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{{#Wiki_filter:ANS 3.2 Side-By Side Comparison           7/25/2012 1 1 Numbers in brackets refer to corresponding numbers in Sec. 4, "References." Proposed ANS 3.2 Wording American National Standard ANSI/ANS 3.2-2012 Administrative Controls for the Operational Phase of Nuclear power Plants Staff Comments/COLP Verification Wording from ANS 3.2 1976 Wording from ANS 3.2 1982 1. Scope, Applicability and Purpose 1.1 Scope and Applicability. This standard provides requirements and recommendations for managerial and administrative contro ls to ensure that activities associated with operating a nuclear power plant are carried out without undue risk to the health and safety of the public. This standard provides requirements for implementing managerial and administrative controls consistent with requirements of 10 CFR 50, Appendix B [1].
{{#Wiki_filter:ANS 3.2 Side-By Side Comparison Proposed ANS 3.2 Wording                                                                                       7/25/2012 Staff American National Standard ANSI/ANS 3.2-2012 Comments/COLP     Wording from ANS 3.2 1976                   Wording from ANS 3.2 1982 Administrative Controls for the Operational Phase of Nuclear        Verification power Plants
1 This standard is not specifically intended for application to test, mobile, experimental reactors, nor reactors not subject to U.S. Nuclear Regulatory Commission licensing. Although the standard is based on USNRC requirements the approach is applicable with modifications to reflect the regulatory requirements in the country of application. Applicable sections of this standard may be used in those cases for activities similar to those addressed herein. This Standard is intended to be consistent with applicable criteria for quality assurance, including those given in Title 10, Code of Federal Regulations, Part 50, "Licensing of Production and Utilization Facilities," Appendix B. [1]1 1.2 Purpose. This standard contains requirements for managerial and administrative controls for nuclear power plants during the operational phase of plant life. This phase is generally considered to commence prior to initial fuel loading at a time identified by the owner organization. Certain initial construction activities may extend past fuel loading and certain operational activities may take place prior to fuel loading. The owner organization is expected to identify those activities that are included in these overlapping time periods and are expected to specify whether the This Standard fully and completely describes the general requirements and guidelines of American National Standard Quality Assurance Program Requirements for Nuclear Power Plants, N45.2-1971, [2] as those requirements and guidelines apply during the operational phase of plant life.  
: 1. Scope, Applicability and Purpose 1.1 Scope and Applicability.
This standard provides requirements and recommendations for                             This Standard is intended to be consistent managerial and administrative controls to ensure that activities                       with applicable criteria for quality associated with operating a nuclear power plant are carried out                         assurance, including those given in Title without undue risk to the health and safety of the public.                             10, Code of Federal Regulations, Part 50, "Licensing of Production and Utilization This standard provides requirements for implementing                                   Facilities," Appendix B. [1]1 managerial and administrative controls consistent with requirements of 10 CFR 50, Appendix B [1].1 This standard is not specifically intended for application to test, mobile, experimental reactors, nor reactors not subject to U.S.
Nuclear Regulatory Commission licensing. Although the standard is based on USNRC requirements the approach is applicable with modifications to reflect the regulatory requirements in the country of application. Applicable sections of this standard may be used in those cases for activities similar to those addressed herein.
1.2 Purpose.
This standard contains requirements for managerial and                                 This Standard fully and completely administrative controls for nuclear power plants during the                             describes the general requirements and operational phase of plant life. This phase is generally considered                     guidelines of American National Standard to commence prior to initial fuel loading at a time identified by the                   Quality Assurance Program Requirements owner organization. Certain initial construction activities may                         for Nuclear Power Plants, N45.2-1971, [2]
extend past fuel loading and certain operational activities may                         as those requirements and guidelines take place prior to fuel loading. The owner organization is                             apply during the operational phase of plant expected to identify those activities that are included in these                       life.
overlapping time periods and are expected to specify whether the 1
Numbers in brackets refer to corresponding numbers in Sec. 4, References.
1


ANS 3.2 Side-By Side Comparison           7/25/2012 2 activities are to be considered as operational or as construction activities. This phase continues until the operating license is withdrawn. The managerial and administrative controls of this standard promote safe, reliable and efficient plant operation. This standard may be applied to other activities consistent with the degree to which those activities affect plant reliability. In keeping with this intent, the provisions in this standard may be applied to operational activities other than those specified in the Scope, consistent with the degree to which those activities affect these functions, compliance with regulations specifying radiation dose and contamination criteria, or plant reliability. Applicable portions of this standard may also be used for activities at reactors specifically excluded in the Scope. This standard is intended to be implemented together with the applicable elements of ASME NQA-1-2008 and the NQA-1a-2009 addenda [2]. ASME NQA-1 is the standard that provides the appropriate Quality Assurance requirements for all phases. This standard provides the managerial and administrative requirements needed to assure safe operation of a facility.   
ANS 3.2 Side-By Side Comparison 7/25/2012 activities are to be considered as operational or as construction activities. This phase continues until the operating license is withdrawn.
The managerial and administrative controls of this standard promote safe, reliable and efficient plant operation. This standard may be applied to other activities consistent with the degree to which those activities affect plant reliability. In keeping with this intent, the provisions in this standard may be applied to operational activities other than those specified in the Scope, consistent with the degree to which those activities affect these functions, compliance with regulations specifying radiation dose and contamination criteria, or plant reliability. Applicable portions of this standard may also be used for activities at reactors specifically excluded in the Scope.
This standard is intended to be implemented together with the applicable elements of ASME NQA-1-2008 and the NQA-1a-2009 addenda [2]. ASME NQA-1 is the standard that provides the appropriate Quality Assurance requirements for all phases. This standard provides the managerial and administrative requirements needed to assure safe operation of a facility.
2 Definitions                                                                        2. Definitions                          2. Definitions 2.1 Glossary of Terms                                                                2.2 Glossary or Term                    2.2 Glossary of Terms The terms defined in NQA-1 apply to this standard and are not duplicated herein.
experiments: performance of those plant operations executed                          Experiments. Performance of those plant Experiments. Performance of those plant under controlled conditions in order to establish characteristics or                operational carried out under controlled operations carried out under controlled values not previously known.                                                        conditions in ord., to establish        conditions in order to establish characteristics or values not previously characteristics or values not previously known.
known.
independent review: review completed by personnel not having                        Independent review. Review completed    Independent review. Review completed by direct responsibility or direct involvement in the work function                    by personnel not having direct          personnel not having direct responsibility 2


2 Definitions
ANS 3.2 Side-By Side Comparison 7/25/2012 under review.                                                                              responsibility for the work function under for the work function under review review regardless of whether they operate  regardless of whether they operate as a as a part of an organizational unit or as  part of an organizational unit or as individual staff members (see review).
: 2. Definitions
individual staff members (see review ).
: 2. Definitions2.1 Glossary of Terms  The terms defined in NQA-1 apply to this standard and are not duplicated herein.
managerial and administrative controls: rules, orders,                                    Administrative controls. Rules, order,    Administrative controls *. Rules, order instructions, procedures, policies, practices, and designations of                        instruction&, procedures, policies,        instructions, procedures, policies, authority and responsibility.                                                              practices and designations of authority    practices and designations of authority and responsibility.
2.2 Glossary or Term 2.2 Glossary of Terms experiments:  performance of those plant operations executed under controlled conditions in order to establish characteristics or values not previously known.
and responsibility.
Experiments. Performance of those plant operational carried out under controlled conditions in ord., to establish characteristics or values not previously known. Experiments. Performance of those plant operations carried out under controlled conditions in order to establish characteristics or values not previously known. independent review:  review completed by personnel not having direct responsibility or direct involvement in the work function Independent review. Review completed by personnel not having direct Independent review. Review completed by personnel not having direct responsibility 
owner organization: the organization, including the on-site                                Owner organization. The organization, operating organization, that has overall legal, financial, and                            including the onsite operating technical responsibility for the operation of one or more nuclear                          organization, which has overall legal, power facilities.
financial and technical responsibility for the operation of one or more nuclear power plants.
operating organization: the organization concerned with daily        New Definition operation, maintenance, and related technical services. This organization may include personnel located off-site who provide operational support.
shall, should and may: the word "shall" is used to denote a                                shall, should and may. The word shall is requirement; the word "should" to denote a recommendation; and                            used to denote a requirement; the word, the word "may," to denote permission neither a requirement nor a                          should to denote a recommendation; and recommendation.
the word may to denote permission, neither a requirement nor a recommendation.
3 Requirements 3.1 Organization                                                                          3. Owner Organization                      3. Owner Organization 3.1.1 General                                                                              3.1 General                                3.1 General Managerial and administrative controls which comply with this        NQA-l, Basic        The owner organization shall establish an  The owner organization shall establish an standard shall be established. The controls shall be in effect at all Requirement 2. Ok. administrative controls and quality        administrative control and quality times during the operational phase. The controls shall require that                        assurance program which complies with      assurance program which complies with 3


ANS 3.2 Side-By Side Comparison           7/25/2012 3 under review.
ANS 3.2 Side-By Side Comparison 7/25/2012 decisions are made at the proper level and with the necessary                            this Standard. The program shall be in        this standard. The program shall be in reviews. The organization responsible for establishing and                                effect at all times during the operational    effect at all times during the operational executing the administrative controls in accordance with this                            phase to assure that operational phase        phase to assure that operational phase standard may delegate any or all of the work to others, but shall                                                                        activities are carried out without undue risk activities are carried out without undue risk retain overall responsibility.                                                                                                          to the health and safety of the public. The to the health and safety of the public. The    program shall require that decision program shall require that decisions          affecting safety made at the proper level of affecting safety are made at the proper        responsibility and with the necessary level of responsibility and with the          technical advice and review. The owner necessary technical advice and review.         organization may delegate to other The owner organization may delegate to        organizations the work of establishing and executing the administrative controls and other organizations the work of Quality assurance program or any part.
responsibility for the work function under review regardless of whether they operate as a part of an organizational unit or as individual staff members (see review ). for the work function under review regardless of whether they operate as a part of an organizational unit or as individual staff members (see review). managerial and administrative controls:  rules, orders, instructions, procedures, policies, practices, and designations of authority and responsibility.
establishing and executing the                thereof, in accordance with this standard.
Administrative controls. Rules, order, instruction&, procedures, policies, practices and designations of authority and responsibility. Administrative controls *. Rules, order instructions, procedures, policies,  practices and designations of authority and responsibility. owner organization:  the organization, including the on-site operating organization, that has overall legal, financial, and technical responsibility for the operation of one or more nuclear power facilities.
administrative controls and quality            but shall retain responsibility there for.
Owner organization. The organization, including the onsite operating organization, which has overall legal, financial and technical responsibility for the operation of one or more nuclear power plants.
assurance program or any part thereof, in accordance with this Standard, but shall retain responsibility therefore.
operating organization:  the organization concerned with daily operation, maintenance, and related technical services. This organization may include personnel located off-site who provide operational support.
3.1.2 Assignment of Authority and Responsibility.                                        3.2 Assignment of Authority and               3.2 Assignment of Authority and Responsibility                                Responsibility Lines of authority, responsibility, and communication shall be      NQA-1, Basic        It is essential that all members of the        It is essential that all members of the established and defined for the corporate, plant operating, and     Requirement 2. Ok. organization involved in operation of          organization involved in operation of support organizations. These relationships shall be documented                            nuclear power plants, including those at      nuclear power plants, including those at and updated, as appropriate, in the form of organizational charts,                        the highest management levels, recognize      the highest management levels, recognize functional descriptions of departmental responsibilities and                             the necessity that the plants be operated      the necessity that the plants be operated relationships and job descriptions for key personnel positions or in                      under a well formulated and detailed          under a well formulated and detailed equivalent forms of documentation.                                                       administrative controls and quality            administrative control and quality assurance program to assure safety and        assurance program to ensure safety and efficiency. Lines of authority, responsibility efficiency. Lines of authority responsibility and communication shall be established        and communication shall be established from the highest management level              and well defined from the highest through intermediate levels to and            management level through intermediate including the onsite operating organization    level, to and including all onsite operating (including those offsite organizational units  organization position with involvement in assigned responsibility for procurement,      activities affecting the safety of the nuclear design and construction, quality              power plant including those offsite assurance, and technical support              organizational positioning under assigned activities).                                   responsibility for procurement, design and construction, quality assurance and These relationships shall be documented        technical support activities.
New Definition shall, should and may:  the word "shall" is used to denote a requirement; the word "should" to denote a recommendation; and the word "may," to denote permission neither a requirement nor a recommendation.
and updated, as appropriate, in the form of organizational charts, functional              These relationships shall be documented 4
shall, should and may. The word "shall" is used to denote a requirement; the word, "should" to denote a recommendation; and the word "may" to denote permission, neither a requirement nor a recommendation.
3 Requirements 3.1 Organization
: 3. Owner Organization 3. Owner Organization 3.1.1 General 3.1 General3.1 GeneralManagerial and administrative controls which comply with this standard shall be established. The controls shall be in effect at all times during the operational phase. The controls shall require that NQA-l, Basic Requirement 2. Ok. The owner organization shall establish an administrative controls and quality assurance program which complies with The owner organization shall establish an administrative control and quality  assurance program which complies with 


ANS 3.2 Side-By Side Comparison           7/25/2012 4 decisions are made at the proper level and with the necessary reviews. The organization responsible for establishing and executing the administrative controls in accordance with this standard may delegate any or all of the work to others, but shall retain overall responsibility.
ANS 3.2 Side-By Side Comparison 7/25/2012 descriptions or departmental                and Updated, as appropriate in the form of responsibilities and relationships and job  organizational chart, functional description descriptions for key personnel positions or  of departmental responsibilities and in equivalent forms of documentation. The   relationships and job description for key owner organization shall specify in writing  personnel positioned or in equivalent forms the authority and responsibility assigned to of documentation.
this Standard. The program shall be in effect at all times during the operational phase to assure that operational phase activities are carried out without undue risk to the health and safety of the public. The program shall require that decisions affecting safety are made at the proper level of responsibility and with the necessary technical advice and review.
individuals and organizations involved in establishing, executing and measuring the overall effectiveness of the administrative controls and quality assurance program required by this Standard. The persons or organizations responsible for defining and measuring the overall effectiveness of the program shall be designated, shall be sufficiently independent from cost and scheduling considerations when opposed to safety considerations, shall have direct access to responsible management at a level where appropriate action can be accomplished, and shall report regularly on the effectiveness of the program to the plant manager and the cognizant offsite management. Persons or organizations performing functions or assuring that the administrative controls and quality assurance program is established and implemented or of assuring that an activity has been correctly performed shall have sufficient authority and organizational freedom to: identify quality problems; initiate, recommend or provide solutions, through designated channels; and verify implementation of solutions.
The owner organization may delegate to other organizations the work of establishing and executing the administrative controls and quality assurance program or any part thereof, in accordance with this Standard, but shall retain responsibility therefore. this standard. The program shall be in effect at all times during the operational phase to assure that operational phase activities are carried out without undue risk to the health and safety of the public. The program shall require that decision affecting safety made at the proper level of responsibility and with the necessary technical advice and review. The owner organization may delegate to other organizations the work of establishing and executing the administrative controls and Quality assurance program or any part. thereof, in accordance with this standard. but shall retain responsibility there for. 3.1.2 Assignment of Authority and Responsibility. 3.2 Assignment of Authority and Responsibility 3.2  Assignment of Authority and Responsibility Lines of authority, responsibility, and communication shall be established and defined for the corporate, plant operating, and support organizations. These relationships shall be documented and updated, as appropriate, in the form of organizational charts, functional descriptions of departmental responsibilities and relationships and job descriptions for key personnel positions or in equivalent forms of documentation.
The organizational structure and the functional responsibility assignments shall be such that: (1) Attainment of program objectives is accomplished by those who have been assigned responsibility for performing work. This may include interim examinations, checks, and inspections of the work by the individual performing the work. (2) Verification or conformance to established program requirements is accomplished by a qualified person who does not have responsibility for performing 5
NQA-1, Basic Requirement 2. Ok.


It is essential that all members of the organization involved in operation of nuclear power plants, including those at the highest management levels, recognize the necessity that the plants be operated under a well formulated and detailed administrative controls and quality assurance program to assure safety and efficiency. Lines of authority, responsibility and communication shall be established from the highest management level through intermediate levels to and including the onsite operating organization (including those offsite organizational units assigned responsibility for procurement, design and construction, quality assurance, and technical support activities).
ANS 3.2 Side-By Side Comparison 7/25/2012 or directly supervising the work. The method and extent or such verification shall be commensurate with the importance of the activity to plant safety and reliability. In structuring the organization and assigning responsibility, quality assurance should be recognized as an interdisciplinary function involving many organizational component and, therefore, should not be regarded as the sole domain of a single quality assurance group. For example, it may be more appropriate for nuclear engineers to perform reviews of plant nuclear engineering activities rather than quality assurance engineers because of the special .competence required to perform these reviews. Quality assurance encompasses many functions and activities and extends to various levels in all participating organizations. From the top executive to all workers whose activities may influence quality.
These relationships shall be documented and updated, as appropriate, in the form of organizational charts, functional It is essential that all members of the organization involved in operation of nuclear power plants, including those at the highest management levels, recognize the necessity that the plants be operated under a well formulated and detailed administrative control and quality assurance program to ensure safety and efficiency. Lines of authority responsibility and communication shall be established and well defined from the highest management level through intermediate level, to and including all onsite operating organization position with involvement in activities affecting the safety of the nuclear power plant including those offsite organizational positioning under assigned responsibility for procurement, design and construction, quality assurance and technical support activities.
3.1.3 Plant Operating Organization                                                        3 .4. 1 General                              3 .4. 1 General 3.1.3.1 General                                                      NQA-1, Basic        A number of factors influence                A number of factors influence Requirement 2. Ok. management in its decision regarding the    management in its decision regarding the Management shall establish and periodically assess the adequacy of                        establishment of an onsite operating        establishment of an onsite operating the plant operating organization and shall ensure that necessary                          organization.
These relationships shall be documented 
organization.
changes to the organization are made in a timely manner.
When establishing the plant operating organization, the owner        NQA-1, Basic        These include the owner organization's      These include the owner organization's organization should evaluate the physical size and complexity of the Requirement 2. Ok. established staffing policies, the physical  established staffing policies, the physical nuclear power plant, the number of units, the extent of assistance                        size and complexity of the nuclear power    size and complexity of the nuclear power provided by technical support organizations, and the extent of plant, the number of units, the extent of    plant, the number of units, the extent of reliance on consultants and the availability of qualified personnel from other sources.                                                                      assistance provided by offsite technical'    assistance provided by offsite technical support organizations, the extent of        support organizations the extent of reliance on consultants and the availability reliance on consultants and the availability of qualified personnel (room other sources  of qualified personnel from other sources to assist in activities. such as initial    to assist in activities such as initial startup startup, refueling. maintenance or          refueling, maintenance or modification 6


ANS 3.2 Side-By Side Comparison           7/25/2012 5 descriptions or departmental responsibilities and relationships and job descriptions for key personnel positions or in equivalent forms of documentation. The owner organization shall specify in writing the authority and responsibility assigned to individuals and organizations involved in establishing, executing and measuring the overall effectiveness of the administrative
ANS 3.2 Side-By Side Comparison 7/25/2012 modification work.                          work.
3.1.3.1.1 Requirements for the Plant Operating Organization                                    3. 4. 2 Requirements for the Onsite        3. 4. 2 Requirements for the Onsite Operating Organization                      Operating Organization The plant operating organization shall include one or more            NQA-1, Basic            The onsite operating organization shall    The Onsite operating organization shall individuals knowledgeable in the following fields: nuclear power plant Requirement 1. Ok.      include one or more individuals            include. At a minimum, one or more operation; nuclear power plant mechanical systems; nuclear power                              knowledgeable in the following field. :    individual knowledgeable in the following plant electrical systems; instrumentation and control (electronic)                            nuclear power plant operation; nuclear      fields: nuclear power plant operation:
systems; nuclear engineering; heat transfer, fluid flow and                                   power plant mechanical, electrical and      nuclear power plant mechanical systems; thermodynamics; chemistry and radiochemistry; radiation protection;                            electronic systems; nuclear engineering    nuclear power plant electrical and risk assessment; and quality assurance.                                                        chemistry and radiochemistry; radiation    electronic systems; nuclear engineering; protection; and quality assurance. Initial  heat transfer, fluid flow and incumbents or replacements (or members      thermodynamics; chemistry and of the onsite operating organization and    radiochemistry; radiation protection; and offsite technical sup. port organizations  quality assurance. Initial incumbents or shall have appropriate experience; training replacements for members of the onsite and retraining to assure that necessary    operating organization shall have competence is maintained in accordance      appropriate experience, training and with the provisions of American National    retraining to assure that necessary Standard for Selection and Training of      competence is maintained in accordance Nuclear Power Plant Personnel, NIS.1-      with the provisions of American National 1971                                        Standard for Selection. Qualification Personnel whose qualifications do not      and Training of Personnel for Nuclear meet those specified in NlS.l and who are  Power Plants, ANS UAN & S.1-l981.
performing inspection. examination, and testing activities during the operations phase of the plant, including preoperational and start-up testing, shall be qualified to American National Standard Qualifications of Inspection, Examination and Testing Personnel for the Construction Phase of Nuclear Power Plants N45.2.6-1973 . except that the QA experience cited for Levels I, II, and III should be interpreted to mean actual experience in carrying out the types of inspection. examination. or testing a being performed.
Staffing requirements for positions in the plants operating          Staffing should be in  The owner organization shall designate      The owner organization shall designate organization that are to be filled by personnel holding NRC            alignment with 50.54. those positions in the onsite operating    those positions in the onsite operating operator and senior operator licenses are normally delineated in                              organization which shall be filled by      organization which shall be filled by the plants Safety Analysis Report. These positions shall be                                  personnel holding NRC reactor operator      personnel holding NRC reactor operator specified. Requirements for the minimum number of personnel                                    and senior reactor operator licenses.      and senior reactor operator licenses.
7


controls and quality assurance program required by this Standard. The persons or organizations responsible for defining and measuring the overall effectiveness of the program shall be designated, shall be sufficiently independent from cost and scheduling considerations when opposed to safety considerations, shall have direct access to responsible management at a level where appropriate action can be accomplished, and shall report regularly on the effectiveness of the program to the plant manager and the cognizant offsite management. Persons or organizations performing functions or assuring that the administrative controls and quality assurance program is established and implemented or of assuring that an activity has been correctly performed shall have sufficient authority and organizational freedom to: identify quality problems; initiate, recommend or provide solutions, through designated channels; and verify implementation of solutions. The organizational structure and the functional responsibility assignments shall be such that: (1) Attainment of program objectives is accomplished by those who have been assigned responsibility for performing work. This may include interim examinations, checks, and inspections of the work by the individual performing the work. (2)  Verification or conformance to established program requirements is accomplished by a qualified person who does not have responsibility for performing and Updated, as appropriate in the form of organizational chart, functional description of departmental responsibilities and relationships and job description for key personnel positioned or in equivalent forms of documentation. 
ANS 3.2 Side-By Side Comparison 7/25/2012 holding such licenses who are to be present at the plant under                                Requirements for the minimum number of     Requirements for the minimum number of various operating conditions and situations shall also be specified,                          personnel holding such licenses who shall   personnel holding such licenses who shall normally in the plants Technical Specifications.                                             be present at the plant under various       be present at the plant under various operating conditions and situations shall   operating conditions and situations shall also be specified.                          also be specified.
 
3.1.3.1.2 Technical Support for the On-Duty Operating Staff                                                                               3.4.3 Technical Support of the Off-Duty Operating Staff.
ANS 3.2 Side-By Side Comparison           7/25/2012 6 or directly supervising the work. The method and extent or such verification shall be commensurate with the importance of the activity to plant safety and reliability. In structuring the organization and assigning responsibility, quality assurance should be recognized as an interdisciplinary function involving many organizational component and, therefore, should not be regarded as the sole domain of a single quality assurance group. For example, it may be more appropriate for nuclear engineers to perform reviews of plant nuclear engineering activities rather than quality assurance engineers because of the special .competence required to perform these reviews. Quality assurance encompasses many functions and activities and extends to various levels in all participating organizations. From the top executive to all workers whose activities may influence quality. 3.1.3 Plant Operating Organization 3 .4. 1 General 3 .4. 1 General3.1.3.1 General  Management shall establish and periodically assess the adequacy of the plant operating organization and shall ensure that necessary changes to the organization are made in a timely manner.
The shift staffing shall include, or have available for consultation, individuals in technical areas that are related to the safe operation                                                                     The owner organization shall establish of the facility. The technical areas include thermodynamics and provisions for assuring that the shift fluid flow, reactor engineering, systems engineering, transient and accident analysis, instrumentation and controls, quality assurance,                                                                       organization includes, or has available for radiation protection, and chemistry and radiochemistry.                                                                                   consultation, persons with professional level expertise in technical areas that are related to the safe operation of the plant.
NQA-1, Basic Requirement 2. Ok.
A number of factors influence management in its decision regarding the establishment of an onsite operating organization. A number of factors influence management in its decision regarding the establishment of an onsite operating organization. When establishing the plant operating organization, the owner organization should evaluate the physical size and complexity of the nuclear power plant, the number of units, the extent of assistance provided by technical support organizations, and the extent of reliance on consultants and the availability of qualified personnel from other sources.
NQA-1, Basic Requirement 2. Ok.
These include the owner organization's established staffing policies, the physical size and complexity of the nuclear power plant, the number of units, the extent of assistance provided by offsite technical' support organizations, the extent of reliance on consultants and the availability
 
of qualified personnel (room other sources to assist in activities. such as initial startup, refueling. maintenance or These include the owner organization's established staffing policies, the physical size and complexity of the nuclear power plant, the number of units, the extent of assistance provided by offsite technical support organizations the extent of reliance on consultants and the availability of qualified personnel from other sources to assist in activities such as initial startup refueling, maintenance or modification 
 
ANS 3.2 Side-By Side Comparison            7/25/2012 7 modification work. work. 3.1.3.1.1 Requirements for the Plant Operating Organization  3. 4. 2 Requirements for the Onsite Operating Organization 3. 4. 2 Requirements for the Onsite Operating Organization The plant operating organization shall include one or more individuals knowledgeable in the following fields: nuclear power plant operation; nuclear power plant mechanical systems; nuclear power plant electrical systems; instrumentation and control (electronic) systems; nuclear engineering; heat transfer, fluid flow and thermodynamics; chemistry and radiochemistry; radiation protection; risk assessment;  and quality assurance.
NQA-1, Basic Requirement 1. Ok.
The onsite operating organization shall include one or more individuals knowledgeable in the following field. : nuclear power plant operation; nuclear power plant mechanical, electrical and electronic systems; nuclear engineering chemistry and radiochemistry; radiation protection; and quality assurance. Initial incumbents or replacements (or members o f the onsite operating organization and offsite technical sup. port organizations shall have appropriate experience; training and retraining to assure that necessary competence is mainta ined in accordance with the provisions of American National Standard for Selection and Training of Nuclear Power Plant Personnel, NIS.1-1971 Personnel whose qualifications do not meet those specified in NlS.l and who are performing inspection. examination, and testing activities during the operations phase of the plant, including preoperational and start-up testing, shall be qualified to American National Standard Qualifications of Inspection, Examination and Testing Personnel for the Construction Phase of Nuclear Power Plants  N45.2.6-1973 . except that the QA experience cited for Levels I, II, and III should be interpreted to mean actual experience in carrying out the types of inspection. examination. or testing a being performed. The Onsite operating organization shall include. At a minimum, one or more individual knowledgeable in the following fields: nuclear power plant operation:
nuclear power plant mechanical systems; nuclear power plant electrical and electronic systems; nuclear engineering; heat transfer, fluid flow and thermodynamics; chemistry and radiochemistry; radiation protection; and quality assurance. Initial incumbents or replacements for members of the onsite operating organization shall have appropriate experience, training and retraining to assure that necessary competence is mainta ined in accordance with the provisions of American National Standard for Selection. Qualification and Training of Personnel for Nuclear Power  Plants, ANS UAN & S.1-l981. Staffing requirements for positions in the plant's operating organization that are to be filled by personnel holding NRC operator and senior operator licenses are normally delineated in the plant's Safety Analysis Report. These positions shall be specified. Requirements for the minimum number of personnel Staffing should be in alignment with 50.54.
The owner organization shall designate those positions in the onsite operating organization which shall be filled by personnel holding NRC reactor operator and senior reactor operator licenses. The owner organization shall designate those positions in the onsite operating organization which shall be filled by personnel holding NRC reactor operator and senior reactor operator licenses. 
 
ANS 3.2 Side-By Side Comparison            7/25/2012 8 holding such licenses who are to be present at the plant under various operating conditions and situations shall also be specified, normally in the plant's Technical Specifications.
Requirements for the minimum number of personnel holding such licenses who shall be present at the plant under various operating conditions and situations shall also be specified. Requirements for the minimum number of personnel holding such licenses who shall be present at the plant under various operating conditions and situations shall also be specified. 3.1.3.1.2 Technical Support for the On-Duty Operating Staff The shift staffing shall include, or have available for consultation, individuals in technical areas that are related to the safe operation of the facility. The technical areas include thermodynamics and fluid flow, reactor engineering, systems engineering, transient and accident analysis, instrumentation and controls, quality assurance, radiation protection, and chemistry and radiochemistry.
3.4.3 Technical Support of the Of f-Duty Operating Staff. The owner organization shall establish provisions for assuring that the shift organization includes, or has available for consultation, persons with professional level expertise in technical areas that are related to the safe operation of the plant.
The technical areas include, as a minimum, thermodynamics/fluid flow, reactor engineering, systems engineering transient and accident analysis, radiation protection, and chemistry radiochemistry.
The technical areas include, as a minimum, thermodynamics/fluid flow, reactor engineering, systems engineering transient and accident analysis, radiation protection, and chemistry radiochemistry.
These personnel shall be available (at the station or on call and capable of responding to the plant within two hours) for the purpose of providing technical advice to the shift supervisor on a 24-hour-a-day basis. They may be part of the plant organization or they may be part of the offsite technical support for the plant staff, except that an individual appropriately  
These personnel shall be available (at the station or on call and capable of responding to the plant within two hours) for the purpose of providing technical advice to the shift supervisor on a 24-hour-a-day basis. They may be part of the plant organization or they may be part of the offsite technical support for the plant staff, except that an individual appropriately Qualified in the first four areas listed above shall be onsite and capable of responding to the control room within ten minutes after the start of an emergency.
 
3.1.4 Operating Organization Authorities and Responsibilities                                 5.2.1 Responsibilities and Authorities Of Operating Personnel Responsibilities and authorities of plant operating personnel and     Essentially, equivalent The responsibilities and authorities of the See 5.2.1.2 below.
Qualified in the first four areas listed above shall be onsite and capable of responding to the control room within ten minutes after the start of an emergency.
those persons assigned to provide immediate support for the plant     to 1976 version,         plant operating personnel shall be operations personnel shall be delineated for both normal and                                   delineated. These shall include, as a emergency conditions. The following requirements shall be 8
3.1.4 Operating Organization Authorities and Responsibilities 5.2.1 Responsibilities and AuthoritiesOf Operating Personnel Responsibilities and authorities of plant operating personnel and those persons assigned to provide immediate support for the plant operations personnel shall be delineated for both normal and emergency conditions. The following requirements shall be Essentially, equivalent to 1976 version, The responsibilities and authorities of the plant operating personnel shall be delineated. These shall include, as a See 5.2.1.2 below.    
 
ANS 3.2 Side-By Side Comparison            7/25/2012 9 established:
Section 5.2.1. Ok.
minimum: (1) The reactor operator's Authority and responsibility for shutting the reactor down when he determines that the safety of the reactor is in jeopardy or when operating parameters exceed any of the reactor protection safety system set points and automatic shutdown does not occur. (2) The responsibility to determine the circumstances, analyze the cause, and determine that operations can proceed safely before the reactor is returned to power after a trip or An unscheduled or unexplained power reduction. (3) The senior reactor operator's responsibility to be present at the plant and to provide direction for returning the reactor to power following a trip or an unscheduled or unexplained power reduction. (4) The responsibility to believe and respond conservatively to instrument indications unless they are proved to be incorrect.  (5) The responsibility to adhere to the plant's Technical Specifications. (6) The responsibility to review routine operating data to assure safe operation. 3.1.4.1 Plant Control Responsibilities 5.2.1 Responsibilities and Authorities or Operating Personnel 5.2.1 Control of Plant OperationsResponsibilities and authorities shall be established so that at all times it is clear which individuals have responsibility for directing the various plant operating and control room activities. In  Essentially, equivalent to 1976 (1) The reactor operator's Authority and responsibility for shutting the reactor down Responsibilities and authorities of onsite operating personnel and those person! assigned to provide immediate support for
 
ANS 3.2 Side-By Side Comparison            7/25/2012 10 addition, there shall be clear identification of the individual(s) responsible for determining the circumstances, analyzing the cause, and determining that operations may proceed safely after an unexplained event or before the reactor is returned to power after a trip.
version, Section 5.2.1(1) & (2).
when he determines that the safety of the reactor is in jeopardy or when operating parameters exceed any of the reactor protection safety system set points and automatic shutdown does not occur. (2) The responsibility to determine the circumstances, analyze the cause, and determine that operations can proceed safely before the reactor is returned to power after a trip or An unscheduled or unexplained power reduction. the onsite operations personnel shall be delineated for both  normal and emergency conditions. at minimum. These rules of practice shall establish the following: 3.1.4.2 General Authorities and Responsibilities of Operating Personnel 5.2.1 Responsibilities and AuthoritiesOf Operating Personnel 5.2.1.2  General Authorities and responsibilities of Operating Personnel The general authorities and responsibilities of operating personnel shall be clearly delineated and shall include the following: (1) the authority and responsibility of licensed personnel for shutting down the reactor when it is determined that the safety of the reactor is in jeopardy or when operating parameters exceed any of the reactor protection system set points and automatic shutdown does not occur. (2) the responsibility to respond conservatively to instrument indications unless they are determined to be incorrect. (3) the responsibility to adhere to plant procedures (see also Section 3.5.1). (4) the responsibility to adhere to the plant's License Conditions and Technical Specifications. (5) the responsibility to review routine operating data to ensure safe operation.
Essentially, equivalent to 1976 version, Section 5.2.1(1) & (2).
The responsibilities and authorities of the plant operating personnel shall be delineated. These shall include, as a minimum:  (1) The reactor operator's Authority and responsibility for shutting the reactor down when he determines that the safety of the reactor is in jeopardy or when operating parameters exceed any of the reactor protection system set points and automatic shutdown does not occur.  (2) The responsibility to determine the circumstances, analyze the cause, and determine that operational can  proceed safely before the reactor is returned to power after a trip or An unscheduled unexplained power reduction. (3) The senior reactor operator's responsibility to be present at the plant and to provide direction for returning the reactor to power following a trip or an unscheduled or unexplained power reduction. (4) The responsibility to believe and respond conservatively to instrument indications unless they are proved to be incorrect. Rules of practice shall clearly delineate the general authorities and responsibilities of operating personnel, including the following: 1) The reactor operator's authority and responsibility (or shutting down the reactor when be determines that; the safety of the reactor is in jeopardy or when operating parameters exceed any of the reactor protection system set points and automatic shutdown does not occur.  (2) The responsibility to behave and respond conservatively to instrument indications unless they are proved to be incorrect (3) The responsibility to adhere to the plant's operational and emergency procedures. (see also 5.2.21.) (4) The responsibility to adhere to the plant's Technical Specification. (5) The responsibility to review routine operating data to assure safe operation. 
 
ANS 3.2 Side-By Side Comparison            7/25/2012 11 (5) The responsibility to adhere to the plant's Technical Specifications.  (6) The responsibility to review routine operating data to assure safe operation. 3.1.4.3 Authority and Responsibilities of the Operations Shift Supervisor 5.2.1 Responsibilitiesand Authorities. Of Operating Personnel 5.2.1.3 Authority and Responsibilities of the Shift Supervisor The operations shift supervisor (sometimes called the Shift Manager) shall manage the activities of the operating shift to ensure integrated direction of all activities. The authority and responsibilities of the operations shift supervisor during normal operation and emergency events shall be clearly delineated and shall include the following: (1) the operations shift supervisor shall have the authority and responsibility to direct all activities pertaining to plant operations. (2) the responsibilities of the operations shift supervisor shall be to maintain a comprehensive understanding of operational conditions that affect the safety of the plant as a matter of highest priority. Control room command duties, responsibilities, and authorities shall be clearly specified. The operations shift supervisor shall not become totally involved in any single operation when multiple operations are required in the control room. If the operations shift supervisor is temporarily absent from the control room area during routine operations, a qualified licensed senior operator shall be designated to assume the control room command function.
New addition. Ok. Similar to 1982 version 5.2.1.3. The responsibilities and authorities of the plant operating personnel shall be delineated. These shall include, as a minimum: (1) The reactor operator's authority and responsibility for shutting the reactor down when he determines that the safety of the reactor is in jeopardy or when operating parameters exceed any of the reactor protection System set points and automatic shutdown did not occur. (2) The responsibility to determine the circumstances, analyze the cause, and determine that operation" can proceed safely before the reactor is returned to power after a trip or an unscheduled or unexplained power reduction. (3) The senior reactor operator's responsibility to be present at the plant and to provide direction for returning, the reactor to power following, a trip or an unscheduled or unexplained power reduction. (4) The responsibility to believe and respond conservatively to instrument indications until they are proved incorrect. (5) The responsibility to adhere to the plant's Technical Specifications. Rules of practice shall clearly delineate the authority and responsibilities of the shift supervisor during normal operation and emergency events, including the following:
(1) The shift supervisor shall have the authority and responsibility to direct all activities affecting the safety of the nuclear power plant. Transfer of authority and responsibility to plant staff members in management levels above the shift supervisor shall be predetermined. Transfer of this authority and responsibility shall be documented for routine shift turnover and emergency conditions.
(2) The responsibilities of the shift supervisor shall be primarily to maintain the broadest perspective of operational conditions affecting the safety of the plant as a matter of highest priority at all times. The idea of command and control shall be reinforced and the shift supervisor shall be instructed not to become totally involved in any single operation in times of emergency when multiple operations are required in the control room. If the shift supervisor is temporarily absent from the control room during routine operations, a lead control room operator shall be designated to assume the control room command function. Temporary duties, responsibilities, and authority shall be clearly specified.
(3) During emergency conditions, the duty station for the shift supervisor shall be the 
 
ANS 3.2 Side-By Side Comparison            7/25/2012 12 (6)  The responsibility to review routine operating data to ensure safe operation. central control room. The shift supervisor, until properly relieved, shall remain in the control room at all times during such situations to direct the activities of control room operators. In order to perform the preceding functions effectively, the operations shift supervisor shall not be encumbered with unnecessary on-shift administrative duties.
Worded slightly different than 1976 version, Section 3.4.2. Intent is the same. Ok.
3.4.2 Requirements for the Onsite Operating Organization The onsite operating organization shall include one or more individuals knowledgeable in the following field!!:nuclear power plant operation; nuclear power plant mechanical, electrical and electronic systems; nuclear engineering chemistry and radiochemistry; radiation protection; and quality assurance. Initial incumbents or replacements (or members of the onsite operating organization and offsite technical support organizations shall have appropriate experience; training and retraining to assure that necessary competence is mainta ined in accordance with the provisions of American National Standard for Selection and Training of Nuclear Power Plant Personnel, NIS.1-1971. Personnel whose qualifications do not meet those specified in NlS.l and who are performing inspection. examination, and testing activities during the operations phase of the plant, including preoperational and start-up testing, shall be qualified to American National Standard Qualifications of Inspection, Examination and Testing Personnel for the Construction Phase of Nuclear Power Plants. N45.2.6-1973 (5]. except that the QA experience cited for Levels I, II, and III should be interpreted to mean actual experience in carrying out the types of 3.4.2 Requirements for the onsite Operational Organization
 
The Onsite operating organization shall include. At a minimum, one or more individual knowledgeable in the following fields: nuclear power plant operation: nuclear power plant mechanical systems; nuclear power plant electrical and electronic systems; nuclear engineering; heat transfer, fluid flow and thermodynamics; chemistry and radiochemistry; radiation protection; and quality assurance. Initial incumbents or replacements for members of the onsite operating organization shall have appropriate experience, training and retraining to assure that necessary competence is mainta ined in accordance with the provisions of American National Standard for Selection. Qualification and Training of Personnel for Nuclear Power  Plants, ANS UAN & S.1-l981. 
 
ANS 3.2 Side-By Side Comparison            7/25/2012 13 inspection. examination. or testing activity being performed. The owner organization shall designate those positions in the onsite operating organization which shall be filled by personnel holding NRC reactor operator and senior reactor operator licenses. Requirements for the minimum number of personnel holding such licenses who shall be present at the plant under various operating conditions and situations shall be specified. The Plant Manager shall have Overall responsibility for the execution of the administrative control. and quality assurance program at the plant to assure safety. An individual or organizational unit knowledgeable and experienced in nuclear power plant operational phase activities and quality assurance practice: shall be designated and assigned the responsibility to verify that the program is being effectively implemented. Depending on the organizational structure, the individual or organizational unit may report functionally to offsite plant management or an offsite organization (see also 3.2). Reporting to onsite plant management is preferable since such an arrangement usually resulting in improved communications in identifying problems and initiating corrective action. The individual or organizational unit in this case may receive technical guidance from offsite support groups. This individual's or organizational unit's duties and responsibilities shall be such that the required attention can be devoted, as required, to verifying that the program is being effectively executed. The individual 


ANS 3.2 Side-By Side Comparison           7/25/2012 14 or organizational unit shall report on the effectiveness of the program to the Plant Manager and to either cognizant management as may be designated. The activities shall be periodically audited by designated offsite personnel. 3.1.4.4 Responsibilities of Others in the Plant Operating Organization  3.4.2  Requirements for the OnsiteOperating Organization. 3.4.2 Requirements for the Onsite Operational Organization The authority and responsibility of other personnel whose actions or decisions could affect normal plant operations or exacerbate an abnormal or accident condition shall be delineated. As a minimum, personnel performing maintenance or testing shall not work on plant systems and equipment unless permission has been granted by designated operating personnel.
ANS 3.2 Side-By Side Comparison 7/25/2012 established:                                                          Section 5.2.1. Ok. minimum:
New addition. Ok. §No discussion of the role of the Plant Manager, as in 1976 version, Section 3.4.2. The onsite operating organization shall include one or more individuals knowledgeable in the following field:nuclear power plant operation; nuclear power plant mechanical, electrical and electronic systems; nuclear engineering chemistry and radiochemistry; radiation protection; and quality assurance. Initial incumbents or replacements (or members of the onsite operating organization and offsite technical support organizations shall have appropriate experience; training and retraining to assure that necessary competence is mainta ined in accordance with the provisions of American National Standard for Selection and Training of Nuclear Power Plant Personnel, NIS.1-1971. Personnel whose qualifications do not meet those specified in NlS.l and who are performing inspection. examination, and testing activities during the operations phase of the plant, including preoperational and start-up testing, shall be qualified to American National Standard Qualifications of Inspection, Examination. And Testing Personnel for the Construction Phase of Nuclear Power Plants. N45.2.6-1973. except that the QA experience cited for Levels I, II, and III should be interpreted to mean actual experience in carrying out the types of inspection. examination. or testing activity The Onsite operating organization shall include. At a minimum, one or more individual knowledgeable in the following fields:nuclear power plant operation: nuclear power plant mechanical systems; nuclear power plant electrical and electronic systems; nuclear engineering; heat transfer, fluid flow and thermodynamics; chemistry and radiochemistry; radiation protection; and quality assurance. Initial incumbents or replacements for members of the onsite operating organization shall have appropriate experience, training and retraining to assure that necessary competence is mainta ined in accordance with the provisions of American National Standard for Selection. Qualification and Training of Personnel for Nuclear Power Plants  ANSI/ANs 3.1-l981  (SI Personnel whose qualifications are not addressed in ANS-3.1 and who are performing inspection, examination, and testing activities during the operations phase of the plant.. including preoperati onal and start-up testing. shall be qualified in accordance with the requirements of  NQA-1-1979, except that cited experience shall be limited to actual experience in carrying out the types of inspection. examination, or testing activity being performed. The owner organization shall designate the position in the onsite operating organization which shall be filled 
(1) The reactor operator's Authority and responsibility for shutting the reactor down when he determines that the safety of the reactor is in jeopardy or when operating parameters exceed any of the reactor protection safety system set points and automatic shutdown does not occur.
(2) The responsibility to determine the circumstances, analyze the cause, and determine that operations can proceed safely before the reactor is returned to power after a trip or An unscheduled or unexplained power reduction.
(3) The senior reactor operator's responsibility to be present at the plant and to provide direction for returning the reactor to power following a trip or an unscheduled or unexplained power reduction.
(4) The responsibility to believe and respond conservatively to instrument indications unless they are proved to be incorrect.
(5) The responsibility to adhere to the plant's Technical Specifications.
(6) The responsibility to review routine operating data to assure safe operation.
3.1.4.1 Plant Control Responsibilities                                                    5.2.1 Responsibilities and Authorities      5.2.1 Control of Plant Operations or Operating Personnel Responsibilities and authorities shall be established so that at all  Essentially,       (1) The reactor operator's Authority and    Responsibilities and authorities of onsite times it is clear which individuals have responsibility for directing equivalent to 1976  responsibility for shutting the reactor down operating personnel and those person!
the various plant operating and control room activities. In                                                                            assigned to provide immediate support for 9


ANS 3.2 Side-By Side Comparison           7/25/2012 15 being performed. by personnel holding NRC operator and senior operator license. Requirements for the minimum number of personnel holding such licenses who shall be present at the plant under various operating conditions and situation shall also be specified_ 3.1.4.5 Transfer of Authority and Responsibility  5.2.1.4 Transfer of ResponsibilityTransfer of authority and responsibility to plant staff members in management levels above the operations shift supervisor shall be predetermined. The transfer of responsibility from one shift to another, as well as the transfer of authority during emergency conditions shall be documented and shall involve: (1) Persons authorized to relieve the operations shift supervisor. Only personnel meeting the qualification requirements of the operations shift supervisor position shall relieve the on-duty shift supervisor. (2) The line of ascension of authority.
ANS 3.2 Side-By Side Comparison 7/25/2012 addition, there shall be clear identification of the individual(s)  version, Section        when he determines that the safety of the    the onsite operations personnel shall be responsible for determining the circumstances, analyzing the        5.2.1(1) & (2).         reactor is in jeopardy or when operating    delineated for both normal and emergency cause, and determining that operations may proceed safely after                              parameters exceed any of the reactor        conditions. at minimum. These rules of an unexplained event or before the reactor is returned to power                                                                          practice shall establish the following:
(3) The authority and limitations of technical and management personnel to direct activities in the control room.
protection safety system set points and after a trip.
New addition. Ok. Similar to 1982 version, Section 5.2.1.4. Rules of practice shall be established for the transfer of responsibility from one shift to another, as well as the transfer of authority during emergency conditions. These rules of practice shall delineate:
automatic shutdown does not occur.
(2) The responsibility to determine the circumstances, analyze the cause, and determine that operations can proceed safely before the reactor is returned to power after a trip or An unscheduled or unexplained power reduction.
3.1.4.2 General Authorities and Responsibilities of Operating                                5.2.1 Responsibilities and Authorities      5.2.1.2 General Authorities and Personnel                                                                                    Of Operating Personnel                      responsibilities of Operating Personnel The general authorities and responsibilities of operating personnel Essentially, equivalent  The responsibilities and authorities of the  Rules of practice shall clearly delineate the shall be clearly delineated and shall include the following:        to 1976 version,        plant operating personnel shall be           general authorities and responsibilities of Section 5.2.1(1) & (2). delineated. These shall include, as a        operating personnel, including the (1) the authority and responsibility of licensed personnel for                              minimum:                                    following:
shutting down the reactor when it is determined that the safety of                          (1) The reactor operator's Authority and    1) The reactor operator's authority and the reactor is in jeopardy or when operating parameters exceed                              responsibility for shutting the reactor down responsibility (or shutting down the reactor any of the reactor protection system set points and automatic                                when he determines that the safety of the    when be determines that; the safety of the shutdown does not occur.                                                                     reactor is in jeopardy or when operating    reactor is in jeopardy or when operating parameters exceed any of the reactor        parameters exceed any of the reactor (2) the responsibility to respond conservatively to instrument                              protection system set points and automatic  protection system set points and automatic indications unless they are determined to be incorrect.                                      shutdown does not occur.                    shutdown does not occur.
(2) The responsibility to determine the      (2) The responsibility to behave and (3) the responsibility to adhere to plant procedures (see also                              circumstances, analyze the cause, and        respond conservatively to instrument Section 3.5.1).                                                                             determine that operational can proceed      indications unless they are proved to be safely before the reactor is returned to    incorrect (4) the responsibility to adhere to the plant's License Conditions                          power after a trip or An unscheduled        (3) The responsibility to adhere to the and Technical Specifications.                                                               unexplained power reduction.                 plant's operational and emergency (3) The senior reactor operator's            procedures. (see also 5.2.21.)
(5) the responsibility to review routine operating data to ensure                            responsibility to be present at the plant    (4) The responsibility to adhere to the safe operation.                                                                             and to provide direction for returning the   plant's Technical Specification.
reactor to power following a trip or an      (5) The responsibility to review routine unscheduled or unexplained power            operating data to assure safe operation.
reduction.
(4) The responsibility to believe and respond conservatively to instrument indications unless they are proved to be incorrect.
10


(1) Persons authorized to relieve the shift supervisor.
ANS 3.2 Side-By Side Comparison 7/25/2012 (5) The responsibility to adhere to the plant's Technical Specifications.
(2) The line of ascension of authority during both normal and emergency conditions when one or more persons of management authority above the shift supervisor are present in the central control room. Only personnel meeting the qualification requirements of the shift supervisor position shall have the authority to relieve the on-duty shift supervisor from the responsibility to direct activities affecting the safety of the nuclear power plant. (3) The authority, and limitations thereon, of technical and management personnel to direct activities in the central control room.
(6) The responsibility to review routine operating data to assure safe operation.
(4) Interfaces between groups such as the utility's corporate organization, vendors, the architect-engineer, contractors and consultants, NRC and other local state or federal agencies. To ensure that personnel on succeeding shifts have a clear understanding of the condition of equipment and systems, each on-shift duty station shall have procedures for the turnover of duties. These procedures shall include documented turnover action appropriate to the duty station acknowledging the status of the plant New addition. Ok. Similar to 1982 version, Section  See above 
3.1.4.3 Authority and Responsibilities of the Operations Shift                                  5.2.1 Responsibilities and Authorities.      5.2.1.3 Authority and Responsibilities of Supervisor                                                                                      Of Operating Personnel                      the Shift Supervisor The operations shift supervisor (sometimes called the Shift            New addition. Ok.        The responsibilities and authorities of the  Rules of practice shall clearly delineate the Manager) shall manage the activities of the operating shift to          Similar to 1982 version  plant operating personnel shall be          authority and responsibilities of the shift ensure integrated direction of all activities. The authority and        5.2.1.3.                delineated. These shall include, as a        supervisor during normal operation and responsibilities of the operations shift supervisor during normal                                                                            emergency events, including the minimum:
operation and emergency events shall be clearly delineated and                                                                                following:
shall include the following:
(1) The reactor operator's authority and    (1) The shift supervisor shall have the (1) the operations shift supervisor shall have the authority and                                responsibility for shutting the reactor down authority and responsibility to direct all responsibility to direct all activities pertaining to plant operations.                          when he determines that the safety of the    activities affecting the safety of the nuclear reactor is in jeopardy or when operating    power plant. Transfer of authority and (2) the responsibilities of the operations shift supervisor shall be to                          parameters exceed any of the reactor        responsibility to plant staff members in maintain a comprehensive understanding of operational                                            protection System set points and            management levels above the shift conditions that affect the safety of the plant as a matter of highest                                                                        supervisor shall be predetermined.
automatic shutdown did not occur.
priority.                                                                                                                                    Transfer of this authority and responsibility shall be documented for routine shift Control room command duties, responsibilities, and authorities                                  (2) The responsibility to determine the      turnover and emergency conditions.
shall be clearly specified. The operations shift supervisor shall not                            circumstances, analyze the cause, and become totally involved in any single operation when multiple                                    determine that operation" can proceed        (2) The responsibilities of the shift operations are required in the control room. If the operations shift                            safely before the reactor is returned to    supervisor shall be primarily to maintain supervisor is temporarily absent from the control room area during                              power after a trip or an unscheduled or      the broadest perspective of operational routine operations, a qualified licensed senior operator shall be                                                                            conditions affecting the safety of the plant unexplained power reduction.
designated to assume the control room command function.                                                                                      as a matter of highest priority at all times.
The idea of command and control shall be (3) The senior reactor operator's reinforced and the shift supervisor shall be responsibility to be present at the plant    instructed not to become totally involved in and to provide direction for returning, the any single operation in times of emergency reactor to power following, a trip or an    when multiple operations are required in unscheduled or unexplained power            the control room. If the shift supervisor is reduction.                                  temporarily absent from the control room during routine operations, a lead control (4) The responsibility to believe and       room operator shall be designated to assume the control room command respond conservatively to instrument function. Temporary duties, indications until they are proved incorrect. responsibilities, and authority shall be clearly specified.
(5) The responsibility to adhere to the plant's Technical Specifications.            (3) During emergency conditions, the duty station for the shift supervisor shall be the 11


ANS 3.2 Side-By Side Comparison           7/25/2012 16 and transfer of authority. Overall plant status, maintenance and test status, planned activities, and any identified trends applicable to the duty station shall be explained. In addition, the following items shall be identified: (1) critical parameters that are not within normal limits, (2) systems that are not in their normal configuration, or are in a degraded mode of operation permitted by the Technical Specifications, and (3) any time that limitations are placed on continued operation.
ANS 3.2 Side-By Side Comparison 7/25/2012 (6) The responsibility to review routine      central control room. The shift supervisor, operating data to ensure safe operation.      until properly relieved, shall remain in the control room at all times during such situations to direct the activities of control room operators.
In order to perform the preceding functions effectively, the Worded slightly          3.4.2 Requirements for the Onsite            3.4.2 Requirements for the onsite operations shift supervisor shall not be encumbered with    different than 1976      Operating Organization                        Operational Organization unnecessary on-shift administrative duties.                  version, Section 3.4.2.
The onsite operating organization shall      The Onsite operating organization shall Intent is the same. Ok.
include one or more individuals              include. At a minimum, one or more knowledgeable in the following               individual knowledgeable in the following field!!:nuclear power plant operation;        fields: nuclear power plant operation:
nuclear power plant mechanical, electrical    nuclear power plant mechanical systems; and electronic systems; nuclear              nuclear power plant electrical and engineering chemistry and radiochemistry;    electronic systems; nuclear engineering; radiation protection; and quality            heat transfer, fluid flow and assurance. Initial incumbents or              thermodynamics; chemistry and replacements (or members of the onsite        radiochemistry; radiation protection; and operating organization and offsite            quality assurance. Initial incumbents or technical support organizations shall have    replacements for members of the onsite appropriate experience; training and          operating organization shall have retraining to assure that necessary          appropriate experience, training and competence is maintained in accordance        retraining to assure that necessary with the provisions of American National      competence is maintained in accordance Standard for Selection and Training of        with the provisions of American National Nuclear Power Plant Personnel, NIS.1-        Standard for Selection. Qualification 1971.                                        and Training of Personnel for Nuclear Power Plants, ANS UAN & S.1-l981.
Personnel whose qualifications do not meet those specified in NlS.l and who are performing inspection. examination, and testing activities during the operations phase of the plant, including preoperational and start-up testing, shall be qualified to American National Standard Qualifications of Inspection, Examination and Testing Personnel for the Construction Phase of Nuclear Power Plants. N45.2.6-1973 (5]. except that the QA experience cited for Levels I, II, and III should be interpreted to mean actual experience in carrying out the types of 12


5.2.1.4. 3.1.4.6 Control Room Access  5.2.9 Plant Security and Visitor Control5.2.1.5 Control Room AccessAccess to the control room shall normally be limited to on-shift personnel and other persons whose job function requires their physical presence in the control room. Access to the control room for the purpose of general familiarization and other non-work-related activities shall be authorized only for good cause.
ANS 3.2 Side-By Side Comparison 7/25/2012 inspection. examination. or testing activity being performed. The owner organization shall designate those positions in the onsite operating organization which shall be filled by personnel holding NRC reactor operator and senior reactor operator licenses. Requirements for the minimum number of personnel holding such licenses who shall be present at the plant under various operating conditions and situations shall be specified. The Plant Manager shall have Overall responsibility for the execution of the administrative control.
New addition. Ok. Similar to 1982 version, Section
and quality assurance program at the plant to assure safety. An individual or organizational unit knowledgeable and experienced in nuclear power plant operational phase activities and quality assurance practice: shall be designated and assigned the responsibility to verify that the program is being effectively implemented. Depending on the organizational structure, the individual or organizational unit may report functionally to offsite plant management or an offsite organization (see also 3.2). Reporting to onsite plant management is preferable since such an arrangement usually resulting in improved communications in identifying problems and initiating corrective action. The individual or organizational unit in this case may receive technical guidance from offsite support groups. This individual's or organizational unit's duties and responsibilities shall be such that the required attention can be devoted, as required, to verifying that the program is being effectively executed. The individual 13


5.2.1.5. Slightly similar to 1976 version, Section 5.2.9. Procedures shall be developed to supplement features and physical barriers design to control access to the pant and as appropriate to vital area within the plant information concerning specification designated features and administrative provision of the plant and visitors controls procedures such as fences and lightings lock control for doors gates and compartments --..the security and visitors control for doors gates an challenging of strangers  By operating crew and a program of reemployment screening (or potential employee. See American National Standard Industrial Security for Nuclear Power Plant, N18.7-1971, for guidance and provisions for security measures adequate to protect nuclear power plants. Access to the control room shall normally be limited to assigned shift personnel and other persons whose job function requires their physical presence in the control room. This control shall be exercised by physical security controls and by administrative controls implemented by the shift supervisor or other emergency coordinators that have assumed control. Access to the control room for the purpose of general familiarization and other non-work-related activities shall be authorized only for good cause. To facilitate the assistance by technical support personnel to the shift operating crew in an emergency, provisions shall be made to provide a technical support center for these persons 
ANS 3.2 Side-By Side Comparison 7/25/2012 or organizational unit shall report on the effectiveness of the program to the Plant Manager and to either cognizant management as may be designated. The activities shall be periodically audited by designated offsite personnel.
3.1.4.4 Responsibilities of Others in the Plant Operating                                    3.4.2 Requirements for the Onsite            3.4.2 Requirements for the Onsite Organization                                                                                  Operating Organization.                     Operational Organization The authority and responsibility of other personnel whose actions or New addition. Ok.        The onsite operating organization shall      The Onsite operating organization shall decisions could affect normal plant operations or exacerbate an                              include one or more individuals              include. At a minimum, one or more abnormal or accident condition shall be delineated. As a minimum,    §No discussion of the    knowledgeable in the following              individual knowledgeable in the following personnel performing maintenance or testing shall not work on plant  role of the Plant        field:nuclear power plant operation;        fields:nuclear power plant operation:
systems and equipment unless permission has been granted by          Manager, as in 1976      nuclear power plant mechanical, electrical  nuclear power plant mechanical systems; designated operating personnel.                                                              and electronic systems; nuclear              nuclear power plant electrical and version, Section 3.4.2. engineering chemistry and radiochemistry;    electronic systems; nuclear engineering; radiation protection; and quality            heat transfer, fluid flow and assurance. Initial incumbents or            thermodynamics; chemistry and replacements (or members of the onsite      radiochemistry; radiation protection; and operating organization and offsite          quality assurance. Initial incumbents or technical support organizations shall have  replacements for members of the onsite appropriate experience; training and        operating organization shall have retraining to assure that necessary          appropriate experience, training and competence is maintained in accordance      retraining to assure that necessary with the provisions of American National     competence is maintained in accordance Standard for Selection and Training of      with the provisions of American National Nuclear Power Plant Personnel, NIS.1-       Standard for Selection. Qualification and 1971.                                        Training of Personnel for Nuclear Power Personnel whose qualifications do not        Plants ANSI/ANs 3.1-l981 (SI Personnel meet those specified in NlS.l and who are    whose qualifications are not addressed in performing inspection. examination, and      ANS-3.1 and who are performing testing activities during the operations    inspection, examination, and testing phase of the plant, including                activities during the operations phase of preoperational and start-up testing, shall  the plant.. including preoperational and be qualified to American National            start-up testing. shall be qualified in Standard Qualifications of Inspection,      accordance with the requirements of Examination. And Testing Personnel for       NQA-1-1979, except that cited experience the Construction Phase of Nuclear Power      shall be limited to actual experience in Plants. N45.2.6-1973. except that the QA    carrying out the types of inspection.
experience cited for Levels I, II, and III  examination, or testing activity being should be interpreted to mean actual        performed. The owner organization shall experience in carrying out the types of      designate the position in the onsite inspection. examination. or testing activity operating organization which shall be filled 14


ANS 3.2 Side-By Side Comparison           7/25/2012 17 During emergency conditions, access to the control room should also be limited. A technical support center, operational support center, and emergency operations facility are provided for support personnel.
ANS 3.2 Side-By Side Comparison 7/25/2012 being performed. by personnel holding NRC operator and senior operator license. Requirements for the minimum number of personnel holding such licenses who shall be present at the plant under various operating conditions and situation shall also be specified_
New addition. Ok. Similar to 1982 version, Section 5.2.1.5. N/A See above 3.2 Program  The managerial and administrative controls employed shall provide control over activities affecting the quality of safety-related structures, systems, and components to an extent consistent with the scope and purpose of this standard. Managerial and administrative controls shall establish requirements pertaining to the conduct and control of plant activities such that affected personnel are provided with a clear understanding of operating philosophy and management policies, as well as methods and techniques for performing required work. These controls shall be established in appropriate policies, procedures, and/or instructions for the operating and support organizations.
3.1.4.5 Transfer of Authority and Responsibility                                                            5.2.1.4 Transfer of Responsibility Transfer of authority and responsibility to plant staff members in    New addition. Ok.                     Rules of practice shall be established for management levels above the operations shift supervisor shall be                                            the transfer of responsibility from one shift predetermined. The transfer of responsibility from one shift to      Similar to 1982                       to another, as well as the transfer of another, as well as the transfer of authority during emergency        version, Section                     authority during emergency conditions.
3.2.1 Operating Organization Review The operating organization shall provide, as a part of the normal duties of plant supervisory personnel, timely and on-going monitoring of operating activities to assist the plant manager in keeping abreast of general plant conditions and to verify that day-to-day operations are conducted safely in accordance with the established administrative controls. These monitoring activities are considered to be an integral part of the routine supervisory function and are important to the safety of plant operation.  
conditions shall be documented and shall involve:                    5.2.1.4.                             These rules of practice shall delineate:
. The operating organization shall perform reviews periodically and as situations demand, to evaluate plant operations and plan future activities. The important elements of the reviews shall be documented. Such reviews serve a useful purpose but shall not take the place of the reviews described in Section 3.2.2, or audits described in Section 3.18. The onsite operating organization   
(1) Persons authorized to relieve the operations shift supervisor.                                         (1) Persons authorized to relieve the shift Only personnel meeting the qualification requirements of the                                                supervisor.
operations shift supervisor position shall relieve the on-duty shift supervisor.                                                                                                 (2) The line of ascension of authority during both normal and emergency (2) The line of ascension of authority.                                                                    conditions when one or more persons of management authority above the shift (3) The authority and limitations of technical and management                                              supervisor are present in the central personnel to direct activities in the control room.                                                        control room. Only personnel meeting the qualification requirements of the shift supervisor position shall have the authority to relieve the on-duty shift supervisor from the responsibility to direct activities affecting the safety of the nuclear power plant.
(3) The authority, and limitations thereon, of technical and management personnel to direct activities in the central control room.
(4) Interfaces between groups such as the utility's corporate organization, vendors, the architect-engineer, contractors and consultants, NRC and other local state or federal agencies.
To ensure that personnel on succeeding shifts have a clear            New addition. Ok.                    See above understanding of the condition of equipment and systems, each on-shift duty station shall have procedures for the turnover of duties. Similar to 1982 These procedures shall include documented turnover action            version, Section appropriate to the duty station acknowledging the status of the plant 15


ANS 3.2 Side-By Side Comparison           7/25/2012 18 shouldscreen subjects of potential concern to independent reviewers (see section 3.2.2.2 (1) through (8)) and perform preliminary investigations. The plant manager shall ensure the timely referral of the applicable matters discussed in the reviews to appropriate management and independent reviewers.
ANS 3.2 Side-By Side Comparison 7/25/2012 and transfer of authority.                                            5.2.1.4.
3.2.2 Independent Review 4.3 Independent Review Program4.3 Independent Review ProgramActivities occurring during the operational phase shall be independently reviewed on a periodic basis. The independent review program shall be functioning prior to initial core loading. This Standard does not advocate any specific organizational structure for complying with the independent review function, but, in lieu thereof, delineates essential elements of satisfactorily comprehensive programs for review that shall be applied in the manner best suited to the owner organization involved. An Independent Review Body (IRB) as described in 3.2.2.3 or an Independent Review Committee (IRC) as described in 3.2.2.4 shall be used to perform the independent review function. The terms IRB and IRC are intended to be generic in nature and may be substituted with the specific owner organization's terms.
Overall plant status, maintenance and test status, planned activities, and any identified trends applicable to the duty station shall be explained. In addition, the following items shall be identified:
Activities occurring during the operational phase shall be independently reviewed on a periodic basis. The independent review program shall be functional prior to initial core loading. Activities occurring during the operational phase shall be independently reviewed on a periodic basis. The independent review program shall be functional prior to initial core loading. 3.2.2.1 Personnel 4.3.1 Personnel 4.3.1 PersonnelPersonnel assigned responsibility for independent review shall be specified, in both number and technical disciplines, and shall collectively have the experience and competence required to review problems in the following areas:
(1) critical parameters that are not within normal limits, (2) systems that are not in their normal configuration, or are in a degraded mode of operation permitted by the Technical Specifications, and (3) any time that limitations are placed on continued operation.
3.1.4.6 Control Room Access                                                                      5.2.9 Plant Security and Visitor Control    5.2.1.5 Control Room Access Access to the control room shall normally be limited to on-shift      New addition. Ok.         Procedures shall be developed to            Access to the control room shall normally personnel and other persons whose job function requires their          Similar to 1982          supplement features and physical barriers    be limited to assigned shift personnel and physical presence in the control room. Access to the control room      version, Section          design to control access to the pant and as other persons whose job function requires for the purpose of general familiarization and other non-work-related                                                                        their physical presence in the control room.
5.2.1.5.                 appropriate to vital area within the plant activities shall be authorized only for good cause.                                                                                           This control shall be exercised by physical information concerning specification        security controls and by administrative Slightly similar to 1976  designated features and administrative      controls implemented by the shift version, Section 5.2.9. provision of the plant and visitors controls supervisor or other emergency procedures such as fences and lightings      coordinators that have assumed control.
lock control for doors gates and             Access to the control room for the purpose compartments ..the security and visitors  of general familiarization and other non-work-related activities shall be authorized control for doors gates an challenging of only for good cause. To facilitate the strangers By operating crew and a program   assistance by technical support personnel of reemployment screening (or potential      to the shift operating crew in an employee. See American National Standard    emergency, provisions shall be made to Industrial Security for Nuclear Power Plant, provide a technical support center for N18.7-1971, for guidance and provisions for  these persons security measures adequate to protect nuclear power plants.
16


(1)    Nuclear power plant operations (2)    Nuclear engineering (3)    Chemistry and radiochemistry (4)    Metallurgy (5)    Nondestructive testing IAW NRC Safety Evaluation ML050210276 Personnel assigned responsibility for independent reviews shall be specified, in both number and technical disciplines, and shall collectively have the experience and competence required to review problems in the following areas; (1) Nuclear power plant operations (2) Nuclear engineering (3) Chemistry and radiochemistry (4) Metallurgy (5) Nondestructive testing Personnel assigned responsibility for independent reviews shall be specified, in both number and technical disciplines, and shall collectively have the experience and competence required to review problems in the following areas; (1) Nuclear power plant operations (2) Nuclear engineering (3) Chemistry and radiochemistry (4) Metallurgy (5) Nondestructive testing
ANS 3.2 Side-By Side Comparison 7/25/2012 During emergency conditions, access to the control room should          New addition. Ok. N/A          See above also be limited. A technical support center, operational support        Similar to 1982 center, and emergency operations facility are provided for support      version, Section personnel.
5.2.1.5.
3.2 Program The managerial and administrative controls employed shall provide control over activities affecting the quality of safety-related structures, systems, and components to an extent consistent with the scope and purpose of this standard.
Managerial and administrative controls shall establish requirements pertaining to the conduct and control of plant activities such that affected personnel are provided with a clear understanding of operating philosophy and management policies, as well as methods and techniques for performing required work.
These controls shall be established in appropriate policies, procedures, and/or instructions for the operating and support organizations.
3.2.1 Operating Organization Review The operating organization shall provide, as a part of the normal      .
duties of plant supervisory personnel, timely and on-going monitoring of operating activities to assist the plant manager in keeping abreast of general plant conditions and to verify that day-to-day operations are conducted safely in accordance with the established administrative controls. These monitoring activities are considered to be an integral part of the routine supervisory function and are important to the safety of plant operation.
The operating organization shall perform reviews periodically and as situations demand, to evaluate plant operations and plan future activities. The important elements of the reviews shall be documented. Such reviews serve a useful purpose but shall not take the place of the reviews described in Section 3.2.2, or audits described in Section 3.18. The onsite operating organization 17


ANS 3.2 Side-By Side Comparison           7/25/2012 19 (6)    Instrumentation and control (7)    Radiological safety (8)    Mechanical engineering (9)   Electrical engineering (10) Administrative control and quality assurance practices (11) Training (12) Emergency plans and related procedures and equipment.
ANS 3.2 Side-By Side Comparison 7/25/2012 shouldscreen subjects of potential concern to independent reviewers (see section 3.2.2.2 (1) through (8)) and perform preliminary investigations. The plant manager shall ensure the timely referral of the applicable matters discussed in the reviews to appropriate management and independent reviewers.
3.2.2 Independent Review                                                            4.3 Independent Review Program              4.3 Independent Review Program Activities occurring during the operational phase shall be                          Activities occurring during the operational  Activities occurring during the operational independently reviewed on a periodic basis. The independent                          phase shall be independently reviewed on    phase shall be independently reviewed on review program shall be functioning prior to initial core loading.                  a periodic basis. The independent review    a periodic basis. The independent review This Standard does not advocate any specific organizational                                                                      program shall be functional prior to initial program shall be functional prior to initial structure for complying with the independent review function, but,                                                                core loading.
in lieu thereof, delineates essential elements of satisfactorily                    core loading.
comprehensive programs for review that shall be applied in the manner best suited to the owner organization involved. An Independent Review Body (IRB) as described in 3.2.2.3 or an Independent Review Committee (IRC) as described in 3.2.2.4 shall be used to perform the independent review function. The terms IRB and IRC are intended to be generic in nature and may be substituted with the specific owner organizations terms.
3.2.2.1 Personnel                                                                    4.3.1 Personnel                              4.3.1 Personnel Personnel assigned responsibility for independent review shall be  IAW NRC Safety   Personnel assigned responsibility            Personnel assigned responsibility specified, in both number and technical disciplines, and shall    Evaluation        for independent reviews shall be            for independent reviews shall be collectively have the experience and competence required to        ML050210276      specified, in both number and technical      specified, in both number and technical review problems in the following areas:                                              disciplines, and shall collectively have the disciplines, and shall collectively have the experience and competence required to        experience and competence required to review problems in the following areas;      review problems in the following areas; (1)    Nuclear power plant operations                                                (1) Nuclear power plant operations          (1) Nuclear power plant operations (2)    Nuclear engineering                                                           (2) Nuclear engineering                      (2) Nuclear engineering (3)   Chemistry and radiochemistry                                                  (3) Chemistry and radiochemistry            (3) Chemistry and radiochemistry (4)    Metallurgy                                                                    (4) Metallurgy                              (4) Metallurgy (5)    Nondestructive testing                                                        (5) Nondestructive testing                  (5) Nondestructive testing 18


(6) Instrumentation and control (7) Radiological safety (8) Mechanical engineering and Electrical engineering (9) Administrative controls and quality assurance practices (10) Other appropriate fields associated with the unique characteristics of the nuclear power plant involved. (6) Instrumentation and control (7) Radiological safety (8) Mechanical engineering (9) Electrical engineering (10) Administrative controls and quality assurance practices (11) Emergency plans and related organization, procedure and equipment (12) Other appropriate fields associated with the unique characteristics of the nuclear power plant involved. An individual may possess competence in more than one specialty area. If sufficient experience is not available within the owner organization, independent reviews shall be supplemented through outside consultants or organizations. Provisions shall be made to assure that appropriate expertise is brought to bear in reviews of operational phase activities.
ANS 3.2 Side-By Side Comparison 7/25/2012 (6)  Instrumentation and control                                                      (6) Instrumentation and control            (6) Instrumentation and control (7)   Radiological safety                                                             (7) Radiological safety                    (7) Radiological safety (8)  Mechanical engineering                                                          (8) Mechanical engineering and Electrical   (8) Mechanical engineering engineering (9)  Electrical engineering                                                                                                      (9) Electrical engineering (9) Administrative controls and quality (10) Administrative control and quality assurance practices                            assurance practices                        (10) Administrative controls and quality assurance practices (11) Training                                                                          (10) Other appropriate fields associated with the unique characteristics of the     (11) Emergency plans and related (12) Emergency plans and related procedures and equipment.                            nuclear power plant involved.              organization, procedure and equipment (12) Other appropriate fields associated with the unique characteristics of the nuclear power plant involved.
An individual may possess competence in more than one specialty area. If sufficient expertise is not available from within the owner organization, independent reviews shall be supplemented through outside consultants or organizations. Provisions shall be made to assure that appropriate expertise is brought to bear in reviews of operational phase activities. An individual may possess competence in more than one specialty area. If sufficient expertise is not available from within the owner organization, independent reviews shall be supplemented through outside consultants or organizations. Provisions shall be made to assure that appropriate expertise is brought to bear in reviews of operational phase activities. Persons fulfilling the independent review function shall be qualified as follows: (1) Supervisor or Chairperson:     a. Education: baccalaureate in engineering or related science.     b. Minimum experience: 6 years combined managerial and technical support. (2) Reviewers:
An individual may possess competence in more than one                                 An individual may possess competence in    An individual may possess competence in specialty area. If sufficient experience is not available within the                   more than one specialty area. If sufficient more than one specialty area. If sufficient owner organization, independent reviews shall be supplemented                         expertise is not available from within the  expertise is not available from within the through outside consultants or organizations. Provisions shall be                     owner organization, independent reviews    owner organization, independent reviews made to assure that appropriate expertise is brought to bear in                       shall be supplemented through outside      shall be supplemented through outside reviews of operational phase activities.                                               consultants or organizations.               consultants or organizations.
: a. Education: - Baccalaureate in engineering or related science for those independent review personnel who are required to review problems in nuclear power plant operations, nuclear engineering, chemistry and radiochemistry, metallurgy, nondestructive testing, IAW NRC Safety Evaluation ML050210276
Provisions shall be made to assure that    Provisions shall be made to assure that appropriate expertise is brought to bear in appropriate expertise is brought to bear in reviews of operational phase activities. reviews of operational phase activities.
Persons fulfilling the independent review function shall be         IAW NRC Safety qualified as follows:                                               Evaluation ML050210276 (1) Supervisor or Chairperson:
: a. Education: baccalaureate in engineering or related science.
: b. Minimum experience: 6 years combined managerial and technical support.
(2) Reviewers:
: a. Education:
- Baccalaureate in engineering or related science for those independent review personnel who are required to review problems in nuclear power plant operations, nuclear engineering, chemistry and radiochemistry, metallurgy, nondestructive testing, 19


ANS 3.2 Side-By Side Comparison           7/25/2012 20 instrumentation and control, radiological safety, mechanical engineering, and electrical engineering. - High school diploma or equivalent for those independent review personnel who are required to review problems in administrative control and quality assurance practices, training, and emergency plans and related procedures and equipment. - Alternatives to the education requirements may be applied consistent with USNRC Regulatory Guide 1.8 [4]. b. Minimum experience: 5 years experience in their own area of responsibility (1 through 12 above).
ANS 3.2 Side-By Side Comparison 7/25/2012 instrumentation and control, radiological safety, mechanical engineering, and electrical engineering.
3.2.2.2 Scope of Review 4.3.4 Subjects Requiring IndependentReview 4.3.4 Subjects Requiring Independent Review The independent review function shall perform the following:
- High school diploma or equivalent for those independent review personnel who are required to review problems in administrative control and quality assurance practices, training, and emergency plans and related procedures and equipment.
The following subjects shall be reviewed by the independent review body: The following subjects shall be  reviewed by the independent review body: (1) Reviews proposed changes to the facility as described in the safety analysis report (SAR) and verifies that changes do not adversely affect safety and if a technical specification change or NRC review is required.
- Alternatives to the education requirements may be applied consistent with USNRC Regulatory Guide 1.8 [4].
(1) Written safety evaluations of changes in the facility as described in the Safety Analysis Report, changes in procedures as described in the Safety Analysis Report and tests or experiments not described in the Safety Analysis Report which are completed without prior NRC approval under the provisions of 10 CFR 50.59(a)(1). This review is to verify that such changes, tests or experiments did not involve a change in the technical specifications or an unreviewed safety question as defined in10CFR 50.59(a)(2). (1) Written safety evaluations of changes in the facility as described in the Safety Analysis Report, changes in procedures as described in the Safety Analysis Report and tests or experiments not described in the Safety Analysis Report which are completed without prior NRC approval under the provisions of 10 CFR 50.59(a)(1). This review is to verify that such changes, tests or experiments did not involve a change in the technical specifications or an unreviewed safety question as defined in10CFR 50.59(a)(2). (2) Reviews proposed tests and experiments not described in the SAR prior to implementation. Verifies the determination of whether changes to proposed tests and experiments not described in the SAR require a technical specification change or license amendment. .  (2) Proposed changes in procedures, Proposed changes in the facility, or proposed tests or experiments any of which involves a change in the technical specification or an unreviewed safety question as defined in 10 CFR 50.59(c).
: b. Minimum experience: 5 years experience in their own area of responsibility (1 through 12 above).
Matters of this kind shall be referred to the independent review body by the 0nsite operating organization (see 4.4) following (2) Proposed changes in procedures, Proposed changes in the facility, or proposed tests or experiments any of which involves a change in the technical specification or an unreviewed safety question as defined in 10 CFR 50.59(c).
3.2.2.2 Scope of Review                                                           4.3.4 Subjects Requiring Independent          4.3.4 Subjects Requiring Independent Review                                        Review The independent review function shall perform the following:                     The following subjects shall be              The following subjects shall be reviewed by the independent review body:     reviewed by the independent review body:
Matters of this kind shall be referred to the independent review body by the 0nsite operating organization (see 4.4) following
(1) Reviews proposed changes to the facility as described in the                 (1) Written safety evaluations of changes    (1) Written safety evaluations of changes safety analysis report (SAR) and verifies that changes do not                     in the facility as described in the Safety    in the facility as described in the Safety adversely affect safety and if a technical specification change or               Analysis Report, changes in procedures        Analysis Report, changes in procedures as NRC review is required.                                                           as described in the Safety Analysis Report   described in the Safety Analysis Report and tests or experiments not described in     and tests or experiments not described in the Safety Analysis Report which are          the Safety Analysis Report which are completed without prior NRC approval          completed without prior NRC approval under the provisions of 10 CFR                under the provisions of 10 CFR 50.59(a)(1). This review is to verify that   50.59(a)(1). This review is to verify that such changes, tests or experiments did        such changes, tests or experiments did not not involve a change in the technical        involve a change in the technical specifications or an unreviewed safety        specifications or an unreviewed safety question as defined in10CFR 50.59(a)(2).     question as defined in10CFR 50.59(a)(2).
(2) Reviews proposed tests and experiments not described in the                   (2) Proposed changes in procedures,          (2) Proposed changes in procedures, SAR prior to implementation. Verifies the determination of                       Proposed changes in the facility, or          Proposed changes in the facility, or whether changes to proposed tests and experiments not                             proposed tests or experiments any of          proposed tests or experiments any of described in the SAR require a technical specification change or                 which involves a change in the technical      which involves a change in the technical license amendment.                                                                specification or an unreviewed safety        specification or an unreviewed safety question as defined in 10 CFR 50.59(c).       question as defined in 10 CFR 50.59(c).
.                                                                                Matters of this kind shall be referred to the Matters of this kind shall be referred to the independent review body by the 0nsite         independent review body by the 0nsite operating organization (see 4.4) following    operating organization (see 4.4) following 20


ANS 3.2 Side-By Side Comparison           7/25/2012 21 its review, or by other functional organizational units within the owner organization, prior to implementation. its review, or by other functional organizational units within the owner organization, prior to implementation. (3) Reviews proposed technical specification changes and license amendments relating to nuclear safety prior to NRC submittal and implementation, except in those cases where the change is identical to a previously approved change.
ANS 3.2 Side-By Side Comparison 7/25/2012 its review, or by other functional         its review, or by other functional organizational units within the owner       organizational units within the owner organization, prior to implementation.      organization, prior to implementation.
(3) Changes in the technical specifications or license amendments relating to nuclear safety prior to implementation, except in those cases where the change is identical to a previously reviewed proposed change. (3) Changes in the technical specifications or license amendments relating to nuclear safety prior to submi ttal to the Commission for approval and prior to implementation. (4) Reviews violations, deviations, and events that are required to be reported to the NRC. This review includes the results of investigations and recommendations resulting from such investigations to prevent or reduce the probability of recurrence of the event.
(3) Reviews proposed technical specification changes and license                   (3) Changes in the technical specifications (3) Changes in the technical specifications amendments relating to nuclear safety prior to NRC submittal and                   or license amendments relating to nuclear  or license amendments relating to nuclear implementation, except in those cases where the change is                           safety prior to implementation, except in   safety prior to submittal to the Commission identical to a previously approved change.                                         those cases where the change is identical  for approval and prior to implementation.
(4) Violations, deviations, and reportable events which require reporting to the NRC in writing 24 hours, such as (4) Violations, deviations, and reportable events which require reporting to the NRC in writing.
to a previously reviewed proposed change.
Review of events covered under this subsection shall include the results of any investigations made and the recommendations resulting from such investigations to prevent or reduce the probability of recurrence of the event. (5) Reviews any matter related to nuclear safety that is requested by the plant manager or any IRB/IRC member.
(4) Reviews violations, deviations, and events that are required to                 (4) Violations, deviations, and reportable  (4) Violations, deviations, and reportable be reported to the NRC. This review includes the results of                         events which require reporting to the NRC  events which require reporting to the NRC investigations and recommendations resulting from such                              in writing 24 hours, such as               in writing.
(5) Any other matter involving safe operation of the nuclear power plant which an independent reviewer deems appropriate for consideration, or which is referred to the independent reviewers by the onsite operating organization or by other functional organizational units within the owner organization. (6) Reviews corrective actions for significant conditions adverse to quality.     (7) Reviews internal audit reports.
investigations to prevent or reduce the probability of recurrence of the event.                                                                                                                      Review of events covered under this subsection shall include the results of any investigations made and the recommendations resulting from such investigations to prevent or reduce the probability of recurrence of the event.
(8) Reviews the adequacy of the internal audit program every 24 months. 3.2.2.3 Independent Review Body
(5) Reviews any matter related to nuclear safety that is requested                                                             (5) Any other matter involving safe by the plant manager or any IRB/IRC member.                                                                                     operation of the nuclear power plant which an independent reviewer deems appropriate for consideration, or which is referred to the independent reviewers by the onsite operating organization or by other functional organizational units within the owner organization.
(6) Reviews corrective actions for significant conditions adverse to quality.
(7) Reviews internal audit reports.
(8) Reviews the adequacy of the internal audit program every 24 months.
3.2.2.3 Independent Review Body 21


ANS 3.2 Side-By Side Comparison           7/25/2012 22 A group may function to perform the reviews of 3.2.2.2 and is described as an independent review body (IRB). In discharging its review responsibilities, the IRB keeps safety considerations paramount when opposed to cost or schedule considerations. One or more organizational units may collectively perform this function.
ANS 3.2 Side-By Side Comparison 7/25/2012 A group may function to perform the reviews of 3.2.2.2 and is         IAW NRC Safety described as an independent review body (IRB). In discharging         Evaluation its review responsibilities, the IRB keeps safety considerations     ML050210276 paramount when opposed to cost or schedule considerations.
One or more organizational units may collectively perform this function.
: 1. The IRB reviews shall be supplemented as follows:
: 1. The IRB reviews shall be supplemented as follows:
: a. A qualified person, independent of the preparer, reviews proposed changes in the procedures as described in the SAR prior to implementation of the change to determine if a technical specification change or NRC approval is required. b. Audits of selected changes in the procedures described in the SAR are performed to verify that procedure reviews and revision controls are effectively implemented. c. Competent individual(s) or group(s) other than those who performed the original design but who may be from the same organization verify that changes to the facility do not result in a loss of adequate design or safety margins. 2. The results of IRB reviews of matters involving the safe operation of the facility are periodically independently reviewed. This review is intended to support management in identifying and resolving issues potentially affecting safe plant operation. This review supplements the existing corrective action programs and audits. a. The review is performed by a team consisting of personnel with experience and competence in the activities being reviewed, but independent from cost and schedule considerations and from the organizational unit[s] responsible for those activities. b. The review is supplemented by outside consultants or organizations as necessary to ensure the team has the requisite expertise and competence. c. Results of the review are documented and reported to responsible management. IAW NRC Safety Evaluation ML050210276
: a. A qualified person, independent of the preparer, reviews proposed changes in the procedures as described in the SAR prior to implementation of the change to determine if a technical specification change or NRC approval is required.
 
: b. Audits of selected changes in the procedures described in the SAR are performed to verify that procedure reviews and revision controls are effectively implemented.
ANS 3.2 Side-By Side Comparison            7/25/2012 23  d. Management periodically evaluates issues they determine warrant special attention, such as deficient plant programs, declining performance trends, employee concerns, or other issues related to safe plant operations and determine what issues warrant the review. e. Management determines the scheduling and scope of review and the composition of the team performing the review.
: c. Competent individual(s) or group(s) other than those who performed the original design but who may be from the same organization verify that changes to the facility do not result in a loss of adequate design or safety margins.
3.2.2.4  Independent Review Committee 4.3.2.1 Committee CompositionWhen an independent review committee is assigned independent review responsibilities: 1. The independent review committee reports to a management level above the plant manager. 2. The independent review committee shall be composed of no less than 5 persons and no more than a minority of members are from the on-site operating organization. Competent alternates are permitted if designated in advance. The use of alternates shall be restricted to legitimate absence of the principles. 3. Results of the meeting shall be documented and recorded and disseminated promptly to appropriate members of management having responsibility in the area reviewed. 4. Consultants and contractors are used for the review of complex problems beyond the expertise of the independent review committee.
: 2. The results of IRB reviews of matters involving the safe operation of the facility are periodically independently reviewed. This review is intended to support management in identifying and resolving issues potentially affecting safe plant operation. This review supplements the existing corrective action programs and audits.
IAW NRC Safety Evaluation ML050210276  When a standing committee is responsible for the independent review program. it shall be composed of no less than five persons, of whom no more than a minority are members of the onsite operating organization. Competent alternates are permitted if designated in advance. The use of alternates shall be restricted to legitimate absences of principals. 5. During the period of initial operation, meetings shall be conducted no less frequently than once per calendar quarter. Afterwards meetings are conducted no less than twice a year.
: a. The review is performed by a team consisting of personnel with experience and competence in the activities being reviewed, but independent from cost and schedule considerations and from the organizational unit[s]
4.3.2.2 Meeting FrequencyFormal meetings of personnel assigned to a standing committee functioning as an independent review group shall be scheduled as needed. During the period of initial operation such meetings should be held no less frequently than once per calendar quarter. Subsequently, the meeting frequency shall not be less than twice a year.
responsible for those activities.
4.3.2.2 Meeting FrequencyFormal meetings of personnel assigned to a standing committee functioning as an independent review group shall be scheduled as needed. During the period of initial operation such meetings should be held no less frequently than once per calendar quarter. Subsequently, the meeting frequency shall not be less than twice a year.
: b. The review is supplemented by outside consultants or organizations as necessary to ensure the team has the requisite expertise and competence.
: c. Results of the review are documented and reported to responsible management.
22


It is intended that committee decisions 
ANS 3.2 Side-By Side Comparison 7/25/2012
 
: d. Management periodically evaluates issues they determine warrant special attention, such as deficient plant programs, declining performance trends, employee concerns, or other issues related to safe plant operations and determine what issues warrant the review.
ANS 3.2 Side-By Side Comparison           7/25/2012 24 normally be made at formal meetings. However, in extenuating circumstances where it is impractical to convene a quorum for a formal meeting within a necessary time constraint, alternative means such as a conference call are acceptable. In such cases, action taken shall be reviewed by a quorum of the independent review body at its next regularly scheduled meeting. 6. A quorum for formal meetings shall consist of not less than a majority of the members, or duly appointed alternates. The chairperson or duly appointed alternate shall be present for all meetings; and no more than a minority of the quorum shall have line responsibility for operation of the plant.
: e. Management determines the scheduling and scope of review and the composition of the team performing the review.
4.3.2.3 Quorum A quorum for formal meetings of the committee held under the provisions of 4.3.2.2 shall consist of not less than a majority of the principals, or duly appointed alternates, and shall be subject to the following constraints: the chairman (or his duly appointed alternate) shall be present for all formal meetings; and no more than a minority of the quorum .shall have line responsibility for operation of the plant. 4.3.2.3 QuorumA quorum for formal meetings of the committee held under the provisions of 4.3.2.2 shall consist of not less than a majority of the principals, or duly appointed alternates, and shall be subject to the following constraints: the chairman (or his duly appointed alternate) shall be present for all formal meetings; and no more than a minority of the quorum .shall have line responsibility for operation of the plant. 3.2.3 Indoctrination and Training Qualification requirements for positions in the plant operating organization shall be established in accordance with the provisions of plant technical specifications, American National Standard for Selection, Qualification and Training of Personnel for Nuclear Power Plants, USNRC Regulatory Guide 1.8 [4]. USNRC Regulatory Guide 1.8 [4].or ASME NQA-1-2008 and the NQA-1a-2009 addenda [2] as applicable.  
3.2.2.4 Independent Review Committee                                                                                            4.3.2.1 Committee Composition When an independent review committee is assigned independent        IAW NRC Safety                                              When a standing committee is responsible review responsibilities:                                            Evaluation                                                  for the independent review program. it ML050210276                                                shall be composed of no less than five
: 1. The independent review committee reports to a management                                                                    persons, of whom no more than a minority level above the plant manager.                                                                                                  are members of the onsite operating organization. Competent alternates are
: 2. The independent review committee shall be composed of no                                                                    permitted if designated in advance. The less than 5 persons and no more than a minority of members are                                                                  use of alternates shall be restricted to from the on-site operating organization. Competent alternates are                                                              legitimate absences of principals.
permitted if designated in advance. The use of alternates shall be restricted to legitimate absence of the principles.
: 3. Results of the meeting shall be documented and recorded and disseminated promptly to appropriate members of management having responsibility in the area reviewed.
: 4. Consultants and contractors are used for the review of complex problems beyond the expertise of the independent review committee.
: 5. During the period of initial operation, meetings shall be                          4.3.2.2 Meeting Frequency                4.3.2.2 Meeting Frequency conducted no less frequently than once per calendar quarter.                          Formal meetings of personnel assigned to  Formal meetings of personnel assigned to Afterwards meetings are conducted no less than twice a year.                          a standing committee functioning as an    a standing committee functioning as an independent review group shall be        independent review group shall be scheduled as needed. During the period of scheduled as needed. During the period of initial operation such meetings should be initial operation such meetings should be held no less frequently than once per    held no less frequently than once per calendar quarter. Subsequently, the       calendar quarter. Subsequently, the meeting frequency shall not be less than  meeting frequency shall not be less than twice a year.                             twice a year.
It is intended that committee decisions 23


ANS 3.2 Side-By Side Comparison 7/25/2012 normally be made at formal meetings.
However, in extenuating circumstances where it is impractical to convene a quorum for a formal meeting within a necessary time constraint, alternative means such as a conference call are acceptable. In such cases, action taken shall be reviewed by a quorum of the independent review body at its next regularly scheduled meeting.
: 6. A quorum for formal meetings shall consist of not less than a                              4.3.2.3 Quorum                                4.3.2.3 Quorum majority of the members, or duly appointed alternates. The                                    A quorum for formal meetings of the          A quorum for formal meetings of the chairperson or duly appointed alternate shall be present for all                              committee held under the provisions of        committee held under the provisions of meetings; and no more than a minority of the quorum shall have                                4.3.2.2 shall consist of not less than a      4.3.2.2 shall consist of not less than a line responsibility for operation of the plant.                                              majority of the principals, or duly          majority of the principals, or duly appointed appointed alternates, and shall be subject    alternates, and shall be subject to the to the following constraints: the chairman    following constraints: the chairman (or his duly appointed alternate) shall be present (or his duly appointed alternate) shall be for all formal meetings; and no more than a present for all formal meetings; and no      minority of the quorum .shall have line more than a minority of the quorum .shall    responsibility for operation of the plant.
have line responsibility for operation of the plant.
3.2.3 Indoctrination and Training Qualification requirements for positions in the plant operating      Refers to guidance in organization shall be established in accordance with the provisions  NQA-1 of plant technical specifications, American National Standard for Selection, Qualification and Training of Personnel for Nuclear Power Plants, USNRC Regulatory Guide 1.8 [4]. USNRC Regulatory Guide 1.8 [4].or ASME NQA-1-2008 and the NQA-1a-2009 addenda [2] as applicable.
Training shall be in accordance with ASME NQA-1-2008 and the NQA-1a-2009 addenda [2].
Training shall be in accordance with ASME NQA-1-2008 and the NQA-1a-2009 addenda [2].
Refers to guidance in NQA-1  3.2.4 Maintenance
3.2.4 Maintenance 24
 
ANS 3.2 Side-By Side Comparison            7/25/2012 25 Maintenance activities that may affect the functions of structures, systems, or components shall
: (1) be performed in a manner to assure quality, availability, and reliability at least equivalent to that specified in the original or updated design bases and requirements. (2) provide for the conduct of appropriate inspections and performance tests to demonstrate that maintenance has been properly performed. (3) be planned and performed in accordance with written procedures, documented instructions or drawings appropriate to the circumstances which conform to applicable codes, standards, specifications, and criteria.  (4) be documented in accordance with applicable codes, standards and regulatory commitments. This documentation shall be retained as specified in 3.17.    (5) be scheduled and planned so as not to violate plant Technical Specifications or compromise the safety of plant personnel or equipment. Planning shall evaluate the possible safety consequences of concurrent or sequential maintenance, testing or operating activities. Equipment required to be operable for the prevailing mode shall be available, and maintenance shall be performed in a manner such that license limits are not violated. Planning for maintenance shouldinclude evaluation of equipment out-of-service to ensure the increased risk is known and compensatory measures are taken when appropriate. Planning should also evaluate the use of special processes, equipment and materials, potential hazards to personnel and equipment and the benefits of minimizing equipment unavailability.  (6) contain general rules for the development, review, and approval, prior to use, of repair, replacement, recurring, and routine maintenance procedures consistent with the provisions of this standard.    (7) provide for a preventive maintenance program, based on performance and condition monitoring, that prescribes the frequency and type of maintenance to be performed. A preliminary program based on service conditions, industry experience with comparable equipment and supplier recommendations, should be developed prior to fuel loading. The program should be revised and updated as NRC did not endorse subpart 2.18 of NQA-1 in RG1.33. 
 
See note under section 2.2  Would affect the Glossary.


May be needed to support section 5.2.7 and 5.2.7.1 in ANS 3.2-1976 version.  
ANS 3.2 Side-By Side Comparison 7/25/2012 Maintenance activities that may affect the functions of structures, systems, or components shall:
NRC did not endorse (1) be performed in a manner to assure quality, availability, and    subpart 2.18 of NQA-1 reliability at least equivalent to that specified in the original or in RG1.33.
updated design bases and requirements.
(2) provide for the conduct of appropriate inspections and performance tests to demonstrate that maintenance has been properly performed.                                                  See note under section 2.2 (3) be planned and performed in accordance with written procedures, documented instructions or drawings appropriate to the  Would affect the circumstances which conform to applicable codes, standards,          Glossary.
specifications, and criteria.
(4) be documented in accordance with applicable codes, standards and regulatory commitments. This documentation shall be retained    May be needed to as specified in 3.17.
support section 5.2.7 (5) be scheduled and planned so as not to violate plant Technical    and 5.2.7.1 in ANS Specifications or compromise the safety of plant personnel or        3.2-1976 version.
equipment. Planning shall evaluate the possible safety consequences of concurrent or sequential maintenance, testing or operating activities. Equipment required to be operable for the prevailing mode shall be available, and maintenance shall be performed in a manner such that license limits are not violated.
Planning for maintenance shouldinclude evaluation of equipment out-of-service to ensure the increased risk is known and compensatory measures are taken when appropriate. Planning should also evaluate the use of special processes, equipment and materials, potential hazards to personnel and equipment and the benefits of minimizing equipment unavailability.
(6) contain general rules for the development, review, and approval, prior to use, of repair, replacement, recurring, and routine maintenance procedures consistent with the provisions of this standard.
(7) provide for a preventive maintenance program, based on performance and condition monitoring, that prescribes the frequency and type of maintenance to be performed. A preliminary program based on service conditions, industry experience with comparable equipment and supplier recommendations, should be developed prior to fuel loading. The program should be revised and updated as 25


ANS 3.2 Side-By Side Comparison           7/25/2012 26 experience is gained with the equipment. Equipment history files should be created, kept current, and periodically evaluated for adverse trends. The files should be organized to provide complete and easily retrievable equipment history.   (8) provide for the prompt determination, evaluation, recording, and dissemination to appropriate personnel of the causes of malfunctions or unacceptable performance (see also Section 3.16). Industry experience with malfunctioning equipment shouldbe reviewed and evaluated to determine whether a component of the same type can be expected to perform its function reliably. (9) provide requirements to implement appropriate corrective actions prior to replacement or repair of similar components in systems that performed unsatisfactorily. (10) address aging, generic, and common cause effects to prevent possible recurrence and to inform appropriate industry communication organizations. (11) provide assurance that replacement components shall receive adequate testing or shall be of a design for which experience indicates a high probability of satisfactory performance. (12) evaluate phased replacement to permit in-service monitoring of new components thus minimizing the possibility of a hidden deficiency producing a systematic failure. (13) evaluate implementing and monitoring an augmented testing and inspection program following a large-scale component replacement (or repair) until such time that a suitable level of performance has been demonstrated.
ANS 3.2 Side-By Side Comparison 7/25/2012 experience is gained with the equipment. Equipment history files should be created, kept current, and periodically evaluated for adverse trends. The files should be organized to provide complete and easily retrievable equipment history.
3.2.5 Housekeeping and Cleanliness Control Housekeeping and cleanliness shall be controlled in accordance with ASME NQA-1-2008 and the NQA-1a-2009 addenda [2].
(8) provide for the prompt determination, evaluation, recording, and dissemination to appropriate personnel of the causes of malfunctions or unacceptable performance (see also Section 3.16).
NRC did not endorse subpart 2.18 of NQA-1  
Industry experience with malfunctioning equipment shouldbe reviewed and evaluated to determine whether a component of the same type can be expected to perform its function reliably.
 
(9) provide requirements to implement appropriate corrective actions prior to replacement or repair of similar components in systems that performed unsatisfactorily.
in RG1.33.  
(10) address aging, generic, and common cause effects to prevent possible recurrence and to inform appropriate industry communication organizations.
 
(11) provide assurance that replacement components shall receive adequate testing or shall be of a design for which experience indicates a high probability of satisfactory performance.
ANS 3.2 Side-By Side Comparison            7/25/2012 27 May be needed to support section 5.2.7 and 5.2.7.1 in ANS 3.2-1976 version. 3.3 Design Control Design activities, including modifications, associated with structures, systems, and components (SSC)s shall be controlled in accordance with ASME NQA-1-2008 and the NQA-1a-2009 addenda [2].
(12) evaluate phased replacement to permit in-service monitoring of new components thus minimizing the possibility of a hidden deficiency producing a systematic failure.
Essentially, equivalent to NQA- 1. Ok.
(13) evaluate implementing and monitoring an augmented testing and inspection program following a large-scale component replacement (or repair) until such time that a suitable level of performance has been demonstrated.
3.2.5 Housekeeping and Cleanliness Control Housekeeping and cleanliness shall be controlled in accordance       NRC did not endorse with ASME NQA-1-2008 and the NQA-1a-2009 addenda [2].               subpart 2.18 of NQA-1 in RG1.33.
26


ANS 3.2 Side-By Side Comparison 7/25/2012 May be needed to support section 5.2.7 and 5.2.7.1 in ANS 3.2-1976 version.
3.3 Design Control Design activities, including modifications, associated with        Essentially, equivalent structures, systems, and components (SSC)s shall be controlled      to NQA- 1. Ok.
in accordance with ASME NQA-1-2008 and the NQA-1a-2009 addenda [2].
1982 version states to do IAW NQA-1. No unique additional requirements.
1982 version states to do IAW NQA-1. No unique additional requirements.
3.4 Procurement Document Control Procurement Documents shall be controlled in accordance with ASME NQA-1-2008 and the NQA-1a-2009 addenda [2].
3.4 Procurement Document Control Procurement Documents shall be controlled in accordance with       Essentially, equivalent ASME NQA-1-2008 and the NQA-1a-2009 addenda [2].                   to NQA- 1. Ok.
Essentially, equivalent to NQA- 1. Ok.  
 
1982 version states to do IAW NQA-1. No unique additional requirements.
1982 version states to do IAW NQA-1. No unique additional requirements.
3.5 Instructions, Procedures, and Drawings Instructions, procedures, and drawings shall be used in accordance with ASME NQA-1-2008 and the NQA-1a-2009 addenda [2]. Appendix A includes a listing of typical procedures that are considered to affect safe operation or the quality of SSCs    
3.5 Instructions, Procedures, and Drawings Instructions, procedures, and drawings shall be used in accordance with ASME NQA-1-2008 and the NQA-1a-2009 addenda [2]. Appendix A includes a listing of typical procedures that are considered to affect safe operation or the quality of SSCs 27
 
ANS 3.2 Side-By Side Comparison            7/25/2012 28 that shouldbe addressed through the managerial and administrative controls program. Specific requirements for operational procedures are as follows.
3.5.1 Procedure Adherence  5.2.2 Procedure Adherence 5.2.2 Procedure  Adherence Procedures shall be followed, and the requirements for their use shall be prescribed in writing. Procedures and changes thereto are controlled in accordance with Section 3.6 of this standard.
Essentially, equivalent to NQA-1.
 
Similar to 1982 version, Section5.2.2. Procedure shall be followed, and the requirements  for use of procedures shall be prescribed in writing. Rules shall be established which provide methods by which temporary changes to approved procedures can be made. including the designation of a person or persons authorized to approve such changes.
Temporary changes which clearly do not change the intent of the approved procedure, shall at a minimum be approved by two member of the plant staff knowledgeable in the areas affected by the procedures. At least one of these individuals shall be the supervisor in charge of the shift and hold a senior operator's license on the unit affected. Such changes shall be documented and if appropriate, incorporated in the next revision of the affected procedure.
Procedures shall be (allowed, and the requirements for use of procedures shall be prescribed in writing. Rules shall be established which provide methods by which temporary changes to approved procedures can be made, including the designation of 8 person or persons authorized to approve such changes. Temporary changes which clearly do not change the intent of the approved procedure, shall as a minimum be approved by two members of the plant staff knowledgeable in the areas affected by the procedure. At least one of these shall be a member of plant supervision. For changes to procedures which may affect the operational status of plant systems or equipment. the changes shall be approved by two members of the plant supervision, at least one of whom holds a senior operator' License on the unit affected. Such changes shall be documented and, if appropriate. incorporated in the next revision of the affected procedure. In the event of an emergency not covered by an approved procedure, or an emergency not following the path upon which the approved procedure is based, operations personnel shall be instructed to take action so as to protect public health and safety, and minimize personnel injury and damage to the facility.
Essentially, equivalent to ANS 3.2 1976, section 5.2.2. In the event of an emergency not covered by an approved procedure, operations personnel shall be instructed to take action so as to minimize personnel injury and damage to the facility and to protect health and safety. In the event of an emergency not covered by an approved procedure, or an emergency not following the path upon which the approved procedure is based, operations personnel shall be instructed to take action so as to protect health and safety, and minimize personnel injury and damage to the facility. 
 
ANS 3.2 Side-By Side Comparison            7/25/2012 29 Guidance should be provided to identify the manner in which procedures are to be implemented. Examples of such guidance include identification of those tasks that require:
Essentially, equivalent to ANS 3.2 1976, section 5.2.2. Guidance should be provided to identify the manner in which procedures are to be implemented. Example of such guidance include identification of those tasks that require: Guidance should be provided to identify the manner in which procedures are to be implemented. Examples of such guidance include identification of those tasks that require: (1) The written procedure to be present and followed step-by-step while the task is being performed.
Essentially, equivalent to ANS 3.2 1976, section 5.2.2. (1) The written procedure to be present and followed step by step while the task is being performed (l) The written procedure to be present. Either on paper or on a suitable electronic or other display, and followed step by step while the task is being performed. (2) Memorization of procedural steps.
Essentially, equivalent to ANS 3.2 1976, section 5.2.2. (2) The operator to have committed the procedural step to memory (2) The operator to have committed the procedural steps to memory. (3) Verification of completion of significant steps, by initials or signatures on check-off lists. Startup and shutdown procedures are examples of procedures that require verification.
Essentially, equivalent to ANS 3.2 1976, section 5.2.2. (3) Verification of completion of significant steps by initial or signature of \check off list (3) Verification of completion of significant steps. by initials or signatures of check off lists. The types of procedures that shall be present and referred to directly are those developed for extensive or complex jobs where reliance on memory cannot be trusted, e.g., reactor startup, tasks which are infrequently performed, and tasks in which operations shall be performed in a specified sequence, and emergency operating procedures. Routine procedural actions that are frequently repeated may not require the procedure to be present; however, periodic procedure reference may be needed to verify the adequacy of procedures and task performance, and accurate adherence. Copies of all procedures shall be available to appropriate members of the plant staff.
 
Those procedures that are necessary for use by the reactor operators shall be available and readily accessible in the control room. If an electronic display is relied upon as the written procedure, a hard copy should be available as backup. If documentation of an action is required, the necessary documentation shall be recorded as the task is performed. Essentially, equivalent to ANS 3.2 1976, section 5.2.2. 5.2.2 Procedure Adherence Procedure shall be followed and the requirement for use of procedures shall be prescribed in writing. Rules shall be established which provide methods by which temporary changes to approved procedures can be made, including the designation of a person or persons authorized to approve such changes. Temporary changes which clearly do not change the intent of the approved procedure shall at a minimum be approved by two members of the plant staff knowledgeable in the areas affected by the procedures. At least one of these individuals shall be the supervisor in charge of the shift and hold a senior operator's license on the unit affected. Such changes shall be documented and if appropriate, incorporated in the next The types of procedures that shall be present and referred to directly are those developed for extensive or complex jobs where reliance on memory cannot be trusted. e.g. reactor startup tasks which are infrequently performed, and tasks in which operation must be performed in a specified sequence. Procedural steps for which actions should be committed. to memory include. for example, immediate actions in emergency procedures. Routine procedural actions that. Are frequently repeated might not require the procedure to be present. Copies of all procedure shall be available to appropriate members of the plant staff. Those procedures which may be necessary for' use by the reactor operator's shall be available in the control room. If documentation of an action is required  the necessary data shall be recorded as the task is performed. Examples of procedures requiring 
 
ANS 3.2 Side-By Side Comparison            7/25/2012 30  revision of the affected procedure. In the event of an emergency not covered by an approved procedure, operations personnel shall be instructed to take action so as to minimize personnel injury and damage to the facility and to protect health and safety. Guidance should be provided to identify the manner in which procedures are to be implemented. Examples of such guidance include identification of those skill that require: (1) The written procedure to be present followed step by step while the task is being performed (2) The operator to have committed the procedural steps to memory (3) Verification of completion of significant steps by initial or signature of check off list The type of procedures that shall he present and referred to directly are those developed examples jobs where reliance on memory cannot be trusted. e.g., reactor "start-up tasks which are infrequently Performed any tasks in which operation) must be performed in a specified sequence. Procedure steps for which action should be committed to memory include, or example, action in emergency procedures. Routine procedural actions that are frequently repeated may not require the procedure to be present Copies of all procedures shall be available to appropriate members of the plant staff  documentation of an action is required. the necessary data shall be recorded as the task is performed. Examples of procedure requiring verification are furnished in verification are furnished in 5.3.4.1 and 5.3.4.2. 
 
ANS 3.2 Side-By Side Comparison            7/25/2012 31 5.3.4.1 And 5.3.4:2. 3.5.2 Content and Format Procedure format and content may vary from one owner organization, or group therein, to the other. However, procedures shall include the following elements as appropriate to the purpose or task to be described.
See section 5.3.2 of 3.5.1 on the ANS 3.2 sheet  3.5.2.1 Title/Status Each procedure is given a title descriptive of the work or subject it addresses, and includes a revision number and/or date and an approval status.
See section 5.3.2 of 3.5.1 on the ANS 3.2 sheet  3.5.2.2 Purpose/Statement of Applicability/Scope The purpose for which the procedure is intended is clearly stated (if not clear from the title). The systems, structures, components, processes or conditions to which the procedure applies are also clearly described.
See section 5.3.2 of 3.5.1 on the ANS 3.2 sheet  3.5.2.3 References Applicable references, including reference to appropriate Technical Specifications, are required. References are included within the body of the procedure when the sequence of steps requires other tasks to be performed (according to the reference) prior to or concurrent with a particular step.
See section 5.3.2 of 3.5.1 on the ANS 3.2 sheet  3.5.2.4 Prerequisites/Initial Conditions Prerequisites/initial conditions identify those independent actions or procedures that shall be accomplished and plant conditions that are required to exist prior to performing the procedure. A prerequisite applicable to only a specific portion of a procedure is See section 5.3.2 of 3.5.1 on the ANS 3.2
 
ANS 3.2 Side-By Side Comparison            7/25/2012 32 so identified.
sheet 3.5.2.5 Precautions Precautions alert the user to those important measures to be used to protect equipment and personnel, including the public, or to avoid an abnormal or emergency situation during performance of the procedure. Cautionary notes applicable to specific steps are included in the main body of the procedure and are identified as such. See section 5.3.2 of 3.5.1 on the ANS 3.2 sheet  3.5.2.6 Limitations and Actions Limitations on the parameters being controlled and appropriate corrective measures to return the parameter to the normal control band are specified.
See section 5.3.2 of 3.5.1 on the ANS 3.2 sheet  3.5.2.7 Main Body The main body of the procedure contains the step-by-step instructions in the degree of detail necessary for performing the required function or task.
See section 5.3.2 of 3.5.1 on the ANS 3.2 sheet  3.5.2.8 Acceptance Criteria The acceptance criteria provide the quantitative or qualitative criteria against which the success or failure of the step or action (such as for a test type activity) would be judged.
See section 5.3.2 of 3.5.1 on the ANS 3.2 sheet  3.5.2.9 Checklists Complex procedures should utilize checklists which may be See section 5.3.2 of 3.5.1 on the ANS 3.2
 
ANS 3.2 Side-By Side Comparison            7/25/2012 33 included as part of the procedure or appended to it.
sheet    3.5.3 Plant Procedures Plant procedures provide instructions for controlling plant activities. Typical examples of these types of plant procedures and their characteristics are as follows.
Essentially, equivalent to ANS 3.2 1976, section 5.3.4.
3.5.3.1 Administrative Control Procedures These include administrative procedures, directives, policies, standards, and similar documents that control the programmatic aspects of facility activities. These administrative documents ensure that the requirements of regulatory and license commitments are implemented. Several levels of administrative controls are applied ranging from those affecting the entire owner organization to those prepared at the implementing group level. These documents establish responsibilities, interfaces, and standard methods (rules of practice) for implementing programs Replacement for 5.1,  ANS 3.2 1976, more general. No problems


identified. Ok. Section 5.2 "Rules of Practice," replaced by part 26 requirements.   
ANS 3.2 Side-By Side Comparison 7/25/2012 that shouldbe addressed through the managerial and administrative controls program. Specific requirements for operational procedures are as follows.
3.5.1 Procedure Adherence                                                                    5.2.2 Procedure Adherence                      5.2.2 Procedure Adherence Procedures shall be followed, and the requirements for their use    Essentially, equivalent  Procedure shall be followed, and the          Procedures shall be (allowed, and the shall be prescribed in writing. Procedures and changes thereto are  to NQA-1.                requirements for use of procedures shall be    requirements for use of procedures shall controlled in accordance with Section 3.6 of this standard.                                  prescribed in writing. Rules shall be          be prescribed in writing. Rules shall be established which provide methods by established which provide methods by which temporary changes to approved which temporary changes to approved            procedures can be made, including the procedures can be made. including the          designation of 8 person or persons designation of a person or persons            authorized to approve such changes.
Similar to 1982 authorized to approve such changes.            Temporary changes which clearly do not version, Section5.2.2.                                                  change the intent of the approved Temporary changes which clearly do not change the intent of the approved              procedure, shall as a minimum be approved by two members of the plant procedure, shall at a minimum be approved staff knowledgeable in the areas affected by two member of the plant staff              by the procedure. At least one of these knowledgeable in the areas affected by the    shall be a member of plant supervision.
procedures. At least one of these individuals For changes to procedures which may shall be the supervisor in charge of the shift affect the operational status of plant and hold a senior operators license on the    systems or equipment. the changes shall unit affected. Such changes shall be          be approved by two members of the plant supervision, at least one of whom holds a documented and if appropriate, incorporated senior operator' License on the unit in the next revision of the affected          affected. Such changes shall be procedure.                                    documented and, if appropriate.
incorporated in the next revision of the affected procedure.
In the event of an emergency not covered by an approved              Essentially, equivalent  In the event of an emergency not covered      In the event of an emergency not covered procedure, or an emergency not following the path upon which the    to ANS 3.2 1976,        by an approved procedure, operations          by an approved procedure, or an approved procedure is based, operations personnel shall be          section 5.2.2.          personnel shall be instructed to take action  emergency not following the path upon instructed to take action so as to protect public health and safety, so as to minimize personnel injury and        which the approved procedure is based, and minimize personnel injury and damage to the facility.
damage to the facility and to protect health  operations personnel shall be instructed to and safety.                                    take action so as to protect health and safety, and minimize personnel injury and damage to the facility.
28


So ok to remove. Section 5.2.1 is elaborated in other parts of the new ANS 3.2. Different levels of detail than ANS 3.2 1976 version. Section 5.3.3. 5.3.3  System Procedures.Instructions for energizing  filling venting. Draining, starting up. shutting down, changing modes of operation and other instructions appropriate for operations of systems related to the safety of the plant shall be delineated in system procedures. Procedures for correcting off-normal conditions shall be developed for those events where system complexity may lead to operator uncertainty. System procedures shall contain check off lists where appropriate.
ANS 3.2 Side-By Side Comparison 7/25/2012 Guidance should be provided to identify the manner in which            Essentially, equivalent  Guidance should be provided to identify the  Guidance should be provided to identify procedures are to be implemented. Examples of such guidance            to ANS 3.2 1976,        manner in which procedures are to be          the manner in which procedures are to be include identification of those tasks that require:                    section 5.2.2.          implemented.                                  implemented. Examples of such guidance include identification of those tasks that Example of such guidance include              require:
3.5.3.2 Operating Orders/Procedures 5.2.3 Operating Order 5.2.3  Operating OrdersInstructions of general and continuing applicability to the conduct of business to the plant staff are provided. Examples where these Similar to 1982 A mechanism shall be provided for dissemination to the plant staff of A mechanism shall be provided for dissemination to the plant staff of
identification of those tasks that require:
(1) The written procedure to be present and followed step-by-step      Essentially, equivalent  (1) The written procedure to be present      (l) The written procedure to be present.
while the task is being performed.                                      to ANS 3.2 1976,        and followed step by step while the task is  Either on paper or on a suitable electronic section 5.2.2.          being performed                              or other display, and followed step by step while the task is being performed.
(2) Memorization of procedural steps.                                  Essentially, equivalent  (2) The operator to have committed the        (2) The operator to have committed the to ANS 3.2 1976,        procedural step to memory                    procedural steps to memory.
section 5.2.2.
(3) Verification of completion of significant steps, by initials or    Essentially, equivalent  (3) Verification of completion of significant (3) Verification of completion of significant signatures on check-off lists. Startup and shutdown procedures          to ANS 3.2 1976,        steps by initial or signature of \check off  steps. by initials or signatures of check off are examples of procedures that require verification.                  section 5.2.2.           list                                          lists.
The types of procedures that shall be present and referred to directly  Essentially, equivalent  5.2.2 Procedure Adherence Procedure          The types of procedures that shall be are those developed for extensive or complex jobs where reliance on    to ANS 3.2 1976,        shall be followed and the requirement for    present and referred to directly are those memory cannot be trusted, e.g., reactor startup, tasks which are        section 5.2.2.           use of procedures shall be prescribed in      developed for extensive or complex jobs infrequently performed, and tasks in which operations shall be                                                                                where reliance on memory cannot be writing. Rules shall be established which performed in a specified sequence, and emergency operating                                                                                    trusted. e.g. reactor startup tasks which procedures. Routine procedural actions that are frequently repeated                              provide methods by which temporary            are infrequently performed, and tasks in may not require the procedure to be present; however, periodic                                  changes to approved procedures can be        which operation must be performed in a procedure reference may be needed to verify the adequacy of                                      made, including the designation of a          specified sequence. Procedural steps for procedures and task performance, and accurate adherence. Copies                                  person or persons authorized to approve      which actions should be committed. to of all procedures shall be available to appropriate members of the                               such changes. Temporary changes which        memory include. for example, immediate plant staff.                                                                                    clearly do not change the intent of the      actions in emergency procedures. Routine procedural actions that. Are frequently approved procedure shall at a minimum be repeated might not require the procedure approved by two members of the plant          to be present. Copies of all procedure shall Those procedures that are necessary for use by the reactor                                      staff knowledgeable in the areas affected    be available to appropriate members of the operators shall be available and readily accessible in the control                              by the procedures. At least one of these      plant staff. Those procedures which may room. If an electronic display is relied upon as the written procedure,                          individuals shall be the supervisor in        be necessary for' use by the reactor a hard copy should be available as backup. If documentation of an                                charge of the shift and hold a senior        operators shall be available in the control action is required, the necessary documentation shall be recorded as                                                                          room. If documentation of an action is operators license on the unit affected.
the task is performed.                                                                                                                        required the necessary data shall be Such changes shall be documented and if recorded as the task is performed.
appropriate, incorporated in the next        Examples of procedures requiring 29


ANS 3.2 Side-By Side Comparison           7/25/2012 34 are applied include, but are not limited to, job turnover and relief, designation of confines of control room, definition of duties of operators and others, transmittal of operating data to management, filing of charts, limitations on access to certain areas and equipment, shipping and receiving instructions. Provisions are made for periodic review and updating of these documents, where appropriate.
ANS 3.2 Side-By Side Comparison 7/25/2012 revision of the affected procedure. In the      verification are furnished in 5.3.4.1 and event of an emergency not covered by an        5.3.4.2.
version, Section 5.2.3.
approved procedure, operations personnel shall be instructed to take action so as to minimize personnel injury and damage to the facility and to protect health and safety. Guidance should be provided to identify the manner in which procedures are to be implemented. Examples of such guidance include identification of those skill that require:
instructions of general and continuing applicability to .the conduct of business.
(1) The written procedure to be present followed step by step while the task is being performed (2) The operator to have committed the procedural steps to memory (3) Verification of completion of significant steps by initial or signature of check off list The type of procedures that shall he present and referred to directly are those developed examples jobs where reliance on memory cannot be trusted. e.g., reactor "start-up tasks which are infrequently Performed any tasks in which operation) must be performed in a specified sequence. Procedure steps for which action should be committed to memory include, or example, action in emergency procedures. Routine procedural actions that are frequently repeated may not require the procedure to be present Copies of all procedures shall be available to appropriate members of the plant staff documentation of an action is required. the necessary data shall be recorded as the task is performed. Examples of procedure requiring verification are furnished in 30
Such instruction... ~, sometimes also referred to as standing orders or standard operating procedures should deal with job turnover and relief, designation of confines of control room, definition of duties of operators and others, transmittal) of operating data to management, filing of charts, limitations on access to certain areas and equipment, shipping and receiving instructions, or other such matters. Provisions should be made for periodic review and updating of standing orders. instructions of general and continuing applicability to the conduct of business.
Such instructions. sometimes also referred to as administrative procedures, standing orders or standard operating procedures, should deal with job turnover and relief. designation of confines of control room, definition of duties of operators and others, transmittal of operating data to management, filing of charts, limitations on access to certain areas and equipment, shipping and receiving instructions. or other such matters. Provisions shall be made for periodic review and updating of operating orders. 3.5.3.3 Special Orders 5.2.4 Special Orde r 5.2.4 Special OrdersManagement instructions, which have short-term applicability and require dissemination, are issued to encompass special operations, housekeeping, data taking, publications and their distribution, plotting process parameters, personnel actions, or other similar matters. Provisions are made for periodic review, updating, and cancellation of these documents, where appropriate.
Essentially, equivalent wording as ANS 3.2, 1976 version, section 5.2.4 A mechanism shall be provided for issuing management instructions which have short-term applicability and which require dissemination. Such instructions sometimes referred to as  special orders, should encompass special operational, housekeeping, data taking, publication and their distribution, plotting process parameters, personnel actions or other familiar material Provisions should be made for periodic review, updating and cancellation of special orders. A mechanism shall be provided for issuing management instructions which have short-term applicability and which require dissemination. Such instructions, sometimes referred to as special orders, should encompass special operations, housekeeping, data taking, publications and their distribution, plotting process parameters, personnel actions or other similar matters. Provisions shall be made for periodic review, updating and cancellation of special orders. 3.5.3.4 Temporary Procedures 5.2.5 Temporary Procedures5.2.5 Temporary ProceduresTemporary procedures may be used to direct operations during testing, refueling, maintenance, and modifications to provide guidance in unusual situations not within the scope of the normal procedures. These procedures ensure orderly and uniform operations for short periods when the plant, a system, or a component of a system is performing in a manner not addressed by existing detailed procedures or has been modified or extended in such a manner that portions of existing procedures do not apply. Temporary procedures include designation of the period of time during which they may be used and are subject to the procedure review process as applicable.
Essentially, equivalent wording as ANS 3.2, 1976 version, section 5.2.5 Temporary procedures may be issued during the operational phase: to direct operations during testing, refueling, maintenance and modifications; to provide guidance in unusual situations not within the scope of the normal procedures; and to ensure orderly and uniform operations for short periods when the plant, a system, or a component of a system is performing in a manner not covered by existing detailed procedures or has been modified or extended in such a manner that Temporary procedures may be issued during the operational phase: to direct operations during testing, refueling, maintenance and modifications; to provide guidance in unusual situations not within the scope of the normal procedures; and to ensure orderly and uniform operations for short periods when the plant, a system, or a component of a system is performing in a manner not covered by existing detailed procedures or has been modified or extended in such a manner that portions of existing procedures do not apply. Temporary procedures shall include 


ANS 3.2 Side-By Side Comparison           7/25/2012 35 portions of existing procedures do not apply. Temporary procedures shall include designation of the period of time during which they may be used and shall be subject to the review process prescribed in 4.3 and 5.2.15 as applicable. designation of the period of time during which they may be used and shall be subject to the review process prescribed in 4.3 and 5.2.15 as applicable. Temporary procedures shall be approved by the management representative assigned approval authority. 3.5.3.5 Engineering Procedures These documents provide instructions for the preparation of engineering documents, engineering analysis, and implementation of engineering programs. This includes activities such as designs; calculations; fabrication, equipment, construction, and installation specifications; drawings; analysis and topical reports; and testing plans or procedures. They include appropriate references to industry codes and standards, design inputs, and technical requirements. Additional criteria for these procedures are contained in ASME NQA-1-2008 and the NQA-1a-2009 addenda
ANS 3.2 Side-By Side Comparison 7/25/2012 5.3.4.1 And 5.3.4:2.
[2]. New section in line with NQA-1 requirements. Ok.
3.5.2 Content and Format Procedure format and content may vary from one owner                  See section 5.3.2 of organization, or group therein, to the other. However, procedures     3.5.1 on the ANS 3.2 shall include the following elements as appropriate to the purpose    sheet or task to be described.
3.5.3.6 Installation Procedures These documents provide instructions for the installation of components generally related to new construction and certain modification activities. They include appropriate reference to industry standards, installation specifications, design drawings, and supplier and technical manuals for the performance of activities. These documents include provisions, such as hold or witness points, for conducting and recording results of required inspections or tests. These documents may include applicable inspection and test instructions subject to the requirements for test and inspection procedures below.
3.5.2.1 Title/Status Each procedure is given a title descriptive of the work or subject it See section 5.3.2 of addresses, and includes a revision number and/or date and an          3.5.1 on the ANS 3.2 approval status.                                                     sheet 3.5.2.2 Purpose/Statement of Applicability/Scope The purpose for which the procedure is intended is clearly stated    See section 5.3.2 of (if not clear from the title). The systems, structures, components,   3.5.1 on the ANS 3.2 processes or conditions to which the procedure applies are also      sheet clearly described.
New section in line with NQA-1 requirements. Installation in operating plants equivalent to design and construction phase.
3.5.2.3 References Applicable references, including reference to appropriate            See section 5.3.2 of Technical Specifications, are required. References are included      3.5.1 on the ANS 3.2 within the body of the procedure when the sequence of steps          sheet requires other tasks to be performed (according to the reference) prior to or concurrent with a particular step.
3.5.3.7 System Procedures These documents contain instructions for energizing, filling, venting, draining, starting up, shutting down, changing modes of operation, and other instructions appropriate for operations of systems related to the safety of the plant. Action s to correct off-normal conditions are invoked following an operator observation or
3.5.2.4 Prerequisites/Initial Conditions Prerequisites/initial conditions identify those independent actions  See section 5.3.2 of or procedures that shall be accomplished and plant conditions that    3.5.1 on the ANS 3.2 are required to exist prior to performing the procedure. A prerequisite applicable to only a specific portion of a procedure is 31
§ New section similar to 1982 version Sections


ANS 3.2 Side-By Side Comparison           7/25/2012 36 an annunciator alarm indicating a condition which, if not corrected, could degenerate into a condition requiring action under an emergency procedure. Separate procedures may be developed for correcting off-normal conditions for those events where system complexity may lead to operator uncertainty 3.2 & 3.5.5.2. 3.5.3.8 Start-up Procedures 5.3.4.1 Start-up Procedures5.3.4.1 Start-up ProceduresThese documents contain instructions for starting the reactor from cold or hot conditions and establishing power operation. This includes documented determination that prerequisites have been satisfied, including confirmation that necessary instruments are operable and properly set, valves are properly aligned, necessary system procedures, tests and calibrations have been completed, and required approvals have been obtained.
ANS 3.2 Side-By Side Comparison 7/25/2012 so identified.                                                      sheet 3.5.2.5 Precautions Precautions alert the user to those important measures to be used  See section 5.3.2 of to protect equipment and personnel, including the public, or to    3.5.1 on the ANS 3.2 avoid an abnormal or emergency situation during performance of      sheet the procedure. Cautionary notes applicable to specific steps are included in the main body of the procedure and are identified as such.
Essentially, equivalent wording as ANS 1976 version, section 5.3.4.1  
3.5.2.6 Limitations and Actions Limitations on the parameters being controlled and appropriate      See section 5.3.2 of corrective measures to return the parameter to the normal control  3.5.1 on the ANS 3.2 band are specified.                                                 sheet 3.5.2.7 Main Body The main body of the procedure contains the step-by-step            See section 5.3.2 of instructions in the degree of detail necessary for performing the  3.5.1 on the ANS 3.2 required function or task.                                         sheet 3.5.2.8 Acceptance Criteria The acceptance criteria provide the quantitative or qualitative    See section 5.3.2 of criteria against which the success or failure of the step or action 3.5.1 on the ANS 3.2 (such as for a test type activity) would be judged.                sheet 3.5.2.9 Checklists See section 5.3.2 of 3.5.1 on the ANS 3.2 Complex procedures should utilize checklists which may be 32


Start-up procedures shall be provided that include starting the reactor from cold or hot conditions and establishing power operation, with the generator synchronized to the line. Recovery from reactor trips shall be in accordance with the start-up procedure and shall be subject to the determinations set fo rth in 5.2.1.1. Start-up procedures shall be provided that include starting the reactor from cold or hot conditions and establishing power operation, with the generator synchronized to the line. Recovery from reactor trips shall be in accordance with the start-up procedure and shall be subject to the determinations set fo rth in 5.2.1.1. 3.5.3.9 Shutdown Procedures 5.3.4.2 Shutdown Procedures5.3.4.2 Shutdown ProceduresThese documents contain guidance for operations during controlled shutdown and following reactor trips, including instructions for establishing or maintaining hot shutdown/standby or cold shutdown conditions, as applicable. The major steps involved in shutting down the plant are specified, including instructions for such actions as monitoring and controlling reactivity, load reduction and cool down rates, sequence for activating or deactivating equipment, requirements for prompt analysis for causes of reactor trips or abnormal conditions requiring unplanned controlled shutdowns, and provisions for decay heat removal. Essentially equivalent wording as ANS 1976 version, section 5.3.4.2.
ANS 3.2 Side-By Side Comparison 7/25/2012 included as part of the procedure or appended to it.                    sheet 3.5.3 Plant Procedures Plant procedures provide instructions for controlling plant activities. Essentially, equivalent Typical examples of these types of plant procedures and their          to ANS 3.2 1976, characteristics are as follows.                                         section 5.3.4.
Shutdown procedures shall be provided to guide operations during and following controlled shutdown or reactor trips and shall include instructions for establishing or maintaining hot standby or cold shutdown conditions as applicable. The major steps involved in shutting down the plant shall be specified, including detailed instructions for the performance of such actions as monitoring and controlling reactivity load reduction and cool down rates, sequence of activating or deactivating equipment, requirements for prompt analyses of causes of reactor trips or abnormal conditions requiring unplanned controlled shutdowns, and provisions for decay heat removal. Check off list should be used for confirming completion of major steps in proper sequence. Shutdown procedures shall be provided to guide operations during and following controlled shutdown or reactor trips and  shall include instructions for establishing or maintaining hot standby or cold shutdown conditions, AS applicable. The major steps involved in shutting down the plant shall be specified, including detailed instructions for the performance of such actions as monitoring and controlling reactivity, load reduction, and cool down rates, sequence of activating or deactivating equipment, requirements for prompt analyses of causes or reactor trips or abnormal conditions requiring unplanned controlled shutdowns, and provisions for decay heat removal. Check off lists shall be used for the purpose of confirming completion of major steps in proper sequence. 3.5.3.10 Power Operation and Load Changing Procedures5.3.4.3 Power Operation and Load Changing Procedure. 5.3.4.3 Power Operation and Load Change* These documents contain instructions for steady-state power Essentially equivalent Procedures for steady- state power Procedures for steady-state power 
3.5.3.1 Administrative Control Procedures These include administrative procedures, directives, policies,         Replacement for 5.1,     5.3.3 System Procedures.
standards, and similar documents that control the programmatic          ANS 3.2 1976, more      Instructions for energizing filling venting.
aspects of facility activities. These administrative documents          general. No problems    Draining, starting up. shutting down, ensure that the requirements of regulatory and license                                          changing modes of operation and other identified. Ok.
commitments are implemented. Several levels of administrative                                    instructions appropriate for operations of controls are applied ranging from those affecting the entire owner                              systems related to the safety of the plant Section 5.2 Rules of organization to those prepared at the implementing group level.                                 shall be delineated in system procedures.
These documents establish responsibilities, interfaces, and             Practice, replaced by  Procedures for correcting off-normal standard methods (rules of practice) for implementing programs          part 26 requirements. conditions shall be developed for those So ok to remove.        events where system complexity may lead to operator uncertainty. System Section 5.2.1 is        procedures shall contain check off lists elaborated in other      where appropriate.
parts of the new ANS 3.2.
Different levels of detail than ANS 3.2 1976 version. Section 5.3.3.
3.5.3.2 Operating Orders/Procedures                                                              5.2.3 Operating Order                        5.2.3 Operating Orders Instructions of general and continuing applicability to the conduct of Similar to 1982          A mechanism shall be provided for           A mechanism shall be provided for business to the plant staff are provided. Examples where these                                  dissemination to the plant staff of          dissemination to the plant staff of 33


ANS 3.2 Side-By Side Comparison           7/25/2012 37 operation and load changing. These type documents include, as examples, provisions for use of control rods, chemical shim, coolant flow control, or any other system available for short-term or long-term control of reactivity, making deliberate load changes, responding to unanticipated load changes, and adjusting operating parameters.
ANS 3.2 Side-By Side Comparison 7/25/2012 are applied include, but are not limited to, job turnover and relief, version, Section 5.2.3. instructions of general and continuing      instructions of general and continuing designation of confines of control room, definition of duties of                              applicability to .the conduct of business. applicability to the conduct of business.
  . wording as ANS 1976 version, section 5.3.4.3.
operators and others, transmittal of operating data to management,                             Such instruction... ~, sometimes also        Such instructions. sometimes also referred filing of charts, limitations on access to certain areas and                                   referred to as standing orders or standard  to as administrative procedures, standing equipment, shipping and receiving instructions. Provisions are                                operating procedures should deal with job    orders or standard operating procedures, made for periodic review and updating of these documents, where                                turnover and relief, designation of confines should deal with job turnover and relief.
operation and load changing shall be provided that include, for example, provisions for use of control rods, chemical shim, coolant flow control or any other system available for long or short-term control of reactivity, making deliberate load changes, responding to unanticipated load changes and adjusting operating parameters. operation and load changing shall be provided that include, for example, provisions for use of control rods, chemical shim, coolant flow control or any other system available for long or short-term control of reactivity, making procedures, deliberate load changes, responding to unanticipated load changes and adjusting operating parameters 3.5.3.11 Process Monitoring Procedures 5.3.4.4 Process MonitoringProcedures5.3.4.4 ProcessMonitoringProcedures These documents contain instructions for monitoring performance of plant systems to assure that core thermal margins and coolant quality are maintained in acceptable status at all times, that integrity of fission product barriers is maintained, and that engineered safety features and emergency equipment are in a state of readiness to maintain the plant in a safe condition if needed. Maximum and minimum limits for process parameters are appropriately identified. Operating procedures address the appropriate nature and frequency of this monitoring.
appropriate.                                                                                  of control room, definition of duties of    designation of confines of control room, operators and others, transmittal) of        definition of duties of operators and others, operating data to management, filing of      transmittal of operating data to charts, limitations on access to certain    management, filing of charts, limitations on areas and equipment, shipping and            access to certain areas and equipment, receiving instructions, or other such        shipping and receiving instructions. or matters. Provisions should be made for       other such matters. Provisions shall be periodic review and updating of standing    made for periodic review and updating of orders.                                      operating orders.
Essentially equivalent wording as ANS 1976 version, section 5.3.4.4.
3.5.3.3 Special Orders                                                                        5.2.4 Special Order                          5.2.4 Special Orders Management instructions, which have short-term applicability and      Essentially, equivalent  A mechanism shall be provided for           A mechanism shall be provided for issuing require dissemination, are issued to encompass special                wording as ANS 3.2,      issuing management instructions which        management instructions which have operations, housekeeping, data taking, publications and their        1976 version, section    have short-term applicability and which      short-term applicability and which require distribution, plotting process parameters, personnel actions, or                              require dissemination. Such instructions    dissemination. Such instructions, 5.2.4 other similar matters. Provisions are made for periodic review,                                sometimes referred to as special orders,    sometimes referred to as special orders, updating, and cancellation of these documents, where appropriate.                             should encompass special operational,        should encompass special operations, housekeeping, data taking, publication and  housekeeping, data taking, publications their distribution, plotting process        and their distribution, plotting process parameters, personnel actions or other      parameters, personnel actions or other familiar material Provisions should be       similar matters. Provisions shall be made made for periodic review, updating and       for periodic review, updating and cancellation of special orders.             cancellation of special orders.
Procedures for monitoring performance of plant systems shall be required to assure that core thermal margins and coolant quality are maintained at all times, that intergraded of fission product barriers is maintained at all times and that engineered safety features and emergency equipment are in a state of readiness to maintain the plant in a safe condition ( needed.. The limit (maximum and minimum) (or significant process parameters shall be identified. 'The nature and frequency of this monitoring shall be covered by operating procedures. as appropriate. Procedures for monitoring performance of plant systems shall be required to assure that core thermal margins and coolant quality are maintained at all times. that integrity of fission product barriers is maintained at all times and that engineered safety features and emergency equipment are in a state of readiness to ma intain the plant in a safe condition if needed. The limits ( maximum and minimum for significant process parameters shall be identified. The nature and frequency of this monitoring shall be covered by operating procedures, as appropriate. 3.5.3.12 Fuel Handling Procedures 5.3.4.6 Fuel-Handling Procedures5.3.4.5 Fuel-Handling Procedures These documents contain instructions for core alterations, accountability of fuel and partial or complete refueling operations that include, for example, continuous monitoring of neutron flux throughout core loading, periodic data recording, audible annunciation of abnormal flux increases, and evaluation of core neutron multiplication to verify safety of loading increments. Procedures are also provided for receipt and inspection of new fuel, and for fuel movements in the spent fuel storage areas. Fuel handling procedures include prerequisites to verify the status of systems required for fuel handling and movement; inspection of replacement fuel and control rods; designation of proper tools, Essentially equivalent wording as ANS 1976 version, section
3.5.3.4 Temporary Procedures                                                                   5.2.5 Temporary Procedures                  5.2.5 Temporary Procedures Temporary procedures may be used to direct operations during          Essentially, equivalent Temporary procedures may be issued          Temporary procedures may be issued testing, refueling, maintenance, and modifications to provide        wording as ANS 3.2,     during the operational phase: to direct      during the operational phase: to direct guidance in unusual situations not within the scope of the normal    1976 version, section    operations during testing, refueling,       operations during testing, refueling, procedures. These procedures ensure orderly and uniform                                                                                    maintenance and modifications; to provide 5.2.5                    maintenance and modifications; to provide operations for short periods when the plant, a system, or a                                                                                guidance in unusual situations not within component of a system is performing in a manner not addressed                                  guidance in unusual situations not within    the scope of the normal procedures; and to by existing detailed procedures or has been modified or extended                              the scope of the normal procedures; and      ensure orderly and uniform operations for in such a manner that portions of existing procedures do not apply.                            to ensure orderly and uniform operations    short periods when the plant, a system, or Temporary procedures include designation of the period of time                                for short periods when the plant, a system,  a component of a system is performing in during which they may be used and are subject to the procedure                                or a component of a system is performing    a manner not covered by existing detailed review process as applicable.                                                                  in a manner not covered by existing          procedures or has been modified or extended in such a manner that portions of detailed procedures or has been modified existing procedures do not apply.
or extended in such a manner that            Temporary procedures shall include 34


5.3.4.5.
ANS 3.2 Side-By Side Comparison 7/25/2012 portions of existing procedures do not      designation of the period of time during apply. Temporary procedures shall          which they may be used and shall be include designation of the period of time  subject to the review process prescribed in 4.3 and 5.2.15 as applicable. Temporary during which they may be used and shall procedures shall be approved by the be subject to the review process            management representative assigned prescribed in 4.3 and 5.2.15 as applicable. approval authority.
Fuel handling operations shall be performed in accordance with written procedures. These procedures shall specify actions for .core alterations, accountability of fuel and partial or complete refueling operations that include, (or example, continuous monitoring of the neutron flux throughout core loading, periodic recording of data, audible annunciation of abnormal flux increases and evaluation of core neutron .Fuel handling operations shall be performed in accordance with written procedures. These procedure shall specify instructions for use of refueling equipment, actions for core alterations, accountability of fuel and partial or complete refueling operations that include, for example, continuous monitoring of the neutron flux: throughout 
3.5.3.5 Engineering Procedures These documents provide instructions for the preparation of          New section in line engineering documents, engineering analysis, and implementation      with NQA-1 of engineering programs. This includes activities such as designs;    requirements. Ok.
calculations; fabrication, equipment, construction, and installation specifications; drawings; analysis and topical reports; and testing plans or procedures. They include appropriate references to industry codes and standards, design inputs, and technical requirements. Additional criteria for these procedures are contained in ASME NQA-1-2008 and the NQA-1a-2009 addenda
[2].
3.5.3.6 Installation Procedures These documents provide instructions for the installation of         New section in line components generally related to new construction and certain          with NQA-1 modification activities. They include appropriate reference to        requirements.
industry standards, installation specifications, design drawings, and Installation in operating supplier and technical manuals for the performance of activities.
These documents include provisions, such as hold or witness          plants equivalent to points, for conducting and recording results of required inspections  design and or tests. These documents may include applicable inspection and       construction phase.
test instructions subject to the requirements for test and inspection procedures below.
3.5.3.7 System Procedures These documents contain instructions for energizing, filling,        § venting, draining, starting up, shutting down, changing modes of operation, and other instructions appropriate for operations of      New section similar to systems related to the safety of the plant. Actions to correct off-  1982 version Sections normal conditions are invoked following an operator observation or 35


ANS 3.2 Side-By Side Comparison           7/25/2012 38 proper conditions for spent fuel movement, proper conditions for fuel cask loading and movement; and status of interlocks, reactor trip circuits and mode switches. These procedures provide requirements for refueling, including proper sequence, orientation and seating of fuel and components, rules for minimum operable instrumentation, actions for response to fuel damage, verification of shutdown margin, communications between the control room and the fuel handling station, independent verification of fuel and component locations, criteria for stopping fuel movements, and documentation of final fuel and component serial numbers (or other unique identifiers) and locations.
ANS 3.2 Side-By Side Comparison 7/25/2012 an annunciator alarm indicating a condition which, if not corrected,  3.2 & 3.5.5.2.
multiplication to verify the safety of loading increments. Provisions shall be made for preparing specific procedures for each refueling outage and for receipt and shipment of fuel. Plant procedures should, nonetheless, prescribe the general preplanning for the fuel-handling program and its associated safety measures and should identify those aspects of the program for which procedures are to be prepared for each refueling outage (1) Prerequisites. Prerequisites  shall be provided in the fuel-handling procedures that include, for example, the status of plant systems required for refueling; inspection of replacement fuel, control rods poison curtains and internals; designation of proper tools; proper conditions for spent fuel movement; proper conditions for fuel cask loading and movement; and status of interlocks reactor trip circuits and mode. (2) Main Body. The main body of fuel hand line procedures shall include requirements for refueling; for sample, the status of the core, instructions (or proper sequence, orientation. and seating of fuel and components, rules for minimum operable instrumentation, actions to be followed in the event of fuel damage, rules for periods when refueling is interrupted, verification of the shutdown margin and the frequency of determination, communications between control room and the fuel loading station. independent verification of fuel and component location, criteria (or stopping refueling and (or reducing the size of the fuel loading increment, and a containment evacuation plan and its associated  safe measures. Documentation of final fuel and component serial numbers and locations shall be maintained core loading, periodic recording of data, audible annunciation of abnormal flux increase and evaluation of core neutron multiplication to verify the safety of loading increments. Provisions shall be made for preparing specific procedures for each refueling outage and for receipt and shipment of fuel Plant procedures shall prescribe the general preplanning for the fuel handling program and its associated safety measures and should identify those aspects of the program for which procedures are to be prepared for each refueling outage (1) Prerequisites. Prerequisites shall be provided in the fuel-handling procedures that include. for example, the status of plant systems required for refueling; inspection of replacement fuel control rod!:, poison curtains and internals; designation of proper tools; proper conditions for spent fuel movement.; proper conditions for fuel cask loading and movement; and status of interlocks, reactor trip circuits and mode switches. (2)  Main Body. The main body of fuel handling procedures shall include requirements for refueling; for example, the status of the core instructions for proper :sequence, orientation, and seating of fuel and components, rules for minimum operable instrumentation, actions to be followed in the event of fuel damage, administrative control of shift changes rules for periods when refueling is interrupted. Verification of the shutdown margin and the frequency of determination communications between control room and the fuel loading station. Independent verification of fuel and 
could degenerate into a condition requiring action under an emergency procedure. Separate procedures may be developed for correcting off-normal conditions for those events where system complexity may lead to operator uncertainty 3.5.3.8 Start-up Procedures                                                                    5.3.4.1 Start-up Procedures                  5.3.4.1 Start-up Procedures These documents contain instructions for starting the reactor from    Essentially, equivalent  Start-up procedures shall be provided that  Start-up procedures shall be provided that cold or hot conditions and establishing power operation. This        wording as ANS 1976      include starting the reactor from cold or    include starting the reactor from cold or hot includes documented determination that prerequisites have been        version, section 5.3.4.1 hot conditions and establishing power        conditions and establishing power satisfied, including confirmation that necessary instruments are                              operation, with the generator synchronized  operation, with the generator synchronized operable and properly set, valves are properly aligned, necessary                              to the line. Recovery from reactor trips    to the line. Recovery from reactor trips system procedures, tests and calibrations have been completed,                                 shall be in accordance with the start-up    shall be in accordance with the start-up and required approvals have been obtained.                                                    procedure and shall be subject to the       procedure and shall be subject to the determinations set forth in 5.2.1.1.        determinations set forth in 5.2.1.1.
3.5.3.9 Shutdown Procedures                                                                    5.3.4.2 Shutdown Procedures                  5.3.4.2 Shutdown Procedures These documents contain guidance for operations during                Essentially equivalent  Shutdown procedures shall be provided to    Shutdown procedures shall be provided to controlled shutdown and following reactor trips, including            wording as ANS 1976      guide operations during and following        guide operations during and following instructions for establishing or maintaining hot shutdown/standby    version, section        controlled shutdown or reactor trips and     controlled shutdown or reactor trips and or cold shutdown conditions, as applicable. The major steps                                    shall include instructions for establishing  shall include instructions for establishing or 5.3.4.2.
involved in shutting down the plant are specified, including                                  or maintaining hot standby or cold          maintaining hot standby or cold shutdown instructions for such actions as monitoring and controlling                                    shutdown conditions as applicable. The      conditions, AS applicable. The major steps reactivity, load reduction and cool down rates, sequence for                                   major steps involved in shutting down the    involved in shutting down the plant shall be activating or deactivating equipment, requirements for prompt                                  plant shall be specified, including detailed specified, including detailed instructions for analysis for causes of reactor trips or abnormal conditions requiring                          instructions for the performance of such    the performance of such actions as unplanned controlled shutdowns, and provisions for decay heat                                  actions as monitoring and controlling        monitoring and controlling reactivity, load removal.                                                                                       reactivity load reduction and cool down      reduction, and cool down rates, sequence rates, sequence of activating or            of activating or deactivating equipment, deactivating equipment, requirements for     requirements for prompt analyses of prompt analyses of causes of reactor trips  causes or reactor trips or abnormal or abnormal conditions requiring            conditions requiring unplanned controlled unplanned controlled shutdowns, and         shutdowns, and provisions for decay heat provisions for decay heat removal. Check    removal. Check off lists shall be used for off list should be used for confirming      the purpose of confirming completion of completion of major steps in proper         major steps in proper sequence.
sequence.
3.5.3.10 Power Operation and Load Changing Procedures                                          5.3.4.3 Power Operation and Load            5.3.4.3 Power Operation and Load Changing Procedure.                         Change*
These documents contain instructions for steady-state power          Essentially equivalent  Procedures for steady- state power          Procedures for steady-state power 36


ANS 3.2 Side-By Side Comparison           7/25/2012 39 component location, criteria for stopping refueling and for reducing the size of the fuel loading  increment and a containment evacuation plan and its associated safety measures. Documentation of final fuel and component serial numbers and locations shall be maintained. 3.5.3.13 Maintenance Procedures These documents contain instructio ns in sufficient detail to permit maintenance work to be performed correctly and safely, and include provisions, such as hold or witness points, for conducting and recording results of required inspections or tests. These documents may include applicable inspection or test instructions subject to the requirements for test and inspection procedures below. Appropriate referencing to other procedures, standards, specifications, or supplier manuals is provided. When not provided through other documents, instructions for equipment removal and return to service, and applicable radiation protection measures (such as protective clothing and radiation monitoring) will be included. Additional maintenance procedure requirements are addressed in ASME NQA-1-2008 and the NQA-1a-2009 addenda, Subpart 2.18 [2].
ANS 3.2 Side-By Side Comparison 7/25/2012 operation and load changing. These type documents include, as        wording as ANS 1976      operation and load changing shall be          operation and load changing shall be examples, provisions for use of control rods, chemical shim,          version, section        provided that include, for example,          provided that include, for example, coolant flow control, or any other system available for short-term or 5.3.4.3.                provisions for use of control rods, chemical provisions for use of control rods, chemical long-term control of reactivity, making deliberate load changes,                              shim, coolant flow control or any other shim, coolant flow control or any other responding to unanticipated load changes, and adjusting operating                              system available for long or short-term parameters.                                                                                   control of reactivity, making deliberate load system available for long or short-term changes, responding to unanticipated load    control of reactivity, making procedures, changes and adjusting operating              deliberate load changes, responding to parameters.                                  unanticipated load changes and adjusting
Essentially equivalent wording as ANS 1976 version, section 5.3.5.  
.                                                                                                                                            operating parameters 3.5.3.11 Process Monitoring Procedures                                                        5.3.4.4 Process Monitoring Procedures          5.3.4.4 Process Monitoring Procedures These documents contain instructions for monitoring performance      Essentially equivalent  Procedures for monitoring performance of      Procedures for monitoring performance of of plant systems to assure that core thermal margins and coolant      wording as ANS 1976      plant systems shall be required to assure      plant systems shall be required to assure quality are maintained in acceptable status at all times, that        version, section        that core thermal margins and coolant          that core thermal margins and coolant integrity of fission product barriers is maintained, and that                                  quality are maintained at all times, that 5.3.4.4.                                                                quality are maintained at all times. that engineered safety features and emergency equipment are in a                                    intergraded of fission product barriers is state of readiness to maintain the plant in a safe condition if                                maintained at all times and that engineered    integrity of fission product barriers is needed. Maximum and minimum limits for process parameters are                                  safety features and emergency equipment       maintained at all times and that appropriately identified. Operating procedures address the                                    are in a state of readiness to maintain the    engineered safety features and appropriate nature and frequency of this monitoring.                                           plant in a safe condition ( needed.. The      emergency equipment are in a state of limit (maximum and minimum) (or                readiness to maintain the plant in a safe significant process parameters shall be        condition if needed. The limits ( maximum identified. 'The nature and frequency of this and minimum for significant process monitoring shall be covered by operating procedures. as appropriate.                    parameters shall be identified. The nature and frequency of this monitoring shall be covered by operating procedures, as appropriate.
3.5.3.12 Fuel Handling Procedures                                                              5.3.4.6 Fuel-Handling Procedures              5.3.4.5 Fuel- Handling Procedures These documents contain instructions for core alterations,           Essentially equivalent   Fuel handling operations shall be              .Fuel handling operations shall be accountability of fuel and partial or complete refueling operations  wording as ANS 1976     performed in accordance with written          performed in accordance with written that include, for example, continuous monitoring of neutron flux      version, section         procedures. These procedures shall            procedures. These procedure shall throughout core loading, periodic data recording, audible                                      specify actions for .core alterations, 5.3.4.5.                                                               specify instructions for use of refueling annunciation of abnormal flux increases, and evaluation of core                                accountability of fuel and partial or neutron multiplication to verify safety of loading increments.                                complete refueling operations that include,    equipment, actions for core alterations, Procedures are also provided for receipt and inspection of new                                (or example, continuous monitoring of the      accountability of fuel and partial or fuel, and for fuel movements in the spent fuel storage areas. Fuel                            neutron flux throughout core loading,          complete refueling operations that handling procedures include prerequisites to verify the status of                              periodic recording of data, audible            include, for example, continuous systems required for fuel handling and movement; inspection of                                annunciation of abnormal flux increases        monitoring of the neutron flux: throughout replacement fuel and control rods; designation of proper tools,                                and evaluation of core neutron 37


NRC did not endorse 2.18 of NQA-1 in RG 1.33  . 3.5.3.14 Radiation Control Procedures These documents contain instructions for implementation of the radiation control program requirements necessary to maintain compliance with regulatory commitments, including acquisition of data and use of equipment to perform necessary radiation surveys, measurements and evaluations for the assessment and control of radiation hazards. These procedures provide requirements for monitoring both external and internal exposures of employees, utilizing accepted techniques; routine radiation surveys of work areas; effluent and environmental monitoring in the vicinity of the plant; radiation monitoring of maintenance and special work activities, and for maintaining records demonstrating the adequacy of measures taken to control radiation exposures to employees Essentially, equivalent wording as ANS 1976 version, section 5.3.6.  
ANS 3.2 Side-By Side Comparison 7/25/2012 proper conditions for spent fuel movement, proper conditions for                    multiplication to verify the safety of loading core loading, periodic recording of data, fuel cask loading and movement; and status of interlocks, reactor                    increments. Provisions shall be made for      audible annunciation of abnormal flux trip circuits and mode switches. These procedures provide                            preparing specific procedures for each        increase and evaluation of core neutron requirements for refueling, including proper sequence, orientation                  refueling outage and for receipt and multiplication to verify the safety of loading and seating of fuel and components, rules for minimum operable                      shipment of fuel. Plant procedures should, instrumentation, actions for response to fuel damage, verification of                nonetheless, prescribe the general            increments. Provisions shall be made for shutdown margin, communications between the control room and                        preplanning for the fuel-handling program     preparing specific procedures for each the fuel handling station, independent verification of fuel and                      and its associated safety measures and        refueling outage and for receipt and component locations, criteria for stopping fuel movements, and                       should identify those aspects of the          shipment of fuel Plant procedures shall documentation of final fuel and component serial numbers (or other                  program for which procedures are to be        prescribe the general preplanning for the unique identifiers) and locations.                                                  prepared for each refueling outage (1)        fuel handling program and its associated Prerequisites. Prerequisites shall be safety measures and should identify those provided in the fuel-handling procedures that include, for example, the status of      aspects of the program for which plant systems required for refueling;          procedures are to be prepared for each inspection of replacement fuel, control rods  refueling outage (1) Prerequisites.
poison curtains and internals; designation    Prerequisites shall be provided in the fuel-of proper tools; proper conditions for spent  handling procedures that include. for fuel movement; proper conditions for fuel      example, the status of plant systems cask loading and movement; and status of required for refueling; inspection of interlocks reactor trip circuits and mode. (2)
Main Body. The main body of fuel hand line    replacement fuel control rod!:, poison procedures shall include requirements for     curtains and internals; designation of refueling; for sample, the status of the core, proper tools; proper conditions for spent instructions (or proper sequence,              fuel movement.; proper conditions for fuel orientation. and seating of fuel and          cask loading and movement; and status of components, rules for minimum operable interlocks, reactor trip circuits and mode instrumentation, actions to be followed in the event of fuel damage, rules for periods    switches. (2) Main Body. The main body when refueling is interrupted, verification of of fuel handling procedures shall include the shutdown margin and the frequency of      requirements for refueling; for example, determination, communications between          the status of the core instructions for control room and the fuel loading station. proper :sequence, orientation, and seating independent verification of fuel and          of fuel and components, rules for component location, criteria (or stopping minimum operable instrumentation, refueling and (or reducing the size of the fuel loading increment, and a containment      actions to be followed in the event of fuel evacuation plan and its associated safe        damage, administrative control of shift measures. Documentation of final fuel and      changes rules for periods when refueling component serial numbers and locations        is interrupted. Verification of the shutdown shall be maintained                            margin and the frequency of determination communications between control room and the fuel loading station.
Independent verification of fuel and 38


Ok    
ANS 3.2 Side-By Side Comparison 7/25/2012 component location, criteria for stopping refueling and for reducing the size of the fuel loading increment and a containment evacuation plan and its associated safety measures.
Documentation of final fuel and component serial numbers and locations shall be maintained.
3.5.3.13 Maintenance Procedures These documents contain instructions in sufficient detail to permit maintenance work to be performed correctly and safely, and                                  .
include provisions, such as hold or witness points, for conducting  Essentially equivalent and recording results of required inspections or tests. These      wording as ANS 1976 documents may include applicable inspection or test instructions    version, section 5.3.5.
subject to the requirements for test and inspection procedures below. Appropriate referencing to other procedures, standards, specifications, or supplier manuals is provided. When not provided through other documents, instructions for equipment removal and return to service, and applicable radiation protection measures    NRC did not endorse (such as protective clothing and radiation monitoring) will be      2.18 of NQA-1 in RG included. Additional maintenance procedure requirements are        1.33 addressed in ASME NQA-1-2008 and the NQA-1a-2009 addenda, Subpart 2.18 [2].
3.5.3.14 Radiation Control Procedures These documents contain instructions for implementation of the      Essentially, equivalent radiation control program requirements necessary to maintain        wording as ANS 1976 compliance with regulatory commitments, including acquisition of    version, section 5.3.6.
data and use of equipment to perform necessary radiation surveys, Ok measurements and evaluations for the assessment and control of radiation hazards. These procedures provide requirements for monitoring both external and internal exposures of employees, utilizing accepted techniques; routine radiation surveys of work areas; effluent and environmental monitoring in the vicinity of the plant; radiation monitoring of maintenance and special work activities, and for maintaining records demonstrating the adequacy of measures taken to control radiation exposures to employees 39


ANS 3.2 Side-By Side Comparison           7/25/2012 40 and others.
ANS 3.2 Side-By Side Comparison 7/25/2012 and others.
3.5.3.15 Calibration and Test Procedures These documents contain instructions for periodic calibration and testing of instrumentation and control systems, and for periodic calibration of measuring and test equipment used in activities affecting the quality of these systems. These documents provide for meeting surveillance requirements and for assuring measurement accuracy adequate to keep safety-related parameters within operational and safety limits. Additional requirements for these procedures are contained in ASME NQA-1-2008 and the NQA-1a-2009 addenda [2].
3.5.3.15 Calibration and Test Procedures These documents contain instructions for periodic calibration and     Essentially, equivalent testing of instrumentation and control systems, and for periodic       wording as ANS 1976 calibration of measuring and test equipment used in activities         version, Section 5.3.7.
Essentially, equivalent wording as ANS 1976 version, Section 5.3.7. Ok. 3.5.3.16 Chemical and Radiochemical Control ProceduresThese documents contain instructions for chemical and radiochemical control activities and include: the nature and frequency of sampling and analyses; instructions for maintaining coolant quality within prescribed limits; and limitations on concentrations of agents that could cause corrosive attack, foul heat transfer surfaces, or become sources of radiation hazards due to activation. These documents also provide for the control, treatment, and management of radioactive wastes, and control of radioactive calibration sources.
affecting the quality of these systems. These documents provide Ok.
Essentially equivalent wording as ANS 1976 version, section 5.3.8. Ok. 3.5.3.17 Emergency Operating Procedures 5.3.9 Emergency Procedures5,3.9 Emergency ProceduresThese documents contain instructions for response to potential emergencies so that a trained operator will know in advance the expected course of events that will identify an emergency and the immediate actions that should be taken in response. Format and content of emergency procedures are based on regulatory and Owner's Group(s) guidance for the plant type that identify potential emergency conditions and generally require such procedures to include, as appropriate, a title, symptoms to aid in identification of the nature of the emergency, automatic actions to be expected from protective systems, immediate operator actions for operation Revised  section.
for meeting surveillance requirements and for assuring measurement accuracy adequate to keep safety-related parameters within operational and safety limits. Additional requirements for these procedures are contained in ASME NQA 2008 and the NQA-1a-2009 addenda [2].
3.5.3.16 Chemical and Radiochemical Control Procedures These documents contain instructions for chemical and                 Essentially equivalent radiochemical control activities and include: the nature and           wording as ANS 1976 frequency of sampling and analyses; instructions for maintaining       version, section 5.3.8.
coolant quality within prescribed limits; and limitations on Ok.
concentrations of agents that could cause corrosive attack, foul heat transfer surfaces, or become sources of radiation hazards due to activation. These documents also provide for the control, treatment, and management of radioactive wastes, and control of radioactive calibration sources.
3.5.3.17 Emergency Operating Procedures                                                         5.3.9 Emergency Procedures                5,3.9 Emergency Procedures These documents contain instructions for response to potential         Revised section.        Procedures shall be provided to guide      Procedures shall be provided to guide emergencies so that a trained operator will know in advance the                                 operations during potential emergencies,  operations during potential emergencies.
expected course of events that will identify an emergency and the                               They shall be written so that a trained    They shall be written so that a trained immediate actions that should be taken in response. Format and                                 operator will know in advance the expected operator will know the action he should content of emergency procedures are based on regulatory and                                     course of events that will identify an Owners Group(s) guidance for the plant type that identify potential                           emergency and the immediate action he      take. Since emergencies may not follow emergency conditions and generally require such procedures to                                   should take. Since emergencies may not    anticipated patterns. the procedures include, as appropriate, a title, symptoms to aid in identification of                         follow anticipated patterns the procedures should provide sufficient flexibility to the nature of the emergency, automatic actions to be expected                                   should provide sufficient flexibility to  accommodate variations. These from protective systems, immediate operator actions for operation                               accommodate variations. Emergency          procedures may be based upon plant 40


Procedures shall be provided to guide operations during potential emergencies, They shall be written so that a trained operator will know in advance the expected course of events that will identify an emergency and the immediate action he should take. Since emergencies may not follow anticipated patterns the procedures should provide sufficient flexibility to accommodate variations. Emergency Procedures shall be provided to guide operations during potential emergencies. They shall be written so that a trained operator will know the action he should take. Since emergencies may not follow anticipated patterns. the procedures should provide sufficient  flexibility to accommodate variations. These procedures may be based upon plant 
ANS 3.2 Side-By Side Comparison 7/25/2012 of controls or confirmation of automatic actions, and subsequent                procedures that cover actions for            symptoms or plant event or both operator actions to return the reactor to a normal condition or                manipulations of controls to prevent          Symptomatic procedures specify operator provide for a safe extended shutdown period under abnormal or                  accidents or lessen their consequences        actions based on the determination of the emergency conditions.                                                          should be based on a general sequence of plant status. Event procedures specify observations and actions. Emphasis should be placed on operator responses to            operator actions based on the observational and indications in the control  determination of the event. The content room that is, when immediate operator        and format of symptomatic procedures are actions are required to prevent or mitigate  not covered in this standard. An the consequences of a serious condition,      acceptable format and content for event procedures should require that those          procedures is given in 5.3.9.1. Emergency actions be implemented promptly. The procedures that cover actions for emergency procedure format given in 5.3.9.1 provides a basis for coping with      manipulations of control to prevent emergencies and is an acceptable format      accidents or lessen their consequences for prescribing operator observations and    should be based on a general sequence of actions. Emergency procedures may            observations and actions. Emphasis shall contain supplemental background              be placed on operator responses to information to further aid operators in      observations and indications in the control taking proper emergency action&, but this room; that is, when operator actions are information shall be separated from the procedural actions. It is extremely difficult required to prevent or mitigate the to distinguish between procedures            consequences of a serious condition.
prepared (or the purpose of connecting off*  procedures shall require that those actions normal conditions which in themselves do      be implemented in a timely fashion.
not compatible actual emergency              Emergency procedures may contain situations, but which conceivably can supplemental background information to degenerate into true emergencies in the absence of positive corrective action. and    aid operators further in taking proper procedures required for coping with true      emergency actions, but this information emergencies that have already occurred        shall be separated from the procedural Some owner organizations choose the term      actions. When initially available "Off normal procedure" for the same          intelligence provided to operating purpose that others choose "Emergency        personnel via instrument readings, Procedures." When initially available physical conditions, and personal intelligence provided to operating personnel via instrument readings, physical  observations may not indicate clearly the condition&, and personal observations may     difference between a simple operational not clearly indicate the difference between  problem and a serious emergency, the a simple operational problem and a serious    actions outlined in the emergency emergency, the actions outlined in the       procedures shall be based on a emergency procedures shall be based on a      conservative course of action by the conservative course of action by the operating crew. Departure from the operating crew. Considerable judgment on the part of competent personnel is required  emergency procedure shall require the 41


ANS 3.2 Side-By Side Comparison           7/25/2012 41 of controls or confirmation of automatic actions, and subsequent operator actions to return the reactor to a normal condition or provide for a safe extended shutdown period under abnormal or emergency conditions.
ANS 3.2 Side-By Side Comparison 7/25/2012 before departing room the emergency          prior approval of the off-duty shift procedure.                                    supervisor or, if the on-duty shift supervisor is unavailable, the licensed senior operator in the control room.
procedures that cover actions for manipulations of controls to prevent accidents or lessen their consequences should be based on a general sequence of observations and actions. Emphasis should be placed on operator responses to observational and indications in the control room that is, when immediate operator actions are required to prevent or mitigate the consequences of a serious condition, procedures should require that those actions be implemented promptly. The emergency procedure format given in 5.3.9.1 provides a basis for coping with emergencies and is an acceptable format for prescribing operator observations and actions. Emergency procedures may contain supplemental background information to further aid operators in taking proper emergency action&, but this information shall be separated from the procedural actions. It is extremely difficult to distinguish between procedures prepared (or the purpose of connecting off* normal conditions which in themselves do not compatible actual emergency situations, but which conceivably can degenerate into true emergencies in the absence of positive corrective action. and procedures required for coping with true emergencies that have already occurred Some owner organizations choose the term "Off normal procedure" for the same purpose that others choose "Emergency Procedures." When initially available intelligence provided to operating personnel via instrument readings, physical condition&, and personal observations may not clearly indicate the difference between a simple operational problem and a serious emergency, the actions outlined in the emergency procedures shall be based on a conservative course of action by the operating crew. Considerable judgment on the part of competent personnel is required symptoms or plant event or both Symptomatic procedures specify operator actions based on the determination of the plant status. Event procedures specify operator actions based on the determination of the event. The content and format of symptomatic procedures are not covered in this standard. An acceptable format and content for event procedures is given in 5.3.9.1. Emergency procedures that cover actions for manipulations of control to prevent accidents or lessen their consequences should be based on a general sequence of observations and actions. Emphasis shall be placed on operator responses to observations and indications in the control room; that is, when operator actions are required to prevent or mitigate the consequences of a serious condition.
Signals that initiate engineered 3.5.3.18 Emergency Plan Implementing Procedures                                      5.3.9.3 Procedure for Implementing            5.3.9.3 Procedure for Implementing Emergency Plan                                Emergency Plan These documents contain instructions for activating the Emergency Revised section. Implementing procedures for emergency        Implementing procedures for emergency Response Organization and facilities, protective action levels,                       plan actions shall contain, as appropriate,  plan actions shall contain, as appropriate, organizing emergency response actions, establishing necessary                        the following elements:                      the following elements:
procedures shall require that those actions be implemented in a timely fashion. Emergency procedures may contain supplemental background information to aid operator's further in taking proper emergency actions, but this information shall be separated from the procedural actions. When initially available intelligence provided to operating personnel via instrument readings, physical conditions, and personal observations may not indicate clearly the difference between a simple operational problem and a serious emergency, the actions outlined in the emergency procedures shall be based on a conservative course of action by the operating crew. Departure from the emergency procedure shall require the 
communications with local, state and federal agencies, and for periodically testing the procedures, communications and alarm                        (1) Individual assignment of authorities and  (1) Assignment of authority and systems to assure they function properly. Format and content of responsibilities for performance of specific  responsibilities for performance of specific these procedures are such that requirements of each facilitys nuclear regulator approved Emergency Plan are satisfied.                             tasks to specific individuals or staff        tasks to operating staff positions. (21 positions. (2) Protective action level and   Protective action levels and protective protective measurers outlined for the         measures outlined for the emergency emergency identified. (3) Specific actions to identified. (31 Specific actions to be taken be taken by coordinating support group.(4)    by coordinating support groups. (4)
Procedures for medical treatment and          Procedures for medical treatment and handling of contaminated individuals.(5)      handling of contaminated individuals (5)
Special equipment requirements (or items      Special equipment requirements for items such as medical treatment. emergency          such as medical treatment, emergency personnel removal, specific radiation        personnel removal, specific radiation detection. personnel doeimetry and rescue    detection personnel dosimetry and rescue operations. procedures for making this        operations procedures for making this equipment available, plus operating          equipment available plus operating instructions for such equipment, and          instructions for such equipment, and provisions for its periodic inspection and    provisions for its periodic inspection and maintenance. (6) Identification of           maintenance. (6) Identification of emergency communications network,            emergency communications network, including communications required for        including communications required for personnel identification and effective        personnel identification and effective coordination of all support groups. (7)      coordination of all support groups. (7)
Description of alarm signal in each facility. Description of alarm signal in each facility.
At sites with multiple units, alum signals    At sites with multiple units. Alarm signals should be consistent from one unit to         should be consistent from one unit to another. (Signals for initiating protective  another. (Signals for initiating protective 42


ANS 3.2 Side-By Side Comparison           7/25/2012 42 before departing room the emergency procedure. prior approval of the off-duty shift supervisor or, if the on-duty shift supervisor is unavailable, the licensed senior operator in the control room. Signals that initiate engineered 3.5.3.18  Emergency Plan Implementing Procedures5.3.9.3 Procedure for Implementing Emergency Plan 5.3.9.3 Procedure for Implementing Emergency Plan These documents contain instructions for activating the Emergency Response Organization and facilities, protective action levels, organizing emergency response actions, establishing necessary communications with local, state and federal agencies, and for periodically testing the procedures, communications and alarm systems to assure they function properly. Format and content of these procedures are such that requirements of each facility's nuclear regulator approved Emergency Plan are satisfied.
ANS 3.2 Side-By Side Comparison 7/25/2012 measures should be clear and distinct from      measures should be dear and distinct from process or operational alarm system to          process or operational alarm system to avoid confusion. (8) Produces required to        avoid confusion. (8) Procedures required restore the plant to normal conditions          to restore the plant to normal or safe following an emergency (9) Requirements          shutdown conditions following an for periodically testing of procedures          emergency. (9) Requirements for periodic communications network and alarm                testing of procedures communications systems to assure that they function            network and alarm systems to assure that properly.                                        they function properly.
Revised section.
See also U.S. Nuclear Regulatory                For additional guidance see the following Commission (NRC) "Guide to the                   American National Standards: Facilities Preparation of Emergency Plans (or               and Medical Care for Onsite Nuclear Production and Utilization facilities,"          Power Plant Radiological Emergencies.
ANSI/ANS 3.2.1-1979:
Emergency Control Centers for Nuclear Power Plants. ANSI/ANS 3.2 979: and Radiological Emergency Preparation Exercises for Nuclear Power Plants, ANSI ANS 3.2 1979.
3.5.3.19 Test and Inspection Procedures                                                        5.3.10 Test and Inspection Procedures            5.3.10 Test and Inspection Procedures These documents provide the necessary measures to assure              Essentially equivalent  Test and inspection procedures shall contain a Test and inspection procedures shall quality is achieved and maintained for the nuclear facilities. The    wording as ANS 1976      description of objectives; acceptance criteria t contain: a description of objectives; instructions for tests and inspections may be included within other  version, section 5.3.10. used to evaluate the results; prerequisites for acceptance criteria that will be used to procedures, such as installation and maintenance procedures, but performing the tests or inspections including a evaluate the results: prerequisites for will contain the objectives, acceptance criteria, prerequisites for performing the test or inspection, limiting conditions, and                                   conditions to be used. to simulate normal or a performing the tests or inspections appropriate instructions for performing the test or inspection, as                            operating conditions; limiting conditions; and t including any special conditions to be used applicable. These procedures also specify any special equipment                                inspection procedure. These procedures shall 1.0 simulate normal or abnormal operating or calibrations required to conduct the test or inspection and                                specify any special equipment or calibrations conditions: limiting conditions: and the test provide for appropriate documentation and evaluation by                                        to conduct the test or inspection. Test and ins or inspection procedure, including or responsible authority to assure test or inspection requirements                                results shall be documented and evaluated by referencing instruction, for restoration of have been satisfied. Where necessary, hold or witness points are responsible authority to assume that test and the system to the condition consistent with identified within the procedures and require appropriate approval for the work to continue beyond the designated point. These                                    requirements have been satisfied.               the normal plant operating status,. If procedures provide for recording the date, identification of those                                                                              applicable. These procedures shall also performing the test or inspection, as-found condition, corrective                              Where test and inspections are to be            specify any special equipment or actions performed (if any), and as-left condition, as appropriate for                          witnessed, the procedure shall identify hold    calibrations required to conduct the test or 43


Implementing procedures for emergency plan actions shall contain, as  appropriate, the following elements: (1) Individual assignment of authorities and responsibilities for performance of specific tasks to specific individuals or staff positions. (2) Protective action level and protective measurers outlined for the emergency identified. (3) Specific actions to be taken by coordinating support group.(4)
ANS 3.2 Side-By Side Comparison 7/25/2012 the subject test or inspection. Additional criteria for these                      points in the testing sequence to permit      inspection. Test and inspection results procedures are contained in ASME NQA-1-2008 and the NQA-1a-                        witnessing. The procedure shall require      shall be documented and evaluated by the 2009 addenda [2].                                                                   appropriate approval (or the work to          responsible authority to assure that test continue beyond the implanted hold point. and inspection requirements have been The test and inspection procedures shall      satisfied. Where tests and inspections are require recording the date, identification of to be witnessing the procedure ,hall those performing the test or inspection. As  identify hold points in the testing found condition corrective actions            !Sequence to permit witnessing The performed, if any, and as-left condition. procedure shall require appropriate approval for the work to continue beyond the designated hold point. The test and inspection procedures shall require recording the date identification of those performing the test or inspection. As found condition corrective actions performed . If any and as-left condition.
Procedures for medical treatment and handling of contaminated individuals.(5) Special equipment requirements (or items such as medical treatment. emergency personnel removal, specific radiation detection. personnel doeimetry and rescue operations. procedures for making this equipment available, plus operating instructions for such equipment, and provisions for its periodic inspection and maintenance. (6) Identification of emergency communications network, including communications required for personnel identification and effective coordination of all support groups. (7) Description of alarm signal in each facility. At sites with multiple units, alum signals should be consistent from one unit to another. (Signals for initiating protective Implementing procedures for emergency plan actions shall contain, as appropriate, the following elements: (1) Assignment of authority and responsibilities for performance of specific tasks to operating staff positions. (21 Protective action levels and protective measures outlined for the emergency identified. (31 Specific actions to be taken by coordinating support groups. (4)
3.6 Document Control                                                                5.2.13.1 Procurement Document                5.2.15 Review, Approval, and Control Control                                      of Procedures Document control activities associated with SSCs shall be     Revision to 1976      Measures shall be provided to assurance      The administrative controls and quality accomplished in accordance with ASME NQA-1-2008 and the      version section      that applicable regulatory requirements,     assurance program shall provide NQA-1a-2009 addenda [2]. The following requirements apply to 5.2.13.1. Previous    design bases and other requirements          measures to control and coordinate the plant procedures utilized during the operational phase.
Procedures for medical treatment and handling of contaminated individuals (5) Special equipment requirements for items such as medical treatment, emergency personnel removal, specific radiation detection personnel dosimetry and rescue operations procedures for making this equipment available plus operating instructions for such equipment, and provisions for its periodic  inspection and maintenance. (6) Identification of emergency communications network, including communications required for personnel identification and effective coordination of all support groups.   (7) Description of alarm signal in each facility. At sites with multiple units. Alarm signals should be consistent from one unit to another. (Signals for initiating protective 
requirements were    which are necessary to assure adequate        approval and issuance of documents, addressed by NQA-1. quality are included or referenced in the    including changes thereto which prescribe Ok.                  procedures for procurement of items and       all activities affecting quality.
services. To the extent necessary, procurement documents shell require          Such documents include those which suppliers to provide a quality assurance      describe organizational interfaces. or program consistent with the pertinent        which prescribe activities affecting requirements of American National            structures, systems or components Standard Quality Assurance Program            important to safety. These documents Requirement for Nuclear Power Plants,        also include operating and special order N4.S.2-1971. Where changes are made to        operating procedures emergency and off procurement documents, they shall be         normal procedures, test procedures, subject to the same degree of control as      equipment control procedures was used in the preparation or the original  maintenance or modification procedures, documents. Procurement documents shall        refueling procedures, and material control include provisions for the following. as      procedures. These measures shall assure 44


ANS 3.2 Side-By Side Comparison           7/25/2012 43 measures should be clear and distinct from process or operational alarm system to avoid confusion.  (8) Produces required to restore the plant to normal conditions following an emergency (9) Requirements for periodically testing of procedures communications network and alarm systems to assure that they function properly. See also U.S. Nuclear Regulatory Commission (NRC) "Guide to the Preparation of Emergency Plans (or Production and Utilization facilities," measures should be dear and distinct from process or operational alarm system to avoid confusion. (8) Procedures required to restore the plant to normal or safe shutdown conditions following an emergency. (9) Requirements for periodic testing of procedures communications network and alarm systems to assure that they function properly. For additional guidance see the following American National Standards: Facilities and Medical Care for Onsite Nuclear Power Plant Radiological Emergencies.
ANS 3.2 Side-By Side Comparison 7/25/2012 applicable:                                    that documents, including revisions or changes, are reviewed for adequacy by (I) Supplier Quality Assurance Program.        appropriately qualified personnel and Identification of quality assurance            approved for release by authorized requirements applicable to the items or        personnel: and are distributed in services procured.                            accordance with current distribution lists and used by the personnel performing the (2) Basic Technical Requirements Where        prescribed activity, and that procedures specific technical requirements apply, such    are provided to avoid the misuse of as drawings, specifications, and industrial    outdated or inappropriate codes and standards, they shall be identified by title and dates of issue in such Procedures for operational phase a way as to clearly set forth the applicable  activities of a nuclear power plant reflect documents. Where procedural                    the conditions that exist at the time the requirements apply, in such areas as test      procedures are written. These conditions and inspection needs, fabrication, cleaning    include the technical information erecting, packaging, handling, shipping,       available, industry experience. and in the and storage, they too, shall be identified    case of the initial procedure fully for a new clearly and in such a way as to avoid          plant assumptions made regarding the uncertainty as to source and need.            detailed behavior of the plant that may not be fully known prior to operation_ In order (3) Source Inspection and Audit Provisions    to ensure that the procedures in current for access to the supplier's facilities and    use provide the best possible instructions records for source inspection and audit        for performance of the work involved when the need for such inspection or audit    systematic review and feedback of shall be determined.                          information based on use is required documents.
ANSI/ANS 3.2.1-1979: Emergency Control Centers for Nuclear Power Plants. ANSI/ANS 3.2  979: and Radiological Emergency Preparation Exercises for Nuclear Power Plants, ANSI ANS 3.2 1979. 3.5.3.19 Test and Inspection Procedures 5.3.10 Test and Inspection Procedures 5.3.10 Test and Inspection Procedures These documents provide the necessary measures to assure quality is achieved and maintained for the nuclear facilities. The instructions for tests and inspections may be included within other procedures, such as installation and maintenance procedures, but will contain the objectives, acceptance criteria, prerequisites for performing the test or inspection, limiting conditions, and appropriate instructions for performing the test or inspection, as applicable. These procedures also specify any special equipment or calibrations required to conduct the test or inspection and provide for appropriate documentation and evaluation by responsible authority to assure test or inspection requirements have been satisfied. Where necessary, hold or witness points are identified within the procedures and require appropriate approval for the work to continue beyond the designated point. These procedures provide for recording the date, identification of those performing the test or inspection, as-found condition, corrective actions performed (if any), and as-left condition, as appropriate for Essentially equivalent wording as ANS 1976 version, section 5.3.10.
(4) Documentation Requirements records to be prepared, maintained, submitted or       Each procedure shall be reviewed and made available for review, such as drawing    approved prior to initial use. The specifications, procedures, procurement        frequency of subsequent review shall be documents, inspection and test records.       specified and may vary depending on the personnel and procedure qualifications,        type and complexity of the activity and material, chemical, and physical test      involved and may vary with time as a requirements ETC                              given plant reaches operational maturity.
Test and inspection procedures shall contain adescription of objectives; acceptance criteria tused to evaluate the results; prerequisites for performing the tests or inspections including aconditions to be used. to simulate normal or aoperating conditions; limiting conditions; and tinspection procedure. These procedures shal lspecify any special equipment or calibrations to conduct the test or inspection. Test and insresults shall be documented and evaluated b yresponsible authority to assume that test and requirements have been satisfied. Where test and inspections are to be witnessed, the procedure shall identify hold Test and inspection procedures shall contain: a description of objectives; acceptance criteria that will be used to evaluate the results: prerequisites for performing the tests or inspections including any special conditions to be used 1.0 simulate normal or abnormal operating conditions: limiting conditions: and the test or inspection procedure, including or referencing instruction, for restoration of the system to the condition consistent with the normal plant operating status,. If applicable. These procedures shall also specify any special equipment or calibrations required to conduct the test or 
Applicable procedures shall be reviewed following an unusual incident such as an accident an unexpected transient, significant operator error. Or equipment 45


ANS 3.2 Side-By Side Comparison           7/25/2012 44 the subject test or inspection. Additional criteria for these procedures are contained in ASME NQA-1-2008 and the NQA-1a-2009 addenda [2].
ANS 3.2 Side-By Side Comparison 7/25/2012 malfunctions. Applicable procedures shall be reviewed following any modification to For the first time owners (or licensees) of a unit from a particular nuclear steam supply system (NSSS) vendor the initial issuance of fuel loading and post fuel loading startup test procedure emergency procedures related to the NSSS, and system operating procedures for systems important to safety shall be reviewed by the appropriate design organization prior to approval.
points in the testing sequence to permit witnessing. The procedure shall require appropriate approval (or the work to continue beyond the implanted hold point. The test and inspection procedures shall require recording the da te, identification of those performing the test or inspection. As found condition corrective actions performed, if any, and as-left condition. inspection. Test and inspection results shall be documented and evaluated by the responsible authority to assure that test and inspection requirements have been satisfied. Where tests and inspections are to be witnessing the procedure ,hall identify hold points in the testing !Sequence to permit  witnessing The  procedure shall require appropriate approval for the work to continue beyond the designated hold point. The test and inspection procedures shall require recording the date identification of those performing the test or inspection. As found condition corrective actions performed . If any and as-left condition. 3.6 Document Control  5.2.13.1  Procurement Document Control 5.2.15  Review, Approval,and Control of Procedures Document control activities associated with SSCs shall be accomplished in accordance with ASME NQA-1-2008 and the NQA-1a-2009 addenda [2]. The following requirements apply to plant procedures utilized during the operational phase.
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 for routine follow up review can be accomplished in several ways, including, but not necessarily limited to documented step-by-step use of the procedure, such as occurs when the procedure has a step-by-step check off associated with it or detailed scrutiny of the procedure as part of a documented training program. drill, simulator exercise. or other such activity.
Revision to 1976 version section 5.2.13.1. Previous requirements were addressed by NQA-1. Ok.
A revision of a procedure constitutes a procedure review Procedures shall be approved by the owner organization before initial use.
Measures shall be provided to assurance that applicable regulatory requirements, design bases and other requirements which are necessary to assure adequate quality are included or referenced in the procedures for procurement of items and services. To the extent necessary, procurement documents shell require suppliers to provide a quality assurance program consistent with the pertinent requirements of American National Standard Quality Assurance Program Requirement for Nuclear Power Plants, N4.S.2-1971. Where changes are made to procurement documents, they shall be subject to the same degree of control as was used in the preparation or the original documents. Procurement documents shall include provisions for the following. as The administrative controls and quality assurance program shall provide measures to control and coordinate the approval and issuance of documents, including changes thereto which prescribe all activities affecting quality. Such documents include those which describe organizational interfaces. or which prescribe activities affecting structures, systems or components important to safety. These documents also include operating and special order operating procedures emergency and off normal procedures, test procedures, equipment control procedures maintenance or modification procedures, refueling procedures, and material control procedures. These measures shall assure 
Rules shall be established which provide for interdisciplinary review of procedures by knowledgeable personnel other than the originator and the approval of procedures and procedure channel by 46


ANS 3.2 Side-By Side Comparison           7/25/2012 45 applicable: (I) Supplier Quality Assurance Program. Identification of quality assurance requirements applicable to the items or services procured. (2) Basic Technical Requirements Where specific technical requirements apply, such as drawings, specifications, and industrial codes and standards, they shall be identified by title and dates of issue in such a way as to clearly set forth the applicable documents. Where procedural requirements apply, in such areas as test and inspection needs, fabrication, cleaning erecting, packaging, handling, shipping, and storage, they too, shall be identified clearly and in such a way as to avoid uncertainty as to source and need. (3) Source Inspection and Audit Provisions for access to the supplier's facilities and records for source inspection and audit when the need for such inspection or audit shall be determined. (4) Documentation Requirements records to be prepared, maintained, submitted or made available for review, such as drawing specifications, procedures, procurement documents, inspection and test records. personnel and procedure qualifications, and material, chemical, and physical test requirements   ETC that documents, including revisions or changes, are reviewed for adequacy by appropriately qualified personnel and approved for release by authorized personnel: and are distributed in accordance with current distribution lists and used by the personnel performing the prescribed activity, and that procedures are provided to avoid the misuse of outdated or inappropriate Procedures for operational phase activities of a nuclear power plant reflect the conditions that ex ist at the time the procedures are written. These conditions include the technical information available, industry experience. and in the case of the initial procedure fully for a new plant assumptions made regarding the detailed behavior of the plant that may not be fully known prior to operation_ In order to ensure that the procedures in current use provide the best possible instructions for performance of the work involved systematic review and feedback of information based on use is required documents. Each procedure shall be reviewed and approved prior to initial use. The frequency of subsequent review shall be specified and may vary depending on the type and complexity of the activity involved and may vary with time as a given plant reaches operational maturity.
ANS 3.2 Side-By Side Comparison 7/25/2012 authorized individuals.
Applicable procedures shall be reviewed following an unusual incident such as an accident an unexpected transient, significant operator error. Or equipment 
Changes to documents shall be reviewed and approved by the same organizations that perform the original review and approval unless the owner organization designates another qualified organization The reviewing organizations shall have access to pertinent background information upon which to base its approval and shall have adequate understanding of requirement and intent of the original document.
Those participating in any activity shall be made aware of and use proper and current instructions, procedures, drawings, and engineering requirements for performing the activity.
Participating organizations shall have procedures for control of the documents and changes thereto to preclude the possibility or use of outdated or inappropriate documents.
Document control measures shall provide for:
(1) Identification of individuals or organizations responsible for preparing, reviewing, approving and issuing documents and revisions thereto (2) Identifying the proper document 1.0 be used in performing the activity (3) Coordination and control of interlace 47


ANS 3.2 Side-By Side Comparison           7/25/2012 46 malfunctions. Applicable procedures shall be reviewed following any modification to For the first time owners (or licensees) of a unit from a particular nuclear steam supply system (NSSS) vendor the initial issuance of fuel loading and post fuel loading startup test procedure  emergency procedures related to the NSSS, and system operating procedures for systems important to safety shall be reviewed by the appropriate design organization prior to approval. 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 for routine follow up review can be accomplished in several ways, including, but not necessarily limited to documented step-by-step use of the procedure, such as occurs when the procedure has a step-by-step check off associated with it or detailed scrutiny of the procedure as part of a documented training program. drill, simulator exercise. or other such activity. A revision of a procedure constitutes a procedure review Procedures shall be approved by the owner organization before initial use.
ANS 3.2 Side-By Side Comparison 7/25/2012 documents (4) Ascertaining that proper procurements and proper revisions are being used (5) Establishing current and updated distribution lists The method, by which both permanent and temporary changes to approved procedures are made, shall be implemented through a procedure and shall include the designation of a person or persons authorized to approve such changes.
Rules shall be established which provide for interdisciplinary review of procedures by knowledgeable personnel other than the originator and the approval of procedures and procedure channel by 
Plant procedures shall be reviewed by an individual(s) knowledgeable in the aspects of the technical content and of human factors affected by the procedure within six months following startup after the first refueling outage of the unit to determine if changes are necessary or desirable. Applicable procedures shall also be reviewed following an unusual incident, such as an accident, an unexpected transient, significant operator error, or equipment malfunction, or following any modification to a system, or prior to use if the procedure has not been used in the previous two years.
Technical review of documents affecting the plant should be          Consider deleting this accomplished to verify technical accuracy and to determine that      paragraph. This would no conflicts with Technical Specifications exist and no proposed    be addressed by 50.36 changes require prior NRC approval. If a Technical Specification
                                                                    & by the independent change is needed or prior NRC approval is required, changes proposed by the documents under review shall not be                 review requirements implemented until required approvals are obtained. The reviewers    that are being moved to shall be other than the individuals who prepared the document.      NQA-1.
The technical review is the first step in the formal review process.
The reviewer shall determine if additional cross-disciplinary review is required. Conflicts that develop shall be addressed and resolved prior to approval. Successful completion of the review shall be documented.
48


ANS 3.2 Side-By Side Comparison           7/25/2012 47 authorized individuals. Changes to documents shall be reviewed and approved by the same organizations that perform the original review and approval unless the owner organization designates another qualified organization
ANS 3.2 Side-By Side Comparison 7/25/2012 Procedures shall be updated, as necessary, based on the results of the above reviews, or when procedure discrepancies are found such as through normal use or QA audits.
3.7 Control of Purchased Material, Equipment and Services Addressed by NQA-1.
Ok.
Control of purchased materials and services including the procurement and dedication of commercial grade items shall be accomplished in accordance with ASME NQA-1-2008 and the NQA-1a-2009 addenda [2].
Procedure(s) shall be implemented to aid in the identification of    New revision to counterfeit and fraudulently marketed products. As a minimum,        standard. Adding procedure(s) shouldinclude selective inspections and testing of      CF&SI guidance.
products to verify compliance with procurement requirements when Detail is sufficient. Ok.
products are suspect.
3.8 Identification and Control of Materials, Parts and Components Identification and control of materials, parts, and components shall Essentially, equivalent be accomplished in accordance with ASME NQA-1-2008 and the           to NQA- l. Ok.
NQA-1a-2009 addenda [2].
3.9 Control of Special Processes Special processes such as welding, heat treating, chemical          Essentially, equivalent cleaning, applied coatings, and nondestructive examination shall    to NQA- l. Ok.
be controlled in accordance with ASME NQA-1-2008 and the NQA-1a-2009 addenda [2].
3.10 Inspection Inspection activities shall be accomplished in accordance with      Essentially, equivalent 49


The reviewing organizations shall have access to pertinent background information upon which to base its approval and shall have adequate understanding of requirement and intent of the original document. Those participating in any activity shall be made aware of and use proper and current instructions, procedures, drawings, and engineering requirements for performing the activity. Participating organizations shall have procedures for control of the documents and changes thereto to preclude the possibility or use of outdated or inappropriate documents. Document control measures shall provide for: (1) Identification of individuals or organizations responsible for preparing, reviewing, approving and issuing documents and revisions thereto (2) Identifying the proper document 1.0 be used in performing the activity (3) Coordination and control of interlace 
ANS 3.2 Side-By Side Comparison 7/25/2012 ASME NQA-1-2008 and the NQA-1a-2009 addenda [2].                    to NQA- l. Ok.
With respect to inspection of operating activities (work functions  Essentially, equivalent associated with normal operation of the plant, routine              to NQA- l. Ok.
maintenance, and certain technical services routinely assigned to the onsite operating organization), the inspections may be carried out by personnel experienced in and knowledgeable of the scope, complexity, and nature of the work activity that they have not performed or directly supervised. For modifications and non-routine maintenance, inspections are to be conducted in a manner similar (frequency, type, and personnel performing such inspections) to that associated with construction phase activities.
3.11 Test Control Test activities shall be controlled in accordance with ASME NQA-    Essentially, equivalent 1-2008 and the NQA-1a-2009 addenda [2]. Controls shall be            to NQA- l. Ok.
established for operational phase surveillance, calibration, and in-service inspection and testing activities.
Tests during the preoperational period shall be conducted to demonstrate that the performance of facility systems is in accordance with its design intent and that the coordinated operation of the facility as a whole is satisfactory, to the extent feasible. The preoperational testing program shoulddemonstrate, as nearly as can be practicably simulated, the overall integrated operation of the plant systems at rated conditions, including simultaneous operation of auxiliary systems. It may be necessary to defer portions of these tests until nuclear heat is available.
Tests during the initial operational phase shall be conducted to demonstrate the performance of systems that could not be tested prior to operation and to confirm those physical parameters, hydraulic or mechanical characteristics that need to be known, but which could not be predicted with the required accuracy, and to confirm that behavior conforms to design criteria.
3.11.1 Tests Associated with Plant Maintenance, Modifications or Procedure Changes 50


ANS 3.2 Side-By Side Comparison           7/25/2012 48 documents (4) Ascertaining that proper procurements and proper revisions are being used (5) Establishing current and updated distribution lists The method, by which both permanent and temporary changes to approved procedures are made, shall be implemented through a procedure and shall include the designation of a person or persons authorized to approve such changes.
ANS 3.2 Side-By Side Comparison 7/25/2012 Tests shall be performed following plant modifications or          Essentially equivalent significant changes in operating procedures to confirm that the    wording in ANS 1976 modifications or changes reasonably produce expected results        version, section and that the change does not reduce safety of operations.
Plant procedures shall be reviewed by an individual(s) knowledgeable in the aspects of the technical content and of human factors affected by the procedure within six months following startup after the first refueling outage of the unit to determine if changes are necessary or desirable. Applicable procedures shall also be reviewed following an unusual incident, such as an accident, an unexpected transient, significant operator error, or equipment malfunction, or following any modification to a system, or prior to use if the procedure has not been used in the previous two years. Technical review of documents affecting the plant should be accomplished to verify technical accuracy and to determine that no conflicts with Technical Specifications exist and no proposed changes require prior NRC approval. If a Technical Specification change is needed or prior NRC approval is required, changes proposed by the documents under review shall not be implemented until required approvals are obtained. The reviewers shall be other than the individuals who prepared the document. The technical review is the first step in the formal review process. The reviewer shall determine if additional cross-disciplinary review is required. Conflicts that develop shall be addressed and resolved prior to approval. Successful completion of the review shall be documented.
5.2.19.3 3.12 Control of Measuring and Test Equipment Measuring and test equipment shall be controlled in accordance      Essentially, equivalent with ASME NQA-1-2008 and the NQA-1a-2009 addenda [2].              to NQA- l. Ok.
Consider deleting this paragraph. This would be addressed by 50.36 & by the independent review requirements that are being moved to NQA-1.  
3.13 Handling, Storage and Shipping Handling, shipping, and storage activities shall be accomplished in Essentially, equivalent accordance with ASME NQA-1-2008 and the NQA-1a-2009                to NQA- l. Ok.
addenda [2]. Additional requirements are addressed in ASME NQA-1-2008 and the NQA-1a-2009 addenda, Subpart 2.2 [2].
3.14 Inspection, Test and Operating Status Inspection, test and operating status shall be accomplished in     Items already accordance with ASME NQA-1-2008 and the NQA-1a-2009                addressed in NQA-1.
addenda [2]. The following requirements shouldbe employed          Ok.
during the operational phase.
(1) Equipment shall be controlled, as necessary, to maintain        Essentially, equivalent personnel and reactor safety and to avoid unauthorized        to NQA- l. Ok.
operation of equipment.
(2) Control measures such as locking or tagging to secure and       Essentially, equivalent identify equipment in a controlled status shall be required. to NQA- l. Ok.
Independent verifications shall be conducted to ensure that necessary measures, such as tagging equipment, have been implemented correctly. Tagouts shall be designed and installed to prevent obstruction of other controls or indications.
(3) The status of equipment undergoing inspections, calibrations,  Essentially, equivalent maintenance and modification activities and tests shall be     to NQA- l. Ok.
identified.
51


ANS 3.2 Side-By Side Comparison           7/25/2012 49 Procedures shall be updated, as necessary, based on the results of the above reviews, or when procedure discrepancies are found such as through normal use or QA audits. 3.7 Control of Purchased Material, Equipment and Services Addressed by NQA-1.
ANS 3.2 Side-By Side Comparison 7/25/2012 Essentially, equivalent (4) Control room indicators and operating devices that are to NQA- l. Ok.
Ok. Control of purchased materials and services including the procurement and dedication of commercial grade items shall be accomplished in accordance with ASME NQA-1-2008 and the NQA-1a-2009 addenda [2].
out-of-service shall be appropriately tagged or labeled or provided by a suitable means when applied to electronic displays where affixing a physical tag would not be feasible.
Procedure(s) shall be implemented to aid in the identification of counterfeit and fraudulently marketed products. As a minimum, procedure(s) shouldinclude selective inspections and testing of products to verify compliance with procurement requirements when products are suspect.
Essentially, equivalent (5) Items which have not satisfactorily passed required inspections, calibrations or tests shall be identified. In cases  to NQA- l. Ok.
New revision to standard. Adding CF&SI guidance. Detail is sufficient. Ok.
where required documentary evidence is not available to demonstrate that items have passed inspections, calibrations or tests required by Technical Specifications, affected items shall be considered inoperable and reliance shall not be placed on them to fulfill their intended safety function(s).
3.8 Identification and Control of Materials, Parts and Components  Identification and control of materials, parts, and components shall be accomplished in accordance with ASME NQA-1-2008 and the NQA-1a-2009 addenda [2].
Local identification of deficiencies in equipment which require correction should be provided.
Essentially, equivalent to NQA- l. Ok.
5.2.6 Equipment Control                      5.2.6 Equipment Control (6) Permission to release plant systems or equipment for maintenance or tests shall be granted by designated operating Permission to release equipment or          Procedures shall be provided for control of personnel holding a senior operator license who have been designated responsibility for granting such activities. Prior to                            systems for maintenance shall be granted    equipment, as necessary, to maintain granting permission, such operating personnel shall verify that                            by designated operating personnel. Prior to  personnel and reactor safety and to avoid the equipment or system may be safely released, determine                                  granting permission, such operating          unauthorized operation of equipment.
3.9 Control of Special Processes Special processes such as welding, heat treating, chemical cleaning, applied coatings, and nondestructive examination shall be controlled in accordance with ASME NQA-1-2008 and the NQA-1a-2009 addenda [2].
how long it may be out of service, and determine what                                      personnel shall verify that the equipment or These procedures shall require control functional testing or redundant systems are required prior to and                          system can be released and determine        measures such as locking or tagging to during the out-of-service period. Granting of such permission how long it may be out of service, Granting  secure and identify equipment in a shall be documented.          Independent verification shall be provided to the extent necessary to ensure that the proper                                  of such permission shall be documented.     controlled status. Control room & gouts system was removed from service. This may be accomplished                                  Attention shall be given to the potentially  shall be designed and installed to prevent by checking appropriate equipment and controls, or by indirect                              degraded degree of protection when one      obstruction of other instruments, controls, means such as observation of indicators and status lights. This                            subsystem of a redundant safety system      or indicating lights. Procedures shall also requirement may be waived if the only way of accomplishing it                              has been removed (or maintenance,           require that the status of inspection and would result in significant radiation exposure. Attention shall be                                                                       tests performed upon individual items in given to the degraded protection available when a subsystem of                              After permission has been granted to        the nuclear power plant be indicated by a redundant safety system has been removed for remove the equipment (room service, it      the use of markings such as stamps, tags, maintenance or surveillance testing.
Essentially, equivalent to NQA- l. Ok.
shall be made are to work on. Measures      labels. Routing cards or other suitable shall provide (or protection of equipment    means. Suitable means include and workers, Equipment and systems in a      identification numbers which are traceable controlled status shall clearly identified. to records of the status of inspections and Strict control measures for such equipment  tests. Procedures shall also provide for shall be enforced.                          the identification of items which have not satisfactorily passed required inspections Conditions to be considered in preparing    and tests, where necessary, to preclude 52
3.10  Inspection Inspection activities shall be accomplished in accordance with Essentially, equivalent   


ANS 3.2 Side-By Side Comparison           7/25/2012 50 ASME NQA-1-2008 and the NQA-1a-2009 addenda [2].
ANS 3.2 Side-By Side Comparison 7/25/2012 equipment for maintenance include, for        inadvertent bypassing of such inspections example: shutdown margin; method of            and tests. In cases where require emergency core cooling,; establishment of     documentary evidence isnt available, the B path for decay heat removal; temperature    associated equipment or materials must and pressure of the system; valves            be considered nonconforming in between work and hazardous material;          accordance with 5.2.14. Until suitable venting, draining, and flushing; entry into    documentary evidence is available to closed vessels; hazardous atmospheres          show the equipment or material is in handling hazardous materials; and              conformance affected systems shall be electrical hazards. When entry into a          considered to be inoperable and reliance closed system is required, control            shall not be placed on such systems to measures shall be established to prevent      fulfill their intended safety functions.
to NQA- l. Ok.
entry of extraneous material and to assure that foreign material is removed before the    Permission to release plant systems or system is reclosed Equipment, as              equipment for maintenance or necessary, to maintain personnel and          surveillance tests shall be granted by reactor l entry and to avoid unauthorized      designated operating personnel operation of equipment.
With respect to inspection of operating activities (work functions associated with normal operation of the plant, routine maintenance, and certain technical services routinely assigned to the onsite operating organization), the inspections may be carried out by personnel experienced in and knowledgeable of the scope, complexity, and nature of the work activity that they have not performed or directly supervised. For modifications and non-routine maintenance, inspections are to be conducted in a manner similar (frequency, type, and personnel performing such inspections) to that associated with construction phase activities.
Holding a senior operator license. Prior to Procedures shall be provided for control of    granting permission, such operating equipment, as necessary, to maintain          personnel shall verify that the equipment personnel and reactor safety and to avoid      or system can be released. determine unauthorized operation of equipment.          how long it may be out of service and These procedures shall require control        determine what functional testing of measures such as locking or tagging to         redundant systems is required prior to secure and identify equipment in controlled    and during the out-of service period.
Essentially, equivalent to NQA- l. Ok.
status. The procedure shall require            Granting of such permission shall be independent verification where appropriate,   documented. Attention shall be given to to ensure that necessary measure such as       the potentially degraded degree of tagging equipment has been implemented        protection when one subsystem of a correctly. Temporary modification such as      redundant safety system has been temporary bypass lines electrical jumpers      removed for maintenance or surveillance lifted electrical leads and temporary trip    testing. In addition to the requirements of point settings shall be controlled by          the Technical Specifications additional approved procedures which shall include        conditions to be considered in preparing the requirements for independent              equipment for maintenance or verification. A log shall be maintained of the surveillance testing include, for example; current status of such temporary              shutdown margin: method of emergency core cooling; establishment of a path for 53
3.11 Test Control Test activities shall be controlled in accordance with ASME NQA-1-2008 and the NQA-1a-2009 addenda [2]. Controls shall be established for operational phase surveillance, calibration, and in-service inspection and testing activities. Tests during the preoperational period shall be conducted to demonstrate that the performance of facility systems is in accordance with its design intent and that the coordinated operation of the facility as a whole is satisfactory, to the extent feasible. The preoperational testing program shoulddemonstrate, as nearly as can be practicably simulated, the overall integrated operation of the plant systems at rated conditions, including simultaneous operation of auxiliary systems. It may be necessary to defer portions of these tests until nuclear heat is available. Tests during the initial operational phase shall be conducted to demonstrate the performance of systems that could not be tested prior to operation and to confirm those physical parameters, hydraulic or mechanical characteristics that need to be known, but which could not be predicted with the required accuracy, and to confirm that behavior conforms to design criteria.
Essentially, equivalent to NQA- l. Ok.
3.11.1 Tests Associated with Plant Maintenance, Modifications or Procedure Changes 


ANS 3.2 Side-By Side Comparison           7/25/2012 51 Tests shall be performed following plant modifications or significant changes in operating procedures to confirm that the modifications or changes reasonably produce expected results and that the change does not reduce safety of operations.
ANS 3.2 Side-By Side Comparison 7/25/2012 modifications                               decay heat removal: temperature and pressure of the system: valves between The procedures shall also require that the   work and hazardous material; venting, status of inspections and tests performed    draining and flushing; entry into closed upon individual items on the nuclear power  vessels; hazardous atmospheres; plant be indicated by the use of markings    handling hazardous materials; and such as stamps, tags, labels, routing cards, electrical hazards. When entry into a or other suitable means. Suitable means      closed system is required, control include identification numbers, which are    measures shall be established top vent traceable to records of the status of        entry of extraneous material and to assure inspections and tests. Procedures shall      that foreign material is removed before the also provide for the identification of items system is reclosed. After permission has which has satisfactorily passed required    been granted to remove a system from inspections and tests, where necessary to    service, it shall be made safe to work on.
Essentially equivalent wording in ANS 1976 version, section 5.2.19.3  3.12  Control of Measuring and Test Equipment Measuring and test equipment shall be controlled in accordance with ASME NQA-1-2008 and the NQA-1a-2009 addenda [2].
preclude inadvertent bypassing of such      Measures shall provide for protection of inspections and tests fn cases where        equipment and workers. Equipment and required documentary evidence is not        systems in a controlled status shall be available, the associated equipment or      clearly identified, at a minimum, at any materials must be considered                location where the equipment can be nonconforming in accordance with Section    operated. When a system important to 5.2.14. Until suitable documentary          safety is removed from service, evidence is available to show the            independent verification shall be provided equipment or material is in conformance,     to the extent necessary to assure that the affected systems shall be considered        proper system was removed. This may be inoperable and reliance shall not be placed  accomplished by checking appropriate on such systems to fulfill their intended    equipment and controls, or by indirect safety functions. When equipment is ready    means such as observation of indicators to be returned to service, operating        and status light. This requirement may be personnel shall place the equipment in       waived if the only way of accomplishing it operation and verify and document its        would result in significant radiation functional acceptability, Attention shall be exposure. Reactor operators and the shift given to restoration of normal conditions,  supervisor shall be informed of changes in such as removal of jumpers or signals used  equipment status and the effects of such in maintenance or testing or such as re      changes. Temporary modifications, such turning valves, breakers or switches to     as temporary bypass lines electrical proper start-up or operating positions from  jumpers, lifted electrical leads, and "test" or "manual" position". When placed    temporary trip point settings, shall be into service the equipment should receive    controlled by approved procedures which additional surveillance during the run-in    shall include a requirement for 54
Essentially, equivalent to NQA- l. Ok.
3.13 Handling, Storage and Shipping Handling, shipping, and storage activities shall be accomplished in accordance with ASME NQA-1-2008 and the NQA-1a-2009 addenda [2]. Additional requirements are addressed in ASME NQA-1-2008 and the NQA-1a-2009 addenda, Subpart 2.2 [2].
Essentially, equivalent to NQA- l. Ok.
3.14 Inspection, Test and Operating Status Inspection, test and operating status shall be accomplished in accordance with ASME NQA-1-2008 and the NQA-1a-2009 addenda [2]. The following requirements shouldbe employed during the operational phase.
Items already addressed in NQA-1. Ok.   (1) Equipment shall be controlled, as necessary, to maintain personnel and reactor safety and to avoid unauthorized operation of equipment. Essentially, equivalent to NQA- l. Ok.
(2) Control measures such as locking or tagging to secure and identify equipment in a controlled status shall be required.
Independent verifications shall be conducted to ensure that necessary measures, such as tagging equipment, have been implemented correctly. Tagouts shall be designed and installed to prevent obstruction of other controls or indications. Essentially, equivalent to NQA- l. Ok.
(3) The status of equipment undergoing inspections, calibrations, maintenance and modification activities and tests shall be identified. Essentially, equivalent to NQA- l. Ok.


ANS 3.2 Side-By Side Comparison           7/25/2012 52 (4) Control room indicators and operating devices that are out-of-service shall be appropriately tagged or labeled or provided by a suitable means when applied to electronic displays where affixing a physical tag would not be feasible. Essentially, equivalent to NQA- l. Ok.
ANS 3.2 Side-By Side Comparison 7/25/2012 period.          independent verification by either a second person or by a functional test which conclusively proves the proper installation or removal of the temporary modification. A log or other documented evidence shall be maintained of the current status of such temporary modifications. When equipment I, ready to be returned to service. Operating personnel shall place the equipment in operation and verify and document its functional acceptability. Attention shall be given to restoration of normal conditions, such as removal of jumpers or signal used in maintenance or testing or such as returning valves. breaker or switches to proper startup or operating positions from "test" or "manual position, and assuring that all alarms which are indicative of inoperative status are extinguished. For equipment important to safety, proper alignment shall be independently verified by a second qualified person unless all equipment. Valves. and switches involved in the activity can be proven to be in their correct alignment by functional testing without. Adversely affecting the safety of the plant. A second inspection is where such verification would result. in significant radiation exposure. The person who performs the verification of correct implementation of equipment control measures or proper alignment prior to returning equipment to service shall be qualified to perform such tasks for the particular system involved, and shall process operating knowledge of the particular system involved and its 55
(5) Items which have not satisfactorily passed required inspections, calibrations or tests shall be identified. In cases where required documentary evidence is not available to demonstrate that items have passed inspections, calibrations or tests required by Technical Specifications, affected items shall be considered inoperable and reliance shall not be placed on them to fulfill their intended safety function(s). Local identification of deficiencies in equipment which require correction should be provided. Essentially, equivalent to NQA- l. Ok.
(6) Permission to release plant systems or equipment for maintenance or tests shall be granted by designated operating personnel holding a senior operator license who have been designated responsibility for granting such activities. Prior to granting permission, such operating personnel shall verify that the equipment or system  may be safely  released, determine how long it may be out of service, and determine what functional testing or redundant systems are required prior to and during the out-of-service period. Granting of such permission shall be documented. Independent verification shall be provided to the extent necessary to ensure that the proper system was removed from service. This may be accomplished by checking appropriate equipment and controls, or by indirect means such as observation of indicators and status lights. This requirement may be waived if the only way of accomplishing it would result in significant radiation exposure. Attention shall be given to the degraded protection available when a subsystem of a redundant safety system has been removed for maintenance or surveillance testing.
5.2.6 Equipment Control Permission to release equipment or systems for maintenance shall be granted by designated operating personnel. Prior to granting permission, such operating personnel shall verify that the equipment or system can be released and determine how long it may be out of service, Granting of such permission shall be documented. Attention shall be given to the potentially degraded degree of protection when one subsystem of a redundant safety system has been removed (or maintenance, After permission has been granted to remove the equipment (room service, it shall be made are to work on. Measures shall provide (or protection of equipment and workers, Equipment and systems in a controlled status shall clearly identified. Strict control measures for such equipment shall be enforced. Conditions to be considered in preparing 5.2.6  Equipment Control Procedures shall be provided for control of equipment, as necessary, to maintain personnel and reactor safety and to avoid unauthorized operation of equipment.
These procedures shall require control measures such as locking or tagging to secure and identify equipment in a controlled status. Control room & gouts shall be designed and installed to prevent obstruction of other instruments, controls, or indicating lights. Procedures shall also require that the status of inspection and tests performed upon individual items in the nuclear power plant be indicated by the use of markings such as stamps, tags, labels. Routing cards or other suitable means. Suitable means include identification numbers which are traceable to records of the status of inspections and tests. Procedures shall also provide for the identification of items which have not satisfactorily passed required inspections and tests, where necessary, to preclude 


ANS 3.2 Side-By Side Comparison           7/25/2012 53 equipment for maintenance include, for example: shutdown margin; method of emergency core cooling,; establishment of B path for decay heat removal; temperature and pressure of the system; valves between work and hazardous material; venting, draining, and flushing; entry into closed vessels; hazardous atmospheres handling hazardous materials; and electrical hazards. When entry into a closed system is required, control measures shall be established to prevent entry of extraneous material and to assure that foreign material is removed before the system is reclosed Equipment, as necessary, to maintain personnel and reactor l entry and to avoid unauthorized operation of equipment. Procedures shall be provided for control of equipment, as necessary, to maintain personnel and reactor safety and to avoid unauthorized operation of equipment. These procedures shall require control measures such as locking or tagging to secure and identify equipment in controlled status. The procedure shall require independent verification where appropriate, to ensure that necessary measure such as tagging equipment has been implemented correctly. Temporary modification such as temporary bypass lines electrical jumpers lifted electrical leads and temporary trip point settings shall be controlled by approved procedures which shall include the requirements for independent verification. A log shall be maintained of the current status of such temporary inadvertent bypassing of such inspections and tests. In cases where require documentary evidence isn't available, the associated equipment or materials must be considered nonconforming in accordance with 5.2.14. Until suitable documentary evidence is available to show the equipment or material is in conformance affected systems shall be considered to be inoperable and reliance shall not be placed on such systems to fulfill their intended safety functions. Permission to release plant systems or equipment for maintenance or surveillance tests shall be granted by designated operating personnel Holding a senior operator license. Prior to granting permission, such operating personnel shall verify that the equipment or system can be released. determine how long it may be out of service and determine what functional testing of redundant systems  is required prior to and during the out-of service period. Granting of such permission shall be documented. Attention shall be given to the potentially degraded degree of protection when one subsystem of a redundant safety system has been removed for maintenance or surveillance testing. In addition to the requirements of the Technical Specifications additional conditions to be considered in preparing equipment for maintenance or surveillance testing include, for example; shutdown margin: method of emergency core cooling; establishment of a path for   
ANS 3.2 Side-By Side Comparison 7/25/2012 relationship to plant safety.
5.2.6 Equipment Control                      5.2.6 Equipment Control (7) In addition to limiting conditions for operation and allowed outage times in Technical Specifications, additional conditions Permission to release equipment or          When equipment is, ready to be returned to to be considered in preparing equipment for maintenance or surveillance testing may include: shutdown risk; shutdown                      systems for maintenance shall be granted    service operating personnel shall place the margin; method of emergency core cooling; establishment of a                    by designated operating personnel. Prior to  equipment in operation and verify and path for decay heat removal; temperature and pressure of the                   granting permission, such operating          document its functional acceptability.
system; valves between work and hazardous material; venting,                   personnel shall verify that the equipment or Attention shall be given to restoration of draining and flushing; entry into closed vessels; hazardous                     system can be released. and determine        normal conditions, such as removal of atmospheres and ALARA considerations; handling hazardous how long it may be out of service, Granting  jumpers or signals used in maintenance or materials; and electrical hazards. When entry into a closed system is required, entry of extraneous material shall be                      of such permission shall be documented.      testing or such as returning valves. breaker prevented. Any foreign material shall be removed and the                        Attention shall be given to the potentially  or switches to proper startup or operating removal verified before the system is re-closed. Foreign                        degraded degree of protection when one      positions from "test" or "manual positions material may be allowed to remain if an analysis is performed to               subsystem of a redundant safety system      and assuring that all alarms which are demonstrate that the material would not adversely affect plant                  has been removed (or maintenance,            indicative of in inoperative status are safety.                                                                                                                     extinguished. For equipment important to After permission has been granted to        safety, proper alignment shall be remove the equipment (room service, it      independently verified by a second qualified shall be made are to work on. Measures      person unless all equipment, valves, and shall provide (or protection of equipment   switches involved in the activity can be and workers, Equipment and systems in a      proven to be in their correct alignment by controlled status shall clearly identified. functional testing without adversely Strict control measures for such equipment  affecting the safety of the plant. A second shall be enforced.                           inspection is where such verification would result in significant radiation exposure. The Conditions to be considered in preparing     person who performs the verification of equipment for maintenance include, for       correct implementation of equipment control example: shutdown margin; method of         measures or proper alignment prior to emergency core cooling,; establishment of   returning equipment to service shall be B path for decay heat removal; temperature  qualified to perform such verification for the and pressure of the system; valves          particular system involved, and shall between work and hazardous material;        possess operating knowledge of the venting, draining, and flushing; entry into particular system closed vessels; hazardous atmospheres handling hazardous materials; and electrical hazards. When entry into a closed system is required, control measures shall be established to prevent entry of extraneous material and to assure 56


ANS 3.2 Side-By Side Comparison           7/25/2012 54 modifications The procedures shall also require that the status of inspections and tests performed upon individual items on the nuclear power plant be indicated by the use of markings such as stamps, tags, labels, routing cards, or other suitable means. Suitable means include identification numbers, which are traceable to records of the status of inspections and tests. Procedures shall also provide for the identification of items which has satisfactorily passed required inspections and tests, where necessary to preclude inadvertent bypassing of such inspections and tests fn cases where required documentary evidence is not available, the associated equipment or materials must be considered nonconforming in accordance with Section 5.2.14. Until suitable documentary evidence is available to show the equipment or material is in conformance, affected systems shall be considered inoperable and reliance shall not be placed on such systems to fulfill their intended safety functions. When equipment is ready to be returned to service, operating personnel shall place the equipment in operation and verify and document its functional acceptability, Attention shall be given to restoration of normal conditions, such as removal of jumpers or signals used in maintenance or testing or such as re turning valves, breakers or switches to proper start-up or operating positions from "test" or "manual" position". When placed into service the equipment should receive additional surveillance during the run-in decay heat removal: temperature and pressure of the system: valves between work and hazardous material; venting, draining and flushing; entry into closed vessels; hazardous atmospheres; handling  hazardous  materials; and electrical hazards. When entry into a closed system is required, control measures shall be established top vent entry of extraneous material and to assure that foreign material is removed before the system is reclosed. After permission has been granted to remove a system from service, it shall be made safe to work on. Measures shall provide for protection of equipment and workers. Equipment and systems in a controlled status shall be clearly identified, at a minimum, at any location where the equipment can be operated. When a system important to safety is removed from service, independent verification shall be provided to the extent necessary to assure that the proper system was removed. This may be accomplished by checking appropriate equipment and controls, or by indirect means such as observation of indicators and status light. This requirement may be waived if the only way of accomplishing it would result in significant radiation exposure. Reactor operators and the shift supervisor shall be informed of changes in equipment status and the effects of such changes. Temporary modifications, such as temporary bypass lines electrical jumpers, lifted electrical leads, and temporary trip point settings, shall be controlled by approved procedures which shall include a requirement for 
ANS 3.2 Side-By Side Comparison 7/25/2012 that foreign material is removed before the system is reclosed. equipment. as necessary, to maintain personnel and reactor l entry and to avoid unauthorized operation of equipment.
Procedures shall be provided for control of equipment. as necessary, to maintain personnel and reactor safety and to avoid unauthorized operation of equipment.
These procedures shall require control measures such as locking or tagging to secure and identify equipment in controlled status. The procedure shall require independent verification where appropriate, to ensure that necessary measure such as tagging equipment has been implemented correctly. Temporary modification such as temporary bypass lines electrical jumpers lifted electrical leads and temporary trip point settings shall be controlled by approved procedures which shall include the requirements for independent verification. A log shall be maintained of the current status of such temporary modifications The procedures shall also require that the status of inspections and tests performed upon individual items on the nuclear power plant be indicated by the use of markings such as stamps, tags, labels, routing cards, or other suitable means. Suitable means include identification numbers, which are traceable to records of the status of inspections and tests. Procedures shall also provide for the identification of items which has satisfactorily passed required inspections and tests, where necessary to 57


ANS 3.2 Side-By Side Comparison           7/25/2012 55 period. independent verification by either a second person or by a functional test which conclusively proves the proper installation or removal of the temporary modification. A log or other documented evidence shall be maintained of the current status of such temporary modifications. When equipment I, ready to be returned to service. Operating personnel shall place the equipment in operation and verify and document its functional acceptability. Attention shall be given to restoration of normal conditions, such as removal of jumpers or signal used in maintenance or testing or such as returning valves. breaker or switches to proper startup or operating positions from "test" or "manual" position,  and assuring that all alarms which are indicative of inoperative status are extinguished. For equipment important to safety, proper alignment shall be independently verified by a second qualified person unless all equipment. Valves. and switches involved in the activity can be proven to be in their correct alignment by functional testing without. Adversely affecting the safety of the plant. A second inspection is where such verification would result. in significant radiation exposure. The person who performs the verification of correct implementation of equipment control measures or proper alignment prior to returning equipment to service shall be qualified to perform such tasks  for the particular system involved, and shall process operating knowledge of the particular system involved and its 
ANS 3.2 Side-By Side Comparison 7/25/2012 preclude inadvertent bypassing of such inspections and tests fn cases where required documentary evidence is not available, the associated equipment or materials must be considered nonconforming in accordance with Section 5.2.14. Until suitable documentary evidence is available to show the equipment or material is in conformance, affected systems shall be considered inoperable and reliance shall not be placed on such systems to fulfill their intended safety functions. When equipment is ready to be returned to service, operating personnel shall place the equipment in operation and verify and document its functional acceptability, Attention shall be given to restoration of normal conditions, such as removal of jumpers or signals used in maintenance or testing or such as re turning valves, breakers or switches to proper start-up or operating positions from "test" or "manual" position". When placed into service the equipment should receive additional surveillance during the run-in period.
5.2.6 Equipment Control                      5.2.6 Equipment Control (8) A plant system(s) or component(s) shall be made safe to work on after permission has been granted to remove it from service.
(See Above)                                  (See Above)
Equipment and systems in a controlled status shall be clearly identified at any location where the equipment can be operated.
Control room supervision shall be promptly informed of changes in equipment status, including temporary modifications, and the effects of such changes. Equipment, which is in other than normal condition, shouldbe readily identifiable to the operating staff.
58


ANS 3.2 Side-By Side Comparison           7/25/2012 56 relationship to plant safety. (7) In addition to limiting conditions for operation and allowed outage times in Technical Specifications, additional conditions to be considered in preparing equipment for maintenance or surveillance testing may include: shutdown risk; shutdown margin; method of emergency core cooling; establishment of a path for decay heat removal; temperature and pressure of the system; valves between work and hazardous material; venting, draining and flushing; entry into closed vessels; hazardous atmospheres and ALARA considerations; handling hazardous materials; and electrical hazards. When entry into a closed system is required, entry of extraneous material shall be prevented. Any foreign material shall be removed and the removal verified before the system is re-closed. Foreign material may be allowed to remain if an analysis is performed to demonstrate that the material would not adversely affect plant safety. 5.2.6 Equipment ControlPermission to release equipment or systems for maintenance shall be granted by designated operating personnel. Prior to granting permission, such operating personnel shall verify that the equipment or system can be released. and determine how long it may be out of service, Granting of such permission shall be documented. Attention shall be given to the potentially degraded degree of protection when one subsystem of a redundant safety system has been removed (or maintenance, After permission has been granted to remove the equipment (room service, it shall be made are to work on. Measures shall provide (or protection of equipment and workers, Equipment and systems in a controlled status shall clearly identified. Strict control measures for such equipment shall be enforced. Conditions to be considered in preparing equipment for maintenance include, for example: shutdown margin; method of emergency core cooling,; establishment of B path for decay heat removal; temperature and pressure of the system; valves between work and hazardous material; venting, draining, and flushing; entry into closed vessels; hazardous atmospheres handling hazardous materials; and electrical hazards. When entry into a closed system is required, control measures shall be established to prevent entry of extraneous material and to assure 5.2.6 Equipment ControlWhen equipment is, ready to be returned to service operating personnel shall place the equipment in operation and verify and document its functional acceptability. Attention shall be given to restoration of normal conditions, such as removal of jumpers or signals used in maintenance or testing or such as returning valves. breaker or switches to proper startup or operating positions from "test" or "manual" positions and assuring that all alarms which are indicative of in inoperative status are extinguished. For equipment important to safety, proper alignment shall be independently verified by a second qualified person unless all equipment, valves, and switches involved in the activity can be proven to be in their correct alignment by functional testing without adversely affecting the safety of the plant. A second inspection is where such verification would result in significant radiation exposure. The person who performs the verification of correct implementation of equipment control measures or proper alignment prior to returning equipment to service shall be qualified to perform such verification for the particular system involved, and shall possess operating knowledge of the particular system 
ANS 3.2 Side-By Side Comparison 7/25/2012 (9) Temporary plant modifications shall be clearly identified at the                  5.2.6 Equipment Control                        5.2.6 Equipment Control installed location(s) and at any location of operation which could be affected by the temporary modification.                                       (See Above)                                    (See Above)
(10) When equipment is ready to be returned to service, operating                      5.2.6 Equipment Control                        5.2.6 Equipment Control personnel shall place the equipment in operation and verify and document its functional acceptability. Attention shall be given to               (See Above)                                    (See Above) restoration of normal conditions, such as removal of jumpers or signals used in maintenance or testing or returning valves, breakers or switches to proper startup or operating positions from "test" or "manual" positions. Steps shall be taken to ensure that all associated alarms and indications are returned to normal.
(11) Proper alignment of equipment shall be independently verified                    Conditions to be considered in preparing       When equipment is, ready to be returned to by a second qualified person unless all equipment, valves, and                    equipment for maintenance include, for         service operating personnel shall place the switches involved in the activity can be proven to be in their                    example: shutdown margin; method of           equipment in operation and verify and correct alignment by functional testing without adversely emergency core cooling establishment of B     document its functional acceptability.
affecting the safety of the plant. Another exception is where such verification would result in significant radiation exposure.                path for decay heat removal; temperature       Attention shall be given to restoration of The person who performs the verification of correct                              and pressure of the system; valves between     normal conditions, such as removal of implementation of equipment control measures or proper                            work and hazardous material; venting,         jumpers or signals used in maintenance or alignment prior to returning equipment to service shall be                        draining, and flushing; entry into closed     testing or such as returning valves. breaker qualified to perform such tasks for the particular system                        vessels; hazardous atmospheres handling        or switches to proper ,startup or operating involved, and shall possess operating knowledge of the                            hazardous materials; and electrical hazards. positions from "test" or "manual positions, particular system involved and its relationship to plant safety.
When entry into a closed system is required,  and assuring that all alarms which are control measures shall be established to      indicative of in inoperative status are prevent entry of extraneous material and to    extinguished. For equipment important to assure that foreign material is removed        safety, proper alignment shall be before the system is reclosed equipment, as    independently verified by a second qualified necessary, to maintain personnel and reactor  person unless all equipment, valves. and l entry and to avoid unauthorized operation of switches involved in the activity can be equipment.                                    proven to be in their correct alignment by functional testing without adversely affecting the safety of the plant. A second inspection is where such verification would result. in significant radiation exposure. The person who performs the verification of correct implementation of equipment control measures or proper alignment prior to returning equipment to service shall be qualified to perform such verification for the 59


ANS 3.2 Side-By Side Comparison           7/25/2012 57 that foreign material is removed before the system is reclosed. equipment. as necessary, to maintain personnel and reactor l entry and to avoid unauthorized operation of equipment. Procedures shall be provided for control of equipment. as  necessary, to maintain personnel and reactor safety and to avoid unauthorized operation of equipment. These procedures shall require control measures such as locking or tagging to secure and identify equipment in controlled status. The procedure shall require independent verification where appropriate, to ensure that necessary measure such as tagging equipment has been implemented correctly. Temporary modification such as temporary bypass lines electrical jumpers lifted electrical leads and temporary trip point settings shall be controlled by approved procedures which shall include the requirements for independent verification. A log shall be maintained of the current status of such temporary modifications The procedures shall also require that the status of inspections and tests performed upon individual items on the nuclear power plant be indicated by the use of markings such as stamps, tags, labels, routing cards, or other suitable means. Suitable means include identification numbers, which are traceable to records of the status of inspections and tests. Procedures shall also provide for the identification of items which has satisfactorily passed required inspections and tests, where necessary to
ANS 3.2 Side-By Side Comparison 7/25/2012 particular system involved, and shall possess operating knowledge of the particular system (12) Equipment shouldreceive additional monitoring during an                                  When placed into service the equipment        5.2.19.1. Preoperational Tests appropriate run-in period prior to being placed into service to                         should receive additional surveillance during perform its intended function. Final acceptance of equipment                             the run-in period,                            A component test is a functional, that is returned to service shall be made by the on-duty                                                                              operational or performance test of an supervisor responsible for the unit.                                                                                                  individual piece of equipment or unit system under prescribed conditions. Typical parameters to be examined are direction of rotation, bearing temperatures, vibration, time delays, and ability to operate with remote and local control. The procedure shall list checks to be made and provide acceptance criteria. Consideration should also be given to providing run-in period to minimize early failures during operation of the plant.
3.15 Nonconforming Items Nonconforming items shall be controlled in accordance with          Essentially, equivalent ASME NQA-1-2008 and the NQA-1a-2009 addenda [2].                    to NQA- l. Ok.
3.16 Corrective Actions Corrective action activities shall be accomplished in accordance    Essentially, equivalent with ASME NQA-1-2008 and the NQA-1a-2009 addenda [2].               to NQA- l. Ok.
3.17 Plant Records Management Quality assurance records shall be controlled in accordance with    Essentially, equivalent ASME NQA-1-2008 and the NQA-1a-2009 addenda [2].                     to NQA- l. Ok.
60


ANS 3.2 Side-By Side Comparison           7/25/2012 58 preclude inadvertent bypassing of such inspections and tests fn cases where required documentary evidence is not available, the associated equipment or materials must be considered nonconforming in accordance with Section 5.2.14. Until suitable documentary evidence is available to show the equipment or material is in conformance, affected systems shall be considered inoperable and reliance shall not be placed on such systems to fulfill their intended safety functions. When equipment is ready to be returned to service, operating personnel shall place the equipment in operation and verify and document its functional acceptability, Attention shall be given to restoration of normal conditions, such as removal of jumpers or signals used in maintenance or testing or such as re turning valves, breakers or switches to proper start-up or operating positions from "test" or "manual" position". When placed into service the equipment should receive additional surveillance during the run-in period. (8) A plant system(s) or component(s) shall be made safe to work on after permission has been granted to remove it from service. Equipment and systems in a controlled status shall be clearly identified at any location where the equipment can be operated. Control room supervision shall be promptly informed of changes in equipment status, including temporary modifications, and the effects of such changes. Equipment, which is in other than normal condition, shouldbe readily identifiable to the operating staff. 5.2.6 Equipment Control(See Above) 5.2.6 Equipment Control(See Above) 
ANS 3.2 Side-By Side Comparison 7/25/2012 A list of typical lifetime records is included in ASME NQA-1-2008 and the NQA-1a-2009 addenda, Part III, Nonmandatory Appendix 17A-1, 200, List of Typical Lifetime Records [2], and should be       Nonmandatory considered for guidance purposes only. The list is not considered    Appendix 17A-1 will be to be all-inclusive and the nomenclature of these records may        endorsed through RG vary. For records not listed in Appendix 17A-1, the type of record 1.33 that most nearly describes the record in question should be followed with respect to its retention classification. The applicant or licensee itself shall ensure that it maintains sufficient records, both lifetime and nonpermanent, to furnish evidence of activities affecting quality The storage of QA records in electronic media shall be consistent    In accordance with with the intent of US NRC Regulatory Issue Summary (RIS) 2000-        NRC guidance.
18, Guidance on Managing Quality Assurance Records in Electronic Media, dated October 23, 2000 [4], and associated NIRMA Guidelines TG 11-1998 [5], TG15-1998 [6], TG16-1998
[7], and TG21-1998 [8]. The guidance of (RIS) 2000-18 shouldalso be applied to the record keeping and maintenance requirements in other parts of the regulations that accept the storage of records in the form of electronic media.
The use of optical disks for electronic records storage and           In accordance with retrieval systems shall comply with the USNRC guidance in            NRC guidance.
Generic Letter 88-18, "Plant Record Storage on Optical Disks." [9]
3.18. Audit Program Audit activities shall be controlled in accordance with ASME NQA-    Reference to NQA-1.
1-2008 and the NQA-1a-2009 addenda [2]. Audit frequencies and        Ok.
inclusion of functional areas for audit during the operational phase is a combination of quality criteria and management direction that are specific to the operation phase as described below.
3.18.1 Audit Frequency 61


ANS 3.2 Side-By Side Comparison           7/25/2012 59 (9) Temporary plant modifications shall be clearly identified at the installed location(s) and at any location of operation which could be affected by the temporary modification.
ANS 3.2 Side-By Side Comparison 7/25/2012 3.18.1.1 Regularly Scheduled Internal Audits Internal audits of activities conducted during the operational phase should be performed in such a manner that an audit of applicable QA program elements is completed for each functional area within a      Aligns with regulatory period of two years. Internal audits of activities conducted during the position in RG1.28 operational phase should be performed in such a manner that an audit of applicable QA program elements is completed for each functional area within a period of two years.
5.2.6 Equipment Control(See Above) 5.2.6 Equipment Control(See Above)
Internal audit frequencies of well established operational phase activities may be extended one year at a time beyond the above two year interval based on the results of an annual evaluation of the applicable functional area and objective evidence that the functional area activities are being satisfactorily accomplished. The evaluation shall include a detailed performance analysis of the functional area based upon applicable internal and external source data and due consideration of the impact of any functional area changes in responsibility, resources or management. The evaluation shall be considered a quality record and available for review by the regulator.
(10) When equipment is ready to be returned to service, operating personnel shall place the equipment in operation and verify and document its functional acceptability. Attention shall be given to restoration of normal conditions, such as removal of jumpers or signals used in maintenance or testing or returning valves, breakers or switches to proper startup or operating positions from "test" or "manual" positions. Steps shall be taken to ensure that all associated alarms and indications are returned to normal. 5.2.6 Equipment Control(See Above) 5.2.6 Equipment Control(See Above) (11) Proper alignment of equipment shall be independently verified by a second qualified person unless all equipment, valves, and switches involved in the activity can be proven to be in their correct alignment by functional testing without adversely affecting the safety of the plant. Another exception is where such verification would result in significant radiation exposure. The person who performs the verification of correct implementation of equipment control measures or proper alignment prior to returning equipment to service shall be qualified to perform such tasks for the particular system involved, and shall possess operating knowledge of the particular system  involved and its relationship to plant safety. Conditions to be considered in preparing equipment for maintenance include, for example: shutdown margin; method of emergency core cooling establishment of B path for decay heat removal; temperature and pressure of the system; valves between work and hazardous material; venting, draining, and flushing; entry into closed vessels; hazardous atmospheres handling hazardous materials; and electrical hazards. When entry into a closed system is required, control measures shall be established to prevent entry of extraneous material and to assure that foreign material is removed before the system is reclosed equipment, as necessary, to maintain personnel and reactor l entry and to avoid unauthorized operation of equipment. When equipment is, ready to be returned to service operating personnel shall place the equipment in operation and verify and document its functional acceptability. Attention shall be given to restoration of normal conditions, such as removal of jumpers or signals used in maintenance or testing or such as returning valves. breaker or switches to proper ,startup or operating positions from "test" or "manual" positions, and assuring that all alarms which are indicative of in  inoperative status are extinguished. For equipment important to safety, proper alignment shall be independently verified by a second qualified person unless all equipment, valves. and switches involved in the activity can be proven to be in their correct alignment by functional testing without adversely affecting the safety of the plant. A second inspection is where such verification would result. in significant radiation exposure. The person who performs the verification of correct implementation of equipment control measures or proper alignment prior to returning equipment to service  shall be qualified to perform such verification for the 
However, the internal audit frequency interval shall not exceed a maximum of four years. If an adverse trend is identified in the applicable functional area, the internal audit frequency extension should be rescinded and an audit scheduled as soon as practicable.
Internal audits shall include the following areas, along with the specific quality assurance program elements included in ASME NQA-1-2008 and the NQA-1a-2009 addenda [2] and the owner organizations QA program. The audits shall take into consideration applicable regulatory and license requirements, and associated record keeping.
(1) Compliance with and effectiveness of implementation (i.e.
performance) of internal rules and procedures, such as for operating, design, procurement, maintenance, modification, refueling, surveillance, and test activities.
(2) The conformance of facility operation to provisions contained within the Technical Specifications, including administrative controls and applicable license conditions.
(3) The performance, training, and qualification of the plant staff.
62


ANS 3.2 Side-By Side Comparison           7/25/2012 60 particular system involved, and  shall possess operating knowledge of the particular system (12) Equipment shouldreceive additional monitoring during an appropriate run-in period prior to being placed into service to perform its intended function. Final acceptance of equipment that is returned to service shall be made by the on-duty supervisor responsible for the unit. When placed into service the equipment should receive additional surveillance during the run-in period, 5.2.19.1. Preoperational TestsA component test is a functional, operational or performance test of an individual piece of equipment or unit system under prescribed conditions. Typical parameters to be examined are direction of rotation, bearing temperatures, vibration, time delays, and ability to operate with remote and local control. The procedure shall list checks to be made and provide acceptance criteria. Consideration should also be given to providing  run-in period to minimize early failures during operation of the plant. 3.15 Nonconforming Items  Nonconforming items shall be controlled in accordance with ASME NQA-1-2008 and the NQA-1a-2009 addenda [2].
ANS 3.2 Side-By Side Comparison 7/25/2012 (4) The Fire Protection Program and implementing procedures. The audit shall include an inspection of fire protection equipment and program implementation utilizing either a qualified off-site licensed fire protection engineer or an outside qualified fire protection consultant at least every two years. This audit is not subject to the extension of the audit intervals described above.
Essentially, equivalent to NQA- l. Ok.
(5) Corrective actions taken following abnormal occurrences.
3.16 Corrective Actions Corrective action activities shall be accomplished in accordance with ASME NQA-1-2008 and the NQA-1a-2009 addenda [2].
Essentially, equivalent to NQA- l. Ok.
3.17 Plant Records Management Quality assurance records shall be controlled in accordance with ASME NQA-1-2008 and the NQA-1a-2009 addenda [2].
Essentially, equivalent to NQA- l. Ok.
 
ANS 3.2 Side-By Side Comparison            7/25/2012 61 A list of typical lifetime records is included in ASME NQA-1-2008 and the NQA-1a-2009 addenda, Part III, Nonmandatory Appendix 17A-1, 200, List of Typical Lifetime Records [2], and should be considered for guidance purposes only. The list is not considered to be all-inclusive and the nomenclature of these records may vary. For records not listed in Appendix 17A-1, the type of record that most nearly describes the record in question should be followed with respect to its retention classification. The applicant or licensee itself shall ensure that it maintains sufficient records, both lifetime and nonpermanent, to furnish evidence of activities affecting quality Nonmandatory Appendix 17A-1 will be endorsed through RG
 
1.33    The storage of QA records in electronic media shall be consistent with the intent of US NRC Regulatory Issue Summary (RIS) 2000-18, "Guidance on Managing Quality Assurance Records in Electronic Media," dated October 23, 2000 [4], and associated NIRMA Guidelines TG 11-1998 [5], TG15-1998 [6], TG16-1998 [7], and TG21-1998 [8]. The guidance of (RIS) 2000-18 shouldalso be applied to the record keeping and maintenance requirements in other parts of the regulations t hat accept the storage of records in the form of electronic media.
In accordance with NRC guidance. 
 
The use of optical disks for electronic records storage and retrieval systems shall comply with the USNRC guidance in Generic Letter 88-18, "Plant Record Storage on Optical Disks." [9]
In accordance with NRC guidance. 
 
3.18. Audit Program Audit activities shall be controlled in accordance with ASME NQA-1-2008 and the NQA-1a-2009 addenda [2]. Audit frequencies and inclusion of functional areas for audit during the operational phase is a combination of quality criteria and management direction that are specific to the operation phase as described below.
Reference to NQA-1. Ok. 3.18.1 Audit Frequency
 
ANS 3.2 Side-By Side Comparison            7/25/2012 62 3.18.1.1 Regularly Scheduled Internal Audits Internal audits of activities conducted during the operational phase should be performed in such a manner that an audit of applicable QA program elements is completed for each functional area within a period of two years. Internal audits of activities conducted during the operational phase should be performed in such a manner that an audit of applicable QA program elements is completed for each functional area within a period of two years. Internal audit frequencies of well established operational phase activities may be extended one year at a time beyond the above two year interval based on the results of an annual evaluation of the applicable functional area and objective evidence that the functional area activities are being satisfactorily accomplished. The evaluation shall include a detailed performance analysis of the functional area based upon applicable internal and external source data and due consideration of the impact of any functional area changes in responsibility, resources or management. The evaluation shall be considered a quality record and available for review by the regulator. However, the internal audit frequency interval shall not exceed a maximum of four years. If an adverse trend is identified in the applicable functional area, the internal audit frequency extension should be rescinded and an audit scheduled as soon as practicable.
Aligns with regulatory position in RG1.28 Internal audits shall include the following areas, along with the specific quality assurance program elements included in ASME NQA-1-2008 and the NQA-1a-2009 addenda [2] and the owner organization's QA program. The audits shall take into consideration applicable regulatory and license requirements, and associated record keeping. (1) Compliance with and effectiveness of implementation (i.e. performance) of internal rules and procedures, such as for operating, design, procurement, maintenance, modification, refueling, surveillance, and test activities. (2) The conformance of facility operation to provisions contained within the Technical Specifications, including administrative controls and applicable license conditions. (3) The performance, training, and qualification of the plant staff.   
 
ANS 3.2 Side-By Side Comparison            7/25/2012 63 (4) The Fire Protection Program and implementing procedures. The audit shall include an inspection of fire protection equipment and program implementation utilizing either a qualified off-site licensed fire protection engineer or an outside qualified fire protection consultant at least every two years. This audit is not subject to the extension of the audit intervals described above. (5) Corrective actions taken following abnormal occurrences.
Periodic reviews of other important areas, such as plant security, emergency preparedness, and radiation protection, may be conducted through internal audits.
Periodic reviews of other important areas, such as plant security, emergency preparedness, and radiation protection, may be conducted through internal audits.
3.18.1.2 Regularly Scheduled External Audits External audits, e.g., supplier audits, should be performed on a triennial basis and supplemented by annual evaluations of the supplier's performance. A continuous or ongoing evaluation of the supplier's performance may be conducted in lieu of the annual evaluations provided that the results are reviewed in order to determine if corrective action is required. Aligns with regulatory position in RG1.28 If more than one purchaser utilizes a supplier, the purchaser may arrange for an audit of the supplier on behalf of itself and the other purchasers to reduce the number of external supplier audits. The scope of the audit should address the needs of all purchasers and the report shouldbe distributed to purchasers for whom the audit    
3.18.1.2 Regularly Scheduled External Audits External audits, e.g., supplier audits, should be performed on a       Aligns with regulatory triennial basis and supplemented by annual evaluations of the         position in RG1.28 suppliers performance. A continuous or ongoing evaluation of the suppliers performance may be conducted in lieu of the annual evaluations provided that the results are reviewed in order to determine if corrective action is required.
If more than one purchaser utilizes a supplier, the purchaser may arrange for an audit of the supplier on behalf of itself and the other purchasers to reduce the number of external supplier audits. The scope of the audit should address the needs of all purchasers and the report shouldbe distributed to purchasers for whom the audit 63


ANS 3.2 Side-By Side Comparison           7/25/2012 64 was conducted.
ANS 3.2 Side-By Side Comparison 7/25/2012 was conducted.
Each purchaser relying on the results of such an audit remains individually responsible for the adequacy of the audit and for its use by their organization.
Each purchaser relying on the results of such an audit remains individually responsible for the adequacy of the audit and for its use by their organization.
4.0 References   The user is advised to review each of the following references to determine whether it, a more recent version, or a replacement document is the most pertinent for each application. When alternate documents are used, the user is advised to document this decision and its basis.
4.0 References The user is advised to review each of the following references to determine whether it, a more recent version, or a replacement document is the most pertinent for each application. When alternate documents are used, the user is advised to document this decision and its basis.
[1] Title 10, Code of Federal Regulations, Part 50, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants"
[1] Title 10, Code of Federal Regulations, Part 50, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants
[2] American National Standard ANSI/ASME NQA-1-2008 with NQA-1a-2009 Addenda, "Quality Assurance Requirements for Facility Application"
[2] American National Standard ANSI/ASME NQA           2008 with NQA-1a-2009 Addenda, Quality Assurance Requirements for Facility Application
[3] USNRC Regulatory Guide 1.8, Rev. 3 (May 2000), "Qualification and Training of Personnel for Nuclear Power Plants."
[3] USNRC Regulatory Guide 1.8, Rev. 3 (May 2000),
[4] Regulatory Issue Summary (RIS) 2000-18, "Guidance on Managing Quality Assurance Records in Electronic Media," dated October 23, 2000
Qualification and Training of Personnel for Nuclear Power Plants.
[5] Nuclear Information and Records Management Association, Inc. (NIRMA) Technical Guide (TG), TG 11-1998, "Authentication of Records and Media"
[4] Regulatory Issue Summary (RIS) 2000-18, Guidance on Managing Quality Assurance Records in Electronic Media, dated October 23, 2000
[6] NIRMA TG15-1998, "Management of Electronic Records"
[5] Nuclear Information and Records Management Association, Inc. (NIRMA) Technical Guide (TG), TG 11-1998, Authentication of Records and Media
[7] NIRMA TG16-1998, "Software Configuration management and Quality Assurance"   
[6] NIRMA TG15-1998, Management of Electronic Records
[7] NIRMA TG16-1998, Software                 Configuration management and Quality Assurance 64


ANS 3.2 Side-By Side Comparison           7/25/2012 65  APPENDIX A TYPICAL PROCEDURES FOR PRESSURIZED WATER REACTORS AND BOILING WATER REACTORS The following are typical activities that affect safe operations and/or the quality of SSCs that should be covered by written p rocedures. This appendix is not intended as an inclusive listing of all needed procedures since many other activities carried out during the op eration phase of nuclear power plants should be covered by procedures not included in this list.
ANS 3.2 Side-By Side Comparison 7/25/2012
: 1. Administrative Procedures a Authorities and Responsibilities for Safe Operation and shutdown b. Equipment Control (e.g., locking and tagging)
[8] NIRMA TG21-1998, Electronic Records Protection and Restoration
[9] USNRC Guidance in Generic Letter 88-18, Plant Record Storage Optical Disks.
APPENDIX A TYPICAL PROCEDURES FOR PRESSURIZED WATER REACTORS AND BOILING WATER REACTORS The following are typical activities that affect safe operations and/or the quality of SSCs that should be covered by written procedures. This appendix is not intended as an inclusive listing of all needed procedures since many other activities carried out during the operation phase of nuclear power plants should be covered by procedures not included in this list.
: 1. Administrative Procedures a Authorities and Responsibilities for Safe Operation and shutdown
: b. Equipment Control (e.g., locking and tagging)
: c. Procedure Adherence and Temporary Change Method
: c. Procedure Adherence and Temporary Change Method
: d. Procedure Review and Approval
: d. Procedure Review and Approval
: e. Schedule for Surveillance Tests and Calibration
: e. Schedule for Surveillance Tests and Calibration
: f. Shift and Relief Turnover
: f. Shift and Relief Turnover
: g. Log Entries, Record Retention, and Review procedures
: g. Log Entries, Record Retention, and Review procedures 65
[8] NIRMA TG21-1998, "Electronic Records Protection and Restoration"
[9] USNRC Guidance in Generic Letter 88-18, "Plant Record Storage Optical Disks."


ANS 3.2 Side-By Side Comparison           7/25/2012 66 h. Access to Containment
ANS 3.2 Side-By Side Comparison 7/25/2012
: h. Access to Containment
: i. Bypass of Safety Functions and Jumper (temporary modification) Control
: i. Bypass of Safety Functions and Jumper (temporary modification) Control
: j. Maintenance of Minimum Shift Complement and call-in of personnel k. Plant Fire Protection Program
: j. Maintenance of Minimum Shift Complement and call-in of personnel
: k. Plant Fire Protection Program
: l. Communication System Procedures
: l. Communication System Procedures
: m. Core Design and Configuration
: m. Core Design and Configuration
: 2. General Plant Operating Procedures a. Cold Shutdown to Hot Standby
: 2. General Plant Operating Procedures
: b. Hot Standby to Minimum Load (nuclear startup). c. Recovery from Reactor Trip
: a. Cold Shutdown to Hot Standby
: b. Hot Standby to Minimum Load (nuclear startup).
: c. Recovery from Reactor Trip
: d. Operation at Hot Standby
: d. Operation at Hot Standby
: e. Turbine Startup and Synchronization of Generator
: e. Turbine Startup and Synchronization of Generator
Line 421: Line 549:
: i. Plant Shutdown to Hot Standby
: i. Plant Shutdown to Hot Standby
: j. Hot Standby to Cold Shutdown
: j. Hot Standby to Cold Shutdown
: k. Preparation for Refueling and Refueling Equipment Operation
: k. Preparation for Refueling and Refueling Equipment Operation 66
 
ANS 3.2 Side-By Side Comparison            7/25/2012 67 I. Refueling and Core Alterations
: 3. Procedures for Startup, Operation, and Shutdown of Safety-Related PWR Systems


Instructions for energizing, filling, venting, draining, startup, shutdown, and changing modes of operation should be prepared, as appropriate, for the following systems: a. Reactor Coolant System b. Control Rod Drive System (including part-length rods).
ANS 3.2 Side-By Side Comparison 7/25/2012 I. Refueling and Core Alterations
: 3. Procedures for Startup, Operation, and Shutdown of Safety-Related PWR Systems Instructions for energizing, filling, venting, draining, startup, shutdown, and changing modes of operation should be prepared, as appropriate, for the following systems:
: a. Reactor Coolant System
: b. Control Rod Drive System (including part-length rods).
: c. Shutdown Cooling System
: c. Shutdown Cooling System
: d. Emergency Core Cooling System
: d. Emergency Core Cooling System
: e. Component Cooling Water System
: e. Component Cooling Water System
: f. Containment   (1) Maintaining Containment Integrity (2) Special Containment Systems (a) Atmosphere (b) Subatmospheric (c) Double-Wall Containment with Controlled Interspace (d) Ice Condenser (3) Containment Ventilation System (4) Containment Cooling System
: f. Containment (1) Maintaining Containment Integrity (2) Special Containment Systems (a) Atmosphere (b) Subatmospheric (c) Double-Wall Containment with Controlled Interspace (d) Ice Condenser (3) Containment Ventilation System (4) Containment Cooling System 67


ANS 3.2 Side-By Side Comparison           7/25/2012 68 g. Atmosphere Cleanup Systems h. Fuel Storage Pool Purification and Cooling System
ANS 3.2 Side-By Side Comparison 7/25/2012
: g. Atmosphere Cleanup Systems
: h. Fuel Storage Pool Purification and Cooling System
: i. Main Steam System
: i. Main Steam System
: j. Pressurizer Pressure and Spray Control Systems
: j. Pressurizer Pressure and Spray Control Systems
Line 439: Line 569:
: m. Service Water System
: m. Service Water System
: n. Chemical and Volume Control System (including Letdown/Purification System)
: n. Chemical and Volume Control System (including Letdown/Purification System)
: 0. Auxiliary or Reactor Building Heating and Ventilation p. Control Room Heating and Ventilation q. Radwaste Building Heating and Ventilation
: 0. Auxiliary or Reactor Building Heating and Ventilation
: p. Control Room Heating and Ventilation
: q. Radwaste Building Heating and Ventilation
: r. Instrument Air System
: r. Instrument Air System
: s. Electrical System (1) Offsite (access circuits)  
: s. Electrical System (1) Offsite (access circuits)
 
(2) Onsite (a) Emergency Power Sources (e.g., diesel generator, batteries)
(2) Onsite (a) Emergency Power Sources (e.g., diesel generator, batteries) (b) A.C. System (c) D.C. System t. Nuclear Instrument System
(b) A.C. System (c) D.C. System
 
: t. Nuclear Instrument System 68
ANS 3.2 Side-By Side Comparison            7/25/2012 69 (1) Source Range (2) Intermediate Range
 
(3) Power Range


(4) Incore System u Reactor Control and Protection System
ANS 3.2 Side-By Side Comparison 7/25/2012 (1) Source Range (2) Intermediate Range (3) Power Range (4) Incore System u Reactor Control and Protection System
: v. Hydrogen Recombiner
: v. Hydrogen Recombiner
: 4. Procedure for Startup, Operation, and Shutdown of Safety-Related BWR Systems Instructions for energizing, filling, venting, draining, startup, shutdown, and changing modes of operation should be prepared, as appropriate, for the following systems: a. Nuclear Steam Supply System (Vessel and Recirculating System)
: 4. Procedure for Startup, Operation, and Shutdown of Safety-Related BWR Systems Instructions for energizing, filling, venting, draining, startup, shutdown, and changing modes of operation should be prepared, as appropriate, for the following systems:
: a. Nuclear Steam Supply System (Vessel and Recirculating System)
: b. Control Rod Drive System
: b. Control Rod Drive System
: c. Reactor Cleanup System
: c. Reactor Cleanup System
Line 457: Line 587:
: e. Shutdown Cooling and Reactor Vessel Head Spray System
: e. Shutdown Cooling and Reactor Vessel Head Spray System
: f. High Pressure Coolant Injection
: f. High Pressure Coolant Injection
: g. Reactor Core Isolation Cooling System/Isolation Condenser h. Emergency Core Cooling Systems
: g. Reactor Core Isolation Cooling System/Isolation Condenser
: h. Emergency Core Cooling Systems
: i. Closed Cooling Water System
: i. Closed Cooling Water System
: j. Containment
: j. Containment 69


ANS 3.2 Side-By Side Comparison           7/25/2012 70 (1) Maintaining Integrity (2) Containment Cooling and Ventilation System (3) Inerting and deinerting k. Fuel Storage Pool Purification and Cooling System
ANS 3.2 Side-By Side Comparison 7/25/2012 (1) Maintaining Integrity (2) Containment Cooling and Ventilation System (3) Inerting and deinerting
: k. Fuel Storage Pool Purification and Cooling System
: l. Main Steam System (reactor vessel to turbine)
: l. Main Steam System (reactor vessel to turbine)
: m. Turbine-Generator System
: m. Turbine-Generator System
: n. Condensate System (hotwell to feedwater pumps, including demineralizers and resin regeneration)
: n. Condensate System (hotwell to feedwater pumps, including demineralizers and resin regeneration)
: o. Feedwater System (feedwater pumps to reactor vessel) p. Makeup System (filtration, purification, and water transfer) q. Service Water System r. Reactor Building Heating and Ventilation Systems
: o. Feedwater System (feedwater pumps to reactor vessel)
: p. Makeup System (filtration, purification, and water transfer)
: q. Service Water System
: r. Reactor Building Heating and Ventilation Systems
: s. Control Room Heating and Ventilation Systems
: s. Control Room Heating and Ventilation Systems
: t. Radwaste Building Heating and Ventilation Systems
: t. Radwaste Building Heating and Ventilation Systems
: u. Standby Gas Treatment System
: u. Standby Gas Treatment System
: v. Instrument Air System
: v. Instrument Air System
: w. Electrical System (1) Offsite (access circuits)   (2) Onsite (a) Emergency Power Sources (e.g., diesel generator, batteries)
: w. Electrical System (1) Offsite (access circuits)
 
(2) Onsite (a) Emergency Power Sources (e.g., diesel generator, batteries) 70
ANS 3.2 Side-By Side Comparison            7/25/2012 71 (b) A.C. System (c) D.C. System x. Nuclear Instrument System (1) Source Range


(2) Intermediate Range  
ANS 3.2 Side-By Side Comparison 7/25/2012 (b) A.C. System (c) D.C. System
 
: x. Nuclear Instrument System (1) Source Range (2) Intermediate Range (3) Power Range (4) TIP System
(3) Power Range (4) TIP System y. Reactor Protection System
: y. Reactor Protection System
: z. Rod Worth Minimizer
: z. Rod Worth Minimizer
: 5. Procedures for Abnormal, Offnormal, or Alarm Conditions Since these procedures are numerous and correspond to the number of alarm annunciators, the procedures are not individually listed. Each safety-related annunciator should have its own written procedure, which should normally contain (1) the meaning of the annunciator, (2) the source of the signal, (3) the immediate action that is to occur automatically, (4) the immediate operation action, and (5) the long-range actions.
: 5. Procedures for Abnormal, Offnormal, or Alarm Conditions Since these procedures are numerous and correspond to the number of alarm annunciators, the procedures are not individually listed. Each safety-related annunciator should have its own written procedure, which should normally contain (1) the meaning of the annunciator, (2) the source of the signal, (3) the immediate action that is to occur automatically, (4) the immediate operation action, and (5) the long-range actions.
: 6. Procedures for Combating Emergencies and Other Significant Events a. Loss of Coolant (including significant PWR steam generator leaks) (inside and outside primary containment) (large and small, including leak-rate determination) b. Loss of Instrument Air
: 6. Procedures for Combating Emergencies and Other Significant Events
: a. Loss of Coolant (including significant PWR steam generator leaks) (inside and outside primary containment) (large and small, including leak-rate determination)
: b. Loss of Instrument Air 71


ANS 3.2 Side-By Side Comparison           7/25/2012 72 c. Loss of Electrical Power (and/or degraded power sources) d. Loss of Core Coolant Flow
ANS 3.2 Side-By Side Comparison 7/25/2012
: c. Loss of Electrical Power (and/or degraded power sources)
: d. Loss of Core Coolant Flow
: e. Loss of Condenser Vacuum
: e. Loss of Condenser Vacuum
: f. Loss of Containment Integrity
: f. Loss of Containment Integrity
Line 488: Line 626:
: i. Loss of Component Cooling System and Cooling to Individual Components.
: i. Loss of Component Cooling System and Cooling to Individual Components.
: j. Loss of Feedwater or Feedwater System Failure
: j. Loss of Feedwater or Feedwater System Failure
: k. Loss of Protective System Channel l. Mispositioned Control Rod or Rods (and rod drops) m. Inability to Drive Control Rods
: k. Loss of Protective System Channel
: l. Mispositioned Control Rod or Rods (and rod drops)
: m. Inability to Drive Control Rods
: n. Conditions Requiring Use of Emergency Boration or Standby Liquid Control System
: n. Conditions Requiring Use of Emergency Boration or Standby Liquid Control System
: o. Fuel Cladding Failure or High Activ ity in Reactor Coolant or Offgas p. Fire in Control Room or Forced Evacuation of Control Room
: o. Fuel Cladding Failure or High Activity in Reactor Coolant or Offgas
: p. Fire in Control Room or Forced Evacuation of Control Room
: q. Turbine and Generator Trips
: q. Turbine and Generator Trips
: r. Other Expected Transients that may be Applicable
: r. Other Expected Transients that may be Applicable
: s. Malfunction of Automatic Reactivity Control System
: s. Malfunction of Automatic Reactivity Control System
: t. Malfunction of Pressure Control System
: t. Malfunction of Pressure Control System
: u. Reactor Trip
: u. Reactor Trip 72


ANS 3.2 Side-By Side Comparison           7/25/2012 73 v. Plant Fires w. Acts of Nature (e.g., tornado, flood, dam failure, earthquakes) x. Irradiated Fuel Damage While Refueling
ANS 3.2 Side-By Side Comparison 7/25/2012
: v. Plant Fires
: w. Acts of Nature (e.g., tornado, flood, dam failure, earthquakes)
: x. Irradiated Fuel Damage While Refueling
: y. Abnormal Releases of Radioactivity
: y. Abnormal Releases of Radioactivity
: z. Intrusion of Demineralizer Resin Into Primary System (BWR Plants)
: z. Intrusion of Demineralizer Resin Into Primary System (BWR Plants)
: 7. Procedures for Control of Radioactivity (For limiting materials released to environment and limiting personnel exposure) a. Liquid Radioactive Waste System (1) Collection, Demineralizing, Filtering, Evaporating and Concentrating, And Neutralizing (2) Sampling and Monitoring (3) Discharging to Effluents b. Solid Waste System (1) Spent Resins and Filter Sludge Handling  
: 7. Procedures for Control of Radioactivity (For limiting materials released to environment and limiting personnel exposure)
: a. Liquid Radioactive Waste System (1) Collection, Demineralizing, Filtering, Evaporating and Concentrating, And Neutralizing (2) Sampling and Monitoring (3) Discharging to Effluents
: b. Solid Waste System (1) Spent Resins and Filter Sludge Handling (2) Baling Machine Operation (3) Drum Handling and Storage
: c. PWR Gaseous Effluent System (1) Collection, Storage, and Discharge (2) Sampling and Monitoring (3) Air Ejector and Stack Monitoring 73


(2) Baling Machine Operation (3) Drum Handling and Storage c. PWR Gaseous Effluent System (1) Collection, Storage, and Discharge
ANS 3.2 Side-By Side Comparison 7/25/2012 (4) Ventilation Air Monitoring
: d. BWR Air Extraction. Offgas Treatment. and Other Gaseous Effluent Systems (1) Mechanical Vacuum Pump Operation (2) Air Ejector Operation (3) Packing Steam Exhauster Operation (4) Sampling (5) Air Ejector, Ventilation, and Stack Monitor
: e. Radiation Protection Procedures (1) Access Control to Radiation Areas Includ1ing a Radiation Work Permit System (2) Radiation Surveys (3) Airborne Radioactivity Monitoring (4) Contamination Control (5) Respiratory Protection (6)Training in Radiation Protection (7) Personnel Monitoring (8) Bioassay Program (9) Implementation of ALARA Program
: f. Area Radiation Monitoring System Operation
: g. Process Radiation Monitoring System 74


(2) Sampling and Monitoring (3) Air Ejector and Stack Monitoring 
ANS 3.2 Side-By Side Comparison 7/25/2012
: h. Meteorological Monitoring Operation
: 8. Procedures for Control of Measuring and Test Equipment and for Surveillance Tests, Procedures. and Calibrations
: a. Procedures of a type appropriate to the circumstances should be provided to ensure that tools, gauges, Instruments, controls, and other measuring and testing devices are properly controlled, calibrated. and adjusted at specified periods to maintain accuracy. Specific examples of such equipment to be calibrated and tested are readout instruments. Interlock permissive and prohibit circuits, alarm devices, sensors. signal conditioners, controls, protective circuits. and laboratory equipment.
: b. Specific procedures for surveillance tests, inspections, and calibrations should be written (implementing procedures are required for each surveillance test. inspection. or calibration listed in the technical specifications):
(1) Pressurized Water Reactors (a) Containment Leak-Rate Tests (b) Containment Isolation Tests (c) Containment Local Leak Detection Tests (d) Containment Heat and Radioactivity Removal Systems Tests (e) Containment Tendon Tests and Inspections (f) Service Water System Functional Tests (g) Main Steam Isolation Valve Tests (h) Fire Protection System Functional Tests (i) Boric Acid Tanks-Level Instrumentation Calibrations (j) Emergency Core Cooling System Tests (k) Control Rod Operability and Scram Time Tests (l) Reactor Protection System Tests and Calibrations 75


ANS 3.2 Side-By Side Comparison           7/25/2012 74 (4) Ventilation Air Monitoring d. BWR Air Extraction. Offgas Treatment. and Other Gaseous Effluent Systems (1) Mechanical Vacuum Pump Operation
ANS 3.2 Side-By Side Comparison 7/25/2012 (m) Permissive-Tests and Calibrations (n) Refueling System Circuit Tests (o) Emergency Boration System Functional Tests (p) DNB Checks and Incore-Excore Flux Monitor Correlations (q) Emergency Power Tests (r) Auxiliary Feedwater System Tests (s) NSSS Pressurization and Leak Detection (t) Inspection of Reactor Coolant System Pressure Boundary (u) Inspection of Pipe Hanger Settings (v) Control Rod Drive System Functional Tests (w) Heat Balance-Flux Monitor Calibrations (x) Pressurizer and Main Steam Safety Valve Tests (y) Leak Detection Systems Tests (z) Axial and Radial Flux Pattern Determinations (aa) Area, Portable, and Airborne Radiation Monitor Calibrations (bb) Process Radiation Monitor Calibrations (cc) Environmental Monitor Calibrations (dd) Safety Valve Tests (ee) Turbine Overspeed Trip Tests 76


(2) Air Ejector Operation (3) Packing Steam Exhauster Operation (4) Sampling
ANS 3.2 Side-By Side Comparison 7/25/2012 (ff) Water Storage Tanks-Level Instrumentation Calibration (2) Boiling Water Reactors (a) Containment Leak-Rate and Penetration Leak-Rate Tests (b) Containment Isolation Tests (c) Containment Vacuum Relief Valve Tests (d) Containment Spray System Tests (el Standby Gas Treatment System Tests (including filter tests) \
(f) Service Water System Functional Tests (g) Main Steam Isolation Valve Tests (h) Fire Protection System Functional Tests (i) Nitrogen Inerting System Tests (j) Emergency Core Cooling System Tests (k) Control Rod Operability and Scram Time Tests (l) Reactor Protection System Tests and Calibrations (m) Rod Blocks-Tests and Calibrations (n) Refueling System Circuit Tests (o) Liquid Poison System Tests (p) Minimum Critical Heat Flux Checks and Incore Flux Monitor Calibrations (q) Emergency Power Tests 77


(5) Air Ejector, Ventilation, and Stack Monitor e. Radiation Protection Procedures    (1) Access Control to Radiation Areas Includ1ing a Radiation Work Permit System  (2) Radiation Surveys  (3) Airborne Radioactivity Monitoring (4) Contamination Control
ANS 3.2 Side-By Side Comparison 7/25/2012 (r) Isolation Condenser or RCIC Tests (s) NSSS Pressurization and Leak Detection (t) Inspection of Reactor Coolant System Pressure Boundary (u) Inspection of Pipe Hanger Settings (v) Control Rod Drive System Functional Tests (w) Heat Balance (x) Auto blowdown System Tests (y) Leak Detection System Tests (z) Axial and Radial Flux Pattern Determinations (aa) Area, Portable, and Airborne Radiation Monitor Calibrations (bb) Process Radiation Monitor Calibrations I (cc) Environmental Monitor Calibrations (dd) Safety Valve Tests (ee) Turbine Overspeed Trip Test (ff) Water Storage Tanks-Level Instrumentation Calibrations (gg) Reactor Building Inleakage Tests
: 9. Procedures for Performing Maintenance
: a. Maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. Skills normally possessed by qualified maintenance personnel 78


(5) Respiratory Protection (6)Training in Radiation Protection (7) Personnel Monitoring (8) Bioassay Program (9) Implementation of ALARA Program f. Area Radiation Monitoring System Operation g. Process Radiation Monitoring System 
ANS 3.2 Side-By Side Comparison 7/25/2012 may not require detailed step-by-step delineation in a procedure. The following types of activities are among those that may not require detailed step-by-step written procedures:
 
(1) Gasket Replacement (2) Trouble-Shooting Electrical Circuits (3) Changing Chart or Drive Speed Gears or Slide Wires on Recorders
ANS 3.2 Side-By Side Comparison            7/25/2012 75 h. Meteorological Monitoring Operation
: 8. Procedures for Control of Measuring and Test Equipment and for Surveillance Tests, Procedures. and Calibrations a. Procedures of a type appropriate to the circumstances should be provided to ensure that tools, gauges, Instruments, controls, and other measuring and testing devices are properly controlled, calibrated. and adjusted at specified periods to maintain accuracy. Specific examples of such equipment to be calibrated and tested are readout instruments. Interlock permissive and prohibit circuits, alarm devices, sensors. signal conditioners, controls, protective circuits. and laboratory equipment.
: b. Specific procedures for surveillance tests, inspections, and calibrations should be written (implementing procedures are req uired for each surveillance test. inspection. or calibration listed in the technical specifications): (1) Pressurized Water Reactors (a) Containment Leak-Rate Tests (b) Containment Isolation Tests (c) Containment Local Leak Detection Tests (d) Containment Heat and Radioactivity Removal Systems Tests (e) Containment Tendon Tests and Inspections (f)  Service Water System Functional Tests (g) Main Steam Isolation Valve Tests (h) Fire Protection System Functional Tests (i) Boric Acid Tanks-Level Instrumentation Calibrations (j) Emergency Core Cooling System Tests (k) Control Rod Operability and Scram Time Tests (l) Reactor Protection System Tests and Calibrations 
 
ANS 3.2 Side-By Side Comparison           7/25/2012 76 (m) Permissive-Tests and Calibrations (n) Refueling System Circuit Tests (o) Emergency Boration System Functional Tests (p) DNB Checks and Incore-Excore Flux Monitor Correlations (q) Emergency Power Tests (r) Auxiliary Feedwater System Tests (s) NSSS Pressurization and Leak Detection (t) Inspection of Reactor Coolant System Pressure Boundary (u) Inspection of Pipe Hanger Settings (v) Control Rod Drive System Functional Tests (w) Heat Balance-Flux Monitor Calibrations (x) Pressurizer and Main Steam Safety Valve Tests (y) Leak Detection Systems Tests (z) Axial and Radial Flux Pattern Determinations (aa) Area, Portable, and Airborne Radiation Monitor Calibrations (bb) Process Radiation Monitor Calibrations (cc) Environmental Monitor Calibrations (dd) Safety Valve Tests (ee) Turbine Overspeed Trip Tests 
 
ANS 3.2 Side-By Side Comparison            7/25/2012 77 (ff) Water Storage Tanks-Level Instrumentation Calibration (2) Boiling Water Reactors (a) Containment Leak-Rate and Penetration Leak-Rate Tests (b) Containment Isolation Tests (c) Containment Vacuum Relief Valve Tests (d) Containment Spray System Tests (el Standby Gas Treatment System Tests (including filter tests) \
(f) Service Water System Functional Tests (g) Main Steam Isolation Valve Tests (h) Fire Protection System Functional Tests (i) Nitrogen Inerting System Tests (j) Emergency Core Cooling System Tests (k) Control Rod Operability and Scram Time Tests (l) Reactor Protection System Tests and Calibrations (m) Rod Blocks-Tests and Calibrations (n) Refueling System Circuit Tests (o) Liquid Poison System Tests (p) Minimum Critical Heat Flux Checks and Incore Flux Monitor Calibrations (q) Emergency Power Tests 
 
ANS 3.2 Side-By Side Comparison            7/25/2012 78 (r) Isolation Condenser or RCIC Tests (s) NSSS Pressurization and Leak Detection (t) Inspection of Reactor Coolant System Pressure Boundary (u) Inspection of Pipe Hanger Settings (v) Control Rod Drive System Functional Tests (w) Heat Balance (x) Auto blowdown System Tests (y) Leak Detection System Tests (z) Axial and Radial Flux Pattern Determinations (aa) Area, Portable, and Airborne Radiation Monitor Calibrations (bb) Process Radiation Monitor Calibrations I (cc) Environmental Monitor Calibrations (dd) Safety Valve Tests (ee) Turbine Overspeed Trip Test (ff) Water Storage Tanks-Level Instrumentation Calibrations (gg) Reactor Building Inleakage Tests
: 9. Procedures for Performing Maintenance a. Maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accor dance with written procedures, documented instructions, or drawings appropriate to the circumstances. Skills normally possessed by qualified maint enance personnel 
 
ANS 3.2 Side-By Side Comparison            7/25/2012 79 may not require detailed step-by-step delineation in a procedure. The following types of activities are among those that may no t require detailed step-by-step written procedures: (1) Gasket Replacement (2) Trouble-Shooting Electrical Circuits (3) Changing Chart or Drive Speed Gears or Slide Wires on Recorders
: b. Preventive maintenance schedules should be developed to specify lubrication schedules, inspections of equipment, replacement of such items as filters and strainers, and inspection or replacement of parts that have a specific lifetime such as wear rings.
: b. Preventive maintenance schedules should be developed to specify lubrication schedules, inspections of equipment, replacement of such items as filters and strainers, and inspection or replacement of parts that have a specific lifetime such as wear rings.
: c. Procedures for the repair or replacement of equipment should be prepared prior to beginning work. Such procedures for major equipment that is expected to be repaired or replaced during the life of the plan t should preferably be written early in plant life. The following are examples of such procedures for major equipment: (1) Repair of PWR Steam Generator Tubes (2) Replacement and Repair of Control Rod Drives (3) Replacement of Recirculation Pump Seals (4) Replacement of Important Strainers and Filters (5) Repair or Replacement of Safety Valves (6) Repair of Incore Flux Monitoring System (7) Replacement of Neutron Detectors  
: c. Procedures for the repair or replacement of equipment should be prepared prior to beginning work. Such procedures for major equipment that is expected to be repaired or replaced during the life of the plant should preferably be written early in plant life. The following are examples of such procedures for major equipment:
 
(1) Repair of PWR Steam Generator Tubes (2) Replacement and Repair of Control Rod Drives (3) Replacement of Recirculation Pump Seals (4) Replacement of Important Strainers and Filters (5) Repair or Replacement of Safety Valves (6) Repair of Incore Flux Monitoring System (7) Replacement of Neutron Detectors 79
ANS 3.2 Side-By Side Comparison            7/25/2012 80 d. Procedures that could be categorized either as maintenance or operating procedures should be developed for the following activi ties. Instructions for these activities may be included in systems procedures. (1) Exercise of equipment that is normally idle (2) Draining and Refilling Heat Exchangers (3) Draining and Refilling Recirculation Loop (4) Draining and Refilling the Reactor Vessel (5) Draining and Refilling Steam Generators (6) Removal of Reactor Head (7) Disconnection and Reconnection of Wiring Penetrating Reactor Vessel Head (8) Demineralizer Resin Regeneration or Replacement e. General procedures for the control of maintenance, repair, replacement, and modification work should be prepared before reac tor operation is begun. These procedures should include information on areas such as the following: (1) Method for obtaining permission and clearance for operation personnel to work and for logging such work and (2) Factors to be taken into account, including the necessity for minimizing radiation exposure to workmen, in preparing the de tailed work procedures but that must operate when required 10. Chemical and Radiochemical Control Procedures


Chemical and radiochemical control procedures should be written to prescribe the nature and frequency of sampling and analyses, the instructions maintaining water quality within prescribed limits, and the limitations on concentrations of agents that may cause corrosive attack or fouling of heat-transfer surfaces or that may become sources of radiation hazards due to activation. These procedures should specify laboratory instructions and calibration of laboratory equipment. Extreme importance must be placed on laboratory procedures used to determine
ANS 3.2 Side-By Side Comparison 7/25/2012
: d. Procedures that could be categorized either as maintenance or operating procedures should be developed for the following activities. Instructions for these activities may be included in systems procedures.
(1) Exercise of equipment that is normally idle (2) Draining and Refilling Heat Exchangers (3) Draining and Refilling Recirculation Loop (4) Draining and Refilling the Reactor Vessel (5) Draining and Refilling Steam Generators (6) Removal of Reactor Head (7) Disconnection and Reconnection of Wiring Penetrating Reactor Vessel Head (8) Demineralizer Resin Regeneration or Replacement
: e. General procedures for the control of maintenance, repair, replacement, and modification work should be prepared before reactor operation is begun. These procedures should include information on areas such as the following:
(1) Method for obtaining permission and clearance for operation personnel to work and for logging such work and (2) Factors to be taken into account, including the necessity for minimizing radiation exposure to workmen, in preparing the detailed work procedures but that must operate when required
: 10. Chemical and Radiochemical Control Procedures Chemical and radiochemical control procedures should be written to prescribe the nature and frequency of sampling and analyses, the instructions maintaining water quality within prescribed limits, and the limitations on concentrations of agents that may cause corrosive attack or fouling of heat-transfer surfaces or that may become sources of radiation hazards due to activation. These procedures should specify laboratory instructions and calibration of laboratory equipment. Extreme importance must be placed on laboratory procedures used to determine 80


ANS 3.2 Side-By Side Comparison           7/25/2012 81 concentration and species of radioactivity in liquids and gases prior to release including representative sampling, validity of calibration techniques, and adequacy of analysis.}}
ANS 3.2 Side-By Side Comparison 7/25/2012 concentration and species of radioactivity in liquids and gases prior to release including representative sampling, validity of calibration techniques, and adequacy of analysis.
81}}

Latest revision as of 21:51, 11 November 2019

ANS 3.2 Comp Side-By-Side 25
ML12276A076
Person / Time
Issue date: 02/04/2013
From:
Division of Nuclear Materials Safety III
To:
Rodriguez-Luccioni H
Shared Package
ML12276A061 List:
References
DG-1300
Download: ML12276A076 (81)
v • d • e


Text

ANS 3.2 Side-By Side Comparison Proposed ANS 3.2 Wording 7/25/2012 Staff American National Standard ANSI/ANS 3.2-2012 Comments/COLP Wording from ANS 3.2 1976 Wording from ANS 3.2 1982 Administrative Controls for the Operational Phase of Nuclear Verification power Plants

1. Scope, Applicability and Purpose 1.1 Scope and Applicability.

This standard provides requirements and recommendations for This Standard is intended to be consistent managerial and administrative controls to ensure that activities with applicable criteria for quality associated with operating a nuclear power plant are carried out assurance, including those given in Title without undue risk to the health and safety of the public. 10, Code of Federal Regulations, Part 50, "Licensing of Production and Utilization This standard provides requirements for implementing Facilities," Appendix B. [1]1 managerial and administrative controls consistent with requirements of 10 CFR 50, Appendix B [1].1 This standard is not specifically intended for application to test, mobile, experimental reactors, nor reactors not subject to U.S.

Nuclear Regulatory Commission licensing. Although the standard is based on USNRC requirements the approach is applicable with modifications to reflect the regulatory requirements in the country of application. Applicable sections of this standard may be used in those cases for activities similar to those addressed herein.

1.2 Purpose.

This standard contains requirements for managerial and This Standard fully and completely administrative controls for nuclear power plants during the describes the general requirements and operational phase of plant life. This phase is generally considered guidelines of American National Standard to commence prior to initial fuel loading at a time identified by the Quality Assurance Program Requirements owner organization. Certain initial construction activities may for Nuclear Power Plants, N45.2-1971, [2]

extend past fuel loading and certain operational activities may as those requirements and guidelines take place prior to fuel loading. The owner organization is apply during the operational phase of plant expected to identify those activities that are included in these life.

overlapping time periods and are expected to specify whether the 1

Numbers in brackets refer to corresponding numbers in Sec. 4, References.

1

ANS 3.2 Side-By Side Comparison 7/25/2012 activities are to be considered as operational or as construction activities. This phase continues until the operating license is withdrawn.

The managerial and administrative controls of this standard promote safe, reliable and efficient plant operation. This standard may be applied to other activities consistent with the degree to which those activities affect plant reliability. In keeping with this intent, the provisions in this standard may be applied to operational activities other than those specified in the Scope, consistent with the degree to which those activities affect these functions, compliance with regulations specifying radiation dose and contamination criteria, or plant reliability. Applicable portions of this standard may also be used for activities at reactors specifically excluded in the Scope.

This standard is intended to be implemented together with the applicable elements of ASME NQA-1-2008 and the NQA-1a-2009 addenda [2]. ASME NQA-1 is the standard that provides the appropriate Quality Assurance requirements for all phases. This standard provides the managerial and administrative requirements needed to assure safe operation of a facility.

2 Definitions 2. Definitions 2. Definitions 2.1 Glossary of Terms 2.2 Glossary or Term 2.2 Glossary of Terms The terms defined in NQA-1 apply to this standard and are not duplicated herein.

experiments: performance of those plant operations executed Experiments. Performance of those plant Experiments. Performance of those plant under controlled conditions in order to establish characteristics or operational carried out under controlled operations carried out under controlled values not previously known. conditions in ord., to establish conditions in order to establish characteristics or values not previously characteristics or values not previously known.

known.

independent review: review completed by personnel not having Independent review. Review completed Independent review. Review completed by direct responsibility or direct involvement in the work function by personnel not having direct personnel not having direct responsibility 2

ANS 3.2 Side-By Side Comparison 7/25/2012 under review. responsibility for the work function under for the work function under review review regardless of whether they operate regardless of whether they operate as a as a part of an organizational unit or as part of an organizational unit or as individual staff members (see review).

individual staff members (see review ).

managerial and administrative controls: rules, orders, Administrative controls. Rules, order, Administrative controls *. Rules, order instructions, procedures, policies, practices, and designations of instruction&, procedures, policies, instructions, procedures, policies, authority and responsibility. practices and designations of authority practices and designations of authority and responsibility.

and responsibility.

owner organization: the organization, including the on-site Owner organization. The organization, operating organization, that has overall legal, financial, and including the onsite operating technical responsibility for the operation of one or more nuclear organization, which has overall legal, power facilities.

financial and technical responsibility for the operation of one or more nuclear power plants.

operating organization: the organization concerned with daily New Definition operation, maintenance, and related technical services. This organization may include personnel located off-site who provide operational support.

shall, should and may: the word "shall" is used to denote a shall, should and may. The word shall is requirement; the word "should" to denote a recommendation; and used to denote a requirement; the word, the word "may," to denote permission neither a requirement nor a should to denote a recommendation; and recommendation.

the word may to denote permission, neither a requirement nor a recommendation.

3 Requirements 3.1 Organization 3. Owner Organization 3. Owner Organization 3.1.1 General 3.1 General 3.1 General Managerial and administrative controls which comply with this NQA-l, Basic The owner organization shall establish an The owner organization shall establish an standard shall be established. The controls shall be in effect at all Requirement 2. Ok. administrative controls and quality administrative control and quality times during the operational phase. The controls shall require that assurance program which complies with assurance program which complies with 3

ANS 3.2 Side-By Side Comparison 7/25/2012 decisions are made at the proper level and with the necessary this Standard. The program shall be in this standard. The program shall be in reviews. The organization responsible for establishing and effect at all times during the operational effect at all times during the operational executing the administrative controls in accordance with this phase to assure that operational phase phase to assure that operational phase standard may delegate any or all of the work to others, but shall activities are carried out without undue risk activities are carried out without undue risk retain overall responsibility. to the health and safety of the public. The to the health and safety of the public. The program shall require that decision program shall require that decisions affecting safety made at the proper level of affecting safety are made at the proper responsibility and with the necessary level of responsibility and with the technical advice and review. The owner necessary technical advice and review. organization may delegate to other The owner organization may delegate to organizations the work of establishing and executing the administrative controls and other organizations the work of Quality assurance program or any part.

establishing and executing the thereof, in accordance with this standard.

administrative controls and quality but shall retain responsibility there for.

assurance program or any part thereof, in accordance with this Standard, but shall retain responsibility therefore.

3.1.2 Assignment of Authority and Responsibility. 3.2 Assignment of Authority and 3.2 Assignment of Authority and Responsibility Responsibility Lines of authority, responsibility, and communication shall be NQA-1, Basic It is essential that all members of the It is essential that all members of the established and defined for the corporate, plant operating, and Requirement 2. Ok. organization involved in operation of organization involved in operation of support organizations. These relationships shall be documented nuclear power plants, including those at nuclear power plants, including those at and updated, as appropriate, in the form of organizational charts, the highest management levels, recognize the highest management levels, recognize functional descriptions of departmental responsibilities and the necessity that the plants be operated the necessity that the plants be operated relationships and job descriptions for key personnel positions or in under a well formulated and detailed under a well formulated and detailed equivalent forms of documentation. administrative controls and quality administrative control and quality assurance program to assure safety and assurance program to ensure safety and efficiency. Lines of authority, responsibility efficiency. Lines of authority responsibility and communication shall be established and communication shall be established from the highest management level and well defined from the highest through intermediate levels to and management level through intermediate including the onsite operating organization level, to and including all onsite operating (including those offsite organizational units organization position with involvement in assigned responsibility for procurement, activities affecting the safety of the nuclear design and construction, quality power plant including those offsite assurance, and technical support organizational positioning under assigned activities). responsibility for procurement, design and construction, quality assurance and These relationships shall be documented technical support activities.

and updated, as appropriate, in the form of organizational charts, functional These relationships shall be documented 4

ANS 3.2 Side-By Side Comparison 7/25/2012 descriptions or departmental and Updated, as appropriate in the form of responsibilities and relationships and job organizational chart, functional description descriptions for key personnel positions or of departmental responsibilities and in equivalent forms of documentation. The relationships and job description for key owner organization shall specify in writing personnel positioned or in equivalent forms the authority and responsibility assigned to of documentation.

individuals and organizations involved in establishing, executing and measuring the overall effectiveness of the administrative controls and quality assurance program required by this Standard. The persons or organizations responsible for defining and measuring the overall effectiveness of the program shall be designated, shall be sufficiently independent from cost and scheduling considerations when opposed to safety considerations, shall have direct access to responsible management at a level where appropriate action can be accomplished, and shall report regularly on the effectiveness of the program to the plant manager and the cognizant offsite management. Persons or organizations performing functions or assuring that the administrative controls and quality assurance program is established and implemented or of assuring that an activity has been correctly performed shall have sufficient authority and organizational freedom to: identify quality problems; initiate, recommend or provide solutions, through designated channels; and verify implementation of solutions.

The organizational structure and the functional responsibility assignments shall be such that: (1) Attainment of program objectives is accomplished by those who have been assigned responsibility for performing work. This may include interim examinations, checks, and inspections of the work by the individual performing the work. (2) Verification or conformance to established program requirements is accomplished by a qualified person who does not have responsibility for performing 5

ANS 3.2 Side-By Side Comparison 7/25/2012 or directly supervising the work. The method and extent or such verification shall be commensurate with the importance of the activity to plant safety and reliability. In structuring the organization and assigning responsibility, quality assurance should be recognized as an interdisciplinary function involving many organizational component and, therefore, should not be regarded as the sole domain of a single quality assurance group. For example, it may be more appropriate for nuclear engineers to perform reviews of plant nuclear engineering activities rather than quality assurance engineers because of the special .competence required to perform these reviews. Quality assurance encompasses many functions and activities and extends to various levels in all participating organizations. From the top executive to all workers whose activities may influence quality.

3.1.3 Plant Operating Organization 3 .4. 1 General 3 .4. 1 General 3.1.3.1 General NQA-1, Basic A number of factors influence A number of factors influence Requirement 2. Ok. management in its decision regarding the management in its decision regarding the Management shall establish and periodically assess the adequacy of establishment of an onsite operating establishment of an onsite operating the plant operating organization and shall ensure that necessary organization.

organization.

changes to the organization are made in a timely manner.

When establishing the plant operating organization, the owner NQA-1, Basic These include the owner organization's These include the owner organization's organization should evaluate the physical size and complexity of the Requirement 2. Ok. established staffing policies, the physical established staffing policies, the physical nuclear power plant, the number of units, the extent of assistance size and complexity of the nuclear power size and complexity of the nuclear power provided by technical support organizations, and the extent of plant, the number of units, the extent of plant, the number of units, the extent of reliance on consultants and the availability of qualified personnel from other sources. assistance provided by offsite technical' assistance provided by offsite technical support organizations, the extent of support organizations the extent of reliance on consultants and the availability reliance on consultants and the availability of qualified personnel (room other sources of qualified personnel from other sources to assist in activities. such as initial to assist in activities such as initial startup startup, refueling. maintenance or refueling, maintenance or modification 6

ANS 3.2 Side-By Side Comparison 7/25/2012 modification work. work.

3.1.3.1.1 Requirements for the Plant Operating Organization 3. 4. 2 Requirements for the Onsite 3. 4. 2 Requirements for the Onsite Operating Organization Operating Organization The plant operating organization shall include one or more NQA-1, Basic The onsite operating organization shall The Onsite operating organization shall individuals knowledgeable in the following fields: nuclear power plant Requirement 1. Ok. include one or more individuals include. At a minimum, one or more operation; nuclear power plant mechanical systems; nuclear power knowledgeable in the following field. : individual knowledgeable in the following plant electrical systems; instrumentation and control (electronic) nuclear power plant operation; nuclear fields: nuclear power plant operation:

systems; nuclear engineering; heat transfer, fluid flow and power plant mechanical, electrical and nuclear power plant mechanical systems; thermodynamics; chemistry and radiochemistry; radiation protection; electronic systems; nuclear engineering nuclear power plant electrical and risk assessment; and quality assurance. chemistry and radiochemistry; radiation electronic systems; nuclear engineering; protection; and quality assurance. Initial heat transfer, fluid flow and incumbents or replacements (or members thermodynamics; chemistry and of the onsite operating organization and radiochemistry; radiation protection; and offsite technical sup. port organizations quality assurance. Initial incumbents or shall have appropriate experience; training replacements for members of the onsite and retraining to assure that necessary operating organization shall have competence is maintained in accordance appropriate experience, training and with the provisions of American National retraining to assure that necessary Standard for Selection and Training of competence is maintained in accordance Nuclear Power Plant Personnel, NIS.1- with the provisions of American National 1971 Standard for Selection. Qualification Personnel whose qualifications do not and Training of Personnel for Nuclear meet those specified in NlS.l and who are Power Plants, ANS UAN & S.1-l981.

performing inspection. examination, and testing activities during the operations phase of the plant, including preoperational and start-up testing, shall be qualified to American National Standard Qualifications of Inspection, Examination and Testing Personnel for the Construction Phase of Nuclear Power Plants N45.2.6-1973 . except that the QA experience cited for Levels I, II, and III should be interpreted to mean actual experience in carrying out the types of inspection. examination. or testing a being performed.

Staffing requirements for positions in the plants operating Staffing should be in The owner organization shall designate The owner organization shall designate organization that are to be filled by personnel holding NRC alignment with 50.54. those positions in the onsite operating those positions in the onsite operating operator and senior operator licenses are normally delineated in organization which shall be filled by organization which shall be filled by the plants Safety Analysis Report. These positions shall be personnel holding NRC reactor operator personnel holding NRC reactor operator specified. Requirements for the minimum number of personnel and senior reactor operator licenses. and senior reactor operator licenses.

7

ANS 3.2 Side-By Side Comparison 7/25/2012 holding such licenses who are to be present at the plant under Requirements for the minimum number of Requirements for the minimum number of various operating conditions and situations shall also be specified, personnel holding such licenses who shall personnel holding such licenses who shall normally in the plants Technical Specifications. be present at the plant under various be present at the plant under various operating conditions and situations shall operating conditions and situations shall also be specified. also be specified.

3.1.3.1.2 Technical Support for the On-Duty Operating Staff 3.4.3 Technical Support of the Off-Duty Operating Staff.

The shift staffing shall include, or have available for consultation, individuals in technical areas that are related to the safe operation The owner organization shall establish of the facility. The technical areas include thermodynamics and provisions for assuring that the shift fluid flow, reactor engineering, systems engineering, transient and accident analysis, instrumentation and controls, quality assurance, organization includes, or has available for radiation protection, and chemistry and radiochemistry. consultation, persons with professional level expertise in technical areas that are related to the safe operation of the plant.

The technical areas include, as a minimum, thermodynamics/fluid flow, reactor engineering, systems engineering transient and accident analysis, radiation protection, and chemistry radiochemistry.

These personnel shall be available (at the station or on call and capable of responding to the plant within two hours) for the purpose of providing technical advice to the shift supervisor on a 24-hour-a-day basis. They may be part of the plant organization or they may be part of the offsite technical support for the plant staff, except that an individual appropriately Qualified in the first four areas listed above shall be onsite and capable of responding to the control room within ten minutes after the start of an emergency.

3.1.4 Operating Organization Authorities and Responsibilities 5.2.1 Responsibilities and Authorities Of Operating Personnel Responsibilities and authorities of plant operating personnel and Essentially, equivalent The responsibilities and authorities of the See 5.2.1.2 below.

those persons assigned to provide immediate support for the plant to 1976 version, plant operating personnel shall be operations personnel shall be delineated for both normal and delineated. These shall include, as a emergency conditions. The following requirements shall be 8

ANS 3.2 Side-By Side Comparison 7/25/2012 established: Section 5.2.1. Ok. minimum:

(1) The reactor operator's Authority and responsibility for shutting the reactor down when he determines that the safety of the reactor is in jeopardy or when operating parameters exceed any of the reactor protection safety system set points and automatic shutdown does not occur.

(2) The responsibility to determine the circumstances, analyze the cause, and determine that operations can proceed safely before the reactor is returned to power after a trip or An unscheduled or unexplained power reduction.

(3) The senior reactor operator's responsibility to be present at the plant and to provide direction for returning the reactor to power following a trip or an unscheduled or unexplained power reduction.

(4) The responsibility to believe and respond conservatively to instrument indications unless they are proved to be incorrect.

(5) The responsibility to adhere to the plant's Technical Specifications.

(6) The responsibility to review routine operating data to assure safe operation.

3.1.4.1 Plant Control Responsibilities 5.2.1 Responsibilities and Authorities 5.2.1 Control of Plant Operations or Operating Personnel Responsibilities and authorities shall be established so that at all Essentially, (1) The reactor operator's Authority and Responsibilities and authorities of onsite times it is clear which individuals have responsibility for directing equivalent to 1976 responsibility for shutting the reactor down operating personnel and those person!

the various plant operating and control room activities. In assigned to provide immediate support for 9

ANS 3.2 Side-By Side Comparison 7/25/2012 addition, there shall be clear identification of the individual(s) version, Section when he determines that the safety of the the onsite operations personnel shall be responsible for determining the circumstances, analyzing the 5.2.1(1) & (2). reactor is in jeopardy or when operating delineated for both normal and emergency cause, and determining that operations may proceed safely after parameters exceed any of the reactor conditions. at minimum. These rules of an unexplained event or before the reactor is returned to power practice shall establish the following:

protection safety system set points and after a trip.

automatic shutdown does not occur.

(2) The responsibility to determine the circumstances, analyze the cause, and determine that operations can proceed safely before the reactor is returned to power after a trip or An unscheduled or unexplained power reduction.

3.1.4.2 General Authorities and Responsibilities of Operating 5.2.1 Responsibilities and Authorities 5.2.1.2 General Authorities and Personnel Of Operating Personnel responsibilities of Operating Personnel The general authorities and responsibilities of operating personnel Essentially, equivalent The responsibilities and authorities of the Rules of practice shall clearly delineate the shall be clearly delineated and shall include the following: to 1976 version, plant operating personnel shall be general authorities and responsibilities of Section 5.2.1(1) & (2). delineated. These shall include, as a operating personnel, including the (1) the authority and responsibility of licensed personnel for minimum: following:

shutting down the reactor when it is determined that the safety of (1) The reactor operator's Authority and 1) The reactor operator's authority and the reactor is in jeopardy or when operating parameters exceed responsibility for shutting the reactor down responsibility (or shutting down the reactor any of the reactor protection system set points and automatic when he determines that the safety of the when be determines that; the safety of the shutdown does not occur. reactor is in jeopardy or when operating reactor is in jeopardy or when operating parameters exceed any of the reactor parameters exceed any of the reactor (2) the responsibility to respond conservatively to instrument protection system set points and automatic protection system set points and automatic indications unless they are determined to be incorrect. shutdown does not occur. shutdown does not occur.

(2) The responsibility to determine the (2) The responsibility to behave and (3) the responsibility to adhere to plant procedures (see also circumstances, analyze the cause, and respond conservatively to instrument Section 3.5.1). determine that operational can proceed indications unless they are proved to be safely before the reactor is returned to incorrect (4) the responsibility to adhere to the plant's License Conditions power after a trip or An unscheduled (3) The responsibility to adhere to the and Technical Specifications. unexplained power reduction. plant's operational and emergency (3) The senior reactor operator's procedures. (see also 5.2.21.)

(5) the responsibility to review routine operating data to ensure responsibility to be present at the plant (4) The responsibility to adhere to the safe operation. and to provide direction for returning the plant's Technical Specification.

reactor to power following a trip or an (5) The responsibility to review routine unscheduled or unexplained power operating data to assure safe operation.

reduction.

(4) The responsibility to believe and respond conservatively to instrument indications unless they are proved to be incorrect.

10

ANS 3.2 Side-By Side Comparison 7/25/2012 (5) The responsibility to adhere to the plant's Technical Specifications.

(6) The responsibility to review routine operating data to assure safe operation.

3.1.4.3 Authority and Responsibilities of the Operations Shift 5.2.1 Responsibilities and Authorities. 5.2.1.3 Authority and Responsibilities of Supervisor Of Operating Personnel the Shift Supervisor The operations shift supervisor (sometimes called the Shift New addition. Ok. The responsibilities and authorities of the Rules of practice shall clearly delineate the Manager) shall manage the activities of the operating shift to Similar to 1982 version plant operating personnel shall be authority and responsibilities of the shift ensure integrated direction of all activities. The authority and 5.2.1.3. delineated. These shall include, as a supervisor during normal operation and responsibilities of the operations shift supervisor during normal emergency events, including the minimum:

operation and emergency events shall be clearly delineated and following:

shall include the following:

(1) The reactor operator's authority and (1) The shift supervisor shall have the (1) the operations shift supervisor shall have the authority and responsibility for shutting the reactor down authority and responsibility to direct all responsibility to direct all activities pertaining to plant operations. when he determines that the safety of the activities affecting the safety of the nuclear reactor is in jeopardy or when operating power plant. Transfer of authority and (2) the responsibilities of the operations shift supervisor shall be to parameters exceed any of the reactor responsibility to plant staff members in maintain a comprehensive understanding of operational protection System set points and management levels above the shift conditions that affect the safety of the plant as a matter of highest supervisor shall be predetermined.

automatic shutdown did not occur.

priority. Transfer of this authority and responsibility shall be documented for routine shift Control room command duties, responsibilities, and authorities (2) The responsibility to determine the turnover and emergency conditions.

shall be clearly specified. The operations shift supervisor shall not circumstances, analyze the cause, and become totally involved in any single operation when multiple determine that operation" can proceed (2) The responsibilities of the shift operations are required in the control room. If the operations shift safely before the reactor is returned to supervisor shall be primarily to maintain supervisor is temporarily absent from the control room area during power after a trip or an unscheduled or the broadest perspective of operational routine operations, a qualified licensed senior operator shall be conditions affecting the safety of the plant unexplained power reduction.

designated to assume the control room command function. as a matter of highest priority at all times.

The idea of command and control shall be (3) The senior reactor operator's reinforced and the shift supervisor shall be responsibility to be present at the plant instructed not to become totally involved in and to provide direction for returning, the any single operation in times of emergency reactor to power following, a trip or an when multiple operations are required in unscheduled or unexplained power the control room. If the shift supervisor is reduction. temporarily absent from the control room during routine operations, a lead control (4) The responsibility to believe and room operator shall be designated to assume the control room command respond conservatively to instrument function. Temporary duties, indications until they are proved incorrect. responsibilities, and authority shall be clearly specified.

(5) The responsibility to adhere to the plant's Technical Specifications. (3) During emergency conditions, the duty station for the shift supervisor shall be the 11

ANS 3.2 Side-By Side Comparison 7/25/2012 (6) The responsibility to review routine central control room. The shift supervisor, operating data to ensure safe operation. until properly relieved, shall remain in the control room at all times during such situations to direct the activities of control room operators.

In order to perform the preceding functions effectively, the Worded slightly 3.4.2 Requirements for the Onsite 3.4.2 Requirements for the onsite operations shift supervisor shall not be encumbered with different than 1976 Operating Organization Operational Organization unnecessary on-shift administrative duties. version, Section 3.4.2.

The onsite operating organization shall The Onsite operating organization shall Intent is the same. Ok.

include one or more individuals include. At a minimum, one or more knowledgeable in the following individual knowledgeable in the following field!!:nuclear power plant operation; fields: nuclear power plant operation:

nuclear power plant mechanical, electrical nuclear power plant mechanical systems; and electronic systems; nuclear nuclear power plant electrical and engineering chemistry and radiochemistry; electronic systems; nuclear engineering; radiation protection; and quality heat transfer, fluid flow and assurance. Initial incumbents or thermodynamics; chemistry and replacements (or members of the onsite radiochemistry; radiation protection; and operating organization and offsite quality assurance. Initial incumbents or technical support organizations shall have replacements for members of the onsite appropriate experience; training and operating organization shall have retraining to assure that necessary appropriate experience, training and competence is maintained in accordance retraining to assure that necessary with the provisions of American National competence is maintained in accordance Standard for Selection and Training of with the provisions of American National Nuclear Power Plant Personnel, NIS.1- Standard for Selection. Qualification 1971. and Training of Personnel for Nuclear Power Plants, ANS UAN & S.1-l981.

Personnel whose qualifications do not meet those specified in NlS.l and who are performing inspection. examination, and testing activities during the operations phase of the plant, including preoperational and start-up testing, shall be qualified to American National Standard Qualifications of Inspection, Examination and Testing Personnel for the Construction Phase of Nuclear Power Plants. N45.2.6-1973 (5]. except that the QA experience cited for Levels I, II, and III should be interpreted to mean actual experience in carrying out the types of 12

ANS 3.2 Side-By Side Comparison 7/25/2012 inspection. examination. or testing activity being performed. The owner organization shall designate those positions in the onsite operating organization which shall be filled by personnel holding NRC reactor operator and senior reactor operator licenses. Requirements for the minimum number of personnel holding such licenses who shall be present at the plant under various operating conditions and situations shall be specified. The Plant Manager shall have Overall responsibility for the execution of the administrative control.

and quality assurance program at the plant to assure safety. An individual or organizational unit knowledgeable and experienced in nuclear power plant operational phase activities and quality assurance practice: shall be designated and assigned the responsibility to verify that the program is being effectively implemented. Depending on the organizational structure, the individual or organizational unit may report functionally to offsite plant management or an offsite organization (see also 3.2). Reporting to onsite plant management is preferable since such an arrangement usually resulting in improved communications in identifying problems and initiating corrective action. The individual or organizational unit in this case may receive technical guidance from offsite support groups. This individual's or organizational unit's duties and responsibilities shall be such that the required attention can be devoted, as required, to verifying that the program is being effectively executed. The individual 13

ANS 3.2 Side-By Side Comparison 7/25/2012 or organizational unit shall report on the effectiveness of the program to the Plant Manager and to either cognizant management as may be designated. The activities shall be periodically audited by designated offsite personnel.

3.1.4.4 Responsibilities of Others in the Plant Operating 3.4.2 Requirements for the Onsite 3.4.2 Requirements for the Onsite Organization Operating Organization. Operational Organization The authority and responsibility of other personnel whose actions or New addition. Ok. The onsite operating organization shall The Onsite operating organization shall decisions could affect normal plant operations or exacerbate an include one or more individuals include. At a minimum, one or more abnormal or accident condition shall be delineated. As a minimum, §No discussion of the knowledgeable in the following individual knowledgeable in the following personnel performing maintenance or testing shall not work on plant role of the Plant field:nuclear power plant operation; fields:nuclear power plant operation:

systems and equipment unless permission has been granted by Manager, as in 1976 nuclear power plant mechanical, electrical nuclear power plant mechanical systems; designated operating personnel. and electronic systems; nuclear nuclear power plant electrical and version, Section 3.4.2. engineering chemistry and radiochemistry; electronic systems; nuclear engineering; radiation protection; and quality heat transfer, fluid flow and assurance. Initial incumbents or thermodynamics; chemistry and replacements (or members of the onsite radiochemistry; radiation protection; and operating organization and offsite quality assurance. Initial incumbents or technical support organizations shall have replacements for members of the onsite appropriate experience; training and operating organization shall have retraining to assure that necessary appropriate experience, training and competence is maintained in accordance retraining to assure that necessary with the provisions of American National competence is maintained in accordance Standard for Selection and Training of with the provisions of American National Nuclear Power Plant Personnel, NIS.1- Standard for Selection. Qualification and 1971. Training of Personnel for Nuclear Power Personnel whose qualifications do not Plants ANSI/ANs 3.1-l981 (SI Personnel meet those specified in NlS.l and who are whose qualifications are not addressed in performing inspection. examination, and ANS-3.1 and who are performing testing activities during the operations inspection, examination, and testing phase of the plant, including activities during the operations phase of preoperational and start-up testing, shall the plant.. including preoperational and be qualified to American National start-up testing. shall be qualified in Standard Qualifications of Inspection, accordance with the requirements of Examination. And Testing Personnel for NQA-1-1979, except that cited experience the Construction Phase of Nuclear Power shall be limited to actual experience in Plants. N45.2.6-1973. except that the QA carrying out the types of inspection.

experience cited for Levels I, II, and III examination, or testing activity being should be interpreted to mean actual performed. The owner organization shall experience in carrying out the types of designate the position in the onsite inspection. examination. or testing activity operating organization which shall be filled 14

ANS 3.2 Side-By Side Comparison 7/25/2012 being performed. by personnel holding NRC operator and senior operator license. Requirements for the minimum number of personnel holding such licenses who shall be present at the plant under various operating conditions and situation shall also be specified_

3.1.4.5 Transfer of Authority and Responsibility 5.2.1.4 Transfer of Responsibility Transfer of authority and responsibility to plant staff members in New addition. Ok. Rules of practice shall be established for management levels above the operations shift supervisor shall be the transfer of responsibility from one shift predetermined. The transfer of responsibility from one shift to Similar to 1982 to another, as well as the transfer of another, as well as the transfer of authority during emergency version, Section authority during emergency conditions.

conditions shall be documented and shall involve: 5.2.1.4. These rules of practice shall delineate:

(1) Persons authorized to relieve the operations shift supervisor. (1) Persons authorized to relieve the shift Only personnel meeting the qualification requirements of the supervisor.

operations shift supervisor position shall relieve the on-duty shift supervisor. (2) The line of ascension of authority during both normal and emergency (2) The line of ascension of authority. conditions when one or more persons of management authority above the shift (3) The authority and limitations of technical and management supervisor are present in the central personnel to direct activities in the control room. control room. Only personnel meeting the qualification requirements of the shift supervisor position shall have the authority to relieve the on-duty shift supervisor from the responsibility to direct activities affecting the safety of the nuclear power plant.

(3) The authority, and limitations thereon, of technical and management personnel to direct activities in the central control room.

(4) Interfaces between groups such as the utility's corporate organization, vendors, the architect-engineer, contractors and consultants, NRC and other local state or federal agencies.

To ensure that personnel on succeeding shifts have a clear New addition. Ok. See above understanding of the condition of equipment and systems, each on-shift duty station shall have procedures for the turnover of duties. Similar to 1982 These procedures shall include documented turnover action version, Section appropriate to the duty station acknowledging the status of the plant 15

ANS 3.2 Side-By Side Comparison 7/25/2012 and transfer of authority. 5.2.1.4.

Overall plant status, maintenance and test status, planned activities, and any identified trends applicable to the duty station shall be explained. In addition, the following items shall be identified:

(1) critical parameters that are not within normal limits, (2) systems that are not in their normal configuration, or are in a degraded mode of operation permitted by the Technical Specifications, and (3) any time that limitations are placed on continued operation.

3.1.4.6 Control Room Access 5.2.9 Plant Security and Visitor Control 5.2.1.5 Control Room Access Access to the control room shall normally be limited to on-shift New addition. Ok. Procedures shall be developed to Access to the control room shall normally personnel and other persons whose job function requires their Similar to 1982 supplement features and physical barriers be limited to assigned shift personnel and physical presence in the control room. Access to the control room version, Section design to control access to the pant and as other persons whose job function requires for the purpose of general familiarization and other non-work-related their physical presence in the control room.

5.2.1.5. appropriate to vital area within the plant activities shall be authorized only for good cause. This control shall be exercised by physical information concerning specification security controls and by administrative Slightly similar to 1976 designated features and administrative controls implemented by the shift version, Section 5.2.9. provision of the plant and visitors controls supervisor or other emergency procedures such as fences and lightings coordinators that have assumed control.

lock control for doors gates and Access to the control room for the purpose compartments ..the security and visitors of general familiarization and other non-work-related activities shall be authorized control for doors gates an challenging of only for good cause. To facilitate the strangers By operating crew and a program assistance by technical support personnel of reemployment screening (or potential to the shift operating crew in an employee. See American National Standard emergency, provisions shall be made to Industrial Security for Nuclear Power Plant, provide a technical support center for N18.7-1971, for guidance and provisions for these persons security measures adequate to protect nuclear power plants.

16

ANS 3.2 Side-By Side Comparison 7/25/2012 During emergency conditions, access to the control room should New addition. Ok. N/A See above also be limited. A technical support center, operational support Similar to 1982 center, and emergency operations facility are provided for support version, Section personnel.

5.2.1.5.

3.2 Program The managerial and administrative controls employed shall provide control over activities affecting the quality of safety-related structures, systems, and components to an extent consistent with the scope and purpose of this standard.

Managerial and administrative controls shall establish requirements pertaining to the conduct and control of plant activities such that affected personnel are provided with a clear understanding of operating philosophy and management policies, as well as methods and techniques for performing required work.

These controls shall be established in appropriate policies, procedures, and/or instructions for the operating and support organizations.

3.2.1 Operating Organization Review The operating organization shall provide, as a part of the normal .

duties of plant supervisory personnel, timely and on-going monitoring of operating activities to assist the plant manager in keeping abreast of general plant conditions and to verify that day-to-day operations are conducted safely in accordance with the established administrative controls. These monitoring activities are considered to be an integral part of the routine supervisory function and are important to the safety of plant operation.

The operating organization shall perform reviews periodically and as situations demand, to evaluate plant operations and plan future activities. The important elements of the reviews shall be documented. Such reviews serve a useful purpose but shall not take the place of the reviews described in Section 3.2.2, or audits described in Section 3.18. The onsite operating organization 17

ANS 3.2 Side-By Side Comparison 7/25/2012 shouldscreen subjects of potential concern to independent reviewers (see section 3.2.2.2 (1) through (8)) and perform preliminary investigations. The plant manager shall ensure the timely referral of the applicable matters discussed in the reviews to appropriate management and independent reviewers.

3.2.2 Independent Review 4.3 Independent Review Program 4.3 Independent Review Program Activities occurring during the operational phase shall be Activities occurring during the operational Activities occurring during the operational independently reviewed on a periodic basis. The independent phase shall be independently reviewed on phase shall be independently reviewed on review program shall be functioning prior to initial core loading. a periodic basis. The independent review a periodic basis. The independent review This Standard does not advocate any specific organizational program shall be functional prior to initial program shall be functional prior to initial structure for complying with the independent review function, but, core loading.

in lieu thereof, delineates essential elements of satisfactorily core loading.

comprehensive programs for review that shall be applied in the manner best suited to the owner organization involved. An Independent Review Body (IRB) as described in 3.2.2.3 or an Independent Review Committee (IRC) as described in 3.2.2.4 shall be used to perform the independent review function. The terms IRB and IRC are intended to be generic in nature and may be substituted with the specific owner organizations terms.

3.2.2.1 Personnel 4.3.1 Personnel 4.3.1 Personnel Personnel assigned responsibility for independent review shall be IAW NRC Safety Personnel assigned responsibility Personnel assigned responsibility specified, in both number and technical disciplines, and shall Evaluation for independent reviews shall be for independent reviews shall be collectively have the experience and competence required to ML050210276 specified, in both number and technical specified, in both number and technical review problems in the following areas: disciplines, and shall collectively have the disciplines, and shall collectively have the experience and competence required to experience and competence required to review problems in the following areas; review problems in the following areas; (1) Nuclear power plant operations (1) Nuclear power plant operations (1) Nuclear power plant operations (2) Nuclear engineering (2) Nuclear engineering (2) Nuclear engineering (3) Chemistry and radiochemistry (3) Chemistry and radiochemistry (3) Chemistry and radiochemistry (4) Metallurgy (4) Metallurgy (4) Metallurgy (5) Nondestructive testing (5) Nondestructive testing (5) Nondestructive testing 18

ANS 3.2 Side-By Side Comparison 7/25/2012 (6) Instrumentation and control (6) Instrumentation and control (6) Instrumentation and control (7) Radiological safety (7) Radiological safety (7) Radiological safety (8) Mechanical engineering (8) Mechanical engineering and Electrical (8) Mechanical engineering engineering (9) Electrical engineering (9) Electrical engineering (9) Administrative controls and quality (10) Administrative control and quality assurance practices assurance practices (10) Administrative controls and quality assurance practices (11) Training (10) Other appropriate fields associated with the unique characteristics of the (11) Emergency plans and related (12) Emergency plans and related procedures and equipment. nuclear power plant involved. organization, procedure and equipment (12) Other appropriate fields associated with the unique characteristics of the nuclear power plant involved.

An individual may possess competence in more than one An individual may possess competence in An individual may possess competence in specialty area. If sufficient experience is not available within the more than one specialty area. If sufficient more than one specialty area. If sufficient owner organization, independent reviews shall be supplemented expertise is not available from within the expertise is not available from within the through outside consultants or organizations. Provisions shall be owner organization, independent reviews owner organization, independent reviews made to assure that appropriate expertise is brought to bear in shall be supplemented through outside shall be supplemented through outside reviews of operational phase activities. consultants or organizations. consultants or organizations.

Provisions shall be made to assure that Provisions shall be made to assure that appropriate expertise is brought to bear in appropriate expertise is brought to bear in reviews of operational phase activities. reviews of operational phase activities.

Persons fulfilling the independent review function shall be IAW NRC Safety qualified as follows: Evaluation ML050210276 (1) Supervisor or Chairperson:

a. Education: baccalaureate in engineering or related science.
b. Minimum experience: 6 years combined managerial and technical support.

(2) Reviewers:

a. Education:

- Baccalaureate in engineering or related science for those independent review personnel who are required to review problems in nuclear power plant operations, nuclear engineering, chemistry and radiochemistry, metallurgy, nondestructive testing, 19

ANS 3.2 Side-By Side Comparison 7/25/2012 instrumentation and control, radiological safety, mechanical engineering, and electrical engineering.

- High school diploma or equivalent for those independent review personnel who are required to review problems in administrative control and quality assurance practices, training, and emergency plans and related procedures and equipment.

- Alternatives to the education requirements may be applied consistent with USNRC Regulatory Guide 1.8 [4].

b. Minimum experience: 5 years experience in their own area of responsibility (1 through 12 above).

3.2.2.2 Scope of Review 4.3.4 Subjects Requiring Independent 4.3.4 Subjects Requiring Independent Review Review The independent review function shall perform the following: The following subjects shall be The following subjects shall be reviewed by the independent review body: reviewed by the independent review body:

(1) Reviews proposed changes to the facility as described in the (1) Written safety evaluations of changes (1) Written safety evaluations of changes safety analysis report (SAR) and verifies that changes do not in the facility as described in the Safety in the facility as described in the Safety adversely affect safety and if a technical specification change or Analysis Report, changes in procedures Analysis Report, changes in procedures as NRC review is required. as described in the Safety Analysis Report described in the Safety Analysis Report and tests or experiments not described in and tests or experiments not described in the Safety Analysis Report which are the Safety Analysis Report which are completed without prior NRC approval completed without prior NRC approval under the provisions of 10 CFR under the provisions of 10 CFR 50.59(a)(1). This review is to verify that 50.59(a)(1). This review is to verify that such changes, tests or experiments did such changes, tests or experiments did not not involve a change in the technical involve a change in the technical specifications or an unreviewed safety specifications or an unreviewed safety question as defined in10CFR 50.59(a)(2). question as defined in10CFR 50.59(a)(2).

(2) Reviews proposed tests and experiments not described in the (2) Proposed changes in procedures, (2) Proposed changes in procedures, SAR prior to implementation. Verifies the determination of Proposed changes in the facility, or Proposed changes in the facility, or whether changes to proposed tests and experiments not proposed tests or experiments any of proposed tests or experiments any of described in the SAR require a technical specification change or which involves a change in the technical which involves a change in the technical license amendment. specification or an unreviewed safety specification or an unreviewed safety question as defined in 10 CFR 50.59(c). question as defined in 10 CFR 50.59(c).

. Matters of this kind shall be referred to the Matters of this kind shall be referred to the independent review body by the 0nsite independent review body by the 0nsite operating organization (see 4.4) following operating organization (see 4.4) following 20

ANS 3.2 Side-By Side Comparison 7/25/2012 its review, or by other functional its review, or by other functional organizational units within the owner organizational units within the owner organization, prior to implementation. organization, prior to implementation.

(3) Reviews proposed technical specification changes and license (3) Changes in the technical specifications (3) Changes in the technical specifications amendments relating to nuclear safety prior to NRC submittal and or license amendments relating to nuclear or license amendments relating to nuclear implementation, except in those cases where the change is safety prior to implementation, except in safety prior to submittal to the Commission identical to a previously approved change. those cases where the change is identical for approval and prior to implementation.

to a previously reviewed proposed change.

(4) Reviews violations, deviations, and events that are required to (4) Violations, deviations, and reportable (4) Violations, deviations, and reportable be reported to the NRC. This review includes the results of events which require reporting to the NRC events which require reporting to the NRC investigations and recommendations resulting from such in writing 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, such as in writing.

investigations to prevent or reduce the probability of recurrence of the event. Review of events covered under this subsection shall include the results of any investigations made and the recommendations resulting from such investigations to prevent or reduce the probability of recurrence of the event.

(5) Reviews any matter related to nuclear safety that is requested (5) Any other matter involving safe by the plant manager or any IRB/IRC member. operation of the nuclear power plant which an independent reviewer deems appropriate for consideration, or which is referred to the independent reviewers by the onsite operating organization or by other functional organizational units within the owner organization.

(6) Reviews corrective actions for significant conditions adverse to quality.

(7) Reviews internal audit reports.

(8) Reviews the adequacy of the internal audit program every 24 months.

3.2.2.3 Independent Review Body 21

ANS 3.2 Side-By Side Comparison 7/25/2012 A group may function to perform the reviews of 3.2.2.2 and is IAW NRC Safety described as an independent review body (IRB). In discharging Evaluation its review responsibilities, the IRB keeps safety considerations ML050210276 paramount when opposed to cost or schedule considerations.

One or more organizational units may collectively perform this function.

1. The IRB reviews shall be supplemented as follows:
a. A qualified person, independent of the preparer, reviews proposed changes in the procedures as described in the SAR prior to implementation of the change to determine if a technical specification change or NRC approval is required.
b. Audits of selected changes in the procedures described in the SAR are performed to verify that procedure reviews and revision controls are effectively implemented.
c. Competent individual(s) or group(s) other than those who performed the original design but who may be from the same organization verify that changes to the facility do not result in a loss of adequate design or safety margins.
2. The results of IRB reviews of matters involving the safe operation of the facility are periodically independently reviewed. This review is intended to support management in identifying and resolving issues potentially affecting safe plant operation. This review supplements the existing corrective action programs and audits.
a. The review is performed by a team consisting of personnel with experience and competence in the activities being reviewed, but independent from cost and schedule considerations and from the organizational unit[s]

responsible for those activities.

b. The review is supplemented by outside consultants or organizations as necessary to ensure the team has the requisite expertise and competence.
c. Results of the review are documented and reported to responsible management.

22

ANS 3.2 Side-By Side Comparison 7/25/2012

d. Management periodically evaluates issues they determine warrant special attention, such as deficient plant programs, declining performance trends, employee concerns, or other issues related to safe plant operations and determine what issues warrant the review.
e. Management determines the scheduling and scope of review and the composition of the team performing the review.

3.2.2.4 Independent Review Committee 4.3.2.1 Committee Composition When an independent review committee is assigned independent IAW NRC Safety When a standing committee is responsible review responsibilities: Evaluation for the independent review program. it ML050210276 shall be composed of no less than five

1. The independent review committee reports to a management persons, of whom no more than a minority level above the plant manager. are members of the onsite operating organization. Competent alternates are
2. The independent review committee shall be composed of no permitted if designated in advance. The less than 5 persons and no more than a minority of members are use of alternates shall be restricted to from the on-site operating organization. Competent alternates are legitimate absences of principals.

permitted if designated in advance. The use of alternates shall be restricted to legitimate absence of the principles.

3. Results of the meeting shall be documented and recorded and disseminated promptly to appropriate members of management having responsibility in the area reviewed.
4. Consultants and contractors are used for the review of complex problems beyond the expertise of the independent review committee.
5. During the period of initial operation, meetings shall be 4.3.2.2 Meeting Frequency 4.3.2.2 Meeting Frequency conducted no less frequently than once per calendar quarter. Formal meetings of personnel assigned to Formal meetings of personnel assigned to Afterwards meetings are conducted no less than twice a year. a standing committee functioning as an a standing committee functioning as an independent review group shall be independent review group shall be scheduled as needed. During the period of scheduled as needed. During the period of initial operation such meetings should be initial operation such meetings should be held no less frequently than once per held no less frequently than once per calendar quarter. Subsequently, the calendar quarter. Subsequently, the meeting frequency shall not be less than meeting frequency shall not be less than twice a year. twice a year.

It is intended that committee decisions 23

ANS 3.2 Side-By Side Comparison 7/25/2012 normally be made at formal meetings.

However, in extenuating circumstances where it is impractical to convene a quorum for a formal meeting within a necessary time constraint, alternative means such as a conference call are acceptable. In such cases, action taken shall be reviewed by a quorum of the independent review body at its next regularly scheduled meeting.

6. A quorum for formal meetings shall consist of not less than a 4.3.2.3 Quorum 4.3.2.3 Quorum majority of the members, or duly appointed alternates. The A quorum for formal meetings of the A quorum for formal meetings of the chairperson or duly appointed alternate shall be present for all committee held under the provisions of committee held under the provisions of meetings; and no more than a minority of the quorum shall have 4.3.2.2 shall consist of not less than a 4.3.2.2 shall consist of not less than a line responsibility for operation of the plant. majority of the principals, or duly majority of the principals, or duly appointed appointed alternates, and shall be subject alternates, and shall be subject to the to the following constraints: the chairman following constraints: the chairman (or his duly appointed alternate) shall be present (or his duly appointed alternate) shall be for all formal meetings; and no more than a present for all formal meetings; and no minority of the quorum .shall have line more than a minority of the quorum .shall responsibility for operation of the plant.

have line responsibility for operation of the plant.

3.2.3 Indoctrination and Training Qualification requirements for positions in the plant operating Refers to guidance in organization shall be established in accordance with the provisions NQA-1 of plant technical specifications, American National Standard for Selection, Qualification and Training of Personnel for Nuclear Power Plants, USNRC Regulatory Guide 1.8 [4]. USNRC Regulatory Guide 1.8 [4].or ASME NQA-1-2008 and the NQA-1a-2009 addenda [2] as applicable.

Training shall be in accordance with ASME NQA-1-2008 and the NQA-1a-2009 addenda [2].

3.2.4 Maintenance 24

ANS 3.2 Side-By Side Comparison 7/25/2012 Maintenance activities that may affect the functions of structures, systems, or components shall:

NRC did not endorse (1) be performed in a manner to assure quality, availability, and subpart 2.18 of NQA-1 reliability at least equivalent to that specified in the original or in RG1.33.

updated design bases and requirements.

(2) provide for the conduct of appropriate inspections and performance tests to demonstrate that maintenance has been properly performed. See note under section 2.2 (3) be planned and performed in accordance with written procedures, documented instructions or drawings appropriate to the Would affect the circumstances which conform to applicable codes, standards, Glossary.

specifications, and criteria.

(4) be documented in accordance with applicable codes, standards and regulatory commitments. This documentation shall be retained May be needed to as specified in 3.17.

support section 5.2.7 (5) be scheduled and planned so as not to violate plant Technical and 5.2.7.1 in ANS Specifications or compromise the safety of plant personnel or 3.2-1976 version.

equipment. Planning shall evaluate the possible safety consequences of concurrent or sequential maintenance, testing or operating activities. Equipment required to be operable for the prevailing mode shall be available, and maintenance shall be performed in a manner such that license limits are not violated.

Planning for maintenance shouldinclude evaluation of equipment out-of-service to ensure the increased risk is known and compensatory measures are taken when appropriate. Planning should also evaluate the use of special processes, equipment and materials, potential hazards to personnel and equipment and the benefits of minimizing equipment unavailability.

(6) contain general rules for the development, review, and approval, prior to use, of repair, replacement, recurring, and routine maintenance procedures consistent with the provisions of this standard.

(7) provide for a preventive maintenance program, based on performance and condition monitoring, that prescribes the frequency and type of maintenance to be performed. A preliminary program based on service conditions, industry experience with comparable equipment and supplier recommendations, should be developed prior to fuel loading. The program should be revised and updated as 25

ANS 3.2 Side-By Side Comparison 7/25/2012 experience is gained with the equipment. Equipment history files should be created, kept current, and periodically evaluated for adverse trends. The files should be organized to provide complete and easily retrievable equipment history.

(8) provide for the prompt determination, evaluation, recording, and dissemination to appropriate personnel of the causes of malfunctions or unacceptable performance (see also Section 3.16).

Industry experience with malfunctioning equipment shouldbe reviewed and evaluated to determine whether a component of the same type can be expected to perform its function reliably.

(9) provide requirements to implement appropriate corrective actions prior to replacement or repair of similar components in systems that performed unsatisfactorily.

(10) address aging, generic, and common cause effects to prevent possible recurrence and to inform appropriate industry communication organizations.

(11) provide assurance that replacement components shall receive adequate testing or shall be of a design for which experience indicates a high probability of satisfactory performance.

(12) evaluate phased replacement to permit in-service monitoring of new components thus minimizing the possibility of a hidden deficiency producing a systematic failure.

(13) evaluate implementing and monitoring an augmented testing and inspection program following a large-scale component replacement (or repair) until such time that a suitable level of performance has been demonstrated.

3.2.5 Housekeeping and Cleanliness Control Housekeeping and cleanliness shall be controlled in accordance NRC did not endorse with ASME NQA-1-2008 and the NQA-1a-2009 addenda [2]. subpart 2.18 of NQA-1 in RG1.33.

26

ANS 3.2 Side-By Side Comparison 7/25/2012 May be needed to support section 5.2.7 and 5.2.7.1 in ANS 3.2-1976 version.

3.3 Design Control Design activities, including modifications, associated with Essentially, equivalent structures, systems, and components (SSC)s shall be controlled to NQA- 1. Ok.

in accordance with ASME NQA-1-2008 and the NQA-1a-2009 addenda [2].

1982 version states to do IAW NQA-1. No unique additional requirements.

3.4 Procurement Document Control Procurement Documents shall be controlled in accordance with Essentially, equivalent ASME NQA-1-2008 and the NQA-1a-2009 addenda [2]. to NQA- 1. Ok.

1982 version states to do IAW NQA-1. No unique additional requirements.

3.5 Instructions, Procedures, and Drawings Instructions, procedures, and drawings shall be used in accordance with ASME NQA-1-2008 and the NQA-1a-2009 addenda [2]. Appendix A includes a listing of typical procedures that are considered to affect safe operation or the quality of SSCs 27

ANS 3.2 Side-By Side Comparison 7/25/2012 that shouldbe addressed through the managerial and administrative controls program. Specific requirements for operational procedures are as follows.

3.5.1 Procedure Adherence 5.2.2 Procedure Adherence 5.2.2 Procedure Adherence Procedures shall be followed, and the requirements for their use Essentially, equivalent Procedure shall be followed, and the Procedures shall be (allowed, and the shall be prescribed in writing. Procedures and changes thereto are to NQA-1. requirements for use of procedures shall be requirements for use of procedures shall controlled in accordance with Section 3.6 of this standard. prescribed in writing. Rules shall be be prescribed in writing. Rules shall be established which provide methods by established which provide methods by which temporary changes to approved which temporary changes to approved procedures can be made, including the procedures can be made. including the designation of 8 person or persons designation of a person or persons authorized to approve such changes.

Similar to 1982 authorized to approve such changes. Temporary changes which clearly do not version, Section5.2.2. change the intent of the approved Temporary changes which clearly do not change the intent of the approved procedure, shall as a minimum be approved by two members of the plant procedure, shall at a minimum be approved staff knowledgeable in the areas affected by two member of the plant staff by the procedure. At least one of these knowledgeable in the areas affected by the shall be a member of plant supervision.

procedures. At least one of these individuals For changes to procedures which may shall be the supervisor in charge of the shift affect the operational status of plant and hold a senior operators license on the systems or equipment. the changes shall unit affected. Such changes shall be be approved by two members of the plant supervision, at least one of whom holds a documented and if appropriate, incorporated senior operator' License on the unit in the next revision of the affected affected. Such changes shall be procedure. documented and, if appropriate.

incorporated in the next revision of the affected procedure.

In the event of an emergency not covered by an approved Essentially, equivalent In the event of an emergency not covered In the event of an emergency not covered procedure, or an emergency not following the path upon which the to ANS 3.2 1976, by an approved procedure, operations by an approved procedure, or an approved procedure is based, operations personnel shall be section 5.2.2. personnel shall be instructed to take action emergency not following the path upon instructed to take action so as to protect public health and safety, so as to minimize personnel injury and which the approved procedure is based, and minimize personnel injury and damage to the facility.

damage to the facility and to protect health operations personnel shall be instructed to and safety. take action so as to protect health and safety, and minimize personnel injury and damage to the facility.

28

ANS 3.2 Side-By Side Comparison 7/25/2012 Guidance should be provided to identify the manner in which Essentially, equivalent Guidance should be provided to identify the Guidance should be provided to identify procedures are to be implemented. Examples of such guidance to ANS 3.2 1976, manner in which procedures are to be the manner in which procedures are to be include identification of those tasks that require: section 5.2.2. implemented. implemented. Examples of such guidance include identification of those tasks that Example of such guidance include require:

identification of those tasks that require:

(1) The written procedure to be present and followed step-by-step Essentially, equivalent (1) The written procedure to be present (l) The written procedure to be present.

while the task is being performed. to ANS 3.2 1976, and followed step by step while the task is Either on paper or on a suitable electronic section 5.2.2. being performed or other display, and followed step by step while the task is being performed.

(2) Memorization of procedural steps. Essentially, equivalent (2) The operator to have committed the (2) The operator to have committed the to ANS 3.2 1976, procedural step to memory procedural steps to memory.

section 5.2.2.

(3) Verification of completion of significant steps, by initials or Essentially, equivalent (3) Verification of completion of significant (3) Verification of completion of significant signatures on check-off lists. Startup and shutdown procedures to ANS 3.2 1976, steps by initial or signature of \check off steps. by initials or signatures of check off are examples of procedures that require verification. section 5.2.2. list lists.

The types of procedures that shall be present and referred to directly Essentially, equivalent 5.2.2 Procedure Adherence Procedure The types of procedures that shall be are those developed for extensive or complex jobs where reliance on to ANS 3.2 1976, shall be followed and the requirement for present and referred to directly are those memory cannot be trusted, e.g., reactor startup, tasks which are section 5.2.2. use of procedures shall be prescribed in developed for extensive or complex jobs infrequently performed, and tasks in which operations shall be where reliance on memory cannot be writing. Rules shall be established which performed in a specified sequence, and emergency operating trusted. e.g. reactor startup tasks which procedures. Routine procedural actions that are frequently repeated provide methods by which temporary are infrequently performed, and tasks in may not require the procedure to be present; however, periodic changes to approved procedures can be which operation must be performed in a procedure reference may be needed to verify the adequacy of made, including the designation of a specified sequence. Procedural steps for procedures and task performance, and accurate adherence. Copies person or persons authorized to approve which actions should be committed. to of all procedures shall be available to appropriate members of the such changes. Temporary changes which memory include. for example, immediate plant staff. clearly do not change the intent of the actions in emergency procedures. Routine procedural actions that. Are frequently approved procedure shall at a minimum be repeated might not require the procedure approved by two members of the plant to be present. Copies of all procedure shall Those procedures that are necessary for use by the reactor staff knowledgeable in the areas affected be available to appropriate members of the operators shall be available and readily accessible in the control by the procedures. At least one of these plant staff. Those procedures which may room. If an electronic display is relied upon as the written procedure, individuals shall be the supervisor in be necessary for' use by the reactor a hard copy should be available as backup. If documentation of an charge of the shift and hold a senior operators shall be available in the control action is required, the necessary documentation shall be recorded as room. If documentation of an action is operators license on the unit affected.

the task is performed. required the necessary data shall be Such changes shall be documented and if recorded as the task is performed.

appropriate, incorporated in the next Examples of procedures requiring 29

ANS 3.2 Side-By Side Comparison 7/25/2012 revision of the affected procedure. In the verification are furnished in 5.3.4.1 and event of an emergency not covered by an 5.3.4.2.

approved procedure, operations personnel shall be instructed to take action so as to minimize personnel injury and damage to the facility and to protect health and safety. Guidance should be provided to identify the manner in which procedures are to be implemented. Examples of such guidance include identification of those skill that require:

(1) The written procedure to be present followed step by step while the task is being performed (2) The operator to have committed the procedural steps to memory (3) Verification of completion of significant steps by initial or signature of check off list The type of procedures that shall he present and referred to directly are those developed examples jobs where reliance on memory cannot be trusted. e.g., reactor "start-up tasks which are infrequently Performed any tasks in which operation) must be performed in a specified sequence. Procedure steps for which action should be committed to memory include, or example, action in emergency procedures. Routine procedural actions that are frequently repeated may not require the procedure to be present Copies of all procedures shall be available to appropriate members of the plant staff documentation of an action is required. the necessary data shall be recorded as the task is performed. Examples of procedure requiring verification are furnished in 30

ANS 3.2 Side-By Side Comparison 7/25/2012 5.3.4.1 And 5.3.4:2.

3.5.2 Content and Format Procedure format and content may vary from one owner See section 5.3.2 of organization, or group therein, to the other. However, procedures 3.5.1 on the ANS 3.2 shall include the following elements as appropriate to the purpose sheet or task to be described.

3.5.2.1 Title/Status Each procedure is given a title descriptive of the work or subject it See section 5.3.2 of addresses, and includes a revision number and/or date and an 3.5.1 on the ANS 3.2 approval status. sheet 3.5.2.2 Purpose/Statement of Applicability/Scope The purpose for which the procedure is intended is clearly stated See section 5.3.2 of (if not clear from the title). The systems, structures, components, 3.5.1 on the ANS 3.2 processes or conditions to which the procedure applies are also sheet clearly described.

3.5.2.3 References Applicable references, including reference to appropriate See section 5.3.2 of Technical Specifications, are required. References are included 3.5.1 on the ANS 3.2 within the body of the procedure when the sequence of steps sheet requires other tasks to be performed (according to the reference) prior to or concurrent with a particular step.

3.5.2.4 Prerequisites/Initial Conditions Prerequisites/initial conditions identify those independent actions See section 5.3.2 of or procedures that shall be accomplished and plant conditions that 3.5.1 on the ANS 3.2 are required to exist prior to performing the procedure. A prerequisite applicable to only a specific portion of a procedure is 31

ANS 3.2 Side-By Side Comparison 7/25/2012 so identified. sheet 3.5.2.5 Precautions Precautions alert the user to those important measures to be used See section 5.3.2 of to protect equipment and personnel, including the public, or to 3.5.1 on the ANS 3.2 avoid an abnormal or emergency situation during performance of sheet the procedure. Cautionary notes applicable to specific steps are included in the main body of the procedure and are identified as such.

3.5.2.6 Limitations and Actions Limitations on the parameters being controlled and appropriate See section 5.3.2 of corrective measures to return the parameter to the normal control 3.5.1 on the ANS 3.2 band are specified. sheet 3.5.2.7 Main Body The main body of the procedure contains the step-by-step See section 5.3.2 of instructions in the degree of detail necessary for performing the 3.5.1 on the ANS 3.2 required function or task. sheet 3.5.2.8 Acceptance Criteria The acceptance criteria provide the quantitative or qualitative See section 5.3.2 of criteria against which the success or failure of the step or action 3.5.1 on the ANS 3.2 (such as for a test type activity) would be judged. sheet 3.5.2.9 Checklists See section 5.3.2 of 3.5.1 on the ANS 3.2 Complex procedures should utilize checklists which may be 32

ANS 3.2 Side-By Side Comparison 7/25/2012 included as part of the procedure or appended to it. sheet 3.5.3 Plant Procedures Plant procedures provide instructions for controlling plant activities. Essentially, equivalent Typical examples of these types of plant procedures and their to ANS 3.2 1976, characteristics are as follows. section 5.3.4.

3.5.3.1 Administrative Control Procedures These include administrative procedures, directives, policies, Replacement for 5.1, 5.3.3 System Procedures.

standards, and similar documents that control the programmatic ANS 3.2 1976, more Instructions for energizing filling venting.

aspects of facility activities. These administrative documents general. No problems Draining, starting up. shutting down, ensure that the requirements of regulatory and license changing modes of operation and other identified. Ok.

commitments are implemented. Several levels of administrative instructions appropriate for operations of controls are applied ranging from those affecting the entire owner systems related to the safety of the plant Section 5.2 Rules of organization to those prepared at the implementing group level. shall be delineated in system procedures.

These documents establish responsibilities, interfaces, and Practice, replaced by Procedures for correcting off-normal standard methods (rules of practice) for implementing programs part 26 requirements. conditions shall be developed for those So ok to remove. events where system complexity may lead to operator uncertainty. System Section 5.2.1 is procedures shall contain check off lists elaborated in other where appropriate.

parts of the new ANS 3.2.

Different levels of detail than ANS 3.2 1976 version. Section 5.3.3.

3.5.3.2 Operating Orders/Procedures 5.2.3 Operating Order 5.2.3 Operating Orders Instructions of general and continuing applicability to the conduct of Similar to 1982 A mechanism shall be provided for A mechanism shall be provided for business to the plant staff are provided. Examples where these dissemination to the plant staff of dissemination to the plant staff of 33

ANS 3.2 Side-By Side Comparison 7/25/2012 are applied include, but are not limited to, job turnover and relief, version, Section 5.2.3. instructions of general and continuing instructions of general and continuing designation of confines of control room, definition of duties of applicability to .the conduct of business. applicability to the conduct of business.

operators and others, transmittal of operating data to management, Such instruction... ~, sometimes also Such instructions. sometimes also referred filing of charts, limitations on access to certain areas and referred to as standing orders or standard to as administrative procedures, standing equipment, shipping and receiving instructions. Provisions are operating procedures should deal with job orders or standard operating procedures, made for periodic review and updating of these documents, where turnover and relief, designation of confines should deal with job turnover and relief.

appropriate. of control room, definition of duties of designation of confines of control room, operators and others, transmittal) of definition of duties of operators and others, operating data to management, filing of transmittal of operating data to charts, limitations on access to certain management, filing of charts, limitations on areas and equipment, shipping and access to certain areas and equipment, receiving instructions, or other such shipping and receiving instructions. or matters. Provisions should be made for other such matters. Provisions shall be periodic review and updating of standing made for periodic review and updating of orders. operating orders.

3.5.3.3 Special Orders 5.2.4 Special Order 5.2.4 Special Orders Management instructions, which have short-term applicability and Essentially, equivalent A mechanism shall be provided for A mechanism shall be provided for issuing require dissemination, are issued to encompass special wording as ANS 3.2, issuing management instructions which management instructions which have operations, housekeeping, data taking, publications and their 1976 version, section have short-term applicability and which short-term applicability and which require distribution, plotting process parameters, personnel actions, or require dissemination. Such instructions dissemination. Such instructions, 5.2.4 other similar matters. Provisions are made for periodic review, sometimes referred to as special orders, sometimes referred to as special orders, updating, and cancellation of these documents, where appropriate. should encompass special operational, should encompass special operations, housekeeping, data taking, publication and housekeeping, data taking, publications their distribution, plotting process and their distribution, plotting process parameters, personnel actions or other parameters, personnel actions or other familiar material Provisions should be similar matters. Provisions shall be made made for periodic review, updating and for periodic review, updating and cancellation of special orders. cancellation of special orders.

3.5.3.4 Temporary Procedures 5.2.5 Temporary Procedures 5.2.5 Temporary Procedures Temporary procedures may be used to direct operations during Essentially, equivalent Temporary procedures may be issued Temporary procedures may be issued testing, refueling, maintenance, and modifications to provide wording as ANS 3.2, during the operational phase: to direct during the operational phase: to direct guidance in unusual situations not within the scope of the normal 1976 version, section operations during testing, refueling, operations during testing, refueling, procedures. These procedures ensure orderly and uniform maintenance and modifications; to provide 5.2.5 maintenance and modifications; to provide operations for short periods when the plant, a system, or a guidance in unusual situations not within component of a system is performing in a manner not addressed guidance in unusual situations not within the scope of the normal procedures; and to by existing detailed procedures or has been modified or extended the scope of the normal procedures; and ensure orderly and uniform operations for in such a manner that portions of existing procedures do not apply. to ensure orderly and uniform operations short periods when the plant, a system, or Temporary procedures include designation of the period of time for short periods when the plant, a system, a component of a system is performing in during which they may be used and are subject to the procedure or a component of a system is performing a manner not covered by existing detailed review process as applicable. in a manner not covered by existing procedures or has been modified or extended in such a manner that portions of detailed procedures or has been modified existing procedures do not apply.

or extended in such a manner that Temporary procedures shall include 34

ANS 3.2 Side-By Side Comparison 7/25/2012 portions of existing procedures do not designation of the period of time during apply. Temporary procedures shall which they may be used and shall be include designation of the period of time subject to the review process prescribed in 4.3 and 5.2.15 as applicable. Temporary during which they may be used and shall procedures shall be approved by the be subject to the review process management representative assigned prescribed in 4.3 and 5.2.15 as applicable. approval authority.

3.5.3.5 Engineering Procedures These documents provide instructions for the preparation of New section in line engineering documents, engineering analysis, and implementation with NQA-1 of engineering programs. This includes activities such as designs; requirements. Ok.

calculations; fabrication, equipment, construction, and installation specifications; drawings; analysis and topical reports; and testing plans or procedures. They include appropriate references to industry codes and standards, design inputs, and technical requirements. Additional criteria for these procedures are contained in ASME NQA-1-2008 and the NQA-1a-2009 addenda

[2].

3.5.3.6 Installation Procedures These documents provide instructions for the installation of New section in line components generally related to new construction and certain with NQA-1 modification activities. They include appropriate reference to requirements.

industry standards, installation specifications, design drawings, and Installation in operating supplier and technical manuals for the performance of activities.

These documents include provisions, such as hold or witness plants equivalent to points, for conducting and recording results of required inspections design and or tests. These documents may include applicable inspection and construction phase.

test instructions subject to the requirements for test and inspection procedures below.

3.5.3.7 System Procedures These documents contain instructions for energizing, filling, § venting, draining, starting up, shutting down, changing modes of operation, and other instructions appropriate for operations of New section similar to systems related to the safety of the plant. Actions to correct off- 1982 version Sections normal conditions are invoked following an operator observation or 35

ANS 3.2 Side-By Side Comparison 7/25/2012 an annunciator alarm indicating a condition which, if not corrected, 3.2 & 3.5.5.2.

could degenerate into a condition requiring action under an emergency procedure. Separate procedures may be developed for correcting off-normal conditions for those events where system complexity may lead to operator uncertainty 3.5.3.8 Start-up Procedures 5.3.4.1 Start-up Procedures 5.3.4.1 Start-up Procedures These documents contain instructions for starting the reactor from Essentially, equivalent Start-up procedures shall be provided that Start-up procedures shall be provided that cold or hot conditions and establishing power operation. This wording as ANS 1976 include starting the reactor from cold or include starting the reactor from cold or hot includes documented determination that prerequisites have been version, section 5.3.4.1 hot conditions and establishing power conditions and establishing power satisfied, including confirmation that necessary instruments are operation, with the generator synchronized operation, with the generator synchronized operable and properly set, valves are properly aligned, necessary to the line. Recovery from reactor trips to the line. Recovery from reactor trips system procedures, tests and calibrations have been completed, shall be in accordance with the start-up shall be in accordance with the start-up and required approvals have been obtained. procedure and shall be subject to the procedure and shall be subject to the determinations set forth in 5.2.1.1. determinations set forth in 5.2.1.1.

3.5.3.9 Shutdown Procedures 5.3.4.2 Shutdown Procedures 5.3.4.2 Shutdown Procedures These documents contain guidance for operations during Essentially equivalent Shutdown procedures shall be provided to Shutdown procedures shall be provided to controlled shutdown and following reactor trips, including wording as ANS 1976 guide operations during and following guide operations during and following instructions for establishing or maintaining hot shutdown/standby version, section controlled shutdown or reactor trips and controlled shutdown or reactor trips and or cold shutdown conditions, as applicable. The major steps shall include instructions for establishing shall include instructions for establishing or 5.3.4.2.

involved in shutting down the plant are specified, including or maintaining hot standby or cold maintaining hot standby or cold shutdown instructions for such actions as monitoring and controlling shutdown conditions as applicable. The conditions, AS applicable. The major steps reactivity, load reduction and cool down rates, sequence for major steps involved in shutting down the involved in shutting down the plant shall be activating or deactivating equipment, requirements for prompt plant shall be specified, including detailed specified, including detailed instructions for analysis for causes of reactor trips or abnormal conditions requiring instructions for the performance of such the performance of such actions as unplanned controlled shutdowns, and provisions for decay heat actions as monitoring and controlling monitoring and controlling reactivity, load removal. reactivity load reduction and cool down reduction, and cool down rates, sequence rates, sequence of activating or of activating or deactivating equipment, deactivating equipment, requirements for requirements for prompt analyses of prompt analyses of causes of reactor trips causes or reactor trips or abnormal or abnormal conditions requiring conditions requiring unplanned controlled unplanned controlled shutdowns, and shutdowns, and provisions for decay heat provisions for decay heat removal. Check removal. Check off lists shall be used for off list should be used for confirming the purpose of confirming completion of completion of major steps in proper major steps in proper sequence.

sequence.

3.5.3.10 Power Operation and Load Changing Procedures 5.3.4.3 Power Operation and Load 5.3.4.3 Power Operation and Load Changing Procedure. Change*

These documents contain instructions for steady-state power Essentially equivalent Procedures for steady- state power Procedures for steady-state power 36

ANS 3.2 Side-By Side Comparison 7/25/2012 operation and load changing. These type documents include, as wording as ANS 1976 operation and load changing shall be operation and load changing shall be examples, provisions for use of control rods, chemical shim, version, section provided that include, for example, provided that include, for example, coolant flow control, or any other system available for short-term or 5.3.4.3. provisions for use of control rods, chemical provisions for use of control rods, chemical long-term control of reactivity, making deliberate load changes, shim, coolant flow control or any other shim, coolant flow control or any other responding to unanticipated load changes, and adjusting operating system available for long or short-term parameters. control of reactivity, making deliberate load system available for long or short-term changes, responding to unanticipated load control of reactivity, making procedures, changes and adjusting operating deliberate load changes, responding to parameters. unanticipated load changes and adjusting

. operating parameters 3.5.3.11 Process Monitoring Procedures 5.3.4.4 Process Monitoring Procedures 5.3.4.4 Process Monitoring Procedures These documents contain instructions for monitoring performance Essentially equivalent Procedures for monitoring performance of Procedures for monitoring performance of of plant systems to assure that core thermal margins and coolant wording as ANS 1976 plant systems shall be required to assure plant systems shall be required to assure quality are maintained in acceptable status at all times, that version, section that core thermal margins and coolant that core thermal margins and coolant integrity of fission product barriers is maintained, and that quality are maintained at all times, that 5.3.4.4. quality are maintained at all times. that engineered safety features and emergency equipment are in a intergraded of fission product barriers is state of readiness to maintain the plant in a safe condition if maintained at all times and that engineered integrity of fission product barriers is needed. Maximum and minimum limits for process parameters are safety features and emergency equipment maintained at all times and that appropriately identified. Operating procedures address the are in a state of readiness to maintain the engineered safety features and appropriate nature and frequency of this monitoring. plant in a safe condition ( needed.. The emergency equipment are in a state of limit (maximum and minimum) (or readiness to maintain the plant in a safe significant process parameters shall be condition if needed. The limits ( maximum identified. 'The nature and frequency of this and minimum for significant process monitoring shall be covered by operating procedures. as appropriate. parameters shall be identified. The nature and frequency of this monitoring shall be covered by operating procedures, as appropriate.

3.5.3.12 Fuel Handling Procedures 5.3.4.6 Fuel-Handling Procedures 5.3.4.5 Fuel- Handling Procedures These documents contain instructions for core alterations, Essentially equivalent Fuel handling operations shall be .Fuel handling operations shall be accountability of fuel and partial or complete refueling operations wording as ANS 1976 performed in accordance with written performed in accordance with written that include, for example, continuous monitoring of neutron flux version, section procedures. These procedures shall procedures. These procedure shall throughout core loading, periodic data recording, audible specify actions for .core alterations, 5.3.4.5. specify instructions for use of refueling annunciation of abnormal flux increases, and evaluation of core accountability of fuel and partial or neutron multiplication to verify safety of loading increments. complete refueling operations that include, equipment, actions for core alterations, Procedures are also provided for receipt and inspection of new (or example, continuous monitoring of the accountability of fuel and partial or fuel, and for fuel movements in the spent fuel storage areas. Fuel neutron flux throughout core loading, complete refueling operations that handling procedures include prerequisites to verify the status of periodic recording of data, audible include, for example, continuous systems required for fuel handling and movement; inspection of annunciation of abnormal flux increases monitoring of the neutron flux: throughout replacement fuel and control rods; designation of proper tools, and evaluation of core neutron 37

ANS 3.2 Side-By Side Comparison 7/25/2012 proper conditions for spent fuel movement, proper conditions for multiplication to verify the safety of loading core loading, periodic recording of data, fuel cask loading and movement; and status of interlocks, reactor increments. Provisions shall be made for audible annunciation of abnormal flux trip circuits and mode switches. These procedures provide preparing specific procedures for each increase and evaluation of core neutron requirements for refueling, including proper sequence, orientation refueling outage and for receipt and multiplication to verify the safety of loading and seating of fuel and components, rules for minimum operable shipment of fuel. Plant procedures should, instrumentation, actions for response to fuel damage, verification of nonetheless, prescribe the general increments. Provisions shall be made for shutdown margin, communications between the control room and preplanning for the fuel-handling program preparing specific procedures for each the fuel handling station, independent verification of fuel and and its associated safety measures and refueling outage and for receipt and component locations, criteria for stopping fuel movements, and should identify those aspects of the shipment of fuel Plant procedures shall documentation of final fuel and component serial numbers (or other program for which procedures are to be prescribe the general preplanning for the unique identifiers) and locations. prepared for each refueling outage (1) fuel handling program and its associated Prerequisites. Prerequisites shall be safety measures and should identify those provided in the fuel-handling procedures that include, for example, the status of aspects of the program for which plant systems required for refueling; procedures are to be prepared for each inspection of replacement fuel, control rods refueling outage (1) Prerequisites.

poison curtains and internals; designation Prerequisites shall be provided in the fuel-of proper tools; proper conditions for spent handling procedures that include. for fuel movement; proper conditions for fuel example, the status of plant systems cask loading and movement; and status of required for refueling; inspection of interlocks reactor trip circuits and mode. (2)

Main Body. The main body of fuel hand line replacement fuel control rod!:, poison procedures shall include requirements for curtains and internals; designation of refueling; for sample, the status of the core, proper tools; proper conditions for spent instructions (or proper sequence, fuel movement.; proper conditions for fuel orientation. and seating of fuel and cask loading and movement; and status of components, rules for minimum operable interlocks, reactor trip circuits and mode instrumentation, actions to be followed in the event of fuel damage, rules for periods switches. (2) Main Body. The main body when refueling is interrupted, verification of of fuel handling procedures shall include the shutdown margin and the frequency of requirements for refueling; for example, determination, communications between the status of the core instructions for control room and the fuel loading station. proper :sequence, orientation, and seating independent verification of fuel and of fuel and components, rules for component location, criteria (or stopping minimum operable instrumentation, refueling and (or reducing the size of the fuel loading increment, and a containment actions to be followed in the event of fuel evacuation plan and its associated safe damage, administrative control of shift measures. Documentation of final fuel and changes rules for periods when refueling component serial numbers and locations is interrupted. Verification of the shutdown shall be maintained margin and the frequency of determination communications between control room and the fuel loading station.

Independent verification of fuel and 38

ANS 3.2 Side-By Side Comparison 7/25/2012 component location, criteria for stopping refueling and for reducing the size of the fuel loading increment and a containment evacuation plan and its associated safety measures.

Documentation of final fuel and component serial numbers and locations shall be maintained.

3.5.3.13 Maintenance Procedures These documents contain instructions in sufficient detail to permit maintenance work to be performed correctly and safely, and .

include provisions, such as hold or witness points, for conducting Essentially equivalent and recording results of required inspections or tests. These wording as ANS 1976 documents may include applicable inspection or test instructions version, section 5.3.5.

subject to the requirements for test and inspection procedures below. Appropriate referencing to other procedures, standards, specifications, or supplier manuals is provided. When not provided through other documents, instructions for equipment removal and return to service, and applicable radiation protection measures NRC did not endorse (such as protective clothing and radiation monitoring) will be 2.18 of NQA-1 in RG included. Additional maintenance procedure requirements are 1.33 addressed in ASME NQA-1-2008 and the NQA-1a-2009 addenda, Subpart 2.18 [2].

3.5.3.14 Radiation Control Procedures These documents contain instructions for implementation of the Essentially, equivalent radiation control program requirements necessary to maintain wording as ANS 1976 compliance with regulatory commitments, including acquisition of version, section 5.3.6.

data and use of equipment to perform necessary radiation surveys, Ok measurements and evaluations for the assessment and control of radiation hazards. These procedures provide requirements for monitoring both external and internal exposures of employees, utilizing accepted techniques; routine radiation surveys of work areas; effluent and environmental monitoring in the vicinity of the plant; radiation monitoring of maintenance and special work activities, and for maintaining records demonstrating the adequacy of measures taken to control radiation exposures to employees 39

ANS 3.2 Side-By Side Comparison 7/25/2012 and others.

3.5.3.15 Calibration and Test Procedures These documents contain instructions for periodic calibration and Essentially, equivalent testing of instrumentation and control systems, and for periodic wording as ANS 1976 calibration of measuring and test equipment used in activities version, Section 5.3.7.

affecting the quality of these systems. These documents provide Ok.

for meeting surveillance requirements and for assuring measurement accuracy adequate to keep safety-related parameters within operational and safety limits. Additional requirements for these procedures are contained in ASME NQA 2008 and the NQA-1a-2009 addenda [2].

3.5.3.16 Chemical and Radiochemical Control Procedures These documents contain instructions for chemical and Essentially equivalent radiochemical control activities and include: the nature and wording as ANS 1976 frequency of sampling and analyses; instructions for maintaining version, section 5.3.8.

coolant quality within prescribed limits; and limitations on Ok.

concentrations of agents that could cause corrosive attack, foul heat transfer surfaces, or become sources of radiation hazards due to activation. These documents also provide for the control, treatment, and management of radioactive wastes, and control of radioactive calibration sources.

3.5.3.17 Emergency Operating Procedures 5.3.9 Emergency Procedures 5,3.9 Emergency Procedures These documents contain instructions for response to potential Revised section. Procedures shall be provided to guide Procedures shall be provided to guide emergencies so that a trained operator will know in advance the operations during potential emergencies, operations during potential emergencies.

expected course of events that will identify an emergency and the They shall be written so that a trained They shall be written so that a trained immediate actions that should be taken in response. Format and operator will know in advance the expected operator will know the action he should content of emergency procedures are based on regulatory and course of events that will identify an Owners Group(s) guidance for the plant type that identify potential emergency and the immediate action he take. Since emergencies may not follow emergency conditions and generally require such procedures to should take. Since emergencies may not anticipated patterns. the procedures include, as appropriate, a title, symptoms to aid in identification of follow anticipated patterns the procedures should provide sufficient flexibility to the nature of the emergency, automatic actions to be expected should provide sufficient flexibility to accommodate variations. These from protective systems, immediate operator actions for operation accommodate variations. Emergency procedures may be based upon plant 40

ANS 3.2 Side-By Side Comparison 7/25/2012 of controls or confirmation of automatic actions, and subsequent procedures that cover actions for symptoms or plant event or both operator actions to return the reactor to a normal condition or manipulations of controls to prevent Symptomatic procedures specify operator provide for a safe extended shutdown period under abnormal or accidents or lessen their consequences actions based on the determination of the emergency conditions. should be based on a general sequence of plant status. Event procedures specify observations and actions. Emphasis should be placed on operator responses to operator actions based on the observational and indications in the control determination of the event. The content room that is, when immediate operator and format of symptomatic procedures are actions are required to prevent or mitigate not covered in this standard. An the consequences of a serious condition, acceptable format and content for event procedures should require that those procedures is given in 5.3.9.1. Emergency actions be implemented promptly. The procedures that cover actions for emergency procedure format given in 5.3.9.1 provides a basis for coping with manipulations of control to prevent emergencies and is an acceptable format accidents or lessen their consequences for prescribing operator observations and should be based on a general sequence of actions. Emergency procedures may observations and actions. Emphasis shall contain supplemental background be placed on operator responses to information to further aid operators in observations and indications in the control taking proper emergency action&, but this room; that is, when operator actions are information shall be separated from the procedural actions. It is extremely difficult required to prevent or mitigate the to distinguish between procedures consequences of a serious condition.

prepared (or the purpose of connecting off* procedures shall require that those actions normal conditions which in themselves do be implemented in a timely fashion.

not compatible actual emergency Emergency procedures may contain situations, but which conceivably can supplemental background information to degenerate into true emergencies in the absence of positive corrective action. and aid operators further in taking proper procedures required for coping with true emergency actions, but this information emergencies that have already occurred shall be separated from the procedural Some owner organizations choose the term actions. When initially available "Off normal procedure" for the same intelligence provided to operating purpose that others choose "Emergency personnel via instrument readings, Procedures." When initially available physical conditions, and personal intelligence provided to operating personnel via instrument readings, physical observations may not indicate clearly the condition&, and personal observations may difference between a simple operational not clearly indicate the difference between problem and a serious emergency, the a simple operational problem and a serious actions outlined in the emergency emergency, the actions outlined in the procedures shall be based on a emergency procedures shall be based on a conservative course of action by the conservative course of action by the operating crew. Departure from the operating crew. Considerable judgment on the part of competent personnel is required emergency procedure shall require the 41

ANS 3.2 Side-By Side Comparison 7/25/2012 before departing room the emergency prior approval of the off-duty shift procedure. supervisor or, if the on-duty shift supervisor is unavailable, the licensed senior operator in the control room.

Signals that initiate engineered 3.5.3.18 Emergency Plan Implementing Procedures 5.3.9.3 Procedure for Implementing 5.3.9.3 Procedure for Implementing Emergency Plan Emergency Plan These documents contain instructions for activating the Emergency Revised section. Implementing procedures for emergency Implementing procedures for emergency Response Organization and facilities, protective action levels, plan actions shall contain, as appropriate, plan actions shall contain, as appropriate, organizing emergency response actions, establishing necessary the following elements: the following elements:

communications with local, state and federal agencies, and for periodically testing the procedures, communications and alarm (1) Individual assignment of authorities and (1) Assignment of authority and systems to assure they function properly. Format and content of responsibilities for performance of specific responsibilities for performance of specific these procedures are such that requirements of each facilitys nuclear regulator approved Emergency Plan are satisfied. tasks to specific individuals or staff tasks to operating staff positions. (21 positions. (2) Protective action level and Protective action levels and protective protective measurers outlined for the measures outlined for the emergency emergency identified. (3) Specific actions to identified. (31 Specific actions to be taken be taken by coordinating support group.(4) by coordinating support groups. (4)

Procedures for medical treatment and Procedures for medical treatment and handling of contaminated individuals.(5) handling of contaminated individuals (5)

Special equipment requirements (or items Special equipment requirements for items such as medical treatment. emergency such as medical treatment, emergency personnel removal, specific radiation personnel removal, specific radiation detection. personnel doeimetry and rescue detection personnel dosimetry and rescue operations. procedures for making this operations procedures for making this equipment available, plus operating equipment available plus operating instructions for such equipment, and instructions for such equipment, and provisions for its periodic inspection and provisions for its periodic inspection and maintenance. (6) Identification of maintenance. (6) Identification of emergency communications network, emergency communications network, including communications required for including communications required for personnel identification and effective personnel identification and effective coordination of all support groups. (7) coordination of all support groups. (7)

Description of alarm signal in each facility. Description of alarm signal in each facility.

At sites with multiple units, alum signals At sites with multiple units. Alarm signals should be consistent from one unit to should be consistent from one unit to another. (Signals for initiating protective another. (Signals for initiating protective 42

ANS 3.2 Side-By Side Comparison 7/25/2012 measures should be clear and distinct from measures should be dear and distinct from process or operational alarm system to process or operational alarm system to avoid confusion. (8) Produces required to avoid confusion. (8) Procedures required restore the plant to normal conditions to restore the plant to normal or safe following an emergency (9) Requirements shutdown conditions following an for periodically testing of procedures emergency. (9) Requirements for periodic communications network and alarm testing of procedures communications systems to assure that they function network and alarm systems to assure that properly. they function properly.

See also U.S. Nuclear Regulatory For additional guidance see the following Commission (NRC) "Guide to the American National Standards: Facilities Preparation of Emergency Plans (or and Medical Care for Onsite Nuclear Production and Utilization facilities," Power Plant Radiological Emergencies.

ANSI/ANS 3.2.1-1979:

Emergency Control Centers for Nuclear Power Plants. ANSI/ANS 3.2 979: and Radiological Emergency Preparation Exercises for Nuclear Power Plants, ANSI ANS 3.2 1979.

3.5.3.19 Test and Inspection Procedures 5.3.10 Test and Inspection Procedures 5.3.10 Test and Inspection Procedures These documents provide the necessary measures to assure Essentially equivalent Test and inspection procedures shall contain a Test and inspection procedures shall quality is achieved and maintained for the nuclear facilities. The wording as ANS 1976 description of objectives; acceptance criteria t contain: a description of objectives; instructions for tests and inspections may be included within other version, section 5.3.10. used to evaluate the results; prerequisites for acceptance criteria that will be used to procedures, such as installation and maintenance procedures, but performing the tests or inspections including a evaluate the results: prerequisites for will contain the objectives, acceptance criteria, prerequisites for performing the test or inspection, limiting conditions, and conditions to be used. to simulate normal or a performing the tests or inspections appropriate instructions for performing the test or inspection, as operating conditions; limiting conditions; and t including any special conditions to be used applicable. These procedures also specify any special equipment inspection procedure. These procedures shall 1.0 simulate normal or abnormal operating or calibrations required to conduct the test or inspection and specify any special equipment or calibrations conditions: limiting conditions: and the test provide for appropriate documentation and evaluation by to conduct the test or inspection. Test and ins or inspection procedure, including or responsible authority to assure test or inspection requirements results shall be documented and evaluated by referencing instruction, for restoration of have been satisfied. Where necessary, hold or witness points are responsible authority to assume that test and the system to the condition consistent with identified within the procedures and require appropriate approval for the work to continue beyond the designated point. These requirements have been satisfied. the normal plant operating status,. If procedures provide for recording the date, identification of those applicable. These procedures shall also performing the test or inspection, as-found condition, corrective Where test and inspections are to be specify any special equipment or actions performed (if any), and as-left condition, as appropriate for witnessed, the procedure shall identify hold calibrations required to conduct the test or 43

ANS 3.2 Side-By Side Comparison 7/25/2012 the subject test or inspection. Additional criteria for these points in the testing sequence to permit inspection. Test and inspection results procedures are contained in ASME NQA-1-2008 and the NQA-1a- witnessing. The procedure shall require shall be documented and evaluated by the 2009 addenda [2]. appropriate approval (or the work to responsible authority to assure that test continue beyond the implanted hold point. and inspection requirements have been The test and inspection procedures shall satisfied. Where tests and inspections are require recording the date, identification of to be witnessing the procedure ,hall those performing the test or inspection. As identify hold points in the testing found condition corrective actions !Sequence to permit witnessing The performed, if any, and as-left condition. procedure shall require appropriate approval for the work to continue beyond the designated hold point. The test and inspection procedures shall require recording the date identification of those performing the test or inspection. As found condition corrective actions performed . If any and as-left condition.

3.6 Document Control 5.2.13.1 Procurement Document 5.2.15 Review, Approval, and Control Control of Procedures Document control activities associated with SSCs shall be Revision to 1976 Measures shall be provided to assurance The administrative controls and quality accomplished in accordance with ASME NQA-1-2008 and the version section that applicable regulatory requirements, assurance program shall provide NQA-1a-2009 addenda [2]. The following requirements apply to 5.2.13.1. Previous design bases and other requirements measures to control and coordinate the plant procedures utilized during the operational phase.

requirements were which are necessary to assure adequate approval and issuance of documents, addressed by NQA-1. quality are included or referenced in the including changes thereto which prescribe Ok. procedures for procurement of items and all activities affecting quality.

services. To the extent necessary, procurement documents shell require Such documents include those which suppliers to provide a quality assurance describe organizational interfaces. or program consistent with the pertinent which prescribe activities affecting requirements of American National structures, systems or components Standard Quality Assurance Program important to safety. These documents Requirement for Nuclear Power Plants, also include operating and special order N4.S.2-1971. Where changes are made to operating procedures emergency and off procurement documents, they shall be normal procedures, test procedures, subject to the same degree of control as equipment control procedures was used in the preparation or the original maintenance or modification procedures, documents. Procurement documents shall refueling procedures, and material control include provisions for the following. as procedures. These measures shall assure 44

ANS 3.2 Side-By Side Comparison 7/25/2012 applicable: that documents, including revisions or changes, are reviewed for adequacy by (I) Supplier Quality Assurance Program. appropriately qualified personnel and Identification of quality assurance approved for release by authorized requirements applicable to the items or personnel: and are distributed in services procured. accordance with current distribution lists and used by the personnel performing the (2) Basic Technical Requirements Where prescribed activity, and that procedures specific technical requirements apply, such are provided to avoid the misuse of as drawings, specifications, and industrial outdated or inappropriate codes and standards, they shall be identified by title and dates of issue in such Procedures for operational phase a way as to clearly set forth the applicable activities of a nuclear power plant reflect documents. Where procedural the conditions that exist at the time the requirements apply, in such areas as test procedures are written. These conditions and inspection needs, fabrication, cleaning include the technical information erecting, packaging, handling, shipping, available, industry experience. and in the and storage, they too, shall be identified case of the initial procedure fully for a new clearly and in such a way as to avoid plant assumptions made regarding the uncertainty as to source and need. detailed behavior of the plant that may not be fully known prior to operation_ In order (3) Source Inspection and Audit Provisions to ensure that the procedures in current for access to the supplier's facilities and use provide the best possible instructions records for source inspection and audit for performance of the work involved when the need for such inspection or audit systematic review and feedback of shall be determined. information based on use is required documents.

(4) Documentation Requirements records to be prepared, maintained, submitted or Each procedure shall be reviewed and made available for review, such as drawing approved prior to initial use. The specifications, procedures, procurement frequency of subsequent review shall be documents, inspection and test records. specified and may vary depending on the personnel and procedure qualifications, type and complexity of the activity and material, chemical, and physical test involved and may vary with time as a requirements ETC given plant reaches operational maturity.

Applicable procedures shall be reviewed following an unusual incident such as an accident an unexpected transient, significant operator error. Or equipment 45

ANS 3.2 Side-By Side Comparison 7/25/2012 malfunctions. Applicable procedures shall be reviewed following any modification to For the first time owners (or licensees) of a unit from a particular nuclear steam supply system (NSSS) vendor the initial issuance of fuel loading and post fuel loading startup test procedure emergency procedures related to the NSSS, and system operating procedures for systems important to safety shall be reviewed by the appropriate design organization prior to approval.

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 for routine follow up review can be accomplished in several ways, including, but not necessarily limited to documented step-by-step use of the procedure, such as occurs when the procedure has a step-by-step check off associated with it or detailed scrutiny of the procedure as part of a documented training program. drill, simulator exercise. or other such activity.

A revision of a procedure constitutes a procedure review Procedures shall be approved by the owner organization before initial use.

Rules shall be established which provide for interdisciplinary review of procedures by knowledgeable personnel other than the originator and the approval of procedures and procedure channel by 46

ANS 3.2 Side-By Side Comparison 7/25/2012 authorized individuals.

Changes to documents shall be reviewed and approved by the same organizations that perform the original review and approval unless the owner organization designates another qualified organization The reviewing organizations shall have access to pertinent background information upon which to base its approval and shall have adequate understanding of requirement and intent of the original document.

Those participating in any activity shall be made aware of and use proper and current instructions, procedures, drawings, and engineering requirements for performing the activity.

Participating organizations shall have procedures for control of the documents and changes thereto to preclude the possibility or use of outdated or inappropriate documents.

Document control measures shall provide for:

(1) Identification of individuals or organizations responsible for preparing, reviewing, approving and issuing documents and revisions thereto (2) Identifying the proper document 1.0 be used in performing the activity (3) Coordination and control of interlace 47

ANS 3.2 Side-By Side Comparison 7/25/2012 documents (4) Ascertaining that proper procurements and proper revisions are being used (5) Establishing current and updated distribution lists The method, by which both permanent and temporary changes to approved procedures are made, shall be implemented through a procedure and shall include the designation of a person or persons authorized to approve such changes.

Plant procedures shall be reviewed by an individual(s) knowledgeable in the aspects of the technical content and of human factors affected by the procedure within six months following startup after the first refueling outage of the unit to determine if changes are necessary or desirable. Applicable procedures shall also be reviewed following an unusual incident, such as an accident, an unexpected transient, significant operator error, or equipment malfunction, or following any modification to a system, or prior to use if the procedure has not been used in the previous two years.

Technical review of documents affecting the plant should be Consider deleting this accomplished to verify technical accuracy and to determine that paragraph. This would no conflicts with Technical Specifications exist and no proposed be addressed by 50.36 changes require prior NRC approval. If a Technical Specification

& by the independent change is needed or prior NRC approval is required, changes proposed by the documents under review shall not be review requirements implemented until required approvals are obtained. The reviewers that are being moved to shall be other than the individuals who prepared the document. NQA-1.

The technical review is the first step in the formal review process.

The reviewer shall determine if additional cross-disciplinary review is required. Conflicts that develop shall be addressed and resolved prior to approval. Successful completion of the review shall be documented.

48

ANS 3.2 Side-By Side Comparison 7/25/2012 Procedures shall be updated, as necessary, based on the results of the above reviews, or when procedure discrepancies are found such as through normal use or QA audits.

3.7 Control of Purchased Material, Equipment and Services Addressed by NQA-1.

Ok.

Control of purchased materials and services including the procurement and dedication of commercial grade items shall be accomplished in accordance with ASME NQA-1-2008 and the NQA-1a-2009 addenda [2].

Procedure(s) shall be implemented to aid in the identification of New revision to counterfeit and fraudulently marketed products. As a minimum, standard. Adding procedure(s) shouldinclude selective inspections and testing of CF&SI guidance.

products to verify compliance with procurement requirements when Detail is sufficient. Ok.

products are suspect.

3.8 Identification and Control of Materials, Parts and Components Identification and control of materials, parts, and components shall Essentially, equivalent be accomplished in accordance with ASME NQA-1-2008 and the to NQA- l. Ok.

NQA-1a-2009 addenda [2].

3.9 Control of Special Processes Special processes such as welding, heat treating, chemical Essentially, equivalent cleaning, applied coatings, and nondestructive examination shall to NQA- l. Ok.

be controlled in accordance with ASME NQA-1-2008 and the NQA-1a-2009 addenda [2].

3.10 Inspection Inspection activities shall be accomplished in accordance with Essentially, equivalent 49

ANS 3.2 Side-By Side Comparison 7/25/2012 ASME NQA-1-2008 and the NQA-1a-2009 addenda [2]. to NQA- l. Ok.

With respect to inspection of operating activities (work functions Essentially, equivalent associated with normal operation of the plant, routine to NQA- l. Ok.

maintenance, and certain technical services routinely assigned to the onsite operating organization), the inspections may be carried out by personnel experienced in and knowledgeable of the scope, complexity, and nature of the work activity that they have not performed or directly supervised. For modifications and non-routine maintenance, inspections are to be conducted in a manner similar (frequency, type, and personnel performing such inspections) to that associated with construction phase activities.

3.11 Test Control Test activities shall be controlled in accordance with ASME NQA- Essentially, equivalent 1-2008 and the NQA-1a-2009 addenda [2]. Controls shall be to NQA- l. Ok.

established for operational phase surveillance, calibration, and in-service inspection and testing activities.

Tests during the preoperational period shall be conducted to demonstrate that the performance of facility systems is in accordance with its design intent and that the coordinated operation of the facility as a whole is satisfactory, to the extent feasible. The preoperational testing program shoulddemonstrate, as nearly as can be practicably simulated, the overall integrated operation of the plant systems at rated conditions, including simultaneous operation of auxiliary systems. It may be necessary to defer portions of these tests until nuclear heat is available.

Tests during the initial operational phase shall be conducted to demonstrate the performance of systems that could not be tested prior to operation and to confirm those physical parameters, hydraulic or mechanical characteristics that need to be known, but which could not be predicted with the required accuracy, and to confirm that behavior conforms to design criteria.

3.11.1 Tests Associated with Plant Maintenance, Modifications or Procedure Changes 50

ANS 3.2 Side-By Side Comparison 7/25/2012 Tests shall be performed following plant modifications or Essentially equivalent significant changes in operating procedures to confirm that the wording in ANS 1976 modifications or changes reasonably produce expected results version, section and that the change does not reduce safety of operations.

5.2.19.3 3.12 Control of Measuring and Test Equipment Measuring and test equipment shall be controlled in accordance Essentially, equivalent with ASME NQA-1-2008 and the NQA-1a-2009 addenda [2]. to NQA- l. Ok.

3.13 Handling, Storage and Shipping Handling, shipping, and storage activities shall be accomplished in Essentially, equivalent accordance with ASME NQA-1-2008 and the NQA-1a-2009 to NQA- l. Ok.

addenda [2]. Additional requirements are addressed in ASME NQA-1-2008 and the NQA-1a-2009 addenda, Subpart 2.2 [2].

3.14 Inspection, Test and Operating Status Inspection, test and operating status shall be accomplished in Items already accordance with ASME NQA-1-2008 and the NQA-1a-2009 addressed in NQA-1.

addenda [2]. The following requirements shouldbe employed Ok.

during the operational phase.

(1) Equipment shall be controlled, as necessary, to maintain Essentially, equivalent personnel and reactor safety and to avoid unauthorized to NQA- l. Ok.

operation of equipment.

(2) Control measures such as locking or tagging to secure and Essentially, equivalent identify equipment in a controlled status shall be required. to NQA- l. Ok.

Independent verifications shall be conducted to ensure that necessary measures, such as tagging equipment, have been implemented correctly. Tagouts shall be designed and installed to prevent obstruction of other controls or indications.

(3) The status of equipment undergoing inspections, calibrations, Essentially, equivalent maintenance and modification activities and tests shall be to NQA- l. Ok.

identified.

51

ANS 3.2 Side-By Side Comparison 7/25/2012 Essentially, equivalent (4) Control room indicators and operating devices that are to NQA- l. Ok.

out-of-service shall be appropriately tagged or labeled or provided by a suitable means when applied to electronic displays where affixing a physical tag would not be feasible.

Essentially, equivalent (5) Items which have not satisfactorily passed required inspections, calibrations or tests shall be identified. In cases to NQA- l. Ok.

where required documentary evidence is not available to demonstrate that items have passed inspections, calibrations or tests required by Technical Specifications, affected items shall be considered inoperable and reliance shall not be placed on them to fulfill their intended safety function(s).

Local identification of deficiencies in equipment which require correction should be provided.

5.2.6 Equipment Control 5.2.6 Equipment Control (6) Permission to release plant systems or equipment for maintenance or tests shall be granted by designated operating Permission to release equipment or Procedures shall be provided for control of personnel holding a senior operator license who have been designated responsibility for granting such activities. Prior to systems for maintenance shall be granted equipment, as necessary, to maintain granting permission, such operating personnel shall verify that by designated operating personnel. Prior to personnel and reactor safety and to avoid the equipment or system may be safely released, determine granting permission, such operating unauthorized operation of equipment.

how long it may be out of service, and determine what personnel shall verify that the equipment or These procedures shall require control functional testing or redundant systems are required prior to and system can be released and determine measures such as locking or tagging to during the out-of-service period. Granting of such permission how long it may be out of service, Granting secure and identify equipment in a shall be documented. Independent verification shall be provided to the extent necessary to ensure that the proper of such permission shall be documented. controlled status. Control room & gouts system was removed from service. This may be accomplished Attention shall be given to the potentially shall be designed and installed to prevent by checking appropriate equipment and controls, or by indirect degraded degree of protection when one obstruction of other instruments, controls, means such as observation of indicators and status lights. This subsystem of a redundant safety system or indicating lights. Procedures shall also requirement may be waived if the only way of accomplishing it has been removed (or maintenance, require that the status of inspection and would result in significant radiation exposure. Attention shall be tests performed upon individual items in given to the degraded protection available when a subsystem of After permission has been granted to the nuclear power plant be indicated by a redundant safety system has been removed for remove the equipment (room service, it the use of markings such as stamps, tags, maintenance or surveillance testing.

shall be made are to work on. Measures labels. Routing cards or other suitable shall provide (or protection of equipment means. Suitable means include and workers, Equipment and systems in a identification numbers which are traceable controlled status shall clearly identified. to records of the status of inspections and Strict control measures for such equipment tests. Procedures shall also provide for shall be enforced. the identification of items which have not satisfactorily passed required inspections Conditions to be considered in preparing and tests, where necessary, to preclude 52

ANS 3.2 Side-By Side Comparison 7/25/2012 equipment for maintenance include, for inadvertent bypassing of such inspections example: shutdown margin; method of and tests. In cases where require emergency core cooling,; establishment of documentary evidence isnt available, the B path for decay heat removal; temperature associated equipment or materials must and pressure of the system; valves be considered nonconforming in between work and hazardous material; accordance with 5.2.14. Until suitable venting, draining, and flushing; entry into documentary evidence is available to closed vessels; hazardous atmospheres show the equipment or material is in handling hazardous materials; and conformance affected systems shall be electrical hazards. When entry into a considered to be inoperable and reliance closed system is required, control shall not be placed on such systems to measures shall be established to prevent fulfill their intended safety functions.

entry of extraneous material and to assure that foreign material is removed before the Permission to release plant systems or system is reclosed Equipment, as equipment for maintenance or necessary, to maintain personnel and surveillance tests shall be granted by reactor l entry and to avoid unauthorized designated operating personnel operation of equipment.

Holding a senior operator license. Prior to Procedures shall be provided for control of granting permission, such operating equipment, as necessary, to maintain personnel shall verify that the equipment personnel and reactor safety and to avoid or system can be released. determine unauthorized operation of equipment. how long it may be out of service and These procedures shall require control determine what functional testing of measures such as locking or tagging to redundant systems is required prior to secure and identify equipment in controlled and during the out-of service period.

status. The procedure shall require Granting of such permission shall be independent verification where appropriate, documented. Attention shall be given to to ensure that necessary measure such as the potentially degraded degree of tagging equipment has been implemented protection when one subsystem of a correctly. Temporary modification such as redundant safety system has been temporary bypass lines electrical jumpers removed for maintenance or surveillance lifted electrical leads and temporary trip testing. In addition to the requirements of point settings shall be controlled by the Technical Specifications additional approved procedures which shall include conditions to be considered in preparing the requirements for independent equipment for maintenance or verification. A log shall be maintained of the surveillance testing include, for example; current status of such temporary shutdown margin: method of emergency core cooling; establishment of a path for 53

ANS 3.2 Side-By Side Comparison 7/25/2012 modifications decay heat removal: temperature and pressure of the system: valves between The procedures shall also require that the work and hazardous material; venting, status of inspections and tests performed draining and flushing; entry into closed upon individual items on the nuclear power vessels; hazardous atmospheres; plant be indicated by the use of markings handling hazardous materials; and such as stamps, tags, labels, routing cards, electrical hazards. When entry into a or other suitable means. Suitable means closed system is required, control include identification numbers, which are measures shall be established top vent traceable to records of the status of entry of extraneous material and to assure inspections and tests. Procedures shall that foreign material is removed before the also provide for the identification of items system is reclosed. After permission has which has satisfactorily passed required been granted to remove a system from inspections and tests, where necessary to service, it shall be made safe to work on.

preclude inadvertent bypassing of such Measures shall provide for protection of inspections and tests fn cases where equipment and workers. Equipment and required documentary evidence is not systems in a controlled status shall be available, the associated equipment or clearly identified, at a minimum, at any materials must be considered location where the equipment can be nonconforming in accordance with Section operated. When a system important to 5.2.14. Until suitable documentary safety is removed from service, evidence is available to show the independent verification shall be provided equipment or material is in conformance, to the extent necessary to assure that the affected systems shall be considered proper system was removed. This may be inoperable and reliance shall not be placed accomplished by checking appropriate on such systems to fulfill their intended equipment and controls, or by indirect safety functions. When equipment is ready means such as observation of indicators to be returned to service, operating and status light. This requirement may be personnel shall place the equipment in waived if the only way of accomplishing it operation and verify and document its would result in significant radiation functional acceptability, Attention shall be exposure. Reactor operators and the shift given to restoration of normal conditions, supervisor shall be informed of changes in such as removal of jumpers or signals used equipment status and the effects of such in maintenance or testing or such as re changes. Temporary modifications, such turning valves, breakers or switches to as temporary bypass lines electrical proper start-up or operating positions from jumpers, lifted electrical leads, and "test" or "manual" position". When placed temporary trip point settings, shall be into service the equipment should receive controlled by approved procedures which additional surveillance during the run-in shall include a requirement for 54

ANS 3.2 Side-By Side Comparison 7/25/2012 period. independent verification by either a second person or by a functional test which conclusively proves the proper installation or removal of the temporary modification. A log or other documented evidence shall be maintained of the current status of such temporary modifications. When equipment I, ready to be returned to service. Operating personnel shall place the equipment in operation and verify and document its functional acceptability. Attention shall be given to restoration of normal conditions, such as removal of jumpers or signal used in maintenance or testing or such as returning valves. breaker or switches to proper startup or operating positions from "test" or "manual position, and assuring that all alarms which are indicative of inoperative status are extinguished. For equipment important to safety, proper alignment shall be independently verified by a second qualified person unless all equipment. Valves. and switches involved in the activity can be proven to be in their correct alignment by functional testing without. Adversely affecting the safety of the plant. A second inspection is where such verification would result. in significant radiation exposure. The person who performs the verification of correct implementation of equipment control measures or proper alignment prior to returning equipment to service shall be qualified to perform such tasks for the particular system involved, and shall process operating knowledge of the particular system involved and its 55

ANS 3.2 Side-By Side Comparison 7/25/2012 relationship to plant safety.

5.2.6 Equipment Control 5.2.6 Equipment Control (7) In addition to limiting conditions for operation and allowed outage times in Technical Specifications, additional conditions Permission to release equipment or When equipment is, ready to be returned to to be considered in preparing equipment for maintenance or surveillance testing may include: shutdown risk; shutdown systems for maintenance shall be granted service operating personnel shall place the margin; method of emergency core cooling; establishment of a by designated operating personnel. Prior to equipment in operation and verify and path for decay heat removal; temperature and pressure of the granting permission, such operating document its functional acceptability.

system; valves between work and hazardous material; venting, personnel shall verify that the equipment or Attention shall be given to restoration of draining and flushing; entry into closed vessels; hazardous system can be released. and determine normal conditions, such as removal of atmospheres and ALARA considerations; handling hazardous how long it may be out of service, Granting jumpers or signals used in maintenance or materials; and electrical hazards. When entry into a closed system is required, entry of extraneous material shall be of such permission shall be documented. testing or such as returning valves. breaker prevented. Any foreign material shall be removed and the Attention shall be given to the potentially or switches to proper startup or operating removal verified before the system is re-closed. Foreign degraded degree of protection when one positions from "test" or "manual positions material may be allowed to remain if an analysis is performed to subsystem of a redundant safety system and assuring that all alarms which are demonstrate that the material would not adversely affect plant has been removed (or maintenance, indicative of in inoperative status are safety. extinguished. For equipment important to After permission has been granted to safety, proper alignment shall be remove the equipment (room service, it independently verified by a second qualified shall be made are to work on. Measures person unless all equipment, valves, and shall provide (or protection of equipment switches involved in the activity can be and workers, Equipment and systems in a proven to be in their correct alignment by controlled status shall clearly identified. functional testing without adversely Strict control measures for such equipment affecting the safety of the plant. A second shall be enforced. inspection is where such verification would result in significant radiation exposure. The Conditions to be considered in preparing person who performs the verification of equipment for maintenance include, for correct implementation of equipment control example: shutdown margin; method of measures or proper alignment prior to emergency core cooling,; establishment of returning equipment to service shall be B path for decay heat removal; temperature qualified to perform such verification for the and pressure of the system; valves particular system involved, and shall between work and hazardous material; possess operating knowledge of the venting, draining, and flushing; entry into particular system closed vessels; hazardous atmospheres handling hazardous materials; and electrical hazards. When entry into a closed system is required, control measures shall be established to prevent entry of extraneous material and to assure 56

ANS 3.2 Side-By Side Comparison 7/25/2012 that foreign material is removed before the system is reclosed. equipment. as necessary, to maintain personnel and reactor l entry and to avoid unauthorized operation of equipment.

Procedures shall be provided for control of equipment. as necessary, to maintain personnel and reactor safety and to avoid unauthorized operation of equipment.

These procedures shall require control measures such as locking or tagging to secure and identify equipment in controlled status. The procedure shall require independent verification where appropriate, to ensure that necessary measure such as tagging equipment has been implemented correctly. Temporary modification such as temporary bypass lines electrical jumpers lifted electrical leads and temporary trip point settings shall be controlled by approved procedures which shall include the requirements for independent verification. A log shall be maintained of the current status of such temporary modifications The procedures shall also require that the status of inspections and tests performed upon individual items on the nuclear power plant be indicated by the use of markings such as stamps, tags, labels, routing cards, or other suitable means. Suitable means include identification numbers, which are traceable to records of the status of inspections and tests. Procedures shall also provide for the identification of items which has satisfactorily passed required inspections and tests, where necessary to 57

ANS 3.2 Side-By Side Comparison 7/25/2012 preclude inadvertent bypassing of such inspections and tests fn cases where required documentary evidence is not available, the associated equipment or materials must be considered nonconforming in accordance with Section 5.2.14. Until suitable documentary evidence is available to show the equipment or material is in conformance, affected systems shall be considered inoperable and reliance shall not be placed on such systems to fulfill their intended safety functions. When equipment is ready to be returned to service, operating personnel shall place the equipment in operation and verify and document its functional acceptability, Attention shall be given to restoration of normal conditions, such as removal of jumpers or signals used in maintenance or testing or such as re turning valves, breakers or switches to proper start-up or operating positions from "test" or "manual" position". When placed into service the equipment should receive additional surveillance during the run-in period.

5.2.6 Equipment Control 5.2.6 Equipment Control (8) A plant system(s) or component(s) shall be made safe to work on after permission has been granted to remove it from service.

(See Above) (See Above)

Equipment and systems in a controlled status shall be clearly identified at any location where the equipment can be operated.

Control room supervision shall be promptly informed of changes in equipment status, including temporary modifications, and the effects of such changes. Equipment, which is in other than normal condition, shouldbe readily identifiable to the operating staff.

58

ANS 3.2 Side-By Side Comparison 7/25/2012 (9) Temporary plant modifications shall be clearly identified at the 5.2.6 Equipment Control 5.2.6 Equipment Control installed location(s) and at any location of operation which could be affected by the temporary modification. (See Above) (See Above)

(10) When equipment is ready to be returned to service, operating 5.2.6 Equipment Control 5.2.6 Equipment Control personnel shall place the equipment in operation and verify and document its functional acceptability. Attention shall be given to (See Above) (See Above) restoration of normal conditions, such as removal of jumpers or signals used in maintenance or testing or returning valves, breakers or switches to proper startup or operating positions from "test" or "manual" positions. Steps shall be taken to ensure that all associated alarms and indications are returned to normal.

(11) Proper alignment of equipment shall be independently verified Conditions to be considered in preparing When equipment is, ready to be returned to by a second qualified person unless all equipment, valves, and equipment for maintenance include, for service operating personnel shall place the switches involved in the activity can be proven to be in their example: shutdown margin; method of equipment in operation and verify and correct alignment by functional testing without adversely emergency core cooling establishment of B document its functional acceptability.

affecting the safety of the plant. Another exception is where such verification would result in significant radiation exposure. path for decay heat removal; temperature Attention shall be given to restoration of The person who performs the verification of correct and pressure of the system; valves between normal conditions, such as removal of implementation of equipment control measures or proper work and hazardous material; venting, jumpers or signals used in maintenance or alignment prior to returning equipment to service shall be draining, and flushing; entry into closed testing or such as returning valves. breaker qualified to perform such tasks for the particular system vessels; hazardous atmospheres handling or switches to proper ,startup or operating involved, and shall possess operating knowledge of the hazardous materials; and electrical hazards. positions from "test" or "manual positions, particular system involved and its relationship to plant safety.

When entry into a closed system is required, and assuring that all alarms which are control measures shall be established to indicative of in inoperative status are prevent entry of extraneous material and to extinguished. For equipment important to assure that foreign material is removed safety, proper alignment shall be before the system is reclosed equipment, as independently verified by a second qualified necessary, to maintain personnel and reactor person unless all equipment, valves. and l entry and to avoid unauthorized operation of switches involved in the activity can be equipment. proven to be in their correct alignment by functional testing without adversely affecting the safety of the plant. A second inspection is where such verification would result. in significant radiation exposure. The person who performs the verification of correct implementation of equipment control measures or proper alignment prior to returning equipment to service shall be qualified to perform such verification for the 59

ANS 3.2 Side-By Side Comparison 7/25/2012 particular system involved, and shall possess operating knowledge of the particular system (12) Equipment shouldreceive additional monitoring during an When placed into service the equipment 5.2.19.1. Preoperational Tests appropriate run-in period prior to being placed into service to should receive additional surveillance during perform its intended function. Final acceptance of equipment the run-in period, A component test is a functional, that is returned to service shall be made by the on-duty operational or performance test of an supervisor responsible for the unit. individual piece of equipment or unit system under prescribed conditions. Typical parameters to be examined are direction of rotation, bearing temperatures, vibration, time delays, and ability to operate with remote and local control. The procedure shall list checks to be made and provide acceptance criteria. Consideration should also be given to providing run-in period to minimize early failures during operation of the plant.

3.15 Nonconforming Items Nonconforming items shall be controlled in accordance with Essentially, equivalent ASME NQA-1-2008 and the NQA-1a-2009 addenda [2]. to NQA- l. Ok.

3.16 Corrective Actions Corrective action activities shall be accomplished in accordance Essentially, equivalent with ASME NQA-1-2008 and the NQA-1a-2009 addenda [2]. to NQA- l. Ok.

3.17 Plant Records Management Quality assurance records shall be controlled in accordance with Essentially, equivalent ASME NQA-1-2008 and the NQA-1a-2009 addenda [2]. to NQA- l. Ok.

60

ANS 3.2 Side-By Side Comparison 7/25/2012 A list of typical lifetime records is included in ASME NQA-1-2008 and the NQA-1a-2009 addenda, Part III, Nonmandatory Appendix 17A-1, 200, List of Typical Lifetime Records [2], and should be Nonmandatory considered for guidance purposes only. The list is not considered Appendix 17A-1 will be to be all-inclusive and the nomenclature of these records may endorsed through RG vary. For records not listed in Appendix 17A-1, the type of record 1.33 that most nearly describes the record in question should be followed with respect to its retention classification. The applicant or licensee itself shall ensure that it maintains sufficient records, both lifetime and nonpermanent, to furnish evidence of activities affecting quality The storage of QA records in electronic media shall be consistent In accordance with with the intent of US NRC Regulatory Issue Summary (RIS) 2000- NRC guidance.

18, Guidance on Managing Quality Assurance Records in Electronic Media, dated October 23, 2000 [4], and associated NIRMA Guidelines TG 11-1998 [5], TG15-1998 [6], TG16-1998

[7], and TG21-1998 [8]. The guidance of (RIS) 2000-18 shouldalso be applied to the record keeping and maintenance requirements in other parts of the regulations that accept the storage of records in the form of electronic media.

The use of optical disks for electronic records storage and In accordance with retrieval systems shall comply with the USNRC guidance in NRC guidance.

Generic Letter 88-18, "Plant Record Storage on Optical Disks." [9]

3.18. Audit Program Audit activities shall be controlled in accordance with ASME NQA- Reference to NQA-1.

1-2008 and the NQA-1a-2009 addenda [2]. Audit frequencies and Ok.

inclusion of functional areas for audit during the operational phase is a combination of quality criteria and management direction that are specific to the operation phase as described below.

3.18.1 Audit Frequency 61

ANS 3.2 Side-By Side Comparison 7/25/2012 3.18.1.1 Regularly Scheduled Internal Audits Internal audits of activities conducted during the operational phase should be performed in such a manner that an audit of applicable QA program elements is completed for each functional area within a Aligns with regulatory period of two years. Internal audits of activities conducted during the position in RG1.28 operational phase should be performed in such a manner that an audit of applicable QA program elements is completed for each functional area within a period of two years.

Internal audit frequencies of well established operational phase activities may be extended one year at a time beyond the above two year interval based on the results of an annual evaluation of the applicable functional area and objective evidence that the functional area activities are being satisfactorily accomplished. The evaluation shall include a detailed performance analysis of the functional area based upon applicable internal and external source data and due consideration of the impact of any functional area changes in responsibility, resources or management. The evaluation shall be considered a quality record and available for review by the regulator.

However, the internal audit frequency interval shall not exceed a maximum of four years. If an adverse trend is identified in the applicable functional area, the internal audit frequency extension should be rescinded and an audit scheduled as soon as practicable.

Internal audits shall include the following areas, along with the specific quality assurance program elements included in ASME NQA-1-2008 and the NQA-1a-2009 addenda [2] and the owner organizations QA program. The audits shall take into consideration applicable regulatory and license requirements, and associated record keeping.

(1) Compliance with and effectiveness of implementation (i.e.

performance) of internal rules and procedures, such as for operating, design, procurement, maintenance, modification, refueling, surveillance, and test activities.

(2) The conformance of facility operation to provisions contained within the Technical Specifications, including administrative controls and applicable license conditions.

(3) The performance, training, and qualification of the plant staff.

62

ANS 3.2 Side-By Side Comparison 7/25/2012 (4) The Fire Protection Program and implementing procedures. The audit shall include an inspection of fire protection equipment and program implementation utilizing either a qualified off-site licensed fire protection engineer or an outside qualified fire protection consultant at least every two years. This audit is not subject to the extension of the audit intervals described above.

(5) Corrective actions taken following abnormal occurrences.

Periodic reviews of other important areas, such as plant security, emergency preparedness, and radiation protection, may be conducted through internal audits.

3.18.1.2 Regularly Scheduled External Audits External audits, e.g., supplier audits, should be performed on a Aligns with regulatory triennial basis and supplemented by annual evaluations of the position in RG1.28 suppliers performance. A continuous or ongoing evaluation of the suppliers performance may be conducted in lieu of the annual evaluations provided that the results are reviewed in order to determine if corrective action is required.

If more than one purchaser utilizes a supplier, the purchaser may arrange for an audit of the supplier on behalf of itself and the other purchasers to reduce the number of external supplier audits. The scope of the audit should address the needs of all purchasers and the report shouldbe distributed to purchasers for whom the audit 63

ANS 3.2 Side-By Side Comparison 7/25/2012 was conducted.

Each purchaser relying on the results of such an audit remains individually responsible for the adequacy of the audit and for its use by their organization.

4.0 References The user is advised to review each of the following references to determine whether it, a more recent version, or a replacement document is the most pertinent for each application. When alternate documents are used, the user is advised to document this decision and its basis.

[1] Title 10, Code of Federal Regulations, Part 50, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants

[2] American National Standard ANSI/ASME NQA 2008 with NQA-1a-2009 Addenda, Quality Assurance Requirements for Facility Application

[3] USNRC Regulatory Guide 1.8, Rev. 3 (May 2000),

Qualification and Training of Personnel for Nuclear Power Plants.

[4] Regulatory Issue Summary (RIS) 2000-18, Guidance on Managing Quality Assurance Records in Electronic Media, dated October 23, 2000

[5] Nuclear Information and Records Management Association, Inc. (NIRMA) Technical Guide (TG), TG 11-1998, Authentication of Records and Media

[6] NIRMA TG15-1998, Management of Electronic Records

[7] NIRMA TG16-1998, Software Configuration management and Quality Assurance 64

ANS 3.2 Side-By Side Comparison 7/25/2012

[8] NIRMA TG21-1998, Electronic Records Protection and Restoration

[9] USNRC Guidance in Generic Letter 88-18, Plant Record Storage Optical Disks.

APPENDIX A TYPICAL PROCEDURES FOR PRESSURIZED WATER REACTORS AND BOILING WATER REACTORS The following are typical activities that affect safe operations and/or the quality of SSCs that should be covered by written procedures. This appendix is not intended as an inclusive listing of all needed procedures since many other activities carried out during the operation phase of nuclear power plants should be covered by procedures not included in this list.

1. Administrative Procedures a Authorities and Responsibilities for Safe Operation and shutdown
b. Equipment Control (e.g., locking and tagging)
c. Procedure Adherence and Temporary Change Method
d. Procedure Review and Approval
e. Schedule for Surveillance Tests and Calibration
f. Shift and Relief Turnover
g. Log Entries, Record Retention, and Review procedures 65

ANS 3.2 Side-By Side Comparison 7/25/2012

h. Access to Containment
i. Bypass of Safety Functions and Jumper (temporary modification) Control
j. Maintenance of Minimum Shift Complement and call-in of personnel
k. Plant Fire Protection Program
l. Communication System Procedures
m. Core Design and Configuration
2. General Plant Operating Procedures
a. Cold Shutdown to Hot Standby
b. Hot Standby to Minimum Load (nuclear startup).
c. Recovery from Reactor Trip
d. Operation at Hot Standby
e. Turbine Startup and Synchronization of Generator
f. Changing Load and Load Follow (if applicable)
g. Power Operation and Process Monitoring
h. Power Operation with less than Full Reactor Coolant Flow
i. Plant Shutdown to Hot Standby
j. Hot Standby to Cold Shutdown
k. Preparation for Refueling and Refueling Equipment Operation 66

ANS 3.2 Side-By Side Comparison 7/25/2012 I. Refueling and Core Alterations

3. Procedures for Startup, Operation, and Shutdown of Safety-Related PWR Systems Instructions for energizing, filling, venting, draining, startup, shutdown, and changing modes of operation should be prepared, as appropriate, for the following systems:
a. Reactor Coolant System
b. Control Rod Drive System (including part-length rods).
c. Shutdown Cooling System
d. Emergency Core Cooling System
e. Component Cooling Water System
f. Containment (1) Maintaining Containment Integrity (2) Special Containment Systems (a) Atmosphere (b) Subatmospheric (c) Double-Wall Containment with Controlled Interspace (d) Ice Condenser (3) Containment Ventilation System (4) Containment Cooling System 67

ANS 3.2 Side-By Side Comparison 7/25/2012

g. Atmosphere Cleanup Systems
h. Fuel Storage Pool Purification and Cooling System
i. Main Steam System
j. Pressurizer Pressure and Spray Control Systems
k. Feedwater System (feedwater pumps to steam generator)

I. Auxiliary Feedwater System

m. Service Water System
n. Chemical and Volume Control System (including Letdown/Purification System)
0. Auxiliary or Reactor Building Heating and Ventilation
p. Control Room Heating and Ventilation
q. Radwaste Building Heating and Ventilation
r. Instrument Air System
s. Electrical System (1) Offsite (access circuits)

(2) Onsite (a) Emergency Power Sources (e.g., diesel generator, batteries)

(b) A.C. System (c) D.C. System

t. Nuclear Instrument System 68

ANS 3.2 Side-By Side Comparison 7/25/2012 (1) Source Range (2) Intermediate Range (3) Power Range (4) Incore System u Reactor Control and Protection System

v. Hydrogen Recombiner
4. Procedure for Startup, Operation, and Shutdown of Safety-Related BWR Systems Instructions for energizing, filling, venting, draining, startup, shutdown, and changing modes of operation should be prepared, as appropriate, for the following systems:
a. Nuclear Steam Supply System (Vessel and Recirculating System)
b. Control Rod Drive System
c. Reactor Cleanup System
d. Liquid Poison System (Standby Liquid Control System)
e. Shutdown Cooling and Reactor Vessel Head Spray System
f. High Pressure Coolant Injection
g. Reactor Core Isolation Cooling System/Isolation Condenser
h. Emergency Core Cooling Systems
i. Closed Cooling Water System
j. Containment 69

ANS 3.2 Side-By Side Comparison 7/25/2012 (1) Maintaining Integrity (2) Containment Cooling and Ventilation System (3) Inerting and deinerting

k. Fuel Storage Pool Purification and Cooling System
l. Main Steam System (reactor vessel to turbine)
m. Turbine-Generator System
n. Condensate System (hotwell to feedwater pumps, including demineralizers and resin regeneration)
o. Feedwater System (feedwater pumps to reactor vessel)
p. Makeup System (filtration, purification, and water transfer)
q. Service Water System
r. Reactor Building Heating and Ventilation Systems
s. Control Room Heating and Ventilation Systems
t. Radwaste Building Heating and Ventilation Systems
u. Standby Gas Treatment System
v. Instrument Air System
w. Electrical System (1) Offsite (access circuits)

(2) Onsite (a) Emergency Power Sources (e.g., diesel generator, batteries) 70

ANS 3.2 Side-By Side Comparison 7/25/2012 (b) A.C. System (c) D.C. System

x. Nuclear Instrument System (1) Source Range (2) Intermediate Range (3) Power Range (4) TIP System
y. Reactor Protection System
z. Rod Worth Minimizer
5. Procedures for Abnormal, Offnormal, or Alarm Conditions Since these procedures are numerous and correspond to the number of alarm annunciators, the procedures are not individually listed. Each safety-related annunciator should have its own written procedure, which should normally contain (1) the meaning of the annunciator, (2) the source of the signal, (3) the immediate action that is to occur automatically, (4) the immediate operation action, and (5) the long-range actions.
6. Procedures for Combating Emergencies and Other Significant Events
a. Loss of Coolant (including significant PWR steam generator leaks) (inside and outside primary containment) (large and small, including leak-rate determination)
b. Loss of Instrument Air 71

ANS 3.2 Side-By Side Comparison 7/25/2012

c. Loss of Electrical Power (and/or degraded power sources)
d. Loss of Core Coolant Flow
e. Loss of Condenser Vacuum
f. Loss of Containment Integrity
g. Loss of Service Water
h. Loss of Shutdown Cooling
i. Loss of Component Cooling System and Cooling to Individual Components.
j. Loss of Feedwater or Feedwater System Failure
k. Loss of Protective System Channel
l. Mispositioned Control Rod or Rods (and rod drops)
m. Inability to Drive Control Rods
n. Conditions Requiring Use of Emergency Boration or Standby Liquid Control System
o. Fuel Cladding Failure or High Activity in Reactor Coolant or Offgas
p. Fire in Control Room or Forced Evacuation of Control Room
q. Turbine and Generator Trips
r. Other Expected Transients that may be Applicable
s. Malfunction of Automatic Reactivity Control System
t. Malfunction of Pressure Control System
u. Reactor Trip 72

ANS 3.2 Side-By Side Comparison 7/25/2012

v. Plant Fires
w. Acts of Nature (e.g., tornado, flood, dam failure, earthquakes)
x. Irradiated Fuel Damage While Refueling
y. Abnormal Releases of Radioactivity
z. Intrusion of Demineralizer Resin Into Primary System (BWR Plants)
7. Procedures for Control of Radioactivity (For limiting materials released to environment and limiting personnel exposure)
a. Liquid Radioactive Waste System (1) Collection, Demineralizing, Filtering, Evaporating and Concentrating, And Neutralizing (2) Sampling and Monitoring (3) Discharging to Effluents
b. Solid Waste System (1) Spent Resins and Filter Sludge Handling (2) Baling Machine Operation (3) Drum Handling and Storage
c. PWR Gaseous Effluent System (1) Collection, Storage, and Discharge (2) Sampling and Monitoring (3) Air Ejector and Stack Monitoring 73

ANS 3.2 Side-By Side Comparison 7/25/2012 (4) Ventilation Air Monitoring

d. BWR Air Extraction. Offgas Treatment. and Other Gaseous Effluent Systems (1) Mechanical Vacuum Pump Operation (2) Air Ejector Operation (3) Packing Steam Exhauster Operation (4) Sampling (5) Air Ejector, Ventilation, and Stack Monitor
e. Radiation Protection Procedures (1) Access Control to Radiation Areas Includ1ing a Radiation Work Permit System (2) Radiation Surveys (3) Airborne Radioactivity Monitoring (4) Contamination Control (5) Respiratory Protection (6)Training in Radiation Protection (7) Personnel Monitoring (8) Bioassay Program (9) Implementation of ALARA Program
f. Area Radiation Monitoring System Operation
g. Process Radiation Monitoring System 74

ANS 3.2 Side-By Side Comparison 7/25/2012

h. Meteorological Monitoring Operation
8. Procedures for Control of Measuring and Test Equipment and for Surveillance Tests, Procedures. and Calibrations
a. Procedures of a type appropriate to the circumstances should be provided to ensure that tools, gauges, Instruments, controls, and other measuring and testing devices are properly controlled, calibrated. and adjusted at specified periods to maintain accuracy. Specific examples of such equipment to be calibrated and tested are readout instruments. Interlock permissive and prohibit circuits, alarm devices, sensors. signal conditioners, controls, protective circuits. and laboratory equipment.
b. Specific procedures for surveillance tests, inspections, and calibrations should be written (implementing procedures are required for each surveillance test. inspection. or calibration listed in the technical specifications):

(1) Pressurized Water Reactors (a) Containment Leak-Rate Tests (b) Containment Isolation Tests (c) Containment Local Leak Detection Tests (d) Containment Heat and Radioactivity Removal Systems Tests (e) Containment Tendon Tests and Inspections (f) Service Water System Functional Tests (g) Main Steam Isolation Valve Tests (h) Fire Protection System Functional Tests (i) Boric Acid Tanks-Level Instrumentation Calibrations (j) Emergency Core Cooling System Tests (k) Control Rod Operability and Scram Time Tests (l) Reactor Protection System Tests and Calibrations 75

ANS 3.2 Side-By Side Comparison 7/25/2012 (m) Permissive-Tests and Calibrations (n) Refueling System Circuit Tests (o) Emergency Boration System Functional Tests (p) DNB Checks and Incore-Excore Flux Monitor Correlations (q) Emergency Power Tests (r) Auxiliary Feedwater System Tests (s) NSSS Pressurization and Leak Detection (t) Inspection of Reactor Coolant System Pressure Boundary (u) Inspection of Pipe Hanger Settings (v) Control Rod Drive System Functional Tests (w) Heat Balance-Flux Monitor Calibrations (x) Pressurizer and Main Steam Safety Valve Tests (y) Leak Detection Systems Tests (z) Axial and Radial Flux Pattern Determinations (aa) Area, Portable, and Airborne Radiation Monitor Calibrations (bb) Process Radiation Monitor Calibrations (cc) Environmental Monitor Calibrations (dd) Safety Valve Tests (ee) Turbine Overspeed Trip Tests 76

ANS 3.2 Side-By Side Comparison 7/25/2012 (ff) Water Storage Tanks-Level Instrumentation Calibration (2) Boiling Water Reactors (a) Containment Leak-Rate and Penetration Leak-Rate Tests (b) Containment Isolation Tests (c) Containment Vacuum Relief Valve Tests (d) Containment Spray System Tests (el Standby Gas Treatment System Tests (including filter tests) \

(f) Service Water System Functional Tests (g) Main Steam Isolation Valve Tests (h) Fire Protection System Functional Tests (i) Nitrogen Inerting System Tests (j) Emergency Core Cooling System Tests (k) Control Rod Operability and Scram Time Tests (l) Reactor Protection System Tests and Calibrations (m) Rod Blocks-Tests and Calibrations (n) Refueling System Circuit Tests (o) Liquid Poison System Tests (p) Minimum Critical Heat Flux Checks and Incore Flux Monitor Calibrations (q) Emergency Power Tests 77

ANS 3.2 Side-By Side Comparison 7/25/2012 (r) Isolation Condenser or RCIC Tests (s) NSSS Pressurization and Leak Detection (t) Inspection of Reactor Coolant System Pressure Boundary (u) Inspection of Pipe Hanger Settings (v) Control Rod Drive System Functional Tests (w) Heat Balance (x) Auto blowdown System Tests (y) Leak Detection System Tests (z) Axial and Radial Flux Pattern Determinations (aa) Area, Portable, and Airborne Radiation Monitor Calibrations (bb) Process Radiation Monitor Calibrations I (cc) Environmental Monitor Calibrations (dd) Safety Valve Tests (ee) Turbine Overspeed Trip Test (ff) Water Storage Tanks-Level Instrumentation Calibrations (gg) Reactor Building Inleakage Tests

9. Procedures for Performing Maintenance
a. Maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. Skills normally possessed by qualified maintenance personnel 78

ANS 3.2 Side-By Side Comparison 7/25/2012 may not require detailed step-by-step delineation in a procedure. The following types of activities are among those that may not require detailed step-by-step written procedures:

(1) Gasket Replacement (2) Trouble-Shooting Electrical Circuits (3) Changing Chart or Drive Speed Gears or Slide Wires on Recorders

b. Preventive maintenance schedules should be developed to specify lubrication schedules, inspections of equipment, replacement of such items as filters and strainers, and inspection or replacement of parts that have a specific lifetime such as wear rings.
c. Procedures for the repair or replacement of equipment should be prepared prior to beginning work. Such procedures for major equipment that is expected to be repaired or replaced during the life of the plant should preferably be written early in plant life. The following are examples of such procedures for major equipment:

(1) Repair of PWR Steam Generator Tubes (2) Replacement and Repair of Control Rod Drives (3) Replacement of Recirculation Pump Seals (4) Replacement of Important Strainers and Filters (5) Repair or Replacement of Safety Valves (6) Repair of Incore Flux Monitoring System (7) Replacement of Neutron Detectors 79

ANS 3.2 Side-By Side Comparison 7/25/2012

d. Procedures that could be categorized either as maintenance or operating procedures should be developed for the following activities. Instructions for these activities may be included in systems procedures.

(1) Exercise of equipment that is normally idle (2) Draining and Refilling Heat Exchangers (3) Draining and Refilling Recirculation Loop (4) Draining and Refilling the Reactor Vessel (5) Draining and Refilling Steam Generators (6) Removal of Reactor Head (7) Disconnection and Reconnection of Wiring Penetrating Reactor Vessel Head (8) Demineralizer Resin Regeneration or Replacement

e. General procedures for the control of maintenance, repair, replacement, and modification work should be prepared before reactor operation is begun. These procedures should include information on areas such as the following:

(1) Method for obtaining permission and clearance for operation personnel to work and for logging such work and (2) Factors to be taken into account, including the necessity for minimizing radiation exposure to workmen, in preparing the detailed work procedures but that must operate when required

10. Chemical and Radiochemical Control Procedures Chemical and radiochemical control procedures should be written to prescribe the nature and frequency of sampling and analyses, the instructions maintaining water quality within prescribed limits, and the limitations on concentrations of agents that may cause corrosive attack or fouling of heat-transfer surfaces or that may become sources of radiation hazards due to activation. These procedures should specify laboratory instructions and calibration of laboratory equipment. Extreme importance must be placed on laboratory procedures used to determine 80

ANS 3.2 Side-By Side Comparison 7/25/2012 concentration and species of radioactivity in liquids and gases prior to release including representative sampling, validity of calibration techniques, and adequacy of analysis.

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