Text

Supplement to Request for Approval of the Tennessee Valley Authority Nuclear Quality Assurance Program Description
	ML24268A322
Person / Time
Site:	Browns Ferry, Watts Bar, Sequoyah, 99902056
Issue date:	09/24/2024
From:	Hulvey K; Tennessee Valley Authority
To:	; Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk
References
	CNL-24-060 TVA-NQA-PLN89-A, Rev 43
	Download: ML24268A322 (1)
	v • d • e

10 CFR 50.54(a) 10 CFR 72.140 1101 Market Street, Chattanooga, Tennessee 37402 CNL-24-060 September 4, 2024 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-001 Browns Ferry Nuclear Plant, Units 1, 2, and 3 Renewed Facility Operating License Nos. DPR-33, DPR-52, and DPR-68 NRC Docket Nos. 50-259, 50-260, and 50-296, and 72-052 Clinch River Nuclear Site Early Site Permit No. ESP-006 Docket No. 99902056 Sequoyah Nuclear Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-77 and DPR-79 NRC Docket Nos. 50-327 and 50-328, and 72-034 Watts Bar Nuclear Plant, Units 1 and 2 Facility Operating License Nos. NPF-90 and NPF-96 NRC Docket Nos. 50-390 and 50-391, and 72-1048

Subject:

Supplement to Request for Approval of the Tennessee Valley Authority Nuclear Quality Assurance Program Description

Reference:

1. TVA letter to NRC, CNL-24-020, Request for Approval of the Tennessee Valley Authority Nuclear Quality Assurance Program Description and Application to Revise the Technical Specifications Associated with QAPD Requirements (BFN-TS-551, SQN-TS-23-05, and WBN-TS-23-21),

dated April 1, 2024 (ML24093A047) 2.

NRC letter to TVA, Summary of July 10, 2024, Meeting With Tennessee Valley Authority Regarding A Proposed Change to the Tennessee Valley Authority Nuclear Quality Assurance Plan (EPID L-2024-LLQ-0000),

dated August 19, 2024 (ML24221A013) 3.

TVA letter to NRC, NNP-24-001, Approved -A Version of the Quality Assurance Program Description for Tennessee Valley Authority (TVA)

New Nuclear, Revision 2, dated February 5, 2024 (ML24037A144) 4.

NRC letter to TVA, Final Safety Evaluation for Tennessee Valley Authority Topical Report, NNP-TR-001-NP Quality Assurance Program Description for TVA New Nuclear, Revision 2 (Docket No. 9990256),

dated December 12, 2023 (ML23254A050)

U.S. Nuclear Regulatory Commission CNL-24-060 Page 2 September 4, 2024 In Reference 1, Tennessee Valley Authority (TVA) submitted a revision to the TVA Nuclear Quality Assurance Program Description (QAPD) and an application to Revise the Technical Specifications (TS) for the Renewed Facility Operating License Nos. DPR-33, DPR-52, and DPR-68 for the Browns Ferry Nuclear Plant (BFN), Units 1, 2, and 3; Renewed Facility Operating License Nos. DPR-77 and DPR-79 for the Sequoyah Nuclear Plant (SQN),

Units 1 and 2; and Facility Operating License Nos. NPF-90 and NPF-96 for the Watts Bar Nuclear Plant (WBN), Units 1 and 2, respectively. The proposed QAPD for the TVA Nuclear Quality Assurance Plan (NQAP) converts the TVA QAPD for the current operating fleet from American National Standards Institute (ANSI) N45.2-1971, Quality Assurance Program Requirements for Nuclear Power Plants, and ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants, to American Society of Mechanical Engineering (ASME) NQA-1-2015, Quality Assurance Requirements for Nuclear Facility Applications.

As noted in Reference 2, on July 10, 2024, the Nuclear Regulatory Commission (NRC) held a public meeting with TVA regarding Reference 1. As noted in Reference 2, TVA stated that it will submit a supplement to the TVA Fleet QAPD request that will address the timing aspects of which QAPD would be governing New Nuclear Program and New Nuclear Project activities. Another public meeting between the NRC and TVA was conducted on August 19, 2024. The clarifications that TVA provided during these public meetings have been incorporated within the revised Enclosure 1 to Reference 1 as summarized below.

This supplement provides an update to Enclosure 1 of Reference 1 in its entirety, and changes are denoted by revision bars. The changes made in this supplement are as follows. Attachment 1-Proposed Quality Assurance Program Description for TVA NQAP changes include the following.

x Revised Fleet QAPD, which clarifies the scope and applicability of the Fleet QAPD for TVAs New Nuclear Projects and Programs as it relates to the QAPD for TVA New Nuclear (New Nuclear QAPD) (Reference 3) that was approved by the NRC in Reference 4.

x Clarified that the Fleet QAPD applies to the Clinch River Nuclear (CRN) Small Modular Reactor (SMR) Project while under an approved early site permit (ESP) and the TVA New Nuclear Program organization, which addresses infrastructure and programmatic matters with siting, licensing, and planning for new nuclear projects, until such time as the QAPD for TVA New Nuclear (New Nuclear QAPD, Reference NNP-TR-001-NP-A) is implemented and the Construction Permit Application (CPA) for CRN Project is approved by the NRC. After this milestone, New Nuclear Projects and Program work for siting, site-selection, design, licensing, planning, construction, and operation of new TVA nuclear plants (including the CRN SMR Project after issuance of the Construction Permit) are addressed under the TVA New Nuclear QAPD.

x Clarified the TVA Fleet NQAP is the Quality Assurance Program Description (QAPD or Fleet QAPD)

U.S. Nuclear Regulatory Commission CNL-24-060 Page 3 September 4, 2024 x

Revised the site applicability for operation of nuclear plant(s) at multiple sites to specify operation of nuclear plants at BFN, SQN, and WBN.

x Aligned positional titles and descriptions to the New Nuclear QAPD titles and descriptions.

x Clarified the qualifications for the Fire Protection Audit x

Reformatted and clarified the wording for the annual evaluation/additional audit activity section.

x Incorporated regulatory guide commitments for CRN while under ESP.

x Revised reference to Regulatory Guide 1.54. TVA commits to Revision 0 for previously applied coatings in existing nuclear plants and commits to Revision 3 for application of new coatings. Attachment 2 - Comparison of Existing NRC Regulatory Guide Commitments to NRC Regulatory Guide Commitments Adopted in the Proposed QAPD changes include the following.

x Revised regulatory guide commitments to clarify revision is in accordance with each plants Updated Final Safety Analysis Report.

x Incorporated regulatory guide commitments for CRN while under ESP.

x Revised reference to Regulatory Guide 1.54. TVA commits to Revision 0 for previously applied coatings in existing nuclear plants and commits to Revision 3 for application of new coatings. Attachment 3 - Comparison of TVA-NQA-PLN89-A (NQAP), Revision 42 to Proposed QAPD based on NQA-1-2015 changes include the following.

x Revised Attachment to correct regulatory guide titles and revisions and NQAP section references were updated throughout the document.

x Clarified the basis for acceptability of the differences in Appendices I and J from Revision 42 compared to the proposed Revision 43 for CRN while under an ESP.

Prior to CRN CPA approval, work performed for New Nuclear and CRN CPA development is governed by the Fleet QAPD, currently under Revision 42, and will continue under the proposed Revision 43, until the CPA is approved. The New Nuclear QAPD will be incorporated by reference in the CRN CPA submittal. Implementation of the New Nuclear QAPD will occur after Fleet QAPD Revision 43 implementation and prior to CPA approval. As stated in Reference 3, TVA will notify the NRC 30 days prior to the implementation of the New Nuclear QAPD. Plant Specific Action Items documented in the New Nuclear QAPD Topical Report, Revision 2, Safety Evaluation are captured as TVA commitments for inclusion in future New Nuclear licensing activities as appropriate.

U.S. Nuclear Regulatory Commission CNL-24-060 Page 4 September 4, 2024 There are no new regulatory commitments associated with this submittal. Please address any questions regarding this request to Stuart L. Rymer, Senior Manager, Fleet Licensing, at slrymer@tva.gov.

Sincerely, Kimberly D. Hulvey General Manager, Nuclear Regulatory Affairs & Emergency Preparedness Enclosure 1.

Proposed Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan cc: (Enclosure )

NRC Regional Administrator - Region II NRC Senior Resident Inspector - Browns Ferry Nuclear Plant NRC Senior Resident Inspector - Sequoyah Nuclear Plant NRC Senior Resident Inspector - Watts Bar Nuclear Plant NRC Project Manager - Browns Ferry Nuclear Plant NRC Project Manager - Sequoyah Nuclear Plant NRC Project Manager - Watts Bar Nuclear Plant State Health Officer, Alabama State Department of Public Health Director, Division of Radiological Health - Tennessee State Department of Environment and Conservation NRC Branch Chief, New Reactor Licensing Branch NRC Director, Division of New and Renewed Licenses NRC Deputy Director, Division of New and Renewed Licenses NRC Project Manager, Clinch River Nuclear Site NRC Chief, Quality Assurance and Vendor Inspection Branch Digitally signed by Edmondson, Carla Date: 2024.09.24 15:44:12 -04'00' Proposed Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan CNL-24-060 CNL-24-060 E1-1 of 1 Background and Description Pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.54(a), Tennessee Valley Authority (TVA) is requesting approval of a revision to the TVA Quality Assurance Program Description (QAPD) for TVA Nuclear Quality Assurance Plan (NQAP), (Attachment

1) to adopt updated industry standards. The updated industry standards represent approximately 45 years of experience and advancement for quality assurance and administrative controls related to the siting, design, construction, start-up, operation, and decommissioning of commercial nuclear power plants. Although the updated industry standards were developed primarily as a result of the resurgence of interest in the construction of domestic nuclear power plants, they are adaptable for use at an operating facility.

provides the Proposed Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan (NQAP), and is based on American Society of Mechanical Engineering (ASME) NQA-1-2015, Quality Assurance Requirements for Nuclear Facility Applications, as endorsed by Regulatory Guide (RG) 1.28, Revision 5, Quality Assurance Program Criteria (Design and Construction). The revised TVA QAPD (or NQAP, or Fleet QAPD) satisfies the requirements of 10 CFR 50, Appendix B, and additional administrative requirements of RG 1.33, Revision 3, Quality Assurance Program Requirements (Operation).

A summary table comparing existing commitments to NRC RGs and commitments to the updated NRC RGs is provided in Attachment 2, Comparison of Existing NRC Regulatory Guide Commitments to NRC RG Commitments Adopted in the Proposed QAPD. The commitment to RG 1.28, Revision 5 replaces commitments to several NRC RGs, which endorsed American National Standards Institute (ANSI) N45.2-1971, Quality Assurance Program Requirements for Nuclear Power Plants, and several of the older ANSI N45.2 series of standards that have been incorporated into NQA-1-2015 and earlier versions of NQA-1. The additional operational phase administrative controls previously addressed by adopting ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants, are now addressed by adopting RG 1.28, Revision 5, and NQA-1-2015.

TVA has evaluated the proposed TVA QAPD changes in accordance with 10 CFR 50.54(a) and has concluded the extent of changes to licensee (TVA) regulatory commitments warrants NRC review and approval prior to implementation. Although the overall effect of the TVA QAPD change has generally been determined to be equivalent to the existing quality assurance (QA) requirements and controls, there are specific changes in the level of detail presented in the proposed TVA QAPD that could be considered reductions in QA program commitments pursuant to 10 CFR 50.54(a). A discussion of those areas TVA considers to be either reductions or increases in the level of regulatory commitment is provided in Attachment 3, Comparison of TVA-NQA-PLN89-A (NQAP), Revision 42 to Proposed QAPD Based on NQA-1-2015.

CNL-24-060 Proposed Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan

TVA-NQA-PLN89-A Revision 43 Document Date: August 2024 Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan Non-Proprietary Approved by: ______________________________________________________

General Manager, TVA Nuclear Quality Assurance

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 2

REVISION LOG Revision 43: TVA NQAP, revised to ASME NQA-1-2015 standard.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 3

TABLE OF CONTENTS POLICY STATEMENT 6

EXECUTIVE

SUMMARY

7 Acronyms and Abbreviations 8

PART I INTRODUCTION 10 SECTION 1 GENERAL 10 SECTION 2 SCOPE / APPLICABILITY 10 PART II QUALITY ASSURANCE PROGRAM DESCRIPTION (QAPD) DETAILS 12 SECTION 1 ORGANIZATION 12 1.1 General 12 1.2 President/Chief Executive Officer 12 1.3 Executive Vice President/Chief Operating Officer 12 1.4 Executive Vice President/Chief Nuclear Officer 13 1.5 Senior Human Resources Business Partner, Nuclear 16 1.6 Nuclear Steam Supply System (NSSS) Supplier 16 1.7 Architect/Engineering (AE) Suppliers 16 1.8 NQA-1 COMMITMENT 16 Figure 2.1 - TVA Fleet QAPD Organization Chart 17 SECTION 2 QUALITY ASSURANCE PROGRAM 18 2.1 General Requirements 18 2.2 Responsibilities 19 2.3 Delegation of Work 20 2.4 Periodic Review of the QA Program 20 2.5 Issuance and Revision to QA Program 20 2.6 Personnel Training and Qualifications 20 2.7 QA Organization Education and Experience Requirements 21 2.8 QA Organizational Independence 22 2.9 Authority to Stop Work 22 2.10 Review of Activities Affecting Safe Plant Operation 22 2.11 NQA-1 Commitment / Exceptions 22 SECTION 3 DESIGN CONTROL 24 3.1 General Requirements 24 3.2 Design Input 24 3.3 Design Process 24 3.4 Design Analysis 24 3.5 Design Verification 25 3.6 Design Records 26 3.7 Computer Application and Digital Equipment Software 26 3.8 Setpoint Control 27 3.9 NQA-1 Commitment 27 SECTION 4 PROCUREMENT DOCUMENT CONTROL 28 4.1 General Requirements 28 4.2 NQA-1 Commitment / Exceptions 28 SECTION 5 INSTRUCTIONS, PROCEDURES, AND DRAWINGS 30

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 4

5.1 General Requirements 30 5.2 Procedure Adherence 30 5.3 Procedure Content 30 5.4 NQA-1 Commitment 31 SECTION 6 DOCUMENT CONTROL 32 6.1 General Requirements 32 6.2 Review and Approval of Documents 33 6.3 Changes to Documents 33 6.4 NQA-1 Commitment 33 SECTION 7 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES 35 7.1 General Requirements 35 7.2 Acceptance of Item or Service 35 7.3 NQA-1 Commitment / Exceptions 36 SECTION 8 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS 38 8.1 General Requirements 38 8.2 NQA-1 Commitment 38 SECTION 9 CONTROL OF SPECIAL PROCESSES 39 9.1 General Requirements 39 9.2 NQA-1 Commitment 39 SECTION 10 INSPECTION 40 10.1 General Requirements 40 10.2 Inspection Program 40 10.3 Inspection Records 41 10.4 Inspector Qualification 41 10.5 NQA-1 Commitment 41 SECTION 11 TEST CONTROL 42 11.1 General Requirements 42 11.2 Testing Programs 42 11.3 Computer Program Testing 42 11.4

14$&RPPLWPHQWV 43 SECTION 12 CONTROL OF MEASURING AND TEST EQUIPMENT 44 12.1 General Requirements 44 12.2 Measuring and Test Equipment Controls 44 12.3 Installed Instrument and Control Devices 44 12.4 NQA-1 Commitment 44 SECTION 13 HANDLING, STORAGE, AND SHIPPING 45 13.1 Material Control Requirements 45 13.2 Housekeeping 45 13.3 NQA-1 Commitment / Exceptions 46 SECTION 14 INSPECTION, TEST, AND OPERATING STATUS 48 14.1 General Requirements 48 14.2 NQA-1 Commitment 48 SECTION 15 CONTROL OF NONCONFORMING ITEMS 49 15.1 General Requirements 49 15.2 Interface with the Reporting Program 49

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 5

15.3 NQA-1 Commitment 50 SECTION 16 CORRECTIVE ACTION 51 16.1 General Requirements 51 16.2 Interface with the Reporting Program 51 16.3 NQA-1 Commitment 51 SECTION 17 QUALITY ASSURANCE RECORDS 52 17.1 General Requirements 52 17.2 Record Retention 52 17.3 Electronic Records 53 17.4 NQA-1 Commitment 53 SECTION 18 AUDITS 54 18.1 General Requirements 54 18.2 Internal Audits 54 18.3 External (Supplier) Audits 56 18.4 Independent Evaluation of QA Functions 56 18.5 NQA-1 Commitment / Exceptions 57 PART III NON-SAFETY RELATED STRUCTURES, SYSTEMS, AND COMPONENTS (SSC)

QUALITY CONTROL

SECTION 1 NON-SAFETY RELATED SSCS WITH SPECIAL TREATMENT 59 1.1 General 59 1.2 Quality Related SSCs 59 1.3 Quality Related Programs and Activities 59 1.4 Applicability of the QAPD 60 SECTION 2 NON-SAFETY RELATED STRUCTURES, SYSTEMS, AND COMPONENTS CREDITED FOR REGULATORY EVENTS 63 PART IV REGULATORY COMMITMENTS 64 SECTION 1 NRC Regulatory Guides and Quality Assurance Standards 64 1.1 Regulatory Guides 64 1.2 Standards 67 PART V ADDITIONAL QUALITY ASSURANCE AND ADMINISTRATIVE CONTROLS FOR THE PLANT OPERATIONAL PHASE

SECTION 1 DEFINITIONS 69 SECTION 2 REVIEW OF ACTIVITIES AFFECTING SAFE PLANT OPERATION 70 2.1 Onsite Review Committee 70 2.2 Independent Review 72 SECTION 3 OPERATIONAL PHASE PROCEDURES 73 3.1 Format and Content 73 3.2 Procedure Types 73 SECTION 4 PLANT MAINTENANCE 74

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 6

POLICY STATEMENT Tennessee Valley Authority (TVA) Nuclear shall design, procure, deliver, construct, and operate the nuclear plant(s) in a manner that will ensure the health and safety of the public and workers.

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

The TVA Fleet Nuclear Quality Assurance Plan (NQAP) is the Quality Assurance Program Description (QAPD or Fleet QAPD) provided in this document and the associated implementing documents. Together they provide for control of TVA Nuclear activities that affect the quality of safety related nuclear plant structures, systems, and components (SSCs) and include all planned and systematic activities necessary to provide adequate confidence that such SSCs will perform satisfactorily in service. The QAPD may also be applied to certain equipment and activities that are not safety related, but support safe plant operations, or where other NRC guidance establishes program requirements.

The QAPD is the top-level policy document that establishes the manner in which quality is to be achieved and presents TVA Nuclears overall philosophy regarding achievement and assurance of quality. Implementing documents assign more detailed responsibilities and requirements and define the organizational interfaces involved in conducting activities within the scope of the QAP. Senior management establishes overall expectations for effective implementation of the quality assurance program and is responsible for obtaining the desired end result. Compliance with the QAPD and implementing documents is mandatory for personnel directly or indirectly associated with implementation of the TVA Nuclear QAP.

Timothy Rausch Chief Nuclear Officer Date

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 7

EXECUTIVE

SUMMARY

This Quality Assurance Program Description (NQAP, QAPD, or Fleet QAPD) document provides a description of the TVA Nuclear Quality Assurance Program (QAP) for the operation of licensed nuclear plants at Browns Ferry Nuclear (BFN), Sequoyah Nuclear (SQN), and Watts Bar Nuclear (WBN).

This Fleet QAPD applies to the Clinch River Nuclear (CRN) Small Modular Reactor (SMR)

Project while under an approved early site permit (ESP) as well as the TVA New Nuclear Program Organization which addresses infrastructure and programmatic matters with siting, licensing, and planning for new nuclear projects, until such time as the Quality Assurance Program Description for TVA New Nuclear (NNQAP, Reference NNP-TR-001-NP-A) is implemented and the Construction Permit Application (CPA) for CRN Project is approved by the NRC. After this milestone, New Nuclear Projects and Program work for siting, site-selection, design, licensing, planning, construction, and operation of new TVA nuclear plants (including the CRN SMR Project after issuance of the Construction Permit) are addressed under the TVA NNQAP.

The QAPD has been prepared in accordance with the requirements of:

x Title 10, Part 50 of the Code of Federal Regulations (10 CFR 50), Domestic Licensing of Production and Utilization Facilities, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, x

ASME NQA-1-2015, Quality Assurance Requirements for Nuclear Facility Applications as approved in 10 CFR 50.55a and endorsed by Regulatory Guide (RG) 1.28, Revision 5, Quality Assurance Program Criteria (Design and Construction), and x

ANSI/ANS 3.2-2012, Managerial, Administrative, and Quality Assurance Controls for the Operational Phase of Nuclear Power Plants, as endorsed by RG 1.33, Revision 3, Quality Assurance Program Requirements (Operation).

TVA Nuclear considered the guidance in NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition, Section 17.5, and Nuclear Energy Institute (NEI)11-04A, Nuclear Generation Quality Assurance Program Description template for the format and content of this document.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 8

Acronyms and Abbreviations Acronym / Abbreviation Definition AE Architect/Engineer AMP Aging Management Program AMR Aging Management Review ANS American Nuclear Society ASL Acceptable Suppliers List ASME The American Society of Mechanical Engineers ATWS Anticipated Transient Without Scram BFN Browns Ferry Nuclear Plant CFR Code of Federal Regulations COL Combined Operating License CP Construction Permit CRN Clinch River Nuclear DC Design Certification EPRI Electric Power Research Institute ESP Early Site Permit ILAC International Laboratory Accreditation Cooperation ISFSI Independent Spent Fuel Storage Installation ISO International Organization for Standardization ITAAC Inspection, Tests, Analyses, Acceptance Criteria LWA Limited Work Authorization M&TE Measuring and Test Equipment MRA Mutual Recognition Agreement NDE Non-destructive Examination NEI Nuclear Energy Institute NIRMA Nuclear Information and Records Management Association

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 9

NQAP Nuclear Quality Assurance Plan NRC Nuclear Regulatory Commission NSSS Nuclear Steam Supply System NUPIC Nuclear Procurement Issues Corporation ODCM Offsite Dose Calculation Manual OL Operating License ORC Onsite Review Committee PCP Process Control Program QA Quality Assurance QAP Quality Assurance Program QAPD Quality Assurance Program Description QC Quality Control RG Regulatory Guide RIS Regulatory Issues Summary SBO Station Blackout SDA Standard Design Approval SDOE Secure development and operational environment SMR Small Modular Reactor SSC Structures, Systems, and Components SSE Safe Shutdown Earthquake SQN Sequoyah Nuclear Plant TVA Tennessee Valley Authority UFSAR Updated Final Safety Analysis Report WBN Watts Bar Nuclear Plant

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 10 PART I INTRODUCTION SECTION 1 GENERAL The QAPD is the top-level policy document that establishes the Quality Assurance policy and assigns major functional responsibilities for all quality related activities conducted by or for TVA Nuclear. The QAPD describes the methods and establishes Quality Assurance (QA) and administrative control requirements that meet 10 CFR 50, Appendix B and 10 CFR 72, Subpart G. The QAPD is based on the requirements and guidance of ASME NQA-1-2015, Quality Assurance Requirements for Nuclear Facility Applications, Parts I and II, with specific reference to selected Part III and Part IV sections, as identified in this document.

The QAP is defined by the NRC-approved regulatory document that describes the QA elements (i.e., the QAPD), along with the associated implementing documents.

Policies establish high-level responsibilities and authority for carrying out important administrative functions which are outside the scope of the QAPD.

Procedures and instructions that control quality related activities will be developed and implemented prior to commencement of those activities.

x Procedures may establish practices for certain activities which are common to all TVA Nuclear organizations performing those activities, so that the activity is controlled and carried out in a manner that meets QAPD requirements.

x Procedures specific to a site, organization, or group establish detailed implementation requirements and methods and may be used to implement policies or be unique to particular functions or work activities.

SECTION 2 SCOPE/APPLICABILITY The QAPD applies to (1) TVA Nuclear personnel and organizations performing activities that could affect quality related structures, systems, and components (SSCs) at TVA's nuclear plants and Independent Spent Fuel Storage Installations (ISFSIs); (2) TVA non-nuclear organizations working either directly under the TVA QAPD, under their program as required by intergroup agreement, or under the quality requirements specified in applicable procurement documents; (3) contractor activities that could affect quality related SSCs, unless TVA Nuclear has approved alternate administrative controls for those activities; and (4) quality related activities which addresses infrastructure and programmatic matters with siting, licensing, and planning for TVAs New Nuclear Projects and New Nuclear Program until such time as the Quality Assurance Program Description for TVA New Nuclear (NNQAP, Reference NNP-TR-001-NP-A) is implemented and the Construction Permit Application (CPA) for CRN Project is approved by the NRC. After this milestone, New Nuclear Projects and Program work for site-selection, design, construction, and operation of new TVA nuclear plants (including the CRN SMR Project after issuance of the Construction Permit) are addressed under the TVA NNQAP.

The QAPD applies to operations phase activities including those in support of Operating Licenses, and activities affecting the quality and performance of safety related structures, systems, and components, including, but not limited to:

x Designing x

Receiving x

Startup

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 11 x

Siting x

Storing x

Operating x

Procuring x

Constructing x

Maintaining x

Fabricating x

Erecting x

Repairing x

Cleaning x

Installing x

Modifying x

Handling x

Inspecting x

Refueling x

Shipping x

Testing x

Training Safety related SSCs, under the control of the QAPD, are identified by design documents. The technical aspects of these items are considered when determining program applicability, including, as appropriate, the item's design safety function. The QAPD may be applied to certain activities where regulations other than 10 CFR 50 and 10 CFR 72, Subpart G establish QA requirements for activities within their scope.

The policy of TVA Nuclear is to assure a high degree of availability and reliability of the nuclear plants while ensuring the health and safety of its workers and the public. To this end, selected elements of the QAPD are also applied to certain equipment and activities that are not safety related, but support safe, economic, and reliable plant operations, or where other NRC guidance establishes quality assurance requirements. Implementing documents establishes program element applicability.

The definitions provided in ASME NQA-1-2015, Part I, Section 400, apply to select terms as used in this document.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 12 PART II QUALITY ASSURANCE PROGRAM DESCRIPTION (QAPD) DETAILS SECTION 1 ORGANIZATION 1.1 General This section describes the TVA Nuclear organizational structure, functional responsibilities, levels of authority and interfaces for establishing, executing, and verifying QAPD implementation. The organizational structure includes corporate, off-site and on-site functions for TVA Nuclear facilities including interface responsibilities for organizations that perform quality related functions. Implementing documents assign more specific responsibilities and duties, and define the organizational interfaces involved in conducting activities and duties within the scope of the QAPD. Management gives careful consideration to the timing, extent, and effects of organizational structure changes.

Contractors may provide design, engineering, environmental, and construction services to the TVA Nuclear organization by using their QA Programs that comply with 10 CFR 50, Appendix B. Contractors performing services for TVA Nuclear without an approved QA Program will be required to meet the requirements of the TVA Fleet QAPD.

The following sections describe the reporting relationships, functional responsibilities, and authorities for organizations implementing and supporting the QAP. The TVA Nuclear organizational structure is shown in Figure 2.1.

1.2 President/Chief Executive Officer The President/Chief Executive Officer (CEO) is responsible for all aspects of design, construction, and operation of TVAs nuclear plants, including new nuclear projects developed under TVA New Nuclear. The President/CEO is also responsible for all technical and administrative support activities provided by TVA and contractors. The President/CEO directs the Chief Nuclear Officer and the Chief Operating Officer in the fulfillment of their responsibilities. The President/CEO reports to the TVA Board of Directors with respect to all matters.

1.3 Executive Vice President/Chief Operating Officer The Executive Vice President/Chief Operating Officer is responsible for TVAs transmission and power supply, power operations, resource management and operations services, and generation projects and fleet services. The Chief Operating Officer supports TVA Nuclear through the Senior Vice President, Resource Management and Operations Support.

Organizations that report through the Senior Vice President, Resource Management and Operations Support include Supply Chain, Nuclear Materials, Central Labs and Services, and Inspection Services. The COO also supports the New Nuclear Projects activities through the Senior Vice President, New Nuclear Projects.

The COO will interface with the CNO regarding QA decisions affecting the New Nuclear Program. The COO does not have the authority to disposition quality assurance issues affecting the New Nuclear Program group.

A. Senior Vice President, Resource Management and Operations Support The Senior Vice President, Resource Management and Operations Support reports to the Chief Operating Officer. The management position responsible for procurement reports through the Vice President, Supply Chain to the Senior Vice

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 13 President, Resource Management and Operations Support and is responsible for ensuring that the QA requirements established by this program description are either included or referenced (as appropriate) in related Procurement sponsored program areas. Supply Chain management is also responsible for receipt inspection of items and materials used in nuclear plants.

B. General Manager, Central Labs and Services The General Manager, Central Labs and Services is the management position responsible for inspection, testing, monitoring and analysis and reports to the Chief Operating Officer through the Senior Vice President, Resource Management and Operations Support. This position is responsible for the Inspection Services organization. Inspection Services assists the responsible organization at the licensed nuclear sites in the performance of ASME,Section XI, NDE. This organization has a quality responsibility to the Vice President, Nuclear Engineering.

1.4 Executive Vice President/Chief Nuclear Officer The Executive Vice President/Chief Nuclear Officer (CNO) is responsible for the safe, reliable, and efficient operation of the TVA Nuclear Plants. The CNO also has the overall responsibility for the establishment, implementation, and administration of the TVA Nuclear Fleet QAPD and the evaluation of its effectiveness. This responsibility is implemented through the General Manager, QA. The CNO also supports the TVA New Nuclear Program activities through the Senior Vice President, Engineering and Operations Support.

A. Senior Vice President, Nuclear Operations The Senior Vice President, Nuclear Operations reports directly to the CNO and has responsibility for organizations that coordinate and integrate efforts and initiatives into day-to-day TVA Nuclear business. The Senior Vice President, Nuclear Operations is also responsible for ensuring that the QA requirements established by this program description are either included or referenced (as appropriate) in related nuclear operations-sponsored program areas identified in the body of this program description. The management positions responsible for outage scheduling and execution and for each operating nuclear site report to this position.

1. Site Vice President The Site Vice President for each nuclear site is responsible for:

a. The site compliance with the operating unit license, governmental regulations, and ASME Code requirements.

b. Supplementing programs at licensed units ensuring that the QA requirements of this program description are appropriately established in licensed units site procedures.

c. The plant technical review process and Onsite Review Committee (ORC).

d. The Fire Protection Program.

The management positions responsible for business operations and planning are matrixed to this position.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 14

2. Vice President, Outage Services The Vice President, Outage Services reports to the Senior Vice President, Nuclear Operations and is responsible for providing corporate governance of the planning and execution of plant nuclear outages and outage scheduling.

B. Senior Vice President, Engineering and Operations Support The Senior Vice President, Engineering and Operations Support reports directly to the CNO and has responsibility for organizations that coordinate and integrate efforts and initiatives into day-to-day TVA Nuclear business. Organizations reporting to this position include Nuclear Engineering, Operations Support, Nuclear Regulatory Affairs and Support Services, Nuclear Projects and Subsequent License Renewal, and New Nuclear Program. The Senior Vice President, Engineering and Operations Support, is also responsible for governance, oversight, and support of TVA New Nuclear.

1. Vice President, Nuclear Engineering The Vice President, Nuclear Engineering reports to the Senior Vice President, Engineering and Operations Support. For issues involving nuclear safety or quality, the Vice President, Nuclear Engineering has the requisite authority and organizational freedom to report directly to the CNO. This position is responsible for engineering functions including Corporate design, plant, programs, procurement, and computer engineering. Responsibilities include governance and oversight of Site Engineering functions and policy compliance for TVAs Nuclear fleet in regard to engineering functions.

2. Vice President, Operations Support The Vice President, Operations Support reports to the Senior Vice President, Engineering and Operations Support. This position provides corporate governance of the various functional areas (maintenance, operations, radiation protection, radiation safety, chemistry, work control) for TVAs nuclear fleet in order to ensure consistency across sites. This position also provides oversight and directs the Performance Improvement organization and is responsible for the nuclear training and organizational effectiveness organizations.

3. Vice President, Nuclear Regulatory Affairs and Support Services The Vice President, Nuclear Regulatory Affairs and Support Services reports to the Senior Vice President, Engineering and Operations Support. This position is responsible for maintaining an interface between TVA and NRC for licensing activities, and managing the emergency preparedness, nuclear security, and nuclear safety culture organizations.

4. Vice President, Nuclear Projects and Subsequent License Renewal The Vice President, Nuclear Projects and Subsequent License Renewal reports to the Senior Vice President, Engineering and Operations Support. This position is responsible for execution of TVA nuclear capital projects and license renewal programs and projects.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 15

5. Vice President, New Nuclear Program The Vice President, New Nuclear Program reports to the Senior Vice President, Engineering and Operations Support. This position is responsible for nuclear site development, fabrication, supply chain, site characterization, document control and advanced design engineering. The Vice President, New Nuclear Program is also responsible for developing strategies for workforce development, training, and transition planning for the New Nuclear Program. The Vice President, New Nuclear Program is also responsible for technical, administrative, corporate support services provided by New Nuclear Program and contractors.

The Vice President, New Nuclear Program is responsible for licensing activities related to the New Nuclear Program and TVA New Nuclear project sites. These include, Early Site Permits (ESPs), Limited Work Authorizations (LWA),

Construction Permits (CPs), Operating Licenses (OLs), Combined Operating Licenses (COLs), Design Certifications (DCs) and Standard Design Approval (SDA) applications. Roles and responsibilities for these activities are contained in New Nuclear Program procedures and guidelines.

The Vice President, New Nuclear Program interfaces with the Vice President, Site Project for project-related advanced nuclear technology development, Licensing, Supply Chain, and Safety during the design phase, and for corporate support during construction and operations in fulfillment of their responsibilities.

C. General Manager, Quality Assurance The General Manager, Quality Assurance (QA) is responsible for the performance of the quality assurance oversight organization for the nuclear operating fleet, vendor support, CRN ESP, and the TVA New Nuclear Program. The General Manager, QA has an independent reporting relationship with the CNO on quality issues. The General Manager, QA administers quality assurance responsibilities through the management positions responsible for Corporate QA, Site QA, and QA Services.

The General Manager, QA is responsible to size the TVA Nuclear Quality Assurance staff commensurate with the duties and responsibilities assigned. The size of the QA organization, including the size of respective site QA staffs, is determined by assessing the resources required to adequately perform functions and workloads assigned to each QA organizational unit.

The General Manager, QA is responsible for planning and performing activities to verify the development and effective implementation of the TVA Fleet QAPD.

Effective implementation includes but is not limited to:

1. developing and maintaining the Fleet QAPD,

2. evaluating compliance to QAP requirements,

3. assuring compliance with regulatory requirements and procedures through audits and technical reviews;

4. monitoring organizational processes to ensure conformance to commitments and licensing document requirements; and

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 16

5. ensuring that vendors providing quality services, parts, and materials to site projects are meeting the requirements of 10 CFR 50, Appendix B through Nuclear Procurement Issues Corporation (NUPIC), joint utility, or TVA vendor audits.

The QA function has sufficient independence from other TVA Nuclear priorities to bring forward issues affecting safety and quality and makes judgments regarding quality in all areas regarding TVA Nuclear activities as appropriate. QA may make recommendations to management regarding improving the quality of work processes. If QA disagrees with any actions taken by the New Nuclear Program group and is unable to obtain resolution, QA shall inform QA management and bring the matter to the attention of the CNO, who will determine the final disposition.

1.5 Senior Human Resources Business Partner, Nuclear The Senior Human Resources Business Partner, Nuclear has the requisite authority and organizational freedom to report directly to the CNO for issues related to nuclear personnel.

In addition, the Senior Human Resources Business Partner, Nuclear maintains a position qualification documentation and validation program.

1.6 Nuclear Steam Supply System (NSSS) Supplier A NSSS Supplier provides engineering services for plant design and licensing of specific plant types on TVA Nuclear sites. These engineering services for nuclear generation include site-specific engineering and design necessary to support ongoing plant maintenance and modifications.

1.7 Architect/Engineering (AE) Suppliers AE Suppliers provide engineering services to support ongoing plant maintenance and modifications. These engineering services include engineering and design activities, including planning and support for maintenance and modification of nuclear generation facilities.

1.8 NQA-1 COMMITMENT In establishing its organizational structure, TVA Nuclear commits to compliance with NQA 2015, Part I, Requirement 1, and ANSI/ANS 3.2-2012, Section 3.1 as endorsed by Regulatory Guide 1.33, Revision 3.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 17 Figure 2.1 TVA Fleet QAPD Organization Chart

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 18 SECTION 2 QUALITY ASSURANCE PROGRAM 2.1 General Requirements A. TVA Nuclear has established the necessary measures and governing procedures to implement the QAP as described in the QAPD. TVA Nuclear is committed to implementing the QAP in all aspects of work that are important to the safety of the nuclear plants as described and to the extent delineated in the QAPD.

B. TVA Nuclear QA program ensures that activities affecting quality shall be accomplished under suitably controlled conditions, including:

1. the use of appropriate equipment,

2. a suitable environment for accomplishing the activity, e.g., adequate cleanliness, and

3. compliance with necessary prerequisites for the given activity.

C. The QAP shall include monitoring activities against acceptance criteria in a manner sufficient to provide assurance that the activities important to safety are performed satisfactorily.

D. The objective of the QAP is to assure that TVAs nuclear generating sites are operated in accordance with governing regulations and license requirements. Cost and scheduling challenges must be addressed; however, they do not prevent proper implementation of the QAP.

E. The QAP is based on the requirements of ASME NQA-1-2015, Quality Assurance Requirements for Nuclear Facility Applications, as endorsed by Regulatory Guide 1.28, Revision 5; ANS 3.2-2012, Managerial, Administrative, and Quality Assurance Controls for the Operational Phase of Nuclear Power Plants, as endorsed by Regulatory Guide 1.33, Revision 3; and as described in this document.

F. The QAP applies to those quality related activities that involve the functions of safety related SSCs associated with the design, fabrication, construction, and testing of the SSCs of the facility and to the managerial and administrative controls to be used to assure safe operations. A list or system that identifies SSCs and activities to which this program applies is maintained at the appropriate facility. Design documents are used as the basis for this list.

G. As described in Part III of the QAPD, specific program controls are applied to non-safety related SSCs that are significant contributors to plant safety, for which 10 CFR 50, Appendix B, is not applicable. The specific program controls, consistent with applicable sections of the QAPD, are applied to those items in a select manner, targeted at those characteristics or critical attributes that qualifies the SSC as a significant contributor to plant safety. (This paragraph and Part III do not apply to ESP related activities.)

H. Activities governed by the QAPD are performed as directed by documented instructions, procedures, and drawings that are of a detail appropriate for the activitys complexity and effect on safety. Provisions are established to designate or identify the proper documents to be used in an activity, and to ascertain that such documents are being used. Instructions, procedures, and drawings specify

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 19 quantitative or qualitative acceptance criteria as applicable or appropriate for the activity, and verification is against these criteria.

I.

Senior management is regularly apprised of the adequacy of implementation of the QAP through the audit functions described in QAPD, Part II, Section 18.

J. A grace period may be applied to provisions that are required to be performed on a periodic basis, unless otherwise noted. Annual evaluations and audits that must be performed on a triennial basis are examples where a grace period could be applied.

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. Audit schedules are based on the month in which the audit starts.

K. TVA Nuclear ensures through the systematic process that its suppliers of safety related equipment or services meet the applicable requirements of 10 CFR 50, Appendix B.

L. Delegated responsibilities may be performed under a suppliers or principal contractors QAP, provided that the supplier or principal contractor has been approved as a supplier in accordance with the TVA Nuclear QAP or TVA Acceptable Suppliers List (ASL).

M. Periodic audits and assessments of supplier QA programs are performed to assure compliance with the suppliers or principal contractors QAPD and implementing procedures. In addition, routine interfaces with the suppliers personnel provide added assurance that quality expectations are met. The program requirements specified herein are detailed in implementing procedures that are either TVA Nuclear implementing procedures, or supplier implementing procedures governed by a supplier quality assurance program.

2.2 Responsibilities A. Personnel who work directly or indirectly for TVA Nuclear are responsible for achieving acceptable quality in the work covered by the QAPD. This includes the activities delineated in Part I, Section 2.

B. The TVA Nuclear Quality Assurance organization is responsible for establishing upper-tier QA Program requirements and implementation of Quality Assurance functions at corporate and nuclear plant sites. The organization is also responsible for independently planning and performing activities to verify the development and effective implementation of the TVA Fleet QAPD.

C. The Quality Assurance organization is responsible for verifying that processes and procedures comply with QAPD and other applicable requirements, that such processes or procedures are implemented, and that management appropriately ensures compliance.

D. TVA Nuclear personnel performing verification activities are responsible for verifying the achievement of acceptable quality.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 20 2.3 Delegation of Work A. TVA Nuclear retains and exercises the responsibility for the scope and implementation of an effective QAP.

B. Positions identified in QAPD, Part II, Section 1, may delegate all or part of the activities of planning, establishing, and implementing the program for which they are responsible to others, but retain the responsibility for the programs effectiveness.

C. Decisions affecting safety are made at the appropriate level based upon their nature and effect, with technical advice or review as appropriate.

2.4 Periodic Review of the QA Program A. The General Manager, QA will assess the adequacy and effective implementation of QA program requirements, and provide periodic reports to the CNO on the health of the program.

B. Management of organizations (other than TVA Nuclear) implementing the QAP, or portions thereof, shall assess the adequacy of that part of the program for which they are responsible to assure its effective implementation.

2.5 Issuance and Revision to QA Program A. Administrative control of the QAPD will be in accordance with 10 CFR 50.54(a).

Changes to the QAPD are evaluated by TVA Nuclear Quality Assurance to ensure that such changes do not degrade safety for previously approved quality assurance controls specified in the QAPD. Revisions to the document will be reviewed and approved, at a minimum, by the General Manager, QA.

B. Regulations require that the Updated Final Safety Analysis Report (UFSAR) include, among other things, the managerial and administrative controls to be used to assure safe operation, including a discussion of how the applicable requirements of 10 CFR 50, Appendix B will be satisfied. In order to comply with this requirement, the UFSAR references the QAPD and, as a result, the requirements of 10 CFR 50.54(a) are satisfied by and apply to the QAPD.

2.6 Personnel Training and Qualifications A. Personnel assigned to implement elements of the QAPD shall be capable of performing their assigned tasks. To this end, TVA Nuclear establishes and maintains formal indoctrination, training, and qualification programs as necessary for personnel performing, verifying, or managing activities within the scope of the QAPD to achieve initial proficiency, maintain proficiency, and adapt to technology changes, method, or job responsibilities.

B. The indoctrination, training, and qualification programs are commensurate with scope, complexity, and importance of the activities; and include or address, as appropriate:

1. the education, experience, and proficiency of the personnel receiving training.

2. general criteria, technical objectives, requirements of applicable codes and standards, regulatory commitments, company procedures, and quality assurance program requirements.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 21

3. on-the-job training if direct hands-on applications or experience is needed to achieve and maintain proficiency.

C. Plant and support staff minimum qualification requirements are as delineated in the unit Technical Specifications. Other qualification requirements may be established but will not reduce those required by Technical Specifications. (This paragraph does not apply to non-operations activities.)

D. Sufficient managerial depth is provided to cover absences of incumbents.

E. When required by code, regulation, or standard, specific qualification and selection of personnel is conducted in accordance with those requirements as established in the applicable TVA Nuclear procedures.

F. Indoctrination includes the administrative and technical objectives, requirements of the applicable codes and standards, and the QAPD elements to be employed.

G. Training for positions identified in 10 CFR 50.120 is accomplished according to programs accredited by the National Nuclear Accrediting Board of the National Academy of Nuclear Training that implement a systematic approach to training (This does not apply to non-operations activities).

H. Records of personnel training and qualifications are maintained.

2.7 QA Organization Education and Experience Requirements A. The minimum qualification of the General Manager, QA is that the manager:

1. holds an engineering or related science degree and

2. has a minimum of four years of related experience, including two years of nuclear power plant experience, one year of supervisory or management experience, and one year of the experience is in performing quality verification activities.

3. meets special requirements, to include management and supervisory skills and experience or training in leadership, interpersonal communication, management responsibilities, motivation of personnel, problem analysis and decision making, and administrative policies and procedures.

B. The minimum qualifications for the individuals responsible for supervising QA or QC personnel is that each:

1. has a high school diploma or equivalent and

2. has a minimum of one year of experience performing quality verification activities.

C. The minimum qualifications of individuals that are part of the QA organization responsible for planning, implementing, and maintaining the programs for the QAPD are that each:

1. has a high school diploma or equivalent and

2. has a minimum of one year of related experience.

D. Individuals who do not possess these formal education and minimum experience requirements should not be eliminated automatically when other factors provide

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 22 sufficient demonstration of their abilities. These other factors are evaluated on a case-by-case basis and approved and documented by senior management.

2.8 QA Organizational Independence A. Independence shall be maintained between the organization(s) performing the checking (quality assurance and control) functions and the organizations performing the functions. This provision is not applicable to design review/verification.

B. The QA function has sufficient independence from other TVA Nuclear priorities to bring forward issues affecting safety and quality and makes judgments regarding quality in all areas regarding TVA Nuclear design activities as appropriate. QA may make recommendations to management regarding improving the quality of work processes. If QA disagrees with any actions taken by the organization and is unable to obtain resolution, QA shall inform quality assurance management and bring the matter to the attention of the CNO, who will determine the final disposition.

2.9 Authority to Stop Work Quality Assurance and Quality Control personnel have the authority, and the responsibility, to stop work in progress which is not being done in accordance with approved procedures or where safety or SSC integrity may be jeopardized. This authority extends to off-site work performed by suppliers that furnish safety related materials and services to TVA Nuclear.

2.10 Review of Activities Affecting Safe Plant Operation For operating units, requirements for the review of activities affecting safe plant operation required by ANS 3.2-2012, Section 3.2 (including onsite review committees and independent review functions) are contained in QAPD, Part V, Section 2.

2.11 NQA-1 Commitment / Exceptions A. In establishing general QA program responsibilities, TVA Nuclear commits to compliance with NQA-1-2015, Part I, Requirement 2, and ANSI/ANS 3.2-2012, Section 3.2 as endorsed by Regulatory Guide 1.33, Revision 3.

B. In establishing education and experience requirements for positions in the plant operating organization, TVA Nuclear commits to compliance with ANSI/ANS 3.1-2014 and the applicable regulatory position stated in Regulatory Guide 1.8, Revision 4, Qualification and Training of Personnel for Nuclear Power Plants.

C. In establishing qualification requirements and training programs, TVA Nuclear commits to compliance with ANSI/ANS 3.2-2012, Section 3.2.3 as endorsed by Regulatory Guide 1.33, Revision 3, with the following clarification: Instead of ANSI/ASME NQA-1-2008 and NQA-1a-2009 Addenda, TVA commits to NQA-1-2015, Part I, Requirement 2 and the applicable regulatory position stated in Regulatory Guide 1.28, Revision 5, specifically Section C.1.a for lead auditors with the following clarifications and exceptions:

x Section 303.3 Prospective lead auditors, with comparable industry experience, may satisfy the lead auditor qualification requirement of participating in a minimum of five QA audits within a period of three (3) years prior to the date of qualification by alternatively demonstrating the ability to properly implement the

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 23 audit process, effectively organize and report results, and participate in at least one nuclear audit within the year preceding the date of qualification, subject to review and acceptance by the responsible QA organization.

x Section 401(g) requires the date of certification expiration be included on the qualification record. TVA Nuclear considers the certification expiration date to be the date from the certification or recertification date plus the certification interval time; therefore, the inclusion of a specific certification expiration date on the qualification record is optional.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 24 SECTION 3 DESIGN CONTROL 3.1 General Requirements A. TVA Nuclear has established and implements a process to control the design, design changes, and temporary modifications (e.g., temporary bypass lines, electrical jumpers, and lifted wires, and temporary setpoints) of items that are subject to the provisions of the QAPD.

B. Changes to design inputs, final designs, and field changes, and temporary and permanent modifications are justified and subject to design control measures commensurate with those applied to the original design.

3.2 Design Input A. Applicable design inputs shall be identified and documented, and their selection reviewed and approved.

B. The design input shall be specified to the level of detail necessary to permit the design activities to be carried out in a controlled manner and to provide a consistent basis for making design decisions, accomplishing design verification measures, and evaluating design changes.

3.3 Design Process A. TVA Nuclear shall prescribe and document design activities to the level of detail necessary to permit the design process to be carried out in a correct manner, and to permit verification that the design meets requirements.

B. Design documents shall support the facility design, construction, and operation.

C. Appropriate quality standards shall be identified and documented, and their selection reviewed and approved.

D. The design process includes provisions to control design inputs, outputs, changes, interfaces, records, and organizational interfaces within TVA Nuclear and with suppliers.

3.4 Design Analysis A. Use of existing data will be performed in accordance with NQA-1-2015, Part IV, Subpart 4.2.3, Guidance on Qualification of Existing Data. These provisions assure that design inputs (such as design bases and the performance, regulatory, quality, and quality verification requirements) are correctly translated into design outputs (such as analyses, specifications, drawings, procedures, and instructions) so that the final design output contains or references appropriate acceptance criteria that can be related to the design input in sufficient detail to permit verification by inspection and test, as required.

B. Design change processes and the division of responsibilities for design-related activities are detailed in TVA Nuclear and supplier procedures.

C. The design control program includes interface controls necessary to control the development, verification, approval, release, status, distribution, and revision of design inputs and outputs.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 25 D. Design changes and disposition of nonconforming items as use as is or repair are reviewed and approved by the TVA Nuclear design organization(s) or by other organizations authorized by TVA Nuclear.

E. Procedural control is established for design documents.

F. Procedural control differentiates between documents that receive formal design verification by interdisciplinary or multi-organizational teams and those which can be reviewed by a single individual (a signature and date is acceptable documentation for personnel certification).

G. Design documents subject to procedural control include, but are not limited to, specifications, calculations, computer programs, system descriptions, and drawings (including flow diagrams, piping and instrument diagrams, control logic diagrams, electrical single line diagrams, structural systems for major facilities, site arrangements, and equipment locations).

H. Specialized reviews should be used when uniqueness or special design considerations warrant.

I.

Design documents are reviewed by individuals knowledgeable in QA to ensure the documents contain the necessary QA requirements. (This paragraph does not apply to ESP activities.)

3.5 Design Verification A. TVA Nuclear design processes provide for design verification to ensure that items, computer programs, and activities subject to the provisions of the QAPD are suitable for their intended application, consistent with their effect on safety. Design changes are subjected to these controls, which include verification measures commensurate with those applied to original plant design.

B. Design verifications are performed by competent individuals or groups other than those who performed the original design but who may be from the same organization.

1. 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.

2. This verification may be performed by the originators supervisor provided the supervisor did not specify a singular design approach, rule out certain design considerations, and did not establish the design inputs used in the design, or if the supervisor is the only individual in the organization competent to perform the verification. If the verification is performed by the originators supervisor, the justification of the need is documented and approved in advance by management.

C. The extent of the design verification required is a function of the importance to safety of the item or computer program under consideration, the complexity of the design, the degree of standardization, state-of-the-art, and the similarity with previously proven designs. This includes design inputs, design outputs, and design changes.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 26 D. Design verification procedures are established and implemented to assure that an appropriate verification method is used, the appropriate design parameters to be verified are chosen, the acceptance criteria are identified, and the verification is satisfactorily accomplished and documented.

E. Verification methods may include, but are not limited to, design reviews, alternative calculations, and qualification testing. Testing used to verify the acceptability of a specific design feature demonstrates acceptable performance under conditions that simulate the most adverse design conditions expected for the items intended use.

F. TVA Nuclear normally completes design verification activities before the design outputs are used by other organizations for design work, and before they are used to support other activities such as procurement, or construction. When such timing cannot be achieved, the design verification is completed before relying on the item to perform its intended design or safety function.

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

B. Plant design drawings reflect the properly reviewed and approved configuration of the plant.

3.7 Computer Application and Digital Equipment Software A. The QAPD governs the development, procurement, testing, maintenance, control, and use of computer applications and digital equipment software when used in safety related applications and designated non-safety related applications.

B. Computer program acceptability is pre-verified, or the results verified with the design analysis for each application. Pre-verified computer programs are controlled using a software configuration management process.

C. TVA Nuclear and suppliers are responsible for developing, approving, and issuing procedures, as necessary, to control the use of such computer application and digital equipment software.

D. TVA Nuclear procedures require that application software be assigned a proper quality classification and that the associated quality requirements be consistent with this classification.

E. Each application software and revision thereto are documented and approved by authorized personnel.

F. The QAPD is also applicable to the administrative functions associated with the maintenance and security of computer hardware where such functions are considered essential in order to comply with other QAPD requirements such as QA records.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 27 3.8 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:

A. identify responsibilities and processes for reviewing, approving, and revising setpoints and setpoint changes supplied by a supplier, SDA holder, DC holder, or the plants technical staff.

B. ensure that setpoints and setpoint changes are consistent with design and accident analysis requirements and assumptions.

C. provide for documentation of setpoints, including those determined operationally.

D. provide for access to necessary setpoint information for personnel who write or revise plant procedures, operate or maintain plant equipment, develop, or revise design documents, or develop or revise accident analyses.

This subsection does not apply to ESP activities.

3.9 NQA-1 Commitment In establishing its program for design control and verification, TVA Nuclear commits to compliance with ANSI/ANS 3.2-2012, Section 3.3, as endorsed by Regulatory Guide 1.33, Revision 3, with the following clarification: Instead of ANSI/ASME NQA-1-2008 and NQA-1a-2009 Addenda, TVA commits to the following parts of NQA-1-2015:

x NQA-1-2015 Part I, Requirement 3 Design Control x

NQA-1-2015 Part II, Subpart 2.7, Quality Assurance Requirements for Computer Software for Nuclear Facilities Applications x

NQA-1-2015 Part II, Subpart 2.14, Quality Assurance Requirements for Commercial Grade Items and Services x

NQA-1-2015 Part II, Subpart 2.20, Quality Assurance Requirements for Subsurface Investigations for Nuclear Facilities (Subpart 2.20 does not apply to Operations activities)

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 28 SECTION 4 PROCUREMENT DOCUMENT CONTROL 4.1 General Requirements A. TVA Nuclear has established the necessary measures and governing procedures to assure that purchased items, computer programs, and services are subject to appropriate quality and technical requirements.

B. Procurement document changes shall be subject to the same degree of control as utilized in the preparation of the original documents. These controls include provisions such that:

1. 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.

2. applicable technical, regulatory, administrative, quality, and reporting requirements (such as specifications, codes, standards, tests, inspections, special processes, and 10 CFR 21) are invoked for procurement of items and services.

C. 10 CFR 21 requirements for posting, evaluating, and reporting will be followed and imposed on suppliers when applicable. Applicable design bases and other requirements necessary to assure adequate quality shall be included or referenced in documents for procurement of items and services.

D. To the extent necessary, procurement documents shall require suppliers to have a documented QA program that is determined to meet the applicable requirements of 10 CFR 50, Appendix B, or 10 CFR 72, Subpart G, as appropriate to the circumstances of procurements (or the supplier may work under TVA Nuclears approved QA program).

E. Reviews of procurement documents shall be performed by personnel who have access to pertinent information and who have an adequate understanding of the requirements and intent of the procurement documents.

4.2 NQA-1 Commitment / Exceptions In establishing controls for procurement documents, TVA commits to ANSI/ANS 3.2-2012, Section 3.4, as endorsed by Regulatory Guide 1.33, Revision 3, with the following clarification: Instead of ANSI/ASME NQA-1-2008 and NQA-1a-2009 Addenda, TVA commits to compliance with NQA-1-2015, Part I, Requirement 4, with the following clarifications and exceptions:

x With regard to service performed by a supplier, TVA Nuclear procurement documents may allow the supplier to work under the TVA Nuclear QAP, including implementing procedures, in lieu of the supplier having its own QAP.

x Section 202, Technical Requirements, and 203, Quality Assurance Program Requirements, of Requirement 4, require that the technical and quality requirements be specified in the procurement documents. As a clarification, procurement documents for Commercial Grade Items that will be procured by TVA Nuclear for use

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 29 as safety related items shall contain technical and quality requirements such that the procured item can be appropriately dedicated in accordance with QAPD, Part II, Section 7, Control of Purchased Material, Equipment, and Services.

x Section 300 and 400 of Requirement 4 require the review of technical and QA Program requirements of procurement documents prior to award of a procurement contract and for procurement document changes. TVA Nuclear may satisfy this requirement through the review of the procurement specification when the specification contains the technical and quality assurance requirements of the procurement contract.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 30 SECTION 5 INSTRUCTIONS, PROCEDURES, AND DRAWINGS 5.1 General Requirements A. TVA Nuclear has established the necessary measures and governing procedures to ensure that activities affecting quality are prescribed by and performed in accordance with instructions, procedures, or drawings of a type appropriate to the circumstances and which, where applicable, include quantitative or qualitative acceptance criteria to implement the QAP as described in the QAPD. Such documents are prepared and controlled according to QAPD, Part II, Section 6.

B. In addition, means are provided to disseminate to the staff, instructions of both general and continuing applicability, as well as those of short-term applicability.

Provisions are included for reviewing, updating, and canceling such procedures.

5.2 Procedure Adherence A. TVA Nuclears policy is that procedures are followed, and the requirements for use of procedures have been established in administrative procedures.

B. Where procedures cannot be followed as written, provisions are established for making changes in accordance with QAPD, Part II, Section 6.

C. 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. the verification of completion of significant steps, by initials or signatures or use of check-off lists.

D. 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.

E. 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 The established measures address the applicable content of procedures as described in ANSI/ANS 3.2-2012. Other applicable requirements for procedure content described in the Introduction to Part II of NQA-1-2015 may be met through administrative procedures.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 31 5.4 NQA-1 Commitment In establishing procedural controls, TVA Nuclear commits to compliance with ANSI/ANS 3.2-2012, Section 3.5 as endorsed by Regulatory Guide 1.33, Revision 3, with the following clarification: Instead of ANSI/ASME NQA-1-2008 and NQA-1a-2009 Addenda, TVA commits to NQA-1-2015, Part I, Requirement 5.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 32 SECTION 6 DOCUMENT CONTROL 6.1 General Requirements A. TVA Nuclear has established the necessary measures and governing procedures to control the preparation, issuance, and revision of documents that specify quality requirements or prescribe how activities affecting quality, including organizational interfaces, to ensure that correct documents are employed. Controls, including electronic systems used to make documents available, are applied to documents and changes to documents, to include:

1. a method to identify controlled documents

2. a specified distribution of controlled documents for use at the appropriate location

3. a method to identify the correct document (including revision) to be used and control of superseded documents

4. a method to identify individuals responsible for controlled document preparation, review, approval, and distribution

5. a method of review of controlled documents for adequacy, completeness, and approval prior to distribution

6. a method to ensure the correct documents are being used

7. a method to provide feedback from users to improve procedures and work instructions

8. a method to coordinate and control interface documents and procedures B. The types of documents to be controlled include:

1. drawings such as design, fabrication, construction, installation, and as-built drawings

2. engineering calculations

3. design specifications

4. purchase orders and related documents

5. vendor-supplied documents

6. audit, surveillance, and quality verification/inspection procedures

7. inspection and test reports

8. instructions and procedures for activities covered by the QAPD including design, construction, installation, operating (including normal and emergency operations), maintenance, calibration, and routine testing

9. technical specifications

10. nonconformance reports and corrective action reports C. During the operational phase, where temporary procedures are used, they shall include a designation of the period of time during which it is acceptable to use them.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 33 6.2 Review and Approval of Documents A. Documents are reviewed for adequacy by qualified persons other than the preparer.

1. During the ESP or construction phase, procedures for design, construction, and installation are also reviewed by the organization responsible for quality verification to ensure quality assurance measures have been appropriately applied. The documented review signifies concurrence. (This requirement does not apply to operations activities.)

2. During the operational phase, documents affecting the configuration or operation of the station as described in the UFSAR are screened to identify those that require review by an Independent Review Group prior to implementation as described in Part V, Section 2.2.

B. To ensure effective and accurate procedures during the operational phase, TVA Nuclear has programmatic controls to ensure procedures are periodically reviewed and maintained current when pertinent source material is revised; the plant design changes; and/or any deficiencies occur.

C. Prior to issuance or use, documents including revisions thereto, are approved by the designated authority. A listing of all controlled documents identifying the current approved revision, or date, is maintained so personnel can readily determine the appropriate document for use.

6.3 Changes to Documents A. Changes to documents, other than those defined in implementing procedures as minor changes, are reviewed, and approved by the same organizations that performed the original review and approval unless other organizations are specifically designated. The reviewing organization has access to pertinent background data or information upon which to base their approval.

B. Where temporary procedure changes are necessary during the operational phase, changes that clearly do not change the intent of the approved procedure may be implemented provided they are approved by two members of the staff knowledgeable in the areas affected by the procedures. (This requirement does not apply to non-operations activities.)

C. Minor changes to documents, such as inconsequential editorial corrections, do 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 classification shall be clearly delineated in implementing procedures.

6.4 NQA-1 Commitment In establishing provisions for document control, TVA Nuclear commits to compliance with ANSI/ANS 3.2-2012, Section 3.6, as endorsed by Regulatory Guide 1.33, Revision 3, with the following clarification and alternative:

x Instead of ANSI/ASME NQA-1-2008 and NQA-1a-2009 Addenda, TVA commits to NQA-1-2015 Part I, Requirement 6.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 34 x

TVA has programmatic controls in place that make a biennial review process unnecessarily duplicative. These programmatic controls ensure procedures are periodically reviewed and maintained current when pertinent source material is revised; the plant design changes; and/or any deficiencies occur.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 35 SECTION 7 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES 7.1 General Requirements A. TVA Nuclear has established the necessary measures and governing procedures to control purchased items and services to assure conformance with specified requirements.

B. Control of purchased items and services provides 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.

7.2 Acceptance of Item or Service A. TVA Nuclear establishes and implements measures to assess the quality of purchased items and services, whether purchased directly or through contractors, at intervals and to a depth consistent with the item or service importance to safety, complexity, quantity, and the frequency of procurement.

B. Verification actions include testing, as appropriate, during design, fabrication, construction, and operation activities. Verifications occur at the appropriate phases of the procurement process, including, as necessary, verification of activities of suppliers below the first tier.

C. Measures to assure the quality of purchased items and services include the following, as applicable.

1. Items are inspected, identified, and stored to protect against damage, deterioration, or misuse.

2. Prospective safety related items and service suppliers are evaluated to assure only qualified suppliers are used. Qualified suppliers are audited on a triennial basis. In addition, if a subsequent contract or a contract modification significantly changes the scope, methods, or controls performed by a supplier, an audit of the changes is performed, thus starting a new triennial period.

3. TVA Nuclear may utilize audits conducted by outside organizations for supplier qualification provided that the scope and adequacy of the audits meet TVA Nuclear requirements. Documented annual evaluations are performed for qualified suppliers to assure they continue to provide acceptable products and services. Industry programs, such as those applied by ASME, NUPIC or other established utility groups, are used as input or the basis for supplier qualification whenever appropriate. The results of the reviews are promptly considered for effect on a supplier's continued qualification and adjustments made as necessary (including corrective actions, adjustments of supplier audit plans, and input to third party auditing entities, as warranted). In addition, results are reviewed periodically to determine if, as a whole, they constitute a significant condition adverse to quality requiring additional action.

4. Provisions are made for accepting purchased items and services, such as source verification, receipt inspection, pre-and post-installation tests, certificates of conformance, and document reviews (including Certified Material Test Report/Certificate). Acceptance actions/documents should be established by the

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 36 Purchaser with appropriate input from the Supplier and be completed to ensure that procurement, inspection, and test requirements, as applicable, have been satisfied before relying on the item to perform its intended safety function.

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

6. If there is insufficient evidence of implementation of a QA program, the initial evaluation is of the existence of a QA program addressing the scope of services to be provided. The initial audit is performed after the supplier has completed sufficient work to demonstrate that its organization is implementing a QA program.

7.3 NQA-1 Commitment / Exceptions In establishing controls for purchased items and services, TVA Nuclear commits to ANSI/ANS 3.2-2012, Section 3.7, as endorsed by Regulatory Guide 1.33, Revision 3, with the following clarification: Instead of ANSI/ASME NQA-1-2008 and NQA-1a-2009 Addenda, TVA commits to NQA-1-2015 Part I, Requirement 7, and the applicable regulatory position stated in Regulatory Guide 1.28, Revision 5 with the following clarifications and exceptions:

A. TVA Nuclear considers that other 10 CFR 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 TVA Nuclear plants are not required to be evaluated or audited.

B. The International Laboratory Accreditation Cooperation (ILAC) accreditation process cannot be used for commercial grade dedication of Nondestructive Examination (NDE) services in lieu of performing a Commercial Grade Survey.

C. For Section 200, during periods of exigent conditions, TVA Nuclear may conduct remote audits/surveys of suppliers in accordance with the guidance in EPRI TR 3002020796, Remote Assessment Techniques: Planning and Conducting Audits and Surveys Using Remote Techniques During Exigent Conditions, and EPRI TR 3002019436, Remote Source Verification During a Pandemic or Similar State of Emergency. The application of the guidance will be limited by the application of the EPRI TRs screening questions.

D. For Section 501, TVA Nuclear considers documents that may be stored in approved electronic media under TVA Nuclear or vendor control, not physically located on the plant site, but accessible from the prospective nuclear facility site as meeting the NQA 2015 requirement for documents to be available at the site. Following completion of the construction period, sufficient as-built documentation will be turned over to TVA Nuclear to support operations. The TVA Nuclear records management system will provide for timely retrieval of necessary records.

E. In establishing commercial grade item requirements, TVA Nuclear commits to compliance with NQA-1-2015, Part I, Requirement 7, Section 700, and Part II, Subpart 2.14, with the following clarification.

1. For commercial grade items, quality verification requirements are established and described in TVA Nuclear documents to provide the necessary assurance an item will perform satisfactorily in service. The TVA Nuclear documents address

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 37 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.

2. TVA Nuclear will assume 10 CFR 21 reporting responsibility for all items that TVA Nuclear dedicates as safety related.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 38 SECTION 8 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS 8.1 General Requirements A. TVA Nuclear has established the necessary measures and governing procedures to identify and control items to prevent the use of incorrect or defective items. This includes controls for consumable materials and items with limited shelf life.

B. The identification of items is maintained throughout fabrication, erection, installation, and use so that the item can be traced to its documentation, consistent with the item's effect on safety. Identification locations and methods are selected so as not to affect the function or quality of the item.

8.2 NQA-1 Commitment In establishing provisions for identification and control of items, TVA Nuclear commits to ANSI/ANS 3.2-2012, Section 3.8, as endorsed by Regulatory Guide 1.33, Revision 3, with the following clarification: Instead of ANSI/ASME NQA-1-2008 and NQA-1a-2009 Addenda, TVA commits to NQA-1-2015, Part I, Requirement 8.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 39 SECTION 9 CONTROL OF SPECIAL PROCESSES 9.1 General Requirements A. TVA Nuclear has established the necessary measures and governing procedures to assure that special processes that require interim process controls to assure quality, such as welding, heat treating, and NDE, are controlled. 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. These provisions include assuring that:

1. special processes are accomplished by qualified personnel.

2. special processes are performed using qualified procedures and equipment, in accordance with applicable codes, standards, specifications, criteria, or other specially established requirements.

3. instructions or procedures for special processes include or reference procedures, personnel, and equipment qualification requirements.

B. Records are maintained as appropriate for the currently qualified personnel, processes, and equipment for each special process.

9.2 NQA-1 Commitment In establishing measures for the control of special processes, TVA Nuclear commits to ANSI/ANS 3.2-2012, Section 3.9, as endorsed by Regulatory Guide 1.33, Revision 3, with the following clarification: Instead of ANSI/ASME NQA-1-2008 and NQA-1a-2009 Addenda, TVA commits to NQA-1-2015, Part I, Requirement 9.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 40 SECTION 10 INSPECTION 10.1 General Requirements A. TVA Nuclear has established the necessary measures and governing procedures to implement inspections that assure items, services, and activities affecting safety meet established requirements and conform to applicable documented specifications, instructions, procedures, and design documents. Inspection may also be applied to items, services, and activities affecting plant reliability and integrity.

B. Types of inspections may include those verifications related to procurement, such as source, in-process, final, and receipt inspection, as well as construction, installation, maintenance, modification, in-service, and operations activities.

C. Inspections are carried out by properly qualified persons independent of those who perform or directly supervise the work.

D. Inspection results are documented.

10.2 Inspection Program A. The inspection program establishes inspections (including surveillance of processes), as necessary to verify quality:

1. at the source of supplied items or services;

2. in-process during fabrication at a supplier's facility or at TVA Nuclear facilities;

3. for final acceptance of fabricated and/or installed items during construction, and upon receipt of items for a facility; and

4. during maintenance, modification, in-service, and operating activities.

B. 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.

C. Inspection planning is performed by personnel qualified in the discipline related to the inspection and includes qualified inspectors or engineers.

D. 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.

E. 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.

F. Inspection program documents establish requirements for performing the planned inspections, and documenting required inspection information such as rejection, acceptance, and re-inspection results, and the person(s) performing the inspection.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 41 10.3 Inspection Records A. Inspection records identify the items inspected, date of inspection, the inspectors identity, types of observation, inspection results and acceptability, and reference to information on action taken in connection with nonconformances.

B. Inspection results are documented by the inspector, reviewed by authorized personnel qualified to evaluate the technical adequacy of the inspection results, and controlled by instructions, procedures, and drawings.

10.4 Inspector Qualification A. TVA Nuclear has established qualification programs for personnel performing quality inspections. The qualification program requirements are described in QAPD, Part II, Section 2.

B. These qualification programs are applied to individuals performing quality inspections regardless of the functional group where they are assigned.

10.5 NQA-1 Commitment In establishing inspection requirements, TVA Nuclear commits to compliance with ANSI/ANS 3.2-2012, Section 3.10, as endorsed by Regulatory Guide 1.33, Revision 3, with the following clarification: Instead of ANSI/ASME NQA-1-2008 and NQA-1a-2009 Addenda, TVA commits to NQA-1-2015, Part I, Requirement 10 and Part II, Subparts 2.5 and 2.8.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 42 SECTION 11 TEST CONTROL 11.1 General Requirements A. TVA Nuclear has established the necessary measures and governing procedures to demonstrate that items subject to the provisions of the QAPD will perform satisfactorily in service, that the plant can be operated safely and as designed, and that the coordinated operation of the plant as a whole is satisfactory.

B. These programs include criteria for determining when testing is required, such as proof tests before installation, pre-operational tests, post-maintenance tests, post-modification tests, in-service tests, and operational tests (such as surveillance tests required by Plant Technical Specifications), to demonstrate that performance of plant systems is in accordance with design.

C. Programs also include provisions to establish and adjust test schedules, and to maintain status for periodic or recurring tests.

11.2 Testing Programs A. Tests are performed according to applicable procedures that include, consistent with the effect on safety: (1) instructions and prerequisites to perform the tests, (2) use of proper test equipment, (3) acceptance criteria, and (4) mandatory verification points as necessary to confirm satisfactory test completion.

B. Test results are documented and evaluated by the organization performing the test and reviewed by a responsible authority to assure that the test requirements have been satisfied.

1. If acceptance criteria are not met, re-testing is performed as needed to confirm acceptability following correction of the system or equipment deficiencies that caused the failure.

2. Test records, at a minimum, shall identify the item tested, date of test, tester or data recorder, type of observation, results and acceptability, action taken in connection with any deviations noted, and the person evaluating test results.

C. Except for computer program testing, which is addressed in QAPD, Part II, Section 11.3, tests are performed, and results documented in accordance with applicable technical and regulatory requirements, including those described in the Technical Specifications and the UFSAR.

D. Test programs ensure appropriate retention of test data in accordance with the records requirements of the QAPD.

E. Personnel that perform or evaluate tests are qualified in accordance with the requirements established in QAPD, Part II, Section 2.

11.3 Computer Program Testing TVA Nuclear establishes and implements provisions to assure that computer software used in applications affecting safety is prepared, documented, verified, and tested, and used such that the expected output is obtained, and configuration control maintained.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 43 11.4 NQA-1 Commitments A. In establishing provisions for testing, TVA Nuclear commits to compliance with ANSI/ANS 3.2-2012, Section 3.11, as endorsed by Regulatory Guide 1.33, Revision 3, with the following clarification: Instead of ANSI/ASME NQA-1-2008 and NQA-1a-2009 Addenda, TVA commits to NQA-1-2015, Part I, Requirement 11.

B. In establishing provisions for computer software, TVA Nuclear commits to compliance with the requirements of NQA-1-2015 Part I, Requirement 11, Section 400 and Part II, Subpart 2.7 to establish the appropriate provisions in addition to the commitment to NQA-1-2015, Part I, Requirement 3.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 44 SECTION 12 CONTROL OF MEASURING AND TEST EQUIPMENT 12.1 General Requirements A. TVA Nuclear has established the necessary measures and governing procedures to control the calibration, maintenance, and use of measuring and test equipment (M&TE) that provides data to verify acceptance criteria are met or provides information important to safe plant operation.

B. The provisions of such procedures cover equipment such as indicating and actuating instruments and gages, tools, reference and transfer standards, and NDE equipment.

C. The suppliers of commercial-grade calibration services are controlled as described in Part II, Subsection 7.2.

12.2 Measuring and Test Equipment Controls (This section does not apply to ESP activities.)

A. M&TE are calibrated, adjusted, and maintained at prescribed intervals, or prior to use, against certified equipment having known valid relationships to nationally recognized standards. If no nationally recognized standards exist, the bases for calibration are documented.

B. Appropriate documentation will be maintained for M&TE to indicate the control status, when the next calibration is due, and identify any limitations on use of the device.

C. A calibration is performed when the accuracy of the equipment is suspect.

D. When M&TE is found out of calibration, personnel shall:

1. tag or segregate, and not use the device until it is recalibrated.

2. make an evaluation and document the validity of previous inspection or test results, and the acceptability of items previously inspected or tested using the suspect M&TE.

E. Any measuring or test equipment consistently found out of calibration is repaired or replaced.

12.3 Installed Instrument and Control Devices TVA Nuclear has established and implements procedures for the calibration and adjustment of instrument and control (I&C) devices installed in the facility. The calibration and adjustment of these devices is accomplished through facility maintenance programs to ensure the facility is operated within design and technical requirements. The controls for M&TE are also applied to installed I&C devices. (This paragraph does not apply to ESP activities.)

12.4 NQA-1 Commitment In establishing provisions for control of measuring and test equipment, TVA Nuclear commits to compliance with ANSI/ANS 3.2-2012, Section 3.12, as endorsed by Regulatory Guide 1.33, Revision 3, with the following clarification: Instead of ANSI/ASME NQA-1-2008 and NQA-1a-2009 Addenda, TVA commits to NQA-1-2015, Part I, Requirement 12.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 45 SECTION 13 HANDLING, STORAGE, AND SHIPPING 13.1 Material Control Requirements A. TVA Nuclear has established the necessary measures and governing procedures to control the handling, storage, packaging, shipping, cleaning, and preservation of items to prevent inadvertent damage or loss, and to minimize deterioration. These provisions include specific procedures, when required, to maintain acceptable quality of the items important to the safe operations of the plant.

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

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

D. 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.

E. Special handling tools and equipment are used and controlled as necessary to ensure safe and adequate handling. Special handling tools and equipment are inspected and tested in accordance with procedures at specified time intervals or prior to use.

F. Operators of special handling and lifting equipment are experienced or trained in the use the equipment.

G. During the operational phase, TVA Nuclear establishes and implements controls over hoisting, rigging, and transport activities to the extent necessary to protect the integrity of the items involved, as well as potentially affected nearby structures and components.

Where required, TVA Nuclear complies with applicable hoisting, rigging and transportation regulations and codes.

13.2 Housekeeping A. Housekeeping practices are established to account for conditions or environments that could affect the quality of SSCs within the plant. This includes:

1. control of cleanliness of facilities and materials,

2. fire prevention and protection,

3. disposal of combustible material and debris,

4. control of access to work areas,

5. protection of equipment, and

6. radioactive contamination control and storage of solid radioactive waste.

B. Housekeeping practices help ensure that only proper materials, equipment, processes, and procedures are used, and that the quality of items is not degraded.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 46 C. Necessary procedures or work instructions, such as for electrical bus and control center cleaning, cleaning of control consoles, and radioactive decontamination are developed and used.

13.3 NQA-1 Commitment / Exceptions A. In establishing provisions for handling, storage, and shipping, TVA Nuclear commits to compliance with ANSI/ANS 3.2-2012, Section 3.13, as endorsed by Regulatory Guide 1.33, Revision 3, with the following clarification: Instead of ANSI/ASME NQA-1-2008 and NQA-1a-2009 Addenda, TVA commits to NQA-1-2015, Part I, Requirement 13.

B. TVA Nuclear also commits, during the construction and operational phase of the plant, to compliance with the requirements of NQA-1-2015, Part II, Subpart 2.1, Subpart 2.2, Subpart 2.3, and Part III, Subpart 3.2-2.1, with the following clarifications and exceptions:

NQA-1-2015, Part II, Subpart 2.1 NQA-1-2015, Part II, Subpart 2.1, Section 301 and 302 establish criteria for classifying items into cleanness classes and requirements for each class. Instead of using the cleanness level system of NQA-1-2015, Part II, Subpart 2.1, TVA Nuclear may establish cleanness requirements on a case-by-case basis, consistent with the other provisions of NQA-1-2015, Part II, Subpart 2.1. TVA Nuclear 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.

NQA-1-2015, Part II, Subpart 2.2

1. NQA-1-2015, Part II, Subpart 2.2, Section 201 establishes criteria for classifying items into protection levels. Instead of classifying items into protection levels during the operational phase, TVA Nuclear may establish controls for the packaging, shipping, handling, and storage of such items on a case-by-case basis with due regard for the items complexity, use, and sensitivity to damage. Prior to installation or use, the items are inspected and serviced as necessary to assure that no damage or deterioration exists which could affect their function.

2. NQA-1-2015, Part II, Subpart 2.2, Section 606, Storage Records: This section requires written records to be prepared containing information on personnel access to storage locations. As an alternative to this requirement, TVA Nuclear 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 of the applicable plant.

NQA-1-2015, Part II, Subpart 2.3 NQA-1-2015, Part II, Subpart 2.3, Section 202 requires the establishment of five zone designations for housekeeping cleanliness controls. Instead of the five-level zone designation, TVA Nuclear bases its control over housekeeping activities on a consideration of what is necessary and appropriate for the activity involved. The controls are implemented through procedures or instructions which, in the case of maintenance

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 47 or modification work, are developed on a case-by-case basis. Factors considered in developing the procedures and instructions include cleanliness control, personnel safety, fire prevention and protection, radiation control, and security. The procedures and instructions make use of standard janitorial and work practices to the extent possible.

NQA-1-2015, Part III, Subpart 3.2-2.1 NQA-1-2015, Part III, Subpart 3.2-2.1 provides guidance on the management of cleaning and cleanness control for fluid systems and associated components. TVA Nuclear commits to only Section 300, Cleaning Recommendations and Precautions. In addition, a suitable chloride stress-cracking inhibitor should be added to the fresh water used to flush systems containing austenitic stainless steels.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 48 SECTION 14 INSPECTION, TEST, AND OPERATING STATUS 14.1 General Requirements A. TVA Nuclear has established the necessary measures and governing procedures to identify the inspection, test, and operating status of items and components subject to the provisions of the QAPD in order to maintain personnel and reactor safety and avoid inadvertent operation of equipment.

1. Where necessary to preclude inadvertent bypassing of inspections or tests, or to preclude inadvertent operation, the inspection, test, or operating status must be verified before release, fabrication, receipt, installation, test, or use.

2. These measures also establish the necessary authorities and controls for the application and removal of status indicators or labels.

B. 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, and status tracking.

C. Administrative procedures also describe the measures taken to control altering the sequence of required tests, inspections, and other operations. 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 NQA-1 Commitment A. In establishing measures for control of inspection, test and operating status prior to operations, TVA Nuclear commits to NQA-1-2015, Part I, Requirement 14.

B. For operational units, TVA Nuclear commits to compliance with ANSI/ANS 3.2-2012, Section 3.14, as endorsed by Regulatory Guide 1.33, Revision 3, with the following clarification: Instead of ANSI/ASME NQA-1-2008 and NQA-1a-2009 Addenda, TVA commits to NQA-1-2015, Part I, Requirement 14.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 49 SECTION 15 CONTROL OF NONCONFORMING ITEMS 15.1 General Requirements A. TVA Nuclear has established the necessary measures and governing procedures to control items, including services that do not conform to specified requirements to prevent inadvertent installation or use.

1. Instructions require that the individual discovering a nonconformance identify, describe, and document the nonconformance in accordance with the requirements of QAPD, Part II, Section 16, Corrective Action.

2. Controls provide for identification, documentation, evaluation, segregation when practical, and disposition of nonconforming items, and for notification to affected organizations.

3. 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.

B. Item disposition, such as use-as-is, reject, repair, or rework shall be identified and documented.

C. Conditional release of nonconforming items for installation requires the approval of the designated management.

D. Nonconformances are corrected or resolved prior to depending on the item to perform its intended safety function.

E. Nonconformances are evaluated for impact on operability of quality SSCs to assure that the final condition does not adversely affect safety, operation, or maintenance of the item or service.

F. 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. The technical justification for acceptability of a nonconforming item, dispositioned repair or use-as-is, shall be documented.

G. Reworked, repaired, and replacement items shall be inspected and tested in accordance with the original inspection and test requirements or specified alternatives.

H. Nonconformance dispositions are reviewed for adequacy, analysis of quality trends, and reports provided to the designated management. Significant trends are reported to management in accordance with TVA Nuclear procedures, regulatory requirements, and industry standards.

15.2 Interface with the Reporting Program TVA Nuclear has appropriate interfaces with the reporting program for identification and control of nonconforming materials, parts, or components to satisfy the requirements of 10 CFR 21 during operations or for CRN ESP activities.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 50 15.3 NQA-1 Commitment In establishing measures for nonconforming materials, parts, or components, TVA Nuclear commits to compliance with ANSI/ANS 3.2-2012, Section 3.15, as endorsed by Regulatory Guide 1.33, Revision 3, with the following clarification: Instead of ANSI/ASME NQA-1-2008 and NQA-1a-2009 Addenda, TVA commits to NQA-1-2015, Part I, Requirement 15.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 51 SECTION 16 CORRECTIVE ACTION 16.1 General Requirements A. TVA Nuclear has established the necessary measures and governing procedures to promptly identify, control, document, classify, and correct conditions adverse to quality.

1. TVA Nuclear 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.

2. TVA Nuclear procedures require personnel to identify known conditions adverse to quality.

3. When complex issues arise where it cannot be readily determined if a condition adverse to quality exists, TVA Nuclear documents establish the requirements for documentation and timely evaluation of the issue.

B. Reports of conditions adverse to quality are analyzed to identify trends.

C. Significant conditions adverse to quality and significant adverse trends 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.

D. Adverse conditions shall be dispositioned by organizations with defined responsibility and authority; and shall be corrected in accordance with documented plans.

E. The satisfactory completion of corrective actions is verified and documented by the appropriate organization. Independent verification of corrective action implementation is performed as specified within the corrective action program.

F. In the case of suppliers working on safety related activities, or other similar situations, TVA Nuclear may delegate specific responsibilities for corrective actions, but TVA Nuclear maintains responsibility for the effectiveness of corrective action measures.

16.2 Interface with the Reporting Program TVA Nuclear has appropriate interfaces with the reporting program for corrective actions to satisfy the requirements of 10 CFR 21 during operations or for CRN ESP activities.

16.3 NQA-1 Commitment In establishing provisions for corrective action, TVA Nuclear commits to compliance with ANSI/ANS 3.2-2012, Section 3.16, as endorsed by Regulatory Guide 1.33, Revision 3, with the following clarification: Instead of ANSI/ASME NQA-1-2008 and NQA-1a-2009 Addenda, TVA commits to NQA-1-2015, Part I, Requirement 16.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 52 SECTION 17 QUALITY ASSURANCE RECORDS 17.1 General Requirements A. TVA Nuclear has the necessary measures and governing procedures to ensure that sufficient records of items and activities affecting quality are developed, reviewed, approved, issued, used, and revised to reflect completed work. The provisions of such procedures establish the scope of the record retention program.

B. The TVA Nuclear records program provides provisions for the administration, receipt, storage, preservation, safekeeping, retrieval, and disposition of all records.

C. All records must be identifiable, retrievable, maintained in a readable format, and safeguarded against equipment malfunction or human error.

D. Document access controls, user privileges, and other appropriate security controls are established.

17.2 Record Retention A. Sufficient records shall be maintained to furnish evidence of activities affecting quality.

B. Records of activities for design, engineering, procurement, construction, inspection and test, installation, pre-operation, startup, operations, maintenance, modification, decommissioning, and audits and their retention times are defined in appropriate procedures.

C. The records shall include at least the following: Operating logs and the results of reviews, inspections, tests, audits, monitoring of work performance, and materials analyses.

D. The records shall also include closely related data such as qualifications of personnel, procedures, and equipment.

E. Inspection and test records shall meet the requirements of NQA-1-2015, Part I, Requirement 11.

F. The records and retention times are based on:

1. Regulatory Position C.3.a.(1) for Lifetime Records and C.3.a.(2) for Non-permanent Records of Regulatory Guide 1.28, Revision 5 for design, construction, and initial start-up.

2. Regulatory Guide 1.33 Revision 3 for units in the operational phase.

G. Retention times for permanent and non-permanent operational phase records are based on construction records that are similar in nature. In cases where state, local, or other agencies have more restrictive requirements for record retention, those requirements will be met.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 53 17.3 Electronic Records A. TVA Nuclear will manage the storage of new QA Records in electronic media consistent with associated NIRMA Technical Guides (TG):

x TG11-2011, Authentication of Records and Media x

TG15-2011, Management of Electronic Records x

TG16-2011, Software Quality Assurance Documentation and Records x

TG21-2011, Required Records Protection, Disaster Recovery and Business Continuation B. TVA Nuclear will manage the storage of historical QA Records in electronic media consistent with the regulatory commitments and guidance in place at the time the records were created.

17.4 NQA-1 Commitment A. In establishing provisions for plant records management during operations, TVA Nuclear commits to compliance with ANSI/ANS 3.2-2012, Section 3.17, as endorsed by and subject to the conditions specified in Regulatory Guide 1.33, Revision 3, with the following clarification: Instead of references in ANS-3.2-2012 to ANSI/ASME NQA 2008 and NQA-1a-2009 Addenda, TVA commits to NQA-1-2015, Part I, Requirement

17.

B. In establishing provisions for plant records management for CRN ESP, TVA Nuclear commits to compliance with ANSI/ANS 3.2-2012, Section 3.17, as endorsed by and subject to the conditions specified in Regulatory Guide 1.28, Revision 5, including Regulatory Positions C.3.a.(1) and C.3.a.(2).

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 54 SECTION 18 AUDITS 18.1 General Requirements A. TVA Nuclear has established the necessary measures and governing procedures to verify that activities covered by the QAP are performed in conformance with the established requirements and performance criteria are met.

B. The quality assurance program is reviewed for effectiveness as part of the overall audit process.

C. Audits shall be scheduled on a formal preplanned audit schedule and in a manner to provide coverage and coordination with ongoing activities, based on the status and importance of the activity.

D. Trained personnel, not having direct responsibilities in the area being audited, conduct audits in accordance with preplanned and approved audit plans or checklists, under the direction of a qualified lead auditor and the cognizance of the General Manager, QA as documented in QAPD, Part II, Section 1.

E. Audit results are reported in writing to the CNO or designee, as appropriate. Additional internal distribution is made to other concerned management levels and to management of internal audited organizations or activities in accordance with approved procedures.

Conditions requiring prompt corrective action shall be reported immediately to the management of the audited organization.

F. Management responds to all audit findings and initiates corrective action where indicated. Where corrective action measures are indicated, documented follow-up of applicable areas through inspections, reviews, re-audits, or other appropriate means is conducted to verify implementation of assigned corrective action. Audits shall be performed with oversight as discussed in Section 18.4, Independent Evaluation of QA Functions.

18.2 Internal Audits A. Internal audits of activities, conducted prior to placing the facility in operation, should be performed in such a manner as to assure that an audit of all applicable QA program elements is completed for each functional area at least once each year or at least once during the life of the activity, whichever is shorter.

B. Internal audits of operational phase unit functional areas shall be scheduled based on the month in which the audit starts. All applicable quality assurance program elements for each functional area shall be audited with a nominal periodicity of 36 months. These functional area audits will evaluate:

1. the effective performance of activities required by the Nuclear Quality Assurance Program to meet the criteria of 10 CFR 50, Appendix B, and 10 CFR 72, Subpart G.

2. the conformance to provisions contained within the Technical Specifications and applicable regulations and license conditions.

3. the compliance with, and effective implementation of, internal rules and procedures (e.g., operating, design, procurement, maintenance, modification, refueling, surveillance, test, and radiation control procedures).

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 55

4. the effectiveness of personnel operating, refueling, maintaining, and modifying the plant with activities covered by the QAPD, including associated record keeping.

5. the effectiveness of training, retraining, qualification, and certification programs.

6. the results of actions taken to correct deficiencies occurring in site equipment, structures, systems, components, or method of operation that affect nuclear safety.

7. other activities and documents considered appropriate by the CNO or other responsible management.

C. Internal audits of operational phase units will be performed with a nominal periodicity of 36 months to verify, either as part of, or as an independent, functional area audit:

1. the fire protection equipment and program implementation, including loss prevention, utilizing either a qualified offsite licensed fire protection engineer or an outside, qualified, independent fire protection consultant. Qualification means the individual meets the eligibility requirements as a Member/Professional Grade in the Society of Fire Protection Engineers.

2. the performance of activities to meet the criteria of Regulatory Guide 4.1, Radiological Environmental Monitoring for Nuclear Power Plants, Rev. 2, June 2009.

3. the performance of activities to meet the criteria of Regulatory Guide 4.15, Quality Assurance for Radiological Monitoring Programs (Inception through Normal Operations to License Termination) - Effluent Streams and the Environment, Rev. 2, July 2007.

4. the performance of activities to meet the criteria of Regulatory Guide 1.21, Measuring, Evaluating, and Reporting Radioactive Materials in Liquid and Gaseous Effluents and Solid Wastes, Rev. 3, September 2021.

5. the performance of activities to meet the criteria of the Offsite Dose Calculation Manual and implementing procedures.

6. the performance of activities to meet the criteria of the TVA Nuclear Process Control Program and implementing procedures for solidification of wet radioactive wastes.

D. An annual evaluation shall be performed to determine the need for additional audit activities.

1. Evaluations are performed prior to the 12 and 24 month date following the last audit.

2. Evaluations should 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.

3. If an adverse trend is identified in the applicable functional area, additional audit activities shall be scheduled and performed as soon as practicable.

E. A maximum extension not to exceed 25 percent of the audit interval shall be allowed for internal functional area audits. When an internal audit interval extension greater than one month is used, the next audit for that particular audit area will be scheduled from the original anniversary month rather than from the month of the extended audit.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 56 F. Internal audits may also be used to meet the periodic regulatory review requirements for the Security, Emergency Preparedness, and Radiological Protection programs.

1. No interval extension is allowed for scheduled audits of Emergency Preparedness and Security (including Physical Security, Cyber Security, Access Authorization, Fitness for Duty and their implementing procedures).

2. Quality assurance assessments may be used to validate audit periodicity when allowable by regulations.

18.3 External (Supplier) Audits A. Audits of suppliers of safety related components and/or services are conducted as described in Part II, Subsection 7.1.

B. A grace period of 90 days may be applied to scheduled supplier audits and annual evaluations of supplier performance.

1. When the 90 day grace period is used, the next scheduled date for the activity shall be based on the activity schedule date and not on the date the activity was actually performed.

2. If the activity is performed early, the next schedule date shall be based on the date the activity was actually performed.

C. TVA Nuclear may apply an extension, not to exceed 25 percent of the audit interval, to contractor/supplier audits or surveys that are normally of triennial frequency under extenuating circumstances (such as declaration of a national emergency; severe localized or national weather conditions or damage to TVA Nuclear or TVA Nuclear suppliers infrastructure; or localized outbreak of a severe health concern to the public and TVA Nuclear).

18.4 Independent Evaluation of QA Functions A. A periodic evaluation of the status and adequacy of the QAP is performed by an independent organization to assure that audits, quality control activities and maintenance of this document (QA Program Description) are being accomplished to program requirements. This periodic evaluation will also include the independent review process as defined in Part V, Section 2, Subsection 2.2.

1. The periodic evaluation will include all sites and are nominally scheduled at a 36 month frequency with a 25 percent grace allowed.

2. The evaluation team consists of qualified individuals, none of which are responsible for the areas evaluated.

3. The evaluation is performed with pre-approved checklists, instructions, or plans.

4. The team conducts a post-evaluation conference with the responsible management of the areas evaluated to discuss the results, including deficiencies.

5. The team prepares a report, which is sent to the General Manager, QA. The General Manager, QA submits the results of this evaluation to the CNO.

6. General Manager, QA or responsible management of the evaluated area determines the need for corrective action and re-evaluation. Necessary corrective action and

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 57 re-evaluation are performed as required.

7. Pertinent correspondence and reports related to the evaluation are filed.

B. A self-assessment will be performed once per calendar year between independent evaluations to identify program weaknesses and determine the need for corrective action or additional audit activities.

18.5 NQA-1 Commitment / Exceptions In establishing the independent audit program for operating units, TVA Nuclear commits to compliance with ANSI/ANS 3.2-2012, Section 3.18, as endorsed by Regulatory Guide 1.33, Revision 3, with the following clarification: Instead of ANSI/ASME NQA-1-2008 and NQA-1a-2009 Addenda, TVA commits to NQA-1-2015, Part I, Requirement 18 with the following clarifications and exceptions:

A. Section 201, Internal Audits - TVA Nuclear may apply a 36 month periodicity for internal audits of 10 CFR 50, Appendix B activities. The 36 month periodicity does not apply to activities where specific regulatory guidance or restrictions regarding audit frequencies apply.

B. Section 201, Internal Audits - TVA Nuclear may apply an extension, not to exceed 25 percent of the audit interval as follows:

1. Audits shall be performed at the intervals designated for each audit area. Schedules shall be based on the month in which the audit starts.

2. No extensions are allowed for scheduled audits of Emergency Preparedness, Security, Cyber Security, Access Authorization, or Fitness for Duty.

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

C. Section 202, External Audits - TVA Nuclear may apply an extension, not to exceed 25 percent of the audit interval, to contractor/supplier audits or surveys that are normally of triennial frequency where performance of the audit or survey is not feasible. The end of the audit or survey will determine the date of the next triennial audit or survey.

1. Application of the 25 percent extension is limited to extenuating circumstances, which include, but are not limited to:

a. the declaration of a national emergency.

b. severe localized or national weather conditions or damage to TVA Nuclear or TVA Nuclear suppliers infrastructure; or

c. localized outbreak of a severe health concern to the public and TVA Nuclear.

2. Continued use of TVA Nuclear suppliers that have exceeded the maximum allowed audit or survey time due to extenuating circumstances is allowed if the following conditions are met:

a. A documented evaluation must be performed to summarize why the audit or survey could not be performed prior to the end of the 90-day grace period and to provide the basis for maintaining the supplier as an approved supplier during the

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 58 25% (9 month) grace period. While implementing procedures must describe elements to be included in the documented evaluation, the following items should be considered as applicable:

1) For 10 CFR 50, Appendix B suppliers, verification that the suppliers quality assurance program is still committed to meeting the requirements of 10 CFR 50, Appendix B.

2) For commercial suppliers who are approved based on commercial grade survey, verification the supplier has maintained adequate documented programmatic controls in place for the activities affecting the critical characteristics of the item/services being procured.

3) Evaluation of any significant open issues with the NRC, 10 CFR 21 Notifications, and any open findings since the previous triennial audits describing impact on the items/services being procured from that supplier.

4) Review of procurement history since last triennial audit/survey including receipt inspection results to identify any potential issues. The results of the performance history must be included in the evaluation.

5) The degree of standardization of the items being procured. For instance, suppliers of catalog items which are used across multiple industries with widely accepted good performance histories would be considered good candidates for a 25% (9 month) grace period.

b. If concerns are identified based on the above evaluation, the following mitigating actions may be considered:

1) the performance of enhanced receiving inspections beyond visual inspections and quality checks.

2) the identification of any additional requirements/restrictions to be placed on the supplier.

c. For audits/surveys performed during the 25% grace period, the audit/survey shall include a review of activities performed by the supplier since the 36 month audit/survey expiration date.

d. The allowance would only apply to existing suppliers on the TVA Nuclear ASL.

e. The 25% grace period discussed above is applicable to domestic and international suppliers.

f.

For audits/surveys performed during the 25% grace period, the audit/survey clock does not have to reset backwards to the original expiration date for which the audit/survey should have been performed. The end of the audit or survey would determine the date of the next triennial audit/survey.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 59 PART III NON-SAFETY RELATED STRUCTURES, SYSTEMS, AND COMPONENTS (SSC) QUALITY CONTROL SECTION 1 NON-SAFETY RELATED SSCS WITH SPECIAL TREATMENT 1.1 General A. TVA Nuclear assures a high degree of availability and reliability for its nuclear plants while ensuring the health and safety of its workers and the public. Requirements for quality related SSCs and activities provide reasonable assurance that the facility can be operated without undue risk to the health and safety of the public.

B. The following clarify the applicability of the QA Program to the non-safety related SSCs with special treatment and related activities, including the identification of exceptions to the QA Program described in QAPD, Part II, Sections 1 through 18 taken for non-safety related SSCs with special treatment.

1.2 Quality Related SSCs SSCs classified as safety related are subject to the requirements of 10 CFR 50, Appendix B and this QAPD. The QAPD is also applied in a graded manner to certain quality related SSCs that are not clearly defined as safety related.

1.3 Quality Related Programs and Activities A. The QAPD is applied in a graded manner to certain quality related programs and activities that are not clearly defined as safety related. TVA shall apply the requirements of all or selected parts of the QAPD to quality related programs and activities to a degree consistent with their importance to safety. Implementing procedures shall define the extent to which the QAPD shall apply to applicable quality related programs and activities. The programs and activities for which the QAPD applies include:

1. health physics and ALARA (As Low As Reasonably Achievable)

2. the control and transport of radioactive waste

3. environmental services

4. aging management programs (for non-safety related SSCs)

5. emergency planning

6. meteorology and radiological environmental monitoring

7. physical security and cybersecurity

8. nuclear plant repairs and alterations

9. low safety significant components with alternate treatment under 10 CFR 50.69, Risk-informed Categorization and Treatment of Structures, Systems, and Components, for Nuclear Power Reactors.

B. Unless otherwise noted, reviews of the program or activity content and implementation are performed during internal functional area or regulatory audits; deficiencies are addressed in accordance with the corrective action program; and program records of audits and reviews are maintained as required.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 60 1.4 Applicability of the QAPD TVA Nuclear shall apply the requirements of all or selected parts of the QAPD to quality related SSCs, programs and activities to a degree consistent with their importance to safety.

General guidelines are below. Organizations shall designate those quality related SSCs, programs and activities for which they are responsible, and define the graded applicability of the QAPD in their implementing procedures.

A. Organization The verification activities described in this part may be performed by the TVA Nuclear line organization. The QA organization described in Part II is not required to perform these functions.

B. QA Program TVA Nuclear QA requirements for non-safety related SSCs are established in 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.

C. Design Control TVA Nuclear has design control measures to ensure that the contractually 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 work.

D. Procurement Document Control TVA Nuclear obtains items and services using procurement documents, that 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.

E. Instructions, Procedures, and Drawings TVA Nuclear 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.

F. Document Control TVA Nuclear 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.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 61 G. Control of Purchased Items and Services TVA Nuclear 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.

H. Identification and Control of Purchased Items TVA Nuclear 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.

I.

Control of Special Processes TVA Nuclear 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.

J. Inspection TVA Nuclear 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.

K. Test Control TVA Nuclear 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.

L. Control of Measuring and Test Equipment TVA Nuclear employs measures to control M&TE use, and calibration and adjustment at specific intervals or prior to use.

M. Handling, Storage, and Shipping TVA Nuclear 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.

N. Inspection, Test, and Operating Status TVA Nuclear 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.

O. Control of Nonconforming Items TVA Nuclear employs measures to identify and control items that do not conform to specified requirements to prevent their inadvertent installation or use.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 62 P. Corrective Action TVA Nuclear employs measures to ensure that failures, malfunctions, deficiencies, deviations, defective components, and nonconformances are properly identified, reported, and corrected.

Q. Records TVA Nuclear 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.

R. Audits TVA Nuclear employs measures for line management to periodically review and document the adequacy of the suppliers process, including taking any necessary corrective action. Audits independent of line management are not required. Line management is 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 part (Part III) are implemented by the same programs, processes, or procedures as the comparable activities of Part II, the audits performed under the provisions of Part II may be used to satisfy the review requirements of this Section (Part III, Section 1.4.R).

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 63 SECTION 2 NON-SAFETY RELATED STRUCTURES, SYSTEMS, AND COMPONENTS 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.

x TVA Nuclear implements quality requirements for the fire protection system in accordance with Fire Protection Reports for each operating site which have been approved by the Nuclear Regulatory Commission and implemented for the respective site.

x TVA Nuclear implements the quality requirements for non-safety related, safety significant ATWS equipment in accordance with Part III, Section 1.

x TVA Nuclear implements quality requirements for non-safety related, safety significant SBO equipment in accordance with Part III, Section 1.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 64 PART IV REGULATORY COMMITMENTS Part IV identifies the NRC Regulatory Guides (RG) and the other quality assurance standards which have been selected to supplement and support the TVA Nuclear Fleet QAPD. TVA Nuclear complies with these standards to the extent described or referenced. Commitment to a particular RG or standard does not constitute a commitment to other RGs or standards that may be referenced therein.

SECTION 1 NRC Regulatory Guides and Quality Assurance Standards 1.1 Regulatory Guides x

Regulatory Guide 1.8, Rev. 4, June 2019, Qualification and Training of Personnel for Nuclear Power Plants Regulatory Guide 1.8, Rev. 4 provides guidance that is acceptable to the NRC staff regarding qualifications and training for nuclear power plant personnel. It endorses ANSI/ANS 3.1 - 2014, Selection, Qualification, and Training of Personnel for Nuclear Power Plants, subject to guidance included in the Regulatory Guide. TVA Nuclear will conform with Regulatory Guide 1.8, Rev. 4 and comply with the staffs regulatory guidance for meeting the conditions described on the use of ANSI/ANS 3.1 - 2014.

x Regulatory Guide 1.26, Quality Group Classifications and Standards for Water-, Steam-,

And Radioactive-Waste-Containing Components of Nuclear Power Plants Regulatory Guide 1.26 defines classification systems and components.

TVA Nuclear will maintain existing commitments to Regulatory Guide 1.26 as specified in each plants UFSAR. The commitment to Regulatory Guide 1.26 is site specific, as required by the approved UFSAR/License at each site. A change to a newer version of the regulatory guide for operating TVA Nuclear plants would require significant analysis and potential backfit of design information used in the development of the quality classifications for TVA Nuclear plants, which is not practical or necessary. TVA Nuclear will maintain existing commitment to Regulatory Guide 1.26, Revision 4, for CRN ESP.

x Regulatory Guide 1.28, Rev. 5, October 2017, Quality Assurance Program Criteria (Design and Construction)

Regulatory Guide 1.28, Rev. 5 describes a method acceptable to the NRC staff for complying with the provisions of 10 CFR 50, Appendix B with regard to establishing and implementing the requisite quality assurance program for the design and construction of nuclear power plants. It endorses ASME NQA-1-2015, Quality Assurance Requirements for Nuclear Facility Applications, subject to guidance included in the Regulatory Guide. TVA Nuclear will conform with Regulatory Guide 1.28, Rev. 5 and comply with the staffs regulatory guidance for meeting the conditions described on the use of ASME NQA-1-2015.

x Regulatory Guide 1.29 - Seismic Design Classification for Nuclear Power Plants Regulatory Guide 1.29 defines light water reactor systems required to withstand a safe shutdown earthquake (SSE).

TVA Nuclear will maintain existing commitments to Regulatory Guide 1.29 as specified in each plants UFSAR. The commitment to Regulatory Guide 1.29 is site specific, as required by the approved UFSAR/License at each site. TVAs current seismic program procedure,

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 65 NEDP-9, complies with Regulatory Guide 1.29, Seismic Design Classification, and Regulatory Guide 1.100, Seismic Qualification of Electric Equipment for Nuclear Power Plants. A change to a newer version of the regulatory guide would require significant analysis and potential backfit of design information used in the development of the quality classifications for TVA Nuclear plants, which is not practical or necessary for the current operational phase of TVA Nuclear plants. TVA Nuclear will maintain existing commitment to Regulatory Guide 1.29, Revision 5, for CRN ESP.

x Regulatory Guide 1.33, Rev. 3, June 2013, Quality Assurance Program Requirements (Operations)

Regulatory Guide 1.33, Rev. 3 describes a method acceptable to the NRC staff for complying with the Commission's regulations with regard to overall quality assurance program requirements for the operation phase of nuclear power plants. Revision 3 of the Regulatory Guide endorses standard ANSI/ANS 3.2-2012, Managerial, Administrative, and Quality Assurance Controls for the Operational Phase of Nuclear Power Plants, subject to guidance included in the Regulatory Guide. TVA Nuclear will conform with Regulatory Guide 1.33, Rev. 3 and comply with the staffs regulatory guidance for meeting the conditions described on the use of ANSI/ANS 3.2-2012.

x Regulatory Guide 1.36, Rev. 1, May 2015, Nonmetallic Thermal Insulation for Austenitic Stainless Steel Regulatory Guide 1.36, Rev. 1 describes methods acceptable to the NRC staff for the selection and use of nonmetallic thermal insulation to minimize any contamination that could promote stress-corrosion cracking in the stainless-steel portions of the reactor coolant pressure boundary and other systems important to safety. TVA Nuclear will conform with Regulatory Guide 1.36, Rev. 1.

x Regulatory Guide 1.54, Service Level I, II, and III Protective Coatings Applied to Nuclear Power Plants Regulatory Guide 1.54 describes a method acceptable to the NRC staff for the selection, application, qualification, inspection, and maintenance of protective coatings applied to Nuclear Power Plants.

TVA Nuclear will maintain existing commitments to Regulatory Guide 1.54 Rev. 0 for previously applied coatings in existing TVA Nuclear plants, which were designed and constructed to RG 1.54, Rev. 0. However, TVA Nuclear commits to RG 1.54, Rev. 3, for application of new coatings.

x Regulatory Guide 1.64, Rev. 2, June 1976, Quality Assurance Requirements for the Design of Nuclear Power Plants Regulatory Guide 1.64, Rev. 2 provides guidance for the quality assurance requirements for design of all types of nuclear power plants. It endorses standard ANSI N45.2.11-1974 subject to guidance included in the Regulatory Guide.

TVA Nuclear will maintain existing commitments to Regulatory Guide 1.64 Rev. 2 for existing TVA Nuclear plants, which were designed to RG 1.64, Revision 2.

x Regulatory Guide 1.94, Rev. 1, April 1976, Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 66 the Construction Phase of Nuclear Power Plants Regulatory Guide 1.94, Rev. 1 provides guidance for the quality assurance requirements for installation, inspection, and testing of structural concrete and structural steel during the construction phase of nuclear power plants. It endorses standard ANSI N45.2.5-1974 subject to guidance included in the Regulatory Guide.

TVA Nuclear will maintain existing commitments to Regulatory Guide 1.94 Rev. 1 for existing TVA Nuclear plants, which were constructed to RG 1.94, Revision 1. Conforming with NQA-1-2015 Part II, Subpart 2.5 is not practical or necessary for the current operational phase of existing TVA Nuclear plants.

x Regulatory Guide 1.116, Rev. 0-R, June 1976, Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems Regulatory Guide 1.116 Rev. 0-R provides guidance for the quality assurance requirements for installation, inspection, and testing of mechanical systems and equipment. It endorses standard N45.2.8-1975 subject to guidance included in the Regulatory Guide.

TVA Nuclear will maintain existing commitments to Regulatory Guide 1.116 Rev. 0-R for constructed nuclear plants.

x Regulatory Guide 1.152, Rev. 4, July 2023, Criteria for Programmable Digital Devices in Safety-Related Systems of Nuclear Power Plants Regulatory Guide 1.152, Rev. 4 describes a method that the NRC staff deems acceptable for complying with the Commissions regulations for promoting high functional reliability, design quality, and a secure development and operational environment (SDOE) for the use of digital computers in the safety systems of nuclear power plants. TVA Nuclear will conform with Regulatory Guide 1.152, Rev. 4.

x Regulatory Guide 1.164, Rev. 0, June 2017, Dedication of Commercial-Grade Items for Use in Nuclear Power Plants Regulatory Guide 1.164, Rev. 0 provides guidance for dedication of commercial-grade items and services used in nuclear power plants. This RG endorses, in part, the Electric Power Research Institute (EPRI) 3002002982, Revision 1 to EPRI NP-5652 and TR-102260, Plant Engineering: Guideline for the Acceptance of Commercial-Grade Items in Nuclear Safety Related Applications, with respect to acceptance of commercial-grade dedication of items and services to be used as basic components for nuclear power plants. TVA Nuclear will conform with Regulatory Guide 1.164, Rev 0.

x Regulatory Guide 1.231, Rev. 0, January 2017, Acceptance of Commercial-Grade Design and Analysis Computer Programs Used in Safety-Related Applications for Nuclear Power Plants Regulatory Guide 1.231, Rev. 0 provides guidance for the use of Revision 1 of EPRI Technical Report 1025243, Plant Engineering: Guideline for the Acceptance of Commercial-Grade Design and Analysis Computer Programs Used in Nuclear Safety Related Applications, with respect to acceptance of commercial-grade design and analysis computer programs associated with basic components for nuclear power plants. TVA Nuclear will conform with Regulatory Guide 1.231, Rev. 0.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 67 x

Regulatory Guide 1.234, Rev. 0, April 2018, Evaluating Deviations and Reporting Defects and Noncompliance Under 10 CFR 21.

Regulatory Guide 1.234, Rev. 0 provides guidance on an acceptable method of evaluating and reporting defects under 10 CFR 21. This guidance will aid in minimizing compliance challenges to licensees and vendors that have been identified through inspection activities.

This guide endorses Nuclear Energy Institute (NEI) 14-09, Guidelines for Implementations of 10 CFR 21 Reporting of Defects and Noncompliance, Revision 1. TVA Nuclear will conform with Regulatory Guide 1.234, Rev. 0.

1.2 Standards x

ASME NQA-1-2015 - Quality Assurance Requirements for Nuclear Facility Applications TVA Nuclear commits to NQA-1-2015, Parts I and II, as described in Parts II and V of this document with specific identification of exceptions or clarifications. TVA Nuclear commits to NQA-1-2015, Parts III and IV only as specifically noted in Parts II and V of this document.

x ANSI/ANS 3.1-2014, Selection, Qualification, and Training of Personnel for Nuclear Power Plants TVA Nuclear commits to ANSI/ANS 3.1-2014, as described in this document, subject to the guidance included in Regulatory Guide 1.8, Rev. 4. TVA Nuclear commits to compliance with ANSI/ANS 3.1-2014 and will comply with the staffs regulatory guidance, with specific identification of exceptions or clarifications.

x ANSI/ANS 3.2-2012 - Managerial, Administrative, and Quality Assurance Controls for the Operational Phase of Nuclear Power Plants TVA Nuclear commits to ANSI/ANS 3.2-2012, as described in this document, subject to the guidance included in Regulatory Guide 1.33, Rev. 3. TVA Nuclear commits to compliance with ANSI/ANS 3.2-2012 and will comply with the staffs regulatory guidance, with specific identification of exceptions or clarifications.

x ANSI N45.2.5-1974 - Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants TVA Nuclear commits to ANSI N45.2.5-1974 for existing TVA Nuclear plants, subject to the guidance included in Regulatory Guide 1.94, Rev. 1.

x ANSI N45.2.8-1975 - Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for the Construction Phase of Nuclear Power Plants TVA Nuclear commits to ANSI N45.2.8-1975 for existing TVA Nuclear plants, subject to the guidance included in Regulatory Guide 1.116 Rev. 0-R.

x ANSI N45.2.11-1974 - Quality Assurance Requirements for the Design of Nuclear Power Plants TVA Nuclear commits to N45.2.11-1974 for existing TVA Nuclear plants, subject to the guidance included in Regulatory Guide 1.64, Rev. 2.

x ANSI N101.4-1972, Quality Assurance for Protective Coatings Applied to Nuclear Facilities

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 68 TVA Nuclear commits to ANSI N101.4-1972, subject to the guidance included in Regulatory Guide 1.54, Rev. 0. TVA Nuclear commits to compliance with ANSI N101.4-1972 and will comply with the staffs regulatory guidance, with specific identification of exceptions or clarifications for previously applied coatings in current nuclear plants. TVA Nuclear commits to RG 1.54, Rev. 3, which endorses ASTM D5144-08 for application of new coatings.

x NEI 14-05A, Guidelines for the Use of Accreditation in Lieu of Commercial Grade Surveys for Procurement of Laboratory Calibration and Test Services, Revision 1.

In establishing controls for purchased items and services, TVA Nuclear commits to compliance with NQA-1-2015, Part I, Requirement 7, as described in QAPD, Part II, Section 7.2.

x Nuclear Information and Records Management Association, Inc. (NIRMA) Technical Guides (TGs)

TVA Nuclear commits to NIRMA TGs as described in QAPD, Part II, Section 17.3.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 69 PART V ADDITIONAL QUALITY ASSURANCE AND ADMINISTRATIVE CONTROLS FOR THE PLANT OPERATIONAL PHASE TVA Nuclear includes the requirements of Part V that follow when establishing the necessary measures and governing procedures for the operational phase of the plant. Implementation of the additional controls in this section shall apply 30 days prior to initial fuel load for COL holders in accordance with 10 CFR 50.54(a)(1) and 90 days prior to initial fuel load for construction permit holders.

SECTION 1 DEFINITIONS TVA Nuclear uses the definitions of terms as provided in Section 400 of the Introduction of NQA-1-2015, and ANSI/ANS 3.2-2012, Section 2 in interpreting the requirements of NQA-1 and the other standards to which the QAPD commits. In addition, definitions are provided for the following terms not covered in NQA-1-2015 or ANS 3.2-2012:

administrative controls: rules, orders, instructions, procedures, policies, practices, and designations of authority and responsibility 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 (see review) nuclear power plant: any plant using a nuclear reactor to produce electric power, process steam, or provide space heating.

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

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

operational phase: that period of time during which the principal activity is associated with normal operation of the plant. This phase of plant life is considered to begin formally with commencement of initial fuel loading, and ends with plant decommissioning.

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

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

surveillance testing: periodic testing to verify that safety related structures, systems, and components continue to function or are in a state of readiness to perform their functions.

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

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 70 SECTION 2 REVIEW OF ACTIVITIES AFFECTING SAFE PLANT OPERATION 2.1 Onsite Review Committee A. The TVA Nuclear onsite organization employs reviews, both periodic and as situations demand, to evaluate plant operations and plan future activities.

B. The Onsite Review Committee (ORC) is a multi-disciplined committee responsible for providing an oversight review of documents required for the safe operation of the plant.

The ORC advises the Nuclear Plant Manager on matters related to nuclear safety.

C. The important elements of the reviews are documented and subjects of potential concern for the independent review described below are brought to the attention of operations management. The reviews are part of the normal duties of plant supervisory personnel in order to 1) provide timely and continuing monitoring of operating activities to assist the Nuclear Plant Manager in keeping abreast of general plant conditions, and

2) to verify that day-to-day operations are conducted safely in accordance with the established administrative controls.

D. The manager responsible for Operations Phase Management ensures the timely referral of the applicable matters discussed in the reviews to appropriate management and independent reviewers.

E. The ORC shall function to advise the Nuclear Plant Manager in matters related to nuclear safety. This advisory function shall be performed by the ORC acting in a formal meeting periodically and as situations demand.

F. The ORC shall be organized, and conduct business as described below.

G. The Nuclear Plant Manager shall appoint the Chairperson and members in writing.

H. ORC members shall meet the experience requirements of ANSI/ANS 3.1-2014 as endorsed by Regulatory Guide 1.8, Revision 4, Qualification and Training of Personnel for Nuclear Power Plants. This applies to the correlated ANSI/ANS 3.1-2014 Manager or Supervisor position for the represented organization. (Operations representatives who hold or who have held Senior Reactor Operator (SRO) licenses at the station are considered qualified.)

I.

Composition. The composition of ORC shall be as follows:

Chairperson: Director, Operations Member:

operations representative(s)

Member:

maintenance representative(s)

Member:

chemistry control representative(s)

Member:

radiological protection representative(s)

Member:

engineering representative(s)

J. Meeting Frequency The ORC meets commensurate with the scope of activities, but minimal frequency requirements are specified in procedures.

K. Quorum

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 71 Rules for a quorum are established and adhered to. However, no more than a minority of alternates may participate as voting members at any one time.

L. Review Topics In performing its independent review responsibilities, the ORC reviews:

1. proposed changes to the facility as described in the UFSAR. This review is to confirm that the change does not adversely affect safety and if a Technical Specification change or NRC review is required.

2. proposed changes to procedures as described in the UFSAR and tests or experiments not described in the UFSAR. This review is to confirm that the change does not adversely affect safety and if a Technical Specification change or NRC review is required.

3. proposed Technical Specifications changes and license amendments, except in those cases where the change is identical to a previously reviewed proposed change.

4. Licensee Event Reports that were made to the NRC. This review includes results of any investigations made and recommendations resulting from such investigations to prevent or reduce the probability of recurrence of the event.

5. any other matter related to nuclear safety requested by the Site Vice President for each nuclear site, Nuclear Plant Manager, selected by ORC members, or referred for review by other organizations.

The ORC also reviews changes to site documents including but not limited to the Offsite Dose Calculation Manual (ODCM), the Process Control Program (PCP), the Emergency Plan, and the Security Plan.

The ORC conducts special reviews and investigations as requested by the Site executive or Nuclear Plant Manager.

M. Authority

1. The ORC may establish subcommittees or use designated organizational units to carry out the review. The subcommittees or organizational units regularly report results of reviews for full committee consideration and may recommend items for full committee review as warranted. Additionally, the reviews by the ORC recognize that the QA Program requires independent technical reviews to be completed including but not limited to design verification and reviews of procedures. Those independent technical reviews are conducted commensurate with the item or activities importance to nuclear safety. In conducting its review, the ORC is not required to independently reperform such reviews.

2. The ORC:

x recommends to the Nuclear Plant Manager approval or disapproval of items reviewed.

x renders determinations with regards to whether items (1) through (3) adversely affect safety and if a Technical Specification change or NRC review is required.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 72 x

provides written notification to the Site Vice President of any disagreements between the ORC and the Nuclear Plant Manager.

3. The ORC advises the Nuclear Plant Manager on matters related to safe operation and overall performance. The Committee has authority to obtain access to records and personnel as needed to conduct reviews.

N. Records The ORC maintains written minutes of each Committee meeting, to include identification of items reviewed, and decisions and recommendations of the Committee. Copies of the minutes are provided to the Site Vice President, and to other onsite and offsite management responsible for the areas reviewed as necessary. ORC records are retained according to Section 17, Quality Assurance Records.

2.2 Independent Review The independent review function is provided through a combination of the ORC, QA organization, and the line organization executing the QA program.

A. Reviews of the independent review subjects are performed by the ORC as described in Section 2.1, Onsite Review Committee.

B. Reviews of audit reports, identified in ASME NQA-1-2015, Part I, Requirement 18, are performed by management of the audited area and QA management instead of the independent review function.

C. Reviews of the corrective actions for significant conditions adverse to quality are performed by appropriate management as described in Section 18.4, Independent Evaluation of QA Functions. Collectively, the ORC and the QA audit function perform the independent review, identified in ANS 3.2-2012, Section 3.2.2.2, for significant conditions adverse to quality.

Collectively, the above independent review functions meet the guidance in ANS 3.2-2012, Section 3.2.2.3 and Standard Review Plan 17.5, Quality Assurance Program Description -

Design Certification, Early Site Permit and New License Applicants, Option I, for an independent review body.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 73 SECTION 3 OPERATIONAL PHASE PROCEDURES The following is a description of the various types of procedures used by TVA Nuclear to govern the design, operation, and maintenance of its nuclear generating plants. TVA Nuclear follows the guidance of ANSI/ANS 3.2-2012 as endorsed by Regulatory Guide 1.33, Rev. 3 in identifying the types of activities that should have procedures or instructions to control the activity. Each procedure shall be sufficiently detailed for a qualified individual to perform the required function without direct supervision, but need not provide a complete description of the system or plant process.

3.1 Format and Content For procedure format and content, TVA Nuclear is committed to ANS 3.2-2012, Section 3.5.2, paragraphs 3.5.2.1 through 3.5.2.9.

3.2 Procedure Types Plant procedures provide instructions for controlling plant activities. For plant procedures and their characteristics, TVA Nuclear is committed to ANS 3.2-2012, Section 3.5.3, paragraphs 3.5.3.1 through 3.5.3.19, and as modified below.

A. Plant Security and Visitor Control Procedures or instructions 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.

B. Configuration Management Procedures These documents provide instructions for the responsibility and authority for functions that affect the configuration of the facility including activities such as operations, design, maintenance, construction, licensing, and procurement. TVA Nuclear shall establish and document a time or event when configuration management shall be established for the facility.

C. System Procedures In addition to the requirements of ANS 3.2-2012, appropriate procedures will also be developed for the fire protection program.

Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan TVA-NQA-PLN89-A, Revision 43, August 2024 74 SECTION 4 PLANT MAINTENANCE 4.1 TVA Nuclear establishes controls for the maintenance or modification of items and equipment subject to this QAPD to ensure quality at least equivalent to that specified in original design bases and requirements, such that safety related structures, systems, and components are maintained in a manner that assures their ability to perform their intended safety function(s).

4.2 Maintenance activities (both corrective and preventive) are scheduled and planned so as not to unnecessarily compromise the safety of the plant.

4.3 In establishing controls for plant maintenance, TVA Nuclear commits to compliance with:

x NQA-1-2015, Part II, Subpart 2.15 and Subpart 2.18, with the following clarification:

Section 203 requires cleanliness during maintenance to be in accordance with NQA-1-2015, Part II, Subpart 2.1. The commitment to NQA-1-2015, Part II, Subpart 2.1 is described in QAPD, Part II, Section 13.3.

x ANS 3.2-2012, Section 3.2.4 as endorsed by RG 1.33, Rev. 3.

CNL-24-060 Comparison of Existing NRC Regulatory Guide Commitments to NRC Regulatory Guide Commitments Adopted in the Proposed Quality Assurance Plan Description Comparison of Existing NRC Regulatory Guide (RG) Commitments to NRC RG Commitments Adopted in the Proposed QAPD CNL-24-060 E1 A2 1 of 5 Current Regulatory Guide Commitment Current Standard Proposed Regulatory Commitment Proposed Standard Basis 1.21 (R1)

Measuring, Evaluating, and Reporting Radioactive Material in Liquid and Gaseous Effluents and Solid Waste N/A RG 1.21 (R3)

N/A TVA will commit to Regulatory Guide 1.21 Revision 3 (9/2021).

1.26 Quality Group Classifications and Standards for Water-, Steam-, And Radioactive-Waste-Containing Components of Nuclear Power Plants N/A No Change N/A TVA Nuclear will maintain existing commitments to Regulatory Guide 1.26 as specified in each plants UFSAR. The commitment to Regulatory Guide 1.26 is site specific, as required by the approved UFSAR/License at each site. A change to a newer version of the regulatory guide would require significant analysis and potential backfit of design information used in the development of the quality classifications for TVA Nuclear plants, which is not practical or necessary for the current operational phase of TVA Nuclear plants. TVA Nuclear will maintain existing commitment to Regulatory Guide 1.26, Revision 4, for CRN ESP.

1.28 (R3-Fleet, R4-CRN ESP)

Quality Assurance Program Requirements (Design and Construction)

ANSI N45.2-1971 RG 1.28 (R5)

NQA-1-2015 TVA will not maintain its commitment to Regulatory Guide 1.28 Revision 3 (8/1985) for the TVA Fleet and Revision 4 (06/2010) for CRN ESP.

TVA will commit to Regulatory Guide 1.28 Revision 5 (10/2017) endorsing NQA-1-2015.

1.29 Seismic Design Classification N/A No Change N/A TVA Nuclear will maintain existing commitments to Regulatory Guide 1.29 as specified in each plants UFSAR. The commitment to Regulatory Guide 1.29 is site specific, as required by the approved UFSAR/License at each site. TVAs current seismic program procedure, NEDP-9, complies with Regulatory Guide 1.29, Seismic Design Classification, and Regulatory Guide 1.100, Seismic Qualification of Electric Equipment for Nuclear Power Plants. A change to a newer version of the regulatory guide would require significant analysis and potential backfit of design information used in the development of the quality classifications for TVA Nuclear plants, which is not practical or necessary for the current operational phase of TVA Nuclear plants. TVA Nuclear will maintain existing commitment to Regulatory Guide 1.29, Revision 5, for CRN ESP.

Comparison of Existing NRC Regulatory Guide (RG) Commitments to NRC RG Commitments Adopted in the Proposed QAPD CNL-24-060 E1 A2 2 of 5 Current Regulatory Guide Commitment Current Standard Proposed Regulatory Commitment Proposed Standard Basis 1.30 (R0)

Quality Assurance Requirements for the Installation, Inspection, and Testing of Instrumentation and Electric Equipment (Safety Guide 30)

ANSI N45.2.4-1972 RG 1.28 (R5)

NQA-1-2015 Part I, Requirements 10 and 11 TVA will not maintain its commitment to Regulatory Guide 1.30 Revision 0 (8/1972).

TVA will commit to Regulatory Guide 1.28 Revision 5 (10/2017) endorsing NQA-1-2015.

1.33 (R2)

Quality Assurance Program Requirements (Operation)

ANSI N18.7-1976 RG 1.28 (R5)

RG 1.33 (R3)

NQA-1-2015 TVA will not maintain its commitment to Regulatory Guide 1.33 Revision 2 (2/1978).

TVA will commit to Regulatory Guide 1.28 Revision 5 (10/2017) endorsing NQA-1-2015.

TVA will commit to Regulatory Guide 1.33 Revision 3 (6/2013) endorsing ANSI/ANS 3.2-2012, Managerial, Administrative, and Quality Assurance Controls for Operational Phase of Nuclear Power Plants.

1.37 (R0-Fleet, R1-CRN ESP)

Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants ANSI N45.2.1-1973 RG 1.28 (R5)

NQA-1-2015 Part II Subpart 2.1 TVA will not maintain its commitment to Regulatory Guide 1.37 Revision 0 (3/1973) for the TVA Fleet and Revision 1 (3/2007) for CRN ESP.

TVA will commit to Regulatory Guide 1.28 Revision 5 (10/2017) endorsing NQA-1-2015.

1.38 (R2)

Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Water-Cooled Nuclear Power Plants ANSI N45.2.2-1972 RG 1.28 (R5)

NQA-1-2015 Part II Subpart 2.2 TVA will not maintain its commitment to Regulatory Guide 1.38 Revision 2 (5/1977).

TVA will commit to Regulatory Guide 1.28 Revision 5 (10/2017) endorsing NQA-1-2015.

1.39 (R2)

Housekeeping Requirements for Water-Cooled Nuclear Power Plants ANSI N45.2.3-1973 RG 1.28 (R5)

NQA-1-2015 Part II Subpart 2.3 TVA will not maintain its commitment to Regulatory Guide 1.39 Revision 2 (9/1977).

TVA will commit to Regulatory Guide 1.28 Revision 5 (10/2017) endorsing NQA-1-2015.

1.54 (R0)

Service Level I, II, and III Protective Coatings Applied to Nuclear Power Plants ANSI N101.4-1972 RG 1.54 (R3)

ASTM D5144-08 TVA will maintain its commitment to Regulatory Guide 1.54 Revision 0 for previously applied coatings in existing nuclear plants. TVA will commit to RG 1.54 Revision 3, which endorses ASTM D5144-08 for application of new coatings.

Comparison of Existing NRC Regulatory Guide (RG) Commitments to NRC RG Commitments Adopted in the Proposed QAPD CNL-24-060 E1 A2 3 of 5 Current Regulatory Guide Commitment Current Standard Proposed Regulatory Commitment Proposed Standard Basis 1.58 (R1)

Qualification of Nuclear Power Plant Inspection, Examination and Testing Personnel ANSI N45.2.6-1978 RG 1.28 (R5)

NQA-1-2015 Part I Requirement 2 TVA will not maintain its commitment to Regulatory Guide 1.58 Revision 1 (9/1980).

TVA will commit to Regulatory Guide 1.28 Revision 5 (10/2017) endorsing NQA-1-2015.

1.116 (R0-R)

Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems ANSI N45.2.8-1975 No Change N/A TVA will maintain its commitment to Regulatory Guide 1.116 Revision 0-R (6/1976).

1.123 (R1)

Quality Assurance Requirements for Control of Procurement of Items and Service for Nuclear Power Plants ANSI N45.2.13-1976 RG 1.28 (R5)

NQA-1-2015 Part I Requirements 4

& 7.

TVA will not maintain its commitment to Regulatory Guide 1.123 Revision 1 (10/1976).

TVA will commit to Regulatory Guide 1.28 Revision 5 (10/2017) endorsing NQA-1-2015.

1.143 (R0)

Design Guidance for Radioactive Waste Management Systems, Structures, and Components Installed in Light-Water-Cooled Nuclear Power Plants ANSI N199-1976 (PWR)

ANSI N197-1976 (BWR)

No Change N/A TVA will maintain its commitment to Regulatory Guide 1.143 Revision 0 (7/1978).

1.144 (R1)

Auditing of Quality Assurance Programs for Nuclear Power Plants ANSI N45.2.12-1977 RG 1.28 (R5)

NQA-1-2015 Part I Requirement 18 TVA will not maintain its commitment to Regulatory Guide 1.144 Revision 1 (9/1980).

TVA will commit to Regulatory Guide 1.28 Revision 5 (10/2017) endorsing NQA-1-2015.

1.146 (R0)

Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants ANSI N45.2.23-1978 RG 1.28 (R5)

NQA-1-2015 Part I Requirement 2 TVA will not maintain its commitment to Regulatory Guide 1.146 Revision 0 (8/1980).

TVA will commit to Regulatory Guide 1.28 Revision 5 (10/2017) endorsing NQA-1-2015.

1.152 (R0- Fleet, R3-CRN ESP)

Criteria for Programmable Digital Computer System Software in Safety-Related Systems of Nuclear Power Plants ANSI/IEEE-ANS 4.3.2-1982 RG 1.152 (R4)

RG 1.152 (R4)

TVA will not maintain its commitment to Regulatory Guide 1.152 Revision 0 (11/1985) for the TVA Fleet and Revision 3 (07/2011) for CRN ESP.

TVA will commit to Regulatory Guide 1.152 Revision 4 (7/2023).

Comparison of Existing NRC Regulatory Guide (RG) Commitments to NRC RG Commitments Adopted in the Proposed QAPD CNL-24-060 E1 A2 4 of 5 Current Regulatory Guide Commitment Current Standard Proposed Regulatory Commitment Proposed Standard Basis N/A-New Standard N/A RG 1.36 (R1)

Nonmetallic Thermal Insulation for Austenitic Stainless Steel RG 1.36 (R1)

Nonmetallic Thermal Insulation for Austenitic Stainless Steel TVA will commit to Regulatory Guide 1.36 Revision 1 (5/2015).

N/A-New Standard EPRI 3002002982 R1 NP-5652 TR-102260 RG 1.164 (R0)

Dedication of Commercial-Grade Items for Use in Nuclear Power Plant RG 1.164 (R0)

Dedication of Commercial-Grade Items for Use in Nuclear Power Plant TVA will commit to Regulatory Guide 1.164 Revision 0 (6/2017).

N/A-New Standard EPRI TR-1025243 RG 1.231 (R0)

Acceptance of Commercial-Grade Design and Analysis Computer Programs Used in Safety-Related Applications for Nuclear Power Plants RG 1.231 (R0)

Acceptance of Commercial-Grade Design and Analysis Computer Programs Used in Safety-Related Applications for Nuclear Power Plants TVA will commit to Regulatory Guide 1.231 Revision 0 (1/2017).

N/A-New Standard NEI 14-09 RG 1.234 (R0)

Evaluating Deviations and Reporting Defects and Noncomplian ce Under 10 CFR Part 21 RG 1.234 (R0)

Evaluating Deviations and Reporting Defects and Noncompliance Under 10 CFR Part 21 TVA will commit to Regulatory Guide 1.234 Revision 0 (4/2018).

Comparison of Existing NRC Regulatory Guide (RG) Commitments to NRC RG Commitments Adopted in the Proposed QAPD CNL-24-060 E1 A2 5 of 5 Current Regulatory Guide Commitment Current Standard Proposed Regulatory Commitment Proposed Standard Basis 1.64 (R2)

Quality Assurance Requirements for the Design of Nuclear Power Plants ANSI N45.2.11-1974 No Change for existing plants RG 1.28 (R5) for new plants No change for existing plants NQA-1-2015 Part I Requirement 3 for new plants TVA will maintain its commitment to Regulatory Guide 1.64 Revision 2 (6/1976) for existing nuclear power plants.

TVA will commit to Regulatory Guide 1.28 Revision 5 (10/2017) endorsing NQA-1-2015 for new nuclear power plants.

1.74 (R0)

Quality Assurance Terms and Definitions ANSI N45.2.10-1973 RG 1.28 (R5)

NQA-1-2015 TVA will not maintain its commitment to Regulatory Guide 1.74 Revision 0 (2/1974).

TVA will commit to Regulatory Guide 1.28 Revision 5 (10/2017) endorsing NQA-1-2015.

1.8 (R2)

Qualification and Training of Personnel for Nuclear Power Plants ANSI/ANS 3.1-1978 RG 1.8 (R4)

ANSI/ANS 3.1-2014 TVA will not maintain its commitment to Regulatory Guide 1.8 Revision 2 (4/1987).

TVA will commit to Regulatory Guide 1.8 Revision 4 (6/2019),

endorsing ANSI/ANS-3.1-2014, Selection, Qualification, and Training of Personnel for Nuclear Power Plants.

1.88 (R2)

Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records ANSI N45.2.9-1974 RG 1.28 (R5)

NQA-1-2015 Part I Requirement 17 TVA will not maintain its commitment to Regulatory Guide 1.88 Revision 2 (10/1976).

TVA will commit to Regulatory Guide 1.28 Revision 5 (10/2017) endorsing NQA-1-2015.

1.94 (R1)

Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants ANSI N45.2.5-1974 No Change N/A TVA will maintain its commitment to Regulatory Guide 1.94 Revision 1 (4/1976).

4.1 (R1)

Radiological Environmental Monitoring for Nuclear Power Plants N/A RG 4.1 (R2)

N/A TVA will commit to Regulatory Guide 4.1 Revision 2 (6/2009).

4.15 (R0)

Quality Assurance for Radiological Monitoring Programs (Inception Through Normal Operations to License Termination) Effluent Streams and the Environment N/A RG 4.15(R2)

N/A TVA will commit to Regulatory Guide 4.15 Revision 2 (7/2007).

CNL-24-060 Comparison of TVA-NQA-PLN89-A Revision 42 to Proposed Quality Assurance Plan Description Based on NQA-1-2015, "Quality Assurance Requirements for Nuclear Facility Applications" Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 1 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability Policy Statement Policy Statement Quality Assurance Program Description (QAPD) policy statement does not address Chief Nuclear Officer (CNO) policy with regards to QA personnel authority. Nuclear Quality Assurance Program (NQAP) policy statement provides more clarity with respect to TVA Nuclear organizations roles and responsibilities regarding the QA program.

N Change does not affect quality requirements and commitments.

1.0 Purpose Part I Section 1 General QAPD Part I Section 1 provides additional discussion regarding the purpose of the document.

N Change does not affect quality requirements and commitments.

2.0 Applicability Part I Section 2 Scope/Applicability QAPD Part I Section 2 provides additional discussion regarding the scope and applicability of the document. A list of quality-related activities is also provided.

N Change does not affect quality requirements and commitments.

3.0 General Part I Section 1 General NQAP Section 3.0 provides additional discussion not included in QAPD Part I Section 1.

N Change does not affect quality requirements and commitments.

3.1 General Management Requirements Part II Section 1.4 Chief Nuclear Officer QA program implementation requirements for the CNO are provided in QAPD Part II Section 1.4.

N Change does not affect quality requirements and commitments.

3.3.2 Authority and Organizational Freedom of Those Performing QA Verification Part II Section 2.8 QA Organizational Independence QAPD Part II Section 2.8 provides a general statement regarding organizational independence, but does not specifically address items A-D of NQAP Section 3.3.2.

These items are included in NQA-1-2015 Part I Requirement 1 paragraph 201(d).

Statements in NQAP Section 3.3.2 regarding individuals and organizations performing QA verifications are not included in the QAPD.

N Change does not affect quality requirements and commitments.

3.3.3 Assessment of Effectiveness Part II Section 1.4 Chief Nuclear Officer Responsibility for assessment of effectiveness of the QA plan is assigned to the CNO. NQAP states General Manager N

Delegated to GMQA. Change does not affect quality requirements and commitments.

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 2 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability Quality Assurance (GMQA) will assess and report QA plan effectiveness to the CNO.

NQAP paragraph 4.1.1A states the CNO has overall responsibility for the establishment, implementation, and administration of TVAs NQAP and the evaluation of its effectiveness.

3.3.3 Assessment of Effectiveness Part II Section 18.4 Periodic assessment of the TVA Nuclear QA Plan by an external organization is addressed in QAPD Part II Section 18.4.

N 3.3.4 Achievement of Quality in Performance Part II Section 1 Addressed in the CNO Policy Statement.

N 3.3.5 Interpretation of Quality Assurance Program Requirements Part II Section 1.3.6 Part II Section 1.4.C addresses GMQA responsibility for interpretation of QAP requirements. Item 1.4.C.2 states effective implementation of the QAP includes evaluation of compliance to QAP requirements.

N 3.3.6 Early Site Permits Appendix I Appendix J Executive Summary NQAP Appendix I provides the roles and responsibilities of positions for Clinch River Nuclear (CRN). NQAP Appendix J provides CRN commitments and clarification of requirements. The QAPD Executive Summary specifically states the Fleet QAPD applies to Clinch River Nuclear (CRN) while under an approved Early Site Permit (ESP).

N NQAP, Revision 42 and QAPD, Revision 43 address CRN quality requirements until New Nuclear NNP-TR-001-NP-A (Quality Assurance Program Description for TVA New Nuclear) is approved by the NRC and implemented by TVA and the Construction Permit Application (CPA) is approved by the NRC.

4.0 Organization Part II Section 1 Organization QAPD Part II Sections 1.2 and 1.3 discusses the roles and responsibilities of the Chief Executive Officer and Chief Operating Officer with respect to the QA program.

Additionally, QAPD Part II Section 1.3.A describes the role of the Senior Vice President, Resource Management and N

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 3 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability Operations Support. These positions are not discussed in the current NQAP.

Role and size of the QA organization is discussed in QAPD Part II Section 1.4.C.

NQAP references to Final Safety Analysis Report (FSAR) and organizational topical report for key position description. QAPD does not reference these documents.

4.1 Functions of Organizations Part II Section 2 Quality Assurance Program QAPD Part II Sections 1.4, 1.4.A, 1.4.B, and 1.4.C provide the description of organizational functions for TVA Nuclears commitment to implementing QAP requirements.

N 4.1.1 Executive Nuclear Management Part II Section 1.4 Chief Nuclear Officer Section 1.4.A Nuclear Operations Section 1.4.B Engineering and Operations Support NQAP paragraph 4.1.1A and QAPD Part II Section 1.4 are aligned.

NQAP paragraph 4.1.1C and QAPD Part II Section 1.4.A are aligned.

NQAP paragraph 4.1.1B and QAPD Part II Section 1.4.B are aligned.

N 4.1.2 TVA Organizations Part II Section 2 Quality Assurance Program Note: NQAP Section 4.1.2 applies to all TVA organizations performing quality-related work.

NQAP 4.1.2A: QAPD Part II Section 2.2.A states, "Personnel who work directly or indirectly for TVA Nuclear are responsible for achieving acceptable quality in the work covered by the QAPD."

I Increase in commitment limited to 1-year or once during the life of the activity requirement for management of organizations implementing the QAP to review the adequacy for the Part of the program they are executing. (NQAP 4.1.2B)

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 4 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability NQAP 4.1.2B: QAPD Part II Section 2.4 discusses periodic review of the QA program.

NQAP 4.1.2C: QAPD Part II Section 2.2.C states activities governed by the QAPD are performed as directed by procedures. Part I Section 1 also states procedures and instructions that control Quality-Related (QR) activities will be implemented.

NQAP 4.1.2D: Not specifically addressed in the same manner as this section. Control of documents and records is discussed throughout the QAPD in various sections.

4.1.2E. Housekeeping is discussed in QAPD Part II Section 13.2. Additional discussion on housekeeping requirements during plant operations is provided in this section.

4.1.2F. Not specifically addressed in the same manner as this section. Identification and resolution of adverse conditions (conditions adverse to quality) is discussed in QAPD Part II Section 16.

4.1.2G. Requirement to make personnel and resources available during audit performance is not discussed in the QAPD.

4.1.2H. QAPD Part II Section 2.6 discusses training and qualification for personnel performing QR work. Does not speak to development of certification programs.

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 5 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability NQAP 4.1.2I is aligned with in QAPD Part II Section 2.9, Authority to Stop Work.

4.1.2J. QAPD Part II Section 2.6 discusses training and qualification for personnel performing QR work.

4.1.2K. Implementing documents for organizational interfaces is discussed in QAPD Part II Section 1. Also NQAP 4.1.2C.

4.1.2L. QAPD Part II Section 1.3.A states, The management position responsible for procurement is responsible for ensuring that the QA requirements established by this program description are either included or referenced (as appropriate) in related Procurement sponsored program areas.

4.1.3 Nuclear Operations Part II Section 1.4.A, 1.4.A.1, 1.4.A.2 NQAP 4.1.3A is aligned with in QAPD Part II Section 1.4.A.

NQAP 4.1.3B is aligned with in QAPD Part II Section 1.4.A.

NQAP 4.1.3C.1 - 4 is aligned with QAPD Part II Section 1.4.A.1.a - d. Business Operations and Planning is referenced in NQAP 4.1.3D.1.f and 4.1.3D.2.d and is aligned with QAPD Part II Section 1.4.A.

QAPD does not include discussion on Site Organizations as described in NQAP Section 4.1.3D.

R Generic description.

The QAPD conforms to American National Standards Institute/American Nuclear Society (ANSI/ANS) 3.2-2012 and NQA 2015 as endorsed by Regulatory Guide (RG) 1.28, Revision 5. Through the various endorsed revisions of NQA-1, unnecessary detail at the program level, examples, or redundant information was removed. The removal of this information is acceptable and does not reduce compliance of the QAPD to the NQA 2015 standard.

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 6 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability NQAP 4.1.3E is aligned with QAPD Part II Section 1.4.A.2.

Reduction in level of detail to be consistent with other utilities QAPs.

4.1.4 Operations Support Part II Section 1.4.B.2 NQAP 4.1.4A-B.1, 2, & 4 is addressed in QAPD Part II Section 1.4.B.2. QAPD does not specifically address PI functions (CAP, trending and indicators) as discussed in NQAP 4.1.4B.4. QAPD Part II Section 1.4.B.2 only states Operations Support oversees the PI organization.)

N Operations Support oversees Performance Improvement (PI) function and duties are delegated to PI group.

4.1.5 Nuclear Engineering Part II Section 1.4.B.1 QAPD Part II Section 1.4.B.1 only aligns with NQAP 4.1.5A. Other responsibilities discussed in 4.1.5B - D are not included in the QAPD.

R Change does not affect quality requirements.

The QAPD conforms to ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3 and NQA-1-2015 as endorsed by RG1.28, Revision 5. Through the various endorsed revisions of NQA-1, unnecessary detail at the program level, examples, or redundant information was removed. The removal of this information is acceptable and does not reduce compliance of the QAPD to the NQA-1-2015 standard.

4.1.6 Procurement Part II Section 1.3.A NQAP 4.1.6 refers to the VP of Supply Chain and Executive Vice President (EVP)/COO.

QAPD Part II Section 1.3.A discusses role of Senior Vice President, Resource Management and Operations Support under the COO. The requirements of this section are satisfied.

N 4.1.7 Nuclear Regulatory Affairs and Support Services Part II Section 1.4.B.3 Part V Section 2.2 NQAP 4.1.7A and B align with QAPD Part II Section 1.4.B.3. QAPD Part V Section 2.2 addresses requirements for independent review of quality activities.

N The Independent Review function (QAPD Part V Section 2.2) describes the collective performance by the Onsite Review Committee, Quality Assurance organization, and the line organization executing quality assurance program Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 7 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability required reviews consistent with ANS 3.2 2012, Section 3.2.2.3 and Standard Review Plan 17.5, Option I - Independent Review Body. This is also consistent with the safety evaluation dated January 13, 2005 to Nuclear Management Company (ML050210276) and the Duke Energy Corporation Topical Report (DUKE-QAPD-001-A), Amendment 42, dated May 22, 2017 (ML17143A355). The responsibilities and qualifications of the Onsite Review Committee were revised consistent with ANSI/ANS 3.2 2012 and ANSI 3.1-2014.

4Property "ANSI code" (as page type) with input value "ANSI 3.1-2014.4" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..1.8 Clinch River Nuclear Part II Section 1.4 See discussion on NQAP Appendix I below.

QAPD Part II Section 1.4.C states the GMQA is responsible for the performance of the quality assurance oversight organization for the nuclear operating fleet, vendor support, CRN ESP, and the TVA New Nuclear Program. This section does not specifically relate to NQAP 4.1.8B with respect to CRN or the management position responsible for quality services. NQAP 4.1.8C and D requirements are not addressed.

N NQAP, Revision 42 and QAPD, Revision 43 address CRN quality requirements until New Nuclear NNP-TR-001-NP-A (Quality Assurance Program Description for TVA New Nuclear) is approved by the NRC and implemented by TVA and the CPA is approved by the NRC.

4.1.9 Nuclear Oversight Part II Section 1.4.C NQAP 4.1.9 states "The management position responsible for nuclear oversight reports to the CNO and manages the TVA Nuclear Quality Assurance organization." QAPD Part II section 1.4.C states "The General Manager, Quality Assurance (QA) is responsible for the performance of the quality assurance oversight organization for the nuclear N

Change does not affect quality requirements and commitments.

Responsibilities of Nuclear Oversight are addressed in description of Quality Assurance organization.

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 8 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability operating fleet, vendor support, CRN ESP, and the TVA New Nuclear Program. The General Manager, QA has an independent reporting relationship with the CNO on quality issues. The General Manager, QA administers quality assurance responsibilities through the management positions responsible for Corporate QA, Site QA, and QA Services."

4.1.10 Quality Assurance NQAP 4.1.10A states,"the quality organization has direct access to appropriate levels of management and sufficient independence or organizational freedom" QAPD does not fully discuss this requirement. Requirement addressed in NQA-1-2015 Part I Requirement 1 Section 201(d).

Education requirements for GMQA are in QAPD Part II Section 2.7.A align with current NQAP requirements. QAPD includes additional language regarding special requirements such as management and supervisory skill. Also includes provision to assign personnel to GMQA position who do not meet minimum requirement based on other factors and evaluated on a case-by-case basis.

NQAP 4.1.10A states the GMQA has responsibility for the administration of TVAs NQAP requirements for projects being implemented on operating units by other organizations. QAPD II Section 1.4.C does not specifically address this.

N Change does not affect quality requirements and commitments.

The QAPD conforms to ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3 and NQA-1-2015 as endorsed by RG1.28, Revision 5. Through the various endorsed revisions of NQA-1, unnecessary detail at the program level, examples, or redundant information was removed. The removal of this information is acceptable and does not reduce compliance of the QAPD to the NQA-1-2015 standard.

NQAP, Revision 42 and QAPD, Revision 43 address CRN quality requirements until New Nuclear NNP-TR-001-NP-A (Quality Assurance Program Description for TVA New Nuclear) is approved by the NRC and implemented by TVA.

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 9 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability NQAP 4.1.10A states the GMQA administers QA responsibilities for CRN through the management position responsible for quality services. Part II Section 1.4.C includes the CRN ESP as part of GMQA oversight activities.

NQAP 4.1.10B - D (CQAM, QSM, SQAM) is described generically as individuals responsible for supervising QA or QC personnel. Duties specifically assigned to the CQAM, QSM, and SQAMs in their respective Sections are not addressed.

Education and experience requirements are aligned.

4.1.11 Inspection, Testing, Monitoring and Analysis Part II Section 1.3.B NQAP 4.1.11 and QAPD Part II Section 1.3.B are aligned.

N Does not impact quality requirements or reporting relationships.

4.1.12 Human Resources (Nuclear)

Part II Section 1.5 NQAP 4.1.12 and QAPD Part II Section 1.5 are aligned.

N Does not impact quality requirements or reporting relationships.

5.0 Nuclear QA Program Part I Section 2 Table in QAPD Part I Section 2 provides a list of quality-related of activities covered by the QAPD as compared to NQAP 5.0.

Discussion of activities performed through approved procedures and instructions by TVA Nuclear and non-nuclear organization included. Additional requirements for TVA non-nuclear organizations regarding use of intergroup agreements (IGA) or quality requirements specified in procurement documents is addressed.

N Does not impact quality requirements.

5.1 Program Scope Part I Section 1 Part I Section 2 Part III Section 1.3 NQAP 5.1A states the document applies to activities associated with safety-related structures, systems and components (SSC)

N The QAPD conforms to ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3 and NQA-1-2015 as endorsed by RG1.28, Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 10 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability or those controlled by Title 10 of the Code of Federal Regulations (10 CFR) 72. QAPD Part I Section 2 states the document applies to personnel and organizations, TVA non-nuclear orgs, and contractor activities.

Section 2 also provides examples activities.

NQAP 5.1B through D are not addressed.

Functional areas and program as listed in 5.1B.2 are discussed in QAPD Part III Section 1.3.

Requirements for establishment of a Q-List are also not addressed (5.1C). This is broadly discussed in QAPD Part II Section 2.1.B.

Revision 5. Through the various endorsed revisions of NQA-1, unnecessary detail at the program level, examples, or redundant information was removed. The removal of this information is acceptable and does not reduce compliance of the QAPD to the NQA-1-2015 standard.

5.2 Graded Approach N/A QAPD does not speak to a graded approach. NQA-1-2015 Part II Section 200 states, When invoked by an organization, regulation, contract, or other specifying document, the applicable Subparts of Part II are to applied using a graded approach to any structure, system, component, activity, or organization that is essential to the safe, reliable, and efficient performance of a nuclear facility and any activities independent of a facility that may affect performanceof those activities.

N Graded approach addressed in NQA 2015 Part II Section 200.

5.3 Program Elements Part II Section 2.1 Part III Section 1 Part V NQAP 5.3A is addressed in QAPD Part II Section 2.1.

NQAP 5.3B statement regarding graded approach is addressed in QAPD Part III Sections 1.2 and 1.3. NQA-1-2015 Part II N

The QAPD conforms to ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3 and NQA-1-2015 as endorsed by RG1.28, Revision 5. Through the various endorsed revisions of NQA-1, unnecessary detail at the program level, examples, or redundant information was removed. The removal of Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 11 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability Part II Section 1 Part V Part II Sections 2, 10, 11 and 18 Part II Section 2.5 Part V, Part II Sections 2.6, 9, 10.1, 12 Section 200 addresses this approach. QA controls are addressed in QAPD Part V.

NQAP 5.3C statement regarding assignment of responsibilities is similar to QAPD Part II Section 1.1 statement. The following Sections describefunctional responsibilities, and authorities for organizations implementing and supporting the QAP.

NQAP 5.3D is addressed throughout QAPD Part V.

NQAP 5.3E is addressed in QAPD Part II Section 2.1.M (assessment/audit of suppliers), Section 10 (Inspection), Section 11 (Test Control), and Section 18 (Audits).

NQAP 5.3F requirement for indoctrination and training, qualification and certification for personnel for performing activities affecting quality is addressed on QAPD Part II Section 2.6. Requirement for training to be complete prior to performing activities is not specifically included in related sections of the QAPD.

NQAP 5.3G provisions for special controls are addressed in ANSI/ANS 3.2-2012; special processes in QAPD Part II Section 9 (Control of Special Processes); test equipment in Section 12 (Control of Measuring and Test Equipment); special tools in Section 10.2.B. Skill is implied in this information is acceptable and does not reduce compliance of the QAPD to the NQA-1-2015 standard.

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 12 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability Part II Sections 2, 13.2 Part II Section 16 Part II Section 17 discussion of qualification of personnel in QAPD Part II Section 2.6.

NQAP 5.3H. General statement for cleanliness in QAPD Part II Section 2.1.B.2.

Section 13.2 address general housekeeping requirements including cleanliness of facilities and materials, fire prevention and protection, disposal of combustible material and debris, control of access to work areas, and protection of equipment. Section 13.1 also states, Housekeeping practices help assure that only proper materials, equipment, processes, and procedures are used, and that the quality of items is not degraded. Also, see Section 13.3 for commitment and exceptions.

NQAP 5.3I requirements for adverse conditions is addressed in QAPD Part II Section 16.

NQAP 5.3J requirements for records is addressed in QAPD Part II Section 17.

5.4 Program Documents Executive Summary, Policy Statement, and Part I Section 1 Statements regarding QA program documents and procedures are addressed in QAPD Executive Summary, Policy Statement, and Part I Section 1. NQAP 5.4A statements regarding implementation of 10 CFR 50 App A and American Society of Mechanical Engineering (ASME)Section XI are addressed in QAPD Part II Section 1.4.A.1. ASME OM Code is not specifically addressed; however site licensing basis N

QAPD Part II Section 1.4.A.1.a states, the Site Vice President is responsible for The site compliance with the operating unit license, governing regulations, and ASME code requirements. ASME code compliance is a commitment in the associated site FSARs.

BFN: FSAR Section 4.12; Appendices A, C, & O SQN: FSAR Section 6.8 Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 13 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability documents do address ASME Code requirements.

WBN: FSAR Section 5.5.12.4; 6.3.4.2; 9.3.6.5 5.5 Program Changes Part II Section 2.5 QAPD Part II Section 2.5 addresses revisions to the QAP. This section does not specifically require distribution to senior managers and department head.

N Does not impact quality requirements.

6.0 Control of Documents and Records 6.1 Procedures and Instructions 6.1.1 General Part II Section 5 Part II Section 6 QAPD Part II Section 5 also addresses drawings and is aligned with requirements of 6.1.1A.

QAPD Part II Section 6 is aligned with requirements of 6.1.1B.

N 6.1.2 Program Elements Part V Sections 3 and 3.1 Part II Section 6 Part V Sections 3 and 3.1 Part II Section 6.1 Part II Section 6 6.1.2A.1 requirements are addressed in ANSI/ANS 3.2-2012.

6Property "ANSI code" (as page type) with input value "ANSI/ANS 3.2-2012.6" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..1.2A.2 requirements are addressed in QAPD Part II Section 6.

6.1.2A.3 requirements are addressed in ANSI/ANS 3.2-2012.

6Property "ANSI code" (as page type) with input value "ANSI/ANS 3.2-2012.6" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..1.2B.1 is addressed in QAPD Part II Section 6.1.

6.1.2B.2 is addressed in QAPD Part II Section 6. This section does not specifically include affected organizations outside the issuing organization. TVA Nuclear document control and procedure program procedures provide direction for responsible individuals performing reviews including affected organizations.

6.1.2B.3 is addressed in QAPD Part II Section 6. This section does not specifically N

Does not impact quality requirements.

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 14 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability Part II Section 6.1 Part II Section 6 Part II Section 6.1 Part II Section 6.2 state a review to ensure proper incorporation of QA requirements. QA organization review is required during ESP or construction phase. During the Ops phase, reviews are performed by qualified individuals which is consistent with 6.1.2B.3.

6.1.2C and QAPD Part II Section 6.1 are aligned.

6.1.2D is addressed in QAPD Part II Section

6.

6.1.2E is addressed in QAPD Part II Section 6.1. This section does not specifically refer to issues identified by NRC, Licensing, or CAP.

6.1.2F is addressed in QAPD Part II Section 6.2.

6.1.3 Responsibilities Part II Section 1.4.B.2 Part II Section 1.4.C 6.1.3A statement that the management position responsible for operations support is responsible for the development of programs to control procedures and instructions. is not included in QAPD Part II Section 1.4.B.2 (Operations Support).

6.1.3B states the following:

The General Manager, QA shall:

1. Perform reviews or assessments of TVA Nuclear NPS documents that implement the NQAP and, N

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 15 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability Part II Section 2.1 Part II Section 6 Part II Section 6.1

2. Verify through assessing or other means that reviews are conducted by personnel knowledgeable in QA requirements.

QAPD Part II Section 1.4.C makes a general statement that the GMQA is responsible for planning and performing activities to verify the development and effective implementation of the QAPD.

6.1.3C1 is addressed in QAPD Part II Section 2.1.

6.1.3C2 requirements for review of NPS documents implementing NQAP are conducted by personnel knowledgeable of QA requirements is implied in QAPD Part II Section 6.1.A bullet Review of controlled documents for adequacy, completeness, and approval prior to use. Additionally, QAPD Part II Section 6.2.A states QA organization review is required during ESP or construction phase. During the Ops phase, reviews are performed by qualified individuals per Section 6.2 which is consistent with 6.1.2C.2.

6.1.4 Source Requirement Documents NQAP Appendix B Table 1:

x RG 1.33 R2 / ANSI N18.7-1976/ANS-3.2 Section 5 x

RG 1.28 R3 / ANSI N45.2-1971 Section 6. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.37 R0 / ANSI N45.2.1-1973 Sections 2.1 and 2.2. Requirements N

The QAPD conforms to ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3 and NQA-1-2015 as endorsed by RG1.28, Revision 5. Through the various endorsed revisions of NQA-1, unnecessary detail at the program level, examples, or redundant information was removed. The removal of this information is acceptable and does not Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 16 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.38 R2 / ANSI N45.2.2-1973 Sections 2.1 and 2.2. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.39 R2 / ANSI N45.2.3-1973 Sections 2.1 and 2.2. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.30 R0 / ANSI N45.2.4-1972 Sections 2.1 and 2.3. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.94 R1 / ANSI N45.2.5-1974 Sections 2.1 and 2.2.

x RG 1.116 R0-R / ANSI N45.2.8-1975 Section 2.1 and 2.2.

x RG 1.88 R2 / ANSI N45.2.9-1974 (NIRMA TG 11-1998, 15-1998, 16-1998, 21-1998, GL 88-18).

Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.64 R2 / ANSI N45.2.11-1974 Section 2.2.

x RG 1.123 R1 / ANSI N45.2.13-1976 Section 2. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x 10 CFR 50 Appendix B Criterion V x

10 CFR 72.150 x

ASME Section III Div 1 Art. NCA 4000 reduce compliance of the QAPD to the NQA-1-2015 standard.

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 17 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability x

Plant Technical Specifications (Administrative Controls Section)

QAPD Part II Section 5.4 x

NQA-1-2015 Part I Requirement 5 QAPD Part II Section 6.4 x

NQA-1-2015 Part I Requirement 6 QAPD Part IV x

RG 1.33 R3 x

RG 1.28 R5 x

RG 1.94 R1 x

RG 1.116 R0-R x

RG 1.64 R2 6.2 Document Control 6.2.1 General Part II Section 6 QAPD Part II Section 6 does not include a statement regarding document availability prior to commencing work. NQA-1-2015 Part I Requirement 6 (200e) requires a method to ensure that correct documents are being used. This requirement is satisfied.

N NQA-1-2015 Part I Requirement 6 (200e) requires a method to ensure that correct documents are being used. This requirement is satisfied.

6.2.2 Program Elements Part II Section 6 QAPD Part II Section 6 addresses all aspects of NQAP 6.2.2.

N 6.2.3 Responsibilities NQAP 6.2.3 states, The management position responsible for nuclear engineering is responsible for the development of programs to control documents.

Responsibility for document control program is not assigned in the QAPD. The QAPD does not specify organizational responsibility for document control programs.

N The QAPD conforms to ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3 and NQA-1-2015 as endorsed by RG1.28, Revision 5. Through the various endorsed revisions of NQA-1, unnecessary detail at the program level, examples, or redundant information was removed. The removal of this information is acceptable and does not reduce compliance of the QAPD to the NQA-1-2015 standard.

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 18 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability 6.2.4 Source Requirement Documents NQAP Appendix B Table 1 x

RG 1.33 R2 / ANSI N18.7-1976/ANS-3.2 Section 5.2.15 x

RG 1.28 R3 / ANSI N45.2-1973 Section 7. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5 x

RG 1.30 R0 / ANSI N45.2.4-1972 Section 2.3. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.94 R1 / ANSI N45.2.5-1974 Section 2.2 x

RG 1.116 R0-R / ANSI N45.2.8-1975 Section 2.2 x

RG 1.64 R2 / ANSI N45.2.11-1974 Section 7 x

10CFR50 Appendix B Criterion VI x

10CFR72.152 x

ASME Section III Div 1 Art. NCA 4000 QAPD Part II Section 6.4 x

NQA-1-2015 Part I Requirement 6 QAPD Part IV x

RG 1.33 R3 x

RG 1.28 R5 x

RG 1.94 R1 x

RG 1.116 R0-R x

RG 1.64 R2 N

The QAPD conforms to ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3 and NQA-1-2015 as endorsed by RG1.28, Revision 5. Through the various endorsed revisions of NQA-1, unnecessary detail at the program level, examples, or redundant information was removed. The removal of this information is acceptable and does not reduce compliance of the QAPD to the NQA-1-2015 standard.

6.3 QA Records 6.3.1 General Part II Sections 17 and 17.3 6.3.1A is addressed in QAPD Part II Section

17.

6.3.1B and C are addressed in QAPD Part II Section 17.3. Section 17.3 Nuclear I

TVA will comply with the 2011 NIRMA standards upon implementation of the QAPD for all QA records generated from that point forward. Existing records will comply with standards in effect at the time Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 19 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability Information and Records Management Association (NIRMA) technical guide differences as below.

NQAP 6.3.1B QAPD Part II Section 17 11-1998 15-1998 16-1998 21-1998 11-2011 15-2011 16-2011 21-2011 the record was archived (QAPD Part II Section 17.3.B).

6.3.2 Program Elements Part II Section 17 NQA-1-2015, Part I, Requirement 17 (800b) 6.3.2A and B is addressed in QAPD Part II Section 17.1.

6.3.2C requirements for in-process QA documents is not addressed.

6.3.2D is addressed in QAPD Part II Section

17.

6.3.2E is broadly addressed in QAPD Part II Sections 17.2 and 17.4. While permanent and temporary records storage facilities not specifically addressed, but is addressed through commitment to the applicable standards.

6.3.2F is covered in QAPD Part II Section 17.1.D.

6.3.2G not addressed. Retrievability requirements are addressed in NQA-1-2015, Part I, Requirement 17 (800b).

R The QAPD conforms to ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3 and NQA-1-2015 as endorsed by RG1.28, Revision 5. Through the various endorsed revisions of NQA-1, unnecessary detail at the program level, examples, or redundant information was removed. The removal of this information is acceptable and does not reduce compliance of the QAPD to the NQA-1-2015 standard.

6.3.3 Responsibilities NQAP 6.3.3 states, The management position responsible for nuclear engineering N

The QAPD conforms to ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3 Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 20 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability is responsible for the development of a QA records program. Responsibility for QA records program is not assigned in the QAPD.

and NQA-1-2015 as endorsed by RG1.28, Revision 5. Through the various endorsed revisions of NQA-1, unnecessary detail at the program level, examples, or redundant information was removed. The removal of this information is acceptable and does not reduce compliance of the QAPD to the NQA-1-2015 standard.

6.3.4 Source Requirement Documents NQAP Appendix B Table 1 x

RG 1.33 R2 / ANSI N18.7-1976/ANS-3.2 Section 5.2.12 x

RG 1.28 R3 / ANSI N45.2-1973 Section 18. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.37 R0 / ANSI N45.2.1-1973 Section 9. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.38 R2 / ANSI N45.2.2-1972 Section 8. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.39 R2 / ANSI N45.2.3-1973 Section 4. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.30 R0 / ANSI N45.2.4-1972 Section 8. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.94 R1 / ANSI N45.2.5-1974 Section 7 x

RG 1.58 R1 / ANSI N45.2.6-1978 Section 6. Requirements N

TVA commits to NQA-1-2015 as endorsed by the NRC in Regulatory Guide 1.28, Revision 5, and ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3.

Commitments to the various regulatory guides and standards will be upgraded with exceptions noted in the QAPD. TVA will no longer commit to regulatory guides endorsing ANSI N45.2-series as they will be superseded by NQA-1-2015.

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 21 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.116 R0-R / ANSI N45.2.8-1975 Section 7 x

RG 1.88 R2 / ANSI N45.2.9-1974.

Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.64 R2 / ANSI N45.2.11-1974 Section 10 x

RG 1.144 R1 / ANSI N45.2.12-1977 Section 5. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5 x

RG 1.123 R1 / ANSI N45.2.13-1976 Section 11. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.146 R0 / ANSI N45.2.23-1978 Section 5. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x 10CFR50 Appendix B Criterion XVII x

10CFR72.174 x

ASME Section III Div 1 Art. NCA 4000 x

NUTAC Report on GL 83-28 QAPD Part II Section 17.3 x

ANSI/ANS 3.2-2012 Section 3.17 x

NQA-1-2015 Part I Requirement 17 QAPD Part IV x

RG 1.33 R3 x

RG 1.28 R5 x

RG 1.94 R1 x

RG 1.116 R0-R Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 22 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability x

RG 1.64 R2 7.0 Design Control 7.1 General Part II Section 3 NQAP 7.1 is covered in NQA-1-2015 Requirement 3.

N 7.2.1 Basic Part II Section 3 7.2.1A requirement for identification of items, services, and activities subject to design control is not specifically included.

7.2.1B covered in QAPD Part II Section 3.6 requirements for Design records 7.2.1C covered in QAPD Part II Section 3.6.

7.2.1D covered in QAPD Part II Section 11.2.B.

7.2.1E states, Measures shall be established and implemented to provide documented input to other organizations which may request input for their special tests. QAPD does not specially address this requirement.

7.2.1F addressed in QAPD Part II Section 3.5.D.

7.2.1G addressed in QAPD Part II Section 3.5.F.

7.2.1H requirement for Q-List is not specifically addressed.

7.2.1I requirement for EQ is not specifically addressed.

N Commitments for Q-List and EQ programs are regulatory-driven and do not need to be included in the QAPD.

The QAPD conforms to ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3 and NQA-1-2015 as endorsed by RG1.28, Revision 5. Through the various endorsed revisions of NQA-1, unnecessary detail at the program level, examples, or redundant information was removed. The removal of this information is acceptable and does not reduce compliance of the QAPD to the NQA-1-2015 standard.

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 23 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability 7.2.1J requirement for errors and deficiencies in design documents is not explicitly addressed, but implied in over-arching statements regarding corrective action.

7.2.2 Design Inputs Part II Section 3.2 Part III Section 1.3 All elements of NQAP 7.2.2 are addressed in QAPD Part II Section 3.2.

N 7.2.3 Design Analysis Part II Section 3.4 NQA-1-2015 Part I Requirement 3 paragraph 300(b)

NQAP 7.2.3A is addressed under procedural controls requirements in QAPD Part II Section 2. NQAP 7.2.3B addressed in QAPD Part II Section 3.4 and NQA-1-2015, Part I Requirement 3 paragraph 300(b).

N 7.2.4 Interface Control Part II Section 3.3 Addressed in QAPD Part II Section 3.3.D.

N 7.2.5 Design Output Part II Section 3 Part II Sections 3 and 5

Part II Section 3 7.2.5A refers to design output documents.

Requirement addressed in QAPD Part II Section 3.3.B, which says, "Design documents shall support the facility design, construction, and operation."

7.2.5B QAPD Part II Section 3 addresses procedural control for design output documents.

7.2.5C QAPD Part II Section 5 addresses the inclusion of acceptance criteria in drawings. Acceptance criteria in design documents addressed in QAPD Part II Section 3.

7.2.5D QAPD Part II Section 3 addresses review requirement for design output.

N Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 24 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability Part II Sections 5 and 6

Part II Section 6.2 7.2.5E QAPD Part II Sections 5 and 6 address document control requirements for design output (drawings).

7.2.5F QAPD Part II Section 6.2.

7.2.6 Design Verification Part II Sections 3 Part V Part II Section 3.1 NQA-1-2015 Part I Requirement 3 paragraph 500(d).

7.2.6A addressed by QAPD Part II Section 3.4.A.

7.2.6B, C addressed by QAPD Part II Section 3.5.

7.2.6D not specifically addressed for units under construction permits. QAPD Part V states TVA Nuclear includes the requirements of Part V that follow when establishing the necessary measures and governing procedures for the operational phase of the plant. Implementation of the additional controls in this section shall apply 30 days prior to initial fuel load for COL holders in accordance with 10 CFR 50.54(a)(1) and 90 days prior to initial fuel load for construction permit holders.

7.2.6E addressed in final paragraph of QAPD Part II Section 3.5.F.

7.2.6F requirement for verification testing under the most adverse conditions for a SSC is addressed in QAPD Part II Section 3.5.E.

NQAP 7.2.6F also contains a statement that such testing should be performed as early as possible prior to installation or it being relied upon in plant operation. QAPD Part II Section 3.5. and NQA-1-2015 Part I N

Quality requirements for units under construction permits are addressed in NNP-TR-001-NP-A (Quality Assurance Program Description for TVA New Nuclear).

The QAPD conforms to ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3 and NQA-1-2015 as endorsed by RG1.28, Revision 5. Through the various endorsed revisions of NQA-1, unnecessary detail at the program level, examples, or redundant information was removed. The removal of this information is acceptable and does not reduce compliance of the QAPD to the NQA-1-2015 standard.

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 25 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability Appendix B, Table 2, RG 1.64 exception to regulatory position C.2.

Requirement 3 paragraph 500(d) address this requirement.

NQAP App B Table 2, RG 1.64 exception.

If in an exceptional circumstance, the engineers supervisor is the only person technically qualified to perform the review, the design verification review will be conducted by the supervisor, provided that:

1. The other provisions of this Regulatory Guide and ANSI N45.2.11, Section 6.1 are satisfied.

2. The justification is individually documented and approved in advance by the supervisors management.

3. QA is to audit the use of supervisors as design verifiers to guard against abuse.

NQA-1-2015 Part I Requirement 3 paragraph 500(a) makes the following statement:

This verification may be performed by the originators supervisor, provided (1) the supervisor did not specify a singular design approach or rule out certain design considerations and did not establish the design inputs used in the design; or (2) the supervisor is the only individual in the organization competent to perform the organization. (Note: ANSI N45.2.11 Section 6.1 requirements are addressed in NQA 2015 Part I Requirement 3 paragraph 500.)

QAPD Part II Section 3.5.B.2 addresses verification by supervisors. Commitment to audit design verification is not addressed; however, audits are performed to verify compliance with the quality plan therefore N

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 26 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability audits of design verification may be performed.

7.2.7 Design Changes Part II Section 3 Part II Section 6.2 Part II Section 3.1.B Part II Section 4 Part II Section 3 7.2.7A is addressed by QAPD Part II Section 3.1.

7.2.7B is addressed in QAPD Part II Section 6.2 (applies to all quality-related documents) and Section 3.1.B.

7.2.7C states, Design changes that affect the supply of a quality-related item or service controlled by procurement documents shall be returned to operation until: (1) the change is reflected in the appropriate change document such as contract or purchase order change notice, (2) the change document has received the requisite reviews and approvals, and (3) the change document has been submitted to and accepted by the respective supplier. QAPD Part II Section 4 broadly addresses items 1 and 2 above, but discussion of item 3 is not explicitly addressed.

7.2.7D requirement that design modifications be at least equivalent to the quality specified in the latest approved design basis is covered in QAPD Part II Section 3. Section 3 makes a broad statement that the design control program includes controls for approval and release of design inputs and outputs.

7.2.7E is addressed in QAPD Part II Section 3.1.

N QAPD Part II Section 3 states, Design change processes and the division of responsibilities for design-related activities are detailed in TVA Nuclear and supplier procedures.

The QAPD conforms to ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3 and NQA-1-2015 as endorsed by RG1.28, Revision 5. Through the various endorsed revisions of NQA-1, unnecessary detail at the program level, examples, or redundant information was removed. The removal of this information is acceptable and does not reduce compliance of the QAPD to the NQA-1-2015 standard.

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 27 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability NQA-1-2015 Part I Requirement 3 (601) 7.2.7F is addressed in NQA-1-2015 Part I Requirement 3 (601).

7.3 Responsibilities Part I Sections 1.4.B.1 and 1.4.B.5.

7.3A is addressed in QAPD Part I Section 1.4.B.1. This section makes a general statement regarding engineering functions and is not limited to the Design Control Program.

7.3B is addressed in QAPD Part I Section 1.4.B.5.

N 7.4 Source Requirement Documents NQAP Appendix B Table 1 x

RG 1.33 R2 / ANSI N18.7-1976/ANS-3.2 Section 5.2.7.2 x

RG 1.28 R3 / ANSI N45.2-1971..

Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

Section 4. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.64 R2 / ANSI N45.2.11-1974 x

10CFR50 Appendix B Criterion III x

ASME Section III Div 1 Art. NCA 4000 x

ASME Section XI x

ASME OM Code QAPD Part II Section 3.9 x

NQA-1-2015 Part I Requirement 3 N

The QAPD conforms to ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3 and NQA-1-2015 as endorsed by RG1.28, Revision 5. Through the various endorsed revisions of NQA-1, unnecessary detail at the program level, examples, or redundant information was removed. The removal of this information is acceptable and does not reduce compliance of the QAPD to the NQA-1-2015 standard.

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 28 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability x

NQA-1-2015 Part II Subpart 2.7 x

NQA-1-2015 Part II Subpart 2.14 x

NQA-1-2015 Part II Subpart 2.20 QAPD Part IV x

RG 1.33 R3 x

RG 1.28 R5 x

RG 1.64 R2 8.0 Procurement and Material Control 8.1 Procurement Document Control 8.1.1 General Part II Section 4 8.1.1 is aligned with QAPD Part II Section 4.1.

N 8.1.2 Program Elements Part II Section 4 NQA-1-2015 Part I Requirement 4 8.1.2A general statement regarding planning and procedure requirements for procurement process is not specifically addressed in QAPD Part II Section 4. A broad statement is provided stating that necessary measures and governing procedures are established.

NQA-1-2015 Part I Requirement 4 Section 200 addresses the content of procurement documents. Review and changes for procurement documents is addressed in Sections 300 and 400. NQAP 8.1.2A provides a finite list of elements to be included in the procurement process that are not specifically delineated in the QAPD or in NQA-1-2015.

NQAP 8.1.2B requirements for procurement document content addressed as follows:

1. QAPD Part II Section 4.1.B addresses technical, quality, and reporting requirements.

N The QAPD conforms to ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3 and NQA-1-2015 as endorsed by RG1.28, Revision 5. Through the various endorsed revisions of NQA-1, unnecessary detail at the program level, examples, or redundant information was removed. The removal of this information is acceptable and does not reduce compliance of the QAPD to the NQA-1-2015 standard.

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 29 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability

2. QAPD Part II Section 4.2 states that procurement documents for Commercial Grade items that will be procured by TVA Nuclear for use as safety-related items shall contain technical and quality requirements such that the procured item can be appropriately dedicated in accordance with QAPD, Part II, Section 7, Control of Purchased Material, Equipment, and Services.

NQAP requirement for engineering evaluation for critical characteristics is addressed in first bullet of introductory paragraph of Section 4.1.B.1.

3. Addressed in QAPD Part II Section 4.1.D.

4. Sub-vendors and subcontractors are not specifically addressed in QAPD.

NQA-1-2015 Part I Requirement 4 paragraph 203 addresses incorporation of QA program requirements in sub-tier procurement documents.

5. NQA-1-2015 Part I Requirement 4 paragraph 205 addresses identification of documentation required to be submitted for information, review, or approval by the Purchaser.

6. NQA-1-2015 Part I Requirement 4 paragraph 205 states, When the Purchaser requires the Supplier to maintain specific records, the Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 30 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability retention times and disposition shall be prescribed. Maintenance, retention, and disposition or record addresses the requirement of this section.

7. NQA-1-2015 Part I Requirement 4 paragraph 204 addresses right of access.

8. NQA-1-2015 Part I Requirement 4 paragraph 207 addresses spare and replacement Parts.

9. NQA-1-2015 Part I Requirement 4 paragraph 206 addresses nonconformances.

NQAP 8.1.2C requirements for procurement document review and approval is addressed in QAPD Part II Section 4.1.E.

NQAP 8.1.2D requirements for procurement document change control is addressed in QAPD Part II Section 4.1.E.

8.1.3 Responsibilities Part II Section 1.3.A Part II Section 4 NQAP 8.1.3A states, the management position responsible for procurement is responsible for the development of a procurement document control program.

The program elements of Section 8.1.2 and the related source requirements contained within the documents listed in Section 8.1.4 shall be addressed. QAPD Part II Section 1.3.A states, The management position responsible for procurement is responsible for ensuring that the QA requirements established by this program description are either included or referenced N

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 31 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability (as appropriate) in related Procurement sponsored program areas. This requirement is satisfied.

NQAP 8.1.3B is addressed as above.

8.1.4 Source Requirement Documents NQAP Appendix B Table 1 x

RG 1.33 R2 / ANSI N18.7-1976/ANS-3.2 Section 5.2.13; 5.2.13.1 x

RG 1.28 R3 / ANSI N45.2-1971.

Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

Section 5 x

RG 1.123 R1 / ANSI N45.2.13-1977 Section 3. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x 10CFR50 Appendix B Criterion IV x

10CFR50.49 x

10CFR72.148 x

ASME Section III Div 1 Art. NCA 4000 QAPD Part II Section 4.2 x

NQA-1-2015 Part I Requirement 4 QAPD Part IV x

RG 1.33 R3 x

RG 1.28 R5 N

The QAPD conforms to ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3 and NQA-1-2015 as endorsed by RG1.28, Revision 5. Through the various endorsed revisions of NQA-1, unnecessary detail at the program level, examples, or redundant information was removed. The removal of this information is acceptable and does not reduce compliance of the QAPD to the NQA-1-2015 standard.

8.2 Control of Purchased Material, Equipment, and Services 8.2.1 General Part II Section 7 NQAP 8.2.1 is aligned with QAPD Part II Section 7.1.

N Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 32 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability 8.2.2 Program Elements Part II Section 7 Part II Section 2 Part II Section 2 and 7.2 Part II Section 7.1 NQAP 8.2.2A.1 and 2 is addressed in QAPD Part II Section 7.1. NQAP 8.2.2A.3 requirement for an ASL is addressed in QAPD Part II Section 2 (requirement to have an ASL is not specifically addressed).

NQAP 8.2.2B requirements for bid evaluation and awards are addressed in NQA-1-2015 Part I Requirement 7 (300).

NQAP 8.2.2C.1 requirements are addressed in QAPD Part II Sections 2 and 7.3.

NQAP 8.2.2C.2 requirements for effectiveness assessment (except assessment of the certification of conformance) is addressed in QAPD Part II Section 7.2.

NQAP 8.2.2C.3 requirements are addressed in QAPD Part II Section 7.2.C.

NQAP 8.2.2D.1 is addressed in QAPD Part II Section 7.2.

NQAP 8.2.2D.2 is addressed in QAPD Part II Section 7.2.

NQAP 8.2.2D.3 is addressed in QAPD Part II Section 7.2.

NQAP 8.2.2E is aligned with QAPD Part II Section 7.2.

N Bid evaluation requirements addressed in NQA-1-2015 Part I Requirement 7 (300).

Graded approach specific to receipt inspection as presented in NQAP 8.2.2F not discussed in QAPD or NQA-1-2015.

NQA-1-2015 Part III Subpart 3.1-2.1 (502) provides general guidance for the use of a graded approach for control and verification of quality activities.

NQAP 8.2.2G requirements regarding maintaining disposition of received items is addressed in NQA-1-2015 Part II Subpart 2.2 (503).

The QAPD conforms to ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3 and NQA-1-2015 as endorsed by RG1.28, Revision 5. Through the various endorsed revisions of NQA-1, unnecessary detail at the program level, examples, or redundant information was removed. The removal of this information is acceptable and does not reduce compliance of the QAPD to the NQA-1-2015 standard.

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 33 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability NQAP 8.2.2F: QAPD Part II Section 7.2.C.4 lists receipt inspection as a means of accepting purchased items or services.

NQAP 8.2.2G requirements regarding maintaining disposition addressed in NQA-1-2015 Part II Subpart 2.2 (503).

8.2.3 Responsibilities Part II Section 1.3.A Part II Section 1.4.C NQAP 8.2.3A states, the management position responsible for procurement is responsible for the development of programs to control purchased material. equipment, and services. The program elements of Section 8.2.2 and the related source requirements contained within the documents listed in Section 8.2.4 shall be addressed. QAPD Part II Section 1.3.A states, The management position responsible for procurement is responsible for ensuring that the QA requirements established by this program description are either included or referenced (as appropriate) in related Procurement sponsored program areas. This requirement is satisfied.

NQAP 8.2.3B is addressed as above.

NQAP 8.2.3C states, The General Manager, QA, is responsible for evaluation and selection of suppliers, acceptance of procured items (as described in Section 9.1.2C), periodic assessment of suppliers using graded approach criteria, and maintenance of an Acceptable Suppliers List (ASL). This requirement is broadly N

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 34 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability addressed in QAPD Part II Section 1.4.C where vendor oversight is listed among the responsibilities for the GMQA.

8.2.4 Source Requirement Documents NQAP Appendix B Table 1 x

RG 1.33 R2 / ANSI N18.7-1976/ANS-3.2 Section 5.2.13.2 x

RG 1.28 R3 / ANSI N45.2-1971 Section 8. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.38 R2 / ANSI N45.2.2-1972 Section 5. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.30 R0 / ANSI N45.2.4-1972 Section 2.2. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.123 R1 / ANSI N45.2.13-1977.

Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x 10CFR21 x

10CFR50 Appendix B Criterion VII x

10CFR72.154 x

ASME Section III Div 1 Art. NCA 4000 QAPD Part II Section 7.3 x

NQA-1-2015 Part I Requirement 7 QAPD Part IV x

RG 1.33 R3 x

RG 1.28 R5 N

The QAPD conforms to ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3 and NQA-1-2015 as endorsed by RG1.28, Revision 5. Through the various endorsed revisions of NQA-1, unnecessary detail at the program level, examples, or redundant information was removed. The removal of this information is acceptable and does not reduce compliance of the QAPD to the NQA-1-2015 standard.

8.3 Identification and Control of Materials, Part II Section 8 NQAP 8.3.1 and QAPD Part II Section 8 are aligned.

N Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 35 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability Parts, and Components 8.3.1 General 8.3.2 Program Elements Part II Section 8 NQAP 8.3.2 is addressed in QAPD Part II Section 8.1.

N 8.3.3 Responsibilities Part II Section 1.3.A NQAP 8.3.3 responsibilities for the management position responsible for procurement is broadly addressed in QAPD Part II Section 1.3.A. This section refers related Procurement sponsored program areas.

N 8.3.4 Source Requirement Documents NQAP Appendix B Table 1 x

RG 1.33 R2 / ANSI N18.7-1976/ANS-3.2 Section 5.2.13.3 x

RG 1.28 R3 / ANSI N45.2-1971 Section 9. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.38 R2 / ANSI N45.2.2-1972.

Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.94 R1 / ANSI N45.2.5-1974.

x RG 1.116 R0-R / ANSI N45.2.8-1975 x

10CFR50 Appendix B Criterion VIII x

10CFR72.156 x

ASME Section III Div 1 Art. NCA 4000 QAPD Part II Section 8.2 x

NQA-1-2015 Part I Requirement 8 QAPD Part IV x

RG 1.33 R3 x

RG 1.28 R5 x

RG 1.94 R1 x

RG 1.116 R0-R N

The QAPD conforms to ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3 and NQA-1-2015 as endorsed by RG1.28, Revision 5. Through the various endorsed revisions of NQA-1, unnecessary detail at the program level, examples, or redundant information was removed. The removal of this information is acceptable and does not reduce compliance of the QAPD to the NQA-1-2015 standard.

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 36 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability 9.0 Control of Plant Activities 9.1 Inspection and Line Verification 9.1.1 General Part II Section 10.1 NQA-1-2015 Part I Requirement 2 (100a)

NQAP 9.1.1 is addressed in QAPD Part II Section 10.1. QAPD does not specifically address line verification. NQA-1-2015 Part I Requirement 2 (100a) requires QA programs contain measures for the verification of quality.

N The QAPD conforms to ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3 and NQA-1-2015 as endorsed by RG1.28, Revision 5. Through the various endorsed revisions of NQA-1, unnecessary detail at the program level, examples, or redundant information was removed. The removal of this information is acceptable and does not reduce compliance of the QAPD to the NQA-1-2015 standard.

NQA-1-2015 Part I Requirement 2 (100a) requires QA programs contain measures for the verification of quality.

9.1.2 Program Elements Part II Section 10, 10.2 NQAP 9.1.2A requirements for line verification are addressed under the umbrella of inspection. Documentation, control, and qualification requirements are also addressed in QAPD Part II Section 10.2.

NQAP 9.1.2B requirement that inspection be controlled is addressed in QAPD Part II Section 10.2.

Specific requirements in NQAP 9.1.2B.1 through 5 are addressed as follows:

1. NQAP 9.1.2B.1 states, Inspections to verify conformance to codes, standards, and design output shall be required for each operation.

Factors used to determine the extent of inspections to be performed are N

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 37 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability NQA-1-2015 Part I Requirement 10 listed in Section 5.2 of this NQAP.

This requirement is broadly addressed in the introductory paragraph of QAPD Part II Section 10.1.B, which states in part, Types of inspections may include those verifications related to procurement,, as well as construction, installation, maintenance, modification, in-service, and operations activities.

2. NQAP 9.1.2B.2 states, Inspection hold points, witness points, and notification points shall be used as required to verify in-process or final achievement of quality. When graded approach criteria are applied to design/regulatory required inspection activities, line verification will be required. The QA organization shall independently verify line organization performance to ensure adequacy of line verifications. QAPD Part II Section 10.2 states, 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, determined applicable acceptance criteria, the frequency of inspection to be applied, and identification of special tools needed to perform the inspection. The Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 38 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability NQA-1-2015 Part I Requirement 12 NQAP requirement is broadly addressed in this section.

3. NQAP 9.1.2B.3 is addressed in NQA-1-2015 Part I Requirement 10 (500).

4. NQAP 9.1.2B.4 is addressed in NQA-1-2015 Part I Requirement 10 (402).

5. NQAP 9.1.2B.5 is addressed in QAPD PART II Section 10.1.

NQAP 9.1.2C requirements for inspection performance by qualified personnel is addressed in NQA-1-2015 Part I Requirement 10 (100).

M&TE requirements in NQAP 9.1.2C.3 are addressed in NQA-1-2015 Part I Requirement 12 (100).

NQAP 9.1.2C.4 is addressed in NQA-1-2015 Part I Requirement 10 (300).

NQAP 9.1.2D is aligned with QAPD Part II Section 10.3 and NQA-1-2015 Part I Requirement 10 (800).

9.1.3 Responsibilities Part II Section 1.3.B NQAP 9.1.3A states, The management position responsible for inspection, testing, monitoring and analysis and the General Manager, QA are responsible for including the applicable QA program elements in Section 9.1.2 and the related source requirements found in the documents listed in Section 9.1.4, within the inspection program. The General Manager, QA N

The QAPD conforms to ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3 and NQA-1-2015 as endorsed by RG1.28, Revision 5. Through the various endorsed revisions of NQA-1, unnecessary detail at the program level, examples, or redundant information was removed. The removal of this information is acceptable and does not Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 39 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability reviews and approves the inspection program to ensure inclusion of QA requirements for their respective site.

NQAP 9.1.3B states, The management position responsible for inspection, testing, monitoring and analysis and the Senior Vice President, Nuclear Engineering and Operations Support are responsible for including the applicable QA program elements in Section 9.1.2 and the related source requirements found in the documents listed in Section 9.1.4, within the line verification program.

NQAP 9.1.3C states, The management position responsible for nuclear engineering is responsible for providing qualitative /

quantitative criteria in design output documents, which are incorporated in implementing procedures. Specific responsibilities relative to qualitative /

quantitative criteria for the management position responsible for nuclear engineering are not discussed in the QAPD.

NQAP 9.1.3D states, For CRN, the management position responsible for New Nuclear Engineering is responsible for providing qualitative / quantitative criteria in design output documents, which are incorporated in implementing procedures.

Specific responsibilities relative to qualitative

/ quantitative criteria for the management reduce compliance of the QAPD to the NQA-1-2015 standard.

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 40 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability position responsible for New Nuclear Engineering are not discussed in the QAPD.

NQAP 9.1.3E states, The General Manager, QA is responsible for establishing and implementing programs for training and certification of personnel performing QC activities. Specific responsibilities of GMQA relative to training and certification of personnel performing QC activities are not discussed in the QAPD. QAPD Part II Section 10.4 state, TVA Nuclear has established qualification programs for personnel performing quality inspections.

This broadly addresses training and certification, but does not include the specific requirements of NQAP 9.1.3E.

9.1.4 Source Requirement Documents NQAP Appendix B Table 1 x

RG 1.8 R2 / ANSI N18.1-1971 and ANSI/ANS 3.1-1981 x

RG 1.33 R2 / ANSI N18.7-1976/ANS-3.2 Section 5.2.8 & 5.2.17 x

RG 1.28 R3 / ANSI N45.2-1971 Section 11. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.37 R0 / ANSI N45.2.1-1973.

Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.38 R2 / ANSI N45.2.2-1972 Section 5.2 & 7.4. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

N The QAPD conforms to ANSI/ANS 3.2-2012 as endorsed by RG 1.33, Revision 3; ANSI/ANS 3.1-2014 as endorsed by RG 1.8, Revision 4; and NQA-1-2015 as endorsed by RG1.28, Revision 5. Through the various endorsed revisions of NQA-1, unnecessary detail at the program level, examples, or redundant information was removed. The removal of this information is acceptable and does not reduce compliance of the QAPD to the NQA 2015 standard.

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 41 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability x

RG 1.39 R2 / ANSI N45.2.3-1973.

Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.30 R0 / ANSI N45.2.4-1972 Section 2.4, 5.1, 6.1, 7.0.

Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.94 R1 / ANSI N45.2.5-1974 Section 2.3, 4, 5, 6 x

RG 1.58 R1 / ANSI/ASME N45.2.6-1978. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.116 R0-R / ANSI N45.2.8-1975 Section 2.3, 3, 4, 5 x

RG 1.123 R1 / ANSI N45.2.13-1976 Section 7 & 10. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x 10CFR50 Appendix B Criterion X x

10CFR72.160 x

ASME Section III Div 1 Art. NCA 4000 x

ASME Section XI QAPD Part II Section 10.5 x

NQA-1-2015 Part I Requirement 10 x

NQA-1-2015 Part II, Subparts 2.5 &

2.8 QAPD Part IV x

RG 1.8 R4 x

RG 1.33 R3 x

RG 1.28 R5 x

RG 1.94 R1 x

RG 1.116 R0-R Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 42 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability 9.2 Quality Assurance Assessments 9.2.1 General Part II Section 2.4 Quality Assurance Assessment is not addressed in the QAPD. The only assessment activities are with respect to vendors. QAPD Section 2.4 states the GMQA "...will assess the adequacy and effective implementation of QA program requirements..."

R The QAPD conforms to ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3 and NQA-1-2015 as endorsed by RG1.28, Revision 5. Through the various endorsed revisions of NQA-1, unnecessary detail at the program level, examples, or redundant information was removed. The removal of this information is acceptable and does not reduce compliance of the QAPD to the NQA-1-2015 standard.

9.2.2 Program Elements Part II Section 2.4 Quality Assurance Assessment is not addressed in the QAPD. The only assessment activities are with respect to vendors. QAPD Part II Section 2.4 states the GMQA "...will continually assess the adequacy and effective implementation of QA program requirements..."

R The QAPD conforms to ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3 and NQA-1-2015 as endorsed by RG1.28, Revision 5. Through the various endorsed revisions of NQA-1, unnecessary detail at the program level, examples, or redundant information was removed. The removal of this information is acceptable and does not reduce compliance of the QAPD to the NQA-1-2015 standard.

9.2.3 Responsibilities Part II Section 2.4 Quality Assurance Assessment is not addressed in the QAPD. The only assessment activities are with respect to vendors. QAPD Part II Section 2.4 states the GMQA "...will continually assess the adequacy and effective implementation of QA program requirements..."

R The QAPD conforms to ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3 and NQA-1-2015 as endorsed by RG1.28, Revision 5. Through the various endorsed revisions of NQA-1, unnecessary detail at the program level, examples, or redundant information was removed. The removal of this information is acceptable and does not reduce compliance of the QAPD to the NQA-1-2015 standard.

9.2.4 Source Requirement Documents Part II Section 2.4 Quality Assurance Assessment is not addressed in the QAPD. The only assessment activities are with respect to R

The QAPD conforms to ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3 and NQA-1-2015 as endorsed by RG1.28, Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 43 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability vendors. QAPD Part II Section 2.4 states the GMQA "...will continually assess the adequacy and effective implementation of QA program requirements..."

Revision 5. Through the various endorsed revisions of NQA-1, unnecessary detail at the program level, examples, or redundant information was removed. The removal of this information is acceptable and does not reduce compliance of the QAPD to the NQA-1-2015 standard.

9.3 Control of Special Processes 9.3.1 General Part II Section 9 NQAP 9.3.1 is broadly addressed by the introductory paragraph of QAPD Part II Section 9. The QAPD and NQA-1-2015 do not specifically state that special processes are determined by the Engineering organization.

N 9.3.2 Program Elements Part II Section 9 NQA-1-2015 Part I Requirement 9 NQAP 9.3.2A lists welding, forming and bending, heat treating, chemical cleaning, protective coatings, and non-destructive examination (NDE) as special processes.

QAPD Part II Section 9 does not specify examples of special processes. NQA-1-2015 Part I Requirement 9 (100) lists welding, heat treating, and nondestructive examination as examples. QAPD Part II Section 9 and NQA-1-2015 Part I Requirement 9 (201) address the requirement that special processes be controlled.

NQAP 9.3.2B is addressed in QAPD Part II Section 9.1.

NQAP 9.3.2C is addressed in NQA-1-2015 Part I Requirement 9 (203).

NQAP 9.3.2D.1 is addressed in QAPD Part II Section 9.1.

N Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 44 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability NQAP 9.3.2D.2 is addressed in NQA-1-2015 Part I Requirement 9 (201).

NQAP 9.3.2D.3 is broadly addressed in QAPD Part II Section 9, which states, Records are maintained as appropriate for the currently qualified personnel, processes, and equipment for each special process.

NQAP 9.3.2E requirements regarding results of examinations are broadly addressed as records in QAPD Part II Section 9.1.

9.3.3 Responsibilities NQAP 9.3.3A states, The management position responsible for nuclear engineering is responsible for development of programs for control of special processes. Specific responsibilities in this section are not discussed in the QAPD nor in NQA-1-2015.

NQAP 9.3.3B states, The management position responsible for Inspection Services Organization (ISO) is responsible for interpretation of NDE results when not achievable at the site level, and development and implementation of NDE methods and procedures. The management position responsible for ISO is also responsible for the qualification or certification of ISO NDE procedures, equipment, and personnel.

Specific responsibilities in this section are not discussed in the QAPD.

NQAP 9.3.3C states, The General Manager, QA reviews and approves the inspection R

The QAPD conforms to ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3 and NQA-1-2015 as endorsed by RG1.28, Revision 5. Through the various endorsed revisions of NQA-1, unnecessary detail at the program level, examples, or redundant information was removed. The removal of this information is acceptable and does not reduce compliance of the QAPD to the NQA-1-2015 standard.

Reduction in level of detail to be consistent with other utilities QAPs.

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 45 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability program for control of special processes to ensure inclusion of QA requirements and is also responsible for the development of upper tier QA requirements for the NED program for licensed units (refer to Section 9.3.2). Specific responsibilities in this section are not discussed in the QAPD.

QAPD Part I Section 1.3.6 broadly addresses GMQA responsibilities in implementation of QAPD requirements.

NQAP 9.3.3D states, The management position responsible for nuclear engineering is responsible for coordinating with appropriate organizations and determining which processes are to be controlled as special processes and for developing engineering requirements for NDE. Specific responsibilities in this section are not discussed in the QAPD.

NQAP 9.3.3E states, The management position responsible for nuclear engineering is responsible for the qualification or certification of TVA Nuclear special process procedures, equipment, and personnel for all areas other than NDE. Specific responsibilities in this section are not discussed in the QAPD. QAPD Part II Section 10.3 state, TVA Nuclear has established qualification programs for personnel performing quality inspections.

This broadly addresses training and certification, but does not include the specific requirements of NQAP 9.3.3E.

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 46 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability 9.3.4 Source Requirement Documents NQAP Appendix B Table 1 x

RG 1.33 R2 / ANSI N18.7-1976/ANS-3.2 Section 5.2.12 &

5.2.18 x

RG 1.28 R3 / ANSI N45.2-1971 Section 10. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.58 R1 / ANSI N45.2.6-1978.

Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x 10CFR50 Appendix B Criterion IX x

10CFR72.158 x

ASME Section III Div 1 Art. NCA 4000 x

ASME Section V x

ASME Section IX x

ASME Section XI x

AWS Structural Welding Code D1.1 x

AISC Specification for the Design, Fabrication, and Erection of Structural Steel for Building x

ASNT SNT-TC-1A-2006 QAPD Part II Section 9.2 x

NQA-1-2015 Part I Requirement 9 QAPD Part IV x

RG 1.8 R4 x

RG 1.33 R3 x

RG 1.28 R5 x

RG 1.94 R1 x

RG 1.116 R0-R N

The QAPD conforms to ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3 and NQA-1-2015 as endorsed by RG1.28, Revision 5. Through the various endorsed revisions of NQA-1, unnecessary detail at the program level, examples, or redundant information was removed. The removal of this information is acceptable and does not reduce compliance of the QAPD to the NQA-1-2015 standard.

9.4 Test Control 9.4.1 General Part II Section 11 Addressed in QAPD Part II Section 11.1.

N Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 47 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability 9.4.2 Program Elements Part II Section 11 NQA-1-2015 Part I Requirement 11 NQAP 9.4.2A lists the following types of tests that must be included in the test control program:

x Design qualification tests x

product acceptance (proof) prior to installation x

pre-operational tests x

construction tests x

start-up tests x

surveillance tests x

functional tests x

post maintenance tests x

post modification tests x

special tests QAPD Part II Section 11.1.B provides a broad statement, These programs include criteria for determining when testing is required, such as proof tests before installation, pre-operational tests, post-maintenance tests, post-modification tests, in-service tests, and operational tests (such as surveillance tests required by Plant Technical Specifications), to demonstrate that performance of plant systems is in accordance with design. QAPD does not explicitly list the types of test listed in the NQAP.

QAPD Part II Section 11 does not address requirements of NQAP 9.4.2B.2. These requirements are addressed in NQA-1-2015 Part I Requirement 11 (200a).

N Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 48 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability NQAP 9.4.2B.3 requirements not specifically addressed. NQA-1-2015 Part I Requirement 11 (200) and (300) broadly addresses this requirement.

NQAP 9.4.2C requirements are addressed in QAPD Part II Section 11.3 and NQA-1-2015 Part I Requirement 11 (600) and (601).

NQAP 9.4.2D requirements are addressed in NQA-1-2015 Part I Requirement 11 (500).

NQAP 9.4.2E requirements are addressed in NQA-1-2015 Part I Requirement 11 (600).

9.4.3 Responsibilities NQAP 9.4.3A states, The management position responsible for nuclear engineering is responsible the development of test control programs. The program elements in Section 9.4.2 and the related source requirements contained within the documents listed in Section 9.4.4 shall be addressed. Specific responsibilities in this section are not discussed in the QAPD.

NQAP 9.4.3B states, The management position responsible for a nuclear site, (delegated to the management position responsible for site engineering) is responsible for reviewing test results and specifying through design output documents the acceptance criteria for tests necessary to demonstrate an items compliance with design parameters for initial acceptance and major modifications for licensed units.

R The QAPD conforms to ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3 and NQA-1-2015 as endorsed by RG1.28, Revision 5. Through the various endorsed revisions of NQA-1, unnecessary detail at the program level, examples, or redundant information was removed. The removal of this information is acceptable and does not reduce compliance of the QAPD to the NQA-1-2015 standard.

Reduction in level of detail to be consistent with other utilities QAPs.

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 49 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability Specific responsibilities in this section are not discussed in the QAPD.

NQAP 9.4.3C states, The management position responsible for a nuclear site, (delegated to the management position responsible for site engineering) is responsible for the development of tests (startup and operations phase) which incorporate engineering requirements and for the conduct of tests, including leak tests (operations phase). They are also responsible for documenting, evaluating, and determining acceptability of test results.

Specific responsibilities in this section are not discussed in the QAPD.

NQAP 9.4.3D states, The General Manager, QA is responsible for oversight of the test control program (i.e., test performance, test results and acceptability of tests). Specific responsibilities in this section are not discussed in the QAPD. QAPD Part I Section 1.4.C broadly addresses GMQA responsibilities in implementation of QAPD requirements.

9.4.4 Source Requirement Documents NQAP Appendix B Table 1 x

RG 1.33 R2 / ANSI N18.7-1976/ANS-3.2 Section 5.2.8 & 5.2.19 x

RG 1.28 R3 / ANSI N45.2-1973 Section 12. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

N TVA commits to NQA-1-2015 as endorsed by the NRC in Regulatory Guide 1.28, Revision 5, and ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3.

Commitments to the various regulatory guides and standards will be upgraded with exceptions noted in the QAPD. TVA will no longer commit to regulatory guides Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 50 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability x

RG 1.37 R0 / ANSI N45.2.1-1973.

Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.38 R2 / ANSI N45.2.2-1972 Section 2.3. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.30 R0 / ANSI N45.2.4-1972.

Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.94 R1 / ANSI N45.2.5-1974 x

RG 1.58 R1 / ANSI N45.2.6-1978.

Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.116 R0-R / ASNI 45.2.8-1975 x

10CFR50 Appendix B Criterion XI x

10CFR72.162 x

ASME Section XI QAPD Part II Section 11.4 x

NQA-1-2015 Part I Requirement 11 QAPD Part IV x

RG 1.33 R3 x

RG 1.28 R5 x

RG 1.94 R1 x

RG 1.116 R0-R endorsing ANSI N45.2-series as they will be superseded by NQA-1-2015.

9.5 Control of M&TE and Installed Safety-Related I&C Devices 9.5.1 General Part II Section 12 NQAP 9.5.1 addressed in QAPD Part II Section 12.1.

N 9.5.2 Program Elements Part II Section 12 NQAP 9.5.2A.1 is addressed in QAPD Part II Section 12.1.

R The QAPD conforms to ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3 and NQA-1-2015 as endorsed by RG1.28, Revision 5. Through the various endorsed Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 51 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability NQA-1-2015 Part I Requirement 12 NQAP 9.5.2A.2 requirements for calibration procedures is broadly addressed in QAPD Part II Section 12.2. Specific requirements are addressed in NQA-1-2015 Part I Requirement 12 (300).

NQAP 9.5.2A.3 requirements are broadly addressed in QAPD Part II Section 12.2.

NQA-1-2015 Part I Requirement 12 (300) addresses calibration intervals.

NQAP 9.5.2A.4 is addressed in QAPD Part II Section 12.1 and NQA-1-2015 Part I Requirement 12 (400).

NQAP 9.5.2A.5 is addressed in QAPD Part II Section 12.2 and NQA-1-2015 Part I Requirement 12 (302).

NQAP 9.5.2A.5 is addressed in QAPD Part II Section 12.3 and NQA-1-2015 Part I Requirement 12 (303.1).

NQAP 9.5.2B requirements for M&TE is broadly addressed in QAPD Part II Sections 12,1, 12.2, and 12.3. Specific requirements in NQAP 9.5.2B are not explicitly addressed in the QAPD. NQA-1-2015 Part I Requirement 12 (300) contains specific requirements for calibration and control of M&TE.

NQAP 9.5.2C requirements for installed safety-related I&C devices are broadly addressed in QAPD Part II Section 12.3.

revisions of NQA-1, unnecessary detail at the program level, examples, or redundant information was removed. The removal of this information is acceptable and does not reduce compliance of the QAPD to the NQA-1-2015 standard.

Reduction in level of detail to be consistent with other utilities QAPs.

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 52 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability This section makes one reference to devices installed in the facility (first sentence). The remainder of the Section speaks to M&TE.

NQA-1-2015 is silent to specific requirements of installed safety-related Instrumentation & Control (I&C) devices. 10 CFR 50.49 (EQ) controls are not addressed.

NQAP 9.5.2D is not specifically addressed in the QAPD or NQA-1-2015.

9.5.3 Responsibilities Part II Section 1.4.A NQAP 9.5.3A states, The management position responsible for a nuclear site is responsible for the development of controls for M&TE and installed safety-related I&C devices. The program elements in Section 9.5.2 and the related source requirements contained within the documents listed in Section 9.5.4 shall be addressed. QAPD Part II Section 1.4.A.1.b contains broad statements for the Site Vice President.

Specifically, Supplementing programs at licensed units ensuring QA requirements of this program description are appropriately established in licensed units site procedures.

NQAP 9.5.3B. states, The management position responsible for a nuclear site, (delegated to the management position responsible for site engineering) is responsible for providing qualitative/quantitative criteria in design output documents for licensed plants.

QAPD Part II Section 1.4.A.1.b contains broad statements for the Site Vice President.

R The QAPD conforms to ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3 and NQA-1-2015 as endorsed by RG1.28, Revision 5. Through the various endorsed revisions of NQA-1, unnecessary detail at the program level, examples, or redundant information was removed. The removal of this information is acceptable and does not reduce compliance of the QAPD to the NQA-1-2015 standard.

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 53 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability Specifically, Supplementing programs at licensed units ensuring QA requirements of this program description are appropriately established in licensed units site procedures.

NQAP 9.5.3C. states, For CRN, the responsibility for providing qualitative/quantitative criteria in design output documents is assigned to the management position responsible for New Nuclear Engineering. Activities associated with CRN are discussed in QAPD Part II, Section 1, second paragraph. CRN is not named within the QAPD, but it is part of New Nuclear Projects organization.

9.5.4 Source Requirement Documents NQAP Appendix B Table 1 x

RG 1.33 R2 / ANSI N18.7-1976/ANS-3.2 Section 5.2.16 x

RG 1.28 R3 / ANSI N45.2-1971 Section 13. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.37 R0 / ANSI N45.2.1-1973 Section 2.5. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.38 R2 / ANSI N45.2.2-1972 Section 2.5. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.30 R0 / ANSI N45.2.4-1972 Section 2.5. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

N TVA commits to NQA-1-2015 as endorsed by the NRC in Regulatory Guide 1.28, Revision 5, and ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3.

Commitments to the various regulatory guides and standards will be upgraded with exceptions noted in the QAPD. TVA will no longer commit to regulatory guides endorsing ANSI N45.2-series as they will be superseded by NQA-1-2015 except as noted below.

TVA will maintain its commitment to Regulatory Guide 1.94, Revision 1 (4/1976).

TVA will maintain its commitment to Regulatory Guide 1.116, Revision 0-R (5/1977).

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 54 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability x

RG 1.94 R1 / ANSI N45.2.5-1974 Section 2.5 x

RG 1.116 R0-R / ASNI 45.2.8-1975 Section 2.8 x

RG 1.123 R1 / ANSI N45.2.13-1976 Section 7.4. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x 10CFR50 Appendix B Criterion XII x

10CFR72.164 x

ASME Section III DIV 1 Art. NCA 4000 QAPD Part II Section 12.4 x

NQA-1-2015 Part I Requirement 12 QAPD Part IV x

RG 1.33 R3 x

RG 1.28 R5 x

RG 1.94 R1 x

RG 1.116 R0-R 9.6 Handling, Storage, and Shipping 9.6.1 General Part II Section 13 Addressed in QAPD Part II Section 13.1.

N 9.6.2 Program Elements Part II Section 13 NQAP 9.6.2A through C is addressed in QAPD Part II Section 13.1.

NQAP 9.6.2D is addressed in QAPD Part II Section 13.1.

N 9.6.3 Responsibilities Part II Section 1.3.A NQAP 9.6.3A states, The management position responsible for procurement is responsible for the development of program controls for handling, storing, and shipping.

The program elements in Section 9.6.2 and N

The QAPD conforms to ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3 and NQA-1-2015 as endorsed by RG1.28, Revision 5. Through the various endorsed revisions of NQA-1, unnecessary detail at Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 55 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability the related source requirements contained within the documents listed in Section 9.6.4 shall be addressed. QAPD Part II Section 1.3.A states, The management position responsible for procurement is responsible for ensuring that the QA requirements established by this program description are either included or referenced (as appropriate) in related Procurement sponsored program areas. This requirement is satisfied.

NQAP 9.6.3B states, The management position responsible for procurement is responsible for implementation of programs for handling, storage, shipping, and issuance of materials. QAPD Part II Section 1.3.A states, The management position responsible for procurement is responsible for ensuring that the QA requirements established by this program description are either included or referenced (as appropriate) in related Procurement sponsored program areas. This requirement is satisfied.

NQAP 9.6.3C states, The management position responsible for nuclear engineering is responsible for establishing storage, handling, and shipping requirements and preventive maintenance requirements during storage. This requirement is not specifically addressed in the QAPD.

the program level, examples, or redundant information was removed. The removal of this information is acceptable and does not reduce compliance of the QAPD to the NQA-1-2015 standard.

Reduction in level of detail to be consistent with other utilities QAPs.

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 56 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability 9.6.4 Source Requirement Documents NQAP Appendix B Table 1 x

RG 1.33 R2 / ANSI N18.7-1976/ANS-3.2 Section 5.2.13.4 x

RG 1.28 R3 / ANSI N45.2-1971 Section 14. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.38 R2 / ANSI N45.2.2-1972.

Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.39 R2 / ANSI N45.2.3-1973 Section 3.3. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.30 R0 / ANSI N45.2.4-1972 Section 2.2. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.94 R1 / ANSI N45.2.5-1974 x

RG 1.116 R0-R / ASNI 45.2.8-1975 Section 2.5 x

10CFR50 Appendix B Criterion XIII x

10CFR72.166 x

ASME Section III DIV 1 Art. NCA 4000 QAPD Part II Section 13.3 x

NQA-1-2015 Part I Requirement 13 x

NQA-1-2015 Part II Subparts 2.1, 2.2, and 2.3 x

NQA-1-2015 Part II Subpart 3.2-2.1 QAPD Part IV x

RG 1.33 R3 x

RG 1.28 R5 x

RG 1.94 R1 N

TVA commits to NQA-1-2015 as endorsed by the NRC in Regulatory Guide 1.28, Revision 5, and ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3.

Commitments to the various regulatory guides and standards will be upgraded with exceptions noted in the QAPD. TVA will no longer commit to regulatory guides endorsing ANSI N45.2-series as they will be superseded by NQA-1-2015 except as noted below.

TVA will maintain its commitment to Regulatory Guide 1.94, Revision 1 (4/1976).

TVA will maintain its commitment to Regulatory Guide 1.116, Revision 0-R (5/1977).

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 57 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability x

RG 1.116 R0-R 9.7 Inspection, Test, and Operating Status 9.7.1 General Part II Section 14 NQAP 9.7.1 is addressed in QAPD Part II Section 14.1.

N 9.7.2 Program Elements Part II Section 14 NQA-1-2015 Part I Requirement 14 NQAP 9.7.2A.1 requirement for inspection and test status is addressed by NQA-1-2015 Part I Requirement 14 (100).

NQAP 9.7.2A.2 is addressed in QAP Part II Section 14 and NQA-1-2015 Part I Requirement 14 (100).

NQAP 9.7.2A.3 requirement for authority for removal of indicators is addressed in QAPD Part II Section 14.1 and NQA-1-2015 Part I Requirement 14 (100).

NQAP 9.7.2A.4 is addressed in QAPD Part II Section 14.1.

NQAP 9.7.2B is addressed in QAPD Part II Section 14.1.

N 9.7.3 Responsibilities Part II Section 1.4.A.1 NQAP 9.7.3A states, The management position responsible for a nuclear site is responsible for the development of controls to maintain inspection, test, and operating status. The program elements in Section 9.7.2 and the related source requirements contained within the documents listed in Section 9.7.4 shall be addressed. QAPD Part II Section 1.4.A.1 contains broad statements for the Site Vice President.

Specifically, 1.4.A.1.b states, N

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 58 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability Supplementing programs at licensed units ensuring QA requirements of this program description are appropriately established in licensed units site procedures. While not specifically addressing inspection, test or operating status, it does provide an umbrella under which the requirements fall.

NQAP 9.7.3B states, The management position responsible for a nuclear site, (delegated to the management position responsible for site engineering) is responsible for establishing applicable inspection and test acceptance criteria to ensure the acceptability of items is maintained. QAPD Part II Section 1.4.A.1 contains broad statements for the Site Vice President. Specifically, 1.4.A.1.b states, Supplementing programs at licensed units ensuring QA requirements of this program description are appropriately established in licensed units site procedures. While not specifically addressing inspection, test or operating status, it does provide an umbrella under which the requirements fall.

NQAP 9.7.3C states, The management position responsible for a nuclear site is responsible for the implementation of programs for maintaining inspection, test, and operating status at licensed units.

QAPD Part II Section 1.4.A.1 contains broad statements for the Site Vice President.

Specifically, 1.4.A.1.b states, Supplementing programs at licensed units Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 59 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability ensuring QA requirements of this program description are appropriately established in licensed units site procedures. While not specifically addressing inspection, test or operating status, it does provide an umbrella under which the requirements fall.

9.7.4 Source Requirement Documents NQAP Appendix B Table 1 x

RG 1.33 R2 / ANSI N18.7-1976/ANS-3.2 Section 5.2.6, 5.2.8, 5.2.14 x

RG 1.28 R3 / ANSI N45.2-1971 Section 15. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.30 R0 / ANSI N45.2.4-1972.

Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.94 R1 / ANSI N45.2.5-1974 Section 3, 4, 5 x

RG 1.116 R0-R / ASNI 45.2.8-1975 Section 4.2, 5.1 x

10CFR50 Appendix B Criterion XIV x

10CFR72.168 x

ASME Section III DIV 1 Art. NCA 4000 x

ASME Section XI x

NUTAC Report on GL 83-28 Section 2.2.2 QAPD Part II Section 14.2 x

NQA-1-2015 Part I Requirement 14 QAPD Part IV x

RG 1.33 R3 x

RG 1.28 R5 N

TVA commits to NQA-1-2015 as endorsed by the NRC in Regulatory Guide 1.28, Revision 5, and ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3.

Commitments to the various regulatory guides and standards will be upgraded with exceptions noted in the QAPD. TVA will no longer commit to regulatory guides endorsing ANSI N45.2-series as they will be superseded by NQA-1-2015 except as noted below.

TVA will maintain its commitment to Regulatory Guide 1.94, Revision 1 (4/1976).

TVA will maintain its commitment to Regulatory Guide 1.116, Revision 0-R (5/1977).

TVA also committed to ANS 3.2 section 3.14 which contains several specific requirements for inspection, test and operating status.

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 60 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability x

RG 1.94 R1 x

RG 1.116 R0-R 9.8 Control Maintenance 9.8.1 General Part V Section 4 NQAP 9.8.1 is addressed in QAPD Part V Section 4.

N 9.8.2 Program Elements Part V Section 4 NQA-1-2015 Part II Subpart 2.18 NQAP 9.8.2A is addressed in QAPD Part V Section 4.

NQAP 9.8.2B is addressed in NQA-1-2015 Part II Subpart 2.18 (202).

NQAP 9.8.2C is addressed in NQA-1-2015 Part II Subpart 2.18 (205).

NQAP 9.8.2D is addressed in NQA-1-2015 Part II Subpart 2.18 (402).

NQAP 9.8.2E is addressed in NQA-1-2015 Part II Subpart 2.18 (201).

N 9.8.3 Responsibilities Part II Section 1.4.A.1 NQAP 9.8.3A states, The management position responsible for a nuclear site is responsible for the development of the nuclear maintenance program. The program elements in Section 9.8.2 and the related source requirements contained within the documents listed in Section 9.8.4 shall be addressed. QAPD Part II Section 1.4.A.1 contains broad statements for the Site Vice President. Specifically, 1.4.A.1.b states, Supplementing programs at licensed units ensuring QA requirements of this program description are appropriately established in licensed units site procedures. While not specifically addressing maintenance, it does provide an umbrella under which the requirements fall.

R Reduction in level of detail to be consistent with other utilities QAPs.

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 61 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability NQAP 9.8.3B states, The management position responsible for a nuclear site is responsible for the implementation of the nuclear maintenance program during operations phase activities. QAPD Part II Section 1.4.A.1 contains broad statements for the Site Vice President. Specifically, 1.4.A.1.b states, Supplementing programs at licensed units ensuring QA requirements of this program description are appropriately established in licensed units site procedures. While not specifically addressing maintenance, it does provide an umbrella under which the requirements fall.

9.8.4 Source Requirement Documents NQAP Appendix B Table 1 x

RG 1.33 R2 / ANSI N18.7-1976/ANS-3.2 Section 5.2.7, 5.3.5 x

RG 1.38 R2 / ANSI N45.2.2-1972 Section 6. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.116 R0-R / ASNI 45.2.8-1975 Section 3.1. 3.5-H, 4.5-B,C x

10CFR21 x

10CFR50.49 x

ASME Section III DIV 1 Art. NCA 4000 QAPD Part V Section 4 x

NQA-1-2015 Part II Subpart 2.18 QAPD Part IV x

RG 1.33 R3 x

RG 1.28 R5 x

RG 1.94 R1 N

TVA commits to NQA-1-2015 as endorsed by the NRC in Regulatory Guide 1.28, Revision 5, and ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3.

Commitments to the various regulatory guides and standards will be upgraded with exceptions noted in the QAPD. TVA will no longer commit to regulatory guides endorsing ANSI N45.2-series as they will be superseded by NQA-1-2015 except as noted below.

TVA will maintain its commitment to Regulatory Guide 1.116, Revision 0-R (5/1977).

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 62 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability x

RG 1.116 R0-R 9.9 Plant Reviews 9.9.1 General Part V Section 2 NQAP 9.9.1 is aligned with QAPD Part V Section 2.1.

N 9.9.2 Plant Reviews Part V Section 2.2 Part V Section 3 Part V Section 3.2 Part II Section 6.3 Part II Section 6.2 Part V Section 2.2 Part II Section 6 NQAP 9.9.2A.1 is addressed in QAPD Part V Section 2.2.

NQAP 9.9.2A.2.a is addressed in QAPD Part V Section 3. Format and content requirements in Section 3.1 are not included in the NQAP. These are addressed in governing procedure NPG-SPP-01.2.

NQAP 9.9.2A.2 requirements for procedures is addressed in QAPD Part V Section 3.2, which references ANS 3.2-2012.

NQAP 9.9.2A.3 requirements for procedure changes are addressed in QAPD Part II Section 6.3.

NQAP 9.9.2A.4 requirements for procedure reviewers are addressed in QAPD Part II Section 6.2.

NQAP 9.9.2A.5 requirements are addressed in QAPD Part V Section 2.2.

NQAP 9.9.2A.6 requirements for temporary procedure changes are addressed in QAPD Part II Section 6.1. The QAPD does not specifically addressed the requirement for temporary changes be documented, reviewed, and approved within 14 days.

R The QAPD conforms to ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3 and NQA-1-2015 as endorsed by RG1.28, Revision 5. Through the various endorsed revisions of NQA-1, unnecessary detail at the program level, examples, or redundant information was removed. The removal of this information is acceptable and does not reduce compliance of the QAPD to the NQA-1-2015 standard.

Reduction in level of detail to be consistent with other utilities QAPs.

TVA Nuclear also commits to ANSI/ANS 3.2-2012 Section 3.2.2.3 as described in QAPD Part V Sections 2.1 and 2.2.

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 63 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability Part V Section 2.2 NQAP 9.9.2B requirement for PORC is contained in QAPD Part V Section 2.2.

Specific requirements for PORC in NQAP 9.9.2B.1 through 9.9.2B.7 are not addressed in the QAPD.

9.9.3 Records NQAP 9.9.3 requirements for PORC records are not specifically addressed.

N The QAPD conforms to ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3 and NQA-1-2015 as endorsed by RG1.28, Revision 5. Through the various endorsed revisions of NQA-1, unnecessary detail at the program level, examples, or redundant information was removed. The removal of this information is acceptable and does not reduce compliance of the QAPD to the NQA-1-2015 standard.

PORC records requirements are addressed in the applicable governing procedure.

10.0 Adverse Conditions 10.1 General Part II Section 16 Part II Section 15 NQAP 10.1 general requirements for adverse conditions are broadly addressed in QAPD Part II Section 16. Specific requirements that items that do not conform to requirements are controlled to prevent their inadvertent installation or use. are not addressed in QAPD Part II Section 16.

QAPD Part II Section 15 addresses control of nonconforming items.

N 10.2 Program Elements 10.2.1 Control of Non-conforming Items Part II Section 15 NQAP 10.2.1 is addressed in QAPD Part II Section 15.

N Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 64 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability 10.2.2 Corrective Action for Adverse Conditions Part II Section 16 NQAP 10.2.2A is addressed in QAPD Part II Section 16.1.

NQAP 10.2.2B states, Minor deficiencies, which may be brought into compliance within an acceptable timeframe, shall be corrected on the spot in accordance with established instructions. This requirement is broadly addressed in QAPD Part II Section 16.1.A statement to promptlycorrect conditions adverse to quality.

NQAP 10.2.2C states, Adverse conditions shall be dispositioned by organizations with defined responsibility and authority; and shall be corrected in accordance with documented plans. This requirement is not specifically addressed in the QAPD.

NQAP 10.2.2D is addressed in QAPD Part II Section 15.

NQAP 10.2.2E is addressed in QAPD Part II Section 16.1.

NQAP 10.2.2F is addressed in QAPD Part II Section 16.1.

NQAP 10.2.2G states, The satisfactory completion of corrective actions shall be verified and documented by the appropriate organization. This requirement is not addressed in the QAPD but is addressed NQA-1-2015 Part III, Subpart 3.1-16.1 (304).

R The QAPD conforms to ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3 and NQA-1-2015 as endorsed by RG1.28, Revision 5. Through the various endorsed revisions of NQA-1, unnecessary detail at the program level, examples, or redundant information was removed. The removal of this information is acceptable and does not reduce compliance of the QAPD to the NQA-1-2015 standard.

Reduction in level of detail to be consistent with other utilities QAPs.

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 65 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability NQAP 10.2.2H. states, Independent verification of corrective action implementation is performed as specified within the corrective action program. This requirement is not addressed in the QAPD but is addressed NQA-1-2015 Part III, Subpart 3.1-16.1 (304).

10.2.3 Escalation of Adverse Conditions NQA-1-2015 Part III, Subpart 3.1-16.1 Addressed in NQA-1-2015 Part III, Subpart 3.1-16.1 (306).

N 10.2.4 Tracking NQA-1-2015 Part III, Subpart 3.1-16.1 Addressed in NQA-1-2015 Part III, Subpart 3.1-16.1 (305).

N 10.2.5 Quality Trend Analysis NQA-1-2015 Part III, Subpart 3.1-16.1 Addressed in NQA-1-2015 Part III, Subpart 3.1-16.1 (307).

N 10.2.6 Stop Work Part II Section 2.9 QAPD Part II Section 2.9. provides a general statement regarding stop work authority.

The requirements of 10.2.6A, B and D are addressed. Stop work for activities that would require extensive rework or repair and continued failure to comply with technical or administrative controls is not specifically addressed.

R The QAPD conforms to ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3 and NQA-1-2015 as endorsed by RG1.28, Revision 5. Through the various endorsed revisions of NQA-1, unnecessary detail at the program level, examples, or redundant information was removed. The removal of this information is acceptable and does not reduce compliance of the QAPD to the NQA-1-2015 standard.

Reduction in level of detail to be consistent with other utilities QAPs.

10.3 Responsibilities Part II Section 1.4.B.2 NQAP 10.3A states, The management position responsible for operations support is responsible for the development, review and approval of the TVA Nuclear corrective action program. The program elements in Section 10.2 and the related source requirements contained within the documents listed in Section 10.4 shall be addressed. QAPD Part II Section 1.4.B.2 N

The QAPD conforms to ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3 and NQA-1-2015 as endorsed by RG1.28, Revision 5. Through the various endorsed revisions of NQA-1, unnecessary detail at the program level, examples, or redundant information was removed. The removal of this information is acceptable and does not Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 66 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability Part II Section 2.9 Part II Section 1.4.B.2 state that the Vice President, Operations Support provides oversight and directs the Performance Improvement organization.

While no direct reference to the Corrective Action Program is made here, the Performance Improvement organization owns the Corrective Action Program; therefore, the Vice President, Operations Support responsibility in this area is aligned.

NQAP 10.3B states, Line managers are responsible to stop any work within their areas of responsibility when a continuation of activities could meet the criteria of Section 10.2.6. Specific requirements regarding line management and stop work is not addressed in the QAPD.

NQAP 10.3C states, QA is responsible to issue a formal Stop Work Order, as required, if a line manager fails to act on a stop work condition. Stop Work Orders shall remain in effect until proper evaluation can be made and adequate correction can be applied.

While formal stop work orders are not addressed, QAPD Part II Section 2.9 provides QA the authority to stop work when required.

NQAP 10.3B states, The Vice President, Operations Support is responsible to establish and maintain trend analysis procedures for adverse conditions and the quality indicator generated by QA verification activities such as audits, assessments, reduce compliance of the QAPD to the NQA-1-2015 standard.

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 67 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability inspection, and vendor audits and surveillances. The General manager, QA is responsible for oversight and independent analysis of TVA Nuclear CAP trending.

While no direct reference to the trending analysis is made here, the Performance Improvement organization owns the Trending Program; therefore, the Vice President, Operations Support responsibility in this area is aligned. Trending is addressed in NQA-1-2015 Part II Subpart 2.18 (201k).

10.4 Source Requirements Documents NQAP Appendix B Table 1 x

RG 1.33 R2 / ANSI N18.7-1976/ANS-3.2 Section 5.2.11, 5.2.14 x

RG 1.28 R3 / ANSI N45.2-1971 Section 16, 17. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.38 R2 / ANSI N45.2.2-1975 Section 5.5. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.30 R0 / ANSI N45.2.4-1972 Section 2.6. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.64 R2 / ANSI N45.2.11-1974 Section 9 x

RG 1.123 R1 / ANSI N45.2.13-1976 Section 8, 9. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x 10CFR21 x

10CFR50 Appendix B Criterion XVI N

TVA commits to NQA-1-2015 as endorsed by the NRC in Regulatory Guide 1.28, Revision 5, and ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3.

Commitments to the various regulatory guides and standards will be upgraded with exceptions noted in the QAPD. TVA will no longer commit to regulatory guides endorsing ANSI N45.2-series as they will be superseded by NQA-1-2015.

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 68 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability x

10CFR72.170, 172 x

ASME Section III DIV 1 Art. NCA 4000 x

ASME Section XI x

NUTAC Report on GL 83-28 Section 2.2.2 QAPD Part II Section 15.3 x

NQA-1-2015 Part I Requirement 15 QAPD Part II Section 16.3 x

NQA-1-2015 Part I Requirement 16 QAPD Part IV x

RG 1.33 R3 x

RG 1.28 R5 x

RG 1.64 R2 11.0 Indoctrination,

Training, Qualification, and Certification 11.1 General Part II Section 2.6 NQAP 11.1 is aligned with QAPD Part II Section 2.6.

N 11.2 Program Elements 11.2.1 Indoctrination and Training Part II Section 2.6 NQA-1-2015 Part I Requirement 2 (500)

NQAP 11.2.1A is aligned with QAPD Part II Section 2.6.

NQAP 11.2.1B requirements for maintaining proficiency is addressed in QAPD Part II Section 2.6. Specific measures noted in NQAP 11.2.1B are not listed.

R The QAPD conforms to ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3 and NQA-1-2015 as endorsed by RG1.28, Revision 5. Through the various endorsed revisions of NQA-1, unnecessary detail at the program level, examples, or redundant information was removed. The removal of this information is acceptable and does not Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 69 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability NQAP 11.2.1C is addressed by broad statement in QAPD Part II Section 2.6, which states, To this end, TVA Nuclear establishes and maintains formal indoctrination, training, and qualification as necessary for personnel performing,

verifying, or managing activities within the scope of the QAPD to achieve initial proficiency, maintain proficiency, and adapt to technology changes, method, or job responsibilities.

NQAP 11.2.1D requirements for documentation of training scope, method, and objectives is not specifically addressed.

This may be considered Part of a formal training program.

NQAP 11.2.1E requirements for training record retention is aligned with NQA-1-2015 Part I Requirement 2 (500).

reduce compliance of the QAPD to the NQA-1-2015 standard.

11.2.2 Qualification and Certification Part II Sections 2.5 &

2.6 Part II Section 10 NQA-1-2015 Part I Requirement 2 NQAP 11.2.2 are addressed as follows:

x general requirement - QAPD Part II Section 2.6 x

inspection - QAPD Part II Section 10 x

test & examination - NQA-1-2015 Part I Requirement 2 (300) x special processes - QAPD II Section 9

x lead audits - NQA-1-2015 Part I Requirement 2 (303) as noted in QAPD Part II Section 2.6 x

Methods to assess performance of certified individuals - NQA-1-2015 Part I Requirement 2 (401 and 402)

N Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 70 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability x

Certification records - NQA-1-2015 Part I Requirement 2 (400) 11.3 Responsibilities Part II Section 1.4.B.2 NQA-1-2015 Part I Requirement 2 NQAP 11.3A states, The management position responsible for operations support is responsible for the development of the program for indoctrination and training. This is addressed with QAPD Part II Section 1.4.B.2.

NQAP 11.3B states, Other nuclear managers are responsible for delineating training requirements in their applicable areas of responsibility and providing these requirements to the management position responsible for operations support. QAPD Part II Section 2.6 says that TVA Nuclear establishes and maintains a formal indoctrination and training program, the QAPD is silent with respect to line manager requirements. NQA-1-2015 Part I Requirement 2 (100b) provides requirement for management assessment.

NQAP 11.3C states, The management position responsible for human resources (nuclear) is responsible for establishing a position qualification documentation and validation program. This requirement is aligned with QAPD Part II Section 1.5.

NQAP 11.3D states, Managers are responsible for implementing the indoctrination and training program and, as appropriate, developing a certification program and implementing the certification N

The QAPD conforms to ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3 and NQA-1-2015 as endorsed by RG1.28, Revision 5. Through the various endorsed revisions of NQA-1, unnecessary detail at the program level, examples, or redundant information was removed. The removal of this information is acceptable and does not reduce compliance of the QAPD to the NQA-1-2015 standard.

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 71 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability requirements in their area of responsibility.

Implementation of these programs is not specifically addressed in the QAPD. NQA 2015 Part I Requirement 2 (100) addresses this requirement.

NQAP 11.3E requirements address program requirements are addressed.

11.4 Source Requirements Documents NQAP Appendix B Table 1 x

RG 1.8 R2 / ANSI N18.1-1971 &

ANSI/ANS 3.1-1981 x

RG 1.33 R2 / ANSI N18.7-1976/ANS-3.2 Section 3.3 x

RG 1.28 R3 / ANSI N45.2-1971 Section 2. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.94 R1 / ANSI N45.2.5-1974 Section 2.4 x

RG 1.58 R1 / ANSI/ASME N45.2.6-1978. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.116 R0-R / ASNI 45.2.8-1975 Section 2.7 x

RG 1.123 R1 / ANSI N45.2.13-1976 Section 7.5. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.146 R0 / ANSI N45.2.23-1978 x

10CFR50 Appendix B Criterion II x

10CFR50.120 x

10CFR72.144 N

TVA commits to ANSI/ANS 3.2-2012 as endorsed by Regulatory Guide 1.33, Revision 3; ANSI/ANS 3.1-2014 as endorsed by Regulatory Guide 1.8, Revision 4; and NQA-1-2015 as endorsed by the NRC in Regulatory Guide 1.28, Revision 5. Commitments to the various regulatory guides and standards will be upgraded with exceptions noted in the QAPD. TVA will no longer commit to regulatory guides endorsing ANSI N45.2-series as they will be superseded by NQA-1-2015 except as noted below.

TVA will maintain its commitment to Regulatory Guide 1.94, Revision 1 (4/1976).

TVA will maintain its commitment to Regulatory Guide 1.116, Revision 0-R (5/1977).

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 72 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability x

ASME Section III DIV 1 Art. NCA 4000 QAPD Part II Section 2.11 x

NQA-1-2015 Part I Requirement 2 x

RG 1.28 R5 Position C.1.a QAPD Part IV x

RG 1.8 R4 x

RG 1.33 R3 x

RG 1.28 R5 x

RG 1.94 R1 x

RG 1.116 R0-R 12.0 Auditing 12.1 General Part II Section 18 NQAP 12.1 is addressed in QAPD Part II Section 18.

N 12.2 Program Elements Part II Section 18.1 NQA-1-2015 Part III Subpart 3.1-18.1 NQA-1-2015 Part I Requirement 18 NQAP 12.2A is aligned with QAPD Part II Section 18.1.

NQAP 12.2B requirements are addressed in QAPD Part II Section 18.1. Specific verbiage related to audit performance (i.e.

document review) are not specifically addressed. Additional requirements regarding review of audit results with responsible manager are addressed in Section 18.1 and NQA-1-2015 Part III Subpart 3.1-18.1 (500).

NQAP 12.2C is addressed in QAPD Part II Section 18 introductory paragraph and Section 18.1.

NQAP 12.2D addressed in NQA-1-2015 Part III Subpart 3.1-18.1 (202(d)).

NQAP 12.2E N

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 73 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability

1. Determination of internal audit scope not addressed in QAPD. Covered in NQA-1-2015 Part III Subpart 3.1-18.1 (302.5) & (402)

2. QAPD Part II Section 18

3. QAPD Part II Section 18.2, 6th paragraph addresses Fitness for Duty program. Design and Construction phase units are addressed in NQA-1-2015 Part I Requirement 18 (201.1).

4. Aligned with QAPD Part II Section 18.2.

5. Aligned with QAPD Part II Section 18.2.

6. Aligned with QAPD Part II Section 18.2.

NQAP 12.2F

1. QAPD Part II Section 18 contains a general statement regarding performance of audits to verify activities covered by the QAP are performed in conformance with established requirements and performance criteria are met. This addresses the requirement of 12.2F.1.

2. QAPD Part II Section 18.3 states that supplier audits are conducted as described in QAPD Part II Section 7.1. The requirement of 12.2F.2 is satisfied.

3. Addressed in QAPD Part II Section 18.1.

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 74 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability

4. Supplier audit result reporting is not specifically addressed. The requirement is addressed in NQA 2015 Part I Requirement 18 (500),

which states, The audit report shall be signed or otherwise endorsed by the Lead Auditor and issued to the audited organization.

5. Addressed by QAPD Part II Section 2.1.J, which says, A grace period may be applied to provisions that are required to be performed on a periodic basis, unless otherwise noted. Annual evaluations and audits that must be performed on a triennial basis are examples where a grace period could be applied.

6. Addressed in QAPD Part II Section 18.5.

7. Addressed in QAPD Part II Section 18.5.

12.3 Responsibilities Part II Section 1.4.C.

NQAP 12.3A states, The General Manager, QA, is responsible for the development of the TVA Nuclear audit program. The program elements in Section 12.2 and the related source requirements contained within the documents listed in Section 12.4 shall be addressed. This requirement is addressed in QAPD Part II Section 1.4.C.

N Part II Section 1.4.C NQAP 12.3B states, QA is responsible to conduct audits, including audits of selected suppliers, to verify implementation and adequacy of specified QA requirements.

N Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 75 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability This requirement is addressed in QAPD Part II Section 1.4.C.

12.4 Source Requirements Documents NQAP Appendix B Table 1 x

RG 1.33 R2 / ANSI N18.7-1976/ANS-3.2 Section 4.5 x

RG 1.28 R3 / ANSI N45.2-1971 Section 19. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.88 R2 / ASNI 45.2.9-1974 Section 5.7. Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.64 R2 / ANSI N45.2.11-1974 Section 11 x

RG 1.144 R1 / ANSI N45.2.12-1977.

Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.123 R1 / ANSI N45.2.13-1976.

Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x RG 1.146 R0 / ANSI N45.2.23-1978.

Requirements superseded by NQA-1-2015 as endorsed by RG 1.28 R5.

x 10CFR50 Appendix B Criterion XVIII x

10CFR72.176 x

ASME Section III DIV 1 Art. NCA 4000 x

NUTAC Report on GL 83-28 Section 2.2.2 QAPD Part II Section 18.5 x

NQA-1-2015 Part I Requirement 18 x

RG 1.28 R5 N

TVA commits to ANSI/ANS 3.2-2021 as endorsed by the NRC in Regulatory Guide (RG) 1.33, Revision 3; and NQA-1-2015 as endorsed by the NRC in RG 1.28, Revision 5. Commitments to the various regulatory guides and standards will be upgraded with exceptions noted in the QAPD. TVA will no longer commit to regulatory guides endorsing ANSI N45.2-series as they will be superseded by NQA-1-2015.

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 76 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability QAPD Part IV x

RG 1.33 R3 x

RG 1.28 R5 x

RG 1.64 R2 13.0 Computer Software and Data 13.1 General Part II Section 3.7 Aligned with QAPD Part II Section 3.7.

N 13.2 Program Elements NQA-1-2015 Part II Subpart 2.7 NQAP 13.2 A. Addressed in QAPD Part II Section 3.7 B. QAPD Part II Section 3.7.B contains a statement Pre-verified computer programs are controlled using a software configuration management process. This satisfies the requirement for controls for changes to application software and associated documentation.

Additionally, Section 3.7 states, Each application software and revision thereto are documented and approved by authorized personnel.

C. Documentation control requirements are addressed in NQA-1-2015 Part II Sub-Part 2.7.

D. Documentation requirements for software usage are addressed in NQA-1-2015 Part II Subpart 2.7 (404).

E. Documentation (as QA records) requirements are addressed in NQA-1-2015 Part II Subpart 2.7.

F. NQA-1-2015 Part II Subpart 2.7 (405) requires that control of N

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 77 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability QAPD Part II Section 3.7 approved software include an application log. This satisfies the requirement for a central list of application software.

G. QAPD Part II Section 3.7 and NQA-1-2015 Part II Subpart 2.7 (402.1) satisfy the requirement for software verification.

H. Addressed in general statements regarding software design verification in NQA-1-2015 Part II Subpart 2.7 (402.1).

I.

NQAP 13.2I states, For current active application software developed or purchased prior to October 16, 1986, only the requirements of Section 13.2B, 13.2E, and 13.2F apply. In addition, this application software shall be validated through documented tests and test results independently reviewed. This requirement is not specifically addressed in the QAPD or NQA-1-2015.

13.3 Responsibilities NQAP 13.3 states, The management position responsible for nuclear engineering is responsible for the development of controls for computer software and data.

The program elements in Section 13.2 and the criteria in Appendix E of this program description shall be addressed. Assignment of responsibility for software control to the management position responsible for nuclear engineering is not addressed.

R The QAPD conforms to NQA-1-2015 as endorsed by RG1.28, Revision 5.

Through the various endorsed revisions of NQA-1, unnecessary detail at the program level, examples, or redundant information was removed. The removal of this information is acceptable and does not reduce compliance of the QAPD to the NQA-1-2015 standard.

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 78 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability 13.4 Source Requirements Documents NQAP Appendix B Table 1 x

RG 1.64 R2 / ANSI N45.2.11-1974 Section 6.1 x

RG 1.152 / ANSI/IEEE 7-4.3.2-1982 Section 6, 7 x

10CFR50 Appendix B QAPD Part II Section 3.9 x

NQA-1-2015 Part I Requirement 3 x

RG 1.28 R5 QAPD Part IV x

RG 1.33 R3 x

RG 1.28 R5 x

RG 1.64 R2 N

TVA commits to NQA-1-2015 Part I Requirement 3 and Part II Subpart 2.7 Quality Assurance Requirements for Computer Software for Nuclear Facilities Applications as endorsed by the NRC in Regulatory Guide 1.28, Revision 5.

Commitments to the various regulatory guides and standards will be upgraded with exceptions noted in the QAPD. TVA will no longer commit to regulatory guides endorsing ANSI N45.2-series as they will be superseded by NQA-1-2015.

14.0 Reference 14.1 Regulations N

References only. Quality requirements not impacted.

14.2 Regulatory Guidance N

References only. Quality requirements not impacted.

14.3 TVA Licensing Submittal Documents N

References only. Quality requirements not impacted.

14.4 QA Manuals N

References only. Quality requirements not impacted.

14.5 Others N

References only. Quality requirements not impacted.

15.0 Definitions Part V Section 1 No commitments to address.

N Applicable definitions included in QAPD and NQA-1.

Appendix A Comparison Matrix of Quality Assurance Program Requirements with those of 10 CFR 50, Appendix B, 10 CFR72, SubPart G, Not included.

N For reference / illustration only.

Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 79 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability and Selected ANSI Standards Appendix B Regulatory Compliance Status Part II Sections 1-18 Table 1 not included. Source requirements from applicable Sections of NQA-1-2015 are included throughout the document.

Table 2 not included. Exceptions and alternatives are listed throughout the document in the applicable Sections (NQA-1 requirements). QAPD Part IV provides the regulatory commitments.

R The QAPD conforms to NQA-1-2015 as endorsed by RG1.28, Revision 5. Through the various endorsed revisions of NQA-1, unnecessary detail at the program level, examples, or redundant information was removed. The removal of this information is acceptable and does not reduce compliance of the QAPD to the NQA 2015 standard.

Appendix C Guidelines for Determination of TVA Identified Quality-Related Classifications Not included in QAPD.

N This appendix contains guidelines and documents for consideration when making quality determinations. No commitments are included.

Appendix D Scope of Nuclear Quality Assurance Program Not included - scope described in QAPD Part I Section 2.

N Illustration purposes only.

Appendix E Computer Software Part II Section 3 General statements in QAPD Part II Section 3.7 addresses software used in safety-related and designated non-safety-related applications. The specific requirements of NQAP Appendix E are not addressed in the QAPD.

N QAPD Part II Section 3.9 references applicable regulatory guides endorsed for software quality requirements.

Requirements for use of software in safety-related applications are contained in governing and implementing procedures for computer software control.

Appendix F Types of Controlled Documents and Manuals Part II Section 6 NQAP Appendix F requirements adequately addressed in QAPD Part II Section 6 N

Appendix G TVA NQAP Organization Chart Part II Figure 2.1 No change N

No change Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 80 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability Appendix H List of Abbreviations Acronyms and Abbreviations QAPD does not contain all abbreviations and acronyms as NQAP Appendix H. Additional terms are included.

N Does not affect quality requirements or commitments.

Appendix I Clinch River Nuclear Part II Section 1:

Organization 1.4.B.5 New Nuclear Program NQAP Appendix I provides the roles and responsibilities of the TVA New Nuclear Program organization. QAPD Part II Section 1 provides a general statement that the Vice President, New Nuclear Program interfaces with the Vice President, Site Project for project-related advanced nuclear technology development, Licensing, Supply Chain, and Safety during the design phase, and for corporate support during construction and operations in fulfillment of their responsibilities.

QAPD Part II Section 1.4.B.5 describes the role of the Vice President, New Nuclear Program. Additional positions described in NQAP Appendix I are not discussed in the QAPD.

N Does not affect quality requirements or commitments.

Responsibilities in positions not discussed in QAPD Part II Section 1.4.B.5 report to the Vice President, New Nuclear Program and are delegated.

NQAP, Revision 42 and QAPD, Revision 43 address CRN quality requirements until New Nuclear NNP-TR-001-NP-A (Quality Assurance Program Description for TVA New Nuclear) is approved by the NRC and implemented by TVA and the CPA is approved by the NRC.

Appendix J Clinch River Commitments and Clarifications Part IV Section 1 x

ANSI N.45.2.10-1973 x

ANSI N.45.2.11-1974 x

ANSI N.45.2.12-1977 x

ANSI N.45.2.13-1976 N

The QAPD conforms to ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3 and NQA-1-2015 as endorsed by RG1.28, Revision 5. Through the various endorsed revisions of NQA-1, unnecessary detail at the program level, examples, or redundant information was removed. The removal of this information is acceptable and does not reduce compliance of the QAPD to the NQA 2015 standard.

NQAP, Revision 42 and QAPD, Revision 43 address CRN quality requirements until Comparison of TVA-NQA-PLN89-A (NQAP) Revision 42 to Proposed QAPD Based on NQA-1-2015 CNL-24-060 E1 A3 81 of 81 NQAP Section QAPD Section Differences R -

Reduction N -

Neutral I -

Increase Basis for Acceptability x

ANSI N45.2.15-1981 x

ANSI N45.2.20-1979 x

ANSI N45.2.23-1978 x

ANSI N18.7-1976/ANS-3.2 x

GL 91-05 x

GL 89-02 QAPD Part IV x

RG 1.28 R5 x

RG 1.152 R4 New Nuclear NNP-TR-001-NP-A (Quality Assurance Program Description for TVA New Nuclear) is approved by the NRC and implemented by TVA and the CPA is approved by the NRC.

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EPID:L-2024-LLQ-0000, Supplement to Request for Approval of the Tennessee Valley Authority Nuclear Quality Assurance Program Description (Open)
Initiation Request, Request, Request, Request, Request, Request, Request Acceptance... Administration Meeting, Meeting, Meeting, Meeting, Meeting Questions 21 November 2024 10 December 2024 30 December 2024 1 April 2025 Answers 26 February 2025 Results Approval Other:
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