NG-21-0028, Request for Approval of NextEra Energy Duane Arnold, Llc'S Decommissioning Quality Assurance Program Revision 0

Request for Approval of NextEra Energy Duane Arnold, Llc'S Decommissioning Quality Assurance Program Revision 0

ML21214A125
Person / Time
Site:	Duane Arnold
Issue date:	07/30/2021
From:	Hansen P NextEra Energy Duane Arnold
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NG-21-0028
Download: ML21214A125 (49)

Text

NEXTera"'

ENERGY~

DUANE ARNOLD July 30, 2021 NG-21-0028 10 CFR 50.54(a)(4)

U. S. Nuclear Regulatory Commission ATTN : Document Control Desk Washington, DC 20555-0001 Duane Arnold Energy Center Docket No . 50-331 Renewed Facility Operating License No. DPR-49 Request for Approval of NextEra Energy Duane Arnold, LLC's Decommissioning Quality Assurance Program Revision 0 In accordance with 10 CFR 50 .54(a)(4), NextEra Energy Duane Arnold, LLC (NEDA) hereby submits a proposed Decommissioning Quality Assurance Program (DQAP)

Revision 0 (Enclosure 1) for U.S. Nuclear Regulatory Commission (NRC) review and approval.

The proposed DQAP is based on the NRG-approved Duane Arnold Quality Assurance Topical Report (QATR) FPL-3. The intent of the DQAP is to describe appropriate and sufficient requirements to establish how the quality assurance program meets 10 CFR 50, Appendix B criteria while allowing flexibility in how QA requirements are met.

In accordance with 10 CFR 50 .54(a)(4)(ii), a comparison of the DQAP to the current QATR was performed (Enclosure 2). Additionally, based on identification of the reduction in commitment, the DQAP requires NRC approval prior to implementation. QATR FPL-3 will no longer be effective at DAEC following approval and implementation of the DQAP .

NEDA is requesting NRC review and approval by June 1, 2022. NEDA requests that the approved DQAP become effective after all spent fuel has been removed from the spent fuel pool and placed in dry storage within the DAEC site-controlled ISFSI, with a 60-day implementation period.

There are no new commitments contained in this submittal.

NextEra En ergy Du ane Arnold , LLC, 3277 DAEC Ro ad, Palo , IA 5232 4

NG-21-0028 Page 2 of 2 Should there be any questions regarding this information, please contact J. Michael Davis at (319) 851-7032.

Paul Hansen Decommissioning Director, Duane Arnold Energy Center NextEra Energy Duane Arnold, LLC

Enclosures:

As Stated cc: Region Ill Administrator, USNRC Project Manager, USNRC, Duane Arnold Energy Center Inspector, USNRC, Duane Arnold Energy Center

Enclosure 1 to NG-21-0028 NextEra Energy Duane Arnold, LLC Decommissioning Quality Assurance Program 35 pages follow

NextEra Energy Duane Arnold, LLC Decommissioning Quality Assurance Program (DQAP)

NEXTera ENERGY ~

NextEraTM Energy Duane Arnold, LLC DECOMMISSIONING QUALITY ASSURANCE PROGRAM (DQAP)

(Formerly QATR)

Duane Arnold Energy Center Proposed Revision 0 Proposed Revision 0 1 of 35 TBD

NextEra Energy Duane Arnold, LLC Decommissioning Quality Assurance Program (DQAP)

Approved By:

Richard Baird Director Nuclear Assurance and Assessment Date Bob Coffey Executive Vice President, Nuclear Division and Chief Nuclear Officer Date Proposed Revision O 2 of 35 TBD

NextEra Energy Duane Arnold, LLC Decommissioning Quality Assurance Program (DQAP)

TABLE OF CONTENTS POLICY STATEMENT .................................................................................................... 3 1.0 ORGANIZATION .................................................................................................... 5 2.0 QUALITY ASSURANCE PROGRAM ..................................................................... 8 3.0 DESIGN CONTROL ............................................................................................. 10 4.0 PROCUREMENT DOCUMENT CONTROL ......................................................... 12 5.0 INSTRUCTIONS, PROCEDURES AND DRAWINGS .......................................... 13 6.0 DOCUMENT CONTROL ...................................................................................... 14 7.0 CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES ......... 15 8.0 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS .................................................................................................... 18 9.0 CONTROL OF SPECIAL PROCESSES .............................................................. 19

10. INSPECTION ....................................................................................................... 20

11. TEST CONTROL ................................................................................................. 21

12. CONTROL OF MEASURING AND TEST EQUIPMENT ...................................... 22

13. HANDLING, STORAGE, AND SHIPPING ........................................................... 23

14. INSPECTION, TEST, AND OPERATING STATUS .............................................. 24

15. NONCONFORMING MATERIAL, PARTS, OR COMPONENTS .......................... 25

16. CORRECTIVE ACTION ....................................................................................... 26

17. QUALITY ASSURANCE RECORDS ................................................................... 27

18. AUDITS ................................................................................................................ 28 APPENDIX A TERMS AND DEFINITIONS ....................................................... 29 APPENDIX B WRITING REFERENCE DOCUMENTS ............................................... 30 APPENDIX C REGULATORY COMMITMENTS ......................................................... 31 APPENDIX D GENERAL ADMINISTRATIVE REQUIREMENTS ............................... 32 APPENDIX E SITE SPECIFIC ADMINISTRATIVE REQUIREMENTS ..................... 34 Proposed Revision 0 3 of 35 TBD

NextEra Energy Duane Arnold, LLC Decommissioning Quality Assurance Program (DQAP)

POLICY STATEMENT NextEra Energy Duane Arnold, LLC (NEDA) shall maintain the permanently defueled Duane Arnold Energy Center (DAEC) in a manner that will ensure the health and safety of the public and our workers. The facility shall, at a minimum, be in compliance with the applicable requirements of the Code of Federal Regulations, Nuclear Regulatory Commission (NRC)

Facility Licenses, and the laws and regulations of the state and local governments.

The Decommissioning Quality Assurance Program (DQAP), is the highest tiered document that assigns major functional responsibilities for the DAEC. Implementing documents assign more specific responsibilities and define the organizational interfaces involved in conducting important to safety activities within the scope of this DQAP. These requirements apply to those organizations and positions which manage and perform activities within its scope.

The NEDA organization is structured on the basis that the attainment of the objectives of this Program relies on those who manage, perform, and support the performance of activities within the scope of the DQAP. Assurance of this attainment relies on those who have no direct responsibility for performing the activity.

Proposed Revision O 4 of 35 TBD

NextEra Energy Duane Arnold, LLC Decommissioning Quality Assurance Program (DQAP) 1.0 ORGANIZATION NEDA is responsible for the establishment and execution of the DQAP at DAEC.

NEDA submitted a Certification of Permanent Cessation of Operations and Certification of Permanent Removal of Fuel to the NRC, per 10 CFR 50.82(a)(1)(i) and (ii), respectively. The titles of managers used in the DQAP are generic, or functional titles and their formal titles may vary. Unless otherwise specifically prohibited, responsibilities of managers described in the DQAP may be delegated to, and be performed by, other qualified individuals. Site organizations will be commensurate with the activities and risks associated with decommissioning.

1.1 Responsibilities 1.1.1 The authorities and duties of persons and organizations performing activities within the scope of this DQAP are established and delineated in writing. These activities include both performing the functions of attaining quality objectives and the Quality Assurance functions.

1.1.2 All NEDA personnel who work directly, or indirectly, for NEDA are responsible for the achievement of quality in their work. Accordingly, all NEDA personnel, affiliate personnel, and its contractors engaged in supporting decommissioning activities shall comply with the requirements of this DQAP.

1.1.3 The overall responsibility for maintenance, inspection, test, modification, decommissioning and storage of spent fuel resides with the Executive Vice President and Chief Nuclear Officer (CNO), NextEra Energy, Nuclear. The Decommissioning Director is responsible for the administration and implementation of the DQAP at the DAEC.

1.1.4 The DQAP is reviewed and approved by the management position responsible for Nuclear Oversight. The management position responsible for Nuclear Oversight is responsible for periodically appraising the CNO on the effectiveness of the DQAP implementation and immediately apprises the CNO of significant problems affecting quality.

1.1.5 Management of line organizations at the decommissioning facility is responsible to ensure that the quality of work and activities meets the requirements set forth in the decommissioning technical specifications, this DQAP, and implementing procedures.

Proposed Revision O 5 of 35 TBD

NextEra Energy Duane Arnold, LLC Decommissioning Quality Assurance Program (DQAP) 1.2 Corporate Organizations 1.2.1 The Chief Nuclear Officer (CNO), NextEra Energy, reports to the Chairman and CEO of NextEra Energy, Inc., and has overall responsibility for the implementation of the QAP and for the Nuclear Division's activities including corporate responsibility for overall plant nuclear safety. This responsibility includes setting and implementing policies, objectives, expectations, and priorities to ensure activities are performed in accordance with this DQAP and other requirements. The following fleet management positions and committees report to and/or receive direction from the CNO with respect to their assigned roles and responsibilities associated with the execution of this DQAP:

• A management position responsible for Strategic Planning, Project Management, License Renewal, Nuclear Projects, and Decommissioning. This position reports to the CNO and is responsible for defining standard programs and processes, delivering effective services and support, providing technical oversight of program implementation, and supporting the deployment and sharing of best practices throughout the nuclear organization in accordance with the OAP and other requirements, as applicable.

• A management position responsible for Nuclear Oversight reports to the CNO and is responsible to provide oversight to ensure compliance with the DQAP. Nuclear Oversight maintains a staff of supervisory, administrative, and technical personnel to verify the DQAP is effectively implemented. Nuclear Oversight personnel shall have sufficient authority and organizational freedom to identify any quality problems and to verify implementation of corrective actions. Additionally, Nuclear Oversight personnel shall have direct access to appropriate levels of management necessary to perform their function and shall be independent from cost and schedule when opposed to quality and safety considerations. Functional responsibilities include:

• Managing the performance of periodic audits and quality verification inspections in order to verify that activities within the scope of the DQAP have been correctly performed.

• Establishing quality assurance practices and policies.

• Authority and obligation to raise any conditions adverse to quality to the CNO for resolution as necessary.

• Assuring quality activities are performed in accordance with implementing procedures.

• Employee Concerns Program.

• Reporting on oversight activities to the CNO.

• Authority to stop work when quality is adversely affected.

1.2.2 Additional Support Organization Additional support organizational activities such as emergency preparedness, calibrations, procurement, training, legal, communications, records and document control, information technology, business operations, nuclear assurance and human resources may be provided by the station or by corporate or contracted organizations.

Proposed Revision O 6 of 35 TBD

NextEra Energy Duane Arnold, LLC Decommissioning Quality Assurance Program (DQAP) 1.3 Station Management 1.3.1 The Decommissioning Director reports to the CNO and is responsible for the overall safe activities at the plant. The Decommissioning Director shall have control over those onsite activities necessary for safe storage and maintenance of spent nuclear fuel, including maintaining the facility within the constraints of applicable regulatory requirements, license, decommissioning technical specifications and training. The Decommissioning Director, or specified designee, shall approve, prior to implementation, all tests, experiments, and modifications to systems or equipment that affect the safe storage and maintenance of spent nuclear fuel. Supervisory direction is provided for the technical review program, including approval of individuals as technical reviewers as applicable. The following position reports to the Decommissioning Director:

• A management position responsible for Security, with responsibility for operating strategies that support nuclear and personnel safety within the constraints of the decommissioning license and regulatory requirements.

Functional areas of responsibility also include chemistry activities, environmental services, radiation protection, maintenance and work control, and related procedures and programs. The Safety Review Group serves the Decommissioning Director in a technical capacity and provides review of plant safety and performance (see Appendix D).

Proposed Revision 0 7 of 35 TBD

NextEra Energy Duane Arnold, LLC Decommissioning Quality Assurance Program (DQAP) 2.0 QUALITY ASSURANCE PROGRAM 2.1 The QA Program for the DAEC decommissioning facility is described in this DQAP, which provides control over activities affecting quality to an extent consistent with their importance to safety and compliance. The DQAP includes specific monitoring activities which are measured against acceptance criteria in a manner sufficient to provide NEDA management assurance that the activities affecting quality are performed in an acceptable manner. The DQAP requirements apply to (i.e. the following are in the scope of the DQAP) structures, systems, or components (SSCs) designated as important to safety, regulatory programs, and other activities, and SSCs identified in either the facility specific Decommissioning Safety Analysis Report (DSAR) or Appendices of this DQAP.

2.2 The DQAP satisfies the requirements of 10 CFR 50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Processing Plants, 10 CFR 71 Subpart H, Quality Assurance for Packaging and Transportation of Radioactive Material, and 10 CFR 72 Subpart G, Quality Assurance for Independent Storage of Spent Nuclear Fuel and High-Level Radioactive Waste. Regulatory commitments are listed within Appendix C of the DQAP. Implementation of this DQAP is controlled through separately issued procedures, instructions, and drawings. Each organization is responsible for the establishment and implementation of procedures and instructions prescribing the activities within the scope of this DQAP for which they are responsible.

2.3 Activities affecting quality shall be accomplished under suitably controlled conditions.

Controlled conditions include the use of appropriate equipment; suitable environmental conditions for accomplishing the activity, such as adequate cleanliness; and assurance that all prerequisites for the given activity have been satisfied. The DQAP takes into account the need for special controls, processes, test equipment, tools, and skills to attain the required quality, and the need for verification of quality by inspection and testing where required.

2.4 Changes to the DQAP will be implemented in accordance with 10 CFR 50.54(a).

2.5 Program Control and Authority 2.5.1 The management position responsible for Nuclear Oversight is responsible for ensuring that the applicable portions of the DQAP are properly documented, approved and implemented before an activity within the scope of the DQAP is executed. Disputes arising between departments or organizations on any QA matter that cannot be resolved at a lower level of management will be referred to the CNO.

2.5.2 Additional requirements for specific programs are described in Administrative Controls, in the applicable facility Decommissioning technical specifications, or in the DQAP, with the exception of security requirements which are contained in the applicable facility Physical Security Plan; and Emergency Plan requirements which are contained within the applicable facility Site Emergency Plan. Fire Protection Program requirements are addressed in Appendix D of this DQAP.

Proposed Revision O 8 of 35 TBD

NextEra Energy Duane Arnold, LLC Decommissioning Quality Assurance Program (DQAP) 2.6 Program Review 2.6.1 The status and effectiveness of the DQAP and its implementation is periodically reviewed by the management of the organization responsible for its execution. In addition, the effectiveness of the DQAP is evaluated and reported by Nuclear Oversight through the audit and inspection functions.

2.7 Personnel Training and Qualifications 2.7.1 Formal indoctrination and training programs for personnel performing or verifying activities within the scope of this DQAP are established and maintained. The indoctrination and training programs are established by on-site and/or off-site organizational units responsible for the performance or verification of activities within the scope of this DQAP.

2.7.2 All personnel shall have sufficient qualifications, as applicable, to perform their assigned duties. Implementing procedures provide the criteria utilized for determining and assessing appropriate staff qualifications. Indoctrination, training, and qualification programs are established such that:

• Personnel performing and/or verifying activities affecting quality are trained and qualified in the principles, techniques, and requirements of the activity being performed.

• Formal training and qualification program documentation includes the objective, content of the program, attendees, and date of attendance.

• Proficiency tests are given as applicable to those personnel performing and verifying activities affecting quality and the acceptance criteria are developed to determine if individuals are properly trained and qualified.

• Certificate of qualification, as applicable, clearly delineates the specific functions personnel are qualified to perform and the criteria used to qualify personnel in each function.

• Proficiency of personnel performing and verifying activities affecting quality is maintained by re-training, re-examining, re-qualifying, and/or recertifying as determined by management or program commitment.

Proposed Revision 0 9 of 35 TBD

NextEra Energy Duane Arnold, LLC Decommissioning Quality Assurance Program (DQAP) 3.0 DESIGN CONTROL 3.1 Measures shall be established to assure that the designs, including applicable regulatory requirements and design bases, technical and quality requirements, are correctly translated to design documents which include specifications, drawings, procedures and instructions. NEDA has overall responsibility for design and design control activities including, preparing, reviewing, approving, and verifying design documents related to the facility's structures, systems, and components (SSCs) within the scope of the DQAP.

3.2 Design changes to SSCs within the scope of this DQAP shall be properly controlled using design control measures commensurate with those applied to the original design. Design changes are reviewed and approved by the same design groups cognizant in the discipline affected by the change that reviewed and approved the original documentation, unless alternative design groups are designated. Design activities associated with the facility changes or modifications may be performed by NEDA or qualified contractors. Design groups shall have access to background information, shall be competent in the specific area of design interest, and shall understand the requirements and intent of the original design.

3.3 Measures shall be established for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to SSCs that have current important to safety functions. Design control implementing procedures shall define responsibility for the following:

• Design Input

• Design Performance

• Design Interface

• Design Verification

• Design Change 3.4 Design inputs shall be identified, documented, and correctly translated into design outputs. Design inputs shall be specified to a level of detail necessary to allow the design activities to be carried out in a controlled manner. The final design output shall relate to the design input in sufficient detail to facilitate design verification.

3.5 The design organization shall prescribe and document the design activities to the level of detail necessary to permit the design process to be completed in a correct manner which permits verification that the design meets requirements. Design documents shall support facility design, construction, safe storage and handling of spent fuel, and decommissioning projects. Appropriate quality standards shall be identified and documented, and their selection reviewed and approved. Deviations from original design standards shall be reviewed to ensure that the designated quality requirements remain in the design of SSCs, as applicable.

3.6 Design control measures shall be applied to those SSCs within the scope of this DQAP. Design analyses shall be sufficiently detailed such that a person technically qualified in the subject can review and understand the analyses and verify the adequacy of the results without additional input.

Proposed Revision 0 10 of 35 TBD

NextEra Energy Duane Arnold, LLC Decommissioning Quality Assurance Program (DQAP)

3. 7 Design interfaces for SSCs within the scope of this DQAP shall be identified and controlled. Interface controls shall include the assignment of responsibility and the establishment of procedures among participating design organizations. Controls shall be established for the review, approval, release, distribution, and revision of documents involving design interfaces. Design information transmitted across interfaces shall be documented and controlled.

3.8 Changes or modifications to designated SSCs shall be approved by the Design Authority or designee. Procedures for implementing design changes and field changes shall assure that the impact of the change is considered, required actions documented, and information concerning the change transmitted to affected persons or organizations. Applicable regulatory criteria (i.e. 10 CFR 50.59, 10 CFR 50.82(a),

or 10 CFR 72.48) shall be used to determine if NRC approval is required prior to implementation of a design change. For SSCs within the scope of this DQAP, these changes shall be subject to design control measures commensurate with those applied to the original design.

3.9 Design verification for SSCs within the scope of this DQAP shall provide assurance that the final design is correct and has been performed in accordance with approved procedures describing position responsibilities and authorities for the design reviews.

Documentation to be reviewed for this design work includes the necessary calculations and/or analysis, design criteria specifications, drawings, procedures, and instructions to permit a comprehensive review.

3.10 Design verification may be accomplished through design reviews, alternate calculations, or qualification testing. These methods of design verification are defined in design procedures as applicable. The results of the design verification activities shall be documented with the identification of the verifier clearly documented. Design verification shall be performed by competent individual(s) other than those who performed the original design but may be from the same organization. This verification may be performed by the originator's supervisor, provided the supervisor did not specify a singular design approach, rule out certain design considerations, did not establish the design inputs used in the design, or the supervisor is the only individual in the organization competent to perform the verification. Cursory supervisory reviews do not satisfy the intent of design verification. Design verification shall be completed prior to relying upon the SSC to perform its important to safety function.

3.11 Nonconforming activities such as deviations, errors, or deficiencies in the approved design documents, including design methods (e.g., computer codes), shall be identified, documented, and controlled. Computer programs used to calculate or develop data for important to safety activities shall be subject to validation and verification.

3.12 Design documentation and records which provide evidence that the design and design verification process was performed in accordance with the DQAP, shall be collected, stored, and maintained in accordance with approved procedures. This documentation includes final design documents, such as drawings, specifications, calculations, and revisions there to and documentation which identifies important steps, including sources of design inputs that support the final design.

Proposed Revision 0 11 of 35 TBD

NextEra Energy Duane Arnold, LLC Decommissioning Quality Assurance Program (DQAP) 4.0 PROCUREMENT DOCUMENT CONTROL 4.1 Measures shall be established for the preparation, review, and approval of procurement documents for those items and activities within the scope of this DQAP.

Procurement documents include or reference the appropriate regulatory, technical, and quality requirements necessary to assure adequate quality for those materials, equipment, and services that are within the scope of this DQAP. Measures are established to assure that, to the extent necessary, contractors or subcontractors provide a QA Program consistent with the provisions of 10 CFR 50 Appendix B, 10 CFR 71 Subpart H, or 10 CFR 72 Subpart G, and 10 CFR 21, as applicable.

4.2 NextEra Energy maintains a controlled list of evaluated suppliers that are audited on a triennial basis. The evaluated list of such vendors, suppliers, and contractors is described in controlling procedures for the appropriate important to safety classification, except for procurement from other licensees that have an NRC approved quality program.

4.3 Procurement documents require the vendors to incorporate quality assurance program requirements in sub-tier procurement documents and allow right of access to the vendors, sub-tier vendors, and contractors facilities and records for inspection or auditby NEDA or designated representative.

4.4 Procurement document control applies to SSCs within the scope of this DQAP and any spare or replacement parts for those SSCs. Procurement documents shall include those requirements necessary to assure that the items and services to be provided meet the specified technical and quality requirements. Specifically, the procurement system assures that the appropriate technical and quality requirements are specified for procurement of items and services considering the important to safety function, complexity of the design, manufacturing, degree of inspection I testability upon receipt, and other factors which affect the quality of products and services.

4.5 Procedures that implement procurement document control shall describe the organizational responsibilities for procurement planning, preparation, review, approval and control of procurement documents; supplier selection; bid evaluation; identification of replacement parts where applicable; and review and evaluation of supplier's QA Program prior to release for bid and contract award for activities within the scope of this DQAP.

4.6 Procedures shall be established to review the adequacy of the technical and QA requirements specified within procurement documents. Personnel who have access to pertinent information and who have an adequate understanding of the requirements and intent of the procurement documents shall perform reviews required to ensure the adequacy of the technical and QA requirements. Changes to procurement documents shall be subject to the same controls as the original documents.

Proposed Revision 0 12 of 35 TBD

NextEra Energy Duane Arnold, LLC Decommissioning Quality Assurance Program (DQAP) 5.0 INSTRUCTIONS, PROCEDURES AND DRAWINGS 5.1 Measures shall be established to assure that quality activities are prescribed by and performed in accordance with documented instructions, procedures, or drawings.

Documented and approved instructions, procedures, and drawings are required to accomplish work on SSCs within the scope of this DQAP.

5.2 These instructions, procedures, and drawings include, as appropriate, quantitative or qualitative acceptance criteria for determining that activities have been satisfactorily accomplished. Procedures may include reference to vendor equipment manuals, design drawings and specifications, prerequisites, special precautions, and the delineation of work to be performed. Equipment manuals and manufacturer's instructions shall be readily available for use as appropriate.

5.3 Controls are established which ensure that instructions, procedures, and drawings are current and accurately reflect plant design and regulatory requirements.

Documents comprising of instructions, procedures, specifications, and drawings prepared by outside contractors for the performance of site activities are reviewed and approved by the responsible manager or designated representative.

Proposed Revision O 13 of 35 TBD

NextEra Energy Duane Arnold, LLC Decommissioning Quality Assurance Program (DQAP) 6.0 DOCUMENT CONTROL 6.1 Measures shall be established to control the issuance of documents, such as instructions, procedures, drawings, including changes thereto, which prescribe activities affecting quality and activities within the scope of this DQAP. These measures assure that documents, such as procedures, instructions and drawings, are reviewed for adequacy by qualified personnel other than the personnel that prepared the document, approved for release and use, and available at the location where the activity is performed. Written procedures shall define the type of documents to which the document control system applies. These procedures also define the process for controlling the preparation, review, approval, issuance, and distribution.

6.2 Documents and changes to documents that prescribe or verify activities within the scope of this DQAP shall be controlled in a manner that precludes the use of inappropriate or outdated documents. The document control system procedures shall be established to identify the current revision of instructions, procedures, specifications, drawing and procurement documents.

6.3 Changes to documents shall be reviewed and approved by the same organization that performed the original review and approval unless another qualified organization has been designated. Administrative controls shall be established that provide the methods by which temporary changes can be made to procedures which are approved, including the designation of persons authorized to approve such changes, and the time period during which they may be used. Minor changes to documents, such as inconsequential editorial corrections, shall not require that the revised documents receive the same review and approval as the original documents. To avoid a possible omission of a required review, the type of minor changes that do not require such a review and approval, and the persons who can authorize such a decision, shall be clearly delineated.

Proposed Revision 0 14 of 35 TBD

NextEra Energy Duane Arnold, LLC Decommissioning Quality Assurance Program (DQAP) 7.0 CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES 7.1 Measures shall be established for the control of purchased material, equipment, and services, to assure they conform to the procurement documents as they apply to activities within the scope of this DQAP. These measures provide for the following as appropriate: source evaluation and selection, evaluation of objective evidence of quality furnished by the supplier, source inspection, audit, and examination of items or services. Procedures shall describe each organization's responsibilities for the control of purchased material, equipment, and services, including the interfaces between all affected organizations.

7 .2 Verification that a supplier can meet the specified technical and quality requirements shall be documented. NextEra Energy maintains a controlled list of evaluated suppliers that are audited on a triennial basis. Documented supplier performance monitoring is performed in accordance with approved procedures as an acceptable alternate to the performance of the annual evaluation of suppliers. The evaluated list of such vendors, suppliers, and contractors is described in controlling procedures for the appropriate important to safety classification, except for procurement from other licensees that have an NRC approved quality program. Suppliers of commercial grade calibration services may be qualified based on their accreditation by a nationally recognized accrediting body, as an alternative to qualification by supplier audit, commercial grade survey, or in-process surveillance as described below.

7.3 This DQAP considers that other 10 CFR Parts 50 and 52 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 facility, are not required to be evaluated or audited.

7.4 Commercial grade calibration and/or testing services may be procured from domestic and international commercial calibration and/or testing 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 Cooperation (ILAC) Mutual Recognition Arrangement (MRA) provided all of the following are met:

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

• The calibration or test laboratory holds accreditation by an accrediting body recognized by the ILAC MRA.

• The accreditation encompasses ISO/IEC-17025:2005, "General Requirements for the Competence of Testing and Calibration Laboratories."

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

• 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.

Proposed Revision O 15 of 35 TBD

NextEra Energy Duane Arnold, LLC Decommissioning Quality Assurance Program (DQAP)

Control of Purchased Material, Equipment and Services (Continued) 7.4.2 The purchase documents require that:

• The service must be provided in accordance with their accredited ISO/IEC-17025:2005 (OR ANSI/ISO/I EC 17025:2017) program and scope of accreditation.

• As found calibration data must be reported in the certificate of calibration when calibrated items are found to be out-of-tolerance. (For calibration services only)

• The equipment/standards used to perform the calibration must be identified in the certificate of calibration. (For calibration services only)

• The calibration/testing laboratory to notify the DAEC of any condition that adversely impacts the laboratory's ability to maintain the scope of accreditation.

• 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.

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

• The contracted calibration or test service has been performed in accordance with their ISO/IEC-17025:2005 program, and has been performed within their scope of accreditation; and

• The purchase order's requirements are met.

7.5 The effectiveness of contractors and supplier's QA program shall be assessed at intervals consistent with the importance, complexity, and quantity of the product or service. Supplier performance and compliance with procurement documents are monitored by source verification, receipt inspection, audit, or a combination, to ensure continued acceptable supplier performance. Receiving inspection shall verify, by objective evidence, the acceptability of items in accordance with facility procedures.

Accepted items are appropriately marked and located in a controlled storage area until use. Documentary evidence shall be retained in accordance with facility requirements, and applicable regulatory requirements, and shall be sufficient to identify the specific requirements, such as codes, standards, or specifications, met by the purchased material and equipment.

7.6 For acquiring of services only, such as: third-party inspection, engineering and consulting services; auditing and installation; and repair, overhaul, or maintenance work, from suppliers whose QA Program has not been reviewed or accepted, those suppliers may be used, provided additional controls such as technical verification of data produced, surveillance and/or audit of the activity, or review of objective evidence are employed. These additional controls shall be documented in the request for services, and approved by the appropriate level of management.

Proposed Revision O 16 of 35 TBD

NextEra Energy Duane Arnold, LLC Decommissioning Quality Assurance Program (DQAP)

Control of Purchased Material, Equipment and Services (Continued)

7. 7 Spare and replacement parts are procured such that their performance and quality are at least equivalent to those of the parts that will be replaced, as determined by engineering where applicable.

7.8 Designated quality personnel, or other personnel with appropriate qualifications, are responsible for assuring source inspections, surveys, or audits of suppliers are performed as necessary. Documentation of acceptance shall be available prior to installation or acceptance for use.

Proposed Revision O 17 of 35 TBD

NextEra Energy Duane Arnold, LLC Decommissioning Quality Assurance Program (DQAP) 8.0 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS 8.1 Measures shall be established for the identification and control of material, parts, and components, including partially fabricated assemblies and consumables, to assure that only correct and accepted items are used or installed. Identification is maintained on the items or in documents traceable to the items, and physical identification shall be used to the maximum extent possible. If physical identification is either impractical or insufficient for proper control, an item is controlled by physical separation, procedural control, or other appropriate means.

8.2 Markings are applied using materials and methods that are clear, legible and do not detrimentally affect the function or service life of the items that are marked. Markings are transferred to each part of an identified item prior to being subdivided. Markings are not obliterated or masked by surface treatments or coatings unless alternative identification methods are established. When codes, standards, or specifications require specific identification or traceability requirements of an item, procedures shall describe how to maintain traceability as applicable.

8.3 Provisions are made in procedures for maintenance or replacement of markings or identification due to damage from handling or aging, excessive deterioration due to environmental exposure, and for updating records while in storage. Items having limited shelf or operating life are controlled to preclude use after the shelf life or operating life has expired.

Proposed Revision 0 18 of 35 TBD

NextEra Energy Duane Arnold, LLC Decommissioning Quality Assurance Program (DQAP) 9.0 CONTROL OF SPECIAL PROCESSES 9.1 Measures shall be established to assure that special processes that require interim process controls to assure quality, such as welding, heat treating, and nondestructive examination, are controlled. These provisions include assuring that special processes are accomplished by qualified personnel using instructions, procedures, drawings, checklists, or other appropriate means. Personnel are qualified and special processes are performed in accordance with applicable codes, standards, specifications, criteria, or other specially established requirements. Special processes are those where the results are highly dependent on the control of the process, or the skill of the operator, or both, and for which the specified quality cannot be fully and readily determined by inspection or test of the final product. Records are maintained, as appropriate, for the qualified personnel, processes, and equipment.

9.2 NEDA qualifies NOE personnel in accordance with the applicable editions of the codes and standards accepted by the NRC, as identified in fleet NOE procedures.

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NextEra Energy Duane Arnold, LLC Decommissioning Quality Assurance Program (DQAP) 10.0 INSPECTION 10.1 Measures shall be established for inspection of activities within the scope of this DQAP by or for the organization performing the activity, in order to verify conformance with approved instructions procedures, drawings, and specifications for accomplishing the task.

10.2 A comprehensive program of inspections shall be established and implemented to verify conformance of an item or activity with the specified requirements and inspection methods used and will be performed by personnel qualified to validate that the activities meet this acceptance criteria specified in applicable design documents. Inspections shall be performed by qualified individuals other than those who perform or directly supervise the activity being inspected. Inspections, examinations, or tests may be performed by individuals in the same organization as that which performed the work.

10.3 Where mandatory hold or witness points are required for witness or inspection activities by designated personnel, the designated hold points shall be indicated in appropriate documentation. Work shall not progress beyond the point of an assigned hold point unless the inspection is complete or consent to waive the hold point is given by the designated organization.

10.4 Inspections shall be planned to ensure the characteristic to be inspected and the methods used to perform the inspection and acceptance criteria are documented. If inspection of processed or fabricated items is impractical, monitoring of the processing method and equipment shall be utilized. Process monitoring shall be performed by qualified personnel or a qualified automated process. Inspection and process monitoring shall both be used if quality control is inadequate without both.

10.5 Final inspections shall include record review and examinations, measurements I tests as appropriate to verify adequate quality measures were employed in the construction, fabrication and/or processing. Final inspection results shall document the as-found condition including final acceptance/rejection criteria evaluation.

10.6 Unacceptable inspection results shall be evaluated and resolved in accordance with approved procedures. Any modifications, repairs, and replacements are re-inspected to the same standard or method to verify acceptability of the items. Inspection records shall identify the item inspected, date of inspection, inspector's identity, results of inspection, and reference to information taken in connection with nonconformances.

Proposed Revision O 20 of 35 TBD

NextEra Energy Duane Arnold, LLC Decommissioning Quality Assurance Program (DQAP) 11.0 TEST CONTROL 11.1 Measures shall be established for a documented test program in accordance with applicable Decommissioning technical specifications, license conditions, and design documents to assure that all required testing demonstrate that the structures, systems, or components within the scope of this DQAP will perform satisfactorily in service. The test program shall ensure that design and performance criteria have been satisfied and that the testing does not adversely affect the important to safety SS Cs.

11.2 The test program shall include criteria for determining when testing is required, such as proof tests prior to installation, preoperational tests, and operational tests of SSCs.

The procedures that implement testing shall specify the appropriate prerequisites for the test (e.g., personnel qualification requirements, environmental conditions, equipment requirements) sufficient instruction for the performance of the testing, hold or witness points, acceptance/rejection criteria and limits, and the required test documentation. Test results are evaluated by qualified personnel to determine compliance with established acceptance criteria. Test results which do not meet acceptance criteria shall be documented and evaluated in order to determine the appropriate corrective actions. The test program shall require that modifications, repairs, and replacement of items that have a current important to safety function be tested, utilizing the same criteria as the original items to the extent applicable to the current important to safety function. If alternative tests are required, the alternative tests must be reviewed and approved by the same organization that established the original requirements unless the applicable manager designates another responsible organization. Test records shall be maintained in accordance with approved procedures.

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NextEra Energy Duane Arnold, LLC Decommissioning Quality Assurance Program (DQAP) 12.0 CONTROL OF MEASURING AND TEST EQUIPMENT 12.1 Measures shall be established to assure those tools, gauges, instruments, and other measuring and test equipment (M& TE), used for activities within the scope of this DQAP, are controlled, calibrated and adjusted in order to maintain accuracy within necessary limits and to ensure its traceability to calibration test data. Measures shall also be established for the control of permanently installed instrument and control devices that are within the scope of this DQAP.

12.2 Organizational responsibilities shall be delineated for establishing, implementing, and assuring the effectiveness of the calibration program for M&TE. Reference standards used to determine the acceptability of items and activities shall be of appropriate type, and maintained within prescribed accuracy limits, suitable ranges, and accuracies, in order to verify conformance to specified requirements.

12.4 Procedures for the control and calibration of permanently installed plant equipment that are within the scope of this DQAP shall specify identification requirements (labeling, codes, or other documented control system), the recall process and calibration process and frequencies (including documented pre-calibration checks) of the M&TE to nationally recognized standards. Calibration methods are documented and performed by competent personnel in an environment that does not adversely affect the calibration. The calibration procedures shall specify recording of as-found conditions and a means for determining which equipment shall be included in the calibration program. M&TE used in the calibration of permanently installed plant equipment shall have ranges, precision, and accuracy equal to or greater than that to be calibrated and where this is impractical; the cognizant authority shall document rationale for accuracy.

12.5 The calibration procedures shall delineate special controls where applicable, for usage, handling, and storage required for environmental conditions such as temperature, humidity, cleanliness, or radiation, in order to maintain accuracy and operating characteristics of the M&TE.

12.6 Calibration reference standards shall be based on nationally recognized standards or accepted values of natural physical constants. Where national standards do not exist, the basis for the calibration shall be documented. Special calibration and control measures are not required when normal commercial practices provide adequate accuracy (e.g. rulers, tape measures, levels, and other such devices).

12. 7 M&TE which is found to be damaged, out-of-calibration or for which accuracy is suspect, shall be tagged and segregated and processed in accordance with approved procedures. When M& TE is found to be out-of-tolerance, an evaluation is made of its previous uses to determine corrective action.

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NextEra Energy Duane Arnold, LLC Decommissioning Quality Assurance Program (DQAP) 13.0 HANDLING, STORAGE, AND SHIPPING 13.1 Measures shall be established to control the handling, storage, shipping, packaging, cleaning and preservation of items, material and equipment within the scope of this DQAP, in accordance with applicable design, work, and procurement requirements in order to prevent damage or deterioration during handling, packaging, preservation, storage, and shipping.

13.2 Special coverings, equipment and protective environments shall be specified and provided where necessary for the protection of items, material, and equipment from damage and deterioration. Special protective measures are specified and provided when required to maintain acceptable quality. When special protective features are required, their existence shall be verified and monitored as necessary to assure that the special protective features continue to serve its intended function. Special handling tools and equipment shall be provided, where necessary, to ensure items, material and equipment can be handled safely and without damage.

13.3 Controls for hoisting, rigging, and transporting shall be established to protect SSCs within the scope of this DQAP as applicable. Markings or labeling shall be used to indicate the presence of special environments, or the need for special controls.

Provisions shall be described for the storage of chemicals, reagents (including control of shelf life), lubricants and other combustible materials. Cleanliness controls shall be implemented to protect applicable SSCs from the introduction of foreign material and maintain system cleanliness as applicable throughout maintenance and modification activities.

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NextEra Energy Duane Arnold, LLC Decommissioning Quality Assurance Program (DQAP) 14.0 INSPECTION, TEST, AND OPERATING STATUS 14.1 Measures shall be established for indicating the status of items within the scope of this DQAP undergoing inspections and tests to prevent the inadvertent bypassing or altering the sequence of such inspections or tests and avoid inadvertent operation.

Where necessary to preclude inadvertent bypassing of inspections or tests, or to preclude inadvertent operation, these measures require the inspection, test, or operating status be verified before release, fabrication, receipt, installation, test or use. These measures also establish the necessary authorities and controls for the application and removal of status indicators or labels. The methods used to indicate inspection, test and operating status, including control of these indicators, are prescribed by approved procedures and shall be readily apparent and verifiable.

14.2 In addition, temporary design changes (temporary modifications), such as temporary bypass lines, electrical jumpers and lifted wires, and temporary trip-point settings, are controlled by procedures that include requirements for appropriate installation and removal, independent/concurrent verifications where necessary, and status tracking.

14.3 Deviations from the required sequence shall be subject to the same level of control as the generation of the original sequence to prevent the bypassing or omission of required test or inspection. The operating status of nonconforming, inoperable or malfunctioning SSCs shall be identified and documented to prevent inadvertent operation.

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NextEra Energy Duane Arnold, LLC Decommissioning Quality Assurance Program (DQAP) 15.0 NONCONFORMING MATERIAL, PARTS, OR COMPONENTS 15.1 Measures shall be established for the identification, evaluation, segregation when practical, disposition of nonconforming items, and for notification to affected organizations. Items (including applicable services) that do not conform to specified requirements shall be controlled to prevent inadvertent installation or use.

15.2 Measures shall require that the individual (or designee), discovering a nonconformance, identify, describe, and document the nonconformance in accordance with the requirements of the corrective action program. Actions taken to address nonconforming items shall be documented. Controls are provided to address conditional release of nonconforming items for use on an at-risk basis prior to resolution and disposition of the nonconformance, including maintaining identification of the item and documenting the basis for such release. Conditional release of nonconforming items for installation requires the approval of the designated management. Nonconformances are corrected or resolved prior to depending on the item to perform its intended important to safety function. Nonconformances to design requirements dispositioned as repair or use as-is are subject to design control measures commensurate with those applied to the original design. Significant trends in nonconformances are reported to management in accordance with applicable procedures, regulatory requirements, and industry standards.

15.3 Nonconforming items that are being used for training must be controlled (e.g.,

administratively controlled, permanently identified, marked, obliterate Material ID Tag or Q level indicators) to prevent inadvertent or inappropriate use of the item.

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NextEra Energy Duane Arnold, LLC Decommissioning Quality Assurance Program (DQAP) 16.0 CORRECTIVE ACTION 16.1 Measures shall be established to promptly identify, control, document, classify, and correct conditions adverse to quality. Procedures assure that corrective actions are documented and initiated following the determination of conditions adverse to quality in accordance with regulatory requirements and applicable quality standards.

Procedures require personnel to identify known conditions adverse to quality. When a complex issue arises where it cannot be readily determined if a condition adverse to quality exists, measures shall be established for documentation and timely evaluation of the issue. Significant conditions adverse to quality are documented and reported to responsible management. In the case of a significant condition adverse to quality, the cause is determined and actions to preclude recurrence are taken and followed up on to verify implementation.

16.2 In case of suppliers performing activities within the scope of this DQAP, or other similar situations, the applicable manager may delegate specific responsibilities for corrective actions but maintains responsibility for the effectiveness of corrective action measures.

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NextEra Energy Duane Arnold, LLC Decommissioning Quality Assurance Program (DQAP) 17.0 QUALITY ASSURANCE RECORDS 17 .1 Measures shall be established which define the requirements and responsibilities for identification, generation, collection, compilation, storage, maintenance, retention, and retrieval of records necessary to provide objective evidence that activities within the scope of this DQAP are in compliance with the regulations and facility implementing procedures.

17.2 Distribution of records shall be controlled in accordance with written procedures.

Measures are established for replacement, restoration, or substitution of lost or damaged records. A system for receipt control of records is established. Receipt control is required for records transferred between NEDA locations, vendors and the NEDA, and from NEDA department files to final storage locations.

17 .3 Records are legible, accurate, complete, identifiable, and retrievable. Records are considered valid and complete when dated and stamped, initialed, signed, or otherwise authenticated. Corrections, revisions, or supplements to completed records are reviewed and approved by an authorized individual in the originating organization.

Such changes are dated and stamped, initialed, signed, or otherwise authenticated including the use of electronic approval and authorization as applicable.

17.4 Record storage facilities are established and maintained in a manner that minimizes the risk of damage or destruction. Records may be kept by suppliers and maintained on an available basis for a specified period of time. Records may be stored in electronic media provided that the process for managing and storing data is documented in procedures that comply with applicable regulations, including NRC guidance in RIS 2000-18 and as recognized in NIRMA (Nuclear Information Records Management Association) technical guides TG-11, TG-15, TG-16, and TG-21 as approved in NRC SERs.

17.5 Record retention periods are established to meet regulatory, DSAR, DQAP, and License requirements. The most stringent retention period is implemented when multiple requirements exist. Records are dispositioned at the end of the prescribed retention period.

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NextEra Energy Duane Arnold, LLC Decommissioning Quality Assurance Program (DQAP) 18.0 AUDITS 18.1 Measures shall be established for a system of planned and documented audits to verify compliance with all aspects of the DQAP and determine the effective implementation of programs covered by the DQAP. Internal and supplier audits are conducted in accordance with written procedures or checklists. Audit personnel shall not have direct responsibilities in the areas to be audited.

18.2 The internal audit program is conducted on a performance driven frequency that is commensurate with the status and importance of the activity to be completed but does not exceed 36 months, unless otherwise required by regulation. An evaluation will be performed once per calendar year to determine the need for additional audit activities. When determined necessary, an additional audit activity will be performed within a timeframe established by the evaluation. Audits may be extended beyond their originally scheduled due date based on the following criteria:

A. Audits shall be performed at the intervals designated and the schedules are based on the month in which the audit starts.

B. A maximum extension not to exceed 25 percent of the audit interval is allowed unless restricted by regulation.

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

D. Item B applies to supplier audits and evaluations except that a total combined interval for any three (3) consecutive inspection or audit intervals does not exceed 3.25 times the specified inspection or audit interval.

Emergency Planning, Access Authorization, Security, Fire Protection and Independent Spent Fuel Storage are audited in accordance with site procedures and at frequencies established by related NRC rules. A grace period shall not be applied to these regulatory topics unless permitted by the NRC Rule.

18.3 Audit scheduling, preparation, personnel selection, personnel qualification, performance, reporting, response, follow-up, and records management for audits are performed in accordance with written procedures. Audit scopes and schedules are based upon the status of work progress, activities being performed, regulatory requirements, and/or experience with the organization being audited. An audit schedule shall be maintained, reviewed, and revised as necessary at least annually, to ensure that programs receive necessary audits to support regulatory compliance.

18.4 External audits of suppliers providing materials, parts, equipment or services within the scope of this DQAP are scheduled and performed based on the importance of the activity and to confirm implementation of the supplier's Quality Assurance Program at a frequency of not less than three (3) years with an audit extension period identified in D above.

18.5 Audit reports shall be prepared, reviewed, approved and distributed in accordance with approved procedures.

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NextEra Energy Duane Arnold, LLC Decommissioning Quality Assurance Program (DQAP)

APPENDIX A TERMS AND DEFINITIONS A.1. Important to safety (for this DQAP)

Structures, systems, and components (SSCs) whose functions are to protect spent fuel and/or the capability to prevent or mitigate the consequences of accidents that could result in potential for offsite exposure comparable to the guidelines in 10 CFR 50.34(a)(1 ), 10 CFR 50.67(b)(2) or 10 CFR 100.11, as applicable. These SSCs are typically listed in site specific DSARs or ISFSI design documents. Refer to NUREG/CR-6407, "Classification of Transportation Packaging and Dry Spent Fuel Storage System Components According to Importance to Safety," for application of this term to transportation packaging and dry fuel storage systems for compliance with 10 CFR 71 and 10 CFR 72.

A.2. For other terms and definitions refer to the applicable standard or guidance such as:

• 10 CFR 50.2, Definitions

• 10 CFR 71.4, Definitions

• 10 CFR 72.3, Definitions Proposed Revision O 29 of 35 TBD

NextEra Energy Duane Arnold, LLC Decommissioning Quality Assurance Program (DQAP)

APPENDIX B WRITING REFERENCE DOCUMENTS B.1. Quality Standards and Regulatory Guidance

• Regulatory Guide 7 .10, Establishing Quality Assurance Programs for Packaging Used in the Transportation of Radioactive Materials (Revision 2-March 2005).

• NUREG-1757, Consolidated Decommissioning Guidance, Volume 1, Revision 2 B.2. Safety Evaluation Reports

• Revision 1, U.S. NRC, Safety Evaluation by the Office of Nuclear Reactor Regulation quality assurance independent review program alternative, Duane Arnold Energy Center, Kewaunee Nuclear Power Plant, Monticello Nuclear Plant, Palisades Nuclear Plant, Point Beach Nuclear Plant, Units 1 and 2, Docket Nos. 50-331, 50-305, 50-263, 50-255, 50-266, 50-301, 50-282, and 50-306, dated January 13, 2005, ADAMS Accession No. ML050210276 Proposed Revision O 30 of 35 TBD

NextEra Energy Duane Arnold, LLC Decommissioning Quality Assurance Program (DQAP)

APPENDIX C REGULATORY COMMITMENTS C.1. 10 CFR 50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Processing Plants C.2. 10 CFR 71 Subpart H, Quality Assurance for Packaging and Transportation of Radioactive Material C.3. 10 CFR 72, Subpart G, Quality Assurance for Licensing Requirements for the Independent Storage of Spent Nuclear Fuel and High-Level Radioactive Waste C.4. NUREG/CR-6407, Classification of Transportation Packaging and Ory Fuel Storage System Components According to Important to Safety (211996)

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NextEra Energy Duane Arnold, LLC Decommissioning Quality Assurance Program (DQAP)

APPENDIX D GENERAL ADMINISTRATIVE REQUIREMENTS D.1. Fire Protection 10 CFR 50.48(f) requires that licensees that have submitted the certification required under 50.82(a)(1) shall maintain a fire protection program to address the potential for fires that could cause the release or spread of radioactive materials. The quality assurance program established for these fire protection SSCs ensures that design, procurement, instruction, procedures, drawings, inspection, installation, testing, maintenance, operations, nonconforming items, corrective action, records, audits and administrative controls meet the applicable quality assurance guidelines as described in CMEB 9.5-1, Revision 2, Position C.4, "Quality Assurance Program," during decommissioning and permanent shutdown. Engineering determines what fire protection SSCs are required to prevent fires, rapidly detect, control, and extinguish fires that do occur and could result in a radiological hazard and, minimize the risk the public, environment, and plant personnel resulting from fires that could result in a release of radioactive materials. Engineering also establishes the requirements for the design, procurement, fabrication, installation and/or modification of these fire protection SSCs. All other fire protection equipment and supplies will be of commercial quality, in accordance with National Fire Protection Association (NFPA) guidelines.

D.2. Transport of Radioactive Waste When NEDA contracts with vendors to transport radioactive waste in NRC approved shipping packages, it meets the requirements of 10 CFR 71, Subpart H. NEDA assures that this service is procured from an organization with a QA program and if applicable, includes an NRC licensed transport system. Loading, surveying, closure, placarding, and inspections are conducted in accordance with written procedures and instructions.

Transport casks and trailers are inspected before release in accordance with Department of Transportation (DOT) 49 CFR. Shipping manifests, including final radiation surveys, are completed and retained. Radioactive waste shipments not meeting the requirements for NRC approved packaging, shall meet the requirements of DOT 49 CFR.

D.3. Services NEDA procures services from qualified suppliers. It is not necessary that these suppliers have a quality assurance program approved by the licensee, however, suppliers should provide a quality assurance program that includes the quality assurance program elements presented in Regulatory Guide 4.15, "Quality Assurance for Radiological Monitoring Programs (Normal Operations) - Effluent Streams and the Environment," and routinely provide program data summaries sufficiently detailed to permit evaluation of the program for the following areas:

• Meteorology

• Offsite Dose Assessment Manual

• Radiological environmental monitoring Proposed Revision 0 32 of 35 TBD

NextEra Energy Duane Arnold, LLC Decommissioning Quality Assurance Program (DQAP)

D.4. License Renewal Consistent with the requirements of 10 CFR 54.21 (a)(3), NEDA implements the requirements of DQAP Section 1 through 18 for aging management activities related to safety-related SSCs as described by licensing documents for those systems that remain active.

Additionally, to manage the aging effects of non-safety-related SSCs that were determined to be within the scope of License Renewal, NEDA implements the administrative controls, corrective actions and confirmation processes described in DQAP Sections 6, 16, and the applicable requirements of this appendix.

D.5. Safety Review Group The Safety Review Group (SRG) is responsible to the Decommissioning Director as an on-site review body that performs procedure and program reviews for decommissioning activities and ISFSI operation as necessary on matters of Nuclear Safety. Details regarding the membership, quorum, agenda, and meeting schedule are contained in implementing procedures.

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APPENDIX E SITE SPECIFIC ADMINISTRATIVE REQUIREMENTS E.1. Regulatory Guide 1.33 Written procedures shall be established, implemented, and maintained for the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978.

E.2. Independent Spent Fuel Storage Installation (ISFSI) SSC ISFSI quality assurance program requirements are performed in accordance with the applicable 10 CFR 72.212 report which invokes the portions of the NRC approved 10 CFR 50 Appendix B quality assurance program as described in this DQAP, commensurate with the safety classification of the component and quality requirements specified in the cask vendor Final Safety Analysis Report (FSAR) or site-specific license.

E.3. Records Retention The following records shall be retained for at least five years:

• Records and logs of activities related to the safe storage of irradiated fuel.

• Records and logs of principle maintenance activities, inspections, repair and replacement of principal items of equipment related to safe storage of irradiated fuel.

• All Licensee Event Reports.

• Records of surveillance activities, inspections and calibrations required by technical specifications.

• Records of changes made to the procedures required by technical specification.

• Records of sealed source leak tests and results.

• Records of annual physical inventory of all source material of record.

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The following records shall be retained for the duration of the Facility License:

• Records and drawing changes reflecting facility design modification made to systems and equipment needed for the safe storage of irradiated fuel as described in the Defueled Safety Analysis Report.

• Records of irradiated fuel inventory, fuel transfers and assembly burnup histories.

• Records of facility radiation and contamination surveys.

• Records of doses received by all individuals for whom monitoring was required.

• Records of gaseous and liquid radiative material released to the environs.

• Records of training and qualification for current members of the facility staff.

• Records of reviews performed for changes made to procedures or equipment or reviews of tests and experiments pursuant to 10 CFR 50.59.

• Records of results of analyses required by the Radiological Environmental Monitoring Program.

• Records of reviews performed for changes made to the Defueled Offsite Dose Assessment Manual and Process Control Plan.

• Records of radioactive shipments.

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Enclosure 2 to NG-21-0028 NextEra Duane Arnold, LLC Quality Assurance Topical Report Change Summary 1O pages follow

INITIAL ISSUE CHANGE REQUEST I TABLE OF CHANGES 10 CFR 50.54(a) Evaluation Purpose The purpose of this 10 CFR 50.54(a) Evaluation is to assess the changes being proposed associated with transitioning the NextEra Energy Duane Arnold, LLC (NEDA) Quality Assurance Topical Report (QATR) (FPL-3), to a new NEDA Decommissioning Quality Assurance Program (DQAP).

Discussion The NEDA QATR (FPL-3) Revision 1 was issued on December 3, 2020 to the NRC. This revision changes the title to "NextEra Energy Duane Arnold, LLC Decommissioning Quality Assurance Program" (NEDA DQAP). This DQAP has changes representing a decrease in commitments that will require NRC prior approval. Revising the QATR to the DQAP simplifies the document commensurate with a decommissioning facility with all fuel in dry storage. This 50.54(a) evaluation is performed for the purposes of determining if any of the changes associated with transitioning the DAEC to the new DQAP require prior NRC approval pursuant to the requirements of 10 CFR 50.54(a)(3).

The primary focus of the change is to reflect the decommissioning status of Duane Arnold facility after all fuel is removed from the fuel pool and placed in the on-site dry storage facility.

The intent of the DQAP is to describe appropriate and sufficient requirements to establish how the Quality Assurance Program meets 10 CFR 50 Appendix B while allowing flexibility in the manner by which a requirement is met.

Several of the proposed changes (organizational, administrative, editorial and clarification) associated with transitioning the current NEDA QATR to this DQAP can be made without prior NRC approval, based on the guidance provided within 10 CFR 50.54(a)(3).

However, implementing the DQAP results in two (2) changes that represent a reduction in commitment for NEDA, requiring NRC approval prior to implementation. These changes are as follows:

1. Removal of commitment to NQA-1.

2. Moving the Quality Assurance Manager function from a site position to corporate.

The evaluation of these changes and the conclusion is presented in the attached table on a section by section basis. A copy the proposed new NEDA DQAP is provided in Enclosure 1 of NG-21-0028.

Page 1 of 10

INITIAL ISSUE CHANGE REQUEST I TABLE OF CHANGES 10 CFR 50.54(a) Evaluation Conclusion The 10 CFR 50.54(a) evaluation concluded that several of the changes associated with transitioning the current NEDA QATR to this DQAP (organizational, administrative, editorial and clarification) can be made without prior NRC approval, based on the guidance provided within 10 CFR 50.54(a)(3).

However, there are two (2) changes that are considered a reduction in commitment to the previously approved NEDA QATR that cannot be implemented without prior NRC approval:

1. Removal of commitment to NQA-1.

2. Moving the Quality Assurance Manager function from a site position to corporate.

Transitioning NEDA's QATR to this new DQAP cannot be implemented without prior NRC approval in accordance with 10 CFR 50.54(a). The specific discussion for each of the proposed changes for each of the sections and the associated evaluation is included in the attached table.

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Table of Changes and the Associated Evaluation NEDA DQAP Initial Issue Change Request -10 CFR 50.54(a) Evaluation DQAP Change(s) Evaluation and Justification Prior NRC Section Approval General Editorial Changes (All Sections)

Extensive editorial changes to eliminate redundancy, provide clarity, These types of changes are editorial and do not alter the No and improve readability were made. Examples include: intent or purpose of the DQAP. The DQAP satisfies the criteria of 10 CFR 50, Appendix B, 10 CFR 71, Subpart

• The scope statements at the beginning of the section were H and 10 CFR 72, Subpart G. This change can be eliminated. This was done to remove redundant information that is implemented without prior NRC approval, based on the contained in the section. guidance provided in 10 CFR 50.54(a)(3).

• Reduced the use of bulleted lists and converted multiple single sentence paragraphs into more descriptive paragraphs; thus improving the overall readability.

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Table of Changes and the Associated Evaluation NEDA DQAP Initial Issue Change Request -10 CFR 50.54(a) Evaluation DQAP Change(s) Evaluation and Justification Prior NRC Approval Section Changes (All Sections)

Commensurate with the status of decommissioning at Implementation methodology details found in the QATR Yes. 50.54(a)(4)

DAEC, a complete rewrite was performed. The NEDA are not included in the DQAP. The intent of the DQAP is The reduction in the details Quality Assurance Topical Report (QATR)(FPL-3) is to describe appropriate and sufficient requirements to regarding implementation being changed to the NEDA Decommissioning Quality establish how the DQAP meets 10 CFR 50 Appendix B methodology and changing the Assurance Program (DQAP) to reduce detail and while allowing flexibility in how a requirement is met. This previous commitment to NQA-1 improve readability. NEDA is also changing its reduction in implementation detail provides flexibility of the is considered a reduction in commitment to NQA-1. implementation of the DQAP while maintaining commitment and will need to be appropriate and sufficient guidance to ensure QA program reviewed and approved by the The current level of detail is unnecessary to satisfy 10 requirements are met. NRC. The proposed revision CFR 50, Appendix B and the information can be continues to satisfy the criteria captured in implementing procedures. NEDA is changing our commitment to NQA-1. The of 10 CFR 50, Appendix B; 10 references and commitments to NQA-1 have been CFR 71, Subpart H and 10 CFR All Sections of the DQAP are affected by the rewrite removed. 72, Subpart G.

described and evaluated here. Additional changes falling outside this description are listed below.

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Table of Changes and the Associated Evaluation NEDA DQAP Initial Issue Change Request-10 CFR 50.54(a) Evaluation DQAP Change(s) Evaluation and Justification Prior NRC Approval Section Cover Page The title of the new NextEra Energy, Duane Arnold, These changes to the Cover Page are minor No LLC Quality Assurance Topical Report will be "NextEra administrative changes, which are considered editorial Energy Duane Arnold, LLC Decommissioning Quality and do not constitute a reduction in commitments to the Assurance Program (DQAP)". previously approved QATR (FPL-3) Revision 1. This change can be implemented without prior NRC approval, based on the guidance provided in 10 CFR 50.54(a)(3).

Policy Statement The policy statement was changed to a focus on The purpose and intent of the policy statement remains No decommissioning versus an operational focus. the same. The changes are considered editorial and do not reduce the effectiveness or commitments to the technical requirements of the DQAP or regulatory and industry standards. This change can be implemented without prior NRC approval, based on the guidance provided in 10 CFR 50.54(a)(3).

Table of Contents The table of contents was streamlined to reflect the Changes to the table of contents are considered editorial No reduction in detail within the sections of the DQAP. changes that do not reduce the effectiveness or commitments to the technical requirements of the DQAP or regulatory and industry standards. This change can be implemented without prior NRC approval, based on the guidance provided in 10 CFR 50.54(a)(3).

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Table of Changes and the Associated Evaluation Duane Arnold DQAP Initial Issue Change Request - 10 CFR 50.54(a) Evaluation DQAP Change(s) Evaluation and Justification Prior NRC Approval Section Section 1.0 Organization 1.0 Organization - This is a complete rewrite Changes to the organizational responsibilities other than Yes. 50.54(a)(4) since the previously approved QATR the Nuclear Assurance Manager are considered Moving the site Nuclear (FPL-3) Revision 1. Site organization has administrative and do not impact the reporting Assurance Manager changed to reflect the plant relationships with the Chief Nuclear Officer (CNO). The responsibilities to corporate decommissioning status with all fuel executive management position and the quality assurance is a reduction in transferred to the ISFSI facility. Several organization (through the nuclear oversight executive) commitment. The proposed changes were made by streamlining continue to report to the CNO. revision is acceptable organizational functions to accommodate because it continues to changing and consolidating The Nuclear Assurance Manager responsibilities are satisfy the criteria of 10 CFR responsibilities. being moved to corporate. After all fuel has been 50, Appendix B; 10 CFR 71, transferred to dry storage, activities at the site that would Subpart H and 10 CFR 72, The Nuclear Assurance Manager (QA fall under the requirements of the QAPM will be Subpart G.

Manager) function has been removed from infrequent. The decrease in these types of activities will no the site organization and now resides at longer necessitate the continuous on-site presence of the corporate organization. Nuclear Assurance. The corporate Nuclear Assurance organization will be able to provide the necessary oversight of the site's quality assurance proqram.

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Table of Changes and the Associated Evaluation Duane Arnold DQAP Initial Issue Change Request - 10 CFR 50.54(a) Evaluation DQAP Change(s) Evaluation and Justification Prior NRC Approval Section Section 2.0 Quality Assurance Program 2.0 Quality Assurance Program - All NEDA is changing our commitment to NQA-1. Yes. 50.54(a)(4) references to NQA-1 commitment have This reduction in been removed throughout the DQAP. The requirements for independent review functions were commitment is acceptable based on ANSI N18.7-1976 as endorsed by Regulatory because the proposed Periodic independent reviews involving the Guide 1.33, Revision 2. These functions as described in revision continues to satisfy safe operations of the nuclear power plant the QATR follow the guidance provided in ANSI N18.7- the criteria of 10 CFR 50, is removed from the decommissioning 1976, Section 4.3.1. However, ANSI N 18. 7-1976 states: Appendix B, 10 CFR 71, quality assurance plan. 18.7 is applicable during the "operational phase," which is Subpart H and 10 CFR 72, defined within the standard as "That period of time during Subpart G.

which the principal activity is associated with normal operation of the plant. This phase of plant life is considered to begin with commencement of fuel loading and ends with plant decommissioning." The detailed ANSI N18.7-1976 requirements for Nuclear Oversight Board (NOB), Onsite Review Committee (OSRC) and Independent Technical Review (ITR) activities apply to power plants in the operational phase. Sites under this DQAP are no longer in the operational phase, it is concluded that detailed requirement for independent review per ANSI N18.7-1976 need not be applied to the DQAP.

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Table of Changes and the Associated Evaluation Duane Arnold DQAP Initial Issue Change Request -10 CFR 50.54(a) Evaluation DQAP Change(s) Evaluation and Justification Prior NRC Approval Section Section 18.0 Audits 18.2 Audits - Internal audit frequency has been The proposed change does not represent a reduction in No changed from 24 months to 36 months effectiveness or compliance with 10 CFR 50 Appendix B, and an annual evaluation has been added. "Quality Assurance Criteria for Nuclear Power Plants." A comprehensive system of planned and periodic audits will continue to be performed by independent trained personnel using written procedures to verify compliance with all aspects of the QAP. The internal audit program will continue to be conducted on a performance driven frequency that is commensurate with the status and importance of the activity to be completed. Performance of functional area and vendor audits will continue to determine effectiveness of the program.

The proposed frequency change supplemented by evaluation is similar to audit requirements outlined in ASME NQA-1-2015, "Quality Assurance for Nuclear Facility Applications," that was endorsed by Regulatory Guide 1.28, "Quality Assurance Program Criteria (Design and Construction)," Revision 5. This revision of NQA-1, Requirement 18, "Audits," Section 201 .2, "Nuclear Facilities After Placing the Facility into Operation,"

references extending the 2-year internal audit interval to 3 years, not to exceed 4 years with performance of an annual evaluation. Also, the proposed changes are similar to ANSI/ANS 3.2-2012, "Managerial, Administrative and Quality Assurance Controls for the Operational Phase of Nuclear Power Plants," that was endorsed by Regulatory Guide 1.33, "Quality Assurance Program Requirements (Operation)," Revision 3. This quality standard also, Page 8of10

provides guidance in section 3.18.1.1, "Regularly Scheduled Audits," for extending the 2-year frequency not to exceed 4 years with performance of an annual evaluation. In addition, the proposed 36-month audit frequency is consistent with external audit requirements for audit of suppliers and with NRC triennial inspections.

It should be noted that NEDA is not adopting NQA-1-2015 or ANSI/ANS 3.2-2012 as part of this proposed change but is only citing those standards to show that the proposed frequencies are similar to other NRC endorsed standards. The variations between the proposed changes and NRC endorsed quality standards include setting the audit frequency to 36 months with 25% grace versus the 2-year frequency with a 1-year extension(s) not to exceed 4 years described in NQA-1-2015 and ANSI/ANS 3.2-2012 standards. The proposed evaluation will focus on identifying areas that require audit activity prior to the next scheduled audit, rather than justifying extension.

Functional area audits and evaluations would be separated into three cycles covering a period of 36 months. Each cycle includes a set of audits and evaluations. Results of the completed audits will be reviewed to determine if additional audit activities are necessary prior to their next scheduled performance. Each functional audit area will receive an additional performance analysis (evaluation) within 2 years of the last performed audit based on internal and external data; functional area changes in responsibility, resources, or management; and consideration of the impacts, as applicable, to determine if additional audit activities are necessary prior to the 36-month scheduled performance.

These evaluations will meet the intent of the annual evaluation described in NRC endorsed quality standards by ensuring action by the audit organization upon evaluation of adverse performance trends should they exist prior to the next scheduled audit activity. The resulting action will be based on the problem identified and may include one or more of a variety of audit tools, Page 9of10

such as simple observations, follow-up reviews, limited scope audits up to a full audit of the functional area.

In aggregate, these changes will continue to meet the fundamental requirements of an internal audit program as described in quality standards endorsed by the NRC and will continue to provide proper coverage of QAP activities.

The changes will allow audits to be scheduled at a frequency commensurate with the status and importance of the activity. Evaluations of performance will be used to effectively focus audit resources in areas indicating gaps in QAP implementation.

Precedent Exelon Generating Company ML20287A130 11 /5/2020.

References

1. ANSI N 18. 7-1972, "Administrative Controls for Nuclear Power Plants"

2. ANSI N18.7-1976/ANS 3.2, "Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants (Limerick, Fitzpatrick, Clinton)"

3. ANSI/ANS 3.2-1988, "Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants (Braidwood, Byron, Dresden, LaSalle and Quad Cities)"

4. Regulatory Guide 1.189, "Fire Protection for Nuclear Power Plants"

5. NQA-1-1994, "Quality Assurance Program Requirement for Nuclear Facilities" Based on the above, the change described does not result in a reduction of any QA Program commitment due to the use of a QA Standard approved by the NRC which is more recent than the QA standard in NEDA's current QA proqram at the time of the chanqe.

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