View source for ZS-2010-0199, Submittal of Quality Assurance Project Plan, ZS-QA-10

{{Adams
| number = ML102150351
| issue date = 07/27/2010
| title = Submittal of Quality Assurance Project Plan, ZS-QA-10
| author name = Tramm T
| author affiliation = ZionSolutions, LLC
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/FSME
| docket = 05000295, 05000304
| license number = DPR-039, DPR-048
| contact person = 
| case reference number = ZS-2010-0199
| document type = Letter type:ZS, Quality Assurance Program
| page count = 241
}}

=Text=
{{#Wiki_filter:ZIONSOLuTONa 10 CFR 50.54(a)(3)
ZS-2010-0199 July 27, 2010 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Zion Nuclear Power Station, Units 1 and 2 Facility Operating License Nos. DPR-39 and DPR-48 NRC Docket Nos. 50-295 and 50-304

==Subject:==
ZionSolutions LLC Quality Assurance Project Plan, ZS-QA-10

==References:==
: 1) Letter from T. S. O'Neill (Exelon Generation Company) and J. Christian (ZionSolutions)to NRC, "Application for License Transfers and Conforming Administrative License Amendments," dated January 25, 2008
: 2) Letter from P.B Cowan, Exelon Generation Company, LLC and AmerGen Energy Company, LLC, "Submittal of Exelon Generation Company, LLC and AmerGen Energy Company, LLC Quality Assurance Topical Report, NO-AA-10, Revision 84," dated February 5, 2010 In accordance with the requirements of 10 CFR 50.54(a)(3), ZionSolutions, LLC (ZionSolutions) is submitting the ZionSolutions Quality Assurance Project Plan (QAPP) for NRC review. This letter satisfies the requirements of 10 CFR 50.54(a)(3) to provide the NRC with information on changes to the quality assurance program which do not reduce commitments in the program description, and therefore, do not require NRC approval prior to implementation.
By order dated May 4, 2009 the NRC has approved the transfer of Facility Operating License Nos. DPR-39 and DPR-48 for Zion Nuclear Power Station Units 1 and 2 (Zion) from Exelon to ZionSolutions. As indicated in the application for this license transfer (Reference 1), ZionSolutions will implement the applicable requirements of the NRC approved Exelon Quality Assurance Topical Report (QATR, Reference 2). The QATR, Appendix A, Section 2.6.1 "Augmented Quality Requirements for Zion Station's Important to Defueled Condition Structures, Systems, Components and Activities" includes provisions for an augmented quality assurance program specific to the defueled condition.
Based on recent improvement in the value of the Zion decommissioning trust fund, ZionSolutions expects the transfer of the Zion operating licenses to occur soon and intends 101 Shiloh Boulevard 9 Zion, IL 60999 224.789.4016
* Fax 847.379.2746

July27, 2010 U.S. Nuclear Regulatory Commission ...
Page 2 to begin decommissioning activities promptly thereafter. :To assure :appropriate control6 of activities associated :with dry.fuel storage, Zion Solutions has: prepared armajor upgrade.to:
the quality program: document~that incorporates, the prior provisions of, the QATR applicable to Zion Station and also addresses the full requirementsof 10 :CFR 50, Appendix 'B. The upgraded program is now referred; to :as Zion Solutions document ZS-QA-1 0, Zion Station Quality:Assurance, ProjectlPlan .(QAPP) (Enclosure( 1). Enclosure 2 provides a:discussion of the QAPP commitments: to NQA-1l-1993 and describes the additional supporting:::
information which is provided in Enclosures 3 and 4. While .this change :supplements     the currently applicable requirements, it results in no reduction in prior comm tments and is therefore submitted in accordance with the requirements of 10 CFR 50.54(a).(3).
ZionSolutions expects to implement the QAPP concurrent with completion of :the transfer of the operating licenses.                                                   ...
If you have any questions about this letter, please contact me at (847) 78974042.:
Respectfully, Tom R. Tramm
.Director, Regulatory Affairs & QA Zion Solutions, LLC

==Enclosures:==

(1) ZionSolutions Quality Assurance.Project Plan,: Rev.11, :dated February:9, 2010
()Summar 'of:Commitments. to NQAA-1 (3) NQA-I:to QAPP Cross-reference Matrix (4) NQA-:1 vs. No0n-programmatic:,ANSI. Standards Tabke. (6).
cc*.            Regional Administrator, Region (ll, US NRC

Enclosure         1 ZIONSOLUTIONSUC      An~enaSso~on,p, Quality Assurance Project Plan ZS-QA-1 0 ZionSolutions LLC Zion Station Restoration Project Revision 1 February .9,2010 AuthorApproval:
Edward L Martin, Acting Quality Assurance Manager             Date RAIQA Approval:       omX2   r2-e                      o                       -z7)/ 0  0 Tom: R.Tramm, Direc~tor, :RegulatoryAffairs and QA          "Date Cororate QA
          ,Approval:
Richard E, Campbell, EnergySolutionsCorporate Director, QA    Date Senior VPeApproval:
ck eio al, VP&      enealManagerlr&#xfd;                  Date

ZS-QA- 10 Revision 1 Information Use ZIONSOLUTIONS LLC ZION STATION RESTORATION PROJECT STATEMENT OF QUALITY ASSURANCE POLICY This Quality Assurance Project Plan (QAPP) defines the ZionSolutions LLC Quality Assurance Program to be implemented during the Zion Station Restoration and Dry Cask Storage (DCS) Project at the Zion Nuclear Power Station (ZNPS) site. This QAPP is designed to meet the requirements of Title lO of the Code of Federal Regulations, Part 50 Appendix B, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," ANSIIASME NQA-1-1994, Part 71, Subpart H, "Quality Assurance Requirements for Packaging and Transportation of Radioactive Waste" and Part 72, Subpart G, "Quality Assurance Requirements for the Independent Storage of Spent Nuclear Fuel, High Level Radioactive Waste, and Reactor-Related Greater Than Class C Waste."
The QAPP incorporates the applicable portions of the current EnergySolutions Quality Assurance Program (QAP) Revision 0, effective date May 31, 2007, and the existing Exelon Quality Assurance Topical Report (QATR) Revision 81, Appendix A, Section 2.6, Augmented Quality requirements for Zion Station. Augmented Quality requirements are' addressed in the appropriate subsections of Section 4.0, Quality Assurance               .
Requirements, and are implemented in a graded approach.
Implementation of the QAPP will include initial training to ensure employees are aware of their personal responsibility to consistently deliver quality products and services that meet regulatory, and industry requirements while ensuring the health and safety of their fellow workers, the public, and the environment, This QAPP applies to all activities associated with the design, fabrication, installation, and operation of an Independent Spent Fuel Storage Installation (ISFSI), safe storage of spent nuclear fuel, and all related plant modifications and other site activities as designated by the General Manager. Design and fabrication of the Dry Fuel Storage System (DFSS) portion of the DCS project will not be performed under this QAPP; however, selection, qualification, and performance-based overview of the selected DFSS designer and DFSS fabrication will be conducted in accordance with this QAPP.
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ZS-QA- 10 Revision 1 Information Use TABLE OF CONTENTS Page No.

==1.0 INTRODUCTION==
5 1.1    Project Quality Assurance Program                                             5 1.2    Scope                                                                         7 2.0 QUALITY RESPONSIBILITIES                                                             8 2.1    Senior Vice President & General Manager                                       8 2.2    Senior Vice President & Gen Mgr, Comm'l Services Operations                   8 2.3    Management Team                                                               8 2.4    Director Regulatory Affairs and Quality Assurance                             9 2.5    Quality Assurance Manager                                                     9 2.6    Human Resources/Training/labor Relations Manager                              9 2.7    ZionSolutions Project Review and Advisory Board                              10 2.8    Quality Assurance Personnel                                                  10 2.9    Support Personnel                                                            10 2.10   Supplier/Subcontractor Project Managers                                      10 2.11   Supplier/Subcontractor Quality Assurance Managers                            10 3.0 CLASSIFICATION OF PROJECT TASKS                                                     11 Table 3.1 - ZionSolutions Quality Classification Category Descriptions              12 4.0 QUALITY ASSURANCE REQUIREMENTS                                                      13 4.1    Organization                                                                 13 4.2    QA Program                                                                   13 4.3    Design Control                                                               17 4.4    Procurement Document Control                                                 22 4.5    Instructions, Procedures and Drawings                                        23 4.6    Document Control                                                             23 4.7    Control of Purchased Material, Equipment and Services                        24 4.8    Identification and Control of Materials, Parts and Components                28 4.9    Control of Special Processes                                                 29 4.10   Inspection                                                                   30 4.11  Test Control                                                                  31 4.12   Control of Measuring and Test Equipment                                      33 4.13   Handling, Storage and Shipping                                               34 4.14   Inspection, Test, and Operating Status                                       35 4.15  Nonconforming Materials, Parts or Components                                  35 4.16, Corrective Action                                                             36 4.17  Quality Assurance Records                                                     37 4.18  Audits                                                                        41 3

ZS-QA-10 Revision 1 Information Use TABLE OF CONTENTS Page No.
5.0     QUALITY MONITORING                                                             44 6.0     ZIONSOLUTIONS QUALITY COUNCIL                                                  44

==7.0     REFERENCES==
45 FIGURES Figure 1     ZionSolutions Restoration and DSC Organization Chart                      46 APPENDICES Appendix A   List of Acronyms                                                          47
                                   .4

ZS-QA- 10 Revision 1 Information Use 1.0     Introduction The Zion Nuclear Power Station (ZNPS) located in Zion, Illinois is currently being maintained in a SAFSTOR condition by its owner, Exelon Corporation. The Exelon Quality Assurance Topical Report (QATR) is designed to meet the requirements of 10 CFR 50, Appendix B, and ANSI/ASME NQA-1-1 994, and reflects the direction of applicable regulatory guides and industry standards thereby assuring that the health and safety of the public is not caused undue risk.
EnergySolutions has entered into an agreement with Exelon under which ZionSolutions, a wholly-owned subsidiary of EnergySolutions, assumes ownership of the facility, takes possession of the licenses, and undertakes decommissioning activities, to be conducted by EnergySolutions and affiliated companies.
The nuclear fuel stored in the Spent Fuel Pool (SFP) will be placed in Dry Cask Storage (DCS) casks and stored in an ISFSI, a secured storage pad on the ZNPS site. In addition, greater than Class C (GTCC) waste also will be stored at the ISFSI location.
This Quality Assurance Project Plan (QAPP) defines the methodology that the ZionSolutions Project Team will utilize to meet the quality assurance requirements of 10 CFR 50 Appendix B, ANSI/ASME NQA-1-1994, 10 CFR 71 Subpart H, and 10 CFR 72 Subpart G as applicable to these tasks.
1.1     Project Quality Assurance Program This QAPP defines the Quality Assurance (QA) program requirements applicable to the ZionSolutions restoration and DCS project including activities such as: existing plant operations, licensing, site design, procurement, vendor selection, fabrication, shipping, receiving, storing, cleaning, erecting, site installation, inspecting, testing, cask loading, cask sealing, cask handling, preparation for an ISFSI operation, waste handling, packaging and transportation, and associated plant modification activities. The QAPP also may be utilized for other site activities as designated by the General Manager.
Quality Assurance, as defined herein, encompasses all those planned and systematic actions related to the control of the physical characteristics and quality of the material or components to predetermined requirements necessary to provide adequate confidence that a component, structure, or system will perform satisfactorily in service. Quality is recognized as an interdisciplinary function and not the sole responsibility of the Quality Assurance Department. The QAPP utilizes the existing 10 CFR 50 Appendix B, NRC approved, Exelon QATR as the initial basis of the program. In addition, the QAPP incorporates the EnergySolutions NRC approved 10 CFR 71 Subpart H QAP requirements.
QA programmatic requirements within this QAPP are based on, and meet, all applicable quality assurance requirements stipulated in 10 CFR 50 Appendix B, 10 CFR 71 Subpart H, and 10 CFR 72 Subpart G. In addition, the applicable requirements of 5

ZS-QA- 10 Revision 1 Information Use ANSI/ASME NQA-1-1994 Basic Requirements have been incorporated. It should be noted that the EnergySolutions QAP commits to the requirements of 10 CFR 50 Appendix B, 10CFR71 Subpart H, 10CFR72 Subpart G, and ANSI/ASME NQA-1.
The project's quality program as defined in this QAPP primarily consists of the current Exelon QATR, EnergySolutions QAP, and applicable existing ZNPS and ZionSolutions' implementing procedures and instructions. Additionally, project unique procedures and processes, and Subcontractor QA programs define various aspects of the quality program controls that are applicable to the DCS project and other site activities as designated by the General Manager, and supplement this QAPP. The project unique procedures and process documents address applicable elements of ASME NQA-1-1994 Supplementary Requirements.
Supplier and subcontractor quality activities associated with the DCS will be performed in accordance with a QA program that meets the requirements of this QAPP as specified in written ZionSolutions contract documents. Activities will not be subcontracted without documented permission of the ZionSolutions Senior Vice President & General Manager (GM) and ZionSolutions Quality Assurance Manager (QAM). Suppliers and subcontractors will perform their activities in accordance with their QA programs, procedures, and specific project procedures, which shall be reviewed and accepted by ZionSolutions QA prior to use. Subsequent to ZionSolutions acceptance, all major changes to supplier and subcontractor programs, procedures, instructions and processes applicable to the project shall be reviewed and accepted by ZionSolutions prior to use.
The Zion Restoration and DCS project includes activities that temporarily maintain existing SSCs in operation, decommissioning of SSCs that are no longer required, design and construction of an ISFSI and transferring fuel from the existing SFP to the ISFSI, and releasing the remainder of the site for unrestricted use. The QAPP is written to invoke the quality assurance requirements that apply to these activities based on their function and importance to safety. As such, varying degrees of QA criteria are applied.
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ZS-QA-10 Revision 1 Information Use 1.2     Scope This QAPP applies to project activities performed by the ZionSolutions project team and its suppliers and subcontractors for the duration of the DCS project activities associated with the operation and decommissioning of SSCs classified as Important to Defueled Condition (ITDC), and other site activities as designated by the GM. The DCS portion of the project is defined as beginning with the project conceptual design including ZNPS modifications required to accommodate the DFSS and continuing through the final placement of the last DFSS canister on the ISFSI pad and ending with the completion of the clean-out of the fuel pool. Operation of the ISFSI will be performed under this QAPP. The Restoration portion of the project includes activities that release the site for unrestricted use except for the ISFSI.
A Graded Approach To Quality shall be applied to the DCS project activities and other selected site activities as designated by the GM and will be defined through classification of tasks delineated in Section 3.0.
The Graded Approach to Quality involves both technical and quality oversight requirements for project activities, including subcontractors, and typically consists of a balanced review of technical and quality capabilities with a focus on technical acceptability of the activity, product and service.
The Augmented Quality requirements that were established by Exelon for existing SSC's designated as ITDC will continue to be applied in a graded approach as defined in the applicable subsections of Section 4.0, Quality Assurance Requirements.
See Section 3.0 for project task classification, Section 4.0 for QA requirements and Section 5.0 for QA oversight.
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ZS-QA-10 Revision 1 Information Use 2.0    QUALITY RESPONSIBILITIES This section defines the responsibilities of key project members accountable for implementation of the QAPP. Functions and actions can be delegated; however, the responsibility remains with the designated individual. Implementation and management oversight of the QAPP is the responsibility of the following key individuals:
Note: Minor variations may occur between the titles contained herein and those used in practice. Specific position descriptions may be contained in other approved company documents. Certain functions may be named differently within the EnergySolutions and ZionSolutions organizations.
2.1     Senior Vice President & General Manager (GM)
This project executive provides direct oversight of the project, and other selected tasks, to ensure the project is properly planned, staffed and executed. The General Manager has periodic meetings with the management team to review plans and progress and to address stakeholder, quality, and project management issues. The GM delegates to the Management Team the day-to-day responsibilities for the DCS project, plant operation and decommissioning such as, but not limited to, safe conduct of work, procedure reviews, test and experiment reviews, personnel qualification, and other selected tasks.
2.2     Senior Vice President & General Manager, Commercial Services Operations (SVP)
This executive manages the operation of all EnergySolutions projects at commercial facilities. He reports directly to the President of ZionSolutions. The SVP assures that the ZionSolutions project receives timely and effective support from EnergySolutions corporate groups. He meets periodically with the General Manager and other key managers to review plans and progress and to address project management and quality issues.
2.3     Management Team The Management Team consist of those VP's, Directors and Managers who are the senior person in each department/functional area. They report directly to the GM on all DCS project, plant operations and decommissioning activities and are responsible for the implementation of the QAPP for the duration of the project and other site activities as designated by the General Manager. Management Team members have full authority and accountability for successful project planning and execution, including effective implementation of this QAPP. They are responsible for assuring that project personnel are properly indoctrinated, trained, and qualified to all applicable project quality and technical requirements. They also are responsible for satisfactory resolution of nonconforming conditions and effective implementation of corrective action commitments. They are responsible for contract management and 8

ZS-QA-10 Revision 1 Information Use development of contract deliverables in accordance with quality requirements defined in this QAPP. They are also responsible for ensuring that applicable project quality and technical requirements are transmitted to, addressed by, and acceptably implemented by the project's Subcontractors.
2.4      Director Regulatory Affairs and Quality Assurance (DRA/QA)
The DRA/QA reports directly to the GM on licensing and quality assurance issues.
The DRA/QA is responsible for the day-to-day licensing activities, interfaces with the Nuclear Regulatory Commission and Exelon, and is the Single Point of Contact for licensing and regulatory matters and concerns. The DRA/QA has management overview responsibility for quality assurance requirements and staffing. The Director is a member of the ZionSolutions Quality Council and, in the absence of the Quality Assurance Manager, chairs the Council.
2.5      Quality Assurance Manager (QAM)
The QAM reports to the DRA/QA, and has access to the GM and EnergySolutions Corporate Director, QA for quality matters. The QAM also has a functional relationship with the Management Team Members and Project Support Personnel (PSP). The QAM is responsible for establishing and maintaining the QAPP, monitoring the project's quality objectives through overview activities, and providing feedback to management on the effectiveness of the QAPP. The QAM evaluates, accepts, and performs oversight of supplier and subcontractor Quality Assurance programs.
The QAM formulates and assures execution of overview/acceptance plan for suppliers and subcontractors that lack acceptable Quality Assurance programs to ensure their full compliance with applicable requirements of this QAPP. The QAM is the custodian of this QAPP and, as such, is responsible for initiating necessary changes and revisions and obtaining necessary reviews and approvals of technical changes. The QAM and the Training Manager, with assistance from Quality Assurance personnel, provide orientation and training on applicable quality requirements to the project team. The QAM also is responsible for identification and execution of quality HOLD points, QC inspections, and QA/QC personnel qualification. The QAM chairs the ZionSolutions Quality Council and periodically provides reports on project quality activities to the GM, DRA/QA, and the management team.
2.6      Human Resources/Training/Labor Relations Manager (HRTLRM)
The HRTLRM reports directly to the GM in a number of capacities. For purposes of this QAPP, the Manager is responsible for overview and management of the project training program. The Manager shall periodically evaluate and report the status of the training program and effectiveness of the training process to the GM.
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ZS-QA-10 Revision 1 Information Use 2.7     ZionSolutions Project Review and Advisory Board (PRAB)
The Project Review and Advisory Board provides independent oversight of the project to ensure compliance with licenses and regulations and to provide guidance on where improvements are needed and how they can be made. The PRAB has access to audit and management assessment reports and provides feedback to the GM and input to the Quality Council. The PRAB reports to the President, ZionSolutions.
2.8     Quality Assurance Personnel The QA personnel report directly to the QAM and have a functional relation with management and support personnel. The QA personnel perform project overview activities such as oversight, auditing, and inspecting to verify that activities affecting the functions that are important to safety have been correctly performed. In addition, they support the supplier and subcontractor Quality Program evaluation process.
2.9     Support Personnel (SP)
The Project Team consists of a number of support personnel that are responsible for performing their activities in accordance with this QAPP. Support personnel activities include, but are not limited to, safety, ALARA/RP, engineering, licensing, operations, security, maintenance, document control/records, fire protection, reactor engineering, emergency planning, training, and procurement.
2.10    Supplier/Subcontractor Project Managers Supplier/Subcontractor Project Managers are responsible for assuring their personnel are properly indoctrinated, trained, and qualified to all applicable project and Subcontractor quality program requirements. They are also responsible for assuring acceptable implementation of technical and quality requirements, and for ensuring when nonconforming conditions are identified, they are satisfactorily resolved.
2.11    Supplier/Subcontractor Quality Assurance Managers The Managers are responsible for assuring their quality program and procedures are effectively implemented in accordance with the Supplier's QA program (reviewed "
and accepted by ZionSolutions) and this QAPP. Each Manager is responsible for providing proposed Quality Assurance program revisions to the QAM for review and acceptance prior to implementation on the DCS project. Each Quality Assurance Manager of major suppliers/subcontractors may be a member of the Quality Council as determined by the GM and QAM.
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ZS-QA-10 Revision 1 Information Use 3.0     CLASSIFICATION OF PROJECT TASKS The DCS project involves activities that include design, procurement, fabrication, construction, assembly, inspection, testing, repair, modification, and data collection that are subject to 10 CFR 50, 10 CFR 71, and/or 10 CFR 72 regulatory requirements. The Quality Assurance requirements of these activities are classified based on their function and importance to safety, and are described in Section 4.
The extent of the quality assurance criteria applicable to tasks associated with the Systems, Structures and Components (SSCs) will, as a minimum, be based on their quality classification. The level of quality rigor applicable to a task is directly proportional to the task's importance to safety. The quality classification dictates-the quality requirements and overview applicable to a task.
Assignment of quality classification is a two-step process consisting of:
(i)     Determination of EITHER important to safety OR not important to safety, and (ii)    Categorization of SSCs determined to be important to safety.
DCS SSCs are classified as Important to Safety or Not-Important to Safety based on their function and the definition of Important to Safety provided in Table 3.1, "DCS Quality Assurance Classification Category Descriptions." Guidance provided in NUREG-1536, NUREG-1567, and, NUREG-1617 Standard Review Plans also is utilized when making the determination of task classifications.
Importance to Safety relates to the basic ISFSI nuclear safety criteria, as follows:
* Maintain subcriticality
* Maintain confinement
" Ensure that radiation dose rates and doses for workers and public do not exceed acceptable levels (and remain ALARA)
" Maintain retrievability of the fuel by normal means
* Heat removal (as necessary to meet the above criteria)
Once a SSC is determined to be Important To Safety it is further categorized into one of three quality assurance classification categories (A, B, or C) based on the descriptions given in Table 3.1. The ISFSI quality assurance classification categories given in Table 3.1 are consistent with the NRC guidance given in NUREG/CR-6407 and Regulatory Guide 7.10.
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ZS-QA-1 0 Revision 1 Information Use Table 3.1 - DCS Quality Classification Category Descriptions Any structure, system or component whose failure could directly result in a condition adversely affecting public CRITICAL health and safety. The failure of a single item could cause A        TO SAFE loss of primary containment leading to release of OPERATION radioactive material, loss of shielding, or unsafe geometry compromising criticality control.
Any structure, system or component whose failure or malfunction could indirectly result in a condition adversely B        SAFETY               affecting public health and safety. The failure of a category B item, in conjunction with a failure of an additional item, could result in an unsafe condition.
Any structure, system or component whose failure or MINOR IMPACT ON      malfunction would not significantly reduce the packaging SAFETY               effectiveness and would not be likely to create a situation adversely affecting public health and safety.
Any structure, system or component whose failure or NITS       Not Important To     malfunction would not reduce the packaging effectiveness Safety               or would not create a situation adversely affecting public health or safety.
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ZS-QA- 10 Revision 1 Information Use 4.0     QUALITY ASSURANCE REQUIREMENTS Quality procedures, instructions, processes, and systems will be utilized to manage, supervise and perform work for the duration of the Zion Restoration and DCS project.
The approach to achieving effective quality assurance and control throughout the project involves the effective execution of this QAPP, the DFSS Designer, the Design Authority, and other supplier/subcontractor quality programs and associated procedures, instructions, processes, and systems. A Design Authority (DA) is a selected Architect-Engineering firm, crane designer, or the selected Dry Cask Storage System (DCSS) Designer for the DCS project. Each is the Design Authority within its assigned scope of responsibility.
4.1     Organization The Zion Restoration and DCS Project organization, authority, duties, responsibilities, and interface requirements are addressed in QAPP Section 2.0, Quality Responsibilities. These activities include performing activities affecting the functions of structures, systems, and components which are important to safety, those associated with attaining quality objectives, and the QA functions. The primary Zion Restoration and DCS Project organizations are ZionSolutions, EnergySolutions, DFSS Designer, DFSS Prime Fabricator(s), and Design Authorities.
The QAM position shall be responsible for verifying the proper establishment and effective execution of the QAPP and shall have no assigned responsibilities that would preclude appropriate attention to Quality Assurance matters.
Quality Assurance staff shall have sufficient independence from cost and schedule considerations and shall have the access to work areas and organizational freedom to effectively identify quality problems, initiate, recommend or provide solution to quality problems through designated channels, verify implementation of solutions; and assure that further processing, delivery, installation, and use are controlled until proper disposition of a nonconformance, deficiency, or unsatisfactory condition has occurred.
The QAM has the authority to stop work when significant conditions adverse to quality warrant such action.
In the case where differences of opinion involving the QAPP requirements exist, they shall be brought to the attention of the GM for resolution. If necessary, the QAM also has the ability to elevate the item to the Corporate Director, QA for resolution.
The responsibility for achieving and maintaining quality resides with those performing the work. Personnel or organizations not directly responsible for performance of the work can verify quality achievement of that work.
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ZS-QA-10 Revision 1 Information Use 4.2 QA Program The ZionSolutions Quality Assurance Project Plan (QAPP) consists of those planned and systematic actions necessary to assure that activities will be conducted in a satisfactory manner and that equipment and material will perform satisfactorily in service. The system is based on the concept that work performance is a process that can be planned, executed, assessed, and improved. Management is responsible for these ongoing activities. Since all work is accomplished using people, equipment, and procedures as directed by management, management is responsible for fostering an attitude of support and encouraging personnel to complete their work in a quality manner. All employees are responsible for identifying non-compliant work or areas for improvement. Management is responsible for identifying (both internal and external) project needs and expectations. Meeting these needs and expectations is a measure of quality and success.
4.2.1    QAPP Application Procedures describe how ZionSolutions implements the requirements of the QAPP. These procedures document methods for planning, reviewing, implementing, controlling, and verifying activities affecting quality.
The QAPP shall apply to all activities that are important-to-safety or DCS operations and require compliance with applicable sections of the documents listed below:
            -   10CFR50, Appendix B
* 10CFR71, Subpart H
* 10CFR72, Subpart G
* ANSI/ASME NQA-1-1994 The applicability of the QAPP takes into consideration the regulatory requirements for important-to-safety and DCS operations items and activities, as well as their complexity and impact on safety, the need for special controls, demonstration of compliance through inspection and test, and the degree of standardization of the item. The requirements of the QAPP are implemented using a graded approach allowing control over items and activities to be commensurate with their importance and level of risk and are not reductions in quality requirements. Measures are established for identifying the components, systems, and structures to be covered by the QAPP. During the planning of an activity or design of an item the QAPP requirements will be implemented through procedures.
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ZS-QA-10 Revision 1 Information Use 4.2.2 Quality Achievement, Management, and Verification The achievement of quality is the responsibility of all employees and is led by management. The QAPP provides for a systematic approach at various levels for oversight and assessment to assure the adequacy and effectiveness of implementation of the QAPP and implementing procedures. A tiered approach to verification and assessment includes self-checking by the individuals performing the work, supervision and oversight by management, independent inspection, and surveillance and verification to confirm adequacy and effectiveness of results. Managers are required to assess the effectiveness of their own operations and implementation of their portion of the QAPP. QA personnel perform independent audits, surveillances, and inspections to verify the effectiveness of the QAPP.
The management team provides systematic planning to establish the scope of work, analyze hazards, and confirm the appropriateness of methods to be used and controls to be applied. Work performed is then monitored to confirm performance within the established controls and to provide feedback to achieve continuous improvement as an integral process of assuring effectiveness of the quality and safety systems.
The management team members within each group periodically perform effectiveness reviews of activities that affect quality, safety, and regulatory requirements. The management team is comprised of representatives from Engineering, Operations, Quality Assurance, Safety, Radiation Safety, and other areas as needed.
On an annual basis, the Director, Regulatory Affairs and QA, will provide the GM an assessment on the effectiveness of the QAPP. This assessment is based on the performance and review of audits, independent assessments, inspections, surveillances, and trending.
4.2.3 Personnel Qualification and Certification 4.2.3.1    Training and Indoctrination The requirements and responsibilities established for the project Team ensure that management assess their organizations' training needs and assure that all personnel performing activities affecting quality are indoctrinated, trained, and qualified according to their level of responsibility and assigned functions.
This includes training on appropriate procedures, processes and policies and any special skill training required for the performance of job activities. Qualification is completed prior to 15

ZS-QA-10 Revision 1 Information Use performing work, unless qualification is based upon demonstration of job skills under the supervision of a qualified person. The extent of such training is commensurate with the scope, nature, and complexity of the activity, as well as the education, experience, and abilities of the individual. Training scopes, objectives, and methods of implementation are included in approved procedures.
All activities affecting quality are accomplished under suitably controlled conditions. Controlled conditions include the use of appropriate equipment, suitable environmental conditions for accomplishing the activity, and assurance that prerequisites for the given activity have been satisfied. Management provides for any special control, processes, test equipment, tools, and skills to attain the required quality and for verification of quality.
Indoctrination and training are conducted as necessary to assure suitable proficiency is achieved and maintained. Project personnel shall be trained in the applicable procedures and project-specific documents..
The QAM shall monitor suppliers/subcontractors, as necessary, for implementation of these requirements.
4.2.3.2 Inspection and Test Personnel Inspection and test personnel have experience commensurate with the scope of work and the complexity of the activity and are selected and trained in accordance with approved procedures.
The job performance of inspection and test personnel is reevaluated at periodic intervals not to exceed three (3) years.
Certification or qualifications that are revoked for deficient job performance will result in the reevaluation of items inspected or tested by the individual.
Personnel performing nondestructive examinations are qualified in accordance with the American Society of Nondestructive Testing recommended practice, or as otherwise commensurate with the NDE requirements.
Certification documentation shall be maintained in accordance with approved procedures.
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ZS-QA-1 0 Revision 1 Information Use 4.2.3.3     Lead Auditors and Inspectors Quality Assurance (QA) Lead Auditors are qualified and certified by ZionSolutions or by approved suppliers. Lead Auditors are qualified in accordance with established procedures, and records are maintained. Training methods, minimum experience requirements, and certification practices are in accordance with NQA-1, Supplement 2S-3, 1994. Proficiency evaluations are performed annually and documented for individuals performing audit activities and appropriate certification renewal or re-qualification actions are taken.
Personnel performing inspection activities are qualified and certified in accordance with established procedures that comply with ANSI N45.2.6, 1978 or NQA-1, Supplement 2S-1, 1994.
Auditor and Inspector certification documentation shall be maintained in accordance with approved procedures.
4.3 Design Control Design Control procedures ensure that the design meets applicable regulatory requirements, and that design activities are carried out in a planned and controlled manner. Procedures describe responsibilities for design interface, control, verification, and change. Approved procedures govern translation of applicable project and regulatory requirements and design bases into design, procurement, and procedural documents, as Well as controlling the design documents and design document distribution.
ITDC Design Control requirements are addressed via a graded approach.
Design controls shall be applied to: criticality physics, radiation shielding, stress, thermal, hydraulic, accident analysis, compatibility of materials, accessibility for in-service inspection, maintenance and repair, features to facilitate decontamination, and delineation of acceptance criteria for inspections and tests.
4.3.1   Design Input The engineering organization is responsible for identifying and documenting design input. Design inputs include:
* Design basis;
* Performance requirements; Regulatory requirements; 17

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* Equipment specifications;
* Industry codes and standards; and
* Technical requirements.
The input used in each design is documented, reviewed, and approved in a timely manner by the responsible design organization. Documented design inputs provide the necessary level of detail to ensure the design activity can be carried out correctly and provides a consistent basis for making decisions, accomplishing design verification, and for evaluating changes. Changes from approved design inputs, including the reason for the changes, are documented, approved, and controlled.
Design inputs including appropriate quality standards shall be specified in a timely basis and translated into applicable design documents.
Deviations from the quality standards shall be controlled. Design measures shall include review for suitability of application for materials, parts, equipment and processes that are important to safety.
4.3.2 Design Process ZionSolutions describes and controls the design process through approved procedures. Appropriate design documents are developed to support the design, construction/manufacture, and operation. Quality standards are identified, documented, and approved by cognizant personnel. In addition, measures are established for selection and review for suitability of application of materials, parts, equipment, and processes.
Design activities result in design output documents that meet the design input requirements. Design documents contain the identification of assemblies and/or components that are part of the item being designed.
These measures include provisions to assure quality standards are specified and included in design documents. Any deviations from these standards are documented, reviewed, and approved.
4.3.3 Design Analysis Design analysis is performed and documented in accordance with approved procedures. Design analysis reports provide the following details as applicable:
* The objective of the analysis;
* Design inputs and their sources;
* Literature research and background data; 18

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* Assumptions and designation of those that must be verified as design proceeds;
* Calculation methodology and calculations; a Summary of results and compliance with requirements;
* Identification of computer calculations, including computer hardware and software; and
* Review and approval as specified in engineering procedures.
The Project team shall develop a standardized approach for the project to initiate, perform, document, check, approve, revise, and retain engineering calculations. This process will be utilized by project personnel performing design calculation activities including internal design review, validation, and verification activities on design information and design products produced.
4.3.4 Design Verification Design verification is performed to ensure that appropriate requirements and project needs are translated to the design documents. Design verification is performed in accordance with approved procedures that define responsibilities, methods, and documentation requirements.
Independent personnel who have qualifications equal to those of the original design personnel perform design verification. This could include an engineering supervisor who initiated the design provided he/she did not specify a singular design approach or rule out certain design considerations. No individual is ever the verifier for his/her own work or input.
Design verification methods include, but are not limited to, formal design reviews, alternative calculations, and qualification testing. The level of design verification applied complies with identified requirements.
Design verification is usually performed and discrepancy resolution is complete prior to the release of the design output document for production uses or process implementation. An exception would be cases where insufficient data exists to finalize the design at a point in the project where material procurement or preliminary facility construction must begin. In such cases, unverified portions of the design are identified and controlled.
Final design verification is completed prior to reliance on the item or process to perform its function. Engineering Management shall document completion of design verification.
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ZS-QA-10 Revision 1 Information Use The design documents and records that provide evidence that a design analysis was accomplished in accordance with this QAPP shall be accumulated, maintained, and stored at the site for the duration of the project.
4.3.5 Design Review Management is responsible for ensuring design reviews are performed at appropriate phases of the design process. Design review performance requirements, methods, and responsibilities are included in approved procedures.
The design is evaluated for the adequacy of the incorporated design inputs and the design methods used. Responsibilities for action items are assigned, verified completed, and the results are incorporated into the final design.
Individuals or multi-disciplined design review teams perform independent reviews on important-to-safety and DCS operations items. These reviews are performed by competent personnel and address the following as applicable:
* Design input selection;
* Design output compared to design input and verification requirements from interfacing organizations;
* Design methods;
* Design inputs correctly incorporated into the design;
* Adequately described, reasonable, and identified assumptions; and
* Assignment of quality levels.
QA may review design drawings, specifications, calculations, and procurement documents via a performance-based overview process (generally not as an in-line review responsibility).
4.3.6 Alternative Calculation The requirements for verification by alternative calculations are described in procedures that include the review of appropriateness of assumptions, input data, and computer program or other calculation methods used.
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ZS-QA-10 Revision 1 Information Use 4.3.7 Qualification Tests Qualification testing (synonymous with design validation) provides the assurance that products conform to defined user needs and requirements.
Qualification tests of important-to-safety and DCS operations items validate and demonstrate the adequacy of performance under conditions that simulate the most severe design conditions in accordance with written test procedures and test specifications. Test specifications are reviewed and approved by the responsible engineering organization. The engineering group responsible for the design approves results of the qualification tests. For tests performed on models or mockups, scaling laws are established and verified. Test results obtained for model or mockup test work are subject to error analysis, where applicable, prior to use in final design work. Information regarding verification that is incomplete, including incomplete qualification tests, is available prior to installation of equipment.
4.3.8 Design Changes Changes to final design, field changes, and modifications are justified and subject to design control measures commensurate with those applied to the original design. These measures shall include assurance that the design analyses for the items are still valid. Where changes to previously verified designs have been made, the initial design verification shall be reviewed for the impact of the changes to the original design and the need for any supplementary design verification shall be determined. Changes are approved by the same, or equivalent, group organization responsible for review and approval of the original design documents.
4.3.9 Interface Control Formal design interfaces are established when multiple organizations (internal or external) participate in the design process. Procedures are written that establish and document responsibility and authority for transmittal, review, approval, release, distribution, and revision of design inputs and design output documents. Transmittals shall indicate the status of design information or of documentation submitted, including any incomplete items that require further actions.
4.3.10 Computer Programs Computer programs (whether generated, transferred, or purchased) used to calculate or develop important-to-safety and DCS operations data shall be subjected to documented verifications or validations, including evaluation of program changes. Computer programs may be used for 21

ZS-QA-10 Revision 1 Information Use design analysis without individual verification of the program for each application provided:
0 The computer program has been verified to show that it produces correct solutions for the encoded mathematical model within defined limits for each parameter employed; and
* The encoded mathematical model has been shown to produce a valid solution to the physical problem associated with the particular application.
4.4 Procurement Document Control Controls for procured items and services are established in approved programs and procedures. These programs and procedures require the technical, quality, regulatory, and administrative requirements applicable to the procurement to be specified in procurement documents. To the extent necessary, procurement documents require suppliers to adequately implement a quality program consistent with the type and use of the item or service being purchased.
ITDC Procurement Document Control requirements are addressed via a graded approach.
Management is responsible for supplying personnel to perform the procurement process and ensuring that project-specific requirements for procurement documents are documented.
Procurement documents generated under the controls of this section involve project contracts placed with supplier/subcontractor team members or other supplier/subcontractors performing specific DCS tasks, and other tasks designated by the GM.
4.4.1 Content of the Procurement Document Procurement documents shall include the following as applicable: the scope of work; technical and regulatory requirements; quality criteria for items and services; quality requirements for suppliers and sub-tier suppliers; documentation requirements; quality record maintenance and retention; right of access for audit or inspection; requirements for reporting and approving supplier generated nonconformance's; and identification of spare and replacement parts.
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ZS-QA-10 Revision 1 Information Use 4.4.2 Procurement Document Review Technical, safety, and quality personnel who have an understanding of the requirements and intent of the procurement, shall review the procurement documents. Procurement documents are reviewed, approved, and documented prior to award.
QA shall review all Important to Safety (ITS) procurements for the appropriate Quality Assurance requirements prior to issuance.
4.4.3 Procurement Document Changes Changes to procurement documents receive the same level of review and approval as the original.
4.5 Instructions, Procedures and Drawings Management is responsible for ensuring that important-to-safety and DCS operations activities are described in instructions, procedures, or drawings, which are prepared and approved prior to commencing activities. All project personnel are responsible to perform their activities in accordance with the requirements of these documents. These documents include appropriate quantitative and qualitative acceptance criteria to verify that the activity has been satisfactorily accomplished.
ITDC instructions, procedures and drawings requirements are addressed via a graded approach.
Management is responsible for maintaining these documents current to reflect actual work practice. Instructions, procedures, work instructions and drawings are prepared, reviewed, issued, and controlled in accordance with approved procedures.
Procedures shall be reviewed periodically for adequacy and effectiveness.
4.6 Document Control Documents that prescribe or affect quality are controlled to ensure that the proper revisions are used. Controlled documents include documentation for important-to-safety and DCS operations activities such as procedures, work instructions, and drawings.
ITDC Document Control requirements are addressed via a graded approach.
The Document Control System ensures that all documents are properly identified, distributed, and retained as specified in approved procedures.
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ZS-QA-1 0 Revision 1 Information Use Documents are reviewed for adequacy and approved for release by authorized personnel prior to issuance. Documents are issued to and used at the location where the activity is performed as specified in project procedures. Document changes are reviewed and approved in accordance with project procedures.
Project documents, including changes, shall be identified, prepared, reviewed, approved, maintained, revised, and controlled in accordance with the requirements of this QAPP.
Documents will be controlled based upon their revision date and specific project distribution lists. Management is responsible for assigning personnel to originate and process project documents, for review and approval, and assure that correct documents are being used.
4.6.1   Document Preparation, Review, Approval, and Issuance Management is responsible for identifying documents to be controlled and for their distribution. Controls are established in approved procedures that define responsibility, authority, issue, use, and revision of controlled documents. Management ensures that documents are reviewed for adequacy, completeness, and correctness prior to issue.
4.6.2 Document Changes Document changes are reviewed and approved in accordance with project procedures. Minor changes such as inconsequential editorial corrections do not require the same review cycle as the original document. Approved procedures define the types of changes considered minor and the persons who are permitted to make these changes.
4.7 Control of Purchased Materials, Equipment and Services ZionSolutions procurement controls establish measures to ensure those procured items and services for important-to-safety and DCS operations applications are clearly and adequately specified in procurement documents.
Items and services are provided by suppliers and subcontractors who are capable of producing items and furnishing services that conform to procurement document requirements. These procurement methods are controlled by procedures for supplier evaluation, review of procurement requirements, and audit/surveillance of supplier's facilities.
ITDC Control of Purchased Items and Services requirements are addressed via a graded approach.
Commercial -grade items may be procured and dedicated for important-to-safety and DCS operations applications. Qualified project personnel shall identify the 24

ZS-QA-10 Revision 1 Information Use critical characteristics and the method(s) (e.g., special tests and inspections, commercial supplier survey, source verification, and/or acceptable supplier/item performance record) to be used to dedicate commercial grade items. Dedication of commercial grade items shall be accomplished in accordance with approved procedures.
4.7.1    Supplier Evaluation Project technical, procurement, and QA personnel participate, as appropriate, in evaluation of potential procurement sources performed by EnergySolutions' Corporate Quality Assurance Department or ZionSolutions QA staff. ZionSolutions' QA Department shall perform a third party review of EnergySolutions' audits to ensure they are acceptable to ZionSolutions'. ZionSolutions' recommendations of procurement sources are based on these evaluations. Results of supplier evaluations performed prior to contract award are documented and retained. The evaluations cover review of capabilities and facilities for technical, manufacturing, and quality performance, and include any or all of the following, as appropriate:
* Historical performance data, particularly in product quality and delivery.
* Review of supplier's QA Program, including current quality records.
         " Inspections, audits, or surveillances to verify supplier's QA Program implementation.
* Source qualification programs.
Supplier evaluations include elements of the QA Program applicable to the purchased item or services.
Engineering and QA will identify supplier qualification requirements and documentation in accordance with procedures.
4.7.2 Procurement Requirements Requirements to be met by the supplier are detailed in the procurement documents, which may include procurement specifications. Procurement specifications detail the supplier QA requirements such as inspection reports, provisions for inspection, equipment calibration prior to use, and provisions for inspection after component repair. The procurement specification also may require the supplier to submit the following for ZionSolutions's review:
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* Special process procedures for performing welding, heat treatment, and nondestructive examination.
* Recommended inspection point program.
* Appropriate documentation as required by applicable codes, standards, and procurement documents.
* Notices of nonconformance and their disposition.
* Test procedures in accordance with applicable codes and standards.
4.7.3 Supplier Surveillance QA is responsible for conducting and documenting supplier surveillance activities. Surveillance activities may include:
* Witnessing tests, inspections, nondestructive examinations, and various special process operations.
* Monitoring heat treatment, welding, cleaning, preserving, and packaging activities.
QA also is responsible for verifying supplier conformance with established procedures such as:
* Use of ZionSolutions accepted drawings and procedures.
* Document change control.
* Material identification and traceability control.
* Control of repairs.
      " Control and calibration of measuring and test equipment.
Documentation packages for purchased items, if required, are reviewed by QA or their qualified designee prior to release of the items for use. This documentation may include material test reports, inspection and test reports, NDE reports, and applicable code data reports.
4.7.4 Receiving Inspection Receiving inspection shall be performed for purchased items that are important-to-safety or DCS operations related (including spare or replacement parts) to ensure that:
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* Items are properly identified and correspond to the receiving documentation.
        " Inspection records and certificates of conformance attesting to the acceptance of the items are available.
        " Items accepted and released are identified as to their inspection status prior to forwarding them to a controlled storage area or releasing them for installation or further work.
* Physical attributes comply with specified requirements.
Records of such inspections and documentary evidence that material, equipment, and services conform to procurement specifications and documents shall be retained or be available prior to installation or use of the item, material, equipment or service, for the life of the package, and for the life of the ISFSI as applicable. Nonconforming conditions or discrepancies identified during a receipt inspection shall be documented
       *on Condition Report (CR). ZS will keep all fuel records and ISFSI component records and turn them over to Exelon upon transfer of the 10CFR50 licenses.
4.7.5 Post Installation Testing When used, post installation test requirements and acceptance criteria shall be established with input from the supplier, if appropriate.
4.7.6 Vendor Evaluation A documented evaluation is required annually for suppliers maintained on the supplier list. Supplier audits, when required, shall be conducted at least once every thirty-six (36) months in accordance with the audit section of this document. A third party review of an audit performed or accepted by EnergySolutions may be performed to add the supplier to the list. This review shall be documented.
The controls used for procuring items or services include the requirement that the suppliers/subcontractors are required to implement their QA Program for the requested item or service for ITS category A and B. Applicable subcontractors are subject to technical and quality assurance reviews for acceptance. Suppliers/
subcontractors performing activities that affect quality will conduct the activities in accordance with a Quality Assurance program that meets the applicable requirements of this QAPP. Supplier/subcontractor QA programs must be reviewed and accepted by ZionSolutions QA prior to use including technical and quality assurance program changes that result from bid evaluations or negotiations. Subcontractors will be evaluated to pre-established technical and quality assurance requirements.
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ZS-QA-10 Revision 1 Information Use Supplier/subcontractor qualifications and capabilities will be determined based upon evaluation, previous quality services provided, surveillance/audit and/or ZionSolutions or EnergySolutions recommendations. In addition to an initial evaluation of the supplier/subcontractor QA program, QA will perform periodic independent oversight (audit, surveillance or assessment) at intervals consistent with the importance, complexity and quantity of the product or service to ensure performance as required by the applicable ZionSolutions procurement document.
4.8 Identification and Control of Materials, Parts and Components Controls are established in approved procedures to assure that only correct and accepted items are used or installed. Identification is maintained either on the items or in documents traceable to the item. When such controls are required, the following methods of identification and control will be utilized.
4.8.1 Identification Identification such as batch, lot, serial number, or part number is maintained from initial receipt up to and including installation. The identification relates the item to the applicable design or other specification document when appropriate. ZionSolutions utilizes physical identification when possible. Other means, including separation or procedural control, are used when physical identification is not possible.
4.8.2 Markings Markings are applied using materials and methods that are clear, legible, and do not detrimentally affect the function or service life of the item.
Markings are transferred to each part of an identified item when subdivided. Markings are not obliterated or hidden by surface treatments or coatings unless other identification methods are established.
4.8.3 Traceability Project procedures specify methods for identification of items when codes, standards, or specifications require identification or traceability of an item.
Procedures describe how to maintain traceability to a specification, grade of material, heat, batch, lot, part or serial number, or inspection, test, or other records.
The identification and control of material, parts, and components will include the use of heat numbers when applicable to assure the maintenance of identification and traceability throughout all stages of the project and to prevent the use of incorrect or defective material, parts or
            .components.
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ZS-QA-10 Revision 1 Information Use 4.8.4 ShelflOperating Life Items having limited calendar or operating life are controlled to preclude use after the shelf life or operating life has expired.
4.8.5 Maintaining Identification in Storage Provisions are made in project procedures for maintenance or replacement of markings and identification due to damage from handling or aging, excessive deterioration due to environmental exposure, and for updating records while in storage.
4.9 Control of Special Processes Processes are planned and performed under controlled conditions that ensure conformance to project requirements, quality system requirements, and applicable codes, standards, and regulations. Inspection, audit, assessment, surveillance, and non-destructive examination procedures are used to perform such verifications. Management is responsible for ensuring that only properly trained and qualified personnel are assigned to accomplish work activities and that they are provided adequate facilities, equipment, tools, and information to perform their work in compliance with requirements. Managers monitor the quality of activities through the results of in-process checks described in implementing procedures. These checks may be performed by co-workers or supervisory personnel independent of the work and provide a method of tracking and trending events that affect the quality, safety, or regulatory status of operations, products, and services.
4.9.1 General Processes Instructions, procedures, drawings, checklists, process control documents, or other appropriate methods are used to control processes affecting the quality of items and services. When required, process parameters and environmental conditions are specified and maintained.
4.9.2 Special Processes Special processes that control or verify quality are performed by qualified personnel using qualified procedures. Personnel, equipment, and procedures used to perform special processes are qualified in accordance with specified requirements. Qualified procedures for special processes include required conditions such as proper equipment, controlled parameters, and calibration requirements. Documentation of personnel, 29

ZS-QA-1 0 Revision 1 Information Use equipment, and process qualifications is maintained in accordance with procedures..
4.10 Inspection Quality Assurance, engineering, and technical support personnel are responsible for ensuring that inspections required to verify conformance of an item or activity to specified requirements are planned, executed, and documented by qualified personnel according to approved procedures.
ITDC Inspection requirements are addressed via a graded approach.
Equipment modifications, repairs, and replacement are inspected in accordance with the original design and inspection requirements unless. an approved alternative exists.
4.10.1 Personnel Inspection personnel are independent of those who performed the work being inspected. Personnel who verify conformance of work for acceptance are qualified to perform the inspection in accordance with approved procedures. Personnel in training for qualification as an inspector by on-the-job training are directly supervised by a qualified person who verifies the inspection results until qualification is achieved.
4.10.2 Inspection Hold Points Responsibilities for identifying and specifying hold points are established in approved procedures. Quality Assurance, Engineering, and technical support representatives are responsible for identifying inspection hold points in appropriate documents to ensure that no further work is performed until a certain inspection has been completed. Work does not proceed beyond hold points without consent from the organization that established them. This consent is recorded prior to continuation of work.
4.10.3 Inspection Planning Inspection procedures, instructions, or checklists identify the characteristics and activities to be inspected:
* acceptance criteria;
* responsible organization for performing inspection;
* and, provide for recording objective evidence of inspection results.
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* approval of data by supervisors to ensure that all inspection prerequisites and requirements have been satisfied, including operator and equipment qualifications;
* and, if applicable, establishment of sampling methods based on recognized standard practices, in accordance with approved procedures or project plans.
4.10.4 In-Process Inspection Inspections are performed, as necessary, to verify conformance to requirements. Indirect control by monitoring may be utilized when direct inspection is impractical. Both inspection and monitoring are performed when control is inadequate without both. A combination of inspection and process monitoring is performed in a systematic manner to assure quality is achieved throughout the duration of the process.
4.10.5 Final Inspection Final inspection includes a record review of the results of inspection and resolution of nonconformance's identified in previous inspections. Items are inspected for completeness, markings, calibration, adjustments, and protection from damage. The acceptance of the item will be documented and approved by authorized personnel. Modification, repair, or replacement requires re-inspection or retest to verify acceptability, as appropriate.
4.10.6 In-Service Inspection In-service inspection methods are established to verify that the characteristics of an item continue to stay within the specified limits.
Inspection methods include routine evaluation of emergency and safety systems, and verification of calibration or integrity of instruments or systems and their maintenance, as appropriate.
4.10.7 Inspection Records Inspection records contain, at a minimum, identification of the item inspected, date of inspection, inspector name, type of observation, acceptance and rejection criteria, results or acceptability, and reference to nonconformance's.
4.11 Test Control Testing to verify conformance of processes, equipment, and products to specified requirements and to demonstrate satisfactory performance is planned and 31

ZS-QA-10 Revision 1 Information Use performed by qualified personnel in accordance with approved procedures.
Tests required to collect data are planned, executed, documented, and evaluated.
ITDC Test Control requirements are addressed via a graded approach.
DCS tests will be performed in accordance with written test procedures that incorporate the requirements and acceptance criteria contained in the DCS system Safety Evaluation Report and Certificate of Compliance.
4.11.1 Test Requirements Engineering and technical support representatives are responsible to ensure that test requirements and acceptance criteria are developed and incorporated into appropriate test plans, procedures, or checklists. The test methods and acceptance criteria are based on specified requirements contained in design or other technical documents. As appropriate, test plans are established, procedures developed, and results documented on checklists or other suitable records.
4.11.2 Test Procedures Test procedures include or reference characteristics to be tested and test objectives and prerequisites. Prerequisites such as calibrated instrumentation, equipment and its condition, personnel qualification, environmental conditions, and collection and recording of data are taken into consideration during development of test procedures. Test procedures are reviewed and approved by cognizant technical, quality, and management personnel. Changes to test procedures are required to be reviewed and approved by the same, or equivalent, organization(s) as the original procedure.
4.11.3 Test Results Test results are documented and evaluated by a responsible authority to assure the test requirements were satisfied. Records include as a minimum the item tested, date of test, name of the tester, environmental conditions, observations, acceptance and rejection criteria, results and acceptability, action taken for deviations noted, and name of the person evaluating results.
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ZS-QA-10 Revision 1 Information Use 4.11.4 Testing after Modifications Modification, repairs, or replacements shall be in accordance with the original design and test requirements or acceptable alternatives approved in the same, or equivalent, manner as the original.
4.11.5 Computer Program Testing Testing of computer programs is performed in accordance with written procedures that address test requirements, verification methods, in-use tests, test results, and records requirements. Additional requirements regulating computer program testing are contained in Section 3 of this QAPP.
4.12 Control of Measuring and Test Equipment Measuring and Test Equipment (M&TE) used for important-to-safety and DCS operations activities is controlled in accordance with approved procedures to ensure accuracy. The calibration process assures that all measuring instruments used in the acceptance of material, equipment, and assemblies are calibrated and properly adjusted at specified intervals to maintain accuracy within pre-determined limits. These procedures identify the responsible organizations, the devices to be controlled, the controlling and calibration methods, and calibration intervals to maintain accuracy within the necessary limits.
ITDC Control of Measuring and Test Equipment requirements are addressed via a graded approach.
Management is responsible for selecting the appropriate type, range, accuracy, and tolerance of M&TE to verify conformance to specified requirements.
M&TE is calibrated, adjusted, and maintained at scheduled intervals against certified equipment or standards having known valid relationships to nationally
     .recognized standards, derived from accepted values for natural physical constants or by the ratio type of self-calibration. If no national standard exits, the basis of calibration is documented. The method and interval of calibration for each item is based on the type of device, stability characteristics, required accuracy, purpose, frequency of usage, and environment where it will be used.
Calibration methods are documented and performed by competent personnel in             -
an environment that does not adversely affect the calibration. Special controls for usage, handling, and storage are documented and applied when they are required for environmental conditions such as temperature, humidity, cleanliness, or radiation to maintain accuracy or operating characteristics of the device.
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ZS-QA-10 Revision 1 Information Use When a M&TE device is found out of calibration, previous test results back to the previous acceptable calibration date are validated. Out-of-calibration devices are tagged or segregated until repaired and recalibrated or replaced.
Record of calibration history is maintained and equipment is marked to indicate calibration status. Documentation includes the equipment identification number, next calibration due date, and the inspector's or calibrator's signature or initials attesting to the accuracy and validity of the calibration.
4.13 Handling, Storage and Shipping Materials considered critical, sensitive, perishable, or QA designated are handled, cleaned, stored, packaged, and shipped in accordance with controls identified in codes, standards, regulations, engineering specifications, or project requirements to prevent damage or loss and to minimize deterioration.
4.13.1 Instruction Handling, storage, and shipping processes are conducted in accordance with written procedures, inspection instructions, drawings, specifications, vendor recommendations, or other documents, as appropriate.
Information pertaining to shelf life, environment, packaging, temperature, cleaning, preservation, etc., is included, as required, to meet design, regulatory, and project requirements.
4.13.2 Requirements When necessary for particular products, special protective environments, such as inert gas atmosphere, and specific moisture content and temperature levels, are specified and provided in applicable documents.
The use of special handling equipment or techniques is addressed in procedures. Special tools and equipment are inspected and tested in accordance with approved procedures that describe the inspection and test methods, time intervals, maintenance methods, and personnel qualifications and training requirements.
4.13.3 Marking Suitable marking or labeling to identify, maintain, and preserve the item is provided during packaging, shipment, handling, and storage.
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ZS-QA-10 Revision 1 Information Use 4.13.4 USNRC-Licensed Packages ZionSolutions shall meet the requirements of 10CFR71, Subpart H and 10CFR72, Subpart G and DOT 49 CFR for restrictions concerning handling, storage, and shipping of NRC Licensed packages.
Transportation cask handling and operation shall conform to the handling and operating procedure for each licensed cask.
Prior to the shipment of a transport cask, conditions of the NRC's Certificate of Compliance (specifications, tests, and inspections) shall be satisfied. Required shipping papers shall be prepared and shall accompany the shipment in accordance with regulatory requirements and approved procedures.
Established safety restrictions concerning handling, storage, and shipping shall be included in the handling and operating procedures for storage and transport casks.
4.14 Inspection, Test, and Operating Status Methods to indicate the status of inspections, tests, and operating status of systems for DCS, ISFSI, or spent fuel cask items and other selected tasks also include stamps, tags, or routing cards. Methods used will assure that required inspections and tests are performed and to assure that items which have not passed the required inspections or tests are not inadvertently installed, used or operated and to prevent inadvertent operation of systems. These methods provide for identification of items which have satisfactorily passed the required inspections and tests.
The status of items can be determined at any point throughout an operational process to prevent inadvertent use, installation, or operation of nonconforming or defective items. Status indicators are required to the extent possible to prevent operation of items that are removed from service for test, calibration, maintenance, or repair, and to ensure that required inspections and tests have been performed.
Status is identified by the use of tags, markings, stamps, or travelers. The authority for application and removal of status indicators is identified in approved procedures. Quality Assurance personnel routinely monitor project activities to assure status indicators are used and removed, as appropriate, in accordance with approved procedures.
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ZS-QA-10 Revision 1 Information Use 4.15 Nonconforming Materials, Parts or Components Items that do not conform to specified requirements are controlled to prevent inadvertent installation or use in accordance with approved procedures.
Procedures include controls that provide for reporting, identifying, documenting, evaluating, segregating (when feasible), dispositioning nonconforming items, and notifying affected organizations.
ITDC Control of Nonconforming Conditions requirements are addressed via a graded approach.
Management is responsible for establishing an environment for identifying potential conditions adverse to quality. Management shall conduct analysis, as appropriate, to systematically determine significance of these conditions and actions appropriate to the conditions.
All project personnel are responsible for reporting nonconforming conditions.
Management, at all levels, fosters a "no fault" attitude toward the identification of conditions that are adverse to quality, such as failures, malfunctions, nonconformances, and out-of-control processes including the failure to follow procedures. Nonconforming items are identified by using marking, tagging, or other means that do not adversely affect their end use.
To avoid inadvertent use, nonconforming items are segregated in holding areas when feasible, or in the case of large items, marking, or roping designates special storage areas.
Conditions that may be reportable per 10CFR72.242, 10CFR71.95, or 10CFR21, shall be reported in accordance with approved Quality Assurance procedures.
Management shall establish and implement a process for identifying, controlling, evaluating, and dispositioning nonconforming conditions. Such items, services or activities shall be documented and controlled to prevent inadvertent installation or use. Disposition of nonconformances shall be addressed in a timely manner by management. Personnel performing evaluations to determine a disposition shall have demonstrated competence in the specific area they are evaluating, have an adequate understanding of the requirements, and have access to pertinent background information. The disposition of nonconformances is evaluated and approved by QA. Disposition of a nonconformance, involving repair or use-as-is, is based on documented technical justification to assure continued compliance with design, regulatory, and contractual requirements, and may include provisions for retest or re-inspection to the original acceptance criteria. Any changes to design require the same design controls as those applied to the original design. Accept-as-is dispositions of materials and items 36

ZS-QA-10 Revision 1 Information Use require engineering approval. Accepted deviations are reflected in as-built records.
Reports of nonconforming conditions are closed and documented by QA personnel and records are maintained in accordance with approved procedures.
Reports of conditions that are adverse to quality are analyzed to identify trends in quality performance.
4.16 Corrective Action Conditions adverse to quality (e.g., nonconformances, failures, malfunctions, deficiencies, defective material, etc.) are promptly identified and evaluated to determine corrective action in accordance with established procedures. The identification, cause, and corrective action for significant conditions adverse to quality shall be documented and reported to appropriate levels of management.
ITDC Corrective Action requirements are addressed via a graded approach.
Corrective action shall be promptly initiated when it is determined that a condition adverse to quality exists. In cases where it is not possible to accomplish a corrective action immediately, the appropriate management provides a written response describing the cause of the deficiency and the proposed corrective action to be completed within a specified time.
Management shall exercise controls to ensure that conditions adverse to quality are promptly detected and corrected or prevented, and ensure continuous quality improvement in project activities and products. The management control systems established includes problem investigation, evaluation, reporting, and follow-up action taken to verify that corrective action has been thoroughly implemented and such conditions are effectively resolved.
For significant conditions adverse to quality, the condition, the cause of the condition and the corrective action taken is documented and reported to appropriate levels of management. Follow-up action shall be taken to verify effective implementation of the required corrective actions to prevent recurrence and to verify that they are effectively implemented. The GM, or designee, is responsible for reviewing the condition and determining validity. The GM will assure that validated conditions are processed in accordance with the project's corrective action program.
The QAM has the authority to stop work or ensure adequate controls are in place until effective corrective action has been taken and any applicable changes have been incorporated in procedures and communicated to appropriate personnel.
37

ZS-QA-1 0 Revision 1 Information Use The QAM will periodically analyze and assess CRs for apparent trends and conformance to performance indicators. The GM, or designee, will evaluate recommendations for consideration to improve or enhance procedures, systems or processes.
4.17 Quality Assurance Records ITDC Quality Assurance Records requirements are addressed via a graded approach.
4.17.1 Record Management System Quality Records shall be identified, controlled and stored in accordance with written procedures.
The record system includes the retention of those design, fabrication, inspection, operation, and surveillance records essential to demonstrate product quality. It provides for the identification of materials and their corresponding manufacturing, installation, inspection, test, and audit results. Requirements and responsibilities for the transmittal, distribution, retention, maintenance, and disposition of records are specified in approved procedures. QA records shall be protected against damage, deterioration, unauthorized change, or loss. For any work performed, the records to be generated must be identified, along with a means of matching the record to the item or activity to which it applies. Records must be legible, reproducible, and accurate.
4.17.2 Authentication Documents shall be considered valid records only if stamped, initialed, or signed and dated by authorized personnel or otherwise authenticated, including the use of electronic approval and authorization. This authentication may take the form of a statement by the responsible individual or organization. Handwritten signatures are not required if the document is clearly identified as a statement by the reporting individual or organization. These records may be originals or reproduced copies.
4.17.3 Index The records indexing system must include records identification, location of the record within the system, and minimum retention time. The records and/or indexing system(s) shall provide sufficient information to permit identification between the record and the items or activities to which it applies.
38

ZS-QA-10 Revision 1 Information Use 4.17.4 Distribution The records shall be distributed, handled, and controlled in accordance with written procedures.
4.17.5 Classification of Records Records shall be classified for retention and storage requirements as either lifetime or nonpermanent. Records that meet any of the following criteria are designated Lifetime records and must be maintained until completion of the project and turned over to Exelon if they will be of significant value in the following:
* Demonstrating the capability for safe operation.
* Determining the cause of an accident or the malfunction or failure of an item.
* Maintaining, reworking, repairing, replacing, or modifying an item.
* Providing required baseline data for in-service inspections.
       " Used nuclear fuel records, including original fabrication, repair, and inspection
* ISFISI design and construction records
* DCS system design and fabrication records
* Fuel loading records Project lifetime records shall include, as a minimum, design specifications, stress reports or stress calculations, "as-built" and interface control drawings, copies of material test reports, tabulation of materials for "as-built" configuration, NDE reports including examination reports, and nonconformance reports. Lifetime record retention is based on the life of the program, life of the item, life of the facility, or life of the license, as applicable.
Nonpermanent records are required to show evidence that an activity was performed in accordance with applicable requirements. Retention times must be established in writing.
QA records for packaging and transportation of radioactive materials include instructions, procedures, drawings, and closely related specifications such as required qualifications, procedures, and equipment.
These records will be maintained for three years beyond the date EnergySolutions last engages in the packaging and transportation of 39

ZS-QA-1 0 Revision .1 Information Use radioactive materials related to the Zion site under the rules of 10CFR71.
Superseded procedures or instructions are retained for a minimum of three years after the procedure or instruction is superseded.
For subcontractors/sub-suppliers, the original QA record of the deliverables will be transmitted to ZionSolutions when applicable.
4.17.6 Correction Methods of correcting errors shall be identified along with a means of documenting the authorized individual who made the corrections and the date.
4.17.7 Receipt Control Each organization responsible for the receipt of records must designate an individual or organization responsible for receiving the records. Receipt control of records for permanent or temporary storage must include instructions for designating the required records to be controlled, identifying the records received, receiving and inspecting incoming records, determining the status, and forwarding to records storage facilities. Each receipt control system shall be structured to permit a current and accurate assessment of the status of records during the receiving process.
4.17.8 Storage Requirements The records shall be stored in predetermined location(s) that meet the requirements of applicable standards, codes, and regulatory agencies.
Prior to storage of records, a written storage procedure shall be prepared and responsibility assigned for enforcing the requirements of that procedure. This procedure shall include, as a minimum:
* A description of the storage facility;
* The filing system to be used;
* A method for verifying that the records received agree with the transmittal document and that the records are legible;
* A method of verifying that the records are those designated;
* The rules governing -access to and control of the files;
* A method for controlling and accounting for records removed from the storage facility; and 40

ZS-QA-1 0 Revision 1 Information Use
* A method for filing supplemental information and disposing of superseded records.
Records shall be stored to prevent damage from moisture or temperature.
All records maintained in hard copy form shall be firmly attached to binders or placed in folders, envelopes, or boxes for storage in file cabinets or within containers on shelving. Records may be stored in electronic media provided that the process for managing and storing the records are documented in approved procedures. Media used for the retention of records include, but are not limited to, microfilm, compact disks, magnetic media, optical disks, and hard disks. The format used must be capable of producing legible and complete documents during the entire retention period.
Records shall be stored in facilities that minimize the risk of damage or destruction from the following:
* Natural disasters such as wind, flood, or fires;
       " Environmental conditions such as high and low temperatures and humidity; and
       " Infestation by insects, mold, or rodents.
Records are maintained at an approved records storage facility or by storage of duplicate copies at separate geographical locations.
4.17.9 Authorized Personnel Measures shall be established to preclude the entry of unauthorized personnel into the storage area. These measures shall guard against larceny and vandalism. Measures shall be taken to provide for replacement, restoration, or substitution of lost or damaged records.
4.17.10 Retrieval Storage systems shall provide for retrieval of information in accordance with planned retrieval times based upon the record type. A list shall be maintained designating those personnel who shall have access to the files. Records maintained by the supplier at their facility or other location shall be accessible to the purchaser or their designated alternate.
4.17.11 Disposition Records accumulated at Zion site shall be made accessible to EnergySolutions directly or through the procuring organization. These records shall be processed in accordance with this QAPP.
41

ZS-QA-10 Revision 1 Information Use Various regulatory agencies have requirements concerning records that are within the scope of the QAPP. The most stringent requirements shall be used in determining the final disposition.
4.18 Audits Planned internal audits are scheduled annually and performed per approved procedures or checklists. Elements of the QAPP will be audited at least annually to provide comprehensive, independent verification and evaluation of all aspects of the quality assurance program and to determine its effectiveness.
Independent oversight of project activities will be accomplished by performing audits, surveillances, management assessments and/or independent assessments during the course of the Project. Scheduling, preparation, personnel selection, performance, reporting, response, follow-up action, and records management will be performed in accordance With Quality Procedures identified in the QA Program Implementation Matrix.
ITDC Audit requirements are addressed via a graded approach.
QA staff will perform project surveillances and overviews of deliverables to ensure compliance with the applicable QA requirements defined in this QAPP and as requested by the project team.
Audits of suppliers and subcontractors will be conducted as necessary but not less than once every three years to assess compliance with applicable requirements of this QAPP.
4.18.1 Scheduling, Preparation, and Performance Internal and external audits are scheduled based on the status and importance of an activity. Schedules are updated as necessary to ensure that adequate coverage is maintained.
The audit scope shall encompass evaluation of quality system practices and/or procedures and the effectiveness of their implementation, monitoring of operations and activities, and a review of pertinent documents and their control and maintenance.
An audit team, composed of one or more qualified auditors is identified for each audit using personnel who have no direct responsibility for the activity being covered. A lead auditor, as a member of the team, is designated as a team leader.
The key elements of the audit program are:
42

ZS-QA-10 Revision 1 Information Use
* Scheduling and notifying management of scope and nature of audit
* Team selection, orientation, and planning
* Entrance conference
* Exit conference
* Reporting and response
* Follow-up action 4.18.2 Reporting, Response, Follow-up-Action, and Records Audit reports are prepared upon completion of the audit and distributed to appropriate management for review and response. Management of the audited organizations provide a response to all identified conditions adverse to quality that includes corrective actions, including cause and action to prevent recurrence, and a schedule for completion, when applicable. Audit files are retained as quality records in accordance with approved procedures.
The results of internal audits, surveillances and assessments and independent assessments and audits of Subcontractors will be utilized as input into the continuous improvement program through identification in the CR system. Re-audit of deficient areas will be performed when required.
4.18.3 Surveillance Surveillances are performed and documented when it is determined that it is necessary to monitor or observe an item or activity to verify conformance. Adequate demonstration of the areas covered by surveillance is a requirement to be considered as part of an effective audit program. Surveillance must be documented in sufficient detail to identify the activity covered, identify individuals doing surveillance, and to document results and any corrective measures necessary.
43

ZS-QA-10 Revision 1 Information Use 5.0     QUALITY MONITORING Quality Assurance will utilize performance data from the project's CR system, Subcontractor corrective action systems, QA audit, surveillance, and assessment results to monitor the quality of project tasks and deliverables. This data will be used in determining areas requiring increased or decreased review by the established overview mechanisms. Data reviews will be performed on a periodic basis, but may be generated more frequently as necessary.
The QAM, using data from the project's CR system, also will perform trending of ZionSolutions quality activities. Trends identified will be reviewed by the QAM and appropriate actions will be developed to improve work activities and/or processes.
Trending may result in Apparent Cause Evaluation (ACE) and/or Root Cause Analyses (RCA) as necessary.
6.0     ZIONSOLUTIONS QUALITY COUNCIL ZionSolutions will collaborate with its subcontractors and establish a committee to coordinate the quality overview of design, engineering, fabrication, installation and operation activities of the project including the implementation of the QAPP. The ZionSolutions Quality Council consists of key QA members of ZionSolutions, EnergySolutions, DFSS Designer, Design Authorities, and other supplier/subcontractor organizations. The Quality Council provides a united effort to.coordinate, monitor, and effectively implement the project's oversight activities.
The Council will establish, review and evaluate quality performance indicators, discuss quality issues/concerns and assure effective corrective actions are implemented in a timely fashion. The Council will assure that design, fabrication, installation and operations activities are thoroughly and effectively overviewed and minimize duplication of oversight efforts.
It should be noted that the QAM has the primary responsibility for implementing this QAPP, and, in part, based upon supplier/subcontractor inputs will introduce and discuss ZionSolutions quality issues and topics to the committee.
44

ZS-QA-10 Revision 1 Information Use

==7.0     REFERENCES==

ANSI/ASME NQA-1 -1994 Edition, "Quality Assurance Requirements for Nuclear Facility Applications."
Title 10 of the Code of Federal Regulations, Part 21, "Reporting of Defects and Noncompliance."
Title 10 of the Code of Federal Regulations, Part 50 Appendix B, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants."
Title 10 of the Code of Federal Regulations, Part 71, Subpart H, "Quality Assurance Requirements for Packaging and Transportation of Radioactive Waste."
Title 10 of the Code of Federal Regulations, Part 72, Subpart G, "Quality Assurance Requirements for the Independent Storage of Spent Nuclear Fuel, High Level Radioactive Waste, and Reactor-Related Greater Than Class C Waste."
NUREG/CR-6407 [INEL-95/0551], Classification of Transportation Packaging and Dry Spent Fuel Storage System Components According to Importance to Safety, February 1996.
NUREG-1 536, "Standard Review Plan for Dry Cask Storage Systems," January 1997.
NUREG-1 567, "Standard Review Plan for Spent Fuel Storage Facilities," Draft Report, October 1996.
NUREG-1617, "Standard Review Plan for Transportation Packages for Spent Nuclear Fuel," Draft Report, March 1998.
RegulatoryGuide 7.10, "Establishing Quality Assurance Programs for Packaging Used in the Transport of Radioactive Material," Revision 1, June 1986.
EnergyS6lutions Quality Assurance Program, Rev. 0, effective May 31, 2007.
Exelon Quality Assurance Topical Report, Rev 81, implemented June 16, 2008.
45

ZS-QA-10 Revision 1 Information Use Figure 1 ZionSolutions LLC Restoration and Dry Cask Storage Project Organization Chart
    - -CorporateDirector tEnergySolutions I    Quality Assurance 46

ZS-QA-1 0 Revision 1 Information Use Appendix A List of Acronyms ACE   _  Apparent Cause Evaluation ASME     American Society of Mechanical Engineers ANSI     American National Standards Institute DCS      Dry Cask Storage DFSS     Dry Fuel Storage System ISFSI    Independent Spent Fuel Storage Installation ITDC    Important to the Defueled Condition ITS      Important To Safety NUREG    Nuclear Regulatory Guide PTSP     Project Technical Support Personnel QA       Quality Assurance QAPP     Quality Assurance Project Plan RCA      Root Cause Analysis SAFSTOR  Safe Storage SSC      Structures, Systems, and Components USNRC   United States Nuclear Regulatory Commission 46

Enclosure 2 Quality Assurance Project Plan (QAPP) Commitments to NQA-1 The ZionSolutions QAPP contains explicit commitments to applicable quality assurance requirements of ASME NQA-1-1994 Part I. The acceptability of the use of NQA-1-1994, Part I, is based on the NRC's Safety Evaluation for consolidation of the Exelon Quality Assurance Program, which is contained in the letter from Mahesh Chawla (NRC) to John L.
Skolds (Exelon Generation Company), "Approval of Proposed Revision 70 of Quality Assurance Topical Report EGC-1A, Rev. 70, in Accordance with 10 CFR 50.54(a)
Requirements for Exelon/Amergen Plants," dated December 24, 2002. This Safety Evaluation indicates the NRC has "examined the side-by-side comparison of NQA-1-1983 and NQA-1-1994 equivalence, and concurs with the licensee's conclusions in finding NQA-1-1994, as implemented through the common QATR, to provide an acceptable basis for the licensee's operational QA program." The 1983 version of NQA-1 had been previously endorsed by NRC through Regulatory Guide 1.28, Revision 3, August 1985. In the QAPP ZionSolutions commits to implementation of Part I of the 1994 edition of NQA-1. A QAPP Compliance Matrix (Enclosure 3) demonstrates that the ZionSolutions QAPP fully meets the applicable requirements of NQA-1-1994 Part 1,10 CFR50 Appendix B, 10 CF71 Subpart H, and 10 CFR72 Subpart G.
In addition, it is ZionSolutions' intent to utilize certain portions of NQA-1-1994, Part II in its QAPP. Six Subparts in NQA-1 Part IIrepresent incorporation of requirements from ANSI Standards. These are Subpart 2.1 (ANSI N45.2.1), Subpart 2.2 (N45.2.2), Subpart 2.3 (N45.2.3), Subpart 2.5 (N45.2.4), Subpart 2.5 (N45.2.5) and Subpart 2.8 (N45.2.8).
ZionSolutions has performed a comparison of each of these ANSI Standards with the appropriate sections of Part II of NQA-1-1994 and finds that the requirements are essentially equivalent, and often identical. Therefore, ZionSolutions has included applicable portions of the appropriate sections of NQA-1-1994, Part II in the QAPP, in lieu of the associated ANSI Standards. In order to facilitate NRC review, ZionSolutions has enclosed with this letter, a matrix for each ANSI Standard (Enclosure 4) providing a comparison of the ANSI Standard with the appropriate NQA-1-1994, Part IIsection. Requirements for activities applicable to Zion which are similar to those addressed by Subparts 2.15 and 2.16, as applicable, are defined in the QAPP. Activities addressed by Subparts 2.18 and 2.20 do not apply to expected activities at Zion and are not addressed in the QAPP. In cases where supplemental requirements are determined to be needed to facilitate site activities, useful provisions of the NQA-1 Subparts or other industry guidelines or standards will be incorporated into applicable procedures or instructions.

Enclosure 3 ZionSolutions Quality Assurance Project Plan (ZS-QA-10)
QAPP Compliance Matrix II I= L..IUI I F%= LUI "ILIUII l[ Ull ..,,O  I I11 dULIIUIILy dIIU UULIt5 UI     I IIt UlIga l IOIIdI 101ULIUILUI *,                                   1,0) I It Ilu O 000, 0j   -  L -S lII~  .
Project organization, authority,             persons and organizations           functional responsibilities, levels  holder, and applicant for a CoC   license, certificate holder, and duties, responsibilities, and                performing activities affecting the of authority, and lines of           shall be responsible for the      applicant for a CoC shall be interface requirements are                   safety-related functions of         communication for activities         establishment and execution of    responsible for the establishment addressed in QAPP Section 2.0,               structures, systems and             affecting quality shall be           the quality assurance program. and execution of the quality Quality Responsibilities. These              components shall be clearly         documented.                          The licensee, certificate holder, assurance program. The licensee activities include performing                established and delineated in                                            and applicant for a CoC may       and certificate holder may activities affecting the functions           writing. These activities include                                        delegate to others, such as       delegate to others, such as of structures, systems, and                  both the performing functions of                                         contractors, agents, or           contractors, agents, or components which are important               attaining quality objectives and                                         consultants, the work of          consultants, the work of to safety, those associated with             the quality assurance functions.                                         establishing and executing the    establishing and executing the attaining quality objectives, and                                                                                     quality assurance program, or     quality assurance program, but the QA functions. The primary                                                                                         any part of the quality assurance the licensee and the certificate Zion Restoration and DCS                                                                                              program, but shall retain         holder shall retain responsibility Project organizations are                                                                                             responsibility for the program. for the program. The licensee, ZionSolutions, EnergySolutions,                                                                                       These activities include          applicant for a license, certificate DFSS Designer, DFSS Prime                                                                                             performing the functions          holder, and applicant for a CoC Fabricator(s), and Design                                                                                             associated with attaining quality shall clearly establish and Authorities.                                                                                                          objectives and the quality        delineate in writing the authority assurance functions.              and duties of persons and organizations performing activities affecting the functions of structures, systems, and components which are important to safety. These activities include performing the functions associated with attaining quality objectives and the quality assurance functions.
1 of 32

Enclosure 3 ZionSolutions Quality Assurance Project Plan (ZS-QA-10)
QAPP Compliance Matrix ZinSoltiions QA*P,                 ICFRS6OApp'endix B                         }IQA-i.1 994       -                IOCFR71                         10 CFR72 Quality Assurance staff shall       The persons and organizations       Persons or organizations           (c) The persons and              (2) The persons and have sufficient independence        performing quality assurance        responsible for assuring than an   organizations performing quality organizations performing quality from cost and schedule              functions shall have sufficient     appropriate QA program is          assurance functions must have    assurance functions shall have considerations and shall have the   authority and organizational        established and verifying that     sufficientorganizational freedom sufficient authority and access to work areas and            freedom to identify quality         activities affecting quality have  to identify quality problems; to organizational freedom to identify organizational freedom to           problems; to initiate, recommend,   been correctly performed shall     initiate, recommend, or provide  quality problems; to initiate, effectively identify quality        or provide solutions; and to verify have sufficient authority, access  solutions; and to verify         recommend, or provide solutions; problems, initiate, recommend or    implementation of solutions,        to work areas, and organizational  implementation of solutions. and to verify implementation of provide solution to quality                                             freedom to:                                                         solutions.
problems through designated channels, verify implementation
* Identify quality problems; of solutions; and assure that
* Initiate, recommend or further processing, delivery,                                                provide solution to quality installation, and use are                                                    problems through controlled until proper disposition                                          designated channels; of a nonconformance, deficiency,
* Verify implementation of or unsatisfactory condition has                                              solutions; and occurred. The QAM has the
* Assurance that further authority to stop work when                                                  processing, delivery, significant conditions adverse to                                            installation, or use is quality warrant such action.                                                 controlled until proper disposition of a nonconformance, deficiency, or unsatisfactory condition has occurred.
Quality Assurance staff shall       Such persons and organizations      Such persons or organizations      (d) The persons and              (c) The persons and have sufficient independence        performing quality assurance        shall have direct access to        organizations performing quality organizations performing quality from cost and schedule              functions shall report to a         responsible management at a        assurance functions shall report assurance functions shall report considerations and shall have the   management level such that this     level where appropriate action     to a management level which      to a management level that access to work areas and            required authority and              can be effected (and) shall report assures that the required        ensures that the required organizational freedom to           organizational freedom, including   to a management level such that    authority and organizational     authority and organizational effectively identify quality        sufficient independence from cost   required authority and             freedom, including sufficient    freedom, including sufficient problems, initiate, recommend or    and schedule when opposed to        organizational freedom are         independence from cost and       independence from cost and provide solution to quality         safety considerations, are          provided, including sufficient     schedule when opposed to safety  schedule considerations when problems through designated         provided,                           independence from cost and         considerations, are provided,    these conditions are opposed to channels, verify implementation                                         schedule considerations.                                            safety considerations, are of solutions; and assure that                                                                                                               provided.
further processing, delivery, installation, and use are 2 of 32

Enclosure 3 ZionSolutions Quality Assurance Project Plan (ZS-QA-1O)
QAPP Compliance Matrix Zion:SolfonsQAP                     B               NAIA-1 9C94                        *FR71                            10 CFR72 controlled until proper disposition of a nonconformance, deficiency, or unsatisfactory condition has occurred. The QAM has the authority to stop work when significant conditions adverse to quality warrant such action.
Quality Assurance staff shall                                                (e) Because of the many             (c) Because of the many have sufficient independence                                                 variables involved, such as the     variables involved, such as the from cost and schedule                                                       number of personnel, the type of    number of personnel, the type of considerations and shall have the                                            activity being performed, and the   activity being performed, and the access to work areas and                                                     location or locations where         location or locations where organizational freedom to                                                    activities are performed, the       activities are performed, the effectively identify quality                                                 organizational structure for        organizational structure for problems, initiate, recommend or                                             executing the quality assurance     executing the quality assurance provide solution to quality                                                  program may take various forms      program may take various forms problems through designated                                                   provided that the persons and      provided that the persons and channels, verify implementation                                              organizations assigned the          organizations assigned the of solutions; and assure that                                                quality assurance functions have    quality assurance functions have further processing, delivery,                                                the required authority and          the required authority and installation, and use are                                                     organizational freedom.            organizational freedom.
controlled until proper disposition of a nonconformance, deficiency, or unsatisfactory condition has occurred.
Quality Assurance staff shall                                                 (f)Irrespective of the             *(c) Irrespective of the have sufficient independence                                                 organizational structure, the       organizational structure, the from cost and schedule                                                        individual(s) assigned the         individual(s) assigned the considerations and shall have the                                             responsibility for assuring        responsibility for assuring access to work areas and                                                      effective execution of any portion effective execution of any portion organizational freedom to                                                     of the quality assurance program   of the quality assurance program, effectively identify quality                                                  at any location where activities   at any location where activities problems, initiate, recommend or                                              subject to this section are being  subject to this section are being provide solution to quality                                                   performed must have direct         performed, must have direct problems through designated                                                  access to the levels of             access to the levels of channels, verify implementation                                               management necessary to            management necessary to of solutions; and assure that                                                 perform this function.             perform this function.
further processing, delivery, 3 of 32

Enclosure 3 ZionSolutions Quality QAPP Assurance          Project Plan (ZS-QA-10)
Compliance Matrix
      ~ZionSolutions QAPP ?->       K     'I1CFRSO Appendix B                     NQA-1 -994<                         . 10CFR71>                          10 CFR72 installation, and use are controlled until proper disposition of a nonconformance, deficiency, or unsatisfactory condition has occurred.
SECTION4.2                         'CRITERIA 1I!  "      /"BASIC      REQUIREMENT 2           71.105 QUALITY ASSURA NE            72.144 QUALITY ASSURANGE Q ualityAssuranceProgra          Qualit Assurance iPrograrn                      PROGRAM                           PROGRAM Procedures describe how             The program shall be              A documented quality assurance      (a) The licensee shall document     (a) The licensee, applicant for a ZionSolutions implements the        documented by written policies,   program shall be planned,           the quality assurance program by    license, certificate holder, and requirements of the QAPP.           procedures, or instructions and   implemented, and maintained in      written procedures or instructions  applicant for a CoC shall These procedures document           shall be carried out throughout   accordance with this Part (Part I), and shall carry out the program in  document the quality assurance methods for planning, reviewing,    plant life in accordance with     or portions thereof.                accordance with those               program by written procedures or implementing, controlling, and      policies, procedures, or                                              procedures throughout the period    instructions and shall carry out verifying activities affecting      instructions.                                                         during which packaging is used. the program in accordance with quality.                                                                                                                                      those procedures throughout the period during which the ISFSI or MRS is licensed or the spent fuel storage cask is certified.
The QAPP shall apply to all         The applicant shall identify the  The program shall identify the      (a) The licensee shall identify the (a) The licensee, applicant for a activities that are                 structures, systems, and          activities and items to which it    material and components to be       license, certificate holder, and important-to-safety or DCS          components to be covered by the   applies,                            covered by the quality assurance    applicant for a CoC shall identify operations and require              quality assurance program and                                         program, the major organizations    the structures, systems, and compliance with applicable          the major organizations                                               participating in the program, and   components to be covered by the sections of the documents listed    participating in the program,                                         the designated functions of these   quality assurance program, the below:                              together with the designated                                          organizations.                      major organizations participating functions of these organizations.                                                                         in the program, and the
" 10CFR50, App. B                                                                                                                             designated functions of these
" 10CFR71, Subpart H                                                                                                                          organizations.
" 10CFR72, Subpart G
" ANSI/ASME NQA-1-1994 The applicability of the QAPP takes into consideration the regulatory requirements for important-to-safety and DCS operations items and activities, 4 of 32

Enclosure 3 ZionSolutions Quality Assurance Project Plan (ZS-QA-10)
QAPP Compliance Matrix Zion'S6I**tion@CQAPP        IIOCFRS0 A pndix B                NQA-1*9194                             1.OCFR71                          10 CFR72 as well as their complexity and impact on safety, the need for special controls, demonstration of compliance through inspection and test, and the degree of standardization of the item. The requirements of the QAPP are implemented using a graded approach allowing control over items and activities to be commensurate with their importance and level of risk and are not reductions in quality requirements. Measures are.
established for identifying the components, systems, and structures to be covered by the QAPP. During the planning of an activity or design of an item the QAPP requirements will be implemented through procedures.
The establishment of the            (c) The licensee shall base the   (c) The licensee, applicant for a program shall include               requirements and procedures of    license, certificate holder, and consideration of the technical      its quality assurance program on  applicant for a CoC shall base aspects of the activities affecting the following consideration       the requirements and procedures quality,                            concerning the complexity and     of their quality assurance proposed use of the package and   program(s) on the following its components:                   considerations concerning the complexity and proposed use of (1) The impact of malfunction     the structures, systems, or or failure of the item to   components:
safety; (2) The design and fabrication    (1) The impact of malfunction complexity or uniqueness of       or failure of the item to the item;                         safety; (3) The need for special          (2) The design and
                                                                                                   *controls and surveillance         fabrication complexity or over processes and                uniqueness of the item; 5 of 32

Enclosure 3 ZionSolutions Quality Assurance Project Plan (ZS-QA-1 0)
QAPP Compliance Matrix ZionSo.utins QAPP                  IOC FR50A P*...i...                                                               1OFR71                                   CFR.2
                                                                                                                                                                  .The.
equipment;                     (3)   The need for special (4) The degree to which                     controls and surveillance functional compliance can            over processes and be demonstrated by                   equipment; inspection or test; and        (4)   The degree to which (5) The quality history and                 functional compliance can degree of standardization of          be demonstrated by the item.                             inspection or test; and (5)   The quality history and degree of standardization of the item.
The requirements of the QAPP      The quality assurance programs        The program shall provide control    (b) The licensee, through its         (b) The licensee, applicant for a are implemented using a graded    shall provide control over            over activities affecting quality to quality assurance program, shall      license, certificate holder, and approach allowing control over    activities affecting the quality of   an extent consistent with their      provide control over activities       applicant for a CoC, through their items and activities to be        the identified structures, systems,   importance.                          affecting the quality of the          quality assurance program(s),
commensurate with their           and components, to an extent                                               identified materials and              shall provide control over importance and level of risk and  consistent with their importance                                           components to an extent               activities affecting the quality of are not reductions in quality     to safety.                                                                 consistent with their importance      the identified structures, systems, requirements.                                                                                                to safety, and as necessary to        and components to an extent assure compliance to the              commensurate With the approved design of each               importance to safety, and as individual package used for the       necessary, to ensure shipment of radioactive material,     conformance with the approved design of each ISFSI, MRS, or spent fuel storage cask.
The applicant shall establish at      The program shall be established     (a) The licensee shall establish,     (a) The licensee, applicant for a the earliest practicable time,        at the earliest time consistent      at the earliest practicable time      license, certificate holder, and consistent with the schedule for      with the schedule for                consistent with the schedule for      applicant for a CoC shall accomplishing the activities, a       accomplishing the activities,        accomplishing the activities, a       establish, at the earliest quality assurance program which                                            quality assurance program which       practicable time consistent with complies with the requirements of                                          complies with the requirements of     the schedule for accomplishing this Appendix.                                                             71.101 through 71.137.                the activities, a quality assurance program which complies with the requirements of this subpart.
The management team provides      Activities affecting quality shall be The program shall provide for the    (b) The licensee's shall assure       (b) The licensee, applicant for a systematic planning to establish, accomplished under suitably           planning and accomplishment of       that activities affecting quality are license, certificate holder, and the scope of work, analyze        controlled conditions.                activities affecting quality under   accomplished under suitably           applicant for a CoC shall ensure 6 of 32

Enclosure 3 ZionSolutions Quality Assurance Project Plan (ZS-QA-1O)
QAPP Compliance Matrix ZionSpolutioms QAPP,                IOCRSO Apg0ndix B
* NQA-1-1.94.               .        1...R71. .                            10 CFR7 2   '
* hazards, and confirm the                                                    suitably controlled conditions. controlled conditions.               that activities affecting quality are appropriateness of methods to be.                                                                                                                   accomplished under suitably used and controls to be applied.                                                                                                                    controlled conditions.
The management team provides         Controlled conditions include the      Controlled conditions include the  (b) Controlled conditions include    (b) Controlled conditions include systematic planning to establish     use of appropriate equipment;          use of appropriate equipment,      the use of appropriate               the use of appropriate the scope of work, analyze           suitable environmental conditions      suitable environmental conditions  equipment; suitable                  equipment; suitable hazards, and confirm the             for accomplishing the activity,        for accomplishing the activity,    environmental conditions for.        environmental conditions for appropriateness of methods to be     such as adequate cleanliness;          and assurance that prerequisites   accomplishing the activity, such     accomplishing the activity, such used and controls to be applied,     and assurance that all                 for the given activity have been   as adequate cleanliness; and         as adequate cleanliness; and prerequisites for the given activity   satisfied.                         assurance that all prerequisites     assurance that all prerequisites All activities affecting quality are have been satisfied.                                                      for the given activity have been     for the given activity have been accomplished under suitably                                                                                    satisfied,                           satisfied.
controlled conditions. Controlled conditions include the use of appropriate equipment, suitable environmental conditions for accomplishing the activity, and assurance that prerequisites for the given activity have been satisfied. Management provides for any special control, processes, test equipment, tools, and skills to attain the required quality and for verification of.
quality.
The management team provides         The program shall take into            The program shall provide for      (b) The licensee shall take into     (b) The licensee shall take into systematic planning to establish     account the need for special           any special control, processes,    account the need for special         account the need for special the scope of work, analyze           controls, processes, test              test equipment, tools, and skills  controls, processes, test            controls, processes, test hazards, and confirm the             equipment, tools and skills to         to attain the required quality and equipment, tools and skills to       equipment, tools and skills, to appropriateness of methods to be     attain the required quality, and       for verification of quality,       attain the required quality, and     attain the required quality, and used and controls to be applied. the need for verification of quality                                      the need for verification of quality the need for verification of quality by inspection and test.                                                   by inspection and test.              by inspection and test.
All activities affecting quality are accomplished under suitably controlled conditions. Controlled conditions include the use of appropriate equipment, suitable environmentalconditions for 7 of 32

Enclosure 3 ZionSolutions Quality Assurance Project Plan (ZS-QA-10)
QAPP Compliance Matrix ZZ16W$O"uio"       AI'PP         <1QOCIFRSO APO,7rdlx B     'NQA-~1-94                                ~1             0CFIR71                           10 CFR7,2           C accomplishing the activity, and assurance that prerequisites for the given activity have been satisfied. Management provides for any special control, processes, test equipment, tools, and skills to attain the required quality and for verification of quality.
Section 4.1:                                                                                                 71.103 (c) The persons and          72.142 (2) The persons and Quality Assurance staff shall                                                                                organizations performing quality    organizations performing quality have sufficient independence                                                                                 assurance functions must have       assurance functions shall have from cost and schedule                                                                                       sufficient organizational freedom   sufficient authority and considerations and shall have the                                                                            to identify quality problems; to    organizational freedom to identify access to work areas and                                                                                     initiate, recommend, or provide     quality problems; to initiate, organizational freedom to                                                                                    solutions; and to verify            recommend, or provide solutions; effectively identify quality                                                                                 implementation of solutions.        and to verify implementation of problems, initiate, recommend or                                                                                                                 solutions.
provide solutionto quality problems through designated channels, verify implementation of solutions; and assure that further processing, delivery, installation, and use are controlled until proper disposition of a nonconformance, deficiency, or unsatisfactory condition has occurred.
Indoctrination and training are     The program shall provide for            The program shall provide for   (d) The licensee shall provide for  (d) The licensee, applicant for a conducted as necessary to           indoctrination and training of           indoctrination and training, as indoctrination and training of      license, certificate holder, and assure suitable proficiency is      personnel performing activities          necessary, of personnel         personnel performing activities     applicant for a CoC shall provide achieved and maintained,            affecting quality as necessary to        performing activities affecting affecting quality as necessary to   for indoctrination and training of Project personnel shall be trained  assure that suitable proficiency is      quality to assure that suitable assure that suitable proficiency is personnel performing activities in the applicable procedures and    achieved and maintained,                 proficiency is achieved and     achieved and maintained,            affecting quality as necessary to project-specific documents.                                                  maintained.                                                         ensure that suitable proficiency is achieved and maintained.
8 of 32

Enclosure 3 ZionSolutions Quality Assurance Project Plan (ZS-QA-10)
QAPP Compliance Matrix ZlouiS~qoutions QAPP       4     7iCFR5,OAppendlxSB              I       -     NQA-119,94                          10CFR71                            10CFR72 10           __
Managers are required to assess     The applicant shall review the        Management of those               (d) The licensee shall review the   (e) The licensee, applicant for a the effectiveness of their own      status and adequacy of the            organizations implementing the    status and adequacy of the          license, certificate holder, and operations and implementation of    quality assurance program.            quality assurance program, or     quality assurance program at        applicant for a CoC shall review their portion of the QAPP. QA       Management of other                   portions thereof, shall regularly established intervals.              the status and adequacy of the personnel perform independent       organizations participating in the    assess the adequacy of that part  Management of other,                quality assurance program at audits, surveillances, and          quality assurance program shall       of the program for which they are organizations participating in the  established intervals.
inspections to verify the           regularly review the status and       responsible and shall assure its  quality assurance program shall     Management of other effectiveness of the QAPP.           adequacy of that part of the          effective implementation.         regularly review the status and     organizations participating in the quality assurance program which                                         adequacy of that part of the        quality assurance program shall they are executing.                                                     quality assurance program which     regularly review the status and they are executing.                 adequacy of that part of the quality assurance program which they are executing.
uLJbIgrI %,orIuoI proceuures                                               i ne oesign snan ce oen          (a) i ne ucensee snai esiao*isn     (a) i ne ,icensee, appucant Tor a ensure that the design meets         assure that applicable regulatory     controlled, and verified.         measures to assure that             license, certificate holder, and applicable regulatory                requirements and the design                                             applicable regulatory -             applicant for a CoC shall requirements, and that design       basis, as defined in 10CFR 50.2                                         requirements and the package        establish measures to ensure activities are carried out in a     and as specified in the license                                         design, as specified in the license that applicable regulatory planned and controlled manner.      application, for those structures,                                      for those materials and             requirements and the design Procedures describe                 systems, and components to                                              components to which this section    basis, as specified in the license responsibilities for design         which this Appendix applies, are                                        applies, are correctly translated   or CoC application for those interface, control, verification,   correctly translated into                                               into specifications, drawings,      structures, systems, and and change. Approved                specifications, drawings,                                               procedures, and instructions.       components to which this section procedures govern translation of    procedures, and instructions.                                                                               applies, are correctly translated applicable project and regulatory                                                                            (b) The licensee shall apply any    into specifications, drawings, requirements and design bases       Design control measures shall be                                        design control measures to items    procedures, and instructions.
into design, procurement, and        applied to items such as the                                            such as the following:
procedural documents, as well as     following: reactor physics, stress,                                     1) Criticality physics, radiation   (a) The licensee, applicant for a controlling the design documents     thermal, hydraulic, and accident                                              shielding, stress, thermal,   license, certificate holder, and and design document                  analyses; compatibility of                                                    hydraulic, and accident       applicant for a CoC shall apply distribution.                        materials; accessibility for                                                  analyses;                     design control measures to items inservice inspection,                                                   2) Compatibility of materials;      such as the following: criticality Design' controls shall be applied    maintenance and repair, the                                             3) Accessibility for inservice      physics, radiation shielding, to: criticality physics, radiation   delineation of acceptance criteria                                            inspection, maintenance and   stress, thermal, hydraulic, and shielding, stress, thermal,          for inspections and tests.                                                    repair,                       accident analyses; compatibility hydraulic, accident analysis,                                                                               4) Features to facilitate           of materials; accessibility for compatibility of materials,                                                                                        decontamination: and          inservice inspection, 9 of 32

Enclosure 3 ZionSolutions Quality Assurance Project Plan (ZS-QA-10)
QAPP Compliance Matrix Z!onS1utlons QAPP                 .lO0F,,RS,0Appendix        B                        !QA-1-1 94                          1 CFR71                            1O-1KOCFIR72 accessibility for in-service                                                                                  5)    Delineation of acceptance     maintenance and repair, features inspection, maintenance and                                                                                         criteria for inspections and  to facilitate decontamination; and repair, features to facilitate                                                                                     tests.                         delineation of acceptance criteria decontamination, and delineation                                                                                                                  for inspections and tests.
of acceptance criteria for inspections and tests.
The input used in each design is      These measures shall include          Applicable design inputs shall be (a) These measures must include     (a) These measures must include documented, reviewed, and             provisions to assure that             appropriately specified on a      provisions to assure that           provisions to ensure that approved in a timely manner by        appropriate quality standards are     timely basis and correctly        appropriate quality standards are   appropriate quality standards are the responsible design                specified and included in design      translated into design            specified and included in design    specified and included in design organization. Documented              documents and that deviations         documents.                        documents and that deviations       documents and that deviations design inputs provide the             from standards are controlled,                                          from standards are controlled,      from standards are controlled.
necessary level of detail to          Measures shall also-be                                                  Measures must be established        Measures must be established ensure the design activity can be     established for the selection and                                       for the selection and review for    for the selection and review for carried out correctly and provides    review for suitability of application                                   suitability of application of       suitability of application of a consistent basis for making         of materials, parts, equipment,                                         materials, parts, equipment, and    materials, parts, equipment, and decisions, accomplishing design       and processes that are essential                                        processes that are essential to     processes that are essential to verification, and for evaluating      to the safety-related functions of                                      the safety-related functions of the the functions of the structures, changes. Changes from                 the structures, systems, and                                            materials, parts, and components    systems, and components which approved design inputs, including     components.                                                             of the packaging that are           are important to safety.
the reason for the changes, are                                                                               important to safety.
documented; approved, and controlled.
Design inputs including appropriate quality standards shall be specified in a timely basis and translated into applicable design documents.
Deviations from the quality standards shall be controlled.
Design measures shall include review for suitability of application for materials, parts, equipment and processes that are important to safety.
10 of 32

Enclosure 3 ZionSolutions Quality Assurance Project Plan (ZS-QA-1O)
QAPP Compliance Matrix Zlon$,olutlonsQAPP                  10CFRSO Appendix a             ~         NQA-1 -199~4                    10CFR71 1;                                 10 .F~R72 Formal design interfaces are        Measures shall be established for  Design interfaces shall be     (b) The licensee, certificate      (b) The licensee, applicant for a established when multiple           the identification and control of  verified and controlled.       holder, and applicant for a CoC    license, certificate holder, and organizations (internal or          design interfaces and for                                         shall establish measures for the   applicant for a CoC shall external) participate inthe design  coordination among participating                                  identification and control of      establish measures for the process. Procedures are written     design organizations.                                             design interfaces and for          identification and control of that establish and document                                                                           coordination among participating   design interfaces and for responsibility and authority for                                                                      design organizations. These        coordination among participating transmittal, review, approval,                                                                        measures must include the          design organizations. These release, distribution, and revision                                                                   establishment of written           measures must include the of design inputs and design                                                                           procedures, among participating    establishment of written output documents.                                                                                     design organizations, for the      procedures among participating review, approval, release,         design organizations for the distribution, and revision of      review, approval, release, documents involving design         distribution, and revision of interfaces,                        documents involving design interfaces.
(b) The design control measures    (b) The design control measures must provide for verifying or      must provide for verifying or checking the adequacy of design,   checking the adequacy of design by methods such as design          by methods such as design reviews, alternate or simplified   reviews, alternate or simplified calculational methods, or by a     calculational methods, or by a suitable testing program.          suitable testing program.
Independent personnel who have      The verifying or checking process  Design adequacy shall be       (b) For the verifying or checking  (b) For the verifying or checking qualifications equal to those of    shall be performed by individuals  verified by persons other than process, the licensee shall        process, the licensee and the original design personnel       or groups other than those who     those who designed the item. designate individuals or groups    certificate holder shall designate perform design verification. This   performed the original design, but                                other than those who were          individuals or groups other than could include anengineering         who may be from the same                                          responsible for the original       those who were responsible for supervisor who initiated the        organization.                                                     design, but who may be from the    the original design, but who may design provided he/she did not                                                                        same organization.                 be from the same organization.
specify a singular design approach or rule out certain design considerations. No individual is ever the verifier for his/her own work or input.
Qualification testing                                                                                 (b) Where a test program is used   (b) Where a test program is used (synonymous with design                                                                               to verify the adequacy of a        to verify the adequacy of a validation) provides the                                                                              specific design feature in lieu of specific design feature in lieu of assurance that products conform                                                                       other verifying or checking        other verifying or checking 11 of 32

Enclosure 3 ZionSolutions Quality Assurance Project Plan (ZS-QA-10)
QAPP Compliance Matrix iZoSd0utios                      10CFRSOAppendiB CQAPP                                 NQA-1A9I94                                I0CFR7!                              0CER2.
10 to defined user needs and                                                                                      processes, the licensee,             processes, the licensee and requirements. Qualification tests                                                                              certificate holder, and applicant    certificate holder shall include of important-to-safety and DCS                                                                                 for a CoC shall include suitable     suitable qualification testing of a operations items validate and                                                                                  qualification testing of a prototype prototype or sample unit under demonstrate the adequacy of                                                                                    or sample unit under the most        the most adverse design performance under conditions                                                                                   adverse design conditions.           conditions.
that simulate the most severe design conditions in accordance with written test procedures and test specifications.
Changes to final design, field      Design changes, including field     Design changes, including field        (c) The licensee, certificate        (c) The licensee, applicant for a changes, and modifications are      changes, shall be subject to        changes, shall be governed by          holder, and applicant for a CoC      license, certificate holder, and justified and subject to design     design control measures             control measures commensurate          shall subject design changes,        applicant for a CoC shall subject control measures commensurate       commensurate with those applied     with those applied to the original     including field changes, to design   design changes, including field with those applied to the original  to the original design.             design.                                control measures commensurate        changes, to design control design.                                                                                                        with those applied to the original   measures commensurate with design. Changes in the               those applied to the original conditions specified in the CoC      design. Changes in the require prior NRC approval,          conditions specified in the license or CoC require prior NRC approval.
SECTION 4.4                        CRITERIA IV)                 BAI*. . REQUIREMENT 4          .        71.109 PROCUREMENT.                  72.148 PR.OCUREMENT PROCUREMENTDocUMENT                 !ROCUREMENTID~OCMENT P                                  i      DOCUMENTCO~NTROL                      DOCUMENT CONTROL
                             ~~          2< CONT~RQL                          -C~ONT~ROL Controls for procured items and     Measures shall be established to    Applicable design bases and            The licensee shall establish         The licensee, applicant for a services are established in         assure that applicable regulatory   other requirements necessary to        measures to assure adequate          license, certificate holder, and approved programs and               requirements, design bases, and     assure adequate quality shall be       quality is required in the           applicant for a CoC shall procedures. These programs          other requirements which are        included or referenced in              documents for procurement of         establish measures to assure and procedures require the          necessary to assure adequate        documents for procurbment of           material, equipment, and             that applicable regulatory technical, quality, regulatory, and quality are suitably included in    items and services.                    services, whether purchased by       requirements, design basis, and administrative requirements         the documents for procurement                                              the licensee or by its contractors   other requirements which are applicable to the procurement to    of material, equipment, and                                                or sub-contractors.                  necessary to assure adequate be specified in procurement         services, whether purchased by                                                                                  quality are included or referenced documents. To the extent            the applicant or by its contractors                                                                             in the documents for necessary, procurement              or sub-contractors.                                                                                             procurement of material, documents require suppliers to                                                                                                                      equipment, and services, adequately implement a quality                                                                                                                      whether purchased by the program consistent with the type                                                                                                                   licensee, certificate holder, or by 12 of 32

Enclosure 3 ZionSolutions Quality Assurance Project Plan (ZS-QA-10)
QAPP Compliance Matrix ZIon S 616d iQAPPz                10CFRS5O 9Appenidlix B                      NQA-1-1994                              1iOCFR71                            10iCFR7~2 and use of the item or service                                                                                                                      their contractors and sub-being purchased.                                                                                                                                    contractors.
To the extent necessary,           To the extent necessary, the          To the extent necessary,              To the extent necessary, the         To the extent necessary, the procurement documents require      procurement documents shall           procurement documents shall           licensee shall require contractors   licensee, applicant for a license, suppliers to adequately            require contractors or                require Suppliers to have a           or subcontractors to provide a       certificate holder, and applicant implement a quality program        subcontractors to provide a           quality assurance program             quality assurance program            for a CoC, shall require consistent with the type and use   quality assurance program             consistent with the applicable        consistent with the applicable       contractors or subcontractors to of the item or service being       consistent with the applicable        requirements of this Part (Part1). provisions of this part.             provide a quality assurance purchased                          provisions of this Appendix.                                                                                     program consistent with the applicable provisions of this subpart.
SEC~TION 4.5,1'~                   CRITERIA V                  KBASIC REQUIREMENTS671.1~11                       INSTRUCTbONS,               72.10NSTRUC.TIONS,,
INSRDUCETIAND, PROCEDURES     INTUCIN,          PRCDRAWING                POEURES, AND                         PROCEDURES, AND AND DRAC                                                     DRAWINGS         DAIG KDRAWINGSI Management is responsible for      Activities affecting quality shall be Activities affecting quality shall be The licensee shall prescribe         The licensee, applicant for a ensuring that important-to-safety  prescribed by documented              prescribed by and performed in        activities affecting quality by      license, certificate holder, and and DCS operations activities are  instructions, procedures, or          accordance with documented            documented instructions,             applicant for a CoC shall described in instructions,         drawings of a type appropriate to     instructions, procedures, or          procedures, or drawings of a type    prescribe activities affecting procedures, or drawings, which     the circumstances and shall be        drawings of a type appropriate to     appropriate to the circumstances     quality by documented are prepared and approved prior    accomplished in accordance with       the circumstances.                    and shall require that these         instructions, procedures, or to commencing activities. All      these instructions, procedures, or                                          instructions, procedures, and        drawings of a type appropriate to project personnel are responsible  drawings.                                                                   drawings be followed,                the circumstances and shall to perform their activities in                                                                                                                      require that these instructions, accordance with the                                                                                                                                 procedures, and drawings be requirements of these                                                                                                                               followed.
documents.
These documents include            Instructions, procedures, or          These documents shall include or      The instructions, procedures, and    The instructions, procedures, and appropriate quantitative and       drawings shall include                reference appropriate                 drawings must include                drawings must include qualitative acceptance criteria to appropriate quantitative or           quantitative or qualitative           appropriate quantitative or          *appropriate quantitative or verify that the activity has been  qualitative acceptance criteria for   acceptance criteria for               qualitative acceptance criteria for  qualitative acceptance criteria for satisfactorily accomplished,       determining that important            determining that prescribed           determining that important           determining that important activities have been satisfactorily   activities have been satisfactorily   activities have been satisfactorily  activities have been satisfactorily accomplished.                         accomplished,                         accomplished.,                       accomplished.
13 of 32

Enclosure 3 ZionSolutions Quality Assurance Project Plan (ZS-QA-10)
QAPP Compliance Matrix LJU1.Ul I IrI It-0 LI ICIL VI  ;"Ot. IUV   UI        IVICCOIUI VO 01 011 UVO VOLOV1IOI IVU        The preparation, issue, and              The licensee shall establish                  I ne iicensee, appiicant Tor a affect quality are controlled to                     to control the issuance of                    change of documents that                measures to control the issuance              license, certificate holder, and ensure that the proper revisions                     documents such as instructions,               specify requirements or                 of documents such as                          applicant for a CoC shall are used. Controlled documents                       procedures, and drawings,                     prescribe activities affecting          instructions, procedures, and                 establish measures to control the include documentation for                            including changes thereto, which              quality shall be controlled to          drawings, including changes,                  issuance of documents such as important-to-safety and DCS                          prescribe all activities affecting            assure that correct documents           which prescribe all activities                instructions, procedures, and operations activities such as                        quality.                                      are being employed.                     affecting quality                             drawings, including changes, procedures, work instructions,                                                                                                                                                           which prescribe all activities and drawings.                                                                                                                                                                            affecting quality..
Project documents, including changes, shall be identified, prepared, reviewed, approved, maintained, revised, and controlled in accordance with the requirements of this QAPP.
________________________                          L                                           .1                                         I Documents are reviewed for                         These measures shall assure                  Such documents, including                 These measures must assure                    These measures must assure adequacy and approved for                           that documents, including                    changes thereto, shall be                 that documents, including                     that documents, including release by authorized personnel                     changes, are reviewed for                    reviewed for adequacy and                 changes, are reviewed for                     changes, are reviewed for prior to issuance. Documents                        adequacy and approved for                    approved for release by                   adequacy, approved for release                adequacy, approved for release are issued to and used at the                       release by authorized personnel              authorized personnel.                     by authorized personnel, and                  by authorized personnel, and location where the activity is                      and are distributed to and used at                                                     distributed and used at the                   distributed and used at the performed as specified in project                   the location where the prescribed                                                      location where the prescribed                 location where the prescribed procedures. Document changes                       activity is performed.                                                                 activity is performed.                        activity is performed. These are reviewed and approved in                                                                                                                                                             measures must assure that accordance with project                                                                                                                                                                  changes to documents are procedures.                                                                                                                                                                             reviewed and approved.
LIU[IOUIUIIU!II         i IIUUUI       UiI11{I11!   IVIUCI:UlI0Z  WIIII UO "   L0t L:UIIbII{U LU     I II0* IUl. UIVIIIIIL UI ILtlI 0I1.llU   *1,0 I I IC *I1'.,0I 000;* 01111 COll OLIUIICl I (a) The licensee, applicant tor a controls establish measures to                     assure that purchased material,              services shall be controlled to           measures to assure that                       license, certificate holder, and ensure those procured items and                    equipment, and services,                     assure conformance with                   purchased material, equipment,                applicant for a CoC shall services for important-to-safety                   whether purchased directly or                specified requirements.                   and services, whether purchased               establish measures to ensure and DCS operations applications I throuqh contractors and                                                                                 directly or through contractors               that purchased material, i
14 of 32

                                                                              , Enclosure 3 ZionSolutions Quality Assurance Project Plan (ZS-QA-10)
QAPP Compliance Matrix aZI1.SoRutSons QAPP              A0.i       *FMO-Appendi.B                NA-1-9..4                          10CFR.7.1                         10 CF-R72 are clearly and adequately          subcontractors, conform to the                                      and subcontractors, conform to    equipment, and services, specified in procurement            procurement documents.                                              the procurement documents.        whether purchased directly or documents.                                                                                                                                through contractors and subcontractors, conform to the Receiving inspection shall be                                                                                                             procurement documents.
performed for purchased items that are important-to-safety or DCS operations related (including spare or replacement parts) to ensure that:
-     Items are properly identified and correspond to the receiving documentation.
-     Inspection records and certificates of conformance.
attesting to the acceptance of the items are available.
-     Items accepted and released are identified as to their inspection status prior to forwarding them to a controlled storage area or releasing them for installation or further work.
-     Physical attributes comply with specified requirements.
Project technical, procurement,     These measures shall include     Such control shall provide for the (a) These measures must include   (a) These measures must include and QA personnel participate, as    provisions, as appropriate, for  following as appropriate: source   provisions, as appropriate, for   provisions, as appropriate, for appropriate, in evaluation of       source evaluation and selection, evaluation and selection,          source evaluation and selection,  source evaluation and selection, potential procurement sources       objective evidence of quality    evaluation of objective evidence   objective evidence of quality     objective evidence of quality performed by EnergySolutions'       furnished by the contractor or   of quality furnished by the        furnished by the contractor or    furnished by the contractor or Corporate Quality Assurance         subcontractor, inspection at the Supplier, source inspection,       subcontractor, inspection at the. subcontractor, inspection at the Department or ZionSolutions QA      contractor or subcontractor      audit, and examination of items    contractor or subcontractor       contractor or subcontractor staff. ZionSolutions' QA            source, and examination of       or services upon delivery or       source, and examination of        source, and examination of Department shall perform a third    products upon delivery,          completion.                        products upon delivery,           products upon delivery.
party review of EnergySolutions' audits to ensure they are acceptable to ZionSolutions'.
15 of 32

Enclosure 3 ZionSolutions Quality Assurance Project Plan (ZS-QA-10)
QAPP Compliance Matrix Z--lo-nSolutiIons QARPP      10CFRSO Appendix B    ~        NCJA-1 -1994                   ICFR71F 10                                 10 CFR72~
ZionSolutions' recommendations of procurement sources. are based on these evaluations.
Results of supplier evaluations performed prior to contract award are documented and retained.
The evaluations cover review of capabilities and facilities for technical, manufacturing, and quality performance, and include any or all of the following, as appropriate:
-     Historical performance data, particularly inproduct quality and delivery.
-     Review of supplier's QA Program, including current quality records.
-    Inspections, audits, or surveillances to verify supplier's QA Program implementation.
-     Source qualification programs.
Receiving inspection shall be performed for purchased items that are important-to-safety or DCS operations related (including spare or replacement parts)
Receiving inspection shall be                                                        (b) The licensee, certificate      (b) The licensee, applicant for a performed for purchased items "                                                      holder, and applicant for a CoC    license, certificate holder, and that are important-to-safety or                                                      shall have available documentary   applicant for a CoC shall have' DCS operations related                                                               evidence that material and        -available documentary evidence (including' spare or replacement                                                     equipment conform to the           that material and equipment parts) to ensure that:                                                               procurement specifications         conform to the procurement before installation or use of the  specifications prior to installation 16 of 32

Enclosure 3 ZionSolutions Quality Assurance Project Plan (ZS-QA-1O).
QAPP Compliance Matrix ZlonSo1UtfdihiQAFPP           f1OCER5O Appoeaidx B ~          .NCLA-1-t  1"'4                  1OFR7I1CR~~
  " Items are properly identified                                                         material and equipment. The         or use of the material and and correspond to the                                                                licensee, certificate holder, and   equipment. The licensee and receiving documentation.                                                             applicant for a CoC shall retain,   certificate holder shall retain or Inspection records
  " censetiion             and recordsrmande                                                          or have available, this             have available this documentary documentary evidence for the life   evidence for the life of the ISFSI, certificates of conformance                                                          of the package to which it          MRS, or spent fuel storage cask.
attesting to the acceptance of                                                       applies. The licensee, certificate  The licensee and certificate the items are available.                                                             holder, and applicant for a CoC     holder shall ensure that the
  " Items accepted and released                                                           shall'assure that the evidence is   evidence is sufficient to identify are identified as to their                                                           sufficient to identify the specific the specific requirements met by inspection status prior to                                                           requirements met by the             the purchased material and forwarding them to a controlled                                                      purchased material and              equipment.
storage area or releasing them                                                       equipment.
for installation or further work.
 " Physical attributes comply with specified requirements.
Records of such inspections and documentary evidence that material, -equipment, and services conform to procurement specifications and documents shall be retained or be available prior to installation or use of the item, material, equipment or service, for the life of the
* package, and for the life of the ISFSI as applicable.
A documented evaluation is                                                               (c) The licensee, certificate       (c) The licensee, applicant for a required annually for suppliers                                                         holder, and applicant for a CoC     license, certificate holder, and maintained on the supplier list.                                                        shall assess the effectiveness of   applicant for a CoC, or a Supplier audits, when required,                                                          the control of quality by           designee of either, shall assess shall be conducted at least once                                                         contractors and subcontractors at   the effectiveness of the control of every thirty-six (36) months in                                                          intervals consistent with the       quality by contractors and accordance with the audit section                                                        importance, complexity, and         subcontractors at intervals of this document.                                                                       quantity of the product or          consistent with the importance, services.                           complexity, and quantity of the product or services.
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Enclosure 3 ZionSolutions Quality Assurance Project Plan (ZS-QA-10)
QAPP Compliance Matrix Lontrois are estaDlisneo in            m Measures      snaii De estaoiisnea Tor    uontrois snaii oe estaoiisnea to      i ne iicensee snaiu estaDiisn          I ne iicensee, appiicant Tor a approved procedures to assure         the identification and control of          assure that only correct and          measures for the identification        license, certificate holder, and that only correct and accepted         materials, parts, and components          accepted items are used or            and control of materials, parts,       applicant for a CoC shall items are used or installed.           including partially fabricated            installed.                            and components.:                       establish measures for the assemblies.                                                                                                            identification and control of The identification and control of                                                                                      These identification and control       materials, parts, and material, parts, and components        These identification and control                                                measures must be designed to           components.
will include the use of heat           measures shall be designed to                                                   prevent the use of incorrect or numbers when applicable to             prevent the use of incorrect or                                                 defective material, parts and          These identification and control assure the maintenance of              defective material, parts and                                                   components.                            measures must be designed to identification and traceability        components.                                                                                                            prevent the use of incorrect or throughout all stages of the                                                                                                                                  defective material, parts and project and to prevent the use of                                                                                                                             components.
incorrect or defective material, parts or components.
L                                         .1                                                                          .
Identification is maintained either                                               Identification shall be maintained   These measures must assure             These measures must ensure on the items or in documents                                                     either on the items or in             that identification of the item is     that identification of the item is traceable to the item.                                                           documents traceable to the            maintained by heat number, part        maintained by heat number, part items, or in a manner which          number, or other appropriate           number, serial number, or other Identification such as batch, lot,                                                assures that identification is       means, either on the item or on        appropriate means, either on the serial number, or part number is                                                  established and maintained.          records traceable to the item, as      item or on records traceable to maintained from initial receipt up                                                                                     required throughout fabrication,       the item as required, throughout to and including installation. The                                                                                     installation, and use of the item. fabrication, installation, and use identification relates the item to                                                                                                                            of the item.
the applicable design or other specification document when appropriate. ZionSolutions utilizes physical identification when possible. Other means, including separation or procedural control, are used when physical identification is not possible.
I __________________                      .1.__________________                  1__________________                  .1.
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Enclosure 3 ZionSolutions Quality Assurance Project Plan (ZS-QA-10)
QAPP Compliance Matrix zspecial processes, that control or Measures shall be established to      Processes atrecting qualit verify quality are performed by     assure that special processes,        items or services shall be qualified personnel using           including welding, heat treating,     controlled.
qualified procedures. Personnel,    and nondestructive testing, are equipment, and procedures used      controlled and accomplished by to perform special processes are    qualified personnel using qualified in accordance with .      qualified procedures in specified requirements. Qualified   accordance with applicable procedures for special processes    codes, standards, specifications, include required conditions such    criteria, and other special as proper equipment, controlled     requirements.
parameters, and calibration requirements.
Special processes that control or                                         Special processes that control or  The licensee shall establish                           The licensee, applicant for a verify quality are performed by                                           verify quality, such as those used measures to assure that special                        license, certificate holder, and qualified personnel using                                                 in welding, heat treating, and     processes, including welding,                          applicant for a CoC shall qualified procedures. Personnel,                                          nondestructive examination, shall  heat treating, and nondestructive                      establish measures to ensure equipment, and procedures used                                            be performed by qualified          testing, are controlled and                            that special processes, including to perform special processes are                                          personnel using qualified          accomplished by qualified                              welding, heat treating, and qualified in accordance with                                              procedures in accordance with      personnel using qualified                              nondestructive testing, are specified requirements. Qualified                                         specified requirements.            procedures in accordance with                          controlled and accomplished by procedures for special processes                                                                             applicable codes, standards,                           qualified personnel using include required conditions such                                                                             specifications, criteria, and other                    qualified procedures in as proper equipment, controlled                                                                              special requirements.                                  accordance with applicable parameters, and calibration                                                                                                                                         codes, standards, specifications, requirements.                                                                                                                                                       criteria, and other special requirements.
I, udIlly ms5urance, engmr1eeiriny,                                       IIIZpL;AIUIIu ) IquIIuu LUVwIIy     I I I t I I K AI I+ V biI dI l * , ZLdU I I I d:t l u Wf         I I1W MII I &#xfd;Uu'l    i::J yp*t*j aI lL IUI C::
II, and technical support personnel     activities affecting quality shall be conformance of an item or          execute a program for inspection                       license, certificate holder, and are responsible for ensuring that   established and executed by or        activity to specified requirements of activities affecting quality by or                  applicant for a CoC shall inspections required to verify      for the organization performing       shall be planned and executed. for the organization performing                        establish and execute a program conformance of an item or           the activity to verify conformance                                       the activity to verify conformance                     for inspection of activities 19 of 32

Enclosure 3 ZionSolutions Quality Assurance Project Plan (ZS-QA-10)
QAPP Compliance Matrix
      -ZionS.6Iutlons QAPP                 1c0cFRO Appendix B                     NQASI 1994                       10CFR7I                             10 CFR72 activity to specified requirements   with the documented instructions,                                 with the documented instructions, affecting quality by or for the are planned, executed, and           procedures, and drawings for                                      procedures, and drawings for      organization performing the documented by qualified              accomplishing the activity.                                       accomplishing the activity.       activity to verify conformance personnel according to approved                                                                                                          with the documented instructions, procedures.                                                                                                                              procedures, and drawings for accomplishing the activity.
Inspection procedures,                                                 Characteristics to be inspected instructions, or checklists identify                                   and inspection methods to be the characteristics and activities                                     employed shall be specified.
to be inspected:
-    acceptance criteria;
-    responsible organization for performing inspection;
-    and, provide for recording objective evidence of inspection results.
Quality Assurance, engineering,                                        Inspection results shall be and technical support personnel                                        documented.
are responsible for ensuring that inspections required to verify conformance of an item or activity to specified requirements are planned, executed, and documented by qualified personnel according to approved procedures.
Inspection records contain, at a minimum, identification of the item inspected, date of inspection, inspector name, type of observation, acceptance and rejection criteria, results or acceptability, and reference to nonconformance's.
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Enclosure 3 ZionSolutions Quality Assurance Project Plan (ZS-QA-10)
QAPP Compliance Matrix ZionSolutionsQAPP                    19%CFR50Al*OfWdlx B                  NQA-1-y994                        10CFR7_1_                          10 CF_ 2 Inspection personnel are             Such inspection shall be        Inspection for acceptance shall The inspection must be              The inspection must be independent of those who             performed by individuals other  be performed by persons other   performed by individuals other      performed by individuals other performed the work being             than those who performed the    than those who performed or     than those who performed the        than those who performed the inspected,                           activity being inspected.       directly supervised the work    activity being inspected.           activity being inspected.
I __                              being inspected.
Quality Assurance, engineering,                                                                      Examination, measurements, or       Examinations, measurements, or and technical support personnel                                                                      tests of material or products       tests of material or products are responsible for ensuring that                                                                    processed must be performed for     processed must be performed for inspections required to verify                                                                       each work operation where           each work operation where conformance of an item or                                                                            necessary to assure quality. If     necessary to assure quality. If activity to specified requirements                                                                   direct inspection of processed      direct inspection of processed are planned, executed, and                                                                           material or products is not carried material or products cannot be documented by qualified                                                                              out, indirect control by monitoring carried out, indirect control by personnel according to approved                                                                      processing methods, equipment,      monitoring processing methods, procedures.                                                                                          and personnel must be provided. equipment, and personnel must Both inspection and process         be provided. Both inspection and Responsibilities for identifying                                                                     monitoring must be provided         process monitoring must be and specifying hold points are                                                                       when quality control is             provided when quality control is established in approved                                                                              inadequate without both. If         inadequate without both. If procedures. Quality Assurance,                                                                       mandatory inspection hold points,   mandatory inspection hold points Engineering, and technical                                                                           which require witnessing or         that require witnessing or support representatives are                                                                          inspecting by the licensee's        inspecting by the licensee's or responsible for identifying                                                                          designated representative and       certificate holder's designated inspection hold points in                                                                            beyond which work should not        representative, and beyond appropriate documents to ensure                                                                      proceed without the consent of its  which work should not proceed that no further work is performed                                                                    designated representative, are      without the consent of its until a certain inspection has .                                                                     required, the specific hold points  designated representative, are been completed. Work does not                                                                        must be indicated in appropriate    required, the specific hold points proceed beyond hold points..                                                                         documents.                          must be indicated in appropriate without consent from the                                                                                                                 documents.
organization that established them. This consent is recorded prior to continuation of work.
Inspections are performed, as necessary, to verify conformance to requirements. Indirect control by monitoring may be utilized when direct inspection is impractical. Both insoection and 21 of 32

Enclosure 3 ZionSolutions Quality Assurance Project Plan (ZS-QA-1O)
QAPP Compliance Matrix 3/4Zioif6uiofls QAPP                   i90_CfR60O.Apiiendlx 8                 NQAi-1 -994,           ~10,CTR7,1                                    1,0_9FR7Z2 monitoring are performed when control is inadequatewithout both. A combination of inspection and process monitoring is performed in a systematic manner to assure quality is achieved throughout the duration of the process.
SECTION4.1         '76RITERIA                      Xl_    -    BASIC REQUIREMENTI1                  71.123 TEST CONTROL             72.162 TEST cNTROL
                 ~'   &~   ~TEST                      CQ NTROL                 TEST CONTROL Testing to verify conformance of     A test program shall be          Tests required to verify           The licensee shall establish a  The licensee, applicant for a processes, equipment, and            established to assure that all   conformance of an item or          test program to assure that all license, certificate holder, and products to specified                testing required to demonstrate  computer program to specified      testing required to demonstrate applicant for a CoC shall requirements and to demonstrate      that structures, systems, and    requirements and to demonstrate    that the packaging components   establish a test program to satisfactory performance is          components will perform          that items willperform             will perform satisfactorily in  ensure that all testing required to planned and performed by             satisfactorily in service is     satisfactorily in service shall be service is identified and       demonstrate that the structures, qualified personnel in accordance    identified and performed in      planned and executed,              performed in accordance with    systems, and components will with approved procedures. Tests      accordance with written test                                        written test procedures that    perform satisfactorily in service, required to collect data are         procedures which incorporate the                                    incorporate the requirements of is identified and performed in planned, executed, documented,       requirements and acceptance                                         this part and the requirements  accordance .with written test and evaluated,                       limits contained in applicable                                      and acceptance limits contained procedures that incorporate the design documents.                                                   in the package approval.        requirements of this part and the The test methods and                                                                                                                     requirements and acceptance acceptance criteria are based on                                                                                                         limits contained in the ISFSI, specified requirements contained                                                                                                         MRS, or spent fuel storage in design or other technical                                                                                                             license or CoC.
documents.
Engineering and technical                                             Characteristics to be tested and support representatives are                                           test methods to be employed responsible to ensure that test                                       shall be specified.
requirements and acceptance criteria are developed and incorporated into appropriate test plans, procedures, or checklists.
The test methods and acceptance criteria are based on specified requirements contained in design or other technical documents.
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Enclosure 3 ZionSolutions Quality Assurance Project Plan (ZS-QA-10)
QAPP Compliance Matrix S~<Z~n~out~o&QAPK~  A      IOCFR50 A peridlxB8NAi19                                              '>x     10F717                           K<0CR~
Test procedures include or                                                                                The test procedures must include      The test procedures must include reference characteristics to be                                                                           provisions for assuring that all      provisions to ensure that all tested and test objectives and                                                                            prerequisites for the given test      prerequisites for the given test prerequisites. Prerequisites such                                                                         are met, that adequate test           are met, that adequate test as calibrated instrumentation,                                                                            instrumentation is available and      instrumentation is available and equipment and its condition,                                                                              used, and that the test is            used, and that the test is personnel qualification,                                                                                  performed under suitable              performed under suitable environmental conditions, and                                                                             environmental conditions.             environmental conditions.
collection and recording of data are taken into consideration during development of test procedures.
Test results are documented and                                      Test results shall be documented     The licensee, certificate holder,     The licensee, applicant for a evaluated by a responsible                                           and their conformance with           and applicant for a CoC shall         license, certificate holder, and authority to assure the test                                         acceptance criteria shall be         document and evaluate the test        applicant for a CoC shall requirements were satisfied,                                         evaluated,                           results to assure that test           document and evaluate the test requirements have been                results to ensure that test satisfied.                            requirements have been satisfied.
Tests required to  collect data, such as for siting or design input, shall be planned,  executed, documented, and     evaluated.
SECTION 4.12                        CRITERIA XII              BASICREQUiREMENT 12*               .. 7 1.125 CONTR OL OF                   72.164 CONTROL OF CONTROLOFMEASURNG                 C            OF MEASURING.              MEA*.URING AND TEST
* MASURING AND TEST AND TEST EQUIPMENT                 ANDTESTEQUIPMENT               ..           EQUIPMENT                       -     EQUIMENT The calibration process assures    Measures shall be established to  Tools, gages, instruments, and       The licensee shall establish          The licensee, applicant for a that all measuring instruments     assure that tools, gages,         other measuring and test              measures to assure that tools,       license, certificate holder, and used in the acceptance of          instruments, and other measuring  equipment used for activities        gages, instruments, and other         applicant for a CoC shall material, equipment, and           and testing devices used in       affecting quality shall be            measuring and testing devices        establish measures to ensure assemblies are calibrated and      activities affecting quality are  controlled and at specified           used in activities affecting quality that tools, gauges, instruments, properly adjusted at specified     properly controlled, calibrated,  periods calibrated and adjusted       are properly controlled,             and other measuring and testing intervals to maintain accuracy     and adjusted at specified periods to maintain accuracy within           calibrated, and adjusted at          devices used in activities within pre-determined limits,      to maintain accuracy within       necessary limits,                     specified times to maintain          affecting quality are properly necessary limits,                                                       accuracy within necessary limits,    controlled, calibrated, and adjusted at specified times to maintain accuracy within necessary limits.
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Enclosure 3 ZionSolutions Quality Assurance Project Plan (ZS-QA-10)
QAPP Compliance Matrix ivateinais consiaerea critical,      measuressnall oe estaDlIsned to   Handling, storage, cleaning,           11ne itcensee Snail establish     Ine licensee, applicant tor a sensitive, perishable, or QA         control the handling, storage,    packaging, shipping, and              measures to control, in           license, certificate holder, and designated are handled, cleaned, shipping, cleaning, and               preservation of items shall be        accordance with instructions, the applicant for a CoC shall stored, packaged, and shipped in preservation of materials and         controlled to prevent damage or       handling, storage, shipping,      establish measures to control, in accordance with controls             equipment in accordance with      loss and to minimize                  cleaning, and preservation of     accordance with work and identified in codes, standards,     *work and inspection instructions  deterioration.                        materials and equipment to be     inspection instructions, the regulations, engineering             to prevent damage or                                                    used in packaging to prevent      handling, storage, shipping, specifications, or project           deterioration.                                                          damage or deterioration.          cleaning, and preservation of requirements to prevent damage                                                                                                                 materials and equipment to or loss and to minimize                                                                                                                        prevent damage or deterioration.
deterioration.
When necessary for particular                                                                                When necessary for particular     When necessary for particular products, special protective                                                                                 products, special protective      products, special protective environments, such as inert gas                                                                              environments, such as inert gas   environments, such as inert gas atmosphere, and specific                                                                                     atmosphere, and specific          atmosphere, and specific moisture content and                                                                                         moisture content and              moisture content and temperature levels, are specified                                                                            temperature levels must be        temperature levels must be and provided in applicable                                                                                   specified and provided.           specified and provided.
documents.
IvIULFnuus u:StU Will assul Urenal. nese measures snaii provice I    ' ne status or inspection ana test                                     ta) i nese measures must required inspections and tests       the identification of items which activities shall be identified either provide for the identification of provide for the identification of are performed and to assure that     have satisfactorily passed        on the items or in documents          items that have satisfactorily    items which have satisfactorily items which have not passed the      required inspections and tests,   traceable to the items where it is    passed required inspections and   passed required inspections and required inspections or tests are    where necessary to preclude       necessary to assure that required     tests where necessary to          tests where necessary to not inadvertently installed, used    inadvertent bypassing of such     inspections and tests are             preclude inadvertent bypassing    preclude inadvertent bypassing or operated and to prevent           inspections and tests.            performed and to assure that          of the inspections and tests. of the inspections and tests.
inadvertent operation of systems.                                      items which have not passed the These methods provide for                                              required inspections and tests identification of items which have                                     are not inadvertently installed; 24 of 32

Enclosure 3 ZionSolutions Quality Assurance Project Plan (ZS-QA-10)
QAPP Compliance Matrix ZiqnSodut~ons QA-PP                I'OCFR5OYAppendix Bl                        ~-~f4    "                             IDCFR71                           1OCfR72 satisfactorily. passed the required                                     used, or operated.
inspections and tests.
Methods to indicate the status of   Measures shall be established to    Status shall be maintained           (a) The licensee shall establish    (a) The licensee shall establish inspections, tests, and operating   indicate, by the use of markings    through indicators, such as          measures to indicate, by use of     measures to indicate, by use of status of systems for DCS, ISFSI,   such as stamps, tags, labels,       physical location and tags,          markings such as stamps, tags,,     markings such as stamps, tags, or spent fuel cask items and        routing cards, or other suitable    markings, shop travelers,            labels, routing cards, or other     labels, routing cards, or other other selected tasks also include   means, the status of inspections    stamps, inspection records, or       suitable means, the status of       suitable means, the status of stamps, tags, or routing cards,     and tests performed upon            other suitable means.                inspections and tests performed   . inspections and tests performed individual items of the nuclear                                          upon individual items of the        upon individual items of the ISFSI power plant and fuel                                                     packaging.                          or MRS.
reprocessing plant.
The authority for application and                                       The authority for application and removal of status indicators is                                         removal of tags, markings, labels, identified in approved                                                  and stamps shall be specified.
procedures.
The status of items can be          Measures shall also be              Status indicators shall also         (b) The licensee shall establish    (b) The licensee shall establish determined at any point             established for indicating the      provide for indicating the           measures to identify the            measures to identify the throughout an operational           operating status of structures,     operating status of systems and      operating status of components      operating status of structures, process to prevent inadvertent      systems, and components of the      components of the nuclear            of the packaging, such as tagging   systems, and components of the use, installation, or operation of  nuclear power plant and fuel        facility, such as by tagging valves  valves and switches, to prevent     ISFSI or MRS, such as tagging nonconforming or defective          reprocessing plant, such as by      and switches, to prevent             inadvertent operation.              valves and switches, to prevent items. Status indicators are        tagging valves and switches, to. inadvertent operation.                                                   inadvertent operation.
required to the extent possible to  prevent inadvertent operation.
prevent operation of items that are removed from service for test, calibration, maintenance, or repair, and to ensure that required inspections and tests have been performed.
iiems  mai oo not conmorm to        imeasures   snail ue estaoiisneu to i emins rnaL uo n[10 CunjiI[ LU     I I[it IIU;IIZSUU ZIdIf ULdUIIl:[     I IIU IILUIIb5t, dPIIJIIdIIL IUl d specified requirements are          control materials, parts, or        specified requirements shall be      measures to control materials,      license, certificate holder, and controlled to prevent inadvertent   components which do not             controlled to prevent inadvertent    parts, or components that do not    applicant for a CoC shall ,
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Enclosure 3 ZionSolutions Quality Assurance Project Plan (ZS-QA-10)
QAPP Compliance Matrix ZionSolutions QAPP                  1,DC *50Ap*pendi*x B               .*:NQA-1     -1994                         1'0,C FRT7I*,                      10, CFR72&#xfd; installation or use in accordance   conform to requirements in order   installation or use.                conform to the licensee's          establish measures to control with approved procedures.           to prevent their inadvertent use                                       requirements to prevent their      materials, parts, or components or installation.                                                       inadvertent use or installation. that do not conform to their requirements in order to prevent their inadvertent use or installation.
Procedures include controls that    These measures shall include, as   Controls shall provide for          These measures must include,       These measures must include, provide for reporting, identifying, appropriate, procedures for        identification, documentation,      as appropriate, procedures for     as appropriate, procedures for documenting, evaluating,            identification, documentation,     evaluation, segregation when        identification, documentation,     identification, documentation, segregating (when feasible),        segregation, disposition, and      practical, and disposition of       segregation, disposition, and      segregation, disposition, and dispositioning nonconforming        notification to affected           nonconforming items, and for        notification to affected           notification to affected items, and notifying affected       organizations.                     notification to affected            organizations.                     organizations.
organizations.                                                         organizations.
Nonconforming items must be        Nonconforming items must be reviewed and accepted, rejected,   reviewed and accepted, rejected, repaired, or reworked in           repaired, or reworked in accordance with documented         accordance with documented procedures.                        procedures.
SECTtON 4.16                        CRITERIA XVI                BASIC REQUIREMENT 16             71.133 CORREGCTIVE AClO       ION   7.*72 CORRECTIVE ACTION CORRECTIVE ACTION                  CORRECTIVE ACTION Conditions adverse to quality       Measures shall be established to   Conditions adverse to quality       The licensee shall establish       The licensee, applicant for a (e.g., nonconformances, failures,   assure that conditions adverse to  shall be identified promptly and    measures to assure that            license, certificate holder, and malfunctions, deficiencies,         quality, such as failures,         corrected as soon as practical. conditions adverse to quality,     applicant for a CoC shall defective material, etc.) are       malfunctions, deficiencies,                                            such as deficiencies, deviations,  establish measures to ensure promptly identified and evaluated   deviations, defective material and                                     defective material and             that conditions adverse to quality, to determine corrective action in   equipment, and                                                         equipment, and                     such as failures, malfunctions, accordance with established         nonconformances are promptly                                           nonconformances are promptly       deficiencies, deviations, defective procedures.                         identified and corrected,                                              identified and corrected.          material and equipment, and nonconformances are promptly identified and corrected.
For significant conditions adverse  In the case of a significant       In the case of a significant        In the case of a significant       In the case of a significant to quality, the condition, the      condition identified as adverse to condition adverse to quality, the   condition adverse to quality, the  condition identified as adverse to cause of the condition and the      quality, the measures shall        cause of the condition shall be     measures must assure that the      quality, the measures must corrective action taken is          assure that the cause of the       determined and corrective action    cause of the condition is          ensure that the cause of the documented and reported to          condition is determined and        taken to preclude recurrence.       determined and corrective action   condition is determined and appropriate levels of               corrective action taken to                                           I taken to preclude repetition.      corrective action taken to 26 of 32

Enclosure 3 ZionSolutions Quality Assurance Project Plan (ZS-QA-10)
QAPP Compliance Matrix Zion$,olutlons 4APP                1OCIR5O I          Appendlix B                  QA-1 -994 14~                             ~     10CFR71~                        1CFR72 10 management. Follow-up action       preclude. repetition.                                                                                 preclude repetition.
shall be taken to verify effective implementation of the required corrective actions to prevent recurrence and to verify that they are effectively implemented.                                                                                                      ._.
For significant conditions adverse The identification of the         The identification, cause, and     The identification of the        The identification of the to quality, the condition, the     significant condition adverse to  corrective action for significant  significant condition adverse to significant condition adverse to cause of the condition and the     quality, the cause of the         conditions adverse to quality      quality, the cause of the        quality, the cause of the corrective action taken is         condition, and the corrective     shall be documented and            condition, and the corrective    condition, and the corrective documented and reported to         .action taken shall be documented reported to appropriate levels of  action taken must be             action taken must be appropriate levels of              and reported to appropriate       management;                        documented and reported to       documented and reported to management. Follow-up action       levels of management.                                                appropriate levels of            appropriate levels of shall be taken to verify effective                                                                      management.                      management.
implementation of the required corrective actions to prevent recurrence and to verify that they are effectively implemented. The GM, or designee, is responsible for reviewing the condition and determining validity. The GM will assure that validated conditions are processed in accordance with the project's corrective action program.
The management control                                               follow-up action shall be taken to systems established includes                                         verify implementation of this problem investigation, evaluation,                                   corrective action.
reporting, and follow-up action taken to verify that corrective action has been thoroughly implemented and such conditions are effectively resolved.
Follow-up action shall-be taken to verify effective implementation of the required corrective actions to prevent recurrence and to verify that they are effectively implemented.
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Enclosure 3 ZionSolutions Quality Assurance Project Plan (ZS-QA-10)
QAPP Compliance Matrix The record system includes the      .JUI IR.,lVIIL IV&#xfd;UlI UO 01 loll LJU                                        I I1IUII.t*llI t::U LUt:I LIIIkC[Ltr: IIVUIUtI ,. I It: IIUUlle , dpiJlul dII IUI d retention of those design,          maintained to furnish evidence of    documentary evidence of quality       and applicant for a CoC shall                      license, certificate holder, and fabrication, inspection, operation, activities affecting quality.        shall be specified, prepared, and     maintain sufficient written records                applicant for a CoC shall and surveillance records                                                 maintained.                           to describe the activities affecting               maintain sufficient records to essential to demonstrate product                                                                               quality. The records must include                  furnish evidence of activities quality.                                                                                                       the instructions, procedures, and                  affecting quality.
drawings required by &sect; 71.111 to                   The records must include the prescribe quality assurance                        following: design records, records activities and must include                        of use, and the results of reviews, closely related specifications                     inspections, tests, audits, such as required qualifications of                 monitoring of work performance, personnel, procedures, and                         and materials analyses. The equipment.                                         records must include closely related data such as qualifications of personnel, procedures, and equipment.
For any work performed, the         Records shall be identifiable and    Records shall be legible,                                                                Records must be identifiable and records to be generated must be     retrievable,                         identifiable, and retrievable,                                                           retrievable.
identified, along with a means of matching the record to the item or activity to which it applies.
Records must be legible, reproducible, and accurate.
QA records shall be protected                                            Records shall be protected against damage, deterioration,                                           against damage, deterioration, or unauthorized change, or loss.                                            loss.
The record system includes the      The records shall include at least   Requirements and                      The records must include the retention of those design,          the following: operating logs and    responsibilities for record           instructions or procedures which fabrication, inspection, operation, the results of reviews,              transmittal, distribution, retention, establish a records retention and surveillance records            inspections, tests, audits,          maintenance, and disposition          program that is consistent with
.essential to demonstrate product    monitoring of work performance,      shall be established and              applicable regulations and quality. It provides for the        and material analyses.               documented.                           designates factors such as identification of materials and     Consistent with applicable                                                 duration, location, and assigned their corresponding                 regulatory requirements                                                    responsibility.
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Enclosure 3 ZionSolutions Quality Assurance Project Plan (ZS-QA-10)
QAPP Compliance Matrix aZ!6flS..Qi sQARP       2        OC1FR50 Appendix S            >   NQA-11-19941 manufacturing, installation,          concerning record retention, such inspection, test, and audit results. as duration, location, and                                 The licensee, certificate holder, Requirements and                      assigned responsibility.                                   and applicant for a CoC shall responsibilities for the transmittal,                                                            retain these records for 3 years distribution, retention,                                                                         beyond the date when the maintenance, and disposition of                                                                  licensee, certificate holder, and records are specified in approved                                                                applicant for a CoC last engage procedures.                                                                                      in the activity for which the quality assurance program was developed. If any portion of the written procedures or instructions is superseded, the licensee, certificate holder, and applicant for a CoC shall retain the superseded material for 3 years after it is superseded.
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Enclosure 3 ZionSolutions Quality Assurance Project Plan (ZS-QA-10)
QAPP Compliance Matrix ZlotiSolutionsQAPP~        _       1CR5O"A&pedix             ,  1 '. A-1 -19%4f              IOCFR71 T-1WCF72 Section 4.2                         The records shall also include                                                The records must include closely Inspection and Test Personnel       closely related data such as                                                  related data such as certification documentation shall   qualifications of personnel,                                                  qualifications of personnel, be maintained in accordance with    procedures, and equipment.                                                    procedures, and equipment.
approved procedures.
Inspection and test records shall,                                            Inspection and test records must, Section 4.5                         as a minimum, identify the                                                    at a minimum, identify the Instructions, procedures, work      inspector or data recorder, the                                               inspector or data recorder, the instructions and drawings are       type of observation, the results,                                             type of observation, the results, prepared, reviewed, issued, and     the acceptability, and the action                                             the acceptability, and the action controlled in accordance with       taken in connection with any                                                  taken in connection with any approved procedures.                deficiencies noted.                                                           noted deficiencies.
Section 4.9 Documentation of personnel, equipment, and process qualifications is maintained in accordance with procedures.
Section 4.10 Inspection records .contain, at a minimum, identification of the item inspected, date of inspection, inspector name, type of observation, acceptance and rejection criteria, results or acceptability, and reference to nonconformance's.
Section 4.11 Records include as a minimum the item tested, date of test, name of the tester, environmental conditions, observations, acceptance and rejection criteria, results and acceptability, action taken for deviations noted, and name of the person evaluating results.
30 of 32

Enclosure 3 ZionSolutions Quality Assurance Project Plan (ZS-QA-1 0)
QAPP Compliance Matrix
        ~Zion$6,1Ud6-n~sQ APP         I       IOCER60 AppndlixA::&#xfd;B        [            "A-1-1199~4                                100 ER 71                              1,0 CFP72" The record system includes the                                                                                                                           Records pertaining to the design, retention of those design,                                                                                                                               fabrication, erection, testing, fabrication, 'inspection, operation,                                                                                                                     maintenance, and use of and surveillance records                                                                                                                                 structures, systems, and essential to demonstrate product                                                                                                                         components important to safety quality. It provides for the                                                                                                                             must be maintained by or under identification of materials and                                                                                                                          the control of the licensee or their corresponding                                                                                                                                      certificate holder until the NRC manufacturing, installation,                                                                                                                             terminates the license or CoC.
inspection, test, and audit results.
Requirements and responsibilities for the transmittal, distribution, retention, maintenance, and disposition of records are specified in approved procedures.
Various regulatory agencies have requirements concerning records that are within the scope of the QAPP. The most stringent requirements shall be used in determining the final disposition.
F 101 11IWU 11II It Clll UU1LJ Cl1C                                          rlidH: M t: di u lIl bU1I UUUlUU d:ULIILb* I II* IIMUMI=Vl   Wi1dl L, IIIy UUL d  I II1 IIl* *,ll :  dC. IIUdl1 IL 1UUId scheduled annually and                  planned and periodic audits shall    shall be performed to verify          comprehensive system of               license, certificate holder, and performed per approved                  be carried out to verify             compliance with all aspects of.the    planned and periodic audits to        applicant for a CoC shall carry procedures or checklists.               compliance with all aspects of the   quality assurance program and to      verify compliance with all aspects    out a comprehensive system of Elements of the QAPP will be            quality assurance program and to     determine its effectiveness.          of the quality assurance program      planned and periodic audits to audited at least annually to            determine the effectiveness of                                             and to determine the                  verify compliance with all aspects provide comprehensive,                  the program.                                                               effectiveness of the program.         of the quality assurance program independent verification and                                                                                                                             and to determine the evaluation of all aspects of the                                                                                                                         effectiveness of the program.
quality assurance program and to determine its effectiveness.
31 of 32

Enclosure 3 ZionSolutions Quality Assurance Project Plan (ZS-QA-10)
QAPP Compliance Matrix ZlonSIP!utions QAPP           *10CFRSO Appendix*B                           NQA1-1994                           10.R7_110                           0CFR72 Planned internal audits are        The audits shall be performed in    These audits shall be performed   The audits must be performed in     The audits must be performed in scheduled annually and             accordance with written             in accordance with written        accordance with written          . accordance with written performed per approved             procedures or checklists by         procedures or checklists by       procedures or checklists by         procedures or checklists by procedures or checklists,          appropriately trained personnel     personnel who do not have direct  appropriately trained personnel     appropriately trained personnel not having direct responsibility in responsibility for performing the not having direct responsibility in not having direct responsibility in An audit team, composed of one     the areas being audited.            activities being audited.         the areas being audited.            the areas being audited.
or more qualified auditors is identified for each audit using personnel who have no direct.
responsibility for the activity being covered. A lead auditor, as a member of the team, is designated as a team leader.
Audit reports are prepared upon    Audit results shall be              Audit results shall be            Audit results must be               Audit results must be completion of the audit and        documented and reviewed by          documented and reported to and. documented and reviewed by          documented and reviewed by distributed to appropriate         management having                   reviewed by responsible           management having                   management having management for review and          responsibility in the area audited. management.                       responsibility in the area audited. responsibility in the area audited.
response. Management of the
,audited organizations provide a response to all identified conditions adverse to quality that includes corrective actions, including cause and action to prevent recurrence, and a schedule for completion, when applicable.
The results of internal audits,    Follow-up action, including         Follow-up action shall be taken   Follow-up action, including         Follow-up action, including surveillances and assessments      reaudit of deficient areas, shall   where indicated.                  reaudit of deficient areas, must    reaudit of deficient areas, must and independent assessments        be taken where indicated,                                             be taken where indicated.           be taken where indicated.
and audits of Subcontractors will be utilized as input into the continuous improvement program through identification in the CR system. Re-audit of deficient areas will be performed when required.
32 of 32
: NQA-1 vs. Non-programmatic ANSI Standards Tables
: 1. ANSI N45.2.1 -1973 vs NQA-1-1994, Subpart 2.1
: 2. ANSI N45.2.2-1972 vs NQA-1-1994, Subpart 2.2
: 3. ANSI N45.2.3-1973 vs NQA-1-1994, Subpart 2.3
: 4. ANSI N45.2.4-1972 vs NQA-1 -1994, Subpart 2.4
: 5. ANSI N45.2.5-1978 vs NQA-1-1994, Subpart 2.5
: 6. ANSI N45.2.8-1975 vs NQA-1-1994, Subpart 2.8

Enclosure 4, Table 1 ANSI N45.2.1-1973 vs NQA-1 -1994, Subpart 2.1 N45.2.1 limited to "during construction." NQA-1 larger scope of 1.1        Scope                          Subpart 2.1 provides amplified          "during manufacturing, construction, requirements for the management of      repairs, and modifications."
This standard covers on-site cleaning     cleaning and cleanness control of of materials and components,              fluid systems and associated cleanness control, and preoperational     components for nuclear power plants cleaning and layup of important           during manufacturing, construction, nuclear power plant fluid systems         repairs, and modifications. It during construction.                      supplements the requirements of Part I.
These systems include those whose                                                 QAPP establishes applicability in satisfactory performance is required for                                          Section 1.2, Scope safe and reliable operation of the plant.
The requirements may also be              ... when and to the extent specified by In addition, the QAPP establishes extended to other parts of nuclear        the organization invoking Subpart       applicability in Section 1.2, Scope power plants when specified in            2.1.
contract documents.
The standard covers requirements                                                  Guidance only. Wording does not necessary to ensure an adequately                                                 establish requirements.
clean system upon completion of construction activities, and covers the period from which the materials and equipment are removed from storage or receiving for installation at the construction site until the systems are ready for pre-operational testing.
The intent of this standard is to require                                         Guidance only. Wording does not close attention to cleanness control                                              establish requirements.
during erection of a nuclear power plant so that only water flushing or rinsing of an installed system is required to render it ready for service.
When more than a water flush or rinse                                             Guidance only. Wording does not is needed to produce the specified                                                establish requirements.
cleanness, additional cleaning, in accordance with this standard may be necessary.
This standard is intended to be used in   ... and shall be used in conjunction    Guidance only. Wording does not conjunction with ANSI N45.2 Quality       with applicable Basic and               establish requirements.
Assurance Requirements for Nuclear        Supplementary Sections of Part I Power Plants.                             when and to the extent specified by the organization invoking Subpart 2.1.
1.2     Applicability                    Section 1 "Introduction"                These words are not included in NQA-1 Subpart 2.1, but rather in Section 1 The requirements of this standard         2 Applicability apply to the work of any individual or organization that participates in the     The requirements of this Part (Part I1) construction phase cleaning of items to   apply to fabrication, construction, be incorporated into nuclear power        modification, repair, maintenance, plants as discussed in Subsection 1.1. and testing activities that affect the quality of structures, systems, and components for nuclear facilities.
These activities include the performing function of attaining quality objectives and verifying that activities affecting quality have been correctly performed. These activities include planning, subsurface investigation, fabricating, handling, shipping, storng, cleaning...
The extent to which the individual re-    ... when and to the extent specified by OK quirements of this standard will apply    the organization invoking Subpart will depend upon the nature and scope     2.1.
1 of 29                                                7/27/10

Enclosure 4, Table 1 ANSI N45.2.1-1973 vs NQA-1-1994, Subpart 2.1 importance of the item or service involved.
The requirements are intended to                Section 1 "Introduction"                These words are not included in NQA-ensure that only proper cleaning                                                        1 Subpart 2.1, but rather in the materials, equipment, processes and             2 Applicability                         Introduction to Part II procedures are utilized during the construction of bower plants and that           The requirements of this Part (Part II) the quality of items is maintained as a         apply to fabrication, construction, result of use of proper cleaning                modification, repair, maintenance, practices and techniques during                 and testing activities that affect the construction.                                   quality of structures, systems, and components for nuclear facilities.
These activities include the performing function of attaining quality objectives and verifying that activities affecting quality have been correctly performed. These activities include planning, subsurface investigation, fabricating, handling, shipping, storing, cleaning.
1.3      Responsibility                         Section 1 "Introduction"                These words are not included in NQA-1 Subpart 2.1, but rather in the The organization or organizations               3 Responsibility                        Introduction to Part II responsible for the activities covered by this standard shall be identified and       The organization invoking this Part the scope of their responsibility shall         (Part II) shall be responsible for be documented.                                 specifying which section, or portions thereof, apply and appropriately relating them to specific items and services. To the extent necessary, this organization shall invoke the applicable provision of Part 1, Basic and Supplementary Requirements, to specify a complete Quality Assurance Program appropriate for the specific items or services. The organization upon which this Part (Part II), or portions thereof, is invoked shall be responsible for complying with the c*noeiflor  ronlu uirn=m*nnf Such responsibility should be assigned                                                 QAPP Section 2, Quality at the earliest practical point in time so                                             Responsibilities establishes as to facilitate incorporation of cleaning                                             responsibilities. Otherwise wording is requirements in design drawings and                                                    guidance.
purchase specifications.
The establishment of practices and         .                                           QAPP Section 2, Quality procedures and provision of resources,                                                 Responsibilities covers delegation.
in terms of personnel, equipment, and services necessary to implement the requirements of this standard, may be delegated to other organizations and such delegations shall also be documented.
Each organization participating in site        Section 1 "Introduction"                These words are not included in NQA-construction activities shall comply with                                              1 Subpart 2.1, but rather in the procedures and instructions issued for         3 Responsibility                        Introduction to Part II the project and with those require-ments of this standard applicable to his       The organization invoking this Part work.                                          (Part II) shall be responsible for specifying which section, or portions thereof, apply and appropriately relating them to specific items and
                                             -- services. To the extent necessary, 2 of 29                                              7/27/10

Enclosure 4, Table 1 ANSI N45.2.1-1973 vs NQA-1-1994, Subpart 2.1 LI Ilb U1 YCIl 1/_CLIUII Z11r ICII IVUMVt LlIV*
applicable provision of Part 1, Basic and Supplementary Requirements, to specify a complete Quality Assurance Program appropriate for the specific items or services. The organization upon which this Part (Part II), or portions thereof, is invoked shall be responsible for complying with the soecified reouirements.
The organization responsible for          Section 1 "Introduction                         These words are not included in NQA-performing the cleaning shall identify                                                     1 Subpart 2.1, but rather in the and document detailed cleaning            4.2 Procedures                                   Introduction to Part II. Not as specific procedures unless they are specified in                                                   in NQA-1.
the procurement documents.                Installation, inspection, test procedures, and work instructions identified during planning shall be prepared.
Requirements for review and/or            NQA-4S-1 "Supplementary                         OK approval of such procedures shall be      Requirements for Procurement specified in the procurement              Document Control" documents.
Section 2.5 The procurement documents at all tiers shall identify the documentation required to be submitted for information, review, or approval by the Purchaser.
1.4     Definitions                       1.1 Definitions                                 OK The following, definitions are provided    The following definitions are provided to assure a uniform understanding of       to assure a uniform understanding of select terms as they are used in this      unique terms as they are used in standard.                                  Subpart 2.1.
Acid Cleaning-The removal of metal         acid cleaning- the removal of metal             OK oxides by either dissolution of the        oxides by either dissolution of the oxide or undercutting the oxide by         oxide or undercutting the oxide by dissolution of the base metal with an      dissolution of the base metal with an acid solution,                             acid solution Alkaline Cleaning-The removal of           alkaline cleaning- the removal of               OK organic contaminants by converting         organic contaminants by converting them to an emulsion with an alkaline       them to an emulsion with an solution such as trisodium phosphate.      alkaline solution such as trisodium phosphate Chelate Cleaning-The removal of            chelate cleaning - the removal of               OK slightly soluble compounds such as         slightly soluble compounds such as iron oxide, by complexing the metallic     iron oxide, by complexing the metallic ions with organic chelating compounds      ions with organic chelating such as ethylene diamine tetra-acetic      compounds such as ethylene acid (EDTA).                               diamine tetra-acetic acid (EDTA)
Chemical Conditioning-The addition         chemical conditioning - the addition            OK of chemicals in low concentration to       of chemicals in low concentration to flush, rinse, or layup water to prevent    flush, rinse, or lay up water to inhibit precipitation of dissolved solids, inhibit precipitation of dissolved solids, corrosion, etc.                            corrosion, and other detrimental effects Cleaning-The removal of any                cleaning- the removal of any                    Definitions are similar and have same contaminants that might have a             contaminants that might have a                  intent- N45.2.1 includes the words "on deleterious effect on plant safety and     deleterious effect on operation of the          plant safety' and "reliable" reliable operation.                        plant Contractor-Anyindividual or                Section 1 "Introduction"                        This definition not included in NQA-1, organization entering into a contract to                                                   Subpart 2.1, but rather in Section 1 furnish items or services to a             Supplier - any individual or purchaser. The term contractor             organization who furnishes items or includes the terms Vendor, Supplier,       services in accordance with a 3 of 29                                                      7/27/10

Enclosure 4, Table 1 ANSI N45.2.1-1973 vs NQA-1-1994, Subpart 2.1 IJIUL,U MIIIVIIIL UUkU  I jUl
                                                                     *IL. -1 Iil these where appropriate.                  inclusive term used in place of the following: vendor, seller, contractor, subcontractor, fabricator, consultant, and their subtier levels.
Contamination-Anyundesirable              contamination - any unwanted or          OK foreign material on the surface of an     undesirable foreign material on the item, in the atmosphere, or in process    surface of an item, in the atmo-liquids or gases.                         sphere, or in process liquids or gases Corrosion Resistant Alloys-               corrosion-resistantalloys - materials    OK Materials, such as stainless steel,       that inherently resist oxidation or nickel-base, or cobalt-base alloys, that  chemical attack in water, air, and the inherently resist oxidation or chemical   operating environment, such as attack in water, air, and the operating    stainless steel, nickel-base alloys, or environment,                               cobalt-base alloys Crevice-Any narrow opening in a            crevice - a narrow opening in a         OK surface or any open juncture between      surface or an open juncture between mating surfaces in which                   mating surfaces in which solutions or solutions can be trapped and not           contaminants can be trapped and not readily removed during rinsing or          readily removed during rinsing or flushing operations; for example, the     flushing operations (for example, the annular spaces in threaded                annular spaces in threaded connections and socket assemblies,         connections and socket assemblies, tube-to-tube sheet joints, and tube-to-   tube-to-tube sheet joints, and tube-to-tube support joints.                      tube support Dead Leg-Any area that does not            dead leg - an area that does not        OK have flow during the cleaning              have flow during the cleaning operation or which cannot be drained       operation or that cannot be drained without special provisions,                without special provisions Documentation-Any written or               Section 1 "Introduction"                This definition not included in NQA-1 pictorial information describing,                                                  Subpart 2.1, but rather in Section 1 defining, specifying, reporting, or        document - any written or pictorial certifying activities, requirements,,      information describing, defining, procedures or results.                     specifying, reporting, or certifying activities, requirements, procedures, or results..."
fluid - any gas or liquid               This definition not included in N45.2.1 Flushing-Flowingwater through a            flushing - flowing fluid through a      OK component or system at adequate            component or system at adequate velocity to suspend and carry              velocity to suspend and carry away away anticipated contaminants,             anticipated contaminants Inhibitor-A chemical additive which       inhibitor-- a chemical additive that    OK retards some specific chemical             retards some specific chemical -
reaction,                                  reaction InaccessibleArea-An area or               inaccessible area - an area or          OK opening in an item which is not directly   opening in an item that is not directly accessible for cleaning or inspection,     accessible for cleaning or inspection Item -Any level of unit assembly,         Section 1 "Introduction"                This definition not included in NQA-1 including structure, system,                                                      Subpart 2.1, but rather in Section 1 subsystem, subassembly, component,        item - an all inclusive term used in part or material.                         place of any of the following:
appurtenance, assembly, component, equipment, material, module, part, structure, subassembly, subsystem, system, or unit.
Layup-The protection of an item after     layup - the protection of an item       OK it has been cleaned, to prevent-          after it has been cleaned to prevent corrosion of interior surfaces             corrosion of interior surfaces while while the item is out of service or        the item is out of service or awaiting awaiting subsequent operations,            subsequent operations Mechanical Cleaning-A method in            mechanical cleaning- a method in        OK which contaminant removal is               which contaminant removal is accomplished solely by mechanical          accomplished solely by mechanical means, including wiping, abrasive          means, including wiping, abrasive blasting, brushing, grinding, sanding,     blasting, high pressure water jetting, chipping, etc.                             brushing, sanding, grinding, and 4 of 29                                               7/27/10

Enclosure 4, Table 1 ANSI N45.2.1-1973 vs NQA-1-1994, Subpart 2.1 Pitting- Localized corrosion resulting     pitting - surface defects resulting in surface defects.                        from localized corrosion Purchaser-Theagency responsible             Section 1 "Introduction"                  This definition not included in NQA-1 for issuance administration of a                                                      Subpart 2.1, but rather in Section 1 contract, subcontract, or purchase          Purchaser-The organization order imposing this standard or             responsible for establishment of portions hereof.                            procurement requirements and for issuance or administration, or both, of procurement documents Rinsing-(I) Filling and draining an        rinsing                                    OK item with water until contaminants in      (a) filling and draining an item with the. effluent water are reduced to some    water until soluble contaminants in predetermined concentration, or (2)        the effluent water are reduced to flowing water through the system or        some predetermined concentration; component at low velocity until            or contaminants in the effluent water are     (b) flowing water through the system reduced to some predetermined              or component until water soluble concentration.                             contaminants in the effluent water are reduced to some predetermined concentration Rust-Corrosion products, consisting        rust- corrosion products consisting        OK largely of iron oxide. Such oxides may     largely of iron oxide. Such oxides vary in color from red to black and may    may vary in color from red to black form a loosely adherent heavy              and may form anything from a loosely covering to a tightly adherent light film. adherent heavy covering to a tightly Pitting or general surface roughening      adherent light film. Pitting or general may or may not be present.                 surface roughening may or may not be present.
Sensitized CorrosionResistant Alloy        sensitized corrosion-resistantalloy -      ANSI N45.2.1 includes ASTM A393.
- Any alloy which has been                  a corrosion-resistant alloy that has       NQA-1 refers to the latest document subjected to heating that causes inter-    been subjected to heating that             A262.
granular precipitation of chromium         causes intergranular precipitation of carbides in quantities sufficient to be    chromium car-bides in sufficient detected by methods of ASTM A262-          quantities to be detected by Practice 68, Recommended Practices for              B, C, D, F, or F of ASTM A 262, Detecting Susceptibility to Intergranular  Practices for Detecting Susceptibility Attack in Stainless Steel or ASTM           to Intergranular Attack in Austenitic A393-63, Recommended Practices for          Stainless Steels Conducting Acidified Copper Sulfate Test for Inter-granular Attack in Austentic Stainless Steel.
Solvent Cleaning- Dissolving organic       solvent cleaning.- removing                OK contaminants with an organic solvent,       contaminants with an organic solvent 1.5      Referenced Documents              Section 1 "Introduction                    These words are not included in NQA-1 Subpart 2.1, but rather in the Other documents that are required to        7 Referenced Codes, Standards,             Introduction to Part I1.
be included as part of this standard are    and Specifications either identified at the point of reference or described in Section 10 of     All codes, standards, and this standard. The issue or edition of      specifications that are referenced as the referenced document that is             a part of this Part (Part II)are listed in required will be specified either at the    the Table entitled "Codes, Standards, point of reference or in Section 10 of      and Specifications Referenced in this standard.                              Text." Codes, standards, and specifications referenced in this Part (Part II) may be identified with the applicable date or reference at the point of reference or in the Table "Codes, Standards, and Specifications Referenced in Text.-
Other terms and definitions are                                                        N45.2.10 incorporated into NQA-1.
contained in ANSI N45.2.10
: 2. GENERAL REQUIREMENTS                     2 GENERAL REQUIREMENTS                     ZS retains responsibility for work.
Delegation is covered in QAPP This section contains requirements                                                     Section 2, Quality Responsibilities" 5 of 29                                                    7/27/10

Enclosure 4, Table 1 ANSI N45.2.1-1973 vs NQA-1-1994, Subpart 2.1 LI MM    dl* LU U-  lUlllllCU U    -
uy LI.. UIILl ,,LUI who is responsible for performing any                                                     Sections 4.7.6 Vendor Evaluation.
segment of work described in paragraphs 3 through 9 of this standard.
Cleanness classification for an item            The cleanness classification of each      OK shall be specified in accordance with           item shall be specified in accordance paragraph 3.1 of this standard.                 with para. 3.2 of Subpart 2.1.
The work and quality assurance                  The work and quality assurance            OK requirements for the cleaning of items          requirements for the cleaning of and systems to be incorporated in the           components and systems and for the nuclear power plant and control of              control of their cleanness shall be cleanness thereof shall be established          established in order to:
in order to (1) ensure the removal of any                   (a) ensure the removal of deleterious     OK deleterious contaminants,                 contaminants; (2) minimize recontamination of                 (b) minimize recontamination of           QK cleaned surfaces, and                     cleaned surfaces; and (3) minimize the cleaning required after        (c) minimize the cleaning required        OK installation,                             after installation, repair, or modification.
2.1         Planning                            2.1       Planning                        NQA-1 adds the words (manufacturing, construction, The cleanness and cleanness control             Cleaning and cleanness control            modification, repair, etc.)
activities shall be planned and outlined        activities for each phase to define cleaning and inspection               (manufacturing, construction, operations to be used.                          modification, repair, etc.) shall be planned in accordance with the re-quirements of the Introduction to this Part (Part II).
It shall detail the systematic, sequential     The plan(s) shall define the cleaning     N45.2.1 uses the words "systematic, progression of cleaning operations for          and inspection operations to be used,     sequential progression". This is each item or system, the                        the system, the responsibilities of the   unnecessary detail not included in responsibilities of parties concerned for       parties concerned for each operation,     NQA-1.
each operation, and measures to be              and the measures to be employed to employed to preserve the cleanness of           preserve the cleanness of cleaned cleaned surfaces.                               surfaces.
Planning for cleaning activities shall          Section 1 Introduction                    These words are not included in NQA-include a review of the system and                                                        1 Subpart 2.1, but rather in the component design specifications and             4.1 Planning                              Introduction to Part II drawings and of the construction work plans and schedules to ensure that              Planning shall include a review of the provisions for cleaning have been               structure, system or component incorporated; that they can be                  design/procurement specifications, accomplished as specified; and that             materials, lists, drawings, time and resources are sufficient to            construction work plans, and accomplish the required actions,                schedules to ensure that fabrication, installation, modification, inspection, testing, etc., activities have been incorporated; that the work can be accomplished as specified; and that time and resources, plus training, are sufficient to accomplish the work in accordance with specified requirements This review shall consider the following        In addition, planning shall consider      NQA-1 adds the words "recognizing items as appropriate,                           the following factors, as appropriate,    that this list may not be complete nor recognizing that this list may not be     applicable to each phase covered by complete nor applicable to each           this Part (Part II):"
phase covered by this Part (Part II):
: 1. Adequacy of vents and drains,                (a) adequacy of vents, drains,            OK inspection access points, bypass          inspection access points, and bypass or recirculation lines;                    or recirculation lines;
: 2. Facilities for filters, and flushing         (b) facilities for filters and flushing   OK and/or drain connections, in              and drain connections in locations      I 6 of 29                                                 7/27/10

Enclosure 4, Table 1 ANSI N45.2.1-1973 vs NQA-1 -1994, Subpart 2.1 unavoidable;
: 3. Piping system design-and                        (c) design and installation of piping      OK installation ina manner which                 in a manner that minimizes the minimizes the necessity for                    necessity for installing temporary installation of temporary piping              piping dluring the cleaning operations, dluring the cleaning operations;              such as dividing the system into a (Where possible, divide the                    number of separate cleaning circuits system into a number of separate              to facilitate cleanability; cleaning circuits to facilitate cleaning).
: 4. Sequencing of the installation                   (d) sequencing of installation            N45.2.1 uses the words "crawl operations to provide for visual               operations to provide for visual          through". This is unnecessary detail inspection (crawl through)                     inspection of inside surfaces of large    not included in NQA-1.
of the inside surfaces of large               diameter piping; diameter piping;
: 5. Control of the installation                      (e) control of installation operations    OK operations so that piping and                so that piping and components that components which have already                have already been installed are not been installed are not subject to            subject to contamination when contamination when                           subsequent installation operations subsequent installation operations           are performed; are performed;
: 6. Adequate pumping and heating                     (0 adequacy of pumping and                OK capacities when these are                     heating capacities when these are important factors in the cleaning             important factors in the cleaning op-operations.                                    erations; (g) disposal of cleaning solutions        These words not included in N45.2.1 and waste water;
                                                    ,(h) safety, fire protection, and other   These words not included in N45.2.1 hazards.
2.2 Procedures and Instructions                     2.2 Procedures and Instructions           N45.2.1 includes the word
                                                                                              ",examinations" Cleaning procedures as well as                      Written procedures and instructions procedures or work instructions for                 for cleaning, cleanness control, cleanness control practices and                     inspections, and tests to verify inspections, examinations or tests to               cleanness of items shall be prepared verify cleanness of items shall be                  in accordance with the requirements prepared.                                           of the Introduction to this Part (Part 11).
These documents shall include as                    Section I "Introduction                   These words are not included in NQA-appropriate:                                                                                  1 Subpart 2.1, but rather in the 4.2 Procedures                            Introduction to Part 11- In addition 2 through 11 are also in this Part.
The documents shall include the
__________________________following                as applicable:
: 1. Detailed cleaning-cleanness                      2.2 Procedures and Instructions           OK control procedures Written procedures and instructions for cleaning, cleanness control, inspections, and tests to verify cleanness of items shall be prepared in accordance with the requirements of the Introduction to this Part (Part II)
: 2. Personnel safety considerations                  (a) personnel safety and structure of     OK
__________________________facility              protection considerations
: 3. Structure or facility protection                 (a) personnel safety and structure of     OK consideration                                       facility protection considerations
: 4. Inspection and test equipment                    (h) identification of inspection and      NQA-1 adds the words "and related requirements                                        test equipment and related calibration    calibration requirements including requirements including recalibration      recalibration dates"
_____________________________dates
: 5. Sequence of work activities,                     (d) sequence of activities to be          OK inspections and tests                               followed and steps within a given       I________________
7 of 29                                                 7of 297/27/10

Enclosure 4, Table 1 ANSI N45.2.1-1973 vs NQA-1-1994, Subpart 2.1 a'*tlVILy (i) sequence and frequency of inspection or test
: 6. Sequential steps for a given activity   (d) sequence of activities to be          OK followed and steps withina given activity
: 7. Acceptance criteria including           (j) acceptance criteria and methods       OK methods for verifying cleanness            for verifying
: 8. Preparatory checks                      (e) prerequisites including               OK preparatory checks and inspections
: 9. Approvals                               (I) approvals and authorizing or          OK verifying signatures
: 10. Responsibilities                       (k) responsibility and required           OK qualifications of personnel
: 11. Data report forms                      (n) data or test report forms             NQA-1 also adds "or test" The preparation of the actual working      2.2.2        Preparation of the actual    N45.2.1 uses "should", NQA-1 uses procedures or instructions to be used      cleaning procedures or instructions       "shall" should consider:                           shall consider the following:
: 1. Work practices, housekeeping,           (a) work practices, housekeeping,         OK access control, and prevention of          access control, and prevention of contamination and recontamination;         contamination and recontamination;
: 2. Effectiveness of cleaning               (b) effectiveness of cleaning             OK procedures for removal of the              methods for removal of the contaminants;                              contaminants; (c) effects of residual quantities of     These words not included in N45.2.1 cutting fluids, liquid penetrants, weld fluxes, precleaning solutions, engineering test fluids, and other process compounds that may have been intentionally or advertently ap-plied to the surface of the item during prior steps of manufacture, installation, or use;
: 3. Corrosiveness of cleaning solutions     (d) corrosiveness of cleaning             NQA-1 adds the words "and in contact with the material of an item,   solutions in contact with the material    entrapment of cleaning solutions" particularly in the case of dissimilar     of an item, particularly in the case of metals;                                    dissimilar metals and entrapment of cleaning solutions;
: 4. Chemical composition,                   (e) chemical composition,                 OK concentration, and temperature limits      concentration, and temperature limits of cleaning solutions to avoid             of cleaning solutions to avoid delete-deleterious effects;                        rious effects;
: 5. Proposed solution and metal             (f) solution and metal temperatures,      OK temperatures, solution concentrations,      solution concentrations, velocity, and velocity, and contact times during          contact times during cleaning; cleaning;-
: 6. Methods for monitoring cleaning          (g) methods for monitoring cleaning       OK solution concentration and                  solution concentration, temperatures, temperatures during cleaning                and velocities during cleaning operations;                                 operations;
: 7. Identification of the systems and       (h) identification of the items for       OK subsystems with which the procedures        which the procedures are to be used; are to be used;
: 8. Proposed sequence of operations          (i) sequence of operations and            OK and methods of filling, system              methods of filling system circulation, circulation, draining, and flushing;        draining, and flushing;
: 9. Proposed equipment isolation,             (")(1) equipment isolation               NQA-1 adds: (d) connections for location of temporary piping and                 (2) location of:                     filling, flushing, rinsing, and draining valves, location of strainers and where      (a) temporary piping and valves          equipment possible, the location of temporary          (b) strainers equipment;                                   (c) temporary equipment (d) connections for filling, flushing, rinsing, and draining equipment
: 10. Construction operations prohibited      (k) activities to be prohibited or        OK during cleaning operations;                 constrained before, during, and after   I 8 of29                                                     7/27/10

Enclosure 4, Table 1 ANSI N45.2.1-1973 vs NQA-1-1994, Subpart 2.1
: 11. Methods for rinsing and                (I) methods for rinsing and             NQA-1 adds the word "estimated" neutralizing including number of rinses;   neutralizing, including estimated number of rinses;
: 12. Methods for verifying cleanness;       (m) methods for verifying cleanness;    OK
: 13. Methods of drying and layup of the     (n) methods for drying and layup;       OK system;
: 14. Methods for protecting installed       (o) methods for protecting installed    N45.2.1 states "used", NQA-1 states equipment which are not used in the        items which are not involved in the     "involved" cleaning operations;                       cleaning operation;
: 15. Methods for disposal of cleaning       (p) method of disposal of cleaning      OK solutions;                                 solution.
2.3       Results                          BR 10 "Inspection"                      NQA-1 does not include words "ina suitable test report or data sheet".
Inspection and test results shall be        Inspection results shall be documented in a suitable test report or    documented.
data sheet.
BR 11 "Test Control" Test results shall be documented..."
Each report shall identify the item to    Supplement 1OS-1 "Supplementary         Supplement 11 S-1 contains similar which it applies, the procedures or        Requirements for Inspection"            words to 10IS-1.
instruction followed in performing the task and the identification of the         Paragraph 9                             NQA-1 does not include words "the following:                                                                         procedures or instruction followed in Records shall, as a minimum, identify  performing the task".
(a) through (f) below:
(1) Conditions encountered which           (f) reference to information on action  Slightly different words, but same were not anticipated, including            taken in connection with                intent.
nonconformance.                            nonconformances (2) Identity of inspector or tester.       (c) inspector                           OK (3) Completion date.                       (b) date of inspection                  Slightly different words, but same intent.
Test reports and data sheets shall         (e) results or acceptability            Slightly different words, but same include an evaluation of the                                                     *intent.
acceptability of inspection and test       and 11S-1 "Supplementary results and provide for identifying the    Requirements for Test Control" individual who performed the evaluation.                                Paragraph 5(g) person evaluating test results 2.4 Personnel Qualifications               Introduction                           These words are not included in NQA-1 Subpart 2.1, but rather in the Those personnel who perform                Section 5 "Qualification of            Introduction to Part II. N45.2.1 inspection, examination or testing         Personnel"                             requires qualification in accordance activities required by this standard                                              with N45.2.6, NQA-1 requires shall be qualified in accordance with      Inspection, test, and nondestructive   qualification in accordance with NQA-N45.2.6 Qualifications of Inspection,     examination personnel and               1.
Examination, and Testing Personnel         laboratory technicians shall be for the Construction Phase of Nuclear     trained and qualified/certified in Power Plants.                              accordance with the applicable portions of Part 1, Basic and Supplementary Requirements.
Professional personnel shall meet the requirements defined by the implementing organization in its position descriptions.
2.5       Test Equipment                    Supplement 12S-1 "Supplementary        Slightly different words, but same Requirements for Control of            intent.
2.5.1 Selection.                            Measuring and Test Equipment" Inspection and test equipment used to      Paragraph 2 implement the requirements of this standard shall be selected to have          Selection of measuring and test sufficient accuracy and sensitivity        equipment shall be controlled to 9 of 29                                                 7/27/10

Enclosure 4, Table 1 ANSI N45.2.1-1973 vs NQA-1-1994, Subpart 2.1 assure that such items are of proper specified requirements.                   type, range, accuracy, and tolerance to accomplish the function of determining conformance to specified reauirements.
2.5.2       Calibration and Control.      Supplement 12S-1 "Supplementary         Slightly different words, but same Requirements for Control of             intent.
Test equipment shall be adjusted and      Measuring and Test Equipment" calibrated at prescribed intervals against certified equipment having        Paragraph 3.1 known valid relationships to nationally known standards.                          "Measuring and test equipment shall be calibrated, adjusted and maintained at prescribed intervals or, prior to use, against certified equipment having known valid relationships to nationally recognized standards.
If no national standards exist, the basis Supplement 12S-1 "Supplementary         OK of calibration shall be documented.       Requirements for Control of Measuring and Test Equipment" Paragraph 3.1 If no national recognized standards exists, the bases for calibration shall be documented.
Records' shall be maintained and          Supplement 12S-1 "Supplementary         OK equipment suitably marked to indicate     Requirements for Control of calibration status.                       Measuring and Test Equipment" Paragraph 5 Records shall be maintained and equipment shall be suitably marked to indicate calibration status.
When inspection and testing               Supplement 12S-1 "Supplementary         NQA-1 adds the words "and equipment is found to be out of           Requirements for Control of             documented" calibration, an evaluation shall be       Measuring and Test Equipment" made of the validity of previous inspection or test results and ac-       Paragraph 3.2 ceptability of items previously inspected or tested.                     When measuring and test equipment is found to be out of calibration, an evaluation shall be made and documented of the validity of-previous inspection or test results and of the acceptability of items previously inspected or tested.
2.6     Housekeeping                                                             QAPP Section 4.13, Handling, Storage, and Shipping and Subpart In areas, facilities and environments                                            2.3 "Quality Assurance Requirements where the cleanness controls of this                                              for Housekeeping for Nuclear Power standard are required, the                                                       Plants" establish requirements for housekeeping requirements shall be in                                            housekeeping.
accordance with ANSI N45.2.3, Housekeeping During Construction Phase of Nuclear Power Plants.
2.3 Rectification of Unacceptable       These words not included in N45.2.1 Cleanness If indications of contamination in excess of specified limits are observed at the end of a cleaning operation or at any subsequent inspections for cleanness, the item 10 of 29                                                7/27/10

Enclosure 4, Table 1 ANSI N45.2.1-1973 vs NQA-1-1994, Subpart 2.1 shall be recleaned using an approved procedure. If such indications are observed at the anticipated end of a cleaning operation, continued cleaning shall be performed to reduce the level to the specified limit.
If necessary, an evaluation shall be made to determine the cause of the unacceptable cleanness and the actions required to preclude recurrence.
: 3. CRITERIA FOR CLEANING               3 CLEANNESS CRITERIA                     Guidance only. Wording does not establish requirements.
It is intended that systems that have been cleaned in accordance with this standard should require only water flushing or rinsing as a final cleaning step in preparing them for service.
However, where more than normal                                                    Guidance only. Wording does not water flushing or rinsing is required to                                            establish requirements.
produce the specified cleanness, additional cleaning in accordance with this standard may be necessary.
While this standard is primarily                                                    Guidance only. Wording does not concerned with the cleaning and                                                     establish requirements.
cleanness of internal surfaces, external surface cleanness may be of equal importance in some cases and should be recognized during the cleaning operations.
Internal and external surfaces may        3.1 Different cleanness classes may      OK have different cleaning and cleanness      be assigned to internal and external requirements.                              surfaces, or to different parts of the same item based on the cleanness needs of the specific item.
3.1        Cleanness Classifications       3.1 Cleanness Classification             N45.2.1 uses word "degree", NQA-1 uses "level" - these are equivilent.
The degree of cleanness required is a      The level of cleanness required for function of the particular item under      any particular application is a function consideration.                             of the particular item under Consideration.
The assignment of a cleanness             The assignment of a cleanness             N45.2.1 does not reference "the classification shall consider the,         classification shall consider the        function of the item to be cleaned."
susceptibility to corrosion of the        following:
material, the consequences of             (a) the function of the item to be        NQA-1 adds words "various formsof malfunction or failure of the item and     cleaned;                                 corrosion, including intergranular the probability of contaminants           (b) the susceptibility of its materials   cracking, or stress corrosion cracking contributing to or causing such,          of construction to various forms of       under fabrication, installation, or malfunction or failure,                   corrosion, including intergranular        operating conditions" and "(introduced cracking, or stress corrosion cracking    during fabrication, storage, installation, under fabrication, installation, or      repairs, or service)".
operating conditions; (c) the consequences of malfunction or failure of the item; (d) the possibility of contaminants (introduced during fabrication, storage, installation, repairs, or ser-vice) contributing to or causing such malfunction or failure.
This standard does not establish the                                                Guidance only. Wording does not cleanness classification of any specific                                            establish requirements.
item. However, typical examples are presented as a guide.
The specification for the required                                                  QAPP Section 4.13, Handling, Storing, cleanness class shall be the                                                        and Shipping establishes requirements 11 of 29                                               1 7/27/10

Enclosure 4, Table 1 ANSI N45.2.1-1973 vs NQA-1-1994, Subpart 2.1 The class of cleanness required for       The cleanness class or classes          N45.2.1 states "required for any given any given application shall be specified  applicable to the item or specific      application" whereas NQA-1 states in design drawings or specifications      parts of the item shall be established  "applicable to the item or specific parts associated with the cleaning of items,    and specified in the applicable         of the item" and the method of verification of         drawings, specifications, or other cleanness shall be documented.            appropriate documents.
and (Preparation of the actual cleaning procedures or instructions shall consider the following):
2.2(m) methods for verifying cleanness Four classes of surface cleanness       These words not included in N45.2.1 (Classes A, B, C, and D) with criteria for each are provided in Subpart 2.1.
Guidelines for assigning cleanness classifications are listed in Part III, Subpart 3.2, Appendix 2.1.
NOTE                                                                              Guidance only. Wording does not establish requirements.
The following cleanness classifications are not directly related to component classifications assigned by the ASME Boiler and Pressure Vessel Code for design and inspection or for other purposes.
3.1.1 Class A-A very high level of        3.2      Cleanness Class Criteria       NQA-1 includes more detail in cleanness in which there is no                                                    referencing ASTM A380.
evidence of contamination of a surface    3.2.1 Class A. A very high level of either under visual examination, with or  cleanness as evidenced by the without magnification, or with the aid of freedom from all types of surface sensitive detection methods.              contamination, according to the acceptance criteria of the inspection methods specified in the procedures required by para. 2.2.1. If close control of particulate contamination is required, a clean room, in accor-dance with para. 8.5.5 of ASTM A 380-78, Practice for Cleaning and Descaling Stainless Steel Parts, Equipment, and Systems, shall be employed during the manufacturing, assembly, and installation operations when particulate contamination could occur. Gross and precision inspection methods applicable to Class A are described in paras. 7.2 and 7.3 of ASTM A 380-78; other special tests shall be specified as necessary.
Where the cleanness of internal surfaces is evaluated by flushing, criteria shall be specified in the cleaning procedure.
Class A cleanness applies to special                                             Guidance only. Wording does not items such as fuel elements, control                                             establish requirements.
rod drive mechanisms, delicate instruments, and other dose tolerances or carefully controlled surfaces or assemblies.
Such items should receive, their                                                  Guidance only. Wording does not 12 of 29                                                 7/27/10

Enclosure 4, Table 1 ANSI N45.2.1-1973 vs NQA-1-1994, Subpart 2.1 1IV'4 U11VU  IV VVI V I &#xfd;IV.COIIICC 1 -0a  LIIV FUI IL of manufacture and cleanness must be m~int~inor{    nt thn r'nnctri r~tinn *ito For these reasons, requirements of                                                         Guidance only. Wording does not this level of cleanness are considered                                                      establish requirements.
to be outside of the scope of this document.
3.1.2 Class B-A high level of                       3.2.2 Class B - A high level of         NQA-1 does not include the examples cleanness applicable to reactor coolant             cleanness as evidenced by the           given in N45.2.1.
systems, components, and other                     following characteristics items, such as the reactor coolant purification system, which have similar cleanness requirements.
Piping and components in systems                    3.2.2 Class B. A high level of          NQA-1 does not include the words which are designed as requiring Class               cleanness as evidenced by the           "piping and component in systems" B cleanness shall meet the following               following characteristics.
requirements:
: 1. The surface shall appear "metal                (a) Corrosion-ResistantAlloys            NQA-1 includes more detail in clean" when examined without                         (1) The surface shall appear metal     referencing ASTM A380.
magnification under a lighting level                 clean and free of organic films and (background plus supplementary                       contaminants when examined in lighting) of at least 100 foot candles.              accordance with para.,7.2.1 of Scattered areas of rust are permissible              ASTM A 380-78, Practice for provided         the aggregate area of               Cleaning and Descaling Stainless rust does not exceed 2 square inches                 Steel Parts, Equipment, and in any one square foot area.                         Systems, except light deposits of atmospheric dust are permissible and shall show no evidence of deleterious contamination when subjected to the wipe test of para.
7.2.2 of ASTM A 380-78.
Scattered areas of rust are permissible, provided the aggregate area does not exceed 2 sq in. in any 2             2 1 sq ft area (14 cm per 1000 cm ).
Temper films and discolorations re-sulting from welding are acceptable.
(b) Carbon and Low Alloy Steels (1) The surface shall appear metal clean when examined in accordance with para. 7.2.1 of ASTM A 380-78, except light deposits of atmospheric dust are permissible, and shall show no deleterious contamination when subjected to the wipe test of para.
7.2.2 of ASTM A 380-78. Wipe tests shall be made prior to the application of any preservative film (some type of protective film may be required in order to maintain a clean carbon or low alloy steel surface at Class 8 level).
Scattered areas of rust are permissible, provided the aggregate area does not exceed 2 sq in. in any 2             2 I 1 s5 ft area (14 cm per 1000 cm ). I NOTE                                                                                        Guidance only. Wording does not establish requirements.
Localized rusting may indicate pitting of the surface and should be evaluated metallurgically). Thin temper films resulting from welding or post-weld 13 of 29                                              7/27/10

Enclosure 4, Table 1 ANSI N45.2.1-1973 vs NQA-1-1994, Subpart 2.1
: 2.          The surface shall be free or    (a) Corrosion-ResistantAlloys              Different words but same intent on particulate contaminants such as sand,       (1) The surface shall appear metal       .cleanness.
metal chips, weld slag, etc.                        clean (b) Carbon and Low Alloy Steels (1) The surface shall appear metal clean
: 3.          The surface shall be free of    (a)Corrosion-ResistantAlloys               N45.2.1 provides examples otherwise organic films and contaminants such          (1) The surface shall appear metal        same.
as oils, paint, and preservatives as                clean and free of organic films determined by a visual examination or               and contaminants when an organic solvent-dampened white                   examined in accordance with cloth or an equivalent alternate                    para. 7.2.1 of ASTM A 380-78, method.                                             Practice for Cleaning and Descaling Stainless Steel Parts, Equipment, and Systems (b) Carbonand Low Alloy Steels (1) The surface shall appear metal clean when examined in accordance with para. 7.2.1 of ASTM A 380-78,
: 4.          When a visual inspection is      3.2.2(a). When visual inspection is       Wording between N45.2.1 and NQA-1 not possible and the surfaces are            impossible but surfaces are               is somewhat different. Detail method accessible, a dry white-cloth wipe,          accessible for wipe tests, sufficient     information in N45.2.1 covered by followed by a solvent-dampened white-        wipe tests in different areas of.the      specific NQA-1 reference to ASTM cloth wipe, may be used to evaluate          item shall be made to evaluate the        380-78 Paragraph 7.2.2.
the cleanness of the surface.                general cleanness level of the surface.
3.2.2(b). When visual inspection is impossible, but surfaces are accessible for a wipe test, sufficient
                                            .wipes of different areas of the item shall be made to evaluate the general cleanness of the surface.
If either cloth exhibits indications of      2.3 If indications of contaminations in   N45.2.1 also allows for determination contamination, the system shall either       excess of specified limits are            and evaluation.
be recleaned or the specific                 observed at the end of a cleaning contaminant shall be determined and          operation or at any subsequent evaluated as to its potential deleterious    inspections for cleanness, the item effect,                                      shall be recleaned using an approved procedure.
: 5.           If flushing is the only        (a) Corrosion-ResistantAlloys              The words "and the item flushed with practical means for determining                (2) If flushing is the only practical   water or other fluid meeting the system cleanliness, the system shall           means for evaluating the cleanness      requirements of paragraph 3.4" are not be evaluated by examining a 20-mesh            of internal surfaces, a 20-mesh (850    included in N45.2.1.
(ASTM Eli 1-70, Specifications for             mm, ASTM E 11, Specification for Wire Cloth Sieves for Testing                  Wire Filter Cloth Sieves for Testing    The note is not included in N45.2.1.
Purposes) or finer filter, or the              Purposes) or finer filter (or the equivalent, installed on the outlet of the     equivalent) shall be installed and the cleaning circuit.                              item flushed with water or other fluid meeting the requirements of para.
3.4.
(b) Carbon andLow Alloy Steels (2) If flushing is the only practical means for evaluating the cleanness of internal surfaces,.a 20 mesh (850 mm, ASTM E 11, Specification for Wire Cloth Sieves for Testing Purposes) or finer filter (or the equivalent) shall be installed and the 14 of 29                                                  7/27/10

Enclosure 4, Table 1 ANSI N45.2.1-1973 vs NQA-1 -1994, Subpart 2.1 IRUM11IiUWMIIIU W1UI wVOLCI UI ULI CI IJUIU meeting the requirements of para.
3.4.
NOTE: class B cleanness should be specified for carbon steel and low alloy steel surfaces only in special cases because of the difficulty in maintaining such surfaces in that condition after they have been cleaned.
The system shall be flushed at its         3.2.2(a) The item shall be flushed at       NQA-1 includes some additional normal design velocity (or other           the design velocity (or other flow          details "(as specified in the procedure velocity if specified by procurement       velocity if specified in the procedure)     in qualitative or quantitative terms,
*documents) until the screen shows no      until the screen shows no more than         such as the number of particles per more than slight particle speckling and    slight speckling (as specified in the       unit surface area of the screen)"..
no more than slight rust staining.         procedure in qualitative or quantitative terms, such as the number of particles per unit surface area of the screen) and no more than slight rust staining.
3.2.2(b) The item shall be flushed at the design velocity (or other flow velocity if specified in the procedure) until the screen shows no more than slight speckling (as specified in the procedure in qualitative or quan-titative terms, such as the number of particles per unit area of the screen) and no more than sliaht rust staininQ.
There shall be no particles larger than    3.2.2(a) There shall be no particles       Slight difference in description of 1/32 inch in any dimension, except fine    larger than 1/32 in. X 1/16 in. long       allowable particles. (1/32 inches in any hairline slivers of less than 1/32 inch    (0.8 mm x 1.6 mm).                         dimension v 1/32 X 1/16) thickness are permissible up to 1/16 inch long.                                 3.2.2(b) There shall be no particles larger than 1/32 in. X 1/16 in. long (0.8 mm x 1.6 mm).
There shall be no evidence of organic      3.2.2(a) In water flushed systems           OK contamination in the effluent water or     there shall be no visual evidence of on the filter.                             contamination (e.g., oil, discoloration) of the effluent flush water or screen.
3.2.2(b) In water flushed systems there shall be no visual evidence of contamination (e.g., oil, discoloration) of the effluent flush water or screen.
3.1.3 Class C-An intermediate level        3.2.3 Class C. An intermediate level        N45.2.1 includes a generally of cleanness generally applicable to       of cleanness in which the surfaces          applicable statement.
closed service-water systems that cool     meet the requirements for Class B components containing reactor              except:                                     Guidance only. Wording does not coolant, engineered safety systems,                                                   establish requirements.
and other high integrity systems.
Surfaces shall meet the requirements for Class B cleanness, except:
: 1.         Thin uniform rust films are    (b) Carbonand Low Alloy Steels.             NQA-1 adds the words "can be acceptable on carbon steel surfaces.       A uniform light rust bloom which can        removed by brushing or wiring" be removed by brushing or wiping is acceptable.
: 2.          Scattered areas of rust are    (a) Corrosion-ResistantAlloys.              NQA-1 adds the word "aggregate".
permissible provided that the area of      Scattered areas of rust are rust does not exceed 15 square inches      permissible, provided the aggregate in any 1square foot on corrosion           area does not exceed 15 sq in. per 1 2               2 resistant alloys.                          sq ft area (100 cm per 1000 cm ).
15 of 29                                                     7/27/10

Enclosure 4, Table 1 ANSI N45.2.1-1973 vs NQA-1-1994, Subpart 2.1
: 0.                                  i0y FIUcII-LUMVL IIILVI&#xfd; 11   C.     (c) Corrosion-ResistantAlloys considerable rust staining.                    and Carbonand Low Alloy Steels.           parenthesis.
Screens installed for evaluation of internal surfaces by flushing may exhibit considerable particle speckling (as specified in the procedures in qualitative or quantitative terms, such as the number of particles~per unit area of the screen) and considerable rust staining.
3.1.4 Class D-The level of cleanness           3.2.4 Class D. A nominal level of         N45.2.1 includes a generally applicable to fire-protection, open            cleanness in which the following are      applicable statement.
service water, and similar systems             acceptable:
requiring only a nominal degree of                                                       Guidance only. Wording does not cleanness. The following are                                                             establish requirements.
acceptable on items which meet Class D cleanness:-
: 1. Tightly adherent mill scale on              (b) tightly adherent mill scale on        NQA-1 adds the words "and low alloy carbon steel surfaces.                         nonmachined carbon and low alloy          steel surfaces" steel surfaces that resist removal by hand scrubbing with a stiff wire brush;
: 2. Paint or preservative coatings on           (c) paint or preservative coatings on     NQA-1 adds the words "or low alloy carbon steel surfaces that will not peel       carbon or low alloy steel surfaces        steel surfaces" or flake when exposed to cold-water            that will not peel or flake when flushing.                                      subjected to cold water flushing;
: 3. Rust films on carbon steel and              (a) rust films on both corrosion-         N45.2.1 includes the words "that resist stainless steel surfaces that resist           resistant alloys and carbon and low       removal by scrubbing with a bristle removal by scrubbing with a bristle            alloy steel surfaces;                     brush."
brush.
: 4. If flushing is the only practical           (d) particles no larger than 1/16 in. x   Words are different, but intent is same.
means of determining system                    1/8 in. long (1.6 mm x 3.2 mm) on a cleanness, the system shall be                 14-mesh (1.4 mm, ASTM E 11), or evaluated by examining a 14-mesh               finer filter (or the equivalent).
(ASTM El 1-70, Specification for Wire Cloth Sieves for Testing Purposes) or fine filter, or the equivalent, installed on the outlet of the cleaning circuit.
The system shall be flushed at its                                                       These words not included in NQA-1 normal velocity until the screen shows no more than occasional particle speckling.
There shall be no particles larger than        (d) particles no larger than 1/16 in. x   N45.2.1 states no particles shall be 1/16 inch in any dimension, except             1/8 in. long (1.6 mm x 3.2 mm) on a       larger than 1/16 inch in any direction -
hairlike slivers of less than 1/16 inch        14-mesh (1.4 mm, ASTM E 11), or           NQA-1 allows for 1/16 inch X 1/8 inch thickness are permissible up to 1/8            finer filter (or the equivalent),         long.
inch long.
There shall be no evidence of organic                                                    These words not included in NQA-1 contamination on the screen; con-siderable rust-staining is acceptable.
3.2.5 Summary                             These words not included in N45.2.1 The cleanness classes are summa-rized in Table 3.2 of Subpart 2.1.
3.3     Hydraulic, Instrument             These words not included in N45.2.1 Control, and Lubrication Lines and Systems The preceding cleanness classifications and criteria in para. 3.2 16 of 29                                                7/27/10

Enclosure 4, Table 1 ANSI N45.2.1-1973 vs NQA-1-1994, Subpart 2.1
    ,  ANSI N45.2.1-1 973                 NQA-1 (194 Subpart 2.1                           Comments<
(except where noted)               (NOTE: OKsigmfies,*idntia[ior are primarily applicable to relatively large items which are generally amenable to visual inspection of internal surfaces at some time during manufacture and installation operations. Interior surfaces of hydraulic, instrument control, and lubrication systems are generally not accessible for visual inspection dur-ing manufacture and installation, and may have much more stringent requirements on particulate contami-nation than those specified in the preceding cleanness classes. Where special characteristics and specific requirements are needed for such systems, they shall be specified.
Guidelines for classifying hydraulic, instrument, and lubrication cleanness are presented in Part Ill, Subpart 3.2, Appendix 2.1.
3.4         Cleaning and Flushing       These words not included in N45.2.1 Fluid Quality Requirements 3.4.2 Gaseous Fluids. The requirements for gaseous fluids used for flushing are dependent upon the particular item being flushed. The requirements for any given item shall incorporate restrictions on particulate contaminants, organic contaminants, water soluble contaminants, and water content as appropriate for the item.
3.4.3 Organic Fluids.
Requirements for organic fluids used for flushing are dependent upon the particular item being flushed. The requirements for any given item shall incorporate restrictions on particulate contaminants, water soluble contaminants, and water content as appropriate for the item.
3.4.4 Fluids for Hydraulic, Instrument Control, and Lubrication Systems. In addition to the requirements of para. 3.4.1, 3.4.2, or 3.4.3, as applicable for the system being flushed, fluids used for final flushing or rinsing of components and installed systems covered by this paragraph shall 3.2    Water Quality Requirements        3.4.1 Water. The water quality for      NQA-1 goes into greater detail.
mixing cleaning solutions, rinsing, The selection of the water quality for a and flushing shall be specified by the specific application shall be made by    organization responsible for cleaning the organization responsible for the     unless otherwise stipulated in cleaning operations unless otherwise     procurement documents or approved specified in the purchase document.      procedures. Table 3.4.1 lists water quality requirements commonly used for such purposes in nuclear cleaning operations. When fresh Water is used on components or systems 17 of 29                                               7/27/10

Enclosure 4, Table 1 ANSI N45.2.1-1973 vs NQA-1-1994, Subpart 2.1 attention shall be given to methods for minimizing the possible effects of chlorides meet the particulate contamination limits specified in Table 3.4.4 for the system class soecified.
In cases where the water quality for       4(d) The quality of fluid used for final Words are different, but intent is same.
operating systems is lower than that       flushing or rinsing shall be equivalent specified below (e.g., open service        to the quality of the operational fluid water systems), the water used for         of the item, unless otherwise cleaning can be equivalent to the          specified in approved procedures.
quality of the operating system water.
When cleaning water quality is not         4(d) The quality of fluid used for final Words are different, but intent is same.
otherwise specified, it shall comply       flushing or rinsing shall be equivalent with the following specifications.         to the quality of the operational fluid of the item, unless otherwise specified in approved procedures.
Fresh Water                                TABLE 3.4.1                              Chloride allowance is larger in NQA-1 WATER REQUIREMENTS                       (250 v 100ppm)
Fresh water shall meet the following requirements:                               Fresh water shall meet the following    Turbidity not mentioned in NQA-1 requirements:
pH at 25 C (77 F)            5.5 to 8 pH at 25 C (77 F)             5.5 to 8 Chloride         Less than 100 ppmn Chloride         Less than 250 ppm Fluoride         Less than 5 ppm Fluoride        Less than 5 ppm Sulfide          Less than 1 ppm Sulfide         Less than 1 ppm Total Dissolved Solids Less than 500 ppm          Total Dissolved Solids Less than 500 ppm Turbidity Less than 5 Jackson Turbidity Units Demineralized Water                        TABLE 3.4.1                              N45.2.1 references turbidity, NQA-1 WATER REQUIREMENTS                       references total suspended solids.
Demineralized water shall meet the                                                  This is equivalent.
following requirements:                     High quality water shall meet the following requirements:
ph at 25 C(77 F)           5.5    to 8 ph at 25 C (77 F)           5.5   to 8 Chloride            Less than I ppm Chloride           Less than 1 ppm Fluoride            Less than 1 ppm Fluoride          Less than 1 ppm Sulfide             Less than 1 ppm Sulfide           Less than 1 ppm Conductivity        Less than 3 micromho/cm                          Conductivity       Less than 3 micromho/cm Silica          Less than 0.05 ppm Silica            Less than 0.05 ppm Turbidity Less than 1 Jackson Turbidity Unit         Total suspended solids
                                                               . Less than 3ppm 3.4.6 The use of contaminated tools     These words not included in N45.2.1 shall be avoided. Tools Which contain, or which may become contaminated with, materials that could contribute to stress-corrosion or intergranular cracking shall not be used on corrosion-resistant alloys.
: 4.           PRE-INSTALLATION              5 CLEANNESS PRIOR TO                     Words are slightly different, but intent 18 of 29                                                  7/27/10

Enclosure 4, Table 1 ANSI N45.2.1-1973 vs NQA-1-1994, Subpart 2.1 From a cleanness standpoint, Items should not be delivered to the consideration shall be given as to point of installation site sooner than     whether items should be delivered to necessary unless the installation the point of installation sooner than location is considered a better storage    necessary, i.e., whether the area.                                      installation location is a better storage area [see Subpart 2.2 of this Part (Pz~rt hI*
Inspections, examinations, and tests       Inspections and tests, as appropriate,  OK as appropriate shall be performed          shall be made immediately prior to immediately prior to installation to       installation to determine the determine the'cleanness of the item.       cleanness of the item.
If contaminants are detected, they          If potentially harmful contaminants    NQA-1 adds the words "potentially shall be removed if it is judged that      are detected, they shall be removed if  harmful" they will not be removed in subsequent     they will not be removed in cleaning operations.                       subsequent cleaning operations.
Items having surfaces to which              Items having surfaces to which         OK temporary paint or preservative            temporary paint or preservative coatings have been applied shall be        coatings have been applied shall be identified, the composition of the          identified; the composition of the coating and methods for its removal         coating and methods for its removal shall be determined and removal of          shall be determined and removal of coatings, where required, recorded in       coatings, when required, recorded in the inspection report.                     the inspection report.
Unless otherwise required by the job        Unless otherwise required by the job   OK specifications, the temporary coatings      specifications, the temporary shall be removed prior to installation of   coatings shall be removed prior to items.                                      installation of items.
: 5.        INSTALLATION CLEANING             6 CLEANNESS DURING                     OK INSTALLATION The installation process represents an opportunity for the introduction of         The installation process represents contaminants into a cleaned item and        an opportunity for the introduction of care should be taken to minimize            contaminants into a 'cleaned item, contamination. Operations which             and care shall be taken to minimize generate particulate matter, such as        contamination. Operations that grinding and welding, should be con-        generate particulate matter, such as trolled.                                    grinding and welding, shall be controlled.
Local cleanup of contaminated areas is     Cleanup of locally contaminated        OK recommended as installation                 areas as installation progresses is progresses, rather than one cleanup        recommended (rather than one operation when installation is              cleanup operation when installation is completed.                                 completed).
Consideration should be given to           Consideration shall be given to        OK sequencing installation and erection       sequencing of installation and operations, when practical, to facilitate   erection operations to facilitate cleaning and cleanness control.            cleaning, cleanness control, and inspection.
Where visual inspection of internal        Insofar as practicable, internal       NQA-1 adds the words "insofar as surfaces of a portion of a system can      surfaces of a portion of a system that practicable" and "obscured by be blocked, that part of the system        can be blocked or obscured by          subsequent operations" should be fabricated as a complete         subsequent operations shall be unit and a visual inspection should be     visually inspected and verified as performed just before the access           being clean before the access points points are closed,                         are closed.
Openings and pipe ends shall~be            Openings and pipe ends shall be        OK sealed at all times except when they       sealed at all times except when they must be unsealed to carry out              must be unsealed to carry out necessary operations.                      necessary operations.
Fitted and tack-welded joints (which                                              These words not included in NOA-1 will not beimmediately sealed by welding) shall be wrapped with polyethylene or other nonhalogenated 19 of 29                                            7/27/10

Enclosure 4, Table 1 ANSI N45.2.1-1973 vs NQA-1-1994, Subpart 2.1 Dleted.
Precautions shall be taken to avoid      Precautions shall be taken to avoid      N45.2.1 states "inaccessible areas" contamination of crevices, blind holes,  contamination of crevices, blind         whereas NQA-1 states "accessible dead legs, undrainable cavities, and     holes, dead legs, undrainable cavi-      areas".
inaccessible areas.                      ties, and accessible areas.
When grinding, sanding, chipping or      When grinding, sanding, chipping, or     OK wire brushing, the item shall be so       wire brushing, the item shall be so oriented that chips fall away from the   oriented that chips fall away from the openings or covers shall be provided     openings, or covers shall be provided for the openings.                         for the openings.
Marking materials containing sulfur,     4 MANUFACTURING PHASE                    NQA-1 includes more detail. Different lead, zinc, mercury and other low         CLEANNESS                               words, but same intent.
melting alloys as a basic chemical constituent shall not be brought into     (b) Cleaning methods and materials contact or shall not be used on the       used during manufacture shall be surfaces of corrosion resistant alloys,   compatible with the materials of construction of the item being cleaned (see para. 2.2.2). Cutting fluids; lubricants, liquid penetrants, marking materials, precleaning solutions, engineering test fluids, tools, and other materials and process compounds to be used on surfaces of items made from austenitic stainless steel or corrosion-resistant alloy during manufacture shall be evaluated from the stand-point of potentially harmful contaminants. Such contaminants include chlorides, fluorides, and low melting point materials such as sulfur, lead, zinc, copper, and mercury. Where potentially harmful quantities of such contaminants can be leached or are in a form that they could be released by breakdown of the compound during subsequent manufacturing, installation, or operation, they shall not be used.
Low-sulfur, low fluorine, and/or low-     The use of mineral acids and organic     Wording is different but overall intent is chlorine compounds may be used on         acids to clean austenitic stainless      similar.
austenitic stainless steels. Low-sulfur,  steel and nickel alloys shall be low lead compounds may be used on         evaluated and approved prior to use.
nickel-base alloys.
Paints, chalk and other temporary         (b) ... Paint, chalk, scribing inks, and N45.2.1 is more specific in how they marking materials shall be removed by     other temporary marking materials        shall be removed.
solvent-wiping or mechanical means.       shall be removed from the affected surfaces prior to heat treatment or welding.
Surfaces should be cleaned after          Surfaces shall be visually inspected     OK completion of work on them, before        upon completion of work on them, proceeding to the next installation or    and obvious contamination removed construction step.                        before proceeding to the next installation or construction step.
The use of mineral acids and organic      The use of cleaning methods and          Wording is different but intent is same.
acids on austenitic stainless steels and  materials, cutting fluids, lubricants, nickel alloys should be avoided except    liquid penetrants, marking materials, when the material is in the solution      precleaning solutions, engineering annealed condition.                       test fluids, tools, and other materials and process compounds used during installation of items made from austenitic stainless steel or other corrosion-resistant alloys shall be subject to the limitations on such methods and materials specified in 20 of 29                                                 7/27/10

Enclosure 4, Table 1 ANSI N45.2.1-1973 vs NQA-1-1994, Subpart 2.1 Section 4.
Pre-cleaning and post-cleaning of weld  Precleaning and post-cleaning of           OK joint areas and welds shall be          weld joint areas and welds shall be performed by wire brushing and          performed by wire brushing and scrubbing with a solvent-moistened      scrubbing with a solvent-moistened clean cloth unless specified otherwise  clean cloth unless otherwise specified.
Large openings, such as the open          These words not included in N45.2.1 reactor vessel, shall be protected against falling and windblown con-taminants.
TABLE 3.4.4                                This table not included in N45.2.1 FLUSHING REQUIREMENTS FOR HYDRAULIC, INSTRUMENT CONTROL, AND LUBRICATION SYSTEMS 4 MANUFACTURING PHASE                      These words not included in N45.2.1 CLEANNESS The cleanness of an item at the point of manufacture is critical to the final cleanness level ultimately attained after installation. Where practicable, the cleanness classification of an item listed in the purchase specification shall be the same as that for final service. The capability of construction site cleaning operations may not be sufficient to upgrade the cleanness level of a complex item since a much wider variety of cleaning facilities and procedures are generally available for use at the manufacturer's shops than are available at the construction sites.
Purchase specifications shall specify the required as shipped cleanness level for the item. Shop cleaning procedures shall be in accordance with para. 2.2, and inspection and test results shall be documented, as appropriate, in accordance with approved procedures.
Listed below are cleaning considerations that are appropriate to all manufacturing operations. Addi-tional information is presented in ASTM A 380-78 where applicable,
                                        *they shall be considered.
(a) Operations which generate chemical or particulate contaminant such as welding and grinding shall be controlled during fabrication steps, after which removal of such contaminants becomes difficult be-cause of limited access. Under such conditions, protection of openings shall be provided to prevent entry of contaminants, especially particulate contaminants. If practical, manufacturing sequence shall be based on considerations related to cleanino of individual items as the 21 of 29                                                 7/27/10

Enclosure 4, Table 1 ANSI N45.2.1-1973 vs NQA-1-1994, Subpart 2.1 IJJI I IJUI IVI K I&#xfd; da Vl I ILJIVU, UI IIV&#xfd;O LIIV component is readily cleanable in its final assembled state.
(c) Use of tools, such as those used for grinding, polishing, filing, deburring, and brushing during man-ufacture shall be controlled when surface contamination of the item from such tools is considered an im-portant factor.
(d) The quality of fluid used for final flushing or rinsing shall be equivalent to the quality of the oper-ational fluid of the item, unless otherwise specified in approved procedures (see para. 3.4.1).
Particular attention shall be paid to flushing of pockets, crevices, or dead legs to assure that cleaning solutions are not trapped in such areas.
(e)Fresh water may be used for mixing oil cleaning solutions and for initial rinsing and flushing when per-mitted by approved procedures.
(f)         The final cleaned item shall be sealed in a dried condition to prevent subsequent recontamination and then packaged in accordance with the requirements established in the orocurement documents.
: 6. MAINTENANCE OF                         7               MAINTENANCE OF                     OK INSTALLATION CLEANNESS                    INSTALLATION CLEANNESS After any isolable system has been        After any isolable item has been installed in a clean condition and        installed in a clean condition, cleanness control measures have           cleanness control measures and been established, access control into     access control shall be established to the system is essential to minimize the   minimize the introduction of introduction of contaminants between      contaminants between the time of the time of system isolation and pre-     system isolation and preoperational operational testing.                      testing.
Access control shall be established to    Control of tools, loose items, and                 Similar words but same intent exclude personnel and contaminants,       access shall be maintained in accordance with applicable requirements.
Where environmental contamination         Where environmental contamination                  N45.2.1 includes the words "which could cause degradation                   could cause degradation of quality,                must be hermetically tight and difficult of quality, seals must be installed       seals shall be installed to prevent                to remove" which must be hermetically tight and      contamination of interior surfaces.
difficult to remove.
Gasketed metal seals with welded                                                             Guidance only. Wording does not metal strap closures, or seal welded                                                         establish requirements.
metal caps are recommended for Class B systems and components.
Items in this condition shall be tagged   Removal shall be only with proper with identifications and instructions for authorization.                                     Similar words, same intent seal removal.
Seals shall be installed in a manner to prevent accidental removal.
If access to a sealed system is           If access to such sealed items is                  OK required, precautions shall be taken to   required, precautions shall be taken prevent introduction of contaminants,     to prevent introduction of contam-inants.
Prior to opening the seals, the           Such precautions include masking                   OK immediate surroundings should be          and tenting of surrounding areas with cleaned to remove solid contaminants      plastic film or tape, cleanup of the 22 of 29                                                     7/27/10

Enclosure 4, Table 1 ANSI N45.2.1-1973 vs NQA-1-1994, Subpart 2.1 WI ILI I IIIlYI IL UU IIILIUUULCU III LIIV     IIIIIIlVI l C U UlIUUI  lullya LU IVIIIUVC system.                                        particulate matter that can be introduced into the opening Personnel entering the system should          ... requiring personnel to wear clean    OK wear clean outer clothing and shoe             outer clothing and shoe covers, etc.
covers.
When the necessary work is                     When the necessary work is               OK completed, the interior surface shall be       completed, the interior surface shall locally cleaned to its original condition     be locally cleaned, if necessary, to its and the system should be resealed.             original condition and the item resealed.
Materials usedfor sealing items          These words not included in N45.2.1 made from austenitic stainless steel or other corrosion-resistant alloys shall be subject to the limitations specified in Section 4
: 7.             PRE-OPERATIONAL                 8 PREOPERATIONAL CLEANING                NQA-1 states "insofar as practicable" CLEANING 8.1 Preparations 7.1 Preparations Insofar as practicable, cleaning and Cleaning and flushing operations shall         flushing operations shall be be scheduled so as to minimize                scheduled so as to minimize interference from other plant                  interference from other plant operations,                                    operations.
Areas in which cleaning operations are         Areas in which cleaning operations       OK being performed shall be isolated to           are being performed shall be isolated the extent that personnel performing           and marked to the extent that other construction phase operations            personnel performing other are aware that the cleaning operations         construction phase operations are are being conducted.                           aware that the cleaning operations are being conducted.
Personnel shall be familiarized with the      Personnel shall be familiarized with     OK intended procedure and associated              the intended procedure and hazards.                                       associated hazards.
Means for communicating shall be               Means for communicating shall be         OK provided between the local areas in           provided between the local areas in which the cleaning is performed and            which the cleaning is performed and any remote areas (e.g., control rooms)         any remote areas (e.g., control that may be related to the cleaning            rooms) that may be related to the operations,                                    cleaning operations.
Loose tools should be attached to              Tools and other loose items in           NQA-1 includes "and other loose either the workman or the exterior of          controlled areas shall be controlled     items" the system with a lanyard.                     as specified in Section 7.
The actual circulating flow path shall         The actual circulating flow path shall   OK be checked for agreement with                  be checked for agreement with specified requirements in regard to            specified requirements with regard to location, position and status of all           location, position, and status of all components.                                    components.
Critical valves, controls and switches         Critical valves, controls, and switches  OK shall be tagged to prevent inadvertent         shall be tagged to prevent actuation during the cleaning                  inadvertent actuation during the operation:                                     cleaning operation.
The interior of all accessible                 The interior of all accessible com-      OK components (e.g., tanks) and large             ponents (i.e., tanks) and large diameter piping shall be inspected for         diameter piping shall be inspected for cleanness; all debris and                      cleanness; all debris and contamination shall be removed,                contamination shall be removed.
Demineralizers, filters, instruments,          Demineralizers, filters, instruments,    OK valve intemals and other items that            valve intemals- and other items that may be damaged by the cleaning                 may be damaged by the cleaning process shall be blanked off, bypassed         process shall be blanked off, or removed,                                    bypassed, or removed.
Protective screens shall be installed on       Protective screens shall be installed    OK the suction side of all pumps and other        on the suction side of all pumps and 23 of 29                                               7/27/10

Enclosure 4, Table 1 ANSI N45.2.1-1973 vs NQA-1-1994, Subpart 2.1 t    -ilIIJVIII ILO LI II 11-y  -   UUJ-1-I. LU     otner components mat may De suo-damage during the cleaning opera-                   ject to damage during the cleaning tinn'*                                              onn.rntinns.
Instrumentation (e.g., pressure                     Instrumentation (e.g., pressure,         OK temperature and flow) shall be used                 differential pressure temperature, and where possible to monitor the cleaning              flow) shall be used as necessary to operations.                                         monitor flushing and recirculatory cleaning operations.
All other permanentlyinstalled                       Instrumentation installed in the         OK instrumentation shall be isolated where            system but not used to monitor the possible.                                          cleaning operations shall be isolated where necessary.
Cleaning should be completed before                 Cleaning of the reactor vessel and       NQA-1 adds the words "of the reactor installation of fuel, reactor vessel                reactor vessel intemals shall be         vessel and reactor vessel intemals" internals and control rods.                         completed before installation of fuel and control rods.
Provisions shall be made to collect                 Provisions shall be made to collect      OK leakage and to protect insulation from              liquid leakage and to prevent wetting being wetted.                                       of insulation.
Where the use of installed plant                    Where the use of installed plant components, such as pumps, may be                   components such as pumps may be affected by the cleaning operations,                affected by the cleaning operations, recommendations           shall  be obtained        recoedatin shall           berotined from the component           manufacturers          recommendations      shall be obtained fromardintheuseof       componentm r        rs.       from the component manufacturers regarding the use of their components.             regarding precautions to be taken for the use of their components.
Procedures used to protect installed               Procedures shall be established to       OK components which are not used in the               protect or isolate installed cleaning operations but which are                  components that could be adversely included in the cleaning circuit should            affected by cleaning or flushing he reviewed,                                       operations.
7.2         Flushing and Cleaning                  8.2 Flushing and Cleaning                N45.2.1 states water flushing, NQA-1 Methods                                Methods                                  uses the term flushing (applicable throughout this section) 7.2.1          Water Flushing. If the              8.2.1 Flushing. If the intended level intended level of cleanness has been               of cleanness has been maintained maintained during erection of the plant,           during erection of the plant, only only water flushing will be required.              flushing or rinsing will normally be required.
The system shall be filled with water of           The system shall be filled with fluid of OK the quality specified and flushed in               the type and quality specified and accordance with approved procedures.               flushed in accordance with approved procedures.
Completion of flushing shall be                    Completion of flushing shall be deter-   OK determined by filter, turbidimetric or.            mined by filter, turbidimetric or chemical analyses. If the final flushes            chemical analysis, or any for removal of particulate contaminants            combination of these, as applicable.
are directed toward the reactor vessel,            If flushes are directed toward the soluble contaminants shall be removed              large components, provisions shall from the system by first flushing away             be made to prevent contaminants from the reactor vessel until a specified          from collecting in areas where they water quality is achieved on the ef-               cannot be removed in subsequent fluent from the system.                            cleaning operations.
At this time, high velocity flushes may            If flushes are directed toward the       OK be made toward the reactor vessel,                 large components, provisions shall be made to prevent contaminants from collecting in areas where they cannot be removed in subsequent cleaning operations.
This procedure is not recommended                                                           Guidance only. Wording does not unless reactor vessel internal surfaces                                                     establish requirements.
are accessible for subsequent me-chanical cleaning and inspection, or unless provisions are made to collect 24 of 29                                                 7/27/10

Enclosure 4, Table 1 ANSI'N45.2.1-1973 vs NQA-1 -1994, Subpart 2.1 V- - tJdL
           -     il I-~   I III -L -A . CI.. IV accessible location within the reactor vessel by filtration or other technique.
After system flushing is completed, but              After system flushing is completed,       OK before system drain, all pockets and                 but before draining, all pockets and dead legs shall be flushed through                   dead legs shall be thoroughly their drain connections.                             flushed.
If conditioned water is used, particular             Where conditioned water is used,         OK attention should be given to assure                  particular attention should be given to that large volumes of solution do not                 assure that large volumes of solvent remain trapped in the system.                        do not remain trapped in the system.
Care shall be taken to assure that                   Provisions shall be made to assure       OK organics do not remain on the                       that organics do not remain on the surfaces.           .surfaces:
A final flush writh demineralized water                                                        Guidance only. Wording does not is desirable, but is not necessarily                                                          establish requirements.
required at this time._________________
The system shall be sealed to prevent                After cleaning, the item shall be         OK the subsequent entry of contamination,                sealed where appropriate to prevent If no further cleaning is required,                 the subsequent entry of contami-system layup may be performed.                        nants. If no further cleaning is required, system layup shall be performed if specified.                  ________________
7.2.2.        Alkaline Cleaning.                      8.2.2 Alkaline Cleaning. Although it     OK is the intent of those involved in Although it shall be the intent of those             erecting the nuclear plant to install involved inerecting the nuclear plant to              piping systems and components in a install piping systems in a clean                     clean condition, this may not be fully condition, this may not be achieved,                 achieved.       I________________
One relatively common source of                      Common sources of organic                 OK organic contamination in piping                       contamination in items are lubrication systems is lubricating oils from, air                oils from air tools, preservative films, tools.                                               and valve lubricants.
When local cleanup is not performed                  When immediate local cleanup is not       OK following grinding operations on                     performed, full item cleaning to internal surfaces of piping welds, full              remove such organic contaminants system cleaning to remove organic                    may be necessary.
contaminants may be necessary._________________
If required the cleaning shall be                    Such cleaning shall be performed          OK performed according to the cleaning                  according to the cleaning procedures procedures established for the                       established for the operation, and the operation and the procedure shall                    procedure shall assure that quantities assure that quantities of organics do                of organic contaminants do not not remain on the surfaces.                          remain on the surfaces.
Alkaline cleaning should consist of the              Alkaline cleaning consists of the         OK circulation of an appropriately heated               circulation of an appropriately heated solution until a selected area or a                  solution until a selected area coupon contaminated with the ex-                     represented by the worst pected contamination is cleaned by the               contamination or a coupon cleaning solution.                                   contaminated with the expected contamination is cleaned by the cleaning solution to the specified cleanness level.
After system cleaning is completed, a                After item cleaning is completed, the     OK flush with water of a quality consistent             item shall be flushed with water of the with the system requirements shall be                specified quality to remove the performed to remove the cleaning                   .cleaning    agents.
agents.
In particular, all pockets and dead legs             In particular, all pockets and dead       OK should be flushed and attention should               legs shall be flushed and attention be given to assure that large volumes               given to assure that large volumes of of solution do not remain in the                     solution do not remain.
system&#xfd; The system should be sealed to                      Where appropriate, the item shall be       O prevent the subsequent entry of                     sealed to prevent subsequent              _________________
25 of 2972/1                                          7/27/10

Enclosure 4, Table 1 ANSI N45.2.1-1973 vs NQA-1-1994, Subpart 2.1 If no further cleaning is required,        If no further cleaning is required,      OK system layup may be performed.             system layup shall be performed, if specified.
Precautions related to the use of          Precautions related to the use of        OK alkaline cleaning solutions are listed in  alkaline cleaning solutions are listed paragraph 7.3.                             in Part Ill, Subpart 3.2, Appendix 2.1.
7.2.3 Chelate Cleaning.                    8.2.3 Chelate Cleaning.                  Guidance only. Wording does not establish requirements.
Chelate cleaning of carbon or low-alloy steel surfaces to remove light corrosion product films is not a required cleaning operation.
If chelating cleaning is used, flushing    Unless it is considered desirable to     OK with water of a quality consistent with    leave a film of chelating agent on the the system requirements should be          surfaces as a protective film, the item performed to remove the chelating          shall be flushed with water of a agents.                                    quality consistent with the item requirements to remove residual chelating agents.
All pockets and dead legs in particular. If chelate cleaning is used, attention   OK should be flushed and attention should     shall be given to all pockets and dead be given to assure that large volumes      legs to ensure that large volumes of of the chelating solution do not remain    solution do not remain in the item.
in the system.
The system should be sealed to             Where appropriate, items shall be        OK prevent the subsequent entry of            sealed to prevent subsequent contaminants. If no further cleaning is    contamination. If no further cleaning required, layup may be performed.          is required, layup shall be performed, if specified.
Precautions related to the use of          Precautions related to the use of        OK chelating agents are listed in             chelating agents are listed in Part III, paragraph 7.3.                             Subpart 3.2, Appendix 2.1.
7.3 Cleaning Precautions                   8.2.2 Alkaline Cleaning                  Similar Words - same intent There are a number of precautions that     Precautions related to the use of.
should be observed during cleaning         alkaline cleaning solutions are listed operations. The following should be        in Part Ill, Subpart 3.2, Appendix 2.1.
considered as appropriate.
: 1.         The addition of a suitable     3.4.1 Water                              Similar words - same intent chloride stress cracking inhibitor is recommended iffresh water flushing of      When fresh water is used on systems containing austenitic stainless    components or systems containing steels is planned.                         austenitic stainless steel, attention shall be given to methods for minimizing the possible effects of chlorides.
: 2.          The use of alkaline cleaning   Part II refers to Appendix 2.1           Similar words - same intent compounds which contain free caustic       "Nonmandatory Guidance on is not recommended on components or        Cleaning of Fluid Systems and systems in which cleaning solutions        Associated Components for may be entrapped. Cleaners based on        Nuclear Power Plants" compounds which produce hydroxylions by hydrolysis, such as tri-   3(a) The use of alkaline cleaning sodium phosphate, are recommended,         compounds that contain free caustic If heavy organic solids are present, the   is not recommended on components addition of an emulsifier and a wetting    or systems in which cleaning agent may be considered,                   solutions may be entrapped.
Cleaners based on compounds that produce alkaline solutions by hydrolysis, such as phosphate compounds, are recommended. If heavy organic contaminants are present, the addition of an emulsifier and a wetting agent should be 26 of 29                                             7/27/10

Enclosure 4, Table 1 ANSI N45.2.1-1973 vs NQA-1 -1994, Subpart 2.1
: 3.          The use of acid-chelating      Part II refers to Appendix 2.1 agents on welded or furnace sensitized     "Nonmandatory Guidance on stainless steels and nickel base alloys    Cleaning of Fluid Systems and is not recommended.                        Associated Components for Nuclear Power Plants" 3(b) The use of acid-chelating agent on welded or furnace sensitized stainless steels and nickel base nilnvt, ic nnf rornmm~nr1~r
: 4.          The use of halogenated         Part II refers to Appendix 2.1            Similar words - same intent organic solvents is not recommended,       "Nonmandatory Guidance on except upon crevice-free, open, freely     Cleaning of Fluid Systems and evaporating surfaces. This recom-          Associated Components for mendation is not intended to prohibit      Nuclear Power Plants" the use of such solvents under other conditions, providing adequate             3(c) The use of halogenated organic removal is assured prior to any            solvents is not recommended, except subsequent operations,                     upon crevice-free, open, freely evaporating surfaces. This recom-mendation is not intended to prohibit the use of such solvents under other conditions, providing adequate removal is assured prior to any subsequent operations.
: 5.           Acid cleaning of installed    3.4.5 If acid cleaning is used,           N45.2.1 includes the words "is not systems is not recommended,                particular attention shall be given to:   recommended" however, if used, particular attention shall be given to:
(a)         Avoiding the entrapment of     (a) avoidance of entrapment of acids      OK acids in the crevices,                     in crevices; (b)         Avoiding contact with either    (b) effects on either welded or          OK welded or furnace sensitized corrosion     sensitized corrosion-resistant alloys resistant alloys, and non-ferrous         and nonferrous materials; materials.
(c)        Complete removal of any        (c) complete removal of any residual      N45.2.1 uses the term "system", NQA-residual acid solution from the system. acid solution from the item;              1 states "item" - these are equivalent.
(d)         Neutralization treatment as a  (d) neutralization treatment followed    OK final operation,                            by thorough rinsing or flushing.
7.4 Control of Cleaning Solutions         2.4          Control of Cleaning          OK Solutions Cleaning solutions should be prepared in accordance with the applicable          Cleaning solutions shall be prepared cleaning procedure and shall be            in accordance with the applicable checked for proper chemical                cleaning procedure and shall be composition and effectiveness of           checked for proper chemical inhibitors (if used).                      composition and effectiveness of inhibitors, if used.
Solution temperatures must be              Solution temperatures shall be           OK maintained and controlled to assure        maintained and controlled to ensure adequate cleaning and to prevent           adequate cleaning and to prevent decomposition and possible damage to       cleaning agent decomposition and the system.                                possible damage to the item.
10 POST-OPERATIONAL                      These words not included in N45.2.1 REPAIRS ANT MODIFICATIONS Subpart 2.1 does not address radioactive decontamination operations that may be required prior to post-operational repairs or system modifications, although some of its    I 27 of 29                                                7/27/10

Enclosure 4, Table 1 ANSI N45.2.1-1973 vs NQA-1-1994, Subpart 2.1 requirements may be applicable to such decontamination operations.
For the purposes of maintenance of cleanness as defined in Subpart 2.1, post-operational repairs or system modifications shall be considered identical to preoperational installation procedures and treated in accordance with Sections 5, 6, and 7.
If system cleaning following repair or modification operations is deemed necessary, such cleaning shall be performed in accordance with Section 8, except that flushes directed toward the reactor vessel shall, to the extent possible, first be preceded with flushes directed away from the reactor vessel until expected contamination is removed and the specified water quality level is achieved. If layup is deemed neces-sary, it shall be performed in accordance with Section 9.
: 8. LAYUP AND POST-LAYUP                   9       LAYUP AND POST-LAYUP             OK CLEANING                                       CLEANING 8.1 Upon completion of pre-operational      Upon completion of preoperational cleaning, unless the system is to be        cleaning, unless the item is to be released for the next series of             released for the next series of operations or tests, the system should      operations or tests, the item shall be be placed in layup condition, if            placed in layup condition by filling required, by filling with dry inert gas,    with dry, contaminant-free inert gas the process fluid that will be used in      or dry air; the process fluid that will the system during operation, water Of       be used in the system during purity equivalent to that used to make      operation; fluid of purity equivalent to up the system, or chemically-               that used to make up the system; conditioned water.                          chemically conditioned fluid; or other specified method.
8.2         Prior to the next series of     Prior to the next series of operations   OK operations or tests residual cleaning       or tests, residual cleaning solutions solutions or layup chemicals shall be       or layup media shall be removed, if removed from the system by flushing,        required, from the item by flushing or or draining and filling until the effluent  by draining and filling until the water from the system meets the pre-        effluent fluid from the item meets the operational test water quality              preoperational test fluid quality re-requirements for the system.                quirements for the system.
: 9. RECORDS                                  11 RECORDS                               N45.2.1 includes "personnel qualification records".
Record copies of completed                  The following shall be prepared:
procedures; reports; personnel                  (a) record copies of procedures; qualification records; test equipment           (b) reports; calibration records, test deviation or          (c) test equipment calibration exception records; inspection and                     records; examination records shall be prepared.           (d) test deviation or exception records; (e) inspection and examination records; (f) other records necessary to document the cleaning and cleanness history of the items during manufacture, shipment, storage, installation, preopera-tional cleaning, modifications, and repairs.
These shall be placed with other            These records shall be retained with     OK 28 of 29                                            7/27/10

Enclosure 4, Table 1 ANSI N45.2.1-1973 vs NQA-1-1 994, Subpart 2.1 I.JIUJML! II WUIUb d: I ",%4UilU Uy WUU,     ULIUI PIIUJ)CI.LI[WIUU  Oi IW,4U1 CL standard, specification, or project          code, standard, specification, or Drocedures.                                  Droject procedures.
Collection, Storage and maintenance          BR1 7 "Quality Assurance Records"       Similar words, same intent.
records shall be in accordance with ANSI N45.2.9.                                Records that furnish documentary evidence of quality shall be specified, prepared, and maintained.
: 10. REVISION OF ANSI                                                             N/A - These words not included in STANDARDS REFERRED TO                                                        NQA-1 nor would they be expected to IN THIS DOCUMENT                                                             be.
When the following standards referred to in this document are superseded by a revision approved by the American National Standards Institute, the revi-sion shall apply.
N45.2       Quality Assurance Program Requirements for Nuclear Power Plants N45.2.3 Housekeeping During the Construction Phase of Nuclear Power Plants Qualification of Inspection, N45.2.6 Qualification of Inspection, Examination, and Testing Personnel for the Construction Phase of Nuclear Power Plants N45.2.9 Requirements for Collection, Storage and Maintenance of Quality Assurance Records
 *N45.2. 10 Terms and Definitions
 *These Standards are being approved by The American National Standards Institute and they should be available in 1973.
29 of 29                                            7/27/10

Enclosure 4, Table 2 ANSI N45.2.2-1972 vs NQA-1-1994, Subpart 2.2 1.1         Scope                         Subpart 2.2 provides amplified requirements for packaging, shipping, This standard defines requirements for    receiving, storage, and handling of packaging, shipping, receiving,           nuclearpower plant items.
storage, and handling of nuclear Dower Dlant items.
These items include the parts of          Part II                                    QAPP Section 1.2 "Scope" structures, systems, and components       Introduction                               establishes applicability.
whose satisfactory performance is required for the plant to operate         The requirements of this Part (Part il) reliably, to prevent accidents that       apply to fabrication, construction, could cause undue risk to the health      modification, repair, maintenance, and and safety of the public, or to mitigate  testing activities that affect the quality the consequences of such accidents if     of structures, systems, and they were to occur.                       components for nuclear facilities.
,The requirements stated herein deal      Part II                                    QAPP Section 1.2 "Scope" with the protection and control           Introduction                               establishes applicability.
necessary to assure that the requisite quality of those important parts of the   The requirements of this Part (Part II) plant are preserved from the time         apply to fabrication, construction, items are fabricated until they are       modification, repair, maintenance, and incorporated in the plant.                testing activities that affect the quality of structures, systems, and components for nuclear facilities.
This standard is intended to be used in   It supplements the requirements of         Slightly different words, but same conjunction with ANSI N45.2, Quality      Part I and shall be used in conjunction    intent.
Assurance Program Requirements for        with applicable Basic and Nuclear Power Plants. The                 Supplementary Sections of Part I when requirements may also be extended to      and to the extent specified by the other appropriate parts of nuclear        organization invoking Subpart 2.2.
power plants when specified in contract documents.
1.2       Applicability                   Part II                                    QAPP Section 1.2 "Scope" Introduction                               establishes applicability.
The requirements of this standard apply to the work of any individual or    These activities include the performing organization that participates in the     function of attaining quality objectives packaging, shipping, receiving,           and verifying that activities affecting storage and handling of items to be       quality have been correctly performed.
incorporated into nuclear power plants as discussed in Subsection 1.1 of this standard.
The extent to which the individual re-    Introduction                               Slightly different words, but same quirements of this standard shall apply                                              intent.
will depend upon the nature and scope     Section 2 "Applicability" of the work to be performed and the importance of the item or service in-     To the extent applicable to the volved.                                   activities being performed, the application of this Part (Part II)or portions thereof, and the provisions of Part 1, Basic and Supplementary Requirements, shall be.specified in written contracts, policies, procedures, or instructions.
The requirements are intended to          BR 13 "Handling, Storage, and              Slightly different words, but same assure that the quality of items is not   Shipping"                                  intent.
degradedas a result of packaging, shipping, receiving, storage, and         Handling, storage, cleaning, handling practices and techniques.        packaging, shipping, and preservation of items shall be controlled to prevent damage or loss and to minimize deterioration.
1.3      Responsibility                   BR 1 "Organization"                        In addition, QAPP Section 2O0"Organization" and 3.0 1 of 39                                                   7/27/10

Enclosure 4, Table 2 ANSI N45.2.2-1972 vs NQA-1 -1994, Subpart 2.2 I ne organization or organizations responsible for establishing the          responsibilities, level of authority, and applicable requirements for the           lines of communication for activities activities covered by this standard       affecting quality shall be documented.
shall be identified and the scope of their responsibilities shall be documented.
The work of establishing practices and    BR 1 "Organization"                        QAPP Section 2.0 "Organization" procedures and providing the                                                         also details delegation and the need resources in terms of personnel,          Section 2.2                                for documenting said function.
equipment and services necessary to implement the requirements of this        The individual(s) or organization(s) standard may be delegated to other        responsible for establishing and organizations and such delegation         executing a quality assurance program also shall be documented.                 under this Standard may delegate any or all of the work to others but shall retain responsibility.
However, it is the responsibility of      Introduction                               Slightly different words, but same each organization performing work                                                    intent.
covered by this standard to comply        Section 3 "Responsibility" with the procedures and instructions issued for the project and to conform     The organization upon which this Part to the requirements of this standard      (Part II), or portions thereof, is invoked applicable to his work.                   shall be responsible for complying with the specified requirements.
The following shall be used as a guide                                               Guidance only. Wording does not in determining those responsibilities                                                establish requirements. (Same for 1-which shall be established and                                                       7 below).
documented:
: 1.       Classification of items (protection level)
: 2.        Packaging design and methods
: 3.        Shipping requirements and methods
: 4.        Receiving requirements and methods
: 5.        Storage requirements and procedures
: 6.        Handling requirements and procedures
: 7.        Records 1.4       Definitions                      1.1    Definitions                        OK The following definitions are provided    The following definitions are provided to assure a uniform understanding of      to assure a uniform understanding of select terms as they are used in this     unique terms as they are used in standard.                                 Subpart 2.2.
Barrier--A flexible material designed     barrier- a flexible material designed      OK to withstand the penetration of water,    to withstand the penetration of water, water vapor, grease, or harmful gases. water vapor, grease, or harmful gases Carrier--The transporting agency.         carrier--the transporting agency           OK Classification- The organization of       classification- the organization of        OK items according to their susceptibility   items according to their susceptibility to damage during shipping, receiving      to damage during shipping, receiving, and storage only. It does not relate to   and storage only. It does not relate to the function of the item in the com-      the function of the item in the pleted system.                            completed system.
Documentation - Any written or            I Introduction                             NQA-1 provides additional details on pictorial information describing,         Section 4 "Terms and Definitions"          when a document is considered a defining, specifying, reporting, or                                                  Quality Assurance Record.
certifying activities, requirements,      Document - any written or pictorial procedures or results..                   information describing, defining, specifying, reporting, or certifying activities, requirements, procedures, or 2 of 39                                                   7/27/10

Enclosure 4, Table 2 ANSI N45.2.2-1972 vs NQA-1 -1994, Subpart 2.2 to be a Quality Assurance Record until it satisfies the definition of a Quality Assurance Record as defined in this Suiplement.
Dynamic Load Test - A test to                    dynamic load test - a test wherein       Different words are used, but. intent is demonstrate the ability of hoisting              designated loads are hoisted, rotated,   same.
equipment to safely handle its rated             or transported through motions and load by exercising the equipment                 accelerations required to simulate through vertical and horizontal                   handling of the intended item movement along its lines of travel, using a load of specified weight.
Handling - The act of physically                                                          No definition of this exists in NQA-1.
moving items by hand or by mechanical machinery, not including transport modes.                                                                          ________________
Item - Any level of unit assembly,               I Introduction                           Definitions are slightly different but including system, subsystem,                      Section 4 "Terms and Definitions"        intent is same.
subassembly, component, part, or material.                                         Item - an all-inclusive term used in place of any of the following:
appurtenance, assembly, component, equipment, material, module, part, structure, subassembly, system, or
_____________________________unit.
Nonconformance - A deficiency in                  I Introduction                          N45.2.2 provides examples.
characteristic, documentation, or                 Section 4 "Terms and Definitions" procedure which renders the quality of an item unacceptable or                           Nonconformance - a deficiency in indeterminate. Examples of                       characteristic, documentation, or nonconformance include: physical de-              procedure that renders the quality of fects, test failures, incorrect or               an item or activity unacceptable or inadequate documentation, and                     indeterminate deviation from prescribed processing, inspection or test procedures.                                                            ________________
Package - The shipping container                                                           No definition of this exists in NQA-1.
plus the contents of the container.
Package Unit - Any assembly of                                                            No definition of this exists in NQA-1.
mechanical and/or electrical components and parts which can be disassembled without destroying the integrity of the individual parts.              _________________________________
Receiving - To take delivery of                  I Introduction                           OK material at the construction site or             Section 4 "Terms and Definitions" other location designated by the purchaser.                                        Receiving - taking delivery of an item
____________________________at           a designated location                ________________
Storage - The act of holding items at            storage - the act of holding items in   OK the construction site or in an area               storage facilities other than its permanent location in the plant.
Storage Facilities - Warehouse or               storage facilities - warehouse, yard,    OK yard area designated and prepared for            or other areas designated and holding of items,                                 prepared for holding of items Transit Carrier (Open) - Trucks,                                                          No definition of this exists in NQA-1.
Trailers, Railroad cars, Barges; Aircraft, or Ships which do not provide protection       of items from the environment.
Transit Carrier (Closed) -Trucks,                                                        No definition of this exists in NQA-1.
Trailers, Railroad cars, Barges, Aircraft or Ships which do provide protection of items from the environment by nature of their inherent design.
Transportation Mode - A method                  transportation mode - a method           OK identified by the conveyance used for          Iidentified -by the conveyance used for 3 of 39                                                 3of397/27/10

Enclosure 4, Table 2 ANSI N45.2.2-1972 vs NQA-1 -1994, Subpart 2.2 u alI  opuIL -LIUII I H IIlll I llU II  ZlUUV*UIIdlIJUILOLIUI I VI ILVI, Hald 1 II IIAU1-1-u any motor vehicles, ships, railroad           any motor vehicles, ships, railroad cars, or aircraft. Each cargo-carrying        cars, or aircraft. Each cargo carrying body (trailer, van, boxcar, etc.) is a        body (trailer, van, boxcar, etc.) is a separate vehicle.                             separate vehicle.
Wrap - A flexible material, formed            wrap - a flexible material formed              OK around the item or package to exclude         around the item or package to exclude dirt and to facilitate handling, marking      dirt and to facilitate handling, marking, or labeling,                                   or labeling Other terms and their definitions are         NQA-1 Introduction contains many of            These words are not in NQA-1 nor contained in ANSI N45.2.10                    the definitions that were in N45.2.10          would they expected to be.
1.5       Referenced Documents                 Introduction                                  Slightly different words, but same intent.
Other documents that are required to          Section 7 "Referenced Codes, be included as a part of this Standard        Standards, and Specifications" are either identified at the point of reference or described in Section 9 of        All codes, standards, and this Standard.                                 specifications that are referenced as a part of this Part (Part II) are listed in the Table entitled "Codes, Standards, and Specifications Referenced in Text."
The issue or edition of the referenced         Codes, standards, and specifications           NQA-1 adds the clarification on what document that is required will be              referenced in this Part (Part II) may be       to do when a specific date or edition specified either at the point of               identified with the applicable date or         is not identified.
reference or in Section 9 of this              reference at the point of reference or standard.                                      in the Table "Codes, Standards, and Specifications Referenced in Text."
Where no specific date or edition is identified, the latest published version shall be used unless contractual documents stipulate otherwise.
: 2. GENERAL REQUIREMENTS                    Introduction                                   Slightly different words but same intent.
This section contains requirements            Section 1 "Purpose" that are to be fulfilled by the organization or organizations re-             This Part (Part II) sets forth the quality sponsible for performing any segment          assurance requirements for the of work described in Sections 3               planning and execution of identified through 8 of this standard.                   tasks during the fabrication, construction, modification, repair, maintenance, and testing of systems, components, and structures for nuclear facilities.
Measures shall be established and             2 GENERAL REQUIREMENTS                          N45.2.2 includes the word implemented for the packaging,                                                                "examinations". Same intent/results.
shipping, receiving, storage and               Measures shall be established and handling of specified items to be             implemented for the packaging, incorporated in the nuclear power             shipping, receiving, storage, and han-plant, and for the inspections, ex-           dling of specified items to be aminations, testing and documentation         incorporated in the nuclear power to verify conformance to specified            plant, and for the inspection, testing, requirements.                                 and documentation to verify conformance to specified re-quirements.
2.1     Planning                               Introduction                                   QAPP Section 1.2, "Scope" provides 2 Applicability                                 for identification of items to which the The specific items to be governed by                                                          QAPP is applied.
this standard shall be identified.            An appropriate Quality Assurance Program, based on the nature and scope of the work.to be performed and the relative importance of the items or services, shall be specified in contractual documents by selective 4 of 39                                                      7/27/10

Enclosure 4, Table 2 ANSI N45.2.2-1972 vs NQA-1-1994, Subpart 2.2 OpIPIII1OL*:IIUI VI  IJULIVI IUI U) r dl I,I L.. .
and Supplemental Requirements, for programmatic activities and of this Part (Part Wifor work oriented activities.
Planning shall take into account the       2.1           Planning and Procedures           Slightly different words, but same need for the preparation and control of                                                    intent.
proceduresand work instructions as         Planning and procedure preparation necessary to comply with specified         shall be in accordance with the.
requirements.                              requirements of the Introduction to this Part (Part II).
Planning shall include a review of the     Introduction                                    NQA-1 provides some additional design specifications and drawings for                                                     details, but the intent is similar.
the items covered by this standard to      Section 4.1 "Planning" assure that packaging, shipping, receiving, storage, and handling           Planning shall include a review of the activities have been incorporated and      structure, system or component that they can be accomplished as           design/procurement specifications, specified.                                 materials, lists, drawings, construction work plans and schedules to ensure that fabrication, installation, modification, inspection, testing, etc.,
activities have been incorporated; that the work can be accomplished as specified; and that time and resources, plus training, are sufficient to accomplish the work in accordance with the specified requirements.
2.2 Procedures and Instructions            Introduction                                    N45.2.2 is more specific, however intent of developing, using, and Procedures and instructions shall be . Section 4.2 "Procedures"                        maintaining procedures is similar.
generated, used, and maintained current; these shall contain sufficient     Installation, inspection, test detail to provide for the listed items     procedures, and work instructions (see Subsection 2.1 of this Standard)      identified during planning shall be a basis for packaging design, shipping     prepared. Preparation and approval of requirements, receiving, storage and       the procedures/instructions shall be in handling procedures, implementation        advance of the need to use the thereof, and inspection, in accordance     documents. The documents shall be with this standard.                        kept current and revised as necessary to assure that the work is performed in accordance with the latest approved information.
2.3 Results                                BR 10 "Inspection"                              NQA-1 does not include words "in a suitable test report or data sheet".
Inspection and test results shall be       Inspection results shall be documented in a suitable test report or    documented.
data sheet.
BR 11 "Test Control" Test results shall be documented..."
Each report shall identify the item to    Supplement 1OS-1 "Supplementary                 Supplement 11S-1 contains similar which it applies, the procedures or        Requirements for Inspection"                    words to 1oS-1.
instruction followed in performing the task and the identification of the         Paragraph 9                                     NQA-1 does not include words "the following:                                                                                 procedures or instruction followed in Records shall, as a minimum, identify           performing the task".
(a) through (f) below:
(1) Conditions encountered which           (f) reference to information on action          Slightly different words, but same were not anticipated, including            taken in connection with                        intent.
nonconformance.                            nonconformances (2) Identity of inspector or tester.       (c) inspector                                   OK (3) Completion date.                       (b) date of inspection                          Slightly different words, but same intent.
Test reports and data sheets shall         (e) results or acceptability                    Slightly different words, but same include an evaluation of the                                                               intent.
acceptability of inspection and test       and 11S-1 Paragraph 5(g) person 5 of 39                                                      7/27/10

Enclosure 4, Table 2 ANSI N45.2.2-1972 vs NQA-1-1994, Subpart 2.2 IWOUIL     -U dl     -IUVIU- IVI lVul IlII individual who performed the
 *u2Ih ,ntinn 2.5 Personnel Qualifications               Introduction                             Slightly different words, but same intent. N45.2.2 uses the words "at the Those personnel who perform                Section 5 "Qualification of              job site".
inspection, examination or testing         Personnel" activities at the job site shall be qualified in accordance with N45.2.6.      Inspection, test, and nondestructive examination personnel and laboratory technicians shall be trained and qualified/certified in accordance with the applicable portions of Part 1, Basic and Supplementary Requirements.
Off-site inspection, examination or        Introduction                             Slightly different words, but same testing shall be audited and monitored                                              intent. NQA-1 does not require that by personnel who are qualified in ac-     Section 5 "Qualification of              auditors be qualified/certified as cordance with N45.2.6.                    Personnel"                               inspectors to monitor offsite inspection, examinations or testing.
Inspection, test, and nondestructive examination personnel and laboratory technicians shall be trained and qualified/certified in accordance with the applicable portions of Part 1, Basic and Supplementary Requirements.
Professional personnel shall meet the requirements defined by the implementing organization in its position descriptions.
2.5 Measuring and Test Equipment          Supplement 12S-1 "Supplementary          Slightly different words, but same Requirements for Control of              intent.
2.5.1 Selection.                          Measuring and Test Equipment" Inspection, examination, and testing      Paragraph 2 equipment utilized to implement the requirements of this standard shall be    Selection of measuring and test selected to have accuracy and             equipment shall be controlled to tolerance sufficient to determine con-    assure that such items are of proper formance to specified requirements.       type, range, accuracy, and tolerance to accomplish the function of determining conformance to specified requirements.
2.5.2 Calibration and Control.            Supplement 12S-1 "Supplementary          Slightly different words, but same Requirements for Control of              intent.
As appropriate, measuring and test        Measuring and Test Equipment" equipment shall be adjusted and calibrated at prescribed intervals        Paragraph 3.1 against certified equipment having known valid relationships to nationally    Measuring and test equipment shall be recognized standards.                      calibrated, adjusted and maintained at prescribed intervals or, prior to use, against certified equipment having known valid relationships to nationally recognized standards.
If no national standards exists, the      Supplement 12S-1 "Supplementary          NQA-1 includes the word basis for calibration shall be            Requirements for Control of              "recognized" documented.                               Measuring and Test Equipment" Paragraph 3.1 If no national recognized standards exists, the bases for calibration shall be documented.
Records shall be maintained and           Supplement 12S-1 "Supplementary          OK equipment suitably marked to indicate     Requirements for Control of calibration status.                       Measuring and Test Equipment"-
6 of 39                                                7/27/10

Enclosure 4, Table 2 ANSI N45.2.2-1972 vs NQA-1 -1994, Subpart 2.2 Paragraph 5 Records shall be maintained and equipment shall be suitably marked to 2.6 Housekeeping                              NQA-11 Subpart 2.3 replaced~ N45.2.3. QAPP Sbction 4.13 "Handling, Storage, and Shipping" establishes In job-site areas, facilities, and                                                    requirements for housekeeping via environments where packaging,                                                         commitment to NQA-1 -1994, Subpart shipping, receiving, storage and                                                      2.3.
handling of items is performed in accordance with the requirements of this standard, the housekeeping requirements shall be in accordance with N45.2.3.
2.7 Classification of Items                  2.2      Classification of Items         OK The requirements for activities covered Requirements are divided into four by this standard (packaging, shipping,       levels with respect to protective receiving, storage and handling) are         measures to prevent damage, de-divided into four levels with respect to     terioration, or contamination of the protective measures to prevent               items based upon the important damage, deterioration or                     physical characteristics, and not upon contamination of the items, based            the important functional characteristics upon the important physical                  of the item with respect to safety, characteristics and not upon the im-         reliability, and operation.
portant functional characteristic of the item with respect to safety, reliability and operation.
It should be recognized, however, that        It should be recognized, however, that  OK within the scope of each level there         within the scope of each level there may be a range of controls and that          may be a range of controls, and that the detailed requirements for an item        the detailed requirements for an item are dependent on the importance of            are dependent on the importance of the item to safety or reliability,            the item to safety reliability.
For example, even though a reactor*          For example, even though a reactor       OK vessel and structural steel are               vessel and structural steel are classified as level 0, the degree of         classified as Level 0, the degree of protection and control over the reactor      protection and control over the reactor vessel should exceed that of the              vessel should exceed that of the structural steel,                             structural steel.
Each of the specific items govemned by Each of the specific items govemned by         OK this procedure (See Subsection 2.1 of         Subpart 2.2 shall be classified into one this standard) shall be classified into       of these four levels by the buyer or the one of these four levels by the buyer         contractor.
or the contractor.
The manufacturer's documented                 The manufacturer's documented            OK standard or minimum requirements              standard or minimum requirements shall be considered when classifying          shall be considered when classifying the items. -the                                     items.
Items, once classified, shall be              Items, once classified at a level, shall OK restricted to the level or higher for         be restricted to that level or a higher each of the packaging, shipping,              level for each of the packaging, receiving, storage and handling opera- shipping, receiving, storage, and han-tions.                                        dling operations.
Items shall not be classified according                                                Implied by statement above.
to the requirements of one level, then packaged, shipped, received, stored or handled according to a level of lower grade.
Any package unit or assembly made             Any package unit or assembly made        OK Up of items of different levels shall be      up of items of different levels shall be classified to the highest level               classified to the highest level designated for any of the respective         designated for any of the respective parts.                                       items.
7 of 3972/1                                         7/27/10

Enclosure 4, Table 2 ANSI N45.2.2-1972 vs NQA-1 -1994, Subpart 2.2 shall be indicated for each part.            shall be indicated for each part.
Items covered by Subpart 2.2 shall be r    A  nrlr +h- frlliroinr In* &#xfd;lI When the unit cannot be physically                                                           These words not included in NQA-1 disassembled, special rules are contained herein.
Items covered by this standard shall         Items covered by Subpart 2.2 shall be           OK be categorized under the following           categorized under the following levels.
levels:
2.7.1 Level A Items classified to level      2.2.1       Level A. Items classified to        N45.2.2 uses the term "gravitational A are those that are exceptionally           Level A are those that are                      (g) forces" whereas NQA-1 uses the sensitive to environmental conditions        exceptionally sensitive to                      term "accelerating forces".
and require special measures for             environmental conditions and require            Similar, Same Intent.
protection from one or more of the           special measures for protection from following effects:                           one or more of the following effects:
(a) temperatures outside required temperatures outside required limits,             limits sudden temperature changes,                 (b) sudden temperature changes humidity and vapors, gravitational (g)      (c) humidity and vapors forces, physical damage and airborne         (d) accelerating forces contamination (e.g. rain, snow, dust,       (e) physical damage dirt, salt spray, fumes).                   (f) airborne contamination (e.g., rain, snow, dust, dirt, salt spray, fumes)
The following shall be used as a guide       Types of items to be categorized                OK for classifying items intended for this    . under this classification level are:
level classification:
(1)       Special electronic equipment       (a) special electronic equipment and            OK and instrumentation,                        instrumentation (2)      Special materials, such as         (b) special materials, such as                  OK chemicals that are sensitive to             chemicals, that are sensitive to environment,                                environment (3)       Special nuclear material (fuel)    (c) special nuclear material and                N45.2.2 uses the term "AEC fuel and sources. The requirements of the        sources. The requirements of the NRC            license" while NQA-1 uses the term
'AEC fuel license and conditions and          fuel license and conditions and of              "NRC fuel license".
other governmental agencies shall be        other governmental agencies shall be            Similar, Same Intent.
met.                                        met.
2.7.2 Level B - Items classified to         2.2.2 Level B. Items classified to Level        N45.2.2 uses the term "gravitational level B are those that are sensitive to     B are those that are sensitive to               (g) forces" whereas NQA-1 uses the environmental conditions and require        environmental conditions and require            term "accelerating forces" measures for protection from the            measures for protection from the                Similar, Same Intent.
effects of temperature extremes,            effects of temperature extremes, humidity and vapors, g forces, physical     humidity and vapors, accelerating damage and airborne contamination           forces, physical damage, and airbome and should not require special              contamination, and do not require protection required for level A items.      special protection required for Level A items.
The following shall be used as a guide      Types of items to be categorized                OK for classifying items intended for this     under this classification level are:
level classification:
(1)      Instrumentation                    (a) instrumentation                             NQA-1 adds the parenthesis (2)      Electrical penetrations            (b) electrical penetrations                     (Welding electrodes hermetically (3)       Batteries                         (c) batteries                                   sealed in metal containers may be (4)       Welding electrode and wire        (d) welding electrode and wire                  stored under conditions described for (5)       Control rod drives.               (Welding electrodes hermetically                Level C, unless other storage (6)       Motor control centers,            sealed in metal containers may be               requirements are specified by the switchgear and control panels     stored under conditions described for           manufacturers.) after (d) and deletes (7)      Motors and generators              Level C, unless other storage                   the word "erection" before (j).
(8)       Precision machined parts           requirements are specified by the (9)      Erection spares, such as           manufacturers.)
gaskets, "0" rings                (e) control rod drives (10)     Air handling filters               (f) motor control centers, switchgear, (11)     Computers                          and control panels (g) motors and generators (h) precision machine parts (i) spares, such as gaskets, 0-rings 8 of 39                                                     7127/10

Enclosure 4, Table 2 ANSI N45.2.2-1972 vs NQA-1-1994, Subpart 2.2 (k) comouters 2.7.3 Level C - Items classified to       2.2.3 Level C. Items classified to       N45.2.2 uses the term "gravitational level C are those that require             Level C are those that require          (g) forces" whereas NQA-1 uses the protection from exposure to the           protection from exposure to the          term "accelerating forces".
environment, airborne contaminants, g     environment, airborne contamination,     Similar, Same Intent.
forces and physical damage.               acceleration forces, and physical Protection from water vapor and           damage. Protection from water vapor condensation is not so important as       and condensation is not as important that for Level B items.                   as for Level B items.
The following shall be used as a guide    Types of items to be categorized         OK for classifying items intended for this   under this classification level are:
level classification.
(1) Pumps                                  (a) pumps                               NQA-1 adds the parenthesis (2) Valves                                (b) valves                               (unjacketed) after instrument cable in (3) Fluid filters                         (c) fluid filters                        (g) and adds (I) fabricated fuel rods (4) Reactor intemals                      (d) reactor intemals                     and assemblies which is not included (5) Compressors                           (e) compressors                          in N45.2.2.
(6) Auxiliary Turbines                    (f0 auxiliary turbines                   Similar, Same Intent.
(7) Instrument cable                      (g) instrument cable (unjacketed)
(8) Refueling equipment                   (h) refueling equipment (9) Thermal insulation                    (i) thermal insulation (10) Fans and blowers                     (j) fans and blowers (11) Cement                               (k) cement (I) fabricated fuel rods and assemblies 2.7.4 Level D - Items classified to       2.2.4 Level D. Items classified to Level NQA-1 adds the words "acceleration level D are those that are less            D are those that are less sensitive to  forces" as what an item requires sensitive to the environment than level   the environment than those for Level     protection from.
C. These items require protection         C. These items require protection        Similar, Same Intent.
against the elements airbom               against the weather, acceleration contamination, and physical damage.       forces, airborne contamination, and physical damage.
The following shall be used as a guide    Types of items to be categorized         OK for classifying items intended for this   under this classification level are:
level classification.
(1) Tanks                                 (a) tanks                                NQA-1 adds the parenthesis (2) Heat exchangers and parts             (b) heat exchangers and parts            (jacketed) after electrical cable in (j).
(3) Accumulators                          (c) accumulators                         Similar, Same Intent.
(4) Demineralizers                        (d) demineralizers (5) Reactor vessel                        (e) reactor vessel (6) Evaporators                           (f) evaporators (7) Steam generators                      (g) steam generators (8) Pressurizer                           (h) pressurizers (9) Piping                                (i) piping (10) Electrical cable                     6) electrical cable (jacketed)
(11) Structural items                     (k) structural items (12) Reinforcing steel                    (I) reinforcing steel (13) Aggregates                           (m) aggregates
: 3. PACKAGING                            3 PACKAGING                              OK 3.1   General                             3.1    General This section contains the requirements    This Section contains the for packaging of items for protection     requirements for packaging of items against corrosion, contamination,         for protection against corrosion, physical damage or any effect which       contamination, physical damage, or would lower the quality or cause the      any effect that would lower the quality item to deteriorate during the time it is or cause the items to deteriorate dur-shipped, handled and stored.              ing the time they are shipped, handled, and stored.
The degree of protection specified will   The degree of protection specified will  OK vary according to storage conditions      vary according to conditions and and duration, shipping environment,       duration of storage, shipping envi-and handling conditions.                  ronment, and handling conditions.
9 of 39                                                7/27/10

Enclosure 4, Table 2 ANSI N45.2.2-1972 vs NQA-1 -1994, Subpart 2.2 I1I[JIU1IIl*UIdLIUI        iaJdLddYil I Ul ULIMP            ly     IIIlIjJI    lOVIILOLIUII Vu LIII1  I,.,LIUI I 0 section is accomplished by identifying             accomplished by identifying the item the item and the appropriate                       and the appropriate packaging packaging level, and then applying the             level, and then applying the appropriate criteria contained herein              appropriate criteria contained herein concerning cleaning, preservatives,                concerning cleaning, preservatives, desiccants, inert gas blankets,                    desiccants, inert gas blankets, cushioning, caps and plugs, barrier                cushioning, caps and plugs, barrier and wrapping materials, tapes,                     and wrapping materials, tapes, blocking and bracing, containers,                  blocking and bracing, containers, marking, other quality assurance                   marking, other quality assurance H,        0  i. 01
                 -VIUVlOlJl l ullul  i H *LIL  I I.                lOII I i- , l             ILl Appendix A-3 contains additional                   Part II Introduction                              OK requirements generally not available in            1 Purpose other documents.                                   Applicable nonmandatory guidance for various subparts are provided in Part Ill.
These requirements are a mandatory                                                                   These words not included in NQA-1 part of this standard                                                                                as the requirements are included in the text and not in a separate appendix.
3.2 Levels of Packaging                            3.2 Levels of Packaging                           OK The packaging requirements are                     The packaging requirements shall be based on the protection the items                  based on the protection that is should receive during shipping,                    necessary during shipping, handling, handling, and storage.                             and storage of the item to satisfy Levels A, B, C, and D protection requirements set forth below.
The requirements of this standard are              The requirements herein are intended              OK intended to be in addition to industry             to be in addition to industry classifications or tariff rules for rail,          classifications or tariff rules for rail, truck, air and water shipments and                 truck, air, and water shipments and regulatory agency rules already                    regulatory agency rules already established in the transportation                  established in the transportation industry and in no way are they                    industry; and in no way are they intended to reduce the minimum                     intended to reduce the minimum standards established by these                     standards established by these regulatory agency rules.                           regulatory agency rules.
The following packaging criteria are               The following packaging criteria are              OK divided into four levels corresponding             divided into four levels corresponding to the categories of Subsection 2.7 of             to the classification categories of para.
this Standard.                                     2.2 of Subpart 2.2.
3.2.1 Level A Items. (See paragraph                3.2.1 Level A Items. (See para.                   OK 2.7.1). Level A items require the                  2.2.1.) Level A items require the highest degree of protection and shall             highest degree of protection and shall conform to the following criteria:                 conform to the following criteria.
(1)         Package design requirements            (a) Package design requirements shall             OK are for extraordinary environmental                be for extraordinary environmental protection to avoid the deleterious                protection to avoid the deleterious effects of shock and vibration, to                 effects of shock and vibration, to control temperature or humidity within             control temperature or humidity within specified limits, or for any other special         specified limits, or for any other special requirements.                                      requirements.
(2) Items shall have been inspected                (b) Items shall have been inspected for           OK for cleanness immediately before                   cleanness immediately before packaging. Dirt, oil residue, metal                packaging. Dirt, oil residue, metal chips or other form of contamination               chips, or other forms of contamination shall have been removed by approved                shall have been removed by approved cleaning methods. Any entrapped                    cleaning methods. Any entrapped water shall have been removed,                     water shall have been removed.
(3) Items which are not immediately                (c) Items which are not immediately               OK packaged shall be protected from                   packaged shall be protected from                I 10 of 39                                                   7/27/10

Enclosure 4, Table 2 ANSI N45.2.2-1972 vs NQA-1-1 994, Subpart 2.2 W.I IdI WIII1 IdLIUJ 1.
(4)        All Items shall be packaged       (d)Items requiring protection from             OK with a barrier (see Subsection 3.6 of      water vapor, salt air, dust, dirt, and this Standard) so that water vapor, salt   other forms of contamination pen-air, dust, dirt and other forms of         etrating the package shall be contamination do not penetrate the         packaged with a barrier (see para.
packane.                                   3.6).
(5) Items shall be packaged in             (e) Items which require protection from          NQA-1 adds the words "which require containers or crates (see Subsection       damage during shipping and handling,             protection from damage during 3.7 of this standard).                     shall be packaged in containers or          .shipping      and handling".
crates (see para. 3.7).
(6) Items which can be damaged by         (0 Items which can be damaged by                 OK condensation trapped within the            condensation trapped within the package shall be packaged with             package shall be packaged with approved desiccant (see paragraph          approved desiccant (see para. 3.6.3) 3.6.3) inside the sealed water vapor       inside the sealed water- and vapor-proof barrier or by an equivalent          proof barrier or by an equivalent method (for example, see paragraph         method (for example, see para. 3.6.2).
3.6.2).
(7) All openings into items shall be       (g)All openings into items shall be              OK capped, plugged or sealed (see             capped, plugged, or sealed (see para.
Subsection 3.5 of this standard). Weld     3.5). Weld end preparations shall be end preparations shall be protected         protected against corrosion and against corrosion and physical              physical damage.
damage.
(8) Items packed in containers shall be      (h)Items packed in containers shall            N45.2.2 uses the words "and/or" blocked, anchored, braced and/or            be blocked, anchored, braced, or                whereas NQA-1 uses the words "or'.
cushioned (see Subsection 3.8 of this      cushioned (see pama. 3.8) to prevent             Similar, Same Intent.
standard) to prevent physical damage       physical damage to the item or barrier.
to the item or barrier.)
(9) Items and their containers shall be      (i) Items and their container shall be         OK identified by marking (see Subsection       identified by marking (see para. 3.9).
3.9 of this standard).
3 2.2 Level B Items. (See paragraph         3.2.2 Level B Items. (See para.                 OK 2.7.2) Level B items require a high         2.2.2.) Level B items require a high degree of protection and the package        degree of protection, and the package shall be designed to avoid the             shall be designed to avoid the deleterious effects of shock, vibration,   deleterious effects of shock, vibration, physical damage, water vapor, salt         physical damage, water vapor, salt spray, condensation and weather             spray, condensation, and weather during shipping, handling and storage.      during shipping, handling, and storage.
This packaging shall be equivalent to       This packaging shall be equivalent to           Slightly different wording between that for Level A except that the ex-       that for Level A,except that the                 N45.2.2 and NQA-1 but equivalent.
tremes of paragraph 3.2.1 (1) need not      package design requirements need apply,                                     not be equivalent to satisfy' the level of extraordinary environmental protection indicated in para. 3.2.1 (a) where such protection is not justified.________________
Level B items such as control panels       Shipment of Level B items in fully en-          N45.2.2 includes the words "such as or similar special items may be            closed vehicles or equivalent                   control panels or other similar special shipped with a minimum of protection       protective enclosure or packaging is            items" and is more specific in when transported ina fully enclosed         acceptable, provided the above-stated           describing the transportation manner furniture type van with special             high degree of protection for Level B           as "fumniture type van with special suspension, provided the shipment          items is maintained throughout                  suspension".
goes through to destination in the         shipment, and the shipment goes original vehicle and Level B storage      through to destination inthe original facilities are available at the site.       vehicle and Level B storage facilities are available on site.________________
If transfer becomes necessary to                These words not included in N45.2.2.
transit, transfer procedures shall be subject to purchaser acceptance.               ________________
3.2.3 Level C Items. (See paragraph        3.2.3 Level C Items. (See para.          .      N45.2.2 adds the words "airbomne 2.7.3) Level C items require protection    2.2.3.) Level C items require protection        and windblown" when referring to from exposure to salt spray, rain, dust,   from exposure to salt spray, rain, dust,        contaminants.
dirt, and other airbomne and windblown     dirt, and other contaminants.
contaminants. Protection from water        Protection from water vapor and 11 of 397//1                                                   7/27/10

Enclosure 4, Table 2 ANSI N45.2.2-1972 vs NQA-1-1994, Subpart 2.2 vapor and condensation is less             condensation is less important than for important than for Level B items. The      Level B items. The following criteria followina criteria shall aDDIv:            shall arrlv.
(1) Criteria (2) (3) (5) (7) (8) and (9)   (a) Criteria (b), (c), (e), (g), (h), and (i) OK for Level A items (see paragraph           for Level A items (see para. 3.2.1) 3.2.1) shall apply to Level C items.       shall apply to Level C items.
(2) Items shall be packaged with a         (b) Items shall be packaged with a            OK waterproof enclosure so that water,        waterproof enclosure so that water, salt spray, dust, dirt, and other forms    salt spray, dust, dirt, and other forms of contamination do not penetrate to       of contamination do not penetrate to the item.                                  the item.
(3) Items subject to detrimental           (c) Items subject to d etrimental             OK corrosion, either internal or external,    corrosion, either internal or external, shall be suitably protected.               shall be suitably protected.
3.2.4 Level D Items. (See paragraph        3.2.4 Level D Items. (See para.               OK 2.7:4) Level D items require protection    2.2.4.) Level D items require protection from physical and mechanical               from physical and mechanical damage. The following criteria shall       damage. The following criteria shall apply:                                     apply.
(1)      Items, just before packaging,     (a) Items, just before packaging, shall       OK shall have been inspected for              have been inspected for cleanness cleanness according to the                 according to the requirements requirements specified in the              specified in the purchasing document.
purchasing document. Dirt, oil residue,    Dirt, oil residue, metal chips, or other metal chips or other forms of              forms of contamination shall have contamination shall have been              been removed by approved cleaning removed by approved cleaning meth-         methods. Any entrapped water shall ods. Any entrapped water shall have        have been removed.
been removed.
(2)      All openings into items shall be  (b) All openings into items shall be          OK capped, plugged and sealed (see            capped, plugged, and sealed (see Subsection 3.5 of this standard). Weld     para. 3.5). Weld end preparations shall end preparations shall be protected        be protected from corrosion and from corrosion and physical damage.        physical damage.
(3)       Items subject to detrimental     (c) Items subject to detrimental              OK corrosion, either internal or external,    contamination or corrosion, either shall be suitably protected.               internal or external, shall be suitably protected.
(4)      Items packed in containers         (d) Items packed in containers shall         OK shall be blocked, braced and/or            be blocked, braced, or cushioned to cushioned to prevent physical damage       prevent damage (see para. 3.8).
(see Subsection 3.8 of this Standard).
(5)      Items such as aggregate and       (c) Items subject to detrimental              These specific words related to reinforcing steel shall be suitably        contamination or corrosion, either            aggregates and reinforcing steel are protected against detrimental              internal or external, shall be suitably       not included as a separate item since contamination or corrosion.                protected.                                    item (c) of this section includes this provision as a general requirement.
(6)     The identity of the item shall be  (e) The identity of the item shall be         OK maintained by marking (see                 maintained by marking (see para. 3.9)
Subsection 3.9 of this standard) or        or other appropriate means.
other appropriate means.
Cleaning                             3.3 Cleaning                                  N45.2.2 uses the word "purchase document" whereas NQA-1 uses the Cleaning includes the preparation of       Cleaning includes the preparation of          word "procurement document" items for preservation or packaging, or    items for preservation or packaging, or both, to minimize the requirements for     both, to minimize the requirements for site cleaning. Items shall be inspected    site cleaning. Items shall be inspected for cleanness immediately before           for cleanness immediately before packaging according to the cleaning        packaging according to the cleaning requirements specified in the purchase     requirements specified in the pro-document. Any dirt, oil residue, metal     curement documents. Any dirt, oil chips or other forms of contamination      residue,, metal chips, or other forms of shall be removed by documented             contamination shall be removed by cleaning methods. Any entrapped            documented cleaning methods. Any water shall be removed,                    entrapped water shall be removed.
12 of 39                                                     7/27/10

Enclosure 4, Table 2 ANSI N45.2.2-1972 vs NQA-1-1994, Subpart 2.2 Any item which is not immediately          (d) After cleaning, the item shall be     OK packaged shall be protected from           protected from contamination until further contamination,                     preservation or packaging is complete.
(See Appendix section A3.3 for additional requirements.)
Methods of Preservation             3.4     Methods of Preservation           OK Items subject to deleterious corrosion     Items subject to deleterious corrosion shall be protected by using either         shall be protected by using either contact preservatives, inert gas           contact preservatives, inert gas blankets, or vaporproof barriers with      blankets, or vapor-proof barriers with desiccants. (See Subsection 3.6 of this    desiccants. (See para. 3.6 for vapor-standard for vaporproof barriers and       proof barriers and desiccants.)
desiccants.)
3.4.1 Contact Preservatives.               3.4.1 Contact Preservatives.              OK Contact preservatives are compounds        Contact preservatives are compounds applied to bare metal surfaces to          applied to bare metal surfaces to pre-prevent surface corrosion during           vent surface corrosion during shipping shipping and storage and generally         and storage and generally require require removal prior to installation,     removal prior to installation.
(See Appendix section A3.4.1 for additional requirements.)
3.4.2 Inert Gas Blankets. Purging          3.4.2 Inert Gas Blankets. Purging         OK and pressurizing the interior of an item   and pressurizing the interior of an item or its container or both with a dry inert  or its container, or both, with a dry gas provides a means of preventing        inert gas provides a means of moisture or corrosive atmospheres         preventing moisture or corrosive from acting on sensitive bare metal        atmospheres from acting on sensitive, surfaces or other materials. The item     bare metal surfaces or other materials.
or its container shall be either          The item or its container shall be either evacuated prior to filling with the inert  evacuated prior to filling with the inert gas or adequately purged with the          gas or adequately purged with the same gas prior to applying the gas        same gas prior to applying the gas blanket. (See Appendix section A3.4.2     blanket.
for additional requirements.)
Caps, Plugs, Tapes, and Adhesives         3.5      Caps, Plugs, Tapes, and          OK Adhesives These items shall be of materials which enable them to perform their         These items shall be of materials that intended function adequately without      enable them to perform their intended causing deleterious effects on items or   function adequately, without causing systems operation,                        deleterious effects on the items or system operation.
3.5.1 Caps and Plugs. Caps and            3.5.1 Caps and Plugs. Caps and            OK plugs shall be used to seal openings in   plugs shall be used to seal openings in items having sensitive internal           items having sensitive internal sur-surfaces, and to protect threads and      faces and to protect threads and weld weld end preparations. (See Appendix       end preparations.
section A3.6.1 for additional requirements.)
3.5.2 Tapes and Adhesives.                3.5.2 Tapes and Adhesives.                OK Pressure sensitive, removable, tape        Pressure-sensitive, removable tape should be used in lieu of adhesives in    shall be used in lieu of adhesives in contact with bare metal surfaces.         contact with bare metal surfaces.
Tapes or adhesives which could have       Tapes or adhesives that could have        OK damaging effects on the item or           damaging effects on the item or sys-system shall not be used. Tapes near      tem shall not be used. Tapes near a a weld shall be removed completely        weld shall be removed completely, immediately prior to performing a weld     immediately prior to performing a weld.
or closure.
Tapes used for identification rather      Tapes used for identification rather      OK than sealing which are not near a          than sealing that are not near a 13 of 39                     7/27/10

Enclosure 4, Table 2 ANSI N45.2.2-1972 vs NQA-1-1994, Subpart 2.2 welding operation may remain until system testing. (See Appendix section      system testing is complete, but shall A3.5.2 for additional requirements.)       be removed before plant operations unless qualified for operating conditions.
Barrier and Wrap Materials and             1.1 Definitions                           OK Desiccants barrier--a flexible material designed A barrier generally is a flexible material to withstand the penetration of water, designed to withstand the penetration      water vapor, grease, or harmful gases of water, water vapor, grease, or harmful gases. A wrap is a flexible        wrap - a flexible material formed material, formed around the item or        around the item or package to exclude package to exclude dirt and to             dirt and to facilitate handling, marking, facilitate handling, marking or labeling,  or labeling Material thickness shall be selected on    3.6 Barrier and Wrap Materials            OK the basis of type, size and weight of      and Desiccants equipment oritem to be protected, such that the barrier or wrap will not     Material thickness shall be selected on easily be damaged by puncture,             the basis of type, size, and weight of abrasion, weathering, cracking,            equipment or item to be protected, temperature extremes, wind                 such that the barrier or wrap will not conditions, and the like.                  easily be damaged by puncture, abrasion, weathering, cracking, temperature extremes, wind conditions, and the like.
Barrier and wrap materials shall be        Barrier and wrap materials shall be       OK nonhalogenated when used in direct         noncorrosive and shall not be contact with austenitic stainless steels,  otherwise harmful to the item pack-shall be noncorrosive, shall not readily   aged. When barrier and wrap support combustion and shall not be        materials are used in direct contact otherwise harmful to the item              with austenitic stainless steels, the packaged.                                  total and water leachable content of halogen shall not be harmful to the item packaged. Also, barrier and wrap materials shall not readily support combustion.
Vaporproof barrier materials used with     Vapor-proof barrier materials used        OK desiccants constitutes another             with desiccants constitute another preservation system (see Subsection        preservation system that protects 3.4 of this standard); it protects against against potential damage by water potential damage by water vapor            vapor condensate.
condensate.
3.6.1 Water-proof Barrier Material.        3.6.1 Waterproof Barrier Material.        OK Waterproof barrier material shall be       Waterproof barrier material shall,be resistant to grease and water:             resistant to grease and water; it shall it shall protect items from airborne and   protect items from airborne and windblown soils,                           windblown soils.
3.6.2 Vapor Barrier Material.              3.6.2 Vapor-proof Barrier Material.       OK Vaporproof barrier materials shall be      Vapor-proof barrier materials shall be sealable and the edge of the barrier       sealable, and the edge of the barrier which normally will be opened at           that normally will be opened at destination shall be of sufficient area    destination shall be of sufficient area to permit at least two subsequent          to permit at least two subsequent sealing operations. (See Appendix          sealing operations.
A3.6.2 for additional requirements).
3.6.3 Desiccants. Desiccants may be        3.6.3 Desiccants. Desiccants shall        OK used within a vaporproof barrier when      be used within a vapor-proof barrier condensation or high humidity could        when condensation or high humidity damage an item by corrosion, mold, or      could damage an item by corrosion, mildew. (See Appendix A3.6.3 for           mold, or mildew.
additional requirements).
3.7 Containers, Crating and Skids          3.7     Containers, Crating, and          OK Skids 3.7.1 Containers. Containers are           3.7.1- Containers. Containers shall       OK 14 of 39                     7/27/10

Enclosure 4, Table 2 ANSI N45.2.2-1972 vs NQA-1 -1994, Subpart 2.2
          ~ ~ ~~P
       '.OOU IOI',*         pILLLI-- I HUH Ll -
item or its barrier is required. Domestic    the item or its barrier is required.
types used shall be limited to:              Domestic types used shall be limited to the followina:
(1)      Cleated, sheathed boxes (500         (a) cleated, sheathed boxes [500 lb      NQA-1 also references metric weight lb maximum net weight).                      (227 kg) maximum net weight]              equivalents.
L2) Nailed wood boxes.                 -      (b)nailed wood boxes                    OK (3)      Wood-cleated solid fiberboard       (c) wood-cleated solid fiberboard         OK boxes,                                        boxes (5      Metal or fiber drums.                (d)metal or fiber drums                  OK 6 Crates (see paragraph 3.7.2). -        (e) crates (see para. 3.7.2)              OK (7)       Wire bound boxes (200 lb            (0 wire bound boxes [200 lb (91 kg)       NQA-i. also references metric weight maximum net weight).                         maximum net weight]                       equivalents.
(8)       Other specially designed            (g) other specially designed containers   OK Containers for special equipment.            for special equipment                    ________________
(4)      Fiberboard boxes (120 lb             (h)fiberboard boxes [120 lb (54.5 kg)    NQA-1 also references metric weight maximum net weight. See Appendix             maximum net weight].                      equivalents.
A3.7.1 for additional requirements).                                                   ________________
Cleated boxes in excess of 50 lb shall       Cleated boxes in excess of 50 lb (22.7    NQA-1 also references metric weight be bound with steel strapping or              kg) shall be bound with steel            equivalents.
equivalent around the container at not        strapping, or equivalent, around the less than two places. (See Appendix          container at not less than two places.
A3.7.1 for additional requirements.)
3.7.2 Crates and Skids. Crates and            3.7.2 Crates and Skids. Crates and        NQA-1 also references metric weight skids shall be used for equipment in          skids shall be used for equipment in      equivalents.
excess of 500 lb. Skids and runners           excess of 500 lb (227 kg). Skids and shall be used on boxes with a gross           runners shall be used on boxes with a weight of 100 lb or more, allowing a          gross weight of 100 lb (45.5 kg) or minimum floor clearance for forklift          more, allowing a minimum floor tines as provided by 4 inch lumber.           clearance for forklift tines as provided by 4 in. (10 cm) lumber.
3.8 Cushioning, Blocking, Bracing             3.8      Cushioning, Blocking,            OK and Anchoring                                 Bracing, and Anchoring 3.8.1 Cushioning. Cushioning shall            3.8.1 Cushioning. Cushioning shall        OK be used where protection from shock           be used where protection from shock and vibration is required; the                and vibration is required. The Cushioning materials shall have               cushioning materials shall have sufficient strength to perform this           sufficient strength to perform this function. (See Appendix A3.8.1 for            function.
additional requirements.)
3.8.2 Blocking and Bracing.                   3.8.2 Blocking and Bracing.               OK Blocking and bracing used for                 Blocking and bracing used for protection of the load to be supported,       protection of the load to be supported shall be compatible with the size,            shall be compatible with the size, shape, and strength of bearing areas          shape, and strength of bearing areas of the shipment.                              of the shipment.________________
The blocking and bracing used to              The blocking and bracing used to          OK prevent item movement shall                   prevent item movement shall withstand thrust and impact applied in        withstand thrust and impact applied in any direction,                                any direction.
Blocking and bracing used in direct           Blocking and bracing used in direct       OK contact with the item being blocked           contact with the item being blocked shall not have a corrosive effect on the      shall not have a corrosive effect on the item,                                         item.
3.8.3 Anchoring. Anchoring of the             3.8.3 Anchoring. Anchoring of the         OK item within a crate or on a skid shall        item writhin a crate or on a skid shall adequately fasten the item during             adequately fasten the item duning shipment and protect the item from            shipment and protect the item from potential damage due to rough                 potential damage due to rough handling,                                     handling.
To facilitate disassembly and minimize                                                 Guidance only. Does not establish damage when removing container                                                         requirements.
contents, bolting is preferred. (See Ap-pendix A3.8.3 for additional requirements.)__________________________________
15 of 397271                                           7/27/10

Enclosure 4, Table 2 ANSI N45.2.2-1972 vs NQA-1 -1994, Subpart 2.2 CU I~lJUI  Cly LUOIlllUI IIIl~ uIuv, lJlJ~.S           i I  .I 1".y u4 111 Il I~j U U1114l bracing or anchoring placed within an       bracing, or anchoring placed on an item for shipping protection that must       item for shipping protection that needs be removed prior to operation of the         to be removed prior to operation of the item shall be identified by warnings         item shall be identified by warnings placed in a conspicuous manner to           placed in a conspicuous manner to effect proper removal of the packing         effect proper removal of the packing material.                                   material.
3.9 Marking                                 3.9 Marking                                 OK To maintain proper identification and        To maintain proper identification and instructions or both during shipping,       instructions, or both, during shipping, receiving and storage, and to provide       receiving, and storage and to provide for identification after the outside of the for identification after the outside of the container has been removed, the item        container has been removed, the item and the outside of containers shall be      and the outside of the containers shall marked. (See Appendix 3.9 for               be marked.
additional requirements.)
If equipment does not lend itself to       Words not included in N45.2.2 marking, records shall be maintained that are uniquely identifiable to the item.
: 4. SHIPPING                             4.1        General                          N45.2.2 goes into details as to what is covered under this section.
4.1      General                            This Section covers the requirements This section covers the requirements        for loading and shipment of items as for loading and shipment of items as        defined in para. 2.2.
defined in Subsection 2.7 of this standard. Described are environmental protection during transit, procedures to minimize damage in transit, precaution required when handling items during loading and transit, and identification and in-
.spection on overseas shipments.
The mode of transportation used shall       The mode of transportation used shall       OK be consistent with the protection            be consistent with the protection classification of the item (see              classification of the item (see para.
Subsection 2.7 of this standard) and         2.1) and with the packaging methods with the packaging methods employed          employed (see para. 3.2).
(see Subsection 3.2 of this standard).
4.2 Transportation Requirements              4.2       Transportation                   OK Requirements 4.2.1        Open Carriers. For              4.2.1 Open Carriers. For shipment          OK shipment on open carriers where items        on open carriers where items may be may be exposed to adverse                    exposed to adverse environmental environmental conditions, the following      conditions, the following shall apply.
 -shall apply:
(1) Level A, B, and C items shall be         (a) Levels A, B, and C items shall be      OK covered for protection from                  covered for protection from environmental conditions. Tarpaulins,        environmental conditions. Tarpaulins, when used, shall be fire retardant; and      when used, shall be fire retardant, and they shall be installed in a manner to       they shall be installed in a manner to provide drainage and to insure air           provide drainage and to ensure air circulation to prevent condensation,         circulation to prevent condensation.
(2) Barrier and wrapping materials           (b) Barrier and wrapped materials (see     OK (see Subsection 3.6 of this standard)        para. 3.6) subject to transportation subject to transportation damage shall       damage shall be covered with be covered with waterproof shrouds           waterproof shrouds, such as such as tarpaulins, so that they are not     tarpaulins, so that they are not exposed directly to the environment,         exposed directly to the environment.
4.2.2 Closed Carriers. For shipment         4.2.2 Closed Carriers. For shipment         OK on closed carriers the following shall      on closed carriers the following shall
                                                                  .16 of 39                                              7/27/10

Enclosure 4, Table 2 ANSI N45.2.2-1972 vs NQA-1-1 994, Subpart 2.2 dppiJy.                                    dfiJply.
(1) When level A, B, and C items           When Levels A,B, and C items cannot       OK cannot be adequately protected from         be adequately protected from weather weather or environment on open             or environment on open carriers, carriers, closed carriers shall be used. dosed carriers or fully enclosed vehi-cles shall be used.
(2) Use of fully enclosed fumniture                                                  Recommendation only. Does not vans is recommended when shipping                                                    establish requirements.
large delicate items such as control panels.
4.2.3 Special Shipments. Items that         4.2.3 Special Shipments. Items that      OK exceed established weight or size           exceed established weight or size limitations for railroads or highways, or   limitations for railroads or high require special handling should be         ways or require special handling shall given additional consideration in the       be given additional consideration in following areas:                            the following areas.
(1) The type of bracing and tie down        (a)The type of bracing and tie down      OK methods to be used with the mode of         methods to be used with the mode of transportation selected for special         transportation selected for special shipments shall be specified.               shipments shall be specified.
(2) "NO HUMPING" shall be specified         (b) NO HUMPING shall be specified        OK on rail shipments of these items, and       on rail shipments of these items, and "NO HUMPING" signs shall be                 NO HUMPING signs shall be prominently displayed.                      prominently displayed.
(3) Use of impact recording meters          (c) Use of impact recording meters       OK should be specified on shipments of         shall be specified on shipments of heavy or relatively large items             heavy or relatively large items incorporating delicate factory installed    incorporating delicate factory-installed instrumentation. Meters, when               instrumentation. Meters, when specified, shall be installed prior to      specified, shall be installed prior to loading (to record any rough handling       loading (to record any rough handling during loading). Procedures shall be        during loading). Procedures shall be established to interpret recorded data,     established to interpret recorded data and to thoroughly check the integrity of    and to thoroughly check the integrity of an item when there is evidence of           an item when there is evidence of rough handling. A notice that impact        rough handling. A notice that impact recording meters are being used shall       recording meters are being used shall be prominently displayed. Special           be prominently displayed. Special recording meters with operating time        recording meters with operating time limits greater than the expected transit    limits greater than the expected transit time shall be specified or, if the         time shall be specified or, if the ex-expected transit time exceeds the           pected transit time exceeds the operating time limit of the recorders      operating time limit of the recorders being used, provisions shall be made        being used, provisions shall be made to service the meters during transit.      to service the meters during transit.
(4) The use of "Escorts" may be                                                      These words are not contained in specified to accompany shipments,                                                    NQA-11. "May" establishes a when additional surveillance is                                                      recommendation, not a requirement.
required during transit of certain items.
(5) For special shipments, the              (d)For special shipments, the            OK conveyance used for transport shall be     conveyance used for transport shall be certified to be structurally adequate to   certified to be structurally adequate to take the loads imposed during loading,     take the loads imposed during loading, while en route, and during unloading,      while en route, and during unloading.
Prior to shipment the route shall have      Prior to shipment the route shall have been investigated to assure safe           been investigated to assure safe transit.                                   transit.
4.3 Precautions During Loading             4.3 Precautions During Loading            OK and Transit                                and Transit 4.3.1 Loading. The weight, lifting         4.3.1 Loading. The weight, lifting        NOA-1 includes the words "by the points; or center of gravity indicated on  points, or center of gravity indicated by shipper" when referrng to indicating the crate, skid, or package by the         the shipper on the crate, skid, or        the weight, etc.
shipper (see Subsection 3.9 of this        package by the shipper (see para. 3.9) standard) shall be utilized to insure      shall be utilized to ensure proper        ________________
17 of 397//1                                          7/27/10

Enclosure 4, Table 2 ANSI N45.2.2-1972 vs NQA-1-1994, Subpart 2.2 transfer between carriers, and un-        between carriers, and unloading (see loading (see Section 7 of this            Section 7).
standard'.
4.3.2 Rigging. Carbon steel rigging       4.3.2 Rigging. Carbon steel rigging        OK equipment shall not come in direct        equipment shall not come in direct contact with stainless steel except       contact with stainless steel, except when attached to lifting lugs, eyes, or   when attached to lifting lugs, eyes, or pads, in order to avoid surface           pads in order to avoid surface damage.                                   damage.
4.3.3      Handling Precautions. All      4.3.3 Handling Precautions. All            OK austenitic stainless steel and nickel     austenitic stainless steel and nickel-base alloy materials shall be handled     base alloy materials shall be handled in such a manner that they are not in     in such a manner that they are not in contact with lead, zinc, copper,          contact with lead, zinc, copper, mercury, or other low melting             mercury, or other low melting point elements, alloys, or halogenated          elements, alloys, or halogenated material,                                 material.
4.3.4      PackagelPreservative           4.3.4        Package and Preservative      N45.2.2 uses and/or when referring Coatings. Packages and/or                 Coatings. Package or preservative          to" packages and/or preservative preservative coatings shall be visually   coatings shall be visually inspected       coatings", NQA-1 uses the word "or".
inspected after loading, and damaged      after loading and damaged areas areas repaired prior to shipment.         repaired prior to shipment.
Items shipped with desiccants shall be    Items shipped with desiccants shall be    OK inspected after loading to assure that    inspected after loading to assure that sealed areas are intact,                  sealed areas are intact.
4.3.5       Sealed Openings. Sealed       4.3.5 Sealed Openings. Sealed              OK Openings shall be visually inspected      openings shall be visually inspected after loading to assure closures are      after loading to assure closures are intact. Materials used for resealing      intact. Materials used for resealing shall be in accordance with Section 3     shall be in accordance with Section 3.
of this standard.
4.3.6      Stacking. Written instructions 4.3.6 Stacking. Where special care         NQA-1 includes the words "Where covering the location and stacking       is deemed necessary to avert damage,       special care is deemed necessary to limits of the crates or boxes on the     written instructions concerning the        avert damage", whereas N45.2 transport vehicle shall be specified;      location or stacking limits for crates or includes the words "on the transport these should be marked on the              boxes shall be marked on the              vehicle" when referring to limits of the container,                               containers,                                crates or boxes.
4.3.7      Theft and Vandalism.          4.3.7 Theft and Vandalism.                 OK Precautions shall be taken to minimize    Precautions shall be taken to minimize the possibility of theft and vandalism   the possibility of theft and vandalism during shipment of items.                during shipment of items.
4.4 Identification and Marking           4.4       Identification and Markings      N45.2.2 includes the words "in accordance with Subsection 3.9 of Identification and markings on the        Identification and markings on the        this standard."
outside of all packages, skids or        outside of all packages, skids, or protective covering shall be              protective covering shall be main-maintained in accordance with            tained.
Subsection 3.9 of this standard.
4.5 Shipments From Countries             4.5 Shipments From Countries               OK Outside United States                     Outside the United States 4.5.1 Overseas Shipment. When             4.5.1 Overseas Shipment. When              OK overseas shipments are involved, use     overseas shipments are involved, use of deck cargo facilities shall be        of deck cargo facilities shall be avoided unless necessary due to          avoided unless necessary due to physical dimensions. Shipments            physical dimensions. Shipments utilizing approved watertight             utilizing approved watertight con-containers may be carried on deck.       tainers may be carded on deck.
4.5.2 Inspection at Point of              4.5.2 Inspections at Point of              N45.2.2 uses the terminology "For Shipment. For special shipments,          Shipment. Items shall be inspected to     special shipments". NQA-1 is more items shall be inspected to insure       ensure integrity of packaging or pro-      conservative.
integrity of packaging or protective     tective enclosures after being loaded      OK enclosures after being loaded aboard     aboard ship.
ship.
4.5.3 Inspection at Port of Entry.        4.5.3 Inspection at Port of Entry.         N45.2.2 uses the terminology "For For special shipments, items shall be     Items shall be inspected to ensure        special shipments". " NQA-1 is more 18 of 39                                                7/27/10

Enclosure 4, Table 2 ANSI N45.2.2-1972 vs NQA-1 -1994, Subpart 2.2 II Ipw&#xfd;LwV  LV II HOUIV I ILUI I LY VI     11IIL"VIlLy UI P.IUdMOVt, IV U HI -IVLCAIVC packaging or protective enclosures         enclosures when items are off-loaded        OK when items are off loaded at the port      at the port of entry.
rf entry.
4.5.4 Identification and Markings.         4.5.4 Identification and Markings.          OK Identification and markings shall follow    Identification and markings shall follow the procedure outlined in Subsection       the procedure outlined in para. 3.9.
3.9 of this Standard.
The English language and avoirdupois                                                   These words are not included in weight shall be used for all                                                           NQA-1.
identification and marking. Duplicate markings and identification in other languages or weight systems may be used.
4.5.5 Transportation                       4.5.5 Transportation                        OK Requirements. Requirements outlined        Requirements. Requirements outlined in Subsection 4.2 (Transportation) and     in para. 4.2 and Section 7 shall be in Section 7 of this Standard shall be     followed where applicable.
followed where applicable.
4.6 Nuclear Material Shipments             4.6      - Nuclear Material Shipments       N45.2.2 uses the term "AEC fuel license" while NQA-1 uses the term Special nuclear material and sources       Special nuclear material and sources        "NRC fuel license".
shall be shipped as specified in the       shallbe shipped as specified in the AEC fuel license and by other              NRC fuel license and by other               Similar, Same Intent.
regulatory agencies.                       regulatory agencies.
: 5. RECEIVING                           5 RECEIVING                                 OK 5.1    General                             5.1        General This section contains requirements         The requirements that shall be fulfilled that are to be fulfilled by the            by the organization(s) responsible for organization or organizations re-          the receiving of items.
sponsible for the receiving of items.
Receiving starts when the items arrive    Receiving starts when the items arrive      OK at a storage facility or construction site at a storage facility or construction site before unloading or unpacking,             before unloading or unpacking.
Included are procedures, inspections,                                                 Guidance only. Does not establish marking, identification and                                                           requirements.
documentation prior to placing the item in storage or directly in its final location. Shipping damage claims, transfer of ownership, financial responsibility and contractual obligations are commercial obligations which are not included in the scope of this Standard.
5.2 Receiving Inspection                  5.2       Receiving Inspection              OK Requirements                               Requirements 5.2.1       Shipping Damage                5.2.1 Shipping Damage Inspection.           OK Inspection. Preliminary visual             Preliminary visual inspection shall be inspection or examination shall be         performed prior to or immediately after performed prior to unloading to           unloading to determine if any damage determine if any damage occurred           occurred during shipping.
during shipping. Observations for          Observations for unusual conditions unusual conditions shall include:          shall include:
(1)         Fire - Charred paper, wood     (a) fire - charred paper, wood, or          OK or paint, indicating exposure to fire or   paint, indicating exposure to fire or high temperature.                          high temperature; (2)      Excessive Exposure -              (b) excessive exposure - weather-           OK Weather-beaten, frayed, rusted, or         beaten, frayed, rusted, or stained stained containers indicating              containers, indicating prolonged ex-prolonged exposure during transit.         posure during transit; (3)      EnvironmentalDamage -             (c) environmental damage - water or         OK Water or oil marks, damp conditions,       oil marks, damp conditions, dirty dirty areas, or salt film (indicating      areas, or salt film, indicating exposure 19 of 39                                             7/27/10

Enclosure 4, Table 2 ANSI N45.2.2-1972 vs NQA-1 -1 994, Subpart 2.2 WPZUULU&#xfd;V     WaILeUI U1W1i= ICV OU             to sea water or winte-r road-salt salt chemicals).                                      chemicals:
(4)       Tie Down Failure Shifted,                   (d)tie down failure - shifted, broken,        OK broken, loose or twisted shipping ties,               loose, or twisted shipping ties, and        -
and worn material under ties,                         worn material under ties indicating indicating improper blocking and, tie                 improper blocking and tie down during down during shipment.                                 shipment; (5)         Rough Handling -(e)                           rough handling - splintered, tom,         OK Splintered, tom, or crushed containers                or crushed containers, indicating indicating improper handling,                         improper handling; Review of impact recording instrument                 (0)review of impact recording                 NQA-1 adds the words "against readings.                                             instrument readings against                   established criteria."
__________________________established                   criteria. See para. 4.2.3(c).
5.2.2 Item Inspection. Unless the                     5.2.2      Item Inspection. Unless the        OK package marking prohibits unpacking,                  package marking prohibits unpacking, the content of all shipments shall be                 the contents of all shipments shall be visually inspected to verify that the                 visually inspected to verify that the specified packaging and shipping                      specified packaging and shipping requirements have been maintained,                    requirements have been maintained.
When items are contained in trans-                    When items are contained in                   OK parent separate moisture-proof bags                   transparent, separate moisture-proof or envelopes, visual inspection without               bags or envelopes, visual inspection unpacking the contents is acceptable.                 without unpacking the contents shall be acceptable.
Statistical sampling methods may be                   Where specific inspection                     NQA-1 adds the words "Where used for groups of similar items.                     requirements can be achieved,                 specific inspection requirements can statistical sampling methods may be           be achieved" used for groups of similar items.
Care shall be taken to avoid                          Care shall be taken to avoid                  OK contamination of the items during                     contamination of the items during inspection. The inspections shall be                   inspection. The inspections shall be performed inan area equivalent to the                  performed in an area equivalent to the level of storage requirement for the                   level of storage requirement for the item (see Section 6 of this standard).                 item (see Section 6).
These inspections and examinations                     These inspections and examinations            OK shall include the following as                         shall include the following, as appropriate:                                           appropriate:
(1) Identification and Marking.                        (a)identification and marking -               OK Verification that identification and                  verification that identification and markings are in accordance with                       markings are in accordance with applicable codes, specifications,                     applicable codes, specifications, purchase orders, drawings, and this                    purchase orders, and drawings, and standard.                                             with requirements in this Part (Part 11);
(2) *Manufacturing Documentation -                     (b)manufacturing documentations -             N45.2.2 uses the term "and/or Asrnethat the item received was                 assurance that the item received was          drawings", NQA-1 states "or fassrianedtse n npce ro                                fabricated, tested, and inspected prior       drawings".
fabrhicaeted tete ancodainspcted prior                 to shipment inaccordance with appli-          Similar, Same Intent.
applicable code, specification,calcoespifatnurhe purchase order and/or drawings.                        order, or drawings; (3) Protection Covers and Seals -                      (c) protective covers and seals -             OK Visual inspection to assure that covers visual inspection to assure that covers and seals meet their intended function, and seals meet their intended function; (4) Coatings and Preservatives -                   .(d)    coatings and preservatives                OK Verification that coatings and                       'Verification that coatings and preservatives are applied in                           preservatives are applied in accordance with specifications,                       accordance with specifications, purchase orders, or manufacturer's                     purchase orders, or manufacturer's instructions.                     .instructions;                                                     _________________
(5) Inert Gas Blanket- Verification                 (e) inert gas blanket - verification that      OK that the inert gas'blanket pressure is                the inert gas blanket pressure is within within the acceptable limits,                         the acceptable limits;                         ________________
(6). Desiccant - Verification that the                 (0)desiccant - verification that the          OK desiccant is not saturated,, as indicated             desiccant is not saturated, as through the use of humidity indicators,               indicated, through the use of humidity Desiccants shall be regenerated or                 Iindicators. Desiccants shall be                  ________________
20 of 397//1                                                7/27/10

Enclosure 4, Table 2 ANSI N45.2.2-1972 vs NQA-1-1994, Subpart 2.2 lwitlh se U    Iinsvtctiy on s. I  tlt  I:yVIulI  atwUU UI  vpIa3IdIJcU 0&#xfd; I1.-odl y with special instructions.                  in accordance with special in-structions.
(7) Physical Damage- Visual                 (g) physical damage - visual                 OK inspection to assure that parts of items    inspection to assure that parts of items are not broken, cracked, missing,           are not broken, cracked, missing, deformed or misaligned and rotating.        deformed, or misaligned, and that parts turn without binding. Accessible      rotating parts turn without binding.
internal and external areas shall be        Accessible internal and external areas free of detrimental gouges, dents,          shall be free of detrimental gouges, scratches and burns,                        dents, scratches, and burrs.
(8) Cleanness- Visual inspection to         (h) cleanness - visual inspection to         OK assure that accessible internal and         assure that accessible internal and external areas are within the               external areas are within the specification requirements for dirt, soil,  specification requirements for dirt, soil, mill scale, weld splatter, oil, grease, or  mill scale, weld splatter, oil,.grease, or stains. If inspection for cleanness was     stains. If inspection for cleanness was performed prior to sealing and ship-        performed prior to sealing and ship-ping and inspection upon receipt            ping, and inspection upon receipt indicates that there has been no            indicates that there has been no penetration of the sealed boundary,         penetration of the sealed boundary, then inspection for internal cleanness      then inspection for internal cleanness is optional,                                is optional.
Unless the completed item was              Unless the completed item was                N45.2 adds the words "or examined" inspected or examined at the source, it     inspected at the source, it shall be         OK shall be inspected or examined at the       inspected at the point of receiving to point of receiving to verify that the       verify that the following characteristics following characteristics conform to the    conform to the specified requirements.
specified requirements.
These inspections or examinations           These inspections shall include such         OK shall include such items as:                items as:
(1)          PhysicalProperties-            (a) physical properties - assurance          OK Assurance that physical properties          that physical properties conform to the conform to the specified requirements       specified requirements and that and that chemical and physical test-        chemical and physical test reports, if reports, if required, meet the require-    required, meet the requirements; ments; (2)         Dimensions - Random            (b) dimensions - random visual               OK visual inspection to assure that           inspection to as sure that important important dimensions conform with          dimensions conform with drawings and drawings and specifications. Examples      specifications, i.e., baseplate mounting are: base plate mounting holes, overall     holes, overall extemal size, and external size, configuration and           configuration and orientation of parts; orientation of parts.
(3)          Weld Preparations-             (c) weld preparations - random               OK Random verification that weld              verification that weld preparations are preparations are in accordance with        in accordance with applicable applicable drawings and                     drawings and specifications; specifications.
(4)          Workmanship - Visual           (d) workmanship - visual inspection          OK inspection of accessible areas to           of accessible areas to assure that the assure that the workmanship is              workmanship is satisfactory to meet satisfactory to meet the intent of the      the intent of the requirements; requirements.-
(5)        Lubricants and Oils -          (e) lubricants and oils - verification of    OK Verification of presence of proper          presence of proper lubricants and oils, lubricants and oils, if required by either  if required, by either specification, specification, purchase order, or           purchase order, or manufacturer's in-manufacturers' instructions.                structions; (6)          ElectricalInsulation -         (f) electrical insulation - performance      OK Performance of insulation resistance        of insulation resistance tests for tests for motors, generators, control       motors, generators, and control and and power cable, to ensure                  power cable to ensure conformance conformance with specifications,            with specifications.
5.2.3        Special Inspection -           5.2.3 Special Inspection. Where              OK Where receiving inspection in addition      receiving inspection in addition to that 21 of 39                                               7/27/10

Enclosure 4, Table 2 ANSI N45.2.2-1972 vs NQA-1-1994, Subpart 2.2 LU LIIdL U(b:UIIU"U CIUUVV. M,Il IqUiluU,     UUWAIIUWU aULJVV    1&#xfd; I VqUI VU, L. 1.
the "Special Inspection" procedure,           special inspection procedure, complete with documentation                   complete with documentation instructions, shall be attached to the         instructions, shall be attached to the item or container (see Section 3 of this       item or container. This is in addition to standard); this is in addition to the         the copy sent through normal copy sent through normal channels.            channels. The special inspection shall The special inspection shall be                be performed, and the results of the performed and the results of the               inspection shall be documented.
inspection shall be documented.
5.3 Disposition of Received Items             5.3 Disposition of Received Items           OK 5.3.1 Acceptable - Containers and             5.3.1 Acceptable. Containers and            N45.2.2 adds the words "or items inspected or examined and               items inspected and found in                examined" and "in accordance with found in conformance with specified           conformance with specified require-         the status indicating system requirements shall be identified as ac-       ments shall be identified as acceptable     employed".
ceptable in accordance with the status        (see para. 5.4) and placed in a storage     Similar, Same Intent.
indicating system employed (see               area for acceptable items, or moved to Subsection 5.4 of this standard) and          the final location for installation or use.
placed in a storage area for acceptable items or moved to the final location for installation or use.
5.3.2 Nonconforming - Items                   5.3.2 Nonconforming. Items which            N45.2.2 adds the words which do not conform to the specified          do not conform to the specified             "identified...in accordance with the requirements shall be identified as           requirements shall be controlled in         system employed" whereas NQA-1 nonconforming.in accordance with the          accordance with Part I.                     uses the word "controlled in system employed (see Subsection 5.4                                                       accordance with Part 1."
of this standard) and when practical           Part I, Supplement 15S-1                   Similar, Same Intent.
the item shall be placed in a                 3 Segregation:
segregated storage area or removed            (a) Nonconforming items shall be from the project site to prevent                     segregated, when practical, by inadvertent installation or use.                     placing tem in a clearly identified and designated hold area until properly dispositioned.
(b) When segregation is impractical or impossible due to physical conditions such as size, weight, or access limitations, other precautions shall be employed to preclude inadvertent use of a nonconforming item.
5.3.3 Conditional Release -If the             5.3.3 Conditional Release. Ifthe            OK nonconformance which caused the                nonconformance that caused the item item to be classified "unacceptable"           to be classified unacceptable can be can be corrected after installation, the       corrected after installation, the item item may be released for installation          may be released for installation on a on a conditional release basis. A              conditional release basis. A statement statement documenting the authority            documenting the authority and and technical justification for the con-       technical justification for the ditional release of the item for               conditional release of the item for installation shall be prepared, and            installation shall be prepared and made part of the documentation,                made part of the documentation.
5.4 Status Indicating System                   5.4 Status Indicating System                N45.2.2 states that the system "shall be employed", NQA-1 does not use A system or method for identifying the         A status indicating system is a system      these words.
status of items (e.g. an inventory             or method for identifying the status of system, tagging, labeling, color code)         items (e.g., an inventory system, shall be employed that clearly                 tagging, labeling, color code) that indicates whether items are                    clearly indicates whether items are acceptable or unacceptable for in-             acceptable or unacceptable for stallation.                                    installation.
A controlled physical separation is an         A controlled physical separation is an      OK acceptable equivalent method.                  acceptable equivalent method.
The system shall indicate the date the         The system shall provide for indication     N45.2.2 states that "The use of the item was placed in the acceptable or           of the date the item was placed in the      system shall be regulated by the unacceptable installation status. The          acceptable oir unacceptable installation    Quality Control program." NQA-1 22 of 39                                                  7/27/10

Enclosure 4, Table 2 ANSI N45.2.2-1972 vs NQA-1-1994, Subpart 2.2 use OTtne system snail De reguiatea        status ana tne conaitionai reiease or by the Quality Control program. The        the items for installation pending the system shall provide for the conditional   subsequent correction of the noncon-release of items for installation          formance.
pending subsequent correction of the nonconformance.
When tags are used the stock shall be     When tags are used, the stock shall be   OK made from materal which will not           made from material that will not deteriorate during storage;                deteriorate during storage.
tags shall be securely affixed to the      Tags shall be securely affixed to the    OK items and displayed in an area that is     items and displayed in an area that is readily accessible.                        readily accessible.
The stock used shall not be                The stock used shall not be              OK deleterious to the item.                   deleterious to the item.
5.5      Correction of                     Supplement 15S-1 "Supplementary          NQA-1 does not include words "Ifthis Nonconformances                            Requirements for the Control of          is not possible, the item shall be Nonconforming Items"                     scrapped or otherwise discarded".
Items designated nonconforming or unacceptable for installation or use       Paragraph 4.4 shall be corrected using authorized procedures, to meet specified require-     Technical justification for the ments, or accepted "As is". If this is not acceptability of a nonconforming item, possible, the item shall be scrapped or    dispositioned repair, or use-as-is shall otherwise discarded.                       be documented.
5.5.1 Reinspection - Items that            Supplement 15S-1 "Supplementary          N45.2.2 provides greater detail as to have been corrected shall be               Requirements for the Control of          actions to take when it is determined reinspected. The area of inspection        Nonconforming Items"                     that the corrected item is satisfactory.
may be confined to the area of the nonconformance. When it has been           Paragraph 4.5 determined that the corrected item is satisfactory, the status of the item as    Repaired or reworked items shall be denoted by the system shall be             reexamined in accordance with changed to acceptable. An appropriate      applicable procedures and with the entry shall be made in the                 original acceptance criteria unless the documentation after acceptance is          nonconforming item disposition has determined.                                established alternate acceptance criteria.
5.6 Marking                                BR 8 "Identification and Control of      Slightly different words, but same Items"                                   intent.
Required marking shall be verified to provide positive identification during     Identification shall be maintained on receiving, storage, and installation,      items or in documents traceable to the Items not properly identified at           items, or in a manner which assures receiving may be marked using the          that identification is established and method in the appendix (see Appendix       maintained.
A 3.9 of this standard).
Changing, correcting or any other          5.5 Marking                              N45.2.2 uses the words "whose serial marking on Code Stamp name plate is                                                 number is applied" when referring to prohibited, unless authorized by the       Changing, correcting, or any other       who can authorize changes, etc.
manufacturer whose serial number is        marking on Code stamp nameplate          NQA-1 states "manufacturer of the applied,                                   shall be prohibited, unless authorized   item."
by the manufacturer of the item.
5.7 Documentation                          5.6       Documentation                  OK A written record of the receiving          A written record of the receiving inspection, package identification,        inspection, package identification, tagging, corrective actions, and           tagging, corrective actions, and jus-justification for conditional acceptance   tification for conditional acceptance shall be prepared.                         shall be prepared.
These records shall be made a part of      Basic Requirement 17 "Quality            OK the permanent records provided for in      Assurance Records" and QAPP B. 15 Section 8 of this standard.                "Records" detail requirements of records that need to be maintained.
: 6. STORAGE                                 6 STORAGE                                OK 6.1      General 23 of 39                                                7/2710

Enclosure 4, Table 2 ANSI N45.2.2-1972 vs NQA-1-1994, Subpart 2.2 U. I -ul lalt01 6.1.1 Scope. This Section contains 6.1.1 Scope. This section contains          requirements that shall be fulfilled by requirements that are to be fulfilled by    the organization responsible for the organization responsible for            performing the storage of items.
performing the storage of items.
Levels and methods of storage,              Levels and methods of storage are          NQA-1 adds some details on what necessary are defined to minimize the       defined to minimize the possibility of     lowering of quality could be due to.
possibility of damage or lowering of        damage or lowering of quality due to       N45.2.2 specifies the time frame as quality due to corrosion,                   corrosion, contamination,                  "upon receipt" whereas NQA-1 uses contamination, deterioration or             deterioration, or physical damage from     the term "from the time an item is physical damage from the time an item       the time an item is stored upon receipt    stored."
is stored upon receipt until the time the   until the time the item is removed from item is removed from storage and            storage and placed in its final location.
placed in its final location.
6.1.2 Levels of Storage.                    6.1.2 Levels of Storage.                   OK Environmental conditions for items          Environmental conditions for items classified as Levels A, B, C, and D         classified as Levels A, B, C, and D described in Subsection 2.7 of this         described in para. 2.2 shall meet the Standard shall meet requirements as         requirements as described in the described in the following paragraphs:      following paragraphs.
(1) Level A items shall be stored           (a) Level A items shall be stored under    OK under special conditions similar to.        special conditions similar to those those described for Level B items but       described for Level B items but with with additional requirements such as        additional requirements such as temperature and humidity control            temperature and humidity control within specified limits, a ventilation      within specified limits, a ventilation system with filters to provide an           system with filters to provide an atmosphere free of dust and harmful         atmosphere free of dust and harmful vapors, and any other appropriate           vapors, and any other appropriate requirements.                              requirements.
(2)       Level B items shall be stored     (b) Level B items shall be stored within   OK within a fire resistant, tear resistant,    a fire-resistant, tear-resistant, weather-weathertight, and well ventilated           tight, and well-ventilated building or building or equivalent enclosure,          equivalent enclosure. Precautions Precautions shall be taken against         shall be taken against vandalism.
vandalism.
This area shall be situated and            This area shall be situated and            OK constructed so that it will not be         constructed so that it will not be subject to flooding; the floor shall be    subject to flooding; the floor shall be paved or equal, and well drained,          paved or equal, and well drained.
Items shall be placed on pallets or        Items shall be placed on pallets or shoring to permit air circulation,         shoring to permit air circulation.
The area shall be provided with            The area shall be provided with            OK uniform heating and temperature            uniform heating and temperature control or its equivalent to prevent       control or its equivalent to prevent condensation and corrosion,                condensation and corrosion.
Minimum temperature shall be 40 F          The minimum temperature shall be           NOA-1 adds the Celsius equivalents.
and maximum temperature shall be           40OF (50 C), and the maximum 140 F or less ifso stipulated by a         temperature shall be 1400 F (60 0C) or manufacturer.                              less if so stipulated by the manufacturer.
(3)      Level C items shall be stored            (c) Level C items shall be stored   OK indoors or equivalent with all             indoors or in an equivalent provisions and requirements as set         environment with all provisions and re-forth in Level B items except              quirements as set forth for Level B that heat and temperature control is       items, except that heat and not required.                  -           temperature control is not required.
(4) Level D items may be stored            (d)Level D items may be stored             OK outdoors in an area marked and             outdoors in an area marked and designated for storage, which is well      designated for storage that is well drained, preferably gravel covered or      drained, preferably gravel covered or paved and reasonably removed from          paved, and reasonably removed from the actual construction area and traffic - the actual construction area and traffic 24 of 39                                                7/27/10

Enclosure 4, Table 2 ANSI N45.2.2-1972 vs NQA-1 -1994, Subpart 2.2 bU LIIdL PUbbIUIIILY VI UdIlIldyU IUIII     bU LI.IdL LIM  JVUblUIIILY UI UlCIyC   IIVUIII construction equipment is minimized.        construction equipment is minimized.
Items shall be stored on cribbing or       Items shall be stored on cribbing or equivalent to allow for air circulation     equivalent to allow for air circulation and to avoid traroino water.                and to avoid traoDina water.
6.2 Storage Areas                           6.2 Storage Areas                              N45.2.2 uses words "these requirements" whereas NQA-1 uses Periodic inspections   shall be            Periodic inspections shall be                  "applicable requirements" perfordic performed inetionsue    thall storage to assure that    sae           performed areas         to assure are being         that storage maintained    in areas are being maintained in ac-           ardane with aicable cordance with these requirements.           requirements.
The housekeeping requirements shall         NQA-1 Subpart 2.3 replaced N45.2.3.            Specific provisions of Subpart 2.3 be in accordance with N45.2.3.                                                             which are applicable to project activities will be defined in associated procedures.
6.2.1 Access to Storage Areas.              6.2.1 Access to Storage Areas.                 N45.2.2 states that access to storage Access to storage areas shall be            Access to storage areas for Levels A,          areas for all levels shall be controlled.
controlled and limited only to              B, and C items shall be controlled and         NQA-1 allows that "Access to storage personnel designated by the                 limited only to personnel designated by        areas involving Level D items shall responsible organization.                   the responsible organization. Access           be controlled as designated by the to storage areas involving Level D             responsible organization."
items shall be controlled as designated by the responsible organization.
6.2.2 Cleanliness and                       6.2.2 Cleanness and                            OK Housekeeping Practices.                     Housekeeping Practices.
Cleanliness and good housekeeping           Cleanliness and good housekeeping practices shall be enforced at all times    practices shall be enforced at all times in the storage areas. The storage           in the storage areas. The storage areas shall be cleaned as required to       areas shall be cleaned as required to avoid the accumulation of trash,            avoid the accumulation of trash, discarded packaging materials and           discarded packaging materials, and other detrimental soil.                     other detrimental soil.
6.2.3 Fire Protection. Fire protection      6.2.3 Fire Protection. Fire                    OK commensurate with the type of storage       protection commensurate with the type area and the material involved shall be     of storage area and the material in-provided and maintained.                    volved shall be provided and maintained.
6.2.4 Storage of Food and                   6.2.4 Storage of Food and                      OK Associated Items. The use or storage        Associated Items. The use or storage of food, drinks, and salt tablet            of food, drinks, and salt tablet dispens-dispensers in any storage area shall        ers in controlled storage areas shall not be permitted.                           not be permitted.
6.2.5 Measures to Prevent                   6.2.5 Measures to Prevent                      OK Entrance of Animals. Measures shall         Entrance of Animals.
be taken to prevent the entrance of         Measures shall be taken to prevent the rodents and other animals into indoor       entrance of rodents and other animals storage areas or equipment to               into indoor storage areas or minimize possible contamination and         equipment to minimize possible mechanical damage to stored material.       contamination and mechanical damage to stored material.
6.3 Storage Methods                         6.3 Storage Methods                            OK Storage methods and procedures shall        Storage methods and procedures shall comply with the requirements                comply with the requirements described in the following paragraphs.      described in the following paragraphs.
6.3.1 Ready Access to Stored                6.3.1 Ready Access to Stored                   OK Items. All items shall be stored in such    Items. All items shall be stored in such a manner as to permit ready access          a manner as to permit ready access for inspection or maintenance without       for inspection or maintenance without excessive handling, to minimize risk of     excessive handling to minimize risk of damage.                                     damage.
6.3.2 Arrangement of Items. Items           6.3.2 Arrangement of Items. Items              OK 25 of 39                                                      7/27/10

Enclosure 4, Table 2 ANSI N45.2.2-1972 vs NQA-1-1994, Subpart 2.2
  -L-Lt*U  lUl OLu  ye  allall
                         --    V alll.llyu     stacKed tor storage snail De arrangea so that racks, cribbing or crates are          sothat racks, cribbing, or crates are bearing the full weight without                bearing the full weight without 6.3.3Storage of Hazardous Material.            6.3.3 Storage of Hazardous                OK Hazardous chemicals, paints,                   Material. Hazardous chemicals, solvents, and other materials of a like        paints, solvents, and other materials of.
nature shall be stored in well ventilated      alike nature shall be stored in well-areas which are not in close proximity         ventilated areas and not in close to important nuclear plant items.              proximity to important nuclear plant items.
6.3.4 Identification. All items and            6.3.4 Identification. Items and their     OK their containers shall be plainly              containers shall be plainly marked so marked so that they are easily                 that they are easily identified without identified without excessive handling,         excessive handling or unnecessary or unnecessary opening of crates and           opening of crates and boxes.
boxes.
6.3.5 Coverings. Weatherproof                  6.3.5 Coverings. Weatherproof             OK covering, when used for outdoor                coverings, when used for outdoor storage, shall be flame-resistant type         storage, shall be the flame-resistant of sheeting or tarpaulins. They shall be       type of sheeting or tarpaulins. They placed so as to provide drainage and '         shall be placed so as to provide to insure air circulation to minimize          drainage and to ensure air circulation condensation. They shall be tied down          to minimize condensation. They shall to prevent moisture from entering laps         be tied down to prevent moisture from and to protect the coverings from wind         entering laps and to protect the damage.                                        coverings from wind damage.
6.3.6 Outdoor Storage. Items              These words are not in N45.2.2.
stored outdoors shall be positioned or covered to avoid trapping moisture in pockets or intemally. For example, valves shall be positioned such that water does not collect under the bonnet but can drain from the valve packing area.
6.4 Control of Items in Storage                6.4       Control of Items in Storage     OK Control of items in storage is                 Control of items in storage is described in the following paragraphs.         described in the following paragraphs.
6.4.1 Inspections and Examinations.            6.4.1 Inspections. Inspections shall      N45.2.2 contained the words "and Inspections and examinations shall be          be performed and documented on a         examinations". Similar, same intent.
performed and documented on a                  periodic basis to assure that the periodic basis to assure that the              integrity of the item and its container, integrity of the item and its container        as provided for under Section 3, is as provided for under Section 3 of this        being maintained.
standard is being maintained.
Deficiencies noted shall be corrected          Deficiencies noted shall be corrected    OK and documented.                                and documented.
The characteristics verified during this       The characteristics verified during this  OK inspection or examination shall include        inspection shall include such items as:
such items as:
(1)       Identification and marking (see      (a) identification and marking (see       OK Subsection 3.9 of this Standard).               para. 3.9)
(2)       Protective covers and seals          (a) protective covers and seals (see (see Subsection 3.9 of this standard).          para. 3.6)
(3)       Coatings and preservatives           (b) coatings and preservatives (see (see paragraph 3.4A1).                          para. 3.4.1)
(4)       Desiccants and inert gas             (c) desiccants and inert gas blankets blankets (see paragraph 3.6.3 and              (see paras. and 3.4.2) 3.4.2).                                        (d) physical damage (5)       Physical damage.                     (e) cleanness (6) Cleanness.
6.4.2       Care of Items. Care of items       6.4.2 Care of Items. Requirements         NQA-1 adds the parenthesis in storage shall be exercised in              for proper maintenance during storage     "(includes storage in place)".
accordance with the following,                 shall be documented. Care of items in Requirements for proper maintenance            storage (includes storage in place) 26 of 39-                                               7/27/10

Enclosure 4, Table 2 ANSI N45.2.2-1972 vs NQA-1 -1994, Subpart 2.2
                                                                                                        'Comments~
(NOTE: OK signifies identical or nearly identical wording) during storage shall be documented           bIUCII WWWAt!IL.IbU   III ClAVIUOI-. VVILII and written procedures or instructions      the following.
shall be established.
(1) Items in storage shall have all .        (a) Items in storage shall have all          OK covers, caps, plugs or other closures        covers, caps, plugs, or other closures intact. Methods used to seal openings        intact. Methods used to seal openings shall be in accordance with Section 3        shall be in accordance with Section 3.
of this standard. Covers removed for .       Covers removed for intemnal access internal access at any time for any         shall be immediately replaced and reason shall be immediately replaced         resealed after completion of the and resealed after completion of the         purpose for removal.
purpose for removal.
(2)      Temporary preservatives shall       (b)Temporary preservatives shall be          OK be left intact during storage. Should        left intact during storage. Should reapplication of preservatives be            reapplication of preservatives be required at the site, only those             required at the site, only those previously approved shall. be used,          previously approved shall be used.
(3)      Items pressurized with inert gas    (c) Items pressurized with inert gas         OK shall be monitored at such a frequency       shall be monitored at such a frequency as to insure that the gas pressure is        as to ensure that the gas maintained within specified limits          pressure is maintained within specified during storage. Desiccant humidity          'limits during storage. Desiccant indicators shall also be monitored and       humidity indicators shall also be desiccants shall be changed or re-           monitored, and desiccants shall be processed when specified.                    changed or reprocessed when specified.
(4)      Instrumentation racks shall be      (d) Instrumentation racks shall be           OK energized as specified by the                energized as specified by the manufacturer.                                manufacturer.
(5)      Space heaters enclosed in           (e)Space heaters enclosed in                 OK electrical items shall be energized.         electrical items shall be energized.
(6)      Rotating electrical equipment       (9~ Rotating electrical equipment shall      OK shall be given insulation resistance         be given insulation resistance tests on tests on a scheduled basis.                  a scheduled basis.
(7)      The shafts of rotating              (g)The shafts of rotating equipment          OK equipment shall be rotated on a              shall be rotated on a periodic basis.
periodic basis. The degree of turn shall     The degree of turn shall be be established so that the parts             established so that the parts receive a receive a coating of lubrication where       coating of lubrication, where applicable, and so that the shaft does       applicable, and so that the shaft does not come to rest in a previous position,     not come to rest in a previous position (90 deg. and 450 deg. rotations are         (90 deg. and 450 deg. rotations are examples.)                                   examples).
(8) Other maintenance                        (h)Other maintenance requirements            OK requirements specified by the                specified by the manufacturer's manufacturer's instruction for the item      instructions for the item shall be shall be performed.                     . performed.________________
6.4.3 Post Fire Evaluation. In the           6.4.3 Post-Fire Evaluation. In the           NQA-1 deletes the word "or" in the event a fire. should occur in the storage .event     a fire should occur inthe storage   following from N45.2.2 "in the event a area or at any time, each item known         area at any time, each item known to        fire should occur in the storage area to have been heated to an ambient            have been heated to an ambient               or at any time.."Additionally, NQA-1 temperature of over 150 F or                temperature of over 150OF (650C) or           adds the metric equivalent to the subjected to smobke contamination            subjected to smoke contamination             temperature.
shall be withheld from installation or       shall be withheld from installation or use until it has been thoroughly             use until it has been thoroughly examined and the item has been              examined, and the item has been verified to be in conformance with          verified to be in conformance with specified requirements.                      specified requirements.
6.5 Removal of Items from Storage            6.5 Removal of Items From                    OK Storage Only items which have been inspected         Only items which have been inspected and are considered acceptable for            and are considered acceptable for installation or use inaccordance with        installation or use in accordance with the receiving inspection procedure           the receiving inspection procedure shall be removed from storage for            shall be removed from storage for            ________________
27 of 397271                                              7/27/10

Enclosure 4, Table 2 ANSI N45.2.2-1972 vs NQA-1-1994, Subpart 2.2 installation or use. (See Section 5 of this standard.
this.sa.dar.....
Items released from storage and              Items released from storage and           OK placed in their final locations within the   placed in their final locations and items power plant, shall be inspected and          stored in place within the power plant cared for in accordance with the             shall be inspected and cared for in requirements of Section 6 of this            accordance with the requirements of standard, and other applicable               paras. 6.4.1 and 6.4.2 and other standards.                                   standards, as applicable.
6.6 Storage Records                          6.6 - Storage Records                     OK Written records shall be prepared that       include Written such  pertinent records  shall beinformation as prepared that include such pertinent information as        storage locatin, inspection     r   s storage location, inspection results,        storage location, inspection results, protection, and personnel access.            protection, and personnel access.
: 7. HANDLING                                   7 HANDLING                               N45.2.2 contains details for handling items, NQA-1 refers to another 7.1 General                                  7.1 General                               Subpart. QAPP Section 4.13 establishes general handling This section contains requirements           The requirements that shall be fulfilled  requirements. Specific provisions of that are to be fulfilled by the              by the organizations responsible for      Subpart 2.15 which are applicable to organizations responsible for handling       handling items are contained in           project activities will be defined in items. This section covers the               Subpart 2.15.                             associated procedures.
requirements for the handling of items in Subsection 2.7 of this standard utilizing appropriate equipment in accordance with methods and procedures specified to minimize damage and preserve the quality of the item and container.
7.2 Methods and Procedures                                                             N45.2.2 contains details for handling items, NQA-1 refers to another Detailed handling instructions and                                                     Subpart. QAPP Section 4.8 procedures shall be prepared for all                                                   establishes general handling items that require special handling                                                    requirements. Specific provisions of instructions because of weight, size,                                                  Subpart 2.15 which are applicable to susceptibility to shock damage, high                                                   project activities will be defined in nil ductility transition temperatures, or                                              associated procedures.
any other conditions that warrant special instructions.
Such instructions or procedures shall                                                  N45.2.2 contains details for handling be made available prior to the time the                                                items, NQA-1 refers to another item is to be handled and shall give                                                   Subpart. QAPP Section 4.13 weights, sling locations, balance                                                      establishes general handling points, methods of attachment,                                                         requirements. Specific provisions of maximum hoist line speeds and other                                                    Subpart 2.15 which are applicable to pertinent features to be considered as                                                 project activities will be defined in necessary for safe handling,                                                           associated procedures.
Items not specifically covered above                                                   N45.2.2 contains details for handling shall be handled in accordance with                                                    items, NQA-1 refers to another sound material handling practices.                                                     Subpart. QAPP Section 4.13 establishes general handling requirements. . Specific provisions of Subpart 2.15 which are applicable to project activities will be defined in associated procedures.
7.3 Hoisting Equipment                                                                 N45.2.2 contains details for handling items, NQA-1 refers to another All equipment for handling items shall                                                 Subpart. QAPP Section 4.13 be used and maintained in accordance                                                   establishes general handling with the following:                                                                    requirements. Specific provisions of Subpart 2.15 which are applicable to project activities will be defined in associated procedures.
7.3.1            Hoisting equipment used for                                           N45.2.2 contains details for handling 28 of 39                                                    7/27/10

Enclosure 4, Table 2 ANSI N45.2.2-1972 vs NQA-1-1994, Subpart 2.2 I id IUII ly Wlldll UV L I Ll III U UYLI IV manufacturer. The certification shall                                       Subpart. QAPP Section 4.13 indicate the various parameters for the                                     establishes general handling maximum load to be handled.                                                 requirements Specific provisions of Subpart 2.15 which are applicable to project activities will be defined in associated Drocedures.
7.3.2         Hoisting equipment shall not                                  N45.2.2 contains details for handling be loaded beyond its rated load, as                                         items, NQA-1 refers to another certified by the manufacturer, except                                       Subpart. QAPP Section 4.13 for test purposes.                                                          establishes general handling requirements Specific provisions of Subpart 2.15 which are applicable to project activities will be defined in associated procedures.
7.3.3        The requirements of ANSI                                      N45.2.2 contains details for handling B30.2.0, Safety Standard for                                               items, NQA-1 refers to another Overhead and Gantry Cranes, ANSI                                           Subpart. QAPP Section 4.13 B30.5, Safety Standard for Crawler,                                        establishes general handling Locomotive and Truck Cranes, ANSI                                          requirements. Specific provisions of B30.6, Safety Standard for Derricks,                                       Subpart 2.15 which are applicable to and ANSI A10.5, Safety Requirements                                        project activities will be defined in for Material Hoists shall be followed.                                     associated procedures.
7.3.4        For special lifts, hoisting                                   Specific provisions of Subpart 2.15 equipment may be re-rated, or                                              which are applicable to project modified and re-rated, upon approval                                       activities will be defined in associated by the manufacturer or if the                                              procedures.
manufacturer's specifications are not available, the limitations assigned to-the equipment shall be based on the determinations of a qualified engineer competent in this field and such determination shall be documented and recorded appropriately. Re-rated equipment shall be given a dynamic load test over the full range of the lift using a test weight at least equal to the lift weight. A dynamic test includes raising, lowering and traversing the load in contrast to a static test where the test weight may be increased incrementally with no movement.
7.4 Inspection of Equipment and                                             N45.2.2 contains details for handling Rigging                                                                     items, NQA-1 refers to another Subpart. QAPP Section B.7 An inspection program shall be                                             establishes general handling established for equipment and rigging.                                      requirements. Specific provisions of A system shall be established that will                                     Subpart 2.15 which are applicable to indicate acceptability of all equipment                                     project activities will be defined in and rigging after each inspection. This                                     associated procedures.
system shall specify control of nonconforming lifting equipment.
Periodic inspections shall be supplemented with special visual and non~destructive examinations and dynamic load tests prior to handling of items described in Subsection 7.2 of this standard.
7.4.1 Rigging that is frayed, worn or                                       N45.2.2 contains details for handling otherwise deteriorated shall not be                                         items, NQA-1 refers to another used.                                                                       Subpart. QAPP Section 4.13 establishes general handling requirements Specific provisions of Subpart 2.15 which are applicable to project activities will be defined in associated procedures.
29 of 39                                             7/27/10

Enclosure 4, Table 2 ANSI N45.2.2-1972 vs NQA-1 -1994, Subpart 2.2 1.1-L   1 VOI iV I44J     IL LIHL
                                  - JIJO not meet manufacturer's specifications                                            items, NQA-1 refers to another shall not be used.                                                                Subpart. QAPP Section 4.13 establishes general handling requirements. Specific provisions of Subpart 2.15 which are applicable to project activities will be defined in associated procedures 7.4.3 Equipment and rigging shall be                                              N45.2.2 contains details for handling kept clean and free of contaminants                                               items, NQA-1 refers to another that are detrimental to the material                                               Subpart. QAPP Section 4.13 being handled.                                                                    establishes general handling requirements. Specific provisions of Subpart 2.15 which are applicable to project activities will be defined in associated procedures.
7.4.4 Rigging items such as hooks,                                                N45.2.2 contains details for handling shackles, and tumbuckles that appear                                               items, NQA-1 refers to another to have yielded or are distorted shall                                             Subpart. QAPP Section 4.13 not be used.                                                                      establishes general handling requirements. Specific provisions of Subpart 2.15 which are applicable to project activities will be defined in associated procedures.
7.5 Personnel                               Supplement 13S-1 "Supplementary        Slightly different words, but same Requirements for Handling, Storage,    intent.
The responsible organization shall          and Shipping" determine that the personnel engaged in operating material handling              Section 3.4 equipment are competent and have demonstrated satisfactory ability in        Operators of special handling and operating similar lifting equipment.        lifting equipment shall be experienced or trained in use of the equipment.
: 8.      RECORDS                             8 RECORDS                              N45.2.2 uses "completed procedures", NQA-1 states Record copies of completed                  Record copies of procedures, reports,  "procedures" and N45.2 uses procedures; reports; personnel              personnel qualification records, test  "inspection and examination records" qualification records; test equipment       equipment calibration records, test    whereas NQA-1 states "inspection calibration records; test deviation or      deviation or exception records, and    records".
exception records; and inspection and       inspection records shall be prepared   Similar, Same Intent.
examination records shall be prepared       as required by this Subpart.
as required by this standard.
These records shall be placed with          These records shall be retained with   N45.2.2 uses the word "placed",
other project records as required by        other project records as required by   NQA-1 uses the word "retained".
code, standard, specification or project    code, standard, specification, or procedures.                                 project procedures.
: 9. AMERICAN NATIONAL                                                               N/A- These words are not contained STANDARDS REFERRED TO IN                                                   in NQA-1 nor would they be expected THIS DOCUMENT                                                              to be.
When the following standards referred to in this document are superseded by a revision approved by the American National Standards Institute, the re-vision shall apply:
N45.2 Quality Assurance Program Requirements for Nuclear Power Plants
*N4523       Housekeeping During the Construction Phase of Nuclear Power Plants
*N45.2.6 Qualifications of Quality Assurance Personnel for the 30 of 39                                                 7/27/10

Enclosure 4, Table 2 ANSI N45.2.2-1972 vs NQA-1 -1994, Subpart 2.2 uonstruction Plants
*N45.2.10 Quality Assurance Terms and Definitions MH 6.1 Pictorial Markings for Handling of Goods B30.2.0 Safety Code for Overhead and Gantry Cranes B30.S Safety Code for Crawler, Loco-motive, and Truck Cranes B30.6 Safety Code for Derricks A10.5 Safety Requirements for Material Hoists
 *The standards are being approved by the American National Standards Institute and they should be available early in 1973.                           -.4                                        I.
: 10. APPENDIX A3 PACKAGING                                                                           The specified requirements are now included in the body of NQA-1, The following are additional minimum                                                   Subpart 2.2.
requirements to be used with the rules of Section 3 of N45.2.2: "Packaging, Shipping, Receiving, Storage and Handling of Items for Nuclear Power Plants".
A3.3 Cleaning                                3.3 Cleaning The following general        OK criteria shall apply as part of the Specific cleaning procedures are             manufacturing specifications specific considered to be part of the                 cleaning procedures.
manufacturing specifications. The fol-lowing general criteria shall apply:
(1) The cleaning process including           (a) The cleaning process, including       OK cleaning compounds chosen shall in           cleaning compounds chosen, shall in no way damage the item during                no way damage the item during cleaning or subsequent service when          cleaning or subsequent service when considering the composition, surface         considering the composition, surface finish, complexity or other inherent         finish, complexity, or other inherent features or other interface equipment        features, or other interface equipment after installation,                          after installation.
(2) The cleaning process or                  (b) The cleaning process or processes     OK processes chosen shall remove loose          chosen shall remove loose mill and mill and heat scale, oil, rust, grease,      heat scale, oil, rust, grease, paint, paint, welding fluxes, chalk, abrasives,     welding fluxes, chalk, abrasives, carbon deposits, coatings used for           carbon deposits, coatings used for nondestructive testing processes and         nondestructive testing processes, and other contaminants which would               other contaminants that would render render ineffective the method of             ineffective the method or preservation preservation and packaging, or other         and packaging or other specified specified requirements.                      requirements.
(3) Item surfaces after cleaning shall       (c) Item surfaces after cleaning shall    OK be free of cleaning media, such as           be free of cleaning media, such as aluminum oxide, silica, grit, lint,          aluminum oxide, silica, grit, lint, chemical cleaning residue, petroleum         chemical cleaning residue, and solvent residue, etc.                        petroleum solvent residue, etc.
(4) After cleaning, the item shall be        (d) After cleaning, the item shall be     OK protected from contamination until           protected from contamination until preservation or packaging is complete.,      preservation or packaging is complete.
31 of 39                                              7/27/10

Enclosure 4, Table 2 ANSI N45.2.2-1972 vs NQA-1 -1994, Subpart 2.2
           *&#xfd;UIq.
I    ll&#xfd;L r VI     b
                              &#xfd;l VOL]VV&#xfd;. 11I1V following criteria shall be used when             The following criteria shall be used considering the type of contact                   when considering the type of contact preLerv     -S     euseU    .                preserva  vOLV   SUOJO (1)The contact preservative shall be              (a) The contact preservative shall be      OK compatible with the material on which             compatible with the material on which it is applied,                                    it is applied.
(2) Contact preservatives which are               (b) Contact preservatives which are        OK nondrying shall require a neutral-                nondrying shall require a neutral grease-proof protective wrap when                 grease-proof protective wrap when packaged.                                         packaged.
(3)            The procedure for applying         (c) The procedure for applying contact     OK contact preservatives shall not require           preservatives shall not require disassembly of the item nor shall it be           disassembly of the item nor shall it be necessary to disassemble the item at              necessary to disassemble the item at the site for complete removal. An                 the site for complete removal. An exception would be for long term                  exception would be for long-term storage protection to be agreed upon              storage protection to be agreed upon by the owner, buyer and manufacturer.            by the owner, buyer, and manufacturer.
(4)            The method of contact              (d) The method of contact preservative     N45.2.2 states "...shall be indicated preservative removal shall be                    removal shall be accomplished with         to facilitate touch-up" whereas NQA-1 accomplished with approved solvents              approved solvents and wiping cloths or     states "shall be the water flushable and wiping cloths or by flushing                  by flushing internal cavities with sol-    type" internal cavities with solvents which            vents which are not deleterious to the are not deleterious to the item or other          item or other interconnecting material.
interconnecting material. However,               However, preservatives for preservatives for inaccessible inside            inaccessible inside surfaces of pumps, surfaces of pumps, valves and pipe for           valves, and piping for systems systems containing reactor coolant               containing reactor coolant water shall water shall be indicated to facilitate            be the water flushable type.
touch-up.
(5)            The name of the                    (e) The name of the preservative used      In regards to the name of the preservative used shall be the water             shall be provided to facilitate touch-up. preservative used, N45.2.2 states flushable type.                                                                              "...shall be the water flushable type" whereas NQA-1 states "shall be provided to facilitate touch-up" (6)           When motors, pumps,                (f) When motors, pumps, turbines,          OK turbines, etc., are shipped with oil             etc., are shipped with oil reservoirs reservoirs and bearings cavities filled          and bearing cavities filled with with preservative oil, the item shall be         preservative oil, the item shall be so so tagged and instructions for draining,         tagged and instructions for draining, flushing, refilling and periodic rotation        flushing, refilling, and periodic rotation shall be included with the item.                 shall be included with the item.
(7)           When it is anticipated that        (g) When it is anticipated that the item   OK the item might require an extended               might require an extended storage storage period, six (6) months or                period (6 months or longer), a longer, a preservative needed for the            preservative needed for the long-term long term protection of the item shall           protection of the item shall be applied be applied or arrangements shall be              or arrangements shall be made to made to periodically reapply the                 periodically reapply the preservatives.
preservatives.
A3.4.2 Inert Gas Blankets. When                  3.4.2 Inert Gas Blankets.                  OK inert gas blankets are used, the                 When inert gas blankets are used, the following criteria shall apply:                  following criteria shall apply.
(1)            Inert gas blankets shall be       (a)lnert gas blankets shall be used        N45.2.2 states "to form a leak-proof used only when the exterior shell of             only when the exterior shell of the item   barrier" whereas NQA-1 states "or an the item or its container can be tightly         or its container can be tightly sealed or  inert gas blanket can otherwise be sealed to form a leak-proof barrier,             an inert gas blanket can otherwise be      maintained."
maintained.
(2)            Only a commercial grade of         (b) Only dry, oil free, inert gas shall be NQA-1 deleted the words dry, oil-free, inert gas shall be used.           used.                                      "commercial grade" (3)            Provisions shall be made for       (c) Provisions shall be made for           NQA-1 adds words "when used to measuring and maintaining the blanket            measuring and maintaining the blanket      maintain a static pressure" pressure withinthe required range                pressure within.the required range and within each pressurized purged item or            within each pressurized purged item or 32 of 39                                                  7/27/10

Enclosure 4, Table 2 ANSI N45.2.2-1972 vs NQA-1 -1994, Subpart 2.2 container. uiosures anru zeuali iwlil [     LoUlILdIlItH.   %,WU:SU bd     11::lU btV;*d1b,' WV IIt:
tightly secured so that the absolute (by    used to maintain a static pressure, mass) pressure after final seal is          shall be tightly secured so that the maintained for 24 hours without adding      absolute pressure (by mass) after final gas, prior to shipping the item from the    seal is maintained for 24 hr, without manufacturer's plant.                       adding gas, prior to shipping the item II -l f11 4H HUHOULJ
                                                      .I*I1{11-IUII. U -l;
                                                                                ~IO S E
                                                                                       +
                                                                                   ."aI.
(4)     The item or container shall be      (d) The item or container shall be                     OK marked in bold letters cautioning that      marked in bold letters cautioning that an inert gas blanket has been used.         an inert gas blanket has been used.
The required pressure range also shall      The required pressure range also shall be marked on the item or container,         be marked on the item or container.
A3.5.1 Caps and Plugs. Caps and             3.5.1 Caps and Plugs.                                  OK plugs shall conform to the following        Caps and plugs shall conform to the criteria:                                   following criteria.
(1)         Nonmetallic plugs and caps      (a) Nonmetallic plugs and caps shall                   NQA-1 adds the words "or shall be brightly colored. Clear plastic    be brightly or contrastingly colored,                  contrastingly" when detailing color closures are not to be used except          Clear plastic closures are not to be when specified for a special purposew       used except when specified for a for example, as a window for humidity       special purpose: for example, as a indicator cards. Special attention shall    window for humidity indicator cards.
be given in the control of these            Special attention shall be given in the closures,                                   control of these closures.
(2)         Metallic plugs and caps         (b) Metallic plugs and caps contacting                 OK contacting metal surfaces shall not         metal surfaces shall not cause cause galvanic corrosion at the             galvanic corrosion at the contact contact areas. Gasketing or other           areas. Gasketing or other nonmetallic nonmetallic materials used in               materials used in conjunction with conjunction with metallic caps or plugs     metallic caps or plugs shall exhibit no shall exhibit no corrosive effect on the    corrosive effect on the material.
material.
(3)         Simplicity of installation,     (c) Simplicity of installation, inspection,            OK inspection, and removal without             and removal without damage to the damage to the item shall be                 item shall be considered.
considered.
(4)         Provisions shall be made to     (d) Provisions shall be made to                        OK preclude the plug or cap from falling       preclude the plug or cap from falling into or being pushed into the opening       into or being pushed into the opening after its installation,                     after its installation.
(5)         Plugs or caps shall be          (e) Plugs or caps shall be secured with                OK secured with tape (see paragraph            tape (see para. 3.5.2) or other means A3.5.2 of this Appendix) or other           as necessary to prevent accidental means as necessary to prevent ac-           removal.
cidental removal.
(6)         All plugs and caps shall be     (f) All plugs and caps shall be clean                  OK clean and free of visible contamination     and free of visible contamination such such as, but not limited to dust, dirt,     as, but not limited to, dust, dirt, stains, stains, rust, discoloration or scale.       rust, discoloration, or scale.
(7)         Plugs and caps used in          (g) Plugs and caps used in contact                     OK contact with austenitic stainless steel     with austenitic stainless steel shall be shall be made from nonhalogenated           made from nonhalogenated materials.
materials or stainless steel.               or stainless steel.
A3.5.2 Tapes and Adhesives. Tapes           3.5.2 Tapes and Adhesives. Tapes                       OK and adhesives shall conform to the          and adhesives shall conform to the following criteria:                         following criteria.
(1)         When contacting austenitic      (a) When contacting austenitic                         OK stainless steel and nickel alloy            stainless steel and nickel alloy surfaces:                                   surfaces:
(a) The halogen and sulfur contents         (1) tapes shall not be compounded                      N45.2.2 states that contents "should of tapes should not be in excess of         from or treated with chemical                          not be in excess of 0.10% by weight 0.10% by weight each. Paperbacked           compounds containing elements in                       each" whereas NQA-1 provides more (masking) tape shall not be used.           such quantities that harmful                           detail but does not specify a %.
concentrations are leachable, or that they could be released by breakdown under expected environmental conditions and could contribute to 33 of 39                                                        7/27/10

Enclosure 4, Table 2 ANSI N45.2.2-1972 vs NQA-1-1994, Subpart 2.2 corrosion cracking, such as those containing fluorides, chlorides, sulfur, lead, zinc, copper, and mercury
[paperbacked (masking) tape shall not be usedl:
(b) Upon removal of tape, all residual      (2) upon removal of tape, all residual   OK adhesive shall be removed by a non-       . adhesive shall be removed by wiping halogenated solvent (acetone, alcohol       with a nonhalogenated solvent or equal) wiping.                            (acetone, alcohol, or equal);
(c) Starch, silicone and epoxy type         (3) starch, silicone, and epoxy tape     OK material may be used for tape -             material may be used for tape adhesives.                                  adhesive.
(2)        When contacting other            (b) When contacting other surfaces       OK surfaces and containers:                    and containers:
(a) Tapes and adhesives used to             (1) tapes and adhesives used to seal     OK seal nonaustenitic materials or             nonaustenitic materials or containers containers are not subject to the above     are not subject to the above restrictions.                               restrictions; (b) Tape shall be impervious to             (2) tape shall be impervious to water    OK water and not subject to cracking or        and not subject to cracking or drying drying out if exposed to sunlight, heat     out if exposed to sunlight, heat, or or cold.                                    cold.
(3)        Tapes should be brightly         (c) When used on surfaces of items,      N45.2.2 and NQA-1 use different colored to preclude their loss into a       tapes shall be visibly distinguishable. words but the intent is same.
system.                                     from the materials on which they are used.
A3.6.2 Vapor Barrier Material. When         3.6.2 Vapor Barrier Material. When       OK maximum vapor protection is required,       maximum vapor protection is required, barrier material shall meet the             barrier material shall meet the maximum water vapor transmission            maximum water vapor transmission rate of 0.05 grams per 100 square           rate of 0.05 g/1 00 sq in. per 24 hr inches per 24 hours per ASTM E96            required by ASTM E 96, Test Methods Tests for Water Vapor Transmission          for Water Vapor Transmission of Of Materials In Sheet Form, Procedure       Materials, Procedure E, and shall be E and shall be packaged with an             packaged with an approved desiccant.
approved desiccant.
The barrier material should be brightly     Vapor-proof barrier material should be   N45.2.2 and NQA-1 use different colored to preclude loss within a           colored to contrast with the material on words but the intent is same.
 -system.                                     which it is used.
A3.6.3 Desiccants. Desiccants shall         3.6.3 Desiccants. Desiccants shall       OK consist of nondeliquescent,                 consist of nondeliquescent, non-nondusting, chemically inert, de-           dusting, chemically inert, dehydrating hydrating agents.                           agents.
The following criteria apply when they      The following criteria shall apply.      OK are used.
(1)         When used with austenitic       (b) When used with austenitic            N45.2.2 is limited to austenitic stainless steels, the desiccant and the     stainless steel and nickel alloy         stainless steels and specifies that the bag material shall not have a halogen       materials, tapes, desiccants, and the    halogen content shall not be over content over 0.25%.                         materials for the desiccant bag shall    0.25% whereas NQA-1 adds "and not be compounded from or treated        nickel alloy materials, tapes" and with chemical compounds containing       does not provide a specific content elements in such quantities that         level.
harmful concentrations are leachable, or they could be released by breakdown under expected environmental conditions and could contribute to intergranular cracking or stress corrosion cracking, such as those containing fluorides, chlorides, sulfur, lead, zinc, copper, and mercury.
The desiccant bag shall be made of          (a) The desiccant bag shall be made      OK puncture, tear and burst resistant          of puncture-, tear-,and burst-resistant material,                                   material.
_(2)          The reactivation                (c) The reactivation temperature and     OK 34 of 39                                                7/27/10

Enclosure 4, Table 2 ANSI N45.2.2-1972 vs NQA-1-1994, Subpart 2.2 W[e1pu UdLUr[ dIIU LlmtI brFdll Ut mrfdIKkU on the desiccant container.                   container.
(3)         Canisters used to contain         (d) Canisters used to contain            OK desiccants shall be placed so as to           desiccants shall be placed so as to cause no deleterious effects such as          cause no deleterious effects such as galvanic corrosion, even when the             galvanic corrosion, even when the desiccant has reached its absorptive          desiccant has reached its absorptive capacity for water vapor,                     capacity for water vapor.
(4)         Desiccant bags and                (e) Desiccant bags and canisters,        OK canisters, when used, shall be secured        when used, shall be secured to to prevent movement, rupture of the           prevent movement, rupture of the bags, or damage to the item being             bags, or damage to the item being protected.                                    protected.
(5)         Water-vaporproof flexible         (f) Water - and vapor-proof flexible     OK barriers shall be used to seal items          barriers shall be used to seal items containing desiccants. The included air       containing desiccants. The included air volume within the flexible barrier shall      volume within the flexible barrier shall be kept to a minimum,                         be kept to a minimum.
(6)         Items which contain               (g) Items that contain desiccants shall  OK desiccant shall have all openings             have all openings securely sealed.
securely sealed. When flange con-             When flange connections are a part of nections are a partof the barriers, 0-        the barriers, 0-rings or gaskets shall rings or gaskets shall be used with all       be used with all bolts in place and bolts in place and tightened sufficiently     tightened sufficiently to ensure a to insure a water-vaporproof seal.            water- and vapor-proof seal. Weld end Weld end preparations, after capping,         preparations, after capping, shall be shall be covered with a water-vapor           covered with a water- and vapor-proof proof seal.                                   seal.
(7)         Packages and items                (h) Packages and items containing        N45.2.2 uses words "and/or" when containing desiccant shall be marked.         desiccants shall be marked. The total    detailing bags and containers The total number of separate bags             number of separate bags or containers    whereas NQA-1 uses the word "or" and/or containers in the package shall        of desiccants in the package shall be be indicated,                                 indicated.
(8) The minimum quantity of                   (i) The minimum quantity of desiccant    OK desiccant for use in each package             for use in each package shall be shall be determined in accordance             determined in accordance with with Formula I or Formula II, as              Formula I or Formula II, as applicable.
applicable.
Formula I: To determine minimum of            Formula I                                OK desiccant for use with other than             To determine minimum units of sealed rigid metal barrier:                   desiccant for use with other than U=I .6A plus XD.                              sealed rigid metal barrier:
U = 1.6A + XD Formula II: To determine minimum              Formula II                               OK units of desiccant for use within sealed          To determine minimum units of rigid metal barrier:                              desiccant for use with sealed rigid metal barrier:
SU= KV plus XD.
U=KV+XD 35 of 39                                                7/27/10

Enclosure 4, Table 2 ANSI N45.2.2-1972 vs NQA-1-1994, Subpart 2.2 In the above formulas:                      where                                      NQA-1 added metric equivalents 2
A= Areas of barrier in square feet            A = area of barrier, sq ft (m x U= Number of units* of desiccant to           0.0929) be used                               U = number of units of desiccant to be used (see Note)
D=Pounds of dunnage (other than                D = dunnage (other than metal) metal) within barrier                          within barrier, lb (kg x 2.2)
K= 0.0007 when volume is given in              K 0.0007 when volume is given cubic inches                                   in cu in.
K= 1.2 when volume is given in                   = 1.2 when volume is given in cubic feet                                     cu ft V=Volume within barrier in cubic                 =0.000042 5 when volume is given in cm3 (42.5 in M )
* inches or cubic feet                                                      3 X= 8 for hair felt, cellulosic material        V= volume within barrier in cu in.
3      3 (including wood) and other                   or cu ft (cm or M )
material not categorized below           X = 8 for hair felt, cellulosic X= 6 for bound fibers (animal hair,                material (including wood), and synthetic fiber or vegetable fiber           other material not categorized bound with rubber)                           below X= 2 for glass fiber                             = 6 for bound fibers (animal hair, X= 0,5 for synthetic foams and                     synthetic fiber, or vegetable rubber                                       fiber bound with rubber)
                                                    = 2 for glass fiber
                                                    = 0.5 for synthetic foams and rubber
*A desiccant unit is that quantity of        NOTE:        A desiccant unit is that*    NQA-1 added English unit equivalent desiccant, as received, which will           quantity of desiccant, as received, that  for temperature.
absorb at equilibrium with air at 25 C       will absorb at equilibrium with air at at least the following quantities of         78OF (250C) at least the following water vapor: 3.00 grams at 20%               quantities of water vapor: 3.00 g at 20 relative humidity and 6.00 grams at          % relative humidity and 6.00 g at 40%
40% relative humidity.                       relative humidity.
(9)          A humidity indicator shall be   6) A humidity indicator shall be          OK included in every water-vaporproof           included in every water- and vapor-envelope containing desiccant. As            proof envelope containing desiccant:
applicable, the indicator shall be           As applicable, the indicator shall be located behind inspection windows or         located behind inspection windows or immediately within the closing edge,         immediately within the closing edge, face, or cover of the barrier, and as far face, or cover of the barrier and, as far as practical from the nearest unit of        as practical, from the nearest unit of desiccant.                                   desiccant.
A3.7.1 Fiberboard Boxes. The                 3.7.1 Containers The following criteria   OK following criteria apply for fiberboard
* shall apply for fiberboard boxes used boxes used as exterior containers:           as exterior containers.
(1)           Boxes shall be weather-        (1) Boxes shall be weather-resistant      OK resistant fiberboard preferably from the fiberboard preferably from the grade following grade types (or compliance         types (or compliance symbol): V2 s, symbol): V2 s, V3 s. or V3 c. (Federal       V3 s, or V3 c (Federal Specification Specification PPP-B-636.)                    PPP-B-636).
(2)           Box style shall be RSC -       (2) Box style shall be RSC regular        OK Regular slotted box, (Outer flaps meet,     slotted box (outer flaps meet, inner inner flaps and outer flaps are of equal    flaps and outer flaps are of equal length).                                    length).
(3).          Fiberboard boxes shall be      (3) Fiberboard boxes shall be securely    NQA-1 added metric equivalents securely closed with a water resistant       closed with a water-resistant adhesive adhesive applied to the entire area of       applied to the entire area of contact contact between the flaps. All seams,        between the flaps. All seams and and joints shall be further sealed with " joints shall be further sealed with not not less than two inch wide, water          less than 2 in. (5 cm) wide, water-resistant tape.                             resistant tape.
(4)           Boxes shall be strapped with (4) Boxes shall be strapped with            OK 36 of 39                                             7/27/10

Enclosure 4, Table 2 ANSI N45.2.2-1972 vs NQA-1-1994, Subpart 2.2
 .il I t:b uICt*-tl I*ILIVC CI  l11IIU L.C:U t~Cl*     pressure-sensitive reinforced tape, length-wise (top, bottom and ends),               lengthwise (top, bottom, and ends),
girthwide (top, bottom and sides) and             girthwise (top, bottom, and sides), and horiznntal sides and e~nds.                       horizontal sides~ and ends.
(5)           Wood cleating on fiberboard         (5) Wood cleating on fiberboard boxes      OK boxes shall be fabricated from sound,             shall be fabricated from sound, well-well-seasoned lumber.                             seasoned lumber.
A3.8.1 Cushioning. Selection of                   3.8.1 Cushioning. Selection of             OK cushioning materials shall be based on            cushioning material shallbe based on the following:                                    the following.
(1)           It shall exhibit no corrosive        (a) It shall exhibit no corrosive effect  OK effect when in contact with the item              when in contact with the item being being cushioned.                                  cushioned.
(2)           It shall have, low moisture         (b) It shall have low moisture content     OK content and exhibit low moisture                  and exhibit low moisture absorption absorption properties; or if the                   properties, or if the cushioning material cushioning material has some                       has some moisture absorbing moisture absorbing capacity, the item              capacity, the item shall be protected shall be protected with a water vapor-            with a water-vaporproof barrier.
proof barrier.
(3)           It shall have negligible             (c) It shall have negligible dusting      OK dusting characteristics.                           characteristics.
(4)           It shall not readily support         (d)Itshall not readily support            OK combustion.                                        combustion.
A3.8.3 Anchoring. When bolts are                   3.8.3 Anchoring. When bolts are           OK used for anchoring the following                   used for anchoring, the following criteria shall apply.                              criteria shall apply.
(1) If precision bolt holes in the item            (a) If precision bolt holes in the item   OK are used for anchoring, precaution                 are used for anchoring, precaution shall be taken to insure that properiy             shall be taken to ensure that properly fitting bolts of the correct dimension             fitting bolts of the correct dimension and characteristics are used to prevent            and characteristics are used to prevent marring or elongation of the holes,               marring or elongation of the holes.
(2) .         Holes bored through                  (b) Holes bored through containers or     OK containers or mounting bases shall                 mounting bases shall provide a snug provide a snug fit.                               fit.
(3) When mounting items to container               (c) When mounting items to container      N45.2.2 states that counter-sinking bases equipped with skids, bolts shall            bases equipped with skids, bolts shall    "is necessary" whereas NQA-1 states be extended through the skids                     be extended through the skids             "shall be done" whenever practical. In such instances              whenever practical. In such instances, counter-sinking of the bolt in the                countersinking of the bolts in the sliding surface of the skid is                    sliding surface of the skid shall be necessary.                                        done.
(4)          Washers shall be used                (d) Washers shall be used under the       OK under the nuts to decrease the                    nuts to decrease the possibility of the possibility of the bolt pulling through           bolt pulling through the wood.
the wood.
(5)          Nuts shall be properly               (e) Nuts shall be properly tightened. OK torqued. To prevent their loosening               To prevent their loosening during during shipment, lock nuts, lock                  shipment, lock nuts, lock washers, washers, cotter pins, or staking shall            cotterpins, or staking shall be be employed,                                      employed.
A3.9 Marking                                      3.9 Marking Items shall be marked to      OK preserve identity in accordance with Items shall be marked to preserve                 the following criteria.
identity in accordance with the following criteria:
(1)          The specified identification         (a) The specified identification shall be NQA-1 added metric equivalents shall be stamped, etched, stenciled or            stamped, etched, stenciled, or otherwise marked on the item or on                otherwise marked on the item or on tags to be affixed securely to the item           tags to be affixed securely to the item in plain, unobstructed view: When                 in plain, unobstructed view. When metal stamps are employed, low                    metal stamps are employed, low stress rounded bottom type stamps                 stress, rounded bottom type stamps shall be used when the item proper is             shall be used when the item proper is 37 of 39                                              7/27/10

Enclosure 4, Table 2 ANSI N45.2.2-1972 vs NQA-1-1994, Subpart 2.2 marked. When vibrating marking tools       11 dr10- U. VVI11W1 V-1  II*
11VllC I 1*1- 111V U*I are used they shall be fitted with a       are used, they shall be fitted with a carbide marking tip or equivalent and      carbide marking tip or its equivalent, shall be designed to provide a rounded     and shall be designed to provide a impression not to exceed 0.0 10            rounded impression not to exceed inches in depth. Etching shall not be      0.010 in. (0.25 mm) in depth. Etching used on nickel alloys or on weld areas     shall not be used on nickel alloys, weld or sensitized areas of stainless steel. areas, or sensitized areas of stainless Electric arc marking pencils shall not     steel. Electric-arc marking pencils shall be used.                                   not be used.
(2)        The marking shall not be        (b) The marking shall not be                    OK deleterious to the material nor violate    deleterious to the material nor violate any other section of this standard.        any other Section of Subpart 2.2.
(3)        When tags are employed,        .(c) When tags are employed, they                OK they shall be of a material which will     shall be of a material which will retain retain the marking, withstand              the marking, withstand weathering weathering deterioration, and other        deterioration, and other normal normal shipping and handling effects       shipping and handling effects, and and shall not be detrimental to the        shall not be detrimental to the item.
item.
(4)        The English language shall      (d) The English language shall be               OK be used. Duplicate marking may be          used. Duplicate marking may be made made in other languages.                   in other languages.
(5)        References to weights shall     (e) References to weights shall be in           OK be in avoirdupois units. Duplicate         avoirdupois units. Duplicate markings markings in other systems may also         in other systems may also be be indicated,                              indicated.
Markings on the outside container          Markings on the outside container               OK shall be in accordance with the            shall be in accordance with the following criteria:                       following criteria.
(1)        Container markings shall        (a) Container markings shall appear             OK appear on a minimum of two sides of        on a minimum of two sides of a the container, preferably on one side      container, preferably on one side and and one end..                             one end.
(2)        The English language shall      (b) The English language shall be               OK be used. Duplicate marking may be         used. Duplicate marking may be made made in other languages or in pictorial   in other languages or in pictorial markings according to ISO                  marking according to ISO Recommendation R780 Pictorial              Recommendation R780, Pictorial Markings For Handling of Goods             Markings for Handling of Goods (general symbols) or ANSI MH6.1.          (general symbols) or ANSI MH6. 1.
(3)        References to weights shall    (c) References to weights shall be in            OK be in avoirdupois units. Duplicate        avoirdupois units. Duplicate markings marking in other systems mayalso be       in other systems may also be indicated,                                indicated.
(4)         Container markings shall be    (d) Container markings shall be                  N45.2.2 details that "characters no applied .with waterproof ink or paint in   applied with waterproof ink or paint in          less than 3/4 inch high, container size characters no less than 3/4 inch high,    characters that are legible. When                permitting" be used whereas NQA-1 container size permitting.                information relative to handling and             states "in characters that are legible" special instructions is required, such           and then provides additional details information shall be preceded by the             on special instructions.
word CAUTION in letters that are at least 1/2 in. (12.7 mm), as permitted by container size.
(5)        Where tags or labels are       (e) Where tags or labels are used,               OK used, they shall be affixed to the         they shall be affixed to the container container using a waterproof adhesive,     using a waterproof adhesive, tacks tacks where practical, or a corrosion      where practical, or a corrosion-resistant wire.                            resistant wire.
(6)         Container marking shall        (9 Container markings shall include              OK include the following information:         the following information:
(a)         Destination                    (1) destination                                  OK (b)         Return address                 (2) return address                               OK (c)         Package numbers showing        (3) package numbers showing the                  OK the purchase order number, followed        purchase order number, followed by 38 of 39                                                     7/27/10

Enclosure 4, Table 2 ANSI N45.2.2-1972 vs NQA-1-1994, Subpart 2.2 by the package number and the tc number of Dackaaes.
(d)        Material identification         (4) material identification number        OK number (e)        Handling instructions           (5) handling instructions (e.g., Fragile, OK Fragile, Center of Gravity, Keep Dry,      Center of Gravity, Keep Dry, This Side This Side Up, Sling Here, Do Not           Up, Sling Here, Do Not Freeze) and Freeze, stacking limitations as            stacking limitations, as appropriate appropriate.
(f)        Weight of package (in           (6) weight of package [in excess of       NQA-1 added metric equivalents excess of 100 pounds).                      100 lb (45.5 kg)]
(g)        Special Instructions.           (7) special instructions (Desiccant       OK Desiccant Inside, Special Inspection,       Inside, Special Inspection, Storage, Storage, Unpacking Restrictions, etc.      Unpacking Restrictions, etc.) as as appropriate,                            appropriate.
Marking of items not within a               Marking of items not within a            N45.2.2 does not allow marking container, such as pipe, tanks and         container, such as pipe, tanks, and       directly on austenitic stainless steel heat exchangers, shall exhibit              heat exchangers, shall exhibit speci-    and nickel alloy metal surfaces specified information in a location        fled information in a location which is   whereas NQA-1 states that marking which is in plain unobstructed view,       in plain unobstructed view. Marking       is acceptable "provided it has been but not directly applied to bare           may be applied directly to bare metal     established that the marking material austenitic stainless steel and nickel      surfaces provided it has been             is not deleterious to the item."
alloy metal surfaces of the item.          established that the marking material
_ is not deleterious to the item.
39 of 39                                                  7/27/10

Enclosure 4, Table 3 ANSI N45.2.3-1973 vs NQA-1-1994, Subpart 2.3 rN'4,./.3 iirniLMu LU UUr   UI
[lly construction phase" NQA-1 1.1 Scope                                             Subpart 2.3 provides housekeeping                  addresses a larger scope of the This standard defines the housekeeping                requirements for the control of work conditions    "nuclear power plant".
requirements for the control of work activities,      and environments that can affect the quality of conditions, and environments that can affect the      important parts of a nuclear power plant. It quality of important parts of a nuclear power         supplements the requirements of Part I and plant during the construction phase.                  shall be used in conjunction with applicable Basic and Supplementary Sections of Part I when and to the extent specified by the organizations invoking Subpart 2.3.
These parts include the structures, systems,         Subpart 2.3 provides housekeeping                  Similar and components whose satisfactory                     requirements for the control of work conditions Same Intent performance is required for the plant to operate      and environments that can affect the quality of reliably, to prevent accidents that cause undue       important parts of a nuclear power plant.
risk to the health and safety of the public, or to     NQA-1 Part II Introduction includes similar mitigate the consequences of such accidents if        language with the same intent:
they were to occur.                                   The requirements of this Part (Part II)apply to fabrication, construction, modification, repair, maintenance, and testing activities that affect the quality of structures, systems, and components for nuclear facilities.
Housekeeping encompasses all activities                                                                  Guidance which defined related to control of cleanness of facilities,                                                           "housekeeping". Scope and cleanness of material and equipment, fire                                                                requirements adequately cover the prevention and fire protection including disposal                                                        areas identified.
of combustible materials and debris, control of access, and protection of equipment not denoted in other standards.
The requirements may also be extended to               NQA-1 Part II Introduction includes similar       Similar other appropriate parts of nuclear power plants       language with the same intent:                     Same Intent when specified in contract documents.                 To the extent applicable to the activities being performed, the application of this Part (Part II),
or portions thereof, and the provisions of Part I, Basic and Supplementary Requirements, shall be specified in written contracts, policies, procedures, or instructions.
This standard is intended to be used in               To the extent applicable to the activities being   Similar conjunction with ANSI N45.2, Quality                  performed, the application of this Part (Part II), Same Intent Assurance Requirements For Nuclear Power              or portions thereof, and the provisions of Part I, Plants.                                               Basic and Supplementary Requirements, shall be specified in written contracts, policies, procedures, or instructions.
1.2 Applicability                                    The requirements of this Part (Part II)apply to    Guidance Only. Wording does not fabrication, construction, modification, repair,   establish requirements.
The requirements of this standard apply to the        maintenance, and testing activities that affect work of any individual or organization that           the quality of structures, systems, and participates in housekeeping activities during        components for nuclear facilities.
construction activities of nuclear power plants as discussed in paragraph 1 .1.
The extent to which the individual requirements       NQA-1 Part II Introduction includes similar        Similar of this standard apply will depend upon the           language with the same intent:                     Same Intent nature and scope of the work to be performed and the importance of the item or service             An appropriate Quality Assurance Program, involved.                                             based on the nature and scope of the work to be performed and the relative importance of the items or services, shall be specified in contractual documents by selective applications
                                                   .. of portions of Part I,Basic and Supplemental 1 ofll1                                                       7/27/10

Enclosure 4, Table 3 ANSI N45.2.3-1973 vs NQA-1 -1994, Subpart 2.3 MeqUIFUreenL5, 1Vo PrUYgdr[i1FrdLLU dLA!IVIUUb d1IU of this Part (Part II) for work oriented activities.
                                                   +
* The requirements are intended to assure that                                                                Guidance Only. Wording does not only proper materials, equipment, processes,                                                                establish requirements.
and procedures arc utilized in the maintenance of housekeeping during the construction of power plants and that the quality of items is not degraded as a result of housekeeping practices and techniques during construction processing.
1.3 Responsibility                                   NQA-1 Part I, Basic Requirement 1,                     Similar Organization includes similar words:                   Same Intent The organization or organizations responsible        The organizational structure, functional for establishing the applicable requirements for     responsibilities, levels of authority, and lines of the                                                  communication for activities affecting quality activities covered by this standard shall be         shall be documented.
identified and the scope of their responsibilities shall be documented.
The work of establishing practices and               NQA-1 Part I, Basic Requirement 1,                     Similar procedures and providing the resources in            Organization includes similar words:                   Same Intent terms of personnel, equipment, and services          2.2 Delegation of Work necessary to implement the requirements of this      The individuals(s) or organization(s) standard may be delegated to other                   responsible for establishing and executing a organizations, and such delegations shall also       quality assurance program under this Standard the documented.                                      may delegate any or all of the work to others but shall retain responsibility therefor.
However, it is the responsibility of each           NQA-1 Part II Introduction includes similar            Similar organization performing work covered by this         language with the same intent:                         Same Intent standard to comply with the procedures and           The organization upon which this Part (Part II),
instructions issued for the project and to           or portions thereof, is invoked shall be conform to the requirements of this standard         responsible for complying with the specified applicable to his work.                              requirements.
It is the responsibility of the organization                                                                These words are not included in performing these activities to specify the                                                                  NQA-1 or the QAPP. Specific detailed methods and procedures unless they                                                                 provisions regarding organization are specified in the contract documents.                                                                    responsibilities which are applicable to project activities will be defined in associated procedures.
1.4 Definitions                                      NQA-1 Part II Introduction includes similar            Similar language with the same intent:                         Same Intent The following definition is provided because it is 6 DEFINITIONS used uniquely in this standard.
Definitions unique to the activities described in this Part (Part II) are included in the section dealing with that activity. Definitions generic to quality assurance activities are included in Part I, Supplement S-i, Terms and Definitions.
Construction Phase-The period of time                                                                       These words are not included in beginning with the start of construction activity                                                           NQA-1 or the QAPP. Specific and ending as each plant area is turned over to                                                             provisions regarding this definition the plant operator.                                                                                         which are applicable to project activities will be defined in associated procedures.
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Enclosure 4, Table 3 ANSI N45.2.3-1973 vs NQA-1 -1994, Subpart 2.3 ITTIIIIdj in ANSI N45.2.10.                                   language with the same intent:                       Same Intent 6 DEFINITIONS Definitions unique to the activities described in this Part (Part II) are included in the section dealing with that activity. Definitions generic to quality assurance activities are included in Part I. Suinnlement S-1 Terms-and Definitions.
1.5 Referenced Documents                           NQA-1 Part II Introduction includes similar          Similar language with the same intent:                       Same Intent Other documents that are required to be included as a part of this standard are either     7 REFERENCED CODES, STANDARDS, AND identified at the point of reference or identified SPECIFICATIONS in paragraph 5 of this standard.
All codes, standards, and specifications that are referenced as a part of this Part (Part II).are listed in the Table entitled "Codes, Standards, and Specifications Referenced in Text."
: 2. GENERAL REQUIREMENTS                             2 GENERAL REQUIREMENTS                              Similar Same Intent This paragraph contains requirements that are       Housekeeping activities shall include to be fulfilled by the contractor who is            documented methods and techniques for responsible for performing any segment of work      control of the site area, the plant, and the described in paragraphs 3 and 4 of this             materials and equipment being incorporated in standard.                                           the plant to preserve the requisite quality of the Measures shall be established and                   items being constructed or installed.
implemented for documenting housekeeping operations to verify conformance to specified requirements.
OK 2.4 Personnel Qualifications                        Personnel working in zone controlled areas shall be familiar with the necessities and All personnel working in zone controlled areas      requirements for cleanness control applicable to shall be familiar with the necessities and          the various zones.
requirements for cleanness control applicable to the various zones.
Training programs shall be utilized for this       Training programs shall be utilized for this        OK purpose where appropriate,                         purpose, where appropriate.
2.1 Planning                                       NQA-1 Part II Introduction includes similar         Similar The work and the quality assurance                 language with the same intent:                      Same Intent requirements for the housekeeping activities at    A plan shall be developed outlining the work to the nuclear power plant site shall be delineated,  be performed and the work procedures or instructions required to comply with the requirements of the defined work scope.
The planned activities shall include the          2.1 Planning and Procedures                         Similar methods and techniques for control of the site                                                         Same Intent area, the facilities, and the materials and        Planning and procedure preparation shall be in equipment being incorporated in the plant to       accordance with the requirements of the preserve the requisite quality of the items being  Introduction to this Part (Part II); procedures constructed or installed,                          and instructions shall contain sufficient detail to provide for control of the site area, the plant, and the materials and equipment being incorporated in the plant to preserve the requisite quality of the item being constructed or installed.
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Enclosure 4, Table 3 ANSI N45.2.3-1973 vs NQA-1 -1994, Subpart 2.3 riecessary prUce&ures an)U WOrK IrnstrucuoIs       INLt'-   I rdFl II             IflUlUUWZb b1llllldr roILUUMMUT.lrl                    o ilnlldr that are needed to assure compliance with the       language with the same intent:                        Same Intent specified requirements shall be identified and      Installation, inspection, test procedures, and provisions shall be made for their preparation,     work instructions identified during planning shall approval, release, and control.                     be pre-pared. Preparation and approval of the procedures! instructions shall be in advance of the need to use the documents Methods to be used for the collection, handling, Basic Requirement 17                                    OK and disposition of records, data, and reports       Requirements and responsibilities for record shall be designated.                                transmittal, distribution, retention, maintenance, and disposition shall be established and documented.
2.2 Procedures and Instructions                     NQA-1 Part II Introduction includes similar           Similar language with the same intent:                        Same Intent The procedures and instructions for housekeeping practices shall be prepared and Installation, inspection, test procedures, and may be issued in segments to conform with the work instructions, identified during planning shall project construction schedule.                      be pre-pared.
The first segment establishing regulations for      Procedures and instructions providing for the         Similar control of site area, site preparation, fire        control of site areas, site preparation, fire         Same Intent prevention and protection, and records shall be     prevention and protection, and records shall be in force with the start of construction activity,   in force with the start of the construction activity.
The remaining segments shall be prepared and Other procedures and instructions shall be                   Similar approved no later than the start of equipment       prepared and approved no later than the start of Same Intent installation work.                                  equipment installation work.
Cleanness requirements for housekeeping             2.2 Classification of Cleaness                        OK activities shall be established on the basis of     Cleanness requirements for housekeeping the following zone designations.                    activities shall be established on the basis of the following zone designations.
Time for implementation of the zone                  The timing for implementation of the zone            Similar designations shall be as required by the            designations shall be as required by the need         Same Intent construction progress.                              for cleanness.
Zones                                                                Zones                                OK Restriction List               I   II  Ill IV     V Restriction List            I      II Ill IV V Clothing change             Yes No No No No Clothing change              Yes No No No No        Clean gloves, shoe Clean gloves, shoe covers,                          covers, head head covering                Yes Yes No No No       covering                     Yes Yes No No No Filtered air                  Yes No No No No       Filtered air                  Yes No No No No Material precleaning          Yes No No No No       Material Material accountability       Yes Yes Yes No No     precleaning                    Yes Yes No No No Personnel accountability Yes Yes Yes No No          Material No use of tobacco/eating Yes Yes Yes Yes No         accountability                 Yes Yes Yes No No Personnelaccountability Yes Yes Yes No No Use of tobacco or eating Yes Yes Yes Yes No Zone I-                                             Zone I.                                               Similar Areas requiring the highest order of cleanness      Areas requiring the highest order of cleanness- Same Intent and shall be equipped with a clean clothing         shall be equipped with a clean clothing change change facility at the vestibule or entrance,       facility at the vestibule or entrance preferably with toilet facilities immediately adjacent so that personnel working in the controlled area do not have to wear the special clothing in other areas.
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Enclosure 4, Table 3 ANSI N45.2.3-1973 vs NQA-1 -1994, Subpart 2.3 OUU1 drUdb WWI] proVIU: Wor WuUIpIMLU UUM         OVU[I   dIed5b W11111 PIVIUlU 1J lI ,UlJIPIWLU UULVI change of clothing by personnel, including use     change of clothing by personnel, including the of shoe covers, head covers, and gloves to         use of shoe covers, head covers, and gloves to protect all equipment surfaces from outside        protect all equipment surfaces from outside contamination.                                     contamination.
Material entering this zone shall have been        Material entering this zone shall have been        OK appropriately cleaned prior to entry as specified appropriately cleaned prior to entry.
in ANSI N45.2.1.
Zone II-                                            Zone I1.                                          OK Intermediate cleanness requirements less            Intermediate cleanness requirements less restrictive than Zone I but where foreign matter   restrictive than Zone I, but where foreign matter may have detrimental effects.                      may have detrimental effects.
Zone Ill-                                          Zone Ill.                                          OK Areas less restrictive than Zones I and II but     Areas less restrictive than Zones I and II, but requiring access control over personnel and         requiring access control over personnel and materials,                                          materials.
Zone IV-                                           Zone IV.                                           OK Areas where it is desired to regulate the use of    Areas where it is desired to regulate the use of tobacco and eating for material and equipment      tobacco and eating of food for material and protection or for health and fire hazards.          equipment protection or for health and fire hazards.
Zone V-Unrestricted construction areas              Zone V.                                           OK requiring good construction site housekeeping       Unrestricted construction areas requiring good practices only.                                    construction site housekeeping practices only.
For Zones 1,1[,and IIIa written record of the      For Zones 1,11,and Illa written record of the     OK entry and exit of all personnel and material shall entry and exit of all personnel and material shall be established and maintained,                     be established and maintained.
2.3 Results                                        NQA-1 Part I Supplement 1OS-1 includes            Similar similar language with the same intent:            Same Intent Inspection and test results shall be documented in a suitable test report or data sheet.           Inspection activities shall be documented and controlled by instructions, procedures, drawings, checklists, travelers, or other appropriate means.
NQA-1 Part I Supplement 11S-1 includes similar language with the same intent:
Test results shall be documented and evaluated by a responsible authority to assure that test requirements have been satisfied.
Each report shall identify the item to which it   NQA-1 Part I Supplement 1OS-1 includes            Similar applies, the procedures or instruction followed    similar language with the same intent:            Same Intent in performing the task, and the identification of the following:                                     Records shall, as a minimum, identify (a) through (f) below:
11S-1 includes similar language with the same intent:
5 Test Records-Test records shall, as a minimum, identify (a)
_through   (g) below:
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Enclosure 4, Table 3 ANSI N45.2.3-1973 vs NQA-1-1994, Subpart 2.3 LI) ,onloqtiolnS encountereo wnicn were             NU/A- i ran i  ouppiemeni -u- i inciuc anticipated, including nonconformance.              similar language with the same intent:               Same Intent (2) Identity of inspector or tester.                (a) Item inspected (b) date of inspection (3) Completion date.                                (c) inspector (d) type of observation (e) results or acceptability (f) reference to information on action taken in connection with nonconformances.
11S-i includes similar language with the same intent:
(a) Item tested (b) date of test (c) tester or data recorder (d) type of observation (e) results or acceptability 4-                                                   +
Test reports and data sheets shall include an       NQA-1 Part I Supplement 1OS-1 includes               Similar evaluation of the acceptability of inspection and similar language with the same intent:                 Same Intent test results and provide for identifying the individual who performed the evaluation.            (a) Item inspected (b) date of inspection (c) inspector (d) type of observation (e) results or acceptability (f) reference to information on action taken in connection with nonconformances.
11S-1 includes similar language with the same.
intent:
(a) Item tested (b) date of test (c) tester or data recorder (d) type of observation (e) results or acceptability
: 3. REQUIREMENTS                                     3. Requirements                                      OK 3.1 Control of Site Area                            3.1 Control of Site Area                             OK Areas for specific activities shall be assigned     Areas for specific activities shall be assigned and regulated.                                      and regulated.
Areas which shall be designated include where       Areas that shall be designated include, where        OK appropriate refuse and garbage dumps, refuse        appropriate, refuse and garbage dumps, refuse burning sites, storage locations, parking lots,     burning sites, storage locations, parking lots, eating places, non-smoking areas,                   eating places, nonsmoking areas, subcontractor subcontractor work areas, common areas, and         work areas, common areas, and waste waste collection container locations.               collectioncontainer locations.
Personnel entrance to controlled areas,               Personnel entrance to controlled areas,            Similar admission of visitors to the work site, and         admission of visitors to the work site; and          Same Intent identification of all personnel shall be regulated  identification of all personnel shall be controlled in accordance with established procedures and       in accordance with established procedures and regulations.                                        instructions.
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Enclosure 4, Table 3 ANSI N45.2.3-1973 vs NQA-1 -1994, Subpart 2.3 Grading. drainage, roads, construction facilities,   Grading, drainage, roads, construction facilities, plant fencing, and utilities shall be provided in    plant fencing, and utilities shall be provided in accordance with specified requirements and           accordance with specified requirements and shall he maintained as required in good              shall be maintained as required in good condition throughout the construction phase or       condition throughout the construction phase or until replaced with the permanent facilities.        until replaced with the permanent facilities.
3.2 Control of Facilities                            3.2 Control of Facilities                          OK Control of work and storage areas where              Control of work and storage areas where important items are handled shall be                 important items are handled shall be established and maintained to conform to the         established and maintained to conform to the appropriate zone defined in paragraph 2.1 of         appropriate zone defined in para. 2.2 of this this standard.                                       Subpart.
Atmosphericcontrol shall be provided where           Atmospheric control shall be provided where        OK necessary.                                           necessary.
The control of all tools, equipment, materials,       The control of tools, equipment, materials, and OK and supplies that are used in Zones I - II, and IIIsupplies that are used in Zones 1,11,and IIIshall shall be maintained to prevent the inadvertent be maintained to prevent the inadvertent inclusion of deleterious materials or objects in inclusion of deleterious materials or objects in critical systems                                     critical systems.
Appropriate control measures shall be provided Appropriate control measures shall be provided OK through utilization of such items as log books        through utilization of such items as log books and tethered tools.                                   and tethered tools.
3.2.1 Cleanness          The work areas shall be      3.2.1 Cleanness. The work areas shall be kept OK kept sufficiently clean and orderiy that              sufficiently clean and orderly so that construction activity can proceed in an efficient     construction activity can proceed in an efficient manner that will produce and maintain quality in      manner that will produce and maintain quality in conformance with specified requirements.              conformance with specified requirements.
Where large accumulations of materials occur           Where large accumulations of materials occur      OK on a nonroutine basis, such as the stripping of       on a nonroutine basis, such as the stripping of concrete forms, the material shall be promptly        concrete forms, the material shall be promptly removed or stored neatly.                             removed or stored neatly.
Garbage, trash, scrap, litter, and other excess       Garbage, trash, scrap, litter, and other excess    OK materials shall be collected, removed from the        materials shall be collected, removed from the job site, or disposed of in accordance with          job site, or disposed of in accordance with specified requirements or planned practices.          specified requirements or planned practices.
Such excess material shall not be allowed to       . Such excess material shall not be allowed to       OK accumulate and create conditions that will            accumulate and create conditions that will adversely affect quality.                             adversely affect quality.
The disposal of cleaning chemicals shall be            The disposal of cleaning chemicals shall be       OK accomplished so additional hazards are not           accomplished so additional hazards are not created at the disposal site.                         created at the disposal site.
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Enclosure 4, Table 3 ANSI N45.2.3-1973 vs NQA-1-1994, Subpart 2.3
,.L.L    -nvironment. Areas 01 activity snail De     J.Z.Z t-nvlrUromenL. mreas 01 da.LIVILy WWII U1:
adequately lighted, ventilated, protected, and       adequately lighted, ventilated, protected, and accessible as appropriate to the work being          accessible as appropriate for the work being performed.                                           performed.
Temporary lighting may be utilized but shall be Temporary lighting may be utilized but shall be OK installed and maintained to provide good            installed and maintained to provide good visibility,                                          visibility.
Ventilation shall be provided where necessary         Ventilation shall be provided where necessary OK to prevent accumulation of dust, noxious fumes, to prevent accumulation of dust, noxious fumes, and temperature extremes.                           and temperature extremes.
Adequate working space for construction              Adequate working space for construction             OK personnel shall be provided utilizing proper        personnel shall be provided utilizing proper work stages and platforms having accessibility       work scaffolds and platforms having by stairs or ladders.                               accessibility by stairs or ladders.
Barriers, screens, shields, restricted access, or  Barriers, screens, shields, restricted access, or OK other protection shall be provided as necessary     other protection shall be provided as necessary for isolation of areas where noise, welding arcs,   for isolation of areas where noise, welding arcs, dust, inclement weather, or other conditions        dust, inclement weather, or other conditions that exist that may affect the quality of work being     may affect the quality of work being performed.
performed.
3.2.3 Fire Protection and Prevention.               3.2.3 Fire Protection and Prevention.               OK Equipment and instructions for the protection       Equipment and instruction for the protection       Similar from, and prevention of, damage by fire shall be    from, and prevention of, damage by fire shall be Same Intent provided in accordance with the NEPA National       provided in accordance with the requirements of Fire Codes, Volume 4, Building Construction         the NFPA National Fire Codes Facilities.
Procedures or instructions for fire protection     Procedures or instructions for fire protection      OK shall include provisions for fighting fires         shall include provisions for fighting fires involving the use of available community fire       involving the use of available community fire departments, trained project brigades, and          departments, trained project brigades, and others.                                             others.
Procedures or instructions shall include plans      Procedures or instructions shall include plans      OK tor provision of water supplies, hydrants,          for provision of water supplies, hydrants, automatic sprinklers, access for fire fighting,     automatic sprinklers, access for fire fighting, and distribution of extinguishers and fire fighting and distribution of extinguishers and fire fighting equipment.                                          equipment.
Fire watches during and immediately following Fire surveillance during and immediately                 Similar welding operations should be specified,             following operations such as welding and heat       Same Intent treating shall be provided when materials are located such that flames, flying sparks, weld spatter, or excessive heat resulting from the operation could cause combustion, with resulting damage to items of the nuclear plant.
Fire protection facilities shall be in service      Fire protection facilities shall be in service     OK beginning with the initial stages of permanent      beginning with the initial stages of permanent construction.                                       construction.
Pre-fire planning should be considered as a         Pre-fire planning shall be conducted as a          OK requirement of the fire protection procedures or requirement of the fire protection procedures or instructions which shall include evacuation of      instructions, which shall include evacuation of confined areas.                                     confined areas.
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Enclosure 4, Table 3 ANSI N45.2.3-1973 vs NQA-1-1994, Subpart 2.3 i.j  Matenals ana -quipment                        Maternais ano equipment ueiiverea to mne worK Materials and equipment delivered to the work      area shall be so positioned, or protected when Same Intent area shall be placed so that they are accessible   necessary, to assure that the quality of the item but do not hinder construction progress.           will not be degraded by the construction activity.
However, material and equipment shall be so       Materials and equipment delivered to the work positioned that it will not be damaged by          area shall be so positioned, or protected when construction activity.                             necessary, to assure that the quality of the item will not be degraded by the construction activity.
The receiving. storage, and handling activities These provisions contained in NQA-1 Subpart           Similar required by this standard shall be performed as 2.2                                                   Same Intent specified in ANSI N45.2.2.
3.3 Material and Equipment                         Similar Same Intent The cleaning of important parts for the plant     The cleaning of important materials and that is necessary during these activities shall be equipment for the plant that is necessary during performed as specified in ANSI N45.2. 1.           receiving, storage, and handling activities shall be in accordance with applicable requirements.
3.4 Construction Tools, Supplies, and              3.4 Construction Tools, Supplies, and              OK Equipment                                          Equipment The use, location, and deployment of               The use, location, and deployment of               OK construction tools, supplies, and equipment        construction tools, supplies, and equipment shall be regulated to keep access and work         shall be controlled to keep access and work areas clear and prevent conditions that will       areas clear and to prevent conditions that will adversely affect quality,                          adversely affect quality.
These provisions shall include, but are not         These provisions shall include, but are not       OK limited to such items as the movement of           limited to, such items as the movement of materials to the work area, welding and stress     materials to the work area, welding and stress relieving leads, power leads, temporary heating    relieving leads, power leads, temporary heating equipment, pumps, air and water hoses,             equipment, pumps, air and water hoses, welding machines. air compressors, hoisting        welding machines, air compressors, hoisting equipment, air tools, grinding tools and burning   equipment, air tools, grinding tools, and burning tools.                                             tools.
3.5 Surveillance, Inspections, and                 3.5 Surveillance and Inspections                   OK Examinations Periodic inspection of work areas and Periodic inspection and examination of the work    construction practices shall be performed at areas and the construction practices shall be      scheduled intervals to assure adequacy of performed                                          cleanness and housekeeping practices.
at scheduled intervals to assure adequacy of cleanness and housekeeping practices.
These inspections and examinations shall          These inspections shall include the following, as OK include the following as appropriate:              appropriate:.
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Enclosure 4, Table 3 ANSI N45.2.3-1973 vs NQA-1-1994, Subpart 2.3 kI I ,   I-.- IdILUI I U I ,
lIIII                I+LI.ULLIUI I ZlLtM IUdUZ,     kaI 111Pct.LIVI I UI .AIII UILII -        ' O.t,-O
                                                                                               'alyruoU access ways, and ramps for conditions that               ways, and ramps for conditions that may result Same Intent may result In damage to items being                      in damage to items being transported or transported or handled.                                  handled; (2) Examination of storage area for                      (b) inspection of storage and work areas for conformance to procedures and instructions in            conformance to procedures and instructions in the following categories:                                the following categories:
(a) adequacy of access control.                          (1) adequacy of access control (b) evidence of damage or deterioration.                 (2) evidence of damage or deterioration (c) adequacy of protection from fires. weather,          (3) adequacy of protection from fires, weather, movement of equipment, and other factors that            movement of equipment, and other factors that may result in damage to stored items.                    may result in damage to stored and installed (d) adequacy of solvent storage facilities.              items (3) Inspection of work areas for maintenance of          (4) adequacy of hazardous chemicals, paints, environmental conditions within specified limits.        and solvent storage facilities (4) Surveillance over Installed items to assure          (c) inspection of work areas for maintenance of the adequacy of:                                         environmental conditions within specified limits; (a) maintenance of protection.                           (d) surveillance over installed items to assure (b) preservation of precautionary signs.                 the adequacy of:
(c) presrvation of item identity.                        (1) maintenance of protection (d) protection from fire, weather, movement of           (2) preservation of precautionary signs materials or equipment and other factors which           (3) preservation of item identity may result in damage to installed items.                 (4) protection from fire, weather, movement of materials or equipment, and other factors which may result in damage to installed items Where these requirements duplicate the                                                                         Guidance Only. Wording does not requirements of other standards such as ANSI                                                                   establish requirements.
N45.2.1, duplicate activities and reports are not required.
: 4. RECORDS                                                4 RECORDS                                            Similar Copies of approved procedures, reports;                                                                        Same Intent personnel training and qualification records;             Record copies of procedures, reports, controlled zone registry, fire and accident               personnel qualification records, zone control Investigations; and Inspection and examination            registries, fire and accident investigations, records shall be prepared and placed with other           surveillance, and inspection records shall be project records,                                          prepared as required in this Part (Part I1).
Final disposition of records shall be In                  These records shall be retained with other           Similar accordance with ANSI N45.2.9.                             project records as required by code, standard,       Same Intent specification, or project procedures.
: 5. REVISIONS OF AMERICAN NATIONAL                         NQA-1 Part II Introduction includes similar          Similar STANDARDS REFERRED TO IN THIS                             language with the same intent:                       Same Intent DOCUMENT                                                  7 REFERENCED CODES, STANDARDS, AND SPECIFICATIONS 10 of 11                                                   7/27/10

Enclosure 4, Table 3 ANSI N45.2.3-1973 vs NQA-1-1994, Subpart 2.3 When the following standards referred to in this                                  No corresponding provision in NQA-1 document are superseded by a revision                                             for addressing revisions is included or approved by the American National Standards                                       required.
Institute, the revision shall apply.
A 10.2-1 Q44 Safety Code for Building Construction N45.2 Quality Assurance Program Requirements for Nuclear Power Plants N45.2.1 Cleaning of Fluid Systems and Associated Components During the Construction Phase of Nuclear Power Plants N45.2.2 Packaging, Shipping, Receiving, Storage and Handling of Items for Nuclear Power Plants (During the Construction Phase N45.2.9 Requirements for Collection, Storage and Maintenance of Quality Assurance Records N45.2.10 Quality Assurance Terms and Definitions.
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Enclosure 4, Table 4 ANSI N45.2.4-1972 vs NQA-1-1 994, Subpart 2.4
                                                  'Subpart 2.4 consists or ANl/IIL:t_: bitd. JJb-    Guidance unly. wording does 1985, 1 IEEE Standard Installation, Inspection,    not establish requirements.
and Testing Requirements for Power, Instrumentation, and Control Equipment at Nuclear Facilities.
: 1. Introduction                                   1. Introduction                                    Similar Same intent 1.1 Scope. This standard sets forth the           1.1 Scope. This standard sets forth the requirements for installation, inspection, and    requirements for installation, inspection, and testing of Class I and Class IE electric power,   testing of power, instrumentation, and control instrumentation, and control equipment and        equipment and systems during the construction systems during the construction phase of a        phase of a nuclear facility.
nuclear power generating station.
These requirements also cover modifications and These words were added in those operating phase activities that are          NQA-1 comparable in nature and extent to related initial construction activities of the facility.
These requirements are intended to assure that                                                       Guidance Only. Wording does only materials and equipment of acceptable                                                           not establish requirements.
quality are incorporated into the plant, that quality is maintained and quality workmanship prevails throughout the construction process, and that completed installations conform to specified requirements, so as to promote public safety, prevent accidents and mitigate the consequences of accidents if they occur, and provide a high degree of plant reliability.
1.1.1 In addition to the Class I and Class IE     The intent of this standard is to establish        Similar systems, the requirements also apply to the       requirements for safety systems equipment.         Same Intent following auxiliary equipment that are a part     (Safety systems equipment is defined in IEEE thereof.                                          Std 603-1980 [5].') However, this standard may also be applied to non-safety systems equipment.
(1) Connecting cables and raceways                IEEE Std 603-1980 includes direction and           Similar (2) Electric and instrumentation containment      definitions which provide for the determination of Same Intent penetrations                                     the components or elements of a safety system (3) Instrumentation sensing lines from the       which, when applied would define the equipment process root valves to and including input       that the requirements of subpart 2.4 would apply transducers                                      to. This would include the equipment similar to (4) Primary sensing devices (for example,        that listed in N45.2.4.
orifices, flow nozzles, venturi tubes, and reference columns)
(5) Pneumatic instrumentation (6) Output control transducers, including tubing and piping (7) Fluid systems associated with standby generators and transformer cooling systems (8) Switchgear fluid systems (9) Panels, enclosures, and mountings 1.1.2 These requirements may also be              NQA-1 Part II Introduction includes similar        Similar extended to other appropriate parts of nuclear   language with the same intent: Tothe extent         Same Intent power generating stations when specified in      applicable to the activities being performed, the contract documents.                              application of this Part (Part II), or portions thereof, and the provisions of Part I, Basic and Supplementary Requirements, shall be specified in written contracts, policies, procedures, or instructions.
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Enclosure 4, Table 4 ANSI N45.2.4-1972 vs NQA-1 -1994, Subpart 2.4 1.1.3 This standard does not set forth specific    1.1.1 This standard does not set forth specific requirements for the following, though related to requirements for the following, though they are the above equipment and systems:                   related to the above equipment and systems.
(1) Inspection or testing, or both, of welds       (1) Installation, inspection, and testing of welds   Similar (2) Cleaning and flushing of instrument sensing    (2) Cleaning and flushing of instrument sensing Same Intent Items 5 - 9 added lines                                              lines (3) Aligning or verifying alignment, or both, of   (3) Aligning or verifying alignment, or both, of Class I rotating equipment                         rotating equipment (4) Verifying structural integrity of support for  (4) Verifying structural integrity of supports for Class I or Class IE electric equipment             equipment (5) Activity governed by Section III of [6]
(6) Preoperational tests of the integrated systems and equipment (7) Periodic testing and maintenance after initial operation (8) Receiving inspection and test (9) Non-destructive examination when required 1.1.2 During the construction phase and when         Redundant. NQA-1 has modifications are being performed, this standard     incorporated IEEE 336 as shall be used in conjunction with the applicable     Subpart 2.4 of NQA-1.
portions of ANSI/ASME NQA-1-1983 [1) and ANSI/ASME NQA-2-1983 [2).
During the operations phase this standard shall      These words were added in be used with the applicable portions of              NQA-1 ANSI/ANS 3.2-1982 [3).                               The QAPP and procedures address applicable provisions of ANS 3.2.
For applicable codes on the above refer to                                                              Guidance Only. Wording does Section 9.                                                                                              not establish requirements.
1.2 Applicability. The requirements set forth in   1.2 Applicability. The requirements set forth in     Similar this standard apply to the work of any             this standard apply to the work of any               Same Intent organization that participates in the construction organization that participates in the installation, phase of electric and instrumentation              inspection, testing, or modification of power, equipment and systems from the time that the       instrumentation, and control equipment and equipment is turned over to the installers until   systems in a nuclear facility from the time that the the time it is integrated into systems in a        equipment is tumed over for installation Until it is condition to commence system performance           integrated into a system.
testing.
The extent to which the individual requirements      These words were added in of this standard apply either wholly or in part      NQA-1 depends upon the nature and scope of the work to be performed and the importance of the item or service involved.
The requirements of this standard are basic                                                             Guidance / Informational minimum requirements which relate to nuclear power generating stations during construction or construction phases of modification or expansion.
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Enclosure 4, Table 4 ANSI N45.2.4-1972 vs NQA-1-1994, Subpart 2.4 For supplementary requirements applicable to      NUA-1 Part II Introduction includes sir              Similar the construction phase of multi-unit stations,    language with the same intent:                       Same Intent including expansions to existing stations, refer to Appendix A.                                    8 MULTI-UNIT FACILITY PROVISIONS For construction activities in a nuclear power plant where one or more units is already operating or has reached a stage where the fuel has been loaded in the reactor and associated systems energized, the following measures shall be taken in addition to the provisions defined elsewhere in this Part (Part II).
1.3 Responsibility. The organization or           Basic Requirement 1                                  OK organizations responsible for establishing the    The organizational structure, functional applicable requirements for the activities        responsibilities, levels of authority, and lines of covered by this standard shall be identified, and communication for activities affecting quality shall the scope of their responsibility shall be        be documented.
documented.
Supplement 1S-1 3.1 Where more than one organization is involved in the execution of activities covered by this Part (Part 1), the responsibility and authority of each organization shall be clearly established and documented.
The planning operations stipulated in Section 3.2 These words were added in shall specify the inspections and tests to be        NQA-1 performed on the identified equipment and systems consistent with this standard.
The work of establishing practices and            The work of establishing practices and               OK procedures and providing the resources in         procedures and providing the resources, in terms terms of personnel, equipment, and services       of personnel, equipment, and services, to necessary to implement the requirements of        implement the requirements of this standard, this standard may be delegated to other           may be delegated to other organizations. Such organizations, and such delegations shall also    delegation shall be documented.
be documented.
In any case, the organization invoking this          These words were added in standard shall retain responsibility for overall     NQA-1 program effectiveness.
It is the responsibility of each organization     NQA-1 Part II Introduction includes similar          Similar participating in site construction activities to  language with the same intent:                       Same Intent comply with the procedures and instructions issued for the project.                           The organization upon which this Part (Part II), or portions thereof, is invoked shall be responsible for complying with the specified requirements.
1.4 Definitions. The following definitions are    NQA-1 Part II Introduction includes similar          Similar provided to assure uniform understanding of       language with the same intent:                       Same Intent select terms as they are used in this standard.
6 DEFINITIONS Definitions unique to the activities described in this Part (Part II)are included in the section dealing with that activity. Definitions generic to quality assurance activities are included in Part I, Supplement S-i, Terms and Definitions.
IEEE 336 also refers to IEEE 603: Safety Systems equipment is defined in IEEE Std 603-1980 3 of 22                                                 7/27/10

Enclosure 4, Table 4 ANSI N45.2.4-1972 vs NQA-1-1994, Subpart 2.4 Class I equipment. Equipment that is essential                                                           zimiiar to the safe shutdown and isolation of the                                                                Same Intent reactor or whose failure or damage could result in significant release of radioactive material.
Class IE electric systems. The systems that        Defined within IEEE 603-1980                          Similar provide the electric power used to shut down                                                             Same Intent the reactor and limit the release of radioactive material following a design basis event.
system performance testing.                        7.2.2 System Tests                                    Similar Same Intent Tests performed on completed systems,              Tests shall be made to verify that all parts of a including all-their electric, instrumentation,     system properly coordinate with each other.
controls, fluid and mechanical subsystems under normal or simulated normal process conditions of temperature, flow, level, pressure, etc.
set point. A predetermined level at which a                                                              Term now commonly used in bistable device changes state to indicate that                                                           the nuclear industry. NQAIIEEE the quantity under surveillance has reached the                                                          chose not to include them in selected value,                                                                                          later revisions of NQA-1 and IEEE-336 lay-up. Idle condition of equipment and systems                                                          Term now commonly used in during and after installation, with protective                                                           the nuclear industry. NQAIIEEE measures applied as appropriate.                                                                         chose not to include them in later revisions of NQA-1 and IEEE-336 1.5 Referenced Documents. Other documents                                                                Guidance Only. Wording does that are required to be included as a part of this                                                       not establish requirements.
standard, as well as the issue or edition of such                                                        QAPP identifies applicable documents, are either identified at the point of                                                         reference documents.
reference or described in Section 9 of this standard.
: 2. General Requirements                            3. General Requirements                               Similar Same Intent Measures shall be established and                  Measures shall be established and implemented implemented for documenting installation,          for planning and control of installation, inspection, inspection, and testing operations to verify       and testing activities to verify conformance to conformance to specified requirements.             specified requirements.
2.1 Planning. The installation, inspection, and     3.2 Planning. The installation, inspection, and       OK testing activities shall be planned and outlined    testing activities shall be performed in to define the operations to be used and the         accordance with documented plans that define systematic, sequential progression of               the operations to be used, the systematic, "
operations for each item or system, the             sequential progression of operations for each responsibilities of parties concemed for each       item or system, the responsibilities of parties operation, and the measures employed to             concerned for each operation, and the measures preserve the quality of equipment.                  employed to preserve the quality of equipment.
4 of 22                                                      7/27/10

Enclosure 4, Table 4 ANSI N45.2.4-1972 vs NQA-1-1994, Subpart 2.4 manning shall take into account the need for    Planning shall take into account the need for the the preparation and control of procedures and   preparation and control of procedures and work work instructions necessary to comply with the  instructions necessary to comply with the requirements for installation, inspection, and  requirements for installation, inspection, and testing of components and systems.              testing of equipment and systems.
Planning shall include a review of the system   Planning shall include a review of the system and     Same except for the omission and component design specifications and         equipment specifications and drawings and of the      from NQA-1 of "and that time drawings, and of the construction work plans    construction work plans and schedules to assure       and resources are sufficient to and schedules, to assure that installation,     that installation, inspection, and testing activities accomplish the required inspection, and testing activities have been    have been incorporated and that they can be           actions".
incorporated, that they can be accomplished as  accomplished as specified.
specified, and that time and resources are sufficient to accomplish the required actions.
2.2 Prerequisites.                              3.1 Prerequisites.                                    OK The following conditions shall have been met                                                          Guidance as required by other standards before the requirements set forth in this standard are applied.
(1) Qualification of personnel assigned to the  3.7 Personnel Qualification. Personnel                Similar construction phase has been in accordance       performing the verifications required by this         Same Intent with the requirements of appropriate codes and  standard shall be qualified in accordance with an standards.                                      approved quality assurance program.
(2) Systems have been designed and                                                                    QAPP Section 4.3 invokes engineered and equipment has been specified                                                           Basic Requirement 3 and in accordance with the published applicable                                                           Supplement 3S-1 which standards and specifically within the frame-                                                          provides for design controls that work of the Quality Assurance program                                                                 achieve the same intent.
described in the Safety Analysis Report.
(3) Materials have been selected, and                                                                 QAPP Section 4.7 invokes equipment has been fabricated and shop                                                                Basic Requirement 7 and assembled, in accordance with the                                                                     Supplement 7S-1 which specifications and the applicable published                                                           provides for purchasing controls codes and Standards, the conformance to                                                               that achieve the same intent.
which has been demonstrated by the manufacturer.
(4) Materials and equipment have been                                                                 QAPP 4.13 invokes Basic shipped, received, handled and stored in                                                              Requirement 13 and accordance with the requirements of applicable                                                        Supplement 13S-1 which codes, standards, and manufacturers'                                                                  provides for shipping, handling recommendations to preserve their integrity and                                                       and receiving controls that prevent physical, mechanical, and/or electrical                                                       achieve the same intent.
damage.
5 of 22                                                    7/27/10

Enclosure 4, Table 4 ANSI N45.2.4-1972 vs NQA-1-1994, Subpart 2.4 (5) The following documents relating to the       The following applicable documents relating to specific equipment to be installed are available  the specific equipment to be installed shall be    Same Intent at the construction site:                         available in legible form at a predetermined retention area or area of usage.
(a) The latest applicable approved-for-           (1) The latest applicable approved-for-            Similar construction drawings                             construction drawings                              Same Intent (b) Installation specifications                   (2) Installation specifications (c) Manufacturers' instructions                   (3) Manufacturers' instructions (d) Evidence of compliance by manufacturer        (4) Evidence of compliance by manufacturer with with purchase requirements, including quality -   purchase requirements, including quality assurance requirements                            documentation (e) Records of inspections and tests during on-   (5) Records of inspections and tests during site storage and handling,                        receiving and on-site storage, handling, and maintenance 2.3 Procedures and Instructions. Installation,    3.3 Procedures and Instructions. Procedures        Similar inspection, and test procedures and work          shall be prepared and documented as                Same Intent instructions shall be prepared and documented determined by the planning in 3.2.
for those activities falling within the scope of this standard.
These procedures and instructions may be in the These words were added in form of manuals or drawings.                       NQA-1 These documents shall be kept current and         These documents shall be kept current by           Similar revised as necessary to assure that installation, controlled supervision so that installation,       Same Intent inspections, and tests are performed in           inspections, and tests are performed in accordance with latest information and shall      accordance with the latest approved design and include as appropriate:                           manufacturers' instructions. The documents shall include or reference:
(1) Installation specifications                   (1) Installation specifications                    Similar (2) Inspection and test objectives                (2) Inspection and test objectives                 Same Intent (3) Precautions to avoid component or sys-tem     (3) Precautions to avoid equipment or system damage during testing or inspection               damage during installation, testing, or inspection (4) Inspection and test equipment required        (4) Inspection and test equipment required (5) Sequence of tests (if applicable)             (5) Sequence of tests (6) Sequential actions to be followed             (6) Sequential actions to be followed (7) Frequency of inspection or test               (7) Frequency of inspection or test (8) Prerequisites                                 (8) Test prerequisites (9) Approvals                                     (9) Appropriate approvals (10) Data report form                             (10) Suitable form for reporting data (11) Identification of test equipment and date of (11) Provision for identificationof test equipment required recalibration where required for         and date of next required recalibration (where interpretation of test results                    required) for interpretation of test results (12) Inspection and test acceptance limits        (12) Inspection and test acceptance limits (13) References (14) Other pertinent items The above items shall be included as a check list These words were added in and shall be marked as required or not             NQA-1 appropriate when preparing procedures or instructions.
2.4 Results. Inspection and test results shall be 3.4 Results. Inspection and test results shall be  OK documented in a suitable test report or data      documented in a suitable test report or data sheet.                                            sheet.
Each report shall identify the item to which it   Each report shall identify the item to which it    OK applies, the procedures or instruction followed   applies, the procedures or instructions and its in performing the task, and the identification of revision number used in performing the task, and the following:                                    the identification of the following:
6 of 22                                              7/27/10

Enclosure 4, Table 4 ANSI N45.2.4-1972 vs NQA-1-1994, Subpart 2.4 (1) Ulonldtions encountered which were not         (1)uonditions encountered tnat were not anticipated, including nonconformance              anticipated, including nonconformance (2) Identity of inspector or tester                (2) Identity of inspector or tester (3) Completion date                                (3)Completion date Test reports and data sheets shall include an      Test reports or data sheets shall include an       OK evaluation of the acceptability of inspection and  evaluation of the acceptability of the results and test results and provide for identifying the       provide for identifying the individual who individual who performed the evaluation.           performed the evaluation.
2.5 Measuring and Test Equipment.                  3.5 Measuring and Test Equipment.                  OK 2.5.1 Selection.                                   NQA-1 Basic Requirement 12 includes similar        Similar language with the same intent:                     Same Intent Inspection and testing equipment with acceptable accuracy for performing the             2 Selection required function shall be selected Selection of measuring and testequipment shall be controlled to assure that such times are of proper type, range, accuracy, and tolerance to accomplish the function of determining conformance to specified requirements.
Measuring and test equipment used to determine These words were added in compliance with specifications shall be controlled NQA-1 in accordance with the requirements of IEEE Std 498-1985 [4].
When general voltage levels, flow directions, or NQA-1 Basic Requirement 12 includes similar          Similar other parameters are checked, an instrument        language with the same intent:                     Same Intent without high precision may be used.
3.3 Commercial Devices Calibration and control measures may not be required for rulers, tape measures, levels and other such devices, if normal commercial equipment provides adequate accuracy.
When characteristics, efficiencies, capabilities,  NQA-1 Basic Requirement 12 includes similar        Similar or other properties are measured to appraise       language with the same intent:                     Same Intent compliance with specifications, the instrument must have adequate accuracy to determine the 2 Selection measured quantity to the precision required by the stated limits of the specifications.           Selection of measuring and test equipment shall be controlled to assure that such items are of proper type, range, accuracy, and tolerance to accomplish the function of determining conformance to specified requirements.
Use shall be made of approved industry                                                                These words are not in NQA-1 standards relating to measuring procedures.                                                           or the OAPP Test equipment and/or apparatus supplying          NQA-1 Basic Requirement 12 includes similar        Similar electrical, mechanical, or other test inputs shall language with the same intent:                     Same Intent have adequate capacity and be compatible with items under test so that the resultswill not be    2 Selection distorted.
Selection of measuring and test equipment shall be controlled to assure that such items are of proper type, range, accuracy, and tolerance to accomplish the function of determining conformance to specified requirements.
7 of 22                                               7/27/10

Enclosure 4, Table 4 ANSI N45.2.4-1972 vs NQA-1-1994, Subpart 2.4 z.boz uali1ration ana uontroi. measunng ano test equipment used to determine compliance          language with the same intent:                            Same Intent with specifications, shall be adjusted and calibrated at prescribed intervals against           3 Calibration and Control certified equipment having known valid relationships to nationally recognized               3.1 Calibration standards.
Measuring and test equipment shall be calibrate-d, adjusted, and maintained at prescribed intervals or prior to use, against certified equipment having known valid r0hlsfinn,,hin* in n~,finn~llv mrc'nnni7A,,r *f~ndr1d.r1 If no national standards exist, the basis for         NQA-1 Basic Requirement 12 includes similar              Similar calibration shall be documented.                      language with the same intent:                           Same Intent If no nationally recognized standards exist, the bases for calibration shall be documented.
Records of the calibrations shall be maintained NQA-1 Basic Requirement 12 includes similar                    Similar and equipment suitably marked to indicate date language with the same intent:                                  Same Intent of next required calibration.
5 Records Records shall be maintained and equipment shall be suitably marked to indicate calibration status.
When inspection and testing equipment are             NQA-1 Basic Requirement 12 includes similar              Similar found to be out of calibration, an evaluation         language with the same intent: When inspection Same Intent shall be made of the validity of previous             and testing equipment are found to be out of inspection or test results and of the acceptability calibration, an evaluation shall be made and of items previously inspected or tested,              documented of the validity of previous inspection or test results and of the acceptability of items previously inspected or tested.
Test equipment found to be out of calibration         NQA-1 Basic Requirement 12 includes similar              Similar shall be clearly identified as such.                 language with the same intent: Out-of-calibration Same Intent devices shall be tagged or segregated ...
2.6 Nonconforming Items. Defects, deficiencies,      3.6 Nonconforming Items. Defects, deficiencies, OK discrepancies, or other nonconforming                discrepancies, or other nonconforming situations situations shall be resolved in accordance with      shall be resolved in accordance with established established proceduresl                              procedures.
These procedures shall provide for identifying,       These procedures shall provide for identifying,         OK documenting, and obtaining authorization for         documenting, and obtaining authorization for resolving each nonconforming situation,              resolving each nonconforming situation.
: 3. Preconstruction Verification                      4. Preinstallation Verification                          Similar Same Intent While it is recognized that the requirements for Verifications shall be performed just prior to initial receipt inspections and storage are          installation.
covered by another standard, it is necessary to verify that the quality of an item has not suffered during the interim period.
It is not intended to duplicate inspections but                                                               Guidance / Information rather to verify that items are in a satisfactory condition for installation.
The verifications shall include:                    (1) The following, relating to the specific               Similar equipment to be installed, shall be available at          Same Intent the construction site in legible form:
8 of 22                                                      7/27/10

Enclosure 4, Table 4 ANSI N45.2.4-1972 vs NQA-1-1994, Subpart 2.4 (1) Verification that materials and equipment    (a) I he latest applicable approved-tor-            zSimilar received by the installers are identified in    construction drawings                               Same Intent accordance with the latest approved-for-         (b) Installation specifications, procedures, or any construction drawings, equipment lists, and     special work instructions specifications                                  (2) Identification of materials and equipment in (2) Verification that approved procedures,       accordance with the latest approved-for-instruction manuals, and/or any special work    construction drawings, equipment lists, and instructions ifrequired for specific equipment  specifications are available                                    (3) Documentation of protective measures taken (3) Checking of records of protective measures   during storage maintained during storage for conformance to    (4) Physical integrity by visual examination of storage requirements                             materials and equipment for damage, corrosion, (4) Visual examination of materials and          contamination, and condensation.
equipment to assure physical integrity such as absence of physical damage, rust or corrosion, contact contamination, and condensation Equipment shall be located, installed,          5.1 Equipment Placement.                            Similar assembled, and/or connected in strict                                                                Same Intent accordance with the following as applicable:     Equipment shall be located, installed, assembled, and connected in strict accordance with the following:
(1) Latest approved-for-construction drawings    1) Latest approved-for-construction drawings        Similar (2) Manufacturers' instructions                  (2) Installation specifications and procedures,     Same Intent (3) Installation specifications and procedures   where required by the planning of 3.2 NQA-1 omitted "(2)
Manufacturers' instructions" Care shall be especially exercised in following  5.2 Precautions. Care shall be exercised in         Similar the provisions of the above documents for        following the provisions of the documents listed    Same Intent operations such as:                              in 5.1 for operations such as:
(1) Cable pulling                                (1) Cable pulling                                   Similar (2) Cable splicing                               (2) Cable splicing                                  Same Intent (3) Cable terminating                            (3) Cable terminating (4) Cable routing including maintaining required (4) Cable and instrument sensing line routing,      Items 7 - 10 added in NQA-1 separation between redundant systems             including maintenance of required separation (5) Tagging and/or identifying various items     between redundant systems including cable                                  (5) Tagging or identifying, or both, various items, (6) Installing electric and instrumentation      including cable, and temporary conditions penetration assemblies and assuring the          (6) Installing electric and instrumentation integrity of the containment seals               penetration assemblies and assuring the integrity of the containment seals (7) Installation of fire stops and fire barriers (8) Installation of instrumentation piping or tubing -
(9) Mounting and supporting of equipment (10) Removal of temporary shipping supports and holddown bolts (11) Installation of environmental and pressure seals
: 5. Verification During Construction              6. Verification During Installation                 Similar Same Intent 5.1 Inspections. Surveillance of construction    Verification during installation shall include      Similar activities shall include inspections of the work inspections and tests performed in accordance       Same Intent areas and the work in progress to assure         with the QA program requirements.
conformance to applicable requirements.
Inspections shall include the following, as      6.1 Inspections. Inspections performed during       Similar appropriate:                                     installation shall include the following.           Same Intent 9 of 22                                                  7/27/10

Enclosure 4, Table 4 ANSI N45.2.4-1972 vs NQA-1-1994, Subpart 2.4 5.1.1 Inspections to Verily uorrectness ot        ti.1.1 Inspections to verily uorrectness ot        zimiiar Installation. Inspection shall be made to verify  Installation. Inspections shall be performed to    Same Intent that equipment is being located, installed,       verify that equipment is being located, installed, assembled, and/or connected to comply with        assembled, and connected to comply with latest latest approved-for-construction drawings,        approved-for-construction drawings and manufacturers' instructions, and installation     installation specifications and procedures.
specifications.
Such inspections shall include, as appropriate,     Inspections shall include such items as          OK verification of:                                  verification of:
(1) Leveling and alignment                        (I) Leveling and alignment (nonrotating            Similar (2) Clearances and tolerances                     equipment)                                         Same Intent (3) Proper location and routing of cables and     (2) Clearances and tolerances                      Items 13 - 18 added in NQA-1 sensing lines                                     (3) Location, support, and routing of cables and (4) Tightness of connections and fastenings-      sensing lines (5) Freedom of movement                           (4) Tightness of connections and fastenings and (6) Correct polarity                               use of proper tools (7) Proper grounding                              (5) Freedom of movement (8) Terminations                                  (6) Polarity (9) Fluid levels and pressures                    (7) Grounding and shielding (10) Absence of leaks                            (8) Terminations (11) Physical integrity                          (9) Fluid levels and pressures (12) Identifications                              (10) Absence of leaks (111)Physical integrity (12) Identifications (13) Circuit fusing (14) Equipment rating (15) Fire stops and fire barriers (16) Installation of mountings and supports (17) Lubrication of bearings (18) Environmental and pressure seals 5.1.2 Inspections to Verify Housekeeping.         6.1.2 Inspections to Verify Housekeeping and      OK Inspections shall be made to verify adequacy of Protective Measures. Inspections shall be housekeeping in work areas.                       performed to verify the adequacy of housekeeping in work areas [2].
Inspections shall be performed on a regular       These words were added in schedule and properly documented to verify that   NQA-1 the following protective measures are adequate.
(1) Protective measures applied for lay-up during These words were added in construction are in accordance with procedures    NQA-1 or specifications Adequacy of barriers and protective covers        (2) Protective measures to prevent damage as a    Similar shall be evaluated to assure that items will not  result of adjacent activity be damaged as a result of adjacent construction activity.
Adequacy of protective measures shall be          (3) Protective measures to prevent damage to      Similar evaluated to assure that equipment being used measuring and test equipment during field use for testing will not be damaged.
5.1.3 Inspection of Temporary Conditions.         6.1.3 Inspections of Temporary Conditions.        OK 10 of 22                                                7/27/10

Enclosure 4, Table 4 ANSI N45.2.4-1972 vs NQA-1 -1994, Subpart 2.4 Inspections shall be made to verity adequacy c (1) Protective measures applied tor lay-up during 6imilar protective measures applied for layup during      construction are in accordance with procedures       Same Intent construction.                                     or specifications All temporary connections, such as jumpers         Inspections shall be performed to verify that all and bypass lines, and temporary set points of     temporary connections, such as jumpers and control equipment shall be clearly identified and bypass lines and temporary setpoints of control documented so that subsequent restoration can     equipment, are clearly identified and documented be ascertained prior to placing the item in       so that subsequent restoration can be service.                                          ascertained prior to placing the item in service.
5.2 Tests.                                        6.2 Tests.                                           OK Surveillance of construction activities shall     NQA-1 Part II Introduction includes similar         Similar include tests performed in accordance with        language with the same intent:                       Same Intent written test procedures to verify that items being installed comply with specified quality      Installation, inspection, test procedures, and work and performance requirements.                     instructions identified during planning shall be These tests should be performed at appropriate    prepared.
points in the construction phase as access         When these tests serve as a prerequisite or a permits or when questions arise as to the         part of the test of the completed system' a review quality of components or workmanship.             of construction activity that may have affected the Where preliminary operation of equipment,          results shall be made.
during construction, is utilized for a testing      Manufacturers' tests on fabricated items may be function, the purpose of the test, its scope, and  accepted for equipment not disturbed during the results shall be clearly established and          construction phase.
documented.                                       Tests performed during installation shall be those Tests shall be repeated if construction or         specified in the planning in 3.2 and shall include associated activity affects the results of the    a selection of the following.
tests.
The need to repeat a test shall be ascertained at the time of preparing for post-construction testing in accordance with 6.2.
Tests during construction shall include the following:
5.2.1 Electrical Tests.                            6.2.1 Electrical Tests                               OK The following electrical tests shall be                                                                Editorial difference.
performed:                                                                                              Same effect Similar (1) tests to ascertain circuit continuity, absence (1) Tests to ascertain circuit continuity, absence   Same Intent of short circuits, correct polarity and correct    of improper grounds and short circuits, correct      "Protective relays and breakers" direction of rotation                              polarity and correct direction of rotation.          added to item 2 (2) Tests to ascertain proper functioning of       (2) Tests to ascertain proper phasing and systems, including indicating meters, recorders,   functioning of equipment, including indicating transducers, targets and lamps, annunciators       meters, recorders, transducers, targets and and alarms, controls and interlocks                lamps, annunciators and alarms, controls, (3) Voltage breakdown tests on liquid insulation   interlocks, protective relays and breakers (4) Overpotential tests as specified               (3) Voltage breakdown tests on fluid insulation (5) Insulation resistance measurements as          (4) Overpotential tests as specified specified                                          (5) Insulation resistance measurements as specified When overpotential tests are performed, the        When overpotential tests are performed, the          Similar values shall conform to the applicable codes       manufacturers' recommendations shall be              Same. Intent and standards. The manufacturers'                  considered.
recommendations shall always be considered.
11 of 22                                                   7/27/10

Enclosure 4, Table 4 ANSI N45.2.4-1972 vs NQA-1-1994, Subpart 2.4 D.L.z  iviecnanicai i ests. Mecnanicai tests snaii o.z.j Mecnanicai I es5s. LedK or now Lebss snWii be performed to ascertain that electric and/or. be performed to demonstrate the operation of           Same Intent instrumentation components or systems can          electric instrumentation equipment or systems.
withstand systems pressure ratings.                As a minimum, such tests shall be applied to As a minimum, such tests shall be applied to       pressure sensing and transmitting devices pressure sensing and transmitting devices          operating in steam, hydraulic, or pneumatic operating in steam, hydraulic, and vacuum          interconnecting piping or tubing and associated systems and their hydraulic or pneumatic           instruments to ascertain that they can withstand interconnecting piping or tubing and associated    systems pressure ratings.
instruments.
Pressurized equipment which is a part of           Pressurized equipment that is a part of electric       Similar electric apparatus such as heat exchangers, .      apparatus, such as heat exchangers, circulating        Same Intent circulating systems, actuating systems, and        systems, actuating systems, and electric and electric and instrumentation containment           instrumentation containment penetrations, shall penetrations shall likewise be tested if site      be tested.
assembled or fabricated.
Manufacturers' tests on fabricated items may       6.2 Tests. Manufacturers' tests on fabricated          OK be accepted for equipment not disturbed during     items may be accepted for equipment not the construction phase.                            disturbed during the construction phase.
These tests shall be in accordance with the        (3.2) Planning shall take into account the need        Planning per 3.2 establishes applicable codes and standards.                    for the preparation and control of procedures and      appropriate requirements work instructions necessary to comply with the requirements for installation, inspection, and testing of equipment and systems.
If equipment is assembled at the construction      (1.2) . The requirements set forth in this standard    Applicability of this part is to site, tests shall be conducted after the           apply to the work of any organization that             activities related to final assembly is complete even though the               participates in the installation, inspection, testing, installation and construction components may have been previously tested. or modification of power, instrumentation, and control equipment and systems in a nuclear facility from the time that the equipment is turned over for installation until it is integrated into a system.
5.2.3 Physical and Chemical Tests. These tests 6.2.2 Physical and Chemical Tests                          Similar shall include, as appropriate:                                                                            Same Intent (1) Chemical analyzing of fluids for oxygen or     (1) Chemical analysis of fluids for oxygen or          OK moisture content and'purity                        moisture content and purity (2) Radiation sensitivity testing to confirm that  (2) Radiation testing to confirm that radiation radiation sensors and controlling devices are      sensors and controlling devices are properly properly functioning                               functioning.
These tests shall be in accordance with the                                                               Planning per 3.2 establishes applicable codes in Appendix B.                                                                           appropriate requirements
: 6. Post-ConstructionVerification                   7. Post-Installation Verification                      OK 6.1 Inspections. Installed equipment and           7.1 Inspections. Installed equipment and systems systems shall be inspected to verify the           shall be inspected to verify that:
following:
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Enclosure 4, Table 4 ANSI N45.2.4-1972 vs NQA-1 -1994, Subpart 2.4 k i) i nat equipment ano materiais nave not        (1 ) -quipment ana matenais nave not sustainea sustained damage during installation               damage during installation (2) That good and proper workmanship has           (2) Good and proper workmanship has prevailed prevailed                                          (3) The installation has been made in accordance (3) That the installation has been made in         with specified requirements accordance with specified requirements             (4) All nonconforming items have been (4) That all nonconforming items have been         satisfactorily resolved satisfactorily resolved                            (5) Appropriate protective measures are applied (5) That appropriate protective measures are       for lay-up after installation applied for lay-up after installation (6) That all temporary conditions such as          (6) All temporary conditions, such as jumpers,-    OK jumpers, bypass lines, and temporary set points    lifted leads, bypass lines, and temporary set-have been clearly identified so that subsequent    points, have been clearly identified so that restoration can be ascertained prior to placing    subsequent restoration can be ascertained prior the items in service                               to placing the items in service.
To satisfy the above objectives, inspections       To satisfy the above objectives, it may be         Similar defined in 5.1 shall be repeated, as               necessary to repeat some of the inspections        Same Intent appropriate-ate,                                   defined in 6.1.
6.2 Tests. Installed equipment and systems         7.2 Tests. Installed equipment and systems shall. OK shall be tested to demonstrate that the            be tested to demonstrate that they have been in-installation has been made in accordance with      stalled in accordance with design requirements design requirements and that the operation         and that the operation gives the desired result.
gives the desired result.
Temlorary electrical connections, temporary        Temporary electrical connections, temporary        OK piping sections, abnormal chemical solutions,      piping sections, abnormal chemical solutions, unspecified setting of devices, the fixing of a    unspecified setting of devices, the temporary moving component, or the effecting of any other    blocking or the effecting of any other abnormality abnormality if made previously shall be rectified   previously made shall be rectified before final before final testing except in cases where fuel    testing except in cases where fuel loading or loading or other critical operations prevent        other operations prevent using the complete using the complete assembly for the test.           assembly for the test.
In these instances, a documented notice shall      In these instances, a documented notice stating   Similar, be prepared stating the substitutions that         the temporary test conditions shall be prepared   Same Intent existed for the test.                              and be referenced to the appropriate test report or data sheet.
In final testing that precedes system              In final testing that precedes preoperational     OK performance testing, normal system readout        testing, normal system readout devices and devices and installed transducers shall be used     installed transducers shall be used as far as as far as possible to monitor the operation.        possible to monitor the operation.
Where the installed equipment is not adequate      Where the installed equipment is not adequate      OK for the purpose of conducting tests, special       for the purpose of conducting tests, special measuring instruments and simulating devices       measuring instruments and simulating devices shall be used.                                     shall be used.
Test equipment used shall have adequate            Test equipment used shall have adequate            Similar capacity and be compatible with system under        capacity and tolerance and be compatible with     Same Intent test so that the results will not be distorted,     the system under test.
6.2.1 Equipment Tests. Tests shall be               7.2.1 Equipment Tests. Tests shall be performed Similar performed to verify that the quality of installed  to demonstrate that the installed equipment is in Same Intent equipment has not deteriorated during the           an acceptable condition to be energized where construction phase.                                manufacturers' tests or calibrations cannot be accepted (see 6.2).
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Enclosure 4, Table 4 ANSI N45.2.4-1972 vs NQA-1-1994, Subpart 2.4 I ests ana snaKeaown runs snail De maae on        Tests and shakedown runs shall be made on energized systems where necessary to              energized systems where necessary to evaluate evaluate operations and to properly condition     operation and to properly condition for service for service (for example, the seating of brushes  (for example, the seating of brushes or bearings, or bearings, the stabilization of instrumentation the stabilization of instrumentation and burn-in of and bum-in of electronic devices).                electronic devices).
Tests shall be made to assure that                Tests shall be made to assure that                   OK instrumentation and control channels are          instrumentation and control channels are properly calibrated,                              properly calibrated.
In addition, specific tests shall be made at                                                           Properly calibrated and proper critical levels such as "set points" in a manner                                                       operation imply operating simulating the approach toward the set point,                                                          correctly at the "set points" These calibrations shall be made with these        Ifthe calibration is dependent upon location or     Similar devices in their normal positions if the          orientation, then calibrations shall be made with    Same Intent calibration is dependent upon location or         these devices in their normal positions.
attitude.
Tests shall be made to determine that proper      Tests shall be made to determine that proper         Similar response is obtained over the operating range     operation is obtained over the range of the          Same Intent of the device,                                    device.
Particular attention shall be given to verifying  Particular attention shall be given to verifying     OK independence and dependence, as                   independence and dependence, as appropriate, appropriate, of the elements of the systems.      of the elements of the systems.
Items requiring calibration shall be tagged or     Items requiring calibration shall be identified by  Similar labeled on completion indicating date of '        tags or labels indicating the identity of the person Same Intent calibration and identity of person that performed who performed the calibration and the date of the the calibration,                                   next required calibration.
6.2.2 System Tests. These tests shall be made 7.2.2 System Tests. Tests shall be made to verify OK to verify that all parts of a system properly      that all parts of a system properly coordinate with coordinate with each other.                        each other.
Tests shall be made with attention given to         Tests shall be made with attention given to         OK demonstrating required independence and            demonstrating required independence and dependence of subsystems.                          dependence of subsystems.
Consideration shall be given to demonstrating      Consideration shall be given to the need for         Similar freedom from unwanted or harmful effects of        demonstrating freedom from unwanted or               Same Intent conducted or induced electrical noise.             harmful effects of conducted or induced electrical noise.
A review shall be made of all testing that has     A review shall be made of testing that has           OK preceded the final integrated system testing       preceded the final integrated system testing, including both the tests made on assemblies        including the tests made on equipment with and components with particular attention given particular attention given to those that to those that demonstrate functional or            demonstrate functional or operational results.
operational results.
When these tests serve as a prerequisite or a       When these tests serve as a prerequisite or a       OK part of the final system test, a review of         part of the test of the completed system, a.review construction activity which may have affected      of construction activity that may have affected the the results shall be made.                         results shall be made.
14 of 22                                                    7/27/10

Enclosure 4, Table 4 ANSI N45.2.4-1972 vs NQA-1 -1994, Subpart 2.4 The final construction-phase testing shall be     i ne rinai construction-pnase testing snaii oe     Similar made with all assemblies and components of       made with all equipment of subsystems complete Same Intent subsystems complete except where a critical      except where an operation requires that operation requires that temporary electrical     temporary electrical connections, piping sections, connections, piping sections, or structural      or structural supports be installed to make the supports be installed to make the tests.         tests.
: 7. Data Analysis and Evaluation                  8. Data Analysis and Evaluation                     Similar Same Intent Procedures shall be established for processing   Procedures shall be established for processing inspection and test data and their analysis and  inspection results and analyzing and evaluating evaluation,                                      test data.
These procedures shall include acquisition and These procedures shall include requirements for Similar reduction of inspection and test data for prompt reduction of inspection and test data for review or Same Intent evaluation against acceptance criteria,          evaluation against acceptance criteria.
operating limits and performance standards.
The data processing procedures shall provide                                                         These words are not in NQA-1 for "on-the-spot" evaluation to determine the                                                        or the QAPP. Applicable validity of the inspection and test results, the                                                     requirements will be addressed appropriateness of continuing the inspection or                                                      in associated procedures to the test.                                                                                                extent necessary for the project The data shall be analyzed and evaluated to      The data shall be analyzed and evaluated to         Similar verify completeness of results, achievement of   verify completeness, achievement of objectives, Same Intent inspection and test objectives, and operational  and correct operation of equipment and.systems, proficiency of equipment and systems; to         and to identify any additional inspection or tests identify additional inspection and/or tests      required.
required; and to identify necessary changes to the installation inspection or test procedures Inspection and test results that include         3.4 Results. Inspection and test results shall be Similar inspection and test data, together with a report documented in a suitable test report or data        Same Intent of data analysis and evaluation, shall be        sheet.
provided as specified in Section 8.              Each report shall identify the item to which it applies, the procedures or instructions and its revision number used in performing the task, and the identification of the following:
(1) Conditions encountered that were not anticipated, including nonconformance (2) Identity of inspector or tester (3) Completion date Test reports or data sheets shall include an evaluation of the acceptability of the results and provide for identifying the individual who performed the evaluation.
: 8. Records                                       9 Records                                            Similar Same Intent Record copies of completed procedures, re-      Copies of construction records such as approved ports, personnel qualification records, test    procedures, personnel qualifications, test equipment calibration records, test deviation or equipment calibration records, deviation or exception records, and inspection and            exception records, and inspection and test examination records shall be prepared.          records shall be prepared.
These shall be placed with other project         These shall be placed with other project records     OK records as required by code, standard,          as required by code,'standard, specification, or specification, or project procedures.           project procedures.
15 of 22                                                 7/27/10

Enclosure 4, Table 4 ANSI N45.2.4-1972 vs NQA-1-1994, Subpart 2.4 V. AppIJUc                                                                                           AppliCabie requirements Guides                                                                                               encompassed by NQA-1 are incorporated in the QAPP and The applicable published codes, standards, and                                                       associated procedures to the auides shall be used.                                                                                extent necessary for the proiect.
In cases where codes or standards were                                                               Applicable requirements intended to cover the manufacturing phase of                                                         encompassed by NQA-1 are an item, these codes shall be used as guides.                                                        incorporated in the QAPP and associated procedures to the extent necessary for the project.
Refer to Appendix B for a listing, not                                                               Similar necessarily complete, of additional codes,     NQA-1 Part II Introduction includes similar           Same Intent standards, and guides that should be           language with the same intent:
considered during the construction phase.
7 REFERENCED CODES, STANDARDS, AND SPECIFICATIONS All codes, standards, and specifications that are referenced as a part of this Part (Part II)are listed in the Table entitled "Codes, Standards, and Specifications Referenced in Text."
The following guides or standards refer                                                              Applicable requirements specifically to nuclear power generating                                                             encompassed by NQA-1 are stations and their construction, and shall be                                                        incorporated in the QAPP and considered applicable.                                                                               associated procedures to the extent necessary for the project.
When the following standards referred to in this      Applicable requirements document are superseded by a revision                 encompassed by NQA-1 are approved by the American National Standards           incorporated in the QAPP and Institute, the revision is not mandatory until it has associated procedures to the been incorporated as part of this standard.           extent necessary for the project.
16 of 22                                                    7/27/10

Enclosure 4, Table 4 ANSI N45.2.4-1972 vs NQA-1-1994, Subpart 2.4 ANSI N45.2.4 - 1972                           NQA-1 (1994) Subpart 2.4~                         Commients               <
(IEEE 3361.971)                                   (exceptas noted)                (NOTE OK 0signifes dentica or..
nearly identic~al wvording.
(1) IEEE Std 279-1971, Criteria for Protection                                                  Specific provisions of Subpart Systems for Nuclear Power Generating                                                            2.4 which are applicable to Stations                                                                                        project activities will be defined (2) IEEE Std 308-1971, Criteria for Class IE                                                    in-associated procedures.
Electric Systems for Nuclear Power Generating Stations (3) IEEE Std 317-1971, Electric Penetration Assemblies in Containment Structures for Nuclear Fueled Power Generating Stations (4) IEEE Std 323-1971, Guide for Qualification of Class I ElectricEquipment for Nuclear Power Generating Stations (5) ANSI 18.2-1965, Nuclear Safety Criteria for the Design of Stationary Pressurized Water Reactor Plants (6) ANSI B31.7-1969, Nuclear Power Piping (7) IEEE Std 334-1971, Guide for Type Tests of Continuous-Duty Class I Motors In-stalled Inside the Containment of Nuclear Power Generating Stations (8) IEEE Std 336-1971, Installation, Inspection and Testing Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations (9) IEEE Std 338-1971, Trial-Use Criteria for the Periodic Testing of Nuclear Power Generating Station Protection Systems (10) IEEE Std 344-1971,Trial-Use Guide for Seismic Qualification of Class I Electric Equipment for Nuclear Power Generating Stations
[1] ANSI/ASME NQA-1-1 983, Quality Assurance   Specific provisions of Subpart Program Requirements for Nuclear Power         2.4 which are applicable to Plants.2                                        project activities will be defined in associated procedures.
[2] ANSI/ASME NQA-2-1983, Quality Assurance Requirements for Nuclear Power Plants.
[3] ANSI/ANS 3.2-1982, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants.
[4] IEEE Std 498-1985, IEEE Standard Requirements for the Calibration and Control of Measuring and Test Equipment Used in the Construction and Maintenance of Nuclear Power Generating Stations.
[5] IEEE Std 603-1980, IEEE Standard Criteria for Safety Systems for Nuclear Power Generating Stations.
[6] 1984 ASME Boiler and Pressure Vessel Code.
17 of 22                                                 7/27/10

Enclosure 4, Table 4 ANSI N45.2.4-1972 vs NQA-1 -1994, Subpart 2.4 (TIhese Appendixes are not a part ot IEEE        l u. suppiementary t'rovisions 1                       SameIar.
Same Intent Standard Installation. Inspection, and Testing   Stations and Operating Plants Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear     For construction activity in nuclear facilities Power Generating Stations.)                      where one or more units are already operating or have reached a stage in their construction where Appendix A                                       the fuel has been loaded in the reactor and Supplementary Provisions for Multi-Unit          associated systems energized for whatever Stations                                         purpose, the following measures shall be taken in addition to the provisions defined elsewhere in For construction activity in nuclear power      this standard.
generating stations where one or more units are already operating or have reached a stage in their own construction where the fuel has been loaded in the reactor and associated systems energized for whatever purpose,.the following measures shall be taken in addition to the provision defined in the body of this document.
AL. Planning and Preparation                     10.1 Planning and Preparation. Instructions,           OK procedures, or drawings shall be prepared to Instructions, procedures or drawings shall be    control installation, inspection, and testing prepared to control installation, inspection and activities at areas of interface between the new testing activities at areas of interface between and existing units. These instructions and the new and existing units. These instructions   procedures or drawings shall define the following:
and procedures or drawings shall define:         (1) The areas of interface between the new and (1) The areas of interface between the new and existing units -
existing units                                  (2) Access control and authority for work at these (2) Access control and authority for work at    interface areas these interface areas                           (3) Nature of potential hazards to or from the (3) Nature of potential hazards to and/or from   existing equipment the existing equipment                           (4) Precautions required to be taken during (4) Precautions required to be taken during      installation installation                                    (5) Supplementary objectives for inspection and (5) Supplementary objectives for inspection and testing testing A2. Documentation                                10.2 Documentation                                    Similar Same Intent 10.2.1 "documented" and "as A2.1 The instructions, procedures or drawings   The instructions, procedures, or drawings              necessary" are omitted from described in Section Al shall be documented     described in 10.1 shall be kept current by             NQA-1 and shall be kept current by revisions as       revisions.
necessary.
18 of 22                                                   7/27/10

Enclosure 4, Table 4 ANSI N45.2.4-1972 vs NQA-1-1994, Subpart 2.4 A2.2 I he equipment and/or systems which are.      1U.2.2 I he equipment or systems wnich are "
associated with existing unit(s) that are          associated with existing unit(s) that are electrically energized or charged with             electrically energized or charged with pressurized pressurzed and/or radioactive fluids and which     or radioactive fluids and which are in the vicinity are in the vicinity of the construction activity   of the construction activity associated with the associated with the new unit shall be properly     new unit shall be properly tagged or identified.
tagged or identified.
A2.3 The documentation associated with             10.2.3 The documentation associated with             OK installation described in Section 2.2 of the main  installation described in 10.2.2 shall also include:
document shall additionally include:               (1) The identification of the equipment or sys-tem A2.3.i The identification of the equipment         defined in 10.2.2 which poses a potential hazard and/or system defined in 2.2 above, which          in the vicinity of current construction activity poses a potential hazard in the vicinity of        (2) Identification of the potential hazard of such current construction activity,                     neighboring energized systems as voltage, A2.3.2 Level of potential hazard from such         radiation level, fluid pressure, or temperatures neighboring energized systems, such as: volt-age, radiation level, fluid pressure and/or temperatures.
A2.4 Authorizations for access to and work at      10.2.4 Authorizations for access to and work at      OK the areas of interface between the new and         the areas of interface between the new and existing units shall be documented.                existing units shall be documented.
10.2.5 Provisions of Section 9 shall be              These words were added in implemented to supplement or supersede               NQA-1 documents or records as required.
A3. Installation                                   10.3.1 Suitable protective barriers shall be         OK erected where needed, to prevent damage to A3.1 Suitable protective barriers shall be         equipment or systems associated with the erected to prevent damage to equipment and/or existing unit(s).
systems associated with the existing unit(s).
A3.2 Spare capacities available in existing        10.3.2 Spare capacities available in the existing OK facility such as in cable raceways or in           facility, such as in cable raceways or in panelboards shall not be used unless expressly panelboards, shall not be used unless expressly indicated on the latest applicable approved-for- indicated on the latest applicable approved-for-construction drawings or installation              construction drawings or installation specification.
specification.                                    II 19 of 22                                                7/27/10

Enclosure 4, Table 4 ANSI N45.2.4-1972 vs NQA-1-1994, Subpart 2.4 I his does not proflioit autfonzed temporary use      Inese words were a of such spare capacities.                             NQA-1 A3.3 When working in an area common to the        10.3.3 When working in an area common to the OK new and the existing units, such as the cable     new and the existing units, such as the cable spreading room, control room, radio-active        spreading room, control room, or radioactive waste building or the battery room, care shall    waste building, care shall be especially exercised be especially exercised to avoid interference     to avoid interference with existing facilities and to with existing facilities and to maintain required maintain required separation, where appropriate, separation, where appropriate, between the        between the systems associated with existing systems associated with existing and new units. and new units.
A4. Inspection                                    10.4 Inspection                                       Similar A4.1 Inspection shall be performed to verify that 10.4.1 Inspection shall be performed to verify that Same Intent existing equipment and/or systems neighboring     the requirements of 10.2 and 10.3 have been current construction activity are properly tagged satisfied.
and identified, and potential hazards therefrom identified and documented.
A4.2 Inspection shall be performed to verify that 10.4.2 Inspection shall be performed to verify that OK the existing facilities are properly protected - the existing facilities are properly protected from from current construction activity,               construction activity.
AS. Testing                                       10.5 Testing                                          OK In testing integrated electrical control or A5.1 In testing integrated electrical, control,   instrumentation systems, or both, where the plant and/or instrumentation systems where the plant design calls for interconnection between the design calls for interconnection between the      existing and new systems, care shall be existing and new systems, care shall be           exercised to prevent tripping or otherwise especially exercised to prevent tripping or       disturbing the operation of equipment or systems otherwise dislocating the operation of            associated with the existing unit(s).
equipment and/or systems associated with the existing unit(s).
Appendix B                                                                                               No corresponding requirement Additional Codes, Standards and Guides                                                                  in NQA-1. Specific provisions of codes, standards and guides not included in Subpart 2.4 which are applicable to project activities will be defined in associated procedures.
1'.ANSI C1 -1968,' National Electrical Code                                                              No corresponding requirement (NFPA 701 968) (to be used as a guide when                                                              in NQA-1. Specific provisions of appropriate)                                                                                            codes, standards and guides
: 2. ANSI C29.1-1961, Test Methods for                                                                    not included in Subpart 2.4 Electrical Power Insulators                                                                             which are applicable to project
: 3. ANSI Appendix C57.93, Guide for Installation                                                         activities will be defined in and Maintenance of Oil-Immersed                                                                         associated procedures.
Transformers
: 4. ANSI Appendix C57.94, Guide for Installation and Maintenance of Dry-Type Transformers
: 5. ANSI C96.1-1969, Temperature Measurement Thermocouples
: 6. API RP550-1965,2 Manual on Installation of Refinery Instruments and Control Systems, Part I - Process Instrumentation and Control
: 7. API RP550-1965, Manual on Installation of Refinery Instruments and Control Systems, Part 20 of 22                                                      7/27/10

Enclosure 4, Table 4 ANSI N45.2.4-1972 vs NQA-1-1994, Subpart 2.4 II- Process Stream Analyzers
: 8. ASME Boiler and Pressure Vessel Code, Section III, Nuclear Power Plant Components, 1971
: 9. IEEE Std 4-1968, Techniques for Dielectric Tests (ANSI C68.1-1968)
: 10. IEEE Std 43-1961, Recommended Practice for Testing Insulation Resistance of Rotating Machinery
: 11. IEEE Std 51-1955, Guiding Principles for Dielectric Tests
: 12. IEEE Std 56-1958, Guide for Insulation                                       No corresponding requirement Maintenance for Large AC Rotating Machinery                                      in NQA-1. Specific provisions of
: 13. IEEE Std 62-1958, Guide for Making                                           codes, standards and guides Dielectric Measurements in the Field                                             not included in Subpart 2.4
: 14. IEEE Std 64-1969, Guide for Acceptance                                       which are applicable to project and Maintenance of Insulating Oil in Equipment                                   activities will be defined in
: 15. IEEE Std 81-1962, Guide for Measuring                                        associated procedures.
Ground Resistance and Potential Gradients in the Earth
: 16. IEEE Std 95-1962. Guide for Insulation Testing of Large AC Rotating Machinery with High Direct Voltage
: 17. IEEE Std 1 12A-1 964, Test Procedure for Polyphase Induction Motors and Generators
: 18. IEEE Std 114-1969, Test Procedure for Single-Phase Induction Motors
: 19. IEEE Std 115-1965. Test Procedure for Synchronous Machines
: 20. IEEE Std 118-1949, Master Test Code for Resistance Measurement
: 21. IEEE Std .120-1955 (withdrawn), Master Test Code for Electrical Measurement in Power Circuits
: 22. IEEE Std 262-1968, Test Code for Distribution, Power and Regulating Trans-formers, and Shunt Reactors (ANSI C57.12.90-1968) 21 of 22                                     7/27/10

Enclosure 4, Table 4 ANSI N45.2.4-1972 vs NQA-1-1994, Subpart 2.4 ANSI N45.2.4 - 1 97 2                      NQA- 1(1 994) S u pa rt 2.4           Commets1
: 23. IEEE Std 283-1968, Guide for Installation of                                  No corresponding requirement Oil-Immersed Transformers                                                         in NQA-1 Specific provisions o0f
: 24. ISA-RP3.1,4 Flowmeter Installations, Seal                                     codes, standards and guides and Condensate Chambers, 1960                                                     not included in Subpart 2.4
: 25. ISA-S5.1, Instrumentation Symbols and                                         which are applicable to project Identification, 1968                                                              activities will be defined in
: 26. ISA-RP7.1, Pneumatic Control Circuit                                          associated procedures.
Pressure Test, 1956
: 27. ISA-RP7.2, Color Code for Panel Tubing, 1957
: 28. ISA-RP8.1, Instrument Enclosures for Industrial Environments
: 29. ISA-RP25.1, Materials for Instruments in Radiation Service, 1957
: 30. ISA-526, Dynamic Response Testing of Process Control Instrumentation, 1968
: 31. ISA-537.1, Electrical Transducers Nomenclature and Terminology, 1969
: 32. ISA-RP42.1, Nomenclature for Instrument Tubing Fittings (Threaded), 1965
: 33. NEMA ICS-1970,5 Industrial Controls and Systems
: 34. NEMA IS1.1-1969, Enclosures for Indus-trial Controls and Systems
: 35. NEMA SG 3-1965, Low-Voltage Power Circuit Breakers 36: NEMA SG 5-197 1, Power Switchgear Assemblies
: 37. NEMA VE 1-1965, Ventilated Cable Trays 22 of 22                                     7/27/10

Enclosure 4, Table 5 ANSI N45.2.5-1978 vs NQA-1-1994, Subpart 2.5
:imliar Same Intent This standard sets forth the supplementary          Subpart 2.5 provides amplified requirements for quality assurance requirements for installation,    installation, inspection, and testing of structural inspection, and testing of nuclear safety related   concrete, structural steel, soils, and structural concrete, structural steel, soils, and   foundations, foundations for nuclear power plant construction.
It applies to the following:                        and applies to the following:                         OK
: 1. Formwork                                         (a) formwork
: 2. Steel Reinforcement                              (b) steel reinforcement
: 3. Embedded Items                                    c) embedded items
: 4. Foundation Preparation                           (d) foundation preparation
: 5. Concrete                                         (e) concrete
: 6. Structural Steel                                 () structural steel
: 7. Soils and Earthwork                              (g) soils and earthwork
: 8. Special Foundations                              (h) special foundations (i) foundation underpinning The requirements may also be extended to other                                                            Similar appropriate parts of nuclear rower plants when      It supplements the requirements of Part I and         Same Intent specified in contract documents.                    shall be used in conjunction with applicable Basic and Supplementary Sections of Part I when and to the extent specified by the organization invoking Subpart 2.5.
This standard is intended to be used in              It supplements the requirements of Part I and        Similar conjunction with ANSI N45.2.                         shall be used in conjunction with applicable         Same Intent Basic and Supplementary Sections of Part I when and to the extent specified by the organization invoking Subpart 2.5.
1.2 APPLICABILITY                                   2 GENERAL REQUIREMENTS                                Similar Same Intent The requirements of this standard apply to the      The requirements of Subpart 2.5 apply to any work of any organization or individual              organization or individual participating in work participating in the production, preparation,        relating to production, preparation, placement, placement, inspection, and testing of structural     installation, inspection, and testing of structural concrete, structural steel, soils and foundations,   concrete, structural steel, soils, and as identified in Section 1.1.                        foundations, and applies to the following:
The extent to which the individual requirements      NQA-1 Part II Introduction includes similar          Similar of this Standard apply will depend upon the          language with the same intent:                       Same Intent nature and scope of the work to be performed         An appropriate Quality Assurance Program, and the importance of the item or service            based on the nature and scope of the work to involved,                                            be performed and the relative importance of the items or services, shall be specified in contractual documents by selective applications of portions of Part I, Basic and Supplemental Requirements, for programmatic activities and of this Part (Part II) for work oriented activities.
1 of 33                                                 7/27/10

Enclosure 4, Table 5 ANSI N45.2.5-1978 vs NQA-1-1994, Subpart 2.5 only specified materials and workmanship are incorporated into the plant; that quality of materials and quality of workmanship are              This Part (Part II)sets forth the quality maintained throughout the construction process;       assurance requirements for the planning and that the work is performed in accordance with         execution of identified tasks during the applicable construction procedures; and that the      fabrication, construction, modification, repair, completed installation conforms to the specified      maintenance, and testing of systems, requirements.                                         components, and structures for nuclear fnrilifiao The ASME Boiler and Pressure Vessel Code,                                                                 Guidance only. Wording does not Section III, Divisions 1 and 2, as well as other                                                          establish requirements American National Standards, have been considered in the development of this standard; and this standard is intended to be compatible with their requirements.
This standard applies to structural concrete,         Subpart 2.5 provides amplified requirements for Similar structural steel, and foundation components of        installation, inspection, and testing of structural Same Intent nuclear power plants not covered by the Code.         concrete, structural steel, soils, and foundations.
However, this Standard does not apply to                                                                  Guidance only. Wording does not activities covered by Section III, Divisions 1 and                                                        establish requirements 2 and Section Xl of the Code for those activities covered by the Code, 1.3 RESPONSIBILITY                                   NQA-1 Basic Requirement 1 includes similar           Similar words: The organizational structure, functional      Same Intent The organization or organizations responsible        responsibilities, levels of authority, and lines of for establishing the applicable requirements for     communication for activities affecting quality the activities covered by this standard shall be     shall be documented.
identified, and the scope of their responsibilities shall be documented.                                 Supplement 1 S-1 3.1 Responsibility.
Where more than one organization is involved in the execution of activities covered by this Part (Part II), the responsibility and authority of each organization shall be clearly established and documented.
The work of establishing practices and               NQA-1 Supplement 1S-1 2.2 Delegation of              Similar procedures and providing the resources in terms Work includes similar words: The individuals(s) Same Intent of personnel, equipment, and services                or organizations(s) responsible for establishing necessary to implement the requirements of this and executing a quality assurance program Standard may be delegated to other                   under this Standard may delegate any or all of organizations, and such delegation also shall be the work to others but shall retain responsibility documented.                                          therefor.
It is the responsibility of each organization        The organization upon which this Part (Part II),     Similar performing work covered by this standard to          or portions thereof, is invoked shall be             Same Intent comply with the procedures and instructions          responsible for complying with the specified issued for theproject and to conform to the          requirements.
requirements of this standard applicable to their work.
It is the responsibility of the organization          Part II Introduction                                Similar performing these activities tospecify the detailed    2 Applicability                                     Same Intent methods and procedures unless they are                Planning shall define the operations to be specified in the procurement documents.               performed, the systematic sequential progression of operations, and the overall measures to be employed to preserve the quality of the work.
2 of 33                                                   7/27/10

Enclosure 4, Table 5 ANSI N45.2.5-1978 vs NQA-1-1994, Subpart 2.5 The following definitions are provided to assure a The following definitions are provided to assure uniform understanding of select terms as they        a uniform understanding of unique terms as are used in this standard.                           they are used in Subpart 2.5.
Additional definitions of terms are included in      NQA-1 Part II Introduction includes similar        Similar ANSI N45.2.10.                                       language with the same intent:                     Same Intent 6 DEFINITIONS Definitions unique to the activities described in this Part (Part II) are included in the section dealing with that activity. Definitions generic to quality assurance activities are included in Part I, Supplement S-1, Terms and Definitions.
Class of Concrete   -  Identifies each individual    class of concrete - identifieseach individual      OK design mix.                                          design mix Correlation Testing - A form of in-process testing   correlation testing - a form of in-process         OK accomplished consistent with established             testing accomplished consistent with procedures and which provides for the                established procedures, which provides for the comparison on results of specified tests of          comparison of results of specified tests of concrete samples taken of corresponding              concrete samples taken of corresponding batches from two different points to establish to    batches from two different points to establish to what extent the conditions and method of transit     what extent the conditions and method of has impacted on specified requirements for           transit have impacted on specified plastic concrete at the placement point,             requirements for plastic concrete at the placement point Curing - The process of maintaining a                curing - the process of maintaining a              OK satisfactory moisture content and a favorable        satisfactory moisture content and a favorable temperature in concrete during hydration of the      temperature in concrete during hydration of the cementitious materials so that desired properties    cementitious materials so that desired of the concrete are developed,                       properties of the concrete are developed Delivery Point - The point of discharge in the       delivery point - the point of discharge in the     Similar case of a truck agitator unit, or non-agitating unit case of a truck agitator unit, or non-agitating    Same Intent when another conveying device is to be used to       unit when another conveying device is to be transport the plastic concrete to the placement      used to transport the plastic concrete to the      Statement 'When a non-agitating point. Where a truck agitator unit is used in the    placement point. Where a truck agitator unit is    unit is used, the delivery point and transit of concrete, the delivery point and the      used in the transit of concrete, the delivery      the.mixing point shall not be mixing point are considered coincident when: (1)     point an'd the mixing point are considered         considered coincident." was added the delivery point is not more than a distance of    coincident when:                                   in NQA-1.
two miles and an average of one half-hour in         (a) the delivery point in not more than a transit from the mixing point, and (2) the           distance of 2 mi (3.22 kin) and a maximum time delivered concrete commences to be placed            of 1/2 hr in transit from the mixing point, and within an average of one-half hour from the time     (b) the delivered concrete commences to be the transporting vehicle arrives at the delivery     placed within a maximum time of 1/2 hr from point,                                               the time the transporting vehicle arrives at the delivery point.
When a non-agitating unit is used, the delivery point and the mixing point shall not be considered coincident.
Finishing - The process of obtaining specified       finishing - the process of obtaining specified     OK surface characteristics of hardened concrete.        surface characteristics of hardened concrete 3 of 33                                                    7/27/10

Enclosure 4, Table 5 ANSI N45.2.5-1978 vs NQA-1-1994, Subpart 2.5 Mixing Point - The point of discharge of plastic    mixing point - the point of discharge of plastic concrete from a central mix plant. For truck        concrete from a central mix plant. For truck mixed concrete the mixing point and delivery        mixed concrete, the mixing point and delivery point are defined as coincident.                    point are defined as coincident.
Placement Point-The point of discharge of plastic   placement point - the point of discharge of       OK concrete into the forms. Except for pumped          plastic concrete into the forms. Except for concrete the placement point and the delivery       pumped concrete, the placement point and the point are considered coincident when 5 minutes      delivery point are considered coincident when 5 or less is used in transit of the concrete from the min or less is used in transit of the concrete delivery point to the placement point,              from the delivery point to the placement point.
Qualified Procedures - Procedures which             ASME NQA-1 Section I Introduction Subsection OK incorporate applicable codes and standards,         4 Terms and Definitions:
manufacturer's parameters, and engineering specifications.                                     Qualified procedure - an approved procedure that has been demonstrated to meet the specified requirements for its intended purpose.
Qualification Tests - Tests performed to qualify qualification tests - tests performed toqualify OK.
the basic material source or manufacturer.          the basic material source or manufacturer to These tests are mandatory unless current            assure conformance to specification documentary test data is available to establish     requirements complete confidence in conformance to specification requirements.                         also 4.2 To assure that materials meet specified requirements, preconstruction qualification tests and inspections of the materials to be used and in-process tests of materials being used shall be conducted. Qualification tests shall be performed and the results evaluated prior to the initial use of the material to establish conformance of the materials to the specified requirements. These tests are mandatory unless current documentary test data are available to establish complete confidence in conformance to specification requirements.
In-Process Tests - Tests performed during the       in-process tests - tests performed during the OK course of construction to determine compliance course of construction to determine compliance with specified requirements and to maintain        with specified requirements and maintain control of structural materials. These tests may control of materials. These tests may be be performed by the purchaser (or his agent),       performed by the purchaser (or his agent),
contractor, manufacturer or supplier, but           constructor, manufacturer, or supplier, but samples for these tests must be taken from the samples for these tests must be taken from the lot or batch of materials supplied and used at the lot or batch of materials supplied and used at site of construction,                               the site of construction.
: 2. GENERAL REQUIREMENTS                             3 REQUIREMENTS                                   OK 2.1 PLANNING                                       Measures shall be established and implemented for documenting installation, Measures shall be established and implemented inspection, and testing activities to verify for documenting installation, inspection, and       conformance to specified requirements.
testing operations to verify conformance to specified requirements.
4 of 33                                     7/27/10

Enclosure 4, Table 5 ANSI N45.2.5-1978 vs NQA-1-1994, Subpart 2.5 rHldllllll bl alil LCI~*V HIVLuCl.A,.IUllL L  ll IM  U HUHk.11U preparation and control of procedures and work                                                                 Same Intent instructions necessary to comply with                       Planning and procedure preparation shall be in requirements for installation, inspection, and              accordance with the Introduction to this Part testing.                                                    (Part II)
NQA-1 Part II Introduction includes similar language with the same intent:
                                                            "A plan shall be developed outlining the work to be performed and the work procedures or instructions required to comply with the requirements of the defined work scope."
Planning shall include a review of the structure,           NQA-1 Part II Introduction includes similar        Similar system, or component design and procurement                 language with the same intent:                     Same Intent specifications, materials lists, drawings, construction work plans, procedures, and                    "Planning shall include a review of the schedules to assure that installation, inspection,          structure, sys-tem or component and testing activities have been incorporated;              design/procurement specifications, materials, that they can be accomplished as specified; and             lists, drawings, construction work plans, and that time and resources are sufficient to                   schedules to ensure that fabrication, accomplish the scheduled construction without               installation, modification, inspection, testing, degradation of quality.                                     etc., activities have been incorporated; that the work can be accomplished as specified; and that time and resources, plus training, are sufficient to accomplish the work in accordance with the specified requirements.
2.2 Procedures and Instructions                             NQA-1 Part II Introduction includes similar        Similar language with the same intent:                     Same Intent Installation, inspection and test procedures, and Installation, inspection, test procedures, and work instructions shall be prepared and                     work instructions identified during planning shall documented for those activities falling within thc be pre-pared.
scope of this Standard.
These documents shall be revised and controlled             NQA-1 Part II Introduction includes similar        Similar as necessary to assure that installation,                   language with the same intent:                     Same Intent inspections, and tests are performed in                     The documents shall be kept current and accordance with latest information and shall                revised as necessary to assure that the work is include as appropriate:                                     per-formed in accordance with the latest approved information.
The documents shall include the following as applicable:
5 of 33                                               7/27/10

Enclosure 4, Table 5 ANSI N45.2.5-1978 vs NQA-1 -1994, Subpart 2.5 I. III &#xfd;LO..OLI I I OFVW.. Hl.ll UI I.
: 2. Inspection and test objectives and              language with the same intent:                     SameIntent requirements.                                      (a) personnel safety and structure or facility
: 3. Precautions to avoid component or system        protection considerations damage during installation, inspection, and        (b) precautions to be observed following inspection but prior to use.             (c) work requirements including installation
: 4. Inspection and test equipment required.         specifications.
: 5. Sequence of tests (if applicable).              (d) sequence of activities to be followed and
: 6. Sequential actions to be followed.              steps within a given activity
: 7. Frequency of inspections and tests.             (e) prerequisites including preparatory checks
: 8. Prerequisites.                                  and inspections
: 9. Approvals.                                      (f) test and inspection objectives
: 10. Data report form.                              (g) special equipment required
: 11. Identification of test equipment and date of   (h) identification of inspection and test required recalibration where required for          equipment and related calibration requirements interpretation of test results.                    including recalibration dates
: 12. Inspection and test acceptance limits.         Ci)sequence and frequency of inspection or test (i) acceptance criteria and methods for verifying (k) responsibility and required qualifications of personnel (I) approvals and authorizing or verifying signatures (in) specific document references (n) data or test report forms (o) information to be collected for plant records (p) processing inspection and test data and their analysis, evaluation, and final acceptance 2.3 RESULTS                                        9.1                                                Similar Inspection and test results shall be documented    ... Inspection and test results that include       Same Intent in a suitable test report or data sheet.           inspection and test data, together with a report of data analysis and evaluation, shall be provided as specified in Section 10.
Also 10S-1 2 INSPECTION REQUIREMENTS
                                                    ... Inspection activities shall be documented and controlled ...
Each report shall identify the item to which it   Supplement 10 S-1:                                 Similar applies, the procedures or instructions followed   9 Records                                          Same Intent in performing the task, and the following:         Records shall as a minimum, identify (a) through (f) below:
: 1. Pertinent inspection and test data such as     (a)    item inspected                              Similar identification of location where testing was      (b)    date of inspection                          Same Intent performed or where test samples were taken.       (c)    inspector (d)    type of observation
: 2. Significant dates and times.                    (e)    results or acceptability (f)    reference to information on action taken in
: 3. Inspection acceptance and test completion             connection with nonconformances signatures.
: 4. Conditions encountered which were not anticipated1 including nonconformance.
Test reports and data sheet shall include an       Supplement 11 S-1:                                 Similar evaluation of the acceptability of inspection and  5 Test Records                                     Same Intent test results and provide for identifying the individual who performed the evaluation.          (d) type of observation (e) results and acceptability (f) action taken-in connection with any deviations noted (g) person evaluating test results 6 of 33                                              7/27/10

Enclosure 4, Table 5 ANSI N45.2.5-1978 vs NQA-1-1994, Subpart 2.5 Personnel performing tests and inspections                                              5 required bythis standard shall be qualified in       QUALIFICATION OF PERSONNEL accordance with ANSI N45.2.6.
Inspection, test, and nondestructive examination personnel and laboratory technicians shall be trained and qualified/certified in accordance with the applicable portions of Part I, Basic and Supplementary Requirements. Professional personnel shall meet the requirements defined by the implementing organization in its position descriotions.
4         .
* 2.5 MEASURING AND TEST EQUIPMENT                     3.2 Measuring and Test Equipment                    Similar Same Intent 2.5.1 Selection. Measuring and test equipment        Measuring and test equipment used to used to implement the requirements of this           implement the requirements of Subpart 2.5 standard shall be selected on the basis of           shall include (but not be limited to) accuracy sufficient to determine conformance to      thermometers, balances, scales, air specified requirements.                              entrainment meters, volumetric buckets, field measuring devices, pressure gages, and torque These measuring devices shall include but not        wrenches.
be limited to thermometers, balances, scales, air entrainment meters, humidity meters, volumetric Also Supplement 12 S-1, 2 Selection:
buckets, field moisture testing and soil density measuring devices, pressure gages, and torque Selection of measuring and test equipment wrenches.                                            shall be controlled to assure that such items are of proper type, range, accuracy, and tolerance to accomplish the function of determining rnnfnrrrnnro*n cnnrifI~r roanIiirpmonfc 2.5.2 Calibration and Control.                       Supplement 12 S-1, 3.1 Calibration:                 Similar The equipment shall be adjusted or calibrated or Measuring and test equipment shall be                   Same Intent both at prescribed intervals against certified       calibrated, adjusted, and maintained at standards having known valid relationships to        prescribed intervals or, prior to use, against national standards where such exist.                 certified equipment having known valid relationships to nationally recognized standards.
If no national standards exist, the basis for the   Supplement 12 S-1, 3.1 Calibration:                 OK adjustment or calibration shall be documented.       If no nationally recognized standards exist, the bases for calibration shall be documented.
Records shall be maintained and equipment            Supplement 12 S-1, 5 Records:                       OK suitably marked to indicate calibration status.      Records shall be maintained and equipment shall be suitably marked to indicate calibration status.
Measures shall be taken to assure proper             Supplement 12 S-1, 4 Handling and Storage:          Similar handling, storage and care of installation of        Measuring and test equipment shall be properiy Same Intent inspection and testing equipment after               handled and stored to maintain accuracy.
adjustment of calibration in order to maintain the required accuracy of such equipment.
Test equipment found to be out of calibration       Supplement 12 S-i, 3.2 Control:                      Similar shall be clearly identified as such.                Out-of-calibration devices shall be tagged or        Same Intent segregated and not used until they have been recalibrated.
7 of 33                                               7/27/10

Enclosure 4, Table 5 ANSI N45.2.5-1978 vs NQA-1-1 994, Subpart 2.5 vvnen aiscrepancies, maltunctions or                  WheUnJIJl E Ii When measuring ing  ad and test.-
test equipm I Ui. enI equipment   is is found inaccuracies in inspection and testing equipment are found during calibration, all items inspected     to be out of calibration, an evaluation shall be with that equipment since the last previous           made and documented of the validity of calibration shall be considered unacceptable          previous inspection or test results and Of the until an evaluation has been made by the              acceptability of items previously inspected or responsible authority and appropriate action          tested.
taken.
2.6 Laboratory Testing.                               3.3 Laboratory Testing                              OK Laboratory operations and testing associated with concrete and soils shall be controlled using     Laboratory operations and testing associated a Quality Assurance program.                          with concrete and soils shall be controlled using a Quality Assurance Program.
2.7 HOUSEKEEPING                                       N45.2.3 incorporated into NQA-1 as Subpart          Specific provisions of Subpart 2.3 2.3.                                                 which are applicable to project In areas, facilities and environments where                                                               activities will be defined in installation, inspection and testing activities are                                                       associated procedures.
performed in accordance with the requirements of this standard, the housekeeping requirements shall be in accordance with ANSI N45.2.3.
3 PRECONSTRUCTION VERIFICATION                       4 PRECONSTRUCTION VERIFICATION                       Similar 3.1 GENERAL                                                                                                Same intent 4.1 General Receipt inspections and storage are covered by another standard, ANSI N45.2.2.                       Receipt and interim storage inspections shall be used to verify that items are in a satisfactory Interim inspections shall be used to verify that     condition for installation.
items are in satisfactory condition for installation.
The verification shall include:                       The verification shall include the following:        OK (1) Visual examination of materials for proper        (a) visual inspection of material for proper         OK identification, physical damage, and                  identification, physical damage, and contamination,                                        contamination; (b) review of manufacturer's documentation, (2) Review of manufacturer's documentation,           test reports, or other evidence of quality test reports, or other evidence of quality            conformance for correctness and compliance conformance for correctness and compliance            with specifications if not reviewed at time of with specifications if not reviewed at time of        receipt.
receipt.
3.2 MATERIALS SUITABILITY                             4.2 Materials Suitability                            OK To assure that materials meet specified               To assure that materials meet specified requirements, preconstruction qualification tests     requirements, preconstruction qualification tests and inspections of the materials to be used and       and inspections of the materials to be used and in-process tests of the materials being used shall    in-process tests of materials being used shall be conducted.                                         be conducted.
8 of 33                                                       7/27/10

Enclosure 4, Table 5 ANSI N45.2.5-1978 vs NQA-1-1994, Subpart 2.5 J.4     '.UIII W.I   It&#xfd;LllJI I I V&#xfd;ILb. %dUdhII1I%,0LIU]I I LVL Wll Iol U.UOI II I&#xfd;LUli I LWOLO&#xfd;I 1011 UC P- lUI I IIU 01IU LI IV be performed and the results evaluated prior to                  results evaluated prior to the initial use of the the initial use of the materials to establish                    material to establish conformance of the conformance of the materials to the specified.                   materials to the specified requirements.
requirements.
The specifications shall identify the required             These words were added in NQA-1 qualification tests and the frequency for their repetition.
The tests required for concrete, concrete                 These words were added in NQA-1 constituents, materials for reinforcing systems, materials for prestressing systems and welding materials shall be in accordance with the ASME Boiler and Pressure Vessel Code, Section III, Division 2 (ACI Standard 359).
Lightweight concrete mix designs shall be                 These words were added in NQA-1 made in accordance with ACI 211.2.
Lightweight concrete aggregates shall be                  These words were added in NQA-1 qualified by tests for conformance with ASTM C 330.
When splitting tensile strengths are required for These words were added in NQA-1 lightweight concrete mix, the methods given in ASTM C 330 shall be used.
A list of normally required qualification tests or              Qualification and certification testing is                Test Standards are now included in certifications is contained in Table A.                         addressed in 4.2 as noted above as well as in             the body of subpart 2.5 at the (Table A lists various test standards)                          5.2                                                       appropriate location. This area is similar with the same intent.
Specific provisions of Subpart 2.5 which are applicable to project activities will be defined in associated procedures.
This list contains tests to qualify materials for                                                                         Since Test Standards are now normal application,                                                                                                       included in the body of subpart 2.5 at the appropriate location, this guidance is no longer applicable.
Specific provisions of Subpart 2.5 which are applicable to project activities will be defined in associated procedures.
Additional tests may be required to qualify                     Additional tests may be required to qualify               OK materials for special applications.                             materials for special application.
3.3 CONSTRUCTION PROCESSES                                                                                                OK 4.3 Construction Processes Inspections shall be performed to verify that the prerequisites for control of construction                       Inspections shall be performed to verify that the processes such as welding, bolting, structural                  prerequisites for control of construction reinforcement, splicing, and concrete measuring,                processes such as welding, structural bolting, mixing, transporting, placing, and curing have                  mechanical splicing of reinforcement, and been accomplished,                                              concrete measuring, mixing, transporting, placing, and curing have been accomplished.
9 of 33                                                          7/27/10

Enclosure 4, Table 5 ANSI N45.2.5-1978 vs NQA-1-1994, Subpart 2.5 I I COWuII~vuul 0             d
                                                                            &#xfd;CUIU lol n~I.,U
                                                                                     &#xfd;l   Vo V  I I I&#xfd;tLIIJ I VI S111111eIt the following:                                            Same Intent
: 1. Verification that the process has been            (a) the process has been qualified as required; qualified as required.                               (b) process controls are in effect;                       The words in item (e)" (including
: 2. Verification that process controls are in effect: (c) approved procedures, instruction manuals,             measuring and testing equipment)"
: 3. Verification that qualified procedures,           or both, if required for specific equipment, are          were added in NQA-1 instruction manuals, or both, if required for        available for use during construction; specific equipment, are available for use during (d) the process is suitable for the particular construction.                                        application;
: 4. Verification that the process is suitable for the (e) manpower, equipment (including measuring particular application.                              and testing equipment), and materials are
: 5. Verification that manpower, equipment, and        readily available and adequate to perform the materials are readily available and adequate to      work inaccordance with drawing and perform the work in accordance with drawing          specification requirements.
and specification requirements.
4 INSPECTION OF SOILS AND EARTHWORK                  5 INSPECTION OF SOILS AND EARTHWORK OK 4.1 GENERAL 5.1 General shall include Inspection of soils and earthwork preparations for earthwork as well as in-process     Inspection of soils and earthwork shall include inspections of placing and compacting                preparations for earthwork, as well as in-operations to assure conformance to specified        process inspections of placing and compacting requirements.                                        operation, to assure conformance to specified requirements.
4.2 MATERIALS                                        5.2 Materials                                             OK Inspections of stockpiles or borrow pits shall be    Inspections and qualification testing of performed to verify conformance to specified         stockpiles or borrow pits shall be performed to requirements,                                        verify conformance to specified requirements.
Qualification tests of soil fill materials shall be       These words were added in NQA-1 performed for:
(a) grain size analysis using ASTM D 422; (b) moisture-density relationship of soil using ASTM D 1557, and D 698; (c) maximum and minimum index density of soils using ASTM D 4253 and D 4254; (d) liquid limit, plastic limit, and plasticity index of soils using ASTM D 4318; and (e) unified soil classification using ASTM D 653, D 2487, and D 2488.
Other qualification tests of soil fill materials may These words were added in NQA-1 be used when specified.
4.3 PLACING AND COMPACTING EQUIPMENT 5.3 Placing and Compacting Equipment                                      OK Inspections shall be performed prior to              Inspections shall be performed prior to compacting operations to verify the adequacy of compacting operations to verify the adequacy compacting equipment.                                of compacting equipment.
These inspections shall include the following:       These inspections shall include the following:            OK 10 of 33                                                         7/27/10

Enclosure 4, Table 5 ANSI N45.2.5-1978 vs NQA-1-1994, Subpart 2.5
: 1. Inspections to verify that compacting equipment has the specified weight, if applicable. (a) inspections to verify that compacting equipment has specified weight, if applicable;
: 2. Inspections to verify that the specified type of (b) inspections to verify that the specified type equipment is available and in operating             of equipment is available and in operating condition.                                          condition; (c) inspections of vibratory compaction
: 3. Inspections of vibratory compaction equipment equipment to verify correct vibration frequency.
to verify correct vibration frequency.
4.4 PREPLACEMENT PREPARATIONS                       5.4 Preplacement Preparations                     OK Inspections of preparations for fill placement      Inspections of preparations for fill placement shall include the following:                        shall include the following:
I. Inspections to assure compliance with site       (a) inspections to assure compliance with site OK preparation requirements.                           preparation requirements;
: 2. Inspections to assure that the subgrade          (b) inspections to assure that the subgrade surface is level within specified limits,           surface is within specified limits;
: 3. Inspections to assure that the subgrade          (c) inspections to assure that the subgrade is surface is free of deleterious materials and voids  free of deleterious materials and voids and in and in compliance with specified requirements.      compliance with specified requirements;
: 4. Inspections to assure that the subgrade          (d) inspections to assure that the subgrade is surface is free of excess moisture, snow, frost or  free of excess moisture, snow, frost, or frozen frozen lumps.                                       lumps;
: 5. Inspections to verify that subgrade compaction   (e) inspections to verify that subgrade meets specified requirements.                       preparation meets specified requirements;
: 6. Documentation of the inspections required by     (f) documentation of the inspections required by items (1) through (5) shall be verified as being    (a) through (e) above shall be verified as being complete and indicating that all inspection results complete and indicating that all inspection are satisfactory.                                   results are satisfactory
: 4. SOIL COMPACTION                                  5.5 Soils Compaction                              OK Inspections of soil compaction during               Inspections of soil compaction during construction shall be performed to verify the       construction shall be performed to verify the following:                                          following:.
: 1. That fill material meets specified               (a) fill material meets specified requirements;   Similar requirements.                                       (b) segregation of the fill material does not     Same Intent
: 2. That segregation of the fill material does not   occur as it is dumped and spread; ,               Words in (d) "and where fill is occur as it is dumped and spread.                   (c) specified lift thicknesses are not exceeded;  placed against existing earth slopes
: 3. That specified lift thicknesses are not          (d) when specified, a knitting technique is used  or adjacent to previously exceeded.                                           when joining lifts and where fill is placed       compacted fills;", (f) "heavy
: 4. That when specified a "knitting technique" is    against existing earth slopes or adjacent to      compaction equipment does not used when joining lifts,                            previously compacted fills;                       impose overloads of subsurface
: 5. That the compacting equipment makes the          (e) the compacting equipment makes the            structures or foundations, unless specified number of passes over each lift and       specified number of passes over each lift and     otherwise stated in the that passes overlap.                                that passes over-lap;                             specifications, that are based on (f) heavy compaction equipment does not           design considerations;" and impose overloads of subsurface structures or      (g) "heavy compact equipment does foundations, unless otherwise stated in the       not overload buried structures specifications, that are based on design          before backfill is placed to grade."
considerations;                                   added in NQA-1 (g) heavy compact equipment does not
                                                -   overload buried structures before backfill is placed to grade.
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Enclosure 4, Table 5 ANSI N45.2.5-1978 vs NQA-1-1994, Subpart 2.5 In-process tests shall be performed during the        In-process tests shall be performed during the course of construction to maintain control of soil course of construction to maintain control of soil compaction.                                           compaction.
A list of the required in-process tests is            A list of the in-process tests for soils is shown in OK contained in Table B.                                 Table 5.6..
Table B                                               Table 5.6                                            The tests for soils listed in Table 5.6 is the same as those listed in N45.2.5 Table B with one exception, for Moisture Density relationships (compaction tests per 45.2.5) the frequency is increased in Subpart 2.5 through the increase in field density testing. This is more conservative and results in similar requirements with same intent.
Specific provisions of Subpart 2.5 which are applicable to project activities will be defined in associated procedures.
In-process tests shall be performed more              The need for each specific test shall be             Similar frequently if the test results are erratic or ifthe   established in the specifications. In-process        Same Intent trend of results. or an apparent change in            tests shall be performed more frequently if the      OK material characteristics indicates that the           test results are erratic, or if the trend of results frequency should be increased,                        or an apparent change in material characteristics indicates that the frequency should be increased.
5 INSPECTION OF FOUNDATION FILES AND                  6 INSPECTION OF FOUNDATION PILE AND                  OK CAISSONS CONSTRUCTION                                 CAISSON CONSTRUCTION 5.1 Pile 6.1 Piles 5.1.1 Pile Receiving Handling and Storage.
Inspections shall be performed to verify that         6.1.1 Pile Receiving, Handling, and Storage.
specified material has been received and to           Inspections shall be performed to verify that the verify the adequacy and proper maintenance of         specified material has been received and to pile storage and handling techniques.                 verify the adequacy and proper maintenance of pile storage and handling techniques.
These inspections shall include the following:        These inspections shall include the following:       OK
: 1. Receiving inspection                               (a) receiving inspection;
: 2. Inspectionof handling procedure to verify that     (b) inspection of handling procedure to verify proper lifting points and lifting techniques are      that proper lifting points and lifting techniques utilized;                                             are utilized;
: 3. Inspection of storage procedure to verify that     (c) inspection of storage procedure to verify that suitable storage areas have been designated,          suitable storage areas have been designated, blocking is adequate and properly located, and        that blocking is adequately and properly that piles can be rehandled without damage.           located, and that piles can be rehandled
: 4. Inspection of procedure for transporting piles     without damage; from storage area to driving location to verify that  (d) inspection of procedure for transporting proper support and lifting points are utilized, that  piles from storage area to driving location to proper lifting technique is used to' position the     verify that proper support and lifting points are pile for driving, and that pile to be driven is       utilized, that proper lifting technique is used to undamaged and as specified.                           position the pile for driving, and that pile to be driven is undamaged and as specified.
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Enclosure 4, Table 5 ANSI N45.2.5-1978 vs NQA-1 -1994, Subpart 2.5 Q.1.4 rIV uiiviiiy dIlU %&#xfd;dbLIII ~I-dIU               o.ns.t 1-c Construction.
ItIo Construction.
Pile driving and cast in place pile construction    Pile driving and cast-in-place pile construction shall be inspected to verify that piles are properly  shall be inspected to verify that the specified located from site base lines and elevation            piles are properly located from site baselines benches, located according to length and              and elevation benches (located according to capacity, and that pile driving surface has been      length and capacity), that the surface from properly prepared, excavated to the designated        which the piles will be driven has been properly driving elevation, and drained or dewatered and       prepared, excavated to the designated driving that pile driving equipment in compliance with        elevation, and drained or dewatered, as the specification is available.                       specified, and that pile driving equipment in compliance with the specification is available.
5.1.2.1 Wood, Steel and Precast Concrete Piles,      6.1.2.1 Installation of Wood, Steel, and Precast   Similar and Cast In Place Concrete Piles with                Concrete Piles, and Cast-in-Place Concrete         Same Intent Permanent Casing. The driving of wood, steel         Piles With Permanent Casing and Shell. The         The words "or casing" added to and precast concrete piles, and the shells for        installation of wood, steel, and precast concrete NQA-l cast in place concrete piles shall be inspected to    piles, and the shells or casing for cast-in-place OK verify the following:                                 concrete piles shall be inspected to verify the following:
: 1. The specified pile hammer is being used and        a) the specified pile hammer is being used and    Similar is operating at the required speed.                   is operating at the required speed;               Same Intent
: 2. The pile being driven is the specified type,      (b) the pile being installed is the specified type capacity and length.                                 and length;                                        Items H, I, and J were added in
: 3. The pile is driven plumb or to the specified      (c) the pile is installed within specified         NQA-1 batter, to the specified tip elevation and that the  tolerances of locations, plumb, and rotation or blow count at that elevation is as specified         to the specified batter, to the specified tip
: 4. The proper type of cushioning material is used    elevation, and that the blow counts are as between the hammer and the pile.                     specified;
: 5. The follower used on piles with the final top     (d) the proper type of cushioning materials is elevation below the existing grade is compatible     used between the hammer and the pile and to with the driving characteristics of the pile.        assure that piles are not being damaged during
: 6. The piles adjacent to the pile being driven are   driving; checked for heave and redriven if required.          e) the follower used on piles with the final top
: 7. The sequence of pile driving is as specified in   elevation below the existing grade is compatible order to avoid displacement of piles in place.       with the driving characteristics of the pile; (f) the piles that are adjacent to the pile being installed are checked for heave and reinstalled if required; (g) the sequence of pile installation is as specified in order to avoid displacement of piles in place; (h) adjacent structures, fresh concrete, etc., are not damaged due to driving vibrations; (i) drilling and jeting are only done when specified and are performed in accordance with the specification;
() complete records are made of.pile driving resistance 5.1.2.2 Concrete Placement in Cast in Place          6.1.2.2 Concrete Placement in Cast-in-Place        OK Piles with Permanent Casing.                         Piles With Permanent Casing. Prior to Prior to concreting cast in place concrete piles,    concreting cast-in-place concrete piles, inspection shall be performed to verify the          inspection shall be performed to verify the following:                                           following:
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Enclosure 4, Table 5 ANSI N45.2.5-1978 vs NQA-1-1994, Subpart 2.5
                                                     ) IU -  - I.,O l EEO- I - LJUM1- -U    LUJIOJ PEEL 1
b) the casing is straight;                         Same Intent (2) The casing is straight.                         c) the casing is dewatered, if necessary, and inside of casing has been cleaned to the tip       Items E and F were added in (3) The casing is dewatered if necessary.           elevation;                                         NQA-1 d) the reinforcement is installed and positioned (4) The reinforcement is installed and positioned as specified and is secured against as specified and is secured against displacement displacement during concreting; during concreting.                                  e) the volume of concrete used is consistent with the estimated required volume; f) grouting pressure or compaction energy used to form the pile is as specified.
The placement of concrete in the pile casing        The placement of concrete in the pile casing       OK shall be inspected to verify that it conforms with  shall be inspected to verify that it conforms with subsection 6.5, Concrete Placement.                 paras. 7.5 and 7.7, as applicable.
5.1.2.3 Cast in Place Piles Without Permanent       6.1.2.3 Concrete Placement for Cast-in-Place       OK Casing. The construction of cast in place piles     Piles Without Permanent Casing. The without permanent casing shall he inspected to      construction of cast-in-place piles without verify the following:                               permanent casing shall be inspected to verify the following:
(1) The size and tip elevation of the pile is as    a) the volume of concrete used is consistent       Similar specified.                                          with the estimated required volume;                Same Intent (2) The completed pile is plumb or to the           b) the method for withdrawing the casing will specified batter.                                   not cause separation of the pile concrete;         Items (1) and (2) were omitted in (3) The quantity of concrete placed in the pile is  c) the method for withdrawing the casing during    NQA-1.
consistent with the size and length specified.      the placing of the concrete maintains a level of (4) The method for withdrawing the casing will      concrete sufficiently above the bottom of the      Item (e) was added in NQA-1 not cause separation of the pile concrete.          casing to avoid soil intruding or necking down (5) The method for withdrawing the casing during    the concrete pile; the placing of concrete maintains a level of        d) the placement of concrete in the pile casing concrete sufficiently above the bottom of the       conforms with paras. 7.5 and 7.7; casing to avoid soil intruding or necking down      e) grouting pressure or compaction energy the concrete pile.                                  used to form the pile is specified.
(6) The placement of concrete in the pile conforms with paragraph 6.5, Concrete Placement.
5.1.2.4 Pile Splicing. The construction of          6.1.2.4 Pile Splicing. The construction of         OK composite piles and the splicing of piles with the  composite piles and the splicing of piles with same section above and below the splice shall       the specified section above and below the be inspected to verify the following:               splice shall be inspected to verify the following:
(1) The top section is properly aligned with the    a) the top section is properly aligned with the    OK bottom section.                                     bottom section; (2) The splice interface is clean and is properly  b) the splice interface is clean and is properly prepared and spaced for application of the          prepared and spaced for application of the splicing material.                                  splicing material; (3) The pile is at the specified temperature limits c) the pile is at the specified temperature limits for splicing and that the splice is installed in    for splicing and that the splice is installed in accordance with applicable standards and            accordance with applicable standards and specifications.                                     specifications.
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Enclosure 4, Table 5 ANSI N45.2.5-1978 vs NQA-1-1994, Subpart 2.5 U.I .L.U IIIbPM..LIUII U I UIIUIU Lt; ".UIIZLlUULIUII.   . I.1.0 IIPIbMJAULIUIIU I 1, VUI LV .UI I&#xfd;LI UULIUII.
Concrete construction of cast in place piles and      Concrete construction of cast-in-place piles and protective concrete cast around piles shall be         protective concrete cast around piles shall be inspected in accordance with Section 6,                inspected in accordance with Section 7.
Inspection of Concrete Construction.
5.1.2.6 Test Piles. Test piles shall, be inspected    6.1.2.6 Test Piles. Test piles shall be inspected OK to verify that:                                        to verify that:
(1) Load tests are made on piles driven or cast.      (a) load tests are made on piles driven or cast- OK in place in the same manner as production piles,       in-place in the same manner as production (2) The driving or construction is in accordance       piles; with the applicable paragraphs above.                  (b) the driving or construction is in accordance (3) The performance of load .testing is in            with the applicable paragraphs above; accordance with ASTM D1143, Load Settlement           (c) the performance of load testing is in Relationship for Individual Vertical Piles Under      accordance with ASTM D 1143, Method of Static Axial Load.                                    Testing Piles Under Static Axial Compressive Load.
5.2 CAISSONS                                          6.2 Caissons                                        OK Caisson excavation shall be inspected to verify        6.2.1 Caisson excavation shall be inspected to that:.                                                 verify that:
(1) Caissons are correctly located,                    a) caissons are correctly located;                  OK (2) The caisson shaft is straight and plumb or to       b) the caisson shaft is straight and plumb, or to the specified batter, and suitable means are           the specified batter, and suitable means are employed to maintain the shaft diameter.               employed to maintain the shaft diameter; (3) The bottom of the caisson is at the specified      c) the bottom of the caisson is at the specified elevation and is level or is excavated in steps as     elevation and is level, or is excavated in steps necessary to provide level and uniform bearing         as necessary to provide level and uniform over the full base area.                               bearing over the full base area; (4) There are no unacceptable voids, cavems or         d) there are no unacceptable voids, caverns, or strata of compressable material below the              strata of compressible material below the bottom of caisson.                                     bottom of the caisson; (5) Underreamed caissons have the specified            e) underreamed caissons have the specified bottom diameter and side slope,                        bottom diameter and side slope; (6) The rock socket of drilled in caissons is the      f) the rock socket of drilled-in caissons is the specified diameter and depth.                          specified diameter and depth; (7) The shear rings of friction caissons are the       g) the shear rings of friction caissons are the specified size.and spacing,                            specified size and spacing.
5.2.2 Caisson concrete construction shall be           6.2.2 Caisson concrete construction shall be        OK inspected in accordance with subsection 6.4,           inspected in accordance with Section 7.
Preplacement Preparations, subsection 6.5, Concrete Placement, and subsection 6.7, Curing, of Section 6.
In addition caisson concreting shall be inspected In addition, caisson concrete shall be inspected OK to verify that:                                        that:
15 of 33                                      7/27/10

Enclosure 4, Table 5 ANSI N45.2.5-1978 vs NQA-1-1994, Subpart 2.5 I) m-l IuOe spoii nas ueeri reonuveu Tromn trie   a) all loose soil has been removed from the bot- fIIIIIdl bottom of the caisson excavation prior to          tom of the caisson excavation prior to           Same Intent concreting.                                        concreting:
(2) The caisson excavation has been dewatered      b) the caisson excavation has been dewatered Item (f) was added in NQA-1 or that approved means of placing concrete         or that approved means of placing concrete underwater are employed.                           underwater are employed; (3) Sufficient head of concrete is maintained      c) sufficient head of concrete is maintained above the bottom of the casing while it is being   above the bottom of the casing while it is being withdrawn to avoid soil intrusion or necking down  withdrawn to avoid soil intrusion or necking of the concrete shaft.                             down of the concrete shaft; (4) Method of withdrawal of the casing prevents    d) method of withdrawal of the casing prevents voids in or separation of the concrete shaft.      voids in or separation of the concrete shaft; (5) Approved methods of proportioning and          e) approved methods of proportioning and placing concrete are employed in slurry            placing concrete are employed in slurry stabilized caisson to prevent segregation or       stabilized caisson to prevent segregation or mixing with slurry and to assure specified         mixing with slurry and to assure specified concrete strength.                                 concrete strength; f) the volume of concrete used is consistent with the estimated required volume.
5.3 REQUIRED QUALIFICATION TESTS                   6.3 Required Qualification Tests                 The tests listed are the same as those listed in Table A of N45.2.5 The required qualification tests are covered in    The required qualification tests are as follows: with additional tests listed for wood Table A.                                           (a) Wood piles shall conform to specifications   piles regarding the wood such as ASTM D 25, and AWPA C3, and ASTM preservative treatment. Therefore D 1760 for wood preservation treatment,          subpart 2.5 is more conservative (b) Steel piles shall conform to specifications  than N45.2.5. Specific provisions of such as ASTM A 252 for pipe, and ASTM A 6        Subpart 2.5 which are applicable to and A 36 for structural shapes.                  project activities will be defined in (c) Concrete piles (precast, cast in place and   associated procedures.
pre-stressed) shall conform to approved specifications used in the manufacturer's certification, or as specified.
6 INSPECTION OF CONCRETE                           7 INSPECTION OF CONCRETE                         OK CONSTRUCTION                                       CONSTRUCTION 6 6.1 GENERAL 7.1 General inspection of concrete construction shall include inspections of preparations for concreting, as     Inspection of concrete construction shall well as in-process inspections of concrete         include inspection of preparations for measuring, mixing, transporting, placement,        concreting, as well as in-process inspections of curing, and protection to assure conformance to    concrete measuring, mixing, transporting, specified requirements.                            placement, curing, and protection to assure conformance to specified requirements.
The inspection of pre- or post-tensioning          The inspection of pretensioning or post-         OK systems shall be.included, if applicable,          tensioning systems shall be included, if applicable.
The inspection shall follow the Recommended        The inspection shall follow ACI 311.4R, Guide Similar Practice for Concrete Inspection, ACI 311 and     for Concrete Inspection; and PCI MNL-1 16 and Same Intent the PCI Manual for Quality Control.                MNL-1 17.
16 of 33                                                  7/27/10

Enclosure 4, Table 5 ANSI N45.2.5-1978 vs NQA-1 -1994, Subpart 2.5 Inspections shall be performed to verify the         Inspections shall be performed to verify the adequacy and proper maintenance of material          adequacy and proper maintenance of material storage conditions and handling techniques.          storage conditions and handling techniques.
These inspections shall Include the following:        These inspections shall include the following:   OK
: 1. Inspection of cement storage facilities to verify a) inspection of cement storage facilities to     OK weather tightness, cement temperature and the        verify weather tightness, cement temperature absence of lumps, and review of records to vedfy     and the absence of lumps, and review of type and age of cement.                              records to vedfy type and age of cement; b) inspection of aggregate stockpiles to verify
: 2. Inspection of aggregate stockpiles to verify:     that:
handling techniques are not resulting in             I) handling techniques are not resulting in segregation; storage and handling adequately         segregation; prevent contamination with deleterious               2) storage and handling adequately prevent substances; proper temperature                       contamination with deleterious substances; and uniform moisture control; and use of frozen 3) specified temperature and uniform moisture materials is prevented,                              control are maintained; and
: 3. Inspection of admixture storage and handling 4) use of frozen materials is prevented; facilities to verify that deterioration and          c) inspection of admixture storage and handling contamination are prevented,                         facilities to verify that deterioration and
: 4. Inspection of water sources and cooling and       contamination are prevented; heating facilities to verify the specified water     d) inspection of water sources and cooling and quality and assure that the specifications for       heating facilities to verify the specified water concrete temperature are met.                        quality and to assure that the specifications for
: 5. Inspection of reinforcing material,               concrete temperatures are met; embedments, and prestressing system materials e) inspection of reinforcing material, (wire, strand, tendons, tendon tubes and             embedments, and prestressing systems temporary or permanent anchor hardware) to           materials (wire, strand, tendons, tendon tubes, verify protection against corrosion, contamination and temporary or permanent anchor hardware) and physical damage.                                 to verify protection against excessive corrosion, contamination, and physical damage.
6.3 MEASURING, MIXING, AND                           7.3 Measuring, Mixing, and Transporting           OK TRANSPORTING EQUIPMENT                               Equipment Inspections shall be performed prior to and          Inspections shall be performed prior to and during the production of concrete to verify the      during the production of concrete to verify the adequacy and proper operation of measuring,          adequacy and proper operation of measuring, mixing, and transporting equipment in                mixing, and transporting equipment in accordance with ACI 304, ASTM C-94, and              accordance with ACI 304, ASTM C 94, and National Ready Mix Concrete Association -            National Ready Mix Concrete Association Concrete Plant Standard and Truck Mixer and          Concrete Plant Standard and Truck Mixer and Agitator Standard.                                   Agitator Standard.
The inspections shall include time following:        These inspections shall include the following:    OK 17 of 33                                     7/2710

Enclosure 4, Table 5 ANSI N45.2.5-1978 vs NQA-1-1994, Subpart 2.5 k I IlI0P~tAI./ ;I .UI II i:* *Uilly 151 ICIIIILll*I IUZ I    1 .0. I IIIlOtJV".VIl I UI I 1C-00U IVIJ , II.I V IUI U IV specified accuracy of measuring, weighing and              specified accuracy of measuring, weighing, and weight recording devices to control time                   weight recording devices to control the following:                                                 following:
(a) Proportions of cement, water and                    (a) proportions of cement, water, and aggregates                                                 aggregates (b) Quantities of admixtures                            (b) quantities of admixtures (c) Aggregate moisture compensation                     (c) aggregate moisture compensation (d) Mixing time                                         (d) mixing time (e) Temperature control: Heating or cooling of          (e) temperature control, heating or cooling of concrete.                                                  concrete (f) Method of adding water when batching                   (f) method of adding water when batching light-lightweight aggregates in accordance with ACI              weight aggregates in accordance with ACl 301.
301.
(2) Inspection of central mix plant and truck              7.3.2 Inspection of central mix plant and truck OK mixers for wear of drum blades, availability of            mixers for wear of drum blades, availability of revolution counter and water measuring device,             revolution counter and water measuring proper speed of rotation and ability to mix                devices, proper speed of rotation, and ability to concrete completely in the specified time.                 mix concrete completely in the specified time.
6.4 PREPLACMENT PREPARATIONS                               7.4 Preplacement Preparations                              OK Inspection of preparations for concrete                   Inspection of preparations for concrete placement shall include the following:                     placement shall include the following:
: 1. Inspection-of compacted structural fill during         a) inspection of the compacted structural fill or          Similar placement to verify correct condition.                     undisturbed soil to verify correct condition;              Same Intent b) inspection and field testing, in accordance
: 2. Inspection of rock surfaces which will be in            with the specifications of all structural fill, contact with structural concrete to verify surface undisturbed soil, and rock surfaces which will cleanness, removal of loose rock and free water, be in contact with structural concrete to verify correct contour and specified subgrade                    surface cleanness, removal of loose rock and condition,                                                free water, correct contour, and specified subgrade condition;
: 3. Inspection of previously placed concrete to            c) inspection of previously placed concrete to verify proper preparation for the next lift.              verify proper preparation for the next lift; d) inspection of formwork to verify:
: 4. Inspection of formwork to verify: correct              I) correct location and configuration, location and configuration of formwork;                   dimensional accuracy; and proper line and installation and integrity of water stops and             grade of form-work; membrane waterproofing; condition of form                 2) installation and integrity of water stops and material to produce the specified concrete finish; membrane waterproofing; installation of ties, anchors, bracing, shoring and 3) condition of form material to produce the supports; correct location and dimensions of              specified concrete finish, installation of ties, blackouts; proper form coating and cleanliness            anchors, bracing, shoring, and supports to inspection of forms forwater tightness and                prevent movement during concrete placement; placement of grout and vent pipes when                    4) correct location and dimensions of block-preplaced aggregate concrete is used.                     outs, proper form coating, and cleanness inspection of forms fore tightness and
: 5. Inspection of reinforcing steel, prestressing           placement of grout and vent pipes when components (if applicable) and other embedded preplaced aggregate concrete is used; items to verify: correct size, number, location,          e) inspection of reinforcing steel, prestressing position                                                  components (if applicable), and other embedded items to verity; (1) correct size, number, location, position, cleanness and leak tightness, if applicable; (2) proper stringing and absence of physical damage topretensioning strands or tendons; 18 of 33                                                     7/27/10

Enclosure 4', Table 5 ANSI N45.2.5-1978 vs NQA-1-1994, Subpart 2.5 V. 111bP, kA:ULIUI U1 IIItRIIC11IIk,0I IV:lllUI6,Ill Udl    I) IIIiI*{.AtIUI UI     I  Il   lL.0l I   1 IIUI. I Ul splicing operations to verify conformance to the          splicing operations to verify conformance to the Same Intent requirements of Section 6.12.                             requirements of para. 7.12;
: 7. Inspection by use of a mandrel or similar              g) inspection by use of a mandrel or similar           Item "k"added in NQA-1 device to ensure that the tendons conduits are            device to ensure that the tendon conduits are open and remain open during the concrete                  open and remain open during the concrete placing operation.                                        placing operation;
: 8. Inspection of pretensioning load cells and/or          h) inspection of pretensioning load cells and pressure sages for accuracy and calibration if            pressure gages for accuracy and calibration, if applicable.                                               applicable;
: 9. Inspection of pretensioning system strand              i) inspection of pretensioning system strand vises for cleanliness, proper lubrication, wear,          vises for cleanness, proper lubrication, wear, distortion and cracking if applicable.                    distortion, and cracking, if applicable; j) inspection of the pretehsioning operation, if
: 10. Inspection of the pretensioning operation if          applicable, to verify:
applicable, to verify: initial tensioning of each         (1) initial tensioning of each strand to eliminate strand to eliminate slack and to provide a                slack and to provide a uniform initial stress uniform initial stress condition in all strands prior condition in all strands prior to final stressing; to final stressing; proper measurement and                (2) proper measurement and correlation of jack correlation of Jack pressure (or load cell reading) pressure (or load cell reading) and strand or and strand or tendon elongation; proper                   tendon elongation; correction for elongation losses due to strand            (3) proper correction for elongation losses due slippage in the rises and movement of                     to strand slippage in the rises and movement of anchorage abutments.                                      anchorage abutments; (k) inspection of groundwater control, as specified; III inspectIUII     I IIIb    l    nIILO, Documentation of the inspections required by              Documentation of the inspections required by           OK steps 1 through 10 above shall be verified as             steps (a) through (I) above shall be verified as being complete and indicating that all inspection         being complete and indicating that all results are satisfactory.                                 inspection results are satisfactory.
6.5 CONCRETE PLACEMENT                                    7.5 Concrete Placement                                 OK Inspection of concrete placement shall be                 Inspection of concrete placement shall be performed to verify the following:                        performed to verify the following:
: 1. Specified tests of concrete have been                  a) specified tests of concrete have been               OK performed.                                                performed;
: 2. Adherence to specified requirements for class          b) adherence to specified requirements for of concrete, age, rate of placement, lift height,         class of concrete, age, rate of placement, lift placing                                                   height, placing sequence, concrete sequence and hot or cold weather concreting               temperature, and hot or cold weather practice. (ACI 305 or 306 respectively.)                  concreting practice (ACI 305 or ACI 306,
: 3. Proper use of adequate conveying and placing           respectively);
equipment.                                                c) proper use of adequate conveying and
: 4. That harmful materials are not used in                 placing equipment; covering or placing equipment.                            (d) harmful materials are not used in covering
: 5. Adequate concrete consolidation equipment              or placing equipment; and technique of operation.(ACI 309)                      e) adequate concrete consolidation equipment
: 6. Embedded items are not disturbed nor forms             and technique of operation (ACI 309);
displaced.                                                f) embedded items are not disturbed nor forms displaced.
6.6 FINISHING AND REPAIRS                                 7.6 Finishing and Repairs                              OK Inspections shall be performed to verify that             Inspections shall be performed to verify that specified finishes are obtained; i.e., wood float,        specified finishes are-obtained, i.e., wood float, steel trowel, as cast or other type.                      steel trowel, as cast, or other type.
19 of 33                                                  7/27/10

Enclosure 4, Table 5 ANSI N45.2.5-1978 vs NQA-1-1994, Subpart 2.5 MILWll uriris IldVtIUmIl ruifiIvU U, Iliz.iAl UIlib   mitt[IuI iI lb ICIVU UVIV I I V1II1UVVU, Iiibz~utLlUii1&#xfd; shall be performed to verify that the formed          shall be performed to verify that the formed surfaces have been repaired and finished in           surfaces have been repaired and finished in accordance with specified requirements.               accordance with specified requirements.
Any indications of voids or contamination, such       Any indication of voids or contamination, such           OK as at a construction joint, shall be explored by      as at a construction joint, shall be explored by physical removal of concrete if necessary to          physical removal of concrete, if necessary, to determine the extent of such voids or                 determine the extent of such voids or contamination.                                        contamination.
Appropriate repairs shall be made.                    Appropriate repairs shall be made.                       OK 6.7 Curing                                            7.7 Curing                                               OK Qualification tests shall be performed on liquid         These words were added in NQA-1 membrane forming curing compounds and sheet materials for concrete curing for compliance with ASTM C 309 in accordance with test methods given therein or ASTM C 171, as applicable.
Inspections shall be performed throughout the         Inspections shall be performed throughout the            OK specified curing period to verify the following:      specified curing period to verify the following:
I. Correct curing method is used, i.e., use of        a) correct curing method is used, i.e., use of           OK ponding, fog spray, wet buriap, curing                ponding, fog spray, wet burlap, curing compound, or other method in accordance with compound, or other methods in accordance specified requirements.                               with specified requirements;
: 2. Concrete is kept continuously, i.e., not           b) concrete is kept continuously, i.e., not periodically, wet during the entire curing period, if periodically, wet during the entire curing period, one of the wet curing methods is used.                if one of the wet curing methods is used;
: 3. Membrane curing compounds are specifically c) membrane curing compounds are specifically approved for use prior to application,                approved for use prior to application;
: 4. Curing temperature is maintained within            d) curing temperature is maintained within specified limits during the entire curing period,     specified limits during the entire curing period;
: 5. Shoring and forms are left in place and .          e) shoring and forms are left in place, and precast concrete members are left in the forms        precast concrete members are left in the forms until concrete has reached the specified strength until concrete has reached specified strength necessary to preclude the possibility of damage necessary to preclude the possibility of damage from construction loads,                              from construction loads;
: 6. Concrete test cylinders are subjected to the       f) concrete test cylinders are subjected to the same curing process as the concrete when field same curing process as the concrete when field cured cylinders are required to evaluate curing       cured cylinders are required to evaluate curing methods.                                              methods.
6.8 Stress Transfer of Pretensioned Members           7.8 Stress Transfer of Pretensioned Members              OK If applicable, inspections shall be performed to      If applicable, inspections shall be performed to verify that:                                          verify the following:
20 of 33                                                       7/27/10

Enclosure 4, Table 5 ANSI N45.2.5-1978 vs NQA-1-1994, Subpart 2.5 I. I I1 I",% IU.1 t bLC LI*ilyLII, d5 IIUIILtOU uy LtZCL  a)1 U CAJ1W ,     OI
                                                                          -L      I 0 VUbt OQ   IU  L  UY   -ytO cylinders, is in accordance with the specified          cylinders, is in accordance with the specified    Same Intent transfer strength prior to the transfer of              transfer strength prior to the transfer of prestressing load from the bed to the member.           prestressing load to the member;
: 2. Stress transfer is performed within the              b) stress transfer is performed within the specified temperature limits for heat-cured             specified temperature limits for heat cured members.                                                members;
: 3. Forms, ties, inserts, hold downs or other            c) forms, ties, inserts, hold downs, or other devices that would restrict longitudinal                devices that would restrict longitudinal movement of the member(s) along the bed are             movement of the member(s) are removed, or removed, or loosened in a specific sequence             loosened in a specific sequence to or in prior to or in conjunction with stress transfer.        conjunction with stress transfer;
: 4. The stress transfer is performed in a                d) the stress transfer is performed following an sequence which avoids overstressing or cracking approved stressing procedure.
of the member due to unacceptable non-symmetrical loading.
6.9 Post Tensioning                                     7.9 Post-Tensioning                               OK Inspections shall be performed prior to and             Inspections shall be performed prior to and during post-tensioning, if applicable, to verify the during post-tensioning, ifapplicable, to verify following:                                              the following:
I. The concrete strength, as indicated by test          a) the concrete strength, as indicated by test    OK cylinders is in accordance with the specified           cylinders, is in accordance with the specified strength at time of prestress or at the time of         strength at the time of prestress or at the time post-tensioning.                                        of post-tensioning;
: 2. The tendons and tendon ducts of ungrouted            b) the tendons and tendon ducts of ungrouted tendons have been treated with the specified            ten-dons have been treated with the specified lubricant and/or corrosion inhibiting compound          lubricant, or corrosion-inhibiting compound, prior to tendon installation.                          prior to tendon installation;
: 3. The tendons are tensioned (from both ends if         c) the tendons are tensioned (from both ends if so specified) in accordance with the specified          so specified) in accordance with the specified pre-stressing sequence.                                 prestressing sequence;
: 4. There is proper measurement and correlation          d) there is proper measurement and correlation of jack pressure (or load cell reading) and tendon      of jack pressure (or load cell reading) and elongation as well as proper correction for             tendon elongation as well as proper correction elongation and/or prestress seating losses,             for elongation, or prestress seating losses;
: 5. The anchorage details (buttonheads, friction        e) the anchorage details (buttonheads, friction grip, wedge grip, threaded, etc.) are in                grip, wedge grip, threaded, etc.) are in accordance with the specified requirements both        accordance with the specified requirements prior to and after tensioning.                         both prior to and after tensioning;
: 6. The grouted tendon ducts are free from              f) the grouted tendon ducts are free from excessive moisture prior to tendon installation         excessive moisture prior to grouting; the grout and kept dry prior to grouting; the grout material      material and the grouting operation are in and the grouting operation are                          accordance with specified requirements.
6.10 Shipping and Handling of Precast Concrete 7.10 Shipping and Handling of Precast                     OK Members                                                Concrete Members Shipping and handling of precast concrete              N45.2.2 incorporated into NQA-1 as Subpart        Specific provisions of Subpart 2.2 members shall be in accordance with the                2.2.                                              which are applicable to project requirements of ANSI                                                                                     activities will be defined in.
N45.2.2.                                                                                                 associated procedures.
21 of 33                                                    7/27/10

Enclosure 4, Table 5 ANSI N45.2.5-1978 vs NQA-1-1994, Subpart 2.5 apto    d to andandy,     erctonl during 1rpui  U to verify erection     rt verify thfllowpng:
the following:
IIIbIJ.ULIUIIb blIdll U*; PJiIUIIII U JIIUI LU dIIU during erection to verify the following:
: 1. Members are handled only by means of            a) members are handled only by means of             OK approved devices at designated locations or        approved devices at designated locations or pick-up points.                                    pick-up points;
: 2. Suitable foundations are provided for storage   b) suitable foundations are provided for storage of precast members.                                of precast members;
: 3. Stacked members are separated and               c) stacked members are separated and supported by battens placed across the full width supported by battens placed across the full of the designated bearing points.                  width of the designated bearing points;
: 4. Shipping and handling has not caused            d) cracking, spalling, and other defects caused unacceptable cracking, spalling, or chipping of    by shipping and handling of the precast the precast members, using acceptance criteria     members do not exceed the specified limits.
at least equivalent to those of ACI Committee Report 533, "Design of Concrete Wall Panels, Chapter 17, Cracking Acceptability."
6.11 In-Process Tests on Concrete and              7.11 In-Process Tests on Concrete and               OK Reinforcing and Prestressing Steels                Reinforcing and Prestressing Steel In-process tests shall be performed during the     In-process tests shall be performed during the course of construction to maintain control of      course of construction to maintain control of structural, prestressed and precast concrete.      structural, prestressed, and precast concrete.
A list of the required in-process tests is         The tests which are required and the frequency Similar contained in Table B.                              shall be in accordance with the ASME Boiler         Same Intent and Pressure Vessel Code, Section Il1,Division 2 (ACI Standard 359) except as follows.
The ASME Boiler and Pressure Vessel Code, Section III, Division 2 (ACI Standard 359) test frequencies for the following tests shall be considered minimum, unless current documentary test data are available to establish adequate confidence in conformance of materials to specified requirements.
a) for concrete materials - unit weightlyield b) for aggregate materials
: 1) unit weight of aggregate
: 2) fixed water and iron content of aggregate only for radiation-shielding concrete
: 3) organic impurities
: 4) fiat and elongated particles
: 5) lightweight particles
: 6) soft fragments
: 7) specific gravity and absorption
: 8) Los Angeles abrasion
: 9) potential reactivity
: 10) soundness 22 of 33                                                7/27/10

Enclosure 4, Table 5 ANSI N45.2.5-1978 vs NQA-1-1994, Subpart 2.5 lIEI  Lw~t [I rqUwlkEIvAW IVUIEu IIwloll Uw &#xfd;IIIUvWU     IV I VUUUI.VIII I V 1 1 4UC ILy i.1- 11IV I I lIUQL u minimums.                                              documented, and referenced documentation must be representative of the material currently being certified with the results of prior testing.
In-process tests shall be performed more               In-process tests shall be performed more              OK frequently if test results are erratic or ifthe trend  frequently if test results are erratic, or ifthe of results or an apparent change in material           trend of results or an apparent change in characteristics indicates that the frequency           material characteristics indicates that the should be increased,                                   frequency should be increased.
Samples for in-process tests of concrete shall be      Samples for in-process tests of concrete shall        OK taken following the procedures of ASTM C- 172          be taken following the procedures of ASTM C except as defined herein regarding location of         172, except as defined herein regarding sampling,                                              location of sampling.
No water or other ingredients may be added to          No water or other ingredients may be added to OK any concrete batch after making the in-process         any concrete batch after making the in-process tests,                                                 tests.
Samples shall not be taken from concrete               Samples shall not be taken from concrete              OK deposited in the form.                                 deposited in the form.
Except as noted below for pumped concrete and          Except as noted below, the sampling point for         OK when correlation testing is performed, the             taking in-process test samples of plastic sampling point for taking in-process test samples      concrete shall be performed at the placement of plastic concrete shall be performed at the          point or other points coincident thereto.
placement point, or other points coincident thereto.
In the case where concrete is pumped during its        When concrete is pumped during its movement OK movement from the delivery point to the                from the delivery point to the placement point, placement point, in-process strength samples           in-process strength samples shall be taken at shall be taken at the placement point, unless          the placement point, unless correlation tests of correlation tests of air content, slump, and           air content, slump, and temperature are temperature are performed.                             performed.
Where correlation testing is ineffect, in-process      When correlation testing is in effect, in-process OK strength samples may be taken at the delivery          strength samples may be taken at the delivery point.                                                 point.
In-process strength testing conducted at the          In-process strength testing conducted at the          OK mixing point is permitted, but unless the mixing       mixing point is permitted, but unless the mixing point and the delivery point are considered            point and the delivery point are considered coincident, correlation strength tests between         coincident, correlation strength tests between samples taken at the mixing point and the              samples taken at the mixing point and the delivery point are required.                           delivery point are required.
In this case the frequency of the correlation of       In this case, the frequency of the correlation of OK strength samples taken at the delivery point shall     strength samples taken at the delivery point be each 500 cubic yards of concrete or twice           shall be taken each 500 cu yd (382 in3) of each week, which-ever provides the greater             concrete or twice each week, whichever number of samples.                                     provides the greater number of samples.
23 of 33                                         7/27/10

Enclosure 4, Table 5 ANSI N45.2.5-1978 vs NQA-1-1994, Subpart 2.5 II b    pll lJIIly IV I UI C2L,kUl IIJIIP IICU aL LIIC pId lcI lII11 It  I  ipI I VJ IC I IUL . I I.IiIIJI EcU OLLIIC point and ifthe delivery point and the placement                placement point and if the delivery point and point are not considered coincident, correlation                the placement point are not considered tests will be established and performed for air                 coincident, correlation tests will be established content, slump, and temperature.                                and performed for air content, slump, and temperature.
The frequence of correlation tests shall be at an               The frequency of the correlation tests shall be   Similar interval four times greater than that noted in                  at an interval of four times greater than the     Same Intent Table B for in-process tests.                                    required test frequency.
When any of the specified limits and tolerances                  When any of the specified limits and tolerances OK on loss of air content, slump, or temperature are               on loss of air content, slump, or temperature exceeded at the placement point, correlation                    are exceeded at the placement point, strength tests between the delivery point and the                correlation strength tests between the delivery placement point shall be accomplished for each                   point and the placement point shall be 100 cubic yards of concrete placed as long as                   accomplished for each 100 cu yd (76.5 in3) of limits and tolerances are exceeded. If no limits                 concrete places as long as limits and and tolerances are specified, the ASTM C-94                     tolerances are exceeded. If no limits and shall apply.                                                    tolerances are specified, ASTM C 94 shall apply.
6.12 Mechanical (Cadweld) Splice Testing                         7.12 Mechanical (Sleeve With Ferrous Filler      OK Metal) Splice Testing These words were added in NQA-1 The mechanical (sleeve with ferrous filler metal) splice testing shall be done in accordance with the requirements of the ASME Boiler and Pressure Vessel Code, Section III, Division 2 (ACI Standard 359).
6.12.1 Qualification of Operators. Prior to the                 The mechanical (sleeve with ferrous filler metal) Similar production splicing of reinforcing bars, each                    splice testing shall be done in accordance with Same Intent member of the splicing crew (or each crew if the the requirements of the ASME Boiler and members work as a crew) shall prepare two                        Pressure Vessel Code, Section III, Division 2 qualification splices on the largest bar size for               (ACI Standard 359).
each of the splice positions (e.g., horizontal, vertical, diagonal) to be used.
The qualification splices shall be made using the The mechanical (sleeve with ferrous filler metal) Similar same materials (e.g., bar, sleeve, powder) as                    splice testing shall be done in accordance with Same Intent those to be used in the structure.                              the requirements of the ASME Boiler and Pressure Vessel Code, Section III, Division 2 (ACI Standard 359).
To qualify, the completed splices must meet the The mechanical (sleeve with ferrous filler metal) Similar specified visual inspection acceptance                          splice'testing shall be done in accordance with Same Intent requirements of paragraph 6.12.2 and meet the the requirements of the ASME Boiler and tensile test requirements of paragraph 6.123.                    Pressure Vessel Code, Section III, Division 2 (ACI Standard 359).
24 of 33                                              7/27/10

Enclosure 4, Table 5 ANSI N45.2.5-1978 vs NQA-1-1994, Subpart 2.5 II i10I ii1101.1i1i111l,01 IlOOOvO* VVIIII Il IIUU IIII I1011.10l0 theI members if-"I,I  IIll 1110 1...
1&#xfd; I work
                     ,   "'O  p as                00,1 I
a crew) is subject IVII -W -. kY ual to1w V   splice testing shall be done in accordance with requalification (1) if the specific splice position         the requirements of the ASME Boiler and (e.g., horizontal, vertical, diagonal) has not been         Pressure Vessel Code, Section III, Division 2 used by member or crew for a period of three                (ACI Standard 359).
months or more or (2) if there has been an increase in bar size beyond one bar size up or (3) if there is a reason to question their ability, such as the completed splices not passing visual inspection or tensile testing.
The requalification procedure should be identical The mechanical (sleeve with ferrous filler metal) Similar to the initial qualification procedure.                     splice testing shall be done in accordance with Same Intent the requirements of the ASME Boiler and Pressure Vessel Code, Section III, Division 2 (ACI Standard 359).
6.12.2 Visual Inspection.                                   The mechanical (sleeve with ferrous filler metal) Similar All completed mechanical splices shall be cooled            splice testing shall be done in accordance with Same Intent to ambient temperature prior to being visually              the requirements of the ASME Boiler and inspected at both ends of the splice sleeve and             Pressure Vessel Code, Section III, Division 2 at the tap hole in the center of the splice sleeve          (ACI Standard 359).
for longitudinal centering of sleeve on the spliced ends, allowable voids in filler metal; extent of leaking of filler metal, gas blowout, amount of packing and slag at the tap hole.
Splices that fail to pass visual inspection shall be        The mechanical (sleeve with ferrous filler metal) Similar discarded and replaced and shall not be used as             splice testing shall be done in accordance with Same Intent tensile test samples.                                       the requirements of the ASME Boiler and Pressure Vessel Code, Section III, Division 2 (ACI Standard 359).
6.12.3 Tensile Testing. Splice samples may be               The mechanical (sleeve with ferrous filler metal) Similar production splices (i.e., those cut directly from in-       splice testing shall be done in accordance with Same Intent place reinforcing) or sister splices (i.e., those           the requirements of the ASME Boiler and removable splices made in place next to                     Pressure Vessel Code, Section III, Division 2 production splices and under the same                       (ACI Standard 359).
conditions).
A record shall be kept of all splices tested,               The mechanical (sleeve with ferrous filler metal) Similar showing the splice location, splice identification          splice testing shall be done in accordance with Same Intent number, and whether the tested splice was a                 the requirements of the ASME Boiler and production or sister splice. Splice samples shall           Pressure Vessel Code, Section III, Division 2 be subjected to tensile tests in accordance. with           (ACI Standard 359).
the sampling frequency specified in Section 6.12.4 to determine conformance with the tensile requirements set forth in Table CB-4330-1 of the ASME Code Sec. III,Div. 2.
Splice samples shall be subjected to tensile tests          The mechanical (sleeve with ferrous filler metal) Similar in accordance. with the sampling frequency                  splice testing shall be done in accordance with Same Intent specified in Section 6.12.4 to determine                    the requirements of the ASME Boiler and conformance with the tensile requirements set               Pressure Vessel Code, Section III, Division 2 forth in Table CB-4330-1 of the ASME Code Sec.              (ACI Standard 359).
Ill,Div. 2.
25 of 33                                                7/27/10

Enclosure 4, Table 5 ANSI N45.2.5-1978 vs NQA-1-1994, Subpart 2.5 Olllt.V tUlVt;U   IlillUfUllly Ud[Ir Will llUL L*,ll*l tW*I   I It; IIWL 101 11,&#xfd;t1 l,           v  LI IIIUU  HIII1C1IllUll accurately, production splice'samples shall not              splice testing shall be done in accordance with     Same Intent be re-moved from curved reinforcing bars for                 the requirements of the ASME Boiler and tensile testing.                                             Pressure Vessel Code, Section III,Division 2 (ACI Standard 359).
Straight sister splice samples shall be made for             The mechanical (sleeve with ferrous filler metal) Similar each of the required curved reinforcing bar                  splice testing shall be done in accordance with Same Intent production splices,                                          the requirements of the ASME Boiler and Pressure Vessel Code, Section III, Division 2 (ACl Standard 359).
Production samples shall also not be cut from                The mechanical (sleeve with ferrous filler metal) Similar the structure where the mechanical splicing                  splice testing shall be done in accordance with Same Intent sleeve is welded to an anchorage in a region of              the requirements of the ASME Boiler and high stress concentration, or at a leak tight                Pressure Vessel Code, Section I1l,Division 2 barrier (e.g., embedded structural steel sections            (ACI Standard 359).
or liner plate Representative sister splice samples shall be                The mechanical (sleeve with ferrous filler metal)   Similar used in such cases.                                          splice testing shall be done in accordance with     Same Intent the requirements of the ASME Boiler and Pressure Vessel Code, Section III, Division 2 (ACI Standard 359).
The sampling frequency specified in Section                 The mechanical (sleeve with ferrous filler metal)   Similar 6.12.4(2) shall then be followed, except that all            splice testing shall be done in accordance with     Same Intent splices tested shall be sister splices,                      the requirements of the ASME Boiler and Pressure Vessel Code, Section III,Division 2 (ACI Standard 359).
6.12.4 Tensile Test Frequency. Separate test                 The mechanical (sleeve with ferrous filler metal) Similar cycles shall be established for mechanical                   splice testing shall be done in accordance with Same Intent splices in horizontal, vertical, and diagonal bars,          the requirements of the ASME Boiler and for each bar size as follows:                                Pressure Vessel Code, Section III, Division 2 (ACI Standard 359).
: 1. Test Frequency for Production Splice Test                 The mechanical (sleeve with ferrous filler metal) Similar Samples. If only production splices are tested,              splice testing shall be done in accordance with Same Intent the sample frequency shall be:                               the requirements of the ASME Boiler and
: a. One of the first 10 splices.                              Pressure Vessel Code, Section III, Division 2
: b. One of the next 90 splices.                               (ACI Standard 359).
: c. Two of the next and subsequent units of 100 splices.
: 2. Test Frequency for Combination of Production              The mechanical (sleeve with ferrous filler metal) Similar and Sister Splices. If production and sister                 splice testing shall be done in accordance with Same Intent splices are tested, the sample frequency shall               the requirements of the ASME Boiler and be:                                                          Pressure Vessel Code, Section III, Division 2
: a. One production splice of the first 10 splices.            (ACI Standard 359).
: b. One production and three sister splices for the next 90 production splices.
c - One splice either production or sister splice, for the next and subsequent units of 33 splices.
At least 1/4 of the total number of splices tested shall be production splices -
26 of 33                                               7/27/10

Enclosure 4, Table 5 ANSI N45.2.5-1978 vs NQA-1 -1994, Subpart 2.5 SamIneln Same Intent Welded reinforcing bar splices shall be subject to Welded reinforcing bar splices shall be subject the requirements of Section 7.5 of this Standard   to the requirements of para. 8.5, except that except that provisions of Subsection CC-4334 of    provisions of the ASME Boiler and Pressure ASME Code Section III, Division 2 shall apply. Vessel Code, Section III,Division 2 (ACI Standard 359) shall also apply.
: 7. INSPECTION OF STEEL CONSTRUCTION                8 INSPECTION OF STEEL CONSTRUCTION                OK 7.1 General                                        8.1 General Structural steel qualification shall be           These words were added in NQA-1 documented by manufacturer's certification showing conformance to specifications such as ASTM A 36, A 441, or as otherwise specified.
Inspection of steel construction in accordance      Inspection of steel construction in accordance OK with the "AISC Specification for the Design,        with the AISC S326, Specification for the Fabrication, and Erection of Structural Steel for  Design, Fabrication, and Erection of Structural Buildings" as contained in the AISC Manual of      Steel for Buildings shall include inspection of Steel Construction shall include inspection of      assembly and erection operations, fastening or assembly and erection operations, fastening or      connecting operations such as high strength connecting operations such as high strength         bolting and welding, and finishing operations to bolting and welding and finishing operations to     include cleaning and protective painting or include cleaning and protective painting or         coating.
coating.
!nspection of steel construction shall include      Inspection of steel construction shall include    OK inspection of related items, such as anchor bolts   inspection of related items, such as anchor and base plates, which may be part of the           bolts and baseplates, which may be part of the supporting structure and installed as part of       supporting structure and installed as part of the structural concrete work.                           structural concrete work.
Table B                                             Required tests are delineated within body of      Similar Required In-Process Test                           Subpart 2.5                                       Same Intent 7.2 Supporting Structures                           8.2 Supporting Structures                         OK Prior to erection of steel, anchor bolts, base      Prior to erection of steel, anchor bolts, plates, and other structural embedments shall be baseplates, and other structural embedments checked for correct orientationspacing, and         shall be checked for correct orientation, elevation. Base plate surfaces and supporting       spacing, and elevation. Baseplate surfaces and concrete surfaces shall be checked to verify        supporting concrete surfaces shall be checked satisfactory condition for grouting.                to verify satisfactory conditions for grouting.
Grouting of base plates, beam pockets, etc.,        Grouting of baseplates, beam pockets, etc.,       OK shall be controlled and inspected to verify that    shall be controlled and inspected to verify that only specified materials are used, proportioned     only specified materials are used, proportioned properly, placed correctly; and cured properly to   properly, placed correctly, and cured properly to achieve the specified compressive strength -        achieve the specified compressive strength.
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Enclosure 4, Table 5 ANSI N45.2.5-1978 vs NQA-1-1 994, Subpart 2.5 Assembly and erection operations shall be            Assembly and erection operations shall be inspected to verify compliance with installation     inspected to verify compliance with installation procedures and work instructions. Alignment          procedures and work instructions. Alignment operations shall be carried out early enough and     operations shall be carded out eady enough as often as is necessary as erection progresses      and as often as is necessary as erection to ensure that specified requirements are met        progresses to ensure that specified requirements are met.
Particular attention shall be given to verification  Particular attention shall be given to verification OK of the condition of contact surfaces of friction     of the condition of contact surfaces of friction type connections and bolt hole alignment,            type connections and bolt hole alignment.
Correction of fabrication errors shall be closely    Correction of fabrication errors shall be closely OK controlled to prevent correction of misaligned       controlled to prevent correction of misaligned holes by reaming in excess of AISC tolerances.       holes by reaming in excess of AISC tolerances.
Burning of bolt holes is not permitted.             Burning of bolt holes is not permitted.             OK All equipment used in connecting operations         Equipment used in connecting operations shall       OK shall be inspected to verify conformance with        be inspected to verify conformance with specification requirements.                          specification requirements.
For example, air compressors must be of               For example, air compressors shall be of           OK sufficient capacity to maintain the required         sufficient capacity to maintain the required operating pressures for impact tools.                operating pressures for impact tools.
7.4 High Strength Bolting                            8.4 High Strength Bolting                           OK Bolt tightening shall be in accordance with the       Bolt tightening shall be in accordance with the specified method, i.e., automatic cut-off impact     specified method, e.g., automatic cut-off impact wrench, turn-of-nut method, or direct-tension        wrench, turn-of-nut method, or direct-tension indicator. If the turn-of-nut method is used,        indicator. If the turn-of-nut method is used, inspections shall be made to verify that the          inspections shall be made to verify that the bolting crews understand the meaning of "snug         bolting crews understand the meaning of snug tight" condition before the nut is tumed through     tight condition before the nut is turned through the required angle                                   the required angle.
If an automatic cut-off impact wrench is used, it     If an automatic cut-off impact wrench is used, it OK shall be calibrated at least twice daily,            shall be calibrated at. least twice daily.
The calibration of automatic cut-off impact          The calibration of automatic cut-off impact       . OK wrenches shall be performed by tightening in a       wrenches shall be performed by tightening in a device capable of indicating actual bolt tension,    device capable of indicating actual bolt tension, using no less than three typical bolts of each        using no less than three typical bolts of each diameter from the bolts being installed,             diameter from the bolts being installed.
Installation of bolts shall be done in accordance     Installation of bolts shall be done in accordance OK with "Specifications for Structural Joints Using     with AISC 5329, Specifications for Structural ASTM A-325 or A-490 Bolts."                          Joints Using ASTM A 325 or A 490 Bolts.
Qualification of bolts shall be.documented by      These words were added in NQA-1 manufacturer's certification or as otherwise specified 28 of 33                                                7/27/10

Enclosure 4, Table 5 ANSI N45.2.5-1978 vs NQA-1-1994, Subpart 2.5 I H.I II~pI*l.lIlU[ I IJI LJIILII I*. IIlI*)J*,tlq.IUI I LII IJuIJ  U.-t I IIpO     .   .fJIJ
                                                                                              -V...U IV. IO-LI*LIf~ ..
shall include visual inspections of bolting                            shall include visual inspection of bolting operations and torque wrench inspection of                             operations and torque wrench inspection of completed connections.                                                 completed connections.
Connection points shall be visually inspected for Connection points shall be visually inspected                           OK the following items:                                                   for the following items:
(a) bolts are long enough as indicated by the
: 1. Bolts are long enough as indicated by the                           point of the bolts being flush with or outside the point of the bolts being flush with or outside the face of the nuts; face of the nuts.                                                      (b) correct type bolt is used as indicated by the
: 2. Correct type bolt is used as indicated by the                       manufacturer's marking on the head; manufacturers marking on the head.                                     Cc) torque has been applied as indicated by the
: 3. Torque has been applied as indicated by the burnishing or peening of the comers of the nut; burnishing or peening of the comers of the nut. (d) tuming elements are on the correct face;
: 4. Turning elements are on the correct face;                           properly sized washers are used when properly sized washers are used when required. required.
The schedule bolt tension inspection shall be as                       Bolt tension inspection shall be as specified in   OK specified in the latest edition of "Specification for                  AISC Structural Joints Using ASTM A-325 or A-490                            5329, Specification for Structural Joints Using Bolts".                                                                ASTM A 325 or A 490 Bolts.
In addition, during the initial phase of bolting                       In addition, during the initial phase of bolting   OK operations, all bolts tightened by each bolting                        operations, all bolts tightened by each bolting crew shall be checked until the results are                            crew shall be checked until the results are consistently acceptable.                                               consistently acceptable.
7.4.2 Inspection Tools and Procedure.                                  8.4.2 Inspection Tools and Procedure. Hand         OK Hand torque wrenches used for inspection shall                         torque wrenches used for inspection shall be be controlled in accordance with paragraph 2.5.2                       controlled in accordance with Part I, Basic and and must be calibrated at least weekly and more                        Supplementary Requirements, and shall be often if deemed necessary.                                             calibrated at least weekly, more often ifdeemed necessary.
Impact torque wrenches used for inspection                             Impact torque wrenches used for inspection        OK must be calibrated at least twice daily,                               shall be calibrated at least twice daily.
Feeler gauges used for inspection of direct-                           Feeler gauges used for inspection of direct-       Similar tension indicators shall be controlled in                              tension indicators shall be controlled..           Same intent accordance with paragraph 2.5.2.
7.5 Welding                                                            8.5 Welding                                        Similar Same Intent Inspection of structural steel welding shall be                        Inspection of structural steel welding shall be performed in accordance with the provisions of                         per-formed in accordance with the provisions of AWS DI .1, Section 6, entitled "Structural                             Section 6.0 of AWS DI., Structural.Welding Welding Code," and supplemental addenda.                               Code- Steel.
This inspection shall include visual examination                       This inspection shall include visual examination OK of preparations, welding processes, and post-                          of preparations, welding processes, post-welding operations and ifdeemed necessary                              welding operations, and if deemed necessary, some NDE inspections which are appropriate to                          some NDE inspections which are appropriate to the application,                                                       the application.
Prior to welding, verification of welding                              Prior to welding, verification of welding          OK procedure and welder qualification shall be                            procedure and welder qualification shall be documented and shall include all essential                             documented and shall include all essential variables identified in the procedure.                                 variables identified in the procedures.
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Enclosure 4, Table 5 ANSI N45.2.5-1978 vs NQA-1-1994, Subpart 2.5 II I-PIuubb                 i lb lI 16l.IUU wIbpAII acceptability of environmental conditions, joint fit  acceptability of environmental conditions, joint up prior to start of welding, preheat and interpass   fit-up prior to start of welding, preheat and temperature requirements, filler metal, control of    interpass temperature requirements, filler distortion, and post-weld heat treatment and          metal, control of distortion, post-weld heat cleaning requirements.                                treatment, and deaning requirements.
Procedures shall be established to control the         Procedures shall be established to control the    OK purchase, receiving, distribution, storage, and       purchase, receiving, distribution, storage, and use of welding electrode.                             use of welding electrodes.
Weld repairs necessitated by visual or             These words were added in NQA-1 nondestructive examinations shall be made in accordance with the procedure used to perform the original weld or a qualified repair procedure and reinspected by the same method that disclosed the repairable defect.
All weld repairs necessitated by nondestructive These words were added in NQA-1 examination shall be documented.
: 8. DATA ANALYSIS AND EVALUATION                       9 DATA ANALYSIS AND EVALUATION                     OK 8.1 General                                           9.1 General Procedures shall be established for processing        Procedures shall be established for processing inspection and test data and their analysis and       inspection and test data and their analysis and evaluation,                                           evaluation.
These procedures shall provide for acquisition        These procedures shall .provide for acquisitions OK and preparation of inspection and test data for       and preparation of inspection and test data for prompt evaluation against acceptance criteria,        prompt evaluation againstacceptance criteria, operating limits, and performance standards.          operating limits, and performance standards.
The data processing procedures shall provide for      The data processing procedures shall provide       OK "on-the-spot" evaluation to determine the validity    for on-the-spot evaluation to determine the of the inspection and test results and the            validity of the inspection and test results and appropriateness of continuing the inspection or       the appropriateness of continuing the test.                                                 inspection or test.
The data shall be analyzed and evaluated to           The data shall be analyzed and evaluated to        OK verify completeness of results, achievement of        verify completeness of results and achievement inspection and test objectives, and to identify       of inspection and test objectives; and to identify additional inspection and tests required; and         additional inspection and tests required, and necessary changes to the installation inspection      necessary changes to the installation inspection or test procedures.                                   or test procedures.
Inspection and test results that include              Inspection and test results that include           OK inspection and test data, together with a report of   inspection and test data, together with a report data analysis and evaluation, shall be provided       of data analysis and evaluation, shall be as specified in Section 9.                            provided as specified in Section 10.
8.2 Concrete and Mechanical (Cadweld) Splice          9.2 Concrete and Mechanical (Sleeve With           OK Test Data Evaluation and Analysis                     Ferrous Filler Metal) Splice Test Data Evaluation and 8.2.1 Evaluation of Concrete Test Results.            Analysis Standard deviation data shall be developed, evaluated, and maintained for permanent               9.2.1 Evaluation of Concrete Test Results.
records in accordance with ACI 214.                   Standard deviation data shall be developed, evaluated, and maintained for permanent records in accordance with ACI 214.
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Enclosure 4, Table 5 ANSI N45.2.5-1978 vs NQA-1-1994, Subpart 2.5
%..UIIUIACU t4UdIILY al 1U dAC&#xfd;PLCII UV U1 ILVId ~I    '.VILIL -I    yuirc-y O 01/4.- Ct  L~CI    ..
conform to the requirements of ACI 318, Chapter conform to the requirements of ACI 318,
: 4.                                                    Chapter 4.
8.2.2 Evaluation of Mechanical (Cadweld) Splice 9.2.2 Evaluation of Mechanical Splice Test             Similar Test Results. The following procedure shall be        Results.                                         Same Intent used for substandard tensile test results:            The evaluation of mechanical splice test results shall be in accordance with ASME Boiler and Pressure Vessel Code, Section IIl, Division 2 (ACI Standard 359).
: 1. If any production or sister splice tested fails to 9.2.2 Evaluation of Mechanical Splice Test       Similar meet the tensile test specification of paragraph      Results.                                         Same Intent 6.12.3 and the observed rate of splices that fail     The evaluation of mechanical splice test results the tensile test at that time does not exceed one     shall be in accordance with ASME Boiler and for each 15 consecutive test samples, the             Pressure Vessel Code, Section I1l,Division 2 sampling procedure shall be started anew.             (ACI Standard 359).
If any production or sister splice used for testing  9.2.2 Evaluation of Mechanical Splice Test       Similar fails to meet the tensile test specification in       Results.                                         Same Intent paragraph 6.12.3 and the observed rate of             The evaluation of mechanical splice test results splices that fail the tensile test exceeds one for    shall be in accordance with ASME Boiler and each 15 consecutive test samples, mechanical          Pressure Vessel Code, Section III; Division 2 splicing shall be stopped.                            (ACI Standard 359).
In addition, the adjacent production splices on       9.2.2 Evaluation of Mechanical Splice Test       Similar each side of the last failed splice and four other    Results.                                         Same Intent splices distributed uniformly throughout the          The evaluation of mechanical splice test results balance of the 100 production splices Under           shall be in accordance with ASME Boiler and investigation shall be tested, and an analysis        Pressure Vessel Code, Section III, Division 2 shall be made to identify the cause of all failures.  (ACI Standard 359).
The results of these tests shall be evaluated by      9.2.2 Evaluation of Mechanical Splice Test       Similar the responsible engineering organization to           Results.                                         Same Intent determine the corrective action.                      The evaluation of mechanical splice test results shall be in accordance with ASME Boiler and Pressure Vessel Code, Section Il, Division 2 (ACI Standard 359).
The responsible engineering organization shall       9.2.2 Evaluation of Mechanical Splice Test       Similar specify the extent of repairs necessary and the      Results.                                         Same Intent actions required to prevent further failures from    The evaluation of mechanical splice test results the identified causes.                               shall be in accordance with ASME Boiler and Pressure Vessel Code, Section III, Division 2 (ACI Standard 359).
If two or more splices from any of these six         9.2.2 Evaluation of Mechanical Splice Test       Similar additional splice samples fail to meet the tensile   Results.                                         Same Intent test specification of paragraph 6.12.3, the          The evaluation of mechanical splice test results balance of the 100 production splices under          shall be in accordance with ASME Boiler and investigation shall be evaluated by the              Pressure Vessel Code, Section III, Division 2 responsible engineering organization to              (ACI Standard 359).
determine the corrective action.
When mechanical splicing is resumed, the            9.2.2 Evaluation of Mechanical Splice Test       Similar sampling procedure shall be started anew.            Results.                                         Same Intent The evaluation of mechanical splice test results shall be in accordance with ASME Boiler and Pressure Vessel Code, Section III, Division 2 (ACI Standard 359).
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Enclosure 4, Table 5 ANSI N45.2.5-1978 vs NQA-1 -1994, Subpart 2.5
: z. if Fie average  ler1si1e SL((regl o1 Mnei D      U.4.L   -VdIludLlU1I U1 IVl*Tl*1diIIL;*dl OpIILU I tbL   l[l lilrd consecutive samples fails to meet the provisions    Results.                                               Same Intent of paragraph 6.12.3, the responsible engineering    The evaluation of mechanical splice test results organization shall evaluate and assess the          shall be in accordance with ASME Boiler and acceptability of the reduced average tensile        Pressure Vessel Code, Section III, Division 2 strength with respect to the required strength of   (ACl Standard 359).
the location from which the samples were taken.
8.2.3 Evaluation of Aggregate Test Results.         9.2.3 Evaluation of Aggregate Test Results             OK When any aggregate tests specified fail to meet      When any aggregate tests specified fail to meet the specified requirements, two additional tests     the specified requirements, two additional tests shall be made from samples of the same lot of       shall be made from samples of the same lot of aggregate.                                           aggregate.
If one or both of the two additional tests fail to  9.2.3 If one or both of the two additional tests       OK meet the specified requirements, the data shall     fails to meet the specified requirements, the be submitted to the responsible engineering         data shall be submitted to the responsible organization forevaluation and corrective action. engineering organization for evaluation and corrective action.
8.3 Steel Construction Test Data Evaluation and 9.3 Steel Construction Test Data Evaluation                 Similar Analysis                                             and Analysis                                           Same Intent This data shall be evaluated for conformance to      This data shall be evaluated for conformance to project specifications, the AISC Manual of Steel     project specifications of the AISC MO1 1, Construction, and AWS DI .1 and supplemental         Manual of Steel Construction and AWS Di.,
addenda.                                             Structural Welding Code - Steel.
8.4 Soils Test Data Evaluation and Analysis          9.4 Soils Test Data Evaluation and Analysis            OK This data shall be evaluated daily during            This data shall be evaluated daily during progress of the work for conformance to project      progress of the work for conformance to project specifications,                                      specifications.
The control techniques given in the                  The control techniques given in the                    OK specifications such as specific test methods for     specifications, such as specific test methods for the type of soil compacted must be verified,         the type of soil compacted, shall be verified.
Data must include determination of parameters         Data shall include determination of parameters Similar specified including use of proper materials,         specified, including use of proper materials,          Same Intent amounts and uniformity of soil moisture,             amounts and uniformity of soil moisture, and thickness of layers being placed, and finally,       thickness of layers being placed.
determination of specified compacted values by       In-place compacted fill density shall be specified tests of in-place density and attainment   determined using standard approved methods of specified values,                                 and the results evaluated for compliance to specified requirements.
Data shall include verification that the soils are    Data shall include verification that the soils are OK fully compacted or consolidated to contours and      fully compacted or consolidated to contours and grades specified,                                    the grades specified.
When statistical methods are required by the        When statistical methods are required by the           OK specification, the desired level of confidence       specification, the desired level of confidence must be specified.                                   shall be specified.
32 of 33                                                   7/27/10

Enclosure 4, Table 5 ANSI N45.2.5-1978 vs NQA-1-1994, Subpart 2.5 Record copies of completed procedures, reports,       Record copies of procedures, reports, personnel qualification records, test equipment       personnel qualification records, test equipment calibration records, test deviation or exception      calibration records, test deviation or exception records, and inspection and examination records       records, and inspection and examination shall be prepared.                                    records shall be prepared.
These shall be placed with other project records      These shall be retained with other project        OK as required by code, standard, specification, or      records as required by code, standard, project procedures.                                   specification, or project procedures.
Collection, storage, and maintenance of records       N45.2.9 incorporated into NQA-1 as Basic          QAPP Section 4.17 commits to shall be in accordance with requirements of           Requirement 17 and Supplement 17S-1.              Basic Requirement 17 and ANSI N45.2.9.                                                                                           Supplement 17 S-1.
: 10. REVISION OF AMERICAN NATIONAL                     These documents incorporated into NQA-1 STAN-DARDS REFERRED TO IN THIS DOCUMENT When any of the following standards referred to in this document is superseded by a revision approved by the American National Standards Institute, the revision is not mandatory until it has been incorporated as a part of this Standard.
N45 2 Quality Assurance Program Requirements These documents incorporated into NQA-1 for Nuclear Power Plants N45.2.2 Packaging, Shipping, Receiving, Storage and Handling of Items for Nuclear Power Plants.
N45.2.3 Housekeeping During the Construction Phase of Nuclear Power Plants N45.2.6 Qualifications of Inspection, Examination and Testing Personnel for the Construction Phase of Nuclear Power Plants N45 .2.9 Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants N45.2.10 Quality Assurance Terms and Definitions APPENDIX                                              NQA-1 Part II Introduction includes similar       Similar language with the same intent:                    Same intent (This Appendix is not a part of ANSI Standard N45.2.5 but is included for information purposes      7 REFERENCED CODES, STANDARDS, AND only.)                                                SPECIFICATIONS All codes, standards, and specifications that are NONMANDATORY APPENDIX A                              referenced as a part of this Part (Part II) are listed in the Table entitled "Codes, Standards, (Ust of Reference Documents)                          and Specifications Referenced in Text."
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Enclosure 4, Table 6 ANSI N45.2.8-1975 vs NQA-1-1994, Subpart 2.8 intent.
1.1          Scope                          Section 1 "Purpose" This standard contains requirements         This Part (Part II) sets forth the and guidelines to assure the quality of     quality assurance requirements for important items of nuclear power            the planning and execution of plants including structures, systems         identified tasks during the fabrication, and components.                              construction, modification, repair, maintenance, and testing of systems, components, and structures for The requirements and guidelines are          I GENERAL                                N45.2.8 includes "in a manner that will intended to assure that these important                                              provide adequate confidence that they items are installed, inspected and          Subpart 2.8 provides amplified           will perform satisfactorily in service."
tested in a manner that will provide        requirements for installation, adequate confidence that they will          inspection, and testing of mechanical perform satisfactorily in service.          equipment and systems.
The requirements and guidelines for                                                  Guidance only. Wording does not installation, inspection and testing                                                 establish requirements.
activities during construction are intended to assure the quality of mechanical items not covered by Section III of the ASME Boiler and Pressure Vessel Code.
The requirements of this standard deal                                               Guidance only. Wording does not with the protection and control                                                      establish requirements.
necessary to assure that the requisite quality of mechanical items of the plant
.are preserved from the time items are removed from storage or receiving until they are incorporated into the plant up to but not including fuel loading of PWR plants and the completion of cold functional testing of BWR and HTGR plants.
This standard is intended to be used in     It supplements the requirements of       Slightly different words, but same conjunction with ANSI N45.2. If any         Part I and shall be used in              intent.
conflict exists, ANSI N45.2 shall           conjunction with applicable Basic and govern.                                     Supplementary Sections of Part I when and to the extent-specified by the organization invoking Subpart 2.8.
1.2       Applicability                     Introduction                              N45.2.2 is more specific in detailing that the requirements and guidelines The requirements and guidelines of          Section 2 "Applicability"                 "apply to the work of any individual or this standard apply to the work of any                                               organization"..
individual or organization that             "...The requirements of this Part (Part participates in installation, inspection    II) apply to fabrication, construction,  Same Intent / Result or testing of mechanical equipment          modification, repair, maintenance, during construction activities of nuclear   and testing activities that affect the power plants as discussed in Subsec-        quality of structures, systems, and tion 1.1.                                   components for nuclear facilities.
These activities include the performing function of attaining quality objectives and verifying that activities affecting quality have been correctly performed. These activities include planning, subsurface investigation, fabricating, handling, shipping, storing, cleaning..."
The extent to which the individual          Introduction                              N45.2.8 states that application will be requirements of this standard apply will                                             dependent "upon the nature and scope depend upon the nature and scope of         Section 2 "Applicability"                of the work to be performed and the the work to be performed and the                                                      importance of the item or service importance of the item or service           To the extent applicable to the           involved" whereas NQA-1 states "shall 1 of 24                                                   7/27/10

Enclosure 4, Table 6 ANSI N45.2.8-1975 vs NQA-1-1994, Subpart 2.8 application of this Part (Part II), or    policies, procedures, or instructions.
portions thereof, and the provisions     Same Intent / Result of Part 1, Basic and Supplementary Requirements, shall be specified in written contracts, policies, orocedures, or instructions.
Important mechanical items to be           Introduction                             Same Intent / Result covered and the extent of coverage shall be identified by the individual or    Section 2 "Applicability" organization invoking this standard.
To the extent applicable to the activities being performed, the application of this Part (Part II), or portions thereof, and the provisions of Part 1, Basic and Supplementary Requirements, shall be specified in written contracts, policies, procedures, or instructions.
The requirements are intended to                                                     Guidance / Context Wording assure that only proper materials, equipment, processes and procedures are utilized during the construction of power plants and that the quality of items is not degraded as a result of installation, inspection and testing practices and techniques during construction.
The ASME Boiler and Pressure Vessel                                                  Section 1.1/1.2 of the QAPP specifies Code (herewith referred to as the                                                    applicable Regulatory Commitments.
Code), as well as other American National Standards has been considered in the development of this standard, and this standard is intended to be compatible with their requirements. However, this standard does not apply to activities covered by Section IIIDivision I and 2 and Section XI of the Code for those activities covered by the Code.
1.3      Responsibility                    Basic Requirement 1                       Similar Same Intent The organization or organizations          The organizational structure, responsible for establishing the           functional responsibilities, levels of applicable requirements for the activi-    authority, and lines of communication ties covered by this standard shall be     for activities affecting quality shall be identified and the scope of their          documented.
responsibilities shall be documented.
Supplement 1S-1 3.1 Where more that one organization is involved in the execution of activities covered by this Part (Part 1) the responsibility and authority of each organization shall be clearly established and documented.
The work of establishing practices and     Supplement 1S-1                           Similar procedures and providing the               2.2 The individual(s) or                  Same intent resources in terms of personnel, equip-    organization(s) responsible for ment and services necessary to             establishing and executing a quality implement the requirements of this         assurance program under this standard may be delegated to other         Standard may delegate any or all of organizations and such delegation          the work to others but shall retain shall also be documented.                  responsibility therefor.
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Enclosure 4, Table 6 ANSI N45.2.8-1975 vs NQA-1-1994, Subpart 2.8 tion performing work covered by this                                                intent.
standard to comply with the               Section 3 "Responsibility" procedures and instructions issued for the project and to conform to the         The organization invoking this Part requirements of this standard             (Part II) shall be responsible for applicable to this work.                  specifying which section, or portions thereof, apply and appropriately relating them to specific items and services. To the extent necessary, this organization shall invoke the applicable provision of Part 1, Basic and Supplementary Requirements, to specify a complete Quality Assurance Program appropriate for the specific items or services. The organization upon which this Part (Part II), or portions thereof, is invoked shall be responsible for complying with the specified requirements.
It is the responsibility of the          Introduction.                             NQA-1 does not include the words organization performing these activities                                            "unless they are specified in to specify the detailed methods and       Section 3 "Responsibility"                procurement documents".
procedures unless they are specified in the procurement documents.                The organization invoking this Part       Differences are not relevant.
(Part II) shall be responsible for specifying which section, or portions thereof, apply and appropriately relating them to specific items and services. To the extent necessary, this organization shall invoke the applicable provision of Part 1, Basic and Supplementary Requirements, to specify a complete Quality Assurance Program appropriate for the specific items or services. The organization upon which this Part (Part II), or portions thereof, is invoked shall be responsible for complying with the specified reauirements.
1.4       Definitions                     1.1     Definitions                      OK The following definitions are provided    The following definitions are provided to assure a uniform understanding of      to assure a uniform understanding of select terms as they are used in this     unique terms as they are used in standard.                                 Subpart 2.8.
Acceptance Criteria- A limit or limits    I Introduction                           N45.2.8 is more specific in detailing placed on the variation permitted in the  Section 4 "Terms and Definitions"        definitive engineering terms.
characteristics of an item expressed in definitive engineering terms such as      acceptance criteria - specified limits   Differences are not relevant.
dimensional tolerances, chemical          placed on characteristics of an item, composition limits, density and size of   process, or service defined in codes, defects, temperature ranges, time         standards, or other required limits, operating parameters, and other   documents.
similar characteristics.
Checks - The tests, measurements,         checks - the tests, measurements,        OK verifications or controls placed on an    verifications, or controls placed on an activity by means of investigations,      activity by means of investigations, comparisons, or examinations to           comparisons, or examinations to determine satisfactory condition,         determine satisfactory condition, accuracy, safety or performance.          accuracy, safety, or performance EngineeringLimitations - Restrictions     engineering limitations- restrictions    OK which, if disregarded, may result in      which, if disregarded, may result in damage to the item, shortening the life   damage to the item, shortening the of the item, or preventing the item from  life of the item, or preventing the item functioning as intended,                  from functioning as intended 3 of 24                                                7/27/10

Enclosure 4, Table 6 ANSI N45.2.8-1975 vs NQA-1 -1994, Subpart 2.8 inspection consisting of investigation of           inspection consisting of investigation materials, components, supplies and                 of materials, components, supplies, services to determine conformance to                and services to determine those specified requirements which                  conformance to those specified can be determined by such                           requirements which can be investigation. Examination is usually               determined by such investigation.
nondestwuctive and includes simple                   Examination is usually nondestructive physical manipulation, gaging and                   and includes simple physical measurement.                                        manipulation, gaging, and measurement.
Inspection - An element of quality                   I Introduction                            N45.2.8 includes words "an element of control which by means of                           Section 4 "Terms and Definitions"          quality control" and "observation" and examination, observation or                                                                   examples of what one is trying to measurement determines the                           inspection - examination or              determine conformance of (i.e.,
conformance of materials, supplies,                  measurement to verify whether an          materials, supplies, etc.). In addition, components, parts, appurtenances,                    item or activity conforms to specified    N45.2.8 states that it is to systems, processes or structures to                 requirements.                              "predetermined quality requirements" predetermined quality requirements.                                                           whereas NQA-1 states "specified requirements".
_________________________Same                                                 Intent IResult Mechanical Items - Parts,                          mechanical items - parts,                  OK components, or systems that function                components, or systems that function primarily for pressure retaining, mass              primarily for pressure retaining, mass moving, or heat exchange purposes.              .moving,       or heat exchange purposes.
Examples of mechanical items are                     Examples of mechanical items are rotating equipment (motors, pumps,                  rotating equipment (motors, pumps, blowers), handling equipment (cranes,                blowers), handling equipment hoists, conveyors), piping systems                  (cranes, hoists, conveyors), piping (pipe, valves, hangers), fuel handling              systems (pipe, valves, hangers), fuel systems, and waste effluent systems.                 handling systems, and waste effluent
____________________________systems.__________________
Testing - The determination or                     I Introduction                             OK verification of the capability of an item           Section 4 "Terms and Definitions" to meet specified requirements by subjecting the item to a set of physical,           testing - an element of verification for chemical, environmental or operating                the determination of the capability of conditions,                                         an item to meet specified requirements by subjecting the item to a set of physical, chemical, environmental, or operating conditions.
Verification - An act of confirming,                I Introduction                             N45.2.8 states that it is an act of substantiating and assuring that an                 Section 4 "Terms and Definitions"          "confirming, substantiating and activity or condition has been                                                                 assuring" whereas NQA-1 defines it as implemented in conformance with the                 verification - the act of reviewing,       an act of "reviewing, inspecting, specified requirements.                             inspecting, testing, checking,             testing, checking, auditing, or auditing, or otherwise determining         otherwise determining". In addition and documenting whether items,             N45.2.8 states that it is "an activity or processes, services, or documents          condition" whereas NQA-1 states it is conform to specified requirements.         "items, processes, services, or documents".
Same Intent / Result Other terms and their definitions are               Introduction                               Slightly different words, but same contained in ANSI N45.2.10.                                                                    intent.
Section 6 "Definitions" Definitions unique to the activities described in this Part (Part 11)are included inthe section dealing with that activity. Definitions generic to quality assurance activities are         _________________
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Enclosure 4, Table 6 ANSI N45.2.8-1975 vs NQA-1 -1994, Subpart 2.8 ANSI N45.2.8 - 1975               _&#xfd; NQA-1 (1994) Subpart2.8                                Commennts (except where rnoted)        /       (NOTF: OK signifies ide~ntical or
_                                              n(early clentical wording) included in Part 1, Supplement S-1, Terms and Definitions 1.5         Referenced Documents           Introduction                               Slightly different words, but same intent.
Documents that are required to be          Section 7 "Referenced Codes, included as a part of this standard are    Standards, and Specifications" identified at the point of reference and described in Section 8 of this standard. All codes, standards, and specifications that are referenced as a part of this Part (Part II)are listed in the Table entitled "Codes, Standards, and Specifications Referenced in Text."
The issue or edition of the referenced     Codes, standards, and specifications.      N45.2.8 includes the words "unless document that is required will be          referenced in this Part (Part II)may       otherwise specified in the contract specified either at the point of           be identified with the applicable date     document".
reference or in Section 8 of this          or reference at the point of reference     Same Intent / Result standard unless otherwise specified in     or in the Table "Codes, Standards, the contract document.                     and Specifications Referenced in Text.
: 2. GENERAL REQUIREMENTS                  2 GENERAL REQUIREMENTS                     Guidance only. Wording does not establish requirements.
This section contains requirements that are to be fulfilled by the organization or organizations responsi-ble for performing any segment of work described in Section 3 through 5 of this standard.
Measures shall be established and          Measures shall be established and          OK implemented for documenting the            implemented for documenting the necessary installation, inspection and     necessary installation, inspection, testing to verify conformance to           and testing to verify conformance to specified requirements.                    specified requirements.
5 of 24                                                     7/27/10

Enclosure 4, Table 6 ANSI N45.2.8-1975 vs NQA-1 -1994, Subpart 2.8 Activities shall be planned and              Planning and procedure preparation documented to be consistent with             shall be in accordance with the engineering and design requirements          requirements of the Introduction to including those which define the             this Part (Part II).
degree of importance to safety and reliability of the item.                     Introduction Planning shall define the operations to     Section 4.1 "Planning" be used and the systematic, sequential progression of operations, the               A plan shall be developed outlining personnel responsibilities for each          the work to be performed and the activity and the measures employed to        work procedures or instructions preserve the quality of the item.           required to comply with the requirements of the defined work Planning shall take into account the        scope.
need for the identification, preparation and control of procedures and work           Planning shall define the operations instructions necessary to comply with       to be performed, the systematic requirements for installation, inspection    sequential progression of operations, and testing of components and               .and the overall measures employed systems; and the need for trained           to preserve the quality of the work personnel necessary to comply with these procedures, work instructions,         Planning shall include a review of the and requirements.                            structure, system or component design/procurement specifications, Planning shall include a review of the       materials, lists, drawings, system and component design                  construction work plans, and specifications, procurement documents        schedules to ensure that fabrication, and drawings and of the construction         installation, modification, inspection, work plans and schedules to assure           testing, etc., activities have been that applicable installation, inspection,    incorporated; that the work can be and testing activities have been iden-       accomplished as specified; and that tified; that they can be accomplished        time and resources, plus training, are as specified; and that time and              sufficient to accomplish the work in resources are sufficient to accomplish       accordance with the specified the required actions.                        requirements.
Deficiencies identified during reviews       Basic Requirement 16                    Same Intent / Effect shall be brought to the attention of the     Conditions adverse to quality shall be responsible organization for action,         identified promptly and corrected as soon as practical.
2.2 Procedures and Instructions              Introduction                            N45.2.8 states that procedures and instructions should be prepared and Installation, inspection and test           Section 4.2 "Procedures"                 documented, NQA-1 states prepared.
procedures and work instructions identified during planning shall be          Installation, inspection, test prepared and documented for those            procedures, and work instructions activities falling within the scope of this  identified during planning shall be standard.                                    prepared.
'Where the planning review identifies         Preparation and approval of the         Same Intent / Result new procedures and inspections that          procedures/instructions shall be in are necessary, appropriate target            advance of the need to use the dates and effort shall be scheduled for      documents.
their preparation and approval.
These documents shall be kept current       The documents shall be kept current      OK and revised as necessary to assure           and revised as necessary to assure that installation, inspections, and tests. that work is performed in accordance are performed in accordance with,            with the latest approved information.
latest approved information and shall include as appropriate:                      The documents shall include the following as applicable:
6 of 24                                              7/27/10

Enclosure 4, Table 6 ANSI N45.2.8-1975 vs NQA-1-1994, Subpart 2.8 r i2.9.llI;IC S
Subsectionc. UCl It 2.9.                                                          Iprepa1a t-U-checks preparatory        k aVnV-d LIc     -n InUUIIoIn and inspections" preparatory checks and inspections
: b. Precautions to be observed.               (b)  precautions to be observed        OK
: c. Installation requirements.                (c)  work requirements including       Slightly different words, but same installation specifications      intent.
: d. Sequential actions to be followed.        (d)   sequence of activities to be     Slightly different words, but same followed and steps within a      intent.
given activity
: e. Test objectives.                          (f)   test and inspection objectives   NQA-1 adds the words "and inspection"
: f. Special equipment required for            (g) special equipment required         OK installation, inspection and test.
: g. Identification of inspection and test     (h) identification of inspection and   NQA-1 adds "and test equipment and equipment.                                 test equipment and related       related calibration requirements calibration requirements         including recalibration dates" including recalibration dates
: h. Frequency of inspection or test.          (i) sequence and frequency of          NQA-1 adds "sequence" inspection or test
: i. Inspection and test acceptance            (0) acceptance criteria and methods    NQA-1 adds "and methods for criteria,                                  for verifying                    verifying"
: j. Specific document references where        (m) specific document references       N45.2.8 adds "where required" required.                                                                   Same Intent / Result
: k. Data report forms.                        (n) data or test report forms          NQA-1 adds "or test" 1.Approvals.                                 (I) approvals and authorizing or       NQA-1 adds "and authorizing or verifying signatures             verifying signatures" 2.3 Results                                  6      Data Analysis and Evaluation    N45.2.8 states "in a suitable test report or data sheet" Inspection and test results shall be          Inspection and test results supported Same Intent / Result documented in a suitable test report or      by inspection and test data, together data sheet.                                  with a report of data analysis and evaluation, shall be provided as specified in Section 7.
Each report shall identify the item to       BR 10 "Inspection"                     These words are not included in NQA-which it applies, the procedures or                                        .1            Intent is encompassed by instruction followed in performing the       Inspection results shall be            subsequent record requirements of a-f.
task and include the following:               documented.
BR 11 "Test Control" Test results shall be documented.
Supplement 1OS-1 "Supplementary Requirements for Inspection" Records shall, as a minimum, identify (a) through (f) below:
: a. Pertinent inspection and test data.        (e) results and acceptability          Slightly different words, but same intent.
: b. Significant dates and times.               (b) date of inspection                 Slightly different words, but same intent.
: c. Signature or stamp of inspector or         (c) inspector                          Slightly different words, but same tester.                                                                              intent.
: d. Measuring and test equipment used          (d) type of observation                Type of observation may include where required.                                                                      identification of equipment as necessary
: e. Identification of nonconformances          (f) reference to information on action Slightly different words, but same and action taken on other conditions          taken in connection with               intent.
that were not anticipated.                    nonconformances Test reports and data sheets shall            6 Data Analysis and Evaluation         Slightly different words, but same include an evaluation of the                                                         intent.
acceptability of inspection and tests         Procedures shall be established for results and provide for identifying the       processing inspection and test data individual who performed the                  and their analysis, evaluation, and 7 of 24                                               7/27/10

Enclosure 4, Table 6 ANSI N45.2.8-1975 vs NQA-1 -1994, Subpart 2.8 shall identify individuals or organizations responsible for the acquisitions and reduction of inspection and test data, and evaluation against acceptance criteria, operating limits and 2.6 Cleaning                                                                     Specific provisions which are applicable to project activities are Cleaning activities required by this                                             addressed by other portions of NQA-1 standard shall be performed in                                                   or will be defined in associated accordance with ANSI N45.2.1 and                                                 procedures if applicable to project Section 4 of this standard.                                                      activities.
2.5 Receiving, Storage and                                                       Specific provisions which are Handling                                                                         applicable to project activities are addressed by other portions of NQA-1 Receiving, storage and handling                                                  or will be defined in associated activities required by this standard                                             procedures if applicable to project shall be performed in accordance with                                            activities.
ANSI N45.2.2.                            _____________                            _____________
2.6 Housekeeping                                                                 Specific provisions which are applicable to project activities are In areas, facilities, and environments                                           addressed by other portions of NQA-1 where installation, inspection and                                               or will be defined in associated testing of mechanical items is                                                   procedures if applicable to project performed in accordance with the                                                 activities.
requirements of this standard, the housekeeping requirements shall be in accordance with ANSI N45.2.3.
2.7 Personnel Qualifications               Introduction                          Slightly different words, but same intent.
Those personnel who perform                Section 5 "Qualification of inspection and testing activities          Personnel" required by this standard shall be qualified in accordance with ANSI          Inspection, test, and nondestructive N45.2.6.                                   examination personnel and laboratory technicians shall be trained and qualified/certified in accordance with the applicable portions of Part 1, Basic and Supplementary Requirements.
Professional personnel shall meet the requirements defined by the implementing organization in its position descriptions.
2.8 Measuring and Test Equipment           Supplement 12S-1 "Supplementary       OK Requirements for Control of 2.8.1 Selection. Measuring and test        Measuring and Test Equipment" equipment used to implement the requirements of this standard shall be  'Paragraph 2 selected to have range, type and accuracy sufficient to determine           Selection of measuring and test conformance to specified                  equipment shall be controlled to requirements.                             assure that such items are of proper type, range, accuracy, and tolerance to accomplish the function of determining conformance to specified requirements.
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Enclosure 4, Table 6 ANSI N45.2.8-1975 vs NQA-1-1994, Subpart 2.8 Measuring and test equipment used to      Requirements for Control of.
determine compliance with speci-          Measuring and Test Equipment" fications, shall be adjusted and calibrated at predetermined intervals,    Paragraph 3.1                          Slightly different wording. Same intent based on equipment stability and use,                                            and effect.
against certified equipment having        Measuring and test equipment shall known valid relationships to nationally   be calibrated, adjusted and recognized standards.                     maintained at prescribed intervals or, prior to use, against certified equipment having known valid rela-tionships to nationally recognized standards.
If no national standards exist, the basis Supplement 12S-1 "Supplementary        OK for calibration shall be documented.       Requirements for Control of Measuring and Test Equipment" Paragraph 3.1 If no nationally recognized standards exist, the bases for calibration shall be documented.
Records of calibrations shall be          Supplement 12S-1 "Supplementary        Slightly different words, but same maintained and equipment suitably         Requirements for Control of            intent.
marked so that the calibration status     Measuring and Test Equipment" can be determined.
Paragraph 5 Records shall be maintained and equipment shall be suitably marked to indicate calibration status.
Records of calibration shall be                                                  These words not in NQA-1 included in inspection and test results where applicable.
Measures shall be taken to assure         Supplement 12S-1 "Supplementary        Slightly different words, but same proper handling, storage, and care of      Requirements for Control of            intent.
the measuring and test equipment           Measuring and Test Equipment" after calibration in order to maintain the required accuracy of such equipment.       Paragraph 4 Measuring and test equipment shall be properly handled and stored to maintain accuracy.
When measuring and test equipment is       Supplement 12S-1 "Supplementary        NQA-1 does not include the word found to be out of calibration, an         Requirements for Control of            "mechanical" and "since the last evaluation shall be made of the validity   Measuring and Test Equipment"          calibration check".
of previous inspection or test results and the acceptability of mechanical        Paragraph 3.2                          Slightly different wording. Same intent items inspected or tested since the last                                          and effect.
calibration check.                         When measuring and test equipment is found to be out of calibration, an evaluation shall be made and documented of the validity of previous inspection or test results and the acceptability of items previously inspected or tested.
Where necessary to determine the.          4.1 Planning                           The effect of the 4.1 requirements is to acceptability of items or data, the        A plan shall be developed outlining    establish the necessity and methods required original inspections or tests or  the work to be performed and the       for such inspections or tests ifthey are applicable portions thereof shall be       work procedures or instructions        deemed to be required.
repeated using properly calibrated         required to comply with the equipment. In the event that the status    requirements of the defined work of equipment precludes using the           scope.
originally specified methods,              Planning shall include a review of the equipment or procedures, alternate         structure, system or component inspections or tests agreeable to the      design/procurement specifications, 9 of 24                                                7/27/10

Enclosure 4, Table 6 ANSI N45.2.8-1975 vs NQA-1-1994, Subpart 2.8 materials, lists, drawings, used.                                      construction work plans, and schedules to ensure that fabrication, installation, modification, inspection, testing, etc., activities have been incorporated; that the work can be accomplished as specified; and that time and resources, plus training, are sufficient to accomplish the work in accordance with the specified requirements.
Planning shall define the operations to be performed, the systematic sequential progression of operations,
                                            -and the overall measures to be employed to preserve the quality of the work.
2.9 Prerequisites                          2.2 Prerequisites                        OK The following minimum conditions shall     The following minimum conditions have been met or evidence thereof          shall have been met, or evidence shall be available as applicable before    thereof shall be available as appli-the requirements set forth in this         cable, before the requirements set standard are applied:                      forth in Subpart 2.8 are applied.
: a. Qualification of individuals,           (a) Qualification of individuals,        OK organizations and procedures have          organizations, and procedures have been completed in accordance with the      been completed in accordance with requirements of applicable codes and       the requirements of applicable codes standards,                                 and standards.
: b. Systems have been designed and           (b) Systems have been designed          OK engineered in accordance with               and engineered in accordance with applicable codes, standards and             applicable codes, standards, and specifications,                            specifications.
: c. Materials have been selected and        (c) Materials have been selected         OK equipment has been fabricated and           and equipment has been fabricated assembled in accordance with the            and assembled in accordance with design specifications and the               the design specifications and the applicable published codes and              applicable published codes and standards, the conformance to which         standards ,the conformance to which has been demonstrated by the               has been demonstrated by the responsible organization,                  responsible organization.
: d. Engineering limitations, as              (d) Engineering limitations, as          OK applicable, have been incorporated in       applicable, have been incorporated in the procedures and instructions. These      the procedures and instructions.
limitations and requirements shall         These limitations and requirements include, as a minimum, installation,        shall include, as a minimum, testing, and on-site fabrication            installation, testing, and on-site processes such as cleaning, welding,        fabrication processes such as nondestructive examination and              cleaning, welding, nondestructive parameters such as pressure, flow,          examination, and parameters such as speed, load limits (static and dynamic),    pressure, flow, speed, load limits travel limits, physical clearances,         (static and dynamic), travel limits, control and alarm settings, en-             physical clearances, control and vironmental and thermal limits which        alarm settings, and environmental are included in design specifications,      and thermal limits, which are included manufacturer's data sheets, instruction     in design specifications, manual and design reports.                  manufacturer's data sheets, instruction manual, and design reports.
: e. To substantiate (b) and (c) above,       (e)          To substantiate (b) and (c) N45.2.8 uses the term "construction the following documents relating to the     above, the following documents           site" whereas NQA-1 uses the term specific stage of installation activity for relating to the specific stage of        "work site". Same intent and effect.
the item shall be available at the con-     installation activity for the item shall struction site:                             be available at the work site:
(1)       The latest applicable approved-   (1)          the latest applicable       OK for-construction drawings.                  approved-for construction drawings 10 of 24                                               7/27/10

Enclosure 4, Table 6 ANSI N45.2.8-1975 vs NQA-1-1994, Subpart 2.8 instructions,                                 instructions (4)       Installation procedures.           (4)          installation procedures        OK (5)       Evidence of compliance by           (5)         evidence of compliance by      OK manufacturer with purchase                    manufacturer with purchase requirements, including quality assur-        requirements, including quality assur-ance requirements.                           ance requirements (6)       Evidence that engineering or       (6)          evidence that engineering      OK design changes are documented and            or design changes are documented approved prior to installation,              and approved prior to installation (7) Records of inspections and tests          (7)         records of inspections and     OK during on-site receiving, storage and        tests during on-site receiving, handling.                                     storage, and handling (8) Release of mechanical items for           (8)         release of mechanical          OK installation,                                 items for installation (9) Evidence that nonconformances             (9) evidence that nonconformances          OK have been satisfactorily resolved or          have been satisfactorily resolved or controlled.                                   controlled
: 3. PRE-INSTALLATION                           3 PREINSTALLATION                          OK VERIFICATION                                  VERIFICATION 3.1 General                                   3.1 General Prior to the actual Prior to the actual installation of          installation of mechanical items, there mechanical items, there are certain          are certain preliminary inspections, preliminary inspections, checks and          checks, and similar activities that similar activities that shall be             shall be completed to verify that the completed to verify that the item and        item and the installation area conform the installation area conform to             to specified requirements, and the specified requirements and the               necessary resources are available to necessary resources are available to         assure that the quality of the assure that the quality of the               mechanical item will be maintained as mechanical item will be maintained as        the installation proceeds.
the installation proceeds.
The quality requirements and quality          The quality requirements and quality       OK assurance actions that are necessary          assurance actions that are necessary during installation shall be reviewed         during installation shall be reviewed and planned so that they are                  and planned so that they are understood by responsible individuals,       understood by responsible individuals.
3.2 Identification                            3.2     Identification                     OK Checks shall be made to verify that the       Checks shall be made to verify that identity of received mechanical              the identity of received mechanical materials and equipment has been             materials and equipment has been maintained and is in accordance with         maintained and is in accordance with the latest approved-for-construction          the latest approved-for-construction drawings, equipment lists,                   drawings, equipment lists, specifications and established               specifications, and established procedures.                                 procedures.
If these checks disclose apparent loss       Ifthese checks disclose apparent           OK of identification, the identity shall be     loss of identification, the identity shall reaffirmed prior to release for              be reaffirmed prior to release for installation,                                installation.
Checks shall be made to verify that a        Checks shall be made to verify that a      OK control system for maintaining               control system for maintaining identification of mechanical items           identification of mechanical items throughout installation has been              through installation has been established including provisions for         established, including provisions for control of substitution or exchange of       control of substitution or exchange of equipment or materials,                      equipment or materials.
The procedures for control of                The procedures for control of              OK identification shall provide a system of     identification shall provide a system traceability to drawings, specifications     of traceability to drawings, or other records when identification or       specifications, or other records when 11 of 24                     7/27/10

Enclosure 4, Table 6 ANSI N45.2.8-1975 vs NQA-1 -1994, Subpart 2.8
 ,I'l'.. i'  II.W U- U- U..... '            luCl ILIIIl,O*LIUI UI I Ilal P.11 I*:O{ I UOLI UA removed from an item.                    destroyed, hidden, or removed from an item.
3.3 Processes and Procedures             3.3 Processes and Procedures                    OK Consistent with the construction         Consistent with the construction activities schedule, inspections or      activities schedule, inspections, or checks shall be performed to verify      checks shall be performed to verify that processes and procedures are        that processes and procedures are ready when needed for use in the         ready when needed for use in the installation of mechanical items.        installation of mechanical items.
These inspections or checks shall        These inspections or checks shall               OK include, but not be limited to the       include, but not be limited to, the following verifications:                 following verifications.
: a. Approved procedures, drawings,        (a) Approved procedures, drawings,              OK manuals or other work instructions are   manuals, or other work instructions provided to the installer at the         are provided to the installer at the construction site.                       work site.
: b. Special instructions and checklists   (b) Special instructions and                    OK as required are available at the         checklists as required are available at installation area or attached to the     the installation area or attached to item.                                    the item.
: c. Approved procedures and               (c) Approved procedures and                     OK instructions for special processes such  instructions for special processes as coating, welding, heat treating and   such as coating, welding, heat nondestructive examination are           treating, and nondestructive available at the site.                   examination are available at the site.
: d. Where applicable, personnel,          (d) Where applicable, personnel,                OK procedures and instructions shall have   procedures, and instructions shall been qualified through the preparation   have been qualified through the of workmanship standards, samples,       preparation of workmanship or mockups that simulate actual job      standards, samples, or mockups that conditions,                              simulate actual job conditions.
: e. Installation preparations have been   (e) Installation preparations have              OK completed, including such tasks as       been completed, including such tasks removal of packaging, conditioning,      as removal of packaging, condi-cleaning, and preliminary positioning. tioning, cleaning, and preliminary positioning.
: f. Jigs, fixtures and equipment for      (f0 Jigs, fixtures, and equipment for           OK special processes, if required, are      special processes, if required, are available at the site and conform to     available at the site and conform to specified requirements.                  specified requirements.
: g. Equipment for handling and             (g) Equipment for handling and                  OK placement of mechanical items is         placement of mechanical items is available at the site and is adequate to  available at the site and is adequate perform the work in accordance with      to perform the work in accordance specified requirements.                   with specified requirements.
: h. Warnings and safety notices,           (h) Wamings and safety notices                  OK appropriate to the activity, are posted. appropriate to the activity are posted.
3.4 Physical Condition                    3.4 Physical Condition                          OK Inspections or checks as appropriate     Inspections or checks, as shall be performed to verify that         appropriate, shall be performed to mechanical items at the installation are  verify that mechanical items at the in accordance with the specified re-      installation are in accordance with the quirements and that quality has been      specified requirements and that maintained,                               quality has been maintained.
These inspections or checks shall         These inspections or checks shall               OK include, but not be limited to, the       include, but not be limited to, the following verifications:                  following verifications.
: a. Protective measures and physical       (a) Protective measures and physical            OK integrity during storage have been        integrity during storage have been maintained in conformance with            maintained in conformance with specified requirements.                   specified requirements.
12 of 24                       7/27/10

Enclosure 4, Table 6 ANSI N45.2.8-1975 vs NQA-1 -1994, Subpart 2.8 ANSI N45.2.8          - 1975         NQA-1 (1994) Subpart 2.8 ~                          Commenets (except where noted)             (NOTE: OK signifies kdentical or
_             _            _           _          _            _            _nearly                identical wording)     *
: b. Nonconformances have been                (b) Nonconformances have been            OK satisfactorily dispositioned or             satisfactorily dispositioned or controlled,                                 controlled.
: c. Items have been cleaned in               (c) Items have been cleaned in           OK accordance with specified                   accordance with specified requirements.                               requirements.
3.5 Site Conditions                         3.5 Site Conditions                      OK Inspections or checks as appropriate       Inspections or checks, as shall be performed to verify that           appropriate, shall be performed to conditions of the installation area         verify that conditions of the conform to specified requirements and      installation area conform to specified precautions have been taken to             requirements and precautions have prevent conditions that will adversely     been taken to prevent conditions that affect the quality of the item during      will adversely affect the quality of the installation,                              items during installation.
These inspections or checks shall          These inspections or checks shall        OK include, but not be limited to, the        include, but not be limited to, following to verify that:                  verification of the following.
: a. Protection from adjacent                (a) Protection from adjacent             OK construction activities being provided     construction activities is being including implementation of appro-          provided, including implementation of priate exclusion and area cleanness        appropriate exclusion and area requirements.                               cleanness requirements.
: b. Protection from inclement weather        (b) Protection from inclement           OK and other ambient conditions adverse       weather and other ambient conditions to quality is being provided,               adverse to quality is being provided.
: c. Materials that may be deleterious        (c) Materials that may be               OK to the mechanical items being               deleterious to the mechanical items installed, are controlled,                  being installed are controlled.
: d. Installation of the mechanical item      (d) Installation of the mechanical      OK will not adversely affect the               item will not adversely affect the subsequent installation of materials        subsequent installation of materials and equipment and that repair or            and equipment, and repair or rework rework on any nonconforming items           on any nonconforming items can be can be performed satisfactorily.            performed satisfactorily.
: e. Nonconformances for adjacent             (e) Nonconformances for adjacent        OK items have been dispositioned or            items have been dispositioned or controlled,                                 controlled.
: f. Adequate permanent or approved           (0 Adequate permanent or                OK temporary supports and mountings            approved temporary supports and have been installed that will properiy      mountings have been installed that interface with the mechanical item.         will properly interface with the mechanical item.
: g. Mating parts such as couplings           (g) Mating parts such as couplings      OK and flanges are properiy positioned         and flanges are properly positioned and conditioned,                            and conditioned.
: h. Servicing or maintenance activity        (h) Servicing or maintenance activity   OK related to installation has been            related to installation has been performed.                                  performed.
: 4. CONTROL DURING                          4 CONTROL DURING                         NQA-1 uses "Checking, inspection, INSTALLATION PROCESS                        INSTALLATION PROCESS                    and examination of testing..." This is considered to be a typographical error.
4.1 General                                4.1    General Checking, inspection, examination or        Checking, inspection, and testing activities shall be performed       examination of testing activities shall during the installation of mechanical       be performed during the installation items to assure that the required           of mechanical items to assure that quality is being obtained in accordance     the required quality is being obtained with prescribed procedures.                 in accordance with prescribed proce-dures.
13 of 24                                               7/27/10

Enclosure 4, Table 6 ANSI N45.2.8-1975 vs NQA-1 -1994, Subpart 2.8 systematic manner to assure                a systematic manner to assure surveillance thoughout the installation    surveillance throughout the process.                                   installation process.
A procedure shall be provided for the      A procedure shall be provided for the   OK coordination and sequencing of these       coordination and sequencing of these activities at established inspection       activities at established inspection points in successive stages of             points in successive stages of installation,                              installation.
A method shall be implemented to           A method shall be implemented to        OK assure that engineering and design         assure that engineering and design changes are documented and                 changes during installation are controlled during installation,            documented and controlled.
4.2 Process and Procedure Control          4.2 Process and Procedures              OK Control Checks shall be made .to verify that a     Checks shall be made to verify that a   OK system of controls has been                system of controls has been established and is being maintained at     established and is being maintained the construction site to assure the        at the construction site to assure the following:                                 following.
: a. The applicable revision of approved     (a) The applicable revision of          OK procedures, drawings and instructions      approved procedures, drawings, and are being followed,                        instructions is being followed.
: b. Qualified and approved processes,        (b) Qualified and approved             OK materials, tools and other equipment        processes, materials, tools, and other are being used by qualified personnel.      equipment are being used by quali-fied personnel.
: c. The status of installation,              (c) The status of installation,        OK inspections, examinations or tests is       inspections, examinations, or tests is clearly indicated or identified in in-      clearly indicated or identified in in-spection records.                           spection reports.
: d. The installation, inspection and         (d) The installation, inspection, and  OK testing sequence is being maintained,       testing sequences are being maintained.
: e. Identification, appropriate              (e) Identification, appropriate        N45.2.8 uses term "are being segregation, and disposition of             segregation, and disposition of        controlled" whereas NQA-1 uses term nonconforming items are being              nonconforming items are being main-    "are being maintained".
controlled.                                tained.
Differently worded. Same intent and effect.
: f. "As-built" information is being          (f) As-built information is being      OK processed.                                 processed.
: g. Inspection and test reports are          (g) Inspection and test reports are    OK current, accurate and complete.            current, accurate, and complete.
4.3 Examination                             Supplement 9S-1 "Supplementary         N45.2.8 provides examples of Requirements forControl of             nondestructive examinations.
Nondestructive examinations, when          Processes" required, shall be performed to                                                   Same intent and effect.
approved applicable procedures. Ex-         Paragraph 3 amples of these examinations are liquid penetrant, magnetic particle,       Each special process shall be ultrasonic, eddy current and radi-         performed in accordance with ography.                                   appropriate instructions which include or reference procedure, personnel, and equipment qualification requirements.
4.4 Inspection                             4.3        Inspection                   OK Inspections of the work areas and the      Inspections of the work areas and the work in progress shall be performed to      work in progress shall be performed verify that mechanical items are being     to verify that mechanical items are located, installed, assembled or con-      being located, installed, assembled, nected in compliance with the latest       or connected in compliance with the
                                                            .14 of 24                                            7/27/10

Enclosure 4, Table 6 ANSI N45.2.8-1975 vs NQA-1-1994, Subpart 2.8 JlVOJ vv  I   Iu-
                - AvI C..
U U*LLRJ JI a aVVIIII*O,    ICLUCI. 0 1
Jj  tJV0U-IU.~XI-C lLlbil manufacturers' instructions, codes,             drawings, manufacturer's installation instructions and                   instructions, and procedures.
orocedures.
Inspections performed shall include as          Inspections performed shall include           OK appropriate, but not be limited to, the          as appropriate, but not be limited to, following:                                       the following:
: a. Identification.                               (a) identification                            OK
: b. Location and orientation of                  (b) location and orientation of               OK components.                                      components
: c. Leveling and alignment.                       (c) leveling and alignment                    OK
: d. Clearances and tolerances.                    (d) clearances and tolerances                 OK
: e. Tightness of connections and                  (e) tightness of connections and              OK fastenings.                                      fastenings
: f. Fluid levels and pressures.                   (f) fluid levels and pressures                OK
: g. Absence of leakage.                           (g) absence of leakage                        OK
: h. Physical integrity.                          (h) physical integrity                        OK
: i. Cleanness.                                   (i) cleanness                                 OK
: j. Welding operations including                  0() welding operations, including             OK materials and process controls,                 materials and process controls, adequate purging, and the removal of             adequate purging, and the removal of purge dams on completion,                        purge dams on completion
: k. Adequacy of protective measures to            (k) adequacy of protective measures           OK assure that the item will not be                 to assure that the item will not be damaged during installation,                     damaged during installation I. Adequacy of housekeeping, barriers            (I) adequacy of housekeeping,                 OK and protective equipment to assure               barriers, and protective equipment to that items will not be damaged or                assure that items will not be contaminated as a result of adjacent             damaged or contaminated as a result construction activities,                         of adjacent construction activities 4.5 Installation Checks                          4.4 Installation Checks                       OK Checks shall be performed to verify              Checks shall be performed to verify that mechanical items have been                  that mechanical items have been correctly installed and will function            correctly installed and will function properly so that the initial starting of         properly so that the initial starting of items and preoperational testing can             items and preoperational testing can proceed with a minimum amount of                 proceed with a minimum amount of problems and delays.                             problems and delays.
If construction or associated activity           If construction or associated activity        OK affects the results of these checks, the         affects the results of these checks, checks shall be repeated if necessary            the checks shall be repeated, if to assure that the quality has not been          necessary, to assure that the quality adversely affected.                              has not been adversely affected.
These activities shall include as                These activities shall include as             OK appropriate, but not be limited to, the          appropriate, but not be limited to, the following:                                       following.
: a. Checkout procedures are prepared              (a)
* Checkout procedures are         OK and approved to verify correctness of            prepared and approved to verify installation and ability to function,            correctness of installation and ability to function.
: b. Proper greasing or lubrication has            (b)            Proper greasing or             OK been completed.                                  lubrication has been completed.
: c. Lubricating and cooling water                 (c)            Lubricating and cooling        OK systems are in service,                          water systems are in service.
: d. Protection strainers are installed            (d)            Protection strainers are       OK where necessary.                                 installed where necessary.
: e. Rotation of prime movers is correct.          (e)            Rotation of prime movers is    OK correct.
: f. Electrical circuits, controls and relay       (0             Electrical circuits, controls, OK settings are correct.                            and relay settings are correct.
: g. Phasing of electrical busses is               (g)            Phasing of electrical buses    OK correct.                                         is correct.
: h. Instrumentation is calibrated and in          (h)            Instrumentation is             OK 15 of 24                    7/27/10

Enclosure 4, Table 6 ANSI N45.2.8-1975 vs NQA-1-1994, Subpart 2.8
: j. Casings, reservoirs, etc. are primed,   0)          Casings, reservoirs, etc.,  OK vented and filled,                         are primed, vented, and filled.
: k. Proper communications are               (k)         Proper communications       OK established for control,                   are established for control.
I. Tags are issued, where appropriate,     (I)         Tags are issued, where      OK for isolationand control.                  appropriate, for isolation and control.
: m. Piping system alignment is correct.     (M)         Piping system alignment is  OK correct.
: n. Pipe hanger placement is correct        (n)         Pipe hanger placement is    OK and hangers will function properly.        correct and hangers will function properly.
: o. Seismic anchors and restraints are      (o)         Seismic anchors and         OK properly installed.                        restraints are properly installed.
: p. Valve glands and packing are            (p)         Valve glands and packing    OK installed,                                 are installed.
: q. Pneumatic lines have been blown.        (q)         Pneumatic lines have been   OK blown.
: r. Valve stroking, actuation and           (r)         Valve stroking, actuation,  OK settings are proper.                       and settings are proper.
: s. Pump seals andpacking are               (s)         Pump seals and packing      OK properly installed,                        are properly installed.
: t. Limit switches, interlocks and stops    (t)         Limit switches, interlocks, OK are properly adjusted and set.             and stops are properly adjusted and set.
4.5.1 Cleaning. Installed systems and      4.4.1 Cleaning. Installed systems       N45.2.8 states according to the components shall be cleaned, flushed       and components shall be cleaned,        requirements of ANSI N45.2.1 and conditioned according to the           flushed, and conditioned according to   whereas NQA-1 states according to requirements of ANSI N45.2.1. Special     applicable requirements. Special        applicable requirements.
attention shall be given to the following  attention shall be given to the requirements:                              following requirements.                 See 2.4 above.
: a. Chemical Conditioning.                  (a) Chemical Conditioning.              OK Procedures shall be prepared including     Procedures shall be prepared the scope, acceptance criteria, se-        including the scope, acceptance quence, temperatures, soak periods         criteria, sequence, temperatures, and neutralizing solutions to be used. soak periods, and neutralizing solutions to be used.
Checks shall be made to verify            Checks shall be made to verify that     OK that the proper chemicals at the           the proper chemicals at the designated strength and temperature       designated strength and temperature are being used in the conditioning        are being used in the conditioning operations                                operations.
Other operations shall be performed as    Other operations shall be performed     OK specified in Paragraph 4.5.1.c.           as specified in (c) below.
: b. Flushing.Procedures shall be           (b) Flushing.Procedures shall be        OK prepared including routes, boundaries,    prepared including routes, velocities and acceptance criteria,       boundaries, velocities and restoration, and layup for high integrity acceptance criteria, restoration, and systems where appropriate.                layup for high integrity systems, where appropriate.
Checks shall be made to verify that       Checks shall be made to verify that     OK mechanical items are being flushed in     mechanical items are being flushed accordance with specified                 in accordance with specified requirements so that contaminants or      requirements so that contaminants or flow velocities will not adversely affect  flow velocities will not adversely subsequent operations.                    affect subsequent operations.
Other operations shall be performed as    Other operations shall be performed     OK specified in Paragraph 4.5.1 .c.          as specified in (c) below.
: c. ProcessControls. Checks shall          (c) Process Controls.Checks shall       OK be performed to verify that controls are  be performed to verify that controls functioning for the following:            are functioning for the following:
(1) Removal and installation of parts or   (1) removal and installation of parts   OK 16 of 24                                              7/27/10

Enclosure 4, Table 6 ANSI N45.2.8-1975 vs NQA-1-1994, Subpart 2.8 UI 1A..II I   jJJ~ 1
                                                            , I tO OU*I   I001* II IOO1 III 4
orifice plates and valve internals that    devices, orifice plates, and valve are removed from the system to             internals that are removed from the L hf-m       tn f    ,       fl_                 _ilif_  _      _ __hin_         _
(2) Installation and removal of            (2) installation and removal of                  OK temporary strainers, blind flanges, and    temporary strainers, blind flanges, piping:                                   and piping; (3) Isolation of sensitive                 (3) isolation of sensitive                       OK instrumentation,                          instrumentation; (4) Water and chemical quality.            (4) water and chemical quality;                  OK (5) Acceptance data, specimens, or        (5) acceptance data, specimens, or               OK progressive samples if required.          progressive samples, if required.
Where appropriate for disassembly          Where appropriate for disassembly                OK and reassembly of components,              and reassembly of components, procedures or instructions shall be       procedures or instructions shall be prepared or manufacturer's technical      prepared or manufacturer's technical manuals shall be used to assure           manuals shall be used to assure adherence to match marks, protection       adherence to match marks, of seats and proper reassembly and to      protection of seats, and proper preclude damage to the component.          reassembly and to preclude damage to the component.
4.5.2 Pressure Testing. Checks             4.4.2 Pressure Testing. Checks                   OK shall be made to verify that mechanical    shall be made to verify that items are being pressure tested in         mechanical items are being pressure accordance with specified                  tested in accordance with specified requirements to assure that the            requirements to assure that the strength and integrity of the installed    strength and integrity of the installed systems or portions thereof conform to     systems or portions thereof conform specified requirements.                    to specified requirements.
The purpose of the test, scope, test       The purpose of the test, scope, test             OK boundary, duration for inspection,         boundary, duration for inspection, acceptance criteria, restoration, and      acceptance criteria, restoration, and layup shall be clearly established and     layup shall be clearly established and documented.                                documented.
Checks shall include, but not be limited   Checks shall include, but not be                 OK to, the following:                         limited to, the following.
: a. Appropriate pressures,                  (a) Appropriate pressures,                       OK temperatures, water chemistry, and         temperatures, water chemistry, and pressure test cycles are established,      pressure test cycles are established.
: b. Sufficient time at test pressure is     (b) Sufficient time at test pressure is          OK specified to determine acceptance          specified to determine acceptance.
: c. Provisions are available to protect     (c) Provisions are available to protect          OK and isolate instrumentation during         and isolate instrumentation during hydrostatic testing.                       hydrostatic testing.
: d. Items external to test boundary are     (d) Items external to test boundary              OK protected to prevent inadvertent           are protected to prevent inadvertent overpressurization.                        overpressurization.
: e. Relief devices are controlled to        (e) Relief devices are controlled to             OK prevent system overpressurization.         prevent system overpressurization.
: f. Gagging and ungagging of relief         (0) Gagging and ungagging of relief              OK valves,                                    valves.
: g. Piping and equipment supports have      (g) Piping and equipment supports                OK hydrostatic pins installed where           have hydrostatic pins installed where applicable for testing and removed         applicable for testing and are to be upon completion of testing.                removed upon completion of testing.
(h) Evidence of calibration of test              These words are not included in gages.                                           N45.2.8 4.6    Care of Items                       4.5 Care of Items                                OK Items on which inspection and testing      Items on which inspection and testing activities are being performed shall be    activities are being performed shall protected from personnel traffic,          be protected from personnel traffic, weather, and adjacent construction         weather, and adjacent construction activities such as sandblasting, acid      activities such as sandblasting, acid cleaning, welding, jack hammering,         cleaning, welding, jack hammering, 17 of 24                                               7/27/10

Enclosure 4, Table 6 ANSI N45.2.8-1975 vs NQA-1-1994, Subpart 2.8 chipping, burning and stress relieving that would adversely affect the quality    relieving, which would adversely of the item or test results.               affect the quality of the item or test results.
Such protection shall be provided          Such protection shall be provided        OK through good cleanliness and               through good cleanliness and housekeeping practices, temporary          housekeeping practices, temporary packaging, erection of barriers,           packaging, erection of barriers, protective covers, and walkways as         protective covers, and walkways, as required in accordance with                required.
Subsection 2.6.
Temporary use of equipment or              Temporary use of equipment or            OK facilities to which this standard applies  facilities to which this Part applies that are to become part of the             that are to become part of the com-completed project may be desirable.        pleted project may be desirable.
Authorization for such usage shall be      Authorization for such usage shall be    OK as provided for in the contract or by      as provided for in the contract or by written approval from the responsible      written approval from the responsible organization,                              organization.
Such temporary use shall not subject       Such temporary use shall not subject     OK the equipment or systems to conditions     the equipment or systems to for which they were not designed.          conditions for which they were not designed.
The temporary use authorization shall      The temporary use authorization          OK include:                                   shall include:
(1)conditions of use or operation;          (a) conditions of use or operation;     OK.
(2) maintenance requirements; and           (b) maintenance requirements; and       OK (3) inspections and tests as required to   (c) inspections and tests as required    OK maintain operability and quality during    to maintain operability and quality period of temporary use of the item.       during the period of temporary use of item.
When temporary use is completed,           When temporary use is completed,         NQA-1 adds the word "most".
conditions of temporary use shall be       conditions of temporary use shall be evaluated to verify that the permanent     evaluated to verify that the plant equipment continues to satisfy        permanent plant equipment the specified requirements.                 continues to satisfy the most specified requirements.
: 5.        INSTALLED SYSTEMS                5 INSTALLED SYSTEMS                      OK INSPECTION AND TESTS                       INSPECTION AND TESTS 5.2 General                                5.1 General Following the installation of mechanical    Following the installation of items, the checking, inspection; and        mechanical items, the checking testing activities shall be performed to    inspection and testing activities shall verify that the completed systems are       be performed to verify that the in conformance with specified              completed systems are in requirements.                              conformance with specified requirements.
This is a final verification that the      This is a final verification that the    OK requirements defined by licensing           requirements defined by licensing commitments, drawings, specifications      commitments, drawings, and other contract documents are           specifications, and other contract reflected in the completed installation,   documents are reflected in the completed installation.
It is also a time to verify that field      It is also a time to verify that field  OK modifications and other changes made       modifications and other changes and controlled during installation,        made and controlled during activities have been incorporated in the   installation activities have been "as-built" documents.                      incorporated in the as-built documents.
Controls shall be provided for the         Controls shall be provided for the       OK 18 of 24                                            7/27/10

Enclosure 4, Table 6 ANSI N45.2.8-1975 vs NQA-1-1994, Subpart 2.8 identification, documentation, and resolution of nonconformances                resolution of nonconformances di'~rln~qn hvj in.onr.tionn' or tp'.qt.*     di.wnlns*rd hv insne~ctions or tests.
Tests shall be conducted on completed        Tests shall be conducted on              OK plant systems.                               completed plant systems.
Test procedures shall identify               Test procedures shall identify           OK prerequisites for system testing             prerequisites for system testing, including required completed construc-       including required completed con-tion activities.                             struction activities.
The test procedure shall identify and        The test procedures shall identify and   OK describe any temporary or simulated          describe any temporary or simulated condition or equipment.                      condition or equipment.
If not previously planned, a                 If not previously planned, a             OK documented notice shall be prepared          documented notice shall be prepared and issued with approval of the              and issued with approval of the responsible organization stating the         responsible organization stating the substitutions that existed for the test. substitutions that existed for the test.
Written verification shall also be           Written verification shall also be       OK provided that temporary installations        provided that temporary installations have been satisfactorily replaced by         have been satisfactorily replaced by the permanent installations,                 permanent installations.
Checks and inspections shall be              Checks and inspections shall be          OK performed to verify the operational         performed to verify the operational readiness and completeness of coin-         readiness and completeness of com-ponents and systems. These systems          ponents and systems. These or partial systems shall be identified,      systems or partial systems shall be tagged and released for operational          identified, tagged, and released for testing.                                     operational testing.
These checks and inspections shall be       These checks and inspections shall       OK performed to verify the following as a      be performed to verify the following, minimum:                                    as a minimum.
: a. Equipment and materials have not         (a) Equipment and materials have         OK sustained external physical damage.         not sustained external physical damage.
: b. The installation has been made in         (b) The installation has been made      OK accordance with specified                    in accordance with specified requirements.                                requirements.
: c. All nonconforming items have              (c) All nonconforming items have        OK been satisfactorily dispositioned.           been satisfactorily dispositioned.
: d. Internal and external restrictions        (d) Internal and external restrictions  OK and obstructions to flow and full travel    and obstructions to flow and full have been removed,                          travel have been removed.
: e. Supports and restraints are              (e) Supports and restraints are          OK properly installed.                          properly installed.
: f. Interfacing connections with              (f0) Interfacing connections with       OK adjacent systems are compatible.            adJacent systems are compatible.
: g. Original materials and component          (g) Original materials and              OK identification has been preserved with       component identification have been provisions for traceability throughout       preserved with provisions for trace-the installed systems.                       ability throughout the installed systems.
: h. Safety features such as interlocks,       (h) Safety features such as             OK cable separation, guards, warning            interlocks, cable separations, guards, devices, and lockouts have been             warning devices, and lockouts have installed, are being used and comply         been installed, are being used, and with applicable codes and regulations,       comply with applicable codes and regulations.
: i. Temporary connections such as             (i) Temporary connections, such as      OK jumpers and bypass lines and                jumpers and bypass lines, and temporary trip points of control equip-      temporary trip points of control ment are identified and documented so        equipment are identified and that their final condition can be verified,  documented so that their final condition can be verified.
: j. System water chemistry is                 (I) System water chemistry is           OK appropriate for operational testing.         appropriate for operational testing.
19 of 24                   7/27/10

Enclosure 4, Table 6 ANSI N45.2.8-1975 vs NQA-1-1994, Subpart 2.8 re.u.. ets..      have b...en
                            -.. aintai reauirements have been maintained.            reauirements have been maintained.
I. Permits and authorizations have            (I) Permits and authorizations have    OK been obtained,                                been obtained.
5.3 Preoperational Testing                    5.2 Preoperational Testing             OK This testing involves the operation of        This testing involves the operation of all items in a system, partial systems        all items in a system(s) or partial or systems to assure that operation is        system(s) to assure that operation is in accordance with the design criteria        in accordance with the design criteria and functional requirements. The              and functional requirements. The testing shall include, but not be limited      testing shall include, but not be to, the following:                             limited to, the following:
: a. Systems integrity.                         (a) systems integrity;                 OK
: b. In-line instrument installation is         (b) in-line instrument installation is OK consistent with specified flow         consistent with specified flow directions.                            directions;
: c. Sensing lines are phased                   (c) sensing lines are phased           OK correctly to in-line elements and      correctly to in-line elements and sensors.                               sensors;
: d.      Service requirements for initial       (d) service requirements for initial   OK operation such as flow alignment,       operation such as flow alignments, limiting flow orificing and relief     limiting flow orificing, and relief devices have been performed.            devices have been performed;
: e.      Operation of controls, valves,         (e) operation of controls, valves,     OK dampers, operators, and load            dampers, operators, and load limiting limiting devices.                      devices;
: f.      Rotating equipment (motors,            (f) rotating equipment (motors,        OK pumps, blowers)- rotation,             pumps, blowers), rotation, speed, speed, vibration, noise, and no-        vibration, noise, and no-load opera-load operation.                        tion;
: g.      Handling equipment-load tests          (g) handling equipment (load tests of  OK of cranes, hoists, conveyors,           cranes, hoists, conveyors, hooks, hooks, and handling adaptors,           handling adapters, and accessories);
and accessories.
: h. Containment systems.                        (h) containment systems;               OK
: i. Air handling systems.                   (i) air handling systems;              OK
: j. Fuel storage and handling                 ") fuel storage and handling         OK systems.                                systems;
: k. Reactor components handling             (k) reactor component handling         OK systems.                                systems;
: 1.      Instrument air systems.                (I) instrument air systems;            OK
: m. Fluid service systems.                      (m) fluid service systems;             OK
: n. Waste effluent systems.                     (n) waste effluent systems;            OK
: o. Auxiliary building systems.                 (0) auxiliary building systems.        OK Where mechanical equipment and                 Where mechanical equipment and         OK systems interface with, and their              systems interface with, and their operation must coordinate with, non-           operation must coordinate with, non-mechanical equipment or systems, the           mechanical equipment or systems, test performed shall include verifying         the test performed shall include the compatibility of interfacing               verifying the compatibility of equipment and functions.                       interfacing equipment and functions.
For additional information on                                                         Guidance only. Wording does not inspections, tests and procedures, see                                                establish requirements.
Section 6 of ANSI N18.7.
5.4 Cold Functional Tests                      5.3     Cold Functional Tests          OK These tests follow preoperational              These tests follow preoperational testing of individual systems including        testing of individual systems, reactor coolant systems.                       including reactor coolant systems.
This testing shall be performed to             This testing shall be performed to     OK obtain operational data of equipment           obtain operational data of equipment with maximum allowable simultaneous            and maximum allowable operation of interfacing systems and           simultaneous operation of interfacing equipment and final verification of            systems and equipment, the final 20 of 24                                            7/27/10

Enclosure 4, Table 6 ANSI N45.2.8-1975 vs NQA-1-1994, Subpart 2.8 tunctional perrormance Ot tnese            verification of functional performance sYstems.                                   of these systems.
5.3.1 Reactor Coolant System               5.3.1 Reactor Coolant System              OK Hydrostatic Tests. As applicable to        Hydrostatic Tests. As applicable to the reactor system type, hydrostatic       reactor system type, hydrostatic tests tests to verify conformance to specified   to verify conformance to specified requirements when performed on the         requirements, when performed on the reactor coolant system, shall include      reactor coolant system, shall include all or parts of connected systems          all or parts of connected systems which cannot be isolated from the test     which cannot be isolated from the pressure.                                  test pressure.
The applicable test requirements are       The applicable test requirements are      OK contained in Section III of the Code.      contained in Section III of the ASME Boiler and Pressure Vessel Code.
5.3.2 Functional and Flow Testing.         5.3.2 Functional and Flow                 OK The required individual systems shall      Testing. The required individual be tested to demonstrate cold             systems shall be tested to functional operability of individual       demonstrate cold components, subsystems and                functional operability of individual systems, and to demonstrate               components, subsystems, and compatibility with other systems.         systems, and to demonstrate compatibility with other systems.
These tests, where appropriate, shall     These tests, where appropriate, shall     OK demonstrate the following:                demonstrate the following:
: a. System pressure drop.                   (a) system pressure drop                 OK
: b. Flow rate.                              (b) flow rate                            OK
: c. Controls and throttling device          (c) controls and throttling device       OK settings.                                  settings
: d. Function of interlocks, alarms and      (d) function of interiocks, alarms, and  OK automatic features.                        automatic features
: e. Instrument calibration.                (e) instrument calibration                OK
: f. Setting of meter biases.                (f) setting of meter biases              OK
: g. Systems stability.                      (g) system stability                     OK
: h. Adequacy of pipe and equipment          (h) adequacy of pipe and equipment       OK support settings.                          support settings
: i. Heat runs on rotating equipment.        (i) heat runs on rotating equipment      OK
: j. Adequacy of ventilation, lubrication     0) adequacy of ventilation,              OK and cooling systems under sustained        lubrication, and cooling systems operating conditions.                      under sustained operating conditions
: k. Ability to meet water chemistry         (k) ability to meet water chemistry      OK requirements.                              requirements 5.5 Hot Functional Tests                   5.4 Hot Functional Tests                 OK These tests are not applicable to BWR      These tests are not applicable to and HTGR nuclear plants because            BWR and HTGR nuclear plants these plants use nuclear heat to           because these plants use nuclear produce the system temperatures.           heat to produce the system temperatures.
Hot functional tests for PWR plants        Hot functional tests for PWR plants      OK follow cold functional tests and           follow cold function tests and simulate plant operating conditions at     simulate plant operating conditions at elevated temperatures and pressures.       elevated temperatures and pressures.
All auxiliary and support systems          All auxiliary and support systems        OK exclusive of those required for pre-       exclusive of those required for criticality resting must be available for  precriticality testing must be available these tests.                               for these tests.
If any of these systems are. not           If any of these systems is not           OK available, the responsible organization    available, the responsible shall specifically authorize exclusion of  organization shall specifically these systems or subsystems from           authorize exclusion of these systems testing and document those                 from testing and document those exceptions,                                exceptions.
These systems shall include the            These systems shall include the          OK 21 of 24                   7/27/10

Enclosure 4, Table 6 ANSI N45.2.8-1975 vs NQA-1-1994, Subpart 2.8
: a. oystem pressure arop.
: b. Flow rate.
: c. Controls and throttling device       (c) controls and throttling device      OK settinas.                            settinas
: d. Function of interlocks, alarms and  (d) function of interlocks, alarms,     OK automatic features.                  and automatic features
: e. Instrument calibration.                 (e) instrument calibration              OK
: f. Setting of meter biases.             (f) setting of meter biases             OK
: g. Systems stability.                  (g) system stability                    OK
: h. . Adequacy of pipe and equipment        (h) adequacy of pipe and equipment      OK support settings.                    support settings
: i. Heat runs on rotating equipment.     (i) heat runs on rotating equipment     OK
: j. Verification of heat exchanger       () verification of heat exchanger       OK performance.                         performance
: k. Verification of boron control        (k) verification of boron control       OK system performance.                  system performance I. Thermal insulation effectiveness.    (I) thermal insulation effectiveness    OK
: m. Set points of temperature,              (m) set points of temperature,          OK pressure and level devices,          pressure, and level devices
: n. System heatup tests.                    (n) system heatup tests                 OK
: o. System cooldown tests.              (0) system cooldown tests               OK
: p. Hot flow tests.                     (p) hot flow tests                      OK
: q. Setting protective devices.         (q) setting protective devices          OK
: r. Hot clearances.                     (r) hot clearances                      OK
: s. Vibration measurement of major          (s) vibration measurements of major     OK equipment and piping, as             equipment and piping, as applicable applicable.
: 6. DATA ANALYSIS AND                       6 DATA ANALYSIS AND                     OK EVALUATION                                 EVALUATION Procedures shall be established for        Procedures shall be established for processing inspection and test data        processing inspection and test data and their analysis, evaluation, and final  and their analysis, evaluation, and acceptance.                                final acceptance.
These procedures shall identify            These procedures shall identify         OK individuals or organizations               individuals or organizations responsible for the acquisition and        responsible for the acquisitions and reduction of inspection and test data      reduction of inspection and test data, and evaluation against acceptance          and evaluation against acceptance criteria, operating limits, and            criteria, operating limits, and performance standards.                     performance standards.
The data processing procedure should       The data processing procedure shall     OK provide for preliminary evaluation to      provide for preliminary evaluation to determine the validity of the inspection   determine the validity of the and test results, and the                  inspection and test results and the appropriateness of continuing the          appropriateness of continuing the in-inspection or test.                        spection or test.
The data shall be analyzed and             The data shall be analyzed and eval-    OK evaluated to verify completeness of        uated to verify completeness of results, achievement of inspection and     results, achievement of inspection test objectives, and operational           and test objectives, and operational proficiency of equipment and systems;      proficiency of equipment and to identify additional inspection or test  systems; to identify additional requirements or both; and to identify      inspection or test requirements or necessary changes to the installation      both; and to identify necessary inspection or test procedures.             changes to the installation inspection or test procedures.
Inspection and test results supported      Inspection and test results supported   OK by the inspection and test data,           by the inspection and test data, together with a report of data analysis    together with a report of data analysis and evaluation, shall be provides as       and evaluation, shall be provided as specified in Section 7.                    specified in Section 7.
: 7. RECORDS                                 7 RECORDS                               NQA-1 deleted the word "completed" 22 of 24                                            7127/10

Enclosure 4, Table 6 ANSI N45.2.8-1975 vs NQA-1-1994, Subpart 2.8 Record copies of completed                Record copies of procedures, procedures; reports; required             reports, required qualification       No effect - a record is defined as qualification records; test equipment     records, test equipment calibration   being properly completed and calibration records; test deviation or    records, test deviation or exception  authenticated.
exception records; and inspection,        records, and inspection, examination, examination and check records shall       and check records shall be prepared.
be prepared.
These shall be placed with other          These records shall be retained with  N45.2.8 uses word "placed" whereas project records as required by code,      other project records as required by  NQA-1 uses word "retained".
standard, specification or project        code, standard, specification, or procedures.                               project procedures.                   Same intent and effect.
Collection, storage and maintenance of                                          Guidance only. Wording does not quality assurance records shall be in                                           establish requirements.
accordance with ANSI N45.9.                                                                          QAPP 4.17 "Quality Assurance Records" establishes requirements.
: 8. REVISION OF AMERICAN                                                      NQA-1 includes applicable provisions NATIONAL STANDARDS                                                        of these standards. No corresponding REFERRED TO IN THIS                                                       provision in NQA-1 for addressing DOCUMENT                                                                  revisions is included or required.
When the following standards referred to in this document are superseded by a revision approved by the American National Standards Institute, the revi-sion is not mandatory until it has been incorporated as a part of this standard.
Revisions of the referenced standards, and revisions to this standard issued after the date of a specific contract invoking this standard may be used by mutual consent of the purchaser and the supplier.
N18.7-1972        Administrative Controls for Nuclear Power Plants N45.2-1971        Quality Assurance Program Require-ments for Nuclear Power Plants N45.2.1 -1973 Cleaning of Fluid Systems and Asso-ciated Components During the Con-struction Phase of Nuclear Power Plants N45.2.2-1972      Packaging, Shipping, Receiving, Storage and Handling of Items for Nuclear Power Plants (During the Construction Phase)
N45.2.3-1973      Housekeeping During the Construction Phase of Nuclear Power Plants N45.2-6-1973      Qualifications of 23 of 24                                                7/27/10

Enclosure 4, Table 6 ANSI N45.2.8-1975 vs NQA-1-1994, Subpart 2.8 inspecuion, :xami-nation and Testing Personnel for the Construction Phase of Nuclear Power Plants N45.2.9-1974  Requirements for Collection, Storage and Maintenance of Quality Assurance Records for Nuclear Power Plants N45.2.10-1973  Quality Assurance Terms and Definitions 24 of 24                      7/27/10}}