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Request to Change the Quality Assurance Program Description (QAPD)
	ML15212A718
Person / Time
Site:	Palo Verde
Issue date:	07/28/2015
From:	Lacal M; Arizona Public Service Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	102-07022 -MLL/JR
	Download: ML15212A718 (605)
	v • d • e

10 CFR 50.54(a)

MARIA L. LACAL Vice President, Nuclear Regulatory & Oversight Palo Verde Nuclear Generating Station P.O. Box 52034 Phoenix, AZ 85072 Mail Station 7605 102-070 2 2 -MLL/JR Tel 623 393 6491 July 28, 2015 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Dear Sirs:

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2, and 3 Docket Nos. STN 50-528, 50-529, and 50-530 Request to Change the Quality Assurance Program Description (QAPD)

Pursuant to 10 CFR 50.54(a), Arizona Public Service Company (APS) hereby requests a change to the PVNGS Quality Assurance Program Description (QAPD). As detailed further in the enclosure to this letter, the proposed change involves an entire rewrite and extraction of the PVNGS QAPD from the Updated Final Safety Analysis Report (UFSAR) in order to adopt a standardized QAPD based upon guidance of Nuclear Energy Institute (NEI)11-04A, Nuclear Generation Quality Assurance Program Description. The NEI 11-04A Quality Assurance Program template was reviewed and approved by the NRC via Safety Evaluation Report (NRC Agencywide Document Management System {ADAMS} Accession Number ML13023A051) dated May 9, 2013.

The enclosure to this letter includes background and description information along with attachments providing a detailed description of, and basis for, the proposed QAPD change. The attachments include:

Regulatory Basis for Revised Quality Assurance Program Description

Proposed PVNGS Operations QAPD Based Upon NEI 11-04A

Mark-Ups of Existing QA-Related UFSAR Pages

Comparison of Existing NRC Regulatory Guide Commitments to the New NRC Regulatory Guide Commitments Adopted in the Proposed QAPD

Specific Deviations from the NEI 11-04A Template and the Basis for Deviations A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway - Diablo Canyon - Palo Verde - Wolf Creek

J "Z.

ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Request to Change the Quality Assurance Program Description Page 2

" Comparison of Current QAPD to Proposed QAPD Based Upon NEI 11-04A and NQA-1-2008/NQA-la-2009

NEI 11-04A, Revision 0, Appendix 1, Regulatory Guide 1.33, Rev. 2, ANSI N18.7-1976, NQA 2008/NQA-la-2009 Standards, and NEI 11-04 QAPD Compliance Matrix Once approved, implementation shall be completed within 270 days.

The Plant Review Board and the Offsite Safety Review Committee have reviewed and concurred with this proposed QAPD change.

No new NRC commitments are being made by this letter. Should you need further information regarding this submittal, please contact Thomas N. Weber, Regulatory Affairs Department Leader, at (623) 393-5764.

Sincerely, MLL/J R

Enclosure:

Proposed Change to the Palo Verde Nuclear Gene rating Station (PVNGS) Operations Quality Assurance Program Description (QAPD) cc: M. L. Dapas NRC Region IV Regional Administrator M. M. Watford NRC NRR Project Manager for PVNGS L. J. KIos NRC NRR Project Manager C.A. Peabody NRC Senior Resident Inspector for PVNGS

ENCLOSURE Proposed Change to the Palo Verde Nuclear Generating Station (PVNGS)

Operations Quality Assurance Program Description (QAPD)

BACKGROUND AND DESCRIPTION ATTACHMENTS:

1. Regulatory Basis for Revised Quality Assurance Program Description

2. Proposed PVNGS Operations QAPD Based Upon NEI 11-04A

3. Mark-Ups of Existing QA-Related UFSAR Pages

4. Comparison of Existing NRC Regulatory Guide Commitments to New NRC Regulatory Guide Commitments Adopted in the Proposed QAPD

5. Specific Deviations from the NEI 11-04A Template and the Basis for Deviations

6. Comparison of Current QAPD to Proposed QAPD Based Upon NEI 11-04A and NQA 2008/NQA-1 a-2009

7. NEI 11-04A, Revision 0, Appendix 1, Regulatory Guide 1.33, Rev. 2, ANSI N18.7-1976, NQA-1-2008/NQA-la-2009 Standards, and NEI 11-04 QAPD Compliance Matrix

ENCLOSURE BACKGROUND AND DESCRIPTION Pursuant to 10 CFR 50.54(a), Arizona Public Service (APS) is requesting approval of a revision to the Palo Verde Nuclear Generating Station (PVNGS) Operations Phase Quality Assurance (QA) Program to adopt updated industry standards. The updated industry standards represent approximately 40 years of experience and advancement for quality assurance and administrative controls related to the siting, cdesign, construction, start-up, operation, and decommissioning of commercial nuclear power plants. Although the updated industry standards were developed primarily as a result of the resurgence of interest in the construction of domestic nuclear power plants, they are adaptable for use at an operating facility.

Nuclear Energy Institute (NEI)11-04A, Nuclear Generation Quality Assurance Program Description, Revision 0, was developed to be used by new licensees constructing facilities under Early Site Permit and combined Construction and Operating License provisions of 10 CFR 52. APS has adapted the NEI 11-04A template to replace the existing PVNGS Operations Quality Assurance Program Description (QAPD) and thus appropriate deviations from the NEI 11-04A guidance were necessary to address an operational facility that has already been designed, constructed, and licensed to earlier regulatory guidance and industry standards.

The basis for concluding that the revised PVNGS QAPD satisfies the requirements of 10 CFR 50, Appendix B, and additional administrative requirements of NRC Regulatory Guide (RG) 1.33, Revision 2, is provided as Attachment 1, Regulatory Basis for Revised Quality Assurance Program Description.

The current PVNGS QAPD resides in various sections of the PVNGS Updated Final Safety Analysis Report (UFSAR). The revised PVNGS QAPD is intended to be issued as a separate topical report following the overall format and content of the NEI 11-04A template. The revised PVNGS QAPD is provided in Attachment 2, Proposed PVNGS Operations Quality Assurance Program Description (QAPD) Based Upon NEI 11-04A. A marked-up copy of existing QA-related UFSAR pages is provided in , Mark-Ups of Existing QA-Related UFSAR Pages.

A summary table comparing existing commitments to NRC Regulatory Guides and commitments to the updated NRC Regulatory Guides is provided as Attachment 4, Comparison of Existing NRC Regulatory Guide Commitments to New NRC Regulatory Guide Commitments Adopted in the Proposed QAPD. The overall change implements an updated QA regulatory commitment structure based upon RG 1.28, Revision 4, which endorses Nuclear Quality Assurance (NQA)-I-2008 and the subsequent addenda in NQA-la-2009 (NQA-1-2008/NQA-la-2009), Quality Assurance Requirements for Nuclear FacilityApplications. The commitment to RG 1.28 replaces commitments to several NRC Regulatory Guides which endorsed ANSI Page I 1

ENCLOSURE BACKGROUND AND DESCRIPTION N45.2-1971, and several of the older ANSI N45.2 series of standards that have been incorporated into NQA-1-2008/NQA-la-2009. The additional operational phase administrative controls previously addressed by adopting ANSI N18.7-1976 are now addressed by adopting RG 1.28, NQA-1-2008/NQA-la-2009, and the additional operational phase administrative controls embedded in the text of NEI 11-04A. The overall format of NEI 11-04A has been adopted with some minor numbering modifications.

Specific deviations from the NEI 11-04A template and the basis for deviations are presented in Attachment 5, Specific Deviations from the NEI 11-04A Template and the Basis for Deviations.

APS has evaluated the proposed PVNGS QAPD changes in accordance with 10 CFR 50.54(a) and has concluded the extent of changes to licensee (APS) regulatory commitments warrants NRC review and approval prior to implementation. Although the overall effect of the PVNGS QAPD change has generally been determined to be equivalent to the existing QA requirements and controls, there are specific changes in the level of detail presented in the revised PVNGS QAPD that could be considered reductions in QA program commitments pursuant to 10 CFR 50.54(a). A discussion of those areas APS believes could be considered as either reductions or increases in the level of regulatory commitment is provided in Attachment 6, Comparison of Current QAPD to Proposed QAPD Based Upon NEI 11-04A and NQA-1-2008/NQA-la-2009. Attachment 6 provides a table comparing major sections in the existing PVNGS QAPD to the proposed PVNGS QAPD sections that will describe related QA program requirements and administrative controls.

The proposed changes in QA regulatory commitments for PVNGS, when approved by the NRC, shall not be construed to negatively impact the quality of any items (structures, systems, components, parts, or materials) that were properly controlled or activities that were properly implemented in accordance with previous NRC approved QA programs for PVNGS, as periodically updated per requirements of 10 CFR 50.54(a).

As described in the NRC Safety Evaluation Report for adopting the NEI 11-04A template, PVNGS has incorporated all of the administrative controls for the operational phase as described in NEI 11-04A, Appendix 1, Regulatory Guide 1.33, Rev. 2, ANSI N18.7-1976, NQA 2008/NQA-la-2009 Standards, and NEI 11-04 QAPD Compliance Matrix. Incorporation of the administrative controls as described in NEI 11-04A, Appendix 1, provides an equivalent and acceptable alternative to the existing PVNGS commitment to RG 1.33. Appendix 1 of NEI 11-04A, is included as , NEI 11-04A, Revision 0, Appendix 1, Regulatory Guide 1.33, Rev. 2, Page 1 2

ENCLOSURE BACKGROUND AND DESCRIPTION ANSI N18.7-1976, 'NQA-1-2008/NQA-la-2009 Standards, and NEI 11-04 QAPD Compliance Matrix. Attachment 4 describes the incorporation of the administrative controls into the PVNGS QAPD.

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ATTACHMENT 1 Regulatory Basis for Revised Quality Assurance Program Description (16 Pages follow)

ATTACHMENT 1 Regulatory Basis for Revised Quality Assurance Program Description The Palo Verde Nuclear Generating Station (PVNGS) Quality Assurance Program Description (QAPD) is the top-level policy document that establishes the quality assurance (QA) policy and assigns major functional responsibilities for operational phase activities conducted by or for PVNGS. The PVNGS QAPD describes the methods and establishes QA and administrative control requirements that meet 10 CFR 50, Appendix B, 10 CFR 71, Subpart H, and 10 CFR 72, Subpart G, using the applicable regulatory guidance and industry standards as a basis.

In June 2010, the NRC issued Regulatory Guide (RG) 1.28, Revision 4, Quality Assurance Program Criteria(Design and Construction). This RG described methods that the NRC staff considered acceptable for complying with the provisions of 10 CFR Part 50 and 10 CFR Part 52 for establishing and implementing a QAPD for the design and construction of nuclear power plants and fuel reprocessing plants.

Regulatory Guide 1.28 endorsed the American Society of Mechanical Engineers Standard NQA-1, Quality Assurance Requirements for Nuclear FacilityApplications, Part I and Part II requirements included in NQA-1-2008 and the subsequent addenda in NQA-la-2009 (NQA-1-2008/NQA-la-2009), as the bases for complying with the requirements of 10 CFR Part 50, Appendix B, subject to the additions and modifications of NQA-1-2008/NQA-la-2009 identified in the regulatory positions of the RG.

The NRC staff approved a QAPD template provided by the Nuclear Energy Institute (NEI) which reflected the guidance of RG 1.28, Revision 4. The QAPD template was released as NEI 11-04A, Quality Assurance Program Description, Revision 0, the "A" denoting NRC staff approval, as documented by NRC Safety Evaluation (SE) dated May 9, 2013.

As stated in the NRC SE, the NEI template provides an adequate basis for complying with the requirements of Appendix B to 10 CFR Part 50, subject to specific additions and modifications of NQA-1-2008/NQA-la-2009, as supplemented by additional regulatory guidance and industry guidance applicable to administrative and quality controls during nuclear power plant operation. The QAPD template provides guidance for establishing a top-level policy document that defines QA policy and assigns major QA Program functional responsibilities. The QAPD template can be used for early site permit, construction, preoperational, and/or operational activities, as applicable, that affect the quality and performance of safety-related structures, systems, and components (SSCs).

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ATTACHMENT 1 Regulatory Basis for Revised Quality Assurance Program Description The NRC SE stipulates additional quality assurance program requirements for the operating phase:

"an applicant must either demonstrate that its QAPD has incorporated all of the administrative controls not included in NQA-1-2008 and the NQA-la-2009 Addenda by explicitly addressing the provisions in NEI 11-04, Revision 0, Part V and Appendix 1, or otherwise by including a commitment to RG 1.33, Quality Assurance Program Requirements (Operation), Revision 2 in Part IV of the QAPD."

The additional requirements are met by the proposed PVNGS QAPD as follows:

NEI 11-04A, Revision 0, Part V is addressed in PVNGS QAPD Section 5.0.

Appendix 1 of NEI 11-04A is explicitly addressed in this submittal and is included as Attachment 7, NEI 11-04A, Revision 0, Appendix 1, Regulatory Guide 1.33, Rev. 2, ANSI N18.7-1976, NQA 2008/NQA-la-2009 Standards, and NEI 11-04 QAPD Compliance Matrix.

The PVNGS QAPD is also intended to satisfy the quality assurance program requirements of other regulations under Title 10, Energy, which also contain 18 quality assurance criteria which are either identical to, or essentially the same as, the 18 Criteria of 10 CFR 50, Appendix B. The other regulations which have applicability are listed as follows:

10 CFR 71, Subpart H - Quality Assurance, for packaging and transportation of radioactive material

10 CFR 72, Subpart G - Quality Assurance, for the independent storage of spent nuclear fuel and high-level radioactive waste, and reactor-related greater than Class C waste Page I 2

ATTACHMENT 1 Regulatory Basis for Revised Quality Assurance Program Description The following is a discussion regarding how the revised PVNGS QAPD satisfies each of the 18 Criteria of 10 CFR 50, Appendix B.

Criterion 1 - Organization The PVNGS QAPD Section 2.1 provides an organizational description that clearly describes the management structure and functional responsibilities, from corporate management through operating plant positions, to establish, maintain, and implement the regulatory and QA Program requirements applicable to PVNGS. The QAPD functional description of responsibilities allows management to size the nuclear production and technical organizations commensurate with their assigned duties and responsibilities. The organizational structure described provides sufficient independence of the organization with primary responsibility of verifying effective implementation of the PVNGS QA Program requirements.

The PVNGS QAPD adopts the quality standards for the organization as described in NQA-1-2008, Requirement 1, and an organizational description for the operational phase consistent with guidance provided in the NEI 11-04A QAPD template. These standards and guidance are endorsed as acceptable methods of meeting 10 CFR 50, Appendix B by NRC RG 1.28, Revision 4, dated June 2010, and the NRC SE for NEI 11-04A.

Criterion 2 - Quality Assurance Program The PVNGS QAPD Sections 2.2 and 3.0 establish the necessary measures to implement a QA Program to ensure that the operation of the PVNGS nuclear power plants and facilities are in accordance with governing regulations and license requirements. The QA Program comprises those planned and systematic actions necessary to provide confidence that structures, systems, and components (SSCs) will perform their intended safety functions, including certain non-safety related SSCs and activities that are significant contributors to plant safety or compliance with other regulations applicable to fire protection (10 CFR 50.48), anticipated transients without scram (ATWS) (10 CFR 50.62), and the station blackout (SBO)

(10 CFR 50.63). PVNGS maintains a list or system identifying SSCs and activities within the scope of the QA program.

The PVNGS QAPD provides measures to assess the adequacy of the QAPD and to ensure its effective implementation at least once every 2 years. In addition, a grace period of 90 days is applied to activities that must be performed on a periodic basis.

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ATTACHMENT 1 Regulatory Basis for Revised Quality Assurance Program Description The PVNGS QAPD describes the necessary measures to establish and maintain formal indoctrination and training programs for personnel performing, verifying, or maintaining activities within the scope of the PVNGS QAPD to ensure task-related proficiency is maintained. The PVNGS QAPD provides the minimum training requirements for managers responsible for implementing elements of the PVNGS QAPD and for the manager responsible for planning, implementing, and maintaining the programs for the PVNGS QAPD.

The PVNGS QAPD adopts the quality standards described in NQA-1-2008, Requirement 2 with alternatives provided in the NEI 11-04A QAPD template. These standards are endorsed by NRC RG 1.28, Revision 4, and the NRC SE for NEI 11-04A as acceptable methods of meeting 10 CFR 50, Appendix B. The PVNGS QAPD adopts NRC RG 1.28, Revision 4; the guidance of NQA-1-2008/NQA-la-2009; and specific alternatives of NEI 11-04A in lieu of existing commitments to RG 1.58 (ANSI N45.2.6) and RG 1.146 (ANSI N45.2.23). The existing PVNGS commitment to NRC RG 1.8, which endorses ANSI/ANS 3.1-1978, is maintained with some modifications. These modifications remove a previous exception to ANSI/ANS 3.1-1978 for the "Engineer in Charge" and adopt NQA-1-2008/NQA-la-2009 as the basis for QA management qualifications in lieu of ANSI/ANS 3.1-1978.

One additional alternative to the guidance of NQA-1-2008, Requirement 2, related to qualification of lead auditors, is also included in the PVNGS QAPD Section 2.2.7.

A similar alternative was previously accepted by NRC SE dated March 27, 1998, for the San Onofre Nuclear Generating Station. This alternative was adopted by PVNGS and incorporated into the PVNGS QAPD uonder the provisions of 10 CFR 50.54(a)(3)(ii) in November 2000.

Criterion 3 - Design Control The PVNGS QAPD Section 2.3 establishes the necessary measures to control design, design changes, and temporary modifications of items within the scope of the PVNGS QAPD. The PVNGS QAPD includes measures to control design inputs, outputs, changes, interfaces, records, and organizational interfaces among the licensee and its suppliers. These provisions ensure that the design inputs are correctly translated into design outputs. In addition, the PVNGS QAPD provides for individuals knowledgeable in QA principles to review design documents to ensure that they contain the necessary QA requirements.

The PVNGS QAPD adopts the quality standards for design control and verification as described in NQA-1-2008 and NQA-la-2009 Addenda, Requirement 3; Subpart 2.7 Page I 4

ATTACHMENT 1 Regulatory Basis for Revised Quality Assurance Program Description for computer software; and Subpart 2.14 for QA requirements for commercial grade items and services. These standards are endorsed by NRC RG 1.28, Revision 4, and the NRC SE for NEI 11-04A as acceptable methods of meeting 10 CFR 50, Appendix B. The PVNGS QAPD adopts NRC RG 1.28, Revision 4, and guidance of NQA 2008/NQA-la-2009 in lieu of existing commitment to NRC RG 1.64 and ANSI N45.2. 11.

Criterion 4 - Procurement Document Control The PVNGS QAPD Section 2.4 establishes the necessary administrative controls and processes to ensure that procurement documents include or reference applicable regulatory, technical, and QA program requirements. Applicable technical, regulatory, administrative, quality, and reporting requirements are invoked for procurement of items and services.

The PVNGS QAPD adopts the quality standards for procurement document control as described in NQA-1-2008, Requirement 4, with alternatives provided in the NEI 11-04A QAPD template. These standards are endorsed by NRC RG 1.28, Revision 4, and the NRC SE for NEI 11-04A as acceptable methods of meeting 10 CFR 50, Appendix B. The PVNGS QAPD adopts NRC RG 1.28, Revision 4, and the guidance of NQA-1-2008/NQA-la-2009 with alternatives of NEI 11-04A in lieu of existing commitment to NRC RG 1.123 and ANSI N45.2.13.

Criterion 5 - Instructions, Procedures, and Drawings The PVNGS QAPD Sections 2.5 and 5.3 establish the necessary measures and governing procedures to ensure that activities affecting quality are prescribed by and performed in accordance with documented instructions, procedures, and drawings.

The PVNGS QAPD adopts the quality standards described in NQA-1-2008, Requirement 5, and the guidance of NEI 11-04A, Part V, Section 3, Operational Phase Procedures, in establishing the required procedural controls. These standards are endorsed by NRC RG 1.28, Revision 4, and the NRC SE for NEI 11-04A as acceptable methods of meeting 10 CFR 50, Appendix B.

Criterion 6 - Document Control To ensure effective and accurate procedures during the operational phase, procedures are reviewed and updated as necessary. Temporary changes to a procedure that clearly do not alter the intent of the procedure may be Page I 5

ATTACHMENT 1 Regulatory Basis for Revised Quality Assurance Program Description implemented, provided that two members of the operations staff knowledgeable in the areas affected by the procedure approve the changes. These temporary changes include a specific period of time during which the revised procedure may be used.

In establishing provisions for document control, the PVNGS QAPD adopts the quality standards described in NQA-1-2008, Requirement 6 and the NEI 11-04A QAPD template. These standards are endorsed by NRC RG 1.28, Revision 4, and the NRC SE for NEI 11-04A as acceptable methods of meeting 10 CFR 50, Appendix B.

Criterion 7 - Control of Purchased Material, Equipment, and Services The PVNGS QAPD Section 2.7 establishes necessary measures and governing procedures that control procurement of items and services to ensure conformance with specified requirements. The controls include measures for evaluating prospective suppliers and selecting only those that are qualified. In addition, controls include auditing and evaluating suppliers to ensure that qualified suppliers continue to provide acceptable products and services.

The program provides for acceptance actions (e.g. source verification, receipt inspection, pre- and post-installation tests) and review of documentation (e.g.

certificates of conformance) to ensure that the procurement, inspection, and test requirements have been satisfied before relying on the item to perform its intended safety function. Purchased items (components, spares, and replacement parts necessary for plant operation, refueling, maintenance, and modifications) and services are subject to quality and technical requirements at least equivalent to those specified for original equipment, or specified by properly reviewed and approved revisions to design documentation, to ensure these are suitable for their intended service and are of acceptable quality, consistent with their effect on safety.

In establishing procurement verification control, the PVNGS QAPD adopts the quality standards described in NQA-la-2009, Requirement 7, with alternatives provided in the NEI 11-04A QAPD template. These standards are endorsed by NRC RG 1.28, Revision 4, and the NRC SE for NEI 11-04A as acceptable methods of meeting 10 CFR 50, Appendix B. The PVNGS QAPD adopts NRC RG 1.28, Revision 4, and the guidance of NQA-1-2008/NQA-la-2009 with alternatives of NEI 11-04A in lieu of existing commitment to NRC RG 1.123 and ANSI N45.2.13.

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ATTACHMENT 1 Regulatory Basis for Revised Quality Assurance Program Description Criterion 8 - Identification and Control of Materials, Parts, and Components The PVNGS QAPD Section 2.8 establishes necessary measures for identification and control of items such as materials, including consumables, and items with limited shelf life, parts, components, and partially fabricated subassemblies. Identification of items is maintained throughout fabrication, erection, installation, and use so that the item is traceable to its documentation.

In establishing provisions for identification and control of items, the PVNGS QAPD adopts the quality standards described in NQA-1-2008, Requirement 8 and the NEI 11-04A QAPD template. These standards are endorsed by NRC RG 1.28, Revision 4, and the NRC SE for NEI 11-04A as acceptable methods of meeting 10 CFR 50, Appendix B. The PVNGS QAPD adopts NRC RG 1.28, Revision 4, in lieu of existing commitment to NRC RG 1.38 and ANSI N45.2.2.

Criterion 9 - Control of Special Processes The PVNGS QAPD Section 2.9 establishes programs, procedures, and processes to ensure that special processes requiring interim process controls to ensure quality are controlled in accordance with applicable codes, specifications, and standards for the specific application.

In establishing measures for the control of special processes, the PVNGS QAPD

-adopts the quality standards described in NQA-1-2008, Requirement 9 and the NEI 11-04A QAPD template. These standards are endorsed by NRC RG 1.28, Revision 4, and the NRC SE for NEI 11-04A as acceptable methods of meeting 10 CFR 50, Appendix B.

Criterion 10 - Inspection The PVNGS QAPD Section 2.10 establishes the necessary measures to implement inspections that ensure items, services, and activities affecting safety meet established requirements and conform to documented specifications, instructions, procedures, and design documents. The inspection program establishes requirements for planning inspections, determining applicable acceptance criteria, setting the frequency of inspections, and identifying special tools needed to perform the inspections. Qualified personnel perform the inspections and are independent of those who perform or directly supervise the work.

In establishing inspection requirements, the PVNGS QAPD adopts the quality standards described in NQA-1-2008 and NQA-la-2009, Requirement 10, and Page I 7

ATTACHMENT 1 Regulatory Basis for Revised Quality Assurance Program Description Subparts 2.4 and 2.8, with alternatives provided in the NEI 11-04A QAPD template.

These standards are endorsed by NRC RG 1.28, Revision 4, and the NRC SE for NEI 11-04A as acceptable methods of meeting 10 CFR 50, Appendix B. The PVNGS QAPD adopts NRC RG 1.28, Revision 4, with alternatives of NEI 11-04A, in lieu of existing commitment to RG 1.30 (ANSI N45.2.4) and RG 1.116 (ANSI N45.2.8).

The PVNGS QAPD maintains existing commitment to NRC RG 1.94 and ANSI N45.2.5 rather than adopting NQA-1-2008 Subpart 2.5.

Criterion 11 - Test Control The PVNGS QAPD Section 2.11 establishes necessary measures and governing provisions to demonstrate that items within the scope of the QAPD will perform satisfactorily in service, that the plant can be operated safely as designed, and that the operation of the plant, as a whole, is satisfactory. The PVNGS QAPD establishes provisions to assure that computer software used in applications affecting safety is prepared, documented, verified and tested, such that the expected output is obtained and configuration control maintained.

In establishing the overall provisions for testing of items within the PVNGS QA Program scope, the PVNGS QAPD adopts the quality standards described in NQA-la-2009, Requirement 11 and the NEI 11-04A QAPD template. Testing of computer software is addressed by the PVNGS QAPD's adoption of the appropriate provisions of Requirement 11 and Subpart 2.7 from NQA-la-2009. These standards are endorsed by NRC RG 1.28, Revision 4, and the NRC SE for NEI 11-04A as acceptable methods of meeting 10 CFR 50, Appendix B.

Criterion 12 - Control of Measuring and Test Equipment The PVNGS QAPD Section 2.12 establishes necessary measures to control the calibration, maintenance, and use of measuring and test equipment that provides information important to safe plant operation.

In establishing provisions for control of measuring and test equipment, the PVNGS QAPD adopts the quality standards described in NQA-1-2008 and NQA-la-2009, Requirement 12 with alternatives provided in the NEI 11-04A QAPD template.

These standards are endorsed by NRC RG 1.28, Revision 4, and the NRC SE for NEI 11-04A as acceptable methods of meeting 10 CFR 50, Appendix B.

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ATTACHMENT 1 Regulatory Basis for Revised Quality Assurance Program Description Criterion 13 - Handling,. Storage, and Shipping The PVNGS QAPD Section 2.13 establishes the necessary measures to control handling, storage, packaging, shipping, cleaning, and preservation of items to prevent inadvertent damage or loss and to minimize deterioration.

In establishing provisions for the handling, storage, packaging, shipping, cleaning, and preservation of items, the PVNGS QAPD adopts the quality standards described in NQA-1-2008, Requirement 13. The PVNGS QAPD also adopts the quality standards described in NQA-1-2008 and NQA-la-2009, Subpart 2.1, Subpart 2.2, Subpart 2.3, and Subpart 3.2, Appendix 2.1, with alternatives provided in the NEI 11-04A QAPD template. These standards are endorsed by NRC RG 1.28, Revision 4, and the NRC SE for NEI 11-04A as acceptable methods of meeting 10 CFR 50, Appendix B. The PVNGS QAPD adopts NRC RG 1.28, Revision 4, and the guidance of NQA-1-2008/NQA-la-2009 with alternatives of NEI 11-04A in lieu of existing commitments to NRC Regulatory Guides 1.37 (ANSI N45.2.1), 1.38 (ANSI N45.2.2), and 1.39 (ANSI N45.2.3).

Criterion 14 - Inspection, Test, and Operating Status The PVNGS QAPD Sections 2.14 and 5.4 establish the necessary measures to identify the inspection, test, and operating status of items and components within the scope of the QAPD to maintain personnel and reactor safety and to prevent inadvertent operation of equipment.

In establishing measures for control of inspection, test, and operating status, the PVNGS QAPD adopts the standards described in NQA-1-2008, Requirement 14 and the additional operational phase equipment control measures described in the NEI 11-04A QAPD template, Part V, Section 4, Control of Systems and Equipment in the OperationalPhase. These standards are endorsed by NRC RG 1.28, Revision 4, and the NRC SE for NEI 11-04A as acceptable methods of meeting 10 CFR 50, Appendix B.

Criterion 15 - Nonconforming Materials, Parts, or Components The PVNGS QAPD Section 2.15 establishes the necessary measures to control items, including services that do not conform to specified requirements to prevent inadvertent installation or use. Nonconformances are evaluated for their impact on operability of quality SSCs to ensure that the final condition does not adversely affect safety, operation or maintenance of the item or service. Results of evaluations of conditions adverse to quality are analyzed to identify quality trends, Page I 9

ATTACHMENT 1 Regulatory Basis for Revised Quality Assurance Program Description documented, and reported to upper management in accordance with applicable procedures.

In addition, the PVNGS QAPD establishes the necessary interfaces between the QA program for identification and control of nonconforming material, parts, and components and the non-QA reporting program that satisfies applicable requirements of 10 CFR Part 21.

In establishing measures for nonconforming materials, parts, or components, the PVNGS QAPD adopts the quality standards described in NQA-1-2008, Requirement 15 and the NEI 11-04A QAPD template. These standards are endorsed by NRC RG 1.28, Revision 4, and the NRC SE for NEI 11-04A as acceptable methods of meeting 10 CFR 50, Appendix B. A clarification is included regarding identification of nonconforming items. PVNGS considers other means of identification acceptable when marking on or tagging either the item, the container, or the package containing the item is not practical.

Criterion 16 - Corrective Action The PVNGS QAPD Section 2.16 establishes the necessary measures to promptly identify, control, document, classify, and correct conditions adverse to quality. The PVNGS QAPD requires personnel to identify known conditions adverse to quality.

Reports of conditions adverse to quality are analyzed to identify trends. Significant conditions adverse to quality are documented and reported to responsible management. In the case of suppliers working on safety-related activities or similar situations, PVNGS may delegate specific responsibility for the corrective action program, but PVNGS maintains responsibility for program effectiveness.

In addition, the PVNGS QAPD establishes the necessary interfaces between the QA corrective action program and the non-QA reporting program to identify, evaluate, and report defects and noncompliances to satisfy the applicable requirements of 10 CFR Part 21.

In establishing provisions for corrective action, the PVNGS QAPD adopts the quality standards described in NQA-1-2008, Requirement 16 and the NEI 11-04A QAPD template. These standards are endorsed by NRC RG 1.28, Revision 4, and the NRC SE-for NEI 11-04A as acceptable methods of meeting 10 CFR 50, Appendix B.

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ATTACHMENT 1 Regulatory Basis for Revised Quality Assurance Program Description Criterion 17 - Quality Assurance Records The PVNGS QAPD Section 2.17 establishes the necessary measures to ensure that sufficient records of items and activities affecting quality are generated, identified, retained, maintained, and retrievable. Regulatory position C.i.a of RG 1.28, Revision 4, provides record retention times for lifetime and nonpermanent records.

In establishing the retention time for records, the PVNGS QAPD bases the retention period on regulatory position C.i.a of RG 1.28, Revision 4. For use of electronic records storage and retrieval systems, the PVNGS QAPD complies with NRC guidance in Generic Letter (GL) 88-18, Plant Record Storage on Optical Disks, (dated October 20, 1988); Regulatory Issue Summary (RIS) 2000-18, Guidance on Managing Quality Assurance Records in ElectronicMedia (dated October 23, 2000);

and associated Nuclear Information and Records Management Association (NIRMA) technical guidelines TG 11-2011, TG 15-2011, and TG 21-2011. It should be noted that the PVNGS QAPD adopts more recent versions of the NIRMA technical guidelines referenced in RIS 2000-18 and endorsed by RG 1.28, Revision 4, Regulatory Position C.1.b.

In establishing provisions for quality assurance records, the PVNGS QAPD adopts the quality standards described in NQA-1-2008, Requirement 17, and the regulatory positions stated in RG 1.28, Revision 4. Use of these standards has been endorsed by the NRC SE for NEI 11-04A as an acceptable method of meeting 10 CFR 50, Appendix B. The PVNGS QAPD adopts NRC RG 1.28, Revision 4, and the guidance of NQA-1-2008/NQA-la-2009 in lieu of existing commitment to NRC RG 1.88 and ANSI N45.2.9.

Criterion 18 - Audits The PVNGS QAPD Sections 2.18 and 5.2 establish the necessary measures to implement audits to verify that activities covered by the PVNGS QAPD are performed in conformance with the established requirements. The effectiveness of the audit program is reviewed as part of the overall review and audit process. The PVNGS QAPD provides for the conduct of periodic internal and external audits.

Internal audits are conducted to determine the adequacy of the QA Program and its implementing procedures and to determine if they comply with the PVNGS QAPD requirements. Internal audits are performed at a frequency commensurate with safety significance and in such a manner as to ensure that an audit of all applicable QA program elements is completed for each functional area within a period of two years unless performance dictates that audits should be performed at a different frequency. External audits determine the adequacy of supplier or contractor QA Page I 11

ATTACHMENT 1 Regulatory Basis for Revised Quality Assurance Program Description programs. Responsible management reviews audit results, responds to audit findings, and initiates corrective action where indicated in accordance with the PVNGS Corrective Action Program. Where corrective actions are indicated, documented follow-up of applicable areas through inspection, review, re-audit, or other appropriate means is conducted to verify that corrective actions have been adequately implemented.

In establishing the independent audit program, the PVNGS QAPD adopts the quality standards described in NQA-1-2008, Requirement 18 and the regulatory positions stated in RG 1.28, Revision 4, with alternatives provided in the NEI 11-04A QAPD template. These standards are endorsed by NRC RG 1.28, Revision 4, and the NRC SE for NEI 11-04A as acceptable methods of meeting 10 CFR 50, Appendix B. The PVNGS QAPD adopts NRC RG 1.28, Revision 4, the guidance of NQA-1-2008/NQA-la-2009, and alternatives provided in NEI 11-04A in lieu of existing commitments to NRC Regulatory Guides 1.33 (ANS 3.2/ANSI N18.7) and 1.144 (ANSI N45.2.12) for audits.

Page 1 12

ATTACHMENT 1 Regulatory Basis for Revised Quality Assurance Program Description Reference Documents

1. Appendix B to 10 CFR Part 50, QualityAssurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants

2. 10 CFR 71, Packagingand transportationof radioactive material, Subpart H, Quality Assurance

3. 10 CFR 72, Licensing requirements for the independent storage of spent nuclear fuel and high-level radioactive waste, and reactor-relatedgreater than Class C waste, Subpart G, Quality Assurance

4. NRC Regulatory Guide 1.28, Revision 4, Quality Assurance Program Criteria (Design and Construction)

5. ASME NQA-1-2008/NQA-1a-2009, Quality Assurance Requirements for Nuclear Facility Applications

6. NEI 11-04A, Revision 0, Nuclear Energy Institute, Nuclear Generation Quality Assurance ProgramDescription

7. NRC Safety Evaluation Report on NEI 11-04, Revision 0, Dated May 9, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML13023A051)

8. NRC Regulatory Guide 1.33, Revision 2, Quality Assurance Program Requirements (Operation)

9. ANS 3.2/ANSI N18.7-1976, Administrative Controls and Quality Assurance for the OperationalPhase of Nuclear Power Plants

10. NRC Regulatory Guide 1.58, Revision 1, Qualification of Nuclear Power Plant Inspection, Examination and Testing Personnel

11. ANSI N45.2.6-1978, QualificationsInspection, Examination and Testing Personnel for Nuclear Power Plants

12. NRC Regulatory Guide 1.146, Revision 0, Qualification of Quality Assurance ProgramAudit Personnel for Nuclear Power Plants

13. ANSI N45.2.23-1978, Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants Page 1 13

ATTACHMENT 1 Regulatory Basis for Revised Quality Assurance Program Description

14. NRC Regulatory Guide 1.8, Revisionl-R, Qualification and Training of Personnel for Nuclear Power Plants

15. ANSI/ANS 3.1-1978, American National Standardfor Selection and Training of Nuclear Power PlantPersonnel

16. NRC Safety Evaluation dated March 27, 1998, Approval of Changes to the Quality Assurance Program Description for the San Onofre Nuclear Generating Station, UNITS 1, 2, AND 3 (TAC NOS. MA1002, MA-0981, MA-0982)

17. NRC Regulatory Guide 1.64, Revision 2, Quality Assurance Requirements for the Design of Nuclear Power Plants

18. ANSI N45.2.11-1974, Quality Assurance Requirements for the Design of Nuclear Power Plants

19. NRC Regulatory Guide 1.123, Revision 1, Quality Assurance Requirements for Control of Procurementof Items and Service for Nuclear Power Plants

20. ANSI N45.2.13-1976, Quality Assurance Requirements for Control of Procurementof Items and Service for Nuclear Power Plants

21. NRC Regulatory Guide 1.38, Revision 2, Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Water-Cooled Nuclear Power Plants

22. ANSI N45.2.2-1972, Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants (During the Construction Phase)

23. NRC Regulatory Guide 1.30, Revision 0, Quality Assurance Requirements for the Installation, Inspection, and Testing of Instrumentation and Electric Equipment (Safety Guide 30)

24. ANSI N45.2.4-1972, Installation,Inspection, and Testing Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations

25. NRC Regulatory Guide 1.116, Revision 0-R, Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems Page 1 14

ATTACHMENT 1 Regulatory Basis for Revised Quality Assurance Program Description

26. ANSI N45.2.8-1975, Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for the Construction Phase of Nuclear Power Plants

27. NRC Regulatory Guide 1.94, Revision 1, Quality Assurance Requirements for Installation, Inspection, and Testing of StructuralConcrete and StructuralSteel During the Construction Phase of Nuclear Power Plants

28. ANSI N45.2.8-1975, Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Concrete and StructuralSteel During the Construction Phase of Nuclear Power Plants

29. NRC Regulatory Guide 1.37, Revision 0, Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants

30. ANSI N45.2.1-1973, Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants

31. NRC Regulatory Guide 1.39, Revision 2, Housekeeping Requirements for Water-Cooled Nuclear Power Plants

32. ANSI N45.2.3-1973, Housekeeping During the Construction Phase of Nuclear Power Plants

33. 10 CFR Part 21, Reporting of Defects and Noncompliance

34. Proposed Final NRC Generic Letter 88-18, Guidance on Managing Quality Assurance Records in Electronic Media (dated October 20, 1988)

35. Regulatory Issue Summary (RIS) 2000-18, Guidance on Managing Quality Assurance Records in Electronic Media Generic Letter (GL) 88-18, Plant Record Storage on Optical Disks (dated October 23, 2000)

36. Nuclear Information and Records Management Association, Inc. (NIRMA), TG 11-2011, Authentication of Records and Media

37. Nuclear Information and Records Management Association, Inc. (NIRMA), TG 15-2011, Management of Electronic Records

38. Nuclear Information and Records Management Association, Inc. (NIRMA), TG 21-2011, ElectronicRecords Protection and Restoration Page 1 15

ATTACHMENT 1 Regulatory Basis for Revised Quality Assurance Program Description

39. NRC Regulatory Guide 1.88, Revision 2, Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records

40. ANSI N45.2.9-1974, Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants

41. NRC Regulatory Guide 1.144, Revision 1, Auditing of Quality Assurance Programsfor Nuclear Power Plants

42. ANSI N45.2.12-1978, Requirements for Auditing of Quality Assurance Programsfor Nuclear Power Plants Page 1 16

ATTACHMENT 2 Proposed PVNGS Operations Quality Assurance Program Description Based Upon NEI 11-04A (69 Pages Follow)

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 1 of 69 PVNGS Operations Quality Assurance Program Description (QAPD)

REVISION 0 Originator:

Reviewer:

Approval:

EFFECTIVE DATE:

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 2 of 69 PVNGS Operations Quality Assurance Program Description (QAPD)

REVISION 0

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 3 of 69 DESCRIPTION OF CHANGES PAGE Revision 0

1. Relocation of QA Program from UFSAR to stand-alone topical report ALL

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 4 of 69 TABLE OF CONTENTS SECTION PAGE POLICY STATEMENT ...................................................................................................................... 6 1.0 GENERAL .................................................................................................................................. 6 1.1 SCOPE/APPLICABILITY ..................... ! ....................... ..7 2.0 -QAPD DETAILS ........................................................................................................................

2.0ILS...................................................8.

QAD DET 8 2.1 O R GANIZA TIO N .............................................................................................................................. 7 2.2 QUALITY ASSURANCE PROGRAM ...................................................................................... 7 2.3 D E SIGN C ON TR O L ....................................................................................................................... 7 2.4 PROCUREMENT DOCUMENT CONTROL ........................................................................... 7 2.5 INSTRUCTIONS, PROCEDURES, AND DRAWINGS ......................................................... 7 2.6 DO CUM ENT CON TROL ............................................................................................................. 7 2.7 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES .................... 7 2.8 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS ....... 7 2.9 CONTROL OF SPECIAL PROCESSES .................................................................................... 7 2.10 IN SP EC TIO N ................................................................................................................................. 7..7 2.11 T EST C O N T RO L .............................................................................................................................. 7 2.12 CONTROL OF MEARURING AND TEST EQUIPMENT ....................................................... 7 2.13 HANDLING, STORAGE, AND SHIPPING ............................................................................. 7 2.14 INSPECTION, TEST, AND OPERATING STATUS .............................................................. 7 2.15 NONCONFORMING MATERIALS, PARTS, AND COMPONENTS ................. 7 2.16 CORRECTIVE A CTION S ............................................................................................................ 7 2.17 QUALITY ASSURANCE RECORDS ......................................................................................... 7 2 .18 A U D IT S ............................................................................................................................................... 7 3.0 NONSAFETY-RELATED SSC QUALITY CONTROL ......... Error! Bookmark not defined.

3.1 NONSAFETYRELATED SSCs - SIGNIFICANT CONTRIBUTORS TO PLANT SAFE TY ............................................................................................................................................ 7 3.2 NONSAFETY-RELATED SSCs CREDITED FOR REGULATORY EVENTS ....................... 7 4.0 REGULATORY COMMITMENTS ........................................... Error! Bookmark not defined.

5.0 ADDITIONAL QUALITY ASSURANCE AND ADMINISTRATIVE CONTROLS FOR THE PLANT OPERATIONAL PHASE .......................................................... 39 5.1 D E FIN IT IO NS ................................................................................................................................ 39 5.2 REVIEW OF ACTIVITIES AFFECTING SAFE OPERATIONError! Bookmark not defined.

5.3 OPERATIONAL PHASE PROCEDURES .............................. Error! Bookmark not defined.

5.4 CONTROL OF SYSTEMS AND EQUIPMENT IN THE OPERATIONAL PHASEError! Boo ka 5.5 PLANT MAINTENANCE ......................................................... Error! Bookmark not defined.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 5 of 69 TABLE OF CONTENTS (CONTINUED)

FIGURES FIGURE 1 PVNGS ORGANIZATION ...................................................................................... 33 FIGURE 2 PVNGS OPERATIONS ORGANIZATION ................................ 33

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 6 of 69 Arizona Public Service POLICY STATEMENT Arizona Public Service (APS) will operate Palo Verde Nuclear Generating Station (PVNGS) in a manner that will ensure the health and safety of the public and workers. These activities shall be performed in compliance with the requirements of the Code of Federal Regulations (CFR), the applicable Nuclear Regulatory Commission (NRC) Facility Operating License and applicable laws and regulations of the state and local governments.

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

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

Signed Randy Edington Executive Vice President and Chief Nuclear Officer Palo Verde Nuclear Generating Station

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 7 of 69 1.0 GENERAL The PVNGS QAPD is the top-level policy document that establishes the quality assurance policy and assigns major functional responsibilities for operational phase activities conducted by or for PVNGS. The QAPD describes the methods and establishes quality assurance (QA) and administrative control requirements that meet 10 CFR 50, Appendix B, 10 CFR 71, Subpart H, and 10 CFR 72, Subpart G. The QAPD is based on the requirements and guidance of ASME NQA-1-2008 and NQA-la-2009 Addenda, "Quality Assurance Requirements for Nuclear Facility Applications," Parts I and II, with specific reference to selected Part III sections, as identified in this document. The QA Program (QAP) is defined by the NRC-approved regulatory document that describes the QA elements (i.e., the QAPD),

along with the associated implementing documents. Procedures and instructions that control operational phase activities will be developed prior to commencement of those activities.

Policies establish high-level responsibilities and authority for carrying out important administrative functions which are outside the scope of the QAPD. Procedures establish practices for certain activities which are, common to all PVNGS organizations performing those activities so that the activity is controlled and carried out in a manner that meets QAPD requirements. Procedures specific to a site, organization, or group establish detailed implementation requirements and methods, and may be used to implement policies or be unique to particular functions or work activities.

1.1 Scope/Applicability The QAPD applies to operational phase activities affecting the quality and performance of safety-related structures, systems, and components, including, but not limited to:

Designing Storing Operating Decommissioning Receiving Maintaining Procuring Erecting Repairing Fabricating Installing Modifying Cleaning Inspecting Refueling Handling Testing Training Shipping Safety-related SSCs, under the control of the QAPD, are identified by design documents. The technical aspects of these items are considered when determining program applicability, including, as appropriate, the item's design safety function. The QAPD may be applied to certain activities where regulations other than 10 CFR 50, Appendix B, 10 CFR 71, Subpart H, and 10 CFR 72, Subpart G, establish QA requirements for activities within their scope.

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

The definitions provided in ASME NQA-1-2008 and NQA-la-2009 Addenda, Part I, Section 400, apply to select terms as used in this document.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 8 of 69 2.0 QAPD DETAILS 2.1 ORGANIZATION This section describes the PVNGS organizational structure, functional responsibilities, levels of authority and interfaces for establishing, executing, and verifying QAPD implementation. The organizational structure includes corporate support and onsite functions for PVNGS operations, including interface responsibilities for the organizations that perform quality-related functions. The overall PVNGS operating and support organizations, including reporting relationships, are illustrated in the organizational charts in Appendix A of this QAPD. Specific line responsibilities and authorities for operation of the PVNGS nuclear power plants are described in PVNGS UFSAR Section 13.1.2 and the Unit Technical Specifications.

Implementing documents assign more specific responsibilities and duties, and define the organizational interfaces involved in conducting activities and duties within the scope of the QAPD. Management gives careful consideration to the timing, extent, and effects of organizational structure changes.

2.1.1 President/CEO Arizona Public Service Company (APS), one of the owners of the Palo Verde Nuclear Generating Station (PVNGS), has the overall responsibility for management, operation and oversight of the PVNGS site nuclear facilities. The APS President and CEO is responsible for all aspects of operation of the PVNGS plants and site. The APS President and CEO is also responsible for all technical and administrative support activities provided by APS and contractors. The APS President and CEO directs the Executive Vice President Nuclear and Chief Nuclear Officer (CNO) in fulfillment of his responsibilities. The APS President and CEO reports to the APS Board of Directors with respect to all matters affecting the PVNGS.

2.1.2 Executive Vice President and Chief Nuclear Officer (CNO)

The Executive Vice President and Chief Nuclear Officer (CNO) is responsible for the safe, reliable, and efficient operation of the PVNGS nuclear facilities. The CNO provides direction to the PVNGS Senior Vice President, Site Operations and the Vice President, Regulatory and Oversight. The Director Nuclear Assurance reports to the Vice President, Regulatory and Oversight.

2.1.3 Senior Vice President, Site Operations The Senior Vice President, Site Operations is responsible for:

0 overall PVNGS site and plant management, including nuclear power plant and spent fuel storage facility operations, technical and engineering support for operations, maintenance and modifications, work management, water reclamation facility operations, industrial health and safety programs, and nuclear training activities

establishing and administering policies, providing procedures, and maintaining standards of performance that ensure safe operation of PVNGS C

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 9 of 69 ensuring site operations and technical support activities are in compliance with requirements of the operating license, applicable regulations, and regulatory commitments 2.1.3.1 Site General Plant Manager The Site General Plant Manager reports to the Senior Vice President, Site Operations and has direct line responsibility for operation and maintenance of the PVNGS nuclear plants.

This position fulfills the role of the Plant Manager as described in the PVNGS Unit Technical Specifications.

2.1.4 Vice President, Regulatory and Oversight The Vice President, Regulatory and Oversight is responsible for:

licensing and regulatory compliance functions

non-radiological environmental programs

development, maintenance, and administration of programs for independent, review and audit of operational activities affecting quality and/or nuclear safety

administration of programs for review and use of internal and external operating experience

development, maintenance and administration of the programs for corrective action and trending of conditions adverse to quality as described in the PVNGS quality assurance program for operations

appropriately delegating department responsibilities to the management positions within the regulatory and oversight organization, such that the authority and independence of the Director, Nuclear Assurance, are maintained

administration of nuclear safety culture programs, including the program to investigate, resolve, and document nuclear safety concerns

providing the overall infrastructure and administrative controls for managing PVNGS site programs, processes, and procedures; maintain the business processes and infrastructure to support this function 2.1.5 Quality Assurance The PVNGS Nuclear Assurance organization, under the direction of the Director, Nuclear Assurance, is responsible for:

establishing quality assurance program requirements via the PVNGS QAPD

independently planning and performing activities to verify effective implementation of the PVNGS Quality Assurance Program

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 10 of 69 2.1.5.1 Quality Assurance Management The Director, Nuclear Assurance reports to the Vice President, Regulatory and Oversight.

The Director, Nuclear Assurance is responsible for assuring compliance with regulatory requirements and procedures through audits and technical reviews; monitoring organizational processes to ensure conformance to commitments and licensing document requirements; and ensuring that vendors providing quality services, parts, and materials to PVNGS are meeting the requirements of 10 CFR 50, Appendix B or other pertinent regulatory requirements through joint nuclear industry or PVNGS vendor audits.

The Director, Nuclear Assurance has sufficient independence from other operational priorities to bring forward issues affecting safety and quality and makes judgments regarding quality in all areas regarding PVNGS operational activities as appropriate. The Director, Nuclear Assurance may make recommendations to the PVNGS management regarding improving the quality of work processes. The Director, Nuclear Assurance has the responsibility and authority to escalate safety or quality issues to the level of site or APS corporate management deemed appropriate to obtain satisfactory resolution. The Nuclear Assurance staff, which is outside of the line of responsibility for power production and independent of day-to-day plant operating responsibilities, includes personnel with engineering and operational expertise. The Nuclear Assurance staff performs independent review and assessment of plant activities, including plant maintenance, modifications, and operations. The Nuclear Assurance staff is expected to develop and present recommendations to plant management for such things as revised procedures or equipment modifications where useful improvements in plant safety or human performance can be achieved.

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

2.1.5.3 Quality Assurance Organizational Independence For the operational phase, independence shall be maintained between the organization(s) performing the checking (quality assurance and quality control) functions and the organizations performing the functions to the extent described in the specific sections of this QAPD.

2.1.6 Performance Improvement A management position is responsible for development, maintenance and administration of the operating experience program and the programs for corrective action and trending of conditions adverse to quality as described in the QAPD.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 11 of 69 2.1.7 Nuclear Regulatory Affairs and Environmental A management position is responsible for:

development, maintenance and administration of environmental licensing and compliance programs

development, maintenance and administration of the nuclear licensing and compliance programs

monitoring nuclear safety, engineering, operating, and environmental activities to assure activities are carried out within plant licensing and design bases and activities comply with applicable regulations o interfacing with state and federal regulatory agencies on nuclear and environmental licensing and compliance matters, including submitting routine and non-routine regulatory reports

development, maintenance, and administration of programs governing the development and maintenance of PVNGS licensing basis documents 2.1.8 Site Procedure Standards A management position is responsible for:

e development and maintenance of standards for PVNGS policies, programs and procedures

assuring that the preparation, review, and approval of PVNGS policies, programs, and procedures are carried out as specified by the PVNGS quality assurance program and administrative requirements

assisting the nuclear operations organizations in preparing, reviewing, approving, and maintaining their procedures 2.1.9 Nuclear Engineering A management position is responsible for the overall direction, administration, and supervision of the PVNGS engineering organizations.

2.1.9.1 Nuclear Fuel Management A management position is responsible for:

nuclear fuel design, contracting and utilization expertise

nuclear fuel core, and plant transient and accident analysis

operational reactor engineering support 0 alternative core operating, strategies

spent fuel storage 2.1.9.2 Design, Projects, and Plant Engineering One (or more) management position(s) is (are) responsible for:

development, maintenance, and administration of the facility design basis, including determining and documenting the quality classifications of the PVNGS facility structures, systems, components, and replacement parts

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 12 of 69 development, maintenance, and administration of engineering programs including inspections, testing, equipment qualification, configuration maintenance, nondestructive examinations, performance monitoring, erosion/corrosion monitoring, equipment root cause of failure analysis, and probabilistic risk analysis development and administration of engineering projects, including equipment design modifications and fabrication

providing technical analysis in support of plant operations and maintenance

implementation and monitoring of programs related to plant aging management

controlling software and data for plant digital process control and monitoring systems 2.1.10 Maintenance A management position is responsible for:

managing and directing maintenance, modifications, and related support activities

ensuring that the PVNGS units are maintained and modified in strict compliance with.regulatory requirements and consistent with requirements for public health and safety

managing and providing programs and procedures for control of plant maintenance

managing technical resources supporting maintenance and modification activities 2.1.11 Work Management A management position is responsible for:

developing long-term refueling cycle and outage plans;

preparing plans for accomplishing refueling, maintenance, and modifications during planned outages, with the concurrence of other departments;

directing and controlling outage work activities

acting as a central source for transferring "lessons learned" from previous outages and for developing a standardized approach toward planning and conducting outages

providing support to the units as necessary for unplanned outages

scheduling of day-to-day unit activities 2.1.12 Radiation Protection Manager The Radiation Protection Manager is responsible for:

the overall implementation and performance of the radiation protection program at PVNGS, to include radioactive waste processing and shipping, radioactive effluent activities, radiological environmental monitoring, and radioactive material control

" taking timely actions to correct substandard performance within the radiation protection program This position satisfies the requirements of the Director, Site Radiation Protection, as described in the PVNGS Unit Technical Specifications.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 13 of 69 2.1.13 Chemistry A management position is responsible for:

overall direction of plant chemistry activities for PVNGS

systems chemistry control, chemical and radiochemical sampling and analysis 2.1.14 Assistant Plant Manager(s)

Assistant Plant Manager(s) are responsible for:

0 coordinating outages and equipment reliability improvement activities 0 working in concert with other site organizations to ensure overall safe and efficient implementation of work activities

assisting the site general plant manager in developing and/or reviewing strategic plans and actions to improve overall work performance and enhance the safe and reliable operation of plant equipment 2.1.15 Nuclear Projects A management position is responsible for:

" managing quality of assigned maintenance and modification activities

" planning, scheduling, and implementing assigned maintenance and modification activities, including the management of resources and funding for assigned maintenance and modification activities 2.1.16 Operations Support A management position is responsible for:

" development, maintenance, and administration of programs for security operations, security training, access authorization, and fitness for duty

development, maintenance, and administration of programs for fire protection for the nuclear power plants, including critical support structures, systems and components, and the independent spent fuel storage facility

" development, maintenance, and administration of programs for procurement of materials and services, material control, including implementation of QC receiving inspection functions

development, maintenance and administration of the coordinated PVNGS, federal, state, and local government emergency response program for PVNGS

development, maintenance, and administration of the PVNGS document and record control programs

" information technology support for PVNGS, including administration and

" maintenance of non-process computer networks, databases, and software, and program management for the PVNGS non-process software quality assurance program

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 14 of 69 2.1.17 Water Reclamation Facility A management position is responsiblefor:

the maintenance and operation of the WRF and the incoming pipeline

supply of site water and chemicals

management of underground piping projects

maintenance and testing activities as delegated by the operating organization 2.1.18 Nuclear Training The Director, Nuclear Training has overall responsibility for the conduct and administration of training programs for the staff of PVNGS.

2.1.19 Industrial Health and Safety A management position is responsible for development, maintenance, and administration of programs promoting personnel health and safety.

2.1.20 NQA-1 Commitment In establishing its organizational structure, PVNGS commits to compliance with NQA 2008, Requirement 1.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 15 of 69 2.2 QUALITY ASSURANCE PROGRAM PVNGS has established the necessary measures and governing procedures to implement the QAP as described in the QAPD. PVNGS is committed to implementing the QAP in all aspects of work that are important to the safety of the nuclear facility, as described and to the extent delineated in the QAPD. The QAP shall include monitoring activities against acceptance criteria in a manner sufficient to provide assurance that the activities important to safety are performed satisfactorily. Further, PVNGS ensures through the systematic process described herein, that its suppliers of safety-related equipment or services meet the applicable requirements of 10 CFR Part 50, Appendix B, 10 CFR 71, Subpart H, 10 CFR 72, Subpart G, and 10 CFR Part 21. Senior management is regularly apprised of the adequacy of implementation of the QAP through the audit functions described in Section 2.18.

The objective of the QAP is to assure that PVNGS, including the Independent Spent Fuel Storage Installation (ISFSI) located at the facility, is designed, maintained, and operated in accordance with governing regulations and license requirements. The program is based on the requirements of ASME NQA-1-2008 and NQA-la-2009 Addenda, "Quality Assurance Requirements for Nuclear Facility Applications," as further described in this document. The QAP applies to those quality-related activities that involve the functions of safety-related structures, systems, and components (SSCs) associated with the design, fabrication, maintenance, testing, and safe operation of the nuclear facility and to the managerial and administrative controls to be used to assure safe operations. A list or system that identifies SSCs and activities to which this program applies is maintained at PVNGS. UFSAR 3.2 is used as the basis for this list. Cost and scheduling challenges must be addressed; however, they do not prevent proper implementation of the QAP.

As described in Sections 3.1 and 3.2 of the QAPD, specific program controls are applied to nonsafety-related SSCs that are significant contributors to plant safety, for which 10 CFR 50, Appendix B, is not applicable. The specific program controls, consistent with applicable sections of the QAPD, are applied to those items in a select manner, targeted at those characteristics or critical attributes that qualify the SSC as a significant contributor to plant safety.

Delegated responsibilities may be performed under a supplier's QAP, provided that the supplier has been approved as a supplier in accordance with the PVNGS QAP. Periodic audits and assessments of supplier QA programs are performed to assure compliance with the supplier's QAPD and implementing procedures. In addition, routine interfaces with the supplier's personnel provide added assurance that quality expectations are met.

In general, the program requirements specified herein are detailed in implementing procedures that are either PVNGS implementing procedures, or supplier implementing procedures governed by a supplier quality assurance program.

A grace period of 90 days may be applied to provisions that are required to be performed on a periodic basis, unless otherwise noted. Annual evaluations and audits that must be performed on a triennial basis are examples where the 90 day grace period could be applied.

The grace period does not allow the "clock" for a particular activity to be reset forward. The

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 16 of 69 "clock" for an activity is reset backward by performing the activity early. Audit schedules are based on the month in which the audit starts.

2.2.1 Responsibilities Personnel who work directly or indirectly for PVNGS are responsible for achieving acceptable quality in the work covered by the QAPD. This includes the activities delineated in Section 2.1.1. PVNGS personnel performing verification activities are responsible for verifying the achievement of acceptable quality. Activities governed by the QAPD are performed as directed by documented instructions, procedures, and drawings that are of a detail appropriate for the activity's complexity and effect on safety. Instructions, procedures and drawings specify quantitative or qualitative acceptance criteria as applicable or appropriate for the activity, and verification is against these criteria. Provisions are established to designate or identify-the proper documents to be used in an activity, and to ascertain that such documents are being used. The Director, Nuclear Assurance is responsible to verify that processes and procedures comply with QAPD and other applicable requirements, that such processes or procedures are implemented, and that management appropriately ensures compliance.

2.2.2 Delegation of Work PVNGS retains and exercises the responsibility for the scope and implementation of an effective QAP. Positions identified in UFSAR 13.1 and QAPD Section 2.1 may delegate all or part of the activities of planning, establishing, and implementing the program for which they are responsible to others, but retain the responsibility for the program's effectiveness.

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

2.2.3 Deleted 2.2.4 Periodic Review of the Quality Assurance Program Management of those organizations other than APS implementing the PVNGS QA program, or portions thereof, shall assess the adequacy of that part of the program for which they are responsible to assure its effective implementation at least once every two years or at least once during the life of the activity, whichever is shorter.

2.2.5 Issuance and Revision to Quality Assurance Program Administrative control of the QAPD will be in accordance with 10 CFR 50.54(a). Changes to the QAPD are evaluated by the Director, Nuclear Assurance to ensure that such changes do not degrade safety for previously approved quality assurance controls specified in the QAPD.

New revisions to the document will be reviewed, at a minimum, by the PVNGS Director Nuclear Assurance and approved by the PVNGS Executive Vice President (CNO) or the Senior Vice President, Regulatory and Oversight.

Regulations require that the Final Safety Analysis Report (FSAR) include, among other things, the managerial and administrative controls to be used to assure safe operation,

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 17 of 69 including a discussion of how the applicable requirements of 10 CFR 50, Appendix B will be satisfied. In order to comply with this requirement, the PVNGS UFSAR references the QAPD and, as a result, the requirements of 10 CFR 50.54(a) are satisfied by and apply to the QAPD.

2.2.6 Personnel Training and Qualifications Personnel assigned to implement elements of the QAPD shall be capable of performing their assigned tasks. To this end, PVNGS establishes and maintains formal indoctrination, training, and qualification as necessary for personnel performing, verifying, or managing activities within the scope of the QAPD to achieve initial proficiency, maintain proficiency, and adapt to technology changes, method, or job responsibilities. The indoctrination, training, and qualification programs are commensurate with scope, complexity, and importance of the activities; and include or address the following, as appropriate:

Education, experience, and proficiency of the personnel receiving training 0 General criteria, technical objectives, requirements of applicable codes and standards, regulatory commitments, company procedures, and quality assurance program requirements

On-the-job training, if direct hands-on applications or experience is needed to achieve and maintain proficiency Plant and support staff minimum qualification requirements are as delineated in the unit Technical Specifications. Other qualification requirements may be established but will not reduce those required by Technical Specifications.

Sufficient managerial depth is provided to cover absences of incumbents. When required by code, regulation, or standard, specific qualification and selection of personnel is conducted in accordance with those requirements as established in the applicable PVNGS procedures.

Indoctrination includes the administrative and technical objectives, requirements of the applicable codes and standards, and the QAPD elements to be employed. Training for positions identified in 10 CFR 50.120 is accomplished according to programs accredited by the National Nuclear Accrediting Board of the National Academy of Nuclear Training that implement a systematic approach to training. Records of personnel training and qualification are maintained.

The minimum qualifications of the Director, Nuclear Assurance are that he or she holds an engineering or related science degree and a minimum of four years of related experience including two years of nuclear power plant experience, one year of supervisory or management experience, and one year of the experience is in performing quality verification activities. Special requirements shall include management and supervisory skills and experience or training in leadership, interpersonal communication, management responsibilities, motivation of personnel, problem analysis and decision making, and administrative policies and procedures. Individuals who do not possess these formal education and minimum experience requirements should not be eliminated automatically when other factors provide sufficient demonstration of their abilities. These other factors are evaluated on a case-by-case basis and approved and documented by senior management.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 18 of 69 The minimum qualifications for the individuals responsible for supervising QA or QC personnel is that each has a high school diploma or equivalent and has a minimum of one year of experience performing quality verification activities. Individuals who do not possess these formal education and experience requirements should not be eliminated automatically when other factors provide sufficient demonstration of their abilities. These other factors are evaluated on a case-by-case basis and approved and documented by senior management.

The minimum qualifications of individuals that are part of the Nuclear Assurance organization responsible for planning, implementing, and maintaining the programs for the QAPD are that each has a high school diploma or equivalent and has a minimum of one year of related experience. Individuals who do not possess these formal education and minimum experience requirements should not be eliminated automatically when other factors provide sufficient demonstration of their abilities. These other factors are evaluated on a case-by-case basis and approved and documented by senior management.

2.2.7 NQA-1 Commitment / Exceptions In establishing qualification and training programs, PVNGS commits to compliance with NQA-1-2008, Requirement 2 with the following clarifications and exceptions:

Section 302, Inspection and Test (1) In lieu of Nonmandatory Appendix 2A-1, PVNGS may not establish levels of qualification/certification for inspection personnel. Instead, PVNGS may establish initial qualification requirements and determine individual qualification through evaluation of education, training and experience, and through demonstration of capability in performing the type of inspections expected on the job.

(2) Inspections, examinations or tests may be performed by individuals in the same organization as that which performed the work, provided that (a) the qualifications of the inspector for an activity are equal to or better than the minimum qualifications for persons performing the activity, (b) the work is within the skills of personnel and/or is addressed by procedures, and (c) if work involves breaching a pressure-retaining item, the quality of the work can be demonstrated through a functional test. When a, b and c are not met, inspections, examinations, or tests are carried out by individuals certified in accordance with Section 300.

Individuals performing visual inspections or nondestructive examinations required by the ASME Boiler and Pressure Vessel Code are qualified and certified according to Code requirements.

PVNGS follows Section 301 for qualification of nondestructive examination personnel, except that PVNGS will follow the applicable standard cited in the version(s) of Section III and Section XI of the ASME Boiler and Pressure Vessel Code approved by the NRC for use at PVNGS for the scope of activities governed by these cited standards.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 19 of 69

" As an alternative to Section 303.3 that prospective Lead Auditors have participated in a minimum of five (5) audits in the previous three (3) years, the following may be used for qualification of experienced individuals:

Prospective lead auditors shall demonstrate their ability to effectively implement the audit process and lead an audit team. They shall have participated in at least one audit within the year preceding the individual's effective date of qualification. Upon successful demonstration of the ability to effectively lead audits, licensee management may designate a prospective lead auditor as a "lead auditor."

Section 400(a)(8) requires the date of certification expiration be included on the qualification record. PVNGS considers the certification expiration date to be the date from the certification or recertification date plus the certification interval time, and its inclusion on the qualification record is optional.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 20 of 69 2.3 DESIGN CONTROL PVNGS has established and implements a process to control the design, design changes, and temporary modifications (e.g., temporary bypass lines, electrical jumpers and lifted wires, and temporary setpoints) of items that are subject to the provisions of the QAPD. The design process includes provisions to control design inputs, outputs, changes, interfaces, records, and organizational interfaces within PVNGS and with suppliers. These provisions assure that design inputs (such as design bases and the performance, regulatory, quality, and quality verification requirements) are correctly translated into design outputs (such as analyses, specifications, drawings, procedures, and instructions) so that the final design output contains or references appropriate acceptance criteria that can be related to the design input in sufficient detail to permit verification by inspection and test, as required.

Design change processes and the division of responsibilities for design related activities are detailed in PVNGS and supplier procedures. Changes to design inputs, final designs, field changes, and temporary and permanent modifications to the facility are justified and subject to design control measures commensurate with those applied to the original design. The design control program includes interface controls necessary to control the development, verification, approval, release, status, distribution, and revision of design inputs and outputs. Design changes and disposition of nonconforming items as "use as is" or "repair" are reviewed and approved by the PVNGS design organization or by other organizations so authorized by PVNGS.

Design documents are reviewed by individuals knowledgeable in QA to ensure the documents contain the necessary QA requirements.

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

Design verifications are performed by competent individuals or groups other than those who performed the design but who may be from the same organization. The verifier shall not have taken part in the selection of design inputs, the selection of design considerations, or the selection of a singular design approach, as applicable. This verification may be performed by the originator's supervisor provided the supervisor did not specify a singular design approach, rule out certain design considerations, and did not establish the design inputs used in the design, or if the supervisor is the only individual in the organization competent to perform the verification. If the verification is performed by the originator's supervisor, the justification of the need is documented and approved in advance by management.

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

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 21 of 69 are established and implemented to assure that an appropriate verification method is used, the appropriate design parameters to be verified are chosen, the acceptance criteria are identified, and the verification is satisfactorily accomplished and documented. Verification methods may include, but are not limited to, design reviews, alternative calculations, and qualification testing. Testing used to verify the acceptability of a specific design feature demonstrates acceptable performance under conditions that simulate the most adverse design conditions expected for the item's intended use.

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

2.3.2 Design Records PVNGS maintains records sufficient to provide evidence that the design was properly accomplished. These records include the final design output and any revisions thereto, as well as record of the important design steps (e.g., calculations, analyses and computer programs) and the sources of input that support the final output. Plant configuration documents reflect the properly reviewed and approved design of the plant.

2.3.3 Computer Application and Digital Equipment Software The QAPD governs the development, procurement, testing, maintenance, control, and use of computer applications and digital equipment software when used in safety-related applications and designated nonsafety-related applications. Computer program acceptability is pre-verified or the results verified with the design analysis for each application. Pre-verified computer programs are controlled using a software configuration management process. PVNGS and suppliers are responsible for developing, approving, and issuing procedures, as necessary, to control the use of such computer application and digital equipment software. The procedures require that the application software be assigned a proper quality classification and that the associated quality requirements be consistent with this classification. Each application software and revision thereto is documented and approved by authorized personnel. The QAPD is also applicable to the administrative functions associated with the maintenance and security of computer hardware where such functions are considered essential in order to comply with other QAPD requirements such as QA records.

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

Identify responsibilities and processes for reviewing, approving, and revising setpoints and setpoint changes supplied by a supplier, Design Certification holder, or the plant's technical staff.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 22 of 69 a Ensure that setpoints and setpoint changes are consistent with design and accident analysis requirements and assumptions.

Provide for documentation of setpoints, including those determined operationally.

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

2.3.5 NQA-1 Commitment In establishing its program for design control and verification, PVNGS commits to compliance with NQA-1-2008 and NQA-la-2009 Addenda, Requirement 3, Subpart 2.7 for computer software, and Subpart 2.14 for Quality Assurance requirements for commercial grade items and services.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 23 of 69 2.4 PROCUREMENT DOCUMENT CONTROL PVNGS has established the necessary measures and governing procedures to assure that purchased items, computer programs, and services are subject to appropriate quality and technical requirements. Procurement document changes shall be subject to the same degree of control as utilized in the preparation of the original documents. These controls include provisions such that:

Where original technical or quality assurance requirements cannot be determined, an engineering evaluation is conducted and documented by qualified staff to establish appropriate requirements and controls to assure that interfaces, interchangeability, safety, fit, and function, as applicable, are not adversely affected or contrary to applicable regulatory requirements.

Applicable technical, regulatory, administrative, quality, and reporting requirements (such as specifications, codes, standards, tests, inspections, special processes, and 10 CFR 21) are invoked for procurement of items and services. 10 CFR 21 requirements for posting, evaluating, and reporting will be followed and imposed on suppliers when applicable. Applicable design bases and other requirements necessary to assure adequate quality shall be included or referenced in documents for procurement of items and services. To the extent necessary, procurement documents shall require suppliers to have a documented QA program that is determined to meet the applicable requirements of 10 CFR 50 Appendix B, 10 CFR 71 Subpart H, or 10 CFR 72 Subpart G, as appropriate to the circumstances of procurements (or the supplier may work under PVNGS's approved QA program). Reviews of procurement documents shall be performed by personnel who have access to pertinent information and who have an adequate understanding of the requirements and intent of the procurement documents.

2.4.1 NQA-1 Commitment / Exceptions In establishing controls for procurement, PVNGS commits to compliance with NQA- 1-2008, Requirement 4, with the following clarifications and exceptions:

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

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

0 Procurement documents for Commercial Grade Items that will be procured by PVNGS for use as safety-related items shall contain technical and quality requirements such that the procured item can be appropriately dedicated in accordance with Section 2.7, "Control of Purchased Material, Equipment and Services."

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 24 of 69 2.5 INSTRUCTIONS, PROCEDURES, AND DRAWINGS PVNGS has established the necessary measures and governing procedures to ensure that activities affecting quality are prescribed by and performed in accordance with instructions, procedures, or drawings of a type appropriate to the circumstances and which, where applicable, include quantitative or qualitative acceptance criteria to implement the QAP as described in the QAPD. Such documents are prepared and controlled accordingto Section 2.6. In addition, means are provided to disseminate to the staff instructions of both general and continuing applicability, as well as those of short-term applicability. Provisions are included for reviewing, updating, and canceling such procedures.

2.5.1 Procedure Adherence PVNGS policy is that procedures are followed, and the requirements for use of procedures have been established in administrative procedures. Where procedures cannot be followed as written, provisions are established for making changes in accordance with Section 2.6.

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

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

2.5.2 Procedure Content The established measures address the applicable content of procedures as described in the Introduction to Part II of NQA-1-2008. In addition, procedures governing tests, inspections, operational activities and maintenance will include as applicable, initial conditions and prerequisites for the performance of the activity.

2.5.3 NQA-1 Commitment In establishing procedural controls, PVNGS commits to compliance with NQA-1-2008, Requirement 5.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 25 of 69 2.6 DOCUMENT CONTROL PVNGS has established the necessary measures and governing procedures to control the preparation of, issuance of, and changes to documents that specify quality requirements or prescribe how activities affecting quality, including organizational interfaces, are controlled to ensure that correct documents are employed. The following controls, including electronic systems used to make documents available, are applied to documents and changes thereto:

Identification of controlled documents

Specified distribution of controlled documents for use at the appropriate location

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

Identification of authorized personnel responsible for controlled document preparation, review, approval, and distribution

" Review of controlled documents for adequacy, completeness, and approval prior to distribution

" A method to ensure the correct documents are being used

A method to provide feedback from users to improve procedures and work instructions

Coordinating and controlling interface documents and procedures The types of documents to be controlled include:

Drawings such as design, installation, and as-built drawings

Engineering calculations

Design specifications

Purchase orders and related documents

Vendor-supplied documents

Audit, surveillance, and quality verification/inspection procedures

Inspection and test reports

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

" Technical specifications

" Nonconformance reports and corrective action reports Where temporary procedures are used, they shall include a designation of the period of time during which it is acceptable to use them.

2.6.1 Review and Approval of Documents Documents are reviewed for adequacy by qualified person(s) other than the preparer. The documented review signifies concurrence.

Documents affecting the configuration or operation of the station as described in the UFSAR are screened to identify those that require review by the Independent Review Body prior to implementation as described in QAPD Section 5.2.2.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 26 of 69 To ensure effective and accurate procedures, applicable procedures are reviewed, and updated as necessary, based on the following conditions:

Following any modification to a system

Following an unusual incident, such as an accident, significant operator error, or equipment malfunction

When procedure discrepancies are found -

" Prior to use if not used in the previous two years

Results of QA audits conducted in accordance with QAPD Section 2.18.1 Prior to issuance or use, documents including revisions thereto, are approved by the designated authority. A listing of all controlled documents identifying the current approved revision, or date, is maintained so personnel can readily determine the appropriate document for use.

2.6.2 Changes to Documents Changes to documents, other than those defined in implementing procedures as minor changes, are reviewed and approved by the same organizations that performed the original review and approval unless other organizations are specifically designated. The reviewing organization has access to pertinent background data or information upon which to base their approval. Where temporary procedure changes are necessary, changes that clearly do not change the intent of the approved procedure may be implemented provided they are approved by two members of the staff knowledgeable in the areas affected by the procedures.

Minor changes to documents, such as inconsequential editorial corrections, do not require that the revised documents receive the same review and approval as the original documents.

To avoid a possible omission of a required review, the type of minor changes that do not require such a review and approval and the persons who can authorize such a classification shall be clearly delineated in implementing procedures.

2.6.3 NQA-1 Commitment In establishing provisions for document control, PVNGS commits to compliance with NQA 2008, Requirement 6.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 27 of 69 2.7 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES PVNGS has established the necessary measures and governing procedures to control purchased items and services to assure conformance with specified requirements. Such control provides for the following as appropriate: source evaluation and selection, evaluation of objective evidence of quality furnished by the supplier, source inspection, audit, and examination of items or services.

2.7.1 Acceptance of Item or Service PVNGS establishes and implements measures to assess the quality of purchased items and services, whether purchased directly or through contractors, at intervals and to a depth consistent with the item or service importance to safety, complexity, quantity, and the frequency of procurement. Verification actions include testing, as appropriate, during design, fabrication, and operation activities. Verifications occur at the appropriate phases of the procurement process, including, as necessary, verification of activities of suppliers below the first tier. Measures to assure the quality of purchased items and services include the following, as applicable:

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

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

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

Provisions are made for accepting purchased items and services, such as source verification, receipt inspection, pre- and post-installation tests, certificates of conformance, and document reviews (including Certified Material Test Report/Certificate). Acceptance actions/documents should be established by the Purchaser with appropriate input from the Supplier and be completed to ensure that procurement, inspection, and test requirements, as applicable, have been satisfied before relying on the item to perform its intended safety function.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 28 of 69

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

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

2.7.2 NQA-1 Commitment / Exceptions In establishing controls for purchased items and services, PVNGS commits to compliance with NQA-la-2009, Requirement 7, with the following clarifications and exceptions:

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

When purchasing commercial grade calibration services from a calibration laboratory, procurement source evaluation and selection measures need not be performed provided each of the following conditions are met:

- The purchase documents impose any additional technical and administrative requirements, as necessary, to comply with the PVNGS QA program and technical provisions. At a minimum, the purchase documents shall require that the calibration certificates/reports include identification of the laboratory equipment/standards used.

- The purchase documents require reporting as-found calibration data when calibrated items are found to be out-of-tolerance.

- A documented review of the supplier's accreditation will be performed and will include a verification of the following:

o The calibration laboratory holds a domestic (United States) accreditation by an NRC-approved accrediting body recognized by the International Laboratory Accreditation Cooperation (ILAC) Mutual Recognition Arrangement (MRA).

o The accreditation encompasses ANSI/ISO/IEC 17025, "General Requirements for the Competence of Testing and Calibration Laboratories."

o The published scope of accreditation for the calibration laboratory covers the necessary measurement parameters, range, and uncertainties.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 29 of 69 For Section 501, PVNGS considers documents that may be stored in approved electronic media under PVNGS or vendor control, not physically located on the PVNGS site, but accessible from the respective nuclear facility site as meeting the NQA-1 requirement for documents to be available at the site. The PVNGS records management system will provide for timely retrieval of necessary records.

In establishing commercial grade item requirements, PVNGS commits to compliance with NQA-la-2009, Section 700 and Subpart 2.14, with the following clarification:

- For commercial grade items, quality verification requirements are established and described in PVNGS documents to provide the necessary assurance an item will perform satisfactorily in service. The PVNGS documents address determining the critical characteristics that ensure an item is suitable for its intended use, technical evaluation of the item, receipt requirements, and quality evaluation of the item.

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

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 30 of 69 2.8 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS PVNGS has established the necessary measures and governing procedures to identify and control items to prevent the use of incorrect or defective items. This includes controls for consumable materials and items with limited shelf life. The identification of items is maintained throughout fabrication, erection, installation, and use so that the item can be traced to its documentation, consistent with the item's effect on safety. Identification locations and methods are selected so as not to affect the function or quality of the item.

2.8.1 NQA-1 Commitment In establishing provisions for identification and control of items, PVNGS commits to compliance with NQA-1-2008, Requirement 8.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 31 of 69 2.9 CONTROL OF SPECIAL PROCESSES PVNGS has established the necessary measures and governing procedures to assure that special processes that require interim process controls to assure quality, such as welding, heat treating, and nondestructive examination, are controlled. These provisions include assuring that special processes are accomplished by qualified personnel using qualified procedures and equipment. Personnel are qualified and special processes are performed in accordance with applicable codes, standards, specifications, criteria or other specially established requirements. Special processes are those where the results are highly dependent on the control of the process or the skill of the operator, or both, and for which the specified quality cannot be fully and readily determined by inspection or test of the final product.

2.9.1 NQA-1 Commitment In establishing measures for the control of special processes, PVNGS commits to compliance with NQA-1-2008, Requirement 9.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 32 of 69 2.10 INSPECTION PVNGS has established the necessary measures and governing procedures to implement inspections that assure items, services, and activities affecting safety meet established requirements and conform to applicable documented specifications, instructions, procedures, and design documents. Inspections may also be applied to items, services, and activities affecting plant reliability and integrity. Types of inspections may include those verifications related to procurement, such as source, in-process, final, and receipt inspection, as well as installation, maintenance, modification, in-service, and operations activities. Inspections are carried out by properly qualified persons independent of those who performed or directly supervised the work. Inspection results are documented.

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

(1) at the source of supplied items or services, (2) in-process during fabrication at a supplier's facility or at PVNGS, (3) for final acceptance of fabricated and/or installed items, and (4) upon receipt of items for PVNGS, as well as (5) during maintenance, modification, in-service, and operating activities.

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

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

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

2.10.2 Inspector Qualification PVNGS has established qualification programs for personnel performing quality inspections.

The qualification program requirements are described in QAPD Section 2.2. These qualification programs are applied to individuals performing quality inspections regardless of the functional group where they are assigned.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 33 of 69 2.10.3 NQA-1 Commitment / Exceptions In establishing inspection requirements, PVNGS commits to compliance with NQA-1-2008 and NQA-la-2009, Requirement 10 and Part II, Subparts 2.4 and 2.8 for establishing appropriate inspection requirements with the following clarifications:

Subpart 2.4 commits PVNGS to IEEE 336-1985, which refers to IEEE 498-1985. Both IEEE 336-1985 and IEEE 498-1985 use the definition of "Safety Systems" from IEEE 603-1980. PVNGS commits to the definition of Safety Systems in IEEE 603-1980, but does not commit to the balance of that standard. This definition is only applicable to equipment in the context of Subpart 2.4.

An additional exception to Subpart 2.4 is addressed in QAPD Section 2.12.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 34 of 69 2.11 TEST CONTROL PVNGS has established the necessary measures and governing procedures to demonstrate that items subject to the provisions of the QAPD will perform satisfactorily in service, that the plant can be operated safely and as designed, and that the coordinated operation of the plant as a whole is satisfactory. These programs include criteria for determining when testing is required, such as proof tests before installation, post-maintenance tests, post-modification tests, in-service tests, and operational tests (such as surveillance tests required by Plant Technical Specifications), to demonstrate that performance of plant systems is in accordance with design. Programs also include provisions to establish and adjust test schedules, and to maintain status for periodic or recurring tests.

Tests are performed according to applicable procedures that include, consistent with the effect on safety:

(1) instructions and prerequisites to perform the tests, (2) use of proper test equipment, (3) acceptance criteria, and (4) mandatory verification points as necessary to confirm satisfactory test completion.

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

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

Except for computer program testing, which is addressed in QAPD Section 2.11.1, tests are performed and results documented in accordance with applicable technical and regulatory requirements, including those described in the Technical Specifications and UFSAR. Test programs ensure appropriate retention of test data in accordance with the records requirements of the QAPD. Personnel that perform or evaluate tests are qualified in accordance with the requirements established in QAPD Section 2.2.

2.11.1 NQA-1 Commitment for Computer Program Testing PVNGS establishes and implements provisions to assure that computer software used in applications affecting safety is prepared, documented, verified and tested, such that the expected output is obtained and configuration control maintained. To this end PVNGS commits to compliance with the requirements of NQA-la-2009, Requirement 11 and Subpart 2.7 to establish the appropriate provisions in addition to the commitment to NQA-1-2008, Requirement 3.

2.11.2 NQA-1 Commitment In establishing provisions for testing, PVNGS commits to compliance with NQA-la- 2009, Requirement 11.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 35 of 69 2.12 CONTROL OF MEASURING AND TEST EQUIPMENT PVNGS has established the necessary measures and governing procedures to control the calibration, maintenance, and use of measuring and test equipment (M&TE) that provides data to verify acceptance criteria are met for information important to safe plant operation.

The provisions of such procedures cover equipment such as indicating and actuating instruments and gages, tools, reference and transfer standards, and nondestructive examination equipment. The suppliers of commercial grade calibration services are controlled as described in QAPD Section 2.7.

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

2.12.2 NQA-1 Commitment / Exceptions In establishing provisions for control of measuring and test equipment, PVNGS commits to compliance with NQA-1-2008 and NQA-la-2009, Requirement 12 with the following clarification and exception:

NQA-1-2008, Subpart 2.4 refers to ANSJIIEEE Std. 336-1985 for the installation, inspection, and testing requirements for power, instrumentation, and control equipment at nuclear facilities. Where ANSI/IEEE Std. 336-1985 makes reference to the use of IEEE Std. 498-1985 for measuring and test equipment control, PVNGS will implement the QA requirements of NQA 2008, Requirement 12.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 36 of 69 2.13 HANDLING, STORAGE, AND SHIPPING PVNGS has established the necessary measures and governing procedures to control the handling, storage, packaging, shipping, cleaning, and preservation of items to prevent inadvertent damage 'or loss, and to minimize deterioration. These provisions include specific procedures, when required to maintain acceptable quality of the items important to the safe operations of the plant. Items are appropriately marked and labeled during packaging, shipping, handling, and storage to identify, maintain, and preserve the item's integrity and indicate the need for special controls. Special controls (such as containers, shock absorbers, accelerometers, inert gas atmospheres, specific moisture content levels, and temperature levels) are provided when required to maintain acceptable quality.

Special or additional handling, storage, shipping, cleaning, and preservation requirements are identified and implemented as specified in procurement documents and applicable procedures. Where special requirements are specified, the items and containers (where used) are suitably marked.

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

Operators of special handling and lifting equipment are experienced or trained in the use of the equipment. PVNGS establishes and implements controls over hoisting, rigging, and transport activities to the extent necessary to protect the integrity of the items involved, as well as potentially affected nearby structures and components. Where required, PVNGS complies with applicable hoisting, rigging and transportation regulations and codes.

2.13.1 Housekeeping Housekeeping practices are established to account for conditions or environments that could affect the quality of structures, systems, and components within the plant. This includes control of cleanliness of facilities and materials, fire prevention and protection, disposal of combustible material and debris, control of access to work areas, and protection of equipment, as well as, radioactive contamination control, and storage of solid radioactive waste. Housekeeping practices help assure that only proper materials, equipment, processes, and procedures are used and that the quality of items is not degraded. Necessary procedures or work instructions, such as for electrical bus and control center cleaning, and cleaning of control consoles, and radioactive decontamination are developed and used.

2.13.2 NQA-1 Commitment / Exceptions In establishing provisions for handling, storage, and shipping, PVNGS commits to compliance with NQA-1-2008, Requirement 13. PVNGS also commits to compliance with the requirements of NQA-1-2008 and NQA-la-2009, Part II, Subpart 2.1, Subpart 2.2, Subpart 2.3, and Part III, Subpart 3.2, Appendix 2.1, with the following clarifications and exceptions:

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 37 of 69 NQA-1-2008 and NQA-la-2009, Part II, Subpart 2.1 Subpart 2.1, Section 301 and 302 establish criteria for classifying items into cleanness classes and requirements for each class. Instead of using the cleanness level system of Subpart 2.1, PVNGS may establish cleanness requirements on a case-by-case basis, consistent with the other provisions of Subpart 2.1. PVNGS establishes appropriate cleanliness controls for work on safety-related equipment to minimize introduction of foreign material and maintain system/component cleanliness throughout maintenance or modification activities, including documented verification of absence of foreign material prior to system closure.

NQA-la-2009, Part II, Subpart 2.2

Subpart 2.2, Section 201 establishes criteria for classifying items into protection levels.

Instead of classifying items into protection levels during the operational phase, PVNGS may establish controls for the packaging, shipping, handling, and storage of such items on a case-by-case basis with due regard for the item's complexity, use, and sensitivity to damage. Prior to installation or use, the items are inspected and serviced as necessary to assure that no damage or deterioration exists which could affect their function.

Subpart 2.2, Section 606, "Storage Records": This section requires written records be prepared containing information on personnel access. As an alternative to this requirement, PVNGS documents establish controls for storage areas that describe those authorized to access areas and the requirements for recording access of personnel.

However, these records of access are not considered quality records and will be retained in accordance with the administrative controls established for PVNGS.

NQA-1-2008 and NQA-la-2009, Part II, Subpart 2.3 Subpart 2.3, Section 202 requires the establishment of five zone designations for housekeeping cleanliness controls. Instead of the five-level zone designation, PVNGS may base its control over housekeeping activities on a consideration of what is necessary and appropriate for the activity involved. The controls are implemented through procedures or instructions which, in the case of maintenance or modification work, may be developed on a case-by-case basis. Factors considered in developing the procedures and instructions include cleanliness control, personnel safety, fire prevention and protection, radiation control, and security. The procedures and instructions make use of standard janitorial and work practices to the extent possible.

NQA-la-2009, Part III, Subpart 3.2 Subpart 3.2, Appendix 2.1: Only Section 300, "Cleaning Recommendations and Precautions" are being committed to in accordance with RG 1.37. In addition, a suitable chloride stress-cracking inhibitor should be added to the fresh water used to flush systems containing austenitic stainless steels.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 38 of 69 2.14 INSPECTION, TEST, AND OPERATING STATUS PVNGS has established the necessary measures and governing procedures to identify the inspection, test, and operating status of items and components subject to the provisions of the QAPD in order to maintain personnel and reactor safety and avoid inadvertent operation of equipment. Where necessary to preclude inadvertent bypassing of inspections or tests, or to preclude inadvertent operation, these measures require the inspection, test, or operating status be verified before release, fabrication, receipt, installation, test or use. These measures also establish the necessary authorities and controls for the application and removal of status indicators or labels.

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

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

2.14.1 NQA-1 Commitment In establishing measures for control of inspection, test and operating status, PVNGS commits to compliance with NQA-1-2008, Requirement 14.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 39 of 69 2.15 NONCONFORMING MATERIALS, PARTS, OR COMPONENTS PVNGS has established the necessary measures and governing procedures to control items, including services that do not conform to specified requirements to prevent inadvertent installation or use. Instructions require that the individual discovering a nonconformance identify, describe, and document the nonconformance in accordance with the requirements of QAPD Section 2.16. Controls provide for identification, documentation, evaluation, segregation when practical, and disposition of nonconforming items, and for notification to affected organizations. Controls are provided to address conditional release of nonconforming items for use on an at-risk basis prior to resolution and disposition of the nonconformance, including maintaining identification of the item and documenting the basis for such release. Conditional release of nonconforming items for installation requires the approval of the designated management. Nonconformances are corrected or resolved prior to depending on the item to perform its intended safety function. Nonconformances are evaluated for impact on operability of quality structures, systems, and components to assure that the final condition does not adversely affect safety, operation, or maintenance of the item or service. Nonconformances to design requirements dispositioned repair or use-as-is are subject to design control measures commensurate with those applied to the original design. Nonconformance dispositions are reviewed for adequacy, analysis of quality trends, and reports provided to the designated management. Significant trends are reported to management in accordance with PVNGS procedures, regulatory requirements, and industry standards.

2.15.1 Interface with the Reporting Program PVNGS has appropriate interfaces between the QAP for identification and control of nonconforming materials, parts, or components and the non-QA Reporting Program to satisfy the requirements of 10 CFR 21.

2.15.2 NQA-1 Commitment In establishing measures for nonconforming materials, parts, or components, PVNGS commits to compliance with NQA-1-2008, Requirement 15 with the following clarifications and exceptions:

0 For Section 200, "Identification", PVNGS considers other means of identification acceptable when marking or tagging on either the item, the container, or the package containing the item is not practical.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 40 of 69 2.16 CORRECTIVE ACTION PVNGS has established the necessary measures and governing procedures to promptly identify, control, document, classify, and correct conditions adverse to quality. PVNGS procedures assure that corrective actions are documented and initiated following the determination of conditions adverse to quality in accordance with regulatory requirements and applicable quality standards. PVNGS procedures require personnel to identify known conditions adverse to quality. When complex issues arise where it cannot be readily determined if a condition adverse to quality exists, PVNGS documents establish the requirements for documentation and timely evaluation of the issue. Reports of conditions adverse to quality are analyzed to identify trends. Significant conditions adverse to quality and significant adverse trends are documented and reported to responsible management. In the case of a significant condition adverse to quality, the cause is determined and actions to preclude recurrence are taken.

In the case of suppliers working on safety-related activities, or other similar situations, PVNGS may delegate specific responsibilities for corrective actions but PVNGS maintains responsibility for the effectiveness of corrective act ion measures.

2.16.1 Interface with the Reporting Program PVNGS has appropriate interfaces between the QAP for corrective actions and the non-QA Reporting Program to satisfy the requirements of 10 CFR 21.

2.16.2 NQA-1 Commitment In establishing provisions for corrective action, PVNGS commits to compliance with NQA 2008, Requirement 16.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 41 of 69 2.17 QUALITY ASSURANCE RECORDS PVNGS has established the necessary measures and governing procedures to ensure that sufficient records of items and activities affecting quality are developed, reviewed, approved, issued, used, and revised to reflect completed work. The provisions of such procedures establish the scope of the records retention program for PVNGS and include requirements for records administration, including receipt, preservation, retention, storage, safekeeping, retrieval, access controls, user privileges, and final disposition.

2.17.1 Record Retention Measures are established that ensure sufficient records of completed items and activities affecting quality are appropriately stored. Records of activities for design, engineering, procurement, manufacturing, construction, inspection and testing, installation, pre-operation, startup, operations, maintenance, modification, decommissioning, and audits and their retention times are defined in appropriate procedures. For design, construction, and initial start-up activities, the records to be maintained and their retention times are based on previous PVNGS commitments to Regulatory Guide 1.28, Revision 0, and Regulatory Guide 1.88, Revision 2. For operational phase activities, records to be maintained and their retention times are based on PVNGS commitment to Regulatory Guide 1.28, Revision 4, and the list of typical lifetime records provided in NQA-1-2008, Part III, Nonmandatory Appendix 17A-1, Section 200. In all cases where state, local, or other agencies have more restrictive requirements for record retention, those requirements will be met.

2.17.2 Electronic Records When using optical disks for electronic records storage and retrieval systems, PVNGS complies with the NRC guidance in Generic Letter 88-18, Plant Record Storage on Optical Disks. PVNGS will manage the storage of QA Records in electronic media consistent with the intent of RIS 2000-18 and associated NIRMA Guidelines TG11-2011, TG15-2011, TG16-2011, and TG21-2011.

2.17.3 NQA-1 Commitment / Exceptions In establishing provisions for records, PVNGS commits to compliance with NQA 2008, Requirement 17, and regulatory positions stated in Regulatory Guide 1.28, Rev 4, June 2010.

In establishing the provisions for managing electronic records, PVNGS commits to comply with Regulatory Guide 1.28, Revision 4, position C.l.b(2) with the following clarification:

In lieu of adopting NIRMA Guidelines TG11-1998, TG15-1998, TG16-1998, and TG21-1998, PVNGS adopts TG11-2011, TG15-2011, TG16-2011, and TG21-2011.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 42 of 69 2.18 AUDITS PVNGS has established the necessary measures and governing procedures to implement audits to verify that activities covered by the QAPD are performed in conformance with the established requirements and performance criteria are met. The audit programs are themselves reviewed for effectiveness as a part of the overall audit process.

2.18.1 Performance of Audits Internal audits of selected aspects of operating phase activities are performed with a frequency commensurate with safety significance and in a manner which assures that audits of safety-related activities are completed. Functional areas of an organization's QA program for auditing include, at a minimum, verification of compliance and effectiveness of implementation of internal rules and procedures (e.g., operating, design, procurement, maintenance, modification, refueling, surveillance, test, security, radiological protection procedures, and the emergency plan), Technical Specifications, regulations and license conditions, programs for training, retraining, qualification and performance of operating staff, corrective actions, and observation of performance of operating, refueling, maintenance, and modification activities, including associated record keeping.

The audits are scheduled on a formal preplanned audit schedule and in a manner to provide coverage and coordination with ongoing activities, based on the status and importance of the activity. Additional audits may be performed as deemed necessary by management. The scope of the audit is determined by the quality status and safety importance of the activities being performed. These audits are conducted by trained personnel not having direct responsibilities in the area being audited and in accordance with preplanned and approved audit plans or checklists, under the direction of a qualified lead auditor and the cognizance of the Director Nuclear Assurance.

PVNGS is responsible for conducting periodic internal audits to determine the adequacy of programs and procedures and to determine if they comply with the overall QAPD.

The results of each audit are reported in writing to the Senior Vice President, Site Operations, and the Chief Nuclear Officer or designee, as appropriate. Additional internal distribution is made to concerned management levels and to management of the internal audited organizations or activities in accordance with approved procedures.

Management responds to all audit findings and initiates corrective action where indicated in accordance with the PVNGS corrective action program. Where corrective action measures are indicated, documented follow-up of applicable areas through inspections, reviews, re-audits, or other appropriate means is conducted to verify implementation of assigned corrective action.

Audits of suppliers of safety-related components and/or services are conducted as described in QAPD Section 2.7.1.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 43 of 69 2.18.2 Internal Audits Internal audits of operational activities are performed at a frequency commensurate with the safety significance and in such a manner as to assure that an audit of all applicable QA program elements is completed for each functional area within a period of two years.

Internal audit frequencies of well established activities may be extended one year at a time beyond the above two-year interval based on the results of an annual evaluation of the applicable functional area and objective evidence that the functional area activities are being satisfactorily accomplished. The evaluation should include a detailed performance analysis of the functional area based upon applicable internal and external source data and due consideration of the impact of any functional area changes in responsibility, resources, or management. However, the internal audit frequency interval should not exceed a maximum of four years. If performance dictates, the extension of the internal audit frequency interval for the applicable functional area should be rescinded and an audit scheduled as soon as practicable.

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

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

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

The performance, training, and qualifications of the facility staff

The performance of activities required by the QAPD to meet the criteria of 10 CFR 50, Appendix B

The Fire Protection Program and implementing procedures. A fire protection equipment and program implementation inspection and audit are conducted utilizing either a qualified off-site licensed fire protection engineer or an outside qualified fire protection consultant

" Other activities and documents considered appropriate by the Senior Vice President, Site Operations, or the Chief Nuclear Officer Audits may also be used to meet the periodic review requirements of the code for the Security, Emergency Preparedness, and Radiological Protection programs within the provisions of the applicable code.

2.18.3 NQA-1 Commitment In establishing the independent audit program, PVNGS commits to compliance with NQA 2008, Requirement 18 and the regulatory positions stated in Regulatory Guide 1.28, Revision 4.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 44 of 69 3.0 NONSAFETY-RELATED SSC QUALITY CONTROL 3.1 NONSAFETY-RELATED SSCS - SIGNIFICANT CONTRIBUTORS TO PLANT SAFETY Specific program controls are applied to nonsafety-related SSCs, for which 10 CFR 50, Appendix B is not applicable, that are significant contributors to plant safety. The specific program controls consistent with applicable sections of the QAPD are applied to those items in a selected manner, targeted at those characteristics or critical attributes that render the SSC a significant contributor to plant safety. The following clarify the applicability of the QA Program to the nonsafety-related SSCs and related activities, including the identification of exceptions to the QA Program described in QAPD Sections 2.1 through 2.18 that are taken for nonsafety- related SSCs.

3.1.1 Organization The verification activities described in this part may be performed by the PVNGS line organization. The QA organization described in QAPD Section 2.1.3 is not required to perform these functions.

3.1.2 QA Program PVNGS QA requirements for nonsafety-related SSCs are established in the QAPD and appropriate procedures. Suppliers of these SSCs or related services describe the quality controls applied in appropriate procedures. A new or separate QA program is not required.

3.1.3 Design Control PVNGS has design control measures to ensure that the contractually established design requirements are included in the design. These measures ensure that applicable design inputs are included or correctly translated into the design documents, and deviations from those requirements are controlled. Design verification is provided through the normal supervisory review of the designer's work.

3.1.4 Procurement Document Control Procurement documents for items and services obtained by or for PVNGS include or reference documents describing applicable design bases, design requirements, and other requirements necessary to ensure component performance. The procurement documents are controlled to address deviations from the specified requirements.

3.1.5 Instructions, Procedures, and Drawings PVNGS provides documents such as, but not limited to, written instructions, plant procedures, drawings, vendor technical manuals, and special instructions in work orders, to direct the performance of activities affecting quality. The method of instruction employed provides an appropriate degree of guidance to the personnel performing the activity to achieve acceptable functional performance of the SSC.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 45 of 69 3.1.6 Document Control PVNGS controls the issuance and change of documents that specify quality requirements or prescribe activities affecting quality to ensure that correct documents are used. These controls include review and approval of documents, identification of the appropriate revision for use, and measures to preclude the use of superseded or obsolete documents.

3.1.7 Control of Purchased Items and Services PVNGS employs measures, such as inspection of items or documents upon receipt or acceptance testing, to ensure that all purchased items and services conform to appropriate procurement documents.

3.1.8 Identification and Control of Purchased Items PVNGS employs measures where necessary, to identify purchased items and preserve their functional performance capability. Storage controls take into account appropriate environmental, maintenance, or shelf life restrictions for the items.

3.1.9 Control of Special Processes PVNGS employs process and procedure controls for special processes, including welding, heat treating, and nondestructive testing. These controls are based on applicable codes, standards, specifications, criteria, or other special requirements for the special process.

3.1.10 Inspection PVNGS uses documented instructions to ensure necessary inspections are performed to verify conformance of an item or activity to specified requirements or to verify that activities are satisfactorily accomplished. These inspections may be performed by knowledgeable personnel in the line organization. Knowledgeable personnel are from the same discipline and have experience related to the work being inspected.

3.1.11 Test Control PVNGS employs measures to identify required testing that demonstrates that equipment conforms to design requirements. These tests are performed in accordance with test instructions or procedures. The test results are recorded, and authorized individuals evaluate the results to ensure that test requirements are met.

3.1.12 Control of Measuring and Test Equipment (M&TE)

PVNGS employs measures to control M&TE use, and calibration and adjustment at specific intervals or prior to use.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 46 of 69 3.1.13 Handling, Storage, and Shipping PVNGS employs measures to control the handling, storage, cleaning, packaging, shipping, and preservation of items to prevent damage or loss and to minimize deterioration. These measures include appropriate marking or labels, and identification of any special storage or handling requirements.

3.1.14 Inspection, Test, and Operating Status PVNGS employs measures to identify items that have satisfactorily passed required tests and inspections and to indicate the status of inspection, test, and operability, as appropriate.

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

3.1.16 Corrective Action PVNGS employs measures to ensure that failures, malfunctions, deficiencies, deviations, defective components, and nonconformances are properly identified, reported, and corrected.

3.1.17 Records PVNGS employs measures to ensure records are prepared and maintained to furnish evidence that the above requirements for design, procurement, document control, inspection, and test activities have been met.

3.1.18 Audits PVNGS employs measures for line management to periodically review and document the adequacy of the process, including taking any necessary corrective action. Audits independent of line management are not required. Line management is responsible for determining whether reviews conducted by line management or audits conducted by any organization independent of line management are appropriate. If performed, audits are conducted and documented to verify compliance with design and procurement documents, instructions, procedures, drawings, and inspection and test activities. Where the measures of QAPD Section 3.0 are implemented by the same programs, processes, or procedures as the comparable activities of QAPD Section 2.0, the audits performed under the provisions of QAPD Section 18.0 may be used to satisfy the review requirements of 3.1.18.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 47 of 69 3.2 NON-SAFETY-RELATED SSCS CREDITED FOR REGULATORY EVENTS The following criteria apply to fire protection (10 CFR 50.48), anticipated transients without scram (ATWS) (10 CFR 50.62), and the station blackout (SBO) (10 CFR 50.63) SSCs that are not safety-related:

PVNGS implements quality requirements for the fire protection system in accordance with Section C to Appendix A of Branch Technical Position 9.5-1. Implementation is described in UFSAR 9B.3.1.

a PVNGS implements the quality requirements for ATWS equipment in accordance with QAPD Section 3.1.

PVNGS implements quality requirements for SBO equipment in accordance with QAPD Section 3.1.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 48 of 69 4.0 REGULATORY COMMITMENTS NRC Regulatory Guides and Quality Assurance Standards This section identifies the NRC Regulatory Guides (RG) and the other quality assurance standards which have been selected to supplement and support the PVNGS QAPD. PVNGS complies with these standards to the extent described or referenced. Commitment to a particular RG or standard does not constitute a commitment to other RGs or standards that may be referenced therein.

Regulatory Guide 1.8, Revision 1-R, September 1975, Personnel Selection and Training Regulatory Guide 1.8, Revision 1-R, was issued for comment in September of 1975. This same Regulatory Guide was re-issued in May of 1977 without any changes except the words "For Comment" were deleted. For the purposes of conformance to this guide, the 1975 and 1977 versions are considered the same.

The position of Regulatory Guide 1.8 is accepted with the following exceptions and clarifications:

A. Where Part C to the guide discusses ANSI N18.1-1971 as the criteria for the selection and training of nuclear power plant personnel, ANSI/ANS 3.1-1978 is substituted.

B. Where Part C to the guide provides additional guidance for the Radiation Protection Manager, the guidance of ANSI/ANS 3.1-1978 is substituted. Regulatory Guide 1.8, Part C, as it pertains to the Radiation Protection Manager, is equivalent to the requirements of ANSI/ANS 3.1-1978, Section 4.4.4. Both Regulatory Guide 1.8 and ANSI/ANS 3.1-1978 require a bachelor's degree or equivalent. APS has defined equivalency using an NRC approved change in accordance with the requirements of 10 CFR 50.54(a)3(ii).

Equivalence is defined below and is not an exception to Technical Specification 5.3.1.

C. Where equivalency to a bachelor's degree is permitted by the applicable regulatory guide or the endorsed industry standards, a high school education plus the following qualifications may be considered equivalent to the bachelor's degree:

1. 4 years of post-secondary schooling in science or engineering, or

2. 6 years of applied experience at a nuclear facility in the area for which qualification is sought, or

3. 6 years of operational or technical experience/training in nuclear power, or

4. Any combination of the above totaling 6 years.

Any years of experience credited to meet the education (degree) requirement, as described above, shall not also be credited to meet any additional experience required by the standard.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 49 of 69 D. For those individuals not already qualified by experience and education in their designated craft or discipline and where ANSI/ANS 3.1-1978 permits the use of related training to meet certain qualifications (examples include sections 3.2.4 and 5.3.1-5.3.4),

appropriate training and qualification shall be provided to demonstrate capability to perform assigned tasks. Additional training program requirements for the nuclear power plant staff are described at UFSAR 13.2 and the pertinent section of the PVNGS Operations Quality Assurance Program Description.

E. The experience requirements of NUREG 1021, Rev. 8, ES- 202, "Preparing and Reviewing Operator License Applications" are satisfied in lieu of experience requirements of ANSI/ANS 3.1, paragraph 4.3.1, Supervisors Requiring NRC Licenses, for individuals filling the position of LSRO.

F. Qualifications of the quality assurance manager, quality assurance personnel, and quality control inspectors are as described in the pertinent sections of the PVNGS Operations Quality Assurance Program Description.

REGULATORY GUIDE 1.26, Revision 1, September 1974 Quality Group Classifications and Standards for Water, Steam and Radioactive-Waste-Containing Components of Nuclear Power Plants Equipment classification and code requirements are described in UFSAR 3.2. Quality Group classification and code requirements for each quality group correspond to those indicated in Regulatory Guide 1.28, Revision 1, with the following exceptions:

A. Positions C.1 and C.2 For Quality Group B and C instrument lines for safety related instruments, the instrument piping, tubing, and fittings downstream of the instrument root valves will be the same quality group classification as the root valve. The instrument valves will be Quality Group D.

B. Position C.1 for the Quality Group B Refueling Water Tank and Position C.2 for the Quality Group C Condensate Storage Tank These tanks are of concrete construction with a stainless steel liner for maintenance of water quality and are not constructed to the ASME Boiler and Pressure Vessel Code,Section III.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 50 of 69 C. Positions C.l.d, C.l.e, C.2.c, and Footnote 4 The words "or remote manual" are considered to be inserted between the words "automatic" and "closure." This option is included to avoid an unnecessary complication (leading to decreased plant reliability) in lines which would not normally be provided with automatic closing valves.

D. Position C.l.d Specific exceptions taken to placing main steam and feedwater lines in Quality Group B are as follows: The branch line size limitation of application of Seismic Category I requirements, indicated in Regulatory Guide 1.29, is also applied to quality group classification. Therefore, branch lines 2 inches nominal pipe size and under, excluding containment penetrations, are placed in Quality Group D.

E. Position C.2.a The requirement that systems providing cooling for the spent fuel pool be placed in Quality Group C is interpreted to apply only to the minimum systems required during an emergency condition and not necessarily to those systems normally providing such cooling.

F. Position C.2.b The seal water injection lines to the reactor coolant pumps are constructed to ASME Section III Class 2 requirements, although the cooling water lines to the shell side of the seal water heat exchanger are constructed to Quality Group D requirements as are the cooling water lines for the reactor coolant pump motors. This piping is quality Group D because the cooling water is not required for safe shutdown of the reactor as the reactor coolant pumps can coast down without the benefit of this cooling water.

In the normal borated makeup flowpath, a coriolis type flow sensor was selected to provide reliable and accurate measurement of flow rate over the full range of expected service, including the very low flow rates required at the end of core life. Since the line is designated as an ASME Section III, Safety Class 3, Regulatory Guide 1.26 indicates that the flow sensor should meet Quality Group C requirements. However, because an instrument manufactured in accordance with ASME Code Section III was not available, PVNGS proposed an alternate set of quality assurance requirements to ensure that the component quality was high and commensurate with its safety significance. Since the PVNGS licensing basis in UFSAR Chapter 17 and section 1.8 (Regulatory Guide 1.26) endorse the ASME Code to comply with 10 CFR 50.55a(a)(1), the subject relief request was made under the provision of 10 CFR 50.55a(a)(3). NRC approved the alternate quality assurance provisions with the safety evaluation in NRC Letter to APS, "ASME Code Alternative Request for the Palo Verde Nuclear Generating Station," dated March 8, 1999.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 51 of 69 Regulatory Guide 1.28, Revision 4, June 2010 - Quality Assurance Program Criteria (Design and Construction)

Regulatory Guide 1.28 describes a method acceptable to the NRC staff for complying with the provisions of 10 CFR 50, Appendix B, with regard to establishing and implementing the requisite quality assurance program for the design and construction of nuclear power plants.

Regulatory Guide 1.28, Revision 4, conditionally endorses NQA-1-2008 and NQA-la-2009 Addenda as the basis for the quality assurance program.

" ASME NQA-1-2008 Edition with NQA-la-2009 Addenda - Quality Assurance Requirements for Nuclear Facility Applications Regulatory Guide 1.28, Revision 4, and NQA-1-2008 with NQA-la-2009 Addenda have been adapted for use during the operational phase as provided for in NEI 11-04A, Revision 0, and its supporting NRC Safety Evaluation Report. For the operational phase, PVNGS adopts Regulatory Guide 1.28, Revision 4, and NQA-1-2008 with NQA-la-2009 Addenda consistent with the guidance of NEI 11-04A, Revision 0. Exceptions and clarifications are as described in the pertinent sections of the PVNGS Operations Quality Assurance Program Description.

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

Technical Guides (TGs) - Regulatory Guide 1.28, Revision 4, Regulatory Position C. 1.(b) provides guidance on managing records in electronic media and refers to Regulatory Information Summary (RIS) 2000- 18, "Guidance on Managing Quality Assurance Records in Electronic Media," dated October 23, 2000. RIS 2000-18 refers to NIRMA Technical Guides (TGs) as an acceptable method for maintaining records in electronic media. NEI 11-04A, Revision 0, also endorses the use of these NIRMA Technical Guides. PVNGS adopts the 2011 versions of the NIRMA Technical Guides described in NEI 11-04A Revision 0. Conformance with the NIRMA Technical Guides, including any exceptions or clarifications, is as described in the pertinent sections of the PVNGS Operations Quality Assurance Program Description.

REGUIATORY GUIDE 1.29., Revision 3, September 1978 - Seismic Design Classification Seismic classifications of structures, systems, and components are described in UFSAR 3.2.

For operations phase activities that are comparable to activities occurring during the construction phase, the following interpretations apply to the position of Regulatory Guide 1.29:

A. Position C.l.d Systems required for cooling the spent fuel storage pool are required to be designed for the SSE. This is interpreted to apply only to the minimum systems required in an emergency condition and not necessarily to those systems normally providing such cooling.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 52 of 69 B. Position C.l.f and Footnote 1 The words "or remote manual" are considered to be inserted between the words "automatic" and "closure." This option is included to avoid an unnecessary complication (leading to decreased plant reliability) in lines which would not normally be provided with automatic closing valves.

C. Position C.l.h Refer to UFSAR section 5.4.1.

Regulatory Guide 1.33, Revision 2, February 1978 - Quality Assurance Program Requirements (Operations)

Regulatory Guide 1.33 describes a method acceptable to the NRC staff for complying with the Commission's regulations with regard to overall quality assurance program requirements for the operations phase of nuclear power plants. Regulatory Guide 1.33, Revision 2, conditionally endorses ANSI N18.7-1976 as providing acceptable methods for satisfying NRC regulations for operations phase quality assurance.

In lieu of adopting ANSI N18.7-1976, PVNGS adopts the guidance of NEI 11-04A, Revision 0, in conjunction with commitment to Regulatory Guide 1.28, Revision 4, which conditionally endorses NQA-1-2008 with NQA-la-2009 Addenda. Adopting a quality assurance program consistent with the guidance of NEI 11-04A Revision 0 has been determined by NRC Safety Evaluation Report dated May 9, 2013, to be an acceptable alternative to adopting the guidance of ANSI N18.7-1976. Specific PVNGS exceptions and clarifications to the guidance of NEI 11-04A Revision 0, Regulatory Guide 1.28 Revision 4, and NQA-1-2008 with NQA-la-2009 Addenda, are as described in the pertinent sections of the PVNGS Operations Quality Assurance Program Description.

Regulatory Guide 1.37, Revision 1, March 2007 - Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water- Cooled Nuclear Power Plants In lieu of adopting Regulatory Guide 1.37, Revision 1, PVNGS adopts Regulatory Guide 1.28, Revision 4, and the guidance of NQA-1-2008 with NQA-la-2009 Addenda, as modified by NEI 11-04A, Revision 0. Conformance to NQA-1-2008 with NQA-la- 2009 Addenda, including any exceptions or clarifications, is as described in the pertinent sections of the PVNGS Operations Quality Assurance Program Description.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 53 of 69 Regulatory Guide 1.54, Revision 0, June 1973 - Quality Assurance Requirements for Protective Coatings Applied to Water-Cooled Nuclear Power Plants.

The requirements of Regulatory Guide 1.54, Revision 0, and the referenced standard (ANSI N101.4-1972) are included in the APS quality assurance program as modified or interpreted below:

A. Section 2.5 A meeting will not necessarily be held prior to coating work or a demonstration conducted provided all parties understand the coating requirements and acceptance standards.

B. Section 5.2 Coating procedures used by suppliers may not be required to be submitted to the owner or his representative. However, they will be required to be approved by the coating applicator and coating manufacturer.

C. Section 6 Instead of using a coating inspection agency, coating inspectors may be assigned by the owner or supplier to perform this function. These inspectors will meet the qualification requirements of section 6.3.1, but may be assigned other inspection duties as long as these duties do not interfere with the coating inspection.

Service Level I, II, and III coatings are defined, as:

Service Level I coatings are used in areas inside the reactor containment where the coating failure could adversely affect the operation of post-accident fluid systems and thereby impair safe shutdown.

Service Level II coatings are used in areas where coatings failure could impair, but not prevent, normal operating performance. The functions of Service Level 2 coatings are to provide corrosion protection and decontaminability in those areas outside the reactor containment that are subject to radiation exposure and radionuclide contamination.

Service Level II coatings are not safety-related.

Service Level III coatings are used in areas outside the reactor containment where failure could adversely affect the safety function of a safety-related structure, system, or component. Service Level III also includes immersion surfaces of safety- related piping, tanks, ducts, and safety related systems and components.

Balance of Plant (BOP) coatings are used in areas outside the reactor containment and not subject to radioactive contamination. These areas are not classified as Service Level I, II, or III.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 54 of 69 The selection of protective coatings for specific locations and the extent of applicability of Regulatory Guide 1.54 shall be based on the following coatings criteria:

A. Location Coating systems selected for either shop coatings program or field coatings are based on the location of the particular area or equipment within the plant, as it may be subject to unique environmental exposures and service conditions. These areas are identified as Q, RCA, and NON-RCA areas.

1. Q Area (nuclear)

Area located inside the Containment Building (Service Level I) and immersion surface of safety related systems and components (Service Level III) that may affect the safe shut down of the plant.

2. RCA Area (decontaminable)

Area located outside the Containment Building but subject to radioactive contamination (Service Level II). These areas include portions of the Auxiliary, Fuel, Radwaste Buildings, Low Level Storage Facility, and Dry Active Waste Processing Storage Facility.

3. NON-RCA Areas (Balance of Plant Areas)

Areas located outside the Containment Building and not subject to radioactive contamination. These are all areas not classified under Q or RCA (BOP as described above).

B. Quality Assurance Requirements

1. Summary

a. Compliance with Regulatory Guide 1.54 for RCA and NON-RCA areas is not required and, therefore, will not be imposed for these areas.

b. Coating systems used in the Containment Building shall meet the testing and evaluation criteria of ANSI N101.2 or ASTM D3911, ASTM D4082, and ASTM D5139. The coating used shall be certified by the coating manufacture to withstand the spray solution proposed by the project.

c. Compliance with Regulatory Guide 1.54 for each and every item to be located within the Containment Building is considered impractical and in some cases unattainable.

Therefore, Regulatory Guide 1.54 will or will not be imposed in accordance with the following criteria:

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 55 of 69

2. Regulatory Guide 1.54 will be imposed for items located within the Containment Building as follows:

a. For shop priming of liner plate, structural steel, and fabricated shapes.

b. For shop priming of fabricated pipes, tanks, HVAC ducts, and equipment.

c. Field touch-up of any Q class coated items, except as noted in section 5 below.

d. For field finish painting of structural steel and equipment where called for in drawings and specifications.

e. For surfacing of concrete where indicated in drawings and specifications.

3. Regulatory Guide 1.54 will be implemented by requirements as follows:

a. Use of specific coatings systems which are Design Basis Accident (DBA) qualified to ANSI N101.2 or ASTM D3911, ASTM D4082, and ASTM D5139 in the Containment Building.

b. Surface preparation standards

c. Surface profile requirements

d. Application of the coating systems in accordance with the paint manufacturer's printed instructions

e. Inspections and nondestructive examinations

f. Identification of all nonconformances

g. Certifications of compliance and/or documentation procedures to satisfy project requirements

h. Coated surfaces not meeting the requirements of Regulatory Guide 1.54 will be considered "Unqualified Coating" applications, see Section 5 for Tracking.

3.1 Items (b) through (g) above shall also be applicable for Q area coatings applications outside of the Containment Building.

4. Regulatory Guide 1.54 will not be imposed when:

a. The item is to be insulated

b. The surface is contained within a cabinet or enclosure (the interior of the cab of a polar crane; the interior surfaces of ducts)

c. The surface is stainless or galvanized

d. The coating is used for the color coding markings on piping.

5. Coating surfaces applied in the Containment Building that do not meet the requirements of Regulatory Guide 1.54, as stated in item 3.a above, are nonconforming and shall be documented as indicated below. These coatings are considered to be "Unqualified Coatings."

a. The field repair to any "Q" Class coated item with an unqualified coating system shall be documented and reported for tracking in the Unqualified Coating Log.

Containment building interior coating system assessments shall be performed in accordance with the Containment Coatings Condition Assessment procedure every operating cycle.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 56 of 69 Regulatory Guide 1.94, Revision 1, April 1976 - Installation, Inspection, and Testing of Structural Concrete and Structural Steel during the Construction Phase of Nuclear Power Plants For operations phase activities that are comparable to activities during the construction phase, the position of Regulatory Guide 1.94, Revision 1, is accepted.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 57 of 69 5.0 ADDITIONAL QUALITY ASSURANCE AND ADMINISTRATIVE CONTROLS FOR THE PLANT OPERATIONAL PHASE PVNGS includes the requirements of Part V that follow when establishing the necessary measures and governing procedures for the operational phase of the plant.

5.1 DEFINITIONS PVNGS uses the definitions of terms as provided in Section 4 of the Introduction of NQA 2008 with NQA-la-2009 Addenda in interpreting the requirements of NQA-1 and the other standards to which the QAPD commits. In addition, definitions are provided for the following terms not covered in NQA-1:

administrative controls: rules, orders, instructions, procedures, policies, practices, and designations of authority and responsibility experiments: performance of plant operations carried out under controlled conditions in order to establish characteristics or values not previously known independent review: review completed by personnel not having direct responsibility for the work function under review regardless of whether they operate as a part of an organizational unit or as individual staff members (see review) nuclear power plant: any plant using a nuclear reactor to produce electric power, process steam, or provide space heating on-site operating organization: on-site personnel concerned with the operation, maintenance and certain technical services operating activities: work functions associated with normal operation and maintenance of the plant, and technical services routinely assigned to the on-site operating organization operational phase: that period of time during which the principal activity is associated with normal operation of the plant. This phase of plant life is considered to begin formally with commencement of initial fuel loading, and ends with plant decommissioning review: a deliberately critical examination, including observation of plant operation, evaluation of assessment results, procedures, certain contemplated actions, and after-the-fact investigations of abnormal conditions supervision: direction of personnel activities or monitoring of plant functions by an individual responsible and accountable for the activities they direct or monitor surveillance testing: periodic testing to verify that safety related structures, systems, and components continue to function or are in a state of readiness to perform their functions system: an integral part of nuclear power plant comprising components which may be operated or used as a separate entity to perform a specific function

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 58 of 69 5.2 REVIEW OF ACTIVITIES AFFECTING SAFE PLANT OPERATION 5.2.1 Onsite Operating Organization Review The PVNGS onsite organization employs reviews, both periodic and as situations demand, to evaluate plant operations and plan future activities. The important elements of the reviews are documented and subjects of potential concern for the independent review described below are brought to the attention of -thesite general plant manager. The reviews are part of the normal duties of plant supervisory personnel in order to provide timely and continuing monitoring of operating activities in order to assist the site general plant manager in keeping abreast of general plant conditions and to verify that day-to-day operations are conducted safely in accordance with the established administrative controls.

The site general plant manager ensures the timely referral of the applicable matters discussed in the reviews to appropriate management and independent reviewers.

5.2.2 Independent Review Activities shall be independently reviewed on a periodic basis. The independent review function performs the following:

Reviews proposed changes to the facility as described in the updated final safety analysis report (UFSAR). The Independent Review Body (IRB) also verifies that changes do not adversely affect safety and if a technical specification change or NRC review is required.

Reviews proposed tests and experiments not described in the UFSAR prior to implementation. Verifies the determination of whether changes to proposed tests and experiments not described in the UFSAR require a technical specification change or license amendment.

Reviews proposed technical specification changes and license amendments relating to nuclear safety prior to NRC submittal and implementation, except in those cases where the change is identical to a previously approved change.

Reviews violations, deviations, and events that are required to be reported to the NRC.

This review includes the results of investigations and recommendations resulting from such investigations to prevent or reduce the probability of recurrence of the event.

Reviews any matter related to nuclear safety that is requested by the vice president, site operations or any IRB member.

Reviews corrective actions for significant conditions adverse to quality.

" Reviews internal audit reports.

Reviews the adequacy of the internal audit program every 24 months.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 59 of 69 A group may function as an independent review body (IRB). In discharging its review responsibilities, the IRB keeps safety considerations paramount when opposed to cost or schedule considerations. One or more organizational units may collectively perform this function.

IRB reviews are supplemented as follows:

" A qualified person, independent of the preparer, reviews proposed changes in the procedures as described in the UFSAR prior to implementation of the change to determine if a technical specification change or NRC approval is required.

Audits of selected changes in the procedures described in the UFSAR are performed to verify that procedure reviews and revision controls are effectively implemented.

Competent individual(s) or group(s) other than those who performed the original design but who may be from the same organization verify that changes to the facility do not result in a loss of adequate design or safety margins.

. The results of IRB reviews of matters involving the safe operation of the facility are periodically independently reviewed. This review supports management in identifying and resolving issues potentially affecting safe plant operation. This review supplements the existing corrective action programs and audits.

- The review is performed by a team consisting of personnel with experience and competence in the activities being reviewed, but independent from cost and schedule considerations and from the organizations responsible for those activities. The IRB supervisor or chairman has a minimum six (6) years combined managerial and technical support experience. The members of the IRB should have a minimum of five years of experience in their own area of responsibility as applicable to the activities being reviewed (i.e., a minimum of five years of experience in one of the areas listed below:

o Nuclear power plant operations o Nuclear engineering o Chemistry and radiochemistry o Metallurgy o Nondestructive testing o Instrumentation and control o Radiological safety o Mechanical engineering o Electrical engineering o Administrative control and quality assurance practices o Training o Emergency plans and related procedures and equipment).

- The review is supplemented by outside consultants or organizations as necessary to ensure the team has the requisite expertise and competence.

- Results of the review are documented and reported to responsible management.

- Management periodically consider issues they determine warrant special attention, such as deficient plant programs, declining performance trends, employee concerns, or other issues related to safe plant operations and determine what issues warrant the review.

- Management determines the scheduling and scope of review and the composition of the team performing the review.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 60 of 69 5.3 OPERATIONAL PHASE PROCEDURES The following is a description of the various types of procedures used by PVNGS to govern the design, operation, and maintenance of its nuclear generating plants. PVNGS follows the guidance of Appendix A to Regulatory Guide 1.33 in identifying the types of activities that should have procedures or instructions to control the activity. Each procedure shall be sufficiently detailed for a qualified individual to perform the required function without direct supervision, but need not provide a complete description of the system or plant process.

5.3.1 Format and Content Procedure format and content may vary from one location to another, however, procedures include the following elements as appropriate to the purpose or task to be described.

Title/Status Each procedure is given a title descriptive of the work or subject it addresses, and includes a revision number and/or date and an approval status.

Purpose/Statement of Applicability/Scope The purpose for which the procedure is intended is clearly stated (if not clear from the title).

The systems, structures, components, processes or conditions to which the procedure applies are also clearly described.

References Applicable references, including reference to appropriate Technical Specifications, are required. References are included within the body of the procedure when the sequence of steps requires other tasks to be performed (according to the reference) prior to or concurrent with a particular step.

Prerequisites/Initial Conditions Prerequisites/initial conditions identify independent actions or procedures that must be accomplished and plant conditions which must exist prior to performing the procedure; including prerequisites applicable to only a specific portion of a procedure.

Precautions Precautions alert the user to those important measures to be used to protect equipment and personnel, including the public, or to avoid an abnormal or emergency situation during performance of the procedure. Cautionary notes applicable to specific steps are included in the main body of the procedure and are identified as such.

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

Main body The main body of the procedure contains the step-by-step instructions in the degree of detail necessary for performing the required function or task.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 61 of 69 Acceptance criteria The acceptance criteria provide the quantitative or qualitative criteria against which the success or failure (as of a test-type activity) of the step or action would be judged.

Checklists Complex procedures utilize checklists which may be included as part of the procedure or appended to it.

5.3.2 Procedure Types Procedure types may vary from one location to the other based on scope of activities; however, procedures are developed in each of the following categories.

Administrative Control Procedures These include administrative procedures, directives, policies, standards, and similar documents that control the programmatic aspects of facility activities. These administrative documents ensure that the requirements of regulatory and license commitments are implemented. Several levels of administrative controls are applied ranging from those affecting the entire Company to those prepared at the implementing group level. These documents establish responsibilities, interfaces, and standard methods (rules of practice) for implementing programs. In addition to the administrative controls described throughout this QAPD, instructions governing the following activities are provided:

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

Special Orders Management instructions, which have short-term applicability and require dissemination, are issued to encompass special operations, housekeeping, data taking, publications and their distribution, plotting process parameters, personnel actions, or other similar matters.

Provisions are made for periodic review, updating, and cancellation of these documents, where appropriate.

Plant Security and Visitor Control Procedures or instructions developed to supplement features and physical barriers designed to control access to the plant and, as appropriate, to vital areas within the plant.

Information concerning specific design features and administrative provisions of the plant security program is confidential and thus accorded limited distribution. The security and visitor control procedures consider, for example, physical provisions, such as: fences and

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 62 of 69 lighting; lock controls for doors, gates and compartments containing sensitive equipment; and provisions for traffic and access control. Administrative provisions, such as: visitor sign-in and sign-out procedures; escorts and badges for visitors; emphasis on inspection, observation and challenging of strangers by operating crews; and a program of pre-employment screening for potential employees are also considered.

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

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

Configuration Management Procedures These documents provide instructions for the responsibility and authority for functions that affect the configuration of the facility including activities such as operations, design, maintenance, construction, licensing, and procurement.

Installation Procedures These documents provide instructions for the installation of components generally related to new construction and certain modification activities. They include appropriate reference to industry standards, installation specifications, design drawings, and supplier and technical manuals for the performance of activities. These documents include provisions, such as hold or witness points, for conducting and recording results of required inspections or tests. These documents may include applicable inspection and test instructions subject to the requirements for test and inspection procedures below.

System Procedures These documents contain instructions for energizing, filling, venting, draining, starting up, shutting down, changing modes of operation, and other instructions appropriate for operations of systems related to the safety of the plant. Actions to correct off-ndrmal conditions are invoked following an operator observation or an annunciator alarm indicating

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 63 of 69 a condition which, if not corrected, could degenerate into a condition requiring action under an emergency procedure. Separate procedures may be developed for correcting off-normal conditions for those events where system complexity may lead to operator uncertainty.

Appropriate procedureswill also be developed for the fire protection program.

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

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

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

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

Process Monitoring Procedures These documents contain instructions for monitoring performance of plant systems to assure that core thermal margins and coolant quality are maintained in acceptable status at all times, that integrity of fission product barriers is maintained, and that engineered safety features and emergency equipment are in a state of readiness to keep the plant in a safe condition if needed. Maximum and minimum limits for process parameters are appropriately identified. Operating procedures address the appropriate nature and frequency of this monitoring.

Fuel Handling Procedures These documents contain instructions for core alterations, accountability of fuel and partial or complete refueling operations that include, for example, continuous monitoring of neutron flux throughout core loading, periodic data recording, audible annunciation of abnormal flux increases, and evaluation of core neutron multiplication to verify safety of loading increments. Procedures are also provided for receipt and inspection of new fuel, and for fuel

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 64 of 69 movements in the spent fuel storage areas. Fuel handling procedures include prerequisites to verify the status of systems required for fuel handling and movement; inspection of replacement fuel and control rods; designation of proper tools, proper conditions for spent fuel movement, proper conditions for fuel cask loading and movement; and status of interlocks, reactor trip circuits and mode switches. These procedures provide requirements for refueling, including proper sequence, orientation and seating of fuel and components, rules for minimum operable instrumentation, actions for response to fuel damage, verification of shutdown margin, communications between the control room and the fuel handling station, independent verification of fuel and component locations, criteria for stopping fuel movements, and documentation of final fuel and component serial numbers (or other unique identifiers) and locations.

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

Radiological Protection Procedures These documents contain instructions for implementation of the radiological protection program requirements necessary to meet regulatory commitments, including acquisition of data and use of equipment to perform necessary radiation surveys, measurements and evaluations for the assessment and control of radiation hazards. These documents provide requirements for monitoring both external and internal exposures of employees,'utilizing accepted techniques; routine radiation surveys of work areas; effluent and environmental monitoring in the vicinity of the plant; radiation monitoring of maintenance and special work activities, and for maintaining records demonstrating the adequacy of measures taken to control radiation exposures to employees and others. These documents also provide for the control, treatment and management of radioactive wastes, and control of radioactive calibration sources.

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

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 65 of 69 Chemical and Radiochemical Control Procedures These documents contain instructions for chemical and radiochemical control activities and include: the nature and frequency of sampling and analyses; instructions for maintaining coolant quality within prescribed limits; and limitations on concentrations of agents that could cause corrosive attack, foul heat transfer surfaces, or become sources of radiation hazards due to activation.

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

Emergency Plan Implementing Procedures These documents contain instructions for activating the Emergency Response Organization and facilities, protective action levels, organizing emergency response actions, establishing necessary communications with local, state and federal agencies, and for periodically testing the procedures, communications and alarm systems to assure they function properly.

Format and content of such procedures are such that requirements of each facility's NRC-approved Emergency Plan are met.

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

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

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 66 of 69 5.4 CONTROL OF SYSTEMS AND EQUIPMENT IN THE OPERATIONAL PHASE Permission to release systems and equipment for maintenance or modification is controlled by designated operating personnel and documented. Measures, such as installation of tags or locks and releasing stored energy, are used to ensure personnel and equipment safety. When entry into a closed system is required, PVNGS has established control measures to prevent entry of extraneous material and to assure that foreign material is removed before the system is reclosed.

Administrative procedures require the designated operating personnel to verify that the system or equipment can be released and determine the length of time it may be out of service. In making this determination, attention is given to the potentially degraded degree of protection where one subsystem of a redundant safety system is not available for service.

Conditions to be considered in preparing equipment for maintenance include, for example:

shutdown margin; method of emergency core cooling; establishment of a path for decay heat removal; temperature and pressure of the system; valves between work and hazardous material; venting, draining and flushing; entry into closed vessels; hazardous atmospheres; handling hazardous materials; and electrical hazards.

When systems or equipment are ready to be returned to service, designated operating personnel control placing the items in service and document its functional acceptability.

Attention is given to restoration of normal conditions, such as removal of jumpers or signals used in maintenance or testing, or actions such as returning valves, breakers or switches to proper start-up or operating positions from "test"or "manual" positions. Where necessary, the equipment placed into service receives additional surveillance during the run-in period.

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

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 67 of 69 5.5 PLANT MAINTENANCE PVNGS establishes controls for the maintenance or modification of items and equipment subject to this QAPD to ensure quality at least equivalent to that specified in original design bases and requirements, such that safety-related structures, systems and components are maintained in a manner that assures their ability to perform their intended safety function(s). Maintenance activities (both corrective and preventive) are scheduled and planned so as not to unnecessarily compromise the safety of the plant. In establishing controls for plant maintenance, PVNGS commits to compliance with NQA-1-2008, Subpart 2.18, with the following clarifications:

Where Subpart 2.18 refers to the requirements of ANS-3.2, it shall be interpreted to mean the applicable standards and requirements established within the PVNGS QAPD.

Section 203 requires cleanliness during maintenance to be in accordance with Subpart 2.1. The commitment to Subpart 2.1 is described QAPD Section 2.13.2.

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 68 of 69 Figure 1 - PVNGS Organization

PVNGS Operations Quality Assurance Program Description (QAPD) REVISION 0 PAGE 69 of 69 Figure 2 - PVNGS Operations Organization I

Chief NuclearOfficer Senior Vice President sit operations Ste General Not Manager Operations Director Nuclea forolectel

ATTACHMENT 3 Mark-Ups of Existing QA-Related UFSAR Pages (Excerpt from LDCR 12-F014)

(379 Pages Follow)

PVNGS UPDATED FSAR F-0-1 -4]

APPENDIX 15A RESPONSES TO NRC REQUESTS FOR INFORMATION APPENDIX 15B DOSE MODELS USED TO EVALUATE THE ENVIRONMENTAL CONSEQUESNCES OF ACCIDENTS APPENDIX 15C DELETED APPENDIX 15D ANALYSIS METHODS FOR LOSS OF PRIMARY COOLANT FLOW APPENDIX 15E LIMITING INFREQUENT EVENT APPENDIX 17.2A DELETED AP PENDIX 17.2 COMPLIANCE MATRIX A PPENDIX 7.20 I l - -+ZISýpl inht4I-iui'iswd iimpINL APPENDIX 17.2D COMPARISON OF--QA-PLAN REQUIREMENTS WITH THOSE OF AP.

DFRE0 B AN STDS APPENDIX 17.2E DELETED APPENDIX 17.2F OUALITY AUGMENTDPORM A-PPENDIX 17.2C CONTR-p.OL OF COMPUTER SOFTW7ARED AN U DATA APPENDIX 18A RESPONSES TO NRC REQUESTS FOR INFORMATION APPENDIX 18B SYSTEM 80 GENERIC INADEQUATE CORE COOLING INSTRUMENTATION APPENDIX 18B-A EVALUATION OF INSTRUMENTATION FOR DETECTION OF INADEQUATE CORE COOLING June 2007 1v Revision 14

PVNGS UPDATED FSAR F0141 CONFORMANCE TO NRC REGULATORY GUIDES REGULATORY GUIDE 1.6: Independence Between Redundant Standby (Onsite) Power Sources and Between Their Distribution Systems (Revision 0, March 10, 1971)

RESPONSE

The position of Regulatory Guide 1.6 is accepted (refer to section 8.3). Additional references: 7.1.2.13 and 8.1.4.3.

REGULATORY GUIDE 1.7: Control of Combustible Gas Concentrations in Containment Following a Loss-of-Coolant Accident (Revision 0, March 10, 1971)

RESPONSE

The position of Regulatory Guide 1.7 is accepted (refer to subsection 6.2.5). Additional references: 3.11, 6.2.5, 9.3.2.2.2, 12.2.3, and 18.II.B.3.

REGULATORY GUIDE 1.8: Personnel Selection and Training (Revision 1-R, May 1977).

RESPONSE

sppteher f 19Q7' Thg sa'~me R.ýrfi11 nrxi-, GThi HdP 1,1a--

M,;'- nf 1 Q727 *^iihnii- any rhang"P except- i-h. wnrds "Fnr Pnmmpnt" theg 19C75~ and1 1q'77 h czaicn~~rn~

me_

Reqiig 1lti-crx Gii 1e IR Pa rt C: a- it- nprtanstC the Rag. at -n Prni-r! n Man;ý;qpr j--,

'qi j ia g'nt- rc) t1- rcp rp~mni-ncý n-f PVNGS identifies conformance to the regulatory positions of Regulatory Guide 1.8 (including any exceptions or clarifications) in the PVNGS Operations Quality Assurance Program Description.

June20131 . -3 Rvisin 1 June 2013 1.8-3 Revision 17

PVNGS UPDATED FSAR 112-jFO1 CONFORMANCE TO NRC REGULATORY GUIDES AT\~TAN 21-1()7R- qpcinn 4. 4-A RrC1h Bpq.gi;itcnrW;Cii~ 1-R

nr ALST /Ahq 3,1 -1c)"78 requvirp a har'hp1 cr'S' ripgrp- r)-r eqr-pI u.a I P2t- A2S h);ý rl,- npH pcj-N z;1 ~rz ii-- nrj an LIP(' apC7P c-h;=nge in accorac ialith 1-hp rurempn1-'q rf 10(- 'F'R

1) R()(i)

'-) Fg111uTv1pnrý. Jq rjf-ingc hp1r~w :nrl J'q nnW ;;n c'rep1-1n tQc Tp.rhnjr;:i q;pjjrtj~ 5, 2 1 Thp pngi1Hrmn omf Ppqjj]At-cmrý7 Qj'rlk-ip 1 8 Jq ar-r-ppt1-cm with 1h-h frn11cmxAng Pxr-ept~nns and r'1arif rmr-nns t>~-ate hba1nw A Whprg. P~ar1 CE to the qliiirp 7AN'T NIR.l-19Q71 t-hp rrit-,r ;ý frmr the se'1plec-inn and~ tra nlp omf niur'1 Pr pwrpl ~n1 pprgrcnnpl, ANST/Ahlq 2 1-1 97R j-,~ '-iijhqtj-iit-p1-~

B. Whpra P,-1t C' to t-he giiire prouides addiiomnal gulclanr' fn-r 1-hg P;;H ;ýtH cm Prcmtprt-ijon Manager? 1-hp "uj-i l;;rp rmf ANTI~T/AN~q 2ý 1- q'7P cq sih'i-i tilt PH-.

C:. Whpra cr -0 ;:

trvv1 h;:rhp1 crF' 'd rl-rcpz cq pp-rmi 1-t-pr hw 1-hp ~p]Ir~1~regli1 ~i--r uIqi~d omr I-hp p~nd(-mrcqpr I ndiiqt1rý7

_gtancdhrrV. ;: hjcgh qr'hnnlm Pd=ir;t~cn plus t1-hp fcm11cmtidin

-ifi cn~

c~1-i ~whe r-on'girip-crl 2cqljc-TI v;1 nt- 1-cm 1-hp h,--r'hp1 nmr' -, clprpp 1 4 Nwt;:-r r'~cf pcS-c~'cnLr;C~chcmcm1Ing 1]2 Rr'ipnc-p -ar_

Pnrci neprnrj ncmr 2 6 ui'ar'S cf Applpr eyPpi-rit-mnrp ;;- ;= nlirn] -4 f;:)ni 1 1 in t-hg ýrpa fcmr wrhirh giial' fi ra1-i n Iis -cmugh1, p-r e ýwparsq of n;Dp~ratj cnn.ý cr 1-prhni na1 Pwpp-rjpnc--'p/t-r;: cLngn jin nun] pec poweizr omr A 72ZvýxT nh n =-+- vný ý +- I-),= n~cu~1--cn7 -n+-~n I ncy r X71g' r :z Anx xp~C~ f Pxpp-ri pLp r pl -H1c m-ý1 pc 1it-h cnn (rlgrP) rq-ilr~~n p Crdjp to~r-hcTnpetT thp1 ncm1-i1r June 2013 1.8-4 Revision 17

PVNGS UPDATED FSAR 112-F01i CONFORMANCE TO NRC REGULATORY GUIDES hp rr*rdiH t-g mn mpatn irt ;nHdjnn;=1PXD*1 *Y jnrP rpq11r1ýH hN7 thp qt,;nd,ýir

.snnfHmnrm nc11's c- d Spin cm- ;nnnd 13,2n l 2 i t- Qn;1 n

refPrancesg 12. ' 1 1 _ 147 21 A cnH 17 2..

REGULATORY GUIDE 1.9: Selection, Design, Qualification, and Testing of Emergency Diesel Generator Units used as Class 1E Onsite Electric Power Systems at Nuclear Power Stations, (Revision 3, July 1993)

RESPONSE

The position of Regulatory Guide 1.9 is accepted with the following clarifications and exceptions:

A. Clarification: The diesel generator power supplies were originally selected in accordance with R.G. 1.9, Rev. 0.

B. Regulatory Position C. Exception is taken to regulatory endorsement of IEEE Std .387 1984. Palo Verde retains commitments to earlier editions of IEEE Std 387. The original selection and qualification testing of the diesel generator power supplies were performed in accordance with IEEE Std 387-1972. The present design and testing of the diesel generators is performed in accordance with IEEE Std 387-1977. The following table identifies the applicable portions of IEEE Std 387-1977 that are equivalent to the general sections and specific paragraphs of IEEE Std 387-1984 referenced in Regulatory Guide 1.9, Revision 3.

June 2013 1.8-5 Revision 17

PVNGS UPDATED FSAR CONFORMANCE TO NRC REGULATORY GUIDES will be in accordance with current NRC regulations and PVNGS Technical Specifications and TRM.

REGULATORY GUIDE 1.17: Protection of Nuclear Power Plants Against Industrial Sabotage (Revision 1, June 1973)

RESPONSE

The position of Regulatory Guide 1.17 is accepted with the following exception to ANSI N18.17-1973 regarding employee screening.

Section 4.3 of ANSI N18.17-1973 addresses employee screening.

Section 4.3 has become obsolete with the promulgation of IOCFR73.56, "Personnel Access Authorization Requirements for Nuclear Power Plants." APS complies with the requirements of IOCFR73.56 as described in the PVNGS Security Plan, rather than Section 4.3 of ANSI N18.17-1973. Reference 13.6.2 a4 REGULATORY GUIDE 1.18: Structural Acceptance Test for Concrete Primary Reactor Containments (Revision 1, December 28, 1972)

June 2015 1.8-12 Revision 18

PVNGS UPDATED FSAR

~I~E1 CONFORMANCE TO NRC REGULATORY GUIDES REGULATORY GUIDE 1.20: Vibration Measurements on Reactor Internals (Revision 0, December 29, 1971)

RESPONSE

Refer to 3.9.2.4, 14.2.7, and 14A.3.

REGULATORY GUIDE 1.21: Measuring, Evaluating, and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants (Revision 1, June 1974)

RESPONSE

The position of Regulatory Guide 1.21 is accepted (refer to and section 11.5). Additional references: 4.2.5, 9.3.2.1, 12.3.4f 12.5.1.3. 1 .4 4 c;- 17 ? 4 1- and 17-92 .

REGULATORY GUIDE 1.22: Periodic Testing of Protection System Actuation Functions (Revision 0, February 17, 1972)

RESPONSE

The position of Regulatory Guide 1.22 is accepted (refer to subsections 7.1.2 and 8.3.1). Also see 7.2.1.1.9, 7.2.2.3.3, 7.3.1, 7.3.2.3.3, and 7.3.5.1.17.

REGULATORY GUIDE 1.23: Onsite Meteorological Programs (Revision 0, February 17, 1972)

June 2013 1.8-16 Revision 17

PVNGS UPDATED FSAR P --01 47 CONFORMANCE TO NRC REGULATORY GUIDES

RESPONSE

The position of Regulatory Guide 1.23 is accepted (refer to section 2.3). Additional references: 17 ?2 6 41 and 18.III.A.1.1.

REGULATORY GUIDE 1.24: Assumptions Used for Evaluating the Potential Radiological Consequences of a Pressurized Water Reactor Radioactive Gas Storage Tank Failure (Revision 0, March 23, 1972)

RESPONSE

The position of Regulatory Guide 1.24 is accepted (refer to section 15.7 and 5.1.4).

REGULATORY GUIDE 1.25: Assumptions Used for Evaluating the Potential Radiological Consequences of a Fuel Handling Accident in the Fuel Handling and Storage Facility for Boiling and Pressurized Water Reactors (Revision 0, March 23, 1972)

RESPONSE

PVNGS deviates from Regulatory Guide 1.25 to allow use of 'peak assembly average fuel pin pressure is < 1200 psig' in place of

'maximum fuel rod pressurization is 1200 psig'. This approach allows a few fuel rods to exceed the 1200 psig maximum pressurization while still maintaining the conservative iodine DF value specified by Regulatory Guide 1.25. This deviation is June 2013 1.8-17 Revision 17

PVNGS UPDATED FSAR T-i-F01-4 CONFORMANCE TO NRC REGULATORY GUIDES acceptable due to the overall conservatisms associated with analyzing the fuel handling accident. This deviation can not be used for fuel that incorporates zirconium diboride pellet coatings (i.e., integrated fuel burnable absorber (IFBA)).

Refer to section 15.7, 1.9.2.4.5, and 9.1.4.6.

REGULATORY GUIDE 1.26: Quality Group Classification and Standards for Water, Steam and Radioactive-Waste-Containing Components of Nuclear Power Plants DELETE For operational phase activities, PVNGS identifies conformance to the regulatory 7

ESOSE_,*

S PO]positions Ithe

-RE Guide 1.26 RegulatoryQuality t PVNGSofOperations (including Assurance any exceptions Program or clarifications) in Description.

uality group classifications and code requirements for each qua 'ty group correspond to those indicated in Regulatory Gui 1.26 wi the following exceptions:

A. Posit s C.l and C.2 For Quality roup B and C instrument nes for safety-related instrume s, the instrume piping, tubing, and fittings downstream the i trument root valves will be the same quality gro lassification as the root valve. The instrum t valves be Quality Group D.

B. Position C.1 r the Quality Group Refueling Water Tank and sition C.2 for the Quality Gr p C Condensate hese tanks are of concrete construction with a stainless steel liner for maintenance of water quality June 2013 1.8-18 Revision 17

DELETE PVNGS UPDATED FSAR T-2-F014 CONFORMANCE TO NRC REGULATORY GUID and are not constructed to the ASME Boiler and Pres re Vessel Code, Sedtion III.

C. P itions C.l.d, C.l.e, C.2.c, and Footnote 4 The ords "or remote manual" are considered to be inserte between the words "automatic" an "closure."

This opti n is included to avoid an un cessary complicatio (leading to decreased p ant reliability) in lines which w ld not normally be rovided with automatic closin valves.

D. Position C.1.d Specific exceptions ta en o placing main steam and feedwater lines in Qual Group B are as follows: The branch line size limi atio of application of Seismic Category I require nts, in ated in Regulatory Guide 1.29, is a o applied to uality group classification Therefore, branc lines 2 inches nominal pipe size and under, excludi g containment penetrati s, are placed in Quality Gr up D.

E. Positi C.2.a The equirement that systems providing cooli g for the s ent fuel pooi be placed in Quality Group C i interpreted to apply only to the minimum systems required during an emergency condition and not necessarily to those systems normally providing such cooling.

June 2013 1.8-19 Revision 17

,,j*DELETE ] PVNGS UPDATED FSAR [1-01j CONFORMANCE TO NRC REGULATORY GUIDE Position C.2.b The seal water injection lines to the reactor coo nt p ps are constructed to ASME Section III Class req irements, although the cooling water line to the shell ide of the seal water heat exchanger are constru ed to Quality Group D requireme s as are the cooling wa er lines for the reactor co ant pump motors.

This piping *s Quality Group D becau e the cooling water is not require for safe shutdown f the reactor as the reactor coolant mps can coast own without the benefit of this cooling wat r.

In the normal borated ake flowpath, a coriolis type flow sensor was selecte o provide reliable and accurate measurement o fl w rate over the full range of expected service, in luding e very low flow rates required at the e of core li Since the line is designated as a ASME Section II Safety Class 3, Regulatory Gu e 1.26 indicates tha the flow sensor should meet Quality Group C requireme ts. However, because a instrument manufactured in a ordance with ASME C e Section III was not available, NGS proposed an a ernate set of quality assurance requir ments to en re that the component quality was high an ommensurate with its safety significance. Sinc the PVNGS licensing basis in UFSAR Chapter 17 and section 1.8 (Regulatory Guide 1.26) endorse the ASME Code to comply with 10 CFR 50.55a(a) (1), the subject relief request was made under the provision of June 2013 1.8-20 Revision 17

PVNGS UPDATED FSAR F12- T i14 CONFORMANCE TO NRC DELETE !

REGULATORY GUIDES 10 CFR 50.55a(a)(3). NRC approved the alternate qua>

urance provisions with the safety evaluatýin NRC Letter APS, "ASME Code Alternative uest for the Palo Verde Nuc Generating

ion, " dated March 8, 1999.

Equipment cla ication and co equirements are presen in section 3.2. Additional r ences: 5.1.4,

~.4.7, 6.2.4.2.2, 6.3.1.3, 9.1.4.6, 9.3.4.6, 9 .and

17. 2B.

REGULATORY GUIDE 1.27: Ultimate Heat Sink for Nuclear Power Plants (Revision 2, January 1976)

RESPONSE

The position of Regulatory Guide 1.27 is accepted (refer to subsections 9.2.5, 9.1.3, 9.2.1.1, and 3.1.40).

REGULATORY GUIDE 1.28: Quality Assurance Program Requirements (Design and Construction) (PtRljon Q, TiinE 27. 1Q79)

RESPONSE

!'r rong~t-*rt-inn phas art-jvjtjp- and pr~rpciJqj~tp and phý,sp -L qt, p t sjng, i-rt-iip t i-h pn-)i tJnn nf Rpajlql;tnrý7 (-l1jj ri 1 9R j*

rp*tH, A7\ -go Se -771 ;=nri 17 2 , Fr nperainng ph;:;R ri- i Titi

inr'1iiln g p hnm TT - hrn11gh phaa TV siari-1p t~1 lng tlhp rpcgillt-nrwi pnsii-nn fnrinrd in PRi-gll1rtnry (TllirHe 1 9R will hp

-rplP ;rn hu thp reg1lat-nrc,, pnrc-ii-inn fnlimin in RPgiI,ýlt-nry Thi-icl 1 33 ;ý mnr ~fjinH ;ncd ini-rpr1-tr-i- h-,7 A~ in OP--r1~n I R For operational phase activities, PVNGS identifies conformance to the regulatory positions of Regulatory Guide 1.28 (including any exceptions or clarifications) in the PVNGS Operations Quality Assurance Program Description.

June 2013 1.8-21 Revision 17

PVNGS UPDATED FSAR -01 CONFORMANCE TO NRC REGULATORY GUIDES Adit~nn;ni1 Rp pr -ri-- 4- 2 ý. -ý-/1 7 J. C)1 1 Q 4- ;;nc IR IT , E 2-3 PECrT~jATnPY (ý-ITDTBT I1 2. - p flmi(-EP&,jgn 1 'iq f jr-: t jnn P Plz N sP1 n l t q7 gpng3Zr:;-Qr Crnn~t-rijic'h in qrltjvjtp~q t he pn'sit icn of ail;c-ý

(,Ii1p 1 ?c) iq ýcr~ppt-pd ldt-r) t1hp fn11n~ldinc PrX-kptiLnncz A - nqit- Co7 1 cl c; t ~q Pm rpp red~ fnr r 01 ing the spent- flit- ,trr1t pnn(-l a-r -ri-cpji red t-p hrp cdni gnpr]c fnrr t-hi s;f shiit-cinrTd-n Prt-hgiij;;kp qq F. T h Jq in j t- Prp r p tPc t-n c)appl I nx 1-n)-)

r t h EM mn i M iiumS-, t- ptu r~pq jrH 6-3: n q P~ mgrn r-n r r-n 12 1 jt jn

1nH -n ot- n P, (-S S;

ri w i- r t c)c; '~~

qk - tEm--, n r)rm 2 1 1 vp r n a 1d n q

-gir-h ron] j nq-

&. Pcni t-irn C. 1 f a]nH Fcc-nn1p 1 Thp idinrciq "or rg~mrnt- m;;]2uu; 11 " i- rnn~ic:;d~pr~ t-n hi-jng-,r1-te- hg-t~iannn 1-hg w6-rci "aiito-cntj -i" ;;nri "(- n-qrreY- I Th i q~ Qp1-i on Lscunrl iucpd- ton aucid rn ijnc-=q~;

in 1i q iffjh r-h tirnuu1H not- ncrnrmil] h bw prnui Hri wit 1h CI Pnqit-ion (-- 1 h Rgpfpr 1n 'gpr1-inn 5 4-1 June 2013 1.8-22' Revision 17

PVNGS UPDATED FSAR 112-014-]

CONFORMANCE TO NRC REGULATORY GUIDES

,q6= *mi or ri] *< fijt inm of str1-tiir]g -mm, Andg*; rrnmprin-nt-.

nnr is presented in sprtJnn - 2.

A1.qn s 7 1 2 16. A 1itinnal rt-fEgrPnr'p; 3,7.2 1 2, 3-8 1. 3. 3; 8-3 .2-., 4.2-5., 5.1 4.,; 5 4., 6 2 4-2.29 6-3-1-.2 R q 1 2 ?- r P R. -? 2 1 ý.- 1 4 I) 9_ 9 54 3 , ; :nH 17 ?R REGULATORY GUIDE 1.29: Seismic Design Classification

('PRL'7 -,i n'n '_ , qtpt-rmhmr 1lq78)

For operational phase activities, PVNGS identifies conformance to the regulatory RESPONSE positions of Regulatory Guide 1.29 (including any exceptions or clarifications) in the PVNGS Operations Quality Assurance Program Description.

Tor niprat1inc phrp wi tih- tr th- 2r r-nmppgr;h1, tn-r ar't-LI w -i q n(r-nr'r'1,ni Hirnq rig-be mrinst-ruct1iori pha-cPf th-h fCnllnwin" jnt-rrpr~ftaihnn-- ;:ýnlj to the ;Dnsi-tjnn nf REpcllltory7 (u,1ijj 1 29*

a Pn-q!t-ni n 1 rj

.qwcqt--mq r* urpi r'ci fn'r rn'Jnl-n tr-h ,p,-nt- fii1- 1 -Nrir'u pnnrl *i rpqiri-ri- tnr hp r1pigjn'PH for the SEE Thi.* iq i nt erprpted tn 1-r lNy in 1 tn-r thp mi nimuim s -ms

'-rui rp ' i19 .-;n Pm~rgPnrw rmnmdtLion m 2nd Nt nTPCr, ri 1 y to those '*r m nnrrmmlT17 nrriiHi rig sirh rCrOIng-fl Pnrit-in12n ', 1 F anH Frint-nt- 1 Thp in'rd q "nrr rpm otp maniu1*v I" a rrSn i HprpH t-o hi-in rt-Pd hirh-Pn ntlhL- ircj ",1-Qnimn*m1i r" ;;nd 'I" rI nirp Thi q r)pti rimn i -, inrm'1rji~ri 1-ri awi H~

dn iinc-sa=

rmrimnpl r-atinin (I Pai ng tor Hpr-r;: q p I an- ri- Ii ;:h I j tw) in I i npý'i u41i m-h ioliiu1 r] irit- ri I1 I 'z hi- prriu ri P~H uId! 1h 11tni1-rimt (- 1 ns~ rin q ~ aI Nze June 2013 1.8-23 Revision 17

PVNGS UPDATED FSAR F - -47 CONFORMANCE TO NRC REGULATORY GUIDES c-. Pcmgi1-nn C. 1 h Pefer ton setjn 4 Addthlnna reeecs 32-2Z 7.1-2-16 '7 2.1 21,381 92 3. 382.201 4.2S 5 - 4. 1 5 4. 6 22 2, 4 1 6. 3 - 3.2 2-176 9 2EC11TILTOAfRY GUIDE1 -1 3Q.: nu1ity~1 Asguranr' ReWe t fomr 1-ha installat-n, Tnap~r'1Hc. anr1 TpqtH nq n-f TnqPriimpnftatjnn onc1 E~lectric' E'giimant (EmTsion 3 The repwremnt n f the referamra1 stanr1arH W~NcS NLK 9 A-1972) will be applied tcr the Bechtel "uahty1- pr-ngram fo~r rcamstrir'tonn Of safet-w-ra-lte itm as interprater1 Qn t-he Lam"Inf-crxi piqtimn as modified1 and interpreted bpjana L- Ratinn 2 1,-Kanmning The g11IAred w1anning i freq11pnt1 y pp]ZfLnrm~.r Cmn a gpnerjr T-' jafcLr app] c';+/-i nn to~ -anw i nstljt> ~irns jm on rnna cr Mmcmr prmjprt-,q Thi results~ in s1-andwdc- prcdue on plan fovr ingtallstcon and1 jwato and~ I sting w~hjr'h mppt the rqirMelnfq of the standa~rd Tn~~~I11p~c nr machOemnr sxstem ar no~t ncorma1 x. prepared on] sq the wir~rk rnpezrati Inns are~ 1un i ue. hruE7HTr, sta.nrH procedures o -1:n: ars rrg17Ti -ugz fcmr appj cb

-di1 I ity~ inT a;:ýr-h- r- o aa Tnpt.p 1p I rn mln a nn mnn = w ova plan June 2013 1.8-24 Revision 17

PVNGS UPDATED FSAR 1I 1 2-01I CONFORMANCE TO NRC REGULATORY GUIDES limitedr -in snpa to those acti-msn cr aF tlvt1p-q iahic'h

r Ps~entjr-i fnMai tQ ntain Or ahPN~iP roimini gJjj-u n

C~r B_ Scto 3. Prer'nnstrzrtinn Hp7rifirc1tion Thn n- cp i jr Pmants, of f-hi 'q qpt nr ;:r ;ýnnlj, t-n i-m IgThi r'h Arp -rpr'pi 'iTPC ;T-lH --tr-rpcl p-ri -r to jn_9t>-l1 jf-i nn-Thw p-ý rp r-nmhi ne wIdth rprepi vinq i n.-per-tinn ;ctiNTj t iPe jn ~r-r_ a r p x. jth AN7ýT\qT N65.2 2 rpcpijirenmntc; fn-r iteMS whicrh a-re jzsta-le 1 HmmprLi t-f-p1 ;:f-I-pr rerCei ~i ng fnllImIri Q1Tjn rTtrpi-pttinng C .LSpp]xi -- n t-f-p pnc)-qii-inn of Reqgi11t-nrxi cThiicp I f ThI) UvIrinmi tpt- ar Ip~rfn-rmp-u "as~ ;:;"rripnijr" ;ýi etrmineru 1-)-, PTc En-inpprnang1pnrtm epnt h;ý P liupnn

.t-he sgnijfiranr' of t-he change or mndfir-,tirnn P17NGS llti 1 *i 7PCS a Ccmpliter j nfnrmatj on manaqp-melt - ycqtp-m to Tnai nta-~in pl :;Lt Pglii Dpmnt cali hr;:t- nn cRt;=itiq incln~ruinq t-he dat-p nf raliihration and jd irptitw nf thp p Prsn -t-hat- p a-rfnrmaru -t-h r, 1 hratjInn, Th-)P Complif-nr I nforrnati n mamaqg-mrint sx;stem provide 2u~more rpl I ab1p

I r-pmq h methodl of dLnrumenti ng pl ý;Lt egni pmef-rc1 ih-r;t-i n qtatfiiS than thp liqp n~f t;=icj or_ 1ihplsc affivxrl to the Pglipj

Mpnt June 2013 1.8-25 Revision 17

PVNGS UPDATED FSAR 112-F014 CONFORMANCE TO NRC REGULATORY GUIDES ThE reqluirement that c\zstems h 1-)gh m:;H tn to rj fw that 1 1 parts nof a g\hT~m - rrTpn ,i r l ccnrhin~tpc with each nther is intarnratpd aS nnt rqliirin" that an enti~ ;gsstem hE rptestEd a=fter modi fi ratio n nf nnl a portionn nof ha.p hat -,M ThE testL2ng rgqijire~mEntS Of thp TlerhniJc7rn1p(rfj-i Htnn* ,arE met fcor jInnn -rh-)1 Ea11ipment, EefarncE 3,11-9-7 1_9 61 7 1 9 17? R_ _1 2 2 7 8 2 2 2 1 rf 14 2 7 17 1F 17 ?.2 rinH Tahb] JS TT F P2-3 REGULATORY GUIDE 1.31: Control of Ferrite Content in Stainless Steel Weld Metal (Revision 3, April 1978)

RESPONSE

The recommendations of Regulatory Guide 1.31 are followed for non-NSSS ESF components except as noted below:

The delta-ferrite determination method specified in Part C is not met. Austenitic stainless steel welding filler materials used in the fabrication and installation of ASME Section III, Class 1, 2, and 3 components are controlled to deposit from 8 to 25% delta-ferrite except for 309 and 309L welding filler materials which are controlled to deposit from 5 to 15% delta-ferrite and are used when welding carbon or low alloy steel to austenitic stainless steel. Welding filler material 309L is used further for the overlay deposit on the carbon or low-alloy June 2013 1.8-26 Revision 17

PVNGS UPDATED FSAR F014 CONFORMANCE TO NRC REGULATORY GUIDES REGULATORY GUIDE 1.33: Quality Assurance Program Requirements (Operation) (Beuisinn 29 For~n~n operatinal phase activities, PVG idnisconforma2 nce1 to th4eultr RESPONSE posly itions~of Rgltry c uie.3 (includingany eceptionsfor clrifcaios inth T~'Cr- Pprfnl :;-rn-r-i7 Pr -i1~m t' 4, t-)4m ~pr'f-nmm 7Pl t-mnt-- refer ' to C' 4 h- ALd F_ 4 C' s~hall hp perrfnrMec 2Vt ý f-rgilý1=nz~ Cmf at I eas once~ peiý 24 months. Tn adcjjQL. c-n a- rar'p pp~jod i-cif 9n

.Cnmnj1mtifln omf -intenrnalf TAhphn f1h. ryr.qr( n prinrd is

]tiI-i 7ý-H 'Siqi~1 r'h~cjiijjnr- fcm-r tlhe au-~ii-- shall he as iipcmn tIhe or-iclinal dilp- dc)te ThI-)ic~ grT-r~e 1-Hcmci sha I noti hen Aipplipci to thrcmc. alidc-tcs that ha-cp a freqjjpnc-'w Spnýr-'fuc-'1y ciPfnni l I a ai1t jcmn Tn 2drcift-icn t-imp fnm11cmiLrin rlarjfr'p1-ion J-- ma-p_ -in 7\2R' pcmnqit~cn -,ryg:i-rHcnrg Pergi~latrmr C'&iric 1 33-Encmplianc'e tom aNSI~ standa-rci rn-fPrg~nc'-c th:=hrcmlgml &LIST NiP7-Q'~/1~~-A -rp ;qdpse -qPnArA-f-=c -in 7APq' recpr-qeL -cm-cnforma-nre- with- thei reql1-cm-rw r rlcqIi 1 st-pd in qý-r-tif i-n 2?' nf P6cni1 ;ýt-nrvr- (-ii! rlit 1-June 2013 1.8-28 Revision 17

PVNGS UPDATED FSAR F-01L4 CONFORMANCE TO NRC REGULATORY GUIDES The fni11nding excptrJns ar takpn 1-n ANSI~ NIR.7-A 'pctjn32 'ý 4 2

'Tbp Ap.0 rnmmjthmpnt- nn thh alfi1 rat I n of pprsn-nngl Tdihn ar pt-rformi nq prppp~rati-nn~zi1 and- stharti-p test fiinrtH nns is frniinr in p~~rrb14 2-9-12, Bý Spr'ti)nn 211 TAdh6n pi1rrh;:iqnq c-nmmnpr(-jl r~q 1 ib;ljr;=tjrn qr~j-- frn-m cert; n:;j~ ~ g~1r 1b~

nn-;rcrprl-jtpH t-hn proc.11rpm-nt- Hc)(iinpntm.qh ir nrnf rp~j t-dnL !Tnprnq a ulj ARjr~nnp prmgr;:m nggn ,id1-h Z0\j.-T T\T4R: 2-19'71 7\lt-prnM;-Lzpg r1i-irnpmpnj-q rI n,(ribhr in TlWqAP qtr-t-inn 1 P for Pag11latonrw (Thide1 1 123 may he iMplpmTnprntr in 1jiji n~f

]mpn,-i ng ;: giiz1;jtx7 :q-ir-r program rannsistent- tiri-h ANJI'JT NL5 2-1 971 Tn riidtjmnn t-he fn1lnidring int-erprptaicnnq nf LNqT NIR-7 Ar A Section 5-2-2 Th,' r~pqi~ijrk-m nt-- of thb qp~rt- inn ;;r ;q-~p t c iaji -f- t-hg fn11n~jj7inL int-prprpt.11Hmnnc Tpmpnrarx; rh~qnq,-- t-n) prnrpc~iiiracs may hp made~ prniTirli-r t-he rnhanrjp is ; pprmurpr by7 t-wn mphpr rf th-h pl ;ýnt- Tn:n:q-p qt1:;ff, at- 1pq Qnn nf lwhnrn hnlri -;~ -,pgn n]: ra;;1-tnr

ýý -r r Iýr, 1 1 nn Q, rn fhbý iun 1 - -- f f,ýr- ~i-r ac1-i nng rirrp 1 ncnypnr;f:c1 int-n I g-,t-ndc:r- pn),q-t-1-i- p4rt-jInn-,

7nl 1 niizL --; mrninuu1 or ~i1nnu- 'rp;;rtC3: trip., 1-n~~c June 2013 1.8-29 Revision 17

PVNGS UPDATED FSAR TT0141 CONFORMANCE TO NRC REGULATORY GUIDES PnO~t-trjjD artji nn: iTý7l1)1 n~p-r-fni-rmpd The rpaintor (pPerato-rS are a~parf-PH fn know t-he 1-stnda-rd- pcst-t1rj acting ;:;Ld bpgq p tn take a r1-t- j n The rncmn-rr ronm smpnj~r 'qhA1 p-rfn-rm ni f-'hp cqI- ncbi ri-I pncq1-t--r p act-ion-'

f-he ni-clpreant th-f-ppnch rjn nprq mjpirh f-proria --h-pt r'nf-unL~

he siihj pr-f tQ t-he s~zimp dereerP of cont1rol as was lizr r 1-hp p-r.-p-r;1--ion of 1-hf Cn--fj-inp1 rjnr)-iimpnt1-ý is aPPlJPr con jstrm- with t-hcp -rpri-m-re~entS- fA~1 4~21 PaLrigraph 72.2 M-iL pr c hr:n4ES f-n dcrlnr-r~rit-cS qiir-h ;qc

~Pii~ti~1Pdi Pr-P 1-nri~ c nrrpr-fi pDR or r-harnrjpq to r-nmrprr-ia 11-rmS t prýM r-nLi f-t nnZ MAW nn1- -rl~rllirP t-h~t- 1h-h rpv, csprj drln-impntf repr-PlizP the csamp rpr,-iL Pwm ;;rnnprnNT;l as tfhe nriqla do1criiranp1-c Sectp-1oi) 5-2.12 The raglli ramentsc nf t-hq c- prt1i nn a-rp Arr-Pp-f-ntpr( wt1-h t-he f nl Inigi ng n1-prpretat 1-nu -

Thp rpr1 ,, rpmpp1- 1-h,1 Hp7T-I rpu tnpn -h týr r-a,1RP. ;:;nc Ar cr-nrrpr-ti-SZ ir at-1ica r-nmp:)l p1-pdcr pl arnedr shall hep dcr-l=--n1-~rd ghall arpplw 1-n sjqrifjr-;:;n1- rdPuLtr1-mnp Ot1her jIpn1-ifjipr cpiH ui;-i nns idi 1 hip cirrimrume-prl and r-orrert-1-pri Thi -

-iP-PrrP1~1-1nP-, r-nnqiqt-fp-n wiod-h Apppnr-lix B 1-n 10=1250,~f J une 2013 1.8-30 Revision 17

PVNGS UPDATED FSAR 112-F14 CONFORMANCE TO NRC REGULATORY GUIDES in a1'JqT NIR,7, P~ r;;;grph 5.2,9,19 1 jl bp CrnnrjliCr1-H- in I 1-h Requl t-mru Gliidec 1 68. 'Rp-vl ',In n.

'F qartjnn q 1 Th)p 3zp[iijrpmp~nt-R of thhi 'gprt-jnn -;r ;rrpptpc1 jdt,~h t+/-he f01 1cmnr-inq n-pnrprt-aM- iomn Ac't- c.-m Jrent-Jif~ asc- jmmpdjatp1- mpp~r_;tcr ;r-tjQT-) h;;;7TP h-)Pn

',tanc;:rc-j 7-pi inU t-he f~rmr n-f safet-w fcimrti c-n tigrh'g g.'fgfp--,7 fmmnrf-tji2 ring maH nt-~i ng'c for-c ~ ;] t-rarqi-ntg- wrhgn t-he eimergency'~ prm-pc~riiibrpi J- -imjp~rm,-nt-pr Thj -q Pnqirt-q procper rippratnrc rpc~po-nqp inc-pppndln1 o-f P77pn1- c-jagnc-iji ThIS ;qpprn-vCrh jg cr-'c-ingg1-pnt c~iatl-h (E-~2CFmeircJenrwý Prnc'rr-plmrp R,,i c-lcr1 jneq Artiorns HgnLti fiar pc- slhsrmn rnpP-r;;tcr ;;rt-i nf 2dr~~p ag ;; rp~-rnazery prc-rediirp., imp] cmentedc after Puent-C- ;i 4n r - i~ Th-) s pprnr:rh j rrngigt-ent- ~idi h rFwN-1 ý'21 CT7 Fmprqpnc\1 PrcraduHcre ,mljc-p1 mpS Th~ p~c-.if rprrirc-p1,rp fcirmt ;;nc c-rnnt-nt- 'haip hgpnl i c-pznt-i f ~ri ýn 1-hp Emrnqr-jnr-' Prorc liE p(~nerac Sc~m -Inn Parkag-e and ghm-il-1-g sl to 1h~p the- c frir rpiuipmc T~hls j,- pc-q'c-qnt-pnl-Tp qRpr-'1--Ic n ~ 2 11 Thp rapgivirpm~npnt c-f thi g gpr-c-imn ý-rp ArCp ldit1h 1-hp June 2013 1.8-31 Revision 17

PVNGS UPDATED FSAR I I f-jjuJ-CONFORMANCE TO NRC REGULATORY GUIDES The rp~pu rpmp-nt for ppri o~rz rpe-ie n~f rout Jn pl nt-prorc-edurps no les' fre~ient Ig t-hai p-uerw tt-wo yea~rs max,i pvrpce-qcl fo~r jroit-ul-ne plant- pizoredreisc uffChi rb ;rp i 3-nfrpgui~pnt-lW wh1 ~1t-rn;;t al -ýZ TInep;Tl ~rýp Prclli rpr toa Pn 'luirp rpxLjid nt.f these prorpriii-re pr-I r ton ii-P Ppri -ii r' rpur pT, of p 1 ant- prorc-6-urt-, nn frpgi1L-nt-1 t-han Pjvprý7 thTr) -mars, 1 -, not- rpglli rarj for rnut-intop fraqiip-nt-1j7-u cqpr p]lant pror.~rhe~iirp- Ppr- on r' aiiriits 't sat~sfz rpui aforý) rpcpi rpmentqc And~ r'onmi tMpnt- incor'] uH ;;n

ý-pSmn Of a rprg-nýtu -,,)Tp1p o-f rplatrci pror~ediirp- to) 1T11 rLtp t-h;=t- thp p~r~rpnu-rpcl ;: r Arm-ptazh1 for iiqp ;incd that thý) ;Drnor~irpr -revju nu; nn rpu i -, Jnn p r c)r- ta Js bping Pffartiupl w imTpl Pmot-n- r]

Thp Pxrppt 1 nnR tn ptri r~ icd-' rpuipia rpqliirpmr'nt-, '1 t -t

ý;hmp H~o no-t- appl yz t-o nCon-roiit- i n pro.H u' ;=Ia

-ýhnnrm,:; np,-r,ýt-ng rrnrc Pmnprgpnc;7 opprat-ing

l;rm rcponqp proCpcilrpq, proradurps t~idhLh impl pmpnt thp F.m-rrjenr'y P1 ;n, or pror'pci~rps w~hicrh implprn-nt thehp ~riirit-N Pl1 n) Thp_ perinorH r rp~ujt-rCirpmrnhn for thp -e prorpndu rps' m,ýlz hp i~c x hýt7' tb -

liip o~r -rPNri px, o~f the p-rordurpir Hlurna pla~nt QpE]Zt-jon,-

h r;:;i- nq i n prc'i~ dpnril1,1 or bxn other slich rtp-\r P]67 oýCtji 17 wdhir-h 1Talic-ieVpý ;;r-r-pt;:hilitwz of thp ;Drocadiurp, prov-ided thh- ;procrjHu rt c-p, or rpu~i pi -;rt iu-it1w ic g Hc',impnoti-p June 2013 1.8-32 Revision 17

PVNGS UPDATED FSAR FIII014 CONFORMANCE TO NRC REGULATORY GUIDES C"Prt1inn 5 2.7 Th)p rrpii rpmants, of this 's rti nn ;r ;ýrr'=phtr1 ht~ih thp follmnwinq intrprpta~ns-.

Art-Lulthi , nr.'riirri nq rc11ijii the oppr~t-imnna pha-g that arp rnmp;:r~h1 p in n;:tlirp ;:md extpnt tn rel;ýtpd ;rtji-ijtjpq nr'rlrri nq r-iiri nq jnt-ji ;l pl;ýnt- c16-i gcn -ýnd rn-nst-rirt- nnl

-gh;r)l he 1-gjnt-erprpt-pHr tn mp,ýn t-hnp a't-i vi ti s nf rnqr'h ;q

'Sr;; 1 ;:inr t--i7no tý-hat- thp fo I 1 oidi nq rnnd! ti nnq rir mat-i A-... Thp wonrk iR ta hp-~ Dp~rfarmpcj hxi ýn nvit-qi p rnnnhra(tnr nr nianprlqc ggarui~rp n-rqani 7ti nn not part- nf t-hp pl~nI- organi7zIinn, JB. The sxyqt-pm nr Arp-a of thp pl nt- ;ffe(-tpH hw7 thE we-nrk Ji re p,;RP t~g~Inthe ront-r,;r1-r or Rprivircp

=Cgan1 7'rhinn rlij-jn,n t--h. Ar-t, vit-w- ;qnd, f-xrPpt- fcnr r~~ining n1print-prti nn piirpn~qpq n d n th-hr

.qjprifi pc rncnt-~rnlq Pffart-irlýx r~a S q tn hp p~rt nf ;gn npinZr;tjinq nirl par pnwlre3 pl~nj-_

£.~.Thp- Cnnt-ract-r or 'sprvire nrrg~ni 7;:t-inn bag~ hpen-cM rertPHr in ;:;HT;:nrp, nf t-hp wn~rrk thh;:t- rrnnfnr~r~n;nrt t-n Rpgiilat-orx7 C-,mijjl 1 7\ANqT MIR 7, and

~pn~r~hP st;:;ndcl;rrl referenced in 7\NqT N\1R-7 w~ill 1mii l r-nnczi It-E t- dit-h tbhp P\7NI, TJ1lPq\

Thp- implpmentat-ion n~f t-hp pngitinng nf Rp-cijat-nr2 Guhide~ 1 33

,ir rlp.-rrihpcj in rh;;pt-prq 12 ;ýnrh 17 ýnri flip Tpchnir-A1 June 2013 1.8-33 Revision 17

PVNGS UPDATED FSAR 112-F01 CONFORMANCE TO NRC REGULATORY GUIDES REGULATORY GUIDE 1.36: Nonmetallic Thermal Insulation for Austenitic Stainless Steel (Revision 0, February 23, 1973)

RESPONSE

The position of Regulatory Guide 1.36 is accepted (refer to section 6.1). Also see 5.2.3.2.3. Additional

References:

6.3.1, 6.5.2, 4.2.5, 5.1.4, 5.1.5, 5.4.7, 5.2.3.4.1.2.2, and 9.3.4.

REGULATORY GUIDE 1.37: Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants (BPuHsjnn N, M;:rr-1 1 6, 1 Qc2)

For operational phase activities, PVNGS identifies conformance to the regulatory RESPONSE f--positions of Regulatory Guide 1.37 (including any exceptions or clarifications) in Ithe PVNGS Operations Quality Assurance Program Description.

Thjar-i11 r-sm~nts r~f the refg~rPnrpr stancHarc (ANSI N41ý 9 -9~

a mn-ified in thE rqg1iatnory pnoitinn arE npPl1ipd tn C1Eaning ar:Lut -jE-,i* qýp~rjfjd n0-r app14ed bir :r~rhtp* tn) s;=f~tv-rzelated "it-pmnq as mrnHji f-7i*] and in--1 rnr'=t- hP1 onal L.. qýrt-jnn 2 IF plmnnin.n The r*d-1ll r* pl7nninq JS frpqu1 nt]fl nf-p-rfnrmed on a generic has fnr ;pplrnn tjonn to manwf jnst-alat-Qnnsf on nn* nr mnre pronjrc This rE'~ij1 tc i-n qt,ýncLarcl prflrEcbrPS or plans for in~sta11at-in and] Jnspectinn and] tesinq which mpat the r~q11-i ~m¢ni- n~f t-hp qt:-mndnr Tn-idirilial plaL/s for

,.-;r-h itpm nr .sV -qtm 2r7 nnt nnrTnal1_ pr-pparpH ljn1l ,

June 2013 1.8-35 Revision 17

PVNGS UPDATED FSAR CONFORMANCE TO NRC REGULATORY GUIDES p rnrgrli-rp- n-pr nln arp rplTi Pw'j-cl fnr ýjppl jr,;hi I it -u i

~~ Tnsi-.ý;]1 ali on plansc-nr prorpz~-iirps ;:r also~

lmi-pr -in qcnpp In I-hng act-Jnns nZ ý;rtjjtt- Tarhmrh ar Pcggpnti- t1fn mai nta.in or arhieuiT rpg1,i rpr cpiv=~j Thgj rnn -,i-,pnt- wjti1h Se rion TT. Par;ý;r,;phs 2 :;nd of A~iqT N17)4 2-19'71 w~hjrh prouic1dp for inni-n m,;: o-jcTpt.

r t(~-cing J j~c - a-gir cgr liý -- 7 or i ncij rm-ct monrt-rn)] bwz moni tcrl nq of prrnmpqq -n" m,-hhorjq Hjnxap7ui' fi n;ll r pngnc or f1,ijhi ng mn-iuii-, arp pprfnrmnpdl

-ýrrnrHc;nrgp 107' I-h prnrpwHlirpq qpt-r fi r tn th-h -7gw'pi-m A1n 1).2 4 1 2 1 Adrirt-inn.ý; Peferpnrpg 4 2 4 51 S. 5 .1 ? 4 ? 4, 33 S ~4 7 6 1.1-1 3,2, 3 1 4. 6, 5 2. S., ( ) 7Z 12. Q, 4 1f 3 ,C 2, 14 ?-:Z 17-1, and 17 2 For nzp~r;=t-nns ;n-fc-u-iz j-s tha--it arp= mncmpar;:;hl j- o mia tJ-vi t i--, ci nmmiirri -nq +ijrjinq t--hp rnnqt-r~ijct-i nn ph;:;cP, th-h r~pferenm~pH ctI-ýnri cl (ANST L14 1 2 1 -1923.) a mn)9 fpr adhw Ppg~ill I-t rw7 Ci rl P 1 -ý7 ic; ;ýrropt-Ld ;; mnc)( fi '- hi-InT.

A Sprt-mI-in 2 1 .,P] ;nnj nc Thp rk-qui rpdIil= p1 qnJing frpgiipntl- Wc perfnrmnt-H nn q gpnprJ r' h;=iqi - fnr ;ýppl 1 rit- onn tnc mTnw:n su.y;t-irn and~ cmnpnnpit- 1 n.i-1tR I at-- rnn Th-ý s

-rpqii1 i-- -in g-ty;:;ndc1rri pmrrPrerjmp- for rl p;;mnc;i ng jn.-p~m-rtnn 2nd- I-pgt-ing ijh-i h mppl- thp- rpqjli rempntq of t-he Rtandrdr R- TnrM u-i Hli~l plans fnr Pamh i I-pm nc- Su~-,7-tn ;:rir nnit- -ncrm~na1w pri-pared iinlass, t-f-hp idrnrk npprat-H nnsg ;qrpu-i gii* nwp-n-p-r.

qta~n-H;rr p-rnm r-1iirpcz Ar reiiTpihrc- fnr ap;Dl 1 ra 1lit-N7 -in p~h C=q Cl],-ninc nrj rnmr-p iira-c ar 1 -i r-i -ri I n -,rnre f-n)

June 2013 1.8-36 Revision 17

PVNGS UPDATED FSAR 12F1 CONFORMANCE TO NRC REGULATORY GUIDES t-hose ;rl--i rnl or actlvl fl es whicrh g~~ni1tc m'.l 12t ain Qrm a chi a~~za rp "I I i rgpri r~vl: I Jtx;' This '~is r-cnn~j tE~nt

]A~i-h n1in' 17 Pa~ ;ragrph 5F of ANSIT NTR 7Z-19Q7r wicjl h prou-i cpgq fn-br ymint rnmp~qqnirmp~n,-- rmr t~t ton asg9i1rE cri-i,1itý7 Qr jnrjj rezr' rnntrnl -h-7 mnnnitmri nq of BFGOLT1TO2E GITTTOF. I -ýP fulitiz I I- siranr' PgiiqurampnI- far-PRaka"Ling Shipp~ing. R~pacia~in",

Stn~g,-;:nH ýTandljng Of TtE~mq fnr WtATIr-(rr3]~lp Nii(]gp~r Pntxipr Planta (R2p-ujiqnn n.- MA-rCh 16. q-7'ý)

Thbe rp-"))irp~mpnt-s of I-hp rgpfprpnr'p standard (ANSI~ L1[5 22-lq7?.)

A- mn~ifi;=H AnH intprprnlrnr -in t-he rernulaI-nm- pncsl-inn 'ýrp a"ppIj~ ton Ih-h Rprht-E1 cpia]Jt-w programn fnr r-nnqt=I-ric'-jn nft

'qafet~z-rp1 at-pc I t~ms., excepI- - mnrM fid a ndl 1,3ner-preI-P hplow.i Dp~rform-i og off.SitIp rnaiidit-' shall 1e hp ial1i f-pi t-o ANS1T N45.2,23 RpLc~nnp1l pprfnrmina cffqiI-p niaIrial inspp~r'tin cqh~1 hp [ýi1lfipr1 I-n ALNTSN1 P2prsonnp] pprfnrmingT offc~-iIp monitorzing aoI-tivi~ti-sip s~hall he ni,.z~ifieH I-n ZINTST M451 2 23 or- iA1'T Nd4),2 L_

.~~pI-on2 iaS fircI-ion o~f Itpmqý The foiur-1 p--p]

clasq-j f-iraI- nm swyI-pm may i nt he ilsýpH Pxpl Ir-tlw-T-To~ 3. 7p-Tp~r. t-hp q pa-ifi r rpcp1ijrt-mpnI.- for ipa oh c-'1sific'aI-ionD ;:; '=p3~rzlf-iEd -n I-hE 'I-ancarr a-r- apzplýEd June 2013 1.8-37 Revision 17

PVNGS UPDATED FSAR -F0-1I4 CONFORMANCE TO NRC REGULATORY GUIDES toc t-bp Jte-ms qlrrpq-r jn P;:;Ch crlaS~fjr r;tcmn ;;nr for c_ Sr'1-ion ? -qf M;ýrking. Tentjficatinn of items. Aiftirn the c-,i-'its -f n1 thp rconta! nr ha hpe rammrv . is Acconmplighed in rr;-cn-Hdaiip wi~th ANSIT N'JR. 7 S~rtJ~rn 5.2,J3 3?

Sp~r'fnn Cý,9, qtir;:;qp Arp,ý Paragmaph 6.2.1 rpgiiires rr~nnrnl and1 1jje 1 ml h es to~ st-;m ;:re Tn 1j a o~f and- ton amplify thisc paragraph, the. follow-ing Ls, "Ar-g~Ce~ tn Si-nr,;gp ara for 1 geup1c A 7ý, l ; nrj r' I cnt-rn11lc-] h1w t-he. LTIAdiial (s) rsponsihIbp for matejrIal s-rce" TIvp.1 lD itms ar stored in a it

~h-ich wr~ has access, rant-rol r-ozgl tnt w.iith 7flfl T17 nf ANST 1\4 -Q? WhJI1 tbp ;;p.) Thýy hp pnst-ri tn

]im~t ;:r'r'pqq nthprn pCr'n1:T! ntrn-1,c (n~thpr t-hln that-for' the oaprall it I-. arpa "ur~ maiz nnct- he prnoui de F rtionng ? qn r; rý, ;:Ind~ srticn 83ý of Appp~nrHx A, Marking T'hp'q ANq~T hNAý2- ge9rt1innq~ r'nntnl rHIrpr1-marki ng Of allstani ti r sta~m-q Stee ac~~-p nd~ ni rV haserd a 17Sv' MjarkinnC is nj r-nmnplj*i nc ijdith the raquLraments, of thesep ger-tionns except that- marki-nq max;, he drelrc~t1 x a pp 1 1pH usi Inq n ks r- nn -rnlp 1q go n~~ Lo t ton rnntI-ýjn mn rp than 2Qlf ppm of jnnrqanir' hajc1ng-n

]3tfgerpnr=p 4,29 )., 1 4, 5 2-3.4,1.29 2., 6 ? 1 3.

9 4~17l91'7 iRF 17 9Rý, Anri '~hl- IR TT F.-.

June 2013 1.8-38 Revision 17

PVNGS UPDATED FSAR CONFORMANCE TO NRC REGULATORY GUIDES RFSTITIATflPY CGT7TfE-l' 1 -iB (Tilj lR i17 AssuranceRg z~~1~ fnr P;;-kr-fjgng- qhippinq, ERec~-aizng str~acp aLn1 THanr11inr of Items~ fra ThTýtar-(,cpln p Nir-l pir PC~iqp]: P1 Ant-.

(uipx~jnrn 92 MAx,z 1 977) aiui ~p or-cirjlrrincfH dlrjiD the~ rconsriir1-ticnn as h pCD~j-ir-in rnf TP~milzitnrur CGivicd I -ý2 1s acaped ith t-he fcul 1 wnq e~xc~r~p-;-tcio to fhhg raferenr'H standa~rd (ANfPT N14rS 2 2-1972).

Sec~~t ~cn 2 4- 2ergarnine1 CQui;;i1fi rat- run Pp~rSunnD~

ppr-FcrMjLng n-Fffs1it amdi ts shall e cpiaul i fid irto ANST N45.2 23 Pg=rqnnnp1 jp~zfrrmjing ruffcuite =tp-zra ingpprti-irn shall hp rpu;:ijfipc tou ANJT N'45.2-6.

lPar'snnnpl perfnurmi ng cuffculi- mcni tcruinq ar-tI itie sha 1-u h ii ifnr fuv tor A.NSIT N[45 923 o~r ALTSIT N45 2 6 PRn~runnn1 pp-rfp-rmjng prn1liminarw-ýz :szjsiiru1-u'spr~ztiruns (p-nri rut-ru lun] rri ng) pe3Z Sec'tH rn 1) 2 I of ANTiP N41A) 2 2-1 972 nppcI nrut hPn guulafInc-l t-ru A\NqT N41) 2 6-Ttp~m in~rup'tjrnn rper Sectiorn 5, 22 ouf ANST LT1'J4,2-2-1 972

~rzPnrfrurnunHd h-,7 parsrunnnl guml-i f-id to Z-rINSIPN45 2 C, The -ite-m n~spacti- ns 1 'lqru Pnnqrp t-1-u:t nou rljim;ýrg h~

rrnccirradr rluurim ng hippl na B- Spr'tjrn 2-7, Cl1agsifir'~-airun ruf Ttpms. ThI-u fruur-lnwnl r cjaq-i -ic-ati-Ij S\7Sn Pu~-nMrMu anIrui- b2u 11nr 4wp I r--i-1r El ) Ia TepUr I-i-u rupnr'i fi r. uregui -rpnp-nt-. for Pach, June 2013. 1.8-39 Revision 17

PVNGS UPDATED FSAR12F4 CONFORMANCE TO NRC REGULATORY GUIDES

(-1 -,-,j jCat-Q- A -,,--fis-d Ln the -ct;:-~nri.rH are ;;pph1Pcrl tcr t-he i t-pm'q -,iiggpt1-pc3 in -;;rh ri la.cq fi r;1it rn ;;nrl fnr qjmi 1 ýr itpmc.

f_ qp-tjnn 2,7, ~ f n~- T1-pmq. T\P16 (uni r~l-i~1pcl~fuijr P1 pments, fi c~~irn crh;r;mhpr Hptprtnrrq. c cicnrpu oi~ufin ~~i nui] ~m;=itpri al -ýr,-i casfiar as pE-p la31 R fnr t-hp_

piirpnqpq f 1hig qt;cir n- Sc'1-irn 3.9. M.:rkinq- Tcipntfjr-,:Hcn af -- pmq. afte~r 1-hp cmiit c jd ig n- f 1-hp Crnn1-qjnpr "h, c hppn rpmnupHr.cl -ig acconmplishedi in ;:rr-nrcianrp w~it1h AN'J'T hllB_7 Sert-inn 5.2,12 2-qp.rr'-t-inn e-2, St-crage Areas Paracgrajh e-2 1 rL-qii rp'q rc-n-r-n] ýndi limi1-pc ýcpq t-n Rt1nr;:;p 4ra Tn I i pu of ;:nH ton amplifw 1-hic p,ýrqr~ph t-hg frn11ntling J-

"Arrpgq 1tQ q1-tnragp arp~q frtr 1eal A.,1 B., Annrl Cj rn(,n1-rrmllpe- hx7 1-hp inrl-iTv-icial ~ r,-.pcncuihlp fn-r mate-ri al q-tnracgp I,,ptrpl n2 itpmq t:rgp 1-,t)rpd 1: c-,itp-

rpa ij7hi rh h;

;-, p~ rntn1rol r-nncui cu-e]2 ibri1-h 7nlfp TVU rmf 7\NqT N41 -17 Whilp 1-hp u: rp~ mAx7 hi- ;Dn.-1-pri t-n fri 1h -utp r 1 - gi-pr Sr ju~rl t-wjn1up (-c Dt 3 )ISmppr t ;;

p r th c-ri mupi 1 q ,;) Q cn ri ný7n~-h p 'prt-innq'ýýq 2 g4 nH ApppnrliY A Spr1-nn 3.q9 Mwr-kinq Thq ATNCT N141 2-2 spr'1ing' rontn1rcl rijrpr1-marki ng ruf ;:mjqtpnitj q-rc1.ti jni p'~ gepp1 ;:nc n-irkpl 'h;:;Pc all 1ns-q M~ki ng; is in r'rTrnpl i :nrp laith th-h r~tpiijr-t-pmgnt-,

nf thq qgprtinns except- t-hat mark-ingq m~x, hp dir-Hrt~'-1 June 2013 1.8-40 Revision 17

PVNGS UPDATED FSAR FT-F-01L4 CONFORMANCE TO NRC REGULATORY GUIDES

ppljp rl iqi nq i nkq ront--rrllp 1 qn ;

- nnt- t-C) rront-;=ijn-rn-r, l-h;n 9nnf ;)pm of jnnorqanjr h;:;]ync~nq Epfprpnrp 4. 2-5.,5 1 4L, 5.2 *ý 4 1 2 2, e ' 1 l

q 1 Li F, 1-7 1A.?2 1-7 llý, 1ý7-2B1 -zmri T~qhlp IR-TT. 2-3 PPCZ-TIT.A\TflY (,T1TDnF. 1 ~Q I-In1pVpp-nq PRgiiiremenI- for W~i-pr-Enc-led Nuiclear Pnkzpr P1, -inhcR (2pvlc~jon 2, Sept-amber 1)77.)

Thp ]:aqi~ijrnmni- of t-he r Pfprpnccl _RtancrlrH (AN1ST N14iý 2 3-1973) are~ applie to1 ihe t- Bpr'hi-p1 c11alit pro~qrm fo-r rmnsi-riirtH o~n (-f A pri-tInn 2 1., P1-=nnin The requ-Hracd pl anni nrj -is, fr6ýqijtni-1 w pprfrormt-r nn ;: qpnprl r 'for ;;ppl I c'=it-jnn I-n mrnw;ý jnqti-;l1At~-jon.- on n~ o)m-r-Tmort prcojr'i-. ThI a ri-g~ij1t i-~n 'si-ancIrci pron(-p1iirpr-, or plams fcr nci~s-a 1 1 i-onn I;r jnqppct-i n ALnH tp~gt-incg ldhi h mnept- the r~p11ijr6-Mni-q of tl-ho qi-~ndrd~ Tnrjjui cj~iiil pl;:;n'- fnor Parh -it,-Tn or g-,;qti-~m

ýirp nnt- nrmrm11 y p-rpp;: rpdc inles;. i-hp wnirk npp~ri-iongq ;;

in icpip- I-miaz,--rf gtanrlarri pror-tciiiurpq~ nr pl ct ;f

-rgea Pidedc- for app] i Ch-;i 11 i t7 n -ar rqp Tn SaI 1I ;: Ji-=

p] ;: ns r prcd i gzArp A I so I1 mj ti-,-( i n -,c'npp i- thr-hn

=rti, nn nr ;=i(-tLui i-i p- Twh1 rh ar P'qgpni-i: ;li-n mýijnt->ýin nr

(h i t- t rp "i ii rfc1 ¶uu1i;ý -N7 PR Alti-rnat-ju Pcxu-LT1 1tnt- 7nflp ci gsinat-Jonn anc- r,-c11i r,-m(n-rt m;

iý hp Hi-ill 7pri i-n) -r'n~pr t-hn-,p qji--,;:;t-jnnq nnit- I nr1 1r,crj in i-hp qlluh-j.pcti.~~h Frnr (=,xm3p1, Ritmat~-jnns- in iazhic-h June 201-3 1.8-41 Revision 17

PVNGS UPDATED FSAR F1-F014]

CONFORMANCE TO NRC REGULATORY GUIDES slhni rrnrprq :nH./nr rnuar;77. arp reqlijrpH 1h1it- maprj1l

=irrnilni-1 i -7 i jt-, nnrt

,ac't -N -r- ti-- nrc-ivrur incf rliri nq- i-hp m.n 'tri-rt- n ph;;q ' t -ho-pngit-inn n~f Ppgiil;ýt-nrxc urnigir 1,39 is ac'r'epted xait-h 1-hg fn11nwjng r'f-Inf1inn; hi- ,ijti1-ýIj7g.C t-cl mclvr t1-iC)_q qjt1-ii~t-jr-, not- jnrciH-H jn thp

,sllhjprt -,tndarrL For Pymple. sitn*atinns, in whirh qhnp rnNzprq nnt-Refef rence , 9A.3. 12 5,,9 4 17 .1 . 177.A 9. anH 17 92B REGULATORY GUIDE 1.40: Qualification Tests of Continuous-Duty Motors Installed Inside the Containment of Water-Cooled Nuclear Power Plants (Revision 0, March 16, 1973)

ESPONSE Regulatory Guide 1.40 is not applicable to PVNGS as there are no safety-related, continuous-duty motors installed inside the containment. Reference 3.11.2, 7.1.2.18, 8.3.1.2.2.9, and 8.3.2.2.1.8.

REGULATORY GUIDE 1.41: Preoperational Testing of Redundant Onsite Electric Power Systems to Verify Proper Load Group Assignments (Revision 0, March 16, 1973)

June 2013 1.8-42 Revision 17

112-F014 PVNGS UPDATED FSAR CONFORMANCE TO NRC REGULATORY GUIDES REGULATORY GUIDE 1.53: Application of the Single Failure Criterion to Nuclear Power Plant Protection Systems (Revision 0, June 1973)

RESPONSE

The position of Regulatory Guide 1.53 is accepted (refer to section 7.1.2). Additional references: 7.3.5.1.18, 6.3.1.3, 8.3.1.2.2.12, and 8.3.2.2.1.11.

REGULATORY GUIDE 1.54: Quality Assurance Requirements for Protective Coatings Applied to Water-Cooled Nuclear Power Plants D E LE T E RESPONSE PVNGS identifies conformance to the regulatory positions of Regulatory Guide 1.54 (including any RESPONSEexceptions or clarifications) in the PVNGS Operations Quality Assurance Program Description.

The requirements of Regulatory Guide 1.54 and the referenced st dard (ANSI N101.4-1972) are included in the APS quality progra except as modified or interpreted below:

A. Sect 2.5 A meeting 1 not necessarily be h prior to coating work or a demon ration conduc provided all parties understand the coati re rements and acceptance standards.

B. Section 5.2/

Coating ocedures used by suppliers not be requ ed to be submitted to the owner or h epresentative. However, they will be require o be June 2013 1.8-65 Revision 17

DEEE12-F014 PVNGS UPDATED FSAR CONFORMANCE TO NRC REGULATORY GUI S approved by the coating applicator and coating manufacturer.

C. S tion 6 Inst ad of using a coating inspection agen y, coating inspec rs may be assigned by the owner r supplier to perform is function. These inspecto s will meet the qualificati n requirements of secti 6.3.1, but may be assigned othe inspection duties s long as these duties do not i terfere with th coating inspection.

Service Level I, II, and I I coating are defined as:

Service Level I coatings are sed n areas inside the reactor containment where the coating f lure could adversely affect the operation of post-acciden fl *d systems and thereby impair safe shutdown.

Service Level II coating are used in eas where coatings failure could impair, ut not prevent, no mal operating performance. The f ctions of Service Leve 2 coatings are to provide corrosion rotection and decontaminabiity in those areas outside t reactor containment that are bject to radiation exp sure and radionuclide contamination. Service Level II co tings are not safety-related.

Service evel III coatings are used in areas outside t reacto containment where failure could adversely affect he safe y function of a safety-related structure, system, or c onent. Service Level III also includes immersion surface June 2013 1.8-66 Revision 17

j*DELETE I PVNGS UPDATED FSAR 12-F0 CONFORMANCE TO NRC REGULATORY GUID of fety-related piping, tanks, ducts, and safety related syste and components.

Balance Plant (BOP) coatings are used in areas outs e the reactor co ainment and not subject to radioactive contamination These areas are not classified as ervice Level I, II, or III.

The selection of p otective coatings for spec'fic locations and the extent of applic ility of Regulatory ide 1.54 shall be based on the following oatings criteria A. Location Coating systems sele ed fo either shop coatings program or field coatin s are based on the location of the particular area or q ipment within the plant, as it may be subject to un ue en ronmental exposures and service conditions These ar s are identified as Q, RCA, and NON-RCA areas.

1. Q Area (n clear)

Area 1 cated inside the Containme t Building (Ser ice Level I) and immersion sur ace of safety r ated systems and components (Servi Level III) hat may affect the safe shut down of th plant.

2. RCA Area (decontaminable)

Area located outside the Containment Building ut subject to radioactive contamination (Service Level II) . These areas include portions of the Auxiliary, Fuel, Radwaste Buildings, Low Level June 2013-' 1.8-67 Revision 17

DELETE PVNGS UPDATED FSAR 12-F014 CONFORMANCE TO NRC REGULATORY GUIDE Storage Facility, and Dry Active Waste Processi Storage Facility.

3. NON-RCA Areas (Balance of Plant Areas) reas located outside the Containment B lding and no subject to radioactive contamination. These are 1 areas not classified under or RCA (BOP as descri d above).

B. Quality Assura ce Requirements

1. Summary

a. Compliance with Re ulatory Guide 1.54 for RCA and NON-RCA rea is not required and, therefore, wi not be imposed for these areas.

b. Coating stems use in the Containment Buildi g shall meett testing and evaluation crit ra of ANSI N101.2 r ASTM D3911, A M D4082, and ASTM D5139. The coating used shall be certified by the co ing manufacturer to withstand the spray solution proposed by the project.

c. Compliance with Regulatory Guide 1.5 for each and every item to be located within th Containment Building is considered impra ical and in some cases unattainable. Therefore, Regulatory Guide 1.54 will or will not be June 2013 1.8-68 Revision 17

DELETE PVNGS UPDATED FSAR 12-F014 CONFORMANCE TO NRC REGULATORY GUI S imposed in accordance with the following criteria:

2. Regulatory Guide 1.54 will be imposed fo items located within the Containment Buildin as follows:

a. For shop priming of liner plat , structural steel, and fabricated shapes.

b. Fo shop priming of fabr ated pipes, tanks, HVAC ducts, and equipm t.

c. Field t ch-up of a Q class coated items, except as oted i section 5 below.

d. For field fi h painting of structural steel and equipme w ere called for in drawings and specifica ions.

e. For su facing of con ete where indicated in dra ngs and specifica .ons.

3. Regula ory Guide 1.54 will be iplemented by req rements as follows:

Use of specific coatings system which are Design Basis Accident (DBA) quali ed to ANSI N101.2 or ASTM D3911, ASTM D40 , and ASTM D5139 in the Containment Building.

b. Surface preparation standards C. Surface profile requirements June 2013 1.8-69 Revision 17

DELETE PVNGS UPDATED FSAR 112-F014 i CONFORMANCE TO NRC REGULATORY GUIDE

d. Application of the coating systems in accordance with the paint manufacturer's printed instructions

e. Inspections and nondestructive examnations

f. Identification of all nonconform nces

g. Certifications of compliance d/or d umentation procedures to satisfy project req. rements

h. Coated urfaces not me ting the requirements of Regula ory Guide .54 will be considered "Unqualifie Coat g" applications, see Section 5 for T acking.

3.1 Items (b) throu h ) above shall also be applicable fo Q area coatings applications outside of he Containm nt Building.

4. Regulator Guide 1.54 will n t be imposed when:

a. T item is to be insulat

b. he surface is contained wit in a cabinet or enclosure (the interior of the cab of a polar crane; the interior surfaces of ucts)

C. The surface is stainless or galvani ed

d. The coating is used for the color codi g markings on piping.

5. Coating surfaces applied in the Containment Building that do not meet the requirements of Regulatory Guide 1.54, as stated in item 3.a above, June 2013 1.8-70 Revision 17

PVNGS UPDATED FSAR CONFORMANCE TO NRC

,, DELETE I REGULATORY GUIDES are nonconforming and shall be documented as indicated below. These coatings are consider to be "Unqualified Coatings."

a. e field repair to any "Q" Cla coated item with unqualified coati system shall be documente nd report for tracking in the Unqualified Coa g Log.

Containment building inte or coating stem assessments shall be performed in acco ance with the Contai ent Coatings Condition Asses ent procedure every operating cle.

Refer to ubsection 6.1.2 and section 17.2. Also see sec Ion 7.1.2.9. Additional references: 3.8.1, 4.2.5, 5.

.1.4.6, 6A.5, and 17.lB.

REGULATORY GUIDE 1.55: Concrete Placement in Category I Structures (Revision 0, June 1973)

RESPONSE

Except as discussed below, concrete is placed in Category I structures in accordance with Regulatory Guide 1.55.

Creep tests are normally performed on prestressed structures only. Loss of prestress through creep is not applicable to nonprestressed structures. Reference section 3.8.1.2.3, 3.8.1.6, and 3.8.3.2.2.

REGULATORY GUIDE 1.56: Maintenance of Water Purity in Boiling Water Reactors (Revision 0, June 1973)

June 2013 1.8-71 Revision 17

PVNGS UPDATED FSAR 112-F14I CONFORMANCE TO NRC REGULATORY GUIDES

RESPONSE

Not applicable.

REGULATORY GUIDE 1.57: Design Limits and Loading Combinations for Metal Primary Reactor Containment System Components (Revision 0, June 1973)

RESPONSE

Not applicable. Each PVNGS unit utilizes a prestressed concrete primary containment.

RFFiiTATn]3y rCTITBP. I r)R li1fr1 n nf jr1r Prnwdr P1 ;r]2-Tnqp~rtinn; Fxnmin*i nn and Tpqtfng Personnnl (~rei inn I,

,q nt-amh:)r i cAn)_

RFS2PflNSP.

Thp posit-ion nf Rp*ugnat-rv (lli-rip 1 ,R5 8 rrqrpt-id winth thp fnl lnajng PxrPjpt-i nn.-"l

_ Pnftýi)nn C. 1 The q1ial ifi rjc i nn nf p~j:nnnil P j hn pprivnx prennprationnl and startup tpst nrnr-irp and tp-t rslllts -g nd tnhnr-l

- who HitcHi nr ipp l]1 TiSE T tl p rnnHiiirt rif jnHi ui i1:] pr~npPr;h nna1 and startllp t'qi- La HisiIlssedH in par-gaqrap 149 ?2 19 ThE q1jajifijri-tnn nf nthpr pnrqnnnjl Hi*c'liq~H in Pn-itiinn ( 1 fnInllncmy the g r1i-llnq of ls p.giltnrw ? 4ijirip 1,8 niin June 2013 1.8-72 Revision 17

PVNGS UPDATED FSAR F014 CONFORMANCE TO NRC REGULATORY GUIDES B.ý Pnsit-nn C' ;

Thp qp-fjr Prbjric-'tjnn ;ýmc -Xp ripn- rprnmmpnHzd- nn of ANSJT N41:')2 6-1978 for u\Tir-inhiq1,-7,I r f jnspp~r'tn-r.

'qh,11 nn-t hp trp;;tpd ;;. ;;h.n1,Qip tiahpn nthp~r f,ýctnrq p mU, dp rp:;c~nA'hlp ~' ,~rnr' th , t- :-ppr.nn C-a cnnmp~t-nft1 x pp-rfn~rm ;ý parti r'iil,ýr t-k- Thq f.ýrtnrg la' 11 hi- Hnr-unpntn1-. uiLth jis firati on bhy Tnanaqtpmirnt (nn ;:;] -indjvh-iH;ýil d,-T) n~n.tr~t-jnc t-h;;t- t-hp j nc 3Tidi U1 :;1 rinpc havep ecuiui nlnn1- r-nnmpptpnr6- to thh; whih-i-rh TnilT hp I-, ;npnH frnmn h;:~iun fi t-hp rrglijjreH PHiirr:itjm n And Pwppri pnrp Tn ;HHt-j1--Dn. 1-h( fn11n¶ain" Pppt-jrn-, ;:;rp t-zflc=2 t-Q ti-h rpf,-rpnrpHr1in~r ANSI N45. 2 C)-19-78 arp Tn~rip-A- Th,- fir~t- -n1-tnrc of Paraq-raph 3-4 -qtl-tp 1-h;;;;; T.irpl TIT qun:;lfipH ;Drso-n c-;h;;1 h;:v7- all I-hp r;:p;:hjl1ipq cnf

T.Np TT g1lalfjpd pp~rqr)Tn fnr t-he -ingpen1t nn Pxv;=in~-t--n n-r test1 r-ategnrv n-c in cpiegt-ion A Pq iaj1 1 cpj;;I Jf v T,,-T,-1 T TT p Pr q 0n -,i n ihnnt- t-h po; ~r t-i i, h;

;nHi n~n Pxpp~ri pnrp AnH r-;pmb 1jtjZ tcn ppz-rfnrm spec'if-i r jnqp,-r-tjrnnc,. PYAm-int--nn-- nr 1-p'1-g rpcpiir,-r nf ;; T.Pp]r T o r TT cpi lfjpriHp I~rsciznn ;:nrH iiit-J1 7- t-hg c-p pe rs~nn c fnrr

drvi n-i t- r;

;i-p n; inr s11p,-ruT-inrw fiinnl- nng jnr-inl ijrj-9 rprt-Hfri n" persons At- the sam n-r 1 nw~r 1 pm'1 BT.. Pariagraph Rt~ q t-hat- ;= T.,pvpl t-,1- TT gli1: ;lf-ipr pi-r-'nn

,hall1 h,.;7P H9pmnni-rt-npH6- Pxpprinr -iL2n rpr1--ifý7in" 1 ntar 1,-v17l gii;: -if-i rH ppr-,nn.-, 7\PC cinp' nn1- iii',e T,p-Nnp1 TT j fu;l P fpergans, t-n' r-rt- f-u' 1 nxag-r I p-up] C1~];;I f j PH June 2013 1.8-73 Revision 17

PVNGS UPDATED FSAR 12F014 CONFORMANCE TO NRC REGULATORY GUIDES perSnrq. and dopq nnt- rt-Cii re Tp P1 TT c11jlifjPd p r'qnnq toHPmnn~qtr;tP In fhi r;p;hj li-I-w Thi fnl1 ni-ng nt-PrprPt-at-c1nn iLs a msomade-n t legilltfnry A. Pnc4 -inn C'_1 Fnr givZ qllIfir,-ionn nf ;Prconnnel;, (1.) wdhn jDPifnrm nr and (2) who -i rp nr lci p -hp rcrnnr-t- nf jnHjiu-irj;i:1 noprt--Jnna1 the gllhdpl H ne rnnt- 1n7pd in 2pgqill;: f-rw/ *lcl i p 1 R RpNi p, Jon 1-P, "PPr-onnnpl

.qflP] r't-jnn ;nrl Trgjning" wt1-h t-hp rr-ite-pr-i 7 fnr

p1Pr7t-inn ancI t-r;injn ronn-AonPd in ANJT./ANS .- Tq7R Rll-1--it 1-lii-p *-for al\1RT-N11 P 1-1 q71 _ 11 h r 1 njp_

f1nl

. ] C*ln rnoin r-mr n rn-' 1-cn PR giil ~1cnru' (lii rIe 1 R Parsonnn1l plpcf--inn anH TrLinirn (RPui.ui n I--p MAz I q77) ,

Rpfer-nr* -prt-innS 17 1A 21 17 1 8; 1-7 ?R _ cnH Tab] 1~ R TT 1]' 9--

REGULATORY GUIDE 1.59: Design Basis Floods for Nuclear Power Plants (Revision 2, August 1977)

RESPONSE

The position of Regulatory Guide 1.59 is acceptea (refer to subsection 2.4.2). Additional reference: 3.8.1.2.3.

June 2013 1.8-74 Revision 17

PVNGS UPDATED FSAR CONFORMANCE TO NRC REGULATORY GUIDES D. Low Voltage Control Systems For low voltage protection circuits connected in the containment, redundant protection is provided by a combination of two fuses, a combination of a breaker and a fuse, or two breakers in series where the circuit resistance does not limit the fault current to a level that does not damage the penetration.

E. Instrument Systems The energy levels in the instrument systems are sufficiently low so that no damage can occur to the containment penetration.

The circuit overload protection system for electric penetration assemblies meets the single failure criterion set forth in IEEE Standard 279-1971.

The overload protection systems do not conform to the online testability, bypassing, or manual initiation criteria of IEEE 279-1971, since these criteria do not apply to these systems.

Reference 3.8.1.2.3, 3.11.2, 7.1.2.22, 8.3.1.2.2.14, and 8A.11.

PFrGTTATVRY ruiTnE 1 , F*4 - Qn;;1ji7y Ag-g1irncn RPqgivir7Mntni fo r thi=

- m gn nf *Toblrl Prnwgr P1 lants (pujqjnn n. nr-tnhbr 19qT)4 RP*p17 ;tnr\7 G111de 1 64 endnreqg A lqjno-rr H Hdrj f d-r ig;ft cmf ANST N45 2 11 For r-7'q prngrm, r*@fer to qeCtion 17 1C Th e June 2013 1.8-78 Revision 17

PVNGS UPDATED FSAR EýT 01L CONFORMANCE TO NRC REGULATORY GUIDES Rprhi-p. prncgr;=i romp11Pq wti--h ALNST N45, 9.1-lQ)74 i pP-c hprp-in A qpr1-t- nn ý -I ThiS qprtnni-nD -mpijp ti~i1h;;- ýll nprp'q'arw rdpgln -input- (;:-

lisfpd -n qartjorn 2 9) -ghnii1c] hpu1T~ prinr t-n t-hp St;;r1- nf ;= ( ~psj n a r1-i ITjtw7 Tn prir-r---rP crt-;;n ric.qin

rt-iujt--ip a-re -inj1-jpr] hpfn-rp ti-h f-irm inplif-rpqjjr~npt-q;

rp ; 1 hj jh1 (P'nr Px,;mp1 t- fnirnc1jh-icnn

-p'~i gn- flr~ppiri~r has'tpcl nn prprl rn-i n = infnrmn;ýtHnn jw nr ngiiijjpm~np q~j ~pc ;ncj rnintn-i nq ;;nc embedripci (nnnc-jii - rim 1miPHnn prp] -i DiA rxi estimatespc of r-ircij -t rpcpijrpmg-nt-ci)

The dpgnq3 phaspr QA\ prng-ramr j-, q:riic'f-iirpc- t-n aq.-iirp t-hat-

=II1 nepr'pa3ýrx dasirn .inplii- 'js ;: =1mý1 p hp~fnr~

romp1pti--n of f-in;; rip.-Lgn nf t-he work affec'ted hu7 t-hp 1 fpul- ;ýnrd H-ih:; fi nal d1pq n jnplll isc :ý7T;; 1 ;:h1 - frnr ii.-,

in izpr-if r'aI-i n n~f t-hp f-iný;] c~p.- cvn ggC: irt-,n4I 1 L)-- i qn fl, Prncpqq r pnpr;: 1 P;ýr;:;r~ph 2 implipq t-r r,-;=bjljxi b~rk frnm f-in;=i ri1-qgn tfn I-hp q~niirrp of dpjq ojlit, Tr pr;:r1-tr-P. A 1 it-r;;1 1 nt-~pr;2rpt;i-Hnn nf t-h-jqig' not- ~ pnc---ih1- Tn r rc-];:;-pc1r'j ri~-i T'hj- p~rngic-.~ph Jq *inI-pr;D-r1p I-n rn;ýn t-hat -it sh;ý;1 he 3zmqsih1p to rp1at-E! I-hg rrit-pri;

=ind~~n1'p pprfnrmadr I-n the fina] c~slqn drlnrirpntg' ;: nd I-h;:t- rprnrcl f 1 pq will pp~rrn - 1nr)1- :t-nn nf

~1 \7C,11jiipprtjnc nq Dpcjifjr HpcH g niit-piiI- rl-inni,-ntn-q June 2013 1.8-79 Revision 17

PVNGS UPDATED FSAR 14I

-F0I CONFORMANCE TO NRC REGULATORY GUIDES Addjtnn;1 rpprn-q I .? 9 ,- 4 9 1 4, 5 4 -7. J. 6, 3, 1 3. 9. 1 .4 6. q -3 4 - . 17. and Tahd-~1 IR TT 7 -

PEFGT1TATC)TY G(ZITOF, 1 )4- fln;=jtx7 q jg1rpT-n,-n-Rmrr' fc-r the FlPqi gn rf N\iirc'1 ; Pnwiipr P1 .;nt-q (P~uc c 2, Tiinp lq7N;)

PP P P OQN1PP Fnr cppatnnq rt t-bat- 21:- rccmp;;r;;h1 tr ar1- -ti i-jes cnr'rijrr nq cHnin n th,= ronqtrn(i-'tHn phs. thez ppsjt--io o~f TRpqliil:t-nrx, C-,vicjri 1 E4 J- (r'rpjt-pc1 idth t-hp.

fo11otmi-n" ecept-Jon t-m Proc~-it-irin P'2

.qn,-r~jSr\7; p~j-r~onnp1 M;:xy p2-rforrrm rlcqj-i vr-fi uo Ir1-A-inn iindk-r evreptionn;l ;;sim~r'cdoriimmpnt-pl ;:nrl apprrCý7Ld L7 I-hp ncvt- 1 N7T- 1 o-f qiipprujT1 'i 3 fn

'L- Th~ i1-fI-'I- (for da-cjqn wTprjfr =tion hbw;:

rdi-I gýnerl'g mmpdli tp- sui P-rui c~r) Js jncli u-Icidiw~l HrijMpntEl Andl apprruarl in ;:iujjno~p aLnc 9-... fii~1 -j1- ac;Sjrnar~nrp airldi t-roug'r frecpii-nrow ,-n g-ffprt1- -rpq ~fr iiq, r f qijp~r-mI ,;r'r as'd p g inrfjpr-un to qiia~rcl aai nct ahliip, APP intprprptq ANIq1T 1'j4l 9 11-lqg74. qpgrtjnnqn'ý I1 :nc 4 J. ;=l for)1 1or~w--,

qpgri-irn 'ý 1 This gert1i on I tip ihati ;:1 1 ng-rinxr dt--,n -mpli- (,;

1~c~cl-n -,r'-tion '-9) R~ho-)i]H hp iu1:;lqhj p2rn-io t-r 1-hg' June 2013 1.8-80 Revision 17

PVNGS UPDATED FSAR 112-FO14 CONFORMANCE TO NRC REGULATORY GUIDES Rt;;ri- of ar dpqgn air'1-Lv-il- Tn prartire- c' r'erti-in rl-,jc~

artv~tas ýr -in-itipted hp-fnrE t-hp firm inpitl rcpqii rpmentqc ar a37,1 1Ih;;z (For- Pv-amplp. foincat-i on d-lqcHgns preparprH bhasc on pre1 minv;3:W jnform;;t-jon o-r Pqui pm~nt- sizes a~~

nd moinnt ng ;;ma PmhP(9dcpd- oonrii lt rni hs-ion prpl1m imn rw Pqj~~ o~f rjrriijt- -r,-"iirL-m~nt-.-)

Thp ri~s gn phARcP QTA pror~qrn ic; cs-ruirt-lirtH to) that-all rPq~zrý Hp.rJqn inplit jsv1-~p1gfr r-mp1~jl-onn of fin~l c ~~nof t-he !iork ;:ff~rl-tzr hx7 l-hp

-jnpult- ýnc.] that- final 1.Psjcgn in;Dii Js au T1J1-i1p for use in ur~fr~i--Iton of j-hp f-in;:; rdp-gn" B...~~r-in-~n A 1 T)h-siqrn Prnr_,-qcu (-,inPr, 1 P~~rph?-mpljp- trcphl-xi hark f-rrm f-Fjin~ cj~qgn l-o l-hp cuou-rc--. nf des'in n jin;Dlit Tn prartirp, A 1lite-ral1 jnl-rpr~l.t--it on of thi s, j.-, not- izllT 1 -

7.x poccv. ,i h 1 - 7 -r exa~mple., f~n-i nl Hqq dr,ý107nqs do not- ir-nli fxz l-hp rP1;:&r1rPru1l-io' Tý)hq paraqraph g -intprpretedc l-o mp;:n R-~-i-'~hul hp pnqqBilp tor rpl;ý;t-. l-hp rr~t-rnri:

ij-'i~rl ;nri an,;1 ~-,7'e pfjrforuruPr to -t-hp final c-lriu-i ciorlimp~ntgc ;ndllhl rirorc1 fi 1 uwill

.- parm-i - 1 orat-ion of an]Wp1 , ipprortHi~ ospe.r'-ifi r dpcv g-n null-pult- rlonuumnl-s.

P~f r~n-Pq 1. A

4. S c 1 4A ý A '7 1. e 3 9 1 A, 6 g9 4 6. 1-7, ;;nr Tahlp JR-TT F ?--ý REGULATORY GUIDE 1.65: Materials and Inspections for Reactor Vessel Closure Studs (Revision 0, October 1973)

June 2013 1.8-81 Revision 17

PVNGS UPDATED FSAR FT12-F014 CONFORMANCE TO NRC REGULATORY GUIDES

RESPONSE

Not applicable to PVNGS.

REGULATORY GUIDE 1.73: Qualification Tests of Electric Valve Operators Installed Inside the Containment of Nuclear Power Plants (Revision 0, January 1974)

RESPONSE

The position of Regulatory Guide 1.73 is accepted (refer to section 3.11 and 7.1.2.22). Additional references: 5.1.4, 5.4.7.1, 6.2.4.2.2, 7.1.2.24, and 8.3.1.2.2.15.

PPFXT7T.ATC)PQY (-TITBnF. 1 flii tx 7 . cir,rnrp Tprq A- rn Tph rii a L*1 74)

Rgspfnmsp Thp Xpogitin nf Reqii1atornrxi C1iijc 1 74 JS arcptpri~ (,:-p t-rn sartioin 17 2 and 17-16) , ddtiC~nal rf-Pr~nr~q 4, ~1 5 -4,

') 4 -7 I1 C 1, 4 ý;. 1 7 ,1 A. 17 , 1, ~n

d T;ih P1~iR ,T T 7 . 2-REGULATORY GUIDE 1.75: Physical Independence of Electric Systems (Revision 1, January 1975)

June 2013 1.8-89 Revision 17

PVNGS UPDATED FSAR FO-1-4]

CONFORMANCE TO NRC REGULATORY GUIDES REGULATORY GUIDE 1.86: Termination of Operating Licenses for Nuclear Reactors (Revision 0, June 1974)

RESPONSE

The position of Regulatory Guide 1.86 is accepted.

REGULATORY GUIDE 1.87: Construction Criteria for Class 1 Components in Elevated Temperature Reactors (Revision 0, June 1974)

RESPONSE

Not applicable.

RECULATORY GUIDE 1.88: Collection, Storage and Maintena Nu. Powers Plant Quality Assu9ance Records(Rcvisic:n 2, October 1976 RE SP ONSE Th posit4# ofegulat

{ion G,41d 1.8 -is accepted with the following exceptions to Sertiqo 5. of ANSI N45 2 9-1974:

,A-i Doors, Str-ucture and frame, andhardwr-e shal be designqed- toA comRply wi4th1 th1e reurmet f amimu 2-hou fire rating. (Sectio n 4.4. (G) of Supplem.ent

!7S-! of NQA-! requires 2-hour rated doors and dampers, and the latest version of Regulatory Guide 1.28 provides no additional guidance in this area.)

Vinyl tile is u.sed. on the flo-r in lieu o.f a.urfa

.seal-an.-t-9.

June 2015 1.8-98 Revision 18

PVNGS UPDATED FSAR112_F014 CONFORMANCE TO NRC REGULATORY GUIDES 9-- A roof drainage line penetrating the stutr aAs been plugged- to avoid any potential flooding due to rain.

There is a floor drain with a vent line loatod in the center of the room. The ven.t l1 ine to the ro is exclusively for the drain and it does net carry liquids, therefore it does nt present any poten lflood-ing problems to the storage room.

T-ý PVNGS also providePs the -followingcaictonWith.

regard to application of -ANSI1 N'15.2.9-!974:-

PVNGS adheres to the guidance of the Standard for classification and reteon pe*rJi*odS of quality assurance records, unless other more stringent requirements apply or a graded approach as def*

Sectioen 1-7._2 -has been applied to dtriethe reltv vaplue of the re-o-rd- or group of reod.When-the, graded approac. i-s utilize4, te e-x-e-nt t. whc the-record maintenance and storage requirements of the St-andard apply may bemoied For quality assurance records to which.the graded approach is not appliedy the record0s shalhe maintained and store consis~ten~t with applicable regulatory requirements and the pertinent requirements of R.G. 1.88 and ANSI N45.2.9-1974, with exceptions as noted, in A through C above.

Reference:

175.1, 1.2, and Tablei June 2015 1.8-99 Revision 18

PVNGS UPDATED FSAR ~i1-14 CONFORMANCE TO NRC REGULATORY GUIDES REGULATORY GUIDE 1.94: Quality Assurance Requirements for Installation, Inspection and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants (Revision 1, Ap4i1 976)

RESPONSE

For operations phase acti-Jvite thI; At- r*e cemparable o activites durig th1e co9rutonpase, th1e positionAP o-f-Regu..latory C.4ide 1 4is accepted (refe-r to ection 3.8)

Additional references: 17.1 and 17.2 REGULATORY GUIDE 1.95: Protection of Nuclear Power Plant Control Room Operators Against an Accidental Chlorine Release (Revision 0, February 1975)

RESPONSE

Regulatory Guide 1.95 is not applicable to PVNGS as there is no gaseous chlorine stored onsite and the nearest railroad route for possible chlorine transportation is several miles away.

REGULATORY GUIDE 1.97: Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant Conditions During and Following an Accident For operations phase activities, PVNGS identifies conformance to the regulatory positions of Regulatory Guide 1.94 (including any exceptions or clarifications) in the PVNGS Operations Quality Assurance Program Description.

June 2015 1.8-105 Revision 18

PVNGS UPDATED FSAR h /2-FO141 CONFORMANCE TO NRC REGULATORY GUIDES

RESPONSE

Information contained in Regulatory Guide 1.112 is utilized as discussed in section 11.3.

REGULATORY GUIDE 1.114: Guidance on Being Operator at the Controls of a Nuclear Power Plant (Revision 1, November 1976

RESPONSE

The position of Regulatory Guide 1.114 is accepted.

Reference 13.1.3.1.

REGULATORY GUIDE 1.115: Protection Against Low-Trajectory Turbine Missiles (Revision 1, July 1977)

RESPONSE

The position of Regulatory Guide 1.115 is accepted as described in section 3.5.

REGULATORY CUIDE 1.116: Quality Assuranoc Requirements for Installation, I8nPe..tio, and Tcet.ng

-97 - -I1 - - - - .- 1 H 4! pqk.ý kýi ieqvi i ý!; 1!1 !t- En $1-iti!E i i 1=

(Revision 0-R, May 197ý7)

Fo oertons phas a 'tivitio,th 'psiio of Regulator Cuide i n11 is accepted with the following intr.rt.ton of ANSI N45.2.8:

June 2015 1.8-149 Revision 18

PVNGS UPDATED FSAR I CONFORMANCE TO NRC REGULATORY GUIDES A-.- Section 2.3 Test rcports attached to or referenced in data sheets may meet the evaluation requirements of the last par-agraph.

-9. Sections 2.2 and 2.3; 5.2 and 5.-

F.or applicatin of the provi:sios oAf*the osetions to prepertioal nd- st-artu~p testi=ng, th~e IPS posi:tion An th~e applic=ablqe r-evision1 of Rgltr ud 1.63, "Pr-eoper-ational and1 nialStar~tup Test ProGgramsg for4 where there is a conflict of difference.

g.-. Item 2.9e(6)

This ite s~hal Ilz beitrpee to) mean6; thlat- any workw perormd ithutan approGvedl desi.gn chiange sh~all not beG considePred--- complete andl acceptab-le -for--itsiJnte-nd-ed u.se until:te ch~ange i:s approevedl, and th-at th-e -in-teint of this item w-will be satisfied provided that such work activities and the results are documented. Evidence of dsgchn approv.l.shall be--required prior tov plac4ingf thýeafetdieinsrc.

- Section 5 Frc)l thqe purýpoese of functionapl tests ac-ddressed b9y thpis standard, PS defpneqsr completed systems as any system, orz potin r-component th4er~eof, onWhichlq Aosrcin is. suficinty complete o allow.. the required testng, Jun .e 2015 1.8-150 Revision 183

PVNGS UPDATED FSAR CONFORMANCE TO NRC REGULATORY GUIDES an n Whicq-Jh -f-14urther o--

oPG r- adjýacGent const-#-ruction-wil q not;-I render the results of such testing invalid or indetermin....te-.

tiesm s discussed in Section. 5.2.13.3 of ANSI N!8.7.

ReP-fe-r-ence sectionGPs 1L42.7, 17.lA.2, 17land 17.2P.

REGULATORY GUIDE 1.117: Tornado Design Classification (Revision 1, April 1978)

RESPONSE

The position of Regulatory Guide 1.117 is accepted to the extent described in sections 3.3 and 3.5, and subsection 9.2.5.4. Also see Regulatory Guide 1.76.

REGULATORY GUIDE 1.118: Periodic Testing of Electric Power and Protection Systems (Revision 1, November 1977)

RESPONSE

The position of Regulatory Guide 1.118 is accepted as described in sections 7.1 and 8.3. Additional references 14.2.7 and Table 18.II.F.2-3.

June 2015 1.8-151 Revision 18

PVNGS UPDATED FSAR CONFORMANCE TO NRC REGULATORY GUIDES REGULATORY GUIDE 1.121: Bases for Plugging Degraded PWR Steam Generator Tubes (Revision 0, August 1976)

RESPONSE

The position of Regulatory Guide 1.121 is accepted. Reference the Technical Specifications.

REGULATORY GUIDE 1.123: Quality Assuran*ce Control of Procuremenr of Items and Services for Nuclear-- Per Plants (Rcviion 1, Juy197,777).

RESPONSE

Fo.r operatio.nspaeciv , th.e position of Regulatory Guide 1.123 is accepted with the folloWing modifications to ANSI N45.2.13-1976:

A. Section..... Per.onnel. ualificat.. Personn.l performing cffsite audits shall be qualified to ANSI N45.2.23.

performing effsite material inspection shall be qualified to ANSI N45.2.6. Personnel perfG-rmi4g offsite monitoring tJ;htie

P q a] _bhp~1 ii;if-a t(: ~ANT N45 ') 5)' ,--- 7XMCQT KAr, 0 (

B. Section 3.2.3 T-he requiremen.ts of this secti ecptd ith the following exception:

When purchasing ... m..r calibration !aboratori SaccreditedI byanainlyrcgie accrediting body, the -rr~~~r~~-I4 I r~- .,. _

4r,~ 4Acn 4-- %

June 2015 1.8-152 Revision 18

PVNGS UPDATED FSAR 112F14]

CONFORMANCE TO NRC REGULATORY GUIDES ANSI N-5, _1971. Nationally.recogni4edac...diting 1o4des include the National Voluntary Laboratory Accreditation ProGram NNatioa:l ,f Institutc o Standar4ds and Tccnolgy(NIT) ndothr acrditngbodes]J -recognijzedb-y N ALAP viaoaMutual l ecognition (tRA) thruArrangement .tn-cases, Accddio y be aGceptdI 4ion leu oft ura

imposing a QA ProGgram ossetwihAS 4.-14,poie all th.e foloin are met; I Th7pe i. toN.....E rccqrediatins 17sf5.

2r. The aoredtwin bcudy is eithert NVAp or the Aerien Associatio for Laborato bryacredi . (A2..A) based*I on aot-or vers the eeen parameters, rcanges, 4J. Te purchase documents impo-se 3 addition technical and admnisraivereqirmensas neces8sar-y, to stfy APS Q sh4all spcfclyrequir4:e thaqt- thecairto ceifce or- repor-t wJlll include identifiat ion of- the equaipment andl,'or st-anda-rdczs u4sed.

5. The purcGhase doumnt equir-e rceporting as-foun~d caibato dAtaqwhen caiba te item ar foun4:d to b June 2015 1.8-153 Revision 18

PVNGS UPDATED FSAR I 12 I1 CONFORMANCE TO NRC REGULATORY GUIDES Information contained in Regulatory Guide 1.140 is utilized as discussed in sections 9.4 and 11.3, and in table 1.8-3.

Additional references: 9A.38 and 14.2.8.

REGULATORY GUIDE 1.141: Containment Isolation Provisions for Fluid Systems (Revision 0, April 1978)

RESPONSE

The position of Regulatory Guide 1.141 is accepted (refer to subsection 6.2.4) except for the following. An exception is taken to Regulatory Guide 1.141 for the CVCS charging line containment isolation valve CHA-HV-524. This valve does not meet the guidance of Section 4.2.2 of ANSI N271-1976 which requires all power-operated isolation valves to be capable of remote manual actuation from the control room. The power supply for this valve is removed by locking open its breaker at MCC PHA-M3520. The restoration of the power supply requires local operator action at the MCC. This exception to lock open valve CHA-HV-524 ensures that a flow path is available for charging or auxiliary spray flow by preventing inadvertent operation of the valve.

REGULATORY GUIDE 1.143: Design Guidance for Radioactive Waste Management Systems Structures, and Components Installed in Light-Water-Cooled Nuclear Power Plants (Revision 0, July 1978)

June 2015 1.8-163 Revision 18

PVNGS UPDATED FSAR CONFORMANCE TO NRC REGULATORY GUIDES

the PVNGS Operations Quality RESPONSE Assurance Program Description.

PVNGS accepts the position of Regulatory Guide 1,143 including implementati n of quality assurance requirements for the radwaste mitagement systems (refer to sections 9.3, 11.2, 11.3, 11.4, and Additional references: 3.2.2 (Table 3.2-1),

6.2.4.2.2, 11.5.4.2, and 11A.1) with the following exceptions:

A. Position B, (Discussion) - For the purpose of this guide the radwaste systems do not include instrumentation and sampling systems beyond the first root valve.

B. Position B - The instrument and controls of the gaseous radioactive waste processing system satisfy the requirements of Section 7.2 of ANSI/ANS-55.4-1979 referenced by Regulatory Guide 1.143, Rev. 1, with the following exception:

The system gas analyzer, as specified in Table 6, will not record the H2 % by volume. It is assumed that the gaseous radwaste system will contain > 4% H2 by volume whenever the system is in service. Monitoring the potentially explosive mixture will be based upon this assumption and the measured 02 concentration by the gas analyzers.

C. Position C, Paragraph 1.1.3 The turbine building, which houses most of the steam generator blowdown system, is a Seismic Category II braced steel and concrete structure with a design that has been shown not to collapse under SSE loads. The June 2015 1.8-164 Revision 18

PVNGS UPDATED FSAR CONFORMANCE TO NRC REGULATORY GUIDES turbine building has no means of containing the maximum liquid inventory contained in the potentially radioactive portions of the steam generator blowdown system. This potential for liquid/gaseous release is less than that resulting from failure of the refueling water tank analyzed in subsection 15.7.3 where the radiological consequences have been determined to be less than 1% of the 10CFR100 limits.

D. Position C, Paragraph 1.2.1 High level alarms on tanks in the radwaste building alarm in the radwaste control room instead of the main control room. A common radwaste alarm sounds in the main control room for any alarm that exists in the radwaste control room. No tank has a local alarm as the tank overflows are hardpiped to sumps avoiding local uncontrolled spillage.

E. Position C, Paragraph 1.2.3 The blowdown flashtank, (SCN-XO1) in the turbine building, does not have an elevated threshold to catch potential leakage. However, because this tank operates at an elevated temperature and pressure, any leakage would be initially visible as steam. Liquid leaks would be collected by the turbine building drain system, which can be routed to the liquid radwaste system.

June 2015 1.8-165 Revision 18

PVNGS UPDATED FSAR 12_F0141 CONFORMANCE TO NRC REGULATORY GUIDES F. Position C, Paragraph 4.3 Pressure testing (hydrostatic or equivalent pneumatic) is conducted using the applicable ASME or ANSI code, but in no case less than one and one-half times the line design pressure for hydrostatic testing and no less than 1.2 times design pressure for pneumatic testing of the GRS for a minimum of 10 minutes as required by the above codes.

G. Position C, Paragraphs 5.1.2 and 5.2.4 The reinforced concrete design of these structures is in accordance with American Concrete Standard ACI 318 in lieu of ACI 349-76. Structures containing radwaste systems are analytically verified to withstand SSE loads without collapse.

H. Position C, Paragraph 1.1.2 "Materials for pressure retaining components" will be met for Chemical Waste (CM) system, except that ferritic ductile cast iron that meets the requirement of ASTM A-395 may be substituted for low carbon steel components where the maximum service temperature is 200'F and the maximum service pressure is 200 psig.

Welding shall not be permitted on any ductile iron component.

June 2015 1.8-166 Revision 18

PVNGS UPDATED FSAR FIF141 CONFORMANCE TO NRC REGULATORY GUIDES REGULATORY 1.44:

1UD Audpiting ofQultAsraePogm for Nuclear Power Plns Rvsion 1, September 1980)

RESPONSE

Th4e requirements of the referenced sadr

(*ANSI N]A5 9 10-1977n) aS moiie nd inte~rpretd i.n the the following ec*eptins A-i Section 4.3.1 requires that a brief preaudit conference be conducted;-4ith cognizant oranization management. A f-rm-al preaudit conference ay not bgeruired for some ruie iea audits.-here' informl p2r7auI communication is determined to be adequate. T of the auditing organization will monitor the performance of audits, through revi-ew of audit reports, to ensure that informal preaudit com-munication is utilized only in cases w,-here suach informal communication i dqae

-.- Section 4.5.1 states that an y "adverse findings" shall be r-ev-iewed and investigated to determinpe and schedule a.pproriate orrecti.ve action including-action to preVent rcrec. Consistent with the PVNGSpsition established ins on.. 1.8.fo Regulatory Gide 1-.33, PVNC reqiresdeteminaion f root cause anpd atin to prevent recurrence for significant conditions adverse to qunali2ty t-hat areident e driin a June 2015 1.8-176 Revision 18

PVNGS UPDATED FSAR 112-F014 CONFORMANCE TO NRC REGULATORY GUIDES intcr-pretatioen iJs cos etw-ithq Appendlix B top FRO Criterion XWVT, Cor.civ Ac-tio.

4.- A g.ra* e period of 90 days bey*ond the. specified fr..equency sh-all b-e permi=ttedla fo-r- com:pletio:n of- Supplier-q A1annual evaluation an i uple adt. When-- the gr-ace period~

Is u-tili1zed, subeuetshedluling for the evalulation or-audit shall be based upon the original due date. 1/2 grace pgeiod e -I h all be applied to evaluatin orp audits :thhv a frýequency specifically eindb regulation.

4;. Regulatory Cuide 144, Seto

.. C.3.b(2) mTh Rea!lý4pp_*tq Qf thJq q.r-#týp are aGGntndt with the following interpretationG Wh.en pu.rch.as.ing comm..ercial grade calibratio.ser.vices from calibatio labortorie accedte by a nati-haly_

recognized accrediting body, th accreditation*÷4* process and accrediting bodGy may..bhe crdie it1h a G.out a portion of theo Purchase d4uties of verif*yin acceptability and effective -iplementation of the caliba to serviA qce=3 suppli4er'1s quali.ty assurýance porm Natinaly-reognzedacorediting bodies inclludeth National Voluntary Laboratory Accreditation Program (NVLAP) administered by the National Institute of Stapdard- and- TchnGoloy (NIST) ad o-th- acrediting bodies recognized by NTLAP via a4Mutua Recognition Arr01angement (RevAs)in.

June 2015 1.8-177 Revision 18

PVNGS UPDATED FSAR I IF12-F014 CONFORMANCE TO NRC REGULATORY GUIDES Tn i .... o f performýiý* g an audit, accepting an audi by 84upplier surv-ey, a douetdrveAf the sujpfýplir's

e-G-4n accrditaionsh4all G--oin b9e per-formed b9y th~e Prh r ThPis r1eviýew Sh-all inldat a m~inimýR, all ofth

1. The accreditation is to ANSI!/ISO/IEC 17025.

-2.Th19reii gboy iseihe NVL4A-P orte ~ria Association for Laboratory Accreditation (A2LA) based upon A2LA continued NVLAP recognition through the Inentoa aoaoyAccreditationP Cooperation (ILTTAC) Muta Recognition Arrngeen...

3.. Th..e published scope -faccreditation f the calir a tionlaboratorýy cove4rs thep neededmesren par-ameter-s, -ranges, andI uncrertainties REGULATORY GUIDE 1.145: Atmospheric Dispersion Models for Potential Accident Consequence Assessment at Nuclear Power Plants (November 1982)

RESPONSE

Information contained in Regulatory Guide 1.145 is utilized as discussed in section 2.3.

REGULATORY GUIDE 1.146: Qualification of Quality Assurance Program Audit Personnel for Nuclear Po.er Pants (Revision Q, August 1980)

June 2015 1.8-178 Revision 18

12-F0141 PVNGS UPDATED FSAR CONFORMANCE TO NRC REGULATORY GUIDES

RESPONSE

The requirements of. the f . tna (ANSI N"15.Q.23-1978) as mdfied and interpreted in the Position of Regulatory Cuidc 1146 are appliled to the quality assurance program Wit-h the folloIGwing modificationS:

A_.- At paragraph 2.2.1 of ANSI NA5.2-23 Orientaino auditors is provided topr3oduce a working knowledge and understanding of ANSI N!8.7, ANSI N05.2.12, this stand*a*W, an the au.iting organization's procedures f implementing audits and reporting results.

At paragraph 2.3.4 of ANSI N45.2.23: Prospective lead auditors shall demonstrate their ability to effectively implement- the audi proc and lead an audit tea.

salhave participated in at# least one audit withiAn the year preceding the individual's effective date of qualificatio Upo sucGcessful demonstration of tha ability to effectively leaRd a*uit*,R licensee management may designate a prospective lead auditor as a "lead auditor".

Reference 17.1 and 17.2.

REGULATORY GUIDE 1.147: Inservice Inspection Code Case Acceptability ASME Section XI Division 1 June 2015 1.8-179 Revision 18

PVNGS UPDATED FSAR1 112F14 CONFORMANCE TO NRC REGULATORY GUIDES

RESPONSE

The position of Regulatory Guide 1.147 is accepted. Code Cases that are actually used will be identified in the applicable Inservice Inspection Programs. Reference 5.2.1.2.

REGULATORY GUIDE 1.155: Station Blackout Revision 0, August. 1988 The position of Regulatory Guide 1.155 is accepted as described in Table 1.8-4. The compliance of PVNGS to Regulatory Guide 1.155 is based on the following significant issues:

a. A minimum emergency diesel generator -(EDG) reliability target of 0.95 per demand for each EDG has been selected and a reliability program is in place to monitor and maintain this reliability level.

1. Regulatory Guide 1.155 section 1.1.1 (NUMARC 87-00 sections 3.2.3, 3.2.4) - Exception is taken to monitoring failures based on 20, 50, and 100 demands.

Since the Maintenance Rule has been accepted and utilized for system reliability monitoring, Maintenance Rule EDG Performance Criteria (PC) for Reliability has been set to meet the overall goal of EDG targeted reliability of 0.95.

2. Section 1.1.2 - Exception is taken to averaging a nuclear unit's failures based on 20, 50, and 100 demands. Per the Maintenance Rule, monitoring and tracking of failures is performed per train to avoid June 2015 1.8-180 Revision 18

PVNGS UPDATED FSAR CONFORMANCE TO NRC REGULATORY GUIDES masking a poor performing EDG. Also 20, 50, and 100 demands are not used per the Maintenance Rule PC.

3. Section 1.1.3 - Comparison on average nuclear unit EDG reliability is not performed per 20, 50, and 100 demands, but per the Maintenance Rule PC.

4. Section 1.2 (various NUMARC 87-00 App. D sections) -

Exceptions are taken to:

a. NUMARC various App. D sections - General exception is taken to counting 20, 50, and 100 demands. Per Maintenance Rule PC, overall target meets Regulatory Guide 1.155 and NUMARC 87-00 target of 0.95.

b. NUMARC 87-00 section D 2.2 - Exception is taken to counting start demands and load-run demands separately. All engine starts are counted as demands (no separating start demands and load-run demands).

c. NUMARC 87-00 sections D 2.2.2, 2.2.3, 2.3.4, 2.3.5, 2.4.2, 2.4.3 - Exception is taken to monitoring failures to 50 and 100 demands per the Maintenance Rule PC. In addition, the Corrective Action Program performs monitoring of failures and maintenance performance under these NUMARC sections.

d. NUMARC D 2.4.4 - Exception is taken to requirements for a problem diesel and June 2015 1.8-181 Revision 18

PVNGS UPDATED FSAR CONFORMANCE TO NRC REGULATORY GUIDES accelerated testing based on the Maintenance Rule and Corrective Action Program providing monitoring of failures and maintenance performance.

e. NUMARC D 2.4.5 - Exception is taken to requirements from exceeding failure trigger values. The Maintenance Rule and Corrective Action Program provide monitoring of failures and maintenance performance.

f. NUMARC D 2.4.6 - Exception is taken to requirements to retain demands and failures, corrective actions etc. for 50 and 100 demands.

Since the Maintenance Rule PC and Corrective Action Program is used to track and monitor EDG performance, 50 and 100 demands are not specifically tracked.

g. NUMARC D 2.4.7 - Exception is taken to reporting to the NRC all failures/demands per 20, 50, and 100 demands. Exception is taken to the 20, 50, and 100 demand trigger values.

b. The minimum acceptable station blackout (SBO) coping duration was determined to be 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months . Studies and analyses have been performed to demonstrate the capability of withstanding and recovering from a station blackout event of 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months duration.

c. An onsite Alternate AC (AAC) power system has been installed to provide power to plant loads that have been June 2015 1.8-182 Revision 18

PVNGS UPDATED FSAR CONFORMANCE TO NRC REGULATORY GUIDES determined to be important to the mitigation of a station blackout event. This system is manually started and can be connected to the affected nuclear unit within one hour of the onset of a SBO. The AAC power system is inspected and tested periodically to demonstrate its availability and reliability. Further discussion of the AAC power system is provided in Section 8.3.1.1.10.

d. A minimum reliability target of 0.95 per demand for the AAC power system has been selected and a reliability program is in place to monitor and maintain this reliability level.

e. Procedures and training have been established for operator actions necessary to cope with a station blackout event.

f. Quality assurance activities have been implemented as applicable for the non-safety related systems and equipment installed and dedicated for the operation of the AAC power source. Further discussion of the quality assurance program for SBO is provided in the PVNGS Operations Quality Assurance Program Description.

June 2015 1.8-183 Revision 18

PVNGS UPDATED FSAR I12-F014 CONFORMANCE TO NRC REGULATORY GUIDES section states that "A summary of 10 CFR 72.48 evaluations for activities implemented under 10 CFR 72.48 must be provided to NRC... The 10 CFR 72.48 reporting requirement (every 24 months) is identical to that for UFSAR updates such that licensees and CoC holders may provide these reports to NRC on the same schedule." (emphasis added).

10 CFR 72.48 evaluation summary reports will include a summary of all 10 CFR 72.48 evaluations that were performed for the stated time period, regardless of the implementation status for the change, test, or experiment that was evaluated.

REGULATORY GUIDE 4.1: Programs for Monitoring Radioactivity in the Environs of Nuclear Power Plants (Revision 1, April 1975)

RESPONSE

The position of Regulatory Guide 4.1 is accepted. Rcfercne:

13.4.5 and 17.-2.B.

REGULATORY GUIDE 8.2: Guide for Administrative Practices in Radiation Monitoring (Revision 0, February 2, 1973)

RESPONSE

The position of Regulatory Guide 8.2 is accepted (refer to subsections 12.1.1, 12.3.4, 11.5.1.1.3, and sections 12.5 and 13.2).

June 2015 1.8-192 Revision 18

Insert New Appendix 1B APPENDIX 1B HISTORICAL REGULATORY GUIDE INFORMATION FROM CHAPTER 1

HISTORICAL REGULATORY GUIDE 1.28: Quality Assurance Program Requirements (Design and Construction) (Revision 0, June 7, 1972)

RESPONSE

For construction phase activities and prerequisite and phase I startup testing, the position of Regulatory Guide 1.28 is accepted. Also see 17.1 and 17.2. For operations phase activities including phase II through phase IV startup testing, the regulatory position found in Regulatory Guide 1.28 will be replaced by the regulatory position found in Regulatory Guide 1.33 as modified and interpreted by APS in Section 1.8. Additional

References:

4.2.5, 5.4.7.1, 6.3.1.3, 9.1.4.6, and 18.II.F.2-3.

HISTORICAL REGULATORY GUIDE 1.30: Quality Assurance Requirements for the Installation, Inspection, and Testing of Instrumentation and Electric Equipment (Revision 0, August 11, 1972)

RESPONSE

The requirements of the referenced standard (ANSI N45.2.4-1972) will be applied to the Bechtel quality program for construction of safety-related items as interpreted in the regulatory position as modified and interpreted below:

A. Section 2.1, Planning. The required planning is frequently performed on a generic basis for application to many installations on one or more projects. This results in standard procedures or plans for installation and inspection and testing which meet the requirements of the standard.

Individual plans for each item or system are not normally prepared unless the work operations are unique; however, standard procedures or plans are reviewed for applicability in each case. Installation plans or procedures are also limited in scope to those actions or activities which are essential to maintain or achieve required quality.

B. Section 3, Preconstruction Verification. The requirements of this section are applied to items which are received and stored prior to installation.

They are combined with receiving inspection activities in accordance with ANSI N45.2.2 requirements for items which are installed immediately after receiving inspection.

For operations phase activities that are comparable to activities occurring during the construction phase, the following interpretations apply to the position of Regulatory Guide 1.30:

A. Section 5.2:

The various tests are performed "as appropriate" as determined by PVNGS Engineering Department based upon the significance of the change or modification.

B. Section 6.2.1:

PVNGS utilizes a computer information management system to maintain plant equipment calibration status including the date of calibration and identity of the person that performed the calibration. The computer information management system provides a more reliable and accessible method of documenting plant equipment calibration status than the use of tags or labels affixed to the equipment.

C. Section 6.2.2:

The requirement that systems tests be made to verify that all parts of a system properly coordinate with each other is interpreted as not requiring that an entire system be retested after modification of only a portion of that system. The testing requirements of the Technical Specifications are met for inoperable equipment.

Reference 3.11.2, 7.1.2.6, 7.1.2.17, 8.3.1.2.2.7, 8.3.2.2.1.6, 14.2.7, 17.1, 17.2, and Table 18.II.F.2-3.

HISTORICAL REGULATORY GUIDE 1.33: Quality Assurance Program Requirements (Operation) (Revision 2, February 1978)

RESPONSE

The position of Regulatory Guide 1.33 is accepted with the following exceptions to Regulatory Positions C.2 and C.4:

For Regulatory Position C.2, the APS commitment refers to regulatory guides, and revisions thereof, specifically' identified in this FSAR.

For Regulatory Position C.4, the specific audits at C.4.a, C.4.b, and C.4.c shall be performed at a frequency of at least once per 24 months. In addition, a grace period of 90 days beyond the specified frequency shall be permitted for completion of internal audits. When the grace period is utilized, subsequent scheduling for the audit shall be based upon the original due date. This grace period shall not be applied to those audits that have a frequency specifically defined by regulation.

In addition, the following clarification is made in APS' position regarding Regulatory Guide 1.33:

Compliance to ANSI standards referenced throughout ANSI N18.7-1976/ANS-3.2 are addressed separately in APS' response to conformance with the regulatory guides listed in section C.2 of Regulatory Guide 1.33.

The following exceptions are taken to ANSI N18.7:

A. Section 3.4.2 The APS commitment on the qualification of personnel who are performing preoperational and startup test functions is found in paragraph 14.2.2.12.

B. Section 5.2.13.1 When purchasing commercial-grade calibration services from certain accredited calibration laboratories, the procurement documents are not required to impose a quality assurance program consistent with ANSI N45.2-1971. Alternative requirements described in UFSAR Section 1.8 for Regulatory Guide 1.123 may be implemented in lieu of imposing a quality assurance program consistent with ANSI N45.2-1971.

In addition, the following interpretations of ANSI N18.7 are made:

A. Section 5.2.2

The requirements of this section are accepted with the following interpretations:

Temporary changes to procedures may be made provided the change is approved by two members of the plant management staff, at least one of whom holds a senior reactor operator license on the unit affected.

Procedural steps traditionally identified as immediate actions are incorporated into standard post-trip actions. Following a manual or automatic reactor trip, standard post-trip actions will be performed. The reactor operators are expected to know the standard post-trip actions and begin to take action.

The control room supervisor shall perform the standard post-trip actions in the order written and go over each step with the control room staff.

B. Section 5.2.13.1 The requirement that changes made to procurement documents be subject to the same degree of control as was used in the preparation of the original documents is applied consistent with the requirements of ANSI N45.2.11, Paragraph 7.2. Minor changes to documents, such as inconsequential editorial corrections or changes to commercial terms and conditions, may not require that the revised document receive the same review and approval as the original documents.

C. Section 5.2.17 The requirements of this section are accepted with the following interpretation:

The requirement that deviations, their cause, and any corrective action completed or planned shall be documented shall apply to significant deviations.

Other identified deviations will be documented and corrected. This interpretation is consistent with Appendix B to 10CFR50, Criterion XVI, Corrective Action.

D. Section 5.2.19.1

Preoperational testing (phase I startup testing) addressed in ANSI N18.7, Paragraph 5.2.19.1, will be conducted in accordance with Regulatory Guide 1.68, Revision 0.

E. Section 5.3.9.1 The requirements of this section are accepted with the following interpretation:

Actions identified as immediate operator actions have-been standardized in the form of safety function status checks. Safety functions are maintained for all transients when the emergency procedure is implemented. This ensures proper operator response independent of event diagnosis. This approach is consistent with CEN-152, CE Emergency Procedure Guidelines.

Actions identified as subsequent operator action are addressed as a recovery procedure, implemented after event diagnosis. This approach is consistent with CEN-152, CE Emergency Procedure Guidelines.

The specific procedure format and content have been identified in the Emergency Procedure Generation Package and submitted to the NRC for review. This is consistent with NUREG-0899.

F. Section 5.2.15 The requirements of this section are accepted with the following interpretation(s):

The requirement for periodic review of routine plant procedures no less frequently than every two years may be exceeded for routine plant procedures which are used infrequently, when alternative means are provided to ensure review of these procedures prior to use.

Periodic review of plant procedures no less frequently than every two years is not required for routine, frequently-used plant procedures. Periodic audits to satisfy regulatory requirements and commitments include an assessment of a representative sample of related procedures to validate that the procedures are acceptable for use and that the procedure review and revision process is being effectively implemented.

The exceptions to periodic review requirements stated above do not apply to non-routine procedures (such as abnormal operating procedures, emergency operating procedures, alarm response procedures, procedures which implement the Emergency Plan, or procedures which implement the Security Plan). The periodic review requirement for these procedures may be satisfied by the use or review of the procedure during plant operation, training exercise, drill, or by other such review activity which validates acceptability of the procedure, provided the procedure use or review activity is documented.

G. Section 5.2.7 The requirements of this section are accepted with the following interpretations:

Activities occurring during the operational phase that are comparable in nature and extent to related activities occurring during initial plant design and construction' shall be interpreted to mean those activities of such a scale and type that the following conditions are met:

A. The work is to be performed by an outside contractor or owner's service organization not part of the plant organization.

B. The system or area of the plant affected by the work is released to the contractor or service organization during the activity, and, except for radiological protection purposes and other specified controls, effectively ceases to be part of an operating nuclear power plant.

C. The contractor or service organization has been directed in advance of the work that conformance to Regulatory Guide 1.33, ANSI N18.7, and Applicable standards referenced in ANSI N18.7 will be required, consistent with the PVNGS UFSAR position on these standards.

The implementation of the positions of Regulatory Guide 1.33 are described in chapters 13 and 17 and the Technical Specifications.

HISTORICAL REGULATORY GUIDE 1.37: Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants (Revision 0, March 16, 1973)

RESPONSE

The requirements of the referenced standard (ANSI N45.2.1-1973) as modified in the regulatory position are applied to cleaning activities specified or applied by Bechtel to safety-related items as modified and interpreted below:

A. Section 2.1, Planning. The required planning is frequently performed on a generic basis for application to many installations on one or more projects. This results in standard procedures or plans for installation and inspection and testing which meet the requirements of the standard. Individual plans for each item or system are not normally prepared unless the work operations are unique; however, standard procedures or plans are reviewed for applicability in each case. Installation plans or procedures are also limited in scope to those actions or activities which are essential to maintain or achieve required quality.

This is consistent with Section II, Paragraphs 2 and 3, of ANSI N45.2- 1971 which provide for examination, measurement, or testing to assure quality or indirect control by monitoring of processing methods. However, final cleaning or flushing activities are performed in accordance with procedures specific to the system.

Also see 5.2.3.4.1.2.1. Additional

References:

4.2.5, 4.5.1.5, 5.1.5, 5.2.3, 5.4.2.4, 5.3.3.5, 5.4.7, 6.1.1.1.3.2, 6.3.1.4, 6.5.2.8, (RA) 7.12.5, 9.3.4, 10.3.6.2, 14.2.7, 17.1, and 17.2.

For operations phase activities that are comparable to activities occurring during the construction phase, the referenced standard (ANSI N45.2.1-1973) as modified by Regulatory Guide 1.37 is accepted as modified below.

A. Section 2.1, Planning. The required planning is frequently performed on a generic basis for application to many systems and component

installations. This results in standard procedures for cleaning, inspection, and testing which meet the requirements of the standard.

B. Individual plans for each item or system are not normally prepared unless the work operations are unique; however, standard procedures are reviewed for applicability in each case. Cleaning procedures are limited in scope to those actions or activities which are essential to maintain or achieve required quality.

This is consistent with Section 5.2.17, Paragraph 5, of ANSI N18.7-1976 which provides for examination, measurement, or testing to assure quality or indirect control by monitoring of processing methods.

HISTORICAL REGULATORY GUIDE 1.38: Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Water-Cooled Nuclear Power Plants (Revision 0, March 16, 1973)

RESPONSE

The requirements of the referenced standard (ANSI N45.2.2-1972) as modified and interpreted in the regulatory position are applied to the Bechtel quality program for construction of safety-related items, except as modified and interpreted below:

A. Section 2.4, Personnel Qualification. Personnel performing offsite audits shall be qualified to ANSI N45.2.23. Personnel performing offsite material inspection shall be qualified to ANSI N45.2.6.

Personnel performing offsite monitoring activities shall be qualified to ANSI N45.2.23 or ANSI N45.2.6.

B. Section 2.7, Classification of Items. The four-level classification system may not be used explicitly. However, the specific requirements for each classification as specified in the standard are applied to the items suggested in each classification and for similar items.

C. Section 3.9, Marking. Identification of items, after the outside of the container has been removed, is accomplished in accordance with ANSI N18.7, Section 5.2.13.3.

D. Section 6.2, Storage Areas. Paragraph 6.2.1 requires control and limited access to storage areas.

In lieu of and to amplify this paragraph, the following is applied:

"Access to storage areas for levels A, B, and C is controlled by the individual(s) responsible for material storage." Level D items are stored in a site area which has access control consistent with zone IV of ANSI N45.2.3-1973. While the areas may be posted to limit access, other positive controls (other than that for the overall site area) or guards may not be provided.

E. Sections 3.9 and 5.6, and Section A3.9 of Appendix A, Marking. These ANSI N45.2.2 sections control direct marking of austenitic stainless steel and nickel based alloys. Marking is in compliance with the requirements of these sections except that markings may be directly applied using inks controlled so as not to contain more than 200 ppm of inorganic halogens.

Reference 4.2.5, 5.1.4, 5.2.3.4.1.2.2, 6.3.1.3, 9.1.4.6, 17.1A.2, 17.1B, 17.2B, and Table 18.II.F.2-3.

HISTORICAL REGULATORY GUIDE 1.39: Housekeeping Requirements for Water-Cooled Nuclear Power Plants (Revision 2, September 1977)

[Historical]

RESPONSE

The requirements of the referenced standard (ANSI N45.2.3-1973) are applied to the Bechtel quality program for construction of safety-related items except as modified and interpreted below:

A. Section 2.1, Planning. The required planning is frequently performed on a generic basis for application to many installations on one or more projects. This results in standard procedures or plans for installation and inspection and testing which meet the requirements of the standard. Individual plans for each item or system are not normally prepared unless the work operations are unique; however, standard procedures or plans are reviewed for applicability in each case. Installation plans or procedures are also

limited in scope to those actions or activities which are essential to maintain or achieve required quality.

B. Alternative equivalent zone designations and requirements may be utilized to cover those situations not included in the subject standard. For example, situations in which shoe covers and/or coveralls are required but material accountability is not.

For operations phase activities that are comparable to activities occurring during the construction phase, the position of Regulatory Guide 1.39 is accepted with the following exception:

Alternative equivalent zone designations and requirements may be utilized to cover those situations not included in the subject standard. For example, situations in which shoe covers and/or coveralls are required but material account-ability is not.

Reference 5.3.3.5, 9A.33, 12.5.3.4, 17.1B, 17.1A.2, and 17.2B.

HISTORICAL REGULATORY GUIDE 1.58: Qualification of Nuclear Power Plant Inspection, Examination and Testing Personnel (Revision 1, September 1980) [Historical]

RESPONSE

The position of Regulatory Guide 1.58 is accepted with the following exceptions:

A. Position C.l The qualification of personnel who approve preoperational and startup test procedures and test results, and those who direct or supervise the conduct of individual preoperational and startup tests is discussed in paragraph 14.2.2.12. The qualification of other personnel discussed in Position C.1 follows the guidelines of Regulatory Guide 1.8 as discussed in sections 13.1 and 13.2.

B. Position C.6 The specified education and experience recommendation of ANSI N45.2.6-1978 for various levels of inspectors shall not be treated as absolute when other factors

provide reasonable assurance that a person can competently perform a particular task. These factors will be documented, with justification by management (on an individual basis), demonstrating that the individual does have equivalent competence to that which would be gained from having the required education and experience.

In addition, the following exceptions are taken to the referenced standard ANSI N45.2.6-1978 are made:

A. The first sentence of Paragraph 3.4 states that a Level III qualified person shall have all the capabilities of a Level II qualified person for the inspection, examination or test category or class in question. APS will qualify Level III persons without the actual hands on experience and capability to perform specific inspections, examinations or tests required of a Level I or II qualified person, and utilize these persons for administrative and supervisory functions including certifying persons at the same or lower level.

B. Paragraph 3.3 states that a Level II qualified person shall have demonstrated experience in certifying lower level qualified persons. APS does not use Level II qualified persons to certify lower level qualified persons, and does not require Level II qualified persons to demonstrate this capability.

The following interpretation is also made to Regulatory Guide 1.58:

A. Position C.1 For qualification of personnel, (1) who perform or approve operational test procedures and test results, and (2) who direct or supervise the conduct of individual operational tests, the guidelines contained in Regulatory Guide 1.8, Revision 1-R, "Personnel Selection and Training" with the criteria for selection and training contained in ANSI/ANS 3.1-1978, substituted for ANSI-N18.1-1971, will be followed.

See also conformance to Regulatory Guide 1.8:

Personnel Selection and Training (Revision 1-R, May 1977).

Reference sections 17.1A.2, 17.1B, 17.2B, and Table 18.II.F.2-3.

HISTORICAL REGULATORY GUIDE 1.64: Quality Assurance Requirements for the Design of Nuclear Power Plants (Revision 0, October 1973) [Historical]

RESPONSE

Regulatory Guide 1.64 endorses a superseded draft issue of ANSI N45.2.11. For C-E's program, refer to Section 17.1C.

The Bechtel program complies with ANSI N45.2.11-1974 as interpreted herein.

A. Section 3.1.

This section implies that all necessary design input (as listed in section 3.2) should be available prior to the start of a design activity. In practice, certain design activities are initiated before the firm input requirements are available. (For example, foundation designs prepared based on preliminary information or equipment sizes and mounting and embedded conduit run based on preliminary estimates of circuit requirements). The design phase QA program is structured to assure that all necessary design input is available before completion of final design of the work affected by the input and that final design input is available for use in verification of the final design.

B. Section 4.1, Design Process General Paragraph 3 implies traceability back from final design to the source of design input. In practice, a literal interpretation of this is not always possible. For example, final design drawings do not identify the related calculations. This paragraph is interpreted to mean that it shall be possible to relate the criteria used and analyses performed to the final design documents and that record files will permit location of analyses supporting specific design output documents.

Additional references: 3.8.1.2.3, 4.2.5, 5.1.4, 5.4.7.1, 6.3.1.3, 9.1.4.6, 9.3.4.6, 17, and Table 18.II.F.2-3.

HISTORICAL

REGULATORY GUIDE 1.64: Quality Assurance Requirements for the Design of Nuclear Power Plants (Revision 2, June 1976)

RESPONSE

For operations phase activities that are comparable to activities occurring during the construction phase, the position of Regulatory Guide 1.64 is accepted with the following exception to Position C.2:

Supervisory personnel may perform design verification under exceptional circumstances as documented and approved by the next level of supervision, if:

1. The justification (for design verification by a designer's immediate supervisor) is individually documented and approved in advance, and

2. Quality assurance audits cover frequency and effectiveness of use of supervisors as design verifiers to guard against abuse.

APS interprets ANSI N45.2.11-1974, Sections 3.1 and 4.1, as follows:

A. Section 3.1 This section implies that all necessary design input (as listed in section 3.2) should be available prior to the start of a design activity. In practice, certain design activities are initiated before the firm input requirements are available. (For example, foundation designs prepared based on preliminary information or equipment sizes and mounting and embedded conduit run based on preliminary estimates of circuit requirements).

The design phase QA program is structured to assure that all necessary design input is available before completion of final design of the work affected by the input and that final design input is available for use in verification of the final design.

B. Section 4.1, Design Process General Paragraph 3 implies traceability back from final design to the source of design input. In practice, a literal interpretation of this is not always possible. For example, final design drawings do not identify the related

calculations. This paragraph is interpreted to mean that it shall be possible to relate the criteria used and analyses performed to the final design documents and that record files will permit location of analyses supporting specific design output documents.

References:

3.8.1.2.3, 4.2.5, 5.1.4, 5.4.7.1, 6.3.1.3, 9.1.4.6, 9.3.4.6, 17, and Table 18.II.F.2-3.

HISTORICAL REGULATORY GUIDE 1.74: Quality Assurance Terms and Definitions (Revision 0, February 1974)

RESPONSE

The position of Regulatory Guide 1.74 is accepted (refer to section 17.2 and 17.16). Additional references: 4.2.5, 5.1.4, 5.4.7.1, 9.1.4.6, 17.1A, 17.1B, and Table 18.II.F.2-3.

HISTORICAL REGULATORY GUIDE 1.88: Collection, Storage and Maintenance of Nuclear Power Plant Quality Assurance Records (Revision 2, October 1976) [Historical]

RESPONSE

The position of Regulatory Guide 1.88 is accepted with the following exceptions to Section 5.6 of ANSI N45.2.9-1974:

A. Doors, structure and frames, and hardware shall be designed to comply with the requirements of a minimum 2-hour fire rating. (Section 4.4.1 (c) of Supplement 17S-1 of NQA-1 requires 2-hour rated doors and dampers, and the latest version of Regulatory Guide 1.28 provides no additional guidance in this area.)

B. Vinyl tile is used on the floor in lieu of a surface sealant.

C. A roof drainage line penetrating the structure has been plugged to avoid any potential flooding due to rain. There is a floor drain with a vent line located in the center of the room. The vent line to the roof is exclusively for the drain and it does not carry

liquids, therefore it does not present any potential flooding problems to the storage room.

D. PVNGS also provides the following clarification with regard to application of ANSI N45.2.9-1974:

PVNGS adheres to the guidance of the Standard for classification and retention periods of quality assurance records, unless other more stringent requirements apply or a graded approach as defined in Section 17.2 has been applied to determine the relative value of the record or group of records. When the graded approach is utilized, the extent to which the record maintenance and storage requirements of the Standard apply may be modified.

For quality assurance records to which the graded approach is not applied, the records shall be maintained and stored consistent with applicable regulatory requirements and the pertinent requirements of R.G. 1.88 and ANSI N45.2.9-1974, with exceptions as noted in A through C above.

Reference:

17.1, 17.2, and Table 18.II.F.2-3.

HISTORICAL REGULATORY GUIDE 1.116: Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems (Revision O-R, May 1977) [Historical]

RESPONSE

For operations phase activities, the position of Regulatory Guide 1.116 is accepted with the following interpretations of ANSI N45.2.8:

A. Section 2.3 Test reports attached to or referenced in data sheets may meet the evaluation requirements of the last paragraph.

B. Sections 2.2 and 2.3; 5.2 and 5.4 For application of the provisions of these sections to preoperational and startup testing, the APS position on the applicable revision of Regulatory Guide 1.68, "Preoperational and Initial Startup Test Programs for Water-Cooled Power Reactors," shall take precedence where there is a conflict or difference.

C. Item 2.9e(6)

This item shall be interpreted to mean that any work performed without an approved design change shall not be considered complete and acceptable for its intended use until the change is approved, and that the intent of this item will be satisfied provided that such work is performed only with approved procedures and that the activities and the results are documented.

Evidence of design change approval shall be required prior to placing the affected item in service.

D. Section 5 For the purposes of functional tests addressed by this standard, APS defines completed systems as any system, or portion or component thereof, on which construction is sufficiently complete to allow the required testing, and on which further or adjacent construction will not render the results of such testing invalid or indeterminate.

E. Item 5.l.g Traceability as used in this item is considered to be the same as discussed in Section 5.2.13.3 of ANSI N18.7.

Reference sections 14.2.7, 17.1A.2, 17.1B, and 17.2B.

HISTORICAL REGULATORY GUIDE 1.123: Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants (Revision 1, July 1977) [Historical]

RESPONSE

For operations phase activities, the position of Regulatory Guide 1.123 is accepted with the following modifications to ANSI N45.2.13-1976:

A. Section 7.5, Personnel Qualifications. Personnel performing offsite audits shall be qualified to ANSI N45.2.23. Personnel performing offsite material inspection shall be qualified to ANSI N45.2.6.

Personnel performing offsite monitoring activities shall be qualified to ANSI N45.2.23 or ANSI N45.2.6.

B. Section 3.2.3

The requirements of this section are accepted with the following exception:

When purchasing commercial grade calibration services from calibration laboratories accredited by a nationally recognized accrediting body, the procurement documents are not required to impose a quality assurance program consistent with ANSI N45.2-1971. Nationally-recognized accrediting bodies include the National Voluntary Laboratory Accreditation Program (NVLAP) administered by the National Institute of Standards and Technology (NIST) and other accrediting bodies recognized by NVLAP via a Mutual Recognition Arrangement (MRA). In such cases, accreditation may be accepted in lieu of the Purchaser imposing a QA Program consistent with ANSI N45.2-1971, provided all the following are met:

1. The accreditation is to ANSI/ISO/IEC 17025.

2. The accrediting body is either NVLAP or the American Association for Laboratory Accreditation (A2LA) based upon A2LA continued NVLAP recognition through the International Laboratory Accreditation Cooperation (ILAC) Mutual Recognition Arrangement.

3. The published scope of accreditation for the calibration laboratory covers the needed measurement parameters, ranges, and uncertainties.

4. The purchase documents impose additional technical and administrative requirements, as necessary, to satisfy APS QA Program and technical requirements. The purchase documents shall specifically require that the calibration certificate or report will include identification of the equipment and/or standards used.

5. The purchase documents require reporting as-found calibration data when calibrated items are found to be out-of-tolerance.

HISTORICAL REGULATORY GUIDE 1.144: Auditing of Quality Assurance Program for Nuclear Power Plants (Revision 1, September 1980) [Historical]

RESPONSE

The requirements of the referenced standard (ANSI N45.2.12-1977) as modified and interpreted in the position of Regulatory Guide 1.144 are applied to the APS quality

assurance program for operations phase activities, with the following exceptions:

A. Section 4.3.1 requires that a brief preaudit conference be conducted with cognizant organization management. A formal preaudit conference may not be required for some routine internal audits where informal preaudit communication is determined to be adequate. The manager of the auditing organization will monitor the performance of audits, through review of audit reports, to ensure that informal preaudit communication is utilized only in cases where such informal communication is adequate.

B. Section 4.5.1 states that any "adverse findings" shall be reviewed and investigated to determine and schedule appropriate corrective action including action to prevent recurrence. Consistent with the PVNGS position established in section 1.8 for Regulatory Guide 1.33, PVNGS requires determination of root cause and actions to prevent recurrence for significant conditions adverse to quality that are identified during audits. This interpretation is consistent with Appendix B to 10CFR50, Criterion XVI, Corrective Action.

C. A grace period of 90 days beyond the specified frequency shall be permitted for completion of supplier annual evaluations and supplier audits. When the grace period is utilized, subsequent scheduling for the evaluation or audit shall be based upon the original due date. This grace period shall not be applied to evaluations or audits that have a frequency specifically defined by regulation.

Reference:

17.1, 17.2, and Table 18.II.F.2-3.

D. Regulatory Guide 1.144, Section C.3.b(2)

The Requirements of this section are accepted with the following interpretation.

When purchasing commercial grade calibration services from calibration laboratories accredited by a nationally-recognized accrediting body, the accreditation process and accrediting body may be credited with carrying out a portion of the Purchaser's duties of verifying acceptability and

effective implementation of the calibration service supplier's quality assurance program. Nationally-recognized accrediting bodies include the National Voluntary Laboratory Accreditation Program (NVLAP) administered by the National Institute of Standards and Technology (NIST) and other accrediting bodies recognized by NVLAP via a Mutual Recognition Arrangement (MRA).

In lieu of performing an audit, accepting an audit by another licensee, or performing a commercial-grade supplier survey, a documented review of the supplier's accreditation shall be performed by the Purchaser.

This review shall include, at a minimum, all of the following:

1. The accreditation is to ANSI/ISO/IEC 17025.

2. The accrediting body is either NVLAP or the American Association for Laboratory Accreditation (A2LA) based upon A2LA continued NVLAP recognition through the International Laboratory Accreditation Cooperation (ILAC) Mutual Recognition Arrangement.

3. The published scope of accreditation for the calibration laboratory covers the needed measurement parameters, ranges, and uncertainties.

HISTORICAL REGULATORY GUIDE 1.146: Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants (Revision 0, August 1980) [Historical]

RESPONSE

The requirements of the referenced standard (ANSI N45.2.23-1978) as modified and interpreted in the position of Regulatory Guide 1.146 are applied to the quality assurance program with the following modifications:

A. At paragraph 2.2.1 of ANSI N45.2.23: Orientation of auditors is provided to produce a working knowledge and understanding of ANSI N18.7, ANSI N45.2.12, this standard, and the auditing organization's procedures for implementing audits and reporting results.

B. At paragraph 2.3.4 of ANSI N45.2.23: Prospective lead auditors shall demonstrate their ability to effectively implement the audit process and lead an

audit team. They shall have participated in at least one audit within the year preceding the individual's effective date of qualification. Upon successful demonstration of the ability to effectively lead audits, licensee management may designate a prospective lead auditor as a "lead auditor".

Reference 17.1 and 17.2.

PVNGS UPDATED FSAR ONSITE POWER SYSTEMS southwest penetration areas contain cable for separation groups A and C, at two levels each located in a separate area.

Raceway separation criteria, as described in this section, apply in routing cable through the penetration areas. Non-safety-related penetration assemblies are located in each of the four areas.

8.3.1.4.2 Administrative Responsibilities and Controls for Assuring Separation Criteria The cable and raceway channel identification described in paragraph 8.3.1.3 facilitates and ensures the maintenance of separation in the routing of cables and the connection of control boards and panels. At the time of the cable routing assignment during design, those responsible for cable and raceway scheduling check to ensure that the separation group designation in the cable number is compatible with a single-line diagram load group designation. Extensive use of computer facilities assists in ensuring separation. Each cable and raceway is identified in the computer program, and the identification includes the applicable separation group designation. Auxiliary programs are made available inspection specifically to ensure that cables of a parti ar separation group are routed through the appropriate aceways. The routing is also confirmed by quality control personnel during installation to be consistent with the design document. Color identification of equipment and cabling (refer to paragraph 8.3.1.3) assists field personnel in this effort.

June 2015 8.3-126 Revision 18

112-F014I Table 9B.3-1 COMPARISON OF PALO VERDE NUCLEAR GENERATING STATION TO APPENDIX A OF NRC BRANCH TECHNICAL POSITION APCSB 9.5-1 (Sheet 13 of 69)

C. QUALITY ASSURANCE PROGRAM APPLICATION DOCKETED BUT CONSTRUCTION PLANTS UNDER CONSTRUCTION AND PERMIT NOT RECEIVED AS OF 7/1/76 OPERATING PLANTS Quality assurance (QA) programs of Same ine hs dex~l n H impjpmentA fi prnt OA applicants and contractors should be prngrsm As risq-ihP in *hp PVN*q Qr n- c11a14+/-y developed and implemented to assure that Ar~n! Plan, Appeni E-1 The fir pr n n QA the requirements for design, procurement, Prng- - it-h mA-Irrn grO - n in Pstionn installation, and testing andA -1; Append x A Rpt, - nn (7 "lal- I 111ilan-administrative controls for the fire Implementation of the quality POram "Fn ' prot-eti f

re. 'r'rs to prntrt' protection program for safety-related areas assurance program for fire saft--la ... *a i-priz * . , v... -, 3 rcnip.n..*- are as defined in this Branch Position are protection is consistent with withi tha spe tfhe fio prnotr.ti QA prograr satisfied. The program should be under the management control of the QA organization. NRC Branch Technical Position The QA program criteria that applies to the APCSB 9.5-1, Appendix A, fire protection program should include the following: Section C, "Quality Assurance

1. Design Control and Procurement Document Program". Fire protection n n An PrQrment nnrumpn- Control Control features required to protect Measures should be established to assure safety-related structures, l t the McNG np Qaf-, A,-A- P . C) that all design-related guidelines of systems, and components are AppOndix F-1 N' the Branch Technical Position are within the scope of the PVNGS included in design and procurement documents and that deviations therefrom Quality Assurance Program for C) 0 are controlled, the operational phase. APS

2. Instructions, Procedures, and Drawings implements the fire protection 2 Tn* ,*urtnn oa,

n,-n,.

Instructions, tests, administrative OA program through approved Refp fn th- pu-h gCp--nti-o C li-,, A ...... Pln, ZI controls, fire drills, and training that procedures, instructions, and Adpipn F-1 L.

govern the fire protection program drawings in accordance with 0 should be prescribed by documented instructions, procedures, or drawings the requirements of the and should be accomplished in accordance PVNGS Operations Quality with these documents. Assurance Program 0

3. Control of Purchased Material, Description. I Cnntrol of P,,irnh*s M*t-rijl] cnint F,-n andi seruiri ,

Equipment, and Services Measures should be established to assure Refer fa t-he RUNcG cpratinnr rqio q,airi-y7 PlAn that purchased material, equipment, and Appandix.*.-1 services conform to the procurement documents.

Table 9B.3-1 COMPARISON OF PALO VERDE NUCLEAR GENERATING STATION TO APPENDIX A OF q

C1 NRC BRANCH TECHNICAL POSITION APCSB 9.5-1 (Sheet 14 of 69)

C. QUALITY ASSURANCE PROGRAM (D

APPLICATION DOCKETED BUT CONSTRUCTION PLANTS UNDER CONSTRUCTION AND N) PERMIT NOT RECEIVED AS OF 7/1/76 OPERATING PLANTS C3

4. Inspection 4 Tnqption A program for independent inspection of Rpfn t'n lhp OXphTO ClPnratinng Qll-*'r *,lr~ . Ol activities affecting fire protection Appendix F-I.

should be established and executed by, or for, the organization performing the activity to verify conformance with documented installation drawings and test procedures for accomplishing the activities.

5. Test and Test Control S TPt ýnH Tpst C'nntrnl A test program should be established and Refer 1-a t p 21-H OxPcAg-in= Qii -V1 Aq sn PiAn, implemented to assure that testing is Appendix L-1 performed and verified by inspection and C-audit to demonstrate conformance with *0 wo design and system readiness CD CD requirements. The tests should be t3 performed in accordance with written I

test procedures; test results should be C-properly evaluated and acted upon. a o1 0X '-9

6. Inspection, Test, and Operation Status r Tn-.rtinr TP, ,rQc flnpr.pt-n S-t,,Cs a

Measures should be established to Refer 1-n he p0uwc fpýr~-nnq Qll-Jv L,'-q*"rprP PiAp provide for the identification of items Appendix F-1 H that have satisfactorily passed required H tests and inspections.

LA 0 0 ci ol HD H o) 0 ol (D

CD 0 -I o- cyD 0

Table 9B.3-l COMPARISON OF PALO VERDE NUCLEAR GENERATING STATION TO APPENDIX A OF NRC BRANCH TECHNICAL POSITION APCSB 9.5-1 (Sheet 15 of 69)

C. QUALITY ASSURANCE PROGRAM APPLICATION DOCKETED BUT CONSTRUCTION PLANTS UNDER CONSTRUCTION AND PVNGS POSITION AND BASIS FOR NONCOMPLIANCE ITEMS N) PERMIT NOT RECEIVED AS OF 7/1/76 OPERATING PLANTS CD CA) 7. Nonconforming Items 7 nrnfnnni ng T-fi Measures should be established to Pnfr tn tbhn Poiwcq flpnrinnq Qialitit Ag-1uirnrp PlAn.

control items that do not conform to Appendjix* -1 specified requirements to prevent inadvertent use of installation.

8. Corrective Action R Cnrrcti~vr Lrtinr Measures should be established to Rfer to the PNgCv Cpnrfiinmn QOnlilt-x Aq,,rfnir Pl~n assure that conditions adverse to fire Appendim FE-t protection, such as failures, malfunctions, deficiencies, deviations, ho defective components uncontrolled ci combustible material and non- z conformances are promptly identified, 0 CD reported, and corrected.

0 1k) 9. Records P-S ds ho 0

Records should be prepared and Pefr tn 1t-h poxicg rnr.n. r 0fit'g lhn- ,frs-nn PlAn, HA -2 I> maintained to furnish evidence that the Appendix E-1 n0 LII criteria enumerated above are being met 0 for activities affecting the fire protection program. x ho 0 CD ho >1

10. Audits 1n A Audits should be conducted and Pnpfr t- 1-Rnn m GSCpc

%nfin 01nnpl ,ityAslinn Plan z documented to verify compliance with v Epp*n V-i the fire protection program including 0 design and procurement documents, instructions, procedures and drawings, and inspection and test activities.

0 0

(D ho oj L-4 0

0 z H.. o

PVNGS UPDATED FSAR 112-FO14 I

CHAPTER 13 CONDUCT OF OPERATIONS CONTENTS Page 13.1 ORGANIZATIONAL STRUCTURE OF APPLICANT 13.1-1 13.1.1 MANAGEMENT AND TECHNICAL SUPPORT ORGANIZATION 13.1-1 13.1.1.1 Design and Operating Responsibilities 13.1-1 13.1.1.2 Licesec rganizational-8 Arrangemlent 13.1-21 13.1.1.3 13.1.2 OPERATING ORGANIZATION 13.1-4--7 13.1.2.1 Onsite Station Organization 13.1-17 Station Personne! Responsibilities and Authorities 13.1-12 13.1.2.3 13.1-28 13.1.3 13.12 . QUALIFICATIONS OF NUCLEAR PLANT PERSONNEL 13.1-29 13.1.3.1 Qualfictio Requirements 13.1-29 13.1.3.2 13.1-32 13.2 TRAINING PROGRAM 13.2-1 13.2.2.1 TECHNICAL TRAINING PROGRAMS 13.2-1 13.2.2 GENERAL TRAINING DESCRIPTION 13.2-2 13 .2 .2. 1 Types of Training 13.2-2 13 .2.2 .2 Qualification of Personnel 13.2-2 June 2015 13-i Revision 18

12-F014 PVNGS UPDATED FSAR CONTENTS (cont)

Page 13.2.2.3 General Employee Training 13.2-2 13.2.3 FIRE PROTECTION TRAINING 13.2-3 13.2.3.1 General Employee Fire Protection Training 13.2-3 13.2.3.2 Fire Department Training 13.2-3 13.2.3.3 Security Department Fire Protection Training 13.2-6 13.3 EMERGENCY PLANNING 13.3-1 13.3..1 PRELIMINARY PLANNING (PSAR) 13.3-1 13.3.2 EMERGENCY PLAN (FSAR) 13.3-1 13.4 REVIEW AND AUDIT 13.4-1 5q'NAPVF TF I-4NT\T(7\T. P7T.\TTF.W 13, 4.9 13. 4-?

flN~TTF7, P1UTF.W l q_4-3 1_%__4 A INDE.P.JENDENT PE\TIZIE INDERPENDEPNT SAEETY RF.\7TEldaI 1z3 4 ýL I1- 4-j ATTflT *PROfAM 13.5 PLANT PROGRAMS AND PROCEDURES 13.5-1 pRPpABATTnN DE PpfCPDTTBFE nPFP7ATTT'\Tr- aI'J MaTT\Tr1'FNrAT'NlF. PD1?nr7F)TMrTP 13,5-6 13.6 Conntrrc1 Rnným Opp~ra:Linr Prrrgcp1irpq INDhUr IrALSErCirIT 13. 5-1Q

13. 6 INDUSTRIAL SECURITY 13.6-1 June 2013 13-ii Revision 17

PVNGS UPDATED FSAR E~I~1i~

CONTENTS (cont)

Page 13.6.1 PRELIMINARY PLANNING (PSAR) 13. 6-1 13.6.2 SECURITY PLAN (FSAR) 13. 6-1 13.7 TECHNICAL REQUIREMENTS MANUAL (TRM) 13. 7-1 13.7.1 TRM CONTENT 13.7-1 13.7.1.1 Component Lists 13.7-1 13.7.2 TRM CHANGE CONTROL 13. 7-2 APPENDIX 13A RESPONSES TO NRC REQUESTS FOR INFORMATION APPENDIX 13B PROJECT DESIGN, CONSTRUCTION AND PREOPERATIONAL ACTIVITIES (HISTORICAL)

June 2013 13-iii Revision 17

F1L2--F-O1-4-]

PVNGS UPDATED FSAR I FIGURES 13.1-1 Deleted 13 .1-2 Deleted

13. 1-3 Deleted

13. 1-4 Deleted

13. 1-5 Deleted 13.1-6 Deleted June 2013 13-iv Revision 17

F12--F-0-14 PVNGS UPDATED FSAR

13. CONDUCT OF OPERATIONS 13.1 ORGANIZATIONAL STRUCTURE OF APPLICANT 13.1.1 MANAGEMENT AND TECHNICAL SUPPORT ORGANIZATION Arizona Public Service Company (APS), one of the owners of the Palo Verde Nuclear Generating Station (PVNGS), has the overall responsibility for management, operation and oversight of the facility. APS provides a staff of personnel that either conducts these operations or provides support services for operations. Members of the management and technical support organization staff may be located onsite or offsite.

This section provides information relative to the management an technical support organizations, their functions and respon ibilities, and qualifications of personnel. Spec ic organizati al responsibilities relating to quality surance (QA) are speci *ed in the Operations Quality Ass ance Plan (section 17.2).

13.1.1.1 Design and Oper ing Respons' ilities The design and operating respo i ilities can be divided into three categories: design and onst uction activities (project phase), preoperational ac vities, an technical support for operation.

Project design, nstruction and preoperationa activities are complete for 1 three units. The full power lice e for Unit Three was received in 1987. The sections describing t proje phase and preoperational activities have been relo ted t Appendix 13B due to the historical status of their content.

Replace with INSERT A, Page 13.1-1 1 June 2013 13.1-1 Revision 17

INSERT A, Page 13.1-1 The executive vice president, nuclear and CNO, reports directly to the chief executive officer of APS, and is responsible to provide leadership to the Nuclear Generation organization and overall management of the activities related to the operation, maintenance, and modification of the Palo Verde Nuclear Generating Station, including the entire owner controlled property.

The executive vice president, nuclear and CNO, has overall responsibility to ensure that all PVNGS activities, including operation, maintenance, and modification of the units are performed in strict compliance with regulatory requirements, consistent with the requirements for protection of the health and safety of the general public and company personnel, and in accordance with company policy.

The overall organizational structure, reporting relationships, and responsibilities for management and technical support of the facility are described in the PVNGS Operations Quality Assurance Program Description (QAPD).

The onsite operating organization and its responsibilities and authorities are further described in UFSAR Section 13.1.2, the Unit Technical Specifications, and station administrative procedures.

PVNGS UPDATED FSAR ORGANIZATIONAL STRUCTURE OF APPLIC NT 13.1. .1.1 Technical Support for Operations The exec tive vice president, nuclear and chief nuclear officer (CNO), and the chief executive officer of Arizona Pub ic Service Comp y (APS), are the corporate officers sponsible for providing nagement and technical support s vices for PVNGS. The execu ive vice president, nuclear d CNO, has been delegated corporate responsibility for overa plant nuclear safety, and has estab ished direct report roups and departments as discusse in section 13.1 1.2.

13.1.1.2 Licensee Organiza onal Ar angement The executive vice president, uc ear and CNO, reports directly to the APS chief executive offi r and president. The executive vice president, nuc ear d CNO has the overall responsibility and authori for the peration and technical support of PVNGS. The e cutive vice pesident, nuclear and CNO, and the nuclear o ganization have th overall responsibility and a thority to ensure that all activities associated with AP ' nuclear facilities are c rried out with the highest stan ards of safety and ensuring th station is operated in a ordance with the licenses granted the USNRC, the Technic Specifications, and the requirements a d commitmen stated in the Updated Final Safety Analysi Report The clear organization includes the positions for activites af cting safety of the nuclear power plant. Lines of thority, responsibility, and communication are defined and June 2013 13.1-2 Revision 17

DELETE PVNGS UPDATED FSAR [12-F014 I ORGANIZATIONAL STRUCTURE OF APPLIC T these relationships are documented and updated, as approprate.

The fol owing paragraphs provide a functional descripti of departmen al responsibilities and reporting relations ps at a high level. Further details regarding authorities, responsibilit s, and communications within the n clear organization are described in station procedure and other appropriate forms f documentation such as o anization charts, functional descripti s of departmental re onsibilities and relationships, and job escriptions for ey personnel positions.

13.1.1.2.1 Executive Vice resi ent, Nuclear and Chief Nuclear Officer (CNO). The exe tive vice president, nuclear and CNO, is responsible for te o erall operation of the three PVNGS units. Additional di cussion f this position is provided in paragraph 13. .2.2.

13.1.1.2.2 Vice Pr sident, Nuclear Engi eering. The vice president, nuclear ngineering, is responsib e to the senior vice president, te operations, for the overa 1 direction, administration and supervision of the engineeri organization . The nuclear engineering organizati s provide support a assistance to the PVNGS generating units nd other site fa lities in the area of engineering including: sign engin ring for modifications; engineering evaluations su ort; per ormance monitoring and optimization; configuration m nagement, including maintenance and control of the plant design basis; cybe r security; and nuclear fuel management.

June 2013 13.1-3 Revision 17

DELETE PVNGS UPDATED FSAR 112-F014 I ORGANIZATIONAL STRUCTURE OF APPLIC T Resp sibilities for those reporting directly to the vice presid t, nuclear engineering, are outlined in the foll ing paragrap 13.1.1.2.2.1 Director, Design Engineering. Th director, design engineerng, is responsible to the vice esident, nuclear engineeri for providing design eng eering programs and directing techn al resources to mainta the design basis, provide for configuraton maintenance, de elop plant design modifications, and provi e technical an lysis, in support of plant operations and maint nance. S cific implementing responsibilities may be appr riat y delegated within the PVNGS nuclear organization.

13.1.1.2.2.2 Director, Nuc ear F 1 Management. The director, nuclear fuel man gement, is responsible to the vice president, nuclear engin ering, for fue management and core analysis for PVNGS. Te director, nuclea fuel management, provides nuclear fu design, contracting a utilization expertise; nuclea fuel core, and plant transi nt and accident analysis; opera ional reactor engineering suppor ; alternative core operatin strategies, and spent fuel storage. Specific responsibi ties may be delegated to leaders reporti to the director nuclear fuel management.

13.1 .2.2.3 Director, Project Engineering. The directo pr ject engineering, reports to the vice president, nuclear ngineering, and is responsible for overall management and June 2013 13.1-4 Revision 17

DELETE UPDATED FSAR 1-F014 I FPVNGS ORGANIZATIONAL STRUCTURE OF APPLIC T succe s of assigned engineering projects. Responsibilitie include the three functional areas of equipment design a d fabricati ; coordination of on-site modifications; a development f requests for funding and management the approved fund g for assigned projects. Specific responsibilities may be appropriately delegated o leaders reporting to the rector, project engineerin , or other cognizant organizati ns providing support f r assigned projects.

13.1.1.2.2.4 Director, Plant Eng' eering. The director, plant engineering, is respon ble/the vice president, nuclear engineering, for direc technical resources in support of equipment root caus ilure analysis. The director, plant engineering esponsibilities also include providing technical suppor for perfo mance monitoring to assure proper functionin of the nuclea plant systems and components, including mplementation and onitoring of programs related to aging ma gement and life extens n. The director, plant engineering lso is responsible for the ontrol of software and da a for plant digital process cont ol and monitoring sy tems. Specific implementing responsbilities may be appropri tely delegated within the PVNGS nuclear organizat on.

13.1. .2.2.5 Director, Engineering Programs and Suppo T director, engineering programs and support, is responsibe the vice president, nuclear engineering, for providing June 2013 13.1-5 Revision 17

DELETE PVNGS UPDATED FSAR F12-F014 ORGANIZATIONAL STRUCTURE OF APPLIC T prog ms and directing technical resources in support of i -

service inspection and in-service testing (ASME Section and OM Code), equipment qualification, 10 CFR 50 Appendix containment inspection and testing, performance of nondestructiv examinations (NDE), erosion/corros' n monitoring, and robabilistic risk analysis. T director, engineering progra s and support, is also res onsible for providing programs f r ensuring that inspec ions are performed as required.

13.1.1.2.3 Vice Presi nt, Opera ions Support.

The Vice President, Operation Su ort, reports to the senior vice president, site operations The vice president, operations support is respons le or records management (storage, retrieval, distri ution an document drawing control/maintenance); pr urement and ores; the security, fire protection and em gency preparedne programs; implementation of pr grams for fire protecton; and for information techno ogy support for PVNGS. Re onsibilities for those reporting irectly to the vice president, operations support are o lined in the following paragraphs.

13.1.1.2. .1 Director, Nuclear Security Division. The directo , nuclear security division, is responsible to te vice presi ent, operations support, for the areas of security ope ations, security training and self assessments, access thorization, fitness for duty, and security program June 2013 13.1-6 Revision 17

VDELETE IPVNGS UPDATED FSAR ORGANIZATIONAL STRUCTUR OF APPLIC NT stan rds. Specific responsibilities may be delegated to leaders reporting to the director, nuclear security div ion.

13.1.1.2.3. Manager, Fire Protection. The ma ger, fire protection is esponsible to the vice president, perations support, for are s of fire protection related t the power block, critical su ort structures, systems d components; and the independent spen fuel storage facilit Specific responsibilities may b delegated to in' iduals reporting to the manager, fire protec 'on. Fire pr tection for ancillary and other site buildings ma be dele ated to other support organizations.

13.1.1.2.3.3 Director, Su 1 Chain. The director, supply chain reports to the vice p sident, operations support, and is responsible for nuclear ad support a a contract formation and administration, materia procurement an material control, including the QC receving inspection func ions.

13.1.1.2.3.4 irector, Emergency Planning. The director, emergency plan ng, reports to the vice presiden , operations support and responsible for developing and main aining a coordinate PVNGS, federal, state, and local governm t emergenc response program for PVNGS.

13.1 1.2.3.5 Manager, Emergency Planning. The manager, e rgency planning, reports to the director, emergency planni g nd is responsible for developing and maintaining a coordinated June 2013 13.1-7 Revision 17

DELETE PVNGS UPDATED FSAR F12-F0144 ORGANIZATIONAL STRUCTURE OF APPLIC T PVNG, federal, state, and local goverment emergency resp se progra for PVNGS.

13.1.1.2.3.6 Manager, Support Services. The ma ger, support serv es reports to the vice president, op rations support, and is responsible for development, ma tenance and administration o the PVNGS document and reco cdontrol programs. Responsi ilities include providi g document and record control progra that provide for e distribution of approved documents, dra ngs, procedure , instructions, and manuals and that provide r the col ction, maintenance, and storage of records in accor nce w'h approved written procedures and instructions whc conform to the regulatory requirements and policy of APS 13.1.1.2.3.7 Palo Ver Information Services. The Palo Verde Information Servi s group is di cted by the information services manager. Th information servic s manager is a matrix position reportingio the vice president, o erations support.

The Palo Verde In ormation Services Group is legated information ser ices functions for PVNGS includ g the maintenance non-process computer networks and sftware, database d ign and administration, data security, a d program manageme for the PVNGS non-process software quality ssurance progra described in Section 17.2G.

13 1.1.2.4 Director, Nuclear Assurance. The director, uclear assurance, reports to the senior vice president, June 2013 13.1-8 Revision 17

DELETE PVNGS UPDATED FSAR 12-F014 ORGANIZATIONAL STRUCTURE OF APPLIC T regu atory and oversight. The director, nuclear assurance is respon ible for development of the operations QA program and to verify e fective implementation. The director, nuclea assurance, irects the activities of the PVNGS Nucle r Assurance De rtment, and has overall responsibil y for the QA program includi g audits, assessments and quali verification.

The director, nucl ar assurance, has been gi n the authority, by the executive vic president, nuclear a d CNO, to maintain open lines of communic tion with individ als and groups having responsibilities related o the operation of PVNGS to ensure that policies and requirem ts of t operations QA program are properly interpreted and ade ate implemented, and to determine the effectiveness of e operations QA program. The director, nuclear assurance, as e authority to cross organizational lines to id tify qu ity problems, to initiate, recommend, or provide so tions and t verify implementation of solutions. The direct r, nuclear assura ce, has been given the authority, by the ex cutive vice president nuclear and CNO, to stop activities a /r the use or further pr cessing of materials that e not in conformance with spe fied quality requirements d/or the provisions of the operat ns QA program. T is authority is exercised through esta ished procedure.

Reportng to the director, nuclear assurance, are nuclea assu ance department leaders, who are delegated specific r ponsibilities assigned to the nuclear assurance rganization.

June 2013 13.1-9 Revision 17

DELETE PVNGS UPDATED FSAR 12-F014-ORGANIZATIONAL STRUCTURE OF APPLICA T 13.1 1.2.4.1 PVNGS Nuclear Assurance Organization The PV S nuclear assurance organization is under the supervisin and direction of the director, nuclear ass rance.

General res onsibilities of the organization include assuring that programs, processes, and activities associate with general station rocedures, plant operations, a maintenance are effectively i lemented to support safe a reliable electrical power pr uction. The scope of ese oversight and review activities inc des the operations rogram, control and manipulation of the reac or plant, tech ical specifications and surveillance testing progr m, transie t, special and off-normal evolutions, emergency and ab ormal perating procedures, system status, operator training and u ification, performance of maintenance, testing and retes ork control, measuring and test equipment controls, mat ial ntrol, maintenance rule implementation, inspection , and out e coordination. The nuclear assurance organi ation is respo sible for assuring that programs, processes, ad activities assocated with engineering and support are effe tively implemented to upport safe and reliable plant ope ations. The scope of thes oversight and review activiti includes design control and p ant modifications plant performance monitoring, reac r engineering nd special nuclear materials, software ontrol, document ontrol, ASME section XI program, ASME OM Co program procurement (including receiving inspection an wareh use storagef handling, and shipping controls), chemi try con rols, radiological controls, dosimetry, occupational r diation safety, radwaste, radiological effluent, emergency June 2013 13.1-10 Revision 17

DELETE PVNGS UPDATED FSAR 12-F°14 ORGANIZATIONAL STRUCTUR OF APPLI NT prepa edness, security, training, fire protection and fit ss for dut The nuclea assurance organization is also responsib for assuring tha programs, processes, and activities or audits, independent sa ety reviews, corrective actions, roblem identification, roblem resolution, operating xperience review, and trend alysis are effectively i plemented to support safe and rel ble plant operation Specific quality assura ce program resp nsibilities assigned to the PVNGS Nuclear Assuran organiza on are described in Section 17.2.

13.1.1.2.5 Senior Vice-Pres'nt, Regulatory and Oversight.

The senior vice president, gulat y and oversight reports to the executive vice presid t, nuclea and CNO, and is delegated the overall responsibil' y for licensin and regulatory compliance functions, non-radiological en ironmental programs, site programs, the perating experience pro ram, and the programs for cor ctive action and trending o conditions adverse to qua ty as described in the PVNGS qu ity assurance program for erations. Responsibilities also in ude the appropriat integration and alignment of oversight nctions such tha performance improvement and quality assuranc resour es are efficiently and effectively utilized to su ort cont nuous improvement in nuclear plant operations and sup ort a ivities. These responsibilities are appropriately delega d o the directors and department leaders reporting to the senio June 2013 13.1-11 Revision 17

DELETE PVNGS UPDATED FSAR 12-F014]

ORGANIZATIONAL STRUCTURE OF APPLIC T vice president, regulatory and oversight, such that the /

authority and independence of the director, nuclear assu ance, are main ained.

13.1.1.2.5.1 Director, Nuclear Regulatory Affairs and Environmental. The director, nuclear regulator affairs and environmental, re orts to the senior vice pre ident, regulatory and oversight, and *s assigned overall resp nsibility for nuclear and environme tal licensing and c mpliance programs.

This position is respon ible to monitor nuclear safety, engineering, operating, a environme tal activities to assure actions are within plant li nsing nd design bases and comply with applicable regulations. h' position is also responsible for interface with state and f ral regulatory agencies on nuclear and environmental li ensin and compliance matters.

Specific responsibilities ay be del ated to leaders reporting to the director, nuclear regulatory af airs and environmental.

13.1.1.2.5.1.1 Nuci ar Regulatory Affairs epartment.

The department le der, nuclear regulatory aff irs, reports to the director, clear regulatory affairs and en ronmental, and is responsib for developing technical license d ument changes, m ntaining specific licensing documents, veloping response to NRC requests, submitting routine regulato y agency report , and developing strategies for addressing NRC is ues.

The epartment leader, nuclear regulatory affairs, is also re ponsible to advise PVNGS management on regulatory issues o romote station compliance, minimize violations and open items, June 2013 13.1-12 Revision 17

DELETE PVNGS UPDATED FSAR IliZ-tuL]I ORGANIZATIONAL STRUCTURE OF APPLICA T and udently commit resources to resolve regulatory concer s.

The re latory affairs department shall serve as the foc point fo direct communications with NRC personnel. S cific responsibil ties may be delegated to leaders reporti to the department le der, nuclear regulatory affairs. Sp ific responsibilitie associated with quality assuran e program requirements are urther described in the PVNC quality assurance program f operations in section 7.2.

13.1.1.2.5.1.2 Environ ntal Department The department leader, envronmental, reports to the director, nuclear, regulatory affairs nd envronmental, and is responsible for direction, adm i tration and supervision of matters associated with federal tate, and non-radiological local environmental safety r uire nts. The department leader, environmental, is so respon ible to advise PVNGS management on non-radiol gical environm ntal regulatory issues to promote station com iance, minimize volations and open items, and to pruden ly commit resources to resolve regulatory concerns.

13.1.1.2.5.2 erformance Improvement Department.

The directo , performance improvement, reports to th senior vice presdent, regulatory and oversight, and is respo sible for dir ction, administration and supervision of the ope ating exper ence program and the programs for corrective action d tr ding of conditions adverse to quality as described in th NGS quality assurance program for operations. The director, June 2013 13.1-13 Revision 17

DELETE PVNGS UPDATED FSAR 12-F014 ORGANIZATIONAL STRUCTUR OF APPLI NT per rmance improvement is also responsible for collectin and repor ng of PVNGS site performance information. Speci ic responsi ilities associated with quality assurance pr gram requiremen s are further described in the PVNGS qua ity assurance pr ram for operations in section 17.2.

13.1.1.2.5.3 Pa Verde Communications Depar ment.

The director, gener tion communications, r ports to the executive vice presid nt, nuclear and CN , and is responsible for interfacing with th PVNGS and AP management teams to develop and deliver commu 'cations th internally and externally.

13.1.1.2.6 Employee Concer epartment The employee concerns depa ment i directed by the employee concerns department lead who repor to the senior vice president, regulatory nd oversight. e employee concerns department is respon ible to investigate, resolve, and document concerns reported o the employee concerns epartment.

13.1.1.2.7 Director, Strategic and Long Ran e Planning.

The directo , strategic and long range planning, ports to the executive ice president, nuclear and CNO and is re onsible for the VNGS budget process including coordinating th prepa ation and reporting of actual and budgeted data fo all pro'ect operations and maintenance (O&M); capital; nuclear f els costs; providing cost, estimating, and scheduling supp rt to all PVNGS departments; analyzing budget and work schedule June 2013 13.1-14 Revision 17

12--F0-1-4 DELETE PVNGS UPDATED FSAR ORGANIZATIONAL STRUCTURE OF APPLICANT v lances; long range planning; and preparing financial pac ges for Engineering and Operations (E&O) Committee re ew and ap royal.

13.1.1.2.8 Other Departments. Other corporate sources may be utili d by the nuclear organization as de ribed in the following parag aphs.

13.1.1.2.8.1 Palo Verde Human Resources. The human resources group is ma ged by the direct, Palo Verde human resources, who is matrix d to the exec ive vice president, nuclear and CNO. The Palo Verde hum n resources group is responsible for employee rel ion support, staffing, and compensation services for PVNG 13.1.1.2.8.2 Director, E cutive rojects. The director, executive projects, repor s to the ex utive vice president, nuclear and CNO. Resp sibilities of th director, executive projects, include im rementation of strate ies, processes and programs to optimi e site long range plans a dmanage various executive level rojects.

13.1.1.2.8. Director, Site Programs. The direc or, site programs, reports to the senior vice president, regul tory and oversi t. The director, site programs, is responsible or prov ding the overall infrastructure and administrative co trols for managing PVNGS site programs, processes, and rocedures. The director, site programs, is also responsible June 2015 13.1-15 Revision 18

DELETE I PVNGS UPDATED FSAR 12F14 ORGANIZATIONAL STRUCTURE OF APPLIC T for aintaining the business processes and infrastructure suppor this function.

13.1.1.2.8. .1 Department Leader, Site Procedure Sta dards.

The departmen leader, site procedure standards, r orts to the director, site rograms. The department leader, site procedure standards, is res nsible for development and aintenance of the standards for P GS programs and proced es. In this capacity, the site pro edure standards or nization is delegated responsibility by the senior ce president, site operations, to assure that he prepar ion, review, and approval of PVNGS programs an proc dures are carried out as specified by Section 13.5.1, Pr p ration of Procedures. The site procedure standards organi a ion also assists the Nuclear Operations and Maintenance o aniza ons in preparing, reviewing, and maintaining heir proce ures. Responsibility and authority for approv of Maintenanc and Operating procedures is delegate to department lead s and section leaders within the Ste Procedure Standards ganization. In this capacity, the Procedure Standards Organiza ion is functionally res onsible to the operations and maitenance directors for he technical accuracy and overall qu ity of procedures develops and approves.

13.1.1. Qualifications Memb s of the management and technical support organization st f providing technical and operational support and not in e nuclear production organization, who perform activities June 2013 13.1-16 Revision 17

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INSERTA, Page 13.1 -2 The responsibilities and authorities of key members of the operating organization are described in this section. The following APS positions have the responsibility and authority for directing or placing a PVNGS unit in a reduced power or shutdown condition to ensure nuclear safety:

" executive vice president and CNO

" senior vice president site operations

" site general plant manager

operations director

unit operations managers

shift managers

control room supervisors

" control room operators 13.1.2.1 Executive Vice President and CNO is responsible for:

" overall plant nuclear safety and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety;

ensuring that all PVNGS activities, including operation, maintenance, and modification of the units and related nuclear facilities are performed in strict compliance with regulatory requirements, consistent with the requirements for protection of the health and safety of the general public and company personnel, and in accordance with company policy; This position fulfills the role of the corporate officer described at 5.2.1.c of the PVNGS Unit Technical Specifications.

13.1.2.2 The Senior Vice President Site Operations is responsible for:

" overall PVNGS site and plant management, including operations of the nuclear power plants, spent fuel storage facility, and water reclamation facility

" providing technical and engineering support for operations, maintenance, and modification of the power plants and facilities located at the plant site

" establishing and administering policies, providing procedures, and maintaining standards of performance that ensure safe operation

ensuring site operations are in compliance with requirements of the operating license, applicable regulations, and regulatory commitments

13.1.2.3 The Site General Plant Manager has direct line responsibility for operation and maintenance of the PVNGS nuclear plants and is responsible for direction of plant operations.

This position fulfills the role of the Plant Manager as described in 5.2.1.b. of the PVNGS Unit Technical Specifications.

13.1.2.4 The Operations Director is responsible for:

" approving operational programs and procedures

" managing and directing safe operation of the facility in accordance with regulatory requirements, the Operating Licenses, and company policies, programs, and procedures

" providing programs for ensuring that surveillance testing is performed as required 13.1.2.5 Units 1, 2, and 3 Operations Managers are responsible for:

conducting unit operations in a safe manner in accordance with the technical specifications and station procedures

supervising the activities of the operating personnel

coordinating the activities and performance of the shift managers to ensure that the conduct of the operating staff is consistent with protection of the health and safety of the public and is in compliance with all applicable rules, regulations, and procedures

ensuring that identified plant deficiencies receive the appropriate work priority to maintain plant safety and reliability

reviewing various operating logs and records for accuracy, completeness, adherence to applicable administrative procedures, regulations and technical specifications, and to maintain current knowledge of plant activities This position satisfies the requirements of the Operations Department Leader as described in the PVNGS Unit Technical Specifications. This position will hold a senior reactor operator license to satisfy the requirements of the PVNGS Unit Technical Specifications 5.2.2.d.

13.1.2.6 Operating Shift Crews Normally during non-outage periods, operating crews will be manned on a five shift, self-relieving 5-crew basis. An operating crew for each unit will normally consist of a shift manager and control room supervisor (who will possess senior reactor operator licenses), two reactor operators (who will possess reactor operator licenses), and four non-licensed operators (nuclear auxiliary operators). The minimum shift operating crew composition for various modes of operation is described in the PVNGS Unit Technical Specifications and in section 18.I.A.1.3.

A site Fire Department of at least five members shall be maintained onsite at all times. Fire Department composition may be less than the minimum requirements for a period of time not to exceed two hours in order to accommodate unexpected absence of fire department members, provided immediate action is taken to restore the fire department manning to minimum requirements.

The Fire Department shall not include the Shift Manager, the STA, nor the 3 other members of the minimum shift crew necessary for safe shutdown of the unit and any personnel required for other essential functions during a fire emergency. One Reactor Operator is assigned to support the Fire Department as the Fire Team Advisor.

13.1.2.6.1 Shift Managers are responsible for the safe operation of the unit during their assigned shifts.

13.1.2.6.2 Control Room Supervisors are responsible to provide a backup to the shift manager and supervise shift personnel in the conduct of operations.

13.1.2.6.3 Limited Senior Reactor Operator (LSRO) for Refueling. The limited senior reactor operator (LSRO) for refueling is responsible to the shift manager for directly supervising core alterations and those specific evolutions or work activities that could result in core alterations.

This individual will be a senior reactor operator conditionally licensed for refueling operations and who has no concurrent duties when performing functions of the LSRO. A fully-licensed senior reactor operator with no concurrent duties may perform the functions'of the LSRO.

13.1.2.6.4 Reactor Operators are responsible for:

operating and directing operations of mechanical, electrical, and reactor systems from the control room

reactor safety in accordance with Technical Specifications, company policies, and procedures 13.1.2.6.5 Nuclear Auxiliary Operators are responsible, under the direction of the control room supervisor, for operating plant systems and assisting in fueling handling operations, as directed.

13.1.2.6.6 Shift Technical Advisor is responsible for:

providing advisory technical support to the Shift Manager in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to safe operation

" meeting qualification requirements specified by the Commission Policy Statement on Engineering Expertise on Shift

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DELETE PVNGS UPDATED FSAR 12-F014 ORGANIZATIONAL STRUCTUR OF APPLI NT maint *n standards of performance that ensure safe operation of the sit This position is also responsible to ensure ite operations are in compliance with requirements of the operating license, app icable regulations, and regulatory co itments.

Reporting dire tly to the senior vice-president, ite operations are v ce president, nuclear enginee ing; vice president, operati s support; the site gene al plant manager, water reclamation fa lity plant manager, irector, nuclear training, and departmen leader, industral health and safety.

13.1.2.2.1.2 Site Genera Plant M nager. The site general plant manager, is responsible to e senior vice president, site operations, for the overal day-to-day station operations.

Reporting to the site general pla manager are the director, operations; director, maint nance; *rector work management; director, nuclear project ; radiation rotection manager; assistant plant manage and department 1ader, chemistry. The operations departmen leaders, under the diection of the operations directo , are responsible for ope ations of their assigned unit.

13.1.2.2.1.2 1 Director, Operations. The director operations reports to the site general plant manager and is resp nsible to approve perational programs and procedures, and to man ge and direc the safe, efficient operation of Units 1, 2, and 3 in acc dance with regulatory requirements, the Operating Licenses, and approved company policies, programs, and procedures. The Director, Operations responsibilities also June 2013 13.1-20 Revision 17

DELETE PVNGS UPDATED FSAR 12-F0147]

ORGANIZATIONAL STRUCTUR OF APPLI NT inc de providing programs for ensuring that surveillance testin is performed as required.

Responsiblity and authority for approval of operati al procedures *s delegated to department leaders and ection leaders withi the Site Procedure Standards Orga ization. In this capacity, e Procedure Standards Organi tion is functionally resp sible to the operations rector for the technical accuracy a d overall quality of rocedures it develops and approves. Specific respon ibilities may be delegated to leaders rep rting to the irector, operations.

13.1.2.2.1.2.2 Department ead s Units 1, 2, and 3, Operations. The department le ers Units 1, 2, and 3, Operations are responsible to th director, operations, for the conduct of unit operations n a sa and efficient manner in accordance with the tech ical specifi ations and station procedures. Each Unit's operations dep rtment leader supervises the activties of the units op rating personnel.

The department le ers Units 1, 2, and 3, c ordinate the activities and rformance of the shift manag s to ensure that the conduct o the operating staff is consisten with protection f the health and safety of the public nd is in complianc with all applicable rules, regulations an procedu es. The department leaders Units 1, 2, and 3, ensure that dentified plant deficiencies receive the appropria work pr' rity to maintain plant reliability. The department le ers its 1, 2, and 3, review various operating logs and records for accuracy, completeness, adherence to applicable June 2013 13.1-21 Revision 17

DELETE PVNGS UPDATED FSAR 112--014 ORGANIZATIONAL STRUCTURE OF APPLICANT admi istrative procedures, regulations and technical specif ations, and to maintain current knowledge of plant activiti This position will hold a senior reactor oper tor license on VNGS. The holder of the senior reactor oper tor license shall direct the licensed activities of the 1 ensed operators.

13.1.2.2.1.2.3 Shft Managers. The Shift Ma agers are responsible to the ope ations department lea r for the safe, reliable, and efficient eration of the u t during the assigned shift.

13.1.2.2.1.2.3.1 Control Ro Su ervisors. The control room supervisor provides a backup o the shift manager and supervises shift personnel in c ndu of operations as assigned.

13.1.2.2.1.2.3.2 Lim' ed Senior Reacto Operator for Refueling. The limite senior reactor opera r (LSRO) for refueling is the indvidual in the containment uilding directly responsi e to the shift manager. The LS will directly superv'se all core alterations and those s cific evolutions or work activities that lead to core altera ions.

This indiv ual will be a senior reactor operator conditonally licensed or refueling operations. A fully-licensed senior reacto operator with no concurrent duties [sometimes referre to a a refueling senior reactor operator (RSRO)] may also p form this function as needed.

June 2015 13.1-22 Revision 18

DELETE PVNGS UPDATED FSAR F12-F014 ORGANIZATIONAL STRUCTUR OF APPLIC NT 13.1. .2.1.2.3.3 Reactor Operator. The reactor opera or operate and directs operations of mechanical, electric, and reactor s tems from the control room in a safe and e ficient manner to a ure maximum unit electrical generation The reactor operat r, reporting to the control room s pervisor, is responsible for eactor safety in accordance wi h Technical Specifications, co any policies and procedu s to ensure the health and safety of the public.

13.1.2.2.1.2.3.4 Nuc ear Auxiliary perator and Auxiliary Operator, Senior. The nuc ear auxil' ry operator and auxiliary operator, senior are respons le, der the direction of the control room supervisor, for o ating auxiliary systems and assisting in the refueling of e plant as directed.

13.1.2.2.1.2.3.5 OperaXions Supp t Department Leaders.

Operations support depar ment leaders r port to the director, operations. The opera ions support depar ment leaders manage the operations supp t staff to ensure that the Operations department is pro ded with quality procedure Shift Technical Advisor support and training support that meet equirements and departmen al needs. One of these positions i responsible for the ope ations work planning and scheduling fun ion which supports fficient use of Operations department resour es within VNGS work management processes. The operations upport depar ment leaders also provide support to the operations di ctor in resolving Operations department technical and ogrammatic issues.

June 2013 13.1-23 Revision 17

PVNGS UPDATED FSAR I I14 ORGANIZATIONAL STRUCTURE OF APPLICANT

13. .2.2.1.2.3.6 Fuel Handling Supervisor. The fuel handli g supervisor (FHS) is the individual in the fuel building directly responsible to the shift manager. The F S will direc ly supervise all nuclear fuel movement in the spent fuel pool to 'nclude the Cask Load Pit and Transfer C al.

This individual will be trained and qualified in eqipet systems and proce ures that are applicable to the movement of fuel in the spent f 1 pool. A fully-licensed enior reactor operator with no concu rent duties [sometime referred to as a refueling senior reactor operator (RSRO)] r a limited senior reactor operator (LSRO) ma also perfor this-function.

13.1.2.2.1.3 Director, Mainte nce The Director, Maintenance reports to the site g neral plant manager and is responsible to manage and direc ma. tenance, modification, and support activities in Units ,2, and ,and site facilities.

The director, maintenance, isalso respo sible to ensure that the PVNGS units are main ained and modifie in strict compliance with regul ory requirements and nsistent with requirements for pu ic health and safety, to mnage and provide programs nd procedures for control of p1 nt maintenance, a for managing technical resources i support of plant operat' ns and maintenance. Responsibility and uthority for approv 1of maintenance procedures is delegated to departme t leaders and section leaders within the Site Proce re Standards Organization. In this capacity, the Pro edure Standards Organization is functionally responsible to t e maintenance director for the technical accuracy and overall June 2015 13.1-24 Revision 18

DELTEI PVNGS UPDATED FSAR 112-F014I R ~ORGANIZATIONAL STRUCTURE/

OF APPLICANT qua 'ty of procedures it develops and approves. Specific respon ibilities may be delegated to leaders reporting to t director maintenance.

13.1.2.2.1.4 Director, Work Management. The Direct ,Work Management, rep rts to the site general plant mana r and is responsible for dvelopment of long-term refueli g cycle and outage plans; prepa *ng plans for accomplishin refueling, maintenance, and modi cations during plann outages, with the concurrence of other dep rtments; directi and controlling outage work activities; ac ing as a cen ral source for transferring "lessons learne " from evious outages and for developing'a standardized appro ch oward planning and conducting outages; providing su ort to the units as necessary for unplanned outages; and the day- -day scheduling of unit activities. Specific respo ibilities may be delegated to leaders reporting to the rector, work anagement.

13.1.2.2.1.5 Radiaton Protection Manager. The radiation protection manager eports to the site general lant manager.

This position is lso known as the director, radi tion protection or irector, site radiation protection, d these titles may b used interchangeably throughout the UFS and Technical pecifications. This position is responsible or the overallimplementation and performance of the radiation prote tion program at PVNGS, to include radioactive waste pr essing and shipping, radioactive effluent activities, diological environmental monitoring, and radioactive material June 2015 13.1-25 Revision 18

PVNGS UPDATED FSAR ORGANIZATIONAL STRUCTURE OF APPLICAN con ol. The director is also responsible to take timely action to correct substandard performance within the radi tion protecti program. Specific responsibilities may be d egated to leaders eporting to the radiation protection mana er.

13.1.2.2.1.6 epartment Leader, Chemistry. The department leader, chemistry, reports to the site general lant manager and is responsible r the overall direction f plant chemistry activities for PVNGS. These responsibilites include systems chemistry control, chemi al and radioche ical sampling and analysis. Specific respon bilities y be delegated to the leaders reporting to the depa tment eader, chemistry.

13.1.2.2.1.7 Plant Manager,. ater Reclamation Facility.

The plant manager, WRF repor to t senior vice president, site operations and is res onsible fo the maintenance and operation of the WRF and the incoming pi eline, for supply of site water and chemic s, for management o underground piping projects, and for m ntenance and testing ac vities as delegated. Activties are coordinated with the Work Management Department.

13.1.2.2.1. Director, Nuclear Training. The dir tor, nuclear raining, reports to the senior vice president, ite operations and is responsible for the preparation, coo ination, and conduct of PVNGS training. Responsibiliti i lude providing health services support for operational June 2015 13.1-26 Revision 18

DELETE PVNGS UPDATED FSAR 12T-F014]

ORGANIZATIONAL STRUCTURE OF APPLICANT actvities. Specific responsibilities may be delegated to leade reporting to the director, nuclear training.

13.1.2.2. 9 Assistant Plant Managers. The assis ant plant manage s report to the site general plant man er. Each assistant plan manager is responsible for outage coordination and equipment re ability improvement activitie for a single Palo Verde unit. Asistant plant managers wo k in concert with the other site organi ations to ensure the verall implementation of on-li , planned outag , and forced outage work activities are comple ed efficie ly and without compromising plant or person el saf y. The assistant plant managers assist the site gener ant manager in developing and/or reviewing strategic plan nd actions to improve overall work performance and enhance he re iable operation of plant equipment.

13.1.2.2.1.10 Dire tor, Nuclear Proje s. The director, nuclear projects, re orts to the site genera plant manager and is responsible fo the overall management and uality of assigned mainte ance and modification activities. Specific responsibilities include the planning, scheduling, nd implementa on of assigned maintenance and modificati activiti s, including the management of resources and f ding for pe formance of assigned maintenance and modification act ities. Specific responsibilities may be appropriately d egated to leaders reporting to the director, nuclear projects, or other cognizant organizations providing support.

June 2015 13.1-27 Revision 18

DELETE PVNGS UPDATED FSAR i12F04I ORGANI ZATIONAL STRUCTURE OF APPLICANT

13. .2.3 Operating Shift Crews Normal during non-outage periods, operating crews will manned o a five shift, self-relieving 5 crew basis.

An operatin crew for each unit will normally consis of a shift manager nd control room supervisor (who wil possess senior reactor o erator licenses), two reactor erators (who will possess react operator licenses), and ur non-licensed operators (either nu ear auxiliary operatd s or auxiliary operator, seniors). Th minimum shift o rating crew composition for various m es of opera on is as described in the PVNGS Technical Specifi tions ad UFSAR section 18.T.A.1.3. A site Fi e D partment of at (a) least TeFr five members shall be maintained ons at all times a). The Fire Department shall not include e Shft Manager, the STA, nor the 3 other members of the inimum shit crew necessary for safe shutdown of the uni and any perso el required for other essential functions du ing a fire emergenc . One Reactor Operator is assigne to support the Fire Dep rtment as the Fire Team Advisor.

a. Fire Department composition may be less than the minimum

requirements for a period of time not to exceed two hours in order to accommodate unexpected absence of fire department members provided immediate action is taken to restore the fire department within the minimum requirements.

June 2015 13 1-28 Revision 18

DELETE PVNGS UPDATED FSAR 1'1-1 'I_

ORGANIZATIONAL STRUCTURE OF APPLICANT 13.1 3 QUALIFICATIONS OF NUCLEAR PLANT PERSONNEL 13.1.3. Qualification Requirements The statio technical specifications, specific regulatio, and the recommen ations of Regulatory Guide 1.8, Personnel Selection and aining, and ANSI/ANS 3.1-1978, Selec ion and Training of Nucle r Power Plant Personnel, are us as the basis for establishng minimum qualifications f r nuclear power plant personnel; with he exception of operat r license applicants. For those ldividuals not alr dy qualified by experience and training/e cation in the esignated craft or discipline, and for which AN I/ANS 3.1 1978 permits the use of related training to meet certal qu ifications (e.g.,

sections 3.2.4 and 5.3.1-5.3.4), propriate training shall be provided to develop the profici cy required for safe and competent job performance. N te that here is no specific time correlation for the durati of this traiing when used in lieu of the education or expe lence specified i the Standard.

The education and exp ience eligibility requiements for operator license ap licants, and changes theret shall be those previously eviewed and approved by the NRC, specifically those referenc in letter 102-04930-GRO/TNW/RJR, da ed The Shift echnical Advisor shall have a bachelor's degre or equival nt in a scientific or engineering discipline with spec ic training in plant design and plant operating ch acteristics, including transients and accidents.

June 2015 13.1-29 Revision 18

DELETE PVNGS UPDATED FSAR ORGANIZATIONAL STRUCTURE OF APPLICANT Othe specific exceptions and clarifications to ANSI/A 3.1-1978 are as follows:

A. E eption is taken to the educational requirement of ANS ANS 3.1, paragraph 4.6.1 Engineer in Charg Equiva ent technical expertise is demonstrate by possessi of a Professional Engineering Li ense; or successful ompletion of the Engineer in raining examination; r successful completionif 80 semester credit hours of echnical portions o an engineering or physical scien program; or a ombination of any Bachelor's Degree an a current or previously held Senior Reactor Operato Licen e.

B. The experience requiremen of NUREG 1021, Rev. 8, ES-202, "Preparing and vi ing Operator License Applications" are sat' fied in lieu of experience requirements of ANS /ANS 3.1, pa agraph 4.3.1, Supervisors Requi ing MRC Licenses, for individuals filling the te orary position of LS C. The radiati protection manager shall hye a bachelor' degree or equivalent as describ d in the PVNGS c mmitment-to Regulatory Guide 1.8. I addition to t bachelor's degree or equivalent, the ra ation pr ection manager shall also have the required years of related experience discussed in ANSI/ANS 3.1-1978, Section 4.4.4, paragraph 2.

Exception is taken to the experience requirement of ANSI/ANS 3.1-1978, paragraph 4.4.5 for the nuclear June 2015 13.1-30 Revision 18

DELETE PVNGS UPDATED FSAR 12-F014I ORGANIZATIONAL STRUCTURE OF APPLICANT assurance department leaders. They are not required to have one year of experience within the QA/nuclea a surance organization.

E. The irector, nuclear assurance, shall have br d experi ce and formal training in the perfor ance of quality a surance and quality control acti ities, including i spection and testing. They hall be capable of pl ning and providing sup rvision to nuclear assuran personnel who ma e engaged in inspecting, testin , reviewing, aluating, and auditing the adequac of activ ies to accomplish quality assurance prog m obectives.

The director, nuclear ass ance, shall have a bachelor's degree in scence or engineering or the equivalent of a bach or's deg ee as described in the PVNGS commitmeht t Regulatory G de 1.8. In addition to the bachelor' degree or equival nt, the nuclear assurance dir tor shall have at leas 4 years of quality ass ance or operations supervi ry experienc. At least two years of the re ired experi ce shall be nuclear power plant expe ience.

As d' cussed in ANS 3.1-1978, Section 4.4.5, a least on year of the required experience shall be upervisory or management experience in overall implementation of a quality assurance program.

June 2015 13.1-31 Revision 18

DELETE PVNGS UPDATED FSAR ORGANIZATIONAL STRUCTU OF LCANTO The station tr ing programs and associated Tr 'ning Program Descriptions further scribe the minimum alifications for key nuclear power plant pe onnel.

13.1.3.2 Qualification Plant Pers el Resumes of the ap Intees to key plant manage al positions and shift manag level are on file for review and are t included jhere.I" June 2015 13.1-32 Revision 18

112-F014-1 PVNGS UPDATED FSAR 13.2 TRAINING PROGRAM Personnel to staff PVNGS are selected to ensure they will have the qualifications necessary to satisfactorily perform their assigned functions. To augment the formal education, training and experience of station personnel, training programs have been instituted for site employees and contract personnel. The Director, Nuclear Training has overall responsibility for the conduct and administration of training programs for the staff of PVNGS. fthe PVNGS Operations Quality Assurance Program Description Refer to. =S S 17 . Ql A7 Pr...a..

(174.2F. Quality un for... Fire Protection, 44.2F.3 Qua4i,,ty Assura~nce for Secur-ity, 1nd:7.2F.4 Quality Assurance felý Emergency Plan7 and Eqaipment) for other training program requirements and associated responsibilities.

The Plant Manager, Water Reclamation Facility has the overall responsibility for the conduct and administration of the Water Reclamation Facility training programs.

Training program content is described in training program descriptions.

13.2.1 TECHNICAL TRAINING PROGRAMS:

Technical training programs for the staff of PVNGS have been developed based on a systematic approach to training as defined by 10CFR55.4.

The technical training programs include those listed in 10CFR50.120, "Training and qualification of nuclear power plant personnel" and these programs are periodically evaluated by the National Nuclear Accrediting Board (NNAB).

June 2007 13.2-1 Revision 14

PVNGS UPDATED FSAR TRAINING The Director, Nuclear Training has direct responsibility for administration of the training programs identified in 10CFR50.120, "Training and qualification of nuclear power plant personnel."

13.2.2 GENERAL TRAINING DESCRIPTION 13.2.2.1 Tyipes of Traininq Station personnel may be qualified through formal education and experience, formal job training, related technical training, on-the-job training, or a combination thereof.

13.2.2.2 Qualification of Personnel Personnel training and qualification is delineated in training program descriptions or administrative procedures. The Nuclear Training Department assists each unit staff organization in the development of training and the maintenance of personnel qualifications. Site personnel and their leaders are responsible to ensure they are qualified prior to performing assigned tasks.

13.2.2.3 General Emnloyee Training Site access training meets the requirements delineated in ANSI/ANS 3.1-1978 and is provided to long-term site employees and to all personnel prior to their being granted unescorted access to restricted areas. This training is implemented using industry guidance and regulatory requirements and includes topics such as instruction on evacuation signals, evacuation routes, and procedures for reporting a fire. The course requires satisfactory completion of written or computer-aided examination.

Radiological protection training which addresses the topics and requirements of Regulatory Guide 8.27 is provided to personnel prior to their being granted unescorted access to radiological June 2007 13.2-2 Revision 14

PVNGS UPDATED FSAR 1F0 TRAINING controlled areas. The course requires satisfactory completion of a written or computer-aided examination.

Temporary personnel receive training based on the access level required and their knowledge and experience, as validated by written or computer-aided examination.

13.2.3 FIRE PROTECTION TRAINING 13.2.3.1 General Empnloyee Fire Protection Training As a portion of General Employee Training, station personnel are trained in the following aspects of fire protection:

eStation Fire Protection Program

Station Evacuation Routes

Fire Reporting Procedures

Job Related Fire Prevention and Suppression

Control of Ignition Sources 13.2.3.2 Fire Department Training The Fire Department training program ensures that the capability to fight potential fires is established and maintained. The program consists of initial classroom instruction followed by periodic classroom training, firefighting practice, and fire drills. The program is based on specific 10CFR50, Appendix R training requirements and selected recommended practices by the National Fire Protection Association (NFPA) Standard (1987) 1001 for the equipment and practices applicable to the PVNGS Fire Department for Firefighter Level I.

June 2009 13.2-3 Revision 15

PVNGS UPDATED FSAR F12-F014]

TRAINING Periodic classroom refresher training sessions are held to repeat the classroom instruction for all fire department members over a 24 month period. Changes to the fire protection program and plant changes impacting fire response capability are reviewed as necessary in the training sessions. Senior fire department members receive instruction in incident command.

Practice sessions are held for each shift fire department on fighting fires similar to those expected in nuclear power plants. These sessions provide Fire Department members with experience in actual fire extinguishment and use of self contained breathing apparatus under strenuous conditions encountered in firefighting. These practice sessions are provided at least once per year for each fire department member.

Fire department drills are performed at regular intervals not exceeding 3 months for each shift. Each fire department member is encouraged to participate in each drill, but is required to participate in at least 2 drills per year.

A sufficient number of these drills, but not less than one for each fire department shift per year, are unannounced to determine the firefighting readiness of the fire department, shift fire captain, and fire protection systems and equipment.

At least one drill per year is performed on a "backshift" for each fire department shift. The drills are pre-planned to establish the training objectives of the drill and shall be critiqued to determine how well the training objectives have been met.

Unannounced drills are planned and critiqued by the fire training officer or designee. Performance deficiencies of a fire department shift or individual fire department members are remedied by scheduling additional training for the department or June 2007 13.2-4 Revision 14

PVNGS UPDATED FSAR L12 1 TRAINING individual. Unsatisfactory drill performance is followed by a repeat drill within 30 days.

At 3 year intervals, a randomly selected unannounced drill is critiqued by qualified individuals independent of the PVNGS Fire Department staff. A copy of the written report of each critique is available for review.

Fire drills as a minimum include the following:

A. Assessment of fire alarm effectiveness, time required to notify and dispatch the fire department, and selection, placement, and use of equipment, as well as firefighting tactics and strategies.

B. Assessment of each fire department member's knowledge of his or her role in the firefighting strategy for the area assumed to contain the fire. Assessment of the fire department member's conformance with established firefighting procedures and use of firefighting equipment.

C. The simulated use of firefighting equipment required to cope with the situation and type of fire selected for the drill. The area and type of fire chosen for the drill differ from those used in the previous drill so that fire department members are trained in fighting fires in various plant areas. The situation selected simulates the size and arrangement of a fire that could reasonably occur in the area selected, allowing for fire development due to the time required to respond, obtain equipment, and size up the fire, and assuming loss of automatic suppression capability.

D. Assessment of the shift fire captain's direction of the fire suppression activities as to thoroughness, accuracy, and effectiveness.

June 2007 13.2-5 Revision 14

PVNGS UPDATED FSAR 12-F014 I TRAINING Individual records of training provided to each fire department member are maintained for at least 3 years to ensure that each member receives training in all parts of the training program.

Retraining or broadened training is scheduled for all fire department members whose performance records show deficiencies.

The Fire Department training program also includes training for personnel who inspect and test fire protection equipment, to ensure that they are certified to perform that work. The training consists of on-the-job training conducted by qualified Fire Department personnel. Written records of each individual's qualifications are maintained.

The Fire Department training program includes hazardous materials handling training. The program is based on the requirements of OSHA 29CFR1910.120, for the equipment and practices applicable to the PVNGS Fire Department. Training will consist of initial classroom and practical sessions, followed by annual refresher training.

13.2.3.3 Securitv Department Fire Protection Training Instruction is provided for security personnel that addresses (a) entry procedures for outside fire departments, (b) crowd control for people exiting the station, and (c) procedures for reporting potential fire hazards observed when touring the facility.

June 2007 13.2-6 Revision 14

PVNGS UPDATED FSAR 112-Fjl is described in the PVNGS Operations Quality Assurance 13.4 REVEW AD ADITProgram Description (QAPO).

operating phase activities that affect nuclear safety are reviewed and audited. The review and audit p ogram is implemented prior to initial fuel loading and eniip proiper rpi~i t-d;nrl PiT;:;1 ~ii;-1inn rnf fa~r! 1 J hý nperai- i nn q, p~rnpn-,-Hri h;=nges*

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saf npprant~nn of P\TN1( -THe L kept- ahrest- oif unit'L lr' nppratjD4n cnrndi tH rns hN7 f-hp Cingi t-f=~Hr,-ri-trum-, -ýndr1 ~p;:riTnh 1 ~grif-r- w~hri =;7-P know~ledrgeabl a nd~ cPvpc~ri ~nr- in t-hpi r ~r'~rif jrml- rPcupcinqjhi ii -v ThE di rectorsr andl darpar-mpni- 1 a~prS pi-rfrirm H-melv ;'nr rrunt-jinih n mnnit-n-rinqng f np~r;:;ti nc- ;=nc mTn1-~ntpnr-p ar1-iatipci asc parti of t-heir noi-ma1 joli ii,1-Jesi Tn Ar~c-it1ic-nn a form;:;] rpujr Pia ;;nri ýumcj t proqr~m Ii q ';-rni ccl out-for rhangqci t-o -,gqtlPmnc; prrunt-rP1irPci, 1-pstsc ;;nrl rYpP-rjm~~nj-,c; 1

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Snrlepp~ndin t Ra~fetxc rPNLwci . andic anc ~n ffqi 1 q~fa-frh' Pt77T gpu PrmrTnmitti-p (nfl,]3)

June 2013 13.4-1 Revision 17

PVNGS UPDATED FSAR IIýlUl RF'XTTF.W Am\1F AtThTn 1?2d-1 STAFF' TP.C'TNTrAT, RF.\TTFWC 1*ý-4.1 1 PrrpDnqpHc- Tnncli fi r-;:;tinng tn -ijnt n ii g~r

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rplated(-- SN~r-ur~g7j-,t-flc ;;nr c')nmprn,-nt--- gh;n;1 b,-rips'ianeH Imy4 C

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-qb;l1 1bi- rpuipdri htýi7c Iu;n jncjj~jir;;;l/grnuup nt-hpr-r t-h);n. the nc-Ir3-i u--i ruu 1/qrcp w~hicrh rhicu-Lqgnri the mncri fi r'zýtinnf hiit ian may, hi- frCni 1-hpr nrq~ni 7At-nn as the ji ncl u-i c-u-a/grnuup w~hi rh ci, gjCnprl thL- mmdjifj-,rt nn Prmnpn~qpH mnii fi r;:t-nn-, t-n) nirle-ýi~re

-,ae-7-p atd treur'tuures' (;47stpmq ;:zrj rrnmpnnnpnt--, 'hhp

-;pprnuedr pDrInr i-n imj~p]~ment;ýti nr 1-)-, fth- nL-ýDrtment- T~p~rjcpr.

npp;ýtjnq- nr hý7 t1-h fli rpr't-nr- Q2p4~raetinng- ;:;- c3--Lc~in;;t,-Cr hu thp~

-13.4-1 1 1 Mmdifiratimnnq in t-he CPC- Ac1Hraqqahl C'nngi-ani n;ip n -informal-inn chti-neindr ihrnulclb t-hp Pl;nt C-nmpuulrnr - ((

c~1 I~nk cgh;;1 nnl- }-up m;c-lp wiii-hoii- prior approNza~l of t-he PER

.J.....LL.-2. Tndi -iii lj;ij q~n~i fnr ~rpNri1c zq pprfarmeHu in arr'c'rcdhnr tirii-h 12 A4 1 1 q'hal h-p ci~pnt-ifijcl in q:L,ýj-inn prnrcadiures,~ F,:r-h -,uuh ri-Nripia~ shall inao-Ld re~rmi cipt nati nn of Ndptprnr nnt- ;;Hlrli -inna n-r-nqsc-rIJ qrip] in~rx; rn-7-i IýUi 1I nppggru-, Tf Hpepmcpc ncprcpcu;u:rw ,ir' ~1Il gh.:;i hp parfnrmenod hN7 t-hpr ;:;pprnp3:j;tez deqcuinaei-P reV1~tji pcprsrnnnpi

]',41Thp PiHi ;-ti-nn Protpte~i-nn Maun~qcpr sh;:)l 1 sgu~rp t-he pprfnrmennr. nf ;; rgn-ili nui h17x ;; "i-ajveifitcl incli1TIcIIle./n.)rgni7ai-irnn 1

n~f neenry imp enne1nnI gmr tp mple nýsn nf raeciý-:)tvnTn~un mi-nriA in te t-hp Pnnurrnn.- inn] irlijng thi- Z~pjDA-r,;tjnn ;:nH- fne-~~rke-li n[ nf June 2013 13.4-2 Revision 17

PVNGS UPDATED FSAR Fl--F01 REVIEW AND AUDIT

-r~ppnrt'q rcnTr-i n thp Pu;illiva1 c-nn rpr'nmmpndat+/-Hnnq n rlij --pr)Sl tHj n of ti-hg rnr~rrga rti vi-g ;:r- on t-I- ;Dr-r-pnt- rpii-r,1r(=nr

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4- 21-~ Qnjt pl-Ia JS p,--rfnr-rm.-Cl h-n 1hp Pla~nt Pý-7Tgpmi nnard (PRg), ihjrh h,ýý th,- r pnnnqm-V it--,z t-m ;=ldvjq th,- Site r(fn,-ral Pla~nt M,;m;grpr on all mat1t-prc rpla~ti nc to mi~r'1 r

-afi-tNZ The PPR Mmhp~mrS rrmllemrtjurplx7 t-hem tup cl derp f e-yrpprtjq rpq-liwi rrp t-n prcnp~r1 rpiH pw prrnpcqtcl

,changes, t-n qý7~-qtm--, pr-nr'nclires tests, ce x-prrimeints ;=ncl linpli- i-7Tt- -wnt-.q that ;; ffpzr-- niir'] , r q;=fpthw7 Th,- PPR mn:;i nt->ýlna xir t-1-~n rni niitg" of P;:rh rnpp~-j- ng. wh ich arp~ ra~ipiae hN7C tmwhe flff~j -t S;lfg.-tx PP3TirmtT PC'nMri tA-t-422Thp 1 PER Shall1 hP rnrnpnosed of at- 1pq Rrp- up~n Tnprnhprs fromn týmp P,-1n \7prdlpr mTn,-4acprnt gt;:iff, Theqp pnqt~ willc 1r hp1 gi.-Jnaterl in iwr-fln( h1w t-he Si-ip Gpnpr;;] Pl:mt- M;;na"rgr The~ q1-p (~m~~1Plant Manager shall deignate the Chairman andl dpqinat-ci atrn;=it- -in i~r-ig Thp r'h;H-rrn;n anHrl q;t-

,a t-prnz;tp m,-4N h from niif-g r-p t-hrp mrnbmhrS prnuidi lri 1-h;:1 thprý rnp1t th-h rt-Cpirpmpnt-q rnf 4 '7 1 rnf A1'JT./A1'1' -LI 1 q-7g

.1-ý-411 -3 ll ltrnatp rnmpmhrrq-c ýhall hp~ appnint-t-r in Twrjt-ng byw t-he 22R 13~-harrnrn1n :u~ to n t--rmrporal:N7~i hnTj7p--r, nom mrnnr thn tl7n ;:i I trn,ýtpS 'qh~z 1 p~rti rip,;ta -c 77mi-J n" rnmemhpzrr in PP'R ;;;r-tjxr rm' :t- ;;n-,7 nnrm 1-irnrm 1'-4?AThe PPR qh~1 1 mrrpI ;qt 1 ;:R~t nnr'p ppr r';:ilpnH-Thr mninth

ndA cnnirpnpc h17 t-hk- 12RP C'hajr-i rn nr clýc- rfn~t-prl a1 -tarn~tp-~

June 2013 13.4-3 Revision 17

PVNGS UPDATED FSAR ~I 1 I REVIEW AND AUDIT 13 42.5 Thp Ciicnriim of thR PRB1, nerg'sarx; for- t-h Xparfnrmancp Qf H-)e PE"R rp'qpnnsihi t-xZ ;;nrl aiii-hcnr~ tx plrnui 'ý jr nn; r'nnta n~eH hprpn. -ghal1 rnnqi qt nf th)p r-haj rmn= ni- re-pqjgna-pci alternata =dH a maý=JntxL mf t-he memhirs nncluirnq ýltrn;;tpq-134Z.2 Thp PRIB gh;:;1 hp re pnngjh1p for-Pe~tPý-i nf ;ll prnponpdch rhng~'R ton l-h Tin-il- Tf-r'hnir--1 Sppnri fij rAtl rnnD~

hb -T-n-7-gt , i" - -i n c)f ;;;1 1 vj l:-;t n-n- nf -hp Uin-it Tpr'Hnr~il

~pfr~linn~ -nc.iicinq t-he preparat-jnn And- fn warrlj]2g nf x-Epnrts-C r -rvuerngý Pv-;ii- ,

1iitj nf and- rar-nranrnnclfitinng tn pDrnilTpft r~c-irrpnr'p to t-he Cffsi-e Safet-y Rgpiph Commli-pp (n~r~)-

r pPýTj pidj of PFPnfPT7LRTFI F\FNTq Ea h RF.PfRTABT.. 717ENT gh=i 1 1 hip rpir-i pidjpc hxr t-ho PPT:ý. and th-b rp-;lj 1 -- of tish ' rg-ujpl4

-gh-all hp -,ib-mjt-t-pd t-n t-hp rh;:jrm-n;: n. ffql tp CfIwPpuvpi~r Cnmm it-pp ;:md I-hp Site (rpnpr,ý] P1ýnI- M;:;n~pr-d- Rpaj-ipix nf iun t- nppraiti nnq tn) c1tt-~rt- pnit-pntlal~ nijmn] pir-

ý2 Ppm-fnrm,;nr-'p nf -pr-i-ra ri1v-uH pw- nip1 r ~ n nr ;n;;1 7Sp-c

nc1 rnpnrI-rt- t-h-)rpnn aq' ri-glmczt-pri hN ti-h jIP(np.1Pn-Man,;ar nr PMD, Ch~ti rmn;

n SRez,-w pzind nH cnrimpnt-;;t-j1nn of j limt-gmnt- connr'rnjnq prr 1 nnqpci oppn-i-Ii nn in 1-iwpaqq- r-h~qnnel ti-rp. anH./r r~pzýiir nf r~~pcI--i-ppr-ni-pr-i--in rc-hqnnplq n~f prn)-c;-n-;i~mh~~p~-r

-in7ryql ~n'pg tI-hg 1 q PRR Tnpptinrcf C ri P-L1 At 1r cc-pij1c- nfa ii-nI-h (ThnDC7M)fl ni~cj~

June 2013 13.4-4 Revision 17

PVNGS UPDATED FSAR --F017 PW.VTTF-1 ANT-) ATIDT h- w~r rnt~r o~r f the fol 1 ni n" rh;:ngn-- as -rngii j rprl Ihxy n-hpr pl ~nt rlnriimannh nr n-)rpui nii- rnr~mntnmi -mnjntq 85 C'h;;n"P tn the~ Prnrpq~ C'nni-rn] P-rngr;;m 85 Majn-r rh;:ngnq tn r1inri1r;rtjTp ]j-igiHr g;n1 nd 8 Ch;flmjns tn thp C'n-ra Prntprt-inn (Cýirji,1ai-ar (4Cpa) adrpsgahlp ronsctant-q as Hnscrihac at 12 4 1 1 1 8 rhangncq tn thnp sniibhmnr 13.4,2, Thnpp qh311 a pnnclr cntnrm jn;f--i nn -in wdr i--inq with reCg;rd t-n wh,-t-htr n)r not- Pirh -i-nm cnn~qi~lprnc iinrdnr qpr't-n 1-ý-4 9 F h rncyijr-irn

Ircnnq 1i ;=mpnnrmpnn1

]a Prn'ricrl r-i t-tnn nnt ifira't-i n widith-in 24 'hnirs ton i-hp exariii-j xii r(-i prnp idt-nt- ni~r'1 r Anri (.Nn, qnn 1nr ul rg p2prnc-iHpnni Sitp nper;;ioinn., ;nrl (1qTCr of cq-i egrppnmnnt-hetiapnn the 2EB and~ t-he s~iti-n nnnr; p1 ;nt- manarger;

'hnwdkNTm-r, t-Lhn gi i-P cgpnnnr1 p1 lant- m;:n;:;,r ~11ha1M-rp~pnn~-ih-i 1 i- for rpnqn1lit-i nn nf glich H-i ;;grepmpnt-1342 R Thp PPB gh~zi1 m,ý;nti-jn wdr-ii-in m-inuu1-n, nf nPirh PIRR m ,npt- -i ng i-T ~I-at r~n-imuir~n Hrinr-rMnn-rt t-he regiiu1-t- nf al1l PP.R r;(-ti ý -T1 1~ n :ppzrformad ;=icz ra-urpuirn 1w t-he prnu-i'-sionn, n-f

~nrinn1 4- 9 nýps qc

'h;:;I1 hp prnuidtcln tn) i-hn epyrijt- i p7 u-irp p rng ripnni niirl1 n;r manrl r-Nn. git i-n nnra 1 pla~nt man;rj-pr, ;=d i-hp OSRC.

June 2013, 13.4-5 Revision 17

PVNGS UPDATED FSAR F -O 7 PF.\TTR'.W AND ATDTfT 1.3.4..a~ TbJFYR.PP.NlP.NTRF\TT I ' ý 41 Tndpnnc-anti gaideNel pprforrnnCd by tba Cflfqlt1,

~fpn1-w 2 e37i ewCmmtte-~ (rlqP() Then-Fflff&1 qahfpt-%; Pp7Tnra Cmmittee is an Jnepnnrenn nffq1-n rnm~1-tt ton prnoj-rde tLhn axerlitiz '-~u-i r pre-i c-antn- mflu-pa~r anr-d C'nfl iduit1h an mch-pennrnt-P-32ij nor T~nii-ti-gp~rnnn asesmn af the P\TNGS ar't-izi~itj g-: nlA(r< nq pr-iLrtH ij aT_ nMph;:;Ri O~n ti-io~e actH l-gj nj Iýihý ih maýw af~fnr't- th-Ii long tei-rm safp and1rn1Tl npnr1-1n--in cf t-he far-jl~1- Tha CQRC' shall flmrt1ion ton prnur-irl inrlj~npdncnt rpn-ijpmi r-ind --

,hall he~

rnspons~hI p for- t-he aui~t of rinqi -jna1-nc zurt-i i1ila gn t-he un-bh-. ninicnear pnqJngi nnnring f- r-hemist1rxi and radi n'hgm~str-u-mrnnh~rjrnal andi nl nn1ric ný en;ng e n.A-J3-4-L2 The CYP'Rr shall cnnns~- of t-he OS~C' C'hairman and a rnin muojm of fn-F-i-r flPC:p rnmhn-Mbp-- The (Cha rrnn mnd~ membrshr a-p-dr-lni gnate-nr h~z t-he nynnu-it-i u wjr- nn prnirjpnt- numi-lz.ar andi END, aind shall ha-ii- t-he qualZ1ficat1-ins, tb-h;t- meet- t-he rnui-irEME~nt-, nf sp1-rinn 6,7 n~f ANST/ANq -ý 1- lq-78 June 2013 13.4-6 Revision 17

PVNGS UPDATED FSAR Ff- -4 REVIEW AND AUDIT 43-3 13 nrngii-tant-q gh,;ll he li1- 1izpc as Hatrminpri h-W Ihp (YSRr c~;: j I-nn prrnTi Hp pxpp~rI a{u71re i-Q t-hp nqPCR.

a_ Thip ;prngram Pqt;hljqhp in implpmpnt- t-he reapiiremen1s of

.in PFp 5nl )q In Pn'qnrp I-h;;t Ir-jwjt-jpq cmplet-erd linri-pr 1-hp prn~zslnns of Inl C'TF'R SQ-l h;;n hppn cnrrprtl-l Pvaliiat-Pr1 and detp-rMi npH- ton jnti rpiir 1:

lrpgnqi- ;qm.~mpnt.-

U.... Proposedr- rlh)ngc~p I-n eque~i~~Plipmpnt, qy1-Prn,-m- nr) 1 f~n -~ 1h,;t- -r-qg11jrp a 1 rprqe ,;mtpndf-rnpn ý- riffi npri in r~ 5fl 5q*

.~... Prnpnq~p- 1-pq1- o~r Pxpp~ri mpnI 1-hI- reur a li -Pc

Mpnc~mpn1- ;ý Hpfinpr-H -in Inl ('PR 5n 5c) d& Prnposprd rhanaes 1-n Tpchn-iral Spni f ratiomns, nr thp Qpp~r;d-jnq T~jr,-2-p-

p. j7jni qt- cn-, n~f rnripq. rprqlii ýt-jnnsf nrHrjp,-. Tpr-h-nir-;;

Sprf r,;t-jcnnq 1 iren r,-qil rpmnpnI-'q or n~f jnt-~rn~q p rnr-pcjlrpq or 1 fltI- iin1-t inn , h;;v nq miuna~ r q ýfpI-t

.rirnif r cnr' The nIqRC' Ch;;rm,-n Rh~li he nnt-jfipri wjt-hin 24 hnlirq of ;: Tpr'hnjr';:j qp-fjr1-A-jcnnfp Tjmj-i1

ýL Sjqn~fr'-ruin- n~p~r;:;--inc ;zhnn~rL2;;lI-j- nr rpgTijatinn'q frnu-n nn)rm;:; 1 nri -wpvp~rI-Pr perfo-rmance nf iin 1- Pcpj prn6-n1 1-h;=i-

- ffn r-t-nuni j ; fpI--w-

g. All RPQ.fRTA~TL,E FTF1'jTq rpqiijrinq 24 hnur'l-r wrI-1-pn nn1t- f-i t~-nnm June 2013 13.4-7 Revision 17

PVNGS UPDATED FSAR F-014Ii REVIEW AND AUDIT Al rrcgfl 7CindJ:;i ctH ~nq rf ;:in jjnant-j rjn pt-Pr crzfi r~ipnr'w iTn somp a sper1 nf- desgn cLr cnperat1- on~f st-rlciir-,Rp, systems Qr rnrmpC~hpaLt-S t-hat - rnlH wffpr-t njjr-P,-ýr --AiFPt-x7 j B ýPpnrt-s :nH rnppt jnr Tn nnit-eS f thp 22B.

5 uir111-q rnf unnt aC~tiazite shall hp performed. iincar t-he CQ--i7anrn Qf t-he C)SERC T-hP mqiri-j pi-nrnrf~ S~rrpp i Hn--bJc n_ pczrr- jn)n 1~ 4! ý 5 L3~2-~ The QYqRC sh~11 -r~pKnrl to and~ aduT1e- the exerlt-i NTJ rP prP--i c]PTn1- f mr' IP;:r An H ('NQl ., n thn'sp r f respcmnsibhity- p~'fP in 13.4-3.4- and 13, 4 2 ,

j -ý ~ Rpr'nrrd of (YS]2(' aziui1-is shall hP p-rp;:rPH and mn~q1 n f-A j nPcl Peport of rpuipsa andI Aijcj--i qhal he fortki~rclpr to t-b-h Pixprutii Ip -- i re pre cside n-TTn. rjtICflajn1- wlp - ýi CLrihubition t-n 1-hg. -ln;ýqemenI pnq 1innS r pnnncjhja for t-he i ý3.R, 4 AlI al tpr~n;:tp mPmh-Prcz ghall ]hp ;:mnni ntpH j iTrj - ng hiiT t-hg r)qTRC' hr-ii rmn t-n -iPrr6-p nn -empn~r;;rN7 h a i hnuiP-N,-pr nn mnre t-han 1-urn ;ntI Prn;:;-Pc -h~l1 par jr!-i-'pat-a 3Ec 12inq m Pmb Pr-: in tr1i 3T t i e S cl~C at: anxi one-P t-im

'h The SR(' hA I I -m~pt a1- 1 paic~ Onn'P ner sj v munnhq 1 3.- .J3.OLa Thp qimnrim oif the QSRC. npc-'p'ssarx Fn-r 1-hP P Prfn-rM;:nr-p of 1-hg QqERC' rpi-i pi6 ;:ncl .r ii 1- fiinc1- I nn 'r nf 1-2 4 2ý gh1nqnic j-q n-f 1-ho Cai rmaij n)r his d-pcje-gn~tPrl ; 1 1-rnatPr andI June 2n013- 13.4-8 Revision 17

PVNGS UPDATED FSAR 112-FO14 atl 1]Past fcmiir nqhRC" mg'rnbprc; n-rl ldcing q alternates- Nnc- Tncrp th),:n mi-- r ý-F -r F~ -F- 'k, - 1 -,-r, .1, 1 1 ýns,r m - I ý -- -a nrr --k +- ,, -Fn np~raM-Jnn of l-hp init-13.4 . TNDRlPETMDFlNT qAFFETY RFj7T7W' 14 1 Thp Nlirlp;:r ATc~~~np lp;:rtmpnt R'h;:1 1 prfnlrm i ndeppndpnt ýq;:fptx, TpI7i piwi TnHdppncjpnt cR;:;fpthw reall ~1

-,h;: 1

-,e ert- j3L- wTPrx=m-np pl :;n-I- rlpk-r;:t- Jnq r'h)arac ,r j -qt~-i r LIP('

jSn1nc-. jndifl'P C 1fll1tr~ r-'\ qrjs Ioi rpn cpp

-C11P~T FiTpnt 'R~pmr:Lh -n Ot-hprc goir1rr'pS n-f pl :;nt r1pqjcn ;:nc1 c-iprr~tH ri Pyppr-1pnrp i nfc-rm;ýilinn. in r-]nrjjn p1,-nt'q c-f qi~mi 1,r d-psjgnf jh-irh m;:;

i nHi r;tps ;:rp;:; fc-r jiýrmfr j-~Ing I1 ~nt c;Afpt-x7,

]-ý. 4ý2 Pprgnnne] -:;SS"-D2 t-c- ppc-fc-rm Jnd~ppndpnl Rg:fpfh rpvu pIgj gh,-q 1 hp 1 ncýt-pc onnsi p ;:nH- g'h,ý 1 mgipt o-np oif thp fc-il1 wjinrj ml nimnimn PcHii,rýtnn aind ex;prc-ipnc-p rprq, ram~npi-~

8 A 'Rm:;rhplnr-1r' flpgr6F JIn fPnnp~rjnr or jn rp];:;tpH fik-Iri jdit-h ;:t- 1 pit ý xp;;rc c-f c-pl;tr Pxpirr 8 Zlt- 1 n-qt- R i7P-ar-- o-f rp1 Al-pri v--wp-rj,-nr-p, 1 3.4- 4-3 TnHpýp~nd~nt s- fpti w cpiv pmicq qh:; 1 1 c 1,-

nrl

.,iirupi 11 ;;nr'. c-f se] ece pml ant- arl-i 7L l-i Ps ton delt-p-t- pct-ptntJi ;1 LuiC-1 t-r 'c~afpl-w b7a rcl g to- pc-flirT Hp j -ncHpnHpnt-ug-rj fi r'-;t-j c-n l-hinil i:rt-j77jt-jpg -;rp ppc-fnrmpd rCnr-rpct-l-,7 -, t-Cl prnu-ic-p r-r-nmmend,-Lýl -i-nq fc-r rpHiirinC rig hiM~n Prrrc--l- Aq miirh n;Iqc prinict i rpl Pprcinnnpl iciciignP-H l-c perfo-rm indppp~nHtnt- ciinifpt-x;, rp7pd- -ih~ 1 hri-ip ;iric-pqsc tnc-i l-h ,n l- ;=nH u lt- -rpc'rc-rlc ;;i. nprpqcig:rx, tc-ri pDerfn-rmn pirTaul'aUnnc and aggpcigmenl- Tnc-dppnrizint- Ramfpt-l7 -cpuiipil inir-t-!' ic-i--i p cZ!hil 1] nci- nc-l1uuc-= c~i-i-n-c-i-Ff -li, u-'h l-I~-) -

Qllc-nll June 2013 13.4-9 Revision 17

PVNGS UPDATED FSAR 12F1 RFXTTF.Wd A~ND ATIflTT t-hnoqp pprc-onnno1 ;:-icjnpc1 to Dperfnrm Jnc~ppkncj-nI- safp-t-w rprTipldg bprrom- *1 nTl TPHC in thp nppr;:tjing nrqgýni 7At nn 13 4- Wri I-I-n rprorrV'g of i nCopopnrig-nl Safpt-v;, rpujf~w 014g 1 hp majint.; i nor As~ ;: mi n 1 rnnm Ihpqe rprnrcls shal1l i nr-iiirip i-'ho roilt~of ;:irt-jN~t-jio- roncliurt-k-HI anu~ rpronmmpnci~t-ionnq Tnrn~ip ;nr1 ARcoSR~npnt nf pl gnt npgor~tj nn rol ;=iýP tn' th-h rpvi-i o-r Dp L fLormpd 1'li-ý 4 4- on~i rornmmpncliti nn for roy-ised- prcrocdiirps, ogiiipmon-t- moli fi r,;-i nns. mai ntonpn;ýrr Ac-tiv-i ti-o , np Pra t-i on~

cir-ti ~ritij--. ocr ot-hor moans cn f Jmproazi nq pl ~nt- - fi-tW th-ht-ropvilti frnom jnrlp;otnc~nt rpfoi-pvro-- s hall1 hp fo-rjg;rdpdr tm t-he Tpzn~gpmoni- pogi ti n rp~ponni hi for i-ho arcori roluiporon Siimm a ryz ropnrt-q of i nciopencdoni q afotw revi P a~rtp--i ul t-i Pq And~ i-h

-,tAt.ll-i1' of -roqiiliinq recommendations Rh~l1 hp fonrigýrdpHc rpoii n i r- 11 ~ to) t-ho axtor,,t~ ITO i prpc. i cpnt, olnu-' 1 oýr Andl('f ancLd i-ho Clh, jIm An .- ffc-,ito S=foi--N7 ]2piouj l CoQmmj t-t-,- (flnRl) 1j34-a Z\TIL1TT PpncYpAm A nompri-hen- ji T prograrm of pl annt-H And1 cio~n'i,mont-o ýii~itg I 1i r,; rn-iH nijot- to vnorifw romrpl Lance uiiI-h, ;;ndIofntivn~ of.

imalmpi mntat-in of i-ho ;rlmj-inij-crt]Z-juL- corntrozls And QA I:)rogru;m Ancl to Aq-qji t~-ihe Cflff',itI Polni o,-3 fLOmmi i-i-o (flqpr) in i-he oyon-'iti on of L -s rpcpansi hil1 i fo~r i nloppnpnioi rpujpioud of opporatinc ;;i-tiH~ ti Poq i-h~i Affect nunr Par ;:ft-The aliHi t- gunopo q'hA 11i nr'lunio~ t-hro.;i prrogram Aro;i ;=;iuci i-q roguij red hy; rpqiil Ati- on or rtoguuIl ~torw rrTrnmi i-mont Aluiij i-q of thE!

p -rngr:am ArgoA 'dpor-ri hon in i-hi qu sori-i on -,)a 1 bph porformk-i at Au June 2013 13.4-10 Revision 17

PVNGS UPDATED FSAR FY -4 RP\JTFW AED ATTlT~

frpcgiipncr nn-t- to excee 24 mcan1-hsc more fraqjj1-nt-N ;--

pprfnrm~anrp drl;ýtg c r aq nntpdc 1-n mppi- q;p~C-.fj c-'r~cpjl~zl t1- c-)

n-r c-'nnmi hrngntq' a...Ther pprfn-rmn~nr-ý nf ani-t ju 1-H -. rpgli rPH- hw, 1-th n-ppr,;t- rnna 1lnc-pr~nfl append1ix 'g b.. Prnq-r;;m- for cipra~z ponnc mnnjt-ncj--ncg prm=imry7 c-'n~nl ant-csrnilrrp', miit-'c-b,il of r-nn1-a nm-nt.- and- 1-hp hac'Viip mF1-thrc- fcnr Htr~rn-in-in ýqiibc-'njnqn m~c-gin as dec1r ihed in T17AR 13 H... Th)p Prncpqq~ rnn1-rn] PrngrA~m ;ýnc1 j rpipmpni- nq-procedu~irpcs fn-c- p-rnn-pqqnc-j ;:nc p;:;-.kaqg- nc--f rAH nar1-tup-P, Spcnnd;ýrw7 ThL:1-r Chpmistr+/--r Pi-nar-m rlpqp-rj1hp- in th-h lininh1 t-pCrhnc-;:; c~pt-(-jfjr,;;jnnq f The ~-i1-n Prntlrnc-'trn Prcngr,-m anci~1h Tn-P1;n1-P;:;r31Ainn Mnni1-nring Prng~r;:r dprrBhi -in TIFSAP 1 h The rnnfc-rm;:nr-'Pz rf unit- operat1ions~ ton 1hp pro-vsTisio1nns L_ TChp pprform;:nraP i-r;ýtn-ing. and- "nujific-1iann of -hg ,unit-Rpqiiul 1- of ;ýrj- nn, ta~ken to corrct'1 H-pf c-H nc-Hq orn-rii-'rrH nc jn uint1 Pc-pijpmt-nt1 gt1-riur-t1-urt-c- -,w7qt- mqf n-c mp-h nci-i ruf June 2013 13.4-11 Revision 17

PVNGS UPDATED FSARI RBX7TF.W ANDl AUDFIT 8 fffs~ tC' ~r Dos (aciu i-ainn Manua1 anr mpi mpLitng 8~ r~rtiuT~ ffi ianit C'runt-rrui P-rrugr;:m ;.- Hje'-r~rihad ic t-he ij]21- t1-~r'hnir-Al cpzn.ni-jfi1H;runS 8Rr~u~ugr'i na jrcunMpnt-;iý Moinit-crirn" Proragm ;:;nci 8 he pzerfcrrmAnr. of acthiazi ties reguu rza hy the gu1'ait Aq-uir~ruc'e prcrarrm faur effiuie.ut--- andH en-uuiru-unment-.a mruni jtcr-rl n tcr meet- t-he Xprmz js ns ruf NBC rju -uw G'iIHcle 1 21 'Reizisrun I Jumrp 1974 and NIRC' Ppcjiu1:itnrur (Zr~ 4 1F PINTqinrn I, 7\,ril 1Q)7c) jL Spriurihxy andH Saelars Cnrn1-ingcnr.w p~rnugr;ým- pý-r ifO CEB' 732 5(m) inl (-Tip -7,; 7pppnr~v r- AnH IQ C'T'R (24)u- atl leas) ccu- -vw 24 mpunt-hq. rur mnrpr frrI P 1)t 11W wih)P n tou mnpp+/- thp-cur reqij 1 at i ons M- 7jj-npqc-frur-Hujtwz (771D) pr~rugr~z~na re~lui~re hýy 1n C'FB 9(;.41 and 2e.203(f)

T)PT'merrfpnr\ 121a~njnq at- leap~t runC' elzer-x; 24 monrthuq jui rurj thg-1 pefrac-ae ruptirun permittedu~ W IQ CE~R 50,l Apprandv E. and 20 CEPi' 5n 54(t), rur Torpr fraquucantlz lahpn ni r-u-qqA-ru Th,ýct-mtn -rýcn,1 ;t1run'--

June 2013 13.4-12 Revision 17

PVNGS UPDATED FSAR LI I'IJ--1 RmI'\TFW ANDl AT1V1TT r). Thp Fi rp Prnti-~rt i on Prrocjrprn ;: -, f nl 1 ntid.,

15 Trp prcnt-6,r't I n Pcji1Ip-mpnt -;nd-p-rng-rp~m jnt-l irhng Impi pmcntH ng prrcr'pdil1rp--, hN7 gli;:; fjpi MNilrli A 7AcSir;:nc., p,-r-qnnnpl int-j1 71fl0 gjt-+/-hpr pi;i~l fi ,cI n-ff~-i i-t 1 ppr~nnnpl Or alD Ovl-Itscd-1 fi rL p rntprt, rn r-nn'gillta~nt, ;;it-1 g.-gt- nnrp ppr 94 mront-h-,

P1 Frp prnhcprt- rn equi1lpment ;:ild pz)rmqgr;m jmpl ampnhtati li~t-Ji 7jin ;;n nih,~fi re prchlrerti nn . t-A~ll1l p_... ZJnyý ar rnf unit- nppr~t- r)ID Crc~n2-i dprpc ;:pprcnpri ;;- bN7 thh CflqPC' rr thp i-xir'iii-Ju 77L1r presICApnt., niirl aqn1Cf gr;ýIp A pri c-v- n-f qQf cHav- hxi-wd t-he -c;p~rifi PH f rpg11Pnrx7 1 q~

pp~.rrnjtt,- frnr (-M;plt+/-lcn of infr~rnal rnc-ijdct jhn 1-hp 1)p-r~ndis 1tli7il(ld siihcsgiant --chcluiIng fo-r t-he amridf1 ~ha 1 Aid- Its a~rp pe rfor-med- In a rcrnrcanc w~~itih apprnn-pri proredu1rps,'

AlijiA - ;ýiggI gnmpntni- ýr -,iirh thhýif t-hi ;;iit- t-p;;m mpmThi-rc; w-il1 nnt Dp~rfrvrm ;urjjtc;1- nf ~rIv 1p~frr iaihi h 1-hp~ ' h;:-Nr irnmpdli :;f-g Wri t-tpn rppnjrf-, n-f ali~cj tq art- read P~irzed bx7 the flPC' and h~z

-- ýprnrla-f Tmpmnhrq of m~nagamernt, i nr~ml iinq fthrc-gv h;:;NI ng

-rpqprn-qIbilit-w In t-h,- Ar; ýijcjjt-kri 7\"rr~pr11-p andI ti-in14 frnlr 1 z-ii-1p ;(.trt n.-n j nr-IiiciI ng rpauiit o-f rit-fi ri ent- Al- as June 2013 13.4-13 Revision 17

PVNGS UPDATED FSAR 112-FO14 2717TEN. 8ND ALOOT apprompr-iate.,Js takpi2 to~ engiire cvuprzll Pffecrtiue(ý-; cf r thi-r =jidi andl audit- - pro~gram- Spc-prjfj r'- Izap ramplnts fol:

jmpi e-entzat In nf 1-hp ;aiiHli n-rnqra for t1hp nnp~r;1-it nn ph,;.q are dIcrisissed i 1he tr O~perations QA Prnr~q;=m (,TT~ql\

,Pr1-:i nn1 9:.)

June 2013 13.4-14 Revision 17

12-F014I PVNGS UPDATED FSAR 1

' The PVNGS Operations Quality Assurance

rogra____ Description (QAPD) 13.5 PLANT PRO RAMS AND PROCEDURES Ths sor'tinn escribes administrative and operating procedures that will be used by the operating organization to ensure that routine operating, off-normal, and emergency activities affecting nuclear safety are conducted in a safe manner.

The a*nm !Sn-tr",-Tfiz* p r'pfr-e11:E.r , frljt P..Q "Tprrj IHi-Niir1 ar. *prnpr-t-inc-Stma nn (PHN7N() aijll hp- rcnnjsitnt- an-i h rrnmrnn-licti nns rnnained in RCglllm1nry (uiritI 1_33. Appendix A. as dcisiissed in r*i-Lnn 1,R and th Itnit rhnir-._l nPifirCatiLnnc_

1.51 PPREPAPATTCZ1N D' PR20CEDflRP-Engni

ft gtation sllprirs*l"T ,crcl, a

r -pnnnSib1P for initiatinq, p_ rPar' ;I control 1inn station prnaceHlre consist-Dt i*d- h thpir rcponn--i hiljt-i p -n-d for ensiiring that wor!k is p~rfnrm):c in ;:nrHrrd nC: i Idt-h t-he 1 *i-pI -ppl i rdhl

prirn rCnmiiMpni-2ri~ai of t-hpp proc~duirps Js armplishpr1 hx7w qft;t-ion gt-;-ff par)-nnn l7 rpNi-jpdl fornmirlp p r

S7qfPtV wyrtS - taji 1 1 as*

dcerrihbd "n ser'Iinn 1? 4.

3 5_1 -1 ThE senior uirp president, sit-e operat-ionq, or his desi jnee t~~11~c~~p1hat-Pairh pror-pciir-e ;;nc ~r~ogram -rprfi i r,s-rl hxz T-chni ra 1p.r-ifi -t-ions, or nt-hpr prnrchirps, which affprf-niiclar .fpI-ey anLd chang.qe t-har~no iL prpartp- by q 1f i rIl incuiidull 1./orgmni7it-inon Fc-h iirh prornedlure: anr changpg therpO- .q 11 }ib rpvi ý :ipi::- h1 ýn i nci

- i iT'dlI/ 1 /girnip on-hpr than thp inAirirdlii.1/g-r'olp wahich pren7papr tbh prnr~cl1rl, or rh:ngPg I-hprtr. -hilt ulho may hE! from the .q~mp ornqni 7n-ionn q f-hp incldi~ri ./grnolp twihirh przparel i-he proredcur or rhangPe n

there*_o June 2013 13.5-1 Revision 17

DELETE PVNGS UPDATED FSAR 12-F0 1i4 PLANT PROGRAMS AND PROCEDURES 3.5.1.2 Each program or procedure, and changes thereto, sha be reviewed as specified in 13.5.1 and approved prior to impl entation. Program, administrative, and implementin proced es shall be approved by the senior vice preside t, site operation, or designated alternate who is at supervi ory level or above.

13.5.1.3 Indivduals responsible for reviews rformed in accordance with 1 .5.1 shall be identified i station procedures. Each s h review shall includ a determination of whether or not additio al, cross-disciplnary, review is necessary. If deemed ne essary, such eview shall be performed by the appropriate designa ed revie personnel.

13.5.1.4 Proposed tests and e riments which affect station nuclear safety and are not ad re ed in the UFSAR or Technical Specifications shall be reviewed b the senior vice president, site operations, or his signee.

13.5.1.5 Programs a procedures shall b reviewed periodically in ac ordance with the provisi ns of the operations quali y assurance program (UFSAR 1 .2) as set forth in administratve procedures.

13.5.1.6 emporary changes to procedures above may e made provide.

a. he intent of the original procedure is not altered.

b. The change is approved by two members of the plant supervisory staff, at least one of whom is a shift manage June 2013 13.5-2 Revision 17

E2EFT014E PVNGS UPDATED FSAR PLANT PROGRAMS AND PROCEDURES or control room supervisor with an SRO on the affected unit.

c. Th change is documented, reviewed, and approved i acco dance with 13.5.1.2 within 14 days of imple ntation.

Temporary ch nges to station procedures will be go rned by administrative controls in an administrative con ol procedure.

13.5.1.7 Phase I IV tests described in th UFSAR that are performed by the pla operations staff sh 1 be approved by the Department Leader, ystems Engineeri g or individuals designated by the executi e vice presi ent, nuclear and CNO.

Test results shall be appro ed by t Department Leader, System Engineering or his designee.

13.5.1.8 Administrative Proc dur The following are descript ns of ad inistrative procedures that will be prepared fo PVNGS:

A. Procedures fo Shift Managers and Operators

1. Senio reactor operator's autho ity and res onsibilities Describes senior reactor operat r's duties, responsibilities, and authority.

Reactor operator's authority and responsi ilities

a. Describes the reactor operator's duties responsibilities, and authority.

June 2013 13.5-3 Revision 17

DELETE PVNGS UPDATED FSAR -1*§UI iZU PLANT PROGRAMS AND PROCEDURES

3. Conduct of operations

a. Procedures are written to implement the administrative requirements of the Techni al Specifications concerning licensed pers nnel on shift. These procedures will incl de provisions of 10CFR50.54 (i) throu (m).

b. he "at the controls" area of t control r m is defined in Palo Verde rocedures.

B. Special Orders f a Transient or Sel Canceling Nature Special orders wi 1 be written to ssue instructions which have short-te applicabi ty and which require dissemination. These rders 11 be reviewed on at least an annual basis fo t e purpose of purging and updating.

C. Equipment Control Proc dures Equipment control p ocedures ar written to provide control over the atus of station equipment, purchased material, and n nconforming material Such procedures will include:

1. Work uthorization

2. Co trol of purchased material, equipmen , and

ervices _

3. Handling, storage, and shipment of materials

4. Nonconforming materials, parts, components, or operations.

June 2013 13.5-4 Revision 17

DELETE PVNGS UPDATED FSAR 12-F014T PLANT PROGRAMS AND PROCEDURES Control of Maintenance and Modifications Maintenance of equipment important to safety is ccomplished in accordance with written procedures Ce tain minor maintenance actions of a routine n ture, the erformance of which is covered in the nor al job qualif cation of the performing personnel, y be accompli ed without written procedures. uch procedures re described in paragraph 1 .5.2.2.

Modification f equipment important t safety is accomplished in accordance with wri ten procedures.

E. Surveillance Test chedule The surveillance tes schedul is based on the surveillance requireme s e ablished in the Technical Specifications and provi s means for tracking the performance of the surv il nce tests.

F. Log Book Usage and C trol Log book usage an control is in orporated in instructions to perators covered der listing A above.

G. Temporary ocedures Temporar procedures are issued as require to provide instr tions for certain jobs that are of a imited dur ion and of a one-time-only nature. These p ocedures are reviewed in accordance with June 2013 13.5-5 Revision 17

DELETE I PVNGS UPDATED FSAR 12-F01 PLANT PROGRAMS AND PROCEDURES H. Fire Protection Procedures Fire protection procedures are written delineating he fire protection organization and programs for fi p evention and fire fighting.

I. Cran Operating Procedures Admini rative controls governing crane eration will be establshed prior to fuel loading ad will include a requirement that crane operators who operate cranes over fuel poo will be qualified nd conduct themselves in a ordance with t guidelines of ANSI B30.2-1976 (apter 2-3) 13.5.2 OPERATING AND MAINTE AN PROCEDURES 13.5.2.1 Control Room Operati g rocedures Procedure content and forma for ope ating and emergency procedures are in accorda. ce with Regu atory Guide 1.33, Appendix A, as discusse in section 1.8. Classification of procedures that are rformed by operators n the control room are as follows:

A. General perating Procedures - Procedure that provide instr tions for the following integrated erations of the lant:

1 Cold Shutdown to Hot Standby

2. Reactor Startup

3. Turbine Startup and Generator Synchronization

4. Power Operations June 2013 13.5-6 Revision 17

,*--*DELETE wPVNGS UPDATED FSAR 12-F014 PLANT PROGRAMS AND PROCEDURES

5. Plant Shutdown to Hot Standby

6. Operation at Hot Standby Hot Shutdown to Cold Shutdown

8. Refueling and Core Alterations B. System Procedures - Procedures that provide instructions for ener izing, startup, shutdown,, and ch nging modes of operation the following systems imp tant to safety:

1. Reactor olant System

2. Control Rod rive System

3. Shutdown Cooli System

4. Safety Injection stem

5. Essential Cooling Wa er System

6. Essential Spray P d Sy tem

7. Containment Ve ilation Sy tem

8. Spend Fuel ol Purification nd Cooling System

9. Main Ste System

10. Feedwa er System

11. Auxliary Feedwater System

12. ant Cooling Water System

13. Turbine Cooling Water System

14. Nuclear Cooling Water System

15. Chemical and Volume Control System

16. Auxiliary Building Heating and Ventilation System June 2013 13.5-7 Revision 17

DELETE PVNGS UPDATED FSAR F12-F0 14 PLANT PROGRAMS AND PROCEDURES

17. Control Room Heating and Ventilation System

8. Radwaste Building Heating and Ventilation System

19. Instrument Air System

20. AElectrical System

21. DC ectrical System

22. Emerge y Diesel Generator System C. Abnormal Oper ting Procedures - Procedu es that specify operator action for restoring an op ating variable to its normal contro ed value when i departs from its normal range or to r store norma operating conditions following a transient. The fo owing are addressed:

1. Loss of Instrument Ar

2. Loss of Electrical we

3. Loss of Condense Vacuum

4. Loss of Cooli Water

5. CEA Malfunc ions

6. Emergenc Boration

7. Fire *n Control Room or Forced Evacua ion of Con rol Room

8. rbine and Generator Trips.

9. Malfunction of Automatic Reactivity Control stem

0. Acts of Nature

11. Irradiated Fuel Damage While Refueling

12. Excessive Reactor Coolant Leakage June 2013 13.5-8 Revision 17

DELETE PVNGS UPDATED FSAR 12-F014 PLANT PROGRAMS AND PROCEDURES

13. Reactor Coolant Pump Emergencies

14. Loss of Letdown Flow 1 Loss of Annunciators

16. ain Feedwater Pump Trips

17. Man Condenser Tube Rupture

18. Inad rtent Engineered Safety Featu e Actuations

19. Loss of eating and Ventilation stems

20. Loss of Sp t Fuel Pool Cooli D. Emergency Procedure - Procedure that direct actions necessary for the ope ators to itigate the consequences of transients and acci nts at cause plant parameters to exceed reactor protect"a system or engineered safety features actuation setpo' t or transients during lower modes of operation. T e foll wing conditions are addressed:

1. Standard pos -trip actions i the form of safety functions

2. Reactor Trip

3. Loss of Coolant

4. S am Generator Tube Rupture

5. Excessive Steam Demand

6. Loss of Feedwater Loss of Core Coolant Flow

8. Loss of Electrical Power June 20l13 13 5-9 Revision 17

DELETE PVNGS UPDATED FSAR 12 I PLANT PROGRAMS AND PROCEDURES

9. Loss of Shutdown Cooling Operators will perform emergency and recovery procedures as described in the procedure gen ration package submitted to the NRC in accordance with LLIR, Item I.C.1 (NUREG-0737 response)

E. Alarm sponse Procedures Alarm res nse procedures will be index according to main contro board section and alarm odule number.

Each alarm pro edure will also in de exact terminology of the alarm win ow.

F. Temporary Procedure Temporary procedures 11 b developed as needed and will be for a certain jo and duration.

G. Preparation of Procedu es Required operating ocedures ill be available for use 60 days prior to el loading. he development of most operating proce ures will be comp ted prior to system testing so th t these procedures may also be tested.

13.5.2.2 Other ocedures Other procedu s are provided in the following are s:

A. Sta ion Radiation Protection Procedures ocedures for personnel radiation protection sh 1 be prepared consistent with the requirements of 10 CF Part 20 and shall be approved, maintained, and adhere to for all operations involving personnel radiation exposure. Station radiation protection procedures are June 2013 13.5-10 Revision 17

DELETE I PVNGS UPDATED FSAR PLANT PROGRAMS AND PROCEDURES designed to limit and control radiation exposures and the spread of contamination as well as to meet the requirements of 10CFR20.1001-20.2401 and ALARA p ilosophy. Radiation protection procedures ar dis ussed in subsection 12.5.3.

B. Emerge cy Preparedness Procedures Emergency preparedness procedures are povided to implement t e provisions of the emer ncy plan (refer to section 13.3) . They provide for a ignment of responsibilitie instructions t employees, procedures for coping with e rgencies, ad mobilization of offsite assistance where nec ssary. Procedures in this area are detailed in the emerge cy lan.

C. Instrument Calibration n Test Procedures Instrument calibrati n and tst procedures are provided to detail step-by- tep methods for calibration and test, acceptance crit ia, and testing intervals performed by instrument pe onnel.

D. Chemical-R iochemical Control Proced res Chemical radiochemical control procedure provide for instr tions to accomplish various chemica and radochemical analyses, sampling techniques, nd to m intain coolant chemistry within required limi s.

These procedures apply to work performed by chemi try personnel.

June 2013 13.5-11 Revision 17

DELETE 12-F014-PVNGS UPDATED FSAR PLANT PROGRAMS AND PROCEDURES E. Radioactive Waste Management Procedures Radioactive waste management procedures provide

nstructions for the handling and processing of ra ioactive waste. These procedures apply to tation oper tors and others who are involved in han ling radioa tive waste. Procedures in this are include the procedur s that implement the process c trol program and those ocedures for:

1. Gaseous adwaste processing

2. Liquid radw ste processing

3. Radwaste soli *fication

4. Solid radwaste ha dli g

5. Radwaste shipment Changes to the Proce Cont 1 Program shall become effective after re iew and ac ptance by the PRB (refer to subsection 13.4.2.6.h) and ap roval by the radiation protection ma ger.

Documentati n of changes to the Proce s Control Program shall co amn sufficient information to support the change ogether with the appropriate anal es or eval ations justifying the change and a det mination th t the change will maintain overall conforma ce of the olidified waste product to existing requirement of Federal, State, or other applicable regulations.

June 2013 13.5-12 Revision 17

DELETE PVNGS UPDATED FSAR F12-F014 PLANT PROGRAMS AND PROCEDURES F.. Maintenance and Modification Procedures Maintenance procedures provide detailed instruction for the accomplishment of important maintenance funct ns as w 11 as for major evolutions performed by stati mai enance personnel. Procedures for major epair or repla ment of equipment and schedules for reventive maintena ce are provided.

G. Material Co trol Procedures Material cont 1 procedures are dev loped to provide for procurement, doc mentation, and ntrol of those safety-related materials nd componen s including spare and replacement parts ne ssary or operation, refueling, maintenance, and modifi aton.

H. Station Security Proced r Station security pro edures ovide for the implementation of he security lan (refer to section 13.6).*

I. Not Used./

J. Fire Prote tion Procedures Fire pr tection procedures are provided t instruct app> able station personnel in methods of .re pr ention, fire fighting, and maintenance of ire rotection equipment. Procedures provide speci *c instructions to members of the fire department in ire fighting techniques. In addition, fire protection procedures implement the fire protection TLCOs, Action June 2013 13.5-13 Revision 17

DELETE PVNGS UPDATED FSAR 12-F014ý PLANT PROGRAMS AND PROCEDURES and TSRs contained in the Technical Requirements Manual (TRM).

K. Settlement Monitoring Program Procedures A ritten procedure(s) shall be established, impl mented, and maintained covering the Settl ent Monito ing Program implementation. PVNGS sh 11 maintain a settle nt monitoring program throughou the life of the plant accordance with the progra described per Section 2.5.4 13 or another NRC appro ed program.

L. CEA Reactivity I tegrity Program P ocedures Written procedure(s shall be e ablished, implemented, and maintained coven the C A Reactivity Integrity Program implementation. P GS shall, after initial fuel load and after each relo meet the applicability requirements of the NR appr ved Startup Testing Activity Reduction Pogram (ST ) described in WCAP-17787 or per rm worth meas ements of all full-strength CEA gr ups to address Section 4.2.2 of the PVNGS SER dat d November 11, 1981.

M. Fuel Asse ly Surveillance Program Proce res A writt n procedure(s) shall be established, impl ented, and maintained covering the Fuel ssembly Su eillance Program implementation. PVNGS shal erform a fuel assembly surveillance program in conformance with the program discussed in Section 4. 4 of the PVNGS SER dated November 11, 1981.

June 2015 13.5-14 Revision 18

DELETEI PVNGS UPDATED FSAR 12F14 PLANT PROGRAMS AND PROCEDURES N. In-Plant Radiation Monitoring Program Procedures Procedures will be provided for implementation of the n-plant radiation monitoring program. This program wi 1 ensure the capability to accurately determine he airb ne iodine concentration in vital areas und acciden conditions. This program shall inclu e training f personnel, procedures for monito ing, and provisions or maintenance of sampling an analysis equipment.

0. Procedures for th Backup Method for etermining Subcooling Margin Procedures shall be pr vided an maintained for a program which will ensur th capability to accurately monitor the reactor coolan system subcooling margin.

This program shall inclu e th procedures for monitoring and the training of pe sonnel.

P. Spray Pond Monitori g Procedures A procedure(s) s all be provided for program which will identify nd describe the paramete and activities used to con rol and monitor the essential pray pond and piping. he program shall be conducted in a cordance with s tion procedures.

Q. Rad' active Effluent Controls and Radiological E ironmental Monitoring Procedures Procedures shall be provided for the radioactive effluent controls and the radiological environmental monitoring programs described in the unit technical June 2015 13.5-15 Revision 18

D4ELETEI PVNGS UPDATED FSAR PLANT PROGRAMS AND P ES specifications and t ose Calculation Manual (ODCM).

June 2015 13.5-16 Revision 18

12-F014]

PVNGS UPDATED FSAR CONTENTS (cont)

Page 17.2 QUALITY ASSURANCE DURING THE OPERATIONS PHASE 17.2-1 17.2.0 17.2-1 17.2.0.1 Quality Assur.nce Program Policy 17.2-3 ORCANIZATION 17.2-r4 17.2.1 APS Chief Executive Officer and President 17.2-5 Executive Vice President, Nuclear and CNO 17.2-6 17.2.1.1 Senior Vice-President, Site Operations 17.2-7 17.2-11 17.2.1.6 Vice President, Nuclear Engineering 17.2.1.2 17.2-11 17.2.1.7 Di:rector, Nuciple-ar Assuarance 17.2-13 17.2.2.

17.2-12 QUAL!TYTm ASSURANCE PROGRAM 17.2-19 17.2.2.2 172.2 17.22.1 I17.2-19 17.2.2.3 Qu=alty Assurance Scope 17.2-20 17.2-23 CrddApproGach4 17.2.2.5 17.2-25 Three- Level Assuarance App-roac 17.2-28 Control of the Quality Assurance Plan 17.2.2.6 Quali,4ty AsrneProGgram Review 17.2-30 17.2.2.7 Tr-aining andQuaiicto 17.2-31 17.2.2.8 Quality Classification 17.2-33 June 2013 1 7-v 7Revision 17

Fl 2--

F-0 174 PVNGS UPDATED FSAR CONTENTS (cont)

Page 17.2.2.9 Safety Reviews 17.2-35 17.2.2.10 Conditions Adverse to Quality and Corrective Actions 17.2-37 17.2.2.11 External Organizations 17.2-37 17 .2 2.12 Resolution of Differences and Escalations 17.2-38 17.2.3 CONTROL OF STATION ACTIVITIES 17.2-38 17.2.3.1 Policy' 17.2.3.2 Design Control 17.2-40 17.2.3.3 Procurement Control 17.2-45 17.2,3.4 Identification an C;otroL o MIteral Par~ts, andl Com:poenets 17.2-56 17.2.3.5 Control of Special Processes 17.2-59 17.2.3.6 Test Control 17.2.3.7 qtrol f Measuring ad Test EqU.pment 17.2-65 17.2.3.8 17.2-70 17.2.3.9 17.2-73 17.2.3.10 Housep~keepi.ng and-Cenlns 17.2-77 17.2.3.11 Control of Construction, Maintenance Modifications 17.2-79 June 2013 June 213 Revision 1 Revsion 17

PVNGS UPDATED FSAR ~j~14 CONTENTS (cont)

Page 17.2.3. 12 Control f SuvilneTeSting4 and4 Inspect ion 17.2-85 17.2.3. 13 Radiological Control 17.2-88 17.2-90 17.2.3.14 Control of Radioactive Waste 17.2.4 CONTROL OF QUALITY VERIFICATIONS AND SELF ASSESSMENTS 17.2-94 17.2.4.1 Policy~ 17.2-94 17.2.4.2 Levol I Verifications 17.2-94 17.2.4.3 Level II Vorifications 17.2.4.4 Level III Verifications 17.2-1011 17.2.5 CONTROL OF CONDITIONS ADVERSE TO 17.2-111 QUALITY AND CORRECTIVE ACTIONS 17.2.5.1 Policy' 17.2-111 17.2.5.2 Requirements 17.2.5.3 Responsibilities 17.2-114 17.2.6 CONTROL OF DOCUMENTS AND RECORDS 17.2-116 17.2.6.1 17.2-116 17.2.6.2 Instructions, Procedures, Drawings, and Policies 17.2-117I June 2013 17-vii Revision 17

12-F014 FSAR PVNGS UPDATED CONTENTS (cont)

Document Control 17.2.6.4 17.2-125 APPENDIX 17,.2A *eee APPENDIX 17, "-2 CRmp7an'c Matr-"x APPENDIX 17,

2. 1;'

APPENDIX 17.

QCmpar-on of 9A Plan Requirement-wiJth tho-Se o:f- 1-OCF72R.50 App. B3 and APPENDIX 17.2E ApPENDIX 7.2 F Quality Augmented Programs APPENDIX 17.2G and Dat a June 2013 17-viii Revision 17

PVNGS UPDATED FSAR F12-0 14 lQuality Assurance requirements for the Operations Phase are described in the PVNGS Operations Quality Assurance Program Description (QAPD).

17.2 QUALITY ASSURANCE DURING THE OPERATIONS PHASE DELETE 17.

2.0 INTRODUCTION

izona Public Service Company (APS) is responsible for the ape ation and maintenance of the Palo Verde Nuclear Generatng Stati (PVNGS) . The Quality Assurance Plan (the Plan) containe herein describes the formal and comprehensiv plan which has en established to assure compliance wit Title 10 of the Code o Federal Regulations (CFR) and commi ments associated with those NRC Regulatory Guides cit d in Appendix 17.2B to his Plan during the opera on of PVNGS.

This Plan serves as he PVNGS Updated Fina Safety Analysis Report (UFSAR) Section 7.2 and superse s all previous Quality Assurance Plans and manua s.

This Quality Assurance Plan escri es how the Quality Assurance Program is to be implemented wi due regard to the health and safety of the public and the ers nnel onsite.

Section 17.2.1 describes t e organiz tions responsible for implementation of the Q lity Assuranc Program.

Section 17.2.2 provi s an overview of the Quality Assurance Program.

Section 17.2.3 escribes the Control of Station ctivities.

This section ddresses quality related activities hich are within the scope of the Quality Assurance Program.

Section 17.2.4 describes the Control of Quality Verific ions and lf-Assessments.

Se tion 17.2.5 addresses the identification and disposition conditions adverse to quality associated with all aspects of June 2013 17.2-1 Revision 17

X*-*DELETE I PVNGS UPDATED FSAR 12-F014 QUALITY ASSURANCE DURING THE OPERATIONS PH E th QA Program. In addition, this section contains the cont ols provided for evaluating all conditions adverse o qualit and determining what corrective actions should e taken to precl e their recurrence.

Section 17. .6 describes the control of documents and records.

Activities an items within the scope of the QA Plan will require documen which control activities a records which will serve as a hi torical reference.

Changes to the quali assurance progra description in the FSAR will be made in a ordance with CFR50.54(a). It should be noted that FSAR Sectio 17.2 doe not contain all the quality assurance conmitmen s tha are subject to control in accordance with 10CFR50.54(a) dditional sections of the FSAR that contain quality assuranc equirements include:

Section 1.8 for mmitmen s, alternatives, and exceptions to e quality a surance regulatory guides and standard listed in Appen ix 17.2B.

Table 3.2 and section 3.6 for nformation regarding the cla sification of structures, stems, and compo ents within the scope of the q lity assurance proram.

iection 13.1 for the organizational struc re and specific quality assurance responsibilities f the organizations addressed therein.

Section 13.4 for commitments pertaining to review and audits.

June 2013 17.2-2 Revision 17

DELETE PVNGS UPDATED FSAR 12-F0147 QUALITY ASSURANCE DURING THE OPERATIONS PHAS Section 13.5 for commitments pertaining to procedu al coverage, control of procedures, procedure revie s, and procedural approvals.

S ction 18.I.B.l for Independent Safety Rev'ew co tments provided in response to the reco ndations of NUREG-0737.

17.2.0.1 Quality Asurance Program Policy S atement One of the fundamental aspects of any Qua ty Assurance (QA) Program is that the individuals pe orming the work determine the level of qua ity that i achieved. Though plans, procedures, and instructions are a asic part of any quality program, it should be recogniz at people make quality happen. Each individual, when perly trained and motivated, must achieve the highest qualty o performance of which he or she is capable.

PVNGS is maintained and perated in suc a manner as to ensure the health and safety f the public and t personnel onsite.

One way to accomplis this critical objecti is to have an aggressive and co rehensive quality assurance program in place for those activ ies which can impact nuclear sa ety and quality. ./ ..

The executi e vice president, nuclear and CNO, has di ected the establis ent of a formal and comprehensive quality ass rance progra at PVNGS. This program places accountability for qual' y on all personnel at PVNGS. In addition, it emphasi s th creation of an atmosphere in the workplace where reportin 17 2-3 Revision 17 June 2013 17.2-3 Revision 17

DELETE PVNGS UPDATED FSAR 112-F014 QUALITY ASSURANCE DURING THE OPERATIONS PHAS and solution of conditions adverse to quality are encouragd and ex cted at all levels.

The PVNGS uality Assurance Program includes this QA P1 and the associa d procedures and instructions which impl ent the Plan requirem ts. The QA Plan identifies those Qu ity Assurance Regul ory Guides, Standards, and Codes hat shall be implemented to sa *sfy the requirements of 10CF 50, Appendix B, "Quality Assurance iteria for Nuclear Power Plants and Fuel Reprocessing Facilitie ."

Quality assurance object es shall not b subordinate to cost or schedule objectives. T ensure com iance with the QA Plan requirements, independent ve ficati ns and assessments shall be conducted to provide manage nt a measure of the program's effectiveness and adequacy in me ing the requirements of the QA Plan and its implementing p oce res and instructions.

Conflicts involving impleme ation of he requirements of the Quality Assurance Program shall be reso ed by the Director, nuclear assurance, or, deemed necessar the executive vice president, nuclear an CNO. In those instan es when APS has delegated responsiblity for implementation o parts of the Quality Assurance Program to contractors, APS re ains responsibility or adequacy of the overall program 17.2.1 0 GANIZATION The gene 1 organizational structure responsible for implem tation of the Quality Assurance Program is describ in Sect'on 13.1. This section sets forth specific June 2013 17.2-4 Revision 17

DELETE PVNGS UPDATED FSAR 12-F014 QUALITY ASSURANCE DURING THE OPERATIONS PH E resp nsibilities relative to quality assurance for various organi tions and key personnel within those organizatios.

The impl enting procedures identify interface require ents and are present d in more depth than are necessarily des ribed herein.

It is the respon ibility of PVNGS Leaders (i.e. officers, directors, manager , department leaders, secton leaders, and team leaders) to cre te an atmosphere in t workplace where reporting and resoluti of conditions a erse to quality is encouraged at all levels.

PVNGS Leaders give full sup rt to e Quality Assurance Program described herein, the by assuring that all work performed under their cognizanc will conform to and support the requirements of the progr m. VNGS Leaders are charged with the responsibility an authorit to ensure that quality related activities are c pleted with he highest standards of safety and have the au ority to allocat resources in their areas of responsibilty to achieve this ob ctive. They also have the responsibility to stop PVNGS activites within their area of responsi ility which are not accomplish d in compliance with applicab license and/or regulatory require ents.

17.2.1.11 PS Chief Executive Officer and President The ch' f executive officer and president of APS has the over 1 responsibility for the engineering, design, pr curement, construction, repair, modification, maintenance, efueling, inservice inspection and operation of PVNGS.

June 2013 17.2-5 Revision 17

DELETE PVNGS UPDATED FSAR 12-F014 QUALITY ASSURANCE DURING THE OPERATIONS PH SE Exec ion of these responsibilities, including the erespon 'bility for developing and ensuring the implement tion of the P GS Quality Assurance Program, is delegated t the executive vce president, nuclear and CNO.

17.2.1.2 Execu ive Vice President, Nuclear and NO The Executive Vice President, Nuclear and CNO reports directly to the APS Chief Exe utive Officer and Presdent. The Executive Vice Preside t, Nuclear and CN is responsible for the engineering, design, rocurement, nstruction, repair, modification, maintenance, efueling inservice inspection and operation of PVNGS, and ensu s th appropriate policies are provided for these activities.

As such, the executive vice p esi nt, nuclear and CNO has the authority to stop unsatisfa ory wo and control further processing, delivery, or n tionf nonconforming material. The executiv vice president, nuclear and CNO, reviews the status a adequacy of the QA rogram by reviewing reports prepared b the director, nuclear as rance, at least annually. Respo ibility for the operation of VNGS, engineering an design support, construction of jor modification , records management during the opera ons phase, and proper implementation of the QA Program for these activiti s is delegated to the direct reports of the ex cutive vice esident, nuclear and CNO. The responsibility to est lish, maintain, and verify proper implementation of th Q lity Assurance Program is delegated to the Director, Nucle ssurance. The executive vice president, nuclear and CNO, June 2013 17.2-6 Revision 17

DELETE PVNGS UPDATED FSAR 12-F014 QUALITY ASSURANCE DURING THE OPERATIONS PHAS shall etain the responsibility for assuring that the author y and inde endence of the director, nuclear assurance, are s h that he/sh can effectively assure the conformance to qu ity requirements and is independent of undue influences an responsibiliti s for schedules and costs.

17.2.1.3 Senior Vi e-President, Site Operations The senior vice presi ent, site operations re rts to the executive vice presiden , nuclear and CNO, d is responsible to ensure that PVNGS is o erated and main ined in a safe, reliable, and efficient man er in accor nce with corporate policies and all applicable 1 ws, reg ations, licenses, and technical requirements.

The senior vice president, site rations is responsible for the following major functions:

A. Operating and maintainng PVNGS.

B. Planning and schedu ing unit activi *es.

C. Providing functi al support required or operation and maintenance, s h as plant wide chemical, radiological services, wa e disposal, maintenance plan 'ng, engineerin support, materials, document con ols, records anagement, security and fire protectio servic etc. . ...

D. Ass ing standardization of procedures and practice a ng the units.

E. Providing formal training programs.

June 2013 17.2-7 Revision 17

PVNGS UPDATED FSAR 112-F014-]

QUALITY ASSURANCE DURING THE OPERATIONS PHAS F. Initiating unit shutdown when warranted.

G. I lementationof programs for industrial health and saf ty.

H. Provi *ng and maintaining the surveillance test rogram.

To execute the responsibilities, the senior vice resident, site operations l supported by the staff descri ed in section 13.1.

17.2.1.4 Nuclear Supp t Organizations Nuclear Support functions include the m agement of the licensing, safety, and othe function that support the safe, reliable and efficient operatin of VNGS. Responsibilities for these functions are distrib to various supporting organizations at the PVNGS.

These organizations and mana ment p itions are charged with the responsibility and aut ority to en re that quality related activities are completed ith the high s ndards of safety, and have the authority to locate resources i their area of responsibility to ac ieve this objective. Ea h PVNGS Leader gives full support to the Quality Assurance Pro ram described herein, thereby ssuring that work performed unde their cognizance wil conform to and support the requirem nts of the Plan.

The follo ing paragraphs describe specific positions an respons ilities for certain support functions.

17.2-8 Revision 17 June 2013 17.2-8 Revision 17

DELETE PVNGS UPDATED FSAR 112-F014 I QUALITY ASSURANCE DURIN THE OPERATIONS P SE 1 2.1.4.1 Director, Nuclear Regulatory Affairs and Envi onmental. The director, nuclear regulatory affair and enviro mental is responsible for:

A. Main aining the licensing basis and identifyi new NRC requir ments and PVNGS commitments. Tracki g compliance with the e requirements and commitments.

B. The on-site environmental licensing ac vities.

C. Providing pri ipal interface with e NRC and INPO.

D. Programs to comp with NRC repor ing requirements.

E. The program for saf ty evaluatons associated with changes to PVNGS.

F. Initiating unit shutdown ecommendations when warranted by a safety concern.

G. Establishing lines o communi ation for recognition and evaluation of indu ry nuclear afety matters.

Specific respon ibilities and auth rities related to quality assur nce are delegated to 1 aders reporting to the directo , nuclear regulatory affai s and environme tal, as described in the text the PVNGS qualit assurance program.

17.2.1.4.2 Director, Nuclear Security Division. The direc r, Nuclear Security Division, is responsible fo:

A. Implementation of programs for on-site security.

June 2013 17.2-9 Revision 17

DELETE PVNGS UPDATED FSAR 112-F014 QUALITY ASSURANCE DURING THE OPERATIONS PHASE B. Implementation of programs for plant staff reliabil y and fitness for duty.

17.2.1.4.3 Director, Supply Chain. The director, su ly chain is responsib e for:

A. Implem ntation of programs for control, andling, shipping and storage of materials.

B. Implementaton of programs for con rolling procurement of materials d services.

17.2.1.4.4 Manager, Fire otection. The manager, fire protection is responsible to e vie president, operations support, for areas of fire prot ion related to the power block, critical support struct res systems and components; and the independent spent fuel s orage f cility. Specific responsibilities may be d egated to i ividuals reporting to the manager, fire prote ion. Fire prote tion for ancillary and other site buildi gs may be delegated t other support organizations.

17.2.1.4.5 De artment Leader, Employee Concerns clear Training. T e employee concerns department leader i responsibi to investigate, resolve, and document conc ns reporte to the employee concerns department.

17. .1.4.6 Director, Nuclear Training. The nuclear trainin rector is responsible for health June 2015 1'7.2-10 Revision 18

DELETE PVNGS UPDATED FSAR 12-F014]

QUALITY ASSURANCE DURING THE OPERATIONS PHA ser .ces for PVNGS, to include medical examinations in supp t of op ational activities.

17.2.1.4. Director, Performance Improvement. The rector, Performance mprovement reports to the Senior Vice resident, Regulatory and Oversight, and is responsible for he following:

A. Initiating u it shutdown recommendations en warranted by a safety conce n.

B. Establishing prog ams for the review evaluation, and communication of in house and indu try operating experience informatio .

C. Establishment and overal im ementation of the programs for the identification, co ection and trending of conditions adverse to qu it Specific responsibilities d author ies related to quality assurance are delegated leaders rep ting to the director, performance improvemen , as described in he text of the PVNGS quality assurance pr gram.

17.2.1.5 Vice P esident, Nuclear Engineering The vice pres ent, nuclear engineering, reports rectly to the senior ice president, site operations, and is r sponsible to provid engineering services to assure uniform tech cal and regulat ry adequacy of all aspects of nuclear activities o prov e safe, reliable, and efficient operations in accorda ce wi corporate policies and all applicable laws, regulations, d licenses.

June 2013 17.2-11 Revision 17

,*DELETEI PVNGS UPDATED FSAR 12-F014 QUALITY ASSURANCE DURING THE OPERATIONS PHAS The v ce president, nuclear engineering, is responsible for e followi major functions:

A. oviding system, Inservice Inspection (ImI),

Non estructive Examination (NDE), component, and desig engineering services.

B. Providin technical engineering docume s such as calculatio s, material evaluations a analysis, design drawi gs, and specification alidation criteria.

C. Maintaining the e gineering d ign bases for PVNGS.

D. Managing major site elated construction, modifications, and/or *ns allation of structures, systems, and component hat represent physical changes or additions o P GS facilities.

E. Tracking and eval ting equip ent failures.

F. Providing techncal and enginee ng support for PVNGS.

G. Providing nu ear fuel procurement and related engineerin activities.

H. Develop g and maintaining a Quality Cl ssification I. De loping and maintaining the equipment qua ification J. Providing configuration control.

Performing material evaluations and analysis.

June 2013 17.2-12 Revision 17

DELETE PVNGS UPDATED FSAR 12-F014 QUALITY ASSURANCE DURING THE OPERATIONS PH E Preparing replacement material procurement specifications.

M. roviding and maintaining test programs.

N. Imp ementing the cyber security program.

To execute thes responsibilities, the Vice Pre ident, Nuclear Engineering, is s ported by the staff descr ed in s ection 13.1.

17.2.1.6 Director, Nuc ar Assurance The Director, Nuclear Assurance, has the functio al autho ty, independence, and responsibility to assure the effe tive implementation of and compliance to the Quality Assu nce Program. Consistent with this authority is the respon bi 'ty to document interpretations of those a ivitie to which this Plan applies and the extent to which he Plan apples to those activities.

The Director, Nuclear ssurance, has no unrelated duties that would preclude the propriate attention o the primary responsibility of verifying effective imple ntation of the Quality Assura e Program.

The directo , nuclear assurance, reports directl to the senior vice pres dent, regulatory and oversight. The dire tor, nuclear assurance, is responsible to ensure that an a propriate Qual y Assurance Program, the scope of which includes 11 the it s and activities that affect safety and quality, is stablished and implemented in accordance with the requirem ts of this Plan. The director, nuclear assurance, reviews PVNGS activities with the goal of identifying areas where changes June 2013 17.2-13 Revision 17

DELETE PVNGS UPDATED FSAR 12-F014 QUALITY ASSURANCE DURING THE OPERATIONS PH SE coul lead to improvements in nuclear safety and/or qualit The dir ctor, nuclear assurance, has the authority to cr ss organizat nal lines to identify quality problems; to nitiate, recommend, provide solutions; and to verify impl entation.

Specific respo ibilities of the director, nucle assurance, include the follo ing:

A. Developin the operations QA Prog am criteria and updating the Operations Quality Assurance Program Description in the UFSAR.

B. Developing audit, review, ndependent inspection, and assessment programs for uality-related activities within the scope of t PVNGS Operations Quality Assurance Program.

C. Verifying the ef ective imp ementation of the PVNGS QA program thr ugh performanc of audit, review, independent nspection, and ass ssment functions and advising nagement of the status f program impleme ation.

D. Init ating and/or verifying corrective ction as ne essary to resolve significant QA Progr m i mplementation problems.

E. Assuring work is stopped on nonconforming mate ials or activities if:

e continued work may jeopardize nuclear safety; June 2013 17.2-14 Revision 17

DELETE PVNGS UPDATED FSAR QUALITY ASSURANCE DURING THE OPERATIONS PHAS

other corrective action processes are ineffect e in protecting the health and safety of the p lic and/or plant personnel;

" c ntinued work will require significant rework or rep 'r to backfit corrective action; r

an org nization, department, grou , section, or individu by a repetitive fail re to comply with technical administrative c ntrols, contributes to a conditi that is a s' nificant QA program deficiency.

F. Initiating unit shutdo n commendations when warranted by a safety c cern.

G. Reviewing changes to he qu lity classification assigned to system , equipmen and components, as identified in ta e 3.2-1.

H. Reviewing and ccepting, as requir quality-related procurement documents, procedures, i tructions, and other qua ity-related documents, to pro ide assurance that Q requirements are being incorporat d and/or adhe d to.

I. R iewing supplier and contractor quality assu ance rograms for compliance with regulatory requirem nts and the requirements of the PVNGS Operations Quali Assurance Program.

June 2013 17.2-15 Revision 17

DELETE PVNGS UPDATED FSAR 12-F014 QUALITY ASSURANCE DURING THE OPERATIONS PH SE J. Accepting supplier and contractor quality assura ce programs, when required by the PVNGS Operation Quality Assurance program.

K. V rifying through audits or surveys condu ted by PVN or others, that activities of su liers are in compl nce with the requirements of eir QA programs L. Maintainin an awareness of QA r quirements, practices, an experiences th ughout the nuclear power industry nd providin a working interface and line of communica ion wit other divisions, appropriate industr re resentatives, and regulatory groups on QA matters.

M. Maintaining an awa eness of quality-related activities as th y pertain o the operation of PVNGS by reviewing a dit reports, rrective action reports, co espondence from t NRC, inspection report re onses, and other selec ed documents.

N. Establ' hing an indoctrination and aining program for clear Assurance personnel and p viding input fo QA indoctrination of personnel outsi e of the clear Assurance organization. Verifying that adequate quality training programs are devel ed and implemented for each organizational unit perfo ing a quality-related function.

0. Assisting in the development and preparation of procedures controlling the activities of PVNGS June 2013 17.2-16 Revision 17

DELETE PVNGS UPDATED FSAR [12-F014 ]

QUALITY ASSURANCE DURIN THE OPERATIONS P SE personnel and the quality of off-site activitie related to PVNGS startup and operations.

P. viewing reports of significant condition adverse to uality and verifying that events rep rtable to the C are promptly investigated and orrected in a manner uch that the probability of ecurrence of such even s is reduced.

Q. Deleted R. Issuing periodi reports and other quality-related information to th executi e vice president, nuclear and CNO, and approp iate company management to inform them of QA activities nd the status of quality-related activities.

S. Reporting potenti lly signficant quality-related matters, orall or in writin , to the organizational unit concern , and the executve vice president, nuclear an CNO, as appropriate.

T. Perform g independent safety revie s of plant activ ies to detect potential nuclea safety haz rds, to provide independent verific tion that a ivities are performed correctly, and t provide recommendations for reducing human errors as much as practical.

The irector, nuclear assurance, gives full support to the Qu lity Assurance Program described herein, thereby assuring June 2013 17.2-17 Revision 17

DELETE PVNGS UPDATED FSAR 112-F014 QUALITY ASSURANCE DURING THE OPERATIONS PHA that 11 work performed under their cognizance will conform to and sup ort the requirements of the Plan.

This position is charged with the responsibility and a thority to ensure th quality related activities are compl ed with the highest sta dards of safety and has the autho ty to allocate resource in this area to achieve this objective. To execute these respo sibilities, the Director, uclear Assurance, delegates nd assigns Nuclear As urance organization responsibilities to the uclear Assurance Department Leaders.

Members of the Nuclear Ass rance staff routinely participate in Unit scheduling and Plant st us me ings to ensure that the Nuclear Assurance organization 's pprised of activities being performed, and that adequate Nu ar Assurance staffing is available to perform the nece sary erifications consistent with their importance to sa ety.

17.2.1.7 All PVNGS Em oyees All PVNGS employees re responsible for:

A. Achievi acceptable quality during th performance of work tivities.

B. Ac mplishing work activities in accordanc with structions, procedures, and drawings.

C. Stopping work activities and informing their lea ers when it appears that adherence to a procedure is n t possible or may result in an unsafe condition.

June 2013 17.2-18 Revision 17

DPE-LET-EI] PVNGS UPDATED FSAR 12-F014 QUALITY ASSURANCE DURING THE OPERATIONS PH SE deficiencies via the site corrective action pr ram.

17.2.2 Q LITY ASSURANCE PROGRAM 17.2.2.1 Gene al The PVNGS Quality Assurance (QA) Program has en established to control the acti ties performed by or.f PVNGS within the scope of the Quality surance Plan. The scope of the QA Program is defined by ta le 3.2-1 of th UFSAR and section 17.2.2.2 of this Plan. Th Quality surance Plan is the highest level document which escr es the Quality Assurance Program. The term "Program" a sed herein includes subtier policies, program procedures, dm nistrative control procedures, and implementin proced res and instructions.

Adherence to the requirem ts of the uality Assurance Program is mandatory for all PV GS organization and for all external organizations workin under the direct con rol of the PVNGS Quality Assurance ogram.

The Quality Ass ance Plan is the primary docum nt which establishes te policies, goals, and objectives o the Quality Assurance P ogram. Individuals throughout the PVNG organiza *on are responsible for the quality of items nd/or activi es within their area of accountability. The Qua ity Assu ance Program descri.bes the processes to measure the d ree to which the quality level of an item or activity has been chieved.

June 2013 17.2-19 Revision 17

QUALITY ASSURANCE DURN DELETE! BraGS UPDATED FSAR 2F 0 14R THE OPERATIONS PH SE The ey elements of the QA program include a defined scope a planne methodology of quality level management, a proce s for document g nonconformances and corrective actions, a indoctrinaton and training program, and provisions or Quality and Safety Re iews. The principles which establi the QA Program will be controlled by this QA Plan whic is authorized by the executive *ce president, nuclear and 0, and accepted by the NRC.

17.2.2.2 Quality Assura ce Scope The scope of the PVNGS Qua *ty Assur nce Plan includes, but is not limited to, items and actviti s related to safe nuclear plant operation, and protection f personnel and the public.

To ensure consistency in iden fyig items and activities within the scope of this P1 , a cl ssification process has been developed and is con rolled thro h PVNGS Administrative Control Procedures. Th's process relie on the use of the terms "Quality Class ", "quality augmente " "quality related," and "non- uality related."

17.2.2.2.1 It ms Items to wh h this Plan applies are designated as uality Class Q ( ich includes safety related and additional items as designa ed by Senior Management) or quality augmented ( G).

The d finitions of these terms are provided in Appendix 1 .2C of his Plan. A quality classification process for items ha en developed and is controlled through PVNGS Administrative Control procedures. This classification process produces a June 2013 17.2-20 Revision 17

DELTEIPVNGS UPDATED FSAR F12--F0147

~QUALITY ASSURANCE DURING THE OPERATIONS PH SE quail y classification list which identifies the permanent plant s ructures, systems, and components that are withi the scope of his Plan and their specific classifications. New items to wh h this Plan applies shall be added to e quality classificatio list.

The classificati of parts, materials, and co umable items (such as chemicals, radwaste liners, diesel el, etc.) and the technical and qualit requirements shall b specified, documented, and approve as part of the rocurement process.

This Plan may be applied titems, pa ts, and materials other than those designated as "Qu lity C ass Q" or "quality augmented" as specified by PVN S enior Management.

17.2.2.2.2 Activities Activities to which this P an applies are designated as "quality related." Qualty related activities are performed under suitable environ ental conditions u ing special equipment, skills, d processes as necessa . These activities includ but are not limited to:

A. Suppo activities such as, system/comp nent/part cla sification; operating experience asse sment; d sign, maintenance of environmental and fie protection qualification; core design and ass iated safety analysis; procurement; fabrication; handing;

'shipping; storage; cleaning; erecting; installing; testing; repairing; training; welding; inservice June 2013 17.2-21 Revision 17

DELETE PVNGS UPDATED FSAR 112-F014 QUALITY ASSURANCE DURING THE OPERATIONS PHASE inspection; heat treatment; document control; and records management.

B. 0 rational activities, such as normal, abnorma , and eme ency operation; chemistry control; core perfo ance monitoring; operational advice; equipment control; surveillance testing; inservice esting; maintenanc ; housekeeping; fire protect on; security; ALARA; radio ogical controls; radiol ical environmental onitoring; radwaste reparation for shipment; radwas e shipment; fue handling/refueling; technical specific tion compli ce; and emergency preparedness.

C. Assurance activities, s c as audits; document reviews; inspections; m tors; nondestructive testing; and safety r iews.

D. Procedure complian is consi red within QA Plan scope regardless f quality clas ification.

The above activities ar controlled through he use of approved documents which are, s a minimum, consistent ith the requirements of thi Plan, the Operating License the Updated Final Safety Anal sis Report, specific Regulatory uides (to the extent refe enced in Appendix 17.2B of this Plan) and other regulat ry commitments.

17.2-22 Revision 17 June 2013 17.2-22 Revision 17

\*DELETEI PVNGS UPDATED FSAR 12--F0-14 ]

X ~QUALITY ASSURANCE DURING/

THE OPERATIONS PHAS A spe ific task or tasks associated with the above activitie shall b classified as either within the scope of this Pla or not depen ng upon:

" sta ements within the text and the Regulato Guides ident ied in Appendix 17.2B of this Plan

" the rela *onship of the task(s) to the safe operation of the faci ity;

" the relations p of the task(s) t the protection of personnel from e effects of r diation;

" the relationship o the task s) to the protection the health and safety of he blic;

the relationship of the ask(s) to regulatory requirements and co tmen s; and;

" other factors as y be speci ied by PVNGS Senior Management.

Documents that prescri e how to perform act ities within the scope of this Plan s all be identified as sta d in Section 17.2.6.2i..1 17.2.2.3 Gra d Approach The extent o which the requirements of this Plan and ts implemen ng documents are applied to an item or activit shall be bas upon the following:

A. The effect of a malfunction or failure of the item o nuclear safety or safe plant operation.

June 2013 17-2-22 Revision 17

DELETE PVNGS UPDATED FSAR F12-F014I1 QUALITY ASSURANCE DURING THE OPERATIONS PHA E The design and fabrication complexity or uniquene of the item.

C. he need for special controls, surveillanceo mo itoring of processes, equipment, and op ational acti ities.

D. The deg ee to which functionality can e demonstrated by inspec ion or test.

E. The quality istory and degree o standardization of the item.

The extent to which the re uirements f this Plan apply to activities shall be based as mini um on Operating License conditions and other plans pre *o sly approved by the NRC, other regulatory commitments as y have been made associated with activities, the text of his an, the Unit's Technical Specifications, and Append 17.2B o this Plan. Such other plans or regulatory comm ments include, but are not limited to, those associated wth emergency plann g, physical plant security, safeguard ontingency planning, r iological controls, radiolog'cal environmental controls, fire protection, inservice inspe ion, inservice testing, license operator qualification nd requalification, process control offsite dose calcul ion, shift technical advisor training, environme tal qualification of equipment, and security uard trainin and qualification.

When he graded approach is utilized, the justification and ba is for grading shall be documented and retrievable.

pplication of the graded approach shall be accomplished in

.June 2013 17.2-24 Revision 17

DELETE PVNGS UPDATED FSAR 12-F014 QUALITY ASSURANCE DURING THE OPERATIONS PH E acc rdance with procedures concurred with by the Nuclear Assur nce organization. These procedures shall clearly identif how the justification and basis for grading s 11 be documente and maintained.

Grading of P n requirements applicable to items all be the responsibility f the Vice President, Nuclear E gineering.

Grading of Plan quirements applicable to ac ivities shall be the responsibility f the organization res nsible for performing the activi.

17.2.2.4 Three Level Ass rance Appro ch PVNGS is committed to a comp ehensive assurance process consisting of a three level ap ach to assure consistent and complete implementation of th lan. This approach is described in detail in Secton 17. .4.

17.2.2.4.1 Level I Activities at this 1 el consist of worke verifications, supervisory verifi ations, second party ver ications, independent ver ications, and independent ins ections for the purpose of est blishing acceptance of equipment, systems and activities thin the QA scope.

17.2.2.

2.* 2 Level II .. .. "

Acti 'ties at this level are primarily those of survey, su eillance, monitoring, and document review and are perfo med deemed necessary by the Director, Nuclear Assurance. Thes June 2013 17.2-25 Revision 17

DELETE PVNGS UPDATED FSAR [12-F014 ]

QUALITY ASSURANCE DURING THE OPERATIONS PHA E act ities are used to establish adequate confidence that activ ies within the QA scope are being performed in accordan e with QA Program requirements and plant administra ive controls.

Procedures an instructions are established and re ords of the verification ac ivity shall be completed and ma tained. Such surveillance and r monitoring normally inclu observation of tests and inspectio s, observation of selec ed operations, review of records, ve*fications of tests reports, and direct verification on a spot- eck basis.

17.2.2.4.3 Level III The purpose of this level of a ity is to assure, through a comprehensive program of audit a assessment, that the first and second levels of the pro ram a properly functioning, and that organizations conductng activit'es within the scope of this Plan are properly s tisfying the r quirements of the Quality Assurance Pro am.

At this level, proc dures and instructions a e established, including docume ation requirements of the au it or third-level activity.

17.2.2.4.4 Where necessary, quality verifications a e adjusted considering the criteria provided below. Ad stments includ , but are not limited to, changes in frequency of ver ication, application of random or selective sampling te hniques, redefining the scope of specific verification ctivities, or shifting of verification levels.

June 2013 17.2-26 Revision 17

r-D-LETE1PVNGS UPDATED FSAR 112-F014 QUALITY ASSURANCE DURIN THE OPERATI.ONS P SE

" he effect of a malfunction or failure of the item o nu lear safety or safe plant operation

" The d sign and fabrication complexity or unique ess of the item

" The need f special controls, surveillanc or monitoring of processes, equipment, and operationa activities

" The degree to wh'ch functionality ca be demonstrated by inspection or test

" The quality history a d degree standardization of the item

" Activities requiring verif cation as mandated by code, standard, licensing requireme t, or regulatory commitment

" Activities critical t plant sa ty or with a high potential to impac plant safety

Complex activit' s not previously per ormed or implemented

" Implementati of significantly revised rocedures or organizati al structures

" Trendin or quality history information relat d to the activ' y

" Ac ivities that have not been recently evaluated o are erformed infrequently Activities performed by contractors or new personnel June 2013 17.2-27 Revision 17

DELETE PVNGS UPDATED FSAR 12-F014 QUALITY ASSURANCE DURING THE OPERATIONS PH SE verall quality verification coverage applied to the 17.2.2.5 C ntrol of the Quality Assurance Plan The Director, uclear Assurance, with assistance rom the Director, Regula ory Affairs and Environmental hall, for each revision to this Q ality Assurance Plan, det mine if the proposed changes aff t the program descri ion previously accepted by the NRC.

Revisions to the Quality surance Pl that do not reduce the commitments in the program script n previously accepted by the NRC shall be concurred wi b affected Senior Management and approved by the director, n lear assurance. Revisions of this type do not require acce tanc by the NRC prior to implementation, but shall b submitt d to the NRC within 24 months of the previous revision in ccordance with the provisions of the appr ad exemption fro NRC requirements related to 10 CFR 50 4(a).

The executive vic president, nuclear and CNO ay authorize changes to the lo Verde organizational struct e that affect the Quality A surance Plan, provided the change d s not constitute reduction in QA commitment pursuant to 10CFR50.5 (a). Such organizational changes shall be a thorized in writng and do not require updating of the Quality As urance Plan rior to implementation. Supporting Quality Assuranc P1 changes, required reviews, and approvals shall be mpleted as soon as practical after the change is authorized, June 2013-, 17.2-28 Revision 17

DELETE PVNGS UPDATED FSAR 112-F014 QUALITY ASSURANCE DURING THE OPERATIONS PH E but t to exceed 90 days from the effective date of the organi tional change.

evisions to the Quality Assurance Plan that reduce te commitments 'n the program description previously a cepted by the NRC shall e concurred with by affected Senio Management, the director, nu lear assurance, and approved b the executive vice president, nu lear and CNO. They shall e submitted to the NRC for acceptan e prior to implementa on in accordance with I0CFR50.54 (a)(3). Such revisions s 11 be regarded as accepted by the NRC upon eceipt of a etter to this effect from the appropriate revie *ng offic of the Commission or 60 days after submittal to the mmis ion, whichever comes first.

The submittal of the revision t the Quality Assurance Plan shall include all pages affect d that change and shall be accompanied by a forwarding etter dentifying the change, the reason for the change, an the basis or concluding that the revised program incorpo ating the chang continues to satisfy the criteria of Appen ix B to 10CFR50 and o provide a suitable level of control. e letter need not provi e the basis for changes that corr ct spelling, punctuation, or editorial items.

A copy of this etter shall be maintained as a r cord for three years.

17.2.2.5. Effective Date of Implementation Change to implementing procedures resulting from changes to this Plan shall be incorporated within 90 days of the Plan c nge approval date unless an interim action plan is defined nd approved by the Director, Nuclear Assurance.

June 2013 17.2-29 Revision 17

DELETE PVNGS UPDATED FSAR F-014 QUALITY ASSURANCE DURING THE OPERATIONS PHAS 17.2. .5.2 Regulatory Commitments Conforma ce to NRC Regulatory Guides is documented in the Updated Fi 1 Safety Analysis Report (UFSAR) which is maintained b the Regulatory Affairs department.

Appendix 17.2B this Plan contains the Quality A surance Regulatory Guides nd standards that PVNGS shal utilize to meet 10CFR50, Appen x B.

The director, regulato affairs and envir mental, is responsible for providin PVNGS position and interpretations on the Regulatory Guides to which PVNG is committed. Changes to these commitments shall be accomp ished in accordance with regulatory requirements. The D e tor, Nuclear Assurance, shall concur with changes to the sitions and interpretations affecting the Regulatory Guid and tandards contained in Appendix 17.2B.

17.2.2.6 Quality Assur ce Program Review 17.2.2.6.1 The effe iveness of the QA Prog am and its implementation is riodically reviewed by vari us organizations at arious levels and the results o these reviews are do mented in reports to the executive ice president, n clear and CNO, and Senior Management for review and correc ive action as required. The effectiveness o the QA Program Is also evaluated and reported by the Nuclear Ass ance organ ation through the inspection, review, monitoring, aud ing, and assessment functions. In addition, the Nuclear A surance organization periodically prepares reports on Program June 2013 17.2-30 Revision 17

DELETE PVNGS UPDATED FSAR 12-F014 QUALITY ASSURANCE DURING THE OPERATIONS PHAS effect eness. APS management is informed of quality assura ce activiti at least annually through reports developed by he Nuclear As rance organization. Other organizations pr ide additional i ormation and assessment as requested.

17.2.2.6.2 In adition to the reviews and evalua ons performed above, t e executive vice president, n clear and CNO, shall have an indepe ent assessment of the QA Program implementation perform at least annually t ensure that activities meet the regu tory requiremen and the policies of PVNGS. This assessment ma be performe utilizing the safety review groups, an independent consult t, representatives of other utilities and/or the exec tiv vice president, nuclear and CNO's staff.

Any corrective action which ma be emed necessary as a result of these assessments shall b formall identified and tracked through resolution.

17.2.2.7 Training and ualification The PVNGS Quality A urance Program includes re uirements for the training (inc ding indoctrination) and, when necessary, qualification o personnel involved in activities wihin the QA scope. These requirements establish and demonstrate hat personnel a signed to implement elements of the QA Prog am are capable o performing their assigned task and that requir job relate knowledge and skills are maintained. The training depa ment is responsible for planning, scheduling and pr iding training to PVNGS personnel. The specific needs, and June 2013 17.2-31 Revision 17

,TDELETEI PVNGS UPDATED FSAR 12-F014 QUALITY ASSURANCE DURIN THE OPERATIONS P ASE the su ject material to be covered in training and qualific tion programs are established by the organizatonal units resp sible for the activities and by the Nuci r Training Dep tment.

Programs and pr cedures shall be established to ssure that personnel are pro rly trained and/or qualifi to perform their assigned task These programs and p cedures shall define, address, or en ompass the followi g features, as appropriate:

A. The organizationa authorit and responsibilities relative to the tra ing nd/or qualification of personnel.

B. Regulatory and accr ite training, qualification, and certification req rements.

C. Indoctrination nd training r uirements for personnel performing a ivities affecting uality.

D. Methods f demonstrating proficie y.

E. Trainin program evaluation and impro ment.

F. Meth ds used to verify completion of req ired tr ining.

G. Instructor qualifications.

Retraining and requalification requirements, and frequency.

I. Methods of training.

June 2013 17.2-32 Revision 17

DELETE PVNGS UPDATED FSAR F12- F014 QUALITY ASSURANCE DURIN THE OPERATIONS P SE J. Maintenance and control of training, certificati and qualification records.

Personnel erforming activities within the QA scope s all be indoctrinat into the Quality Assurance Program.

Indoctrinatio shall emphasize that the individu is responsible for uality and explain the progra that exist for reporting conditio s believed to be in non-c pliance with the QA Program.

Personnel performing ac ivities within e QA scope shall be instructed as to the purp se, scope, d implementation of manuals, procedures, and in tructio s for the activities being performed. Training shall be e ired commensurate with the activities importance to safety. For those activities that require certification, profi enc shall be demonstrated and documented.

Training programs shall e revised as cessary to reflect job performance, plant mo fications, procedu e changes, industry events, and regulat y changes.

Required trainin and/or qualification shall b identified, satisfactorily ompleted, and documented prior t an individual being assign to independently perform the task.

17.2.2.8 Quality Classification The q lity classifications for items and activities withn the QA ope as described in Section 17.2.2.2 shall be establis ed u ing approved procedures. The significance of an item's or activity's importance to safety shall be considered in its June 2013 17.2-33 Revision 17

DELETE PVNGS UPDATED FSAR 12-F°14 QUALITY ASSURANCE DURING THE OPERATIONS PH E clas *fication. Procedures shall be prepared that establis the re irements for the identification and control of t classific tion of quality related items and activities. These procedures nd changes to them shall be reviewed and oncurred with by the N clear Assurance organization prior t issuance.

Systems and majo components shall be identifie as either Quality Class Q, Q ality Augmented (QAG), or on-Quality Related (NQR) in acc. dance with PVNGS proc dures. The classification of the stems and compone ts shall be subject to independent verificati n. Where the e is a change to a lower quality classificatio of syste s, structures, and components, the classificatio sha be determined by Engineering and concurred with Nuclear Assurance. The determinations shall be docume e and retained as a permanent record.

Spare or replacement part and materia s are not necessarily classified the same as e component of ich they are a part.

Such parts and materi s that perform or c tribute to the performance of a sa ety related or Quality Au mented function are within the sc pe of this Plan and classifie similarly as the component which they are a part. The clas ification of spare or rep cement parts and materials, that are f a different assification than the component of which ey are a part, sh 1 be determined by the Engineering organizati The determ'nation shall be documented and reviewed by the Nucl ar Assu ance organization consistent with the requirements of tis P1 n.

June 2013 17.2-34 Revision 17

DELETE PVNGS UPDATED FSAR 12-F014 QUALITY ASSURANCE DURING THE OPERATIONS PH E Activ'ties that are within the scope of this Plan are identif d in Subsection 17.2.2.2.2. Subsection 17.2.2.

provides rther basis for grading the extent of appli ation of the require nts of this Plan to these activities. ocuments that prescribe methods for implementing the requir ments of this Plan shall eet the requirements of Section 17.2.6.

17.2.2.9 Safety Rev'ews The safety review prog m is comprised of four major elements:

17.2.2.9.1 The first elem nt of the afety review program is the responsible Technical Reviwer. Technical Reviews shall be performed by someone other than t e individual doing the work.

This review shall be performed y a qualified responsible Technical Reviewer on activi es wi in the QA scope. This includes, but is not limit to, desi work or changes, plant operations procedures, e ergency and ala m procedures, radiological protectio procedures, and p nt maintenance procedures. Individ als performing the revi w shall not have direct responsibil ty for the performance of t e activities under review, b may be from the same functiona ly cognizant organization the individual/group performing th original work. Addi onal reviews and evaluations shall be p formed when required by 10 CFR 50.59.

17.2. .9.2 The second element of the safety review progra is the Plant Review Board (PRB). The PRB is composed of key nagement personnel whose function is to advise the site June 2013 17.2-35 Revision 17

DELETE PVNGS UPDATED FSAR 12-F014 QUALITY ASSURANCE DURING THE OPERATIONS PH E genera plant manager on all matters related to nuclear sa ty.

The PRB eviews all proposed changes to Technical Specificat ns, investigates all violations of Technic Specificatio reviews reportable events, reviews u it operations to tect potential nuclear safety haza ds, and performs reviews nd investigations of other mat ers related to nuclear safety.

17.2.2.9.3 The third eement of the safe y review program consists of the independe safety revi s performed by personnel assigned to the N lear Ass rance Department. When assigned to perform independen saf ty reviews, personnel have no line responsibilities and sel tively assess and evaluate safety matters from a technica pe spective.

17.2.2.9.4 The fourth ele ent of the afety review program is the Offsite Safety Revie Committee. The ommittee reports to and advises the execut' e vice president, clear and CNO, on matters subject to i s review. Committee me ers perform periodic reviews o selected PVNGS events and a tivities in order to identif areas involving nuclear safety here current and long term mprovement can be realized. Additio ally, the committee p vides Senior Management with an overview nd assessmen of the adequacy of activities associated wit meeting nuclear safety goals and objectives. This commit e is compr sed of a chairman, PVNGS senior managers, and members fro outside PVNGS with overall nuclear expertise. The June 2013 17.2-36 Revision 17

DELETE PVNGS UPDATED FSAR 112-F014 ]

QUALITY ASSURANCE DURING THE OPERATIONS PH SE chal man and members are designated by the executive vicee presi nt, nuclear and CNO.

17.2.2.10 Conditions Adverse to Quality and Correc ive A program for i entifying activity and hardware conditions adverse to qualit within the QA scope shall e established.

Conditions adverse quality include, but are not limited to, failures, malfunctions deficiencies, de iations, defective material and equipment, nd non-confo ances.

Conditions adverse to quali y shall be identified, documented, and controlled in accordance it administrative control procedures to ensure that they re promptly corrected.

Significant conditions adver eto uality shall be promptly identified, evaluated for eportabiliy, and corrected. The cause of significant co itions advers to quality shall be determined and approp iate action taken oprevent recurrence.

The identification, cause, and actions tak to correct significant condi ions adverse to quality sha 1 be documented and reported to the appropriate levels of mana ment.

17.2.2.11 External Organizations Supplier who provide items, parts, materials, consuma les, and/or services that are within the scope of this Plan s all hay an appropriate QA program and implementing procedures T supplier's QA program shall be subject to review and June 201-3 17.2-37 Revision 17

DEET]PVNGS UPDATED FSAR IFf--F0-1-4

~QUALITY ASSURANCE DURING THE OPERATIONS PH SE designe\

concu rence by the Director, Nuclear Assurance or their The exten to which the supplier's QA program shall b applied shall be spe ified by procurement documents.

17.2.2.12 Resolu ion of Differences and Escalato ns Differences of opi *on involving quality bet en Nuclear Assurance personnel ad other organization) (engineering, operation, maintenance, etc.) shall, if ossible, be resolved at the level at which the occur. If is is not possible, the differences shall be escala ed throu supervisory/management levels until resolution is ac ieve The Director, Nuclear Assurance shall make the decision on matters concerning the applic ili y of the Plan to activities.

The Vice President, Nuclea Engineeri g, shall make the decision on matters rela ed to classifi ation of items, parts, materials, and technic requirements.

17.2.3 CONTROL STATION ACTIVITIES 17.2.3.1.1 ation activities within the QA scope shall be conducted accordance with the requirements of thi Plan.

These ac vities include but are not limited to design hanges, procur ent, fabrication, handling, shipping, storage, clea ng, erecting, installation, inspection, testing, op ration, maintenance, repair, refueling and modification.

June 2013 17.2-38 Revision 17

DELETE PVNGS UPDATED FSAR 12-F014]

QUALITY ASSURANCE DURING THE OPERATIONS PH E 17.2.3.1.2 The Quality Assurance requirements for station activi ies are contained in this Plan and conform with applicab NRC Regulatory Guides and associated ANSI S ndards.

The commit nts to these Regulatory Guides and assocated ANSI Standards sh 1 be implemented in appropriate proc dures governing stati n activities. The requirements f this Plan apply to all orga izations performing function within the QA scope which affect he quality of structures systems, components, or activi ies.

17.2.3.1.3 The followin subsections discuss typical activities which are repres ntative f the broad scope of administrative controls and q ali assurance requirements that are applicable to station activ ies. The organizational and functional responsibilities g er 'ng station activities shall be structured so that the o jective of this Plan are accomplished by those who ave been as igned responsibility for performing the work. C nformance to est blished requirements is the responsibilit of individuals perfo ming the work.

Nuclear Assurance vision activities such a independent inspection, moni ring, audits, and reviews ar performed to independently rify conformance to this Plan, a licable station admi stration controls, and applicable re latory and licensing ommitments. These Nuclear Assurance orga zation independ nt verifications are applied to station activ ies to the ex ent necessary to provide adequate confidence that stru tures, systems, components, and personnel perform s isfactorily to maintain the safety of the station.

June 2013 17.2-39 Revision 17

DELETE PVNGS UPDATED FSAR 12-F014]

QUALITY ASSURANCE DURING THE OPERATIONS PHAS 17.2. .2 Design Control 17.2.3. .1 Requirements 17.2.3.2.1 1 The organizational structure and responsibili ies of personnel involved in preparing, eviewing, approving, and erifying design documents shall be efined.

17.2.3.2.1.2 The esign bases, safety analys , design criteria, codes and andards, and Plant Tec ical Specifications, includi g all amendments, all be translated into design documents and reviewed durin the design process.

Changes shall be in accorda ce with re ulatory requirements.

17.2.3.2.1.3 Materials, parts, a d processes selected by design are reviewed to assure t are suitable for the intended application, includi com tibility of materials; accessibility for inservice inspection- maintenance and repair; ALARA considerations; per onnel safety; ire hazards analysis; associated computer pro rams; and quality tandards. The review shall also ev uate suitability with gard to human factors which may fect safe operation; and t suitability of commercial grade aterials, parts, and equipment o the application.

17.2.3.2.14 Internal and external design interface c ntrols, procedur s, and lines of communication, among participati desig organizations and across technical disciplines, are est lished and described for the preparation, review, a roval, release, distribution, and revision of documents June 2013 17.2-40 Revision 17

DELETE PVNGS UPDATED FSAR 12-F014 QUALITY ASSURANCE DURING THE OPERATIONS PHA inv ving design interfaces to assure structures, systems, d compo ents are compatible geometrically, functionally, an with process and the environment.

17.2.3.2.1. Errors and deficiencies in approved esign documents, in uding design methods (such as co ter software) that could adver ely affect items and activiti swithin the QA scope shall be doc ented. Action shall be aken to assure that these errors or eficiencies are corr cted. In addition to correcting a deficie cy (or error), rrective action also includes, for significan or recurrin deficiencies (or errors), determining the ca se and instituting appropriate changes in the design process o revent similar types of deficiencies from recurring.

17.2.3.2.1.6 Deviations om speci ied quality standards shall be identified and ocedures sha 1 be established to assure their resolutio and control.

17.2.3.2.1.7 Desgn verification methods (esign review, alternate calcu tions, or qualification testin) shall be established t verify design adequacy.

17.2.3.2. .8 Design documents shall be subject to p ocedural control Controlled design documents include, but are ot limit d to, specifications, calculations, computer progra sy em design descriptions, and drawings (including flow lagrams, piping and instrument diagrams, system diagrams, Ju~ne 2013-' 17.2-41 Revision 17

DELETE PVNGS UPDATED FSAR F2 -Fj014 QUALITY ASSURANCE DURING THE OPERATIONS PHA faclity drawings showing equipment locations, and site arran ments).

17.2.3.2. .9 Design verification procedures shall b established hich assure the following:

A. The r sponsibilities of the verifier, a eas and feature to be verified, and the exte t of documenta *on required are identif d.

B. The verifier is qualified and is not directly responsible fo the design.

C. Verifications are complete and documented prior to turnover of the com nen or system to Operations.

17.2.3.2.1.10 When verificati ns are to be accomplished solely by test:

A. Prototype, comp ent, or fea re testing shall be performed pri r to installation of the equipment, or prior to th point when the insta lation would become irreversi le.

B. Verifi ation by test shall be performe , whenever prac ical, under conditions that simulat the most a erse design conditions as determined by analysis.

C. Procedures provide criteria that specify when verification should be by test.

June 2013ý' 17-2-42 Revision 17

DELETE PVNGS UPDATED FSAR 112-F014 QUALITY ASSURANCE DURING THE OPERATIONS PH SE 17.2. .2.1.11 Procedures shall be established to assure t at compute codes, and changes thereto, are validated and controlle to prevent unauthorized changes.

17.2.3.2.1.12 Design and specification changes, cluding field changes, all be subject to design contr 1 measures commensurate with hose applied to the origi 1 design. Design changes shall be reviewed and approved by e organization responsible for the or inal design or b another organization with comparable expertis designated t review and approve changes.

17.2.3.2.1.13 Measures shall bprovided to assure that responsible plant personnel ae i formed of and/or trained on design changes and/or modifcations hich may affect the performance of their duti s.

17.2.3.2.1.14 Work thorizing documents hich control the installation of qu ity related modification shall be clearly identified as qu ity related. New items shal be evaluated for quality cl ssification determination and adde to the Quality Cla ification list as applicable.

17.2.3. .1.15 Design control procedures shall ensure t at desig documents for implemented design changes are issue in a tim ly manner to prevent inadvertent use of superseded desi formation.

June 2013 17.2-43 Revision 17

DELETE PVNGS UPDATED FSAR 112-F014 QUALITY ASSURANCE DURING THE OPERATIONS PH E 17.2.3.2.2 Responsibilities 17.2.3. .2.1 Vice President, Nuclear Engineering. Th Vice President, Nuclear Engineering, is responsible for th development nd implementation of the design contr measures, maintenance an control of the PVNGS design base determination of the quality classification of systems, structures, and co onents, and delineating ritical attributes requiring verificatio . This position is lso responsible for providing qualified dis ipline engineer to perform design for major modifications, impr ements and additions to PVNGS. To fulfill these responsibiliti s, th Vice President, Nuclear Engineering shall:

A. Monitor operational er rmance data.

B. Provide technical assistan to other organizations.

C. Ensure design erifications a performed.

D. Ensure Nucl ar Assurance review d concurrence of applicabl design criteria documen specifications, and ch ges.

E. Maiain a classification list.

F. sure that construction, modification and r installation of major structures, systems, an components are in compliance with technical and Quality Assurance requirements.

June 2013 17.2-44 Revision 17

DELETE PVNGS UPDATED FSAR 12-F014-1 QUALITY ASSURANCE DURING THE OPERATIONS PH E

17. .3.2.2.2 Director, Nuclear Assurance. The Director, Nude r Assurance, is responsible for performing Quality Assuran e verifications in accordance with Section 17. .4 of this Plan 17.2.3.2.2.3 PVNGS Leaders. PVNGS Leaders are responsible to incorporate int applicable policies, procedu s, and instructions thos requirements contained i this Plan and the Regulatory Guides a standards committed o in Appendix 17.2B of this Plan.

17.2.3.3 Procurement Cont ol 17.2.3.3.1 Requirements The requirements for the prep ion, review, approval, and control of procurement docu ents all be delineated in detailed procedures. Thes procedure shall comply with and require the incorporati n of current PNGS QA program controls into procurement doc ents. Technical r uirements for spare and replacement pa s shall meet or exceed he original procurement requrements. Procedures shall so delineate requirements t assure that procurement documen s contain the following, a applicable:

A. pecify technical, quality assurance, insp ction, and acceptance criteria commensurate with the re irements of this Plan.

B. Impose applicable quality program requirements on vendors, subvendors, and contractors.

June 2013 17.2-45 Revision 17

DELETE PVNGS UPDATED FSAR F12i-F014 QUALITY ASSURANCE DURING THE OPERATIONS PHAS C. Specify or reference appropriate technical requirements, including applicable regulatory r uirements, material, component identificati req 'rements, drawings, specifications, code and stand ds, test, calibration, inspection r quirements, handlin storage, shipping requirements and special process in tructions.

D. Identify the ocumentation to be pr pared, maintained, and submitted r review and appr val.

E. Identify those it s and activties within the QA scope.

F. Identify those records hch vendors, subvendors, or contractors shall retai , maintain, and control; and those which vendors, ubven ors, or contractors shall deliver prior to u or insta lation of the item.

G. Include right o access to vendo 's, contractor's and their subtier endor's and contrac or's facilities and records or source inspection an /r audit.

H. Contain chnical and quality requireme ts for spare or rep cement parts at least equivalent o those applied to the original procurement. In th se cases wh re the technical and quality requirements or the riginal item cannot be readily determined or w n spare or replacement parts and materials are of a different classification than that of the component f which it is a part, an engineering evaluation shall be June 2013 17.2-46 Revision 17

DELETE PVNGS UPDATED FSAR 12-F014-]

QUALITY ASSURANCE DURING THE OPERATIONS PHASE conducted and documented to establish the requireme s and controls.

I. dlude provisions that ensure PVNGS reviews o desgnated supplier procedures prior to imple ntation.

J. Require esign organizations performing design activities or PVNGS to have and impl ment quality programs whi include design contr 1 provisions consistent wit those provided i this Plan.

K. Identify the prog ins, proced es, activities, and conditions that requre PVN approval and/or release.

L. Include requirements fo eporting and approving the disposition of nonconf m nces including the requirement for noti icatio of significant conditions determined to be r portable u er 10CFR21.

M. Provisions for xtending applica e requirements to lower tier s contractors and supp ers.

N. Require su mittal of appropriate cert ication documen tion identifying the purchased aterial and the s cific procurement requirements met. For any pro rement requirements that were not met, he vendor will be required to furnish documentation mndi ting how such non-conformances were resolved. Such certification must be attested to by a person responsible for this quality assurance function.

June 2013 17.2-47 Revision 17

DELETE PVNGS UPDATED FSAR 12-F0141 QUALITY ASSURANCE DURING THE OPERATIONS PHAS Measures shall be established for the review, approval, and release of procurement documents ad subsequent revisions. Changes to technical and quality r uirements specified in procurement docume ts shall be bject to at least the same level of view and appro 1 as the original document. The views shall assure te inclusion of the applicabi technical, quality, a d administrative require ents in procurement ocuments prior to t ir use. Reviews shall be docum ted to provide bjective evidence of approval prior to release.

.17.2.3.3.2 Qualification and 1 tion of External organizations 17.2.3.3.2.1 Procedures sh 1 be tablished to accomplish the evaluation and selecti of extern 1 organizations.

Contracts or purchase or ers for materia , equipment or services covered by th scope of the Quali Assurance Program shall be awarded to rganizations that have en evaluated by the Nuclear Assur ce organization and determi d to have an acceptable Qualty Program that is commensurate th the equipment or ervices to be provided, unless one or more of the following c nditions apply:

A. The external organization shall be required in he procurement documents to accomplish their work un er the direct control of the PVNGS Quality Assurance Program and in accordance with procedures that have been approved by PVNGS.

June 2013 17.2-48 Revision 17

DELETE PVNGS UPDATED FSAR F12-F014 QUALITY ASSURANCE DURING THE OPERATIONS PHA The external organization will be supplying commer ial grade items or services as defined in 10CFR21 a the cceptability of these items or services can d shall be adequately verified by PVNGS through ins ection or test conducted following delivery of th item or servic or through in-process surveill ces conducted during th manufacture or performanc of the item or service.

C. The external o ganization will e supplying an item or service for use 'a Quality ugmented structure, system or componen and th quality of the item or service can be assure the extent required by this Plan by receipt inspe on or in-process surveillances.

17.2.3.3.2.2 Documente evaluations o prospective suppliers shall be conducted. alifications shall e based upon one or more of the followi criteria:

A. Capabilty to provide products or ser *ces based upon histo ical performance.

B. C ability to comply with the PVNGS Qualit Assurance rogram, as applicable to the items or servic s to be supplied.

C. Acceptable pre-award survey of the organization's facilities and quality assurance program to determine their capability to supply the items or services that June 2013 17.2-49 Revision 17

DELETE PVNGS UPDATED FSAR 112-F014 QUALITY ASSURANCE DURING THE OPERATIONS PHAS meet the design and quality requirements of the specification.

D. e supplier is providing commercial-grade ca ibration se ices and is accredited by a nationally- ecognized accre iting body as described in the APS esponses to NRC Reg latory Guides 1.123 and 1.144 at are documente in Section 1.8 of the UFS. For suppliers of commerci grade calibration se vices with accreditation y a nationally-re ognized accrediting body, a document d review of e supplier's accreditation by t e purcha er may be used in lieu of inspections or tests oll.wing delivery or in-process surveillances during p formance of the service. This review shall include, at minimum, all of the following:

1. The accred ation is to ASI/ISO/IEC 17025.

2. The acc diting body is eith r NVLAP or the Ameri an Association for Labor tory Accreditation (A2 A) based upon A2LA continued VLAP r cognition through the Internatio 1 Laboratory Accreditation Cooperation (ILAC) Mutu 1 Recognition Arrangement.

3. The published scope of accreditation for t e calibration laboratory covers the needed measurement parameters, ranges, and uncertainties.

June 2013 17.2-50 Revision 17

DELETE PVNGS UPDATED FSAR f12-F014 QUALITY ASSURANCE DURING THE OPERATIONS PH E

17. .3.3.2.3 When the approval of an external organizatio 's quali assurance program by PVNGS is required, it shall e reviewe and approved by PVNGS prior to initiation of e activity a fected by their program.

17.2.3.3.2.4 In the case where "commercial gra items," are to be used in sa ety related applications, eva uations are not required; however, ritical characteristics f the items to be provided shall be es blished and verifie for the purpose of item dedication and ac ptance.

17.2.3.3.2.5 Material sup hers, t holding a quality systems certificate, shall be eva ated by PVNGS to assess compliance with ASME Section II , Subsection NCA-3800 quality program requirements.

17.2.3.3.3 Vendor Assura ce Measures shall be esta ished to provide for control of vendor activities. These m asures shall be descr ed in detailed written procedures.

The attributes f the Vendor Assurance program all include:

A. Pro isions for the review and approval o appropriate vndor Quality Assurance documents prior to fabrication. When specified in procurement d cuments, vendors may not implement procedures until writ n notice of PVNGS approval is received.

June 2013 17.2-51 Revision 17

DELETE PVNGS UPDATED FSAR 112-F014 QUALITY ASSURANCE DURING THE OPERATIONS PHA B. Provisions for source verifications that delineate as required, review, inspection, verification, and old, witness, or test points in the manufacturing! sign p cess.

C. Meth s for resolution of nonconformances. Where the vendor disposition of nonconformance against PVNGS accepted rawings/specifications is se--as-is" or "Repair," a proval by the responsi e engineer and the PVNGS Nuclear Assurance organiza ion shall be required.

D. Planned and system tic audi and surveillance of vendor quality activtie . Scope of coverage and frequency shall be det mined by the criticality of the furnished items nd te evaluated results of vendor qualificati ns, incl ding pre-award surveys, quality program eviews, audi and industry experience, a quality procedu reviews. Revisions to audit an surveillance plans sh 11 be made as warranted y vendor performance. Id ntified deficie cies shall be documented. The Nuclear Assu nce organization shall also provid followup of co ective action implementation.

E. ontrol of vendor document packages, includin reviews for completeness and acceptability. Inadequate records which render the quality status of item(s) furnished indeterminate shall be sufficient cause fo rejection of the item(s).

June 2013 17.2-52 Revision 17

DELETE PVNGS UPDATED FSAR 112-F°14 QUALITY ASSURANCE DURING THE OPERATIONS PHASE Assessments of vendor quality. Assessments shall be made at a frequency commensurate with Regulatory r quirements and the importance, complexity and qua tity of the items furnished. These asses ents shall utilize the qualitative and quantitat e informa 'on provided by vendor noncomplia ce documents; industry experience, inspection, monitoring, nd audit reports; and re eiving inspection an test records.

G. Material accepta ce procedures at assure:

1. The material, co ponent, r equipment is clearly identified and the iden ification and quantity correspond to the in rmation on the shipping documents and quaY y cords.

2. The item's handling and s ipping requirements have been met by t vendor and intained by the carrier./

3. The item' quality record packag or compliance certif' ation is complete and adeq te. Supplier cert' icates of conformance shall be eriodically va idated through audits, surveys, inde endent

.nspections, or tests when they are used s the basis for acceptance of a purchased item or

4. The material, component, or equipment meets the technical requirements specified in procurement June 2013 17.2-53 Revision 17

PVNGS UPDATED FSAR !12-F014 11ý=

QUALITY ASSURANCE DURINC2 THE OPERATIONS PHI documents, inspection plans, checklists, or o er engineering documents.

5. Items delivered which are not in complia ce with requirements are documented in accorda ce with the onconformance procedure, tagged (as item co figuration or storage conditio permit; addi 'onal administrative contr s shall be used if tag 'ng is not practical), segregated (if possible) and prevented fr m being inadvertently issued for nstallation use.

6. Items are main ained proper storage levels.

7. Items accepted a *dentified as to their inspection status p ior to releasing them for installation o furth r work.

17.2.3.3.4 Responsibil' ies 17.2.3.3.4.1 Direc r, Supply Chain. T e Director, Supply Chain is responsib for the following:

A. Admini tration and operation of contr cting, proc rement, and warehousing activities of PVNGS.

B. A surance that the contractual, legal, an commercial requirements are incorporated into the procu ement documents in a manner which shall enforce the technical and quality requirements.

June 2013 17.2-54 Revision 17

DELETE PVNGS UPDATED FSAR i2-F0141 QUALITY ASSURANCE DURING THE OPERATIONS PHA C. Assurance that documents and records, as required y procurement documents, are submitted to PVNGS i a timely manner and that they are complete and gible.

D. surance that purchase orders and contrac for items and services within QA scope are issued external organizations that meet the requiremen s of this Plan.

E. Assuranc that the technical and qu ity requirements are incorp rated into contract/pr curement documents.

F. Receipt inspe tion and accepta e of procured materials using ualified in ependent inspection personnel.

G. Review and acceptanc o quality documentation submitted by supplier 17.2.3.3.4.2 Director, N clear Ass rance. The Director, Nuclear Assurance, is re ponsible to:

A. Approve sup ier Quality Assuran e Programs to the extent re ired in the procurement documents.

B. Review nd concur with PVNGS receipt nspection Pr°c ures".

C. E ablish and implement an adequate progra of source nspection, surveillance, and audit, to assu e supplier compliance with procurement document requirements.

D. Review procurement documents to assure that quality requirements are correctly stated, inspectable, and June 2013 17.2-55 Revision 17

DELETE PVNGS UPDATED FSAR 12L-F01I4 QUALITY ASSURANCE DURING THE OPERATIONS PHAS controllable; that there are adequate acceptance/!

rejection criteria; that source surveillance or receipt inspection is specified; that minimum cumentation to be supplied is specified; d that th procurement documents have been proce ed in acco ance with established requirement . This review may inc ude sampling review of previo sly approved procureme t documents or in-line re iews of selected purchase re isitions or orders ior to placement E. Establish and aintain an Appr ved Vendors List/

Approved Supplie List (AV ASL) which documents an acceptable quality rogra which meets PVNGS procurement requireme t/.

17.2.3.3.4.3 PVNGS Leaders.. PVN Leaders are responsible to incorporate into applicabl policies, procedures and instructions those requi ements contain d in this Plan and the Regulatory Guides and tandards committe to in Appendix 17.2B of this Plan.

17.2.3.4 Ident ication and Control of Materia s, Parts, and Com nents 17.2.3.4.1Requirements 17.2.3.4.1.1 Identification and traceability requirem nts shalle included in specifications and drawings. r 17.2.3.4.1-2 Materials, parts, and components, including artially fabricated subassemblies or subdivided materials, June 2013 17.2-56 Revision 17

DELETE I PVNGS UPDATED FSAR 12-F014 QUALITY ASSURANCE DURING THE OPERATIONS PHAS sha be identified to preclude the use of incorrect or defec 'e items.

17.2.3.4.1 3 Materials, parts, and components withi the QA scope shall e identified so that they can be trace to the appropriate do mentation. Appropriate documenta ion may include, but is nt limited to:

A. Specifica *ons B. Drawings (in uding as-builts)

C. Procurement Doc ents D. Physical and Chemi 1 Tes Reports E. Nonconformance Report F. Inspection Reports nd C ecklists G. Storage Maintena ce Instruc ions H. NDE Reports I. Vendor Cer ficates of Compliance 17.2.3.4.1.4 T e location and method of ident ication shall be specified s as not to affect the form, fit, f ction, or quality of e item being identified.

17.2.3. .1.5 Identification of materials, parts and compo ents shall be traceable through release for fabricat n, shi ping, installation, and testing.

June 2013 17.2-57 Revision 17

DEET IPVNGS UPDATED FSAR F12- F0 14 SQUALITY ASSURANCE DURIN

~THE OPERATIONS P SE 17.2 3.4.1.6 Where physical identification is either imprac ical or insufficient, physical separation, proce ural control, or other approved means shall be employed.

17.2.3.4.1.7 A receipt inspection shall be perf rmed at the site to verify hat identification for receive items is complete and acco panied by appropriate docu ntation.

17.2.3.4.2 Responsiblities 17.2.3.4.2.1 Director, Supply Chain. The Director, Supply Chain is responsible for suring t t materials, parts, and components are correctly ide tifi prior to release for fabrication, shipping, install on, and testing.

17.2.3.4.2.2 Director, Nu erAsurance. The Director, Nuclear Assurance, is res onsible fo performing Quality Assurance verifications in accordance 'th Section 17.2.4 of this Plan.

17.2.3.4.2.3 P GS Leaders. PVNGS Leaders re responsible for:

A. Ens ring that procurement documents cont in propriate requirements for the identific tion and control of materials, parts, or components a that only materials, parts, or components which hav been accepted in accordance with Quality Assurance Pro ram requirements are used.

June 2013 17.2-58 Revision 17

DELETE PVNGS UPDATED FSAR 112-F014 QUALITY ASSURANCE DURING THE OPERATIONS PHAS B. Incorporating into applicable policies, procedures, and instructions those requirements contained in his Plan and the Regulatory Guides and standards c itted tin Appendix 17.2B of this Plan.

17.2.3.5 Cont 1 of Special Processes 17.2.3.5.1 Requi ments 17.2.3.5.1.1 Speci 1 processes are those at require interim in process controls in ddition to final spection to assure quality. Special process nclude, but a e not limited to, such processes as welding, heat reating, hemical cleaning, nondestructive examination, a d co ings.

17.2.3.5.1.2 Measures shall stablished and documented to assure that special processe are a omplished under controlled conditions in accordance with applica e codes, standards, applications criteria, a d other require ents including the use of qualified personne and procedures.

17.2.3.5.1.3 Pr edures shall provide for re ording evidence of acceptable c pletion of special processes. ocedures and instructions or the control of special processes all be reviewed a approved by qualified personnel. Quali *cation records personnel, equipment, and procedures associa ed with specia processes shall be established and maintained. F r special processes not covered by the existing codes or st ndards, or when item quality requirements exceed the equirements of established codes or standards, the necessary June 2013 17.2-59 Revision 17

DELETE PVNGS UPDATED FSAR 112-FO14 QUALITY ASSURANCE DURING THE OPERATIONS PHA E qua 'fications of personnel, procedures and equipment shall e defin in procedures.

17.2.3.5. Responsibilities 17.2.3.5.2.1 PVNGS Leaders. PVNGS Leaders perfo ming special processes are sponsible for:

A. Assuring that the established progr requirements for controllin and accomplishing spe al processes are implemented.

B. Assuring that t procedures including changes, are reviewed, approve and qu ified prior to use.

C. Assuring that person el nd equipment used in the performance of specia rocesses are qualified and the records of qualific tion re maintained.

D. Incorporating ino applicab policies, procedures, and instructio s those requir ents contained in this Plan and the egulatory Guides a d standards committed to in Appe dix 17.2B of this Plan.

17.2.3.5.2.2 irector, Nuclear Assurance. Th Director, Nuclear Assur ce, is responsible for:

A. erforming Quality Assurance verifications*n accordance with Section 17.2.4 of this Plan.

Review of special process procedures.

June 2013 17.2-60 Revision 17

DELETE PVNGS UPDATED FSAR E1-F14I QUALITY ASSURANCE DURING THE OPERATIONS PHAS

17. .3.6 Test Control 17.2.3.6.1 Requirements 17.2.3.6. .1 A documented test program shall be esta lished.

Testing req ired to demonstrate that the structures, systems, or components ithin QA scope will perform satisf torily in service will be *dentified and documented. Thee tests shall be performed in ac ordance with written, appr ved, and controlled test proc dures which incorporat or reference the requirements and accep ance standards co ained in the applicable design and pr urement docu nts. These test procedures or instructions hall pro ide the following, as required:

A. A description of the t t objective.

B. Instructions for pe formi the test, including caution or safet notes in fficient detail to avoid operator inter etation.

C. Test prereq sites such as calib ted instrumentation, adequate st equipment and instru ntation including accurac requirements, status of item to be tested, suita e and controlled environmental c nditions, and per onnel to be provided to conduct tests under the rection of a qualified test engineer.

D. Provisions for data collection and storage.

Acceptance and rejection criteria as specified in design and procurement documents.

June 2013 17.2-61 Revision 17

DELETE PVNGS UPDATED FSAR 112-F014 QUALITY ASSURANCE DURING THE OPERATIONS PHAS F. Methods of documenting or recording test data and results, in sufficient detail to prevent misinterpretation.

G. ndatory hold or witness points for inspec on by PVN S Nuclear Assurance and/or other desi nated perso el.

H. Provisio s for control of jumpers, lfted leads, and jurisdicti al or safety tags.

I. Provisions fo returning a syst m to normal configuration u n completio of the test, including verification.

J. Provisions for assur g est prerequisites have been met.

17.2.3.6.1.2 Test result shall be documented, evaluated, and their acceptability dete med by a qu ified individual or group.

17.2.3.6.1.3 The test program shall cover a 1 required tests including:

A. Pre erational test of components or sys ms to d onstrate that performance is in accordan e with the design intent.

B Tests during initial operation to demonstrate s tem performance (that could not be tested prior to operation) to confirm compliance to design criteria.

June 2013 17.2-62 Revision 17

DELETE PVNGS UPDATED FSAR 12-F0141 QUALITY ASSURANCE DURING THE OPERATIONS PHASE C. Tests during the operational phase to provide assurance that failures or substandard performanc do n t remain undetected and that the required rel bility of systems within the QA scope is ma~inta ned.

D. Tests du *ng activities associated with lant maintenanc and modifications during e operational phase.

E. Tests to demonst ate satisfactor performance following plant mantenance, m difications, or procedural changes.

17.2.3.6.1.4 Tests performed fo owing plant repairs or replacements shall be conducted In a cordance with the original design and testing requiremen s or app oved, documented alternatives. The extent testing sha be based upon the complexity of the modifi tion, replacemen or repair. Testing shall be sufficient to confirm that the chang s reasonably produce expected res lts and that the change do s not reduce plant safety.

17.2.3.6.2 Re ponsibilities 17.2.3.6.2. Director, Plant Engineering. The Directo Plant En neering is responsible for the startup test func on which sures that new or substantially modified facilities a d June 2013 17.2-63 Revision 17

DELETE PVNGS UPDATED FSAR 12-F0147I QUALITY ASSURANCE DURING THE OPERATIONS PHA sys ems are tested. These responsibilities include providi g a progr which ensures that:

A. Test plans are developed and implemented in cordance wth written, approved, and controlled pro dures.

B. Pers nnel performing tests have the tra' ing and skills required to perform the testin activities.

C. Testing i completed and documente , as required, and test result are evaluated for a ceptability by qualified ind iduals.

D. Test documentati and test document reviews are complete prior to move to Operations.

17.2.3.6.2.2 Director, Engin e ing Programs and Support. The Director, Engineering Progra s and Support has overall responsibility for provid' g a code st program which ensures, at a minimum, that:

A. Testing is erformed in accordan e with written, approved, and controlled procedure .

B. Person el performing tests have the t aining and skil s required to perform the testing ctivities.

C. T st results are documented and evaluated or acceptability by a qualified individual.

D. Identified discrepancies are addressed, resolve and reported as required by the Operating Licenses or other regulatory requirements.

June 2013 17.2-64 Revision 17

DELETE PVNGS UPDATED FSAR F12-F-014i QUALITY ASSURANCE DURING THE OPERATIONS PH E 17.2.3.6.2.3 Director, Nuclear Assurance. The Director, Nuclea Assurance, is responsible for performing Quality Assurance verifications in accordance with Section 17. .4 of this Plan.

17.2.3.6.2.4 VNGS Leaders. PVNGS Leaders ar responsible to incorporate into plicable policies, procedu s, and instructions those r quirements contained i this Plan and the Regulatory Guides and tandards committe to in Appendix 17.2B of this Plan.

17.2.3.7 Control of Measurin and est Equipment 17.2.3.7.1 Requirements 17.2.3.7.1.1 Measures shal be e ablished to assure that tools, gauges, instruments and other measuring and testing devices used in activit s affecting th function or quality of structures, systems, d components cover under the scope of the QA Program, are roperly controlled and alibrated or adjusted at speci ied periods to maintain accu acy within specified limi . Additional measures shall be stablished to ensure that e proper range, type, and accuracy o the measuring nd test equipment is used in order to con rm to the specifie requirements.

Calibration and control measures may not be requ ed for rulers, tape measures, volumetric glassware, an other such devices if commercial equipment provides accuracy adequate to meet specified requirements.

June 2013 17.2-65 Revision 17

DELETE PVNGS UPDATED FSAR 12-F0147 QUALITY ASSURANCE DURING THE OPERATIONS PHA B. NDE equipment shall be controlled and calibrated accordance with the industry code(s) governing s use.

17.2.3.7.1.2 Requirements for each control progr shall include provis ns for verification of accuracy, identification of all instrument, calibration, scheduled rec 11 as appropriate for rec libration, and traceabilty to an accepted Standard.

17.2.3.7.1.3 Calibratio of all it s which are used in the measurement, inspection, an monito ing of components, systems, and structures covered under te A scope shall be traceable to nationally recognized standards. Where national standards do not exist, provisions shall est lished to document the basis for the calibration.

17.2.3.7.1.4 For per anent-plant instr ents which are used in the measurement,npection, and monito *ng of components, systems, and stru ures covered under the QA cope, procedures or instructions hall be established to impleme t the following requirements.

A. tablish the calibration technique and fr uency requirements, maintenance requirements, and ntrols.

Identify all permanent-plant instruments and pr vide traceability to the calibration test data.

C. Installed permanent-plant instrumentation shall be labeled, tagged or otherwise controlled in accordance June 2013 17.2-66 Revision 17

DELETE PVNGS UPDATED FSAR 12-F014I QUALITY ASSURANCE DURING THE OPERATIONS PHASE with written, approved procedures to assure that approved calibration intervals are not exceeded.

D. I stalled permanent-plant instrumentation that fou dout of calibration shall be evaluated o deter 'ne if the condition constitutes a portable occurren e in accordance with Technical Specifications or other regulatory re irements.

17.2.3.7.1.5 For porta le Measuring and T st Equipment which are used in the calibratio measurement, inspection, and monitoring of components, sy ems, and tructures covered under the QA scope, procedures or ins ruct'ns shall be established to implement the following requir ents.

A. Establish the calibra ion echnique, calibration intervals, maintena ce requi ements, and controls.

B. The identificati of Measuring and Test Equipment, traceability t the calibration t st data, and calibration tatus.

C. Measurin and Test Equipment requiring calibration shall clearly labeled, as appropriate, to indicate the te on which the current calibration e pires.

Me suring and Test Equipment that has exceede its alibration interval shall not be used for measurements or tests.

Calibration intervals for Measuring and Test Equipment shall be based on required accuracy, purpose, degree of usage, stability characteristics, June 2013 17.2-67 Revision 17

DELETE PVNGS UPDATED FSAR 112-FOl QUALITY ASSURANCE DURING THE OPERATIONS PHASE and/or any other condition which may affect the measurement.

E. A alibration recall system shall be implemented o ass e that Measuring and Test Equipment is not used past i s calibration interval.

F. Establish methods for determining the vali ity of previous in ections or tests performed when Measuring and est Equipment is found o be out of calibration. Thi determination sha be documented.

Where the validit of previous in pections cannot be established, the ins ected ite shall be identified as "nonconforming" unt ins ctions or tests can confirm acceptability.

G. Establish methods for e alu ing items of Measuring and Test Equipment th t are co sistently found to be out of calibration, to determine the cause of the problem, and res ve it by repairi or replacing the item. _

17.2.3.7.1.6 Proce ures or instructions shall be stablished to implement the f llowing requirements:

A. In al calibrations, the ratio of the calibraton acc racy of the item being calibrated to the ite ing used as the calibration reference shall be greater than 1:1.

In addition, Measuring and Test equipment (M&TE) used to calibrate or test permanent plant instruments June 2013 17.2-68 Revision 17

DELETE PVNGS UPDATED FSAR T12-F014]

QUALITY ASSURANCE DURING THE OPERATIONS PHA E shall have been calibrated against calibration standards with accuracies at least four times eater than that of the M&TE equipment being calibr ted.

C. W n requirements of either A. or B. abov cannot be met, the equipment and/or standards use to perform the ca ibration shall have the requi d precision to assure t at the device being calib ted is within the required t erance. The basis f r acceptability of such calibratons shall be doc mented and approved.

17.2.3.7.2 Responsibilitie 17.2.3.7.2.1 Director, Maint n ce. The Director, Maintenance, is responsible fo e development of the M&TE control program.

17.2.3.7.2.2 PVNGS Le ers. PVNGS Le ders utilizing tools, gauges, instruments, d other measuring vices in activities affecting the funct'on or quality of struct es, systems, components, and a tivities are responsible for A. Assu ing that the equipment is controll d in a ordance with an approved calibration c ntrol rogram which complies with the requirement of this Incorporating into applicable policies, procedure and instructions those requirements contained in ths

/ Plan and the Regulatory Guides and standards referenced in Appendix 17.2B of this Plan.

June 2013 17.2-69 Revision 17

DELETE PVNGS UPDATED FSAR 12-F01 QUALITY ASSURANCE DURIN THE OPERATIONS P SE 17.2. .7.2.3 Director, Nuclear Assurance. The Director, Nuclear ssurance, is responsible for performing Qualit Assurance erifications in accordance with Section 17 2.4 of this Plan.

17.2.3.8 Handli , Storage, and Shipping 17.2.3.8.1 Require ents 17.2.3.8.1.1 Measure shall be establis ed and documented to control handling, storag , and shippin , including cleaning, packaging, and preservatio of items ithin the QA scope in accordance with established istru tions, procedures, and drawings to prevent damage, det ioration, or loss. The requirements for handling, st ag , packaging, and shipping of radioactive wastes are cont ned in ection 17.2.3.14 of this Plan.

Procedures shall be es ablished to contr the cleaning, handling, storage, pckaging, and shipping f materials, components, and sy tems in accordance with de ign and procurement req rements to preclude damage, lo s, or deterioration y environmental conditions such as emperature or humidity These procedures shall be implemented y trained individu s. The procedures shall include but not be imited to the ollowing:

A. Packaging and preservation procedures to provide assurance of adequate protection against corrosion, contamination, physical damage, or any effect which would lower the quality of the items or cause June 2013 17.2-70 Revision 17

DELETE PVNGS UPDATED FSAR 112-F014 QUALITY ASSURANCE DURING THE OPERATIONS PHASE deterioration during shipping, handling, or storage.

Special protective environments, special coverings ert gas atmospheres, moisture contents, and te erature controls shall be specified as re ired and t eir existence verified and documented B. Cleaning methods to provide assurance th necessary cleaning o erations are carried out pror to packaging, s rage, or installation. The level of cleanliness re ired, and verifica ion and documentation re irements shal be specified in the procedures.

C. Detailed handling meth ds r all items that require special handling. Speci handling tools and equipment shall be pro ide and controlled to ensure safe and adequate ha dling. hese tools and equipment shall be maintaine , inspected, and tested in accordance with ritten procedure at established intervals to sure their.reliabili and availability for use. / ..

D. Storage ractices to provide for methods f storage and th control of items in storage which 11 mini ize the possibility of damage or deterio ation d ing storage. Periodic inspections of storag areas shall be performed and documented to verify compliance with storage procedures. Release of items for installation shall also be procedurally controlled.

June 2013 17.2-71 Revision 17

PVNGS UPDATED FSAR F1-2--F 1 0-14--] 1 1ýýý QUALITY ASSURANCE DURING THE OPERATIONS PHA E. Provisions to assure that proper marking and labeing of items and containers is accomplished to provi e i entification and necessary instructions dur g pac aging, shipment, and storage.

F. Provis'ons for documenting and reporting nonconfo mances with handling, storage, and shipping requiremen s.

G. Provisions fo the storage of chem' als, reagents, lubricants, an other consumable +/-naterials which will be used in conjun tion with qu ity related systems.

H. Provisions for "Limited Life requirements (including "Shelf Life" for appli ab materials).

17.2.3.8.2 Responsibilities 17.2.3.8.2.1 Director Supp Chain. The director supply chain, is responsible for:

A. Providing the ocedures applicab e to receiving, shipping, an storage of materials, parts, and components B. Assurin that the personnel responsible or handling and s rage of materials, parts, and compo ents are tra ed in the performance of their duties a d that t y implement the procedures properly.

C. Providing adequate storage of materials, compone s, and parts within the QA scope.

June 2013 17.2-72 Revision 17

DELETE PVNGS UPDATED FSAR 112-F014 QUALITY ASSURANCE DURING THE OPERATIONS PHA

17. 3.8.2.2 Senior Vice President, Site Operations. The senior vice president, site operations, is responsible fo A. ssuring that the handling, cleaning, and sto age a ivities associated with the operation a main enance of PVNGS are performed in ac rdance with the re uirements of this Plan.

B. Assuring hat the handling, cleanin , and storage requirement of this Plan are inc porated in the procedures an are properly imp emented for all maintenance and odification ctivities.

17.2.3.8.2.3 Director, Nucl ar A surance. The Director, Nuclear Assurance, is responsib for performing Quality Assurance verifications in ac rd nce with Section 17.2.4 of this Plan.

17.2.3.8.2.4 PVNGS Le ers. PVNGS Le ers are responsible to incorporate into applicable policies, pro dures, instructions, drawings, specifica ions, or procurement doc ents those requirements cont ined in this Plan and the Re ulatory Guides and standards mmitted to in Appendix 17.2B of is Plan.

17.2.3.9 uipment Status and Control 17.2.3. .1 Measures shall be established for the cont 1 and statu of equipment, as necessary, to maintain personnel d rea or safety and to avoid unauthorized operation of e uipment. In addition, measures shall be established and documented to ensure that required inspections and tests are June 2013 17.2-73 Revision 17

DELETE PVNGS UPDATED FSAR 1F 014-I]

QUALITY ASSURANCE DURING THE OPERATIONS PH E perf med and that the acceptability of these items is know throug ut manufacturing, installation, and operation. T se measures hall be documented in procedures and shall r quire that:

17.2.3.9.1.1 ontrol measures, such as lockin or tagging to secure and identi equipment in a controlled tatus, are established.

17.2.3.9.1.2 Independe t verification , where appropriate, to ensure that necessary meas res, such s tagging, have been correctly implemented.

17.2.3.9.1.3 The status of i ctions and tests performed upon individual items shall e ind ated by the use of markings such as stamps, tags, labe s, routin cards, or other suitable means.

17.2.3.9.1.4 Item that have satisfactori passed required inspections and t ts, shall, where necessary, be identified to preclude inadve tent bypassing of required inspe tions and tests on othe similar items which may not have be n inspected or tested.

17.2.3. .1.5 When required documentary evidence of pas ed insp ctions and tests is not available, the associated e ipment or materials shall be considered nonconforming.

nless suitable documentary evidence is available to show the equipment or material is in conformance, affected systems shall June 2013 17.2-74 Revision 17

DELETE PVNGS UPDATED FSAR FTF1012F4 QUALITY ASSURANCE DURING THE OPERATIONS PHASE be con idered to be inoperable and reliance shall not be placd on such stems to fulfill their intended safety functions.

17.2.3.9.1.6 Documented permission from the operatio organization be obtained prior to releasing equipmen or systems for maint nance or modification. Operatio s personnel shall verify that e ipment or system can be rel ased and determine how long it ay be out of service. ttention shall be given to the potentia ly degraded degree of protection when one subsystem of a redunda t safety syste has been removed for maintenance.

17.2.3.9.1.7 After permission h been granted, equipment shall be made safe to work on. qui ment and systems in a controlled status shall be cle rly id tified. Measures shall provide for protection of e ipment and orkers.

17.2.3.9.1.8 When equ' ment is ready to be returned to service, operating pe sonnel shall place the e Uipment in operation and verif and document its functional cceptability.

Documentation of unctional acceptability shall be raceable to the equipment. Attention shall be given to restorati n of normal condi ions.

17.2.3.9.1.9 Design documents or other appropriate docume s addre the requirements for the identification of inspection, tes and operating status.

June 2013 17.2-75 Revision 17

FSAR F0 14-1I2 --

DELETE PVNGS UPDATED QUALITY ASSURANCE DURING THE OPERATIONS PHAS 17.2.3.9.1.10 Bypassing or altering the sequence of insp tions, tests, or other critical operations shall be proced ally controlled. These procedures require concu rence from the uclear Assurance organization.

17.2.3.9.1.11 Temporary modifications, such as t porary bypass lines, e ctrical jumpers, lifted electrcal leads, and temporary trip po t settings, shall be contr lled and shall include a requiremen for either independe verification or functional test which onclusively prove the installation and subsequent removal of th temporary mo ification. A log shall be maintained of the curre status f such temporary modifications.

17.2.3.9.2 Responsibilities 17.2.3.9.2.1 Senior Vice resident Site Operations. The senior vice president, s e operations is responsible for assuring the appropria e/requirements fo control of equipment, inspection, test, a operating status, in uding independent verification, are ncorporated in the procedu es on all fabrication, in allation, test, and operating ctivities.

17.2.3.9.2. Director, Nuclear Assurance. The di ctor, nuclear surance, is responsible for performing Qual y Assura e verifications in accordance with Section 17.2. of June 2013 17.2-76 Revision 17

12-F0147 DELETE PVNGS UPDATED FSAR QUALITY ASSURANCE DURING THE OPERATIONS PHA

17. .3.9.2.3 PVNGS Leaders. PVNGS Leaders are responsibl for in orporating into applicable policies, procedures, ad instructons those requirements contained in this Plan nd the Regulatory uides and standards committed to in Appe ix 17.2B of this Plan.

17.2.3.10 Houseke ing and Cleanliness 17.2.3.10.1 Requirem nts 17.2.3.10.1.1 Good hou ekeeping practic s shall be utilized at all times to maintain the facilities a neat and clean condition. Housekeeping en mpasse all activities related to the control of cleanliness of aclities, materials, and equipment; fire prevention and otection including disposal of combustible material and deb is; c trol of access to areas, protection of equipment, a d radioac ye contamination control; and storage of solid ra oactive waste.

17.2.3.10.1.2 Hous eeping practices shall assure that only proper materials, equipment, and processes, a utilized and that the qualit of the item is not degraded as result of housekeeping ractices or techniques. During main enance activities certain portions of quality related syst s or componen s may be subject to potential contamination wi h forei materials. To prevent such contamination, contro mea res, including measures for access control, and tool a countability, shall be established. Additionally, immediately prior to closure of system(s) or component(s), a verification shall be conducted and documented to ensure June 2013 17.2-77 Revision 17

DELETE PVNGS UPDATED FSAR 112-F°14 QUALITY ASSURANCE DURING THE OPERATIONS PHA clea liness. Special housekeeping considerations shall be ade for ma'ntenance of radioactively contaminated systems an componen s.

17.2.3.10.2 Responsibilities 17.2.3.10.2.1 nior Vice President, Site Oper ions. The senior vice presi nt, site operations, is re ponsible for establishing and mai taining programs and actices for housekeeping and clean ness control for ork activities performed by the plant s e staff, sup ort organizations, and contractors in accordance wth the r quirements of the QA Program.

17.2.3.10.2.2 Director, Nucl r surance. The director, nuclear assurance, is respo sible fo performing Quality Assurance verifications i accordance ith Section 17.2.4 of this Plan.

17.2.3.10.2.3 PVN Leaders. PVNGS Leaders re responsible for incorporatin into applicable policies, pro edures, and instructions t ose requirements contained in this Plan and the Regulatory ides and standards committed to in App dix 17.2B of this P an.

June 2013 17.2-78 Revision 17

DELETE PVNGS UPDATED FSAR 12-F014 QUALITY ASSURANCE DURING THE OPERATIONS PHASE 17.2.3.11 Control of Construction, Maintenance (Preventive/Corrective), and Modifications 17.2.3.11.1 equirements 17.2.3.11.1.1 Construction, maintenance, or modific ions which have the p ential to affect the functioning f structures, system or components within the QA scope shall be performed in a manner to ensure quality at lea t equivalent to that specified in the o iginal design bases nd requirements, materials specification, d inspection r uirements. A suitable level of confidenc in structu s, systems, or components on which maintenan or mo ifications have been performed shall be attained by a pr priate inspection and performance testing. Constructio maintenance, or modification of equipment shal be p eplanned ard performed in accordance with written proc dures, in ructions, or drawings appropriate to the circums ances which co form to applicable codes, standards, specifcations, and crite ia. In this regard, modification pe work in areas and s stems of the plant, which are cr ical to the safe operation f the plant, shall not be perf med without specific, advanced pproval in each instance b the designated Operations managemen personnel. intenance shall be performed in a manner such that licens limits are not violated.

June 2013 17.2-79 Revision 17

DELETE PVNGS UPDATED FSAR QUALITY ASSURANCE DURING THE OPERATIONS PHA

17. .3.11.1.2 Written procedures are subject to general admin trative controls that govern or define the followig areas:

A. M thods for obtaining permission and cleara ce from ope tions personnel to work and for app priately loggin such work.

B. Factors be taken into account, i luding the necessity o maintaining occupati al radiation exposure as w as is reasonabl achievable (ALARA).

C. Method for identfying what rocedural coverage is necessary for the aintena ce, construction, and modification activit.

D. Considerations for s t /equipment cleanliness control.

E. Method for identfication of ost maintenance, construction, r modification sting, including testing req red to demonstrate stem/equipment functiona capability to meet opera ional requirements in all espects.

F. Meth d for ensuring that maintenance, co struction, or mo ification activities, performed either n-site or ff-site, are properly reviewed.

G Considerations for other activities already tak g place in the general area.

June 2013 17.2-80 Revision 17

DELETE PVNGS UPDATED FSAR 120 I QUALITY ASSURANCE DURING THE OPERATIONS PHA

17. .3.11.1.3 Skills normally possessed by qualified mainte ance personnel may not require detailed step-by-st delineat'nin a written procedure.

17.2.3.11.1. Means for assuring quality of mainte ance, modifications, r construction activities and me ures to document the per rmance thereof shall be esta ished.

Measures shall be etablished and documented o identify the inspection and test s atus of items to be sed in maintenance, modification, and const uction activitie 17.2.3.11.1.5 A corrective ainten ce program shall be developed to restore structur , stems and components to the quality level required for them o perform their intended functions. Corrective mainte ance shall be performed in a timely manner.

17.2.3.11.1.6 A preve ive maintenance ogram shall be established, includi appropriate procedu s which prescribe the frequency and pe of maintenance to be prformed for structures, syst ims, and components. In all ca es, maintenance shall be sched led and planned so as not to compr ise the safety of t plant. Planning shall consider the p sible safety co equences of concurrent or sequential maint ance, testing or operating activities. Preventive maintenanc shall be pe formed in a timely manner to ensure that quality rel ted ite s are adequately maintained in the original, as designed, nctional status.

June 2013 17.2-81 Revision 17

DELETE PVNGS UPDATED FSAR 12-F0144 QUALITY ASSURANCE DURING THE OPERATIONS PHAS 17.2. .11.1.7 Proposed modifications shall be reviewed, approv and controlled in accordance with the applicable requireme ts of the Operating Licenses, regulatory requirement , and procedures governing the design, pr curement, construction, testing and inspection. Modification to structures, sys is, and components within the Q scope shall be reviewed and a epted in accordance with th requirements of Section 17.2.2.9 of his Plan.

17.2.3.11.1.8 Design, p ocurement, cons ruction, testing, and inspection of all modifica *ons shall e performed in accordance with the applicab port'ns of this Plan.

17.2.3.11.1.9 Deficiencies ide 'fied during installation shall be identified for resol tion sing the appropriate documentation as identified in the im lementing procedures.

17.2.3.11.1.10 Organiz ions performing c struction, maintenance, or modi cations shall notify sponsible inspection personn and, where applicable, th Authorized Inspection Agenc of all witness and hold points in sufficient time for perfo mance of required inspections.

17.2.3.11. .11 Deviations from design shall not be per without roper review and approval.

June 2013 17.2-82 Revision 17

DELETE PVNGS UPDATED FSAR 112-F014 QUALITY ASSURANCE DURING THE OPERATIONS PH SE

17. .3.11.2 Responsibilities 17.2.3.11.2.1 Senior Vice President, Site Operations. he senior v e president, site operations, is responsibi for:

A. Es ablishing and implementing preventive nd corr ctive maintenance programs to mai ain the statio in a safe, reliable, and effcient condition.

B. Ensuring hat maintenance and mod ication activities are perform in accordance wit the requirements of this Plan and he applicable perating Licenses, and regulatory requi ements.

C. Establishing admini tratve control procedures for maintenance and modi 'ation work performed.

17.2.3.11.2.2 Vice Preside t, Nuc ar Engineering. The vice president, nuclear engine ring, is r ponsible for:

A. Ensuring tha design and procu ement activities associated ith plant modificati s are implemented in accordan e with approved procedure B. Provi ing the drawings and specificat ns used for pla modifications.

C. reparing and issuing as-built drawings of lant modifications, as appropriate.

Ensuring that modifications are designed, procu d, and installed in accordance with requirements whic are either equal to or better than the original requirements.

June 2013 17.2-83 Revision 17

DELETE PVNGS UPDATED FSAR 12-F014-QUALITY ASSURANCE DURING THE OPERATIONS PHASE Preparing and filing records in accordance with the requirements of the Plan.

F. oviding the design and engineering support duing ins allation and testing of plant modificatio s inclu ing the resolution of deficiencies i ntified during s tallation.

G. Maintainin configuration control.

H. Ensuring prop r approvals for devi ions from design.

17.2.3.11.2.3 Leaders of ganizations nstalling modifications are responsible for:

A. Reviewing the requirem nt of the modification packages and preparing appropriate installation procedures and supporing cumentation.

B. Providing the supe ision and abor necessary to complete the mod* ications.

C. Ensuring that he modifications ar installed in accordance ith the engineering requi ements.

D. Preparin and filing records in accordan e with the requir ments of this Plan.

17.2.3.11.2 4Director, Nuclear Assurance. The Direct Nuclear A surance, is responsible for performing Quality Assura le verifications in accordance with Section 17.2.4 o June 2013 17.2-84 Revision 17

DELETE PVNGS UPDATED FSAR FI01-F4 QUALITY ASSURANCE DURING THE OPERATIONS PHAS

17. .3.11.2.5 PVNGS Leaders. PVNGS Leaders are responsibl to incor orate into applicable policies, procedures, instruc ons, drawing specifications, or procurement documents thos requiremen s contained in this Plan and the Regulator Guides and standar committed to in Appendix 17.2B of thi Plan.

17.2.3.12 Contro of Surveillance Testing and spection 17.2.3.12.1 Require ents 17.2.3.12.1.1 Surveil ance testing and i spection programs shall be established an implemented i accordance with the Operating Licenses require ents of t plant to ensure that quality related structures, stem , and components will continue to operate to maintai arameters within normal bounds, or will act to put the p nt in a safe condition if parameters exceed normal bo ds.

17.2.3.12.1.2 Provisio shall be made for performing required surveillance testing d inspections, inc ding inservice inspections. Such rovisions shall include he establishment of a master survellance schedule reflecting te status of all planned in-pla surveillance tests and inspecti ns. Frequency of surveilla e tests and inspections shall be in ccordance with Opera Ing Licenses unless increased frequency i warranted by relia ility analyses, type of service, or age of the item or 17.2.3.12.1.3 Additional control procedures shall be nstituted, as necessary, to assure timely conduct of June 2013 17.2-85 Revision 17

DELETE PVNGS UPDATED FSAR 12-F014 -

QUALITY ASSURANCE DURING THE OPERATIONS PHA su eillance tests and inspections, and appropriate docu ntation, reporting, and evaluation of the results.

Procedu es shall be established to assure proper revie of surveilla ce test data and the return of systems to operable status foll ing the completion of testing. These rocedures shall include rovisions for the documentation o authority, conduct, responsbility, and verification invo ved in returning the system to an o erable status. Such provsions shall include the use of p ocedures, checklists and independent verification as approp ate, considerin the degree that system status was altered duin the perform nce of the test.

17.2.3.12.2 Responsibilities 17.2.3.12.2.1 Director, Opera i ns The Director, Operations has overall responsibility f r pro iding a surveillance test program which ensures, at minimum, that:

A. Surveillance sts are perfor d in accordance with written, ap oved, and controlle procedures that implement the surveillance test re uirements of the Operati g Licenses applicable to eac unit.

B. Surv illance test requirements are comp eted as C. Surveillance test personnel have the trainin and skills required to perform surveillance test a inspection activities.

D. Test results are documented and evaluated for acceptability by a qualified individual.

June 2013 17.2-86 Revision 17

DELETE PVNGS UPDATED FSAR 12-F014 QUALITY ASSURANCE DURING THE OPERATIONS PHASE 17.2. .12.2.2 Director, Plant Engineering. The Director, Plant E ineering has the overall responsibility for an inspection program covering the main steam/pressurizer s ety valve testin as well as the integrated safeguards tra testing which sures that:

A. Inspectons are performed in accordance ith written, approved, nd controlled procedures t at implement the inspect n requirements of the perating Licensing appl cable to each uni B. Inspection requi ments are c pleted as required.

C. Inspection personne have t e training and skills required to perform in p tion activities.

D. Inspection results are d umented and evaluated for acceptability by a alifie individual.

17.2.3.12.2.3 Director, gineering Prog ams and Support. The Director, Engineering P ograms and Support as the overall responsibilities for *nservice inspection and *nservice testing (ASME Section XI a OM code), 10CFR50 Appendix containment inspection and t ting, and performance of nondest uctive examinations E).

17.2.3.12. .4 -Director, Nuclear Assurance. The Directo Nuclear ssurance, is responsible for performing Quality Assur ce verifications in accordance with Section 17.2.4 of thi Plan.

June 2013 17.2-87 Revision 17

-DELETE PVNGS UPDATED FSAR 12-F014 QUALITY ASSURANCE DURING THE OPERATIONS PHA 17.2. .12.2.5 PVNGS Leaders. PVNGS Leaders are responsibli for:

A. oviding schedules and manpower necessary t imp ement the Surveillance Testing and Ins ction Progr B. Incorpor ting into applicable policie , procedures, instructio , drawings, specificati ns, or procurement documents th e requirements cont med in this Plan and the Regula ry Guides and s andards committed to in Appendix 17.2B of this P1 17.2.3.13 Radiological Control 17.2.3.13.1 Requirements 17.2.3.13.1.1 A radiologica contro program shall be established and implemente to:

A. Control radia on hazards.

B. Avoid acci ntal radiation exposure C. Maintain exposures to workers and the eneral popul ion as low as is reasonably achie able (ALARA) and ithin regulatory requirements.

D. Povide guidance and specify appropriate meth ds or techniques to ensure that the performance of activities are in accordance with sound radiologi1 control principles and in compliance with applicable regulatory requirements.

June 2013 17.2-88 Revision 17

DELETE PVNGS UPDATED FSAR 112-F°147]

QUALITY ASSURANCE DURING THE OPERATIONS PHAS

17. .3.13.1.2 The radiological controls program is to be fu y integ ated into the applicable activities of each and ever phase o operations at the nuclear generating station.

17.2.3.13.1.3 Procedures shall be provided for the implementatio of the radiological controls progr. These procedures shal contain the requirements for i plementation of the program by the radiation protection mana r and the requirements for inc usion of radiological ontrols in the plant operation, maint ance, and testin procedures.

17.2.3.13.1.4 The radiolo cal cont ols program includes the acquisition of data, and pro Sion for equipment necessary to perform radiation surveys, meas ements and evaluations for assessments and control of ra o gical conditions.

17.2.3.13.2 Responsibi ties 17.2.3.13.2.1 Radiatio Protection Mana er. The Radiation Protection Manager i also known as the di ector, radiation protection or dire or, site radiation prote ion and the titles may be usd interchangeably throughout e UFSAR and Technical Specfications. This position is resp sible for:

A. E ablishing and maintaining the radiologi al controls rogram.

B Providing the personnel, procedures and adminis ative controls to implement the radiological controls program.

June 2013 17.2-89 Revision 17

DELETE PVNGS UPDATED FSAR 12-F014 QUALITY ASSURANCE DURIN THE OPERATIONS PH SE C. Providing administrative and technical guidance applicable to radiological controls, radioacti e materials, respiratory protection and radiol gical engineering including ALARA programs and simetry c trol.

17.2.3.13.2.2 irector, Nuclear Assurance. he Director, Nuclear Assurance, is responsible for perf ming Quality Assurance verificati ns in accordance wi Section 17.2.4 of this Plan.

17.2.3.13.2.3 PVNGS Leade s. PV S Leaders are responsible for incorporating into appli ab policies, procedures, and instructions those requiremen contained in this Plan and the Regulatory Guides and stand rds c rmitted to in Appendix 17.2B of this Plan.

17.2.3.14 Control Radioactive Wast 17.2.3.14.1 Re irements 17.2.3.14.1.1 rocedures and administrative ontrols shall be developed an implemented to cover the followin A. rocessing of radioactive wastes includin the collection, handling, and preparation for s ipment of radioactive liquids and solids. These proced es shall be consistent with the ALARA program and all clearly identify the administrative controls and organizational responsibilities.

June 2013 17.2-90 Revision 17

DELETE PVNGS UPDATED FSAR 12-F014 QUALITY ASSURANCE DURING THE OPERATIONS PH SE Training and qualification of personnel operating radioactive waste processing equipment, health hysics onitoring, packaging and shipping (which in udes wa te classification and establishment of ste char cteristics), and other operations d emed approp 'ate by management.

C. The activties associated with the ckaging of radioactive astes to include the roper selection of the receptacl to be used for ontaining the waste materials, the lection of t e shipping containers (structures used contain and support the receptacle and its contents), etabishment of Waste Characteristics, radio gical control inspections of the outside of the p ka e, and the preparation of documentation. Th activi ies shall be in accordance with regulatory equirements.

D. Movement of r ioactive materia s within and outside the protect area to assure pers nnel protection at all times . .

E. The sh ment of radioactive material cm the station.

F. The ackaging used for transporting of ra ioactive w tes, whether purchased from an outside s pplier or esigned by PVNGS.

G Minimization of the generation of radwaste mate als through training programs, prudent scheduling, pro er use of equipment, and good housekeeping practices.

June 2013 17.2-91 Revision 17

DELETE PVNGS UPDATED FSAR 12-F014 QUALITY ASSURANCE DURING THE OPERATIONS PH E

17. .3.14.1.2 Procedures shall also be developed for minimizing the generation of radwaste materials, the pro ssing of radi active waste, and movement of radioactive mate als.

These pro dures include the following:

A. Training of personnel in the methods to inimize the gener tion of radwaste materials.

B. Processi g and packaging of liquid nd solid waste.

C. Collection nd identification of radioactive solids such as rags, papers, boots, oves, etc.

D. Selection of the proper pac aging for the specific contents to be shi ped, t king into consideration the radiation levels, co ta ination limits, and shipping requirements. Provi s for surveying the packaging for radiation leves, ap opriate package markings, shipping papers! anifests ad certificates, the security seals and advising he carrier that the shipment is eady.

E. Review an acceptance of carrier p ocedures specified by the rocurement documents coverin the acceptance of r ioactive waste materials for shi ent.

F. Re iew and acceptance of the designs of p ckaging urchased from an outside supplier.

17.2. .14.1.3 The carriers to be used for transporting o ra oactive wastes shall be selected on the basis of their perience, knowledge of DOT regulations, control and maintenance of their equipment, and the selection and control June 2013 17.2-92 Revision 17

DELETE PVNGS UPDATED FSAR 12-F014 QUALITY ASSURANCE DURING THE OPERATIONS PHA of t eir drivers. The carrier is required to have or shall e suppli documented procedures covering acceptance of mat rials from a s .pper, certification requirements, placarding, stowage control, re orting of incidents, and security.

17.2.3.14.1.4 adwaste operations shall be cont lled to minimize personne exposures or environmental ontamination consistent with ALA .

17.2.3.14.2 Responsibil ies 17.2.3.14.2.1 Radiation P tection nager. The Radiation

Protection Manager is respon ble r:

A. Developing and impleme ing radwaste procedures.

B. Monitoring all radi ogic 1 activities associated with the processing an handling of radioactive wastes and for providing a vice on radio gical matters relating to processin packaging, and s *pping.

C. Incorporatng into applicable poli *es, procedures, and ins uctions those requirements ntained in the Regul ory Guides and standards committ d to in App dix 17.2B of this Plan.

17.2.3.1 .2.2 Director, Nuclear Assurance. The Direc r, Nuclea Assurance, is responsible for performing Nuclear Assu ance verifications in accordance with Section 17.2.4 o th's Plan.

June 2013 17.2-93 Revision 17

DELETE IPVNGS UPDATED FSAR F-F0j1-4 QUALITY ASSURANCE DURIN THE OPERATIONS P SE

17. .3.14.2.3 PVNGS Leaders. PVNGS Leaders are responsi e for corporating into applicable policies, procedures, nd instru ions those requirements contained in this Pla and the Regulator Guides and standards committed to in App ndix 17.2B of this Pla 17.2.4 CONTR OF QUALITY VERIFICATIONS A SELF ASSESSMENTS 17.2.4.1 Policy A comprehensive Quali y Verification Pr gram shall be established and impleme ted to provi verification that Plan requirements are implemen ed.

17.2.4.2 Level I Verificatio Activities at this level co sist f worker verifications, supervisory verifications second rty verifications, independent verificatio s, and indepe.dent inspections for the purpose of establish g acceptance of e uipment, systems and activities within e QA scope.

17.2.4.2.1 Re irements A program f verification of items within the Q scope shall be estabished and executed by, or for, the organi tion performing the activity to verify conformance to the ocumented instr ctions, procedures, and drawings for accomplishin the ac vity. Design specifications, drawings, procedures, o

. structions shall include the necessary requirements for performance of verification activities. These requirements June 2013 17.2-94 Revision 17

DELETE PVNGS UPDATED FSAR 1 L2-F0147 QUALITY ASSURANCE DURING THE OPERATIONS PHA in ude acceptance criteria and reference codes, standards, nd regu tory documents. These requirements shall be furthe transla ed into procedures, instructions, or checklists which shall con an, as required, the following:

A. Ide tification of characteristics and ac vities to be veri ed.

B. Methods o be used including necess y measuring and test equip ent and the accuracy r quirements.

C. Identificatio of the organiza ion responsible for performing the erification.

D. Acceptance and rej ction riteria.

E. Identification of re ed procedures, drawings, and specifications, in di g the applicable revisions.

F. Provisions for do mentati n of verification results including identfication of he individual performing the verificaton.

17.2.4.2.1.1 The organization that initiat s work implementing doc ments is responsible for iden ification of tasks which r uire worker verification, supervi ory verificatio , second party verification, independet verificaton and independent inspection. Procedures hall be develo d to provide appropriate guidelines used in tas sele ion.

.2.4.2.1.2 The Nuclear Engineering organization is responsible for the identification of attributes that require June 2013 1V. 2-95 Revision 17

DELETE PVNGS UPDATED FSAR 112-F014 QUALITY ASSURANCE DURING THE OPERATIONS PHA ind endent inspection. The Nuclear Assurance organization ay elect o identify additional attributes requiring indepen ent inspecti n based on quality history, trending, and othe informatio that indicates the need for increased in pendent inspection.

17.2.4.2.1.3 W ker Verification. Worker v ifications provide a confirma *on of the product qualit provided by the worker who performed he tasks (i.e., the orker checks the quality of his/her own ask(s)). The wo ker is responsible and accountable for the prope completion nd documentation of the task(s) in accordance with e cont olling document or procedure. Worker verificatio m y be requested by the organization initiating work i ementing documents for quality related tasks. A sign-off f wor er verification shall be provided in the work docum t when w ker verification is requested.

17.2.4.2.1.4 Super isory Verification. pervisory verifications provde a confirmation of produ t quality by technically cog zant supervisory personnel sub equent to worker verifi tion. Supervisory verification ma also be requested b the organization initiating work imple nting documents for quality related tasks. A sign-off for t e supervi ory verification shall be provided in the work dcument when upervisory verification is requested.

.2.4.2.1.5 Second Party Verifications. Second party verifications are performed during activities where a second June 2013 17.2-96 Revision 17

DELETE PVNGS UPDATED FSAR 112-F014 QUALITY ASSURANCE DURING THE OPERATIONS PHASE check of the work is desired to provide an additional measure of the uality of the work performed.

Second par verifications are performed by individuals w o are knowledgeabi in the activity being validated and who m y have responsibility or performing the work, but did not prform the specific activit being checked. A sign-off for s ond party verification shall e provided in the work docum t.

17.2.4.2.1.6 Independ nt Verifications. I dependent verifications are perform on activities ere an independent review of correct performan is desire or when required by code, standard, or regulatory ommitm t.

Independent verifications are pe o med by qualified individuals who do not have resp sibility for performing or directly supervising the work.

Independent verifications m be conduct d by second line supervisory personnel or y other qualifie personnel not assigned first line sup rvisory responsibili for the conduct of the work. Indepen ent verifications are no intended to dilute or replace e clear responsibility of the first line supervisors for e quality of the work performed u der their supervision. sign-off for independent verification hall be provided in e work document.

Independe t verification data and results shall be evaluat by designa ed personnel to assure that the acceptance criteria have een met and that items requiring action or follow-up are id tified and documented.

June 2013 17.2-97 Revision 17

DELETE PVNGS UPDATED FSAR FI01-4i QUALITY ASSURANCE DURING THE OPERATIONS PHASE Reco ds shall be kept in sufficient detail to provide adequat confir ation of an independent verification program.

17.2.4.2.1.7 Independent Inspections Independent i spection is performed on activities in which a high degree of dependence is desired to assure rrect performance was a omplished or when required b code, standard, or regulat ry commitment.

Independent inspection s performed by ANS N45.2.6 certified inspectors, by individual in organizati ns authorized by the Nuclear Assurance organizatin to perf rm those activities and who meet the requirements of SI N .2.6, and by NDE personnel certified in accordance with ap able codes and standards.

Inspectors (including NDE pers ne shall be qualified in accordance with applicable c es, st dards, and PVNGS training programs and their qualifi ation and/or certification shall be maintained current and d cumented.

Selected quality rela ed work authorizing do uments shall be reviewed by the Nuc ear Assurance organization to determine the need for and ann ation of additional attributes equiring independent in ection.

When indepe ent inspection hold points have been est lished, either co ractually by procurement, or internally by p nt procedu es, work may not proceed beyond the hold point unt'l eithe the inspection is performed satisfactorily or-waived in viduals assigned waiver authority.

June 2013 17.2-98 Revision 17

DELETE PVNGS UPDATED FSAR 12-F014 QUALITY ASSURANCE DURING THE OPERATIONS PHAS Whe independent inspection is being performed on previous accept d lots, sampling inspection shall be representativ and shall be applied only to the extent necessary to assure adequacy o control. The sampling plan shall be revi wed and concurred wi by the Nuclear Assurance organizatio.

Inspection per nnel shall be provided with suit le equipment and tools, which re calibrated as necessary, d controlled to assure that accurac requirements are satisfied and that inspections are compl te.

Inspection data and resu ts shall be ev uated by designated personnel to assure that t e acceptan e criteria have been met and that items requiring act n or ollow-up are identified and documented.

Records shall be kept in suffi ie detail to provide adequate confirmation of an inspecti progra 17.2.4.2.2 Responsibil ies 17.2.4.2.2.1 PVNGS eaders. PVNGS Leader are responsible for:

A. Ensuri g that the requirements for wor r yeni ication, supervisory verification, s cond party v ification, independent verification, an ndependent inspection are incorporated into ork implementing documents.

B. Incorporating into applicable policies, procedures and instructions those requirements contained in this P1 June 2013 17.2-99 Revision 17

DELETE PVNGS UPDATED FSAR [-F120 14 QUALITY ASSURANCE DURING THE OPERATIONS PHA and the Regulatory Guides and standards committed o in Appendix 17.2B of this QA Plan.

C. otifying the Nuclear assurance Division of e work be'ng performed.

D. Assu *ng that established independent i pection hold points re not bypassed without prior authorization by individua s assigned waiver authori y.

E. Assuring tha all information, r cords or copies of records associ ed with their ork are made available to Nuclear Assura ce person 1.

F. Assuring that the p son 1 performing Level I Verifications are quaY ied in accordance with applicable codes, st da ds, training programs and procedures.

G. Assuring that t e results of evel I Verifications are properly docu ented.

17.2.4.2.2.2 Vic President, Nuclear Engine: ring. The Vice President, Nucle r Engineering, is responsible or ensuring that verifica on requirements are included in ap opriate design spec ications, drawings, procedures and ins uctions and that ese documents include acceptance criteria a d, as applica le, references to codes, standards and regulator dounts..

June 2013 17.2-100 Revision 17

DELETE PVNGS UPDATED FSAR 12-F014 QUALITY ASSURANCE DURING THE OPERATIONS PHA

17. .4.2.2.3 Director, Nuclear Assurance. The Director, Nucle r Assurance is responsible for:

A. Independent inspections performed by the Nuc ar

surance Division.

B. Ass ing that Nuclear Assurance inspecton personnel are qu lified in accordance with applicable codes, standard , and PVNGS training progr ms.

C. Reviewing s lected work authorizng documents for inclusion of ditional indep dent inspection points.

D. Development of p ocedures d other documents necessary to faciltate clear Assurance independent inspections.

E. Making decisions on at rs concerning inspection and acceptance to cri eria est blished by the Vice President, Nuci ar Engineeri .

17.2.4.2.2.4 Direc or, Engineering Prog ms and Support. The Director, Engineerng Programs and Support, *s responsible for performing NDE accordance with applicable c des, standards, and regulator requirements.

17.2-4.3 evel II Verifications Activi ies at this level are primarily those of survey, surv illance, monitoring, and document review and are per rmed a deemed necessary by the Director, Nuclear Assurance. The e ctivities are used to establish adequate confidence that activities within the QA scope are being performed in June 2013 17.2-101 Revision 17

DELETE PVNGS UPDATED FSAR 12-014 QUALITY ASSURANCE DURING THE OPERATIONS PHAS acco dance with QA Program requirements and plant admini rative controls.

Procedure and instructions are established and record of the verificatio activity shall be completed and maintai ed. Such surveillance a d/or monitoring normally includes o servation of tests and inspec ions, observation of selected erations, review of records, erification of test repor, and direct verification on a sp -check basis.

17.2.4.3.1 Requirements 17.2.4.3.1.1 A program fo monitorng, survey, surveillance, and document review activities wi in the QA scope shall be established.

17.2.4.3.1.2 Survey, Surv nd Monitoring. Survey, surveillance, and monitorng are used t establish adequate confidence that activites within the QA cope are being performed in accorda e with the QA Program requirements and plant administrati controls. The level of rvey, surveillance, or monitoring applied is consiste with the activities or tem's importance to safety and the xtent of Level I ver ication applied.

Survey, rveillance, and monitoring personnel shall be qualifed in accordance with documented procedures.

June 2013 17.2-102 Revision 17

DELETE PVNGS UPDATED FSAR V2-F014 QUALITY ASSURANCE DURING THE OPERATIONS PHAS Sur ey, surveillance, and monitoring reports shall contain, s a min um, the following:

A. Identification of the activity being observed i cluding specific reference to the program or pro edural requirements governing the ac vity.

B. Identi ication of compliance.

C. Identific tion of the individual ob erving the activity.

D. Appropriate di tribution to s ervisory or managerial personnel who ha responsi lity for performance of the activity.

E. Identification of eac onconformance and action taken when such nonconform nce exist.

Records shall be kept in s ficient etail to provide adequate documentation of surveys surveillance and monitoring activities.

17.2.4.3.1.3 Doc ent Reviews. A program r reviewing documents that i plement quality related activi ies shall be established t verify incorporation of the requir ents of this Plan. _/.. .. " _*

Review o plant procedures and other documents shall b perfor ed on a graded or sample basis as part of verifica ion acti ities. The purpose of such reviews is to verify that uch do uments will be or are appropriate for use.

June 2013 17.2-103 Revision 17

DELETE PVNGS UPDATED FSAR F12-F0147]

QUALITY ASSURANCE DURING THE OPERATIONS PHA Th types of documents typically reviewed include plans, proc ures, temporary procedures, instructions, procureme t docume s, engineering documents, and work authorizing documents Refer to Section 17.2.6.3.1.1 for specifc types of documents t at shall periodically be verified for ocument review.

Plans procedures, instructions, and changes t ereto that shall be reviewed by Nuc ar Assurance personnel rior to implementation shall e identified in ad nistrative control procedures. The timing and extent of uch reviews shall be prescribed by procedures d shall b consistent with the text and Appendix 17.2B of this an, d the following:

" Changes to quality classi cation procedure(s) and review and approval procedure( sh 11 be reviewed by Nuclear Assurance prior to im lementat n of the change.

Procurement and en ineering docum ts that prescribe technical and/o quality requirement for items, parts, materials, an changes to the existing lant configuration shall be re iewed prior to issue if insp ction requireme ts are to be revised or affected.

When docume ts do not comply with requirements of e QA Progr , the noncompliance shall be resolved thro h an approv process or a nonconformance/corrective action rocess depe ing on the status of the document at the time of re iew, ty e of document, and its importance to safety.

June 2013 17.2-104 Revision 17

DELETE PVNGS UPDATED FSAR 112-FO14 QUALITY ASSURANCE DURING THE OPERATIONS PHA Reviews may address the technical correctness or performanc objec 'es in addition to the review for compliance with e QA Prog m.

Records sha 1 be kept in sufficient detail to provid adequate documentation of reviews.

17.2.4.3.2 Respo sibilities 17.2.4.3.2.1 Direc or, Nuclear Assurance. The Director, Nuclear Assurance, is esponsible for:

A. Establishing th requirement for Level II activities.

B. Assuring that Nucle r Ass ance personnel performing Level II activities a e adequately trained and qualified to perform h ir duties.

C. Assuring that repo ts of t e verification activity have sufficient etail and p ovide adequate confirmation the verificati.

D. Establishi the requirements for he review of document affecting materials, part components, and activi ies within the QA scope.

E. Ass ring that records of document reviews have s fficient detail to provide adequate confi mation of document review activities.

Reviewing and concurring with specific documents and procedures prior to implementation, as identified plant administrative procedures.

G. Reviewing special process procedures.

June 2013 17.2-105 Revision 17

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17. .4.4 Level III Verifications Activi ies at this level are primarily audits and assess nts.

The purp se of this level of activity is to assure, th ugh a comprehensve program of audit and assessment, that e first and second le els of the program are properly func ioning, and that organizati ns conducting activities within he scope of this Plan are pro erly satisfying the require nts of the Quality Assurance P gram. At this level, rocedures and instructions are estab ished, including d cumentation requirements of the audi or third-leve activity.

17.2.4.4.1 Requirements 17.2.4.4.1.1 Audits. An audi program shall be established for both internal and externa fu tions which affect structures, systems, compon nts, op ations and activities within the QA scope. The audit progra shall satisfy the requirements of ANS N45.2.12. The organiation performing audits shall have su icient authority and lines of internal and external commu ications to obtain the ne ssary management attention to audt activities and findings.

Planned and s eduled audits shall measure complia ce with PVNGS Quali y Assurance Policies, Plan, and Program, the Code of Feder Regulations, applicable Regulatory Guides, NSI Standa s, other codes and PVNGS license-based documents, Oper ting Licenses, commitments, procurement requirements as ociated with external organizations providing items, and ervices within the QA scope.

June 2013 17.2-106 Revision 17

PVNGS UPDATED FSAR 12-F014 DELETE QUALITY ASSURANCE DURING THE OPERATIONS PHAS Audit shall include an objective evaluation of quality rela ed practic s, procedures, and instructions, including an obje tive review of ctivities, items, and records which demonstra e effective a proper implementation.

Audits shall b performed in accordance with pre-es ablished written procedure and checklists, and shall be nducted by trained and qualifi d personnel having no diret responsibilities in t e areas being audited. The audit program shall include:

A. Audit schedules.

B. Procedures for prepa ation performance, and reporting of audits.

C. Analysis of audit dat an reporting these results to appropriate levels manag ent.

D. Provisions for f low-up actio E. Qualification f auditors.

F. Delineatio of the authority, respon ibility, and organiza lonal independence of those r sponsible for the au it program.

Audits shall e initiated in a timely manner to assu the effectiven ss of the QA Program. Implementation of cor ective action s all be verified in a timely manner.

Auditd organizations shall provide sufficient support to ass re the accuracy of the audit results, respond to audit nconformances, and resolve deficiencies. The corrective June 2013 1V. 2-107 Revision 17

DELETE PVNGS UPDATED FSAR 112-F014 QUALITY ASSURANCE DURING THE OPERATIONS PHAS acti s required to resolve audit findings and observations shall baddressed in a timely manner.

Audits sha 1 be regularly scheduled, and their frequenc shall be based upo the requirements section 13.4.5, the st us and safety importa ce of activities, degree of previous experience, thoroughness of verall coverage, unique testing perating activities, and fo ow-up of previous audit fi ings. In addition, audits shal be scheduled and perf rmed as required by management. Unsched led audits may be onducted at any time on any aspect of this Pla Records shall be maintained o provi evidence of audit program scope coverage, indivi al udit coverage, audit results, auditor certifications, ollow-up, and verification.

Audits shall be performed by rson 1 who are trained and qualified to the requiremen s defined *n ANSI N45.2.23 (as modified for PVNGS and de cribed in sectin 1.8). Each audit team shall be led by a ualified Audit Tea Leader. Audit team members shall be uti zed as required and sh 1 be classified as either auditors r technical specialists, de ending on their function on the udit team. Additional technical xperts may be assigned to t audit team as deemed necessary.

17.2.4.4. .2 Assessments. An assessment program shal be establi ed for activities within the QA scope. The prog m shall e delineated in procedures and instructions and shall inc ude documentation requirements for the assessment activity.

June 2013 17.2-108 Revision 17

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QUALITY ASSURANCE DURING THE OPERATIONS PH E As ssments are performed by the Nuclear Assurance organiz ion and the Offsite Safety Review Committee (OSRC). Asse ments are per ormance based reviews designed to provide mana ement a measure o the effectiveness of various programs in eeting management pectations and nuclear performance s ndards.

Assessments m be performed in conjunction wit other oversight activi ies, such as Nuclear Assuran e audits and evaluations or OSR independent review acti ities. The Director, Nuclear As rance, and the OSRC*, shall determine the need for assessments. he assessment ope shall be defined.

The results of assessmen shall be ocumented and any corrective action which may be dee ed necessary as a result of these assessments shall be fo ly identified and tracked through resolution.

17.2.4.4.2 Responsibilits s 17.2.4.4.2.1 Directo , Nuclear Assur ce. The Director, Nuclear Assurance, 1 responsible to:

A. Establis and implement the Qualit Assurance audit and a essment program.

B. Pro ide an auditing organization which ets the quirements of this Plan.

C. Evaluate the effectiveness of the audit prog m.

Ensure the development and implementation of th audit schedule.

June 2013 17.2-109 Revision 17

DELETE PVNGS UPDATED FSAR 12-F014 QUALITY ASSURANCE DURING THE OPERATIONS PHA E. Analyze audit data and the results, including the eed for re-audits, and reporting these results to appropriate levels of management.

17.2.4.4.2. PVNGS Leaders of Audited Organizatio s. The PVNGS Leaders f audited organizations are respo ible to ensure:

A. Sufficient support is given to the audit process to optimize the accuracy of the audt results.

B. Sufficient revi w of audit re ults is provided to assure that effec ive preve tive measures for audit nonconformances are efi d and implemented.

C. Responses to audit fi *ngs are reviewed and approved by their organizati s p 'or to submittal to the auditing organiza ion.

D. Responses to a dit findings a submitted to the auditing org nization in a timel manner as defined in implementi g policies, plans, proc dures

_ _ and/or instruc ons.

E. Corr tive actions to resolve audit fin ngs are taken in timely manner.

17.2.4. .2.3 Chairman Offsite Safety Review Committee. The chair n, Offsite Safety Review Committee (OSRC), is res onsible for establishing and implementing an assessment pogram for the Offsite Safety Review Committee.

June 2013 17.2-110 Revision 17

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17. .5 CONTROL OF CONDITIONS ADVERSE TO QUALITY AND CORRECTIVE ACTIONS 17.2.5.1 Policy Measures sh 11 be established which ensure that con tions adverse to qu ity, such as failures, malfunction, deficiencies, de iations, defective material an equipment, and nonconformances ar promptly identified, docu ented, controlled, and corr cted. The cause of s nificant conditions adverse to quality sha be determined a appropriate action taken to prevent recurre e. The iden fication, cause, and actions taken to correct si nificant conditions adverse to quality shall be documented a d re orted to the appropriate levels of management.

17.2.5.2 Requirements 17.2.5.2.1 Conditions A erse to Quali y Conditions adverse to uality include har are problems involving materials parts, components or sy tems which do not comply with estab ished requirements and non-h rdware problems such as comput software deficiencies, failure ocomply with the Licensin Commitments, Technical Specification procedures regulations, design bases, or other estab ished require nts.

It is the responsibility of all organizations and individu ls to dentify and report conditions adverse to quality.

June 2013 17.2-111 Revision 17

DELETE PVNGS UPDATED FSAR 12-0174 QUALITY ASSURANCE DURING THE OPERATIONS PH SE Ac ivities such as examinations or checks performed to ass ss the ondition of equipment or its operation shall be do mented on an propriate form to control the activity. Once t has been det mined that a nonconformance exists, the c dition shall be re orted as a nonconformance and the ite controlled to prevent in dvertent use prior to correction.

Procedures shall be established to assure th t conditions adverse to quality are promptly identifie , documented, controlled, and corr ted. These proce res shall detail and implement, as appropria e, the followng measures:

A. Conditions adver e to qua ity shall be evaluated to determine the need or orrective action.

B. Follow-up activities all be conducted to verify implementation of orre ive actions and to close out corrective acti s in a ti ely manner.

C. Conditions a erse to qualit that are potentially reportable o the NRC shall be dentified to appropri te management personnel or evaluation and repor ng to the NRC as required.

D. Ide tification of nonconforming items appropriate ans (tags, labels, etc.) and segregati if practical, until disposition of the noncon rming item has been determined.

E. Disposition of the condition adverse to quality.

Nonconforming items shall be dispositioned as eith r rework, scrap, repair, or use-as-is. Use-as-is and June 2013 17.2-112 Revision 17

DELETE PVNGS UPDATED FSAR 12-F014 I QUALITY ASSURANCE DURING THE OPERATIONS PHAS repair dispositions require approval and justificaton by the cognizant engineering organization.

F. erification method, verification, and close o t.

G. Re rd retention.

H. Requi ed approval signatures of the disp sition and the ver ication.

Reworked, repaired, nd replacement items sh 1 be inspected and tested in accordan e with the originalinspection and test requirements or acceptab e alternatives. All inspection, testing, rework, and repai shall be ontrolled by approved procedures, and the results cumen d.

Prior to the initiation of a pr erational test on a Quality Related item, all nonconforman es hall be evaluated for significance or impact on fu ther te ting or operation and shall be dispositioned as ppropriate. The evaluation/disposition all be document Conditions adverse t quality shall be peri cally analyzed to detect trends whic may not be apparent to a y-to-day observer. The r sults of analyses shall be repo ted to management for review and assessment. When action are required to orrect problems, such as a generic prob m identifie by trend analysis or repetitive failure to disposi ion nonconformances, these problems shall be elev ted to u er levels of management for resolution.

June 2013 17.2-113 Revision 17

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QUALITY ASSURANCE DURING THE OPERATIONS PHA 17.2.5.2.2 Significant Conditions Adverse to Quality In addi ion to the requirements delineated in Section 17.2.5.2. procedures shall require the identificatio of the cause and t actions to be taken to prevent recurre ce of significant co ditions adverse to quality. These rocedures shall include ad itional requirements for the f lowing:

A. Identific ion of the form to be usd for reporting the signifi nt condition adverse to quality.

B. Description of he significant condition adverse to quality and date f identifi ation.

C. Identification of th re irement violated.

D. Notification to the af cted organizations of the significant conditio adv rse to quality.

E. Nuclear Assurance Division c ncurrence with all dispositions to significant co dition adverse to quality.

17.2.5.3 Respons ities 17.2.5.3.1 Dir ctor, Nuclear Assurance The Director Nuclear Assurance, is responsible for he following:

A. Review and concurrence of all procedures for re rting and controlling conditions adverse to quality in accordance with the requirements of this Plan.

June 2013 17.2-114 Revision 17

DELETE PVNGS UPDATED FSAR F12-F01I QUALITY ASSURANCE DURIN THE OPERATIONS PH SE B. Concurring with the dispositions to significant conditions adverse to quality.

C. Deleted D. erforming Quality Assurance verificatios in ac rdance with Section 17.2.4.

17.2.5.3.2 Exec tive Vice President, Nucle and CNO The executive vice resident, nuclear an CNO, is responsible for the establishment of programs for e reporting and correction of condition adverse to uality. Plant items such as failures, malfunctions, defici cies, deviations and defective materials, parts oc ponents are handled in a manner consistent with their ortance to safety and reviewed in accordance with appropri te p ocedures and the applicable Technical Specification(s . Autho *ty and responsibility for the development and da to-day implem ntation of the programs for the reporting an correction of con itions adverse to quality are delega ed to the senior vice esident, regulatory and oversight, d the director, performanc improvement.

17.2.5.3.3 ice Presidents, Directors and Depar ment Leaders Vice pres dents, directors and department leaders ae respon ble for ensuring that conditions adverse to ality are iden ified and controlled in accordance with approved pr cedures and for ensuring that an atmosphere is created *n he workplace where reporting and resolution of conditions adverse to quality are encouraged at all levels.

June 2013 17.2-115 Revision 17

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17. .5.3.4 The Director, Performance Improvement, is respo ible for:

A. The establishment and day-to-day implementati of p ograms for the reporting, correction, and trend ana sis of conditions adverse to quality.

B. Report g significant conditions adver e to quality to the orga 'zational unit concerned, d the executive vice presi nt, nuclear and CNO,s appropriate.

17.2.6 CONTROL OF DOC ENTS AND REC DS 17.2.6.1 Policy 17.2.6.1.1 The PVNGS Quality s rance Program requires that activities within the QA scope prescribed by documented procedures, instructions, an or d wings of a type appropriate to the circumstances. Actvities are accomplished in accordance with these d uments.

17.2.6.1.2 Measure shall be established a d documented to control the issua ce of documents, such as pro ram documents, design document , instructions, procedures, and rawings, including ch ges thereto, which prescribe activitis as defined in ection 17.2.2 of this Plan. These measu s shall assure t at documents, including changes, are reviewed or adequa y and approved for release by authorized personnel and are istributed to, and used at, the location where the p scribed activity is performed.

June 2013 17.2-116 Revision 17

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17. .6.1.3 Quality Assurance records for items and activi ies covere under the scope of the PVNGS Quality Assurance P gram shall be identified, reviewed, retained, and retrievab e.

These requrements are imposed on all organizations erforming Quality Rela d activities. Quality Assurance re rd systems shall be descri ed and controlled by approved w tten procedures and in tructions.

17.2.6.2 Instruction , Procedures, Drawi gs, and Policies 17.2.6.2.1 Requirements 17.2.6.2.1.1 Procedures, nstructons, drawings, and policies that prescribe the performanc of activities within the QA scope shall comply with the re rements of this Plan. To accomplish this, these docum ts all, as appropriate:

A. Include quantita ive and qu litative acceptance criteria suffi ient for deter 'ning that activities have been sa isfactorily accomp shed.

B. Require a proval and concurrence o responsible person 1 prior to the initiation of he activity.

C. Des ibe the action to be accomplished.

D. D fine the responsibilities and authoritie of personnel performing the activity.

Describe interfaces with other company elements r other organizations that affect or are affected by the activity described in the procedure.

June 2013 17.2-117 Revision 17

PVNGS UPDATED FSAR F12-F014 DELETE QUALITY ASSURANCE DURING THE OPERATIONS PHA F. Be distributed in a controlled manner to preclude he use of obsolete documents and to assure availab ity to responsible personnel.

G. quire that changes be documented and app oved prior to eing implemented.

H. Requi that revisions be reviewed an approved by the same or nizations that performed t e original review and approv 1 or by organizations esignated by the originating rganizations.

I. Be clearly iden ified as "Q lity Related." (Since procedure complia e is r quired by 17.2.2.2.2.D of this plan regardles of quality classification, identification of pr dures as "Quality Related" is not required.)

17.2.6.2.1.2 Measures hall be estab ished to control and coordinate the approv and issuance of 'structions, procedures, and dra ings, including change which prescribe activities within the QA scope.

These measures shall include the requirements f review of specific do ments by the Nuclear Assurance organ ation. The Nuclear A urance is to provide an independent ver 'cation that th documents have been prepared and reviewed in accor ance with established policy and program controls.

Ad toaythe Nuclear Assurance review shall verify po *cy d program requirements have been incorporated.

June 2013 17.2-118 Revision 17

DELETE PVNGS UPDATED FSAR QUALITY ASSURANCE DURIN THE OPERATIONS PH SE Ap licable plant procedures shall be reviewed following a unus 1 incident (such as an accident, unexpected trans nt, signif ant operator error, or significant equipment malfuncti n) and following modifications to structu es, systems, or components.

Non-routine pr cedures (such as abnormal opera ing procedures, emergency operatng procedures, alarm respo e procedures, procedures which i lement the Emergency an, and procedures which implement the curity Plan) shal be reviewed at least every two years and revised as necess ry. This review may be satisfied by a detailed u e or revi w of the procedure during plant operation, training e rci , or drill, or by a revision to the procedure which valida acceptability of the procedure. The use or revie ac ivity shall be documented.

Periodic review of plant rocedures no less frequently than every two years is not equired for r utine, frequently-used plant procedures. Pe iodic audits to s tisfy regulatory requirements and c itments include an a essment of a representative s ple of related procedures o validate that the procedures are acceptable for use and that the procedure review and r vision process is being effectively implemented.

Routine pant procedures which are infrequently use shall be identi ed and controlled to ensure they are reviewed ithin two ars prior to their use to determine if changes ar ne essary or desirable.

June 2013 17.2-119 Revision 17

DELETE PVNGS UPDATED FSAR 12-F0 14I QUALITY ASSURANCE DURING THE OPERATIONS PHAS Perodic reviews of procedures shall be performed by indiv uals knowledgeable in the area affected by the procedu s.

17 .2. 6. 2.2 esponsibilities 17.2.6.2.2.1 VNGS Leaders. PVNGS Leaders per orming activities within the scope of this Plan are r sponsible for:

A. Assuring tat provisions are made for interface controls for internal and exter al lines of communications mong partici ting organizations and technical discip *nes.

B. Incorporating into plcable policies, procedures and instructions thos requirements contained in this Plan and the Regula ory uides and standards committed to in pendix 1 .2B of this Plan.

17.2.6.2.2.2 Directo Nuclear Assuran The Director, Nuclear Assurance, +/- responsible for perfo ming Quality Assurance verifica ions in accordance with Se tion 17.2.4 of this Plan.

When specifie in procurement documents, contracto and vendor Quality As rance Programs, special process procedur and inspecti and test procedures shall be reviewed and a roved by the uclear Assurance organization prior to releasing he cont actor or vendor to start work.

June 2013 17.2-120 Revision 17

DELETE PVNGS UPDATED FSAR 112-F014 QUALITY ASSURANCE DURING THE OPERATIONS PH E 17.2 6.2.2.3 External Organizations. Those activities w hin the QA scope that are performed by contractors, supplier , or vendors all be delineated by documented, approved, ad controlled rocedures, instructions, or drawings.

17.2.6.3 Docum nt Control 17.2.6.3.1 Requir ments 17.2.6.3.1.1 Docume t control procedures shall be established to provide for control f all activities within the QA scope.

These procedures shall ad ress the fo owing documents as a minimum:

A. Drawings B. Plans/Manuals and P ce ures C. Operating Proced es & Ins ructions D. Maintenance Pr cedures & Inst uctions E. Design Docu ents (i.e., calculatons, specifications, changes, nalysis, as-built docume tation) including docume s related to computer softwa .

F. Man acturing, Construction Modificatio s, I tallation, Test, and Inspection Probed es, nstructions, and Drawings G Procurement Documents and Specifications H. UFSAR and Related Design Criteria Documents I. Nonconformance Documents J. Design Criteria Documents and Specifications June 2013 17.2-121 Revision 17

DELETE PVNGS UPDATED FSAR i'- i QUALITY ASSURANCE DURING THE OPERATIONS PHASE Test Specifications L. Operating and Special Orders M. E uipment & Material Control Procedures N. Refu ling Procedures

0. Compone t Classification Evaluations P. Audit and ssessment Reports Q. Equipment Qua ification Data Files EQ Binders)

R. Technical Manua S. Operating Licenses

.17.2.6.3.1.2 All procedures est ished for document control shall meet the following require n s:

A. Review, approval, a issuan e criteria for documents and their revisio shall be s ecified to assure adequate techni al and quality r uirements are met prior to iss .

B. The organi ations or positions respon ble for reviewi, approving, and issuing docume ts and their revis n shall be specified.

C. Ch ges must be documented and approved prior to eing implemented.

D. Revisions shall be approved by the same organizati ns that performed the original review and approval, or by organizations designated by the originating organizations except for documents originated by June 2013 17.2-122 Revision 17

DELETE PVNGS UPDATED FSAR 12-F014 QUALITY ASSURANCE DURING THE OPERATIONS PHASE organizations outside PVNGS. In cases, where documents are originated by organizations outside VNOS, PVNGS may designate the review and appr al or anization. Approved changes shall be pro tly tran itted for incorporation into documen s and obsole or superseded documents shall b eliminated from use.

E. Document dis ribution must be suffi ient to assure that the docum nts are readily a ilable to responsible pers nel prior to commencement of work.

F. Controls shall be e tablish to assure that the correct revision of d um nts are used to perform work, thus assuring tha voided, superseded or obsolete documents ar not used. Master lists that identify the curre revisio of documents shall be maintained. As alternative to master lists, documents may e issued as contr led documents and, as such, sh 1 be appropriately sta ped. Holders of controlle documents or master lists re responsible for mai aining their assigned copies i a current statu .

G. Pr visions shall be made to prohibit unautho 'zed isclosure of safeguards information. These provisions shall include identification of the documents, restrictions on their distribution, and storage in locked security storage containers.

June 2013 17.2-123 Revision 17

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~QUALITY ASSURANCE DURING THE OPERATIONS PHAS SDocument disposition, including filing and permane t 17.2. 6.3.2 esponsibilities sevces is respo*

sibl todvlp , maintaihnad dminister thee, 0

PVNGS Document Cont 1 rogram. /

17.2.6.3.2.2 Director, Nuclear Assurance. The Director, Nuclear Assurance, is resp nsible for p forming Quality Assurance verifications in a cordance ith Section 17.2.4 of this Plan. X 17.2.6.3.2.3 PVNGS Leaders. iVN Leaders performing activities within the scope o this P a are responsible for:

A. Incorporating i o applicable olicies, procedures, and instructi s those requireme ts contained in this Plan, the T chnical Specifications, nd the Regulator Guides and standards comifted to in Appendi 17"2B of this Plan.k B. Es n that documents are available when required.

C. P perly reviewing and approving documents s h as June 2013 17.2-124 .-124Revision June201317 17

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~QUALITY ASSURANCE DURING

]k THE OPERATIONS PHSE

m. Ensuring that approved changes are promptly/

Stransmitted for incorporation into documents id ensuring that obsolete or superseded docume s are

.... eliminated from use.

17.2.6.4 Qua7 *ty4.Assurance Records Procedures shall b~e established for the g neration, collection, storage, maintenance, nnd retrieval of uality Assurance records and shall meet *e followingiinimum requirements:

A. Design specifica *ns, p ocurement documents, and prcdrsshallscy the records to be generated, supplied, and maint ied by or for PVNGS, including retention require ents. Typical records to be specified incle operati <logs; maintenance and modification rocedures and elated inspection results; r ortable occurrence ; inspection and verifica ion procedures (excludi* completed checklsts when results are docume td in a separate repo t); results or reviews, inspecti ns, tests, aits, and material analysis; qualific tion of

/ersonnel, procedures, and equiPment; o th r

/ documentation such as calculations, .design

/ verifications, drawings, specifications, proc ement June 2013 17.2-125 013 7 -125Revision June . 17

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k THE OPERATIONS PHASE k ~vendor evaluations; and other records required by/

Sregulations and Technical Specifications. ./

etention periods of records for operations p s ac ivities shall meet, as a minimum, the re irements desc ibed in ANSI N45.2.9-1974, Appendix/.6. In_

additi to these record retention requrements, the followin records shall be collectedstored, and maintained or the periods indicat:

1. Records oreports of all portable events

2. Records of sea*ed ou e and fision detector lastest ans t s-alet5years.

3. Records ofannua p sica iventory ofall sealed source ateria of record -at least 5 years./

S4. Records o inservice inspe tion performed pursua to the technical sp ifications - the dura on of the operating licen e

5. R ords of changes to the facilit_ including

he written evaluation that provide the bases June 2013 17.2-126 2126Revision June201317 17

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~QUALITY ASSURANCE DURING k ~THE OPERATIONS PHAS S 6. Records of changes to procedures, or tests o

~experiments, including the written evaluaton

~that provided the bases for the determi tion

~that the change in the procedure, or st or

~experiment, did not require a licen e amendment

ursuant to 10 CFR 50.59 - the du ation of the o erating license, or license isued pursuant to 10 R Part 54, whichever islater.

7. Record of changes in the aculity (Independent Spent Fu Storage Inst lation (ISFSI)) or spent fuel torage ca design, including the written evalu tionihat provided the bases for the determinati that the change did not require a lic~e e Certificate of Compliance (CoC) amendmnt purs ant to 10 CFR 72.48 -

maintained until spent fuel is no longer stored in the fcility (ISFSI) rthe spent fuel stora_ cask design is no nger being used, or untl the Commission termina s the license or C C issued pursuant to 10 CFR P r 72.

8./ Records of changes to Procedures, r tests or

/ exPeriments, including the written e aluatiOn

/ that provided the bases for the determ ation June 2013 17.2-127 013 7 -127Revision June . 17

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~QUALITY ASSURANCE DURING/

STHE oPERATIoNs PA S 9. Records of the service lives of all hydraulic

~and mechanical snubbers within the scope o

~snubber test and inspection program requred by

~unit technical specifications, includi g the

date at which life commences and ass ciated installation and maintenance reco s - the d a~tion of the operating licen e.. ..

10. Reco d of audits required b UFSAR 13.4.5 - the durati of the operating icense. . ..

11. Records o analyses re ired by the radiological environmenta monitor ng-program that would permit evaluatoni the accuracy of the analysis at a lae date.

These records shoul include PrOcedures_

effective a specifie times and QA records showing tat these proce ures were followed-the du tion of the operatng license.

12. Met rological data, summariz d and reported in a format consistent with the re oemendations of e*gulatory G ide i*s 12 nd 1.23_- h uration

/13. Records of. secondary water sampling, and water

/ _ _quality- the duration of the operating +/-oense.

S14.th hOF:SIT DOSEr CALCUL::ATiON MANUAL and: thed June 2013 17.2-128 .-128Revision June201317 17

DELETE PVNGS UPDATED FSAR [1~2-F04i PR*oCEss. CoNToL, PRORA - the duration of th B. Sufficient records and documentation shall b/

m intained to provide objective quality evdence of S the *ems or activities within the QA sc pe.

Inspe ion and test records shall con in the

~follow in , where applicable:/

1. Identi 'ction of the type of observation.

2. The date a dresults of th inspection or test.

3. Identificatio of any c nditions adverse to

~~quality. X 4_. Inspector or data eorder identification.

5. Evidence as to e a eptability of the results.

6. Action takento resolve ny discrepancies noted.

C. Documented an approved measur sshall be established

for comply' g with the r equireme t of codes, standard and procurement documen regarding record transm tal, retention, and maintenan e subsequent to competion of work ... ... * .

D. R cord storage facilities shall1 be establi hed and June 2013 17.2-129 17 June201317.2129Revision

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, QUALITY ASSURANCE DURING THE OPERATIONS PH SE E. All records shall be legible and should be capab e of being reproduced./

17."2."6"4."2 Responsibilities 17.2.6.4.2.1 PVNGS Leaders. PVNGS Leaders perf rming activities withl the scope of this Plan are r ponsible for:

A. Incorpor tng into applicable pol'ies, Procedures, and instru ions those requirem ts contained in this Plan and the e*gulatory Guide and standards committed to in Apendix 172B of this Plan.

B. The initiation, ccolecti n, maintenance, and storage of records in accord ne with approved written procedures which co o to the requirements and policy of this se ion u il such time as they are transferred to clear Reco ds Information Management for storage.X 17.2.6.4.2.2 /Manaer, Support Services, he manager, support services is respo sible for:

A. Theiollection, maintenance, and stora e of records i accordance with approved written proc ures and

/nstructions which conform to the requireme ts and

/ policy of this section.

/. Providing Procedures which ensure the maintenan of

/ records sufficient to furnish objective evidence t at

~activities affecting quality are in compliance with

,T]iir 9fl1q 17 2-I T Revi sion 17

,-DELETEI PVNGS UPDATED FSAR 12-F0141

~QUALITY ASSURANCE DURIN THE OPERATIONS P SE applicable codes and standards, Regulatory Guid s, and applicable regulations.

C. Establishing and implementing the PVNGS Re od

)ntrol Program.

17.2.6.4.2.3 xternal Organizations. Recor( generated by contractors shall e controlled according t cnrtor o PVNGS procedures un '1 such time as they returned over for review, acceptance, an transmittal to hepermanent records file. Purchased equipme t records s 11 be retained by the vendor until the equipmenti relesdfrsimna hc time the records required by ro urement documents are to be

'submitted to PVNGS.

When required by the procur ment *cuments, contractors and vendors shall establish pocedures t control Quality Assurance3 records. Implementati of theseprcdes halbasud by performance of so ce surveillance, m itoring, and audits performed by the Nclear Assurance organiz ion.

Records to be s mitted with the shipment or tamned by the vendor shall e specifically identified in proc ement documents . These records shall be reviewed as nec ssary by Nuclear surance and/or Material Management and Bud ets to provid the required degree of confidence regarding th*

adeq acytofncompliance by the vendor with the requiremen, of tssection. eqirme~

June 2013 17.2-131 .-131Revision June201317 17

DELETE PVNGS~ UPDATED FSAR12F4

OE'ETE I 12-F014 I 17..6..2.

Diectr, u r Assur :e. The Director, Nuclear Assurance is responsib o eformingqult veiiain nacr ce with Section 1i o hs ln June 2013 17.2-132 June201317.2132Revision 17

112-F014 PVKGS UPDATED ESAR (The PVNGS in section 13.1)

June 2001 June2001Revision 11

Intenti Blank PVNGS UPDATED ESAR 12-F014 D{ELETE APPENDIX 17.2B/

APPENDIX 17.2B COMPLIANCE MATRIX (Sheets 1 of 2 Degree of REG. Guide Revi ~ion Standard Ye* Conformance Title 1.8 Rev. 1 R\ Personnel Selection and Training NI8.1 1 Modified 1.21 Revision Measuring, Evaluating, and Reporting N/A N/A Conform June, 1974 Radioactivity in Solid Wastes and

~Releases of Radioactive Materials in/

~Liquid and Gaseous Effluents from/

~Light-Water-Cooled Nuclear Power 1.26 Rev. 1 Qu lity Group Classifications and8 Modi fied Sept. 1974 Ste dards for Water-, Steam- and

~Radi ctive-Waste-Containing Components

~of Nucear Power Plants/

1.28 Rev. 0 .__ Quali"ty *surance Program Requireme s N45.2 1971 8Modified June 7, 1972 (Design a Construction) / Note 1 1.29 Rev. 3 Seismic Desi n Classification 8Modi fied

)perations Phese 1.30 Rev. 0 Quality Assurance Requireme ts for the N45.2.4 1972 8Modified Aug 11, 1972 Installation, Insp tion *d Testing of Intuettinad lcrical Eqipmaent 1.33 Revisin2 QaiyAsurance Pro am Requirements N18.7 1976 Modified February 1978 (Operation)! ._

1.37 Revisin0 Qalt surance equire nts for N45.2.1 1973 Modified March 16, 93 Cenigo li Systems a d Associated

~Components of W ~er-Cooled N lear Power 1.38 Revisio ult ss ance Requirements fr N45.2.2 1972 1Modified May 1977 Packaging, ipng, Receiving, S rage Operations and Hnlng of Items for Water-Coo ed Phese Nuclear ower Plants 1.39 Revisin2 Hus pn Requirements for Water- N45.2.3 1973 1Modified Sept. 97 old Nuclear Power Plantsk 1.54 Revisin0 Q lt suace Requirements for \101.4 1972 Modified June 1973 *otetv otngs Applied to Water-Cooled Ncea*r Power Plants 1.58 Revisin1 Qaiicto fNcear Power Plant N45 2.6 1978 8Modified Sept. 90 Isecin xmnation and Testing I / *~Prsonnel ...

1.64 RevisinQaiyAsrneRqiements for the N45.2.ill 1974 8Modified June 1 Design of Nuclear Power Plgants Operations 1.74 IRev o ult surneTrsadDfnitions N45.2.10 19*

REFER TO UFSAR SECTION 1.8 FOR CONFORMANCE STATEMENTS

! /< .Note 1. For Operational Phase see Rag.

Guide June 2001 17.2B-I June20011711

.2B-1Revision

,]-DELETE PIGSUPDATED ESAR 12F1 I APPENDIX 17.2B APPENDIX 17.2.B COMPLIANCE MATRIX (Sheet 2 of 2)

Revison Title Standard Year onforac REG. Guide 1.88 Revision* Collection, Storage and Maintenance of N45.2.9 1974/ Modified October 19 8 Nuclear Power Plant Quality Assurance k Records/

1.94 Revision 1 kkQuality Assurance Requirements for N45.2.5 /1974 Modified April 1976 *Installation, Inspection, and Testing of

tructural Concrete and Structural Steel d ing the Construction Phase of Nuclear /

Po r Plants 1.116 Revision 0-R Quali* Assurance Requirements for N4 .2.8 1975 Modified May 1977 Install tion, Inspection, and Tasting of z Mechanic Equipment and Systems 1.123 Revision 1 Quality As rance Requirements for Control /N45.2.13 1976 Modified July 1977 of Procureme t of Items and Services for /

Nuclear Power lants 1.143 Revision 0 Design Guidance or Radioactive Waste/ N199 1976 Modified July 1978 Management Systemk Structures, and*

Components Installe in Light-Water Cooled Nuclear Power Plantsk

1. 144 Revision 1 Auditing of Quality Ass rance P ograms for M45.2.12 1977 Modified Sept. 1980 Nucl~ear Powr/Pant 1.14'6 Revision ulfcation of Quality As rance Program M45.2.23 1978 Modified August 1980 Audi esnel_ for Nudel wer Plants Appendix A to Guidelines for Fire Pro ection or Nuclear (BTP) APCSB Power Plants 9.5-1 ..

(2/24/77) The prtons Qual~ty Assurance Pr ~rem complies with the Qality Assurance Program Guidelin s of Appendix A to

~(BTP)APCSB 9.5-k 4.1 Revision 1, Porasfr Monitoring N/A M/A Modified April 1975 Radioactiv y in the Environs *kAudits of the of Nuclea Power Plants (1/73) . kQA program

/ *k for monitoring

/ kk radioactivity in June 2001 17.2B-2 .3-2Revision June200117 11

PVNGS UPDATED FSAR [1-01

-DELETE

~APPENDIX 17.2C TERMS AND DEFINITIONS Accept:<

To a nowledge that identified items or specific srie rendere comply with the specifications and proc due describe inthe controlling document. /,

Acceptance: /"

(As used in rela ion to acceptance of a document)

Generally approved believed or recog ized. Does not require signature o eri son accept g.

Accept-As-Is:" .

A disoiinwhc a e *posed for a nonconformance when it can be establishe th t the discrepancy will resulti o desec tons and thtat the item under consideration will co *inue to me t all engineering functional requirem ts including p rformance, maintainabilityt, and safety.X Acceptance .Criter~i '_

A limto mt pae nte vavriation pe mitted in the caat stc ofa itmepesdin dein i~ve engine, ing terms such as dimensional tolerances, chemical comp sition limits, density and size of defects, June 2001 17.2C-1 June200117 11

-2C-lRevision

,DELETE PVNGS UPDATED FSAR 12-iF01l APPENDIX 17.2 hhA~ cronym for As Low As is Reasonably Achievable) As sed wit in the QA Plan means as low as is reasonably achie able taking into account the state of tech logy, and the economics of improvements in relation/go benefits to the pulic health and safety and other so/fetal and socioecno c considerations, and in rela on to the utilization oatomic energy in the pubc interest.

Aacofendorsing d digp tive authorization (signature) to a docum Lt by t person(s) responsible for the documents. m Approved Vendor List (AVL)/:

A list of Suppliers w/hehave be evaluated by the PVNGS NucearAssurance o *anization fo their capabilities to produce or proi quality related i m, equipment or services.

Approved Supplie s List (ASL):

Synonymowith (AVL) and may be used interc ngeably.

APS: /_.

Arzona Public Service Company.

As- 3uilt Data: _

Documented data that describes the condition actually

~achieved in a product.

June 2001 17.2C-2 June200117. C-2Revision 11

,,DELETE IPVNGS UPDATED FSAR 112-F°14 a.quacy of, and adherence to, established procedurs, ins utions, specifications, codes, and standardy or other pplicable contractual and licensing requrements, and the ffctiveness of implementation.

Auditor: _ </-I Any individual ho performs any portio, of. an audit, including lead au itdrs, technical s ecialists, and others such as management epresentatives and auditors in Calibration : _..

Comparison of_ toe ?instru ntvor mesuin dtevice, oneo nat ,iona stnad todetect co relat ne, reort or*

June 2001 17.2C-3 June20011711

.2C-3Revision

112-F014 DELETE PVNGS UPDATED ESAR ..

~APPENDIX 17.2C do not include items where the design and manufacturin.

process require in-process inspections and verificaon b~~ensure that defects or failures to comply are/

id tified and corrected (i.e., one or more critcal

~chara teristics of the item cannot be verifie*

Therefo e the capability to verify all of e item's critica aracteristicscalduring the dei on process must exist.

Component:

A ieeofeuimetsuhas avsepiping, pump, valve or core support stru ture, whi will be combined with other components to fo an ssemly.

Concurrence: _

Written agreement wi the pvsons in a document.

Conditionadere to qualityissyony eswith terms such asaiues, maluction, def cien eviatons, ,

defecve material and equipment, and noncon rmnces.

An*y organization under contract for furnishing.itemsor se*rvices. It includes the term Vendors, Supplier,

/Subcontrato, Fabricator and subtier level, where "

aprprae June 2001 17.2C-4 June200117 11

.2C-4Revision

DELETE PVNGS UPDATED ESAR12F4

d APPENDIX 17.2 C to edDocument :/

document which is assigned and distributed to an*

i dividual or organization and requires that indiv dual or

~org ization to be accountable for the document nd to ackno edge receipt of the document in writin . The

recipient with current revision to _the d ument and for mainte~nane fte return acknowledgmn receipts.

Corrective Action: ./

~Measures taken to ctify a cond ion adverse to quality

_.and where necessary, o reclu repetition.

Dedication :

An acceptance process un er ken to provide reasonable designed and ma factured under a 1 FR Part 50, Appendix B,'i~ty assurance program.k Deficiency: /.. .

or 1 k of conformance to requirements.

Docum tatio.n.: . . . .. . ..

/ ~seifing, reporti!ii::ingorctifini!g aciviti!!i~es, June 2001 17.2C-5 June20011711

.2C-5Revision

k*-DELETE PVNGS UPDATED FSAR t12.-F014 cnsidered to be a QA record until it is completed and/

c ntins the required signatures."

Engineerin (Engineer) :. . _

~The term used to refer to the technical respons ilities of

.Technical untions, Plant Engineering, etc.

Equipment Qualifica in :

~The generation an maintenance of evid ce to assure that

~~the equipment will *erate on demand o meet the system.

performance requreme ts E'valuat°ion:. * / . . . .

performance standrds. Thsu trmvseynyos ihn Failure:

Th nb iyo nie oefr ihnpe ul June 2001 17.2C-6 .C-6Revision June200117 11

- ~DELETE PVNGS UPDATED FSARAPEDX1.C2F1 until inspection has been performed or waived in accra

'th approved procedures.

Indepen nt evaluations and assessments of proce res and activitie to detect potential nuclear safety yazards,__to provide id promdcdor )endent ctly, verification an oprovide thatrecomm activindations ies are for ipoigplant atyand reducing huma errors.

Inservice Inspection (S Those periodic or even elateda tions accomplished to satisfy the requirements f he/ASME Boiler and Pressure Vessel Code, Section XI. e* actions may be required by PVNGS Technical Specificati. n Inservice Test (IST)

Those periodic surve lance tests pe formed* to satisfy the requirements of th ASME ON Code. The e surveillance tests may be re _red by PVNGS Technical Specifications.*Seii Inspection Plan:/

The instr ction document that identifies the charact ristics or activities requiring inspectio , the metho* of inspection, acceptance criteria, and the *xtent ofoumentationofrequired.

Ite*

Any level of unit assembly, including structure, system,

/ subsystem, subassembly, component, part, or material.

June 2009 17 .20-7 June20091715

-2C-7Revision

-DELETE PVKGS UPDATED ESAR [12-F014

, APPENDIX 17.

individual qualified to organize and direct an udit,_

~re rt audit findings, and evaluate corrective tion (also refe edtO as ATL.)

Measuring and est Equipment (M&TE):/ .

Any tool, g ge, instrument, standard, r device used to

,measure, test, calibrate, or otherwi erify acceptance

_. _parameters.

limitations of applicabe des, standards, specifcations, licenses and predeter ed saet restrictions.

Monitoring:/__

verifying th. an action is accomplis d as specified (also see Evalua nion)

Nonconforma ce : ...

Ad iciency in characteristic, documentation, r procedure

indeterminate. nExamples of nonconforma~nc e include:.° June 2001 17.2C-8 June20017.C-8Revision 11

,*-DELETE PVNGS UPDATED FSAR 12F1 APPENDIX 17.2 N -Qualit Relaed (NQR):/

Items that are not designated as Quality Class Q or ality a mnted (QAG).

Operationa Phase:./.. .

~associated with normal operation of the ant. This phase

~of plant lif is considered to begin f mally with

~commencement. o fuel loading and end with plant Purchase requisit~ions, urc se orders, drawings, __

requirements for purcha.e.

PVNS:,~~e-/_

Pao Vr deNd eeatn ttn June 2001 17.2C-9 17.C-9Revision June200 11

,DELETE PVNGS UPDATED FSAR 12-F014 J APPENDIXl7C Qua T y Assurance:/

A 1 those planned and systematic actions necessary

~pro ide adequate confidence that an item or a fac ity will

.perfo°satisfactorily in service.

Quality Assura ce Plan (Plan):/

~The document which describes the method, eans, controls and limits of -he QA Program that impl ents the applicable

_ regulatory and P G requirements..

Quality Assurance Program. ..

The program establishe by APS to provide the formal necessary to assure that lity related activities,.

control to provid adequate confide e that systems and This* program s described inthe Qualit Asurance Plan.

Quality Assurace Records:

Those ecords which furnish documentary eviden e of the

~een completed.

June 2001 17.2C-i0 June . 11 001 7 C-l0Revision

DELETE PVNGS UPDATED FSAR 12F1 tems tha do not perform a saety related functionb whc, as a result of regulatory ommitent or mana eent dire tive, require the application of certain qua ity Quality Class Q:

A Qualit Casifcaton tha includes sety relaed

~items as well a equipment, systems, a d structures which do not meet the c teria of safety r ated, but, due to

~their importance, a designated b Senior Management as requiring the full ap icaion o 0OFR50, Appendix B.

Quality Classification List: *. . ..

requirements of the/ Plan.

Quality Related (Activties): __ ..

obj tives of the operations Quality Assurance Pro°ram June 2001 17.2C-ii June 11 001 7 C-llRevision

--DELETEI PVNGS UPDATED FSAR !I12-F°14 I eNprocess of restoring a nonconforming characterist' to a c ndition such that the capability of an item to/

functon reliably and safely is unimpaired, even hough that it* still may not conform to the origina£

.requireme< t..

Review-: . .

To examine any f rm of documentation o activity for the purpose of establi ing acceptabiliy to the requirements of the function repr ented by th reviewer. Reviews may range from a thorough vestiga on to a spot check.

R*VeviWStarergenerrallytnoc hOle points,'dboUtsign-off on required. /

Rework :

The process by whi a nocnformin item is made to conform to a pri specified requirem t by completion, remachining, rassembling or other corr tve means.

Safety-Related Q):

The equ ment, systems, and structures that ar relied upon o remain functional during and following d ign

/A. The integrity of the reactor coolant bounda-ry;

/ B. The capability to shut down the reactor and maintaink

/ . it in a safe condition; June 2001 17.2C-12 001 7 C-12Revision June . 11

-DIELETE PVNGS UPDATED FSAR 12-F014I C. The capability to prevent or mitigate the consequences of accident which could result in potential offsite exposures comparable to the udeline exposures of 10CFR100.

Safety Review Goups: i..

Committees r organizations with respons lities for evlutinof ~ethods, procedures or conditions affecting plant safety du iung te operational pse.

Services:

The performance b a upplier ocntaorof activities such as design, fabrica ion, i spection, nondestructive examination, repair, or i stllation.

Shall, Should, and May:1._/e The word "shall" is u ed to deoea requirement; the word "should" is to deno/e a recommenda ion; and the word "may" is used to denote permission, neithe a requirement nor a Significant Con gtion Adverse to Quality:

A significant condition adverse to quality is one which, if unc rrected, could have a serious effect on *afety or operbility.

Spec 1 Processes: _

Those processes that require interim inprocess controls *n

~addition to final inspection to assure quality. Included June 2001 17.2C-13 001 7 C-13Revision June . 11

SDELETE PVNG UPDATED FSAR I2F1

~APPENDIX 17.2C are such processes as welding, heat-treating, chemical cleaning, and nondestructive examination.

Any o anization or individual furnishing ite or service (not including contract work perfor e at PVNGS) subject procurement document. /

Testing: tt The determinatio or verification o the capability of an item to mespeci *ed requiremensb subjecting the item to a set of physical chemicalevromna or operating Traceability:

The ability to trace t e hist y, application, or location of an item and like tems or ac *vities by means of recorded informatn.

The analysi of deficiency data to ident y weaknesses that mayot be apparent to the day to day berver.

A isposition which may be imposed for a nonconfo ance hen it can be established that the discrepancy wil*

result in no adverse conditions and that the item und*

/ consideration will continue to meet all engineering

/ ~functional, requirements including per formance,

~maintainability, fit, and safety.\

June 2001 17.2C-14 June 001 7 C-14Revision

. 11

DELETE PVNGS UPDATED FSAR 112-F0!4

* "APPENDIX172 Vendo .,

Any ganization or individual furnishing itemsa service ,0ffsite or at the PVNGS, subject to procurement document. The term vendor includes both supiers and Verification:_ /.

An act of confirming, ubstanti ing and assuring that an S with the specified require t.

Witness: _

. operation with gn-off responsibilit icuded.

in vance of the operation, is required so that i_ may be June 2001 17.2C-15 001 7 C-15Revision June . 11

This pa intent' al blank

,--DELETE PVNGS UPDATED FSAR vir-, I

~APPENDIX 17.2D COMPARISON OF QA PLAN REQUIREMENTS WITH THOSE OF 10CFR50 APP.B AND SELECTED ANSI STDS i 0A Plan I rganization 17.2.

II Q roram 7.2.2 III Design Control 17.2.3.2 IV Procurement Document Isrci\ PoeueD*1.3.3Control 17.2 VI Document Contr 1 17.2.6.3 VII Control of Purcha ed Mate ial 17.2.3.3 VIII Identification & Cotr* of 17.2.3.4 Materials, Parts, an *Components IX Control of Special Proc s7..s.

X Inspection.24 XI Test Contro 7.36 XII Control M&TE 1.

XIII Handl g, Storage and Shipping 1.

XIV Ins ection, Test and Operating Status 7.2.3.9 XV /onconforming Materials, Parts or 1.. 0 Components17 .

XVI Corrective Action i .. 0 X*Quality Assurance Records 17.12.16.4*

VII Audits 17. *2.4, 17.2.4.4 June 2001 17.2D-I June200117. D-1Revision 11

DELETE PVNGS ~ UPDATED FSAR 2F1 12-F014!

OELETE ,

APPENDIX 17.2D

_~ANSI N45.2 - 1971 OA Plan!

1.0 \k Introduction 2.0 QA Program 17.2.

3.0 Organization 4.0 D ign Control 7.2.3.2 5.rc eet ocumen Cot ro 1723/QA Plan3 C-Procedures anaing 60 7.0 Istructions Document Controk 172..

17.2.6.3 8.0 Co*ntro o Purchas evcf dNerials 17.2.3.3, 9.0 Identification and on rol of 17.2.3.4

.Materials, Parts nd Co onents 10.0 Contol f Spe ial ProceSSn/ s 17.2.3.5 12.0 TestCo rol 17 .2.3.6 13.0 Cont of M&T 17\ .2.3.7 14.0 Hadling, Storage and Shipping 17.2.3.8 15.0 nspectiontTes and 172..9 "

16.0 Nonconforming Items 17.2. 10, 18.0 Quail;itAssuranceSRecords 17.2.6.40' June 2001 17.2D-2 June200117 11

.2D-2Revision

DELETE PVNGS UPDATED FSAR 12-F014

9. APPENDIX 17.2D 90Audits 17.2.2.4, 17.2.4.4 AN*I 18.7 1976QA Plan/

3.0 Owner Organization 17 .

3.1 Geea 7.2 .1 3.2 Assi ~ent of Authority / 17.2.1 and Re onsibility 3.3 Indoctrin tion and Training /17.2.2.7 3.4 Onsite Oper ing Organization 17.2.1 4.0 Reviews and Au *ts 17.2.2.4, 4.1 General\ /

4.2 Program Description k 4.3 Independent Revi Progr m 17.2.2.9 4.4 Rve ciiiso h 4.5 Onsite perating Organization 5.0 irogram, Policies, and Procedures 1 -

June 2001 17.2D-3 June20011711

.2D-3Revision

DEEEPVTNGS UPDATED ESAR 12-F014 I

,,*---tDELETE I

~APPENDIX 17.2D 23 Operating Orders 17.2.6 /

5.2.% Special Orders .17.2.6/

5.2.5 k Temporary Procedures 17.2.

5.2.6 quipment Control 17 .3.9 5.2.7 Ma tenance and Modifications / 7.2.3.11 5.2.8 Survellance Testing and 17.2.3.12

_ _ _ Inspec on Schedule 5.2.9 Plant sec rity and /17. 2F

_ Visitor Con o~l 5.2.1i0 Housekeeping a d Cleanlines* 17.2.3.1i0 Control 17 .2 .3.4, k 17.2.3.8 5.2.14 Nonconformin Items 17 .2.2 .10, k 17.2.5 5.2.15 Review, *pproval and 17 .2 .6 .2, Contro of Procedures ~17. 2E 5.2.16 Measring and Test Equ ipment 1l7.2.3.7 5.2.17 I spections i1 .2.2.4,

17. 4.2 5.2.18/ Control of Special Pro cesses 17.2. .*5 5.2. Test Control 17 .2 .3 .

June 2001 17.2D-4 June20011711

.2D-4Revision

PVNGS UPDATED FSAR DELETE I

~APPENDIX 17 D

~and Procedures 5.3.1 rocedure Scope 17.2.6 5.3.2 Pro due Content 17.2.6 5.3.3 System P cdures 17.2.6 5.3.4 General Plan Prcedures 17.2.6 5.3.5 Maintenance Proceres/ 17.2.6 5_.3.6 Ra~diat ion Contr~ol ues 17.2.6 5.3.7 Calibration a Test Equip n 17.2.6 531 TetadInspection June 2001 17.2D-5 June20011711

.2D-5Revision

x*DELETE I 112-F014 ]

Intent io**ft Blank

PVNGS UPDATED ESAR 112F014 l AP]

(The Nuclear Assurance *iew requirements are described in the text of ~iDescription contained in 17.2)

June 2001 June2001Revision 11

Blank

,-DELETE PVNGS UPDATED FSAR 12-F014

~~~~APPENDI___ X i_7.2F /

~QUALITY AUGMENTED PROGRAMS/

S17.2F.I QUALITY ASSURANCE FOR FIRE PROTECTION 17.2F.I.I op 17.2F.I.I.l kThis Appendix provides the Quality suac criteria for fi eprotection consistent with Br c Technical Position, APCSB 9. -, Appendix A, and the NR Guidnce Letter dated August 29, 19 , entitled "Nuclear P1 nt Fire Protection Functional Responsibil ties, Administrati e Controls and 7.2F.l.l.2 Items and act vtie to whic this Apendx applies are identified and cia fied in accordance with PVNGS Administrative Controlpo ed es\

17.2F.l.l.3 This Appen x along wi h its implementing procedures comprise the VNGS Fire Prot cion Quality Assurance Program.-/

17.2F.l.2 Purpos The purpose of this Appendix is to ensure that th critical aspects of sign, procurement, maintenance, and te ting are applied t ensure that fire protection equipment is a ailable and fun ional. The Quality Assurance requirements des ibed herei are applied to the extent necessary to ensure that he saf shutdown capability of the plant is maintained and to nimize any radioactive release to the environment if a fire does occur.

June 2013 17.2F-I June20131717

.2F-1Revision

,,DELETE PVNGS UPDATED FSAR L12F1i

. APPENDIX 17.2F

2F. 1.3 Requirements/

17.2F. .3.1. The fire protection program shall/includE A. C ducting a fire hazards analysis and nual upda es, as necessary, to evaluate th effect of a fire o nuclear safety. The analyss shall evaluate plant de ign, potential fire haza ds in the plant, potential reat of these hazar s in the plant, and the effect o postulated fir on the capability to safely shut dow the plant/and to minimize radioactive relea e tohe environment.

B. Establishing the org izational and administrative responsibilities fo t eprogram.

C. Training, which hail inc ude fire drills, and qualification f Fire Depar ent personnel.

D. General emp oyee training on f e protection and pr eventio1 E. Contr ling the use and storage of rnbustibles (such as ood and flammable gases and liqui ) and ignition s urces (such as welding, cutting, and o en flame).

potntialvfire hazalrds(includin houseeein , and preautidons hallbe taken to prevent the initi to June 2013 17.2F-2 June20131717

.2F-2Revision

-DELETE PVNGS UPDATED FSAR I12F04I

~APPENDIX 17.2F k F. Reporting of a fire, fire emergency procedures, and/

k coordination of fire fighting activities with offste

~fire departments.

G. Compensatory actions to be taken in the even that a reprotection system is out of service.y H. Con cting reportability evaluations of iolations of the re uirements of the fire protecti program describe in the UFSAR and the unit Operating-Licenses w ich could have adverse y affected the ability to a ieve and maintai safe shutdown in the event of a fire*

17.2F.I.3.l.2 Those items as ocia ed with fire Protection that are not part of the permanent p nt (i.e., communications equipment, portable smoke eje or manual fire fighting equipment, etc.), shall be rocured o an appropriate_

commercial quality standa d. The acti ities associated with assuring that these ite s are functional and available for use shall be delineated* administrative cont o procedures and shall be classifi as quality related.

7.2F.l.3- #ality Assurance\

7.2F.l.3.2 The extent to whic the requirementsf this Appendix nd its implementing documents are applied to an item or act ity shall be based on a graded approach using th*

A.g Theeffect f [aomalfunc~tiOnorfil*Ure.of the item June 2013 17.2F-3 June20131717

.2F-3Revision

,DELETE PVNGS UPDATED FSAR 12F1 B. The design and fabrication complexity or uniqueness of the item./

C.* The need for seilcnrssurveillance o monitoring of processes, equipment, and opertional ctivities./

D. The degree to which functionality can b demonstrated by in ection or test. /. .

E. T~he qualty history and degree ofitandardization of th item.\/ ...

When the graded approac is utilized, t e justification and basis for grading shall b documente and retrievable.

Application of the graded a roach hall be accomplished in accordance with procedures con ued with by the Nuclear Assurance organization. Thesepocedures shall clearly identify how the justificati n and basis for grading shall be documented and maintained. ...

Grading of Plan require ents applicable to items shall be the responsibility of thVice President, Nuc er Engineering.

Grading of Plan re uirements applicable to a tivities shall be the responsibil y of the organization respons le for performing t activity.

17.2F.lI3.2 Design Control and Procurement Documen Controlk Measur s shall be established tO assure that the applica le guid ines of Branch Technical Position APCSB 9.5-1 are inluded in design and procurement documents and that June 2013 17.2F-4 June20131717

.2F-4Revision

-- DELETE PVNGS UPDATED FSAR [1Z-PjI4

~APPENDIX 17..2F/

de iations therefrom are controlled. These measures shall /

assu ethat :/

A.k Design and procurement document changes, includig

~~ield changes and design deviations are subje* ovo t t e same level of controls, reviews, and ap ovls tha ere applicable to the original docuent.

B. Qualit standards are specified in the design document such as appropriate fire p otection codes and standa s, and deviations and hanges from these quality stan rds are controlle C. New designs and lant modific tions, including fire protection systems are rev ewed by qualified personnel to assure nclion of appropriate fire protection requirement .These reviews shall include items such as: < ~ e

1. Design evest eify adequacy of wiring isola on and cable epaation criteria.

2. De gn reviews toveni appropriate eqirements fo romi tionor( sealing penetrations, floors, and *her fire barriers).

D. A2 rvew and concurrence of the adequacy *fire p0tection requirements and quality requirem nts

/stated in procurement documents are performed nd documented by qualified personnel. This review hall

~determine that fire protection requirements and

/ ~quality requirements are correctly stated,

~inspectable, and controllable; there are adequate June 2013 17.2F-5 F-5Revision June201317. 17

tDELETE PVNGS UPDATED FSAR [i12-F14 APPENDIX 17.2F acceptance and rejection criteria; and the procure t

. document has been prepared, reviewed, and approve i accordance with QA program requirements.

17.2F.l.3.2.3 Instructions, procedures, and drawing*

Inspection, ets, administrative controls, fir ri , and training that overn the fire protection progra shall be prescribed by do mented instructions, proced res, or drawings and shall be accomp ished in accordance wit these documents.

The following provisi n shall be include A. Indoctrination and training rograms for fire prevention and fre fight g are implemented in accordance with do° ened procedures.

B. Activities such as d *n, installation, inspection, test, maintenance, nd dification of fire protection systes are Pre cribed and accomplished in accordance wit documented i sructions, procedures,

' ~ ~and drawing" __ _

C. Instruct'ns and procedures for d sgn, installation, inspec on, test, maintenance, modi *ation, and admiistrative controls are reviewed t assure proper ombustibles, provisions for backup fire pro ction Tinne 2fl12 17.2P-6 Revision 17

........ v

DELETE IPVNGS UPDATED FSAR 112-F°14

~APPENDIX 17.2F D. The installation or application of penetration seals k and fire retardant coatings is performed by traine

~personnel using approved procedures.

E. Instructions, procedures, and drawings shall e n*trolled to prevent the use of supersede in rmation.

F. Revie of fire protection procedures shall be performe a described in Section 1.2.4.3.1.3.

17.2F.I.3.2.4 Controlo Purchased MateraEupet an Measures shall be establis to as ethat purchased material, equipment, and services confo tthe procurement documents.

These measures shall include:

A. Provisions, as app opriat , for source evaluation and selcton ojec ive eie fqaiyfrihdb theinpctonCntractor, inspectionsn a suppliers, or receiving isplections.beie o uliyfrihdb B. Source orreceiving inspection, as minimum, for those em whose quality cannot be rified after inst lation.

17.2F.i.3..5 Inspection A progr m for inspection of activities affecting fire pro~teton shall be established by or for the organizationk pe orming the activity to verify conformance to documented

stallation drawings and test procedures for accomplishing activities. The program shall include:

June 2013 17.2F-7 June20131717

.2F-7Revision

DELETE PVNGS UPDATED FSAR 12-F014 X APPENDIX 17.2F X A. Inspections of (1) installation, maintenance,/

Xmodification, and tests of fire protection systems,

~and (2) emergency lighting and communication kequipment to assure conformance to design and ntallation requirements.

B. Ins ection of penetration seals and fire retardant coati g installations to verify the ac ivity is s atisfa trily completed.

C. Inspection of cable routing to vrify conformance with design equirements. /

D. Inspection to v ify that a ropriate requirements for room isolatio (seali g penetrations, floors, and other fire barriers) ar accomplished during construction. !

E. Measures to as sure that i spection personnel are

~independent fro the indivi uals performing the activity bein inspected and *e knowledgeable in the design and stallation require nts for fire protectio\

F. Inspec ion procedures, instructions, nd checklists that provide fokh oloig June 2013 17.2F-8 June20131717

.2F-8Revision

,-DELETE PVNGS UPDATED FSAR 12-F014 k APPENDIX 17.2F I* 4. A description of the method of inspection. /

S 5. Recording evidence of completing and verify g a

~manufacturing, inspection or test operati

6. Recording inspector or data recorder a d the

~results of the inspection operation.

C. Pen dic inspections of fire protectio systems,

"' emerge cy breathing and auxiliary e ipment, emergenc lighting, and coinmunica on equipment to assure the cceptable condition f these items.

Ii. Periodic insp cion of mater is subject to-degradation suc as fire s ps, seals, and fire

. retardant coatings to as ure that these items have

' not deteriorated or e n damaged.

I. The identificationif a y required independent insPections to beperform dby the Nuclear Assurance 17.2F,2.3.2.6 Test ~d/ Test Control A test Program sh 1 be established and impl ented to ensure that testing is performed and verified by inspe tion and audit to demonstrat conformance with design and system readiness requiremen . The _tests shall be performed in acco dance with written/tset procedures; test results shall be proper*

evalua ed and acted upon. The* test program shall inclu the

/ A. Installation testing - Following 'construction,

/ ~modification, repair, or replacement, sufficient June 2013 17.2F-9 June20131717

.2F-9Revision

,,DELETE PVNGS UPDATED FSAR 112-F014

~APPENDIX 17.2F k " testing shall be performed to demonstrate that fire k ~protection systems, emergency lighting, and/

communication equipment will perform satisfacto ly

~in service and that design criteria are met. Written test procedures for installation tests inc rporate

~t requirements and acceptance limits c ntained in applcable design documents. /

B. Periodi testing. The schedules and methods for Periodic esting shall be developd and documented.

Fire protec ion equipment, eme gency lighting, and communication equipment are ested periodically to assure that the quipment ill properly function and

, . continue to meet t ede gn criteria. . .

C. Provisions for the N ear Assurance organization to verify testing of */re rotection systems and to verify that testersonne are effectively trained.

D. Test results e document ed, evaluated, and their acceptabili y determined by a ualified responsible idvda or gop 17.2F.l.3.2.7 nspection, Test, and OPerating ttus Measures sh*1 e established to provide for the intifiation of items at have satisfactorilypass~ed required t:ets and inspettyons. Th*ese. measures shall incude appopratek Provi ions fro identification by means of tags, labels, s *ir eporaryesmarkings oid iae< co~tmuPletion of requi d June 2013 17.2F-I0 013 7 F-l0Revision June . 17

,*-DELETE PVNGS UPDATED FSAR EL112F1I 172~. . Nonconforming _tems/

Me sures shall be established to control items that do no con rm to specified requirements to prevent inadverten use or instal aion. These measures shall include provision to assure that: /

A. N conforming, inoperative, or malfunc ioning fire pro ction systems, emergency lightig, and cornmun cation equipment are appro lately tagged or

_ labeled... .

B. The identi cation, document ion, segregation, review dispostion, and no ifiation to the affected organization of onconfo ming materials, parts,

' components, or se ic are procedurally controlled.

C. Documentation ident s the nonconforming item, describes the no onfor ance and the disposition of

. the nonconform g item, a d includes signature

~approval of e disposition.

D. Provision are established ide tifying those individals or groups delegated e responsibility Measu s shall be established to ensure that condition adverse June 2013 17.2F-f1 013 7.2F-liRevision June 17

,.DELETE PVNGS UPDATED FSAR 31 I

~APPENDTX 17.2F ietified, reported, and corrected. These measures shall /

as/e A Procedures are established for evaluation of

conditions adverse to fire protection (such s nconformance, failures, malfunctions, de iciencies, deation, and defective material and e ipment) to deter me the necessary corrective ac on. _

B. In the c se of significant or repe tive condition adverse to ire protection, cincding fire i~ncidents, the cause of he condition isietermined and.

analyzed, and p ompt correc *ve actions are taken to preclude recurren e. The ause of the condition and the corrective acti tken are promptly reported to cognizant levels of agement for review and assessment.

C. Conditions adver e to fire rotection are periodically alyzed to dete ttrends which may not Sbe apparentto a day-to-day obs ve.

Records shall t prepared and maintained to furni h evidence that the cr eria enumerated above are being met fo activities affecting he fire protection program. The following rovision shall b included: ..

- R ecords are iden~tifiable and. retrievable and sha*

/ ~demonstrate conformance to fire Protection

/ ~requirements. The records shall include results of

-- inspection, tests, reviews, and audits; June 2013 17.2F-12 013 7 F-12Revision June . 17

,DELETE PvNG UPDATED FSAR 12"F014I X ~nonconformance and corrective action reports;/

~construction, maintenance, and modification record; Sand certified manufacturer's data./

B. ecrd retention requirements are establishe 17.2F.l1.3.2. ll Audits' /

17.2F.l.3.2.ll.1 Audits shall be onducted an documented to verify complance wth the fire protection proram, including design and procuremen\documents, instruct , procedures, drawings, and inspectio and test activites. These audits are performed by Nuclear Assu nce personne in accordance with pre-established written proc dures or check lists and conducted bytriedr peronel not havin dirct responsibilities in the 17.2F.l.3.2.11.2 Audit re lts are documented and reviewed with management having re osibility i te area audited.

17.2F.l.3.2.11.3 Folowup action is take by responsible management to corr deficiencies revealed bte audit.

172~. l Audits are performed to provi anoverall assessment of cofrmanc to fre protection require ens" 17.2F. .4.1 The vice President, Operations Support, is resp nsible for implementing and maintaining in effect all pr visions of the approved fire protection program for PVNGS,k s required by the Operating Licenses.

June 2013 17.2F-13 F-13Revision June201317. 17

,DELETE PVNGS UPDATED FSAR 112-F014

ib APPENDIX 17.2F

17. F.I.4.2 The Vice President, Nuclear Engineering, is respsile for establishing all technical and quality classif cation requirements for the engineering and desig f fire po tinsrcuesystems, and componentsinc /ding changes and odfications thereto.

17.2F.I.4.3 T e Director, Nuclear Assurance, srspnil for:

17.2F.l.4.3.1 Perfom g independent inspe/ion, when required.

17.2F.I.4.3.2 Performing an udit of t/he Fire Protection Program and implementing procedrsa frequencies specified in 13.4.5. /

17.2F.I.4.3.3 Reviewing Fir Protecti nprocedures as described in Section 17.2. .3..1.3.

17.2F.!.4.3.4 Resolvi g;/ disputes on matters ocrning the quality classificat/ of activities.

17.2F.l.4.3.5 eromng periodic monitoring to e ure that the requireme ts of this Appendix are properly implem nted.

17.2F.l.4 4 PVNGS Leaders are responsible for assistin in the imp ementation of the fire protection program as specif ed byainistrative controls and implementing procedures.

June 2013 17.2F-14 F-14Revision June201317. 17

,VDELETE PVNGS UPDATED FSAR 12-F014 7.2F.l.4 The Director, Performance Improvement, is/

re onsible for the establishment of programs for the .

repor ing, correction, and trend analysis of conditions a verse to fire rtectiOn.

17.2F.2.I.I Ths Appendix provides the Qua ity Assurance criteria for those dwaste Systems within he scope Of Regulatory Guide 1.14 II Design Guidance or Radioactive Waste Management Systems, Stru tures, and Co ponents Installed in 17.2F.2.1.2 Items and activ es to which this Appendix applies are identified and cl sil~ed in accordance with PVNGS Administrative Control Pro ures.*

7.2F.2.2 Purpose /k .. .

The purpose of this ppendix is to provide criteria that will furnish reasonableassurance that components and structures used in the rad active waste management and s eam generator blowdown syst s are designed, constructed, insta led, and tested to a evel commensurate with the need to pro ect the June 2013 17.2F-15 June201 172-iSRevision 17

DELETE PVNGS UPDATED FSAR 12-F014 1 2.2.3 Requirements /

17.2 .. 3.1 General/ "

12.2F.2I.3I. Since the impact of these systems on safe y is limited, quality assurance program corresponding to he full extent of Ap endix B to 10CFR Part 50 is not requir . However, to ensure that\ systems will perform their intende function, a quality asurn program sufficient to ensre at all design, contrctonan sing provisions are met all be established and doc ntd.

17.2F.2.3.1.2 The design procurement fabrication, and construction activities sha 1 confor t the quality assurance provisions of the codes and s anda ds referenced in Regulatory Guide 1.143.

17.2F.2.3.1.3 Where not coy rd byh eeece oe n standards, the quality ass7 ac featu es of this Appendix shall be established.

17.2F.2.3.2 Qualit Assurance_

The extent to whch the requirements of this Ap endix and its implementing d cuments are applied to an item or tivity shall be based on graded approach using the following c *eria:

A. he effect of a malfunction or failure of th tem on nuclear safety or safe plant operation.\

//'3. The design and fabrication complexity or uniquene*

~of the item.

JTune 2fl13 17.2F-16 Revision 17

DELETE PVNG*s UPDATED FSAR p2-F14 ]

I* APPENDIX 17.2F C. The need for special controls, surveillance or S monitoring of processes, equipment, and operato

" k activities.

D. *The degree to which functionality can be dem strated

~inspection or test./

E. The uality history and degree of stand rdzation of the it m When the graded app oach is utilized, the ju tfication and basis for grading sha 1 be documented and erevable.

Application Of the grad dapproach shal b accomplished in accordance with procedure concurred ith by the Nuclear Assurance organization. The e proc dures shall clearly identify how the justification a basis for grading shall be documented and maintained. "

Grading of Plan requirements plic ble to items shall be the responsibility of the Vic President, uclear Engineering.

Grading of Plan requir ents applicable o activities shall be the responsibility o the organization res nsible for performing the acvity.

17.2F.2.3.3 D sign and Procurement 17.2F.2.3.3 1 Design and procurement documents shal be independetly verified for conformance to the requirem nts of Regula ry Guide 1.143 and this Appendix by individual(sk with the design organization who are not the originators f th documents. Changes to these documents shall be verified r iontrolled to maintain conformance to this Appendix.

June 2013 17.2F-17 F-17Revision June201317. 17

,,*-JDELTE IPVNGS UPDATED FSAR12F4 1 2F.2.3.3.2 Measures to ensure suppliers of material, /

equi ment, and construction services are capable of supplyng these tems to the quality specified in the procurement/

document shall be established. This may be done by a/

evaluation r a survey of the suppliers' products a facilities.

17.2F.2.3.3.3 In tructions shall be provided in procurement documents to contro the handling, storage,/shipping, and preservation of materi 1 and equipment to prevent damage, deterioration, or reducto inte1v of cleanliness.

7.F234inspection \ /

Iaditi*on to required odze in *ections, a program for_

and executed by, or for, th organi aion performing the activity to verify confor ance with t documented instructions, procedure , nd drawings r accomPlishing the activity. This shallInclude the v~isual in ection of components prior t installation for conform ce with procurement docu ents and the visual inspectio of items and systems followng installation, cleanness, and pa sivation (where app ).d) 17.2F.2..5 _InspectionTest and Operating Status_ . .

Meas es shall be established to provide for the identific tion of tesm which have satisfactorily passed required inspectio*

June 2013 17.2F-18 013 7 F-18Revision June . 17

,[DELETE PVNGS UPDATED FSAR12F4 Meas es shall be established to identify items of/

noncon rmance with regard to the requirements of procurem nt documents or applicable codes and standards and to i den *fy the action take t correct such items.

17,2F.2.3.7 Re rds Sufficient records hall be maintained to furnsh evidence that the measures identifi d herein are being imp emented. The records shall include r sults of reviews a d inspections and shall be .identifiable _and rerievable.

I_7.2F.2.4.1 ".The Radiation Pro ction Manager is responsible for implementing and maintaini g i effect all provisions of the Radwaste Management Prog am for P NGS, as required by the Operating Licenses."/

17.2F.2.4.2 _The Vi* President, Nuclear gineering, is r esponsible for est lishing all technical an quality classification re irements for the engineering nd design of the R~adwaste st uctures and components, including hanges and modifications 17.2F.2. 3 The Director, Nuclear Assurance, is respo ible for:/

17. .2.43.1 Performing independent inspections, when June 2013 17.2F-19 F-19Revision June201317. 17

,-DELETE PvNGs UPDATED FSAR [12-F0141

d~e APPENDIX 17.2F 7.2F.2.4.3.2 Reviewing Radwaste Management procedures as /

de rbed in Section 17.2.4.3.1.3. .

17.2F. 4.3.3 Resolving matters of dispute with regard o the quality c asification of activities./

17.2Fo2.4.3.4 Performing periodic monitoring to, sure that terequirement ofthis Appendix are properl et.

17.2F.2.4.4 PVNG Leaders are responsibi for assisting in the implementation of he Radwaste Manag ent Program as specified by the adminis rative contro and implementing procedures _..

17.2F.2.4.5- The Director, P ormance Improvement, is responsible for the establish nt of programs for the reporting, correction, and end an lysis of conditions adverse to quality related to radaste manage en.

17.2F.3 QUALITY ASSRANCE FOR SECURITY 17.2F.3.1.1

is Appendix provides the Quali Assurance requirements pplicable to the PVNGS Security Pro am 17.2F.3. 2 _Activities to which this Appendix appli s are identis edand classiieodinaccrdance with PVNGS June 2013 17.2F-20 F-20Revision June201317. 17

,tDELETEI PVNGS UPDATED FSAR 12-F0141

7.2 APPENDIX 17.2F 7.F.3.1.3 This Appendix, along with its implementing pr cedures, comprise the PVNGS Quality Assurance Program f The purpose f this Appendix is to ensure that th rquirements of 10CFR73, "P yical Protection of Plns n teil, and the applicable R ulatory Guidance are approp i.ately applied to protect PVNGS from csof industrial sao ethat could lead to a threat to the helhand saeyof e public.

172.. Requirements 17.2F.3.3.1 General The security program is dec' further in section 13.6.2, "Security Plan".

17.2F.3.3.l.I The securi program or PVNGS shall provide for A. The mainte ance of the physical security plan submitte2Fy ine*-/5 accordance with 10CF 0.34(c) and B. The /maintenance of the training and qu lification p an submitted in support of the physica security plan, as required by 10CFR73, Appendix B, ' eneral Criteria for Security Personnel."

c. The maintenance of the safeguards contingency pl n

/ ~submitted in support of the physical security planX

Tinn* 2flIZ 17.2P-21 Revision 17

,,DELETEI PVNGS UPDATED FSAR 12-F014I Plan," and 10CFR73, Appendix C, "Licensee Safeguard/

Contingency Plans."/

17.2F.3. .1.2 Changes to the physical security plan, t e training a dqualification plan, and the safeguards cintingency plan for PV S shall be either pre-approved or subsquently accepted for i cusion in the plan(s) by the NRC where necessary.

17.2F.3.3.1.3 safegu rds Information shal be protected against unauthorized di closure in accor ance with 10CFR73.21, and shall be restricted t authorized ersonnel with an established need-to-know. /. ..

17.2F.3.3.1.4 Security trainin operational activities, and contingency measures shall becomp eted in accordance with the plans described i17.2F3 .1.1.

17.2F.3.3.1.5 Reporti g of physical sec ity events shall be accomplished in accodance with 10CFR73.71.X 17.2F.3.3.2 Quity Assurance 17.2F.3.3.2.1 Instructions, Procedures, and Drawi gs Instructio s, procedures, and drawings for implementi g the security program shall be prepared, processed, and cont olled iacrdance with PVNGS Administrative Control Procedure*

June 2013 17.2F-22 F-22Revision June201317. 17

,*-DELETE PVNGS UPDATED FSAR 12-F0114 17 .3.3.2.2 Reviews A revew' of the security and safeguards contingency program shall bperformed at least once every 24 months using t*

pefrmn -based option permitted by 10CFR73, Appendix/C, 10CFR73.55g (), and 10CFR50.54(p) (3&4), ormoefquny when necessary to meet these regulations. Deficie ies identified durnn reviews of the security progra* shall be documented, review by< management, and evaued *for trends.

17.2F.3.3.2.3 Correcti eActions *etfe Security Program deficien ses sall !be enfedand controlled in accordance wit PVNGS dministrative Control Procedures.

17.2F.3.3.2.4 Records tt Records generated during t deeomtand implementation of the security program shal b processed nd maintained in accordance with Sectio 17.2.6 of this QA an 17.2F.3.4 Responsilities 17.2F.3.4.1 pe Director, Nuclear security Di *son, is responsible f implementing and maintaining in ef ct all provisionsif the approvedLseuriy program for PVNGS, as June 2013 17.2F-23 June . 17 013 7 F-23Revision

,VDELETE PVNGS UPDATED FSAR E2-F14 I 12F.3.4.2 The Director, Nuclear Assurance, is responsible for:

A.k Performing an audit of the PVNGS security progr at fequencies specified in 13.4.5._/

B. Pe forming periodic monitoring to ensure t t the requ rements of this Appendix are proper y C. Deleted D. Reviewing se urity Program Proce res as described in

_ Section 17.2.4.3..3./_ _

E. Resolving dispute on matte s concerning the quality classification of s ui activities.

17.2F.3.4.3 PVNGS Leaders a sponsible for assisting in the implementation of the se rity p ogram as specified by administrative control ad iplementin prcedures.

7.2F.3.4.4 The Dir ctor, Performance I rovement, is responsible for the stablishment of Program for the reporting, correc on, and trend analysis of co dit ions adverse to quality relaed to security.k 17.2F 4.1.1 This Appendix provides the Quality Assurancek re iemets aplcabl::m.e to the PVNGS Emergency Plan and June 2013 17.2F-24 013 7 F-24Revision June . 17

DELETE PVNGS UPDATED FSAR12F4 APENix 17.2F 1.F.4.1.2 Items and activities to which this Appendix apples are identified and classified in accordance with PVN Admini trtive Control Procedures. .

17.2F.4.1.k This Appendix, along with its implementng procedures, *mprise the PVNGS Quality Assurance Pr ram for Emergency Plann ng 172 . Purpose\

The purpose of this Ap endix is to ensure at the requirements of i0CFR50.47, "Emergenc Plans and 10C R50, Appendix E, "EmergencY Planning and Pr aredness fr Production and Utilization Facilities" and e app cable Regulatory Guidance are appropriately applied to p vde assurance that adequate protective measures are taken* i e event of a radiological emergency"./

17.2F.4.3.1" General/_ __

The PVNGs EergencPlan shall:..

A. Establ h plans for coping with emergen is.

June 2013 17.2F-25 17 013 7 F-25Revision June .

!DELETE PVNGS UPDATED FSAR ~I12F014 D. Establish provisions for prompt communication among principal response organizations, emergency personnel, and the public./

E.Dsrieamiitaiveadpyialgeancis fo not fyng local, state, and federal agnces n emerg cy personnel./

F. EstablieumntS and describe emergency facili es/ and G. Establishemlyesa p grm to provide fr raining of H. Require periodic d isand P ovide for formal critiques of drills.!

I. Provide for independent eviw of the emergency preparedness porm J. Identify and evalu e events *hich may arise during operation. /

K. Provide direc on of activities to lmit consequences of an accid t,.

L. Provide r a general approach to recov y.

M. 'euperiodic testing of communication 'stems.

17.2F.4.3.2 Quality Assurance Plans, p ocedures, and instructions shall be prepared, proces ed, and controlled in accordance with PVNGS Ad strative Control Procedures.

June 2013 17.2F-26 .F-26Revision June201317 17

,DELETE ]PVNGS UPDATED FSAR 112-F014I

. ~APPENDIX 17.2F/

M asuring and test equipment utilized in implementing the/

Eme ency Plan shall be calibrated against standards which a e tracea le to National Institute of Standards and Technolog or other na ionally recognized standards. In cases whereS such standard e *ts, standards should be derived or devel ed.

Equipment, co onents, and supplies that are utili d in implementing the Emergency Plan shall be inspect d at least quarterly. Equipm nt and components shall be aintained and tested in accordance with approved written ocedures.

Deficiencies shall be cumented and corrcted.

Deficiencies noted during rills and e ercises shall be incorporated in action itemsX Follo -up shall be performed to ensure that deficien~cies are c rreted.,

Independent audit of the Emergec Program (including the Emergency Plan) shall be pmer rmed.

Records, including traini records, g erated during the development and implemetation of the Eme gency Plan shall be identifid and their etention requirements sal be specified.

17.2F.4._4.1 The Vice President, OPerations Supp rt, is responsible or, implementing and maintaining in effe tall provisio of the Emergency Plan for PVNGS.*

72F442 TeDrco, Nula ssurance, i epnil fo Iaut June 2013 17.2F-27 013 7 F-27Revision June . 17

DELETEI PVNGS UPDATED FSAR 12F1

k APPENDIX 17.2F/

B. Performing periodic monitoring to ensure that the /

requirements of this Appendix are properly/

\\implemented.

C. esolving disputes on matters concerning the jality c ssfication of Emergency Plan activities 17.2F.4.4.3 VNGS Leaders are responsible forissisting in the implementatio of the Emergency Plan as sp ified by administrative cont 1 nd implementing procures.

17.2F.5 QUALITY ASSURA C FOR SEISMIC TEGORY IX 17.2F.5.1*I This Appendix p ovis the Quality Assurance criteria for items that do not p form a safety related function but whose structural ail re and collapse during a safe shutdown earthquake co d reduc the functioning of safety related equipmen or sys s."

17.2F.5.1.2 Items d activities to whic this Appendix applies are identifed and classified in acco dance with PVNGS Administrative Cotrol Procedures.

The purpos of this Appendix is to ensure that seismic ategory TX i tem are designed and installed such that a safe shut own earthuake will not cause their structural failure and coll se or ause the generation of mi!ssiles that could reduce the fnctioning of safety related structures, systems, and components.

June 2013 17.2F-28 Revision 17

X*.DELETE PVNGS UPDATED FSAR t12-F014 APPENDIX 1.2 172.5.3 Requirements 17.2 5.3.1 General The quality augmented program applied to seismic category IX structures systems, and components is primarily intend d to provide desiln nd configuration control.

The primary foc s of this quality augmented progr is component support d support elements.

anX It al must be applied to supporte components\ to the extent hat the support is an integral part o te supported compOen n This quality augmented p gram is not inL eded to encompass structures, systems, and co ponents wh se failure could reduce the functioning of safety re tdeiment through leakage, spray, or impingement effects. .

17.2F.5.3.2 Quality Assuranc*

17.2F.5.3.2.l The extent which the equirements of this Appendix and its impleme:* ing documents a e applied to an item activityciea:shall be b ed* on a graded appr ach using the orfolwn folw ngucrieri a:eyo aepan prtoe A. The eff t of a malfunction or failure f the item on nud saeyhrsfeiplant opratioln. eor B. Th design and fabrication complexity or uni ueness C. The need for special controls,suvilneo monitoring of processes, equipment, and operational

activities.

June 2013 17.2F-29 F-29Revision June201317. 17

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~APPENDIX a17"2F D. The degree to which functionality can be demonstrae by inspection or test.

E. The quality history and degree of standardiztion of he item./

When the gra ed approach is utilized, the justificati n and basis for grad g shall be documented and retrievabe.

Application of t graded approach shall be acco lished in accordance with pro edures concurred with by t Nuclear Assurance organizatio . These procedures sh 1 clearly identify how the justifcation and basis f r grading shall be documented and maintained.

Grading of Plan requirements pplicabe to items shall be the responsibility of the Vice Pre de, Nuclear Engineering.

Grading of Plan requirements appi ble to activities shall be the responsibility of the org izati n responsible for performing the activity.

17.2F.5.3.2.2 Designentrol The organizational s ructure and responsibili is of personnel involved in preparng, reviewing, approving, an verifying design document shall be defined.

Internal and xternal design interface controls, pro dures, and lines/ communication among participating design organiza ons *an acrosstehncaiscilns shall be k June 2013 17.2F-30 013 7 F-30Revision June . 17

-- DELETE 1PVNGS UPDATED FSAR 12-F014 ndor designed components shall be evaluated by Engineering o the extent necessary to assure that they are compatible wit appro e support design parameters.

A. Components or parts containing integral supp t e ements (e.g., a built-in mounting bracke on an ins rument) shall be analyzed by Enginee ing to ensur that the support element is ade uate to withsta a safe shutdown earthquak without loss of structural integrity.

B. Vendor design d equipment shal be documented on approved drawin s that are s fficiently detailed for

.... the performance o configuation inspections.

Conditions adverse to quality n approved design documents, including design methods (such a computer software) that could adversely affect items withi the cope of this Appendix shall be identified, documentedand corre ted. An evaluation of the effect of such conditio s adverse to q lity on installed hardware shall be per ormed. Significan conditions adverse to quality shall be pr mptly identified, evalu ted for reportability, ay corrected. The cause of s nificant conditions adv se to quality shall be determin and appropriate ction taken to prevent recurrence.

Design ye ification methods shall be established con stent with th commitment to Regulatory Guide 1.64 (includin*

clan ications and exceptions) contained in Appendix 17.2 of th Plan.

June 2013 17.2F-31 F-31Revision June201317. 17

,.DELETEI PVNGS UPDATED FSAR 12-FO1jj

F APPENDIX 17.2 12.5.3.2.3 Instructions, Procedures, and Drawings Acti ities critical to the structural integrity of seismic catego* IX systems, structures, and components shall be accompli ed in accordance with documented procedures, instruction , and/or drawings of a type appropriate othe circumstances* These procedures, instructions, ar drawings shall, as appro iate, be clearly identified asqult related." (Since rocedure compliance is req re by 17.2.2.2.2 of this p an, regardless of qualty classification, identification of proc dures as "Quality ead"is not required).pe, 17.2F.5.3.2.4 Control of Sp ia ocess Special processes subject to th controls mandated by this Appendix are welding, brazing an nondestructive examination which, if performed incorr tly, cou dhave a detrimental effect on the structural ntegrity of eismic category IX structures, systems, ocomponents.X Measures shall be e ablished to assure tha special processes are accomplished nder controlled conditions i accordance with applicable code, standards, applications critera, and other requirementsincluding the use of qualified perso el and procedures.

Qualifi ation records of personnel, equipment, and proc ures assocated with special processes shall be established an*

ma tamned to the extent required by applicable codes and andards.

June 2013 17.2F-32 013 7 F-32Revision June . 17

DELETE PVNG-S UPDATED FSAR ~I112F1 1I.F.5.3.2.5 Contro___l of Measuring an__d Tes___t Equipment (M&TE)/

Mea res shall be established to assure that tools, gauges, instru ents and other measuring and testing devices used n activiti saffecting the structural integrity of seismc category I structures, systems, and components are roperly controlled an calibrated or adjusted at specifie intervals to maintain accura with specified limits. /.. .

Measures shall be stablished for de termininythe validity of previous inspections o tests performed wh n the measuring and test equipment is foun to be out of cal ration. Such determination is to be do umented in itable form. If any calibration, testing or mea uring d ice is consistently found to be out of calibration, it al be repaired or replaced.

Some measuring tools, becauseif teir construction or because they are not adjustable (suc as r ers) may not require periodic calibration. Ho ver, they hall be maintained in A program of ins ection shall be establ~ished b or for the.

organization prforming maintenance and modifica *n activities that could fect the structural integrity of seismc category IX structres, systems, and components.

The in ection program associated with the installationf seis ic IX.compo~nents shall include verification of genera*

cfie°mfguration of vendor and APE designed components and suppo ~t June 2013 17.2F-33 June013 7 F-33Revision

. 17

!DELETE PVNGS UPDATED FSAR '~12-04I Mesres shall be established to assure that inspection pers nnel are independent from the individuals performing the activi being inspected and are knowledgeable in the desi and insta ation requirements for seismic category IX/

structures, sytems, and components.

17.2F.5.3.2.7 Contol o Coniions Adverse to Qality and Measures shall be es ablished for controllin items that do not conform to specified r uirements to preve inadvertent use or installation.

Measures shall be establish tO ensu e that conditions adverse to quality are promptly identi iedidocumented and corrected.

Significant conditions adverse t quality shall be promptly identified, evaluated for repo ab ity, and corrected. The cause of significant conditi s adve e to quality shall be determined and appropriat action taken toprevent recurrence.

17.2F.5.3.2.8 Contro of Documents and Re ords Measures shall be e tablished for the control nd generation of documents and rec rds associated with activities critical to the structural ntegrity of seismic category IX st uctures, systems, and components.

These mea res shall control the issuance of documents.ch as program documents, design documents[,and work* instructions that s~trmcUral ntegrity of .seismic category IX structures, June 2013 17.2F-34 17 F-34Revision June201317.

XFDELETE IPVNGS UPDATED FSAR [2F1 ee measures shall require that records are prepared and mai ]tained to furnish objective evidence that the criteria/

enume ated above are being met for activities affecting th strctual integrity of seismic category IX structure, ses and compo ents.

l7.2F.5.4 Re onsibilities l7.2F.5.4.1 T Vice President, Nuclear Eng ering, is A. Establihn altechnical and a lity classification requirements f the engineer 'g and design of seismic categoryXsrcue, ytman components.

B. Identifying attributes requiring inspection.

17.2F.5.4.2 The Dieco Nuclea Assuranceirepnbl for :

A. Performing i ependent inspecti swhen required.

B. ci( rcedures associated wi aReviewing th impleme ation of this Appendix a dcribed in C. Re lying matters of dispute with regard *the

ality classification of activities.

D. Performing eriodicmontoigsrtOpenSure that he June 2013 17.2F-35 013 7 F-35Revision June . 17

,__DELETEI PVNGS UPDATED FSAR 12-F014I APPENDIX 17.2F*

17 2F.5.4.3. PVNGS Leaders are responsible for assisting in /

the plementation of the seismic category IX program as/

specifi d by the administrative control and implementing procedureX 17.2F.5,4.4 XThe Director, Performance Improvement, is responsible for the establishment of programs for te reporting, correc *n, and trend analysis of con tions adverse to quality related t Seismic IX structures, s stems, and components programs.

17.2F.6 QUALITY ASSURANCE OR STATION LACKOUT COPING EQIMET7.2F.6.l Scope*

17.2F.6.1.I This Appendix pr i s the Quality Assurance requirements applicable to ot e non- afety related station blackout coping equipment yed to meet *e requirements of I0CFR50.63 and not alrea covered by exi ing QA requirements in 10CFR50 Appendix B R.

17.2F.6.1.2 Ite s and activities to which thi Appendix applies are ide ified and class ified in accordanc with PVNGS Administrati Control procedures . ..

17.2F.6.l This Appendix along with its implementingk procedu es comprise the PVNGS Quality Assurance Program fork nnsfety related station blackout coping equipment.

June 2013 17.2F-36 F-36Revision June201317. 17

,DELETE PVNGS UPDATED FSAR 12F1 1I.F.6.2 Pur__pose The urpose of this Appendix is to ensure that the quality/

assura ce requirements of Regulatory Guide 1.155 (August 1988),

Appendix , are appropriately applied to ensure oompl' ce with the stat ion blackout rule.

17.2F.6.3 Requirements 17.2F.6.3.1 Gener 1 17.2F.6.3.1.l Since *-he impact of this sy tern on safety is limited, a quality assu ance program co *esponding to the full extent of Appendix B to 1 FR Part 50/is not required.

However, to ensure that the ystem ill perform as intended, programs sufficient to enuehapiation of the quality assrane povsions of Regula o Guide 1.155 shall be established and documented 17.F.63..2 qupmet.nstalled to m tthe station blackout rule shall be impleme/ed such that it do* not degrade existing safety-re {ted systems. This shhbeacop lihe b making the non-sa ety related equipment as i pendent as practicable r existing safety-related systems.

June 2013 17.2F-37 013 7 F-37Revision June . 17

-- DELETE ]PVNGS UPDATED FSAR [~ 1 Ui4-1 1 2.. ult Assurance/

Appendx and its implementing documents are applied to an item or activ t shall be based on a graded approach, consisent with Regula ory Guide 1.155 requirements, using the ilowing criteria: /

A. The e ect of a malfunction or failur of the item on nuclear afety or safe plant operaton.

B. The design nd fabrication compl xity or uniqueness of the item. /

C. The need for spe ial contros, surveillance or monitoring of proc ses, quipment, and operational activities.

D. The degree to which un ionality can be demonstrated bY inspection or est-.

E. The quality hi tory and degre of standardization of the item./

When the graded app oach is utilized, the ju tification and basis for gradin 'shall be documented and retr evable.

Application of he graded approach shall be acco lished in accordance wth procedures_ concurred with by the Nu lear identif how the justification and basis for grading sh 1 be docum ted and maintained. _. .

Cr~idin of Plno requrementrPsP appicble to itemseEshallibe th*

esosblt/fteVc rsdnNcerEgneig June 2013 17.2F-38 013 7 F-33Revision June . 17

,--DELETE PVNGS UPDATED FSAR12F4 G ading of Plan requirements applicable to activities shall b the responsibility of the organization responsible for/

perfo in the activity./_

17.2F.6.3. .2 Design Control and Procurement Documen Control Measures sha be established to ensure that all d sign-related guidelines use in complying with 10CFR50.63 are included in design and procur ment documents, and that dev ations therefrom Inspections, tests, admini trative c trols, and training necessary for compliance wit lOCF 0.63 shall be prescribed by documented instructions, proce *es, and drawings and shall be accomplished in accordance wit ese documents. Document control measures shall be ap lied t assure that activities are completed in accordance w h the late t approved revisions of these documents. /_ _ k 17.2F.6.3.2.4 Con ol of Purchased Materirvcsa , Equipment, and Measures shall e established to ensure that pur ased material, e ipment, and services conform to the p curement documents 17.2F..3.2.5 Inspection ...

A pogram for verification/inspection of activities affectin*

ation blackout coping equipment shall be established by or for the organization performing the activity to verify June 2013 17.2F-39 013 7 F-39Revision June . 17

,DELETE PVNGS UPDATED FSAR 12-F14II

.

APPENDIX 17.2F/

co ormance with documented installation drawings and test /

proc dues for accomplishing the activities.

17.2F.6. .. 6 Testing and Test Control A test prog am shall be established and implemented t ensure that testing *sperformed and verified by inspectio and audit to demonstrate onformance with design and system readiness requirements. Te s shall be performed in accodance with written test procedu es; test results shall* properly 17.a2 li~ Inspectin, itdupTF.6.3.2. est, and 0 /eratin Status

.Measures shall be established t id ntify items that have satisfactorily passed required e s and inspections.

17.2F.6.3.2.8 Nonconforming tems Measures shall be establis ed to ctr items that do not conform to specified re irements open inadvertent use or 17.2F.6.3.2.9 Co etv Action Measures shall eestablished to ensure that failu e, malfunctions dfciencies, deviations, defective co onents, and noncon omne are promptly identified, reported, nd June 2013 17.2F-40 F-40Revision June201317.17

DELETEI PVNGS UPDATED FSAR 12-F014t APEDX 72 172.6.3.2.10 Records Recor s shall be prepared and maintained to furnishevdn that th criteria enumerated above are being met for acti ties affecting testation blackout coping equipment.

17.2F.6.3.2.1 Adits _

Audits shall be *nducted and documented to yen y compliance with design and pro urement documents, instruc ions, procedures, drawings, and inspection and tes activities developed to comply wit 10CFR50.63. The audit areh performed bY- Nuclear Assu ance personne in accordance with pre-established written pro dures or check lists and conducted bytrie d peronel having no dire t responsibilities in the

17. 2F. 6.4 Responsibilities*

17.2F.6.4.1 The Vice Pr sident, Nuc ar Engineering, is responsible for establi ing all technica and quality classification requir *ents for the ngeeigand design for the station blacko coping equipment, inclu g changes and 17.2F.6.4.2/ PVNGS Leaders are responsible o as *sting i the implem tation of the station blackout coping eq]uien program- specified by administrative controls and implem nting procedures.

June 2013 17.2F-41 F-41Revision June201317. 17

DEEEPVNGS UPDATED FSAR 12-F014 SDELETE I

nsible is APPEND/

rify Assurance, Nuclearmonitoring The Director, 17.2F.6*

and periodic 17.2F.6. 3 The Director, Nuclear Assurance, is res nsible for performi*dits for performi audits and periodic monitoring to rify compliance with t requirements of this App dix.

June 2013 17.2F-42 013 7 F-42Revision June . 17

,DELETE PVNGS UPDATED FSAR 112-F014

~APPENDIX 17.2G CONTROL OF COMPUTER SOFTWARE AND DATA 17.2G.I GENERAL Measures s al be established utilizing the graded aroc to ensure that e requirements for procurement, inst lation, design, testin modification, and use of softwa e and computer databases are co esurate with their importa e to safety.

17.2G. 2 PROGRAM REQ IREMENTS /

17.2G.2.1 The computer software deve Pment process, documentation requirements, and quaY ication and approval requirements shall be establi hed.

17.2G.2.2 Methods shall be e ta lished and implemented to control the procurement of mputer sofware.

17.2G.2.3 Methods sha* be establishe and implemented to document, evaluate, a d correct errors an deficiencies in computer software./Their impact on past an present design activities shalle evaluated.

17.2G.2.4 *thods shall be established and imple ented for the contr of changes to approved computer software.

17.2G. .5. Methods shall be established for the installa ion, June 2013 17.2G-I G-lRevision June201317. 17

,DELETE IPVNGS UPDATEDn FSAR E12F04I

~APPENDIX 17.2G*

17 2G.2..6 Methods shall be established for the maintenance.

and etention of computer software and associated documentat on in acc dance with Section 17.2. 6.4 of this Plan.

17.2G.2.7 Prior to utilization, computer software s all be qualified in ccordance with approved procedures, o by administrative ontrols that require verification of output prior to use. k 17.2G.2.8 Controls all be established* verify the accuracy and integrity o dta input mt computer databases.

17.2G. 3 APPLICABILITY /

17.2G.3.1 The requirements o tis Appendix apply to computer software and relevant data notiP cifically classified as a plant system, structure, orrmpone tin accordance with Section 17.2.2.8 of this P h n

17.2G.3.2 The requir ents of this Appen ix apply to computer software that is use to:.. .

A. Generat design output which defines r Prescribes activties affecting safety related fun tons or eB..irectyinerface, with contrl roo*mtPerSonn an is

1. heibntedngrity of the reactor coolant press r bondry June 2013 17.2G-2 June20131717

.2C-2Revision

-DELETE PVNGS UPDATED FSAR 1*2-F014]

~APPENDIX 17.2G0 k 2. The capability to shut down the reactor and /

k ~maintain it in a safe condition./

3. The capability to prevent or mitigate th consequences of accidents that could rsult k in potential offsite exposure compar ble to

~ ~the10CFRI00 guidelines./_

C. Perfor calculations which result in a cePtance of inspecti n or test data for quality elated equiPment.*

D. Design or aid in the design of uality related structures, sysrins, or compo4ents including physics, seismic, stress, t ermal, draulic, radiation, and

.... accident analysis.

17.2G.3.3 The requirements o th sappendix also apply to computer databases that are sed wit ut further verification to maintain or control de criptive info mation for output used in design, operation, m intenance, test, 'nspection or Procurement of quali related items.*

17.2G.4 RESPONSBIELITIES 17.2G.4.1 T* Vice President, Operations Support, is responsible or the develoPment of non-process compu r software d data controls in accordance with the requi ements of this lan. ...

17.0.42 Te DrecorPlat Eginerig, srsposibe June 2013 17.2G-3 .0-3Revision June201317 17

,FDELETE PVNGS UPDATED FSAR L III 17.2G.4.3 T retor, Nuclear Assuranc, se~ sponsibe for performing Quality As anc verificato in accordance with June 2013 17.2G-4 June20131717

.2G-4Revision

PVTNGS UPDATED FSAR 18.I.B OVERALL ORGANIZATION 18.I. B.1.2 INDEPENDENT SAFETY ENGINEERING GROUP NRC Position Each applicant for an operating license shall establish an onsite independent safety engineering group (ISEG) to perform independent reviews of plant operations.

The principal function of the ISEG is to examine plant operating characteristics, NRC issuances, licensing information service advisories, and other appropriate sources of plant design and operating experience information that may indicate areas for improving plant safety. The ISEG is to perform independent review and audits of plant activities, including maintenance, modifications, operational problems, and operational analysis, and aid in the establishment of programmatic requirements for plant activities. Where useful improvements can be achieved, it is expected that this group will develop and present detailed recommendations to corporate management for such things as revised procedures or equipment modifications.

Another function of the ISEG is to maintain surveillance of plant operations and maintenance activities to provide independent verification that these activities are performed correctly and that human errors are reduced as far as practicable. The ISEG will then be in a position to advise utility management on the overall quality and safety of operations. The ISEG need not perform detailed audits of plant operations and shall not be responsible for sign-off functions such that it becomes involved in the operating organization.

June 2001 18.I.B-I ..B-1Revision June200118 11

PVNGS UPDATED FSAR 12-F014 1 OPERATIONAL SAFETY PVNGS Evaluation

-In rcsponse to the recommecndations cf NUREC-0737, TIndep...cnt perform independent reviews of plant operations. The principal funtio of*ISE was t... o..... plant operating charact..ri.tic.,

NRPC i .. u...e.. industry advisories, liceseevent reports, and

.th.r...ur .. of plant design and operating experi.nce

-Thc Director, Nucle7ar Assurance, s responsibl f7r performance...

peror th independen safety review function. Personn..l performing independent safety reviews are outside of the line of responsibility fo *,

power... production an independent of th da -oday pln oprtn respnsiiliies Detailed ro~airements for imnlementation of the indeuendent

,-, -~,-4 ,- 1 " A A The program and related procedures for review of operating experience described at UFSAR 18.1.0.5 are the primary method used at PVNGS to review and act upon internal and external operating experience.

To augment the program and related procedures described at 18.1.C.5, the Director, Nuclear Assurance, is responsible to monitor and assess operational activities to provide assurance that activities important to safety are performed satisfactorily. Specific functions of the Nuclear Assurance staff are described in the Operations Quality Assurance Program Description (QLAPD).

June 2007 18 .I.B-2 ..B-2Revision June200718 14

ATTACHMENT 4 Comparison of Existing NRC Regulatory Guide Commitments to New NRC Regulatory Guide Commitments Adopted in the proposed QAPD (6 Pages Follow)

ATTACHMENT 4 Comparison of Existing NRC Regulatory Guide Commitments to New NRC Regulatory Guide Commitments Aadopted in the proposed QAPD Basis 1.0 I[1S1-1S*, iviay I1J/I), PVNGS will maintain existing commitment to Personnel Selection and Training 1978 Personnel Selection and Regulatory Guide 1.8 consistent with the Units 1, Training 2, and 3 Technical Specifications with the

[Modified] exception of qualifications for the independent QA organization management personnel described in NEI 1 1-04A, Part II, Section 2.6.

1.21 (RI, June 1974), N/A [NO CHANGE] N/A PVNGS will maintain existing commitment to Measuring, Evaluating, and Regulatory Guide 1.21las described in UFSAR 1.8.

Reporting Radioactivity in Solid The reference to RG 1.21 in the current PVNGS Wastes and Releases of QA Program UFSAR 17.2 was intended to identify Radioactive Materials in Liquid that QA program elements discussed in Regulatory and Gaseous Effluents from Guide 1.21 are independently audited by the Light-Water-Cooled Nuclear PVNGS Nuclear Assurance organization.

Power Plants 1.26 (RI, September 1974), N/A [NO CHANGE] N/A PVNGS will maintain existing commitments to Quality Group Classifications and Regulatory Guide 1.26. PVNGS was designed and Standards for Water-, Steam- and constructed to RG 1.26, Revision 1, September Radioactive-Waste-Containing 1974. A change to a newer version of the Components of Nuclear Power regulatory guide would require significant analysis Plants and potential backfit of design information used in the development of the quality classifications for PVNGS, which is not practical or necessary at the current stage of the operational phase.

1.28 (R0, June 1972), N45.2 (1971 ) 1.28 (R4, June 2010) NQA- 1-2008/NQA- 1a- PVNGS will commit to Regulatory Guide 1.28, Quality Assurance Program 2009 Part I/ll Revision 4, June 2010. RG 1.28 Revision 4 Requirements (Design and endorses NQA-1-2008/2009 Part I/II as the basis Construction) for the operational phase quality assurance program

___________going forward.

1.29 (R3, September 1978), N/A [NO CHANGE] N/A PVNGS will maintain existing commitments to Seismic Design Classification Regulatory Guide 1.29. PVNGS was designed and constructed to RG 1.29, Revision 3, September 1978. A change to a newer version of the regulatory guide would require significant analysis and potential backfit of design information used in Notes: W=Withdrawn RG; Wi = Withdrawn RG after Issuance of RG 1.28, Revision 4, June 2010 Pg page 1

ATTACHMENT 4 Comparison of Existing NRC Regulatory Guide Commitments to New NRC Regulatory Guide Commitments Aadopted in the proposed QAPD Basis the development of the quality classifications for PVNGS, which is not practical or necessary at the current stage of the operational phase.

1.30 (R0, August 11, 1972), N45.2.4 (1972) 1.28 (R4, June 2010) NQA-1-2008/NQA-la- PVNGS will commit to Regulatory Guide 1.28 Quality Assurance Requirements 2009 Subpart 2.4 Revision 4, June 2010. RG 1.28 Revision 4 for the Installation, Inspection endorses NQA- 1-2008!/NQA-lIa-2009. Table A-3 and Testing of Instrumentation of RG 1.28 Revision 4 provides a cross-reference and Electrical Equipment between previous regulatory guides, the related ANSI Standards, and location in NQA-1. The cross-reference for RG 1.30 and ANSI N45.2.4 is NQA- 1-2008/NQA-l1a-2009 Subpart 2.4 1.33 (R2, February 1978), N18.7 (1976) 1.28 (R4, June 2010) NQA-1-2008/NQA-1la- PVNGS is currently committed to Regulatory Quality Assurance Program 1.33 (R2, February 1978) 2009 & NEI 11 -04A Guide 1.33, Revision 2, February1 978.

Requirements (Operation) In lieu of adopting ANSI N 18.7-1976/ANS 3.2 per RG 1.33, PVNGS will adopt RG 1.28, Revision 4, NQA- 1-2008/NQA- Ia-2009, and the additional guidance for operational phase activities provided in the text of NEI I 1-04A, Part V.

1.37 (R0, March 16, 1972), N45.2.1 (1973) 1.28 (R4, June 2010) NQA-1-2008/NQA-1la- PVNGS is currently committed to Regulatory Quality Assurance Requirements 1.37 (Ri, March 2007) 2009 Subpart 2.1 Guide 1.37, Revision 0, March 16, 1973.

for Cleaning of Fluid Systems PVNGS will commit to the revision of RG 1.37 and Associated Components of endorsed in NEI I11-04A, but in lieu of adopting Water-Cooled Nuclear Power ASN4E NQA-l-1994, Part II, Subpart 2.1 per RG Plants 1.37, Revision 1, March 2007, PVNGS will adopt NQA-1-2008/NQA-la-2009 Subpart 2.1 as endorsed by RG 1.28, Revision 4.

1.38 (R2, May 1977) W', N45.2.2 (1972) 1.28 (R4, June 2010) NQA-1-2008/NQA-la- PVNGS will not maintain commitment to RG 1.38.

Quality Assurance Requirements 2009 Subpart 2.2 for Packaging, Shipping, PVNGS will commit to RG 1.28 (R4, June 2010).

Receiving, Storage Operations Table A-3 of RG 1.28 Revision 4 provides a cross-and Handling of Items for Water- reference between previous regulatory guides, the Cooled Phase Nuclear Power related ANSI Standards, and location in NQA-1.

Plants The cross-reference for RG 1.38 and ANSI N45.2.2

___________ ___________________is__NQA-__1-2008iNQAs-NQA1-2a-2N009a- Subprt22.

Sub Notes: W=Withdrawn RG; W' = Withdrawn RG after Issuance of RG 1.28, Revision 4, June 2010 Pg Page 2

ATTACHMENT 4 Comparison of Existing NRC Regulatory Guide Commitments to New NRC Regulatory Guide Commitments Aadopted in the proposed QAPD Basis PVNGS will not maintain commitment to 1 .37 iIXL, O3I)LVIIIUUI 171 /]J VV, NQA- 1-2008/NQ Housekeeping Requirements for 2009 Subpart 2.3 Regulatory Guide 1.39.

Water-Cooled Nuclear Power Plants PVNGS will commit to Regulatory Guide 1.28, Revision 4, June 2010. RG 1.28 Revision 4 endorses NQA-l1-2008/NQA-l1a-2009. Table A-3 of RG 1.28 Revision 4 provides a cross-reference between previous regulatory guides, the related ANSI Standards, and location in NQA-1.

The cross-reference for RG 1.39 and ANSI N45.2.3 is NQA-l1-2008/NQA-I1a-2009 Subpart 2.3.

1.54 (R0, June 1973), Quality 101.4 (1972) [NO CHANGE] [NO CHANGE] PVNGS will maintain existing commitments to Assurance Requirements for Regulatory Guide 1.54, Revision 0, June 1973.

Protective Coatings Applied to Water-Cooled Nuclear Power Plants ________________________

1.58 (RI, September 1980) W, N45.2.6 (1978) 1.28 (R4, June 2010) NQA-l-2008iNQA-la- PVNGS will not maintain commitment to Qualification of Nuclear Power 2009 Part I Regulatory Guide G 1.58.

Plant Inspection, Examination [Requirement 2, as and Testing Personnel modified by NRC- PVNGS will commit to RG 1.28, Revision 4, June endorsed alternatives for 2010. RG 1.28 Revision 4 endorses NQA-1I-the operational phase as 2008/NQA-la-2009. Table A-3 of RG 1.28 described in NEI 11 -04A, Revision 4 provides a cross-reference between Part II, Section 2.] previous regulatory guides, the related ANSI Standards, and location in NQA-I. The cross-reference for RG 1.58 and ANSI N45.2.6 is NQA-1-2008/NQA-1la-2009, Part I [Requirement 2].

1.64 (R2, June 1976) W, N45.2.1 1(1974) 1.28 (R4, June 2010) NQA-1-2008/NQA-la- PVNGS will not maintain commitment to Quality Assurance Requirements 2009 Part I Regulatory Guide 1.64.

for the Design of Nuclear Power [Requirement 3]

Plants PVNGS will commit to RG 1.28, Revision 4, June 2010. RG 1.28 Revision 4 endorses NQA 2008/NQA-la-2009. Table A-3 of RG 1,28

_____________________Revision 4 provides a cross-reference between Notes: W=Withdrawn RG, Wz = Withdrawn RG after Issuance of RG 1.28, Revision 4, June 2010 Pg Page 3

ATTACHMENT 4 Comparison of Existing NRC Regulatory Guide Commitments to New NRC Regulatory Guide Commitments Aadopted in the proposed QAPD Basis previous regulatory guides, the related ANSI Standards, and location in NQA-I1. The cross-reference for RG 1.64 and ANSI N45.2.11 is NQA-1-2008/N0A-Ila-2009 Part I rRequirement 31.

1.74 (R0, February 1974), N45.2.10 (1973) 1.28 (R4, June 2010) NQA-1-2008/NQA-Ila- PVNGS will not maintain commitment to Quality Assurance Terms and 2009 and NEI 11-04, Part Regulatory Guide 1.74. PVNGS will commit to Definitions V, Section 1 RG 1.28, Revision 4, June 2010 and the Quality Assurance terms and definitions provided in NQA-I1-2008/NQA-I a-2009. Additional definitions applicable to the operational phase are adopted via

____________NEI 11 -04A, Part V, Section 1.

1.88 (R2, October 1976) W, N45.2.9 (1974) 1.28 (R4, June 2010) NQA-1-2008iNQA-la- PVNGS will not maintain commitment to Collection, Storage and 2009 Part I Regulatory Guide 1.88.

Maintenance of Nuclear Power [Requirement 17]

Plant Quality Assurance Records PVNGS will commit to RG 1.28, Revision 4, June 2010. RG 1.28 Revision 4 endorses NQA 2008/NQA-la-2009. Table A-3 of RG 1.28 Revision 4 provides a cross-reference between previous regulatory guides, the related ANSI Standards, and location in NQA-I. The cross-reference for RG 1.88 and ANSI N45.2.9 is NQA-1-2008/NQA-lIa-2009, Part I [Requirement 17].

[1.94 (RI, April 1976) W', N45.2.5 (1974) [NO CHANGE] [NO CHANGE] PVNGS will maintain existing commitments to Quality Assurance Requirements Regulatory Guide 1.94 in lieu of adopting Subpart for Installation, Inspection, and 2.5 ofNQA-1-2008/NQA-Ia-2009. PVNGS was Testing of Structural Concrete designed and constructed to Regulatory Guide 1.94, and Structural Steel during the Revision 1, April 1976. NQA-1-2008iNQA-I a-Construction Phase of Nuclear 2009 Subpart 2.5 is intended for new construction Power Plants and would cause significant re-analysis and backfit of designs for PVNGS, which is not practical or necessary at the current stage of the operational phase.

Notes: W=Withdrawn RG; W' = Withdrawn RG after Issuance of RG 1.28, Revision 4, June 2010 Pg Page 4

ATTACHMENT 4 Comparison of Existing NRC Regulatory Guide Commitments to New NRC Regulatory Guide Commitments Aadopted in the proposed QAPD Basis PVNGS will not maintain commitment to Quality Assurance Requirements 2009, Part II, Subpart 2.8. Regulatory Guide 1.116.

for Installation, Inspection, and Testing of Mechanical Equipment PVNGS will commit to RG 1.28, Revision 4, June and Systems 2010. RG 1.28 Revision 4 endorses NQA 2008/NQA-1la-2009.Table A-3 of RG 1.28 Revision 4 provides a cross-reference between previous regulatory guides, the related ANSI Standards, and location in NQA-1. The cross-reference for RG 1.116 and ANSI N45.2.8 is NQA-1-2008iNQA-I1a-2009, Subpart 2.8.

1.123 (Ri, July 1977) W, N45.2. 13 (1976) 1.28 (R4, June 2010) NQA-1t-2008/NQA-1 a- PVNGS will not maintain commitment to Quality Assurance Requirements 2009 Part I Regulatory Guide 1.123.

for Control of Procurement of [Requirements 4 and 7]

Items and Services for Nuclear PVNGS will commit to RG 1.28, Revision 4, June Power Plants 2010. RG 1.28 Revision 4 endorses NQA-I-2008/NQA-la-2009. Table A-3 of RG 1.28 Revision 4 provides a cross-reference between previous regulatory guides, the related ANSI Standards, and location in NQA-1I. The cross-reference for RG 1.123 and ANSI N45.2.13 is NQA-I-2008/NQA-1la-2009 Part I [Requirements 4

_________________and 7].

1.143 (RO, July 1978), N199 (1976) [NO CHANGE] [NO CHANGE] PVNGS will maintain existing commitments to Design Guidance for Radioactive Regulatory Guide 1.143.

Waste Management Systems, Structures, and Components Installed in Light-Water-Cooled Nuclear Power Plants 1.144 (RI, September 1980) W, N45.2.12 (1977) 1.28 (R4, June 2010) NQA-1-2008/NQA-la- PVNGS will not maintain commitment to Auditing of Quality Assurance 2009 Part I Regulatory Guide 1.144.

Programs for Nuclear Power [Requirement 18]

Plants PVNGS will commit to RG 1.28, Revision 4, June

___________ ____________________ _2010.___RG__1.2_82010vRGi128 Reision4rendrses AQA--

Notes: W=Withdrawn RG; W' = Withdrawn RG after Issuance of RG 1.28, Revision 4, June 2010 Pg Page 5

ATTACHMENT 4 Comparison of Existing NRC Regulatory Guide Commitments to New NRC Regulatory Guide Commitments Aadopted in the proposed QAPD Basis 2008/NQA-la-2009. Table A-3 of RG 1.28 Revision 4 provides a cross-reference between previous regulatory guides, the related ANSI Standards, and location in NQA- 1. The cross-reference for RG 1.144 and ANSI N45.2.12 is NQA- 1-2008/NQA-l1a-2009, Part I [Requirement 18].

1.146 (R0, August 1980) W, N45.2.23 (1978) 1.28 (R4, June 2010) NQA-1-2008iNQA-Ila- PVNGS will not maintain commitment to Qualification of Quality 2009 Part I Regulatory Guide 1.146.

Assurance Program Audit [Requirement 2]

Personnel for Nuclear Power PVNGS will commit to RG 1.28, Revision 4, June Plants 2010. RG 1.28 Revision 4 endorses NQA 2008/NQA-Ia-2009. Table A-3 of RG 1.28 Revision 4 provides a cross-reference between previous regulatory guides, the related ANSI Standards, and location in NQA-I1. The cross-reference for RG 1.146 and ANSI N45.2.23 is NQA- 1-2008/NQA-l1a-2009, Part I [Requirement 2].

Appendix A to BTP APCSB 9.5- N/A [NO CHANGE] N/A PVNGS will maintain existing commitments to 1, Guidelines for Fire Protection Appendix A of NRC Branch Technical Position for Nuclear Power Plants APCSB 9.5-I in lieu of adopting NRC RG 1.189 as described in NEI 1 1-04A, Part IV.

4.1 (RI, April 1975), N/A [NO CHANGE] N/A PVNGS will maintain existing commitments to Programs for Monitoring Regulatory Guide 4.1 as described in UJFSAR 1.8.

Radioactivity in the Environs Audits of the of Nuclear Power The reference to RG 4.1 in the current PVNGS QA Plants (1/73) Program, UFSAR 17.2, Appendix B, was intended to identify' that QA program elements discussed in Regulatory Guide 4.1 are independently audited by the PVNGS Nuclear Assurance organization.

Notes: W=Withdrawn RG; Wi = Withdrawn RG after Issuance of RG 1.28, Revision 4, June 2010 Pg Page 6

ATTACHMENT 5 Specific Deviations from the NEI 11-04A Template and the Basis for the Deviations (12 Pages follow)

ATTACHMENT 5 Specific Deviations from the NEI ll-04A Template and the Basis for the Deviations r*irsi raragrapn, *een~ce:

i nirnaQAPD iut.ArK~L uocs not appiy to mecr vINU~ uperauonai ytir. t2IX r-arn 1, :,ectlon 1 -

General Changed1,sentence

ecnion to read "The describes the methods and requirements described in 10 CFR 71, Subpart H, and 10 CFR 72, establishes quality assurance (QA) and administrative control Subpart G, are within the scope of the PVNGS QAP.

requirements that meet 10 CFR 50, Appendix B, 10 CFR 71, Subpart H, and 10 CFR 72. Subpart G."

Changed1.1, Section sentence read "The Last SecondtoParagraph, QAPDSentence:

may be applied to certain j10CFR52 does not apply to the PVNGS Operational QAP. QA requirements described in 10 CFR 71, Subpart H, and 10 CFR 72, activities where regulations other than 10 CFR 50, Appendix B, 10 Subpart G, are within the scope of the PVNGS QAP.

CFR 71, Subpart H, and 10 CFR 72, Subpart G, establish QA requirements for activities within their scope."_______________________________

Section 1.1, Third Paragraph, First Sentence: Editorial. PVNGS is a nuclear generating station and the QAP Changed "plant" to "generating station". extends beyond the power plant itself (e.g. Independent Spent Fuel Storage Facility).

Part 11, Section 1 - 17.2.1 2.1.5.3 Section 1.9: PVNGS adopted the option from NEI 11 -04A Part 11, Section 2 Organization 13.1.1 Changed sentence to read "For the operational phase, independence which allows inspection to be performed by the same 13.1.2 shall be maintained between the organization(s) performing the organization. Therefore, this sentence needed to be altered to checking (quality assurance and quality control) functions and the reflect this option or otherwise the two sections would have been organizations performing the functions to the extent described in the in conflict.

specific sections of this QAPD."

Part II, Section 2 - 17.2.2 2.2 Section 2, First Paragraph, Second Sentence: PVNGS is considered a facility, not multiple plants at various sites Quality Assurance Replace "plant" with "facility." and the QAP extends beyond the power plant itself (e.g.

Program _______________________________Independent Spent Fuel Storage Facility).

Section 2, First Paragraph, Third Sentence: QA requirements described in 10 CFR 71, Subpart H, and 10 CFR Changed sentence to read" Further, PVNGS ensures through the 72, Subpart G, are within the scope of the PVNGS QAP.

systematic process described herein, that its suppliers of safety-related equipment or services meet the applicable requirements of 10 CFR Part 50, Appendix B, 10 CFR 71, Subpart H, 10 CFR 72, Subpart G, and 10 CFR Part 21, as applicable to their activities."

Section 2, Second Paragraph, First Sentence: QA requirements related to the PVNGS ISFSI are within the scope Added "including the Independent Spent Fuel Storage Installation of the PVNGS QAP.

(ISFSI) located at the facility,".

Section 2, Second Paragraph, Third Sentence: PVNGS is one nuclear generating station.

Replaced "the appropriate facility" with "PVNGS."____________________________

Section 2, Third Paragraph, Second Sentence: Replaced "qualifies" Editorial.

with "qualify".

Section 2, Fourth Paragraph: Removed all "principal contractor" Does not apply to PVNGS. PVNGS is no longer in the wording, construction or initial start-up phases.

Page I 1

ATTACHMENT 5 Specific Deviations from the NEI 11-04A Template and the Basis for the Deviations 4QAP ...... ::,* 2,* Deviations from EJ 11-04Basis

for Deviations froni- NE 11-04., , ,

sectioif Secio Section 2, Last Paragraph, Second Sentence: Replaced "general" Editorial.

with "grace".

Deleted Section 2.3 This does not apply to an Operations only QAP.

Section 2.4: The wording was changed to clarify that "those organizations" implies "organizations other than APS" to which APS has Changed paragraph to read "Management of those organizations delegated responsibility. The reason for the change (clarification) other than APS implementing the PVNGS QA program, or portions is that 10 CFR 50, Appendix B, Criterion 2, discusses the thereof, shall assess the adequacy of that part of the program for requirement in terms of "The applicant" ("licensee" or "APS") and which they are responsible to assure its effective implementation at further states: "Management of other organizations shall regularly least once every two years or at least once during the life of the review the status and adequacy of that part ofthe quality assurance activity, whichever is shorter." program which they are executing."

Section 2.4: Assessment of QA Programs is reflected in Part II, Section 18.

Removed "However, the period for assessing QA programs during This change eliminates a potential conflict with extended the operational phase may be extended to once every two years." frequencies specified for the operational phase as discussed in NEI 11-04A Part II, Section 18.

Section 2.5, First Paragraph: This statement does not apply to PVNGS as we are not seeking Removed sentence "This document shall be revised as appropriate to license under 10 CFR 52 (ESP and COL). Applicable NRC incorporate additional QA commitments that may be established regulations 10 CFR 50.7 1(e) and 10 CFR 50.54(a) will apply during the [ESP and COL] application development process." regarding the updating of the PVNGS UFSAR and QAPD content.

Section 2.5, First Paragraph: This would allow revisions to the QAPD to be approved by the Added "or Senior Vice President Regulatory & Oversight" at the end Senior Vice President, Regulatory and Oversight.

of last sentence.

Section 2.7: This modification is made to allow use of either the levels of Modified the NEI 11-04A template alternative to NQA-1-2008, qualification per NQA-1-2008 or the alternative provided in the Requirement 2, Section 302, Inspection and Test, to use the term NEI template. Original wording provided by the template "may" instead of "does" regarding implementation of the template alternative implies only the template alternative will be alternative for qualifying inspection and test personnel, implemented instead of allowing use of both methods.

Section 2.7: This alternative was previously approved by NRC Safety Added exception which reads "As an alternative to Section 303.3 Evaluation Report dated March 27, 1998, for the San Onofre that prospective Lead Auditors have participated in a minimum of Nuclear Generating Station. (Reference TAC Nos. MA1002, five (5) audits in the previous three (3) years the following may be MA098 I, and MA0982.) This alternative was adopted by PVNGS used for qualification of experienced individuals: Prospective lead and incorporated into the PVNGS QA Program Description in auditors shall demonstrate their ability to effectively implement the November 2000 under the provisions of 10 CFR 50.54(a)(3)(ii),

audit process and lead an audit team. They shall have participated in which states, in part: ". .. In addition to quality assurance program at least one audit within the year preceding the individual's effective changes involving administrative improvements and clarifications, date of qualification. Upon successful demonstration of the ability to spelling corrections, punctuation, or editorial items, the following

_____________________________________ effectively lead audits, licensee management may designate a changes are not considered to be reductions in commitment:...

Page I 2

ATTACHMENT 5 Specific Deviations from the NET ll-04A Template and the Basis for the Deviations C.rrent New ...... .. 9* ..

NEI1-0 PVNS* ; QAPD Deviations ~r~om NET: 110 Basis for: Deviations from NET 1:1-04 prospective lead auditor as a "lead auditor.'"" (ii) The use of a quality assurance alternative or exception approved by an NRC safety evaluation, provided that the bases of the NRC approval are applicable to the licensee's facility;..."

Part II, Section 3 - 17.2.3.2 2.3 Section 3.1 Design Verification, First Paragraph, Second Sentence: Editorial. Design changes are subject to design controls for Design Control Changed "these" to "design". clarity. Use of term "these" in this context could be confusing.

Section 3.1 Design Verification, Second Paragraph, First Sentence: Generalized to "design" versus "original design." Designs change Removed "original" from sentence. over the life of the facility. "Original" used in this context may be misinterpreted to mean design created prior to or during initial construction.

Section 3.2 Design Records, Second Paragraph, First Sentence: A broad scope of PVNGS configuration documents reflects the Changed sentence to read "Plant configuration documents reflect the properly reviewed and approved design of the plant. The approved properly reviewed and approved design of the plant." design in general precedes documentation of plant configuration.

Section 3.4 Setpoint Control, First Bullet: Editorial. Statement applies to any setpoint information supplied.

Removed "originally". PVNGS is in the operational phase, and term "Originally" may be a source of confusion in this context.

Section 3.5 NQA-l1 Commitment: Editorial. "NQA-l1-2008 and NQA-l1a-2009 Addenda" was repeated in the sentence.

Reworded sentence to read "In establishing its program for design control and verification, PVNGS commits to compliance with NQA-1-2008 and NQA-Ia-2009 Addenda, Requirement 3, Subpart 2.7 for computer software, and Subpart 2.14 for Quality Assurance requirements for commercial grade items and services."

Part II, Section 4 - 17.2.3.3 2.4 Section 4, Second Bullet, Last Sentence: QA requirements of 10 CFR 71, Subpart H, and 10 CFR 72, Procurement Document Subpart G, are within the scope of the PVNGS QAP.

Control Added "1 0 CFR 71 Subpart H, or 10 CFR 72 Subpart G,". __________________________

Part II, Section 5 - 17.2.6.2 2.5 No deviations from template. N/A Instructions, Procedures, and Drawings _____________________________

Part II, Section 6 - 17.2.6.3 2.6 Section 6, First Paragraph, Fourth Bullet: Editorial. This editorial change was made to identify "authorized Document Control personnel" versus "individuals" for consistency.

Replaced "individuals" with "authorized personnel".

Section 6, Third Paragraph, Section 6.1, Second Paragraph, First Editorial. The entire QAPD scope is an operational phase QAP Sentence, Section 6.1, Third Paragraph, First Sentence, and Section only.

6.2, Third Sentence: Deleted "during the operational phase"._______________________________

Section 6.1, First Paragraph, Last Sentence: Editorial.

Changed sentence to read "The documented review(s) signify concurrence."

Page I 3

ATTACHMENT 5 Specific Deviations from the NEI ll-04A Template and the Basis for the Deviations NETv11-04 PVNG QA)PDi* ,: ;:::i ::Deviations from NEJ i1-0)4i: iiBasis for Deviations from NEI 1[1-04: &

Part II, Section 7 - 17.2.3.3 2.7 Section 7.2, First Paragraph, First Sentence: NQA-la-2009 superseded NQA-I-2008 on this topic.

Control of Purchased Material, Equipment, and Deleted "NQA-1-2008 and".

Services Section 7.2, First Paragraph, First Bullet: PVNGS is one nuclear generating station including other nuclear facilities (such as the Independent Spent Fuel Storage Installation),

Deleted " the plants" and replaced with "P VNGS". which is also covered by this QAPD.

Section 7.2, First Paragraph, Second Bullet, First Sub-bullet: Editorial. To identify more than one of each of these items may be needed to procure the services.

Pluralized "document", "certificate", "report", and "standard'.

Section 7.2, First Paragraph, Third Bullet, Second Sentence: Construction phase is complete for the currently licensed activities at PVNGS.

Deleted "Following completion of the construction period, sufficient as-built documentation will be turned over to [CA] to support operations".

Part II, Section 8 - 17.2.3.4 2.8 No deviations from template. N/A Identification and Control of Materials, Parts, and Components Part II, Section 9 - 17.2.3.5 2.9 No deviations from template. N/A Control of Special Processes Part II, Section 10 - 17.2.2.4, 2.10 Section 10.1, First Paragraph, Second Numbered Bullet: "PVNGS" encompasses the scope intended in this sentence.

Inspection 17.2.4.2 Replaced " a [CA] facility" with "P VNGS" Section 10.1, First Paragraph, Fourth Numbered Bullet: "P VNGS" encompasses the scope intended in this sentence.

Replaced " a facility" with "P VNGS" Section 10.3, First Paragraph, First Sentence: For accuracy, NQA-la-2009 includes additional content that superseded certain content contained in NQA-1-2008 for Added "and NQA- la-2009,". Requirement 10.

Section 10.3, First Paragraph, First Sentence: Editorial. "Part II" was added to identify Subparts 2.4, 2.5, and 2.8 as content of Part II of the NQA-1 standard.

Added "Part II".

Section 10.3, First Paragraph, First Sentence: PVNGS will maintain current commitments to RG 1.94 in lieu of adopting Subpart 2.5 of NQA-1 -2008/ NQA-la-2009.

Removed reference to Subpart 2.5.

Page I 4

ATTACHMENT 5 Specific Deviations from the NET 11-04A Template and the Basis for the Deviations NET.1. -4.PVNG :QAP *:::; Deviations from NET 11-04 , BaSis for Deviations from NET 11-0 Part II, Section 11 - Test 17.2.3.6 2.1l1 Section I11, Second Paragraph, First Sentence: The SAR is known as the UFSAR during the operational phase at Control PVNGS.

Replaced "SAR" with "UFSAR".

Section 11 : This paragraph does not apply to PVNGS. The Initial start-up Removed second paragraph of NEI 11-04A. phase is complete for PVNGS.

Section 11.1I, First Paragraph, First Sentence: Editorial. The words "and used" is redundant to the beginning part of the sentence where it states "computer software used".

Removed "and used".

Part II, Section 12 - 17.2.3.7 2.12 Section 12.0, First Paragraph, First Sentence: Editorial.

Control of Measuring and Test Equipment Replaced "or" with "for".

Section 12.1I, First Sentence: PVNGS is currently in its operational phase. The scope of the Deleted "For the operational phase of the facilities". QAPD is for the operational phase only.

Section 12.2, First Paragraph, First Sentence: For accuracy, NQA-la-2009 includes additional content that superseded certain content contained in NQA-I-2008 for Added "and NQA-la-2009,". Requirement 12.

Part II, Section 13 - 17.2.3.8 2.13 Section 13.2, First Paragraph, First Sentence: PVNGS is currently in its operational phase. The scope of the Handling, Storage, and QAPD is for the operational phase only.

Shipping Deleted "during the construction and operational phase of the plant".

Section 13.2, First Paragraph, First Sentence: Editorial. "Part II" was added to identify Subparts 2.1I, 2.2, and 2.3 as content of Part II of the NQA-1 standard.

Added "Part II".

Section 13.2, First Paragraph, First Sentence: Editorial. "Part III" was added to identify Subpart 3.2, Appendix 2.1i as content of Part III of the NQA-1 standard.

Added "Part III".

Section 13.2, First Bullet, Second Bullet, and Third Bullet: Editorial. "Part II" was added to identify Subparts 2.1, 2.2, and 2.3 as content of Part II of the NQA-1 standard.

Added "Part II".

Section 13.2, Third Bullet, Last Sentence: Editorial. PVNGS is located at one site and is comprised of all nuclear facilities on site within the scope of the QAPD.

Replaced "of the applicable plant" with "established for PVNGS".

Section 13.2, NQA-la-2009, Part II, Subpart 2.2 Editorial. Corrected incorrect NQA-1 section reference in the NEI 1 1-04A template.

Changed first bullet reference from "Section 201" to "Section 202" Page 5

ATTACHMENT 5 Specific Deviations from the NEI 11-04A Template and the Basis for the Deviations

____________Section: : :;

Section 13.2, Fourth Bullet referencing Subpart 2.3: NQA-1la-2009 reference added for accuracy.

Change would allow either the method specified in NQA-1 or the Added "and NQA- I a-2009" to the section header for Subpart 2.3. alternative methods to be used, as appropriate, based upon the Changed word "bases" to "may base" related to control over specific work location, work activities, or circumstances at an housekeeping activities, operating nuclear facility.

Section 13.2, Fifth Bullet referencing Subpart 3.2: For accuracy, NQA-1la-2009 superseded NQA-1-2008 for Part III, Subpart 3.2.

Changed section heading to "NQA- 1a-20 09".

Part II, Section 14 - 17.2.3.9 2.14 Section 14, Second Paragraph, First Sentence: PVNGS also performs temporary modification work and related Inspection, Test and verifications in accordance with controlled work instructions.

Operating Status Added "or work instructions" in sentence.

Part II, Section 15 - 17.2.2.10, 2.15 Section 15.2, First Bullet: There are instances when marking or tagging on either the item, Nonconforming 17.2.5 the container, or the package containing the item is not practical.

Materials, Parts, or Added clarification "For Section 200, Identification, PVNGS Components considers other means of identification acceptable when marking or tagging on either the item, the container, or the package containing the item is not practical."

Part II, Section 16 - 17.2.2.10, 2.16 No deviations from template. N/A Corrective Action 17.2.5 Part II, Section 17 - 17.2.6.4 2.17 Section 17, First Paragraph, First Sentence: Editorial. Added for consistency with other sections of the NEI Quality Assurance 11 -04A template and the PVNGS QAPD.

Records Added "established".

Section 17.1, Third Sentence: Two separate statements were placed in this section to differentiate between record retention requirements for initial Added "For design, construlction, and initial start-up activities, the design, construction, and start-up activities versus the revised records to be maintained and their retention times are based on requirements for ongoing operational phase record maintenance previous PVNGS commitments to Regulatory Guide 1.28, Revision activities.

0, and Regulatory Guide 1.88, Revision 2."

Section 17.1I, Fourth Sentence: Two separate statements were placed in this section to differentiate between historical record retention requirements for Added "For operational phase activities, records to be maintained initial design, construction, and start-up activities versus the and their retention times are based on PVNGS commitment to revised requirements for ongoing operational phase activities.

Regulatory Guide 1.28, Revision 4, and the list of typical lifetime records provided in NQA-1-2008, Part III, Nonmandatory Appendix 17A-1, Section 200."

Section 17.2, Second Sentence: Current PVNGS electronic QA records storage practices are more closely reflected in the updated 2011 NIRMA guidelines, which Changed sentence to read "PVNGS will manage the storage of QA were not available at the time RIS 2000-18 was issued by the Records in electronic media consistent with the intent of RIS 2000- NRC.

Page 16

ATTACHMENT 5 Specific Deviations from the NET ll-04A Template and the Basis for the Deviations 18 and associated NlRMA Guidelines TG 11-2011, TG 15 -2011, TGI6-2011, and TG21-2011I."

Section 17.3: Current PVNGS electronic QA records storage practices are more closely reflected in the updated 2011 NIRMA guidelines, which Added exception "In establishing the provisions for managing were not available at the time RIS 2000-18 was issued by the electronic records, PVNGS commits to comply with Regulatory NRC.

Guide 1.28, Revision 4, position C.1.b(2) with the following clarification:

In lieu of adopting NIRMA Guidelines TG1-1-I998, TG15-1998, TG16-1998, and TG21-1998, PVNGS adopts TG11-2011, TG15-2011, TG16-2011I, and TG21-2011."

0 Part 11, Section 18 - 17.2.2.4, 2.18 Section 18.1, First Paragraph: PVNGS is currently in its operational phase not the nuclear Audits 17.2.4.4 development phase, therefore the statement is not applicable to Removed "During the early portions of [Nuclear Development] PVNGS.

activities, audits will focus on areas including, but not limited to,

[site investigation], procurement, and corrective action."

Section 18.1, Third Paragraph: PVNGS determines the adequacy of programs and procedures via audits; however, "representative sampling" may or may not be Removed "(by representative sampling),", used to determine adequacy of programs and procedures in audits.

Section 18.2, First Paragraph (original template): PVNGS is currently in its operational phase. The statement removed is not applicable to PVNGS.

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

Section 18.2, First Paragraph, First sentence: Editorial. Restructured sentence to reflect an operating facility.

Incorporated major elements of the NEI template Section 18.2 Restructured sentence to read "Internal audits of operational fourth paragraph into the first paragraph to eliminate redundancy.

activities are performed at a frequency commensurate with the safety significance and in such a manner as to assure that an audit of all applicable QA program elements is completed for each functional area within a period of two years."____________________________

Section 18.2, First Paragraph, Second Sentence: PVNGS is currently in its Operational phase. The QAPD is an operational phase QAPD only.

Removed ", conducted after placing the facility in operation,".

Page 17

ATTACHMENT 5 Specific Deviations from the NEI ll-04A Template and the Basis for the Deviations NEL 1-0 ~ ~APDDevatios foml Ei04 Basls~foi.D~evations from ~NEIV1PO-4 :...

etinSection 18.2, First Paragraph, Last Sentence: This sentence was reworded to reflect the perceived intent of the paragraph. The paragraph discusses "a detailed performance Reworded sentence to read "If performance dictates, the extension of analysis" which would provide input into determining frequencies the internal audit frequency interval for the applicable functional area of audits. This "performance analysis" should dictate that "the should be rescinded and an audit scheduled as soon as practicable." extension of the internal audit frequency interval for the applicable functional area should he rescinded and an audit scheduled as soon as practicable" as the rest of the sentence reads. Hence the reference to "If performance dictates" is used to reflect the "performance analysis."

Section 18.2, Second Paragraph, First Sentence: PVNGS is currently in its Operational phase. The QAPD is an operational phase QAPD only.

Added "of operational phase activities".

Section 18.2, Third Paragraph (Original Template): The major elements of this sentence were incorporated into the first sentence of the first paragraph because they were redundant Removed "During the operational phase audits are performed at a and created a potential conflict with extended frequencies frequency commensurate with the safety significance of the activities permitted during the operational phase as described later in the and in such a manner to assure audits of all applicable QA program paragraph.

elements are completed within a period of two years."

Section 18.2, Last Paragraph (Original Template): Editorial. This paragraph seemed more appropriate after the first paragraph in Section 18.2.

Relocated paragraph stating "Internal audits of operational phase activities include verification of compliance and effectiveness of the administrative controls established for implementing the requirements of the QAPD; regulations and license provisions; provisions for training, retraining, qualification, and performance of personnel performing activities covered by the QAPD; corrective actions taken following abnormal occurrences; and, observation of the performance of fabrication, operating, refueling, maintenance, and modification activities including associated record keeping."

Part III, Section 1 - 17.2.2.2, 3.1 No deviations from template. NIA Nonsafety-Related SSCs 17.2.2.8,

- Significant 17.2F Contributors to Plant Safety Page I8

ATTACHMENT 5 Specific Deviations from the NEI 11-04A Template and the Basis for the Deviations NET.11- .. PVNS A. Deiaios romNE 1-0 Bas~is Ifor. Dewiations :from NEI: 1-04~

Part III, Section 2 - 17.2.2.2, 3.2 Section 2, First Bullet: PVNGS does not intend to adopt RG 1.189 as a part of this QAPD Nonsafety-Related SSCs 17.2.2.8, change. PVNGS will maintain existing commitments to Section C Credited for Regulatory 17.2F Reworded bullet to read "PVNGS implements quality requirements of Appendix A of Branch Technical Position 9.5-1.

Events for the fire protection system in accordance with Section C to Appendix A of Branch Technical Position 9.5-1. Implementation is

_________described in UFSAR 9B.3.1."

Part IV, Regulatory 1.8, 4.0 No deviations from template. PVNGS will maintain existing commitments to Regulatory Guide Guide 1.8 [Rev. 3, May 17.2B 1.8 consistent with the Units 1,2, and 3 Technical Specifications.

2000] ________________________________

Part IV, Regulatory 1.8, 4.0 No deviations from template. PVNGS will maintain existing commitments to Regulatory Guide Guide 1.26 [Rev. 4, 17.2B 1.26, Revision 1, September 1974.

March 2007]

Part IV, Regulatory 1.8, 4.0 Removed "[CA] identifies conformance and exceptions for the PVNGS will commit to Regulatory Guide 1.28, Revision 4, June Guide 1.28 [Rev. 4, June 17.2B applicable regulatory position guidance provided in this regulatory 2010 which adopts NQA-1-2008 and NQA-la-2009 Addenda.

2010] guide in [state location, e.g. FSAR Chapter 1.]" and added Specific clarifications and exceptions are identified at the pertinent "Regulatory Guide 1.28, Revision 4, conditionally endorses NQA-I- sections of the revised PVNGS Operations Quality Assurance 2008 and NQA-1la-2009 Addenda as the basis for the quality Program Description.

assurance program."

Part IV, Regulatory 1.8, 4.0 No deviations from template. PVNGS will maintain existing commitments to Regulatory Guide Guide 1.29 [Rev. 4, 17.2B 1.29, Revision 3, September 1978.

March 2007]

Part IV, Regulatory 1.8, 17.2.4 Replaced "[CA] identifies conformance and exceptions for the PVNGS is currently committed to RG 1.33, Revision 2, February Guide 1.33 [Rev. 2, 17.2B applicable regulatory position guidance provided in this regulatory 1978, which conditionally endorses ANSI N18.7-1976 (ANS.32).

February 1978] guide in [state location, e.g. FSAR Chapter 1.]" with "Regulatory Guide 1.33, Revision 2, conditionally endorses ANSI N18.7-1976 as PVNGS will modify existing commitment to Regulatory Guide providing acceptable methods for satisfying NRC regulations for 1.33, Revision 2, by adopting Regulatory Guide 1.28, Revision 4, operations phase quality assurance." NQA- 1-2008/NQA-l a-2009, and additional administrative controls for operational phase activities as described in NEI 11-Also added paragraph stating "In lieu of adopting ANSI N 18.7-1976, 04A, Revision 0.

PVNGS adopts the guidance of NEI 11 -04A, Revision 0, in conjunction with commitment to Regulatory Guide 1.28, Revision 4, which conditionally endorses NQA-1-2008 with NQA-la-2009 Addenda. Adopting a quality assurance program consistent with the guidance of NEI 11l-04A Revision 0 has been determined by NRC Safety Evaluation Report dated May 9, 2013, to be an acceptable alternative to adopting the guidance of ANSI N18.7-1976. Specific PVNGS exceptions and clarifications to the guidance ofNEI 11-04A Revision 0, Regulatory Guide 1.28 Revision 4, and NQA-1-2008 Page I 9

ATTACHMENT 5 Specific Deviations from the NEI 11-04A Template and the Basis for the Deviations

.. . ... : " C.urrent..

u ie t NNew..

W : ' ; . ... .. : *... .. . ....... . . .. ; : * - * ..

PVNGEIIL0T:***.3 S* : Q:J Devitios.fom ET 1-0 Basis for Devlations.. from NEI 11-04*...

with NQA-1la-2009 Addenda, are as described in the pertinent sections of the PVNGS Operations Quality Assurance Program Description."

Part IV, Regulatory 1.8, 4.0 Added "In lieu of adopting Regulatory Guide 1.37, Revision 1, PVNGS is currently committed to RG 1.37, Revision 0, March 16, Guide 1.37 [Rev. 1, 17.2B3 PVNGS adopts Regulatory Guide 1.28, Revision 4, and the guidance 1973.

March 2007] of NQA-1-2008 with NQA-1la-2009 Addenda, as modified by NEI l1-04A, Revision 0. Conformance to NQA-l-2008 with NQA-la- PVNGS will commit to the revision of RG 1.37 endorsed in NEI 2009 Addenda, including any exceptions or clarifications, is as11-04A, hut in lieu of adopting ASME NQA-l-1994, Part LI, described in the pertinent sections of the PVNGS Operations Quality Subpart 2.1 per RG 1.37 Revision 1, March 2007, PVNGS will Assurance Program Description." adopt NQA-l-2008/NQA-la-2009 Subpart 2.1 as endorsed by Regulatory Guide 1.28, Revision 4.

Part IV, Regulatory 1.8, 4.0 No deviations from template. PVNGS will maintain existing commitments to Regulatory Guide Guide 1.54 [Rev. 2, 17.2B 1.54, Revision 0, June 1973.

October 2010]

Part IV, Regulatory 1.8, 4.0 Added existing PVNGS commitment to Regulatory Guide .194 as PVNGS will maintain existing commitments to NRC Regulatory Guide 1.94 [Rev. 1, April 17.2B follows: Guide 1.94 in lieu of adopting Subpart 2.5 ofNQA-1-2008 /

1976] "Regulatory Guide 1.94, Revision 1, April 1976 - Installation, NQA-la-2009. The current PVNGS civil specifications meet the Inspection, and Testing of Structural Concrete and Structural Steel current licensing basis commitment to Regulatory Guide 1.94, during the Construction Phase of Nuclear Power Plants Revision 1. NQA-1-2008/NQA-la-2009 Subpart 2.5 is intended For operations phase activities that are comparable to activities for new construction and would require extensive changes to during the construction phase, the position of Regulatory Guide 1.94, existing implementation for an operating facility.

Revision 1, is accepted."

Part IV, ASME NQA-l- 1.8, 4.0 Reworded paragraph to read "ASME NQA-1-2008 Edition with PVNGS commits to NQA-1-2008 with NQA-la-2009 Addenda 2008 Edition with NQA- 17.2B NQA-la-2009 Addenda - Quality Assurance Requirements for with exceptions and clarifications as described in the pertinent 1la-2009 Addenda (ANSI Nuclear Facility Applications Regulatory Guide 1.28, Revision 4, sections of the revised PVNGS Operations Quality Assurance N45.2 and and NQA-1-2008 with NQA-1la-2009 Addenda have been adapted Program Description.

N18.7) for use during the operational phase as provided for in NEI 1 1-04A, Revision 0, and its supporting NRC Safety Evaluation Report. For the operational phase, PVNGS adopts Regulatory Guide 1.28, Revision 4, and NQA-l1-2008 with NQA-l1a-2009 Addenda consistent with the guidance of NEI 11-04A, Revision 0. Exceptions and clarifications are as described in the pertinent sections of the PVNGS Operations Quality Assurance Program Description."

Relocated information under commitment to Regulatory Guide 1.28.

Part IV, Nuclear 1.8 (R.G. 4.0 Reworded paragraph to read "Nuclear Information and Records PVNGS commits to the later versions of the referenced NIRMA Information and Records 1.88), Management Association, Inc. (NIRMA) Technical Guides (TGs) Guidelines, specifically TG1 1-2011, TG15-2011I, TGI6-201 1, and Management 17.2.6 - Regulatory Guide 1.28, Revision 4, Regulatory Position C.l.(b) TG21-2011.

Page 10

ATTACHMENT 5 Specific Deviations from the NET 1l-04A Template and the Basis for the Deviations Association, Inc. provides guidance on managing records in electronic media and (NIRMA) Technical refers to Regulatory Information Summary (P1S) 2000- 18, Guides (TGs) "Guidance on Managing Quality Assurance Records in Electronic Media," dated October 23, 2000. RIS 2000-18 refers to NIRMA Technical Guides (TGs) as an acceptable method for maintaining records in electronic media. NEI 11-04A, Revision 0, also endorses the use of these NIRMA Technical Guides. PVNGS adopts the 2011 versions of the NIRMA Technical Guides described in NEI I 1-04A Revision 0. Conformance with the NIRIMA Technical Guides, including any exceptions or clarifications, is as described in the pertinent sections of the PVNGS Operations Quality Assurance Program Description." Relocated this information under commitment to Regulatory Guide 1.28.

Part V, Section I1- 17.2C 5.1I No deviations from template. N/A Definitions Part V, Section 2 - 13.4, 5.2 Section 2.2, First Paragraph, First Sentence: PVNGS is currently in its Operational phase.

Review of Activities 17.2.2.9 Deleted "occurring during the operational phase" Affecting Safe Plant Section 2.2, First Paragraph, Second Sentence: PVNGS is currently in its Operational phase.

Operation Deleted "The independent review program shall be functional prior to initial core loading."

Section 2.2, First Paragraph, First Bullet: Editorial.

Added "updated final" in front of "safety analysis report" and added "UP" in front of"SAR" to reflect the PVNGS Updated Final Safety Analysis Report (UFSAR).

Section 2.2, First Paragraph, Second Bullet: Editorial.

Added "UP" in front of"SAR" to reflect the PVNGS Updated Final Safety Analysis Report (UFS AR).

Section 2.2, "Independent Review Body" Section, Second Paragraph, Editorial.

First Bullet:

Added "UF" in front of"SAR" to reflect the PVNGS Updated Final Safety Analysis Report (UFSAR).

Section 2.2, "Independent Review Body" Section, Second Paragraph, Editorial.

Second Bullet:

Added "IJF" in front of "SAR" to reflect the PVNGS Updated Final Safety Analysis Report (UFSAR).

Part V, Section 3 - 13.5 5.3 Section 3.1, First Paragraph, First Sentence: Editorial.

Operational Phase Reworded first part of sentence to read "Procedure format and Procedures content may vary from one location to another, however,".

Page I 11

ATTACHMENT 5 Specific Deviations from the NET 11-04A Template and the Basis for the Deviations NE]I: .1..4 PVN GS:*...... Dev.iations* from :NET 11-04:/: Bass or evatinsfro NT 1-0 Section 3.2, Radiation Control Procedures Section, Title Heading: Editorial. The types of procedures described are known as Renamed "Radiation Control Procedures" to "Radiological "Radiological Protection Procedures" at PVNGS.

Protection Procedures".

Section 3.2, Radiation Control Procedures Section, First Sentence: Editorial. The radiation control program described is known as Replaced "radiation control" with "radiological protection". the "radiological protection" program at PVNGS.

Section 3.2, Radiation Control Procedures Section, Second Sentence: Editorial. The first sentence describes "documents" which contain Replaced "procedures" with "documents". instructions for implementation of the radiation protection program. The second sentence was changed to be consistent with the first sentence.

Section 3.2, Radiation Control Procedures Section, Last Sentence: Radiological Protection Procedures "provide for the control, Removed sentence from "Chemical and Radiochemical Control treatment and management of radioactive wastes, and control of Procedures" Title Heading which states "These documents also radioactive calibration sources."

provide for the control, treatment and management of radioactive wastes, and control of radioactive calibration sources." and placed this sentence into the Title Heading "Radiological Protection Procedures".

Part V, Section 4 - 17.2.3.9 5.4 Section 4, Fourth Paragraph: Modified to be consistent with NEI 11l-04A, Part II, Section 14, Control of Systems and 17.2.3.11 Replaced "Independent verifications" with "Jndependentlconcurrent which includes concurrent verifications as well as independent Equipment in the verifications", verifications for status control activities.

Operational Phase ____________

Part V, Section 5 -Plant 17.2.3.11 5.5 NQA-1-2008 Part II, Subpart 2.18, Section 207 refers to Subpart 2.5 PVNGS will maintain existing commitments to NRC Regulatory Maintenance for inspection. In lieu of using Subpart 2.5, PVNGS performs Guide 1.94 in lieu of adopting Subpart 2.5 ofNQA-1-2008 /

installation inspections for maintenance activities consistent with NQA-1 a-2009. The current PVNGS civil specifications meet the PVNGS commitment to RG 1.94 (R1, April 1976) / ANSI 45.2.5 current licensing basis. NQA-1-2008JNQA-la-2009 Subpart 2.5 is (1974). intended for new construction and would require extensive changes to existing implementation for an operating facility.

Page[ 112

ATTACHMENT 6 Comparison of Current QAPD to Proposed QAPD Based Upon NEI 11l-04A and NQA-1-2008/NQA-la-2009 (28 Pages Follow)

ATTACHMENT 6 Comparison of Current QAPD to Proposed QAPD Based Upon NEI ll-04A and NQA-1-2008/NQA-la-2009

!i * :*+*/

22;*;K~d +*?,Zii*¢

,<* +*+;*:;:*;**/,+.>++*+*::.+;*i*:*>;*;O*%

Current Quality..

. S*2.......... .

8.3.1.4.2 - 8.3.1.4.2 - Administrative Revising sentence that reads "The N Qualified inspection personnel meeting the Administrative Responsibilities and Controls routing is also confirmed by quality requirements of the revised operational phase QA Responsibilities and for Assuring Separation control personnel during installation Program will inspect this activity. This Controls for Assuring Criteria to be consistent with the design administrative change is being made to clarify that Separation Criteria document." The words "quality for the operational phase, the inspection may be control personnel" will be changed performed by properly qualified inspection to "inspection personnel." personnel and not a separate QC organization.

Table 9B.3 Quality Assurance for Fire Revised "PVNGS Position and Basis N Clarifies that implementation of the quality Comparison of Palo Protection is specifically for Noncompliance Items" column assurance program for fire protection is consistent Verde Nuclear addressed by new QAPD 3.2. of Table 9B.3-1 to read "Fire with NRC Branch Technical Position APCSB 9.5-1, Generating Station to protection features required to Appendix A, Section C, "Quality Assurance Appendix A of NRC protect safety-related structures, Program". Specific details for quality classifications Branch Technical systems, and components are within of affected nonsafety-related SSCs and Position APCSB 9.5-1 the scope of the PVNGS Quality implementing details are addressed by station (sheet 13 of 69) C. Assurance Program for the procedures consistent with the guidance ofNI 11-Quality Assurance operational phase. APS implements 04A, Part III.

Program the fire protection QA program through approved station procedures, instructions, and drawings that are controlled per the requirements of the PVNGS Quality Assurance Program for operational phase.

Implementation of the quality assurance program for fire protection is consistent with NRC Branch Technical Position APCSB 9.5-1, Appendix A, Section C, "Quality Assurance Program." Deleted all

_______________________other information in this column.

R = Considered to be a reduction in commitment Page 1 N =Neutral change (considered to be neither a reduction or increase in commitment)

I = Considered to be an increase in commitment

ATTACHMENT 6 Comparison of Current QAPD to Proposed QAIPD Based Upon NEI ll-04A and NQA-1-2008/NQA-la-2009 Assurance Program Revised... LJA or...NEW. ... . RIN/I.. . .. . .. .

Description...(QAPD).Q.PD..Section 'DifferenCes ,- .[*,:*:, :*, Ba sis for Accepabliy Decit Q P ) ' :*QDSection.. *. ... . *. .... .- :,, :*,

13.1 - Organizational QAPD 2.1 - Organization Generally, the organization is more N Adopting functional description of organizational Structure of Applicant functionally described (where relationships, authorities, and responsibilities is not possible) rather than by specific title. considered a reduction in commitment per 10 CFR 50.54(a) (3)(iii) and (iv).

13.1.1.2.2 - Vice QAPD 2.1.9 - Organization The "Vice President, Nuclear N The nuclear engineering organization is more President, Nuclear Engineering" position in the current generically and functionally described, however Engineering QAPD will be known as "Nuclear organizational responsibilities remain the same.

Engineering" in the current QAPD.

13.1.1.2.2.2 - Director, QAPD 2.1.9.1 - Nuclear Fuel The "Director, Nuclear Fuel N The nuclear fuel management organization is more Nuclear Fuel Management Management" in the current QAPD generically and functionally described, however Management will be known as "Nuclear Fuel organizational responsibilities remain the same.

Management" in the new QAPD.

13.1. 1.2.2.1, QAPD 2.1.9.2 - Design, The "Director, Design Engineering," N The nuclear engineering organization is more 13.1.1.2.2.3, Proj ects, and Plant "Director, Plant Engineering," generically and functionally described, however 13.1.1.2.2.4, Engineering "Director, Engineering Programs and organizational responsibilities remain the same. One 13.1.1.2.2.5 Support," and "Director, Project or more management positions within the Nuclear Directors reporting to the Engineering" in current QAPD will Engineering organization may be assigned these Vice President, Nuclear be "Design, Project, and Plant responsibilities.

Engineering Engineering" in the new QAPD.

13.1.1.2.3 - Vice QAPD 2.1.15 - Operations The "Vice President, Operations N The operations support organization is more President, Operations Support Support" in the current QAPD will generically and functionally described, however the Support be known as "Operations Support" in overall operations support organizational the new QAPD. responsibilities remain the same.

13.1.1.2.3.1 - Director, QAPD 2.1.15 The "Director, Nuclear Security N The operations support organization is more Nuclear Security Division" is not specifically generically and functionally described; existing Division described in the revised QAPD. nuclear security functions are described and carried

__________________________out by Operations Support organization.

13.1.1.2.3.2 - Manager, QAPD 2.1.15 The "Manager, Fire Protection" is N The operations support organization is more Fire Protection not specifically described in the generically and functionally described; existing fire revised QAPD. ____protection functions are described and carried out R = Considered to be a reduction in commitment Page 2 N = Neutral change (considered to be neither a reduction or increase in commitment)

I = Considered to be an increase in commitment

ATTACHMENT 6 Comparison of Current QAPD to Proposed QAPD Based Upon NEI 11-04A and NQA-1-2008/NQA-la-2009 Assurance Program :**Revised IJSA or NEW,, : * :,,:, . . , BSsio cetaii * :

SDescription. ..(QAPD). . :*., QAPD ,Section .. . -, : :],: ... " ':... /

.....Differences

* ::': ot)r Basis for!:Acceptabili....... ty : : *:

by Operations Support organization.

13.1.1.2.3.3 - Director, QAPD 2.1.15 The "Director, Supply Chain" is not N The operations support organization is more Supply Chain specifically described in the revised generically and functionally described; existing QA QAPD. functions are described and carried out by Operations Support organization.

13.1.1.2.3.4 - Director QAPD 2.1 .15 The Director, Emergency Planning" N The operations support organization is more Emergency Planning and "Manager, Emergency generically and functionally described; existing 13.1.1.2.3.5 - Manager, Planning" are not specifically emergency planning functions are described and Emergency Planning described in the revised QAPD. carried out by Operations Support organization.

13.1.1.2.3.6 -Manager, QAPD 2.1.15 The "Manager, Support Services" is N The operations support organization is more Support Services not specifically described in the generically and functionally described; existing QA revised QAPD. functions are described and carried out by Operations Support organization.

13.1.1.2.3.7 - Palo QAPD 2.1.15 The "Palo Verde Information N Though there is no specific organization titled "Palo Verde Information Services" group in the current QAPD Verde Information Services" in the revised QAPD, Services is not specifically described in the the organization's QA functions are described and revised QAPD. carried out by the Operations Support organization.

13.1 .1.2.4 - Director, QAPD 2.1.5 - Quality The "PVNGS Nuclear Assurance N The Nuclear Assurances organization is more Nuclear Assurance Assurance Organization" responsibilities in the generically and functionally described. Specific 2.1.5.1 - Quality Assurance current QAPD are simplified and authorities and responsibilities of the Director, Management functionally described in 2.1.5 of the Nuclear Assurance, are described at QAPD 2.1.5.1 revised QAPD as "Quality consistent with the guidance of NEI 1 1-04A,

____________Assurance". Revision 0.

13.1.1.2.4.1 - Nuclear QAPD 2.1.5 - Quality The "PVNGS Nuclear Assurance N The Nuclear Assurances organization is more Assurance Organization Assurance Organization" description is generically and functionally described consistent simplified and more functionally with the guidance of NEI 11l-04A, Revision 0.

described at 2.1.5 "Quality Overall Nuclear Assurance organizational Assurance" in the revised QAPD. responsibilities are the same, except where specific

________________________ _________________hanges__a__enotedchangsoarenoteden othrnsecionshoithistable R = Considered to be a reduction in commitment Page 3 N = Neutral change (considered to be neither a reduction or increase in commitment)

I = Considered to be an increase in commitment

ATTACHMENT 6 Comparison of Current QAPD to Proposed QAPD Based Upon NEI ll-04A and NQA-1-2008/NQA-la-2009 Current,:: uality. : ... * ** Ii '.. ..

Description (QAPD) ii :QPD Section Difernce (o" 1)> Acceptabili.........ty

Section ; .. . .* : ... .: ...... e )*

13.1.1.2.5.1 - Director, QAPD 2.1.7 - Nuclear The "Director, Nuclear Regulatory N The regulatory affairs and environmental Nuclear Regulatory Regulatory Affairs and Affairs and Environmental" organization is more generically and functionally Affairs and Environmental responsibilities are functionally described, however organizational responsibilities Environmental described as "Nuclear Regulatory remain the same.

Affairs and Environmental" in the revised QAPD.

13.1 .1.2.5.1.1 Nuclear QAPD 2.1.7 - Nuclear The section entitled "Nuclear N The regulatory affairs and environmental Regulatory Affairs Regulatory Affairs and Regulatory Affairs Department" and organization is more generically and functionally Department Enviromnental "Environmental Department" does described, however organizational responsibilities 13.1.1.2.5.1.2 - not exist in the revised QAPD. remain the same.

Environmental Department 13.1.1.2.5.2 - QAPD 2.1.6 - Performance The "Performance Improvement N The performance improvement organization is Performance hnprovement Department" responsibilities are generically and functionally described, however Improvement functionally described as organizational responsibilities remain the same.

Department "Performance Improvement" in the revised QAPD.

13.1.1.2.5.3 - Palo N/A The "Palo Verde Communications N There are no specific licensing requirements to have Verde Communications Department" and "Employee "Communications Department" or "Employee Department Concerns Department" are not Concerns Department" responsibilities described in 13.1.1.2.6 -Employee described in the revised QAPD. the UFSAR or QAPD.

Concerns Department 13.1.1.2.7 - Director, N/A The "Director, Strategic and Long N There is no specific licensing requirement to have Strategic and Long Range Planning" is not described in "Director, Strategic and Long Range Planning" Range Planning the revised QAPD. responsibilities described in the UFSAR or QAPD.

13.1.1.2.8.1 - Palo N/A The "Palo Verde Human Resources" N There is no specific licensing requirement to have Verde Human Resources in the current QAPD is not described Human Resources organization responsibilities

_______________________________in the revised QAPD. ____described in the UFSAR or QAPD.

13.1.1.2.8.2 - Director, N/A The "Director, Executive Projects" N There is no specific licensing requirement to have Executive Projects ________________in the current QAPD is not described the "Director, Executive Projects" responsibilities R = Considered to be a reduction in commitment Page 4 N = Neutral change (considered to be neither a reduction or increase in commitmentj I =Considered to be an increase in commitment

ATTACHMENT 6 Comparison of Current QAPD to Proposed QAPD Based Upon NET ll-04A and NQA-1-2008/NQA-la-2009 described in the UFSAR or QAPD.

13.1.1.2.8.3 - Director, The "Director, Site Programs" and The site procedure standards organization is Site Programs "Department Leader, Site Procedure generically and functionally described, however 13.1.1.2.8.3.1 - organizational responsibilities remain the same.

Standards" responsibilities in the Department Leader, Site current QAPD are now functionally Procedure Standards described under "Site Procedure*

Standards" in the revised QAPD.

13.1.2.2.1 - Executive UFSAR 13.1.2.1 The Executive Vice President and N The responsibilities are the same.

Vice President, Nuclear QAPD 2.1.2 Chief Nuclear Officer and Chief Nuclear responsibilities are described in Officer (CNO) UFSAR 13.1.2.1 and QAPD 2.1.2.

13.1.2.2.1.1 - Senior UFSAR 13.1.2.2 The Senior Vice President, Site N The responsibilities are the same.

Vice President, Site QAPD 2.1.3 Operations responsibilities are Operations described in UFSAR 13.1.2.2 and

______________ ~~~~~QAPD 2.1.3.___ ____________

13.1.2.2.1.2 - Site UFSAR 13.1.2.3 The Site General Plant Manager N The responsibilities are the same.

General Plant Manager responsibilities are described in UFSAR 13.1.2.3 and QAPD 2.1.3.1.

13.1.2.2.1.2.1- Director, UFSAR 13.1.2.4 The Operations Director N The responsibilities are the same.

Operations responsibilities are described in

___________________ ~~~~UFSAR 13.1.2.4. __ _________________

13.1.2.2.1.2.2 - UFSAR 13.1.2.5 The "Department Leaders Units 1, 2, N The responsibilities are the same.

Department Leaders and 3, Operations" responsibilities Units 1, 2, and 3 are described in UFSAR 13.1.2.5 Operations "Units 1, 2, and 3 Operations

_______________________ ~~Managers".________________________

13.2.2.1.2.3 - Shift UFSAR 13.1.2.6.1 Shift Manager responsibilities are N The responsibilities are the same.

Managers described under 13.1.2.6 "Operating

_________________ ______________________Shift Crews"._________________________

R = Considered to be a reduction in commitment Page 5 N = Neutral change (considered to be neither a reduction or increase in commitment)

I = Considered to be an increase in commitment

ATTACHMENT 6 Comparison of Current QAPD to Proposed QAPD Based Upon NET 11-04A and NQA-1-2008/NQA-la-2009 13.2.2.1.2.3.1 - Control UFSAR 13.1.2.6.2 Control Room Supervisor N The responsibilities are the same.

Room Supervisors responsibilities are described under 13.1.2.6 "Operating Shift Crews".

13.2.2.1.2.3.2 - Limited UFSAR 13.1.2.6.3 Limited Senior Reactor Operator for N The responsibilities are the same.

Senior Reactor Operator Refueling responsibilities are for Refueling described under 13.1.2.6 "Operating Shift Crews".

13.2.2.1.2.3.3 - Reactor UFSAR 13.1.2.6.4 Reactor Operator responsibilities are N The responsibilities are the same.

Operator described under 13.1.2.6 "Operating Shift Crews".

13.2.2.1.2.3.4 -Nuclear UFSAR 13.1.2.6.5 Nuclear Auxiliary Operator N The responsibilities are the same.

Auxiliary Operator and responsibilities are described under Auxiliary Operator, 13.1.2.6 "Operating Shift Crews".

Senior Shift Technical Advisors UFSAR 13.1.2.6.6 The Shift Technical Advisor N The operating organization is updated to responsibilities are described under acknowledge the Shift Technical Advisors as 13.1.2.6 "Operating Shift Crews". members of the "Operating Shift Crews." Their responsibilities are the same.

13.1.2.2.1.3 - Director, QAPD 2.1.10 The "Director, Maintenance" N The maintenance organization is more generically Maintenance responsibilities are now functionally and functionally described, however organizational described as "Maintenance" in the responsibilities remain the same.

_______________ ___________________revised QAPD.

13.1.2.2.1.4 - Director, QAPD 2.1.11 The "Director, Work Management" N The work management organization is more Work Management responsibilities are now functionally generically and functionally described, however described as "Work Management" in organizational responsibilities remain the same.

the revised QAPD.

13.1.2.2.1.5 Radiation QAPD 2.1.12 The Radiation Protection Manager is N The radiation protection manager responsibilities Protection Manager considered the same as the Director, are more generically and functionally described, Site Radiation Protection, as ____however organizational responsibilities remain the R = Considered to be a reduction in commitment Page 6 N = Neutral change (considered to be neither a reduction or increase in commitment)

I = Considered to be an increase in commitment

ATTACHMENT 6 Comparison of Current QAPD to Proposed QAPD Based Upon NET 1l-04A and NQA-1-2008/NQA-la-2009 AsirceProgram ~ RvsdFA iNEW * :Differences

Basis...for....

Acceptabilit"...

... y' Descriptioni (QAPD):; QAPD Sectioni ..*, ,, ::,,:, (NoteIf.* i

- Section , . .. - . ... * -' . , , - .. " -

described in the PVNGS Unit same.

__________________ ______________________Technical Specifications_______________________

13.1.2.2.1.6 - QAPD 2.1.13 The "Department Leader, N The chemistry organization is more generically and Department Leader, Chemistry" responsibilities are functionally described, however organizational Chemistry functionally described as responsibilities remain the same.

_________________ _____________________"Chemistry" in revised QAPD.______________________

13.1.2.2.1.7 - Plant QAPD 2.1.17 The "Plant Manager, Water N The water reclamation facility organization is more Manager, Water Reclamation Facility" generically and functionally described, however Reclamation Facility responsibilities are functionally organizational responsibilities remain the same.

described as "Water Reclamation Facility" in the revised QAPD.

13.1.2.2.1.8 - Director, QAPD 2.1.18 No change in responsibilities. N The responsibilities are the same.

Nuclear Training 13.1.2.2.1.9 - Assistant QAPD 2.1.14 No change in responsibilities. N The responsibilities are the same.

Plant Managers 13.1.2.2.1. 10 - Director, QAPD 2.1.15 The "Director, Nuclear Projects" N The maintenance projects organization is more Nuclear Projects responsibilities are functionally generically and functionally described, however described as "Maintenance Projects" organizational responsibilities remain the same.

in the revised QAPD.

13.1.3.- Qualifications QAPD 4.0, PVNGS will not carry over the I Compliance with NRC QA Regulatory Guides is of Nuclear Plant Regulatory Commitments, exception to ANSI / ANS 3.1-1978 described at QAPD 4.0. PVNGS will meet the Personnel NRC Regulatory Guide 1.8 at UFSAR 13.1.3.1 A. which states: "Engineer In Charge" qualification requirement as "A. Exception is taken to the delineated in ANSI / ANS 3.1-1978 as endorsed by educational requirements of NRC Regulatory Guide 1.8 (exception removed).

ANSI/ANS 3.1, paragraph 4.6.1 Engineer in Charge. Equivalent technical expertise is demonstrated by possession of a Professional Engineering License; or successful

_________________ ______________________completion of the Engineer in_________________________

R = Considered to be a reduction in commitment Page 7 N = Neutral change (considered to be neither a reduction or increase in commitment)

I = Considered to be an increase in commitment

ATTACHMENT 6 Comparison of Current QAPD to Proposed QAPD Based Upon NEL 11-04A and NQA-1-2008/NQA-la-2009

, Current Quality :.. 7/: :33i: :*** , : -. : :' , ... " * ... : ,

,Assurance Program:' -Revised. USARorNEW: ; :: ....re .... s Diff .. I

Basis for.Acceptabilit Training examination; or successful completion of 80 semester credit hours of technical portions of an engineering or physical science program; or a combination of any Bachelor's Degree and a current or previously held Senior Reactor

________________________Operator License."

13.1.3 - Qualifications QAPD 4.0, The exception to NRC Regulatory N Compliance with NRC QA Regulatory Guides is of Nuclear Plant Regulatory Commitments, Guide 1.8 and ANS 3.1-1978 at described at QAPD 4.0. Existing exception to ANS Personnel NRC Regulatory Guide 1.8 UFSAR 13.1.3.1 B. is relocated to 3.1-1978 related to LSRO experience requirements QAPD 4.0 with no changes. is maintained at QAPD 4.0.

13.1.3 - Qualifications QAPD 4.0, At UFSAR 13.1.3.1 C. Radiation N Compliance with NRC QA Regulatory Guides is of Nuclear Plant Regulatory Commitments, Protection "Director" and "Manager" described at QAPD 4.0. Existing clarification to Personnel NRC Regulatory Guide 1.8 are considered the same. NRC Regulatory Guide 1.8 for the Radiation Protection Manager is maintained at QAPD 4.0.

13.1.3 - Qualifications QAPD 2.2, Quality Assurance PV~NGS will not carry over the N Quality Assurance personnel training and of Nuclear Plant Program exception to ANSI / ANS 3.1-1978 qualification requirements will be described in Personnel QAPD 4.0, at UFSAR 13.1.3.1 D. which states: Section 2.2 of the new QAPD and are based upon Regulatory Commitments, "D. Exception is taken to the the guidance of NQA-1-2008 with 2009 Addenda NRC Regulatory Guide 1.8 experience requirement of and NELI 11-04A, Revision 0.

ANSI/ANS 3.1-1978, paragraph 4.4.5 for the nuclear assurance department leaders. They are not required to have one year of experience within the QA/nuclear assurance organization."

13.1.3 - Qualifications QAPD 2.2, Quality Assurance PVNGS will not carry over the N Quality Assurance personnel training and of Nuclear Plant Program exception to ANSI / ANS 3.1-1978 qualification requirements will be described in Personnel QAPD 4.0, Regulatory at UFSAR 13.1.3.1 B. which states: ___Section 2.2 of the new QAPD and are based upon R =Considered to be a reduction in commitment Page 8 N =Neutral change (considered to be neither a reduction or increase in commitment)

I =Considered to be an increase in commitment

ATTACHMENT 6 Comparison of Current QAPD to Proposed QAPD Based Upon NET ll-04A and NQA-1-2008/NQA-la-2009 Commitments, "B. The director, nuclear assurance, the guidance of NQA- 1-2008 with 2009 Addenda NRC Regulatory Guide 1.8 shall have broad experience and, and NEI 11-04A, Revision 0.

formal training in the performance of quality assurance and quality control activities, including inspection and testing. They shall be capable of planning and providing supervision to nuclear assurance personnel who may be engaged in inspecting, testing, reviewing, evaluating, and auditing the adequacy of activities to accomplish quality assurance program objectives. The director, nuclear assurance, shall have a bachelor's degree in science or engineering or the equivalent of a bachelor's degree as described in the PVNGS commitment to Regulatory Guide 1.8. In addition to the bachelor's degree or equivalent, the nuclear assurance director shall have at least 4 years of quality assurance or operations supervisory experience. At least two years of the required experience shall be nuclear power plant experience. As discussed in ANS 3.1-1978, Section 4.4.5, at least one year of the required experience shall be

________________ _____________________supervisory or management________________________

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I = Considered to be an increase in commitment

ATTACHMENT 6 Comparison of Current QAPD to Proposed QAPD Based Upon NET ll-04A and NQA-1-2008/NQA-la-2009 experience in overall implementation of a quality assurance program."

13.2 - Training Program 13.2 - Training Program Removed paragraph which stated N These references are no longer valid. UFSARI17.2F "Refer to UFSAR Section 17.2F. will cease to exist upon adopting new QAPD based Quality Augmented Programs upon NEL 11-04A, Revision 0 and NQA-1-2008 (17.2F. 1 Quality Assurance for Fire with 2009 Addenda. Emergency response training, Protection, 17.2F.3 Quality security force training, and fire fighting training are Assurance for Security, and 17.2F.4 addressed separately in the emergency plan, security Quality Assurance for Emergency plan, and fire protection plan respectively. These Plans and Equipment) for other training programs are governed by regulations other training program requirements and than 10 CFR 50, Appendix B.

associated responsibilities."

13.4 - Review and Audit QAPD 2.2 Revised section to read "Operating N The new QAPD contains equivalent functions as QAPD 2.18 phase activities that affect nuclear currently described in UFSAR 13.4:

QAPD 5.2 safety are reviewed and audited. The

13.4.1 - Staff Technical Reviews: Function is review and audit program is described in Section 5.2.2 of the new QAPD.

implemented prior to initial fuel

13.4.2 - Onsite Review: Function is described in loading and is described in the Section 5.2.1 of the new QAPD.

PVNGS Operations Quality

13.4.3 - Independent Review: Function is Assurance Program Description described in Section 5.2.2 of the new QAPD.

(QAPD)." All remaining details in

13.4.4 - Independent Safety Reviews: Independent UFSAR 13.4 were deleted and oversight of operating activities to satisfy' the intent replaced with equivalent guidance in of NUREG-0737 are carried out by the Nuclear the new QAPD. Assurance organization as described in Section 2.2 of the new QAPD and modified "PVNGS Evaluation" at UFSAR 18.I.B. 1.2.

13.4.5 - Audit Program: The audit program is described in Section 2.18 of the new QAPD.

R = Considered to be a reduction in commitment Page 10 N = Neutral change (considered to be neither a reduction or increase in commitment)

I = Considered to be an increase in commitment

ATTACHMENT 6 Comparison of Current QAIPD to Proposed QAPD Based Upon NEI ll-04A and NQA-1-2008/NQA-la-2009 13.5 - Plant Programs QAPD 5.3 Revised section to read "The N Section 5.3 of the new QAPD provides the various and Procedures PVNGS Operations Quality types of procedures used by PVNGS to govern the Assurance Program description design, operation, and maintenance of its nuclear (QAPD) describes administrative generating plants.

and operating procedures that will be used by the operating organization to Procedural coverage for the operational phase is ensure that routine operating, off- also described in the PVNGS Unit Technical normal, and emergency activities Specifications by specific reference to Regulatory affecting nuclear safety are Guide 1 33, Appendix A conducted in a safe manner." All remaining details in UFSAR 13.5 were deleted. Section 5.3 of the new QAPD provides a generic list of procedure types consistent with NEI 1 1-04A, Revision 0.

17.2.0.1 - Quality QAPD Policy Statement Revised policy statement consistent N Adopted policy statement for operational phase Assurance Program with NEI 11-04A, Revision 0 consistent with NEI 1 1-04A, Revision 0 Policy Statement guidance.

17.2.1 - Organization 13.1 - Organizational Operating organization positions N Operational responsibilities are maintained in Structure of Applicant with direct operational authority for UFSAR 13.1 consistent with the NRC Standard QAPD 2.1 - Organization the nuclear facilities are described at Review Plan for FSAR content [NUJREG-0800].

UFSAR 13.1. Organizations Section 2.1 of the new QADP provides a functional providing technical support for description of supporting organization authorities operations are functionally described and responsibilities consistent with the guidance of

_________________in Section 2.1 of the new QAPD. NEI 11-04A, Revision 0 and 10 CFR 50.54(a).

17.2.2.1 - General QAPD 1.0, GENERAL The new QAPD states "The QAPD N The new QAPD is based on the requirements and is based on the requirements and guidance of ASME NQA-1-2008 and NQA-la-2009 guidance of ASME NQA-1-2008 Addenda. Format and content is based upon and NQA-la-2009 Addenda, guidance of NEI 11-04A, Revision 0.

_________________ ______________________"Quality Assurance Requirements ___ ______________________

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I = Considered to be an increase in commitment

ATTACHMENT 6 Comparison of Current QAPD to Proposed QAPD Based Upon NEI 1l-04A and NQA-1-2008/NQA-la-2009 for Nuclear Facility Applications,"

Parts I and II, with specific reference to selected Part III sections, as identified in this document."

17.2.2.2 - Quality 1.1 -Scope / Applicability Items are not specifically called out N Determining safety functions and the specific Assurance Scope as Quality Class Q or QAG in the quality classification of items (structures, systems, new QAPD. In the new QAPD, components, and parts) is an engineering function items within the QA Program scope governed by the design control requirements of 10 are discussed in terms of "safety- CFR 50, Appendix B, Criterion 3, as implemented related" and "non-safety-related in the PVNGS QAPD by adopting NEI 11 -04A and significant contributors to plant NQA-1-2008INQA-la-2009.

safety."________________________

17.2.2.3 - Graded Intentionally not included. The term "graded approach" is no N Although the term "graded approach" is not Approach longer specifically described or used specifically used, quality assurance requirements in the proposed new QAPD. adopted in NELI 11-04A, Part III, "NONSAFETY-RELATED SSC QUALITY CONTROL" represent an equivalent approach by applying quality requirements similar to those in 10 CFR 50, Appendix B, commensurate with the safety significance of the item and/or based upon specific regulatory commitments.

17.2.2.4 - Three Level Details intentionally not The "three level assurance approach" N The elements of the three level approach to Assurance Approach included is not specifically delineated in the verification are similar to the those verification new QAPD. activities described in NFL 11l-04A, Part LI/Section 2, Quality Assurance Program; NFL 11 -04A, Part Il/Section 10, Inspection; and NFL 11-04A, Part Il/Section 18, Audits, which are intended to meet the requirements of 10 CFR 50, Appendix B.

___________________ _______________________________________With__regard__to__pWithoegardtoeperormane poftispectonsdanttest R = Considered to be a reduction in commitment Page 12 N = Neutral change (considered to be neither a reduction or increase in commitment)

I = Considered to be an increase in commitment

ATTACHMENT 6 Comparison of Current QAPD to Proposed QAPD Based Upon NEI 1l-04A and NQA-1-2008/NQA-la-2009 Curen Quality... .

7Assuranice Program: 'Revse

......... A... or........

NEW. RIN/ ' :°:¢: Acet ilt: "i. :: .

DeQcription )QAPD)QAPDSection

oDiff erences BaisforAcptblt for the operational phase, NEI 11 -04A includes specific exceptions to NQA-1-2008/ NQA-la-2009 regarding persons or organizations performing inspections and tests, and regarding qualifications of inspection and test personnel. These exceptions have been previously accepted by the NRC.

Specific verification activities related to operating status control are intentionally separated from the more traditional quality verifications (inspections) required by 10 CFR 50, Appendix B, Criterion 10, in order to provide clarity in the requirements for the various types of verifications . PVNGS is adopting the guidance of NEI 11-04A, Part II/Section 14, Inspection, Test, and Operating Status, and Part V/Section 4, "Control of Systems and Equipment in the Operational Phase", which specifically addresses verification requirements related to equipment status control.

17.2.2.5 - Control of the 2.2.5 - Issuance and Revision The Senior Vice President N In addition to the Chief Nuclear Officer, the Senior Quality Assurance Plan to Quality Assurance Program Regulatory & Oversight may review Vice President Regulatory and Licensing is and approve new revisions to the delegated responsibility and authority to review and QAPD. approve revisions to the QAPD.

17.2.2.6 - Quality 2.2 - Quality Assurance Removed the summary description N A simplified QAPD is adopted consistent with the Assurance Program Program of reviews at existing UFSAR guidance of NEI 1 1-04A, Revision 0. Equivalent Review 2.2.4 - Periodic Review of the 17.2.2.6. Specific reviews of QA audit and review requirements for operating Quality Assurance Program Program and operational activities activities are addressed in Sections 2.2, 2.2.4, 2.18, 2.18 - Audits are addressed in applicable sections and 5.2 of the new QAPD.

5.2 - Review of Activities of the new QAPD.

__________________Affecting Safe Plant Operation_________________ __________________________

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I = Considered to be an increase in commitment

ATTACHMENT 6 Comparison of Current QAPD to Proposed QAPD Based Upon NEI ll-04A and NQA-1-2008/NQA-la-2009 Assuranc~e Program RvsdUFSAR or NEW -",". .

Decrpton(QPD..P Sectio.. :..:? * =Differences .... "I,. , Basis for Accetabilit 17.2.2.7 - Training and 2.2.6 - Personnel Training and. Excessive details regarding N A simplified description of training requirements is Qualification Qualifications implementation and training methods provided consistent with the guidance of NEI 11-are removed. 04A, Revision 0 and 10 CER 50, Appendix B, Criterion 2.

17.2.2.8 - Quality 2.2 - Quality Assurance The PVNGS Nuclear Assurance R The overall guidance provided in NEI 11-04A and Classification Program Department will not be required to NQA-1-2008iNQA-la-2009, does not prescribe a 3.1 - Non safety-related SSCs- concur with lowering the quality similar review and concurrence by the independent Significant Contributors to classification of systems, structures, quality assurance organization. Determining the Plant Safety components, or parts, safety functions and the specific quality 3.2 -Non-safety-related SSCs classifications of items (structures, systems, Credited for Regulatory Events components, and parts) are engineering design activities governed by the requirements of 10 CFR 50, Appendix B, Criterion 3. Design verifications and reviews are required for design activities as described in the new QAPD sections 2.3 and 5.2.

Requirements are consistent with the guidance of NEI 11l-04A and NQA- 1-2008iNQA-l1a-2009.

17.2.2.8 - Quality Intentionally not included. The new QAPD does not specifically N The existing quality classification system and terms Classification define the terms Quality Class Q, used at PVNGS are expected to remain in place Quality Augmented (QAG), or Non- because to change would be cost-prohibitive. The Quality Related (NQR), however the underlying concepts related to the quality concept behind each classification classifications are unchanged. QAPD Section 1.1 remains, addresses the scope of the QAP and determination of safety functions; specific quality classifications of items (structures, systems, components, and parts) is an engineering function governed by the design control requirements of 10 CFR 50, Appendix B, Criterion 3. Although "quality augmented "classification is not specifically

__________de__ined,__the__quadefineathequaliyeassuanceeequireentsodopte R =Considered to be a reduction in commitment Page 1.4 N =Neutral change (considered to be neither a reduction or increase in commitment)

I =Considered to be an increase in commitment

ATTACHMENT 6 Comparison of Current QAPD to Proposed QAPD Based Upon NEL 11-04A and NQA-1-2008/NQA-la-2009

Description (QAPD)! ........ D Section ......[.... Difrecs i

f' Acceptabili...

Ba...is .

, S ectio n,: . . ... . . .. .... i.. Y .

from NEI 11 -04A, Part III, "NONSAFETY-RELATED SSC QUALITY CONTROL" represents an equivalent approach by applying quality requirements similar to those in 10 CFR 50, Appendix B, commensurate with the safety significance of the item and/or based upon specific regulatory commitments.

17.2.2.9 - Safety QAPD 2.2 This section is redundant to the more N Review and audit functions are maintained in the Reviews QAPD 2.18 detailed requirements of UFSAR new QAPD. Refer to discussion for UFSAR 13.4, QAPD 5.2 13.4. which provided a more detailed set of requirements.

17.2.2.10 - Conditions 2.16 - Corrective Action No change in requirements N N/A Adverse to Quality and Corrective Actions 17.2.2.11 - External 2.7.1 - Acceptance of Item or Interface with external organizations N Equivalent requirements provided at new QAPD Organizations Service is accomplished via procurement 2.7. This statement was redundant in the existing requirements at new QAPD 2.7. PVNGS QA Program Description.

17.2.2.12 -Resolution 2.1.5.1 - Organization Overall no change in requirements. N Specific discussion regarding Nuclear Assurance of Differences and Director making decisions regarding Quality Escalation Assurance and the responsibility and authority for escalating safety or quality issues to the level of station or corporate management necessary to achieve resolution is captured at QAPD 2.1.5.1.

17.2.3.1 - Policy 1.0 - General Overall, no change in requirements. N General description of activities within the QA scope are identified at QAPD 2.1 consistent with NEI 11 -04A, Revision 0. An overall QA policy statement is also provided at the beginning of the

__________________ _______________QA__D__onsistentQAPDwcnsistnt wih1NET A,1-RevRevsion0 17.2.3.2 - Design 2.3 - Design Control Overall, no change in requirements. N NEI-1 1-04A, Revision 0 and NQA-1-2008 with Control _______________________________ ___2009 Addenda provide equivalent controls to those R = Considered to be a reduction in commitment Page 15 N = Neutral change (considered to be neither a reduction or increase in commitmentj I = Considered to be an increase in commitment

ATTACHMENT 6 Comparison of Current QAPD to Proposed QAPD Based Upon NEL 11-04A and NQA-1-2008/NQA-la-2009 Asuac rga Reise FA r NEW Differences ::Basis frcetblt in existing QAPD commitments to NRC Regulatory Guide 1.64, Revision 2, and ANSI N45.2.1 1-1974.

17.2.3.2 - Design QAPD 2.1 Engineering and Nuclear Assurance N Functional description of the organizational Control responsibilities and authorities are relationships, authorities, and responsibilities is not more generally described at QAPD considered a reduction in commitment per 10 CFR

_____________Section 2.2. 50.54(a) (3)(iii) and (iv).

17.2.3.2 - Design 2.3.4 - Setpoint Control New QAPD identifies requirements I The existing QAPD did not specifically address Control for instrument and equipment separate requirements for instrument and equipment setpoints that could affect nuclear setpoint control. Rather, control of setpoints was safety, embedded within existing design and configuration control requirements previously delineated in

_________________UFSAR 17.2.3.2.

17.2.3.3 - Procurement QAPD 2.1 Supply Chain and Director Nuclear N Functional description of the organizational Control Assurance responsibilities are more relationships, authorities, and responsibilities is not generally described in QAPD 2.1. considered a reduction in commitment per 10 CFR 50.54(a) (3)(iii) and (iv).

17.2.3.3 - Procurement 2.7 - Control of Purchased Instead of crediting either NVLAP or N NEI 11 -04A included a provision to credit Control Material, Equipment, and the American Association for calibration laboratories which hold a domestic Services Laboratory Accreditation (A2LA) (United States) accreditation by an NRC- approved based upon A2LA continued accrediting body recognized by the International NVLAP recognition through the Laboratory Accreditation Cooperation (ILAC)

International Laboratory Mutual Recognition Arrangement (MRA).

Accreditation Cooperation (ILAC)

Mutual Recognition Arrangement, the new QAPD credits calibration laboratories which hold a domestic (United States) accreditation by an NRC-approved accrediting body recognized by the International

__________________ ______________________ Laboratory Accreditation ___ ______________________

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ATTACHMENT 6 Comparison of Current QAPD to Proposed QAPD Based Upon NEI ll-04A and NQA-1-2008/NQA-la-2009

.Current Quality !7 ***.......

AssracePrgra RviedIJFARorNE Differences : -'- I... Basis for Accetblt Desciption (QAD): QADScto r' *ote1P :

s c tione t o -i. . .. .. . . .... . .. . ..

Cooperation (ILAC) Mutual Recognition Arrangement (MRA).

17.2.3.4 - Identification 2.8 - Identification and Control No change in requirements N N/A and Control of Materials, of Materials, Parts, and Parts, and Components Components 17.2.3.5 - Control of 2.9 - Control of Special Coatings application is not N NEI 11-04A and NQA-1-2008/NQA-la-2009 do Special Processes Processes specifically identified as an example not specifically identifyr coatings as a special of a special process, process. Existing commitment to NRC Regulatory Guide 1.54 as discussed in QAPD Section 4.0 addresses the QA requirements applicable to coatings applications and inspections.

17.2.3.6 - Test Control 2.11 - Test Control Overall no change in in existing N N/A requirements.

17.2.3.6 - Test Control 2.3.4 - Setpoint Control Computer program testing I PVNGS will implement the enhanced testing 2.11 - Test Control requirements are expanded in the program requirements for computer programs in new QAPD. station administrative procedures.

17.2.3.7 - Control of 2.12 - Control of Measuring Controls defined are essentially the N N/A Measuring and Test and Test Equipment same, except responsibilities are Equipment relocated to QAPD 2.1.

17.2.3.8 - Handling, 2.13- Handling, Storage, and Similar controls are adopted by N Controls defined by NQA-1-2008 with 2009 Storage, and Shipping Shipping reference to NQA-1-2008 with 2009 Addenda are essentially the same as existing Addenda versus describing controls controls contained in Regulatory Guide 1.38, in detail. Controls for the handling of Revision 2, and ANSI N45.2.2 - 1972.

radioactive materials are within the scope of QA Program by reference to 10 CFR 71, Subpart H, and 10

________________ _____________________CFR 72, Subpart G, in the new QA ________________________

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I = Considered to be an increase in commitment

ATTACHMENT 6 Comparison of Current QAPD to Proposed QAPD Based Upon NEI 11-04A and NQA-1-2008/NQA-la-2009

__________________Program scope statements at 1.0.

17.2.3.9 - Equipment 2.14 - Inspection, Test, and The PVNGS Nuclear Assurance R PVNGS will adopt the guidance of NEI 1 1-04A, Status and Control Operating Status Department will not be required to Revision 0. Specifically, Part Il/Section 14, 5.4 - CONTROL OF concur with the administrative "Inspection, Test, and Operating Status states, in SYSTEMS AND controls for bypassing or altering the part: "Administrative procedures also describe the EQUIPMENT IN THE sequence of inspections, tests, or measures taken to control sequence of required OPERATIONAL PHASE other critical operations, tests, inspections, and other operations. Review and approval for these actions is subject to the same control as taken during the original review and approval of tests, inspections, and other operations."

17.2.3.10 - 2.13 - HANDLING, Similar controls are adopted by N The controls for housekeeping and cleanliness Housekeeping and STORAGE, AND SHIPPING reference to NQA-1-2008 with 2009 included in NQA-1-2008 with 2009 Addenda are Cleanliness Addenda versus describing controls essentially the same as existing controls contained in detail. The following requirement in ANSI N45.2.1 - 1973 and ANSI N45.2.3 - 1973.

in current QAPD is not specifically described in the new QAPD: For the change related to verifying no foreign "Additionally, immediately prior to material has entered opened systems or components, closure of system(s) or PVNGS will adopt equivalent guidance provided in component(s), a verification shall be NEI 11 -04A, Revision 0, Part V, Section 4, conducted and documented to ensure "CONTROL OF SYSTEMS AND EQUIPMENT cleanliness." IN THE OPERATIONAL PHASE", which states:

"When entry into a closed system is required,

[PVNGS] has established control measures to prevent entry of extraneous material and to assure that foreign material is removed before the system is reclosed."

17.2.3.11 - Control of 5.4 - CONTROL OF The term "construction" is generally I PVNGS has already or will implement the enhanced Construction, SYSTEMS AND no longer used in the new QAPD as ___maintenance and modification program R = Considered to be a reduction in commitment Page 18 N = Neutral change (considered to be neither a reduction or increase in commitment)

I = Considered to be an increase in commitment

ATTACHMENT 6 Comparison of Current QAPD to Proposed QAPD Based Upon NET ll-04A and NQA-1-2008/NQA-la-2009 Current Quality... ...

AssUrance . Pr~ogram

. Rev......

ised UAPDSAciRe or NE 1 'i -.... ':Differen

!.. c-iesi....-..)-".-- -: . .o. :Basis for Ac~ceptabiility ° =-

Deciption (QAPD) ..... Section "N-te 1)

Maintenance (Preventive EQUIPMENT IN THE the construction phase is complete. requirements in station administrative procedures.

/ Corrective), and OPERATIONAL PI-ASE More detailed requirements for Modifications 2.3 - Design Control modifications and maintenance are 2.10 - Inspection described in NQA-l1-2008 / NQA-2.11 - Test Control 1la-2009, Subpart 2.18 "Quality 2.15 - Nonconforming Assurance Requirements for Materials, Parts, or Components Maintenance of Nuclear Facilities" 2.16 - Corrective Action including preventive maintenance 2.5.4 - Control of Systems and (including vendor recommendations, Equipment in the Operational monitoring and evaluating for Phase degradation of performance, 2.5.5 - Plant Maintenance evaluating the effectiveness of 2.12 - Control of Measuring preventive maintenance) and and Test Equipment corrective maintenance (requiring engineering evaluation for failures identified that could have serious effect on safety or operability, provisions for emergency maintenance work).

17.2.3.12 - Control of 2.10 - Inspection The existing requirements of N N/A Surveillance Testing and 2.11 - Test Control UFSAR section 17.2.3.12 - Control Inspection of Surveillance Testing and Inspection are included in QAPD sections 2.10 and 2.11.

17.2.3.13 - Radiological Details intentionally not There is no specific section N Radiological Controls are generally covered by Control included dedicated to "Radiological Control" regulations outside of 10 CFR 50, Appendix B, such in the new QAPD. Required as 10 CFR 20, STANDARDS FOR PROTECTION procedural coverage for the AGAINST RADIATION. Operational phase operational phase includes radiation procedures for radiological controls are required as

_______________ ___________________protection and radioactive material ___described at QAPD 5.3. In addition, audits of R =Considered to be a reduction in commitment Page 19 N = Neutral change (considered to be neither a reduction or increase in commitment)

I = Considered to be an increase in commitment

ATTACHMENT 6 Comparison of Current QAPD to Proposed QAPD Based Upon NEI 11-04A and NQA-1-2008/NQA-la-2009 Curren Quality * ..... i . ..

Decrpto P~rm-(QPD R"i. QAPDSecton . ... iBasis for...Acceptability ..

D esc*ition((PNa.. .. .. . .. .. . ... r nc s. . .e tif 1.) : , ,,-::*

controls. radiation protection and radioactive material controls are performed per QAPD 2.18, "Audits".

17.2.3.14 - Control of Details intentionally not There is no specific section N Controls for radioactive materials and wastes are Radioactive Waste included dedicated to "Control of Radioactive generally covered by regulations outside of 10 CFR Waste" in the new QAPD. Required 50, Appendix B, such as 10 CFR 20, Standards for procedural coverage for the Protection Against Radiation; 10 CFR 71, operational phase includes handling Packaging and Transportation of Radioactive of radioactive materials and wastes. Material; and 10 CFR 72, Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater Than Class C Waste. Operational phase procedures for handling of radioactive materials and wastes are required as described at QAPD 5.3. In addition, audits related to control of radioactive materials and wastes are performed per QAPD 2.18, "Audits". In addition, the requirements of 10 CFR 71, Subpart H and 10 CFR 72, Subpart G, are specifically included within the PVNGS QA Program scope as described at QAPD 1.0.

17.2.4.1 - Policy for 2.10 - Inspection Level I, Level II, and Level III N The elements of the three level approach to Control of Quality 2.11 - Test Control verifications are not specifically verification are similar to the those verification Verifications and Self described in the new QAPD. activities described in NEI 11-04A, Part IT/Section Assessments PVNGS will not apply the three- 2, Quality Assurance Program; NEI 11-04A, Part level approach to quality verification II/Section 10, Inspection; and NEI 11l-04A, Part as previously described. II/Section 18, Audits, which are intended to meet the requirements of 10 CFR 50, Appendix B.

With regard to performance of inspections and tests for the operational phase, NEI 11 -04A includes specific exceptions to NQA-1-2008/NQA-la-2009

___________________ _______________regarding___ personrgardigoperonsiororganzatios rperormin R = Considered to be a reduction in commitment Page 20 N = Neutral change (considered to be neither a reduction or increase in commitment)

I = Considered to be an increase in commitment

ATTACHMENT 6 Comparison of Current QAPD to Proposed QAPD Based Upon NEI 11-04A and NQA-1-2008/NQA-la-2009

@Dffere]~e inspections and tests, and regarding qualification *sof inspection and test personnel. These exceptions have been previously accepted by the NRC.

Specific verification activities related to operatin *g status control are intentionally separated from th.e more traditional quality verifications (inspection:.s) required by 10 CFR 50, Appendix B, Criterion 1,0, in order to provide clarity in the requirements foi the various types of verifications . PVNGS is adopting the guidance of NEI 11 -04A, Part II/Section 14, Inspection, Test, and Operating Status, and Part V/Section 4, Control of Systems and Equipment in the Operational Phase, which specifically address verification requirements I ;::4:L*U. LU. *;Lj I.I*,III;IL 3LaIILu.) L.*ULLI Ul.

17.2.4.2 - Level I 2.3 - Design Control Level I verifications are not N The intent of Level I Verifications in the existing Verifications 2.10 - Inspection, specifically detailed in the new PVNGS QA Program was to generically meet the 2.14 - Inspection, Test, and QAPD. The terms "worker requirements of: 10OCFR50, Appendix B, Criterion 3 Operating Status verifications", "supervisory (design verifications); Criterion 10 (inspections),

5.4 - Control of Equipment and verifications", "second party and Criterion 14 (independent verification of Systems in the Operational verifications", and "independent" operating activities), and additional operational Phase inspections are no longer specifically phase verifications resulting from the Three Mile described. Island accident (reference NUREG-0737). In the new QAPD, equivalent verification requirements are included in the applicable QAPD sections.

17.2.4.3 - Level II 2.2 - QA Program The term "Level II Verifications" is N Similar functions are accomplished by adopting Verifications no longer used in the new QAPD. NEI 11 -04A Part UI/Section 2 17.2.4.4 - Level III 2.2 - QA Program The term "Level III Verifications" is N Similar functions are accomplished by adopting Verifications 2.18 - Audits no longer used in the new QAPD. ____NEI 11 -04A Part Il/Section 2 (for Assessments),

R =Considered to be a reduction in commitment Page 21 N = Neutral change (considered to be neither a reduction or increase in commitment)

I =Considered to be an increase in commitment

ATTACHMENT 6 Comparison of Current QAIPD to Proposed QAPD Based Upon NEI ll-04A and NQA-1-2008/NQA-la-2009 Cret Quality .... RL. J .... *

Description (QAPD) ,: i: *QAI D Section " nces::

Differe. (~**~ ::;: : ,,: or.. ccepa:* .....

5.2.2 Independent Review- "Assessments" are not specifically Part I1/Section 18 (for Audits), and Part V/Section described. 2.2 (for independent review of operating activities).

17.2.5.1 - Policy for 2.15 - Nonconforming Overall there is no change in existing N N/A Control of Conditions Materials, Parts, or Components requirements, with minor differences Adverse to Quality and 2.16 -Corrective Action for UFSAR 17.2.5.1 and 17.2.5.3 as Corrective Actions noted below. _________________________

17.2.5.1 - Policy for 2.15 - Nonconforming There are no provisions in NEW R Follow-up and verification of corrective actions Control of Conditions Materials, Parts, or Components QAPD requiring Nuclear Assurance may be accomplished by various means as Adverse to Quality and 2.16 - Corrective Action Division to concur with all described in NEI 11 -04A, Revision 0, Part 2/Section Corrective Actions dispositions to significant conditions 18 and QAPD 2.18, which state: "Management adverse to quality, responds to all audit findings and initiates corrective action where indicated in accordance with the

[PVNGS] corrective action program. Where corrective action measures are indicated, documented follow-up of applicable areas through inspections, reviews, re-audits, or other appropriate means is conducted to verify implementation of assigned corrective action."

17.2.5.3 Responsibilities Details intentionally not Responsibilities are more generally N Functional description of the organizational included described in QAPD 2.1. relationships, authorities, and responsibilities is not considered a reduction in commitment per 10 CFR 50.54(a) (3)(iii) and (iv).

17.2.6.1 - Policy 2.5 - Instructions, Procedures General discussion on documents N N/A and Drawings and records policy; no overall 2.6 - Document Control change in requirements.

2.17 - Quality Assurance Records_____________________________________________

17.2.6.2 - Instructions, Details intentionally not The revised QAPD will no longer R Document controls, including requirements for Procedures, Drawings, included include specific requirements for ____reviews, will be implemented per NEI 11-04A, R =Considered to be a reduction in commitment Page 22 N =Neutral change (considered to be neither a reduction or increase in commitment)

I=Considered to be an increase in commitment

ATTACHMENT 6 Comparison of Current QAIPD to Proposed QAPD Based Upon NET ll-04A and NQA-1-2008/NQA-la-2009

Assurance Progra .... :Revi'sed* J A or NEW "*...

RIN/

D. . "QID A? Section... . D.ffee... *. .# BasisfrAcetbly

.i escription ( A D ! @ ,': .. :: ::,, ::: i "(Note I) :. .. ' "

and Policies Nuclear Assurance review of Revision 0, Part 2/Section 6, "DOCUMENT documents and will not identify the CONTROL" and revised QAPD 2.6 which state, in specific objectives for such Nuclear part:

Assurance document reviews. The following details are being removed: "The following controls, including electronic

Nuclear Assurance review of systems used to make documents available, are specific documents applied to documents and changes thereto:

Nuclear Assurance reviews to

Identification of authorized personnel independently verify that the responsible for controlled document specific documents have been preparation, review, approval, and prepared and reviewed in distribution accordance with established policy *Review of controlled documents for and program controls adequacy, completeness, and approval prior

Nuclear Assurance reviews to to distribution" verify policy and program requirements have been

___________________incorporated.

17.2.6.2 - Instructions, 2.6 - Document Control There will be no specific QAPD R PVNGS will meet the requirements of QAPD 2.6, Procedures, Drawings, requirement to clearly identify Document Control, which states "PVNGS has and Policies documents as "quality related." established the necessary measures and governing procedures to control the preparation of, issuance of, and changes to documents that specify quality requirements or prescribe how activities affecting quality, including organizational interfaces, are controlled to ensure that correct documents are

______________________employed."

17.2.6.3 - Document 2.1- Organization Responsibilities are more generally N Organizational structure and responsibilities are Control ______ ___described in QAPD 2.1. ___more generically described in QAPD 2.1.

17.2.6.3 - Document 2.6 - Document Control The listing of documents in the N The revised QAPD adopts content guidance of NET Control __________proposed QAPD does not describe ___11-04A and includes commitment to NRC R =Considered to be a reduction in commitment Page 23 N =Neutral change (considered to be neither a reduction or increase in commitment)

I = Considered to be an increase in commitment

ATTACHMENT 6 Comparison of Current QAPD to Proposed QAPD Based Upon NEI ll-04A and NQA-1-2008/NQA-la-2009 the "minimum" documents to be Regulatory Guide 1.28, Revision 4. The revised controlled. Some of the "minimum"~ QAPD does not provide an all-inclusive list of documents described are not documents to be controlled or attempt to identify specifically described in the revised every type of document to be controlled. The listing QAPD. These documents include: provides examples of the types of documents to be

Documents related to computer controlled. The specific documents to be controlled software and the specific methods used for their control are

Operating and Special Orders defined in station administrative procedures.

Component Classification Evaluations

Equipment Qualification Data Files (EQ Binders)

Operating Licenses 17.2.6.3 - Document 2.6 - Document Control In the current QAPD, master lists are R PVNGS will apply controls to documents and Control required to identify the current changes thereto as described in NEI 11 -04A, revision of documents and these Revision 0, Part II/Section 6, "DOCUMENT master lists are maintained. As an CONTROL", as follows:

alternative to master lists, documents "The following controls, including electronic may be issued as controlled systems used to make documents available, are documents and, as such, shall be applied to documents and changes thereto:

appropriately stamped. This specific

A method to identify the correct document requirement is not included in the (including revision) to be used and control of proposed QAPD. superseded documents

A method to ensure the correct documents are being used" 17.2.6.3 - Document 2.5 - Instructions, Procedures The current QAPD requires N Requirements for protection and disclosure of Control and Drawings provisions to prohibit unauthorized safeguards information are not directly related to 10 2.6 - Document Control disclosure of safeguards' CFR 50 Appendix B. Though these requirements 2.17 - Quality Assurance information. These provisions shall are not specifically called out in the revised QAPD,

____________Records include identification of the ____PVNGS must meet NRC regulatory requirements R = Considered to be a reduction in commitment Page 24 N = Neutral change (considered to be neither a reduction or increase in commitment)

I = Considered to be an increase in commitment

ATTACHMENT 6 Comparison of Current QAIPD to Proposed QAIPD Based Upon NET ll-04A and NQA-1-2008/NQA-la-2009 C urrentQ uality i" ..... *.. . .... ..... ....... ... '

Assurance Program Revised UFSAR or: NE -D..if : , "* ... :*. .

Description QAPD.Section..erencesBasis :Qiffe for Acceptability SectionAD : Q D e¢i :,"::ii documents, restrictions on their related to security and safeguards information. The distribution, and storage in locked applicable NRC regulations and the NRC-approved security storage containers. The PVNGS Security Plan provide the licensing basis proposed QAPD does not delineate and commitments for control of security sensitive these requirements. and safeguards documents, not the QAPD.

17.2.6.4 - Quality 2.17 - Quality Assurance The existing QAPD identifies R Records to be maintained for the operational phase Assurance Records Records specific "minimum" records to be and their retention times will be based upon UFSAR 13.1 - PVNGS maintained and their retention as Regulatory Position C. 1.a.(3) of Regulatory Guide Organization well as includes direction to apply 1.28, Revision 4, as described in NEI 11 -04A, QAPD 2.1 - Organization the guidance for retention of Revision 0, Part lI/Section 17, "QUALITY 1.8 - Conformance to NRC operational phase records as ASSURANCE RECORDS".

Regulatory Guides described in Appendix A of ANSI 2.4 - Regulatory Commitments N45.2.9-1 974. The proposed QAPD Appropriate modifications to the wording of NEI does not specifically describe a list 11 -04A, Revision 0, Part Il/Section 17, are included of "minimum" records to be to address those initial design, construction, and maintained or any specific retention start-up records that are to be maintained to meet times. The proposed QAPD does not previous commitments to Regulatory Guide 1.88 contain these details, however does and related guidance contained in ANSI N45.2.9-describe methods to be used by 1974.

PVNGS to meet Regulatory Position C. 1.a(3) of Regulatory Guide 1.28, Revision 4. ___ ______________________

Appendix 17.2A Organizational charts included Organizational charts are included at N This UFSAR appendix providing organizational (Deleted) at QAPD Appendix A. QAPD Appendix A. charts was previously deleted. The overall PVNGS organization, responsibilities, and reporting relationships are functionally described in UFSAR 13.1 and QAPD 2.1.

Appendix 17.2B - QAPD 4.0 Differences in existing and proposed N Specific sections of QAPD Sections 2.0 and 3.0 Compliance Matrix ___ ________regulatory guide commitments are ___identify specific details related to NRC Regulatory R = Considered to be a reduction in commitment Page 25 N =Neutral change (considered to be neither a reduction or increase in commitment)

I=Considered to be an increase in commitment

ATTACHMENT 6 Comparison of Current QAPD to Proposed QAPD Based Upon NEI ll-04A and NQA-1-2008/NQA-la-2009 Current Asuac Quality rga Revised UFSARor NEW. *'i*:lt Basis

, for Descipton.(APD ....... Section....Differencesi~f~ Acceptability Sectionn.. . ~ti: : ° identified in a separate Regulatory Guides and endorsed industry standards. QAPD Guide Comparison Matrix. Section 4.0 provides an overall summary of the PVNGS QA Regulatory Guide commitments going forward. PVNGS commitment to R. G. 1.28, Revision 4, which endorses NQA-1-2008/NQA-1la-2009 and retaining certain existing regulatory guide commitments is considered to be equivalent to the previous commitments to the various regulatory guides that endorse ANSI N45.2 and related ANSI N45.2 series daughter standards. Adoption of the additional administrative controls defined by NEI 1 1-04A, Revision 0, in conjunction with a commitment to Regulatory Guide 1.28, Revision 4, is considered equivalent to previous commitment to Regulatory Guide 1.33, Revision 2.

Appendix 17.2C - QAPD 2.4 (RG 1.28, R4) In general, NRC Regulatory guide N Adopting new QA standards necessitates the Terms and Definitions QAPD 5.1 1.28, Revision 4, adopts the NQA adoption of terms and definitions consistent with 2008/NQA-la-2009 terms and their use in the context of the new standards. To do definitions. NEI 11l-04A, Part V, otherwise would promote confusion and ambiguity Section 1, provides additional terms in the interpretation and implementation of the and definitions for the operational revised QA Program requirements.

______________________ ~~~~phase._______________________

Appendix 17.2D - Details intentionally not There is no comparison matrix of N The proposed QA Program is structured using the Comparison of QA Plan included QA Plan requirements with those of NET 11 -04A, Revision 0 template. NEI 11 -04A Requirements with those 10CFR50 Appendix B in the new Part II, Sections 1 through 18, are structured such of 10CFR5O, APP.B QAPD. that the correlation of the 18 criteria of 10CFR50 AND SELECTED ANSI There is no comparison matrix of Appendix B to new QAPD sections is clearly STDS QA Plan requirements with those of evident. Applicable sections of NQA-1-2008/NQA-selected industry standards in the la-2009 are made at the related QAPD sections,

_________________________new QAPD. ___including any specific exceptions or clarifications.

R = Considered to be a reduction in commitment Page 26 N = Neutral change (considered to be neither a reduction or increase in commitment)

I = Considered to be an increase in commitment

ATTACHMENT 6 Comparison of Current QAPD to Proposed QAPD Based Upon NET 11-04A and NQA-1-2008/NQA-la-2009 C urrent Quality.. ..... ", * :

ASSUrac Progrm Kele u i r E ffern ::!?:* .[ *, ;*:oBasis for!Acceptabiliiy..

DescriptionS iQV)*-ii

QPD, Section: * ... : ,es ierenc ; ::, ,,*

APPENDIX 17.2E N/A N/A N Previously deleted. (The Nuclear Assurance DELETED document review requirements are described in the text of the QA Program Description contained in

_________________Section 17.2)

Appendix 17.2F - QAPD 3.0 - NONSAFETY- There are no longer specific QAPD N The previous quality augmented programs for items Quality Augmented RELATED SSC QUALITY sections providing details related to: and activities that are significant contributors to Programs CONTROL

Fire Protection plant safety OR to meet PVNGS regulatory QAPD 2.3 - Design Control

Radwaste Management commitments are now addressed by QAPD Section

Security 3.0. Format and content are as provided in the NEI

Emergency Plans and Equipment 11 -04A, Revision 0, Quality Assurance Program

Seismic Category IX Description template.

Station Blackout Coping Quality classification for quality augmented, Equipment nonsafety-related SSCs is a design control function carried out by the nuclear engineering organization Implementing details are eliminated, under design controls similar to those for safety-related SSCs and governed by the requirements of 10 CFR 50, Appendix B, Criterion 3.

Implementing details for quality augmented programs are described in station procedures consistent with the guidance in NEI 11-04A, Revision 0, Part III.

Appendix 17.2G - QAPD 2.3 - Design Control More detailed requirements are I PVNGS has or will implement the enhanced Control of Computer QAPD 2.4 - Procurement provided in NQA- 1-2008 / NQA- 1a- computer software requirements in station Software and Data Document Control 2009 Subpart 2.7 "Quality Assurance procedures as described in the revised QAPD.

QAPD 2.11 - Test Control Requirements for Computer Software for Nuclear Facility Applications" than those currently in UJFSAR Appendix 17.2G. QAPD reference to Subpart 2.7 invokes ___ ______________________

R = Considered to be a reduction in commitment Page 27 N =Neutral change (considered to be neither a reduction or increase in commitment)

I = Considered to be an increase in commitment

ATTACHMENT 6 Comparison of Current QAPD to Proposed QAPD Based Upon NEI 11-04A and NQA-1-2008/NQA-la-2009 Crr~ent Quality " .. ... .*I.. .

Assurance Progra ~ Reised UFSARor NEW Diff-er"

. . s .. BasisRfor Aceptabili

Description (QAPD) QAPD Secton. Not 1) ": ,:ai frAc

. .. S e tion.. . ... .. ,". . ... . . . .. . .

enhanced controls for software development, procurement, testing, maintenance, and control.

18.I.B. 1.2 - Independent QAPD 2.1.5.1 - Quality Revised PVNGS evaluation at R Specific implementing details are removed.

Safety Engineering Assurance Management 18.I.B.l1.2 to read: "The program and The reference to 13.4.4 becomes irrelevant as Group QAPD 2.2 - QA Program related procedures for review of content of UF'SAR 13.4 is being consolidated into QAPD 5.2.1 - Onsite Operating operating experience described at the new Operations QAPD. UFSAR 18.I.B. 1.2 is Organization Review UFSAR 18.I.C.5 are the primary also revised to refer to the new Operations QAPD.

method used at PVFNGS to review PVNGS will continue to satisfyi the intent of the and act upon internal and external guidance contained in NUREG-0737 related to the operating experience. Independent Safety Engineering Group (ISEG)

To augment the program and related function. Current industry-accepted monitoring and procedures described at 18.I.C.5, the assessment practices, as well as increased access to Director, Nuclear Assurance, is and use of relevant operating experience by plant responsible to monitor and assess staff, does not warrant a separate group of operational activities to provide independent safety engineers to accomplish the assurance that activities important to objective of the ISEG function. The ISEG function safety are performed satisfactorily, is encompassed within the normal operational Specific functions of the Nuclear performance monitoring and assessment activities Assurance staff are described in the that are routinely preformed by the independent Operations Quality Assurance Nuclear Assurance organization at PVNGS.

Program Description (QAPD)"

R = Considered to be a reduction in commitment Page 28 N =Neutral change (considered to be neither a reduction or increase in commitment)

I = Considered to be an increase in commitment

ATTACHMENT 7 NEI 11-04A, Revision 0, Appendix 1, Regulatory Guide 1.33, Rev. 2, ANSI N18.7-1 976, NQA 2008INQA-1la-2009 Standards, and NEI 11-04 QAPD Compliance Matrix (82 Pages Follow)

NEI 11-04A, Appendix 1 QAPD Compliance Matrix APPENDIX 1 Regulatory Guide 1.33, Rev. 2, ANSI N18.7-1976, NQA 2008fNQA-la-2009 Standards, and NEI 11-04 QAPD Compliance Matrix Appendix 1-1

NEI 11-04A, Appendix 1 QAPD Compliance Matrix Appendix 1-2

NEt 11-04A, Appendix QAPD Compliance Matrix1

American Natioixal Standard N18'.7-19761ANS-3.2,-i NQ3A-1 2*008, NQA-ia-20109 Adminitrtiv Controls and Qualt Assurance for Addenda*;.or* Comment..

s the Operational P~hase of Nucle~ar P'ower Plants I NEIr*,bO4 9APD*?, .. '* bmns ,.;

1. Scope ______________

This Standard provides requirements and NQA-1, Introduction to Part I recommendations for an administrative controls and NQA- 1, Introduction to Part II quality assurance program necessary to provide assurance QAPD, Part I, Introduction that operational phase activities at nuclear power plants QPPr I eto are carried out without undue risk to the health and safety QPPr I eto of the public. The requirements of this Standard apply to all activities affecting the safety-related functions of nuclear power plant structures, systems, and components.

It is not intended to apply to test mobile and experimental reactors nor reactors not subject to U.S. Nuclear Regulatory Commission licensing. However, applicable sections of this Standard should be used as they apply to related activities.

Activities included are: design changes, purchasing, fabricating, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling and modifying.

It is recommended that the administrative controls and NQA- 1, Introduction to Part I quality assurance provisions of this Standard be applied to NQA- 1, Introduction to Part II other important plant equipment at a level commensurate QAPD, Part I, Introduction with the importance of the equipment to reliable and efficient plant operation. However, it is emphasized that QPPr I eto this Standard is directed primarily toward administrative controls and quality assurance associated with safety-related activities, equipment and procedures.

This Standard incorporates criteria that permit a degree of NQA-1 and the NET 11-04 are flexibility, since administrative practices vary among ______________similar in allowing some Appendix 1-3

QAPD NEI 11-04A, Compliance MatrixI Appendix American NationaliStandard N18.7-1976/ANS-3.2 NQA-08,Q-a209 ,

Administrative th Controls and Quality Oertina~hsl~o~uler~we Phn*/Assurance for, ... ..

,Addenda , NQAi.....

.... or , Comments th prtoa Paeo ula Poe Pla.ts NE 11-04 QAPD . ' ..

Regulatory Guide 1.33, Rev. 2 Regulatory Positions .. ... ____________ ________,_.... ___..... _____

organizations operating nuclear power plants. flexibility based on importance to safety.

The Nuclear Regulatory Commission (NRC) promulgates NQA- 1 Introduction to Part I regulations applicable to many aspects of the design, NQA- 1, Introduction to Part II construction and operation of nuclear power reactors. This QAPD, Part I, Introduction Standard contains criteria for administrative controls and QAPD, Part II, Section 2 quality assurance for nuclear power plants during the operational phase of plant life. This phase is generally considered to commence with initial fuel loading, except for certain preoperational activities. Certain operating activities may commence prior to fuel loading and certain initial construction activities may extend past fuel loading.

Owner organizations should identify clearly those activities that fall in these overlapping time periods and should specify whether the activities are to be considered as operational or as construction activities.

This Standard is intended to be consistent with applicable QAPD Part I, Introduction 10 CFR 50, Appendix B, for the criteria for quality assurance, including those given in Title QAPD, Part II, Section 2 operational phase is met through 10, Code of Federal Regulations, Part 50, "Licensing of QAPD, Part pV a combination of NQA- 1 and the Production and Utilization Facilities," Appendix B. [1]' This QAPD in lieu of a commitment to Standard fully and completely describes the general implement the requirements of requirements and guidelines of American National ANSI N18.7-1976/ANS-3.2.

Standard Quality Assurance Program Requirements for (Commitment to industry Nuclear Power Plants, N45.2- 1971, [2] as those standards is addressed in requirements and guidelines apply during the operational nuclear facility's FSAR, [Usually phase of plant life. Chapter 1, and QAPD referenced in chapter 17]. Most of the listed

______________________standards are updated and Footnote from N18.7 - "Numbers in brackets refer to corresponding numbers in Section 6, References."

Appendix 1-4

QAPDNEI 11-04A, ComplianceAppendix Matrix1 Ameri~can, Nat~ional Standard N18.7_i976/ANS-3..2, NQA,-1-2.....N..A-la.-2...

Admninist~rative Contro1sand Quality'Assurance for *ddenda or.

A *..... Comments the euaoyGie:3 Operational Phase of e.2Rgltr Nuclear Power Plants o itin : 11-04 QAPD , , ... <

Reg. Guide 1.33 - C. Regulatory Position, paragraph 1: incorporated into NQA-1.

The overall quality assurance program requirements for For the QAPD the following the operation phase that are included in ANSI N18.7- cross-reference is provided:

1976/ANS-3.2 are acceptable to the NRC staff and provide an adequate basis for complying with the N45.2 is replaced by NQA quality assurance program requirements of Appendix B 2008 and NQA- la-2009 Addenda to 10 CFR Part 50, subject to the following [NOTE: The as indicated in Reg. Guide 1.28, Regulatory Positions that followed this statement are Rev. 4.

inserted into the 'best fit' sections of the N18.7- Table A-3 of RG 1.28 provides a 1976/ANS-3.2 text in this column of the table.]: cross-reference between the RGs, Reg. Guide 1.33 - C. Regulatory Position 2. ANSI Standard and their Throughout ANSI N18.7- 1976/ANS- 3.2, other location in NQA, as follows:

documents required to be included as a part of this standard are identified at the point of reference. The RG ANSI NQA-1 specific acceptability of these standards listed in ANSI N18.7-1976/ANS-3.2 has been addressed in the latest 1.30 N45.2.4 Subpart 2.4 revision of the following regulatory guides: 1.37 N45.2.1 Subpart 2.1 ANSI Standard Regulatory Guide 1.38 Wi N45.2.2 Subpart 2.2 N45.2 1.28 1.39 Wi N45.2.3 Subpart 2.3 N45.2.1 1.37 1.58 W N45.2.6 Part I N45.2.2 1.38 N45.2.3 1.39 1.64 W N45.2.11 Part I N45.2.4 1.30 1.88 W N45.2.9 Part I N45.2.5 1.94 1.94 Wi N45.2.5 Subpart 2.5 N45.2.6 1.58 1.116 N45.2.8 Subpart 2.8 N45.2.8 1.116 W N45.2.9 1.88 ___

N45.2.10 1.74 1.123 W N45.2.13 Part I N45.2.11 1.64 1.144W N45.2.12 Part I N45.2.13 1.123 _____________

Appendix 1-5

NEI 11-04A, Appendix I QAPD Compliance Matrix American National Administrative Standard Controls N18.7-1976/ANS-3.2:

and!QUality Assurance for NQA-1-2008, NQA--UU*Ala-2009...

Addenda...or Comments.

the *Operational Phase of Nuclear Power Plants I EI1-0 QP Regulatory Guide 1.33, Rev. 2 Regulatory Positions N18.1 1.8 1.146 W /N45.2.23 /Part I N18.17 1.17 W = Withdrawn Reg. Guide N101.4 1.54 Wi = Withdrawn Reg. Guide after Note: N45.2.12 is discussed in NRC documents WASH- issuance of RG 1.28, Rev.4, June 1283, "Guidance on Quality Assurance Requirements 2010 During Design and Procurement Phase of Nuclear *N521 snwNA120 Power Plants," (Grey Book) and WASH- 1309, "Guidance and NQA-la-2009, Part I, on Quality Assurance Requirements During the Introduction, Section 400; Reg.

Construction Phase of Nuclear Power Plants," (Green Guide 1.74 has been Book) and will be endorsed by a regulatory guide upon withdrawn its approval as an ANSI standard.

N18.1 is now ANS-3.1

N18.17 and Reg. Guide 1.17 have been withdrawn and the applicable requirements included in 10 CFR Part 73

N101.4 has been withdrawn and replaced with several other standards as discussed in RG 1.54, Rev. 2)

2. Definitions ________________

2.1 Limitations.

The definitions given below are applicable specifically to NQA- 1, Introduction to Part I NQA- 1 replaces N45.2 and this Standard. Other terms and their definitions are daughters, including N45.2. 10 contained in American National Standard, Quality Assurance Terms and Definitions, N45.2.10 [3].____________________________

2.2 Glossary of Terms _____________

administrative controls. Rules, orders, instructions, QAPD, Part V, Section 1 Appendix 1-6

NEI 11-04A, Appendix QAPD Compliance Matrix1 Amer~ican National Standard N18.7-1 9761ALNS-3.2 NQA'-1-2008,w

=o NQA-la-2009" Administrative Controls and Quality Assurance for Aded.rCmet the Operationaly Phase ofNcearPoe Plantios NEI 11-04 QAPD ° ReultoyGuide 1.33, Rev. 2 Reulatory Po..itions*

procedures, policies, practices and designations of authority and responsibility.

audit. A formal, independent examination with intent to NQA- 1, Introduction to Part I NQA- 1 provides more clarity verify conformance with established requirements.

emergency procedures. Written procedures which QAPD, Part V, Section 3 The intent of the definition is specify actions, including manipulation of plant controls, to met by the description of the reduce the consequence of an accident or potentially Emergency Operating hazardous condition which has already occurred, to Procedures and Emergency Plan implement the emergency plan, or to prepare for possible Implementing Procedures in the hazardous natural occurrences. QAPD.

experiments. Performance of those plant operations QAPD, Part V, Section 1 carried out under controlled conditions in order to establish characteristics or values not previously known.

independent review. Review completed by personnel not QAPD, Part V, Section 1 having direct responsibility for the work function under review regardless of whether they operate as a part of an organizational unit or as individual staff members (see review).

inspection. Examination, observation, or measurement to NQA- 1, Introduction to Part I determine the conformance of materials, supplies, components, parts, appurtenances, systems, personnel performance, procedures, processes or structures to predetermined requirements.

maintenance and modification procedures. Written NQA-1, Part II, Subpart 2.18, procedures defining the policies and practices by which Sections 202 and 404.1 structures; mechanical, electrical and instrumentation and QAPD, Part V, Section 4 control systems; and components thereof of a nuclear power plant are kept in a condition of good repair or efficiency so Appendix 1-7

NEI 11-04A, Appendix 1 QAPD Compliance Matrix Administrative Controls and Quality Assurance for NQA-1-2008, NQA-la-2009 the Operational!Phase of NularPwe.lat. Addenda or, '° Comments gu at~ryNEy11-O4QAPD* ..

to those activities performed by maintenance or contractor personnel to maintain, repair or modify safety-related equipment. Related activities are those actions taken by operating personnel to determine that a planned maintenance activity can be safely performed under the existing plant operating conditions, to authorize the release of equipment to be maintained in accordance with equipment control procedures, and to assure that the equipment has been returned to normal operating status at the completion of the maintenance work including verification of functional acceptability. Procedures for these related activities by operating personnel are considered to be operating procedures, but may be included in maintenance procedures.

nuclear power plant. Any plant using a nuclear reactor QAPD, Part V, Section 1 to produce electric power, process steam or space heating.

off-normal condition procedures. Written procedures QAPD, Part V, Section 3 which specify operator actions for restoring an operating variable to its normal controlled value when it departs from its range or to restore normal operating conditions following a perturbation. Such actions are invoked following an operator observation or an annunciator alarm indicating a condition which, if not corrected, could degenerate into a condition requiring action under an emergency procedure.________________

onsite operating organization. Onsite personnel QAPD, Part V, Section 1 concerned with operation, maintenance and certain_________________

Appendix 1-8

NEI 11-04A, Appendix 1 QAPD Compliance Matrix American National Standard N18.7-197/6/ANS-3.2*

AdministratiVe Controls and Quality Assurance for :NQA-I"20*08',NQAla-20°9 . . .

Addenda or ""

Comments

'theOperational Phase of Nuclear Power Plants / NEI 1-04QAP Regulatory* Guide 1.33, Rev. 2 Regulatory Positions NEl'0QPD*

technical services.

operating activities. Work functions associated with QAPD, Part V, Section 1 normal operation and maintenance of the plant, and technical services routinely assigned to the onsite operating organization.

operating procedures. Written procedures defining the QAPD, Part V, Section 4 normal method, means and limits of operation of a nuclear power plant, a plant system or systems, or processes, including actions to be taken by operating personnel for removal from and return to service equipment on which maintenance is to be or has been performed (see also maintenance and modification procedures).

operational phase. That period of time during which the QAPD, Part V, Section 1 principal activity is associated with normal operation of the plant. This phase of plant life is considered to begin formally with commencement of fuel loading, and ends with plant decommissioning.

owner organization. The organization, including the NQA- 1, Introduction to Part I, This term is also defined in onsite operating organization, which has overall legal, Section 400 ANS-3.1 financial and technical responsibility for the operation of QAPD, Part II, Section 1 one or more nuclear power plants._________________

quality assurance. All those planned and systematic NQA-1, Introduction to Part I actions necessary to provide assurance that a structure, system or component will perform satisfactorily in service.

It applies to all activities associated with doing a job correctly as well as verifying and documenting the Appendix 1-9

NEI 11-04A, QAPD Appendix Compliance Matrix1 American National Standard N18.7-1976/ANS-3.2 NA.-08 Q-a20 Admini~strative Controls and Quality Assurance forAdde20 da oQA : Comments*

the Operational Phase, of Nuclear Power Plants/. NEI-4QP * ..

RegulatoryGuide 1.33, Rev. 2 Regulatory PositionS° NEI 11-04 QAPD '

satisfactory completion of the work.

review. A deliberately critical examination, including QAPD, Part V observation of plant operation, evaluation of audit results, procedures, certain contemplated actions, and after-the-fact investigations of abnormal conditions (see independent review).

shall, should and may. The word "shall" is used to denote NQA- 1, Introduction to Part I The word "may" is not defined in a requirement; the word, "should" to denote a (as part of the definition of NQA- 1 or Regulatory Guide 1.33, recommendation; and the word "may" to denote permission, guideline) but used in NQA- 1 to denote neither a requirement nor a recommendation. permission. These words are also defined in ANS-3.1.

supervision. Direction of personnel activities or QAPD, Part V monitoring of plant functions by an individual responsible and accountable for the activities he directs or monitors.

surveillance testing. Periodic testing to verify that QAPD, Part V safety-related structures, systems and components continue to function or are in a state of readiness to perform their functions.

system. An integral part of a nuclear power plant QAPD, Part V comprising components which may be operated or used as a separate entity to perform a specific function.

testing. Performance of those steps necessary to determine NQA-1, Introduction to Part I NQA-1 expounds on the that systems or components function in accordance with definition.

predetermined specifications.

Appendix 1-10

NEI 11-04A, Appendix 1 QAPD Compliance Matrix

!'American National Standard N18.7-1976/ANS-3.2 NQA-1-2008, NQA-la-2009 Administrative Controls and~Quality Assurance forAdeaorCm nt the Operational Phase of Nuclear Power Plants/ ], "* 11-0 QAPD/-

Regulatory Guide 1.33, Rev. 2 RegulatorY Positions * ,

3. Owner Organization 3.1 General.

The owner organization shall establish an administrative NQA- 1, Requirement 2 controls and QA program which complies with this QAPD Policy Statement Standard. The program shall be in effect at all times during QAPD Part II, Sections 1 and the operational phase to assure that operational phase 2 activities are carried out without undue risk to the health and safety of the public. The program shall require that decisions affecting safety are made at the proper level of responsibility and with the necessary technical advice and review. The owner organization may delegate to other organizations the work of establishing and executing the administrative controls and quality assurance program or any part thereof, in accordance with this Standard, but shall retain responsibility.

3.2 Assignment of Authority and Responsibility.

It is essential that all members ... involved in operation of NQA-1, Requirement 1 nuclear power plants, including those at the highest QAPD, Part I, Section 1 management levels, recognize the necessity that plants be operated under a well formulated & detailed administrative controls and QAP to assure safety and efficiency. Lines of authority, responsibility and communication shall be established from the highest management level through intermediate levels to and including the onsite operating organization (including offsite organizations assigned responsibility for procurement, design and construction, QA, and technical support activities). These relationships shall be documented and updated, as appropriate, in Appendix 1-11

NEI 11-04A, Appendix 1 QAPD Compliance Matrix

Regulatory .Guide 1.334 Rev. 2 Regulatory Positi'ons;; NE 110 QAPD...

*. ;,*

organizational charts, functional descriptions of departmental responsibilities and relationships and job descriptions for key personnel positions or equivalent.

The owner organization shall specify in writing the authority and responsibility assigned to individuals and organizations involved in establishing, executing and measuring the overall effectiveness of the administrative controls and quality assurance program required by this Standard.

The persons or organizations responsible for defining and NQA-i1, Requirement 1 measuring the overall effectiveness of the program shall be designated, shall be sufficiently independent from cost and scheduling considerations when opposed to safety considerations, shall have direct access to responsible management at a level where appropriate action can be accomplished, and shall report regularly on the effectiveness of the program to the plant manager and the cognizant offsite management.

Persons or organizations performing functions of assuring NQA- 1, Requirement 1 that the administrative controls and quality assurance program is established and implemented or of assuring that an activity has been correctly performed shall have sufficient authority and organizational freedom to: identify quality problems; initiate, recommend or provide solutions, through designated channels; and verify implementation of solutions.

The organizational structure and the functional NQA- 1, Requirement 1 responsibility assignments shall be such that:

(1) Attainment of program objectives is accomplished by _______________________________

Appendix 1-12

NEI 11-04A, Appendix 1 QAPD Compliance Matrix American Nationai;Standard Ni18.7-1976/ANS-3.2 NA-08 Q-a20' Administrative Controls and Quality AddendaaocComment the Operational Phase of Nuclear Power plants/I Regulatory Guide 1.33, Rev. 2: RegUlatory Positions* : NEI 11-04 QA'PD those ... assigned responsibility for performing work. This may include interim examinations, checks, and inspections of the work by the individual performing the work.

(2) Verification of conformance to established program requirements is accomplished by a qualified person who does not have responsibility for performing or directly supervising the work. The method and extent of such verification shall be commensurate with the importance of the activity to plant safety and reliability.

4 4 In structuring the organization and assigning NQA-1, Requirement 1 responsibility, quality assurance should be recognized as an interdisciplinary function involving many organizational components and, therefore, should not be regarded as the sole domain of a single quality assurance group. For example, it may be more appropriate for nuclear engineers to perform reviews of plant nuclear engineering activities rather than quality assurance engineers because of the special competence required to perform these reviews.

Quality assurance encompasses many functions and activities and extends to various levels in all participating organizations, from the top executive to all workers whose activities may influence quality.

4 4 3.3 Indoctrination and Training. 4 4 Provisions shall be made for indoctrination and training of NQA- 1, Requirement 2 those personnel in the owner organization performing QAPD, Part II, Section 2 activities affecting quality to assure that suitable proficiency is achieved and maintained. Such personnel also shall be provided training concerning the administrative controls and quality assurance program Appendix 1-13

NEI 11-04A, Appendix 1 QAPD Compliance Matrix A..e ic ..n Naioa

... Stndr N1.7... 1AS. 2

"*NQA-12008 ......-1 * * ......

which, as a minimum, shall include the following areas:

- Overall company policies, procedures, or instructions which establish the program

- Procedures or instructions which implement the program related to the specific job-related activity.

3.40Onsite Operating Organization 3.4.1 General.

A number of factors influence management in its decision NQA- 1, Requirement 1 regarding the establishment of an onsite operating QAPD, Part II, Section 1 organization. These include the owner organization's established staffing policies, the physical size and complexity of the nuclear power plant, the number of units, the extent of assistance provided by offsite technical support organizations, the extent of reliance on consultants and the availability of qualified personnel from other sources to assist in activities, such as initial start-up, refueling, maintenance or modification work.

A nuclear power plant onsite operating organization may change with time. For example, the number and qualifications of personnel making up the onsite technical support staff can generally be reduced as a plant progresses through initial operation to operational maturity.

Management shall give careful consideration to the timing and extent of such changes.______________

3.4.2 Requirements for the Onsite Operating Organization._______________ ________________

The onsite operating organization shall include one or more QAPD, Part II, Section 1 individuals knowledgeable in the following fields: nuclear power plant operation; nuclear power plant mechanical, ______________

Appendix 1-14

NEI 11-04A, Appendix 1 QAPD Compliance Matrix American National Standard N18.7-1976/ANS-3.2 *'NQ--08 N..QA-la-2009 .,;,

Administrative Controls and Quality Assurance ,for Addenda or Comments

,,vthe Operational Phase of Nuclear Power Plants / N,, 1O4 AP "Regulatory Guide 1.33,Rev. 2 Regulatory Positions NEI___11___04 ____PD ______________________

electrical and electronic systems; nuclear engineering; chemistry and radiochemistry; radiation protection; and quality assurance.

Initial incumbents or replacements for members of the NQA- 1, Requirement 2 The facility technical onsite operating organization and offsite technical support QAPD, Part II, Section 2 specifications also address organizations shall have appropriate experience, training QAPD, Part IV, (by commitments for training and and retraining to assure that necessary competence is commitment to ANS-3.1) qualification of the operating maintained in accordance with the provisions of American staff.

National Standard for Selection and Training of Nuclear Between NQA-1-2008, NQA-la-Power Plant Personnel, N18.1-1971. [4] Personnel whose 2009 Addenda, and the QAPD qualifications do not meet those specified in N18. 1 and who content, alternative are performing inspection, examination, and testing requirements that meet the activities during the operational phase of the plant, intent of ANSI N45.2.6 are including preoperational and start-up testing, shall be established.

qualified to American National Standard Qualifications of Inspection, Examination, and Testing Personnel for the Construction Phase of Nuclear Power Plants, N45.2.6-1973

[5], except that the QA experience cited for Levels I, II, and III should be interpreted to mean actual experience in carrying out the types of inspection, examination, or testing activity, being performed.

The owner organization shall designate those positions in QAPD, Part II, Section 1 The facility technical the onsite operating organization which shall be filled by QAPD, Part IV (by the specifications establish specific personnel holding NRC reactor operator and senior reactor commitment to ANS-3. 1 requirements for numbers of operator licenses. Requirements for the minimum number where it describes functional personnel requiring NRC of personnel holding such licenses who shall be present at positions that require an NRC licenses based on operating the plant under various operating conditions and situations operator license) conditions/situations.

shall also be specified._______________ ____ ___________

Appendix 1-15

NEI 11-04A, Appendix 1 QAPO Compliance Matrix The Plant Manager shall have overall responsibility for the NQA- 1, Requirement 1 execution of the administrative controls and quality NQA- 1, Requirement 2 assurance program at the plant to assure safety. An QAPD, Part II, Section 1 individual or organizational unit knowledgeable andQADPatIScin1fo experienced in nuclear power plant operational phase assessing and reporting on the activities and quality assurance practices shall be designated and assigned the responsibility to verify that efctvnsofheA the program is being effectively implemented. Depending pormipeetto on the organizational structure, the individual or organizational unit may report functionally to onsite plant management or an offsite organization (see also 3.2).

Reporting to onsite plant management is preferable since such an arrangement usually results in improved communications in identifying problems and initiating corrective action. The individual or organizational unit in this case may receive technical guidance from offsite support groups. This individual's or organizational unit's duties and responsibilities shall be such that the required attention can be devoted, as required, to verifying that the program is being effectively executed. The individual or organizational unit shall report on the effectiveness of the program to the Plant Manager and to other cognizant management as may be designated. Their activities shall be periodically audited by designated offsite personnel.

Appendix 1-16

NEI 11-04A, Appendix 1 QAPD Compliance Matrix American National Standard N18.7-1976/ANS-3.2 NQA-1,2008, NQA-la-2009

Administrativie Controls and Quality ASsuraiiceo for Addenda... orCmet the Operational Phase of Nuclear Power Plants /I Regulatory Guide 1.33, Rev. 2 Regulatory Posiion~s .. . NEI 11-04 QAPD , * *

4. Reviews and Audits 4.1 General.

Programs for reviews and for audits of activities affecting NQA-1, Requirement 18 plant safety during the operational phase shall be QAPD, Part II, Sections 1, 2, established by the owner organization to: 3, 5, and 18 QAPD, Part V, Section 2 (1) Verify that these activities are performed in NQA- 1, Requirement 18 conformance with this Standard and with company policy QAPD, Part II, Sections 1, 2, and rules, approved operating procedures and license 3, 5, 18 provisions. QAPD, Part V, Section 2 (2) Review significant proposed plant changes, tests and QAPD, Part II, Sections 5,18 procedures QAPD, Part V, Section 2 (3) Verify that reportable events, which require reporting to QAPD, Part V, Section 2 NRC in writing within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , are promptly investigated and corrected in a manner which reduces the probability of recurrence of such events (4) Detect trends which may not be apparent to a day-to- QAPD, Part II, Section 18 day observer QAPD, Part V, Section 2 These programs for reviews and audits shall, themselves, QAPD, Part II, Section 18.2 be periodically reviewed for effectiveness by management of the owner organization.

The programs provided for reviews and audits may take This paragraph contains general different forms. For example, the owner organization may guidance and historical assign these functions to separate established units information, no requirements independent of the onsite operating organization, or are specified.

appoint a committee comprised of individuals from within Appendix 1-17

NEI 11-04A, QAPD Appendix Compliance Matrix1 American National Administrative Standard Controls N18.7-1976/ANS-3.2 and Quality ASsurance for the Operational Phase of Nuclear Power PlantsI IQ.b08 AddendaQ-a20 or I..C.mments Regulatory Guide 1.33, Rev. 2 Regulatory Positions NEI 11-04 QAPD or outside the owner organization to perform reviews and exercise overview of audits. Historically, a committee approach was used to provide both review and audit capability .... This approach was employed to make the most efficient use of personnel with pertinent experience and qualifications. In the ensuing period, the availability of competent personnel has significantly increased as the nuclear power industry has expanded and the sources of trained manpower have responded to the resulting demand.

This growing pool of talent in the aggregate, is sufficient to encourage alternative approaches to the review and audit committees commonly used in the past.

In general, the time required of individuals serving as This paragraph provides general members of independent review groups is a function of the guidance information, no number of nuclear power plants an owner organization has requirements are specified.

in operation. For this reason, owner organizations contemplating rapid growth and an expanding commitment to nuclear power should regard the use of committees to meet the independent review functions as an interim approach for effective utilization of available technical expertise. In addition, such owner organizations should include in their expansion planning, provisions for early establishment of organizational units to provide independent review, for recruitment of staff, and for an orderly transition to such an organizational structure in the event a committee approach has been used previously to meet the independent review function An independent offsite organizational unit may be assigned This paragraph provides general review responsibilities including responsibility for guidance information, no reviewing audit reports provided by onsite staff members, requirements are specified.

Appendix 1-18

NEI 11-04A, QAPD Appendix Compliance Matrix1 American !National Standard N 18.7-19761ANS-3.2 NQA--2008,*NA- la--2009..... "

Administrative Controls and Quality Assurance for Addenda or Comments

,the Operational Phase of Nuclear Power Plants"/ ~1-4QP Regulatory Guide 1.33, Rev. 2 Regulatory Positions .... NE_,____i_04QAPD__...._____..._

or both functions may be assigned to an organizational unit that is independent of line responsibility for operating activities. This Standard does not specify an organizational structure for meeting the review and audit functions, but in lieu thereof delineates essential elements of satisfactorily comprehensive programs for review and for audit in the manner best suited to the owner organization involved.

4.2 Program Description.

Written programs for both audits and independent reviews NQA-1, Requirement 18 shall be prepared that contain: QAPD, Part II, Section 18 (1) Subjects to be audited and independently reviewed. QAPD, Part V, Section 2 (2) Responsibility and authority of those supervising audits and conducting independent reviews. These responsibilities shall include the identification of problems and the verification of corrective action. Additional responsibilities may include recommendations to appropriate management of solutions to problems and the approval or disapproval of contemplated actions.

(3) Mechanisms for initiating audit and independent review activities.

(4) Provisions for use of specialists or subgroups.

(5) Authority to obtain access to the nuclear power plant operating records and operating personnel to perform audits and independent reviews.

(6) Requirements, for distribution of reports and other records to appropriate staff members and managers in the owner organization.

(7) Identification of the management position (or positions, if auditors and reviewers have different reporting chains) to Appendix 1-19

NEI 11-04A, Appendix 1 QAPD Compliance Matrix American National Standard N18.,7-1976/ANS-3.2 ,I Q:-08'Q-a20.* ,*::*'*..

Administrative Controls and Quality Assurance for NQAd1end08 NQA-1a-"2 r coent the Operational Phase of Nuclear Power plants! NE."

I 11-0 QAPDin ... *°.

RegulatoryGuide_1.33,_Rev._2_RegulatoryPositions _________,_________.....___________________"

which auditors and independent reviewers report.

(8) Provisions for assuring that personnel responsible for audit and independent review are kept informed on a timely basis of matters within their scope of responsibility.

(9) Provisions for follow-up action, including re-audit of deficient areas where indicated.

(10) Other provisions required for effective audits and independent reviews.

4.3 Independent Review Program.

Activities occurring during the operational phase shall be QAPD, Part V, Section 2 independently reviewed on a periodic basis. The independent review program shall be functional prior to initial core loading.__________________

4.3.1 Personnel.

Personnel assigned responsibility for independent reviews QAPD, Part V, Section 2 shall be specified, in both number and technical disciplines, and shall collectively have the experience and competence required to review problems in the following areas:

(1) Nuclear power plant operations (2) Nuclear engineering (3) Chemistry and radiochemistry (4) Metallurgy (5) Nondestructive testing (6) Instrumentation and control (7) Radiological safety (8) Mechanical and electrical engineering_________________________________

Appendix 1-20

NEI 11-04A, QAPD Appendix Compliance Matrix1 Administrative Controls and Quality.Assurance for ... A 1........A-a-00

the Operational Phase of Nuclear ower Pl~ants/: i *Addenda or Comm]*ents":i

)iRegulatory Guide 1.33, Rev. 2 Regulatory Positions " NEI* 11-0 QAPD:... .

(9) Administrative controls and quality assurance practices (10) Other appropriate fields associated with the unique characteristics of the nuclear power plant involved.

An individual may possess competence in more than one specialty area. If sufficient expertise is not available from within the owner organization, independent reviews shall be supplemented through outside consultants or organizations. Provisions shall be made to assure that appropriate expertise is brought to bear in reviews of operational phase activities.

4.3.2 Standing Committees Functioning as Independent Review Bodies 4.3.2.1 Committee Composition.

When a standing committee is responsible for the QAPD, Part V, Section 2 independent review program, it shall be composed of no less than five persons, of whom no more than a minority are members of the onsite operating organization. Competent alternates are permitted if designated in advance. The use of alternates shall be restricted to legitimate absences of principals.

4.3.2.2 Meeting Frequency.

Formal meetings of personnel assigned to a standing QAPD, Part V, Section 2 committee functioning as an independent review group shall be scheduled as needed. During the period of initial operation such meetings should be held no less frequently than 1/calendar quarter. Subsequently, the meeting frequency shall not be less than twice a year. _______________ ________________

Appendix 1-21

NEI 11-04A, Appendix 1 QAPD Compliance Matrix AmisrtvAmerican Nationalcnol an N18.7-1976/ANS'3.2ssrne fo ultStandard NQA,1-2008, NQA-la,2009 * ,, .. * -

AdiitaieCnrl n ult suac o Addenda or* Comments the Operational Phase of Nuclear Power Plants/ 1-4QP Regulatory Guide 1.33, Rev. 2 R~egulatory Positions ______ 11_4_QpD_______._....._____

4.3.2.3 Quorum. _____________

A quorum for formal meetings of the committee held under QAPD, Part V, Section 2 the provisions of 4.3.2.2 shall consist of not less than a majority of the principals, or duly appointed alternates, and shall be subject to the following constraints: the chairman (or his duly appointed alternate) shall be present for all formal meetings; and no more than a minority of the quorum shall have line responsibility for operation of the plant.

4.3.2.4 Meeting Records._____________________________

Committee meeting minutes shall be prepared and QAPD, Part V, Section 2 retained, and disseminated promptly to appropriate members of management having responsibility in the area reviewed. All documentary material reviewed should be identified. Committee decisions and recommendations shall be documented. (See also Section 5.2.12.)

4.3.3 Organizational Units Functioning as Independent Review Bodies.

An organizational unit assigned responsibility for review of QAPD, Part V, Section 2 operational phase activities shall report to designated management with authority and responsibility for effective functioning of the unit and not immediately responsible for the performance of the activities to be reviewed. The supervisor of such an organizational unit should schedule periodic formal meetings of his staff, or of appropriate subparts thereof, for the purpose of fostering interaction in reviews of specific operational phase activities.

Appendix 1-22

NEI 11-04A, Appendix 1 QAPD Cornpliance Matrix American National Standard N18.7-1976/ANS-3.2 NQA_1_2008, NQA-la-2009 AdministratiVe Controls and Quality AsSurance for* Aded rCmet Sthe Operational Phase of Nuclear Power Plants I E,1OQP - J.....

Regulatory GUide 1.33, Rev. 2 Regulatory Positions NEI 1.44QAP 4.3.3.1 Documentation of Reviews.

Written records of reviews shall be prepared and retained. QAPD, Part V, Section 2 All documentary material reviewed should be identified.

Results of reviews ... including recommendations and proposed actions shall be subject to approval of the supervisor of the unit, and shall be disseminated promptly to management with responsibility in the area reviewed.

(See also Section 5.2.12.)

4.3.4 Subjects Requiring Independent Review.

The following subjects shall be reviewed by the QAPD, Part V, Section 2 independent review body:

(1) Written safety evaluations of changes in the facility as QAPD, Part V, Section 2 described in the Safety Analysis Report, changes in procedures as described in the Safety Analysis Report and tests or experiments not described in the Safety Analysis Report which are completed without prior NRC approval under the provisions of 10 CFR 50.59(a)(1). [1] This review is to verify that such changes, tests or experiments did not involve a change in the technical specifications or an unreviewed safety question as defined in 10 CFR 50.59(a)(2). [1]

(2) Proposed changes in procedures, proposed changes in QAPD, Part V, Section 2 Note - change in 50.59 language the facility, or proposed tests or experiments, any of which ("unreviewed safety question" no involves a change in the technical specifications or an longer used) - but otherwise unreviewed safety question as defined in 10 CFR 50.59(c). covered in QAPD, Part V,

[1] Matters of this kind shall be referred to the independent Section 2.2 review body by the onsite operating organization (see 4.4) following its review, or by other functional organizational units within the owner organization,_prior to_________________________________

Appendix 1-23

NEI 11-04A, Appendix 1 QAPD Compliance Matrix American National Standard N18"7-'1976/ANS'3"2

NA120*NAZ-09 '.. .

Administrative Controls and Quality Assurance for NQA....... NAdden a-o2...009 *' .... Cmet the Operationial Phase of Nuclear Power Plants I/ded rCmet Regulatory Guide 1.33, Rev. 2 Regulatory Positions NEI 11-04 QAPD implementation.

(3) Changes in the technical specifications or license QAPD, Part V, Section 2 amendments relating to nuclear safety prior to implementation, except in those cases where the change is identical to a previously reviewed proposed change.

Reg. Guide 1.33 - C. Regulatory Position 3.

Section 4.3.4, "Subjects Requiring Independent Review,"

Item (3) states, in part, that changes to the technical specifications or license amendments related to nuclear safety are required to be reviewed by the independent review body prior to implementation. It should be noted that proposed changes to technical specifications or license amendments should be reviewed by the independent review body prior to their submittal to the Commission for approval.

(4) Violations, deviations and reportable events, which QAPD, Part V, Section 2 Regulations for reporting have require reporting to the NRC in writing within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , changed, but the intent of this is such as: addressed in QAPD, Part V, Section 2.2 (a) Violations of applicable codes, regulations, orders, QAPD, Part V, Section 2 technical specifications, license requirements or internal procedures or instructions having safety significance (b) Significant operating abnormalities or deviations from QAPD, Part V, Section 2 normal or expected performance of plant safety-related structures, systems, or components (c) Reportable events, which require reporting to the NRC QAPD, Part V, Section 2 Regulations for reporting have in writing within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , as defined in the plant technical changed, but the intent of this is specifications Review of events covered under this Section addressed in QAPD, Part V, Appendix 1-24

NEI 11-04A, Appendix 1 QAPD Compliance Matrix American National Standard N18.7-1976/ANS-3.2 NQ-1208 NQA-l-200 Administrative Controls and Quality Assurance for Adde1-0,ndA-a or 09Comment..

the Operationial Phase of Nuclear Power PlantsI Regulatory Guide 1.33, Rev. 2 Regulatory Positions NEJ 11-04 QAPD,' ,i:I*

shall include the results of any investigations made and the Section 2.2 recommendations resulting from such investigations to prevent or reduce the probability of recurrence of the event.

(5) Any other matter involving safe operation of the nuclear QAPD, Part V, Section 2 power plant which an independent reviewer deems appropriate for consideration, or which is referred to the independent reviewers by the onsite operating organization or by other functional organizational units within the owner organization.

4.4 Review Activities of the Onsite Operating Organization._______________

The onsite operating organization shall provide, as part of QAPD, Part V, Section 2 the normal duties of plant supervisory personnel, timely and continuing monitoring of operating activities to assist the Plant Manager in keeping abreast of general plant conditions and to verify that the day-to-day operating activities are conducted safely and in accordance with applicable administrative controls. These continuing monitoring activities are considered to be an integral part of the routine supervisory function and are important to the safety of plant operation.

The onsite operating organization should perform reviews QAPD, Part V, Section 2 periodically and as situations demand, to evaluate plant operations and to plan future activities. The important elements of the reviews should be documented. Such reviews serve a useful purpose but shall not take the place of the reviews and audits described in Sections 4.3 and 4.5, respectively. The onsite operating organization should screen subjects of potential concern to independent Appendix 1-25

NEI 11-04A, QAPD Appendix Compliance Matrix1 American NationaliStandard N18.7-1 9761A1NS-3.2

NA120,NAl-20*..

Administrative Controls and Quality Assurance for NQA1Commentsla-00 the Operational Phase of Nuclear Power Plants / NEI: 11den4 QAPD.. ..

Regulatory Guide 1.33, Rev. 2 Regulatory Positions- :

reviewers and perform preliminary investigations (see 4.3.4). The Plant Manager, in carrying out his responsibility for overall safety of plant operations, shall be responsible for timely referral of appropriate matters to management and independent reviewers.

Reg. Guide 1.33 - C. Regulatory Position 5.a.

The guidelines (indicated by the verb "should") of ANSI N18.7-1976/ANS-3.2 contained in the following sections have sufficient safety importance to be treated the same as the requirements (indicated by the verb "shall") of the standard:

a. Section 4.4-The guidelines concerning review activities of the onsite operating organization, except the guideline that refers to screening subjects of potential concern.

[NOTE: The affected "should" words are underlined in the N18.7 excerpt above.]

4.5 Audit Program.

A comprehensive system of planned and documented audits NQA-1, Requirement 18 shall be carried out to verify compliance with all aspects of QAPD, Part II, Section 7 the administrative controls and quality assurance program. QAPD, Part II, Section 18.

Audits of selected aspects of operational phase activities QAPD, Part II, Section 18 The utilities' have modified their shall be performed with a frequency commensurate with audit programs over the years to their safety significance and in such a manner as to assure include risk-informed scheduling that an audit of all safety-related functions is completed and controlling the scope of the within a period of two years. audits as alternate methods of Audits shall include as a minimum verification of satisfying the amplified compliance and effectiveness of implementation of internal requirements stated in RG 1.33 rules, procedures (for example, operating, design, for specific elements to be Appendix 1-26

NEI 11-04A, Appendix Matrix1 QAPD Compliance American National .'Stanidard N18.7-19761ANS-3.2 NQA*-1-20 08, NQA-la-2009; "

Administrative Controls an4 Quality Assurance for Addenda Or Comments the Operational Phase of NUclear Power Plants/, I i

Regulatory Guide 1.33, Rev. 2 Regultory PoSitions o***NEI 1104* QAP*D ,* , .:,,

procurement, maintenance, modification, refueling, audited more frequently than surveillance, test, security and radiation control procedures every two years.

and the emergency plan), regulations and license provisions; programs for training, retraining, qualification and performance of operating staff; corrective actions taken following abnormal occurrences; and observation of performance of operating, refueling, maintenance and modification activities, including associated record keeping.

Reg. Guide 1.33 - C. Regulatory Position 4.

Section 4.5, "Audit Program," of ANSI N18.7-1976/ANS-3.2 states that audits of selected aspects of operational phase activities shall be performed with a frequency commensurate with their safety significance and in such a manner as to ensure that an audit of all safety-related functions is completed within a period of 2 years. In amplification of this requirement, the following program elements should be audited at the indicated frequencies:

a. The results of actions taken to correct deficiencies that affect nuclear safety and occur in facility equipment, structures, systems, or method of operation-at least once per 6 months.

b. The conformance of facility operation to provisions contained within the technical specifications and applicable license conditions-at least once per 12 months.

c.-The performance, training, and qualifications of the facility staff-at least once per 12 months.

Written reports of such audits shall be reviewed by the NQA- 1, Requirement 18 independent review body and by appropriate members of_______________

Appendix 1-27

NEI 11-04A, QAPD ComplianceAppendixMatrix1 American National Stanadard Ni8.7-1976/ANS-3.2 NQA 08, NAla-2009 Administrative Controls and Quality Assurancie for Adedao Coment

_the Operational Phase of Nuclear Power Plants I' Regulatory Guide 1.33 *Rev. 2 Regulatory:POsitions ::* NEI 11-04, QAPD ,t* .. ..

management including those having responsibility in the QAPD, Part II, Section 18 area audited. QAPD, Part V, Section 2.2 Those performing the audits may be members of the NQA- 1, Requirement 18 audited organization; however, they shall not audit activities for which they have immediate responsibility.

While performing the audit, they shall not report to a management representative who has immediate responsibility for the activity being audited.

Appropriate and timely follow-up action, including re-audit NQA- 1, Requirement 18 of deficient areas, shall be taken.

Periodic review of the audit program shall be performed by QAPD, Part V, Section 2 Audits are no longer addressed the independent review body or by a management in the technical specifications.

representative at least semiannually to assure that audits Based on SRP 17.5, the period are being accomplished in accordance with requirements of for evaluating the audit program technical specifications and of this Standard. is two years rather than every six months.

Further guidance on requirements for auditing of quality assurance programs for nuclear power plants exists in draft form. 2

5. Program, Policies and Procedures 5.1 Program Description.

The total program for providing administrative controls QAPD, Part I, Introduction and quality assurance during the operational phase may be QAPD, Part II, Section 6 described in many diverse documents. For example, ______________________________

2 Fotoefrom N18.7 "Requirements for auditing of Quality Assurance Programs for Nuclear Power Plants," Proposed American National Standard N45.2.12, trial use (Draft 4, Revision 2) January 1 1976; correspondence should be sent to: Secretary, American National Standards Committee N45, The American Society of Mechanical Engineers, United Engineering Center, 345 East 47 street, New York, NY 10017. The provisions of this draft standard shall be used for audits performed under this section except the audit frequency specified herein shall be used."

Appendix 1-28

NEI 11-04A, Appendix 1 QAPD Compliance Matrix American National Administrative Standard Controls N18.7-1976/ANS-3.2for and Quality*A'ssurance ~N NQ--0,NQ Addendaor, a20 NQ-la-Coment , -

-thOprtoa G~uide 1.33, hsofNcerowrPntRegulatory Rev. 2 Regulatory Positions* *NEI 11-04 QAPD ... = ,

operating procedures may be compiled in one manual, maintenance procedures in a second manual and Quality Assurance procedures in a third. It is not intended that all source documents be compiled in one master document.

However, a summary document shall be compiled by each owner organization to identify the sources, to index such source documents to the requirements of this Standard and to provide a consolidated base for description of the program.

The owner organization shall identify in the program NQA- 1, Requirement 2 The applicable licensee's SAIR description those structures, systems and components to be QAPD, Part II, Section 2 provides more detail on the SSCs covered by the program and the major organizational units and their importance to safety.

and their responsibilities. The program shall provide In most cases this will refer back control over activities affecting the quality of the to the list in the referenced DCD.

structures, systems and components to an extent consistent with their importance to safety. The program shall take into account the need for special controls, processes, tests, equipment, tools, and skills to attain the required quality and the need for verification of quality by inspections, evaluation or test.

5.2 Rules of Practice.______________________________

The owner organization shall establish rules and QAPD, Policy instructions pertaining to personnel conduct and control, QAPD, Part V including consideration of job-related factors which influence the effectiveness of operating and maintenance personnel, including such factors as number of hours at duty station, availability on call of professional and supervisory personnel, method of conducting operations, and preparing and retaining plant documents. These rules and instructions should provide a clear understanding of _____________________________

Appendix 1-29

NEI 11-04A, Appendix 1 QAPD Compliance Matrix operating philosophy and management policies.

5.2.1 Responsibilities and Authorities of Operating Personnel.

The responsibilities and authorities of the plant operating QAPD, Part I Section 1 QAPD provides overall personnel shall be delineated. These shall include, as a QAPD, Part V responsibilities in general terms.

minimum: The specific responsibilities (1) The reactor operator's authority and responsibility for described here are located in the shutting the reactor down when he determines that the organizational standards and safety of the reactor is in jeopardy or when operating administrative controls, parameters exceed any of the reactor protection system Technical Specifications and setpoints and automatic shutdown does not occur, reinforced through the (2) The responsibility to determine the circumstances, systematic training programs.

analyze the cause, and determine that operations can proceed safely before the reactor is returned to power after a trip or an unscheduled or unexplained power reduction.

(3) The senior reactor operator's responsibility to be present at the plant and to provide direction for returning the reactor to power following a trip or an unscheduled or unexplained power reduction.

(4) The responsibility to believe and respond conservatively to instrument indications unless they are proved to be incorrect.

(5) The responsibility to adhere to the plant's Technical Specifications.

(6) The responsibility to review routine operating data to assure safe operation.

5.2.2 Procedure Adherence.

Procedures shall be followed, and the requirements for use NQA- 1, Requirements 5 & 6 Appendix 1-30

NEI 11-04A, Appendix 1 QAPD Compliance Matrix of procedures shall be prescribed in writing. Rules shall be QAPD, Part II, Sections 5 & 6 established which provide methods by which temporary changes to approved procedures can be made, including the designation of a person or persons authorized to approve such changes.______________

Temporary changes which clearly do not change the intent QAPD, Part II, Sections 5 & 6 The QAPD requirements only of the approved procedure, shall as a minimum be approved allow temporary changes that do by two members of the plant staff knowledgeable in the not change the intent of the areas affected by the procedures. At least one of these procedure. All other changes individuals shall be the supervisor in charge of the shift must be done in accordance with and hold a senior operator's license on the unit affected. the document control program.

Such changes shall be documented and, if appropriate, incorporated in the next revision of the affected procedure.

In the event of an emergency not covered by an approved procedure, operations personnel shall be instructed to take action so as to minimize personnel injury and damage to the facility and to protect health and safety.

Guidance should be provided to identify the manner in QAPD, Part II, Section 5 which procedures are to be implemented. Examples of such guidance include identification of those tasks that require:

(1) The written procedure to be present and followed step by step while the task is being performed (2) The operator to have committed the procedural steps to memory (3) Verification of completion of significant steps, by initials or signatures of check-off lists.

The types of procedures that shall be present and referred QAPD, Part II, Section 5.1 to directly are those developed for extensive or complex jobs where reliance on memory cannot be trusted, e.g., reactor Appendix 1-31

QAPD NEI 11-04A, Appendix Compliance Matrix1 American National Standard N18.7-1976/ANS-3.2 NQA-1-2008 NQA"la-200

Administrative Controls and Quality Assurance for Addenda or Comments Sthe 1Operational Phase of Nuclear Power Plants /

Reguflatory GUide 1.33, Rev. 2 Regulatory Positions: * .NEI 11-*04 QAPD ' ,... ,,= -!,

start-up, tasks which are infrequently performed, and tasks in which operations must be performed in a specified sequence. Procedural steps for which actions should be committed to memory include, for example, immediate actions in emergency procedures. Routine procedural actions that are frequently repeated may not require the procedure to be present. Copies of all procedures shall be available to appropriate members of the plant staff. If documentation of an action is required, the necessary data shall be recorded as the task is performed. Examples of procedures requiring verification are furnished in 5.3.4.1 and 5.3.4.2.

5.. peaig res A mechanism shall be provided for dissemination to the QAPD, Part V, Section 3.2 plant staff of instructions of general and continuing applicability to the conduct of business. Such instructions, sometimes also referred to as standing orders or standard operating procedures, should deal with job turnover and relief, designation of confines of control room, definition of duties of operators and others, transmittal of operating data to management, filing of charts, limitations on access to certain areas and equipment, shipping and receiving instructions, or other such matters. Provisions should be made for periodic review and updating of standing orders.

Reg. Guide 1.33 - C. Regulatory Position 5.b.

The guidelines (indicated by the verb "should") of ANSI N18.7-1976/ANS-3.2 contained in the following sections have sufficient safety importance to be treated the same as the requirements (indicated by the verb "shall") of Appendix 1-32

NEI 11-04A, Appendix 1 QAPD Compliance Matrix American National Standard N18.7-1976/ANS-3.2 NA..--00NQA:a-00 .... '

Administrative Controls and Quality Assurance for* NQ-1--08~NA-a2 the Operational Phase of Nuclear:Power Plants / Addenda or, Comments, *

...Regulatory Guide 1.33; Rev. 2 Regulatory Positions , NEI 11-0O4 QA*PD.... ,

the standard:

b. Section 5.2.3-The guideline concerning review and updating of standing orders.

[NOTE: The affected "should" word is underlined in the N18.7 excerpt above.]

5.2.4 Special Orders.

A mechanism shall be provided for issuing management QAPD, Part V, Section 3.2 instructions which have short-term applicability and which require dissemination. Such instructions, sometimes referred to as a special orders, should encompass special operations, housekeeping, data taking, publications and their distribution, plotting process parameters, personnel actions, or other similar matters. Provisions should be made for periodic review, updating and cancellation of special orders.

Reg. Guide 1.33 - C. Regulatory Position 5.c.

The guidelines (indicated by the verb "should") of ANSI N18.7-1976/ANS-3.2 contained in the following sections have sufficient safety importance to be treated the same as the requirements (indicated by the verb "shall") of the standard:

c. Section 5.2.4-The guideline concerning review, updating, and cancellation of special orders.

[NOTE: The affected "should" word is underlined in the N18.7 excerpt above.]

5.2.5 Temporary Procedures.

Temporary procedures may be issued during the QAPD, Part V, Section 3.2 operational phase: to direct operations during testing, Appendix 1-33

NEI 11-04A, QAPD Appendix Compliance Matrix1

' Administrative Control andQuality Assurance: for NA120, Q-a20

., the: Operational Phasee of Nuclear: Pow~er Plants/.!; Addenda orC.mment refueling, maintenance and modifications; to provide Also, temporary procedures guidance in unusual situations not within the scope of the for Maintenance activities are normal procedures; and to insure orderly and uniform covered under NQA- 1, Part II, operations for short periods when the plant, a system, or a Subpart 2.18, Section 202.

component of a system is performing in a manner not covered by existing detailed procedures or has been modified or extended in such a manner that portions of existing procedures do not apply. Temporary procedures shall include designation of the period of time during which they may be used and shall be subject to the review process prescribed in 4.3 and 5.2.15 as applicable.

Temporary procedures shall be approved by the QAPD, Part V, Section 3.2 management representative assigned approval authority 5.2.6 Equipment Control.

Permission to release equipment or systems for NQA-1, Requirement 14 maintenance shall be granted by designated operating NQA- 1, Part II, Subpart 2.18, personnel. Prior to granting permission, such operating Section 205 personnel shall verify that the equipment or system can be QAPD, Part V, Section 4 released, and determine how long it may be out of service.

Granting of such permission shall be documented.

Attention shall be given to the potentially degraded degree of protection when one subsystem of a redundant safety system has been removed for maintenance.

After permission has been granted to remove the NQA-1, Requirement 14 equipment from service, it shall be made safe to work on. QAPD, Part V, Section 4 Measures shall provide for protection of equipment and workers. Equipment and systems in a controlled status shall be clearly identified. Strict control measures for such equipment shall be enforced.

Appendix 1-34

NEI 11-04A, QAPD MatrixI Appendix Compliance the Operational Phase of Nula oerPat EI 11-04* QAD):! :

Regutlatory*:Guide: 1.33,...Re...2..Regulator....Positions:

Conditions to be considered in preparing equipment for NQA- 1, Part II, Subpart 2.18, maintenance include, for example: shutdown margin; Section 205 method of emergency core cooling; establishment of a path QAPD, Part V, Section 4 for decay heat removal; temperature and pressure of the system; valves between work and hazardous material; venting, draining and flushing; entry into closed vessels; hazardous atmospheres; handling hazardous materials; and electrical hazards.

When entry into a closed system is required, control NQA-1, Subpart 2.3 measures shall be established to prevent entry of QAPD, Part II, Section 13 extraneous material and to assure that foreign material is QAPD, Part V, Section 4 removed before the system is reclosed.

Procedures shall be provided for control of equipment, as NQA- 1, Requirement 14 necessary, to maintain personnel and reactor safety and to QAPD, Part V, Section 4 avoid unauthorized operation of equipment. These procedures shall require control measures such as locking or tagging to secure and identify equipment in a controlled status. The procedures shall require independent verifications, where appropriate, to ensure that necessary measures, ... , have been implemented correctly.

Temporary modifications, such as temporary bypass lines, QAPD, Part II, Section 3 electrical jumpers, lifted electrical leads, and temporary QAPD, Part II, Section 14 trip point settings, shall be controlled by approved procedures which shall include a requirement for independent verification. A log shall be maintained of the current status of such temporary modifications.

The procedures shall also require that the status of NQA- 1, Requirement 14 inspections and tests performed upon individual items on ________________

Appendix 1-35

NEI 11-04A, QAPD Compliance Matrix1 Appendix American National Standard N18.7-1 97~6IANS-3.2:, NAI2 NA AdminiStrative Controls and Quality Assurance for" NQ- 008, NQAla-2009 . -

the OerationaliPhaseof Nulear Powe Plants!i: I '\::. - Addenda. or Comments.

eultry Gui[de 1.33, Rev; W~ lat6ry ositions::i: ' NE I 11-04 QAPD . ... :

the nuclear power plant be indicated by the use of markings such as stamps, tags, labels, routing cards, or other suitable means. Suitable means include identification numbers which are traceable to records of the status of inspections and tests.

Procedures shall also provide for the identification of items NQA- 1, Requirement 14 which have satisfactorily passed required inspections and QAPD, Part II, Section 14 tests, where necessary to preclude inadvertent bypassing of such inspections and tests. In cases where required documentary evidence is not available, the associated equipment or materials must be considered nonconforming in accordance with Section 5.2.14. Until suitable documentary evidence is available to show the equipment or material is in conformance, affected systems shall be considered to be inoperable and reliance shall not be placed on such systems to fulfill their intended safety functions.

When equipment is ready to be returned to service, NQA- 1, Requirement 14 operating personnel shall place the equipment in operation NQA- 1, Part II, Subpart 2.18, and verify and document its functional acceptability. Section 202 Attention shall be given to restoration of normal conditions, QAPD, Part V, Section 4 such as removal of jumpers or signals used in maintenance or testing or such as returning valves, breakers or switches to proper start-up or operating positions from "test" or "manual" positions. When placed into service, the equipment should receive additional surveillance during the run-in period.________________

5.2.7 Maintenance and Modifications.

Maintenance or modifications which may affect functioning NQA- 1, Introduction to Part II of safety-related structures, systems, or components shall NQA- 1, Part II, Subpart 2.18 Appendix 1-36

NEI 11-04A, Appendix 1 QAPD Compliance Matrix American National Standard N18.7-1976/A~NS-3.2* NQA-1-208 NQ-a 200-9°*°'*..- .

Administrative Controls and Quality Assurance for Adena rComet the Operational Phase of Nuclear Power Plants / NE 104QP Regulatory Guide 1.33, Rev. 2 Regulatory Positions N_____11_04___D_________

be performed in a manner to ensure quality at least QAPD, Part V, Section 5 equivalent to that specified in original design bases and requirements, materials specifications and inspection requirements. A suitable level of confidence in structures, systems, or components on which maintenance or modifications have been performed shall be attained by appropriate inspection and performance testing (see also 5.2.17 and 5.3.5).

Maintenance or modification of equipment shall be NQA- 1, Requirement 5 preplanned and performed in accordance with written NQA- 1, Part II, Subpart 2.18, procedures, documented instructions or drawings Section 202 appropriate to the circumstances which conform to QAPD, Part II, Section 5 applicable codes, standards, specifications, and criteria.

Skills normally possessed by qualified maintenance personnel may not require detailed step-by-step delineations in a written procedure.

Means for assuring quality of maintenance and NQA- 1, Requirement 2 modification activities (for example, inspections, NQA- 1, Requirement 3 measurements, tests, welding, heat treatment, cleaning, NQA- 1, Requirement 9 nondestructive examination and worker qualifications in NA ,Rqieet1 accordance with applicable codes and standards) and measures to document the performance thereof shall be NQA- 1, Requirement 11 established. This documentation shall be retained as NQA- 1, Requirement 17 specified in Section 5.2.12. NQA-1, Part II, Subpart 2.1 NQA-l, Part II, Subpart 2.3 QAPD, Part II, Sections 2, 3,

_________________________________________9, 10, 11, and 17 Measures shall be established and documented to identify NQA- 1, Requirement 14 the inspection and test status of items to be used in QAPD, Part II, Section 14 Appendix 1-37

NEI 11-04A, Appendix 1 QAPD Compliance Matrix American National Standard N18. 7-19761ANS-3.2 NQA-l-2008, NQA-la-2009:

Administrative Controls and Quality* Assurance for ..... .... Addenda or Comments the Operational Phase of Nuclear Power Plants/I,.E 10QP ... ,;,*,.. .

Rlegulatory Guide 1.3'3, Rev. 2 Regulatory Positions NE 1-0,QP maintenance and modification activities. Normally, the point of control for such items should be the plant storage area.

The following standards contain useful guidance concerning QAPD, Part IV ANSI N101.4 has been design and construction-related activities associated with withdrawn and RG 1.54 revised modifications and shall be applied to those activities in October 2010 to address the occurring during the operational phase that are comparable acceptability of the replacement in nature and extent to related activities occurring during ANSI Standards.

initial plant design and construction: American National Standard Installation, Inspection and Testing of Instrumentation and Electric Equipment During the Construction of Nuclear Power Generation Station, N45.2.4- 1972 (IEEE 336-1972) [6]; American National Standard Supplementary Quality Assurance Requirements for Installation, Inspection and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants, N45.2.5-1974 [7]; American National Standard Qualifications of Inspection, Examination and Testing Personnel for the Construction Phase of Nuclear Power Plants N45.2.6- 1973 [5]; American National Standard Supplementary Quality Assurance Requirements for Installation, Inspection and Testing of Mechanical Equipment and Systems for Construction Phase of Nuclear Power Plants, N45.2.8- 1975 [8] American National Standard Quality Assurance Requirements for the Design of Nuclear Power Plants, N45.2.11-1974 [9]; and American National Standard Quality Assurance for Protective Coating Applied to Nuclear Facilities N10 1.4-1972 [10]. Considerable care is required in assessing which operational phase activities are comparable in nature and Appendix 1-38

NEI 11-04A, QAPD Appendix Compliance Matrix1 American National standard N18.7-1976/ANS-3.2 NQA-1-20f18, NQA-la-2009*I* -° ..'..

Administrative Controls and Quality Assurance for [ Addenda or !'

Comments the Operational Phase of Nuclear Power Plants" H1-4QP Regulatory Guide 1.33, Rev. 2 Regulatory Positio0ns !NI1-4Q D ,o . .

extent to activities normally associated with design and construction.

5.2.7.1 Maintenance Programs._____________

A maintenance program shall be developed to maintain NQA-1, Part II, Subpart 2.18, safety-related structures, systems and components at the Section 100 quality required for them to perform their intended functions.

Maintenance shall be scheduled and planned so as not to NQA- 1, Introduction to Part II compromise the safety of the plant. Planning shall consider NQA- 1, Part II, Subpart 2.18, the possible safety consequences of concurrent or sequential Section 201 maintenance, testing or operating activities. Equipment required to be operable for the prevailing mode shall be available, and maintenance shall be performed in a manner such that license limits are not violated. Planning for maintenance shall include evaluation of the use of special processes, equipment and materials in performance of the task, including assessment of potential hazards to personnel and equipment.

General rules for the development of procedures under a NQA-1, Part II, Subpart 2.18 maintenance program which is consistent with the QAPD, Part V, Section 3 provisions of 5.2.7 shall be written before start-up. These general rules shall form the basis for developing the repair or replacement procedures at the time of failure.

Procedures required for maintenance of equipment expected to require recurring maintenance should be written prior to plant operation. As experience is gained in operation of the plant, routine maintenance should be altered to improve equipment performance, and procedures

.for repair of equipment shall be improved as appropriate. _______________

Appendix 1-39

NEI 11-04A, QAPD Appendix Compliance Matrix1 American National Standard NiS.7 I976/AN S,3.2,,... NQA4-:200s; NOQAla 2009 ii, Administrative Controls and Quality Assurance for Addenda or* Comments

the Operational:Phase of Nuclear~Power Plants/ ... : *-o~

' Regulatory Guide-1.33, Rev*. 2, Regulatory Positions ______i____0__D________._____ ** :,, *....

Approved procedures shall be available for repair of safety-related equipment prior to the performance of such repairs (see also Sections 5.2.2 and 5.2.7).

A preventive maintenance program including procedures as NQA- 1, Part II, Subpart 2.18, appropriate for safety-related structures, systems and Section 300 components shall be established and maintained which prescribes the frequency and type of maintenance to be performed. A preliminary program based on service conditions and experience with comparable equipment should be developed prior to fuel loading. The program should be revised and updated as experience is gained with the equipment.

The causes of malfunctions shall be promptly determined, NQA- 1, Requirement 16 evaluated and recorded (see also Sections 4.3 and 4.4). NQA-l, Part II, Subpart 2.18, Experience with the malfunctioning equipment and similar Section 400 components shall be reviewed and evaluated to determine whether a replacement component of the same type can be expected to perform its function reliably. If evidence indicates that common components in safety-related systems have performed unsatisfactorily, corrective measures shall be planned prior to replacement or repair of all such components. Replacement components should have received adequate testing or should be of a design for which experience indicates a high probability of satisfactory performance. Consideration shall be given to phased replacement to permit inservice performance of the new component to be evaluated and thereby minimize the possibility of a hidden deficiency producing a systematic failure. An augmented testing and inspection program should be implemented following a large scale component Appendix 1-40

NEI 11-04A, Appendix 1 QAPD Compliance Matrix American National Administrativbe Standard Cont~rols N18.7-1976/ANS-3.2 and Quality Assurance for .° NQA-I-2O08, Addenda NQA-la-2009,:-..

or " . .. Comments ..

the Operational Phase of Nuclear Power plants/I NEI 11-04 QAPD I i Regulatory Guide 1.33, Rev: 2 Regulatory Posit~ions ______________________________

replacement (or repair) until such time as a suitable level of performance has been demonstrated.

Reg. Guide 1.33 - C. Regulatory Position 5.d.

The guidelines (indicated by the verb "should") of ANSI N18.7- 1976/ANS-3.2 contained in the following sections have sufficient safety importance to be treated the same as the requirements (indicated by the verb "shall") of the standard:

d. Section 5.2.7.1-The guidelines that address adequate design and testing of replacement parts.

[NOTE: The affected "should" words are underlined in the N18.7 excerpt above.]

5.2.7.2 Modifications.

Design activities associated with modifications of safety- NQA- 1, Requirement 3 related structures, systems, and components shall be QAPD, Part II, Section 3 accomplished in accordance with N45.2. 11-1974. [9]

5.2.8 Surveillance Testing and Inspection Schedule.

A surveillance testing and inspection program shall be NQA- 1, Requirement 10 prescribed to insure that safety-related structures, systems, NQA- 1, Requirement 11 and components will continue to operate, keepingQADPatIScin1 parameters within normal bounds, or will act to put the QADPatIScin1 plant in a safe condition if they exceed normal bounds.

Provisions shall be made for performing required NQA- 1, Requirement 10 surveillance testing and inspections, including IS1. Such NQA- 1, Requirement 11 provisions shall include the establishment of a master QAPD, Part II, Section 11 surveillance schedule reflecting the status of all planned in plant surveillance tests and inspections. Frequency of surveillance tests and inspections may be related to the Appendix 1-41

NE!11-04A, QAPD Appendix Compliance Matrix1 American National Standard N18.7-1976/ANS-3.21 :NQA-1_2008, NQA-la_2009 Administrative Controls and Quality Assurance for ,Addenda or

Comments

the Operational Phase of Nuclear Power Plants/I Regulatory Guide 1.33, Rev. 2 Regulatory Positions*° NEI 11-04 QAPD...*

results of reliability analyses, the frequency and type of service, or age of the item or system, as appropriate.

Additional control procedures shall be instituted, as NQA- 1, Requirement 11 necessary, to assure timely conduct of surveillance tests and inspections and appropriate documentation, reporting, and evaluation of the results. Surveillance testing which may increase the probability of plant trips or major transients with accompanying safety concerns should be deferred to periods when such plant trips or transients have a minimum impact on safety and reliability.

5.2.9 Plant Security and Visitor Control. _____________

Procedures shall be developed to supplement features and Administrative controls are physical barriers designed to control access to the plant established through the security and, as appropriate, to vital areas within the plant. measures required by regulation Information concerning specific design features and (10 CFR 73) and NRC orders.

administrative provisions of the plant security program These regulatory requirements shall be confidential and thus accorded limited distribution. have superseded the The security and visitor control procedures should consider, requirements of ANSI N18.7.

for example, physical provisions, such as: fences and lighting; lock controls for doors, gates and compartments containing sensitive equipment; and provisions for traffic and access control. Also to be considered are administrative provisions, such as: visitor sign-in and sign-out procedures; escorts and badges for visitors; emphasis on inspection, observation and challenging of strangers by operating crews; and a program of pre-employment screening for potential employees. See American National Standard Industrial Security for Nuclear Power Plants, N18. 17-1973, for guidance and provisions for security measures adequate _______________________________

Appendix 1-42

NEI 11-04A, QAPO Appendix Compliance Matrix1 American National Standard ,NIS. 7-19761ANS-3.2 ... NQA-1-20; NA..la-200 Administrative Controls and' Quality Assurance forAdeaorCm nt ithe Operational Phase of Nuclear Power Plants I ded rCmet Regulatory Guide 1.33, Rev. 2 Regulatory Positions NE 110,° Q APD*

to protect nuclear power plants. [11]

5.2.10 Housekeeping and Cleanliness Control.

Housekeeping practices shall be utilized recognizing NQA-l, Part II, Subpart 2.3 requirements for the control of radiation zones and the QAYD, Part IV control of work activities, conditions and environments that can affect the quality of important parts of the nuclear plant. Housekeeping encompasses all activities related to the control of cleanness of facilities, materials, equipment fire prevention and protection including disposal of combustible material and debris and control of access to areas, protection of equipment, radioactive contamination control and storage of solid radioactive waste.

Housekeeping practices shall assure that only proper materials, equipment, processes and procedures are utilized and that the quality of items is not degraded as a result of housekeeping practices or techniques.

Where necessary, procedures and work instructions needed NQA-I, Requirement 2 NQA- 1, Subpart 2.3 replaces to assure compliance with specific requirements shall be NQA 1, Requirement 5 ANSI N45.2.3 available; e.g., inspection and cleaning of electrical bus and NQA- 1, Part II, Subpart 2.3 control centers, cleaning of control consoles, radioactive NQA-1, Part II, Subpart 2.18 decontamination. Particular attention should be given to QAPD, Part II, Sections 2 housekeeping in work and storage areas where important QAPD, Part II, Section 5 items are handled and stored to preclude damage or contamination. American National Standard Housekeeping During the Construction Phase of Nuclear Power Plants, N45.2.3-1973 [12] shall be applied to those activities occurring during the operational phase that are comparable in nature and extent to related activities occurring during construction.

Appendix 1-43

NEI 11-04A, QAPD Appendix Compliance Matrix1 SAmerican National Standard N18,7-19761ANS-3.2 NQA-I-2008, NQA-la-2009 ':'..

Administrative Controls and Quality Assurance for *Addenda or - . Comments

the Operational Ph4ase of Nuclear Power Plants/:I

'Regulatory *Guide 1.33, Rev. 2 Regulatory Positions , NEI.11-04 QAPD *-*

During maintenance or modification activities, certain NQA- 1, Part II, Subpart 2.1 NQA- 1, Subpart 2.1 replaces portions of safety-related systems may be subject to NQA-1, Part II, Subpart 2.18, N45.2.1 potential contamination with foreign materials. To prevent Section 203 such contamination, control measures, including measures for access control, shall be established. Immediately prior to closure an inspection shall be conducted to assure cleanness and the result of such inspection shall be documented. American National Standard Cleaning of Fluid Systems and Associated Components during Construction Phase of Nuclear Power Plant, N45.2. 1-1973

[13] shall be applied to activities occurring during the operational phase that are comparable in nature and extent to related activities occurring during construction.

Measures for minimizing the introduction of foreign materials during maintenance or modification, or cleaning following maintenance or modification of radioactively contaminated systems or of equipment of high radiation fields require special consideration.

5.2.11 Corrective Actions.

The program shall provide measures to ensure that NQA-1, Requirement 16 conditions adverse to plant safety, such as failure, NQA- 1, Part II, Subpart 2.18 malfunctions, deficiencies, deviations, defective material QAPD, Part II, Section 16 and equipment, abnormal occurrences, and nonconformances are promptly identified and corrected.

In the case of significant conditions adverse to safety, the NQA- 1, Requirement 16 measures shall assure that the cause of the condition is NQA-1, Part II, Subpart 2.18, determined and corrective action taken shall be Section 403.2 documented and reported to appropriate levels of QAPD, Part II, Section 16 management and for independent review in accordance QADPatVSeio2 Appendix 1-44

NEI 11-04A, QAPD Appendix Compliance Matrix1 American, National

Administrative Standard Controls N18.,7-19761ANS-3.2,for,! N..

and:QualityAssurance T"12=

u* NA.l-20 Q a2=*'*x u " ... ' ' *T* °....

/*the Operational Phase of Nuclear Power Plants/,AdnaorCmet

,,Regulatory Guide 1.33, ... Rev.. 2 Regulatory Positions* *i NEI 11-04, QAPD... , , i- . ,:*

with Section 4.3.

5.2.12. Plants Records Management.

Provisions shall be made for preparation and retention of NQA- 1, Requirement 17 plan pprprite.QAPD reord as Part II, Section 17.1 The responsibility for maintaining records and storing NQA-1, Requirement 17 Retention periods of sufficient duration to assure the ability NQA- 1, Requirement 17, NQA- 1, Requirement 17 with to reconstruct significant events and satisfy any statutory Section 400 the information in Reg. Guide requirements which apply shall be specified. QAPD, Part II, Section 17.1 1.28, Rev. 4 for NQA-1 Part III, Nonmandatory Appendix 17A- 1, "Guidance on Quality Assurance Records," in Paragraph 200, "List of Typical Lifetime Records," is equivalent to ANSI N45.2.9 American National Standard Requirements for Collection, NQA- 1, Requirement 17 NQA- 1, Requirement 17 with the Storage and Maintenance of Quality Assurance Records for QAPD, Part II, Section 17.1 information in Reg. Guide 1.28, Nuclear Power Plants, N45.2.9-1974, shall be used for Rev. 4 for NQA-1 Part III, management of plant records during the operational phase. Nonmandatory Appendix 17A-1,

[14] "Guidance on Quality Assurance Records," in Paragraph 200, "List of Typical Lifetime Records," is equivalent to ANSI N45.2.9 5.2.13 Procurement and Materials Control.

Measures shall be provided for procurement, NQA-1, Requirement 4 NQA-1 Requirements 4 and 7 documentation and control of those materials and NQA- 1, Requirement 8 are equivalent to the components including spare and replacement parts NQA- 1, Requirement 15 requirements of N45.2. 13 and necessary for plant operation, refueling, maintenance and replace that standard.

Appendix 1-45

QAPDNEI 11-04A, Compliance Appendix Matrix1 American National Standard N18.7-1976/ANS-3.2 .. . .. .. . **

Administrative Cointrols and Quality Assurance for

NQA-1-2008, . NQA-la-2009 Addenda or .. .. Comments '

the Operational Phase of Nuclear Power Plants /' NE 10QP

_*Regulatory Guide 1.33, Rev. 2 Regtilatory Positions __NE_11-04oAPD_____________

modification. These measures shall utilize American NQA- 1, Part II, Subpart 2.2 National Standard Quality Assurance Requirements for the QAPD, Part II, Section 4 Control of Procurement of Items and Services for Nuclear QAPD, Part II, Section 8 Power Plants, N45.2.13-1976. The Appendix to N45.2.13 is QAPD, Part II, Section 15 particularly useful in determining the quality assurance requirements depending on the complexity or safety of the item. [151. Procedures shall be established and implemented to ensure that purchased materials and components associated with safety-related structures or systems are:

(1) Purchased to specifications and codes equivalent to those specified for the original equipment, or those specified by a properly reviewed and approved revision. (In those cases where the original item or part is found to be commercially "off the shelf or without specifically identified quality assurance requirements spare and replacement parts may be similarly procured but care shall be exercised to assure at least equivalent performance. In those cases where the QA requirements of the original item cannot be determined, an engineering evaluation shall be conducted by qualified individuals to establish the requirements and controls. This evaluation shall assure that interfaces, interchangeability, safety, fit and function are not adversely affected or contrary to applicable regulatory or code requirements. The results of this evaluation shall be documented);

(2) Produced or fabricated under requirements at least equivalent to that of the original equipment, or those specified by a properly reviewed and approved revision; (3) Packaged and transported in a manner that will ensure Appendix 1-46

NEI 11-04A, Appendix 1 QAPD Compliance Matrix AxircnNationa Standr clN18.7-976ANS-3.2i NQ-1208,NQ-l-2 th.OeatoalPas.f.ulerP.e Plats NI 11048 QAPD*00 ;*:'

that the quality is not degraded during transit; (4) Properly documented to show compliance with applicable specifications, codes and standards; (5) Properly inspected, identified and stored to protect against damage, deterioration or misuse; (6) Properly controlled to ensure the identification, segregation and disposition of nonconforming material.

Special nuclear material and sources shall be shipped and stored as specified in the U.S. Nuclear Regulatory Commission (NRC) fuel license and other applicable regulatory documents.

5.2.13.1 Procurement Document Control.

Measures shall be provided to assure that applicable NQA- 1, Requirement 4 See Requirement 2, paragraph regulatory requirements, design bases and other 202, Technical Requirements.

requirements which are necessary to assure adequate quality are included or referenced in the procedures for procurement of items and services.

To the extent necessary, procurement documents shall NQA- 1, Requirement 4 The QA requirements of NQA require suppliers to provide a quality assurance program 1994 are equivalent to those of consistent with the pertinent requirements of American ANSI N45.2-1971.

National Standard Quality Assurance Program See Requirement 2, paragraph Requirements for Nuclear Power Plants, N45.2-1971. [2] 203, Quality Assurance Program Requirements.

Where changes are made to procurement documents, they NQA- 1, Requirement 4 See Requirement 2, paragraph shall be subject to the same degree of control as was used in 400, Procurement Document the preparation of the original documents. Changes.

Procurement documents Shall include provisions for the NQA- 1, Requirement 4 See Requirement 2, paragraph following, as applicable: ______________203, Quality Assurance Program Appendix 1-47

NEI 11-04A, Appendix 1 QAPD Compliance Matrix American National Administrative< Standard Controls N18.7-1976/ANS-3.2for *°NQA-1,2008, and QualityAssurance NQA-la-2009 Addenda Or ' Comments the Operational Phase of Nuclear Power. Plant;s I,**.. ..

Regulatory Guide 1.33, Rev. 2Regulatory Positions " -NEI 11-04 QAD *...

(1) Supplier Quality Assurance Program. Identification of Requirements.

quality assurance requirements applicable to the items or services procured. _______________

(2) Basic Technical Requirements. Where specific technical NQA- 1, Requirement 4 See Requirement 2, paragraph requirements apply, such as drawings, specifications, and 202, Technical Requirements.

industrial codes and standards, they shall be identified by titles and dates of issue in such a way as to clearly set forth the applicable documents. Where procedural requirement apply, in such areas as test and inspection needs, fabrication, cleaning, erecting, packaging, handling, shipping and storage, they too, shall be identified clearly and in such a way as to avoid uncertainty as to source and need.

(3) Source Inspection and Audit. Provisions for access to the NQA- 1, Requirement 4 See Requirement 2, paragraph supplier's facilities and records for source inspection and 204, Right of Access.

audit when the need for such inspection or audit has been determined.

(4) Documentation Requirements. Records to be prepared, NQA- 1, Requirement 4 See Requirement 2, paragraph maintained, submitted or made available for review, such 205, Documentation as drawings, specifications, procedures, procurement Requirements.

documents, inspection and test records, personnel and procedure qualifications, and material, chemical, and physical test results. Instruction on record retention and disposition shall be provided. _______________

(5) Lower Tier Procurement. Provisions for extending NQA- 1, Requirement 4 See Requirement 2, paragraph applicable requirements to lower tier subcontractors and 203, Quality Assurance Program suppliers, including purchaser's access to facilities and Requirements and paragraph records. 204, Right of Access.

Appendix 1-48

NEI 11-04A, Appendix 1 QAPD Compliance Matrix American National Standard= Ni18.7-1 9761ANS-3.2 NQ-2O8NAIa09 Administrative Controls and Quality Assurance for QAddenda08 orA Commentsi

,the Operational Phase of Nuclear Power Plants INI 104QP Regulatory Guide 11.33, ReV. 2 Regulatory Positions, , *NIi-4AP .. ..

5.2.13.2 Control of Purchased Material, Equipment and Services.

Measures shall be provided to assure that purchased items NQA-1, Requirement 7 and services, whether purchased directly or through contractors, conform to the procurement documents.

These measures shall include provisions, as appropriate, NQA-1, Requirement 7 for source evaluation and selection, objective evidence of quality furnished by the contractor, inspection and audit at the source and examination of items upon delivery.

Measures for evaluation and selection of procurement NQA-1, Requirement 7 See Requirement 7, paragraph sources include the use of historical quality performance 200, Supplier Evaluation and data, source surveys or audits, or source qualification Selection.

programs.

Source inspection or audit shall be performed as necessary NQA- 1, Requirement 7 See Requirement 7, paragraph to assure the required quality of an item. Source inspection QAPD, Part II, Section 7.1 200, Supplier Evaluation and or audit may not be necessary when the quality of the item Selection and paragraph 5, can be verified by review of test reports, inspection upon Acceptance of Item or Service.

receipt, or other means.

Where required by code, regulation, or contract NQA-1, Requirement 7 See Requirement 7, paragraph requirements documentary evidence that items conform to 501, General.

procurement requirements shall be available at the nuclear power plant site prior to installation or use of such items.

This documentary evidence shall be retrievable and shall NQA- 1, Requirement 7 See Requirement 7, paragraph be sufficient to identify the specific requirements such as 400, Control of Supplier codes, standards and specifications met by the purchased Generated Documents and item. paragraph 800, Records.

Where not precluded by other requirements, such NQA- 1, Requirement 7 See Requirement 7, paragraph documentary evidence may take the form of written 502, Methods of Acceptance.

Appendix 1-49

NEI 11-04A, Appendix 1 QAPD Compliance Matrix American National Standard N18.7-1976/ANS-3.2 NQA.......,NQA-la-20, Administrative Controls and Quality Assurance for* Addenda or Comments the Operational Phase of Nuclear Power Plants / NE 104QP Reguilatory Guide 1.33, ReV. 2 Regulatory Positions NEI____1-04___A__D __ _______________

certifications of conformance which identify the requirements met by the items, provided means are available to verify the validity of such certifications.

The effectiveness of the control of quality shall be assessed NQA- 1, Requirement 7 See Requirement 7, paragraph by the purchaser at intervals consistent with the QAPD, Part II, Section 7.1 200, Supplier Evaluation and importance, complexity and quality of the item or service. Selection.

5.2.13.3 Identification and Control of Materials, Parts and Components.

Measures shall be provided for the identification and NQA- 1, Requirement 8 control of materials, parts, and components including partially fabricated subassemblies.

These procedures shall be implemented to provide NQA-1, Requirement 8 See Requirement 8, paragraph insurance that only correct and accepted items are used 201, Item Identification.

and installed, and relating an item of production (batch, lot, component, part) at any stage, from initial receipt through fabrication, installation, repair or modification, to an applicable drawing, specification, or other pertinent technical document.

Physical identification shall be used to the maximum NQA- 1, Requirement 8 See Requirement 8, paragraph extent possible. Where physical identification is either 202, Physical Identification.

impractical or insufficient, physical separation, procedural control or other appropriate means shall be employed.

Identification may be either on the item or on records NQA- 1, Requirement 8 traceable to the item, as appropriate.

Where identification marking is employed, the marking NQA-1, Requirement 8 See Requirement 8, paragraph shall be clear, unambiguous and indelible, and shall be 202, Physical Identification, applied in such a manner as not to affect the function of the item.

Appendix 1-50

NEI 11-04A, Appendix Compliance Matrix1 QAPD SAmerican National Standard N18.7-1976/ANS-3.2* NQA-1-2008, N*QA*-l2009;* .. * * . .

Administrativie Co ntrols :and Quality ASsurance ifor Addenda..* or ... Comment the OperationalPhase of Nuclear Power Plants I,.. : . . *i:,'":;* ,, .:*.,;;:

Reuatory Guide 1.33, R~ev. 2 Regulatory Positionsi . .i:NEI 11-O04 QAPD*

Markings shall be transferred to each part of an item when NQA- 1, Requirement 8 See Requirement 8, paragraph subdivided and shall not be obliterated or hidden by surface 202, Physical Identification, treatment or coatings unless other means of identification are substituted.

When codes, standards or specifications require traceability NQA- 1, Requirement 8 See Requirement 8, paragraph of materials, parts or components to specific inspection or 301, Identification and test records, the program shall be designed to provide such Traceability of Items.

traceability.

5.2.13.4 Handling, Storage and Shipping.

Measures shall be provided to control handling, storage and NQA- 1, Requirement 13 See Requirement 13, paragraph shipping, including cleaning, packaging and preservation of 100, Basic, material and equipment in accordance with established instructions, procedures or drawings, to prevent damage, deterioration and loss.

When necessary for particular items, special coverings, NQA- 1, Requirement 13 See Requirement 13, paragraph special equipment and special protective environments, 300, Procedures, such as inert gas atmosphere, specific moisture content levels and temperature levels shall be specified, provided, and their existence verified.

For critical, sensitive, perishable or high value articles, NQA-1, Requirement 13 See Requirement 13, paragraph specific written procedures for handling, storage, 300, Procedures, packaging, shipping and preservation should be used.

Special handling tools and equipment should be provided NQA-I, Requirement 13 See Requirement 13, paragraph, and controlled as necessary to ensure safe and adequate 300, Procedures.

handling.

Reg. Guide 1.33 - C. Regulatory Position 5.e.

The guidelines (indicated by the verb "should") of ANSI N18.7-1976/ANS-3.2 contained in the following sections _______________

Appendix 1-51

NEI 11-04A, Appendix 1 QAPO Compliance Matrix American National Standard N18.7-1976/ANS-3.2 NQA,1-2008, NQA-la-2009 Administrative Controls and Quality Assurance for Ade. a..Comet the.Operational Phase of Nuclear Power Plants/Ade aor-Cmens Regulatory Guide 1.33, Rev;i2* Regulatory Positions* NEI 1'1-04* QAPD**. o,, ..

have sufficient safety importance to be treated the same as the requirements (indicated by the verb "shall") of the standard:

e. Section 5.2.13.4-The guideline concerning special handling tools and equipment.

[NOTE: The affected "should" word is underlined above.]

Special handling tools and equipment shall be inspected NQA- 1, Requirement 13 See Requirement 13, paragraph and tested in accordance with written procedures and at 300, Procedures.

specified times, to verify that the tools and equipment are adequately maintained.

Attention shall be given to providing adequate instructions NQA- 1, Requirement 13 See Requirement 13, paragraph for marking and labeling of items for packaging, shipment 600, Marking or Labeling and storage. Marking shall be adequate to identify, maintain and preserve the shipment, including indication of the presence of special environments or the need for special control.

American National Standard for Packaging, Shipping, NQA- 1, Part II, Subpart 2.2 NQA- 1, Subpart 2.2 is Receiving, Storage and Handling of Items for Nuclear equivalent to the cited ANSI Power Plants (During the Construction Phase), N45.2.2- N45.2.2 standard.

1972, shall be applied to those activities occurring during the operational phase that are comparable in nature and extent to related activities occurring during construction.

[16] _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

5.2.14 Nonconforming Items.

Measures shall be provided to control items, services or NQA- 1, Requirement 15 activities which do not conform to requirements (see also Section 5.2.6).

Appendix 1-52

NEI 11-04A, Appendix 1 QAPD Compliance Matrix American National Standard N18.7-1976/ANS-3.2 N.A-20,QAa209 *-"

Administrative Controls and Quality Assurance for NA120;QAdden oa - 20C9ens...

the Operational Phase of Nuclear Power Plants INI1.-4QP Regulatory Guidel1.33, Rev. 2 Regulatory Positions __ NE_____ 04_,,____________ ______..... ____________

These procedures shall include as appropriate, instructions NQA- 1, Requirement 15 for identification, documentation, segregation, disposition QAPD, Part II, Section 15 and notification to affected organizations.

Nonconforming items shall be reviewed and accepted, NQA- 1, Requirement 15 See Requirement 15, paragraph rejected, repaired or reworked in accordance with 404, Disposition.

documented procedures.

The responsibility and authority for the disposition of NQA- 1, Requirement 15 See Requirement 15, paragraph nonconforming items shall be defined. 402, Responsibility and Authority.

Repaired and reworked items shall be re-inspected in NQA- 1, Requirement 15 See Requirement 15, paragraph accordance with applicable procedures. 404, Disposition.

Measures which control further processing, delivery or NQA-1, Requirement 15 See Requirement 15, paragraph installation of a nonconforming or defective item pending a 200, Identification and decision on its disposition shall be established and paragraph 400, Disposition.

maintained. Nonconforming items may be:

-Dispositioning the item as accept "as is" after evaluation

-Scrapping the defective item

-Repairing the defective item

- Reworking the defective item to complete or correct the item to a drawing or specification.

Such measures shall provide assurance that the item is identified as nonconforming and controlled. The measures shall require documentation verifying the acceptability of nonconforming items which have the disposition of "repair" or "~use as is." A description of the change, waiver or deviation that has been accepted shall be documented to record the change and denote the as-built condition.

Appendix 1-53

NEI 11-04A, Appendix 1 QAPD Compliance Matrix SAlnerican Natibinal Standard N18.7-l976/ANS-3.2: ... ' ' ...... .**

Administrative Contrl and QatyAsrnefr NQ--I200~8, NQA-la-2009' oft "a~-- Plants/' : - Addenda or ,:***,,

Coments t-e ' pera1utloalP soNuclear Power , Nnt/EI 11-~t04 QAPD:...'*: i" i Regiulatory G~uide 1.33, Rev.:2 Rgulatory Posi~tions* !::N D..

As a guideline, control of nonconforming items by tagging, NQA-1, Requirement 15 See Requirement 15, paragraph marking or other means of identification is acceptable 300, Segregation.

where physical segregation is not practical, although physical segregation and marking are preferred. _______________

5.2.15 Review, Approval and Control of Procedures. _____________

The administrative controls and quality assurance program NQA- 1, Requirement 6 shall provide measures to control and coordinate the QAPD, Part II, Section 6 approval and issuance of documents, including changes thereto, which prescribe all activities affecting quality.

Such documents include those which describe organizational interfaces, or which prescribe activities affecting safety-related structures, systems, or components.

These documents also include operating and special orders, operating procedures, test procedures, equipment control procedures, maintenance or modification procedures, refueling, and material control procedures.

These measures shall assure that documents, including NQA- 1, Requirement 6 revisions or changes, are reviewed for adequacy by QAPD, Part II, Section 6 appropriately qualified personnel and approved for release by authorized personnel; and are distributed in accordance with current distribution lists and used by the personnel performing the prescribed activity, and that procedures are provided to avoid the misuse of outdated or inappropriate documents.

Procedures for operational phase activities of a nuclear power plant reflect the conditions that exist at the time the procedures are written. These conditions include the technical information available, industry experience, and in the case of the initial procedures for a new plant, ________________

Appendix 1-54

QAPDNEI 11-04A, Appendix Compliance Matrix1 American National Standard N18.7-19761ANS-3:2 NQA-1-2008, NQA-1a-2009 ...

Administrative

,Controls and Quality Assurance for Addenda or Comments th perational Phase of Nuclear Power Plants" NEI 11-04 Q'A*,

PD *

Regulatory Guide 1.33, R~ev. 2 Regulatory, Positions, :i . . .. *. .

assumptions made regarding the detailed behavior of the plant that may not be fully known prior to operation. In order to ensure that the procedures in current use provide the best possible instructions for performance of the work involved, systematic review and feedback of information based on use is required.

Each procedure shall be reviewed and approved prior to initial use. The frequency of subsequent reviews shall be specified and may vary depending on the type / complexity of the activity involved, and may vary with time as a given plant reaches operational maturity. Applicable procedures shall be reviewed following an unusual incident, such as an accident, an unexpected transient, significant operator error, or equipment malfunction. Applicable procedures shall be reviewed following any modification to a system.

Plant procedures shall be reviewed by an individual.

knowledgeable in the area affected by the procedure no less frequently than every two years to determine if changes are necessary or desirable. A revision of a procedure constitutes a procedure review.

Procedures shall be approved as designated by the owner organization before initial use. Rules shall be established which clearly delineate the review of procedures by knowledgeable personnel other than the originator and the approval of procedures and procedure changes by authorized individuals.

Changes to documents shall be reviewed and approved by NQA- 1, Requirement 6 See Requirement 6, paragraph the same organizations that perform the original review 301, Major Changes.

and approval unless the owner organization designates another qualified organization. ______________

Appendix 1-55

NEI 11-04A, Appendix 1 QAPD Compliance Matrix American}National Standar-d N18.7-1976/ANS-3.2*0 I NQA-1-2008, NQA-la-2009 ;" 'I ..

SA~dministrativeVControls 'and Quality *Assurance for* Addenda or' .*!"Comments **

Sthe Operational Phase of Nuclear Power; Plants/ ....

Regulatory Guide 1.]33,Rev. 2 Regulatory Positions INEI 11"O4'QAPD*I* .. '

The reviewing organizations shall have access to pertinent NQA-1, Requirement 6 See Requirement 6, paragraph background information upon which to base its approval 301, Major Changes.

and shall have adequate understanding of requirements and intent of the original document.

Those participating in any activity shall be made aware of, QAPD, Part II, Section 6 and use, proper and current instructions, procedures, drawings, and engineering requirements for performing the activity. Participating organizations shall have procedures for control of the document and changes thereto to preclude the possibility or use of outdated or inappropriate documents.

Document control measures shall provide for: NQA-1, Requirement 6 See Requirement 6, paragraph (1) Identification of individuals or organizations responsible QAPD, Part II, Section 6 200, Document Control.

for preparing, reviewing, approving, and issuing documents and revisions thereto (2) Identifying the proper documents to be used in performing the activity (3) Coordination and control of interface documents (4) Ascertaining that proper documents are being used (5) Establishing current and updated distribution lists 5.2.16 Measuring and Test Equipment.

The method and interval of calibration for each installed NQA- 1, Requirement 12 instrument and control device shall be defined and shall be based on the type of equipment, stability and reliability characteristics, required accuracies and other conditions affecting calibration.

Tools, instruments, testing equipment and measuring NQA- 1, Requirement 12 See Requirement 12, paragraph devices used for measurements, tests and calibration shall 200, Selection and paragraph Appendix 1-56

NEI 11-04A, QAPD Appendix Compliance Matrix1 American National Standard N18. 7-19761ANS-3.2 NQA-1-00,* *NA-la*,-20 Administrative° Controls and :Quality Assurance for Addend oraComent the Operational Phase of Nuclear Power Plants /

Regulatory Guide 1.33, Rev. 2 Regulatory Positions ' NEI 11-04* QAPD. ... = -

be of the proper range and type and shall be controlled, 300, Calibration and Control.

calibrated and adjusted and maintained at specified intervals or prior to use to assure the necessary accuracy of calibrated devices.

When calibration, testing, or other measuring devices are NQA- 1, Requirement 12 See Requirement 12, paragraph found to be out of calibration, an evaluation shall be made 303, Control.

and documented concerning the validity of previous test and the acceptability of devices previously tested from the time of the previous calibration.

If any calibration, testing or measuring device is NQA- 1, Requirement 12 See Requirement 12, paragraph consistently found to be out of calibration, it shall be 302, Control.

repaired or replaced.

It is not the intent of this Standard to imply a need for NQA- 1, Requirement 12 See Requirement 12, paragraph special calibration and control measures on rulers, tape 304, Commercial Devices.

measures, levels and other such devices if normal commercial practices provide adequate accuracy.

Special calibration shall be performed when the accuracy of NQA-1, Requirement 12 See Requirement 12, paragraph either installed or calibrating equipment is questionable. 302, Control Records shall be made and equipment suitably marked to NQA-1, Requirement 12 See Requirement 12, paragraph indicate calibration status. 400, Records.

American National Standard N45.2.4- 1972 shall be applied NQA-1, Part II, Subpart 2.4 NQA-1, Part II Subpart 2.4 to those activities occurring during the operational phase (ANSI/IEEE Std. 336-1985 that are comparable in nature and extent to related IEEE) is equivalent to ANSI activities occurring during construction. [6] N45.2 .4.

NQA-1, Part II, Subpart 2.16 consists of IEEE Std. 498-1985; however, IEEE has withdrawn

______________________________________________________________ this standard. The primary Appendix 1-57

NEI 11-04A, Appendix 1 QAPD Compliance Matrix American National Standard N18. 7-1976/ANS-3 .2 .. *. . .r"..

Administrative Controls and Qaly Assurance fore NQ-1208.... A- a-0... ... ..

°the Operational Phase of Nuclear Power Plants / Addndaor..mmnt Regulatory Guide 1.33, ReV. 2 Re ulatorc Positions ..... NEI 11-04 QAPD

requirements from this standard are included in NQA- 1 Requirement 12.

5.2.17 Inspections.

A program for inspection of activities affecting safety shall NQA- 1, Requirement 10 be established and executed by or for the organization QAPD, Part II, Section 10 performing the activity to verify conformance with applicable documented instructions, procedures, and drawings.

Inspections, examinations, measurements, or tests of NQA- 1, Part II, Subparts 2.1, material, products, or activities shall be performed for each 2.2, 2.3, 2.4, 2.5, 2.8, and 2.15 work operation where necessary to assure quality, establish specific inspections to be performed Such inspections shall be performed by qualified NQA-1, Requirement 10 individuals other than those who performed or directly QAPD, Part II, Section 10 supervised the activity being inspected. Inspection of (Note exemption in the operating activities (work functions associated with normal QAPD.)

operation of the plant, routine maintenance, and certain technical services routinely assigned to the onsite operating organization) may be conducted by second-line supervisory personnel or by other qualified personnel not assigned first-line supervisory responsibility for conduct of the work.

These independent inspections, i.e., those performed by individuals not assigned first-line supervisory responsibility for the conduct of the work, are not intended to dilute or replace the clear responsibility of first-line supervisors for the quality of work performed under their supervision.

Appendix 1-58

NEI 11-04A, Appendix 1 QAPD Compliance Matrix

American National Standard

.. °N18.7-1976/ANS-3.2***

.. .. NQ*.

A-i20,

. . : NQA-l-209NQ..

Administrative Controls and Quality Assurance for Addenda8, oa-00 Co.. ents the Operational Phase of Nuclear Power Plants I *-

i Regulatory.Guide 1.33*R~ev', 2 Regulatory Positionsi ( *i*NEI, 11-04 QAPD" .**ii For modifications and non-routine maintenance, NQA- 1, Requirement 10 See Requirement 10, paragraph inspections shall be conducted in a manner similar 603, Modifications, Repairs and (frequency, type, and personnel performing such Replacements.

inspections) to that associated with construction phase activities (see also Section 5.2.7).

Inspections of safety-related activities shall be performed in NQA- 1, Requirement 10 See Requirement 10, paragraph accordance with approved written procedures, which set 200, Inspection Requirements.

forth the requirements and acceptance limits and specify the inspection responsibilities.

If mandatory inspection hold points are required, the NQA- 1, Requirement 10 See Requirement 10, paragraph specific hold points shall be indicated in appropriate 300, Inspection Hold Points.

documents.

Information concerning inspection shall be obtained from NQA-1, Requirement 10 See Requirement 10, paragraph the related design drawings, specifications and/or other 200, Inspection Requirements.

controlled documents.

When inspection techniques require specialized NQA- 1, Requirement 10 qualifications or skills, personnel performing the inspection NQA- 1, Requirement 2 shall meet applicable licensing requirements, codes, and standards appropriate to the discipline involved (see also Sections 5.2.7, 5.2.6 and 5.3.10).

If inspection is impossible or disadvantageous, indirect NQA-1, Requirement 10 See Requirement 10, paragraph control by monitoring processing methods, equipment and 500, In-process Inspection.

personnel shall be provided.

Both inspection and process monitoring shall be provided NQA-1, Requirement 10 See Requirement 10, paragraph when control is inadequate without both. In cases where 500, In-process Inspection.

documented verification of quality implied by the above requirements is not possible or feasible, the extent of inspection or performance testing to verify adequacy of Appendix 1-59

NEI 11-04A, QAPD ComplianceAppendix Matrix1 American NationalStandard Ni8. 71 976/A1NS-3.2 .. ..= ... ** " *

Administrative Controls and Quality Assurance for NQA1-208 NQ-la-2009 .. .:

the Operational Phatseof Nuclear Power Plants / Addenda": or Comments*

Regulatory Guide 133, Rev. 2 Regulatory Positions' NEI11-O4QAPD.. * ,

structures, systems, or components for service should be, in general, greater than otherwise required.

The owner organization shall evaluate inspection results NQA-1, Requirement 10 along with test results (see Section 5.2.19) to determine NQA-1, Requirement 11 whether the individual inspection and test programs NQA-1, Part II, Subpart 2.18, demonstrate that the plant can be operated safely and as Section 202 designed.

Records shall be kept in sufficient detail to permit adequate NQA- 1, Requirement 10 Inspection records under NQA- 1 confirmation of the inspection program. The person NQA-l, Requirement 11 may be a part of the work recording the data as well as the person approving the documents.

inspection results shall be identified. Deviations, their See Requirement 10, paragraph cause, and any corrective action completed or planned as a 800, Records and Requirement result of the deviations shall be documented. Inspection 11, paragraph 600, Test Records.

records shall be identified as such and shall be retrievable (see also Section 5.2.12).

5.2.18 Control of Special Processes.

Measures shall be established and documented to assure NQA- 1, Requirement 9 See Requirement 9, paragraph that special processes, accomplished under controlled 200, Process Controls conditions in accordance with applicable codes, standards, specifications, criteria, and other special requirements, use qualified personnel and procedures. ______________

Qualification of personnel, procedures, and equipment shall NQA-1, Requirement 9 See Requirement 9, paragraph comply with the requirements of applicable codes and NQA- 1, Requirement 2 201, Special Processes.

standards.

Special processes are those that require interim in process NQA- 1, Requirement 9 controls in addition to final inspection to assure quality QAPD, Part II, Section 9 including such processes as welding, heat treating, chemical cleaning, and nondestructive examination.

Appendix 1-60

NEI 11-04A, QAPD Appendix Compliance Matrix1

!*:the Operational Phiase o*fNuclear :Power Plants:],: I: NH 11-04 QAPD For special processes not covered by existing codes or NQA- 1, Requirement 9 See Requirement 9, paragraph standards, or where item quality requirements exceed the 203, Special Requirements.

requirements of established codes or standards, the necessary qualifications of personnel, procedures, or equipment shall be defined.

5.2.19 Test Control.

A test program shall be established to assure that testing NQA- 1, Requirement 11 required to demonstrate that the item will perform NQA- 1, Part II Subpart 2.18 satisfactorily in service is identified and documented, and establishes programmatic that the testing is performed in accordance with written controls for testing test procedures which incorporate or reference the NQA- 1, Part II Subparts 2.1, requirements and acceptance limits contained in applicable 2.4, 2.5, and 2.8 establish design documents. specific testing requirements that apply to the operational

________________________________________phase The test program shall cover all required tests including: NQA-i, Requirement 10 See Requirement 10, paragraph (1) Tests during the preoperational period to demonstrate NQA-1, Requirement 11 700, Inspections During that performance of plant systems is in accordance with NQA-1, Part II, Subpart 2.4, Operations.

design intent and that the coordinated operation of the ANSI/IEEE Std. 336-1985, See Requirement 11, paragraph plant as a whole is satisfactory, to the extent feasible. Section 7 200, Test Requirements.

(2) Tests during the initial operational phase to NQA- 1, Part II, Subpart 2.8, demonstrate the performance of systems that could not be Section 500 tested prior to operation and to confirm those physical NQA- 1, Part II, Subpart 2.18, parameters, hydraulic or mechanical characteristics that Section 207 need to be known, but which could not be predicted with QADPatIScin1 the required accuracy, and to confirm that plant behavior QPDPatIScin1 conforms to design criteria. The initial start-up test program shall be planned to permit safe fuel loading and start-up; to increase power in safe increments; and to Appendix 1-61

NEI 11-04A, Appendix 1 QAPD Compliance Matrix American National Standard N18.7-1976/ANS-3.2 NQA-1-2008, NQA-la-2009 Administrative Controls and Quality Assurance for~ Addenda or Comments the Operational Phase of Nuclear Po~wer Plants I NEI 11-04 QAPD RegulatoryGuide_1.33,_Rev._2_RegulatoryPositions _________________________ ___________________________

perform major testing at specified power plateaus. If tests require the variation of operating parameters outside of their normal range, the limits within which such variation is permitted shall be prescribed. Prerequisites and record keeping shall be given attention and the scope of the testing shall demonstrate insofar as practicable that the plant is capable of withstanding the design transients and accidents. The suitability of plant operating procedures should be checked to the maximum extent possible during the preoperational and initial start-up test programs.

Reg. Guide 1.33 - C. Regulatory Position 5.f.

The guidelines (indicated by the verb "should") of ANSI N18.7- 1976/ANS- 3.2 contained in the following sections have sufficient safety importance to be treated the same as the requirements (indicated by the verb "shall") of the standard:

f. Section 5.2.19(2)-The guideline for checking plant operating procedures during the testing program.

[NOTE: The affected "should" word is underlined in the N18.7 excerpt above.]

(3) Surveillance tests during the operational phase to provide assurance that failures or substandard performance do not remain undetected and that the required reliability of safety-related systems is maintained (see Section 5.2.8).

(4) Tests during design, fabrication and construction activities associated with plant maintenance and modifications during the operational phase and the demonstration of satisfactory performance followina plant Appendix 1-62

NEI 11-04A, Appendix 1 QAPD Compliance Matrix Administrative Controls; and Quality AssUrance for Addendao-or

Comments,,

tihe Operationa'l Phase of Nuclear Power Plants÷I *: .....

..... . ....Guide 1.33, Rev. *2 Regulatory Poiton NE 11-0 A.. ..

maintenance and modifications or procedural changes (see Section 5.2.7).

5.2.19.1 Preoperational Tests.______________________________

Preoperational tests are generally performed sequentially NQA-1, Requirement 11. NQA-1, Part II Subpart 2.8 is in accordance with written procedures. NQA- 1, Part II, Subpart 2.4, equivalent to the requirements Procedures should ensure that prerequisite steps for ANSI/IEEE Std. 336-1985, of ANSI N45.2.8 equipment testing, such as completion of necessary Section 7 See Requirement 11, paragraph construction, prior testing, safety precautions, and NQA- 1, Part II, Subpart 2.8, 300, Test Procedures.

measures to preserve equipment status have been or will be paragraph 500 performed (see also Sections 5.2.17 and 5.3.10). QAPD, Part II, Section 11 A detailed prescribed physical inspection of equipment components and facilities should be performed to ensure readiness for operation. Typical items to be covered include cleanliness, lubrication, setting of limit switches, calibration of instruments, and presence of safety devices.

The test procedure should list the checks to be made and include acceptance criteria and reference sources , such as vendor's literature, engineering drawings or plant specifications.

A component test is a functional, operational or performance test of an individual piece of equipment or unit system under prescribed conditions. Typical parameters to be examined are direction of rotation, bearing temperatures, vibration, time delays, and ability to operate with remote and local controls. The procedure should list checks to be made and provide acceptance criteria. Consideration should also be given to providing a run-in period to minimize early failures during operation of the plant.

Appendix 1-63

NEI 11-04A, QAPO Appendix Compliance Matrix1 American National Standard N18.7-1976/ANS-3.2 " * :. ...

Administrative Controls and Quality Assurance for; NQ--08 Q-a20

,*the Operational Phase of Nuclear Power Plants I : Addenda or ,*Comments SReguilatory Guide 1.33, Rev. 2 Regulatory Positions '

NEI: 11-04, QAPD ,* ,**, ,:

Individual system tests establish the functional adequacy by operation under prescribed conditions. The tests shall be designed to permit evaluation of system performance including, for example, the measurement of flow, temperature, pressure, response time and vibration, transfer of power supply to emergency power and accuracy and response of control devices.

The preoperational testing program should demonstrate, as nearly as can be practicably simulated, the overall integrated operation of the plant systems at rated conditions, including simultaneous operation of auxiliary systems. It may be necessary to defer portions of these tests until nuclear heat is available.

The procedures used should be similar to those discussed in 5.3.3 and 5.3.4, and they should be modified to require variation in control parameters, such as pump stops and restarts, cycling valves and varying flows so that system performance can be evaluated. For additional requirements in matters relating to preoperational test programs, American National Standard N45.2.8-1975 is generally applicable. [8]

Reg. Guide 1.33 - C. Regulatory Position 5.g.

The guidelines (indicated by the verb "should") of ANSI N18.7- 1976/ANS-3.2 contained in the following sections have sufficient safety importance to be treated the same as the requirements (indicated by the verb "shall") of the standard:

g. Section 5.2.19.1-The guidelines for preoperational tests,_except the guideline that refers to a run-in period_________________

Appendix 1-64

NEI 11-04A, QAPO Appendix Compliance Matrix1 American National Standard Ni18.7-1976/ANS-3.2 '.

Administrative Controls and Quality'Assurance for N Adde08,nQAda-2009Cmmnt the Operational.Phase. of Nuclear Power Plants /I*** ,

RegulatorY Guide 1.33, Rev. *2 RegulatoryPositions: INEI!I1-04 QAPD!

for equipment. In addition to these guidelines, the prerequisite steps for each equipment test should be completed prior to the commencement of the preoperational test.

[NOTE: The affected "should" words are underlined in the N18.7 excerpt above.]

5.2.19.2 Tests Prior to and During initial Plant Operation._____________

Prior to placing a nuclear power plant into operation, a NQA-1, Requirement 11, preoperational test program shall be performed to NQA-1, Part II, Subpart 2.8, demonstrate the functional adequacy of plant components, paragraph 500 systems and structures. Following fuel loading an initial QAPD, Part II, Section 11 start-up test program shall be conducted to evaluate plant performance as the start-up progresses.

Responsibilities The ultimate responsibility for the preparation and QAPD, Part II, Section 1 execution of adequate preoperational and initial start-up test programs rests with the owner organization. If design or construction is performed by other than the owner organization, design organizations involved should participate in definition of the programs, and the construction organization involved may supply manpower or supervision for execution of part or all of the program, but the owner organization shall determine that the program is adequate and that the results are satisfactory.

Scheduling A schedule shall be provided and maintained to provide QAPD, Part II, Section 11 assurance that all necessary tests are performed and_________________________________

Appendix 1-65

NEI 11-04A, QAPD Appendix Compliance Matrix1 American National Standard N18.7-19761ANS-3.2 NAi*0iQ=a20 ;:!

Administrative Controls and Quality Assurance for NQAdde08,nQd-a-2009Cmmnt the Operational Phase of Nuclear Power PlantsIAde aorCm nt Regulatory.Guide 1.33, Rev. 2 Regulatory Positions ' NEI 11-04 QAPD:* ,, . ... ;*

properly evaluated on a timely basis. Testing shall be scheduled so that the safety of the plant is never dependent on the performance of an untested system (see also Section 5.2.8).

5.2.19.3 Tests Associated with Plant Maintenance, Modifications or Procedure Changes._____________________________

Tests shall be performed following plant modifications or NQA-l, Requirement 11 See Requirement 11, paragraph significant changes in operating procedures to confirm that NQA-1, Part II, Subpart 2.18, 200, Test Requirements.

the modifications or changes reasonably produce expected paragraph 200 results and that the change does not reduce safety of QAPD, Part II, Section 11 operations.

5.3 Preparation of Instructions and Procedures.

The administrative controls and quality assurance program NQA- 1, Requirement 5 shall be carried out throughout plant life in accordance QAPD, Part II, Section 5; Part with written procedures. Activities affecting safety at V, Section 3 nuclear power plants shall be described by written procedures of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions and procedures.

Reg. Guide 1.33 - Regulatory Position C, Item 1 ANSI N18.7-1976/ANS-3.2 requires the preparation of many procedures to carry out an effective quality assurance program. Appendix A, "Typical Procedures for Pressurized Water Reactors and Boiling Water Reactors," to this regulatory guide should be used as guidance to ensure minimum procedural coverage for plant operating activities, including related maintenance activities. Appendix A lists typical safety-related activities that should be covered by written _______________ ________________

Appendix 1-66

NEI 11-04A, Appendix QAPD Compliance Matrix1 American National.

Administrative Standard Controls N18.7-1976/ANS-3.2 NQA-I-2008, NQA-la-2009 and Quality Assurance for* Adedao omet the Operational Phase of Nuclear Power Plants !I ded r..Cmet Regula'tory Guide 1.33, Rev. 2 Regulatory Positions . N..... 11-04QAP procedures but does not provide a complete listing of needed procedures. Many other activities carried out during the operation phase of a nuclear power plant require written procedures not included in Appendix A.

Appendix A may also contain procedures that are not applicable to an applicant because of the configuration of the nuclear power plant. The procedures listed in Appendix A may be combined, separated, or deleted to conform to the applicant's procedures plan.

These procedures shall include appropriate quantitative or NQA- 1, Requirement 5 qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.

These procedures shall provide an approved preplanned method of conducting operations. Procedures shall be prepared and approved prior to implementation as required by 4.3 and 5.2.15.

5.3.1 Procedure Scope.____________________________

Each procedure shall be sufficiently detailed for a qualified QAPD, Part V, Section 3 individual to perform the required function without direct supervision, but need not provide a complete description of the system or plant process.__________________

5.3.2 Procedure Content. ______________

The format of procedures may vary from plant to plant, QAPD, Part V, Section 3 depending on the policies of the owner organization.

However, procedures shall include, as appropriate, the following elements:

(1) Title. Each procedure should contain a title descriptive QAPD, Part V, Section 3.1 of the work or system or unit to which it applies, a revision _________________________________

Appendix 1-67

NEI 11-04A, QAPD Appendix Compliance Matrix1 Amjerican National Standar N187. NS3 ....

Administrative Contr'ols oand Quality ;*;i*.J*L;Addendaoror Comments;*,*

*t the Operatio)nal Phase* of zNuclear Poiver"Plants/' INI"'" ; .. ;

.Regulatoy

. ..... Gie133, :Rev>2 regulatory Positions .. NEI 11-04 A"PD* ° number or date, and an approval status.

(2) Statement of Applicability. The purpose for which the QAPD, Part V, Section 3.1 procedure is intended should be clearly stated; for example, for use during reactor or plant start-up. If the purpose is not clear from the title, a separate statement of applicability should be provided, which may identify the reasons for particular operations.

(3) References. References, including reference to technical NQA- 1, Introduction to Part specifications, should be included in procedures as II, applicable. References should be identified within the body NQA- 1, Part II, Subpart 2.18, of procedures when the sequence of steps requires other paragraph 202 tasks to be performed prior to or concurrent with a QAPD, Part V, Section 3.1 particular step within that task.

(4) Prerequisites. Each procedure should identify those NQA- 1, Introduction to Part independent actions or procedures which shall be II, NQA- 1, Part II, Subpart completed and plant conditions which shall exist prior to its 2.18, paragraph 202 use. Prerequisites applicable only to certain sections of a QAPD, Part V, Section 3.1 procedure should be so identified.

(5) Precautions. Precautions should be established to alert NQA- 1, Introduction to Part the individual performing the task to those important II, NQA- 1, Part II, Subpart measures which should be used to protect equipment and 2.18, paragraph 202 personnel, including the public, or to avoid an abnormal or QAPD, Part V, Section 3.1 emergency situation. It may be convenient to specify precautions separately. Cautionary notes applicable to specific steps in the procedure should be included in the main body of the procedure and should be identified as such.

(6) Limitations and Actions. Limitations on the parameters QAPD, Part II, Section 5 being controlled and appropriate corrective measures to Appendix 1-68

NEI 11-04A, QAPD Appendix Compliance Matrix1 American National Standard N18. 7-.19761ANS-3.2

!Administrati~ve Controls and Quality Assurance for" NQ-- 8 NddAnda-o 2.0o0et ..

Sthe Operational Phase of Nuclear power Plants / Addenda-0 oADr Comments Regulatory Guide 1.33, Rev. 2 Regulatory Positions NE 104QP return the parameter to the normal control band should be QAPD, Part V, Section 3.1 specified. It may be convenient to specify limitations and setpoints in a separate section. Where appropriate, quantitative control guides should be provided; for example, an appropriate step of a procedure should say "Manually adjust the feedwater flow controller to maintain the reactor water level at x feet," rather than "Manually adjust the feedwater flow to maintain water level."

(7) Main Body. The main body of a procedure should NQA- 1, Introduction to Part II contain step-by-step instructions in the degree of detail NQA- 1, Part II Subpart 2.18, necessary for performing a required function or task. paragraph 202 QAPD, Part V, Section 3.1 (8) Acceptance Criteria. Procedures should contain, where NQA-1, Introduction to Part II applicable, acceptance criteria against which the success or NQA- 1, Part II, Subpart 2.18, failure of test-type activity would be judged. In some cases paragraph 202 there would be qualitative criteria, i.e., a given event does QAPD, Part V, Section 3.1 or does not occur. In other cases quantitative values would be designated.

Appendix 1-69

NEI 11-04A, Appendix 1 QAPD Compliance Matrix American National Standard N18.7-1976/ANS-3.2 ** NQA-1-20)08, NAla--2009' Administrative, Controls and Quality Assurance' for Addenda or ... '.... Comments';

,the Operational Phase of Nuclear Power Plants / ~ 1-4QP Regulatory Guide 1.33, RevW 2 Regulatory Positions *NI1-4QP ,* ° . ..

(9) Checkoff Lists. Complex procedures should have NQA- 1, Introduction to Part II checkoff lists. These lists may be included as part of the NQA-l, Part II Subpart 2.18, procedure or may be appended to the procedure. paragraph 202 Reg. Guide 1.33 - C. Regulatory Position 5.h. QAPD, Part V, Section 3.1 The guidelines (indicated by the verb "should") of ANSI N18.7- 1976/ANS-3.2 contained in the following sections have sufficient safety importance to be treated the same as the requirements (indicated by the verb "shall") of the standard:

h. Section 5.3.2-The guidelines that describe the content (excluding format) of procedures, except for the guidelines that address (1) a separate statement of applicability in Section 5.3.2(2), (2) inclusion of references in procedures, as applicable, in Section 5.3.2(3), and (3) inclusion of quantitative control guides in Section 5.3.2(6).

[NOTE: The affected "should" words are underlined in the N18.7 excerpts above.]

5.3.3 System Procedures.

Instructions for energizing, filling, venting, draining, QAPD, Part V, Section 3.2 starting up, shutting down, changing modes of operation and other instructions appropriate for operations of systems related to the safety of the plant shall be delineated in system procedures. Procedures for correcting off-normal conditions shall be developed for those events where system complexity may lead to operator uncertainty.

System procedures shall contain checkoff lists where appropriate._____________________________

Appendix 1-70

NEI 11-04A, Appendix 1 QAPD Compliance Matrix American National Standard N18.7-1976/ANS-3.21*

Administrative Controls and Quality Assurance for NQA-1.2008, NQA-la,2009 [): i****-

... . ** Addenda or * : ' comments the Operational phase of Nuclear Power Plants/~ E 1-4QP Regulatory Guide. 1.33, Rev. 2 Regulatory Pos;itions NI1-4QP 5.3.4 General Plant Procedures.

General plant procedures provide instructions for the QAPD, Part V, Section 3.2 integrated operations of the plant. In addition to the characteristics of procedures presented in 5.3.1 and 5.3.2, details concerning specific general plant procedures are emphasized in the following sections.

5.3.4.1 Start-up Procedures.

Start-up procedures shall be provided that include starting QAPD, Part V, Section 3.2 the reactor from cold or hot conditions and establishing power operation, with the generator synchronized to the line. Recovery from reactor trips shall be in accordance with the start-up procedure and shall be subject to the determinations set forth in 5.2.1.

(1) Prerequisites. Start-up procedures shall include provisions for documented determination that prerequisites have been met, including confirmation that necessary instruments are operable and properly set; valves are properly aligned; necessary systems procedures, tests and calibrations have been completed; and required approvals have been obtained. Checkoff lists are normally used for this purpose.

(2) Main Body. The main body of the start-up procedures shall include the major steps of the start-up sequence, including reference to appropriate system procedures. Such major steps shall include or reference detailed instructions for their performance, for example, minimum instrumentation requirements coverage of control rod withdrawal sequence or soluble poison dilution, manipulation of controls, establishment of feed and steam Appendix 1-71

NEI 11-04A, Appendix 1 QAPD Compliance Matrix American National* Standard N18, 7-1976/ANS-.3.2 NQA-1-_0....NQA..... -

Administrative Controls and Qualit~yAssurance for* N Addenda*,.* or Co9mments * ..

the Operational Phase of Nuclear Power Plants/ NE(10 AD. ... :

SRegulatory*Guide 1.33, Rev. 2 Regulatory Positions .... QAPD .1.04.

flow and turbine start-up and synchronization. Checkoff lists should be used for the purpose of confirming completion of major steps in proper sequence.

5.3.4.2 Shutdown Procedures.

Shutdown procedures shall be provided to guide operations QAPD, Part V, Section 3.2 during and following controlled shutdown or reactor trips and shall include instructions for establishing or maintaining hot standby or cold shutdown conditions, as applicable. The major steps involved in shutting down the plant shall be specified, including detailed instructions for the performance of such actions as monitoring and controlling reactivity, load reduction and cooldown rates, sequence of activating or deactivating equipment, requirements for prompt analyses of causes of reactor trips or abnormal conditions requiring unplanned controlled shutdowns, and provisions for decay heat removal. Checkoff lists should be used for the purpose of confirming completion of major steps in proper sequence.

5.3.4.3 Power Operation and Load Changing Procedures.

Procedures for steady-state power operation and load QAPD, Part V, Section 3.2 changing shall be provided that include, for example, provisions for use of control rods, chemical shim, coolant flow control or any other system available for long-or-short term control of reactivity, making deliberate load changes, respornding to unanticipated load changes and adjusting operating parameters.

Appendix 1-72

NEI 11-04A, QAPD Appendix Compliance Matrix1 American National Standard N18. 7-1 976/ANS-3.2 NQ-208NAla09 Administrative Controls and Quality Assurance for N Addenda8 orA-Comments the Operational Phase of Nuclear Power Plants I

_Regulatory Guide 1.33, Rev. 2 Regulatory Positions NI1-4QP 5.3.4.4 Process Monitoring Procedures._______________

Procedures for monitoring performance of plant systems QAPD, Part V, Section 3.2 shall be required to assure that core thermal margins and coolant quality are maintained at all times, that integrity of fission product barriers is maintained at all times and that engineered safety features and emergency equipment are in a state of readiness to maintain the plant in a safe condition if needed. The limits (maximum and minimum) for significant process parameters shall be identified. The nature and frequency of this monitoring shall be covered by operating procedures, as appropriate.

5.3.4.5 Fuel-Handling Procedures.

Fuel-handling operations shall be performed in accordance QAPD, Part V, Section 3.2 with written procedures. These procedures shall specify actions for core alterations, accountability of fuel and partial or complete refueling operations that include, for example, continuous monitoring of the neutron flux throughout core loading, periodic recording of data, audible annunciation of abnormal flux increases and evaluation of core neutron multiplication to verify the safety of loading increments.

Provisions shall be made for preparing specific procedures for each refueling outage and for receipt and shipment of fuel. Plant procedures should, nonetheless, prescribe the general preplanning for the fuel-handling program and its associated safety measures and should identify those aspects of the program for which procedures are to be prepared for each refueling outage.

_(1) Prerequisites. Prerequisites shall be provided in the__________________

Appendix 1-73

NEI 11-04A, QAPD Appendix Compliance Matrix1 American National Standard N18.7-1976/ANS-3.2 NA-208NAla09 Administrative Controls and Quality Assurance forAdeaorCm nt the Operational Phase of Nuclear Power Plants /IE 1-4QP Regulatory Guide 1.33, Rev. 2 Regulatory Positions NI1-4QP fuel-handling procedures that include, for example, the status of plant systems required for refueling; inspection of replacement fuel, control rods, poison curtains and internals; designation of proper tools; proper conditions for spent fuel movement; proper conditions for fuel cask loading and movement; and status of interlocks, reactor trip circuits and mode switches.

(2) Main Body. The main body of fuel handling procedures shall include requirements for refueling; for example, the status of the core , instructions for proper sequence, orientation, and seating of fuel and components, rules for minimum operable instrumentation, actions to be followed in the event of fuel damage, rules for periods when refueling is interrupted, verification of the shutdown margin and the frequency of determination, communications between control room and the fuel loading station, independent verification of fuel and component location, criteria for stopping refueling and for reducing the size of the fuel loading increment, and a containment evacuation plan and its associated safety measures.

Documentation of final fuel and component serial numbers and locations shall be maintained.

5.3.5 Maintenance Procedures.

Maintenance procedures shall contain applicable items NQA- 1, Part II, Subpart 2.18, listed under 5.3.2 and, in addition, measures to cover the paragraph 200 features of maintenance described below. QAPD, Part V, Section 3.2 (1) Preparation for Maintenance. Maintenance procedures shall reflect considerations listed under 5.2.6. Adherence to applicable radiation protection measures shall be prescribed. These measures shall specify protective clothing__________________

Appendix 1-74

NEI 11-04A, Appendix 1 QAPD Compliance Matrix American National Standard Ni18.7-1 976/ANS-3.2 NA--0,NAl-29 Administrative Controls and Quality Assurance for N Add-2 nda orAComments the Operational Phase of Nuclear Power Plants I

_Regulatory Guide 1.33, Rev. 2 Regulatory Positions NE 104QP and radiation monitoring needed to assure safety.

(2) Performance of Maintenance. The procedures shall contain enough detail to permit the maintenance work to be performed correctly and safely, and shall include provisions for conducting and recording results of required tests and inspections. References should be made to vendor manuals, plant procedures, drawings and other sources as applicable.

(3) Post Maintenance Check Out and Return to Service.

Instructions shall be included, or referenced, for returning the equipment to its normal operating status.

(4) Supporting Maintenance Documents. Where appropriate sections of related documents, such as vendor manuals, equipment operating and maintenance instructions, or approved drawings with acceptance criteria provide adequate instructions to assure the required quality of work, the applicable sections of the related documents shall be referenced in the procedure, or may, in some cases, constitute adequate procedures in themselves.

Such procedures shall receive the same level of review and approval as operating procedures.

5.3.6 Radiation Control Procedures.

Procedures shall be provided for implementation of a QAPD, Part V, Section 3.2 radiation control program to meet applicable program requirements. The radiation control program involves the acquisition of data and provision of equipment to perform necessary radiation surveys, measurements and evaluations for the assessment and control of radiation hazards associated with a nuclear power plant. Procedures shall be developed and implemented for: monitoring both Appendix 1-75

NEI 11-04A, Appendix 1 QAPD Compliance Matrix American National Standard Ni18. 7-1976/ANS-3.2 NA1-0,NAl-29 Administrative Controls and Quality Assurance for N Addenda8 orAComments the Operational Phase of Nuclear Power Plants /

Regulatory Guide 1.33, Rev. 2 Regulatory PositionsNH1-4QP external and internal exposures of employees, utilizing accepted techniques; routine radiation surveys of work areas; environmental monitoring in the vicinity of the plant; radiation monitoring of maintenance and special work activities; and for maintaining records demonstrating the adequacy of measures taken to control radiation exposures of employees and others.

5.3.7 Calibration and Test Procedures.

Procedures shall be provided for periodic calibration and QAPD, Part V, Section 3.2 testing of safety-related instrumentation and control systems. Procedures shall also be provided for periodic calibration of measuring and test equipment used in activities affecting the quality of these systems. The procedures shall provide for meeting surveillance schedules and for assuring measurement accuracy adequate to keep safety-related parameters within operational and safety limits.

5.3.8 Chemical-Radiochemical Control Procedures.

Procedures shall be provided for chemical and QAPD, Part V, Section 3.2 radiochemical control activities. They should include, for example, the nature and frequency of sampling and analyses; instructions for maintaining coolant quality within prescribed limits; and limitations on concentrations of agents that could cause corrosive attack, foul heat transfer surfaces or become sources of radiation hazards due to activation. Procedures shall also be provided for the control, treatment and management of radioactive wastes and control of radioactive calibration sources.

Appendix 1-76

NEI 11-04A, Appendix I QAPD Compliance Matrix American National Standard N18. 7-1976/ANS-3 .2 NA120,NA-a20 Administrative Controls and Quality Assurance for N Addenda8 orAComment9 the Operational Phase of Nuclear Power Plants /

Regulatory Guide 1.33, Rev. 2 Regulatory Positions NI1-4QP 5.3.9 Emergency Procedures._____________________________

Procedures shall be provided to guide operations during QAPD, Part V, Section 3.2 Requirements for Emergency potential emergencies. They shall be written so that a Procedures have been updated trained operator will know in advance the expected course through the years through of events that will identify an emergency and the industry initiatives and lessons immediate action he should take. Since emergencies may learned.

not follow anticipated patterns, the procedures should provide sufficient flexibility to accommodate variations.

Emergency procedures that cover actions for manipulations of controls to prevent accidents or lessen their consequences should be based on a general sequence of observations and actions. Emphasis should be placed on operator responses to observations and indications in the control room; that is, when immediate operator actions are required to prevent or mitigate the consequences of a serious condition, procedures should, require that those actions be implemented promptly. The emergency procedure format given in 5.3.9.1 provides a basis for coping with emergencies and is an acceptable format for prescribing operator observations and actions.

Emergency procedures may contain supplemental background information to further aid operators in taking proper emergency actions, but this information shall be separated from the procedural actions. It is extremely difficult to distinguish between procedures prepared for the purpose of correcting off-normal conditions which in themselves do not constitute actual emergency situations, but which conceivably can degenerate into true emergencies in the absence of positive corrective action, and procedures required for coping with true emergencies Appendix 1-77

NEI 11-04A, QAPD Appendix Compliance Matrix1 American National Standard N18. 7-1976/ANS-3.2 NA-20,NAla00 Administrative Controls and Quality Assurance for N Addenda8 orQJ-Comment the Operational Phase of Nuclear Power Plants/IEI 11-04 QAPD Regulat~ory Guide 1.33, Rev. 2 Regulatory Positions 4 that have already occurred. Some owner organizations choose the term "Off-normal Procedures" for the same purpose that others choose "Emergency Procedures." When initially available intelligence provided to operating personnel via instrument readings, physical conditions, and personal observations may not clearly indicate the difference between a simple operational problem and a serious emergency, the actions outlined in the emergency procedures shall be based on a conservative course of action by the operating crew. Considerable judgment on the part of competent personnel is required before departing from the emergency procedure.

Reg. Guide 1.33 - C. Regulatory Position 5.i.

The guidelines (indicated by the verb "should") of ANSI N18.7- 1976/ANS-3.2 contained in the following sections have sufficient safety importance to be treated the same as the requirements (indicated by the verb "shall") of the standard:

i. Section 5.3.9-The guideline concerning emergency procedures requiring prompt implementation of immediate operator actions when required to prevent or mitigate the consequences of a serious condition.

[NOTE: The affected "should" words are underlined in the N18.7 excerpt above.]

-~ 1-5.3.9.1 Emergency Procedure Format and Content.

Emergency procedures shall include, as appropriate, the QAPD, Part V, Section 3.2 Requirements for Emergency following elements: Procedures have been updated (1) Title. The title should be descriptive of the emergency through the years through

______________________________________________________________ ____________ndustry_____initiativesndutryiniiatvesandleson Appendix 1-78

NEI 11-04A, Appendix 1 QAPD Compliance Matrix American National Administrative Standard Controls N18. 7-1976/ANS-3.2 and Quality Assurance for INQ-20,NAl-09 N Addenda8 orAComments the Operational Phase of Nuclear Power Plants/ NEI104Q Regulatory Guide 1.33, Rev. ~2 Regulatory Positions NI1-4QP for which the procedure is provided. learned.

(2) Symptoms. Symptoms should be included to aid in the identification of the emergency. They should include alarms, operating conditions and probable magnitudes of parameter changes. If a condition is peculiar only to the emergency under consideration, it should be listed first.

(3) Automatic Actions. The automatic actions that will probably occur as a result of the emergency should be identified.

(4) Immediate Operator Actions. These steps should specify immediate actions for operation of controls or confirmation of automatic actions that are required to stop the degradation of conditions and mitigate their consequences.

Examples include the following:

(a) The verification of automatic actions. This step is based on equipment operating as designed and the sequence of events following an expected course. Since variations from the expected course may occur, operators should be prepared to manipulate controls as necessary to cope with the problem. However, the procedure should caution the operator not to place systems in "manual" unless misoperation in "automatic" is apparent, and should require him to make frequent checks for proper operation of systems placed in manual control.

(b) Assurance that reactor is in a safe condition. This step usually means shutdown of the reactor with sufficient reactivity margin and establishment of required core cooling.

(c) Notification to plant personnel of the nature of the_________________

Appendix 1-79

NEI 11-04A, QAPD Appendix Compliance Matrix1 American National Standard N18. 7-1 976/ANS-3.2 NA-208NQ la09 Administrative Controls and Quality Assurance for N Addenda8 orAComments the Operational Phase of Nuclear Power Plants /IE 1-4QP

_Regulatory Guide 1.33, Rev. 2 Regulatory Positions NE 104QP emergency.

(d) Determination that the reactor coolant system pressure boundary is intact.

(e) Confirmation of the availability of adequate power sources.

(I) Confirmation that containment and exhaust systems are operating properly in order to prevent uncontrolled release of radioactivity.

(5) Subsequent Operator Actions. Steps should be included to return the reactor to a normal condition or to provide for a safe extended shutdown period under abnormal or emergency conditions.

Reg. Guide 1.33 - C. Regulatory Position 5.j.

The guidelines (indicated by the verb "should"1 ) of ANSI N 18.7- 1976/ANS- 3.2 contained in the following sections have sufficient safety importance to be treated the same as the requirements (indicated by the verb "shall") of the standard:

j. Section 5.3.9.1-The guidelines that describe the content (excluding format) for: the title in Section 5.3.9.1(1); the inclusion of symptoms to aid in identification in Section 5.3.9.1(2); automatic actions in Section 5.3.9.1(3); immediate operator action, excluding those guidelines contained in the examples, in Section 5.3.9.1(4); and subsequent operator actions in Section 5.3.9.1(5).

[NOTE: The affected "should" words are underlined in the N18.7 excerpt above.]

Appendix 1-80

NEI 11-04A, QAPD ComplianceAppendix 1 Matrix American National Standard Ni18. 7-1976/ANS-3.2 NQA-1-2008, NQA-la-2009 Administrative Controls and Quality Assurance forAde aorCm nt the Operational Phase of Nuclear Power Plants /IE 1-4QP Regulatory Guide 1.33, Rev. 2 Regulatory Positions NE 1-0 QP 5.3.9.2 Events of Potential Emergency.

Potential emergency conditions shall be identified and QAPD, Part V, Section 3.2 The list contained in N18.7 is procedures for coping with them shall be prepared. The provided as examples and is not following categories of events may, depending upon the stated in the QAPD. NRC design of the plant, be considered as examples of potential regulatory guidance and the emergencies for which procedures are written and for which applicable facility SAR and immediate action is indicated: Emergency Plans will provide (1) Loss of coolant from identified and unidentified sources, the basis for what procedures from small loss to design-basis-accident loss are necessary.

(2) Reactor transients and excursions (3) Failure of vital equipment (4) Loss or degradation of vital power sources (5) Civil disturbances (6) Abnormally high radiation levels (7) Excessive release of radioactive liquid or gaseous effluent (8) Malfunction of reactivity control system (9) Loss of containment integrity (10) Conditions that require use of standby liquid poison systems (11) Possible natural occurrences (12) Fires 5.3.9.3 Procedures for Implementing Emergency Plan. ___________

Implementing procedures for emergency plan actions shall QAPD, Part V, Section 3.2 contain, as appropriate, the following elements:

(1) Individual assignment of authorities and responsibilities for performance of specific tasks to specific Appendix 1-81

NEI 11-04A, Appendix 1 QAPD Compliance Matrix American National Standard N18. 7-1976/ANS-3 .2 NA120,NA-a20 Administrative Controls and Quality Assurance for N Addenda8 orAComment9 the Operational Phase of Nuclear Power Plants I Regulatory Guide 1.33, Rev. 2 Regulatory Positions NI1-4QP individuals or staff positions.

(2) Protective action levels and protective measures outlined for the emergency identified.

(3) Specific actions to be taken by coordinating support groups.

(4) Procedures for medical treatment and handling of contaminated individuals.

(5) Special equipment requirements for items such as medical treatment, emergency personnel removal, specific radiation detection, personnel dosimetry and rescue operations, procedures for making this equipment available, plus operating instructions for such equipment, and provisions for its periodic inspection and maintenance.

(6) Identification of emergency communications network, including communications required for personnel identification and effective coordination of all support groups.

(7) Description of alarm signals in each facility. At sites with multiple units, alarm signals should be consistent from one unit to another. (Signals for initiating protective measures should be clear and distinct from process or operational alarm system to avoid confusion.)

(8) Procedures required to restore the plant to normal conditions following an emergency.

(9) Requirements for periodically testing of procedures, communications network and alarm systems to assure that they function properly. _______________ ________________

Appendix 1-82

v t e Letter Sequence Request
CAC:MF6537, (Open)
Initiation Request Acceptance... Administration Questions 6 January 2016 Answers 29 January 2016 Results Approval... Other: ML16194A323
MONTHYEAR2016-01-29 [Table View]

ML15212A718: Difference between revisions

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RESPONSE

RESPONSE

RESPONSE

RESPONSE

RESPONSE

RESPONSE

References:

RESPONSE

RESPONSE

RESPONSE

RESPONSE

RESPONSE

RESPONSE

RESPONSE

RESPONSE

RESPONSE

Reference:

RESPONSE

RESPONSE

RESPONSE

RESPONSE

RESPONSE

RESPONSE

RESPONSE

RESPONSE

RESPONSE

RESPONSE

RESPONSE

RESPONSE

RESPONSE

RESPONSE

RESPONSE

RESPONSE

RESPONSE

References:

RESPONSE

RESPONSE

RESPONSE

References:

RESPONSE

RESPONSE

RESPONSE

RESPONSE

RESPONSE

References:

RESPONSE

RESPONSE

Reference:

RESPONSE

RESPONSE

RESPONSE

Reference:

RESPONSE

2.0 INTRODUCTION

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