurement, manufoc-turing or construction or release to another organization for use in other design activities. In those cases where this timing connot be met, the design verification may be deferred, provided that the justification for this action is documented and the unverified portion of the design output document and all design output docu'ments, based on the unverified dato, are oppropriately identified and controlled. .

Site activities associated with a design or design change shall not proceed without verificatfor' past the point where the installation- ,

would become irreversible without extensive demolition and rework.

In all cases, the design verification shall be completed prior to l

relying upon the component, system, or structure to perform its safety-related function.

A,S-3 5) With regard to Section 10 of ANSI N45.2.11 - 1974 titled Records:

FPC shall maintain records in occordance with and to meet the requirements of Section 1.7.1.17 of the OQAP and ANSI N45.2.9 as specified in Table 1-3. The additional requirements of the first sentence of the second porograph in this Section shall also be met.

A,S-3 9) With regard to Section iI (inclwfing Subsections Il.l through Il.7) of ANSI N45.2.11 - 1974, titled Audits: The FPC's Audit Program shall be implemented in occordance with and to meet the requirements of:

ANSI N45.2.12 as endorsed in Table 1-3; Sections 1.7.1.16 and 18 of 1-109

NRC Regulatory Guide f.64 (Continued) 55 the OOAP; and the requirements of Crystal River Unit 3 Technical Specifications.

N-i l 10) FPC does not require the FSAR to be a design document. However, if the FSAR contains any design or design input that has not been previously documented, reviewed and opproved in occordance with the requirements contained in the OOAP or another approved design control QA program and if the FSAR is used as a design document during the design process, that specific information must be controlled and verified in accordance with the commitments here and Section 1.7.1.3 of the OOAP.

i 1

(

i 1-110

NRC Regulatory Guide 1.74 " Quality Assurance Terms and Definition" 55 (2/74) - Endorses ANSI N45.2.10 - 1973 The Quality Program (OOAP) complies with the requirements of this Guide with the following clarifications:

S-7 l} FPC reserves the right to define odditional words or phrases which are not included in this Standard. Such additional definitions shall be documented in oppropriate procedures and/or in ottochments/

oppendices to quality assurance procedures /monuals, or in Sections of the OOAP.

l

i 2) In addition to the Standard's definition of " Inspection," FPC shall use the following

" Inspection (when used to refer to octivities that are NOT performed by quality organization personnel) - Examining,

viewing closely, scrutinizing, looking over or otherwise checking octivities. Personnel performing these functions are not necessarily certified to ANSI N45.2.6."

S-7 When FPC intends for inspections to be performed in occordance with the OQAP by personnel certified as required by that Program and for

' octivities defined by " Inspection" in ANSI N45.2.10, appropriate references to the plant quality organization which shall perform the octivity or to Quality Procedures to be used for performing the activity shall be mode. If such references are NOT mode, inspections are to be considered under the odditional definition given above.

I 3) In oddition to the Standard's definition of " procurement documents,"

FPC shall utilize the definitions given in ANSI N45.2.13 and in Regulatory Guide 1.74. The compound definition is given as follows:

Procurement documents - Contractually binding documents that identify and define the requirements which items or services must meet in order to be considered acceptable by the purchaser. They

{nclude documents which authorize the seller to perform r,ervices or supply equipment, material or facilities on behalf of the purchaser (e.g., Engineering Service Agreements (ogreements for engineering, .

j construction, or consulting services)), contracts, letters of intent, work outhorization (in some cases), purchase requisitions, purchase orders, or proposals and their acceptance, drawings, specifications, or instructions which define requirements for purchase.

I 4) " Audit" (Shall be o modification of the word - to allow the use of subjective evidence if no objective evidence is available - os defined in Section 1.4 of ANSI N45.2.12 - 1977 and Section 1.4.3 of ANSI N45.2.23 - 1978 as opposed to the definition given in ANSI N45.2.10 -

1973) - A documented activity performed in occordonce with written procedures or checklists to verify, by examination and evoluotion of objective evidence where available, that applicable elements of the quality assurance program have been developed, documented and effectively implemented in accordance with specified requirements.

An audit should not be confused with surveillance or inspection for the sole purpose of process control or product occeptance.

1-111

i NRC Regulatory Guide I.74 (Continued)

" Independent Verification" - Verification by an individual other than 55 S-8 5) the person who performed ther operation or octivity being verified that required actions have been completed. Such verification shall not require confirmation of the identical oction when other indications provide assurance or indication that the prescribed activity is in fact complete. Examples include, but are not ilmited to: verification of a breaker opening by observing the octuation of status or indicating lights of the required panel-meter indicated value; verification that a valve has been positioned by observing the starting or stopping of flow on meter indicottons or by remote volve positions indicating lights.

S-8 6) "Must"-(Not defined in any ANSI Standord) - An internally auditable requirement imposed by FPC management upon its employees, con-tractors, and agents - above and in excess of the legally binding requirements of the oppropriate regulatory body. Such items are internally required but not externally enforceable.

S-8 7) "NRC occepted Construction QA Program" - (1) o program for design or construction which was reviewed by the QA organization of the NRC and accepted for use; (2) the revision of that NRC occepted proaram which is in effect at the time that FPC outhorizes com-1 mencement of work; and (3) a program which the FPC QA organiza-tion reviews and concurs that the QA Program controis are occept-l oble for the activity to be performed.

S-4 8) " Program Deficiencies" (Not defined in ANSI N45.2.10, but used and defined differently in ANSI N45.212)- Failure to develop, document or implement effectively any applicable element of the OQAP.

S-4 9) " Quality Assurance Program Requirements" (Not defined in ANSI N45.2.10 but used and defined differently in ANSI N45.2.13) - Those individuct requirements of the OOAP which, when invoked in total or In part, establish the requirements of the Quality Program for the

! octivity being controlled. Although not specifically used in the OQAP, ANSI N45.2 may be imposed upon FPC's suppliers.

I 10) " Quality assurance records" - (Not defined in ANSI N45.2.10 and defined without " expansion" in ANSI N45.2.9 - 1974) - The definition of " quality assurance records" which is given in Section 1.4 of ANSI N45.2.9 - 1974 shall be used with the clarification that " quality assurance records" are the Lifetime Quality Assuronce Records defined in Section 2.2.1 and the Nonpermanent Quality Assurance

+ Records defined in Section 2.2.2 of the Standcrd as well as those records specifically required to be retained by the applicable portions of the Code of Federal Regulations, Title 10 and as defined in Crystal River Technical Specification 6.10.

S-8 II) "Will" - (Not defined in any ANSI standard) - Means the some as "shall" except when context shows that it is simply being used to

' indicate events which are to take place in the future. In the latter l

case, "will" is normally followed by "be".

l S-7 12) " Quality Control" - FPC uses the definition provided in FSAR Section I l.7.4.

1-112 I -

l-- ._ -. _ _ _ . _ . .____ _ _ ___ _ _ __ _ _ _ _ _ _ _

NRC Reoulatory Guide 1.88~ " Collection, Storage and Maintenance of Nuclear Power Plant Quality Assurance Records" (Rev. 2,10/76 - Endorses ANSI N45.2.9 - 1974)

The Quality Program (OGAP) complies with the requirements of this guide with the following clarifications:

A,1 l} With regard to Section 1.4 of ANSI N45.29 1974 titled Definitions:

The only definition given in this Standard is not included in ANSI N45.2.10. The Standard's definition of " quality assurance records" shall be used with the clarification that " quality assurance records" are the Lifetime Quolity Assurance Records defined in Section 2.2.1 and the Nanpermanent Quality Assurance Records defined in Section 2.2.2 as well as those records specifically required to be retained by the applicable portions of the Code of Federal Regulations, Title 10 and as defined in Crystal River Technical Specification 6.10. This clarification is also given in this Table under Regulatory Guide 1.74.

D 2) With regard to Section 3.2.1 of ANSI N45.2.9 - 1974 titled Generation of Quality Assurance Records: The phrase " completely filled out" is ,

clarified to meca that sufficient informatim is recorded to fulfill the intended purpose of the record.

F 3) With regard to Section 3.2.2 of ANSI N45.2.9 - 1974 titled Indu The phrase "an index" is clarified to mean a collection of documents or indices which, when taken together, supply the information attributed l fo "an index" in the Stondord.

F,C The specificotton location of a record "within a storage area" may not always be delineated (e.g. The specific location within a computer record file may not be constant. Further, FPC may utilize a computer assisted random occess filing system where such a

" location" could not be readily documented, nor would such a location be meaningful). The storage location shall be delineated, but where file locations change with time, the specific location of a record within taat file may not always be documented.

L l

S-5 4) With regard to Section 4.2 of ANSI N45.2.9 - 1974 titled Timeliness:

FPC's contractual ogreement with its vendors, A/E, constructors, and suppliers shall constitute fulfillment of the requirements of this Section.

D,F 5) With regard to Section 5.3 of ANSI N45.2.9 - 1974 titled Storace:

The first sentence is clarified by stating that an individual or group l

of Individuals or a classification of employee shall be designated and assigned the responsibility to enforce written storage procedures.

The term " custodian" may or may not be used as part of that designation.

S-6 6) With regard to Section 5.4 of ANSI N45.2.9 - 1974 titled Preserva-tion: The following clarification is substituted for the current 5ulisection 5.4.2 " Records sholl not be stored loosely. They shcIl be secured for storage in file cabinets or on shelving in containers".

1-113

l i NRC Re<vlotory Guide 1.88 (Continued)

Alt wogh not a verbot;m quote, this is the position token in the latest consensus Stmdord (ANSI /ASME NOA-lb-1981, Supplement 175-1, Section 4.2(b)).

5-6 7) . With regard to Subsection 5.4.3 of ANSI N45.2.9 - 1974 titled Special Processed Records: Tne following clarificotton is substituted for the current Subsection 5.4.3: " Provisions shall be mode for special processed records (such as radiographs, photographs, negatives, microfilm and mognetic media) to prevent damoge from excessive light, stocking, electromagnetic fields, temperature and humidity as oppropriate to the record type." This is the position token in the latest consensus Standard (ANSI /ASME NOA-Ib-1981, Supplement ,

175-1, Section 4.2(c)).

, D 8) With regard to Section 5.5 of ANSI N45.2.9 - 1974 titled Safekeepino:

Routine general office and nuclear site security systems and occess controls are provided: No special security systems are required to be established for record storage areas. t F 9) With regard to Section 5.6 of ANSI N45.2.9 - 1974 titled Focility:

This Section provides no distinction between temporary and per-monent facilities. To cover temporary storage, the following clari-fication is added: Active records (those completed but not yet duplicated or placed on microform) may be temporarily stored in one-j hour fire rated file cabinets, in general, records shall not ~ be maintained in such temporary storoge for more than three months offer completion without being duplicated (for dual storage) or being p! aced on microform. Any exceptions to this three month storage shall be evoluated and opproved by the Director, Quality Programs; a list of all such excepted records shall be maintained and available for NRC review. Open-ended documents (those revised or updated on a more-or-less continuing basis over an extended period of time (e.g.

personnel qualification and training documents, equipment history cards, oudit or surveillance schedules)) and those which are cumulo-

! tive, in nature (e.g. nonforming item logs, control room log books, night order books) are not considered as OA records since they are not !' complete". These types of documents shall become QA records:

when they are issued as a specific revision (e.g. the audit schedule);

when they are filled-up or discontinued (e.g. log books or equipment history cards); on a predefined periodic basis when the completed

. portion of the on-going document shall be transferred to the records storage facility os a " record" (e.g. training and qualification records).

The applicable provision of Section 5.3 shall be met by QA records in temporary storoge.

S-6 Where duplicate storage is employed as permitted by the 2nd porograph, no special construction requirements are opplicable.

However, the record storage locottons shall be sufficiently separated from one another that they are not generally susceptible to simul-toneous destruction by the some natural disaster (e.g. fire, flooding).

Although not a verbatim quote, this is the position taken in the latest

+

consenses Standord (ANSI /ASME NOA-Ib-1981, Supplement 175-l, e Section 4.4.2).

l-Il4

55 NRC Regulatory Guide 1.88 (Continued!

S-6 The 4th paragraph, item 3 is modified to require o two< hour minimum fire rating to be consistent with the 1779 version of the Standard, NOA-lb+1981, and NRC Criteria for Record Storage Focilities (Guidance-ANSI N45.2.9, Section 5.6) issued 7/I/80.

S-6 The Aih porograph, item 9 is clorified to read: "No pipes or penetrations except those used exclusively for fire protection, light-Ing, temperature / humidity control, or communicottons are to be Iccated within the facility. All such penetrations shall be sealed or dampened to comply with a minimum two-hour fire protection

." This is the position tal<en in the latest consensus Standard rating (ANSI /ASME NOA-lb-1981, Supplement 175-1, Section 4.4.l(j)).

D 10) With regard to Section 6.2 of ANSI N45.2.9 - 1974 titled Accessibi-

!ity: The second paragraph of this Section is clarified to mean that persons authorized occess shall be designated. However, the designa-tion may be by generic group (e.g. all Records personnel; all licensed personeel; all FPC employees) or by job title / function. In such cases, no " list," per se, would be generated.

e c l-115

55 NRC Recolatory Guide 1.94 " Quality Assurance Requirements for Instal-lation, inspection, and Testing of Structural Concrete end Structural Steel during the Construction Phase of Nuclear Power Plants" (Rev. I, 4/76) -

Endorses ANSI N45.2.5 - 1974.

The Ovality Program (OOAP) complies with the requirements of this Guide with the following clarifications:

G,N-7 l} For operational phase maintenance and modification activities which are comparable in nature and extent to similar activities conducted during the construction phase, FPC shall either control these activ-Itles under this OOAP or under on NRC occepted Construction OA Program. When this OOAP is used, FPC shall comply with the requirements of the Regulatory Position documented in this Guide in that GA programmatic /odministrative requirements incleded therein (subject to the clarificottons below) shall opply to these maintenance and modificotton activities even though such requirements may not have been in effect originally. Technical requirements associated with the maintenance and modifications shall be the original require, ments or better (e.g., code requirements, material properties, design margins, manufacturing processes, and inspection requirements).

H 2) With regord to Section 1.1 of ANSI N45.2.5 - 1974 titled Scope: The last paragraph of this Section is not opplicable to the operational phase.

H,B,0 3) With regard to Section 1.3 of ANSI N45.2.5 - 1974 titled Applicabil-h: The first sentence in this Section is not applicable to the operational phase. FPC shall comply with the thhd sentence in this Section with the clarifications that "importance of the item or service involved" is interpreted to mean those to which the OOAP opplies, and the extent of coverage shall be defined by supervisory maintenance personnel by the way in which they implement the other requirements of this Standard. ,

H In the second paragraph of this Section, FPC shall substituto the words " maintenance and modification" for the word " construction" as the modifier of " procedures".

D 4) With regard to Section 1.3 of ANSI N45.2.5 - 1974 titled Responsibil-h: This Section's requirements are met by the definitions for positions and the organizational responsibilities outlined in the Tech-nical Specifications, Section 1.7.1.1 of the OOAP, and the position descriptions for plant personnel.

A 5) With regard to Section 1.4 of ANSI N45.2.5 - 1974 titled Definitions:

Definitions in this Standard which are not included in ANSI N45.2.10 shall be used: All definitions which are included in ANSI N45.2.10 shall be used as clarified in FPC's commitment to Regulatory Guide 1.74.

l-!!6

5 . ,

t i

NRC Reaulatory Guide 1.94 (Continued)

D 6) With regard to Section 2,1 of ANSI N45.2.5 - 1974 titled Plannino: 55

+

Planning requirements, when necessary, shall be incorporated into maintenance and modification procedures.

A 7) With regard to Section 2.2 of ANSI N45.2.5 - 1974 titled Procedures and Instructions: Procedures and instructions shall be implemented as set forth in Sections 1.7.l.5,10 and 11 of the OQAP and by

- compliance with the Crystal River Unit 3 Technical Specificottons .

! and ANSI N18.7 as set forth in Table 1-3 of that Program in lieu of the requirements set forth here.

! A,S-3 6) With regard to Section 2.3 of ANSI N45.2.5 - 1974 titled Results:

These requirements are met by implementing Sections 1.7.1.10, il and 17 of the OQAP and by compliance with ANSI N18.7 as set forth in Table 1-3 of that Program in lieu of the requirements set forth '

l here.

A 9) With regard to Section 2.5.2 of ANSI N45.2.5 - 1974 titled Calibration

.t and Control: The first paragraph of this Section shall be met as set i forth in item 2 of FPC's commitment to Regulatory Guide 1.30 i elsewhere in this Table.

N-l 10) With regard to Section 4.8 of ANSI N45.2.5 - 1974 titled in-Process T_ests on Concrete and Reinfercing Steel: The seventh sentence i specifies the location for taking pumped concrete samples. There may be instances when the pump line discharge is inaccessible for i sampling and there may be other instances when, although samples 4 could be taken, the technician would be in such a position that he

could not satisfactorily conduct the tests. In these instances, FPC shall sompte the concrete at the truck just before it enters the pump inlet hopper. When this technique is used, o correlation shall be established between truck discharge test results and pump line l

discharge test results.

N-8 11) With regard to Section 5.4 of ANSI N45.2.5 - 1974 titled JHi Strength Rolting: Item I of the second paragraph of this Section requires at least two threads to extend beyond the nut. FPC shall normally meet this criterion but may accept installations which have the point of the bolt flush with or outside of the foce of the nut when completely installed if a direct-tension indicator is used to tighten the bolt.

A,S-3 12) With regard to Section 6.1 of ANSI N45.2.5 - 1974 titled General:

Inspection and test requirements shall be implemented as defined in Sections 1.7.l.3,10 and ll of the OQAP and FPC's commitment to Section 5.2.7 of ANSI N18.7 as described in Table 1-3 of that Program in lieu of the requirements set forth here. ,

A 13) With regard to Section 7 of ANSI N45.2.5 - 1974 titled Records: FPC shall maintain records in occordance with and to meet the require-ments of Section 1.7.1.17 of the OQAP and ANSI-N45. 2.9 as ,

specified in Table 1-3.

1-117

__ _ m_ _ . _ _

s l

~

~

p i ( <

NRC Regulatory Guide 1.116 "Ouality Assurance (Requirements .for 55 Installation, inspection and Testing of Mechanical Equipment and Systems" (Rev. O-R, 6/76) - Endorses ANSI N45.2.8 - 1975 The Quality Program (OGAP) complies with the requirements of this Guide with the following clarifications:

G,N-7 l} For operational phase maintenance and modification activities which are comparable in nature and extent to similar activities conducted during the construction phase, FPC shall either control these activ-ities under this OQAP or under an NRC occepted Construction GA Program. When this OCAP is used, FPC shall comply with the requirements of the Reoulatory Penition documented in this Guide in that OA programmatic / administrative requirements included therein (subject to the clorifications below) shall apply to these maintenance and modification activities even though such requirements may not have been in effect" originally. Technical requirements associated with the maintenance and mcdificottons shall be the original require-ments or better (e.g., code requirements, material properties, design margins, manufacturing processes, and inspection requirements).

H 2) With regard to Section 1.1 of ANSI N45.2.8 - 1975 titled Scope: The last paragraph of this Section is not applicable to the operational phase. The applicable portions of the requirements of this Standard shall also be applied af ter fuel lood; therefore, the last twenty-two words in the last sentence of the second paragraph under this Saction are also not appropriate to the operational phase.

H,B,D 3) With regard to Section 1.2 of ANSI N45.2.8 - 1975 titled Applicabil- I h The first sentence in this Section is not applicable to the operational phase. FPC shall comply with the third sentence in this Section with the clarifications that "important mechnical systems to be covered" is interprated to mean those to which the OOAP opplies, and "the extent of coverage" shall be defined by supervisory mainte-nace personnel by the way in which they implement the other '

requirements of this Standard.

D 4) With regard to Section 1.3 of ANSI N45.2.8 - 1975 titled Respon.sibil-ity: This Section's requirements are met by the definitions for l positions and the organizational responsibilities outlined in the Tech-l nical Specifications, Sectionl.7.1.1 of the OQAP, and the position j descriptions for plant personnel.

l A S) With regard to Section 1.4 of ANSI N45.2.8 - 1975 titled Definitions:

l Definitions in this Standard which are not included in ANSI N45.2.10 I shall be ured: All definitions which are included in ANSI N45.2.10 shall be used as clarified in FPC's commitment to Regulatory Guide 1.74.

I j D 6) With regard to Section 2.1 of ANSI N45.2.8 - 1975 titled Planning:

Planning requirements, when necessary, shall be incorporated into maintenance and modification procedures.

l-!18 l

l - . . . - . - -

NRC Regulatory Guide 1.116 (Continued) 55 A 7) With regard to Section 2.2 of ANSI N45.2.8 - 1975 titled Procedures and instructions: Procedures and instructions shcIl be implemented as set forth in Sections 1.7.i.5,10 and Il of the OQAP and by compliance with the Crystal River Unit 3 Technical Specificottons and ANSI N18.7 as set forth in Table 1-3 of that Program in lieu of the requirements set forth here.

A,S-3 8) With regard to Section 2.3 of ANSI N45.2.8 - 1975 titled Results:

These requirements are met by implementing Sections 1.7.1.10, II and 17 of the OOAP and by compliance with ANSI NI8.7 as set forth in Table 1-3 of that Program in lieu of the requirements set forth here.

A 9) With regard to Section 2.8.2 of ANSI N45.2.8 - 1975 titled Calibration and Control: The first paragraph of this Section shall be met as set forth in item 2 of FPC's commitment to Regulatory Guice 1.30 elsewhere in this Table.

A,H,D 10) With regard to Section 2.9 of ANSI N45.2.8 - 1975 titled Prerequi- ~

sites: Most of the items in this Section were written for construction activities. Maintenance and modification activities which are similar in nature and extent to construction activities shall be handled as set forth in item I above. The portions of this Section which are considered cpplicable by responsible maintenance supervisory personnel shall be complied with as stated.

A,H,0 ll} With regard to Section 3.1 of ANSI N45.2.8 - 1975 titled Pre-Installation Verification: (including Subsections 3.!,3.2,3.3,3.4~o3 3.5.) Most of the items in this Section (and its Subsections) were written for construction activities. Maintenance and modification activities which are similar in nature and extent to construction activities shall be handled as set forth in item I above. The portions of this Section (and its Subsections) which are considered applicable by responsible maintenance supervisory personnel shall be complied with as stated.

A,S-3 12) With regard to Sections 4.1 and 4.2 of ANSI N45.28 - 1975 titled, respectively, General and Process and Procedure Control: FPC meets these requirements by commitments to ANSI N18.7 as set forth elsewhere in 4 nis Table.

A 13) With regard to Section 4.4 of ANSI N45.2.8 - 1975 titled Inspections:

The requirements of Sech 4.4 shall be implemented as set forth in Section 1.7.1.10 of the OQAP. The inspection program shall incor-porate, os applicable, those items listed in this Section.

8,D 14) With regard to Section 4.5 of ANSI N45.2.8 - 1975 titled Installation Checks: (including Subsections 4.5.1 and 4.5.2.) The portions of this Section (and its Subsections) which are considered applicable by responsible maintenance supervisory personnel shall be complied with as stated. Such items shall be specified in appropriate maintenance or modification procedures.

1-119

NRC Reoulatory Guide 1.116 (Continued)

H,A 15) With regard to Section 4.6 of ANSI N45.2.8 - 1975 titled Care of 55 Items: FPC does not consider most of this Section to be applicable to the operational phase due to the relatively short period of time between installation and use. Consistent with commitments to ANSI N45.2.3 and ANSI NI8.7 as given elsewhere in this Table, FPC shall implement appropriate housekeeping and preventive maintenance procedures to assure that all material which has been installed is appropriately protected and maintained.

A,S-3 16) With regard to Section 5.1 of ANSI N45.2.8 - 1975 titled General:

The requirements of this Section shall be implemented as set forth in Sections I.7.l.3 and ll of the OOAP. The test program shall consider the elements outlined in this Se:: tion, where applicable, when devel-oping test requirements for inclusion in maintenance and modifica-tion procedures. In some coses, testing requirements may be met by post-installation surveillance testing in lieu of a special post-instal- .

lation test.

H,A 17) With regard to Sections 5.2,5.3 and 5.4 of ' ANSI N45.2.8 - 1975 titled, respectively, Preoperational Testina, Cold Functional Tests, and Hot Functional Tests: Except for maintenance and modification activ- '

ities which are similar in nature and extent to similar construction activities (which are handled as set forth in item I above), the extensive testing program described in these Sections would not be appl!coble to operational phase activities. Where certain items are applicable, as determined by supervisory maintenance personnel, they j shall be included in appropriate procedures or handled as described under item 7 cbove.

A,S-3 18) With regard to Section 6 of ANSI N45.2.8 - 1975 titled Data Analysis and Evaluation: FPC shall process and analyze inspection and test data as set forth in Sections I.7.1.10, ll and 17 of the OOAP and our commitment to Sections 5.2.7 cnd 5.2.17 of ANSI N18.7 as described in Table 1-3 of the Program in lieu of the requirements of this Section.

l A 19) With regard to Section 7 of ANSI N45.2.8 - 1975 titled Records: FPC shall maintain records in accordance with and to meet the require-ments of Section 1.7.1.17 of the OOAP and ANSI N45.2.9 as specified i in Table 1-3.  ;

p l

6 l

! l-120 l

NRC Re<ulatory Guide 1.123 " Quality Assurance Requirements for 55 Control of Procurement of items and Services for Nuclear Power Plants" (Rev. I, 7/77) -Endorses ANSI N45.2.13 - 1976 The Quality Program (OOAP) complies with the requirements of this Guide with the following clarifications:

S-9 1) Paragraph C.6.c of Regiatory Guide 1.123 (and Sections 10.2.a through f of ANSI N45.2.13 which it references) shall be implemented as originally written (i.e. with the verb "should" instead of the verb "shall").

C, S-9 2) Paragraph C.6.e of Regulatory) Guide 1.123 (cnd Secticn 10.3.4 o N45.2.13 which it references written (i.e. with the verb "should" instead of the verb "shall"). This flexibility is necessxy because FPC may not always be able to obtain Since FPC retains the ultimate agreement with a supplier.

responsibility for performance of purchased equipment and since FPC maintains its own Nuclear Engineering Department, FPC should be allowed to exercise this monogement/ engineering prerogative with respect to the final decision on post installation test requirements.

A 3) With regard to Section 1.3 of ANSI N45.2.13 - 1976 titled Definitions:

With two exceptions (Procurement Document and Quality Assurance

' Program Requirements) definitions in this Standard which are not included in ANSI N45.2.10 shall be used; oil definitions which are included in ANSI N45.2.10 shall be used as clarified in FPC's commitment to Regulatory Guide 1.74. The two exceptions are

' defined in Table 1-3 under Regulatory Guide 1.74.

E 4) With regard to Section I.2.2 of ANSI N45.2.13 - 1976 titled Purchaser's Responsibilities: Item e is one of the options which may be used by FPC to assure quality; however, any of the options given in 10 CFR 50, Appendix B, Criterion Vil as implemented by Sections 1.7.1.4 and 7 of the OOAP may also be used.

F 5) With regard to Section 3.1 of ANSI N45.2.13 - 1976 titled Procurement Document Preparation, Review and Change Control: The phrase "the some degree of control" is stipulated to mean " equivalent level of i review and approval." The changed document may not alwcys be re-reviewed by the originator; however, at least an equivalent level of supervision shall review and approve any chonges.

A, S-3 6) With regard to Section 3.4 of ANSI N45.2.13 - 1976 titled Procurement Document Control: FPC shall meet the requirements of Sections 1.7.1.4 and 7 of the OOAP in lieu of the requirements specified in this l

! Section.

B 7) With regard to Section 5.3 of ANSI N45.2.13 - 1976 titled Preaward Evaluation: FPC shall comply with an alternate paragraph which '

reads: "Except in unusual circumstances (e.g. replacement ports are l

l l

l-121

~

NRC Regulatory Guide 1.123 (Continued) needed to preclude the development of some unsafe or undesirable condition at Crystal River Unit 3), a preaward evoluotion of the 55 Supplier shall be performed as required by the OOAP."

S-4 8) With regard to Section 6.4 of ANSI N45.2.13,1976 titled Control of ,

Changes in items or Services: The phrase "the Quality Progrom" shall  !

be inserted in lieu of " ANSI N45.2, Section 7." l N-9 9) With regard to Section 8.2 of . ANSI N45.2.13 - 1976 titled Disposition: The third sentence of item b is revised to read:

Nonconformances to the contractual procurement requirements or purchaser opproved documents and which consist of one or more of the following shall be submitted to the purchaser for opproval of the recommended disposition prior to shipment when the nonconformance could adversely offect the end use of a module

• or shippable component relative to safety, interchangeability, operability, reliability, integrity, or maintainability:

a) Technical or material requirement is violated; b) Requirement in supplier documents, which have been approved by the purchaser, is violated; c) Nonconformance connot be corrected by continuation of the original manufacturing process or by rework; and/or d) The item does not conform to the criginal requirement even though the item con be restored to a condition such that the capability of the item to function is unimpaired.

• A module is on " assembled device, instrument, or piece of equipment identified by serial number or other identification code, having been evoluoted by inspection and/or test for conformance to procurement requirements regarding end use.

A shippable component is a part of a device, instrument, or piece of equipment which is shipped as an individual item and which has been evaluated by inspection and/or test for conformance to procurement requirements regarding end use".

A, S-3 10) With regard to Section 11 of ANSI N45.2.13 - 1976 titled Quality Assurance Records: FPC shall maintain records in accordance with and to meet the requirements of Section 1.7.1.17 of the OOAP and ANSI N45.2.9 as specified in Table 1-3.

A, S-3 II) With regard to Section 12 of ANSI N45.2.13 - 1976 titled Audit of Procurement Program: The FPC audit program shall be implemented in occordance with and to meet the requirements of: ANSI N45.2.12 as endorsed in Toble 1-3; Sections I.7.1.16 and 18 of the OQAP, and the

~

requirements of the Crystal River Unit 3 Technical Specifications.

l-122

- l l

• l NRC Reautatory Guide 1.144 " Auditing of Quality Assurance Programs for 55 Nuclear Power Plants" (Rev. I, 9/80) . Endorses ANSI N45.2.12 - 1977.

The Quality Program (OGAP) complies with the requirements of this Guide with the following clarifications:

A l} Paragraph C.3.a of Regulatory Guide 1.144 (and Section 3.5.2 of ANSI N45.2.12 which it references) shall be implemented by meeting the audit requirements of the Crystal River Unit 3 Technical Specifications for audits under C.3.o(l). Audits under C.3.o(2) are not covered by this OQAP.

! 2) Porograph C.3.b of Regulatory Guide 1.144 (and Section 3.5.2 of ANSI N45.2.12 which it references) shall be implemented as follows:

S-7 C.3.b(1) shall be met offer adding another item for which external oudits offer contract award are not necessory: weld rod and other similar material which is produced under an ASME NCA3800 program. Such audits are not necessary, althcugh they may be performed, if the material manufacturer retains ASME certification.

N-6 C.3.b(2) is replaced with the following: Eoch supplier is evaluated initially to determine the acceptability of his quality assurance program. If acceptable, the supplier is placed on the approved

, supplier list. .In lieu of routinely conducting on annual reaudit, a formal evaluation of the supplier is performed each year to determine if a reaudit is required during the upcoming year. This evaluation must be formal, with the results documer<ted and approved by responsible GA management; and it must consider pertinent l factors such as the results of other audits, history of performance of l product and/or purchased service, and effectiveness of implemen-l tation of the supplier's OA program.

N-6 This annual assessment shall consider the complexity of the component concerned and the degree of quality and process control required by the manufacturing effort. As a result of this evoluotion,

, suppliers requiring a formal reoudit are identified. Regardless of the results of the evaluation, active suppliers (except those excluded under C.3.b(1) above) shall be reaudited every three years.

S-7, S-9 Inactive suppliers shall be evaluated prior to supplying safety-related

[

items or services. An audit shall be conducted IF required to determine the acceptcbility of procured items or services (i.e.

occeptobility can not be determined by receipt inspection or one of the other methods allowable under 10 CFR 50, Appendix B, Criterion Vil).

D 3) Parograph C.4.o of Regulatory Guide 1.144 (and Section 3.5.3.3 of ANSI N45.2.12 which it references) shall be implemented with the clarificotton that the Director, Quality Programs or his designee shall determine which reorganizations or procedure revisions are -

"significant".

1-123

_ _ _ _ . . . . _ . . . _ . _ , _ _ . _ _ . _ . . _ _ _ _ ~ _ _ _ _ _ _ _ _

l NRC Reaulatory Guide 1.144 (Continued) 55 A,S-3 4) Paragraph C.7 of Regulatory Guide 1.144 (and Section S.2 of ANSI N45.2.12 which it references) shall be implernented by mairitaining records in accordonce with and to meet the requirements of Section 1.7.1.17 of the OGAP and ANSI N45.2.9 as specified in Table 1-3. With respect to the additional oudit records recommended in C.7, FPC may retain such records, but their retention shall not be considered i mandatory.

A 5) With regard to Section 1.4 of ANSI N45.2.12 - 1977 titled Definitions:

With one except!cn (Program Deficiencies) the definitions in this Standard which are not included in ANSI N45.2.10 shall be used as clarified in FPC's commitment to Regulatory Guide I.74. The one excepted definition and a clorified definition (of oudit) relevant to this Standard are defined in Table 1-3 under Regulatory Guide 1.74.

A 6) With regard to Section 2.2 of ANSI N45.2.12 - 1977 titled Personnel Qualification: FPC audit personnel shall be qualified to meet the

, requirements of Section 2 of ANSI N45.2.23 as endorsed in Table 1-3 and Sections 1.7.1.2 and 18 of the OQAP.

A 7) With regcrd to Section 2.3 (and Subsections 2.3.1 through 2.3.3) of ANSI N45.2.12 - 1977 titled Trainino: FPC audit personnel shall be trained as necessory to meet the requirements of Sections 2.2 and 2.3.3 of ANSI N45.2.23 as endorsed in Table 1-3 and Sections 1.7.1.2 and 18 of the OOAP.

j A 8) With regard to Section 2.4 of ANSI N45.2.12 - 1977 litled Maintenance of Proficiency: FPC oudit personnel shall maintain their proficiency by meeting the requirements of Section 3.2 of ANSI N45.2.23 as endorsed in Table 1-3 and Sections 1.7.1.2 and 18 of the OOAP.

C,E,D 9) With regard to Section 3.3 of ANSI N45.2.12 - 1977 titled Essential Elements of the Audit System: FPC shall comply with Subsection l

3.3.5 as it was originally written (Subsection 3.2.5 in ANSI N45.2.12, Draft 3, Revision 4): " Provisions for reporting on the effectiveness of the quality assurance program to the responsible management."

For auditing and cudited organizations within FPC, " effectiveness of the quality assurance progrom" is reported to responsible monogement by meeting the requirements of the Crystal River Unit 3 Technical Specifications and Sections 1.7.1.1, 2,16 and 18 of the OOAP. For audited organizations outside (e.g. vendors, suppliers) of FPC, transmittal of the audit report shall be deemed to meet the requirements of Subsection 3.3.5 "for reporting on the effectiveness of the quality assurance progtam to the responsible management".

D Subsection 3.3.6 requirements are considered to be fulfilled by compliance with the organization and reporting measures outlined in j the OOAP md the Technical Specifications for Crystal River Unit 3.

Subsection 3.3.7 requires verification of effective corr'octive action l on a " timely basis." Timely basis is interpreted to mean within the 1-124

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k NRC Regulatory Guide 1.144 (Continued) framework or pericd of time for completion of corrective action that is accepted by the quality organization. Each finding requires response and a corrective action completion date; these dates are subject to revision (with the opprovel of the quality organization) and must be escalated to higher wthority when there is a disagreement between the audited and the auditing organization on what constitutes " timely corrective action".

. F 10) With regard to Section 3.5 of ANSI N45.2.12 - 1977 titled Scheduling:

Subsection 3.5.3J is interpr(ted to mean that FPC may procedurally control qualification of a contractor's or supplier's quality assurance program prior to awarding a contract or purchase order by means other than oudit.

F, C ll) With regard to Section 4.3.1 of ANSI N45.2.12 - 1977 titled Pre-Aud!t Conference: FPC shall comply with requirements of this Section by inserting the word "Normally" of the beginning of the first sentence.

This clorification is required because, in the case of certain unannounced audits or audits of a particular operation or work cctivity, a pre-oudit conference might interfere with the activity or with the spontaneity of the operation or activity being audited. In other cases, persons who should be present at a pre-oudit conference may not always be availnble: Sxh lock of availability should not be on impediment to beginning on audit. Even in the above examples, which are not intended to be all inclusive, the material set forth in Section 4.3.1 is normally covered during the course of the audit.

12) With regard to Section 4.3.2 of ANSI N45.2.12 - 1977 titled Audit Process:

F, C a) Subsection 4.3.2.2 could be interpreted to limit audits to the review of only objective evidence; sometimes and for some program elements, no objective evidence may be available. FPC shall comply with an alternate sentence which reads

"When available, objective i evidence shall be examined for compliance with Quality Program l requirements. If subjective evidence is used (e.g. personal interviews, direct observations by the auditor), then the oudit report must indicate how the evidence was obtained.'

B, C b) Subsection 4.3.2.4 is modified as follows to take into account  ;

l the fact that some nonconformances are virtually " obvious" with i respect to the needed corrective action: "When a nonconformance or

. Quality Program deficiency is identified as a result of an oudit, unless the appcrent cause, extent, and corrective action are readily evident, further investigation shall be conducted by the audited orgottization in an effort to identify the cause and effect and to j determine the extent of the corrective oction required." k t

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NRC Reculatory Guide I.I44 (Continued)

F, S-3 c) Subsection 4.3.2.5 contains a recommendation which is clarified 55 with the definition of "ocknowledged by a member of the audited organization" to mean that "a member of the audited organizatica has been informeo of the findings." Agreement or disagreement with a finding may be expressed in the response from the audited organization.

F, C d) Subsection 4.3.2.6 is modified as follows to account for the fact  !

that immediate notification is not always possible: " Conditions requiring immediate corrective action (i.e. those which are so severe that any delay would be undesirable) shall be reported as soon as practical to monogement of the audited organization."

F, 5-7 13) With regard to Section 4.3.3 of ANSI N45.2.12 - 1977 titled Post-Audit Conference: FPC shall substitute and comply with the following parograph: "For all external oudits, a post-oudit conference shall be held with monogement of the audited organization to present audit findings and clorify misunderstandings; where no adverse findings exist, this conference may be waived by management of the audited organization: Such waiver shall be documented in the audit report.

Unless unusual operating or maintenance conditions preclude attendance by appropriate managers /supervi: ors, a post-oudit conference shall be held with managers / supervisors for all internal 4

oudits for the some reasons os above. Again, if there are no adverse findings, the monogement of the internal audited organization may waive the post-oudit conference: Such wolver shall be documented in the audit report."

14) With regard to Section 4.4 of ANSI N45.2.12 - 1977 titled Reperting:

F, C a) This Section states that the audit report shall be signed by the audit team leader; this is not always the most expeditious route to take to assure that the audit report is issued as soon as'proctical.

FPC shall comply with Section 4.4 as clarified in the opening: "An audit report, which shall be signed by the audit team leoder, or his supervisor in his obsence, shall provide:" In cases where the audit report is not signed by the Lead Auditor due to his obsence, one record copy of the report must be signed by the Lead Auditor upon his return. The report shall not require the Lead Auditor's review / concurrence / signature if the Lead Auditor is no longer employed by FPC of the time the audit report is issued.

S-7 b) FPC shall comply with Subsection 4.4.3 clarified to read:

" Supervisory level personnel with whom significant discussions were held during the course of pre-oudit (where conducted), oudit, and post-oudit (where conducted) activities."

E c) Audit reports may not necessarily contain on evaluation statement regarding the effectiveness of the quality assurance program elements which were audited, as required by Subsection 4.4.4, but they shall provide o summary of the audited areas and the I results.

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+ NRC Regulatory Guide 1.144 (Continued) 4.4.6 requires oudit reports to include 55 d) Subsection recommendations for corrective actions; FPC may choose not to comply with this requirement. Instead, FPC auditors /leod auditors are required to document all adverse findings on Audit Finding Reports (AFRs). The procedure for processing AFRs allows the -

ouditor/ lead auditor to document actions which are considered necessary to correct the finding; the auditor / lead auditor may also ,

document actions which are considered unocceptable for correcting the finding: The AFR with these " Auditor Recommendations" is then transmitted to the audited organization. In addition, the auditor / lead auditor is required to review the response to the AFR and determine if it is acceptable. Any disagreements must be escalated to higher management for resolution via the Nonconfctmonce Report (NCR) process.

I e) The lost paragraph in Section 4.4 deals with distribution of oudit reports. FPC shall comply with these requirements after substituting the following for the lost sentence: "The audit report shall be issued within thirty working days' after the last day of the audit."

E, I, C 15) -With regard to Section 4.5.1 of ANSI N45.2.12 - 1977 titled By Audited Oraanization: FPC shall comply with the following clarification of this Section: " Management of the audited organization or activity shall review and investigate all adverse audit findings, os necessary, (e.g. where the cause is not already known or another organization

, has not already investigated and found the cause, etc.) to determine and schedule oppropriate corrective action (which includes oction to prevent recurrence). They shall respond, in writing, within thirty working days af ter the date of issuance of the audit report. The response shall clearly state the corrective action token or planned to prevent recurrence and the results of the investigation, if conducted.

In the event that corrective action is not completed by the time the response is submitted, the audited organization's response shall i include a scheduled date for completion of pionned corrective action:

A followup response shall be provided stating the corrective action to!<en and the date that the action was completed. If corrective actions are verified as satisfactorily completed by the quality organization prior to the scheduled completion date, no followup response is required. The audited organization shall take appropriate action to assure that corrective action is accomplished as scheduled.

Either the Director, Quality Programs or the onsite QA Supervisor

. may waive the requirement for o supplementory response.

A, S-3 16) With regard to Section 5.1 of ANSI N45.2.12 - 1977 titled General

FPC shall maintain records in occordance with and to meet the requirements of Section 1.7.1.17 of the OGAP and ANSI N45.2.9 as specified in Table 1-3. (See also item 4 obove.)

I-127

NRC Regulatory Guide 1.146 " Qualification of Quality Assurance Program 55 Audit Personnel for Nuclear Power Plants" (Rev. O, 8/80) - Endorses ANSI N45.2.23 - 1978 The Quality Program (OOAP) complies with the requirements of this Guide with the following clarifications:

A I) With regard to Section 1.4 of ANSI N45.2.3 - 1978 titled Definitions: i Definitions in this Standard which are not included in ANSI N45.2.10  !

shcIl be used; " Audit" which is included in ANSI N45.2.10 shall be used as clarified in FPC's comments to Regulatory Guide 1.74.

S-4 2) With regard to Section 2.2 of ANSI N45.2.23 - 1978 titled Qualification of Auditors: Subsection 2.2.1 references on ANSI B45.2 (presumed to be ANSI N45.2); therefore, FPC shall comply with an alternate Subsection 2.2.1 which reads: " Orientation to provide a working knowledge and understanding of the OQAP, including the ANSI Standards and Regulatory Guides included in Table 1-3 of that

Program, and FPC's procedures for conducting audits and reporting results."

F 3) With regard to Section 3.2 of ANSI N45.2.23 - 1978 titled Maintenance of Proficiency: FPC shall comply with the requirements of this Section by. defining " annual assessment" as one which takes l place every 12 + or - 3 months and which may use either the initial date of certification or the calendar year in which an auditor / lead auditor was certified as basis for determining when an annual assessment is due.

B, F 4) With regard to Sect!on 4.1 of ANSI N45.2.23 -

1978 titled Organizational Responsibility: FPC shall comply with this Section j with the substitution of the following sentence in ploce of the last sentence in the Section. "The Director, Quality Programs, Audit Supervisor, or Lead Auditor shall, prior to commencing the audit, assign personnel who collectively have experience or training

, commensurate with the scope, complexity, or special nature of the activities to be audited."

S7 5) With regard to Section 5.3 of ANSI N45.2.23 - 1978 titled Updatino of Lead Auditors' Records: FPC shall substitute the following sentence for this Section: " Records for each Lead Auditor shall be maintained and updated during the period of the annual management assessment as defined in Section 3.2 (as clarified)."

A,S-3 6) With regard to Section 5.4 of ANSI N45.2.23 - 1978 titled Records Retention: FPC shall substitute the following sentence for this Section: "Qualificotton records shall be generated and maintained as required by Sections 1.7.l.2,17, and 18 of the OQAP and by 4

commitment to ANSI N45.2.9 as set forth in Table I-3 of that Program."

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9 ATTACHMENT B e

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Attachmsnt B Reasons and Rationale for Chances to the FPC Guality Program Description F!crida Power Corporation (FPC) insists on quality in its management and operation of Crystal River Unit 3. This commitment to quality is represented by l

FPC's Quality Program (Operational).

This Quality Program has undergone o detailed and critical review by FPC monogement. This review included comparison of the Quality Program description with 10 CFR 50 Appendix B, the NRC's Standard Review Plan and the Regulatory Guides and ANSI Standards to which FPC is committed. Based on this review, we conclude that the current Quality Program description continues to satisfy the criterio of 10 CFR S0, Appendix B and the Quality Program description commitments previously accepted by the NRC.

Changes to the Quality Program description which have been made are constructive in nature and do not reduce the effectiveness of the program.

Editorial changes have been made. Provisions which serve os bases for compliance with the requirements of Appendix B or which represent additional / upgraded FPC commitments to Regulatory Guides and ANSI Standards have been added.

Changes have been made to establish a single point of reference and thereby facilitate the understanding, tracking and control of requirements. Towards this purpose, changes have been mode to eliminate redundancy within the Quality Program description; to reference the Tecnnical Specifications where it estohiishes program requirements; and, to consolidate the description of FPC's commitment to Regulatory Guides and ANSI Standards in Table 1-3.

i Other changes have been mede to eliminate detail that is far in excess of that colled for in the criteria of Appendix B. This level of detail is more properly contained in implementing documents. Deletion of this detail does not result in a reduction in requirements.

All changes which have been mode to the Quality Program description previously accepted by the NRC are marked in the current Quality Program description (Attochment A) with a vertical line in the margin. For the purpose of this submittal the change lines are annotated to correspond with additional discussion below supporting the acceptability of the changes. Change lines ossoelated with editorial changes are not annotated unless the editorial changes occur ,

simultaneously with other changes.

Editorial Changes l Editorial changes mode to the Quality Program description include correction of t spelling and punctuation; revision of section and paragraph numbering; I

modification of verb tense to reflect implementation of the program; and, deletion of references to the preoperational Quality Program description which l

ore not applicable to the Quality Program (Operational). The word "oll" has been l

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l I

I

deleted where it does not specifically and correctly contribute to the extent or scope of a requirement. The Justification in these cases is that it may be interpreted to preclude acceptable equivalent methods or include activities not intended to be subject to the Quality Program. FPC's Quality Program is well defined and the use of "all" in most cases is unnecessary.

1 Editorial changes otso include the deletion of specific position / organization titles in situations where the requirements or activities discussed could very well apply to other positions / organizations. The Quality Program description includes the requirement that FPC has established the functional responsibilities and authorities of positions / organizations involved in the Quality Program. FPC reserves the right to control these assignments within the requirements of the program.

Generic Chonoes Certain changes or portions of changes are common and occur throughout the Quality Program description.

The statement of requirements for oudits to assure compliance with the Quality Program har been deleted from most sections. These are redundant statements to the requirements of the Audit program as described in Section 1.7.l.18. Such changes are marked " audit".

All references to Regulatcry Guides and ANSI Standards include the reference to Table 1-3 os port of establishing a single point of reference. Such changes are marked " table". The endorsement of on ANSI Standard includes the endorsement of the associated Regulatory Guide. The justification for changes ossociated with Table 1-3 is provided in the discussion of Change 55.

Other Changes (Numbered) j l. The previously accepted description of FPC's Quality Program for the operational phase of Crystal River Unit 3, was in FSAR Section 1.7 olong with the description of the Quality Program for all aspects of the preoperational phase. In 1982 the organization of the FSAR was modified such that the Quality Program opplicable to the preoperational phase is in FSAR Section 1.6 and the Quality Program for the operational phase is in FSAR Section 1.7. A statement has been added to the introduction to indicate that Section 1.7 contains the description of the FPC Quality Program for the operational phase.

The reference to position descriptions in Section 1.7.S.1.1 hos been deleted since these descriptions are now provided in Section 1.7.I.1, Organization.

The reference to individual qualifications has been moved to Section 1.7.1.l.

2. The remainder of the statements in the previously accepted introduction l

have been deleted based on our efforts to reduce redundancy and organize l

the Quality Program description in line with Appendix B and the SRP. The

' statements regarding document controls and Quality Program training were deleted since these programs are described in Sections 1.7.f.6 and 1.7.l.2 respectively. The statements regarding FPC's responsibility for the l

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• Quality Program, the term of responsibility, and the performance of maintenance or modifications have been moved to Sections 1.7.1.1, 1.7.l .2, and 1.7.1.3 respectively.

3. The reference to organization responsibility descriptions elsewhere in Section 1.7 has been deleted since these responsibilities are now described in this section. The reference to Appendix 12A for personnel qualifications -

and the statement of FPC's responsibility for the Quality Program have been added (see changes I and 2).

The statement that FPC personnel implement the Quality Program in the some manner as FPC requires of its contractors has been deleted. This statement stems from o philosophy applicable during the preoperational phase and not the operational phase. FPC personnel implement the Quality Program described in FSAR Section 1.7. Quality assurance related to contractor activities is controlled as described in Sections 1.7.l.4 ond 1.7.l.7.

4. Discussion of the Quality Program staff has been deleted. The responsibilities of this staff are oddressed in Section 1.7.3.

5. The statement regarding qualification requirements for positions responsible for directing and monoging the Quality Program has been deleted. Qualification requirements applicable to the quality assurance organization (both onsite and offsite) are specified in Table 1-3, Regulatory Guides 1.8 and 1.146, and qualifications for the positions listed in this section are summarized in Appendix 12A of the FSAR.

The porographs regarding the responsibilities of Reoctor Operators, Shift Supervisors and the Operations Superintendent contain requirements which are more appropriately stated in the implement!ng documents of the Quclity Program. FPC's Administrative Instruction Al-500, Conduct of Operations, and its referenced implementing procedures contain the i

requirements of these parographs including the responsibilities and authorities for shutdown and restart of the reactor (including shutdown when RPS setpoints are exceeded and automatic shutdown does not occur);

the responsibility to believe and respond to instrument indications and adhere to Technical Specificottons; and the responsibility for review of routine operations. Based on the above and FPC's continuing commitment to Regulatory Guide 1.33 as specified in Table 1-3, the subject FSAR prographs have been deleted.

6. The summary of functional responsibilities and authoritics has been odded 4 so that Section 1.7 presents a complete description of the FPC Quality Program for the operational phase. The FPC organization continues to provide the positions performing quality assurance functions with the authority, independence and access to management necessary to assure effective implementation of the Quality Program.

7. The definition of the operational phase has been odded (see change 2).

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8. The statement that the Quality Program meets the requirements of 10 CFR 50, Appendix B hos been added. This statement, when coupled with the statement that the program meets the requirements of Regulatory Guides and ANSI Standards os defined in Table 1-3 (see change 15), presents the regulatory requirements which serve as a basis for the Quality Program.

The sentence regarding compliance with the program has been modified to correctly relate this compliance with persons performing quality octivities. ,

The statement regarding records and test dato hos been deleted since the '

requirements for records and test data are specified, as appropriate, in other sections (e.g. l.7.l.9, i.7.1.10,1.7.l.ll, and 1.7.l.17).

9. The requirement to train and qualify personnel in the principles and techniques of the activity being performed has been modified to indicate that personnel will be trained and qualified in the activity being performed.

Specific training and qualification requirements for positions performing quality-related activities are specified elsewhere such as in Toble 1-3 and the Technical Specifications. There is no apparent benefit to summarizing two aspects, " principles and techniques",' of training and qualification programs in this statement. Furthermore a brood but improper interpretation of " principles and techniques" could exceed the octual requirements of approved training and qualification programs. Therefore

" principles and techniques" has been deleted.

10. The statement of FPC's commitment to housekeeping and cleanliness 4

controls, including the applicable ANSI Standards, has been added, ll. A summary of quality control related responsibilities and requirements has been added to the Quality Program section. This summary as well as other elements of the Quality Program are used to justify deleting the separate discussion of quality controls from the previously occepted Quality Program description (see change 51).

12. A statement has been odded to identify, by reference, the structures, systems, and components covered by the Quality Program. The statement of opplicable structures, systems, and components in FSAR Section 1.6.4 (preoperational phase) is unchanged and is included in the Quality Progrcm for the operational phase by the oppropriate reference. To supplement this general description of equipment covered by the program we have odded a reference to our "Sofety Listing" and Indicated that we may apply the Quality Program requirements to other equipment and activities.

13. Statements have been odded to indicate some of the methods used by FPC to review the status and adequacy of its Quality Program. This is in ogreement with the organization and requirements of 10 CFR 50 Appendix B.

14. A statement has been added to allow a period of time between a change to the Quality Program description and the necessary changes in implementing procedures. This period of time will permit the revision of oppropriate implementing procedures in a controlled and effective manner such that the revisions are truely responsive to the change in Quality Program requirements.

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15. A specific reference to FSAR Section 1.7.2, Program Commitment, and Table 1-3, which define FPC's Quality Program commitments to Regulatory Guides and ANSI Standards, has been odded in place of the general reference to applicable Regulatory Guides and ANSI Standards.

16. The referente to ANSI N18.7-1976, Section 5.2.7.2 regarding design octivities associated with modifications, has been revised to ANSI N45.2.ll.

This provides a direct reference to the controlling Standard. The genero!

discussion of engineering reviews and the establishment of modifiotion packages for both safety related and non safety related modifications does

> not enhance or modify the commitment to ANSI N45.2.ll. Section 7) of Table 1-3, Regulatory Guide 1.64 oddresses timing of design verifications.

In addition the discussion of non safety related modifications is beycnd the scope of this Quality Program description which demonstrates compliance with the requirements of 10 CFR 50 Appendix B. While it is true that, in general, modifications undergo on engineering review and for non safety related modifications, this review ma take place offer the fact, deletion of these statements from the uo ity Program description does not represent a reduction in commitment, i 17. Statements regarding the performance of maintenance or modifications have been added (see change 2).

18. FPC is committed to the requirements of ANSI N45.2.13, as defined in Table 1-3. Section 3.3 of that Standard contains the requirements for procurement document review. By meeting the requirements of ANSI N45.2.13, FPC assures that all discrepancies are resolved prior to purchase.

Therefore the redundant statement to this effect has been deleted.

19. The requirement to review suppliers' quality programs prior to implementation more correctly belongs in Section 1.7.l.7, Control of Purchased Material, Equipment, and Services. Therefore this statement hos been deleted (see change 28).

20&

21. The extensive listings of exomptes of basic technical requirements and documentation requirements, which may be contained in procurement documents, os well as details regarding the evaluation and selection of suppliers are more oppropriately stated in the implementing documents of the Quality Program and have been deleted. These examples and details are contained in the opplicable sections of FPC's Nuclear Procurement and Storage Manual. FPC's commitment to ANSI N45.2.13 assures that these deletions do not represent a reduction in commitments.

22. The statements regarding the use of procedures have been co'solidated.

i The control of nonconformances is discussed in Section 1.7.1.l5. Therefore i

this redundont statement hos been deleted.

23. The requirement that procedures be strie.tly odhered to in all matters i relating to nuclear safety could be improperly interpreted as a requirement to always . .ove procedures present and followed step by-step and, 5

therefore, has been modified. As now stated, FPC has identified tasks during which written procedures are present and followed step-by-step.

These tasks are identified in Administrative instruction Al-500 and implementing procedures. FPC requires adherence to procedures, in all matters related to nuclear safety, consistent with the requirements of ANSI N18.7 as defined in Table 1-3.

24. The ~stotements or;d porographs regarding the use of checkoff lists, dato collection sheets, emergency and abnormal procedures cnd other procedures contain details which are more oppropriately stated in implementing documents of the Quality Program. FPC's Administrative Instructions Al-400 and Al-500 and implementing procedures contain the requirements for use of the subject documents. FPC's commitment to ANSI NI8.7 assures that these deletions do not represent a reduction in commitments.

Temporary changes to procedures are controlled in accordance wl;h the requirements of Section 6 of the Technical Specifications. Therefore the statement regarding this subject hos been deleted.

The statement regarding housekeeping and cleanliness controls has been odded to Section 1.7.I.2.

25. The description of documents subject to FPC's document control system hos been more broadly and occurately stated as " documents which prescribe activities offecting quality". The requirement that records are entered into the files in accordance with written procedures is stated in Section 1.7.1.17.

, 26. FPC wishes to reserve the management flexibility to issue instructions, l procedures, and drawings and revisions thereto which do not necessarily j oppear on a master list. Also the capability must exist to revise documents

' which are contained on lists, prior to updating the lists, os long as the

( current revision is identified to offected personnel. All documents and revisions subject to FPC's document control system are controlled per Section 1.7.l.6(4), (5) and (7) which assures that the current revision of instructions, procedures and drawings is used for octivities offecting quality.

27. The control of procedures per Regulatory Guide 1.33 has been odded to indicate additional commitments per Toble 1-3 and the Technical Specifications.

28. The statement regarding evoluotion of suppliers' quality programs has been odded (see change 19). The reference to ANSI N45.2.13 is oppropriate and hos been added.

29. The methods ovallable to FPC for assuring that quality requirements are met have been more occurately stated as source inspection, receipt inspection, or document review as appropriate. This is consistent with

! FPC's commitment to ANSI N18.7 and ANSI N45.2.13. -

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30. An introduction indicating that FPC hos established measures for the identification and control of materials, parts, and components has been added.

31. " Subassemblies" is not defined in ANSI N18.7 or ANSI N45.2.10. " Assembly"

!- is defined in ANSI N4S.2.10 as o combination of subassemblies or components, or both, fitted together to form o unit. As used in this FSAR statement, partially fabricated assemblies represents identification and control requirements to the subassembly and component level. -Therefore use of defined terms represents on adequate level of equipment identification and control.

32. Chemical cleaning has been added as an example of the types of special, processes subject to controls by FPC.

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33. Approved written procedures specify the documentation requirements and applicable forms for special processes.

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34. FPC's qualification requirements for inspection personnel are based on the requirements of applicable Regulatory Guides, corresponding ANSI Standards and .the Crystal River Unit 3 Technical Specifications.

Regulatory Guides 1.8, l.S8 and 1.146, as described in Table 1-3, and Section j 6 of the Technical Specifications contain the complete statement of FPC's qualification requirements for inspection personnel. In addition, Table 1-3 discusses the bases for these requirements.

35. Statements regarding the use of process monitoring, alone and in combination with inspection, and the use of inspection hold points have been added to indicate aspects of FPC's Quality Program which serve os bases for compliance with 10 CFR S0 Appendix B. The statement regarding inspections performed after initial inspections is ambiguous and has been deleted. FPC's commitment to the requirments of ANSI N18.7, section S.2.17 assures that inspections of modifications and maintencnce adequately consider the initial inspection requirements.

l 36. " Operational tests" has been added to reflect that Crystal River Unit 3 is 1

in the operational phase.

37. A statement regarding the evaluation of test results has been added to indicate an ospect of FPC's Quality Program which serves os a basis for compliance with 10 CFR SO Appendix B.

38. FPC has expanded the references to applicable Standards and the Technical Specifications to provide a complete reference. The bases for other changes to this introduction are discussed earlier in those paragraphs which oddress editorial and generic type changes.

39. FPC desires to maintain a management option to accept calibration " prior to use" of that measurement and test equipment for which this is on effective means of control. Such equipment might include that used infrequently or at non-periodic intervals. This option continues to assure that calibrated measurement and test equipment is used.

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40. Records requirements have been deleted as a highlighted ospect of FPC's measurement and test equipment controls program since recordkeeping requirements are spec.ified in Section 1.7.1.17, the Technical Specifications and applicable ANSI Standards referenced in the introduction to Section 1.7.1.17.

41. Specific exceptions to ANSI N45.2.2 have been replaced by reference to this Standard as defined in Table 1-3. Clarification of specific aspects of this Standard are discussed in change 55.

42. Reinspection as originally inspected or at least equal to the original inspection method is too brood a statement of the requirement. FPC wishes to maintain the flexibility to specify inspection requirements which

. odequately assure that original design requirements are met while taking into consideration the extent of the rework or repair. The modified statement of this program provison meets the requirements of ANSI NI8.7 Section 5.2.14.

43. A provision of FPC's program regarding the identification and correction of conditions adverse to quality has been added to represent the basis for FPC's compliance with 10 CFR 50 Appendix B.

44. " Training records" has been odded as an example of quality assurance records to represent FPC's commitment to treat training records os such.

45. Reference to ANSI N45.2.9 has replaced N18.7, Section 5.2.12 te present a direct reference to the controlling Standard.

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46. This statement has been broadened to nddress those quality assurance records maintained as single copy records. Furthermore, the duplicate set of information maintained by FPC does not have to be microfilmed to

< satisfy the intent of maintaining a duplicate set of records. FPC commits

! to the requirements of ANSI N45.2.9, os defined in Table 1-3, for storoge of quality assurance records.

47. The discussion regarding the review of oudit results has been deleted here because this review is odequately addressed in statements added to Sections 1.7.1.1 (change 6) and 1.7.l.2 (change 13); in FPC's commitment to Regulatory Guide 1.144 as described in Table I-3; and in provision 3 of this section.

48. FPC wishes to retain management flexibility in determining when reouditing is necessary. The criteria contained in this modified statement will be used in making such determinations. This position comp"es with j the requirements of ANSI N18.7 Section 4.2

49. The Technical Specificottons contain the requirements for audit frequency and this statement hos been modified accordingly.

i 50. This statement has been odded to reflect FPC's commitment to Regulatory l Guide 1.146.

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51. The statement that the issue date of a Standard committed to takes presedence over ANSI Standards referenced in ANSI NI8.7 is repetitious when compared to the balance of Section 1.7.2 and Table 1-3. Therefore it has been deleted.

The discussion of quality control has been deleted. The requirements in this discussion are stated elsewhere in the Quality Program description inc!uding management responsibilities (Section 1.7.1.1), Plant Review Committee responsibilities (1.7.l.I), applicable equipment (Section 1.7.l.2),

indoctrination and training program (Section 1.7.1.2), the independence of personnel performing the quality control function (Section 1.7.1.2) and performance in accordance with approved written procedures (Section 1.7.l.2 and 1.7.1.5). As on element of FPC's Quality Program the quality control function is subject to requirements of the Quality Program.

Therefore deletion of this discussion does not represent a reduction in FPC's previnusly accepted commitments or an exception to the requirements of 10 CFR 50 Appendix 8.

52. This section has been expanded to indicate that others, in addition to the Quality Programs Department staff, perform quality assurance activities.

The requirement that the Quality Programs Department maintain records of audit results has been moved to Section 1.7.I.18.

53. The responsibilitie s and authorities of the NGRC in performing the independent review function are described in Section 1.7.1.1.

54. FPC has retained the definitions of " Quality Control" and " Quality Activity" (previously " Quality Function") from the accepted FSAR description of the Quality Program. FPC has defined the other terms used in its Quality Program by reference to applicable Standards as defined in Table 1-3. This provides a means of assurance that each term will have but one definition.

55. Justification and Rationale for Clarifications to Standards Listed in Table 1-3 of the Crystal River #3 FSAR.

During our review of the various Standards and Regulatory Guides endorsed by FPC, certain requirements were found to need cicrification in order to ensure that the Quality Program could be readily understood and implemented. These clarifications generally resulted from generic concerns or were based on specific circumstances at Crystal River Unit 3.

The specific line of reasoning or rationale which prompted each of our clarifications is listed below. Items A through I are generic; items S-l through S-9 are based on specific circumstances at Crystal River Unit 3; cnd items NRC-l through NRC-il are based upon published USNRC QA positions or statements.

In the left hcnd margin beside each clarification in Table 1-3, a designation has been inserted. This designation corresponds to the generic or specific justification listed below. In some instances, a particular clarification was made for several reasons. In these cases, the designation for each of the major contributing reasons has been indicated.

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The fundamental concept behind nll of the clarifications is this: An easily understood, workable program has the highest probability for successful implementation. The FPC commitment to quality depends upon each person within the nuclear function knowing and performing thct portion of the . Quality Program for which he or she is responsible. Such a commitment-demands personal involvement by our employees, but it also requires an enlightened management team with a Quality Program dynamic enough to allow change when experience indicates that there is a better way of doing business. Thus each of our changes hos been made in order to make our Quality Program relevant to those who implement it, based on our own or the experience of other utilities within the nuclear industry.

On the basis that all of the clarifications are made within the constraints of 10 CFR 50, Appendix B; and all that are applicoble to the operational phase provide on equivalent alternate to that specified in the original commitment; FPC concludes that: (1) the changes do not reduce the commitments in the program description previously accepted by the NRC (per 10 CFR 50.54(aX3)); and (2) the revised program incorporating the changes continues to satisfy the criteria of Appendix B (per 10 CFR i 50.54(oX3Xii)).

Generic A. A Single Point of Reference Most of the GA Standards were developed, initially, on a concurrent

basis. Thus each covered precedures, records, qualifications of personnel, audits and definitions. Specific standards were later issued which covered these areas in detail. In other cases, subsequent NRC occepted documents (Standard Technical Specifications (STS),

Security Plans, TMI Action Plan items) superseded items in a particular Standard.

To comply with our general philosophy of an " understandable" l program, FPC has opted for a single point of reference where we will define how on activity is to be accomplished. This also requires that the selected point be the most logical. For example, commitments relative to records will be in the records standard; audits in the audit standard; definitions in the definition standard. Since Technical Specifications are the most widely known and accepted " standard" during the operational phase, this location always received priority.

B.- Broad Requirements (Too " General" or "All Encompassing")

Certain paragraphs or sections within some Standards could be interpreted to require a specific practice under all conditions since there is no delimiting language within the requirement statement. As on example, preplanning of maintenance is a desirable requirement, but not in an emergency where time does not permit such a deliberate approach. In these cases, FPC has stated which conditions 10 l

x are expected or has added limits to the requirement statement. In all cases FPC hos preserved the practical intent of the Standard.

C. Clarification Contains Justification in some cases, the logic or rationale is included within the clarification itself. This was done to provide FPC personnel (who would not normally see the justification sent to the USNRC) on insight -to ensure consistent application- by giving the underlying principal behind the actual words or phrases used.

D. Do Not Specify "How", Only "What" In many instances, the Standards give requirements for "what" must be accomplished but do not specify "how": Generally these instances were not clarified. However in some cases we have documented our opproach to give guidance to our personnel on how FPC management wishes the activity to be accomplished.

E. Excessively Restrictive or Prescriptive Some requirements were written in such a manner that only one of many equally acceptcble methods is allowed. In these cases, FPC l wishes to retain the management flexibility to comply with the regulations in other acceptable ways. Clarifying language was used either in place of or to modify the Standards' requirements.

F. Flexibility Possibly inhibited These cases are similar to those described under item E obove except that the statement witnin the Standard would be excessively restrictive or prescriptive only with one, very narrow, interpretation of the language. FPC defined the word or words which could be l misconstrued to preclude such on interpretation and to clearly l express our intention for compliance.

l G. Generic Clorification (Similar to that in USNRC Regulatory Guides)

This clarification applies to all FPC commitments in Table 1-3 and is based on language in several USNRC Regulatory Guides and covers two aspects: First, FPC commits -os clarified- to a particular Standard, but unless a specific commitment is made elsewhere, FPC does NOT commit to documents referenced within or appended to the Standard; Second, FPC commits to construction type Standards (or certain construction type sections within a Standard) only for construction type activities. The words "similar in nature and extent to construction activities" embrace the USNRC's interpretation of applicability in these oreos.

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• , e H. Have No Applicability to FPC Operational Activities A small portion of the requirement statements in the Standards have no applicability to quality, safety, legality or efficiency of our operations. We have so stated in Table 1-3.

l. Increasing Scope This classification is used primarily with definitions, in some cases, the definitions used in Standards are too restrictive to allow the variety of documents and activities which our personnel commonly group under these designations. In these ecses, FPC has clearly defined what is included in our scope of work or word definition.

Crystal River Specific S-1 Loss Prevention This clarification is taken for ANSI N45.2.2-1972. The " protection" requirements for Level D items specified in the Standard deal with prevention of loss, not maintenance of quality. FPC may choose to accept a risk of loss in lieu of providing a protection system for Level D items. Normally such items are stored within a fenced-in portion of the Crystal River site, but FPC wishes to retain the option for storage at other locations.

S-2 Personnel Qualifications This clarification deals with the qualification of personnel or the method of documenting the qualifications of personnel. FPC is committed to o program which always uses qualified personnel, but also to one which recognizes that individual talent is not always directly related to completion of academic training. FPC management e:es the method, described each time this justification is used, to assure itself that oppropriately trained / qualified personnel are used.

S-3 Comparable FPC Program This clarification is used whenever FPC has a program which is established to meet the intent of the program / activity specified in the Regulatary Guide or Standard. FPC uses its program to meet the one specified.

S-4 ANSI N45.2 Most of the Standards are construction standards and reference ANSI N45.2. Since ANS! N45.2 has been replaced by ANSI N18.7 for the l

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operational phase, this clarification is invoked each time ANSI N4S.2 is used.

S-S Requirements on Suppliers Some Standards / Regulatory Guides require that requirements be imposed upon FPC's suppliers. In each of these cases, FPC has specified that its procurement process shall impose these requirements when necessary to assure quality consistent with the importance of the item or service to nuclear safety.

S-6 Updating to Later Requirements in the cases where this designation is used, FPC wishes to upgrade its Quality Program to later consensus Standards which have been developed and published by the nuclear industry but which have not yet been endorsed by the NRC in a published Regulatory Guide.

Since the Standard Review Plan (NUREG-0800) requires either a commitment to published Regulatory Guides or acceptable alternate methods for meeting a requirement, FPC has selected only specific sections rather than committing in total to on unendorsed Standard.

The specific sections of the Standards are referenced within the clarification.

S-7 Exercising of a Management Prerogative Clarifications in this category are simple statements of the management prerogative that FPC intends to exercise. The actions described are usually not explicitly addressed in the Standard.

However without such a clarification, some different actions might be assumed as part of FPC's commitment to follow the Standard.

S-8 Defining a CR-3 Specific Word / Term This clarification is made when a specific word or term, not clarified in the Standards, is used in the Quality Program. Such definitiens are added to assure on understanding of the Quality Program requirements.

S-9 No Commitment without Evoluotion This justification is used when FPC takes exceptions to on NRC change of a recommendation in a Standard to a requirement. Such on exception is justified because FPC is vo!untarily increasing the commitments in the Quality Program. While FPC wishes to meet the latest NRC guidance, insufficient dato is available to allow FPC management to determine whether the NRC's " tightening" of recommendations produces on increase in safety, reliability or quality commensurate with the increased effort to meet the new requirements.

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e USNRC Positions N-1 N45.2.5-1974 (Source of Concrete Test Somptes)

The words used are based on o GA Branch interpretation (OAB #3) issued in a memorandum dated July 1975. (Based on APCo's position in the Barton PSAR).

N-2 N45.2.ll-1974 (Documentation of Design Reviews)

The words used are based on a QA Branch interpretation (QAB #8) Issued by C. J. Heltemes, Jr. In a memorandum dated July 26,1977. (inquiry l}

N-3 N45.2.ll-1974 (Use of initials)

The words used are based on o QA Branch interpretation (OAB #8) issued ,

by C. J. Heltemes, Jr. In a memorandum dated July 26,1977. (Inquiry 2)

N-4 N45.2.ll-1974 (Timeliness of Design Verifications)

The words used are based on a QA Branch interpretation (QAB #10) issued by C. J. Heltemes, Jr. In a memorandum dated April 5,1977.

N-5 N45.2.ll-1974 (Interdisciplinary Review Documentation)

The words used are based on a QA Branch interpretation (QAB #12) issued by W. P. Hooss in a memorandum dated May 20,1980.

N-6 N45.2.12-1977 (Frequency for Supplier Audits)

The words used are based on o QA Branch interpretation (OAB #9) issued by C. J. Heltemes, Jr. in a memorandum dated December 23,1977.

N-7 N!8.7-1976 (Design and Construction Activities During Operations)

The words used are based on a QA Branch interpretation (QAB #7) issued by C. J. Heltemes, Jr. In a memorandum dated April 5,1977.

N-8 N45.2.5-1974 (Bolt Length Beyond Nut)

Based on NRC occepted exception in the SNUPPS PSAR, Chapter 17A.0, N-9 N45.2.I3-1976 (Position on Nonconformance Disposition) '

Based on NRC occepted position in the GESAR.

N-10 N101.4-1972 Based on NRC's withdrawal of this Standard from Chapter 17.2,of the SRP.

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o, N-Il N45.2.ll-1974 The words used are based on a GA Branch Interpretatica (GAB #6) issued by C. J. Heltemas, Jr. in a memorondum dated December 2,1976.

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Mr. J.P. O'Reilly 3F-0683-01 cc w/ attachment Document Control Desk U.S. Nuclear Regul atory Cen :i ssion Washington, DC 20555 Mr. Tom Stetka Regional Inspector U.S. Nuclear Regul atory Conni ssion Crystal River Unit #3 Crystal River, FL -

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