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Virgil C. Summer Nuclear Station Unit 1 - Transmittal of Quality Assurance Program Description
	ML13316A259
Person / Time
Site:	Summer
Issue date:	11/07/2013
From:	Thompson B L; South Carolina Electric & Gas Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	Download: ML13316A259 (158)
	v • d • e

Bruce L. ThompsonManager, Nuclear Licensing 803.931.5042 November 7, 2013A SCANA COMPANYDocument Control DeskU. S. Nuclear Regulatory Commission Washington, DC 20555

Dear Sir / Madam;Subject:

VIRGIL C. SUMMER NUCLEAR STATION UNIT 1DOCKET NO. 50-395OPERATING LICENSE NO. NPF-12TRANSMITTAL OF QUALITY ASSURANCE PROGRAM DESCRIPTION (QAPD)In accordance with 10 CFR 50.54(a)(3),

South Carolina Electric

& Gas Company, actingfor itself and as agent for South Carolina Public Service Authority, transmits onecontrolled copy of the QAPD, Revision 1 and one controlled copy of the QAPD,Revision

2. The 10 CFR 50.54(a) evaluations for each revision are also attached.

Should you have any questions, please contact Ms. Tammy Price at (803) 345-4176.

Very truly yours,Bruce L. Thomps nTJP/BLT/ts Attachment c: (Without Attachment unless noted)Victor M. McCreeNRC Resident Inspector RTS (LTD 1362)File (810.10-2, RR 6950)PRSF (RC-13-0163)

Virgil C. Summer Station .Post Office Box 88. Jenkinsville, SC. 29065 .F (803) 941-9776 CONTROLLED COPY NUCLEAR OPERATIONS COPY NO.____A SCANA COMPANY Quality Assurance Program Description Title: South Carolina Electric

& Gas Co.V. C. Summer Unit 1 Quality Assurance Program Description Process/Program Owner: Senior Vice President, Nuclear Operations Version Number Effective DateRevision 1 7/24/2013 Revision Summary:1. Revised to acknowledge application of previously approved 10 CFR 50 Appendix B program to ISFSI aspermitted by 10 CFR 72.140(d).

2. Revised Part II Section 10.3 resolving an apparent conflict between IEEE 336-1985 and RG 1.33 Revision 2.3. Added the minimum qualifications of the Manager, Materials

& Procurement.

4. Revised Part V Section 5 clarifying the use of calibrated tools.5. Clarified Part II Section 1 to address the split quality responsibilities of the Manager, Business and Financial

Services, and the Manager, Nuclear Finance Administration.

6. Revised Part Ii Section 1 to clarify the organizational titles and responsibilities of the COO, EPVG, VPNNO,DNT, MNT(Unit 1), MNT (NND).7. Clarified Part II Section 1 requirements related to the maintenance of independence by the Quality Assurance organization.

8. Addressed numerous typographical, grammatical, and editorial related items.9. Enhanced Figures 11.1-1 and 11.1-2 to appropriately identify the organizational structure depicted in Part II,Section 1, and OrgPlus.Prepared By/Date:Original Signed by Melvin N. Browne on 07/24/13M. N. BrowneManager, Quality SystemsReviewed By/Date:

Approved By/Date:Original Signed by Thomas D. Gatlin on 07/24/13 Original Signed by Jeffrey B. Archie on 07/24/13T. D. Gatlin J. B. ArchieVice President, Nuclear Operations Senior Vice President and Chief Nuclear Officer V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1South Carolina Electric

& Gas Co.Policy Statement South Carolina Electric

& Gas Co. (SCE&G) shall design, procure, and operate the V. C.Summer nuclear plant in a manner that will ensure the health and safety of the public andworkers.

These activities shall be performed in compliance with the requirements of the Code ofFederal Regulations (CFR), the applicable Nuclear Regulatory Commission (NRC) FacilityOperating

Licenses, and applicable laws and regulations of the state and local governments.

The SCE&G Quality Assurance Program (QAP) is the Quality Assurance Program Description (QAPD) provided in this document and the associated implementing documents.

Together theyprovide for control of SCE&G activities that affect the quality of safety-related nuclear plantstructures,

systems, and components (SSCs) and include all planned and systematic activities necessary to provide adequate confidence that such SSCs will perform satisfactorily in service.The QAPD may also be applied to certain equipment and activities that are not safety-related, butsupport safe plant operations, or where other NRC guidance establishes program requirements.

The QAPD is the top-level policy document that establishes the manner in which quality is to beachieved and presents SCE&G's overall philosophy regarding achievement and assurance ofquality.

Implementing documents assign more detailed responsibilities and requirements anddefine the organizational interfaces involved in conducting activities within the scope of theQAPD. Compliance with the QAPD and implementing documents is mandatory for personnel directly or indirectly associated with implementation of the SCE&G QAP.Original signed by: K.B. Marsh Date: 3/16/11K. B. MarshPresident

/ COO V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1TABLE OF CONTENTSPO LICY STA T EM EN T .......................................................................................................................

iT a b le o f C o nte n ts ...............................................................................................................................

ii -ivPA RT I INTRO DU CTIO N ................................................................................................

1SECTIO N 1 G EN ERA L ........................................................................................................

11.1 Scope / A pplicability

.........................................................................................

1PA RT II Q A PD D ETA ILS ..................................................................................................

3SECTIO N 1 O RGAN IZATIO N ................................................................................................

31.1 SCE&G Corporate Management Organization

.................................................

31.1.1 SCANA Chief Executive Officer (CEO) ..................................................

31.1.2 SCE&G President

& Chief Operating Officer (COO) ..............................

31.1.3 Executive Vice President, Generation (EVPG) ......................................

41.1.4 Senior Vice President

& Chief Nuclear Officer (SVP/CNO)

..................

41.1.5 Vice President, Nuclear Operations (VPNO) ........................................

41.1.6 Vice President, New Nuclear Operations (VPNNO) ..............................

41.1.7 Director, Nuclear Training

...................................................................

41.1.7.1 Manager, Nuclear Training (Unit 1) ...............................................

41.1.7.2 M anager, Nuclear Training (NND) .......................................................

51.2 V. C. Summer Unit 1 Operating Plant Management Organization

...................

51.2.1 General Manager, Nuclear Plant Operations (GMNPO) ......................

51.2.1.1 M anager, O perations

......................................................................

51.2.1.2 Manager, Maintenance Services

....................................................

51.2.1.3 Manager, Chemistry Services

........................................................

61.2.1.4 Manager, Health Physics and Safety Services

................................

61.2.2 General Manager, Nuclear Support Services (GMNSS) .......................

61.2.2.1 M anager, Nuclear Licensing

...........................................................

71.2.2.2 Manager, Planning

& Scheduling

....................................................

71.2.2.3 Manager, Emergency Planning

......................................................

71.2.2.4 O utage M anager ............................................................................

71.2.2.5 W orkweek M anagem ent ...............................................................

71.2.3 General Manager, Engineering Services (GMES) ..................................

81.2.3.1 M anager, Design Engineering

.........................................................

91.2.3.2 Manager, Plant Support Engineering

..............................................

81.2.3.3 Manager, Materials

& Procurement

..............................................

81.2.4 General Manager, Organizational Development and Effectiveness (G M O D & E) ...........................................................................................

81.2.4.1 Manager, Organizational Development

& Performance

...............

91.2.4.2 Manager, Nuclear Protection Services

...........................................

91.2.4.3 M anager, Quality System s .............................................................

91.2.4.4 Manager, Information and Systems Technology

..........................

101.2.4.5 Supervisor

Records, Documents, and Reproduction

....................

101.2.5 Manager, Business and Financial Services

.........................................

10ii V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 11.2.6 Corporate Services

.............................................................................

101.2.6.1 Manager, Nuclear Finance Administration

.............................................

101.3 Q uality Assurance

.........................................................................................

1 01.4 Authority to Stop W ork ...................................................................................

111.5 Quality Assurance Organizational Independence

.........................................

111.6 NQA-1-1994 Commitment

.............................................................................

11Figure 11.1-1 SCE&G Corporate Organization

..........................................................

12Figure 11.1-2 Unit 1 Plant Management Organization

..............................................

13SECTION 2 QUALITY ASSURANCE PROGRAM ....................................................................

142.1 Responsibilities

..............................................................................................

152.2 Delegation of W ork ........................................................................................

152.3 Periodic Review of the Quality Assurance Program .......................................

152.4 Issuance and Revision to Quality Assurance Program ...................................

152.5 Personnel Q ualifications

.................................................................................

152.6 NQA-1-1994 Commitment

/ Exceptions

.........................................................

16SECTIO N 3 DESIG N CO NTRO L ..........................................................................................

183.1 Design Verification

..........................................................................................

183.2 Design Records ...............................................................................................

193.3 Computer Application and Digital Equipment Software

................................

193.4 Setpoint Control ..............................................................................................

193.5 NQA-1-1994 Commitment

.............................................................................

193.6 Design Control Commitment (Section

3) ......................................................

20SECTION 4 PROCUREMENT DOCUMENT CONTROL .........................................................

214.1 NQA-1-1994 Commitment

/ Exceptions

........................................................

21SECTION 5 INSTRUCTIONS, PROCEDURES, AND DRAWINGS

............................................

235.1 Procedure Adherence

.....................................................................................

235.2 Procedure Content .........................................................................................

235.3 NQA-1-1994 Commitment

.............................................................................

23SECTION 6 DOCUMENT CONTROL ..................................................................................

246.1 Review and Approval of Documents

.............................................................

256.2 Changes to Docum ents ...................................................................................

256.3 NQA-1-1994 Commitment

.............................................................................

256.4 Alternative Commitment to Biennial Review of Procedures (Section 6.1.(d))...

26SECTION 7 CONTROL OF PURCHASED

MATERIAL, EQUIPMENT, AND SERVICES

.............

277.1 Acceptance of Item or Service ........................................................................

277.2 NQA-1-1994 Commitment/

Exceptions

.........................................................

28SECTION 8 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS..

308.1 NQA-1-1994 Commitment

.................................

...........................................

30SECTION 9 CONTROL OF SPECIAL PROCESSES

..................................................................

319.1 NQA-1-1994 Commitment

.............................................................................

31SECTIO N 10 INSPECTIO N .....................................................................................................

3210.1 Inspection Program ........................................................................................

3210.2 Inspector Q ualification

....................................................................................

32iii V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 110.3SECTION 1111.111.2SECTION 1212.112.2SECTION 1313.113.2SECTION 1414.1SECTION 1515.115.2SECTION 1616.116.2SECTION 1717.117.217.3SECTION 1818.118.218.3PART IIISECTION 1SECTION 2PART IVPART VSECTION 1SECTION 2SECTION 3SECTION 4SECTION 5NQA-1-1994 Commitment

/ Exceptions

.........................................................

32TEST CO NTRO L ................................................................................................

34NQA-1-1994 Com m itm ent .............................................................................

34NQA-1-1994 Commitment for Computer Program Testing ............................

34CONTROL OF MEASURING AND TEST EQUIPMENT

.......................................

35Installed Instrument and Control Devices ......................................................

35NQA-1-1994 Commitment

/ Exceptions

.........................................................

35HANDLING,

STORAGE, AND SHIPPING

...........................................................

36Housekeeping

................................................................................................

36NQA-1-1994 Commitment

/ Exceptions

.........................................................

36INSPECTION, TEST, AND OPERATING STATUS ...............................................

38NQA-1-1994 Com m itm ent .............................................................................

38NONCONFORMING MATERIALS, PARTS, OR COMPONENTS

..........................

39Interface with the Reporting Program ...........................................................

39NQA-1-1994 Com m itm ent .............................................................................

39CO RRECTIVE ACTIO N ......................................................................................

40Interface with the Reporting Program ...........................................................

40NQA-1-1994 Commitment

/ Exception

...........................................................

40QUALITY ASSURANCE RECORDS .....................................................................

41Record Retention

............................................................................................

41Electronic Records .........................................................................................

41NQA-1-1994 Commitment

/ Exceptions

.........................................................

41A U D IT S ................................................................................................................

4 2Perform ance of Audits ...................................................................................

42Internal A udits .................................................................................................

42NQA-1-1994 Com m itm ent .............................................................................

43NON-SAFETY-RELATED SSC QUALITY CONTROL ............................................

44NON-SAFETY-RELATED SSCs -SIGNIFICANT CONTRIBUTORS TO PLANT SAFETY. 44NON-SAFETY-RELATED SSCs -CREDITED FOR REGULATORY EVENTS .............

47REGULATORY COMMITMENTS

......................................................................

48NRC Regulatory Guides and Quality Assurance Standards

............................

48Regulatory G uides ..........................................................................................

48Standards

.....................................................................................................

..49ADDITIONAL QUALITY ASSURANCE AND ADMINISTRATIVE CONTROLS FOR THE PLANT OPERATIONAL PHASE .....................................

50D EFIN ITIO N S ...................................................................................................

50REVIEW OF ACTIVITIES AFFECTING SAFE PLANT OPERATION

........................

51OPERATIONAL PROCEDURES

..........................................................................

57CONTROL OF SYSTEMS AND EQUIPMENT DURING PLANT OPERATION

...... 65PLANT M AINTENANCE

...................................................................................

66iv V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1PART I INTRODUCTION SECTION 1 GENERALSCE&G's Operational Phase Quality Assurance Program Description (QAPD) is the top-level policydocument that establishes the quality assurance policy and assigns major functional responsibilitiesfor operations activities conducted by or for SCE&G. Organizations within SCE&G Nuclear Operations support New Nuclear Deployment through implementing and supporting the QAPD. The QAPD describes the methods and establishes quality assurance (QA) and administrative control requirements that meet10 CFR 50, Appendix B. The QAPD is based on the requirements and recommendations of ASME NQA-1-1994, "Quality Assurance Requirements for Nuclear Facility Applications,"

Parts I, II, and Ill, as specified inthis document.

The QAPD is applied to the Independent Spent Fuel Installation governed by Subpart G of 10 CFR 72 asspecifically delineated in 72.140. The quality assurance elements and required control detailed in SubpartG are addressed in the QAPD.The QA Program (QAP) as defined by the NRC-approved regulatory document that describes the QAelements (i.e. the QAPD), along with the associated implementing documents.

Procedures andinstructions that control Operational Phase activities were or will be developed prior to commencement of those activities.

Policies establish high-level responsibilities and authority for carrying out important administrative functions which are outside the scope of the QAPD. Procedures establish practices forcertain activities which are common to all SCE&G organizations performing those activities so that theactivity is controlled and carried out in a manner that meets QAPD requirements.

Procedures specific to asite, organization, or group establish detailed implementation requirements and methods, and may beused to implement policies or be unique to particular functions or work activities.

1.1 Scope / Applicability The QAPD applies to operational phase activities affecting the quality and performance of safety-related structures,

systems, and components, including, but not limited to:Designing Storing Operating Maintaining Procuring ErectingRepairing Fabricating Installing Modifying Cleaning Inspecting Refueling Handling TestingTraining Shipping StartupDecommissioning Receiving Safety-related SSCs, under the control of the QAPD, are identified by design documents.

The technical aspects of these items are considered when determining program applicability, including, as appropriate, the item's design safety function.

The QAPD may be applied to certain activities where regulations otherthan 10 CFR 50 and 10 CFR 72, Subpart G establish QA requirements for activities within their scope.The policy of SCE&G is to assure a high degree of availability and reliability of the V. C. Summer NuclearStation Unit I while ensuring the health and safety of its workers and the public. To this end, selectedelements of the QAPD are also applied to certain equipment and activities that are not safety-related, I

V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1but support safe, economic, and reliable plant operations, or where other NRC guidance establishes quality assurance requirements.

Implementing documents establish program element applicability.

The definitions provided in ASME NQA-1-1994, Part I, Section 1.4, apply to select terms as used in thisdocument.

Additional definitions are provided in Part V, Section 1.0 of this QAPD.2 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1PART II QAPD DETAILSSECTION 1 ORGANIZATION This Section describes the SCE&G organizational structure, functional responsibilities, levels of authority and interfaces for establishing, executing, and verifying QAPD implementation.

The organizational structure includes Corporate Support/off-site and on-site functions for Nuclear Plant Operations including interface responsibilities for multiple organizations that perform quality-related functions.

Implementing documents assign more specific responsibilities and duties, and define the organizational interfaces involved in conducting activities and duties within the scope of the OAPD. Management givescareful consideration to the timing, extent and effects of organizational structure changes.SCE&G Vice President Nuclear Operations (VPNO) is responsible to size the Quality Assurance organization commensurate with the duties and responsibilities assigned.

The SCE&G Nuclear Operations organization is responsible for implementing and supporting the QAPD.Several organizations within SCE&G Nuclear Operations support New Nuclear Deployment throughimplementing and supporting the QAPD. These organizations

include, but are not limited to theProcurement Group, Engineering,

Training, Security, Emergency Preparedness, and SCANA Corporate Services.

During the operating life of V. C. Summer Nuclear Station (VCSNS) Unit 1, SCE&G may delegate the workof executing portions of the QAPD. However; SCE&G shall retain the responsibility for its overalleffectiveness.

Outside organizations that perform activities in support of the design, procurement, fabrication, modification, inspection, test or maintenance of the safety related SSCs of the plant are required to workunder an approved QAPD.The following sections describe the reporting relationships, functional responsibilities and authorities fororganizations implementing and supporting the SCE&G QAP. The SCE&G Corporate Organization and theOperating Plant Management Organization are shown in Figures 11.1-1 and 11.1-2.1.1 SCE&G Corporate Management Organization 1.1.1 SCANA Chief Executive Officer (CEO)The Chief Executive Officer (CEO) has the ultimate responsibility for the safe and reliable operation ofeach nuclear unit owned and/or operated by SCE&G. The CEO is responsible for the overall direction andmanagement of the corporation, and the execution of the company policies, activities, and affairs.

TheCEO is assisted by the Executive Vice President, Generation (EVPG), and other executive staff in thenuclear division of the corporation.

1.1.2 SCE&G President

& Chief Operating Officer (COO)The positions of President

& Chief Operating Officer (COO) of SCE&G and the Executive Vice President, Generation (EVPG) are held by the same entity/office with dual responsibilities and reports to the CEO.3 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1As delegated from the CEO, the President

& Chief Operating Officer (COO) is responsible for the design,construction, and operation of SCE&G's nuclear plants.1.1.3 Executive Vice President, Generation (EVPG)The positions of President

& Chief Operating Officer (COO) of SCE&G and Executive Vice President, Generation (EVPG) are held by the same entity/office with dual responsibilities and reports to the CEO.The EVPG reports to the CEO through the COO. The EVPG is responsible for electric generation, overallplant nuclear safety, and takes the measures needed to provide acceptable performance of the staff inoperating, maintaining, and providing technical support to the nuclear site. The EVPG delegates authority and responsibility for the operation and support of the site through the Senior Vice President, NuclearOperations (SVP/CNO).

It is the responsibility of the EVPG to provide guidance and direction such thatsafety-related activities, including engineering, construction, operations, operations support,maintenance, and planning, are performed following the guidelines of the quality assurance program.The EVPG is responsible for new nuclear plant licensing, design, and construction through the SVP/CNO.1.1.4 Senior Vice President

& Chief Nuclear Officer (SVP/CNO)

The SVP/CNO reports to the EVPG. The SVP/CNO serves as the Chief Nuclear Officer (CNO) and isresponsible for the safe operation of all current nuclear plant operations along with the design, licensing, and construction of new nuclear plants. The SVP/CNO delegates authority and responsibility for theoperation and support of the operating nuclear plants through the VPNO. The SVP/CNO is responsible for new nuclear plant licensing, design, and construction via the Vice President, New Nuclear Operations (VPNNO) who maintains control of nuclear plant construction through construction completion.

1.1.5 Vice President, Nuclear Operations (VPNO)The Vice President, Nuclear Operations reports to the SVP/CNO and is responsible for the overall safeand efficient operation of VCSNS operating plants and for the implementation of quality assurance requirements in the areas specified by the QAPD.1.1.6 Vice President, New Nuclear Operations (VPNNO)The VPNNO reports to the SVP/CNO and directs the planning and development of the NND staff andorganizational resources.

The VPNNO is responsible for establishing and managing the Engineering, Procurement and Construction contract (EPC) for the development of new nuclear power plants.1.1.7 Director, Nuclear TrainingThe Director, Nuclear Training, reports directly to the SVP/CNO and has the overall responsibility for theaccredited and non-accredited training programs at VCSNS. This includes the responsibility for providing the required training for personnel within VCSNS Units 1, 2 and 3. This position is responsible for themanagement of all nuclear learning programs for VCSNS Units 1, 2 and 3. The position is also part of theSenior Management team that provides overall strategic direction for nuclear operations.

4 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 11.1.7.1 Manager, Nuclear Training (Unit 1)The Manager, Nuclear Training, reports directly to the Director, Nuclear Training, and is responsible forthe operations-related training programs.

This includes the operation, certification, and coordination ofthe maintenance and modification of the VCSNS Unit 1 Simulators.

This also includes training programsfor manager/technical staff personnel, shift engineers/technical

advisors, and licensed and non-licensed operators.

The Manager, Nuclear Training, is also responsible for the maintenance and technical trainingprograms for VCSNS Unit 1. This includes training in the areas of Maintenance, Health Physics, Chemistry, and Engineering.

1.1.7.2 Manager, Nuclear Training (NND)The Manager, Nuclear Training, reports directly to the Director, Nuclear Training, and is responsible forthe operations-related training programs.

This includes the operation, certification, and coordination ofthe maintenance and modification of the VCSNS Units 2 and 3 Simulators.

This also includes trainingprograms for manager/technical staff personnel, shift engineers/technical

advisors, and licensed andnon-licensed operators.

The Manager, Nuclear Training, is also responsible for maintenance andtechnical training programs for VCSNS Units 2 and 3. This includes training in the areas of Maintenance, Health Physics, Chemistry, and Engineering.

1.2 VCSNS Unit 1 Operating Plant Management Organization The operating organization is responsible for keeping the VPNO abreast of plant conditions and verifying that the day to day operations of the plant are conducted safely and in accordance with all administrative controls including the QAPD.1.2.1 General Manager, Nuclear Plant Operations (GMNPO)The GMNPO reports to the VPNO, and is responsible for overall safe operation of the plant, and hascontrol over those onsite activities necessary for safe operation and maintenance of the plant including operations, chemistry, maintenance, and modification.

Additionally, the GMNPO has overallresponsibility for occupational and public radiation safety. The GMNPO is the Chairman of the PlantSafety Review Committee (PSRC). The GMNPO is also referred to as the Plant Manager.1.2.1.1 Manager, Operations The Manager, Operations, is responsible for the day to day operation of the plant in a safe and efficient manner in compliance with the operating license.

Manager, Operations is responsible for review andimplementation of normal and emergency training and retraining programs.

He/she has the assistance ofthe Operations Supervisor.

In the absence of the Manager, Operations, the Operations Supervisor willassume his/her responsibilities.

1.2.1.2 Manager, Maintenance ServicesThe Manager, Maintenance

Services, is responsible for establishing and implementing the programs formaintenance activities to ensure the continued safe, efficient, and reliable operation of the V. C. Summer5 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1Station.

Manager, Maintenance Services is responsible to ensure the Station is maintained in compliance with company policies as they relate to Maintenance Services.

1.2.1.3 Manager, Chemistry ServicesThe Manager, Chemistry Services is responsible for directing and coordinating in-plant chemistry andwater treatment programs.

The Manager, Chemistry

Services, has the responsibility of supervising the Chemistry Supervisors and theChemistry Specialists.

Through this staff, the Manager, Chemistry Services is charged with implementing the chemistry

programs, controlling non-rad releases, maintaining the quality of fluids in various plantsystems within the prescribed limits, operating water treatment facilities, ensuring that writtenprocedures within his/her scope of supervision reflect the criteria of performance standards established by regulatory

agencies, and ensuring that these procedures are followed.

He/she is responsible forensuring that training and retraining of Chemistry personnel are performed as scheduled by the NuclearTraining Department.

The Chemistry Specialists, under the direction of the Chemistry Supervisors, perform tasks incident to the categories of work implemented by the Manager, Chemistry Services.

1.2.1.4 Manager, Health Physics and Safety ServicesThe Manager, Health Physics and Safety Services (MHPSS),

is responsible for directing and coordinating station health physics and radwaste programs.

In addition, the MHPSS establishes occupational safetyand health policy as well as providing technical support to plant staff concerning occupational health andsafety issues.The MHPSS is responsible for directing and coordinating health physics, count room and radwasteprocessing, environmental monitoring, and dosimetry activities.

He/she plans, coordinates and / ordirects supportive station activities with regard to the Radiation Protection, Radiological Effluent Control,Environmental Surveillance, Dosimetry, Radwaste Processing and Disposal, and Analytical programs.

Through evaluations, he/she advises management on program status issues related to these programsand technical guidance for issue resolution.

He/she has direct access to the General Manager, NuclearPlant Operations for matters concerning any phase relative to radiological protection and occupational safety.The MHPSS has the responsibility of supervising the activities of the Health Physics Supervisors and theHealth Physics Specialists as well as the subcontractor support.

Through this staff, the Manager, HPSS ischarged with controlling the exposure of plant personnel and the public to radiation, preventing thespread of radioactive contamination, ensuring that written procedures reflect the criteria for establishing performance standards, and ensuring that these procedures are followed.

He/she is responsible forensuring that training and retraining of health physics personnel are performed as well as providing health physics services, radiological engineering expertise, and periodic health physics reviews for allplant personnel.

He/she is responsible for the timely submission of reports pertaining to health physics,radioactive waste releases to the environment, and other areas as required.

6 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 11.2.2 General Manager, Nuclear Support Services (GMNSS)The GMNSS reports to the VPNO, and is overall responsible for Nuclear Licensing; Emergency Services; the Planning and Scheduling processes; Outage Planning; and the scheduling of modification,

testing, andinspection activities.

The GMNSS is responsible for directing the Manager, Nuclear Licensing, to develop and maintaineffective communications with and in response to regulatory authorities; directing the Manager,Emergency Services to ensure emergency plans, programs and procedures are being properly maintained and implemented to meet the requirements of SCE&G and the regulatory authorities; directing theManager, Planning

& Scheduling, to ensure that maintenance activities are properly planned to minimizeunavailability of Safety-Related SSCs; and directing the Outage Manager to ensure that refueling outagesare properly

planned, scheduled, and executed.

1.2.2.1 Manager, Nuclear Licensing The Manager, Nuclear Licensing is responsible for the development and implementation of the SCE&Gnuclear licensing policy while ensuring that applicable safety and environmental regulatory standards aremet. Additionally, the Manager, Nuclear Licensing is responsible for reviewing general safety questions, safety issues, and safety goals; Probabilistic Risk and Safety Analyses

Programs, NRC industry issues andvendor correspondence for insight on industry activities and practices, and evaluating the potential impact of generic regulatory issues. Working together with all SCE&G organizations,

Manager, NuclearLicensing coordinates the generation, amendment, and distribution of various licensing documents, suchas the FSAR, and development of Licensee Event Reports (LERs) per 10 CFR 50.73 and other writtenreports required by regulations or the Operating License.

As the principal interface with the NuclearRegulatory Commission and other regulatory

agencies, NL ensures that the respective directives,

requests, and information documents are distributed to the proper organizations and that any necessary responses are developed and submitted within the prescribed time frame. Also reporting to theManager, Nuclear Licensing is the PRA group. The PRA group is responsible for the development andmaintenance of PRA models used to support risk informed applications and for providing risk insights to:processes which control risk informed applications, proposed changes to plant design and licensing basis,maintenance activities, and off normal plant events or conditions.

1.2.2.2 Manager, Planning

& Scheduling The Manager, Planning

& Scheduling is responsible for the scheduling of maintenance, modification, testand inspection activities within the constraints imposed by operational, regulatory, and system loadrequirements.

1.2.2.3 Manager, Emergency PlanningThe Manager, Emergency Planning is responsible for the effective

planning, coordination, andmanagement of the V. C. Summer Nuclear Plant Emergency Preparedness Program.

Additional responsibilities include ensuring that the emergency plans, programs, and procedures are being properlymaintained and implemented to meet the requirements of SCE&G and the regulatory authorities.

7 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 11.2.2.4 Outage ManagerThe Outage Manager is responsible for planning, scheduling, and executing refueling outages within theestablished outage schedule and budget.1.2.2.5 Workweek Management Workweek Management organization is responsible for and serves as primary organizational interface with outside organizations for management, engineering, planning and implementation of capitalprojects.

The organization provides coordination and interface for resolving conflicts and delays forexecution of activities as necessary for project implementation.

1.2.3 General Manager, Engineering Services (GMES)The GMES is the onsite lead position for engineering and reports to the VPNO. The GMES is responsible for engineering activities related to the operation or maintenance of the plant and design changeimplementation support activities.

The GMES directs functional managers responsible for plant supportengineering, design engineering, and materials and procurement.

1.2.3.1 Manager, Design Engineering The Manager, Design Engineering is responsible for resolving design issues, onsite development ofdesign-related change packages and plant modifications, managing contractors who may perform design-related activities, maintaining the configuration control program, and developing and maintaining engineering programs such as accident analysis activities and ISI.The Nuclear Design and Analysis Engineers, who report to the Manager, Design Engineering, ensure thatreactor engineering tests are performed in accordance with plant procedures and manuals and ensuringthat current industry techniques are utilized to monitor and reduce megawatt loss. The Core DesignEngineers are responsible for evaluating, designing, and managing core design changes.1.2.3.2 Manager, Plant Support Engineering The Manager, Plant Support Engineering supervises a technical staff of engineers and other engineering specialists and coordinates interfaces with other groups as necessary.

The Manager, Plant SupportEngineering is responsible for providing direction and guidance to system engineers for monitoring theefficiency and proper operation of balance of plant and reactor systems, planning programs forimproving equipment performance, reliability, or work practices; overseeing operational tests andanalyzing the results; and maintaining engineering programs such as IST, valve testing, maintenance rule,piping erosion/corrosion, and system/equipment reliability.

1.2.3.3 Manager, Materials

& Procurement The Manager, Materials

& Procurement (MMPR) is responsible for all site purchasing activities, SupplierQuality Audits, Receipt Inspections, and Procurement Engineering functions.

The MMPR is alsoresponsible for providing sufficient and proper materials to support the needs of the plant and8 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1performing related activities including procedure development, procurement and materials

storage, andsupply system database management.

1.2.4 General Manager, Organizational Development and Effectiveness (GMOD&E)The GMOD&E reports to the VPNO. The GMOD&E directs managers responsible for Nuclear Protection

Services, Quality Systems, overall coordination of station Information Systems Technology activities, Change Management, Organizational Development

& Performance and Corrective Action Program, andsupervisor for Records and Document Control.

Additionally, the GMOD&E holds the position andresponsibilities of Chairman of the Corrective Action Review Board.1.2.4.1 Manager, Organizational Development

& Performance The Manager, Organizational Development

& Performance (MOD&P),

is responsible for directing andcoordinating the station organizational effectiveness

programs, to include human performance, operating experience, root cause, corrective action, self-assessment, management observation, trendingand benchmarking programs to effectively develop and coordinate these programs to aid in thedevelopment of a strong learning organization and to promote continuous improvement.

The MOD&P has the responsibility of supervising the Corrective Action Supervisor and HumanPerformance Supervisor.

Through this staff, the MOD&P is responsible for the implementation of theOD&P organizational effectiveness programs and ensuring written procedures accurately reflect thecriteria for establishing performance standards and are adhered to. The incumbent is responsible forensuring that training and retraining of the OD&P personnel is performed and providing OD&P expertise and service to the station.

This incumbent establishes and maintains rapport with plant personnel, encouraging the reporting of problems and events that can adversely affect plant performance at the V.C. Summer Nuclear Station Unit 1.The MOD&P is responsible for performing OD&P improvement initiatives and assists in identifying andtraining of human error reduction techniques for all station employees.

The incumbent develops andparticipates in activities to identify human error challenges and opportunities for improvement, communicates to the station results to be achieved and the part they play in obtaining them, facilitates group learning sessions with supervisors and managers to identify

barriers, develops goals and measuresfor monitoring improvement plan results and provides results to management in periodic

reports, tracksinitiatives and assists in the development of measures for less than desirable results and ensures stronginterfaces and exchanges of information exists with others involved in improvement activities to ensureeffective integration of improvement efforts.1.2.4.2 Manager, Nuclear Protection ServicesThe Manager, Nuclear Protection

Services, is responsible for management control activities of NuclearSecurity and the access control and fitness for duty program.

Reporting to the Manager, NuclearProtection Services is the Supervisor, Operations

Security, and the Supervisor, Access Control/Fitness ForDuty.The Manager, Nuclear Protection

Services, is responsible for physical

security, security force operations, training and qualification

programs, and maintenance and testing activities for security equipment forthe V. C. Summer Station.9 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 11.2.4.3 Manager, Quality SystemsThe Manager, Quality Systems (MQS), is responsible for audit, surveillance, and inspection of NuclearOperations activities to ensure that all safety-related activities are performed in accordance with aquality assurance program which meets the criteria of 10 CFR 50, Appendix B and 10 CFR 72, Subpart G.Quality Assurance and Quality Control services may be subcontracted as needed. Further detail can befound in Section 18 of the QAPD. The MQS is responsible for independent oversight activities performed during refueling

outages, startup activities, and normal and off-normal operational activities at the V. C.Summer Station.The responsibility for developing, maintaining and verifying effective implementation of the QAPD restswith the MQS. The MQS through the GMOD&E has the responsibility and authority to report qualitymatters to any management level necessary within SCE&G in order to establish timely and effective corrective action. The MQS is authorized by this QAPD to identify concerns adverse to quality directly tothe VPNO as indicated by the dotted line reporting shown on Figure 11.1-2 "Unit 1 Plant Management Organization."

To ensure independence is maintained between QA and line management, QA shallbe excluded from participation in line functions, assessments, or evaluations.

Independence shallnot be subordinated to achieve cost or schedule objectives.

1.2.4.4 Manager, Corporate Information and Systems Technology The Manager, Corporate Information and Systems Technology reports through a dotted-line to theGMOE and is responsible for ensuring station computer operation and records applications are installed and maintained per approved procedures and working with departments to ensure regulatory compliance.

1.2.4.5 Supervisor

Records, Documents, and Reproduction The Supervisor

Records, Documents, and Reproduction is responsible for providing for acceptable records storage systems and locations; obtaining, filing and maintaining auditable records; andmaintenance of the Station document control program.1.2.5 Manager, Business and Financial ServicesThe Manager, Business and Financial

Services, is responsible for project prioritization, businessdevelopment including budget and business plan development, and tracking and coordination withexternal industry groups.1.2.6 Corporate ServicesThe SCANA/SCE&G Corporate Services organizations are responsible for supporting the NuclearOrganization by performing activities related to accounting, safety and health, and environmental services where applicable.

These organizations will serve the Nuclear Organization through "dotted-line" reporting to the Nuclear Organization managers.

10 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 11.2.6.1 Manager, Nuclear Finance Administration The Manger, Nuclear Finance Administration, is responsible for time and attendance management, fatigue rule management, capital and operating

budgets, project support functions, and site widefinancial analytical support and budget adherence.

1.3 Quality Assurance The SCE&G Quality Assurance Organization is responsible for independently planning and performing activities to verify the development and effective implementation of the SCE&G QAPD, including but notlimited to engineering, licensing, document

control, corrective action program, and procurement thatsupport the operational phase of the V. C Summer Nuclear Station.

This verification of development andeffective implementation of the SCE&G QAPD allows SCE&G Nuclear Operations to support New NuclearDeployment activities 1.4 Authority to Stop WorkQuality assurance and inspection personnel have the authority, and the responsibility, to stop work inprogress which is not being done in accordance with approved procedures or where safety or SSCintegrity may be jeopardized.

This extends to off-site work performed by suppliers furnishing safety-related materials and services to SCE&G.1.5 Quality Assurance Organizational Independence For operational phase activities, independence shall be maintained between the organization ororganizations performing the checking (quality assurance and control) functions and the organizations performing the functions.

This provision is not applicable to design review / verification.

1.6 NOA-1-1994 Commitment In establishing its organizational structure, SCE&G commits to compliance with NQA-1-1994, Basic Requirement 1 and Supplement 1S-1.11 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1II*Multiple Responsibilities held by oneindividual.

IIDirectorNuclear TrainingIILViePeidn ie rsdnNula prtosNwNcerOeain Figure 11.1-1 SCE&G Corporate Organization 12 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1m- -- i-Supports NNO In participating onNEI AP1000 HP Task Force** Supports NND in the area of Emergency Planning--* Dotted line per Section 1.2.4.3 toindicate MQS authority to reportquality matters directly to the VPNO.Supports NND in the procurement of safety and non-safety relatedmaterials, equipment, and services.

Supports NND CIS personnel in theperformance of external activities by the participation of NUPIC audits todetermine contractor/vendor conformance to their QA program.Figure 11.1-2 Unit 1 Plant Management Organization 13 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1SECTION 2 QUALITY ASSURANCE PROGRAMSCE&G has established the necessary measures and governing procedures to implement the QAP asdescribed in the QAPD. SCE&G is committed to implementing the QAP in all aspects of work that areimportant to the safety of the nuclear plant as described and to the extent delineated in the QAPD.Further, SCE&G ensures through the systematic process described herein that its suppliers of safety-related equipment or services meet the applicable requirements of 10 CFR 50, Appendix B. Seniormanagement is regularly apprised of the adequacy of implementation of the QAP through the auditfunctions described in Part II, Section 18.The objective of the QAP is to assure that the V. C. Summer Nuclear Station Unit 1 is designed andoperated in accordance with governing regulations and license requirements.

The program is based onthe requirements of ASME NQA-1-1994, "Quality Assurance Requirements for Nuclear FacilityApplications,"

as further described in this document.

The QAP applies to those quality-related activities that involve the functions of safety-related structures,

systems, and components (SSCs) associated withthe design, maintenance,

testing, and safe operation of the nuclear facility and managerial andadministrative controls as described in the Final Safety Analysis Report. A list or system that identifies SSCs and activities to which this program applies is maintained at the V. C. Summer Nuclear Station.

Costand scheduling functions do not prevent proper implementation of the QAP.As described in Part III of the QAPD, specific program controls are applied to non-safety related SSCs, forwhich 10 CFR 50, Appendix B and 10 CFR 72, Subpart G, is not applicable, that are significant contributors to plant safety. The specific program controls consistent with applicable sections of the QAPD are appliedto those items in a selected manner, targeted at those characteristics or critical attributes that render theSSC a significant contributor to plant safety.Delegated responsibilities may be performed under a suppliers or principal contractors QAP, providedthat the supplier or principle contractor has been approved as a supplier in accordance with the QAPD.Periodic audits and assessments of supplier QA programs are performed to assure compliance with thesupplier's or principle contractors QAPD and implementing procedures.

In addition, routine interfaces with the supplier's personnel provide added assurance that quality expectations are met.For the operational phase, the QAPD applies to those operational and SCE&G activities that can affect,either directly or indirectly, the safety-related site characteristics or analysis of those characteristics.

In general, the program requirements specified herein are detailed in implementing procedures that areeither SCE&G implementing procedures, or supplier implementing procedures governed by a supplierquality program.A grace period of 90 days may be applied to provisions that are required to be performed on a periodicbasis unless otherwise noted. Annual evaluations and audits that must be performed on a triennial basisare examples where the 90 day general period could be applied.

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

The "clock" for an activity is reset backwards byperforming the activity early. Audit schedules are based on the month in which the audit starts.14 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 12.1 Responsibilities Personnel who work directly or indirectly for SCE&G are responsible for achieving acceptable quality inthe work covered by the QAPD. This includes the activities delineated in Part I, Section 1.1. SCE&Gpersonnel performing verification activities are responsible for verifying the achievement of acceptable quality.

Activities governed by the QAPD are performed as directed by documented instructions, procedures and drawings that are of a detail appropriate for the activity's complexity and effect onsafety. Instructions, procedures and drawings specify quantitative or qualitative acceptance criteria asapplicable or appropriate for the activity, and verification is against these criteria.

Provisions areestablished to designate or identify the proper documents to be used in an activity, and to ascertain thatsuch documents are being used. The Manager, Quality Systems is responsible to verify that processes and procedures comply with QAPD and other applicable requirements, that such processes orprocedures are implemented, and that management appropriately ensures compliance.

2.2 Delegation of WorkSCE&G retains and exercises the responsibility for the scope and implementation of an effective QAPD.Positions identified in Part II,Section I, may delegate all or part of the activities of planning, establishing, and implementing the program for which they are responsible to others, but retain the responsibility forthe program's effectiveness.

Decisions affecting safety are made at the level appropriate for its natureand effect, and with any necessary technical advice or review.2.3 Periodic Review of the Quality Assurance ProgramManagement of those organizations implementing the QA program, or portions

thereof, assess theadequacy of that part of the program for which they are responsible to assure its effective implementation at least once every two years or at least once during the life of the activity, whichever isshorter.2.4 Issuance and Revision to Quality Assurance ProgramAdministrative control of the QAPD will be in accordance with 10 CFR 50.54(a).

Changes to the QAPD areevaluated by the Manager, Quality Systems to ensure that such changes do not degrade previously approved quality assurance controls specified in the QAPD. This document shall be revised asappropriate to incorporate additional QA commitments that may be established during the operating lifeof the V. C. Summer Nuclear Station Unit 1. New revisions to the document will be reviewed, at aminimum, by the Manager, Quality Systems, and approved by the Senior Vice President, NuclearOperations/CNO.

Regulations require that the Final Safety Analysis Report (FSAR) include, among other things, themanagerial and administrative controls to be used to assure safe operation, including a discussion of howthe applicable requirements of Appendix B will be satisfied.

In order to comply with this requirement, theFSAR references the QAPD and, as a result, the requirements of 10 CFR 50.54(a) is satisfied by, andapplies to, the QAPD.15 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision I2.5 Personnel Qualifications Personnel assigned to implement elements of the QAPD shall be capable of performing their assignedtasks. To this end, SCE&G establishes and maintains formal indoctrination and training programs forpersonnel performing, verifying, or managing activities within the scope of the QAPD to assure thatsuitable proficiency is achieved and maintained.

Plant and support staff minimum qualification requirements are as delineated in the V. C. Summer Technical Specifications.

Other qualification requirements may be established but will not reduce those required by Technical Specifications.

Sufficient managerial depth is provided to cover absences of incumbents.

When required by code,regulation, or standard, specific qualification and selection of personnel is conducted in accordance withthose requirements as established in the applicable SCE&G procedures.

Indoctrination includes theadministrative and technical objectives, requirements of the applicable codes and standards, and theQAPD elements to be employed.

Training for positions identified in 10 CFR 50.120 is accomplished according to programs accredited by the National Nuclear Accrediting Board of the National Academy ofNuclear Training that implement a systematic approach to training.

Records of personnel training andqualification are maintained.

The minimum qualifications of the Managers, Quality Systems and Materials

& Procurement arethat they have an engineering or related science degree and a minimum of four years of relatedexperience including two years of nuclear power plant experience, one year of supervisory ormanagement experience, and one year of the experience is in performing quality verification activities.

Special requirements shall include management and supervisory skills and experience or training inleadership, interpersonal communication, management responsibilities, motivation of personnel, problem analysis and decision making, and administrative policies and procedures.

Individuals who donot possess these formal education and minimum experience requirements should not be eliminated automatically when other factors provide sufficient demonstration of their abilities.

These other factorsare evaluated on a case-by-case basis and approved and documented by senior management.

The minimum qualifications of the individuals responsible for planning, implementing and maintaining the programs for the QAPD are that each has a high school diploma or equivalent and has a minimum ofone year of related experience.

Individuals who do not possess these formal education and minimumexperience requirements should not be eliminated automatically when other factors provide sufficient demonstration of their abilities.

These other factors are evaluated on a case-by-case basis and approvedand documented by senior management.

2.6 NQA-1-1994 Commitment

/ Exceptions In establishing qualification and training

programs, SCE&G commits to compliance with NQA-1-1994, Basic Requirement 2 and Supplements 2S-1, 2S-2, 2S-3 and 2S-4, with the following clarifications andexceptions:

NQA-1-1994, Supplement 2S-1-Supplement 2S-1 will include use of the guidance provided in Appendix 2A-1 the sameas if it were part of the Supplement.

The following two alternatives may be applied tothe implementation of this Supplement and Appendix:

16 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1(1) In lieu of being certified as Level I, II, or III in accordance with NQA-1-1994, personnel that perform independent quality verification inspections, examinations, measurements, or tests of material,

products, or activities will be required topossess qualifications equal to or better than those required for performing the taskbeing verified; and the verification is within the skills of these personnel and/or isaddressed by procedures.

These individuals will not be responsible for the planningof quality verification inspections and tests (i.e., establishing hold points andacceptance criteria in procedures, and determining who will be responsible forperforming the inspections),

evaluating inspection training

programs, nor certifying inspection personnel.

(2) A qualified engineer may be used to plan inspections, evaluate the capabilities of aninspector, or evaluate the training program for inspectors.

For the purpose of thesefunctions, a qualified engineer is one who has a baccalaureate in engineering in adiscipline related to the inspection activity (such as electrical, mechanical, civil) andhas a minimum of five years engineering work experience with at least two years ofthis experience related to nuclear facilities.

NQA-1-1994, Supplement 2S-2In lieu of Supplement 2S-2, for qualification of nondestructive examination personnel, SCE&G will follow the applicable standard cited in the version(s) of Section III andSection Xl of the ASME Boiler and Pressure Vessel Code approved for use at the V. C.Summer Nuclear Station Unit 1.* NQA-1-1994, Supplement 2S-3The requirement that prospective Lead Auditors have participated in a minimum of five(5) audits in the previous three (3) years is replaced by the following, "The prospective lead auditor shall demonstrate his/her ability to properly implement the audit process,as implemented by SCE&G, to effectively lead an audit team, and to effectively organizeand report results, including participation in at least one nuclear audit within the yearpreceding the date of qualification."

17 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1SECTION 3 DESIGN CONTROLSCE&G establishes and implements a process to control the design, design changes and temporary modifications (e.g., temporary bypass lines, electrical jumpers and lifted wires, and temporary setpoints) of items that are subject to the provisions of the QAPD.The design process includes provisions to control design inputs, outputs,

changes, interfaces, records andorganizational interfaces within SCE&G and with suppliers.

These provisions assure that design inputs(such as design bases and the performance, regulatory,

quality, and quality verification requirements) arecorrectly translated into design outputs (such as analyses, specifications,

drawings, procedures, andinstructions) so that the final design output can be related to the design input in sufficient detail topermit verification.

Design change processes and the division of responsibilities for design-related activities are detailed in SCE&G and supplier procedures.

The design control program includes interface controls necessary to control the development, verification,

approval, release, status, distribution, andrevision of design inputs and outputs.

Design changes and disposition of nonconforming items as "use asis" or "repair" are reviewed and approved by the SCE&G design organization or by other organizations soauthorized by SCE&G.Design documents are reviewed by individuals knowledgeable in QA to ensure the documents containthe necessary QA requirements.

3.1 Design Verification SCE&G design processes provide for design verification to ensure that items and activities subject to theprovisions of the QAPD are suitable for their intended application, consistent with their effect on safety.Design changes are subjected to these controls, which include verification measures commensurate withthose applied to original plant design.Design verifications are performed by competent individuals or groups other than those who performed the original design but who may be from the same organization.

The verifier shall not have taken part inthe selection of design inputs, the selection of design considerations, or the selection of a singular designapproach, as applicable.

This verification may be performed by the originator's supervisor provided thesupervisor did not specify a singular design approach, rule out certain design considerations, and did notestablish the design inputs used in the design, or if the supervisor is the only individual in theorganization competent to perform the verification.

If the verification is performed by the originator's supervisor, the justification of the need is documented and approved in advance by management.

The extent of the design verification required is a function of the importance to safety of the item underconsideration, the complexity of the design, the degree of standardization, the state-of-the-art, and thesimilarity with previously proven designs.

This includes design inputs, design outputs, and designchanges.

Design verification procedures are established and implemented to assure that an appropriate verification method is used, the appropriate design parameters to be verified are chosen, the acceptance criteria are identified, and the verification is satisfactorily accomplished and documented.

Verification methods may include, but are not limited to, design reviews, alternative calculations and qualification testing.

Testing used to verify the acceptability of a specific design feature demonstrates acceptable performance under conditions that simulate the most adverse design conditions expected for item'sintended use.18 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1SCE&G normally completes design verification activities before the design outputs are used by otherorganizations for design work, and before they are used to support other activities such as procurement, manufacture, or installation.

When such timing cannot be achieved, the design verification is completed before relying on the item to perform its intended design or safety function.

3.2 Design RecordsSCE&G maintains records sufficient to provide evidence that the design was properly accomplished.

These records include the final design output and any revisions

thereto, as well as record of theimportant design steps (e.g., calculations, analyses and computer programs) and the sources of inputthat support the final output.Plant design drawings reflect the properly reviewed and approved configuration of the plant.3.3 Computer Application and Digital Equipment SoftwareThe QAPD governs the development, procurement,

testing, maintenance, and use of computerapplication and digital equipment software when used in safety-related applications and designated non-safety-related applications.

SCE&G and suppliers are responsible for developing, approving, and issuingprocedures, as necessary, to control the use of such computer application and digital equipment software.

The procedures require that the application software be assigned a proper quality classification and that the associated quality requirements be consistent with this classification.

Each application software and revision thereto is documented and approved by authorized personnel.

The QAPD is alsoapplicable to the administrative functions associated with the maintenance and security of computerhardware where such functions are considered essential in order to comply with other QAPDrequirements such as QA records.3.4 Setpoint ControlInstrument and equipment setpoints that could affect nuclear safety shall be controlled in accordance with written instructions.

As a minimum, these written instructions shall:1. Identify responsibilities and processes for reviewing, approving, and revising setpoints and setpoint changes originally supplied by the A/E for V. C. Summer Nuclear Station Unit 1 andthe station's technical staff;2. Ensure that setpoints and setpoint changes are consistent with design and accident analysisrequirements and assumptions;

3. Provide for documentation of setpoints, including those determined operationally; and4. Provide for access to necessary setpoint information for personnel who write or reviseplant procedures, operate or maintain plant equipment, develop or revise designdocuments, or develop or revise accident analyses.

3.5 NQA-1-1994 Commitment In establishing its program for design control and verification, SCE&G commits to compliance with NQA-1-1994, Basic Requirement 3, and Supplement 3S-1, and the standards for computer software contained in Subpart 2.7.19 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 13.6 Design Control Commitment (Section 3)The requirement that design documents are reviewed by individuals knowledgeable in QA to ensure thedocuments contain the necessary QA requirements is not applicable to VCSNS Operating Unit I asdiscussed in 10 CFR 50.34(f)(3)(iii)(H).

20 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1SECTION 4 PROCUREMENT DOCUMENT CONTROLSCE&G has established the necessary measures and governing procedures to assure that purchased items and services are subject to appropriate quality and technical requirements.

Procurement document changes shall be subject to the same degree of control as utilized in the preparation of theoriginal documents.

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

" Applicable technical, regulatory, administrative, quality and reporting requirements (such asspecifications, codes, standards, tests, inspections, special processes, and 10 CFR 21) areinvoked for procurement of items and services.

10 CFR 21 requirements for posting,evaluating, and reporting will be followed and imposed on suppliers when applicable.

Applicable design bases and other requirements necessary to assure adequate quality shall beincluded or referenced in documents for procurement of items and services.

To the extentnecessary, procurement documents shall require suppliers to have a documented QOA programthat is determined to meet the applicable requirements of 10 CFR 50, Appendix B and 10 CFR72, Subpart G, as appropriate to the circumstances of procurements (or the supplier may workunder SCE&G's approved QA program).

Reviews of procurement documents shall be performed by personnel who have access to pertinent information and who have an adequate understanding of the requirements and intent of theprocurement documents.

4.1 NQA-1-1994 Commitment I Exceptions In establishing controls for procurement, SCE&G commits to compliance with NQA-1-1994, Basic Requirement 4 and Supplement 4S-1, with the following clarifications and exceptions:

NQA-1 -1994, Supplement 4S-1:-Section 2.3 of this Supplement 4S-1 includes a requirement that procurement documents require suppliers to have a documented QAP that implements NQA-1-1994, Part I. In lieu of this requirement, SCE&G may require suppliers to have adocumented supplier QAP that is determined to meet the applicable requirements of10 CFR 50, Appendix B and 10 CFR 72, Subpart G, as appropriate to the circumstances of the procurement;

-With regard to service performed by a supplier, SCE&G procurement documents mayallow the supplier to work under the SCE&G QAP, including implementing procedures, in lieu of the supplier having its own QAP;21 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1-Section 3 of this supplement 4S-1 requires procurement documents to be reviewedprior to bid or award of contract.

The quality assurance review of procurement documents is satisfied through review of the applicable procurement specification, including the technical and quality procurement requirements, prior to bid or awardof contract.

-Procurement document changes (e.g., scope, technical or quality requirements) willalso receive the quality assurance review; and-Procurement documents for Commercial Grade Items that will be procured by SCE&Gfor use as safety-related items shall contain technical and quality requirements suchthat the procured item can be appropriately dedicated.

22 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1SECTION 5 INSTRUCTIONS, PROCEDURES, AND DRAWINGSSCE&G has established the necessary measures and governing procedures to ensure that activities affecting quality are prescribed by and performed in accordance with instructions, procedures ordrawings of a type appropriate to the circumstances and which, where applicable, include quantitative orqualitative acceptance criteria to implement the QAPD as described in the QAPD. Such documents areprepared and controlled according to Part II, Section 6. In addition, means are provided to disseminate tothe staff instructions of both general and continuing applicability, as well as those of short-term applicability.

Provisions are included for reviewing,

updating, and canceling such procedures.

5.1 Procedure Adherence SCE&G's policy is that procedures are followed, and the requirements for use of procedures have beenestablished in administrative procedures.

Where procedures cannot be followed as written, provisions are established for making changes in accordance with Part II, Section 6. Requirements are established toidentify the manner in which procedures are to be implemented, including identification of those tasksthat require:

(1) the written procedure to be present and followed step-by-step while the task is beingperformed; (2) the user to have committed the procedure steps to memory; and (3) verification ofcompletion of significant steps, by initials or signatures or use of check-off lists. Procedures that arerequired to be present and referred to directly are those developed for extensive or complex jobs wherereliance on memory cannot be trusted, tasks that are infrequently performed, and tasks where stepsmust be performed in a specified sequence.

in cases of emergency, personnel are authorized to depart from approved procedures when necessary toprevent injury to personnel or damage to the plant. Such departures are recorded describing theprevailing conditions and reasons for the action taken.5.2 Procedure ContentThe established measures address the applicable content of procedures as described in the introduction to Part II of NQA-1-1994.

In addition, procedures governing tests, inspections, operational activities andmaintenance will include as applicable, initial conditions and prerequisites for the performance of theactivity.

5.3 NQA-1-1994 Commitment In establishing procedural

controls, SCE&G commits to compliance with NQA-1-1994, Basic Requirement 5.23 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1SECTION 6 DOCUMENT CONTROLSCE&G has established the necessary measures and governing procedures to control the preparation of,issuance of, and changes to documents that specify quality requirements or prescribe how activities affecting

quality, including organizational interfaces, are controlled to assure that correct documents arebeing employed.

The control systems (including electronic systems used to make documents available) are documented and provide for the following:

(a) identification of documents to be controlled and their specified distribution; (b) a method to identify the correct document (including revision) to be used and control ofsuperseded documents; (c) identification of assignment of responsibility for preparing, reviewing, approving, andissuing documents; (d) review of documents for adequacy, completeness, and correctness prior to approval andissuance; (e) a method for providing feedback from users to continually improve procedures and workinstructions; and(f) coordinating and controlling interface documents and procedures.

The types of documents to be controlled include:(a) drawings, such as design, construction, installation, and as-built drawings; (b) engineering calculations; (c) design specifications; (d) purchase orders and related documents; (e) vendor-supplied documents; (f) audit, surveillance, and quality verification/inspection procedures; (g) inspection and test reports;(h) instructions and procedures for activities covered by this QAPD including design,modification, installation, operating (including normal and emergency operations),

maintenance, calibration, and routine testing;(i) technical specifications; and(j) nonconformance reports and corrective action reports.24 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1Where temporary procedures are used, they shall include a designation of the period of time duringwhich it is acceptable to use them.6.1 Review and Approval of Documents Documents are reviewed for adequacy by qualified persons other than the preparer.

StationAdministrative Procedures, as identified by the Manager, Quality Systems, defining and/or implementing portions of the Quality Assurance

Program, shall be reviewed by Quality Systems to ensure qualityassurance measures have been appropriately applied.

This documented review signifies concurrence.

Documents affecting the configuration or operation of the station as described in the FSAR are screenedto identify those that require review by the PSRC prior to implementation as described in Part V, Section2 of the QAPD.To ensure effective and accurate procedures, applicable procedures are reviewed, and updated asnecessary, based on the following conditions:

(a) following any modification to a system;(b) following an unusual incident, such as an accident, significant operator error, or equipment malfunction; (c) when procedure discrepancies are found;(d) prior to use if not used in the previous two years; or(e) results of QA audits conducted in accordance with Part II, Section 18.1.Prior to issuance or use, documents including revisions

thereto, are approved by the designated authority.

A listing of all controlled documents identifying the current approved

revision, or date, ismaintained so personnel can readily determine the appropriate document for use.6.2 Changes to Documents Changes to documents, other than those defined in implementing procedures as minor changes, arereviewed and approved by the same organizations that performed the original review and approvalunless other organizations are specifically designated.

The reviewing organization has access to pertinent background data or information upon which to base their approval.

Where temporary procedure changes are necessary, changes that clearly do not change the intent of the approved procedure may beimplemented provided they are approved by two members of the staff knowledgeable in the areasaffected by the procedures.

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

To avoid a possible omission of a required review, the type of minor changes that do notrequire such a review and approval and the persons who can authorize such a classification shall beclearly delineated in implementing procedures.

25 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 16.3 NQA-1-1994 Commitment In establishing provisions for document

control, SCE&G commits to compliance with NQA-1-1994, BasicRequirement 6 and Supplement 6S-1.6.4 Alternative Commitment To Biennial Review Of Procedures (Section 6.1(d))VCSNS Unit 1 continues to implement an alternative commitment to performing biennial procedure reviews as documented in NRC Letter from Albert F. Gibson, Director Division of Reactor Safety to John L.Skolds, Vice President, Nuclear Operations dated 11/29/1990.

This alternative commitment is described below:The following programs and activities provide adequate procedure revision control and a method toverify the adequacy of these programs and activities:

" Plant Design Change Program" Non-Conformance and Corrective Action Program" Licensee Event Report System" Operator Feedback Program" Surveillance Test Program" Operating Experience Review Program" Technical Specification and FSAR Revision Process" Corrective Actions for Regulatory Issues" Quality Assurance Program" Quality Assurance audit of the procedural development program using a representative sampleprocess.

The biennial audit will provide verification that the existing plant programs andactivities listed above are effective in maintaining procedures current.26 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1SECTION 7 CONTROL OF PURCHASED

MATERIAL, EQUIPMENT, ANDSERVICESSCE&G has established the necessary measures and governing procedures to control the procurement ofitems and services to assure conformance with specified requirements.

Such control provides for thefollowing as appropriate:

source evaluation and selection, evaluation of objective evidence of qualityfurnished by the supplier, source inspection, audit, and examination of items or services.

7.1 Acceptance of Item or ServiceSCE&G establishes and implements measures to assess the quality of purchased items and services, whether purchased directly or through contractors, at intervals and to a depth consistent with the itemor service's importance to safety, complexity,

quantity, and the frequency of procurement.

Verification actions include testing, as appropriate, during design, fabrication and operation activities.

Verifications occur at the appropriate phases of the procurement

process, including, as necessary, verification ofactivities of suppliers below the first tier.Measures to assure the quality of purchased items and services include the following, as applicable:

Items are inspected, identified, and stored to protect against damage, deterioration, or misuse.Prospective suppliers of safety-related items and services are evaluated to assure that onlyqualified suppliers are used. Qualified suppliers are audited on a triennial basis. In addition, if asubsequent contract or a contract modification significantly enlarges the scope of, or changesthe methods or controls for activities performed by the same supplier, an audit of the modifiedrequirements is conducted, thus starting a new triennial period. SCE&G may utilize auditsconducted by outside organizations for supplier qualification provided that the scope andadequacy of the audits meet SCE&G requirements.

Documented annual evaluations areperformed for qualified suppliers to assure they continue to provide acceptable products andservices.

Industry

programs, such as those applied by ASME, Nuclear Procurement IssuesCommittee (NUPIC),

or other established utility groups, are used as input or the basis forsupplier qualification whenever appropriate.

The results of the reviews are promptly considered for effect on a supplier's continued qualification and adjustments made as necessary (including corrective

actions, adjustments of supplier audit plans, and input to third party auditing

entities, as warranted).

In addition, results are reviewed periodically to determine if, as a whole, theyconstitute a significant condition adverse to quality requiring additional action.Provisions are made for accepting purchased items and services, such as source verification, receipt inspection, pre- and post-installation tests, certificates of conformance, and documentreviews (including Certified Material Test Report/Certificate).

Acceptance actions/documents should be established by the Purchaser with appropriate input from the Supplier and becompleted to ensure that procurement, inspection, and test requirements, as applicable, havebeen satisfied before relying on the item to perform its intended safety function.

Controls are imposed for the selection, determination of suitability for intended use (critical characteristics),

evaluation,

receipt, and acceptance of commercial-grade services or items toassure they will perform satisfactorily in service in safety-related applications.

27 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1If there is insufficient evidence of implementation of a QA program, the initial evaluation is ofthe existence of a QA program addressing the scope of services to be provided.

The initial auditis performed after the supplier has completed sufficient work to demonstrate that itsorganization is implementing a QA program.7.2 NQA-1-1994 Commitment/Exceptions In establishing procurement verification

controls, SCE&G commits to compliance with NQA-1-1994, BasicRequirement 7 and Supplement 7S-1, with the following clarifications and exceptions:

NQA-1-1994, Supplement 7S-1-SCE&G considers that other 10 CFR 50 licensees, Authorized NuclearInspection

Agencies, National Institute of Standards and Technology, or otherState and Federal agencies which may provide items or services to the V. C. Summerplant are not required to be evaluated or audited.-When purchasing commercial grade calibration services from a calibration laboratory, procurement source evaluation and selection measures need not be performed provided each of the following conditions are met:(1) The purchase documents impose any additional technical and administrative requirements, as necessary, to comply with the SCE&G QA program andtechnical provisions.

At a minimum, the purchase document shall requirethat the calibration certificate/report include identification of thelaboratory equipment/standard used;(2) The purchase documents require reporting as-found calibration data whencalibrated items are found to be out-of-tolerance; and(3) A documented review of the supplier's accreditation will be performed andwill include a verification of the following:

" The calibration laboratory is a domestic calibration service supplier.

" The calibration laboratory holds a domestic (United States)accreditation by any one of the following accrediting bodies, whichare recognized by the International Laboratory Accreditation Cooperation (ILAC) MutualRecognition Arrangement (MRA):-National Voluntary Laboratory Accreditation Program(NVLAP),

administered by the National Institute ofStandards

& Technology;

-American Association for Laboratory Accreditation (A2LA);-ACLASS Accreditation Services (ACLASS);

28 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1-International Accreditation Service (IAS);-Laboratory Accreditation Bureau (L-A-B);

or-Other NRC-approved laboratory accrediting body." The accreditation encompasses ANSI ANS/ISO/IEC 17025, "GeneralRequirements for the Competence of Testing and Calibration Laboratories".

" The published scope of accreditation for the calibration laboratory covers the necessary measurement parameters, ranges, anduncertainties.

" Subsuppliers of calibration service suppliers are acceptable providedthe above conditions are met.-For Section 8.1, SCE&G considers documents that may be stored in approvedelectronic media under SCE&G or vendor control not physically located on the V. C.Summer Nuclear Station site, but are accessible from the site, as meeting the NQA-1requirement for documents to be available at the site. The SCE&G recordsmanagement system will provide for timely retrieval of necessary records.-In lieu of the requirements of Section 10, Commercial Grade Items, controls forcommercial grade items and services are established in SCE&G documents using 10CFR 21 and the guidance of EPRI NP-5652 as discussed in Generic Letter 89-02 andGeneric Letter 91-05.-For commercial grade items, special quality verification requirements areestablished and described in SCE&G documents to provide the necessary assurance an item will perform satisfactorily in service.

The SCE&G documents address determining the critical characteristics that ensure an item is suitablefor its intended use, technical evaluation of the item, receipt requirements, and quality evaluation of the item.-SCE&G will also use other appropriate approved regulatory means andcontrols to support SCE&G commercial grade dedication activities.

SCE&G willassume 10 CFR 21 reporting responsibility for all items that SCE&G dedicates as safety-related.

29 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1Section 8 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS,AND COMPONENTS SCE&G has established the necessary measures and governing procedures to identify and control itemsto prevent the use of incorrect or defective items. This includes controls for consumable materials anditems with limited shelf life. The identification of items is maintained throughout fabrication,

erection, installation and use so that the item can be traced to its documentation, consistent with the item's effecton safety. Identification locations and methods are selected so as not to affect the function or quality ofthe item.8.1 NOA-1-1994 Commitment In establishing provisions for identification and control of items, SCE&G commits to compliance withNQA-1-1994, Basic Requirement 8 and Supplement 8S-1.30 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1SECTION 9 CONTROL OF SPECIAL PROCESSES SCE&G has established the necessary measures and governing procedures to assure that specialprocesses that require interim process controls to assure quality, such as welding, heat treating, andnondestructive examination, are controlled.

These provisions include assuring that special processes areaccomplished by qualified personnel using qualified procedures and equipment.

Personnel are qualified and special processes are performed in accordance with applicable codes, standards, specifications, criteria or other specially established requirements.

Special processes are those where the results arehighly dependent on the control of the process or the skill of the operator, or both, and for which thespecified quality cannot be fully and readily determined by inspection or test of the final product.9.1 NQA-1-1994 Commitment In establishing measures for the control of special processes, SCE&G commits to compliance with NQA-1-1994, Basic Requirement 9 and Supplement 9S-1.31 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision ISECTION 10 INSPECTION SCE&G has established the necessary measures and governing procedures to implement inspections thatassure items, services and activities affecting safety meet established requirements and conform toapplicable documented specifications, instructions, procedures, and design documents.

Inspection mayalso be applied to items, services, and activities affecting plant reliability and integrity.

Types ofinspections may include those verifications related to procurement, such as source, in-process, final, andreceipt inspection, as well as installation, maintenance, modification, in-service, and operations activities.

Inspections are carried out by properly qualified persons independent of those who performed ordirectly supervised the work. Inspection results are documented.

10.1 Inspection ProgramThe inspection program establishes inspections (including surveillance of processes),

as necessary toverify quality:

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

The inspection program establishes requirements for planning inspections, such as the group ordiscipline responsible for'performing the inspection, where inspection hold points are to be applied,determining applicable acceptance

criteria, the frequency of inspection to be applied, and identification of special tools needed to perform the inspection.

Inspection planning is performed by personnel qualified in the discipline related to the inspection and includes qualified inspectors or engineers.

Inspection plans are based on, as a minimum, the importance of the item to the safety of the facility, thecomplexity of the item, technical requirements to be met, and design specifications.

Where significant changes in inspection activities are to occur, management responsible for the inspection programsevaluates the resource and planning requirements to ensure effective implementation of the inspection program.Inspection program documents establish requirements for performing the planned inspections, anddocumenting required inspection information such as rejection, acceptance, and re-inspection results,and the person(s) performing the inspection.

Inspection results are documented by the inspector, reviewed by authorized personnel qualified toevaluate the technical adequacy of the inspection

results, and are controlled by instructions, procedures, and drawings.

10.2 Inspector Qualification SCE&G has established qualification programs for personnel performing quality inspections.

Thequalification program requirements are described in Part II, Section 2. These qualification programs areapplied to individuals performing quality inspections regardless of the functional group where they areassigned.

32 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 110.3 NQA-1-1994 Commitment I Exceptions In establishing inspection requirements, SCE&G commits to compliance with NQA-1-1994, BasicRequirement 10, Supplement 1OS-1 and Subpart 2.4, with the following clarification.

In addition, SCE&Gcommits to compliance with the requirements of Subparts 2.5 and 2.8 for establishing appropriate inspection requirements.

" Subpart 2.4 commits SCE&G to IEEE 336-1985.

IEEE 336-1985 refers to IEEE 498- 1985. BothIEEE 336 -1985 and IEEE 498-1985 use the definition of "Safety Systems" from IEEE 603-1980.

SCE&G commits to the definition of Safety Systems in IEEE 603- 1980, but does not commit tothe balance of that standard.

This definition is only applicable to equipment in the context ofSubpart 2.4." Subpart 2.4 commits SCE&G to IEEE 336-1985.

IEEE 336-1985, Step 1.1.2 refers to ANSI/ANS3.2-1982.

SCE&G commits to ANSI N18.7-1976/ANS 3.2." An additional exception to Subpart 2.4 is addressed in Part II, Section 12 of the QAPD." Where inspections at the V. C. Summer Nuclear Facility are performed by persons within thesame organization (e .g. Maintenance group), SCE&G takes exception to the requirements ofNQA-1-1994, Supplement 1OS-1, Section 3.1, the inspectors report to quality systemsmanagement while performing those inspections.

33 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1SECTION 11 TEST CONTROLSCE&G has established the necessary measures and governing procedures to demonstrate that itemssubject to the provisions of the QAPD will perform satisfactorily in service, that the plant can be operatedsafely and as designed, and that the coordinated operation of the station as a whole is satisfactory.

Theseprograms include criteria for determining when testing is required, such as proof tests beforeinstallation, post-maintenance tests, post-modification tests, in-service tests, and operational tests (suchas surveillance tests required by Plant Technical Specifications),

to demonstrate that performance ofplant systems is in accordance with design. Programs also include provisions to establish and adjust testschedules and to maintain status for periodic or recurring tests. Tests are performed according toapplicable procedures that include, consistent with the effect on safety, (1) instructions and prerequisites to perform the test, (2) use of proper test equipment, (3) acceptance

criteria, and (4) mandatory verification points as necessary to confirm satisfactory test completion.

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

If acceptance criteria are not met, re-testing is performed asneeded to confirm acceptability following correction of the system or equipment deficiencies that causedthe failure.Tests are performed and results documented in accordance with applicable technical and regulatory requirements, including those described in the Technical Specifications and FSAR. Test programs ensureappropriate retention of test data in accordance with the records requirements of the QAPD. Personnel that perform or evaluate tests are qualified in accordance with the requirements established in Part II,Section 2.11.1 NOA-1-1994 Commitment In establishing provisions for testing, SCE&G commits to compliance with NQA-1-1994, BasicRequirement 11 and Supplement 11S-1.11.2 NQA-1-1994 Commitment for Computer Program TestingSCE&G establishes and implements provisions to assure that computer software used in applications affecting safety is prepared, documented, verified and tested, and used such that the expected output isobtained and configuration control maintained.

To this end SCE&G commits to compliance with therequirements of NQA-1-1994, Supplement 11S-2 and Subpart 2.7 to establish the appropriate provisions.

34 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1SECTION 12 CONTROL OF MEASURING AND TEST EQUIPMENT SCE&G has established the necessary measures and governing procedures to control the calibration, maintenance, and use of measuring and test equipment (M&TE) that provides information important tosafe plant operation.

The provisions of such procedures cover equipment such as indicating andactuating instruments and gages, tools, reference and transfer standards, and nondestructive examination equipment.

The suppliers of commercial grade calibration services are controlled asdescribed in Part II, Section 7.12.1 Installed Instrument and Control DevicesSCE&G has established and implements procedures for the calibration and adjustment of instrument andcontrol devices installed in the facility.

The calibration and adjustment of these devices is accomplished through the facility maintenance programs to ensure the facility is operated within design and technical requirements.

Appropriate documentation will be maintained for these devices to indicate the controlstatus, when the next calibration is due, and identify any limitations on use of the device.12.2 NQA-1-1994 Commitment/Exceptions In establishing provisions for control of measuring and test equipment, SCE&G commits to compliance with NQA-1-1994, Basic Requirement 12 and Supplement 12S-1 with the following clarification andexception:

-The out of calibration conditions described in paragraph 3.2 of Supplement 12S-1 refers towhen the M&TE is found out of the required accuracy limits (i.e. out of tolerance) duringcalibration.

-Measuring and test equipment are not required to be marked with the calibration status whereit is impossible or impractical due to equipment size or configuration (such as the label willinterfere with operation of the device) provided the required information is maintained insuitable documentation traceable to the device. This exception also applies to the calibration labeling requirement stated in NQA-1-1994, Subpart 2.4, Section 7.2.1 (ANSI/IEEE Std. 336-1985).35 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1SECTION 13 HANDLING,

STORAGE, AND SHIPPINGSCE&G has established the necessary measures and governing procedures to control the handling,

storage, packaging,

shipping, cleaning, and preservation of items to prevent inadvertent damage or loss,and to minimize deterioration.

These provisions include specific procedures, when required to maintainacceptable quality of the items important to the safe operations of the plant. Items are appropriately marked and labeled during packaging,

shipping, handling, and storage to identify,

maintain, and preservethe item's integrity and indicate the need for special controls.

Special controls (such as containers, shockabsorbers, accelerometers, inert gas atmospheres, specific moisture content levels, and temperature levels) are provided when required to maintain acceptable quality.Special or additional

handling, storage,

shipping, cleaning, and preservation requirements are identified and implemented as specified in procurement documents and applicable procedures.

Where specialrequirements are specified, the items and containers (where used) are suitably marked.Special handling tools and equipment are used and controlled as necessary to ensure safe and adequatehandling.

Special handling tools and equipment are inspected and tested at specified time intervals andin accordance with procedures to verify that the tools and equipment are adequately maintained.

Operators of special handling and lifting equipment are experienced or trained in the use of theequipment.

SCE&G establishes and implements controls over hoisting, rigging and transport activities tothe extent necessary to protect the integrity of the items involved, as well as potentially affected nearbystructures and components.

Where required, SCE&G complies with applicable

hoisting, rigging andtransportation regulations and codes.13.1 Housekeeping Housekeeping practices are established to account for conditions or environments that could affect thequality of structures, systems and components within the plant. This includes control of cleanliness offacilities and materials, fire prevention and protection, disposal of combustible material and debris,control of access to work areas, protection of equipment, radioactive contamination

control, and storageof solid radioactive waste. Housekeeping practices help assure that only proper materials, equipment, processes, and procedures are used and that the quality of items is not degraded.

Necessary procedures or work instructions, such as for electrical bus and control center cleaning, cleaning of control consoles, and radioactive decontamination, are developed and used.13.2 NOA-1-1994 Commitment I Exceptions In establishing provisions for handling, storage and shipping, SCE&G commits to compliance with NQA-1-1994, Basic Requirement 13 and Supplement 13S-1. SCE&G also commits to compliance with therequirements of NQA 1994, Subpart 2.1, Subpart 2.2, Subpart 2.3, and Subpart 3.2, Appendix 2.1, withthe following clarifications and exceptions:

NQA-1-1994, Subpart 2.1-Subpart 2.1, Section 3.1 and 3.2 establish criteria for classifying items into cleanness classesand requirements for each class. Instead of using the cleanness level system of Subpart 2.1,SCE&G may establish cleanness requirements on a case-by-case basis, consistent with the otherprovisions of Subpart 2.1. SCE&G establishes appropriate cleanliness controls for work on36 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1safety-related equipment to minimize introduction of foreign material and maintainsystem/component cleanliness throughout maintenance or modification activities, including documented verification of absence of foreign material prior to system closure.NQA-1-1994, Subpart 2.2-Subpart 2.2, Section 2.2 establishes criteria for classifying items into protection levels.Instead of classifying items into protection levels, SCE&G may establish controls for thepackaging,

shipping, handling, and storage of such items on a case-by-case basis with dueregard for the item's complexity, use, and sensitivity to damage. Prior to installation or use, theitems are inspected and serviced as necessary to assure that no damage or deterioration existswhich could affect their function.

-Subpart 2.2, Section 6.6, "Storage Records:"

This section requires written records be preparedcontaining information on personnel access. As an alternative to this requirement, SCE&Gdocuments establish controls for storage areas that describe those authorized to access areasand the requirements for recording access of personnel.

However, these records of access arenot considered quality records and will be retained in accordance with the administrative controls established for the V. C. Summer Nuclear Station.-Subpart 2.2, Section 7.1 refers to Subpart 2.15 for requirements related to handling of items.The scope of Subpart 2.15 includes

hoisting, rigging and transporting of items for the nuclearpower plants during construction.

NQA-1-1994, Subpart 2.3-Subpart 2.3, Section 2.3 requires the establishment of five zone designations for housekeeping cleanliness controls.

Instead of the five-level zone designation, SCE&G bases its control overhousekeeping activities on a consideration of what is necessary and appropriate for the activityinvolved.

The controls are implemented through procedures or instructions which, in the caseof maintenance or modification work, are developed on a case-by-case basis. Factorsconsidered in developing the procedures and instructions include cleanliness

control, personnel safety, fire prevention and protection, radiation control and security.

The procedures andinstructions make use of standard janitorial and work practices to the extent possible.

NQA-1-1994, Subpart 3.2-Subpart 3.2, Appendix 2.1: Only Section 3 precautions are being committed to in accordance with RG 1.37. In addition, a suitable chloride stress-cracking inhibitor should be added to thefresh water used to flush systems containing austenitic stainless steels.37 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1SECTION 14 INSPECTION, TEST, AND OPERATING STATUSSCE&G has established the necessary measures and governing procedures to identify the inspection, test,and operating status of items and components subject to the provisions of the QAPD in order to maintainpersonnel and reactor safety and avoid inadvertent operation of equipment.

Where necessary topreclude inadvertent bypassing of inspections or tests, or to preclude inadvertent operation, thesemeasures require the inspection, test or operating status be verified before release, fabrication, receipt,installation, test or use. These measures also establish the necessary authorities and controls for theapplication and removal of status indicators or labels.In addition, temporary design changes (temporary modifications),

such as temporary bypass lines,electrical jumpers and lifted wires, and temporary trip-point

settings, are controlled by procedures orwork instructions that include requirements for appropriate installation and removal, independent!

concurrent verifications and status tracking.

Administrative procedures also describe the measures taken to control altering the sequence of requiredtests, inspections, and other operations.

Review and approval for these actions is subject to the samecontrol as taken during the original review and approval of tests, inspections, and other operations.

14.1 NQA-l-1994 Commitment In establishing measures for control of inspection, test and operating status, SCE&G commits tocompliance with NQA-1-1994, Basic Requirement 14.38 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1SECTION 15 NONCONFORMING MATERIALS, PARTS, OR COMPONENTS SCE&G has established the necessary measures and governing procedures to control items, including services that do not conform to specified requirements to prevent inadvertent installation or use.Instructions require that the individual discovering a nonconformance

identify, describe, and documentthe nonconformance in accordance with the requirements of Part II, Section 16. Controls provide foridentification, documentation, evaluation, segregation when practical, and disposition of nonconforming items, and for notification to affected organizations.

Controls are provided to address conditional releaseof nonconforming items for use on an at-risk basis prior to resolution and disposition of thenonconformance, including maintaining identification of the item and documenting the basis for suchrelease.

Conditional release of nonconforming items for installation requires the approval of thedesignated management.

Nonconformances are corrected or resolved prior to depending on the item toperform its intended safety function.

Nonconformances are evaluated for impact on operability of qualitystructures,

systems, and components to assure that the final condition does not adversely affect safety,operation, or maintenance of the item or service.

Nonconformances to design requirements dispositioned repair or use-as-is, are subject to design control measures commensurate with thoseapplied to the original design. Nonconformance dispositions are reviewed for adequacy, analysis ofquality trends, and reports provided to the designated management.

Significant trends are reported tomanagement in accordance with SCE&G procedures, regulatory requirements, and industry standards.

15.1 Interface with the Reporting ProgramSCE&G has appropriate interfaces between the QAP for identification and control of nonconforming materials, parts, or components and the non-QA Reporting Program to satisfy the requirements of 10CFR 21 during operations.

15.2 NQA-1-1994 Commitment In establishing measures for nonconforming materials, parts, or components, SCE&G commits tocompliance with NQA-1 -1994, Basic Requirement 15, and Supplement 15S-1.39 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1SECTION 16 CORRECTIVE ACTIONSCE&G has established the necessary measures and governing procedures to promptly

identify, control,document, classify and correct conditions adverse to quality.

SCE&G procedures assure that corrective actions are documented and initiated following the determination of conditions adverse to quality inaccordance with regulatory requirements and applicable quality standards.

SCE&G procedures requirepersonnel to identify known conditions adverse to quality.

When complex issues arise where it cannot bereadily determined if a condition adverse to quality exists, SCE&G documents establish the requirements for documentation and timely evaluation of the issue. Reports of conditions adverse to quality areanalyzed to identify trends. Significant conditions adverse to quality and significant adverse trends aredocumented and reported to responsible management.

In the case of a significant condition adverse toquality, the cause is determined and actions to preclude recurrence are taken.In the case of suppliers working on safety-related activities, or other similar situations, SCE&G maydelegate specific responsibilities for corrective

actions, but SCE&G maintains responsibility for theeffectiveness of corrective action measures.

16.1 Interface with the Reporting ProgramSCE&G has appropriate interfaces between the QAP for corrective actions and the non-QA Reporting Program to satisfy the requirements of 10 CFR 21 during operations.

16.2 NQA-1-1994 Commitment In establishing provisions for corrective action, SCE&G commits to compliance with NQA-1-1994, BasicRequirement 16.40 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1SECTION 17 QUALITY ASSURANCE RECORDSSCE&G has the necessary measures and governing procedures to ensure that sufficient records of itemsand activities affecting quality are developed,

reviewed, approved, issued, used, and revised to reflectcompleted work. The provisions of such procedures establish the scope of the records retention programfor SCE&G and include requirements for records administration, including

receipt, preservation, retention,

storage, safekeeping, retrieval, access controls, user privileges, and final disposition.

17.1 Record Retention Measures are established that ensure that sufficient records of completed items and activities affecting quality are appropriately stored. Records of activities for design, engineering, procurement, manufacturing, inspection and test, installation, operations, maintenance, modification, decommissioning, and audits and their retention times are defined in appropriate procedures.

Therecords and retention times are based on construction records that are similar in nature based onRegulatory Position C.2 and Table 1 in Regulatory Guide 1.28, Revision

3. In all cases where state, local, orother agencies have more restrictive requirements for record retention, those requirements will be met.For example, ISFSI records required by 10 CFR 72.174 must include the following:

design records,records of use, and the results of reviews, inspections, tests, audits, monitoring of workperformance, and materials analyses.

The records must include closely related data such asqualifications of personnel, procedures, and equipment.

Inspection and test records must, at aminimum, identify the inspector or data recorder, the type of observation, the results, theacceptability, and the action taken in connection with any noted deficiencies.

Records must beidentifiable and retrievable.

Records pertaining to the design, fabrication,

erection, testing,maintenance, and use of structures,

systems, and components important to safety must bemaintained by or under the control of the licensee or certificate holder until the NRC terminates thelicense or COC.17.2 Electronic RecordsWhen using electronic records storage and retrieval

systems, SCE&G complies with NRC guidance inGeneric Letter 88-18, "Plant Record Storage on Optical Disks." SCE&G will manage the storage of QARecords in electronic media consistent with the intent of RIS 2000-18 and associated NIRMA Guidelines TG 11-1998, TG15-1998, TG16-1998, and TG21 -1998.17.3 NQA-1-1994 Commitment I Exceptions In establishing provisions for records, SCE&G commits to compliance with NQA-1-1994, BasicRequirement 17 and Supplement 17S-1, with the following clarifications and exceptions:

NQA-1-1994, Supplement 17S-1-Supplement 17S-1, section 4.2(b) requires records to be firmly attached in binders orplaced in folders or envelopes for storage in steel file cabinets or on shelving incontainers.

For hard-copy records maintained by SCE&G, the records are suitablystored in steel file cabinets or on shelving in containers, except that methods otherthan binders, folders or envelopes may be used to organize the records for storage.41 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1SECTION 18 AUDITSSCE&G has established the necessary measures and governing procedures to implement audits to verifythat activities covered by the QAPD are performed in conformance with the requirements established.

The audit programs are themselves reviewed for effectiveness as a part of the overall audit process.18.1 Performance of AuditsInternal audits of selected aspects of licensing, design, and operating activities are performed with afrequency commensurate with safety significance and in a manner which assures that audits of safety-related activities are completed.

Functional areas of an organization's QA program for auditing include,at a minimum, verification of compliance and effectiveness of implementation of internal rules,procedures (e .g., operating, design, procurement, maintenance, modification, refueling, surveillance, test, security, radiation control procedures, and the Emergency Plan), Technical Specifications, regulations and license conditions, programs for training, retraining, qualification and performance ofoperating staff, corrective

actions, and observation of performance of operating, refueling, maintenance and modification activities, including associated record keeping.The audits are scheduled on a formal preplanned audit schedule.

The audit system is reviewedperiodically and revised as necessary to assure coverage commensurate with current and plannedactivities.

Additional audits may be performed as deemed necessary by management.

The scope of theaudit is determined by the quality status and safety importance of the activities being performed.

Theseaudits are conducted by trained personnel not having direct responsibilities in the area being audited andin accordance with preplanned and approved audit plans or checklists, under the direction of a qualified lead auditor and the cognizance of the Manager, Quality Systems.SCE&G is responsible for conducting periodic internal and external audits. Internal audits are conducted to determine the adequacy of programs and procedures (by representative sampling),

and to determine if they are meaningful and comply with the overall QAPD. External audits determine the adequacy ofsupplier and contractor quality assurance program.The results of each audit are reported in writing to the Senior Vice President, Nuclear Operations, ordesignee, as appropriate.

Additional internal distribution is made to other concerned management levelsin accordance with approved procedures.

Management responds to all audit findings and initiates corrective action where indicated.

Wherecorrective action measures are indicated, documented follow-up of applicable areas through inspections, review, re-audits, or other appropriate means is conducted to verify implementation of assignedcorrective action.Audits of suppliers of safety-related components and/or services are conducted as described in Section7.1.18.2 Internal AuditsInternal audits of activities should be performed in such a manner as to assure that an audit of allapplicable QA program elements is completed for each functional area within a period of two years.Internal audit frequencies of well established activities, conducted after placing the facility in operation, 42 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1may be extended one year at a time beyond the above two-year interval based on the results of anannual evaluation of the applicable functional area and objective evidence that the functional areaactivities are being satisfactorily accomplished.

The evaluation should include a detailed performance analysis of the functional area based upon applicable internal and external source data and dueconsideration of the impact of any function area changes in responsibility, resources or management.

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

Audits are performed at a frequency commensurate with the safety significance of the activities and insuch a manner to assure audits of all applicable QA program elements are completed within a period oftwo years. These audits will include, as a minimum, activities in the following areas:(1) The conformance of facility operation to provisions contained within the Technical Specifications and applicable license conditions including administrative controls.

(2) The performance,

training, and qualifications of the facility staff.(3) The performance of activities required by the QAPD to meet the criteria of 10 CFR 50,Appendix B and 10 CFR 72, Subpart G.(4) The Fire Protection Program and implementing procedures.

A fire protection equipment andprogram implementation inspection and audit are conducted utilizing either a qualified off-site licensed fire protection engineer or an outside qualified fire protection consultant.

(5) Other activities and documents considered appropriate by the Vice President, NuclearOperations.

Audits may also be used to meet the periodic review requirements of the code for the Security, Emergency Preparedness, and Radiological Protection programs within the provisions of the applicable code.Internal audits include verification of compliance and effectiveness of the administrative controlsestablished for implementing the requirements of this OAPD; regulations and license provisions; provisions for training, retraining, qualification, and performance of personnel performing activities covered by this QAPD; corrective actions taken following abnormal occurrences; and observation of theperformance of fabrication, operating, refueling, maintenance, and modification activities including associated record keeping.18.3 NOQA-1-1994 Commitment In establishing the independent audit program, SCE&G commits to compliance with NQA-1-1994, BasicRequirement 18 and Supplement 18S-1.43 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1PART III NON-SAFETY-RELATED SSC QUALITY CONTROLSECTION 1 Non-safety-Related SSCs -Significant Contributors to Plant SafetySpecific program controls are applied to non-safety related SSCs, for which 10 CFR 50, Appendix B is notapplicable, that are significant contributors to plant safety. The specific program controls consistent withapplicable sections of the QAPD are applied to those items in a selected manner, targeted at thosecharacteristics or critical attributes that render the SSC a significant contributor to plant safety.The following clarify the applicability of the QA Program to the non-safety related SSCs and relatedactivities, including the identification of exceptions to the QA Program described in Part II, Sections 1through 18 taken for non-safety related SSCs.1.1 Organization The verification activities described in this Part may be performed by the SCE&G lineorganization.

The QA organization described in Part II is not required to perform these functions.

1.2 QA ProgramSCE&G QA requirements for non-safety related SSCs are established in the QAPD andappropriate procedures.

Suppliers of these SSCs or related services describe the quality controlsapplied in appropriate procedures.

A new or separate QA program is not required.

1.3 Design ControlSCE&G has established design control measures to ensure that the established designrequirements are included in the design. These measures ensure that applicable design inputsare included or correctly translated into the design documents, and deviations from thoserequirements are controlled.

Design verification is provided through the normal supervisory review of the designer's work.1.4 Procurement Document ControlProcurement documents for items and services obtained by or for SCE&G shall include orreference documents describing applicable design bases, design requirements, and otherrequirements necessary to ensure component performance.

The procurement documents arecontrolled to address deviations from the specified requirements.

1.5 Instructions, Procedures, and DrawingsSCE&G provides documents such as, but not limited to, written instructions, plant procedures,

drawings, vendor technical

manuals, and special instructions in work orders, to direct theperformance of activities affecting quality.

The method of instruction employed provides anappropriate degree of guidance to the personnel performing the activity to achieve acceptable functional performance of the SSC.44 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 11.6 Document ControlSCE&G controls the issuance and change of documents that specify quality requirements orprescribe activities affecting quality to ensure that correct documents are used. These controlsinclude review and approval of documents, identification of the appropriate revision for use, andmeasures to preclude the use of superseded or obsolete documents.

1.7 Control of Purchased Items and ServicesSCE&G employs measures, such as inspection of items or documents upon receipt or acceptance

testing, to ensure that all purchased items and services conform to appropriate procurement documents.

1.8 Identification and Control of Purchased ItemsSCE&G employs measures where necessary, to identify purchased items and preserve theirfunctional performance capability.

Storage controls take into account appropriate environmental, maintenance, or shelf life restrictions for the items.1.9 Control of Special Processes SCE&G employs process and procedure controls for special processes, including

welding, heattreating, and nondestructive testing.

These controls are based on applicable codes, standards, specifications,

criteria, or other special requirements for the special process.1.10 Inspection SCE&G uses documented instructions to ensure necessary inspections are performed to verifyconformance of an item or activity to specified requirements or to verify that activities aresatisfactorily accomplished.

These inspections may be performed by knowledgeable personnel in the line organization.

Knowledgeable personnel are from the same discipline and haveexperience related to the work being inspected.

1.11 Test ControlSCE&G employs measures to identify required testing that demonstrates that equipment conforms to design requirements.

These tests are performed in accordance with testinstructions or procedures.

The test results are recorded, and authorized individuals evaluate theresults to ensure that test requirements are met.1.12 Control of Measuring and Test Equipment (M&TE)SCE&G employs measures to control M&TE use, and calibration and adjustment at specificintervals or prior to use.45 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 11.13 Handling,

Storage, and ShippingSCE&G employs measures to control the handling,

storage, cleaning, packaging,

shipping, andpreservation of items to prevent damage or loss and to minimize deterioration.

These measuresinclude appropriate marking or labels, and identification of any special storage or handlingrequirements.

1.14 Inspection, Test, and Operating StatusSCE&G employs measures to identify items that have satisfactorily passed required tests andinspections and to indicate the status of inspection, test, and operability as appropriate.

1.15 Control of Nonconforming ItemsSCE&G employs measures to identify and control items that do not conform to specified requirements to prevent their inadvertent installation or use.1.16 Corrective ActionSCE&G employs measures to ensure that failures, malfunctions, deficiencies, deviations, defective components, and non-conformances are properly identified,

reported, and corrected.

1.17 RecordsSCE&G employs measures to ensure records are prepared and maintained to furnish evidencethat the above requirements for design, procurement, document

control, inspection, and testactivities have been met.1.18 AuditsSCE&G employs measures for line management to periodically review and document theadequacy of the process, including taking any necessary corrective action. Audits independent ofline management are not required.

Line management is responsible for determining whetherreviews conducted by line management or audits conducted by any organization independent ofline management are appropriate.

If performed, audits are conducted and documented to verifycompliance with design and procurement documents, instructions, procedures,

drawings, andinspection and test activities.

Where the measures of this Part III are implemented by the sameprograms, processes, or procedures as the comparable activities of Part 1i, the audits performed under the provisions of Part II may be used to satisfy the review requirements of this Part III,Section 1.18.46 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1SECTION 2 Non-safety-Related SSCs Credited for Regulatory EventsThe following criteria apply to fire protection (10 CFR 50.48), anticipated transients without scram(ATWS) (10 CFR 50.62), and a station blackout (SBO) (10 CFR 50.63) for SSCs that are not safety-related.

-SCE&G implements quality requirements for the Fire Protection System in accordance withRegulatory Position 1.7, "Quality Assurance,"

in Regulatory Guide 1.189, Rev 2 "Fire Protection for Operating Nuclear Power Plants" as identified in FSAR Chapter 3, Appendix 3A.-SCE&G implements the quality requirements for ATWS equipment in accordance with Part Ill,Section 1.-SCE&G implements quality requirements for SBO equipment in accordance with Regulatory Guide 1.155, "Station Blackout,"

and Part III, Section 1.47 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1PART IV REGULATORY COMMITMENTS NRC Regulatory Guides and Quality Assurance Standards This section identifies the NRC Regulatory Guides (RGs) and the other quality assurance standards whichhave been selected to supplement and support the SCE&G QAPD. SCE&G complies with these standards to the extent described or referenced herein. Commitment to a particular RG or standard does notconstitute a commitment to the RGs or standards that may be referenced therein.Regulatory Guides:See FSAR Chapter 3 for the SCE&G evaluation of conformance with the guidance in NRC Regulatory Guides.Regulatory Guide 1.8, Rev. 2, "Personnel Selection and Training,"

April 1987Regulatory Guide 1.8 provides guidance that is acceptable to the NRC staff regarding qualifications and training for nuclear power plant personnel.

SCE&G identifies conformance and exceptions for the applicable regulatory position guidanceprovided in this regulatory guide in FSAR Chapter 3, Appendix 3A.Regulatory Guide 1.26, Rev. 3,"Quality Group Classification and Standards forWater,Steam, and Radioactive-Waste-Containing Components of Nuclear Power Plants,"February 1976Regulatory Guide 1.26 defines classification of systems and components.

SCE&G identifies conformance and exceptions for the applicable regulatory position guidanceprovided in this regulatory guide in FSAR Chapter 3, Appendix 3A.Regulatory Guide 1.28, Rev 3, "Quality Assurance Program Requirements (Designand Construction),

August 1985Regulatory Guide 1.28 describes a method acceptable to the NRC staff for complying with theprovisions of Appendix B with regard to establishing and implementing the requisite qualityassurance program for the design and construction of nuclear power plants.SCE&G identifies conformance and exceptions for the applicable regulatory position guidanceprovided in this regulatory guide in FSAR Chapter 3, Appendix 3A.48 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1Regulatory Guide 1.29, Rev. 2 for Comment, "Seismic Design Classification,"

February 1976Regulatory Guide 1.29 defines systems required to withstand a safe shutdown earthquake (SSE).SCE&G identifies conformance and exceptions for the applicable regulatory position guidanceprovided in this regulatory guide in FSAR Chapter 3, Appendix 3A.Regulatory Guide 1.33, Rev. 2, February 1978, Quality Assurance Program Requirements (Operations)

Regulatory Guide 1.33 describes a method acceptable to the NRC staff for complying with theCommission's regulations with regard to overall quality assurance program requirements for theoperation phase of nuclear power plants.SCE&G identifies conformance and exceptions for the applicable regulatory position SCE&Gguidance provided in this regulatory guide in FSAR Chapter 3, Appendix 3A.Regulatory Guide 1.37, Rev. 1, "Quality Assurance Requirements for Cleaning of Fluid Systemsand Associated Components of Water-Cooled Nuclear Power Plants,"

March 2007.Regulatory Guide 1.37 provides guidance on specifying water quality and precautions related tothe use of alkaline cleaning solutions and chelating agents.SCE&G identifies conformance and exceptions for the applicable regulatory position guidanceprovided in this regulatory guide in FSAR Chapter 3, Appendix 3A.Regulatory Guide 1.54, Rev. 0, "Quality Assurance Requirements for Protective Coatings Applied to Water Cooled Nuclear Power Plants,"

June 1973Regulatory Guide 1.54 provides guidance for the application of protective coatings withinnuclear power plants to protect surfaces from corrosion, contamination from radionuclides, andfor wear protection.

SCE&G identifies conformance and exceptions for the applicable regulatory position guidanceprovided in this regulatory guide in FSAR Chapter 3, Appendix 3A.Standards:

ASME NQA-1-1994

Edition, Quality Assurance Requirements for Nuclear FacilityApplications SCE&G commits to NQA-1-1994, Parts I, II, and Ill, as described in Parts II and V of this document.

Nuclear Information and Records Management Association, Inc. (NIRMA) Technical Guides (TGs)SCE&G commits to NIRMA TGs as described in Part II, Section 17.49 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1PART V ADDITIONAL QUALITY ASSURANCE AND ADMINISTRATIVE CONTROLS FOR THE PLANT OPERATIONAL PHASESCE&G includes the requirements of Part V that follow when establishing the necessary measures and governing procedures for the operations phase of the plant.Section 1 Definitions SCE&G uses the definitions of terms as provided in Section 4 of the Introduction of NQA-1-1994 ininterpreting the requirements of NQA-1-1994 and the other standards to which the QAPD commits.

Inaddition, definitions are provided for the following terms not covered in NQA-1-1994:

administrative controls:

rules, orders, instructions, procedures,

policies, practices and designations ofauthority and responsibility experiments:

performance of plant operations carried out under controlled conditions in order toestablish characteristics or values not previously knownindependent review: a review completed by personnel not having direct responsibility for the workfunction under review regardless of whether they operate as a part of an organizational unit or asindividual staff members (see review)ISFS: An independent spent fuel storage installation (ISFSI) is a facility designed and constructed for theinterim storage of spent nuclear fuel and other radioactive materials associated with the spent fuel (10CFR 72.3). The term ISFSI refers to the facility authorized for storage of spent nuclear fuel pursuant to 10CFR Part 72 and includes the storage pad, the storage containers, and any support facilities.

However, ifthe ISFSI is located at a reactor site, it does not include any structures, facilities, or services that are partof the 10 CFR Part 50 license, unless they are identified as being shared jointly.nuclear power plant: any plant using a nuclear reactor to produce electric power, process steam or spaceheatingon-site operating organization:

on-site personnel concerned with the operation, maintenance andcertain technical servicesoperating activities:

work functions associated with normal operation and maintenance of theplant, and technical services routinely assigned to the on-site operating organization operational phase: that period of time during which the principal activity is associated with normaloperation of the plant. This phase of plant life is considered to begin formally with commencement ofinitial fuel loading, and ends with plant decommissioning review: a deliberately critical examination, including observation of plant operation, evaluation ofassessment

results, procedures, certain contemplated

actions, and after-the-fact investigations ofabnormal conditions 50 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1supervision:

direction of personnel activities or monitoring of plant functions by an individual responsible and accountable for the activities they direct or monitorsurveillance testing:

periodic testing to verify that safety related structures,

systems, and components continue to function or are in a state of readiness to perform their functions system: an integral part of nuclear power plant comprising components which may be operated or usedas a separate entity to perform a specific functionSection 2 Review of Activities Affecting Safe Plant Operation 2.1 Onsite Operating Organization ReviewThe SCE&G onsite organization employs reviews, both periodic and as situations demand, to evaluateplant operations and plan future activities.

The important elements of the reviews are documented andsubjects of potential concern for the independent review described below are brought to the attention of the General Manager, Nuclear Plant Operations.

The reviews are part of the normal duties of plantsupervisory personnel in order to provide timely and continuing monitoring of operating activities inorder to assist the General Manager, Nuclear Plant Operations in keeping abreast of general plantconditions and to verify that day-to-day operations are conducted safely in accordance with theestablished administrative controls.

The General Manager, Nuclear Plant Operations ensures the timelyreferral of the applicable matters discussed in the reviews to appropriate management and independent reviewers.

2.2 Independent ReviewActivities occurring during the operational phase shall be independently reviewed on a periodic basis.The independent review function performs the following:

a. Reviews proposed changes to the facility as described in the safety analysis report (SAR). TheIndependent Safety Review Body (Plant Safety Review Committee (PSRC))/Independent ReviewCommittee (Nuclear Safety Review Committee (NSRC)) also verifies that changes do notadversely affect safety and if a technical specification change or NRC review is required.

b. Reviews proposed tests and experiments not described in the SAR prior to implementation.

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

c. Reviews proposed technical specification changes and license amendments relating to nuclearsafety prior to NRC submittal and implementation, except in those cases where the change isidentical to a previously approved change.d. Reviews violations, deviations, and reportable events that are required to be reported to theNRC in writing within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This review includes the results of investigations andrecommendations resulting from such investigations to prevent or reduce the probability ofrecurrence of the event.e. Reviews any matter related to nuclear safety that is requested by the Vice President, NuclearOperations, Plant Manager, or any PSRC/NSRC member.f. Reviews corrective actions for significant conditions adverse to quality.51 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1g. Reviews internal audit reports.h. Reviews the adequacy of the internal audit program every 24 months.Plant Safety Review Committee The PSRC functions as an independent review body. In discharging its review responsibilities, the PSRCkeeps Safety considerations paramount when opposed to cost or schedule considerations.

One or moreorganizational units may collectively perform this function.

1. PSRC reviews are supplemented as follows:a. A qualified person, independent of the preparer, reviews proposed changes in theprocedures as described in the SAR prior to implementation of the change to determine if atechnical specification change or NRC approval is required.

b. Audits of selected changes in the procedures described in the SAR are performed to verifythat procedure reviews and revision controls are effectively implemented.

c. Competent individual(s) or group(s) other than those who performed the original designbut who may be from the same organization verify that changes to the facility do not resultin a loss of adequate design or safety margins.2. The results of PSRC reviews of matters involving the safe operation of the facility are periodically independently reviewed with a minimum of one such review being conducted yearly. This review isintended to support management in identifying and resolving issues potentially affecting safe plantoperation.

This review supplements the existing corrective action programs and audits.a. The review is performed by a team consisting of personnel with experience andcompetence in the activities being reviewed, but independent from cost and scheduleconsiderations and from the organizations responsible for those activities.

The PSRCsupervisor or chairman has a minimum six (6) years combined managerial and technical support experience.

The members of the PSRC should have a minimum of five (5) years ofexperience in their own area of responsibility as applicable to the activities being reviewed(i.e., a minimum of five years of experience in one of the twelve areas listed below:(1) Nuclear power plant operations (2) Nuclear engineering (3) Chemistry and radiochemistry (4) Metallurgy (5) Nondestructive testing(6) Instrumentation and control(7) Radiological safety(8) Mechanical engineering (9) Electrical engineering (10) Administrative control and quality assurance practices (11)Training (12) Emergency plans and related procedures and equipment).

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

52 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1c. Results of the review are documented and reported to responsible management, PSRCChairman, and NSRC.d. Management periodically consider issues they determine warrant special attention, such asdeficient plant programs, declining performance trends, employee

concerns, or otherissues related to safe plant operations and determine what issues warrant the review.e. Management determines the scheduling and scope of review and the composition of theteam performing the review.Nuclear Safety Review Committee

1. The NSRC is assigned independent review responsibilities.

2. The NSRC reports to Vice President Nuclear Operations.

3. The NSRC is composed of no less than 5 persons and no more than a minority of members are fromthe on-site operating organization.

For example, at least 3 of the 5 members must be from off-site if there are 5 members on thecommittee.

A minimum of the chairman or alternative chairman and 2 members must be presentfor all meetings.

4. During the period of initial operation, meetings are conducted no less frequently than once percalendar quarter.

Afterwards meetings are conducted no less than twice a year.5. Results of the meeting are documented and recorded.

6. Consultants and contractors are used for the review of complex problems beyond the expertise ofthe off site/on site independent review committee.

7. Persons on the NSRC are qualified as follows:a. Supervisor or Chairman of the NSRC-Education:

baccalaureate in engineering or related science-Minimum experience:

6 years combined managerial and technical supportb. NSRC membersEducation:

Baccalaureate in engineering or related science for those Independent reviewpersonnel who are required to review problems in-nuclear power plant operations,

-nuclear engineering

-chemistry and radiochemistry,

-metallurgy,

-nondestructive testing,-instrumentation and control,-radiological safety,-mechanical engineering, and electrical engineering.

53 V. C. Summer Nuclear Station Unit 1Quality Assurance Program.

Description Revision 1High school diploma for those independent review personnel who are required to review problemsin administrative control and quality assurance practices,

training, and emergency plans and relatedprocedures and equipment.

Minimum experience:

5 years experience in their own area of responsibility (nuclear power plantoperations, nuclear engineering, chemistry and radiochemistry, metallurgy, nondestructive testing,instrumentation and control, radiological safety, mechanical engineering, and electrical engineering, administrative control and quality assurance practices,

training, and emergency plans and relatedprocedures and equipment).

2.3 TECHNICAL REVIEW AND CONTROL2.3.1 ACTIVITIES Activities which affect nuclear safety shall be conducted as follows:a. Procedures required by Technical Specification 6.8 and other procedures which affect plantnuclear safety, and changes thereto, shall be prepared,

reviewed, and approved.

Each suchprocedure or procedure change shall be reviewed by an individual/group other than theindividual/group which prepared the procedure or procedure change, but who may be from thesame organization as the individual/group who prepared the procedure or procedure change.Procedures other than administrative procedures will be approved as delineated in writing bythe General Manager, Nuclear Plant Operations.

The General Manager, Nuclear PlantOperations will approve administrative procedures, security implementing procedures, andemergency plan implementing procedures.

Temporary approval to procedures which clearly donot change the intent of the approved procedures can be made by two members of the plantmanagement staff, at least one of whom holds a Senior Reactor Operator's License.

For changesto procedures which may involve a change in intent of the approved procedures, the personauthorized above to approve the procedures shall approve the change.b. Proposed changes or modifications to plant nuclear safety-related structures,

systems, andcomponents shall be reviewed as designated by the General Manager, Nuclear Plant Operations.

Each such modification shall be designed as authorized by Engineering Services and shall bereviewed by an individual/group other than the individual/group which designed themodification, but who may be from the same organization as the individual/group whichdesigned the modification.

Implementation of modifications to plant nuclear safety-related structures,

systems, and components shall require concurrence by the General Manager,Nuclear Plant Operations.

C. Proposed tests and experiments which affect nuclear plant safety and are not addressed in theFinal Safety Analysis Report shall be reviewed by an individual/group other than theindividual/group which proposed the test or experiment.

d. Events reportable pursuant to the Technical Specification 6.9 and violations of Technical Specifications shall be investigated and a report prepared which evaluates the event and whichprovides recommendations to prevent recurrence.

Such report shall be approved by the GeneralManager, Nuclear Plant Operations and forwarded to the Chairman of the NSRC.54 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1e. Individuals responsible for reviews performed in accordance with 2.3.1 a through d above shallbe members of the plant staff that meet or exceed the qualification requirements of Section 4 ofANSI 18.1, 1971, as previously designated by the General Manager, Nuclear Plant Operations.

Each such review shall include a determination of whether or not additional, cross-disciplinary review is necessary.

If deemed necessary, such review shall be performed by the reviewpersonnel of the appropriate discipline.

f. Each review will include a determination of whether or not prior NRC approval is required.

g. Procedures listed in Part V, Section 3.2 and Technical Specifications 6.8.1, and changes thereto,shall be reviewed prior to implementation as set forth in Part V, Sections 2.2 and 2.3 above.2.3.2 RECORDSRecords of the above activities shall be provided to the General Manager, Nuclear PlantOperations, PSRC and/or NSRC as necessary for required reviews.2.4 RECORD RETENTION In addition to the applicable record retention requirements of Title 10, Code of FederalRegulations, the following records shall be retained for the duration of the unit operating license.a. Records and drawing changes reflecting unit design modifications made to systems andequipment described in the UFSAR.b. Records of new and irradiated fuel inventory, fuel transfers, and assembly burnuphistories.

c. Records of radiation exposure for all individuals entering radiation control areas.d. Records of gaseous and liquid radioactive material released to the environment.

e. Records of transient or operational cycles for those unit components identified inTS Table 5.7-1.f. Records of reactor tests and experiments.

g. Records of training and qualification for current member of the unit staff.h. Records of in-service inspections performed pursuant to the Technical Specifications andthis Part V of the QAPD.i. Records of Quality Assurance activities as specified in the NRC's approved SCE&G positionon Regulatory Guide 1.28, Revision 3, August 1985.j. Records of reviews performed for changes made to procedures or equipment or reviewsof tests and experiments pursuant to 10 CFR 50.59 and 10 CFR 72.48.k. Records of meetings of the PSRC and the NSRC.I. Records of the service lives of all hydraulic and mechanical snubbers defined in TS 3.7.7including the date at which the service life commences and associated installation andmaintenance records.m. Records of secondary water sampling and water quality.n. Records of analysis required by the radiological environmental monitoring program.o. Records and logs of unit operation covering time interval at each power level.p. Records and logs of principal maintenance activities, inspections, repair, and replacement of principal items of equipment related to nuclear safety.q. All Reportable Events submitted to the Commission.

55 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1r. Records of surveillance activities, inspections, and calibrations required by theTechnical Specifications and Part V of the QAPD.s. Records of changes made to the procedures required by TS 6.8.1t. Records of radioactive shipments.

u. Records of sealed source and fission detector leak tests and results.v. Records of annual physical inventory of all sealed source material of record.w. Records of reviews performed for changes made to the Offsite Dose Calculation Manualand the Process Control Program.56 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1Section 3 Operational Procedures The following is a description of the various types of procedures used by SCE&G to govern the design,operation, and maintenance of its nuclear generating plants. SCE&G follows the guidance of Appendix Ato Regulatory Guide 1.33 in identifying the types of activities that should have procedures or instructions to control the activity.

Each procedure shall be sufficiently detailed for a qualified individual to performthe required function without direct supervision, but need not provide a complete description of thesystem or plant process.3.1 Format and ContentThe SCE&G procedure format and content include the following elements as appropriate to the purposeor task to be described:

" Title/Status Each procedure is given a title descriptive of the work or subject it addresses, and includes arevision number and/or date and an approval status." Purpose/Statement of Applicability/Scope The purpose for which the procedure is intended is clearly stated (if not clear from the title).The systems, structures, components, processes or conditions to which the procedure appliesare also clearly described.

" References Applicable references, including reference to appropriate Technical Specifications, arerequired.

References are included within the body of the procedure when the sequence ofsteps requires other tasks to be performed (according to the reference) prior to or concurrent with a particular step." Prerequisites/Initial Conditions Prerequisites/initial conditions identify those independent actions or procedures that must beaccomplished and plant conditions which must exist prior to performing the procedure.

Aprerequisite applicable to only a specific portion of a procedure is so identified.

" Precautions Precautions alert the user to those important measures to be used to protect equipment andpersonnel, including the public, or to avoid an abnormal or emergency situation duringperformance of the procedure.

Cautionary notes applicable to specific steps are included inthe main body of the procedure and are identified as such." Limitations and actionsLimitations on the parameters being controlled and appropriate corrective measures to returnthe parameter to the normal control band are specified.

" Main bodyThe main body of the procedure contains the step-by-step instructions in the degree of detailnecessary for performing the required function or task.57 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1" Acceptance criteriaThe acceptance criteria provide the quantitative or qualitative criteria against which thesuccess or failure (as of a test-type activity) of the step or action would be judged." Checklists Complex procedures utilize checklists which may be included as part of the procedure orappended to it.3.2 Procedure TypesAdministrative Control Procedures The administrative control procedures and directives provide a clear understanding of operating philosophy and management policies to ensure safe operation of the plant within the limits set by theoperating license and Technical Specifications.

They provide that plant activities are conducted in amanner that will protect the general public, plant personnel, and equipment.

A description of theseprocedure categories is as follows:* Plant Organization and Responsibility Procedures These procedures describe the plant organization and give the responsibility of the individuals byposition and authority to operate the plant in a safe and efficient manner." Development, Review, Approval, and Control of Safety-Related Plant Procedures These procedures describe the method by which station procedures are written, the control processfor review and approval, and the system utilized to revise the procedures where needed.Administrative procedures, security plan implementing procedures, and emergency planimplementing procedures receive final approval by the General Manager, Nuclear Plant Operations or his/her designated alternate.

They are reviewed under the direction of a supervisor from a groupother than the originating group before final approval.

Conduct of Plant Operations Procedures These procedures describe the rules and instructions issued by the General Manager, Nuclear PlantOperations pertaining to personnel conduct and control.

These rules and instructions provide a clearunderstanding of operating philosophy and management policies.

They delineate the authority andresponsibility of the Reactor Operators and Senior Reactor Operators for the safe operation of thereactor.

They establish the rules for procedure use and the designation of the persons responsible toauthorize a temporary change to an approved procedure.

Additional procedures establish standardoperating orders which deal with such matters as job turnover and relief, designation of the confinesof the Control Room including a diagram of the Control Room that indicates the area designated asat the controls, transmittal of operating data, limitations on access to equipment, and other suchmatters.

Provisions are made for periodic review and updating of standing orders. Instructions which have short time applicability such as housekeeping, publications and their distribution, andpersonnel actions are issued as special orders.58 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1These procedures define the procedural steps for relief of shift personnel.

Checklists are providedfor the oncoming and off-going Control Room Supervisor and the oncoming Shift Supervisor tocomplete and sign. These checklists provide assurance that actual plant parameters are withinallowable limits and that required systems are available and are in proper alignment for theprevention and mitigation of operational transients.

Systems and components that are in adegraded mode of operation permitted by Technical Specifications shall be listed and time indegraded mode is compared with Technical Specification action statements.

Auxiliary Operatorchecklists include any equipment under maintenance or test that could degrade a system or initiatean operational transient and shall include criteria for acceptable status. The. Operations Supervisor will make unannounced audits of shift relief to evaluate the effecti%/Pnp-nf shift rplipfand turnover.

Also these procedures establish the authority and responsibility of the person in charge of theControl Room to limit access.Conduct of Plant Operations administrative procedures establish actual work time limitations forplant shift personnel who maintain or operate any structures,

systems, or components important to safety.Shift Supervisor's Responsibility Upper level management shall issue a directive that establishes the management responsibility forthe Shift Supervisor under all plant conditions.

It shall contain clear delineation of management chain of authority as to who can, and when the Shift Supervisor is relieved of the responsibility fordirect control of the plant.An administrative procedure is provided that gives the authority and responsibilities of the ShiftSupervisor, Control Room Supervisor.

Control Room Operator, and other shift personnel.

Both on the job training and classes emphasize responsibility for safe operation andmanagement functions as given in the administrative procedure.

A review of administrative duties of the Shift Supervisor has been conducted by senior plant andcorporate management.

Additional administrative personnel have been added to the operating group that relieves the Shift Supervisor of routine duties that distract from the management responsibility for assuring the safe operation of the plant.Control of Plant Documents Procedures These procedures describe the preparation and retention of plant records.

Retention periods areestablished to assure the ability to reconstruct significant events and satisfy statutory requirements.

Corrective Action Reporting Procedures These procedures assure that conditions adverse to plant safety such as equipment and materialmalfunction, abnormal occurrences, and nonconformances are promptly identified andcorrected.

They ensure that the cause of the conditions is determined and reported to theappropriate level of management for corrective action.59 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1" Equipment Control Procedures These procedures describe the control measures and actions such as locking,

tagging, notification, removal of tags, and identification of equipment.

They provide for control of equipment to maintainreactor and personnel safety and to avoid unauthorized operation of equipment.

They provideinstructions for verifying correct performance of operating activities.

" Design Modification Control Procedures These procedures ensure that plant modifications

satisfy, at a minimum, the same designrequirements as the original equipment.

Procurement and Materials Control Procedures These procedures provide for the control of purchased

material, equipment, and services.

Theyprovide for proper identification, quality level requirements,

control, handling,

storage, and shippingof materials, parts, and components.

These procedures also provide for the proper documentation to ensure quality of safety-related

systems, equipment, and structures after maintenance or repair." Control and Calibration of Test Equipment and Instrumentation Procedures These procedures ensure that testing and measuring devices are of the proper range and type andare controlled, calibrated,

adjusted, and maintained at specified intervals or prior to use to assurethe necessary accuracy of calibrated devices.

Records are made and equipment suitably markedto indicate calibration status.* Control of Special Processes During Operations Procedures These procedures assure that special processes are accomplished under controlled conditions inaccordance with applicable codes, standards, specifications,

criteria, and other specialrequirements using qualified personnel and procedures.

Non-Conformance Control/Deficiency Reporting Procedures These procedures provide for control of items, services, or activities which do not conform torequirements.

These procedures include instructions for identification, documentation, segregation, notification of affected organizations, and method of disposition of such items,services, or activities.

" Test Control Procedures These procedures assure that testing required to demonstrate that an item will performsatisfactorily in service is accomplished properly.

Test procedures incorporate or reference therequirements and acceptance limits contained in applicable design documents.

These testprocedures may include preoperational tests, initial operational phase tests, surveillance tests, andtests during design, fabrication, and construction activities associated with plant maintenance andmodificat 60 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1* Feedback of Operating Experience These procedures establish a program for evaluating operating plant experience and providing the results of the evaluations, as necessary, to pertinent plant personnel.

The services of"Industry Groups" such as INPO will be utilized to the extent possible in the performance of this* Control Room Operating Procedures Control Room operating procedures are those procedures that are performed by the licensedControl Room Operator or under his/her direction and control.

They are a preplanned method forthe conduct of operations to minimize reliance on memory. These procedures include anticipated operating conditions, the normal method of control, means for and limits on operation of the plant,or plant systems that affect the safety of the plant and the public.* General Operating Procedures General Operating Procedures (GOP) provide for the integrated operation of the plant. Theseprocedures provide the sequence of plant operations to take the plant from given initial conditions to final expected conditions.

Associated system operating procedures are referenced as applicable.

Necessary precautions are inserted at critical points.* Emergency Operating Procedures Emergency Operating Procedures (EOP) are written so that a trained operator and crew will be ableto identify an emergency from the symptoms available to them and take immediate action on theexpected course of events to place the plant in a known safe condition and to mitigate theconsequence of a serious condition should it occur. Since emergencies may not follow anticipated patterns these procedures provide sufficient flexibility to accommodate variations.

Those sections ofthe procedure that require immediate response action from the operating crew are committed tomemory. Considerable judgment on the oart of comoetent nersonnel is exercised before departure from these procedures.

System Operating Procedures System Operating Procedures (SOP) provide instructions for energizing, starting up, shuttingdown, changing modes of operation, and other instructions for operations of systems related tothe safety of the plintThese procedures are concerned with systems only and include valve and switch lineups, controloperations, and instrumentation within the system boundaries.

They are subdivided into normaloperations, infrequent operations, and off normal conditions in the main body.* Annunciator Response Procedures Annunciator Response Procedures (ARPs) are written to instruct the operator on the proper action tobe taken in response to annunciators on the Main Control Board. They contain annunciator identification, inputs into the annunciator, and logical operator responses to be taken to ensure61 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1proper corrective action. The ARPs are identified by panel number. An illustration in the beginning of the ARP depicts the annunciator panel. In the case of computer alarms each alarm's uniqueidentifier is listed.When use of the ARP is required, the operator selects the proper tab by an alarm panelnumber.Fuel Handling Procedures Fuel Handling Procedures (FHP) are written to specify actions and philosophy for core alterations andpartial or complete refueling operations.

They include requirements for continuous monitoring ofneutron flux throughout core loading and audible annunciation of abnormal flux increases.

Theduties of personnel assigned to refueling, such as periodic data taking, response actions to alarmsduring refueling, and criteria for stopping the refueling are specified.

Also, instructions for propersequence of events, verification, and frequency of sampling to ensure shutdown margin,communications between the control room and the fuel loading station, documentation of final fuelcomponent serial numbers and location, containment integrity requirements, and rules for periodswhen refueling is interrupted are included.

System operating procedurp,

-. ...... "4 n, ired.Special Procedures Special procedures are written and issued to direct operations during testing, refueling, maintenance, and modifications.

These procedures provide guidance in unusual situations notcovered by existing procedures.

They ensure orderly and uniform operations for short periods whenthe plant, a system, or a component is not performing in a normal manner and an existing procedure does not apply. Special procedures designate the period of time during which they may be used andare subject to the same review and approval process as other operating procedures.

Maintenance and Modification Procedures Maintenance and modification procedures define the policies and practices by which structures,

systems, and components are kept in a condition of good repair so that they are capable of reliablyperforming their intended functions.

This includes those activities performed by maintenance orcontractor personnel to maintain, repair, or modify safety-related equipment.

Additional relatedactivities covered are those by operating personnel to ensure that a planned maintenance activitycan be safely accomplished, that proper plant operating conditions exist, to authorize the release ofequipment to be maintained using equipment control procedures, and to assure that the equipment has been returned to normal operating status at the completion of maintenance work, as well asverification of functional acceptability.

Procedures are written to assure measurement accuracies are adequate to keep safety parameters and controls within safety and operational limits. Thisinstrumentation includes interlocks, alarm devices,

sensors, readout instruments, transmitters, signalconditioners, laboratory equipment, key recorders, and protective logic circuits.

Calibration, testing,and checking of instrumentation channels are performed at the frequency specified in Technical Specifications.

62 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1Emergency Plan Procedures These procedures are written in sufficient detail that a qualified individual can perform the requiredactions without supervision.

They provide a step by step order and logical sequence in a concisemanner but are flexible enough to give latitude to the user for the exercise of judgment inimplementing specific actions or parts of the procedure.

These instructions specify the individual ororganization having authority and responsibility for performing critical tasks. The actions to beperformed by support agencies and the coordination with other elements of the emergency organization are also specified.

Guidelines for initiating recovery after the emergency is over torestore the plant to the pre-emergency conditions are given." Chemical Radiochemical Control Procedures These procedures provide instructions for maintaining reactor coolant, condensate, and feedwater within prescribed quality limits and include the nature and frequency of sampling and analysis.

They also include laboratory instructions and instructions for calibration of laboratory equipment.

Limitations on concentrations of agents that could cause corrosive attack, foul heat transfersurfaces, or become sources of radiation hazards due to activation are given.* Plant Radiation Protection Procedures These procedures cover plant personnel, other personnel temporarily

assigned, contractor andvendor personnel, and visitor protection to maintain occupational dose rate to as low as reasonably achievable.

They provide coverage for all normal operations and anticipated operational occurrences.

This includes refueling,

purging, fuel handling and storage, also radioactive materialhandling, processing, use, and storage.

Other areas covered are maintenance, routine operational surveillance, inservice inspection, and calibration.

" Plant Security Procedures These procedures are written to supplement physical barriers and features designed to controlaccess to the plant and as appropriate to sensitive areas and equipment within the plant.Information concerning design features and administrative provisions is protected and distribution islimited." Surveillance Test Procedures These tests and inspections are performed in accordance with the Technical Specifications toensure that the required reliability of safety systems is maintained.

These surveillance testprocedures contain a description of the test objectives, the acceptance criteria used to evaluate thetest results, and the prerequisites for performing the test. They include any special conditions to beused to simulate normal or abnormal operating conditions, limiting conditions, the test procedure, and any special test equipment or calibrations required to conduct the test. A master surveillance

schedule, reflecting the status of surveillance testing is also maintained.

Additional controlprocedures ensure timely conduct of surveillance

testing, appropriate documentation, reporting, and evaluation of test results.

Significant deficiencies identified by the tests are reported tomanagement.

The deficiencies will be evaluated and the condition corrected in a timely manner.63 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1Test and Inspection Procedures These documents provide the necessary measures to assure quality is achieved and maintained forthe nuclear facilities.

The instructions for tests and inspections may be included within otherprocedures, such as installation and maintenance procedures, but will contain the objectives, acceptance

criteria, prerequisites for performing the test or inspection, limiting conditions, andappropriate instructions for performing the test or inspection, as applicable.

These procedures alsospecify any special equipment or calibrations required to conduct the test or inspection and providefor as appropriate documentation and evaluation by responsible authority to assure test orinspection requirements have been satisfied.

Where necessary, hold or witness points are identified within the procedures and require appropriate approval for the work to continue beyond thedesignated point. These procedures provide for recording the date, identification of thoseperforming the test or inspection, as-found condition, corrective actions performed (if any), and as-left condition, as appropriate, for the subject test or inspection.

Fire Protection Procedures These associated procedures provide the necessary planning and instructions to ensure adequatefire protection.

Included, but not limited to, are the provisions made in the Fire Protection Evaluation Report (FPER). The responsibilities for preparation of schedules and procedures requiredby the Operations, Maintenance, and Technical Groups are stated in this report and are detailed inadministrative procedures.

64 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1Section 4 Control of Systems and Equipment During Plant Operation Permission to release systems and equipment for maintenance or modification is controlled bydesignated operating personnel and documented.

Measures, such as installation of tags or locks andreleasing stored energy, are used to ensure personnel and equipment safety. When entry into a closedsystem is required, SCE&G has established control measures to prevent entry of extraneous material andto assure that foreign material is removed before the system is reclosed.

Administrative procedures require the designated operating personnel to verify that the system orequipment can be released and determine the length of time it may be out of service.

In making thisdetermination, attention is given to the potentially degraded degree of protection where one subsystem of a redundant safety system is not available for service.

Conditions to be considered in preparing equipment for maintenance

include, for example:

shutdown margin; method of emergency core cooling;establishment of a path for decay heat removal; temperature and pressure of the system; valvesbetween work and hazardous material;

venting, draining and flushing; entry into closed vessels;hazardous atmospheres; handling hazardous materials; and electrical hazards.When systems or equipment are ready to be returned to service, designated operating personnel controlplacing the items in service and document its functional acceptability.

Attention is given to restoration ofnormal conditions, such as removal of jumpers or signals used in maintenance or testing, or actions suchas returning valves, breakers or switches to proper start-up or operating positions from "test" or"manual" positions.

Where necessary, the equipment placed into service receives additional surveillance during the run-in period.Independent verifications, where appropriate, are used to ensure that the necessary measures havebeen implemented correctly.

The minimum requirements and standards for using independent verification are established in company documents.

65 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 1SECTION 5 Plant Maintenance SCE&G establishes controls for the maintenance or modification of items and equipment subject to thisQAPD to ensure quality at least equivalent to that specified in original design bases and requirements, such that safety-related structures, systems and components are maintained in a manner that assurestheir ability to perform their intended safety function(s).

Maintenance activities (both corrective andpreventive) are scheduled and planned so as not to unnecessarily compromise the safety of the plant.In establishing controls for plant maintenance, SCE&G commits to compliance with NQA-1-1994, Subpart 2.18, with the following clarifications:

Where Subpart 2.18 refers to the requirements of ANS-3.2, it shall be interpreted to mean theapplicable standards and requirements established within the QAPD.* Section 2.3 requires cleanliness during maintenance to be in accordance with Subpart 2.1. Thecommitment to Subpart 2.1 is described in the QAPD, Part II, Section 13.2.* Subpart 2.18, Section 5(a), requires tools used during maintenance to be included inmaintenance records.

The term "tools" shall be interpreted to mean calibrated tools tomeet the intent of Section 2.1(e) by its reference to "...calibrated test equipment andtools."66 SAP-01 39ATTACHMENT IIPAGE 1 OF 2REVISION 34DOCUMENT REVIEW FORMPage 1 of 3Dcmen Idntfiato Originators Name: H. KunkleExt: 54086Mail Code: 829Date: 6/10/13 Document No.: QAPD Revision No.: 1 Change Letter:Title: Quality Assurance Program Description 7Z SR i-QR ] NNSDevelopment Process:Permanent:

(check one) M Normal Rev/Chg or [-] Editorial Correction

[] Temporary ApprovalDescription:

Revise the QAPD to apply V. C. Summer's previously-approved quality assurance program to theISFSI as allowed by 10CFR72, Section 72.140(d);

and to address several editorial and organizational changes.

Adetailed summary is provided on Page 2.Reason/Basis for Change: A detailed summary is provided on Page 2.Is the SCOPE of the procedure affected by this change? NO El YES FaTemporary ApprovalFinal approval required by:(30 days)DateQR DC&R (Person Notified)

/SSDou et eiwrs(nloueC 0 ;:!;,i~;,r

0PositionORSVP/CNOVPNOVPNNODNTType/Print Name_D G-c4A1 .So oesTcA Jh, rCl'ýA1Yes/NoLF1: 0PositionMQS (NND)MNT (Unit 1)MNT (NND)RMSType/Print NameC" uommentsYes/NoX EZ1:10QR Qualification Verified?

[KYes Comment Due Date J-k-L, 3,/ 3Concurrence by Designated Supervisor:

I Standard review period is 21 daysOS__p___te.or

.(per_6.4.8.C)

GM concurrence for expedited review periodPr- imlmntto ActinAll Comments Resolved El None Received IYes ________,___-______

/ " nator/ DateCommitments Addressed per SAP-0630

[ NA 3] Yes P/CAP # El MLSAInitial/Date 50.59 Applicability/Review Completed (SAP-01 07) El NA 0 Yes, AttachedSecurity Compliance Review Completed (SAP-0163)

IWNA EL Yes (Security review required)

Pre-implementation Training Completed

[DýNA F1 YesTraining required after implementation

[ NA FI Yes, CR #PSRC Review Completed

[YNA 3] Yes, Mtg. No.NSRC Review Completed M NA [] Yes, Mtg. No.OMMS Update Required LENA E] Yes Planner Notified Initial/Date Superv1s~o_

& -/-A T--MM A 'o,1a, Authortyate

/* Failure by the "Additional Reviewers" to provide comments within 5 working days following the comment due datemay be considered as "No Comment".

SAP-0139ATTACHMENT IIPAGE 2 OF 2REVISION 34DOCUMENT REVIEW FORMPage 2 of 3Document No.: QAPD Rev. No. 1 Chg. Ltr.DESCRIPTION CONTINUED:

Summary of changes:1. Incorporate necessary changes throughout the current QAPD to apply V. C. Summer's previously-approved quality assurance program to the ISFSI as allowed by 10CFR72, Section 72.140(d).

Therevision will include and address the recordkeeping requirements of Section 72.174 as required bySection 72.140(d).

2. CR-10-03108, Action 225: Revise QAPD, Part II, Section 10.3 by adding the following as a secondbullet to Section 10.3:Subpart 2.4 commits SCE&G to IEEE 336-1985.

IEEE 336-1985, Step 1.1.2 refers to ANSI/ANS3.2-1982.

SCE&G commits to ANSI N18. 7-1976/ANS 3.2.The basis for the above change is Unit 1 is committed to ANSI/ANS N18.7/ANS 3.2 through SCE&G'sposition to Regulatory Guide 1.33 Rev. 2, 2/78 as stated in FSAR Chapter 3, Appendix 3A.3. CR-10-03108, Action 259:a) Revise QAPD, Part II, Subsection 2.5, Second paragraph to read "The minimum qualifications ofthe Managers, Quality Systems and Materials

& Procurement are that he/she..."

b) Revise QAPD Part V, Section 5, to add the following bullet as a clarification to the commitment toNQA-1-1994, Subpart 2.18:Subpart 2.18, Section 5(a), requires tools used during maintenance to be included inmaintenance records.

The term "tools" shall be interpreted to mean calibrated tools to meetthe intent of Section 2.1(e) by its reference to "...calibrated test equipment and tools."4. CR-12-00441, Action 2: Revise the QAPD, after NRC approval, to address the split qualityresponsibilities of the position (as listed in the submitted QAPD) Manager, Business

& Financial Services into two positions,

Manager, Business Services and Manager, Financial Services.

(Action 2was discussed with Nuclear Licensing and Human Resources as compared to OrgPlus organizational charts. Final corrective action resulted in changes to the Table of Contents; Part II, Section 1; andFigure 11.1-2 to address the titles/positions of Manager, Business

& Financial Services and Manager,Nuclear Finance Administration.)

5. CR-12-00930, Action 8:a) Revise QAPD, Part II, Sections 1.1.2, 1.1.3, and Figure 11.1-1 to indicate the position for"President

& Chief Operating Officer of SCE&G" and "Executive Vice President of Generation" isa single office with dual responsibilities.

b) Revise QAPD, Part II, Section 1.2.4.3, as follows:

"The MQS is authorized by this QAPD toidentify concerns adverse to quality directly to the VPNO as indicated by the dotted line reporting shown on Figure 11.1-2 'Unit 1 Plant Management Organization'.

To ensure independence ismaintained between QA and line management, QA shall be excluded from participation in linefunctions, assessments, or evaluations.

Independence shall not be subordinated to achieve costor schedule objectives."

This change further clarifies QAPD requirements related to themaintenance of independence by the Quality Assurance organization as addressed in Sections1.2.4.3, 1.3, and 1.5.* Failure by the "Additional Reviewers" to provide comments within 5 working days following the comment duedate may be considered as "No Comment".

SAP-0139ATTACHMENT IIPAGE 2 OF 2REVISION 34DOCUMENT REVIEW FORMPage 3 of 36. CR-13-00799, Action 1: Revise the QAPD to change the title of the VPNND to VPNNO. Anorganizational change (title) at NND was made, as documented in SCANA OrgPlus companyorganizational charts, without evaluating the impact on Unit 1's QAPD. (Requested change was madeto the Table of Contents; Part II, Section 1; and Figure 11.1-1.)7. Address numerous typographical, grammatical, and editorial related items throughout the QAPD.8. Clarify the responsibilities of the Director, Nuclear Training, and Managers, Nuclear Training, for Units1, 2 and 3 in Section 1.1.7 as compared to Figure 11.1-2.9. Enhance Figures 11.1-1 and 11.1-2 to appropriately identify the organizational structure depicted in PartII, Section 1, and OrgPlus.REASON/BASIS FOR CHANGE CONTINUED:

Reference Description Continued Section above.DOCUMENT REVIEWERS CONTINUED:

Comments CommentsPosition Type/Print Name Co. e "sPosition Type/Print Name Y esYes/No Yes/NoGMNPO /JCL'o Of.,* C1-- CA I`IEIIGMNSS El 1 EL El* GMES V W.- ,,,lLILI" ' oi ML b ":*:"

e f~ I. n .:.,<.-.

DI-I0"0W.'w El IN :70 "F::: ElMNL IX' E -E_ E____ lI.... .; 0 E]NEl, E* Failure by the "Additional Reviewers" to provide comments within 5 working days following the comment duedate may be considered as "No Comment".

QSP-1 08Attachment IIPage 1 of 4Revision 050.54(a)

Evaluation QAPD Revision Request Tracking Number 2013-011.0 Yes X No Is the revision limited to administrative improvements and clarifications, spelling corrections, punctuation, or editorial items?Basis: In addition to addressing administrative improvements and providing clarifications, the revision addresses organizational related changes and theapplication of the current approved QA program to the ISFSI as allowed by1OCFR72, Section 72.140(d),

clarifications related to commitments or exceptions to standards, and enhancements to ensure that independence is maintained between Quality Assurance and line management.

2.0 Yes X No Is the revision limited to any of the six (6) 50.54(a)changes (i)-(vi)?

Basis: The revision addresses application of the current approved QA program tothe ISFSI, organizational enhancements/clarifications, clarifications related tocommitments or exceptions to standards, and enhancements to ensure thatindependence is maintained between Quality Assurance and line management.

If the answer to either Question 1.0 or 2.0 is YES, the revision is not areduction in commitment.

Do not answer questions 3.0, 4.0 or 5.0 andprocess the revision.

3.0 Yes X No Does the revision take exception to any part of aRegulatory Guide identified in the QAPD or will the method of implementing theRegulatory Guide reduce the level of commitment?

Basis: Regulatory Guides, as committed to in the QAPD and the FSAR, Chapter3, are not addressed in this change.4.0 Yes X No Does the revision eliminate or potentially reduce theeffectiveness of a function,

control, or activity described in the QAPD?Basis: Proposed changes do not eliminate or reduce the effectiveness offunctions,

controls, or activities described in the QAPD. The revision addresses QAPD enhancements, clarifications, editorial related corrections, and the additionof the ISFSI to comply with 1OCFR72.

QSP-108Attachment IIPage 2 of 4Revision 050.54(a)

Evaluation QAPD Revision Request Tracking Number 2013-015.0 Yes X No Does the revision diminish the intent or scope, orreduce the effectiveness of the QAPD?Basis: Proposed changes do not diminish the intent, scope, or effectiveness ofthe QAPD. The revision addresses QAPD enhancements, clarifications, andeditorial related corrections.

These changes do not constitute a reduction in thelevel of commitments previously accepted and approved by the NRC asstipulated in 10CFR50.54(a).

Also, the application of the QA program to theISFSI to comply with 1 OCFR72 is considered to be an increase in commitments.

If the answer to question 3.0, 4.0, or 5.0 is YES, the revision is a reduction in commitment and NRC approval is required per 10CFR50.54(a)(4) beforeimplementing the revision.

,I kxA-.'ý --7 (2-LVt1 3Originator Date Reviewer DateApprove-d--M(

-'- bte QSP-1 08Attachment IIPage 3 of 4Revision 050.54(a)

Evaluation 50.54(a)

Evaluation Instructions The intent of 10CFR50.54(a) is to determine if a proposed change to the V.C. SummerQuality Assurance Plan Description (QAPD) would constitute a reduction in the level ofcommitments previously accepted and approved by the NRC. Changes that are areduction in the level of commitment require NRC approval prior to implementing.

Ingeneral, a reduction in a commitment is a change in the quality assurance programdescription that diminishes the intent or scope of the program potentially permitting deficiencies to arise in the design, fabrication, construction or operation of the facility.

The following provides guidance on answering the 50.54(a) screening questions.

Enclosure II should be reviewed when screening QAPD changes.1.0 Changes to the QAPD that are administrative in nature or provide clarifications, spelling corrections, punctuation, or editorial items do not affect commitments.

2.0 The NRC recognizes the following changes to the QAPD as not reducing the level ofcommitment.

(i) The use of a QA standard approved by the NRC which is more recent thanthe QA standard in the licensee's current QA program at the time of thechange;(ii) The use of a quality assurance alternative or exception approved by an NRCsafety evaluation, provided that the bases of the NRC approval are applicable to the licensee's facility; (iii) The use of generic organizational position titles that clearly denote theposition

function, supplemented as necessary by descriptive text, rather thanspecific titles;(iv) The use of generic organizational charts to indicate functional relationships, authorities, and responsibilities, or, alternately, the use of descriptive text;(v) The elimination of quality assurance program information that duplicates language in quality assurance regulatory guides and quality assurance standards to which the licensee is committed; and(vi) Organizational revisions that ensure that persons and organizations performing quality assurance functions continue to have the requisite authority and organizational

freedom, including sufficient independence fromcost and schedule when opposed to safety considerations.

3.0 Part IV, Regulatory Commitments, of the QAPD contains a list of Regulatory Guidesand other quality assurance standards which were selected to supplement andsupport the QAPD. Conformance and exceptions to these Regulatory Guides areidentified in Chapter 3 of the FSAR.4.0 The QAPD defines organizational responsibilities and functions, and controls onactivities performed at the station.

This question evaluates the impact of the revision

.fQSP-1 08Attachment IIPage 4 of 4Revision 050.54(a)

Evaluation on these elements of the quality assurance plan. The intent of this question is todetermine if responsibilities, functions or controls are being eliminated or reduced.Examples to consider:

4.1 Offsite review committee (NSRC) reporting structure changed from VicePresident Nuclear Operations to GMNPO. Although the function is still inplace, this would be considered a reduction since the reporting level waslowered.

However, this would not be a reduction if the reporting level waschanged to the Chief Nuclear Officer.5.0 The QAPD establishes the minimum quality assurance and control on stationactivities (i.e. design, purchasing, fabricating,

handling, shipping,

storing, cleaning,

erecting, installing, inspecting,

testing, operating, maintaining, repairing, refueling, modifying).

In general, a reduction in a commitment is a change that diminishes theintent or scope of the program and control of station activities that potentially permitsdeficiencies to arise in the design, fabrication, construction, or operation of thefacility, resulting in increased risk to the public health and safety.Example to consider:

5.1 A procedure change that would eliminate the independent verification requirement for safety related modifications would be a reduction.

Aprocedure change that permits the design engineer's supervisor to performan independent verification of the originators work may not necessarily be areduction on control since the QAPD provides an exception with certainrestrictions.

,4A SCANA COMPANY Quality Assurance Program Description Title: South Carolina Electric

& Gas Co.V. C. Summer Unit 1 Quality Assurance Program Description Process/Program Owner: Senior Vice President, Nuclear Operations Version Number Effective DateSafety RelatedRevision 2 10/25/13Revision Summary:1. Incorporate changes throughout in Part II Section 1 and Part IV to allow application of theQAPD to all training activities for V. C. Summer Units 2 & 3.2. CR-13-1842, Action 2: Revised Part II, Section 18.1 by adding the following sentence to thesecond paragraph, "Projects or programs that have duration less than two years, or arescheduled such that these activities would not be evaluated during the normal audit cycle shouldbe considered for inclusion in the audit schedule."

3. Address numerous typographical, grammatical, and editorial related items throughout theQAPD.4. A change to the title of General Manager, Organizational Development and Effectiveness (GMOD&E) to General Manager, Organizational Development/

Effectiveness (GMOE) wasmade.Prepared By/Date:Original Signed by Melvin N. Browne on 10/22/13M. N. BrowneManager, Quality SystemsReviewed By/Date:

Approved By/Date:Original Signed by Thomas D. Gatlin on 10/23/13 Original Signed by Jeffrey B. Archie on 10/24/13T. D. Gatlin J. B. ArchieVice President, Nuclear Operations Senior Vice President and Chief Nuclear OfficerNUCLEAR OPERATION COPY NO. ao 1 HCONTROLLED COPY V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 2South-Carolina Electric

& Gas Co.Policy Statement South Carolina Electric

& Gas Co. (SCE&G) shall design, procure, and operate the V. C.Summer nuclear plant in a manner that will ensure the health and safety of the public andworkers.

These activities shall be performed in compliance with the requirements of the Code ofFederal Regulations (CFR), the applicable Nuclear Regulatory Commission (NRC) FacilityOperating

Licenses, and applicable laws and regulations of the state and local governments.

The SCE&G Quality Assurance Program (QAP) is the Quality Assurance Program Description (QAPD) provided in this document and the associated implementing documents.

Together theyprovide for control of SCE&G activities that affect the quality of safety-related nuclear plantstructures,

systems, and components (SSCs) and include all planned and systematic activities necessary to provide adequate confidence that such SSCs will perform satisfactorily in service.The QAPD may also be applied to certain equipment and activities that are not safety-related, butsupport safe plant operations, or where other NRC guidance establishes program requirements.

The QAPD is the top-level policy document that establishes the manner in which quality is to beachieved and presents SCE&G's overall philosophy regarding achievement and assurance ofquality.

Implementing documents assign more detailed responsibilities and requirements anddefine the organizational interfaces involved in conducting activities within the scope of theQAPD. Compliance with the QAPD and implementing documents is mandatory for personnel directly or indirectly associated with implementation of the SCE&G QAP...Original signed by; K.B. Marsh Date: 3/16/11K. B. MarshPresident

/ COO V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 2TABLE OF CONTENTSPO LICY STA T EM EN T .......................................................................................................................

iT a b le o f C o nte nts ...............................................................................................................................

ii -ivPA RT I IN T RO D U CTIO N ....................................................................................................

1SECTIO N 1 G EN ERA L .......................................................................................................

11.1 Sco pe / A pplicability

.............................................................................................

1PA RT II Q A PD D ETA ILS ..................................................................................................

3SECTIO N 1 O RGANIZATIO N ................................................................................................

31.1 SCE&G Corporate Management Organization

................................................

31.1.1 SCANA Chief Executive Officer (CEO) ...................................................

31.1.2 SCE&G President

& Chief Operating Officer (COO) ..............................

31.1.3 Executive Vice President, Generation (EVPG) ....................................

41.1.4 Senior Vice President

& Chief Nuclear Officer (SVP/CNO)

..................

41.1.5 Vice President, Nuclear Operations (VPNO) .......................................

41.1.6 Vice President, New Nuclear Operations (VPNNO) ..............................

41.1.7 Director, Nuclear Training

...................................................................

41.1.7.1 Manager, Nuclear Training (Unit 1) .............................................

51.1.7.2 M anager, Nuclear Training (NND) .....................................................

51.2 V. C. Summer Unit 1 Operating Plant Management Organization

...................

51.2.1 General Manager, Nuclear Plant Operations (GMNPO) .......................

51.2.1.1 M anager, Operations Unit 1 ..........................................................

51.2.1.2 M anager, Operations Units 2 & 3 ........................................................

51.2.1.2 Manager, Maintenance Services

...................................................

61.2.1.3 M anager, Chem istry Services

........................................................

61.2.1.4 Manager, Health Physics and Safety Services

................................

61.2.2 General Manager, Nuclear Support Services (GMNSS) ........................

71.2.2.1 M anager, Nuclear Licensing

...........................................................

71.2.2.2 Manager, Planning

& Scheduling

...................................................

71.2.2.3 M anager, Emergency Planning

......................................................

71.2.2.4 O utage M anager .............................................................................

81.2.2.5 W orkweek M anagement

...............................................................

81.2.3 General Manager, Engineering Services (GMES) ..................................

81.2.3.1 M anager, Design Engineering

........................................................

81.2.3.2 Manager, Plant Support Engineering

.............................................

81.2.3.3 Manager, Materials

& Procurement

...............................................

81.2.4 General Manager, Organizational Development/

Effectiveness (GMOE) 91.2.4.1 Manager, Organizational Development

& Performance

................

91.2.4.2 Manager, Nuclear Protection Services

.........................................

91.2.4.3 M anager, Quality System s ..........................................................

101.2.4.4 Manager, Information and Systems Technology

..........................

101.2.4.5 Supervisor

Records, Documents, and Reproduction

...................

101.2.5 Manager, Business and Financial Services

..........................................

10ii V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 21.31.41.51.6FigureFigureSECTION 22.12.22.32.42.52.6SECTION 33.13.23.33.43.53.6SECTION 44.1SECTION 55.15.25.3SECTION 66.16.26.36.4SECTION 77.17.2SECTION 88.1SECTION 99.1SECTION 1010.110.21.2.6 Corporate Services

.............................................................................

101.2.6.1 Manager, Nuclear Finance Administration

........................................

11Q uality A ssurance

.........................................................................................

11Authority to Stop W ork ..................................................................................

11Quality Assurance Organizational Independence

...........................................

11NQA-1-1994 Com m itm ent .............................................................................

1111.1-1 SCE&G Corporate Organization

.........................................................

1211.1-2 Unit 1 Plant Management Organization

............................................

13QUALITY ASSURANCE PROGRAM .....................................................................

14Responsibilities

..............................................................................................

15Delegation of W ork ........................................................................................

15Periodic Review of the Quality Assurance Program ......................................

15Issuance and Revision to Quality Assurance Program ...................................

15Personnel Q ualifications

.................................................................................

16NQA-1-1994 Commitment

/ Exceptions

.........................................................

16DESIG N CO NTRO L ..........................................................................................

18Design V erification

..........................................................................................

18D esign Records .......................................

I .......................................................

19Computer Application and Digital Equipment Software

...............................

19Setpoint Control ..............................................................................................

19NQA-1-1994 Com m itm ent .............................................................................

19Design Control Commitment (Section

3) .......................................................

20PROCUREMENT DOCUMENT CONTROL ..........................................................

21NQA-1-1994 Commitment

/ Exceptions

.......................................................

21INSTRUCTIONS, PROCEDURES, AND DRAWINGS

...........................................

23Procedure Adherence

.....................................................................................

23Procedure Content .........................................................................................

23NQA-1-1994 Com m itm ent .............................................................................

23DOCUM ENT CONTROL ..................................................................................

24Review and Approval of Documents

.............................................................

25Changes to Docum ents ...................................................................................

25NQA-1-1994 Com m itm ent .............................................................................

26Alternative Commitment to Biennial Review of Procedures (Section 6.1.(d))...

26CONTROL OF PURCHASED

MATERIAL, EQUIPMENT, AND SERVICES

.............

27Acceptance of Item or Service ........................................................................

27NQA-1-1994 Commitment

/ Exceptions

.........................................................

28IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS..

30NQA-1-1994 Com m itm ent .............................................................................

30CONTROL OF SPECIAL PROCESSES

..................................................................

31NQA-1-1994 Com m itm ent .............................................................................

31IN SPECTIO N .....................................................................................................

32Inspection Program ........................................................................................

32Inspector Q ualification

....................................................................................

32iii V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 210.3SECTION 1111.111.2SECTION 1212.112.2SECTION 1313.113.2SECTION 1414.1SECTION 1515.115.2SECTION 1616.116.2SECTION 1717.117.217.3SECTION 1818.118.218.3PART IIISECTION 1SECTION 2PART IVPART VSECTION 1SECTION 2SECTION 3SECTION 4SECTION 5NQA-1-1994 Commitment

/ Exceptions

.........................................................

33TEST CO N TRO L .................................................................................................

34NQA-1-1994 Commitment

.............................................................................

34NQA-1-1994 Commitment for Computer Program Testing ............................

34CONTROL OF MEASURING AND TEST EQUIPMENT

........................................

35Installed Instrument and Control Devices .....................................................

35NQA-1-1994 Commitment

/ Exceptions

.........................................................

35HANDLING,

STORAGE, AND SHIPPING

............................................................

36H ousekeeping

................................................................................................

36NQA-1-1994 Commitment

/ Exceptions

..........................................................

36INSPECTION, TEST, AND OPERATING STATUS ................................................

38NQA-1-1994 Commitment

.............................................................................

38NONCONFORMING MATERIALS, PARTS, OR COMPONENTS

.........................

39Interface with the Reporting Program ............................................................

39NQA-1-1994 Commitment

.............................................................................

39CO RRECTIVE ACTIO N ......................................................................................

40Interface with the Reporting Program ............................................................

40NQA-1-1994 Commitment

/ Exception

..........................................................

40QUALITY ASSURANCE RECORDS ....................................................................

41Record Retention

............................................................................................

41Electronic Records ..........................................................................................

41NQA-1-1994 Commitment

/ Exceptions

.......................................................

41A U D IT S ................................................................................................................

4 2Perform ance of Audits ....................................................................................

42Internal A udits .................................................................................................

43NQA-1-1994 Commitment

.............................................................................

44NON-SAFETY-RELATED SSC QUALITY CONTROL ...........................................

45NON-SAFETY-RELATED SSCs -SIGNIFICANT CONTRIBUTORS TO PLANT SAFETY. 45NON-SAFETY-RELATED SSCs -CREDITED FOR REGULATORY EVENTS .............

48REGULATORY COMMITMENTS

......................................................................

49NRC Regulatory Guides and Quality Assurance Standards

.............................

49Regulatory G uides ..........................................................................................

49Sta n d a rd s ............................................................................................................

5 1ADDITIONAL QUALITY ASSURANCE AND ADMINISTRATIVE CONTROLS FOR THE PLANT OPERATIONAL PHASE ....................................

52D EFIN ITIO N S ...................................................................................................

52REVIEW OF ACTIVITIES AFFECTING SAFE PLANT OPERATION

........................

53OPERATIONAL PROCEDURES

...........................................................................

59CONTROL OF SYSTEMS AND EQUIPMENT DURING PLANT OPERATION

...... 67PLANT MAINTENANCE

...................................................................................

68iv V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 2PART I INTRODUCTION SECTION 1 GENERALSCE&G's Operational Phase Quality Assurance Program Description (QAPD) is the top-level policydocument that establishes the quality assurance policy and assigns major functional responsibilities foroperations activities conducted by or for SCE&G. Organizations within SCE&G Nuclear Operations support New Nuclear Deployment through implementing and supporting the QAPD. The QAPD describes the methods and establishes quality assurance (QA) and administrative control requirements that meet10 CFR 50, Appendix B. The QAPD is based on the requirements and recommendations of ASME NQA-1-1994, "Quality Assurance Requirements for Nuclear Facility Applications,"

Parts I, II, and Ill, as specified inthis document.

The QAPD is applied to the Independent Spent Fuel Installation governed by Subpart G of 10 CFR 72 asspecifically delineated in 72.140. The quality assurance elements and required control detailed in SubpartG are addressed in the QAPD.The QAPD is applied to all training activities associated with V.C. Summer Nuclear Station (VCSNS) Units1, 2 and 3.The QA Program (QAP) is defined by the NRC-approved regulatory document that describes the QAelements (i.e. the QAPD), along with the associated implementing documents.

Procedures andinstructions that control Operational Phase activities were or will be developed prior to commencement of those activities.

Policies establish high-level responsibilities and authority for carrying out important administrative functions which are outside the scope of the QAPD. Procedures establish practices forcertain activities which are common to all SCE&G organizations performing those activities so that theactivity is controlled and carried out in a manner that meets QAPD requirements.

Procedures specific to asite, organization, or group establish detailed implementation requirements and methods, and may beused to implement policies or be unique to particular functions or work activities.

1.1 Scope / Applicability The QAPD applies to operational phase activities affecting the quality and performance of safety-related structures,

systems, and components, including, but not limited to:Designing Storing Operating Maintaining Procuring ErectingRepairing Fabricating Installing Modifying Cleaning Inspecting Refueling Handling TestingTraining Shipping StartupDecommissioning Receiving Safety-related SSCs, under the control of the QAPD, are identified by design documents.

The technical aspects of these items are considered when determining program applicability, including, as appropriate, the item's design safety function.

The QAPD may be applied to certain activities where regulations otherthan 10 CFR 50 and 10 CFR 72, Subpart G establish QA requirements for activities within their scope.1 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 2The QPAD applies to training activities affecting the quality and performance of VCSNS Units 1, 2 and 3.The policy of SCE&G is to assure a high degree of availability and reliability of the V. C. Summer NuclearStation Unit 1 while ensuring the health and safety of its workers and the public. To this end, selectedelements of the QAPD are also applied to certain equipment and activities that are not safety-related, but support safe, economic, and reliable plant operations, or where other NRC guidance establishes quality assurance requirements.

Implementing documents establish program element applicability.

The definitions provided in ASME NOA-1-1994, Part I, Section 1.4, apply to select terms as used in thisdocument.

Additional definitions are provided in Part V, Section 1.0 of this QAPD.2 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 2PARTII QAPD DETAILSSECTION 1 ORGANIZATION This Section describes the SCE&G organizational structure, functional responsibilities, levels of authority and interfaces for establishing, executing, and verifying QAPD implementation.

The organizational structure includes Corporate Support/off-site and on-site functions for Nuclear Plant Operations including interface responsibilities for multiple organizations that perform quality-related functions.

Implementing documents assign more specific responsibilities and duties, and define the organizational interfaces involved in conducting activities and duties within the scope of the QAPD. Management givescareful consideration to the timing, extent and effects of organizational structure changes.SCE&G Vice President Nuclear Operations (VPNO) is responsible to size the Quality Assurance organization commensurate with the duties and responsibilities assigned.

The SCE&G Nuclear Operations organization is responsible for implementing and supporting the QAPD.Several organizations within SCE&G Nuclear Operations support New Nuclear Deployment throughimplementing and supporting the QAPD. These organizations

include, but are not limited to theProcurement Group, Engineering,

Training, Security, Emergency Preparedness, and SCANA Corporate Services.

During the operating life of V. C. Summer Nuclear Station (VCSNS) Unit 1, SCE&G may delegate the workof executing portions of the QAPD. However; SCE&G shall retain the responsibility for its overalleffectiveness.

Outside organizations that perform activities in support of the design, procurement, fabrication, modification, inspection, test or maintenance of the safety related SSCs of the plant are required to workunder an approved QAPD.The following sections describe the reporting relationships, functional responsibilities and authorities fororganizations implementing and supporting the SCE&G OAP. The SCE&G Corporate Organization and theOperating Plant Management Organization are shown in Figures 11.1-1 and 11.1-2.1.1 SCE&G Corporate Management Organization 1.1.1 SCANA Chief Executive Officer (CEO)The Chief Executive Officer (CEO) has the ultimate responsibility for the safe and reliable operation ofeach nuclear unit owned and/or operated by SCE&G. The CEO is responsible for the overall direction andmanagement of the corporation, and the execution of the company policies, activities, and affairs.

TheCEO is assisted by the Executive Vice President, Generation (EVPG), and other executive staff in thenuclear division of the corporation.

1.1.2 SCE&G President

& Chief Operating Officer (COO)The positions of President

& Chief Operating Officer (COO) of SCE&G and the Executive Vice President, Generation (EVPG) are held by the same entity/office with dual responsibilities and reports to the CEO.3 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 2As delegated from the CEO, the President

& Chief Operating Officer (COO) is responsible for the design,construction, and operation of SCE&G's nuclear plants.1.1.3 Executive Vice President, Generation (EVPG)The positions of President

& Chief Operating Officer (COO) of SCE&G and Executive Vice President, Generation (EVPG) are held by the same entity/office with dual responsibilities and reports to the CEO.The EVPG reports to the CEO through the COO. The EVPG is responsible for electric generation, overallplant nuclear safety, and takes the measures needed to provide acceptable performance of the staff inoperating, maintaining, and providing technical support to the nuclear site. The EVPG delegates authority and responsibility for the operation and support of the site through the Senior Vice President/Chief Nuclear Officer (SVP/CNO).

It is the responsibility of the EVPG to provide guidance and direction suchthat safety-related activities, including engineering, construction, operations, operations support,maintenance, and planning, are performed following the guidelines of the quality assurance program.The EVPG is responsible for new nuclear plant licensing, design, and construction through the SVP/CNO.1.1.4 Senior Vice President

& Chief Nuclear Officer (SVP/CNO)

The SVP/CNO reports to the EVPG. The SVP/CNO serves as the Chief Nuclear Officer (CNO) and isresponsible for the safe operation of all current nuclear plant operations along with the design, licensing, and construction of new nuclear plants. The SVP/CNO delegates authority and responsibility for theoperation and support of the operating nuclear plants through the VPNO. The SVP/CNO is responsible for new nuclear plant licensing, design, and construction via the Vice President, New Nuclear Operations (VPNNO) who maintains control of nuclear plant construction through construction completion.

1.1.5 Vice President, Nuclear Operations (VPNO)The Vice President, Nuclear Operations reports to the SVP/CNO and is responsible for the overall safeand efficient operation of VCSNS operating plants and for the implementation of quality assurance requirements in the areas specified by the QAPD.1.1.6 Vice President, New Nuclear Operations (VPNNO)The VPNNO reports to the SVP/CNO and directs the planning and development of the NND staff andorganizational resources.

The VPNNO is responsible for establishing and managing the Engineering, Procurement and Construction contract (EPC) for the development of new nuclear power plants.1.1.7 Director, Nuclear TrainingThe Director, Nuclear Training, reports directly to the SVP/CNO and has the overall responsibility for theaccredited and non-accredited training programs at VCSNS. This includes the responsibility for providing the required training for personnel within VCSNS Units 1, 2 and 3. This position is responsible for themanagement of all nuclear learning programs for VCSNS Units 1, 2 and 3. The position is also part of theSenior Management team that provides overall strategic direction for nuclear operations.

4 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 21.1.7.1 Manager, Nuclear Training Unit 1The Manager, Nuclear Training (Unit 1), reports directly to the Director, Nuclear Training, and isresponsible for the operations-related training programs.

This includes the operation, certification, andcoordination of the maintenance and modification of the VCSNS Unit 1 Simulators.

This also includestraining programs for manager/technical staff personnel, shift engineers/technical

advisors, and licensedand non-licensed operators.

The Manager, Nuclear Training, is also responsible for the maintenance andtechnical training programs for VCSNS Unit 1. This includes training in the areas of Maintenance, HealthPhysics, Chemistry, and Engineering.

1.1.7.2 Manager, Nuclear Training (NND)The Manager, Nuclear Training (NND), reports directly to the Director, Nuclear Training, and isresponsible for the operations-related training programs.

This includes the operation, certification, andcoordination of the maintenance and modification of the VCSNS Units 2 and 3 Simulators.

This alsoincludes training programs for manager/technical staff personnel, shift engineers/technical

advisors, andlicensed and non-licensed operators.

The Manager, Nuclear Training (NND), is also responsible formaintenance and technical training programs for VCSNS Units 2 and 3. This includes training in the areasof Maintenance, Health Physics, Chemistry, and Engineering.

1.2 VCSNS Unit 1 Operating Plant Management Organization The operating organization is responsible for keeping the VPNO abreast of plant conditions and verifying that the day to day operations of the plant are conducted safely and in accordance with all administrative controls including the QAPD.1.2.1 General Manager, Nuclear Plant Operations (GMNPO)The GMNPO reports to the VPNO, and is responsible for overall safe operation of the plant, and hascontrol over those onsite activities necessary for safe operation and maintenance of the plant including operations, chemistry, maintenance, and modification.

Additionally, the GMNPO has overallresponsibility for occupational and public radiation safety. The GMNPO is the Chairman of the PlantSafety Review Committee (PSRC). The GMNPO is also referred to as the Plant Manager.1.2.1.1 Manager, Unit I Operations The Manager, Unit 1 Operations, is responsible for the day to day operation of the plant in a safe andefficient manner in compliance with the operating license.

Manager, Unit 1 Operations is responsible forreview and implementation of normal and emergency training and retraining programs.

He/she has theassistance of the Operations Supervisor.

In the absence of the Manager, Unit 1 Operations, theOperations Supervisor will assume his/her responsibilities.

1.2.1.2 Manager, Units 2 & 3 Operations Under this QAPD, the Manager, Unit 2 & 3 Operations is responsible for review and implementation of normal and emergency training and retraining programs for Units 2 and 3.5 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 21.2.1.3 Manager, Maintenance ServicesThe Manager, Maintenance

Services, is responsible for establishing and implementing the programs formaintenance activities to ensure the continued safe, efficient, and reliable operation of the V. C. SummerStation.

Manager, Maintenance Services is responsible to ensure the Station is maintained in compliance with company policies as they relate to Maintenance Services.

1.2.1.4 Manager, Chemistry ServicesThe Manager, Chemistry Services is responsible for directing and coordinating in-plant chemistry andwater treatment programs.

The Manager, Chemistry

Services, has the responsibility of supervising the Chemistry Supervisors and theChemistry Specialists.

Through this staff, the Manager, Chemistry Services is charged with implementing the chemistry

programs, controlling non-rad releases, maintaining the quality of fluids in various plantsystems within the prescribed limits, operating water treatment facilities, ensuring that writtenprocedures within his/her scope of supervision reflect the criteria of performance standards established by regulatory

agencies, and ensuring that these procedures are followed.

He/she is responsible forensuring that training and retraining of Chemistry personnel are performed as scheduled by the NuclearTraining Department.

The Chemistry Specialists, under the direction of the Chemistry Supervisors, perform tasks incident to the categories of work implemented by the Manager, Chemistry Services.

1.2.1.5 Manager, Health Physics and Safety ServicesThe Manager, Health Physics and Safety Services (MHPSS),

is responsible for directing and coordinating station health physics and radwaste programs.

In addition, the MHPSS establishes occupational safetyand health policy as well as provides technical support to plant staff concerning occupational health andsafety issues.The MHPSS is responsible for directing and coordinating health physics, count room and radwasteprocessing, environmental monitoring, and dosimetry activities.

He/she plans, coordinates and / ordirects supportive station activities with regard to the Radiation Protection, Radiological Effluent Control,Environmental Surveillance, Dosimetry, Radwaste Processing and Disposal, and Analytical programs.

Through evaluations, he/she advises management on program status issues related to these programsand technical guidance for issue resolution.

He/she has direct access to the General Manager, NuclearPlant Operations for matters concerning any phase relative to radiological protection and occupational safety.The MHPSS has the responsibility of supervising the activities of the Health Physics Supervisors and theHealth Physics Specialists as well as the subcontractor support.

Through this staff, the MHPSS is chargedwith controlling the exposure of plant personnel and the public to radiation, preventing the spread ofradioactive contamination, ensuring that written procedures reflect the criteria for establishing performance standards, and ensuring that these procedures are followed.

He/she is responsible forensuring that training and retraining of health physics personnel are performed as well as providing health physics services, radiological engineering expertise, and periodic health physics reviews for allplant personnel.

He/she is responsible for the timely submission of reports pertaining to health physics,radioactive waste releases to the environment, and other areas as required.

6 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 21.2.2 General Manager, Nuclear Support Services (GMNSS)The GMNSS reports to the VPNO, and is overall responsible for Nuclear Licensing; Emergency Services; the Planning and Scheduling processes; Outage Planning; and the scheduling of modification,

testing, andinspection activities.

The GMNSS is responsible for directing the Manager, Nuclear Licensing, to develop and maintaineffective communications with and in response to regulatory authorities; directing the Manager,Emergency Services to ensure emergency plans, programs and procedures are being properly maintained and implemented to meet the requirements of SCE&G and the regulatory authorities; directing theManager, Planning

& Scheduling, to ensure that maintenance activities are properly planned to minimizeunavailability of Safety-Related SSCs; and directing the Outage Manager to ensure that refueling outagesare properly

planned, scheduled, and executed.

1.2.2.1 Manager, Nuclear Licensing (Unit 1)The Manager, Nuclear Licensing (Unit 1) is responsible for the development and implementation of theSCE&G nuclear licensing policy while ensuring that applicable safety and environmental regulatory standards are met. Additionally, the Manager, Nuclear Licensing (Unit 1) is responsible for reviewing general safety questions, safety issues, and safety goals; Probabilistic Risk and Safety Analyses

Programs, NRC industry issues and vendor correspondence for insight on industry activities and practices, andevaluating the potential impact of generic regulatory issues. Working with all SCE&G organizations, theManager, Nuclear Licensing (Unit 1) coordinates the generation, amendment, and distribution of variouslicensing documents, such as the FSAR, and development of Licensee Event Reports (LERs) per 10 CFR50.73 and other written reports required by regulations or the Operating License.

As the principal interface with the Nuclear Regulatory Commission and other regulatory

agencies, the Manager, NuclearLicencing Unit I ensures that the respective directives,

requests, and information documents aredistributed to the proper organizations and that any necessary responses are developed and submitted within the prescribed time frame. Also reporting to the Manager, Nuclear LicensingUnit 1 is the PRAgroup. The PRA group is responsible for the development and maintenance of PRA models used tosupport risk informed applications and for providing risk insights to: processes which control riskinformed applications, proposed changes to plant design and licensing basis, maintenance activities, andoff normal plant events or conditions.

1.2.2.2 Manager, Planning

& Scheduling The Manager, Planning

& Scheduling is responsible for the scheduling of maintenance, modification, testand inspection activities within the constraints imposed by operational, regulatory, and system loadrequirements.

1.2.2.3 Manager, Emergency PlanningThe Manager, Emergency Planning is responsible for the effective

planning, coordination, andmanagement of the V. C. Summer Nuclear Plant Emergency Preparedness Program.

Additional responsibilities include ensuring that the emergency plans, programs, and procedures are being properlymaintained and implemented to meet the requirements of SCE&G and the regulatory authorities.

7 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 21.2.2.4 Outage ManagerThe Outage Manager is responsible for planning, scheduling, and executing refueling outages within theestablished outage schedule and budget.1.2.2.5 Workweek Management The Workweek Management organization is responsible for and serves as the primary organizational interface with outside organizations for management, engineering, planning and implementation ofcapital projects.

The organization provides coordination and interface for resolving conflicts and delaysfor execution of activities as necessary for project implementation.

1.2.3 General Manager, Engineering Services (GMES)The GMES is the onsite lead position for engineering and reports to the VPNO. The GMES is responsible for engineering activities related to the operation or maintenance of the plant and design changeimplementation support activities.

The GMES directs functional managers responsible for plant supportengineering, design engineering, and materials and procurement.

1.2.3.1 Manager, Design Engineering The Manager, Design Engineering is responsible for resolving design issues, onsite development ofdesign-related change packages and plant modifications, managing contractors who may perform design-related activities, maintaining the configuration control program, and developing and maintaining engineering programs such as accident analysis activities and In Service Inspections (ISI).The Nuclear Design and Analysis Engineers, who report to the Manager, Design Engineering, ensure thatreactor engineering tests are performed in accordance with plant procedures and manuals and ensurethat current industry techniques are utilized to monitor and reduce megawatt loss. The Core DesignEngineers are responsible for evaluating, designing, and managing core design changes.1.2.3.2 Manager, Plant Support Engineering The Manager, Plant Support Engineering supervises a technical staff of engineers and other engineering specialists and coordinates interfaces with other groups as necessary.

The Manager, Plant SupportEngineering is responsible for providing direction and guidance to system engineers for monitoring theefficiency and proper operation of balance of plant and reactor systems, planning programs forimproving equipment performance, reliability, or work practices; overseeing operational tests andanalyzing the results; and maintaining engineering programs such as In Service Testing (IST), valvetesting, maintenance rule, piping erosion/corrosion, and system/equipment reliability.

1.2.3.3 Manager, Materials

& Procurement The Manager, Materials

& Procurement (MMPR) is responsible for all site purchasing activities, SupplierQuality Audits, Receipt Inspections, and Procurement Engineering functions.

The MMPR is alsoresponsible for providing sufficient and proper materials to support the needs of the plant and8 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 2performing related activities including procedure development, procurement and materials

storage, andsupply system database management.

1.2.4 General Manager, Organizational Development/

Effectiveness (GMOE)The GMOE reports to the VPNO. The GMOE directs managers responsible for Nuclear Protection

Services, Quality Systems, overall coordination of station Information Systems Technology activities, Change Management, Organizational Development

& Performance and Corrective Action Program, andsupervisor for Records and Document Control.

Additionally, the GMOE holds the position andresponsibilities of Chairman of the Corrective Action Review Board.1.2.4.1 Manager, Organizational Development

& Performance The Manager, Organizational Development

& Performance (MOD&P),

is responsible for directing andcoordinating the station organizational effectiveness

programs, to include human performance, operating experience, root cause, corrective action, self-assessment, management observation, trendingand benchmarking programs to effectively develop and coordinate these programs to aid in thedevelopment of a strong learning organization and to promote continuous improvement.

The MOD&P has the responsibility of supervising the Corrective Action Supervisor and HumanPerformance Supervisor.

Through this staff, the MOD&P is responsible for the implementation of theOD&P organizational effectiveness programs and ensuring written procedures accurately reflect thecriteria for establishing performance standards and are adhered to. The MOD&P is responsible forensuring that training and retraining of the OD&P personnel is performed and providing OD&P expertise and service to the station.

The MOD&P establishes and maintains rapport with plant personnel, encouraging the reporting of problems and events that can adversely affect plant performance at the V.C. Summer Nuclear Station Unit 1.The MOD&P is responsible for performing OD&P improvement initiatives and assists in identifying andtraining of human error reduction techniques for all station employees.

The MOD&P develops andparticipates in activities to identify human error challenges and opportunities for improvement, communicates to the station results to be achieved and the part they play in obtaining them, facilitates group learning sessions with supervisors and managers to identify

barriers, develops goals and measuresfor monitoring improvement plan results and provides results to management in periodic

reports, tracksinitiatives and assists in the development of measures for less than desirable results and ensures stronginterfaces and exchanges of information exists with others involved in improvement activities to ensureeffective integration of improvement efforts.1.2.4.2 Manager, Nuclear Protection ServicesThe Manager, Nuclear Protection

Services, is responsible for management control activities of NuclearSecurity and the access control and fitness for duty program.

Reporting to the Manager, NuclearProtection Services is the Supervisor, Operations

Security, and the Supervisor, Access Control/Fitness ForDuty.The Manager, Nuclear Protection

Services, is responsible for physical

security, security force operations, training and qualification

programs, and maintenance and testing activities for security equipment forthe V. C. Summer Station.9 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 21.2.4.3 Manager, Quality SystemsThe Manager, Quality Systems (MQS), is responsible for audits, surveillances, and inspections of NuclearOperations activities to ensure that all safety-related activities are performed in accordance with aquality assurance program which meets the criteria of 10 CFR 50, Appendix B and 10 CFR 72, Subpart G.Quality Assurance and Quality Control services may be subcontracted as needed. Further detail can befound in Section 18 of the QAPD. The MOS is responsible for independent oversight activities performed during refueling

outages, startup activities, and normal and off-normal operational activities at the V. C.Summer Station.The responsibility for developing, maintaining and verifying effective implementation of the QAPD restswith the MQS. The MQS through the GMOE has the responsibility and authority to report qualitymatters to any management level necessary within SCE&G in order to establish timely and effective corrective action. The MQS is authorized by this QAPD to identify conditions adverse to quality directlyto the VPNO as indicated by the dotted line reporting shown on Figure 11.1-2 "Unit 1 PlantManagement Organization."

To ensure independence is maintained between QA and linemanagement, QA shall be excluded from participation in line functions, assessments, or evaluations.

Independence shall not be subordinated to achieve cost or schedule objectives.

1.2.4.4 Manager, Corporate Information and Systems Technology The Manager, Corporate Information and Systems Technology reports through a dotted-line to theGMOE and is responsible for ensuring station computer operation and records applications are installed and maintained per approved procedures and working with departments to ensure regulatory compliance.

1.2.4.5 Supervisor

Records, Documents, and Reproduction The Supervisor

Records, Documents, and Reproduction is responsible for providing for acceptable records storage systems and locations; obtaining, filing and maintaining auditable records; andmaintenance of the Station document control program.1.2.5 Manager, Business and Financial ServicesThe Manager, Business and Financial

Services, is responsible for project prioritization, businessdevelopment including budget and business plan development, and tracking and coordination withexternal industry groups.1.2.6 Corporate ServicesThe SCANA/SCE&G Corporate Services organizations are responsible for supporting the NuclearOrganization by performing activities related to accounting, safety and health, and environmental services where applicable.

These organizations will serve the Nuclear Organization through "dotted-line" reporting to the Nuclear Organization managers.

10 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 21.2.6.1 Manager, Nuclear Finance Administration The Manger, Nuclear Finance Administration, is responsible for time and attendance management, fatigue rule management, capital and operating

budgets, project support functions, and site widefinancial analytical support and budget adherence.

1.3 Quality Assurance The SCE&G Quality Assurance Organization is responsible for independently planning and performing activities to verify the development and effective implementation of the SCE&G QAPD, including but notlimited to engineering, licensing, document

control, corrective action program, and procurement thatsupport the operational phase of the V. C Summer Nuclear Station.

This verification of development andeffective implementation of the SCE&G QAPD allows SCE&G Nuclear Operations to support New NuclearDeployment activities 1.4 Authority to Stop WorkQuality assurance and inspection personnel have the authority, and the responsibility, to stop work inprogress which is not being done in accordance with approved procedures or where safety or SSCintegrity may be jeopardized.

This extends to off-site work performed by suppliers furnishing safety-related materials and services to SCE&G.1.5 Quality Assurance Organizational Independence For operational phase activities, independence shall be maintained between the organization ororganizations performing the checking (quality assurance and control) functions and the organizations performing the functions.

This provision is not applicable to design review / verification.

1.6 NQA-1-1994 Commitment In establishing its organizational structure, SCE&G commits to compliance with NQA-1-1994, Basic Requirement 1 and Supplement 1S-1.11 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 2II*Multiple Responsibilities held by oneindividual.

IIDi-ILVic Prsidn Vic PresidenNuclear Opeations New uclear OperaionsJ Fo nt1Oprtn.rgnzto S See Fiur 11.1-2Figure 11.1-1 SCE&G Corporate Organization 12 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 2---------------------

Geýe,.[ Manage,,Wtl- Plantope' ýU.nsiGMNPG)Plant manage, unit Ilin'tIN140I------------

IS****Dotted line per Section 1.2.4.3 toindicate MQS authority to reportquality matters directly to the VPNO.IL*Supports NND in participating onNEI AP1O00 HP Task Force-_0ý -IM-a "Ink-ti.n

& Syt-T h I** Supports NND in the area of Emergency Planning*** Supports NND in the procurement of safety and non-safety relatedmaterials, equipment, and services.

Supports NND 0S personnel in theperformance of external activities by the participation of NUPIC audits todetermine contractor/vendor conformance to their QA program.Figure 11.1-2 Unit 1 Plant Management Organization 13 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 2SECTION 2 QUALITY ASSURANCE PROGRAMSCE&G has established the necessary measures and governing procedures to implement the QualityAssurance Plan (QAP) as described in the QAPD. SCE&G is committed to implementing the QAP in allaspects of work that are important to the safety of the nuclear plant as described and to the extentdelineated in the QAPD. Further, SCE&G ensures through the systematic process described herein that itssuppliers of safety-related equipment or services meet the applicable requirements of 10 CFR 50,Appendix B. Senior management is regularly apprised of the adequacy of implementation of the QAPthrough the audit functions described in Part II, Section 18.The objective of the QAP is to assure that the V. C. Summer Nuclear Station Unit 1 is designed andoperated in accordance with governing regulations and license requirements.

The program is based onthe requirements of ASME NQA-1-1994, "Quality Assurance Requirements for Nuclear FacilityApplications,"

as further described in this document.

The QAP applies to those quality-related activities that involve the functions of safety-related structures,

systems, and components (SSCs) associated withthe design, maintenance,

testing, and safe operation of the nuclear facility and managerial andadministrative controls as described in the Final Safety Analysis Report (FSAR). A list or system thatidentifies SSCs and activities to which this program applies is maintained at the V. C. Summer NuclearStation.

Cost and scheduling functions do not prevent proper implementation of the QAP.As described in Part III of the QAPD, specific program controls are applied to non-safety related SSCs, forwhich 10 CFR 50, Appendix B and 10 CFR 72, Subpart G, is not applicable, that are significant contributors to plant safety. The specific program controls consistent with applicable sections of the QAPD are appliedto those items in a selected manner, targeted at those characteristics or critical attributes that render theSSC a significant contributor to plant safety.Responsibilities may be delegated under a suppliers or principal contractors QAP, provided that thesupplier or principle contractor has been approved as a supplier in accordance with the QAPD. Periodicaudits and assessments of supplier QA programs are performed to assure compliance with the supplier's or principle contractors QAPD and implementing procedures.

In addition, routine interactions with thesupplier's personnel provide added assurance that quality expectations are met.For the operational phase, the QAPD applies to those operational and SCE&G activities that can affect,either directly or indirectly, the safety-related site characteristics or analysis of those characteristics.

In general, the program requirements specified herein are detailed in implementing procedures that areeither SCE&G implementing procedures, or supplier implementing procedures governed by a supplierquality program.A grace period of 90 days may be applied to provisions that are required to be performed on a periodicbasis unless otherwise noted. Annual evaluations and audits that must be performed on a triennial basisare examples where the 90 day general period could be applied.

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

The "clock" for an activity is reset backwards byperforming the activity early. Audit schedules are based on the month in which the audit starts.14 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 22.1 Responsibilities Personnel who work directly or indirectly for SCE&G are responsible for achieving acceptable quality inthe work covered by the OAPD. This includes the activities delineated in Part I, Section 1.1. SCE&Gpersonnel performing verification activities are responsible for verifying the achievement of acceptable quality.

Activities governed by the QAPD are performed as directed by documented instructions, procedures and drawings that are of a detail appropriate for the activity's complexity and effect onsafety. Instructions, procedures and drawings specify quantitative or qualitative acceptance criteria asapplicable or appropriate for the activity, and verification is against these criteria.

Provisions areestablished to designate or identify the proper documents to be used in an activity, and to ascertain thatsuch documents are being used. The Manager, Quality Systems is responsible to verify that processes and procedures comply with QAPD and other applicable requirements, that such processes orprocedures are implemented, and that management appropriately ensures compliance.

2.2 Delegation of WorkSCE&G retains and exercises the responsibility for the scope and implementation of an effective QAPD.Positions identified in Part II,Section I, may delegate all or part of the activities of planning, establishing, and implementing the program for which they are responsible to others, but retain the responsibility forthe program's effectiveness.

Decisions affecting safety are made at the level appropriate for its natureand effect, and with any necessary technical advice or review.2.3 Periodic Review of the Quality Assurance ProgramManagement of those organizations implementing the QA program, or portions

thereof, assess theadequacy of that part of the program for which they are responsible to assure its effective implementation at least once every two years or at least once during the life of the activity, whichever isshorter.2.4 Issuance and Revision to Quality Assurance ProgramAdministrative control of the QAPD will be in accordance with 10 CFR 50.54(a).

Changes to the QAPD areevaluated by the Manager, Quality Systems to ensure that such changes do not degrade previously approved quality assurance controls specified in the QAPD. This document shall be revised asappropriate to incorporate additional QA commitments that may be established during the operating lifeof the V. C. Summer Nuclear Station Unit 1. New revisions to the document will be reviewed, at aminimum, by the Manager, Quality Systems, and approved by the Senior Vice President, NuclearOperations/CNO.

Regulations require that the Final Safety Analysis Report (FSAR) include, among other things, themanagerial and administrative controls to be used to assure safe operation, including a discussion of howthe applicable requirements of Appendix B will be satisfied.

In order to comply with this requirement, theFSAR references the QAPD and, as a result, the requirements of 10 CFR 50.54(a) is satisfied by, andapplies to, the QAPD.15 V. C. Summer Nuclear Station Unit 1Quality Assurance Program Description Revision 22.5 Personnel Qualifications Personnel assigned to implement elements of the QAPD shall be capable of performing their assignedtasks. To this end, SCE&G establishes and maintains formal indoctrination and training programs forpersonnel performing, verifying, or managing activities within the scope of the QAPD to assure thatsuitable proficiency is achieved and maintained.