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{{#Wiki_filter:17.2   QUALITY ASSURANCE DURING THE OPERATIONS PHASE 17.
{{#Wiki_filter:17.2 QUALITY ASSURANCE DURING THE OPERATIONS PHASE 17.


==2.0   INTRODUCTION==
==2.0 INTRODUCTION==
 
17.2.0.1 Scope To maintain the high quality of plant systems and equipment during operation, maintenance, repair, modification, and refueling of the Duane Arnold Energy Center (DAEC),
17.2.0.1   Scope To maintain the high quality of plant systems and equipment during operation, maintenance, repair, modification, and refueling of the Duane Arnold Energy Center (DAEC), a comprehensive quality assurance program has been implemented. The objective of this program is to maintain managerial and administrative control over the operations of and activities relative to safety-related structures, systems, equipment, and components during the operating life of the DAEC. This program is designed to meet the intent of Appendix B to 10 CFR Part 50.
a comprehensive quality assurance program has been implemented.
17.2.0.2   Corporate Policy Iowa Electric considers the operation of the DAEC to be an extension of the basic policies established and documented for design, construction, and startup.
The objective of this program is to maintain managerial and administrative control over the operations of and activities relative to safety-related structures, systems, equipment, and components during the operating life of the DAEC.
This program is designed to meet the intent of Appendix B to 10 CFR Part 50.
17.2.0.2 Corporate Policy Iowa Electric considers the operation of the DAEC to be an extension of the basic policies established and documented for design, construction, and startup.
The policies and procedures identified within this report regarding "operating phase" will form the basis for plant-life operation of the DAEC.
The policies and procedures identified within this report regarding "operating phase" will form the basis for plant-life operation of the DAEC.
Where contractors and suppliers are used during the life of the operating DAEC, their function will be controlled by the Operational Quality Assurance Program.
Where contractors and suppliers are used during the life of the operating DAEC, their function will be controlled by the Operational Quality Assurance Program.
It is the objective of Iowa Electric that the DAEC shall be operated effectively, efficiently, and in such a manner as not to jeopardize the health or safety of the public.
It is the objective of Iowa Electric that the DAEC shall be operated effectively, efficiently, and in such a manner as not to jeopardize the health or safety of the public.
17.2.1   ORGANIZATION 17.2.1.1   Scope Iowa Electric has established an operating organization that is structured to support DAEC operating requirements as well as meet corporate needs in other areas.     This overall organization is described in UFSAR Chapter 13, Conduct of Operations, Section 13.1, Organizational Structure for Iowa Electric.       The organization chart, which identifies both the "on-site" and           "off-site" organizational elements that function under the cognizance of the quality assurance program, appears as Figure 13.1-1, Iowa Electric Corporate Organization. Chapter 13 describes the quality assurance responsibilities of each of the organizational elements noted on the organization chart.
17.2.1 ORGANIZATION 17.2.1.1 Scope Iowa Electric has established an operating organization that is structured to support DAEC operating requirements as well as meet corporate needs in other areas.
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This overall organization is described in UFSAR Chapter 13, Conduct of Operations, Section 13.1, Organizational Structure for Iowa Electric.
The organization
: chart, which identifies both the "on-site" and "off-site" organizational elements that function under the cognizance of the quality assurance program, appears as Figure 13.1-1, Iowa Electric Corporate Organization.
Chapter 13 describes the quality assurance responsibilities of each of the organizational elements noted on the organization chart.
17.2-1 Revision 14 To be determined 9307210065 930630 1
PDR ADOCK 05000331 P
PDR


Additional detail concerning the Quality Assurance Department is presented in Chapter 17.2, Section 17.2.1.2.
Additional detail concerning the Quality Assurance Department is presented in Chapter 17.2, Section 17.2.1.2.
The responsibility and authority for the establishment and execution of the Operational Quality Assurance Program for the operation of the DAEC will be retained by Iowa Electric.
The responsibility and authority for the establishment and execution of the Operational Quality Assurance Program for the operation of the DAEC will be retained by Iowa Electric.
17.2.1.2   Manager, Corporate Quality Assurance The Manager, Corporate Quality Assurance reports to the Vice President - Nuclear and is assigned the primary responsibility for ensuring that quality requirements relative to the safe operation of the DAEC are identified and met.
17.2.1.2 Manager, Corporate Quality Assurance The Manager, Corporate Quality Assurance reports to the Vice President - Nuclear and is assigned the primary responsibility for ensuring that quality requirements relative to the safe operation of the DAEC are identified and met.
Fulfilling the responsibilities of the Corporate Quality Assurance Department requires significant communication with the DAEC, the Outage Manager, the Nuclear Licensing Department, the Emergency Planning Department, the Nuclear Fuels Group, the Engineering Department, the Training Department, and the Purchasing Department.
Fulfilling the responsibilities of the Corporate Quality Assurance Department requires significant communication with the DAEC, the Outage Manager, the Nuclear Licensing Department, the Emergency Planning Department, the Nuclear Fuels Group, the Engineering Department, the Training Department, and the Purchasing Department.
The Manager, Corporate Quality Assurance is responsible for preparing and maintaining the Operational Quality Assurance Program.
The Manager, Corporate Quality Assurance is responsible for preparing and maintaining the Operational Quality Assurance Program.
The Manager, Corporate Quality Assurance is also responsible for evaluating the effectiveness of the Operational Quality Assurance Program and issuing periodic reports to the appropriate levels of management.
The Manager, Corporate Quality Assurance is also responsible for evaluating the effectiveness of the Operational Quality Assurance Program and issuing periodic reports to the appropriate levels of management.
The Manager, Corporate Quality Assurance provides support to the Safety Committee.
The Manager, Corporate Quality Assurance provides support to the Safety Committee.
17.2.1.2.1   Quality Assurance Procurement Supervisor The Quality Assurance Procurement Supervisor reports to the Manager, Corporate Quality Assurance and, along with the Quality Control Supervisor and the Quality Assurance Assessment Supervisor, is responsible for verifying that the Operational Quality Assurance Program is being implemented effectively at the DAEC and other locations in support of the DAEC.
17.2.1.2.1 Quality Assurance Procurement Supervisor The Quality Assurance Procurement Supervisor reports to the
: Manager, Corporate Quality Assurance and, along with the Quality Control Supervisor and the Quality Assurance Assessment Supervisor, is responsible for verifying that the Operational Quality Assurance Program is being implemented effectively at the DAEC and other locations in support of the DAEC.
The Quality Assurance Procurement Supervisor provides quality assurance support for the procurement of materials and equipment.
The Quality Assurance Procurement Supervisor provides quality assurance support for the procurement of materials and equipment.
Procurement   activities   include   audits,   surveillances,   and evaluations of suppliers and contractors for quality capabilities and performance; and maintaining the list   of approved suppliers for nuclear procurements. Procedures for implementation of these functions are prepared and maintained by the Quality Assurance         <
Procurement activities include
Procurement Supervisor.
: audits, surveillances, and evaluations of suppliers and contractors for quality capabilities and performance; and maintaining the list of approved suppliers for nuclear procurements.
17.2-2                     Revision 14 To be determined
Procedures for implementation of these functions are prepared and maintained by the Quality Assurance Procurement Supervisor.
17.2-2 Revision 14 To be determined


The Quality Assurance Procurement Supervisor is assisted in the implementation of these responsibilities by the Group Leader, Material and Supplier Quality.
The Quality Assurance Procurement Supervisor is assisted in the implementation of these responsibilities by the Group Leader, Material and Supplier Quality.
17.2.1.2.2   Quality Assurance Assessment Supervisor The Quality Assurance Assessment Supervisor reports to the Manager, Corporate Quality Assurance and is responsible for evaluating the effectiveness of the Operational Quality Assurance Program through the implementation of the internal audit and surveillance programs; for the implementation of the corrective action and trending program; coordinating the review of divisional procedures that are responsive to the requirements of this Operational Quality Assurance Program; and for the preparation and maintenance of the procedures for which this position is responsible.
17.2.1.2.2 Quality Assurance Assessment Supervisor The Quality Assurance Assessment Supervisor reports to the Manager, Corporate Quality Assurance and is responsible for evaluating the effectiveness of the Operational Quality Assurance Program through the implementation of the internal audit and surveillance programs; for the implementation of the corrective action and trending program; coordinating the review of divisional procedures that are responsive to the requirements of this Operational Quality Assurance Program; and for the preparation and maintenance of the procedures for which this position is responsible.
The Quality Assurance Assessment Supervisor is assisted in these duties by the Group Leader, Audits, and Group Leader, Surveillance.
The Quality Assurance Assessment Supervisor is assisted in these duties by the Group Leader, Audits, and Group Leader, Surveillance.
17.2.1.2.3   Quality Control Supervisor The Quality Control Supervisor reports to the Manager, Corporate Quality Assurance and, along with the Quality Assurance Procurement Supervisor and the Quality Assurance Assessment Supervisor is responsible for verifying that the Operational Quality Assurance Program is being implemented effectively at the DAEC. The Quality
17.2.1.2.3 Quality Control Supervisor The Quality Control Supervisor reports to the Manager, Corporate Quality Assurance and, along with the Quality Assurance Procurement Supervisor and the Quality Assurance Assessment Supervisor is responsible for verifying that the Operational Quality Assurance Program is being implemented effectively at the DAEC. The Quality  
) Control   Supervisor   reviews   plant   operation,   maintenance, modification, and testing documents for inclusion of adequate quality requirements and for inclusion of inspection, witness and hold points; and provides the necessary support to perform the inspections and tests.       The Quality Control Supervisor is responsible for preparing receiving inspection plans and in performing receiving, in-process, and final inspections.
)
The Quality Control Supervisor is also responsible for the preparation and maintenance of procedures for which the position is   /
Control Supervisor reviews plant operation, maintenance, modification, and testing documents for inclusion of adequate quality requirements and for inclusion of inspection, witness and hold points; and provides the necessary support to perform the inspections and tests.
The Quality Control Supervisor is responsible for preparing receiving inspection plans and in performing receiving, in-process, and final inspections.
The Quality Control Supervisor is also responsible for the preparation and maintenance of procedures for which the position is  
/
responsible.
responsible.
Responsibilities relative to the Ten Year Inservice Inspection Program include performance of the required examinations and evaluation of indications of defects.
Responsibilities relative to the Ten Year Inservice Inspection Program include performance of the required examinations and evaluation of indications of defects.
Additionally, the Quality Control Supervisor is responsible for training the Quality Control group in nondestructive examination (NDE) disciplines and interfacing with the Quality Assurance Training Coordinator on other areas requiring training.
Additionally, the Quality Control Supervisor is responsible for training the Quality Control group in nondestructive examination (NDE) disciplines and interfacing with the Quality Assurance Training Coordinator on other areas requiring training.
The Quality Control Supervisor also supports the DAEC Operations Committee.
The Quality Control Supervisor also supports the DAEC Operations Committee.
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17.2-3 Revision 14 To be determined


17.2.1.2.3.1   Corporate Level III NDE The Corporate Level III NDE reports to the Quality Control Supervisor and is responsible for developing and implementing the NDE program, including providing the necessary training.
17.2.1.2.3.1 Corporate Level III NDE The Corporate Level III NDE reports to the Quality Control Supervisor and is responsible for developing and implementing the NDE program, including providing the necessary training.
17.2.1.2.4   Quality Assurance Training Coordinator The Corporate Quality Assurance Department Training Coordinator reports to the Manager, Corporate Quality Assurance and provides training for the Quality Assurance Department.       In addition, training relative to the Operational Quality Assurance Program is provided to the Nuclear Generation Division.
17.2.1.2.4 Quality Assurance Training Coordinator The Corporate Quality Assurance Department Training Coordinator reports to the Manager, Corporate Quality Assurance and provides training for the Quality Assurance Department.
17.2.1.2.5   Stop Work Authority The Manager, Corporate Quality Assurance has the authority to issue a stop work instruction to the organization that has direct responsibility for the work. Only the Vice President - Nuclear has the authority to overrid e the stop-work instruction.
In addition, training relative to the Operational Quality Assurance Program is provided to the Nuclear Generation Division.
17.2.2   OPERATIONAL QUALITY ASSURANCE PROGRAM 17.2.2.1   Scope Iowa Electric has established an Operational Quality Assurance Program that applies to those structures, systems, and components, that are safety-related and those activities that affect those structures, systems, and components that are safety-related.
17.2.1.2.5 Stop Work Authority The Manager, Corporate Quality Assurance has the authority to issue a stop work instruction to the organization that has direct responsibility for the work.
Safety-related structures, systems, and components are those that ensure the integrity of the reactor coolant pressure boundary, shut down the reactor, and maintain the reactor in a safe shut down
Only the Vice President - Nuclear has the authority to overrid e the stop-work instruction.
* condition, or prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public.
17.2.2 OPERATIONAL QUALITY ASSURANCE PROGRAM 17.2.2.1 Scope Iowa Electric has established an Operational Quality Assurance Program that applies to those structures, systems, and components, that are safety-related and those activities that affect those structures, systems, and components that are safety-related.
17.2.2.2   Basis 10 CFR Part 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, and certain regulatory guides, form the basis for the Operational Quality Assurance Program. Appendix A to UFSAR Chapter 17.2 identifies the particular regulatory guides to which Iowa Electric is committed and which are included in the basis for the Operational Quality Assurance Program.
Safety-related structures, systems, and components are those that ensure the integrity of the reactor coolant pressure boundary, shut down the reactor, and maintain the reactor in a safe shut down condition, or prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public.
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17.2.2.2 Basis 10 CFR Part 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, and certain regulatory guides, form the basis for the Operational Quality Assurance Program.
Appendix A to UFSAR Chapter 17.2 identifies the particular regulatory guides to which Iowa Electric is committed and which are included in the basis for the Operational Quality Assurance Program.
17.2-4 Revision 14 m
To be determined


17.2.2.3   Identification of Safety-Related Structures, Systems, Components and Items The pertinent requirements of the Operational Quality Assurance Program apply to all activities affecting the safety-related functions of those structures, systems, and components that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public. A current list of safety-related structures, systems and components is contained in Section 3.2 of the DAEC Updated Final Safety Analysis Report. This list includes structures, systems, and components identified during the design and construction phase and may be modified as required during operations consistent with their importance to safety.
17.2.2.3 Identification of Safety-Related Structures, Systems, Components and Items The pertinent requirements of the Operational Quality Assurance Program apply to all activities affecting the safety-related functions of those structures, systems, and components that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public.
The list of safety-related structures, systems and components from Section 3.2 of the DAEC Updated Final Safety Analysis Report is further defined in data bases through the assignment of plant specific unique identifiers. These data bases include items in addition to safety-related structures, systems and components and are maintained by the Manager of Engineering.
A current list of safety-related structures, systems and components is contained in Section 3.2 of the DAEC Updated Final Safety Analysis Report.
17.2.2.4   Operational Quality Assurance Program Implementation The implementation of the Operational Quality Assurance Program by Iowa Electric is directed toward the assurance that operating phase activities   and maintenance activities       are   conducted under controlled conditions and in compliance with applicable regulatory requirements, including 10 CFR Part 50, Appendix B.         Management personnel responsible for the conduct of safety related activities are responsible for providing approved procedures before initiating the activity.
This list includes structures, systems, and components identified during the design and construction phase and may be modified as required during operations consistent with their importance to safety.
The Iowa Electric Operational Quality         Assurance     Program is implemented via four levels of documents:
The list of safety-related structures, systems and components from Section 3.2 of the DAEC Updated Final Safety Analysis Report is further defined in data bases through the assignment of plant specific unique identifiers.
* Quality Assurance Manual
These data bases include items in addition to safety-related structures, systems and components and are maintained by the Manager of Engineering.
* Nuclear Generation Division Manual
17.2.2.4 Operational Quality Assurance Program Implementation The implementation of the Operational Quality Assurance Program by Iowa Electric is directed toward the assurance that operating phase activities and maintenance activities are conducted under controlled conditions and in compliance with applicable regulatory requirements, including 10 CFR Part 50, Appendix B.
* Departmental Procedures
Management personnel responsible for the conduct of safety related activities are responsible for providing approved procedures before initiating the activity.
* Departmental Instructions.
The Iowa Electric Operational Quality Assurance Program is implemented via four levels of documents:
17.2.2.4.1   Quality Assurance Manual The Quality Assurance Manual is the highest level internal quality program document that implements UFSAR/DAEC-l Chapter 17.2, Quality Assurance During the Operations Phase.     It is directed to those Iowa   Electric organizations     responsible   for   safety-related activities. The Quality Assurance Manual   presents   upper management philosophy and concepts to the middle management         level, defines organizational responsibilities, and identifies organizational interfaces.
Quality Assurance Manual Nuclear Generation Division Manual Departmental Procedures Departmental Instructions.
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17.2.2.4.1 Quality Assurance Manual The Quality Assurance Manual is the highest level internal quality program document that implements UFSAR/DAEC-l Chapter 17.2, Quality Assurance During the Operations Phase.
It is directed to those Iowa Electric organizations responsible for safety-related activities.
The Quality Assurance Manual presents upper management philosophy and concepts to the middle management level, defines organizational responsibilities, and identifies organizational interfaces.
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17.2.2.4.2   Nuclear Generation Division Manual The Nuclear Generation Division Manual contains procedures that are applicable to more than one department within the division. These divisional procedures provide mechanisms which facilitate the flow of information and documents across departmental lines, and also eliminate the need for separate departmental procedures which address the same subject.
17.2.2.4.2 Nuclear Generation Division Manual The Nuclear Generation Division Manual contains procedures that are applicable to more than one department within the division. These divisional procedures provide mechanisms which facilitate the flow of information and documents across departmental lines, and also eliminate the need for separate departmental procedures which address the same subject.
17.2.2.4.3   Departmental Procedures The Departmental Procedures are organizationally unique documents that describe the activities of each department within Iowa Electric that has responsibilities for the operation, maintenance, or modification of the DAEC. The Departmental Procedures specify how to accomplish a specific activity.
17.2.2.4.3 Departmental Procedures The Departmental Procedures are organizationally unique documents that describe the activities of each department within Iowa Electric that has responsibilities for the operation, maintenance, or modification of the DAEC. The Departmental Procedures specify how to accomplish a specific activity.
17.2.2.4.4   Departmental Instructions The Departmental Instructions are unique to the department and activity for which they have been prepared.             Departmental Instructions provide the specific, detailed information necessary to perform an activity. Departmental Instructions are issued at the discretion of the responsible manager and are not required for all activities.
17.2.2.4.4 Departmental Instructions The Departmental Instructions are unique to the department and activity for which they have been prepared.
17.2.2.5   Control of Iowa Electric Suppliers Iowa Electric may employ the services of architect-engineers, NSSS suppliers, fuel fabricators, constructors, and consultants to augment Iowa Electric capabilities.         These organizations are required to work under a quality assurance program to provide the control of quality activities consistent with the scope of their assigned   work. The   quality   assurance programs   of such organizations are subject to review, evaluation, and acceptance by the Iowa Electric Corporate Quality Assurance Department before the initiation of activities affected by the program.
Departmental Instructions provide the specific, detailed information necessary to perform an activity.
17.2.2.6   Indoctrination and Training The indoctrination, training, and retraining of personnel who participate in safety-related activities are provided in five broad areas:     operator training, quality assurance indoctrination, technical training, radiation safety indoctrination and training, and emergency preparedness training.
Departmental Instructions are issued at the discretion of the responsible manager and are not required for all activities.
The Operator training provided to senior reactor operators and reactor   operators   is under the     cognizance of   the Plant Superintendent - Nuclear and Manager, Nuclear Training.
17.2.2.5 Control of Iowa Electric Suppliers Iowa Electric may employ the services of architect-engineers, NSSS suppliers, fuel fabricators, constructors, and consultants to augment Iowa Electric capabilities.
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These organizations are required to work under a quality assurance program to provide the control of quality activities consistent with the scope of their assigned work.
The quality assurance programs of such organizations are subject to review, evaluation, and acceptance by the Iowa Electric Corporate Quality Assurance Department before the initiation of activities affected by the program.
17.2.2.6 Indoctrination and Training The indoctrination, training, and retraining of personnel who participate in safety-related activities are provided in five broad areas:
operator training, quality assurance indoctrination, technical training, radiation safety indoctrination and training, and emergency preparedness training.
The Operator training provided to senior reactor operators and reactor operators is under the cognizance of the Plant Superintendent -
Nuclear and Manager, Nuclear Training.
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The quality assurance indoctrination provided to Iowa Electric personnel is under the cognizance of the Manager, Corporate Quality Assurance and the Manager, Nuclear Training.
The quality assurance indoctrination provided to Iowa Electric personnel is under the cognizance of the Manager, Corporate Quality Assurance and the Manager, Nuclear Training.
The technical training provided to Iowa Electric engineering personnel is under the cognizance of the Manager of Engineering and     4 the Manager, Nuclear Training. The training may be provided in a number of ways, from self-study courses to formalized courses at the DAEC Training Department and educational institutions.
The technical training provided to Iowa Electric engineering personnel is under the cognizance of the Manager of Engineering and 4
Indoctrination and training provided to Iowa Electric personnel and contract personnel relative to performing work in areas that are potentially hazardous because of radioactivity are under the cognizance of the Radiation Protection Manager and the Manager,         4 Nuclear Training.
the Manager, Nuclear Training. The training may be provided in a number of ways, from self-study courses to formalized courses at the DAEC Training Department and educational institutions.
Indoctrination and training provided to Iowa Electric personnel and contract personnel relative to performing work in areas that are potentially hazardous because of radioactivity are under the cognizance of the Radiation Protection Manager and the Manager, 4
Nuclear Training.
The indoctrination and training provided to Iowa Electric personnel and contract personnel relative to emergency preparedness is under the cognizance of the Manager, Emergency Planning and the Manager, Nuclear Training.
The indoctrination and training provided to Iowa Electric personnel and contract personnel relative to emergency preparedness is under the cognizance of the Manager, Emergency Planning and the Manager, Nuclear Training.
17.2.2.7   Management Review and Audit The status of the Iowa Electric Operational Quality Assurance Program is periodically made known to management.         A periodic report is prepared by the Manager, Corporate Quality Assurance and submitted to the Vice President - Nuclear.
17.2.2.7 Management Review and Audit The status of the Iowa Electric Operational Quality Assurance Program is periodically made known to management.
A periodic report is prepared by the Manager, Corporate Quality Assurance and submitted to the Vice President -
Nuclear.
An annual audit of the Operational Quality Assurance Program is conducted to evaluate the effectiveness of the overall program.
An annual audit of the Operational Quality Assurance Program is conducted to evaluate the effectiveness of the overall program.
Direction for these audits alternates between the Vice President Nuclear and the Safety Committee. The Safety Committee audit is in accordance with the Technical Specifications requirement for a biennial audit of the quality assurance program. These alternating audits complement each other and provide an annual evaluation.
Direction for these audits alternates between the Vice President Nuclear and the Safety Committee.
17.2.3   DESIGN CONTROL 17.2.3.1   Scope The   design,   modification,   addition,   and   replacement   of safety-related structures, systems, and components at the DAEC is controlled to ensure that appropriate measures are implemented and to ensure that "as-built" quality is not degraded.         The plant design   is   defined   by Iowa   Electric,   the NSSS   supplier, architect/engineer, and selected suppliers.     Design drawings and specifications illustrate the general arrangement and details of safety-related structures, systems, and components and define the requirements for ensuring their continuing capability to perform their intended operational or safety design function.
The Safety Committee audit is in accordance with the Technical Specifications requirement for a biennial audit of the quality assurance program.
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These alternating audits complement each other and provide an annual evaluation.
17.2.3 DESIGN CONTROL 17.2.3.1 Scope The
: design, modification,
: addition, and replacement of safety-related structures, systems, and components at the DAEC is controlled to ensure that appropriate measures are implemented and to ensure that "as-built" quality is not degraded.
The plant design is defined by Iowa
: Electric, the NSSS
: supplier, architect/engineer, and selected suppliers.
Design drawings and specifications illustrate the general arrangement and details of safety-related structures, systems, and components and define the requirements for ensuring their continuing capability to perform their intended operational or safety design function.
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Design activities include the correct translation of regulatory requirements and design bases into specifications, drawings, written procedures, and instructions that define the design.
Design activities include the correct translation of regulatory requirements and design bases into specifications, drawings, written procedures, and instructions that define the design.
Design analyses regarding reactor physics, stress, seismic, thermal, hydraulic, radiation, and accident analyses used to produce design output documents are performed when appropriate.
Design analyses regarding reactor physics, stress, seismic, thermal, hydraulic, radiation, and accident analyses used to produce design output documents are performed when appropriate.
Design verification is performed.
Design verification is performed.
Procedures establish requirements, assign responsibilities, and provide control of design activities to ensure performance in a planned, controlled, and orderly manner.
Procedures establish requirements, assign responsibilities, and provide control of design activities to ensure performance in a
17.2.3.2   Design Responsibility The design and engineering effort is the responsibility of the Engineering Department within the Nuclear Generation Division.
planned, controlled, and orderly manner.
Assistance may be provided by other engineering organizations; individuals providing that assistance are required to perform their activities in compliance with the Iowa Electric Operational Quality Assurance Program. The design of nuclear fuel reloads is the responsibility of the Nuclear Fuels Group.
17.2.3.2 Design Responsibility The design and engineering effort is the responsibility of the Engineering Department within the Nuclear Generation Division.
17.2.3.3   Design Criteria Design requirements and changes thereto are identified, documented, reviewed, and approved to ensure the incorporation of appropriate quality standards in design documents.       Design requirements and quality standards are described to an appropriate level of detail in design criteria. Any exception to quality standards will be listed. Criteria for modifications to structures, systems, and components will consider, as a minimum, the design bases described in the UFSAR. All design criteria will be satisfied in the design.
Assistance may be provided by other engineering organizations; individuals providing that assistance are required to perform their activities in compliance with the Iowa Electric Operational Quality Assurance Program.
17.2.3.4   Design Process Controls The organization performing design will have the responsibility for design control unless specified otherwise. The control of design will be specified in procedures.       These procedures will include instructions   for   defining     typical   design   requirements; communicating needed design information across internal and external interfaces; preparing, reviewing, approving, releasing, distributing,   revising,   and   maintaining   design   documents; performing design reviews; and controlling field changes.
The design of nuclear fuel reloads is the responsibility of the Nuclear Fuels Group.
17.2.3.3 Design Criteria Design requirements and changes thereto are identified, documented, reviewed, and approved to ensure the incorporation of appropriate quality standards in design documents.
Design requirements and quality standards are described to an appropriate level of detail in design criteria.
Any exception to quality standards will be listed. Criteria for modifications to structures,
: systems, and components will consider, as a minimum, the design bases described in the UFSAR.
All design criteria will be satisfied in the design.
17.2.3.4 Design Process Controls The organization performing design will have the responsibility for design control unless specified otherwise. The control of design will be specified in procedures.
These procedures will include instructions for defining typical design requirements; communicating needed design information across internal and external interfaces; preparing, reviewing, approving, releasing, distributing,
: revising, and maintaining design documents; performing design reviews; and controlling field changes.
Design control involves measures that include a definition of design requirements; a design process that includes design analysis and the delineation of requirements through the issuing of drawings, specifications, and other design documents (design outputs); and design verification.
Design control involves measures that include a definition of design requirements; a design process that includes design analysis and the delineation of requirements through the issuing of drawings, specifications, and other design documents (design outputs); and design verification.
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17.2-8 Revision 14 To be determined


The design process establishes controls for releasing technically adequate and accurate design documents in a controlled manner with a timely distribution to responsible individuals and groups.
The design process establishes controls for releasing technically adequate and accurate design documents in a controlled manner with a timely distribution to responsible individuals and groups.
Documents and revisions are controlled through the use of written procedures that apply to the issuer, distributor, and user to prevent inadvertent use of superseded documents. Document control procedures govern the collection, storage, and maintenance of design documents, results of design document reviews, and changes thereto. Design documents subject to procedural control include, but are not limited to, specifications, calculations, computer programs, the UFSAR when used as a design document, and drawings, including flow diagrams, piping and instrument diagrams, control logic diagrams, electrical single-line diagrams, structural systems for major facilities, site arrangements, and equipment locations.
Documents and revisions are controlled through the use of written procedures that apply to the issuer, distributor, and user to prevent inadvertent use of superseded documents.
17.2.3.5   Design Interface Control Design interfaces with external and internal organizations participating in the design are controlled. The design interface measures ensure that the required design information is available in a timely fashion to the organization(s) responsible for the design.
Document control procedures govern the collection, storage, and maintenance of design documents, results of design document reviews, and changes thereto. Design documents subject to procedural control include, but are not limited to, specifications, calculations, computer programs, the UFSAR when used as a design document, and drawings, including flow diagrams, piping and instrument diagrams, control logic diagrams, electrical single-line diagrams, structural systems for major facilities, site arrangements, and equipment locations.
17.2.3.6   Design Verification The applicability of previously proven designs, with respect to meeting   pertinent   design   inputs,   including   environmental conditions, will be verified for each application.         Where the design of a particular structure, system, or component for a specific application has been subjected to a previous verification process, the verification process need not be duplicated for subsequent identical applications. However, the original design and verification will be documented and referenced for the subsequent application.
17.2.3.5 Design Interface Control Design interfaces with external and internal organizations participating in the design are controlled. The design interface measures ensure that the required design information is available in a timely fashion to the organization(s) responsible for the design.
17.2.3.6 Design Verification The applicability of previously proven designs, with respect to meeting pertinent design
: inputs, including environmental conditions, will be verified for each application.
Where the design of a particular structure, system, or component for a specific application has been subjected to a previous verification process, the verification process need not be duplicated for subsequent identical applications.
However, the original design and verification will be documented and referenced for the subsequent application.
When changes to previously verified designs have been made, design verification will be required for the changes, including an evaluation of the effects of those changes on the overall design.
When changes to previously verified designs have been made, design verification will be required for the changes, including an evaluation of the effects of those changes on the overall design.
Design verification will be performed by competent individuals who:
Design verification will be performed by competent individuals who:
* have not participated in the original design but may be from the same organizational entity,
have not participated in the original design but may be from the same organizational entity, do not have immediate supervisory responsibility for the individual performing the design, have not specified a singular design approach, have not ruled out certain design considerations, and 17.2-9 Revision 14 To be determined
* do not have immediate supervisory responsibility for the individual performing the design,
 
* have not specified a singular design approach,
have not established the inputs for the particular design aspect being verified.
* have not ruled out certain design considerations, and 17.2-9                   Revision 14 To be determined
Under exceptional circumstances, the design verification may be performed by the originator's supervisor provided:
* have not established the inputs for the particular design aspect being verified.
the supervisor is the only technically qualified individual in the organization competent to perform the verification, the need is individually documented and approved in advance by the supervisor's management, and QA audits cover the frequency of occurrence and effectiveness of the supervisor as design verifier to guard against abuse.
Under exceptional circumstances, the design verification     may be performed by the originator's supervisor provided:
* the supervisor is the only technically qualified individual in the organization competent to perform the verification,
* the need is individually documented and approved       in advance by the supervisor's management, and
* QA audits   cover the frequency of occurrence and effectiveness of the supervisor as design verifier to guard against abuse.
Cursory supervisory reviews do not satisfy the intent of providing a design verification.
Cursory supervisory reviews do not satisfy the intent of providing a design verification.
If errors or deficiencies in the design process are detected during the design verification cycle or during audits, resolution of errors and deficiencies will be the responsibility of the design engineer, who must provide documented evidence of resolution to the appropriate levels of management.
If errors or deficiencies in the design process are detected during the design verification cycle or during audits, resolution of errors and deficiencies will be the responsibility of the design engineer, who must provide documented evidence of resolution to the appropriate levels of management.
Acceptable verification methods include, but are not limited to, any one or a combination of the following:
Acceptable verification methods include, but are not limited to, any one or a combination of the following:
: 1.     Design reviews
: 1.
: 2.     Alternative or simplified calculational methods
Design reviews
: 3.     Performance of suitable qualification testing.
: 2.
Alternative or simplified calculational methods
: 3.
Performance of suitable qualification testing.
The method selected will consider the item's complexity, previous operational experience, and importance to safety.
The method selected will consider the item's complexity, previous operational experience, and importance to safety.
The results of the design verification efforts will be clearly documented, with the identification of the verifier clearly indicated and filed.       The documentation of results will be auditable against the verification methods identified by the responsible design organization.
The results of the design verification efforts will be clearly documented, with the identification of the verifier clearly indicated and filed.
17.2.3.6.1   Design Reviews Design reviews will be sufficient to verify the appropriateness of the design input, including assumptions, design bases and applicable regulations, codes and standards, and that the design is adequate for the intended application of the design.
The documentation of results will be auditable against the verification methods identified by the responsible design organization.
17.2-10                   Revision 14 To be determined
17.2.3.6.1 Design Reviews Design reviews will be sufficient to verify the appropriateness of the design
: input, including assumptions, design bases and applicable regulations, codes and standards, and that the design is adequate for the intended application of the design.
17.2-10 Revision 14 To be determined


Design reviews can range from multi-organization reviews to single-person reviews.     The depth of review can range from a detailed check of the complete design to a limited check of the design approach, calculations, and results obtained.
Design reviews can range from multi-organization reviews to single-person reviews.
17.2.3.6.2   Calculations Alternative, simplified calculations can be made, or a check of the original calculations may be performed, to verify the correctness of the original calculation. Where computer programs are used, the program verification will be documented and the inputs shall be considered in the design review.
The depth of review can range from a detailed check of the complete design to a limited check of the design approach, calculations, and results obtained.
17.2.3.6.3   Qualification Testing Design verification for some designs or specific design features may be achieved by suitable qualification testing of a prototype or initial production unit.
17.2.3.6.2 Calculations Alternative, simplified calculations can be made, or a check of the original calculations may be performed, to verify the correctness of the original calculation.
In those cases where the adequacy of a design is to be verified by a qualification test, the testing will be identified and documented. Testing will demonstrate the adequacy of performance under conditions that simulate the most adverse design conditions.
Where computer programs are used, the program verification will be documented and the inputs shall be considered in the design review.
17.2.3.7   Changes To Design Documents Changes to design documents receive a review and approval process as equivalent to original design documents.       Design documents issued by the original architect-engineer, NSSS supplier, and other organizations may be changed and revised by the responsible design organizations within Iowa Electric or contracted by Iowa Electric.
17.2.3.6.3 Qualification Testing Design verification for some designs or specific design features may be achieved by suitable qualification testing of a prototype or initial production unit.
17.2.3.8   Independent Review Committees Independent of the responsibilities of the design organization, the requirements of the Operations Committee and the Safety Committee, as specified in the Technical Specifications, will be satisfied.
In those cases where the adequacy of a design is to be verified by a qualification test, the testing will be identified and documented.
17.2.4   PROCUREMENT DOCUMENT CONTROL 17.2.4.1   Scope Procurement document control applies to documents employed to procure safety related materials, parts, components, and services required to modify, maintain, repair, test, inspect, or operate the DAEC. Iowa Electric controls procurement documents by written procedures that establish requirements and assign responsibility for measures to ensure that applicable regulatory requirements, design bases, and other requirements necessary to ensure quality are included in documents employed for the procurement of safety related materials, parts, components, and services.
Testing will demonstrate the adequacy of performance under conditions that simulate the most adverse design conditions.
17.2-11                 Revision 14 To be determined
17.2.3.7 Changes To Design Documents Changes to design documents receive a review and approval process as equivalent to original design documents.
Design documents issued by the original architect-engineer, NSSS supplier, and other organizations may be changed and revised by the responsible design organizations within Iowa Electric or contracted by Iowa Electric.
17.2.3.8 Independent Review Committees Independent of the responsibilities of the design organization, the requirements of the Operations Committee and the Safety Committee, as specified in the Technical Specifications, will be satisfied.
17.2.4 PROCUREMENT DOCUMENT CONTROL 17.2.4.1 Scope Procurement document control applies to documents employed to procure safety related materials, parts, components, and services required to modify, maintain, repair, test, inspect, or operate the DAEC.
Iowa Electric controls procurement documents by written procedures that establish requirements and assign responsibility for measures to ensure that applicable regulatory requirements, design bases, and other requirements necessary to ensure quality are included in documents employed for the procurement of safety related materials, parts, components, and services.
17.2-11 Revision 14 To be determined


17.2.4.2   Procurement Responsibility The responsibility for the initiation of a purchase requisition is that of the organization that ultimately has the responsibility for the procurement.
17.2.4.2 Procurement Responsibility The responsibility for the initiation of a purchase requisition is that of the organization that ultimately has the responsibility for the procurement.
17.2.4.3   Quality Classification Each item or service to be procured is evaluated by the Engineering Department to determine whether or not it performs a safety-related function or involves activities that affect the function of safety-related materials, parts, or components and to appraise the importance of this function to plant or public safety. For those cases where it is unclear if an individual piece (that is, part of a safety-related structure, system, component, or service) is governed by the Operational Quality Assurance Program, an engineering evaluation will be conducted.       The evaluation will classify the safety relationship of the service or questionable component parts or items of safety-related structures, systems, or components.
17.2.4.3 Quality Classification Each item or service to be procured is evaluated by the Engineering Department to determine whether or not it performs a safety-related function or involves activities that affect the function of safety-related materials, parts, or components and to appraise the importance of this function to plant or public safety. For those cases where it is unclear if an individual piece (that is, part of a safety-related structure, system, component, or service) is governed by the Operational Quality Assurance Program, an engineering evaluation will be conducted.
17.2.4.4   Quality Requirements in Procurement Documents Procurement document control measures will ensure that appropriate regulatory requirements, design bases, and other requirements are included in the procurement process.     Originating and reviewing organizations shall require that the following be included or invoked by reference in procurement documents, as appropriate:
The evaluation will classify the safety relationship of the service or questionable component parts or items of safety-related structures, systems, or components.
: 1. Requirements that the supplier provide a description of his quality assurance program that implements the applicable criteria of 10 CFR Part 50, Appendix B, and that is appropriate for the particular type of item or service to be supplied. Certain items or services will require extensive controls throughout all stages of manufacture or performance, while others may require only a limited control effort in selected phases.
17.2.4.4 Quality Requirements in Procurement Documents Procurement document control measures will ensure that appropriate regulatory requirements, design bases, and other requirements are included in the procurement process.
: 2. Basic   administrative   and   technical   requirements, including drawings, specifications, regulations, special instructions, applicable codes and industrial standards, and procedural requirements identified by titles     and revision levels; special process instructions; test and examination requirements with corresponding acceptance criteria; and special requirements for activities such as designing, identifying, fabricating, cleaning, erecting, packaging, handling, shipping, and storing.
Originating and reviewing organizations shall require that the following be included or invoked by reference in procurement documents, as appropriate:
17.2-12                 Revision 14 To be determined
: 1.
: 3. Requirements for supplier surveillance, audit, and inspection, including provisions for Iowa Electric access to facilities and records and for the identification of witness and hold points.
Requirements that the supplier provide a description of his quality assurance program that implements the applicable criteria of 10 CFR Part 50, Appendix B, and that is appropriate for the particular type of item or service to be supplied. Certain items or services will require extensive controls throughout all stages of manufacture or performance, while others may require only a limited control effort in selected phases.
: 4. Requirements for extending applicable requirements to lower-tier   suppliers     and   subcontractors.     These requirements will include right-of access by Iowa Electric to sub-supplier facilities and records.
: 2.
: 5. Requirements     for the   supplier to   report   certain nonconformances to procurement document requirements and conditions of their disposition.
Basic administrative and technical requirements, including drawings, specifications, regulations, special instructions, applicable codes and industrial standards, and procedural requirements identified by titles and revision levels; special process instructions; test and examination requirements with corresponding acceptance criteria; and special requirements for activities such as designing, identifying, fabricating, cleaning, erecting, packaging, handling, shipping, and storing.
: 6. Documentation requirements, including records to be prepared, maintained, submitted, or made available for review, such as drawings, specifications, procedures, procurement documents, inspection and test records, personnel and procedural qualifications, chemical and physical test results, and instructions for the retention and disposition of records.
17.2-12 Revision 14 To be determined
: 7. Requirements for supplier-furnished records.
: 3.
: 8. Applicability of the provisions of 10 CFR Part 21 for safety-related items, to the extent that a loss of their function may cause potential substantial safety hazards.
Requirements for supplier surveillance, audit, and inspection, including provisions for Iowa Electric access to facilities and records and for the identification of witness and hold points.
: 4.
Requirements for extending applicable requirements to lower-tier suppliers and subcontractors.
These requirements will include right-of access by Iowa Electric to sub-supplier facilities and records.
: 5.
Requirements for the supplier to report certain nonconformances to procurement document requirements and conditions of their disposition.
: 6.
Documentation requirements, including records to be prepared, maintained, submitted, or made available for
: review, such as drawings, specifications, procedures, procurement documents, inspection and test records, personnel and procedural qualifications, chemical and physical test results, and instructions for the retention and disposition of records.
: 7.
Requirements for supplier-furnished records.
: 8.
Applicability of the provisions of 10 CFR Part 21 for safety-related items, to the extent that a loss of their function may cause potential substantial safety hazards.
Certain items, as off-the-shelf items, will be exempt from this requirement.
Certain items, as off-the-shelf items, will be exempt from this requirement.
: 9. Requirements     for packaging   and   transportation   as necessary to prevent degradation during transit.
: 9.
17.2.4.5 Acquisition from Other Licensed Nuclear Power Plants Items may be procured from another NRC licensed nuclear power plant provided the Iowa Electric purchase specification is equivalent to that of the other utility, and the quality assurance requirements of Iowa Electric have been satisfied. If the item was originally procured by the other utility   as a "basic component" as defined in 10 CFR Part 21, the reporting requirements of the regulation are transferred to Iowa Electric Light and Power Company.             Iowa Electric Light and Power Company shall notify the original supplier in writing of this item(s) change in ownership to ensure appropriate 10 CFR Part 21 reporting from the original supplier.
Requirements for packaging and transportation as necessary to prevent degradation during transit.
17.2-13                 Revision 14 To be determined
17.2.4.5 Acquisition from Other Licensed Nuclear Power Plants Items may be procured from another NRC licensed nuclear power plant provided the Iowa Electric purchase specification is equivalent to that of the other utility, and the quality assurance requirements of Iowa Electric have been satisfied.
If the item was originally procured by the other utility as a "basic component" as defined in 10 CFR Part 21, the reporting requirements of the regulation are transferred to Iowa Electric Light and Power Company.
Iowa Electric Light and Power Company shall notify the original supplier in writing of this item(s) change in ownership to ensure appropriate 10 CFR Part 21 reporting from the original supplier.
17.2-13 Revision 14 To be determined


17.2.5   INSTRUCTIONS, PROCEDURES, AND DRAWINGS 17.2.5.1   Scope Instructions, procedures, and drawings will be generated to provide direction and guidance to ensure that safety-related activities are performed correctly. The need for, content of, and depth of detail of the instructions, procedures, and drawings will be consistent with the importance and complexity of that activity.
17.2.5 INSTRUCTIONS, PROCEDURES, AND DRAWINGS 17.2.5.1 Scope Instructions, procedures, and drawings will be generated to provide direction and guidance to ensure that safety-related activities are performed correctly.
17.2.5.2   Content The content of the instructions, procedures, and drawings will be appropriate to the activities being performed.
The need for, content of, and depth of detail of the instructions, procedures, and drawings will be consistent with the importance and complexity of that activity.
17.2.5.2 Content The content of the instructions, procedures, and drawings will be appropriate to the activities being performed.
Instructions and procedures will include, as appropriate, scope or purpose, responsibilities of individuals performing the work, the information needed, and required output and acceptance criteria.
Instructions and procedures will include, as appropriate, scope or purpose, responsibilities of individuals performing the work, the information needed, and required output and acceptance criteria.
Drawings will be prepared using industrially accepted standards.
Drawings will be prepared using industrially accepted standards.
17.2.5.3   Issuance The organization responsible for the activity being described is responsible for the issuance of the instructions, procedures, and drawings.
17.2.5.3 Issuance The organization responsible for the activity being described is responsible for the issuance of the instructions, procedures, and drawings.
The instructions, procedures, and drawings will be issued before the commencement of the activity to be controlled by that instruction, procedure, and drawing.
The instructions, procedures, and drawings will be issued before the commencement of the activity to be controlled by that instruction, procedure, and drawing.
Once instructions, procedures, and drawings have been approved and issued for use, the activities will be performed in accordance with the documents.     If the activity cannot be accomplished, the document will be formally revised to reflect the manner in which the activity is to be performed.
Once instructions, procedures, and drawings have been approved and issued for use, the activities will be performed in accordance with the documents.
If the activity cannot be accomplished, the document will be formally revised to reflect the manner in which the activity is to be performed.
Revised instructions, procedures, and drawings will be reviewed and approved by the same organizations and individuals (or equivalent positions) that reviewed and approved the original document.
Revised instructions, procedures, and drawings will be reviewed and approved by the same organizations and individuals (or equivalent positions) that reviewed and approved the original document.
17.2.6   DOCUMENT CONTROL 17.2.6.1   Scope The organization responsible for the documents will establish measures to ensure that the documents,     including changes, are reviewed for adequacy, are approved for release by authorized 17.2-14                 Revision 14 To be determined
17.2.6 DOCUMENT CONTROL 17.2.6.1 Scope The organization responsible for the documents will establish measures to ensure that the documents, including changes, are reviewed for adequacy, are approved for release by authorized 17.2-14 Revision 14 To be determined


personnel, are distributed to and used at the location where the prescribed activity is performed, and are controlled.
personnel, are distributed to and used at the location where the prescribed activity is performed, and are controlled.
17.2.6.2 Preparation The organization responsible for the initiation of the document is responsible for the issuance of the document.     The organization that issues controlled documents will establish administrative techniques that define the documents to be controlled, identify the current revision or issue of the document, and identify the individuals who are to receive the document.
17.2.6.2 Preparation The organization responsible for the initiation of the document is responsible for the issuance of the document.
The organization that issues controlled documents will establish administrative techniques that define the documents to be controlled, identify the current revision or issue of the document, and identify the individuals who are to receive the document.
The types of documents that are controlled by Iowa Electric include the following:
The types of documents that are controlled by Iowa Electric include the following:
: 1. Specifications
: 1.
: 2. Drawings
Specifications
: 3. Procurement documents
: 2.
: 4. Quality Assurance Manual
Drawings
: 5. Nuclear Generation Division Manual
: 3.
: 6. Departmental Procedures
Procurement documents
: 7. Safety analysis reports and related       design criteria documents
: 4.
: 8. Welding Manual
Quality Assurance Manual
: 9. Computer codes.
: 5.
17.2.6.3 Review and Approval Documents that are specified as being controlled documents are reviewed to ensure that regulatory, technical, quality assurance, and contractual requirements have been appropriately addressed; that review comments have been considered and resolved; and that the document is approved before issuance and use.
Nuclear Generation Division Manual
Divisional procedures that are responsive to the requirements of the Operational Quality Assurance Program shall be reviewed and evaluated for concurrence by the Corporate Quality Assurance Department. The review shall be documented indicating that the procedure is consistent with the quality assurance program and corporate policies.
: 6.
Revisions   will require   review and   approval   by   the same organizations (or equivalent) that performed the original review, before the issuance or implementation of the change.
Departmental Procedures
: 7.
Safety analysis reports and related design criteria documents
: 8.
Welding Manual
: 9.
Computer codes.
17.2.6.3 Review and Approval Documents that are specified as being controlled documents are reviewed to ensure that regulatory, technical, quality assurance, and contractual requirements have been appropriately addressed; that review comments have been considered and resolved; and that the document is approved before issuance and use.
Divisional procedures that are responsive to the requirements of the Operational Quality Assurance Program shall be reviewed and evaluated for concurrence by the Corporate Quality Assurance Department.
The review shall be documented indicating that the procedure is consistent with the quality assurance program and corporate policies.
Revisions will require review and approval by the same organizations (or equivalent) that performed the original review, before the issuance or implementation of the change.
Documents that have been approved by the original designers of the DAEC will be revised by the Iowa Electric Engineering Department.
Documents that have been approved by the original designers of the DAEC will be revised by the Iowa Electric Engineering Department.
17.2-15                   Revision 14 To be determined
17.2-15 Revision 14 To be determined


17.2.6.4   Distribution and Use The mechanism for distribution will provide assurance that the controlled document arrives at the point of use; the user will provide assurance that the document to be used is the proper document and revision.
17.2.6.4 Distribution and Use The mechanism for distribution will provide assurance that the controlled document arrives at the point of use; the user will provide assurance that the document to be used is the proper document and revision.
When formal distribution lists   are used to prescribe an established distribution, they will be maintained current to reflect changes in assigned responsibilities.
When formal distribution lists are used to prescribe an established distribution, they will be maintained current to reflect changes in assigned responsibilities.
Document transmittals will be reviewed for accuracy and dated and made suitable for transmittal. The recipient is informed of what is being transmitted and of the status of the documents being transmitted.
Document transmittals will be reviewed for accuracy and dated and made suitable for transmittal.
The recipient is informed of what is being transmitted and of the status of the documents being transmitted.
An acknowledgment of the receipt of controlled documents by recipients may be required if the organization responsible for the document deems such controls necessary.
An acknowledgment of the receipt of controlled documents by recipients may be required if the organization responsible for the document deems such controls necessary.
The organization responsible for the use of the document will establish   administrative   controls   to provide     for positive identification and prevent the loss of such documents.             The administrative controls will have provisions to remove obsolete documents, thereby precluding the possibility that the wrong documents or revisions will be used.
The organization responsible for the use of the document will establish administrative controls to provide for positive identification and prevent the loss of such documents.
17.2.6.5   Changes to Documents Changes to documents previously released will be reviewed, approved, dated, and distributed in the same manner as the original document.
The administrative controls will have provisions to remove obsolete documents, thereby precluding the possibility that the wrong documents or revisions will be used.
Personnel who review changed documents will have access to the original documents, to any written basis or input information, and to any written reason or justification for the change. When the document that is being changed has been issued by the original designers of the DAEC, then the access to the original documents will depend on the reasonable availability of those documents.
17.2.6.5 Changes to Documents Changes to documents previously released will be
: reviewed, approved, dated, and distributed in the same manner as the original document.
Personnel who review changed documents will have access to the original documents, to any written basis or input information, and to any written reason or justification for the change.
When the document that is being changed has been issued by the original designers of the DAEC, then the access to the original documents will depend on the reasonable availability of those documents.
Revised instructions and procedures will reflect the new revision and date and clearly identify the scope or portion of the instruction and procedure being changed.
Revised instructions and procedures will reflect the new revision and date and clearly identify the scope or portion of the instruction and procedure being changed.
17.2-16                 Revision 14 To be determined
17.2-16 Revision 14 To be determined


17.2.7   CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES 17.2.7.1   Scope Purchased material, equipment, and services are controlled to ensure that the specified technical and quality requirements are obtained. The responsibility for the control of purchased material, equipment, and services is that of the Corporate Quality Assurance Department in close cooperation with the Engineering Department, DAEC, and the Purchasing Department.       The technique used for the control of purchased material, equipment and services includes, as     appropriate, source evaluation and selection, objective evidence of quality furnished, inspection at the source, supplier's history of providing a satisfactory product, and examination of the product on delivery.
17.2.7 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES 17.2.7.1 Scope Purchased material, equipment, and services are controlled to ensure that the specified technical and quality requirements are obtained.
17.2.7.2   Source Evaluation and Selection Potential suppliers are evaluated. These evaluations are performed by qualified personnel to determine the capability of the supplier to provide the items or services.
The responsibility for the control of purchased material, equipment, and services is that of the Corporate Quality Assurance Department in close cooperation with the Engineering Department,
Suppliers are   evaluated on the basis of one or more of the following:
: DAEC, and the Purchasing Department.
: 1.     Capability to comply with the requirements of 10 CFR 50, Appendix B, applicable to the type of material, equipment, or service being procured.
The technique used for the control of purchased material, equipment and services
: 2.     Past records and performance for similar procurements to ascertain the capability of supplying a manufactured product or services under an acceptable quality assurance system.
: includes, as appropriate, source evaluation and selection, objective evidence of quality furnished, inspection at the source, supplier's history of providing a satisfactory product, and examination of the product on delivery.
: 3.     Audits or surveys of supplier's facilities and quality assurance program to determine the capability to supply a product that satisfies the design, manufacturing, and quality requirements.
17.2.7.2 Source Evaluation and Selection Potential suppliers are evaluated.
: 4.     The certification of the supplier by the ASME.
These evaluations are performed by qualified personnel to determine the capability of the supplier to provide the items or services.
: 5.     The results of audits performed by other utilities and consultants.
Suppliers are evaluated on the basis of one or more of the following:
: 1.
Capability to comply with the requirements of 10 CFR 50, Appendix B, applicable to the type of
: material, equipment, or service being procured.
: 2.
Past records and performance for similar procurements to ascertain the capability of supplying a manufactured product or services under an acceptable quality assurance system.
: 3.
Audits or surveys of supplier's facilities and quality assurance program to determine the capability to supply a product that satisfies the design, manufacturing, and quality requirements.
: 4.
The certification of the supplier by the ASME.
: 5.
The results of audits performed by other utilities and consultants.
The supplier's bid proposal is reviewed and evaluated to ensure that the bid is responsive to the procurement documents.
The supplier's bid proposal is reviewed and evaluated to ensure that the bid is responsive to the procurement documents.
Depending on the importance of the item or service and its importance to safety, a post-award meeting may be held to discuss the requirements of the procurement document.
Depending on the importance of the item or service and its importance to safety, a post-award meeting may be held to discuss the requirements of the procurement document.
17.2-17                 Revision 14 To be determined
17.2-17 Revision 14 To be determined


17.2.7.3   Inspection or Surveillance at the Source Subsequent     to   the   award   of   a   purchase     order,   a surveillance/inspection plan may be prepared. The extent of the plan will consider the complexity and importance of the item or service, supplier's past performance, and those aspects of the manufacturing process that may not be verified at receipt inspection.
17.2.7.3 Inspection or Surveillance at the Source Subsequent to the award of a
purchase
: order, a
surveillance/inspection plan may be prepared.
The extent of the plan will consider the complexity and importance of the item or service, supplier's past performance, and those aspects of the manufacturing process that may not be verified at receipt inspection.
The plan will establish, as appropriate, the frequency of surveillance/inspection; processes to be witnessed, inspected, or verified; the method of surveillance/inspection; and documentation requirements.
The plan will establish, as appropriate, the frequency of surveillance/inspection; processes to be witnessed, inspected, or verified; the method of surveillance/inspection; and documentation requirements.
Activities specified in the plan will be conducted at the supplier's facilities by qualified personnel using approved procedures that provide for the following as applicable:
Activities specified in the plan will be conducted at the supplier's facilities by qualified personnel using approved procedures that provide for the following as applicable:
: 1.     Reviewing material acceptability
: 1.
: 2.     Witnessing     in-process     inspections,   tests,   and nondestructive examination
Reviewing material acceptability
: 3.     Reviewing the qualification of procedures, equipment, and personnel
: 2.
: 4.     Verifying that fabrication or construction procedures and processes have been approved and are properly applied
Witnessing in-process inspections,
: 5.     Verifying quality assurance/quality control systems, to the   extent necessary
: tests, and nondestructive examination
: 6.     Reviewing document packages for compliance to procurement document requirements, including qualifications, process records, and inspection and test records
: 3.
: 7.     Reviewing Certificates of Compliance for adequacy.
Reviewing the qualification of procedures, equipment, and personnel
: 8.     Verifying that     nonconformances   have been   properly controlled.
: 4.
Verifying that fabrication or construction procedures and processes have been approved and are properly applied
: 5.
Verifying quality assurance/quality control systems, to the extent necessary
: 6.
Reviewing document packages for compliance to procurement document requirements, including qualifications, process records, and inspection and test records
: 7.
Reviewing Certificates of Compliance for adequacy.
: 8.
Verifying that nonconformances have been properly controlled.
Hold points specified in the procurement document will be complied with and Iowa Electric will be notified in a timely manner when hold points are reached.
Hold points specified in the procurement document will be complied with and Iowa Electric will be notified in a timely manner when hold points are reached.
A method will be established to provide information relative to the characteristics that have been inspected at the source and the characteristics that are to be inspected on receipt.
A method will be established to provide information relative to the characteristics that have been inspected at the source and the characteristics that are to be inspected on receipt.
17.2-18                   Revision 14 To be determined
17.2-18 Revision 14 To be determined


17.2.7.4   Receipt Inspection Items purchased by Iowa Electric are controlled at the final destination by the performance of a receipt inspection. The extent of the receipt inspection depends on the importance to safety, the complexity, the quantity of the product or service, and the extent of source inspection, source surveillance or audit that was performed.
17.2.7.4 Receipt Inspection Items purchased by Iowa Electric are controlled at the final destination by the performance of a receipt inspection.
The extent of the receipt inspection depends on the importance to safety, the complexity, the quantity of the product or service, and the extent of source inspection, source surveillance or audit that was performed.
Receipt inspection is performed by trained and qualified personnel in accordance with approved procedures and acceptance criteria before the installation or use of the item(s) to preclude the placement or use of nonconforming item(s).
Receipt inspection is performed by trained and qualified personnel in accordance with approved procedures and acceptance criteria before the installation or use of the item(s) to preclude the placement or use of nonconforming item(s).
Documentary evidence will demonstrate that materials and equipment conform to the procurement requirements.
Documentary evidence will demonstrate that materials and equipment conform to the procurement requirements.
If receipt inspection indicates that the item is unacceptable, the item is treated as nonconforming.
If receipt inspection indicates that the item is unacceptable, the item is treated as nonconforming.
17.2.7.5   Post-installation Testing Acceptance by post-installation test may be used following one of the preceding verification methods. Post-installation testing is used as the prime means of acceptance verification when it       is difficult to verify item quality characteristics, the item requires an integrated system check out or test, or the item cannot demonstrate its ability to perform when not in use.           Post installation test requirements and acceptance documentation are established by Iowa Electric.
17.2.7.5 Post-installation Testing Acceptance by post-installation test may be used following one of the preceding verification methods.
17.2.8     IDENTIFICATION AND CONTROL OF MATERIALS,   PARTS, AND COMPONENTS 17.2.8.1   Scope Materials, parts, and components will be identified and controlled to ensure that the correct materials, parts, and components are used during fabrication, manufacture, modification, repair, and replacement.
Post-installation testing is used as the prime means of acceptance verification when it is difficult to verify item quality characteristics, the item requires an integrated system check out or test, or the item cannot demonstrate its ability to perform when not in use.
Post installation test requirements and acceptance documentation are established by Iowa Electric.
17.2.8 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS 17.2.8.1 Scope Materials, parts, and components will be identified and controlled to ensure that the correct materials, parts, and components are used during fabrication, manufacture, modification, repair, and replacement.
It is the responsibility of the organization responsible for the engineering design and procurement to include the requirements for proper identification and control in the procurement documents.
It is the responsibility of the organization responsible for the engineering design and procurement to include the requirements for proper identification and control in the procurement documents.
It is the responsibility of the supplier for maintaining the traceability of materials, parts, and components throughout fabrication and shipment.
It is the responsibility of the supplier for maintaining the traceability of materials,
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: parts, and components throughout fabrication and shipment.
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It is the responsibility of the DAEC for maintaining the traceability of materials, parts, and components throughout repair, replacement, modification, and installation.
It is the responsibility of the DAEC for maintaining the traceability of materials, parts, and components throughout repair, replacement, modification, and installation.
17.2.8.2   Identification Identification will be applied in locations and by methods     that will not affect the fit, function, or quality of the item.
17.2.8.2 Identification Identification will be applied in locations and by methods that will not affect the fit, function, or quality of the item.
The identification of the item will be maintained by a unique method such as heat number, part number, serial number, batch number, or other appropriate means in a form that is durable and legible.
The identification of the item will be maintained by a unique method such as heat number, part number, serial number, batch number, or other appropriate means in a form that is durable and legible.
The identification may be on the item or on records traceable to the item. Where feasible, direct placement of the identification on the item will be by stamping, marking, tags, labels, or other similar methods.
The identification may be on the item or on records traceable to the item. Where feasible, direct placement of the identification on the item will be by stamping, marking, tags, labels, or other similar methods.
Where direct placement of identification on the item is not feasible, proper controls will be established that ensure direct positive identification of the item. Where physical identification is either impractical or insufficient, physical separation, procedural control, or other approved means will be employed.
Where direct placement of identification on the item is not feasible, proper controls will be established that ensure direct positive identification of the item.
Where physical identification is either impractical or insufficient, physical separation, procedural control, or other approved means will be employed.
Receipt inspection will verify that identification for received items is complete and accompanied by appropriate documentation.
Receipt inspection will verify that identification for received items is complete and accompanied by appropriate documentation.
When an item is subdivided, the identification will be immediately transferred to the sub-parts so that all sub-parts contain the appropriate identification label.
When an item is subdivided, the identification will be immediately transferred to the sub-parts so that all sub-parts contain the appropriate identification label.
Any identification that will be obliterated or hidden by surface coatings or surface treatments will be reestablished or will be traceable by administrative means.
Any identification that will be obliterated or hidden by surface coatings or surface treatments will be reestablished or will be traceable by administrative means.
Standard catalog items or off-the-shelf items may be identified by catalog number or other appropriate designation.
Standard catalog items or off-the-shelf items may be identified by catalog number or other appropriate designation.
17.2.8.3   Verification and Control The items will be controlled and the identity of the item verified.
17.2.8.3 Verification and Control The items will be controlled and the identity of the item verified.
Inventory and storage controls will be established at the DAEC to ensure proper traceability of items.
Inventory and storage controls will be established at the DAEC to ensure proper traceability of items.
The correctness of the item will be verified on withdrawal from storage and before the initiation of the repair, replacement, and modification.
The correctness of the item will be verified on withdrawal from storage and before the initiation of the repair, replacement, and modification.
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17.2-20 Revision 14 To be determined


17.2.9   CONTROL OF SPECIAL PROCESSES 17.2.9.1   Scope Special processes are those controlled fabrications, tests, and final preparation processes that require the qualification of procedure, technique, and personnel and that are performed in accordance with applicable codes and standards. Certain special processes require interim in-process controls in addition to final inspection to ensure quality.
17.2.9 CONTROL OF SPECIAL PROCESSES 17.2.9.1 Scope Special processes are those controlled fabrications, tests, and final preparation processes that require the qualification of procedure, technique, and personnel and that are performed in accordance with applicable codes and standards.
Certain special processes require interim in-process controls in addition to final inspection to ensure quality.
The control of special processes is the joint responsibility of the Engineering Department, the DAEC, and the Corporate Quality Assurance Department.
The control of special processes is the joint responsibility of the Engineering Department, the DAEC, and the Corporate Quality Assurance Department.
The Engineering Department is responsible for providing technical expertise relative to materials, metallurgy, welding, brazing, and for providing the related special process procedures.           The Corporate Quality Assurance Department is responsible for providing required nondestructive examinations (NDE) and the associated procedures.
The Engineering Department is responsible for providing technical expertise relative to materials, metallurgy, welding, brazing, and for providing the related special process procedures.
17.2.9.2   General Requirements Measures will be established to ensure that special processes are controlled and accomplished by qualified personnel using qualified procedures   in accordance with applicable codes,       standards, specifications, criteria, and other special requirements.
The Corporate Quality Assurance Department is responsible for providing required nondestructive examinations (NDE) and the associated procedures.
17.2.9.2 General Requirements Measures will be established to ensure that special processes are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable
: codes, standards, specifications, criteria, and other special requirements.
Written procedures will be reviewed or prepared before use to ensure that special processes are controlled and accomplished.
Written procedures will be reviewed or prepared before use to ensure that special processes are controlled and accomplished.
These procedures will describe the operations to be performed, the sequence of operations, the characteristics involved, the limits of these characteristics, measuring and test equipment to be used, acceptance criteria, and documentation requirements.
These procedures will describe the operations to be performed, the sequence of operations, the characteristics involved, the limits of these characteristics, measuring and test equipment to be used, acceptance criteria, and documentation requirements.
Special processes will be accomplished in accordance with written procedures and process sheets, or their equivalent.
Special processes will be accomplished in accordance with written procedures and process sheets, or their equivalent.
Personnel will be trained and       qualified in accordance with applicable codes and standards.
Personnel will be trained and qualified in accordance with applicable codes and standards.
Equipment used to perform special processes or measure or test the product will be qualified, before use, in accordance with applicable codes, standards, specifications, or procedures.
Equipment used to perform special processes or measure or test the product will be qualified, before use, in accordance with applicable codes, standards, specifications, or procedures.
The extent and period of training, qualification, and testing of personnel and equipment will be in accordance with applicable codes, standards, specifications, or procedures.
The extent and period of training, qualification, and testing of personnel and equipment will be in accordance with applicable codes, standards, specifications, or procedures.
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17.2-21 Revision 14 To be determined


17.2.9.3   Personnel Qualification The personnel who perform nondestructive examinations will be certified to the precise technique to be used and for the proper level of expertise.
17.2.9.3 Personnel Qualification The personnel who perform nondestructive examinations will be certified to the precise technique to be used and for the proper level of expertise.
A Level III Examiner will be responsible for qualifying and certifying, in accordance with the Iowa Electric Light and Power written practice, the Iowa Electric personnel who perform nondestructive examinations.
A Level III Examiner will be responsible for qualifying and certifying, in accordance with the Iowa Electric Light and Power written
17.2.9.4   Verification and Control The procedures, process sheets, personnel, and equipment will be verified as appropriate, before the initiation of work at the DAEC.
: practice, the Iowa Electric personnel who perform nondestructive examinations.
17.2.9.4 Verification and Control The procedures, process sheets, personnel, and equipment will be verified as appropriate, before the initiation of work at the DAEC.
The Corporate Quality Assurance Department will determine that suppliers performing special processes at the DAEC have sufficient controls before the initiation of the work.
The Corporate Quality Assurance Department will determine that suppliers performing special processes at the DAEC have sufficient controls before the initiation of the work.
The Corporate Quality Assurance Department will determine that DAEC personnel performing special processes have current qualifications.
The Corporate Quality Assurance Department will determine that DAEC personnel performing special processes have current qualifications.
17.2.9.5   Special Protective Coatings (Paint)
17.2.9.5 Special Protective Coatings (Paint)
The application of a special protective coating shall be controlled as a special process when the failure (i.e. peeling or spalling) of the coating to adhere to the substrate can cause the malfunction of a Quality Level I structure, system or component. Special process coatings shall be applied by qualified personnel using qualified materials and equipment, and approved procedures. Documentation shall include identification of the following:
The application of a special protective coating shall be controlled as a special process when the failure (i.e. peeling or spalling) of the coating to adhere to the substrate can cause the malfunction of a Quality Level I structure, system or component. Special process coatings shall be applied by qualified personnel using qualified materials and equipment, and approved procedures.
* person applying the coating (and qualification)
Documentation shall include identification of the following:
* material used
person applying the coating (and qualification) material used procedure used (and qualifying procedure if different) tests performed and results date of application of coating traceability of coating location.
* procedure used (and qualifying procedure if different)
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* tests performed and results
* date of application of coating
* traceability of coating location.
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17.2.10   INSPECTION 17.2.10.1   Scope A program for the inspection of safety-related activities at the DAEC will be established and executed to verify conformance with applicable documented instructions, procedures, drawings, and specifications.
17.2.10 INSPECTION 17.2.10.1 Scope A program for the inspection of safety-related activities at the DAEC will be established and executed to verify conformance with applicable documented instructions, procedures, drawings, and specifications.
The responsibility for the inspection of materials, parts, and components affecting quality is that of the Corporate Quality Assurance Department. The inspection program at DAEC will include the following:
The responsibility for the inspection of materials, parts, and components affecting quality is that of the Corporate Quality Assurance Department. The inspection program at DAEC will include the following:
: 1.     Receipt inspection
: 1.
: 2.     In-process inspections
Receipt inspection
: 3.     Final inspections.
: 2.
: 4.     Nondestructive examinations 17.2.10.2   General Requirements A program for the inspection of activities affecting quality will be established and executed by or for the organization performing the   activity   to verify   conformance with   the   documented instructions, procedures, and drawings for accomplishing the activity.
In-process inspections
Inspection will be performed by individuals other than those who performed the activity being inspected.       Inspections will be performed by personnel using appropriate equipment in accordance with applicable codes, standards, and procedures.
: 3.
Final inspections.
: 4.
Nondestructive examinations 17.2.10.2 General Requirements A program for the inspection of activities affecting quality will be established and executed by or for the organization performing the activity to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activity.
Inspection will be performed by individuals other than those who performed the activity being inspected.
Inspections will be performed by personnel using appropriate equipment in accordance with applicable codes, standards, and procedures.
Procedures, instructions, or checklists will be established and used that identify the characteristics to be inspected, inspection methods, special devices, acceptance and rejection criteria, methods for recording inspection results, and groups responsible for the inspection. Special preparation, cleaning, and the use of measuring devices will be included.
Procedures, instructions, or checklists will be established and used that identify the characteristics to be inspected, inspection methods, special devices, acceptance and rejection criteria, methods for recording inspection results, and groups responsible for the inspection. Special preparation, cleaning, and the use of measuring devices will be included.
Inspections will be planned to identify where in the sequence of work each inspection activity will be performed, to what extent, procedures to be used, and mandatory hold or witness points.
Inspections will be planned to identify where in the sequence of work each inspection activity will be performed, to what extent, procedures to be used, and mandatory hold or witness points.
Repairs, modifications, or replacements will be inspected in accordance with the original inspection requirements or acceptable alternatives.
Repairs, modifications, or replacements will be inspected in accordance with the original inspection requirements or acceptable alternatives.
Sampling methods and process monitoring will         be used when inspection is impossible or disadvantageous.
Sampling methods and process monitoring will be used when inspection is impossible or disadvantageous.
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17.2-23 Revision 14 To be determined


17.2.10.3   Process Monitoring Process monitoring of work activities, equipment, and personnel will be used as a control if inspection of processed items is impossible or disadvantageous.         Both inspection and process monitoring will be provided when control is inadequate without both. As an alternative, a suitable level of confidence in structures, systems, or components on which maintenance or modifications have been performed will be attained by inspection.
17.2.10.3 Process Monitoring Process monitoring of work activities, equipment, and personnel will be used as a control if inspection of processed items is impossible or disadvantageous.
Both inspection and process monitoring will be provided when control is inadequate without both.
As an alternative, a suitable level of confidence in structures,
: systems, or components on which maintenance or modifications have been performed will be attained by inspection.
As appropriate, an augmented inspection program will be implemented until such time as a suitable level of performance has been demonstrated.
As appropriate, an augmented inspection program will be implemented until such time as a suitable level of performance has been demonstrated.
The monitoring of processes will be performed to verify that activities affecting quality are being performed in accordance with documented instructions, procedures, drawings, and specifications.
The monitoring of processes will be performed to verify that activities affecting quality are being performed in accordance with documented instructions, procedures, drawings, and specifications.
17.2.10.4   In-Service Inspection Required     in-service   inspection,     including     nondestructive examination, pressure tests, and in-service tests of pumps and valves, will be planned and executed.           The results of these examinations and tests shall be documented, including corrective actions required and the actions taken.
17.2.10.4 In-Service Inspection Required in-service inspection, including nondestructive examination, pressure tests, and in-service tests of pumps and valves, will be planned and executed.
The basis for the in-service inspection program is the ASME Boiler and Pressure Vessel Code, Section XI, 1980 Edition with Addenda through Winter 1981.         The specific issue and addendum of requirements beyond the base commitment is as specified in 10 CFR Part 50, Section 50.55a(g), except where specific exemptions have been granted by the NRC.
The results of these examinations and tests shall be documented, including corrective actions required and the actions taken.
The Engineering Department has the overall responsibility for developing the inspection program, for ensuring compliance with the ASME Code Section XI rules, and for evaluating the inspection results. The inspection plans shall be updated as required to accommodate the as-built condition of the DAEC.
The basis for the in-service inspection program is the ASME Boiler and Pressure Vessel Code, Section XI, 1980 Edition with Addenda through Winter 1981.
17.2.10.4.1   Ten Year Inspection Program The Ten-Year Inspection Program includes inspections and tests of those pressure boundary welds and materials as defined in ASME Boiler and Pressure Vessel Code, Section XI.       Also included are the pressure boundary welds and materials that are defined as "Augmented" in-service inspections.           The Ten-Year Inspection Program   identifies   the welds   and   items   to be examined, the frequency   of such examinations,   the   methods,   and confirms the continuing   acceptability of the selected   welds and items.
The specific issue and addendum of requirements beyond the base commitment is as specified in 10 CFR Part 50, Section 50.55a(g), except where specific exemptions have been granted by the NRC.
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The Engineering Department has the overall responsibility for developing the inspection program, for ensuring compliance with the ASME Code Section XI rules, and for evaluating the inspection results.
The inspection plans shall be updated as required to accommodate the as-built condition of the DAEC.
17.2.10.4.1 Ten Year Inspection Program The Ten-Year Inspection Program includes inspections and tests of those pressure boundary welds and materials as defined in ASME Boiler and Pressure Vessel Code, Section XI.
Also included are the pressure boundary welds and materials that are defined as "Augmented" in-service inspections.
The Ten-Year Inspection Program identifies the welds and items to be examined, the frequency of such examinations, the methods, and confirms the continuing acceptability of the selected welds and items.
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The Quality Assurance Department has the responsibility for conducting the planned nondestructive examinations (NDE) and providing the services of the Corporate NDE Level III Examiner as required by Code.
The Quality Assurance Department has the responsibility for conducting the planned nondestructive examinations (NDE) and providing the services of the Corporate NDE Level III Examiner as required by Code.
17.2.10.4.2   In-service Testing Program The DAEC has the responsibility for conducting the ASME Boiler and Pressure Vessel Code, Section XI, pump and valve tests, system pressure tests, and snubber tests.     These performance tests to verify operational readiness are part of the plant performance program.
17.2.10.4.2 In-service Testing Program The DAEC has the responsibility for conducting the ASME Boiler and Pressure Vessel Code, Section XI, pump and valve tests, system pressure tests, and snubber tests.
17.2.10.5   Personnel Qualification Personnel performing inspections and examinations, or accepting the results of inspections and examinations, will be trained and qualified in accordance with governing codes, standards, and regulations. The personnel will be competent and cognizant of the technical requirements of the work activity. Qualification records will be maintained by the organization responsible for the individual(s) performing the inspections.
These performance tests to verify operational readiness are part of the plant performance program.
17.2.10.6   Documentation and Records Inspection and examination activities will be reported on a form that indicates the date of the activity, identification of inspector or examiner, and rejection or acceptance of the item(s).
17.2.10.5 Personnel Qualification Personnel performing inspections and examinations, or accepting the results of inspections and examinations, will be trained and qualified in accordance with governing codes, standards, and regulations. The personnel will be competent and cognizant of the technical requirements of the work activity. Qualification records will be maintained by the organization responsible for the individual(s) performing the inspections.
17.2.11   TEST CONTROL 17.2.11.1   Scope Testing will be performed at the DAEC to demonstrate that safety-related   structures, systems,   and components   perform satisfactorily in service. The testing program will include the following, as appropriate:
17.2.10.6 Documentation and Records Inspection and examination activities will be reported on a form that indicates the date of the activity, identification of inspector or examiner, and rejection or acceptance of the item(s).
: 1.     Qualification tests for design verification
17.2.11 TEST CONTROL 17.2.11.1 Scope Testing will be performed at the DAEC to demonstrate that safety-related structures,
: 2.     Proof tests before installation
: systems, and components perform satisfactorily in service.
: 3.     Pre-Operational tests
The testing program will include the following, as appropriate:
: 4.     Operational tests.
: 1.
17.2.11.2   General Requirements The tests will be performed in accordance with approved written test procedures that incorporate the requirements and acceptance limits. The test procedure will identify the item to be tested and the purpose of the test.
Qualification tests for design verification
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: 2.
Proof tests before installation
: 3.
Pre-Operational tests
: 4.
Operational tests.
17.2.11.2 General Requirements The tests will be performed in accordance with approved written test procedures that incorporate the requirements and acceptance limits.
The test procedure will identify the item to be tested and the purpose of the test.
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Test procedures will include provisions for ensuring that all prerequisites for the given test have been met, that adequate test instrumentation is available and used, and that the test is performed under suitable environmental conditions.         The test procedure will incorporate directly, or by reference, the following requirements:
Test procedures will include provisions for ensuring that all prerequisites for the given test have been met, that adequate test instrumentation is available and used, and that the test is performed under suitable environmental conditions.
: 1.     Performance of tests by trained personnel who         are qualified in accordance with applicable codes         and standards
The test procedure will incorporate directly, or by reference, the following requirements:
: 2.     Verification of test prerequisites
: 1.
: 3.     Identification and description of acceptance or rejection criteria
Performance of tests by trained personnel who are qualified in accordance with applicable codes and standards
: 4.     Instructions for performing the test.
: 2.
17.2.11.3   Surveillance Testing Provisions will be established for the performance of surveillance testing to ensure that the necessary quality of systems and components is maintained, that facility operations are within the safety limits, and that limiting conditions of operation can be met. The testing frequency will be at least as frequent as prescribed in the Technical Specifications.     The provisions for surveillance testing will include the preparation of schedules that reflect the status of planned surveillance tests. Qualified plant staff will perform surveillance tests.
Verification of test prerequisites
17.2.11.4   Personnel Qualification Personnel performing testing will be trained and qualified. The personnel will be competent and cognizant of the technical requirements of the work activity.
: 3.
17.2.11.5   Documentation and Records Test procedures and results will be documented     and approved by qualified personnel.
Identification and description of acceptance or rejection criteria
Test   results   shall   be documented   and   indicate   that   the prerequisites and other test requirements have been met.
: 4.
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Instructions for performing the test.
17.2.11.3 Surveillance Testing Provisions will be established for the performance of surveillance testing to ensure that the necessary quality of systems and components is maintained, that facility operations are within the safety limits, and that limiting conditions of operation can be met.
The testing frequency will be at least as frequent as prescribed in the Technical Specifications.
The provisions for surveillance testing will include the preparation of schedules that reflect the status of planned surveillance tests. Qualified plant staff will perform surveillance tests.
17.2.11.4 Personnel Qualification Personnel performing testing will be trained and qualified.
The personnel will be competent and cognizant of the technical requirements of the work activity.
17.2.11.5 Documentation and Records Test procedures and results will be documented and approved by qualified personnel.
Test results shall be documented and indicate that the prerequisites and other test requirements have been met.
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17.2.12   CONTROL OF MEASURING AND TEST EQUIPMENT 17.2.12.1   Scope The responsibility for the control of measuring and test equipment and permanently installed plant instrumentation, is that of the DAEC. The control measures will include the identification and calibration of the equipment to the activity.       The requirements contained within this section do not apply to devices for which normal industry practice provides adequate control, that is, tape measures, rulers, and measuring glasses.
17.2.12 CONTROL OF MEASURING AND TEST EQUIPMENT 17.2.12.1 Scope The responsibility for the control of measuring and test equipment and permanently installed plant instrumentation, is that of the DAEC.
17.2.12.2   General Requirements Measures will be established for the control,       calibration,   and adjustment of measuring and testing devices.
The control measures will include the identification and calibration of the equipment to the activity.
The requirements contained within this section do not apply to devices for which normal industry practice provides adequate control, that is, tape measures, rulers, and measuring glasses.
17.2.12.2 General Requirements Measures will be established for the control, calibration, and adjustment of measuring and testing devices.
Calibration intervals will be based on required accuracy, the use of equipment, stability characteristics, or other factors affecting the measurement.
Calibration intervals will be based on required accuracy, the use of equipment, stability characteristics, or other factors affecting the measurement.
The following requirements will be specified in written procedures that are used to control measuring and test equipment:
The following requirements will be specified in written procedures that are used to control measuring and test equipment:
: 1.     Identification   of   equipment and   traceability     to calibration data
: 1.
: 2.     Calibration methods, frequency, maintenance,   and control
Identification of equipment and traceability to calibration data
: 3.     Labeling and marking of portable equipment to indicate due date for next calibration. Due dates for permanently installed plant equipment are controlled by means of a central record system.
: 2.
: 4.     Provisions for determining the validity of previous measurements when equipment is determined to be out of calibration.
Calibration methods, frequency, maintenance, and control
: 5.     Traceability of reference and transfer standards to nationally recognized standards. When national standards do not exist, the basis for calibration shall be documented.
: 3.
Calibration may be performed at the         DAEC   or   by   qualified laboratories using competent personnel.
Labeling and marking of portable equipment to indicate due date for next calibration.
Due dates for permanently installed plant equipment are controlled by means of a central record system.
: 4.
Provisions for determining the validity of previous measurements when equipment is determined to be out of calibration.
: 5.
Traceability of reference and transfer standards to nationally recognized standards.
When national standards do not exist, the basis for calibration shall be documented.
Calibration may be performed at the DAEC or by qualified laboratories using competent personnel.
Equipment that is consistently found to be out of calibration shall be repaired or replaced.
Equipment that is consistently found to be out of calibration shall be repaired or replaced.
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17.2-27 Revision 14 To be determined


When the accuracy of the measuring or test device can be adversely affected by environmental conditions, special controls will be prescribed to minimize such effects.
When the accuracy of the measuring or test device can be adversely affected by environmental conditions, special controls will be prescribed to minimize such effects.
17.2.12.3   Traceability The measuring and test equipment will be traceable to the item on which the equipment has been used.
17.2.12.3 Traceability The measuring and test equipment will be traceable to the item on which the equipment has been used.
When calibration, testing, or other measuring devices are found to be out of calibration, an evaluation shall be made and documented concerning the validity of previous tests and the acceptability of devices previously     tested from the     time of   the previous calibration.
When calibration, testing, or other measuring devices are found to be out of calibration, an evaluation shall be made and documented concerning the validity of previous tests and the acceptability of devices previously tested from the time of the previous calibration.
17.2.13   HANDLING, STORAGE, AND SHIPPING 17.2.13.1   Scope The handling, storage, shipping, cleaning, and preservation of material and equipment will be controlled to prevent damage, deterioration, and loss.
17.2.13 HANDLING, STORAGE, AND SHIPPING 17.2.13.1 Scope The handling,
: storage, shipping, cleaning, and preservation of material and equipment will be controlled to prevent damage, deterioration, and loss.
It is the responsibility of the organization initiating procurement to specify any special instructions and requirements for packaging and handling, shipping, and extended storage.
It is the responsibility of the organization initiating procurement to specify any special instructions and requirements for packaging and handling, shipping, and extended storage.
It is the responsibility of the DAEC to provide for the proper handling and storage of material and equipment upon receipt and throughout repair, replacement, and modification.
It is the responsibility of the DAEC to provide for the proper handling and storage of material and equipment upon receipt and throughout repair, replacement, and modification.
17.2.13.2   General Requirements Measures will be established to control the handling, storage, shipping, cleaning, and preservation of material and equipment in accordance with work and inspection instructions to prevent damage or deterioration.
17.2.13.2 General Requirements Measures will be established to control the handling,
When necessary     for particular products, special protective environments such as inert gas atmosphere, temperature levels, and specific moisture-content levels will be specified and provided.
: storage, shipping, cleaning, and preservation of material and equipment in accordance with work and inspection instructions to prevent damage or deterioration.
When necessary for particular products, special protective environments such as inert gas atmosphere, temperature levels, and specific moisture-content levels will be specified and provided.
Consistent with the need for preservation, material and equipment will be suitably cleaned to prevent contamination and degradation.
Consistent with the need for preservation, material and equipment will be suitably cleaned to prevent contamination and degradation.
The cleaning method selected will in itself not damage or contaminate the material or equipment.
The cleaning method selected will in itself not damage or contaminate the material or equipment.
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17.2-28 Revision 14 To be determined


17.2.13.3   Shipping When required to prevent contamination or to prevent damage during shipment, special packaging methods will be specified and implemented.
17.2.13.3 Shipping When required to prevent contamination or to prevent damage during
Special-handling requirements, if required, will be specified in the shipping instructions.     The package should be appropriately marked to indicate that special handling or storage requirements are necessary.
: shipment, special packaging methods will be specified and implemented.
Special-handling requirements, if required, will be specified in the shipping instructions.
The package should be appropriately marked to indicate that special handling or storage requirements are necessary.
Markings of packages will conform to applicable Federal and state regulations.
Markings of packages will conform to applicable Federal and state regulations.
17.2.13.4   Radioactive Materials Measures will also be established to control the shipping of licensed radioactive materials in accordance with 10 CFR Part 71.
17.2.13.4 Radioactive Materials Measures will also be established to control the shipping of licensed radioactive materials in accordance with 10 CFR Part 71.
These measures will apply to the use of shipping containers only, and not to the design and fabrication of shipping containers for which an NRC certification is required under Part 71.
These measures will apply to the use of shipping containers only, and not to the design and fabrication of shipping containers for which an NRC certification is required under Part 71.
17.2.13.5   Handling The requirements for special handling will be considered when the item is moved from the receipt point to the storage area and from the storage area to the point of use. Special-handling equipment will be periodically tested and inspected.
17.2.13.5 Handling The requirements for special handling will be considered when the item is moved from the receipt point to the storage area and from the storage area to the point of use. Special-handling equipment will be periodically tested and inspected.
17.2.13.6   Storage Materials and equipment will be stored to minimize the possibility of damage or lowering of quality from the time an item is stored on receipt until the time the item is removed from storage.
17.2.13.6 Storage Materials and equipment will be stored to minimize the possibility of damage or lowering of quality from the time an item is stored on receipt until the time the item is removed from storage.
The manufacturers' recommendations are considered; however, the relaxation   of   manufacturers'     storage   requirements   may be implemented if   the storage   recommendations   are not reasonably necessary to preclude equipment degradation.               Material and equipment will be     stored at   locations   that have a designated storage level. The various storage     levels will be defined and will have prescribed environmental conditions. The storage         conditions will be in accordance with design and procurement requirements to preclude damage, loss or deterioration due to harsh environmental conditions. Items having limited shelf life will be identified and controlled to preclude the use of items whose shelf life has expired.
The manufacturers' recommendations are considered; however, the relaxation of manufacturers' storage requirements may be implemented if the storage recommendations are not reasonably necessary to preclude equipment degradation.
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Material and equipment will be stored at locations that have a designated storage level.
The various storage levels will be defined and will have prescribed environmental conditions. The storage conditions will be in accordance with design and procurement requirements to preclude damage, loss or deterioration due to harsh environmental conditions.
Items having limited shelf life will be identified and controlled to preclude the use of items whose shelf life has expired.
17.2-29 Revision 14 To be determined


17.2.14   INSPECTION, TEST, AND OPERATING STATUS 17.2.14.1   Scope Measures will be established to ensure that necessary inspections of items have not been inadvertently bypassed or that systems or components are not inadvertently operated.
17.2.14 INSPECTION, TEST, AND OPERATING STATUS 17.2.14.1 Scope Measures will be established to ensure that necessary inspections of items have not been inadvertently bypassed or that systems or components are not inadvertently operated.
17.2.14.2   General Requirements Measures will be established to indicate, by the use of marking such as stamps, tags, labels, routing cards, log books, or other suitable means, the status of inspection, test and operating status of individual structures, systems, or components.
17.2.14.2 General Requirements Measures will be established to indicate, by the use of marking such as stamps, tags, labels, routing cards, log books, or other suitable means, the status of inspection, test and operating status of individual structures, systems, or components.
Procedures will provide for controls to preclude the inadvertent use of nonconforming, inoperative, or malfunctioning structures, systems, or components.
Procedures will provide for controls to preclude the inadvertent use of nonconforming, inoperative, or malfunctioning structures, systems, or components.
The procedures will include the following:
The procedures will include the following:
: 1. Identification of authority for application and removal of status indicators
: 1.
: 2. The use of specific status indicators
Identification of authority for application and removal of status indicators
: 3. Provisions for maintaining the status of the structures, systems, or components until removed by an appropriate authority.
: 2.
17.2.14.3   Inspection and Test Status Measures will be established to provide for the identification of items that have satisfactorily passed required inspections and tests.
The use of specific status indicators
: 3.
Provisions for maintaining the status of the structures, systems, or components until removed by an appropriate authority.
17.2.14.3 Inspection and Test Status Measures will be established to provide for the identification of items that have satisfactorily passed required inspections and tests.
Only items that have passed inspection or testing will be used in the manufacture or installation of an item.
Only items that have passed inspection or testing will be used in the manufacture or installation of an item.
Documented procedure requirements will include the following:
Documented procedure requirements will include the following:
: 1. Maintenance of the status     of the item throughout fabrication and installation
: 1.
: 2. Use of status indicators such as stamps, tags, markings, or labels either on the items or on documents traceable to the items 17.2-30                 Revision 14 To be determined
Maintenance of the status of the item throughout fabrication and installation
: 3. Provisions for controlling the bypassing of required inspections, tests, and other critical operations.
: 2.
Use of status indicators such as stamps, tags, markings, or labels either on the items or on documents traceable to the items 17.2-30 Revision 14 To be determined
: 3.
Provisions for controlling the bypassing of required inspections, tests, and other critical operations.
Items at the DAEC will be identified by status indicators to indicate whether they are awaiting inspection, acceptable for use, unacceptable, or in a hold status pending further evaluation.
Items at the DAEC will be identified by status indicators to indicate whether they are awaiting inspection, acceptable for use, unacceptable, or in a hold status pending further evaluation.
17.2.14.4. Operating Status Procedures relating to the operational status of safety-related structures,   systems,     and   components,   including   temporary modifications, will include the following:
17.2.14.4. Operating Status Procedures relating to the operational status of safety-related structures,
: 1. Authorization   for requesting that equipment be removed from service
: systems, and components, including temporary modifications, will include the following:
: 2. Checks that must be made before approving the request
: 1.
: 3. Approval of the   action to remove   the equipment from service
Authorization for requesting that equipment be removed from service
: 4. The actions necessary to isolate the equipment           and responsibility for performing these actions
: 2.
: 5. The actions necessary to return the equipment to its operating status and responsibility for these actions.
Checks that must be made before approving the request
: 3.
Approval of the action to remove the equipment from service
: 4.
The actions necessary to isolate the equipment and responsibility for performing these actions
: 5.
The actions necessary to return the equipment to its operating status and responsibility for these actions.
Equipment and systems in a controlled status will be identified.
Equipment and systems in a controlled status will be identified.
Plant procedures will establish controls to identify the status of inspection and test activities associated with maintenance, instrumentation, and control system calibration and testing. The status of nonconforming, inoperative, or malfunctioning structures, systems, and components will be documented and identified to prevent inadvertent use.
Plant procedures will establish controls to identify the status of inspection and test activities associated with maintenance, instrumentation, and control system calibration and testing. The status of nonconforming, inoperative, or malfunctioning structures, systems, and components will be documented and identified to prevent inadvertent use.
The Technical Specifications establish the status required for safe plant operation, including provisions for periodic and non-periodic tests and inspections, of various structures, systems, and components. Periodic tests may be operational tests or tests following maintenance, and non-periodic tests may be made following repairs or modifications.
The Technical Specifications establish the status required for safe plant operation, including provisions for periodic and non-periodic tests and inspections, of various structures,
17.2.14.5   Sequence Change Control Procedures will include the control of the sequence of required tests, inspections, and other operations when important to safety.
: systems, and components.
Periodic tests may be operational tests or tests following maintenance, and non-periodic tests may be made following repairs or modifications.
17.2.14.5 Sequence Change Control Procedures will include the control of the sequence of required tests, inspections, and other operations when important to safety.
To change these controls, the individual procedure must be changed, which requires the same review and approval cycle as that which authorized the original procedure.
To change these controls, the individual procedure must be changed, which requires the same review and approval cycle as that which authorized the original procedure.
17.2-31                 Revision 14 To be determined
17.2-31 Revision 14 To be determined


17.2.15   NONCONFORMING MATERIALS, PARTS, OR COMPONENTS 17.2.15.1   Scope The nonconformance reporting system is established to control materials, parts or components which do not conform to requirements in order to prevent their inadvertent use or installation.     The responsibility for identification, documentation and segregation of nonconforming materials, parts, or components and notification to affected organizations, is that of the Corporate Quality Assurance Department. The responsibility for the disposition of the nonconforming materials, parts, or components is that of the Engineering Department, DAEC, and the Corporate Quality Assurance Department.
17.2.15 NONCONFORMING MATERIALS, PARTS, OR COMPONENTS 17.2.15.1 Scope The nonconformance reporting system is established to control materials, parts or components which do not conform to requirements in order to prevent their inadvertent use or installation.
17.2.15.2   Identification and Segregation The identification and segregation will be sufficient to prevent inadvertent use or installation of the nonconforming item.
The responsibility for identification, documentation and segregation of nonconforming materials, parts, or components and notification to affected organizations, is that of the Corporate Quality Assurance Department.
Material, parts, or components for which nonconformances have been identified will be immediately segregated, when practical, in areas that are reserved for nonconforming items. When segregation is impractical, administrative measures will be used, such as tagging, roping off the area, etc.
The responsibility for the disposition of the nonconforming materials, parts, or components is that of the Engineering Department, DAEC, and the Corporate Quality Assurance Department.
17.2.15.3   Reporting and Disposition The reporting mechanism will provide the means to disposition the nonconforming material, part, or component.
17.2.15.2 Identification and Segregation The identification and segregation will be sufficient to prevent inadvertent use or installation of the nonconforming item.
Material, parts, or components for which nonconformances have been identified will be immediately segregated, when practical, in areas that are reserved for nonconforming items.
When segregation is impractical, administrative measures will be used, such as tagging, roping off the area, etc.
17.2.15.3 Reporting and Disposition The reporting mechanism will provide the means to disposition the nonconforming material, part, or component.
The 'nonconformance report will identify the item, describe the nonconformance, and contain sufficient information to evaluate the nonconformance. The nonconformance report will be transmitted to the proper organization(s) for evaluation and disposition.
The 'nonconformance report will identify the item, describe the nonconformance, and contain sufficient information to evaluate the nonconformance. The nonconformance report will be transmitted to the proper organization(s) for evaluation and disposition.
17.2.15.4   Disposition The disposition will be limited to one of the following:
17.2.15.4 Disposition The disposition will be limited to one of the following:
use-as-is, rework to original requirements, repair to an acceptable condition, or reject.
use-as-is, rework to original requirements, repair to an acceptable condition, or reject.
For disposition of use-as-is and repair, a technical justification will provide assurance that the item will function as originally intended.
For disposition of use-as-is and repair, a technical justification will provide assurance that the item will function as originally intended.
Items that are to be repaired or reworked will be required to be reinspected or retested to determine that the original or new acceptance criteria have been satisfied.
Items that are to be repaired or reworked will be required to be reinspected or retested to determine that the original or new acceptance criteria have been satisfied.
17.2-32                 Revision 14 To be determined
17.2-32 Revision 14 To be determined


17.2.16   CORRECTIVE ACTION 17.2.16.1   Scope Corrective action control measures will be established to ensure that conditions adverse to quality are promptly identified, reported, and corrected. Corrective action is necessary to correct omissions and problems in the Operational Quality Assurance Program.
17.2.16 CORRECTIVE ACTION 17.2.16.1 Scope Corrective action control measures will be established to ensure that conditions adverse to quality are promptly identified, reported, and corrected.
17.2.16.2   Conditions Adverse to Quality Conditions adverse to quality will       be   identified   promptly and corrected as soon as practical.
Corrective action is necessary to correct omissions and problems in the Operational Quality Assurance Program.
Conditions adverse to quality may be identified         by a number   of techniques such as:
17.2.16.2 Conditions Adverse to Quality Conditions adverse to quality will be identified promptly and corrected as soon as practical.
: 1. Audits of Iowa Electric by regulatory agencies
Conditions adverse to quality may be identified by a number of techniques such as:
: 2. Internal audits
: 1.
: 3. Audits of suppliers by Iowa Electric
Audits of Iowa Electric by regulatory agencies
: 4. Quality Assurance surveillance activities
: 2.
: 5. Management reviews
Internal audits
: 6. Nonconformance reports.
: 3.
Each of the above techniques has a mechanism             to   effect the correction of the condition adverse to quality.
Audits of suppliers by Iowa Electric
17.2.16.3   Significant Conditions Adverse to Quality The Corporate Quality Assurance Department will perform an analysis of conditions adverse to quality to determine if a significant condition adverse to quality exists.
: 4.
The Corporate Quality Assurance Department will perform an analysis to determine if there are any broad programmatic problem areas or if any negative trends are detectable.           This analysis will be performed at least annually and will be reported to the appropriate levels of management. The analysis will be documented and retained as a quality assurance   record.
Quality Assurance surveillance activities
Significant conditions     adverse to quality that impede the implementation or reduce the effectiveness of the program will be controlled. These conditions will be reported to appropriate management and evaluated.     The cause of a significant condition adverse to quality shall be determined, and corrective action will be taken to preclude repetition. Significant adverse conditions may include a recurring condition for which past corrective action has been ineffective, significant trends adverse to quality, or significant Operational Quality Assurance Program deficiencies.
: 5.
17.2-33                     Revision 14 To be determined
Management reviews
: 6.
Nonconformance reports.
Each of the above techniques has a mechanism to effect the correction of the condition adverse to quality.
17.2.16.3 Significant Conditions Adverse to Quality The Corporate Quality Assurance Department will perform an analysis of conditions adverse to quality to determine if a significant condition adverse to quality exists.
The Corporate Quality Assurance Department will perform an analysis to determine if there are any broad programmatic problem areas or if any negative trends are detectable.
This analysis will be performed at least annually and will be reported to the appropriate levels of management.
The analysis will be documented and retained as a quality assurance record.
Significant conditions adverse to quality that impede the implementation or reduce the effectiveness of the program will be controlled.
These conditions will be reported to appropriate management and evaluated.
The cause of a significant condition adverse to quality shall be determined, and corrective action will be taken to preclude repetition.
Significant adverse conditions may include a recurring condition for which past corrective action has been ineffective, significant trends adverse to quality, or significant Operational Quality Assurance Program deficiencies.
17.2-33 Revision 14 To be determined


17.2.16.4   Reporting of 10 CFR 21 Defects and Non-compliances A 10 CFR 21 defect and noncompliance is defined as one which could reasonably indicate a potential substantial safety hazard.
17.2.16.4 Reporting of 10 CFR 21 Defects and Non-compliances A 10 CFR 21 defect and noncompliance is defined as one which could reasonably indicate a potential substantial safety hazard.
A procedure has been established and posted so that Iowa Electric employees will be aware of the methods by which 10 CFR 21 defects and non-compliances are reported to the NRC.
A procedure has been established and posted so that Iowa Electric employees will be aware of the methods by which 10 CFR 21 defects and non-compliances are reported to the NRC.
The President and Chief Operating Officer and the Vice President Nuclear, are designated as the Iowa Electric officers responsible for reporting defects and non-compliances, as appropriate, to the NRC.
The President and Chief Operating Officer and the Vice President Nuclear, are designated as the Iowa Electric officers responsible for reporting defects and non-compliances, as appropriate, to the NRC.
17.2.17   QUALITY ASSURANCE RECORDS 17.2.17.1   Scope Quality assurance records will be prepared, identified, collected, and protected so that adequate evidence of activities affecting quality is available.
17.2.17 QUALITY ASSURANCE RECORDS 17.2.17.1 Scope Quality assurance records will be prepared, identified, collected, and protected so that adequate evidence of activities affecting quality is available.
17.2.17.2   Preparation and Identification of Quality Assurance Records The organization responsible for the activity will also be responsible for the preparation and identification of the quality assurance records that attest to the quality of that activity.
17.2.17.2 Preparation and Identification of Quality Assurance Records The organization responsible for the activity will also be responsible for the preparation and identification of the quality assurance records that attest to the quality of that activity.
As a general criterion, those documents that reflect the as-built condition of an item, component, system, or plant, and those documents that attest to the quality of an activity, item, structure, or system will be treated as quality assurance records.
As a general criterion, those documents that reflect the as-built condition of an item, component, system, or plant, and those documents that attest to the quality of an activity, item, structure, or system will be treated as quality assurance records.
Also, the qualification records of inspection, examination and testing personnel, and quality assurance audit personnel, are classified as quality assurance records.
: Also, the qualification records of inspection, examination and testing personnel, and quality assurance audit personnel, are classified as quality assurance records.
Quality assurance records will be legible, accurate, and complete.
Quality assurance records will be legible, accurate, and complete.
17.2.17.3   Collection and Protection of Quality Assurance Records The quality assurance records       will be   collected, indexed, classified, and protected.
17.2.17.3 Collection and Protection of Quality Assurance Records The quality assurance records will be collected,
The organization that generates the quality assurance record will be responsible for collecting the records. The collected quality assurance records will be classified as either lifetime or non permanent quality assurance records. The lack of a classification will mean that the quality assurance record is a lifetime record.
: indexed, classified, and protected.
17.2-34                 Revision 14 To be determined
The organization that generates the quality assurance record will be responsible for collecting the records. The collected quality assurance records will be classified as either lifetime or non permanent quality assurance records.
The lack of a classification will mean that the quality assurance record is a lifetime record.
17.2-34 Revision 14 To be determined


The quality assurance records that have been identified and collected will be suitably protected against fire, theft, and damage. The manner in which the records are protected will be consistent with the retention period.
The quality assurance records that have been identified and collected will be suitably protected against fire, theft, and damage.
17.2.17.4 Record Storage on Optical Disks Records may be stored on an optical disk storage system which utilizes a write once read many (WORM) system. The image of each record shall be placed onto two optical disks, with verification of the image on each record. Should any of the images be illegible, the hard copy record is maintained as the record. One optical disk shall be used for on-line access and the second optical disk shall be stored in a records storage facility meeting the requirements for single copy storage or in a separate remote location meeting the requirements of Iowa Electric's commitment to ANSI N45.2.9 1974.
The manner in which the records are protected will be consistent with the retention period.
17.2.17.4 Record Storage on Optical Disks Records may be stored on an optical disk storage system which utilizes a write once read many (WORM) system. The image of each record shall be placed onto two optical disks, with verification of the image on each record. Should any of the images be illegible, the hard copy record is maintained as the record.
One optical disk shall be used for on-line access and the second optical disk shall be stored in a records storage facility meeting the requirements for single copy storage or in a separate remote location meeting the requirements of Iowa Electric's commitment to ANSI N45.2.9 1974.
To ensure permanent retention of records, the records stored on an optical disk are acceptably copied onto a new optical disk before the manufacturer's certified useful life of the original disk is exceeded. Records copied shall be verified.
To ensure permanent retention of records, the records stored on an optical disk are acceptably copied onto a new optical disk before the manufacturer's certified useful life of the original disk is exceeded. Records copied shall be verified.
Periodic random inspections of images stored on optical disks are performed to verify that there has been no degradation of image quality.
Periodic random inspections of images stored on optical disks are performed to verify that there has been no degradation of image quality.
Should it become necessary to replace the optical imaging system with a new system which is not compatible, the records stored on the old system shall be converted onto the new system prior to the old system being taken out of service. This conversion process shall include a verification of the records converted.
Should it become necessary to replace the optical imaging system with a new system which is not compatible, the records stored on the old system shall be converted onto the new system prior to the old system being taken out of service.
17.2.17.5   Transfer or Destruction of Records The organization responsible for the quality assurance record will be responsible for the transfer of that quality assurance record for the purposes of microfilming and/or lifetime storage.
This conversion process shall include a verification of the records converted.
17.2.17.5 Transfer or Destruction of Records The organization responsible for the quality assurance record will be responsible for the transfer of that quality assurance record for the purposes of microfilming and/or lifetime storage.
The transfer of quality assurance records from one organization to another organization will be accomplished by a formal mechanism that provides for the acceptance of the quality assurance record.
The transfer of quality assurance records from one organization to another organization will be accomplished by a formal mechanism that provides for the acceptance of the quality assurance record.
The destruction of quality assurance records will be accomplished only with the approval of the concerned organizations.
The destruction of quality assurance records will be accomplished only with the approval of the concerned organizations.
17.2-35                 Revision 14 To be determined
17.2-35 Revision 14 To be determined


17.2.18   AUDITS 17.2.18.1     Scope A comprehensive audit program will be established and implemented.
17.2.18 AUDITS 17.2.18.1 Scope A comprehensive audit program will be established and implemented.
The audit program will be sufficient to verify compliance with the Operational Quality Assurance Program and to determine the effectiveness of the Operational Quality Assurance Program.
The audit program will be sufficient to verify compliance with the Operational Quality Assurance Program and to determine the effectiveness of the Operational Quality Assurance Program.
The   responsibility   for the audit system will be that of the Corporate Quality Assurance Department, the Safety Committee, and the Vice President - Nuclear.
The responsibility for the audit system will be that of the Corporate Quality Assurance Department, the Safety Committee, and the Vice President -
17.2.18.2     Audit System The audit system will be applied to those organizations, both external and internal to Iowa Electric, that are involved in safety-related activities.
Nuclear.
17.2.18.2.1     External Organizations The audit program for suppliers is the responsibility of the Corporate Quality Assurance Department. Audits will be scheduled at a frequency commensurate with the status and importance of the activity.
17.2.18.2 Audit System The audit system will be applied to those organizations, both external and internal to Iowa Electric, that are involved in safety-related activities.
17.2.18.2.1 External Organizations The audit program for suppliers is the responsibility of the Corporate Quality Assurance Department. Audits will be scheduled at a frequency commensurate with the status and importance of the activity.
In general, the audit schedule will be responsive to the performance of audits before the initiation of an activity to ensure that the proper controls are in place, during the early stages of the activity to determine that the proper controls are being implemented, and near the end of the activity to determine that all specified requirements have been met.
In general, the audit schedule will be responsive to the performance of audits before the initiation of an activity to ensure that the proper controls are in place, during the early stages of the activity to determine that the proper controls are being implemented, and near the end of the activity to determine that all specified requirements have been met.
In general, the audit schedule will also include the performance of audits during the activity, assuming that the activity occurs over a sufficient length of time, to determine that the proper controls are being applied and no problems are occurring.
In general, the audit schedule will also include the performance of audits during the activity, assuming that the activity occurs over a sufficient length of time, to determine that the proper controls are being applied and no problems are occurring.
17.2.18.2.2     Internal Organizations The audit program for the internal Iowa Electric organizations is the responsibility of the following:
17.2.18.2.2 Internal Organizations The audit program for the internal Iowa Electric organizations is the responsibility of the following:
: 1.       The Corporate Quality Assurance Department, to determine the compliance of the other organizations to the Operational Quality Assurance Program and to evaluate performance.
: 1.
17.2-36                 Revision 14 To be determined
The Corporate Quality Assurance Department, to determine the compliance of the other organizations to the Operational Quality Assurance Program and to evaluate performance.
: 2. The Safety Committee, to determine the compliance of the DAEC to the Technical Specification requirements and license provisions and to evaluate performance.
17.2-36 Revision 14 To be determined
: 3. The Vice President - Nuclear, to determine the overall effectiveness of the Operational Quality Assurance Program.
: 2.
The audit schedule will cover the total Iowa Electric         audit activities over a period of time not exceeding two years.
The Safety Committee, to determine the compliance of the DAEC to the Technical Specification requirements and license provisions and to evaluate performance.
17.2.18.3   Personnel Training and Qualification The personnel who participate in audits will have sufficient experience and/or training to fulfill their role in the audit.
: 3.
The Vice President -
Nuclear, to determine the overall effectiveness of the Operational Quality Assurance Program.
The audit schedule will cover the total Iowa Electric audit activities over a period of time not exceeding two years.
17.2.18.3 Personnel Training and Qualification The personnel who participate in audits will have sufficient experience and/or training to fulfill their role in the audit.
Personnel who perform as Lead Auditors will be trained, qualified, and certified.
Personnel who perform as Lead Auditors will be trained, qualified, and certified.
A Lead Auditor will review the experience of each potential team member, determine their acceptability to perform the audit, determine if any additional training is required, and ensure that the additional training is performed if required.
A Lead Auditor will review the experience of each potential team member, determine their acceptability to perform the audit, determine if any additional training is required, and ensure that the additional training is performed if required.
17.2.18.4   Performance of Audit The selected audit team shall collectively have experience       or training commensurate with the total scope of the audit.
17.2.18.4 Performance of Audit The selected audit team shall collectively have experience or training commensurate with the total scope of the audit.
Audit checklists will be developed for the total scope of the audit. The audit should be initiated by a pre-audit conference to introduce the audit team and to confirm the scope and plan of the audit and be concluded with a post-audit conference. During the post-audit conference, the Audit Team will discuss the audit findings and clarify misunderstandings.
Audit checklists will be developed for the total scope of the audit. The audit should be initiated by a pre-audit conference to introduce the audit team and to confirm the scope and plan of the audit and be concluded with a post-audit conference.
17.2.18.5   Report and Closeout of Audit Findings The audit will be documented by an audit report signed by a Lead Auditor.
During the post-audit conference, the Audit Team will discuss the audit findings and clarify misunderstandings.
17.2.18.5 Report and Closeout of Audit Findings The audit will be documented by an audit report signed by a Lead Auditor.
The audit report shall be sent to the responsible management of the audited organization.
The audit report shall be sent to the responsible management of the audited organization.
The audit findings will be tracked to ensure that corrective action has occurred.
The audit findings will be tracked to ensure that corrective action has occurred.
The Corporate Quality Assurance Department will evaluate the responses to the audit findings. The evaluation will include the necessity for re-audits, submittal of documentation, or any other means of verifying the corrective action.       Statements by the 17.2-37                 Revision 14 To be determined
The Corporate Quality Assurance Department will evaluate the responses to the audit findings.
The evaluation will include the necessity for re-audits, submittal of documentation, or any other means of verifying the corrective action.
Statements by the 17.2-37 Revision 14 To be determined


audited organization that define the corrective action may be accepted.
audited organization that define the corrective action may be accepted.
The corrective actions will be tracked to ensure that proper and timely corrective actions have occurred prior to closure of the audit findings.
The corrective actions will be tracked to ensure that proper and timely corrective actions have occurred prior to closure of the audit findings.
Inadequate or unresponsive corrective action will be brought to the attention of appropriate levels of management.
Inadequate or unresponsive corrective action will be brought to the attention of appropriate levels of management.
Proced/UFSAR17-2.R14 17.2-38                 Revision 14 To be determined
Proced/UFSAR17-2.R14 17.2-38 Revision 14 To be determined


Iowa Electric Light and Power Company Appendix A to UFSAR/DAEC-l Chapter 17.2 QUALITY ASSURANCE DURING THE OPERATIONS PHASE Quality Assurance Program Description (QAPD)
Iowa Electric Light and Power Company Appendix A to UFSAR/DAEC-l Chapter 17.2 QUALITY ASSURANCE DURING THE OPERATIONS PHASE Quality Assurance Program Description (QAPD)
INTRODUCTION This Appendix describes the manner by which the Iowa Electric Operational Quality Assurance Program for the Duane Arnold Energy Center (DAEC), as set forth in the Quality Assurance Program Description (QAPD), UFSAR Chapter 17.2, conforms to NRC Regulatory Guides listed in the June 6, 1990, letter from Region III (Miller) to Iowa Electric (Liu) and certain other commitments previously contained in Table 2-1 of the Quality Assurance Manual. Comments and clarifications to these specific commitments are identified in this Appendix.
INTRODUCTION This Appendix describes the manner by which the Iowa Electric Operational Quality Assurance Program for the Duane Arnold Energy Center (DAEC), as set forth in the Quality Assurance Program Description (QAPD), UFSAR Chapter 17.2, conforms to NRC Regulatory Guides listed in the {{letter dated|date=June 6, 1990|text=June 6, 1990, letter}} from Region III (Miller) to Iowa Electric (Liu) and certain other commitments previously contained in Table 2-1 of the Quality Assurance Manual.
Iowa Electric's       position on each ANSI standard which is endorsed by a Regulatory Guide to which Iowa Electric is committed is stated in either the UFSAR or the QAPD.               Other ANSI standards are not requirements for Iowa Electric even if they are listed as references in a standard endorsed by a Regulatory Guide to which Iowa Electric is committed.           (Such standards may, of course, be used as guidance.)           However, a section of a standard which is specifically referred to in a standard endorsed by a Regulatory Guide to which Iowa Electric is committed is a requirement for Iowa Electric unless an exception is stated.
Comments and clarifications to these specific commitments are identified in this Appendix.
Iowa Electric is not committed to ANSI N45.2 for the operational phase. Regulatory Guide 1.33, Revision 2, Section B, "Discussion" states ANSI N18.7-1972,           along with ANSI N45.2-1971,     "Quality Assurance Program Requirements for Nuclear Power Plants",             was endorsed by Regulatory Guide 1.33.               The dual endorsement was necessary in order for the guidance contained in the regulatory guide to be consistent with the requirements of Appendix B to 10 CFR Part 50; however, this dual endorsement caused some confusion among users.         To clarify this situation, ANSI N18.7-1972 was revised so that a single standard would define the general quality assurance program "requirements" for the operation phase.             This revised   standard     was approved   by the American National Standards Committee N18, Nuclear Design Criteria.               It was subsequently approved       and   designated     N18.7-1976/ANS-3.2,   "Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants", by the American National Standards Institute             on February 19, 1976.         Therefore, for the operations phase, where a standard endorsed by a Regulatory Guide refers to the use of ANSI N45.2 in conjunction with that Standard, Iowa Electric inserts the ANSI Standard N18.7-1976.
Iowa Electric's position on each ANSI standard which is endorsed by a Regulatory Guide to which Iowa Electric is committed is stated in either the UFSAR or the QAPD.
17.2   A-1                   Revision 14 To be determined
Other ANSI standards are not requirements for Iowa Electric even if they are listed as references in a standard endorsed by a Regulatory Guide to which Iowa Electric is committed.
(Such standards may, of course, be used as guidance.)
: However, a section of a standard which is specifically referred to in a standard endorsed by a Regulatory Guide to which Iowa Electric is committed is a requirement for Iowa Electric unless an exception is stated.
Iowa Electric is not committed to ANSI N45.2 for the operational phase.
Regulatory Guide 1.33, Revision 2, Section B, "Discussion" states ANSI N18.7-1972, along with ANSI N45.2-1971, "Quality Assurance Program Requirements for Nuclear Power Plants",
was endorsed by Regulatory Guide 1.33.
The dual endorsement was necessary in order for the guidance contained in the regulatory guide to be consistent with the requirements of Appendix B to 10 CFR Part 50; however, this dual endorsement caused some confusion among users.
To clarify this situation, ANSI N18.7-1972 was revised so that a single standard would define the general quality assurance program "requirements" for the operation phase.
This revised standard was approved by the American National Standards Committee N18, Nuclear Design Criteria.
It was subsequently approved and designated N18.7-1976/ANS-3.2, "Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants",
by the American National Standards Institute on February 19, 1976.
Therefore, for the operations phase, where a standard endorsed by a Regulatory Guide refers to the use of ANSI N45.2 in conjunction with that Standard, Iowa Electric inserts the ANSI Standard N18.7-1976.
17.2 A-1 Revision 14 To be determined


1.0 REGULATORY GUIDE 1.8, "Personnel Selection and Training" COMMENTS AND CLARIFICATIONS:
1.0 REGULATORY GUIDE 1.8, "Personnel Selection and Training" COMMENTS AND CLARIFICATIONS:
Iowa Electric complies with the Regulatory Position of this Regulatory Guide with the following clarifications:
Iowa Electric complies with the Regulatory Position of this Regulatory Guide with the following clarifications:
1.1   Iowa Electric's       commitment is to Regulatory Guide 1.8, Revision 1-R, September 1975 (reissued May 1977), which endorses ANSI N18.1-1971. However, the Iowa Electric commitment is to ANSI/ANS 3.1-1978, which is a revision of N18.1-1971.
1.1 Iowa Electric's commitment is to Regulatory Guide 1.8, Revision 1-R, September 1975 (reissued May 1977), which endorses ANSI N18.1-1971. However, the Iowa Electric commitment is to ANSI/ANS 3.1-1978, which is a revision of N18.1-1971.
1.2   With respect to selection and training of security personnel, Iowa Electric does not commit to the standard [ANSI N18.17-1973 (ANS 3.3)] referred to in ANSI/ANS       3.1-1978,   Sections   1   (Scope)   and   6 (References).           The   Iowa Electric   training   and qualification plan for security personnel complies with 10 CFR Part 73, Appendix B.
1.2 With respect to selection and training of security personnel, Iowa Electric does not commit to the standard [ANSI N18.17-1973 (ANS 3.3)] referred to in ANSI/ANS 3.1-1978, Sections 1
2.0 REGULATORY GUIDE 1.26,         "Quality Group Classifications and Standards   for       Water-,   Steam-,   and   Radioactive-Waste Containing Components of Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:
(Scope) and 6
(References).
The Iowa Electric training and qualification plan for security personnel complies with 10 CFR Part 73, Appendix B.
2.0 REGULATORY GUIDE 1.26, "Quality Group Classifications and Standards for Water-,
Steam-,
and Radioactive-Waste Containing Components of Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:
The Iowa Electric commitment to Safety Guide 26 (3/23/72),
The Iowa Electric commitment to Safety Guide 26 (3/23/72),
Quality Group Classifications and Standards, is             stated in UFSAR Chapter 1.8, Conformance to NRC Regulatory Guides.
Quality Group Classifications and Standards, is stated in UFSAR Chapter 1.8, Conformance to NRC Regulatory Guides.
3.0 REGULATORY     GUIDE       1.28,   "Quality   Assurance     Program Requirements (Design and Construction)"
3.0 REGULATORY GUIDE 1.28, "Quality Assurance Program Requirements (Design and Construction)"
COMMENTS AND CLARIFICATIONS:
COMMENTS AND CLARIFICATIONS:
This Regulatory Guide (Safety Guide 28, dated June 7, 1972) endorses ANSI N45.2 and is not applicable to the operating phase. DAEC's operational QA program is based on Regulatory Guide 1.33, Rev. 2, as stated in UFSAR Section 1.8.
This Regulatory Guide (Safety Guide 28, dated June 7, 1972) endorses ANSI N45.2 and is not applicable to the operating phase.
DAEC's operational QA program is based on Regulatory Guide 1.33, Rev. 2, as stated in UFSAR Section 1.8.
4.0 REGULATORY GUIDE 1.29, "Seismic Design Classification" COMMENTS AND CLARIFICATIONS:
4.0 REGULATORY GUIDE 1.29, "Seismic Design Classification" COMMENTS AND CLARIFICATIONS:
The Iowa Electric commitment to Safety Guide 29 (6/7/72),
The Iowa Electric commitment to Safety Guide 29 (6/7/72),
Seismic Design Classification, is stated in UFSAR Section 1.8, Conformance to NRC Regulatory Guides.
Seismic Design Classification, is stated in UFSAR Section 1.8, Conformance to NRC Regulatory Guides.
17.2   A-2                     Revision 14 To be determined
17.2 A-2 Revision 14 To be determined


5.0 REGULATORY GUIDE 1.30, "Quality Assurance Requirements for the Installation, Inspection, and Testing of Instrumentation and Electric Equipment" COMMENTS AND CLARIFICATIONS:
5.0 REGULATORY GUIDE 1.30, "Quality Assurance Requirements for the Installation, Inspection, and Testing of Instrumentation and Electric Equipment" COMMENTS AND CLARIFICATIONS:
Iowa Electric complies with the Regulatory Position of this Regulatory Guide with the following clarifications:
Iowa Electric complies with the Regulatory Position of this Regulatory Guide with the following clarifications:
5.1   The Iowa Electric commitment is to Safety Guide 30, dated August 11, 1972 and therefore by reference to ANSI N45.2.4-1972 which it endorses.
5.1 The Iowa Electric commitment is to Safety Guide 30, dated August 11, 1972 and therefore by reference to ANSI N45.2.4-1972 which it endorses.
5.2   For maintenance and modification activities, Iowa Electric shall comply with the Regulatory Position established by this Regulatory Guide in that the quality assurance program requirements included therein (subject to the clarifications below) shall apply.
5.2 For maintenance and modification activities, Iowa Electric shall comply with the Regulatory Position established by this Regulatory Guide in that the quality assurance program requirements included therein (subject to the clarifications below) shall apply.
Technical requirements associated with maintenance and modification activities shall be equal to or better than   the   original   requirements     (eg.,     Code requirements, design and construction specification requirements, and inspection requirements).
Technical requirements associated with maintenance and modification activities shall be equal to or better than the original requirements (eg.,
5.3   Regulatory Position C.1 states that ANSI N45.2.4-1972 should be used in conjunction with ANSI N45.2-1971. In lieu of this, Iowa Electric uses ANSI N45.2.4-1972 in conjunction with ANSI N18.7-1976.
Code requirements, design and construction specification requirements, and inspection requirements).
5.4   Section 2.2(5)(d) of ANSI N45.2.4-1972         requires evidence of compliance by manufacturer with purchase requirements, including quality assurance requirements, before the requirements of ANSI N45.2.4-1972 are implemented. In lieu of this, Iowa Electric may proceed with installation, inspection, and testing activities for equipment lacking its quality documentation provided that this equipment has been identified and controlled in accordance with Iowa Electric's nonconformance reporting system.
5.3 Regulatory Position C.1 states that ANSI N45.2.4-1972 should be used in conjunction with ANSI N45.2-1971.
5.5   With respect to Section 2.5.2 of ANSI N45.2.4-1972, calibration and     control covers     two classes     of instrumentation used by Iowa Electric:     (1) portable equipment and (2) permanently-installed equipment.
In lieu of this, Iowa Electric uses ANSI N45.2.4-1972 in conjunction with ANSI N18.7-1976.
With respect to permanently-installed instrumentation, in lieu of marking the equipment to indicate the date of the next required calibration, a computer-based preventative maintenance program is used.         Once a permanently-installed   instrument is   identified   as needing control, a calibration frequency is assigned, and the information is entered into the data base. The 17.2 A-3                     Revision 14 To be determined
5.4 Section 2.2(5)(d) of ANSI N45.2.4-1972 requires evidence of compliance by manufacturer with purchase requirements, including quality assurance requirements, before the requirements of ANSI N45.2.4-1972 are implemented. In lieu of this, Iowa Electric may proceed with installation, inspection, and testing activities for equipment lacking its quality documentation provided that this equipment has been identified and controlled in accordance with Iowa Electric's nonconformance reporting system.
5.5 With respect to Section 2.5.2 of ANSI N45.2.4-1972, calibration and control covers two classes of instrumentation used by Iowa Electric:
(1) portable equipment and (2) permanently-installed equipment.
With respect to permanently-installed instrumentation, in lieu of marking the equipment to indicate the date of the next required calibration, a computer-based preventative maintenance program is used.
Once a permanently-installed instrument is identified as needing control, a calibration frequency is assigned, and the information is entered into the data base.
The 17.2 A-3 Revision 14 To be determined


calibration task is         then automatically tracked and tasked by the data base.         A "DO NOT USE Until Tested and Calibrated" or equivalent sticker is           applied to instruments not calibrated before their         due date and to instruments unacceptable for use.           The provisions of ANSI N45.2.4-1972, Section 2.5.2, are applied to portable equipment.
calibration task is then automatically tracked and tasked by the data base.
5.6   Section       3     of     ANSI     N45.2.4-1972     regarding "Preconstruction Verification" states it is necessary to verify that the quality of an item has not suffered during the interim period and it           is not intended to duplicate inspections but rather verify that items are in   a     satisfactory     condition     for   installation.
A "DO NOT USE Until Tested and Calibrated" or equivalent sticker is applied to instruments not calibrated before their due date and to instruments unacceptable for use.
Verifications and checks are then required.         In lieu of these verifications and checks, Iowa Electric considers the provisions of QAPD Sections 17.2.8 (Identification and Control of Materials, Parts, and Components) and 17.2.13     (Handling, Storage       and   Shipping)   to   be equivalent.
The provisions of ANSI N45.2.4-1972, Section 2.5.2, are applied to portable equipment.
5.7   The last paragraph of Section 6.2.1 of ANSI N45.2.4 1972 requires that items requiring calibration be tagged or labeled on completion, indicating date of calibration and identity of person who performed the calibration.         In lieu of this, for permanently installed instrumentation, the calibration status is reflected in a computerized preventive maintenance program as described in Section 5.5 above.
5.6 Section 3
6.0 REGULATORY     GUIDE     1.33,     "Quality   Assurance     Program Requirements (Operation)"
of ANSI N45.2.4-1972 regarding "Preconstruction Verification" states it is necessary to verify that the quality of an item has not suffered during the interim period and it is not intended to duplicate inspections but rather verify that items are in a
satisfactory condition for installation.
Verifications and checks are then required.
In lieu of these verifications and checks, Iowa Electric considers the provisions of QAPD Sections 17.2.8 (Identification and Control of Materials, Parts, and Components) and 17.2.13 (Handling, Storage and Shipping) to be equivalent.
5.7 The last paragraph of Section 6.2.1 of ANSI N45.2.4 1972 requires that items requiring calibration be tagged or labeled on completion, indicating date of calibration and identity of person who performed the calibration.
In lieu of this, for permanently installed instrumentation, the calibration status is reflected in a computerized preventive maintenance program as described in Section 5.5 above.
6.0 REGULATORY GUIDE 1.33, "Quality Assurance Program Requirements (Operation)"
COMMENTS AND CLARIFICATIONS:
COMMENTS AND CLARIFICATIONS:
Iowa Electric complies with Regulatory Position of               this Regulatory Guide with the following clarifications:
Iowa Electric complies with Regulatory Position of this Regulatory Guide with the following clarifications:
6.1   The commitment is to Regulatory Guide 1.33, Rev. 2, February 1978, and to ANSI N18.7-1976/ANS-3.2 which it endorses.
6.1 The commitment is to Regulatory Guide 1.33, Rev.
6.2   Regulatory Guide 1.33 Regulatory Position, Section C.2, also lists   fifteen Regulatory Guides and ANSI standards that are referenced in ANSI N18.7-1976/ANS-3.2.             The Iowa Electric position with respect to each of these standards is stated elsewhere in this Appendix A.
2, February 1978, and to ANSI N18.7-1976/ANS-3.2 which it endorses.
6.3   Section 4.3.2.3 (Quorum for Independent Review Program) of ANSI N18.7-1976/ANS-3.2 indicates a Quorum for formal meetings     "... shall consist of not less than a 17.2   A-4                       Revision 14 To be determined
6.2 Regulatory Guide 1.33 Regulatory Position, Section C.2, also lists fifteen Regulatory Guides and ANSI standards that are referenced in ANSI N18.7-1976/ANS-3.2.
The Iowa Electric position with respect to each of these standards is stated elsewhere in this Appendix A.
6.3 Section 4.3.2.3 (Quorum for Independent Review Program) of ANSI N18.7-1976/ANS-3.2 indicates a Quorum for formal meetings "...
shall consist of not less than a 17.2 A-4 Revision 14 To be determined


majority   of     the   principals,   or   duly   appointed alternatives..."       Additionally, "the chairman (or his duly appointed alternate) shall be present for all formal meetings".         Section 6.5.2.6 of Appendix A (Technical Specifications) to the Facility Operating License indicates "A Quorum of the Safety Committee shall consist of the Chairman or Vice Chairman and at least four members with a maximum of two alternates as voting members".       The requirements of the Technical Specifications as stated above shall govern.
majority of the principals, or duly appointed alternatives..."
6.4 With respect to Section 4.3.4 (1), Subjects Requiring Independent Review, of ANSI N18.7-1976/ANS-3.2,           the DAEC Safety Committee is not required to review safety evaluations of changes in the facility which are completed under 10 CFR Part 50.59.
Additionally, "the chairman (or his duly appointed alternate) shall be present for all formal meetings".
6.5 Section 5.1     (Program Description) of ANSI N18.7 1976/ANS-3.2   requires a "summary document" for the Quality Assurance Program.         The QAPD and Appendix A thereto fulfill this requirement for Iowa Electric.
Section 6.5.2.6 of Appendix A (Technical Specifications) to the Facility Operating License indicates "A Quorum of the Safety Committee shall consist of the Chairman or Vice Chairman and at least four members with a maximum of two alternates as voting members".
6.6 Section 5.2.7 (Maintenance and Modifications) of ANSI N18.7-1976/ANS-3.2 lists six standards that are to be applied to activities       occurring during the operational phase that are comparable to related activities       during design and construction. Five of these standards are addressed elsewhere in this Appendix A.
The requirements of the Technical Specifications as stated above shall govern.
Iowa Electric does not follow one of those listed,       ANSI N101.4-1972, Quality Assurance for Protective Coatings Applied to Nuclear Facilities.           See UFSAR Section 17.2.9.5 for Iowa Electric's controls relative to "Special Protective Coatings".
6.4 With respect to Section 4.3.4 (1),
Subjects Requiring Independent Review, of ANSI N18.7-1976/ANS-3.2, the DAEC Safety Committee is not required to review safety evaluations of changes in the facility which are completed under 10 CFR Part 50.59.
6.5 Section 5.1 (Program Description) of ANSI N18.7 1976/ANS-3.2 requires a  
"summary document" for the Quality Assurance Program.
The QAPD and Appendix A thereto fulfill this requirement for Iowa Electric.
6.6 Section 5.2.7 (Maintenance and Modifications) of ANSI N18.7-1976/ANS-3.2 lists six standards that are to be applied to activities occurring during the operational phase that are comparable to related activities during design and construction.
Five of these standards are addressed elsewhere in this Appendix A.
Iowa Electric does not follow one of those listed, ANSI N101.4-1972, Quality Assurance for Protective Coatings Applied to Nuclear Facilities.
See UFSAR Section 17.2.9.5 for Iowa Electric's controls relative to "Special Protective Coatings".
6.7 With respect to Section 5.2.9 (Plant Security and Visitor Control) of ANSI N18.7-1976/ANS-3.2, the DAEC Security Plan meets the stated requirements.
6.7 With respect to Section 5.2.9 (Plant Security and Visitor Control) of ANSI N18.7-1976/ANS-3.2, the DAEC Security Plan meets the stated requirements.
However, the Standard references ANSI N18.17 for guidance. Iowa Electric is not committed to ANSI N18.17. The DAEC Security Plan complies with 10 CFR Part 73.
However, the Standard references ANSI N18.17 for guidance.
6.8 Section 5.2.15       (Review, Approval and Control of Procedures)     of     ANSI   N18.7-1976/ANS-3.2,   fourth /
Iowa Electric is not committed to ANSI N18.17.
The DAEC Security Plan complies with 10 CFR Part 73.
6.8 Section 5.2.15 (Review, Approval and Control of Procedures) of ANSI N18.7-1976/ANS-3.2, fourth  
/
paragraph requires:
paragraph requires:
17.2     A-5                       Revision 14 To be determined
17.2 A-5 Revision 14 To be determined


            "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."
"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."
This requirement is replaced by the following:
This requirement is replaced by the following:  
            "Plant procedures     shall be reviewed,     in accordance with the following, to determine if changes are necessary or desirable:
"Plant procedures shall be
: 1)   Non-routine procedures, such as emergency operating       procedures,       off-normal procedures, those that implement the emergency plan, and others where usage may be dictated by an event, shall be reviewed at least every two years by an individual knowledgeable in the area affected by the procedure.
: reviewed, in accordance with the following, to determine if changes are necessary or desirable:
: 2)   The procedures which have a frequency of use which exceeds two years, shall be reviewed prior to use, or every two years by an individual knowledgeable in the area affected by the procedure.
: 1)
: 3)   Routine plant procedures which are not addressed by (1) and (2) above shall be maintained through use of the procedure revision     process,   as   necessary   or desirable changes are identified through use. In addition, on a frequency not to exceed 2 years, an independent audit or assessment of a representative sample of routine     plant   procedures     shall   be performed to evaluate the effectiveness of the procedure review and revision program.
Non-routine procedures, such as emergency operating procedures, off-normal procedures, those that implement the emergency plan, and others where usage may be dictated by an event, shall be reviewed at least every two years by an individual knowledgeable in the area affected by the procedure.
6.9 Section 5.2.16 (Measuring and Test Equipment) of ANSI N18.7-1976/ANS-3.2 requires that equipment be suitably marked to indicate calibration status. Section 5.2.16 refers to ANSI N45.2.4-1972, which requires (Section 2.5.2, Calibration and Control) that equipment be suitably marked to indicate date of next required calibration and (Section 6.2.1, Equipment Tests) that items requiring calibration be tagged or labeled on completion, indicating date of calibration and identify of person who performed the calibration.           See the 17.2   A-6                       Revision 14 To be determined
: 2)
The procedures which have a frequency of use which exceeds two years, shall be reviewed prior to use, or every two years by an individual knowledgeable in the area affected by the procedure.
: 3)
Routine plant procedures which are not addressed by (1) and (2) above shall be maintained through use of the procedure revision
: process, as necessary or desirable changes are identified through use.
In addition, on a frequency not to exceed 2 years, an independent audit or assessment of a representative sample of routine plant procedures shall be performed to evaluate the effectiveness of the procedure review and revision program.
6.9 Section 5.2.16 (Measuring and Test Equipment) of ANSI N18.7-1976/ANS-3.2 requires that equipment be suitably marked to indicate calibration status.
Section 5.2.16 refers to ANSI N45.2.4-1972, which requires (Section 2.5.2, Calibration and Control) that equipment be suitably marked to indicate date of next required calibration and (Section 6.2.1, Equipment Tests) that items requiring calibration be tagged or labeled on completion, indicating date of calibration and identify of person who performed the calibration.
See the 17.2 A-6 Revision 14 To be determined


discussion provided in Section 5.5 of this document for Iowa Electric's commitment.
discussion provided in Section 5.5 of this document for Iowa Electric's commitment.
6.10   Instead of the format specified in Section 5.3.9.1, (Emergency Procedure Format and Content) of ANSI N18.7 1976/ANS-3.2, Iowa Electric's     DAEC Emergency Operating Procedures (EOPs) are in the format specified by the BWR   Owner's   Group     (BWROG)   Emergency   Procedure Guidelines, as reviewed and approved in the NRC Safety Evaluation Report, BWROG EPG, Revision 4,           September 1988.
6.10 Instead of the format specified in Section 5.3.9.1, (Emergency Procedure Format and Content) of ANSI N18.7 1976/ANS-3.2, Iowa Electric's DAEC Emergency Operating Procedures (EOPs) are in the format specified by the BWR Owner's Group (BWROG)
Emergency Procedure Guidelines, as reviewed and approved in the NRC Safety Evaluation Report, BWROG EPG, Revision 4, September 1988.
7.0 REGULATORY GUIDE 1.37, "Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water Cooled Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:
7.0 REGULATORY GUIDE 1.37, "Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water Cooled Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:
Iowa Electric complies with the Regulatory Position of this Regulatory Guide with the following clarifications:
Iowa Electric complies with the Regulatory Position of this Regulatory Guide with the following clarifications:
7.1   The commitment is to Regulatory Guide 1.37, Revision 0, 3/16/73, and to ANSI N45.2.1-1973 which it endorses.
7.1 The commitment is to Regulatory Guide 1.37, Revision 0, 3/16/73, and to ANSI N45.2.1-1973 which it endorses.
7.2   Iowa Electric shall comply with the Regulatory Position established in this Regulatory Guide for maintenance and modification activities           in that the quality assurance program requirements included therein shall apply.       Technical     requirements     associated   with maintenance and modification activities       shall be equal to or better than the original requirements (eg.,       Code requirements,   design and construction specification requirements, and inspection requirements).
7.2 Iowa Electric shall comply with the Regulatory Position established in this Regulatory Guide for maintenance and modification activities in that the quality assurance program requirements included therein shall apply.
8.0 REGULATORY GUIDE 1.38, "Quality Assurance Requirements for packaging,   Shipping, Receiving,       Storage, and Handling of Items for Water-Cooled Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:
Technical requirements associated with maintenance and modification activities shall be equal to or better than the original requirements (eg.,
Code requirements, design and construction specification requirements, and inspection requirements).
8.0 REGULATORY GUIDE 1.38, "Quality Assurance Requirements for packaging,
: Shipping, Receiving,
: Storage, and Handling of Items for Water-Cooled Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:
Iowa Electric complies with the Regulatory Position of this Regulatory Guide with the following clarifications:
Iowa Electric complies with the Regulatory Position of this Regulatory Guide with the following clarifications:
8.1   The Iowa Electric commitment is to Regulatory Guide 1.38, Revision 2, May 1977, which endorses ANSI N45.2.2-1972. However, the Iowa Electric commitment is to the later version of this Standard, ANSI/ASME N45.2.2-1978.
8.1 The Iowa Electric commitment is to Regulatory Guide 1.38, Revision 2, May 1977, which endorses ANSI N45.2.2-1972.
8.2   The applicability of the requirements of Section 3 and 4 and the Appendix of ANSI N45.2.2, and the paragraphs 17.2   A-7                         Revision 14 To be determined
However, the Iowa Electric commitment is to the later version of this Standard, ANSI/ASME N45.2.2-1978.
8.2 The applicability of the requirements of Section 3 and 4 and the Appendix of ANSI N45.2.2, and the paragraphs 17.2 A-7 Revision 14 To be determined


of the Regulatory Guide relating to these Sections (C.1.c, C.l.e, and C.2), is limited to the procurement of major plant equipment replacements; they are not applied to procurement of operating plant spares and modifications.
of the Regulatory Guide relating to these Sections (C.1.c, C.l.e, and C.2), is limited to the procurement of major plant equipment replacements; they are not applied to procurement of operating plant spares and modifications.
8.3   The shipping damage inspections required by Section 5.2.1 of ANSI N45.2.2 will be performed by Storekeepers prior to unloading in lieu of ANSI N45.2.6 certified inspectors. A shipping damage inspection is performed by ANSI N45.2.6 certified inspectors at a later point in the receiving process for applicable items.
8.3 The shipping damage inspections required by Section 5.2.1 of ANSI N45.2.2 will be performed by Storekeepers prior to unloading in lieu of ANSI N45.2.6 certified inspectors.
A shipping damage inspection is performed by ANSI N45.2.6 certified inspectors at a later point in the receiving process for applicable items.
9.0 REGULATORY GUIDE 1.39, "Housekeeping Requirements for Water Cooled Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:
9.0 REGULATORY GUIDE 1.39, "Housekeeping Requirements for Water Cooled Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:
Iowa Electric complies with the Regulatory Position of this Regulatory Guide with the following clarification:
Iowa Electric complies with the Regulatory Position of this Regulatory Guide with the following clarification:
9.1   The Iowa Electric commitment is to Regulatory Guide 1.39, Revision 2, September 1977, and to ANSI N45.2.3 1973 which it endorses.
9.1 The Iowa Electric commitment is to Regulatory Guide 1.39, Revision 2, September 1977, and to ANSI N45.2.3 1973 which it endorses.
10.0 REGULATORY GUIDE 1.54, "Quality Assurance Requirements for Protective Coatings Applied to Water-Cooled Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:
10.0 REGULATORY GUIDE 1.54, "Quality Assurance Requirements for Protective Coatings Applied to Water-Cooled Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:
Iowa Electric is not committed to Regulatory Guide 1.54, June 1973.       Iowa Electric's controls relative to protective coatings are contained in UFSAR Section 17.2.9.5.
Iowa Electric is not committed to Regulatory Guide 1.54, June 1973.
Iowa Electric's controls relative to protective coatings are contained in UFSAR Section 17.2.9.5.
11.0 REGULATORY GUIDE 1.58, "Qualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel" COMMENTS AND CLARIFICATIONS:
11.0 REGULATORY GUIDE 1.58, "Qualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel" COMMENTS AND CLARIFICATIONS:
Iowa Electric complies with the Regulatory Position of this Regulatory Guide with the following clarifications:
Iowa Electric complies with the Regulatory Position of this Regulatory Guide with the following clarifications:
11.1   The Iowa Electric commitment is to Regulatory Guide 1.58, Revision 1, September 1980, and to ANSI N45.2.6 1978 which it endorses.
11.1 The Iowa Electric commitment is to Regulatory Guide 1.58, Revision 1, September 1980, and to ANSI N45.2.6 1978 which it endorses.
11.2 ANSI N45.2.6-1978 Section 1.0, "Applicability", first paragraph, states       that this standard applies to personnel who perform inspections, examinations, and tests   during fabrication prior to and during receipt of 17.2   A-8                   Revision 14 To be determined
11.2 ANSI N45.2.6-1978 Section 1.0, "Applicability", first paragraph, states that this standard applies to personnel who perform inspections, examinations, and tests during fabrication prior to and during receipt of 17.2 A-8 Revision 14 To be determined


items at the construction site, during construction, during preoperational and startup testing, and during operational phases of nuclear power plants.
items at the construction site, during construction, during preoperational and startup testing, and during operational phases of nuclear power plants.
At Iowa Electric, the qualification of Quality Control personnel (Iowa Electric or contractor employees) performing inspection or examination work at the plant shall be in accordance with Regulatory Guide 1.58 (ANSI N45.2.6-1978). Personnel performing testing activities shall have appropriate experience and training to assure competence in accordance with Regulatory Guide 1.8 (ANS 3.1-1978).
At Iowa Electric, the qualification of Quality Control personnel (Iowa Electric or contractor employees) performing inspection or examination work at the plant shall be in accordance with Regulatory Guide 1.58 (ANSI N45.2.6-1978).
11.3 Regulatory Position C.1 of Regulatory Guide 1.58 states that "for qualification of personnel (1) who approve preoperations, startup, and operation test procedures and test results and (2) who direct or supervise the conduct of individual preoperational, startup, and operational   tests,   the   guidelines     contained   in Regulatory Guide 1.8, "Personnel Selection should be followed in lieu of the guidelines of ANSI N45.2.6-1978".     Iowa Electric complies with this Regulatory Position and,           furthermore, test procedures are reviewed and approved by a committee consisting of members representing a broad range of experience in engineering, operation and quality assurance; the tests shall be performed by qualified personnel and monitored by quality assurance personnel, to   ensure   compliance   with   the   test   procedure requirements.
Personnel performing testing activities shall have appropriate experience and training to assure competence in accordance with Regulatory Guide 1.8 (ANS 3.1-1978).
11.4 ANSI N45.2.6 Section 1.2,         "Applicability", third paragraph, requires that this standard be used in conjunction with ANSI N45.2.       Iowa Electric is not committed to ANSI N45.2.
11.3 Regulatory Position C.1 of Regulatory Guide 1.58 states that "for qualification of personnel (1) who approve preoperations, startup, and operation test procedures and test results and (2) who direct or supervise the conduct of individual preoperational, startup, and operational
11.5 ANSI N45.2.6 Section 1.2,       "Applicability",   fourth paragraph, requires that this standard be applied to organizations other than Iowa Electric. The specific applicability of this standard to other organizations is specified on a case-by-case basis in the procurement documents issued to those suppliers of materials and services.
: tests, the guidelines contained in Regulatory Guide 1.8, "Personnel Selection should be followed in lieu of the guidelines of ANSI N45.2.6-1978".
Iowa Electric complies with this Regulatory Position
: and, furthermore, test procedures are reviewed and approved by a committee consisting of members representing a broad range of experience in engineering, operation and quality assurance; the tests shall be performed by qualified personnel and monitored by quality assurance personnel, to ensure compliance with the test procedure requirements.
11.4 ANSI N45.2.6 Section 1.2, "Applicability",
third paragraph, requires that this standard be used in conjunction with ANSI N45.2.
Iowa Electric is not committed to ANSI N45.2.
11.5 ANSI N45.2.6 Section 1.2, "Applicability",
fourth paragraph, requires that this standard be applied to organizations other than Iowa Electric. The specific applicability of this standard to other organizations is specified on a case-by-case basis in the procurement documents issued to those suppliers of materials and services.
11.6 Regulatory Guide 1.58 Revision 1, in Section B, "Discussion", endorses ASNT Recommended Practice No.
11.6 Regulatory Guide 1.58 Revision 1, in Section B, "Discussion", endorses ASNT Recommended Practice No.
SNT-TC-1A-1975 for the qualification of nondestructive testing personnel.       In accordance with the Iowa Electric ASME Section XI program the 1980 Edition with addenda through Winter 1981 govern. Section IWA-2300 17.2   A-9                       Revision 14 To be determined
SNT-TC-1A-1975 for the qualification of nondestructive testing personnel.
In accordance with the Iowa Electric ASME Section XI program the 1980 Edition with addenda through Winter 1981 govern. Section IWA-2300 17.2 A-9 Revision 14 To be determined


of this Code requires nondestructive     personnel   to be qualified to SNT-TC-1A-1980.
of this Code requires nondestructive personnel to be qualified to SNT-TC-1A-1980.
In accordance with Regulatory Guide 1.147, ASME Code Case N-356, and Iowa Electric ASME Section XI Relief Request NDE-006,     the recertification period for NDE Level III personnel shall be every five years as opposed to the three years as stated in SNT-TC-1A-1980, paragraph 9.7.1.
In accordance with Regulatory Guide 1.147, ASME Code Case N-356, and Iowa Electric ASME Section XI Relief Request NDE-006, the recertification period for NDE Level III personnel shall be every five years as opposed to the three years as stated in SNT-TC-1A-1980, paragraph 9.7.1.
12.0 REGULATORY GUIDE 1.64, "Quality Assurance Requirements for the Design of Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:
12.0 REGULATORY GUIDE 1.64, "Quality Assurance Requirements for the Design of Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:
Iowa Electric complies with the Regulatory Position of this Regulatory Guide.       The Iowa Electric commitment is to Regulatory Guide 1.64, Revision 2, June 1976, and to ANSI N45.2-l1-1974 which it endorses.
Iowa Electric complies with the Regulatory Position of this Regulatory Guide.
13.0 REGULATORY   GUIDE   1.74,   "Quality Assurance   Terms   and Definitions" COMMENTS AND CLARIFICATIONS:
The Iowa Electric commitment is to Regulatory Guide 1.64, Revision 2, June 1976, and to ANSI N45.2-l1-1974 which it endorses.
13.0 REGULATORY GUIDE 1.74, "Quality Assurance Terms and Definitions" COMMENTS AND CLARIFICATIONS:
Iowa Electric complies with the Regulatory Position of this Regulatory Guide with the following clarifications:
Iowa Electric complies with the Regulatory Position of this Regulatory Guide with the following clarifications:
13.1 The Iowa Electric commitment is to Regulatory Guide 1.74, February 1974, and to ANSI N45.2.10-1973, which it endorses.
13.1 The Iowa Electric commitment is to Regulatory Guide 1.74, February 1974, and to ANSI N45.2.10-1973, which it endorses.
13.2 Iowa Electric has adopted the definition of "Audit" which appears in ANSI/ASME N45.2.12-1977, Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants, in lieu of the definition in ANSI N45.2.10-1973.
13.2 Iowa Electric has adopted the definition of "Audit" which appears in ANSI/ASME N45.2.12-1977, Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants, in lieu of the definition in ANSI N45.2.10-1973.
14.0 REGULATORY GUIDE 1.88, "Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records" COMMENTS AND CLARIFICATIONS:
14.0 REGULATORY GUIDE 1.88, "Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records" COMMENTS AND CLARIFICATIONS:
Iowa Electric complies with the Regulatory Position of this Regulatory Guide with the following clarifications:
Iowa Electric complies with the Regulatory Position of this Regulatory Guide with the following clarifications:
14.1 The Iowa Electric commitment is to Regulatory Guide 1.88, Revision 2, October 1976, and to ANSI N45.2.9 1974 which it endorses.
14.1 The Iowa Electric commitment is to Regulatory Guide 1.88, Revision 2, October 1976, and to ANSI N45.2.9 1974 which it endorses.
17.2   A-10                     Revision 14 To be determined
17.2 A-10 Revision 14 To be determined


14.2 Section   3.2.2   of   ANSI   N45.2.9-1974   specifies establishment of an "index".       As we understand this term, it can include a collection of documents or indices (some of which may be computer-based) which, when taken together, supply the information attributed to an "index" in the Standard.         Record retention requirements for records are specified. The specific retention times for records are indicated when the records are transmitted for permanent storage.       Iowa electric utilizes computer-aided retrieval systems to index and locate records.
14.2 Section 3.2.2 of ANSI N45.2.9-1974 specifies establishment of an "index".
14.3 Section 5 of ANSI N45.2.9-1974, "Storage, Preservation and Safekeeping",     provides no distinction between temporary and permanent facilities.           To address temporary   storage,     the   following   position   is established:     Active records (those completed but not yet duplicated or placed on microfilm) may be temporarily stored in one-hour fire rated file cabinets until such time as they are duplicated or microfilmed.
As we understand this
Open-ended documents--those revised or updated on a more-or-less continuing basis over an extended period of time (e1g. personnel qualification and training documents) and those which are cumulative in nature (e1g. nonconforming item logs and control room log books)--are not considered as QA records since they are not "complete". These types of documents shall become QA records when they are issued as a specific revision, when they are filled-up or discontinued, or on a periodic basis when the completed portion of the on going document shall be transferred to permanent storage as a "record".
: term, it can include a collection of documents or indices (some of which may be computer-based) which, when taken together, supply the information attributed to an "index" in the Standard.
14.4 The requirements of Section 4.3 (Receipt Control) of ANSI N45.2.9-1974       are implemented only for the permanent record files and not for temporary record files.
Record retention requirements for records are specified. The specific retention times for records are indicated when the records are transmitted for permanent storage.
14.5 The requirements of Section 5.3 (Storage) of ANSI N45.2.9-1974 are implemented only for the permanent record files and not for temporary record files.
Iowa electric utilizes computer-aided retrieval systems to index and locate records.
14.3 Section 5 of ANSI N45.2.9-1974, "Storage, Preservation and Safekeeping",
provides no distinction between temporary and permanent facilities.
To address temporary
: storage, the following position is established:
Active records (those completed but not yet duplicated or placed on microfilm) may be temporarily stored in one-hour fire rated file cabinets until such time as they are duplicated or microfilmed.
Open-ended documents--those revised or updated on a more-or-less continuing basis over an extended period of time (e1g.
personnel qualification and training documents) and those which are cumulative in nature (e1g. nonconforming item logs and control room log books)--are not considered as QA records since they are not "complete". These types of documents shall become QA records when they are issued as a specific revision, when they are filled-up or discontinued, or on a periodic basis when the completed portion of the on going document shall be transferred to permanent storage as a "record".
14.4 The requirements of Section 4.3 (Receipt Control) of ANSI N45.2.9-1974 are implemented only for the permanent record files and not for temporary record files.
14.5 The requirements of Section 5.3 (Storage) of ANSI N45.2.9-1974 are implemented only for the permanent record files and not for temporary record files.
15.0 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" COMMENTS AND CLARIFICATIONS:
15.0 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" COMMENTS AND CLARIFICATIONS:
Iowa Electric complies with the Regulatory Position of this Regulatory Guide with the following clarifications:
Iowa Electric complies with the Regulatory Position of this Regulatory Guide with the following clarifications:
17.2   A-11                 Revision 14 To be determined
17.2 A-11 Revision 14 To be determined


15.1 The Iowa Electric commitment is     to Regulatory Guide 1.94, Revision 1, April 1976, and to ANSI N45.2.5-1974 which it endorses.
15.1 The Iowa Electric commitment is to Regulatory Guide 1.94, Revision 1, April 1976, and to ANSI N45.2.5-1974 which it endorses.
15.2 For modification activities   Iowa Electric shall comply with the Regulatory Position established by this Regulatory Guide in that the quality assurance program requirements included therein shall apply. Technical requirements associated with modification activities shall be equal to or better than the original requirements (e1g., Code requirements, design and   construction   specification   requirements,   and inspection requirements).
15.2 For modification activities Iowa Electric shall comply with the Regulatory Position established by this Regulatory Guide in that the quality assurance program requirements included therein shall apply. Technical requirements associated with modification activities shall be equal to or better than the original requirements (e1g.,
Code requirements, design and construction specification requirements, and inspection requirements).
16.0 REGULATORY GUIDE 1.116, "Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems" COMMENTS AND CLARIFICATIONS:
16.0 REGULATORY GUIDE 1.116, "Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems" COMMENTS AND CLARIFICATIONS:
Iowa Electric complies with the Regulatory Position of this Regulatory Guide with the following clarifications:
Iowa Electric complies with the Regulatory Position of this Regulatory Guide with the following clarifications:
16.1 The Iowa Electric commitment is     to Regulatory Guide 1.116, Revision O-R, June       1976, with first page revision May 1977, and to ANSI N45.2.8-1975 which it endorses.
16.1 The Iowa Electric commitment is to Regulatory Guide 1.116, Revision O-R, June 1976, with first page revision May 1977, and to ANSI N45.2.8-1975 which it endorses.
16.2   Iowa Electric's commitment to this Regulatory Guide is applicable to maintenance and modification activities in that the quality assurance program requirements included therein shall apply. Technical requirements associated with maintenance and modification activities shall be     equal   to or better than the original requirements   (ezg., Code requirements, design and construction specification requirements, and inspection requirements).
16.2 Iowa Electric's commitment to this Regulatory Guide is applicable to maintenance and modification activities in that the quality assurance program requirements included therein shall apply. Technical requirements associated with maintenance and modification activities shall be equal to or better than the original requirements (ezg.,
17.0 REGULATORY GUIDE 1.123,   "Quality Assurance Requirements for Control of Procurement     of Items and Services for Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:
Code requirements, design and construction specification requirements, and inspection requirements).
17.0 REGULATORY GUIDE 1.123, "Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:
Iowa Electric complies with the Regulatory Position of this Regulatory Guide with the following clarifications:
Iowa Electric complies with the Regulatory Position of this Regulatory Guide with the following clarifications:
17.1 The Iowa Electric commitment is to Regulatory Guide 1.123, Revision 1, July 1977, and to ANSI N45.2.13-1976 which it endorses.
17.1 The Iowa Electric commitment is to Regulatory Guide 1.123, Revision 1, July 1977, and to ANSI N45.2.13-1976 which it endorses.
17.2   A-12               Revision 14 To be determined
17.2 A-12 Revision 14 To be determined


18.0 REGULATORY GUIDE 1.144,     "Auditing   of Quality   Assurance Programs for Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:
18.0 REGULATORY GUIDE 1.144, "Auditing of Quality Assurance Programs for Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:
Iowa Electric complies with the Regulatory Position of this Regulatory Guide with the following clarifications:
Iowa Electric complies with the Regulatory Position of this Regulatory Guide with the following clarifications:
18.1 The Iowa Electric commitment is to Regulatory Guide 1.144, Revision 1, September 1980, and to ANSI N45.2.12-1977 which it endorses.
18.1 The Iowa Electric commitment is to Regulatory Guide 1.144, Revision 1, September
18.2 Section 1.1, "Scope", and Section 1.2, "Applicability",
: 1980, and to ANSI N45.2.12-1977 which it endorses.
of ANSI N45.2.12-1977 reference ANSI N45.2.           Iowa Electric is committed to ANSI N18.7-1976 for the operational phase, consistent with its commitment to Regulatory Guide 1.33.
18.2 Section 1.1, "Scope", and Section 1.2, "Applicability",
18.3 Regulatory Position C.3.b(1) states that external audits, after the award of a contract, are not necessary for procurement actions where acceptance of the product is in accordance with Section 10.3.2, "Acceptance by Reviewing Inspection", of ANSI N45.2.13 1976. The suppliers of products that meet this requirement are included on the Iowa Electric external audit schedule and are audited on a triennial basis.
of ANSI N45.2.12-1977 reference ANSI N45.2.
18.4 ANSI N45.2.12,   Section   4.3.1 "Pre-Audit Conference" first sentence states:
Iowa Electric is committed to ANSI N18.7-1976 for the operational phase, consistent with its commitment to Regulatory Guide 1.33.
              "A brief pre-audit conference shall be conducted with cognizant organization management."           This sentence is   replaced with: "A brief pre-audit conference should be conducted with cognizant organization management."
18.3 Regulatory Position C.3.b(1) states that external audits, after the award of a contract, are not necessary for procurement actions where acceptance of the product is in accordance with Section 10.3.2, "Acceptance by Reviewing Inspection", of ANSI N45.2.13 1976.
In addition,   for internal audits, a "pre-audit planning meeting" may be substituted for the "pre audit conference."   The pre-audit planning meeting should accomplish the following:
The suppliers of products that meet this requirement are included on the Iowa Electric external audit schedule and are audited on a triennial basis.
: 1)   Obtain input on the subject(s) to be audited from the organization(s) to be audited.
18.4 ANSI N45.2.12, Section 4.3.1 "Pre-Audit Conference" first sentence states:  
: 2)   Finalize the audit plan as a result of the input obtained at this audit planning meeting.
"A brief pre-audit conference shall be conducted with cognizant organization management."
: 3)   Introduce the Lead Auditor and identify proposed audit team members. Those audit team members available will be   introduced. Note:
This sentence is replaced with:  
"A brief pre-audit conference should be conducted with cognizant organization management."
In
: addition, for internal audits, a  
"pre-audit planning meeting" may be substituted for the "pre audit conference."
The pre-audit planning meeting should accomplish the following:
: 1)
Obtain input on the subject(s) to be audited from the organization(s) to be audited.
: 2)
Finalize the audit plan as a result of the input obtained at this audit planning meeting.
: 3)
Introduce the Lead Auditor and identify proposed audit team members.
Those audit team members available will be introduced.
Note:
Non-utility team members are usually not available at these meetings.
Non-utility team members are usually not available at these meetings.
17.2   A-13                 Revision 14 To be determined
17.2 A-13 Revision 14 To be determined
: 4)   Counterparts   are   invited   to   these   audit planning meetings as part of the planning process.
: 4)
: 5)   The audit schedule is presented, including a tentative exit date. The final exit date is announced separately during the audit period.
Counterparts are invited to these audit planning meetings as part of the planning process.
: 6)   The channels of communication are opened at the     audit   planning     meeting       through participation in the audit planning process.
: 5)
The audit schedule is presented, including a tentative exit date.
The final exit date is announced separately during the audit period.
: 6)
The channels of communication are opened at the audit planning meeting through participation in the audit planning process.
19.0 REGULATORY GUIDE 1.146, "Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:
19.0 REGULATORY GUIDE 1.146, "Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:
Iowa Electric complies with the Regulatory Position of this Regulatory Guide with the following clarifications:
Iowa Electric complies with the Regulatory Position of this Regulatory Guide with the following clarifications:
19.1 The Iowa Electric commitment is       to Regulatory Guide 1.146, August 1980, and to ANSI N45.2.23-1978 which it endorses.
19.1 The Iowa Electric commitment is to Regulatory Guide 1.146, August 1980, and to ANSI N45.2.23-1978 which it endorses.
19.2 ANSI N45.2.23 Section 1.2 references ANSI N45.2.         For Iowa Electric, the entities subject to audit are defined in 10 CFR 50 Appendix B and ANSI N18.7-1976.
19.2 ANSI N45.2.23 Section 1.2 references ANSI N45.2.
For Iowa Electric, the entities subject to audit are defined in 10 CFR 50 Appendix B and ANSI N18.7-1976.
This is consistent with Iowa Electric's commitment to Regulatory Guide 1.33 which endorses ANSI N18.7-1976, in lieu of ANSI N45.2.
This is consistent with Iowa Electric's commitment to Regulatory Guide 1.33 which endorses ANSI N18.7-1976, in lieu of ANSI N45.2.
19.3 As an alternative to ANSI N45.2.23-1978,           paragraph 2.3.4, "Audit Participation",     the following may be applied:
19.3 As an alternative to ANSI N45.2.23-1978, paragraph 2.3.4, "Audit Participation",
              "The   prospective     Lead   Auditor     shall   have participated in a minimum of two (2) nuclear quality assurance audits within a period of time not to exceed one (1)     year prior to the date of       14 qualification. This participation shall be at an equivalent level as a Lead Auditor, but under the supervision of a Lead Auditor.             This includes responsibility for implementation of the audit process   (i.e.,   planning,     conduct,     meetings, reporting, etc.) and shall result in satisfactory performance as determined by management.
the following may be applied:  
17.2 A-14                   Revision 14 To be determined
"The prospective Lead Auditor shall have participated in a minimum of two (2) nuclear quality assurance audits within a period of time not to exceed one (1) year prior to the date of 14 qualification.
 
This participation shall be at an equivalent level as a Lead Auditor, but under the supervision of a Lead Auditor.
20.0      REGULATORY GUIDE 4.15, "Quality Assurance      for Radiological Monitoring Programs (Normal Operations) -      Effluent Streams and the Environment" COMMENTS AND CLARIFICATIONS:
This includes responsibility for implementation of the audit process (i.e.,
Iowa Electric complies with the Regulatory Position          in Regulatory Guide 4.15, Revision 1, February 1979.
: planning, conduct,
21.0      ASME B&PV Code,  Section XI,  1980 Edition with Addenda through Winter 1981 COMMENTS AND CLARIFICATIONS:
: meetings, reporting, etc.) and shall result in satisfactory performance as determined by management.
The Iowa Electric commitments relative to the Ten-Year Inspection Program and the Pump and Valve Test Program are established separately in formal correspondence with the Nuclear    Regulatory    Commission  and  incorporated    into appropriate Iowa Electric documents.
17.2 A-14 Revision 14 To be determined
Procedur\Apx17-2.kep 17.2  A-15                Revision 14 To be determined


Attachment 2 Discussion of Changes         to NG-93-2180 In the Quality Assurance Program Description
20.0 REGULATORY GUIDE 4.15, "Quality Assurance for Radiological Monitoring Programs (Normal Operations) -
: 1. Vice President - Production to Vice President - Nuclear Identification of changes:
Effluent Streams and the Environment" COMMENTS AND CLARIFICATIONS:
The following sections have been revised by replacing the title Vice President - Production with Vice President Nuclear as previously described in Iowa Electric Light and Power Company correspondence of March 31, 1993, (NG-93 1330):
Iowa Electric complies with the Regulatory Position in Regulatory Guide 4.15, Revision 1, February 1979.
17.2.1.2 - Manager, Corporate Quality Assurance 17.2.1.2.5 (formerly 17.2.1.2.6) - Stop Work Authority 17.2.2.7 -   Management Review and Audit 17.2.16.4   - Reporting of 10 CFR 21 Defects and Non compliances 17.2.18.1   - Audits, Scope 17.2.18.2.2 - Audits, Internal Organizations Reasons for the change:
21.0 ASME B&PV Code, Section XI, 1980 Edition with Addenda through Winter 1981 COMMENTS AND CLARIFICATIONS:
The position Vice President - Production no longer exists.
The Iowa Electric commitments relative to the Ten-Year Inspection Program and the Pump and Valve Test Program are established separately in formal correspondence with the Nuclear Regulatory Commission and incorporated into appropriate Iowa Electric documents.
Procedur\\Apx17-2.kep 17.2 A-15 Revision 14 To be determined Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description
: 1.
Vice President -
Production to Vice President -
Nuclear Identification of changes:
The following sections have been revised by replacing the title Vice President -
Production with Vice President Nuclear as previously described in Iowa Electric Light and Power Company correspondence of March 31, 1993, (NG-93 1330):
17.2.1.2 -
Manager, Corporate Quality Assurance 17.2.1.2.5 (formerly 17.2.1.2.6) -
Stop Work Authority 17.2.2.7 -
Management Review and Audit 17.2.16.4 -
Reporting of 10 CFR 21 Defects and Non compliances 17.2.18.1 -
Audits, Scope 17.2.18.2.2 - Audits, Internal Organizations Reasons for the change:
The position Vice President -
Production no longer exists.
NRC was previously notified of this change by NG-93-1330 of March 31, 1993.
NRC was previously notified of this change by NG-93-1330 of March 31, 1993.
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
This change in titles and organizational structure was previously approved by NRC correspondence of April 15, 1993:
This change in titles and organizational structure was previously approved by NRC correspondence of April 15, 1993:
(Reference letter of Mark A. Ring to Lee Liu).
(Reference letter of Mark A. Ring to Lee Liu).
: 2. 17.2.1.2.1 Quality Assurance Procurement Supervisor:
: 2.
17.2.1.2.1 Quality Assurance Procurement Supervisor:
Identification of the Change:
Identification of the Change:
The word "Assessments" has been corrected to "Assessment" in reference to the title of the QA Assessment Supervisor. In addition, a sentence has been added which states that the QA Procurement Supervisor is responsible for the preparation and maintenance of procedures which implement the functions Page 1 of 27
The word "Assessments" has been corrected to "Assessment" in reference to the title of the QA Assessment Supervisor. In addition, a sentence has been added which states that the QA Procurement Supervisor is responsible for the preparation and maintenance of procedures which implement the functions Page 1 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description assigned to this Supervisor. Also, responsibility for the review of procurement documents has been removed.
 
Attachment 2 Discussion of Changes         to NG-93-2180 In the Quality Assurance Program Description assigned to this Supervisor. Also, responsibility for the review of procurement documents has been removed.
Reason for the Change:
Reason for the Change:
The first change is a typographical correction. The second change is made because the QA Programs Engineer position has been eliminated as described in 17.2.1.2.5 below. It is more efficient for the responsible Supervisor to develop and maintain the procedures for which he/she is responsible.
The first change is a typographical correction. The second change is made because the QA Programs Engineer position has been eliminated as described in 17.2.1.2.5 below. It is more efficient for the responsible Supervisor to develop and maintain the procedures for which he/she is responsible.
The removal of responsibility for the review of procurement documents is made in support of removing the quality assurance organization from the in-line review of these activities. See 17.2.4.5 description of change for further details.
The removal of responsibility for the review of procurement documents is made in support of removing the quality assurance organization from the in-line review of these activities.
See 17.2.4.5 description of change for further details.
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
This first change only corrects a typographical error.
This first change only corrects a typographical error.
The second change reflects transfer of the responsibility to prepare procedures from a position previously identified as the QA Programs Engineer to the supervisory position, which is responsible for implementation of the procedures (i.e.,
The second change reflects transfer of the responsibility to prepare procedures from a position previously identified as the QA Programs Engineer to the supervisory position, which is responsible for implementation of the procedures (i.e.,
QA Procurement Supervisor). All functions previously described in the quality assurance program description continue to be performed, just by a different person. There is no reduction in commitments from those previously reviewed and approved by the NRC. See section 17.2.1.2.5 below for a discussion of the elimination of the QA Programs Engineer.
QA Procurement Supervisor).
All functions previously described in the quality assurance program description continue to be performed, just by a different person. There is no reduction in commitments from those previously reviewed and approved by the NRC.
See section 17.2.1.2.5 below for a discussion of the elimination of the QA Programs Engineer.
The last change regarding elimination of the responsibility for the review of procurement documents is made for consistency with the change described for Section 17.2.4.5.
The last change regarding elimination of the responsibility for the review of procurement documents is made for consistency with the change described for Section 17.2.4.5.
See the discussion of 17.2.4.5 for the basis of this change.
See the discussion of 17.2.4.5 for the basis of this change.
: 3. 17.2.1.2.2 Quality Assurance Assessment Supervisor:
: 3.
17.2.1.2.2 Quality Assurance Assessment Supervisor:
Identification of the Change:
Identification of the Change:
This section has been modified to include responsibilities for coordinating the review of divisional procedures, and for the preparation and maintenance of procedures for which the position is responsible.
This section has been modified to include responsibilities for coordinating the review of divisional procedures, and for the preparation and maintenance of procedures for which the position is responsible.
Page 2 of 27
Page 2 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description Reason for the Change:
 
Attachment 2 Discussion of Changes         to NG-93-2180 In the Quality Assurance Program Description Reason for the Change:
The position of QA Program Engineer has been eliminated and the responsibilities of that position reassigned, in part to this position.
The position of QA Program Engineer has been eliminated and the responsibilities of that position reassigned, in part to this position.
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
The previous Quality Assurance Program Description (QAPD) required that divisional procedures be reviewed by the Quality Assurance Program Engineer. This review continues and is now performed by various QA Department personnel, as assigned by the QA Assessment Supervisor, who coordinates the review. The Quality Assurance Assessment Supervisor is now also responsible for preparation and maintenance of procedures for which he/she is responsible. These functions continue to be performed consistent with the previous revision of the QAPD and as previously reviewed and approved by the NRC. There is no change in commitment. See Section 17.2.1.2.5 below regarding the QA Program Engineer.
The previous Quality Assurance Program Description (QAPD) required that divisional procedures be reviewed by the Quality Assurance Program Engineer. This review continues and is now performed by various QA Department personnel, as assigned by the QA Assessment Supervisor, who coordinates the review. The Quality Assurance Assessment Supervisor is now also responsible for preparation and maintenance of procedures for which he/she is responsible. These functions continue to be performed consistent with the previous revision of the QAPD and as previously reviewed and approved by the NRC. There is no change in commitment. See Section 17.2.1.2.5 below regarding the QA Program Engineer.
: 4. 17.2.1.2.3 Quality Control Supervisor:
: 4.
17.2.1.2.3 Quality Control Supervisor:
Identification of the Changes:
Identification of the Changes:
The changes to this section include correcting "Assessments" to "Assessment" in the title of the Quality Assurance Assessment Supervisor and including the responsibility for preparation and maintenance of procedures for which the Quality Control Supervisor is responsible.
The changes to this section include correcting "Assessments" to "Assessment" in the title of the Quality Assurance Assessment Supervisor and including the responsibility for preparation and maintenance of procedures for which the Quality Control Supervisor is responsible.
Line 652: Line 968:
The basis is the same as that described above in 17.2.1.2.2.
The basis is the same as that described above in 17.2.1.2.2.
These changes do not represent a reduction in commitment.
These changes do not represent a reduction in commitment.
Page 3 of 27
Page 3 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description See Section 17.2.1.2.5 below regarding the QA Program Engineer.
 
: 5.
Attachment 2 Discussion of Changes         to NG-93-2180 In the Quality Assurance Program Description See Section 17.2.1.2.5 below regarding the QA Program Engineer.
17.2.1.2.5 Quality Assurance Programs Engineer:
: 5. 17.2.1.2.5 Quality Assurance Programs Engineer:
Identification of the Change:
Identification of the Change:
The position of Quality Assurance Programs Engineer has been eliminated.
The position of Quality Assurance Programs Engineer has been eliminated.
Line 663: Line 978:
The QA Programs Engineer previously performed three functions: 1) Assisting the Manager, Corporate Quality Assurance in maintaining the Operational Quality Assurance Program; 2) reviewing divisional procedures which were responsive to the requirements of the Operational Quality Assurance Program, and 3) preparing and maintaining QA Department implementing procedures.
The QA Programs Engineer previously performed three functions: 1) Assisting the Manager, Corporate Quality Assurance in maintaining the Operational Quality Assurance Program; 2) reviewing divisional procedures which were responsive to the requirements of the Operational Quality Assurance Program, and 3) preparing and maintaining QA Department implementing procedures.
All of these functions continue to be performed. The maintenance of the Operational Quality Assurance Program continues to be performed by the Manager, Corporate Quality Assurance. The review of divisional procedures is now coordinated by the QA Assessment Supervisor. The department implementing procedures are prepared and maintained by the QA Department Supervisors responsible for their implementation.
All of these functions continue to be performed. The maintenance of the Operational Quality Assurance Program continues to be performed by the Manager, Corporate Quality Assurance. The review of divisional procedures is now coordinated by the QA Assessment Supervisor. The department implementing procedures are prepared and maintained by the QA Department Supervisors responsible for their implementation.
In conclusion, the functions previously performed by the QA Programs Engineer continue to be performed but by different persons within the QA organization. These changes do not affect implementation of the program in accordance with 10 CFR Part 50 Appendix B, and all quality assurance commitments previously reviewed and accepted by the NRC continue to be performed by the Quality Assurance Department. There is no reduction in commitment.
In conclusion, the functions previously performed by the QA Programs Engineer continue to be performed but by different persons within the QA organization.
Page 4 of 27
These changes do not affect implementation of the program in accordance with 10 CFR Part 50 Appendix B, and all quality assurance commitments previously reviewed and accepted by the NRC continue to be performed by the Quality Assurance Department. There is no reduction in commitment.
 
Page 4 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description
Attachment 2 Discussion of Changes         to NG-93-2180 In the Quality Assurance Program Description
: 6.
: 6. 17.2.1.2.6 (Renumbered as 17.2.1.2.5) Stop Work Authority:
17.2.1.2.6 (Renumbered as 17.2.1.2.5) Stop Work Authority:
Identification of Changes:
Identification of Changes:
This section was renumbered from 17.2.1.6 to 17.2.1.5.
This section was renumbered from 17.2.1.6 to 17.2.1.5.
Line 674: Line 989:
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
The paragraph numbering change is editorial.
The paragraph numbering change is editorial.
: 7. 17.2.2.3 Identification of Safety-Related Structures, Systems, Components, and Items:
: 7.
17.2.2.3 Identification of Safety-Related Structures, Systems, Components, and Items:
This section refers to UFSAR Table 3.2-1 for the list of safety-related structures, systems, components and items.
This section refers to UFSAR Table 3.2-1 for the list of safety-related structures, systems, components and items.
The following changes have been made to UFSAR Table 3.2-1 and evaluated for impact on the quality assurance program.
The following changes have been made to UFSAR Table 3.2-1 and evaluated for impact on the quality assurance program.
A. Section III (Recirculation System), Item 6, Pump Motor:
A.
Section III (Recirculation System), Item 6, Pump Motor:
Identification of Changes:
Identification of Changes:
The following changes have been made to item 111.6:
The following changes have been made to item 111.6:
a)   The safety class has been revised from safety class 2 to "other" b)   The quality assurance requirements have been revised from "B" to "D" c)   Footnote lx has been added which states:
a)
              "The recirc pump motors are not seismic category I. However, per 21A9213 sections 4.1.8.3.5 and 4.1.6, they must be seismically supported so as not to breach the integrity of the reactor coolant pressure boundary."
The safety class has been revised from safety class 2 to "other" b)
The quality assurance requirements have been revised from "B" to "D" c)
Footnote lx has been added which states:  
"The recirc pump motors are not seismic category I.
However, per 21A9213 sections 4.1.8.3.5 and 4.1.6, they must be seismically supported so as not to breach the integrity of the reactor coolant pressure boundary."
Reason for the Changes:
Reason for the Changes:
The above changes are the result of continuing work at DAEC to reconstitute the design basis of the plant. Details concerning Item 111.6 must be corrected.
The above changes are the result of continuing work at DAEC to reconstitute the design basis of the plant. Details concerning Item 111.6 must be corrected.
Page 5 of 27
Page 5 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description The original purchase specification for the reactor recirculation pump and motor (General Electric Specification 21A9213) states:  
 
"The pump pressure boundary shall remain suitable for service after the transient; however, it is not required that the pump remain operable."
Attachment 2 Discussion of Changes         to NG-93-2180 In the Quality Assurance Program Description The original purchase specification for the reactor recirculation pump and motor (General Electric Specification 21A9213) states:
    "The pump pressure boundary shall remain suitable for service after the transient; however, it is not required that the pump remain operable."
The recirculation pump motors were not included on the original DAEC "Q-List."
The recirculation pump motors were not included on the original DAEC "Q-List."
In the early design for DAEC, it was assumed that conservative design for the recirculation system pump and motor would require a gradual reduction in recirculation system flow in the event of a transient to minimize the impact on the fuel parameters. This approach was consistent with industry standards ANS-22 and ANS 52.1 which state:
In the early design for DAEC, it was assumed that conservative design for the recirculation system pump and motor would require a gradual reduction in recirculation system flow in the event of a transient to minimize the impact on the fuel parameters. This approach was consistent with industry standards ANS-22 and ANS 52.1 which state:  
"Sufficient inertia shall be provided in the reactor coolant recirculation pumps or their power source so that the coolant flow coastdown characteristics in the event of a total loss of power ensure that fuel design limits are not exceeded."   In support of these requirements, the safety classification tables in these reference standards identify the reactor recirculation system pump motors as safety class 2 which is consistent with the present UFSAR Table 3.2-1.
"Sufficient inertia shall be provided in the reactor coolant recirculation pumps or their power source so that the coolant flow coastdown characteristics in the event of a total loss of power ensure that fuel design limits are not exceeded."
In support of these requirements, the safety classification tables in these reference standards identify the reactor recirculation system pump motors as safety class 2 which is consistent with the present UFSAR Table 3.2-1.
However, in later years it was determined that this long coastdown has a negative effect on pressurization.
However, in later years it was determined that this long coastdown has a negative effect on pressurization.
In 1980, Iowa Electric made a design change (DCR-700) to the recirculation system to install end-of-cycle recirculation pump trip (RPT) breakers in accordance with General Electric document NEDO-24220 "Basis for Installation of Recirculation Pump Trip System." This design change required a request for a revision to the DAEC Technical Specifications, and an NRC safety evaluation report was issued. Additional Class 1E trip breakers were installed which trip the recirculation system pump motors from the recirculation motor generator set, minimizing the recirculation pump coastdown.
In 1980, Iowa Electric made a design change (DCR-700) to the recirculation system to install end-of-cycle recirculation pump trip (RPT) breakers in accordance with General Electric document NEDO-24220 "Basis for Installation of Recirculation Pump Trip System."
These motors are not safety class 2, but safety class "other," and the motors do need to be seismically mounted in order to maintain the reactor coolant pressure boundary (impact on the pumps). New Footnote lx has been added to Page 6 of 27
This design change required a request for a revision to the DAEC Technical Specifications, and an NRC safety evaluation report was issued. Additional Class 1E trip breakers were installed which trip the recirculation system pump motors from the recirculation motor generator set, minimizing the recirculation pump coastdown.
 
These motors are not safety class 2, but safety class "other," and the motors do need to be seismically mounted in order to maintain the reactor coolant pressure boundary (impact on the pumps).
Attachment 2 Discussion of Changes         to NG-93-2180 In the Quality Assurance Program Description define the seismic requirements clearly. The quality assurance requirements have been revised from 10 CFR Part 50 Appendix B to other (D) consistent with the non-safety, but seismic, application of these pump motors.
New Footnote lx has been added to Page 6 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description define the seismic requirements clearly. The quality assurance requirements have been revised from 10 CFR Part 50 Appendix B to other (D) consistent with the non-safety, but seismic, application of these pump motors.
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
The Safety Class 2 and Appendix B classifications for the reactor recirculation pump motors previously stated were in error. As stated above, these motors were not originally purchased as a "Q-List" item. The current Safety Class 2 designation was based on ANS-22 which does not recognize the use of Class 1E trip breakers to remove the power source from the pumps during a transient. These pump motors perform no safety function.
The Safety Class 2 and Appendix B classifications for the reactor recirculation pump motors previously stated were in error. As stated above, these motors were not originally purchased as a "Q-List" item. The current Safety Class 2 designation was based on ANS-22 which does not recognize the use of Class 1E trip breakers to remove the power source from the pumps during a transient. These pump motors perform no safety function.
In conclusion, UFSAR Table 3.2-1 was incorrect because of an incomplete set of input documents. Reclassification of the recirculation pump motor is not a reduction in commitment based on the original DAEC design but could be classified as a reduction in commitment based on the content of the current UFSAR Table 3.2-1. On this basis, this change is categorized as a reduction in commitment from that previously specified.
In conclusion, UFSAR Table 3.2-1 was incorrect because of an incomplete set of input documents.
7B. Item XI.9, HPCI System, Turbine:
Reclassification of the recirculation pump motor is not a reduction in commitment based on the original DAEC design but could be classified as a reduction in commitment based on the content of the current UFSAR Table 3.2-1. On this basis, this change is categorized as a reduction in commitment from that previously specified.
Identification of the Change A reference to Footnote Ig was added to the HPCI Turbine item, and footnote lg was revised to include the HPCI turbine. Footnote lg now states:
7B.
    "The RCIC and HPCI turbines do not fall within the applicable design codes. To assure that the turbines are fabricated to the standards commensurate with their safety and performance requirements, General Electric has established specific design requirements for these components."
Item XI.9, HPCI System, Turbine:
Identification of the Change A reference to Footnote Ig was added to the HPCI Turbine item, and footnote lg was revised to include the HPCI turbine. Footnote lg now states:  
"The RCIC and HPCI turbines do not fall within the applicable design codes.
To assure that the turbines are fabricated to the standards commensurate with their safety and performance requirements, General Electric has established specific design requirements for these components."
Reason for the Change Footnote lg is applicable to the RCIC and HPCI turbines.
Reason for the Change Footnote lg is applicable to the RCIC and HPCI turbines.
That was clear in a similar note in the UFSAR revision of July, 1982, page T.3.2-16. comment 8 which stated:
That was clear in a similar note in the UFSAR revision of July, 1982, page T.3.2-16. comment 8 which stated:
Page 7 of 27
Page 7 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description "The HPCI and RCIC turbines are categorized as machinery and thus do not fall within the classification groups as earlier identified. To ensure that the turbine was fabricated to the standards commensurate with their performance requirements, General Electric has established specific design requirements for these components."
 
This was mistakenly dropped.
Attachment 2 Discussion of Changes         to NG-93-2180 In the Quality Assurance Program Description "The HPCI and RCIC turbines are categorized as machinery and thus do not fall within the classification groups as earlier identified. To ensure that the turbine was fabricated to the standards commensurate with their performance requirements, General Electric has established specific design requirements for these components." This was mistakenly dropped.
Basis for Concluding That The Change Is Acceptable Under Section 50.54 (a)(3):
Basis for Concluding That The Change Is Acceptable Under Section 50.54 (a)(3):
This change clarifies the entry for the HPCI system turbine in UFSAR Table 3.2-1. It does not impact the application of the Quality Assurance Program Description as previously reviewed and approved by the NRC to the RCIC and HPCI turbines and continues to satisfy the provisions of 10 CFR 50 Appendix B. This change is not a reduction in commitment.
This change clarifies the entry for the HPCI system turbine in UFSAR Table 3.2-1.
7C. Items XI.7 (HPCI Vacuum Pump Discharge Line to Containment Isolation Valves) and (RCIC, Vacuum Pump Discharge Line to Containment Isolation Valves):
It does not impact the application of the Quality Assurance Program Description as previously reviewed and approved by the NRC to the RCIC and HPCI turbines and continues to satisfy the provisions of 10 CFR 50 Appendix B. This change is not a reduction in commitment.
7C.
Items XI.7 (HPCI Vacuum Pump Discharge Line to Containment Isolation Valves) and (RCIC, Vacuum Pump Discharge Line to Containment Isolation Valves):
Identification of the Changes:
Identification of the Changes:
Footnote lb was added to the RCIC Item 7 " Vacuum pump discharge line to containment isolation valves". The footnote states:
Footnote lb was added to the RCIC Item 7 " Vacuum pump discharge line to containment isolation valves". The footnote states:
ANSI B31, Code Case 78 applies for B31.7 Class 1 and Class 2 pipe and fittings 3/4" nominal pipe size (NPS) and smaller.
ANSI B31, Code Case 78 applies for B31.7 Class 1 and Class 2 pipe and fittings 3/4" nominal pipe size (NPS) and smaller.
Also, "Principal component description" for entries XI.7 and XII.7 are revised from "Vacuum pump discharge line to containment isolation valves" to "Vacuum pump discharge line."
Also, "Principal component description" for entries XI.7 and XII.7 are revised from "Vacuum pump discharge line to containment isolation valves" to "Vacuum pump discharge line."
Reason for the Change Footnote lb was not previously applied to the RCIC system vacuum pump discharge line. A portion of the RCIC   (and HPCI) system vacuum pump discharge lines return to the barometric condenser and are 3/4" Class 2 lines to which Code Case 78 applies.
Reason for the Change Footnote lb was not previously applied to the RCIC system vacuum pump discharge line. A portion of the RCIC (and HPCI) system vacuum pump discharge lines return to the barometric condenser and are 3/4" Class 2 lines to which Code Case 78 applies.
Page 8 of 27
Page 8 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description The "Principal component description" was in error. The HPCI and RCIC vacuum pump discharge lines discharge to the Standby Gas Treatment System, and back to the barometric condenser. There are no containment isolation valves in these lines.
 
Attachment 2 Discussion of Changes         to NG-93-2180 In the Quality Assurance Program Description The "Principal component description" was in error. The HPCI and RCIC vacuum pump discharge lines discharge to the Standby Gas Treatment System, and back to the barometric condenser. There are no containment isolation valves in these lines.
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
These changes do not impact the application of the Quality Assurance Program Description as previously reviewed and approved by the NRC and continue to satisfy the provisions of 10 CFR 50 Appendix B. Quality Assurance requirement "D" continues to be applied. This change is not a reduction in commitment.
These changes do not impact the application of the Quality Assurance Program Description as previously reviewed and approved by the NRC and continue to satisfy the provisions of 10 CFR 50 Appendix B. Quality Assurance requirement "D" continues to be applied. This change is not a reduction in commitment.
7D. Item XXIII.1, Offgas System, Tanks:
7D.
Item XXIII.1, Offgas System, Tanks:
Identification of the Change Item XXIII.1, the construction code of 'D100 or API-650' was changed to read 'AWWA D100 or API-650'.
Identification of the Change Item XXIII.1, the construction code of 'D100 or API-650' was changed to read 'AWWA D100 or API-650'.
Reason for the Change The addition of AWWA (American Water Works Association) to this entry provides further clarification concerning the origination of the D100 code.
Reason for the Change The addition of AWWA (American Water Works Association) to this entry provides further clarification concerning the origination of the D100 code.
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
This is an editorial change and does not impact the application of the Quality Assurance Program Description as previously reviewed and approved by the NRC and continues to satisfy the provisions of 10 CFR 50 Appendix B. This change is not a reduction in commitment.
This is an editorial change and does not impact the application of the Quality Assurance Program Description as previously reviewed and approved by the NRC and continues to satisfy the provisions of 10 CFR 50 Appendix B. This change is not a reduction in commitment.
7E. Items XXIII.3-6, Offgas System:
7E.
Items XXIII.3-6, Offgas System:
Identification of the Changes:
Identification of the Changes:
Item XXIII.3, piping, the construction code was changed from USAS B31.7-1969 to 'ASME Section 111-1971'. The following comment was added for Items XXIII.3 through 6:
Item XXIII.3, piping, the construction code was changed from USAS B31.7-1969 to 'ASME Section 111-1971'.
Page 9 of 27
The following comment was added for Items XXIII.3 through 6:
 
Page 9 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description "The construction codes used for Offgas pipe, pumps, and valves were USAS B31.7; ASME Sections III and VIII; and the Draft Pump and Valve Code. To identify the correct code for a component it is necessary to research the receiving inspection files (File Q2.321).
Attachment 2 Discussion of Changes         to NG-93-2180 In the Quality Assurance Program Description "The construction codes used for Offgas pipe, pumps, and valves were USAS B31.7; ASME Sections III and VIII; and the Draft Pump and Valve Code. To identify the correct code for a component it is necessary to research the receiving inspection files (File Q2.321).
There are two reasons that several codes and dates were applied. The first reason is that the Offgas design was changed during Procurement/Construction. The second reason is that the codes were changing rapidly during the'period of the design. The project correspondence which records when the Offgas System construction code was changed is given in APED-N62 076."
There are two reasons that several codes and dates were applied. The first reason is that the Offgas design was changed during Procurement/Construction. The second reason is that the codes were changing rapidly during the'period of the design. The project correspondence which records when the Offgas System construction code was changed is given in APED-N62 076."
Reason for the Changes:
Reason for the Changes:
Line 737: Line 1,060:
This change provides an additional level of detail regarding the code of construction for the Offgas system. This does not impact the application of the Quality Assurance Program Description as previously reviewed and approved by the NRC and continues to satisfy the provisions of 10 CFR 50 Appendix B. This change is not a reduction in commitment.
This change provides an additional level of detail regarding the code of construction for the Offgas system. This does not impact the application of the Quality Assurance Program Description as previously reviewed and approved by the NRC and continues to satisfy the provisions of 10 CFR 50 Appendix B. This change is not a reduction in commitment.
7.F Item XXIII.5, Offgas System, Valves, Flow Control:
7.F Item XXIII.5, Offgas System, Valves, Flow Control:
Identification of the Change Item XXIII.5, The Scope of Supply was changed from 'GE' to
Identification of the Change Item XXIII.5, The Scope of Supply was changed from 'GE' to  
    'B'.
'B'.
Reason for the Change The flow control valves for the Offgas system were actually supplied by Bechtel using material requisition specification 7884-M-131 AC.
Reason for the Change The flow control valves for the Offgas system were actually supplied by Bechtel using material requisition specification 7884-M-131 AC.
Page 10 of 27
Page 10 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
 
The correction of the "Scope of Supply" for Item XXIII.5 does not impact the application of the Quality Assurance Program Description as previously reviewed and approved by the NRC.
Attachment 2 Discussion of Changes         to NG-93-2180 In the Quality Assurance Program Description Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
This change is not a reduction in commitment.
The correction of the "Scope of Supply" for Item XXIII.5 does not impact the application of the Quality Assurance Program Description as previously reviewed and approved by the NRC. This change is not a reduction in commitment.
7.G Item XXIII.7, Offgas System, Mechanical Modules:
7.G Item XXIII.7, Offgas System, Mechanical Modules:
Identification of the Change The following changes have been made to this line item:
Identification of the Change The following changes have been made to this line item:
: 1)   The Principal Component description was changed from "Mechanical Modules with safety function" to "Mechanical modules".
: 1)
: 2)   The "Offgas Stack Dilution Fans" were relocated from Item XXIII.7 to the Standby Gas Treatment System (XXXI.1). This relocation causes the following changes:
The Principal Component description was changed from "Mechanical Modules with safety function" to "Mechanical modules".
a)   Scope of Supply Changes from "GE/B" to "GE".
: 2)
b)   The safety class changes from "Other/Other" to "other".
The "Offgas Stack Dilution Fans" were relocated from Item XXIII.7 to the Standby Gas Treatment System (XXXI.1). This relocation causes the following changes:
c)   The quality group class changes from "D/D+QA" to "D".
a)
d)   The Quality Assurance Requirement changes from "D/B" to "D".
Scope of Supply Changes from "GE/B" to "GE".
e)   The seismic category changes from "NA/I" to "NA".
b)
f)   Reference to footnote lv is removed from XXIII.7 and the footnote itself deleted.
The safety class changes from "Other/Other" to "other".
g)   The "Comment" in XXIII.7, pertaining to the Offgas Stack Dilution Fans is deleted.
c)
Reason for the Change As part of the design basis reconstitution for DAEC, it was discovered that the Offgas stack dilution fans were originally designed to be part of the Standby Gas Treatment system, as documented in IE-72-236, letter from D. Flanagan of Iowa Electric, to S. Cott of Bechtel, dated 5-10-72. As previously explained in discussion with F. Maura of the NRC (Docket No. 50-331 G. Wright to L. Liu dated 11-5-92), this original design was changed due to the fact that the Offgas stack dilution fans were the only components with a safety Page 11 of 27
The quality group class changes from "D/D+QA" to "D".
 
d)
Attachment 2 Discussion of Changes         to NG-93-2180 In the Quality Assurance Program Description function. It should be noted that the Offgas stack dilution fans have now been moved to the Standby Gas Treatment system (see change for Item XXXI).
The Quality Assurance Requirement changes from "D/B" to "D".
e)
The seismic category changes from "NA/I" to "NA".
f)
Reference to footnote lv is removed from XXIII.7 and the footnote itself deleted.
g)
The "Comment" in XXIII.7, pertaining to the Offgas Stack Dilution Fans is deleted.
Reason for the Change As part of the design basis reconstitution for DAEC, it was discovered that the Offgas stack dilution fans were originally designed to be part of the Standby Gas Treatment system, as documented in IE-72-236, letter from D. Flanagan of Iowa Electric, to S. Cott of Bechtel, dated 5-10-72. As previously explained in discussion with F. Maura of the NRC (Docket No. 50-331 G. Wright to L. Liu dated 11-5-92), this original design was changed due to the fact that the Offgas stack dilution fans were the only components with a safety Page 11 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description function.
It should be noted that the Offgas stack dilution fans have now been moved to the Standby Gas Treatment system (see change for Item XXXI).
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
The Offgas Stack Dilution Fans and all requirements associated with them have only been relocated from Table 3.2-1 line item XXIII.7 to new line item XXXI.l. This relocation did not alter any of the Quality Assurance Program Requirements applicable to the Mechanical Modules of the Offgas System. The removal of the words "with safety function" is consistent with the NRC letter of November 5, 1992, G. Wright to L. Liu. These changes are not reductions in commitment. See Section XXXI.1 regarding Offgas Stack Dilution Fans.
The Offgas Stack Dilution Fans and all requirements associated with them have only been relocated from Table 3.2-1 line item XXIII.7 to new line item XXXI.l.
This relocation did not alter any of the Quality Assurance Program Requirements applicable to the Mechanical Modules of the Offgas System. The removal of the words "with safety function" is consistent with the NRC letter of November 5, 1992, G. Wright to L. Liu.
These changes are not reductions in commitment. See Section XXXI.1 regarding Offgas Stack Dilution Fans.
7.H Item XXXI.1, Standby Gas Treatment System:
7.H Item XXXI.1, Standby Gas Treatment System:
Identification of Changes:
Identification of Changes:
The Offgas Stack Dilution Fans have been added to this entry (relocation from XXIII.7 above). This relocation also includes the following changes for the Offgas Stack Dilution fans from the previous entry at XXIII.7:
The Offgas Stack Dilution Fans have been added to this entry (relocation from XXIII.7 above).
: 1)   Principal component description a -been revised to include "including Offgas Stack Dilution Fans".
This relocation also includes the following changes for the Offgas Stack Dilution fans from the previous entry at XXIII.7:
: 2)   Safety class "3" is now assigned to these fans (previously "other").
: 1)
: 3)   Quality Group Class is now "blank" versus "D+QA" previously.
Principal component description a -been revised to include "including Offgas Stack Dilution Fans".
: 2)
Safety class "3" is now assigned to these fans (previously "other").
: 3)
Quality Group Class is now "blank" versus "D+QA" previously.
Reason for the Changes:
Reason for the Changes:
As reflected by 05/10/72 correspondence of IE-72-236, D.
As reflected by 05/10/72 correspondence of IE-72-236, D.
Flanagan of Iowa Electric to S. Cott of Bechtel, the Offgas Stack Dilution Fans were originally designed as part of the Standby Gas Treatment System.
Flanagan of Iowa Electric to S. Cott of Bechtel, the Offgas Stack Dilution Fans were originally designed as part of the Standby Gas Treatment System.
The Principal Component title change is a result of relocating the Offgas Stack Dilution Fans from Item XXIII.7 to this section.
The Principal Component title change is a result of relocating the Offgas Stack Dilution Fans from Item XXIII.7 to this section.
Page 12 of 27
Page 12 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description The Safety Class previously stated for these fans was in error. Safety Class "3" is the correct safety class per the original design and in support of the Standby Gas Treatment System, and as defined by UFSAR Section 3.2.
 
The Quality Group Classes are only applied to system piping and equipment pressure parts as defined in UFSAR Section 3.2.
Attachment 2 Discussion of Changes         to NG-93-2180 In the Quality Assurance Program Description The Safety Class previously stated for these fans was in error. Safety Class "3" is the correct safety class per the original design and in support of the Standby Gas Treatment System, and as defined by UFSAR Section 3.2.
Quality Group Class is not applicable to the Offgas Stack Dilution Fans.
The Quality Group Classes are only applied to system piping and equipment pressure parts as defined in UFSAR Section 3.2. Quality Group Class is not applicable to the Offgas Stack Dilution Fans.
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
The above changes to the Offgas Stack Dilution Fans correct the Safety Class and Quality Group Class consistent with UFSAR Section 3.2. These changes do not affect the application of the 10 CFR Part 50 Appendix B program to these components as previously defined in the Operational Quality Assurance Program and previously accepted by the NRC. These changes are not a reduction in commitments.
The above changes to the Offgas Stack Dilution Fans correct the Safety Class and Quality Group Class consistent with UFSAR Section 3.2.
These changes do not affect the application of the 10 CFR Part 50 Appendix B program to these components as previously defined in the Operational Quality Assurance Program and previously accepted by the NRC. These changes are not a reduction in commitments.
7.1 Item XXXVIII.2, MSIV Leakage Control, Piping and Valves, Other:
7.1 Item XXXVIII.2, MSIV Leakage Control, Piping and Valves, Other:
Identification of the Changes:
Identification of the Changes:
Line 783: Line 1,119:
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
This change adds another level of detail regarding the specific year of the ASME Code to which these components were designed. This change does not impact the application of the Quality Assurance Program Description as previously reviewed and approved by the NRC and continues to satisfy the provisions of 10 CFR 50 Appendix B. This change is not a reduction in commitment.
This change adds another level of detail regarding the specific year of the ASME Code to which these components were designed. This change does not impact the application of the Quality Assurance Program Description as previously reviewed and approved by the NRC and continues to satisfy the provisions of 10 CFR 50 Appendix B. This change is not a reduction in commitment.
Page 13 of 27
Page 13 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description 7.J Footnote "e":
 
Identification of the Change The middle sentence of Footnote 'e' has been deleted.
Attachment 2 Discussion of Changes         to NG-93-2180 In the Quality Assurance Program Description 7.J Footnote "e":
It read:
Identification of the Change The middle sentence of Footnote 'e' has been deleted. It read:
The inclusion of a system or structure within Seismic Category I does not mean the entire system or structure is Seismic Category I but rather that the system or structure has been evaluated and those portions that lie within the definition of Seismic Category I have been appropriately analyzed and protected for seismic response.
The inclusion of a system or structure within Seismic Category I does not mean the entire system or structure is Seismic Category I but rather that the system or structure has been evaluated and those portions that lie within the definition of Seismic Category I have been appropriately analyzed and protected for seismic response.
Reason for the Change For clarification and to avoid misinterpretation, this sentence was deleted as previously discussed with F. Maura of the NRC (Docket No. 50-331, G. Wright to L. Liu, date 11 5-92). Any deviation from the Seismic Category I requirements for portions of structures or systems classified as Seismic Category I will be justified on an individual basis.
Reason for the Change For clarification and to avoid misinterpretation, this sentence was deleted as previously discussed with F. Maura of the NRC (Docket No. 50-331, G. Wright to L. Liu, date 11 5-92).
Any deviation from the Seismic Category I requirements for portions of structures or systems classified as Seismic Category I will be justified on an individual basis.
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
This change is a clarification and does not impact the application of the Quality Assurance Program Description as previously reviewed and approved by the NRC and continues to satisfy the provisions of 10 CFR 50 Appendix B. This change is consistent with the previous NRC letter of November 5, 1992, and is not a reduction in commitment.
This change is a clarification and does not impact the application of the Quality Assurance Program Description as previously reviewed and approved by the NRC and continues to satisfy the provisions of 10 CFR 50 Appendix B. This change is consistent with the previous NRC letter of November 5, 1992, and is not a reduction in commitment.
7.K Comments XI.9(1)(6) and XII.9(1)(6):
7.K Comments XI.9(1)(6) and XII.9(1)(6):
Identification of the Change Comments XI 9(6) and XII 9(6) were revised to include "paragraph N624, and magnetic particle or liquid penetrant tested according to ASME Section III" in the following comment:
Identification of the Change Comments XI 9(6) and XII 9(6) were revised to include "paragraph N624, and magnetic particle or liquid penetrant tested according to ASME Section III" in the following comment:
Butt welds were radiographed according to the ASME B&PV Code, Section III, 1968 Edition, "paragraph N624, and Page 14 of 27
Butt welds were radiographed according to the ASME B&PV Code, Section III, 1968 Edition, "paragraph N624, and Page 14 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description magnetic particle or liquid penetrant tested according to ASME Section III", paragraph N626 or N627.
 
Attachment 2 Discussion of Changes         to NG-93-2180 In the Quality Assurance Program Description magnetic particle or liquid penetrant tested according to ASME Section III", paragraph N626 or N627.
APED-A61-052, Comment 10 which is the reference for this comment was also added.
APED-A61-052, Comment 10 which is the reference for this comment was also added.
Reason for the Change This is an editorial change which corrects a portion of the comment omitted in the translation from the original source document.
Reason for the Change This is an editorial change which corrects a portion of the comment omitted in the translation from the original source document.
Line 801: Line 1,135:
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
This is an editorial change and does not impact the application of the Quality Assurance Program Description as previously reviewed and approved by the NRC and continues to satisfy the provisions of 10 CFR 50 Appendix B. This change is not a reduction in commitment.
This is an editorial change and does not impact the application of the Quality Assurance Program Description as previously reviewed and approved by the NRC and continues to satisfy the provisions of 10 CFR 50 Appendix B. This change is not a reduction in commitment.
: 8. 17.2.2.6 Indoctrination and Training:
: 8.
17.2.2.6 Indoctrination and Training:
Identification of Changes:
Identification of Changes:
For operator training, the Plant Superintendent-Nuclear now has cognizance over this training along with the Manager, Nuclear Training.
For operator training, the Plant Superintendent-Nuclear now has cognizance over this training along with the Manager, Nuclear Training.
Line 808: Line 1,143:
Reason for the Changes:
Reason for the Changes:
These changes have been made to recognize the involvement of these functional managers in training personnel who work in the areas for which they are responsible.
These changes have been made to recognize the involvement of these functional managers in training personnel who work in the areas for which they are responsible.
Page 15 of 27
Page 15 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
 
The listing of the Manager of Engineering, Plant Superintendent-Nuclear and Radiation Protection as sharing responsibility for the training in their respective functional areas adds detail to what was provided previously. These changes are consistent with the responsibilities of these positions as defined in UFSAR Section 13.
Attachment 2 Discussion of Changes         to NG-93-2180 In the Quality Assurance Program Description Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
These changes do not affect quality assurance program commitments as previously reviewed and approved by the NRC and remain consistent with the provisions of 10 CFR Part 50, Appendix B. These changes do not reduce any commitment.
The listing of the Manager of Engineering, Plant Superintendent-Nuclear and Radiation Protection as sharing responsibility for the training in their respective functional areas adds detail to what was provided previously. These changes are consistent with the responsibilities of these positions as defined in UFSAR Section 13. These changes do not affect quality assurance program commitments as previously reviewed and approved by the NRC and remain consistent with the provisions of 10 CFR Part 50, Appendix B. These changes do not reduce any commitment.
: 9.
: 9. 17.2.3.7 Design Changes Identification of the Change:
17.2.3.7 Design Changes Identification of the Change:
The title of section 17.2.3.7 is changed from "Design Changes" to "Changes to Design Documents".
The title of section 17.2.3.7 is changed from "Design Changes" to "Changes to Design Documents".
Reason for the Change:
Reason for the Change:
Line 818: Line 1,153:
Basis for concluding that the change is acceptable under 10 CFR Part 50.54 (a)(3):
Basis for concluding that the change is acceptable under 10 CFR Part 50.54 (a)(3):
The change in title is an editorial change per 10 CFR 50.54(a)(3).
The change in title is an editorial change per 10 CFR 50.54(a)(3).
: 10. 17.2.3.8 Design Review Committees Identification of the Change:
: 10.
17.2.3.8 Design Review Committees Identification of the Change:
The title of this section is revised from "Design Review Committee" to "Independent Review Committees".
The title of this section is revised from "Design Review Committee" to "Independent Review Committees".
The following information is deleted from this section:
The following information is deleted from this section:  
    "Design changes require a safety evaluation and concurrence by the Operations Committee. The Operations Committee shall bring to the attention of the Safety Committee those design changes that are deemed to involve an unreviewed safety Page 16 of 27
"Design changes require a safety evaluation and concurrence by the Operations Committee. The Operations Committee shall bring to the attention of the Safety Committee those design changes that are deemed to involve an unreviewed safety Page 16 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description question, or are deemed to be inconsistent with the Technical Specifications."
 
Attachment 2 Discussion of Changes         to NG-93-2180 In the Quality Assurance Program Description question, or are deemed to be inconsistent with the Technical Specifications."
Reason for the Change:
Reason for the Change:
The revised title makes it clear that this section addresses the independent review committees.
The revised title makes it clear that this section addresses the independent review committees.
The deletion is made because this material is an unnecessary duplication of the Technical Specifications section 6.5 and ANSI N18.7-1976 section 4.3.4 and creates confusion. The first sentence of section 17.2.3.8 already states the requirements of the technical specifications will be satisfied. It is unnecessary to repeat the requirements in section 17.2.3.8.
The deletion is made because this material is an unnecessary duplication of the Technical Specifications section 6.5 and ANSI N18.7-1976 section 4.3.4 and creates confusion. The first sentence of section 17.2.3.8 already states the requirements of the technical specifications will be satisfied.
The elimination of this material also eliminates any confusion between a "design change" and "change to the facility as described in the Safety Analysis Report." ANSI N18.7-1976, Technical Specifications, and 10 CFR 50.59 all use the terminology of "change to the facility".
It is unnecessary to repeat the requirements in section 17.2.3.8.
The elimination of this material also eliminates any confusion between a "design change" and "change to the facility as described in the Safety Analysis Report."
ANSI N18.7-1976, Technical Specifications, and 10 CFR 50.59 all use the terminology of "change to the facility".
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
The revised title to section 17.2.3.8 is an editorial change in accordance with 10 CFR Part 50.54(a)(3).
The revised title to section 17.2.3.8 is an editorial change in accordance with 10 CFR Part 50.54(a)(3).
As indicated above, the commitments contained in the material being removed continue to exist, ie, ANSI N18.7 section 4.3.4 and the DAEC Technical Specification section 6.5. Specifically, the following comparisons are made:
As indicated above, the commitments contained in the material being removed continue to exist, ie, ANSI N18.7 section 4.3.4 and the DAEC Technical Specification section 6.5.
17.2.3.8 previously stated: "Design changes require a safety evaluation and concurrence by the Operations Committee."   DAEC Technical Specifications section 6.5.1.5.d states:   "The Operations Committee shall be responsible for:
Specifically, the following comparisons are made:
17.2.3.8 previously stated:  
"Design changes require a safety evaluation and concurrence by the Operations Committee."
DAEC Technical Specifications section 6.5.1.5.d states:  
"The Operations Committee shall be responsible for:
(d) Review of all proposed changes or modifications to plant systems or equipment that affects nuclear safety."
(d) Review of all proposed changes or modifications to plant systems or equipment that affects nuclear safety."
Page 17 of 27
Page 17 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description The other sentence removed from 17.2.3.8 states:  
 
"The Operations Committee shall bring to the attention of the Safety Committee those design changes that are deemed to involve an unreviewed safety question, or are deemed to be inconsistent with the Technical Specification".
Attachment 2 Discussion of Changes         to NG-93-2180 In the Quality Assurance Program Description The other sentence removed from 17.2.3.8 states:
ANSI N18.7-1976 section 4.3.4(2) states: "The following subjects shall be reviewed by the independent review body:
    "The Operations Committee shall bring to the attention of the Safety Committee those design changes that are deemed to involve an unreviewed safety question, or are deemed to be inconsistent with the Technical Specification".
(2) Proposed changes in...
ANSI N18.7-1976 section 4.3.4(2) states: "The following subjects shall be reviewed by the independent review body:   (2) Proposed changes in ... the facility any of which involves a change in the technical specifications or an unreviewed safety question as defined in 10 CFR 50.59(c). Matters of this kind shall be referred to the independent review body by the onsite operating organization following its review, or by other functional organizational units within the owner organization, prior to implementation.
the facility any of which involves a change in the technical specifications or an unreviewed safety question as defined in 10 CFR 50.59(c).
This is also supported by the DAEC Technical Specifications section 6.5.2.7 which states:
Matters of this kind shall be referred to the independent review body by the onsite operating organization following its review, or by other functional organizational units within the owner organization, prior to implementation.
          "The Safety Committee shall be responsible for the review of:   (b) Proposed changes to procedures, equipment or systems which involve an unreviewed safety question as defined in Section 50.59, 10 CFR. "Also Technical Specification 6.5.2.7(d) states:   "Proposed changes in Technical Specifications or licenses."
This is also supported by the DAEC Technical Specifications section 6.5.2.7 which states:  
"The Safety Committee shall be responsible for the review of:
(b) Proposed changes to procedures, equipment or systems which involve an unreviewed safety question as defined in Section 50.59, 10 CFR.  
"Also Technical Specification 6.5.2.7(d) states:  
"Proposed changes in Technical Specifications or licenses."
In conclusion, the requirements previously stated in section 17.2.3.8 continue to apply by virtue of the DAEC Technical Specifications and the commitment to ANSI N18.7-1976 as specified in UFSAR 17.2 Appendix A, section 6. This change has no affect on the quality assurance program requirements and is therefore not a reduction in commitment.
In conclusion, the requirements previously stated in section 17.2.3.8 continue to apply by virtue of the DAEC Technical Specifications and the commitment to ANSI N18.7-1976 as specified in UFSAR 17.2 Appendix A, section 6. This change has no affect on the quality assurance program requirements and is therefore not a reduction in commitment.
Page 18 of 27
Page 18 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description
 
: 11.
Attachment 2 Discussion of Changes         to NG-93-2180 In the Quality Assurance Program Description
17.2.4.5 Quality Assurance Department Review of Procurement Documents Identification of the Change:
: 11. 17.2.4.5   Quality Assurance Department Review of Procurement Documents Identification of the Change:
Section 17.2.4.5 is deleted in its entirety.
Section 17.2.4.5 is deleted in its entirety. It reads as follows:
It reads as follows:  
        "Procurement documents for safety related items and services are reviewed and approved by the Quality Assurance Department for appropriate inclusion of quality requirements."
"Procurement documents for safety related items and services are reviewed and approved by the Quality Assurance Department for appropriate inclusion of quality requirements."
Former section 17.2.4.6 is also renumbered as 17.2.4.5.
Former section 17.2.4.6 is also renumbered as 17.2.4.5.
Reason for the Change:
Reason for the Change:
Line 853: Line 1,197:
This change is a reduction in commitment from that previously specified.
This change is a reduction in commitment from that previously specified.
Compliance with the requirements of 10 CFR 50 Appendix B, Criterion IV, "Procurement Document Control", is assured through UFSAR 17.2 sections 17.2.4.1 through 17.2.4.4. NRC approval of this change will permit Iowa Electric to begin the transition to remove Quality Assurance from the review and approval process of procurement documents and into assessing the performance of procurement document preparation. NRC approval of this change will permit the transition process to begin.
Compliance with the requirements of 10 CFR 50 Appendix B, Criterion IV, "Procurement Document Control", is assured through UFSAR 17.2 sections 17.2.4.1 through 17.2.4.4. NRC approval of this change will permit Iowa Electric to begin the transition to remove Quality Assurance from the review and approval process of procurement documents and into assessing the performance of procurement document preparation. NRC approval of this change will permit the transition process to begin.
Page 19 of 27
Page 19 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description
 
: 12.
Attachment 2 Discussion of Changes         to NG-93-2180 In the Quality Assurance Program Description
17.2.16.2 Conditions Adverse to Quality:
: 12. 17.2.16.2 Conditions Adverse to Quality:
Identification of Change:  
Identification of Change:
"Audits of vendors" has been revised to state "Audits of suppliers."
    "Audits of vendors" has been revised to state "Audits of suppliers."
Reason for the Change:
Reason for the Change:
This change has been made to achieve consistent usage throughout the document.
This change has been made to achieve consistent usage throughout the document.
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
This change is editorial only in accordance with the provisions of 10 CFR 50.54(a)(3). This change is not a reduction in commitment.
This change is editorial only in accordance with the provisions of 10 CFR 50.54(a)(3).
: 13. UFSAR Section 17.2.18.2.1, External Organizations:
This change is not a reduction in commitment.
: 13.
UFSAR Section 17.2.18.2.1, External Organizations:
Identification of Change:
Identification of Change:
The term "vendors" is replaced with the term "suppliers".
The term "vendors" is replaced with the term "suppliers".
Line 869: Line 1,214:
The other sections of UFSAR 17.2 utilize the term "supplier" as opposed to the term "vendor".
The other sections of UFSAR 17.2 utilize the term "supplier" as opposed to the term "vendor".
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
This change is of an editorial nature only in accordance with 10 CFR 50.54(a)(3). This change is not a reduction in commitment.
This change is of an editorial nature only in accordance with 10 CFR 50.54(a)(3).
: 14. 17.2.18.5 Report and Closeout of Audit Findings:
This change is not a reduction in commitment.
: 14.
17.2.18.5 Report and Closeout of Audit Findings:
Identification of Change:
Identification of Change:
The fifth paragraph of this section states: "The corrective actions will be tracked to ensure that proper and timely corrective actions have occurred and that the audit report can be closed." This section is revised to read as follows:
The fifth paragraph of this section states: "The corrective actions will be tracked to ensure that proper and timely corrective actions have occurred and that the audit report can be closed."
    "The corrective actions will be tracked to ensure that proper and timely corrective actions have occurred prior to closure of the audit findings."
This section is revised to read as follows:  
Page 20 of 27
"The corrective actions will be tracked to ensure that proper and timely corrective actions have occurred prior to closure of the audit findings."
 
Page 20 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description Reason for the Change:
Attachment 2 Discussion of Changes         to NG-93-2180 In the Quality Assurance Program Description Reason for the Change:
The "audit report" can be handled separately from the tracking and closure of the "audit findings."
The "audit report" can be handled separately from the tracking and closure of the "audit findings."   The audit report has served its function once it is issued while the corrective actions will be completed over some period of time.
The audit report has served its function once it is issued while the corrective actions will be completed over some period of time.
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
The purpose of the statement: "and that the audit report can be closed" was to focus on the need to keep the corrective action document open until the corrective actions have been completed. However, it is not necessary to keep the audit report open for that period of time if a tracking system separate from the audit report is utilized. This change is editorial. The tracking of corrective actions until proper and timely corrective actions have occurred continues to be required. This change does not affect the quality assurance commitments as previously reviewed and approved by the NRC and continues to comply with the provisions of Appendix B to 10 CFR Part 50. This change is not a reduction in commitment.
The purpose of the statement: "and that the audit report can be closed" was to focus on the need to keep the corrective action document open until the corrective actions have been completed. However, it is not necessary to keep the audit report open for that period of time if a tracking system separate from the audit report is utilized. This change is editorial.
: 15. UFSAR 17.2, Appendix A, Section 6.3 Identification of the Changes:
The tracking of corrective actions until proper and timely corrective actions have occurred continues to be required. This change does not affect the quality assurance commitments as previously reviewed and approved by the NRC and continues to comply with the provisions of Appendix B to 10 CFR Part 50.
This change is not a reduction in commitment.
: 15.
UFSAR 17.2, Appendix A, Section 6.3 Identification of the Changes:
The sentence "Specifically, a Quorum at Safety Committee meetings shall consist of at least four members plus the Chairman or Vice Chairman" has been deleted from the end of paragraph 6.3.
The sentence "Specifically, a Quorum at Safety Committee meetings shall consist of at least four members plus the Chairman or Vice Chairman" has been deleted from the end of paragraph 6.3.
Reason for the Changes:
Reason for the Changes:
The above change is incorporated as a result of NRC comment in the NRC letter of November 5, 1992, G. Wright to L. Liu.
The above change is incorporated as a result of NRC comment in the NRC letter of November 5, 1992, G. Wright to L. Liu.
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
This change was made consistent with the comments provided in the above referenced letter of November 5, 1992. This change was previously evaluated as acceptable by the NRC.
This change was made consistent with the comments provided in the above referenced letter of November 5, 1992.
Page 21 of 27
This change was previously evaluated as acceptable by the NRC.
 
Page 21 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description
Attachment 2 Discussion of Changes         to NG-93-2180 In the Quality Assurance Program Description
: 16.
: 16. UFSAR 17.2 Appendix A, Section 6.8.:
UFSAR 17.2 Appendix A, Section 6.8.:
Identification of the Change:
Identification of the Change:
Appendix A to UFSAR 17.2 is revised by inserting a new section 6.8, and renumbering previous sections 6.8 and 6.9 as 6.9 and 6.10 respectively. The new section 6.8 modifies the DAEC commitment for the biennial review of procedures as follows:
Appendix A to UFSAR 17.2 is revised by inserting a new section 6.8, and renumbering previous sections 6.8 and 6.9 as 6.9 and 6.10 respectively. The new section 6.8 modifies the DAEC commitment for the biennial review of procedures as follows:
ANSI N18.7-1976, Section 5.2.15 (Review, Approval and Control of Procedures), fourth paragraph states:
ANSI N18.7-1976, Section 5.2.15 (Review, Approval and Control of Procedures), fourth paragraph states:  
        "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."
"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."
This commitment is replaced by the following:
This commitment is replaced by the following:  
        "Plant procedures shall be reviewed in accordance with the following to determine if changes are necessary or desirable:
"Plant procedures shall be reviewed in accordance with the following to determine if changes are necessary or desirable:
: 1)   Non-routine procedures, such as emergency operating procedures, off-normal procedures, those that implement the emergency plan, and others where usage may be dictated by an event, shall be reviewed at least every two years by an individual knowledgeable in the area affected by the procedure.
: 1)
: 2)   The procedures which have a frequency of use which exceeds two years, shall be reviewed prior to use, or every two years by an individual knowledgeable in the area affected by the procedure.
Non-routine procedures, such as emergency operating procedures, off-normal procedures, those that implement the emergency plan, and others where usage may be dictated by an event, shall be reviewed at least every two years by an individual knowledgeable in the area affected by the procedure.
: 3)   Routine Plant Procedures which are not addressed by (1) and (2) above shall be maintained through use of the procedure revision process, as necessary or desirable changes are identified through use. In addition, on a frequency not to exceed 2 years, an independent audit or assessment of Page 22 of 27
: 2)
 
The procedures which have a frequency of use which exceeds two years, shall be reviewed prior to use, or every two years by an individual knowledgeable in the area affected by the procedure.
Attachment 2 Discussion of Changes         to NG-93-2180 In the Quality Assurance Program Description a representative sample of routine plant procedures shall be performed to evaluate the effectiveness of the procedure review and revision program.
: 3)
Routine Plant Procedures which are not addressed by (1) and (2) above shall be maintained through use of the procedure revision process, as necessary or desirable changes are identified through use.
In addition, on a frequency not to exceed 2 years, an independent audit or assessment of Page 22 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description a representative sample of routine plant procedures shall be performed to evaluate the effectiveness of the procedure review and revision program.
Reason for the Change:
Reason for the Change:
This change is made to utilize resources more effectively and at the same time maintain a high level of quality in the program for maintenance of our plant procedures.
This change is made to utilize resources more effectively and at the same time maintain a high level of quality in the program for maintenance of our plant procedures.
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
This change is categorized as a reduction in commitment since plant procedures which are of a routine nature will no longer require a separate biennial review. However, the controls specified above will continue to assure a high level of quality is maintained in the plant procedures. The controls specified above are also consistent with the provisions of 10 CFR Part 50, Appendix B for the control of procedures, including revisions thereto.
This change is categorized as a reduction in commitment since plant procedures which are of a routine nature will no longer require a separate biennial review. However, the controls specified above will continue to assure a high level of quality is maintained in the plant procedures. The controls specified above are also consistent with the provisions of 10 CFR Part 50, Appendix B for the control of procedures, including revisions thereto.
: 17. UFSAR 17.2, Appendix A, Section 11:
: 17.
UFSAR 17.2, Appendix A, Section 11:
11.6 Identification of Change (Clarification):
11.6 Identification of Change (Clarification):
This clarification/exception currently recognizes the adoption of SNT-TC-1A-1980 as the standard by which nondestructive examination personnel will be qualified. An addition is made to this clarification/exception which states:
This clarification/exception currently recognizes the adoption of SNT-TC-1A-1980 as the standard by which nondestructive examination personnel will be qualified. An addition is made to this clarification/exception which states:  
        "In accordance with Regulatory Guide 1.147, ASME Code Case N-356, and Iowa Electric ASME Section XI Relief Request NDE-006, the recertification period for NDE Level III personnel shall be every five years as opposed to the previously specified 3 years as stated in SNT-TC-1A-1980, paragraph 9.7.1.
"In accordance with Regulatory Guide 1.147, ASME Code Case N-356, and Iowa Electric ASME Section XI Relief Request NDE-006, the recertification period for NDE Level III personnel shall be every five years as opposed to the previously specified 3 years as stated in SNT-TC-1A-1980, paragraph 9.7.1.
Reason for the Change:
Reason for the Change:
Iowa Electric ASME Section XI Relief Request NDE-006 was previously reviewed and approved by the NRC but was not Page 23 of 27
Iowa Electric ASME Section XI Relief Request NDE-006 was previously reviewed and approved by the NRC but was not Page 23 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description recognized in the quality assurance program commitments in UFSAR 17.2, Appendix A.
 
Attachment 2 Discussion of Changes           to NG-93-2180 In the Quality Assurance Program Description recognized in the quality assurance program commitments in UFSAR 17.2, Appendix A.
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
Regulatory Guide 1.147, Revision 9 of April 1992 recognizes that the conditions of Code Case N-356 were adopted by the NRC on July 1, 1988. Iowa Electric ASME Section XI Relief Request NDE-006 was approved by the NRC on September 16, 1988.
Regulatory Guide 1.147, Revision 9 of April 1992 recognizes that the conditions of Code Case N-356 were adopted by the NRC on July 1, 1988.
The incorporation of this Code Case and relief request into UFSAR 17.2 Appendix A does not reduce the quality assurance program commitments as previously reviewed and approved by the NRC because the change has previously been reviewed and approved by the NRC. This change is not a reduction in commitment.
Iowa Electric ASME Section XI Relief Request NDE-006 was approved by the NRC on September 16, 1988.
: 18. UFSAR 17.2, Appendix A, Section 18:
The incorporation of this Code Case and relief request into UFSAR 17.2 Appendix A does not reduce the quality assurance program commitments as previously reviewed and approved by the NRC because the change has previously been reviewed and approved by the NRC.
This change is not a reduction in commitment.
: 18.
UFSAR 17.2, Appendix A, Section 18:
18.4 Identification of Change (Clarification/Exception):
18.4 Identification of Change (Clarification/Exception):
ANSI N45.2.12, Section 4.3.1, "Pre-Audit Conference",
ANSI N45.2.12, Section 4.3.1, "Pre-Audit Conference",
Line 922: Line 1,276:
Two issues arise from that provision. First there is a conflict between the "shall" in ANSI N45.2.12, Section 4.3.1 and UFSAR Section 17.2.18.4 which uses a "should."
Two issues arise from that provision. First there is a conflict between the "shall" in ANSI N45.2.12, Section 4.3.1 and UFSAR Section 17.2.18.4 which uses a "should."
Secondly, an alternative to pre-audit conferences for internal audits is desired. These two issues are addressed by the addition below to UFSAR 17.2 Appendix A, Section 18.4:
Secondly, an alternative to pre-audit conferences for internal audits is desired. These two issues are addressed by the addition below to UFSAR 17.2 Appendix A, Section 18.4:
The first sentence of the commitment to ANSI N45.2.12, Section 4.3.1 is changed to read:   "A brief pre-audit conference should be conducted with cognizant organization management."
The first sentence of the commitment to ANSI N45.2.12, Section 4.3.1 is changed to read:  
Page 24 of 27
"A brief pre-audit conference should be conducted with cognizant organization management."
 
Page 24 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description In addition, for internal audits, a pre-audit planning meeting may be substituted for the pre-audit conference.
Attachment 2 Discussion of Changes         to NG-93-2180 In the Quality Assurance Program Description In addition, for internal audits, a pre-audit planning meeting may be substituted for the pre-audit conference.
The pre-audit planning meeting should accomplish the following:
The pre-audit planning meeting should accomplish the following:
: 1)   Obtain input on the subjects to be audited from the organization(s) to be audited.
: 1)
: 2)   Finalize the audit plan as a result of the input obtained at this audit planning meeting.
Obtain input on the subjects to be audited from the organization(s) to be audited.
: 3)   Introduce the Lead Auditor and identify the proposed audit team members. Those audit team members available will be introduced. Note: Non-utility team members are usually not available at these meetings.
: 2)
: 4)   Counterparts are invited to these audit planning meetings as part of the planning process.
Finalize the audit plan as a result of the input obtained at this audit planning meeting.
: 5)   The Audit Schedule is presented, including a tentative exit date. The final exit date is announced separately during the audit period.
: 3)
: 6)   The channels of communication are opened at the audit planning meeting through participation in the audit planning process.
Introduce the Lead Auditor and identify the proposed audit team members. Those audit team members available will be introduced. Note:
Non-utility team members are usually not available at these meetings.
: 4)
Counterparts are invited to these audit planning meetings as part of the planning process.
: 5)
The Audit Schedule is presented, including a tentative exit date.
The final exit date is announced separately during the audit period.
: 6)
The channels of communication are opened at the audit planning meeting through participation in the audit planning process.
Reason for the Changes:
Reason for the Changes:
The "should" vs "shall" is clarified between UFSAR Section 17.2.18.4 and ANSI N45.2.12 Section 4.3.1. The "should" contained in UFSAR 17.2 Appendix A Section 18.4 is now consistent with the previous 17.2.18.4.
The "should" vs "shall" is clarified between UFSAR Section 17.2.18.4 and ANSI N45.2.12 Section 4.3.1.
The use of audit planning meetings as an alternative to pre audit conference meetings will more effectively utilize the time of management personnel. We have used audit planning meetings for some time and they have proven to be quite beneficial in opening communications between the audited and auditing organizations and in focusing the audits on the areas of importance. The pre-audit conferences then become somewhat duplicative of the audit planning meeting.
The "should" contained in UFSAR 17.2 Appendix A Section 18.4 is now consistent with the previous 17.2.18.4.
The use of audit planning meetings as an alternative to pre audit conference meetings will more effectively utilize the time of management personnel.
We have used audit planning meetings for some time and they have proven to be quite beneficial in opening communications between the audited and auditing organizations and in focusing the audits on the areas of importance. The pre-audit conferences then become somewhat duplicative of the audit planning meeting.
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
The use of the term "should" with reference to pre-audit conferences is consistent with the previous content of UFSAR Section 17.2.18.4 as previously reviewed and approved by the NRC. A similar argument could be presented that the NRC Page 25 of 27
The use of the term "should" with reference to pre-audit conferences is consistent with the previous content of UFSAR Section 17.2.18.4 as previously reviewed and approved by the NRC. A similar argument could be presented that the NRC Page 25 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description previously approved the "shall" due to no exception or clarification being placed in UFSAR 17.2 Appendix A Section
 
: 18.
Attachment 2 Discussion of Changes         to NG-93-2180 In the Quality Assurance Program Description previously approved the "shall" due to no exception or clarification being placed in UFSAR 17.2 Appendix A Section 18.
The use of audit planning meetings as an alternative to pre audit conferences is a slightly different approach to audits than reflected by the existing commitment to ANSI N45.2.12 1977.
The use of audit planning meetings as an alternative to pre audit conferences is a slightly different approach to audits than reflected by the existing commitment to ANSI N45.2.12 1977. This change is considered a change in commitment but will not reduce the effectiveness of the operational quality assurance program. This change is in accordance with 10 CFR Part 50, Appendix B criteria XVIII, Audits, which requires a comprehensive system of planned and periodic audits be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program.
This change is considered a change in commitment but will not reduce the effectiveness of the operational quality assurance program. This change is in accordance with 10 CFR Part 50, Appendix B criteria XVIII, Audits, which requires a comprehensive system of planned and periodic audits be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program.
These changes will not be placed into effect until NRC review and approval is obtained.
These changes will not be placed into effect until NRC review and approval is obtained.
: 19. UFSAR SECTION 17.2, APPENDIX A, SECTION 19, Paragraph 19.3:
: 19.
UFSAR SECTION 17.2, APPENDIX A, SECTION 19, Paragraph 19.3:
Identification of the Change:
Identification of the Change:
ANSI N45.2.23-1978, Section 2.3.4, "Audit Participation",
ANSI N45.2.23-1978, Section 2.3.4, "Audit Participation",
states:
states:  
        "The prospective Lead Auditor shall have participated in a minimum of five (5) quality assurance audits within a period of time not to exceed three (3) years prior to the date of qualification, one audit of which shall be a nuclear quality assurance audit within the year prior to his qualification."
"The prospective Lead Auditor shall have participated in a minimum of five (5) quality assurance audits within a period of time not to exceed three (3) years prior to the date of qualification, one audit of which shall be a nuclear quality assurance audit within the year prior to his qualification."
As an alternative to ANSI N45.2.23 - 1978, Section 2.3.4, "Audit Participation" the following may be applied:
As an alternative to ANSI N45.2.23 -
        "The prospective Lead Auditor shall have participated in a minimum of two (2) nuclear quality assurance audits within a period of time not to exceed one (1) year prior to the date of qualification." This participation shall be at an equivalent level as a Lead Auditor, but under the supervision of a Lead Auditor.
1978, Section 2.3.4, "Audit Participation" the following may be applied:  
This includes responsibility for implementation of the audit process (i.e., planning, meetings, conduct Page 26 of 27
"The prospective Lead Auditor shall have participated in a minimum of two (2) nuclear quality assurance audits within a period of time not to exceed one (1) year prior to the date of qualification."
 
This participation shall be at an equivalent level as a Lead Auditor, but under the supervision of a Lead Auditor.
Attachment 2 Discussion of Changes         to NG-93-2180 In the Quality Assurance Program Description reporting, etc) and shall result in satisfactory performance as determined by management.
This includes responsibility for implementation of the audit process (i.e., planning, meetings, conduct Page 26 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description reporting, etc) and shall result in satisfactory performance as determined by management.
Reason for the Change:
Reason for the Change:
ANSI N45.2.23 - 1978, "Qualification of QA Program Audit Personnel for Nuclear Power Plants" addresses the following elements for qualification of personnel as Lead Auditors as defined in Section 2.3:
ANSI N45.2.23 -
2.3.1     Education and Experience 2.3.2     Communication Skill 2.3.3     Training 2.3.4     Audit Participation 2.3.5     Examination Section 2.3.4 requires "participation" in five (5) audits.
1978, "Qualification of QA Program Audit Personnel for Nuclear Power Plants" addresses the following elements for qualification of personnel as Lead Auditors as defined in Section 2.3:
The level of responsibility for implementing the audit process exercised by an individual can vary greatly depending on his/her assignment in a particular audit. For personnel who participate in two audits at the same level of responsibility as the Lead Auditor (i.e., the trainee performs all activities for the audit, including preparation of the audit plan and checklist, leads the audit under a Lead Auditors supervision, leads the pre- and post-audit conferences and is held responsible for the written report),
2.3.1 Education and Experience 2.3.2 Communication Skill 2.3.3 Training 2.3.4 Audit Participation 2.3.5 Examination Section 2.3.4 requires "participation" in five (5) audits.
The level of responsibility for implementing the audit process exercised by an individual can vary greatly depending on his/her assignment in a particular audit.
For personnel who participate in two audits at the same level of responsibility as the Lead Auditor (i.e., the trainee performs all activities for the audit, including preparation of the audit plan and checklist, leads the audit under a Lead Auditors supervision, leads the pre-and post-audit conferences and is held responsible for the written report),
the process and skills of auditing may be adequately demonstrated. A minimum of 2 audits at this level of participation are deemed necessary for the trainee to demonstrate the audit process and their skills to management to make a good judgement on qualification. Participating at this level for five audits may be unnecessary depending on the individuals capabilities.
the process and skills of auditing may be adequately demonstrated. A minimum of 2 audits at this level of participation are deemed necessary for the trainee to demonstrate the audit process and their skills to management to make a good judgement on qualification. Participating at this level for five audits may be unnecessary depending on the individuals capabilities.
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).
This change is a reduction in commitment but is consistent with the provisions of 10 CFR Part 50 Appendix B, criterion II, which requires indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained.
This change is a reduction in commitment but is consistent with the provisions of 10 CFR Part 50 Appendix B, criterion II, which requires indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained.
This change will not be placed into effect until NRC review and approval is obtained.
This change will not be placed into effect until NRC review and approval is obtained.
C:\procedur\QAPD.mem Page 27 of 27
C:\\procedur\\QAPD.mem Page 27 of 27


TABLE 3.2-1 INDEX Sys#     SysName                                                                     SysCode I       Reactor         System                                                       i11 II       Nuclear         Boiter         System                                       821 III     Recirculation               System                                         B31 IV       CRD   Hydraulic           System                                         C1i V         Standby         Liquid       Control         System                       C41 VI       Neutron         Monitoring           System                               C51 VII       Reactor         Protection           System                               C71 VIII       Process         Radiation           Monitors                               Oi IX       RHR     System                                                             El x         Low     Pressure           Core     Spray                                 E21 XI         NPCI     System                                                           E41 XII       RCIC     System                                                           E51 XIlf       Fuel     Service         Equipment                                       Fil XIV       Reactor         Vessel         Service         Equipment                   F13 XV         In*Vesset           Service         Equipment                             F14 XVI       Refueling           Equipment                                             Fis XVII     Storage         Equipment                                                   F16 XVIII     Radwaste           System                                                   Gil XIX       Reactor         water       Cleanup         System                         G31 KD       Fuel     Pool       Cooling         and     Cleanup       System         G41 XXI       Control         Room       &   Remote       Shutdom         PanetsHl1     C61 xxII       Local       Panels         and     Racks                                   N21 XXIII     Offgas       System                                                       M62 XXIV       Emergency           Service         Water                                 E13 XXV       RHR     Service         Water       System                                 E12 XXVI       RBCCU                                                                       P42 XXVII     Wall     Water         System                                               P46 XXVIII     Pneumatic           Systems                                           T48 P50 XXIX     Diesel         Generator           System                                   R43 XXX     Containment             Atmosphere             Control       System         T48 XXXI       Standby         Gas     Treatmnt           System                         T46 XXXII     ECCS     Equipment           Area       Cooling       System             T41 XXXIII     Power       Conversion             System                               M11 N21 XXIV     Condensate             Storage         and     Transfer       System       P11 XXXV       Essential           a-c     Power       System           R20-24       R35 R43 XXXVI     125/250         Volt     d-c     Power       System                       R42 XXXVII     River       Water       Supply                                             W10 XXXVIII   NSIV     Leakage         Control                                           321 KXIX       NVAC XXXX       Miscellaneous               Components T3. 2-1                                                             Revision 10 - 6/92
TABLE 3.2-1 INDEX Sys#
SysName SysCode I
Reactor System i11 II Nuclear Boiter System 821 III Recirculation System B31 IV CRD Hydraulic System C1i V
Standby Liquid Control System C41 VI Neutron Monitoring System C51 VII Reactor Protection System C71 VIII Process Radiation Monitors Oi IX RHR System El x
Low Pressure Core Spray E21 XI NPCI System E41 XII RCIC System E51 XIlf Fuel Service Equipment Fil XIV Reactor Vessel Service Equipment F13 XV In*Vesset Service Equipment F14 XVI Refueling Equipment Fis XVII Storage Equipment F16 XVIII Radwaste System Gil XIX Reactor water Cleanup System G31 KD Fuel Pool Cooling and Cleanup System G41 XXI Control Room &
Remote Shutdom PanetsHl1 C61 xxII Local Panels and Racks N21 XXIII Offgas System M62 XXIV Emergency Service Water E13 XXV RHR Service Water System E12 XXVI RBCCU P42 XXVII Wall Water System P46 XXVIII Pneumatic Systems T48 P50 XXIX Diesel Generator System R43 XXX Containment Atmosphere Control System T48 XXXI Standby Gas Treatmnt System T46 XXXII ECCS Equipment Area Cooling System T41 XXXIII Power Conversion System M11 N21 XXIV Condensate Storage and Transfer System P11 XXXV Essential a-c Power System R20-24 R35 R43 XXXVI 125/250 Volt d-c Power System R42 XXXVII River Water Supply W10 XXXVIII NSIV Leakage Control 321 KXIX NVAC XXXX Miscellaneous Components Revision 10 6/92 T3. 2-1


TABLE 3.2-1 INDEX Sys#     SysName                                                                       SysCode XXXVI     125/250         Volt       d-c     Power       System                     R42 XXXIV     Condensate               Storage         and     Transfer       System     P11 xxx       Containment               Atmosphere           Control       System       T48 XXI         Control           Room &         Remote       Shutdown       PaneLsH11     C61 IV       CRD     Hydraulic             System                                       C11 XXIX       Diesel         Generator             System                                 R43 XXXII       ECCS       Equipment             Area     Cooling       System             T41 KXIV       Emergency             Service         Water                                 E13 XXXV       Essential               a-c     Power       System           R20-24     R35 R43 K0         Fuel     Pool         Cooling         and     Cleanup       System         G41 XIII       Fuel       Service           Equipment                                       F11 xI         HPCI       System                                                             E41 XXIX   NVAC XV         In-Vesset             Service         Equipment                             F14 XXII       Local       Panels         an     Racks                                   M21 X           Low     Pressure           Core       Spray                                 E21 XXXX       Miscellaneous                   Components XXXVIII   MSIV       Leakage           Control                                         321 VI         Neutron           Monitoring             System                             c51 II         Nuclear           loiler         System                                       B21 XXIII       Offgas         System                                                       g62 XXVIII     Pneumatic             Systems                                           T48 P50 XXIII Power         Conversion             System                             NIl U21 VIII       Process           Radiation             Monitors                             D11 VIII   Radeaste           System                                                   611 XXVI       RCCW                                                                         P42 XII         RCIC       System                                                             E51 VII         Reactor         Protection               System                             C71 I         Reactor           System                                                       a11 XIV         Reactor           Vessel           Service         Equipment                   F13 XIX         Reactor           Water         Cleaup           System                       031 III       Recirculation                   System                                         331 XVI         Refueling               Equipment                                             F15 XXV         RNR       Service           Water       System                               E12 IX         RNR       System                                                               El XXXVII     River         Water         Supply                                               10 ExMI       Standby           Gas       Treatment           System                         T46 V           Stanby           Liquid         Control         System                       C41 XVII       Storage           Equipment                                                   F16 XXVII       Well       Water         System                                               P46 T3. 2-2                                                   Revision 1 9
TABLE 3.2-1 INDEX Sys#
SysName SysCode XXXVI 125/250 Volt d-c Power System R42 XXXIV Condensate Storage and Transfer System P11 xxx Containment Atmosphere Control System T48 XXI Control Room &
Remote Shutdown PaneLsH11 C61 IV CRD Hydraulic System C11 XXIX Diesel Generator System R43 XXXII ECCS Equipment Area Cooling System T41 KXIV Emergency Service Water E13 XXXV Essential a-c Power System R20-24 R35 R43 K0 Fuel Pool Cooling and Cleanup System G41 XIII Fuel Service Equipment F11 xI HPCI System E41 XXIX NVAC XV In-Vesset Service Equipment F14 XXII Local Panels an Racks M21 X
Low Pressure Core Spray E21 XXXX Miscellaneous Components XXXVIII MSIV Leakage Control 321 VI Neutron Monitoring System c51 II Nuclear loiler System B21 XXIII Offgas System g62 XXVIII Pneumatic Systems T48 P50 XXIII Power Conversion System NIl U21 VIII Process Radiation Monitors D11 VIII Radeaste System 611 XXVI RCCW P42 XII RCIC System E51 VII Reactor Protection System C71 I
Reactor System a11 XIV Reactor Vessel Service Equipment F13 XIX Reactor Water Cleaup System 031 III Recirculation System 331 XVI Refueling Equipment F15 XXV RNR Service Water System E12 IX RNR System El XXXVII River Water Supply 10 ExMI Standby Gas Treatment System T46 V
Stanby Liquid Control System C41 XVII Storage Equipment F16 XXVII Well Water System P46 Revision 1
T3. 2-2 9


Table 3.2-1 DABC Classification of Compoacts in Systems Scope Equivalent                      II Quality Quality                            ASNE of  Safety  Code        Construction        Group Assurance  Seismic              3 & PV Code Principal Component             Supply Clas    Class            Code            Class  Req. Category PO Date    Section III Footnotes Comments (a)      (b)                    (c)                    (d)        (e)(f)      (9)        (h)                (i)
Table 3.2-1 DABC Classification of Compoacts in Systems Principal Component IReactor Systest11
IReactor Systest11
: 1. Reactor vessel
: 1. Reactor vessel                     a/C  I        A    ASHE Section III, 1965    A          a          I                            id 1
: 2. Reactor vessel support skirt
Edition, Summer 1967 Addenda
: 3. Reactor vesset appurtenances, pressure retaining portions
: 2. Reactor vessel support skirt       GE    I        A    ASHE Section III, 1965    A          I                                        Id Edition, Summer 1967 1
: 4. CRD Housing Supports (Shoot-out Steel)
Addenda
S. Reactor internal structures, engineered safety features
: 3. Reactor vesset appurtenances,       GE    1        A    ASHE Section iII, 1965    A          I                              1        Id pressure retaining portions I
: 6. Reactor internal structures, other
Edition, Sumimer 1967 Addenda
: 7. Control rods
: 4. CRD Housing Supports (Shoot-out     GE    2
: 8. Control rod drives
* I Steel)
: 9. Core support structure
S. Reactor internal structures,       GE    2        A    ASHE Section Ill,  1965  MA        3          I engineered safety features                                                                                                           1d,lu              I1P Edition, Summer 1967 Addenda
: 10. Power range detector hardware
: 6. Reactor internal structures, other GE    Other                                  MA        U          I                              tu
: 11. Fuel assemblies
: 7. Control rods                       GE    2                                      MA        BS        I
: 12.
: 8. Control rod drives                 GE    I        I    Section III, Class 1      A          8          I appurtenances
AN Vessel Stabilizer
: 9. Core support structure             GE    2        A    ASHE Section III, 1965    NA        a          I                    NG        1d,lu Edition, Summer 1967 Addenda
: 13. Refueling bellows II Nuclear Boiler System 321
: 10. Power range detector hardware       GE    2 I
: 1. Vessels, level instrumentation condensing chambers
8          8a        I                    2        la,lb
: 2. Vessels, M2 accumulators
: 11. Fuel assemblies                     GE    2                                      NA        I          I                                                    I
: 3. Piping, relief valve discharge
: 12. AN Vessel Stabilizer               GE    2        A    ASHE Section Ill, 1965    NA        B3 Edition, Summer 1967 Addenda
: 4. Piping, main steam within outermost isolation valve S. Pipe supports, main steam
: 13. Refueling bellows                   GE    Other                                                        NA II       Nuclear Boiler System 321
: 1. Vessels, level instrumentation     GE    I                                      A          B          I                    1 condensing chambers
: 2. Vessels, M2 accumulators           0    2        2    ASHE Section III                                        02/26/73    2                            I  11
: 3. Piping, relief valve discharge     A    3        3    USAS 831.7-1969          C                    I      07/30/70    3
: 4. Piping, main steam within           GE    I            ANSI 331.1.0 + Code Cases A          B                  12/05/69    1 outermost isolation valve                                                                                                           la,lb N-2,N-7,N-9,N-1O S. Pipe supports, main steam           GE    1        1    Requirements for Class I  A          B          I      02/26/71    1 piping supports in ANSI 331.7.
: 6. Pipe restraints, main stem
: 6. Pipe restraints, main stem
* 2                                      NA        a          I      -          2
: 7. Piping, other within outermost isolation valves
: 7. Piping, other within outermost     B     1       1   USAS 331.7-1969           A         B           I       07/30/70     1       la,lb isolation valves
: 8. Piping, instrumentation beyond outermost isolation valves Scope of Safety Supply Clas (a)
: 8. Piping, instrumentation beyond      a    Other        USAS B31.1.0-1967                  A                - --                    la,1b outermost isolation valves IELP/Systems,Class/Systems Cji W'
(b) a/C I
I-
GE I
GE 1
GE 2
GE 2
GE Other GE 2
GE I
GE 2
GE GE GE 2
2 2
Code Class Construction Code (c)
A ASHE Section III, 1965 Edition, Summer 1967 Addenda A
ASHE Section III, 1965 Edition, Summer 1967 Addenda A
ASHE Section iII, 1965 Edition, Sumimer 1967 Addenda A
ASHE Section Ill, 1965 Edition, Summer 1967 Addenda I
Section III, Class 1 appurtenances A
ASHE Section III, 1965 Edition, Summer 1967 Addenda A
GE Other GE I
0 2
A 3
GE I
GE 1
2 B
1 a
Other ASHE Section Ill, 1965 Edition, Summer 1967 Addenda 2
ASHE Section III 3
USAS 831.7-1969 ANSI 331.1.0 + Code Cases N-2,N-7,N-9,N-1O 1
Requirements for Class I piping supports in ANSI 331.7.
1 USAS 331.7-1969 USAS B31.1.0-1967 Quality Group Class A
A A
MA MA MA A
NA 8
NA NA Quality Assurance Req.
(d)
Seismic Category (e)(f)
PO Date (9) a I
I I
Equivalent ASNE 3 & PV Code Section III Footnotes (h) 1 1
I 3
I id Id Id 1d,lu U
BS 8
a I
8a I
B3 tu NG 1d,lu 2
la,lb I
I NA A
C A
A NA A
B I
B B
a B
A I
1 02/26/73 07/30/70 12/05/69 2
3 1
la,lb I
02/26/71 1
I 2
I 07/30/70 1
la,lb la,1b IELP/Systems,Class/Systems I I Comments (i)
I1P I
Cji W'
I-11 1
I I
I I
I I


Table 3.2,1 DABC Classification of Compoacas in Systeams Sco.                                             Quality  Quality Equivalent ASHE 110 of Safety    Code        Construction        Group Assurance  Seismc              B A PV Code Principal Component      Supply   Class  Class            Code            Class  Req.      Category PO Date    Section III Footnotes Comments (a)     (b)                     (c)                      (d)        (e)(f)    (g)/        (h)                (1)
Table 3.2,1 DABC Classification of Compoacas in Systeams Principal Component Sco.
: 9. Safety valves                   GE   1         1   ANSI 131.1.0, Addends and A          U            I    12/30/69      1          If applicable code cases or MDE standards of B31.1.
of Supply (a)
Code Cases N2,N7,M9,N10 except that the acceptance standards for Class I valves in the Draft ASNE Code for Puaps and Valves for Nuclear Power my be applied. Use ANSI 16.5 or NSS-SP-66 for design
GE
: 10. Relief valves                    GE    I          1    ANSI 931.1.0, Addends and A          1          I      12/30/69    1        If applicable code cases or NDE standards of B31.1.
: 9. Safety valves
Code Cases N2,11Y,9,110 except that the acceptance standards for Class I valves in the Draft ASNE Code for Pumps and Valves for Nuclear Power my be applied. Use ANSI 16.5 or NSS-SP-66 for design
: 10. Relief valves Safety Class (b) 1 GE I
: 11. Valves, mmin stem isolation      GE    1          I    ANSI 131.1.0. Addends and A          a          I    10/15/69      1        If valves                                                applicable code cases or NDE standards of B31.1.
: 11. Valves, mmin stem isolation valves 12, Valves, other, isolation valves and within
Code Cases 12,.1,9,M10 except that the acceptance standards for Class I valves in the Draft AM Code for Pumps and Valves for Nuclear Power my be applied. Use ANSI 16.5 or NSS-SP-66 for design 12, Valves, other, isolation valves  8    1         1    ASHE Code for Pumps and   A          0          I      10/16/70    I          If and within                                            Valves for Nuclear Power
: 13. Valves. instrumenqation beyond outermost isolation valves
: 13. Valves. instrumenqation beyond        Other          USAS 831.1.0-1967 outermost isolation valves 8
: 14. Nechanical modules, instrumentation, with safety function
la,lb,1f          Ito
: 15. Electrical modules with safety function
: 14. Nechanical modules,            GE    2                                                                                              Ic instrumentation, with safety
: 16. Cable, with safety function Recirculation System 031
* I function
: 1. Piping GE 1
: 15. Electrical modules with safety  GE    2                                          NA                                                  ic function
8 8
* I
1 Other GE 2
: 16. Cable, with safety function    0    2                                                                I Recirculation System 031
GE 2
* 10o
0 2
: 1. Piping                          GE    1        -    ANSI 031.1.0 + Code Cases A         B           I     12/05/69     1         la,lb N2,N7.N9.N1O IELP/SystemsClass/Systems I-.
GE 1
Code Class Construction Code (c) 1 ANSI 131.1.0, Addends and applicable code cases or MDE standards of B31.1.
Code Cases N2,N7,M9,N10 except that the acceptance standards for Class I valves in the Draft ASNE Code for Puaps and Valves for Nuclear Power my be applied.
Use ANSI 16.5 or NSS-SP-66 for design 1
ANSI 931.1.0, Addends and applicable code cases or NDE standards of B31.1.
Code Cases N2,11Y,9,110 except that the acceptance standards for Class I valves in the Draft ASNE Code for Pumps and Valves for Nuclear Power my be applied.
Use ANSI 16.5 or NSS-SP-66 for design I
ANSI 131.1.0. Addends and applicable code cases or NDE standards of B31.1.
Code Cases 12,.1,9,M10 except that the acceptance standards for Class I valves in the Draft AM Code for Pumps and Valves for Nuclear Power my be applied.
Use ANSI 16.5 or NSS-SP-66 for design 1
ASHE Code for Pumps and Valves for Nuclear Power USAS 831.1.0-1967 Quality Quality Group Assurance Class Req.
(d)
A U
A Seismc Category (e)(f)
I PO Date (g)/
12/30/69 Equivalent ASHE B A PV Code Section III Footnotes (h) 1 If 1
I 12/30/69 1
If A
a I
10/15/69 1
A NA ANSI 031.1.0 + Code Cases N2,N7.N9.N1O 0
I 10/16/70 If I
If la,lb,1f I
I I
A Ic ic 10o B
I 12/05/69 1
IELP/SystemsClass/Systems la,lb I-.
110 Comments (1)
Ito


Table 3.'
Table 3.'
DAEC Classificatiom of Composcats in Systcas                                                               I0 Equivalent Scope                                             Ouslity  Quality                        ASHE of Safety    Code        Construction          Group Assurance  Sefsmic            8 & PV Code Principal Component            Supply   Class  Class            Code              Class  Req. Category PO Date  Section III Footnotes Comments (a)     (b)                     (c)                      (d)      (e)(f)    (/)/        (h)                (1)
DAEC Classificatiom of Composcats in Systcas Principal Component
: 2. Pipe suspension, recirculation      GE   I         1    Requirements for Class I   A          I        I      02/26/71    1        -
: 2. Pipe suspension, recirculation tine
tine                                                    piping supports in ANSI 031.7.
: 3. Pipe restraints recirculation line
: 3. Pipe restraints recirculation line  OR    2                                          MA          3        I                  2
: 4.
: 4. Pumps                              GE    I        1   Draft ASHE Code for Pums   A          8        I      11/22/68    1 and Valves for Nuclear Power or MDE and acceptance requirements of ANSI 131.1 Code Cases N7,N9,NiO +
Pumps S. Valves
: 6. Motor, pump
: 7. Electrical modules, with safety function
: 8. Cable with safety function IV CAD Hydrautic System CII
: 1. Valves, isolation, water return line
: 2. Valves, scram discharge volume lines
: 3. Valves insert and withdraw lines
: 4. Valves, other
: 5. Piping, water return line within isolation valves
: 6. Piping, scram discharge volume lines
: 7. Piping, insert and withdraw lines Scope of Supply (a)
GE Safety Class (b)
I Code Class 1
OR 2
GE I
Construction Code (c)
Requirements for Class I piping supports in ANSI 031.7.
1 Draft ASHE Code for Pums and Valves for Nuclear Power or MDE and acceptance requirements of ANSI 131.1 Code Cases N7,N9,NiO +
Design Guide for sizing pressure parts in ASKE Boiler and Pressure Vessel Code (19681 Section III, Class C.
Design Guide for sizing pressure parts in ASKE Boiler and Pressure Vessel Code (19681 Section III, Class C.
S. Valves                              GE    I         I    Requirements for Class 1   A          B        I      03/20/70    1        if valves inDraft ASNE Code for Pumps and Valves for Nuclear Power and requirements applicable to valves in AS1E Section III
I Requirements for Class 1 valves in Draft ASNE Code for Pumps and Valves for Nuclear Power and requirements applicable to valves in AS1E Section III
[1968 Edition plus addenda), articles I and 8.
[1968 Edition plus addenda), articles I and 8.
: 6. Motor, pump 7.Electrical modules, with safety function GE GE NENA Standards             MA MA 6J)
NENA Standards GE I
B        I             -              Ic
Ouslity Quality Group Assurance Class Req.
                                                                                                                                            -ic
(d)
: 8. Cable with safety function        B     2                                                     B        I            -                                  10 IV        CAD Hydrautic System CII
A I
: 1. Valves, isolation, water return
MA A
* 1        I   ANSI 131.1.0 or ASKE Code   A          B        I      12/19/72    1        if line                                                  for Pumps and Valves for nuclear Power, Class 1, or ASKE Section III, 1971 Edition, Class I
3 8
: 2. Valves, scram discharge volume    GE/B 2/2       2   ASME Code for Pupe and     r/n        r/s      i/1I  12/19/72    2        if lines                                                  Valves for Nuclear Power
A B
: 3. Valves insert and withdraw lines  GE/B 2/2       2   ANSI 331.1.0 or ASHE Code   r/8          8/B    1/1    12/19/72    2        if for Pumps and Valves for Nuclear Power or ASKE Section Ill. 1971 Edition, Class 1
2 1
: 4. Valves, other                      6    Other     2   ASKE Section Ill, 1971     D          D        NA    12/19/72              la,1f,1(    Yes    10 Edition
I ANSI 131.1.0 or ASKE Code for Pumps and Valves for nuclear Power, Class 1, or ASKE Section III, 1971 Edition, Class I GE/B 2/2 2
: 5. Piping, water return line within  a    1         1   ASHE Section Ill, 1971     A          B       I      12/19/72    1 isolation valves                                      Edition
ASME Code for Pupe and Valves for Nuclear Power GE/B 2/2 2
: 6. Piping, scram discharge volume    B     2         2   ASHE Section Ill, 1971     I           8B      I     12/19/72     2 lines                                                  Edition
ANSI 331.1.0 or ASHE Code for Pumps and Valves for Nuclear Power or ASKE Section Ill. 1971 Edition, Class 1 6
: 7. Piping, insert and withdraw lines  B     2        2    ASHE Section  Ill, 1971    5          e       I     12/19/72     2 Edition IELP/System,Ciass/System
Other 2
ASKE Section Ill, 1971 Edition a
1 1
ASHE Section Ill, 1971 Edition B
2 2
ASHE Section Ill, 1971 Edition B
2 2
ASHE Section Ill, 1971 Edition A
B B
B r/n r/8 D
A I
5 r/s 8/B Sefsmic Category (e)(f)
I PO Date
(/)/
02/26/71 I
2 I
11/22/68 1
I 03/20/70 1
I I
I 12/19/72 1
i/1I 1/1 12/19/72 12/19/72 D
NA 12/19/72 B
8B e
I 12/19/72 I
12/19/72 I
12/19/72 Equivalent ASHE 8 & PV Code Section III Footnotes (h) 1 if
-ic Ic 10 if 2
if 2
if la,1f,1(
1 2
2 IELP/System,Ciass/System I0 Comments (1)
Yes 10 GE GE MA 6J)
MA B


Table 3.2-1 DABC Classification of Compoacats ia Systes Scope                                                                                           Equivalent                          110 Quality Quality of   Safesty                  Construction        Group Assurance  Seismic                    ASME Principal Component              Supply     Class    Code code            Class  Req.      Category PO Date  PO Dae    PY Code Section  III Footnotes (a)      (b)                        (c)                                                                                  Comments (d)                      (a)          (h)
Table 3.2-1 DABC Classification of Compoacats ia Systes Principal Component Scope of Supply (a)
(e)(f)                                            ()
S. Piping, other
S. Piping, other                             a      Other    2      ASME Section Ill, 1971    D          D            MA        12/19/72      -            1.,1b,11    Yes      10
: 9.
: 9. Nydraulic control unit                                             Edition G      2                                            Special    a
: 10.
: 10. Electrical modules, with safety           GE  - 2                                                                                                                    Yes function                                                                                   NA        I            I                                                Ye      10 I
: 11.
                                                                                                                                        -                          tc
V 1.
: 11. Cable, with safety function               g      2 V            Standby Liquid Control System C41                                                                 U
Nydraulic control unit Electrical modules, with safety function Cable, with safety function Standby Liquid Control System C41 Standby liquid control tank
: 1. Standby liquid control tank             GE      2          -    API-650 and ASNE Section                          I a                                              2                        Yes
: 2. Pump.
: 2. Pump.                                                             Vill, Div. 1                          I                                                                      10 G        2        2      ASNE Code for Pumps and    a Valves for Nuclear Power              I                                  2
: 3. Pump motor
: 3. Pump motor                               GE      2
: 4. Valves, explosive S. Valves, isolation and within
: 4. Valves, explosive                                                                             NA GE      2          2      ASNE Code for Pumps and    B          U S
: 6. Valves, beyond isolation valves
g      .
2            1f Valves for Nuclear Power S. Valves, isolation and within             I      1          1      ASNE Code for Pums and    A                      I        10/16/70      1            If Valves for Nuclear Power              5
: 6. Valves, beyond isolation valves         a      2          2      ASNE Code for Pumps and    a          1          I        10/16/70      2            if Valves for muclear Power
: 7. Piping, within isolation valves
: 7. Piping, within isolation valves
* 1          1      USAS 331.7-1969
: 8. Piping, beyond isolation valves
: 8. Piping, beyond isolation valves                                                               A                              07/30/70        1 9      2          2      USAS 331.7-1969            a          S          I                                    la,lb
: 9. Electrical modules, with safety function
: 9. Electrical modules, with safety         GE      2                                                      S          I      07/30/70      2            Ia, lb, Im function                                                                                             U          I                                  Ic                    10
: 10. Cable, with safety function VI Neutron onitoring System C51
: 10. Cable, with safety function             3      2 VI           Neutron onitoring System C51                                                                       5          I
: 1. Piping, TIP
: 1. Piping, TIP                             GE      2                                            NA
: 2. Valves, isolation, TIP subsystem
: 2. Valves, isolation, TIP subsystem         GE      2                                                      I            I                      2            la,1b
: 3. Electrical modules, IN and APAN
: 3. Electrical modules, IN and APAN         GE      2                                                      S          I                      2            if
: 4. Cable, IN and APRN VII Reactor Protection System C71
: 4. Cable, IN and APRN                       I      2                                                      S                                                ic, w        Yes VII           Reactor Protection System C71
: 1. Electrical modules
: 1. Electrical modules I
: 2. Cable Vi1 Process Radiation Monitors 011
U I
: 1. Electrical modules for main stem line, reactor building ventilation and offess stock monitors
110 GE      2                                                      S          I
: 2. Cable for main steam line, reactor building ventilation, and offgas stack monitors lX ANR System El
: 2. Cable                                   8        2                                          NA MA                                                        ic Vi1           Process Radiation Monitors 011                                                         MA
: 1. Neat exchangers, primary side
* I
: 2. Heat exchangers, secondary side
: 1. Electrical modules for main stem       GE      2 line, reactor building ventilation
: 3. Piping, within outermost LPCI &
* I      -                            Ic and offess stock monitors
shutdown cooling isolation valves
: 2. Cable for main steam line, reactor     I        2 building ventilation, and offgas                                                                     U stack monitors lX           ANR System El
: 4. Piping, other t,4 0 I'J~
: 1. Neat exchangers, primary side           GE      2        I      ASNE Section III, Class  8 a                    I      08/15/69        2 and TENA-C                            S
: 2. Heat exchangers, secondary side         GE      3                ASNE Section VIII, Div. 1, C and TEMA-C                            5          I      06/15/69        3
: 3. Piping, within outermost LPCI &         g        1        1      USAS 831.7-1969 shutdown cooling isolation valves                                                         A                    I      07/30/70        I U
: 4. Piping, other                                                                                                                                           1s, lb a      2          2      USAS 831.7-1969            I                    I      07/30/70        2            Is,Ib t,4 0                                                                                                             IELP/Systems,Class/systems I'J~
C.-,-
C.-,-
Safesty Class (b) a Other G
2 GE
- 2 g
Code Construction code (c) 2 ASME Section Ill, 1971 Edition Quality Quality Group Assurance Class Req.
(d)
D D
Special a
NA I
2 GE 2
G 2
GE 2
GE 2
I 1
a 2
1 9
2 GE 2
3 2
GE GE GE I
API-650 and ASNE Section Vill, Div. 1 2
ASNE Code for Pumps and Valves for Nuclear Power 2
1 2
1 2
ASNE Code for Pumps and Valves for Nuclear Power ASNE Code for Pums and Valves for Nuclear Power ASNE Code for Pumps and Valves for muclear Power USAS 331.7-1969 USAS 331.7-1969 2
2 2
2 GE 2
8 2
GE 2
I U
I I
U S
5 a
a NA B
A a
A a
NA I
NA MA MA 2
GE 2
I ASNE Section III, Class 8 and TENA-C GE 3
ASNE Section VIII, Div. 1, and TEMA-C g
1 1
USAS 831.7-1969 a
2 2
USAS 831.7-1969 Seismic Category (e)(f)
MA Equivalent ASME PO Dae PY Code PO Date Section III (a)
(h) 12/19/72 I
I 110 Footnotes 1.,1b,11 tc I
2 2
2 I
10/16/70 1
If Comments
()
Yes 10 Yes Ye 10 Yes 10 1f 1
I 10/16/70 2
S S
U 5
I S
S U
I I
I I
I I
I 07/30/70 07/30/70 1
2 2
2 S
I I
I U
S 5
U a
C A
I if la,lb Ia, lb, Im Ic la,1b if ic, w 10 Yes 1 10 ic Ic I
08/15/69 2
I 06/15/69 3
I 07/30/70 I
07/30/70 2
IELP/Systems,Class/systems 1s, lb Is, Ib g
I


Table DAEC Classification of Coaspoeats an Systems 1' 0(
Table DAEC Classification of Coaspoeats an Systems Principal Component
Equivalent Scope                                             Quality Quality                        ASME of Safety   Code        Construction          Group Assurance Seismic            B a PV Code Principal Component          Supply  Class  Class           Code              Class   Req. Category PO Date  section III Footnotes  Comments (a)    (b)                     (c)                        (d)      (*MCf)    (g)          (h)                (i)
: 5. Pumps
: 5. Pumps                                GE    2        2    Draft ASHE Code for Pumps   1          8        I      09/17/69    2        le and Valves for Nuclear Power or NDE and acceptance requirements of ANSI 831.1 Code Cases M7,N9.M10 +
: 6. Pump motors
: 7. Valves, isolation, LPCI & shutdoun cooling lines
: 8. Valves, isolation, other
: 9. Valves, beyond isolation'valves
: 10. Mechanical modules
: 11. Electrical modules, with safety function
: 12. Cable, with safety function Low Pressure Core Spray E21
: 1. Piping, within outermost isolation valves
: 2. Piping, beyond outermost isolation valves
: 3. Piping, floodup line to condensate storage tank
: 4. Pumps
: 5. Pump motors
: 6. Valves, isolation and within
: 7. Valves, beyond outermost isolation valves
: 8. Valves, floodup line to condensate storage tank
: 9. Electrical modules with safety function Scope of Supply (a)
GE GE I
Safety Code Class Class (b) 2 2
2 I
I 9
2 M
2 GE 2
GE 2
a 2
2 2
Construction Code (c)
Draft ASHE Code for Pumps and Valves for Nuclear Power or NDE and acceptance requirements of ANSI 831.1 Code Cases M7,N9.M10 +
Design Guide for sizing pressure parts in ASME lofler and Pressure Vessel Code (19681 Section Ill.
Design Guide for sizing pressure parts in ASME lofler and Pressure Vessel Code (19681 Section Ill.
Class C.                                       I
Class C.
: 6. Pump motors                          GE    2                                          NA        83                            -1
ASHE Code for Pumps and Valves for Nuclear Power ASNE Code for Pumps and Valves for Nuclear Power ASNE Code for Pumps and Valves for Nuclear Power Quality Quality Group Assurance Class Req.
: 7. Valves, isolation, LPCI & shutdoun  I    I        I    ASHE Code for Pumps and     A          8        I      10/16/70              If cooling lines                                          Valves for Nuclear Power                                           1
(d) 1 8
: 8. Valves, isolation, other            9    2        2    ASNE Code for Pumps and Valves for Nuclear Power I     10/16/70             If I 1
NA A
: 9. Valves, beyond isolation'valves      M    2        2    ASNE Code for Pumps and                        I      10/16/70     2       if Valves for Nuclear Power
MA 83 8
: 10. Mechanical modules                  GE    2                                                              I                           ic
Seismic Category
: 11. Electrical modules, with safety      GE    2                                          MA                  I                           ic function
(*MCf)
: 12. Cable, with safety function          a    2                                                              I Low Pressure Core Spray E21
I I
: 1. Piping, within outermost isolation  S    I        1    USAS B31.7-1969             A                  I      07/30/70    1        Ia, lb. In valves
I I
: 2. Piping, beyond outermost isolation  B    2        2   USAS 131.7-1969             I                  I      07/30/70    2        Ia,1b valves
I I
: 3. Piping, floodup line to condensate  8    Other         USAS B31.1.0               C                  I                            ta,lb storage tank
I PO Date (g) 09/17/69 10/16/70 10/16/70 10/16/70 Equivalent ASME B a PV Code section III Footnotes (h) 2 le
: 4. Pumps                                GE   2         2   Draft ASNE Code for Pumps   8          a        I      09/17/69    2        le and Valves for Nuclear Power or MDE and acceptance requirements of ANSI 531.1 Code Cases 17,19,110
-1 1
If If if ic ic I
I S
B 8
1 USAS B31.7-1969 2
2 USAS 131.7-1969 Other USAS B31.1.0 GE 2
2 Draft ASNE Code for Pumps and Valves for Nuclear Power or MDE and acceptance requirements of ANSI 531.1 Code Cases 17,19,110
* Design Guide for sizing pressure parts in ASNE Boiler and Pressure Vessel Code (1968) Section III, Class C.
* Design Guide for sizing pressure parts in ASNE Boiler and Pressure Vessel Code (1968) Section III, Class C.
: 5. Pump motors                        GE   2                                         NA        8        I
GE 2
: 6. Valves, isolation and within        S     1         1   ASHE Code for Pumps and     A          U        I 10/16/70              if Valves for Nuclear Power
S 1
: 7. Valves, beyond outermost isolation
2 M
* 2        2    ASHE Code for Pumps and     a          85      I 10/16/70    2        if valves                                                Valves for Nuclear Power
Other 1
: 8. Valves, floodup line to condensate  M    Other
ASHE Code for Pumps and Valves for Nuclear Power 2
* USAS B31.1.0               C         8       I                           If storage tank
ASHE Code for Pumps and Valves for Nuclear Power USAS B31.1.0 GE 2
: 9. Electrical modules with safety      GE    2                                         NA         BS      I                            ic function
A I
                                -4     aIELP/Systems,                                                                 Class/Systems
C 8
  *I.
a NA A
I to
a I
07/30/70 1
I 07/30/70 2
I I
09/17/69 2
8 U
85 8
BS C
NA 10/16/70 10/16/70 Ia, lb. In Ia,1b ta,lb le if if If ic 2
-4 aIELP/Systems, Class/Systems  
*I.
I to 1' 0 (
Comments (i)
I 10 2
I I
I I
I


Table 3.2-1 DABC Classifrcation of Compoacats in Systems Scope                                              Quality  Quality Equivalent                        110 of  Safety                                                                                ASE Code          Construction          Group Assurance  Seismic Principal Component             Supply  Class  Class                                                                      I & PV Code code            Class  Req.      Category PO Date    Section III    Footnotes (a)    (b)                                                                                                        Comments (c)                      (d)                  (e)          (h)
Table 3.2-1 DABC Classifrcation of Compoacats in Systems Principal Component
(*)f)                                        (I)
: 10. Cable, with safety function KI HPCI System E41
: 10. Cable, with safety function           8    2 KI       HPCI System E41
: 1. Piping, within outermost isolation valves
: 1. Piping, within outermost isolation S     I         1     USAS 331.7-1969                        I valves                                                                                 A                            07/30/70                la,lb
: 2. Piping, beyond outermost isolation valves
: 2. Piping, beyond outermost isolation                                                                 U                              1 8      2Ote    2      USAS 831.7-1969 valves                                                                                                               07/30/70    2
: 3. Piping, return test line to condensate storage tank beyond second isolation valve
: 3. Piping, return test line to               Other                                                  D3                                          lath 3                      USAS B31.1.0 condensate storage tank beyond                                                         0                      MA    07/30/70 la,1b,1r second isolation valve                                                                           0
: 4. Pumps.
: 4. Pumps.                               G    2         2     Draft ASHE Code for Pumps   a                     I    07/31/69      2 and Valves for Nuclear                                                           le Power or MOE and acceptance requirements of ANSI 831.1 Code Cases N7,M9,N10 +
Scope of Supply (a) 8 S
Design Guide for siting                 U pressure parts in ASHE Boiler and Pressure Vessel Code (19681 Section III, Class C.
8 3
: 5. Valves, isolation and within        a              I1    ASNE Code for Pumps and     A                     I      10/16/70    I          If Valves for Nuclear Power
G
: 6. Valves, return test line to          a    Other                                                 D USAS B31.1.0               0                     MA      10/16/70                If condensate storage beyond second isolation valve                                                                                  D0
: 5. Valves, isolation and within a
: 7. VacuumPump discharge tie to                Other     -    USAS 331.1.0               D                    NA (containment isolatio vas                                                                                                        -          IaIb
: 6. Valves, return test line to a
: 8. Valvs, otheror                            2        2    ASNE Code for Pumps and               8 a                    I      10/16/70    2 Valves for Nuclear Power               I
condensate storage beyond second isolation valve
: 9. Turbine                              BE    2
: 7. VacuumPump discharge tie to (containment isolatio vas
* NENA Standards for         NA                    I      07/29/69 Mechanical Drive Stem                                                                         Yes Turbine
: 8. Valvs, other or
: 10. Electrical modules, with safety      GE    2                                           KA function                                                                                                    I                              Ic
: 9. Turbine BE
: 11. Cable, with safety function          I    2 RCIC System ESI 1.Piping, within outermost isolation  I      1        I    USAS 831.7-1969                                   I A                            07/30/70     1 valves                                                                                                                                      asI b
: 10. Electrical modules, with safety GE function
: 2. Piping, beyond outermost isolation  0      2        2      USAS 831.7-1969            a valves                                                                                                              07/30/70    2         la,lb
: 11. Cable, with safety function I
: 3. Piping, return test line to        I     Other
RCIC System ESI
* USAS 831.1.0                D condensate storage tank beyond                                                                  0          MA     07/30/70               la. 1b,r second isolation valve IELP/SystemsClass/Systems
: 1. Piping, within outermost isolation I
valves
: 2. Piping, beyond outermost isolation 0
valves
: 3. Piping, return test line to I
condensate storage tank beyond second isolation valve Safety Class (b) 2 I
2Ote Other Code C lass 1
2 Construction code (c)
USAS 331.7-1969 USAS 831.7-1969 USAS B31.1.0 Quality Group Class A
0 2
2 Draft ASHE Code for Pumps a
and Valves for Nuclear Power or MOE and acceptance requirements of ANSI 831.1 Code Cases N7,M9,N10 +
Design Guide for siting pressure parts in ASHE Boiler and Pressure Vessel Code (19681 Section III, Class C.
I 1 ASNE Code for Pumps and A
Valves for Nuclear Power Other USAS B31.1.0 0
Other 2
2 2
2 1
2 Other USAS 331.1.0 2
ASNE Code for Pumps and Valves for Nuclear Power NENA Standards for Mechanical Drive Stem Turbine I
USAS 831.7-1969 2
USAS 831.7-1969 USAS 831.1.0 D
a NA KA A
a D
Quality Assurance Req.
(d)
I U
D3 0
U D
D0 8
I 0
Seismic Category
(*)f)
MA PO Date (e) 07/30/70 07/30/70 07/30/70 Equivalent ASE I & PV Code Section III (h) 1 2
I 07/31/69 2
I MA NA I
I I
I MA 10/16/70 10/16/70 10/16/70 07/29/69 07/30/70 07/30/70 07/30/70 I
Footnotes la,lb lath la,1b,1r le If If IaIb 2
Ic 1
2 as I b la,lb la. 1b,r IELP/SystemsClass/Systems 110 Comments (I)
Yes


Table 3W DABC Classificatiom of Composcats ia Syscn 110 Equivalent Scope                                           Quality Quality                            ASNE of Safety  Code        Construction          Group Assurance  Seismic              I & PV Code Principal Component                Supply   Class Class            Code              Class  Req. Category  PO Date    Section Ill Footnotes Comnents (a)     (b)                  (c)                        (d)      (e)(f)      (g)          (h)                (i)
Table 3W DABC Classificatiom of Composcats ia Syscn Scope of Supply (a)
: 4. Pumps                                   GE   2       2   Draft ASHE Code for PLs     6          B        I      -            2        le and Valves for Nuclear Power or MDE and acceptance requirements of ANSI 931.1 Code Cases M7,9,M10 +
GE Principal Component
: 4. Pumps
: 5. Valves, isolation and within
: 6. Valves, return test line to a
condensate storage beyond second isolation valve
: 7. Vacuu pump discharge It 6I contao nt aolation valves
: a. Valves at er a
: 9. Turbine GE
: 10. Electrical modules, with safety GE function
: 11. Cable, with safety function 8
ill Fuel Service Equipment Fit
: 1. Fuel preparation machine GE
: 2. General purpose grapple GE IV Reactor Vessel Service Equipment F13
: 1. Stem line plugs G
: 2. Dryer and separator sting and head GE strongback In-Vessel Service Equipment F14 1,.
Control rod grapple GE II Refueling Equipment FIS
: 1. Refueling equipment platform GE assembly II Storage Equipment F16
: 1. Fuel storage racks GE
: 2. Defective fuel storage container GE
%VIII RAedeste System G11
: 1. Tanks, Atmospheric GE
: 2. Heat exchangers G
Safety Code Class Class (b) 2 a
1 Other Other 2
2 2
2 Construction Code (c) 2 Draft ASHE Code for PLs and Valves for Nuclear Power or MDE and acceptance requirements of ANSI 931.1 Code Cases M7,9,M10 +
Design Guide for sizing pressure parts in ASNE Boiler and Pressure Vessel Code (19681 Section III, Class C.
Design Guide for sizing pressure parts in ASNE Boiler and Pressure Vessel Code (19681 Section III, Class C.
: 5. Valves, isolation and within            a    1        1   ASNE Code for Ptmps and     A
1 ASNE Code for Ptmps and Valves for Nuclear Power USAS 831.1.0 USAS 831.1.0 2
* I        10/16/70    1        if Valves for Nuclear Power
ASNE Code for Pumps and Valves for Nuclear Power NE1A Standards for Mechanical Drive Stem Turbine 3
: 6. Valves, return test line to            a    Other        USAS 831.1.0               D          D        NA      10/16/70    -        if condensate storage beyond second isolation valve
2 3
: 7. Vacuu pump discharge It                6I    Other    -    USAS 831.1.0               0          0        NA                    2 contao    nt aolation valves
2 2
: a. Valves at er                            a    2        2    ASNE Code for Pumps and     9          8        1        10/16/70    2        if Valves for Nuclear Power
2 2
: 9. Turbine                                GE    2            NE1A Standards for         NA        B        I      07/29/69              1i          Yes Mechanical Drive Stem Turbine
3 E/B Oth/Oth E/1 Oth/Oth API-650 or AWA-0100 or ANSI 096.1 or equivalent plus HDE per ASNE Section VIII Div. 1.
: 10. Electrical modules, with safety        GE    2                                        NA        B        I                              Ic function
Quality Quality Group Assurance Class Req.
: 11. Cable, with safety function            8    2                                                    B        I ill        Fuel Service Equipment Fit
(d) 6 B
: 1. Fuel preparation machine              GE    3                                         NA        S        I
A D
: 2. General purpose grapple                GE    2                                        MA
0 9
* I IV          Reactor Vessel Service Equipment F13
Seismic Category PO Date (e)(f)
: 1. Stem line plugs                        G  E  3                                         MA
(g)
* I
I I
: 2. Dryer and separator sting and head GE    E  2                                        MA
10/16/70 D
* I strongback In-Vessel Service Equipment F14 1,.Control rod grapple                    GE    2                                         WA        8 II        Refueling Equipment FIS                                                                                I
NA 10/16/70 0
: 1. Refueling equipment platform          GE    2                                         NA        U assembly II        Storage Equipment F16
NA 8
: 1. Fuel storage racks                    GE    2                                         NA        6
B B
: 2. Defective fuel storage container      GE    3                                                   6
B NA NA NA MA MA MA WA NA NA 1
%VIII        RAedeste System G11
10/16/70 I
: 1. Tanks, Atmospheric                    GEE/B Oth/Oth       API-650 or AWA-0100 or     CAD        D/D      MA/MA  07/16/70              1h          Yes    1 0 ANSI 096.1 or equivalent plus HDE per ASNE Section VIII Div. 1.
07/29/69 I
: 2. Heat exchangers                        G E/1 Oth/Oth                                  0/0       D/D       NA/NA   -
I Equivalent ASNE I & PV Code Section Ill Footnotes (h) 2 le 1
IELP/Systems,Class/Systems tAO I..-,.
if if 2
2 if 1i Ic S
I I
I I
8 U
6 6
CAD D/D 0/0 D/D tAO I..-,.
I MA/MA 07/16/70 1h NA/NA IELP/Systems,Class/Systems 110 Comnents (i)
Yes Yes 1 0 E
E


Table 3.2-1 DABC Clauification of Compoacals is Systems Scope                                                                                     Equivalent                        110 Quality  Quality                          ASME of   Safety   Code          Construction                Assurance Seismic Principal Component                                                                    Group                                I & PV Code Supply   Class  Class              Code              Class (a)     (b)                                                 Req. Category PO Date    Section III Footnotes    Comments (c)                      (d)      (*)(f)      (g)        (h)                  (0)
Table 3.2-1 DABC Clauification of Compoacals is Systems Principal Component
: 3. Piping and valves, containment        I      2         2      USAS 831.7-1969 isolation                                                                              g           g                            2 I                            la,th
: 3. Piping and valves, containment isolation
: 4. Piping, other                        a     Other     3     USAS 331.7-1969
: 4. Piping, other
: 5. Pums                                                                                    CAD          0          NA                          Is, lb.I GE   Other     3       ANSI 831.1.0 or ASNE Code CAD          0          MA 1,1Ij      Yes    I10 for Pumps and Valves for                                 07/03/72    -          I*'tI Nuclear Power, Class 3, or ASNE Section III, 1971 Edition, Class 3
: 5. Pums
: 6. Valves, flow control and filter      GE   Other     3     ASNE Code for Pumps and system                                                                                  CA0        D            MA Valves for Nuclear Power                                                         1f,1j
: 6. Valves, flow control and filter system
: 7. Valves, other                        I    Other     3     ANSI 831.1.0 or ASNE Code   CAD        0          MA for Pumps and Valves for                                                         if,1j Nuclear Power, Class 3, or ASHE Section III, 1971 Edition, Class 3
: 7. Valves, other
: 8. Nechanical modules                    GE   Other Reactor water Cleanup System G31                                                      CAD         D         MA                             1c,1j
: 8. Nechanical modules Reactor water Cleanup System G31
: 1. Vessels: filter/demineralher          GE   Other     C     ASNE Section III
: 1. Vessels: filter/demineralher
: 2. Heat exchangers                                                                          C          B                12/17/70    3          it GE   Other     -    ASNE Section Vill and       C I
: 2. Heat exchangers
TEKA-C                                 I          I 09/25/67    3          It
: 3. Piping, within outermost isolation valves
: 3. Piping, within outermost isolation    S    1         1     USAS B31.7-1969 valves                                                                                  A          a          I      07/30/70    1          la,1Ib
: 4. Piping, beyond outermost isolation valves
: 4. Piping, beyond outermost isolation    0    Other   3     USAS B31.7-1969 valves                                                                                  C          B        I      07/30/70    3          la,1b,lo,lt
: 5. Pumps
: 5. Pumps                                GE     Other   3     ANSI 831.1.0 or ASNE Code   C          a        I      12/23/69    3 for Pumps and Valves for                                                         le,1t Nuclear Power, Class 3, or ASNE Section III, 1971 Edition, Class 3
: 6. Valves, within isolation valves and
: 6. Valves, isolation valves and          a      1       1     ANSI 831.1.0 or ASNE Code   A          I          I                  1 within                                                      for Pumps and Valves for                                                         If Nuclear Power, Class 1, or ASNE Section Ill, 1971 Edition, Class 1
: 7. Valves, beyond outermost isolation valves
: 7. Valves, beyond outermost isolation    GE/I   Oth/Oth 3     ANSI 031.1.0 or ASNE Code valves                                                                                  C/C        0        1                    3        It11o, 1t for Pumps and Valves for Nuclear Power, Class 3, or ASHE Section Ill,   1971 Edition, Class 3
: 8. Nechanical modules (X
: 8. Nechanical modules                    GE     Other (X      Fuel Pool Cooling and Cleanup Systea 041                                                          S        I                             1c, It 1.Vessels, filter/demineralizers        GE    Other          ASNE Section VIII, Div. 1. C
Fuel Pool Cooling and Cleanup Syste
: 2. Vessels, other                                                                                                MA 8      Other          ASNE Section Vi1, Div. 1. C          0          NA
: 1. Vessels, filter/demineralizers
: 3. Heat exchangers                                                                                    D                              3 GE    Other          ASNE Section VIII, Div. 1, C                     NA     12/23/69 D                              3 and TEMA-C IELP/SystemsClass/Systems
: 2. Vessels, other
: 3. Heat exchangers Scope of Safety Supply Class (a)
(b)
I 2
Code Class Construction Code (c)
Quality Group Class 2
USAS 831.7-1969 g
a Other 3
USAS 331.7-1969 GE Other 3
ANSI 831.1.0 or ASNE Code for Pumps and Valves for Nuclear Power, Class 3, or ASNE Section III, 1971 Edition, Class 3 GE Other 3
ASNE Code for Pumps and Valves for Nuclear Power I
Other 3
ANSI 831.1.0 or ASNE Code for Pumps and Valves for Nuclear Power, Class 3, or ASHE Section III, 1971 Edition, Class 3 GE Other Quality Assurance Req.
(d) g Seismic Category
(*)(f)
I CAD 0
NA CAD 0
MA CA0 CAD PO Date (g) 07/03/72 D
MA 0
MA CAD D
MA GE Other C
ASNE Section III GE Other ASNE Section Vill and TEKA-C S
1 1
USAS B31.7-1969 0
Other 3
USAS B31.7-1969 GE Other 3
ANSI 831.1.0 or ASNE Code for Pumps and Valves for Nuclear Power, Class 3, or ASNE Section III, 1971 Edition, Class 3 a
1 1
ANSI 831.1.0 or ASNE Code for Pumps and Valves for Nuclear Power, Class 1, or ASNE Section Ill, 1971 Edition, Class 1 GE/I Oth/Oth 3
ANSI 031.1.0 or ASNE Code for Pumps and Valves for Nuclear Power, Class 3, or ASHE Section Ill, 1971 Edition, Class 3 GE a 041 GE 8
GE Other Other Other Other C
C A
C C
B I
a 12/17/70 3
09/25/67 3
I 07/30/70 1
B I
07/30/70 3
la,1b,lo,lt a
A I
12/23/69 3
le,1t I
I C/C 0
1 S
I ASNE Section VIII, Div. 1.
ASNE Section Vi1, Div. 1.
ASNE Section VIII, Div. 1, and TEMA-C C
C C
0 D
D MA NA NA 12/23/69 IELP/SystemsClass/Systems Equivalent ASME I & PV Code Section III (h) 2 110 Footnotes la,th Is, lb.I 1,1Ij I*'t I Comments (0)
Yes I10 1f,1j if,1j 1c,1j it It la,1Ib 1
3 If It 11o, 1t 1c, It 3
3 I
I


Table DABC Classificatiom of Compoacats Ia Systems                                                                   . 10 Equivalent Scope                                               Quality  Quality                            ASNE of     Safety   Code          Construction          Group  Assurance Seismic                B A PV Code Principal Component              Supply   Class  Class              Code              Class   Req.      Category PO Date      Section III Footnotes Comnents (s)       (b)                     (c)                        (d)        (e)(f)      (g)          (h)                (i)
Table DABC Classificatiom of Compoacats Ia Systems Principal Component
: 4. Pumps                                  GE     Other   3   ANSI 831.1.0 or ASNE Code     C          0          NA                    3 for Puape and Valves for Nuclear Power, Class 3, or ASHE Section Ill. 1971 Edition, Class 3
: 4. Pumps
: 5. Piping                                1      Other   3   USAS 831.7-1969               C          D          MA                              Ia
: 5. Piping
: 6. Valves                                A      Other   -    ANSI 831.1.0 or ASNE Code     CAD        D          MA                              if for Pumps and Valves for Nuclear Power, Class 3, or ASME Section III, 1971 Edition, Class 3 XXI         Control Room A Remote Shutdown PanetsNI   C61
: 6. Valves Scope of Safety Supply Class (s)
: 1. Electrical modules, with safety       GE     2                                           NA         8          I                              ic                  10 function
(b)
: 2. Cable, with safety function           8       2                                                     8          I xxil       Local Panels and Racks 121
Code Class Construction Code (c)
: 1. Electrical modutes, with safety       GE/1   2/2                                         8/         B/9        I/                            Ic function
GE Other 3
: 2. Cable, with safety function           3       2                                                     B          I                                                  10 XXIII       Offgas System M62                                         w
ANSI 831.1.0 or ASNE Code for Puape and Valves for Nuclear Power, Class 3, or ASHE Section Ill. 1971 Edition, Class 3 1
: 1. Tanks                                 GE     Other   -      00   r API-650                       D          MA      10/21/71              Ih
Other 3
: 2. Hest exchangers                       GE     Other               I   Ill &T                                   NA      11/20/72
USAS 831.7-1969 A
: 3. Piping                                 a       Other   3     ---                                              MA      07/27/72              1k D
Other ANSI 831.1.0 or ASNE Code for Pumps and Valves for Nuclear Power, Class 3, or ASME Section III, 1971 Edition, Class 3 Quality Quality Group Assurance Class Req.
D0
(d)
: 4. pumps                                         Other     *  -                  *9<aL.. -8           D0        NA                              le,1k
C 0
: 5. Valves, flow control                       B9 other         -D                                       D          MA      -    /                if,1k Oth                                                                                              If  I
C CAD XXI Control Room A Remote Shutdown PanetsNI C61
: 6. Valves, other Df9"        MA 11/29/71                IlfIV-      Ie      10
: 1. Electrical modules, with safety GE 2
: 8.       sure vessels                   GE     Other     *
NA function
* D          D          NA      10/21/71 XXIV       Emergency Service Uater E13
: 2. Cable, with safety function 8
: 1. Piping                               5       3       3   USAS 331.7                   D+QA                   I      07/30/70      3                    Yes      10
2 xxil Local Panels and Racks 121
: 2. Pumps                                 U       3       3   ASNE Code for Pumps and       D+0A                   I
: 1. Electrical modutes, with safety GE/1 2/2 8/
* 3        le Valves for Nuclear Power
function
: 3. Pump motors                           a      3
: 2. Cable, with safety function 3
* I      --
2 XXIII Offgas System M62 w
: 4. Valves                               B      3      .3    ASmE Code for Pumps and      O.OA
: 1. Tanks GE Other 00 r API-650
* I        10/16/70      3        if Valves for Nuclear Power Electrical modules, with safety       10      3                                                      6          I                              Ic function Cable, with safety function           3      3                                                      B          I RHR Service Water System E12 Piping                               a       3       3   USAS 831.7-1969               C          6          I      07/30/70      3        1p                  -1 Pumps                                  B     3       3   ANSI 631.1.0 or ASNE Code     C          B          I                      3        le for Pumps and Valves for Nuclear Power, Class 3, or ASHE Section 1I, 1971 Edition, Class 3
: 2. Hest exchangers GE Other I
: 3. Pump motors                          a      3                                                     a         I IELP/Systems, Class/Systems
Ill &T
* I
: 3. Piping a
Other 3
: 4. pumps Other  
*9<aL.. -8
: 5. Valves, flow control B9 other  
-D
: 6. Valves, other Oth
: 8.
sure vessels GE Other D
XXIV Emergency Service Uater E13
: 1. Piping 5
3 3
USAS 331.7 D+QA
: 2. Pumps U
3 3
ASNE Code for Pumps and D+0A Valves for Nuclear Power
: 3. Pump motors
: 4. Valves Electrical modules, with safety function Cable, with safety function RHR Service Water System E12 Piping Pumps
: 3. Pump motors a
3 B
3
.3 10 3
3 3
a 3
3 USAS 831.7-1969 B
3 3
ANSI 631.1.0 or ASNE Code for Pumps and Valves for Nuclear Power, Class 3, or ASHE Section 1I, 1971 Edition, Class 3 a
3 C
C ASmE Code for Pumps and Valves for Nuclear Power O.OA Seismic Category (e)(f)
NA PO Date (g)
Equivalent ASNE B A PV Code Section III (h) 3 D
MA D
MA 8
I 8
I B/9 Footnotes
. 10 Comnents (i)
Ia if ic Ic B
D D
D0 D0 D
Df9" MA 10/21/71 NA 11/20/72 MA 07/27/72 NA MA
/
MA 11/29/71 Ih 1k le,1k if,1k If I IlfIV-D NA 10/21/71 I
07/30/70 3
I 3
le I
I 10/16/70 3
if 6
I I/
10 Ie 10 Yes 10 Ic B
I 6
I B
I 07/30/70 3
1p 3
le a
I I
ELP/Systems, Class/Systems I
10
-1 I


Table 3.2-1 DABC Classification of Compoaeats la Systems Equivalent                        ) 10 Scope                                                Quality Quality                              ASME of    Safety    Code        Construction          Group Assurance Seismic                I & PV Code Principal Component             Supply    Class  Class                Code            Class  Req. Category PO Date      Section III  Footnotes Comments (b)                        (c)                    (d)          (e)(f)                (h)
Table 3.2-1 DABC Classification of Compoaeats la Systems Principal Component
Ca)                                                                                  (g)0                              Mi)
: 4. Valves
: 4. Valves                                     3          3    ASHE Code for Pumps and    C            I 8                      Valves for Nuclear Power I        10/16/70    3        if,1p
: 5. Electrical modales, with safety function
: 5. Electrical modales, with safety             3 function
: 6. Cable, with safety function XVI RBCCU P42
* I                                Ic
: 1. Piping, and valves forming part of primary containment boundary.
: 6. Cable, with safety function         S ,    3 XVI     RBCCU P42
: 2.
* I
: 3.
: 1. Piping, and valves forming part of I      2        8    ASHE Nuclear Vessels Code  I          1        I        07/30/70      2                            I 10 primary containment boundary .                             Section III, Extension of Contairment Code Cases 1425, 1426 & 1427
XVII 1.
: 2. Piping and valves inside drywell   a      Other
Piping and valves inside drywell Piping and valves, other Ueit Mater System P46 Piping and valves forming part of primary containment boundary
* USAS  831.1.0              0            B        I
: 2. Piping and valves inside drywell
: 3. Piping and valves, other           8      Other      -                                                                                      Is D          U          I                              Is XVII    Ueit Mater System P46
: 3. Piping and valves, other KVIII Pneumatic Systems
: 1. Piping and valves forming part of   B      2
: 1. Nitrogen vessels, accumiulators, supporting safety-related system
* ASNE Nuclear Vessels Code, I                                                                          I primary containment boundary                                                                       I                                                                10 Section III, Extension of Contairment Code Cases 1425, 1426 & 1427
: 2. Nitrogen piping and valves in lines between above accumulators and safety-related systems
: 2. Piping and valves inside drywell   a      Other
: 3. Nitrogen piping and valves forming part of containment boundary
* USAS 131.1.0              D
: 4. Instrument air vessels, accumulators, supporting safety-related systems S. Instrument air piping and valves in lines between above accumulators and safety-related system XIX Diesel Generator Systems R43
: 3. Piping and valves, other
* I a      Other    -    USAS 831.1.0              0            -        NA                              .s KVIII   Pneumatic Systems                   T48 P50
: 1. Nitrogen vessels, accumiulators,   8        2        2    ASHE Section III                      I          I        02/26/73 supporting safety-related system
: 2. Nitrogen piping and valves in     U        2        2    ASHE Section III lines between above accumulators and safety-related systems                                                                                                                                           10
: 3. Nitrogen piping and valves forming 8        2        2    ASHE Section III                                I part of containment boundary                                                                                                                 lb
: 4. Instrument air vessels,           a        3 accumulators, supporting
* I        02/26/73 safety-related systems S. Instrument air piping and valves   0        3                                                      a in lines between above accumulators and safety-related system XIX     Diesel Generator Systems R43
: 1. Day tanks
: 1. Day tanks
* 3         -    API-650 or AuuA-DiOO or   C          I                                                                10 ANSI 96.1 or equivalent                                                                               I plus MDE per ASNE Section VIII, Div. 1.
: 2. Piping and valves, fuel oil system and diesel service water system
: 2. Piping and valves, fuel oil system 0       3         3     USAS 131.7 for pipe and   C          8 and diesel service water system                            ASME Code for Pumps and Valves for Nuclear Power
: 3. Pumps, fuel oil system and dies*
: 3. Pumps, fuel oil system and dies*  a        3         3    ASNE Code for Pumqs and   C          I        1 service water system                                        Valves for Nuclear Power
service water system
: 4. Pump motors, fuel oil system and
: 4. Pump motors, fuel oil system and diesel service water system
* 3        *
: 5. Diesel-generators Scope of Supply Ca) 8 Safety Class (b) 3 3
* diesel service water system
Code Class 3
* I
Construction Code (c)
: 5. Diesel-generators                  a       2 a        i IELP/Systems,Class/Systems
ASHE Code for Pumps and Valves for Nuclear Power Quality Quality Group Assurance Class Req.
(d)
C I
I 0
D I
D 0
Seismic Category (e)(f)
I PO Date (g)0 10/16/70 I
I S,
3 I
a 2
8 ASHE Nuclear Vessels Code Section III, Extension of Contairment Code Cases 1425, 1426 & 1427 Other USAS 831.1.0 8
Other B
2 a
Other a
Other T48 P50 8
2 ASNE Nuclear Vessels Code, Section III, Extension of Contairment Code Cases 1425, 1426 & 1427 USAS 131.1.0 USAS 831.1.0 2
ASHE Section III 2
2 ASHE Section III U
8 2
2 ASHE Section III a
3 0
3 Equivalent ASME I & PV Code Section III Footnotes (h) 3 if,1p
) 10 Comments Mi)
Ic 1
I 07/30/70 2
B U
I I
I Is Is I
NA I
I 02/26/73 I
I 02/26/73
.s lb a
3 API-650 or AuuA-DiOO or ANSI 96.1 or equivalent plus MDE per ASNE Section VIII, Div. 1.
0 3
3 USAS 131.7 for pipe and ASME Code for Pumps and Valves for Nuclear Power a
3 3
ASNE Code for Pumqs and Valves for Nuclear Power 3
a 2
C C
C I
8 10 10 10 10 I
1 I
a i
IELP/Systems,Class/Systems I
I I


Table 3A DABC Classificatiom of Composents in Systess                                                               :1 Equivalent Scope                                              Quality  Quality                          ASME of    Safety    Code        Construction          Group Assurance  Seismic            a & PV Code Principal Component               Supply    Class  Class              Code            Class  Req.      Category  PO Date  Section III  Footnotes Comments (a)      (b)                      (c)                    (d)        *)C(f)    (U)          (h)                  Ci)
Table 3A DABC Classificatiom of Composents in Systess Principal Component
: 6. Electrical modules with safety                   3                                                    B          I                        *ic function
: 6. Electrical modules with safety function
: 7. Cable, with safety function                     3
: 7. Cable, with safety function
: 8. Diesel fuel storage tanks                       Other         API-650 or AWA-D100 or     C          U ANSI 896.1 or equivalent plus NOE per ASNE Section             S VIII, Div. 1.
: 8. Diesel fuel storage tanks
: 9. Diesel Air Start System                          2 xxx          Containment Atmosphere Control System T48
: 9. Diesel Air Start System xxx Containment Atmosphere Control
: 1. Piping and valves from primary          a       2        a    ASHE Nuclear Vessels Code I          B          1      07/30/70    -
: 1. Piping and valves from primary containment through outer isolation valve Scope of Supply (a)
containment through outer                                    Section III. Extension of isolation valve                                              Code Cases 1425, 1426 and 1427 XXXI         Standby Gas Treatment System T46
System T48 a
* I functi PJZrf,~                                         fa XXXI I       ECC SEqiihren AiCool11tam~
Safety Code Class Class (b) 3 3
: 1. All comonents with safety functions a       3
Other 2
* I      -
2 Construction Code (c)
Ye XXXIII       Power Conversion System               Nit M21
API-650 or AWA-D100 or ANSI 896.1 or equivalent plus NOE per ASNE Section VIII, Div. 1.
: 1. Main stem piping from outboard           a       Other         USAS 131 .1.0              D+QA
a ASHE Nuclear Vessels Code Section III. Extension of Code Cases 1425, 1426 and 1427 XXXI Standby Gas Treatment System T46 functi PJZrf,~
* I      07/30/70                Is          Yes NSIV to turbine stop valves and branch tine piping up to and including first valve
fa XXXI I ECC SEqiihren AiCool11tam~
: 2. Stem piping and valves, other           I       Other     -    USAS 831 .1.0              D+0A        -        NA      07/30/70                Ia
: 1. All comonents with safety a
: 3. Reactor feedwater piping and             M       1         1   USAS 931 .7-1969          A                                          -
3 functions XXXIII Power Conversion System Nit M21
0          I      07/30/70                la,lb,if valves, RPV to outermost isolation valve
: 1. Main stem piping from outboard a
: 4. Reactor feedwater piping and             I       Other     -    USAS 931 '1.0              O+QA                NA      07/30/70                la,1f      Yes valves, other XXXIV     ' Condensate Storage and Transfer System P11
Other USAS 131 NSIV to turbine stop valves and branch tine piping up to and including first valve
: 1. Condensate store"     tank               U       Other     -    API-650 plus augmented MDE D+QA                  NA    07/30/70                li          YesI of welds
: 2. Stem piping and valves, other I
: 2. Piping and valves                               Other          USAS 331.1.0              0          O        NA                              1f.Iq
Other USAS 831
: 3. Other components                                 Other                                    D          0        MA                              Iq xxxV         Essential a-c Power System   120 -24 R35 R43
: 3. Reactor fee dwater piping and M
: 1. All components with safety               1      2                                                    a          I function XXXVI       125/250 Volt d-c Power system R42
1 1
: 1. All components with safety               8      2                                                    a        I function XXXVII       River Water Supply 1110                                                                                                                                         1
USAS 931 valves, RPV to outermost isolation valve
: 1. Piping, pumps and valves                 B      3              ANSI 831.1.0
: 4. Reactor feedwater piping and I
* I                              If
Other USAS 931 valves, other XXXIV  
: 2. Intake traveling screen, trash           8      3                                                    I        I      -
' Condensate Storage and Transfer System P11
rakes
: 1. Condensate store" tank U
: 3. Pump motors                             1      3                                                    B        I XXXVIII MSIV Leakage Control 321 IELP/Systems,Class/Systems I.-
Other API-650
: 2. Piping and valves
: 3. Other components xxxV Essential a-c Power System 120
: 1. All components with safety function XXXVI 125/250 Volt d-c Power system R42
: 1. All components with safety function XXXVII River Water Supply 1110
: 1. Piping, pumps and valves
: 2. Intake traveling screen, trash rakes
: 3. Pump motors XXXVIII MSIV Leakage Control 321
-24 1
Other Other R35 R43 2
8 2
B 3
8 3
1 3
Quality Quality Group Assurance Class Req.
(d)
B C
I U
S Seismic Category
*)C(f)
I PO Date (U)
Equivalent ASME a & PV Code Section III Footnotes (h)
*ic B
1 07/30/70 I
I
.1.0
.1.0
.7-1969
'1.0 plus augmented MDE of welds USAS 331.1.0 D+QA D+0A A
O+QA D+QA 0
D I
07/30/70 NA 07/30/70 0
I 07/30/70 NA 07/30/70 NA 07/30/70 O
NA 0
MA a
ANSI 831.1.0 a
I I
I I
B I
IELP/Systems,Class/Systems I.-
: 1 Comments Ci)
Is Ia la,lb,if Ye Yes Yes YesI la,1f li 1f.Iq Iq If I
1


Table 3.2-1 DAEC Classification of CoaspoScats in Systcas Scope                                                                                Equivalent Quality  QualitY                          ASME of  Safety  Code        Construction        Group Assurance Principal Component             Su ply  Class Class                                                                    e& PV Code Code            Class  Req. Category PO Date    Section III Footnotes Comments (b)                  (c)                      (d)      (*)(f)                  (h) a)                                                                            (g)
Table 3.2-1 DAEC Classification of CoaspoScats in Systcas Principal Component
: 1. Piping and valves up to the first       I        1    ANSI 031.7                                                                                - )
: 1. Piping and valves up to the first isolation valve of the Inboard sbsystem
A          0 isolation valve of the Inboard                                                                         I                            la,1b,1f sbsystem
: 2. Piping and valves, other
: 2. Piping and valves, other           g    2        2    ASE Section
: 3. Blowers KMIX NVAC
: 3. Blowers                                                                       C/
: 1. Control room
GE    2                                                                                  -        ta.1b~1f KMIX     NVAC                                                                           B          B
: 2. Pump house
: 1. Control room                                                                                         I        .
: 3. Emergency diesel generator room
: 2. Pump house 3                                                  gI        I
: 4. Reactor building secondary containment isolation dampers
: 3. Emergency diesel generator room 3
: 5. Battery rooms
: 4. Reactor building secondary 3
: 6. Intake structure
containment isolation dampers 3                                                            1
: 7. Essential suitchgear rooms XXX Nacellaneous Components
: 5. Battery rooms                           3
: 1. Reactor Building Crane
: 6. Intake structure                         3                                                  I
: 2. Containment Penetrations for Process Piping and Electrical Scope of Su ply a)
: 7. Essential suitchgear rooms               3                                                  U        I      -
Safety Class (b)
XXX     Nacellaneous Components                                                                 3
I g
: 1. Reactor Building Crane           a      3
2 GE 2
: 2. Containment Penetrations for     a     2
Code Class Construction Code (c)
* 1 B         I Process Piping and Electrical IELP/Systems,Class/Systems 10
Quality Group Class 1
ANSI 031.7 A
2 ASE Section C /
B 3
3 3
3 3 3 3
QualitY Assurance Req.
(d) 0 B
gI I
U 3
a 3
a 2
Category PO Date
(*)(f)
(g)
I I
I 1
I Equivalent ASME e & PV Code Section III (h)
Footnotes la,1b,1f ta.1b~1f 1
B I
IELP/Systems,Class/Systems Comments
- )
10


Table 39 DAEC Classification of Compoacats in Systems Footnotes FootO FootNote Systems a GE a General Electric; B a Bechtel; C - CBIl; IE - Iowa Electric Light & Power Co.
Table 39 DAEC Classification of Compoacats in Systems Footnotes Systems FootO FootNote a GE a General Electric; B a Bechtel; C - CBIl; IE - Iowa Electric Light & Power Co.
b         1, 2, 3, "other" - safety classes defined inSection 3.2.4; Ounc" - unclassified as defined in Section 3.2.4.
b 1, 2, 3, "other" - safety classes defined in Section 3.2.4; Ounc" - unclassified as defined in Section 3.2.4.
c         The equipment shall be constructed in accordance with the codes listed in Table 3.2-2. if no Code of Construction isprovided In this table. The term "construction", as used in this UFSAR, .includes provisions for design, materials, fabrication, erection, testing and inspection.
c The equipment shall be constructed in accordance with the codes listed in Table 3.2-2. if no Code of Construction is provided In this table. The term "construction", as used in this UFSAR,.includes provisions for design, materials, fabrication, erection, testing and inspection.
d       6
d 6
* The equipment shall meet the quality assurance requirements of 10CFR50, Appendix 8, in accordance with the quality assurance program described inChapter 17. D a The equipment shall be constructed inaccordance with the quality assurance requirements consistent with good practice for stem power plants.
* The equipment shall meet the quality assurance requirements of 10CFR50, Appendix 8, in accordance with the quality assurance program described in Chapter 17.
e       I
D a The equipment shall be constructed in accordance with the quality assurance requirements consistent with good practice for stem power plants.
* The equipment shall be constructed in accordance with the seismic r i                                             to for the safe shutdoun earthqua ke as de c                         n Section 3.7, Seismic Design.                 The Incus             o system orstructure within Seismic Category                             a not mean to ent re system or structure is Seismic Category I but rather th                   the system or structure has been evaluated                           those portions         that lie eitin an defnhition                     of Se     Ctegor             e               r at h aThisced and isor ed for sismic respoe                   Na       gie e rei                 s       fo         apply forts dn               atdin Code             Css       sall be uie           passin th a           toms Contion s       afeogu a q ita re s                   cte         1.
e I
ADate n th pucoder fo there isimc oen etregrvided                                     th     can b te ued tof         Tab sma)t s noedition and                               anda       llectwforhthe cor       mof       hen eator c             a-h bTiscoaum sh for Saforty o lass . TeC ode iassn inerei                                               a which         oulnct d oapply-?         X SfeyCa2fo the urn dt oute                 iSltionI vale torb sda the c suoff valvetrotn valet                                         XVI coundrthe Codelasressue sensing        seading insrodetlass fooingtremstareon  im solation     Appilisrhalieuse the instrment         whic deermineted smlins                       atoa(3/otContrcto                        7, 11-8, 11-13, 11-4, III-1, IV-4, IV-8, V-7, V-8, y ofshm thaGrAc~fpotain  fna thee assotd:ic oumn anoetces        ins the oflnowncseic    sysmtr ther      is IEC a whichhcess    are thoug shutoff      the thne at asrQualit  except (root      r tovalv ale)      tosalldb lcooline att Te bon Se       gur ha.saet Class 2 vavegrthe lires  classiie instrumentlines eod thhi are ros ve 0obeondith            ied to to 3, IX-4, X-1, X-3, X-2, XI-3, MI-I, XI-7, XI-2, I-2, MIl-I, XII-3, XVIII-4, XVIII-3, XIX-4, XIX-3, S                                                                                                                                               111-3, XXXIII-I, XXXIII-4, XXXIII-2, XXXVIll-2, afety             sCl sse fsr thor sation The aCe             lasseon           hess s toal which tohey ale ttahed. istr u er inst                       tunt       li nes             hbend a rte Cone t ed t               o at uat e coan sdstpem, eaon                   and ano shall be td aae esfre o the ual eisuation s"ensIn aited soafey stshall    (n)Gvalve asisoumninfe    or the Adbesoer.ins    process
* The equipment shall be constructed in accordance with the seismic r i
                                                *()tther Quet Casit Grou 3/     Istrucoment D* N *(2)Al nd t t I sme rerinthog  shutoffevarveh(rootmvaee) hIe lines fromh  the      room t vahe thesh oorigyt ale sa te    ar t f ot eto ctate-, IX te ounete isoation1-7 vacveor thean pressroo vavbhou                     gh thanae remainede tof athae sapein             system shall be                   X5       X lb    Qualty A ensin thbIEV.      oai 31.Cod coige    anecs0.wcekvle(FV rCaent 78app ase-2.          il fof other appliabe        rum1.7                   lassradCase2cpipecand lasfe d ppesQaiyGopDbyn Instrumentd ls s hc             bon          and ftotng f      g 3/4"  noo vanae 3/4acomia           h u I-,
to for the safe shutdoun earthqua ke as de c n Section 3.7, Seismic Design.
piltpe sz             e     ndar anmall r o tlzdt                           cut         aeyssessalb                             ult Xll-,   XI XXXIII-1, lI-7 7,         1- 1 -1,11-4, III-1, IV-8, V-7, V-8, VI-1, 1 10 3, X- , X-3, X-2, XI-3,     I-1, XI-2, I-7, XII-2, 3
The Incus o
I-1,AXVIII- , XVIII-4, XIX-3, XIX-4, XXVIII-3, XXXVIII-2, XXXVIII-I, IELP/Footnote/Footnote I-~
system or structure within Seismic Category a not mean to ent re system or structure is Seismic Category I but rather th the system or structure has been evaluated those portions that lie eitin an defnhition of Se Ctegor e
r at h aThisced and isor ed for sismic respoe Na gie e rei s
fo apply forts dn atdin Code Css sall be uie passin th a toms Contion s
afeogu a q it a re s cte
: 1.
ADate n th pucoder fo there isimc oen etregrvided th can b te ued tof Tab sma)t s noedition and anda llectwforhthe cor mof hen eator c a-h bTiscoaum sh for Saforty o lass.
TeC ode iassn inerei a which oulnct d oapply-?
X SfeyCa2fo the urn dt oute iSltionI vale torb sda the c suoff valvetrotn valet XVI coundrthe seading insrodetlass isrhalieuse whic deermineted atoa Contrcto Codelasressue im l at GrA y fn the oumn solation ther is a cess shutoff the (root ale) to t Te sensing fooingtremstareon Appil the instrment smlins thoug thne (3/ot valv salldb ofshm a e assotd:ic ins the sysmtr whichh are at except r to cooline tha c~fpotain anoetces oflnowncseic vavegr IEC lires classiie asrQualit ros 0obeondith bon Se gur ha.saet Class 2 the instrument lines eod thhi are ve ied to to S
afety sCl sse fsr thor sation The aCe lasseon hess s toal which tohey ale ttahed. istr u er inst tunt li nes hbend a rte Cone t ed t o at uat e coan sdstpem, eaon and ano shall be td aae esfre o the ual e isuation Gvalve or the process shutoffevarveh(rootmvaee) the origyt sa te s"ensIn isoumninfe
*()tther Istrucoment rerinthog the room t vahe sh o ale Qualty c oai anecs0.wcekvle(FV r
lasfe sQaiyGopDbyn h
lb IEV. oige ase-2. appliabe f other Instrumentd lass bon d ppe and f g 3/4" noo vanae I-,
u aited as (n)
Ad soer.ins 3/ N nd t t hIe ar t f ot eto ctate-, IX soafey stshall be Quet Casit Grou D*
*(2)Al I sme lines fromh te ounete isoation1-7 vacveor thean pressroo vavbhou gh thanae remainede tof athae sapein system shall be X5 X
thb A ensin 31.Cod rCaent 78app il fo rum1.7 ls s hc adCase2cpipecand ftotng 3/4acomia piltpe sz e
ndar anmall r o tlzdt cut aeyssessalb ult Xll-, XI XXXIII-1, I-~
7, 11-8, 11-13, 11-4, III-1, IV-4, IV-8, V-7, V-8, 3, IX-4, X-1, X-3, X-2, XI-3, MI-I, XI-7, XI-2, I-2, MIl-I, XII-3, XVIII-4, XVIII-3, XIX-4, XIX-3, 111-3, XXXIII-I, XXXIII-4, XXXIII-2, XXXVIll-2, lI-7 7,
1-1 -1,11-4, III-1, IV-8, V-7, V-8, VI-1, 3, X-, X-3, X-2, XI-3, I-1, XI-2, I-7, XII-2, I-1,AXVIII-3, XVIII-4, XIX-3, XIX-4, XXVIII-3, XXXVIII-2, XXXVIII-I, IELP/Footnote/Footnote 1 10


Table 3.2-1 DAEC Classification of Compoaents in Systems Footnotes Foot# FootNote                                                                                         Systems 1c   A module is an assembly of interconnected components which constitute an identifiable           11-14, 11-15, Ill-7, IV-10, V-9, VI-3, VII-1, VIII-1, Ix-10, device or piece of equipment. For example, electrical modules include sensors, power             IX-11, X-9, xi-i0,-Xii-10, XVIII-8, XIX-8, XXI-1, XXII-I, supplies, and signal processors. Mechanical modules include turbines, strainers, and             XXIII-7, XXIV-5, XXV-S,XxXlx-6, orifices.
Table 3.2-1 DAEC Classification of Compoaents in Systems Footnotes Foot#
id   GE Specification 21AII00AS (Ref. 243) adds the following code requirements to the Reactor       1-1, 1-2, 1-3, 1-5, 1-9, Vessel: The Winter 1967 Addenda to the ASHE Code Section III is not to be included as a basis for purchase of this vessel, except as follows: 1)charpy impact tests per N-331.2 of the Winter 1967 Addenda will be furnished; 2)Welds are to be ultrasonically examined using the angle beam method described by I-62S of Minter 1967 Addenda; 3)The changes to Article 4-Design by the Winter 1967 Addenda are included; 4)The addition of Appendix IX-Quality Control and Nondestructive Examination Methods is included.
FootNote Systems 1c A module is an assembly of interconnected components which constitute an identifiable 11-14, 11-15, Ill-7, IV-10, V-9, VI-3, VII-1, VIII-1, Ix-10, device or piece of equipment. For example, electrical modules include sensors, power IX-11, X-9, xi-i0,-Xii-10, XVIII-8, XIX-8, XXI-1, XXII-I, supplies, and signal processors. Mechanical modules include turbines, strainers, and XXIII-7, XXIV-5, XXV-S,XxXlx-6, orifices.
to   For pump designs, the applicable class, section, or subsection of the referenced ASME BAPV       111-4, V-2, IX-5, X-4, X1-4, Xil-4, XVIll-5, xix-5, XXiII-4, Cqde is used as a guide in calculating the thickness of pressure-retaining portions of the     XXIV-2, XXV-2, pump and in sizing cover bolting. For example, use ASHE Section III, Class C, 1968 Edition, for a design guide for Quality Group A & B pumps. For Quality Group 0 below 150 psig and/or 212 deg. F, manufacturer$s standard pump for service intended may be used.
id GE Specification 21AII00AS (Ref. 243) adds the following code requirements to the Reactor 1-1, 1-2, 1-3, 1-5, 1-9, Vessel: The Winter 1967 Addenda to the ASHE Code Section III is not to be included as a basis for purchase of this vessel, except as follows: 1)charpy impact tests per N-331.2 of the Winter 1967 Addenda will be furnished; 2)Welds are to be ultrasonically examined using the angle beam method described by I-62S of Minter 1967 Addenda; 3)The changes to Article 4-Design by the Winter 1967 Addenda are included; 4)The addition of Appendix IX-Quality Control and Nondestructive Examination Methods is included.
if   ANSI 816.5 or NSS-SP-66 apply for valves [Note NSS-SP-66-1964 was withdrawn from                 11-9, 11-10, 11-11, 11-12, 11-13, 111-5, IV-1, IV-2, IV-3, lication in favor of ANSI 016.34-19731.                                                     IV4, V.4, V-5, V.6, VI-2, IX-8, lX-9, lX-7, X-7, X-6, X-8, ar/,,,e     are                                                     I-5, xl-6, xI-8, XII-5, xll-6, X1l-8, xVIII-6, XVIll-7, XIN-6, MIX-7, xx-6, XMIll-6, XXIll-5, xxIV-4, xxV-4, xxxill-3, anoth'MXXIll-4,                                                         xxxiv-2, EXXVII-1, xxxVIII-1, xxxvill-2, 1g   The RCICturbi           aonot fall within the applicable design codes. To assure that the (27     11-9, fabicated to the standards commensurate with their safety and performance requirements, General Electric has established specific design requirements for           use, componetU; th   ExistingAPI/AWA standards and supplementary requirments apply. Tanks are to be                 XVIII-i, XXIII-1, constructed to meet the Intent of API Standards 620 or 650 or AWA Standard 0100 for those fuel, oil, or water storage tanks.
to For pump designs, the applicable class, section, or subsection of the referenced ASME BAPV 111-4, V-2, IX-5, X-4, X1-4, Xil-4, XVIll-5, xix-5, XXiII-4, Cqde is used as a guide in calculating the thickness of pressure-retaining portions of the XXIV-2, XXV-2, pump and in sizing cover bolting. For example, use ASHE Section III, Class C, 1968 Edition, for a design guide for Quality Group A & B pumps. For Quality Group 0 below 150 psig and/or 212 deg. F, manufacturer$s standard pump for service intended may be used.
1i   The condensate storage tank will be designed, fabricated and tested to meet the intent of       XXXIV-1, API Standard 650. Inaddition, the specifications for this tank will require 100% surface examination of the side wall to bottom joint and 100% volumetric examination of the side wall weld joints.
if ANSI 816.5 or NSS-SP-66 apply for valves [Note NSS-SP-66-1964 was withdrawn from 11-9, 11-10, 11-11, 11-12, 11-13, 111-5, IV-1, IV-2, IV-3, lication in favor of ANSI 016.34-19731.
1i   ASNE Section VIII, Division 1, and USAS 831.1.0 apply downstream of the outermost isolation     XVIll-4, XVill-5, XViII-6, XVIII-7, XVIII-8, valves.
IV4, V.4, V-5, V.6, VI-2, IX-8, lX-9, lX-7, X-7, X-6, X-8, ar/,,,e are I-5, xl-6, xI-8, XII-5, xll-6, X1l-8, xVIII-6, XVIll-7, XIN-6, MIX-7, xx-6, XMIll-6, XXIll-5, xxIV-4, xxV-4, xxxill-3, anoth'MXXIll-4, xxxiv-2, EXXVII-1, xxxVIII-1, xxxvill-2, 1g The RCICturbi aonot fall within the applicable design codes. To assure that the (27 11-9, fabicated to the standards commensurate with their safety and performance requirements, General Electric has established specific design requirements for
1k   The gaseous raduaste system piping, pumps and valves containing gaseous radwaste shall be       XXIII-3, XXIll-4, XXIII-5, XXIII-6, constructed in accordance with the applicable codes of Quality Group D.
: use, componetU; th ExistingAPI/AWA standards and supplementary requirments apply. Tanks are to be XVIII-i, XXIII-1, constructed to meet the Intent of API Standards 620 or 650 or AWA Standard 0100 for those fuel, oil, or water storage tanks.
11   Some of this piping was also constructed to 831.1.0                                             IV-4, IV-8, im   Some lines, such as ECB-9 (drain to filter/demineralizer), are class 3, non-seismic.           V-8, in   This system includes reactor head spray.                                                       X-1, to   Lines DC8-1 and DC8-2 are nuclear class 3, according to Bechtel Specification N-190.           XIX-4, XIX-7, ip   The RNRSU backwash line (GBD-62 and GBO-63) isnon-seismic, according to Bechtel                 XXV-1, XXV-4, Specification M-190, Sheet 23A.
1i The condensate storage tank will be designed, fabricated and tested to meet the intent of XXXIV-1, API Standard 650. In addition, the specifications for this tank will require 100% surface examination of the side wall to bottom joint and 100% volumetric examination of the side wall weld joints.
Iq   Portions of this system which supply suction for HPCI, RCIC, and Core Spray from the           XXXIV-2, XXXIV-3, condensate storage tank are seismic category I.
1i ASNE Section VIII, Division 1, and USAS 831.1.0 apply downstream of the outermost isolation XVIll-4, XVill-5, XViII-6, XVIII-7, XVIII-8, valves.
Ir   The return line to the condensate storage tank was classified as "Q"by Bechtel inthe            XI-3, XII-3, 0-list (Ref. 225) and was built that way by Bechtel. However, these lines are actually Quality Group 0, with no QA requirement. That isthe way these lines are classified in this table.
1k The gaseous raduaste system piping, pumps and valves containing gaseous radwaste shall be XXIII-3, XXIll-4, XXIII-5, XXIII-6, constructed in accordance with the applicable codes of Quality Group D.
is   The Bechtel 0-list (Ref. 225, item 2.4365) notes this item as 0. However, the entry refers     XXVI-3, XXVI-2, XXVII-2, to Bechtel Specification N-119 (Reference 252). This document addresses Seismic Category I supports only. Therefore, only the supports inthis item have a requirement for quality assurae and are Seismic Category I.
11 Some of this piping was also constructed to 831.1.0 IV-4, IV-8, im Some lines, such as ECB-9 (drain to filter/demineralizer), are class 3, non-seismic.
I I                                                                                       IELP/Footnote/Footnote I'I'~               t'.
V-8, in This system includes reactor head spray.
Et
X-1, to Lines DC8-1 and DC8-2 are nuclear class 3, according to Bechtel Specification N-190.
XIX-4, XIX-7, ip The RNRSU backwash line (GBD-62 and GBO-63) is non-seismic, according to Bechtel XXV-1, XXV-4, Specification M-190, Sheet 23A.
Iq Portions of this system which supply suction for HPCI, RCIC, and Core Spray from the XXXIV-2, XXXIV-3, condensate storage tank are seismic category I.
Ir The return line to the condensate storage tank was classified as "Q" by Bechtel in the XI-3, XII-3, 0-list (Ref. 225) and was built that way by Bechtel. However, these lines are actually Quality Group 0, with no QA requirement. That is the way these lines are classified in this table.
is The Bechtel 0-list (Ref. 225, item 2.4365) notes this item as 0. However, the entry refers XXVI-3, XXVI-2, XXVII-2, to Bechtel Specification N-119 (Reference 252). This document addresses Seismic Category I supports only. Therefore, only the supports in this item have a requirement for quality assurae and are Seismic Category I.
I Et I
IELP/Footnote/Footnote I'I'~
t'.


Table 3.
Table 3.
DAEC Classification of Componnts in Systems Foot#   FootNote Pootnotes                                                      I 10 Systems it     The Bechtel 0-tist (Ref. 225, Item 2.1510) notes this item as 0. However, only pipe         xIX-I, XIX-2, XIX-4, XIX-5, XIX-7, xIX-8, hangers and supports provide a specification (N-119, Ref. 252) as a reference. Therefore, only pipe hangers and supports for this item are seismic category I and have special Quality Assurance requirements.
DAEC Classification of Componnts in Systems Pootnotes Systems Foot#
lu     See GE docunent NEDC-31853 (Ref. 2) "Duane Arnold Design Safety Standards", Appendix A, for 1-5, 1-6, 1-9, I ()
FootNote it The Bechtel 0-tist (Ref. 225, Item 2.1510) notes this item as 0. However, only pipe xIX-I, XIX-2, XIX-4, XIX-5, XIX-7, x hangers and supports provide a specification (N-119, Ref. 252) as a reference. Therefore, only pipe hangers and supports for this item are seismic category I and have special Quality Assurance requirements.
IX                                                                       X   -e                                   IELP/Footnote/Footnote 2:~~~~~~~~~~~2   ~        1~e5 2,4V?/                 -~-4/''             7     '
lu See GE docunent NEDC-31853 (Ref. 2) "Duane Arnold Design Safety Standards", Appendix A, for 1-5, 1-6, 1-9, IX X  
                      /     4               ~ 4e
-e IELP/Footnote/Footnote 2:~~~~~~~~~~~2 1~e5  
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Table 3.2-1 DAEC Classification of ComPoncals in Systems                                                                   10 Comments SysD/Comp#   Caments IV         4. 1 The design and construction specifications for the hydraulic control unit (HCU) do invoke such codes and standards as can be reasonably applied to individual parts in developing required quality levels, but these codes and standards are supplemented with additional requirements parts and for the remaining parts and details. For example: (1) all welds are liquid-penetrant inspected; (2) alt socket welds are for    these checked for minimum engagement and and gap between pipe and socket bottom by a marking technique; (3) all welding was performed by qualified welders; (4)all work was done per written procedures. The following examples are typical of the problem associated with codes designed to control field-asseabled comporants wdhen applied to the design and production of factory fabricated specialty components: **1. The HCU nitrogen gas bottle is a spun forging that is mechanically joined to the accumulator. It stores the energy required to scram a drive at low vessel pressure. It has been code stamped since its introduction in 1966, although its size exempts it from mandatory stamping. It isconstructed of a material listed the ASHE BAPV Code, Section VIII, that was selected for its strength and formability. **2. The scram accumulator is joined to the HCU by a splitby flange joint chosen for its compact design to facilitate both assembly and maintenance. Both the design and construction conform to the 931.1.0     10 piping code. This joint, which requires a design pressure of 1750 psig, has been proof tested to 10,000 pal. **3. The accumulator nitrogen shutoff valve is a 6.000 pal cartridge valve whose copper alloy material is listed In the ASHE BAPV Code, Section ViII. The valve was chosen for this service partly because it is qualified by the U.S. Navy for submarine service. **4. The directional control valves are solenoid pilot-operated valves that are subplate mounted on the HCU. The valve has a body specialty designed for the NCU, but the operating parts are identical to a commercial valve with a proven history of satisfactory service. The pressure retaining parts are stainless steel alloys chosen service, fabrication and magnetic properties. The manufacturer cannot substitute a code material for that used for the solenoid core tube. Thefor foregoing examples are not ment to justify one pressure integrity quality level or another, but to demonstrate that the codes and standards invoked by those quality levels are not strictly applicable to special equipment and part designs. Group D classification is generally applicable because the codes and standards invoked by that classification contain clauses that permit the use of manufacturer's standards and proven design techniques that are not explicitly defined within those codes. This was supplemented by the quality control techniques described above.
Table 3.2-1 DAEC Classification of ComPoncals in Systems 10 Comments SysD/Comp#
IV         4. 2 Bechtel built these items to ASNE Class 2 standards, based on the piping classes given on the PID (see paragraph 3.2.7). However, based on the CA classification of these item, they should have been Class 3. The higher class is shown on this table, although Class 3 is justifiable and would make more sense with the GA Group 0 designation.
Caments IV
IV         8. 1 The design and construction specifications for the hydraulic control unit (HCU) do invoke such codes and standards as can be reasonably applied to individual parts indeveloping required quality levels, but these codes and standards are supplemented with additional requirements for these parts and for the reaining parts and details. For example: (1) all welds are liquid-penetrant inspected; (2) all socket welds are checked for minimu engagement and end gap between pipe and socket bottom by a marking technique; (3) at welding was performed by qualified welders; (4)alI work was done per written procedures. The following examples are typical of the problems associated with codes designed to control field-assembled components when applied to the design and production of factory fabricated specialty components: **1. The NU nitrogen gas bottle is a spun forging that ismechanically joined to the accsuulator. It stores the energy required to scram a drive at low vessel pressure. It has been code.steeped since its introduction in 1966, although its size exempts it from mandatory stamping. It is constructed of a material listed       10 by the ASNE B&PV Code, Section VIII, that was selected for its strength and formability. **2. The scram accumulator is joined to the HCU by a split flange joint chosen for its compact design to facilitate both asseobly and maintenance. Both the design and construction conform to the 631.1.0 piping code. This joint, which requires a design pressure of 1750 psig, has been proof tested to 10,000 pal. **3. The accumulator nitrogen shutoff valve is a 6,000 psi cartridge valve whose copper alloy material is listed In the ASNE BAPV Code, Section Vill. The valve was chosen for this service partly because it isqualified by the U.S. -Navy for submarine service. **4. The directional control valves are solenoid pi(ot-operated valves that are subptate mounted on the HCU. The valve has a body specially designed for the HCU, but the operating parts are identical to a commercial valve with a proven history of satisfactory service. The pressure retaining parts are stainless steel alloys chosen for service, fabrication and magnetic properties. The manufacturer cannot substitute a code material for that used for the solenoid core tube. The foregoing examples are not mant to justify one pressure integrity quality level or another, but to demonstrate that the codes and standards invoked by those quality levels are not strictly applicable to special equipment and part designs. Group D classification is generally applicable because the codes and standards invoked by that classification contain clauses that permit the use of manufacturer's standards and proven design techniques that are not explicitly defined within those codes. This was supplemented by the quality control techniques described above.
: 4.
IV         8. 2 Bechtel built these items to ASME Class 2 standards, based on the piping classes given on the PLID (see paragraph 3.2.7). However, based on the OA classification of these items, they should have been Class 3. The higher class is shown on this table, although Class 3 is justifiable and would make more sense with the CA Group D designation.
1 The design and construction specifications for the hydraulic control unit (HCU) do invoke such codes and standards as can be reasonably applied to individual parts in developing required quality levels, but these codes and standards are supplemented with additional requirements for these parts and for the remaining parts and details.
For example: (1) all welds are liquid-penetrant inspected; (2) alt socket welds are checked for minimum engagement and and gap between pipe and socket bottom by a marking technique; (3) all welding was performed by qualified welders; (4)all work was done per written procedures.
The following examples are typical of the problem associated with codes designed to control field-asseabled comporants wdhen applied to the design and production of factory fabricated specialty components: **1.
The HCU nitrogen gas bottle is a spun forging that is mechanically joined to the accumulator.
It stores the energy required to scram a drive at low vessel pressure.
It has been code stamped since its introduction in 1966, although its size exempts it from mandatory stamping.
It is constructed of a material listed by the ASHE BAPV Code, Section VIII, that was selected for its strength and formability.  
**2. The scram accumulator is joined to the HCU by a split flange joint chosen for its compact design to facilitate both assembly and maintenance.
Both the design and construction conform to the 931.1.0 10 piping code.
This joint, which requires a design pressure of 1750 psig, has been proof tested to 10,000 pal.  
**3. The accumulator nitrogen shutoff valve is a 6.000 pal cartridge valve whose copper alloy material is listed In the ASHE BAPV Code, Section ViII.
The valve was chosen for this service partly because it is qualified by the U.S. Navy for submarine service.  
**4.
The directional control valves are solenoid pilot-operated valves that are subplate mounted on the HCU.
The valve has a body specialty designed for the NCU, but the operating parts are identical to a commercial valve with a proven history of satisfactory service.
The pressure retaining parts are stainless steel alloys chosen for service, fabrication and magnetic properties.
The manufacturer cannot substitute a code material for that used for the solenoid core tube.
The foregoing examples are not ment to justify one pressure integrity quality level or another, but to demonstrate that the codes and standards invoked by those quality levels are not strictly applicable to special equipment and part designs.
Group D classification is generally applicable because the codes and standards invoked by that classification contain clauses that permit the use of manufacturer's standards and proven design techniques that are not explicitly defined within those codes.
This was supplemented by the quality control techniques described above.
IV
: 4.
2 Bechtel built these items to ASNE Class 2 standards, based on the piping classes given on the PID (see paragraph 3.2.7).
However, based on the CA classification of these item, they should have been Class 3. The higher class is shown on this table, although Class 3 is justifiable and would make more sense with the GA Group 0 designation.
IV
: 8.
1 The design and construction specifications for the hydraulic control unit (HCU) do invoke such codes and standards as can be reasonably applied to individual parts in developing required quality levels, but these codes and standards are supplemented with additional requirements for these parts and for the reaining parts and details.
For example: (1) all welds are liquid-penetrant inspected; (2) all socket welds are checked for minimu engagement and end gap between pipe and socket bottom by a marking technique; (3) at welding was performed by qualified welders; (4)alI work was done per written procedures.
The following examples are typical of the problems associated with codes designed to control field-assembled components when applied to the design and production of factory fabricated specialty components: **1.
The NU nitrogen gas bottle is a spun forging that is mechanically joined to the accsuulator.
It stores the energy required to scram a drive at low vessel pressure.
It has 10 been code.steeped since its introduction in 1966, although its size exempts it from mandatory stamping.
It is constructed of a material listed by the ASNE B&PV Code, Section VIII, that was selected for its strength and formability.  
**2. The scram accumulator is joined to the HCU by a split flange joint chosen for its compact design to facilitate both asseobly and maintenance.
Both the design and construction conform to the 631.1.0 piping code.
This joint, which requires a design pressure of 1750 psig, has been proof tested to 10,000 pal. **3.
The accumulator nitrogen shutoff valve is a 6,000 psi cartridge valve whose copper alloy material is listed In the ASNE BAPV Code, Section Vill.
The valve was chosen for this service partly because it is qualified by the U.S. -Navy for submarine service.  
**4. The directional control valves are solenoid pi(ot-operated valves that are subptate mounted on the HCU.
The valve has a body specially designed for the HCU, but the operating parts are identical to a commercial valve with a proven history of satisfactory service.
The pressure retaining parts are stainless steel alloys chosen for service, fabrication and magnetic properties.
The manufacturer cannot substitute a code material for that used for the solenoid core tube.
The foregoing examples are not mant to justify one pressure integrity quality level or another, but to demonstrate that the codes and standards invoked by those quality levels are not strictly applicable to special equipment and part designs.
Group D classification is generally applicable because the codes and standards invoked by that classification contain clauses that permit the use of manufacturer's standards and proven design techniques that are not explicitly defined within those codes. This was supplemented by the quality control techniques described above.
IV
: 8.
2 Bechtel built these items to ASME Class 2 standards, based on the piping classes given on the PLID (see paragraph 3.2.7). However, based on the OA classification of these items, they should have been Class 3. The higher class is shown on this table, although Class 3 is justifiable and would make more sense with the CA Group D designation.
IELP/Systems/SysComts
IELP/Systems/SysComts


          'ROW'Table                                                                 3W   'W DABC ('lassificatina of Componen s in Systems Commcals Sys#/Campe     Comments IV           . 7 The design and construction specifications for the hydraulic control unit (NCU) do invoke such codes and standards as can be reasonably applied to individual parts in developing required quality levels, but these codes and standards are supplemented with additional requirements for these parts and for the remaining parts and details. For example: (1) all welds are liquid-penetrant inspected; (2) all socket welds are checked for minima engagement anid end gap between pipe and socket bottom by a marking technique; (3) all welding was performed by qualified welders; (4)all work was done per written procedures. The following examples are typical of the problems associated with codes designed to control field-assembled copnents uhen applied to the design and production of factory fabricated specialty components: **1. The EIU nitrogen gas bottle is a spun forging that is pchanically joined to the accumulator. It stores the energy required to scram a drive at low vessel pressure. It has been code stamped since its introduction in 1966, although its site exempts it from mandatory stamping. It is constructed of a material listed by the ASHE APV Code, Section Wi1, that was selected for its strength and formability. **2. The scram accumulator is joined to the HCU by a split flange joint chosen for its compact design to facilitate both assembly and maintenance. Both the design and construction conform to the 831.1.0 piping code. This joint, which requires a design pressure of 1750 paig, has been proof tested to 10,000 psi. **3. The accumulator nitrogen shutoff valve is a 6,000 psi cartridge valve whose copper alloy material is listed in the ASHE BAV Code, Section Vill. The valve was chosen for this service prtly because it is qualified by the U.S. Navy for subsrine service. **4. The directional control valves are solenoid pilot-operated valves that are subplate mounted on the NCU. The valve has a body specially designed for the MCU, but the operating parts are identical to a commerciat valve with a proven history of satisfactory service. The pressure retaining parts are stainless steel alloys chosen for service, fabrication and magnetic properties. The manufacturer cannot substitute a code material for that used for the solenoid core tube. The foregoing examples are not meant to justify one pressure integrity quality level or another, but to demonstrate that the codes and standards invoked by those quality levels are not strictly applicable to special equipment and part designs. Group D classification is generally applicable because the codes and standards invoked by that classification contain clauses that permit the use of manufacturer's standards and proven design techniques that are not explicitly defined within those codes. This was supplemented by the quality control techniques described above.
'ROW 'Table 3W 'W DABC ('lassificatina of Componen s in Systems Commcals Sys#/Campe Comments IV 7 The design and construction specifications for the hydraulic control unit (NCU) do invoke such codes and standards as can be reasonably applied to individual parts in developing required quality levels, but these codes and standards are supplemented with additional requirements for these parts and for the remaining parts and details.
V           1. 1 The standby liquid control storage tank is designed, fabricated, inspected, and tested to meet the intent of API Standard 650 and the ASHE BLPV Code, Section Vill, Division 1. All butt welds are given spot radiographic examination. Liquid-penetrant inspection is conducted per the ASNE Code, Section ViII, Division 1, on the following welds: **(1)AII tank nozzle welds below and including the overflow nozzle are examined internally and externally to the tank. **(2)Att fillet and socket welds receive a random examination.
For example: (1) all welds are liquid-penetrant inspected; (2) all socket welds are checked for minima engagement anid end gap between pipe and socket bottom by a marking technique; (3) all welding was performed by qualified welders; (4)all work was done per written procedures.
V           1. 2 The construction of the accumulator is in accordance with the requirements of the ASHE BAPV Code, Section VIII, Division 1. An ASHE stamp is required. Other codes applied to the accumulator are as follows: **(1)AMSI 816.11 OForged Steel Fittings, Socket Uelded and Threaded". **(2)AND 10050 "Bosses, Standard Dimensions for Gasket Seat Straight Thread.
The following examples are typical of the problems associated with codes designed to control field-assembled copnents uhen applied to the design and production of factory fabricated specialty components: **1.
VI         3. 1 See IELP letter to the USMRC, NG-91-2652, dated 8/27/91, for inclusion of the 24 V D. C. Power Supply with this Item.                               10 XI         9. 1. The HPCI turbine is categorized as machinery and thus does not fall within the classification groups as earlier identified. To ensure that the turbine was fabricated to the standards commensurate with its performance requirements, General Electric has established specific design requirements for this component, as follows: **(1)AII welding was qualified in accordance with Section IX of the ASHE B&PV Code. **(2)Att pressure retaining castings and fabrications were hydrotested to 1.5 x design pressure. **(3)Att high pressure castings were radiographed according to ASTN E-94 (201 coverage, minimum), ASTN E-142 (severity level 3), ASTN-71, ASTN 186, or ASTN-280. **(4)As-cast surfaces were magnetic particle or liquid-penetrant tested according to the ASE UAPV Code, Section III, 1968 Edition, paragraph M323.3 or N323.4. **(5)Uheel and shaft forgins were ultrasonically tested according to ASTN A388. **(6)Butt welds were radiographed according to the ASHE BAPV Code, Section III, 1968 Edition paragraph N626 or N627. **(7)Motifieation made on any major repairs and records maintained. **(8)Record system and traceability acco         to the ASM B&PV Code, Section III, 1968 Edition, IX-225. **(9)Control and identification according to the ASHE BAPV Code,
The EIU nitrogen gas bottle is a spun forging that is pchanically joined to the accumulator.
                                            -ing Section III, 1968 Edition, IX-226.     *(10O)Procedures conform to the ASHE M&PVCot*       IJdi         Io     IN-300. !** _Jnspection personnel are qualified according to the ASHE BAPV Code, Section III, 1968 Edition, IX-400                             C11-9e       , 2>
It stores the energy required to scram a drive at low vessel pressure.
Xii         9. 1 The RCIC turbine is categorized as machinery and thus does not fall within the ciao                                               ensure that the turbine was fabricated to the standards commensurate with its performance requirements, General Electric has established specific design requirments for this component, as follows: **(1)All welding was qualified in accordance with Section IXof the ASHE UPV Code. **(Z)AII pressure retaining castings and fabrications were hydrotested to 1.5 x design pressure. **(3)AII high pressure castings were radiographed according to ASTN E-94 (20% coverage, minimum), ASTH E-142 (severity level 3), ASTN-71, ASTM-186, or ASTM-280. **(4)As-cast surfaces were magnetic particle or liquid-penetrant tested according to the ASHE BAPV Code, Section 1I, 1968 Edition, paragraph N323.3 or N323.4. **(5)Uheel and shaft forgin a were ultrasonically tested according to ASTN A388. **(6)8utt welds were radiographed according to the ASHE atPV Code, Section I 1on             paragraph N626 or 1627. **(7)Notification made on any major repairs and records maintained. **(8)Record system and traceability according to the ASHE BAPV Code, Section 1I, 1968 Edition, IX-225. **(9)Control and identification according to the ASHE 8&PV Code, Section Ill, 1968 Edition, IX-226. **(10)Proceduras conform to the ASK! BPV Code         t             I         -3 . **(11)Inspection personnel are qualified according to the ASME BAPV Code, Section Ill, 1968 Edition, IX-400.   /$2     -gt/-ef       . E ,a.,',k
It has been code stamped since its introduction in 1966, although its site exempts it from mandatory stamping.
It is constructed of a material listed by the ASHE APV Code, Section Wi1, that was selected for its strength and formability.  
**2. The scram accumulator is joined to the HCU by a split flange joint chosen for its compact design to facilitate both assembly and maintenance.
Both the design and construction conform to the 831.1.0 piping code.
This joint, which requires a design pressure of 1750 paig, has been proof tested to 10,000 psi. **3.
The accumulator nitrogen shutoff valve is a 6,000 psi cartridge valve whose copper alloy material is listed in the ASHE BAV Code, Section Vill.
The valve was chosen for this service prtly because it is qualified by the U.S. Navy for subsrine service.  
**4. The directional control valves are solenoid pilot-operated valves that are subplate mounted on the NCU.
The valve has a body specially designed for the MCU, but the operating parts are identical to a commerciat valve with a proven history of satisfactory service.
The pressure retaining parts are stainless steel alloys chosen for service, fabrication and magnetic properties.
The manufacturer cannot substitute a code material for that used for the solenoid core tube.
The foregoing examples are not meant to justify one pressure integrity quality level or another, but to demonstrate that the codes and standards invoked by those quality levels are not strictly applicable to special equipment and part designs.
Group D classification is generally applicable because the codes and standards invoked by that classification contain clauses that permit the use of manufacturer's standards and proven design techniques that are not explicitly defined within those codes.
This was supplemented by the quality control techniques described above.
V
: 1.
1 The standby liquid control storage tank is designed, fabricated, inspected, and tested to meet the intent of API Standard 650 and the ASHE BLPV Code, Section Vill, Division 1. All butt welds are given spot radiographic examination.
Liquid-penetrant inspection is conducted per the ASNE Code, Section ViII, Division 1, on the following welds: **(1)AII tank nozzle welds below and including the overflow nozzle are examined internally and externally to the tank.  
**(2)Att fillet and socket welds receive a random examination.
V
: 1.
2 The construction of the accumulator is in accordance with the requirements of the ASHE BAPV Code, Section VIII, Division 1. An ASHE stamp is required.
Other codes applied to the accumulator are as follows: **(1)AMSI 816.11 OForged Steel Fittings, Socket Uelded and Threaded".  
**(2)AND 10050 "Bosses, Standard Dimensions for Gasket Seat Straight Thread.
VI
: 3.
1 See IELP letter to the USMRC, NG-91-2652, dated 8/27/91, for inclusion of the 24 V D. C. Power Supply with this Item.
10 XI
: 9.
: 1. The HPCI turbine is categorized as machinery and thus does not fall within the classification groups as earlier identified.
To ensure that the turbine was fabricated to the standards commensurate with its performance requirements, General Electric has established specific design requirements for this component, as follows:  
**(1)AII welding was qualified in accordance with Section IX of the ASHE B&PV Code.  
**(2)Att pressure retaining castings and fabrications were hydrotested to 1.5 x design pressure.  
**(3)Att high pressure castings were radiographed according to ASTN E-94 (201 coverage, minimum), ASTN E-142 (severity level 3), ASTN-71, ASTN 186, or ASTN-280.  
**(4)As-cast surfaces were magnetic particle or liquid-penetrant tested according to the ASE UAPV Code, Section III, 1968 Edition, paragraph M323.3 or N323.4.  
**(5)Uheel and shaft forgins were ultrasonically tested according to ASTN A388.  
**(6)Butt welds were radiographed according to the ASHE BAPV Code, Section III, 1968 Edition paragraph N626 or N627.  
**(7)Motifieation made on any major repairs and records maintained.  
**(8)Record system and traceability acco  
-ing to the ASM B&PV Code, Section III, 1968 Edition, IX-225. **(9)Control and identification according to the ASHE BAPV Code, Section III, 1968 Edition, IX-226.  
*(10O)Procedures conform to the ASHE M&PV Cot*
IJdi Io IN-300. !** _Jnspection personnel are qualified according to the ASHE BAPV Code, Section III, 1968 Edition, IX-400 C11-9e  
, 2>
Xii
: 9.
1 The RCIC turbine is categorized as machinery and thus does not fall within the ciao ensure that the turbine was fabricated to the standards commensurate with its performance requirements, General Electric has established specific design requirments for this component, as follows:  
**(1)All welding was qualified in accordance with Section IX of the ASHE UPV Code.  
**(Z)AII pressure retaining castings and fabrications were hydrotested to 1.5 x design pressure.  
**(3)AII high pressure castings were radiographed according to ASTN E-94 (20% coverage, minimum), ASTH E-142 (severity level 3), ASTN-71, ASTM-186, or ASTM-280.  
**(4)As-cast surfaces were magnetic particle or liquid-penetrant tested according to the ASHE BAPV Code, Section 1I, 1968 Edition, paragraph N323.3 or N323.4.  
**(5)Uheel and shaft forgin a were ultrasonically tested according to ASTN A388.  
**(6)8utt welds were radiographed according to the ASHE atPV Code, Section I 1on paragraph N626 or 1627.  
**(7)Notification made on any major repairs and records maintained.  
**(8)Record system and traceability according to the ASHE BAPV Code, Section 1I, 1968 Edition, IX-225.  
**(9)Control and identification according to the ASHE 8&PV Code, Section Ill, 1968 Edition, IX-226. **(10)Proceduras conform to the ASK! BPV Code t
I  
-3.
**(11)Inspection personnel are qualified according to the ASME BAPV Code, Section Ill, 1968 Edition, IX-400.  
/$2  
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Table 3.2-1 DABC Classificatin of Compoacals in Systems                                                                             t0 Commeals Sys#/Compf       Comments XVIII       1.     1 Unprocessed liquid radioactive waste piping and equipment pressure parts installed prior to January 1, 198.
Table 3.2-1 DABC Classificatin of Compoacals in Systems t 0 Commeals Sys#/Compf Comments XVIII
Unprocessed liquid radioactive waste piping and equipment pressure parts installed subsequent to               were classified as Quality Grop C.
: 1.
D with added quality control (D+QA) in accordance with the design guidance contained in RegulatoryJanuary  1, 1983, my be included in Quality Group Guide 1.143, Revision 1, modified as follows:u (1)Paragraphs C.4.1.3, C.2.1.3, and C.3.1.3 - The commitment is limited to the selmic design methods DAEC and is not uprgraded to Regulatory Guide 1.143, Revision 1, requirements. **(2)Paragraph C.4.3       used in the original construction of the with good operability, maintenance, and repairability practices. **(3)Paragraph C.6 - All of paragraph- System will be fabricated in accordance following senteeme.t*AI safety related systems or portions of systems shall be designed, fabricated C.6 is replaced in its entirety by the Level 11 requirements.0                                                                                 and installed in accordance with Quality Vill     4.       1 Unprocessed liquid radioactive waste piping and equipment pressure parts Installed prior to January 1, 1983, Unprocessed liquid radioactive waste piping and equipment pressure parts Installed subsequent to January 1, were classified as Quality Group C.
1 Unprocessed liquid radioactive waste piping and equipment pressure parts installed prior to January 1, 198.
1983, may be included inQuality Group J         0 with added quality control (D+M4) in accordance with the design guidance contained in Regulatory Guide 1.143, Revision 1, modified as follows:
were classified as Quality Grop C.
7'<           ,Z, ""AEC
Unprocessed liquid radioactive waste piping and equipment pressure parts installed subsequent to January 1, 1983, my be included in Quality Group D with added quality control (D+QA) in accordance with the design guidance contained in Regulatory Guide 1.143, Revision 1, modified as follows:u (1)Paragraphs C.4.1.3, C.2.1.3, and C.3.1.3 - The commitment is limited to the selmic design methods used in the original construction of the DAEC and is not uprgraded to Regulatory Guide 1.143, Revision 1, requirements.  
                      , *(1)Paragraphs and is not C.1.1.3, uprgradedC.2.1.3, and C.3.1.3 - The commitment is limited to the seismic design methods used in the original construction of the to Regulatory Guide 1.143, Revision 1, requirements. **(2)Paragraph C.4.3 - Systems ulith good operability, maintenance, and repairability practices. **(3)Paragraph C.6 - All of paragraph C.6 is will    be fabricated in accordance replaced in its entirety by the following sentence. At safety related systes or portions of systes shall be designed, fabricated and Installed in accordance with Quality
**(2)Paragraph C.4.3 - System will be fabricated in accordance with good operability, maintenance, and repairability practices. **(3)Paragraph C.6 - All of paragraph C.6 is replaced in its entirety by the following senteeme. t*AI safety related systems or portions of systems shall be designed, fabricated and installed in accordance with Quality Level 11 requirements.0 Vill
      /1               Lee II requirements.6 I       7.       1 Tme ogas takiution fans are Sesmic Class Inmust meet the total Q lity Assurance Program.
: 4.
SV         .          me gency serv ce ws er system meets the pressure integrity requirements oi       y       , nc     ng the additional quality assurance                 10 requirements for *critical* piping, as stated in Section 17.1.8.1. All inspection records will be retained according to the Quality Assurance Program of Chapter 10. These records include data pertaining to the qualification procedures and examination results.
1 Unprocessed liquid radioactive waste piping and equipment pressure parts Installed prior to January 1, 1983, were classified as Quality Group C.
KWMIll       1.     1 For Main Stem and Turbine "ypass piping and valves, alt inspection records were retained according to the Quality Assurance Program of Chapter
Unprocessed liquid radioactive waste piping and equipment pressure parts Installed subsequent to January 1, 1983, may be included in Quality Group J
: 17. These records include data pertaining to the qualification of inspection personnel, examination procedures, and examination results.                   10 XXXIII       1. 2 Turbine Stop, Control, and Bypass Valves: A certification was obtained from the vendors of these valves Indicating           that all cast pressure-retaining parts of a size and configuration for which volumstric examination methods are effective have been examined                             10 methods by qualified personnel. Ultrasonic examination to equivalent standards are used as an alternative to radiographic methods. by  radiographic XXXill       1.     3 The main steam piping between the outermost containment isolation valves up to the turbine stop valves, the main turbine bypass valves and all branch line connected to these portions of the main steam and turbine bypass piping turbine up  to bypass piping up to the the first valve capable of 10 timely actuation are classified as Quality Group 0 and meet the additional quality assurance requirements for *critical* piping,       as stated in Section 17.1.8.1, Schedule IV.
0 with added quality control (D+M4) in accordance with the design guidance contained in Regulatory Guide 1.143, Revision 1, modified as follows:
XXXIII       1.     4 The first valve capable of timely actuation in branch lines connected to the main steam lines between the outermost containment and turbine stop valves and connected to the turbine bypass valves meets all of the pressure integrity requirements of Quality Group isolation valves    I 10 the additional quality assurance requirements for "critical* piping, as stated in Section 17.1.8.1, Schedule IV.                           0, including Xxill       1. 5 All inspection records for the min steam and turbine bypass piping and the first valve in the branch lines connected to this piping were retained               10 according to the Quality Assurance Program of Chapter 17. These records include date pertaining to the qualification of Inspection personne(,
7 '<  
,Z  
*(1)Paragraphs C.1.1.3, C.2.1.3, and C.3.1.3 - The commitment is limited to the seismic design methods used in the original construction of the  
""AEC and is not uprgraded to Regulatory Guide 1.143, Revision 1, requirements.  
**(2)Paragraph C.4.3 - Systems will be fabricated in accordance ulith good operability, maintenance, and repairability practices.  
**(3)Paragraph C.6 - All of paragraph C.6 is replaced in its entirety by the following sentence.
At safety related systes or portions of systes shall be designed, fabricated and Installed in accordance with Quality  
/1 Lee II requirements.6 I
: 7.
1 Tme ogas takiution fans are Sesmic Class Inmust meet the total Q lity Assurance Program.
SV me gency serv ce ws er system meets the pressure integrity requirements oi y
nc ng the additional quality assurance 10 requirements for *critical* piping, as stated in Section 17.1.8.1.
All inspection records will be retained according to the Quality Assurance Program of Chapter 10. These records include data pertaining to the qualification procedures and examination results.
KWMIll
: 1.
1 For Main Stem and Turbine "ypass piping and valves, alt inspection records were retained according to the Quality Assurance Program of Chapter 10
: 17.
These records include data pertaining to the qualification of inspection personnel, examination procedures, and examination results.
XXXIII
: 1.
2 Turbine Stop, Control, and Bypass Valves: A certification was obtained from the vendors of these valves Indicating that all cast 10 pressure-retaining parts of a size and configuration for which volumstric examination methods are effective have been examined by radiographic methods by qualified personnel.
Ultrasonic examination to equivalent standards are used as an alternative to radiographic methods.
XXXill
: 1.
3 The main steam piping between the outermost containment isolation valves up to the turbine stop valves, the main turbine bypass piping up to the 10 turbine bypass valves and all branch line connected to these portions of the main steam and turbine bypass piping up to the first valve capable of timely actuation are classified as Quality Group 0 and meet the additional quality assurance requirements for *critical* piping, as stated in Section 17.1.8.1, Schedule IV.
XXXIII
: 1.
4 The first valve capable of timely actuation in branch lines connected to the main steam lines between the outermost containment isolation valves I 10 and turbine stop valves and connected to the turbine bypass valves meets all of the pressure integrity requirements of Quality Group 0, including the additional quality assurance requirements for "critical* piping, as stated in Section 17.1.8.1, Schedule IV.
Xxill
: 1. 5 All inspection records for the min steam and turbine bypass piping and the first valve in the branch lines connected to this piping were retained 10 according to the Quality Assurance Program of Chapter 17.
These records include date pertaining to the qualification of Inspection personne(,
examination procedures, and examination results.
examination procedures, and examination results.
xxxIll     4.       1 Materials used in feedwater control valves are as follows: **(1)Valve body is ASTM A105 Gr. II. **(2)Valve bonnet is ASTM A105 Gr. II and A234         I 10 Gr. UP.
xxxIll
XXXIII     4.       2 Examination and testing requirements for the feedeater control valves are as followss *(1)All pressure retaining castings are radiographed, after final heat treatment, in accordance with the ASHE BAV Code, Section III, Appendix IX, paragraph 330 and ASTM E142. Discontinuities are judged by ASTN E71, E166, and E280. **(2)AIt accessible surfaces of all pressure retaining castings are examined in finished condition, after final heat treatment, by either liquid penetrant methods per paragraph M323.4 or magnetic particle methods per paragraph M323.3, with acceptance criteria per paragraph 1323.4 of the Sumer 1969 addenda to ASME Section Ill. **(3)All pressure retaining forgings are examined In the as-furnished condition by the ultrasonic method per paragraph M322 of the summer 1969 Addenda to ASME, Section III.
: 4.
KXMIV       1.     1 The condensate storage tank was designed, fabricated, and tested to meet the Intent of API Standard 650. In addition,     the specifications for this tank require (1) 1001 surface examination of the side wall to bottom joint and (2) 1001 volumetric examination of the aide wall weld joints.               10 XXXIV       1. 2 Page 13.2-5 of the UFSAR (Ref. 233) says that the CST isnon-seismic.
1 Materials used in feedwater control valves are as follows:  
GENERAL             1 B31.1.0 and 331.7 were originally published as USA Standards (USAS), but are now designated as ANSI Standards.
**(1)Valve body is ASTM A105 Gr. II.  
GENERAL             2 See additional material examination requirements of Section 17.1.8.1 for piping and valves.
**(2)Valve bonnet is ASTM A105 Gr. II and A234 I 10 Gr. UP.
GENERAL             3 Code effective date is obtained by the Purchase Order date for the particular component (see Table 3.2-1) or by referring to Table 3.2-2.
XXXIII
: 4.
2 Examination and testing requirements for the feedeater control valves are as followss  
*(1)All pressure retaining castings are radiographed, after final heat treatment, in accordance with the ASHE BAV Code, Section III, Appendix IX, paragraph 330 and ASTM E142.
Discontinuities are judged by ASTN E71, E166, and E280.  
**(2)AIt accessible surfaces of all pressure retaining castings are examined in finished condition, after final heat treatment, by either liquid penetrant methods per paragraph M323.4 or magnetic particle methods per paragraph M323.3, with acceptance criteria per paragraph 1323.4 of the Sumer 1969 addenda to ASME Section Ill. **(3)All pressure retaining forgings are examined In the as-furnished condition by the ultrasonic method per paragraph M322 of the summer 1969 Addenda to ASME, Section III.
KXMIV
: 1.
1 The condensate storage tank was designed, fabricated, and tested to meet the Intent of API Standard 650. In addition, the specifications for this tank require (1) 1001 surface examination of the side wall to bottom joint and (2) 1001 volumetric examination of the aide wall weld joints.
10 XXXIV
: 1.
2 Page 13.2-5 of the UFSAR (Ref. 233) says that the CST is non-seismic.
GENERAL 1 B31.1.0 and 331.7 were originally published as USA Standards (USAS), but are now designated as ANSI Standards.
GENERAL 2 See additional material examination requirements of Section 17.1.8.1 for piping and valves.
GENERAL 3 Code effective date is obtained by the Purchase Order date for the particular component (see Table 3.2-1) or by referring to Table 3.2-2.
IELP/Systems/SysComts A
IELP/Systems/SysComts A


Insert XXIII   -3,4,5,6 Sys#/Comp# I                                               Comments XXIII               3. 1 The construction codes used for Offgas pipe, pumps, and valves were USAS B31.7; ASME Sections III and VIII; and the Draft Pump and Valve Code. To identify the correct code for a component it is necessary to research the receiving inspection files (File Q2.321). There are two reasons that several codes and dates were applied. The first reason is that the Offgas design was changed during Procurement/Construction. The second reason is that the codes were changing rapidly during the period of the design. The project correspondence which records when the Offgas System construction code was changed is given in APED-N62-076.
Insert XXIII -3,4,5,6 Sys#/Comp# I Comments XXIII
XXIII               4. 1 The construction codes used for Offgas pipe, pumps, and valves were USAS B31.7; ASME Sections III and VIII; and the Draft Pump and Valve Code. To identify the correct code for a component it is necessary to research the receiving inspection files (File Q2.321). There are two reasons that several codes and dates were applied. The first reason is that the Offgas design was changed during Procurement/Construction. The second reason is that the codes were changing rapidly during the period of the design. The project correspondence which records when the Offgas System construction code was changed is given in APED-N62-076.
: 3.
XXIII               5. 1 The construction codes used for Offgas pipe, pumps, and valves were USAS B31.7; ASME Sections III and VIII; and the Draft Pump and Valve Code. To identify the correct code for a component it is necessary to research the receiving inspection files (File Q2.321). There are two reasons that several codes and dates were applied. The first reason is that the Offgas design was changed during Procurement/Construction. The second reason is that the codes were changing rapidly during the period of the design. The project correspondence which records when the Offgas System construction code was changed is given in APED-N62-076.
1 The construction codes used for Offgas pipe, pumps, and valves were USAS B31.7; ASME Sections III and VIII; and the Draft Pump and Valve Code. To identify the correct code for a component it is necessary to research the receiving inspection files (File Q2.321).
XXIII                 6. 1 The construction codes used for Offgas pipe, pumps, and valves were USAS B31.7; ASME Sections III and VIII; and the Draft Pump and Valve Code. To identify the correct code for a component it is necessary to research the receiving inspection files (File Q2.321). There are two reasons that several codes and dates were applied. The first reason is that the Offgas design was changed during Procurement/Construction. The second reason is that the codes were changing rapidly during the period of the design. The project correspondence which records when the Offgas System construction code was changed is given in APED-N62-076.
There are two reasons that several codes and dates were applied. The first reason is that the Offgas design was changed during Procurement/Construction. The second reason is that the codes were changing rapidly during the period of the design. The project correspondence which records when the Offgas System construction code was changed is given in APED-N62-076.
C: \procedur\Tbl3-2-1.kep}}
XXIII
: 4.
1 The construction codes used for Offgas pipe, pumps, and valves were USAS B31.7; ASME Sections III and VIII; and the Draft Pump and Valve Code. To identify the correct code for a component it is necessary to research the receiving inspection files (File Q2.321).
There are two reasons that several codes and dates were applied. The first reason is that the Offgas design was changed during Procurement/Construction. The second reason is that the codes were changing rapidly during the period of the design. The project correspondence which records when the Offgas System construction code was changed is given in APED-N62-076.
XXIII
: 5.
1 The construction codes used for Offgas pipe, pumps, and valves were USAS B31.7; ASME Sections III and VIII; and the Draft Pump and Valve Code. To identify the correct code for a component it is necessary to research the receiving inspection files (File Q2.321).
There are two reasons that several codes and dates were applied. The first reason is that the Offgas design was changed during Procurement/Construction. The second reason is that the codes were changing rapidly during the period of the design. The project correspondence which records when the Offgas System construction code was changed is given in APED-N62-076.
XXIII
: 6.
1 The construction codes used for Offgas pipe, pumps, and valves were USAS B31.7; ASME Sections III and VIII; and the Draft Pump and Valve Code. To identify the correct code for a component it is necessary to research the receiving inspection files (File Q2.321).
There are two reasons that several codes and dates were applied. The first reason is that the Offgas design was changed during Procurement/Construction. The second reason is that the codes were changing rapidly during the period of the design. The project correspondence which records when the Offgas System construction code was changed is given in APED-N62-076.
C: \\procedur\\Tbl3-2-1.kep}}

Latest revision as of 02:21, 13 January 2025

Rev 14 to QA Program Description,Ufsar 17.2 for Duane Arnold Energy Ctr
ML112380576
Person / Time
Site: Duane Arnold NextEra Energy icon.png
Issue date: 06/30/1993
From:
Illinois Power Co
To:
Shared Package
ML112380577 List:
References
NUDOCS 9307210065
Download: ML112380576 (101)
v • d • e


Text

17.2 QUALITY ASSURANCE DURING THE OPERATIONS PHASE 17.

2.0 INTRODUCTION

17.2.0.1 Scope To maintain the high quality of plant systems and equipment during operation, maintenance, repair, modification, and refueling of the Duane Arnold Energy Center (DAEC),

a comprehensive quality assurance program has been implemented.

The objective of this program is to maintain managerial and administrative control over the operations of and activities relative to safety-related structures, systems, equipment, and components during the operating life of the DAEC.

This program is designed to meet the intent of Appendix B to 10 CFR Part 50.

17.2.0.2 Corporate Policy Iowa Electric considers the operation of the DAEC to be an extension of the basic policies established and documented for design, construction, and startup.

The policies and procedures identified within this report regarding "operating phase" will form the basis for plant-life operation of the DAEC.

Where contractors and suppliers are used during the life of the operating DAEC, their function will be controlled by the Operational Quality Assurance Program.

It is the objective of Iowa Electric that the DAEC shall be operated effectively, efficiently, and in such a manner as not to jeopardize the health or safety of the public.

17.2.1 ORGANIZATION 17.2.1.1 Scope Iowa Electric has established an operating organization that is structured to support DAEC operating requirements as well as meet corporate needs in other areas.

This overall organization is described in UFSAR Chapter 13, Conduct of Operations, Section 13.1, Organizational Structure for Iowa Electric.

The organization

chart, which identifies both the "on-site" and "off-site" organizational elements that function under the cognizance of the quality assurance program, appears as Figure 13.1-1, Iowa Electric Corporate Organization.

Chapter 13 describes the quality assurance responsibilities of each of the organizational elements noted on the organization chart.

17.2-1 Revision 14 To be determined 9307210065 930630 1

PDR ADOCK 05000331 P

PDR

Additional detail concerning the Quality Assurance Department is presented in Chapter 17.2, Section 17.2.1.2.

The responsibility and authority for the establishment and execution of the Operational Quality Assurance Program for the operation of the DAEC will be retained by Iowa Electric.

17.2.1.2 Manager, Corporate Quality Assurance The Manager, Corporate Quality Assurance reports to the Vice President - Nuclear and is assigned the primary responsibility for ensuring that quality requirements relative to the safe operation of the DAEC are identified and met.

Fulfilling the responsibilities of the Corporate Quality Assurance Department requires significant communication with the DAEC, the Outage Manager, the Nuclear Licensing Department, the Emergency Planning Department, the Nuclear Fuels Group, the Engineering Department, the Training Department, and the Purchasing Department.

The Manager, Corporate Quality Assurance is responsible for preparing and maintaining the Operational Quality Assurance Program.

The Manager, Corporate Quality Assurance is also responsible for evaluating the effectiveness of the Operational Quality Assurance Program and issuing periodic reports to the appropriate levels of management.

The Manager, Corporate Quality Assurance provides support to the Safety Committee.

17.2.1.2.1 Quality Assurance Procurement Supervisor The Quality Assurance Procurement Supervisor reports to the

Manager, Corporate Quality Assurance and, along with the Quality Control Supervisor and the Quality Assurance Assessment Supervisor, is responsible for verifying that the Operational Quality Assurance Program is being implemented effectively at the DAEC and other locations in support of the DAEC.

The Quality Assurance Procurement Supervisor provides quality assurance support for the procurement of materials and equipment.

Procurement activities include

audits, surveillances, and evaluations of suppliers and contractors for quality capabilities and performance; and maintaining the list of approved suppliers for nuclear procurements.

Procedures for implementation of these functions are prepared and maintained by the Quality Assurance Procurement Supervisor.

17.2-2 Revision 14 To be determined

The Quality Assurance Procurement Supervisor is assisted in the implementation of these responsibilities by the Group Leader, Material and Supplier Quality.

17.2.1.2.2 Quality Assurance Assessment Supervisor The Quality Assurance Assessment Supervisor reports to the Manager, Corporate Quality Assurance and is responsible for evaluating the effectiveness of the Operational Quality Assurance Program through the implementation of the internal audit and surveillance programs; for the implementation of the corrective action and trending program; coordinating the review of divisional procedures that are responsive to the requirements of this Operational Quality Assurance Program; and for the preparation and maintenance of the procedures for which this position is responsible.

The Quality Assurance Assessment Supervisor is assisted in these duties by the Group Leader, Audits, and Group Leader, Surveillance.

17.2.1.2.3 Quality Control Supervisor The Quality Control Supervisor reports to the Manager, Corporate Quality Assurance and, along with the Quality Assurance Procurement Supervisor and the Quality Assurance Assessment Supervisor is responsible for verifying that the Operational Quality Assurance Program is being implemented effectively at the DAEC. The Quality

)

Control Supervisor reviews plant operation, maintenance, modification, and testing documents for inclusion of adequate quality requirements and for inclusion of inspection, witness and hold points; and provides the necessary support to perform the inspections and tests.

The Quality Control Supervisor is responsible for preparing receiving inspection plans and in performing receiving, in-process, and final inspections.

The Quality Control Supervisor is also responsible for the preparation and maintenance of procedures for which the position is

/

responsible.

Responsibilities relative to the Ten Year Inservice Inspection Program include performance of the required examinations and evaluation of indications of defects.

Additionally, the Quality Control Supervisor is responsible for training the Quality Control group in nondestructive examination (NDE) disciplines and interfacing with the Quality Assurance Training Coordinator on other areas requiring training.

The Quality Control Supervisor also supports the DAEC Operations Committee.

17.2-3 Revision 14 To be determined

17.2.1.2.3.1 Corporate Level III NDE The Corporate Level III NDE reports to the Quality Control Supervisor and is responsible for developing and implementing the NDE program, including providing the necessary training.

17.2.1.2.4 Quality Assurance Training Coordinator The Corporate Quality Assurance Department Training Coordinator reports to the Manager, Corporate Quality Assurance and provides training for the Quality Assurance Department.

In addition, training relative to the Operational Quality Assurance Program is provided to the Nuclear Generation Division.

17.2.1.2.5 Stop Work Authority The Manager, Corporate Quality Assurance has the authority to issue a stop work instruction to the organization that has direct responsibility for the work.

Only the Vice President - Nuclear has the authority to overrid e the stop-work instruction.

17.2.2 OPERATIONAL QUALITY ASSURANCE PROGRAM 17.2.2.1 Scope Iowa Electric has established an Operational Quality Assurance Program that applies to those structures, systems, and components, that are safety-related and those activities that affect those structures, systems, and components that are safety-related.

Safety-related structures, systems, and components are those that ensure the integrity of the reactor coolant pressure boundary, shut down the reactor, and maintain the reactor in a safe shut down condition, or prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public.

17.2.2.2 Basis 10 CFR Part 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, and certain regulatory guides, form the basis for the Operational Quality Assurance Program.

Appendix A to UFSAR Chapter 17.2 identifies the particular regulatory guides to which Iowa Electric is committed and which are included in the basis for the Operational Quality Assurance Program.

17.2-4 Revision 14 m

To be determined

17.2.2.3 Identification of Safety-Related Structures, Systems, Components and Items The pertinent requirements of the Operational Quality Assurance Program apply to all activities affecting the safety-related functions of those structures, systems, and components that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public.

A current list of safety-related structures, systems and components is contained in Section 3.2 of the DAEC Updated Final Safety Analysis Report.

This list includes structures, systems, and components identified during the design and construction phase and may be modified as required during operations consistent with their importance to safety.

The list of safety-related structures, systems and components from Section 3.2 of the DAEC Updated Final Safety Analysis Report is further defined in data bases through the assignment of plant specific unique identifiers.

These data bases include items in addition to safety-related structures, systems and components and are maintained by the Manager of Engineering.

17.2.2.4 Operational Quality Assurance Program Implementation The implementation of the Operational Quality Assurance Program by Iowa Electric is directed toward the assurance that operating phase activities and maintenance activities are conducted under controlled conditions and in compliance with applicable regulatory requirements, including 10 CFR Part 50, Appendix B.

Management personnel responsible for the conduct of safety related activities are responsible for providing approved procedures before initiating the activity.

The Iowa Electric Operational Quality Assurance Program is implemented via four levels of documents:

Quality Assurance Manual Nuclear Generation Division Manual Departmental Procedures Departmental Instructions.

17.2.2.4.1 Quality Assurance Manual The Quality Assurance Manual is the highest level internal quality program document that implements UFSAR/DAEC-l Chapter 17.2, Quality Assurance During the Operations Phase.

It is directed to those Iowa Electric organizations responsible for safety-related activities.

The Quality Assurance Manual presents upper management philosophy and concepts to the middle management level, defines organizational responsibilities, and identifies organizational interfaces.

17.2-5 Revision 14 To be determined

17.2.2.4.2 Nuclear Generation Division Manual The Nuclear Generation Division Manual contains procedures that are applicable to more than one department within the division. These divisional procedures provide mechanisms which facilitate the flow of information and documents across departmental lines, and also eliminate the need for separate departmental procedures which address the same subject.

17.2.2.4.3 Departmental Procedures The Departmental Procedures are organizationally unique documents that describe the activities of each department within Iowa Electric that has responsibilities for the operation, maintenance, or modification of the DAEC. The Departmental Procedures specify how to accomplish a specific activity.

17.2.2.4.4 Departmental Instructions The Departmental Instructions are unique to the department and activity for which they have been prepared.

Departmental Instructions provide the specific, detailed information necessary to perform an activity.

Departmental Instructions are issued at the discretion of the responsible manager and are not required for all activities.

17.2.2.5 Control of Iowa Electric Suppliers Iowa Electric may employ the services of architect-engineers, NSSS suppliers, fuel fabricators, constructors, and consultants to augment Iowa Electric capabilities.

These organizations are required to work under a quality assurance program to provide the control of quality activities consistent with the scope of their assigned work.

The quality assurance programs of such organizations are subject to review, evaluation, and acceptance by the Iowa Electric Corporate Quality Assurance Department before the initiation of activities affected by the program.

17.2.2.6 Indoctrination and Training The indoctrination, training, and retraining of personnel who participate in safety-related activities are provided in five broad areas:

operator training, quality assurance indoctrination, technical training, radiation safety indoctrination and training, and emergency preparedness training.

The Operator training provided to senior reactor operators and reactor operators is under the cognizance of the Plant Superintendent -

Nuclear and Manager, Nuclear Training.

17.2-6 Revision 14 To be determined

The quality assurance indoctrination provided to Iowa Electric personnel is under the cognizance of the Manager, Corporate Quality Assurance and the Manager, Nuclear Training.

The technical training provided to Iowa Electric engineering personnel is under the cognizance of the Manager of Engineering and 4

the Manager, Nuclear Training. The training may be provided in a number of ways, from self-study courses to formalized courses at the DAEC Training Department and educational institutions.

Indoctrination and training provided to Iowa Electric personnel and contract personnel relative to performing work in areas that are potentially hazardous because of radioactivity are under the cognizance of the Radiation Protection Manager and the Manager, 4

Nuclear Training.

The indoctrination and training provided to Iowa Electric personnel and contract personnel relative to emergency preparedness is under the cognizance of the Manager, Emergency Planning and the Manager, Nuclear Training.

17.2.2.7 Management Review and Audit The status of the Iowa Electric Operational Quality Assurance Program is periodically made known to management.

A periodic report is prepared by the Manager, Corporate Quality Assurance and submitted to the Vice President -

Nuclear.

An annual audit of the Operational Quality Assurance Program is conducted to evaluate the effectiveness of the overall program.

Direction for these audits alternates between the Vice President Nuclear and the Safety Committee.

The Safety Committee audit is in accordance with the Technical Specifications requirement for a biennial audit of the quality assurance program.

These alternating audits complement each other and provide an annual evaluation.

17.2.3 DESIGN CONTROL 17.2.3.1 Scope The

design, modification,
addition, and replacement of safety-related structures, systems, and components at the DAEC is controlled to ensure that appropriate measures are implemented and to ensure that "as-built" quality is not degraded.

The plant design is defined by Iowa

Electric, the NSSS
supplier, architect/engineer, and selected suppliers.

Design drawings and specifications illustrate the general arrangement and details of safety-related structures, systems, and components and define the requirements for ensuring their continuing capability to perform their intended operational or safety design function.

17.2-7 Revision 14 To be determined

Design activities include the correct translation of regulatory requirements and design bases into specifications, drawings, written procedures, and instructions that define the design.

Design analyses regarding reactor physics, stress, seismic, thermal, hydraulic, radiation, and accident analyses used to produce design output documents are performed when appropriate.

Design verification is performed.

Procedures establish requirements, assign responsibilities, and provide control of design activities to ensure performance in a

planned, controlled, and orderly manner.

17.2.3.2 Design Responsibility The design and engineering effort is the responsibility of the Engineering Department within the Nuclear Generation Division.

Assistance may be provided by other engineering organizations; individuals providing that assistance are required to perform their activities in compliance with the Iowa Electric Operational Quality Assurance Program.

The design of nuclear fuel reloads is the responsibility of the Nuclear Fuels Group.

17.2.3.3 Design Criteria Design requirements and changes thereto are identified, documented, reviewed, and approved to ensure the incorporation of appropriate quality standards in design documents.

Design requirements and quality standards are described to an appropriate level of detail in design criteria.

Any exception to quality standards will be listed. Criteria for modifications to structures,

systems, and components will consider, as a minimum, the design bases described in the UFSAR.

All design criteria will be satisfied in the design.

17.2.3.4 Design Process Controls The organization performing design will have the responsibility for design control unless specified otherwise. The control of design will be specified in procedures.

These procedures will include instructions for defining typical design requirements; communicating needed design information across internal and external interfaces; preparing, reviewing, approving, releasing, distributing,

revising, and maintaining design documents; performing design reviews; and controlling field changes.

Design control involves measures that include a definition of design requirements; a design process that includes design analysis and the delineation of requirements through the issuing of drawings, specifications, and other design documents (design outputs); and design verification.

17.2-8 Revision 14 To be determined

The design process establishes controls for releasing technically adequate and accurate design documents in a controlled manner with a timely distribution to responsible individuals and groups.

Documents and revisions are controlled through the use of written procedures that apply to the issuer, distributor, and user to prevent inadvertent use of superseded documents.

Document control procedures govern the collection, storage, and maintenance of design documents, results of design document reviews, and changes thereto. Design documents subject to procedural control include, but are not limited to, specifications, calculations, computer programs, the UFSAR when used as a design document, and drawings, including flow diagrams, piping and instrument diagrams, control logic diagrams, electrical single-line diagrams, structural systems for major facilities, site arrangements, and equipment locations.

17.2.3.5 Design Interface Control Design interfaces with external and internal organizations participating in the design are controlled. The design interface measures ensure that the required design information is available in a timely fashion to the organization(s) responsible for the design.

17.2.3.6 Design Verification The applicability of previously proven designs, with respect to meeting pertinent design

inputs, including environmental conditions, will be verified for each application.

Where the design of a particular structure, system, or component for a specific application has been subjected to a previous verification process, the verification process need not be duplicated for subsequent identical applications.

However, the original design and verification will be documented and referenced for the subsequent application.

When changes to previously verified designs have been made, design verification will be required for the changes, including an evaluation of the effects of those changes on the overall design.

Design verification will be performed by competent individuals who:

have not participated in the original design but may be from the same organizational entity, do not have immediate supervisory responsibility for the individual performing the design, have not specified a singular design approach, have not ruled out certain design considerations, and 17.2-9 Revision 14 To be determined

have not established the inputs for the particular design aspect being verified.

Under exceptional circumstances, the design verification may be performed by the originator's supervisor provided:

the supervisor is the only technically qualified individual in the organization competent to perform the verification, the need is individually documented and approved in advance by the supervisor's management, and QA audits cover the frequency of occurrence and effectiveness of the supervisor as design verifier to guard against abuse.

Cursory supervisory reviews do not satisfy the intent of providing a design verification.

If errors or deficiencies in the design process are detected during the design verification cycle or during audits, resolution of errors and deficiencies will be the responsibility of the design engineer, who must provide documented evidence of resolution to the appropriate levels of management.

Acceptable verification methods include, but are not limited to, any one or a combination of the following:

1.

Design reviews

2.

Alternative or simplified calculational methods

3.

Performance of suitable qualification testing.

The method selected will consider the item's complexity, previous operational experience, and importance to safety.

The results of the design verification efforts will be clearly documented, with the identification of the verifier clearly indicated and filed.

The documentation of results will be auditable against the verification methods identified by the responsible design organization.

17.2.3.6.1 Design Reviews Design reviews will be sufficient to verify the appropriateness of the design

input, including assumptions, design bases and applicable regulations, codes and standards, and that the design is adequate for the intended application of the design.

17.2-10 Revision 14 To be determined

Design reviews can range from multi-organization reviews to single-person reviews.

The depth of review can range from a detailed check of the complete design to a limited check of the design approach, calculations, and results obtained.

17.2.3.6.2 Calculations Alternative, simplified calculations can be made, or a check of the original calculations may be performed, to verify the correctness of the original calculation.

Where computer programs are used, the program verification will be documented and the inputs shall be considered in the design review.

17.2.3.6.3 Qualification Testing Design verification for some designs or specific design features may be achieved by suitable qualification testing of a prototype or initial production unit.

In those cases where the adequacy of a design is to be verified by a qualification test, the testing will be identified and documented.

Testing will demonstrate the adequacy of performance under conditions that simulate the most adverse design conditions.

17.2.3.7 Changes To Design Documents Changes to design documents receive a review and approval process as equivalent to original design documents.

Design documents issued by the original architect-engineer, NSSS supplier, and other organizations may be changed and revised by the responsible design organizations within Iowa Electric or contracted by Iowa Electric.

17.2.3.8 Independent Review Committees Independent of the responsibilities of the design organization, the requirements of the Operations Committee and the Safety Committee, as specified in the Technical Specifications, will be satisfied.

17.2.4 PROCUREMENT DOCUMENT CONTROL 17.2.4.1 Scope Procurement document control applies to documents employed to procure safety related materials, parts, components, and services required to modify, maintain, repair, test, inspect, or operate the DAEC.

Iowa Electric controls procurement documents by written procedures that establish requirements and assign responsibility for measures to ensure that applicable regulatory requirements, design bases, and other requirements necessary to ensure quality are included in documents employed for the procurement of safety related materials, parts, components, and services.

17.2-11 Revision 14 To be determined

17.2.4.2 Procurement Responsibility The responsibility for the initiation of a purchase requisition is that of the organization that ultimately has the responsibility for the procurement.

17.2.4.3 Quality Classification Each item or service to be procured is evaluated by the Engineering Department to determine whether or not it performs a safety-related function or involves activities that affect the function of safety-related materials, parts, or components and to appraise the importance of this function to plant or public safety. For those cases where it is unclear if an individual piece (that is, part of a safety-related structure, system, component, or service) is governed by the Operational Quality Assurance Program, an engineering evaluation will be conducted.

The evaluation will classify the safety relationship of the service or questionable component parts or items of safety-related structures, systems, or components.

17.2.4.4 Quality Requirements in Procurement Documents Procurement document control measures will ensure that appropriate regulatory requirements, design bases, and other requirements are included in the procurement process.

Originating and reviewing organizations shall require that the following be included or invoked by reference in procurement documents, as appropriate:

1.

Requirements that the supplier provide a description of his quality assurance program that implements the applicable criteria of 10 CFR Part 50, Appendix B, and that is appropriate for the particular type of item or service to be supplied. Certain items or services will require extensive controls throughout all stages of manufacture or performance, while others may require only a limited control effort in selected phases.

2.

Basic administrative and technical requirements, including drawings, specifications, regulations, special instructions, applicable codes and industrial standards, and procedural requirements identified by titles and revision levels; special process instructions; test and examination requirements with corresponding acceptance criteria; and special requirements for activities such as designing, identifying, fabricating, cleaning, erecting, packaging, handling, shipping, and storing.

17.2-12 Revision 14 To be determined

3.

Requirements for supplier surveillance, audit, and inspection, including provisions for Iowa Electric access to facilities and records and for the identification of witness and hold points.

4.

Requirements for extending applicable requirements to lower-tier suppliers and subcontractors.

These requirements will include right-of access by Iowa Electric to sub-supplier facilities and records.

5.

Requirements for the supplier to report certain nonconformances to procurement document requirements and conditions of their disposition.

6.

Documentation requirements, including records to be prepared, maintained, submitted, or made available for

review, such as drawings, specifications, procedures, procurement documents, inspection and test records, personnel and procedural qualifications, chemical and physical test results, and instructions for the retention and disposition of records.
7.

Requirements for supplier-furnished records.

8.

Applicability of the provisions of 10 CFR Part 21 for safety-related items, to the extent that a loss of their function may cause potential substantial safety hazards.

Certain items, as off-the-shelf items, will be exempt from this requirement.

9.

Requirements for packaging and transportation as necessary to prevent degradation during transit.

17.2.4.5 Acquisition from Other Licensed Nuclear Power Plants Items may be procured from another NRC licensed nuclear power plant provided the Iowa Electric purchase specification is equivalent to that of the other utility, and the quality assurance requirements of Iowa Electric have been satisfied.

If the item was originally procured by the other utility as a "basic component" as defined in 10 CFR Part 21, the reporting requirements of the regulation are transferred to Iowa Electric Light and Power Company.

Iowa Electric Light and Power Company shall notify the original supplier in writing of this item(s) change in ownership to ensure appropriate 10 CFR Part 21 reporting from the original supplier.

17.2-13 Revision 14 To be determined

17.2.5 INSTRUCTIONS, PROCEDURES, AND DRAWINGS 17.2.5.1 Scope Instructions, procedures, and drawings will be generated to provide direction and guidance to ensure that safety-related activities are performed correctly.

The need for, content of, and depth of detail of the instructions, procedures, and drawings will be consistent with the importance and complexity of that activity.

17.2.5.2 Content The content of the instructions, procedures, and drawings will be appropriate to the activities being performed.

Instructions and procedures will include, as appropriate, scope or purpose, responsibilities of individuals performing the work, the information needed, and required output and acceptance criteria.

Drawings will be prepared using industrially accepted standards.

17.2.5.3 Issuance The organization responsible for the activity being described is responsible for the issuance of the instructions, procedures, and drawings.

The instructions, procedures, and drawings will be issued before the commencement of the activity to be controlled by that instruction, procedure, and drawing.

Once instructions, procedures, and drawings have been approved and issued for use, the activities will be performed in accordance with the documents.

If the activity cannot be accomplished, the document will be formally revised to reflect the manner in which the activity is to be performed.

Revised instructions, procedures, and drawings will be reviewed and approved by the same organizations and individuals (or equivalent positions) that reviewed and approved the original document.

17.2.6 DOCUMENT CONTROL 17.2.6.1 Scope The organization responsible for the documents will establish measures to ensure that the documents, including changes, are reviewed for adequacy, are approved for release by authorized 17.2-14 Revision 14 To be determined

personnel, are distributed to and used at the location where the prescribed activity is performed, and are controlled.

17.2.6.2 Preparation The organization responsible for the initiation of the document is responsible for the issuance of the document.

The organization that issues controlled documents will establish administrative techniques that define the documents to be controlled, identify the current revision or issue of the document, and identify the individuals who are to receive the document.

The types of documents that are controlled by Iowa Electric include the following:

1.

Specifications

2.

Drawings

3.

Procurement documents

4.

Quality Assurance Manual

5.

Nuclear Generation Division Manual

6.

Departmental Procedures

7.

Safety analysis reports and related design criteria documents

8.

Welding Manual

9.

Computer codes.

17.2.6.3 Review and Approval Documents that are specified as being controlled documents are reviewed to ensure that regulatory, technical, quality assurance, and contractual requirements have been appropriately addressed; that review comments have been considered and resolved; and that the document is approved before issuance and use.

Divisional procedures that are responsive to the requirements of the Operational Quality Assurance Program shall be reviewed and evaluated for concurrence by the Corporate Quality Assurance Department.

The review shall be documented indicating that the procedure is consistent with the quality assurance program and corporate policies.

Revisions will require review and approval by the same organizations (or equivalent) that performed the original review, before the issuance or implementation of the change.

Documents that have been approved by the original designers of the DAEC will be revised by the Iowa Electric Engineering Department.

17.2-15 Revision 14 To be determined

17.2.6.4 Distribution and Use The mechanism for distribution will provide assurance that the controlled document arrives at the point of use; the user will provide assurance that the document to be used is the proper document and revision.

When formal distribution lists are used to prescribe an established distribution, they will be maintained current to reflect changes in assigned responsibilities.

Document transmittals will be reviewed for accuracy and dated and made suitable for transmittal.

The recipient is informed of what is being transmitted and of the status of the documents being transmitted.

An acknowledgment of the receipt of controlled documents by recipients may be required if the organization responsible for the document deems such controls necessary.

The organization responsible for the use of the document will establish administrative controls to provide for positive identification and prevent the loss of such documents.

The administrative controls will have provisions to remove obsolete documents, thereby precluding the possibility that the wrong documents or revisions will be used.

17.2.6.5 Changes to Documents Changes to documents previously released will be

reviewed, approved, dated, and distributed in the same manner as the original document.

Personnel who review changed documents will have access to the original documents, to any written basis or input information, and to any written reason or justification for the change.

When the document that is being changed has been issued by the original designers of the DAEC, then the access to the original documents will depend on the reasonable availability of those documents.

Revised instructions and procedures will reflect the new revision and date and clearly identify the scope or portion of the instruction and procedure being changed.

17.2-16 Revision 14 To be determined

17.2.7 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES 17.2.7.1 Scope Purchased material, equipment, and services are controlled to ensure that the specified technical and quality requirements are obtained.

The responsibility for the control of purchased material, equipment, and services is that of the Corporate Quality Assurance Department in close cooperation with the Engineering Department,

DAEC, and the Purchasing Department.

The technique used for the control of purchased material, equipment and services

includes, as appropriate, source evaluation and selection, objective evidence of quality furnished, inspection at the source, supplier's history of providing a satisfactory product, and examination of the product on delivery.

17.2.7.2 Source Evaluation and Selection Potential suppliers are evaluated.

These evaluations are performed by qualified personnel to determine the capability of the supplier to provide the items or services.

Suppliers are evaluated on the basis of one or more of the following:

1.

Capability to comply with the requirements of 10 CFR 50, Appendix B, applicable to the type of

material, equipment, or service being procured.
2.

Past records and performance for similar procurements to ascertain the capability of supplying a manufactured product or services under an acceptable quality assurance system.

3.

Audits or surveys of supplier's facilities and quality assurance program to determine the capability to supply a product that satisfies the design, manufacturing, and quality requirements.

4.

The certification of the supplier by the ASME.

5.

The results of audits performed by other utilities and consultants.

The supplier's bid proposal is reviewed and evaluated to ensure that the bid is responsive to the procurement documents.

Depending on the importance of the item or service and its importance to safety, a post-award meeting may be held to discuss the requirements of the procurement document.

17.2-17 Revision 14 To be determined

17.2.7.3 Inspection or Surveillance at the Source Subsequent to the award of a

purchase

order, a

surveillance/inspection plan may be prepared.

The extent of the plan will consider the complexity and importance of the item or service, supplier's past performance, and those aspects of the manufacturing process that may not be verified at receipt inspection.

The plan will establish, as appropriate, the frequency of surveillance/inspection; processes to be witnessed, inspected, or verified; the method of surveillance/inspection; and documentation requirements.

Activities specified in the plan will be conducted at the supplier's facilities by qualified personnel using approved procedures that provide for the following as applicable:

1.

Reviewing material acceptability

2.

Witnessing in-process inspections,

tests, and nondestructive examination
3.

Reviewing the qualification of procedures, equipment, and personnel

4.

Verifying that fabrication or construction procedures and processes have been approved and are properly applied

5.

Verifying quality assurance/quality control systems, to the extent necessary

6.

Reviewing document packages for compliance to procurement document requirements, including qualifications, process records, and inspection and test records

7.

Reviewing Certificates of Compliance for adequacy.

8.

Verifying that nonconformances have been properly controlled.

Hold points specified in the procurement document will be complied with and Iowa Electric will be notified in a timely manner when hold points are reached.

A method will be established to provide information relative to the characteristics that have been inspected at the source and the characteristics that are to be inspected on receipt.

17.2-18 Revision 14 To be determined

17.2.7.4 Receipt Inspection Items purchased by Iowa Electric are controlled at the final destination by the performance of a receipt inspection.

The extent of the receipt inspection depends on the importance to safety, the complexity, the quantity of the product or service, and the extent of source inspection, source surveillance or audit that was performed.

Receipt inspection is performed by trained and qualified personnel in accordance with approved procedures and acceptance criteria before the installation or use of the item(s) to preclude the placement or use of nonconforming item(s).

Documentary evidence will demonstrate that materials and equipment conform to the procurement requirements.

If receipt inspection indicates that the item is unacceptable, the item is treated as nonconforming.

17.2.7.5 Post-installation Testing Acceptance by post-installation test may be used following one of the preceding verification methods.

Post-installation testing is used as the prime means of acceptance verification when it is difficult to verify item quality characteristics, the item requires an integrated system check out or test, or the item cannot demonstrate its ability to perform when not in use.

Post installation test requirements and acceptance documentation are established by Iowa Electric.

17.2.8 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS 17.2.8.1 Scope Materials, parts, and components will be identified and controlled to ensure that the correct materials, parts, and components are used during fabrication, manufacture, modification, repair, and replacement.

It is the responsibility of the organization responsible for the engineering design and procurement to include the requirements for proper identification and control in the procurement documents.

It is the responsibility of the supplier for maintaining the traceability of materials,

parts, and components throughout fabrication and shipment.

17.2-19 Revision 14 To be determined

It is the responsibility of the DAEC for maintaining the traceability of materials, parts, and components throughout repair, replacement, modification, and installation.

17.2.8.2 Identification Identification will be applied in locations and by methods that will not affect the fit, function, or quality of the item.

The identification of the item will be maintained by a unique method such as heat number, part number, serial number, batch number, or other appropriate means in a form that is durable and legible.

The identification may be on the item or on records traceable to the item. Where feasible, direct placement of the identification on the item will be by stamping, marking, tags, labels, or other similar methods.

Where direct placement of identification on the item is not feasible, proper controls will be established that ensure direct positive identification of the item.

Where physical identification is either impractical or insufficient, physical separation, procedural control, or other approved means will be employed.

Receipt inspection will verify that identification for received items is complete and accompanied by appropriate documentation.

When an item is subdivided, the identification will be immediately transferred to the sub-parts so that all sub-parts contain the appropriate identification label.

Any identification that will be obliterated or hidden by surface coatings or surface treatments will be reestablished or will be traceable by administrative means.

Standard catalog items or off-the-shelf items may be identified by catalog number or other appropriate designation.

17.2.8.3 Verification and Control The items will be controlled and the identity of the item verified.

Inventory and storage controls will be established at the DAEC to ensure proper traceability of items.

The correctness of the item will be verified on withdrawal from storage and before the initiation of the repair, replacement, and modification.

17.2-20 Revision 14 To be determined

17.2.9 CONTROL OF SPECIAL PROCESSES 17.2.9.1 Scope Special processes are those controlled fabrications, tests, and final preparation processes that require the qualification of procedure, technique, and personnel and that are performed in accordance with applicable codes and standards.

Certain special processes require interim in-process controls in addition to final inspection to ensure quality.

The control of special processes is the joint responsibility of the Engineering Department, the DAEC, and the Corporate Quality Assurance Department.

The Engineering Department is responsible for providing technical expertise relative to materials, metallurgy, welding, brazing, and for providing the related special process procedures.

The Corporate Quality Assurance Department is responsible for providing required nondestructive examinations (NDE) and the associated procedures.

17.2.9.2 General Requirements Measures will be established to ensure that special processes are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable

codes, standards, specifications, criteria, and other special requirements.

Written procedures will be reviewed or prepared before use to ensure that special processes are controlled and accomplished.

These procedures will describe the operations to be performed, the sequence of operations, the characteristics involved, the limits of these characteristics, measuring and test equipment to be used, acceptance criteria, and documentation requirements.

Special processes will be accomplished in accordance with written procedures and process sheets, or their equivalent.

Personnel will be trained and qualified in accordance with applicable codes and standards.

Equipment used to perform special processes or measure or test the product will be qualified, before use, in accordance with applicable codes, standards, specifications, or procedures.

The extent and period of training, qualification, and testing of personnel and equipment will be in accordance with applicable codes, standards, specifications, or procedures.

17.2-21 Revision 14 To be determined

17.2.9.3 Personnel Qualification The personnel who perform nondestructive examinations will be certified to the precise technique to be used and for the proper level of expertise.

A Level III Examiner will be responsible for qualifying and certifying, in accordance with the Iowa Electric Light and Power written

practice, the Iowa Electric personnel who perform nondestructive examinations.

17.2.9.4 Verification and Control The procedures, process sheets, personnel, and equipment will be verified as appropriate, before the initiation of work at the DAEC.

The Corporate Quality Assurance Department will determine that suppliers performing special processes at the DAEC have sufficient controls before the initiation of the work.

The Corporate Quality Assurance Department will determine that DAEC personnel performing special processes have current qualifications.

17.2.9.5 Special Protective Coatings (Paint)

The application of a special protective coating shall be controlled as a special process when the failure (i.e. peeling or spalling) of the coating to adhere to the substrate can cause the malfunction of a Quality Level I structure, system or component. Special process coatings shall be applied by qualified personnel using qualified materials and equipment, and approved procedures.

Documentation shall include identification of the following:

person applying the coating (and qualification) material used procedure used (and qualifying procedure if different) tests performed and results date of application of coating traceability of coating location.

17.2-22 Revision 14 To be determined

17.2.10 INSPECTION 17.2.10.1 Scope A program for the inspection of safety-related activities at the DAEC will be established and executed to verify conformance with applicable documented instructions, procedures, drawings, and specifications.

The responsibility for the inspection of materials, parts, and components affecting quality is that of the Corporate Quality Assurance Department. The inspection program at DAEC will include the following:

1.

Receipt inspection

2.

In-process inspections

3.

Final inspections.

4.

Nondestructive examinations 17.2.10.2 General Requirements A program for the inspection of activities affecting quality will be established and executed by or for the organization performing the activity to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activity.

Inspection will be performed by individuals other than those who performed the activity being inspected.

Inspections will be performed by personnel using appropriate equipment in accordance with applicable codes, standards, and procedures.

Procedures, instructions, or checklists will be established and used that identify the characteristics to be inspected, inspection methods, special devices, acceptance and rejection criteria, methods for recording inspection results, and groups responsible for the inspection. Special preparation, cleaning, and the use of measuring devices will be included.

Inspections will be planned to identify where in the sequence of work each inspection activity will be performed, to what extent, procedures to be used, and mandatory hold or witness points.

Repairs, modifications, or replacements will be inspected in accordance with the original inspection requirements or acceptable alternatives.

Sampling methods and process monitoring will be used when inspection is impossible or disadvantageous.

17.2-23 Revision 14 To be determined

17.2.10.3 Process Monitoring Process monitoring of work activities, equipment, and personnel will be used as a control if inspection of processed items is impossible or disadvantageous.

Both inspection and process monitoring will be provided when control is inadequate without both.

As an alternative, a suitable level of confidence in structures,

systems, or components on which maintenance or modifications have been performed will be attained by inspection.

As appropriate, an augmented inspection program will be implemented until such time as a suitable level of performance has been demonstrated.

The monitoring of processes will be performed to verify that activities affecting quality are being performed in accordance with documented instructions, procedures, drawings, and specifications.

17.2.10.4 In-Service Inspection Required in-service inspection, including nondestructive examination, pressure tests, and in-service tests of pumps and valves, will be planned and executed.

The results of these examinations and tests shall be documented, including corrective actions required and the actions taken.

The basis for the in-service inspection program is the ASME Boiler and Pressure Vessel Code,Section XI, 1980 Edition with Addenda through Winter 1981.

The specific issue and addendum of requirements beyond the base commitment is as specified in 10 CFR Part 50, Section 50.55a(g), except where specific exemptions have been granted by the NRC.

The Engineering Department has the overall responsibility for developing the inspection program, for ensuring compliance with the ASME Code Section XI rules, and for evaluating the inspection results.

The inspection plans shall be updated as required to accommodate the as-built condition of the DAEC.

17.2.10.4.1 Ten Year Inspection Program The Ten-Year Inspection Program includes inspections and tests of those pressure boundary welds and materials as defined in ASME Boiler and Pressure Vessel Code,Section XI.

Also included are the pressure boundary welds and materials that are defined as "Augmented" in-service inspections.

The Ten-Year Inspection Program identifies the welds and items to be examined, the frequency of such examinations, the methods, and confirms the continuing acceptability of the selected welds and items.

17.2-24 Revision 14 To be determined

The Quality Assurance Department has the responsibility for conducting the planned nondestructive examinations (NDE) and providing the services of the Corporate NDE Level III Examiner as required by Code.

17.2.10.4.2 In-service Testing Program The DAEC has the responsibility for conducting the ASME Boiler and Pressure Vessel Code,Section XI, pump and valve tests, system pressure tests, and snubber tests.

These performance tests to verify operational readiness are part of the plant performance program.

17.2.10.5 Personnel Qualification Personnel performing inspections and examinations, or accepting the results of inspections and examinations, will be trained and qualified in accordance with governing codes, standards, and regulations. The personnel will be competent and cognizant of the technical requirements of the work activity. Qualification records will be maintained by the organization responsible for the individual(s) performing the inspections.

17.2.10.6 Documentation and Records Inspection and examination activities will be reported on a form that indicates the date of the activity, identification of inspector or examiner, and rejection or acceptance of the item(s).

17.2.11 TEST CONTROL 17.2.11.1 Scope Testing will be performed at the DAEC to demonstrate that safety-related structures,

systems, and components perform satisfactorily in service.

The testing program will include the following, as appropriate:

1.

Qualification tests for design verification

2.

Proof tests before installation

3.

Pre-Operational tests

4.

Operational tests.

17.2.11.2 General Requirements The tests will be performed in accordance with approved written test procedures that incorporate the requirements and acceptance limits.

The test procedure will identify the item to be tested and the purpose of the test.

17.2-25 Revision 14 To be determined

Test procedures will include provisions for ensuring that all prerequisites for the given test have been met, that adequate test instrumentation is available and used, and that the test is performed under suitable environmental conditions.

The test procedure will incorporate directly, or by reference, the following requirements:

1.

Performance of tests by trained personnel who are qualified in accordance with applicable codes and standards

2.

Verification of test prerequisites

3.

Identification and description of acceptance or rejection criteria

4.

Instructions for performing the test.

17.2.11.3 Surveillance Testing Provisions will be established for the performance of surveillance testing to ensure that the necessary quality of systems and components is maintained, that facility operations are within the safety limits, and that limiting conditions of operation can be met.

The testing frequency will be at least as frequent as prescribed in the Technical Specifications.

The provisions for surveillance testing will include the preparation of schedules that reflect the status of planned surveillance tests. Qualified plant staff will perform surveillance tests.

17.2.11.4 Personnel Qualification Personnel performing testing will be trained and qualified.

The personnel will be competent and cognizant of the technical requirements of the work activity.

17.2.11.5 Documentation and Records Test procedures and results will be documented and approved by qualified personnel.

Test results shall be documented and indicate that the prerequisites and other test requirements have been met.

17.2-26 Revision 14 To be determined

17.2.12 CONTROL OF MEASURING AND TEST EQUIPMENT 17.2.12.1 Scope The responsibility for the control of measuring and test equipment and permanently installed plant instrumentation, is that of the DAEC.

The control measures will include the identification and calibration of the equipment to the activity.

The requirements contained within this section do not apply to devices for which normal industry practice provides adequate control, that is, tape measures, rulers, and measuring glasses.

17.2.12.2 General Requirements Measures will be established for the control, calibration, and adjustment of measuring and testing devices.

Calibration intervals will be based on required accuracy, the use of equipment, stability characteristics, or other factors affecting the measurement.

The following requirements will be specified in written procedures that are used to control measuring and test equipment:

1.

Identification of equipment and traceability to calibration data

2.

Calibration methods, frequency, maintenance, and control

3.

Labeling and marking of portable equipment to indicate due date for next calibration.

Due dates for permanently installed plant equipment are controlled by means of a central record system.

4.

Provisions for determining the validity of previous measurements when equipment is determined to be out of calibration.

5.

Traceability of reference and transfer standards to nationally recognized standards.

When national standards do not exist, the basis for calibration shall be documented.

Calibration may be performed at the DAEC or by qualified laboratories using competent personnel.

Equipment that is consistently found to be out of calibration shall be repaired or replaced.

17.2-27 Revision 14 To be determined

When the accuracy of the measuring or test device can be adversely affected by environmental conditions, special controls will be prescribed to minimize such effects.

17.2.12.3 Traceability The measuring and test equipment will be traceable to the item on which the equipment has been used.

When calibration, testing, or other measuring devices are found to be out of calibration, an evaluation shall be made and documented concerning the validity of previous tests and the acceptability of devices previously tested from the time of the previous calibration.

17.2.13 HANDLING, STORAGE, AND SHIPPING 17.2.13.1 Scope The handling,

storage, shipping, cleaning, and preservation of material and equipment will be controlled to prevent damage, deterioration, and loss.

It is the responsibility of the organization initiating procurement to specify any special instructions and requirements for packaging and handling, shipping, and extended storage.

It is the responsibility of the DAEC to provide for the proper handling and storage of material and equipment upon receipt and throughout repair, replacement, and modification.

17.2.13.2 General Requirements Measures will be established to control the handling,

storage, shipping, cleaning, and preservation of material and equipment in accordance with work and inspection instructions to prevent damage or deterioration.

When necessary for particular products, special protective environments such as inert gas atmosphere, temperature levels, and specific moisture-content levels will be specified and provided.

Consistent with the need for preservation, material and equipment will be suitably cleaned to prevent contamination and degradation.

The cleaning method selected will in itself not damage or contaminate the material or equipment.

17.2-28 Revision 14 To be determined

17.2.13.3 Shipping When required to prevent contamination or to prevent damage during

shipment, special packaging methods will be specified and implemented.

Special-handling requirements, if required, will be specified in the shipping instructions.

The package should be appropriately marked to indicate that special handling or storage requirements are necessary.

Markings of packages will conform to applicable Federal and state regulations.

17.2.13.4 Radioactive Materials Measures will also be established to control the shipping of licensed radioactive materials in accordance with 10 CFR Part 71.

These measures will apply to the use of shipping containers only, and not to the design and fabrication of shipping containers for which an NRC certification is required under Part 71.

17.2.13.5 Handling The requirements for special handling will be considered when the item is moved from the receipt point to the storage area and from the storage area to the point of use. Special-handling equipment will be periodically tested and inspected.

17.2.13.6 Storage Materials and equipment will be stored to minimize the possibility of damage or lowering of quality from the time an item is stored on receipt until the time the item is removed from storage.

The manufacturers' recommendations are considered; however, the relaxation of manufacturers' storage requirements may be implemented if the storage recommendations are not reasonably necessary to preclude equipment degradation.

Material and equipment will be stored at locations that have a designated storage level.

The various storage levels will be defined and will have prescribed environmental conditions. The storage conditions will be in accordance with design and procurement requirements to preclude damage, loss or deterioration due to harsh environmental conditions.

Items having limited shelf life will be identified and controlled to preclude the use of items whose shelf life has expired.

17.2-29 Revision 14 To be determined

17.2.14 INSPECTION, TEST, AND OPERATING STATUS 17.2.14.1 Scope Measures will be established to ensure that necessary inspections of items have not been inadvertently bypassed or that systems or components are not inadvertently operated.

17.2.14.2 General Requirements Measures will be established to indicate, by the use of marking such as stamps, tags, labels, routing cards, log books, or other suitable means, the status of inspection, test and operating status of individual structures, systems, or components.

Procedures will provide for controls to preclude the inadvertent use of nonconforming, inoperative, or malfunctioning structures, systems, or components.

The procedures will include the following:

1.

Identification of authority for application and removal of status indicators

2.

The use of specific status indicators

3.

Provisions for maintaining the status of the structures, systems, or components until removed by an appropriate authority.

17.2.14.3 Inspection and Test Status Measures will be established to provide for the identification of items that have satisfactorily passed required inspections and tests.

Only items that have passed inspection or testing will be used in the manufacture or installation of an item.

Documented procedure requirements will include the following:

1.

Maintenance of the status of the item throughout fabrication and installation

2.

Use of status indicators such as stamps, tags, markings, or labels either on the items or on documents traceable to the items 17.2-30 Revision 14 To be determined

3.

Provisions for controlling the bypassing of required inspections, tests, and other critical operations.

Items at the DAEC will be identified by status indicators to indicate whether they are awaiting inspection, acceptable for use, unacceptable, or in a hold status pending further evaluation.

17.2.14.4. Operating Status Procedures relating to the operational status of safety-related structures,

systems, and components, including temporary modifications, will include the following:
1.

Authorization for requesting that equipment be removed from service

2.

Checks that must be made before approving the request

3.

Approval of the action to remove the equipment from service

4.

The actions necessary to isolate the equipment and responsibility for performing these actions

5.

The actions necessary to return the equipment to its operating status and responsibility for these actions.

Equipment and systems in a controlled status will be identified.

Plant procedures will establish controls to identify the status of inspection and test activities associated with maintenance, instrumentation, and control system calibration and testing. The status of nonconforming, inoperative, or malfunctioning structures, systems, and components will be documented and identified to prevent inadvertent use.

The Technical Specifications establish the status required for safe plant operation, including provisions for periodic and non-periodic tests and inspections, of various structures,

systems, and components.

Periodic tests may be operational tests or tests following maintenance, and non-periodic tests may be made following repairs or modifications.

17.2.14.5 Sequence Change Control Procedures will include the control of the sequence of required tests, inspections, and other operations when important to safety.

To change these controls, the individual procedure must be changed, which requires the same review and approval cycle as that which authorized the original procedure.

17.2-31 Revision 14 To be determined

17.2.15 NONCONFORMING MATERIALS, PARTS, OR COMPONENTS 17.2.15.1 Scope The nonconformance reporting system is established to control materials, parts or components which do not conform to requirements in order to prevent their inadvertent use or installation.

The responsibility for identification, documentation and segregation of nonconforming materials, parts, or components and notification to affected organizations, is that of the Corporate Quality Assurance Department.

The responsibility for the disposition of the nonconforming materials, parts, or components is that of the Engineering Department, DAEC, and the Corporate Quality Assurance Department.

17.2.15.2 Identification and Segregation The identification and segregation will be sufficient to prevent inadvertent use or installation of the nonconforming item.

Material, parts, or components for which nonconformances have been identified will be immediately segregated, when practical, in areas that are reserved for nonconforming items.

When segregation is impractical, administrative measures will be used, such as tagging, roping off the area, etc.

17.2.15.3 Reporting and Disposition The reporting mechanism will provide the means to disposition the nonconforming material, part, or component.

The 'nonconformance report will identify the item, describe the nonconformance, and contain sufficient information to evaluate the nonconformance. The nonconformance report will be transmitted to the proper organization(s) for evaluation and disposition.

17.2.15.4 Disposition The disposition will be limited to one of the following:

use-as-is, rework to original requirements, repair to an acceptable condition, or reject.

For disposition of use-as-is and repair, a technical justification will provide assurance that the item will function as originally intended.

Items that are to be repaired or reworked will be required to be reinspected or retested to determine that the original or new acceptance criteria have been satisfied.

17.2-32 Revision 14 To be determined

17.2.16 CORRECTIVE ACTION 17.2.16.1 Scope Corrective action control measures will be established to ensure that conditions adverse to quality are promptly identified, reported, and corrected.

Corrective action is necessary to correct omissions and problems in the Operational Quality Assurance Program.

17.2.16.2 Conditions Adverse to Quality Conditions adverse to quality will be identified promptly and corrected as soon as practical.

Conditions adverse to quality may be identified by a number of techniques such as:

1.

Audits of Iowa Electric by regulatory agencies

2.

Internal audits

3.

Audits of suppliers by Iowa Electric

4.

Quality Assurance surveillance activities

5.

Management reviews

6.

Nonconformance reports.

Each of the above techniques has a mechanism to effect the correction of the condition adverse to quality.

17.2.16.3 Significant Conditions Adverse to Quality The Corporate Quality Assurance Department will perform an analysis of conditions adverse to quality to determine if a significant condition adverse to quality exists.

The Corporate Quality Assurance Department will perform an analysis to determine if there are any broad programmatic problem areas or if any negative trends are detectable.

This analysis will be performed at least annually and will be reported to the appropriate levels of management.

The analysis will be documented and retained as a quality assurance record.

Significant conditions adverse to quality that impede the implementation or reduce the effectiveness of the program will be controlled.

These conditions will be reported to appropriate management and evaluated.

The cause of a significant condition adverse to quality shall be determined, and corrective action will be taken to preclude repetition.

Significant adverse conditions may include a recurring condition for which past corrective action has been ineffective, significant trends adverse to quality, or significant Operational Quality Assurance Program deficiencies.

17.2-33 Revision 14 To be determined

17.2.16.4 Reporting of 10 CFR 21 Defects and Non-compliances A 10 CFR 21 defect and noncompliance is defined as one which could reasonably indicate a potential substantial safety hazard.

A procedure has been established and posted so that Iowa Electric employees will be aware of the methods by which 10 CFR 21 defects and non-compliances are reported to the NRC.

The President and Chief Operating Officer and the Vice President Nuclear, are designated as the Iowa Electric officers responsible for reporting defects and non-compliances, as appropriate, to the NRC.

17.2.17 QUALITY ASSURANCE RECORDS 17.2.17.1 Scope Quality assurance records will be prepared, identified, collected, and protected so that adequate evidence of activities affecting quality is available.

17.2.17.2 Preparation and Identification of Quality Assurance Records The organization responsible for the activity will also be responsible for the preparation and identification of the quality assurance records that attest to the quality of that activity.

As a general criterion, those documents that reflect the as-built condition of an item, component, system, or plant, and those documents that attest to the quality of an activity, item, structure, or system will be treated as quality assurance records.

Also, the qualification records of inspection, examination and testing personnel, and quality assurance audit personnel, are classified as quality assurance records.

Quality assurance records will be legible, accurate, and complete.

17.2.17.3 Collection and Protection of Quality Assurance Records The quality assurance records will be collected,

indexed, classified, and protected.

The organization that generates the quality assurance record will be responsible for collecting the records. The collected quality assurance records will be classified as either lifetime or non permanent quality assurance records.

The lack of a classification will mean that the quality assurance record is a lifetime record.

17.2-34 Revision 14 To be determined

The quality assurance records that have been identified and collected will be suitably protected against fire, theft, and damage.

The manner in which the records are protected will be consistent with the retention period.

17.2.17.4 Record Storage on Optical Disks Records may be stored on an optical disk storage system which utilizes a write once read many (WORM) system. The image of each record shall be placed onto two optical disks, with verification of the image on each record. Should any of the images be illegible, the hard copy record is maintained as the record.

One optical disk shall be used for on-line access and the second optical disk shall be stored in a records storage facility meeting the requirements for single copy storage or in a separate remote location meeting the requirements of Iowa Electric's commitment to ANSI N45.2.9 1974.

To ensure permanent retention of records, the records stored on an optical disk are acceptably copied onto a new optical disk before the manufacturer's certified useful life of the original disk is exceeded. Records copied shall be verified.

Periodic random inspections of images stored on optical disks are performed to verify that there has been no degradation of image quality.

Should it become necessary to replace the optical imaging system with a new system which is not compatible, the records stored on the old system shall be converted onto the new system prior to the old system being taken out of service.

This conversion process shall include a verification of the records converted.

17.2.17.5 Transfer or Destruction of Records The organization responsible for the quality assurance record will be responsible for the transfer of that quality assurance record for the purposes of microfilming and/or lifetime storage.

The transfer of quality assurance records from one organization to another organization will be accomplished by a formal mechanism that provides for the acceptance of the quality assurance record.

The destruction of quality assurance records will be accomplished only with the approval of the concerned organizations.

17.2-35 Revision 14 To be determined

17.2.18 AUDITS 17.2.18.1 Scope A comprehensive audit program will be established and implemented.

The audit program will be sufficient to verify compliance with the Operational Quality Assurance Program and to determine the effectiveness of the Operational Quality Assurance Program.

The responsibility for the audit system will be that of the Corporate Quality Assurance Department, the Safety Committee, and the Vice President -

Nuclear.

17.2.18.2 Audit System The audit system will be applied to those organizations, both external and internal to Iowa Electric, that are involved in safety-related activities.

17.2.18.2.1 External Organizations The audit program for suppliers is the responsibility of the Corporate Quality Assurance Department. Audits will be scheduled at a frequency commensurate with the status and importance of the activity.

In general, the audit schedule will be responsive to the performance of audits before the initiation of an activity to ensure that the proper controls are in place, during the early stages of the activity to determine that the proper controls are being implemented, and near the end of the activity to determine that all specified requirements have been met.

In general, the audit schedule will also include the performance of audits during the activity, assuming that the activity occurs over a sufficient length of time, to determine that the proper controls are being applied and no problems are occurring.

17.2.18.2.2 Internal Organizations The audit program for the internal Iowa Electric organizations is the responsibility of the following:

1.

The Corporate Quality Assurance Department, to determine the compliance of the other organizations to the Operational Quality Assurance Program and to evaluate performance.

17.2-36 Revision 14 To be determined

2.

The Safety Committee, to determine the compliance of the DAEC to the Technical Specification requirements and license provisions and to evaluate performance.

3.

The Vice President -

Nuclear, to determine the overall effectiveness of the Operational Quality Assurance Program.

The audit schedule will cover the total Iowa Electric audit activities over a period of time not exceeding two years.

17.2.18.3 Personnel Training and Qualification The personnel who participate in audits will have sufficient experience and/or training to fulfill their role in the audit.

Personnel who perform as Lead Auditors will be trained, qualified, and certified.

A Lead Auditor will review the experience of each potential team member, determine their acceptability to perform the audit, determine if any additional training is required, and ensure that the additional training is performed if required.

17.2.18.4 Performance of Audit The selected audit team shall collectively have experience or training commensurate with the total scope of the audit.

Audit checklists will be developed for the total scope of the audit. The audit should be initiated by a pre-audit conference to introduce the audit team and to confirm the scope and plan of the audit and be concluded with a post-audit conference.

During the post-audit conference, the Audit Team will discuss the audit findings and clarify misunderstandings.

17.2.18.5 Report and Closeout of Audit Findings The audit will be documented by an audit report signed by a Lead Auditor.

The audit report shall be sent to the responsible management of the audited organization.

The audit findings will be tracked to ensure that corrective action has occurred.

The Corporate Quality Assurance Department will evaluate the responses to the audit findings.

The evaluation will include the necessity for re-audits, submittal of documentation, or any other means of verifying the corrective action.

Statements by the 17.2-37 Revision 14 To be determined

audited organization that define the corrective action may be accepted.

The corrective actions will be tracked to ensure that proper and timely corrective actions have occurred prior to closure of the audit findings.

Inadequate or unresponsive corrective action will be brought to the attention of appropriate levels of management.

Proced/UFSAR17-2.R14 17.2-38 Revision 14 To be determined

Iowa Electric Light and Power Company Appendix A to UFSAR/DAEC-l Chapter 17.2 QUALITY ASSURANCE DURING THE OPERATIONS PHASE Quality Assurance Program Description (QAPD)

INTRODUCTION This Appendix describes the manner by which the Iowa Electric Operational Quality Assurance Program for the Duane Arnold Energy Center (DAEC), as set forth in the Quality Assurance Program Description (QAPD), UFSAR Chapter 17.2, conforms to NRC Regulatory Guides listed in the June 6, 1990, letter from Region III (Miller) to Iowa Electric (Liu) and certain other commitments previously contained in Table 2-1 of the Quality Assurance Manual.

Comments and clarifications to these specific commitments are identified in this Appendix.

Iowa Electric's position on each ANSI standard which is endorsed by a Regulatory Guide to which Iowa Electric is committed is stated in either the UFSAR or the QAPD.

Other ANSI standards are not requirements for Iowa Electric even if they are listed as references in a standard endorsed by a Regulatory Guide to which Iowa Electric is committed.

(Such standards may, of course, be used as guidance.)

However, a section of a standard which is specifically referred to in a standard endorsed by a Regulatory Guide to which Iowa Electric is committed is a requirement for Iowa Electric unless an exception is stated.

Iowa Electric is not committed to ANSI N45.2 for the operational phase.

Regulatory Guide 1.33, Revision 2, Section B, "Discussion" states ANSI N18.7-1972, along with ANSI N45.2-1971, "Quality Assurance Program Requirements for Nuclear Power Plants",

was endorsed by Regulatory Guide 1.33.

The dual endorsement was necessary in order for the guidance contained in the regulatory guide to be consistent with the requirements of Appendix B to 10 CFR Part 50; however, this dual endorsement caused some confusion among users.

To clarify this situation, ANSI N18.7-1972 was revised so that a single standard would define the general quality assurance program "requirements" for the operation phase.

This revised standard was approved by the American National Standards Committee N18, Nuclear Design Criteria.

It was subsequently approved and designated N18.7-1976/ANS-3.2, "Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants",

by the American National Standards Institute on February 19, 1976.

Therefore, for the operations phase, where a standard endorsed by a Regulatory Guide refers to the use of ANSI N45.2 in conjunction with that Standard, Iowa Electric inserts the ANSI Standard N18.7-1976.

17.2 A-1 Revision 14 To be determined

1.0 REGULATORY GUIDE 1.8, "Personnel Selection and Training" COMMENTS AND CLARIFICATIONS:

Iowa Electric complies with the Regulatory Position of this Regulatory Guide with the following clarifications:

1.1 Iowa Electric's commitment is to Regulatory Guide 1.8, Revision 1-R, September 1975 (reissued May 1977), which endorses ANSI N18.1-1971. However, the Iowa Electric commitment is to ANSI/ANS 3.1-1978, which is a revision of N18.1-1971.

1.2 With respect to selection and training of security personnel, Iowa Electric does not commit to the standard [ANSI N18.17-1973 (ANS 3.3)] referred to in ANSI/ANS 3.1-1978, Sections 1

(Scope) and 6

(References).

The Iowa Electric training and qualification plan for security personnel complies with 10 CFR Part 73, Appendix B.

2.0 REGULATORY GUIDE 1.26, "Quality Group Classifications and Standards for Water-,

Steam-,

and Radioactive-Waste Containing Components of Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:

The Iowa Electric commitment to Safety Guide 26 (3/23/72),

Quality Group Classifications and Standards, is stated in UFSAR Chapter 1.8, Conformance to NRC Regulatory Guides.

3.0 REGULATORY GUIDE 1.28, "Quality Assurance Program Requirements (Design and Construction)"

COMMENTS AND CLARIFICATIONS:

This Regulatory Guide (Safety Guide 28, dated June 7, 1972) endorses ANSI N45.2 and is not applicable to the operating phase.

DAEC's operational QA program is based on Regulatory Guide 1.33, Rev. 2, as stated in UFSAR Section 1.8.

4.0 REGULATORY GUIDE 1.29, "Seismic Design Classification" COMMENTS AND CLARIFICATIONS:

The Iowa Electric commitment to Safety Guide 29 (6/7/72),

Seismic Design Classification, is stated in UFSAR Section 1.8, Conformance to NRC Regulatory Guides.

17.2 A-2 Revision 14 To be determined

5.0 REGULATORY GUIDE 1.30, "Quality Assurance Requirements for the Installation, Inspection, and Testing of Instrumentation and Electric Equipment" COMMENTS AND CLARIFICATIONS:

Iowa Electric complies with the Regulatory Position of this Regulatory Guide with the following clarifications:

5.1 The Iowa Electric commitment is to Safety Guide 30, dated August 11, 1972 and therefore by reference to ANSI N45.2.4-1972 which it endorses.

5.2 For maintenance and modification activities, Iowa Electric shall comply with the Regulatory Position established by this Regulatory Guide in that the quality assurance program requirements included therein (subject to the clarifications below) shall apply.

Technical requirements associated with maintenance and modification activities shall be equal to or better than the original requirements (eg.,

Code requirements, design and construction specification requirements, and inspection requirements).

5.3 Regulatory Position C.1 states that ANSI N45.2.4-1972 should be used in conjunction with ANSI N45.2-1971.

In lieu of this, Iowa Electric uses ANSI N45.2.4-1972 in conjunction with ANSI N18.7-1976.

5Property "ANSI code" (as page type) with input value "ANSI N18.7-1976.</br></br>5" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..4 Section 2.2(5)(d) of ANSI N45.2.4-1972 requires evidence of compliance by manufacturer with purchase requirements, including quality assurance requirements, before the requirements of ANSI N45.2.4-1972 are implemented. In lieu of this, Iowa Electric may proceed with installation, inspection, and testing activities for equipment lacking its quality documentation provided that this equipment has been identified and controlled in accordance with Iowa Electric's nonconformance reporting system.

5.5 With respect to Section 2.5.2 of ANSI N45.2.4-1972, calibration and control covers two classes of instrumentation used by Iowa Electric:

(1) portable equipment and (2) permanently-installed equipment.

With respect to permanently-installed instrumentation, in lieu of marking the equipment to indicate the date of the next required calibration, a computer-based preventative maintenance program is used.

Once a permanently-installed instrument is identified as needing control, a calibration frequency is assigned, and the information is entered into the data base.

The 17.2 A-3 Revision 14 To be determined

calibration task is then automatically tracked and tasked by the data base.

A "DO NOT USE Until Tested and Calibrated" or equivalent sticker is applied to instruments not calibrated before their due date and to instruments unacceptable for use.

The provisions of ANSI N45.2.4-1972, Section 2.5.2, are applied to portable equipment.

5.6 Section 3

of ANSI N45.2.4-1972 regarding "Preconstruction Verification" states it is necessary to verify that the quality of an item has not suffered during the interim period and it is not intended to duplicate inspections but rather verify that items are in a

satisfactory condition for installation.

Verifications and checks are then required.

In lieu of these verifications and checks, Iowa Electric considers the provisions of QAPD Sections 17.2.8 (Identification and Control of Materials, Parts, and Components) and 17.2.13 (Handling, Storage and Shipping) to be equivalent.

5.7 The last paragraph of Section 6.2.1 of ANSI N45.2.4 1972 requires that items requiring calibration be tagged or labeled on completion, indicating date of calibration and identity of person who performed the calibration.

In lieu of this, for permanently installed instrumentation, the calibration status is reflected in a computerized preventive maintenance program as described in Section 5.5 above.

6.0 REGULATORY GUIDE 1.33, "Quality Assurance Program Requirements (Operation)"

COMMENTS AND CLARIFICATIONS:

Iowa Electric complies with Regulatory Position of this Regulatory Guide with the following clarifications:

6.1 The commitment is to Regulatory Guide 1.33, Rev.

2, February 1978, and to ANSI N18.7-1976/ANS-3.2 which it endorses.

6.2 Regulatory Guide 1.33 Regulatory Position, Section C.2, also lists fifteen Regulatory Guides and ANSI standards that are referenced in ANSI N18.7-1976/ANS-3.2.

The Iowa Electric position with respect to each of these standards is stated elsewhere in this Appendix A.

6.3 Section 4.3.2.3 (Quorum for Independent Review Program) of ANSI N18.7-1976/ANS-3.2 indicates a Quorum for formal meetings "...

shall consist of not less than a 17.2 A-4 Revision 14 To be determined

majority of the principals, or duly appointed alternatives..."

Additionally, "the chairman (or his duly appointed alternate) shall be present for all formal meetings".

Section 6.5.2.6 of Appendix A (Technical Specifications) to the Facility Operating License indicates "A Quorum of the Safety Committee shall consist of the Chairman or Vice Chairman and at least four members with a maximum of two alternates as voting members".

The requirements of the Technical Specifications as stated above shall govern.

6.4 With respect to Section 4.3.4 (1),

Subjects Requiring Independent Review, of ANSI N18.7-1976/ANS-3.2, the DAEC Safety Committee is not required to review safety evaluations of changes in the facility which are completed under 10 CFR Part 50.59.

6.5 Section 5.1 (Program Description) of ANSI N18.7 1976/ANS-3.2 requires a

"summary document" for the Quality Assurance Program.

The QAPD and Appendix A thereto fulfill this requirement for Iowa Electric.

6.6 Section 5.2.7 (Maintenance and Modifications) of ANSI N18.7-1976/ANS-3.2 lists six standards that are to be applied to activities occurring during the operational phase that are comparable to related activities during design and construction.

Five of these standards are addressed elsewhere in this Appendix A.

Iowa Electric does not follow one of those listed, ANSI N101.4-1972, Quality Assurance for Protective Coatings Applied to Nuclear Facilities.

See UFSAR Section 17.2.9.5 for Iowa Electric's controls relative to "Special Protective Coatings".

6.7 With respect to Section 5.2.9 (Plant Security and Visitor Control) of ANSI N18.7-1976/ANS-3.2, the DAEC Security Plan meets the stated requirements.

However, the Standard references ANSI N18.17 for guidance.

Iowa Electric is not committed to ANSI N18.17.

The DAEC Security Plan complies with 10 CFR Part 73.

6.8 Section 5.2.15 (Review, Approval and Control of Procedures) of ANSI N18.7-1976/ANS-3.2, fourth

/

paragraph requires:

17.2 A-5 Revision 14 To be determined

"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."

This requirement is replaced by the following:

"Plant procedures shall be

reviewed, in accordance with the following, to determine if changes are necessary or desirable:
1)

Non-routine procedures, such as emergency operating procedures, off-normal procedures, those that implement the emergency plan, and others where usage may be dictated by an event, shall be reviewed at least every two years by an individual knowledgeable in the area affected by the procedure.

2)

The procedures which have a frequency of use which exceeds two years, shall be reviewed prior to use, or every two years by an individual knowledgeable in the area affected by the procedure.

3)

Routine plant procedures which are not addressed by (1) and (2) above shall be maintained through use of the procedure revision

process, as necessary or desirable changes are identified through use.

In addition, on a frequency not to exceed 2 years, an independent audit or assessment of a representative sample of routine plant procedures shall be performed to evaluate the effectiveness of the procedure review and revision program.

6.9 Section 5.2.16 (Measuring and Test Equipment) of ANSI N18.7-1976/ANS-3.2 requires that equipment be suitably marked to indicate calibration status.

Section 5.2.16 refers to ANSI N45.2.4-1972, which requires (Section 2.5.2, Calibration and Control) that equipment be suitably marked to indicate date of next required calibration and (Section 6.2.1, Equipment Tests) that items requiring calibration be tagged or labeled on completion, indicating date of calibration and identify of person who performed the calibration.

See the 17.2 A-6 Revision 14 To be determined

discussion provided in Section 5.5 of this document for Iowa Electric's commitment.

6.10 Instead of the format specified in Section 5.3.9.1, (Emergency Procedure Format and Content) of ANSI N18.7 1976/ANS-3.2, Iowa Electric's DAEC Emergency Operating Procedures (EOPs) are in the format specified by the BWR Owner's Group (BWROG)

Emergency Procedure Guidelines, as reviewed and approved in the NRC Safety Evaluation Report, BWROG EPG, Revision 4, September 1988.

7.0 REGULATORY GUIDE 1.37, "Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water Cooled Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:

Iowa Electric complies with the Regulatory Position of this Regulatory Guide with the following clarifications:

7.1 The commitment is to Regulatory Guide 1.37, Revision 0, 3/16/73, and to ANSI N45.2.1-1973 which it endorses.

7.2 Iowa Electric shall comply with the Regulatory Position established in this Regulatory Guide for maintenance and modification activities in that the quality assurance program requirements included therein shall apply.

Technical requirements associated with maintenance and modification activities shall be equal to or better than the original requirements (eg.,

Code requirements, design and construction specification requirements, and inspection requirements).

8.0 REGULATORY GUIDE 1.38, "Quality Assurance Requirements for packaging,

Shipping, Receiving,
Storage, and Handling of Items for Water-Cooled Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:

Iowa Electric complies with the Regulatory Position of this Regulatory Guide with the following clarifications:

8.1 The Iowa Electric commitment is to Regulatory Guide 1.38, Revision 2, May 1977, which endorses ANSI N45.2.2-1972.

However, the Iowa Electric commitment is to the later version of this Standard, ANSI/ASME N45.2.2-1978.

8.2 The applicability of the requirements of Section 3 and 4 and the Appendix of ANSI N45.2.2, and the paragraphs 17.2 A-7 Revision 14 To be determined

of the Regulatory Guide relating to these Sections (C.1.c, C.l.e, and C.2), is limited to the procurement of major plant equipment replacements; they are not applied to procurement of operating plant spares and modifications.

8.3 The shipping damage inspections required by Section 5.2.1 of ANSI N45.2.2 will be performed by Storekeepers prior to unloading in lieu of ANSI N45.2.6 certified inspectors.

A shipping damage inspection is performed by ANSI N45.2.6 certified inspectors at a later point in the receiving process for applicable items.

9.0 REGULATORY GUIDE 1.39, "Housekeeping Requirements for Water Cooled Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:

Iowa Electric complies with the Regulatory Position of this Regulatory Guide with the following clarification:

9.1 The Iowa Electric commitment is to Regulatory Guide 1.39, Revision 2, September 1977, and to ANSI N45.2.3 1973 which it endorses.

10.0 REGULATORY GUIDE 1.54, "Quality Assurance Requirements for Protective Coatings Applied to Water-Cooled Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:

Iowa Electric is not committed to Regulatory Guide 1.54, June 1973.

Iowa Electric's controls relative to protective coatings are contained in UFSAR Section 17.2.9.5.

11.0 REGULATORY GUIDE 1.58, "Qualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel" COMMENTS AND CLARIFICATIONS:

Iowa Electric complies with the Regulatory Position of this Regulatory Guide with the following clarifications:

11.1 The Iowa Electric commitment is to Regulatory Guide 1.58, Revision 1, September 1980, and to ANSI N45.2.6 1978 which it endorses.

11.2 ANSI N45.2.6-1978 Section 1.0, "Applicability", first paragraph, states that this standard applies to personnel who perform inspections, examinations, and tests during fabrication prior to and during receipt of 17.2 A-8 Revision 14 To be determined

items at the construction site, during construction, during preoperational and startup testing, and during operational phases of nuclear power plants.

At Iowa Electric, the qualification of Quality Control personnel (Iowa Electric or contractor employees) performing inspection or examination work at the plant shall be in accordance with Regulatory Guide 1.58 (ANSI N45.2.6-1978).

Personnel performing testing activities shall have appropriate experience and training to assure competence in accordance with Regulatory Guide 1.8 (ANS 3.1-1978).

11.3 Regulatory Position C.1 of Regulatory Guide 1.58 states that "for qualification of personnel (1) who approve preoperations, startup, and operation test procedures and test results and (2) who direct or supervise the conduct of individual preoperational, startup, and operational

tests, the guidelines contained in Regulatory Guide 1.8, "Personnel Selection should be followed in lieu of the guidelines of ANSI N45.2.6-1978".

Iowa Electric complies with this Regulatory Position

and, furthermore, test procedures are reviewed and approved by a committee consisting of members representing a broad range of experience in engineering, operation and quality assurance; the tests shall be performed by qualified personnel and monitored by quality assurance personnel, to ensure compliance with the test procedure requirements.

11.4 ANSI N45.2.6 Section 1.2, "Applicability",

third paragraph, requires that this standard be used in conjunction with ANSI N45.2.

Iowa Electric is not committed to ANSI N45.2.

11.5Property "ANSI code" (as page type) with input value "ANSI N45.2.</br></br>11.5" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. ANSI N45.2.6 Section 1.2, "Applicability",

fourth paragraph, requires that this standard be applied to organizations other than Iowa Electric. The specific applicability of this standard to other organizations is specified on a case-by-case basis in the procurement documents issued to those suppliers of materials and services.

11.6 Regulatory Guide 1.58 Revision 1, in Section B, "Discussion", endorses ASNT Recommended Practice No.

SNT-TC-1A-1975 for the qualification of nondestructive testing personnel.

In accordance with the Iowa Electric ASME Section XI program the 1980 Edition with addenda through Winter 1981 govern. Section IWA-2300 17.2 A-9 Revision 14 To be determined

of this Code requires nondestructive personnel to be qualified to SNT-TC-1A-1980.

In accordance with Regulatory Guide 1.147, ASME Code Case N-356, and Iowa Electric ASME Section XI Relief Request NDE-006, the recertification period for NDE Level III personnel shall be every five years as opposed to the three years as stated in SNT-TC-1A-1980, paragraph 9.7.1.

12.0 REGULATORY GUIDE 1.64, "Quality Assurance Requirements for the Design of Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:

Iowa Electric complies with the Regulatory Position of this Regulatory Guide.

The Iowa Electric commitment is to Regulatory Guide 1.64, Revision 2, June 1976, and to ANSI N45.2-l1-1974 which it endorses.

13.0 REGULATORY GUIDE 1.74, "Quality Assurance Terms and Definitions" COMMENTS AND CLARIFICATIONS:

Iowa Electric complies with the Regulatory Position of this Regulatory Guide with the following clarifications:

13.1 The Iowa Electric commitment is to Regulatory Guide 1.74, February 1974, and to ANSI N45.2.10-1973, which it endorses.

13.2 Iowa Electric has adopted the definition of "Audit" which appears in ANSI/ASME N45.2.12-1977, Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants, in lieu of the definition in ANSI N45.2.10-1973.

14.0 REGULATORY GUIDE 1.88, "Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records" COMMENTS AND CLARIFICATIONS:

Iowa Electric complies with the Regulatory Position of this Regulatory Guide with the following clarifications:

14.1 The Iowa Electric commitment is to Regulatory Guide 1.88, Revision 2, October 1976, and to ANSI N45.2.9 1974 which it endorses.

17.2 A-10 Revision 14 To be determined

14.2 Section 3.2.2 of ANSI N45.2.9-1974 specifies establishment of an "index".

As we understand this

term, it can include a collection of documents or indices (some of which may be computer-based) which, when taken together, supply the information attributed to an "index" in the Standard.

Record retention requirements for records are specified. The specific retention times for records are indicated when the records are transmitted for permanent storage.

Iowa electric utilizes computer-aided retrieval systems to index and locate records.

14.3 Section 5 of ANSI N45.2.9-1974, "Storage, Preservation and Safekeeping",

provides no distinction between temporary and permanent facilities.

To address temporary

storage, the following position is established:

Active records (those completed but not yet duplicated or placed on microfilm) may be temporarily stored in one-hour fire rated file cabinets until such time as they are duplicated or microfilmed.

Open-ended documents--those revised or updated on a more-or-less continuing basis over an extended period of time (e1g.

personnel qualification and training documents) and those which are cumulative in nature (e1g. nonconforming item logs and control room log books)--are not considered as QA records since they are not "complete". These types of documents shall become QA records when they are issued as a specific revision, when they are filled-up or discontinued, or on a periodic basis when the completed portion of the on going document shall be transferred to permanent storage as a "record".

14.4 The requirements of Section 4.3 (Receipt Control) of ANSI N45.2.9-1974 are implemented only for the permanent record files and not for temporary record files.

14.5 The requirements of Section 5.3 (Storage) of ANSI N45.2.9-1974 are implemented only for the permanent record files and not for temporary record files.

15.0 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" COMMENTS AND CLARIFICATIONS:

Iowa Electric complies with the Regulatory Position of this Regulatory Guide with the following clarifications:

17.2 A-11 Revision 14 To be determined

15.1 The Iowa Electric commitment is to Regulatory Guide 1.94, Revision 1, April 1976, and to ANSI N45.2.5-1974 which it endorses.

15.2 For modification activities Iowa Electric shall comply with the Regulatory Position established by this Regulatory Guide in that the quality assurance program requirements included therein shall apply. Technical requirements associated with modification activities shall be equal to or better than the original requirements (e1g.,

Code requirements, design and construction specification requirements, and inspection requirements).

16.0 REGULATORY GUIDE 1.116, "Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems" COMMENTS AND CLARIFICATIONS:

Iowa Electric complies with the Regulatory Position of this Regulatory Guide with the following clarifications:

16.1 The Iowa Electric commitment is to Regulatory Guide 1.116, Revision O-R, June 1976, with first page revision May 1977, and to ANSI N45.2.8-1975 which it endorses.

16.2 Iowa Electric's commitment to this Regulatory Guide is applicable to maintenance and modification activities in that the quality assurance program requirements included therein shall apply. Technical requirements associated with maintenance and modification activities shall be equal to or better than the original requirements (ezg.,

Code requirements, design and construction specification requirements, and inspection requirements).

17.0 REGULATORY GUIDE 1.123, "Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:

Iowa Electric complies with the Regulatory Position of this Regulatory Guide with the following clarifications:

17.1 The Iowa Electric commitment is to Regulatory Guide 1.123, Revision 1, July 1977, and to ANSI N45.2.13-1976 which it endorses.

17.2 A-12 Revision 14 To be determined

18.0 REGULATORY GUIDE 1.144, "Auditing of Quality Assurance Programs for Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:

Iowa Electric complies with the Regulatory Position of this Regulatory Guide with the following clarifications:

18.1 The Iowa Electric commitment is to Regulatory Guide 1.144, Revision 1, September

1980, and to ANSI N45.2.12-1977 which it endorses.

18.2 Section 1.1, "Scope", and Section 1.2, "Applicability",

of ANSI N45.2.12-1977 reference ANSI N45.2.

Iowa Electric is committed to ANSI N18.7-1976 for the operational phase, consistent with its commitment to Regulatory Guide 1.33.

18.3 Regulatory Position C.3.b(1) states that external audits, after the award of a contract, are not necessary for procurement actions where acceptance of the product is in accordance with Section 10.3.2, "Acceptance by Reviewing Inspection", of ANSI N45.2.13 1976.

The suppliers of products that meet this requirement are included on the Iowa Electric external audit schedule and are audited on a triennial basis.

18.4 ANSI N45.2.12, Section 4.3.1 "Pre-Audit Conference" first sentence states:

"A brief pre-audit conference shall be conducted with cognizant organization management."

This sentence is replaced with:

"A brief pre-audit conference should be conducted with cognizant organization management."

In

addition, for internal audits, a

"pre-audit planning meeting" may be substituted for the "pre audit conference."

The pre-audit planning meeting should accomplish the following:

1)

Obtain input on the subject(s) to be audited from the organization(s) to be audited.

2)

Finalize the audit plan as a result of the input obtained at this audit planning meeting.

3)

Introduce the Lead Auditor and identify proposed audit team members.

Those audit team members available will be introduced.

Note:

Non-utility team members are usually not available at these meetings.

17.2 A-13 Revision 14 To be determined

4)

Counterparts are invited to these audit planning meetings as part of the planning process.

5)

The audit schedule is presented, including a tentative exit date.

The final exit date is announced separately during the audit period.

6)

The channels of communication are opened at the audit planning meeting through participation in the audit planning process.

19.0 REGULATORY GUIDE 1.146, "Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants" COMMENTS AND CLARIFICATIONS:

Iowa Electric complies with the Regulatory Position of this Regulatory Guide with the following clarifications:

19.1 The Iowa Electric commitment is to Regulatory Guide 1.146, August 1980, and to ANSI N45.2.23-1978 which it endorses.

19.2 ANSI N45.2.23 Section 1.2 references ANSI N45.2.

For Iowa Electric, the entities subject to audit are defined in 10 CFR 50 Appendix B and ANSI N18.7-1976.

This is consistent with Iowa Electric's commitment to Regulatory Guide 1.33 which endorses ANSI N18.7-1976, in lieu of ANSI N45.2.

19.3Property "ANSI code" (as page type) with input value "ANSI N45.2.</br></br>19.3" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. As an alternative to ANSI N45.2.23-1978, paragraph 2.3.4, "Audit Participation",

the following may be applied:

"The prospective Lead Auditor shall have participated in a minimum of two (2) nuclear quality assurance audits within a period of time not to exceed one (1) year prior to the date of 14 qualification.

This participation shall be at an equivalent level as a Lead Auditor, but under the supervision of a Lead Auditor.

This includes responsibility for implementation of the audit process (i.e.,

planning, conduct,
meetings, reporting, etc.) and shall result in satisfactory performance as determined by management.

17.2 A-14 Revision 14 To be determined

20.0 REGULATORY GUIDE 4.15, "Quality Assurance for Radiological Monitoring Programs (Normal Operations) -

Effluent Streams and the Environment" COMMENTS AND CLARIFICATIONS:

Iowa Electric complies with the Regulatory Position in Regulatory Guide 4.15, Revision 1, February 1979.

21.0 ASME B&PV Code,Section XI, 1980 Edition with Addenda through Winter 1981 COMMENTS AND CLARIFICATIONS:

The Iowa Electric commitments relative to the Ten-Year Inspection Program and the Pump and Valve Test Program are established separately in formal correspondence with the Nuclear Regulatory Commission and incorporated into appropriate Iowa Electric documents.

Procedur\\Apx17-2.kep 17.2 A-15 Revision 14 To be determined Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description

1.

Vice President -

Production to Vice President -

Nuclear Identification of changes:

The following sections have been revised by replacing the title Vice President -

Production with Vice President Nuclear as previously described in Iowa Electric Light and Power Company correspondence of March 31, 1993, (NG-93 1330):

17.2.1.2 -

Manager, Corporate Quality Assurance 17.2.1.2.5 (formerly 17.2.1.2.6) -

Stop Work Authority 17.2.2.7 -

Management Review and Audit 17.2.16.4 -

Reporting of 10 CFR 21 Defects and Non compliances 17.2.18.1 -

Audits, Scope 17.2.18.2.2 - Audits, Internal Organizations Reasons for the change:

The position Vice President -

Production no longer exists.

NRC was previously notified of this change by NG-93-1330 of March 31, 1993.

Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).

This change in titles and organizational structure was previously approved by NRC correspondence of April 15, 1993:

(Reference letter of Mark A. Ring to Lee Liu).

2.

17.2.1.2.1 Quality Assurance Procurement Supervisor:

Identification of the Change:

The word "Assessments" has been corrected to "Assessment" in reference to the title of the QA Assessment Supervisor. In addition, a sentence has been added which states that the QA Procurement Supervisor is responsible for the preparation and maintenance of procedures which implement the functions Page 1 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description assigned to this Supervisor. Also, responsibility for the review of procurement documents has been removed.

Reason for the Change:

The first change is a typographical correction. The second change is made because the QA Programs Engineer position has been eliminated as described in 17.2.1.2.5 below. It is more efficient for the responsible Supervisor to develop and maintain the procedures for which he/she is responsible.

The removal of responsibility for the review of procurement documents is made in support of removing the quality assurance organization from the in-line review of these activities.

See 17.2.4.5 description of change for further details.

Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).

This first change only corrects a typographical error.

The second change reflects transfer of the responsibility to prepare procedures from a position previously identified as the QA Programs Engineer to the supervisory position, which is responsible for implementation of the procedures (i.e.,

QA Procurement Supervisor).

All functions previously described in the quality assurance program description continue to be performed, just by a different person. There is no reduction in commitments from those previously reviewed and approved by the NRC.

See section 17.2.1.2.5 below for a discussion of the elimination of the QA Programs Engineer.

The last change regarding elimination of the responsibility for the review of procurement documents is made for consistency with the change described for Section 17.2.4.5.

See the discussion of 17.2.4.5 for the basis of this change.

3.

17.2.1.2.2 Quality Assurance Assessment Supervisor:

Identification of the Change:

This section has been modified to include responsibilities for coordinating the review of divisional procedures, and for the preparation and maintenance of procedures for which the position is responsible.

Page 2 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description Reason for the Change:

The position of QA Program Engineer has been eliminated and the responsibilities of that position reassigned, in part to this position.

Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).

The previous Quality Assurance Program Description (QAPD) required that divisional procedures be reviewed by the Quality Assurance Program Engineer. This review continues and is now performed by various QA Department personnel, as assigned by the QA Assessment Supervisor, who coordinates the review. The Quality Assurance Assessment Supervisor is now also responsible for preparation and maintenance of procedures for which he/she is responsible. These functions continue to be performed consistent with the previous revision of the QAPD and as previously reviewed and approved by the NRC. There is no change in commitment. See Section 17.2.1.2.5 below regarding the QA Program Engineer.

4.

17.2.1.2.3 Quality Control Supervisor:

Identification of the Changes:

The changes to this section include correcting "Assessments" to "Assessment" in the title of the Quality Assurance Assessment Supervisor and including the responsibility for preparation and maintenance of procedures for which the Quality Control Supervisor is responsible.

Reason for the Changes:

The change from Assessments to Assessment corrects a typographical error.

The addition of responsibility for the preparation and maintenance of procedures is due to the elimination of the QA Programs Engineer position.

Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).

The basis is the same as that described above in 17.2.1.2.2.

These changes do not represent a reduction in commitment.

Page 3 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description See Section 17.2.1.2.5 below regarding the QA Program Engineer.

5.

17.2.1.2.5 Quality Assurance Programs Engineer:

Identification of the Change:

The position of Quality Assurance Programs Engineer has been eliminated.

Reason for the Change:

The Quality Assurance Programs Engineer position was not efficient.

Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).

The QA Programs Engineer previously performed three functions: 1) Assisting the Manager, Corporate Quality Assurance in maintaining the Operational Quality Assurance Program; 2) reviewing divisional procedures which were responsive to the requirements of the Operational Quality Assurance Program, and 3) preparing and maintaining QA Department implementing procedures.

All of these functions continue to be performed. The maintenance of the Operational Quality Assurance Program continues to be performed by the Manager, Corporate Quality Assurance. The review of divisional procedures is now coordinated by the QA Assessment Supervisor. The department implementing procedures are prepared and maintained by the QA Department Supervisors responsible for their implementation.

In conclusion, the functions previously performed by the QA Programs Engineer continue to be performed but by different persons within the QA organization.

These changes do not affect implementation of the program in accordance with 10 CFR Part 50 Appendix B, and all quality assurance commitments previously reviewed and accepted by the NRC continue to be performed by the Quality Assurance Department. There is no reduction in commitment.

Page 4 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description

6.

17.2.1.2.6 (Renumbered as 17.2.1.2.5) Stop Work Authority:

Identification of Changes:

This section was renumbered from 17.2.1.6 to 17.2.1.5.

Reason for the Changes:

The numbering change is the result of eliminating the Quality Assurance Programs Engineer position.

Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).

The paragraph numbering change is editorial.

7.

17.2.2.3 Identification of Safety-Related Structures, Systems, Components, and Items:

This section refers to UFSAR Table 3.2-1 for the list of safety-related structures, systems, components and items.

The following changes have been made to UFSAR Table 3.2-1 and evaluated for impact on the quality assurance program.

A.

Section III (Recirculation System), Item 6, Pump Motor:

Identification of Changes:

The following changes have been made to item 111.6:

a)

The safety class has been revised from safety class 2 to "other" b)

The quality assurance requirements have been revised from "B" to "D" c)

Footnote lx has been added which states:

"The recirc pump motors are not seismic category I.

However, per 21A9213 sections 4.1.8.3.5 and 4.1.6, they must be seismically supported so as not to breach the integrity of the reactor coolant pressure boundary."

Reason for the Changes:

The above changes are the result of continuing work at DAEC to reconstitute the design basis of the plant. Details concerning Item 111.6 must be corrected.

Page 5 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description The original purchase specification for the reactor recirculation pump and motor (General Electric Specification 21A9213) states:

"The pump pressure boundary shall remain suitable for service after the transient; however, it is not required that the pump remain operable."

The recirculation pump motors were not included on the original DAEC "Q-List."

In the early design for DAEC, it was assumed that conservative design for the recirculation system pump and motor would require a gradual reduction in recirculation system flow in the event of a transient to minimize the impact on the fuel parameters. This approach was consistent with industry standards ANS-22 and ANS 52.1 which state:

"Sufficient inertia shall be provided in the reactor coolant recirculation pumps or their power source so that the coolant flow coastdown characteristics in the event of a total loss of power ensure that fuel design limits are not exceeded."

In support of these requirements, the safety classification tables in these reference standards identify the reactor recirculation system pump motors as safety class 2 which is consistent with the present UFSAR Table 3.2-1.

However, in later years it was determined that this long coastdown has a negative effect on pressurization.

In 1980, Iowa Electric made a design change (DCR-700) to the recirculation system to install end-of-cycle recirculation pump trip (RPT) breakers in accordance with General Electric document NEDO-24220 "Basis for Installation of Recirculation Pump Trip System."

This design change required a request for a revision to the DAEC Technical Specifications, and an NRC safety evaluation report was issued. Additional Class 1E trip breakers were installed which trip the recirculation system pump motors from the recirculation motor generator set, minimizing the recirculation pump coastdown.

These motors are not safety class 2, but safety class "other," and the motors do need to be seismically mounted in order to maintain the reactor coolant pressure boundary (impact on the pumps).

New Footnote lx has been added to Page 6 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description define the seismic requirements clearly. The quality assurance requirements have been revised from 10 CFR Part 50 Appendix B to other (D) consistent with the non-safety, but seismic, application of these pump motors.

Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).

The Safety Class 2 and Appendix B classifications for the reactor recirculation pump motors previously stated were in error. As stated above, these motors were not originally purchased as a "Q-List" item. The current Safety Class 2 designation was based on ANS-22 which does not recognize the use of Class 1E trip breakers to remove the power source from the pumps during a transient. These pump motors perform no safety function.

In conclusion, UFSAR Table 3.2-1 was incorrect because of an incomplete set of input documents.

Reclassification of the recirculation pump motor is not a reduction in commitment based on the original DAEC design but could be classified as a reduction in commitment based on the content of the current UFSAR Table 3.2-1. On this basis, this change is categorized as a reduction in commitment from that previously specified.

7B.

Item XI.9, HPCI System, Turbine:

Identification of the Change A reference to Footnote Ig was added to the HPCI Turbine item, and footnote lg was revised to include the HPCI turbine. Footnote lg now states:

"The RCIC and HPCI turbines do not fall within the applicable design codes.

To assure that the turbines are fabricated to the standards commensurate with their safety and performance requirements, General Electric has established specific design requirements for these components."

Reason for the Change Footnote lg is applicable to the RCIC and HPCI turbines.

That was clear in a similar note in the UFSAR revision of July, 1982, page T.3.2-16. comment 8 which stated:

Page 7 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description "The HPCI and RCIC turbines are categorized as machinery and thus do not fall within the classification groups as earlier identified. To ensure that the turbine was fabricated to the standards commensurate with their performance requirements, General Electric has established specific design requirements for these components."

This was mistakenly dropped.

Basis for Concluding That The Change Is Acceptable Under Section 50.54 (a)(3):

This change clarifies the entry for the HPCI system turbine in UFSAR Table 3.2-1.

It does not impact the application of the Quality Assurance Program Description as previously reviewed and approved by the NRC to the RCIC and HPCI turbines and continues to satisfy the provisions of 10 CFR 50 Appendix B. This change is not a reduction in commitment.

7C.

Items XI.7 (HPCI Vacuum Pump Discharge Line to Containment Isolation Valves) and (RCIC, Vacuum Pump Discharge Line to Containment Isolation Valves):

Identification of the Changes:

Footnote lb was added to the RCIC Item 7 " Vacuum pump discharge line to containment isolation valves". The footnote states:

ANSI B31, Code Case 78 applies for B31.7 Class 1 and Class 2 pipe and fittings 3/4" nominal pipe size (NPS) and smaller.

Also, "Principal component description" for entries XI.7 and XII.7 are revised from "Vacuum pump discharge line to containment isolation valves" to "Vacuum pump discharge line."

Reason for the Change Footnote lb was not previously applied to the RCIC system vacuum pump discharge line. A portion of the RCIC (and HPCI) system vacuum pump discharge lines return to the barometric condenser and are 3/4" Class 2 lines to which Code Case 78 applies.

Page 8 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description The "Principal component description" was in error. The HPCI and RCIC vacuum pump discharge lines discharge to the Standby Gas Treatment System, and back to the barometric condenser. There are no containment isolation valves in these lines.

Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).

These changes do not impact the application of the Quality Assurance Program Description as previously reviewed and approved by the NRC and continue to satisfy the provisions of 10 CFR 50 Appendix B. Quality Assurance requirement "D" continues to be applied. This change is not a reduction in commitment.

7D.

Item XXIII.1, Offgas System, Tanks:

Identification of the Change Item XXIII.1, the construction code of 'D100 or API-650' was changed to read 'AWWA D100 or API-650'.

Reason for the Change The addition of AWWA (American Water Works Association) to this entry provides further clarification concerning the origination of the D100 code.

Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).

This is an editorial change and does not impact the application of the Quality Assurance Program Description as previously reviewed and approved by the NRC and continues to satisfy the provisions of 10 CFR 50 Appendix B. This change is not a reduction in commitment.

7E.

Items XXIII.3-6, Offgas System:

Identification of the Changes:

Item XXIII.3, piping, the construction code was changed from USAS B31.7-1969 to 'ASME Section 111-1971'.

The following comment was added for Items XXIII.3 through 6:

Page 9 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description "The construction codes used for Offgas pipe, pumps, and valves were USAS B31.7; ASME Sections III and VIII; and the Draft Pump and Valve Code. To identify the correct code for a component it is necessary to research the receiving inspection files (File Q2.321).

There are two reasons that several codes and dates were applied. The first reason is that the Offgas design was changed during Procurement/Construction. The second reason is that the codes were changing rapidly during the'period of the design. The project correspondence which records when the Offgas System construction code was changed is given in APED-N62 076."

Reason for the Changes:

Multiple codes were used in the procurement/construction of the Offgas system. Only the most recent code (ASME Section 111-1971) is listed in UFSAR Table 3.2-1 under the construction code column. The complete explanation of the Offgas system construction codes can be found in the comments section as depicted by a 'Yes' in the comments column for Items XXIII.3 through XXIII.6.

Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).

This change provides an additional level of detail regarding the code of construction for the Offgas system. This does not impact the application of the Quality Assurance Program Description as previously reviewed and approved by the NRC and continues to satisfy the provisions of 10 CFR 50 Appendix B. This change is not a reduction in commitment.

7.F Item XXIII.5, Offgas System, Valves, Flow Control:

Identification of the Change Item XXIII.5, The Scope of Supply was changed from 'GE' to

'B'.

Reason for the Change The flow control valves for the Offgas system were actually supplied by Bechtel using material requisition specification 7884-M-131 AC.

Page 10 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).

The correction of the "Scope of Supply" for Item XXIII.5 does not impact the application of the Quality Assurance Program Description as previously reviewed and approved by the NRC.

This change is not a reduction in commitment.

7.G Item XXIII.7, Offgas System, Mechanical Modules:

Identification of the Change The following changes have been made to this line item:

1)

The Principal Component description was changed from "Mechanical Modules with safety function" to "Mechanical modules".

2)

The "Offgas Stack Dilution Fans" were relocated from Item XXIII.7 to the Standby Gas Treatment System (XXXI.1). This relocation causes the following changes:

a)

Scope of Supply Changes from "GE/B" to "GE".

b)

The safety class changes from "Other/Other" to "other".

c)

The quality group class changes from "D/D+QA" to "D".

d)

The Quality Assurance Requirement changes from "D/B" to "D".

e)

The seismic category changes from "NA/I" to "NA".

f)

Reference to footnote lv is removed from XXIII.7 and the footnote itself deleted.

g)

The "Comment" in XXIII.7, pertaining to the Offgas Stack Dilution Fans is deleted.

Reason for the Change As part of the design basis reconstitution for DAEC, it was discovered that the Offgas stack dilution fans were originally designed to be part of the Standby Gas Treatment system, as documented in IE-72-236, letter from D. Flanagan of Iowa Electric, to S. Cott of Bechtel, dated 5-10-72. As previously explained in discussion with F. Maura of the NRC (Docket No. 50-331 G. Wright to L. Liu dated 11-5-92), this original design was changed due to the fact that the Offgas stack dilution fans were the only components with a safety Page 11 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description function.

It should be noted that the Offgas stack dilution fans have now been moved to the Standby Gas Treatment system (see change for Item XXXI).

Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).

The Offgas Stack Dilution Fans and all requirements associated with them have only been relocated from Table 3.2-1 line item XXIII.7 to new line item XXXI.l.

This relocation did not alter any of the Quality Assurance Program Requirements applicable to the Mechanical Modules of the Offgas System. The removal of the words "with safety function" is consistent with the NRC letter of November 5, 1992, G. Wright to L. Liu.

These changes are not reductions in commitment. See Section XXXI.1 regarding Offgas Stack Dilution Fans.

7.H Item XXXI.1, Standby Gas Treatment System:

Identification of Changes:

The Offgas Stack Dilution Fans have been added to this entry (relocation from XXIII.7 above).

This relocation also includes the following changes for the Offgas Stack Dilution fans from the previous entry at XXIII.7:

1)

Principal component description a -been revised to include "including Offgas Stack Dilution Fans".

2)

Safety class "3" is now assigned to these fans (previously "other").

3)

Quality Group Class is now "blank" versus "D+QA" previously.

Reason for the Changes:

As reflected by 05/10/72 correspondence of IE-72-236, D.

Flanagan of Iowa Electric to S. Cott of Bechtel, the Offgas Stack Dilution Fans were originally designed as part of the Standby Gas Treatment System.

The Principal Component title change is a result of relocating the Offgas Stack Dilution Fans from Item XXIII.7 to this section.

Page 12 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description The Safety Class previously stated for these fans was in error. Safety Class "3" is the correct safety class per the original design and in support of the Standby Gas Treatment System, and as defined by UFSAR Section 3.2.

The Quality Group Classes are only applied to system piping and equipment pressure parts as defined in UFSAR Section 3.2.

Quality Group Class is not applicable to the Offgas Stack Dilution Fans.

Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).

The above changes to the Offgas Stack Dilution Fans correct the Safety Class and Quality Group Class consistent with UFSAR Section 3.2.

These changes do not affect the application of the 10 CFR Part 50 Appendix B program to these components as previously defined in the Operational Quality Assurance Program and previously accepted by the NRC. These changes are not a reduction in commitments.

7.1 Item XXXVIII.2, MSIV Leakage Control, Piping and Valves, Other:

Identification of the Changes:

Item XXXVIII.2, The construction code of 'ASME Section III' was changed to 'ASME Section 111-1974'.

Reason for the Change:

The addition of the code date for this entry clarifies which particular code was used during procurement/construction.

Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).

This change adds another level of detail regarding the specific year of the ASME Code to which these components were designed. This change does not impact the application of the Quality Assurance Program Description as previously reviewed and approved by the NRC and continues to satisfy the provisions of 10 CFR 50 Appendix B. This change is not a reduction in commitment.

Page 13 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description 7.J Footnote "e":

Identification of the Change The middle sentence of Footnote 'e' has been deleted.

It read:

The inclusion of a system or structure within Seismic Category I does not mean the entire system or structure is Seismic Category I but rather that the system or structure has been evaluated and those portions that lie within the definition of Seismic Category I have been appropriately analyzed and protected for seismic response.

Reason for the Change For clarification and to avoid misinterpretation, this sentence was deleted as previously discussed with F. Maura of the NRC (Docket No. 50-331, G. Wright to L. Liu, date 11 5-92).

Any deviation from the Seismic Category I requirements for portions of structures or systems classified as Seismic Category I will be justified on an individual basis.

Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).

This change is a clarification and does not impact the application of the Quality Assurance Program Description as previously reviewed and approved by the NRC and continues to satisfy the provisions of 10 CFR 50 Appendix B. This change is consistent with the previous NRC letter of November 5, 1992, and is not a reduction in commitment.

7.K Comments XI.9(1)(6) and XII.9(1)(6):

Identification of the Change Comments XI 9(6) and XII 9(6) were revised to include "paragraph N624, and magnetic particle or liquid penetrant tested according to ASME Section III" in the following comment:

Butt welds were radiographed according to the ASME B&PV Code,Section III, 1968 Edition, "paragraph N624, and Page 14 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description magnetic particle or liquid penetrant tested according to ASME Section III", paragraph N626 or N627.

APED-A61-052, Comment 10 which is the reference for this comment was also added.

Reason for the Change This is an editorial change which corrects a portion of the comment omitted in the translation from the original source document.

The reference for this comment was given for additional clarity.

Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).

This is an editorial change and does not impact the application of the Quality Assurance Program Description as previously reviewed and approved by the NRC and continues to satisfy the provisions of 10 CFR 50 Appendix B. This change is not a reduction in commitment.

8.

17.2.2.6 Indoctrination and Training:

Identification of Changes:

For operator training, the Plant Superintendent-Nuclear now has cognizance over this training along with the Manager, Nuclear Training.

For technical training, the Manager of Engineering now has cognizance over this training along with the Manager, Nuclear Training.

For radiation and safety training, the Radiation Protection Manager now has cognizance over this training along with the Manager of Nuclear Training.

Reason for the Changes:

These changes have been made to recognize the involvement of these functional managers in training personnel who work in the areas for which they are responsible.

Page 15 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).

The listing of the Manager of Engineering, Plant Superintendent-Nuclear and Radiation Protection as sharing responsibility for the training in their respective functional areas adds detail to what was provided previously. These changes are consistent with the responsibilities of these positions as defined in UFSAR Section 13.

These changes do not affect quality assurance program commitments as previously reviewed and approved by the NRC and remain consistent with the provisions of 10 CFR Part 50, Appendix B. These changes do not reduce any commitment.

9.

17.2.3.7 Design Changes Identification of the Change:

The title of section 17.2.3.7 is changed from "Design Changes" to "Changes to Design Documents".

Reason for the Change:

The new title more accurately describes the substance of section 17.2.3.7.

Basis for concluding that the change is acceptable under 10 CFR Part 50.54 (a)(3):

The change in title is an editorial change per 10 CFR 50.54(a)(3).

10.

17.2.3.8 Design Review Committees Identification of the Change:

The title of this section is revised from "Design Review Committee" to "Independent Review Committees".

The following information is deleted from this section:

"Design changes require a safety evaluation and concurrence by the Operations Committee. The Operations Committee shall bring to the attention of the Safety Committee those design changes that are deemed to involve an unreviewed safety Page 16 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description question, or are deemed to be inconsistent with the Technical Specifications."

Reason for the Change:

The revised title makes it clear that this section addresses the independent review committees.

The deletion is made because this material is an unnecessary duplication of the Technical Specifications section 6.5 and ANSI N18.7-1976 section 4.3.4 and creates confusion. The first sentence of section 17.2.3.8 already states the requirements of the technical specifications will be satisfied.

It is unnecessary to repeat the requirements in section 17.2.3.8.

The elimination of this material also eliminates any confusion between a "design change" and "change to the facility as described in the Safety Analysis Report."

ANSI N18.7-1976, Technical Specifications, and 10 CFR 50.59 all use the terminology of "change to the facility".

Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).

The revised title to section 17.2.3.8 is an editorial change in accordance with 10 CFR Part 50.54(a)(3).

As indicated above, the commitments contained in the material being removed continue to exist, ie, ANSI N18.7 section 4.3.4 and the DAEC Technical Specification section 6.5.

Specifically, the following comparisons are made:

17.2.3.8 previously stated:

"Design changes require a safety evaluation and concurrence by the Operations Committee."

DAEC Technical Specifications section 6.5.1.5.d states:

"The Operations Committee shall be responsible for:

(d) Review of all proposed changes or modifications to plant systems or equipment that affects nuclear safety."

Page 17 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description The other sentence removed from 17.2.3.8 states:

"The Operations Committee shall bring to the attention of the Safety Committee those design changes that are deemed to involve an unreviewed safety question, or are deemed to be inconsistent with the Technical Specification".

ANSI N18.7-1976 section 4.3.4(2) states: "The following subjects shall be reviewed by the independent review body:

(2) Proposed changes in...

the facility any of which involves a change in the technical specifications or an unreviewed safety question as defined in 10 CFR 50.59(c).

Matters of this kind shall be referred to the independent review body by the onsite operating organization following its review, or by other functional organizational units within the owner organization, prior to implementation.

This is also supported by the DAEC Technical Specifications section 6.5.2.7 which states:

"The Safety Committee shall be responsible for the review of:

(b) Proposed changes to procedures, equipment or systems which involve an unreviewed safety question as defined in Section 50.59, 10 CFR.

"Also Technical Specification 6.5.2.7(d) states:

"Proposed changes in Technical Specifications or licenses."

In conclusion, the requirements previously stated in section 17.2.3.8 continue to apply by virtue of the DAEC Technical Specifications and the commitment to ANSI N18.7-1976 as specified in UFSAR 17.2 Appendix A, section 6. This change has no affect on the quality assurance program requirements and is therefore not a reduction in commitment.

Page 18 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description

11.

17.2.4.5 Quality Assurance Department Review of Procurement Documents Identification of the Change:

Section 17.2.4.5 is deleted in its entirety.

It reads as follows:

"Procurement documents for safety related items and services are reviewed and approved by the Quality Assurance Department for appropriate inclusion of quality requirements."

Former section 17.2.4.6 is also renumbered as 17.2.4.5.

Reason for the Change:

The review and approval of procurement documents by Quality Assurance personnel is an in-line review function. We have concluded that Quality Assurance's role reviewing procurement documents would be more appropriately performed through independent reviews and the performance of assessments. Elimination of this in-line review function from the quality assurance program description will facilitate the transition.

Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).

This change is a reduction in commitment from that previously specified.

Compliance with the requirements of 10 CFR 50 Appendix B, Criterion IV, "Procurement Document Control", is assured through UFSAR 17.2 sections 17.2.4.1 through 17.2.4.4. NRC approval of this change will permit Iowa Electric to begin the transition to remove Quality Assurance from the review and approval process of procurement documents and into assessing the performance of procurement document preparation. NRC approval of this change will permit the transition process to begin.

Page 19 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description

12.

17.2.16.2 Conditions Adverse to Quality:

Identification of Change:

"Audits of vendors" has been revised to state "Audits of suppliers."

Reason for the Change:

This change has been made to achieve consistent usage throughout the document.

Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).

This change is editorial only in accordance with the provisions of 10 CFR 50.54(a)(3).

This change is not a reduction in commitment.

13.

UFSAR Section 17.2.18.2.1, External Organizations:

Identification of Change:

The term "vendors" is replaced with the term "suppliers".

Reason for the Change:

The other sections of UFSAR 17.2 utilize the term "supplier" as opposed to the term "vendor".

Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).

This change is of an editorial nature only in accordance with 10 CFR 50.54(a)(3).

This change is not a reduction in commitment.

14.

17.2.18.5 Report and Closeout of Audit Findings:

Identification of Change:

The fifth paragraph of this section states: "The corrective actions will be tracked to ensure that proper and timely corrective actions have occurred and that the audit report can be closed."

This section is revised to read as follows:

"The corrective actions will be tracked to ensure that proper and timely corrective actions have occurred prior to closure of the audit findings."

Page 20 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description Reason for the Change:

The "audit report" can be handled separately from the tracking and closure of the "audit findings."

The audit report has served its function once it is issued while the corrective actions will be completed over some period of time.

Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).

The purpose of the statement: "and that the audit report can be closed" was to focus on the need to keep the corrective action document open until the corrective actions have been completed. However, it is not necessary to keep the audit report open for that period of time if a tracking system separate from the audit report is utilized. This change is editorial.

The tracking of corrective actions until proper and timely corrective actions have occurred continues to be required. This change does not affect the quality assurance commitments as previously reviewed and approved by the NRC and continues to comply with the provisions of Appendix B to 10 CFR Part 50.

This change is not a reduction in commitment.

15.

UFSAR 17.2, Appendix A, Section 6.3 Identification of the Changes:

The sentence "Specifically, a Quorum at Safety Committee meetings shall consist of at least four members plus the Chairman or Vice Chairman" has been deleted from the end of paragraph 6.3.

Reason for the Changes:

The above change is incorporated as a result of NRC comment in the NRC letter of November 5, 1992, G. Wright to L. Liu.

Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).

This change was made consistent with the comments provided in the above referenced letter of November 5, 1992.

This change was previously evaluated as acceptable by the NRC.

Page 21 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description

16.

UFSAR 17.2 Appendix A, Section 6.8.:

Identification of the Change:

Appendix A to UFSAR 17.2 is revised by inserting a new section 6.8, and renumbering previous sections 6.8 and 6.9 as 6.9 and 6.10 respectively. The new section 6.8 modifies the DAEC commitment for the biennial review of procedures as follows:

ANSI N18.7-1976, Section 5.2.15 (Review, Approval and Control of Procedures), fourth paragraph states:

"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."

This commitment is replaced by the following:

"Plant procedures shall be reviewed in accordance with the following to determine if changes are necessary or desirable:

1)

Non-routine procedures, such as emergency operating procedures, off-normal procedures, those that implement the emergency plan, and others where usage may be dictated by an event, shall be reviewed at least every two years by an individual knowledgeable in the area affected by the procedure.

2)

The procedures which have a frequency of use which exceeds two years, shall be reviewed prior to use, or every two years by an individual knowledgeable in the area affected by the procedure.

3)

Routine Plant Procedures which are not addressed by (1) and (2) above shall be maintained through use of the procedure revision process, as necessary or desirable changes are identified through use.

In addition, on a frequency not to exceed 2 years, an independent audit or assessment of Page 22 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description a representative sample of routine plant procedures shall be performed to evaluate the effectiveness of the procedure review and revision program.

Reason for the Change:

This change is made to utilize resources more effectively and at the same time maintain a high level of quality in the program for maintenance of our plant procedures.

Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).

This change is categorized as a reduction in commitment since plant procedures which are of a routine nature will no longer require a separate biennial review. However, the controls specified above will continue to assure a high level of quality is maintained in the plant procedures. The controls specified above are also consistent with the provisions of 10 CFR Part 50, Appendix B for the control of procedures, including revisions thereto.

17.

UFSAR 17.2, Appendix A, Section 11:

11.6 Identification of Change (Clarification):

This clarification/exception currently recognizes the adoption of SNT-TC-1A-1980 as the standard by which nondestructive examination personnel will be qualified. An addition is made to this clarification/exception which states:

"In accordance with Regulatory Guide 1.147, ASME Code Case N-356, and Iowa Electric ASME Section XI Relief Request NDE-006, the recertification period for NDE Level III personnel shall be every five years as opposed to the previously specified 3 years as stated in SNT-TC-1A-1980, paragraph 9.7.1.

Reason for the Change:

Iowa Electric ASME Section XI Relief Request NDE-006 was previously reviewed and approved by the NRC but was not Page 23 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description recognized in the quality assurance program commitments in UFSAR 17.2, Appendix A.

Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).

Regulatory Guide 1.147, Revision 9 of April 1992 recognizes that the conditions of Code Case N-356 were adopted by the NRC on July 1, 1988.

Iowa Electric ASME Section XI Relief Request NDE-006 was approved by the NRC on September 16, 1988.

The incorporation of this Code Case and relief request into UFSAR 17.2 Appendix A does not reduce the quality assurance program commitments as previously reviewed and approved by the NRC because the change has previously been reviewed and approved by the NRC.

This change is not a reduction in commitment.

18.

UFSAR 17.2, Appendix A, Section 18:

18.4 Identification of Change (Clarification/Exception):

ANSI N45.2.12, Section 4.3.1, "Pre-Audit Conference",

states: "A brief pre-audit conference shall be conducted with cognizant organization management. The purpose of the conference shall be to confirm the audit scope, present the audit plan, introduce auditors, meet counterparts, discuss audit sequence and plans for the post audit conference, and establish channels of communications.

Two issues arise from that provision. First there is a conflict between the "shall" in ANSI N45.2.12, Section 4.3.1 and UFSAR Section 17.2.18.4 which uses a "should."

Secondly, an alternative to pre-audit conferences for internal audits is desired. These two issues are addressed by the addition below to UFSAR 17.2 Appendix A, Section 18.4:

The first sentence of the commitment to ANSI N45.2.12, Section 4.3.1 is changed to read:

"A brief pre-audit conference should be conducted with cognizant organization management."

Page 24 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description In addition, for internal audits, a pre-audit planning meeting may be substituted for the pre-audit conference.

The pre-audit planning meeting should accomplish the following:

1)

Obtain input on the subjects to be audited from the organization(s) to be audited.

2)

Finalize the audit plan as a result of the input obtained at this audit planning meeting.

3)

Introduce the Lead Auditor and identify the proposed audit team members. Those audit team members available will be introduced. Note:

Non-utility team members are usually not available at these meetings.

4)

Counterparts are invited to these audit planning meetings as part of the planning process.

5)

The Audit Schedule is presented, including a tentative exit date.

The final exit date is announced separately during the audit period.

6)

The channels of communication are opened at the audit planning meeting through participation in the audit planning process.

Reason for the Changes:

The "should" vs "shall" is clarified between UFSAR Section 17.2.18.4 and ANSI N45.2.12 Section 4.3.1.

The "should" contained in UFSAR 17.2 Appendix A Section 18.4 is now consistent with the previous 17.2.18.4.

The use of audit planning meetings as an alternative to pre audit conference meetings will more effectively utilize the time of management personnel.

We have used audit planning meetings for some time and they have proven to be quite beneficial in opening communications between the audited and auditing organizations and in focusing the audits on the areas of importance. The pre-audit conferences then become somewhat duplicative of the audit planning meeting.

Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).

The use of the term "should" with reference to pre-audit conferences is consistent with the previous content of UFSAR Section 17.2.18.4 as previously reviewed and approved by the NRC. A similar argument could be presented that the NRC Page 25 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description previously approved the "shall" due to no exception or clarification being placed in UFSAR 17.2 Appendix A Section

18.

The use of audit planning meetings as an alternative to pre audit conferences is a slightly different approach to audits than reflected by the existing commitment to ANSI N45.2.12 1977.

This change is considered a change in commitment but will not reduce the effectiveness of the operational quality assurance program. This change is in accordance with 10 CFR Part 50, Appendix B criteria XVIII, Audits, which requires a comprehensive system of planned and periodic audits be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program.

These changes will not be placed into effect until NRC review and approval is obtained.

19.

UFSAR SECTION 17.2, APPENDIX A, SECTION 19, Paragraph 19.3:

Identification of the Change:

ANSI N45.2.23-1978, Section 2.3.4, "Audit Participation",

states:

"The prospective Lead Auditor shall have participated in a minimum of five (5) quality assurance audits within a period of time not to exceed three (3) years prior to the date of qualification, one audit of which shall be a nuclear quality assurance audit within the year prior to his qualification."

As an alternative to ANSI N45.2.23 -

1978Property "ANSI code" (as page type) with input value "ANSI N45.2.23 -</br></br>1978" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., Section 2.3.4, "Audit Participation" the following may be applied:

"The prospective Lead Auditor shall have participated in a minimum of two (2) nuclear quality assurance audits within a period of time not to exceed one (1) year prior to the date of qualification."

This participation shall be at an equivalent level as a Lead Auditor, but under the supervision of a Lead Auditor.

This includes responsibility for implementation of the audit process (i.e., planning, meetings, conduct Page 26 of 27 Discussion of Changes to NG-93-2180 In the Quality Assurance Program Description reporting, etc) and shall result in satisfactory performance as determined by management.

Reason for the Change:

ANSI N45.2.23 -

1978Property "ANSI code" (as page type) with input value "ANSI N45.2.23 -</br></br>1978" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., "Qualification of QA Program Audit Personnel for Nuclear Power Plants" addresses the following elements for qualification of personnel as Lead Auditors as defined in Section 2.3:

2.3.1 Education and Experience 2.3.2 Communication Skill 2.3.3 Training 2.3.4 Audit Participation 2.3.5 Examination Section 2.3.4 requires "participation" in five (5) audits.

The level of responsibility for implementing the audit process exercised by an individual can vary greatly depending on his/her assignment in a particular audit.

For personnel who participate in two audits at the same level of responsibility as the Lead Auditor (i.e., the trainee performs all activities for the audit, including preparation of the audit plan and checklist, leads the audit under a Lead Auditors supervision, leads the pre-and post-audit conferences and is held responsible for the written report),

the process and skills of auditing may be adequately demonstrated. A minimum of 2 audits at this level of participation are deemed necessary for the trainee to demonstrate the audit process and their skills to management to make a good judgement on qualification. Participating at this level for five audits may be unnecessary depending on the individuals capabilities.

Basis for Concluding That The Change Is Acceptable Under 10 CFR Part 50.54(a)(3).

This change is a reduction in commitment but is consistent with the provisions of 10 CFR Part 50 Appendix B, criterion II, which requires indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained.

This change will not be placed into effect until NRC review and approval is obtained.

C:\\procedur\\QAPD.mem Page 27 of 27

TABLE 3.2-1 INDEX Sys#

SysName SysCode I

Reactor System i11 II Nuclear Boiter System 821 III Recirculation System B31 IV CRD Hydraulic System C1i V

Standby Liquid Control System C41 VI Neutron Monitoring System C51 VII Reactor Protection System C71 VIII Process Radiation Monitors Oi IX RHR System El x

Low Pressure Core Spray E21 XI NPCI System E41 XII RCIC System E51 XIlf Fuel Service Equipment Fil XIV Reactor Vessel Service Equipment F13 XV In*Vesset Service Equipment F14 XVI Refueling Equipment Fis XVII Storage Equipment F16 XVIII Radwaste System Gil XIX Reactor water Cleanup System G31 KD Fuel Pool Cooling and Cleanup System G41 XXI Control Room &

Remote Shutdom PanetsHl1 C61 xxII Local Panels and Racks N21 XXIII Offgas System M62 XXIV Emergency Service Water E13 XXV RHR Service Water System E12 XXVI RBCCU P42 XXVII Wall Water System P46 XXVIII Pneumatic Systems T48 P50 XXIX Diesel Generator System R43 XXX Containment Atmosphere Control System T48 XXXI Standby Gas Treatmnt System T46 XXXII ECCS Equipment Area Cooling System T41 XXXIII Power Conversion System M11 N21 XXIV Condensate Storage and Transfer System P11 XXXV Essential a-c Power System R20-24 R35 R43 XXXVI 125/250 Volt d-c Power System R42 XXXVII River Water Supply W10 XXXVIII NSIV Leakage Control 321 KXIX NVAC XXXX Miscellaneous Components Revision 10 6/92 T3. 2-1

TABLE 3.2-1 INDEX Sys#

SysName SysCode XXXVI 125/250 Volt d-c Power System R42 XXXIV Condensate Storage and Transfer System P11 xxx Containment Atmosphere Control System T48 XXI Control Room &

Remote Shutdown PaneLsH11 C61 IV CRD Hydraulic System C11 XXIX Diesel Generator System R43 XXXII ECCS Equipment Area Cooling System T41 KXIV Emergency Service Water E13 XXXV Essential a-c Power System R20-24 R35 R43 K0 Fuel Pool Cooling and Cleanup System G41 XIII Fuel Service Equipment F11 xI HPCI System E41 XXIX NVAC XV In-Vesset Service Equipment F14 XXII Local Panels an Racks M21 X

Low Pressure Core Spray E21 XXXX Miscellaneous Components XXXVIII MSIV Leakage Control 321 VI Neutron Monitoring System c51 II Nuclear loiler System B21 XXIII Offgas System g62 XXVIII Pneumatic Systems T48 P50 XXIII Power Conversion System NIl U21 VIII Process Radiation Monitors D11 VIII Radeaste System 611 XXVI RCCW P42 XII RCIC System E51 VII Reactor Protection System C71 I

Reactor System a11 XIV Reactor Vessel Service Equipment F13 XIX Reactor Water Cleaup System 031 III Recirculation System 331 XVI Refueling Equipment F15 XXV RNR Service Water System E12 IX RNR System El XXXVII River Water Supply 10 ExMI Standby Gas Treatment System T46 V

Stanby Liquid Control System C41 XVII Storage Equipment F16 XXVII Well Water System P46 Revision 1

T3. 2-2 9

Table 3.2-1 DABC Classification of Compoacts in Systems Principal Component IReactor Systest11

1. Reactor vessel
2. Reactor vessel support skirt
3. Reactor vesset appurtenances, pressure retaining portions
4. CRD Housing Supports (Shoot-out Steel)

S. Reactor internal structures, engineered safety features

6. Reactor internal structures, other
7. Control rods
8. Control rod drives
9. Core support structure
10. Power range detector hardware
11. Fuel assemblies
12.

AN Vessel Stabilizer

13. Refueling bellows II Nuclear Boiler System 321
1. Vessels, level instrumentation condensing chambers
2. Vessels, M2 accumulators
3. Piping, relief valve discharge
4. Piping, main steam within outermost isolation valve S. Pipe supports, main steam
6. Pipe restraints, main stem
7. Piping, other within outermost isolation valves
8. Piping, instrumentation beyond outermost isolation valves Scope of Safety Supply Clas (a)

(b) a/C I

GE I

GE 1

GE 2

GE 2

GE Other GE 2

GE I

GE 2

GE GE GE 2

2 2

Code Class Construction Code (c)

A ASHE Section III, 1965 Edition, Summer 1967 Addenda A

ASHE Section III, 1965 Edition, Summer 1967 Addenda A

ASHE Section iII, 1965 Edition, Sumimer 1967 Addenda A

ASHE Section Ill, 1965 Edition, Summer 1967 Addenda I

Section III, Class 1 appurtenances A

ASHE Section III, 1965 Edition, Summer 1967 Addenda A

GE Other GE I

0 2

A 3

GE I

GE 1

2 B

1 a

Other ASHE Section Ill, 1965 Edition, Summer 1967 Addenda 2

ASHE Section III 3

USAS 831.7-1969 ANSI 331.1.0 + Code Cases N-2,N-7,N-9,N-1O 1

Requirements for Class I piping supports in ANSI 331.7.

1Property "ANSI code" (as page type) with input value "ANSI 331.7.</br></br>1" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. USAS 331.7-1969 USAS B31.1.0-1967 Quality Group Class A

A A

MA MA MA A

NA 8

NA NA Quality Assurance Req.

(d)

Seismic Category (e)(f)

PO Date (9) a I

I I

Equivalent ASNE 3 & PV Code Section III Footnotes (h) 1 1

I 3

I id Id Id 1d,lu U

BS 8

a I

8a I

B3 tu NG 1d,lu 2

la,lb I

I NA A

C A

A NA A

B I

B B

a B

A I

1 02/26/73 07/30/70 12/05/69 2

3 1

la,lb I

02/26/71 1

I 2

I 07/30/70 1

la,lb la,1b IELP/Systems,Class/Systems I I Comments (i)

I1P I

Cji W'

I-11 1

I I

I I

I I

Table 3.2,1 DABC Classification of Compoacas in Systeams Principal Component Sco.

of Supply (a)

GE

9. Safety valves
10. Relief valves Safety Class (b) 1 GE I
11. Valves, mmin stem isolation valves 12, Valves, other, isolation valves and within
13. Valves. instrumenqation beyond outermost isolation valves
14. Nechanical modules, instrumentation, with safety function
15. Electrical modules with safety function
16. Cable, with safety function Recirculation System 031
1. Piping GE 1

8 8

1 Other GE 2

GE 2

0 2

GE 1

Code Class Construction Code (c) 1 ANSI 131.1.0, Addends and applicable code cases or MDE standards of B31.1.

Code Cases N2,N7,M9,N10 except that the acceptance standards for Class I valves in the Draft ASNE Code for Puaps and Valves for Nuclear Power my be applied.

Use ANSI 16.5 or NSS-SP-66 for design 1

ANSI 931.1.0, Addends and applicable code cases or NDE standards of B31.1.

Code Cases N2,11Y,9,110 except that the acceptance standards for Class I valves in the Draft ASNE Code for Pumps and Valves for Nuclear Power my be applied.

Use ANSI 16.5 or NSS-SP-66 for design I

ANSI 131.1.0. Addends and applicable code cases or NDE standards of B31.1.

Code Cases 12,.1,9,M10 except that the acceptance standards for Class I valves in the Draft AM Code for Pumps and Valves for Nuclear Power my be applied.

Use ANSI 16.5 or NSS-SP-66 for design 1

ASHE Code for Pumps and Valves for Nuclear Power USAS 831.1.0-1967 Quality Quality Group Assurance Class Req.

(d)

A U

A Seismc Category (e)(f)

I PO Date (g)/

12/30/69 Equivalent ASHE B A PV Code Section III Footnotes (h) 1 If 1

I 12/30/69 1

If A

a I

10/15/69 1

A NA ANSI 031.1.0 + Code Cases N2,N7.N9.N1O 0

I 10/16/70 If I

If la,lb,1f I

I I

A Ic ic 10o B

I 12/05/69 1

IELP/SystemsClass/Systems la,lb I-.

110 Comments (1)

Ito

Table 3.'

DAEC Classificatiom of Composcats in Systcas Principal Component

2. Pipe suspension, recirculation tine
3. Pipe restraints recirculation line
4.

Pumps S. Valves

6. Motor, pump
7. Electrical modules, with safety function
8. Cable with safety function IV CAD Hydrautic System CII
1. Valves, isolation, water return line
2. Valves, scram discharge volume lines
3. Valves insert and withdraw lines
4. Valves, other
5. Piping, water return line within isolation valves
6. Piping, scram discharge volume lines
7. Piping, insert and withdraw lines Scope of Supply (a)

GE Safety Class (b)

I Code Class 1

OR 2

GE I

Construction Code (c)

Requirements for Class I piping supports in ANSI 031.7.

1Property "ANSI code" (as page type) with input value "ANSI 031.7.</br></br>1" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. Draft ASHE Code for Pums and Valves for Nuclear Power or MDE and acceptance requirements of ANSI 131.1 Code Cases N7,N9,NiO +

Design Guide for sizing pressure parts in ASKE Boiler and Pressure Vessel Code (19681 Section III, Class C.

I Requirements for Class 1 valves in Draft ASNE Code for Pumps and Valves for Nuclear Power and requirements applicable to valves in AS1E Section III

[1968 Edition plus addenda), articles I and 8.

NENA Standards GE I

Ouslity Quality Group Assurance Class Req.

(d)

A I

MA A

3 8

A B

2 1

I ANSI 131.1.0 or ASKE Code for Pumps and Valves for nuclear Power, Class 1, or ASKE Section III, 1971 Edition, Class I GE/B 2/2 2

ASME Code for Pupe and Valves for Nuclear Power GE/B 2/2 2

ANSI 331.1.0 or ASHE Code for Pumps and Valves for Nuclear Power or ASKE Section Ill. 1971 Edition, Class 1 6

Other 2

ASKE Section Ill, 1971 Edition a

1 1

ASHE Section Ill, 1971 Edition B

2 2

ASHE Section Ill, 1971 Edition B

2 2

ASHE Section Ill, 1971 Edition A

B B

B r/n r/8 D

A I

5 r/s 8/B Sefsmic Category (e)(f)

I PO Date

(/)/

02/26/71 I

2 I

11/22/68 1

I 03/20/70 1

I I

I 12/19/72 1

i/1I 1/1 12/19/72 12/19/72 D

NA 12/19/72 B

8B e

I 12/19/72 I

12/19/72 I

12/19/72 Equivalent ASHE 8 & PV Code Section III Footnotes (h) 1 if

-ic Ic 10 if 2

if 2

if la,1f,1(

1 2

2 IELP/System,Ciass/System I0 Comments (1)

Yes 10 GE GE MA 6J)

MA B

Table 3.2-1 DABC Classification of Compoacats ia Systes Principal Component Scope of Supply (a)

S. Piping, other

9.
10.
11.

V 1.

Nydraulic control unit Electrical modules, with safety function Cable, with safety function Standby Liquid Control System C41 Standby liquid control tank

2. Pump.
3. Pump motor
4. Valves, explosive S. Valves, isolation and within
6. Valves, beyond isolation valves
7. Piping, within isolation valves
8. Piping, beyond isolation valves
9. Electrical modules, with safety function
10. Cable, with safety function VI Neutron onitoring System C51
1. Piping, TIP
2. Valves, isolation, TIP subsystem
3. Electrical modules, IN and APAN
4. Cable, IN and APRN VII Reactor Protection System C71
1. Electrical modules
2. Cable Vi1 Process Radiation Monitors 011
1. Electrical modules for main stem line, reactor building ventilation and offess stock monitors
2. Cable for main steam line, reactor building ventilation, and offgas stack monitors lX ANR System El
1. Neat exchangers, primary side
2. Heat exchangers, secondary side
3. Piping, within outermost LPCI &

shutdown cooling isolation valves

4. Piping, other t,4 0 I'J~

C.-,-

Safesty Class (b) a Other G

2 GE

- 2 g

Code Construction code (c) 2 ASME Section Ill, 1971 Edition Quality Quality Group Assurance Class Req.

(d)

D D

Special a

NA I

2 GE 2

G 2

GE 2

GE 2

I 1

a 2

1 9

2 GE 2

3 2

GE GE GE I

API-650 and ASNE Section Vill, Div. 1 2

ASNE Code for Pumps and Valves for Nuclear Power 2

1 2

1 2

ASNE Code for Pumps and Valves for Nuclear Power ASNE Code for Pums and Valves for Nuclear Power ASNE Code for Pumps and Valves for muclear Power USAS 331.7-1969 USAS 331.7-1969 2

2 2

2 GE 2

8 2

GE 2

I U

I I

U S

5 a

a NA B

A a

A a

NA I

NA MA MA 2

GE 2

I ASNE Section III, Class 8 and TENA-C GE 3

ASNE Section VIII, Div. 1, and TEMA-C g

1 1

USAS 831.7-1969 a

2 2

USAS 831.7-1969 Seismic Category (e)(f)

MA Equivalent ASME PO Dae PY Code PO Date Section III (a)

(h) 12/19/72 I

I 110 Footnotes 1.,1b,11 tc I

2 2

2 I

10/16/70 1

If Comments

()

Yes 10 Yes Ye 10 Yes 10 1f 1

I 10/16/70 2

S S

U 5

I S

S U

I I

I I

I I

I 07/30/70 07/30/70 1

2 2

2 S

I I

I U

S 5

U a

C A

I if la,lb Ia, lb, Im Ic la,1b if ic, w 10 Yes 1 10 ic Ic I

08/15/69 2

I 06/15/69 3

I 07/30/70 I

07/30/70 2

IELP/Systems,Class/systems 1s, lb Is, Ib g

I

Table DAEC Classification of Coaspoeats an Systems Principal Component

5. Pumps
6. Pump motors
7. Valves, isolation, LPCI & shutdoun cooling lines
8. Valves, isolation, other
9. Valves, beyond isolation'valves
10. Mechanical modules
11. Electrical modules, with safety function
12. Cable, with safety function Low Pressure Core Spray E21
1. Piping, within outermost isolation valves
2. Piping, beyond outermost isolation valves
3. Piping, floodup line to condensate storage tank
4. Pumps
5. Pump motors
6. Valves, isolation and within
7. Valves, beyond outermost isolation valves
8. Valves, floodup line to condensate storage tank
9. Electrical modules with safety function Scope of Supply (a)

GE GE I

Safety Code Class Class (b) 2 2

2 I

I 9

2 M

2 GE 2

GE 2

a 2

2 2

Construction Code (c)

Draft ASHE Code for Pumps and Valves for Nuclear Power or NDE and acceptance requirements of ANSI 831.1 Code Cases M7,N9.M10 +

Design Guide for sizing pressure parts in ASME lofler and Pressure Vessel Code (19681 Section Ill.

Class C.

ASHE Code for Pumps and Valves for Nuclear Power ASNE Code for Pumps and Valves for Nuclear Power ASNE Code for Pumps and Valves for Nuclear Power Quality Quality Group Assurance Class Req.

(d) 1 8

NA A

MA 83 8

Seismic Category

(*MCf)

I I

I I

I I

I PO Date (g) 09/17/69 10/16/70 10/16/70 10/16/70 Equivalent ASME B a PV Code section III Footnotes (h) 2 le

-1 1

If If if ic ic I

I S

B 8

1 USAS B31.7-1969 2

2 USAS 131.7-1969 Other USAS B31.1.0 GE 2

2 Draft ASNE Code for Pumps and Valves for Nuclear Power or MDE and acceptance requirements of ANSI 531.1 Code Cases 17,19,110

  • Design Guide for sizing pressure parts in ASNE Boiler and Pressure Vessel Code (1968)Section III, Class C.

GE 2

S 1

2 M

Other 1

ASHE Code for Pumps and Valves for Nuclear Power 2

ASHE Code for Pumps and Valves for Nuclear Power USAS B31.1.0 GE 2

A I

C 8

a NA A

a I

07/30/70 1

I 07/30/70 2

I I

09/17/69 2

8 U

85 8

BS C

NA 10/16/70 10/16/70 Ia, lb. In Ia,1b ta,lb le if if If ic 2

-4 aIELP/Systems, Class/Systems

  • I.

I to 1' 0 (

Comments (i)

I 10 2

I I

I I

I

Table 3.2-1 DABC Classifrcation of Compoacats in Systems Principal Component

10. Cable, with safety function KI HPCI System E41
1. Piping, within outermost isolation valves
2. Piping, beyond outermost isolation valves
3. Piping, return test line to condensate storage tank beyond second isolation valve
4. Pumps.

Scope of Supply (a) 8 S

8 3

G

5. Valves, isolation and within a
6. Valves, return test line to a

condensate storage beyond second isolation valve

7. VacuumPump discharge tie to (containment isolatio vas
8. Valvs, other or
9. Turbine BE
10. Electrical modules, with safety GE function
11. Cable, with safety function I

RCIC System ESI

1. Piping, within outermost isolation I

valves

2. Piping, beyond outermost isolation 0

valves

3. Piping, return test line to I

condensate storage tank beyond second isolation valve Safety Class (b) 2 I

2Ote Other Code C lass 1

2 Construction code (c)

USAS 331.7-1969 USAS 831.7-1969 USAS B31.1.0 Quality Group Class A

0 2

2 Draft ASHE Code for Pumps a

and Valves for Nuclear Power or MOE and acceptance requirements of ANSI 831.1 Code Cases N7,M9,N10 +

Design Guide for siting pressure parts in ASHE Boiler and Pressure Vessel Code (19681 Section III, Class C.

I 1 ASNE Code for Pumps and A

Valves for Nuclear Power Other USAS B31.1.0 0

Other 2

2 2

2 1

2 Other USAS 331.1.0 2

ASNE Code for Pumps and Valves for Nuclear Power NENA Standards for Mechanical Drive Stem Turbine I

USAS 831.7-1969 2

USAS 831.7-1969 USAS 831.1.0 D

a NA KA A

a D

Quality Assurance Req.

(d)

I U

D3 0

U D

D0 8

I 0

Seismic Category

(*)f)

MA PO Date (e) 07/30/70 07/30/70 07/30/70 Equivalent ASE I & PV Code Section III (h) 1 2

I 07/31/69 2

I MA NA I

I I

I MA 10/16/70 10/16/70 10/16/70 07/29/69 07/30/70 07/30/70 07/30/70 I

Footnotes la,lb lath la,1b,1r le If If IaIb 2

Ic 1

2 as I b la,lb la. 1b,r IELP/SystemsClass/Systems 110 Comments (I)

Yes

Table 3W DABC Classificatiom of Composcats ia Syscn Scope of Supply (a)

GE Principal Component

4. Pumps
5. Valves, isolation and within
6. Valves, return test line to a

condensate storage beyond second isolation valve

7. Vacuu pump discharge It 6I contao nt aolation valves
a. Valves at er a
9. Turbine GE
10. Electrical modules, with safety GE function
11. Cable, with safety function 8

ill Fuel Service Equipment Fit

1. Fuel preparation machine GE
2. General purpose grapple GE IV Reactor Vessel Service Equipment F13
1. Stem line plugs G
2. Dryer and separator sting and head GE strongback In-Vessel Service Equipment F14 1,.

Control rod grapple GE II Refueling Equipment FIS

1. Refueling equipment platform GE assembly II Storage Equipment F16
1. Fuel storage racks GE
2. Defective fuel storage container GE

%VIII RAedeste System G11

1. Tanks, Atmospheric GE
2. Heat exchangers G

Safety Code Class Class (b) 2 a

1 Other Other 2

2 2

2 Construction Code (c) 2 Draft ASHE Code for PLs and Valves for Nuclear Power or MDE and acceptance requirements of ANSI 931.1 Code Cases M7,9,M10 +

Design Guide for sizing pressure parts in ASNE Boiler and Pressure Vessel Code (19681 Section III, Class C.

1 ASNE Code for Ptmps and Valves for Nuclear Power USAS 831.1.0 USAS 831.1.0 2

ASNE Code for Pumps and Valves for Nuclear Power NE1A Standards for Mechanical Drive Stem Turbine 3

2 3

2 2

2 2

3 E/B Oth/Oth E/1 Oth/Oth API-650 or AWA-0100 or ANSI 096.1 or equivalent plus HDE per ASNE Section VIII Div. 1.

Quality Quality Group Assurance Class Req.

(d) 6 B

A D

0 9

Seismic Category PO Date (e)(f)

(g)

I I

10/16/70 D

NA 10/16/70 0

NA 8

B B

B NA NA NA MA MA MA WA NA NA 1

10/16/70 I

07/29/69 I

I Equivalent ASNE I & PV Code Section Ill Footnotes (h) 2 le 1

if if 2

2 if 1i Ic S

I I

I I

8 U

6 6

CAD D/D 0/0 D/D tAO I..-,.

I MA/MA 07/16/70 1h NA/NA IELP/Systems,Class/Systems 110 Comnents (i)

Yes Yes 1 0 E

E

Table 3.2-1 DABC Clauification of Compoacals is Systems Principal Component

3. Piping and valves, containment isolation
4. Piping, other
5. Pums
6. Valves, flow control and filter system
7. Valves, other
8. Nechanical modules Reactor water Cleanup System G31
1. Vessels: filter/demineralher
2. Heat exchangers
3. Piping, within outermost isolation valves
4. Piping, beyond outermost isolation valves
5. Pumps
6. Valves, within isolation valves and
7. Valves, beyond outermost isolation valves
8. Nechanical modules (X

Fuel Pool Cooling and Cleanup Syste

1. Vessels, filter/demineralizers
2. Vessels, other
3. Heat exchangers Scope of Safety Supply Class (a)

(b)

I 2

Code Class Construction Code (c)

Quality Group Class 2

USAS 831.7-1969 g

a Other 3

USAS 331.7-1969 GE Other 3

ANSI 831.1.0 or ASNE Code for Pumps and Valves for Nuclear Power, Class 3, or ASNE Section III, 1971 Edition, Class 3 GE Other 3

ASNE Code for Pumps and Valves for Nuclear Power I

Other 3

ANSI 831.1.0 or ASNE Code for Pumps and Valves for Nuclear Power, Class 3, or ASHE Section III, 1971 Edition, Class 3 GE Other Quality Assurance Req.

(d) g Seismic Category

(*)(f)

I CAD 0

NA CAD 0

MA CA0 CAD PO Date (g) 07/03/72 D

MA 0

MA CAD D

MA GE Other C

ASNE Section III GE Other ASNE Section Vill and TEKA-C S

1 1

USAS B31.7-1969 0

Other 3

USAS B31.7-1969 GE Other 3

ANSI 831.1.0 or ASNE Code for Pumps and Valves for Nuclear Power, Class 3, or ASNE Section III, 1971 Edition, Class 3 a

1 1

ANSI 831.1.0 or ASNE Code for Pumps and Valves for Nuclear Power, Class 1, or ASNE Section Ill, 1971 Edition, Class 1 GE/I Oth/Oth 3

ANSI 031.1.0 or ASNE Code for Pumps and Valves for Nuclear Power, Class 3, or ASHE Section Ill, 1971 Edition, Class 3 GE a 041 GE 8

GE Other Other Other Other C

C A

C C

B I

a 12/17/70 3

09/25/67 3

I 07/30/70 1

B I

07/30/70 3

la,1b,lo,lt a

A I

12/23/69 3

le,1t I

I C/C 0

1 S

I ASNE Section VIII, Div. 1.

ASNE Section Vi1, Div. 1.

ASNE Section VIII, Div. 1, and TEMA-C C

C C

0 D

D MA NA NA 12/23/69 IELP/SystemsClass/Systems Equivalent ASME I & PV Code Section III (h) 2 110 Footnotes la,th Is, lb.I 1,1Ij I*'t I Comments (0)

Yes I10 1f,1j if,1j 1c,1j it It la,1Ib 1

3 If It 11o, 1t 1c, It 3

3 I

I

Table DABC Classificatiom of Compoacats Ia Systems Principal Component

4. Pumps
5. Piping
6. Valves Scope of Safety Supply Class (s)

(b)

Code Class Construction Code (c)

GE Other 3

ANSI 831.1.0 or ASNE Code for Puape and Valves for Nuclear Power, Class 3, or ASHE Section Ill. 1971 Edition, Class 3 1

Other 3

USAS 831.7-1969 A

Other ANSI 831.1.0 or ASNE Code for Pumps and Valves for Nuclear Power, Class 3, or ASME Section III, 1971 Edition, Class 3 Quality Quality Group Assurance Class Req.

(d)

C 0

C CAD XXI Control Room A Remote Shutdown PanetsNI C61

1. Electrical modules, with safety GE 2

NA function

2. Cable, with safety function 8

2 xxil Local Panels and Racks 121

1. Electrical modutes, with safety GE/1 2/2 8/

function

2. Cable, with safety function 3

2 XXIII Offgas System M62 w

1. Tanks GE Other 00 r API-650
2. Hest exchangers GE Other I

Ill &T

3. Piping a

Other 3

4. pumps Other
  • 9<aL.. -8
5. Valves, flow control B9 other

-D

6. Valves, other Oth
8.

sure vessels GE Other D

XXIV Emergency Service Uater E13

1. Piping 5

3 3

USAS 331.7 D+QA

2. Pumps U

3 3

ASNE Code for Pumps and D+0A Valves for Nuclear Power

3. Pump motors
4. Valves Electrical modules, with safety function Cable, with safety function RHR Service Water System E12 Piping Pumps
3. Pump motors a

3 B

3

.3 10 3

3 3

a 3

3 USAS 831.7-1969 B

3 3

ANSI 631.1.0 or ASNE Code for Pumps and Valves for Nuclear Power, Class 3, or ASHE Section 1I, 1971 Edition, Class 3 a

3 C

C ASmE Code for Pumps and Valves for Nuclear Power O.OA Seismic Category (e)(f)

NA PO Date (g)

Equivalent ASNE B A PV Code Section III (h) 3 D

MA D

MA 8

I 8

I B/9 Footnotes

. 10 Comnents (i)

Ia if ic Ic B

D D

D0 D0 D

Df9" MA 10/21/71 NA 11/20/72 MA 07/27/72 NA MA

/

MA 11/29/71 Ih 1k le,1k if,1k If I IlfIV-D NA 10/21/71 I

07/30/70 3

I 3

le I

I 10/16/70 3

if 6

I I/

10 Ie 10 Yes 10 Ic B

I 6

I B

I 07/30/70 3

1p 3

le a

I I

ELP/Systems, Class/Systems I

10

-1 I

Table 3.2-1 DABC Classification of Compoaeats la Systems Principal Component

4. Valves
5. Electrical modales, with safety function
6. Cable, with safety function XVI RBCCU P42
1. Piping, and valves forming part of primary containment boundary.
2.
3.

XVII 1.

Piping and valves inside drywell Piping and valves, other Ueit Mater System P46 Piping and valves forming part of primary containment boundary

2. Piping and valves inside drywell
3. Piping and valves, other KVIII Pneumatic Systems
1. Nitrogen vessels, accumiulators, supporting safety-related system
2. Nitrogen piping and valves in lines between above accumulators and safety-related systems
3. Nitrogen piping and valves forming part of containment boundary
4. Instrument air vessels, accumulators, supporting safety-related systems S. Instrument air piping and valves in lines between above accumulators and safety-related system XIX Diesel Generator Systems R43
1. Day tanks
2. Piping and valves, fuel oil system and diesel service water system
3. Pumps, fuel oil system and dies*

service water system

4. Pump motors, fuel oil system and diesel service water system
5. Diesel-generators Scope of Supply Ca) 8 Safety Class (b) 3 3

Code Class 3

Construction Code (c)

ASHE Code for Pumps and Valves for Nuclear Power Quality Quality Group Assurance Class Req.

(d)

C I

I 0

D I

D 0

Seismic Category (e)(f)

I PO Date (g)0 10/16/70 I

I S,

3 I

a 2

8 ASHE Nuclear Vessels Code Section III, Extension of Contairment Code Cases 1425, 1426 & 1427 Other USAS 831.1.0 8

Other B

2 a

Other a

Other T48 P50 8

2 ASNE Nuclear Vessels Code,Section III, Extension of Contairment Code Cases 1425, 1426 & 1427 USAS 131.1.0 USAS 831.1.0 2

ASHE Section III 2

2 ASHE Section III U

8 2

2 ASHE Section III a

3 0

3 Equivalent ASME I & PV Code Section III Footnotes (h) 3 if,1p

) 10 Comments Mi)

Ic 1

I 07/30/70 2

B U

I I

I Is Is I

NA I

I 02/26/73 I

I 02/26/73

.s lb a

3 API-650 or AuuA-DiOO or ANSI 96.1 or equivalent plus MDE per ASNE Section VIII, Div. 1.

0 3

3 USAS 131.7 for pipe and ASME Code for Pumps and Valves for Nuclear Power a

3 3

ASNE Code for Pumqs and Valves for Nuclear Power 3

a 2

C C

C I

8 10 10 10 10 I

1 I

a i

IELP/Systems,Class/Systems I

I I

Table 3A DABC Classificatiom of Composents in Systess Principal Component

6. Electrical modules with safety function
7. Cable, with safety function
8. Diesel fuel storage tanks
9. Diesel Air Start System xxx Containment Atmosphere Control
1. Piping and valves from primary containment through outer isolation valve Scope of Supply (a)

System T48 a

Safety Code Class Class (b) 3 3

Other 2

2 Construction Code (c)

API-650 or AWA-D100 or ANSI 896.1 or equivalent plus NOE per ASNE Section VIII, Div. 1.

a ASHE Nuclear Vessels Code Section III. Extension of Code Cases 1425, 1426 and 1427 XXXI Standby Gas Treatment System T46 functi PJZrf,~

fa XXXI I ECC SEqiihren AiCool11tam~

1. All comonents with safety a

3 functions XXXIII Power Conversion System Nit M21

1. Main stem piping from outboard a

Other USAS 131 NSIV to turbine stop valves and branch tine piping up to and including first valve

2. Stem piping and valves, other I

Other USAS 831

3. Reactor fee dwater piping and M

1 1

USAS 931 valves, RPV to outermost isolation valve

4. Reactor feedwater piping and I

Other USAS 931 valves, other XXXIV

' Condensate Storage and Transfer System P11

1. Condensate store" tank U

Other API-650

2. Piping and valves
3. Other components xxxV Essential a-c Power System 120
1. All components with safety function XXXVI 125/250 Volt d-c Power system R42
1. All components with safety function XXXVII River Water Supply 1110
1. Piping, pumps and valves
2. Intake traveling screen, trash rakes
3. Pump motors XXXVIII MSIV Leakage Control 321

-24 1

Other Other R35 R43 2

8 2

B 3

8 3

1 3

Quality Quality Group Assurance Class Req.

(d)

B C

I U

S Seismic Category

  • )C(f)

I PO Date (U)

Equivalent ASME a & PV Code Section III Footnotes (h)

  • ic B

1 07/30/70 I

I

.1.0

.1.0

.7-1969

'1.0 plus augmented MDE of welds USAS 331.1.0 D+QA D+0A A

O+QA D+QA 0

D I

07/30/70 NA 07/30/70 0

I 07/30/70 NA 07/30/70 NA 07/30/70 O

NA 0

MA a

ANSI 831.1.0 a

I I

I I

B I

IELP/Systems,Class/Systems I.-

1 Comments Ci)

Is Ia la,lb,if Ye Yes Yes YesI la,1f li 1f.Iq Iq If I

1

Table 3.2-1 DAEC Classification of CoaspoScats in Systcas Principal Component

1. Piping and valves up to the first isolation valve of the Inboard sbsystem
2. Piping and valves, other
3. Blowers KMIX NVAC
1. Control room
2. Pump house
3. Emergency diesel generator room
4. Reactor building secondary containment isolation dampers
5. Battery rooms
6. Intake structure
7. Essential suitchgear rooms XXX Nacellaneous Components
1. Reactor Building Crane
2. Containment Penetrations for Process Piping and Electrical Scope of Su ply a)

Safety Class (b)

I g

2 GE 2

Code Class Construction Code (c)

Quality Group Class 1

ANSI 031.7 A

2 ASE Section C /

B 3

3 3

3 3 3 3

QualitY Assurance Req.

(d) 0 B

gI I

U 3

a 3

a 2

Category PO Date

(*)(f)

(g)

I I

I 1

I Equivalent ASME e & PV Code Section III (h)

Footnotes la,1b,1f ta.1b~1f 1

B I

IELP/Systems,Class/Systems Comments

- )

10

Table 39 DAEC Classification of Compoacats in Systems Footnotes Systems FootO FootNote a GE a General Electric; B a Bechtel; C - CBIl; IE - Iowa Electric Light & Power Co.

b 1, 2, 3, "other" - safety classes defined in Section 3.2.4; Ounc" - unclassified as defined in Section 3.2.4.

c The equipment shall be constructed in accordance with the codes listed in Table 3.2-2. if no Code of Construction is provided In this table. The term "construction", as used in this UFSAR,.includes provisions for design, materials, fabrication, erection, testing and inspection.

d 6

  • The equipment shall meet the quality assurance requirements of 10CFR50, Appendix 8, in accordance with the quality assurance program described in Chapter 17.

D a The equipment shall be constructed in accordance with the quality assurance requirements consistent with good practice for stem power plants.

e I

  • The equipment shall be constructed in accordance with the seismic r i

to for the safe shutdoun earthqua ke as de c n Section 3.7, Seismic Design.

The Incus o

system or structure within Seismic Category a not mean to ent re system or structure is Seismic Category I but rather th the system or structure has been evaluated those portions that lie eitin an defnhition of Se Ctegor e

r at h aThisced and isor ed for sismic respoe Na gie e rei s

fo apply forts dn atdin Code Css sall be uie passin th a toms Contion s

afeogu a q it a re s cte

1.

ADate n th pucoder fo there isimc oen etregrvided th can b te ued tof Tab sma)t s noedition and anda llectwforhthe cor mof hen eator c a-h bTiscoaum sh for Saforty o lass.

TeC ode iassn inerei a which oulnct d oapply-?

X SfeyCa2fo the urn dt oute iSltionI vale torb sda the c suoff valvetrotn valet XVI coundrthe seading insrodetlass isrhalieuse whic deermineted atoa Contrcto Codelasressue im l at GrA y fn the oumn solation ther is a cess shutoff the (root ale) to t Te sensing fooingtremstareon Appil the instrment smlins thoug thne (3/ot valv salldb ofshm a e assotd:ic ins the sysmtr whichh are at except r to cooline tha c~fpotain anoetces oflnowncseic vavegr IEC lires classiie asrQualit ros 0obeondith bon Se gur ha.saet Class 2 the instrument lines eod thhi are ve ied to to S

afety sCl sse fsr thor sation The aCe lasseon hess s toal which tohey ale ttahed. istr u er inst tunt li nes hbend a rte Cone t ed t o at uat e coan sdstpem, eaon and ano shall be td aae esfre o the ual e isuation Gvalve or the process shutoffevarveh(rootmvaee) the origyt sa te s"ensIn isoumninfe

  • ()tther Istrucoment rerinthog the room t vahe sh o ale Qualty c oai anecs0.wcekvle(FV r

lasfe sQaiyGopDbyn h

lb IEV. oige ase-2. appliabe f other Instrumentd lass bon d ppe and f g 3/4" noo vanae I-,

u aited as (n)

Ad soer.ins 3/ N nd t t hIe ar t f ot eto ctate-, IX soafey stshall be Quet Casit Grou D*

  • (2)Al I sme lines fromh te ounete isoation1-7 vacveor thean pressroo vavbhou gh thanae remainede tof athae sapein system shall be X5 X

thb A ensin 31.Cod rCaent 78app il fo rum1.7 ls s hc adCase2cpipecand ftotng 3/4acomia piltpe sz e

ndar anmall r o tlzdt cut aeyssessalb ult Xll-, XI XXXIII-1, I-~

7, 11-8, 11-13, 11-4, III-1, IV-4, IV-8, V-7, V-8, 3, IX-4, X-1, X-3, X-2, XI-3, MI-I, XI-7, XI-2, I-2, MIl-I, XII-3, XVIII-4, XVIII-3, XIX-4, XIX-3, 111-3, XXXIII-I, XXXIII-4, XXXIII-2, XXXVIll-2, lI-7 7,

1-1 -1,11-4, III-1, IV-8, V-7, V-8, VI-1, 3, X-, X-3, X-2, XI-3, I-1, XI-2, I-7, XII-2, I-1,AXVIII-3, XVIII-4, XIX-3, XIX-4, XXVIII-3, XXXVIII-2, XXXVIII-I, IELP/Footnote/Footnote 1 10

Table 3.2-1 DAEC Classification of Compoaents in Systems Footnotes Foot#

FootNote Systems 1c A module is an assembly of interconnected components which constitute an identifiable 11-14, 11-15, Ill-7, IV-10, V-9, VI-3, VII-1, VIII-1, Ix-10, device or piece of equipment. For example, electrical modules include sensors, power IX-11, X-9, xi-i0,-Xii-10, XVIII-8, XIX-8, XXI-1, XXII-I, supplies, and signal processors. Mechanical modules include turbines, strainers, and XXIII-7, XXIV-5, XXV-S,XxXlx-6, orifices.

id GE Specification 21AII00AS (Ref. 243) adds the following code requirements to the Reactor 1-1, 1-2, 1-3, 1-5, 1-9, Vessel: The Winter 1967 Addenda to the ASHE Code Section III is not to be included as a basis for purchase of this vessel, except as follows: 1)charpy impact tests per N-331.2 of the Winter 1967 Addenda will be furnished; 2)Welds are to be ultrasonically examined using the angle beam method described by I-62S of Minter 1967 Addenda; 3)The changes to Article 4-Design by the Winter 1967 Addenda are included; 4)The addition of Appendix IX-Quality Control and Nondestructive Examination Methods is included.

to For pump designs, the applicable class, section, or subsection of the referenced ASME BAPV 111-4, V-2, IX-5, X-4, X1-4, Xil-4, XVIll-5, xix-5, XXiII-4, Cqde is used as a guide in calculating the thickness of pressure-retaining portions of the XXIV-2, XXV-2, pump and in sizing cover bolting. For example, use ASHE Section III, Class C, 1968 Edition, for a design guide for Quality Group A & B pumps. For Quality Group 0 below 150 psig and/or 212 deg. F, manufacturer$s standard pump for service intended may be used.

if ANSI 816.5 or NSS-SP-66 apply for valves [Note NSS-SP-66-1964 was withdrawn from 11-9, 11-10, 11-11, 11-12, 11-13, 111-5, IV-1, IV-2, IV-3, lication in favor of ANSI 016.34-19731.

IV4, V.4, V-5, V.6, VI-2, IX-8, lX-9, lX-7, X-7, X-6, X-8, ar/,,,e are I-5, xl-6, xI-8, XII-5, xll-6, X1l-8, xVIII-6, XVIll-7, XIN-6, MIX-7, xx-6, XMIll-6, XXIll-5, xxIV-4, xxV-4, xxxill-3, anoth'MXXIll-4, xxxiv-2, EXXVII-1, xxxVIII-1, xxxvill-2, 1g The RCICturbi aonot fall within the applicable design codes. To assure that the (27 11-9, fabicated to the standards commensurate with their safety and performance requirements, General Electric has established specific design requirements for

use, componetU; th ExistingAPI/AWA standards and supplementary requirments apply. Tanks are to be XVIII-i, XXIII-1, constructed to meet the Intent of API Standards 620 or 650 or AWA Standard 0100 for those fuel, oil, or water storage tanks.

1i The condensate storage tank will be designed, fabricated and tested to meet the intent of XXXIV-1, API Standard 650. In addition, the specifications for this tank will require 100% surface examination of the side wall to bottom joint and 100% volumetric examination of the side wall weld joints.

1i ASNE Section VIII, Division 1, and USAS 831.1.0 apply downstream of the outermost isolation XVIll-4, XVill-5, XViII-6, XVIII-7, XVIII-8, valves.

1k The gaseous raduaste system piping, pumps and valves containing gaseous radwaste shall be XXIII-3, XXIll-4, XXIII-5, XXIII-6, constructed in accordance with the applicable codes of Quality Group D.

11 Some of this piping was also constructed to 831.1.0 IV-4, IV-8, im Some lines, such as ECB-9 (drain to filter/demineralizer), are class 3, non-seismic.

V-8, in This system includes reactor head spray.

X-1, to Lines DC8-1 and DC8-2 are nuclear class 3, according to Bechtel Specification N-190.

XIX-4, XIX-7, ip The RNRSU backwash line (GBD-62 and GBO-63) is non-seismic, according to Bechtel XXV-1, XXV-4, Specification M-190, Sheet 23A.

Iq Portions of this system which supply suction for HPCI, RCIC, and Core Spray from the XXXIV-2, XXXIV-3, condensate storage tank are seismic category I.

Ir The return line to the condensate storage tank was classified as "Q" by Bechtel in the XI-3, XII-3, 0-list (Ref. 225) and was built that way by Bechtel. However, these lines are actually Quality Group 0, with no QA requirement. That is the way these lines are classified in this table.

is The Bechtel 0-list (Ref. 225, item 2.4365) notes this item as 0. However, the entry refers XXVI-3, XXVI-2, XXVII-2, to Bechtel Specification N-119 (Reference 252). This document addresses Seismic Category I supports only. Therefore, only the supports in this item have a requirement for quality assurae and are Seismic Category I.

I Et I

IELP/Footnote/Footnote I'I'~

t'.

Table 3.

DAEC Classification of Componnts in Systems Pootnotes Systems Foot#

FootNote it The Bechtel 0-tist (Ref. 225, Item 2.1510) notes this item as 0. However, only pipe xIX-I, XIX-2, XIX-4, XIX-5, XIX-7, x hangers and supports provide a specification (N-119, Ref. 252) as a reference. Therefore, only pipe hangers and supports for this item are seismic category I and have special Quality Assurance requirements.

lu See GE docunent NEDC-31853 (Ref. 2) "Duane Arnold Design Safety Standards", Appendix A, for 1-5, 1-6, 1-9, IX X

-e IELP/Footnote/Footnote 2:~~~~~~~~~~~2 1~e5

~

2,4V?/

-~-4/

7

/

4

~

4e

-~

~

7e

/~

~

~_

e, I 10 I ()

~J4O I

I-~o IX-8,

Table 3.2-1 DAEC Classification of ComPoncals in Systems 10 Comments SysD/Comp#

Caments IV

4.

1 The design and construction specifications for the hydraulic control unit (HCU) do invoke such codes and standards as can be reasonably applied to individual parts in developing required quality levels, but these codes and standards are supplemented with additional requirements for these parts and for the remaining parts and details.

For example: (1) all welds are liquid-penetrant inspected; (2) alt socket welds are checked for minimum engagement and and gap between pipe and socket bottom by a marking technique; (3) all welding was performed by qualified welders; (4)all work was done per written procedures.

The following examples are typical of the problem associated with codes designed to control field-asseabled comporants wdhen applied to the design and production of factory fabricated specialty components: **1.

The HCU nitrogen gas bottle is a spun forging that is mechanically joined to the accumulator.

It stores the energy required to scram a drive at low vessel pressure.

It has been code stamped since its introduction in 1966, although its size exempts it from mandatory stamping.

It is constructed of a material listed by the ASHE BAPV Code,Section VIII, that was selected for its strength and formability.

    • 2. The scram accumulator is joined to the HCU by a split flange joint chosen for its compact design to facilitate both assembly and maintenance.

Both the design and construction conform to the 931.1.0 10 piping code.

This joint, which requires a design pressure of 1750 psig, has been proof tested to 10,000 pal.

    • 3. The accumulator nitrogen shutoff valve is a 6.000 pal cartridge valve whose copper alloy material is listed In the ASHE BAPV Code, Section ViII.

The valve was chosen for this service partly because it is qualified by the U.S. Navy for submarine service.

    • 4.

The directional control valves are solenoid pilot-operated valves that are subplate mounted on the HCU.

The valve has a body specialty designed for the NCU, but the operating parts are identical to a commercial valve with a proven history of satisfactory service.

The pressure retaining parts are stainless steel alloys chosen for service, fabrication and magnetic properties.

The manufacturer cannot substitute a code material for that used for the solenoid core tube.

The foregoing examples are not ment to justify one pressure integrity quality level or another, but to demonstrate that the codes and standards invoked by those quality levels are not strictly applicable to special equipment and part designs.

Group D classification is generally applicable because the codes and standards invoked by that classification contain clauses that permit the use of manufacturer's standards and proven design techniques that are not explicitly defined within those codes.

This was supplemented by the quality control techniques described above.

IV

4.

2 Bechtel built these items to ASNE Class 2 standards, based on the piping classes given on the PID (see paragraph 3.2.7).

However, based on the CA classification of these item, they should have been Class 3. The higher class is shown on this table, although Class 3 is justifiable and would make more sense with the GA Group 0 designation.

IV

8.

1 The design and construction specifications for the hydraulic control unit (HCU) do invoke such codes and standards as can be reasonably applied to individual parts in developing required quality levels, but these codes and standards are supplemented with additional requirements for these parts and for the reaining parts and details.

For example: (1) all welds are liquid-penetrant inspected; (2) all socket welds are checked for minimu engagement and end gap between pipe and socket bottom by a marking technique; (3) at welding was performed by qualified welders; (4)alI work was done per written procedures.

The following examples are typical of the problems associated with codes designed to control field-assembled components when applied to the design and production of factory fabricated specialty components: **1.

The NU nitrogen gas bottle is a spun forging that is mechanically joined to the accsuulator.

It stores the energy required to scram a drive at low vessel pressure.

It has 10 been code.steeped since its introduction in 1966, although its size exempts it from mandatory stamping.

It is constructed of a material listed by the ASNE B&PV Code,Section VIII, that was selected for its strength and formability.

    • 2. The scram accumulator is joined to the HCU by a split flange joint chosen for its compact design to facilitate both asseobly and maintenance.

Both the design and construction conform to the 631.1.0 piping code.

This joint, which requires a design pressure of 1750 psig, has been proof tested to 10,000 pal. **3.

The accumulator nitrogen shutoff valve is a 6,000 psi cartridge valve whose copper alloy material is listed In the ASNE BAPV Code, Section Vill.

The valve was chosen for this service partly because it is qualified by the U.S. -Navy for submarine service.

    • 4. The directional control valves are solenoid pi(ot-operated valves that are subptate mounted on the HCU.

The valve has a body specially designed for the HCU, but the operating parts are identical to a commercial valve with a proven history of satisfactory service.

The pressure retaining parts are stainless steel alloys chosen for service, fabrication and magnetic properties.

The manufacturer cannot substitute a code material for that used for the solenoid core tube.

The foregoing examples are not mant to justify one pressure integrity quality level or another, but to demonstrate that the codes and standards invoked by those quality levels are not strictly applicable to special equipment and part designs.

Group D classification is generally applicable because the codes and standards invoked by that classification contain clauses that permit the use of manufacturer's standards and proven design techniques that are not explicitly defined within those codes. This was supplemented by the quality control techniques described above.

IV

8.

2 Bechtel built these items to ASME Class 2 standards, based on the piping classes given on the PLID (see paragraph 3.2.7). However, based on the OA classification of these items, they should have been Class 3. The higher class is shown on this table, although Class 3 is justifiable and would make more sense with the CA Group D designation.

IELP/Systems/SysComts

'ROW 'Table 3W 'W DABC ('lassificatina of Componen s in Systems Commcals Sys#/Campe Comments IV 7 The design and construction specifications for the hydraulic control unit (NCU) do invoke such codes and standards as can be reasonably applied to individual parts in developing required quality levels, but these codes and standards are supplemented with additional requirements for these parts and for the remaining parts and details.

For example: (1) all welds are liquid-penetrant inspected; (2) all socket welds are checked for minima engagement anid end gap between pipe and socket bottom by a marking technique; (3) all welding was performed by qualified welders; (4)all work was done per written procedures.

The following examples are typical of the problems associated with codes designed to control field-assembled copnents uhen applied to the design and production of factory fabricated specialty components: **1.

The EIU nitrogen gas bottle is a spun forging that is pchanically joined to the accumulator.

It stores the energy required to scram a drive at low vessel pressure.

It has been code stamped since its introduction in 1966, although its site exempts it from mandatory stamping.

It is constructed of a material listed by the ASHE APV Code, Section Wi1, that was selected for its strength and formability.

    • 2. The scram accumulator is joined to the HCU by a split flange joint chosen for its compact design to facilitate both assembly and maintenance.

Both the design and construction conform to the 831.1.0 piping code.

This joint, which requires a design pressure of 1750 paig, has been proof tested to 10,000 psi. **3.

The accumulator nitrogen shutoff valve is a 6,000 psi cartridge valve whose copper alloy material is listed in the ASHE BAV Code, Section Vill.

The valve was chosen for this service prtly because it is qualified by the U.S. Navy for subsrine service.

    • 4. The directional control valves are solenoid pilot-operated valves that are subplate mounted on the NCU.

The valve has a body specially designed for the MCU, but the operating parts are identical to a commerciat valve with a proven history of satisfactory service.

The pressure retaining parts are stainless steel alloys chosen for service, fabrication and magnetic properties.

The manufacturer cannot substitute a code material for that used for the solenoid core tube.

The foregoing examples are not meant to justify one pressure integrity quality level or another, but to demonstrate that the codes and standards invoked by those quality levels are not strictly applicable to special equipment and part designs.

Group D classification is generally applicable because the codes and standards invoked by that classification contain clauses that permit the use of manufacturer's standards and proven design techniques that are not explicitly defined within those codes.

This was supplemented by the quality control techniques described above.

V

1.

1 The standby liquid control storage tank is designed, fabricated, inspected, and tested to meet the intent of API Standard 650 and the ASHE BLPV Code, Section Vill, Division 1. All butt welds are given spot radiographic examination.

Liquid-penetrant inspection is conducted per the ASNE Code, Section ViII, Division 1, on the following welds: **(1)AII tank nozzle welds below and including the overflow nozzle are examined internally and externally to the tank.

    • (2)Att fillet and socket welds receive a random examination.

V

1.

2 The construction of the accumulator is in accordance with the requirements of the ASHE BAPV Code,Section VIII, Division 1. An ASHE stamp is required.

Other codes applied to the accumulator are as follows: **(1)AMSI 816.11 OForged Steel Fittings, Socket Uelded and Threaded".

    • (2)AND 10050 "Bosses, Standard Dimensions for Gasket Seat Straight Thread.

VI

3.

1 See IELP letter to the USMRC, NG-91-2652, dated 8/27/91, for inclusion of the 24 V D. C. Power Supply with this Item.

10 XI

9.
1. The HPCI turbine is categorized as machinery and thus does not fall within the classification groups as earlier identified.

To ensure that the turbine was fabricated to the standards commensurate with its performance requirements, General Electric has established specific design requirements for this component, as follows:

    • (1)AII welding was qualified in accordance with Section IX of the ASHE B&PV Code.
    • (2)Att pressure retaining castings and fabrications were hydrotested to 1.5 x design pressure.
    • (3)Att high pressure castings were radiographed according to ASTN E-94 (201 coverage, minimum), ASTN E-142 (severity level 3), ASTN-71, ASTN 186, or ASTN-280.
    • (4)As-cast surfaces were magnetic particle or liquid-penetrant tested according to the ASE UAPV Code,Section III, 1968 Edition, paragraph M323.3 or N323.4.
    • (5)Uheel and shaft forgins were ultrasonically tested according to ASTN A388.
    • (6)Butt welds were radiographed according to the ASHE BAPV Code,Section III, 1968 Edition paragraph N626 or N627.
    • (7)Motifieation made on any major repairs and records maintained.
    • (8)Record system and traceability acco

-ing to the ASM B&PV Code,Section III, 1968 Edition, IX-225. **(9)Control and identification according to the ASHE BAPV Code,Section III, 1968 Edition, IX-226.

  • (10O)Procedures conform to the ASHE M&PV Cot*

IJdi Io IN-300. !** _Jnspection personnel are qualified according to the ASHE BAPV Code,Section III, 1968 Edition, IX-400 C11-9e

, 2>

Xii

9.

1 The RCIC turbine is categorized as machinery and thus does not fall within the ciao ensure that the turbine was fabricated to the standards commensurate with its performance requirements, General Electric has established specific design requirments for this component, as follows:

    • (1)All welding was qualified in accordance with Section IX of the ASHE UPV Code.
    • (Z)AII pressure retaining castings and fabrications were hydrotested to 1.5 x design pressure.
    • (3)AII high pressure castings were radiographed according to ASTN E-94 (20% coverage, minimum), ASTH E-142 (severity level 3), ASTN-71, ASTM-186, or ASTM-280.
    • (4)As-cast surfaces were magnetic particle or liquid-penetrant tested according to the ASHE BAPV Code, Section 1I, 1968 Edition, paragraph N323.3 or N323.4.
    • (5)Uheel and shaft forgin a were ultrasonically tested according to ASTN A388.
    • (6)8utt welds were radiographed according to the ASHE atPV Code,Section I 1on paragraph N626 or 1627.
    • (7)Notification made on any major repairs and records maintained.
    • (8)Record system and traceability according to the ASHE BAPV Code, Section 1I, 1968 Edition, IX-225.
    • (9)Control and identification according to the ASHE 8&PV Code, Section Ill, 1968 Edition, IX-226. **(10)Proceduras conform to the ASK! BPV Code t

I

-3.

    • (11)Inspection personnel are qualified according to the ASME BAPV Code, Section Ill, 1968 Edition, IX-400.

/$2

-gt/-ef E

,a.,',k

Table 3.2-1 DABC Classificatin of Compoacals in Systems t 0 Commeals Sys#/Compf Comments XVIII

1.

1 Unprocessed liquid radioactive waste piping and equipment pressure parts installed prior to January 1, 198.

were classified as Quality Grop C.

Unprocessed liquid radioactive waste piping and equipment pressure parts installed subsequent to January 1, 1983, my be included in Quality Group D with added quality control (D+QA) in accordance with the design guidance contained in Regulatory Guide 1.143, Revision 1, modified as follows:u (1)Paragraphs C.4.1.3, C.2.1.3, and C.3.1.3 - The commitment is limited to the selmic design methods used in the original construction of the DAEC and is not uprgraded to Regulatory Guide 1.143, Revision 1, requirements.

    • (2)Paragraph C.4.3 - System will be fabricated in accordance with good operability, maintenance, and repairability practices. **(3)Paragraph C.6 - All of paragraph C.6 is replaced in its entirety by the following senteeme. t*AI safety related systems or portions of systems shall be designed, fabricated and installed in accordance with Quality Level 11 requirements.0 Vill
4.

1 Unprocessed liquid radioactive waste piping and equipment pressure parts Installed prior to January 1, 1983, were classified as Quality Group C.

Unprocessed liquid radioactive waste piping and equipment pressure parts Installed subsequent to January 1, 1983, may be included in Quality Group J

0 with added quality control (D+M4) in accordance with the design guidance contained in Regulatory Guide 1.143, Revision 1, modified as follows:

7 '<

,Z

  • (1)Paragraphs C.1.1.3, C.2.1.3, and C.3.1.3 - The commitment is limited to the seismic design methods used in the original construction of the

""AEC and is not uprgraded to Regulatory Guide 1.143, Revision 1, requirements.

    • (2)Paragraph C.4.3 - Systems will be fabricated in accordance ulith good operability, maintenance, and repairability practices.
    • (3)Paragraph C.6 - All of paragraph C.6 is replaced in its entirety by the following sentence.

At safety related systes or portions of systes shall be designed, fabricated and Installed in accordance with Quality

/1 Lee II requirements.6 I

7.

1 Tme ogas takiution fans are Sesmic Class Inmust meet the total Q lity Assurance Program.

SV me gency serv ce ws er system meets the pressure integrity requirements oi y

nc ng the additional quality assurance 10 requirements for *critical* piping, as stated in Section 17.1.8.1.

All inspection records will be retained according to the Quality Assurance Program of Chapter 10. These records include data pertaining to the qualification procedures and examination results.

KWMIll

1.

1 For Main Stem and Turbine "ypass piping and valves, alt inspection records were retained according to the Quality Assurance Program of Chapter 10

17.

These records include data pertaining to the qualification of inspection personnel, examination procedures, and examination results.

XXXIII

1.

2 Turbine Stop, Control, and Bypass Valves: A certification was obtained from the vendors of these valves Indicating that all cast 10 pressure-retaining parts of a size and configuration for which volumstric examination methods are effective have been examined by radiographic methods by qualified personnel.

Ultrasonic examination to equivalent standards are used as an alternative to radiographic methods.

XXXill

1.

3 The main steam piping between the outermost containment isolation valves up to the turbine stop valves, the main turbine bypass piping up to the 10 turbine bypass valves and all branch line connected to these portions of the main steam and turbine bypass piping up to the first valve capable of timely actuation are classified as Quality Group 0 and meet the additional quality assurance requirements for *critical* piping, as stated in Section 17.1.8.1, Schedule IV.

XXXIII

1.

4 The first valve capable of timely actuation in branch lines connected to the main steam lines between the outermost containment isolation valves I 10 and turbine stop valves and connected to the turbine bypass valves meets all of the pressure integrity requirements of Quality Group 0, including the additional quality assurance requirements for "critical* piping, as stated in Section 17.1.8.1, Schedule IV.

Xxill

1. 5 All inspection records for the min steam and turbine bypass piping and the first valve in the branch lines connected to this piping were retained 10 according to the Quality Assurance Program of Chapter 17.

These records include date pertaining to the qualification of Inspection personne(,

examination procedures, and examination results.

xxxIll

4.

1 Materials used in feedwater control valves are as follows:

    • (1)Valve body is ASTM A105 Gr. II.
    • (2)Valve bonnet is ASTM A105 Gr. II and A234 I 10 Gr. UP.

XXXIII

4.

2 Examination and testing requirements for the feedeater control valves are as followss

  • (1)All pressure retaining castings are radiographed, after final heat treatment, in accordance with the ASHE BAV Code,Section III, Appendix IX, paragraph 330 and ASTM E142.

Discontinuities are judged by ASTN E71, E166, and E280.

    • (2)AIt accessible surfaces of all pressure retaining castings are examined in finished condition, after final heat treatment, by either liquid penetrant methods per paragraph M323.4 or magnetic particle methods per paragraph M323.3, with acceptance criteria per paragraph 1323.4 of the Sumer 1969 addenda to ASME Section Ill. **(3)All pressure retaining forgings are examined In the as-furnished condition by the ultrasonic method per paragraph M322 of the summer 1969 Addenda to ASME,Section III.

KXMIV

1.

1 The condensate storage tank was designed, fabricated, and tested to meet the Intent of API Standard 650. In addition, the specifications for this tank require (1) 1001 surface examination of the side wall to bottom joint and (2) 1001 volumetric examination of the aide wall weld joints.

10 XXXIV

1.

2 Page 13.2-5 of the UFSAR (Ref. 233) says that the CST is non-seismic.

GENERAL 1 B31.1.0 and 331.7 were originally published as USA Standards (USAS), but are now designated as ANSI Standards.

GENERAL 2 See additional material examination requirements of Section 17.1.8.1 for piping and valves.

GENERAL 3 Code effective date is obtained by the Purchase Order date for the particular component (see Table 3.2-1) or by referring to Table 3.2-2.

IELP/Systems/SysComts A

Insert XXIII -3,4,5,6 Sys#/Comp# I Comments XXIII

3.

1 The construction codes used for Offgas pipe, pumps, and valves were USAS B31.7; ASME Sections III and VIII; and the Draft Pump and Valve Code. To identify the correct code for a component it is necessary to research the receiving inspection files (File Q2.321).

There are two reasons that several codes and dates were applied. The first reason is that the Offgas design was changed during Procurement/Construction. The second reason is that the codes were changing rapidly during the period of the design. The project correspondence which records when the Offgas System construction code was changed is given in APED-N62-076.

XXIII

4.

1 The construction codes used for Offgas pipe, pumps, and valves were USAS B31.7; ASME Sections III and VIII; and the Draft Pump and Valve Code. To identify the correct code for a component it is necessary to research the receiving inspection files (File Q2.321).

There are two reasons that several codes and dates were applied. The first reason is that the Offgas design was changed during Procurement/Construction. The second reason is that the codes were changing rapidly during the period of the design. The project correspondence which records when the Offgas System construction code was changed is given in APED-N62-076.

XXIII

5.

1 The construction codes used for Offgas pipe, pumps, and valves were USAS B31.7; ASME Sections III and VIII; and the Draft Pump and Valve Code. To identify the correct code for a component it is necessary to research the receiving inspection files (File Q2.321).

There are two reasons that several codes and dates were applied. The first reason is that the Offgas design was changed during Procurement/Construction. The second reason is that the codes were changing rapidly during the period of the design. The project correspondence which records when the Offgas System construction code was changed is given in APED-N62-076.

XXIII

6.

1 The construction codes used for Offgas pipe, pumps, and valves were USAS B31.7; ASME Sections III and VIII; and the Draft Pump and Valve Code. To identify the correct code for a component it is necessary to research the receiving inspection files (File Q2.321).

There are two reasons that several codes and dates were applied. The first reason is that the Offgas design was changed during Procurement/Construction. The second reason is that the codes were changing rapidly during the period of the design. The project correspondence which records when the Offgas System construction code was changed is given in APED-N62-076.

C: \\procedur\\Tbl3-2-1.kep

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