ML25206A088

Draft Safety Evaluation for the Dominion Energy Topical Report, Quality Assurance Program Description for Dominion Energy New Nuclear Program, Revision 1

ML25206A088
Person / Time
Site:	99902135
Issue date:	08/14/2025
From:	Banks I NRC/NRR/DNRL/NLIB
To:
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ML25206A086	List: ML25206A087
References
EPID L-2025-TOP-0004
Download: ML25206A088 (1)

Text

1 DRAFT SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION FOR THE TOPICAL REPORT, QUALITY ASSURANCE PROGRAM DESCRIPTION FOR DOMINION ENERGY NEW NUCLEAR PROGRAM, REVISION 1 EPID NO. L-2025-TOP-0004

1.0 INTRODUCTION

By letter dated February 19, 2025 (Reference 1), Dominion Energy Services, Inc (Dominion Energy), submitted Topical Report (TR) DOM-QA-3, Revision 0, Quality Assurance Program Description for Dominion Energy New Nuclear Program, (hereafter referred to as NN QAPD) to the U.S. Nuclear Regulatory Commission (NRC). In this letter, Dominion Energy requested the NRC staff review and approval of the Dominion Energy NN QAPD to be used to satisfy the quality assurance (QA) requirements for activities affecting the quality and performance of safety-related structures, systems and components (SSC), including, preliminary site licensing activities (e.g., Early Site Permit (ESP)).

The Dominion Energy NN QAPD is based on the applicable portions of both Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to Title 10 of the Code of Federal Regulations (10 CFR) Part 50 and American Society of Mechanical Engineers (ASME) NQA-1-2015, Quality Assurance Program Requirements for Nuclear Facilities, (Reference 2), as endorsed by NRC Regulatory Guide (RG) 1.28, Quality Assurance Program Criteria (Design and Construction), Revision 5 (Reference 3), with certain exceptions and clarifications.

The NRC staff held a public meeting with Dominion Energy on May 20, 2025 (Reference 4) to discuss clarification items identified as part of its review. Dominion Energy submitted Revision 1 of the NN QAPD by letter dated July 1, 2025 (Reference 5). This safety evaluation (SE) is based on the staffs review of the Dominion Energy NN QAPD Revision 1.

2.0 REGULATORY EVALUATION

The Commissions regulatory requirements related to QA programs are set forth in the following regulations:

Appendix B to 10 CFR Part 50, which establishes QA requirements for the design, manufacture, construction, and operation of SSCs that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public. The pertinent requirements of this appendix apply to all activities affecting the safety-related functions of those SSCs; these activities include designing, purchasing, fabricating, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, and modifying for nuclear power plants and fuel reprocessing plants.

2 10 CFR 52.17(a)(1)(xi), which requires an application for an ESP to include a description of the quality assurance program [QAP] applied to site-related activities for the future design, fabrication, construction, and testing of the SSCs of a facility or facilities that may be constructed on the site. The description of the [QAP] for a nuclear power plant site shall include a discussion of how the applicable requirements of Appendix B to 10 CFR Part 50 will be satisfied.

3.0 TECHNICAL EVALUATION

In evaluating the compliance of Dominion Energys NN QAPD Revision 1 with applicable requirements, the NRC staff utilized the guidance contained in NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition (SRP),

Section 17.5, Revision 1, Quality Assurance Program Description - Design Certification, Early Site Permit and New License Applicants, (Reference 6). SRP Section 17.5, Revision 1, outlines an acceptable QA program template for design certification, ESP, combined license, construction permit, and operating license applicants. SRP Section 17.5, Revision 1, describes regulatory and industry guidance determined to be acceptable methods for satisfying the requirements of Appendix B to 10 CFR Part 50.

3.1 Quality Assurance Program Description Details 3.1.1 Organization The Dominion Energy NN QAPD Revision 1 follows the guidance of SRP Section 17.5, Paragraph II.A, for providing an organizational description that includes the organizational structure, functional responsibilities, levels of authority, and interfaces for establishing, executing, and verifying Dominion Energys QA program implementation. Based on its review, the NRC staff finds that Dominion Energys NN QAPD Revision 1 establishes independence between the organization that performs oversight functions related to the QA program and the organization responsible for performing the functions to be evaluated. In addition, the Dominion Energy NN QAPD Revision 1 provides for applicable management to be responsible to size the QA organization commensurate with the duties and responsibilities assigned. The NN QAPD Revision 1 clearly describes and defines the responsibility and authority for planning, establishing, and implementing an effective overall QA program.

The NN QAPD Revision 1 provides the authority and responsibility to stop work immediately in accordance with approved procedures whenever personnel safety or SSC integrity may be jeopardized.

The Dominion Energy NN QAPD Revision 1 commits to implement the quality standards described in NQA-1-2015, Part I, Requirement 1, without further clarifications or exceptions.

As stated in RG 1.28, Revision 5, NQA-1-2015 is considered acceptable to the NRC staff and provides an adequate basis for complying with the requirements of Appendix B to 10 CFR Part 50. Based upon its review, the NRC staff finds that the description of Dominion Energys Organization, as detailed above, complies with the requirements of Criterion I, Organization, of Appendix B to 10 CFR Part 50, and, therefore, is acceptable.

3.1.2 New Nuclear Quality Assurance Program The Dominion Energy NN QAPD Revision 1 follows the guidance of SRP Section 17.5, Paragraph II.B, for establishing the necessary measures to implement a QA program to ensure

3 that activities affecting the quality and performance of safety-related SSCs are in accordance with the governing regulations and license requirements. Examples of safety-related activities include, but are not limited to, site-specific engineering related to safety-related SSCs, site geotechnical investigations, site engineering analysis, seismic analysis, and meteorological analysis.

Dominion Energy may delegate all or part of the activities for which they are responsible to others but retains overall responsibility for the QA program effectiveness. The Dominion Energy NN QAPD Revision 1 provides measures to assess the adequacy of the QA program to ensure its effective implementation, as described in Part II, Section 18 of the NN QAPD Revision 1.

In addition, consistent with SRP Section 17.5, Paragraph II.B.10, the Dominion Energy NN QAPD Revision 1 allows for the application of a grace period of 90 days to activities that must be performed on a periodic basis. Annual evaluations and audits that must be performed on a triennial basis are examples where the 90 day general period could be applied. The grace period does not allow the "clock" for a particular activity to be reset forward. In addition, the "clock" for an activity is not reset backwards by performing the activity early.

The administrative control of the Dominion Energy NN QAPD Revision 1 will be in accordance with 10 CFR 50.55(f) and 10 CFR 50.54(a) once those regulations apply. Until then, 50.4(b)(7)(ii) applies.

The Dominion Energy NN QAPD Revision 1 follows the guidance of SRP Section 17.5, Paragraphs II.S and II.T, by providing the necessary measures to establish and maintain formal indoctrination and training programs for personnel performing, verifying, or maintaining activities within the scope of the QAPD to ensure that suitable proficiency is achieved and maintained.

The Dominion Energy NN QAPD Revision 1 provides the minimum training qualification for all personnel responsible for implementation of Dominion Energys QA program.

The Dominion Energy NN QAPD Revision 1 commits to implementing the quality standards described in NQA-1-2015, Part I, Requirement 2, and the regulatory position stated in RG 1.28, Revision 5, with the following clarifications and exceptions:

NQA-1-2015, Part I, Requirement 2, Section 302, Inspection and Test - NQA-1-2015, Requirement 2 includes use of Part III, Subpart 3.1-2.3, guidance as if it were part of the Requirement.

1. In lieu of being certified as Level I, II, or III in accordance with NQA-1-2015, personnel that perform independent quality verification inspections, examinations, measurements, or tests of material, products, or activities will be required to possess qualifications equal to or better than those required for performing the task being verified; and the verification is within the skills of these personnel and/or is addressed by procedures. These individuals will not be responsible for the planning of quality verification inspections and tests (i.e., establishing hold points and acceptance criteria in procedures, and determining who will be responsible for performing the inspections), evaluating inspection training programs, nor certifying inspection personnel.

4 The NRC staff evaluated this proposed clarification and determined that the guidance in NQA-1-2015, Part III, Subpart 3.1-2.3 can be used to meet the requirements of Appendix B to 10 CFR Part 50 and is equivalent to the guidance in SRP Section 17.5, Paragraph II.T.5.

Therefore, the NRC staff finds the use of Subpart 3.1-2.3 of NQA-1-2015 for qualification of inspection and test personnel acceptable.

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

The NRC staff reviewed this clarification and determined that there is no conflict with regulatory guidance, NQA-1-2015, or other industry guidance in this subject area. Therefore, the NRC staff finds this clarification acceptable.

Dominion Energy conforms to Section 301 for qualification of nondestructive examination personnel, except that Dominion Energy will follow the applicable standard cited in the version(s) of Section III and Section XI of the ASME Boiler and Pressure Vessel Code of Record at Dominion Energy sites for the scope of activities governed by these cited standards.

The regulations in 10 CFR 50.55a, Codes and Standards, endorses versions of ASME B&PV Code Sections III and XI for activities within the scope of these sections. Therefore, the NRC staff finds the alternative proposed for the use of Sections III and XI of the ASME B&PV Code for qualification of nondestructive examination personnel to be acceptable.

As an alternative to Section 303.3 that prospective Lead Auditors have participated in a minimum of five (5) audits in the previous three (3) years, the guidance in RG 1.28, Revision 5, Section C.1.a, 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 3 years prior to the date of qualification by alternatively demonstrating the ability to properly implement the 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.

The NRC staff notes that this clarification has been documented as a regulatory position in RG 1.28, Revision 5, and therefore, is considered acceptable.

Sections 401 (g) requires the date of certification expiration be included on the qualification record. Dominion Energy considers the certification expiration date to be the date from the certification or recertification date plus the certification interval time and its inclusion on the qualification record is optional.

The NRC staff evaluated this exception and determined that the date of certification establishes the expiration date, when combined with the certification interval. The certification interval is normally a function of a code or standard and is identified in the organizations procedure; therefore, because having both dates on the form is redundant, the NRC staff determined the exception to be acceptable.

5 As stated in RG 1.28, Revision 5, NQA-1-2015 is considered acceptable to the NRC staff and provides an adequate basis for complying with the requirements of Appendix B to 10 CFR Part 50. Based upon its review, the NRC staff finds that the description of Dominion Energys QA program, as detailed above, complies with the requirements of Criterion II, Quality Assurance Program, of Appendix B to 10 CFR Part 50, and, therefore, is acceptable.

3.1.3 Design Control The Dominion Energy NN QAPD Revision 1 follows the guidance of SRP Section 17.5, Paragraph II.C, for establishing the necessary measures to control the design, design changes, and temporary modifications of safety-related items and services that are subject to the provisions of the QAPD. The Dominion Energy NN QAPD Revision 1 design process includes provisions to control design inputs, outputs, changes, interfaces, records, and organizational interfaces within Dominion Energy and with suppliers. These provisions ensure that the 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 can be related to the design input in sufficient detail to permit verification. In addition, the Dominion Energy NN QAPD Revision 1 provides for design documents to be reviewed by individuals knowledgeable in QA to ensure that the documents contain the necessary QA requirements.

Consistent with SRP Section 17.5, Paragraph II.C, the Dominion Energy NN QAPD Revision 1 design processes provide for design verification to ensure that items and activities subject to the provisions of the QA program are suitable for their intended application and are consistent with their effect on safety. Design changes are subject to these controls, which include verification measures commensurate with those applied to the original plant design. The extent of the design verification required is a function of the importance to safety of the item under consideration or computer program under consideration, the complexity of the design, the degree of standardization, the state of the art, and the similarity with previously proven designs.

Verification methods may include, but are not limited to, design reviews, alternative calculations, and qualification testing. 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.

The Dominion Energy NN QAPD Revision 1 governs the development, procurement, testing, maintenance, and use of computer applications when used in safety-related applications and designated non-safety-related applications. Dominion Energy and its suppliers are responsible for developing, approving, and issuing procedures, as necessary, to control the use of such computer applications. The Dominion Energy NN QAPD Revision 1 states that procedures shall require that the application software be assigned a proper quality classification and that the associated quality requirements be consistent with this classification.

The Dominion Energy NN QAPD Revision 1 commits to implement the quality standards described in NQA-1-2015, Part I, Requirement 3, as well as the standards in NQA-1-2015, Part II, Subpart 2.7 Quality Assurance Requirements for Computer Software for Nuclear Facility Applications, Subpart 2.14 Quality Assurance Requirements for Commercial Grade Items and Services, and Subpart 2.20, Quality Assurance Requirements for Subsurface Investigations for Nuclear Facilities, without further clarifications or exceptions.

As stated in RG 1.28, Revision 5, NQA-1-2015 is considered acceptable to the NRC staff and provides an adequate basis for complying with the requirements of Appendix B to 10 CFR Part 50. Based upon its review, the NRC staff finds that the description of Dominion Energys

6 Design Control, as detailed above, complies with the requirements of Criterion III, Design Control, of Appendix B to 10 CFR Part 50, and, therefore, is acceptable.

3.1.4 Procurement Document Control The Dominion Energy NN QAPD Revision 1 follows the guidance of SRP Section 17.5, Paragraph II.D, for establishing the necessary measures and governing procedures for preparing and reviewing procurement documents to ensure that the documents include or reference applicable regulatory, technical, and QA program requirements. The Dominion Energy NN QAPD Revision 1 ensures that relevant personnel develop and review the procurement documents and that changes are subject to the same degree of control as that used in preparing the original documents.

The Dominion Energy NN QAPD Revision 1 states that applicable technical, regulatory, administrative, quality, and reporting requirements (such as those in specifications, codes, standards, tests, inspections, special processes, and 10 CFR Part 21, "Reporting of Defects and Noncompliance,") are invoked for the procurement of items and services.

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 part 50, Appendix B. Alternatively, the QAPD allows the supplier to work under Dominion Energys approved QA program.

The Dominion Energy NN QAPD Revision 1 commits to implement the quality standards described in NQA-1-2015, Part I, Requirement 4, with the following clarifications and exceptions.

Section 203 requires the purchaser to specify the quality assurance requirements in the procurement documents. To meet this requirement, Dominion Energy may require suppliers to have a documented QAP that meets the applicable requirements of 10 CFR 50, Appendix B, as appropriate to the circumstances of the procurement.

The NRC staff evaluated this proposed alternative and determined that it provides adequate control for establishing and executing the responsibilities for the QA program. In addition, Criterion IV, Procurement Document Control, of Appendix B to 10 CFR Part 50, requires suppliers to have a QA program consistent with said Appendix. Therefore, the NRC staff concluded that this alternative is acceptable.

With regard to service performed by a supplier, Dominion procurement documents may allow the supplier to work under the Dominion QA program, including implementing procedures, in lieu of the supplier having its own QA program.

The NRC staff evaluated this proposed exception and determined that it provides adequate control for establishing and executing the responsibilities for the QA program because it is consistent with SRP Section 17.5, Paragraph II.D.1. In addition, Criterion IV, Procurement Document Control, of Appendix B to 10 CFR Part 50, requires suppliers to have a QA program consistent with the regulations. Therefore, the NRC staff determined that the exception is acceptable.

7 Section 300 and 400 of Requirement 4 require the review of technical and Quality Assurance Program requirements of procurement documents prior to award of a contract and for procurement document changes. Dominion Energy may satisfy this requirement through the review of the procurement specification, when the specification contains the technical and quality assurance requirements of the procurement.

The NRC staff evaluated this proposed clarification and determined that it provides adequate QA review of procurement documents before awarding the contract and after any change to the contract because it is consistent with SRP Section 17.5, Paragraph II.D.3. Therefore, the NRC staff determined that the clarification is acceptable.

Procurement documents for commercial grade items that will be procured by Dominion Energy for use as safety-related items shall contain technical and quality requirements such that the procured item can be appropriately dedicated in accordance with this QAPD, Section 7, Control of Purchased Material, Equipment, and Services.

The NRC staff evaluated this proposed clarification and determined that it is consistent with NRC staff guidance provided in RG 1.164, Revision 1, Dedication of Commercial Grade Items for use in Nuclear Power Plants, issued April 2024 (Reference 7). The proposed clarification is also consistent with Generic Letter (GL) 89-02, Actions to Improve the Detection of Counterfeit and Fraudulently Marked Products, dated March 21, 1989 (Reference 8), and GL 91-05, Licensee Commercial-Grade Procurement and Dedication Programs, dated April 9, 1991 (Reference 9), as delineated in SRP Section 17.5, Paragraphs II.V.1.d and II.V.1.e.

As stated in RG 1.28, Revision 5, NQA-1-2015 is considered acceptable to the NRC staff and provides an adequate basis for complying with the requirements of Appendix B to 10 CFR Part 50. Based upon its review, the NRC staff finds that the description of Dominion Energys Procurement Document Control, as detailed above, complies with the requirements of Criterion IV, Procurement Document Control, of Appendix B to 10 CFR Part 50, and, therefore, is acceptable.

3.1.5 Instructions, Procedures, and Drawings The Dominion Energy NN QAPD Revision 1 follows the guidance of SRP Section 17.5, Paragraph II.E, for establishing the necessary measures and governing procedures to ensure that activities affecting quality are prescribed by, and performed in accordance with, documented instructions, procedures, or drawings of a type appropriate to the circumstances and that, where applicable, include quantitative or qualitative acceptance criteria to implement the Dominion Energy QA program. This section also establishes the policies that procedures are followed, and in cases when a procedure cannot be followed as written, provisions are established for making changes in accordance with Part II, Section 6 of the Dominion Energy NN QAPD Revision 1.

In addition, provisions are established for when personnel are authorized to depart from approved procedures in cases of emergency, when necessary to prevent injury to personnel or damage to the plant. Dominion Energy has established measures to address the applicable content of procedures as described in the Introduction, to Part II of NQA-1-2015. Procedures governing tests, inspections, operational activities, and maintenance will include as applicable, initial conditions and prerequisites for the performance of the activity.

8 The Dominion Energy NN QAPD Revision 1 commits to implement the quality standards described in NQA-1-2015, Part I, Requirement 5, without further clarifications or exceptions.

As stated in RG 1.28, Revision 5, NQA-1-2015 is considered acceptable to the NRC staff and provides an adequate basis for complying with the requirements of Appendix B to 10 CFR Part 50. Based upon its review, the NRC staff finds that the description of Dominion Energys Instructions, Procedures, and Drawings, as detailed above, complies with the requirements of Criterion V, Instructions, Procedures, and Drawings, of Appendix B to 10 CFR Part 50, and, therefore, is acceptable.

3.1.6 Document Control The Dominion Energy NN QAPD Revision 1 follows the guidance of SRP Section 17.5, Paragraph II.F, for establishing the necessary measures and governing procedures to control the preparation, review, approval, issuance of, and changes to documents that specify quality requirements or prescribe how activities affecting quality, including organizational interfaces, are controlled. Measures are provided to assure that documents, including revisions or changes (other than those defined in implementing procedures as minor changes), are reviewed and approved by the same organization that performed the original review and approval, unless other organizations are specifically designated. A listing of all controlled documents, identifying the current approved revision or date, is maintained so personnel can determine the appropriate document for use.

The Dominion Energy NN QAPD Revision 1 commits to implement the quality standards described in NQA-1-2015, Part I, Requirement 6, without further clarifications or exceptions.

As stated in RG 1.28, Revision 5, NQA-1-2015 is considered acceptable to the NRC staff and provides an adequate basis for complying with the requirements of Appendix B to 10 CFR Part 50. Based upon its review, the NRC staff finds that the description of Dominion Energys Document Control, as detailed above, complies with the requirements of Criterion VI, Document Control, of Appendix B to 10 CFR Part 50, and, therefore, is acceptable.

3.1.7 Control of Purchased Material, Equipment, and Services The Dominion Energy NN QAPD Revision 1 follows the guidance of SRP Section 17.5, Paragraph II.G, for establishing the necessary measures and governing procedures to control the procurement of items and services to ensure conformance with specified requirements. The Dominion Energy NN QAPD Revision 1 provides measures for source evaluation and selection, evaluation of objective evidence of quality furnished by the supplier, source inspection, audit, and examination of items or services. The Dominion Energy NN QAPD Revision 1 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's or service's importance to safety, complexity, quantity, and frequency of procurement.

The Dominion Energy NN QAPD Revision 1 provides measures for evaluating prospective suppliers and selecting only qualified suppliers, as well as auditing and evaluating suppliers to ensure that qualified suppliers continue to provide acceptable products and services. Qualified suppliers are audited on a triennial basis.

The Dominion Energy NN QAPD Revision 1 also outlines acceptance actions, such as source verification, receipt inspection, certificates of conformance, and review of documentation (e.g.,

9 Certified Material Test Reports/Certificates) to ensure that the procurement, inspection, and test requirements have been satisfied before relying on the item to perform its intended safety function. In addition, the Dominion Energy NN QAPD Revision 1 establishes controls for the selection, determination of suitability for intended use (i.e., critical characteristics), evaluation, receipt, and acceptance of commercial-grade services or items to assure they will perform satisfactorily in service in safety-related applications.

In establishing procurement verification controls and commercial-grade item requirements, the Dominion Energy NN QAPD Revision 1 commits to implement the quality standards described in NQA-1-2015, Part I, Requirement 7, and Part II, Subpart 2.14 with the following clarifications and exceptions:

Dominion Energy considers that other 10 CFR Parts 50 and 52 licensees, Authorized Nuclear Inspection agencies, National Institute of Standards and Technology, or other State and Federal agencies, which may provide items or services to Dominion Energy plant, are not required to be evaluated or audited.

The NRC staff has documented its current regulatory position regarding this exception in SE Section 3.1.7.1 of the Tennessee Valley Authority (TVA) New Nuclear QAPD, dated December 12, 2023 (Reference 10). The NRC staff verified that the Dominion Energy NN QAPD Revision 1 provided the same commitments associated with supplier oversight activities as those provided in the TVA New Nuclear QAPD. Therefore, the NRC staffs position associated with this exception, as documented in the TVA New Nuclear QAPD SE, would apply to the Dominion Energy NN QAPD Revision 1. The NRC staff concludes that the requested exception regarding audit and evaluation, as described above, is acceptable subject to the limitations described in the TVA New Nuclear QAPD SE, as identified in Section 5.0 of this SE, for control of purchased material, equipment, and services.

Commercial-grade calibration and/or testing services may be procured from commercial laboratories based on the laboratory's accreditation to ISO/IEC 17025:2017 by an Accreditation Body (AB) which is a signatory to the International Laboratory Accreditation and Cooperation (ILAC) Mutual Recognition Arrangement (MRA) provided all of the following are met in accordance with NRC SE (ML20322A019) endorsement of NEI 14-05A, Revision 1:

1.

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

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

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

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

10

d. The laboratory has achieved accreditation based on an on-site accreditation assessment by the selected AB within the past 48 months. The laboratory's accreditation cannot be based on two consecutive remote accreditation assessments.

2.

The purchase documents require that:

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

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

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

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

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

f.

The performance of the services listed on this purchase order is contingent on the laboratorys accreditation having been achieved through an on-site accreditation assessment by the AB within the past 48 months.

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

3.

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

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

b. The purchase order's requirements are met.

The NRC staff evaluated this proposed clarification and determined that it is consistent with the NRC staffs current regulatory position, documented in RG 1.28, Revision 6, issued September 2023 (Reference 11). In this RG, the NRC staff concluded that NEI 14-05A, Revision 1, provides an acceptable approach for licensees and suppliers subject to the QA requirements of Appendix B to 10 CFR Part 50. This NEI document relates to using laboratory accreditation by Accreditation Bodies that are signatories to the ILAC MRA in lieu of performing commercial-grade surveys as part of the commercial-grade dedication process for procuring calibration and testing services performed by domestic and international laboratories accredited by signatories to the ILAC MRA. Therefore, the NRC staff concluded that this clarification is acceptable.

For commercial grade items, quality verification requirements are established and described in Dominion Energy documents to provide the necessary assurance that an

11 item will perform satisfactorily in service. The Dominion Energy documents address determining the critical characteristics that ensure an item is suitable for its intended use, technical evaluation of the item, receipt requirements, and quality evaluation of the item.

The NRC staff considers that the establishment of quality verification requirements and processes for identification of critical characteristics of Dominions documents as part of the commercial grade dedication process is acceptable because this is consistent with the guidance in SRP Section 17.5, Subsection II, Item G.

Dominion Energy will assume 10 CFR Part 21 reporting responsibility for all items that Dominion Energy dedicates as safety-related.

Under 10 CFR Part 21, any individual Director or responsible officer of a firm constructing, owning, operating, or supplying the components of any licensed or regulated facility or activity, who obtains information reasonably indicating: (a) that the facility, activity or basic component supplied to such facility or activity fails to comply with the Atomic Energy Act of 1954, as amended, or any applicable rule, regulation, order, or license of the Commission relating to substantial safety hazards; or (b) that the facility, activity, or basic component supplied to such facility or activity contains defects that could create a substantial safety hazard, must immediately notify the Commission of such failure to comply or such defect, unless they have actual knowledge that the Commission has been adequately informed of such defect or failure to comply.

The NRC staff evaluated this clarification and determined that it ensures that 10 CFR Part 21 reportability requirements encompass all items that are dedicated as safety-related and does not remove the suppliers responsibilities under 10 CFR Part 21. Therefore, the NRC staff concluded that this clarification is acceptable.

As stated in RG 1.28, Revision 5, NQA-1-2015 is considered acceptable to the NRC staff and provides an adequate basis for complying with the requirements of Appendix B to 10 CFR Part 50. Based upon its review, the NRC staff finds that the description of Dominion Energys controls for purchased material, equipment, and services, as detailed above, complies with the requirements of Criterion VII, Control of Purchased Material, Equipment, and Services, of Appendix B to 10 CFR Part 50, and, therefore, is acceptable.

3.1.8 Identification and Control of Materials, Parts, and Components The Dominion Energy NN QAPD Revision 1 follows the guidance of SRP Section 17.5, Subsection II.H, for establishing the necessary measures and governing procedures to identify and control items to prevent the use of incorrect or defective items. Identification of items is maintained throughout fabrication, erection, installation, and use so that the materials, parts, or components can be traced back to their documentation, consistent with the items effect on safety. The location and identification methods are selected so the function or quality of the item being identified is not affected.

The Dominion Energy NN QAPD Revision 1 commits to implement the quality standards described in NQA-1-2015, Part I, Requirement 8, without further clarifications or exceptions.

As stated in RG 1.28, Revision 5, NQA-1-2015 is considered acceptable to the NRC staff and provides an adequate basis for complying with the requirements of Appendix B to 10 CFR Part 50. Based upon its review, the NRC staff finds that Dominion Energys description of identification and control of materials, parts, and components, as detailed above, complies with

12 the requirements of Criterion VIII, Identification and Control of Materials, Parts, and Components, of Appendix B to 10 CFR Part 50, and, therefore, is acceptable.

3.1.9 Control of Special Processes The Dominion Energy NN QAPD Revision 1 follows the guidance of SRP Section 17.5, Subsection II.I, for establishing the necessary measures and governing procedures to provide assurance that special processes that require interim process controls to assure quality, such as welding, heat-treating, and non-destructive examination are controlled. Special processes are accomplished by qualified personnel using qualified procedures and equipment, and in accordance with applicable codes, standards, specifications, criteria, or other special requirements.

The Dominion Energy NN QAPD Revision 1 commits to implement the quality standards described in NQA-1-2015, Part I, Requirement 9, without further clarifications or exceptions.

As stated in RG 1.28, Revision 5, NQA-1-2015 is considered to be acceptable to the NRC staff and provides an adequate basis for complying with the requirements of Appendix B to 10 CFR Part 50. Based upon its review, the NRC staff finds that the description of Dominion Energys control of special processes, as detailed above, complies with the requirements of Criterion IX Control of Special Processes, of Appendix B to 10 CFR Part 50, and therefore, is acceptable.

3.1.10 Inspection The Dominion Energy NN QAPD Revision 1 follows the guidance of SRP Section 17.5, Subsection II.J, for establishing the necessary measures and governing procedures to implement inspections that provide assurance that items, services, and activities affecting safety meet established requirements and conform to applicable documented specifications, instructions, procedures, and design documents. Types of inspections may include the following verifications: (1) at the source of supplied items or services, (2) in-process during fabrication at a supplier's facility or at a Dominion Energy facility, (3) for final acceptance of fabricated and/or installed items during construction, and (4) upon receipt of items for a facility. These types of inspections will be performed by properly qualified personnel independent of those who performed or directly supervised the work, and the inspection results will be documented.

Dominion Energys inspection program establishes requirements for planning the inspections, such as measures for (1) the identification of the group or discipline responsible for performing the inspection, (2) the application of hold points, (3) the acceptance criteria for inspection, (4) the frequency of inspections, and (5) identification of special tools needed to perform the inspection. Inspection plans are based on, as appropriate, (1) the importance of the item to safety, (2) the complexity of the item, (3) the technical requirements to be met, and (4) the design specifications. Inspection information and results, such as rejection, acceptance criteria, reinspection results, and the person(s) performing the inspection, are documented. Inspection results are reviewed by authorized personnel qualified to evaluate the technical adequacy of the inspection results and controlled by instructions, procedures, and drawings.

13 The Dominion Energy NN QAPD Revision 1 commits to implement the quality standards described in NQA-1-2015, Part I, Requirement 10, and Part II, Subparts 2.5 Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete, Structural Steel, Soils, and Foundations for Nuclear Facilities include amplified requirements for installation, inspection, and testing of structural concrete, structural steel, soils, and foundations, and 2.8 Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Items for Nuclear Facilities, without further clarifications or exceptions.

As stated in RG 1.28, Revision 5, NQA-1-2015 is considered to be acceptable to the NRC staff and provides an adequate basis for complying with the requirements of Appendix B to 10 CFR Part 50. Based upon its review, the NRC staff finds that Dominion Energys description of inspection controls, with the included clarification, as detailed above, complies with the requirements of Criterion X, Inspection of Appendix B to 10 CFR Part 50, and, therefore, is acceptable.

3.1.11 Test Control The Dominion Energy NN QAPD Revision 1 follows the guidance of SRP Section 17.5, Subsection II.K, for establishing the necessary measures and governing procedures to demonstrate that items subject to the provisions of the NN QAPD Revision 1 will perform satisfactorily in service. Test programs include criteria for determining when testing is required to demonstrate that performance of plant systems is in accordance with design. 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. Test results are documented and evaluated by the organization performing the test and reviewed by a responsible authority to ensure that the test requirements have been satisfied. 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. Personnel who perform or evaluate tests are qualified in accordance with the requirements established in Part II, Section 2 of the NN QAPD Revision 1.

For non-computer program testing, Dominion Energys NN QAPD Revision 1 commits to implement the quality standards described in NQA-1-2015, Part 1, Requirement 11 without further clarifications or exceptions.

For computer program testing, Dominion Energys NN QAPD Revision 1 commits to implement the quality standards described in NQA-1-2015, Part I, Requirement 11 and NQA-1-2015, Part II, Subpart 2.7 to establish the appropriate provisions in addition to the commitment to NQA-1-2015, Requirement 3, without further clarifications or exceptions.

As stated in RG 1.28, Revision 5, NQA-1-2015 is considered to be acceptable to the NRC staff and provides an adequate basis for complying with the requirements of Appendix B to 10 CFR Part 50. Based upon its review, the NRC staff finds that Dominion Energys description of testing controls, as detailed above, complies with the requirements of Criterion XI, Test Control of Appendix B to 10 CFR Part 50, and therefore, is acceptable.

3.1.12 Control of Measuring and Test Equipment The Dominion Energy QAPD Revision 1 follows the guidance of SRP Section 17.5, Subsection II.L, for establishing the necessary measures and governing procedures to control the calibration, maintenance, and use of measuring and test equipment (M&TE) that provides

14 data to verify acceptance criteria are met for information important to safe plant operation. The provisions of such procedures cover equipment such as indicating and actuating instruments and gauges, tools, reference and transfer standards, and non-destructive examination equipment. For installed instruments and control devices, appropriate documentation will be maintained to indicate the control status, when the next calibration is due, and identify any limitations on use of the device.

Dominion Energys NN QAPD Revision 1 commits to implement the quality standards described in NQA-1-2015, Part I, Requirement 12, with the following clarification and exception.

The out-of-calibration conditions described in NQA-1-2015, Part I, Requirement 12, Section 303.2 refers to when the M&TE is found out of the required accuracy limits (i.e.,

out-of-tolerance) during calibration and not overdue for calibration.

The NRC staff finds that the clarification for out-of-calibration conditions is consistent with the overall objective of NQA-1-2015, Requirement 12, Section 303.2, and Criterion XII, Control of Measuring and Test Equipment, of Appendix B to 10 CFR Part 50, which require that M&TE used in activities affecting quality are properly controlled, calibrated, and adjusted at specified periods to maintain accuracy within necessary limits. Therefore, the NRC staff concluded that this clarification is acceptable.

M&TE are not required to be marked with the calibration status, as described in NQA-1-2015, Part I, Requirement 12, Section 303.6 where it is impossible or impractical due to equipment size or configuration (such as the label will interfere with operation of the device) provided the required information is maintained in suitable documentation traceable to the device.

The NRC staff finds this exception consistent with the overall objective of NQA-1-2015, Requirement 12, Section 303.6, and Criterion XII of Appendix B to 10 CFR Part 50, which require that M&TE used in activities affecting quality are properly controlled, calibrated, and adjusted at specified periods to maintain accuracy within necessary limits.

As stated in RG 1.28, Revision 5, NQA-1-2015 is considered to be acceptable to the NRC staff and provides an adequate basis for complying with the requirements of Appendix B to 10 CFR Part 50. Based upon its review, the NRC staff finds that Dominion Energys description of M&TE controls, as detailed above, complies with the requirements of Criterion XII, of Appendix B to 10 CFR Part 50, and therefore, is acceptable.

3.1.13 Handling, Storage, and Shipping The Dominion Energy NN QAPD Revision 1 follows the guidance of SRP Section 17.5, Subsection II.M, for establishing 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. Items are appropriately marked and labeled during packaging, shipping, handling, and storage to identify, maintain, and preserve the items integrity and provide indication of the needs for special controls. Any special controls (such as containers, shock absorbers, accelerometers, inert gas atmospheres, specific moisture content levels, and temperature levels) are provided when required. In addition, procurement documents and applicable procedures identify any special or additional handling, storage, shipping, cleaning, and preservation requirements. Special handling tools and equipment are controlled to ensure safe and adequate handling. These special tools and handling equipment are inspected and tested in accordance with procedures at specified time intervals or before

15 use. Operators of special handling and lifting equipment are experienced or trained in the use of the equipment. Where required, Dominion Energys NN QAPD Revision 1 complies with applicable hoisting, rigging, and transportation regulations and codes. Housekeeping practices are established to account for conditions or environments that could affect the quality of SSCs within the plant.

The Dominion Energy NN QAPD Revision 1 commits to implement the quality standards described in NQA-1-2015, Part I, Requirement 13 without further clarifications or exceptions.

As stated in RG 1.28, Revision 5, NQA-1-2015 is considered to be acceptable to the NRC staff and provides an adequate basis for complying with the requirements of Appendix B to 10 CFR Part 50. Based upon its review, the NRC staff finds that Dominion Energys description of handling, storage, and shipping controls, as detailed above, complies with the requirements of Criterion XIII, Handling, Storage and Shipping of Appendix B to 10 CFR Part 50, and, therefore, is acceptable.

3.1.14 Inspection, Test, and Operating Status The Dominion Energy NN QAPD Revision 1 follows the guidance of SRP Section 17.5, Subsection II.N, for establishing the necessary measures and governing procedures to identify the inspection, test, and operating status of items and components subject to the provisions of the Dominion Energy NN QAPD Revision 1 in order to maintain personnel and reactor safety and avoid inadvertent operation of equipment. Measures are provided for the verification of inspections, tests, and operating status to preclude the bypassing of inspections or tests, or to preclude inadvertent operation. These measures require the inspection, test, or operating status to be verified before release, fabrication, receipt, installation, test, or use. These measures also establish the necessary authorities and controls for the application and removal of status indicators or labels.

The Dominion Energy NN QAPD Revision 1 commits to implement the quality standards described in NQA-1-2015, Part I, Requirement 14, without further clarifications or exceptions.

As stated in RG 1.28, Revision 5, NQA-1-2015 is considered to be acceptable to the NRC staff and provides an adequate basis for complying with the requirements of Appendix B to 10 CFR Part 50. Based upon its review, the NRC staff finds that Dominion Energys description of inspection, test, and operating status controls, as detailed above, complies with the requirements of Criterion XIV, Inspection, Test, and Operating Status of Appendix B to 10 CFR Part 50, and, therefore, is acceptable.

3.1.15 Nonconforming Materials, Parts, or Components The Dominion Energy NN QAPD Revision 1 follows the guidance of SRP Section 17.5, Subsection II.O, for establishing the necessary measures and governing procedures to control items, including services, that do not conform to specified requirements in order to prevent inadvertent installation or use. Controls provide for the identification, documentation, evaluation, segregation (when practical), and disposition of nonconforming items, and notification to affected organizations. Controls are also provided to address the conditional release of nonconforming items for use on an at-risk basis before resolution and disposition of the nonconformance, including maintaining identification of the item and documenting the basis for such release.

16 Nonconforming items are evaluated for impact on the operability of quality SSCs to provide assurance that the final condition does not adversely affect safety, operation, or maintenance of the item or service. Nonconformances to design requirements that are dispositioned repair or use-as-is are subject to design control measures commensurate with those applied to the original design. Nonconformance dispositions are reviewed for adequacy, analysis of quality trends, and reported to designated management. Significant trends are reported to management in accordance with Dominion Energys procedures, regulatory requirements, and industry standards.

The Dominion Energy NN QAPD Revision 1 provides for establishing the appropriate interfaces with the reporting program for identification and control of nonconforming materials, parts or components to satisfy the requirements of 10 CFR 50.55, 10 CFR Part 52, and 10 CFR Part 21.

The Dominion Energy NN QAPD Revision 1 commits to implement the quality standards described in NQA-1-2015, Part I, Requirement 15, without further clarifications or exceptions.

As stated in RG 1.28, Revision 5, NQA-1-2015 is considered to be acceptable to the NRC staff and provides an adequate basis for complying with the requirements of Appendix B to 10 CFR Part 50. Based upon its review, the NRC staff finds that Dominion Energys description of controls for nonconforming materials, parts, or components, as detailed above, complies with the requirements of Criterion XV, Nonconforming Materials, Parts, or Components, of Appendix B to 10 CFR Part 50, and, therefore, is acceptable.

3.1.16 Corrective Action The Dominion Energy NN QAPD Revision 1 follows the guidance of SRP Section 17.5, Paragraph II.P, for establishing the necessary measures and governing procedures to promptly identify, control, document, classify, and correct conditions adverse to quality. The Dominion Energy NN QAPD Revision 1 provides for procedures to ensure that corrective actions are documented and initiated following the determination of conditions adverse to quality in accordance with regulatory requirements and applicable quality standards.

The Dominion Energy NN QAPD Revision 1 requires personnel to identify known conditions adverse to quality. Reports of conditions adverse to quality are analyzed to identify trends.

Significant conditions adverse to quality and significant adverse trends are documented and reported to responsible management. In the case of a significant condition adverse to quality, the cause is determined and actions to preclude recurrence are taken. In the case of suppliers working on safety-related activities, or other similar situations, Dominion Energy may delegate specific responsibilities for corrective actions, but Dominion Energy maintains overall responsibility for the effectiveness of corrective action measures and the corrective action program.

The Dominion Energy NN QAPD Revision 1 provides for establishing the appropriate interfaces with the reporting program for corrective actions to satisfy the requirements of 10 CFR 50.55, 10 CFR Part 52, and 10 CFR Part 21.

The Dominion Energy NN QAPD Revision 1 commits to implement the quality standards described in NQA-1-2015, Part I, Requirement 16, without further clarifications or exceptions.

As stated in RG 1.28, Revision 5, NQA-1-2015 is considered to be acceptable to the NRC staff and provides an adequate basis for complying with the requirements of Appendix B to 10 CFR Part 50. Based upon its review, the NRC staff finds that the description of Dominion Energys

17 Corrective Action program complies with the requirements of Criterion XVI, Corrective Action of Appendix B to 10 CFR Part 50, and, therefore, is acceptable.

3.1.17 Quality Assurance Records The Dominion Energy NN QAPD Revision 1 follows the guidance of SRP Section 17.5, Paragraph II.Q, for establishing the necessary measures 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 records retention program for Dominion Energy and include requirements for records administration including receipt, preservation, retention, storage, safekeeping, retrieval, access controls, user privileges, and final disposition.

The Dominion Energy NN QAPD Revision 1 establishes measures to ensure that records of activities for design, engineering, procurement, construction, inspection and test, installation, pre-operation, startup, operations, maintenance, modification, and audits and their retention times are defined in appropriate procedures. Records and retention times are based on RG 1.28, Revision 5, Regulatory Positions C.3.a.(1) for Lifetime Records and C.3.a (2) for Nonpermanent Records. In all cases in which State, local, or other agencies have more restrictive requirements for record retention, the Dominion Energy QAPD provides that those more restrictive requirements will be met.

When using electronic records storage and retrieval systems, Dominion Energy NN QAPD Revision 1 complies with guidance outlined in associated Nuclear Information and Records Management Association, Inc. (NIRMA) Technical Guidelines (TG), including TG 11-2011, Authentication of Records and Media, (Reference 12), TG 15-2011, Management of Electronic Records, (Reference 13), TG 16-2011, Software Configuration Management and Quality Assurance, (Reference 14), and TG 21-2011, Electronic Records Protection and Restoration (Reference 15).

The Dominion Energy NN QAPD Revision 1 commits to implement the quality standards described in NQA-1-2015, Part I, Requirement 17 and regulatory positions stated in RG 1.28, Revision 5, with the following clarification:

In establishing the provisions for a list of records, Dominion Energy commits to comply with RG 1.28, Revision 5, position C.3.a.(2) with the following clarifications:

Dominion Energy commits to develop a list of typical NN QA records and their retention periods using the guidance of NQA-1-2015, Part III, Subpart 3.1-17.1, Section 200, for the lifetime records recognizing that the record name may vary, and the list may not be all-inclusive. For records not listed, the record that most nearly describes the record in question will be followed regarding retention.

Dominion Energy commits to maintain sufficient records to furnish evidence of activities affecting quality.

The NRC staff notes that this clarification is consistent with regulatory position C.3.a.(2) in RG 1.28, Revision 5, and therefore, is considered acceptable.

18 As stated in RG 1.28, Revision 5, NQA-1-2015 is considered to be acceptable to the NRC staff and provides an adequate basis for complying with the requirements of Appendix B to 10 CFR Part 50. Based upon its review, the NRC staff finds that the description of Dominion Energys QA Records complies with the requirements of Criterion XVII, Quality Assurance Records, of Appendix B to 10 CFR Part 50 and, therefore, is acceptable.

3.1.18 Audits The Dominion Energy NN QAPD Revision 1 follows the guidance of SRP Section 17.5, Paragraph II.R, for establishing the necessary measures and governing procedures to implement audits to verify that activities covered by the QA program are performed in conformance with the established requirements and performance criteria are met. Dominion Energy also reviews the audit programs for effectiveness as part of the overall audit process.

Internal audits of selected aspects of licensing and design activities are performed with a frequency commensurate with safety significance and in a manner which assures that audits of safety-related activities are completed. During the initial portions of Dominion Energy activities, audits will focus on areas including but not limited to, site investigation, procurement, and corrective action.

The Dominion Energy NN QAPD Revision 1 provides for conducting periodic internal and external audits. Internal audits are conducted to determine the adequacy of programs and procedures, as well as to determine whether they are meaningful and comply with the overall Dominion Energy NN QA program. Internal audits of all applicable QA program elements should be completed for each functional area at least once each year or at least once during the life of the activity, whichever is shorter.

External audits determine the adequacy of supplier and contractor QA programs, and Dominion Energy NN QAPD Revision 1 Section 7.1 describes additional controls for external audits.

The scope of the audits is determined by the quality status and safety importance of the activities being performed. These audits are conducted by trained personnel not having direct responsibilities in the area being audited and in accordance with preplanned and approved audit plans or checklists, under the direction of a qualified lead auditor and the cognizance of Dominion Energys QA management.

The Dominion Energy NN QAPD Revision 1 provides for all audit results to be reported to responsible management. Management responds to all audit findings and initiates corrective actions when determined necessary. In addition, if corrective action measures are determined necessary, documented follow-up of applicable areas through inspections, review, re-audits, or other appropriate means, is conducted to verify the implementation and effectiveness of the assigned corrective actions.

The Dominion Energy NN QAPD Revision 1 commits to implement the quality standards described in NQA-1-2015, Part I, Requirement 18 with the following clarification:

Dominion Energy annual evaluations of the supplier in RG 1.28, Revision 5, position C.

4.b. (4). (a), (b), and (c) shall only be required to consider activities related to Dominion Energy procurement activities.

The intent of NRC position C. 4. b. (4). (a), (b), and (c) is for applicants or licensees to assess supplier performance on an annual basis. Activities referenced in C. 4. b. (4). (a), (b), and (c) are performed as part of procurement activities in order to ensure suppliers are qualified and

19 have performed sufficient work to demonstrate that its organization is implementing a QA program that has the required scope for purchases. Therefore, since this clarification is consistent with the intent of the staffs position document in RG 1.28 Revision 5, the NRC staff considers this clarification acceptable.

As stated in RG 1.28, Revision 5, NQA-1-2015 is considered to be acceptable to the NRC staff and provides an adequate basis for complying with the requirements of Appendix B to 10 CFR Part 50. Based upon its review, the NRC staff finds that the description of Dominion Energys audits complies with the requirements of Criterion XVIII, Audits, of Appendix B to 10 CFR Part 50, and, therefore, is acceptable.

3.2 Nonsafety-Related SSC Quality Control 3.2.1 Nonsafety-Related SSCs-Significant Contributors to Plant Safety The Dominion Energy NN QAPD Revision 1 follows the guidance of SRP Section 17.5, Paragraph II.U.1, for establishing necessary measures and governing procedures to be applied to nonsafety-related SSCs that are significant contributors to plant safety, but for which the requirements of Appendix B to 10 CFR Part 50 are not applicable. The Dominion Energy NN QAPD Revision 1 applies specific controls to such items in a selected manner, targeted toward those characteristics or critical attributes that render the SSC a significant contributor to plant safety, consistent with applicable sections of the Dominion Energy NN QAPD Revision 1.

Based upon its review, the NRC staff has determined that this approach, as described in the Dominion Energy NN QAPD Revision 1, is consistent with SRP Section 17.5, Paragraph II.U.1 and is therefore, acceptable.

3.2.2 Nonsafety-Related SSCs Credited for Regulated Events In establishing the quality requirements for non-safety-related SSCs credited for regulatory events, the Dominion Energy NN QAPD Revision 1 follows the guidance of SRP Section 17.5, Paragraph II.U.2, and Dominion Energy commits to implement the following regulatory guidance:

The quality requirements for the fire protection system in accordance with Regulatory Position 1.7, "Quality Assurance," in RG 1.189, Revision 3 "Fire Protection for Operating Nuclear Power Plants (Reference 16).

The quality requirements for anticipated transient without scram equipment in accordance with QAPD Part III,Section I.

The quality requirements for station blackout (SBO) equipment in accordance with QAPD Part III,Section I.

Based upon its review, the NRC staff has determined that this approach, as described in the Dominion Energy NN QAPD Revision 1, is consistent with SRP Section 17.5, Paragraph II.U.2, and is therefore, acceptable.

20 3.3 Regulatory Commitments The Dominion Energy NN QAPD Revision 1 follows the guidance of SRP Section 17.5, Paragraph II.V, for establishing QA program commitments. Furthermore, Dominion Energy NN QAPD Revision 1 commits to comply with the following NRC RGs and other QA standards to supplement and support the QA program:

RG1.28, Revision 5, October 2017, Quality Assurance Program Criteria (Design and Construction). RG 1.28 describes a method acceptable to the NRC staff for complying with the provisions of Appendix B with regard to establishing and implementing the requisite quality assurance program for the design and construction of nuclear power plants. The Dominion Energy NN QAPD states that Dominion Energy identifies conformance and exceptions for the applicable regulatory position guidance provided in this RG in applicable license applications. (Reference 3)

RG 1.29, Revision 6, July 2021, Seismic Design Classification for Nuclear Power Plants. RG 1.29 defines systems required to withstand a safe shutdown earthquake (SSE). The Dominion Energy NN QAPD states that Dominion Energy identifies conformance and exceptions for the applicable regulatory position guidance provided in this RG in applicable license applications. (Reference 18)

RG 1.164, Revision 1, April 2024, Dedication of Commercial-Grade Items for Use in Nuclear Power Plants. RG 1.164 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. The Dominion Energy NN QAPD states that Dominion Energy identifies conformance and exceptions for the applicable regulatory position guidance provided in this RG in applicable license applications. (Reference 7)

RG 1.234, Revision 1, March 2024, Evaluating Deviations and Reporting Defects and Noncompliance Under 10 CFR Part 21. RG 1.234 describes methods acceptable to the NRC staff for complying with the Commission's regulations with regard to 10 CFR Part 21, Reporting of Defects and Noncompliance. The Dominion Energy NN QAPD states that Dominion Energy identifies conformance and exceptions for the applicable regulatory position guidance provided in this RG in applicable license applications. (Reference 19)

ASME NQA-1-2015, Part I and Part II, Quality Assurance Requirements for Nuclear Facility Applications. Dominion Energy commits to NQA-1-2015, Parts I and II, as described in Parts I and II of the Dominion Energy NN QAPD Revision 1 with specific identification of exceptions or clarifications. Dominion Energy commits to NQA-1-2015, Part III, only as specifically noted in Parts I and II of the Dominion Energy NN QAPD Revision 1. (Reference 2)

NIRMA TGs. Dominion Energy commits to NIRMA TGs as described in Part II, Section 17 of the Dominion Energy NN QAPD Revision 1. (References 11-14)

21 NEI 14-05-A, Revision 1-Guidelines for the Use of Accreditation in Lieu of Commercial Grade Surveys for Procurement of Laboratory Calibration and Test Services. (Reference 20)

Based upon its review, the NRC staff has determined that this approach, as described in the Dominion Energy NN QAPD Revision 1, is consistent with SRP Section 17.5, Paragraph II.V, and, therefore, is acceptable.

4.0 CONCLUSION

The NRC staff concludes that the Dominion Energy NN QAPD Revision 1 delineates the policies, processes, and controls associated with Dominion Energys activities that affect the quality of safety-related nuclear plant SSCs and include all planned and systematic activities necessary to provide adequate confidence that such SSCs will perform satisfactorily in service.

The Dominion Energy NN QAPD Revision 1 may also be applied to certain equipment and activities that are not safety-related but are significant contributors to safety, as described in Section III of the Dominion Energy NN QAPD.

The NRC staff used the acceptance criteria of SRP Section 17.5 as the basis for evaluating the acceptability of the Dominion Energy NN QAPD Revision 1 in conformance with the provisions of Appendix B to 10 CFR Part 50 and concludes that the Dominion Energy NN QAPD Revision 1 satisfies the acceptance criteria in SRP Section 17.5.

Based on its review, the NRC staff has determined that the Dominion Energy NN QAPD, Revision 1, adequately describes the Dominion Energy QA program for a potential ESP application. Further, the staff concludes that the Dominion Energy QA program complies with applicable NRC regulations and industry standards and can be used by Dominion Energy for the activities described in NN QAPD Revision 1 Section 2 affecting the quality and performance of safety-related SSCs.

5.0 LIMITATIONS AND CONDITIONS This Dominion Energy NN QAPD is specific to the activities described in Section 2 of the NN QAPD Revision 1. Any other application referencing the approved revision of the Dominion Energy NN QAPD Revision 1, shall provide a description in its QAPD that meets Appendix B to 10 CFR Part 50 and associated regulatory requirements.

As referenced in section 3.1.7 of this SE, the following limitations on the use of this QAPD apply:

The exception to not perform audit or evaluation for procurements from other Part 50 and Part 52 licensees only applies when Dominion Energy procures from other 10 CFR Part 50 and 52 power reactor licensees.

When Dominion Energy procures from manufacturing licensees where inspections during the fabrication or manufacturing process are required to assure quality, Dominion Energy must establish measures for source verification for these procurements, as required by Criterion VII of Appendix B to 10 CFR Part 50.

22

6.0 REFERENCES

1.

Letter from James E. Holloway, Dominion Energy Services, Inc., to the NRC Document Control Desk, Dominion Energy Services, Inc Topical Report Quality Assurance Program Description For Dominion Energy New Nuclear Program, Revision 0, dated February 19, 2025 (ML25051A248).

2.

American Society of Mechanical Engineers (ASME) NQA-1-2015, Quality Assurance Program Requirements for Nuclear Facilities Applications, dated February 20, 2015.

3.

Regulatory Guide (RG) 1.28, Quality Assurance Program Criteria (Design and Construction), Revision 5, dated October 2017 (ML17207A293).

4.

NRC Staff Clarification Call Public Meeting with Dominion Energy Services held on May 20, 2025 (ML25163A099).

5.

Letter from James E. Holloway, Dominion Energy Services, Inc., to the NRC Document Control Desk, Dominion Energy Services, Inc Topical Report Quality Assurance Program Description For Dominion Energy New Nuclear Program, Revision 1, dated July 1, 2025 (ML25182A367).

6.

NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," Section 17.5, Quality Assurance Program Description -

Design Certification, Early Site Permit and New License Applicants," dated August 2015 (ML15037A441).

7.

RG 1.164, Revision 1, Dedication of Commercial-Grade Items for Use in Nuclear Power Plants, April 2024 (ADAMS Accession No. ML24038A310)

8.

NRC, Generic Letter 89-02, Actions to Improve the Detection of Counterfeit and Fraudulently Marketed Products, dated March 21, 1989 (ML031140060).

9.

NRC, Generic Letter 91-05, Licensee Commercial-Grade Procurement and Dedication Programs, dated April 9, 1991 (ML031140508).

10. SE by the Office of Nuclear Reactor Regulation Regarding the Topical Report on the Quality Assurance Program Description for the Tennessee Valley Authority New Nuclear Program, dated December 12, 2023 (ML23254A050).

11. RG 1.28, Quality Assurance Program Criteria (Design and Construction),

Revision 6, dated September 2023 (ML23177A002).

12. Nuclear Information and Records Management Association (NIRMA),

Authentication of Records and Media, TG 11-2011, New York, NY.

13. NIRMA, Management of Electronic Records, TG 15-2011, Windham, NH.

23

14. NIRMA, Software Configuration Management and Quality Assurance, TG 16-2011, Windham, NH

15. NIRMA, Electronic Records Protection and Restoration, TG 21-2011, Windham, NH.

16. RG 1.189, Revision 3, "Fire Protection for Nuclear Power Plants," dated February 2018 (ML17340A875).

17. RG 1.26, Revision 6, "Quality Group Classification and Standards for Water, Steam-, and Radioactive-Waste-Containing Components of Nuclear Power Plants, dated December 2021 (ML21232A142).

18. RG 1.29, Revision 6, "Seismic Design Classification," dated July 2021 (ML21155A003).

19. RG 1.234, Revision 1, Evaluating Deviations and Reporting Defects and Noncompliance Under 10 CFR Part 21, dated March 2024 (ML240038A311).

20. Revision 1 of NEI 14-05A, Guidelines for the Use of Accreditation in Lieu of Commercial-Grade Surveys for Procurement of Laboratory Calibration and Test Services, dated September 2020 (ML20259B731).