ML20010C648

Advises That FSAR Amend Will Clarify Util Commitments to Wash 1284,WASH 1309 & Wash 1283,in Response to NRC 750409 Request.Specific Commitments to Cited Reg Guides Outlined. Related Info Encl

ML20010C648
Person / Time
Site:	Beaver Valley
Issue date:	05/07/1975
From:	Woolever E DUQUESNE LIGHT CO.
To:	Anthony Giambusso Office of Nuclear Reactor Regulation
Shared Package
ML20010C645	List: ML20010C644 ML20010C648 ML20010C659 NG-75-1278, Forwards Clarification of Util 750227 Commitment to Comply W/Qa Guidance Contained in Wash 1284,WASH 1309 & Wash 1283 NG-75-1453, Forwards Clarification of Commitments to QA Guidance Contained in Wash 1283,WASH 1284 & Wash 1309
References
FOIA-81-121 NUDOCS 8108200268
Download: ML20010C648 (150)

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'd c[p.,? 2 ~Lh f.c3I15.fE. ii .w) w (412) 471 43co 4 % fn ath A.ent,e F'd:s hwgh. Pe nnt yl.>ama 15219 May 7, 1975 United States Nuclear Regulatory Cournission of fice of Nuclear Reactor Regulation Division of Reactor Licensing Wachington, D.C. ?0555 Attention: Mr. Angelo Giambusso, Director

Subject:

Beaver Vall'ey Power Station - Unit No. 1 tompliance with WA'SH Docum6nts Docket No. 50-334 Gcntlemen: As requented in your letter of Ipril 9, 1975, we are preparing c.n amendment to the Pinal Safety Analysis Reoort (FSAR) for Beaver Vallev Power Station Unit No. 1 that will clarify our commitmant to the guidance provided i n 'c.'A S H 1234, WAS;i 1309, and WASH 1283. No wich, however, to call to your attention e>:ist-ing speci fic comaitments to the following Regulatory Guides listed in your letter: Regulatory Guide 1.8, " Personnel Selection and Training," in Volume 1, Paragraph 1.3.3.8. (FSAR) Regulatory Guide 1.30, " Quality An':urance Require-nents for the Installation, Inspection and Testing of Indtru-m?ntation and Electric Equipment," in Volume 1, Paragraph 1.3.3.30. Regulatory Guide 1.33, " Quality Assurance Program Req ui re:ra n t s (Opera t ion ), " in Volt:me 1, Paragraph 1.3.3.33. DUQUESNE LIGHT CO.MPANY (CO I f'. . - l. 7 By t-E. 3. Woo 3ever Vice President i 4 8108200268 810618 PDR FOIA e, BUSTANI81-121 PDR 'S.155

/ e J UrJ.ted States Nuclear Regulatory Concnission Mhy 7, 1975 Page 2 4 (CORPORATE SEAL) Attest: i v') / (5 '5.d.d 11. W. Staas Secretary j f COMMONNEALTil OF PENNSYLVANI A) .i ) SS: j COUNTY OF ALLEGHENY ) 4 On this 7 " day of r/x # 1975, before me, D0"l.LD U. SHA.'ECU a Notary Puj51ic in and for said Co:raonwealth and County personally appeared E. J. Woolever i vho, being duly sworn, dispeced, and said that (1) he is Vi ce Pres irient of Dogoc c,no Light (?) bo i s cinl y anthnri vori to execu te and file the foregoing Sub:nitral on behalf of said Company, and (3) the statements set forth in the Sub-i mittal are true and correct to the best of his knowledge, in forma tion and belief. l WITNESS my hand and seal the day and year first above written. ~ j / ' a., s - s-(_,,/s,[;~ : ', ',..,,...,, / t' LC:: tid Y!. CH:J:':X:.1::'s~; r. '1 c fc:!'.:t h. ?!.:;*,:r; Cc. i a... l.*/ (+u.1 n.::n [i;i.cs J...e 7, IUS 1 4 5 r e..,,,,,,, ,,,.e w-m-- -.w--

36h/ G th LE -/ i 2 BVPS FSAR Amendment 6 12/7/73 1 documented and the corrective action is verified through the mechanisms provided in the DLC, SSW, and Westinghouse Manuals. ~ j A.2.1.17 QA records 6 The official quality file for the BVPS is maintained at the SSW Field Quality Control office. This file is monitored and audited by DLC. ) j Included in the records maintained are purchase orders, drawings, specifications, correspondence, procedures, audit

reports, minutes of

meetings, QA checksheets, codes and standards, and

] similar material. } A file system has been established to assure retrievability of i such records. In the case where records are not stored at the j

site, locations for storage are reviewed and/or approved by DLC.

Vendors retaining records for certain periods of time are instructed that such records must be submitted to the applicant i at the conclusion of his (the vendor) storage responsibility. \\ A.2.1.18 Audits a j DLC retains the ultimate responsibility for QA at BVPS. This responsibility is exercised mainly through an audit program. These audits are performed against the SSW and Westinghouse commitments. These include QA/QC procedures, specifications, f drawings, instructions, and similar information. Internal audits j of DLC are also documented and maintained in the file. As agents for DLC, SSW also performs audits at the vendor shops j through their Procurement Quality Control Division and audits at the site through the Field Quality Cbntrol. Division. Both j divisions are audited periodically by DLC. Audit repor ts are utilized to assess the adequacy of the DLC QA Program. A record of all audits is maintained and periodically j reviewed to assure necessary followup action. Audits are reported at each Project Management Committee Meeting to assure j that the necessary level of management is involved and has an awareness of the audit prm3 ram. 1 i All audits are performed utilizing a preplanned checklist. The 1 checklist will include address to the specific QA criteria of Appendix B of

10CFRSO, results of previous audits, inspection I

reports, nonconformance reports, adherence to specifications, and other items as identified in the respective organization QA I manuals. l 4 i A.2-9

ikDi A N t Cop 5otti%TEb Revision 2, 6/3/77 gm seg TABLE A Reculatory Guide / ANSI Std. Interpretation / Alternate / tem No. Reference Requirement Exception 1. General Certain Regulatory Guides The Con Edison commitment invoke or imply Regulatory efers to the Regulatory Guides Guides and standards in d ANSI S tandard s ', specifically addition to the standard .entified in the "Poreword". each primarily endorses. .2ditional Regulatory Guides,. ANSI Standards, Guides and simil, documents implied or referenced Certain ANSI Standards in those specifica]ly iden-invoke or imply additional tified in the " Foreword" are standards. not part of this commitment. 2. General Certain A"SI Standards Our commitment to these extend the scope of standards applies only to those applicability to systems, structures, and include systems, structures, components whose satisfactory and components whose performance is required to satisfactory performance prevent postulated accidents is required for a plant that could cause undue risk to operate reliably. to the health and safety of the public; or to mi.tigate the consequences of such accidents. Reliable operation of the plant may depend upon other systems, structures and components which are not covered by tl.is c'mmitment. o <~.n., 'l-(, 421.22 ^ A-1

Revision 2, 6/3/77 TAIRE A Reatlatory Guide / ANSI Std. Interpretation / Alternate / Item No. Reference Requirement Exception 3. General NRC Regulatory Guides The majority of ANSI Standards; and ANSI Standards to which Con Edison has do not provide for committed are concerned with deviation from any the design and/or constructi9n requirement (s) when phases of nuclear power plants-emergency or otier Consequently, Con Edison urgent conditions has adapted these standards make such deviation to its operations phase, necessary. where practicable, and has developed previsivns for certain conditions not addressed in the standards. In the event of an emergency condition which, if not promptly corrected could likely affect the health and saf,ty of the public, the M: anger, Nuclear Power Generation or his designated alternate (s) may cuthorize emergency repairs and deviations from written pro-cedures. The nature of the eme rg e r.cy, its cause ind the corrective action taken are documented. j e A-2

Revision 2, 6/3/77 9 TAnf.E A Regulatory Guide / ANSI Std. Iaterpretation/ Alternate / Ite.n Mo. Reference Requirement Exception 3 (Cont'd) Waivers to specific procedures. may be authorized by the Manager, UPG or his designated alternate if necessary to avoic significant loss of unit capacity with due consideratio) for public health and safetf. Such waivers, including the need therefor, are documented. j The above provisions assure 421.5 procedural control for by-passing critical inspections, tests, and cperations. 4. General Certain ANSI standards The majority of ANSI Standards contain requirements to which Con Edison has which, under certain committed are concerned with conditions, may con-the design and/or construction flict with limiting phases of nuclear power plant. personnel radiation Consequently, Con Edison has exposure. adapted these standards to its operations phase, where practicable, and has developed provisions for certain conditions not addressed ~in ...the standards. I When conformance with particul standards requiremente; e.g., cleaning of fluid systems, t housekeeping, would conflict with limiting personnel radiat exposure, the degree of con- / I formance to the standards is f 'letermined by appropriate I levels of management. \\ A-3 '\\.

~. O e Revision 2, 6/3/77 TABLE A Regulatory Guide / ANSI Std. Interpretation / Alternate / Item No. Reference Requirement Exception 5. General Various standards require Except ia ANSI N45.2.5, the inspections., examinations frequencies of required and tests, but do not inspections, examinations and specify the frequencies tests are not speci,fied in of these activities. the standards. Accordingly, the f requency of inspections,- examinations and tests required by the standards - other than ANSI N45.2.5 - is identified on a job - by Job-basis. The amount of inspections, examinations and l tests identified is based upon the safety significance of the item involved. 6. ANSI N18.7 " Temporary changes which Temporary changes will be Section 5.2.2 c1.early do not change authorized per the provisions the intent of the approved of the Administrative Controls procedure shall, as a Section of the Facility minimum, be approved by Technical Specifications. two members of the plant staff know12dgeable in i the areas affected by the procedures." I A-4

Revision 2, 6/3/77 TABLE A Regulatory Guide / ANSI Std. Interpretation / Alternate / Item No. Reference Requirement Exception 7. ANSI N.18.7 (a) " Maintenance or mod-Requirements (a), (b) and (c), First Sentence ification...shall be as a whole, require.a degree of 5.2.7 perfo'rmed in a manner of quality for replacement to ensure quality items consistent with their at least equivalent function. Our pro' gram allows. to that specified in this degree of quality to criginal design bases be more or less stringent and requirements, than the original, provided materic.ls specifi-the specified quality require-cations, and in-ments are reviewed and spection require-approved 17 Engineering v( ments..." prior to use. 4 21. & First Sentence of (b) "A maintenance program 5.2.7.1 chall be developed to maintain safety related structures, systems and components at the quality required for them to perform their intended functions." ANSI N18.7 Para (1) (c) " Purchased to specifi-of 5.2.13 cations and codes equivalent to those specified for the original equipment, or those specified by a properly reviewed and approved rvvision." A-5

Revision 2, 6/3/77 TABLE A Regulatory Guide / ANSI Std. Interpretation / Alternate /_ ' tem No. Reference Requirement Exception 8. ANSI N10.7 General requirements Paragraph 5.2.14 applies to Section 5.2.14 for nonconforming items programmatic as well as to specific provisions of ANSIN 18.7 and its associated references. Consistent with paragraph 5.2.14, our quality assurance program will contaid provisions for controlled, documented waivers to its requirements. 9. ANS1 N18.7 Requires certain pro-Per 5.2.13 procurement document Section 5.2.13.1 visions in procure;aent contents for replacement _ items,, will be based primarily on documents. .o r ig i.na l_ pro cu r eme n t3dc umen t.[- ~ l contents._. The provisions of 7/ 5.2.13.1 will be included if required by original procure-ment document or warranted by performance of the item. Procurement document content i for new items will meet the [/j i requirements of 54 2.13.1. When requirements of ANSI standards are included i.. i f f,', procurement documents, the ii-requirements may not be f identified as excerpts from j ANSI standards. Procurement j documents are developed and l reviewed in accordance with j paragraph 5.2.13 of the O.A. Program description. i \\ A-G

Revision 2, 6/3/77 5 TABLE A Regulatory Guide / ANSI Std. Interpretation / Alternate / Ctem No. Reference Requirement Exception 10. ANSI N18.7 Section "... drawings, specifi-Drawings are identified by 5.2.13.1, (2) cation and industrial drawing number, revision codes and standards... number, and title. shall be identified by titles and dates of issue..." 11. ANSI N18.7 Section Where changes are made to Consistent with the requiremente 5.2.13.1 procurement documents, of ANSI N45.2.11, paragraph 1st Para. they shall be subject to 7.2, minor changes to (pro-the same degree of curement) documents, such as, control as was used in inconsequential editorial the preparation of the corrections, or changes to original documents. commercial terms and conditions may not require that the revired (procurement) document receive the same review and approval as the original docu-ments. 12. ANSI N18.7 " Inspection shal1 be Examinations, checks, and'in- .Section 5.2.17 performed by qualified spections of work at Indian individuals other than Point Station are normally those who performed or accomplished and documented directly supervised the by foremen responsible for activity being inspected." the work. Where independent examinations, checks, and inspections are determined appropriate, personnel who do not perform the work and do not directly supervise the A-7

Revision 2, 6/3/77 TABLE A Regulatory Guide / ANSI Std. Interpretation / Alternate / [ tem No. Reference Requirement Exception work are utilized. These 12. (Cont'd) independent examinations, checks, and inspections are comparable in extent to corresponding const'ruction phase activities. 13. ANSI N18.7 Section 5.2.17 Deviations, their cause, Consistent with the documen-Last Paragraph, and any corrective tation requirements of next to last sentence action completed or Criterion XVI, Appendix "B" planned shall be to 10 CFR 50, for corrective documented. action, significant deviations, their cause and any corrective action completed or planned are documented. Results of inspections used to accept or reject items shall be documented in all cases. 14. ANSI N18.7 Section 6 'When the preceding Our commitment to ANSI standard , References American National Standards does not extend beyond the referred to in this standards (date, revisior, etc. document are superseded identified in that cormnitment. by a revision approved by the American National Standards Institute, Inc., the revision shall apply." A-8

Revision 2, 6/3/77 TABLE Is Regulatory Guide /ANS1 Std. Interpretation / Alternate / Item No. Reference Requirement Exception 15. ANSI N18.7 General and specific pro-Alternate methods to those ANSI N45.2 curement requirements. specified in these standards ANSI N45.2.2 may be used in special cases ANSI N45.2.13 to support procurement of items; e.g. those items urgently needed, items where

• commercial quality is sufficient.

or sole source items. In these cases, prior to procurement, exceptions to the standard requirements will be documented and concurred in by Fngineeringt NPG and QA. 16. ANSI N45.2.2 "The specific items to Items governed by this standard Section 2.1 be governed by this or portions thereof are standard shall be identified on a case-by-case identified." basis during the design document and procurement docu-ment development processes. e A-9

Revision 2, 6/3/77 4 TABLE A Regulatory Guide / ANSI Std. Interpretation / Alternate / Item No. Reference Requirement Exception 17. ANSI N45.2.2 Each of the specific items All safety-related items are Section 2.7 governed by this standard protected to an extent shall be classified into commensurate with-their one of 2,ur levels. sensitivity and importance to safety, but are not specifically classified in various levels per the guidance of paragraph 2.7. Therefore, 1 satisfaction of requirements for packaging, shipping, receiving, storage and handling for particular items could be different than those suggested. 18. ANSI 1:45.2.2 General marking require-Some items are of a size, shape Subsection 3.9 ments. or consistency which preclud2 marking. Marking in such cases is applied to box, box or other enclosure. l Tagging is employed, where necessary. b A-10

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Revision 2, 6/3/77 TABLE A Regulatory Guide /AMSI Std. Interpretation / Alternate / Item No. Reference Requirement Exception ANSI N45.2.2 "A statement documenting A statement documenting the au-22. Paragraph 5.3.3 the authority and technical thority and justifichtion for justification for the the conditional release conditional rel2ase... is prepared. Justification shall be prepared..." may not always be of a technical nature. 23. ANSI N45.2.2 The use or storage of food, People working in storage Subsection 6.2.4 drinks and salt tablet areas have a right of access dispensera in any storage to water dispensers per OS!!A area is prohibited. requirements. Additionally, due to location and layout of the building, personnel temporarily. store lunches in the workplace. This area is regularly policed for sanitation. A-12

._ ~ novision 2, 6/3/77 TABLE A Regulatory Guide / ANSI Std. Interpretation /Al*ernate/ Item No. Reference Requirement Exception 24. ANSI N45.2.2 " Container markings shall Containers are adequately Appendix ( A-3) appear on-a minimum of two marked f or storage,' - A.3.9 (1) sides of the container, identification and retrieval. Second Group preferably on one side Multiple marking requirements and one end." are imposed, where necessary. 25. ANSI N45.2.2 " Container markings shall Container markings are of a Appendix ( A-3) be... no less than 3/4" size which permits easy A.3.9 (4) high container permitting." recognition. Second Group 26. ANSI N45.2.2 " Container marking shall The information required in Appendix (A-3) include the following container marking is evalu-A.3.9 (6) information:..." ated on a case-by-case basis. Marking is adequate in each case. 27. ANSI N45.2.2 "Non-metallic plugs and Non-metal plugs and caps Appendix ( A-3) caps shall be brightly are of a suitably visible Section A 3.5.1 (1) colored." color. A-13

Revision 2, G/3/77 TABLE A Regulatory Guide / ANSI Std. Interpretation / Alternate / tem No. Reference Requirement Exception 28. ANFI N45.2.2 Plugs or caps shall be In cases where plugs o.r caps Appendix (A-3) secured with' tape or other do not snugly fit, additional Section A 3.5.1 (5) means as necessary securing devices or' measures to prevent accidental will be used. removal. 29. ANSI N45.2.3 Identifies various house-When this standard is applied, keeping requirements, its requirements are imple-including cleanlinesF, mented in those areas affected fire prevention and fire by work activities associated protection which must be with modifications or accomplished during the maintenance as determined progress of construction. necessary by Engineering or Q.A. Remaining provisions of para. 5.2.10 of 18.7 will be adhered to. 30. ANSI N45.2.4 Pre-construction This section requires Section 3.0 verification. verification that items are in satisfactory condition for installation and have not suffered since initial receipt inspection. Documentation of that verifi-cation in addition to the documentation of the initial receipt inspection is not required. A-14

Revision 2, 6/3/77 TABI.E A Regulatory Guide / ANSI Std. Interpretation /Alternatel Item No. Reference Requirement Exception 31. ANSI N45.2.4 Identifies various tests Consistent with section 5.2 Section 5.2 to be performed, of IEEE 336, Draft l' Revision 2, 1976, these tests will be performed "as appropriate" as determined by Engineering, or Nuclear Power Generation. 32. ANSI N45.2.4 " Mechanical tests shall For the plant operational Subsection 5.2.2 be performed to ascertain phase " system pressure ratings" Mechanical Tests that... components or is interpreted to mean system systems can' withstand operating pressure. For the system pressure rating;". Reactor Coolant System, Facility Technical Specificatio identify testing requirements. 33. ANSI N45.2.4 " Items requiring cali-Items requiring calibration are Subsection 6.2.1 bration shall be tagged... tagged indicating date of indicating date of calibration. Identity of calibration and identity person that performed the. of person..." calibration shall be indicated on tag or traceable through records. A-15

Revision 2, 6/3/77 TABL1' A Regulatory Guide / ANSI Std. Interpretation / Alternate /_ Item No. Reference Requirement Exception 34. ANSI N45.2.5 Requires periodic cali-The initial accuracy of liquid-Section 2.5 bration of thermometers. in-glass thermometers is established and, because of their inherent stability, they need not be " adjusted or calibrated at prescribed intervals". 35. ANSI N45.2.5 when discrepancies... Consistent with ANSI N10.7, Section 2.5.2 are found all itema 5.2.16 when devices Second paragraph inspected shall be are found to be out of cali-considered unacceptable." bration, an evaluation shall be made and documented con-cerning the validity of previous tests. 36. ANSI N45.2.4 "These tests shall be made For the plant operation phase, Subsection 6.2.2 to verify that all parts this requirement is interpreted Systems Tests of a system properly as not requiring that an coordinate with each entire system be re-tested other". after completion of modifi-cation of only a portion of that system. The testing requirements of the Facility Technical Specifications are me for inoperable equipment. A-16

~ Revision 2, 6/3/77 TABI.E A Regulatorg Guide / ANSI Std. Interpretation / Alternate / Item No. Reference Requirement Exception 37. ANSI N45.2.5 " Inspections shall be per-Design controls verify Section 3.3.4 formed to.... verify that qualifications of processes the process is suitable and suitability for particular for the particular appli-applications. Verification ration. Verify that man-of availability of manpower power, equipment and equipment, etc. is performed

• materials are available..."

by project management rather than inspection personnel. 38. ANSI N45.2.5 This section specifies Quality of materials is Section 4.2 inspections of storage verified prior to batching handling facilities stock in lieu of these inspections. piles, water, etc. 39. ANSI N45.2.5 Various wrenches require This requirement will be Section 5.4 calibration twice daily conformed with in the case or weekly. of continued use. For intermittent use calibration frequency is based upon usage and calibration intervals may be greater than days or weeks. A-17

Revision 2, 6/3/77 TABI.E A Regulatory Guide / ANSI Std. Interpretation / Alternate /_ Item No. Reference Dequirement Exception 40. Regulatory Guide 1.58 General requirements for NDE personnel meet the requirec ANSI N45.2.6 inspection, examination ments of SNTC-1A. Other and testing personnel. personnel are qualified as discussed in Sections 3.3 er.J 3.4 of the program Description. 41. ANSI N45.2.8 If checks disclose apoarent We will check identification Section 3.2 loss of ider';ification, of an item prior to release affirm identification for installation; however, prior to release for option is maintained to installation.' knowledgeably install equip-ment lacking full identificatie providing deficiencies are resolved prior to its use; i.e., operation. Such action is recorded in quality-control documents. 42. ANSI N45.2.9 "This standard provides The requirements of this Section 1.1 general re.,uirements... star.dard will be applied to of nuclear pownr plants". records generated a f ter this standard is implemented. J l 4 21. 24 I A-18

Revision 2, 6/3/77 TABI.E A Regulatory Guide / ANSI Std. Interpretation / Alternate / Item No. Reference Requiremen% Excepticn 43. ANSI N45.2.9 Definition of Quality This definition results in un-Section 1.4 Assurance Records. reasonable requirements re-garding time of application of the record system. Con Edison will introduce records into the system as soon as practical after completion of y the document. ]g _E_: '. ' i,,, s.. ~.. 44. ANLI N45.2.9 The quali' ce The n_es of quality assurance Section 3.2.2 records shall be listed records shall be listed in an ~ in an index. index.u-.. The index shall indicate, In accordance with Draft ANSI as a minimum, record N45.2.9, paragraph 3.2.2, retention times, where October 1976, the index will the records are to be indicate the location of the stored and the location records within the storage of the records within system. the storage area. ANSI M45.'2.9 A specific submittal Purchase orders identify any 45* Section 4.2 plan shall be established particular record submittal for quality assurance requirements, as' applicable, records by agreement between Acceptance of the purchase the purchaser and supplier. order by i..e supplier constitutes agreement with the purchaser. , i,

=. -- hevision 2, 6/3/77 TABI.E A Regulatory Guide / ANSI Std. Interpretation /AJ;ernate/ Item No. Reference Reguirement Exception 46. ANSI N45.2.9 "... a receipt control We will provide thes,e adminis-Sections 4.3 system shal.1 include: trative controls for~our 4.4 and 5.3 Engineering and NPG record 1. A records checklist... storage area (s) but', where 2. A record of... records only a small number of non-

received, permanent records are 3.

Procedures for receipt controlled by individual and inspection of... organization (s), these records. auxiliary administrative controls are unnecessary. system shall permit assessment... status... of records. ... a method for verifying that records received are in agreement and are in good condition. a method of verifying that the records agree with pre-established records checklist." A-20

I Hevision 2, 6/3/77 TABI.E A Item No. Regulatory Guide / ANSI Std. Interpretation / Alternate /_ Reference Requirement Exception 47. ANSI N45.2.9 "Special processed In determining storage requir@ Section 5.4 records shall be ments, we will take into accoE stored... as recommendations of the manu-recommended by the facturer if available. manufacturer of these Normally, these recommendati,og materials." will be followed; however, a blanket commitment is impracts cable as we must retair. the flexibility for final determic nation of storage needs. 48. ANSI N45.2.9 "For storage of film... Section 5.6 controls shall be pro-vided... as recommended by the ma nuf ac turer. " 49. ANSI N45.2.9 A full time security system For the purpose of this l Section 5.5 shall be established to commitment " storage arca" preclude the entry of is interpreted to mean a. Con unauthorized personnel Edison facility which containg into the storage area. records; e.g., the Indian Poiri This system shall guard site, 4 Irving Place, etc. against larceny and and " security system" is vandalism. interpreted to mean security measures. A-21

Revision 2, 6/3/77 T_ABLE A Regulatory Guide / ANSI Std. Interpretation / Alternate / Item No. Reference Requirement Exception ~ 50. ANSI N45.2.9 Requires a " Faci'.i ty" or Nan-permanent records need l Section 5.6 duplicate records. f not be duplicated o,r stored / in a " Facility" but'are required to be stored per NFPIs Class I record provisionsc 51. ANSI N45.2.9 " Storage system shaj1 In accordance with Draft ANSI l Section 6.2 provide for the acpurate M45.2.9, paragraph 6.2, Octobes retrieval of infor,matice 1 1976, the storage system shall without undue deldy,._" provide for the accurate ) retrieval of information. lo 52. Regulatory Guide 1.88 "When NFPA 232-lp75 is When a single record storage used, Quality Assurance facility is maintained, per-Records should lie manent (lifetime) records will i classified as NFPA Class be afforded fire protection I Records". 5 in accordance with NFPA Class ' I record provisions. 7/ Fire protection in accordance 421.25 with NFPA Class 2 provisions shall be provided N.. for records designated as non-permanent. 53. AM".I N45.2.9 "An alternative to... Our duplicate records may be Section 5.6 a record storage fa-stored in separate rooms cility... is...dupli-distant from one anott'er but cate records stored within the same building aro-in a separate remote viding their simultaneous ex-location." posure to haz.irds is unlikely.. A-22

Revision 2, 6/3/77 TABLE A Regulatory Guide / ANSI Std. Interpretation / Alternate / Item No. Reference Requirement Exception 53. (Cont'd) If records are storeil in the v/ same building, protection will 421.26 be provided to assure that simultaneous exposure to hazards is unlikel 54. . ANSI N45.2.9 A list shall be generated Lock and key controls, Section 6.2 designating those duplication of records in personnel who shall have separa te lo..a tions and access to the files. other accurity measures could obviate the need for access lists. In cases where access lists are utilized, they are not required in all cases to identify specific individ-4 uals. 55. ANSI "45.2.9 "Upon final transfer the Except for special cases as Section 7.2 owner shall... acknowledge agreed to by Con Edison and receipt..." the vendor, acknowledgment or receipt of vendor O.A. records is unnecessary. 56. ANSI i:4 5. 2. 9 Applicable Codes and Codes and standards used in Appendix A Standards used in design are not considered Design. " records" to be stored and controlled per the requirements of N.45.2.9. They will be stored and controlled in accordance with normal library practices. A-?T

Revision 2, 6/3/77 i TABI.E A Regulatory Guide / ANSI Std. Interpretation / Alternate /_ Item No. Heference Requirement Exception 57. ANSI N45.2.10 " Quality Assurance Terms Where terms defined in and Definitions." ANSI N45.2.10 are also de-fined in other standards to which Con Edison has referred in the " Foreword" of the program description, the definitions in those other standards shall apply. 58. ANSI N45.2.10 Definitions of " Certificate Based upon the guidance of of Conformance" and ANSI N45.2.13, 10.2, the " Certificate of Compliance". definitions of these two terms will be exchanged. 59. ANSI N45.2.10 Definition of "Modifi-Modification - A change to cation". an item's configuration, materials (s) or function (s) such that the item does not conform to previously approved design documents. 60. ANSI N45.2..ll Program procedures shall A variety of experience reports Section 2.2 cover making experience from a number of sources are reports available to made available to design cognizant design person-personnel without benefit

nel, of written procedures.

A-24

11evision 2, 6/3/77 TABLE A Regulatory Guide / ANSI Std. Interpretation / Alternate / Item No. Reference Requirement Exception 61. ANSI N45.2.ll " Program procedures Procedures describing Section 2.2 shall cover necessary technical training are un-training of personnel necessary. Ilowever, our performing activities program includes procedures covered by this standard." for programmatic training of Engineers. 62. ANSI N45.2.11 "The results cf the review Con Edison documents Section 6.3 shall be documented... a completion of the design number of basic questions verification activity, but that shall be addressed..." does not necessarily document that each of the questions listed has been considered in the verification process. The subjects required to be considered during design review are identified in procedures. 53. ANSI N45.2.13 Specifies subjects to be Except in special cases items Section 5.2 evaluated during bid d., e., and f. may be evaluatee evaluation. prior to submittal to bids. A-25

Revisian 2, 6/3/77 TABLE A Regulatory Guide / ANSI Std. Interpretation / Alternate / Item No. Reference Requirement Exception 64. ANSI N45.2.ll " Changes from specified Section 3.1 design inputs including the reason for the changes shall be identified, approved, documented and Changes from specified design controlled." inputs and quality standards - are identified, approved, documented and controlled. The reasons for the changes Secr. ion 4.2 " Changes from specified need not be documented. quolity standards including reasons for the changes shall be identified, approved, documented and controlled." 65. ANSI N101.4 Identifies numerous de-When N101.4 is applied, new tailed, specific require-quality requirements will be ments that must be developed based on it's accomplished in the provisions, but specific course of procuring, requirements, such as applying and inspecting documented site meetings, protective coatings. field demonstrations, sub-strate priming, applicator reporting, inspection reporting and report forms will be con-sidered on a job-by-job basis. A-26

~ ', June 3J, )f77/7/ i TAI 3LE D l Item No. Reg. Guide / ANSI Std. Ref. Guideline Interpretation / Alternate ANSI N45.2.1, 1973 " Cleaning of Fluid Systems...." (cont 'd ) The sixth "should" The degree of surface ~ '-- af cleanliness and the fre- - -- :..,, w i l l June 3, 1977 TABLE D Item No. Reg. Guide / ANSI Std. Ref. Guideline Interpretation / Alternate ANSI N45.2.1, 1973 of Fluid Systems...."" Cleaning 1. Subsection 3.1.1 "Such items should re-ceive their required This "should" is beyond the level of cleanliness.. scope of this standard as indicated by the last i 2. Subsection 3.1.2.1 sentence on the page. Under " NOTE"," Local-ized rusting...should Laboratory type tests on be evaluated metallur-localized rusting will be gically." conducted when for such tests the need is deter-mined by Engineering or 3. QA. Section 5. The fourth "should" ) requires fabrication of ) a complete unit wherc inspection can bc ) blocked. ) The special 1 fabrication ) a id' inspection re " 1 rua, r: e-3

June 3, 1977 TABLE D g June 3, 197.7, June 3, 1977 TABLE D Item No. Reg. Guide / ANSI Std. Ite f. Guideline Interpretation / Alternate ANSI N45.2.1, 1973 " Cleaning of Fluid Systems...." (cont'd) 8. Subccation 7.1 The first "should" Loose tools will be con-requires attachment trollcd as specified by of loose tools "to procedure or by OA. cither the workman Precautionary measures or the exterior of such as barriers between the system with it work areas, and tool lanyard." check-in and ' heck-out c controls may obviate the need for a ttachment. 9. Subsection 7.2.2 The firnt "should" When alkaline cleaning specifies a method is pe:. formed, it will be for determining the accomplished in accor-effeetivenenn of el.ince wiI h Ii.-

r.. p i i. -

.. i s... i i ii... i... l e....

June 3, 1977 TABLE 11 Item No. Reg. Guide / ANSI Std. Ref. Guideline Interpretation / Alternate ANSI N45.2.1, 1973 " Cleaning of Fluid Systems...." l. Subsection 3.1.1 "Such items sitould re-This "should" is beyond the ceive their required scope of this standard level of cleanliness.. as indicated by the last sentence on the page. 2. Subsection 3.1.2.1 Under " NOTE"," Local-Laboratory type tests on ized rusting...should localized rusting will be be evaluated metallur-conducted when the need gically." for such tests is deter-mined by Engineering or LA. 3. Section 5. The fourth "ahculd" ) requires fabrication of ) a complete unit where ) inspection can bc ) The special fabrication blocked. ) and inspection require- ) taents will be complied, The fifth "should" ) with as required by requires inspection of ) Engineering or QA. the completed unit im- ) mediately prior to ) closing access points. ) D-1

Juno 3, 1977 TABLE B Item No. Reg. Guide / ANSI Std. Ref. Guideline Interpretation / Alternate ANSI N45.2.1, 1973 " Cleaning of Pluid Systems...." (cont'd) 4. Section 5. (cont'd) The sixth "should" The degree of surface requires cleaning of cleanliness and the fre-surfaces before pro-quency of cleaning will ceding to the next be as determined by installation or con-Engineering or QA. struction step. 5. Section 5. The seventh "should" Organic acids will be prohibits the use of used only as permitted by mineral or organic Engineering. After their acids on stainless use, however, all resi-steel. dual traces of the acid ka 1 be removed. 6. Section 5. The eighth "should" When the need for re-requires removal.of moval of rust is deter-local rusting from mined, it shall be re-corrosion-resistant moved by mechanical alloys ny mechanical means. means. 7. Section 6. The second "should" We interpret system to requires personnel mean the primary coolant entering the system system. to wear clean outer clothing and shoe covers. B-2

u June 3, 1977 TADLE D Cuideline Interpretation / Alternate Item No. Reg. Guile /A;4SI Std. Ref. ANSI N45.2.1, 1973 " Cleaning of Fluid Systems...." (cont'd) 8. Subsection 7.1 The first "should" Loose tools wil'1,bc con-requires attachment trolled as specified by of loose tools "to procedure or by QA. cither the workman Precautionary measures or the exterior of such as barriers between the system with a work areas, and tool lanyard." check-in and check-out controls may obviate the need for attachment. 9. Subsection 7.2.2 The first "should" When alkaline cleaning specifies a method is performed, it will be for determining the accomplished in accor-offectiveness of dance with the require-alkaline cleaning. ments of Engineering. 10. Subsection 7.2.2 (cont'd) The second "should" ) requires flushing of ) pockets cnd dead legs. ) ) The third "should" ) When alkaline cleaning is requires that atten- ) performed, it will be ac-tion be given to ) complished in accordance removal of uolution. ) with the requirements of ) Engineering. The fourth "should" re- ) quires system to be ) scaled. ) D-3

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=- L , BVPS FSAR Amendment 16 l a May 1975 A.2.2 Oaerations Quality Assurance Program {- Introducti on and Scope 6 An Operation Quality Assurance Program is established by Duquesne Light Company for the operations phase of Beaver Valley Power l Station. The program is written to conform to the require:uents of 10CFR50, Appendix B, " Quality Assurance Criteria for Euclear Power Plants," and NRC Regulatory Guide 1.33 " Quality Assurance Requirements (Operations)." The guidance contained in WASH 1284, 15

1. ~

W dated October 26, 1974, WASH 1309, dated May 10, 1974 and WASH S E S "t j 1283, dated May 24, 1974 is utilized as indicated in the L Attachment to Section A. 2. The purpose of the Operations Quality d 8b # ' l Assurance Program is to ; assure that the installed quality of the Beaver Valley Station is maintained throughout the life of the plant. The Operations Quality Assurance Program applies to all safety related (Category I) structures,

systems, and components, throughout the life of the plant.

The Category I structur0s, systems, and components are identified in Table A.1-1. A.2.2.1 Oraanization The organizations which have ^ responsibilities for performing activities affecting quality, during the opera tions phase of Beaver Valley Power Station are shown in the organization chart of Figure A.2-3. The Operations Quality Assurance Program identifics in detail the functional responsibilities of the organizations within Duquesne Light Company which participate in quality related activities. 6 The Operations Quality Assurance Program is established and managed by the Quality Assurance Manager, who reports to the Vice President, Engineering and Construction Division. The Quality Assurance Manager has the authority to report quality matters to any level necessary within Duquesne Light Company, including the President, and the Vice President, Operations Division, in order to establish effective corrective action. The Duquesne Light Company President, the Vice President, Operations Division and the Vice President, Engineering and Construction

Division, comprise the Executive Management Group.

The effort of the Quality Assurance Manager is directed solely to Quality Assurance. He purposely. has no responsibilities for station costs or schedule considerations. Saf ficient personnel are made available to bnplement the Duquesne Light Company Quality Assurance Program. The Duquesne Light Caupany Quality Assurance Program provides written policies, procedures, and instructions governing the Quality Assurance a ctivity. In addition to -the Duquesne Light Company wuality Assurance. Program, a quality control program is established which describes the activities performed (at Beaver Valley Power S*ation) by the Quality Control Supervisor and his staff. The Quality Control Supervisor reports to the Superintendent of nuclear Services. [ A.2-10

• =

l W

OYs re.R. C.2EEK (ngsEyC_EuptAt.) a cluded in Appendix C to this Plan. a ~_ The Manager-Uperational Quality Assurance is responsible 'or main, taining a comprehensive training program for both the original training and retraining of personnel in the Operational Quality Assurance Staffe The s 1 training program will include, as appropriate: 1ectures, formal schools, job experience, and individual study.i' He alco ensures that quality assur-ance indoctrination is given to Generation Division personnel who are not " in the Operational Quality Assurance Staf f, 'but whose job responsibility ill affect quality. 2-1 Each Manager maintains training programs and procedures to ensure the proper job related training and qualification of his perscnnel. Each ~ ,o, Station Superintendent is responsible for the indoctrination and training e of plant staff personnel performing activities affecting quality or opera-tions, and for ensuring that, where required, operators are formally licensed or qualified.,_ _ _ -- - ~ The control of contractors who perform nuclear related engineering, construction or other technical services is specified in Section V'(PRO-CUREMENT CONTROL) of this Plan. The Manager-Safety and Security is responsible for maintaining a comprehensive training program for both original training and retraining of Fire Brigade persondel. 7 Contractors who perform Kepair Authorization related work are required to have one or more of the following: an appropriate, valid ASME code stamp for the work performed; a valid Repair Certificate of Authorization (. I from the National Board of Boiler and Pressure Vessel Inspectors; a valid Repair Authorization from the State of New Jersey; or else, they shall-work l as an extension of the Jersey Central Power & Light Company Repair Authori-l. zation Program. Each Manager is responsible for specifying which requirements a con-tractor will utilize in the performance of that work which is performed under the guidance of his organization. These requirements shall be specified in the appropriate precurement documents. 4 i For nuclear safety applications, the Plant Operations Review Committee f (PORC), the Independent Safety and Review Group (ISRG), and the General Of fice Review Board (GORB) provide: safety reviews of procedures, tests, l experiments, and modifications; review of plant operations; investigation j of Reportable Occurrences, and Technical Specification Violations, etc., as required in the Safety Technical Specifications, Section 6.5. For activities falling within the scope of Part I of the Quality Assurance Systems List, Jersey Central Power & Light Company shall utilize the guidance off the following documents as follows: gy,g 1. Regulatory Guide 1.8, Revision 1, September 1975, " Personnel Selection and Training" - Exceptions: ( TITLE H PA GE ! REVISION NO. DATE Operational Quality Assurance P1.an 53 3 November 9, 1979 I v - ., ~

A. Guidelines have long been established in the company with respect to awarding jobs to plant maintenance, operations, and other bargaining '( unit personnel who tay be involved in testing, f examination and inspection activities. Personnel are qualified in accordance with the Jersey Central Power & Light Company Job Description Manual. JCP&L believes that the requirements specified in the Job Description Manual meet the intent, and in many cases, exceed the require-ments of ANSI N18.1. In certain specific cases, we envision that there may be individuals in the future who will be qualified by JCP&L because it feels the individual is capable of performing a r j ob even though he does not meet the detailed guidance contained in ANSI N18.1 with respect to length of experience and formal training. B. In the event there is a conflict between ANSI N18.1 and the Station Safety Technical Specifications, Section 6.5 on personnel qualifications, the Station.:- Safety Technical Specifications shall apply.' 2. Regulatory Guide 1.28, June 7, 1972, " Quality Assurance Program Require =ents (Design and Construction)" - Exceptions: A. The JCP&L Co. Operational Quality Assurance Plan has been written to implement the requirements of .t; 10CFR50 Appendix B as was ANSI N45.2. The content and level of detail in both the JCP&L Co. Ope ra- - l tional Quality Assurance Plan and ANSI N45.2 are essentially the same; and, therefore, JCP6L Co. considers that its Operational Quality Assurance Plan parallels the intent of ANSI N45.2 and is its nechanism for the implementation of 10CFR50 Appendix B. Por this reason, a specific commit-cent to ANSI N45.2 does not enhance the Cperational' Quality Assurance Plan. 3. Regulatory Guide 1.30 - August 11, 1972, " Quality Assurance l Requirements for the Installation, Inspection, and Testing j of Instrumentation and Electric Equipment" - Exceptions: l A. ANSI.N45.2.4 Guidance will be utilized in conjunction with the JCP&L Operational Quality Assurance Plan vice ANSI N45.2. B. Sections'5.2 and 6.2 of ANSI N45.2.4 last t e s e.s which are to be conducted during the construction phase. In lieu of this, J P&L Co. utilizes its Engineering ~and/or Maintenance organizations to TITLE _ PAGE REV;S!CN NO. DATE Operational'Qualit'y Assurance Plan 54 3 November 9, 1979 g

est-a'blish the need for specific tests or test procedures during the operational phase. Test procedures are reviewed by PORC. g [2e ubery bu d, l.M 4. Regulatory Guide 1.37 - >Srch 16,1973, "Qtclity Assurance Fequirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants" - Exceptions: a A. ANSI N45.2.1 Gu' dance will be utilized in conjunction with the JCP&L Operational Quality Assurance Plan vice ANSI S45.2. = B. Section 4.0 of ANSI N45.2.1 states that items are not to be delivered to the point of installation sooner than necessary unless the installation location is con-sidered a better storage area. JCP&L Co. strategy for the storage of items is based on many factors, one of which is to not adversely affect the items acceptability while in storage. If other factors cake it desirable to store an item at the installation site, and the location is acceptable from a quality standpoint, it is.not our intention to eliminate that site as a potential storage area. C. Section 6.0 of ANSI N45.2.1 states that where environ-mental contamination causes degradation of quality, seals are installed and the item is tagged with identi-ficatiens and instructions for seal removal. JCP&L Co. utilizes procedural controls which specify the authori-( zation requirements for seal removal. " Tags" are not normally utilized. D. In that this is an Operational Quality Assurance Plan, many aspects of this standard arg,,not applicable, e:. cept pcTsibly on rare occasions. For this reason, JCP&L does intend to have established procedures for all aspects i not of this ANSI Standard. l 5. Regulatory Guide 1.38 - March 16,1973, " Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, i and Handling of Iteas for Water-Cooled Nuclear Power Plants"- Exceptions: A. ANSI N45.2.2 Guicance will be utilized in conjunction with,the JCP&L Operational Quality Assurance Plan vice ANSI N45.2. B. Section 7.4 of N45.2.2 states that a system should be established to indicate acceptability of all equipment snd rigging after each inspection, specify control of nonconforming lifting equipment, and cupplement periodic inspections with special visual and nondestructive ~ TITLE PAGE REVISION NO. l D TE I Operational Quality Assurance Plan 55 3 November 9, 1979 9

examinations and dynamic load ~ tests. In lieu of this, JCP&L Co. does perform dynamic load tests on new equip-ment, preventive maintenance on cranes, nondestructive ( examinat'.on of lifting hooks annually, and a visual inspection of lifting equipment priur to use. C. Off-site inspection, examination' or testing will be audited under the direction of a qualified lead auditor vice an individual certified to ANSI N45.2.6. D. Packages will be marked with the weight when deemed necessary in lieu of when the weight is in excess of 100 pounds. 6. Regulatory Guide 1.39 - March 16, 1973, " Housekeeping Require-ments for Water-Cooled Nuclear Power Plants" - Exceptions: A. ANSI N45.2.3 Guidance will be utilized in conjunction with the JCP&L Operational Quality Assurance Plan vice ANSI N45.2. ~ B. Section 2.1 of ANSI N45.2.3 states that cleanness recuire-ments for housekeeping activities are established on the basis of zone designations. JCP&L does noc intend to utilize zone designations. There are specific require-ments for general plant cleanness. When planning a specific activity, one of the many items considered is ~ cleanness requirements and specific requirements will (.: be established when necessary. In addition, clothing requirements, access restrictions, etc. are governed by s. health physics practices and/or are established for specific situations. C. Section 3.2.3 of ANSI N45.2.3 discusses fire protection. l Except for the quality assurance cspects of fire protection, no specific commitments are made in this Plan. As part of other activitics, JCP&L Co has established positions or conmitments relating i to fire safety or protection. l D. ANS1 N45.2.3 discusses construction related aspects, I such as: temporary construction facilities, ex-ceptionally large accumulations of materials, refuse i and garbage dumps, and the mobilization and deploy-l ment.of construction tools, supplies, and equipment. I These aspects of ANSI N45.2.3 are nor applicable to an operational plant and are not considered in JCP&L Co. operationally-oriented procedures. 7. Regulatory Guide 1.54 - June 1973, " Quality Assuranca Require-ments for Pr'otective Coatir.;s Applied to Water-Cooled Nuclear Power Plants" - Exceptions: g TFTLE PAGE ! REVISION NO l DATE l Operational Quality Assurance Plan 56 3 INovember 9, 1979

A. ANSI N101.4-1972 will be used in conjunction with the JCP&L Co. Operational Quality Assurance Plan vice ANSI N45.2. C B. When performing coating repairs or touch-up, the original coatings and applicaticn requirements will aest likely be utilized for compatability with ex-isting coating systems. For this reason, it may not be possible to comply with all requirements which are imposed on the coatings 'or coating manufacturer. 8. Regulatory Guide 1.58 - August 1973, " Qualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel" - Exceptions: A. ANSI N45.2.6 Guidance will be utilized in conjunction with the JCPGL Operational Quality Assurance Plan vice ANSI N45.2. B. The Operational Quality Assurance Organization is resp'nsible for Quality Assurance including a significant portion of Quality Control; however, there are typical quality control functions which righcfully belong to other organizations. Some examples are: performing surveillance testing of installed plant equipment, taking dimensions on parts that JCP&L manufactures; and obtaining cycle tLmes on valver. The Site Quality Assurance organi- ,_(- zation, in respect to the preceding examples, is per-forming a verification function. It will not generally retake all ceasurecents taken by the mechanic; but it may observe the taking of measurements or take snot ceasurecents to verify the correctness of the mechanic's measurecents. In the area of surveillance testing, it may observe the performance of the sur-veillance testing to assure conpliance with established procedures, etc., on a se 7 e basis. In the case of 1 the mechanic, opetetor, etc., at an operating nuclear power plant, the plant individual actually does I caintenance or operations work and as part of this j work, cakes ceasurements or conducts tests of oper-l ability. The type of inspection and test work done by 5 Oyster Creek Station personnel will normally fall under I the concept of cali*aration, repair, or operation, as defined in ANSI N18.1, and, therefore, comes under the guidacce 'of ANSI N18.1, Section 3.2.4 as be'.ng one of the skills requ; red of these people. The Operational Quality Assurance personnel more closely parallel the inspection, and test personnel concept discussed in ANSI N45.2.6, and therefore, are under the requirements of ANSI N45.2,6. In this light, JCP&L will:

g TITCE PAUE '

REVIS:ON to. DATE Operational Quality Assurance Plan 57 3 November 9, 1979 I 7,

1) As specified in this Plan, utilize the guidance of ANSI N18.1 - 1971 for plant (- personnel performing inspection, examina-tion, and testing functions associated with normal operation of the plant, such as surveillance testing, maintenance, and certain technical reviews routinely assigred to the on-site operating organization. e 2) As specified in this Plan, utilize the guidance of ANSI N45.2.6 - 1973 for Quality Assurance personnel whose qualifi-cations are not required to meet those specified in ANSI N18.1 and who are per-forming inspection, examination and testing activities during the operational phase of the plant. The Q.A. experience cited for Levels I, II, and III shall be interpreted to mean actual experience in carrying out the types of inspection, examination, and testing activities being performed, or else in performing the types of activities being inspected, examined or tested. 9c 9. Regulatory Guide'l.64 - Revision 2, June 1976, " Quality Assurance Requirements for the Design of Nuclear Power Plants" - Exceptions: A. ANSI N45.2.ll Guidance will be utilized in conjunction ,s t,_, with the JCP&L Operational Quality Assurance Plan vice ANSI N45.2. l 10. Regulatory Guide 1.74 - February 1974 " Quality Assurance Terms and Definitions" - Exceptions: A. JCPFL has chosen to include defi$itions in its Operational Quality Assurance Plan. It considers these definitions as its alternative to committing to this Regulatory Guide. I i 11. Regulatory Guide 1.88 - Revision 1975 comment version, " Collection Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records" - Exceptions: j. i A. ANSI N45.2.9 Guidance vill be utilized in conjunction with.the JCP&L operational Quality Assurance Plan vice ANSI N45.2. j. 7 B. Section 1.2 of. ANSI N45.2.9, Applicability, with respect to contractors, suppliers, vendors, etc., Jersey Central Power & Light Company will establish specific require-ments for the collection, storage, and maintenance of g TITLE PAGE - REVISION NO. ' DATE 58 3 Nolenber 9, 1979' Operational Quality Assurance Plan ~ l_ i

Quality Assurance Records and impose them through l'~ procurement documents. In addition to'the considerations in this standard, consideration will be given'to the ) {,s specific standar'ds of the supplier industry involved and realistic requirements will be established. i i C. Section 5.5 of ANSI N45.2.9, safekeeping, Jersey Central Power & Light Company will establish security measures which will restrict access to. record storage areas and will provide protection against record

• loss through j

larceny and vandalism.i 1 j D. With regard to the storage of records, JCP&L utilizes-the' duplicate file concept and has duplicate files-in widely separated locations, but there are certain 4 records, (Single Copy Records), which are not good candi- ]j dates for ' duplication because of the nature of the record. ' Examples of these exceptions are strip charts, radiographs, and other recorder charts. j E. Jersey Central Power & Light Company utilizes a vault for ,I Single Copy Records. Single Copy Records are collected on a j " Day to Day" basis for a period of time which is dependent i upon the nature of the record and the need for access to j that record. We do'not envision that this time period will exceed six (C) months. During this time,.the records will , be kept in an air conditioned, fire resistive building, such j ], as the main and auxiliary office buildings at the plant, on j metal shelves or in metal desks or file cabinets. Strip y .1 charts (a major portion of the Single Copy Records) will be kept on steel shelves in the plant Document Center which' is located in an air conditioned, fire resistive building. 'If j Single Copy Records are kept,on site in, excess of six - months, they will be kept in a one hour rated file cabinet or better. These file cabinets will be located in a fire resistive, air condit!oned building. 1 F. Single Copy Records =ay have to be removed from the vault, i from time to ti=e, for reference. Examples could include l operational needs, NRC inspections, and answering NRC inquiries. In the event this need occurs, the records will i be safeguarded in the same manner as Item 11.E above. I ) 17. Regulatory Guide 1.94 - April'1976, " Quality Assurance Requirc-j ments for Installation, Inspection, and Testing of Structural l' Concrete and Structural Steel During the Construction Phase of I' Nuclear Power Plan'ts" - Exceptions: A. This Regulatory Guide deals ~with the construction of con-tainment structures and other structures needed to prevent } or mitigate the consequences of a postulated accident. J

k.

TITLE PAGE - REVISION NO. DATE i Operational Quality Assurance Plan 59 3 November 9,1979 ' i!. i

'/ In that this Quality Assurance Plan addresses the operational phase and no construction which would l( apply under this Regulatory Guide is anticipated without special licensing approvals, JCP&L chooses not to take a position on Regulatory Guide 1.94. 13. ANSI N18.7-1972, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants" - ) Exceptions: A. ANSI N18.7 Cuidance will be utilized in conjunction with the JCP&L Operational Quality Assurance Plan vice ANSI N45.2. B. Section 4.0 discusses review and audit, JCP6h has revised Section 6.5 of the Safety Technical Speci-fications and this document states JCP&L Co.'s position on_this subject. 3 14. ANSI N45.2.8 - Draft 3, Revisicn 3, April 1974, " Supplementary Requirements for Installation Inspection and Testing of Mechanical Equipment and Systems" - Exceptions: A. ANS1 N45.2.S Guidance will be utilized in conjunction with the JCP&L Operational Quality Assurance Plan l vice ANSI N45.2. l(,. B. Much of this standard applies to construction and preoperational testing. As a result, many of the listed tests are not appropriate in an operational-plant. In lieu of this, JCP&L Co. utilizes its Engineering and/or Maintenance organizations to establish the need for specific tests or test pro-cedures during the operational phase. Test pro-, cedures are reviewed by PORC. l l 15. ANSI N45.2.12 - Draf t 3, Revision 4, February 22, 1974, " Require-. ments for Auditing of Quality Assurance Programs for Nuclear Power Plants" - Exceptions: j A. ANSI N45.2.12 Guidance will be utilized in conjunction with the JCP&L Operational Quality Assurance Plan vice' 1 N45.2. B. With regard to Section 3.4.2 of ANSI h 45.2.12, this Operational Quality Assurance Plan establishes audit schedule requirements in Section XII (AUDITS) and supersedes ANSI N 45.2.12 in this area. TITLE PAGE REVIS!CN NO. DATE l Operational Quality Assurance Plan 60 3 November 9, 1979 l l l 1

~ 16. ANSI N45.2.13 - August 1974, Revision 0, Draft. 3, " Quality Assurance Requirements for Control of Procure =ent of Items and (- Services for Nuclear Power Plants" - Exceptions: A. ANSI N45.2.3 Guidance will be utilized in conjunction with the JCP&L Operational Quality Assurance Plan vice ANSI N45.2. B. k' hen establishing supplier Quality Assurance Program requirements and evaluating Quality Assurance Programs, Jersey Central Power & Light Company shall utilize Section VII of this Plan which may include imposing one or more of the following documents: 1) 10CFR50, Appendix B; 2) Jersey Central Power & Light Conpany Operational Quality Assurance Plan and Program (excluding commitment ANSI N45.2 Guidance); 3) ANSI N45.2; 4) Section III of the ASME Boiler and Pressure Vessel Code (for Section III code work); 5) Other National Consensus Codes (when that code is specified and has quality requirements in-2 ^ cluded as part of the code); i,- C. Section VII of this Plan clearly defines Jersey Central Power & Light Company's mechanism for evaluating and con-l trolling suppliers. The program defined therein is complete and detailed, and is JCP&L's rechanism for accomplishing such activities. In this regard, no specific committent is nade by JCP&L to ANSI N45.2.13 in this area. D. Jersey Central Power & Light Company utilizes Certificates I of Compliance for many purposes varying f rom: a distributor certifying that it provided a commercial quality component, canufactured by an organization other than the distributor, in accordance with rather straightforward procurement documents; to, a manufacture; who =anufactures extremely complex components to very detailed specification;. In the first case, the distributor may act as a middleman whose activities are nothing core than ordering a standard catalog numbered item, storing it, and eventually delivering it to l the customer. In this case, the procure =ent documents cay require that a responsible individual in the organizatica document the fact that the distributor is providing an item which teets the procurement document requirements. It is 1 TITLE PAGE REVISiCN NO. ! pW j Operational quality Assurance Plan 61 3 November 9, 1979 5

~ often a straightforward task to verify the certificate's i Malidity by performing a one to one correlation of the actual item part numbers to the item part numbers on the procurement documents during receipt inspection. In the second case, procurement documents may require that the supplier's quality program detail the mechanism for pre-paring and approving Certificates of Compliance as well as detailed directions that must be included in the certifi-cate. In this case, many mechanisms (such as Audit, Sur-veillance, and Shipment Release) are utilized, as necessary, to verify the validity of the certificate. In conclusion, the uses of a Certificate of Compliance are many and varied, and the degree of administrative control and certificate complexity is a function of the item being procured. 17. In the event Jersey Central Power & Light Company determines that there are equivalent or better means of accomplishing an objec-tive than stated above, it shall implement that means and inform the Nuclear Regulatory Commis.sion (NRC) by means of an Operational Quality Assurance Plan change in accordance with 10CFR50.59. 18. In its commitment to a specific ANSI Standard by specific refer-ence to that standard or by implication through reference to a document which requires implementation of the standard, Jersey Central Power & Light Co. does not commit to any standard ref-erenced in that standard to which it has committed. Any commitment to such a standard is limited to its commitment to specific standards in licensing documents. 1 (- 19. In many cases, Jersey Central Power & Light Co. has defined terms I in a manner which is consistent with its program. In this regard, it does not necessarily comply with definitions of terms which are included in any standard to which it is committed. I i ~ i 1 l TIT!.E PAGE l REVIS:CN NO.! OATE fNovember9, I Operational Quality Assurance Plan 62 3 1979. 1 i 1 l

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a.- l 1 l APPENDIX B (Exceptions) The sub-categories of this Appendix serrarize the exceptiens noted in Section II of the Yankee Atomic Electric Ccapany Operational Quality Assurance Manual. Appendix B Sub-Category Standard / Guide Title B-1 ANSI til8. 7-1976 Administrative Controls and Quality Assurance for the Operat.*onal Phase of Nuclear Power Plants B-2 ANSI N45.2.3-1973 Housekeeping During the Ccastructi:n Phase of Nuclear Power Plants B-3 ANSI N45.2.10-1973 Quality Assurance Terns and Definitions 1 E-4 ANSI M45.2.12 Requirenents for Auditing of Quality i (Draft 4 Asssurance Progratas for Nuclear Revision 2-1976) Power Plants .i B-5 ' ANSI N45.2.2-1972 Packaging, Shipping, Receiving, l Storage and Handling of Items for 5 Nuclear Power Plants i i I i l t c'- TITL$ l PAGE l REV. NO. I DATE !?:h.4 APPENDIX B (Exceptions) 1 of 12 6 10/19/3 g p p

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.-Al ANSI N18.7 - 1976, Administrative Centrols and Ouality.\\ssurance for the Phase of Nucleeir Po er olants EXCEPTION: The fol owing exception is taken by the Yankee operating p.lants. ANSI standards not re ferenced in A.SI til8. 7-1976 but which are referenced in an ANSI stan'ard endorsed by N18.7-1976 shall not be considered as applicable to the Yankee Operational Quality Assurance Program. ALTER'!ATIVE: The Yankee plants r.ay use the noted standards as guid,s, as necessary. I l I i I TITLE PAGE < *:1, REV. NO. DATE j -{'y.d APPENDIX B (C::cepticas) r

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. s.:.a -,/ ANSI N45.2.3-1973, Housekcening During the Construction Phase of Nuclear Poeer Plants A. EXCEPTION: St3 section 2.1 - Pinnning b The Yankee operating plants take exception to the five-zone requirements specified in the subject standard. ALTERNATIV'E: The Yankee operating plants shall establish as a minimum a three zone program as follous: Zone III Zone III criteria shall be applied to major portions of the reactor coclant system which are cpened for inspection, r:aintenance or repair. 1. Access control over personnel shall be required. ' }, 2. Cleanliness shall be maintained, commensurate with the work being performed, so as to preclude the entry of foreign material to the Reactor Coolant System. 3. A documentell cleanliness inspection shall be performed it.madiately prior to closure. NOTE: The Zone III requirements may be expanded for certain maintenance / repair activities if deemed appropriate by plant management. In such instances applicable sections of Zones I & 11 shall be specified. Zone IV Zone IV criteria shall be applied to the radiatin control areas of the plant. 1. Standard janitarial and work practices shall be utilized to maintain a level of cleanliness commensurate with company policy in the areas of Housekeeping, Plant and Personnel Safety and Fire Protection. 2. Additional housekeeping requirer.ents shall be implemented as required for the control of radioactive contamination. bg TITLE I PAGE I REV. NO. DATE w.

F APPE

: DIX b (#::ceptions) 3 of 12 6

10/19/78 Sub Cate,qo ry r>-2 0

3 g,, ,,,f . 3.., e,a ;, ... u a .,.,r.~ a %.; s.b 1 i:o:,io'.'ul1 1 ::. :i.. :.: ii :..... : e ANSI 553.2.3-1973 (Cont.) Zone IV i i i-3. Smoking and eating shall be centro 11ed consistent with good health physics practices and to naintain cleanliness. Zone V j s i Zone V criteria shall.be applied to the remainder of the plant. i 1. Standard janitorial and work practices shall be utilized to rai:-tain a 1cvel of cleanliness cemensurate with company policy in the areas of Ilousekeeping, Pla.t and Personnel Safety and Fire Protectien. i .i 9 gn[ ~~ TITLE I PAGE I REV. NO. I DATE. ,., ~ _, APPE::D1:: B ( E:< ce p t ica s ) n 7,J Sub Category B-2 4 of 12 6 10/19/73

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m \\ tr..,f~.. ,..n~~, ....,,,.,,3 f3,.. .3 3, y E i.' s ;;. *; *.'a i u.... ') C.'...* U a i. u b,u t.i c'h i1 1 h ) B. EXCEPTIO':: s t Subsection 3.2 - Control of Facilities l 6 I The Yankee operating plants take exception to the control of tools, p equipment, materials and supplies used in Zone III. I h ALTEFllATIVE: 0 t The Yankee operating plants shall verify control for Zone III as indicated S in Exception A of this sub-category. f a a 3 l t 1 1 1 l l TITLE PAGE R E V. N O. DATE. c, 1 API'E:: DIX 3 (E::ceptions) gS wy Sub Category B-2 5 o f 12 6 10/19/78 g l

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.. J.] ..... J J s,i J ,m. g %...,,.?,~,.} 20 Turnpike Road Westborough. Massachusatts 01581 T-s ..:.= ., N A;iSI :145.2.10-1973, Qual __.tssurance Terms and Definitions EXCEPTION: Sabsection 2 - Terms and D,2finitions The Yankee operating plants take exception to the definitions of " Certificate of Conforinance" and " Certificate of Cenpliance". ALTEPdIATIVE: The Yankee operating plants shall reverse the definitions of the abcva terms so our Prograa will be in ccepliance with the implied definitiens in the ASMS ESPV Code and Yankee specifications. l i I i i i l i I, I c.d.a TITLE I PAGE 'REV. NO.I DATE ~.' APPENDIX B (Cxc epticus) Sub Category B-3 6 of 12 6 1C/19/76 6

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,/... O ANSI N'5.2.12 Draft 4, Rev. 2-1976. Res erents for Auditinz of Oualit r Assurance Programs for *uclear_ Plants _ EXCEPTION: Subsection 4.2.2 Tean Selection The Yankee operating plants take exception tn the requirenent for a " Lead Auditor". ALTERNATIVE: Tean Selection - In selecting; personnel for auditing assigar'ents, consideration sh'all be given to special abilities, specialized technical training, prior pertinent experience, personal characteristics, and. education. On.e or more auditors comprise an audit tean. Auditor [ responsibilities include establishing the pace of the audit, assurino co=.unications with the organization being audited, participation in the audit performance, and preparation and issuance of reports. i i 3 1 I I s I i ? I t l i I i .A TITLE PAGE I REV. NO.I DATE g:.. APPENDD. r, (0:ceptions) 7 of 12 6 10/19/78 2 Sub Category C-4 l;

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C ;I - : 0 ' = * /SSI N45.2.2 - 1972 Packaging, Shiopine, Receiving. Storaac & tiandline of Items for Nuclear Pcaer Plants A. [3ppption Subsection 3.7.1 & A3.7.1-Containers The Yankee operating plants take exception to the specific requirements for containers. Alt e rr. i t ive Containers shall be of suitable construction 'to assure material is received undamaged. Justification Containers shipped by closed carrier, stored inside and not subjected to a wet environment do not require weather resis tant fibe rbeard, therefore, this is an unnecessary expense. Additionally, numerous vendors utilize' shipping containers that do not cceply with the specific requirements of this section, i.e., flaps overlap. The acceptance criteria for a shipping container shculd be ertablished based on the capability of the container to cair.tain the cor.ponent/ material in a safe condition. Technology has advanced beyond the standard. B. Exception Sybsection 3.7.2 - Crates cnd Skids The Yanker operating plants take exception to the requireaent that skids and runners shall be used on boxes with a sross weight of 100 pounds or more. Alte rna t ive Skids or runners shall be used on boxes vith a gross weight of 100 pounds or more if practical. Justification l Storage methods and container design frequencly are such -hat l runners or skids are not feasible. I TITLE PAGE REV.NO. DATE ,$j)'g Appendiv 3 (Exceptions) 8 of 12 6 10/19/78 ,nfjf Subcategory B-5

vi.r/.iq:.=.;=..pn.w n =.s hu ps csin,otbyv n u on .1 n. s w, a a z.- ANSI : 45.2.2 (cont.) W C. Exception Subsection 5.2.1 - Shipping Datace Inspection The Yankee operating plants take exception to the requirement that a preliminary visual in pection or examination be performed prior to unloading. j Alternative _ i f The Yankee operating plants shall perform tl.ose required inspections after unloading. In special instances, pre-unloading inspections j i shall be performed. i. ) Justification 1 j Post unloading inspection is adequate to determine any damage that may have been incurred during shipping and handling. a D. Exception i Subsection 5.2.2 - Item Inspection ~ i The Yankee operating plants take exception to the requirement, that "The ir.spections shall be performed in an araa equivalent to the ( ~ level of storaj,e requirements for the item." . c Alternative f j The Yankee operating plants shall perform receiving inspection in a manner and in an environmant which do not endanger the requisite a l quality of the item; however, receiving area environmental controls may be less stringent than storage environmental controls for that j item. When inspections are perforned in receiving areas with j environmental controls less stringent than storage area environmental l controls, a time limit shall be established on a case basis for 1 retention of items in the receiving area. Retention time shall be such that deterioration is prevented and applicable manufacturer recommendations are addressed. Justification _ Receipt inspection activities are for a much shorter duration and therefore should not be sfojected tc, the same stringent requirements i as required for storage. i l i TITLE PAGE REV. NO.l !.' ATE l i i j Appendix B (Exceptions) 9 o f 12 6 3/19/79 i W4 Subcategory B-5 Amendaent 1 -~. 3 2 Y v u'te 'T'PD'r ee ge y m- +.- __.,-,~._-.._g

I UUI,.7'r)l*I po I n~n:n -, c-a - - 10 a il tili!~.':y v a .c - !! A Glu : b :.:1 ilb ' *,I J J e L 5 [ A!!S1 ::45.2.2 (cont.) c 0 e b E. Exception i Subsectfon 5.2.3 - Snecial Inspection 4 The Yankee operating plants take exception to attaching special in-f spection procedures to the item or container, 8 0 3 Alternative .o Special inspection proc 2dures shall be readily available to { i personnel perf orming inspections. g Justification-i Precedures are subject to less abuse and r. ore stringent controls i when maintained an file and not attached to the ite;.. Inspection status is maintained by tagging and procedure control. \\ I I. Dr.,-- _i TlTLc l PAGE I REV. NO. .it m 6

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Appendix B (Exceptions) 10 of 12 3/29/79 Auendment 1 Subcategory d-5

r A !!!wa~* A 't :n' n."p ~ ? ;~L;.*m ? O O ~ r C ll a[l'{ ' ti r ~s . : s c :. . w a u u..... ? f, {v ANSI M45.2.2 (cont.) ~# F. Exception _ s i A nendix A ' auasection A3.5.l(1) - Caps'& plu3s_ j l l that l The Yankee operating plants take exception to the requirenent non-metallic plugs and caps shall be brightly colored. j i Alternative i Non-metallic plugs and caps shall be of a centrasting color. Justification The purpose cf utilizing brightly colored plugs and caps is to assist in assuring obstructions are not inadvertently placed in operating By using plugs and caps of a contrasting components or systems. color this objective can be achieved. G. Exception _ Appendix A-3 Subsection A3.9(?T - Second Group, Markinns that The Yankee operating plants take exception ta the cequirer.ent container markings shall appear on a minimum of two sides. Alt erna t ive Containers shall be adequately marked to provide identification and retrievability. l l Justification _ Containers are tagged to provide identification and inspection status. Employment of two tags on small containers adds bulk and conf usion and does not provide for better identification or traceability. l n I TITLE I PAGE REV. NO.t DATE i dj 6 3/29/79 Appendix B (Exceptions) 11 of 12 .bendment 1 Subcategory B-5

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).' J i..* rl A ;SI !;45.2.2 (cont. ) H. Exception Moendix A-3. Subsection A.3.9(4) - 2cond Group. Markine W e Yankee operating picnts take exception to the requirement that container markings shall be no less then 3/4" high container pernitting. Alternative Container marki~ngs shall be of a size which permits easy recognition. Justification Markings were intended to provide identification and instructions. The criteria should be that the markings c]oarly provide the same. I. Exception l Ayyear'ix A-3 Subsection A.3.9 (6) - Second Creup, I'arking The Yankee operating plants take ' ext. ption to the information required for container carking. Al t e rn a t iv,e_ l Marking shall be adequate in each case to provide identification, traceability and instructions for special handling, as applicable. Justification The infornation required is excessive. Cluttering'a container with excessive markings only reduccr the naia objectives, maintaining identification and establishing special controls. I l' i i I. TITLE I PAGE REV. NO. DATE -f.. / Appendix B (Exceptions) 12 of 12 6 3/29/79 Subcategory S-5 Amendment 1 i ~ .. m. _ _ m m .o..m. .m

!Ilchx gv l i l a,u /;, (, t. Tin s APPENDIX C QUALITY ASSURANCE PROGRAM NRC REGULATORY GUIDE COMMITMENTS AND EXCEPTIONS Engineering, in establishing specific requirements for design will use regulatory guide positions controlled by Technical Functions in a project criteria document. Examples of positions taken :alative to. regulatory guides are listed. Those identified by an asterisk cover regulatory guides which are specifically quality related or impacted and are therefore controlled by this manual. The TMI Quality Assurance Program complies witn Section C of the NRC Rdgulatory Guides indicated below. Exceptions to NRC Regulatory Guide position are detailed in Part 2 of this Appendix. This Appendix addresses additional Reg. Guid s not listed in Rev. 7 of the Operational Quality Assurance Plan. Compliance witn tnese added Reg. Guides will apply to modi-fications, additions and activities per formed a f ter issue o f Rev. 8 and does not imply backfitting and/or retroactive compliance. It is also to De recognized that existing plant conditions, may prevent or preclude tne satisfaction of all requirements of a specific design related regulatory guide. The deviation will be documented and, along with the justification, will be approved by the Manager - Engineering and Design. ~ i O C-1 Rev. O d t

I ~ e., APPENDIX C PART I REG. CUTDE APH!!.. 19HO ANSI STD. COMPLTANCE R EMARKS el.B8 10/76. Rev. 2 Collectico Storage and Maintenance of N45.2.9 1974 Hodified See alternate method attached. Nuclear Power Plant Quality Assurance Records 1 94 4/76 Rev. 1 QA Requirements for Installation. Inspect;sa H45.2.5 1974 Hodified See alternate asthod attached. and Testing of Otructural Concrete & Steel during Huclear Power Plant Construction 1.116 5/77. Rev. D-R QA Requirements for Installation Inspection Mk5.2.8 1975 Modified and Testing of Mechanical Equipment and Systems See alternate method attached. s1.123 T/77. Rev. 1 QA Requirements for Control of Procurement of N45.2.13 1976 Pull Items and Services for Nuclear Power Plants Comply with " Regulatory Position".

• 1.14k 1/79 Itequireuents for Auditing of Quality Assurance N45.2.12 1977 Modified See connents attached.

Programs for Nuclear Power Plants 1.26 2/76, Isi. 3 QA Classiftentions and Standards for Water Modified See alternate method attached. Stream and Dadioactive Waste Containing Cer.ponents of Nuclear Power Plants 81 31 4/78. Rev. 3 control of Ferrite Content in 8tainlens Pull Steel Wald Metal 1.63 7/78. Rev. 2 Electric Penetration Assemblies in Containment 1.EEE-317 19T6 Modirted see clarif tention attnehed. Structure for Light Water Cooled Nuclear Power Plants 1.29 9/76 Rev. 3 Seismic Design Classification s Modified Same comment as for Beg. Culde 1.26. o

t~. = e 1 J i APPENDIX C. PART I CleNI'IMENT TO CUA!.iTY ASSURANCE SECUALTORY CUIDES FOR THREE I4ILE 10!AJJ APRIL. 1980 HEC. CUIDE_ DECREE OF ANGI STD. COMPLIMICE REMARKS

• 1. 0 5/77. Rev. 1-a Parsonnel selection and Training N18.1 1971 Pull Comply with "Betulatory Position".
• 1.28 2/T9. Bev. 2 Qaality Assurance Program acquirements Nk5.2 1977 Full Comply 64th " Regulatory Position".

(Dealan and Construction) 1.30 6/11/72 QA Requirements for the Installation.' Inspection Nk5.2.) 1972 Pull and Testing of Instrumentation and Electrical Comply with "Begulatory Position". Equipnent '1.33 2/TD, her. 2 Quality Assurance Program Requirements N18.7 1976 Hodified See alternate method' attached. (Operation) i 1 3T 3/16/T3 QA Requirements for Cleaning of fluid Systems ak$.2.1 1913 Modified 'see alternate method attached. und Associated Components of Water Couled Nucicar Power Plants 1 36 5/17. Rev. 2 qA Bequirements for Packaging. Chipping. Receiving. Storage and Handling of Items Ek53dP"1912 Modified See alternate method attached. for Water Cooled Nuclear Power Plants 1.3) 9/77. Rev. 2 Housekeeping Bequirements for Vater Cooled Nk5.2 3 1973 Full Comply tith " Regulatory Position". Nuclear Power Plants 1 54 6/13 qA Dequirements for Protective Coatings 101 k 1972 Modirted see alternate method attaehed. Applied to Water Cooled fluclear Power Plants + '1 56 T/T9 Pruposed Ltev.1 Qualifications or Nuclear Power Plant Inapection. 345.2.6 19T8 Hoita tt ed see m1 ternate method attached. 1.xamination urns Testing Personnel 1.6L 6/T6 Dev. 2 Quality Assurunce Dequirements for ti e Dealan Nk5.2.11 19T4 Modified See alternate method attached. i of Nuclear Power Plants )

• 1.lk 2/Tk Quality Assurance Terms and Definicions Nk5.2.10 1973 Pull Comply with
• Regulatory Position".

s e Q4=11tication requirements for Dadiation Protection Hanager are satjsfied by Badiation Protection Hanager or his deputy. ^

APPENDIX C, PART 2 NRC Regulatory Guide 1.30, August 1972 Quality Assurance Requirements for the Installation, Insoection and Testing af Instrumentation and Electric Equipment Met-Ed shall comply with the Regulatory Position estab-11shed in this Regulatory Guide in that QA program-matic/ administrative requirements included tnerein shall / apply to maintenance and modification activities even though such requirements were not in e f fect originally. Tecnnical requirements associated with maintenance and modifications shall be the technical requirements or better (e.g., code requirements, material properties, design mar-gins, manufacturing processes, and inspection requirements). NCR Pegulatory Guide 1.33, Rev. 2, February 1978 Quality Assurance Program Requireg,ents (Operation) The TMI QA Program complies with the regulat ry position of this guide with the following clarifications: 1. Paragraph C.4.a is interpreted to mean audits will ce made once each 6 months to verify the nonconfor-mances and corrective action program 1 properly implemented and documented, particularly as relatec to actions taken to correct deficiencies that affect items important to safety. 2. Paragraph 5.2.8 o f ANSI N18.7 - 197 6 titled "Sur- / veillance Testing and Inspection" In lieu o f a " master surveillance" senedule, a technical specification surveillance testing schedule shall be established reflecting the status of all inplant surveillance s_sts and inspections. 3. Paragraph 5. 2,15 o f ANSI N18. 7 - 197 6 titled i " Review, Approval and Control of Procedures" ) . The-tnird sentence of the third paragraph is inter-preted t'o mean applicaole procedures snall oe i reviewed following a reportaole incident sucn as an accident, an unexoected transient, significant operator error, or equipment malfunction. 4. Paragrapn 5.2.17 of ANSI N18.7 - 1976 titled " Inspections" 1 C-4 Rev. 0 \\

APPENDIX C, PART 2 Not all inspections will require a separate inspec-tion report. Inspection requirements may be inte-grated into appropriate procedures or other documents with the procedures or documents with the / l procedure or document serving as the record; how-ever, records of inspections will oe identified and retrievable. NRC Regulatory Guide 1.37, March 16, 1973 Quality Assurance Requirements for Claaning Fluids Systems j/ and Associated Components of Water Cooled Nuclear Power Plants The TMI Quality Assurance Program complies with the regula-tory position of this guide with tne following clarifi-cations: 1. The second sentence o f paragraph C.3 should oe amended to read: K "The water quality fe; final flusnes of fluid sys-tems and associated components shall be at least eaulvalent to tne quality required for normal oper-i ation. This requirement does not apply to disolved oxyaen or nitrogen limits nor does it infer that ..uumates or other additives normally in the system water will be added to tne flush water." 2. Paragraph C.4 should be amended to add: Material such as inks, temperature indicating cray-Sns, labels, wrapping materials (other than poly-ethylene), water soluole dam materi Is, lubricants, NDT penetrant materials and couplants, wnich con-tact stainless steel or nickle alloy material sur-faces shall contain no more than trace elements of lead, zinc, copper, mercury or otner low melting alloys or compounds. Maximum levels of water leacnable hloride ions, total halogens and sulfur compounds shall" be imposed on the a forementioned ' materials. t Y h \\(

c u_

b C-5 Rev. 0 ?

APPENDIX C, PART 2 NRC Regulatory Guide 1.38, Rev. 2, May 1977 V Quality _ Assurance Reauirements for Packaging, Snipoing, Receiviag, Storage and Handling of Items for Water Cooled Nuclear Power Plants The TMI Quality Assurance Program complies with the regulatory position o f this guide with the following modifica-tions: 1. Section 3. 6 o f ANSI N45.2.2 - 1972 concerns preven-tion of halogenated mateI #als from contacting stainless steel or nickel alloy materials. The position stated in Reg. Guide 1.37 also applies to this guide. 2. Section 3.7.1 o f ANSI N45.2.2 - 1972 Cleated, sheathed boxes will De used up to 1000 los. rather than 500 lbs. as specif(ed. Tnis type of box is safe fo r, and has been tested fo r, loads up to 1000 lbs. Other material standards (i.e., s FED Spec. PPP-B-601) allow this. Special Qualifi-cation testing shall be required for loads in i excess o f 1000 lbs. 3. Section 6/2/1 o f ANSI N45.2.2 - 1972 For storage o f level 0 items access wi.'l be con-trolled and limited by posting. Other positive controls such as fencing or posting of guards will be provided for higher storage levels. 4 4 Section A.3.4.1 Appendix to ANSI 45.2.2 - 1972 d ? The last sentence o f A.3.4. l(4) and (5) should be corrected as follows: (4) "However, preservatives for inaccessiole inside sur faces of pumps, valves and pipe systems containing, reactor coolant water ,shall be the water flushable type." (5) "ine name of tne preservative used snall oe indicated to facilitate touch up." 5. With regard to Section A.3.5.2 o f tne Appendix to ANSI N4 5.2.2 - 1972 entitled " Tapes and Adhesives": Tapes will meet a sulphur limit o f 0.30% oy weight instead o f 0.10% as specified in A.3.5.2(1)(a). n .? C-6 Rev. 0 ] Y

A?PENDIX C, PART 2 This limit is1 reasonable based upon the_ chemical content of commercially availaole tapes. Tapes will be of a contrasting color rather than l " Brightly Colored" as required by A.3.5.1(3). 6. With regard to Section A.3.7.1 of the Appendix to ANSI N45.2.2 - 1972 entitled " Fiberboard Boxes": l In lieu o f A.3.7.1(3) and,(4), the folicwing will be imposed: Fiberboard boxes shall be securely closed either with a water resistant adhesive applied to the entire area of contact between the flaps, or all setms ano joints shall be sealed with not less than 2-inch wide, water resistant tape. NRC Regulatory Guide 1.39, R3 *t. 2, September 1977 Housekeeping Reouirements for Water Coolea Nuclear Power / Plants Endorses ANSI N45.2.3 - 1973 The Operational Quality Assurance Program co plies with tnis guide with the 'following clarification: 1. With regard to Sections 2.1 and 3.2 of ANSI N45.2.3 1973 entitled " Planning and Control o f ( Facilities", respectively: The TMI Nuclear Station will not utilize the five level zone designation system referenced in ANSI N45.2.3, but will utilize standard janitorial and work practices to maintain a level of cleanliness commensurate with company policy in the areas of housekeeping, plant and personnel sa fety, and fire protection. Cleanliness will be maintained, consistent with the work being performed, so as to prevent the entry of foreign material into systems considered important a to sa fety. This will include as a minimum docu- .ted cleanliness inspections which w'111 oe per-mt o j formed immediately prior to system closure. Con-d trol c. will be' personnel, tools, equipment, and supplies estaolished when major portions of the re-j actor system are opened for inspection, maintenance j of repair. ~ ) Additional nousekeeping requirements will oe imple-i mented as reauired for control or radioactive con-s tamination. i { O f s ? C-7 Rev. O A i 4 s -Q J

APPENDIX C, PART 2' NRC Regulatory Guide 1.54, June 1973 / Quality Assurance Recuirements for Protective Coatings _Acolied to Water Cooled Nuclear Power Plants Endorses ANSI N101.4 - 1972 The Operational Quality Assurance Program complies with this guide with the following clarification: 1. Met-Ed shall comply with the Regulatory Position established in this Regulatory Guide in that QA programmatic / administrative requirements included therein shall apply to maintenance and modification ~activities even though such requirements were not in ef fect originally. Technical requirements associated with maintenance and modifications (e.g., code requirements, material properties, design margins, manufacturing processes, and inspection reauirements) shall be th,e original requirements or better. 2. The gu* dance o f Regulatory Guide 1.54 shall be followed for organic protective coatings selected and evaluated in accordance with pertinent sc:tions of ANSI N101.2 when_ applied to interior surfaces of the containment. The supplier's quality assurance program snall be approved prior to implementation. Quality Assurance documentation may not be similar to records and documents listed in Sections 7.4 tnrougn 7.8 of ANSI N101.4 out will ce evaluated to assure that they provide at least the same degree of documentation as required by tnis standard. NRC Reculatory Guide 1.58, Proposed Rev. 1, July 1979 s/ ? Qualifications of_ Nuclear Power Plant Inspection, Examination, and lesting Personnel iI Endorses ANSI N45.2.6 - 1978 i a ~ The Operational Quali.ty Asssurance Program complies with [ this guide with.the following clarification: 1 1. The guidance o f Regulatory Guide 1.58 snall be f followed as it pertains to tne qualifications of 4 personnel who. verify conforma,nce o f work activities ?j to quality requirements. The qualifications of W plant operating personnel concerned with day-to-day [ D k 5 o U C-8 Rev. O k 'i! F

APPENDIX C, PART 2 operation, maintenance, and certain technical ser-vices shall conform to Regulatory Guide 1.8. 2. Not all personnel who: A. Review and approve inspection and testing procedures, 8.. Evaluate tne adequacy of activities to accomplish the inspection and test objectives, C. Evaluate the adequacy of specific programs used to train and test inspection and test personnel, D. Certify Level III individuals in specific categories or classes, Will be certified as meeting the Level h b) capability requirements o f ANSI N 4.2.6-1978. Rather these personnel will be determ ned by management through evaluation of their education experience, and training to be fully qualified and competent to perform these functions. The basis for the determination will be documented. 7,_ NRC Regula tory Guide 1. 64, Rev. 2, June 1976 Quality Assurance Recuirements for the Desion o f Nuclear Power Plants t j Endorses ANSI N45.2.ll - 1974 l Met-Ed snall comply with the Regulatory Position estab- ,i 11shed in this Regulatory Cuice in tnat QA programmatic / administrative requirements included therin shall. apply to i maintenance and modification activities even thougn such requirements were not in ef fect originally. Tecnnical requirements (e.g., code requirements, material properties, design margins, manufacturing processes, and inspection reauirements) associated with maintenance and modifications shall be the original rc uirements or better. J The Operational Quality Assurance Program complies with this guide with tne following claIification to pa;r. graph d C.2(1) o f Regulatory Guide 1. 64 : Ii.in an exceptional circumstance the designer's immediate Supervisor is the j only technically cualified individual available, this review can be conducted oy the Supervisor, providing that: (a) the other provisions of the Regulatory Guide are ( satisfied, and (b) the justification is individually documented and approved in advance 'y the Supervisor's a C-9 Rev. 0 0

APPENDIX C, PART 2 management, and (c) ouality assurance audits cover frecuency and ef fectiveness of use of Supervisors as design verifiers to guard against abuse. NRC Regulatory Guide 1.94, Rev. 1, April 1976 Quality Assurance Requirements for Installation, Inspection [ and Testing of Structural Concrete and Structural Steel during the Construction Pnase of Nuclear Power Plants Endorses ANSI N45.2.5 - 1974 The Operational quality Assurance Program complies with this guide with the following clarification: Met-Ed shall comply with the Regulatory Position estab-lished in this Regulatory Guide in tnat QA program-matic/ administrative requirements included toerin shall apoly to maintenance and modification activities even thougn such requirements were not in e f ect origin-ally. Technical requirements associate with main-tenance and modifications sha}l be the original reauirements or better (e.g., code requirements, material properties, design margins, manu f ac turing processes, and inspection reauirements). NRC Regulatory Guide 1.116, Rev. 0-R, May 1977 Quality Assurance Recuirements for Installation, Inspection / ano Testing of Mecnanical Eauioment and Systems Endorses ANSI N45.2.8 Tne Operational Quality Assurance Program complies with this guide with tha following clarification: Met-Ed shall comply with the Regulatory Position estab-11shed in thi; Regulatory Guide in tnat QA program-matic/ administrative recuirements included therein shall apply to maintenance and modification activities even though sucn requirements were not ir, e f fec t ~ o r ig in a.ll y. Technical requirements associated with maintenance and modifications shall oe the original recuirements or better (e.g., code reau';ements, material procerties, design margins, manufacturing processes, and inspection requirements). d

)

NRC Regulatory Guide 1.2 6, Rev. 3, February 1976 1 Quality Group Classifications and Standard for Water, Steam v/ ano Radioactive waste Containing Components o f Nuclear ( Power Plants k C-10 Rev. O d n,

4 APPENDIX C, PART 2 Since tne original design and construction of the Three Mile Island Plants was to different classification criteria than contained in this guide; TMI will comply witn the regulatory position o f this guide with the following clari-fications: ~ 1. For madifications to existing plant systems and for new construction, items will be classified by Technical Functions according to this guide providing such action will improve the safety of the system being modified or make a significant improvemen t in overall plan t sa f ~ ty. Otherwise the items will be classified the same as the original design and construction. 2. Tle-in's to existing plant systems will be mide to the same or more rece't applicable code, staadard and technical require.aents which were applicable to the system to which the tie-in is to Oe made. NRC 9egulatory Guide 1.63 Rev. 2, July 1978 Electric Penetration Assemblies in Containment Structures for 1.*gnt dater Cooled Nuclear Power Plants )J Met-6d will comply with the regulatory position of this guide with the following clarification: For modifications to existing structures and to new constructions, this guide will be utilized providing Its use will improve the safety of the structure being modified or make e significant improvement in overall plant safety. Otherwise, the same or more ecent i Jpplicable code, standard oad tecnnical requirements applicabl's to the original design and construction will I be utiliz3d. NRC Regulatory Guide 1.144, January 1979 Auditing of Quality Assurance Programs for Nuclear Power \\/ Plants Met-Ed is in basic acreement with the position set forth in the Regulatory Guide subject to the following comments: 1. Section C.3.a(2) Tne proposed scheduling requirement for internal audits appears to cnange tne basis for having a rational, programmatic approach to auditing. In 4 \\ its place, the new regulatory guide requires manda-g tory auditing o f all program elements on a yearly A C-ll Rev. 0 E M% f m _ i

.o...- APPENDIX C, PART 2 basis. The latter would require that all elements obtain tne same attention regardless of importance, past performance, or to what extent other aspects of quality assurance measu,r,ing and evaluating tech-niques are used; as an example, tne extent to which surveillance and process monitoring is used. Accordingly, minimum schedule frequency will be as defined in Regulatory Guide 1.33. 2. Section C.3.b(1) Source inspection p'rovioes a controlled basis for replacing the need for external audits. Quality assurance program surveillance will also be used as another alternative. 3. Section C.3.b(2) While the licensee is responsible for procurement control, thiscanbeexercisedthroukhanannual evaluation of the contractor's performance using certinent results from manufacturing survell]ince, source inspection, receiving inspection, and other I applicable factors. The evaluation would include a recommendation as to the need for a scheduled program or proolem area audit. Hence, Puditing, like surveillance and inspection, will ou treated as a anality assurance tool used for evaluation. Furthermore, the recommendation to audit will include provisions for reviewing the importance and impact of the particular contractor's scope and s t a l.u s. NRC Regup tory Guide 1.88, Rev. 2, October, 1976 Colleccion, Storage, and Maintenance of Nuclear Power Plant Ava1133ility Assurance Records ,f Met-Ed will comply with the intent o f tr is regulatory guide ) 4 oy compliance with the requirements o f ANSI /ASME NQA-1-1979, Supplement 175-1 and Appendix 17A-1. j 4o 5 d C-12 Rev. 0 4w

v, - i ) { d( < ) r .lt l v ro,,,e w sSES-FSAR TABLE 17.2-1 OPERATIONAL QUALITY ASSURANCE PROGRAM Page 1 COMPLIANCE MATRIX NRC Reg. Guide ANSI Standard Subject Clarifications & Exceptions N 1.8 Rev. 1 N18.1 - 1978 Personnel Selection & See Chapter 13 22 Training 1.17 Rev. 1 N18.17 - 1973 Security Not included in the OQA Program {G 1.28 Rev. 1 N45.'2 - 1977 QA Requirements Full compliance 1.30 8/72 N45.2.4 - 1972 Electrical Installation, Cocunitment to the extent required by l6 Inspection & Testing ANSI N18.7-1976* l 1.33 Rev. 2 N18.7 - 1976 Administrative Controls & Full compliance Operational QA 1.37 3/73 N45.2.1 - 1973 Cleaning Fluid Systems & Commitment to the extent required by ANSI Components N18.7-1976* 1.38 Rev. 2 N45.2.2 - 1972 Packagiug, Shipping, Receiv-Commitment to the extent required by ANSI ing, Storage & Handling N15.7-1976* 1,39 Rev. 2 N45.2.3-1973 Nousekeeping Comitment to the entent required by ANSI 6 N18.7-1976* 1.54 6/73 N101.4 - 1972 QA for Protective Coatings Comitment to the extent required by ANSI ^ ^"' m.- 1.58 Rev. 1 N45.2.6 - 1978 Qualifice' ions of Inspection, Comitment to the extent requireu, 'NSI ~ Examication, & Testing N18.7-1976*; personnel who only handle t "y Personnel results or perforia document control "i.a.4.. mest mm, i.-- .s 1.64 Rev. 2 N45.2.11 - 1974 QA for Design Full,c6mpitance [ 1.74 2/'4 N45.2.10 - 1973 QA Terms & Definitione Full compliance 1.88 Rev. 2 N45.2.9 - 1979 Collection, Storage & Full compliance 20 Maintenance 6f Records a 1.94 Rev. 1 N45.2.5 - 1974 Concrete & Structural Steel Comitment to the extent required by ANSI Installation, Inspection, N18.7-1976* & Testing 1.116 Rev. 0-R N45.2.8 - 1975 Hechanical Installation, Comitment to the extent required by ANSI l6 Inspection & Testing N18.7-1976* 1.123 Rev. 1 N45.2.13 - 1976 QA for Procurement of Items Full compliance (6 & Services Rev.,2 2, 4/81

U / ~ ~ - ._ _ _ / - -- ssgs.FSAR i I!!LE_12.2:1_IGen1La ndt, page 2 t 1.L23 R e v. 1 04 Fire Protection cuidelines PJ11 :omp1Lsn=e limited to pequlatory {0 far Nuclear Power Plants P3sition 0.3, lg1((Lg,Ls33tiggg_ggoggle l 1.las 1/79 s45.2.12-1911 amotting of QA Programa PsL1 complisace l6 1.146 8/80 N 45. 22 3-19 7 8 g Qualification of OA rull :osp1Lan:e 20 Program Audit Personnel i t / Y

• Thasa standseds will be applied ss directed by the Mar.49er-NOA for activitias whi:h a...sre cosourabic in nature sni extent to related activities occurring during construction" as reqaired by ANSI N18.7-1975.

REY. 20, 2/81 O

1 RESPONSE TO REQUESI FOR ADDITIONAL INFOURION USNRC LETTER DATED AR7 DST 10,1977 1. .1 e ,;g6, e.. PEACH BOITOM ATCMIC FO'a'ER STATION UNITS 2 ANL 3 DOCKET N0 'S. 50-277 AND 50-278 OCIO3ER 1977

• N

k ,.., = l .4 Responses to Request for Additional Infon2ation NP.0 Letter G. Ioar to E. G. Bauer, Jr., August 8,1977 02estion 1. The Eagi2wedng & hesearch D2parkent has not provided a comnit-Appendix 17.2.B ment to ecnply with Regulatory Guide.1 33,11/3/72, "Qulity Assursace Program Requi enents," Regulatory Guide 1.Jo, 3/16/73, "Housekeepirg Require:ents for 'riater-Cooled Nuclear ?cuer Plants" and Regulatcy Guide 1.38,_10/1976, "Cellecticn, Storage, and Mainte:.ance of Nuclear Pcwer Pbnt Quality Assurance Recorn" in Since these Regulatory the Appendix 17.2.3 of the OQA progran. Guides can apply during the mo<lification phr_se, it is regar ated that a commit.nent to ecmply with these Regulatory Guides be provided in Appandix 17.2.B for activities associated with the Engineerirg & Research Department. hvised 17.2 Appendix B to provide commitrents as beques'wd in Response-Qaestion 1. ,1 Q2cstien 2. A question en Section 17.2, previcusly submitted to Philadelphia Electric Ccapny has not been answered. The Engineering & Research D3parkent will be involved in vendor QA evaluations and su veillance and major nodifications work as regaes'ad by tha Electric Production D2parbent. Since the Electric Production D2parbent is principally responsible for Feach Bottc: Atcaic Pcwer Station, Unit Ncs. 2 and 3, it is exFocted any delegatien of QA an'hority within Philadelphia Electric Conpany will comply with the controls described in Section 17.2 of the FSAR. Accordirgly, describe the extent that the Engineering & Research Der rhent will ccuply with the controls of Section 17.2 when parfo ming modifications to Peach Ectton Atcaic Pcwer Statien, Unit Nes. 2 and 3 The previous questica on Section 17 2 was answe ed in the I Resocnse : submittal of May 20, 1977 where the application of the OQA Program to E'.gineering & Ecsean:h D2parbent activities was 'hown by referencing nunerous secticns of FSAR Section 17 2. Er way of additional clarification, the Fagineering & Research D2 parte.ent complies with the corporate administrative centrols desc-ib2d in FSAR Section 17.2 which apply to parsennel working at the plant site. D2 sign, procurc=ent and installation of najor =cAi^i.catiens fcr Peach Bottc, Atenic Power Statien, Unit Ncs. 2 and 3 is perfomed by the Engince-ing & Ecsea~:h reprtr.ent under the centrols of de Peach Sctten Atonic Pcwcr Statien Quality Assurame Plan Volune I. Volme I win be evised to contain quMity assurance provisicas si:ilar to these described in FSAR Section 17 2 as applicab e to Engineering & Research D2partment activities, c.id% provide fcr imple.entation of the z Engineerirg & Research cc. mitments to the Regulatory Guides cr.d A.;SI ,'Jtandards as contained in FSAR Appendix 17.23. Volume I will be subject to review and acceptance by the Elect-ic Production D27rt:ca t.

~ PEACH BOTTOM ATOMIC PO*nR STATION UNITS 2 & 3 FSAR PAGE REVISIONS The folicwing pages are to be 1,serted into your copy of the FSAR. These pages are replacements as indicated below: Volume 6 Delete Substitute Page 17.2. 3-1 Page 17.2. B-1 Dated October 1977 j through through 17.2. B-4 17.2. E-7 I 0 e 6 k e l

. ~ = 1-l, it* 1 P3APS 1 i, _ APPENDIX 17.2.B 4 i REGULATORY GUIDES AND. ANSI STANDARDS ENGINEERING AND RESEARCH DEPARTMENT a 1 l l The Engineering and Research Department follows ANSI Stsndards I and USSRC Regvlatory Guides es described below: 1 i i i 1. Reeulatorv Guide 1.58, August 1973, Qualification of Nuclear 1 Power Plant Inspection, Examination, and Testing Personnel. ( E:,:forses ANSI N45.2.6-1973. i j The Engineering and Research Department follows Regulatory { Guide 1.58, August, 1973 and ANSI N45.2.6 (1973) exclusive of j other docu=ents referenced therein. 1 { ] Two particulars of ANSI N45.2.6 (1973) are implemented by the i Engineering and Research Departnent through alternate equivalent means described below. I 1 1 1 a. Par. 2.2.2 (Proficiency Testing). Specification SNT-TC-l 1A is applied to non-destructive testing (i.e. P.T., i U.T., M.T., and Eddy Current) only, and not to visual { inspections. ) 1 b. Section 3.2.1 Physical. The Medical Department of the j Philadelphia Electric Company records a detailed evaluation of the physical and = ental status of each l c=ployee. This evaluation begins with a thorough pre-j cap 2oyment exanination, and it continues throughout the period of service of each employee. The collection of ~ this data is accomplished by: (1) Exaninations and l evaluations of each employee who is disabled beyc=d a period of five days, repeated at various intervals until I he is capable of returning to work; (2) Requirement thct i the family ph;sician cub =it a definitive diagnosis and i reports of therapy; (3) Examination of enployees who are l incapable of perfor=ing full duty for deter =ination of j capabilities for 11=ited duty or restricted work; (4) [ Exacinations of employees for specific work assignments; (5) Evaluation of e nployees referred by their department l 4 I i 17.2.3-1 October 1977 .( b -..,_..m._,

^ ~ 4 betause of apparent proble=s and suspected disabilities. In

addition, the Construction and nesearch Divisions either have or are developing procedures which require vision examinations of those personnel who perform 2

inspections and specialized testing, in accordance with j APSI N45.2.6 (1973). .These procedures vill be fully i.plemented by January 1, 1978. 4 2. Regulatory Guide 1.30, August 11,

1972, Quality Assurance j

Requirements for the Installation, Inspection, and Testing of i Instrumentation and Electric Equipment. Endorses ANSI N45.2.4 - 1972. I j The Engineering and Research Department follows Regulatory Guide 1.30, August 11, 1972 and ANSI N45.2.4-(1972) exclusive j of other documents referenced therein. 1 One particular of ANSI N45.2.4 (1972) is inplecented by the Engineering and Research Department through alternate j equivalent ceans described below. i a. As an alternative to ANSI 331.7-1969 (referenced in ANSI N45.2.4 (1972), Section 9, Ite: 6) PECO follows USAS B31.1.0-1967 since Peach Sotto= Units 2 and 3 vere i constructed to USAS 331.1.0-1967. i l 1 3. Regulatory Guide 1.37, 3/16/73, Sy' Quality Assurance stens and Associated { Requirements for Cleaning of Fluid j Components of Water-Cooled Nuclear Power Plants. Endorses i ANSI N45.2.1-1973. 1 i The Engineering and Research Department follows Regulatory i Guide 1.37, 3/16/73 and ANSI N45.2.1 (1973) exclusive of i other documents referenced therein. i 1 i Guid'e 1.38, 3/16/73, Quality Assurance ] 4. Reculatory ~ for packaging, Shipping, Receiving, Storage and j Requirements j Esudling of Ite=s for Water-Cooled Nuclear Power Plants. Endorses ANSI N45.2.2-1972. f The Engineering and Research Department follows Regulatory i Guide 1.38, 3/16/73 cnd ANSI N45.2.2 (1972) exclusive of i other docu=ents referenced therein. I 1 17.2.1-2 October 1977 9i.

Two particulars of ANSI N45.2.2 (1972) are i=ple=ented by the Engineering and Research Department through alternate equivalent =eans described below. l a. k'i t h r e g a r d to paragraph.7.4 (Inspections of Equip = ant and Rigging) Engineering and Research Depart =ent will develop an equivalent altetaate approach. A procedure covering inrpection of hoisting and rigging equip =ent will be i=ple=ented by January 1, 1978. This procedure vill include provisions for inspection of hoisting and rigging equip =ent prior to use, accept /rej ect criteria (for such characteristics as wear, fraying, cleanliness, distortion, or other da= age or deterioration), control of nonconfor=ing equip =ent and docu=entation of inspection results. b. As an equivalent alternative to the four levels of classification established by ANSI N45.2.2 (1972), Section 2.7, each co=penent is treated on an individual basis. The Engineering and Research Depart =ent requires that each specification contain handling

stcrage, packaging, and shipping infor=ation.

This information incorporates the guidance and recottendations which are appropriate to each classification for packaging,

shipping, handling, and storage of equip =ent or

=aterials described in the specification. 5. Regulatory Guide 1.64, Revision 1, February

1975, Quality Assurance Require =ents for the Design,,of Nuclear Power Plants.

Endorses ANSI N45.2.11-(1974). l The Engineering and Research Depart =ent follows Regulatory Guide 1.64, Rev. 1, February, 1975 and ANSI N45.2.11(1974) exclusive of other docu=ents referenced therein. 6. ANSI N45.2.8-(1975), Supple =entary Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equip =ent and Syste=s for the Construction Phase of ;uclear Power Plants. l The Engineering and Research Depart =ent follows ANSI N45.2.8-(1975) exclusive of other docu=ents referenced therein. i -n 17.2.3-3 October 1977 ni + 9 -e

14 e s. \\ ' --/. i i j . Engineering and Research Department through alternate One particular of ANSI N45.2.8-(1975) is icple=ented by the ] equivalent means described below: i l j -a. Section 2.1 - This section requires the establish =ent of a for=al and docu=ented plan for each ites of work. The l j PECO procedure specifies the issuance of Job Menoranda, i which serve the equivalent purpose of outlining najor project requirements. t i i 7. Regulatory Guide 1.54,

June, 1973, Quality Assurance

} Requirements for Protective Costings Applied to k'a t e r -C o o l e d i Nuclear Power Plants. Endorses ANSI N101.4-1972. I i i ihe Engineering and Research Depart =ent follows Regulatory l Guide 1.54,

June, 1973 and ANSI N101.4 (1972) exclusive of other documents referenced therein.

One particular of A.NSI i N101.4 (1972) vill be implemented by the Engineering and j Research Depart =ent through alternate equivalent means described b(low: 4 j a. In Para. (5) and (6) PECO vill

initiate, priar to coating application, a

procedure (s) that will ensure i satisfactory pplication and inspect ion of coatings j applied to Nuclear Facilities. N45.2.5-1974dk' Supplementary Quality Assurance' 8. fANSI j, Requirements for Installation, I n s p e c t 1'o n, and Testing cf }R,7yV (- Structural Steel and Structural Concrete. g'? e' s

JN '

ANSI N45.2.5 (1974) exclusive of other documents referenced 7"hq{. therein will be implenented by the Engineering and Research t_' Department through elternate equivalent ceans, prior to placement of any structural steel or concrece at PEAPS Units i 2 and 3. 1 4 1 5 9. Draft Standard f.NSI N45.2.12 (Draft 3, Rev. 4), Requirenents } for Auditing of Quality Assurance Progra=s for Nuclear Power i Plants. 1 1 The Engineeri o and Research Depart:ent follows the guidance of ANSI N45.2.12 (Draft 3, Rev. 4) exclusive of other i docueents referenced therein. l i

• ~e i

l 17.2.B-4 October 1977 2 k r --,.~m..n. =~---,,y,- w-.--,...-..-, ,..-.-n.. m.. ,m., ,ymn,,m nw.,wwy.,..~.nr..,,.n,-rm.n.me,--w,.n.mnam--.

}Tf(A f V \\( il + JAFNPP-FSAR O s G n. .i A M - 1. APP ENDIX D. 2. 2. 0- 1 CCNFORMANCE WITH NRC REGULA'IORY GUIDES 1. Personnel Selection and Training (Regulatory Guide 1.8, March 19 71L The selection and training of personnel to be used at the J.A. Fi tzPatrick Nuclear Power Plant conforms with Regulatory Guide 1.8. 2. Qua. ty Assurance Procram Requirements _JDesion and Construc-tion) (Reculatory Guide 1.28, June 1972) The design and construction of safety related structures, systems, and components resulting from modifications or design changes are subject to quality assurance requirements that comply with the positions defined in R eg ula tory Guide 1.28, which endorces A NSI N45.2-1971, uality Assurance Program Requirements for Nuclear Power Plants". Except th at the systr.ms which were identified during the operating license proceedings and on which the engineering and design work had already been initiated prior 7 i to the issuance of the operating license will be completed in l accordance with the procedures f ollo< ed during the original l design and construction of the J. A. FitzPatrick Nuclear Power Plant.} 3. Quality Assurance Recuirements for Installation,_ Inspection, / and Testing cf Instrumentation and Electric _Equipm1pt l JRegulatory Guide

1. 30,_ Aug ust 1972) l The installation, in sp ect i on, and testing of all IEEE Class IE clectric powe r, instrumenta tion, control equipment and

systems, in clud ing au xilia ry eq uip me nt and associated material, comply I

with the requirencnts of Regulatory Guide 1.30. I 4. Quality Assurance Program Recuirements (Operation) j J_ Regulatory Guide 1.33, Novenber 1972) l l The quality assurance requirements f or the operation of t he J. A. Fit: Patrick Nuclea r Power Pla n t c om ply with Regulatory Guide { 1.33. ) \\ l l 1 D.2.2.0-1-1 11/01/75 l

JAFN PP-F SAR S. Ouality Assurance nequirements for Cleaning of Fluid systems and Associated Comp )nents of Water-Cooled Nuclear Power Pl an t s (Reculatory Guide

1. 37, March 1973)

The quality assurance requirements f or cleaning of fluid systems and associated components comply with Regulatory Guide 1.37, with - g[ the following exceptions: Regulato ry Position C.3 - Saf ety related systems other than the following; 1. Reactor coolant pressure boundary 2. Systems required for reactor shutdown 3. Systems required for emergency core cooling 4. Reactor vessel internals that are relied upon to permit adequate core cooling f or any mode of normal operation or under credible postulated accident conditions are flushed with water in accordance with ANSI N4 5. 2.1-73, except that the quality of water is as close as practical to that of the operating system water. The systems listed comply with NRC Regulatory Position C.3. These are the most critical systems in a plant and must be carefully protected from contamination, especially f or stainless steel systems. For other QA Category I sy stems it is adequate to use wat er defined by ANSI N4 5. 2.1-73, except that the flush water is matched as close as practical to th at intended for system operation. For example, demine ralized water is used for systems that op erat e with de mi n e ra li z ed /d e io n i z e d/ co n den s ed water. It is not necessary to flush such systems with water containing 0.15 ppm chlorides when the 1.0 ppm maximum chlorides required by ANSI would be adequate to prer'nt contamination. 6. Quality Assurance Recuirements for Packagine, S hi pp ine, Rece iv in c, Storace, and Handling of Items for Water-Cooled Nuclear Power Plants (Reculatory Guide 1.38, Maren 1973L The quality assurance requirements for packaging,

shipping,

, receiving, storage and handling comply with Regulatory Guide 1.38 / withe the following exceptions. a. Regulatory Position C. 3

Tapes, dessicants, and dessicant bags do not contain the following as a

basic and essential chemical constituent: lead, zinc, ce p p er, mercury, cadmium and other low melting point

metals, their alleys, and/or compounds.

~~" D.2.2.0-1-2 11/01/75

J AFN PP-FSAR b. As prescribed in ANSI N4 5. 2. 2-19 7 2 maximum levels of water leachable chlorides, total

halogens, and sulfur and their compounds are imposed upon tapes.

c. Dessicants and dessicant bag s contain nonhalog enated and nonsulfur bearing materials. 7. Housekeenino Recuirements for Water-Cooled Nuclear Power / Plants (Reculatory Guide 1.39, March 1973) The housekeeping program complies with Regulatory Guide 1.39. 8( Quality Assurar 7e Recuirements for Protective Coatinos (Eegulatory Guide 1. 54, ([h. Applied to Watcr-Cooled Nuclear Plant / J une 1973) The Quality Assurance recuirements for protective coatings comply with Regulatory Guide 1.54 with the f ollowing exceptions: In lieu of the inspection defined in Section 6.2'.4 of ANSI N 101. 4-19 72, inspection is in accordance with ANSI N5.12-1974 Section 10, Inspection For Shop and Field Work. Regarding the extent of c ov era ge, te f ollowi ng of f ers clarification of paragraph 1.2.4 of ANSI N101.4-72: Regulatory Guide

1. 54 will be a pplied as f ollows:

A. Surfaces within the primary containment liner boundary: a. For large surface area components, the documents shall be retained by the Authority as required by ANSI N101.4-72. Th es e co6ponents include such items as the reactor building

crane, co nta inme nt,

structural steel (including miscellaneous steel and h andrails), concrete, ductwork, uninsulated

pipe, reactor vessel support shield wall, exterior of uninsulated tanks and vessels, and major equipr it supports.

b. For manuf actured equipment such as pumps, notors, pipe hangers and

supports, the doc utae ntation required by ANSI N 101. 4-7 2 sh all be maintained in the Seller's files for the complete duration of the c ont ract warranty / guar antee period.

A certificate of compliance signed by responsible management personnel shall be furnished by the Seller. D.2.2.0-1-3 11/01/75

JAFN PP-FSA R B. Other surfaces where coating f ailure could compromise the design function of equipment of components intended mitigate the consequences of postulated to prevent or accidents which could af fect the public health and safety. B eca us e of the impracticability of imposing the Regulatory Guide requirements on the standard shop process used in painting valve

bodies, handwheels, electrica l cabinetry and control pa nels, loudspeakers, emergency light cases and like components, the Regulatory Guide will not be invoked for these items since the total surface of such items is relatively small when compared to the total surface area for which the requirene nt s will be imposed.

The total surf ace area and estimated volume covered by unknown paint which is not applied in accordance with the requirements of the Regulatory Guide will be re co rd ed. An analysis will have to be con du cted, taking into account the quantity and physical distribution throughout the primary containment of miscellaneous surfaces which will not be coated in accordance with the Regulatory Guide (no such analysis has as yet been undertaken). The analysis, based on the flow paths and the available surf ace area which could be obstructed by n onintegra l

coatings, will verify tha t even in the event that the uncontrolled coatings were removed by a LOCA, the effectiveness of any engineered safety system would not be compromi::ed thereby.

The reference subs ti tution of A NSI N5.12 as the basis for inspection, rather than ANSI N 5. 9 reflects a revision to a standard referenced in the based document, ANSI N101.4. 9. Qualification of Nuclear Power Plant Inspection, Ex ami n a tion, 'jand Testing Personnel (Reg u lato ry Guide 1.58, Auo us t 1973) Qualification of nuclear power plant inspection, examination, and testing personnel couplies with Regulatory Guide 1.58.

10. Quality Assurance Requirements for the D3 sig n o f Nu cl ea r Power Pla nts (Reculatory Guide 1.64, October 1973)

}'~The Quality Assurance requirements for the design or design

gt s change resulting in meification of the J. A.

FitzPa trick Nuclear i-Power Plant comply with Regulatory Guide 1.64. m% D.2.2.0-1-4 11/,01/75

4 JAF N P P-PSA R

11. Quality Assurance Terms and Def initions (Regulatory Guide 1.74, Febru ary 1974)

The J.A. FitzPatrick Nuclear Power Plant Quality Assurance Guide 1.74 is as Program degree of compliance with Regulatory follows: A. The ' Authority uses the appropriate definitions of ANSI N4 5. 2.10- 19'! 4 and supplements these terms wi th others defined in th e Authority's Quality Assurance Program Manual for the James A. Fit 7 Patrick Nuclear Power Plant. G Webster utilizes the Quality Assurance terms and B. Stone definitions described in Appendix III Glossary of SHSCAP 1-74, " Stone Webst er Standa rd Nuclea r Qua lity Assurance Program". This is an acceptabl e alt ernative to Regulatory Guide 1.74.

12. Preoperational and Initial Startup Test Programs for Water-Cooled Power Reactors (Regulat ory Guide 1.68)

Not applicable for our phase of operations. i

• ~e D.2.2.0-1-5 11/01/75

a ,;..s + JAFNPP-FSAR PLANT ADMINISTRATIVE PROCEDURES FIGURE D.2.2.1.2-2 Procedure Appendix B to No. Title _1_0CFR50 Criteria AP-36 Maintenance of Quality Control II, XI Records NOTE Procedures applicable to Criteria IX of Appendix B to 10CFR50 are found in the _ site Welding Handbook and in the Fondestructive Examination Proccdure Ha ndboo) 11/01/76

IN D t M P T. 3 'd n,, p., i; IP3f2PP O'. m (, g. l, J %L\\..s. i APPENDIX 17.2.0-1 CONFORKIdiCE WITH NRC REGULATORY GUIDES .o G fl 1. Personnel Selection and Training (Regulatory Guide 1.8, 7, --- g. The selectica and training of personnel to be used at the 'ndian Point 3 Nuclear Power Plant conforms with Regulatory Guide 1.8. 9 d, 2. Quality Assurance Program Requirements (Design and f) ~ Con s t ruitlen ) (Regulatory Guide.l. 2 8, June l972) The design and construction of safety related structures, systems, and components resulting from modifications or design changes are subject to qual i ty a s <iurance req airc-ments that comply with the positions de fined in Regulatory Guide 1.25, which endorses Irt:SI N45.2-1971, "Ouality I.ssurance Program Requirements for Nucltar Povier Plants". /g' j 3. Quality Assurance Requircments for In s talla t ion, Inspection, ~ - ~ ^~ ~ Instrumentation and Electric Equipment af f ' and' Test 3ng of ( Regulatory GiiT66~1. 30, August 1972) The installation, inspection, c.nd testing of all IEEE Class TE electric power, instrumentation, control equipment and systems, including auxiliary equipment and associated material, comply with the requirements of Regulatory Guide 1.30. , A,, f 4. Quality Assurance Program Requirements (Operation) (( (Rdijiil a tory Gui dF 1 3 3,~Roverl>eF-~l3 7 2) ~ The Quality I.ssurance requirements for the operation of the IP3NPP comply with Regulatory Guide 1.33. 5. Quality Assurance Requirements for Cleaning of Fluid Systems [ ,f" and Associated Components of Wat er-cooled Nuclear Power ,b P 1 "1 t s_,[Regu1atory cuiiie 13 Marefi97 3) i. The Quality Isssurance requirements for cleanir.g of fluid systems and associated components comply with Reg ula tory G_ de 1.37, with the following exceptions: N 3/1/77 17.2-47

IP3NPP l ~ '. - = j' Regulatory Position C3 - Safety related systems other than the following: i 1. Reactor coolant pressure boundary 2. Systems required for reactor shutdown 3. Systems required for emergency core cooling 4. Reactor vessel internals that are relied upon to permit adequate core cooling for any mode.of normal operation or under credible postulated accident conditions are flushed with water in accordance with ANSI N45.2.1-73, except that the quality of water is as close as practical ~ to that of the operating system water. The systems listed comply with NRC Regulatory Position C.3. These are the most critical systems in a plant and must be. carefully protected from contamination, especially for stainless steel systems. For other QA Category I sys tems it is adequate to use water defined by ANSI N45.2.1-73, except that the flush water is matched as close as practical to that intended for system operation. For example, demineralized water is used for systems that operate with demineralized / deionized /condented water. It is not necessary to flush such systems with water d containing 0.15 ppm chlorides when the 1.0 ppm maximum chlorides required by ANSI would be adequate to prevent / l'.* [lS *.l ,/ L contamination. S ] t i 1 ~# l 6. Quality Assu_rance Requirements for Packaging, Shipping,_ 3 Receiving, Storage, and Handling of Items for Water-Cooled Nuclear Power Plants (Regulatory Guide 1. 3 8, March 19 7 3) ] The quality assurance requirements for packaging, shipping, receiving, storage and handling comply with Regulatory Guide 1.38 with the following exceptions,: 1 i j a. Regulatory Position C.3 - Tapes, dessicants, and dessicant bags do not contain the following as a j basic and essential chemical constituent: lead, zinc, copper, mercury, cadmium and other low melting point metals, their alloys, and/or ccmpounds, i b. As prescribed in ANSI N45.2.2-1972 maximum levels of 4 water leachable chlorides, total halogens, and sulfur and their compounds are imposed upon tapes. c. Dessicants and dessicant bags contain nonhalogenated 'and nonsulfur bearing materials. 7. Housekeeping Requirements for Water-Cooled Nuclear Power Plants, / (Regulatory Guide 1.39, March 1973) gpj "f Y A, The hou'sekeeping program complies with Regulatory Guide 1.39. V,,,.n "Y 1 3/1/77 17.2-48 i i _ _ _ _. _ -. _ _ _ _. ~... _ _ _ _ _ _. _ _. _., _..

-.- =._- .= 1 IP3NPP v 8. Quality Assurance Requirements for Protective Coatings Applied to Water-Cooled Nuclear Plant (Regulatory Guide }.54, June 1973) i The Quality Assurance requirements for protective coatings comply with rugulatory Guide 1.54 with the following exceptions: In lieu of the inspection defined in Section 6.2.4 of ANSI N101.4-1972, inspection is in accordance with ANSI N5.12-1974 i Section 10, Inspection For Shop and Field Work, Pegarding the extent'of coverage, the following offers j clarification of paragraph 1.2.4 of ANSI N101.4-72: i Regulatory Guidc 1.54 will be applied as follows: 1 i A. Surfaces within the primary containment liner boundary: I i a. For large surface area components, the documents j sha31 be retained by the Authority as required by j ANSI N101.4-72. These components include such l j items as the reactor buildin g crane, containment, structural' steel (including miscellaneous steel and handrails), concrete, ductwork, uninsulated pipe, i exterior of uninsulated tanks and vessels, and i major equipment supports. I j( b. For manufactured equipment such as pumps, motors, pipe hangers and supports, the documentation j required by ANSI N101.4-72 shall be maintained in j the Seller's files for the complete duration of i the contract warranty / guarantee period. A certi-ficate of compliance signed by responsible manage-ment personnel shall be furnished by the Seller. I. B. Other surfaces where coating failure could compromise the design function of equipnent or components intnnded to prevent or mitigate the concaquences of postulated ] accidents which could affect the public health and safety. 1 Because of the impracticability of imposing the Regulatory Guide. j requirements on the standard shop process used in painting valve i bodies, handwheels, electrical cabinetry and contrcl panels, j loudspeakers, emergency light cases and like components, the Regulatory Guide will not be invoked for these i tems since the i total surface of such items is relatively small when compared 5 to the total surface area for which the requirements will be imposed. The reference substitution of ANSI N5.12 as the basis for ) inspection, rather than ANSI N5.9 reflects a revision to a s tandard referenced in the based document, nNSI N101.4. I d 3/1/77 i 17.2-49 -w.. -n-- e, ,--~v~ 1,+,m ,em-,,w---,-.-+w n- ---,--.w-,.- --w-,-nere-n-, +e--w-,e vno-----~--~-*-v

IP3NPP o. Insnection, Yxamination,0 / 9. Qualification of Nuclear Power Plant ^ {[,,a h v'. and Testing Personnel ( Regulatory GiiTYl. 5 8, August IF73) Qualification of nuclear power plant inspection, examination, and testing personnel complies with Regulatory Guide 1.58. f.. l);et y,F7 10. Quality Assurance Requirements for the Design of Nuclear Power plantTTRegulatory Girde7T6470ctober 157 3) is/ The Quality Assurance requirements for the design or design change resulting in modification of the Indian Point 3 Nuclear Power Plant comply with Regulatory Guide 1.64. 11. Quality Assurance Torms and Definitions (Regulatory Guide 1.74, February r9T4) The Indian Point 3 Nuclear Power Plant Quality Assurance Program degree of compliance with Regulatory Guide 1.74 is as follows: A. The Authority uses the appropriate definitions of ANSI N45.2.10-1973 and supplements there terms with others defined in the Authority's Quality Assurance Program Manual. 12. Preoperational and Initial Startup Test Programs for Water-Coo _ led Pcwer Reactors 7 Regulatory GuTile 1.6~8[ ~~ Not applicable for our phase of operations. 9 j.j 9,/ ts' y,,c r 9 i }& f $?sl i y /. r* f} "] > i l "f s 3/1/77 17.2-50

me I h l\\ L b.~t l L 1bac t n. c Ei i,x i g. .{ (N> 3. A demonstrated interest in his own professional develop- ~ ment as indicated by activities in appropriate technical s c'eties, and/or additional study in the field or asso-ciated fields of his specialty. / / 4. Ability to work we '1. with others. 5. Good oral and'/ writing skills. 6. Initiative and sound judgment to satisface rily complete an undertaking with minor supervision. / 's D.2.2 OUALITY ASSURANCC PROGRAM 43 .s The corporate OA Program has been designed to comply with the requirements of 10CFR50, Appendix B and with {.he Fire Pro-tection Program requirements of Appendix A of Branen Techni-cal Position No. 9.5-1. This program shall be applied to all activities which can affect the health and safer _y of the 2 public. During the pre-operational p,hase, this includes: 3 3 ? l i 1. activities which~ affect the sa fc:ty related functions of i structures, systems and components, and 2. activities which affect fire protection for safety re-lated arcan, SMGS-PSAR D.2-ll Amendment 43 Units 1& 2 M P79 25 01/11

During the operational phase, the OA Program is applied to ( the above activities and to a.;plicable safety-related activi-ties delineated in Appendix A of Regulatory Guide 1.33. Structures, systems and components covered by the OA Program are identified in FSAR Appendix C. 7_ j f The QA Program shall be applied during the pre-operational and operational phases to an extent consistent with the items or activity's importance to safety. 0 Du r i n g t h e oge,r;Qi.o,qa l ppap3, th e s e a c t i v i t i e s s h a l l be pe r - / y 63 / formed in compliance with the applicable quality-related n /h requirements which include, but are not limited to: t 1. Regulatory Guide 1.8, " Personnel Selection and Traning," 9/75, (endorses U18.1). 2. Regulatory Guide 1.30, "Guality Assurance Requirements for the Installation, Inspection, and Testing of Instru-mentation" Electric Equipment, 3/72, (endorses N45.2.4). 3. Regulatory Guide 1.33, " Quality Assurance Program Require-ments (Operation)," 2/78 (endorses N18.7-1976/ANS-3.2). i SNGS-PSAR D.2-12 Amendment 43 Units 14 2 1 P79 25 01/12

4. Regulatory Guide 1.37, " Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components _ of Uater-Cooled Nuclear Power Plants," 3/73, (endorses N45.2.1). n gulatory Guide 1.38, " Quality 7sssurance Requirements 5. c for Packaging, Shipping, Receiving, Storage, and 11andling of Items for Water-Cooled i:oclear Power Plants," 10/76, (endorses N45.2.2). 6. Fegulatory Guide 1.39, "llousekeeping Requ i reraents for Water-cooled Nuclear Powet Plants," 3/73, (endorses N4 5. 2. 3). 43 7. Regulatory Guide 1.58, " Qualification of Nuclear Power Plant Inspection, Examination, and Te ting Personnel," 8/73, (endorses N45.2.6). All PSE6G personnel per-forming Inspection, e.anination or testing shall be qualified in accordance with this Regulatory Guide, with the follouing exceptions: Certification of personnel qualification vill not include an expiration date and will reir.ain in effect for the duration of employraent in the same classification of qualification. Our i rapl c. 'e n-taticn of ANSI standard N45.2.6, paragraph M45.2.6, SNGS-PSAR D.2-13 Amendnent 43 Units 1 & 2 M P79 25 01/13

i j paragraph 2.2.4(5), will be by recording in documents / other than the certificates, the date of certification and the bi-yearly re-evaluation of paragraph 2.2.3. Should the re-evaluation result in a reclassification, a new certificate will be issued. 8. Regulatory Gu de 1.64, " Quality Assurance Requirements i for the Design af Nuclear Power Plants," 10/73, (en-dorses N45.2.ll). 9. Regulatory Guide 1.74, " Quality Assurance Terms and Definitions," 2/74, (endorses N45.2.10). / $?/,i.~~, jf _yh ,,,$,,,, bf S / R,- j g;;f,o,, "f)'{ 43 _; f., u / 10. Regulatory Guide 1.88, " Collection, Storage, and Main-F ? nance of Nuclear Power Plant Quality Assurance Records," 10/76, (endorses N45.2.9). The following is an exception to Regulatory Guide 1.88: Engineering and Construction records are being duplicated via microfilm as an onaning process. h' hen this activity is completed, Salem records will comply with this Regulatory Guide, 11. Regulatory Guide 1."4, " Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants," 4/76 (endorses N45.2.5). SNGS-FSAR D.2-14 Amendment 43 s Units 1& 2 M P79 25 01/14

Major modifications made to the Salem units will comply with Regulatory Guide 1.94. 12. Branch Technical Position 9.5-1, Appendix A, " Guidelines for Fire Protection for Nuclear Plants Docketed Prior to July 1, 1976," 2/77. The Corporate QA Program shall be applied to the Fire Protection Program to an extent consistent with the requirements of Section C of Appendix A to BTP 9.5-1. l The overall QA program is described in the PSC&G Quality Assurance Manual which is prepared and maintained by the 43 4 l l Quality Assurance Department. Generally, the manual consists of: 1. Corp. rate policy statements made by responsible heads of various organizations in PSC&G involved with QA activi-ties. 2. QA Procedures (QAP) which enlarge on the corporate policy statements and are structured according to the 18 Cri-teria of 10CFR50, Appendix B. These procedures are broad in scope and applicable to all PSC&G nuclear generating 1 SNGS-PSAR D.2-15 Amendment 43 Units 1& 2 M P79 25 01/15

m..ceu off \\ . ~ o m.ucf s ps y e POUCT NO' 2 QUAL.iY ASSURANCE PROGRAM POLICY Pl.BE 1 OF 17 Q- 'O QUALIF ASSb J.Ncz FEo3FM. CEYlSIOR 3 CDr.5' m tri F M r DI.. E 22:,1/ h_ s 1.O GF'E01.L The Fresident of Consumers Pcver has issued a "Str. ten.ent cf Authority and Respon-sibility" which ev=its the Conpany to acy ,p and implement e. Q;ality Asrurance Fregan fer Nucleer Fever Plants, in cenplience with IGC Regulatcry Requ'renents r_nd applicable Industr/ Codes and Standrzds. Tne Q ality Arturance Progres is docctnted in the Conruners Tower Concer.y Ra'.lity Assurance P ogre _m M=mual for Nuclecz Ocver F1snts (this docunent). Tne =s.nual defines the Quelity Assurance Fregrsa estat ashed by Censuners ?cver to assure that its nuclear pcwer plants are designed, constructed er.d operated with the controls required to present er nitige.te the consequences of pcstulated acci-dents that cculd crate undue risk to the health e_nd safety of the public. The secpe of the Quality Assrecce Frogrem ccvers design, procr ement, testing, cperations, naistenance, repair, re^celing and nodification acti 4 s associated with safe opers-tion of the plant. Tne Qaality Assure _nce F opzm as - that activitics affecting c.u ality. are accenc. liched bv use of at_ :- cr_i-e er. and under suitable enviren-tental conditions. Tne =ccr:= establishes tue eu..i enents for spec. 1 ecutrels, procccres> test ec_ui m_ents tools and quelified pursonnel. 2.O FASIS DL"G'TS P_. IGC 1005.50, Appendix 3, Criterion 2, Qaality Arsureace Fregrec IEC Eegulatory Guide No 1.8, _ ersonnel Selection a.cd Training (Enderret A'!SI r b. N18.1) IGC Regulate y Guide No 1.28, Qae_lity Assrence Frogrr Requirenents - Design c. and Ccnstracticn (Indcrses A';SI N45.2) IaC Eeculatcry Guide No 1.33, Quality Assr ance Oregrea Eequirerents - C;eration d. 13C Regulatory Guide No 1.58, Qa-ification cf Nuclee Fever Plant Inspection, e. Ext.:-inatica e2d hsting Ferso. (Endorses AI;SI N45.2.6) 130 Eegulatcry Guide No 1.7h, Quality Assrance Terns and Definitiens (Endert es f. ANSI Nh5.2.lo) g. ANSI N18.7 h. ANSI Nb5 2, Criterien 2, Quality Assu ance Progrem i. 'n' ASH 1233, 5/2h/74; WASH 12A,10/26/73; and WASH 1309,5/10/7h e ____w-

e FOUCY NO' 2 A QUALITY ASSURANCE PROGRAM POLICY PAGE 2 0F 17 g "L.' QUALITY Assv?nCE Facc?x4 REYlSION L twemus Pmer DUE 3/1/76 30 ICLICY 31 EtiALIn' ASSU=sCE Pacc n ccMPLIAncz md IEC EIC-ULATCH GUmWCE The Censu=ers Pcr. er Cc pany Qaality Assurance Fregrsa for Nucler.r Power Plants is ec=nitted to the guidance and rec,uirerents contained in NRC Quelity Assurance ?egulatory Guides, and the NRC Grey, Green e,nd C ange Focks, referred to as the Rainbc - Bocks e.nd/cr 'n* ASH Doc" emts (1283, 5/24/7h; 1309, 5/10/74; e_nd 128h,10/26/73, respectively.) L cepticas and or explanatiens follow: Cubsection "a" of Section D-1 in the Grey Ecok requires that, "A schedule of a. ell safety-related nuclear pc aer plant activities to be perforced by each organication alcng with the required prceedres or instructic..s to i-plement the corresponding Q ality Assurr.ce,hegram for the activity should be pre-pared (e_nd periodicelly updated to indicate status) to assure tirely develep-nent, approval e_nd ' plementatien of these 0;;elity Assurance frocedures or instractions pricr to initie. tion of the activity." Consu ers ?cver does net have a schedule relating to timely levelepcent, e.pprcvel and i=plecentation of precedures red instracticns. In lieu cf this schedule, Censumers ?cwer does I require that prccedres er instructions be prepared prior to initiation of sa'ety-related activities (emd revised vLen neciasary) and does verify, during audits, that the precedures have 'ceen prepared and are being implemented, h5.2.10-1973 b. Ccnsu ers ?cuer uses the definiticns of tems provided in A'!SI N for safety-related activities with the folleving exceptiens: Audit is defined as "A doc.nented activity perfo=cd in accordr.ce with written procedres or checklists to veri ^y, by ex= 'natica ecd evaluat'on o of ob'ective evidence, that e.pplicable elecents of a Qaelity Assuranc rogram have been developed, docurented and effectively i plecented in accor6_ ce with srecified recuirements. An audit does not include surveillance or insree-tien for the pa-pose of process centrol er product acceptance." Ccastractic_a F sse is defined as " Activities at the building site necessary to erect and verify proper installatica er.d perfomance of nuclear pcwer plant facilities prior to initial ^cel leading." Nenconfomance is d'efined as "A deficiency in haracteristic, decurentation, or procedure vbi,ch renders the quality cf an item u. acceptable cr indete minate red which is considered significant to quality or safety. L:a o' 4-clude': { s

POW K0. 2 QUALITY ASSURANCE PROGR AM POLICY PAGE 3 Of17 ~ Q, QU/1ITY ASSU?JSCE PEOGRAM REYlSION L %'su./ a C:nsu m FMer DATE 3/1/76 failures, incorrect or inadequate doceenta-Fhysice_1 defects, test tice, deviatica fec prescribed processing, inspecticn, or test precedures." Precrecent Docu entatien is defined as "Purchese Eequisitions (FEs), Purchase Or6 2rs (PCs), Division Purchase Orders (D?Os), Returned !<cteriel E2 quests (??Rs), drawings, contracts, specifications, ead instruc+ ions used to define require:ents for the purchase of rateriels, equip =ent er services." Section 5.6 of ANSI Nb5.2.9 requires that the permanent record stcrate c. fe.cility hr.ve " structure, decrs, freces, and hardveze should be Class. A fire-rated with a recc= ended four-hou minicu rating." In lieu of this, the existing Censuners ?cver perrement record stcrr_ge facility has a two-hcr fire rating. d. Tne rc sining guides ec:d/cr stez. cards telev are listed because the dran revision or reletsed editicn inplczented by Cons =ers Pever Ccapr_ny is later than thct ecntained in the respective W?2i Docurent in which they appeez: Eeculntory Guide 1.6h - Eevisicn 1 (February 1975) Fegulatcry Guide 1.S3 (August 197k) ANSI Nh5.2.9 - 197h Recult.tcry Guide 1.9h ( April 1975) ANSI Nk5.2.5 - 197h A';SI N L 5. c. 8 - 197 5 A';SI NL5.2.12 (Traft L, Revicion 1) ANSI NL5.2.13 (Draft 3, Eevision 3) Censurers Fever Cc pany requires its suppliers to respend to the Grey emd Green 3.c chs (WASH Docu ents 1283 ead 1309) and assi ns responsibility for this cetion to C the Supplier. Alternates or excepticas teken by the Supplier to co ply with er implenent the regulator / Cuidence centained in these documents vill be described and delineated in the Prelininary Cafety Analysis Report. l

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Oc{,m t E Ji v s s ~ EF FS AP. i divided reservoir allows either redundant division of the system to use the entire body of water in the reservoir. The 30-day water supply requirement is thus met even after considering any single failure. In the event of a seismic disturbance and failure which causes the development of a crack, only water stored above grade elevation will be lost. The RHR complex of diesel genera-tors, cooling towers, RHR service water system, and auxiliaries j is redundant. For details, refer to Subsection 9.2.5.2 of this FSAR. REGULATORY GUIDE 1.2h ( f978, Rev. 1), QUALITY ASSURANCE PROGRAM REQUIREMENTS (DESIGN AND CONSTRUCTION) The Fermi 2 Quality Assurance (QA) program complies with ANSI 18 N45.2-1977. J 1 For details on the QA Program refer to Chapter 17 of this FSAR. REGULATORY GUIDE 1.29 (9/1978, Rev. 3), SEISMIC DESIGN 1 CLASSIFICATION i l The Fermi 2 design is in conformance with the requirements of l 12 Regulatory Guide 1.29. Refer to Subsection 3.2.1 of this FSAR for a listing of safety-related structures, systems, and compo-J n'ents that are designed to withstand the ef f ects of a safe shut-down earthquake (SSE). REGULATORY GUIDE 1.30' 8/ '972), QUALITY ASSU"ANCE REQUIREMENTS FOR THE INSTALLATION, INSPECTION, AND TESTING OF INSTRUMENTATION j AND ELECTRIC EQUIPMENT l 4 i The Fermi 2 QA Program is in conformance with this guide. 4 For details refer to Chapter 17 of this FSAR. i l REGULATORY GUIDE 1.31 (4/1978 Rev. 3), CONTROL OF FERRITE CONTENT 12 STAINLESS-ST' EL WELD METAL l gg IN E i j Stainless steel systems and components for Fermi 2 were fabricated by General Electric or Dravo and include the following: 1 I a. Reactor recirculation system b. Control rod drive hydraulic return c. Control rod drive housing to flange I d. RCIC system (suction from condensate storage). A-8 Amendment 18 - December 1978

r-EF - 2'-FS AR REGULATORY GUIDE 1.32 (2/1977, Rev. 2), CRITERIA FOR SAFETY 12 RELATED ELECTRIC POWER SYSTEMS FOR NUCLEAR POWER GENERATING STATIONS The Fermi 2 design conforms to the requirements of Revision 1, this guide, with the exception of complete compliance to Regula-tory Guides 1.75 and 1.93, to which exception is taken. For details refer to Sections 8.2 and 8.3 of this FSAR. REGULATORY GUIDE 1. 33)O.\\L. (2/1978, Rev. 2), QUALITY ASSURANCE PROGRAM g REQUIREMENTS (OPERATION) Fermi 2 will be in conformance with the requirements of Regulatory 12 Guide 1.33, with the exception of full compliance with some regu-latory guides listed in Subsection C.2. The Project's position on regulatory guides in Subsection C.2 is stated elsewhere in this appendix. REGULATORY GUIDE 1.34 (12/1972), CONTROL OF ELECTROSLAG WELD PROPERTIES No electroslag welding for Fermi 2 has been done in the field. Although Edison specifications did not specifically prohibit it, no use of electroslag welding on core support structures or ASME Class 1 or 2 vessels or components can be identified. Most of < (,, those components which would be expected to have electroslag welding were completed and fabricated before this guide was issued. REGULATORY GUIDE 1.35 (1/1976, Rev. 2), INSERVICE SURVEILLANCE OF 12 UNGROUTED TENDONS IN PRESTRESSED CONCRETE CONTAINMENT STRUCTURES This guide does not apply to Fermi 2, which does not utilize con-crete containment. REGULATORY GUIDE 1.36 (2/1973), NONMETALLIC THERMAL INSULATION FOR AUSTENITIC STAINLESS STEEL The Fermi 2 design is in conformance with the requirements of this guide. For further discussion refer to Subsection 5.2.3.3 of this FSAR. JDL REGULATORY GUIDE 1. 37.\\, (3/1973), QUALITY ASSURANCE REQUIREMENTS FOR CLEANING OF FLUID SYSTEMS AND ASSOCIATED COMPONENTS OF WATER-COOLED NUCLEAR POWER PLANTS The Fermi ? project is in conformance with the requirements of 10 CFR Part 50, Appendix B. The plant startup task force is responsible or activities to ensure system cleanliness and flushing with the objective of meeting the intent of ANSI N45.2.1. For details refer to Subsection 17.1.9 and Chapters 13 and 14 of this FSAR. A-ll Amendment 18 - December 1978

F i EF-2-FS AR REGULATORY GUIDE 1.38 (5/1977, Rev. 2), QUALITY ASSURANCE REQUIRE-12 MENTS FOR PACKAGING, SHIPPING, RECEIVING, STORAGE, AND HANDLIWG g'. \\ OF ITEMS FOR WATER-COOLED NUCLEAR POWER PLANTS During the initial design and construction phase, the Fermi 2 project conforms to 10 CFR Part 50, Appendix B, but not with the measures required to comply with this guide. The Fermi 2 project procedure is to require each manufacturer to work by written packaging and 'andling procedures reviewed and approved by Edison and to supply storage instructions which are followed for onsite storage. These measures are similar to the requirements in ANSI N45.2.2=1972. This standard, however, con-tains some specific provisions which a>e c.ot feasible to imple-ment on Fermi 2 because of the date of issue: a. Each specific item covered by the standard (all QA level I items) is required to be classified into one of four levels (A through D). Classification of those items already on order or delivered to the job site is not feasible for the Fermi 2 project b. There are numerous minor requirements which would require significant investigation to ensure compliance, both at the job site and at the vendors' fncilities. These include, but are not necessarily limited to, the. requirement that all tarpaulin be fire-retardant, that i non-metallic caps and plugs be brightly colored, and that all hoisting equipment meet the requirements of either ANSI B30.2.0, B30.5, B30.6, or A10.5, as appro-priate c. Inspection, examination, and testing personnel are required to be qualified in accordance with ANSI 45.2.6. The Fermi 2 position on this is stated in the conformance review of Regulatory Guide 1.58. During the operational phase the QA program will comply with the requirements of this regulatory guide. REGULATORY GUIDE 1.39 (2/1977, Rev. 2), HOUSEKEEPING REQUIREMENTS 12 FOR WATER-COOLED NUCLEAR POWER PLANTS The Fermi 2 project is in conformance with the regulatory position of this guide. Procedures have been written for regulation of site area, site preparation, fire prevention and protection. Further procedures will be written as site activities progress as required by ANSI N45.2.3-1973. y;, 1 A-12 Amendment 18 - December 1978

F EF-2-FSAR REGULATORY GUIDE 1.38 (3/1973), QUALITY ASSURANCE REQUIREMENTS h FOR PACKAGING, SilIPP ING, RECEIVING, STORAGE, AND IIANDLING OF ITEMS FOR WATER-COOLED NUCLEAR POWER PLANTS /l6 During the initial design and construction phase, the Fermi 2 project conforms to 10 CFR Part 50, Appendix B, but not with the measures required to comply with this guide. The Fermi 2 project procedure is to require each manufacturer to work by written packaging and handling procedures reviewed and approved by Edison and to supply storage instructions which are followed for onsite storage. These measures are similar to the requirements in ANSI N45.2.2-1972. This standard, however, con-tains some specific provisions which are not feasible to imple-ment on Fermi 2 because of the date of issue: a. Each specific item covered by the standard (all QA level I items) is required to be classified into one of four levels (A through D). Classifi-cation of those items already on order or delivered to the job site is not feasible for the Fermi 2 project b. There are numerous minor requirements which would require significant investigation to ensure com-pliance, both at the job site and at the vendors' facilities. These include, but are not necessarily limited to, the requirement that all tarpaulin be fire-retardant, that non-metallic caps and plugs be brightly colored, and that all hoisting equipment meet'the requirements of either ANSI B30.2.0, B30.5, B30.6, or A10.5, as appropriate c. Inspection, examination, and testing personnel are required to be qualified in accordance with ANSI 45.2.6. The Fermi 2 position on this is stated in the conformance review of Regulatory Guide 1.58. During the operational phase the QA program will comply with the 6 requirements of this regulatory guide. REGULATORY GUIDE 1.39 (3/1973), IIOUSEKEEPING REQUIRE.'1ENTS FOR WATER-COOLED NUCLEAR POWER PLANTS The Fermi 2 project is in conformance with the regulatory position of this guide. Procedures have been written for regulation of site area, site preparation, fire prevention and protection, h Further procedurcs will be written as site activities progress p as required by ANSI N45.2.3-1973. 4 0 A-9 Amendment 6 - November 1976

r 4 sf EF FS AR REGULATORY GUIDE 1.57 (6/1973), DESIGN LIMITS AND LOADING Cr) COMBINATIONS FOR METAL PRIMARY REACTOR CONTAINMENT SYSTEM COMPONENTS The Fermi 2 containment was purchased, designed, and constructed in accordance with ASME Code Section III, 1968, and is not in conformance with the requirements of this guide, which are based on ASME Code Section III, 1971. Physical changes cannot be made without major construction schedule impact. For details refer to Section 3.8 of this FSAR. REGULATORY GU'DE 1.58 (8/1973), QUALIFICATION OF NUCLEAR POWER PLANT I N S PEC'I. ON, EXAMINATION, AND TESTING PERSONNEL During the initial design and construction phase, the Fermi 2 project is in compliance with 10 CFR Part 50, Appendix B in that personnel performing inspection and testing activities are quali-fied to do so, but there is no commitment to comply with ANSI N45.2.6. During the operational phase, the QA program will comply with requirements of this regulatory guide. REGULATORY GUIDE 1.59 (Rev. 2, 8/1977), DESIGN BASIS FLOODS FOR NUCLEAR POWER PLANTS The analytical methods for assessment of design basis floods at the Fermi 2 site differ in some areas from those presented in 12 Regulatory Guide 1.59, Revision 2. The methods employed for Fermi 2 were reviewed by the NRC staf f, and were determined to be acceptable. (Refer to NUREG-0314, Sections 2.4 and 3.4). REGULATORY GUIDE 1.60 (Rev. 1, 12/1973), DESIGN RESPONSE SPECTRA FOR SEISMIC DESIGN OF NUCLEAR POWER "LANTS The Fermi 2 design is not in cordarmance with the recommendations of this guide. The DBE (now called the SSE) for this plant was defined in 1971; it was reviewed by the AEC/DRL in May 1971, and judged to be reasonable and conservative by the staff and consul-tants. The seismic environment required in Revision 1 by the AEC sets criteria which in some cases are up to 50 percent more con-servative than those used in Fermi 2 design. The following table i shows the comparison of design response spectra. Although the Fermi 2 design is not in conformance with the specific numerical requirements of this guide, the discrepancy between recommended response spectra of Revision 1 and the design of Fermi 2 does not have any significant impact on reactor safety. A-31 Amendment 18 - December 1978

EF-2-FSAR The isolation system does not have a single manual pushbutton that (h.,l actuates all valves closed. A manual switch is available to close each individual valve. The ADS cannot be actuated manually at the system level. Manual 2 j actuation is available at the component level. i Manual initiation of the low pressure coolant injection (LPCI) j system is not available at the system level. However, since a low L reactor pressure interlock prevents the premature opening of the injection valves from eithdT manual or automatic initiation, I actuation at the component level is considered to be adequate. f The core spray system cannot be actuated by a single manual switch. Manual switches are available in the main control room to actuate 2 the individual system components. The high pressure coolant injection (H PCI) system cannot be actu-I ated by a single manual switch. Manual switches are available in the main control room to actuate the individual components j of the system. REGULATORY GU1DE 1.63 (10/1977, Rev. 2), ELECTRIC PENETRATION ASSEMBLIES IN CONTAINMENT STRUCTURES FOR TIGHT-WATER-COOLED REACTORS 18 I{ i 1 The guidelinos presented in Regulatory Guide 1.63, Revision 2, ^ apply to nuclear power plants for which construction permit appli-cations were docketed after December 30, 1977. The application j for Fermi 2 was docketed in 1969 and, as such, is exempt from the guidelines of Regulatory Guide 1.63. However, the Fermi 2 l design complies with the intent of Regulatory Guide 1.63 (10/73, j Rev. 0). For details refer to Subsections 6.2.1.2.1.5, 6.2.1.4.1.1, j and 8.3.1.3 of this FSAR. REGULATORY GUIDE 1.64 (6/1976, Rev. 2) QUALITY ASSURANCE REQUIRE-MENTS OF THE DESIGN OF NUCLEAR POWER PLANTS ) The NRC regulatory staff has accepted ANSI Standard N45.2.11-1974, l " Quality Assurance Requirements for the Design of Nuclear Power i Plants," as an acceptable method of complying with the Commission's regulations in regard to Design Control. The initial issue of Regulatory "uide (RG) 1.64, which endorsed a draft version of ANSI N45.2. 1, was published in October, 1973, approximately a j year'after the issuance of the QA Manual. Later revisions of RG 1.64 were published in February, 1975, and June, 1976. Regu-i latory Guide 1.64, Revisioa 1, endorsed the approved ANSI Stand-j ard N45.2.ll-1974, and was applicable to submittals docketed after April 1, 1975. Regulatory Guide 1.64, Revision 2, clarified the 4 i limitations on performance of " independent design verification" by supervisors, and was applicable to submittals docketed after July 15, 1976. h. 1 1 A-35 Amendment 18 - December 1978

r A EF-2-FS AR Review of Fermi 2 electric valve operators considering the cri- ['- teria of IEEE 382-1972 shows that the valve operators are in com-pliance with the requirements stated in Position 1 of the guide. Valve operators within containment are provided with NEMA Class H j insulation. Such insulation ensures that all primary and auxiliary electrical equipment, conduits, connections and penetrations asso-ciated with each valve operator are of watertight construction which will maintain electrical source availability. In addition, the insulation as well as the operators are seismic, radiation and temperature qualified to withstand containment normal operating conditions and the design basis accident conditions. The test sequence given in IEEE 382-1972 ie more conservative than actual operating conditions. Therefore, in compliance with Position 2, Section 4.5.2 of the standard was applied in the test-analysis ^? of the operators. These tests included periodic actuating condi-tions at 340*F E'. cam atmosphere, chemical exposure to lorated 8 rads. These conditions water, and radiation testing to 2.0 x 10 simulate the most severe DBA and are thus as conservative as Position 3 of this guide. 'g REGULATORY GUIDE 1.74 (2/1974), QUALITY ISSURANCE TERMS AND w DEFINITIONS In order to ensure that Fermi 2 has been designed and built in accordance with the commitments made in (1) the Final Safety Analysis Report, (2) a planned and systematic program of' Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, and (3) 10 CFR Part 50, a documented lexicon of terms at:d 3 definitions which describes and characterizes the operating func-tions of plant structures, systems and components which is univce-sal and conforming to common industrial usage must be devised. In order to comply with the intent of the recommendations of Regula' tory Guide 1.74 and 10 CFR Part 50, ANSI N45.2.10 was adopted by the Fermi 2 project. This standard of word usage was applied to project contracts, letters of intent, work orders, purchase orders or proposals and legal authorizations. The recently updated docu-ment ANSI N45.2.10-1973 recommended by this guide and the Fermi 2 adopted ANST N45.2.10 differ insignificantly. Fermi 2 wo;d usage thus conforms generally with QA definitions contained in ANSI N45.2.10. Any changes in usage at this late date within the on-going project would be detrimental to the continuity of project documentation and personnel communication. Therefore, the changes in the updated revision of ANSI N45.2.10 have not been incorporated into Fermi 2 project documents. REGULATORY GUIDE 1.75 (1/1975, Rev. 1), PilYSICAL INDEPENDENCE OF ELECTRICAL SYSTEMS The Fermi 2 plant is not in full compliance with Regulatory Guide 1.75. This guide was issued after the design criteria of Fermi 2 were formulated. Revision 1 of this guido requirer application of IEEE Standard 384-1974, "IEEE Trial Use Standard Criteria for 1 Separation of Class IE Equipment and Circuits." This standard (,d classifies associated circuits as non-Class IE circuits which L A-18 Amendment 1 - November 1975

EF-2-FS AR REGULATORY GUIDE 1.86 (6/1974), TERMINATION OF OPERATING LICENSES (> FOR NUCLEAR REACTORS This guide is not presently applicable to the Fermi 2 project. At the time of decommissioning and dismantlement of the Fermi 2 plant, Edison intends to follow procedures in compliance with this guide. REGULATORY GUIDE 1.87 (6/1974), CONSTRUCTION CRITERIA FOR CLASS 1 COMPONENTS IN ELEVATED TEMPERATURE REACTORS -(SUPPLEMENT TO ASME SECTION III CODE CASES F592, 1593, 1594, 1595 and 1596) This guide is not applicable to the Fermi 2 BWR. F"GULATORY GUIDE.1.88 (8/1974), COLLECTION, STORAGE, AND .AINTENANCE OF NUCLEAR POWER PLANT QUALITY ASSURANCE RECORDS Appendix B, " Quality Assurance Records," Criterion 17 o* 10 CFR Part 50, Licensing of Production and Utilization Facilities, requires nuclear power plants to define record retention standards and responsibilities. This criterion, " Quality Assutance Criteria 3 for Nuclear Power Plants and Fuel Reprocessing Plants," requires suf ficient records consisting of operating logs, review, audits, test and inspection results along with material analyses and work j performance data. As a guide for licensees, the NRC regulatory staff has accepted ANSI N45.2.9-1974, " Requirement for Collection, ,(' Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants," as the standard and format to be used in compliance. s / With the exception of subdivision 1.5, this standard applies to all construction permit applicants for whom a Safety Evaluation Report (SER) has been issued.after September 1, 1974. Fermi 2 SER was is-sued prior to this date (9/72). For this reason, the Fermi 2 Qual-ity Assurance record system during initial design and construction does not comply wiih Regulatory Guide 1.88. Reformation of cur-6 rent records at this date in project schedule would be disruptive to the project record system. During the operational phase, the records management operation will be conducted in compliance with the requirements of ANSI N45.2.9. REGULATGRY GUIDE 1.89 (11/1974), QUALIFICATION OF CLASS IE EQUI PMENT FOR NUCLEAR POWER PLANTS Regulatcry Guide 1.89 requires the use of IEEC Standard 323-1974, "IEEE Standard for Qua1ifying C1 ass IE Equipment for Nuclear Power Generating Stations," procedures for the qualifying of Class IE equipment and interfaces in light-water-cooled nuclea r plants. Position 1 of Regulatory Guide 1.89 cites Sections 2. 6. 3. 2. (5) of IEEE Standard 323-1974 and 6.3.5 of IEEE Standard 344-1971, " Guide for Seismic Qualification of Class I Electric Equipment for Nuclear Power Generating Stations," for specific application, Position 2 defines the radiological source term for BWR's and PWR's stated in Regulatory Guide 1.7 for use in radiation testing under Q' IEEE Standard 344-1974. A-18d Amendment 6 - November 1976

Y j EF-2-FSAR Regulatory Guide Fermi 2 Project i Level of Degradation 1.93 Position Position

4. The available onsite Power operation should not If both onsite sources are

- 7 j ac power sources are exceed 2 hours. If one lost, Fermi 2 would be shut j two less than the tro. source is restored within down. However, if one 2 hours, operation may source were returned, continue for 72 hours. Fermi 2 would continue to opera'e, as long as that i source was verified regular 1v. l S. The available onsite Power operation may con-Fermi 2 would comply with I de supplies are one tinue for a period not to this position. The pos-less than 140 exceed 2 hours. If de sibility of this occurring I power is restored unre-considering the Fermi 2 dc i stricted, operation may system design is extremely 5 be resumed. remote. l REGULATORY GUIDE 1.94 (4/1976, Rev. 1), QUALITY ASSURANCE REQUIRE-i MENTS FOR INSTALLATION, INSPECTION, AND TESTING OF STRUCTURAL CONCRETE AND STRUCTURAL STEEL DURING THE CONSTRUCTION PHASE OF NUCLEAR POWER PLANTS 1 j The implementation of Regulatory Guide 1.94 applies to nuclear i power plants submitting applications for construction permits on or after October 15, 1976. The applicaticn for Fermi 2 was dock-j eted in 1969. The necessary tests, inspections, records, and data for compliance have not been a strict part of Fermi 2 con-J 5 i struction procedures. For this reason, records are not in strict compliance with ANSI N45.2.5-1974. Various methode of instruction, j 12 testing, reccrding, and material testing have been used during the i fabrication of plant structures. As a result, documentation that ] assures high quality in materials.and workmanship has been retained j by the Project's Quality Assurance group. An outline of these activities as pursued by the Fermi 2 Project is presented in Sec-J [ tion A17.1 of this FSAR. l ] REGULATORY GUIDE 1.95 (1/1977, Rev. 1), PROTECTION OF NUCLEAR j POWER PLANT CONTROL ROOM OPERATURS AGAINST AN ACCIDENTAL CHLORINE )! RELEASE j Under General Design Criterion 4, " Environmental and Missile Design i Bases," of Appendix A to 10 CFR Part 50, safety-related structures, i systems, and components are to be designed to accommodate the ef-fects of, and to be compatible with, environmental conditions of normal operak'on, maintenance, testing, and accidents. General s Design Crit'n ion 19 further requires that the control room be capa-a ble of control of the plant during normal and abnormal conditions. i Regulatory Guide 1.95 specifies requirements for protection against chlorine releases which could possibly contaminate the plant con- ] trol room. l .1 i l A-48 Amendment 18 - December 1978 i

r ,.o. EF-2-FSAR o orotection. The Fermi 2 FSAR, Appendix 9B, details the positions of compliance to the BTP. ( ACU REGULATORY GUIDE 1.121 (8/1976), METHODS FOR PLUGGING DEGRADED PWR STEAM GENERATOR TUBES Regulatory Guide 1.121 is not applicable to Fermi 2. REGULATORY GUIDE 1.122 (2/1978, Rev. 1), DEVELOPMENT OF FLOOR DESIGN RESPONSE SPECTRA FOR SEISMIC DESIGN OF FLOOR-SUPPORTED EQUIPMENT OR COMPONENTS 18 Regulatory Guide 1.122 is required only for construction permit applicants under review. Thus, the Fermi 2 plant is not required to comply. REGULATORY GUIDE 1.123 (7/1977, Rev. 1), QUALITY ASSURANCE REQUIREMENTS FOR CONTROL OF PROCUREMENT OF ITEMS AND SERVICES FOR NUCLEAR POWER PLANTS The NRC regulatory staff has accepted ANSI Standard N45.2.13-1976, " Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Powe2 Plants," as an acceptable method of complying with the Comaassion's regulations in regard to con-trol of procurement. The initial issue of Regulatory Guide 1.123 applied to construction permit and operating license applications docketed after June 15, 1977, and the current revision is appli-12 cable to those docketed after August 1, 1977. The Fermi 2 QA Pro- .i giam for the design and construction phase was established several years before the issuance of either ANSI N45.2.13 or PG 1.123, and is based on the requirements of Appendix B to 10 CFR Part 50. At this stage of the procurement effort, it would not be feasible to make any retroactive changes in the system of Procurement Control. The Fermi 2 QA Program already includes the basic elements set forth in ANSI Standard N45.2.13. Consequently, a change to the system for control of procurement which could affect only the small fraction of the procurement effort still to be done is impractical as any possible benefits would be f ar out-weighed by the cost and schedule impact. During the operational phase of Fermi 2, the procurement control program will be conducted in compliance with Regulatory Guide 1.123. REGULATORY GUIDE 1.124 (1/1978, Rev. 1), SERVICE LIMITS AND LOADING COMBINATIONS FOR CLASS 1 LINEAR-TYPE COMPONENT SUPPORTS 18 The Fermi 2 construction permit was issued prior to January 10, 1978. Therefore, Regulatory Guide 1.124 does not apply. ACU REGULATORY GUIDE 1.125 (3/1977), PHYSICAL MODELS FOR DESIGN AND OPERATION OF HYDRAULIC STRUCTURES AND SYSTEMS FOR NUCLEAR POWER PLANTS _ Regulatory Guide 1.125 does not apply to Fermi 2 as the construction ,.;f permit was docketed prior to November 1977. (2[ l l A-56 Amendment 18 - December 1978

00 1 5c' ( g Q (3 M %d% EMM ~ 8.0 Implementation, WASii-1283, -1284 and -1309 ( The CNS QA Program for Plant Operations will utilize the guidance pro. vided by NRC publications WASll-1283 (5-24-74), WASlf-1284 (10-26-73) and WASil-1309 (5-10-74) (" rainbow" series) except as noted in the " Specific - Exceptions" of this'section. - The existing operational QA Program does not address all of the detailed requirements set forth in the " rainbow books". A detailed review has been made to determine where the CNS QA Program differs from the ANSI Standards cited in the " rainbow books". With respect to the applicability of the " rainbow books" and the associ-ated standards, it is impracticable to apply all of the requirements set forth by these documents to a plant for which important, and (in some respects) irreversible commitments were made 8 to 10 years ago. It is also impracticable to apply require.nents to an operating plant which were intended solely for the design and ccnstruction phase. NPPD does not now envision any major modifications or additions to Cooper Nuclear Sta-tion. In the event that any such construction were undertaken, the Dis-trict would commit to compliance with the applicable portions of the WASil Series ANSI Standards. It is NPPD's intent to apply quality standards to maintenance, repair,, and modification activities which will provide results which are equal' to or better than the original ccustruction. The following sections summarize the scope and applicability of ANSI Stand-ards and describe specific exceptions that will be taken in applying the guidance of these documents to the CNS QA Program. t' 8.1 ANSI N45.2 Quality Assurance Program Requirements for Nuclear Power Plants (a) Scope and Applicability The guidance provided by this standard and tIEe associated Regulatory Guides 1.28 and 1.33 shall be applied to the Operational QA Program to those art Nities affecting the safety-related aspects of the opera-tional phase of CNS. Where codes or standards are referenced, or are incorporated into the standard by reference, which are in conflict with original design couaitments as set forth i.. the SAR, the SAR commitments shall govern Later revisions of applicable codes and standards may be specifically invoked by the design requirements where deemed appropriate, con-sistent with the overall commitment to maintain the plant in an " equal to or better than" original condition. (b) Specific Exceptions guality Assurance Program (Section 2) The QA Drogram describes the measures utilized to comply with the requirements of 10CFR50 Appendix B. The CNS QA Program conforms to this ANSI Standard also, except as noted below.

v n

Revision 8 Date: CD 10 1m D-9-79

, Inspection (Section 11) '( First. Level inspection has been assigned to plant personnel. Con-trary to the cequirement of this standard that such persons shall not report directly to the same immediate supervisor, our program ~ requires only that inspection activities to verify quality of work shall be performed b'y appropriately qualified persons other than those who performed the activlty being inspected. To be considered qualified, persons performing inspection or verification activities shall meet the following requirements:

1) The inspector'iir verifier did not perform or directly supervise the work.

2) The quality of work will be demonstrated by a functional test l

if a pressure boundary has been breached. ~

3) The verifier's qualifications are reviewed and found acceptable

~ l by the QA organization prior to initiating the verification. l 4) Individuals performing verification functions associated with l normal operations of the plant will be qualified to ANSI N18.1- ~ 1971. l 5) Individuals whose.lualifications a re not required to meet those l in ANSI N18.1-1971 and who performs verification activities shall l be qualified to ANSI N45.2.6-1973 except that the QA experience cited for Levels I, II and III shall be interpreted to mean actual experience in carrying out the types of inspection, examination and testing activity being performed. s.,

6) All non-destructive exar. nations (radiography, dye penetrant, magnetic particle, and the like) will be performed by personnel qualified and certified in accordance with SNT-TC-1A.

8.2 ANSI N45.2.1 Cleaning.of Fluid Systems and Associated Components During the Construction Phase of Nuclear Power Plants (a) Scope _and General Applicability The guidance provided by this standard and the associated Rogulatory Guide 1.37 .111 he applied to safety-related maintenance, repair, l and modification activities occurring during the operational phase of Cooper Nuclear Station except as noted below. (b)' Specific Exceptions General Reguirements (Section 2) Cleaning requirements for almost all maintenance, repair and modifi-cation work will be considered as a part of the overall job require-ments. In this respect, detailed cleaning procedures will not gen-erally be prepared as separate documents. Necessary requirements, consist'c61 with the scope of the work, kill be included as a part Revision 8 l Date: FAG t 0 FJ9 D-9-so l l

i of the overall work instructions. System cleanne'ss is controlled I ( at CNS by the following methods:

1) Parts and components are checked for cleanness during receipt inspection and stored in a manner that will ensure adequate levels of cleanness are being maintained.

2) Vork instruction will be reviewed by Quality Control to assure that adequate cleaning and access controls are incorporated into work instruction and associated safty-related activities.

3) Parts and components are inspected for cleanness prior to instal-lation in accordance with CNS maintenance procedures.

8

4) The work area is maintained at a cleanlinc : IcVel app opriate to the maintenance or modification activity being performed.

5) Quality Control inspections before, during and after safety-related maintenance or modification activities address system cleanness.

A

6) Random QA audit and' surveillance of safety-related maintenance or modification activities requires verification of part, com-ponent and system cleanness, g-Criteria for Cleaning (Section 3) f ~

For cleanness classifications where the scope of plant modification U - work is such as to make application of the guidance provided by this standard practicable, the cleanness classifications and requirements thereof chall be evaluated and applied, as appropriate, as a pa'rt of the overall work requirements. Formostmodificationormaintenancework,flowever,involvingonly snall portions or individual components of larger systems, it is not considered practicable to conduct cleanness tests with ASTM E11-70 Series. Appropriate cleanness will be caintained during the work and preoperational flushing will be conducted, consistent with the scope of the work performed and the original design recuirements. Flushing is an additional precaution to insure system cleanness. Controlling the parts and components and the work area has provided.

• CNS with reasonable levels of assurance that system c3.anness will be -aintained.

In addition to the above, the Water Chemistry Depart-ment routinely _ samples and tests for, system cleanliness, corrosion, crud buiM-up etc. 8.3 ANSI N45 2.2 Packaging, Shipping, Receiving, Storage and Handling of Items for Nuclear Power Plants (Durine the Construction Phase) (a) Scope and Applicability The guidance provided by this standard and the associated Regulato:f Guide 1.-38 shall be applied to packaging, shipping, receiving, storage [ and handling activities associated with safety-related items except as noted below. s Revision 8 Date: AUG20 ff/') D-9-81

a .2 (b) Specific Exception

l Our program is. structured to identify safety-related equipment and i

provide for de'signation of packaging, shipping, receiving, storage The 3t and handling requirements for purchased parts and materials. classificaticns of this.tandard cannot be applied directly to indi-Due to vidual spare parts or su: assemblies of the parent equipment. complexity, inrpectability, etc., the packag-difference in volume, ing, shipping, handling and storage requirements of spare parts and subassemblies will necessarily be different from the requ'irements which may be imponed on the entire component or piece of parent equipment. The majority of items purchased for an operating plant consist of components, subassemblies and individual spate parts which could be used in a multitude of different applications. Such items are pur-l The volume and chased to the highest requirement of intended use. characteristics of purchases during the operational phase differ ^ f significantly from those purchases made during the design and con-struction phase, and storage facilities are considerably different. i l Atems that require sp.ecial measures of storage protection will be Items that must identified as a part of the purchasing documents. be stored outdoors (equivalent of Level D) or items that must be, i stored in covere,d but unheated conditions (equivalent of Level C) will be evaluated on af individual case basis. However, it is not considered practicable to preclassify i_ndividual parts by levels as l Shipping and packaging required by Section 2.7 of this standard. requirements for such items will likewise be handled in the purchase f i order documents, as appropriate. (c) Implementation The NPPD procurement procedures for safaty,,related items includes a f checklist to verify that the ANSI N45.2.2 requirements for packing, l shipping, receiving, storage and handling are included in the procure-QA audits and surveillance are performed to verify ment document. that the requirements of N45.2.2 are met exc pt as note f in (b) abcve. ( ANSI N45.2.3 Housekeeping During the Construction Phase of Nuclear Power 8.4 I Plants (a) Scope and General Applicability The guidance provided by this standard and the associated Regulatory 1 Guide 1.39 for control of housekeeping requirements shall be applied to wcnk conditions and other applicable activities which could affect quality 2f important operational aspects of CNS except as noted below. (b) Specific Exceptions General Reauirements (Section 21 The ptant has been divided in zones.for fire protection and security 1 The zone designated for cleanness in the Ahsl Standard l purposes. Rev!sion 8 Date: AUG26 yyF} D-9-82 1

are primarily intended for control or work during construction of the plant. Therefore, the CNS facilities will not be classified by (' the zones designated in the Star.dard general housekeeping rules. Limitations on eating, drinking, and smoking are already provided in existing CNS procedures. Where special cleanness controls, tool and material accountability are required for particular types of work, temporary clean areas will be designated and defined in the procedures for accomplishing the work. Requirements (Section y Fire protection and prevention equipment will be provided as set of t he CNS fire protection forth in accordance with NPPD evaluativ a system as submitted to the NBC on 10/17/76 and 4/6/77. 1 t (c) Implementation Existing maintenance procedures will be reviewed to determine the need for particular cleanness, housekeeping and control provisions. Where indicated, procedures will be revised to incorporate such_ pro-visions, using the guicance of ANSI N45.2.3. Appropriate maintenance procedures will be updated using these guidelines by July 1979. 8.5 ANSI N45.2.4 Installation, Inspection and Testing Requirements for Instru-mentation and Electric Ecuipment During the Construction Phase of Nuclear Power Generating Stations (a) Scope and Applicability ~- f \\. ~ The guidance provided by this standard and the associated Regulatory Guide 1.30 shall be applied to installation, inspection and testing of electrical equipment and systems associated with on-site safety-related modification work occurring during th,e operational phase of CNS except as noted below. Where specific design requirements included in this standard or ref-crenced codes and standards are in conflict with original design requirements set forth in the SAR and other appropriate design docu-ments, the original design requirements shall govern. (b) Specific Exceptions Definitions (Section 1.4) The definition of Class I and Class IE electrical equipment set forth by this standard does not conform to the equipment categories of CNS. Essential electrical items upon which the Operational QA Pro-gram is based are included in the SAR Amendment 39. The scope and applicability of this standard shall necessarily be limited to these^ defined areas. .a \\ j Revision 8 AUG 2 0 tt;) Date: D-9-83

Procedures and Instructions (Section 2.3) ( Appropriate requirements for installation, inspection and tests will be set forth by job specifications and work instructions developed as a part of the modification work package. It is not intended that separate procedures be established which specifically address the a various areas of this standard. However, in the development of the work package, consideration will be given to the areas outlined in Section 2.3, as appropriate. Installation, Verification and Test (Section 4.0, 5.0 and 6.0)_

c The requirements of the installation and the associated inspec-tions, verifications and tests are. included in,the work instruc-tions as appropriate, consistent with the scope of the work' and the importance of quality.

In the development of the' work instruc-tions, consideration will be given to the guidance provided by Section 4.0, 5.0 and 6.0 of this standard, and appropriate require-ments will be incorporated into the instructions. It is not intended that separate procedures be established which specifically. address all of the areas referenced. Applicable Codes, Standards and Guides (Section 9.0 and Appendix B) Application of the guidance provided by the additional codes and standards listed in Appendix B will be considered to the extent that such codes and standards provide useful and practical guidance for the work being performed. Commitment to the guidance of N45.2.4 / shall noc include commitment to the guidance of referenced standards. \\ (See Regulatory Guide 1.30, Safety Guide 30.) 8.6 ANSI N45.2.5 Supplementary Quality Assurance Requirements for Installation, Inspection and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants (a) Scope and Applicability The guidance provided by this standard a,d the associated Regulatory Guide 1.94 shall be applied to activities involving safety-related concrete and structural steel work occurring during the operational phase of Cooper Nuclear Station except as noted below. (b) Specific Exceptions Procedures and Instructions (Section 2.2) Appropriate requirements for installation, inspection and tests will be set forth by job specifications and work instructions developed as a part of the modification work package. It is not intended that separate procedures be established which specifically address the various areas of this standard. However, in the development of the work package, consideration will be given to the areas outlined in Section 2.2, as appropriate. \\ Revision 8 Date: AUGg0 (73 D-9-84

~ Personnel Qualifications (Section 2.4) (, The Operational QA Program includes provisions for ensuring that qualified personnel are assigned to monitor work activities. (Please refer to Section 8.7 of this document.) Calibration and Control (Section 2.5.2) The requirements of control and calibration of measuring and t'est equipment set forth by this standard shall be applied to all measut-ing and test equipment used by NPPD or their agents, test labora-tories and contractors. Such requirements, however, will not be imposed on commercial batch plant facilities. Instrumentation at commercial batch plant facilities will be evaluated by CNS plant management to determine that sufficient accuracy can be obtained 8 and will be verified by an independent QA audit. Qualification Tests (Section 3.2.1) For small quantities of concrete involved in modification work, all concrete must be purchased from commercial concrete batch plants. For small quantities of concrete, it is unreasonable to expect com-mercial facilities to shut down normal operations to provide cer3 tified aggregate, cement, admixtures, fly ash, water, etc. In this respe t, the qualification tests required by Table A for aggregate; cement; admixtures; fly ash and pozzolans; water and ice will not be required. Appropriate evaluations will be made to determine that good quality and generally acceptable materials are used. CNS plant management evaluation, coupled with slump tests, air entrainment tests 0 and concrete cylinder strengths, will provide adequate control and f ( qualification of the concrete. The r:sults of evaluation will be verified by an independent QA audit. Design mixes consistent with, or equivalent to, original requirements will be specified and the results of the cylinder tests will be evalu-ated by CNS plant management based on the ac'ceptance criteria associated 8 with the original design mix requirements and will be verified by an independent QA audit. Protection of Materials (Section 4.2) The inspection requirements of Secti-n 4.2 will not generally be performed, as the small quantities of concrete involved in modifi-cation work will no doubt be mixed using materials already in the-batch plant bins. Control of storage of materials would not be practicable. Measuring, Mixing and Transporting _(Section 4.3) If available, appropriate certifications shall be obtained from the concrete supplier which verify the adequacy of truck mixers per the requirements of ACI-304, ASTM C-94. Where certifications are not avail-able, two concre'te test cylinders representing the first and last one-third of. ruck mixer contents shall be taken for evaluation of the mixer truck, over and above the normal concrete cylinders taken-to evaluate the inplace concrete. The concrete batch plant facility ~ shall b'e-inspected by CNS plant management and the CNS QA staff to~ 8 ( assure that reasonable controls are being exercised with reference to the inspection guidelines set forth by Section 4.3(1) and (2). Revision 8 Date: Att3 2 0 fn3 D-9-85

\\ Preplacement Preparation (Section 4.4) [ Inspection of sils and earthwork will meet the general requiremerts set forth. The extent to which individual inspection requirements are met will depend upon the nature and scope of the work to be per-formed. In-Process Tests on Concrete and Reinforcing Steel (Section 4.8) Except for normal batch qualification tests (slump, air content, temperature and compressive strength) and initial reinforcing steel certifications, the in process tests required by Table B are gener-ally applicable to the periodic control which must be exercised with reference to long-term construction type programs. The in process test requirements of Table B are not ccasidered applicable to short-term modification work as would be required by QA at CNS. (c) Implementation Where the need arises, measures will be implemented to meet this standard with the exceptions ncted above. 8.7 ANSI N45.2.6 Qualification of Inspection, Examination and Testing Personnel for the Construction Phase of Nuclear Power Plants (a) Scope and Applicability The guidance provided by this standard and the associated Regulatory Guide 1.58 shall be applied to inspection, examination and testing activities associated with safety-related operations, including main-tenance, repair and modification except as noted below. (b) Specific Exceptions It has always been the belief of CNS and NPPD that, in order to be effective, quality control must be built into the operation of the plant. With this in mind, CNS incorporated quality control inspec-tion and test functions directly into the station operating pro-cedures. Inspection points are then witnessed and signed-off by members of the operating staff not directly involved in the acti-vity being inspected. Assignment of QC inspectors is a function of station management. The majority of the QC inspections are assigned to engineers, licensed reactor operators or lead technicians. This method for selecting and asigning inspectors has assured station management that the best qualified individual (either through edu-cation or years of experience) is assigned to monitor " essential" or safety-related activities. Inspectors will meet the requirements listed in paragraph 8.1 (of this amendment) under the part titled " Inspection". Revision 8 Date: AUG 2 0 Egg D-9-86

P~ ~ 9 ~ The method endorsed by ANSI N45.2.6 places emphasis on certifying individuals and establishing 1cvels of qualification. It is our 7, contentic: that even though an individual is certified and qualified to the appropriate level, he may not be the best inspector in all situations. The current method of selecting and assigning QC inspectors at CNS has proven to be very effective. We therefore take exception to Sections 2.0 and 3.0 of ANSI N45.2.6. If future operation indicates that our present system is inadequate, the Station Operating Review Committee will reevaluate the QC system and commit to ANSI N45.2.6 or provide an acceptable alternate. CNS does not have the in-house capability to perform nondestructive examinations in accordance with SNT-TC-1A. These services are cur-rently contracted to an approved vendor. Any required nondestruc-tive examinations will be performed by personnel who are qualified ~ and certified per SNT-TC-1A. 8.8 ANSI N45.2.8 Supplementary Quality Assurance Requirements for Installation, Inspection and Testing of Mechanical Equipment and Systems for the Construc-tion Phase of Nuclear Power Plants (a) Scope and Applicability The guidance provided by this standard shall be applied to installa-tion, inspection'and testing of mechanical equipmant and systems associated with on-site safety-related modification work occurring 7 g. during the operational phase of CNS. Where specific design requirements included in this standard or referenced codes and standards are in conflict with original design requirements set fotth in the SAR and other appropriate design docu-ments, the original design requirements shail govern. 8.9 ANSI N45.2.9 Requirements for Collection, Storage and Maintenance of Quality Assurance Records for Nuclear Power Plants (a) Scope and Applicability The guidance provided by this standard and the associated Regulatory Guide 1.88 shall be applied to quality assurance records associated with the operational phase of CNS. For those design, manufacturing, construction and operating records generated prior to implementation of this standard, it is not our intent to backfit the detailed requirements of this standard to those records. All such records, however, have been initially designated for lifetime storage, until specific review dictates otherwise, and will be stored in the permanent record storage facility. Appropriate record indexes and filing system shall be established to permit reasonable identification and retrieval. The records will be stored and prese_rved per the requirements of S_ection 5.0 of this standard. Revision 8 ~ Date: kl.13 ?. 0 E79 l 1 D-9-87 1

8.10 ANSI N45.2.10 Quality Assurance Terms and Definitions .[- (a) Scope and Applicability - 5,, The quality assurance terms and definitions contained in this standard shall be used as guidance and applied as appropriate to the Operational. QA Program for CNS. The use af this standard and the associated Regulatory Guide 1.74 shall be effective immediately. There may be instances where exist-ing procedures contain definitions that may not be in strict accord-ance with those provided by this standard. As existing procedures are revised, however', such definitions shall be evaluated,to deter-mine if all definitions meet those provided by this standard. 8.11 ANSI N45.2.11 Qual [ty Assurance Requirements for Design of Nuclear Power Plants (a) Scope and Applicability 1 The guidance provided by this standard and the associated Regula!ory Guide 1.64 shall be applied to design activities involving safety-related modification work and the revision or development of plant design documents occurring during the operational phase of CNS. Where codes, standards or design requirements are referenced, or are incorporated into the standard by reference, which are in con-flict with original design commitments as set forth in the SAR, the j ({; - SAR conoitments shall govern. Later revisions of applicable codes cr' and standards may be specifically invoked by the design require-ments where deemed appropriate, consistent with the overall commit-ment to maintain the plant in an " equal to or better than" original condition. ^ 8.12 ' ANSI N45.2.12 - 1974 Requirements for Auditing of Q'uality Assurance Pro-grams for Nuclear Plants (a) Scope and Applicability Except as expressly modified below, the guidance provided by this standard shall be applied to the audit program identified by the 1 Operational QA Program for CNS. Program to be audited at least once every year and cocplies with the guidance provided in Regulator Guide 1.33. (b) Specific Exceptions Follow-up (4.5.1)_ c. The audited organization is required by existing procedures to respond in writing to deficiencies noted in the audit report. A minimum response-time is not specified because corrective action varies depend-( \\ Revision 8 Date: AUG

• 0 i479 D-9-88

r ing on the nature and extent of the deficiency. However, corrective (' 'ction is subject to follow-up audits and reports to higher manage-ent within eight (8) weeks of issuance of the original audit report. s 8.13 ANSI N45.2.13 - Quality Ass _tfrance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants (a) Scope and Applicability The guidance provided by this standard shall be applied to the pro-curement of safety-related parts, components, materials and services during the oparational phase of CNS. (b) Specific Exceytions It must be recognized, however, that equipment and components pur-chased during the design and constuction phase weie not purchased on the basis of present-day standards, especially with reference to vendor qualification and vendor quality assurance programs. In this respect, replacecent parts and spare parts for existing equipment are often limited to sole-source suppliers. Such replacement parts or spare parts are purchased to appropriate quality standards to maintain an " equal to or better than" condition but it is not con-sidered practicable to backfit the requirements of the standards to all such vendors. 8.14 ANSI N18.1 - 1971 Selection and Training of Nuclear Power Plant Personnel .e 1( (a) Scope and Applicability The guidance provided by this standard shall be applied to the selec-tion and training of personnel at CNS. 8.15 ANSI N18.7 - 1972 Administrative Controls and Quai'ity Assurance for the Operational Phase of Nuclear Power Plants (a) Scope and Applicability, The operational QA Program for CNS onforms to the guidance provided by this standard and the associated Regulatory Guide 1.33 excepted as noted below. (b) Specific Exceptions Where ANSI N18/7 - 1972 parallels the requirements of ANSI N45.2 through ANSI N45.2.13, exceptions taken shall be applicable to this standard as well. 1-4 Revision 8 "t"~ E0000 nia D-9-89

'[ ' e h\\o RM ~ Operational Quality Assurance Flan y w Q d.5kAw Rev:,2-7 L 'li,3 i 1.0 Policy Statement dCG Northern States Power Company (NSP) he5 established and is impicmenting an Operational Quality Assurance Program. This quality assurarsre program is applicabic to NSP nucicar plants that are reguinted under provisions of an NRC Operating License. "Ite quality assurance program, as applied to activities affecting safety related functions, shall comply with and be responsive to applicable regulatory requirements and app 1! cable industry codes and standards including: 1 1. 10CFR$0, Appendix B " Quality Asserance Criteria for Nucicar Power Plar.cs and Fuel Reprocessing Plants". 2. NRC Operating Licenses. 3. '1he ASME Boiler and Pressure Vessel Code, Section XI, " Inservice Inspection". The Operational Quality Assurance Program shall incorporate: (1) the requirements of ANSI N18.7-1976 as modified by Table 1-1 and (2) the requirements ofsthe following standards to the extent specified by (ANSIN18.7-1976, as modified by the Regulatory Position of the Regulatory or Safety _ Guides referenced below. 1. ANSI N18.1-1971 /

1).,T [

(Regulatory.Cuide 1.8 Re : 2. ANSI N45.2-1971 ' ./ 3. ANSI N45.2.1-1973 /, (Regulatory Guide 1.37, 3-16-73). ' 4. ANSI N45.2.2-1972 / (Regulatory Guide 1.38, Rev: 2 ).l-5. ANSI N45.2.3-1973 ~ /. (Regulatory Guide 1.39, Rev: 1). l/#/ O' 6. ANSI N45.2.4-1972 ( (Safety Guide 30 August 11, 1972). 7. ANSI N45.2.5-1974 / (Regulatory Guide 1.94, Rev:1). k h l 8. ANSI N45.2.6-1973 (Regulatory Guide ly8, August, 1973). ANSI N45.2.8-1975-i s 1 of 74 j

Operationci Quality Accurance Plan Rev: 2 + ~ Table 1-1 Exception to ANSI N 18.7 "- 1976 1. Section 5.2.13.2 last paragraph; change " quality" to " quantity." This u-change corrects an error in the standard. 2 Section 6; delete this section. The referenced documents are explicitly g,- referenced in the Operational Quality Assurance Plan. 3. Documtatation required by ANSI 18.7-1976 may be deferred for emergency work. Emergency w~ik is defiusd as that work that must be completed immediately and which, if delayed, may resnit in an unsafe condition or significantly interfere with reliable pinut operation. 4. Section 5.2.2; replace the 3rd sentence with the following - " Procedure changes shall be revicwed and approved as required by the Technical Specification." Delete the 4th sentence. 5. Section 5.2.5; replace the 2nd and 3rd sentences with " Temporary procedures shall be reviewed and approved as required by the Technical k' Specifications." 6. Section 5.2.9; delete this section. The Plant Security Plans contain k/ appropriate security provisions. 4 7. Section 5.2.11,1st sentence; change " abnormal. occurrences" to "repor, tabic p-occurrences." 8. Section 5.2.13.2, 4th paragraph; change the 1st sentence to read "..... installation or use of such items that serve a safety function." 9. The provisions of Section 5.2.15 of ANSI N18.7-1976 shall govern review, approval, and control of required procedures except that for procedures required by the Plant Technical Specifications, the review and approval requirements stipulated in such Technical Specifications shall be utilized rather than those contained in Section 5.2.15. 10. Section 5.3; change the last sentence to read " Procedures shall be prepared,- and approved prior to impicmentation as required by 5.2.15." 11. Exceptions to Regulatory Guides and ANSI Standarus for those principal .) contractors, retained by NSP, such as NSSS contractors and A/E Firms, ) which exceptions have been approved by the NRC. 3 of 74

Operctional Quality Assurance Plan Rev: 2 1(t h s v 10 ANSI N45.2.9-1974 (Regulatory Guide.l.88, Rev: 2) excep hat radiographs shall not beJz/ retained due to their non-permanenJItcture; records which document -7 the acceptability (Radiographic Review Forms) shall be retained as h,$,esdbJG4 .d stipulated in the Standard, QdG 0h

11. ANSI N45.2.10-1973 c

(Regulatory Guide 1.74, February, 1974). P'^* ,? Nho,M LA 12 ANSI N45.2.11-1974 2).g(3 (Regulatory Guide 1.64 Rev: I t/ ANS1 N45.2.12 (NDraft 4, Revision 2, Jan 1,1976) as modified by / 13. ( ANSI N18.7-1976./ ., ~

14. ANSI N45.2.13-1976

15. ANSI N101.4-1972 (Regulatory Guide 1.54, June, 1973).

Management directives and departmental instructions and procedures shall provide for compliance with appropriate regulatory, statutory, license and industry requirements. Specific quality assurance requirements and organizational responsibilities for implementation of these requirements shall be specified in implementing directives and instructions. Compliance with this policy.and the provisions of the Operational Quality ,\\ Assurance Program is msndatory for NSP personnel with respect to nucicar plant operational activities or activities which support nucicar plant operation. Personnel shall therefore, be familiar with the requirements and responsibilities of the program that are applicable to their indiv-idual activities and interfaces. The Executive Vice President, through an independent organization, shall periodically have the Operational Quality Assurance Program reviewed to assure its adequacy. 9 [ t I 2 of 74

~~ fe ; p/ T~ ' U CH-C H ~ ~ (WI ScoWW ' ELECTO c twe t}> ~ TABLE H.0-1 . [ COMMITEENT TO REGULATORY GUIDES t AtlD ANSI STA!!DARDS i

1. -Regulatory Guide 1.8 (Safety Guide _8) datcd !iarch 10, 1971 d

J f. i O I, Full conenitment except that Point Beach commits to ANSI N18.1- \\ ' 1971 in lieu of the proposed ANSI til8.1 dated June 22, 1970. 2. Regulatory Guide 1.28 (safety Guide 28) dated June 7,1972 3 ch. ANSI til8.7-1976 states in part, "This standard fully and completely j ( i describes the general requirements and guidelines of...[ ANSI] !!45.2-1971 ~ 4 I as those requirements, and guidelines apply during the operational } phase of plant life." As such, commitment to ANSI N18.7-1976 for Po'nt Beach obviates the need to conmit to Regulatory Guide 1.28 which endorses ) ANSI N45.2-1971. i Point B'esch does, however, commit to the p;sition of Regulatory j Guide 1.28 to the extent of requiring its vendors to have quality i j assurance programs which meet the appropriate requirements of ANSI R45.2-1971 i as mentioned in Section 5.2.13.1 of ANSI N18.7-1976. 3. Regulatory Guide 1.30 (Safety Guide 30) dated August 11, 1972 j i o@ Coninitment to follow the position of Regulatory Guide 1.30, which endorses and supplements ANSI M45.2.4-1972, for activities occurring ij. during the operational phase that are comparable in nature and extent' i 4 to related activities during construction. 4. Regulatory Guide 1.37 dated March 16, 1973 Ok Commitment to follow the position of Regulatory Guide 1.37, which t-l er.dorses and supplements ANSI N45.2.1-1973, for activities occurring during the operational phase that are co parable in nature and extent to i l related activities occurring during construction. ( i June 30, 1977 - Page.l of 3 l _, _ _. _ _, _ _ _ _ _ ' _ _ _ _., _

2 5. Iiegulatory Guide 1.38, Revision 1, dated October 1976 ( Commitment to follow the position of Regulatory Guide 1.38, which endorses -and supplements AllSI li45.2.2-1972, for activi. ties tccurring during the operational phase that are comparable in nature and extent to related activities occurring during construction. 6. Regulatcry Guide 1.39, Pevision 1, dated October 1976 Commitment to follow the position of Regulatory Guide 1.39, which ( endorses act supplements MiSI IM5.2.3-1973, for activities occur ing r during the operational phase that are comparable in nature and extent to related activities occurring during construction except that Point Beach does not commit to the documentation requirements of AliSI IM5.2.3-1973 and provides en alternative to the housekeeping zone requirements therein. - Description of these differonces are provided in Section 2.4 of this Aprendix. {.. 7. Regulatory Guide 1.54 dated June 1973 Comraitment to follow the position of Regulatory Guide 1.54, which l t Dk endorses and supplements AliSI i!101.4-1972, for activitie.s occurring during the operational phase that are comparable in nature end extent to related activities occurring during construction. 8. Regulatory Guide 1.58 dated August 1973 Commitment to follow the position of Regulatory Guide 1.58, which Ob endmes and supplements AliSI IM5.2.6-1973, for activities occurring in the opera anal phase that are comparable in nature and extent to related activities during construction, except that Point Beach does not commit to the levels of qualification nor separate certification requirements of AliSI !!45.2.6-1973. Description of these Jifferences are provided in Section 10.6 of this Appendix. f Page 2 of 3 June 30,1977

9. Regulatoq Guide 1.64 dated October 1973 a [ Commitment to follow the position of Regulatory Guide 1.64, except that Point' Beach cormits to A!!SI 1145.2.11-1974 in lieu of Draft 3, Rev.1 dated July 1973, for design activities associated with modification of safety-related structures, systems and components. 10. Regulatory Guide 1.74 dated February 1974 Db Full commitment. 11. Regulatory Guide 1.88, Revision 1, dated December 1975 Commitment to follod the position of Regulatory Guide 1.88, which endorses and supplements Ai!SI 1145.2.9-1974 andliFPA 232-1970, xcept that Point Beach does not commit to all details of constructi6n of a. records storage facility in f!FPA 232-1970. Point Beach has determined that the existing records storcge facility provides a level of protection to the vital records at the Plant which is equivalent to the requirements of Regulatory Guide 1.85. Description of the differences are provided in Section 17.5 of this Appendix. 12. Regulatory Guide 1.94 dated April 1976 Commitment to follow the position of Regulatory Guide 1.94, which endorses and supplements A!!SI l'45.2.5-1974, for activities occurring during the operational phase that are comparable in nature and extent to related activities occurring during construction. 13. AfiSI 18.7-1976 ~ O$ P.efer to Section 0 of this Appendix for details of the Point Beach commitment. - -ir l J. Page 3 of 3 June 30, 1977

l d

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)

1,'vi d C L 3J (,J u c J G.N L t AP?ENDIX A ANSI NlS.7-1976 EXCE?TIONS. INTERPRETATIONS. QUALIFICATIONS l GENERAI. We have adopted ASSI N18.7-1976, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear ?cuer Plants", to provide a basis for establishing an operational quality assurance prograa that neets the requirerents of 10CFR50 Appendix 3. We fcel that the standard provides an acceptable teans to satisfy the c ritaria of 10CFR50 Appendix 3, but does not limit the use of alternate reans to ensure saf e operation of the plant. In this regard, we have attempted to lisc below those portions of this y i19 standard to which we list exceptions, interpretations and/or qualifications. n a.

}j< %.

i Standards in general present objectires to be cet with the tethod of i:plecentation left general enough to provide for various interpretations for inp1 centation. In the review of our program in accordance with the adoption of these new standards, many changes in i placentation have been cade. Where questions of interpretation were raised a c;nscientious interpretation has bee 2 ff. Wherever future questions of interpretation formalired with the QA sta.I arise they will be decided' in a similar canner with continued disagreenent i being brought before corpo' rate canagerent for resolution. I p fil0 n Q.r.nU 5 ? When a short tern or one tire contradiction to"the program is discovered, a non-confornance action will be taken within the QA organiration to ensure q a conscientious effort to =aintain a quality level equivalent to the safety significance of the activity involved. When a long tern or permanent contradierion to the program exists, a prograa change shall be 1:plorented t [? previding the same level of review as the adoptica of this program, and the l' ~ change will be subeitted to the NRC. Finally, wheravar Technical Sperifications overlap or contend with_ tha a dzini s t ra t i.ve controls provided for in this program, the Technical Specifications will take precedent..,,

/ A ANS1 N45.2.9-1974 Section \\ /. ) -s /? 4.3 & 4.4 Concerning Receipt Control. b J' Our plant QA/QC staf f c.as been designated as the group responsible g.;). is for receiving and storing records. This staff does not control .. h i.ch_ r~e c o_r.d_s_._a r e s e n t___t. o.-._t h em, howe v e r, there is a#-record index w systera identifying which records are under the control of the QA - ~.- Prograe.dWe have assigned responsibility for asiurini QA records 2 m ( -~-- ~~.. __,. -.~.... __ _. _,_ heads. A * '.o, 'are retained in the QA Vault to tha various depart =ent I y,, /,' . - - ~.. -........... there is no log of incoming records. ' However, the previously t/_4 f O' centioned index is kept up to date and serves as a list of records received and reta ned. 'We have a procedure which partially ccvers the ret.eipt control of records but none specifically for this. action. /j We do not plan at this tire to inple ent any further controls on the receipt of records. - */ 5.6 Conce rning Fe rranen t and Tecporary Storage Facilities. We meet the criteria ~ specified in this paragraph for those records stored in the QA Vault, however, we dif fer in our use of te porary storage facilities, the definition of a vorking QA docu:ent and the trcusport of QA records to the vault. Several in-house gen-irated QA decu=ents/ records are maintained in working files, e.g., NERAC Meeting Minutes, training records and radiological su rvey data. These docurents/ records which we feel are working docunents until no longer used en a routine basis are kept in locked, fire-proof file cabinets and are at sone later date transferred to. the QA Vault. Duplication or filing in the vault wotid be unacceptable due to the quantity and frecuent use of these documents. We find our handling of these doct=ents acceptable due to the relative short duratira of filing in temporary quarters and relative ' ns.sitivity of these docusents to the. safety of the plant. i Finally, we do not have a courier set vice to icediately transfer a QA record just co-pleted to the vault. Sore records are trcn2ferred by personnel delivery and others through the reuting in-ccrpany mail s e rvice. 't this t'me se do net plan to inplement any f urther centrols on transf ering decuments to the (A Vault. Al'KA A) M S ~~' L 2 fAH9f S 82gf N@Lif e' P Regulatorv Guide / ANSI Std._ Reference Requirement Interpretation / Alternate /Excepticn General Certain Regulatory Guides The AP&L commitment refers to the invoke or imply Regulatory Regulatory Guides and ANSI Standards, Guides and standards in specifically identified in this addition to the standard TOPICAL. Additional Regulatory each primarily endorses. Guides, ANSI Standa rds, Guides and similar documents implied or referenced in those specifically identified in this ident.i fied in this TOPICAL are not part of this C omm i t Df:n t. Certain ANS1 Standards invoke or imply additional standards. General Certain ANSI Standards and/or Our cot.mitment to those standards Regulatory Guides extend the applies only to those systems, scope of applicability to structures, and components whose include systems, structures, satisfactory performance is re-and components wose satis-quired to prevent post : lated ac-factory performance is re-cidents that could cause undue quired for a plant to operate risk to the health and safety reliably, on "high-value of the public; or to mitigate articles." the consequences of such ac-cidents. Reliable operation of the plant may depend upon other systems, st ruct ures and components which are not covered by this c cuitment. General Certain Regulatory Guides Our commitments apply to the an 1 ANSI Standards contain requi rement s. It is our in-bot h re<pii rement s and guid-tent to itplement the guide-ance. lines contained in the ANSI Standards endorsed by R.G.'s 1.30, 1.37, 1.39 Rev. 2, 1.58, 1.64 Rev. 2, 1.88 Rev. 2, 1.94 Rev. I and 1.116 Rev. 0-R unless acceptable alternatives are ccn-tained within this TOPICAL. The General SRC Regulatory Guides and majority of ANSI Standards to ANSI Standards do not pro-which AP&L has committed are vide for deviation from any concerned with the design and/ reeptii eaent (s) when emer gency or const ruct ion phases o f or other urgent c.aditions make nuclear power plants. Con-deviatien necessary. sequently, APSL has adapted r-Q[,1 ~ DATE / OUALITY ASSURANCE FANUAL REV 5 10/10/60 ,. >. v g q ((] TITLE: APPENDIX A PAGE 1 of 28 SECTION 19

..e l Regulatory Guide / ANSI Std. Re f e re:.ce Requirement Interpretation / Alternate / Exception operations phase, where practicable, I and has developed provisions for I certain conditions not addressed in the standards. In the event of an emergency con-dition which, if not promptly cor-i rected could likely affect the health and safety of the public, the Director, Generation Opera-tions or his designated alter-nate(s) may authorize emergency repairs deviations from written procedures. The nature of the emergency, its cause and the cor-rective action taken are docu-mented. In the event of an emergency not covered by an approved procedure, operations personnel shall take actions so as to minimize person-nel injury and damage to the facility and to noted health and safety. t l General Certain ANSI Standards The majority of ANSI Standards to l contain requirements which AP&L has committed are con-which, under certain cerned with the design and/or con-conditions, may con-struction phases of nuclear power. flict with limiting Consequently, AP&L has adapted personnel radiation these standards to its operations exposure. phase, where practicable, and has developed pcovisions for certain conditions not addressed in the standards. khen conformance with particular standards requirements; e.g., cleaning of fluid syst ems, housekeeping, would conflict 1 l "] QUALITY ASSURANCE MANUAL REv. 5 rr DATE / .[ 10/10/80 p / g7 h. TITLE: APPENDIX A PAGE 2 of 28 SECTION 19 __7 ,-,._,._,_.,__y

- -. I Regulatory Guide / ANSI Std. Reference Requirement _ Interpretation / Alternate / Exception con'flict with limiting personnel radiation exposure, the degree of conformance to the standards is determined by appropria'.e leves cf management. General Va rious st. ida rds Except in ANSI N45.2.5, the require inspections, frequencies of required in-e:<aminations, and inspections, examinations and tests, but do not and tests are not specified specify the fre-in the standards. Accordingly, quencies of these the frequency of inspections, activities. examinations and test required by the standards--other than ANTI N45.2.5--is identified on a job-by-job basis. The amount of inspectio,ns, exam-inations and tests identified as based upon safety signi-ficance complexity of the item or activity and degree of standardization of the item or activity. l ANSI N.18.7 (a) " Maintenance or modi-Requirements (a), (b), and First Sentence shall be performed in (c), as a whole, require of 5.2.7 a manner to ensure a degree of quality for quality at least replacement items con-equivalent to that sistent with their func-specified in original tion. It is AP&L's intent desi.,n bases and re-that maintenance and modi-quirements, materials fications including procure-speci fications, and in-ment and use of replacement spection requirements. " items are to technical re-quirements equal to or better than those specified on the j original item or activity. A reduction in the technical (b) "A maintenance pro-and administrative requirements gram shall be de-from the endorsed ANSI Standards veloped to maintain shall be documented with ap-sa fe ty-rela ted propriate rationale for the structures, systems reduction and approved by and components at Engineering. ) (:. - rr a ~ [,i / f QUALITY ASSURANCE fiANUAL RE V. 5 DATE 10/10/80 hyf[a j,I j g j TITLE: APPENDIX A PAGE 3 of 28 SECTION 19

I t' t ---c' Regulatory Caide/ ANSI Std. Reference Reguitument _In t e rp re t a ton / Al t e rn a te / Ex c ept i o_n i I required for them to and QA/QC personnel. I perform their intended functions. l (c) " Purchased to specifications and codes equivalent to those specified for the original equip-ment, or those specified by a properly reviewed and approved revision." ANSI N18.7 General Requirements for Pa ragraph 5.2.14 applies to pro-nonconforming items. grammat. c as well as to speci-l fied provisions of ANSIN 18.7 and its associated references. Consistent with paragraph 5.2.14, our quality assurance program will contain provisicns for controlled, documented waivers to its require-ments. ANSI N18.7 Requires certain provisions Per 5.2.13 procurement document Section 1 in procuremer.t documents. contents for replacement items will be based primarily on original procurement document contents. j The provisions of 5.2.13.1 will be included if required by original procurement document or warranted l by performance of the item. When i requirements of ANSI standards are I included in procurement docu .nts, the requirements may not be ) ~enti-fied as excerpts from ANSI sta dards. Procurement documents ne developed and reviewed as described in Sec-tion 4 of this TOPICAL. ANSI N18.7 Where changes are made to Consistent with the requirements Section procurements, they shall of ANSI N45.2.11, pa ragraph 7.2, 5.2.13.1 be subject to the same minor changes to (procurement) Ist Para. degree of control as was locuments, such as, inconsequen-used in the preparation tial editorial corrections, or of the original documents. changes to commercial terms and d. 3[ 10/g0 i)[- QUAUH ASSURANCE ENUAL m. 5 TITLE: APPENDIX A PAGE 4 of 28 SECTION 19 l p

Regulatory Guide / ANSI Std. Reference Requirement Interpretation / Alternate / Exception conditions may not require that the revised (procurement.) docu-ment receive the same review and approval as the original documents. l ANSI N18.7 Dev i a t. i on s, their cause, Consistent with the documentation Section and any corrective action requirements of Criterion XVI, Ap-5.2.17, last completed or planned shall pendix "B" to 10 CFR 50, for cor-Paragraph, be documented. rective action completed or plan-next to last ned are documented. l sentence. ( ANSI N18.7, "When the preceding Our commitment to ANSI Section 6 American National Standards does not extend References. referred to in this beyond the standards (date, l document are super-revision, etc.) identified l seded by a revision in this TOPICAL. approved by the Am-erican National Stand-ards Inst.itute, Inc., the revision shall ap-ply. ANSI N18.7 Review of Reports Consistent with requirements Section 4.5 of ANSI N45.2.12, reports of audits conducted by QA person-nel shall be distributed to responsible management of both the audited and auditing or-ganizations for review. Vio-lations of applicable statues, codes, regulations, orders, Technical Specifications, license requirements or of internal procedures or in-structions discovered. during audit conductance are reviewed by the in-dependent review body. l Regulatory Sect ion C Pa ragraph 2 The quality assurance pro-i Guide 1.123 gram requirements for con-trol of procurement of safety I e.- ca [f l ]j DATE QUALITY ASSURAliCE mat 4UAL REV. 5 10/10/80 g, TlTLE: APPEtiDIX A PAGE 5 of 28 SECT 10f? 19

-l Regulatory Guide / ANSI Std. Reference Requirement Interpretation / Alternate / Exception related items and services are established in accordance with the requirements of ANSI N45.2.13, normally, by invoking portions of 10 CFR 50 Appenc'ix B/ ANSI N45.2 as well as other applicable codes and standards, or by invoking other specific requirements which meet the intent of this standard. The Appendix to N45.2.13 is used for guidance in making determination. For safety related parts of Code items not covered by the Code, such as non pressure retaining parts, or for Code items performing safety related functions other than pres-sure retaining, the. requirements of the Code program: (a) May be extended to cover such parts and quality related activities when the require-ments of the Code program i are considered to meet the intent of the ANSI Standard. (b) Will be su17 emented by the 1 applicable quality assurance requirements in accordance with ANSI 545.2.13 (as en-dorsed by Regulatory Guide 1.123) to cover t he appro-priate quality related activities for whir.h the Code program requirements are not considered equiva-lent. i For those parts or items covered by the Code, for which the Code program requirements for quality related activities are considered equivalent to t, DATE frf ,j. QUALITY ASSURANCE MANUAL REV. 5 10/10/80 gghl;- g TITLE: APPENDIX A pace 6 of 28 SECTION 19

Regulatory Guide / ANSI Std. Reference Requirement Interpretation / Alternate /E_xception the ANSI Standards, only the quality assurance requirements of the Code will apply. The invoking of N45.2.13, by specific reference, is not con-sidered to be required. Regulatory Section 1.4 Any undesirable foreign l Guide 1.37 Definition of material such as grit, ANSI N45.2.1 Contamination metal particles, oil, grease, loosely adher-l ing slag or scale, film and fiber on the surface i of an item, in the at-mosphere or in pro-cess liquids or gases. l ANSI N45.2.1 Section 3.2 Consistent with ANSI l Fresh water criteria N45.2.1 Draft 3 Rev. 6 for chlorides, and (1/78), the turbidity Jackson Turbidity requirement on fresh Units. water is deleted and the chloride require-meat is revised to read "less than 250 ppm." The turbidy requirement for deminer-alized water is deleted. ANSI N45.2.1 Section 3.1 Consistent with ANSI N45.2.1 Cleanliness Rev. 6 (1/78) allowable par-Classifications ticle size will be as follows: Particle Size (a) Section 3.1.2.5 - There shall be no particles larger than 1/32 inch by l 1/16 inch long (.8 mm X 1.6 mm). (b) Section 3.1.3 - There shall be no particle larger than 1/32 inch by 1/16 inch long ~ L. 1 [6] 30,;^);0 auntiry assuannce xanunt asv. s .,.l;;-Jh TITLE: APPENDIX A PAGE 7 of 28 SECTION 19

O I Regulatory Guide / ANSI Std Reference Requirement Interpretation / Alternate / Exception (.8 mm X 1.6 mm). (c) Section 3.1.4.4 - There shall be no particle larger than 1/16 inch by 1/8 inch long (1.6 mm X 3.2 mm). ANSI N45.2.1 Section 5 AP&L will also allow the use of wood, metal caps, rubber and duct tape to close openings and pipe end when vork is not in progress. These alterna-tive methods are considered to maet the intent of the Standard, which is'to keep the internal surfaces clean. ANSI N45.2.2 "The specific items to be Items governed by this stand-Section 2.1 governed by this standard ard or portions thereof are shall be identified." identified on a case-by-case basis during the design document and procurement document deveop-ment ANSI N45.2.2 Each of the specific All safety-related items are Section 2.7 items governed by this protected to an extent com-standard shall be clas-mensurate with their sen-sified into one of four sitivity and importance to levels. sa fety, but are not specifi-cally classified in various levels per the guidance of paragraph 2.7. Therefore, satisfaction of requirements for packaging, shipping, re-ceiving, storage, and handling for particular items could be different than those sug-gested. '[# QUALITY ASSURANCE MANUAL REV. 5 DATE f h (f);3

k 10/10/80 TITLE

APPENDIX A

_7 PAGE 8 of 28 SECTION 19

a ,e ) Regulatorv Guide / ANSI Std. Reference Requirement Interpretation / Alternate / Exception ANSI N45.2.2 General marking Some itees of a size, shape Subsection requirements. or consistency which pre-3.9 clude marking. Marking in such cases is applied to box or other enclosure. Tagging is employed, where necessary. ANSI N45.2.2 " Preliminary visual Inspection af ter unloading is Subsection inspection or exa nina-sufficient to determine the 5.2.1 tion shall be performed condition of many items. In prior to unloading.." special instances, pre-unload-ing examination is performed. ANSI The (receiving inspections Receiving inspection is performed N45.2.2 shall be performed in an in a manner and in an environment Section area equivalent to the which do not endanger the requisite 5.2.2 level of storage require-quality of an item. The receiving ment for the item. inspection a rea environmental re-quirements for that item, however, the she-t time spent in the less stringent receiving inspection area shall be of such duration that will not adversely a f fect the item being received. ANSI . The 'Special The "Special Inspection" pro-N45.2.2 Inspection' pro-cedure shall be readily avail-Paragraph cedure, complete able to inspection personnel 5.2.3 with documentation and may be attached to the instructions shall be item or container. attached to the item or container.. ANSI "A statement document-A statement documenting N45.2.2 ing the authority and the authority and justifi-Subsec-and technical justi'i-cation for the conditional tion 5.3.3 cation for the condi-release prepared. Justifi-tional release...shall cation may not always be of be prepared. a technical nature. r. DATE f;f[,"rjhjj [.- ([ QUALITY ASSURANCE KANUAL REV. 5 10/10/80 TITLE: APPENDIX A PAGE 9 of 28 SECTION 19

_ Regulatory _ Guide / ANSI Std. Reference Reguirement I n t e rpre t; a t i o r3/A l_ t e rna t e/ E x c ep t i on ANSI The use or storage of People working in storage N45.2.2 food, drinks, and salt areas have a right of sccess Subsec-dispensers in any to water dispensers per OSrIA tion 6.2.4 storage area is requirements. Addi

onally, prohibited.

due to location and layout of the building, personnel may temporarily store lunches in the work-place. This area is policed for sanitation. A3SI " Container markings Containers are adequately N45.2.2 shall appear an a marked for storage, iden-Appendix minimum of t o sides tifcation, and retrieval. (A-3) of the cont.iner, pre- ?!ultiple marking require-A.3.9 (1) ferably on one side and ments ate imposed, where Second one end." necessary. Group ANSI N45.2.2 " Container markings Container markings are of a Appendix (A-3) shall be...no less than size which permits easy A.3.9 (4) 3/4" high container recognition. Second Group. permitting." ANSI " Container marking The information required N45.2.2 shall include the in container marking is App?ndix following informa-evaluated on a case-by-(A-3)A.3.9 tion..." case basis. Blarking is adequate in each case. ANSI N45.2.2 "Non-metallic plugs Non-metal plugs and caps are Appendix (A-3) and caps shall be of a suitably visible color. Section A brightly colored." 3.5.1 (1) ANSI N45.2.2 Plugs or caps shall be In cases where plugs or caps Appendix (A-3) secured with tape or other do not snugly fit, additional Section A means as necessary to pre-securing devices or measurer 3.5.1 (5) vent accidental removal. which will not be detrimer, l to the item will be used. I 3: DATE

~

QUALITY ASSURANCE MANUAL REV 5 10/10/80 [-[-l,g j. TITLE: APPENDIX A PAGE 10 of 28 SECTION 19

I 1 i, l \\ \\ I R gulatorv_ Guide / ANSI Std. Interpretation / Alternate / Exception I l e Reference Requirement The last paragraph of Sec- ' Marking of items tion A.3.9 could be in- /.NSI l N45.2.2 not within a con-terpreted as prohibiting I any direct markia.g on bare tainer. f Appendix l (A-3) Sec-austenitic stainless steel f tion A3.9 and nickel alloy metal sur-In lieu thereof, para-faces. graphs A.3.9 (1) and (2) will be used to control marking on the surface of austenitic stainless steels and nickel base alloys subject to the following limitations: " Marking materials contain-ing sulf"c, lead, zinc, mercury, copper and low melting alloys as a basic chemical tonstituent shall not be brought in contact, or shall not be used on surfaces of corrosion re-sistant alloys. Low sul-low fluorine and/or

fur, low chlorine conpounds.

may be used on austenitic stainless steels." The maximum limits for the above mentioned marking materials will be as follows: (a) Total inorganic and organic shall not halogen content exceed one (1) percent. (b) The sulfur content shall not exceed one (1) percent. involving There may be cases Inert Cas Blankets large or complex shaped for ANSI N45.2.2 which an inert or dry air is provided, r.: t he r purge in than static has blanket order to provide adequate to difficulty protection due of providing a leak proof barrier. In their cases, a positive pressure purge flow may be utilized as an leak proof alternate to a barrier. DAIT. REV. 5 10/10/80 T, QUALITY ASSURANCE I4ANUAL PAGE 11 of 28 5ECilCN 19 _ ' /~f I 5 4 TITLE: APPENDIX A ~ [D M. Q 1

~ / Regulatory Gui;e/ ANSI Std. Reference-Requirement In te rp re t a t i o n/ Al t e rna t e/Ex cey_t i on ANSI Limits halogen and Engineering may allow the N45.2.2 sulphur content of use of tapes containing i Apendix A, tape. greater amounts of halogens i A.3.5.2, af ter appropriate evaluation, (1), (a) however, the quantities shall not be such that harmful concentrations could be leached or relased by breakdown of the com-pounds under expected environmental conditions. Regulatory General hlternative equivalent Guide 1.39 requirements may be ANSI N45.2.3 utilized to cover those situations not included in the subject Standard; for example, situations in which shoe covers and/ or coveralls are required but material accountability is not. In addition, zones might be combined into the next more restrictive category in order to reduce total number of zones. ANSI N45.2.3 Identifies various When this standard is applied, househeeping require-its requirements implemented ments, including clean-in those areas affected by liness, fire prevention, work activities associated and fire protection with modi fications, opera-which must be accomp-tions, or maintenance as lished during the pro-determined necessary by gress of const ruction. Plant Sta f f. Regulatory Pre Construction / This section required Guide 1.30 Installation verification that items ANSI N45.2.4 Verification are in satisfactory condition for installa-Regulatory tion and have not suf-Guide 1.116 fered since initial receipt ANSI N45.2.8 inspection. Upon receipt, items are inspected and stored in an environment which will not adversely a f f ect. the item. Document ed routine inspections and " 's DATE / .g [- QUAL.ITY ASSURANCE MANUAL 10/]O/80 REV* 5 tm/,;;r L.' TITLE: APPENDIX A PAGE 12 of 28 SECTION 19 oc

j' + \\ l = Reculatory GuideLANSI Std. 1 Reference R_cquirement Interpretation / Alternate / Exception ( l periodic audits of the storage areas assure that stored items are maintained j in satisfactory conditions. i Documentation of pre-con-structi;n verification in i addition to documentation l-of initial receipt inspec-tion, periodic storage 3 j inspections, and audits of j storage is not required. ANSI Identifies various During the operational N45.2.4 tests to be per-phase these tests will j formed. be performed "as appro-1 priate" as determined j by Engineering or Genera-1 tion Operations based upon the significance of change or modification. l ANSI " Mechanical tests shall For the plant operational N45.2.4 be perforraed to ascertain phase, " system pressure l Subsection that... con.ponents or sys-ratings" is interpreted to 5.2.2 Mech-tems can withstand system mean system operating pres-anical Tests pressure ratings." sure. For the Reactor Coolant i i System, Facility Technical Speci-fications identify testing requirements. l ANSI " Items requiring cali-Items requiring ca'libration j N45.2.4 bration shall be tagged are tagged indicating date j Subsection ... indicating date of of calibration. Identity of i 6.2.1 calibration and identity person that performed the of person..." calibration shall be in-dicated on the tag or trace-l able through records. ? j ANSI N45.2.4 "These tests shall be For the plant operation phase, 9 Subsectica made to verify that all this requirement is inter-l 6.2.2 parts of a system pro-preted as not requiring that i Systems perly coordinate with an entire system be re-tested Tests each other." after completion of modifica-tion of only a portion of that j l t r... - DA'IE REV. 5 Rf QUALITY ASSURANCE MANUAL 10/10/80 i L[._l m.c'.2d TITLE: APPENDIX A PAGE 13 of 28 SECTION 19

/, Regulatory Guide / ANSI Std. Reference Re3nirement Interpretation /Alteinate/ Exception system. The testing require-ments of the Facility Tech-nical Specifications are met for inoperable equipment. 1 1 I a... pm REV 5 10/10/80 ), QUAllTY ASSURANCE P.ANUAL ga u.? _,: I N l TITLE: APPENDIX A PAGE 14 cf 28 SECTION 19 .m d.

~ ~ Regulatory Guide 1.94, Revision 1, April, 1976 (ANSI N45.2.5 - 1974, Installation,, Inspection, and Testing of Structural Concrete and f.;ructural Steel During the Con; truction Phase of Nuclear Power Plants). The requirements of the reference Standard will be applied to the quality program for construction of safety related items as interpreted in the Regulatory position as modified and interpreted below. 1) Dection 1.4 defines in process tests and states: .. samples of these tests must be taken f rom the lot or hatch cf materials supplied to the site for use." This requirement for reinforcing steel will be interpreted to permit taking the rebar test' specimen at the fabrication shop, prior to start of fabrication of the rebar from the heat or fraction thereof represented by the test specimen. For these tests performed at the fabrication ship, certification shall be available to provide objective evidence that the test specimens ecpresent the material supplied for use at the site. i f t e DATE REv. 5 f/ (), QUALITY ASSURANCE MANUAL 10/10/80 [g {[ TITLE: APPENDIX A PAGE 15 of 23 SECTION 19

, =

• 2)

Section 4.5, Concrete Placement, references American Concrete Institute (ACI) standards (ACI-305-72, "Recommen.h d Practice for llot Weather Concreting" and ACI 306-66, "Recomnended Pract ice for i Cold Weather Concreting?' t In order to clarify use of these ACI standards, we will apply the following requirements: PI. ACING TEMPERATURES OF CONCPETE: i A. ')nring hot weather concreting: Placing temperatures of concrete will be limited to the following: 1) Concrete members less tlian 3 f'eet in least dimension will not exceed 90 F. 2) Concrete members f rom 3 feet to 6 feet in least dimension will not exceed 70 F. 3) Conctete members more than 6 feet in least dimension will have placing temperature as near 50 F as can be obtained by use of ice as necessary up to 100 percent of adding mixing water; and by shading aggregate and sprinkling the coarse aggregate the day it is to be used. Care will be tiken so that no unmelted ice remains in the concrete at the end of the mixing period. B. During t he cold weather concreting: In heating the water and aggregate, live steam to heat the fine and coarse agt:regate shall not be used. The permissible range for concrete t emperature shall be as follows: 1) Sc~tions less than 3 feet in least dimensions: 1 55 to 75 F. 2) Mass concrete 3 feet or more in least dimension: l 45 to 65 F. The mixing water and aggregate will be purchased as required. The materials will be free of ice, snow and frozen lumps before they enter the mixer. 10/db0 .5 QUALITY ASSURANCE MANUAL .5 Eaj; e; m.q TITLE: APPE!; DIX A PAGE 16 of 28 SECTION 19

. - ~. 3) Setion 4.8, "In proc'ss Test on Concrete and lleinforcing Steel" rtates, "Sanpies for in process test of concrete. shall be taken at the sampling point in accordance with l AS1h Cl?2. This point may be at t he truck mixer discharge if the last piece of conveying equipment is a chute, bucket, conveying system, or similar equipment. Pun. ped concrete must be sampled from the pump line discharge." For performance of correlation tests, the requirements of ANSI N45.2.5 - 1978 sha11 be fol1 owed. l l l 4) Section 4.8, "In process Tests on Concrete and Reinforcing St eel" cont ains Table B ent itled, "Requi red In-process Tests." The following modifications to this table will be applied: I l l l c r, DATE - j-l QUALITY ASSURAfCE MAf;UAL REv. 5 t' 10/10/80 p,$;y J) TITLE: APPENDIX A PAGE 17 of 28 SECTION 19

4.1) REINFORCING STEEL In process testing of reinforcing steel will include the mechanical properties of yield strength, tensile strength and percent elogation on full size specimens for each bar size for each 50 tons or fraction thereof from each mill heat. Bend tests are performed during material qualification testing only, except as noted below for bar sizs #14 and

1. 18.

Table A, " Required Qualification Tests" as applied to reinforcing steel will include bend tests as required by ASTM A615 and summarized below: a) For bar sizes #3 through #11, one full size specimen from largest bar size rolled from each mill heat, unless material from eic heat differs by three.or more designation numbers. When this occurs, one bend test shall be made from both the highest and lowest designation number of the deformed bars rolled. b) For har sizes #14 through #18, Supplementary Requirements S1 of ASTM A615 will be applied. One full size specimen for each bar size for each mill heat. If supplementary requirements are not followed for mill tests, they will be applied as in process tests. The above interpretation is consistent with Regulatory Guide 1.15, " Testing Reinforcing bars for Category I Concrete Structures," Revision 1, December 1972. In process t est specimens may be selected at the rebar fabrication shop, prior to start of fabrication of the rebar from the heat or fraction thereof represented by the test specimen. Acceptance criteria for any failed test (qualifications as well as in process) may be the same as that for tensile tests specified in Subarticle CC-2331.2 of ASME Section III, Div. 2 Code (1975). This states that if a test specimen fails to meet the specified strength requirements, two (2) additional specimens from t.he same heat and of t he came bar size would be t ested, and if either of the two additional specimens fails to meet the specified strength requirements, the material represented by the tests would be reject ed for the specified use. Alternative use of rejected material under strict control may be subject to evaluation by the Project Engineer. 6. pg7g REV. 5 l' QUALITY ASSURANCE MANUAL 10/10/80 g n =.ce.,- ex$.. TITLE: APPENDIX A PAGE 18 of 28 SECTION 19

l. 1 l 5) Section 4.9, Mechanical (Cadweld) Splice Testing states in paragraph 4.9.4 " Separate test cydes shall be established fot mechanical splices in horizontal, vertical and diagonal l bars, for each bar size and for each splicing crew..." The terms " horizontal, vertical and diagonal bars" will be interpreted to apply respectively to the following types of splice positions: Horizontal, including 10 to horizontal a. b. Verticle, including 10 to vertical c. 45 angle, including 10 to 80 angle The words " splicing crew" will be interpreted to refer to all uembers on the project that are actively engaged in preparing and assembling cadweld mechaniul splices at the final splice location. Separate test cycles will be established for each be r size and each splice position. - J304% ~ uv. s ig D j;rjj ounun nssuruct mua. TITLE: APPE!; DIX A PAGE 19 of 28 SECTIO!i 19 g

\\ l y--" 0 Regulatory Guide 1.58 dated August 1973 (ANSI N45.2.6 - 1973, Qualifications of Inspectior., Examination and Testing Personnel for the construction t phase mawafacturing/ fabrication phase of Nuclear Power Plants). The requirements of the referenced standard, as modified and interpreted in the regulatory position will applied to the AP&L Quality Program during the operational phase as described in this topical report subject to the following clarifications: 1) Substitute new Section 1.1 and 1.2 and modify first paragraph only of 1.0. Section 1.1 Scope This standard delineates the requirements for quali fication of personnel who perform inspection, examination and testing to verify confor mance to specified requirements of nuclear facility items (structures, systems and components of nuclear power plants, fuel reprocessing plants, plutonium processing plants and plutonium fabrication plants) whose satisfactory performance is required to prevent postulated accidents which could cause undue risk to the health and sa fety of the public; or to mitigate the consequences of such accideats if they were to occur. The requirements may also be extended to other items of nuclear facilities when specified to contract documents. Section 1.2 Applicability The requirements of this standard apply to personnel who perform inspections, examiniations and tests during fabrication prior to and during receipt of items at the construction site, during construction, during preoperational and startup testing, and during operational phases of nuclear facilities. The requirements of this standard do not apply to personnel who perform inspect. ions for government or municipal authorities, or who 1,erforms as authorized inspectors in accordance with the ASSIE Boiler and Pressure Vessel Code. The requirements of this standard are not intended to apply to personnel who only perform inspection, examination or testing in accordance with employer practices which are in compliance with " Recommended Practice No. SNT-TC-1A and its applicable supplements. The requirenents of this standard are operational, at the discretion of t he employer, for application to personnel who rform calibration or to cra f t smen who perform installation checkouts as part of their basic installation responsibility to ready the installation for preoperational testing. This st anda rd is to be used in conjunction with ANSI N45.2-1977. f QUALITY ASSURANCE MANUAL REv. 5 10/10/80 ((( ?;({ TITLE: APPENDIX A PAGE 20 of 28 SECTION 19

~ t The equirements apply to personnel of the owner. The requirements app!y to architect-engineers, nuclear facility systen: designers and system s,uppliers, plant designers and plant construct ors, equipment suppliers, outside testing agencies and consultants when specified by the owenr. Other standards or codes may contain qualification requirements for personnel such as nondestructive examination personnel as required by the ASifE Boiler and Pressu e Vessel Code, and Quality auditor personnel as may be required by Quality Systems or Quality Assurance Program standards. k' hen this is the case, this standard is not to be interpreted to require a duplication of effort. Section 1.3 Responsibility It is the responsibility of each organization participating in the project to assure that only those. personnel within their respective organizations who meet the requirements of this standard are permitted to perform inspection, examination and testing activities covered by this standard that verify conformance to quality requirements. 2) Since this Standard does not apply to personnel who perform non-destructive examinations, delete Section 2.2.2. 3) Section 2.2.3. Evaluation of Performance. The periodic internal for re-evaluation of personnel shall not exceed three years. 4) The requirements of this Stanitard shall apply only to personnel who perform inspection, examination and testing; and accordingly Section 3 and 3.1 shall be revised to read: i 3. Qualifications 3.1 General The requirements contained within this section define the minimum capabilities that qualify personnel to perform in-spections, examinations and tests which are within the l scope of this standard. There are three levels of qualification. The requirements for each level are not limiting with regard to organizational position or professional status, but, rather, are limiting with regard to functional activities which are within the scope of this stas ard. s e DATE e. ff [ QUALITY ASSURANCE MANUAL RE V. 5 10/10/80 pj;;}p);f TITLE: APPENDIX A PAGE 21 of 28 SECTION 19

.,.,. )1. i Followin6 is mbe recommended personnel education and experience for each level. These education and experience reconumendations should h.c treated to recognize that other factors may provide reasonable assurance that a person can competently perform a particular task. Other factors which may demonstrate capability in a given job are previous performance or satisfactory completion of capability testing. The education and experience requirements shall make provision for personnel who have not graduated from high :.chool or who have earned an Associate degree. According to paragraphs 3.1.1, 3.1.1, and 3.1.3 shall be revised to read: 3.1.1 Level I (1) Two years of related experience in equivalent inspection examination or testing activities, or (2) High school graduation and six months of related experience in equivalent inspection, examind ion or testing activities, or i i (3) Completion of college level work leadi.: co an i Associate degree in related discipline plus three j months of related experience in equivalent inspection, examination or testing activities. j 3.1.2 Level II (1) One year of satisfactory performance as Level I, or s (2) High school graduation plus three years of related experience in equivalent inspection, examination or testing activities, or (3) Completion of college level work leading to an Associate degree in related discipline plus one year realted experience in equivalent inspection, examination or testing activities, or (4) Four year college graduation plus six months of related experience in equivalent inspection, examination or test-ing activities. 3.1.3 Level III (1) Six years of satisfactory performance as a Level II, or ~ QUALITY ASSURANCE MANUAL REV. 5 10/ 0 80 s [ g.;'f_,. 3] TITLE: APPENDIX A j PAGE 22 of 28 SECTION 19

3 r,. # (2) liigh school graduation plus ten years of related experience in equivalent inspect. ion, examination or test.ing activities; . or high school graduation plus eight years experience in equivalent inspection, examination or t est.in3; activities, with at least t.wo years as Level II and with at least two years associated with nuclear facilities - or, if not, at least sufficient training to be acquainted with the relevant quality assurance aspects of nuclear facility, or (3) Completion of college level work icading to an Associate degree and seven years of related experience in equivalent inspection, exam;.iation or t esting act.ivit.ics, with at least two years of this experience associated with nuclear facilities - or, if not, at least sufficient. training to be acquainted with the relevant quality assurance aspects of a nuclear facility, or (4) Pour year (.ollege graduation plus five years or related experience in equivalent. inspection, examination or testing activities, with at least two years of this expei-ience associated wit h nuclear facilit.ies - or, i f not, at. least sufficient t raining to be acquainted wit h the re levant quality assurance aspects of a nuclear facility. 6) Section 3.2.1 Physical (Revised to read) AP&L shall identify any special physical characteristics needed in the performance of each act.ivity. Personnel requiring these characteristics shall have t hem verified by examinat ion at intervals act to exceed one year. 7) Section 3.2.2 Technical (Revised to read) a. Level 1 Personnel Capabilities A Level I person shall be capable of performing and documenting the inspections, examinations and tests that. are required to be performed in accordance with documented procedures and/or industry practices. The individual shall be familiar with the tools and equipment t o be en, ployed and sMll have demonst rated proficiency in their use The individual shall also be capable of determining that the calibration st atus of measucing and test equipment is current, that the measuring and test equipment is in proper conditien for use, and that the inspection, examina-tion and test procedures are approved. U. D^E REV* 5

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QUALITY ASSURANCE MA!!UAL 10/10/80 g ,h TITLE: APPENDIX A PAGE 23 of 28 SECTION 19

- =.. _. - -.. _ b. Level II Personnel Capabilities A Level II person chall have all of the capabilities of a Level I person. Additionally, a Level II person shall have demonstrated capabilities in planning inspections, examinations and tests; in setting up tests including pre-paration and set-up of related equipment, as appropriate; in supervising or maintaining surveillance over the inspections, examinations and tests; in supervising and certifying lower icvel personnel; in reporting inspection, exanination and testing results; and in evaluating the validity and accepta-bility of inspection, examination and test results. c. Level III Personnel Capabilities A Level III person shall have all of the capabilit.ies of a Level II pers,a. In addition, the individual shall also be capable of evaluating the adequacy of specific programs used to train and test inspection, examination and test personnel whose qualifications are covend by thir standard. The indi-vidual shall also be capable of reviewing and approving in-spection, examination and testing procedures and of evaluating the adequacy of activities to accomplish the inspection, examina-tion and test. objectives. l 8) Section 4 Performance (Revised last sentence to read) i j When a single inspection or test requires implei.entation by a team or group, personnel not meeting the requirements a I of this Standard raay be used in data - tal.ing assignments or in plant or equipment operation provided they are supervised or overseen by a qualified individual partici-i j pat.ing in t he inspection, examination or test. 1 ] 9) Section 5 Records (Revised to read) I A file of records of personnel qualification shall be I established and maintained by the employer. Collection, storage and control of records required by this Standard shall be in accordance with R.G.I.SS Rev. 2. 10) Table 1 (Revised to read) t Implement inspect ion and test procedures and document results. I 7

1. ~E QUALITY ASSURANCE Wd!UAL PIV. S

.5 10/10/80 5 [., 4 TITLE: APPENDIX A lJECTION 19 P/.CE 24 of 28

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,w---.- 5 Re c u.l a t o r.v G..u i de./ A.NS I S t d Int c rp re ta t i on / A1 t e rna t r /f.x cept i on .-Reference licou i remen t ~ Regulatory "Qualit.y Assurance Tetms Vhere terms defined in ANSI Guide 1.74 and Definitions." N45.2.10 are also defined in ANSI ot her s tanda rds to which /.P&L N45.2.10 L :- s referred in this program desc: stion, the definitions in those other standards shall

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ANSI Definitions of Cert i fi-Based upon the guidance of N45.2.10 cate of Conformance /ASI K45.2.13, 10.2, the of Cotcpliance." definitions of these two terms wi11 be exchanged. ANSI De finition of "!!odi fica- !!odi fica tion - /. change to N45.2.10 Lion." an i' en's con figurat ion, mat - terial(s) of function (s) such that. the item does not conform to previously appr6Ved design documents. ANSI Program procedures nl.a l l A variety of experience reports N45.2.ll cover making experience f rom a nua.ber of sources are Sectica 2.2 reports available nade available to design person-to cogninant design nel wit hout benefit of written in r m nel. procedures. ANSI Individual Audit Plans for thor,e root ine audits con-N45.2.12 ducted during operations, a Pa ra g raph critten procedure covering 4.2.1 c l:a. s c s o f a ud i t s (i.e., plant site operational audits of plant. s t.i t i act ivit n es, et c. ) wi11 he uti1ized as opposed to an individual plan for each audit. 'f b e procedut e(s) will identify t!.e audit scope, a re-q u i r er.w n t t he. t individual chech-lists be utilized listing ie-qui re&nt s which a re to be audi ted and not i ficat ion of the and i t ed ;;roup. l r v' / [,l QUALITY ASSURANCE IGNUAL ..._..'.-.___.__.._1_0. 0 3 _/E0._ _ p;;rg D L},,.. L T!TLE: APPENDIX A I.I rf,cr 25 cf 28 5ECT):H i9 s

+ ,9 = 8 I J Regulatory Guide / ANSI Std. Reference Requirement I n t e rp re t a t i o n / A l t e r n a t e / E x c ep t i on } ANSI Audit Notification Audit Notification shall be 4 i N45.2.12 given either in writing or l Pa ragraph verbally to the involved 4.2.4 organizations. l ANSI Pre-Audit Conference For those routine audits N45.2.12 conducted during operations, Paragraph in some instances, a formal 4.3.1 pre-audit conference is not necessary. For those cases where formal pre-audit con- 'ferences are not held for rottine on-site day-te-day audits, the audited organiza-l tion shall be on distributon j for the audit schedule and the auditor shall notify the organization by phone or personal contact prior to actual start of each audit. The auditor as-signed the task of con-ducting the audit is responsible for estab-lishing if a formal pre -audit conference ^ is required. This de-cisien shcald be made after input from the j audited group. ANSI Follow-up by Audited Management of the audited N45.2.12 Organization organization or activity Paragraph shall respond as requested 4.5.1 by the audit report. For less significant findings, a re-audit may be scheduled and conducted without requir-ing a written response. b' hen a written respense is requested, manage:nent of t!.e audited organization or activity. s i r .r ~ --DATE [ QUALITY ASSURANCE f4ANUAL REv. 5 10/10/89 s g,,.;.7,jg IITLE: APPENDIX A Pact 26 of 28 S ECTIO" 19

s l l Repl a t o ry Guide / ANSI Std. Reference T qui rer..ent Interp_retation/ Alternate / Exception p ro g ram, ar.d no separate system exists that ad-dresses itself solely to such verification. The degree of verifica-tion required will de-pend upon the type of item of service and their safety importance. The means of verification may include source witness / hold points; source audits and document reviews; in-dependent inspections at the time of material re-ceipt; user tests on selected commodities, such as concrete com-ponents; or tests after installation on selected components and systems. All of these means verify whether or not a supplier has fulfilled procurement at oment requirements, and whether or not a certifica-tion system is effective. DATE f / l) QUALITY ASSURANCE MANUAL REV. 5 10/10/80 L..(I._o}... 'm TITL E: AP?ENDIX A Pact 28 of 28 SECT'ON 19}}