ML21168A339

Virgil C. Summer Nuclear Station, North Anna Power Station, Surry Power Station -Submission of Revision 30 of the Quality Assurance Topical Report

ML21168A339
Person / Time
Site:	Millstone, Kewaunee, Summer, Surry, North Anna, 07200002, 07200055
Issue date:	06/17/2021
From:	Mark D. Sartain Dominion Energy Kewaunee, Dominion Energy Nuclear Connecticut, Dominion Energy Services, Dominion Energy South Carolina, Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
21-170
Download: ML21168A339 (144)

Text

Dominion Energy Services, Inc.

5000 Dominion Boulevard, Glen Allen, VA 23060 Dominion Energy.com Dominion Energy June 17, 2021 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 DOMINION ENERGY KEWAUNEE, INC.

DOMINION ENERGY NUCLEAR CONNECTICUT, INC.

DOMINION ENERGY SOUTH CAROLINA, INC.

VIRGINIA ELECTRIC AND POWER COMPANY Serial No.:

NRA/MLW:

Docket Nos.:

KEWAUNEE POWER STATION AND ISFSI License Nos.:

MILLSTONE POWER STATION UNITS 1, 2 & 3 AND ISFSI VIRGIL C. SUMMER NUCLEAR STATION UNIT 1 AND ISFSI NORTH ANNA POWER STATION UNITS 1 & 2 AND ISFSI SURRY POWER STATION UNITS 1 & 2 AND ISFSI SUBMISSION OF REVISION 30 OF THE QUALITY ASSURANCE TOPICAL REPORT 21-170 R2 50-305 50-245/336/423 50-395 50-338/339 50-280/281 72-47 72-16/56 72-2/55 72-64 DPR-43 DPR-21/65 NPF-12 NPF-49 NPF-4/7 DPR-32/37 SNM-2507 SNM-2501 Pursuant to 10 CFR 50.71{e), attached is the required periodic update of the Nuclear Facility Quality Assurance Program Description Topical Report, DOM-QA-1, Revision 30, for Dominion Energy Kewaunee, Inc. {DEK), Dominion Energy Nuclear Connecticut, Inc.

(DENG), Dominion Energy South Carolina, Inc. (DESC), and Virginia Electric and Power Company (Dominion Energy Virginia). The previous periodic update dated June 29, 2020 provided Revision 28 of the Nuclear Facility Quality Assurance Program Description Topical Report to the Nuclear Regulatory Commission (NRG).

i

• Attachment 1 provides a summary of changes made to DOM-QA-1 under the provisions of 10 CFR 50.54 since the previous submittal on June 29, 2020. Attachment 2 provides a discussion of the changes made to DOM-QA-1. provides a complete version of DOM-QA-1, Revision 30.

Serial No.21-170 Annual Submittal of QA Topical Report Rev. 30 Page 2 of 5 If there are any questions, please contact Michael Whitlock at (804) 273-3123.

Sincerely, Mark D. Sartain Vice President - Nuclear Engineering and Fleet Support Virginia Electric and Power Company Dominion Energy Nuclear Connecticut, Inc.

Dominion Energy Kewaunee, Inc.

Dominion Energy South Carolina, Inc.

COMMONWEAL TH OF VIRGINIA

)

)

COUNTY OF HENRICO

)

The foregoing document was acknowledged before me, in and for the County and State aforesaid, today by Mark D. Sartain, who is Vice President - Nuclear Engineering and Fleet Support, of Virginia Electric and Power Company, Dominion Energy Nuclear Connecticut, Inc., Dominion Energy South Carolina Inc., and Dominion Energy Kewaunee, Inc. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of these Companies, and that the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me this My Commission Expires: 12,.j 31 /)1 Commitments made in this letter: None Attachments:

Qp;,~Public

1.

Summary of Changes Made to DOM-QA-1, Revision 30

2.

Discussion of Changes Made to DOM-QA-1, Revision 30

3.

DOM-QA-1, Revision 30 CRAIG D SLY Notary Public commonwealth of Virginia Reg.# 7518653 1'\\

My commission Expires December 31, 20-

Serial No.21-170 Annual Submittal of QA Topical Report - Rev. 30 Page 3 of 5 cc: U. S. Nuclear Regulatory Commission Region I 2100 Renaissance Boulevard Suite 100 King of Prussia, PA 19406-2713 U. S. Nuclear Regulatory Commission Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, GA 30303-1257 U. S. Nuclear Regulatory Commission Region III 2443 Warrenville Road Suite 210 Lisle, Il 60532-4352 Mr. Richard Guzman NRC Senior Project Manager U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop O8 C-2 Rockville, MD 20852-2738 Mr. Ted H. Carter NRC Senior Project Manager U. S. Nuclear Regulatory Commission Two White Flint North 11545 Rockville Pike Mail Stop T-8 F5 Rockville, MD 20852-2738 Mr. Vaughn Thomas NRC Project Manager Surry Power Station U. S. Nuclear Regulatory Commission One White Flint North Mail Stop O4 F-12 11555 Rockville Pike Rockville, MD 20852-2738

Serial No.21-170 Annual Submittal of QA Topical Report - Rev. 30 Page 4 of 5 Mr. G. Edward Miller NRC Senior Project Manager U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop O9 E-3 Rockville, MD 20852-2738 Ms. Yen-Ju Chen NRC Senior Project Manager U. S. Nuclear Regulatory Commission Two White Flint North 11545 Rockville Pike Mail Stop 4B34 Rockville, MD 20852-2738 Mr. John N. Nguyen NRC Senior Project Manager U. S. Nuclear Regulatory Commission Two White Flint North 11545 Rockville Pike Mail Stop 4B34 Rockville, MD 20852-2738 Mr. Christian Jacobs U. S. Nuclear Regulatory Commission Two White Flint North 11545 Rockville Pike Mail Stop 4B72 Rockville, MD 20852-2738 NRC Senior Resident Inspector Millstone Power Station NRC Senior Resident Inspector Virgil C. Summer Nuclear Station NRC Senior Resident Inspector North Anna Power Station NRC Senior Resident Inspector Surry Power Station

Serial No.21-170 Annual Submittal of QA Topical Report - Rev. 30 Page 5 of 5 Office of Nuclear Material Safety and Safeguards U. S. Nuclear Regulatory Commission Two White Flint North 11545 Rockville Pike Mail Stop 8 A23 Rockville, MD 20852-2738 Mr. G. J. Lindamood Santee Cooper - Nuclear Coordinator 1 Riverwood Drive Moncks Corner, SC 29461 Mr. Marcus Harris Old Dominion Electric Cooperative Innsbrook Corporate Center 4201 Dominion Blvd.

Suite 300 Glen Allen, VA 23060

Serial No.21-170 Annual Submittal of QA Topical Report ATTACHMENT 1

SUMMARY

OF CHANGES MADE TO DOM-QA-1, REVISION 30 Kewaunee Power Station and ISFSI Millstone Power Station, Units 1, 2, and 3 and ISFSI Virgil C. Summer, Unit 1 and ISFSI North Anna Power Station, Unit 1 and 2 and ISFSI Surry Power Station, Unit 1 and 2 and ISFSI

Serial No.21-170 Annual Submittal of QA Topical Report - Rev. 30, Page 1 of 2 Revision 29 and Revision 30 of Topical Report DOM-QA-1, Nuclear Facility Quality Assurance Program Description.

The analysis provided with this submittal addresses the changes made to DOMQA1 as follows:

Change request 2020-001 extended the ILAC-ISO transition period expiration date between ISO/IEC-17025:2005 version to ISO/IEC-17025:2017 version from November 30, 2020 to June 1, 2021. This change also added a new paragraph to allow the use of remote vendor surveillance as an alternate method based on EPRI Report 3002019436, "Remote Source Verification During a Pandemic or Similar State of Emergency:

Screening Criteria and Process Guidance."

Change request 2020-002 included the phrase decommissioning phase activities for clarification in Appendix B and corrected typographical errors.

Change request 2021-001 removed ISO/IEC-17025:2005 as a result of NRC endorsement of NEI 14-05A, Revision 1, Guidelines for the Use of Accreditation in Lieu of Commercial Grade Surveys for Procurement of Laboratory Calibration and Test Services." It also updated the EPRI Report 3002019436-A1 reference to reflect NRC endorsement of the EPRI Report.

The following table provides a summary of changes made to DOM-QA-1 resulting from the evaluations described above. Attachment 2 of this submittal identifies each change and the evaluation of whether the change reduces the commitments in DOM-QA-1 as approved by the NRC.

1 When report 3002019436 was approved, it was renumbered as 3002019436-A.

Serial No.21-170 Annual Submittal of QA Topical Report - Rev. 30, Page 2 of 2 TABLE 1 - Summary Description of DOM-QA-1 Changes DOM-QA-1 Section Revisio n

Number Change Request Number Summary Description of Change 7.5.2 7.5.4 Appendix C, Section 8.5 Alternative 1(a), 2(a), 3(a)

Appendix C, Section 8.5, Section 8 and 10 -

Alternative 29 2020-001 Revise to extend the ILAC-ISO transition period expiration date to change from ISO/IEC-17025:2005 version to ISO/IEC-17025:2017 version from November 30, 2020 to June 1, 2021. Add a new paragraph to allow the use of remote vendor surveillance as an alternate method based on EPRI Report 3002019436, "Remote Source Verification During a Pandemic or Similar State of Emergency: Screening Criteria and Process Guidance.".

Appendix B Appendix C 2.5.1.4 1.2.7 29 2020-002 Include the phrase decommissioning phase activities for clarification.

Correct typographical errors.

7.5.2 7.5.4 Appendix C, Section 8.5, Section 8 and 10 -

Alternative 30 2021-001 Remove ISO/IEC-17025:2005 as a result of the NRC endorsement of NEI 14-05A, Revision 1. Update the EPRI Report 3002019436-A reference to reflect the NRC endorsement of the EPRI Report.

Serial No.21-170 Annual Submittal of QA Topical Report ATTACHMENT 2 DISCUSSION OF CHANGES MADE TO DOM-QA-1, REVISION 30 Kewaunee Power Station and ISFSI Millstone Power Station, Units 1, 2, and 3 and ISFSI Virgil C. Summer, Unit 1 and ISFSI North Anna Power Station, Unit 1 and 2 and ISFSI Surry Power Station, Unit 1 and 2 and ISFSI

Serial No.21-170 Annual Submittal of QA Topical Report - Rev. 30, Page 1 of 3 DOM-QA-1, Revision 29, QAPD Change 2020-001 ISO/IEC 17025:2017 Transition Period Due Date Extension This change is an administrative clarification to Section 7.5.2 of DOM-QA-1 and NQA-1-1994, Requirement 7, Supplement 7S1 for the use of commercialgrade suppliers of calibration and testing services. In June 2020, the International Laboratory Accreditation Cooperation (ILAC) decided to extend the end of the ISO/IEC 17025:2017 transition period from November 30, 2020 to June 1, 2021 to ensure all laboratories can be transitioned following the restrictions imposed as a result of the global COVID-19 pandemic.

The NRC has conditionally accepted the ISO/IEC 17025:2017 standard during the ILACISO transition (Ref. NRC ADAMS Accession No. ML19056A451, dated April 16, 2019). More recently, the NRC extended its recognition of ISO/IEC 17025:2017 from November 30, 2020 to June 1, 2021 (Ref. NRC ADAMS Accession No. ML20325A192, dated November 20, 2020) based on recommendations from ILAC. This extension was needed to allow NRC time to complete their review of Revision 1 of NEI 14-05A, which formally recognizes the 2017 edition of ISO/IEC 17025 as the basis for the ILAC accreditation process and addresses other minor editorial changes, clarifications, and adjustments based on operating experience identified subsequent to the NRC's initial endorsement in February 2015. This extension ensured the provisions allowed by DOM-QA-1 for using ISO/IEC-17025:2017 were compliant through June 1, 2021.

The NRC determined that appropriate implementation of ISO/IEC-17025:2017 will continue to meet the requirements of Criterion VII of Appendix B to 10 CFR Part 50 for the acceptance of commercial grade calibration and/or testing services from domestic and international laboratories accredited to ISO/IEC 17025:2017. The basis for the NRC conditional acceptance of the ISO/IEC 17025:2017 standard is applicable to the Dominion Energy fleet since DOM-QA-1 includes provisions to implement the commercial-grade dedication process through the use of the ILAC accreditation process. This change allowed the Dominion Energy fleet to continue to procure and accept calibration and/or testing services from domestic and international laboratories accredited to ISO/IEC 17025:2017 during the transition period provided by ISO in lieu of performing a survey as part of the commercial-grade dedication process. As such, the transition period was adjusted in several sections of DOM-QA-1 to reflect the new date of June 1, 2021. Administrative clarifications and improvements, and editorial changes are not considered a reduction in commitment under 50.54(a)(3).

Remote Source Verification Alternative A new paragraph 7.5.4, NQA-1-1994, Part 1, Supplement 7S-1, Section 8 and 10 -

Alternative, was added to allow the use of remote vendor surveillance as an alternate method to source verification activities supporting commercial grade dedication or other acceptance processes when exigent conditions such as a pandemic or similar state of emergency declarations exist that restricts access or travel to and/or from vendor locations affected by the declaration. The added text is an alternative to the requirements of NQA1-1994, Part I, Requirement 7, Supplement 7S-1, Section 8.2.2, Section 8.3, and Section 10 regarding source

Serial No.21-170 Annual Submittal of QA Topical Report - Rev. 30, Page 2 of 3 verifications typically performed to verify completion of certain fabrication and testing activities related to equipment that are complex, expensive, or designated for use in nuclear safety-related applications. This alternative was approved by NRC Safety Evaluation (Ref. NRC ADAMS Accession No. ML20244A017, dated September 10, 2020) for the Energy Northwest operational QAPD. The basis for the NRC approval is applicable to the Dominion Energy fleet since source verification is required in Section 7 of DOM-QA-1 and the methods proposed by Energy Northwest and accepted by the NRC add an acceptable alternative (under certain conditions) when source verification is required. Usage of a quality assurance alternative or exception approved by an NRC safety evaluation when the bases for the approval is applicable to the licensees facility is not considered a reduction in commitment under 10 CFR 50.54(a)(3)(ii).

DOM-QA-1, Revision 29, QAPD Change 2020-002 This change revised DOM-QA-1, Appendix B, "Management and Independent Review Activities, " Section 1, to include "decommissioning phase activities" in the first sentence. This was done to expand the language, for clarification, related to "operational activities" to explicitly state that MSRC (Management Safety Review Committee) independent review activities for Millstone Unit 1 and Kewaunee Power Station encompass those activities associated with the corresponding "decommissioning phase" of these sites.

This change also corrected the following typographical errors:

Section 2.5.1.4, V.C Summer Nuclear Station, page 29, to reflect ANS-3.1-1981 (and not 1982).

Section 1.2.7, KPS Supporting Services, page 20, to reflect Subsections 1.2.3 and 1.2.9. Currently 1.2.3 is duplicated.

Appendix C, page C-6, item #3, "Regulatory Guide 1.8, Revision 2, April 1987," to reflect ANS-3.1-1981 (and not 1982).

This change to the paragraph to clarify periodic independent reviews and audits of activities are conducted by MSRC during the decommissioned phase is an administrative change.

Administrative clarifications and improvements, and editorial changes are not considered a reduction in commitment under 50.54(a)(3).

DOM-QA-1, Revision 30, QAPD Change 2021-001 Expiration of the ISO/IEC 17025:2005 and ISO/IEC 17025:2017 Transition Period This change is an administrative clarification to the alternative in Section 7.5.2 of DOM-QA-1 and NQA-1-1994, Requirement 7, Supplement 7S1 for the use of commercialgrade suppliers of calibration and testing services. This change removes ISO/IEC-17025:2005 from DOM-QA-1 as a result of the NRC endorsement of NEI 14-05A, Revision 1 (ADAMS Accession No. ML20322A019), and it reflects the end of the three-year period established by ISO to allow accredited laboratories to transition from the 2005 to the 2017 edition of ISO/IEC 17025.

Revision 1 of NEI 14-05A provides an updated approach for licensees and suppliers of basic components for using laboratory accreditation by Accreditation Bodies (ABs) that are

Serial No.21-170 Annual Submittal of QA Topical Report - Rev. 30, Page 3 of 3 signatories to the International Laboratory Accreditation Cooperation (ILAC) Mutual Recognition Arrangement (MRA) in lieu of performing commercial-grade surveys for procurement of calibration and testing services. NEI 14-05A was revised to recognize the 2017 edition of ISO/IEC 17025 as the basis for the ILAC accreditation process and to address other minor editorial changes, clarifications, and adjustments. The changes in NEI 14-05A are supported by an NRC Safety Evaluation which includes endorsement of NEI 14-05A, Revision

1. The removal of ISO/IEC-17025:2005 from DOM-QA-1 was needed to avoid discontinuity of the provisions allowed by DOM-QA-1, Rev. 29.

The NRC determined that appropriate implementation of ISO/IEC-17025:2017 will continue to meet the requirements of Criterion VII of Appendix B to 10 CFR Part 50 for the acceptance of commercial grade calibration and/or testing services from domestic and international laboratories accredited to ISO/IEC 17025:2017. The basis for the NRC acceptance of the ISO/IEC 17025:2017 standard is applicable to the Dominion Energy fleet since DOM-QA-1 includes provisions to implement the commercial-grade dedication process through the use of the ILAC accreditation process. This change allows the Dominion Energy fleet to continue to procure and accept calibration and/or testing services from domestic and international laboratories accredited to ISO/IEC 17025:2017 in lieu of performing a survey as part of the commercial-grade dedication process. Administrative clarifications and improvements, and editorial changes are not considered a reduction in commitment under 50.54(a)(3).

Remote Source Verification Alternative - EPRI Report Reference Update DOM-QA-1, Section 7.5.4, NQA-1-1994, Part 1, Supplement 7S-1, Section 8 and 10 -

Alternative, and Appendix C, Section 8.5, Alternative - Section 8, Acceptance of Item or Service, and Section 10, Commercial Grade Items, were adjusted to update the EPRI Report 3002019436-A, dated October 2020 reference as an editorial enhancement. EPRI Report 3002019436-A allows the use of remote vendor surveillance as an alternate method to source verification activities supporting commercial grade dedication or other acceptance processes when exigent conditions such as a pandemic or similar state of emergency declarations exist that restricts access or travel to and/or from vendor locations affected by the declaration. The updated reference reflects the NRC endorsement of the EPRI Report (ADAMS Accession No: ML20205L619 and ML205L618).

This remote vendor surveillance alternative was approved by NRC Safety Evaluation (Ref.

NRC ADAMS Accession No. ML20244A017, dated September 10, 2020) for the Energy Northwest operational QAPD and included in Revision 29 of DOM-QA-1. The basis for the NRC approval is applicable to the Dominion Energy fleet since source verification is required in Section 7 of DOM-QA-1 and the methods proposed by Energy Northwest and accepted by the NRC as an acceptable alternative (under certain conditions) when source verification is required. This is considered an administrative clarification and improvement to DOM-QA-1 and, as such, is not considered a reduction in commitment under 50.54(a)(3).

Serial No.21-170 Annual Submittal of QA Topical Report - Rev. 30 ATTACHMENT 3 DOM-QA-1, REVISION 30 Kewaunee Power Station and ISFSI Millstone Power Station, Units 1, 2, and 3 and ISFSI Virgil C. Summer, Unit 1 and ISFSI North Anna Power Station, Unit 1 and 2 and ISFSI Surry Power Station, Unit 1 and 2 and ISFSI

Nuclear Facility Quality Assurance Program Description Topical Report DOM-QA-1 Revision 30 I Dominion nergy

i Revision 5 Dominion Energy Nuclear Facility Quality Assurance Program Description Introduction This topical report provides the quality assurance program description (QAPD) for Dominion Energys nuclear power station units that are commercially operational or are in decommissioning, and independent spent fuel storage installations, hereinafter referred to as facility or nuclear facility.

The quality assurance program applies to activities during design, construction, operation, and decommissioning of the nuclear facility. Activities affecting quality include siting, designing, procuring, fabricating, handling, shipping, receiving, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, modifying, and decommissioning.

The quality assurance program provides adequate confidence to management and regulatory agencies that structures, systems, and components (SSCs) will perform satisfactorily in service and that programs for coping with emergencies perform as required. This report describes the policy, principles, and standards that establish the planned and systematic actions used to assure quality is achieved in all activities affecting the safety of the nuclear facility. These policies, principles, and standards are developed into administrative and implementing documents. The administrative and implementing documents govern the various aspects of day-to-day activities for the facility.

Dominion Energys Nuclear Facility QAPD is referred to by several generic titles within the administrative controls for the facilities. These include Chapter 17.2 of the UFSAR, the Operational Quality Assurance Program, the Quality Assurance Plan (or Program), the QA Topical Report, and other similar designations. These are used interchangeably to refer to this document that represents Dominion Energy Managements philosophy and methodologies for complying with the 18 criteria of 10 CFR 50, Appendix B, or the alternative treatment for the SSCs categorized through the risk-informed process under the voluntary regulation in 10 CFR 50.69, where such a license amendment has been issued for a particular facility. This topical report is incorporated by reference into the appropriate chapter of the FSAR for the applicable facilities as the operational quality assurance program description. Within this QAPD, the term Company is used to refer to those parts of the parent company (Dominion Energy) which are under the purview of the Chief Nuclear Officer as described in Section 1 of this QAPD.

The quality assurance measures and administrative controls established by this QAPD are comparable to those implemented during the construction, operational, and decommissioning activities conducted prior to the effective date of this QAPD. Conformance of the existing structures, systems, and components (including new, spare, and replacement items in storage, in stock, or on order) to the previous QA program requirements shall be treated as conforming to the requirements of this QAPD. Where new or updated requirements are established by this QAPD, they are not retroactively applied, but will be applied to the activities conducted subsequent to the effective date of this QAPD.

ii Revision 4 Dominion Energy Nuclear Facility Quality Assurance Program Description Policy This policy provides the expectations to safely design, construct, operate, and decommission Dominion Energys nuclear facilities. Each employee and Supplier is responsible for the quality of their work. Maintaining quality of workmanship, whether physical or programmatic, ensures that our nuclear facilities are designed, constructed, operated, and decommissioned safely, efficiently, and economically and that regulatory commitments are met. Suppliers providing items and services affecting safety of the nuclear facilities are also expected to implement a quality assurance program or quality controls that meet regulatory requirements.

The QAPD is the top-level policy document that establishes the manner in which quality is to be achieved and presents Dominion Energy's overall philosophy regarding achievement and assurance of quality. Quality assurance programs focus employees and Suppliers attention on regulatory requirements and management expectations while requiring identification of concerns.

Implementing documents assign more detailed responsibilities and requirements and indicate the organizational interfaces involved in conducting activities within the scope of the QAPD.

These programs will be implemented for safety-related activities affecting structures, systems, and components. As identified within the QAPD and Company documents, applicable elements of the quality assurance program will be applied to selected activities that are not safety-related, but support safe facility operations. The Dominion Energy Nuclear quality assurance program will comply with the requirements of 10 CFR 50, Appendix B, the approved facility license, and applicable codes and standards as further described in this QAPD. Compliance with the QAPD and implementing documents is mandatory for personnel directly or indirectly associated with implementation of the Dominion Energy quality assurance program.

The management position responsible for Nuclear Oversight is responsible for interpretations and clarifications of the requirements of the QAPD, and is delegated the responsibility and authority to maintain and update the QAPD, including approving changes that do not constitute a reduction in the commitment of the program description accepted by the NRC. Where conflicts in opinion arise that cannot be resolved at that level, they are escalated to the CNO position for resolution.

Signed Signature on file Date:__________

Daniel G. Stoddard Senior Vice President & Chief Nuclear Officer

iii Revision 7 Dominion Energy Nuclear Facility Quality Assurance Program Description Basis This QAPD is based on 10 CFR 50, Appendix B, as amended. The requirements of 10 CFR 50, Appendices A (General Design Criterion I) and R, 50.48, 50.54, 50.55a, 50.59, 50.82; 10 CFR 21; 10 CFR 71, Subpart H; and 10 CFR 72, Subpart G are also included in the development and application of this QA program. Where a facility is granted a license amendment to comply with the voluntary requirements in regulation 10 CFR 50.69 for risk-informed categorization and treatment of SSCs for nuclear power reactors, this QAPD establishes quality assurance requirements to be applied to the alternative treatment where such treatment is permitted.

Dominion Energy is committed to carrying out the provisions of various NRC Regulatory Guides and industry quality assurance standards of ASME, ANSI, and ANS that expound on the 18 criteria of 10 CFR 50, Appendix B. The specific commitments, clarifications, and alternatives are described in detail within the QAPD.

This QAPD is intended to be a comprehensive, up-to-date description of the Companys quality assurance program for nuclear facilities. This topical report will be revised in accordance with 10 CFR 50.54(a).

Applicable Facilities This QAPD is applicable to activities at or for the following Dominion Energy power stations, and any associated or specific Independent Spent Fuel Storage Installation and/or radioactive waste storage/processing facilities at the power station site:

• Kewaunee Power Station (KPS)

• Millstone Power Station (MPS)

• North Anna Power Station (NAPS), excluding North Anna Unit 3 activities

• Surry Power Station (SPS)

• Virgil C. Summer Nuclear Station (VCS)

Dominion Energy Nuclear Facility Quality Assurance Program Description 1

Revision 30 Section Revision Introduction 3

Policy 2

Basis 5

Section 1 Organization 30 Section 2 Quality Assurance Program 30 Section 3 Design Control 30 Section 4 Procurement Document Control 30 Section 5 Instructions, Procedures, and Drawings 30 Section 6 Document Control 30 Section 7 Control of Purchased Material, Equipment, and Services 30 Section 8 Identification and Control of Materials, Parts, and Components 30 Section 9 Control of Special Processes 30 Section 10 Inspection 30 Section 11 Test Control 30 Section 12 Control of Measuring and Test Equipment 30 Section 13 Handling, Storage, and Shipping 30 Section 14 Inspection, Test, and Operating Status 30 Section 15 Nonconforming Materials, Parts, or Components 30 Section 16 Corrective Action 30 Section 17 Quality Assurance Records 30 Section 18 Quality Assurance Audits 30 Appendix A Organizational Relationships of Key Management and Functional Groups 30 Appendix B Management and Independent Review Activities 30 Appendix C Regulatory Guides and Quality Standards Commitments 30 Appendix D Terms and Definitions 30 Appendix E QA Records Retention Requirements For Operating Facilities 30 Appendix F Augmented Quality Assurance Requirements For Selected SSCs and Programs 30 LIST OF EFFECTIVE SECTIONS

Dominion Energy Nuclear Facility Quality Assurance Program Description 2

Revision 30 Section 1 Organization 1.1 General Description................................................

8 1.2 Responsibility and Authority.........................................

9 1.2.1 Chief Nuclear Officer..........................................

9 1.2.2 Facility Operations............................................

9 1.2.3 Engineering Services..........................................

13 1.2.4 Fleet Performance............................................

15 1.2.5 Nuclear Oversight............................................

16 1.2.6 KPS Facility Operations........................................

17 1.2.7 KPS Supporting Services......................................

20 1.2.8 Nuclear Oversight (KPS support)................................

21 1.2.9 Engineering Services (KPS support)..............................

21 1.3 Succession of Responsibility for Overall Plant Operation.................

22 1.4 Organization Charts................................................

22 1.5 Quality Standards Commitment.......................................

22 Section 2 Quality Assurance Program 2.1 General Description................................................

23 2.2 Applicability.......................................................

23 2.2.1 Risk-Informed Categorization...................................

24 2.3 Oversight of the Quality Program Implementation........................

25 2.4 Identification of Structures, Systems, and Components (SSC).............

25 2.5 Selection, Training, and Qualification of Personnel.......................

26 2.5.1 Facility Operating Staff........................................

26 2.5.2 Support Organizations.........................................

30 2.5.3 Quality Assurance Verification Personnel..........................

30 2.5.4 Quality Assurance Audits.......................................

30 2.5.5 Quality Control Verification.....................................

30 2.5.6 Non-Destructive Examination Technicians.........................

31 2.5.7 ASME Code Visual Examinations................................

31 2.6 Control of Activities................................................

31 2.7 Quality Standards Commitment.......................................

32 2.7.1 NQA-1-1994, Part II, Subpart 2.1................................

32 2.7.2 NQA-1-1994, Part II, Subpart 2.3................................

32 Contents

Contents Dominion Energy Nuclear Facility Quality Assurance Program Description 3

Revision 30 Section 3 Design Control 3.1 General Description................................................

33 3.2 Design Control Program.............................................

33 3.2.1 Design Change Control........................................

33 3.2.2 Design Interface Control.......................................

33 3.2.3 Design Verification............................................

33 3.2.4 Computer Application and Digital Equipment Software Design and Control 34 3.2.5 Setpoint Control..............................................

34 3.3 Quality Standards Commitment.......................................

34 Section 4 Procurement Document Control 4.1 General Description................................................

35 4.2 Preparation, Review, and Approval of Procurement Documents............

35 4.3 Quality Standards Commitment.......................................

35 Section 5 Instructions, Procedures, and Drawings 5.1 General Description................................................

36 5.2 Procedure Adherence...............................................

36 5.3 Procedure Content.................................................

36 5.4 Types of Procedures and Instructions.................................

37 5.4.1 Administrative Controls........................................

37 5.4.2 Engineering Procedures.......................................

38 5.4.3 Installation Procedures........................................

38 5.4.4 System Procedures...........................................

39 5.4.5 Start-up Procedures...........................................

39 5.4.6 Shutdown Procedures.........................................

39 5.4.7 Power Operation and Load Changing Procedures...................

39 5.4.8 Process Monitoring Procedures..................................

39 5.4.9 Fuel Handling Procedures......................................

40 5.4.10 Maintenance Procedures.......................................

40 5.4.11 Radiation Control Procedures...................................

41 5.4.12 Calibration and Test Procedures.................................

41 5.4.13 Chemical and Radiochemical Control Procedures...................

41 5.4.14 Emergency Operating Procedures...............................

41 5.4.15 Emergency Plan Implementing Procedures........................

42 5.4.16 Test and Inspection Procedures.................................

42

Contents Dominion Energy Nuclear Facility Quality Assurance Program Description 4

Revision 30 5.4.17 Procedures Specific to Kewaunee Power Station (KPS)...............

42 5.5 Quality Standards Commitment.......................................

43 Section 6 Document Control 6.1 General Description................................................

44 6.2 Applicability.......................................................

44 6.3 Document Review and Approval......................................

44 6.4 Additional Operations and Decommissioning Phase Review Requirements..

45 6.5 Distribution of Controlled Documents..................................

45 6.6 Quality Standards Commitment.......................................

46 Section 7 Control of Purchased Material, Equipment, and Services 7.1 General Description................................................

47 7.2 Selection of Suppliers...............................................

47 7.3 Conformance of Items and Services...................................

47 7.4 Quality Verification.................................................

48 7.5 Quality Standards Commitment.......................................

48 7.5.1 NQA-1-1994, Part I, Supplement 7S Exception...................

48 7.5.2 NQA-1-1994, Part I, Supplement 7S Alternative..................

48 7.5.3 NQA-1-1994, Part I, Supplement 7S-1, Section 10, Commercial Grade Items -

Alternative...........................................................

50 7.5.4 NQA-1-1994, Part 1, Supplement 7S-1, Section 8 and 10 - Alternative...

50 Section 8 Identification and Control of Materials, Parts, and Components 8.1 General Description................................................

51 8.2 Quality Standards Commitment.......................................

51 Section 9 Control of Special Processes 9.1 General Description................................................

52 9.2 Qualification of Special Processes Personnel, Procedures, and Equipment..

52 9.3 Quality Standards Commitment.......................................

52 Section 10 Inspection 10.1 General Description................................................

53 10.2 Inspection Program.................................................

53 10.3 Inspector Qualification..............................................

54 10.4 Quality Standards Commitment.......................................

54

Contents Dominion Energy Nuclear Facility Quality Assurance Program Description 5

Revision 30 Section 11 Test Control 11.1 General Description................................................

55 11.2 Test Procedures...................................................

55 11.3 Evaluation of Test Results...........................................

56 11.4 Scheduling........................................................

56 11.5 Quality Standards Commitment.......................................

56 Section 12 Control of Measuring and Test Equipment 12.1 General Description................................................

57 12.2 Installed Instrument and Control Devices...............................

57 12.3 Quality Standards Commitment.......................................

57 Section 13 Handling, Storage, and Shipping 13.1 General Description................................................

59 13.2 Special Handling, Storage, Shipping, Cleaning and Preservation Requirements 59 13.3 Quality Standards Commitment.......................................

59 13.3.1 Regarding Subpart 2.2.........................................

60 13.3.2 Regarding Subpart 2.15........................................

60 Section 14 Inspection, Test, and Operating Status 14.1 General Description................................................

61 14.2 Control of Systems and Equipment for Operating Facilities................

61 14.3 Quality Standards Commitment.......................................

62 Section 15 Nonconforming Materials, Parts, or Components 15.1 General Description................................................

63 15.2 Nonconformance Responsibilities.....................................

63 15.3 Nonconformance Documentation.....................................

63 15.4 Quality Standards Commitment.......................................

64 Section 16 Corrective Action 16.1 General Description................................................

65 16.2 Corrective Action Documentation.....................................

65 16.3 Follow-up.........................................................

65 16.4 Quality Standards Commitment.......................................

65

Contents Dominion Energy Nuclear Facility Quality Assurance Program Description 6

Revision 30 Section 17 Quality Assurance Records 17.1 General Description................................................

66 17.2 Records of Activities................................................

66 17.3 Record Storage....................................................

66 17.4 Quality Standards Commitment.......................................

67 Section 18 Quality Assurance Audits 18.1 General Description................................................

68 18.2 Audit Scope.......................................................

68 18.3 Audit Responsibilities and Procedures.................................

68 18.4 Supplier Quality Assurance..........................................

69 18.5 Internal Audits.....................................................

69 18.6 Quality Standards Commitment.......................................

70 Appendix A Organizational Relationships of Key Management and Functional Groups...

A-1 Appendix B Management and Independent Review Activities.........................

B-1

1. General........................................................

B-2

2. Qualifications....................................................

B-3

3. Management Safety Review Committee (MSRC)........................

B-3

4. Facility Safety Review Committee (Millstone, North Anna, Surry, V.C. Summer)

B-4

5. Independent Nuclear Safety Review..................................

B-6

6. Facility Safety Review Group (Kewaunee).............................

B-7 Appendix C Regulatory Guides and Quality Standards Commitments..................

C-1

1. Regulatory Guide 1.8, Revision 1-R (Reissued May 1977)................

C-2

2. Regulatory Guide 1.8, Second Proposed Revision 2, (September 1980)......

C-4

3. Regulatory Guide 1.8, Revision 2, April 1987...........................

C-6

4. Regulatory Guide 1.8, Revision 3, May 2000...........................

C-6

5. Regulatory Guide 1.26, Revision 3, February 1976......................

C-7

6. Regulatory Guide 1.28, Revision 3, August 1985........................

C-7

7. Regulatory Guide 1.28, Revision 4, June 2010..........................

C-9

8. ANSI/ASME NQA-1-1994..........................................

C-9

9. Regulatory Guide 1.29, Revision 2: For Comment, February 1976..........

C-17

10. Regulatory Guide 1.29, Revision 3, September 1978.....................

C-17

11. Regulatory Guide 1.29, Revision 4, March 2007........................

C-17

12. Regulatory Guide 1.33, Revision 2, February 1978......................

C-17

13. Regulatory Guide 1.36, Revision 0, February 1973......................

C-19

14. Regulatory Guide 1.37, Revision 1, March 2007........................

C-19

15. Regulatory Guide 1.54, Revision 0, June 1973..........................

C-19

16. Regulatory Guide 1.97............................................

C-19

Contents Dominion Energy Nuclear Facility Quality Assurance Program Description 7

Revision 30

17. Regulatory Guide 1.143, Revision 2, November 2001....................

C-20

18. Regulatory Guide 1.152, Revision 1, January 1996......................

C-20

19. Regulatory Guide 1.155, Revision 0, June 1988.........................

C-20

20. Regulatory Guide 1.164, Revision 0, June 2017.........................

C-20

21. Regulatory Guide 1.189, Rev. 2, October 2009.........................

C-21

22. Regulatory Guide 4.15, Revision 1, February 1979......................

C-21

23. Regulatory Guide 7.10, Revision 1, June 1986..........................

C-21

24. Generic Letters 89-02/91-05........................................

C-21

25. Branch Technical Position APCSB/CMEB 9.5-1.........................

C-21

26. Generic Letter 85-06..............................................

C-22

27. RIS 2000-18....................................................

C-22 Appendix D Terms and Definitions...............................................

D-1 Appendix E QA Records Retention Requirements For Operating Facilities.............

E-1 Appendix F Augmented Quality Assurance Requirements For Selected SSCs and Programs F-1

1. Nonsafety-Related SSCs - Significant Contributors to Plant Safety..........

F-2

2. Nonsafety-Related SSCs Credited for Regulatory Events.................

F-5

3. Alternative Treatment for RISC-2 and RISC-3 SSCs.....................

F-5

4. Nonsafety-Related SSCs subject to Aging Management for Renewed Licenses F-6

8 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Organization Section 1 Organization 1.1 General Description This section describes the key organizational groups performing activities for the Companys nuclear facilities and their responsibilities governed by the Quality Assurance Program Description (QAPD) Topical Report. The reporting relationships are depicted in the organization charts of Appendix A.

The Companys organizational structure ensures compliance with regulatory requirements and industry standards for the implementation of this QAPD. The organizational structure is delineated through the organizational charts, the duties and responsibilities described below and in the policy statement, and written job or functional descriptions contained in implementing documents. These individuals and groups described herein are responsible for performing or verifying activities affecting quality. The Company may delegate all or part of the activities of planning, establishing, and implementing the quality assurance program to others, but retains the responsibility for the programs effectiveness. When activities are delegated to organizations outside the Company, procedures require the establishment of interface requirements including defining authorities and lines of communication as appropriate for the delegated functions. However, the Company retains and exercises responsibility for the scope and effective implementation of the quality assurance program.

The organization consists of three main parts: corporate management, facility operations, and support groups. Corporate management is responsible for overall management of the Companys nuclear facilities through all the phases from initial siting to decommissioning. The support groups provide management, technical, and oversight support for activities such as design, construction, operation, modification, and decommissioning and report to corporate management. The support groups may be located at corporate offices or at a nuclear facility site. The facility operations groups are responsible for overall operational activities of assigned nuclear facilities in accordance with the facility license. The operations groups are typically assigned responsibility for one or more nuclear power station units and any Independent Spent Fuel Storage Installations and/or radioactive waste processing/storage facilities at a particular site.

The overall structure of the organization described herein is applied for the Millstone, North Anna, Surry, and V.C. Summer facilities; while there may be slight variations in responsibilities between facilities, the overall reporting relationships remain. The Kewaunee part of the organization is described separately to align to the unique needs of the facility. Depending on the scope of the activities, one or more individuals may be assigned the described management responsibilities. As the amount of certain activities changes, such as construction or decommissioning, the organizational structure may change and will be reflected in a change to these descriptions.

9 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Organization 1.2 Responsibility and Authority 1.2.1 Chief Nuclear Officer The chief nuclear officer (CNO) has overall responsibility and authority for the implementation of all activities associated with the safe and reliable design, construction, operation, and decommissioning of the Company's nuclear facilities. The CNO establishes the Companys quality assurance policy and is responsible for implementing the quality assurance program during operating activities, including related decommissioning activities.

The CNO has the authority to resolve disputes related to implementation of this QAPD for which resolution is not achieved at lower levels within the organization. There are four functional groups reporting to the CNO that affect the safety of the nuclear facilities governed in accordance with this quality assurance program: operations, engineering, fleet performance, and oversight.

Subsections 1.2.2 through 1.2.4 and Appendix A, describe the onsite organizational functions and relationships for the Millstone, North Anna, Surry, and V. C. Summer facilities and their relationship to the supporting offsite groups. Subsections 1.2.4.2 through 1.2.6 and Appendix A, similarly describe the organizational functions and relationships for the Kewaunee facility.

1.2.2 Facility Operations An executive management position is responsible for operations of their assigned Company nuclear facilities (except for KPS, see 1.2.4, and 1.2.6 through 1.2.9). The necessary responsibility and authority for the management and direction of all activities related to the safe and efficient operation and decommissioning has been delegated by the senior executives. This responsibility includes ensuring quality through implementation of this QAPD in all the activities related to operation such as maintenance, testing, start-up and shutdown, refueling, fuel storage, and modification.

1.2.2.1 Facility Operations and Maintenance A senior management position is responsible for safe operations and maintenance of their assigned nuclear facilities including those activities necessary for safe storage and handling of spent nuclear fuel during decommissioning. The position responsibilities include: directing the operations, maintenance, planning, and site services groups; implementing facility modifications; and maintaining compliance with requirements of the operating license, Technical Specifications, and applicable federal, state, and local laws, regulations, and codes. For VCS, the senior management position responsible for operations and maintenance approves security implementing procedures and emergency plan implementing procedures, and also approves the reports that evaluate and provide recommendations to

10 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Organization prevent recurrence of events that are reportable pursuant to the site's technical specification 6.9 and forwards such reports to the chairman of the FSRC.

1.2.2.1.1 Operations Operations is responsible for operating the facility in accordance with the applicable license, including those facilities in a decommissioning phase that still contain nuclear fuel. Overall facility operation is directed by a management position responsible for Operations activities who is also responsible, through the systematic approach to training (SAT) process, for review of normal and emergency training and retraining programs to ensure they are effective.

Operations activities include monitoring and controlling day-to-day operation of the nuclear facility; responding to alarms; manipulating facility equipment; coordinating facility operations to manage work such as maintenance, testing, and modifications; and moving nuclear fuel. The Operations organization contains supervision and staff for shift operations, including shift managers, unit supervisors, licensed control room operators, and non-licensed operators. Operations is also responsible for the shift technical advisor function. In the absence of the individual filling the management position responsible for shift operations, the individual filling the supervisor position responsible for shift operations will assume these responsibilities.

The staff for operating units, when approved by the NRC and documented in this QAPD, may be responsible for activities related to an adjacent decommissioned units spent fuel pool and auxiliary systems, providing that the transfer of responsibility does not impact the capability to perform their operating duties, including day-to-day functions, and accident and transient mitigation. Minimum shift composition will be in accordance with the nuclear facilitys Technical Specifications.

Specifically, the following allowances are approved:

• Millstone Unit 2 Operations is responsible for operations regarding the Millstone Unit 1 Spent Fuel Pool Island and auxiliary systems.

1.2.2.1.2 Maintenance Maintenance is responsible for directing and coordinating facility maintenance activities including on-line maintenance, installation, maintenance, alterations, adjustment and calibration, replacement and repair of plant electrical and mechanical equipment, and instruments and

11 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Organization controls. The responsibilities include performance of surveillances required by Technical Specifications, establishing standards and frequency of calibration for instrumentation and control devices, and ensuring instrumentation and related testing equipment are properly used, inspected and maintained.

1.2.2.1.3 Outage & Planning Outage & Planning is responsible for planning and scheduling online-maintenance and outage activities, including modification, and surveillance test and inspection activities, within the constraints imposed by operational, regulatory, and system load requirements.

1.2.2.1.4 Site Services Site Services is responsible for facility project support, including project construction and project controls. Site Services is responsible for and serves as the primary organizational interface with outside organizations for capital projects. This group provides coordination and interface for resolving conflicts and delays for execution of activities as necessary for project implementation.

1.2.2.2 Facility Safety & Licensing A senior management position is responsible for ensuring that facility safety and licensing requirements are implemented. This position is responsible for directing and coordinating radiological protection and assessment of nuclear safety issues at the facility, including certain independent review functions. The responsibilities also include managing licensing activities; industrial safety and loss prevention including oversight of fire protection measures (excluding KPS and VCS); interfacing with corporate management on operating experience and licensing issues, managing facility procedures, and administering the facility environmental compliance program in VA. This position is independent of cost and scheduling concerns associated with operations, maintenance, and modification activities to avoid undue pressures when carrying out radiological protection, quality effectiveness verifications, and independent nuclear safety review functions. This position has the authority to suspend unsatisfactory work and control further processing or installation of non-conforming materials. The authority to stop work delegated to quality control inspection personnel is delineated in procedures.

12 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Organization 1.2.2.2.1 Organizational Effectiveness Organizational Effectiveness is responsible for ensuring that procedures are prepared in accordance with applicable regulatory requirements, industry quality standards and this QAPD; management of facility QA records; the corrective action program; and the operating experience program. This responsibility includes review of NRC and industry issuances, significant events, and other operating experience to meet independent nuclear safety review requirements.

1.2.2.2.2 Radiological Protection & Chemistry Radiological Protection & Chemistry carries out health physics and chemistry functions and maintains sufficient organizational freedom and independence from operating pressures as required by the facility Technical Specifications. A qualified supervisor or manager is assigned to fulfill the radiological protection manager position described in Section 2.5 of this QAPD.

The radiological protection responsibilities include scheduling and conducting radiological surveys, contamination sample collection, determining contamination levels, assigning work restrictions through radiation work permits, administering the personnel monitoring program, and maintaining required records in accordance with federal and state codes.

The chemistry responsibilities include maintaining primary and secondary plant chemistry in accordance with established program requirements.

1.2.2.2.3 Emergency Preparedness The Emergency Preparedness group is responsible for development and maintenance of the Company radiological emergency plans and coordination with required off-site radiological emergency response groups for the nuclear facilities. This includes managing the overall scheduling and coordination of emergency plan testing, training and exercises with federal, state, and local agencies, and working with corporate and facility personnel to ensure emergency plans meet all the requirements and commitments.

1.2.2.2.4 Quality Control Inspections (VA)

The Quality Control Inspection group plans and conducts inspections of maintenance and modification activities for operating facilities to ensure

13 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Organization quality in accordance with the requirements of the QA program. The Quality Control Inspectors from the Maintenance and Site Services groups report through this functional organization while performing maintenance and modification inspections for the operating facilities in Virginia.

1.2.2.3 Training A management position is responsible for the training of personnel who operate or support the nuclear facilities. Training responsibilities include: determining the need for training based on information provided by the various groups, developing performance-based training programs, implementing training programs to support employee and facility needs, and evaluating training programs. Certain functional groups may be assigned responsibility for the development and conduct of their own training programs provided these groups are not required to have a systems approach to training under 10 CFR 50.120.

1.2.3 Engineering Services An executive management position is responsible for the engineering functions supporting design and construction activities and long-term nuclear operations. These are accomplished through nuclear engineering, projects, nuclear analysis and fuel, and information technology. Responsibilities include system level implementation of the requirements established by this QAPD for the nuclear facilities and facility specific engineering and technical support required for day-to-day operations. Where implementation of any or all of these functions is delegated to organizations outside the Company, procedures require the establishment of interface documents including defining lines of communication and authorities as appropriate for the delegated functions. However, this executive management position retains responsibility for the scope and effective implementation of the quality assurance program for those functions.

1.2.3.1 Nuclear Engineering and Fuel A senior management position is responsible for design engineering functions, nuclear projects, nuclear safety engineering, nuclear fuel analysis and procurement, and supporting activities. These functions and activities include independent design checks and reviews, developing and maintaining engineering programs, including those for nondestructive examination (NDE), and the facility inservice inspection and test (ISI/IST) programs; configuration management including design and configuration control, and engineering technical support for the operating facilities. The engineering activities also include evaluation, and analysis of: core design, fuel and reactor performance, probabilistic risk

14 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Organization assessment, spent fuel storage, and radiological effects. This group also provides support to reactor engineering for the operating power stations.

Nuclear Engineering and Fuel is responsible for nuclear fuel procurement, assurance of nuclear fuel quality through surveillances and inspections at Company and Supplier facilities, and special nuclear material accountability. This position has the authority to control further processing or installation of nonconforming materials.

The authority delegated to inspection and surveillance personnel is delineated in procedures. Nuclear Engineering and Fuel is also responsible for providing engineering oversight of dry cask spent fuel storage system fabrication, including approval of nonconformance disposition.

Nuclear Engineering and Fuel is responsible for the implementation of large projects for the nuclear facilities on behalf of the Company. Implementation includes development of the detailed scope, estimate, schedule, cost, design, procurement, construction, testing, and closeout of each project. Nuclear Projects focuses on defined projects separate from ongoing routine engineering projects.

1.2.3.2 Facility Engineering Facility Engineering is responsible for managing engineering resources providing day-to-day technical support for facility operations. The functions include engineering, reactor-engineering, and technical support at a system and component level to ensure optimum design basis performance, system reliability, and optimum component performance and reliability. Support is also provided in developing and implementing testing programs, tracking and scheduling test performance, and evaluating test results. The test programs include inservice inspections, Technical Specification surveillances, post-modification and post-maintenance testing, and nondestructive examinations. Facility Engineering is responsible for performing technical reviews and performance monitoring of key structures, systems, and components to meet independent nuclear safety review requirements.

Facility Engineering is also responsible for Design Engineering including classifying SSCs, implementing the design control program, developing and revising facility drawings, and ensuring the design basis for the facility is maintained.

1.2.3.3 Information Technology A senior management position is responsible for direction and support of information technology for the nuclear organizations and facilities. Responsibilities include: network infrastructure maintenance and upgrade, network and application security, network operations; automation strategy, application development and

15 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Organization support, automation training; development and maintenance of the software control program; and oversight, maintenance, and repair of the Emergency Response Facility Computer System.

1.2.3.4 Nuclear Regulatory Affairs A senior management position for Nuclear Regulatory Affairs is responsible for providing regulatory compliance and licensing support through NRC communications, maintaining and acquiring licenses required for continued and extended operations.

Nuclear Regulatory Affairs is responsible to ensure controlled documents (such as manuals, instructions, procedures, and drawings) and QA records are maintained in accordance with applicable regulatory requirements, industry quality standards, and this QAPD. Nuclear Regulatory Affairs is also responsible for leading and providing strategy for the fleet emergency preparedness organizations.

1.2.3.5 Supply Chain Management A senior management position is responsible for material management, purchasing, procurement engineering, Supplier surveillance functions, and source and receipt inspection. This position has the authority to control further processing or installation of nonconforming materials. This authority is delegated to inspection and surveillance personnel as delineated in procedures.

1.2.4 Fleet Performance An executive management position is responsible for providing protective services, training of personnel who support the nuclear facilities, and for assessing fleet and facility performance to identify areas for improvement and recommend actions to improve performance. This position also has corporate responsibility for operations related to the decommissioning of the KPS facility as described in Subsection 1.2.6.

1.2.4.1 Protection Services A senior management position is responsible for providing nuclear facility protective services, including physical security, security force operations, training and qualification programs for security personnel, maintenance and testing activities for security equipment for the facility, nuclear facility access programs, and fitness for duty programs.

1.2.4.2 Performance Improvement and Training A senior management position is responsible for the training of personnel who support the nuclear facilities. Training responsibilities include: determining the need

16 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Organization for training based on information provided by the various groups, developing performance-based training programs, implementing training programs to support employee and facility needs, and evaluating training programs. Certain functional groups may be assigned responsibility for the development and conduct of their own training programs provided these groups are not required to have a systems approach to training under 10 CFR 50.120. Performance Improvement and Training is also responsible for assessing fleet and facility performance to identify areas for improvement and recommend actions to improve performance.

1.2.5 Nuclear Oversight A management position is responsible for the verification of effective Company and Supplier QA program development, documentation, and implementation, and the effective performance of Nuclear Oversight activities. This position is responsible for the performance of independent audits of facility operations related to quality and safety with lines of communication to the executive management position responsible for facility operations.

This position is independent of cost and scheduling concerns associated with construction, operations, maintenance, modification, and decommissioning activities for performing quality assurance program verification. Where implementation of any or all of these functions is delegated to Suppliers, procedures require the establishment of interface documents including defining lines of communication and authorities as appropriate for the delegated functions. However, this management position retains responsibility for the scope and effective implementation of the quality assurance program for those functions. This management position has the necessary authority and responsibility for verifying quality achievement; identifying quality problems, recommending solutions and verifying implementation of the solutions; and escalating quality problems to higher management levels. This position has the authority to suspend unsatisfactory work and control further processing or installation of non-conforming materials. The authority to stop work delegated to Nuclear Oversight personnel is delineated in procedures.

Nuclear Oversight is responsible for the evaluation of Suppliers quality programs through a system of external audits, surveys, evaluations, and/or reviews of Supplier performance in accordance with quality assurance requirements. A list of approved Suppliers is maintained.

Nuclear Oversight is responsible for assuring Company compliance with this QAPD through administration of a comprehensive and systematic internal audit program.

Nuclear Oversight is responsible for developing and maintaining an appropriate quality verification inspection program where not provided for in the facility construction or operating organization functions.

17 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Organization 1.2.5.1 Quality Control Inspections (MPS and VCS)

The Quality Control Inspection group plans and conducts inspections of operating facility maintenance and modification activities to ensure quality in accordance with the requirements of the QA program. The Quality Control Inspectors report through this functional organization while performing maintenance and modification inspections for the operating facilities associated with MPS and VCS.

1.2.6 KPS Facility Operations A senior management position is responsible for overall safe operation of the plant and has control of onsite activities necessary for safe storage and maintenance of nuclear fuel. The necessary responsibility and authority for the management and direction of all activities related to the safe and efficient operation and decommissioning has been delegated by the senior executives. This responsibility includes ensuring quality through implementation of this QAPD in all the activities related to operation such as maintenance, testing, fuel storage, and modification.

1.2.6.1 Operations and Maintenance Facility operation and maintenance is directed by a management position responsible for Operations and Maintenance activities. Operations and Maintenance is responsible for operating the facility in accordance with the applicable license in the decommissioning phase for the safe storage and maintenance of nuclear fuel. The position responsibilities include: directing the operations; planning and coordinating maintenance and facility modifications; and maintaining compliance with requirements of the operating license, Technical Specifications, and applicable federal, state, and local laws, regulations, and codes.

Operations and Maintenance activities include monitoring and controlling day-to-day operation of the nuclear facility; responding to alarms; manipulating facility equipment; coordinating facility operations to manage work such as maintenance, testing, and modifications; and moving nuclear fuel.

Operations and Maintenance is responsible for maintenance activities.

Maintenance activities include installation; maintenance; alterations, adjustment and calibration; replacement; and repair of plant electrical and mechanical equipment, and instruments and controls. The responsibilities include performance of surveillances required by Technical Specifications, establishing standards and frequency of calibration for instrumentation and control devices, and ensuring instrumentation and related testing equipment are properly used, inspected and maintained.

18 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Organization The manager responsible for operations and maintenance is responsible for ensuring that personnel working under his/her authority are provided with the necessary training and resources to accomplish assigned tasks that fall within the scope of the quality assurance program, the operating license, Technical Specifications, and applicable federal state and local laws, regulations, and codes 1.2.6.2 Technical Support Technical Support is directed by a management position responsible for Technical Support functions. Technical Support functions for the facility include:

• engineering and design control, including interfacing with corporate Engineering Services;

• material management and procurement engineering; and

• acquisition of safety-related quality control inspection and authorized nuclear inspection services, as needed; and

• Facility Safety Review Group direction and coordination This group affords independence from cost and scheduling concerns to personnel performing quality verification functions. This group has the authority to suspend unsatisfactory work and control further processing or installation of non-conforming materials. The authority to stop work delegated to quality control inspection personnel is delineated in procedures.

The manager is responsible for ensuring that personnel working under his/her authority are provided with the necessary training and resources to accomplish assigned tasks that fall within the scope of the quality assurance program, the operating license, Technical Specifications, and applicable federal state. and local laws, regulations and codes.

1.2.6.3 Radiological Protection & Chemistry A management position is responsible for directing Radiological Protection &

Chemistry activities. Radiological Protection & Chemistry carries out health physics and chemistry functions and maintains sufficient organizational freedom to ensure their ability to perform their assigned functions as required by the facility Technical Specifications. A qualified supervisor or manager is assigned to fulfill the radiological protection manager position described in Section 2.5 of this QAPD. The radiological protection responsibilities include scheduling and conducting radiological surveys, contamination sample collection, determining contamination levels, assigning work restrictions through radiation work permits, administering the personnel monitoring program, and maintaining required records in accordance

19 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Organization with federal and state codes. The chemistry responsibilities include maintaining plant chemistry in accordance with established Technical Specification requirements.

The manager directing Radiological Protection & Chemistry activities is responsible for ensuring that personnel working under his/her authority are provided with the necessary training and resources to accomplish assigned tasks that fall within the scope of the Quality assurance program, the operating license, Technical Specifications, and applicable federal, state, and local laws regulations and codes.

1.2.6.4 Facility Programs and Processes Facility Programs and Processes involve activities for which independence is not a necessary attribute in the proper management and execution of the activity. Facility Programs and Processes are directed by a management position responsible for the identified activity. Facility programs and processes are directed by the manager responsible for Technical Support, the manager responsible for Operations and Maintenance, the manager responsible for Radiological Protection and Chemistry, a separate manager reporting to the senior manager responsible for KPS Facility Operations or a combination thereof.

Facility Processes and Programs include:

• project oversight;

• information technology support;

• purchasing;

• licensing;

• operating experience;

• corrective action program administration;

• loss prevention;

• fire protection program administration;

• training program administration and implementation in accordance with 10 CFR 50.120 and Technical Specifications;

• procedures, document control and records processes; and

• emergency preparedness support The manager responsible for directing facility program or process implementation under this section is responsible for ensuring that personnel working under his/her authority are provided with the necessary training and resources to accomplish assigned tasks that fall within the scope of the quality assurance program, the

20 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Organization operating license Technical Specifications, and applicable federal, state, and local laws regulations and codes.

1.2.7 KPS Supporting Services Supporting Services provided to the KPS facility for emergency preparedness, security and procurement are as described in Subsections 1.2.3 and 1.2.9 of this QAPD and as clarified below. Where implementation of any or all of these functions is delegated to organizations outside the Company, procedures require the establishment of interface documents including defining lines of communication and authorities as appropriate for the delegated functions. However, the applicable executive management position retains responsibility for the scope and effective implementation of the quality assurance program for those functions.

1.2.7.1 Protection Services The Protection Services group is responsible for providing facility security.

Protective services, includes physical security, nuclear facility access programs, and fitness for duty programs.

1.2.7.2 Emergency Preparedness The Emergency Preparedness group is responsible for development and maintenance of the radiological emergency plan and coordination with required off-site radiological emergency response groups for the nuclear facility. This includes managing the overall scheduling and coordination of emergency plan testing, training and exercises with federal, state, and local agencies, and working with corporate and facility personnel to ensure the emergency plan meets all requirements and commitments.

1.2.7.3 Supply Chain Management The Supply Chain Management group is responsible for Supplier surveillance functions and source and receipt inspection and, as needed, assists KPS Technical Support for material management, purchasing, and procurement engineering.

Supply Chain Management as described in Subsection 1.2.3.5 has the authority to control further processing or installation of nonconforming materials. This authority is delegated to inspection and surveillance personnel as delineated in procedures.

Qualified and certified personnel from KPS Technical Support may conduct supplier surveillance and source and receipt inspections. While performing these functions responsible Technical Support personnel report through Supply Chain Management.

21 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Organization 1.2.8 Nuclear Oversight (KPS support)

A management position is responsible for the verification of effective Company and Supplier QA program development, documentation, and implementation. A management position is responsible for the verification of effective Company and Supplier QA program development, documentation, and implementation, and the effective performance of Nuclear Oversight activities. This position is responsible for the performance of independent audits of facility operations related to quality and safety with lines of communication to the senior management position responsible for facility operations. This position is independent of cost and scheduling concerns associated with construction, operations, maintenance, modification, and decommissioning activities for performing quality assurance program verification. Where implementation of any or all of these functions is delegated to Suppliers, procedures require the establishment of interface documents including defining lines of communication and authorities as appropriate for the delegated functions. However, this management position retains responsibility for the scope and effective implementation of the quality assurance program for those functions. This management position has the necessary authority and responsibility for verifying quality achievement; identifying quality problems, recommending solutions and verifying implementation of the solutions; and escalating quality problems to higher management levels. This position has the authority to suspend unsatisfactory work and control further processing or installation of non-conforming materials. The authority to stop work delegated to Nuclear Oversight personnel is delineated in procedures.

Nuclear Oversight is responsible for the evaluation of Suppliers' quality programs through a system of external audits, surveys, evaluations, and/or reviews of Supplier performance in accordance with quality assurance requirements. A list of approved Suppliers is maintained.

Nuclear Oversight is responsible for assuring Company compliance with this QAPD through administration of a comprehensive and systematic internal audit program.

1.2.9 Engineering Services (KPS support)

An executive management position is responsible for nuclear analysis and fuel and information technology. These functions and activities include independent design checks and reviews and engineering technical support for the facility.

1.2.9.1 Nuclear Engineering and Fuel Nuclear Engineering and Fuel is responsible for activities related to safety and management of nuclear fuel. Nuclear Engineering and Fuel is responsible for engineering activities, evaluation, and analysis of fuel, and for providing engineering oversight of dry cask spent fuel storage system fabrication, including approval of nonconformance disposition.

22 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Organization 1.2.9.2 Information Technology A senior management position is responsible for direction and support of information technology for the nuclear organizations and facilities. Responsibilities include: network infrastructure maintenance and upgrade, network and application security, network operations; automation strategy, application development and support, automation training; development and maintenance of the software control program; and oversight, maintenance, and repair of the Emergency Response Facility Computer System.

1.3 Succession of Responsibility for Overall Plant Operation 1.3.1 The succession of responsibility for overall plant instructions or special orders, in the event of absences, incapacitation of personnel, or other emergencies, is as follows for Millstone, North Anna, Surry, and V.C. Summer unless otherwise designated in writing:

• the executive management position responsible for facility operations

• the senior management position responsible for facility operations & maintenance

• the management position responsible for operations 1.3.2 The succession of responsibility for overall plant instructions or special orders, in the event of absences, incapacitation of personnel, or other emergencies, is as follows for Kewaunee, unless otherwise designated in writing:

• senior management position responsible for facility operations

• management position responsible for operations and maintenance

• management position responsible for shift operations 1.4 Organization Charts Organization charts depicting reporting relationships are contained in Appendix A to this QAPD.

1.5 Quality Standards Commitment The Company is committed to establishing and maintaining an organization in accordance with the quality standards described in NQA-1-1994, Part I, Basic Requirement 1 and Supplement 1S-1.

23 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Quality Assurance Program Section 2 Quality Assurance Program 2.1 General Description Dominion Energy has established a quality assurance program for the nuclear power stations and independent spent fuel storage installations that complies with 10 CFR 50, Appendix B, as amended. A description of the QA program is contained within this Topical Report, designated as DOM-QA-1, and entitled Nuclear Facility Quality Assurance Program Description. This quality assurance program is based on the requirements of the Regulatory Guides and Industry Standards (with approved alternatives) described in Appendix C to this QAPD. The total quality assurance program consists of 1) the Policy statement on quality assurance (included in DOM-QA-1), 2) this Quality Assurance Program Description (QAPD), plus the 3) administrative controls and interface documents, and 4) training and qualification programs developed in accordance with this QAPD.

The application of this program accomplishes two important objectives: 1) provide orderly, uniform administrative and managerial documents to assure safe and reliable operation of nuclear facilities, and 2) assure compliance with regulations promulgated by the U.S. Nuclear Regulatory Commission. Quality assurance activities include planned and periodic audits, reviews, inspections, and other forms of verification to ensure adequacy and completeness of work and the effectiveness of quality programs. Measures are implemented to ensure individuals performing quality assurance audit and inspection/test activities have the authority and organizational freedom (including independence from cost and schedules relative to safety considerations) to identify problems, to recommend solutions, and to verify implementation and effectiveness of corrective actions.

2.2 Applicability This program applies to those activities that involve the safety-related functions of structures, systems, and components (SSCs) during design, construction, operation, and decommissioning of the Company's nuclear facilities, excluding the construction of new nuclear units. This QAPD also provides the elements for the corrective action process, confirmation process, and administrative controls of the renewed license aging management program (AMP) required for safety-related and nonsafety-related SSCs under a renewed license. The applicable provisions of this QAPD are put into place as early as practicable for the above phases of the facilities. Activities important to safety incorporate applicable portions of this program into their governing documents. Personnel participating in activities where this QA program is applicable are required to follow the established program requirements.

Suppliers may perform designated activities under their quality assurance program provided the supplier has been approved under the provisions of this QAPD. The Company implements measures to review and accept the Supplier's quality assurance program.

In addition to this QAPD, the following documents further describe application of portions of the QA program, where appropriate, for their associated nuclear facilities: The Safety Analysis Report

24 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Quality Assurance Program (SAR), renewed license aging management program (AMP), nuclear design control program, physical security plan, emergency plan, radiological protection plan including radioactive material transport and radioactive waste processing, fire protection plan, station blackout program, nuclear chemistry laboratory quality assurance program. As described in Appendix F of this QAPD, specific program controls are applied to certain nonsafety-related SSCs, for which 10 CFR 50, Appendix B, is not applicable, that are significant contributors to facility safety, have specific regulatory significance, or, when approved by license amendment, to safety-related SSCs categorized (see 2.2.1 below) as not significant contributors to facility safety. The specific program controls consistent with applicable sections of the QAPD are applied to those SSCs in a selected manner, targeted at those characteristics or critical attributes that render the SSC a significant contributor to facility safety.

2.2.1 Risk-Informed Categorization A license amendment approving the process established for categorization of SSCs as Risk Informed Safety Class (RISC) 1, 2, 3 or 4, in accordance with 10 CFR 50.69, permits certain alternative treatment from that of the deterministic process. Treatment will be as follows:

• RISC-1 SSCs are safety-related SSCs that the risk-informed categorization process determines to be significant contributors to plant safety. Treatment must continue to ensure that RISC-1 SSCs perform their safety-related and safety-significant functions consistent with the categorization process, including those safety-significant functions that go beyond the functions defined as safety-related for which credit is taken in the categorization process. The safety-related requirements contained in this QAPD and the regulations identified in 10 CFR 50.69(b)(i-xi) continue to apply. Additionally, special treatment of functions beyond safety-related that are credited must be provided that ensure SSC performance consistent with the key assumptions in the categorization process.

• RISC-2 SSCs are those that are defined as nonsafety-related, although the risk-informed categorization process determines that they are significant contributors to plant safety on an individual basis. Some RISC-2 SSCs may not have existing special treatment requirements. As a result, the focus for RISC-2 SSCs is on the safety-significant functions for which credit is taken in the categorization process. At a minimum, the QA measures described in Appendix F of this QAPD will be used to ensure credited functions receive appropriate treatment.

• RISC-3 SSCs are those that are defined as safety-related, although the risk-informed categorization process determines that they are not significant contributors to plant safety.

The safety-related requirements of this QAPD and the regulations identified in 10 CFR 50.69(b)(i-xi) are removed for RISC-3 SSCs and replaced with alternative treatment requirements intended to provide reasonable confidence that these SSCs remain capable

25 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Quality Assurance Program of performing their safety-related functions under design-basis conditions, including seismic conditions and environmental conditions and effects throughout their service life, albeit at a reduced level of assurance compared to the current special treatment requirements. RISC-3 SSCs are not permitted to lose their functional capability or be removed from the facility. At a minimum, treatment described in Appendix F of this QAPD will be used to ensure the capability of performance under design basis conditions.

Periodic inspection and testing activities and corrective actions will be carried out in accordance with the established 10 CFR 50, Appendix B, program.

• RISC-4 SSCs are those that are defined as nonsafety-related, and that the risk-informed categorization process determines are not significant contributors to plant safety. Section 50.69 does not impose alternative treatment for these RISC-4 SSCs. However, as with the RISC-3 SSCs, changes to the design bases of RISC-4 SSCs must be made in accordance with current applicable design change control requirements (if any) and the requirements of 10 CFR 50.59.

2.3 Oversight of the Quality Program Implementation In order to maintain an effective QA program, Nuclear Oversight performs periodic and systematic evaluations through internal and external audits of the programs implementation. The results of the evaluations and recommendations for improving the QA program are provided to the appropriate management responsible for implementation in the areas audited. Management provides oversight of quality program implementation and effectiveness by reviewing the results of audits in their area of responsibility and acting upon any deficiencies identified. In addition, management oversight of the quality program effectiveness is provided through the activities of review groups reporting to management. The composition and function of the review groups are described in Appendix B to this QAPD.

Quality Control inspection programs are established that provide for independent inspection of quality attributes. Craft personnel may perform these inspections, but the inspection program ensures individuals performing the inspections are not the same individuals or supervisors responsible for performing the activity being inspected. Individuals are assigned responsibility for the effective implementation of the quality inspection programs, to certify the qualification of inspection and test personnel, and to facilitate the raising of quality issues affecting nuclear safety to management. The authority to stop work delegated to personnel performing quality assurance roles is delineated in Company documents.

2.4 Identification of Structures, Systems, and Components (SSC)

Programs are established to identify those SSCs where the QA program applies. These programs are administratively controlled and are implemented by the groups responsible for design of the

26 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Quality Assurance Program facility. The SAR for the facility provides an overview of the SSCs that are safety-related or important to safety and require application of quality assurance measures of this program.

2.5 Selection, Training, and Qualification of Personnel The Company has established and implements programs and processes to ensure that personnel are knowledgeable in the applicable quality requirements before performing the activities to which this QAPD is applied. Management is responsible to ensure they have a trained and qualified staff.

The human resources group assists management by maintaining job descriptions, identifying potential candidates, and updating electronic organization charts that identify individuals filling responsible positions. The Nuclear Training group establishes and maintains training programs that meet the systematic approach to training of 10 CFR 50.120 and, with the exception of KPS, these programs are accredited by the National Nuclear Accrediting Board of the National Academy for Nuclear Training (NANT). Additional training is provided as needs are identified. The Company is committed to providing training (initial and continuing) that meets the standards, with alternatives, identified below for the applicable facility. These standards and alternatives are further addressed in Appendix C to this QAPD.

The retraining and replacement training programs for the NRC licensed facility staff meet or exceed the requirements of 10 CFR 55.59 and 55.31(a)(4) for the respective units and shall be maintained.

In addition, for units being decommissioned, a NRC approved training and retraining program for CERTIFIED FUEL HANDLERS shall be maintained as required by the license.

2.5.1 Facility Operating Staff The facility staff meets the qualifications described herein for the stated facilities.

2.5.1.1 Kewaunee Power Station Facility Staff Qualifications Each member of the facility staff shall meet or exceed the minimum qualification of ANSI N18.1-1971 for comparable positions, except for:

a. The radiation protection manager who shall meet or exceed the recommendation of Regulatory Guide 1.8, Revision 1-R, September 1975, or their equivalent as further clarified in Attachment 1 to the NRC Safety Evaluation Report enclosed with Amendment No. 46, dated July 12, 1982.

b. The Plant Manager (i.e., the senior manager responsible for the overall safe operation of the plant), shall have ten years of responsible power plant experience; of which a minimum of three years shall be nuclear power plant experience. A maximum of four years of the remaining seven years of experience may be fulfilled by academic training on a one-for-one time basis.

To be acceptable, this academic training shall be in an engineering or scientific

27 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Quality Assurance Program field generally associated with power production. Experience acquired at a nuclear facility for which permanent cessation of operation has been certified per 10 CFR 50.82(a)(1)(ii) may be credited as nuclear power plant experience.

c. The KPS manager responsible for Operations and Maintenance shall have a minimum of seven years of responsible power plant experience or applicable industrial experience, a minimum of one year of which shall be nuclear power plant experience in Operations, Maintenance or Engineering. A maximum of two years of the remaining six years of power plant or industrial experience may be fulfilled by satisfactory completion of academic or related technical training on a one-for-one time basis. Experience acquired at a nuclear facility for which permanent cessation of operation has been certified per 10 CFR 50.82(a)(1)(ii) may be credited as nuclear power plant experience.

d. The KPS manager responsible for Technical Support functions shall have a minimum of seven years of related experience in responsible positions, of which one year shall be nuclear power plant experience. A maximum of four years of the remaining six years of experience should be fulfilled by satisfactory completion of academic training. Experience acquired at a nuclear facility for which permanent cessation of operation has been certified per 10 CFR 50.82(a)(1)(ii) may be credited as nuclear power plant experience.

e. The KPS manager responsible for directing one or more Facility Programs and Processes described in 1.2.6.4, shall meet the qualifications described in 2.5.1.1.c or 2.5.1.1.d.

f. The KPS manager having overall responsibility for directing Radiological Protection and Chemistry activities (when other than the Radiation Protection Manager) shall meet the qualifications described in 2.5.1.1.c or 2.5.1.1.d.

g. Supervisory Personnel principally responsible for directing the actions of operators, technicians, or repairmen shall possess technical knowledge (through completed training or related nuclear experience) sufficient to ensure that the quality and functionality of equipment important to safety is properly controlled. The minimum qualifications cited in 2.5.1.1.c or 2.5.1.1.d satisfy this requirement.

2.5.1.2 Millstone Power Station Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions, except that:

1. The radiation protection manager shall meet or exceed the qualifications of Regulatory Guide 1.8, Revision 1, May 1977.

28 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Quality Assurance Program

2. As of November 1, 2001, applicants for reactor operator and senior reactor operator qualification shall meet or exceed the education and experience guidelines of Regulatory Guide 1.8, Revision 3, May 2000.

The following additional unit specific requirements will be maintained:

• Millstone Power Station Unit 1 The operations manager or at least one operations middle manager shall be a CERTIFIED FUEL HANDLER in accordance with the facility Technical Specifications.

• Millstone Power Station Unit 2

a. The operations manager or at least one operations middle manager shall hold a senior reactor operator license for Millstone Unit No. 2.

b. The Shift Technical Advisor (STA) who shall meet the requirements of (1) or (2) below:

(1) Dual-role individual: Must hold a senior reactor operators license at Millstone Unit 2, meet the STA training criteria of NUREG-0737, Item I.A.l.1, and meet one of the following educational alternatives:

(a) Bachelors degree in engineering from an accredited institution; (b) Professional Engineers license obtained by the successful completion of the PE examination; (c) Bachelors degree in engineering technology from an accredited institution, including course work in the physical, mathematical, or engineering sciences; (d) Bachelors degree in a physical science from an accredited institution, including course work in the physical, mathematical, or engineering sciences; (e) Successful completion of the Memphis State University (MSU) STA program. (Note: This alternative is only acceptable for individuals who have completed the program prior to December 31, 1986); or (f) Successful completion of the Thames Valley State Technical College associates degree in Nuclear Engineering Technology program, provided that the individual was enrolled in the program by October 1, 1987.

(2) Dedicated STA: Must meet the STA training criteria of NUREG-0737, Item I.A.1.1, and have received specific training in plant design, and response and analysis of the plant for transients and accidents.

29 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Quality Assurance Program

• Millstone Power Station Unit 3

a. The operations manager or at least one operations middle manager shall hold a senior reactor operator license for Millstone Unit No. 3.

b. The Shift Technical Advisor shall have a bachelors degree or equivalent in a scientific or engineering discipline and shall have received specific training in the response and analysis of the unit for transients and accidents, and in unit design and layout, including the capabilities of instrumentation and controls in the control room.

2.5.1.3 North Anna and Surry Power Stations These qualification requirements apply to the power stations and their associated Independent Spent Fuel Storage Installations. Each member of the facility staff shall meet or exceed the minimum qualifications of ANS-3.1 (12/79 Draft) for comparable positions except that the Radiological Protection Manager shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975. The following additional unit specific requirements will be maintained:

• North Anna Power Station The individual filling the role of operations manager and the individual filling the role of operations middle manager (supervisor shift operations) will meet the license requirements of North Anna Units 1 and 2 Technical Specification 5.2.2.e.

• Surry Power Station The individual filling the role of operations manager and the individual filling the role of operations middle manager (supervisor shift operations) will meet the license requirements of Surry Units 1 and 2 Technical Specification 6.1.2.2.d.

2.5.1.4 V. C. Summer Nuclear Station Each member of the facility staff shall meet or exceed the minimum qualifications of:

• ANS-3.1-1981 with the regulatory positions from NRC Regulatory Guide 1.8, Revision 2, April 1987 for the equivalent positions described in the standard as shift supervisor, senior operator, licensed operator, shift technical advisor, and radiation protection group leader (or radiation protection manager (RPM)).

• ANS/ANSI N18.1-1971 for the equivalent positions described in the standard other than those identified in the above paragraph.

• In lieu of the training requirements stated in ANS-3.1-1981 and ANSI N18.1-1971, VCS commits to using accredited training programs for the categories identified in 10 CFR 50.120.

30 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Quality Assurance Program 2.5.2 Support Organizations Personnel performing support activities may either meet the qualification requirements of the standards referenced above for the facility they are performing the function for, or the qualification requirements of ANSI/ANS-3.1-1993 as endorsed by NRC Regulatory Guide 1.8, Revision 3.

2.5.3 Quality Assurance Verification Personnel Personnel performing the following quality verification activities meet the qualification requirements of ANSI/ANS-3.1-1993, and the applicable Regulatory Positions of NRC Regulatory Guide 1.8, Revision 3, for the activities they perform.

2.5.3.1 Management Position Responsible for Quality Assurance or Quality Control The person(s) filling the management position responsible for quality assurance or quality verification (audits, inspections and tests, surveillances of Company or Supplier activities, and NDE) will meet the requirements of Section 4.3.7 and Regulatory Position 2.1.1.

2.5.3.2 Supervisor/Coordinator Responsible for Quality Assurance or Quality Control The person(s) filling the supervisor or coordinator position responsible for quality assurance or quality verification (audits, inspections and tests, surveillances of Company or Supplier activities, and NDE) will meet the requirements of Section 4.4.13. This position includes responsibility for verifying that personnel performing the quality assurance or quality verification activities are qualified for their assigned tasks. The quality assurance and quality verification programs identify the management position responsible for certifying that personnel meet the qualification requirements. For visual examinations to meet the ASME code, the training group may be delegated responsibility for the certification.

2.5.4 Quality Assurance Audits Personnel performing audits are trained and qualified in accordance with a program that meets the applicable requirements of NQA-1-1994, Part I, Basic Requirement 2 and Supplement 2S-3.

2.5.5 Quality Control Verification Personnel performing quality control verification through inspection and test, or surveillance activities (inspectors) are trained and qualified in accordance with a program that meets the applicable requirements of NQA-1-1994, Part I, Basic Requirement 2, Supplement 2S-1,

31 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Quality Assurance Program and Appendix 2A-1. The following alternatives may be applied to the qualification requirements:

1.

In lieu of being certified as Level I, II, or III in accordance with NQA-1-1994, personnel performing operations phase independent quality verification inspections, examinations, measurements, or tests of material, products, or activities will be required to possess qualifications equal to or better than those required for performing the task being verified; and the verification is within the skills of these personnel and/or is addressed by procedures.

These individuals will not be responsible for the planning of quality verification inspections and tests (i.e., establishing hold points and acceptance criteria in procedures, and determining who will be responsible for performing the inspections), evaluating inspection training programs, nor certifying inspection personnel.

2.

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

2.5.6 Non-Destructive Examination Technicians Personnel performing NDE are trained and qualified in accordance with a program that meets the applicable requirements of NQA-1-1994, Part I, Basic Requirement 2 and Supplement 2S-2. Except that the reference to SNT-TC-1A, June 1980 is changed to the qualification standard as specified in the applicable facilitys commitment to the ASME code or other applicable code governing the activity.

2.5.7 ASME Code Visual Examinations Personnel performing visual examinations (VT) required by the ASME code are qualified and certified according to the Code requirements for the applicable facility.

2.6 Control of Activities The Company has established administrative controls over activities for the nuclear facilities in accordance with the quality assurance program. These ensure that the applicable elements of 10 CFR 50, Appendix B are addressed during the performance of the activities. These programs include the appropriate use of qualified personnel, procedures, and methods when performing the activities. They also address special controls necessary such as environmental conditions, cleanliness, housekeeping, use of special or calibrated equipment, and specific operating modes or conditions. Where appropriate, the controls include specifying acceptance criteria that assure

32 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Quality Assurance Program suitable performance of the SSCs. These controls are further addressed throughout this QAPD and within the standards committed to by this QAPD.

2.7 Quality Standards Commitment The Company is committed to implementing a quality assurance program in accordance with the quality standards described in NQA-1-1994, Part I, Basic Requirement 2, its associated Supplements, Part II, Subparts 2.1 and 2.3, and Part III, Subpart 3.1, Appendix 2A-1, and Subpart 3.2, Appendix 2.1 (VCS only), including alternatives identified herein and in Appendix C. The Company also commits to implementing the other standards with alternatives described within Section 2 and those delineated in Appendix C to this QAPD. Alternatives, exceptions, and/or clarifications to the standards for selection, training, and qualification of personnel are specifically addressed within the subsections discussing those commitments for each facility. The following alternatives are applicable to the NQA-1-1994 standards identified in this subsection:

2.7.1 NQA-1-1994, Part II, Subpart 2.1 Subsections 3.1 and 3.2 establish criteria for classifying items into cleanness classes and requirements for each class. Instead of using the cleanness level system of Subpart 2.1, the Company may establish cleanness requirements on a case-by-case basis, consistent with the other provisions of Subpart 2.1. The Company establishes appropriate cleanliness controls for work on safety-related equipment to minimize introduction of foreign material and maintain system/component cleanliness throughout maintenance or modification activities, including documented verification of absence of foreign material prior to system closure.

2.7.2 NQA-1-1994, Part II, Subpart 2.3 The Company may choose to not utilize the five-level zone designations required by Subsection 2.3, but will utilize work practices, as described in administrative controls, that provide an equivalent level of cleanliness control required by the subpart. This will include as a minimum documented cleanliness inspections which will be performed prior to system closure. As necessary, (e.g., the size of the opening would permit entry of the tools being used) control of personnel, tools, equipment, and supplies will be established when major portions of the reactor system are opened for inspection, maintenance, or repair. Factors considered in developing the administrative controls include cleanness requirements, personnel safety, fire prevention and protection, radiation control, and security. The controls make use of standard janitorial and work practices to the extent possible.

33 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Design Control Section 3 Design Control 3.1 General Description The Company has established and implements administrative controls to assure quality is achieved in establishing and changing the design for the nuclear facilities in accordance with industry standards and regulatory requirements. These provisions address control of design inputs, processes, outputs, changes, interfaces, records, and organizational interfaces. The administrative controls designate the design organization that has approval authority for the design, including design changes and modifications.

3.2 Design Control Program The design control program ensures design inputs are correctly translated into specifications, drawings, procedures, and instructions in sufficient detail to permit verification. The design process controls the selection and independent verification of items and activities consistent with their importance to safety, to ensure that they are suitable for their intended application. The design process includes provisions for performing appropriate reviews by nuclear management, operating and corporate safety review committees, and for required regulatory evaluations. Errors and deficiencies in design, including the design process, which could adversely affect quality structures, systems, and components, are documented and corrective action is taken in accordance with Section 15 and Section 16 of this QAPD.

3.2.1 Design Change Control Procedures and instructions govern identifying the need to change the design and a documented method to control these changes. Design and specification changes (including temporary changes, e.g., temporary bypass lines, electrical jumpers and lifted wires, and temporary setpoints) are subject to design control measures commensurate with those applied during the original design as amended by applicable design or licensing basis changes. The design change process includes notifications of changes to responsible plant personnel prior to implementation in accordance with applicable procedures.

3.2.2 Design Interface Control Procedures and instructions establish interface controls between functional groups and with principal Suppliers. The interface controls include processes for the resolution of design questions related to the nuclear facilities.

3.2.3 Design Verification The design control program establishes and implements design verification procedures and instructions to ensure that an appropriate verification method (including, but not limited to, design reviews, alternate calculations, and qualification testing) is used, the appropriate

34 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Design Control design parameters are chosen, the acceptance criteria are identified, the verification is satisfactorily accomplished, and the results are properly recorded. Measures are included that assure the independence of individuals performing design verification. The verifier shall not have taken part in the selection of design inputs, the selection of design considerations, or the selection of a singular design approach, as applicable. If the verification is performed by the originator's supervisor, the justification of the need is documented and approved in advance by management. The Company is responsible for assuring that the design documents generated by Suppliers for the Company's nuclear facilities are technically correct, approved, and maintained.

3.2.4 Computer Application and Digital Equipment Software Design and Control The Company has established programs and procedures to ensure that computer application or digital equipment software is appropriately procured or designed and verified suitable for the intended application. Measures are also taken to control the use and maintenance of computer application or digital equipment software. The computer application or digital equipment software is assigned a quality classification and quality requirements are applied consistent with that classification.

3.2.5 Setpoint Control Instrument and equipment setpoints that could affect nuclear safety shall be controlled in accordance with written instructions. As a minimum, these written instructions shall:

• Identify responsibilities and processes for reviewing, approving, and revising setpoints and setpoint changes originally supplied by the A/E for the facility and the station's technical staff;

• Ensure setpoints and setpoint changes are consistent with design and accident analysis requirements and assumptions;

• Provide for documentation of setpoints, including those determined operationally; and,

• Provide for access to necessary setpoint information for personnel who write or revise facility procedures, operate or maintain facility equipment, develop or revise design documents, or develop or revise accident analyses.

3.3 Quality Standards Commitment The Company commits to meeting the standards for design control of NQA-1-1994, Part I, Basic Requirement 3 and Supplement 3S-1, and the standards for computer software contained in Part II, Subpart 2.7.

35 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Procurement Document Control Section 4 Procurement Document Control 4.1 General Description The Company has established and implements administrative controls and processes to assure that applicable regulatory, technical, and QA program requirements are included or referenced in procurement documents. These measures ensure procurement documents identify applicable regulatory, technical, administrative, and reporting requirements (such as specifications, codes, standards, tests, inspections, special processes, and 10 CFR Part 21); drawings; specifications; codes and industrial standards; test and inspection requirements; and special process instructions that must be complied with by Suppliers. Procedures further define when procurement documents require Suppliers and subtier Suppliers to provide acceptable quality assurance programs, or for services the Supplier works under the Dominion Energy QA program.

4.2 Preparation, Review, and Approval of Procurement Documents Established procedures and instructions describe organizational responsibilities that include:

procurement planning; the preparation, review, approval, and control of procurement documents; Supplier selection; bid evaluations and review and concurrence of Supplier QA programs prior to initiation of activities affected by the program. Where original technical or quality assurance requirements cannot be determined, an engineering evaluation is conducted and documented by qualified staff to establish appropriate requirements and controls to assure that interfaces, interchangeability, safety, fit, and function, as applicable, are not adversely affected or contrary to applicable regulatory requirements. Procedures ensure procurement documents are reviewed to verify that quality requirements are: 1) correctly stated, inspectable, and controllable; 2) have adequate acceptance and rejection criteria; and 3) are prepared, reviewed, and approved in accordance with this QAPD. These procedures also identify those personnel authorized to perform the reviews and their qualification requirements including training in QA practices and concepts.

The Company performs applicable internal and external audits, assessments, and inspections to ensure compliance with quality assurance program requirements for the control of procurement documents.

4.3 Quality Standards Commitment The Company commits to meeting the quality assurance standards for procurement document control of NQA-1-1994, Part I, Basic Requirement 4 and Supplement 4S-1 with the following clarification:

4.3.1 Supplement 4S-1, subsection 2.3 requires that the Supplier have a documented quality assurance program. The procurement documents may allow Suppliers of services to work under the Dominion Energy QA program, including implementing procedures, in lieu of the supplier having its own QA Program.

36 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Instructions, Procedures, and Drawings Section 5 Instructions, Procedures, and Drawings 5.1 General Description The Company has established and implements administrative controls to assure that activities affecting quality are prescribed by and performed in accordance with documented instructions, procedures, and drawings. Provisions include the preparation, review, approval, control and distribution of procedures, instructions and drawings for activities affecting quality structures, systems, and components of Company nuclear facilities. These documents are controlled in accordance with Section 6 of this QAPD.

Instructions, procedures, and drawings are prepared and approved prior to implementation. These documents are sufficiently detailed to allow a qualified individual to perform the required function without direct supervision, and assure consistent and acceptable results in accordance with regulatory guidance and industry quality standards. Management responsible for each functional group has responsibility for assuring that their activities affecting quality are 1) prescribed by documented instructions, procedures, and drawings and 2) accomplished through implementation of these documents.

5.2 Procedure Adherence The Company policy is that procedures are followed, and the requirements for use of procedures have been established in administrative procedures. Where procedures cannot be followed as written, provisions are established for making changes in accordance with Section 6 of this QAPD.

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

In cases of emergency, personnel are authorized to depart from approved procedures when necessary to prevent injury to personnel or damage to the plant. Such departures are recorded describing the prevailing conditions and reasons for the action taken.

5.3 Procedure Content This QAPD does not establish any specific format or style for procedures, this information will be contained in the administrative controls applicable to the facility. The format of procedures may vary based on the applicable facility or the tasks being performed. Where appropriate, checklists (check-off lists) are used with the procedures to ensure accurate completion. Procedures include the

37 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Instructions, Procedures, and Drawings applicable elements described in NQA-1-1994, Part II, Introduction, Section 4.2, (a)-(p), and the following additional elements, where appropriate:

• Title. Each procedure contains a title descriptive of the work or system or unit to which it applies, a revision number or date, and an approval status.

• Statement of Applicability/Purpose. When the procedures purpose is not clear from the title, a separate statement of applicability is provided.

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

Limitations and setpoints may be identified in a separate section. Where appropriate, quantitative control guides are provided.

5.4 Types of Procedures and Instructions The types of procedures and instructions to be developed and used will vary according to the phase that a facility is in as well as the type of facility and activities conducted. This subsection is intended to provide an overview of these types, but is not intended to specify any particular name or format for these documents and some types may be combined. Certain types of procedures and instructions are common to all facilities, but individual facility terminology may vary. The Company programs ensure the procedures identified in the facilitys technical specifications and the applicable types of procedures described in Regulatory Guide 1.33, Rev. 2, Appendix A, are developed, maintained, and implemented for the nuclear facilities in the operational or decommissioning phase.

5.4.1 Administrative Controls These include administrative procedures, directives, policies, standards, and similar documents that control the programmatic aspects of facility activities. These administrative documents ensure that the requirements of regulatory and license commitments are implemented. Several levels of administrative controls are applied ranging from those affecting the entire Company down to those prepared at the implementing group level.

These documents establish responsibilities, interfaces, and standard methods (rules of practice) for implementing programs. In addition to the administrative controls described throughout this QAPD, instructions governing the following activities are provided:

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

38 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Instructions, Procedures, and Drawings

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

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

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

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

5.4.3 Installation Procedures These documents provide instructions for the installation of components generally related to new construction and certain modification activities. They include appropriate reference to industry standards, installation specifications, design drawings, and Supplier and technical

39 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Instructions, Procedures, and Drawings manuals for the performance of activities. These documents include provisions, such as hold or witness points, for conducting and recording results of required inspections or tests.

These documents may include applicable inspection and test instructions subject to the requirements for test and inspection procedures below.

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

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

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

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

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

5.4.8 Process Monitoring Procedures These documents contain instructions for monitoring performance of plant systems to assure that core thermal margins and coolant quality are maintained in acceptable status at

40 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Instructions, Procedures, and Drawings all times, that integrity of fission product barriers is maintained, and that engineered safety features and emergency equipment are in a state of readiness to keep the plant in a safe condition if needed. Maximum and minimum limits for process parameters are appropriately identified. Operating procedures address the appropriate nature and frequency of this monitoring.

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

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

41 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Instructions, Procedures, and Drawings 5.4.11 Radiation Control Procedures These documents contain instructions for implementation of the radiation control program requirements necessary to meet regulatory commitments, including acquisition of data and use of equipment to perform necessary radiation surveys, measurements and evaluations for the assessment and control of radiation hazards. These procedures provide requirements for monitoring both external and internal exposures of employees, utilizing accepted techniques; routine radiation surveys of work areas; environmental monitoring in the vicinity of the plant; radiation monitoring of maintenance and special work activities, and for maintaining records demonstrating the adequacy of measures taken to control radiation exposures to employees and others.

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

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

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

42 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Instructions, Procedures, and Drawings 5.4.15 Emergency Plan Implementing Procedures These documents contain instructions for activating the Emergency Response Organization and facilities, protective action levels, organizing emergency response actions, establishing necessary communications with local, state and federal agencies, and for periodically testing the procedures, communications and alarm systems to assure they function properly. Format and content of such procedures are such that requirements of each facilitys NRC approved Emergency Plan are met.

5.4.16 Test and Inspection Procedures These documents provide the necessary measures to assure quality is achieved and maintained for the nuclear facilities. The instructions for tests and inspections may be included within other procedures, such as installation and maintenance procedures, but will contain the objectives, acceptance criteria, prerequisites for performing the test or inspection, limiting conditions, and appropriate instructions for performing the test or inspection, as applicable. These procedures also specify any special equipment or calibrations required to conduct the test or inspection and provide appropriate documentation and evaluation by responsible authority to assure test or inspection requirements have been satisfied. Where necessary, hold or witness points are identified within the procedures and require appropriate approval for the work to continue beyond the designated point. These procedures provide for recording the date, identification of those performing the test or inspection, as-found condition, corrective actions performed (if any),

and as-left condition, as appropriate for the subject test or inspection.

5.4.17 Procedures Specific to Kewaunee Power Station (KPS)

KPS License Amendment 220 relocated certain requirements from Technical Specification TS 5.4, Procedures, to this QAPD. These requirements direct that written procedures shall be established, implemented, and maintained covering the following activities:

a.

Quality assurance for effluent and environmental monitoring; b.

Fire Protection Program implementation; c.

Radioactive Effluent Controls Program; and d.

Storage Tank Radioactivity Monitoring Program

43 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Instructions, Procedures, and Drawings 5.5 Quality Standards Commitment The Company commits to meeting the standards for instructions, procedures, and drawings of NQA-1-1994, Part I, Basic Requirement 5. Additional requirements regarding the content of procedures for specific activities delineated in NQA-1-1994, Part II, will also be implemented as appropriate to the activity.

44 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Document Control Section 6 Document Control 6.1 General Description The Company has established and implements administrative controls to assure the preparation, review, approval, and issuance of controlled documents and changes thereto. These controls assure technical adequacy and inclusion of appropriate quality requirements prior to implementation. Measures are provided to assure that documents, including revisions or changes, are reviewed for adequacy by knowledgeable personnel other than those who originated or prepared the document, approved for release by authorized personnel, and distributed in accordance with current approved methods. In order to ensure that the documents in current use provide the best possible instructions for performance of the work involved, reviews and/or feedback of information based on use is provided for within the implementing programs. During construction and modification activities, drawings and related documentation are updated in a timely manner to accurately reflect the actual facility design.

6.2 Applicability The provisions for controlling documents include, but are not limited to, the following types of documents:

• Engineering calculations and analyses, design and as-built drawings, design and installation specifications, computer codes

• Purchase orders and related documents, Supplier provided documents

• Instructions, procedures, and drawings used for activities such as siting, designing, procuring, fabricating, handling, shipping, receiving, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, calibrating, repairing, refueling, responding to emergencies, modifying, and decommissioning (including those documents describing organizational interfaces)

• Topical reports, quality assurance and quality control manuals and procedures

• Technical Specifications

• Reports of nonconformance resolution and corrective actions 6.3 Document Review and Approval Administrative procedures provide measures to control and coordinate the approval and issuance of documents, including changes thereto that prescribe all activities affecting quality. Procedures describe the review process and establish who is to perform document reviews and any applicable qualification requirements.

Each procedure (including those that are programmatic in nature) is reviewed and approved prior to initial use. The frequency of subsequent reviews varies depending on the frequency of use, type

45 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Document Control and complexity of the activity involved. Applicable procedures are reviewed following an unusual incident, such as an accident, an unexpected transient, significant operator error, or equipment malfunction, and following any modification to a system.

Installation, maintenance, modification, and inspection procedures may include inspection requirements, methods, and acceptance criteria according to the established QA inspection program. When a change is made to any of these inspections, it is reviewed by personnel knowledgeable in QA requirements.

Documents, including procedures, programs and changes thereto are approved by responsible management or the facility safety review committee, as applicable. Where common procedures or programs are used for multiple facilities, responsible management or the facility safety review committee for each applicable facility must review the procedures or programs.

6.4 Additional Operations and Decommissioning Phase Review Requirements Procedures and programs, including subsequent changes, for operations and decommissioning phase activities are screened to determine if further regulatory evaluation is required to meet 10 CFR Sections 50.59 or 72.48. Procedures and programs that are determined to require further regulatory evaluation are reviewed by the facility safety review committee as described in Appendix B, of this QAPD. The facility safety review committee may require any procedure, program, or changes thereto to be brought before the committee for review.

Administrative controls ensure periodic reviews are performed for procedures that have specific regulatory review requirements. Additional administrative and programmatic controls ensure procedures are maintained current. These controls include pre-job preparation practices and the procedural adherence policy (as discussed in Section 5). In addition, plant procedures are audited or reviewed as part of routine Nuclear Oversight processes providing assurance that existing administrative controls for procedure verification, review, and revision are effective in maintaining the quality of plant procedures.

If a temporary procedure change is required, it will be reviewed and approved in accordance with

1) the applicable facility technical specification requirements, or 2) the provisions of this QAPD when not addressed in the technical specifications, or 3) for VCS, changes that clearly do not change the intent of the approved procedure may be implemented provided the changes are approved by two members of the facility management staff, at least one of whom holds a Senior Reactor Operator's License. Such changes are documented and, if appropriate, incorporated in the next revision of the affected procedure.

6.5 Distribution of Controlled Documents Provisions ensure current documents are available prior to commencing work. Computerized processes may be used to make controlled documents available to users. Where computerized

46 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Document Control distribution is made, administrative controls ensure the record file for the document contains the appropriate review and approval documentation.

Administrative controls are established to assure the timely removal and replacement of obsolete or superseded documents in work areas with applicable revisions. The Company maintains a record of all holders of controlled documents and drawings. An index or file of all controlled documents that lists the current revision or date is maintained so personnel can readily identify the current revision.

6.6 Quality Standards Commitment The Company commits to meeting the quality assurance standards for document control of NQA-1-1994, Part I, Basic Requirement 6 and Supplement 6S-1.

47 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Control of Purchased Material, Equipment, and Services Section 7 Control of Purchased Material, Equipment, and Services 7.1 General Description The Company has established and implements programs, procedures, and processes for the control of purchased items and services, selection of Suppliers, and assessing the acceptability of quality. The Company procedures define the organizational responsibilities for the control of purchased items and services including interfaces between design, procurement, and quality verification organizations.

7.2 Selection of Suppliers Procedures describe the Supplier selection process, including measures to ensure continued acceptable quality from Suppliers. Prospective Suppliers are evaluated based on the items and services they provide and the degree of quality required. The evaluation process ensures only qualified Suppliers are selected. Industry programs, such as those applied by ASME, Nuclear Procurement Issues Corporation (NUPIC), or other established utility groups, are used as input or the basis for supplier qualification whenever appropriate. The Suppliers are periodically evaluated to ensure they continue to provide acceptable products and services. A controlled list of qualified Suppliers is maintained by Nuclear Oversight and made available to the organizations responsible for procuring items and services. Audits, surveillances, inspections, and NRC correspondence used in the evaluation of Suppliers are specifically identified in the evaluation documentation to allow retrieval of the information.

7.3 Conformance of Items and Services Procurement documents identify to the Supplier applicable technical, regulatory, administrative, and reporting requirements. These requirements include specifications, codes, standards, tests, inspections, special processes, reporting in accordance with 10 CFR 21, documentation that identifies the purchased item and the specific procurement requirements met by the item, documentation identifying any procurement requirements that have not been met, and a description of those nonconformances from the procurement requirements dispositioned accept as-is or repair.

The procurement documents identify the technical and quality requirements based on the intended service and the requirements of the current Company QAPD in effect at the time of procurement.

These requirements also apply to the procurement of spare and replacement parts such that the specifying of technical requirements is equal to or better than the original requirements to preclude repetition of defects. For commercial grade (off-the-shelf) items, special quality verification requirements are established and described in Company documents to provide the necessary assurance an item will perform satisfactorily in service. The Company documents address determining the critical characteristics that ensure an item is suitable for its intended use, technical evaluation of the item, receipt requirements, and quality evaluation of the item. The purchase of

48 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Control of Purchased Material, Equipment, and Services commercial grade calibration services from a calibration laboratory may be made in accordance with the alternative to NQA-1-1994, Part I, Supplement 7S-1 requirements described in Section 7.5 below.

7.4 Quality Verification Nuclear Oversight, Nuclear Analysis and Fuel, and Supply Chain Management use a systematic approach through audits, independent inspections, surveillances, or tests to verify Supplier quality including, as necessary, verification of activities of suppliers below the first tier. Personnel from these groups verify Suppliers activities during fabrication, inspection, testing, and shipment of items. Suppliers certificates of conformance are periodically evaluated to assure they are valid.

Additional quality verifications are performed to assure conformance with purchase requirements during receipt inspection, or through pre-installation or post-installation tests. Prior to items being placed in service or used at Company nuclear facilities, responsible inspection personnel verify that required Supplier documentary evidence that the items conform to purchase requirements is available on site. These verification activities are planned, performed, and documented in accordance with written Company documents. The Company documents identify: 1) the characteristics or processes to be witnessed, inspected, verified, evaluated, and accepted; 2) the method of verification; 3) at what interval in the fabrication or manufacture to perform verification;

4) the extent of documentation required; and 5) those responsible for implementing these verification activities.

7.5 Quality Standards Commitment The Company commits to meeting the quality assurance standards for control of purchased material, equipment, and services contained in NQA-1-1994, Part I, Basic Requirement 7, and Supplement 7S-1, with the following alternatives and exceptions:

7.5.1 NQA-1-1994, Part I, Supplement 7S Exception

• Dominion Energy considers that other 10 CFR 50 licensees, Authorized Nuclear Inspection Agencies, National Institute of Standards and Technology, or other State and Federal agencies which may provide items or services to the Company facilities are not required to be evaluated or audited.

7.5.2 NQA-1-1994, Part I, Supplement 7S Alternative

• Commercial-grade calibration and/or testing services may be procured from commercial laboratories based on the laboratory's accreditation to 17025:2017 by an Accreditation Body (AB) which is a signatory to the International Laboratory Accreditation and Cooperation (ILAC) Mutual Recognition Arrangement (MRA) provided all of the following are met:

49 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Control of Purchased Material, Equipment, and Services 1.

A documented review of the supplier's accreditation is performed and includes a verification of the following:

a.

The calibration or test laboratory holds accreditation by an accrediting body recognized by the ILAC MRA. The accreditation encompasses ISO/IEC 17025:2017, General Requirements for the Competence of Testing and Calibration Laboratories.

b.

For procurement of calibration services, the published scope of accreditation for the calibration laboratory covers the needed measurement parameters, ranges, and uncertainties.

c.

For procurement of testing services, the published scope of accreditation for the test laboratory covers the needed testing services including test methodology and tolerancesuncertainty.

2.

The purchase documents require that:

a.

The service must be provided in accordance with their accredited ISO/IEC 17025:2017 program and scope of accreditation.

b.

For calibration services, as-found calibration data must be reported in the certificate of calibration when calibrated items are found to be out-of-tolerance.

c.

For calibration services, the equipment/standards used to perform the calibration must be identified in the certificate of calibration.

d.

Dominion Energy must be notified of any condition that adversely impacts the laboratory's ability to maintain the scope of accreditation.

e.

The laboratory performing the calibration and/or testing service shall not subcontract the service to any other supplier.

f.

Performance of the services listed on this purchase order is contingent on the laboratorys accreditation having been achieved through an on-site accreditation assessment by the Accreditation Body (AB) within the past 48 months.

g.

Any additional technical and quality requirements, as necessary, based upon a review of the procured scope of services, which may include, but are not necessarily limited to, tolerances, accuracies, ranges, and industry standards.

3.

It is validated, at receipt inspection, that the laboratory's documentation certifies that:

a.

The contracted calibration or test service has been performed in accordance with their ISO/IEC 17025:2017 program and has been performed within their scope of accreditation, and

50 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Control of Purchased Material, Equipment, and Services b.

The purchase order's requirements are met.

NOTE: The ILAC accreditation process cannot be used as part of the commercial-grade dedication process of nondestructive examination (NDE) or nondestructive testing (NDT) services in lieu of performing a commercial-grade survey. This is applicable to both American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code and non-ASME B&PV Code safety-related applications.

7.5.3 NQA-1-1994, Part I, Supplement 7S-1, Section 10, Commercial Grade Items -

Alternative Controls for commercial grade items are established in Company documents using the guidance of:

• NRC Regulatory Guide 1.164, Rev. 0, June 2017, Dedication of Commercial-Grade Items for Use in Nuclear Power Plants, with the identified exceptions and clarifications to the use of EPRI 3002002982.

• EPRI 3002002982, September 2014, Plant Engineering: Guideline for the Acceptance of Commercial-Grade Items in Nuclear Safety-Related Applications, Revision 1 to EPRI NP-5652 and TR-102260.

7.5.4 NQA-1-1994, Part 1, Supplement 7S-1, Section 8 and 10 - Alternative Remote source verification (vendor surveillance, inspection, and audit) using live audio/

video technology is allowed as an alternate method to source verification activities supporting commercial grade dedication or other acceptance process when exigent conditions such as a pandemic or similar state of emergency declarations exist that restricts access or travel to and/or from vendor locations affected by the declaration. The use of remote vendor surveillance shall be in accordance with EPRI 3002019436-A, October 2020, Remote Source Inspection During a Pandemic or Similar State of Emergency: Screen Criteria and Process Guidance, Final Report with NRC Safety Evaluation, to screen eligibility, plan verification activities, establish suitable display media, and document verification activities for quality record purposes.

51 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Identification and Control of Materials, Parts, and Components Section 8 Identification and Control of Materials, Parts, and Components 8.1 General Description The Company has established and implements administrative controls and processes for the identification and control of items such as materials (including consumables), parts, components, and partially fabricated subassemblies. Implementing procedures establish the responsibilities and requirements for the identification and control of items throughout fabrication, receipt, handling, storage, and installation to assure that incorrect or defective items are not used. Such requirements include instruction on the use of markings, tags, labels, or record keeping for identification so that the items are not adversely affected by the method of identification.

The methods used for identification of items assure traceability of the items to the appropriate documentation such as drawings, specifications, purchase orders, manufacturing and inspection documents, problem reports, and physical and chemical mill test reports. Procedures include responsibilities and methods for verification and documentation of the correct identification of items prior to release for fabrication, assembling, shipping, and installation.

8.2 Quality Standards Commitment The Company commits to meeting the quality assurance standards for identification and control of items contained in NQA-1-1994, Part I, Basic Requirement 8 and Supplement 8S-1.

52 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Control of Special Processes Section 9 Control of Special Processes 9.1 General Description The Company has established and implements programs, procedures, and processes to assure the acceptability of special processes through the use of procedures, technique sheets, travelers and inspection verification reports, and personnel qualified in accordance with the applicable codes, specifications, and standards for the specific work. Special processes are those where interim process controls are necessary to ensure a final acceptable product and where reliance on a final inspection or test is insufficient to determine quality. Special processes include, but are not limited to, those involving: welding; heat treating; cadwelding; non-destructive examination and testing; painting and coatings; concrete and grout; soils and earthwork; and removal of undesirable substances during shop and site cleaning, degreasing, and flushing. In instances where Suppliers are assigned such work at Company facilities, the Supplier must submit their procedures and personnel qualifications to the Company for approval prior to the start of work.

9.2 Qualification of Special Processes Personnel, Procedures, and Equipment Company documents assure that procedures, equipment, and personnel associated with special processes are qualified and are in conformance with applicable codes, standards, QA procedures, and specifications. In addition, Company documents establish the method for recording evidence of the acceptable accomplishment for special processes. The Company conducts inspections and/or audits of work involving special processes to assure that procedures and personnel are properly qualified and their workmanship is in compliance with applicable specifications, codes, standards, and QA procedures.

Qualification records of procedures, equipment, and personnel associated with special processes are established, filed, and kept current in accordance with the provisions of this QAPD.

9.3 Quality Standards Commitment The Company commits to meeting the standards for control of special processes from NQA-1-1994, Part, I, Basic Requirement 9 and Supplement 9S-1.

53 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Inspection Section 10 Inspection 10.1 General Description The Company has established and implements administrative controls and processes to inspect activities for the nuclear facilities that affect quality to verify conformance with the approved documents for accomplishing the activities including specifications and quality standards. The programs govern establishment of inspection hold points beyond which work is not to continue until a satisfactory inspection is achieved. The inspections are performed by trained and qualified individuals, in accordance with controlled documents, and to established acceptance criteria. The inspection program maintains reporting independence of inspectors by ensuring individuals performing the inspections are not the same individuals or supervisors responsible for performing the activity being inspected. Where quality verification inspections at operating facilities are performed by the Maintenance group, to meet the independence requirements of NQA-1-1994, Part I, Supplement 10S-1, Section 3.1, the inspectors report to the Facility Safety and Licensing organization (VA), Technical Support (KPS), or the Nuclear Oversight group (MPS and VCS) while performing the inspection. Management review and audit of inspection results is established to ensure effectiveness of the inspection program.

10.2 Inspection Program The inspection program establishes inspections (including surveillance of processes), as applicable: 1) at the source of supplied items or services, 2) in-process during fabrication at a Suppliers facility or at a Company facility, 3) for final acceptance of fabricated and/or installed items during construction, 4) upon receipt of items for a facility, as well as 5) during maintenance, modification, inservice, operating and decommissioning activities. The post-maintenance testing program ensures that a functional test can be performed as additional assurance demonstrating the quality of work where inspections for breach of a pressure boundary are performed by an individual within the same functional group (e.g., Maintenance).

The inspection program establishes requirements for planning inspections, such as the group or discipline responsible for performing the inspection, where inspection hold points are to be applied, determining applicable acceptance criteria, the frequency of inspection to be applied, and identification of special tools needed to perform the inspection. Inspection planning is performed by personnel qualified in the discipline related to the inspection and include qualified inspectors or engineers. Inspection plans are based on, as a minimum, the importance of the item to the safety of the facility, the complexity of the item, technical requirements to be met, and design specifications.

Where significant changes in inspection activities for the facilities are to occur, management responsible for the inspection programs evaluate the resource and planning requirements to ensure effective implementation of the inspection program.

54 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Inspection Inspection program documents establish requirements for performing the planned inspections, and documenting required inspection information such as: reject, acceptance, and re-inspection results; and the person(s) performing the inspection.

10.3 Inspector Qualification The Company has established qualification programs for personnel performing quality verification inspections. The qualification program requirements are described in Section 2 of this QAPD.

These qualification programs are applied to individuals performing quality verification inspections regardless of the functional group where they are assigned. Where inspections are to be performed by individuals within the same functional group, an independent audit of the qualification criteria for inspection personnel will be performed prior to implementing such an inspection program.

10.4 Quality Standards Commitment The Company commits to meeting the programmatic standards for Inspection of NQA-1-1994, Part I, Basic Requirement 10, and Supplement 10S-1 with the alternative regarding independence of Maintenance group inspectors stated above. The inspection programs will also incorporate the appropriate inspection requirements described in Part II, Quality Assurance Requirements for Nuclear Facility Applications, of NQA-1-1994. Regarding Subpart 2.4 (ANSI/IEEE Std. 336-1985) and Subpart 2.18 invoked by NQA-1-1994, Part II, any and all references to ANSI/ASME NQA-1, ANSI/ASME NQA-2, and ANSI/ANS-3.2 are changed to mean the appropriate requirements of NQA-1-1994 and this QAPD.

55 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Test Control Section 11 Test Control 11.1 General Description The Company has established and implements programs, procedures, and processes to control tests that assure the nuclear facility structures, systems, and components (items) function satisfactorily in service. The test control programs identify 1) the items to be tested, 2) methods of testing, 3) documentation, and 4) evaluation of test results. The tests are systematic and include, as necessary, proof tests prior to installation, construction tests, preoperational tests, production tests, operational tests, surveillance and inservice tests, and tests following repairs, rework, replacement, preventive maintenance, or modification.

Tests during the preoperational period are conducted to demonstrate that performance of facility systems is in accordance with design intent and that the coordinated operation of the facility as a whole is satisfactory, to the extent feasible. Tests during the initial operational phase are conducted to demonstrate the performance of systems that could not be tested prior to operation and to confirm those physical parameters, hydraulic or mechanical characteristics that need to be known, but which could not be predicted with the required accuracy, and to confirm that behavior conforms to design criteria. The preoperational testing program will demonstrate, as nearly as can be practicably simulated, the overall integrated operation of the plant systems at rated conditions, including simultaneous operation of auxiliary systems. It may be necessary to defer portions of these tests until nuclear heat is available.

The initial start-up test program is planned and scheduled to permit safe fuel loading and start-up; to increase power in safe increments; and to perform major testing at specified power levels. If tests require the variation of operating parameters outside of their normal range, the limits within which such variation is permitted will be prescribed. The scope of the testing demonstrates, insofar as practicable, that the plant is capable of withstanding the design transients and accidents. For new facility construction, the suitability of facility operating procedures is checked to the maximum extent possible during the preoperational and initial start-up test programs.

The tests are performed and results documented in accordance with applicable technical and regulatory requirements including those described in the nuclear facility Technical Specifications and SAR. The test programs ensure appropriate retention of test data in accordance with the records requirements of this QAPD. The personnel performing or evaluating tests are qualified in accordance with the requirements established in Section 2 of this QAPD.

11.2 Test Procedures Tests are conducted in accordance with approved written procedures or instructions that are based on the applicable design requirements for the structures, systems, and components being tested.

Section 5 of this QAPD describes the requirements for test procedures. The procedures include prerequisites and instructions for performing the test that ensure the item is ready for testing,

56 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Test Control appropriate test equipment with suitable accuracy is used, and any necessary controlled environmental conditions are established and maintained. The prerequisites are completed prior to commencement of the test or portion of the test where they are applicable. Test procedures also identify acceptance criteria, any required inspection hold or witness points, and provisions for documenting test performance data and review of test results by appropriate management. When acceptance criteria are not met, provisions are made for retest of corrected areas.

11.3 Evaluation of Test Results The test control programs contain measures for a qualified individual or group to evaluate test results against predetermined acceptance criteria. The acceptance status of the test is documented. Any deficiencies identified by the tests are documented and dispositioned in accordance with procedures.

11.4 Scheduling Scheduling or similar measures are used to ensure that appropriate tests are performed and evaluated on a timely basis so that the safety of the plant is never dependent on the performance of an untested system. Preoperational tests, including start-up tests following fuel loading, are generally performed sequentially to demonstrate functional adequacy and are scheduled to be performed at the time when plant conditions are appropriate for the test. Surveillance testing and inspections for operating facilities (and required operating items of facilities being decommissioned) are scheduled at prescribed intervals to ensure that items important to safety will continue to operate, keeping parameters within normal bounds, or will act to put the plant in a safe condition if they exceed normal bounds. These intervals are established in facility technical documents.

11.5 Quality Standards Commitment The Company commits to meeting the programmatic standards for Test Control of NQA-1-1994, Part I, Basic Requirement 11, Supplement 11S-1, and Supplement 11S-2, along with the surveillance and testing requirements described in Part II, Quality Assurance Requirements for Nuclear Facility Applications, of NQA-1-1994. Regarding Subpart 2.4 (ANSI/IEEE Std. 336-1985) invoked by NQA-1-1994, Part II, any and all references to ANSI/ASME NQA-1, ANSI/ASME NQA-2, and ANSI/ANS-3.2 are changed to mean the appropriate requirements of NQA-1-1994 and this QAPD.

57 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Control of Measuring and Test Equipment Section 12 Control of Measuring and Test Equipment 12.1 General Description The Company has established and implements administrative controls and processes for the calibration, maintenance, and use of measuring and test equipment (including instruments, tools, gauges, fixtures, reference and transfer standards, and non-destructive test equipment). These controls are applicable to those items used in the measurement, inspection, maintenance, and monitoring of structures, systems, and components important to safety. The measuring and test equipment (M&TE) does not include: measuring equipment used for preliminary checks or utility troubleshooting where accuracy is not required, nor rulers, tape measures, levels, and other basic tools where normal commercial practices provide adequate accuracy. Controls for M&TE include selection of equipment; establishing and implementing calibration requirements; documentation and/or markings to trace equipment usage, calibration, and calibration status; handling and storage to maintain accuracy; and measures to address nonconforming or deviating conditions including evaluation, disposition, and retest where indicated. The suppliers of commercial grade calibration services are controlled as described in Section 7.3.

12.2 Installed Instrument and Control Devices For the operations phase of the facilities, the Company has established and implements procedures for the calibration and adjustment of instrument and control devices installed in the facility. The calibration and adjustment of these devices is accomplished through the facility maintenance programs to ensure the facility is operated within design and technical requirements. Appropriate documentation will be maintained for these devices to indicate the control status, when the next calibration is due, and identify any limitations on use of the device.

12.3 Quality Standards Commitment The Company commits to meeting the standards for Control of Measuring and Test Equipment of NQA-1-1994, Part I, Basic Requirement 12, Supplement 12S-1, and Part II, and Subpart 2.16 with the following alternatives and clarification:

58 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Control of Measuring and Test Equipment 12.3.1 All references to ANSI/ASME NQA-1, ANSI/ASME NQA-2, and ANSI/ANS-3.2 are changed to indicate the appropriate Sections of ANSI/ASME NQA-1-1994 and this QAPD.

12.3.2 Instrumentation and control devices installed in operating facilities are not required to be labeled as described in Subpart 2.16, subsection 5.5 (ANSI/IEEE Std. 498-1985), provided the information is maintained in suitable documentation traceable to the device. This alternative also applies to the calibration labeling requirement of Subpart 2.4, subsection 7.2.1 (ANSI/IEEE Std. 336-1985).

12.3.3 The out-of-calibration conditions described in paragraph 3.2 of Supplement 12S-1 refers to when the M&TE is found out of the required accuracy limits (i.e. out of tolerance) during calibration.

59 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Handling, Storage, and Shipping Section 13 Handling, Storage, and Shipping 13.1 General Description The Company has established and implements programs, procedures, and processes to control handling, storage, shipping, cleaning, packaging, and preservation of items. The programs delineate controls to prevent damage, loss, and deterioration by environmental conditions (such as temperature or humidity) of material and equipment received for the nuclear facility. The programs also describe the measures taken, including control of shelf life, for the storage of chemicals, reagents, lubricants, and other consumable materials. Suitable procedures, instructions, and procurement documents are used to define the requirements, training, and responsibilities for implementing the programs. The established requirements are consistent with the regulatory positions of the NRC regulatory guides and their related standards listed in Appendix C, or specifications and/or Supplier technical manuals, including special tool utilization and use, operator experience and training, and appropriate marking and labeling.

13.2 Special Handling, Storage, Shipping, Cleaning and Preservation Requirements Special or additional handling, storage, shipping, cleaning and preservation requirements are identified and implemented as specified in procurement documents and applicable procedures.

Where special requirements are specified, the items and containers (where used) are suitably marked.

13.3 Quality Standards Commitment The Company commits to meeting the standards for handling, storage, and shipping of NQA-1-1994, Part I, Basic Requirement 13, Supplement 13S-1, and Part II, Subpart 2.2, and Subpart 2.15 with the following alternatives:

60 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Handling, Storage, and Shipping 13.3.1 Regarding Subpart 2.2 13.3.1.1 For items in storage, as determined by facility management the packaging requirements described under Section 3, Packaging, may include alternate methods of affording the required protection such as maintaining a storage atmosphere free from harmful contaminants in concentrations that could produce damage to the stored items, or utilizing storage practices that obviate the need for capping all openings.

13.3.1.2 For items in storage at Company facilities, the items and the outside of containers (when present) need to meet the appropriate criteria of subsection 3.9, Marking, necessary to ensure the identity of the item, and proper instructions for preservation during storage and future handling are retained.

13.3.1.3 Regarding maintenance of items in storage in accordance with subsection 6.4.2, Care of Items: the requirement of item (f) will not apply to rotating electrical equipment less than 50 HP, the requirement of item (g) will not apply to rotating equipment weighing less than 50 pounds, the requirements of (e), (f), and (g) may be exempted for specific items on a case-by-case basis provided that a documented engineering evaluation determines that such care is not required.

13.3.1.4 Subsection 6.6, Storage Records, requires written records be prepared containing information on personnel access. As an alternative to this requirement, Company documents establish controls for storage areas that describe those authorized to access areas and the requirements for recording access of personnel. However, these records of access are not considered quality records and will be retained in accordance with the administrative controls for the facility.

13.3.2 Regarding Subpart 2.15 13.3.2.1 The Company may choose to not use the specific classification of Categories A, B, and C, but ensures items to be handled are evaluated and the appropriate range of controls and requirements for the activity are applied consistent with this Subpart.

61 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Inspection, Test, and Operating Status Section 14 Inspection, Test, and Operating Status 14.1 General Description The Company has established and implements administrative controls and processes to indicate and document the inspection, test, and operating status of structures, systems, and components to prevent their inadvertent use or the bypassing of inspections and tests. The requirements for identification of status also apply to nonconforming, inoperative, or malfunctioning structures, systems, and components. Company administrative procedures delineate the requirements, methods, and responsibilities for status identification through the use of stickers, tags and tagging systems, test and inspection records, checklists, or logs. The procedures identify 1) those who are authorized to apply and remove the various status tags, stickers, and other indicators and 2) the authority to operate the item and/or equipment. The operating status is also controlled through the normal nuclear facility operating procedures.

The administrative procedures also describe the measures taken to control altering the sequence of required tests, inspections, and other operations. The review and approval for these actions is subject to the same control as taken during the original review and approval of tests, inspections, and other operations.

14.2 Control of Systems and Equipment for Operating Facilities Permission to release systems and equipment for maintenance or modification is controlled by designated operating personnel and documented. Measures, such as installation of tags or locks and releasing stored energy, are used to ensure personnel and equipment safety. When entry into a closed system is required, the Company has established control measures to prevent entry of extraneous material and to assure that foreign material is removed before the system is re-closed.

Administrative procedures require the designated operating personnel to verify that the system or equipment can be released and determine the length of time it may be out of service. In making this determination, attention is given to the potentially degraded degree of protection where one subsystem of a redundant safety system is not available for service. Conditions to be considered in preparing equipment for maintenance include, for example: shutdown margin; method of emergency core cooling; establishment of a path for decay heat removal; temperature and pressure of the system; valves between work and hazardous material; venting, draining and flushing; entry into closed vessels; hazardous atmospheres; handling hazardous materials; and electrical hazards.

Where temporary modifications, such as temporary bypass lines, electrical jumpers, lifted electrical leads, and temporary trip point settings, are necessary, they are controlled in accordance with approved documents that include requirements for independent verification. A log, or similar documentation, is maintained of the current status of such temporary modifications.

62 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Inspection, Test, and Operating Status When systems or equipment are ready to be returned to service, designated operating personnel control placing the items in service and document its functional acceptability. Attention is given to restoration of normal conditions, such as removal of jumpers or signals used in maintenance or testing, or actions such as returning valves, breakers or switches to proper start-up or operating positions from test or manual positions. Where necessary, the equipment placed into service receives additional surveillance during the run-in period.

Independent verifications, where appropriate, are used to ensure that the necessary measures have been implemented correctly. The minimum requirements and standards for using independent verification are established in Company documents.

14.3 Quality Standards Commitment The Company is committed to implementing a status control program in accordance with the quality standards described in NQA-1-1994, Part I, Basic Requirement 14.

63 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Nonconforming Materials, Parts, or Components Section 15 Nonconforming Materials, Parts, or Components 15.1 General Description The Company has established and implements administrative controls and processes that assure control of nonconforming items (materials, parts, components), and services (including computer codes) to prevent their inadvertent use or installation in Company nuclear facilities. Documents describe the methods for identification, documentation, segregation, review, disposition, and notification to affected organizations of nonconforming items or services when the disposition is other than to scrap the items or services. Instructions require that the individual discovering a nonconformance identify, describe, and document the nonconformance. Procedures identify authorized individuals to review, disposition, and closeout nonconformances. Nonconformances are corrected or resolved prior to the initiation of the preoperational test of the item. The Company has appropriate interfaces between the QAP for identification and control of nonconforming materials, parts, or components and the non-QA Reporting Program to satisfy the requirements of 10 CFR 21 during operations.

15.2 Nonconformance Responsibilities Nonconformances are evaluated for impact on operability of quality structures, systems, and components in accordance with Company procedures to assure that the final condition does not adversely affect safety, operation, or maintenance of the item or service. Nonconforming item reports dispositioned as use-as-is or repair that involve deviation from design requirements are forwarded to the appropriate engineering organization for review and approval of the disposition.

Company documents address the controls established to conditionally release nonconforming items for use on a risk basis prior to resolution and disposition of the nonconformance, including maintaining identification of the item and documenting the basis for such release. Conditional release of nonconforming items for installation requires appropriate senior management approval for the facility or construction project. Resolution of nonconformances for purchased services are also controlled by Company documents.

15.3 Nonconformance Documentation Company procedures assure that documentation identifies the nonconforming item and describes the nonconformance, the disposition of the nonconformance, and applicable inspection requirements. The documentation requires approval of the disposition by an authorized individual.

Reworked, repaired, and replacement items are inspected and tested in accordance with the original inspection and test requirements or approved alternatives.

Company processes verify that nonconformance dispositions are adequate, analyze for quality trends, and report results to upper management in accordance with applicable Company

64 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Nonconforming Materials, Parts, or Components procedures. Any significant trends are reported to upper management in accordance with Company documents, regulatory requirements, and industry standards.

15.4 Quality Standards Commitment The Company commits to meeting the standards for control of nonconforming items of NQA-1-1994, Part I, Basic Requirement 15 and Supplement 15S-1.

65 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Corrective Action Section 16 Corrective Action 16.1 General Description The Company has established and implements corrective action programs, procedures, and processes to assure that conditions adverse to quality at Company nuclear facilities are promptly identified and corrected. Company management at all levels fosters a no-fault attitude toward the identification of problems. Verification of the proper implementation of corrective action measures and close-out of corrective action documentation is assured through the monitoring effort of facility personnel and Nuclear Oversight processes. Reports of conditions adverse to quality are analyzed to identify trends. The Company has appropriate interfaces between the QAP for identification and control of nonconforming materials, parts, or components and the non-QA Reporting Program to satisfy the requirements of 10 CFR 21 during operations.

16.2 Corrective Action Documentation Company procedures assure that corrective action is documented and initiated following the determination of a condition adverse to quality (such as a nonconformance, failure, malfunction, deficiency, deviation, adverse trend, and defective material and equipment) in accordance with regulatory guidance and industry quality standards. When complex issues arise where it cannot be readily determined if a condition adverse to quality exists, Company documents establish the requirements for documentation and timely evaluation of the issue.

In the case of significant conditions adverse to quality, the cause of the condition is determined and corrective action taken to preclude repetition. For these significant conditions, the cause of the conditions, and the corrective action taken to preclude repetition are documented and reported to immediate management and upper levels of responsible management for review and assessment.

16.3 Follow-up Company corrective action procedures describe the methods for follow-up action to verify proper implementation of corrective action and ensure that the corrective actions are closed out in a timely manner, and include follow-up through Nuclear Oversight processes. Independent review of corrective action is conducted in accordance with the requirements of Appendix B of this QAPD.

16.4 Quality Standards Commitment The Company commits to meeting the standards for corrective action of NQA-1-1994, Part I, Basic Requirement 16.

66 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Quality Assurance Records Section 17 Quality Assurance Records 17.1 General Description The Company has established and implements administrative controls and processes to ensure sufficient records of items and activities for the nuclear facilities that reflect completed work are generated, identified, retained, maintained, and retrievable. Company programs and procedures identify specific records, their retention periods, and storage methods.

17.2 Records of Activities Company documents ensure records of activities for design, engineering, procurement, manufacturing, construction, inspection and test, installation, pre-operation, startup, operations, maintenance, modification, decommissioning, and audits include the appropriate content requirements of NQA-1-1994, Parts I and II. The records and their retention times are based on Regulatory Position C.2, Table 1, of NRC Regulatory Guide 1.28, Revision 3 that is incorporated into Appendix E of this QAPD with the exception that the security plan, procedures, and activities and emergency plan, procedures, and activities are not considered QA records and their retention is controlled under their applicable regulations. Additionally, exemptions granted by the NRC in Kewaunee Power Station - Exemption From Record Retention Requirements (CAC NO. L53174) are applied at that facility. The Regulatory Guide table, as amended by approved exceptions, as included in Appendix E to this QAPD, addresses design, construction and initial start-up records and will be applied to operating and decommissioning phase records that are similar in nature to the construction records. Additional operations phase records and their retention periods are also identified in Appendix E to this QAPD. Where State, local or other agencies have more restrictive requirements, those requirements will be met.

17.3 Record Storage Implementing procedures assure that identification and retrievability of records is facilitated through proper indices and an established basic filing system. Records are stored in a manner to preclude deterioration of the item. The Companys records storage facilities are constructed, located, and secured to provide access control and fire protection measures.

Records stored electronically will follow the guidance given in the Nuclear Information and Records Management Association (NIRMA) technical guidelines: TG-11-1998, Authentication of Records and Media; TG-15-1998, Management of Electronic Records; TG-16-1998, Software Configuration Management and Quality Assurance; and TG-21-1998, Electronic Records Protection and Restoration for the KPS, MPS, NAPS, and SPS facilities. Records stored electronically for the VCS facility follow the guidance in the NIRMA technical guidelines: TG-11-2011, Revision 3, Authentication of Records and Media; TG-15-2011, Revision 3, Management of Electronic Records; TG-16-2011, Revision 1, Software Quality Assurance Documentation and Records; and

67 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Quality Assurance Records TG-21-2011, Revision 4, Required Records Protection, Disaster Recovery and Business Continuation. Electronic media may include optical disk, magnetic tape, network drive array, etc.

Information Technology will determine appropriate media based upon data format and level of access required. Records originally created in hard-copy form will be retained in hard copy until such time as electronic versions of these records are created, copied, and verified as legible on two (2) independent copies of an appropriate electronic storage media. File legibility verifications will be completed on all records stored on electronic storage media by either visually verifying the file legibility or by electronically verifying exact binary file transfer. Periodic documented media inspections to monitor image degradation will be conducted in accordance with approved procedures that incorporate NIRMA guidelines or the applicable media manufacturers recommendations. Records stored on electronic media will be refreshed or copied onto new media and subsequently verified if the projected lifetime of that media does not exceed the retention period of the records stored on that media.

Records originally created in electronic form may be retained in electronic form. Backup copies of electronic records will be maintained in multiple physically independent electronic locations until such time as images of these records are created, copied, and verified on two (2) copies of an appropriate electronic storage media. The two copies of electronic storage media will then be stored in separate physical locations. These NIRMA guidelines have been endorsed by RIS 2000-18, Guidance on Managing Quality Assurance Records in Electronic Media, dated October 23, 2000.

17.4 Quality Standards Commitment The Company is committed to implementing a quality assurance records program in accordance with the quality standards described in NQA-1-1994, Part I, Basic Requirement 17 and Supplement 17S-1 with the alternative that where subsection 4.2(b) of Supplement 17S-1 requires records to be firmly attached in binders or placed in folders or envelopes for storage, the hard-copy records may use methods other than binders, folders, or envelopes to organize the records for storage.

The Company will meet the NRC Regulatory Position C.2 of Regulatory Guide 1.28, Revision 3, August 1985 except that: (1) the reference to ASME NQA-1 will be to the 1994 edition; (2) Security plan, procedures, and activities records, and emergency plan, procedures, and activity records (Table 1, Section 4.6 General) will be retained in accordance the applicable security or emergency planning regulations and orders of the NRC; and (3) exemptions were granted by the NRC due to the permanent shutdown and decommissioning status stated in Kewaunee Power Station -

Exemption From Record Retention Requirements (CAC NO. L53174). The Company will also meet the NIRMA Guidelines endorsed by NRC RIS 2000-18, dated October 23, 2000, or the updated NIRMA Guidelines identified in subsection 17.3 for VCS.

68 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Quality Assurance Audits Section 18 Quality Assurance Audits 18.1 General Description The Company has established and implements administrative controls and processes for audits to systematically verify compliance with and determine the effectiveness of all aspects of the QA program for the Companys nuclear facilities. Nuclear Oversight conducts, participates on, or has performed for them, audits to ensure comprehensive independent verification and evaluation of Suppliers, activities, and documents. The audits are performed in accordance with written procedures or checklists and are conducted by appropriately trained personnel having no direct responsibilities in the areas being audited.

An audit schedule is prepared to identify the planned and periodic audits to be performed, their frequencies, and dates for performance. Audits are scheduled based upon the status and safety importance of the activities being performed and are initiated early enough to assure effective QA during design, construction, operation, and decommissioning. When necessary, the scheduled audits are supplemented with audits of specific subjects to ensure adequate coverage or re-audit of deficient areas.

18.2 Audit Scope The audits include an objective evaluation of quality-related practices, procedures, instructions, activities, and items; and review of documents and records. Audits are performed in all areas where the requirements of this QAPD are applicable including activities associated with indoctrination and training programs; interface control between the Company and principal Suppliers; corrective action, calibration, and nonconformance control systems; facility SAR commitments; and activities associated with computer codes. For facilities under construction, the audits will also include, as applicable, the determination of site features which affect plant safety (e.g., core sampling, site and foundation preparation, and methodology) and the preparation, review, approval, and control of early procurements.

18.3 Audit Responsibilities and Procedures Audit data is analyzed by the audit team. The results of the analysis are reviewed by Nuclear Oversight management. Audit reports indicate any quality problems identified, the effectiveness of the QA program elements assessed, and identify the deficiencies that require follow-up of corrective actions. The reports are distributed to affected management for review. Management with responsibility for the area audited review, investigate, and correct (with a view toward preventing recurrence) conditions adverse to quality that involve QA program deficiencies. Follow-up of audit findings involving program deficiencies is performed by Nuclear Oversight as necessary to verify appropriate actions have been taken to resolve audit findings.

69 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Quality Assurance Audits Items not effectively resolved by assigned management are submitted to the senior management position responsible for Nuclear Oversight for resolution with successively higher levels of Company or Supplier executive management, as applicable.

18.4 Supplier Quality Assurance Company documents ensure that 1) triennial external audits, 2) annual Supplier QA program evaluations, 3) reviews of audits conducted by external organizations (e.g., other utilities and NUPIC), and 4) maintenance of the approved Suppliers list are performed to assure Suppliers quality programs meet applicable requirements and that only qualified Suppliers are used.If a subsequent contract or a contract modification significantly enlarges the scope of, or changes the methods or controls for activities performed by the same supplier, an audit of the modified requirements is conducted, thus starting a new triennial audit period. The results of audits and annual evaluations that are performed for qualified suppliers are promptly considered for effect on a supplier's continued qualification and adjustments are made as necessary (including corrective actions, adjustments of supplier audit plans, and input to third party auditing entities, as warranted).

In addition, results are reviewed periodically to determine if, as a whole, they constitute a significant condition adverse to quality requiring additional action.

18.5 Internal Audits During the design, construction, and decommissioning phases of a facility, internal audits are performed of selected activities at appropriate times commensurate with scheduled activities to assure timely and effective implementation of QA requirements. During the operations phase and periods of prolonged lay-up for facilities awaiting final decommissioning, audits are performed at a frequency commensurate with the safety significance of the activities and in such a manner to assure audits of all applicable QA program elements are completed within a period of two years.

These audits will include, as a minimum, activities in the following areas:

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

2. The performance, training, and qualifications of the facility staff.

3. The performance of activities required by the QAPD to meet the criteria of 10 CFR 50, Appendix B (includes activities performed under the Appendix B QA program to meet 10 CFR Part 71, Subpart H, and 10 CFR Part 72, Subpart G).

4. The Fire Protection Program and implementing procedures. A fire protection equipment and program implementation inspection and audit utilizing either a qualified offsite licensed fire protection engineer or an outside qualified fire protection consultant.

70 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Quality Assurance Audits

5. Other activities and documents considered appropriate by the Management Safety Review Committee (MSRC) or the CNO.

Internal audit frequencies of well-established activities (i.e., those required by the QAPD to meet the criteria of 10 CFR 50, Appendix B, and conformance of facility operation to provisions of the Technical Specifications and applicable license conditions other than fire protection requirements (refer to items 1, 2, and 3 above) conducted after placing the facility in operation, may be extended one year at a time beyond the two-year interval based on the results of an annual evaluation of the applicable functional area and objective evidence that the functional area activities are being satisfactorily accomplished. The evaluation shall include a detailed performance analysis of the functional area based upon applicable internal and external source data and due consideration of the impact of any functional area changes in responsibility, resources or management. However, the internal audit frequency interval shall not exceed a maximum of four years. The extended audit frequency may have a grace period of 90 days applied (the normal 25% grace period does not apply). The grace period does not allow the clock for a particular activity to be reset forward. The clock for an activity is reset backwards by performing the activity early. If an adverse trend is identified in the applicable functional area, the extension of the internal audit frequency interval shall be rescinded and an audit scheduled as soon as practicable.

Audits may also be used to meet the periodic review requirements of the code for the Security, Emergency Preparedness, and Radiological Protection programs within the provisions of the applicable code.

Internal audits include verification of compliance and effectiveness of the administrative controls established for implementing the requirements of this QAPD; regulations and license provisions; provisions for training, retraining, qualification, and performance of personnel performing activities covered by this QAPD; corrective actions taken following abnormal occurrences; and, observation of the performance of construction, fabrication, operating, refueling, maintenance, modification, and decommissioning activities.

18.6 Quality Standards Commitment The Company is committed to implementing an audit program in accordance with the quality standards described in NQA-1-1994, Part I, Basic Requirement 18 and Supplement 18S-1.

A-1 Revision 30 Appendix A Organizational Relationships of Key Management and Functional Groups

Dominion Energy Revision 30 Nuclear Facility Quality Assurance Program Description A-2 Appendix A Organizational Relationships of Key Management and Functional Groups Corporate and Technical Support Performance Improvement and Training Chief Nuclear Officer (CNO)

Management Safety Review Committee Executive Management Position Responsible for Fleet Performance Executive Management Position Responsible for Engineering Management Position Responsible for Nuclear Oversight Supplier Quality Internal Audits Regulatory Affairs Facility Engineering Information Technology Principal Suppliers for Design and Construction*

Nuclear Fleet Emergency Preparedness Records Management**

Executive Management Position Responsible for Facility Operations Supply Chain Management Human Resources Protection Services Senior Management Position Responsible for KPS Facility Operations

• When principal Suppliers are used.

• • Includes document control and records management functions.

Shadowed boxes indicate functions for facility operations.

Dotted lines represent matrixed relationships from outside Dominion Energys Nuclear group.

Dominion Energy Revision 30 Nuclear Facility Quality Assurance Program Description A-3 Appendix A Organizational Relationships of Key Management and Functional Groups MPS/NAPS/SPS/VCS Facility Operations Executive Management Position Responsible for Facility Operations Facility Safety Review Committee Management Position Responsible for Facility Safety & Licensing Management Position Responsible for Facility Operations & Maintenance Site Services Outage & Planning Maintenance Operations Operations Support Fire Protection Program Operations Work Control Shift Operations Licensed and Non-Licensed Operators Unit Supervisor Shift Manager Organizational Effectiveness Records Management Procedures Licensing Radiological Protection

& Chemistry Management Position Responsible for Nuclear Training Emergency Preparedness Management Position Responsible for Nuclear Oversight Site Safety &

Loss Prevention Facility QC Inspections (MPS/VCS)

Internal Audits Facility QC Inspections (NAPS/SPS)

Operating facility responsibility includes power plant(s) and associated independent spent fuel storage installation(s) for the site.

Shadowed box and dotted line indicates Corporate oversight of the functions for facility operation with a line of communication to the site.

Dominion Energy Revision 30 Nuclear Facility Quality Assurance Program Description A-4 Appendix A Organizational Relationships of Key Management and Functional Groups Facility Operating Staff Reporting To Support Groups Information Technology Reactor Engineer Supply Chain Management Facility Protection Services Facility Engineering Facility Emergency Preparedness Security System/Component/

Reactor Engineering Testing and NDE Design Engineering Projects Internal Audits Facility QC Inspections (MPS/VCS)

Protection Services Fleet Emergency Preparedness Engineering Services Nuclear Oversight Information Technology Nuclear Engineering and Fuel Supply Chain Management Supplier Surveillance Material Receipt Inspection Material Storage & Control Shadowed boxes indicate Support organizations.

Dotted lines represent matrixed a line of communication, not direct reporting.

KPS/Support Organization relationships are limited to that described in subsections 1.2.6 through 1.2.9.

Dominion Energy Revision 30 Nuclear Facility Quality Assurance Program Description A-5 Appendix A Organizational Relationships of Key Management and Functional Groups KPS Facility Operations Senior Management Position Responsible for Facility Operations Facility Safety Review Group (FSRG)

Technical Support Facility Operations

& Maintenance Work Control Shift Operations FSRG Coordination Procurement &

Material Control Engineering &

Design Control Facility Programs &

Processes Security Nuclear Oversight Supplier Surveillance &

Source and Receipt Inspection Internal Audits Safety-related QC Inspection & ANI Services Radiological Protection &

Chemistry Shadowed box and dotted line indicates Corporate oversight of the functions for facility operation with a line of communication to the site.

B-1 Revision 30 Appendix B Management and Independent Review Activities

B-2 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Management and Independent Review Activities 1.

General The Company ensures operational phase and decommissioning phase activities of the facilities are independently reviewed on a periodic basis. The purpose of these reviews is to:

1) verify that operational phase activities are performed in accordance with this QAPD and Company administrative controls, procedures, and license provisions; 2) review significant proposed plant changes, tests, and procedures; 3) verify that events that are reportable to the NRC are promptly investigated and corrected so as to reduce the probability of recurrence; and 4) detect trends that may not be apparent to a day-to-day observer.

These review functions are performed through a combination of safety review committees, a safety review group, integrated review activities, and internal audits, as applicable. This Appendix describes the review program implemented by the committees, the integrated review activities, and a safety review group, as applicable. The internal audit program is addressed in Section 18 of this QAPD. The review programs of this appendix ensure that the personnel performing this review collectively have the experience and competence necessary to review problems in the following areas:

1. Nuclear power plant operations

2. Nuclear engineering

3. Chemistry and radiochemistry

4. Metallurgy

5. Nondestructive testing

6. Radiological safety

7. Mechanical engineering

8. Electrical engineering

9. Instrumentation and control 10.Administrative controls and quality assurance practices 11.Training 12.Emergency plans and related procedures and equipment

B-3 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description An individual may possess competence in more than one specialty area. The established administrative controls contain provisions to assure the appropriate expertise is applied to the independent reviews, including the use of consultants when necessary.

2.

Qualifications Personnel performing the independent review functions meet the qualification requirements of ANS-3.1-1993, subsection 4.7, as clarified in NRC Regulatory Guide 1.8, Revision 3, and this QAPD. Independent review personnel shall also complete the required qualification training for the function they are performing.

3.

Management Safety Review Committee (MSRC)

The MSRC shall ensure periodic independent reviews and audits of activities are conducted by qualified individuals free from the pressures of plant operations. For new nuclear power plant construction, the MSRC shall be functional at least one year prior to initial core loading.

The MSRC serves in an advisory capacity to the CNO.

3.1 Review Responsibilities The MSRC shall ensure periodic independent reviews and audits of activities as stated in this QAPD are performed. Review of events shall include the results of any investigations made and the recommendations resulting from such investigations to prevent or reduce the probability of recurrence of the event. Additional review activities by the MSRC should be performed to verify adequate organizational response to adverse performance trends.

The MSRC should monitor the results of audits, evaluations, and assessment activities to ensure that items that could affect plant safety are reviewed. The MSRC may delegate review functions to subcommittees, that may include MSRC members, provided that the subcommittees report the results of their reviews to the MSRC.

3.2 Composition The MSRC shall be composed of the Chairperson and a minimum of four members, of whom no more than a minority are members of the plant operating organization. The CNO shall appoint, in writing, a Chairperson. The Chairperson shall appoint, in writing, a minimum of four members to the MSRC and shall designate from this membership, in writing, a Vice Chairperson. Consultants should be utilized as determined by the MSRC Chairperson to provide expert advice to the MSRC.

3.3 Alternates Alternates shall be designated in advance, but their use shall be restricted to legitimate absences of principals.

B-4 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description 3.4 Meeting Frequency The MSRC shall meet at least once per six months. During initial operation of a newly constructed power plant the meeting frequency shall be at least once per calendar quarter.

3.5 Quorum The quorum of the MSRC shall consist of a majority of regular members including the Chairperson or Vice Chairperson. No more than a minority of the quorum shall have line responsibility for operation of a Company nuclear facility.

3.6 Records Minutes of all MSRC meetings shall be prepared and retained. All documents reviewed should be identified. Decisions and recommendations made by the MSRC shall be documented. Minutes of each MSRC meeting shall be disseminated promptly to appropriate members of management having responsibility in the area reviewed. Records of meeting minutes shall be retained in accordance with Section 17 of this QAPD.

4.

Facility Safety Review Committee (Millstone, North Anna, Surry, V.C. Summer)

The facility safety review committee serves in an advisory capacity to the executive management position responsible for facility operations on all matters related to nuclear safety for their assigned Company facilities.

4.1 Composition The facility safety review committee shall be composed of a minimum of five members.

The executive management position responsible for facility operations shall appoint, in writing, the members of facility safety review committee, including the facility safety review committee Chairperson and the Vice Chairperson drawn from the committee members.

4.2 Alternates Alternate members shall be appointed in writing by the facility safety review committee Chairperson to serve on a temporary basis. Each alternate shall meet the minimum qualifications described above for facility safety review committee members, and shall have the same area of expertise as the member being replaced.

4.3 Meeting Frequency The facility safety review committee shall meet at least once per calendar month and as convened by the facility safety review committee Chairperson.

B-5 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description 4.4 Quorum A quorum of the facility safety review committee shall consist of the Chairperson or Vice Chairperson and two members or designated alternates. However, a maximum of one third of the voting membership may be designated alternates.

For any facility safety review committee decision affecting site-wide issues, the Chairperson shall ensure appropriate representation.

4.5 Responsibilities The facility safety review committee shall be responsible for:

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

2. Review of all proposed changes to nuclear facility Technical Specifications.

3. Review of all proposed tests and experiments not described in the FSAR that affect nuclear safety.

4. Review of all proposed changes or modifications to systems or equipment that affect nuclear safety.

5. Rendering determinations in writing or meeting minutes if any item considered under

1. through 4. above, as appropriate and as provided by 10 CFR 50.59, 10 CFR 50.92, or 10 CFR 72.48 requires a license amendment or requires a significant hazards consideration determination.

6. Performance of special reviews and investigations and reports as requested by the Chairperson of the facility safety review committee or the executive management position responsible for facility operations.

7. Investigations of all violations of Technical Specifications, including the preparation and forwarding of reports covering evaluation and recommendations to prevent recurrence, to the executive management position responsible for facility operations, the CNO, and to the Chairperson of the MSRC.

8. Review of all nuclear facility reportable events.

9. Review of facility operations to detect potential safety hazards.

B-6 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description

10. Review of Millstone Unit 3 Turbine Overspeed Protection Maintenance and Testing Program and revisions thereto, where applicable. (MPS committee only, based on regulatory commitment.)

4.6 Authority The facility safety review committee shall:

1. Recommend to the executive management position responsible for facility operations written approval or disapproval in meeting minutes of items considered under Responsibilities 1. through 10. above. The executive management position responsible for facility operations will report any issues that require higher level of authority to the CNO.

2. Provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the CNO, and the Chairperson of the MSRC of disagreement between the facility safety review committee and the executive management position responsible for facility operations. The CNO shall have responsibility for resolution of such disagreement.

4.7 Records The facility safety review committee shall maintain written minutes of each meeting and copies shall be provided to the executive management position responsible for facility operations, the CNO and the facility safety review committee. Records of the minutes shall be maintained in accordance with this QAPD, Section 17.

5.

Independent Nuclear Safety Review 5.1 Independent nuclear safety review functions1 are performed for Company nuclear facilities through integrated review activities that support safe operations. The functions of examining unit operating characteristics, NRC issuances, industry advisories, Licensee Event Reports, and other sources that may indicate areas for improving unit safety are accomplished by groups designated to perform the reviews. These groups shall maintain independence from the groups directly responsible for operating the power stations.

Personnel selected to perform these functions shall have appropriate training and qualification for the tasks they will perform.

The following integrated activities are acceptable to meet the independent nuclear safety review requirements:

1. These groups perform the reviews to meet the guidelines of NUREG-0737,Section I.B.1.2 for the Independent Safety Engineering Group for MPS, NAPS, and VCS.

B-7 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description

1. Corrective Action and Operating Experience Programs - Managed by Facility Safety and Licensing to ensure review of NRC and industry issuances, significant events and other operating experience.

2. Performance monitoring of key structures, systems, and components - Performed through engineering services groups using the programs that implement the Maintenance Rule of 10 CFR 50.65, as well as system and component health reports.

3. Technical reviews - Performed through engineering services groups using appropriate procedures to address technical operability functions, and changes that affect the station design basis.

Reports and recommendations developed through the above activities shall be made available to appropriate levels of management responsible for the facilitys operation.

6.

Facility Safety Review Group (Kewaunee)

The facility safety review group (FSRG) shall serve in an advisory capacity to the senior management position responsible for facility operations on all matters related to nuclear safety for the Kewaunee site.

6.1 Group Composition The FSRG shall be composed of a designated supervisor or manager to serve as the leader and one or more independent reviewers. The leader shall supplement the group with other company personnel or outside consultants when sufficient expertise is not available from within. The leader shall not have immediate responsibility for the performance of activities or functions that are within the scope of activities specified for FSRG review. Independent reviewers shall not be immediately responsible for performance of an activity or function they are assigned to review.

6.2 Completion of Reviews Independent reviews shall be conducted commensurate with their importance to nuclear safety. Reviews of proposed activities or changes shall be completed prior to implementation. Reviews of proposed technical specification or license amendment changes relating to nuclear safety that are not identical to a previously approved change shall be completed prior to NRC submittal or implementation. Other FSRG reviews shall be completed as to not exceed six months from the initiating activity.

B-8 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description 6.3 Responsibilities The FSRG shall be responsible for:

1.

Fulfilling Facility Safety Review Committee functions described in Sections 1 through 18 of this Quality Assurance Program Description.

2.

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

3.

Review of all proposed changes to nuclear facility Technical Specifications.

4.

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

5.

Review of all proposed changes or modifications to systems or equipment that affect nuclear safety.

6.

Rendering determinations in writing if any item considered under 1. through 5. above, as appropriate and as provided by 10 CFR 50.5 9, 10 CFR 50.92, or 10 CFR 72.48, requires a license amendment or requires a significant hazards consideration determination.

7.

Performance of special reviews and investigations and reports as requested by the senior management position responsible for facility operations or facility independent review unit leadership.

8.

Investigations of all violations of Technical Specifications, including the preparation and forwarding of reports covering evaluation and recommendations to prevent recurrence, to the senior management position responsible for facility operations, the CNO, and to the Chairperson of the MSRC.

9.

Review of all nuclear facility reportable events.

10. Review of facility operations to detect potential safety hazards.

B-9 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description 6.4 Records Documentation of reviews shall be prepared. The documentation shall include the identification of documentary materials included in the review, review results, and applicable recommendations and proposed actions. Documentation shall be approved by the unit leader. Copies shall be provided to the senior management position responsible for facility operations, the CNO and the facility safety review group. Records of the reviews shall be maintained in accordance with this QAPD, Section 17.

C-1 Revision 30 Appendix C Regulatory Guides and Quality Standards Commitments

C-2 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Regulatory Guides and Quality Standards Commitments Through this QAPD, the Company commits to compliance with the regulatory guidance and industry standards governing quality assurance as described below along with any exceptions, alternatives, or clarifications described within this QAPD. Commitment to a particular Regulatory Guide or indus-try standard does not constitute commitment to Regulatory Guides or other standards that may be referenced therein; unless otherwise stated within this QAPD, those referenced documents are con-sidered as guidance. When applicable, for Class 1, 2, and 3 items covered by Section III of the ASME Boiler and Pressure Vessel Code, the code Quality Assurance requirements are supplement-ed by the guidance of applicable regulatory guides and this QAPD.

1.

Regulatory Guide 1.8, Revision 1-R (Reissued May 1977)

Personnel Selection and Training This commitment applies to the Kewaunee Power Station and Millstone Power Station facilities only. This Regulatory Guide endorses ANSI N18.1-1971, Selection and Training of Nuclear Power Plant Personnel. Where these editions of the Regulatory Guide and ANSI standard are invoked by this QAPD and/or facility Technical Specifications, the Company will implement the requirements and guidance of the standard and Regulatory Guide subject to the following alternatives:

Applies to Kewaunee Power Station facilities only

1. The radiation protection manager shall meet or exceed the recommendation of Regulatory Guide 1.8, Revision 1-R, September 1975, or their equivalent as further clarified in to the Safety Evaluation Report enclosed with Amendment No. 46, dated July 12, 1982.

2. The Plant Manager (i.e., the senior manager responsible for the overall safe operation of the plant) shall have ten years of responsible power plant experience; of which a minimum of three years shall be nuclear power plant experience. A maximum of four years of the remaining seven years of experience may be fulfilled by academic training on a one-for-one time basis. To be acceptable, this academic training shall be in an engineering or scientific field generally associated with power production. Experience acquired at a nuclear facility for which permanent cessation of operation has been certified per 10 CFR 50.82(a)(1)(ii) may be credited as nuclear power plant experience.

3. The KPS manager responsible for Operations and Maintenance shall have a minimum of seven years of responsible power plant experience or applicable industrial experience, a minimum of one year of which shall be nuclear power plant experience in Operations, Maintenance, or Engineering. A maximum of two years of the remaining six years of power plant or industrial experience may be fulfilled by satisfactory completion of academic or

C-3 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description related technical training on a one-for-one time basis. Experience acquired at a nuclear facility for which permanent cessation of operation has been certified per 10 CFR 50.82(a)(1)(ii) may be credited as nuclear power plant experience.

4. The KPS manager responsible for Technical Support functions shall have a minimum of seven years of related experience in responsible positions, of which one year shall be nuclear power plant experience. A maximum of four years of the remaining six years of experience should be fulfilled by satisfactory completion of academic training. Experience acquired at a nuclear facility for which permanent cessation of operation has been certified per 10 CFR 50.82(a)(1)(ii) may be credited as nuclear power plant experience.

5. The KPS manager responsible for directing one or more Facility Programs and Processes described in 1.2.6.4, shall meet the qualifications described in item 3 or 4 above.

6. The KPS manager having overall responsibility for directing Radiological Protection and Chemistry activities (when other than the Radiation Protection Manager) shall meet the qualifications described in item 3 or 4 above.

7. Supervisory Personnel principally responsible for directing the actions of operators, technicians, or repairmen shall possess technical knowledge (through completed training or related nuclear experience) sufficient to ensure that the quality and functionality of equipment important to safety is properly controlled. The minimum qualifications cited in item 3 or 4 above satisfy this requirement.

Applies to Millstone Power Station facilities only

1. ANSI N18.1-1971, Subsection 4.2.2, states in part The Operations Manager shall hold a Senior Reactor Operators license. The following alternative to this requirement may be used:

The provisions of the Millstone Unit 2 and Unit 3 Technical Specifications Paragraph 6.3.2.

2. ANSI N18.1-1971, Subsection 4.3.1, states in part, A Supervisor (requiring an AEC license) shall have a minimum of a high school diploma or equivalent, and four years of responsible power plant experience, of which a minimum of one year shall be nuclear power plant experience. A maximum of two years of the remaining three years of power plant experience may be fulfilled by academic or related technical training on a one-for-one basis. The following alternative to this requirement will be applied:

Beginning November 1, 2001, applicants for senior reactor qualification shall meet or exceed the education and experience guidelines given in Revision 3 to Regulatory Guide 1.8. Reference license amendments 258 (MP2) and 199 (MP3).

C-4 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description

3. ANSI N18.1-1971, Subsection 4.5.1, states in part, An operator (to be licensed by the AEC) shall have a minimum of a high school diploma or equivalent, and two years of power plant experience, of which a minimum of one year shall be nuclear power plant experience. The following alternative to this requirement will be applied:

Beginning November 1, 2001, applicants for reactor qualification shall meet or exceed the education and experience guidelines given in Revision 3 to Regulatory Guide 1.8 (May 2000). Reference license amendments 258 (MP2) and 199 (MP3).

2.

Regulatory Guide 1.8, Second Proposed Revision 2, (September 1980)

Personnel Qualification and Training This commitment applies to the North Anna and Surry facilities only. This Regulatory Guide endorses ANSI/ANS-3.1 (Draft 12/79), Qualification and Training of Personnel for Nuclear Power Plants. Where these editions of the Regulatory Guide and ANSI standard are invoked by this QAPD and/or facility Technical Specifications, the Company will implement the requirements and guidance of the standard and Regulatory Guide subject to the following alternatives:

1. ANS-3.1 (Draft 12/79), Subsection 4.2.2 c. for the Operations Manager Training requires the individual filling this position to obtain and hold a senior operator license. The following alternative to this requirement will be applied:

The individual filling the role of operations manager and the individual filling the role of operations middle manager (supervisor shift operations) will meet the license requirements of North Anna Units 1 and 2 Technical Specification 5.2.2.e or Surry Units 1 and 2 Technical Specification 6.1.2.2.d as applicable.

2. ANS-3.1 (Draft 12/79), Section 4.1 addresses those circumstances where individuals do not possess the formal educational requirements specified in the standard by indicating that other factors should be evaluated to ensure qualified individuals fill the organizational functions. As part of that evaluation, either of the following additional experience requirements may be considered equivalent to a Bachelors Degree:

(1) Six years of applied engineering experience at a nuclear facility in the area for which qualification is sought. In addition, experience and training requirements for the function shall be met as delineated.

(2) Six years of operational or technical experience/training related to engineering in nuclear power. In addition, experience and training requirements for the function shall be met as delineated.

C-5 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description

3. ANSI/ANS-3.1 (Draft 12/79), Subsection 4.4.5, Quality Assurance, identifies the requirements for professional or technical group leaders in the Quality Assurance function.

The individuals filling this function within the Companys Nuclear Oversight organization will comply with the following alternative:

ANSI/ANS-3.1-1993, Subsections 4.3.7, Quality Assurance, and 4.4.13, Quality Assurance or Quality Control, subject to the description of the commitment to NRC Regulatory Guide 1.8, Revision 3 below.

4. ANSI/ANS-3.1 (Draft 12/79), Subsection 4.3.2.b, describes the experience requirements for supervisors not requiring NRC license. The following alternate experience requirements may be applied to personnel filling the supervisory function:

At the time of appointment to the position; the supervisor shall have 4 years experience in the craft or discipline he supervises or an equivalent number of years nuclear plant experience in a supervisory position with a Senior Reactor Operators license.

5. ANSI/ANS-3.1 (Draft 12/79), Subsection 5.3.3 describes the training requirements for the Shift Technical Advisor with Bachelor Degree without an NRC Senior Operator License. In lieu of the requirement of item 3) to that subsection, the following alternative may be applied:

The Shift Technical Advisors will observe control manipulations on the simulator as appropriate.

6. ANSI/ANS-3.1 (Draft 12/79), Section 5.5 describes the retraining program requirements.

The following alternative requirements will be applied for the following functional positions:

Requalification training requirements for Nuclear Shift Supervisor, Nuclear Assistant Shift Supervisor, Control Room Operator - Nuclear, and Shift Technical Advisor are addressed in the Technical Specifications of the individual nuclear facility.

7. ANSI/ANS-3.1 (Draft 12/79), Section 5.5.2 states that Non-licensed personnel shall receive annual retraining in the areas listed in paragraph 5.4. Section (or paragraph) 5.4 describes General Employee Training required for all persons regularly employed in the nuclear power plant. The following alternative for conduct of General Employee Training will be applied:

Non-licensed personnel shall receive retraining in the areas listed in ANSI/ANS 3.1 (Draft 12/79) Section 5.4 at a periodicity of two (2) years.

C-6 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description 3.

Regulatory Guide 1.8, Revision 2, April 1987 Qualification and Training of Personnel for Nuclear Power Plants This commitment applies to the V. C. Summer facility only. This Regulatory Guide endorses ANS-3.1-1981 for the positions of shift supervisor, senior operator, licensed operator and shift technical advisor with certain regulatory positions and the guidance from the Commission's Policy Statement on Engineering Expertise on Shift. It also endorses the standard's approach for the qualification of the radiation protection supervisory personnel with the clarification that for the group leader (radiation protection manager (RPM)) 3 of the 4 years of experience in applied radiation protection be professional-level experience.

For the operating organization positions other than those identified in the above paragraph, the Regulatory Guide endorses the requirements of ANS/ANSI N18.1-1971 for the equivalent positions described in the standard.

In lieu of the training requirements stated in ANS-3.1-1981 and ANSI N18.1-1971, VCS commits to using accredited training programs for the categories identified in 10 CFR 50.120.

4.

Regulatory Guide 1.8, Revision 3, May 2000 Qualification and Training of Personnel for Nuclear Power Plants This commitment applies to quality verification functions and support functions responsible for multiple facilities. This Regulatory Guide endorses ANSI/ANS-3.1-1993, Selection, Qualification, and Training of Personnel for Nuclear Power Plants. Where these editions of the Regulatory Guide and ANSI standard are invoked by this QAPD and/or facility Technical Specifications, the Company will implement the requirements and guidance of the standard and Regulatory Guide subject to the following alternatives:

1. Regulatory Guide 1.8, Rev. 3, C. Regulatory Position, Paragraphs 2.1.1 and 2.1.3 address approval by the plant manager of the equivalents for education and experience for personnel filling Quality Assurance functional positions. The following alternative requirement for approval of the equivalents will be used by replacing the second sentence in each of the above paragraphs with the following sentence:

These other factors are to be evaluated on a case-by-case basis and approved and documented by the plant manager or the responsible executive.

C-7 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description

2. Regulatory Guide 1.8, Rev. 3, C. Regulatory Position, Paragraphs 2.1.2, 2.3, 2.11, and 2.12 address endorsement of ANSI/ASME NQA-1-1983 related to qualification of Quality Control and Quality Assurance Personnel. The following alternative standard will be used for the qualification of these personnel:

References to ANSI/ASME NQA-1-1983 and associated Supplements and Appendices are replaced with references to ANSI/ASME NQA-1-1994 and its associated Supplements and Appendices.

5.

Regulatory Guide 1.26, Revision 3, February 1976 Quality Group Classifications and Standards for Water-, Steam-, and Radioactive Waste-Containing Components of Nuclear Power Plants The commitment to this Guide (including revision/date) is site specific as described in the approved SAR or License for each Company nuclear facility. Where items do not conform to the requirements of the Guide they are addressed in the applicable facilitys SAR. The quality group classification systems used for the facilities conforms with the requirements of this Regulatory Guide with the following alternative:

The Company does not use the specific A, B, C, and D quality groups set forth in this guide. However, the Company met the intent of this guide in developing the list of SSCs and the corresponding association to quality standards. The specific items the QA program applies to are described in detail in the lists maintained by the Nuclear Engineering group.

6.

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

This Regulatory Guide addresses requirements for assuring quality during the design and construction phases of nuclear power plants. The Company will implement the requirements and guidance of the standard and Regulatory Guide during the design and construction phases of the facilities subject to the following alternatives:

1. Part C, Regulatory Position of this Regulatory Guide endorses the basic and supplementary requirements of ANSI/ASME NQA-1-1983 and the ANSI/ASME NQA-1a-1983 Addenda for the establishment and execution of quality assurance programs during the design and construction phases of nuclear power plants.

In place of the specific edition and addenda of NQA-1 addressed in the Regulatory Guide, the Company commits to implement the requirements of the 1994 Edition. The Companys commitment to these requirements and any alternatives to the requirements are addressed below.

C-8 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description

2. Regulatory Position 3.2 establishes external auditing requirements that are acceptable to the NRC during the design and construction phases.

The guidance provided regarding external audits will also be implemented during the operational phase.

3. Table 1 of the Regulatory Guide identifies record types and their retention periods for construction, pre-operational, and startup activities. During the operations phase, records similar to those identified in this Table will also be retained as designated in the Table. An alternative is applied where, in place of Table 1, Section 4.6 requirements for (1) security plans, procedures, and activities records, and (2) emergency plans, procedures, and activities records being retained as lifetime QA records, the records will be retained as required by the applicable regulations. A further alternative is applied for the records of tests and experiments and/or changes to procedures along with their associated reviews pursuant to 10 CFR 50.59/72.48 such that they are retained as required by the applicable regulation. Note that the Regulatory Guide table is copied into Appendix E of this QAPD and modified consistent with these exceptions.

4. Record Retention Exemption for Kewaunee Power Station (KPS)

In an approval dated May 10, 2017, DEK was granted exemptions by the NRC to allow elimination of the requirement to maintain records that are no longer necessary due to the permanently defueled condition and decommissioning status of the Kewaunee Power Station (KPS). The NRC granted DEK a partial exemption from the record keeping requirements of 10 CFR 50.71(c); 10 CFR Part 50, Appendix B, Criterion XVII; and 10 CFR 50.59(d)(3) for the KPS to advance the schedule to remove records associated with structures, systems, and components (SSCs) that have been or will be removed from NRC licensing basis documents by appropriate change mechanisms. As a result of this exemption, the following records no longer need to be retained at KPS:

(1) Records associated with structures, systems, and components (SSCs), and activities that were applicable to the nuclear unit, which are no longer required by Part 50 licensing basis (i.e., removed from the Updated Safety Analysis Report and/or Technical Specifications by appropriate change mechanisms); and (2) Records associated with storage of spent nuclear fuel in the spent fuel pool (SFP).

C-9 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description 7.

Regulatory Guide 1.28, Revision 4, June 2010 Quality Assurance Program Criteria (Design and Construction)

The Company's V. C. Summer facility commits to Revision 4, June 2010, of this Regulatory Guide for the design and fabrication of the Replacement Reactor Vessel Closure Head. The Replacement Reactor Vessel Closure Head design and fabrication was performed in accordance with Design Specifications prepared and maintained by Westinghouse.

8.

ANSI/ASME NQA-1-1994 Quality Assurance Requirements for Nuclear Facility Applications The Company's quality assurance program will implement the basic and supplementary requirements of Part I and the requirements of Part II to the 1994 edition of NQA-1 subject to the alternatives, exceptions, and clarifications addressed below:

1. The Introduction to Part I of NQA-1, Section 4, and certain Subparts to Part II of NQA-1, define terms to be used with the quality assurance requirements.

Additional definitions applicable to implementation of the Company's Quality Assurance Program are contained in Appendix D to this QAPD.

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

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

(2) A qualified engineer may be used to plan inspections, evaluate the capabilities of an inspector, or evaluate the training program for inspectors. For the purposes of these functions, a qualified engineer is one who has a baccalaureate in engineering in a

C-10 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description discipline related to the inspection activity (such as, electrical, mechanical, civil) and has a minimum of five years engineering work experience with at least two years of this experience related to nuclear facilities.

3. Supplement 2S-2, Supplementary Requirements for the Qualification of Nondestructive Examination Personnel, Subsection 2.1 requires application of Recommended Practice SNT-TC-1A, June 1980 Edition to NDE personnel.

The Company will implement the qualification program required by this supplement in accordance with the applicable standard for the facility's commitment to the ASME code or other applicable code governing the activity.

4. Supplement 4S-1, Supplementary Requirements for Procurement Document Control, subsection 2.3 requires that the Supplier have a documented quality assurance program.

This statement is clarified in that procurement documents may allow the Supplier to work under the Dominion Energy QA program.

5. Supplement 7S-1, Supplementary Requirements for Control of Purchased Items and Services, requirements will be incorporated into the Company program subject to the following exception and alternatives:

Exception Dominion Energy considers that other 10 CFR 50 licensees, Authorized Nuclear Inspection Agencies, National Institute of Standards and Technology, or other State and Federal agencies which may provide items or services to the Company facilities are not required to be evaluated or audited.

Alternative Commercial-grade calibration and/or testing services may be procured from commercial laboratories based on the laboratory's accreditation to ISO/IEC-17025 by an Accreditation Body (AB) which is a signatory to the International Laboratory Accreditation and Cooperation (ILAC) Mutual Recognition Arrangement (MRA) provided all of the following are met:

(1) A documented review of the supplier's accreditation is performed and includes a verification of the following:

a. The calibration or test laboratory holds accreditation by an accrediting body recognized by the ILAC MRA. The accreditation encompasses ISO/IEC-17025:2017, General Requirements for the Competence of Testing and Calibration Laboratories.

C-11 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description

b. For procurement of calibration services, the published scope of accreditation for the calibration laboratory covers the needed measurement parameters, ranges, and uncertainties.

c. For procurement of testing services, the published scope of accreditation for the test laboratory covers the needed testing services including test methodology and tolerances/uncertainty.

(2) The purchase documents require that:

a. The service must be provided in accordance with their accredited ISO/IEC-17025:2017 program and scope of accreditation.

b. For calibration services, as-found calibration data must be reported in the certificate of calibration when calibrated items are found to be out-of-tolerance.

c. For calibration services, the equipment/standards used to perform the calibration must be identified in the certificate of calibration.

d. The customer must be notified of any condition that adversely impacts the laboratory's ability to maintain the scope of accreditation.

e. The laboratory performing the calibration and/or testing services shall not subcontract the service to any other supplier.

f. Performance of the services listed on this purchase order is contingent on the laboratorys accreditation having been achieved through an on-site accreditation assessment by the Accreditation Body (AB) within the past 48 months.

g. Any additional technical and quality requirements, as necessary, based upon a review of the procured scope of services, which may include, but are not necessarily limited to, tolerances, accuracies, ranges, and industry standards.

(3) It is validated, at receipt inspection, that the laboratory's documentation certifies that:

a. The contracted calibration or test service has been performed in accordance with their ISO/IEC-17025:2017 program and has been performed within their scope of accreditation, and

b. The purchase order's requirements are met.

C-12 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description NOTE: The ILAC accreditation process cannot be used as part of the commercial-grade dedication process of nondestructive examination (NDE) or nondestructive testing (NDT) services in lieu of performing a commercial-grade survey. This is applicable to both American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV)

Code and non-ASME B&PV Code safety-related applications.

Alternative - Section 10, Commercial Grade Items Controls for commercial grade items are established in Company documents using the guidance of:

• NRC Regulatory Guide 1.164, Rev. 0, June 2017, Dedication of Commercial-Grade Items for Use in Nuclear Power Plants, with the identified exceptions and clarifications to the use of EPRI 3002002982.

• EPRI 3002002982, September 2014, Plant Engineering: Guideline for the Acceptance of Commercial-Grade Items in Nuclear Safety-Related Applications, Revision 1 to EPRI NP-5652 and TR-102260.

Alternative - Section 8, Acceptance of Item or Service, and Section 10, Commercial Grade Items Remote source verification (vendor surveillance, inspection, and audit) using live audio/video technology is used as an alternate method to source verification activities supporting commercial grade dedication or other acceptance process when exigent conditions such as a pandemic or similar state of emergency declarations exist that restricts access or travel to and/or from vendor locations affected by the declaration.

Controls are established in Company documents using the guidance of:

• EPRI 3002019436-A, Remote Source Inspection During a Pandemic or Similar State of Emergency: Screen Criteria and Process Guidance, Final Report with Safety Evaluation.

C-13 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description

6. Supplement 10S-1, Supplementary Requirements for Inspection, Subsection 3.1 addresses reporting independence and requires that inspection personnel shall not report directly to the immediate supervisors who are responsible for performing the work being inspected.

Where quality verification inspections at operating facilities are performed by the Maintenance group, to meet the independence requirements of NQA-1, Supplement 10S-1, Section 3.1, the inspectors report to the Facility Safety and Licensing management (VA) or the Nuclear Oversight management (KPS, MPS, and VCS) while performing the inspection.

7. Supplement 12S-1, Supplementary Requirements for Control of Measuring and Test Equipment, is incorporated into the Company QA program subject to the following clarification and alternative:

Subsection 3.2, addresses requirements for out-of-calibration devices. The out-of-calibration condition is clarified to refer to when the M&TE is found out of the required accuracy limits (i.e., out of tolerance) during calibration.

Section 5 requires equipment to be suitably marked to indicate calibration status. As an alternative, M&TE are not required to be marked with the calibration status where it is impossible or impractical due to equipment size or configuration (such as the label will interfere with operation of the device) provided the required information is maintained in suitable documentation traceable to the device.

8. Supplement 17S-1, Supplementary Requirements for Quality Assurance Records, subsection 4.2(b) requires records to be firmly attached in binders or placed in folders or envelopes for storage. The hard-copy records may use methods other than binders, folders, or envelopes to organize the records for storage.

9. Subpart 2.1, Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components for Nuclear Power Plants, is applied to the Company's facilities subject to the following alternatives (see also the commitment to Regulatory Guide 1.37, Revision 1, March 2007 for VCS):

Subsections 3.1 and 3.2 establish criteria for classifying items into cleanness classes and requirements for each class. Instead of using the cleanness level system of Subpart 2.1, the Company may establish cleanness requirements on a case-by-case basis, consistent with the other provisions of Subpart 2.1. The Company establishes appropriate cleanliness controls for work on safety-related equipment to minimize

C-14 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description introduction of foreign material and maintain system/component cleanliness throughout maintenance or modification activities, including documented verification of absence of foreign material prior to system closure.

10.Subpart 2.2, Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants, requirements will be incorporated into the Company program subject to the following alternatives:

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

(2) For items in storage at Company facilities, the items and the outside of containers (when present) need to meet the appropriate criteria of Subsection 3.9, Marking, necessary to ensure the identity of the item, and proper instructions for preservation during storage and future handling are retained.

(3) Regarding maintenance of items in storage in accordance with Subsection 6.4.2, Care of Items, the requirement of item (f) will not apply to rotating electrical equipment less than 50 HP, the requirement of item (g) will not apply to rotating equipment weighing less than 50 pounds, the requirements of (e), (f), and (g) may be exempted for specific items on a case-by-case basis provided that a documented engineering evaluation determines that such care is not required.

(4) Subsection 6.6, Storage Records, requires written records be prepared containing information on personnel access. As an alternative to this requirement, Company documents establish controls for storage areas that describe those authorized to access areas and the requirements for recording access of personnel. However, these records of access are not considered quality records and will be retained in accordance with the administrative controls for the facility.

11.Subpart 2.3, Quality Assurance Requirements for Housekeeping for Nuclear Power Plants, will be implemented with the following alternative that will be applied during the operational phase:

The Company may choose to not utilize the five-level zone designations required by subsection 2.3, but will utilize work practices, as described in administrative controls, that provide an equivalent level of cleanliness control required by the subpart. This will include as a minimum documented cleanliness inspections which will be performed prior to system closure. As necessary, (e.g., the size of the opening would permit entry of the

C-15 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description tools being used) control of personnel, tools, equipment, and supplies will be established when major portions of the reactor system are opened for inspection, maintenance, or repair. Factors considered in developing the administrative controls include cleanness requirements, personnel safety, fire prevention and protection, radiation control, and security. The controls make use of standard janitorial and work practices to the extent possible.

12.Subpart 2.4, Installation, Inspection, and Testing Requirements for Power, Instrumentation, and Control Equipment at Nuclear Facilities (ANSI/IEEE Std. 336-1985), will be implemented with the following alternatives:

(1) All references to ANSI/ASME NQA-1, ANSI/ASME NQA-2, and ANSI/ANS-3.2 are changed to refer to the appropriate sections of ANSI/ASME NQA-1-1994 and this QAPD.

(2) With regard to Subsection 3.3, Procedures and Instructions, as an alternative to the requirement to utilize a checklist and mark as required or not appropriate the listed items during preparation of procedures or instructions, the Company utilizes administrative controls to ensure the appropriateness and correctness of procedures and instructions including reviews against standards that may not require a checklist to be marked.

(3) Instrumentation and control devices installed in operating facilities are not required to be labeled as described in Subsection 7.2.1, provided the information is maintained in suitable documentation traceable to the device. Also, M&TE devices are not required to be marked with the calibration status where it is impossible or impractical due to equipment size or configuration (such as the label will interfere with operation of the device) provided the required information is maintained in suitable documentation traceable to the device.

C-16 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description 13.Subpart 2.5, Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete, Structural Steel, Soils, and Foundations for Nuclear Power Plants, will be implemented with the following alternative:

(1) Where important to safety structures other than concrete reactor vessels and containments are constructed or modified, other appropriate industry codes and standards may be invoked in place of ACI 359 as specified by the responsible design organization so long as they meet any current license commitments.

(2) With regard to Subsection 7.7, Curing, ASTM C 1315 is added to the first paragraph as another applicable standard for test methods for curing compounds.

14.Subpart 2.15, Quality Assurance Requirements for Hoisting, Rigging, and Transporting of Items for Nuclear Power Plants, will be implemented with the following alternative:

The Company may choose to not use the specific classification of Categories A, B, and C, but ensures items to be handled are evaluated and the appropriate range of controls and requirements for the activity are applied consistent with this Subpart.

15.Subpart 2.16, Requirements for the Calibration and Control of Measuring and Test Equipment Used in Nuclear Facilities (ANSI/IEEE Std. 498-1985) will be implemented with the following alternatives:

(1) All references to ANSI/ASME NQA-1, ANSI/ASME NQA-2, and ANSI/ANS-3.2 are changed to refer to the appropriate sections of ANSI/ASME NQA-1-1994 and this QAPD.

(2) Instrumentation and control devices installed in operating facilities are not required to be labeled as described in Subpart 2.16, Subsection 5.5, provided the information is maintained in suitable documentation traceable to the device.

16.Subpart 2.18, Quality Assurance Requirements for Maintenance of Nuclear Facilities, will be implemented with the following alternative:

(1) Where this subpart references the requirements of ANS-3.2, it shall be interpreted to mean the applicable standards and requirements established within this QAPD.

(2) Regarding subsection 2.5, Work Authorization, paragraph (d), the requirement that the description of work reference the applicable maintenance procedures will be treated as guidance. Personnel responsible for performance of the work are required to ensure that they are using the appropriate maintenance procedure.

C-17 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description 17.Subpart 3.2, Appendix 2.1, Nonmandatory Guidance on Cleaning of Fluid Systems and Associated Components for Nuclear Power Plants The commitment to this subpart is specific to the VCS facility. Only Section 3, Cleaning Recommendations and Precautions, are being committed to as described in NRC Regulatory Guide 1.37, Revision 1, March 2007. In addition, a suitable chloride stress-cracking inhibitor should be added to the fresh water used to flush systems containing austenitic stainless steels.

9.

Regulatory Guide 1.29, Revision 2: For Comment, February 1976 Seismic Design Classification The commitment to this guide is specific to the VCS facility as described in the updated FSAR.

10. Regulatory Guide 1.29, Revision 3, September 1978 Seismic Design Classification The commitment to this guide is site specific as described in the approved SAR or License for each Company nuclear facility. The specific design criteria and seismic designations are reflected in each plant's SAR, and in other docketed analysis.

11. Regulatory Guide 1.29, Revision 4, March 2007 Seismic Design Classification The commitment to this guide is specific to the VCS facility for the replacement of the reactor vessel closure head as described in the updated FSAR.

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

This Regulatory Guide endorses ANSI N18.7-1976/ANS-3.2 as providing overall acceptable quality assurance program requirements for the operations phase of nuclear power facilities.

The Company commits to implementing administrative controls and quality assurance measures during the operations phase for its facilities that are equivalent in nature to those contained in the endorsed standard subject to the following alternatives:

1. The operational phase quality assurance program requirements will be established through the Company's commitment to ANSI/ASME NQA-1-1994 as described within this QAPD. This edition of NQA-1 contains overall quality assurance requirements equivalent to those of ANSI N18.7-1976, and the Company has included within this QAPD the required administrative controls from ANSI N18.7-1976. Therefore, the Company does not commit to compliance with the requirements of ANSI N18.7-1976/ANS-3.2.

C-18 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description

2. As recommended by Regulatory Position C.1, the Company uses Appendix A of Regulatory Guide 1.33 as guidance in establishing the types of procedures required for plant operation and support.

3. The Company's commitment to the applicable Regulatory Guides and associated standards listed in Regulatory Position C.2 is addressed within this QAPD. A number of these Regulatory Positions and Standards have been incorporated into NQA-1-1994.

4. The Company complies with Regulatory Position C.3, as described in Appendix B of this QAPD. Appendix B of this QAPD describes the Company's independent review programs.

5. The Company complies with Regulatory Position C.4 as described within Section 18 of this QAPD, subject to the following alternatives that are comparable to those approved under the previous operational quality assurance programs:

a. The results of actions taken to correct deficiencies affecting nuclear safety that occur in the facility SSCs or methods of operation are evaluated as a part of each audit performed as related to that audited area. An audit of the effectiveness of the corrective action program is performed at a frequency not to exceed two years.

b. Audits of conformance of facility operation to provisions of the Technical Specifications and applicable license conditions are performed at a frequency not to exceed two years.

c. Audits of the performance, training, and qualifications of the facility staff are performed at a frequency not to exceed two years.

d. Internal audit frequencies of well-established activities (i.e., those required by the QAPD to meet the criteria of 10 CFR 50, Appendix B, and conformance of facility operation to provisions of the Technical Specifications and applicable license conditions other than fire protection and security requirements) conducted after placing the facility in operation, may be extended one year at a time beyond the two-year interval based on the results of an annual evaluation of the applicable functional area and objective evidence that the functional area activities are being satisfactorily accomplished. The evaluation shall include a detailed performance analysis of the functional area based upon applicable internal and external source data and due consideration of the impact of any functional area changes in responsibility, resources or management. However, the internal audit frequency interval shall not exceed a maximum of four years. The extended audit frequency may have a grace period of 90 days applied (the normal 25% grace period does not apply). The grace period does not allow the clock for a particular activity to be reset forward. The clock for an activity is reset backwards by performing the activity early.

C-19 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description If an adverse trend is identified in the applicable functional area, the extension of the internal audit frequency interval shall be rescinded and an audit scheduled as soon as practicable.

6. In lieu of compliance with Regulatory Position C.5, the Company has established appropriate equivalent requirements within this QAPD.

13. Regulatory Guide 1.36, Revision 0, February 1973 Nonmetallic Thermal Insulation for Austenitic Stainless Steel The commitment to this Regulatory Guide during construction and operations is site specific as listed in the approved SAR or License for each Company nuclear facility. This Regulatory Guide may be used for plant modifications on a case-by-case basis.

14. Regulatory Guide 1.37, Revision 1, March 2007 Quality Assurance Requirements For Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants The commitment to this Regulatory Guide is specific to the VCS facility. It provides guidance on specifying water quality and precautions related to the use of alkaline cleaning solutions and chelating agents. Procurement orders apply cleaning requirements during fabrication and packaging of safety-related components so that equipment is delivered to the site in a properly cleaned condition. Site procedures for the operational phase meet the requirements of ASME NQA-1-1994, Part II, Subpart 2.1, and this guide.

15. Regulatory Guide 1.54, Revision 0, June 1973 Quality Assurance for Protective Coatings Applied to Nuclear Power Plants This Regulatory Guide endorses ANSI N101.4-1972. The commitment to this Regulatory Guide during construction and earlier operations was site specific as listed in the approved SAR or License for each Company nuclear facility. The Company commits to the QA requirements of this Regulatory Guide and Standard for design and construction activities.

Applicability and implementation of this guide, including quality inspection requirements, for modifications will be determined as needed, by a qualified engineer.

16. Regulatory Guide 1.97 Instrumentation for Light-Water-Cooled Nuclear Power Plants To Assess Plant and Environs Conditions During and Following an Accident The Company commitment to this Regulatory Guide is site specific as indicated in the SAR for the applicable facility and the facility's response to the NRC regarding this guidance.

C-20 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description

17. Regulatory Guide 1.143, Revision 2, November 2001 Design Guidance for Radioactive Waste Management Systems, Structures and Components Installed in Light-water-cooled Nuclear Power Plants The commitment to this Regulatory Guide (including specific revision) during construction and earlier operations was site specific as listed in the approved SAR or License for each Company nuclear facility. The Company commits to this Regulatory Guide for the construction of any new nuclear power plants. The applicable requirements of this Regulatory Guide will be used for plant modifications on a case-by-case basis.

18. Regulatory Guide 1.152, Revision 1, January 1996 Criteria for Digital Computers in Safety Systems of Nuclear Power Plants This Regulatory Guide endorses IEEE/ANS-7-4.3.2-1993. The Company (excluding VCS) commits to using the guidance of this Standard within the provisions of the Regulatory Guide with the following alternative:

Where this Standard makes reference to ASME NQA-1 and ASME NQA-2, the reference will be interpreted to mean the applicable requirements of NQA-1-1994 and this QAPD.

19. Regulatory Guide 1.155, Revision 0, June 1988 Station Blackout The Company commitment to this Regulatory Guide is site specific as indicated in the SAR for the applicable facility and the facility's response to the NRC regarding this guidance. The quality assurance measures applied to the nonsafety-related items and activities for SBO equipment are addressed in Appendix F of this QAPD.

20. Regulatory Guide 1.164, Revision 0, June 2017 Dedication of Commercial-Grade Items for Use in Nuclear Power Plants This Regulatory Guide provisionally endorses technical report EPRI 3002002982, Plant Engineering: Guideline for the Acceptance of Commercial-Grade Items in Nuclear Safety-Related Applications (Revision 1 to EPRI NP-5652 and TR-102260), September 2014.

The Company commits to implementing the evaluation and acceptance requirements for dedication of commercial-grade items and services of this guideline subject to the exceptions or clarifications identified in the NRC Regulatory Guide.

C-21 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description

21. Regulatory Guide 1.189, Rev. 2, October 2009 Fire Protection for Nuclear Power Plants This commitment applies to the V. C. Summer facility only. VCS implements quality assurance requirements for the Fire Protection System in accordance with Regulatory Position 1.7, Quality Assurance, in Regulatory Guide 1.189, Rev. 2, Fire Protection for Operating Nuclear Power Plants, as identified in FSAR Chapter 3, Appendix 3A.

22. Regulatory Guide 4.15, Revision 1, February 1979 Quality Assurance for Radiological Monitoring Programs (Normal Operations)

The Company programs for radiological environmental monitoring comply with the requirements of this Regulatory Guide.

23. Regulatory Guide 7.10, Revision 1, June 1986 Establishing Quality Assurance Programs for Packaging Used in the Transport of Radioactive Material The Company programs for issuing radioactive material for transport complies with the QA requirements for procurement, use, and maintenance of packaging used in the transport of radioactive material as describe in this Regulatory Guide.

24. Generic Letters 89-02/91-05 Actions to Improve the Detection of Counterfeit and Fraudulently Marketed Products Licensee Commercial-Grade Procurement and Dedication Programs The Company meets the intent of these Generic Letters through the procurement activities defined in this QAPD and the commitment to Regulatory Guide 1.164 that endorses industry guidance regarding the selection and qualification of commercial grade Suppliers and for the dedication of commercial grade items.

25. Branch Technical Position APCSB/CMEB 9.5-1 Guidelines for Fire Protection for Nuclear Power Plants This commitment applies to the Kewaunee, Millstone, North Anna, and Surry facilities only.

The Company commits to implementing the guidance of this Technical Position, however, application of the requirements is site specific as described in the applicable facility SAR and license documents. The Company QA program complies with the QA requirements described in APCSB 9.5-1, Position C or CMEB 9.5-1, Position C.4.

C-22 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description

26. Generic Letter 85-06 Quality Assurance Guidance for ATWS Equipment That Is Not Safety-Related The Company commitment to the guidance of this Generic Letter is site specific as indicated in the SAR for the applicable facility and the facility's response to the Generic Letter. The quality assurance measures applied to the nonsafety-related items and activities for ATWS equipment is addressed in Appendix F of this QAPD.

27. RIS 2000-18 Guidance on Managing Quality Assurance Records in Electronic Media This Regulatory Issue Summary endorses the following set of four guidelines prepared by the Nuclear Information and Records Management Association (NIRMA):

• NIRMA TG-11-1998, Authentication of Records and Media

• NIRMA TG-15-1998, Management of Electronic Records

• NIRMA TG-16-1998. Software Configuration Management and Quality Assurance

• NIRMA TG-21-1998, Electronic Records Protection and Restoration The Company commits to using the guidance of the above four guidelines for storing QA records in electronic media for KPS, MPS, NAPS, and SPS.

The Company commits to using the guidance of the four updated guidelines for storing QA records in electronic media for VCS listed below:

• NIRMA TG11-2011, Revision 3, Authentication of Records and Media

• NIRMA TG-15-2011, Revision 3, Management of Electronic Records

• NIRMA TG-16-2011. Revision 1, Software Quality Assurance Documentation and Records

• NIRMA TG-21-2011, Revision 4, Required Records Protection, Disaster Recovery and Business Continuation

D-1 Revision 30 Appendix D Terms and Definitions

D-2 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Terms and Definitions In addition to those terms defined in NQA-1-1994, the following definitions of terms are to be used in the context of this QAPD and activities governed by this QAPD.

Administrative Controls Rules, orders, instructions, procedures, policies, practices and designations of authority and responsibility.

Augmented Quality The application of selected quality assurance measures to structures, systems, components, or programs that are important to safe operation of the nuclear facilities but not classified as nuclear safety-related. Also known as non-safety-related with special quality/regulatory requirements (NSQ).

Experiment Performance of those plant operations carried out under controlled conditions in order to establish characteristics or values not previously known.

Deleterious Corrosion corrosion that cannot be subsequently removed and that adversely affects form, fit, or function.

Independent Review Review completed by personnel not having direct responsibility for the work function under review regardless of whether they operate as a part of an organizational unit or as individual staff members.

ISFSI An independent spent fuel storage installation (ISFSI) is a facility designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with the spent fuel (10 CFR 72.3). The term ISFSI refers to the facility authorized for storage of spent nuclear fuel pursuant to 10 CFR Part 72 and includes the storage pad, the storage containers, and any support facilities. However, if the ISFSI is located at a reactor site, it does not include any structures, facilities, or services that are part of the 10 CFR Part 50 license, unless they are identified as being jointly shared.

KPS Kewaunee Power Station Lifetime (Records) Lifetime in defining the retention period for records is until 1) termination of the applicable Facility Operating License, 2) termination of employment (training and qualification records), 3) transfer of ownership (i.e., fuel), 4) end of service life of the facility, system, or component, as applicable.

MPS Millstone Power Station NAPS North Anna Power Station Nuclear Power Plant Any plant using a nuclear reactor to produce electric power, process steam or space heating.

Operating Activities Work functions associated with normal operation and maintenance of the plant, and technical services routinely assigned to the facility operating organization.

D-3 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Operational Phase That period of time during which the principal activity is associated with normal operation of the plant. This phase of plant life is considered to begin formally with commencement of initial fuel loading, and ends with plant decommissioning.

Organization, Facility Operating Personnel concerned with operation, maintenance and certain technical services such as reactor engineering and performance of tests/inspections. This organization is also referred to in various standards as the onsite organization and comprises the facility staff.

Organization, Support Personnel providing support functions to the operating organization regardless of their physical location. This organization is also referred to in various standards as the offsite organization.

Program Deficiency Failure to develop, document or implement effectively any applicable element of the QA Program.

Quality Verification The act of reviewing, inspecting, testing, checking, auditing, or otherwise determining and documenting whether items, processes, services, or documents conform to specified requirements integral to the QA Program.

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

Safety Analysis Report (SAR) This term is used generically to refer to the SAR required by NRC regulations that is applicable for the particular nuclear facility for which the activity is being performed. This usage includes, but is not limited to preliminary, final, updated final, and decommissioning safety analysis reports.

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

SPS Surry Power Station Surveillance Testing Periodic testing to verify that safety-related structures, systems and components continue to function or are in a state of readiness to perform their functions.

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

Time Intervals With the exception of time intervals from applicable Codes or the facility Technical Specifications, the following definitions shall be applied for other activities that recur on a regular frequency and may be extended by up to 25%:

Weekly: at least once per 7 days Monthly: at least once per 31 days Quarterly or every 3 months: at least once per 92 days

D-4 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Semiannually or every 6 months: at least once per 184 days Every 9 months: at least once per 276 days Yearly or annually: at least once per 366 days Biennial (2 years): at least once per 732 days Triennial (3 years): at least once per 1098 days VA Virginia Power Stations, i.e., NAPS and SPS VCS Virgil C. Summer Nuclear Station

E-1 Revision 30 Appendix E QA Records Retention Requirements For Operating Facilities

E-2 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description QA Records Retention Requirements For Operating Facilities The following Table lists the type of records and the required retention times and provides the re-quirements for those described in the Quality Standards Commitment discussed in Section 17 of this QAPD. The description of the records in this table is not intended to be the specific name of any par-ticular document since these may vary by facility but are a general description of the types of records to be retained. The term Lifetime is defined in Appendix D of this QAPD.

Description of Records Retention Periods

1. Design Records Applicable codes and standards used in design Lifetime Design drawings Lifetime Design calculations and record of checks (includes computer program or corresponding mathematical model)

Lifetime Approved design change requests Lifetime Design deviations and nonconformances Lifetime Design reports Lifetime Design verification data Lifetime Design specifications and amendments Lifetime Safety analysis report Lifetime Certified stress reports for code items Lifetime System descriptions Lifetime System process and instrumentation diagrams Lifetime Technical analysis, evaluations, and reports Lifetime Master change record Lifetime Reliability analysis, evaluation, and reports Lifetime Equipment qualification documentation Lifetime Design review reports 10 years Design procedures and manuals 3 years Design control procedures 3 years Reports of engineering surveillance of field activity 3 years

2. Procurement Records Procurement specification Lifetime

E-3 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Purchase order (unpriced) including amendments Lifetime Procurement procedures 3 years Purchasers pre-award quality assurance survey 3 years Receiving records 3 years Suppliers quality assurance program manual 3 years Source surveillance data plans, audit, and surveillance reports 3 years

3. Manufacturing Records Applicable code data reports Lifetime As-built drawings and records Lifetime Certificate of compliance Lifetime Eddy-current examination final results Lifetime Electrical control verification test results Lifetime Ferrite test results Lifetime Hat treatment records Lifetime Liquid penetrant examination final results Lifetime Location of weld filler material Lifetime Magnetic particle examination final results Lifetime Major defect repair records Lifetime Material properties records Lifetime Nonconformance reports Lifetime Performance test procedure and results records Lifetime Pipe and fitting location report Lifetime Pressure test results (hydrostatic or pneumatic)

Lifetime Radiograph review records Lifetime Ultrasonic examination final results Lifetime Welding procedures Lifetime Radiographs not required by ASME Section XI 10 years Certificate of inspection and test personnel qualification 3 years Cleaning procedures 3 years Eddy-current examination procedure 3 years Description of Records Retention Periods

E-4 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Ferrite test procedure 3 years Forming and bending procedure qualifications 3 years Heat treatment procedures 3 years Hot bending procedure 3 years Inspection and test instrumentation and tooling calibration records (after last calibration) 3 years Liquid penetrant examination procedure 3 years Magnetic particle examination procedure 3 years Packaging, receiving, storage procedures 3 years Product equipment calibration procedure 3 years QA manuals, procedures, and instructions 3 years Radiographic procedures 3 years Ultrasonic examination procedures 3 years Welding materials control procedures 3 years Welding procedure qualifications and data reports 3 years Work processing and sequencing documents 3 years Product equipment calibration records (after last calibration) 3 years

4. Installation, Construction, Maintenance, and Modification Records 4.1 Receiving and Storage Nonconformance reports Lifetime Inspection reports for stored items 3 years Receipt inspection reports on items 3 years Receiving, storage, and inspection procedures 3 years Storage inventory and issuance records 3 years Vendor quality assurance releases 3 years 4.2 Civil Checkoff sheets for tendon installation Lifetime Concrete cylinder test reports and charts Lifetime Concrete design mix reports Lifetime Description of Records Retention Periods

E-5 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Concrete placement records Lifetime Inspection reports for channel pressure tests Lifetime Material property reports on containment liner and accessories Lifetime Material property reports on metal containment shell and accessories Lifetime Material property reports on reinforcing steel Lifetime Material property reports on reinforcing steel splice sleeve material Lifetime Material property reports on steel embedments in concrete Lifetime Material property reports on structural steel and bolting Lifetime Material property reports on tendon fabrication material Lifetime Pile drive log Lifetime Pile loading test reports Lifetime Procedure for containment vessel pressure proof test and leak-rate tests and results Lifetime Reports for periodic tendon inspection Lifetime Reports of high-strength bolt torque testing Lifetime Soil compaction test reports Lifetime Aggregate test reports Lifetime Batch plant operation reports 10 years Cement grab sample reports 10 years Material property reports on steel piling 10 years Mix water chemical analysis 10 years Releases to place concrete 10 years Slump test results 10 years User's tensile test reports on reinforcing steel 10 years User's tensile test reports on reinforcing steel splices 10 years 4.3 Welding Ferrite test results Lifetime Heat treatment records Lifetime Liquid penetrant test final results Lifetime Material property records Lifetime Description of Records Retention Periods

E-6 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Magnetic particle test final results Lifetime Major weld repair procedure and results Lifetime Radiograph review records and final results Lifetime Ultrasonic test final results Lifetime Weld location diagrams Lifetime Weld procedures Lifetime Welding filler metal material reports Lifetime Ferrite test procedures 3 years Heat treatment procedures 3 years Liquid penetrant test procedures 3 years Magnetic particle test procedures 3 years Radiographic test procedures 3 years Ultrasonic test procedures 3 years Welding materials control procedures 3 years Welding personnel qualifications 3 years Weld fitup reports 10 years Weld procedure qualifications and results 10 years 4.4 Mechanical Cleaning procedures and results Lifetime Installed lifting and handling equipment procedures, inspection, and test data Lifetime Lubrication procedures Lifetime Material properties records Lifetime Pipe and fitting location reports Lifetime Pipe hanger and restraint data Lifetime Safety valve response test procedures Lifetime Code data reports Lifetime Pressure test results (hydrostatic or pneumatic) 3 years Chemical composition user's test (grab samples) for thermal insulation 10 years Chemical tests of water used for mixing insulation cement 10 years Description of Records Retention Periods

E-7 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Data sheets or logs on equipment installation, inspection, and alignment 10 years Documentation of system checkoffs (logs or data sheets) 10 years Material property test reports for thermal insulation 10 years Safety valve response test results 10 years Cleaning procedures 3 years Construction lifting and handling equipment test procedures 3 years Erection procedures for mechanical components 3 years Hydrotest procedures 3 years 4.5 Electrical and Instrumentation and Control Cable pulling tension data Lifetime Cable separation data Lifetime Cable terminating/splicing procedures Lifetime Certified cable test reports Lifetime Relay test procedures and test results Lifetime Voltage breakdown test results on liquid insulation Lifetime Cable pulling procedures 3 years Cable separation checklists 3 years Instrument calibration results (after last calibration) 3 years Documentation of testing performed after installation and prior to conditional acceptance of systems 10 years Field workmanship checklist or equivalent logs 10 years Reports of pre-installation tests 10 years 4.6 General As-built drawings and records Lifetime Final inspection reports and releases Lifetime Nonconformance reports Lifetime Specifications and drawings Lifetime Index system to record file Lifetime Quality assurance and quality control manuals (QAPD) - current revision

- Superseded material Lifetime plus 3 years 3 years after superseded Description of Records Retention Periods

E-8 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Fire protection reports Lifetime Evaluation of results of reportable safety concerns as required by regulations Lifetime Calibration reports for measuring and test equipment and instruments (after last calibration) 3 years Calibration procedures for measuring and test equipment and instruments 3 years Certificate of inspection and test personnel qualification 3 years Field audit reports 3 years Field quality assurance manuals 3 years Quality assurance system audit reports and related correspondence 3 years Special tool calibration records (after last calibration) 3 years

5. Preoperational, Startup, and Operational Test Records Final system adjustment data Lifetime Pressure test results (hydrostatic or pneumatic) (VCS only)

Lifetime Initial plant loading data Lifetime Plant load ramp change data Lifetime Plant load step change data Lifetime Preoperational test procedures and results Lifetime Reactor protection system tests and results Lifetime Startup test procedures and results Lifetime Inservice inspection reports Lifetime Records of reactor tests and experiments 5 years Records and logs of maintenance activities, inspections, repair, and replacement of principal items of structures, systems, and components Lifetime Automatic emergency power source transfer procedures and results 10 years Initial heatup, hot functional, and cooldown procedures and results 10 years Initial reactor criticality test procedures and results 10 years Instrument AC system and inverter test procedures and reports 10 years Main and auxiliary power transformer test procedures and results 10 years Offsite power source energizing procedures and test reports 10 years Description of Records Retention Periods

E-9 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Onsite emergency power source energizing procedure and test reports 10 years Primary and secondary auxiliary power test procedures and results 10 years Startup logs 10 years Station battery and DC power distribution test procedures and reports 10 years Water chemistry report 10 years Records of reviews performed for changes made to the facility or equipment pursuant to 10 CFR 50.59/72.48 Lifetime Records of reviews performed for changes made to procedures or reviews of tests and experiments pursuant to 10 CFR 50.59/72.48 5 years Startup problems and resolutions 10 years Flushing results 10 years Power transmission substation test procedures and results 3 years Surveillance activities, inspections, and calibrations required by the technical specifications records 3 years System lubricating oil flushing procedures 3 years Flushing procedures 3 years Pressure test procedures 3 years Periodic checks, inspections, and calibrations performed to verify that surveillance requirements are being met 3 years

6. Additional Operating Phase Records Records and drawing changes reflecting plant design modifications made to systems and equipment described in the SAR Lifetime Records of new, irradiated, and spent fuel inventory, transfers of fuel, and assemblies history Lifetime plus 5 years Records of plant radiation and contamination surveys Lifetime Records of off-site environmental monitoring surveys Lifetime Records of radiation exposure of all individuals who enter radiation control areas Lifetime Records of radioactive levels of liquid and gaseous waste released to the environs Lifetime Records of reviews performed for changes made to the offsite dose calculation manual and the process control program Lifetime Records of meetings of the facility safety review committee/group and the Management Safety Review Committee Lifetime Description of Records Retention Periods

E-10 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Records of transient or operational cycles for those facility components designated to operate safely for a limited number of transients or operational cycles Lifetime Records of the service lives of all hydraulic and mechanical snubbers on safety-related systems, including the date at which the service life commences and associated installation and maintenance records (VA)

Lifetime Records of the service lives of all hydraulic and mechanical snubbers defined in TS 3.7.7 including the date at which the service life commences and associated installation and maintenance records. (VCS)

Lifetime Records of Environmental Qualification in accordance with 10 CFR 50.49 Lifetime Records of secondary water sampling and water quality Lifetime Records of normal plant operation, including power levels and periods of operation at each power level 5 years Records of principal maintenance activities, including inspection, repair, substitution or replacement of principal items of equipment important to nuclear safety Lifetime Records of reportable events 5 years Records of radioactive material shipments 3 years Records of activities for procurement, use, and maintenance of packaging used in the transport of radioactive material pursuant to 10 CFR Part 71 (ref. §71.135)

Lifetime plus 3 years superseded material 3 years after superseded Records of sealed source leak test results and physical inventories of sealed source material 5 years Records of current individual plant staff members qualifications, experience, training and retraining Lifetime or as noted below Radiological protection training records (e.g., general training provided to personnel with access to the facilities, Advanced Radiation Worker, Radiation Protection Technician, etc.)

Lifetime Initial training and qualification records Lifetime Requalification records (except licensed individuals) 3 training cycles Requalification records for licensed individuals 6 years after license renewal Training materials - Revision 0 records Lifetime Licensed Operators training materials - superseded revisions 6 years Non-licensed Facility staff training materials - superseded revisions 3 training cycles Radiation Protection training materials - superseded revisions Lifetime Description of Records Retention Periods

E-11 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Retraining, specialized training, continuing training records (except licensed individuals and Radiological Protection technicians 3 training cycles Contractor training (except general training for facility access, Advanced Radiation Worker, Radiation Protection Technician training and retraining, etc.)

3 training cycles NANT Accreditation records

- Initial accreditation

- Superseded material Lifetime 4 years Description of Records Retention Periods

F-1 Revision 30 Appendix F Augmented Quality Assurance Requirements For Selected SSCs and Programs

F-2 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description Augmented Quality Assurance Requirements For Selected SSCs and Programs 1.

Nonsafety-Related SSCs - Significant Contributors to Plant Safety Specific program controls (augmented quality assurance) are applied to nonsafety-related SSCs, for which 10 CFR 50, Appendix B is not applicable, that are significant contributors to plant safety or have special regulatory treatment applied to them. The specific program controls consistent with applicable sections of the QAPD are applied to those items in a selected manner, targeted at those characteristics or critical attributes that render the SSC a significant contributor to plant safety.

The following clarify the applicability of the QA Program to the selected nonsafety-related SSCs and related activities, including the identification of exceptions to the QA Program described in Sections 1 through 18 of this QAPD taken for nonsafety-related SSCs.

1.1 Organization The verification activities described in this Part may be performed by the Dominion Energy line organization. The independent QA/QC groups described in Section 1 are not required to perform these functions. The organizational authorities and functions are described in the facility's programs and procedures.

1.2 QA Program Dominion Energy QA requirements for nonsafety-related SSCs are established in Appendix F of the QAPD and appropriate procedures. Suppliers of these SSCs or related services describe the quality controls applied in appropriate procedures. A new or separate QA program is not required.

1.3 Design Control Dominion Energy has established design control measures to ensure that the established design requirements are included in the design. These measures ensure that applicable design inputs are included or correctly translated into the design documents, and deviations from those requirements are controlled. Design verification is provided through the normal supervisory review of the designer's work.

1.4 Procurement Document Control Procurement documents for items and services obtained by or for Dominion Energy shall include or reference documents describing applicable design bases, design requirements, and other requirements necessary to ensure component performance. The procurement documents are controlled to address deviations from the specified requirements.

F-3 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description 1.5 Instructions, Procedures, and Drawings Dominion Energy provides documents such as, but not limited to, written instructions, plant procedures, drawings, vendor technical manuals, and special instructions in work orders, to direct the performance of activities affecting quality. The method of instruction employed provides an appropriate degree of guidance to the personnel performing the activity to achieve acceptable functional performance of the SSC.

1.6 Document Control Dominion Energy controls the issuance and change of documents that specify quality requirements or prescribe activities affecting quality to ensure that correct documents are used. These controls include review and approval of documents, identification of the appropriate revision for use, and measures to preclude the use of superseded or obsolete documents.

1.7 Control of Purchased Items and Services Dominion Energy employs measures, such as inspection of items or documents upon receipt or acceptance testing, to ensure that all purchased items and services conform to appropriate procurement documents.

1.8 Identification and Control of Purchased Items Dominion Energy employs measures where necessary, to identify purchased items and preserve their functional performance capability. Storage controls take into account appropriate environmental, maintenance, or shelf life restrictions for the items.

1.9 Control of Special Processes Dominion Energy employs process and procedure controls for special processes, including welding, heat treating, and nondestructive testing. These controls are based on applicable codes, standards, specifications, criteria, or other special requirements for the special process.

1.10 Inspection Dominion Energy uses documented instructions to ensure necessary inspections are performed to verify conformance of an item or activity to specified requirements or to verify that activities are satisfactorily accomplished. These inspections may be performed by knowledgeable personnel in the line organization. Knowledgeable personnel are from the same discipline and have experience related to the work being inspected.

F-4 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description 1.11 Test Control Dominion Energy employs measures to identify required testing that demonstrates that equipment conforms to design requirements. These tests are performed in accordance with test instructions or procedures. The test results are recorded, and authorized individuals evaluate the results to ensure that test requirements are met.

1.12 Control of Measuring and Test Equipment (M&TE)

Dominion Energy employs measures to control M&TE use, including calibration and adjustment at specific intervals or prior to use.

1.13 Handling, Storage, and Shipping Dominion Energy employs measures to control the handling, storage, cleaning, packaging, shipping, and preservation of items to prevent damage or loss and to minimize deterioration. These measures include appropriate marking or labels, and identification of any special storage or handling requirements.

1.14 Inspection, Test, and Operating Status Dominion Energy employs measures to identify items that have satisfactorily passed required tests and inspections and to indicate the status of inspection, test, and operability as appropriate.

1.15 Control of Nonconforming Items Dominion Energy employs measures to identify and control items that do not conform to specified requirements to prevent their inadvertent installation or use.

1.16 Corrective Action Dominion Energy employs measures to ensure that failures, malfunctions, deficiencies, deviations, defective components, and non-conformances are properly identified, reported, and corrected.

1.17 Records Dominion Energy employs measures to ensure records are prepared and maintained to furnish evidence that the above requirements for design, procurement, document control, inspection, and test activities have been met.

1.18 Audits Dominion Energy employs measures for line management to periodically review and document the adequacy of the process, including taking any necessary corrective action.

Audits independent of line management are not required. Line management is

F-5 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description responsible for determining whether reviews conducted by line management or audits conducted by any organization independent of line management are appropriate. If performed, audits are conducted and documented to verify compliance with design and procurement documents, instructions, procedures, drawings, and inspection and test activities. Where the measures of this Appendix are implemented by the same programs, processes, or procedures as the comparable activities of Sections 1 to 18 of the QAPD, the audits performed under the provisions of Section 18 may be used to satisfy the review requirements of this paragraph (1.18).

2.

Nonsafety-Related SSCs Credited for Regulatory Events The following criteria apply to fire protection (10 CFR 50.48), anticipated transients without scram (ATWS) (10 CFR 50.62), and station blackout (SBO) (10 CFR 50.63) SSCs that are not safety-related.

1. Dominion Energy implements quality assurance requirements for the Fire Protection System in accordance with each facility's Fire Protection Plan/Program that meets the specific Branch Technical Position (BTP) or Regulatory Guide identified in the applicable facility SAR.

2. Dominion Energy implements the quality assurance requirements for ATWS SSCs in accordance with Appendix F, Section 1.

3. Dominion Energy implements quality assurance requirements for SBO SSCs in accordance with Appendix F, Section 1 that meets Regulatory Guide 1.155, Station Blackout.

3.

Alternative Treatment for RISC-2 and RISC-3 SSCs Activities conducted for RISC-2 and RISC-3 SSCs under an approved license amendment to implement the voluntary regulations of 10 CFR 50.69 are subject to the applicable administrative controls in Section 1 to Appendix F of this QAPD as modified below. Such application is to provide reasonable confidence that: (1) the RISC-2 SSCs perform their safety-significant functions consistent with the categorization process assumptions; and, (2) the RISC-3 SSCs remain capable of performing their safety-related functions under design basis conditions, including seismic and environmental, throughout their service life. The following additional requirements for inspection, testing, and corrective action as they relate to the alternative treatment must be applied.

F-6 Revision 30 Dominion Energy Nuclear Facility Quality Assurance Program Description 3.1 Inspection and Testing Periodic inspection and testing activities shall be conducted as described in Sections 10, Inspection, and 11, Test Control, of this QAPD to determine that RISC-3 SSCs will remain capable of performing their safety-related functions under design basis conditions.

3.2 Corrective Action Identification and correction of deficiencies for RISC-2 and RISC-3 SSCs shall be conducted as described in Section 16, Corrective Action, of this QAPD. Conditions that would prevent a RISC-3 SSC from performing its safety-related functions under design basis conditions must be corrected in a timely manner. For significant conditions adverse to quality, measures must be taken to provide reasonable confidence that the cause of the condition is determined and corrective action taken to preclude repetition.

4.

Nonsafety-Related SSCs subject to Aging Management for Renewed Licenses Activities conducted for aging management under a renewed license are subject to the applicable administrative controls in Appendix F of this QAPD, Section 1 with the following additional requirements, as they relate to the activities and procedures for the corrective action process and the confirmation process.

4.1 Document Control The aging management and confirmation process is implemented through procedures that are subject to the document review and approval controls of Section 6, Document Control, of this QAPD.

4.2 Inspection and Testing Periodic inspection and testing activities must be conducted in accordance with the requirements of Sections 10, Inspection, and 11, Test Control, of this QAPD to determine that SSCs in the aging management program remain capable of performing their important functions during the term of the renewed license.

4.3 Corrective Action Identification and correction of deficiencies for nonsafety-related SSCs subject to aging management for renewed licenses shall be conducted as described in Section 16, Corrective Action, of this QAPD.