ML042470018

Attachment 3 - Comparative Analysis of Current N45.2 Series QA Standards to NQA-1-1994 Standards

ML042470018
Person / Time
Site:	Millstone, Surry, North Anna, 07200002, 07100194, 07100207
Issue date:	08/24/2004
From:	Dominion Nuclear Connecticut, Virginia Electric & Power Co (VEPCO)
To:	NRC/FSME
References
+kBR1SISP20060124, 04-326 DOM-QA-1, Rev 0, NQA-1-1994
Download: ML042470018 (430)

Text

ATTACHMENT 3 VIRGINIA ELECTRIC AND POWER COMPANY DOMINION NUCLEAR CONNECTICUT, INC.

SURRY POWER STATION UNITS 1 AND 2 AND ISFSI NORTH ANNA POWER STATION UNITS 1 AND 2 AND ISFSI MILLSTONE POWER STATION UNITS 1, 2 AND 3 AND ISFSI ASSOCIATED RADIOACTIVE MATERIAL PACKAGES NUCLEAR FACILITY QUALITY ASSURANCE PROGRAM DESCRIPTION TOPICAL REPORT DOM-QA-1, REVISION 0 AUGUST 24, 2004 COMPARATIVE ANALYSIS OF CURRENT N45.2 SERIES QA STANDARDS TO NQA-1-1994 STANDARDS 429 PAGES FOLLOW THE FOLLOWING TABLES PROVIDE COMPARISON OF THE NQA-1-1994 QUALITY ASSURANCE STANDARDS TO THE N45.2 AND RELATED QA STANDARDS THAT FORM THE BASIS OF THE CURRENT QA PROGRAMS FOR DOMINION'S NUCLEAR FACILITIES.

AS MUCH AS PRACTICAL, THE TABLES ARE ARRANGED IN THE ORDER OF THE TEXT FROM THE NQA-1 STANDARDS IN THE CENTER COLUMN WITH THE APPROPRIATE CURRENT STANDARD'S REFERENCE IN THE LEFT COLUMN. COMMENTS ON DIFFERENCES ARE CONTAINED IN THE RIGHT HAND COLUMN. NQA-1 STANDARDS THAT DID NOT HAVE A CORRESPONDING CURRENT STANDARD ARE NOT INCLUDED IN THE COMPARISON TABLES (I.E. SUBPARTS 2.7, 2.18, 2.20).

BOOKMARKS ARE INCLUDED TO ALLOW FOR NAVIGATION TO SPECIFIC SECTIONS.

04/19/04OrganizationPage 1 of 6 CRITERION 1ANSI N45.2-1977/N18.7-1976 BASIC REQUIREMENT 1 NQA-1 1994 COMMENTS N45.2 § 2 ¶ 2 - The program shall define theorganizational structure within which the Quality Assurance Program is to be planned and implemented

and shall clearly delineate the responsibility and authority of the various personnel and organizations involved.

N45.2 § 3 ¶ 1 - The organizational structure, functional responsibilities, levels of authority, and lines of internaland external communication for management, direction and execution of the Quality Assurance Program shall be documented.

N45.2 § 1.2 ¶ 1 - This standard is intended to apply tothe facility owners, major contractors, such as the nuclear steam supply system designer or supplier, process equipment designer or supplier, the architect-engineer or facility designer, the constructor, and other organizations participating in activities affecting quality.

N18.7§ 3.2 ¶ 1 Assignment of Authority andResponsibility. It is essential that all members of the organization involved in operation of nuclear power plants, including those at the highest management levels, recognize the necessity that the plants be operated undera well formulated and detailed administrative controls and quality assurance program to assure safety and

efficiency. Lines of au thority, responsibility andcommunication shall be established from the highest management level through intermediate levels to and including the onsite operating organization (including

those offsite organizational units assigned responsibility for procurement, design and construction, quality

assurance, and technical support activities). These relationships shall be documented and updated, as appropriate, in the form of organizational charts, functional descriptions of departmental responsibilitiesand relationships and job descriptions for key personnelpositions or in equivalent forms of documentation.

N18.7§ 3.2 ¶ 2 The owner organization shall specify in writing the authority a nd responsibility assignedindividuals and organizations involved in establishing, executing and measuring the overall effectiveness of the administrative controls and quality assurance program required by this Standard.

The organizational structure, functional responsibilities, levels of authority, and lines of communication for activities affecting quality shall be documented.Similar requirement, but NQA-1 addresses this in the Introduction to Part I, § 2 Applicability.Overall Note: Aspects from N45.2 and N18.7 dealing with qualification and training are addressed with Criterion 2, and Reg. Guide 1.8 regarding selection, training and qualification of personnel.

N 45.2 §3 ¶ 2

- The authority and responsibility of Persons or organizations responsible for assuring that an Similar requirement.

04/19/04OrganizationPage 2 of 6 CRITERION 1ANSI N45.2-1977/N18.7-1976 BASIC REQUIREMENT 1 NQA-1 1994 COMMENTSpersons and organization performing activities shall beclearly established. Persons and organizations performing quality assurance functions shall have sufficient

authority, access to work areas, and organizationalfreedom to:(1) identify quality problems; (2) initiate, recommend, or provide solutions to qualityproblems through designated channels; (3) verify implementation of solutions; and (4) control further processing, delivery, installation, of anonconforming item, deficiency, or unsatisfactory condition until proper dispositioning has occurred.

N18.7 § 3.2 ¶ 4 Persons or organizations performingfunctions of assuring that the administrative controls and quality assurance program is established and implemented or of assuring that an activity has been correctly performed shall ha ve sufficient authority andorganizational freedom to: identify quality problems; initiate, recommend or provide solutions, through designated channels; and verify implementation of solutions.appropriate quality assurance program has been established and verifying that activities affecting quality have been correctly performed shall have sufficient

authority, access to work areas, and organizationalfreedom to: (a) identify quality problems;(b) initiate, recommend, or provide solutions to quality problems through designated channels;(c) verify implementation of solutions; and(d) assure that further processing, delivery, installation, or use is controlled until proper disposition of a nonconformance, deficiency, or unsatisfactory condition

has occurred.

N45.2 § 3 ¶ 3 The person or organization responsible fordefining and measuring the overall effectiveness of the Quality Assurance Program shall be designated, shall be sufficiently independent from the pressures of production

and shall have direct access to responsible management ata level where appropriate action can be required, and shall report regularly on the effectiveness of the program.

N18.7 § 3.2 ¶ 3 The persons or organizations responsiblefor defining and measuring the overall effectiveness of the program shall be designated, shall be sufficiently independent from cost and scheduling considerationswhen opposed to safety considerations, shall have direct access to responsible management at a level where appropriate action can be accomplished, and shall report

regularly on the effectiveness of the program to the plantmanager and the cognizant offsite management.

Such persons or organizations shall have direct access toresponsible management at a level where appropriate action can be effected. Such persons or organizations shall report to a management level such that required authority and organizational freedom are provided, including sufficient independence from cost and schedule considerations.Similar requirement.SUPPLEMENT 1S-1 Supplementary Requirements for Organization 1 GENERALThis Supplement provides amplified requirements for organization.

04/19/04OrganizationPage 3 of 6 CRITERION 1ANSI N45.2-1977/N18.7-1976 BASIC REQUIREMENT 1 NQA-1 1994 COMMENTSIt supplements the requirements of Basic Requirement 1of this Part (Part I) and shall be used in conjunction with that Basic Requirement when and to the extent specifiedby the organization invoking this Part (Part I).2 RESPONSIBILITY

2.1 Purpose

N45.2 § 3 ¶ 4 The organizational structure and thefunctional responsibility assignments shall be such that N18.7 § 3.2 ¶ 5 The organizational structure and thefunctional responsibility assignment shall be such that:

The organizational structure and the responsibility assignments shall be such that:Similar requirement.

N45.2 § 3 ¶ 4 (1) attainment of quality objectives isaccomplished by those who have been assigned responsibility for performing work; e.g. the designer, the welder, or the nuclear facility operator. This may included interim examinations, checks, and inspections of the work by the individual performing the work.

N18.7 § 3.2 ¶ 5 (1) Attainment of program objectives isaccomplished by those who have been assigned responsibility for performing work. This may include interim examinations, checks, and inspections of the work by the individual performing the work.(a) quality is achieved and maintained by those who have been assigned responsibility for performing work; andSimilar requirement.

N45.2 § 3 ¶ 4 (2) verification of conformance toestablished quality requirements is accomplished by those who do not have direct responsibility for performing thework; e.g., the design re viewer, the checker, the inspector, or the tester N18.7 § 3.2 ¶ 5 (2) Verification of conformance toestablished program requirements is accomplished by a

qualified person who does not have responsibility forperforming or directly supervising the work. The method and extent of such verification shall be commensurate with the importance of the activity to plant safety and reliability.(b) quality achievement is verified by persons or organizations not directly responsible for performing the

work.Similar requirement. N18.7 includes a statement that the verification alsocannot be done by the person directly supervising the

work. NQA-1 addresses the independence in the

respective sections of de sign control (Criterion III),inspection (Criterion X), and testing (Criterion XI). There is no specific requirement or definition for "the

checker" as stated in N45.2. This checking could be accomplished by any of the other three functions.2.2 Delegation of Work N45.2 § 1.3 ¶ 1 - The facility owner or his designatedrepresentative and other organizations are also

responsible for assuring that the necessary and appropriate requirements of this standard are invoked.

The facility owner may delegate to other organizations the work of establishing and executing the Quality Assurance Program or any part thereof, but shall retainresponsibility for overall program effectiveness. In no The individual(s) or organization(s) responsible for establishing and executing a quality assurance program under this Standard may delegate any or all of the work

to others but shall retain responsibility therefore.Similar requirement for N 45.2 and NQA-1. N18-7 goesinto details that are covered in the integrated QAPD through other sections of Section 1, Organization, such as description of site executive management and nuclear oversight. However, overall the QAPD and NQA-1-1994 meet the intent of these sections for both N45.2 and

N18.7.

04/19/04OrganizationPage 4 of 6 CRITERION 1ANSI N45.2-1977/N18.7-1976 BASIC REQUIREMENT 1 NQA-1 1994 COMMENTSway shall the program operate to diminish theresponsibility of any contractor for the quality of items or services furnished or for execution of the contractor's designated portion of the Quality Assurance Program.

ANS N18.7 § 3.4.2 The Plant Manager shall have overall responsibility for the execution of the administrativecontrols and quality assurance program at the plant to assure safety. An individual or organizational unit knowledgeable and experienced in nuclear power plant operational phase activities and quality assurance practices shall be designated and assigned the responsibility to verify that the program is being effectively implemented. Depending on the organizational structure, the individual or organizational unit may report functionally to onsite plant management or an offsite organization (see also 3.2). Reporting to onsite plant management is preferable since such an arrangement actually results in improved communications in identifying problems and initiating corrective action.

The individual or organizational unit in this case may

receive technical guidance from offsite support groups.This individual's or organizational unit's duties and

responsibilities shall be such that the required attentioncan be devoted, as required, to verifying that the program is being effectively executed. The individual or organizational unit shall report on the effectiveness of the program to the Plant Manager and to other cognizant management as may be designated. Their activities shall be periodically audited by designated offsite personnel.2.3 Nonconforming Items Responsibility for the contro l of further processing,delivery, installation, or operation of nonconforming items shall be designated in writing.Addressed in implementing procedures.3 MULTIPLE ORGANIZATIONS3.1 Responsibility N45.2 § 3 ¶ 1 - Where multiple organizationalarrangements exist, the responsibility of each organization shall be clearly established.

N45.2 § 3 ¶ 5 In structuring the organization and assigning responsibility, qua lity assurance should berecognized as an interdisciplinary function involving many organizational components and, therefore, should Where more than one organization is involved in the execution of activities covered by this Part (Part I), the

responsibility and authority of each organization shall beclearly established and documented.Similar requirement.Additional explanatory information from N45.2 and N18.7 is more a factor of the founding principles and policy of quality assurance. Much of this is addressed in the Policy section of the QAPD. Additional information is contained in the various sections of the QAPD related to the specific functions such as inspections, testing, 04/19/04OrganizationPage 5 of 6 CRITERION 1ANSI N45.2-1977/N18.7-1976 BASIC REQUIREMENT 1 NQA-1 1994 COMMENTSnot be regarded as the sole domain of a single qualityassurance group. For example, it may be more appropriate for design engineers to perform design

reviews rather than quality assurance engineers becauseof the special competence required to perform these reviews. Quality assurance encompasses many functions and activities and extends to various levels in all participating organizations, from the top executive to all workers whose activities may influence quality.

N18.7 § 3.2 In structuring the organization and assigning responsibility, quality assuran ce should be recognized asan interdisciplinary function involving many organizational components and, therefore, should not be regarded as the sole domain of a single quality assurance group. For example, it may be more appropriate for nuclear engineers to perform reviews of plant nuclear engineering activities rather than quality assurance

engineers because of the special competence required toperform these reviews. Quality assurance encompasses many functions and activities and extends to various levels in all participating organizations, from the top executive to all workers whose activities may influence quality.auditing, design reviews, and independent reviews by the review bodies and the SNS function.

3.2 Interface

Control N18.7 § 3.4 Onsite Operating Organization 3.4.1 General. A number of factors influencemanagement in its decision regarding the establishment of an onsite operating organization. These include the owner organization's established staffing policies, the physical size and complexity of the nuclear power plant,the number of units, the extent of assistance provided by offsite technical support organizations, the extent of reliance on consultants and the availability of qualified personnel from other sources to assist in activities, such as initial start-up, refueling, maintenance or modification

work.A nuclear power plant onsite operating organization may change with time. For example, the number and qualifications of personnel making up the onsite technical support staff can generally be reduced as a plant

progresses through initial operation to operational maturity. Management shall give careful consideration to 3.2.1 The external interfaces between organizations and the internal interfaces betw een organizational units, andchanges thereto, shall be documented.

N45.2 and N18.7 only address interface control with external organizations related to the design control function. However, this should have further controlswhere external organizations provide a quality function for the facility, such as a contractor performing construction activities, or providing an audit service, as well as other functions.N18.7 focuses only on the onsite operating organization functions. This particular section provides more of a

philosophy on the initial onsite organization and changes thereto rather than any specific requirements.

04/19/04OrganizationPage 6 of 6 CRITERION 1ANSI N45.2-1977/N18.7-1976 BASIC REQUIREMENT 1 NQA-1 1994 COMMENTSthe timing and extent of such changes.

3.2.2 Interface

responsibilities shall be defined anddocumented.

N18.7 § 3.4.2 Requirements for the Onsite OperatingOrganization. The onsite operating organization shall include one or more individuals knowledgeable in the following fields: nuclear power plant operation; nuclear power plant mechanical, electrical and electronicsystems; nuclear engineering; chemistry and radiochemistry; radiation protection; and quality assurance. Initial incumbents or replacements formembers of the onsite operating organization and offsite technical support organizations shall have appropriate experience, training and retraining to assure that necessary competence is ma intained in accordance withthe provisions of American National Standard for Selection and Training of Nuclear Power Plant Personnel, N18.1-1971. [4] Personnel whose qualifications do not meet those specified in N18.1 and who are performing inspection, examination, and testing activities during the operations phase of the plant, including preoperational and start-up testing, shall be qualified to American National Standard Qualifications of Inspection, Examination, and Testing Personnel for the Construction Phase of Nuclear Power Plants, N45.2.6-1973 [5], except

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

personnel holding NRC react or operator and senior reactor operator licenses. Requirements for the minimumnumber of personnel holding such licenses who shall be

present at the plant under various operating conditions and situations shall also be specified.N18.7 provides specific requirements for the minimum discipline experience of the onsite operating staff. The experience and qualification requirements for selecting and training onsite and offsite staff are addressed in Section 2 of the QAPD and the company commitment to Reg. Guide 1.8 as defined in that section.N18.7 also addresses positions requiring NRC license requirements. This is likewise addressed in Section 2 of

the QAPD and the specific commitment to Reg. Guide1.8 addressed therein.N18.7 requires the minimum staffing levels of licensed personnel who shall be present during various operatingconditions and situations to be specified. These staffing levels will be specified in the applicable facilities'

technical specifications rather than the QAPD.

04/21/04Quality Assurance ProgramPage 1 of 26 CRITERION 2 ANSI N45.2-1977/N18.7-1976 BASIC REQUIREMENT 2 NQA-1 1994 COMMENTS 2. QUALITY ASSURANCE PROGRAMN45.2 §1.3 ¶1 - It is the responsibility of the facilityowner to provide for the establishment and execution of a Quality Assurance Program for the facility consistent with

the provisions of this standard.A documented quality assurance program shall be planned, implemented, and maintained in accordance with

this Part (Part I), or portions thereof.Similar requirement.N45.2 §1.3 ¶1 - The facility owner or his designated

representative and other organizations invoking this standard are responsible for identifying the structures, systems, and components and for specifying the extent to which the provisions of this standard apply.§2 ¶3 - The program shall identify the items and services to which this and other standards apply.The program shall identify the activities and items to

which it applies.Similar requirement.N45.2 §2 ¶1 - The establishment of the program shall

include considerations of the technical aspects of the activities to be performed. The program shall contain provisions to assure identification of and compliance with requirements of pertinent ANSI and other recognized and appropriate engineering codes, standards, requirements, and practices.The establishment of the program shall include

consideration of the technical aspects of the activities affecting quality.Similar requirement.N45.2 §2 ¶3 - Since items and services will differ in regard to relative safety, reliability, and performance importance, various methods or levels of control and verification may be used to assure adequate quality.

Regardless of the methods or levels used, the program shall provide for the assurance of quality consistent with applicable codes, standards, and other requirements. Some factors to be considered in assigning methods or levels of quality assurance are as follows: (1) the consequence of malfunction or failure of the item; (2) the design and fabrication complexity or uniqueness of the item; (3) the

need for special controls and surveillance over processes and equipment; (4) the degree to which functional compliance can be demonstrated by inspection or test; (5) the quality history and degree of standardization of the item; (6) the difficulty of repair or replacementThe program shall provide control over activities affecting quality to an extent consistent with their importance.Similar requirement.N45.2 §2 ¶1 - A documented Quality Assurance Program which complies with the applicable sections and elements

of this standard shall be established at the earliestThe program shall be established at the earliest time consistent with the schedule for accomplishing the

activities.Similar requirement.

04/21/04Quality Assurance ProgramPage 2 of 26 CRITERION 2 ANSI N45.2-1977/N18.7-1976 BASIC REQUIREMENT 2 NQA-1 1994 COMMENTSpractical time consistent with the schedule foraccomplishing the activities for the nuclear facility.N45.2 §2 ¶6 - The program shall provide for the accomplishment of activities affecting quality under suitably controlled conditi ons. Controlled conditionsinclude the use of appropriate equipment, suitable environmental conditions for accomplishing the activity, and assurance that prerequisites for the given activity have been satisfied. The program shall take into account the need for special controls, processes, test equipment, tools, and skills to attain the required quality and the need for verification of quality by inspection, examination, or test.The program shall provide for the planning and accomplishment of activities affecting quality under suitably controlled conditi ons. Controlled conditionsinclude the use of appropriate equipment, suitable environmental conditions for accomplishing the activity, and assurance that prerequisites for the given activity have been satisfied. The program shall provide for any special controls, processes, test equipment, tools, and skills to attain the required quality and for verification of quality.Similar requirements.N45.2 -The program shall define the organizationalstructure within which the Quality Assurance Program is to be planned and implemented and shall clearly delineate the responsibility and authority of the various personnel

and organizations involved.The program shall provide for indoctrination and training, as necessary, of personnel performing activities affecting quality to assure that suitable proficiency is achieved and maintained.

Organizational structure is covered in Basic Requirement 1 of NQA-1 and

Section 1 of the QAPD. NQA-1

focuses on indoctrination and training

of personnel under this basic requirement, as covered in QAPD, Section 2.The program shall provide for the regular review, by management of organizations participating in the program,of the status and adequacy of that part of the Quality Assurance Program for which they have designated responsibility.Management of those organizations implementing the quality assurance program, or portions thereof, shall regularly assess the adequacy of that part of the program for which they are responsible and shall assure its effective implementation.Similar requirement.

Note: ANSI N45.2.6 addresses the qualification of

inspection and test personnel. Note: Supplement 2S-1 provides requirements while Appendix 2A-1 is considered nonmandatory (by NQA-1)

guidance on qualification of in spection and test personnel.

NRC Reg. Guides 1.8 and 1.28 require using NQA-1, Appendix 2A-1 for

inspection and test personnel

qualification.

ANSI N45.2.6 QUALIFICATIONS OF INSPECTION,EXAMINATION AND TESTING PERSONNEL FOR

NUCLEAR POWER PLANTS SUPPLEMENT 2S-1Supplementary Requirements for the Qualification of Inspection and Test Personnel

1. INTRODUCTION 1 GENERAL 1.1 ScopeThis Standard delineates the requirements for the

qualification of personnel who perform inspection,examination, and testing to verify conformance to specified requirements of nuclear power plant items (structures, systems, and components of nuclear powerThis Supplement provides amplified requirements for the

qualification of personnel who perform inspection andtesting to verify conformance to specified requirements for the purpose of acceptability.NQA-1 does not define "examination" separate from inspection and testing, but the intent is the same.

04/21/04Quality Assurance ProgramPage 3 of 26 CRITERION 2 ANSI N45.2-1977/N18.7-1976 BASIC REQUIREMENT 2 NQA-1 1994 COMMENTSplants) whose satisfactory performance is required to prevent postulated accidents which could cause undue risk to the health and safety of the public; or to mitigate the

consequences of such accidents if they were to occur. Therequirements may also be extended to other items of

nuclear power plants when specified in contract documents. Regulatory Guide-1.58 C-1 "The requirements for

qualification of nuclear power plant inspection, examination, and testing personnel (4) that are included in

ANSI N45.2.6-1978 are acceptable to the NRC staff and provide an adequate basis for complying with the pertinent quality assurance requirements of Appendix B to CFR Part

50, subject to the following:(4)The terms "inspection," "examination," and "testing" are defined in Section 1.4, "Definition," of ANSI N45.2.6-1978. 1. Section 1.2, "Applicability," of ANSI N45.2.6-

1978 states that the standard applies "to personnel who perform inspections, examinations, and tests. . .during

preoperational and startup t esting, and during operational phases of nuclear power plants." However, for

qualification of personnel (1) who approve preoperational, startup, and operational test procedures and test results and

(2) who direct or supervise the conduct of individual

preoperational, startup, and operational tests, the guidelines contained in Regulatory Guide 1.8, "Personnel

Selection and Training," should be followed in lieu of the guidelines of ANSI N45.2.6-1978."

1.2 ApplicabilityThe

requirements of this Standard apply to personnel who perform inspections, examinations, and tests during fabrication prior to and during receipt of items at the

construction site, duri ng construction, during preoperational and startup t esting, and during operationalphases of nuclear power plants. The requirements of this Standard do not apply to personnel who performinspections for government or municipal authorities, or who perform as authorized inspectors in accordance with

the ASME Boiler and Pressure Vessel Code. TheApplicability of NQA-1-1994 is

addressed in the Introduction (Section

I- 2, not in each section.)

04/21/04Quality Assurance ProgramPage 4 of 26 CRITERION 2 ANSI N45.2-1977/N18.7-1976 BASIC REQUIREMENT 2 NQA-1 1994 COMMENTSrequirements of this Standard are not intended to apply topersonnel who only perform inspection, examination, or testing in accordance with ANST "Recommended Practice

No. SNT-TC-1A", since these personnel are certified in accordance with the requirements of SNT-TC-1A and its applicable supplements. The requirements of this Standard are optional, at the discretion of the employer, for

application to personnel who perform calibration or tocraftsmen who perform installation checkouts as part of their basic installation responsibility to ready the

installation for preoperational testing. Regulatory Guide-1.58 C-2. Section 1.2, "Applicability," ofANSI N45.2.6-1978 states: "The requirements of this Standard are not intended to apply to personnel who only perform inspection, examination, or testing in accordance with ASNT'Recommended Practice No. SNT-TC-1A', since these personnel

are certified in accordance with the requirements of SNT-TC-1A and its applicable supplements." SNT-TC-1A-1975 is acceptable for the qualification of personnel performing nondestructive examinations and should be used where applicable, subject to the following: a. SNT-TC-1A-1975 applies to qualification of nondestructive testing personnel for the following nondestructive test methods: (1) Radiographic Testing; (2) Magnetic Particle Testing; (3) Ultrasonic Testing; (4) Liquid Penetrant Testing;(5) Eddy Current Testing;(6)Neutron Radiographic Testing; and (7) Leak Testing.

b. Forqualification of personnel performing nondestructive examinations required by Section III and Section XI of the

ASME Boiler and Pressure Vessel Code, SNT-TC-1A-

1975 should be used in conjunction with the additional

provisions of the Code.Regulatory Guide-1.58 C-3. Section 1.2, "Applicability,"

of ANSI N45.2.6-1978 states: "The ASME Boiler and

Pressure Vessel Code, as well as other ANSI Standards, have been considered in the development of the Standard, and this Standard is intended to be compatible with theirrequirements." While Section III and Section XI of the

ASME Boiler and Pressure Vessel Code address requirements for the qualifications of certain personnel who perform inspection, examination, and testing, these 04/21/04Quality Assurance ProgramPage 5 of 26 CRITERION 2 ANSI N45.2-1977/N18.7-1976 BASIC REQUIREMENT 2 NQA-1 1994 COMMENTS sections do not address the qua lification of all personnel described in ANSI Standard N45.2.6.-1978. ANSI

N45.2.6-1978, subject to the exceptions of the regulatory

positions, should be used in conjunction with Section III and Section XI of the ASME Boiler and Pressure Vessel Code for the qualification of inspection, examination, and

testing personnel where the ASME Code does not address the requirements covered by ANSI N45.2.6-1978.Regulatory Guide-1.58 C-4. Section 1.5, "Referenced Documents," of ANSI N45.2.6-1978 states: "Other documents that are required to be included as a part of this

Standard are either identified at the point of reference or

described in Section 6 of this Standard." The specific applicability or acceptability of listed standards has been or will be covered separately in other regulatory guides, where appropriate.Regulatory Guide-1.58 C-9. Section 1.2, "Applicability,"

of ANSI N45.2.6-1978 states: "The requirements of this Standard do not apply to personnel who performinspections for government or municipal authorities, or who perform as authorized inspectors in accordance with

the ASME Boiler and Pressure Vessel Code." The requirements and recommendations of ANSI N45.2.6-1978, subject to the provisions of Regulatory Positions 1 through 8, are considered acceptable for use by or for all NRC permit holders and licensees, including those that are government or municipal authorities.

This Standard is to be used in conjunction with ANSI N45.2. The requirements apply to personnel of the owners,architect-engineers, nuclear power plant system designers and system suppliers, plant designers and plant constructors, equipment s uppliers, outside testing agencies, and consultants. The ASME Boiler and Pressure

Vessel Code, as well as other ANSI Standards have been considered in the development of the standard, and this Standard is intended to be compatible with their requirements.

NQA-1 incorporates ANSI N45.2.

NQA-1 is also intended to be compatible with ASME Boiler and

Pressure Vessel Code.

1.3 ResponsibilityIt

is the responsibility of each organization participating inResponsibility is defined in the 04/21/04Quality Assurance ProgramPage 6 of 26 CRITERION 2 ANSI N45.2-1977/N18.7-1976 BASIC REQUIREMENT 2 NQA-1 1994 COMMENTSthe project to assure that only those personnel within theirrespective organizations who meet the requirements of this Standard are permitted to perform inspection, examination, and testing activities covered by this Standard that verify conformance to quality requirements.

Introduction to Part I of NQA-1-1994, Section 3.

The organization or organi zations responsible forestablishing the applicable requirements for activities covered by this Standard sh all be identified and the scopeof their responsibility shall be documented. The work of

establishing selection and training practices and

qualification procedures and of providing the resources in terms of personnel, equipment, and services necessary to implement the requirements of this Standard, may be

deleted to other qualifie d organizations and suchdelegations be documented. It is the responsibility of each organization using personnel covered by this Standard toconform to the requirements of this Standard applicable to the organization's work. It is the responsibility of the organization performing these activities to specify the detailed methods and procedures for meeting the requirements of this Standard, unless they are specified in the contract documents.

1.4 Definitions1.4.1 Inspection. A phase of quality control which by means of examination, observation, or measurement determines the conformance of materials, supplies, parts, components, appurtenances, systems, processes, or structures to predetermined quality requirementsinspection - examination or measurement to verify whether an item or activity conforms to specified requirements (From NQA-1-1994, Part I - Introduction)Similar1.4.2 Examination. An element of action consisting of investigation of materials, supplies, parts, components, appurtenances, systems, processes, or structures to determine conformance to those specified requirements which can be determined by such investigation.

Examination is usually nondestructive and includes simply physical manipulation, gaging, and measurement (NQA-1-1994, Part II definitions) examination - an element of inspection consisting of investigation of materials, components, supplies, and services to determine conformance to those specified requirements which can be determined by such investigation. Examination is usually nondestructive and includes simple physical manipulation, gaging, and measurement.

NQA-1 Subpart 2.8 defines examination similar to ANSI N45.2.61.4.3 Testing. The determination or verification of the capability of an item to meet specified requirements bytesting - an element of verification for the determination of the capability of an item to meet specified requirements byNQA-1 defines testing similar to

ANSI N45.2.6 04/21/04Quality Assurance ProgramPage 7 of 26 CRITERION 2 ANSI N45.2-1977/N18.7-1976 BASIC REQUIREMENT 2 NQA-1 1994 COMMENTSsubjecting the item to a set of physical, chemical,environmental, or operating conditions.subjecting the item to a set of physical, chemical, environmental, or operating conditions

1.4.4 Refer

to ANSI N45.2.10 for other definitions to be

used in conjunction with this Standard.

NQA-1 contains definitions in the

Introduction to Part I that are used

with this section.It supplements the requirements of Basic Requirement 2 of

this Part (Part I) and shall be used in conjunction with that Basic Requirement when and to the extent specified by the organization invoking this Part (Part I). The requirements of this Supplement do not apply to the qualification of personnel for performance of nondestructive examination.Not a requirement.

1.5 Referenced

DocumentsOther documents that are required to be included as a part

of this Standard are either identified at the point of

reference or described in Section 6 of this Standard. The issue or edition of the referenced document that is required

will be specified either at the point of reference or in

Section 6 of this Standard.Not a requirement.

N18.7 - 3.3 Indoctrination and Training.

2 CERTIFICATIONProvisions shall be made for indoctrination and training ofthose personnel in the owner organization performing activities affecting quality to assure that suitable proficiency is achieved and maintained. Such personnel also shall be provided training concerning the administrative controls and quality assurance program which, as a minimum, shall include the following areas:

overall company policies, procedures, or instructions which establish the program; procedures or instructions which implement the program related to the specific job-related activity.N18.7 and NQA-1 have similar requirements for qualification and

training. NQA-1 covers this with

section 2.1 through 2.7 below. In

addition, NQA-1, SUPPLEMENT

2S-4, calls out additional

indoctrination and training requirements. Intent of the standards

is consistent, although NQA-1-1994 is more specific.

2. GENERAL REQUIREMENTS2.1 Qualification Requirements

2.1 Planning

Plans shall be developed for staffing, indoctrination, and

training of an adequate num ber of personnel to performthe required actions, examinations, and tests and shall reflect the schedule of project activity so as to know adequate time for assignment or selection and training of

the required personnel.

NQA-1 addresses Planning in Part II.

04/21/04Quality Assurance ProgramPage 8 of 26 CRITERION 2 ANSI N45.2-1977/N18.7-1976 BASIC REQUIREMENT 2 NQA-1 1994 COMMENTS 4. PERFORMANCE Personnel who are assigned the responsibility andauthority to perform functions covered by this Standardshall have, as a minimum, the level of capability shown in

Table 1. When a single inspection or test requires implementation by a team or group, personnel not meeting the requirements of this Standard may be used in data-taking assignments or in plant or equipment operation provided they are supervised or overseen by a qualified individual participating in the inspection, examination, or

test.Regulatory Guide-1.58 C-7. Section 4, "Performance," of

ANSI N45.2.6-1978 states: "When a single inspection or test requires implementation by a team or group, personnel not meeting the requirements of this Standard may be used in data-taking assignments or in plant or equipment operation provided they are supervised or overseen by a

qualified individual particip ating in the inspection,examination, or test." These personnel should have

sufficient training to ensure an acceptable level of competence in the performance of their activities.

The responsible organization shall designate those

activities that require qualified inspection and test personnel and the minimum requirements for such

personnel. Further, the res ponsible organization shall establish written procedures for the qualification of

inspection and test personnel, and for the assurance that only those personnel who meet the requirements of this Supplement are permitted to perform inspection and test

activities. When a single inspection or test requires implementation by a team or a group, personnel not meeting the requirements of this Part (Part I) may be used in data-taking assignments or in plant or equipment operation, provided they are supervised or overseen by a

qualified individual.Similar requirements. Rather than

NQA-1 containing a table for levels of capability the information is contained

in Appendix 2A-1.

2.2 Personnel

SelectionPersonnel selected for performing inspection and test

activities shall have the experience or training commensurate with the scope, complexity, or special

nature of the activities.

2.1.1 Indoctrination.

2.3 IndoctrinationProvisions

shall be made for the indoctrination of

personnel as to the technical objectives of the project; the

codes and standards that are to be used; and the quality assurance elements that are to be employed.Provisions shall be made for the indoctrination of personnel as to the technical objectives and requirements

of the applicable codes and standards, and the quality assurance program elements that are to be employed.

2.1.2 Training.

2.4 TrainingThe

need for formal training programs shall be determined, and such training activities shall be conducted as required to qualify personnel who perform inspections,examinations, and tests.The need for a formal training program shall be determined, and such training activities shall be conducted as required to qualify personnel who perform inspections and tests.

On-the job participation shall also be included in the program, with emphasis on first-hand experience gainedOn-the-job training shall also be included in the program, with emphasis on first-hand experience gained through 04/21/04Quality Assurance ProgramPage 9 of 26 CRITERION 2 ANSI N45.2-1977/N18.7-1976 BASIC REQUIREMENT 2 NQA-1 1994 COMMENTSthrough actual performance of actions, examinations, and tests. actual performance of inspections and tests.

Records of training, when used as the basis forcertification, shall be maintained.

Records are addressed in Section 3 of this Supplement to NQA-1.

2.2 Determination

of Initial Capability2.5 Determination of Initial Capability The capabilities of a candidate for certification shall be initially determined by a suitable evaluation of the candidate's education, experience, training, test results, or capability demonstration.Regulatory Guide-1.58 C-10. Section 2.2, "Determination of Initial Capability," and Section 2.3, "Evaluation of Performance," of ANSI N45.2.6-1978 deal with the use of evaluation of job performance and determination of initial capability to perform the job. Use of the measures outlined

in these sections to establish that an individual has the

required qualifications in lie u of required education andexperience should result in documented objected evidence (i.e., procedures and record of written test) demonstrating that the individual indeed does have "comparable" or "equivalent" competence to that which would be gained from having the required education and experience.

The capabilities of a candidate for certification shall be initially determined by a suitable evaluation of the candidate's education, experience, training, and either test results or capability demonstration.Note Dominion nuclear facilities were previously committed to Regulatory

Guide 1.58, which was withdrawn by

the NRC based on acceptance of

NQA-1-1983. The NRC has accepted

NQA-1-1994 as equivalent to NQA 1983 (Exelon SER), therefore any

specific reference in this table to RG 1.58 is met or superceded by use of

NQA-1.2.3 Evaluation of Performance2.6 Evaluation of PerformanceThe job performance of inspection, examination, and

testing personnel shall be reevaluated at periodic intervals not to exceed three years. The job performance of inspection and test personnel shall be reevaluated at periodic intervals not to exceed 3 years.This requirements of this subsection are similar for ANSI N45.2.6 and

NQA-1-1994.Reevaluation shall be by evidence of continued satisfactory performance or redetermination of capability

in accordance with Subsection 2.2.Reevaluation shall be by evidence of continued satisfactory performance or re-determination of capability in accordance with the requirements of para. 2.5 above.If, during this evaluation or at any other time, it is determined by the responsible organization that the

capabilities of an individual are not in accordance with the

qualifications specified for the job, that person shall be removed from that activity until such time as the required capability has been demonstratedIf during this evaluation or at any other time, it is determined by the responsible organization that the

capabilities of an individual are not in accordance with the qualification requirements specified for the job, that person shall be removed from that activity until such time as the required capability has been demonstrated.Any person who has not performed inspection, examination, or testing activities in his qualified area for a period of one year shall be reevaluated by a redetermination of required capability in accordance withAny person who has not performed inspection or testing activities in his qualified area for a period of 1 year shall be reevaluated by a re-determination of required capability in accordance with the requirements of para. 2.5 above.

04/21/04Quality Assurance ProgramPage 10 of 26 CRITERION 2 ANSI N45.2-1977/N18.7-1976 BASIC REQUIREMENT 2 NQA-1 1994 COMMENTS Subsection 2.2.

2.4 Written

Certification of Qualification

2.7 Certificate

of Qualification The qualification of personnel shall be certified in writingin an appropriate form, including the following information:

The qualification of personnel shall be certified in writing in an appropriate form, including the following information:This requirements of this subsection are virtually the same in both

standards.1. employer's name(a) employer's name;

2. identification of person being certified (b) identification of person being certified;

3. level of capability

4. activities certified to perform(c) activities certified to perform;

5. basis used for certification, including: (d) basis used for certification, which includes such factors as: (a) records of education, experience and training (1) education, experience, indoctrination, and training (b) test results, where applicable (2) test results, where applicable (c) results of capability demonstration(3) results of capability demonstration

6. results of periodic evaluations (e) results of periodic evaluation;7. results of physical examinations, when required(f) results of physical examinations, when required;8. signature of employer's designated representative(g) signature of employer's designated representative who

is responsible for such certification; Clarification in NQA-1

9. date of certification and da te of certification expiration (h) date of certification and da te of certification expiration.

2.5 Physical2.8 PhysicalThe responsible organization shall identify any specialphysical characteristics needed in the performance of eachactivity. Personnel requiring these characteristics shall have them verified by examination at intervals not to exceed one year.The responsible organization shall identify any special physical characteristics needed in the performance of eachactivity, including the need for initial and subsequent physical examination.Similar requirements. NQA-1 requires "Subsequent examinations" whereas

N45.2 requires "intervals not to exceed one year."

3. QUALIFICATIONSThe following information is from Appendix 2A-1

3.1 General

1 GENERALThe requirements contained within this Section define the minimum capabilities that qualify personnel to perform inspections, examinations, and tests which are within the

scope of this Standard. There are three levels of qualification. The requirements for each level are not limiting with regard to organizational position of professional status, but rather, are limiting with regard to

functional activities which are within the scope of this

Standard.This Appendix provides nonmandatory guidance on the

qualifications of inspection and test personnel. This Appendix may be used in conjunction with Basic Requirement 2 and Supplement 2S-1 of Part I.

2 FUNCTIONAL QUALIFICATIONS Three levels of qualification may be utilized depending onthe complexity of the functions involved. The recommendations for each level are not limiting with

regard to organizational positi on or professional status but,rather, are limiting with regard to functional activities.NQA-1-1994, Supplement 2S-1, Supplementary Requirements for the

Qualification of Inspection and Test

Personnel will include use of the

guidance provided in Appendix 2A-1, or the proposed alternatives as

approved.

04/21/04Quality Assurance ProgramPage 11 of 26 CRITERION 2 ANSI N45.2-1977/N18.7-1976 BASIC REQUIREMENT 2 NQA-1 1994 COMMENTSProposed alternative to qualification requirements forDominion QA Program - (1) The company may choose to not specifically use the designations of Level I, II, and III

for qualification of inspectors. However, the qualification program will ensure that only personnel that meet the

required education and experience requirements, and havedemonstrated appropriate capabilities in the inspection activities they are assigned will be certified and used to perform those inspections. The inspectors used in planning inspections will meet or exceed the education and experience requirements of for a Level II inspector plus have an additional three years of related inspection

experience for nuclear facilities. The inspectors used to evaluate the capabilities of other inspectors will meet or exceed the education and experience requirements for a Level II inspector plus have an additional five years of related experience in inspection, examination, or testing

activities for nuclear facilities. This related experience may include ASME VT 1, 2, or 3 examinations, NDE, or

ASME Section XI inservice inspection or testing activities. A qualified engineer may also be used to

evaluate the capabilities of an inspector. The training program for inspectors will be evaluated and approved by personnel who meet the education, experience, and

capabilities designated for a Level III person specific to

the discipline or a qualified engineer. For the purposes of

this alternative, a qualified engineer is one who has a baccalaureate in engineering in a discipline related to the inspection activity (such as, electrical, mechanical, civil) and has a minimum of five years engineering work experience with at least two years of this experience

related to nuclear facilities. (2) As an alternative to the education requirement of high school graduation (or GED), satisfactory demonstration of reading, writing, and mathematical skills through completion of an NANT accredited training development program or an approved inspector training program for nuclear facility personnel will be deemed equivalent.

The following information on Level I, II, and III is 04/21/04Quality Assurance ProgramPage 12 of 26 CRITERION 2 ANSI N45.2-1977/N18.7-1976 BASIC REQUIREMENT 2 NQA-1 1994 COMMENTS from Appendix 2A-1

3.2 Level

I Personnel Capabilities

2.1 Level

I Personnel CapabilitiesA Level I person shall be capable of performing theinspections, examinations, and tests that are required to be performed in accordance with documented procedures and/or industry practices. The individual shall be familiar with the tools and equipment to be employed and shall have demonstrated proficiency in their use. The individual shall also be capable of determining that the calibration status of inspection and measuring equipment is current, that the measuring and test equipment is in proper condition for use, and that the inspection, examination, and test procedures are approved.A Level I person should be capable of performing and documenting the results of inspections or tests that are required to be performed in accordance with documented

procedures, acceptance standards, and/or industry practices as defined in user's written procedures.Similar capabilities described.

3.3 Level

II Personnel Capabilities

2.2 Level

II Personnel Capabilities A Level II person shall have all of the capabilities of a Level I person for the inspection, examination or test category or class in question. Additionally, a Level II person shall have demonstrated capabilities in planning inspections, examinations, and test; in setting up tests including preparation and set-up of related equipment, as

appropriate; in supervising or maintaining surveillanceover the inspections, examinations, and tests; in supervising and certifying lower level personnel; inreporting inspection, examination, and testing results; and in evaluating the validity and acceptability of inspection, examination, and test results A Level II person should have all of the capabilities of a Level I person for the inspection or test category or class in question. Additionally, a Level II person should havedemonstrated capabilities in planning inspections and

tests; in setting up tests, including preparation and setup of related equipment, as appr opriate; in supervising ormaintaining surveillance over the inspections and tests; in supervising and certifying lo wer level personnel; and inevaluating the validity and acceptability of inspection and

test results.Similar capabilities described.

3.4 Level

Ill Personnel Capabilities

2.3 Level

III Personnel Capabilities A Level III person shall have all of the capabilities of a Level II person for the inspection, examination or test category or class in question. In addition, the individual shall also be capable of evaluating the adequacy of specific programs used to train and test inspection, examination, and test personnel whose qualifications are covered by this Standard.Regulatory Guide-1.58 C-5. Section 3.4, "Level III

Personnel Capabilities," of ANSI N45.2.6-1978 specifies the capability requirements of Level III personnel. In

additional, the individual shoul d be capable of reviewing A Level III person should have all of the capabilities of aLevel II person for the inspection or test category or class

in question. in addition, the individual should also be capable of evaluating the adequacy of specific programs used to train and certify inspection and test personnel

whose qualifications are covered by this Appendix.Similar capabilities described.

04/21/04Quality Assurance ProgramPage 13 of 26 CRITERION 2 ANSI N45.2-1977/N18.7-1976 BASIC REQUIREMENT 2 NQA-1 1994 COMMENTSand approving inspection, examination, and testingprocedures and of evaluating the adequacy of such procedures to accomplish the inspection, examination, and

test objectives.The following information on education and experience is from Appendix 2A-1

3.5 Education

and Experience - Recommendations3 EDUCATION AND EXPERIENCE QUALIFICATIONSThe following is the recommended personnel education and experience for each level. These education and experience recommendations should be treated to recognize that other factors may provide reasonable assurance that a person can competently perform a particular task. Other factors which may demonstrate capability in a given job are previous performance or satisfactory completion of capability testingRegulatory Guide-1.58 C-6. Section 3.5, "Education and Experience-Recommendations," of ANSI N45.2.6.-1978

states that the education and experience specified are recommendations and that other factors may provide reasonable assurance that a person can competently perform a particular task. The set of recommendations has been reviewed by the NRC staff and found to be

acceptable with one exception. In addition to the recommendations listed under Section 3.5 for Level I, II, and III personnel, the candida te should be a high school graduate or have earne d the General EducationDevelopment equivalent of a high school diploma. Sinceonly one set of recommendations is provided for the education and experience of personnel, a commitment to comply with the regulatory positions of this guide in lieu of providing an alternative to the recommendations of the standard means that the specified education and experience recommendations of the standard will be

followed.These education and experience recommendations should

be considered with recognition that other factors commensurate with the scope, complexity, or special nature of the activity may provide reasonable assurance that a person can competently perform a particular task.

Other factors which may demonstrate capability in a given job are previous performance or satisfactory completion of capability testing. These factors and the basis for their equivalency should be documented.Similar recommendations.

3.5.1 Level

I

3.1 Level

I1. Two years of related experience in equivalentinspection, examination, or testing activities, or3.1.1 Two years of related experience in equivalent

inspection or testing activities; orSimilar recommendations.

04/21/04Quality Assurance ProgramPage 14 of 26 CRITERION 2 ANSI N45.2-1977/N18.7-1976 BASIC REQUIREMENT 2 NQA-1 1994 COMMENTS 2. High school graduation and six months of relatedexperience in equivalent inspection, examination, or

testing activities, or 3.1.2 High school graduation and 6 months of related experience in equivalent inspection or testing activities; orSimilar recommendations.3. Completion of college level work leading to an Associate Degree in a related discipline plus three months

of related experience in equivalent inspection, examination, or testing activities.3.1.3 Completion of college level work leading to an associate degree in a related discipline plus 3 months of

related experience in equiva lent inspection or testing activities.Similar recommendations.

3.5.2 Level

II

3.2 Level

II1. One year of satisfactory performance as Level I in the corresponding inspection, examination or test category or

class, or3.2.1 One year of satisfactory performance as a Level I in the corresponding inspection or test category or class; orSimilar recommendations.2. High school graduation plus three years of related experience in equivalent inspection, examination, or

testing activities, or3.2.2 High school graduation plus 3 years of related

experience in equivalent inspection or testing activities; orSimilar recommendations.3. Completion of college level work leading to associate Degree in a related discipline plus one year related experience in equivalent inspection, examination, or

testing activities, or3.2.3 Completion of college level work leading to an associate degree in a related discipline plus 1 year of

related experience in equiva lent inspection or testing activities; orSimilar recommendations.4. Four-year college graduation plus six months of relatedexperience in equivalent inspection, examination, or

testing activities3.2.4 Graduation from a 4 year college plus 6 months of

related experience in equiva lent inspection or testing activities.Similar recommendations.

3.5.3 Level

III

3.3 Level

III1. Six years of satisfactory performance as a Level II in the corresponding inspection, examination or test category

or class, or3.3.1 Six years of satisfactory performance as a Level II in the corresponding inspection or test category or class; orSimilar recommendations.

2. High school graduation plus ten years of relatedexperience in equivalent inspection, examination, or

testing activities; or high school graduation plus eight years experience in equivalent inspection, examination, or testing activities, with at least two years as Level II, and with at least two years associated with nuclear facilities-or

if not, at least sufficient training to be acquainted with the relevant quality assurance aspects of a nuclear facility, or3.3.2 High school graduation plus 10 years of related

experience in equivalent inspection or testing activities; or high school graduation plus 8 years of experience in

equivalent inspection or testing activities with at least 2 years as a Level II and with at least 2 years associated with

nuclear facilities - or, if not, at least sufficient training to be acquainted with the relevant quality assurance aspects of a nuclear facility; orSimilar recommendations.3. Completion of college level work leading to an associate Degree and seven years of related experience in equivalent inspection, examination, or testing activities, with at least two years of this experience associated with

nuclear facilities-or if not, at least sufficient training to be3.3.3 Completion of college level work leading to an associate degree and 7 years of related experience in

equivalent inspection or testing activities with at least 2 years of this experience associated with nuclear facilities -

or, if not, at least sufficient training to be acquainted withSimilar recommendations.

04/21/04Quality Assurance ProgramPage 15 of 26 CRITERION 2 ANSI N45.2-1977/N18.7-1976 BASIC REQUIREMENT 2 NQA-1 1994 COMMENTSacquainted with the relevant quality assurance aspects of anuclear facility, orthe relevant quality assurance aspects of a nuclear facility;

or4. Four-year college graduation plus five years of related experience in equivalent inspection, examination, or testing activities, with at least two years of this experience

associated with nuclear facilities-or if not, at least

sufficient training to be acquainted with the relevant quality assurance aspects of a nuclear facility.3.3.4 Graduation from a 4 year college plus 5 years of

related experience in equiva lent inspection or testingactivities with at least 2 years of this experience associated

with nuclear facilities - or, if not, at least sufficient

training to be acquainted with the relevant qualityassurance aspects of a nuclear facility.Similar recommendations.The following is from Supplement 2S-1

5. RECORDS 3 RECORDS 3.1 Record Files A File of records of personnel qualification shall be established and maintained by the employer. Collection, storage, and control of records required by this Standard

shall be in accordance with ANSI N45.2.9.

Records of personnel qualifica tion shall be established andmaintained by the employer. These records shall include the information required by para. 2.7 above.Similar requirement.

ANSI N45.2.6 addresses the qualification of inspection

and test personnel, as described above. For NDE

activities, N45.2.6 refers to the use of SNT-TC-1A for

qualification.Regulatory Guide-1.58 C-8. An important concept that is not addressed directly in ANSI N45.2.6-1978. ANST Recommended Practice No. SNT-TC-1A-1975, or the

ASME Boiler and Pressure Vessel Code is that

occupational radiation exposure should be maintained as low as is reasonable achievable (ALARA). In all cases where inspection, examination, and testing personnel may

be exposed to radiation field during their activities in

restricted areas, these personnel should receive instruction

in radiation protection a nd radiation-dose-reductionconsiderations related to work they are expected to perform. Regulatory Guide 8.8, "Information Relevant to

Ensuring that Occupational Radiation Exposures at

Nuclear Power Stations Will Be As Low As Is Reasonably

Achievable," describes techniques, features, and recommendations to maintain occupational exposures

ALARA.SUPPLEMENT 2S-2Supplementary Requirements for the Qualification of Nondestructive Examination PersonnelNQA-1-1994, Supplement 2S-2, Supplementary Requirements for the Qualification of Nondestructive Examination Personnel, subsection 2.1, requires application of Recommended Practice SNT-TC-1A, June 1980 Edition to NDE personnel. The company will implement the qualification program required by this supplement in accordance with th e applicable standard forthe facility's commitment to the ASME code or other applicable code governing the activity. This alternative is

considered acceptable because other editions of this recommended practice or other national standards may be required by industry codes or regulations for qualification of NDE personnel Exceptions and clarifications to NQA-1-1994, supplement 2S-1 defined.

1 GENERALThis Supplement provides amplified requirements for the 04/21/04Quality Assurance ProgramPage 16 of 26 CRITERION 2 ANSI N45.2-1977/N18.7-1976 BASIC REQUIREMENT 2 NQA-1 1994 COMMENTS qualification of personnel who perform radiographic (RT),magnetic particle (MT), ultr asonic (UT), liquid penetrant(PT), eddy current (ET), neutron radiographic (NRT), leak testing (LT), acoustic emission (AE), and visual testing (VT) [hereinafter referred to as nondestructive examination (NDE)] to verify conformance to specified requirements.It supplements the requirements of Basic Requirement 2 of

this Part (Part I) and shall be used in conjunction with that Basic Requirement when and to the extent specified by the

organization invoking this Part (Part I).

2 CERTIFICATION2.1 Applicable Documents The American Society of Nondestructive Testing Recommended Practice No. SNT-TC-1A, December 1980 Edition, and its applicable supplements shall apply as requirements to NDE personnel covered by this Supplement.

Each standard invokes a different

edition of SNT-TC-1A.The quality program should designate the specific edition the company will meet. It may be that we describe that as being specified in the implementing

procedures and correspondence with the NRC (similar to changed ASME

codes).2.2 Program The responsible organization shall establish written procedures for the control and administration of NDE personnel training, examination, and certification.

2.3 Records

Records of personnel qualifica tion shall be established andmaintained by the employer.

SUPPLEMENT 2S-3Supplementary Requirements for the Qualification of Quality Assurance Program Audit Personnel ANSI N45.2.23 addresses the

qualification of lead auditors. NQA 1994 is consistent with ANSI

N45.2.23.ANSI N45.2.23 addresses the qualification of lead auditor:This Standard provides requirements and guidance for the qualification of audit team leaders, henceforth identified as

a "Lead Auditor", who organizes and directs audits, reports, audit findings, and evaluates corrective action.

04/21/04Quality Assurance ProgramPage 17 of 26 CRITERION 2 ANSI N45.2-1977/N18.7-1976 BASIC REQUIREMENT 2 NQA-1 1994 COMMENTSThis Standard also provides requirements and guidance for the qualifications of individua ls, henceforth referred to as"Auditor", who participate in an audit, such as technical specialists, management representatives, and auditors-in-

training.1.2 Applicability 1 GENERALN45.2.23 was a standalone document therefore repeats applicability and

definitions defined in NQA-1-1994.The requirements of this Standard apply to Auditors and Lead Auditors who perform audits for the plant owner, contractors, or other organizations participating in activities affecting the quality of structures, systems, and components of nuclear power plants which are subject to audit in accordance with requirements of ANSI N45.2.

This Standard shall be used in conjunction with the requirements of ANSI N45.2.12.

1.3 Responsibility

The organization or organi zations responsible forimplementation of the applicable requirements of this

standard shall be identified and the scope of their responsibilities and authorities shall be documented. The

work of establishing practices and procedures and providing the resources in terms of personnel, equipment, and services necessary to implement the requirements of this Standard may be delegate d to other organizations, andsuch delegations shall also be documented. It is the responsibility of each of these organizations to comply

with the practices and procedures so established and to conform with the applicable requirements of this Standard.Responsibility is defined in the

Introduction of NQA-1-1994, Section

I-3.1.4 Definitions The following definitions are provided to assure uniform understanding of selected terms as they are used in this Standard. Other terms and definitions are contained in

ANSI N45.2.10.NQA-1-1994 calls out in Supplement

2S-3-1 "General" what an "auditor" and "lead" auditor means rather than

specific definitions.

1.4.1 Auditor. Any individual who performs any portion of an audit, including Lead Auditors, technical specialists, and others such as management representatives and

auditors-in-training.

04/21/04Quality Assurance ProgramPage 18 of 26 CRITERION 2 ANSI N45.2-1977/N18.7-1976 BASIC REQUIREMENT 2 NQA-1 1994 COMMENTS 1.4.2 Lead Auditor. An individual qualified to organize and direct an audit, report audit findings, and evaluate

corrective action.

1 4.3 Audit. A documented activity performed inaccordance with written procedures or checklists to verify, by examination and evaluation of objective evidence, that applicable elements of the quality assurance program have been developed, documented, and effectively implemented in accordance with specified requirements. An audit

should not be confused with surveillance or inspection for

the sole purpose of process control or product acceptance.audit - a planned and documented activity performed to determine by investigation, examination, or evaluation of

objective evidence the adequacy of and compliance with established procedures, instru ctions, drawings, and otherapplicable documents, and the effectiveness of implementation. An audit should not be confused with

surveillance or inspection activities performed for the solepurpose of process control or product acceptance. [from

Part I - Introduction]NQA-1 similar definition to ANSI

N45.2.10.1.5 Referenced DocumentsDocuments that are referenced in this Standard are

identified at the point of reference and described in

Section 6 of this Standard REGULATORY POSITION

RG 1.146 C1. Section 1.5 of ANSI/ASME N45.2.23-1978 states that documents that are referenced in this standard are

identified at the point of reference and described in Section 6 of the standard. The specific applicability of these listed documents has been addressed in the latest revision of the following regulatory guides:ANSI Standard Regulatory Guide N45.2 1.28 N45.2.9 1.88 N45.2.10 1.74 REGULATORY POSITION RG 1.146 C2. ANSI/ASME N45.2.23-1978 does not include the statement that is found in other N45.2 series standards excluding activities covered by ASME Boiler and Pressure

Vessel Code Section III, Divisions 1 and 2, and Section XI from the requirements of the standard. The NRC staff

considers that ANSI/ASME N45.2.23-1978 applies to

these Code-covered activities where the ASME Code does not address the requirements covered by ANSI/ASME

N45.2.23-1978.

2. QUALIFICATIONS OF AUDITORS AND LEAD 04/21/04Quality Assurance ProgramPage 19 of 26 CRITERION 2 ANSI N45.2-1977/N18.7-1976 BASIC REQUIREMENT 2 NQA-1 1994 COMMENTS AUDITORS (ANSI N45.2.23)

2.1 General

This Section delineates the qualifications of Auditor and Lead Auditors.This Supplement provides amplified requirements for the qualification of an audit team leader, henceforth identified

as a Lead Auditor, who organizes and directs audits, reports audit findings, and evaluates corrective action.This Supplement also provides amplified requirements for

the qualifications of individua ls, henceforth referred to as Auditors, who participate in an audit, such as technical specialists, management representatives, and

auditors-in-training.It supplements the requirements of Basic Requirement 2 of

this Part (Part I) and shall be used in conjunction with that Basic Requirement when and to the extent specified by the

organization invoking this Part (Part I).

2.2 Qualification

of Auditors 2 QUALIFICATION OF AUDITORS2.1 Responsibility of Auditing Organization The responsible auditing organization shall establish the

audit personnel qualifications and the requirements for theuse of technical specialists to accomplish the auditing of the quality assurance programs The responsible auditing organization shall establish the

audit personnel qualifications and the requirements for theuse of technical specialists to accomplish the auditing of quality assurance programs.Similar requirements.Personnel selected for quality assurance auditing assignments shall have experience or training commensurate with the scope, complexity, or special

nature of the activities to be audited.Personnel selected for quality assurance auditing assignments shall have experience or training commensurate with the scope, complexity, or special

nature of the activities to be audited.Similar requirements.

Auditors shall have, or be given, appropriate training ororientation to develop their competence for performing

required audits.

Auditors shall have, or be given, appropriate training ororientation to develop their competence for performing

required audits.Similar requirements.Competence of personnel for performance of the various

auditing functions shall be developed by one or more ofthe following methods:Competence of personnel for performance of the various

auditing functions shall be developed by one or more ofthe methods given in (a) through (c) below:Similar requirements.

2.2.1 Orientation

to provide a working knowledge and

understanding of ANSI B45.2, this Standard, and theauditing organization's procedures for implementing audits

and reporting results.(a) orientation to provide a working knowledge and

understanding of this Part (Part I) and the auditing organization's procedures for implementing audits and

reporting results;Similar requirements.2.2.2 Training programs to provide general and specialized training in audit performance. (b) training programs to provide general and specialized training in audit performance.Similar requirements.General training shall include fundamentals, objectives, characteristics, organization, performance, and results ofGeneral training shall include fundamentals, objectives, characteristics, organization, performance, and results ofSimilar requirements.

04/21/04Quality Assurance ProgramPage 20 of 26 CRITERION 2 ANSI N45.2-1977/N18.7-1976 BASIC REQUIREMENT 2 NQA-1 1994 COMMENTSquality auditing..quality auditing.Specialized training shall include methods of examining,questioning, evaluating, and documenting specific audit items and methods of closing out audit findingsSpecialized training shall include methods of examining, questioning, evaluating, and documenting specific audit items and methods of closing out audit findings.Similar requirements.

2.2.3 On-the-job training guidance, and counseling under

the direct supervision of a Lead Auditor. Such training shall include planning, performing, reporting, and follow-

up action involved in conducting audits.(c) on-the-job training, guidance, and counseling under the

direct supervision of a Lead Auditor. Such training shall include planning, performing, reporting, and follow-up

action involved in conducting audits.Similar requirements.

2.3 Qualification

of Lead Auditors 3 QUALIFICATION OF LEAD AUDITORSAn individual shall meet the requirements of paragraphs

2.3.1 through

2.3.5 prior to being designated a Lead

Auditor.An individual shall meet the requirements of para[graph]s

3.1 through

3.4 below prior to being designated a Lead

AuditorSimilar requirements.

2.3.1 Education

and Experience. The prospective Lead Auditor shall have verifiable evidence that a minimum of ten (10) credits under the following scoring system have been accumulated.

2.3.1.1 Education (4 credits maximum).

Associate degreefrom an accredited institution score one (1) credit or if the degree is an engineering, physical sciences, mathematics, or quality assurance, score two (2) credits or, a bachelor degree from an accredited institution score two (2) credits or if the degree is in engineering, physical sciences, mathematics, or quality assurance, score three (3) credits; in addition score one (1) credit for a master degree in engineering, physical sciences, business management, or quality assurance from an accredited institution.

NQA-1-1994 does not require specific

education and experience to the level

described in N45.2.23, but has included this information in Appendix 2A-3, Non-mandatory Guidance on

the Education and Experience of Lead

Auditors. NQA-1 SUPPLEMENT 2S-4 (described below) meets the

intent of this section.

2.3.1.2 Experience (9 points maximum).

Technicalexperience in engineering, manufacturing, construction, operation, or maintenance, score one (1) credit for each full year with a maximum of five (5) credits for this aspect of experience. If two (2) or more years of this experience

have been in the nuclear field, score one (1) additional credit, or, if two (2) or more years of this experience have been in quality assurance, score two (2) additional credits, or, if two (2) or more years of this experience have been in

auditing, score three (3) additional credits, or, if two (2) or more years of this experience have been in nuclear quality

assurance, score three (3) additional credits, or, if two (2)

.

04/21/04Quality Assurance ProgramPage 21 of 26 CRITERION 2 ANSI N45.2-1977/N18.7-1976 BASIC REQUIREMENT 2 NQA-1 1994 COMMENTSor more years of this experience have been in nuclearquality assurance auditing, score four (4) additional

credits.2.3.1.3 Other Credentials of Professional Competence (2 credits maximum). Certification of competency inengineering, science, or quality assurance specialties issued and approved by a State Agency, or National Professional or Technical Society, score two (2) credits.

2.3.1.4 Rights of Management (2 points maximum).

TheLead Auditor's employer may grant up to two (2) credits for other performance factors applicable to auditing which may not be explicitly called out in this standard. Examples of these factors are leadership, sound judgment, maturity, analytical ability, tenacity, past performance, QA training

courses.2.3.2 Communication Skill.3.1 Communication Skills The prospective Lead Auditors shall have the capability tocommunicate effectively, both written and oral.

The prospective Lead Auditor shall have the capability tocommunicate effectively, both in writing and orally.Similar requirements.These skills shall be attested to in writing by the Lead Auditor's employer.These skills shall be attested to in writing by the Lead Auditor's employer.Similar requirements.

3.2 Training

Prospective Lead Auditors shall have training to the extent necessary to assure their competence in auditing skills.

Prospective Lead Auditors shall have training to the extent necessary to assure their comp etence in auditing skills.Similar requirements.

Training in the following areas shall be given based uponmanagement evaluation of the particular needs of each

prospective Lead Auditor.

Training in the following areas shall be given based upon management evaluation of the particular needs of each

prospective Lead Auditor.Similar requirements.

2.3.3.1 Knowledge and unders tanding of ANSI N45.2, itsassociated Standards, particularly ANSI N45.2.12, and

other nuclear-related codes, standards, regulations,regulatory guides, as applicable.

3.2.1 Knowledge

a nd understanding of this Part (Part I) and other nuclear-related cod es, standards, regulations,and regulatory guides, as applicable.N45.2.23 called out details met by the statement in NQA-1 regarding the elements in NQA-1-1994, Part I.2.3.3.2 General structure of quality assurance programs as a whole and applicable elements such as organization; design control; procurement document control; instructions; procedures and drawings; document control; control of purchased material equipment and services; identification and control of materials, parts and components; control of special processes; inspection; test control; control of measuring and test equipment;3.2.2 General structure of quality assurance programs as a whole and applicable elements as defined in this Part (Part

I).N45.2.23 called out details met by the statement in NQA-1 regarding the elements in NQA-1-1994, Part I.

04/21/04Quality Assurance ProgramPage 22 of 26 CRITERION 2 ANSI N45.2-1977/N18.7-1976 BASIC REQUIREMENT 2 NQA-1 1994 COMMENTS handling, storage and shipping; inspection, test, andoperating status; nonconforming materials, parts, or components; corrective action; quality assurance records; audits; and quality information feedback.2.3.3.3 Auditing techniques of examining, questioning, evaluating and reporting; methods of identifying and following up on corrective action items; and closing out

audit findings.3.2.3 Auditing techniques of examining, questioning, evaluating, and reporting; methods of identifying and following up on corrective action items; and closing out

audit findings.Similar requirements.

2.3.3.4 Audit planning in the quality-related functions for the following activities: design, purchasing, fabrication, handling, shipping, storage, cleaning, erection, installation, inspection, testing, statistics, nondestructive examination, maintenance, repair, operation, modification of nuclear facilities or associated components and safety aspects of the nuclear facility.

3.2.4 Audit

planning in the quality-related functions for the following activities: siting, designing, purchasing, fabricating, handling, shipping, receiving, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, modifying,and decommissioning of nuclear facilities or associated components, and safety aspects of the nuclear facility.

NQA-1 adds "siting", "refueling" and "decommissioning" as the standard

addresses construction. 2.3.3.5 On-the-job training to include the elements of audit activity as described in ANSI N45.2.12.3.2.5 On-the-job training to include applicable elements of the audit program.Similar requirement.

2.3.4 Audit

Participation.

3.3 Audit

Participation The prospective Lead Auditor sh all have participated in aminimum of five (5) quality assurance audits within a period of time not to exceed three (3) years prior to the

date of qualification, one aud it of which shall be a nuclearquality assurance audit within the year prior to his

qualification.

The prospective Lead Auditor sh all have participated in aminimum of five (5) quality assurance audits within a period of time not to exceed 3 years prior to the date of

qualification, one audit of wh ich shall be a nuclear qualityassurance audit within the year prior to his qualification.Similar requirement.2.3.5 Examination.3.4 Examination The prospective Lead Auditor shall pass an examinationwhich shall evaluate his comprehension of and ability to apply the body of knowledge iden tified in paragraph 2.3.3.

The prospective Lead Auditor shall pass an examinationwhich shall evaluate his comprehension of and ability to apply the body of knowledge id entified in para. 3.2 above.Similar requirement.The test may be oral, written, practical, or anycombination of the three types. The examination may be oral, written, practical, or any combination of the three types.Similar requirement.The development and administration of the examination

shall be in accordance with Section 4 of this Standard.The development and administration of the examination shall be in accordance with Section 5 of this Supplement.Similar requirement.

3. MAINTENANCE OF QUALIFICATION 4 MAINTENANCE OF QUALIFICATION

3.1 GeneralThe

maintenance of proficiency established in this Section shall apply to the Lead Auditor only.

3.2 Maintenance

of Proficiency

4.1 Maintenance

of Proficiency 04/21/04Quality Assurance ProgramPage 23 of 26 CRITERION 2 ANSI N45.2-1977/N18.7-1976 BASIC REQUIREMENT 2 NQA-1 1994 COMMENTSLead Auditors shall maintain their proficiency through oneor more of the following: regular and active participation in the audit process; review and study of codes, standards, procedures, instructions, and other documents related toquality assurance programs and program auditing; participation in training programs. Lead Auditors shall maintain their proficiency through one or more of the following: regular and active participation in the audit process; review and study of codes, standards, procedures, instructions, and other documents related toquality assurance program and program auditing; or participation in training program(s).Similar requirement.Based on management annual assessment, management may extend the qualification, require retraining, or require

requalification.Based on annual assessment, management may extend the

qualification, require retraini ng, or require requalification.Similar requirement.

3.3 Requalification

4.2 RequalificationLead Auditors who fail to maintain their proficiency for aperiod of two years or more shall require requalification. Lead Auditors who fail to maintain their proficiency for a period of 2 years or more shall require requalification. Similar requirement.

Requalification shall include retraining in accordance with the requirements of paragraph 2.3.3, reexamination in

accordance with paragraph 2.3.5 and participation as an Auditor in at least one nuclear quality assurance audit.

Requalification shall include retraining in accordance with the requirements of para. 3.2 above, reexamination in

accordance with para. 3.4 above, and participation as an Auditor in at least one nuclear quality assurance audit.Similar requirement.These evaluations shall be documented.These evaluations shall be documented.Similar requirement.

4. ADMINISTRATION 5 ADMINISTRATION4.1 Organizational Responsibility

5.1 Organizational

ResponsibilityTraining of auditors shall be the responsibility of the employer.Training of auditors shall be the responsibility of the employer.Similar requirement.

The responsible auditing organization shall select and assign personnel who are independent of any direct responsibility for performance of the activities which they

will audit.

The responsible auditing organization shall select and assign personnel who are independent of any direct responsibility for performance of the activities which they

will audit.Similar requirement.The Lead Auditor shall, prior to commencing the audit, concur that assigned personnel collectively have experience or training commensurate with the scope, complexity, or special nature of the activities to be

audited.The Lead Auditor shall, prior to commencing the audit, concur that assigned personnel collectively have experience or training commensurate with the scope, complexity, or special nature of the activities to be

audited.Similar requirement.4.2 Qualification Examination5.2 Qualification ExaminationThe development and administration of the examination for Lead Auditor required by paragraph 2.3.5 is the responsibility of the employer. The development and administration of the examination for a Lead Auditor required by para. 3.4 above is the responsibility of the employer.Similar requirement.The employer may delegate this activity to an independent certifying agency, but shall retain responsibility for conformance of the examination and its administration to

this Standard. The employer may delegate this activity to an independent certifying agency, but shall retain responsibility for conformance of the examination and its administration to

this Part (Part I).Similar requirement.

04/21/04Quality Assurance ProgramPage 24 of 26 CRITERION 2 ANSI N45.2-1977/N18.7-1976 BASIC REQUIREMENT 2 NQA-1 1994 COMMENTSIntegrity of the examination shall be maintained by theemployer or certifying agency through appropriate confidentiality of files and, where applicable, proctoring of examinations. Integrity of the examination shall be maintained by the employer or certifying agency through appropriate confidentiality of files and, where applicable, proctoring of examinations.Similar requirement.Copies of the objective evidence regarding the type(s) and content of the examination(s) shall be retained by the employer in accordance with the requirements of Section

5.Copies of the objective evidence regarding the type(s) and content of the examination(s) shall be retained by the employer in accordance with the requirements of Section 6

below.Similar requirement.

5. RECORDS 6 RECORDS 5.1 General

6.1 General

Records of personnel qualifications for Auditors and Lead Auditors performing audits shall be established and maintained by the employer.

Records of personnel qualifications for Auditors and Lead Auditors performing audits shall be established and maintained by the employer.Similar requirement.

5.2 Certification

of Qualification

6.2 Certification

of QualificationEach Lead Auditor shall be certified by his employer as

being qualified to lead audits. Each Lead Auditor shall be certified by his employer as

being qualified to lead audits.Similar requirement.This certification shall, as a minimum, document the

following:This certification shall, as a minimum, document the

following:Similar requirement.a) Employer's name (a) employer's name:b) Lead Auditor's name(b) Lead Auditor's name; c) Date of certification or recertification (c) date of certification or recertification; d) Basis for qualification (i.e., education, experience, communication skills, training, examination, etc.)(d) basis of qualification (i.e., education, experience, communication skills, training, examination, etc.); e) Signature of employers' designated representative who

is responsible for such certification (e) signature of employer's designated representative who

is responsible for such certification.An example of a format for documenting the records of a

Lead Auditor is given in Appendix AExample not called out in NQA-1 but

exists in standard as Non-Mandatory

Appendix 2A-3

5.3 Updating

of Lead Auditors' Records6.3 Updating of Lead Auditors' Records Records for each Lead Auditor shall be maintained andupdated annually.

Records for each Lead Auditor shall be maintained andupdated annually.Similar requirement.

5.4 Record

Retention Qualification records shall be retained as required by ANSI N45.2.12 and maintained as required by ANSI

N45.2.9.Records requirements are addressed in Basic and Supplemental requirements (Section 17) of NQA-1-1994.

SUPPLEMENT 2S-4Supplementary Requirements for Personnel Indoctrination

and TrainingThis Supplement of NQA-1-1994 is met in conjunction with applicable

ANSI N18.1 and/or ANS-3.1 04/21/04Quality Assurance ProgramPage 25 of 26 CRITERION 2 ANSI N45.2-1977/N18.7-1976 BASIC REQUIREMENT 2 NQA-1 1994 COMMENTS standards.

1 GENERALThis Supplement provides amplified requirements for the indoctrination and training of personnel performing ormanaging activities affecting quality.It supplements the requirements of Basic Requirement 2 of

this Part (Part I) and shall be used in conjunction with that Basic Requirement when and to the extent specified by the

organization invoking this Part (Part I).

NQA-1, SUPPLEMENT 2S-4, describes indoctrination and training requirements that meet the intent of

those stated in ANSI N45.2.23.

2Property "ANSI code" (as page type) with input value "ANSI N45.2.23.</br></br>2" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. APPLICABILITYThis Supplement applies to personnel performing or managing activities affecting quality. Personnel to be

indoctrinated or trained shall be identified.

The extent of indoctrination and training shall be commensurate with the following:(a) the scope, complexity, and nature of the activity; and(b) the education, experience, and proficiency of the

person.Activities affecting quality include siting, designing, purchasing, fabricating, handling, shipping, receiving, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, modifying,and decommissioning.

3 INDOCTRINATION Personnel shall be indoctrinated in the following subjects as they relate to a particular function: (a) general criteria, including applicable codes, standards, and company procedures;(b) applicable quality assurance program elements; and(c) job responsibilities and authority.

4 TRAINING Training shall be provided, if needed, to:(a) achieve initial proficiency;(b) maintain proficiency; and(c) adapt to changes in technology, methods, or job

responsibilities.

5 RECORDSRecords of the implementation of indoctrination and 04/21/04Quality Assurance ProgramPage 26 of 26 CRITERION 2 ANSI N45.2-1977/N18.7-1976 BASIC REQUIREMENT 2 NQA-1 1994 COMMENTStraining may take the form of: (a) attendance sheets;(b) training logs; or (c) personnel training records.

04/28/04Design ControlPage 1 of 28 CRITERION 3 ANSI N45.2; N45.2.11; and N18.7 BASIC REQUIREMENT 3 NQA-1 1994 COMMENTS N45.2, § 4.1 General N45.2 Measures shall be established and documented toassure that the applicable specified design requirements, such as design bases, regulatory requirements, codes, and standards are correctly translated into specifications, drawings, procedures, or instructions.

The design shall be defined, controlled, and verified.

Applicable design inputs shall be appropriately specified on a timely basis and correctly translated into design documents.Similar requirements.

Design interfaces shall be identified and controlled.

Addressed in later parts of N45.2.11.Design adequacy shall be verified by persons other than those who designed the item.

Addressed in later parts of N45.2.11.

Design changes, including field changes, shall be governed by control measures commensurate with those applied to

the original design.

Addressed in later parts of N45.2.11.N45.2.11 § 2. Program Requirements

2.1 Establishment

and DocumentationA quality assurance program for design shall be established and documented to comply with the requirements of this Standard.The program documents shall define the organizational structure within which the program is to be implemented, and shall delineate the authority and responsibility of the

persons and organizations involved performing designactivities affecting the quality of design.The program documents shall identify the items and

services and the specific activities to which this standard is applied. The design responsibilities and interfaces among

the contributing organizations, both internal and external, should be identified.Provisions should be made in the program for periodic

audits, review, and evaluation of the effectiveness of the program in achieving quality objectives. Correction of deficiencies shall be an integral part of the program.This subsection is covered by NQA-1, Requirements 1 and

2 and is not repeated in criterion 3NQA-1 does not repeat information from other criteria as in the ANSI

standards.N45.2.11, § 2.2 Program ProceduresProcedures shall be employed to assure that design

activities are carried out in a planned, controlled, orderly and correct manner. Program procedures shall cover the

following as applicable:

1. Responsibilities of organizations involved in the program, such as owner, A-E, NSSS supplier and other NOTE: Program procedure requirements have been incorporated into multiple sections of NQA-1 and are not generally repeated for specific programs.

1. and 2. Responsibilities of organizations is addressed in Basic Requirement 1 and Supplement 1S-1.3. Interface control is addressed in Supplements 1S-1 and

3S-1.NQA-1 does not repeat information from other criteria as in the ANSI

standards. Additional standards and NRC Regulatory Guides also provide information on many of these program requirements.

04/28/04Design ControlPage 2 of 28 CRITERION 3 ANSI N45.2; N45.2.11; and N18.7 BASIC REQUIREMENT 3 NQA-1 1994 COMMENTS contractors.

2. Responsibilities within design organizations.3. Technical information ex changes across external and internal interfaces.4. Document control including review, approval, release, distribution, and revision.5. Maintenance and retention of design documents.6. Management review of status and adequacy of program.7. Necessary training of personnel performing activities covered by this standard.8. Identifying appropriate design input.9. Preparation of design documents.10. Specifying quality levels, acceptance standards, and record requirements.11. Performance of design verifications.

12. Conducting audits of design activities, their reporting

and follow-up.

13. Taking corrective action (see Section 9).

14. Making experience reports available to cognizant

design personnel.

15. Controlling design changes.16. Other procedures as required by this standard.4. Document control is addressed in Basic Requirement 6 and Supplement 6S-1.5. Maintenance of design documents is addressed under document control and retention is addressed in basic requirement 17 and Supplement 17S-1.6. Management review of the program is addressed under Basic Requirement 2.7. Training requirements are addressed in Basic Requirement 2.8. Design input is addressed in Basic Requirement 3 and Supplement 3S-1.9. Preparation of design documents is addressed in Basic Requirement 3 and Supplement 3S-1.10. Specifying quality levels is addressed in Basic Requirement 2. Specifying acceptance standards is addressed in Basic Requirements 3, 5, 10, and 11 with associated Supplements. Records requirements are addressed in Supplement 3S-1 and Basic Requirement 17 and Supplement 17S-1.11. Design verification is addressed in Supplement 3S-1.12. Audits is addressed in Basic Requirement 18 and Supplement 18S-1.13. Corrective Action is addressed in Basic Requirements 15 and 16 and their associated Supplements.

14. Experience reports (operating experience included) are not addressed to any significant degree in NQA-1 related

to design.15. Change control is addressed in Supplement 3S-1.16. Other procedures may be addressed throughout NQA-1 in addition to Supplement 3S-1.

N45.2.11, § 2.3 Factors ConsideredSome of the factors to be considered in establishing the program include:

1. Nature of the organization such as the plant owner, manufacturer, or architect-engineer, and the nature of the design interfaces among them.2. Importance of the design activity to plant safety.3. State of the art such as experimental, developmental, or These factors are generally addressed as principles

throughout the standards of NQA-1.A similar list of factors to consider is contained as nonmandatory guidance in Appendix 3A-1.Not requirements.

04/28/04Design ControlPage 3 of 28 CRITERION 3 ANSI N45.2; N45.2.11; and N18.7 BASIC REQUIREMENT 3 NQA-1 1994 COMMENTS standard design.4. Nature of design activity such as conceptual,preliminary, detailed design, or field engineering.

N45.2.11 § 1 Introduction

1.1 ScopeThis

standard provides requirements and guidance for a quality assurance program for the design of nuclear power plant structures, systems and components whose satisfactory and reliable performance is required:

1. To prevent accidents that could cause undue risk to the health and safety of the public; or2. To mitigate the consequences of such accidents if they

were to occur.

See NQA-1-1994, Part 1, Introduction , for Purpose andApplicability.

SUPPLEMENT 3S-1 SUPPLEMENTARY REQUIREMENTS FOR DESIGN CONTROL 1 GENERALThis Supplement provides amplified requirements for design control.

N45.2.11 § 1.1 - The requirements of this standard mayalso be extended to other structures, systems and components in whole or in part as specified by the

purchaser.

This standard covers activities which affect the final

design.This standard is intended to be used in conjunction with ANSI N45.2.It supplements the requirements of Basic Requirement 3 of

this Part and shall be used in conjunction with that Basic Requirement when and to the extent specified by the

organization invoking this Part.Similar statement regarding use to the extent specified by the purchaser (organization invoking this Part)

N45.2.11 § 1.2 Applicability This standard applies to the plant owner, nuclear steam supply system (NSSS) designer, architect engineer or plant

designer, and other organizati ons participating in designactivities affecting quality of items covered by this

standard. The extent to which the individual sections and elements of this standard are applied will depend upon

factors such as the nature and scope of the work to be performed and the importance of the structures, systems and components to safe plant operation.

The ASME Boiler and Pressure Vessel Code (Hereafter

referred to as the Code) as well as other ANSI Standards, See NQA-1-1994, Part 1, Introduction , for Applicabilityand Responsibility.Similar applicability established

between the standards.

04/28/04Design ControlPage 4 of 28 CRITERION 3 ANSI N45.2; N45.2.11; and N18.7 BASIC REQUIREMENT 3 NQA-1 1994 COMMENTShas been considered in the development of this standard, and this standard is intended to be compatible with theirrequirements.However, this standard does not apply to activities covered by Section III Division I and 2 and Section XI of the Code for those activities covered by the Code.

N45.2.11 § 1.3 ResponsibilityIt is the responsibility of the plant owner to provide for the establishment and execution of a quality assurance program for the plant design consistent with the provisions

of this standard. The plant owner may delegate to other organizations the work of establishing and executing the quality assurance program, or any part thereof, but shall retain responsibility for overall program effectiveness. It is the responsibility of the plant owner and other organizations invoking this standard to identify the structures, systems and components, and to specify the extent to which the provisions of this standard apply to such structures, systems and components. In no way shall the program operate to diminish the responsibility of any contractor for the quality of services furnished.

See NQA-1-1994, Part 1, Introduction , for Applicabilityand Responsibility.Similar responsibilities exist between

the standards.

N45.2.11 § 1.4 Definitions The following definitions are provided to assure a uniform understanding of select terms as they are used in this

standard.Note that the below definitions are copied from the

introduction to Part I of NQA-1.

Definitions are contained in NQA 1994, Part I, Introduction, § 4 Terms

and Definitions Design - Technical and management processes whichcommence with identification of design input and which

lead to and include the issuance of design output documents.

Design process - technical and management processes thatcommence with identification of design input and that lead to and include the issuance of design output documentsSimilar definition.

Design Input - Those criteria, parameters, bases or otherdesign requirements upon which detailed final design is

based.Design input - those criteria, parameters, bases, or otherdesign requirements upon which detailed final design is

basedSimilar definition.

Design Output - Documents such as drawings,specifications and other documents defining technical requirements of structures, systems and components as

delineated in Section 4.

Design output

- drawings, specifications, and otherdocuments used to define technical requirements of structures, systems, components, and computer programsSimilar definition.

External Design Interface - Relationship between designgroups from different companies. Examples are the Design interface is not defined in

NQA-1, but controls for interface are

04/28/04Design ControlPage 5 of 28 CRITERION 3 ANSI N45.2; N45.2.11; and N18.7 BASIC REQUIREMENT 3 NQA-1 1994 COMMENTS interfaces between the plant owner and the architect engineer or the plant owner and the NSSS supplier, or the

architect engineer and the NSSS supplier.described in Supplement 3S-1, § 6

Interface Control Final Design - Approved design output documents and approved changes thereto.

Design, final - approved design output documents and approved changes theretoSimilar definition.

Internal Design Interface - Relationship between designgroups or organizations within a company.

Design interface is not defined in

NQA-1, but controls for interface are described in Supplement 3S-1, § 6

Interface Control Procedures - A document that specifies or describes howan activity is to be performed. It may include methods to be employed, equipment or materials to be used and

sequence of operations.

Procedure - a document that specifies or describes how anactivity is to be performedSimilar definition.

Design change - any revision or alteration of the technicalrequirements defined by approved and issued design output documents and approved and issued changes theretoNew definition not previously in

N45.2.11.N45.2.11, § 1.5 Referenced DocumentsOther documents that are required to be included as part of

this standard will be identified at the point of reference and

described in Section 12 of this standard. The issue or edition of the referenced document that is required will be

specified either at the point of reference or in Section 12 of

this standard.

NRC Reg. Guide 1.64, Reg. Position C.1 indicates thatthe specific acceptability of these listed documents has been or will be covered separately in other regulatory guides or in Commission regulations where appropriate.Applicability of other standards and Regulatory Guides is addressed in

Appendix C of the new QAPD.

N45.2.11, § 3. Design Input Requirements 2 DESIGN INPUT

3.1 General

Applicable design inputs, such as design bases, regulatory requirements, codes and standards, shall be identified, documented and their selecti on reviewed and approved.

Applicable design inputs, such as design bases,performance requirements, regulatory requirements, codes, and standards, shall be identified and documented, andtheir selection reviewed and approved by the responsible

design organization.Similar requirement.The design input should be specified on a timely basis and to the level of detail necessary to permit the design activity to be carried out in a correct manner and to provide a consistent basis for making design decisions, accomplishing design verification measures, and The design input shall be specified and approved on a timely basis and to the level of detail necessary to permit the design activity to be carried out in a correct manner and to provide a consistent basis for making design decisions, accomplishing design verification measures, and Similar requirement.

04/28/04Design ControlPage 6 of 28 CRITERION 3 ANSI N45.2; N45.2.11; and N18.7 BASIC REQUIREMENT 3 NQA-1 1994 COMMENTS evaluating design changes.

evaluating design changes.

N45.2 Changes or deviations from specified designrequirements or quality standards shall be identified, documented, and controlled.

N45.2.11 §3.1, ¶ 1 - Changes from specified design inputs including the reasons for the changes shall be identified, approved, documented and controlled.Changes from approved design inputs, including the reason for the changes, shall be identified, approved, documented, and controlled.Similar requirement.N45.2.11 § 3.2 RequirementsThe design input shall include but is not limited to the

following, where applicable:1. Basic functions of each structure, system and component.2. Performance requirements such as capacity, rating, system output.3. Codes, standards, and regulatory requirements including

the applicable issue and/or addenda.4. Design conditions such as pressure, temperature, fluid chemistry and voltage.5. Loads such as seismic, wind, thermal and dynamic.6. Environmental conditions anticipated during storage, construction and operation such as pressure, temperature, humidity, corrosiveness, site elevation, wind direction, nuclear radiation, electromagne tic radiation and duration of exposure.7. Interface requirements including definition of the functional and physical interfaces involving structures, systems and components.8. Material requirements including such items as compatibility, electrical insulation properties, protective

coating and corrosion resistance.9. Mechanical requirements such as vibration, stress, shock

and reaction forces.10. Structural requirements covering such items as equipment foundations and pipe supports.11. Hydraulic requirements such as pump net positive suction heads (NPSH), allowable pressure drops, and

allowable fluid velocities.12. Chemistry requirements such as provisions for sampling and limitations on water chemistry.

The detailed list of design input requirements has been moved to (and expounded upon as nonmandatory

guidance in) NQA-1, Appendix 3A-1.

04/28/04Design ControlPage 7 of 28 CRITERION 3 ANSI N45.2; N45.2.11; and N18.7 BASIC REQUIREMENT 3 NQA-1 1994 COMMENTS13. Electrical requirements such as source of power,voltage, raceway requirements, electrical insulation and motor requirements.14. Layout and arrangement requirements.15. Operational requirement s under various conditions,such as plant startup, normal plant operation, plant shutdown, plant emergency, operation, special or infrequent operation, and system abnormal or emergency

operation.16. Instrumentation and control requirements including indicating instruments, controls and alarms required for operation, testing, and maintenance. Other requirements such as the type of instrument, installed spares, range of measurement, and location of indication should also be

included.17. Access and administrative control requirements for plant security.18. Redundancy, diversity and separation requirements ofstructures, systems and components.19. Failure effects requirements of structures, systems and components, including a definition of those events and accidents which they must be designed to withstand.20. Test requirements including in-plant tests and the conditions under which they will be performed.21. Accessibility, maintenance, repair and inservice inspection requirements for the plant including the conditions under which these will be performed.22. Personnel requirements and limitations including the qualification and number of pe rsonnel available for plantoperation, maintenance, testing and inspection and permissible personnel radiation exposures for specified

areas and conditions.23. Transportability requirements such as size and shipping weight, limitations, I.C.C. regulations.24. Fire protection or resistance requirements.25. Handling, storage and shipping requirements.26. Other requirements to prevent undue risk to the health and safety of the public.27. Materials, processes,. parts and equipment suitable for

04/28/04Design ControlPage 8 of 28 CRITERION 3 ANSI N45.2; N45.2.11; and N18.7 BASIC REQUIREMENT 3 NQA-1 1994 COMMENTS application.28. Safety requirements for preventing personnel injuryincluding such items as radiation hazards, restricting the use of dangerous materials, escape provisions from enclosures, and grounding of electrical systems.

N45.2.11, § 4. Design Process 3 DESIGN PROCESSDesign activities shall be prescribed and accomplished in

accordance with procedures of a type sufficient to assurethat applicable design inputs are correctly translated into

specifications, drawings, procedures or instructions.

N45.2.11 § 4.1, ¶ 2 - The design activities may be prescribed in job specifications, work-instructions, planning sheets, procedure manuals, test procedures, or any other type of written form, which provides adequate control and permits reviewing, checking or verifying the results of the activity, by personnel who are experienced in the subject activity.

The responsible design organization shall prescribe and document the design activities on a timely basis and to the level of detail necessary to permit the design process to be carried out in a correct manner, and to permit verification that the design meets requirements. Design documents

shall be adequate to support facility design, construction, and operation.Similar requirement.

ANSI N45.2 These measures shall include provisions toassure that appropriate quality standards are specified and included or referenced in design documents.

N45.2.11 § 4.1, ¶ 1 - Appropriate quality standards shallbe identified, documented and their selection reviewed and

approved.Appropriate quality standards shall be identified and documented, and their selec tion reviewed and approved.Similar requirement.

N45.2.11 § 4.1, ¶ 1 - Changes from specified quality standards including reasons for the changes shall be

identified, approved, documented and controlled.Changes from specified quality standards, including the reasons for the changes, shall be identified, approved, documented, and controlled.Similar requirement.

N45.2 Measures shall also be established for the selectionand review for suitability of application of materials, parts, equipment, and processes that are essential to the function of the structure, system, or component.Design methods, materials, parts, equipment, and processes that are essential to the function of the structure, system, or component shall be selected and reviewed for suitability of

application.Similar requirement.Applicable information derived from experience, as set forth in reports or other documentation, shall be made

available to cognizant design personnel.

Reference ANSI N45.2.11, § 2.2, Item

14 regarding experience.

04/28/04Design ControlPage 9 of 28 CRITERION 3 ANSI N45.2; N45.2.11; and N18.7 BASIC REQUIREMENT 3 NQA-1 1994 COMMENTS N45.2.11 § 4.1, ¶ 3 - Methods shall provide for relating the final design back to the source of design input. This traceability shall be documented in accordance with the requirements of Section 10.

N45.2.11 § 4.1, ¶ 4 - The design activities shall bedocumented in sufficient detail to permit verification and auditing as required by this standard.The final design (approved design output documents and

approved changes thereto) shall: (a) be relatable to the design input by documentation insufficient detail to permit design verification; and (b) identify assemblies and/or components that are part of the item being designed. When such an assembly or component part is a commercial grade item that, prior to its installation, is modified or selected by special inspection and/or testing to requirements that are more restrictive than the Supplier's published product description, the component part shall be represented as different from the commercial grade item in a manner traceable to a documented definition of the difference.Similar requirement.New information regarding assemblies and component parts.

N45.2.11, § 4.2, Design Analyses

3.1 Design

AnalysesDesign analyses such as physics, stress, thermal, hydraulic and accident, shall be performed in a planned, controlled and correct manner.Design analyses shall be performed in a planned, controlled, and documented manner. Similar requirement. Examples removed from NQA-1.

N45.2.11, § 4.2, ¶ 2 - Design analysis shall be legible andbe in a form suitable for reproduction, filing and retrieving.Design analysis documents shall be legible and in a form

suitable for reproduction, filing, and retrieval.Similar requirement.

N45.2 Design control measures shall provide for designanalyses, such as physics, stress, thermal, hydraulic, accident; compatibility of materials; accessibility for inservice inspection, maintenance, and repair; and

delineation of acceptance criteria for inspections and tests.

N45.2.11, § 4.2, ¶ 2 - Analyses shall be sufficientlydetailed as to purpose, method, assumptions, design input, references and units such that a person technically

qualified in the subject can review and understand theanalyses and verify the adequacy of the results without

recourse to the originator.They shall be sufficiently detailed as to purpose, method, assumptions, design input, references, and units such that a person technically qualified in the subject can review and understand the analyses and verify the adequacy of the

results without recourse to the originator.Similar requirement. Examples removed from NQA-1.

N45.2.11, § 4.2, ¶ 2 - Calculations shall be identified bysubject (including structure, system, or component to

which the calculation applies) originator, reviewer and date or by other data such that the calculations are retrievable.Calculations shall be identifiable by subject (including structure, system, or component to which the calculation applies), originator, reviewer, and date; or by other data

such that the calculations are retrievable.Similar requirement.(a) Computer programs may be utilized for design analysis without individual verification of the program for each

application provided:

NQA-1 provides additional controls on use of computer programs for design analyses.(1) the computer program has been verified to show that it

04/28/04Design ControlPage 10 of 28 CRITERION 3 ANSI N45.2; N45.2.11; and N18.7 BASIC REQUIREMENT 3 NQA-1 1994 COMMENTSproduces correct solutions for the encoded mathematicalmodel within defined limits for each parameter employed;

and(2) the encoded mathematical model has been shown to produce a valid solution to the physical problem associated

with the particular application.Computer programs shall becontrolled to assure that changes are documented and approved by authorized personnel.Where changes to previously verified computer programs are made, verification shall be required for the change, including evaluation of the effects of these changes on (1)

and (2) above.

N45.2.11, § 4.2, ¶ 2 - Procedures shall includerequirements for:1. Identifying documents to permit ready reference and

retrieval.2. Defining the objective of the analyses.

3. Definition of design inputs and their sources.4. Documenting the results of literature searches or other

applicable background data.5. Documenting assumptions, and identifying those assumptions that must be verified as the design proceeds.6. Identification of computer calculations, including computer type, code or programming, inputs and outputs.

7. Review and approval.(b) Documentation of design analyses shall include (1)

through (6) below: (1) definition of the objective of the analyses; (2) definition of design inputs and their sources; (3) results of literature searches or other applicable

background data;(4) identification of assumptions and indication of those that must be verified as the design proceeds;(5) identification of any computer calculation, including computer type, computer program (e.g., name), revision

identification, inputs, outputs, evidence of or reference to computer program verification, and the bases (or reference thereto) supporting application of the computer program to the specific physical problem; (6) review and approval.Similar requirement. For N45.2.11, item 1, the identification of documents

is addressed under NQA-1, Supplement 17S-1.

N45.2.11, § 4.3 DrawingsRequirements for control of documents (i.e. drawings) is addressed in Basic Requirement 6. Specific information regarding drawings is contained as non-mandatory guidance

in NQA-1, Appendix 3A-1, § 3(a).

04/28/04Design ControlPage 11 of 28 CRITERION 3 ANSI N45.2; N45.2.11; and N18.7 BASIC REQUIREMENT 3 NQA-1 1994 COMMENTS N45.2.11, § 4.4 SpecificationsRequirements for control ofdocuments (i.e. specifications) is addressed in Basic Requirement 6.

Specific information regarding

specifications is contained as non-mandatory guidance in NQA-1, Appendix 3A-1, § 3(b).N45.2.11, § 4.5 Other Design DocumentsRequirements for procedures is addressed in Basic Requirement 5.

Requirements for control of documents (i.e. drawings) is addressed in Basic Requirement 6. Specific information regarding other design documents is contained as non-mandatory guidance in NQA-1, Appendix 3A-1, § 3(b).

NQA-1, Appendix 3A-1, § 3(c) provides guidance on information that design documents should include to support facility operation.

N45.2 § 4.3 Design Verification N45.2.11 § 6. Design Verification 4 DESIGN VERIFICATION N45.2 Design control measures shall be applied to verifyor check the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program.

N45.2.11, § 6.1 GeneralMeasures shall be applied to verify the adequacy of design.

Design verification is the process of reviewing, confirming, or substantiating the design by one or more methods to provide assurance that the design meets the

specified design inputs.Design control measures shall be applied to verify the adequacy of design, such as by one or more of the following: the performance of design reviews, the use of alternate calculations, or the performance of qualification

tests.Similar requirement.Verification of computer programs shall include

appropriate testing.NQA-1-1994 Additional requirement to cover computer programs used in

design.N45.2 The responsible design organization shall identifythe particular design verification methods utilized.The responsible design organization shall identify and document the particular design verification method(s)

Similar requirement.

04/28/04Design ControlPage 12 of 28 CRITERION 3 ANSI N45.2; N45.2.11; and N18.7 BASIC REQUIREMENT 3 NQA-1 1994 COMMENTS used.The results of design verification shall be clearlydocumented with the identification of the verifier clearly

indicated.Additional requirement for NQA 1994.N45.2 The verifying or checking process shall beperformed by individuals or groups other than those who perform the original design but who may be from the same

organization.

N45.2.11, § 6.1, ¶ 2Design verification shall be performed by any competent individuals or groups other than those who performed the original design but who may be from the same

organization. Design verification shall be performed by any competent individual(s) or group(s) other than those who performed the original design but who may be from the same

organization.Similar requirement.

N45.2.11, § 6.1, ¶ 2This verification may be performed by the originator's supervisor provided the supervisor did not specify a

singular design approach, or rule out certain design

considerations and did not establish the design inputs used in the design, or if the supervisor is the only individual in the organization competent to perform the verification.

NRC Reg, Guide 1.64, Reg. Position C.2 states to replace the above sentence with the following: "The duties of a

'supervisor' and the relations hip with subordinates varieswidely in different organizations. Regardless of their title, individuals performing design verification should not (1) have immediate supervisory responsibility for the individual performing the design, (2) have specified a

singular design approach, (3) have ruled out certain design

considerations, or (4) have established the design inputs

for the particular design aspect being verified. While design verification by the designer's immediate supervisor

is encouraged, it should not be construed that such

verification constitutes the required independent design

verification, nor should the i ndependent design verificationbe construed to dilute or replace the clear responsibility of supervisors for the quality of work performed under their

supervision."

MPS QATR alternative states: "the Regulatory position This verification may be performed by the originator'ssupervisor, provided the supervisor did not specify a

singular design approach or rule out certain design

considerations and did not establish the design inputs used

in the design or, provided the supervisor is the only individual in the organization competent to perform the

verification.NQA-1 addresses the NRC statement and encompasses the MPS and VA

QATR alternatives.

NRC Reg. Guide 1.64 has been withdrawn with endorsement of

NQA-1 through Reg. Guide 1.28.

04/28/04Design ControlPage 13 of 28 CRITERION 3 ANSI N45.2; N45.2.11; and N18.7 BASIC REQUIREMENT 3 NQA-1 1994 COMMENTS states, in part, "It should not be construed that such verification constitutes the required independent design verification." The licensee has developed the following

alternative to allow for ad equate independent design verification: This review may be performed by the originator'sSupervisor, only if the Supervisor: Did not specify a singular design approach; Did not establish the design inputs or did not rule out certain Design considerations; Is the only individual in the organization competent toperform the review.Where the Supervisor performs the design review, the next level of management shall fulfill the Supervisor's

responsibilities.

VA QATR alternative states: "With regard to ParagraphC.2(1) of Regulatory Guide 1.64: If in an exceptional circumstance the designer's immediate Supervisor is the only technically qualified individual available, this review may be conducted by the Supe rvisor, providing that: (a)the other provisions of the Regulatory Guide are satisfied, and (b) the justification is individually documented and approved in advance by the Supervisor's management, and(c) Nuclear Oversight audits cover frequency and

effectiveness of use of Supervisors as design verifiers to

guard against abuse."

N45.2.11, § 6.1, ¶ 2Cursory supervisory reviews do not satisfy the intent of

this standard. Cursory supervisory reviews do not satisfy the intent of

this Part.Similar statement.

N45.2 The depth of review can range from a detailed checkof the complete design to a limited check of such things as

the design approach and the results obtained in the original

design.N45.2.11, § 6.1, ¶ 2Design verification may vary from spot checking of

calculations to actual tests in the field.Not a requirement.Verification shall be performed in a timely manner.Additional requirement.

Design verification, for the level of design activity Additional requirement.

04/28/04Design ControlPage 14 of 28 CRITERION 3 ANSI N45.2; N45.2.11; and N18.7 BASIC REQUIREMENT 3 NQA-1 1994 COMMENTSaccomplished, shall be performed prior to release forprocurement, manufacture, construction, or release to

another organization for use in other design activities except in those cases where this timing cannot be met, such

as when insufficient data exist. In those cases, the unverified portion of the design shall be identified and

controlled.In all cases the design verification shall be completed prior to relying upon the component, system, structure, or computer program to perform its function.Additional requirement.

N45.2.11, § 6.2 Extent

4.1 Extent

of Design Verification The extent of the design verification required is a function of the importance to safety of the item under consideration, the complexity of the design, the degree of standardization, the state-of-the-art, and the similarity with previously

proven designs.

The extent of the design verification required is a function of the importance to safety, the complexity of the design, the degree of standardization, the state of the art, and the similarity with previously proven designs.Similar requirement.

N45.2.11, § 6.2, ¶ 1Where the design of a particular structure, system, or component for a particular nuclear power plant has been

subjected to a verification process in accordance with this standard, the verification process need not be duplicated

for identical designs.

Where the design has been s ubjected to a verification process in accordance with th is Part, the verification process need not be duplicated for identical designs.Similar requirement.

N45.2 Regardless of the degree of standardization orsimilarity to previously proven designs, the applicability of standardized or previously proven designs with respect to meeting pertinent design requirements shall be verified for

each application.

N45.2.11, § 6.2, ¶ 1However, the applicability of standardized or previously proven designs, with respect to meeting pertinent design inputs, including environmental conditions, shall be

verified for each application.However, the applicability of standardized or previously proven designs, with respect to meeting pertinent design

inputs, shall be verified for each application.Similar requirement.

N45.2.11, § 6.2, ¶ 1However, known problems affecting the standardized

design and their effects on other features shall be

considered.Known problems affecting the standard or previously

proven designs and their effects on other features shall be

considered.Similar requirement.

N45.2.11, § 6.2, ¶ 1The original design and associated verification measures The original design and associated verification measures shall be adequately documented and referenced in the files Similar requirement.

04/28/04Design ControlPage 15 of 28 CRITERION 3 ANSI N45.2; N45.2.11; and N18.7 BASIC REQUIREMENT 3 NQA-1 1994 COMMENTS shall, however, be adequately documented and referenced in the files of subsequent application of the design.

of subsequent application of the design.

N45.2.11, § 6.2, ¶ 2Where changes to previously verified designs have been made, design verification shall be required for the changes, including evaluation of the effects of those changes on the

overall design.Where changes to previously verified designs have been made, design verification shall be required for the changes, including evaluation of the effects of those changes on the overall design and on any design analyses upon which the design is based that are affected by the change to previously verified design.Similar requirement, but added clarification to check impacts from a change on other design analyses.

N45.2.11, § 6.3 Methods

4.2 Methods

N45.2 Verifying or checking should consist of, as aminimum, reviewing the design, spot-checking the calculations or analyses, and assessing the results against

the original design bases and functional requirements.

N45.2.11, § 6.3, ¶ 1The responsible design organization shall identify anddocument the particular design verification methods to be used. Acceptable verification methods include but are not limited to:

1. Design reviews-

2. Alternate calculations-

3. Qualification testing-Acceptable verification methods include, but are not limited to, any one or a combination of the following:

design reviews, alternate calculations, and qualification

testing.Similar requirement.

N45.2.11, § 6.3.1 Design Reviews

4.2.1 Design

Reviews.

N45.2 There are many ways of performing design reviews, and various depths of reviews may be required dependingupon the importance and complexity of the design being

reviewed, the degree of standardization, the state-of-the-art, and the similarity with previously proven designs.

N45.2 The methods for design review can range from aformalized, multi-organization review to an informal, single-person review.

N45.2.11, § 6.3.1, ¶ 1 Design reviews are critical reviews to provide assurance that design documents such as drawings, calculations, analyses or specifications are correct and satisfactory.

Design reviews can range from multi-organization reviews

to single-person reviews. The depth of review can range from a detailed check of the complete design to a limited

check of such things as the design approach and the results These are critical reviews to provide assurance that thefinal design is correct and satisfactory.Not a requirement.

04/28/04Design ControlPage 16 of 28 CRITERION 3 ANSI N45.2; N45.2.11; and N18.7 BASIC REQUIREMENT 3 NQA-1 1994 COMMENTSobtained. The results of the review shall be documentedand measures taken to ensure that the findings are implemented. Whether the review is conducted by one individual or a multi-organization there are a number of

basic questions that shall be addressed such as:

N45.2.11, § 6.3.1 - Lists the following 19 items to consider in the design review.

Where applicable, (a) through (f) below shall be addressed.Similar requirement.1. Were the inputs correctly selected and incorporated into

design? (See paragraph 3.2).(a) Were the design inputs correctly selected? Similar requirement.2. Are assumptions necessary to perform the design activity adequately described and reasonable, where necessary, are the assumptions identified for subsequent

re-verifications when the detailed design activities are completed?(b) Are assumptions necessary to perform the design activity adequately described and reasonable? Where necessary, are the assumptions identified for

subsequent reverifications when the detailed design activities are completed?Similar requirement.7. Was an appropriate design method used?(c) Was an appropriate design method used?Similar requirement.3. Are the appropriate quality and quality assurance requirements specified?

4. Are the applicable codes, standards and regulatory requirements including issue and addenda properly identified and are their requirements for design met?

5. Have applicable constr uction and operating experience been considered?9. Are the specified parts, equipment, and processes

suitable for the required application?10. Are the specified materials compatible with each other and the design environmental conditions to which the material will be exposed?

11. Have adequate Maintenance features and requirements been specified?12. Are accessibility and other design provisions adequate for performance of needed maintenance and repair?13. Has adequate accessibility been provided to perform

the in-service inspection expected to be required during the

plant life?14. Has the design properly, considered radiation exposure

to the public and plant personnel?

15. Are the acceptance criteria incorporated in the design (d) Were the design inputs correctly incorporated into the design?Multiple questions in N45.2.11 related

to incorporating design inputs into the design combined into one question on

design inputs for NQA-1-1994.

04/28/04Design ControlPage 17 of 28 CRITERION 3 ANSI N45.2; N45.2.11; and N18.7 BASIC REQUIREMENT 3 NQA-1 1994 COMMENTSdocuments sufficient to allow verification that designrequirements have been satisfactorily accomplished?

16. Have adequate preoperati onal and subsequent periodictest requirements been appropriately specified?

17. Are adequate handling, storage, cleaning and shipping requirements specified?8. Is the output reasonable compared to inputs?(e) Is the design output reasonable compared to design

inputs?Similar requirement.6. Have the design interface requirements been satisfied?(f) Are the necessary design input and verification requirements for interfacing organizations specified in the design documents or in supporting procedures or

instructions?Similar requirement.18. Are adequate identification requirements specified?19. Are requirements for record preparation review, approval, retention, etc., adequately specified?N45.2.11 identifies these two items

regarding design reviews. These are

covered in NQA-1 under Requirements 8 and 17 along with associated Supplements.

N45.2.11, § 6.3.2 Alternate Calculations

4.2.2 Alternate

CalculationsVerification of some types of calculations or analyses may be achieved by comparison with alternate methods of calculation or analyses. This shall be performed by a person or persons other than those who performed the

original calculation. Where alternate calculations are performed to verify the correctness of the original calculation a review shall also be performed to address the appropriateness of assumptions, input data, and the code orother calculation method used. The alternate method used for comparison may be a more simplified approach or less

rigorous, such as when a hand calculation is used to check the computer code output. Although the simplified or less rigorous method may not exactly check the original calculation or analysis, it must provide results consistent with the original calculation or analyses.These are calculations or analyses that are made with alternate methods to verify correctness of the original calculations or analyses. The appropriateness of assumptions, input data used, and the computer program or other calculation method used shall also be reviewed.Similar requirement.

N45.2.11, § 6.3.3 Qualification Testing

4.2.3 Qualification

Tests N45.2.11, § 6.3.3, ¶ 1 Design verification for some designsor specific design features can be achieved by suitable qualification testing of a prototype or initial production

unit.Not a requirement.

04/28/04Design ControlPage 18 of 28 CRITERION 3 ANSI N45.2; N45.2.11; and N18.7 BASIC REQUIREMENT 3 NQA-1 1994 COMMENTS N45.2 In those cases where the adequacy of a design is tobe verified by tests, the testing shall be identified.

N45.2.11, § 6.3.3, ¶ 2 In those cases where the adequacyof a design is to be verified by a qualification test, the testing shall be identified and documented.Where design adequacy is to be verified by qualification

tests, the tests shall be identified. The test configuration shall be clearly defined and documented.Similar requirement.

N45.2 Testing shall demonstrate adequacy of performanceunder the most adverse design conditions.

N45.2.11, § 6.3.3, ¶ 2 Testing shall demonstrate adequacyof performance under the most adverse design conditions.Testing shall demonstrate adequacy of performance under conditions that simulate the most adverse design

conditions.Similar requirement.

N45.2 Operating modes and environmental conditions inwhich the item must perform satisfactorily shall be considered in determining the most adverse conditions.

N45.2.11, § 6.3.3, ¶ 2 All pertinent operating modes shallbe considered in determining these design conditions where it is intended that the test program confirm the adequacy of the overall design.Operating modes and environmental conditions in which the item must perform satisfactorily shall be considered in determining the most adverse conditions.Similar requirement.

N45.2.11, § 6.3.3, ¶ 2 Where the test is only intended toverify a specific design feature, the other features of the design shall be verified by other means. For example, it may be most effective to verify that an instrumentation cabinet is designed to withstand the maximum earthquake-caused vibratory motions by actually subjecting the cabinet and its associated components to shaker tests which correspond to these vibratory motions. The shaker tests will not, however, verify that the circuitry is designed correctly, or that the component in the cabinet will perform its intended function. Other tests or verification means are required to confirm that remaining design functions are adequately performed by the instrumentation and that those components perform the intended functions for the varying design conditions to which they are subjected.Where the test is intended to verify only specific design

features, the other features of the design shall be verified by other means.Similar requirement. Example from N45.2.11 is eliminated in NQA-1.

N45.2.1, § 6.3.3, ¶ 3 Qualification testing shall beperformed in accordance with written test procedures which incorporate or reference the requirements and acceptance limits contained in applicable design documents. The test procedures shall include provisions

for assuring that prerequisites for the given test have been met, that adequate instrumentation of the required range Test results shall be documented and evaluated by the

responsible design organization to assure that test requirements have been met.Similar requirement for documenting

and evaluating test results.

Requirements for conduct of tests are addressed in NQA-1, Requirement 11.

04/28/04Design ControlPage 19 of 28 CRITERION 3 ANSI N45.2; N45.2.11; and N18.7 BASIC REQUIREMENT 3 NQA-1 1994 COMMENTSand accuracy is available and used, and that necessarymonitoring is performed. Prerequisites include such items as calibrated instrumentation, appropriate equipment, trained personnel, condition of test equipment and the itemto be tested, suitable environmental conditions and

provisions for data acquisition. Test results shall be documented and evaluated by the responsible designer toassure that test requirements have been satisfied.

N45.2 If testing indicates that modifications to the itemare necessary to obtain acceptable performance, the item shall be modified and retested as necessary to assure satisfactory performance.

N45.2.1, § 6.3.3, ¶ 4 If testing indicates that modificationsto the item are necessary to obtain acceptable performance, the modification shall be documented and the item modified and retested or otherwise verified to assure satisfactory performance. If qualification testing indicates that modifications to the item are necessary to obtain acceptable performance, the modification shall be documented and the item modified

and retested or otherwise verified to assure satisfactory performance.Similar requirement.

N45.2.1, § 6.3.3, ¶ 4 When tests are being performed onmodels or mock-ups, scaling laws shall be established and verified. The test configuration shall be clearly defined and documented. When tests are being performed on models or mockups, scaling laws shall be established and verified.Similar requirement.

N45.2.1, § 6.3.3, ¶ 4 The results of model test work shallbe subject to error analysis, where applicable, prior to use

in final design work.The results of model test work shall be subject to error analysis, where applicable, prior to use in final design

work.Similar requirement.

N45.2, § 4. Change Control N45.2.11, § 8. Design Change Control 5 CHANGE CONTROL N45.2 Design changes, including field changes, shall begoverned by design control measures commensurate with

those applied to the original design.

N18.7, 5.2.7.2 Modifications. Design activities associatedwith modifications of safety-related structures, systems, and components shall be accomplished in accordance with N45.2.11-1974.[9]

N45.2.11, § 8, ¶ 1 Documented procedures shall be provided for design changes to approved design documents, including field changes, which assure that the impact of the change is carefully considered, required actions documented and information concerning the Changes to final designs, field changes, modifications to operating facilities, and nonconforming items

dispositioned use-as-is or repa ir shall be justified andsubject to design control measures commensurate with

those applied to the original design.Similar requirement.

04/28/04Design ControlPage 20 of 28 CRITERION 3 ANSI N45.2; N45.2.11; and N18.7 BASIC REQUIREMENT 3 NQA-1 1994 COMMENTSchange is transmitted to all affected persons and organizations. These changes shall be justified and subjected to design control measures commensurate with

those applied to the original design.

N45.2.11, § 8.1 Reasons for ChangesDesign changes frequently result from such things as the

following:

1. Qualification, preoperational, or operational test results are not satisfactory.2. Interference problems di scovered during construction.3. Failures of structures, systems, or components to meetfunctional requirements.4. Disposition of nonconforming item s.5. Changes in regulatory or other requirements.

6. Operational experience.7. Design improvemen t.Examples not stated in NQA-1 N45.2, §4 It is the intent of this standard that design changes be reviewed and approved by the organizationsthat performed the original design, review, and approval.

In the event that it is not practical for the original organizations to perform the required review or approval, other responsible design organizations may be designated, provided the designated organizations have access to pertinent background information, have demonstrated competence in the specific design area of interest, and have

adequate understanding of the requirements and intent of the original design.

N45.2.11, § 8.2 Review of ChangesNormally, the procedures for effecting design changes shall require that the documents which reflect the design

change be reviewed and approved by the same groups or organizations which reviewed and approved the originaldesign documents. Where an organization which originally

was responsible for approving a particular design document is no longer responsible, the plant owner shall

designate the new responsible organization which may be the owner's own engineering organization. The designated

organization shall have access to pertinent background information, have demonstrated competence in the specificThese measures shall include assurance that the designanalyses for the structure, system. Changes shall beapproved by the same affected groups or organizations

which reviewed and approved the original design documents; except where an organization which originally

was responsible for approving a particular design document is no longer responsible, then the Owner or his

designee shall designate a new responsible organization

which could be the Owner's engineering organization, orcomponent are still valid.Similar requirement.

04/28/04Design ControlPage 21 of 28 CRITERION 3 ANSI N45.2; N45.2.11; and N18.7 BASIC REQUIREMENT 3 NQA-1 1994 COMMENTS design area of interest and ha ve an adequate understandingof the requirements and intent of the original design.When a design change is approved other than by revision to the affected design documents, measures shall be established to incorporate the change into these documents, where such incorporation is appropriate.Additional requirement.

N45.2.11, § 9.2 Review of ProcedureWhere a significant design change is necessary because of

an incorrect design the design process and verification procedure shall be reviewed and modified as necessary.Where a significant design change is necessary because of

an incorrect design, the design process and verification procedure shall be reviewed and modified as necessary.Similar requirement.

N45.2, § 4.2 Interface Control N45.2.11, § 5. Interface Control 6 INTERFACE CONTROL N45.2 Design control measures shall be applied asnecessary to identify and control design interfaces and for coordination among participa ting design organizations.

N45.2.11, § 5.1 External

5.1.1 Identification

of Interface. The external interfacesbetween organizations performing work affecting quality

of design shall be identified in writing and shall include

those organizations providing criteria, designs, specifications and technical direction.

N45.2.11, § 5.2 Internal

5.2.1 Identification

of Interface. Each organization performing work affecting quality of design shall identify in writing its internal design interfaces for managing the flow of design information between organizational units.

Design interfaces shall be identified and controlled and the

design efforts shall be coordinated among the participating organizations.Similar requirement.

N45.2 These measures shall include the establishment ofprocedures among participating design organizations for

the review, approval, release, distribution, and revision of documents involving design interfaces.

N45.2.11, § 5.1 External 5.1.2 Responsibilities. Responsibilities for organizations shall be defined and documen ted in sufficient detail to cover the preparation, review and approval of documentsinvolving design interfaces. Responsibilities may be set forth in tabular form or flow charts accompanied by appropriate text to clarify the intent. Appendices A and BInterface controls shall include the assignment of responsibility and the establishment of procedures among

participating design organizati ons for the review, approval,release, distribution, and revision of documents involving

design interfaces.Similar requirement.

04/28/04Design ControlPage 22 of 28 CRITERION 3 ANSI N45.2; N45.2.11; and N18.7 BASIC REQUIREMENT 3 NQA-1 1994 COMMENTSprovide examples.

N45.2.11, § 5.2 Internal 5.2.2 Responsibilities. Responsibilities for each organizational unit shall be defined and documented in sufficient detail to cover the preparation, review, approval, distribution and revision of documents involving design

interfaces.

N45.2.11, § 5.1 External5.1.3 Lines of Communication. Systematic methods shall be established for communicating needed design information across external design interfaces, including changes to the design information as work progresses.

Documents shall identify the positions and titles of key personnel in the communication channels and their responsibilities for decision-making, for resolution of problems, for providing and reviewing information, and

for taking other action within the scope of this standard.5.1.4 Documentation. Procedures shall be established tocontrol the flow of design information between organizations. Design information transmitted from one organization to another shall be documented in specifications, drawings or other controlled documents which are uniquely identified and issued by authorized

persons. The procedures shall provide that design interface information be transmitted to affected organizations and that any information requested in the design interface transmittal be transmitted back to the originator.

Documentation requesting information or action shall be controlled by a system which assures that the response and the request can be related. Where it is necessary to initially transmit design information orally or by other informal means, the transmittal shall be confirmed promptly by a controlled document.

N45.2.11, § 5.2 Internal5.2.3 Lines of Communication. Systematic methods shall be established for communicating needed design information across the internal design interfaces, including changes to the design information as work progresses.5.2.4 Documentation. Procedures shall be established toDesign information transmitted across interfaces shall be documented and controlled. Transmittals shall identify the status of the design information or document provided and, where necessary, identify incomplete items which require

further evaluation, review, or approval. Where it is necessary to initially transmit design information orally or by other informal means, the transmittal shall be confirmed promptly by a controlled document.Similar requirement. NQA-1-1994 added detail on informal communication.

04/28/04Design ControlPage 23 of 28 CRITERION 3 ANSI N45.2; N45.2.11; and N18.7 BASIC REQUIREMENT 3 NQA-1 1994 COMMENTScontrol the flow of design information betweenorganizational units. Design information transmitted from one organizational unit to another shall be documented andcontrolled. Transmittals shall identify, the status of the design information or document provided and, where necessary, identify incomplete items which require further evaluation, review or approval. Where it is necessary to initially transmit design information orally or by other informal means, the transmittal shall be confirmed promptly by a controlled document.N45.2.11, § 7 Document Control 7 DOCUMENTATION AND RECORDS N45.2 Records of implementation of these design controlmeasures shall be available for review.

N45.2.11, §6.1, ¶ 3 The results of design verification efforts shall be clearlydocumented, with the identification of the verifier clearly

indicated thereon, and filed.N45.2.11, § 7 Document ControlDocumented procedures shall be used to control issuanceof design documents and changes thereto. These procedures shall assure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel and are properly distributed.Design documentation and records, which provide

evidence that the design and design verification processes were performed in accordance with the requirements of this Part (Part 1), shall be collected, stored, and maintained in accordance with documented procedures.Similar requirement.

N45.2.11, §6.1, ¶ 3 Documentation of results shall be auditable against theverification methods identified by the responsible design

organization.

N45.2.11, § 10, ¶ 2 The documentation shall include notonly the final design documents such as drawings and

specifications, and revisions thereto but also records of the important steps including sources of design inputs, which

support the final design. The records shall be legible, identifiable and retrievable.The documentation shall include not only final design documents, such as drawings and specifications, and revisions thereto but also documentation which identifies the important steps, including sources of design inputs that

support the final design.Similar requirement.

7.1 Document

Preparation, Approval and IssuePersonnel shall be made aware of and use proper and

current instructions, procedures, drawings and design

inputs. Participating organizations shall have documentedprocedures for control of design documents and changesDocument Control requirements for NQA-1 are addressed in Requirement 6 and Supplement 6S-1, rather than

repeated under design control.

04/28/04Design ControlPage 24 of 28 CRITERION 3 ANSI N45.2; N45.2.11; and N18.7 BASIC REQUIREMENT 3 NQA-1 1994 COMMENTSthereto to assure that current and appropriate documentsare available for use. The document control procedures shall provide for:

1. Identification of personne l positions or organizations responsible for preparing, reviewing, approving ,andissuing documents and revisions thereto. This identification may take the form of Project General Instructions, design organization Policy Statements, a matrix showing document type against function, or otherwritten forms appropriate to the organizational method of performing the design process.2. Identification of the proper documents to be used in performing the design. The identification should include title applicable revisions, date of issue or any other relevant information that would precisely identify the document to be used.

3. Coordination and control of design (internal and external) interface documents. These interface documents should be mutually agreed to and prepared in sufficient

detail to assure that the requi red reviews and approvals areaccomplished.4. Ascertaining that proper documents are accessible and are in fact being used. This might be accomplished by several schemes including the following examples:

periodic issuance of master drawing or specification lists

showing the latest applicable revision (such lists couldprovide a reference for auditing the accessibility and use of the latest documents); or some type of receipting system can provide assurance that the latest documents have been received and obsolete revisions recalled. An example of such a receipting system is Appendix C, Drawing Issue

Check List.

5. Establishing distribution lists which are updated andmaintained current to assure that the proper personnel are sent all the required documents to perform the work. ANSI

N45.2.117.2 Document RevisionSignificant changes to documents shall be reviewed and approved by the same organizations that performed the 04/28/04Design ControlPage 25 of 28 CRITERION 3 ANSI N45.2; N45.2.11; and N18.7 BASIC REQUIREMENT 3 NQA-1 1994 COMMENTS original review and approval unless other organizations arespecifically designated. The reviewing organizations shallhave access to pertinent background data information upon which to base their approval. However, minor changes to design documents, such as inconsequential editorial corrections or changes to commercial terms and conditions, may not require that the revised document receive the same review and approval as the original documents. To avoid a possible omission of a required review, the type of minor

changes which do not require such a review and approval

and the persons who can authorize such a decision shall be clearly delineated in the document control procedures.

N45.2.11, § 9. Corrective ActionIn addition to correcting a deficiency (or error), corrective

action also includes, for significant or recurring deficiencies (or errors), determining the cause and

instituting appropriate changes in the design process and the quality assurance program to prevent similar types of deficiencies (or errors) from recurring. A procedure shall be employed for providing such corrective action. This

procedure shall also contain provisions for reporting the deficiency and corrective acti on to appropriate levels ofsupervision and management. The procedure shall also include follo w-up actions that cannot be immediatelycompleted to assure timely resolution and/or completion of

the corrective action.

9.1 Detection

of Errors Deficiencies or error in the design or the design quality assurance program may, be detected by:1. Design verification measures.2. Personnel using the design documents.

3. Audits.

4. Tests conducted.

5. Actual failure during operation.6. Other means.

NQA-1 Corrective Action requirements are identified in Basic Requirements 15 and 16 and any associated Supplements.

N45.2.11, § 10 RecordsDesign documentation and records which provide evidence that the design and review process was performed in accordance with the requirements of this standard shall beNQA-1 identifies most records requirements in Basic Requirement 17 and Supplement 17S-1 and doesn't repeat the information in other 04/28/04Design ControlPage 26 of 28 CRITERION 3 ANSI N45.2; N45.2.11; and N18.7 BASIC REQUIREMENT 3 NQA-1 1994 COMMENTScollected, stored and mainta ined in accordance with therequirements of ANSI N45.2.9.

-Documentation and records will be either of the lifetime ornonpermanent category as defined in ANSI N45.2.9.

sections.N45.2.11, § 11. AuditsA comprehensive system of planned and documented audits shall be carried out to verify compliance with all aspects of the Quality Assurance program for design including those procedures delineating quality assurance

actions required during the design process.

11.1 Personnel These audits shall be perform ed in accordance with writtenprocedures or checklist by personnel not having direct responsibilities in the areas being audited. For example, the person who performs an audit on design verification should not have been responsible for performing the design

verification. The personnel performing audits shall be of alevel of competency and have sufficient authority and organizational freedom to make the audit process meaningful and effective.

11.2 Internal AuditsDesign organizations performing work in accordance with the requirements of this standard shall be audited to assure that their design quality assurance programs are being implemented. Audits may be conducted internally by thedesign organization or by a unit independent of the design

organization.

11.3 External Audits Organizations shall conduct or delegate the conduct ofexternal audits of design organizations performing work for them to assure that specified design quality assurance program requirements are being implemented and are

effective.

11.4 Audit Control Audits shall include an evaluation of design quality

assurance policies, practices, procedures and instructions; the effectiveness of implementation; and actions taken toNQA-1 Audit requirements are contained in Basic Requirements 2 and 18 and associated Supplements.

04/28/04Design ControlPage 27 of 28 CRITERION 3 ANSI N45.2; N45.2.11; and N18.7 BASIC REQUIREMENT 3 NQA-1 1994 COMMENTScorrect deficiencies in the program. The audits shouldinclude the examination of design activities, processes anddocuments and records. An aud it plan shall be developedand should identify the functional areas to be audited, the extent of audit within these areas to determine effectiveness, the names and assignments of those who will perform the audit, the scheduling arrangements and the methods of reporting findings and recommendations.

11.5 Audit Schedule Audits should be conducted on a routine basis to establish the adequacy of and conformance to the design quality assurance requirements. Audits should also be conducted when one or more of the following conditions exists:1. When it is necessary to determine the capability of a subcontractor's quality assurance program prior to

awarding of contract of purchase order for design services.2. When, after award of contract, sufficient time has elapsed for the implementation of the quality assurance program for design and it is appropriate to determine that the organization is performing the functions as defined in the quality assurance program description, codes, standards and other contract documents.3. When significant changes are made in functional areas of the quality assurance program for design including

significant reorganizations and procedure revisions.4. When it is suspected that safety related performance of the item is in jeopardy due to deficiencies and nonconformances in the quality assurance program.5. When a systematic, independent assessment of program effectiveness or item quality or both is considered necessary. 6. When it is considered necessary to verify implementation of required corrective actions.

11.6 ResultsAudit results shall be documented and reviewed by management having responsibility in the areas audited.

Audit reports shall be in sufficient detail to permit management evaluation of the breadth of the audit as well as the validity of the findings.

04/28/04Design ControlPage 28 of 28 CRITERION 3 ANSI N45.2; N45.2.11; and N18.7 BASIC REQUIREMENT 3 NQA-1 1994 COMMENTS 11.7 Follow-UpAppropriate corrective action and timely follow-up action, including re-audit of deficient areas, shall be taken where indicated by the audit findings.

04/28/04 Procurement Document ControlPage 1 of 8 CRITERION 4 ANSI N45.2 § 5, N45.2.13 § 3, N18.7 § 5.2.13.1 BASIC REQUIREMENT 4 NQA-1 1994 COMMENTS N45.2 Measures shall be established and documented toassure that applicable regulatory requirements, design bases, and other requirements which are necessary to assure adequate quality are included or referenced in the documents for procurement of items and services.

N45.2.13 § 3.1 The Purchaser shall establish measures toassure that applicable regulatory requirements, design bases, and other requirements (including specific issue dates and applicable addenda) which are necessary to assure adequate quality are included or invoked by reference in the documents for procurement of items and

services.N18.7 § 5.2.13 Procurement and Materials Control.¶ 1 Measures shall be provided for procurement, documentation and control of those materials and components including spare and replacement parts necessary for plant operation, refueling, maintenance and modification. These measures shall utilize American National Standard Quality Assurance Requirements for the Control of Procurement of Items and Services for Nuclear

Power Plants, N45.2.13-1976. Procedures shall be established and implemented to ensure that purchased materials and components associated with safety-related structures or systems are:

(1) Purchased to specifications and codes equivalent to those specified for the original equipment, or those specified by a properly reviewed and approved revision.

(In those cases where the original item or part is found to be commercially "off the shelf," or without specifically identified quality assurance requirements, spare and replacement parts may be similarly procured but care shall be exercised to assure at least equivalent performance. In those cases where the QA requirements of the original item cannot be determined, an engineering evaluation shall be conducted by qualified indi viduals to establish therequirements and controls. This evaluation shall assure that interfaces, interchangeability, safety, fit and function are not adversely affected or contrary to applicable regulatory or code requirements. The results of this evaluation shall Applicable design bases and other requirements necessary to assure adequate quality sha ll be included or referencedin documents for procurement of items and services. Similar requirements.ANSI N18.7 contains more detail on the applicability of the measures and

the need for procedures to control the procurement process. These are covered in a more general sense in the

Introduction section of NQA-1, Part I.

ANSI N18.7 invokes the use of ANSI N45.2.13 requirements related to Procurement Document Control (Section 3 of that standard). The applicable requirements have been included in NQA-1, Supplement 4S-1.This has been acknowledged by the

NRC through the withdrawal of the Regulatory Guide (1.123) that

endorsed ANSI N45.2.13 where licensees are committing to NQA-1.

04/28/04 Procurement Document ControlPage 2 of 8 CRITERION 4 ANSI N45.2 § 5, N45.2.13 § 3, N18.7 § 5.2.13.1 BASIC REQUIREMENT 4 NQA-1 1994 COMMENTSbe documented)

N18.7 § 5.2.13.1 Procurement Document Control.

Measures shall be provided to assure that applicable regulatory requirements, design bases and other requirements which are necessary to assure adequate quality are included or referenced in the procedures for procurement of items and services.

N45.2 To the extent necessary, procurement documentsshall require contractors to provide a Quality Assurance Program consistent with the pertinent requirements of this

standard.

N18.7 5.2.13.1 To the extent necessary, procurementdocuments shall require s uppliers to provide a qualityassurance program consistent with the pertinent requirements of American National Standard Quality Assurance Program Requirements for Nuclear Power Plants, N45.2-1971. [2]To the extent necessary, procurement documents shall require Suppliers to have a quality assurance program

consistent with the applicable requirements of this Part (Part1).Similar requirement.

SUPPLEMENT 4S-1 SUPPLEMENTARY REQUIREMENTS FOR PROCUREMENT DOCUMENT CONTROL 1 GENERALThis Supplement provides amplified requirements forprocurement document control.It supplements the requirements of Basic Requirement 4 of

this Part (Part1) and shall be used in conjunction with that Basic Requirement when and to the extent specified by the

organization invoking this Part (Part1).

2 CONTENT OF THE PROCUREMENT DOCUMENTS N45.2 Procurement documents shall include provisions for the following, as applicable:

N45.2.13 § 3.2 Content of the Procurement Documents - Procurement documents issued at all tiers of procurementshall include provisions for the following, as deemed necessaryby the Purchaser:Procurement documents issued at all tiers of procurement shall include provisions for the following, as deemed necessary by the Purchaser.Similar requirement.

N45.2.13 § 3.2.1 Scope of Work.

2.1 Scope

of Work N45.2.13 § 3.2.1 A statement of the scope of the work tobe performed by the Supplier shall be in the procurement A statement of the scope of the work to be performed by the Supplier shall be in the procurement documents.Similar requirement.

04/28/04 Procurement Document ControlPage 3 of 8 CRITERION 4 ANSI N45.2 § 5, N45.2.13 § 3, N18.7 § 5.2.13.1 BASIC REQUIREMENT 4 NQA-1 1994 COMMENTSdocuments.

ANSI N45.2, (2) Basic Technical Requirements

2.2 Technical

Requirements ANSI N45.2 Drawings, specifications, codes and industrial standards with applicable revision data, test and inspection requirements, and special instructions and requirements, such as for designing, fabricating, cleaning, erecting, packaging, handling, shipping, and, if applicable, extended storage in the field; and for test equipment.

N45.2.13 § 3.2.2 Technical Requirements. Technicalrequirements shall be specified in the procurement documents by reference to the specific drawings, specifications, codes, regulations, procedures or

instructions including revisions thereto that describe the items or services to be furnished. The procurement documents shall identify or provide for later identification of test, inspection and acceptance requirements, and any special instructions and requirements for such activities as

designing, identification, fabrication, cleaning, erecting, packaging, handling, shipping and extended storage. All such technical requirement documents shall be prepared, reviewed and released under the requirements established by ANSI N45.2.11.

N18.7 § 5.2.13.1, ¶ 2 Procurement documents shall include provisions for the following, as applicable: (2) Basic Technical Requirements. Where specific technical requirements apply, such as drawings, specifications, and

industrial codes and standards, they shall be identified bytitles and dates of issue in such a way as to clearly set forth the applicable documents. Where procedural requirements apply, in such areas as test and inspection needs, fabrication, cleaning, erecting, packaging, handling, shipping and storage, they too, shall be identified clearly and in such a way as to avoid uncertainty as to source and

need.Technical requirements shall be specified in the procurement documents. Where necessary, these requirements shall be specified by reference to specific

drawings, specifications, codes, standards, regulations, procedures, or instructions, including revisions thereto that describe the items or services to be furnished. The procurement documents shall provide for identification of test, inspection, and acceptance requirements of the Purchaser for monitoring and evaluating the Supplier's performance.Similar requirement.

N45.2 (1) Supplier Quality Assurance Program

2.3 Quality

Assurance Program Requirements N45.2 (1) Identification of quality assurance requirementsand the elements of the program applicable to the items or services procured. This may be accomplished in various ways, such as the following: (a) invoking this standard by Procurement documents shall require that the Supplier have a documented quality assurance program that implements portions or all of the requirements of this Part (Part1).Similar requirement.

The appendix referred to in N45.2.13

was not considered a part of the

standard. The guidance in the

04/28/04 Procurement Document ControlPage 4 of 8 CRITERION 4 ANSI N45.2 § 5, N45.2.13 § 3, N18.7 § 5.2.13.1 BASIC REQUIREMENT 4 NQA-1 1994 COMMENTSreference, or (b) invoking applicable sections or elementsof this standard, or (c) invoking other specific requirements which meet the intent of this standard.

N45.2.13 § 3.2.3 Quality Assurance ProgramRequirements. Procurement documents shall require that the Supplier have a documented quality assurance program that implements portions or all of ANSI N45.2 as well as applicable quality assurance program requirements of other nationally recognized codes a nd standards. (The Appendixprovides an explanation and examples of logic and considerations which may be used to decide how and towhat extent quality assurance program requirements shall be specified in procurement documents. The Appendix is

not a part of this standard.)

N18.7 § 5.2.13.1, ¶ 1, Sentence 2 - To the extent necessary,procurement documents shall re quire suppliers to provide aquality assurance program consistent with the pertinent requirements of American National Standard Quality Assurance Program Requirements for Nuclear Power

Plants, N45.2-1971.

appendix has been incorporated into the NQA-1 nonmandatory guidance of

Appendices 4A-1 and 7A-1.

N18.7 § 5.2.13, ¶ 1 The Appendix to N45.2.13 isparticularly useful in determining the quality assurance requirements depending on the complexity or safety of the item.N18.7 § 5.2.13.1, ¶ 2 Procurement documents shall include provisions for the following, as applicable: (1) Supplier Quality Assurance Program. Identification of quality assurance requirements applicable to the items or services

procured.The extent of the program required shall depend upon the type and use of the item or service being procured.Similar requirement.

The appendix referred to in N45.2.13

was not considered a part of the

standard. The guidance in the

appendix has been incorporated into the NQA-1 nonmandatory guidance of

Appendices 4A-1 and 7A-1.

N45.2 (5 ) Lower Tier Procurements.

Provisions forextending applicable requirements of procurement documents to lower tier s ubcontractors and suppliers,including purchaser's access to facilities and records.

N45.2.13 § 3.2.3 The procurement documents shall requirethe Supplier to incorporate appropriate quality assurance program requirements in subtier procurement documents.

N18.7 § 5.2.13.1, ¶ 2 Procurement documents shall include provisions for the following, as applicable: (5) Lower Tier Procurement. Provisions for extending applicable The procurement documents shall require the Supplier to incorporate appropriate quality assurance program requirements in subtier procurement documents.Similar requirement.

The appendix referred to in N45.2.13

was not considered a part of the

standard. The guidance in the

appendix has been incorporated into the NQA-1 nonmandatory guidance of

Appendices 4A-1 and 7A-1.

04/28/04 Procurement Document ControlPage 5 of 8 CRITERION 4 ANSI N45.2 § 5, N45.2.13 § 3, N18.7 § 5.2.13.1 BASIC REQUIREMENT 4 NQA-1 1994 COMMENTSrequirements to lower tier subcontractors and suppliers,including purchaser's access to facilities and records.

N45.2(3) Source Inspection and Audit

2.4 Right

of Access N45.2 Provisions for access to the plant facilities and records for source inspection a nd audit when the need forsuch inspection or audit has been determined.

N45.2.13 § 3.2.4 Right of Access. At each tier of aprocurement, the procurement document shall provide, as deemed necessary by the Pu rchaser, for access to theSupplier's plant facilities and records for inspection or audit by the Purchaser, his designated representative, and/or other parties authorized by the Purchaser. The provisions should include a statement of the minimum time of advance notice and the method of communication of such notice. They should include or provide for the later

identification (see Section 6.2) of the events such as

witness and hold points established or considered appropriate for the Purchaser's presence at the Supplier's facility.N18.7 § 5.2.13.1, ¶ 2 Procurement documents shall include provisions for the following, as applicable: (3) Source

Inspection and Audit. Provisions for access to the supplier's facilities and records for source inspection and

audit when the need for such inspection or audit has beendetermined.At each tier of a procurement, the procurement documents shall provide for access to the Supplier's plant facilities and records for inspection or audit by the Purchaser, his

designated representative, and/or other parties authorized by the Purchaser.Similar requirements.

N45.2.13 contains guidance on

sufficient notice for access to a supplier's facility that are more good business sense than quality assurance requirements.

(4) Documentation Requirements.

2.5 Documentation

Requirements N45.2 Records to be prepared, maintained, submitted. Ormade available for review, such as drawings, specifications, procedures, procurement documents, inspection and test records, personnel and procedure qualifications, and material, chemical, and physical test

results. N45.2.13 § 3.2.5 Documentation Requirements. Theprocurement documents at all tiers shall identify the documentation required to be submitted, including qualityassurance records for information, review, or approval of the Purchaser. The time of submittal shall also be

established.

N18.7 § 5.2.13.1, ¶ 2 Procurement documents shall includeThe procurement documents at all tiers shall identify thedocumentation required to be submitted for information,review, or approval by the Purchaser. The time of submittal shall also be established.Similar requirement.

04/28/04 Procurement Document ControlPage 6 of 8 CRITERION 4 ANSI N45.2 § 5, N45.2.13 § 3, N18.7 § 5.2.13.1 BASIC REQUIREMENT 4 NQA-1 1994 COMMENTS provisions for the following, as applicable: (4)Documentation Requirements. Records to be prepared, maintained, submitted or made available for review, such as drawings, specifications, procedures, procurement documents, inspection and test records, personnel and procedure qualifications, and material, chemical, and physical test results. -

N45.2 Instruction on record retention and disposition shall be provided.

N45.2.13 § 3.2.5 - The Purchaser shall prescribe to theSupplier those quality assurance records of compliance forwhich retention responsibility remains with the Supplier.

ANSI N45.2.9 provides guidance for retention and disposition of quality assurance records.

N18.7 § 5.2.13.1, ¶ 2 Procurement documents shall include provisions for the following, as applicable: (4) -

Instruction on record reten tion and disposition shall be provided.When the Purchaser requires the Supplier to maintain specific quality assurance records, the retention times anddisposition requirements shall be prescribed.Similar requirement.2.6 Nonconformances N45.2.13 § 3.2.6 Nonconformances. The procurementdocuments shall include Purchaser's requirements for

reporting and approving disposition of nonconformances.

Section 8 of this standard provides further guidelines on handling nonconformances.The procurement documents shall include Purchaser's requirements for reporting and approving disposition ofnonconformances.Similar requirement.

2.7 Spare

and Replacement Parts N18.7 § 5.2.13 Procurement and Materials Control.¶ 1 Measures shall be provided for procurement, documentation and control of those materials and components including spare and replacement parts necessary for plant operation, refueling, maintenance and modification.The procurement documents shall require the identification of appropriate spare and replacement parts or assemblies

and the appropriate delineati on of the technical and quality assurance related data required for ordering these parts or assemblies.Similar requirement.

N45.2.13 § 3.3 Procurement Document Review 3 PROCUREMENT DOCUMENT REVIEW N45.2.13 § 3.3 A review of the procurement documentsshall be made to assure that documents transmitted to the

prospective Suppliers for bid or contract purposes include appropriate provisions to assure items or services meet the specified requirements.A review of the procurement documents and changes thereto shall be made to assure that documents transmitted

to the prospective Supplier(s) include appropriate provisions to assure that items or services will meet the specified requirements.Similar requirement.

N45.2.13 § 3.3 - a. Such reviews shall be performed priorReviews shall be performed and documented to provideSimilar requirement.

04/28/04 Procurement Document ControlPage 7 of 8 CRITERION 4 ANSI N45.2 § 5, N45.2.13 § 3, N18.7 § 5.2.13.1 BASIC REQUIREMENT 4 NQA-1 1994 COMMENTS to release for bid and contract award and shall assure thatthe documents are complete and contain the applicablerequirements specified in Section 3.2 of this standard.d. Performance of reviews shall be documented to provideobjective evidence of accomplishment.objective evidence of satisfactory accomplishment of such review prior to contract award.

N45.2.13 § 3.3 - b. Changes made in the procurementdocuments as a result of the bid evaluations or precontract negotiations shall be incorporated into the procurement documents. The review of such changes and their effects shall be completed prior to contract award.Changes made as a result of the bid evaluations or

precontract negotiations shall be incorporated into the procurement documents. The review of such changes and their effects shall be completed prior to contract award.Similar requirement.

N45.2.13 § 3.3 - b - This review shall include the following considerations.1) Appropriate requirements specified in Section 3.2.2) Determination of any additional or modified design criteria imposed after preparation of the procurement documents.3) Analysis of exceptions or changes requested or specified by the Supplier and determination of the effects such changes may have on the intent of the procurement documents or quality of the item or service to be furnished.

This review shall include the following considerations:(a) appropriate requirements specified in Section 2 of this Supplement;(b) determination of any additional or modified design

criteria,(c) analysis of exceptions or changes requested or specified by the Supplier and determination of the effects such changes may have on the intent of the procurement documents or quality of the item or service to be furnished.Similar requirement.

N45.2.13 § 3.3 - c. Reviews required by this section shallbe performed by personnel who have access to pertinent information and who have an adequate understanding ofthe requirements and intent of the procurement documents.Reviews required by this Section shall be performed by personnel who have access to pertinent information and

who have an adequate understanding of the requirementsand intent of the procurement documents.Similar requirement.

4 PROCUREMENT DOCUMENT CHANGES N45.2 Changes in procurement documents shall be subjectto the same degree of control as was utilized in the preparation of the original document.

N45.2.13 § 3.4 Procurement Document ControlProcurement documents shall be controlled in accordance

with ANSI N45.2 Section 7.

N18.7 § 5.2.13.1

¶1, sentence 3 -

Where changes are madeto procurement documents, they shall be subject to the same degree of control as was used in the preparation of the original documents.

Alternative from current VA QA Topical Report With regard to Section 5.2.13.1 of ANSI N18.7-1976, titled Procurement Document Control: The words "the same degree of control" in the last sentence are replacedProcurement document changes shall be subject to the same degree of control as utilized in the preparation of the original documents.Similar requirements.

The controls of ANSI N45.2 Section 7

are those related to Criterion 6, Document Control.

The VA alternatives are inconsistent

between N18.7 and N45.2.13. The clarifying statement for N45.2.13 is bounded by the context of the related statements (e.g., Section 3) within

NQA-1 and the clarifications are no longer considered necessary.

04/28/04 Procurement Document ControlPage 8 of 8 CRITERION 4 ANSI N45.2 § 5, N45.2.13 § 3, N18.7 § 5.2.13.1 BASIC REQUIREMENT 4 NQA-1 1994 COMMENTS with "Engineering review."

N45.2.13 § 3.1, sentence 2 - Procurement documentchanges shall be subject to the same degree of control as utilized in the preparation of the original documents.

Alternative from current VA QA Topical Report

(3) With regard to Section 3.1 of ANSI N45.2.13-1976, titled Procurement Document Preparation, Review and Change Control: The phrase "the same degree of control"is stipulated to mean "equivalent level of review and approval." The changed document may not always be rereviewed by the originator; however, at least an

equivalent level supervisor shall review and approve any changes.

04/28/04Instructions, Procedures, and Drawings Page 1 of 17 CRITERION 5 ANSI N45.2 § 6 - ANSI N18.7 BASIC REQUIREMENT 5 NQA-1 1994 COMMENTS Related Definitions: ANSI N45.2.10 Procedure - a document that specifies or describeshow an activity is to be performed. It may include methods to be employed, equipment or materials to be

used and sequence of operations.

Procedure - a document that specifies or describeshow an activity is to be performedSimilar definition.

Related Definitions: ANSI N45.2.10 Qualified Procedure-A procedure which incorporatesall applicable codes and standards, manufacturer's parameters, and engineering specifications and has been

proven adequate for its intended purpose.

Qualified Procedure -

an approved procedure that hasbeen demonstrated to meet the specified requirements

for its intended purpose.Similar definition.

Related Definitions: ANSI N18.7 emergency procedures. Written procedures whichspecify actions, including manipulation of plant

controls, to reduce the consequence of an accident or potentially hazardous condition which has already occurred, to implement the emergency plan, or to

prepare for possible hazardous natural occurrences.

maintenance and modification procedures. Writtenprocedures defining the policies and practices by which structures; mechanical, electrical and instrumentation and control systems; and components thereof of a

nuclear power plant are kept in a condition of good repair or efficiency so that they are capable of performing their intended functions. As used in this Standard, these procedures apply to those activities performed by maintenance or contractor personnel to maintain, repair or modify safety-related equipment.

Related activities are those actions taken by operating personnel to determine that a planned maintenance activity can be safely performed under the existing plant

operating conditions, to authorize the release of equipment to be maintained in accordance with equipment control procedures, and to assure that the equipment has been returned to normal operating status at the completion of the maintenance work including verification of functional acceptability. Procedures for these related activities by operating personnel are considered to be operating procedures, but may be included in maintenance procedures.

No related definitions in NQA-1Procedure types are discussed in the

QAPD.

04/28/04Instructions, Procedures, and Drawings Page 2 of 17 CRITERION 5 ANSI N45.2 § 6 - ANSI N18.7 BASIC REQUIREMENT 5 NQA-1 1994 COMMENTS off-normal condition procedures.

Written procedureswhich specify operator actions for restoring an operating variable to its normal controlled value when it departs from its range or to restore normal operating

conditions following a perturbation. Such actions are

invoked following an operator observation or an annunciator alarm indicating a condition which, if not

corrected, could degenerate into a condition requiring action under an emergency procedure operating procedures.

Written procedures defining thenormal method, means and limits of operation of a nuclear power plant, a plant system or systems, or processes, including actions to be taken by operating personnel for removal from and return to service equipment on which maintenance is to be or has been performed (see also maintenance and modification

procedures).

Related Definitions: ANSI N45.2.10 Documentation - any written or pictorial informationdescribing, defining, specifying, reporting or certifying activities, requirements, procedures, or results.

Document - any written or pictorial informationdescribing, defining, specifying, reporting or certifying activities, requirements, procedures, or results. A document is not considered to be a Quality Assurance

Record until it satisfies the definition of a Quality Assurance Record as defined in this Supplement.Similar definition.

ANSI N45.2 Activities affecting quality shall beprescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these

instructions, procedures, or drawings.

_____N18.7 - 5.3 The administrative controls and qualityassurance program shall be carried out through plant

life in accordance with written procedures.

Activitiesaffecting safety at nuclear power plans shall be described by written procedure of a type appropriate to the circumstances and shall be accomplished in

accordance with these instructions and procedures.

5.2.7 Maintenance

or modifications of equipment shallbe preplanned and performed in accordance with written procedures, documented instructions or Activities affecting quality shall be prescribed by and performed in accordance with documented instructions, procedures, or drawings of a type appropriate to the circumstances.Similar requirement.

ANSI N18.7 contains a lot of specific detail on the type and content of

procedures. Will incorporate the appropriate information into the QAPD

using current alternatives to N18.7 without a specific commitment to N18.7 to avoid confusion by use of redundant

standards.

Reference:

ANSI N45.2.4, 5, 6, 8, and 11

contain additional procedure requirements. These have been

incorporated into NQA-1, Subparts 2.4, 2.5, 2.6, and 2.8. N45.2.11 requirements are incorporated into Supplement 3S-1 of

NQA-1.

04/28/04Instructions, Procedures, and Drawings Page 3 of 17 CRITERION 5 ANSI N45.2 § 6 - ANSI N18.7 BASIC REQUIREMENT 5 NQA-1 1994 COMMENTSdrawings appropriate to the circumstances whichconform to applicable codes, standards, specifications, and criteria. Skills normally possessed by qualified maintenance personnel may not require detailed step-by-step delineations in a written procedure.

Reg. Guide 1.33 lists the activities that

require procedures. Will continue to have procedures of the types addressed by Reg.

Guide 1.33 N45.2 - Instructions, procedures, or drawings shall include appropriate quantitative or qualitative criteria for determining that important activities have been satisfactorily accomplished. The activity may be

prescribed in job specifications, work instructions, shop

construction drawings, j ob tickets, planning sheets,operating or procedure manuals, test procedures, or any other type of written form, provided that the activity is adequately described. Quan titative criteria, such asdimensions, tolerances, and operating limits, and qualitative criteria, such as comparative workmanship samples, shall be specified, as appropriate, for determining satisfactory work performance and quality compliance.

___ANSI N18.7 - 5.3 These procedures shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. These procedures shall provide an approved preplanned method of

conducting operations. Procedures shall be prepared and approved prior to implementation as required by

4.3 and 5.2.15.These documents shall include or reference appropriate

quantitative or qualitative acceptance criteria for determining that prescribed activities have been satisfactorily accomplished.Similar requirement. NQA-1 is not as detailed in describing examples of quantitative criteria. The requirement regarding approved preplanned methods

is addressed in the Introduction to Part II

of NQA-1 and in the appropriate

Subparts.ANSI N18.7 - 5.2.2 Procedure Adherence. Proceduresshall be followed, and the requirements for use of

procedures shall be prescribed in writing. Rules shall be established which provide methods by which temporary changes to approved procedures can be made, including

the designation of a person or persons authorized to approve such changes. Temporary changes which clearly do not change the intent of the approved procedure, shall as a minimum be approved by two members of the plant staff knowledgeable in the areas affected by the procedures. At least one of these The requirement to have and work in

accordance with procedures is addressed in the Basic Requirement of NQA-1. The

level of detail of N18.

7 is not contained inthe Basic or Supplemental requirements

of NQA-1. This is addressed in the

QAPD.

04/28/04Instructions, Procedures, and Drawings Page 4 of 17 CRITERION 5 ANSI N45.2 § 6 - ANSI N18.7 BASIC REQUIREMENT 5 NQA-1 1994 COMMENTS individuals shall be the supervisor in charge of the shift and hold a senior operators license on the unit affected.

Such changes shall be docum ented and, if appropriate, incorporated in the next revision of the affected procedure. In the event of an emergency not covered by

an approved procedure, ope rations personnel shall beinstructed to take action so as to minimize personnel injury and damage to the facility and to protect health and safety. Guidance should be provided to identify the manner in which procedures are to be implemented. Examples of

such guidance include identification of those tasks that

require: (1) The written procedure to be present andfollowed step by step while the task is being performed(2) The operator to have committed theprocedural steps to memory (3) Verification of completion of significantsteps, by initials or signatures, of checkoff lists. The types of procedures that shall be present and referred to directly are those developed for extensive or complex jobs where reliance on memory cannot be

trusted, e.g., reactor start-up, tasks which are infrequently performed, and tasks in which operations must be performed in a specified sequence. Procedural steps for which actions should be committed to memory include, for example, immediate actions in emergency

procedures. Routine procedural actions that are frequently repeated may not require the procedure to be

present. Copies of all procedures shall be available to appropriate members of the plant staff. If documentation of an action is required, the necessary data shall be recorded as the task is performed.

Examples of procedures requiring verification are

furnished in 5.3.4.1 and 5.3.4.2. The Current VA program has the following alternative to thissection: With regard to Section 5.2.2 of ANSI 18.7-1976,titled Procedure Adherence: The third and fourth sentencesof the first paragraph of the Section address approval

04/28/04Instructions, Procedures, and Drawings Page 5 of 17 CRITERION 5 ANSI N45.2 § 6 - ANSI N18.7 BASIC REQUIREMENT 5 NQA-1 1994 COMMENTSrequirements for temporary changes to procedures which donot change the intent of the approved procedure. Adequate reviews will be provided by two members of the plant supervisory staff knowledgeable in the areas affected, one of

which will hold a senior reactor operator license on the unit affected. Adequate reviews will be performed in accordancewith Section 17.2.5 above, the Technical Specifications for Surry Power Station and Appendix C of this topical report for North Anna Power Station.

ANSI N18.7 5.2.3 Operating Orders. A mechanismshall be provided for dissemination to the plant staff of

instructions of general and continuing applicability tothe conduct of business. Such instructions, sometimes

also referred to as standing or ders or standard operating procedures, should deal with job turnover and relief, designation of confines of control room, definition of duties of operators and others, transmittal of operating data to management filing of charts, limitations on access to certain areas and equipment, shipping and receiving instructions, or other such matters. Provisions should be made for peri odic review and updating of standing orders.No similar specifics in NQA-1. Addressed

in the QAPD.

ANSI N18.7 5.2.4 Special Orders.

A mechanism shallbe provided for issuing management instructions which have short-term applicability and which require dissemination. Such instructions, sometimes referred to as a special orders, should encompass special

operations, housekeeping, data taking, publications and their distribution, plotting process parameters, personnel actions, or other similar matters. Provisions should be made for periodic review, updating and cancellation of

special orders.No similar specifics in NQA-1. Addressed

in the QAPD.

ANSI N18.7 5.2.5 Temporary Procedures. Temporaryprocedures may be issued during the operational phase:

to direct operations during testing, refueling, maintenance and modifications; to provide guidance in unusual situations not within the scope of the normal procedures; and to insure orderly and uniform operations for short periods when the plant, a system, orNo similar specifics in NQA-1. Addressed

in the QAPD.

04/28/04Instructions, Procedures, and Drawings Page 6 of 17 CRITERION 5 ANSI N45.2 § 6 - ANSI N18.7 BASIC REQUIREMENT 5 NQA-1 1994 COMMENTSa component of a system is performing in a manner notcovered by existing detailed procedures or has been modified or extended in such a manner that portions of existing procedures do not apply. Temporary

procedures shall include designation of the period of time during which they may be used and shall be

subject to the review process prescribed in 4.3 and

5.2.15 as applicable. Temporary procedures shall be approved by the management representative assigned approval authority.

ANSI N18.7

5.3 Preparation

of Instructions andProcedures. The administrative controls and quality assurance program shall be carried out throughout plant

life in accordance with written procedures. Activities affecting safety at nuclear power plants shall be described by written procedures of a type appropriate to the circumstances and shall be accomplished in

accordance with these instructions and procedures.

These procedures shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. These procedures shall provide an approved preplanned method of conducting operations.

Procedures shall be prepared and approved prior to implementation as required by 4.3 and 5.2.15.No similar specifics in NQA-1. Addressed

in the QAPD.

ANSI N18.7

5.3.1 Procedure

Scope. Each procedureshall be sufficiently detailed for a qualified individual to perform the required function without direct supervision, but need not provide a complete description of the system or plant processNo similar specifics in NQA-1. Addressed

in the QAPD.

ANSI N18.7 5.3.2 Procedure Content. The format ofprocedures may vary from plant to plant, depending on

the policies of the owner organization. However, procedures shall include, as appropriate, the following elements: (1) Title. Each procedure should contain a titledescriptive of the work or system or unit to which it applies, a revision number or date, and an approvalNQA-1 addresses the main requirements of this in Part II, the remainder is

addressed in the QAPD.

04/28/04Instructions, Procedures, and Drawings Page 7 of 17 CRITERION 5 ANSI N45.2 § 6 - ANSI N18.7 BASIC REQUIREMENT 5 NQA-1 1994 COMMENTS status.(2) Statement of Applicability. The purpose for which the procedure is intended should be clearly stated; for example, for use during reactor or plant start-up. If the purpose is not clear from the title, a separate statement of applicability should be provided, which may identify the reasons for particular operations.

(3) References. References, including reference to technical specifications, should be included in

procedures as applicable. References should be identified within the body of procedures when the sequence of steps requires other tasks to be performed

prior to or concurrent with a particular step within that

task.(4) Prerequisites. Each procedure shouldidentify those independent actions or procedures which shall be completed and plant conditions which shall exist prior to its use. Prerequisites applicable only to

certain sections of a procedure should be so identified.

(5) Precautions. Precautions should beestablished to alert the individual performing the task to those important measures which should be used to protect equipment and personnel, including the public, or to avoid an abnormal or emergency situation. It may be convenient to specify precautions separately.

Cautionary notes applicable to specific steps in the procedure should be included in the main body of the

procedure and should be identified as such.(6) Limitations and Actions. Limitations on theparameters being controlled and appropriate correctivemeasures to return the parameter to the normal control band should be specified. It may be convenient to specify limitations and setpoints in a separate section.

Where appropriate, quantitative control guides should be provided; for example, an appropriate step of a procedure should say "Manually adjust the feedwater flow controller to maintain the reactor water level at x feet," rather than "Manually adjust the feedwater flow to maintain water level."

04/28/04Instructions, Procedures, and Drawings Page 8 of 17 CRITERION 5 ANSI N45.2 § 6 - ANSI N18.7 BASIC REQUIREMENT 5 NQA-1 1994 COMMENTS(7) Main Body. The main body of a procedureshould contain step-by-step instructions in the degree ofdetail necessary for performing a required function or

task.(8) Acceptance Criteria. Procedures should contain, where applicable, acceptance criteria against which the success or failure of test-type activity would be judged. In some cases there would be qualitative

criteria, i.e., a given event does or does not occur. In

other cases quantitative values would be designated.(9) Checkoff Lists. Complex procedures shouldhave checkoff lists. These lists may be included as part of the procedure or may be appended to the procedure.

ANSI N18.7 5.3.3 System Procedures. Instructions for energizing, filling, venting, draining, starting up, shutting down, changing mod es of operation and otherinstructions appropriate for operations of systems related to the safety of the plant shall be delineated in system procedures. Procedures for correcting off-normal conditions shall be developed for those events where system complexity may lead to operator uncertainty. System procedures shall contain checkoff

lists where appropriate.No similar specifics in NQA-1. Addressed

in the QAPD.

ANSI N18.7

5.3.4 General

Plant Procedures. General plant procedures provide instructions for the integrated

operations of the plant. In addition to the characteristics

of procedures presented in 5.3.1 and 5.3.2, details

concerning specific general plant procedures are emphasized in the following sections.No similar specifics in NQA-1. Addressed

in the QAPD.

ANSI N18.7 5.3.4.1 Start-up Procedures. Start-up procedures shall be provided that include starting the reactor from cold or hot conditions and establishing power operation, with the generator synchronized to the line. Recovery from reactor trips shall be in accordance

with the start-up procedure and shall be subject to the determinations set forth in 5.2.1.

(1) Prerequisites. Start-up procedures shallinclude provisions for documented determination that prerequisites have been met, including confirmation thatNo similar specifics in NQA-1. Addressed

in the QAPD.

04/28/04Instructions, Procedures, and Drawings Page 9 of 17 CRITERION 5 ANSI N45.2 § 6 - ANSI N18.7 BASIC REQUIREMENT 5 NQA-1 1994 COMMENTSnecessary instruments are operable and properly set;valves are properly aligned; necessary systemsprocedures, tests and calibrations have been completed;

and required approvals have been obtained. Checkofflists are normally used for this purpose.(2) Main Body. The main body of the start-upprocedures shall include the major steps of the start-up sequence, including reference to appropriate system procedures. Such major steps shall include or reference detailed instructions for their performance, for example, minimum instrumentation requirements, coverage of

control rod withdrawal sequence or soluble poison dilution, manipulation of controls, establishment of feed and steam flow and turbine start-up and synchronization. Checkoff lists should be used for the purpose of confirming completion of major steps in

proper sequence.

ANSI N18.7 5.3.4.2 Shutdown Procedures. Shutdown procedures shall be provided to guide operations during and following controlled shutdown or reactor trips and shall include instructions for establishing or maintaining hot standby or cold shutdown conditions, as applicable.

The major steps involved in shutting down the plant

shall be specified, including detailed instructions for the performance of such actions as monitoring and controlling reactivity, load reduction and cooldown rates, sequence of activating or deactivating equipment, requirements for prompt analyses of causes of reactor trips or abnormal conditions requiring unplanned controlled shutdowns, and provisions for decay heat removal. Checkoff lists should be used for the purpose of confirming completion of major steps in proper

sequence.No similar specifics in NQA-1. Addressed

in the QAPD.

04/28/04Instructions, Procedures, and Drawings Page 10 of 17 CRITERION 5 ANSI N45.2 § 6 - ANSI N18.7 BASIC REQUIREMENT 5 NQA-1 1994 COMMENTS ANSI N18.7 5.3.4.3 Power Operation and LoadChanging Procedures. Procedures for steady-state

power operation and load ch anging shall be providedthat include, for example, provisions for use of control rods, chemical shim, coolant flow control or any other system available for long- or short-term control of reactivity, making deliberate load changes, responding

to unanticipated load changes and adjusting operating parameters.No similar specifics in NQA-1. Addressed

in the QAPD.

ANSI N18.7 5.3.4.4 Process Monitoring Procedures.Procedures for monitoring performance of plant systems shall be required to assure that core thermal margins and coolant quality are maintained at all times, that integrity of fission product barriers is maintained at all times and that engineered safety features and emergency equipment are in a state of readiness to maintain the plant in a safe condition if needed. The limits (maximum and minimum) for significant process parameters shall be identifie

d. The nature and frequencyof this monitoring shall be covered by operating procedures, as appropriate.No similar specifics in NQA-1. Addressed

in the QAPD.

ANSI N18.7 5.3.4.5 Fuel-Handling Procedures. Fuel-handling operations shall be performed in accordance

with written procedures. These procedures shall specify actions for core alterations, accountability of fuel and partial or complete refueli ng operations that include, forexample, continuous monitoring of the neutron flux

throughout core loading, periodic recording of date, audible annunciation of abnormal flux increases and evaluation of core neutron multiplication to verify the safety of loading increments.Provisions shall be made for preparing specific

procedures for each refueling outage and for receipt and shipment of fuel. Plant procedures should, nonetheless, prescribe the general preplanning for the fuel-handling program and its associated safety measures and should identify those aspects of the program for which

procedures are to be prepared for each refueling outage.

(1) Prerequisites. Prerequisites shall be No similar specifics in NQA-1. Addressed

in the QAPD.

04/28/04Instructions, Procedures, and Drawings Page 11 of 17 CRITERION 5 ANSI N45.2 § 6 - ANSI N18.7 BASIC REQUIREMENT 5 NQA-1 1994 COMMENTS provided in the fuel-handling procedures that include,for example, the status of plant systems required for refueling; inspection of replacement fuel, control rods, poison curtains and internals; designation of proper tools; proper conditions for spent fuel movement; proper conditions for fuel cask loading and movement; and status of interlocks, reactor trip circuits and mode

switches.(2) Main Body. The main body of fuel-handling procedures shall include requirements for refueling; for example, the status of the core, instructions for proper sequence, orientation, and seating of fuel and components, rules for minimum operable instrumentation, actions to be followed in the event of fuel damage, rules for periods when refueling is interrupted, verification of the shutdown margin and the frequency of determination, communications between control room and the fuel loading station, independent verification of fuel and component location, criteria for stopping refueling and for reducing the size of the fuel loading increment, and a containment evacuation plan and its associated safety measures. Documentation of final fuel and component serial numbers and locations shall be maintained.

ANSI N18.7

5.3.6 Radiation

Control Procedures.Procedures shall be provided for implementation of a radiation control program to meet applicable program requirements. The radiation control program involves the acquisition of data and provision of equipment to perform necessary radiation surveys, measurements and evaluations for the assessment and control of radiation

hazards associated with a nuclear power plant.

Procedures shall be developed and implemented for:

monitoring both external and internal exposures of employees, utilizing accepted techniques; routine radiation surveys of work areas; environmental monitoring in the vicinity of the plant; radiation monitoring of maintenance and special work activities; and for maintaining records demonstrating the adequacyNo similar specifics in NQA-1. Addressed

in the QAPD.

04/28/04Instructions, Procedures, and Drawings Page 12 of 17 CRITERION 5 ANSI N45.2 § 6 - ANSI N18.7 BASIC REQUIREMENT 5 NQA-1 1994 COMMENTSof measures taken to control radiation exposures ofemployees and others.

ANSI N18.7

5.3.7 Calibration

and Test Procedures.

Procedures shall be provided for periodic calibration and testing of safety-related instrumentation and control systems. Procedures shall also be provided for periodic calibration of measuring and test equipment used in activities affecting the quality of these systems. The procedures shall provide for meeting surveillance schedules and for assuring measurement accuracy adequate to keep safety-related parameters within operational and safety limits.No similar specifics in NQA-1. Addressed

in the QAPD.

ANSI N18.7 5.3.8 Chemical-Radiochemical ControlProcedures. Procedures shall be provided for chemical and radiochemical control activities. They should include, for example, the nature and frequency of sampling and analyses; instructions for maintaining coolant quality within prescribed limits; and limitations

on concentrations of agents that could cause corrosive attack, foul heat transfer surfaces or become sources of

radiation hazards due to activation.

Procedures shall also be provided for the control, treatment and management of radioactive wastes and

control of radioactive calibration sources.No similar specifics in NQA-1. Addressed

in the QAPD.

ANSI N18.7 5.3.9 Emergency Procedures. Procedures shall be provided to guide operations during potentialemergencies. They shall be written so that a trained

operator will know in advance the expected course of events that will identify an emergency and the immediate action he should take. Since emergencies may not follow anticipated patterns, the procedures should provide sufficient flexibility to accommodate

variations. Emergency procedures that cover actions for manipulations of controls to prevent accidents or lessen

their consequences should be based on a general sequence of observations and actions. Emphasis should

be placed on operator responses to observations andNo similar specifics in NQA-1. Addressed

in the QAPD in accordance with current requirements for these type procedures.

04/28/04Instructions, Procedures, and Drawings Page 13 of 17 CRITERION 5 ANSI N45.2 § 6 - ANSI N18.7 BASIC REQUIREMENT 5 NQA-1 1994 COMMENTSindications in the control room; that is, when immediateoperator actions are required to prevent or mitigate the consequences of a serious condition, procedures should require that those actions be implemented promptly.The emergency procedure format given in 5.3.9.1 provides a basis for coping with emergencies and is an acceptable format for prescribing operator observations and actions. Emergency procedures may contain supplemental background information to further aid

operators in taking proper emergency actions, but thisinformation shall be separated from the procedural

actions. It is extremely difficult to distinguish between

procedures prepared for the purpose of correcting off-normal conditions which in themselves do not constitutes actual emergency situations, but which conceivably can degenerate into true emergencies in the

absence of positive corrective action and procedures required for coping with true emergencies that have already occurred. Some owner organizations choose the term "Off-normal Procedures" for the same purpose that others choose "Emergency Procedures." When initially

available intelligence provi ded to operating personnelvia instrument readings, physical conditions, and personal observations may not clearly indicate the difference between a simple operational problem and a serious emergency, the actions outlined in the emergency procedures shall be based on a conservative course of action by the operating crew. Considerable judgment on the part of competent personnel is required before departing from the emergency procedure.(17) With regard to Section 5.3.9 of ANSI N18.7-1976, titled Emergency Procedure

As directed by the NRC, theCompany follows a format for emergency procedures whichis "symptom" based as opposed to "event" based as stipulated in Section 5.3.9.1. Since the Company has these "symptom" based procedures; "event" based procedures are not normally provided.

ANSI N18.7 5.3.9.1 Emergency Procedure Format andNo similar specifics in NQA-1. Addressed 04/28/04Instructions, Procedures, and Drawings Page 14 of 17 CRITERION 5 ANSI N45.2 § 6 - ANSI N18.7 BASIC REQUIREMENT 5 NQA-1 1994 COMMENTSContent. Emergency procedures shall include, asappropriate, the following elements:

(1) Title. The title should be descriptive of theemergency for which the procedure is provided.(2) Symptoms. Symptoms should be included toaid in the identification of the emergency. They should include alarms, operating conditions and probablemagnitudes of parameter changes. If a condition is peculiar only to the emergency under consideration, it

should be listed first(3) Automatic Actions. The automatic actionsthat will probably occur as a result of the emergency

should be identified.(4) Immediate Operator Actions. These stepsshould specify immediate actions for operation of controls or confirmation of automatic actions that are

required to stop the degradation of conditions and mitigate their consequences. Examples include the following: (a) The verification of automatic actions.

This step is based on equipment operating as designed

and the sequence of events following an expected course. Since variations from the expected course may occur, operators should be prepared to manipulate controls as necessary to cope with the problem.

However, the procedure should caution the operator not to place systems in "manual" unless misoperation in "automatic" is apparent and should require him to makefrequent checks for proper operation of systems placed in manual control. (b) Assurance that reactor is in a safe condition. This step usually means shutdown of the reactor with sufficient reactivity margin and establishment of required core cooling. (c) Notification to plant personnel of the nature of the emergency. (d)

Determination that the reactor coolant system pressure boundary is intact. (e) Confirmation of the availability of adequate power sources. (f) Confirmation that containment and exhaust systems are operating properly in order to prevent uncontrolled release of radioactivity.

in the QAPD in accordance with thecurrent requirements for these type

procedures.

04/28/04Instructions, Procedures, and Drawings Page 15 of 17 CRITERION 5 ANSI N45.2 § 6 - ANSI N18.7 BASIC REQUIREMENT 5 NQA-1 1994 COMMENTS (5) Subsequent Operator Actions. Steps shouldbe included to return the reactor to a normal condition or to provide for a safe extended shutdown period under abnormal or emergency conditions.5.3.9.2 Events of Potential Emergency. Potential emergency conditions shall be identified and proceduresfor coping with them shall be prepared. The following categories of events may, depending upon the design of the plant, be considered as examples of potential emergencies for which procedures are written and for which immediate action is indicated: (1) Loss of coolant from identified andunidentified sources, from small loss to design-basis-

accident loss (2) Reactor transients and excursions (3) Failure of vital equipment (4) Loss or degradation of vital power sources (5) Civil disturbances (6) Abnormally high radiation levels (7) Excessive release of radioactive liquid or gaseous effluent (8) Malfunction of reactivity control system (9) Loss of containment integrity (10) Conditions that require use of standbyliquid poison systems (11) Possible natural occurrences (12) Fires(18) With regard to Section 5.3.9.2 of ANSI N18.7-1976,titled Events of Potential Emergency: The Company willinterpret item (11) to mean the natural occurrences which have been evaluated in the UFSAR for the individual nuclear

facility5.3.9.3 Procedures for Implementing Emergency Plan.Implementing procedures for emergency plan actions shall contain, as appropriate, the following elements:(1) Individual assignment of authorities andresponsibilities for performance of specific tasks to

specific individuals or staff positions.

(2) Protective action levels and protective 04/28/04Instructions, Procedures, and Drawings Page 16 of 17 CRITERION 5 ANSI N45.2 § 6 - ANSI N18.7 BASIC REQUIREMENT 5 NQA-1 1994 COMMENTSmeasures outlined for the emergency identified.(3) Specific actions to be taken by coordinating support groups.(4) Procedures for medical treatment andhandling of contaminated individuals. (5) Special equipment requirements for items such as medical treatment, emergency personnel removal, specific radiation detection, personnel dosimetry and rescue operations, procedures for making this equipment available, pl us operating instructions forsuch equipment, and provisions for its periodic inspection and maintenance.(6) Identification of emergencycommunications network, including communications

required for personnel iden tification and effective coordination of all support groups.(7) Description of alarm signals in each facility.At sites with multiple units, alarm signals should be consistent from one unit to another. (Signals forinitiating protective measures should be clear and distinct from process or operational alarm system to

avoid confusion.)

(8) Procedures required to restore the plant tonormal conditions following an emergency.(9) Requirements for periodically testing ofprocedures, communications network and alarm systems to assure that they function properly.

5.3.9.3See also U.S. Nuclear Regulatory Commission (NRC)

"Guide to the Preparation of Emergency Plans for

Production and Utilization Facilities." (19) With regard to Section 5.3.9.3 of ANSI N18.7-1976,titled Procedures for Implementing Emergency Plan: TheCompany's NRC accepted Emerge ncy Plan for each nuclearfacility will be implemented in lieu of the requirements in this Section.

ANSI N18.7 5.3.10 Test and Inspection Procedures.

Test and inspection procedures shall contain a

description of objectives; acceptance criteria that will beNo similar specifics in NQA-1. Addressed

in the QAPD.

04/28/04Instructions, Procedures, and Drawings Page 17 of 17 CRITERION 5 ANSI N45.2 § 6 - ANSI N18.7 BASIC REQUIREMENT 5 NQA-1 1994 COMMENTSused to evaluate the results; prerequisites for performingthe tests or inspections including any special conditionsto be used to simulate normal or abnormal operating conditions; limiting conditions; and the test or

inspection procedure. These procedures shall also specify any special equipment or calibrations required

to conduct the test or inspection. Test and inspection results shall be documented and evaluated by responsible authority to assure that test and inspection requirements have been satisfied.

Where tests and inspections are to be witnessed, the procedure shall identify hold points in the testing sequence to permit witnessing. The procedure shall

require appropriate approval for the work to continuebeyond the designated hold point. The test and

inspection procedures shall require recording the date, identification of those performing the test or inspection, as-found condition, corrective actions performed, if any, and as-left condition.

05/21/04Document Control Page 1 of 6 CRITERION 6 ANSI 45.2 §7 - ANSI N18.7 § 5.2.15 BASIC REQUIREMENT 6 NQA-1 1994 COMMENTS N45.2 DOCUMENT CONTROLMeasures shall be established and documented tocontrol the issuance of documents, such as

instructions, procedures, and drawings, including

changes thereto, which prescribe activities affecting quality.ANSI N18.7-5.2.15 The administrative controls andquality assurance program shall provide measures to

control and coordinate the approval and issuance of documents, including changes thereto, which prescribe all activities affecting quality. Such documents include those which describe

organizational interfaces, or which prescribe activities affecting safety-related structures, systems, or components. These documents also include

operating and special orders, operating procedures, test procedures, equipment control procedures, maintenance or modification procedures, refueling, and material control procedures.The preparation, issue, and change of documents that specify quality requirements or prescribe activities affecting quality shall be controlled to assure that correct documents are being employed.Similar requirement.ANSI N18.7 contains some additional information regarding Document control

that is not reflected in the basic or supplemental requirements of NQA-1.

Recommend incorporating this information into the QAPD and eliminate any commitment to N18.7.

N 45.2 These measures shall assure that documents,including changes, are reviewed for adequacy and approved for release by authorized personnel and

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

ANSI N18.7-5.2.15 These measures shall assure thatdocuments, including revisions or changes, are reviewed for adequacy by appropriately qualified personnel and approved for release by authorized

personnel; and are distributed in accordance with current distribution lists and used by the personnel performing the prescribed activity, and that procedures are provided to avoid the misuse of outdated or inappropriate documents.

Procedures for operational phase activities of a

nuclear power plant reflect the conditions that exist at the time the procedures are written. These conditions include the technical information available, industry experience, and in the case of the initial procedures for a new plant, assumptions madeSuch documents, including changes thereto, shall be reviewed for adequacy and approved for release by

authorized personnel.Similar requirement. N18.7 has more detailed review requirements. The QAPD has met the intent of N18.7 through the modified review programs that had previously been established at the sites in

lieu of the specific review periodicity

defined in N18.7 (biennial review). The

Millstone and the North Anna/Surry review programs are continued through the

new QAPD and a biennial review for all procedures is not committed to in the new program. Regulatory requirements for specific reviews will continue to be met.

05/21/04Document Control Page 2 of 6 CRITERION 6 ANSI 45.2 §7 - ANSI N18.7 § 5.2.15 BASIC REQUIREMENT 6 NQA-1 1994 COMMENTSregarding the detailed behavior of the plant that maynot be fully known prior to operation. In order to

ensure that the procedures in current use provide the best possible instructions for performance of the work involved, systematic review and feedback of information based on use is required.

Each procedure shall be reviewed and approved prior to initial use. The frequency of subsequent reviews shall be specified and may vary depending on the type and complexity of the activity involved, and may vary with time as a given plant reaches operational maturity. Applicable procedures shall be

reviewed following an unusual incident, such as an

accident, an unexpected transient, significant operator error, or equipment malfunction.

Applicable procedures shall be reviewed following any modification to a system.Plant procedures shall be reviewed by an individual knowledgeable in the area affected by the procedure no less frequently than every two years to determine if changes are necessary or desirable. A revision of a

procedure constitutes a procedure review. Procedures shall be approved as designated by the

owner organization before initial use. Rules shall be established which clearly delineate the review of procedures by knowledgeable personnel other than

the originator and the approval of procedures and procedure changes by authorized individuals.

The following exception is in the Current MP QAPD: ANSI N18.7-1976, Paragraph 5.2.15,"Review, Approval, and Control of Procedures," states in part: "Plant procedures shall be reviewed by

an individual knowledgeable in the area affected by the procedure no less frequently than every two years to determine if changes are necessary or desirable."The licensee implements administrative and programmatic controls that ensure procedures are maintained current in accordance with 10CFR50, 05/21/04Document Control Page 3 of 6 CRITERION 6 ANSI 45.2 §7 - ANSI N18.7 § 5.2.15 BASIC REQUIREMENT 6 NQA-1 1994 COMMENTSAppendix B, thus meeting the intent of the biennial review.The licensee implements administrative controls toperform biennial reviews of non-routine procedures such as Emergency Operating Procedures (EOP's),

Abnormal Operating Procedures (AOP's), Off Normal Procedures (ONP's), Emergency Plan, Security and other procedures that may be dictated by

an event. Programmatic controls specify conditions when the mandatory review of plant procedures apply, and include a requirement to review applicable

procedures following an accident or transient and following any modification to a system.

The licensee utilizes a pre-job briefing practice to

ensure that personnel are aware of what is to be accomplished and what procedures will be used prior

to beginning a job. In addition, the Procedure Compliance Policy requires that the job be stopped

and the procedure be revised or the situation resolved

prior to work continuing if procedures cannot be implemented as written.Additionally, the licensee's Quality Assurance Program requires the review of a representative sample of plant procedures as part of routine audits

and surveillances to ensure that existing administrative controls for procedure verification, review and revision are effective in maintaining the quality of plant procedures. Significant procedural

deficiencies are identified and corrected through the Station Corrective Action Program. The Station Self-Assessment Program also periodically reviews

selected procedures and identifies deficiencies and improvements through the Corrective Action Program.The following clarification is in the Current VA QAPD: (15) With regard to Section 5.2.15 of ANSI N18.7-1976, titled Review, Approval and Control of Procedures

The third sentence in paragraph 05/21/04Document Control Page 4 of 6 CRITERION 6 ANSI 45.2 §7 - ANSI N18.7 § 5.2.15 BASIC REQUIREMENT 6 NQA-1 1994 COMMENTSthree is interpreted to mean: Applicable procedures, as determined by Station Management, shall be reviewed following an accident, an unexpected transient, significant operator error or equipment malfunction. The first sentence of the fourth paragraph is considered to be met via procedure reviews as described by administrative procedures.

Additional procedure review , approval, and controlrequirements/exceptions are discussed in Section 17.2.5. above. The biennial review requirement isdeleted. The procedures upgrade program provides a systematic and effective process for developing and revising procedures which encompasses the intent of

the biennial review.

SUPPLEMENT 6S-1 Supplementary Requirements For Document Control 1 GENERALThis Supplement provides amplified requirements for a document control system.It supplements the requirements of Basic Requirement 6 of

this Part (Part I) and shall be used in conjunction with that Basic Requirement when and to the extent specified by the

organization invoking this Part (Part I).The documents which shall be controlled in accordance with this Supplement are only those documents which specify quality requirements or prescribe activities affecting quality such as instructions, procedures, and

drawings.NQA 1-1994 added a requirement that describes what falls under the document control supplement.The term document control used throughout thisSupplement is defined as the act of assuring that documents are reviewed for adequacy, approved for release by authorized personnel, and distributed to and used at the location where the prescribed activity is performed.

NQA 1-1994 Added language to bound and limit what falls under document

control.2 DOCUMENT PREPARATION, REVIEW, APPROVAL, AND ISSUANCE N 45.2 Those participating in an activity shall bemade aware of and use proper and currentGeneral language that meets the intent of

N18.7 has been included in Section 6 of 05/21/04Document Control Page 5 of 6 CRITERION 6 ANSI 45.2 §7 - ANSI N18.7 § 5.2.15 BASIC REQUIREMENT 6 NQA-1 1994 COMMENTS instructions, procedures, drawings, and engineeringrequirements for performing the activity.

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

ANSI N18.7-5.2.15 Those participating in anyactivity shall be made aware of, and use, proper and

current instructions, procedures, drawings, and engineering requirements for performing the activity. Participating or ganizations shall haveprocedures for control of the documents and changes thereto to preclude the possibility or use of outdated or inappropriate documents.

the QAPD.N 45.2 Document control measures shall provide for: (1) identification of individuals or organizations

responsible for preparing, reviewing, approving, and issuing documents and revisions thereto; (2) identifying the proper documents to be used in performing the activity; (3) coordination and control of interface documents; (4) ascertaining that proper documents are being used; (5) establishing current

and updated distribution lists.

ANSI N18.7-5.2.15 Document control measures shall provide for: (1) Identification of individuals or

organizations responsible for preparing, reviewing,approving, and issuing documents and revisions thereto; (2) Identifying the proper documents to be used in performing the activity; (3) Coordination and control of interface documents; (4) Ascertaining that proper documents are being used; (5)

Establishing current and updated distribution lists.The control system shall be documented and shall provide for (a) through (c) below:(a) identification of documents to be controlled and their specified distribution;(b) identification of assignment of responsibility for

preparing, reviewing, approving, and issuing documents;(c) review of documents for adequacy, completeness, and correctness prior to approval and issuance.Similar requirement. NQA-1 is not as

detailed.3 DOCUMENT CHANGES

3.1 Major

Changes N 45.2 Changes to documents shall be reviewed andapproved by the same organizations that performed

the original review and approval unless otherChanges to documents, other than those defined as minor changes in para. 3.2 below, are considered as major changes and shall be reviewed and approved by the sameSimilar requirements 05/21/04Document Control Page 6 of 6 CRITERION 6 ANSI 45.2 §7 - ANSI N18.7 § 5.2.15 BASIC REQUIREMENT 6 NQA-1 1994 COMMENTSorganizations are specifically designated.

ANSI N18.7-5.2.15 Changes to documents shall bereviewed and approved by the same organizations that perform the original review and approval unless

the owner organization designates another qualified

organization.organizations that performed the original review and approval unless other organizations are specifically

designated.

N 45.2 The reviewing organizations shall haveaccess to pertinent background information upon

which to base its approval and shall have adequateunderstanding of the requirements and intent of the original document.

ANSI N18.7-5.2.15 The reviewing organizations shall have access to pertinent background information upon which to base its approval and

shall have adequate understanding of requirementsand intent of the original document.

The reviewing organization shall have access to pertinent background data or information upon which to base their

approval.Similar requirements

3.2 Minor

ChangesMinor changes to documents, such as inconsequential

editorial corrections, shall not require that the revised documents receive the same review and approval as the original documents.Additional requirement.To avoid a possible omission of a required review, the type of minor changes that do not require such a review

and approval and the persons who can authorize such a decision shall be clearly delineated.Additional requirement.

05/21/04Control of Purchased Material, Equipment, (Items) and ServicesPage 1 of 22 CRITERION 7 ANSI N45.2 - ANSI N45.2.13 - ANSI N18.7 BASIC REQUIREMENT 7 NQA-1 1994 COMMENTS N45.2 § 8 and N18.7 § 5.2.13.2, unless otherwise noted.

N45.2 Measures shall be established and documented toassure that purchased items and services, whether purchased directly or through contractors, conform to the procurement documents.

N18.7 Measures shall be provided to assure that purchaseditems and services, whether purchased directly or through contractors, conform to the procurement documents.The procurement of items and services shall be controlled to assure conformance with specified requirements.Similar requirement.

N45.2 These measures shall include provisions, as appropriate, for source evaluation and selection, objective evidence of quality furnished by the contractor, inspection and audit at the source, and examination of items upon delivery.N18.7 These measures shall include provisions, as appropriate, for source evaluation and selection, objective evidence of quality furnished by the contractor, inspection and audit at the source and examination of items upon delivery.Such control shall provide for the following as

appropriate: source evaluation and selection, evaluation of objective evidence of quality furnished by the Supplier, source inspection, audit, and examination of items or services upon delivery or completion.Similar requirement.

SUPPLEMENT 7S-1, SUPPLEMENTARY REQUIREMENTS FOR CONTROL OF

PURCHASED ITEMS AND SERVICES 1 GENERAL N45.2.13 § 1.1 ScopeThis standard describes requirements and provides guidelines for the control of activities to be exercised during procurement of items and services which affect the quality of nuclear power plants. These requirements and guidelines apply to procurement activities for items and

services such as designing, purchasing, fabricating, handling, shipping, storing, cleaning, constructing, erecting, installing, inspecting, testing, maintaining, repairing, initial fueling, refueling, and modifying. This

standard provides guidelines for application of quality assurance, program requirements listed in ANSI N45.2 for various types of procurement such as; total system supply, hardware, services, or a combination thereof.This standard applies to the work of any individual or organization participating in the procurement of those This Supplement provides amplified requirements for control of purchased items and services. It supplements the requirements of Basic Requirement 7 of this Part (Part

1) and shall be used in conjunction with that Basic Requirement when and to the extent specified by the organization invoking this Part (Part 1). This Supplement includes requirements for source selection, bid evaluation, Supplier performance evaluation, and verification of conformance.NQA-1 addresses applicability of the

standard in the introduction to Part I.

This edition does not contain the limits on use with ASME III and XI code requirements; therefore, the NRC regulatory position (C.2) is

addressed. The quality assurance requirements of the Dominion program, including the

standards of NQA-1, would be used

for all activities, including ASME III

and XI activities and would supplement any specific quality requirements those codes invoke.The NRC regulatory position (C.5) is addressed by exception. No exception 05/21/04Control of Purchased Material, Equipment, (Items) and ServicesPage 2 of 22 CRITERION 7 ANSI N45.2 - ANSI N45.2.13 - ANSI N18.7 BASIC REQUIREMENT 7 NQA-1 1994 COMMENTSitems and services from which satisfactory performance isrequired. The extent to which the individual requirements

of this standard shall apply will depend upon the natureand scope of the work to be performed and the required quality of the items or services purchased.

The ASME Boiler & Pressure Vessel Code (hereafter referred to as the Code, as well as other American

National standards, has been considered in the development of this standard, and this standard is intendedto be compatible with Code requirements. This standarddoes not, however, apply to activities covered by Section

Ill Divisions I and 2 and Section XI of the Code for those activities covered by the Code.

Reg. Guide 1.123 Regulatory Position C.2. Section 1.1 of ANSI N45.2.13-1976 states: "The ASME Boiler &

Pressure Vessel Code (hereafter referred to as the Code) as

well as other ANSI standards, has been considered in the development of this standard, and this standard is intendedto be compatible with Code requirements. This standarddoes not, however, apply to activities covered by Section

III, Divisions 1 and 2, and Section XI of the Code for those activities covered by the Code." While Section III, Division 1 and 2, and Section XI (which addresses the control of spare and replacement parts) of the ASME

Boiler and Pressure Vessel Code address general requirements for control of procurement of items and

services for nuclear power plants, these sections do not explicitly address all the activities described in the ANSI

N45.2.13-1976 standard. ANSI N45.2.13-1976, subject to the exceptions of the regulatory position, should be used

in conjunction with the ASME Boiler and Pressure Vessel

Code,Section III, Divisions 1 and 2, and Section XI for control of procurement of items and services where the

ASME Code does not address the activities covered by

ANSI N45.2.13-1976.

Reg. Guide 1.123 Regulatory Position C.5. ANSIN45.2.13-1976 addresses the control of procurement of items and services that affect the quality of nuclear power plants, including spare and replacement parts. The is granted to the purchase of spare or replacement parts. Therefore, these quality assurance requirements would be applied to spare and replacement parts the same as new items.

05/21/04Control of Purchased Material, Equipment, (Items) and ServicesPage 3 of 22 CRITERION 7 ANSI N45.2 - ANSI N45.2.13 - ANSI N18.7 BASIC REQUIREMENT 7 NQA-1 1994 COMMENTSstandard, however, does not provide "requirements"specific to spare and replacement parts. Section 5.2.13 of ANSI N18.7-1976/ANS 3.2, "Administrative Controls and Quality Assurance for the Operational Phase of NuclearPower Plants," which is endorsed by Regulatory Guide 1.33, "Quality Assurance Program Requirements (Operation)," addresses control of spare and replacement

parts during the operations phase of nuclear power plants.

As a result, the provisions of Section 5.2.13 of ANSI N18.7-1976 related to control of spare and replacement

parts are considered applicable and should be used in

conjunction with the provisions of ANSI N45.2.13-1976.

2 PROCUREMENT PLANNING N45.2.13 § 2. PLANNINGMeasures established for the control of the procurement ofitems or services shall include planning.Procurement activities shall be planned and documented toassure a systematic approach to the procurement process.Similar requirement.

N45.2.13 § 2 - Control of the procurement process requires the identification of organizations involved in the execution of the activity and the delineation of each organization's responsibility.Planning shall result in the documented identification of methods to be used in procurement activities, sequence of actions and milestones indicating the completion of these

activities, and the preparation of applicable procedures prior to the initiation of each individual activity listed

below.Procurement planning shall result in the documented identification of procurement methods and organizational responsibilities.Similar requirement.

N45.2.13 § 2 - Planning shall determine the following objectives:a. What is to be accomplished.b. Who is to accomplish it.c. How it is to be accomplished.d. When it is to be accomplished.Planning shall determine the following:(a) what is to be accomplished;(b) who is to accomplish it;(c) how it is to be accomplished;(d) when it is to be accomplishedSimilar requirement.

N45.2.13 § 2 - These objectives shall be accomplished asearly as practicable and no later than the start of those procurement activities which are required to be controlled, to assure interface compatibility and a uniform approach to the procurement process.Planning shall be accomplished as early as practicable, and no later than at the start of those procurement

activities which are required to be controlled, to assure interface compatibility and a uniform approach to the procurement process.Similar requirement.

N45.2.13 § 2 - Planning shall provide for the integration These requirements are addressed by

05/21/04Control of Purchased Material, Equipment, (Items) and ServicesPage 4 of 22 CRITERION 7 ANSI N45.2 - ANSI N45.2.13 - ANSI N18.7 BASIC REQUIREMENT 7 NQA-1 1994 COMMENTS of the following:a. Procurement Document Preparation, Review and Change Control.b. Selection of Procurement Sources.

c. Bid Evaluation and Award.d. Purchaser Control of Supplier Performance.

e. Verification (surveillance, inspection, or audit)

Activities by Purchaser.f. Control of Nonconformances.

g. Corrective Action.h. Acceptance of Item or Service.i. Quality Assurance Records.j. Audit of Procurement Program.

Subsequent sections discuss these activities and their control in accordance with the general requirements of

ANSI N45.2 (and this standard) in greater detail. These

activities shall be capable of being verified and their effectiveness determined by audit. Where any of the procurement activities are delegated or applicable to

subtier Suppliers, the a ppropriate controls andrequirements of this standard shall also apply.Supplement 7S-1 to NQA-1, but this

level of detail leading in to the requirements is not used within

NQA-1.3 SUPPLIER SELECTION N45.2 Source inspection or audit shall be performed asnecessary to assure the required quality of an item. Source inspection or audit may not be necessary when the quality of the item can be verified by review of test reports, inspection upon receipt, or other means.

N18.7 Source inspection or audit shall be performed asnecessary to assure the required quality of an item. Source inspection or audit may not be necessary when the quality of the item can be verified by review of test reports, inspection upon receipt, or other means.

N45.2.13 § 4. SELECTION OF PROCUREMENT SOURCES - 4.1 General - The selection of Suppliers shall be based on evaluation of their capability to provide items or services in accordance with the requirements of the procurement documents.

3.1 Source

Evaluation and Selection The selection of Suppliers shall be based on evaluation of their capability to provide items or services in accordance with the requirements of the procurement documents prior

to award of contract.Similar requirement.

N45.2.13 § 4.2 Selection Measures - Procurement source Procurement source evaluation and selection measuresshall be implemented by the Purchaser and shall provideSimilar requirement.

05/21/04Control of Purchased Material, Equipment, (Items) and ServicesPage 5 of 22 CRITERION 7 ANSI N45.2 - ANSI N45.2.13 - ANSI N18.7 BASIC REQUIREMENT 7 NQA-1 1994 COMMENTSevaluation and selection measures shall be adopted by the Purchaser and shall provide for identification of the Purchaser's organizational responsibilities for determining Supplier capability. This may require integrated action involving one or more organi zations (e.g., engineering,construction, manufacturing, operations, purchasing, or quality assurance) based upon the item or service being

procured. for identification of the Purchaser's organizational responsibilities for determining Supplier capability.

N45.2 Measures for evaluation and selection ofprocurement sources include the use of historical quality performance data, source surveys or audits, or source qualification programs.

N18.7 Measures for evaluation and selection ofprocurement sources include the use of historical quality performance data, source surveys or audits, or source qualification programs.

N45.2.13 § 4.2 Methods to be utilized in evaluation ofSupplier sources, and the results therefrom, shall be documented and shall include any or all of the following:Measures for evaluation and selection of procurement sources, and the results therefrom, shall be documented and shall include one or more of (a) through (c) below:Similar requirement.

N45.2.13 § 4.2 - a. Evaluating the suppliers history ofproviding a product which performs satisfactory in actual use. Information which should be evaluated should

include:1) Experience of users of identical or similar products of

the prospective Supplier.2) Purchaser's records that have been accumulated in

connection with previous procurement actions and product operating experience.Quality performance is highly dependent upon the Supplier's personnel capabilities, physical conditions of the manufacturing factory and equipment, and management attitude towards quality. Historical data should be representative of the Supplier's current capability. If there has been no recent experience with the Supplier, or if he is a new Supplier, the prospective Supplier shall be requested to submit information on a similar item or service for evidence of his current

capabilities.

Reg. Guide 1.123 Regulatory Position C.6 In addition to (a) evaluation of the Supplier's history of providing anidentical or similar product which performs satisfactorily in actual use. The Supplier's history shall reflect current capability.Similar requirement.

This addresses NRC Regulatory

Position C.6.a.Other details of items 1, 2 and the

subsequent paragraph in N45.2.13 are

guidance and are addressed as nonmandatory guidance in Appendix

7A-1 of NQA-1 §2.1.

05/21/04Control of Purchased Material, Equipment, (Items) and ServicesPage 6 of 22 CRITERION 7 ANSI N45.2 - ANSI N45.2.13 - ANSI N18.7 BASIC REQUIREMENT 7 NQA-1 1994 COMMENTSthe requirements of the standard, the guidelines (indicatedby the verb "should") identified below are considered to have sufficient safety importance to be treated the same as the requirements of the standard. - a. Section 4.2.a - The guidelines used in evaluating the Supplier's history of providing a product that performs satisfactorily in actual

use.N45.2.13 § 4.2 - b. The Supplier's current quality recordssupported by documented qualitative and quantitativeinformation which can be objectively evaluated. This would include review and evaluation of the Supplier's Quality Assurance Program, Manual, and Procedures, as

appropriate.(b) Supplier's current quality records supported by documented qualitative and quantitative information which can be objectively evaluated;Similar requirement.

N45.2.13 § 4.2 - c. The Supplier's technical and qualitycapability as determined by a direct evaluation of his facilities and personnel, and the implementation of his quality assurance program.(c) Supplier's technical and quality capability as determined by a direct evaluation of his facilities and personnel and the implementation of his quality assurance program.Similar requirement.

N45.2.13 § 5. BID EVALUATION AND AWARD5.1 General - A documented system for reviewing and evaluating the bids and awarding of contracts shall be established by the Purchaser.

4 BID EVALUATIONRequirement addressed through the following statements.

N45.2.13 § 5.2 Conformance to Procurement Document The Purchaser shall establish measures to assure that thebid conforms to the procurement document requirements.

The bid evaluation shall be made by individuals or

organizations designated to evaluate the following subjects, as applicable to the type of procurement:

a. Technical considerations.b. Quality assurance requirements.c. Research and development effort.

d. Suppliers' Personnel.e. Suppliers' production capability.f. Suppliers' past performance.

g. Alternates.

h. Exceptions.

Other considerations such as warranties, schedule, price, price adjustments commercial terms and conditions, although not quality related, are recognized as factors Bid evaluation shall determine the extent of conformance to the procurement documents. This evaluation shall be performed by individuals or organizations designated toevaluate the following subjects, as applicable to the type of procurement: (a) technical considerations(b) quality assurance requirements (c) Supplier's personnel (d) Supplier's production capability(e) Supplier's past performance (f) alternates (g) exceptionsSimilar requirement.

NQA-1 does not address research and development effort as a factor in bid

evaluation. This would be covered by

evaluation of a Supplier's technical

considerations.NQA-1 does not address those items that are not considered quality related.

05/21/04Control of Purchased Material, Equipment, (Items) and ServicesPage 7 of 22 CRITERION 7 ANSI N45.2 - ANSI N45.2.13 - ANSI N18.7 BASIC REQUIREMENT 7 NQA-1 1994 COMMENTS affecting bid evaluation.

N45.2.13 § 5.3 Preaward Evaluation - Prior to the awardof the contract, the Purchaser shall have performed a

preaward evaluation of the Supplier as described in

Section 4.2 of this standard.

Addressed in section 3 of this supplement to NQA-1.

N45.2.13 § 5.4 Award - Prior to the award of the contract,the Purchaser shall also resolve or obtain commitments to resolve unacceptable conditions resulting from the bid

evaluation.

Prior to the award of the contract, the Purchaser shall resolve or obtain commitments to resolve unacceptable quality conditions resulting from the bid evaluation.Similar requirement.

5 SUPPLIER PERFORMANCE EVALUATION N45.2.13 § 6. PURCHASER EVALUATION OF SUPPLIER PERFORMANCE

6.1 General

- Purchasers at all tiers shall retain the responsibility of monitoring and evaluating Supplier performance to the specified requirements of the procurement document. In exercising this responsibility, the Purchaser of items and services shall establish measures to verify Supplier's performance. As deemed necessary by the Purchaser, the methods shall include:The Purchaser of items and services shall establish measures to interface with the Supplier and to verify Supplier's performance as deemed necessary by the Purchaser. The measures shall include (a) through (f)

below:Similar requirement.

N45.2.13 § 6.1 - a. Establishing an understanding between Purchaser and Supplier of the provisions and specifications of the procurement documents.(a) establishing an understanding between Purchaser and

Supplier of the provisions and specifications of the procurement documents;Similar requirement.

N45.2.13 § 6.1 - b. Requiring the Supplier to identify planning techniques and processes to be utilized in fulfilling procurement document requirements.(b) requiring the Supplier to identify planning techniques and processes to be utilized in fulfilling procurement document requirements;Similar requirement.

N45.2.13 § 6.1 - c. Reviewing documents which are generated or processed during activities fulfilling procurement requirements.(c) reviewing Supplier documen ts which are generated orprocessed during activities fulfilling procurement requirements;Similar requirement.

N45.2.13 § 6.1 - d. Identifying and processing necessarychange information.(d) identifying and processing necessary change information;Similar requirement.

N45.2.13 § 6.1 - e. Establishing exchange method ofdocument information between Purchaser and Supplier.(e) establishing method of document information

exchange between Purchaser and Supplier;Similar requirement.

N45.2.13 § 6.2 Planning and Coordination - (3 rd sentence)

Purchaser notification points, including hold and witness points, should be identified and documented based upon mutual agreement between Purchaser and Supplier.

Reg. Guide 1.123 Regulatory Position C.6 In addition tothe requirements of the standard, the guidelines (indicated (f) establishing the extent of source surveillance and

inspection activities.Similar requirement.

This addresses the NRC Regulatory

Position C.6.b 05/21/04Control of Purchased Material, Equipment, (Items) and ServicesPage 8 of 22 CRITERION 7 ANSI N45.2 - ANSI N45.2.13 - ANSI N18.7 BASIC REQUIREMENT 7 NQA-1 1994 COMMENTSby the verb "should") identified below are considered tohave sufficient safety importance to be treated the same as the requirements of the standard. - b. Section 6.2 - The

guideline concerning purchaser notification points as part

of pre-and post-award activities.

N45.2.13 § 6.2 Planning and Coordination - (4 th sentence)These activities shall be implemented as early as practicable in the procurement process.

N45.2.13 § 7.1 - These verification activities shall beconducted as early as practicable to preclude subsequent activities from preventing disclosure of deficiencies.These verification activities shall be conducted as early as

practicable. Similar requirement.

N45.2.13 § 7.1 - The Purchaser's verification activities are not intended to relieve the Supplier of his responsibilitiesfor verification of quality requirements.

The Purchaser's verification activities, however, shall not

relieve the Supplier of his responsibilities for verification of quality achievement.Similar requirement.

6.2 Planning

and CoordinationDepending on the complexity or scope of the item or

service, the Purchaser shall initiate pre- and post-award activities. These activities may take the form of meetings or other forms of communication to establish an

understanding between the Purchaser and Supplier of the procurement requirements; the intent of the Purchaser in monitoring and evaluating the Supplier's performance; and the planning, manufacturing techniques, tests, inspections, and processes to be employed by the Supplier in meeting procurement requirements. Purchaser notification points, including hold and witness points, should be identified and documented based upon mutual agreement between

Purchaser and Supplier. These activities shall be implemented as early as practicable in the procurement process. The depth and necessity of pre- and post-award activity depends on the uniqueness, complexity, procurement frequency with the same Supplier and past Supplier performance for the specific items or services covered by the procurement document.These requirements are contained as nonmandatory guidance in NQA-1, Appendix 7A-1 § 3.

5.1 Extent

of Activities N45.2.13 § 7.2 Planning - Planning shall be an integral part of verification activities. The extent of verification

activities, including planning, shall be a function of the The extent of verification activities, including planning, shall be a function of the relative importance, complexity, and quantity of the item or services procured and the Similar requirement.

05/21/04Control of Purchased Material, Equipment, (Items) and ServicesPage 9 of 22 CRITERION 7 ANSI N45.2 - ANSI N45.2.13 - ANSI N18.7 BASIC REQUIREMENT 7 NQA-1 1994 COMMENTSrelative importance, complexity, and quantity of the itemprocured and the Supplier's quality performance. See

Section 10 of this standard for guidance in selecting verification methods.

N45.2.13 § 7.2.1 Source Verification Planning. Theverification activity plans shall, relative to fabrication sequence and assembly processes, identify the appropriate

inspections, tests, prerequisites and inspection sequence, hold and witness points, acceptance criteria, and the documentation required by the procurement document.Supplier's quality performance.

N45.2.13 § 7.1 - Purchaser verification activities shall beaccomplished by qualified personnel assigned to check, inspect, audit or witness the activities of Suppliers.Verification activities shall be accomplished by qualified

personnel assigned to check, inspect, audit, or witness the

activities of Suppliers.Similar requirement.

5.2 Records

N45.2 The effectiveness of the control of quality shall beassessed by. the purchaser at intervals consistent with the importance, complexity, and quality of the item or service.

N18.7 The effectiveness of the control of quality shall beassessed by the purchaser at intervals consistent with the importance, complexity and quality of the item or service.

N45.2.13 § 11. QUALITY ASSURANCE RECORDSMeasures shall be established and implemented for the control of:a. Supplier-generated documents and records that are required to be submitted to the Purchaser or retained by the Supplier as specified by the procurement documents.b. Purchaser-generated quality related documents and

records.The collection, storage, and maintenance of quality

assurance records shall be in accordance with ANSI N45.2.9.Activities performed to verify conformance to requirements of procurement documents shall be recorded.

Source surveillances and inspections, audits, receiving inspections, nonconformances, dispositions, waivers, and corrective actions shall be documented.The Purchaser shall assure that his documentation is evaluated to determine the Supplier's quality assurance program effectiveness.Similar requirement.

NQA-1 further addresses records in Basic Requirement 17 and Supplement 17S-1.

6 CONTROL OF SUPPLIER GENERATED

DOCUMENTS N45.2 This documentary evidence shall be retained at thenuclear facility site and shall be sufficient to identify the specific requirements such as codes, standards, and specifications met by the purchased item.

N18.7 This documentary evidence shall be retrievable and Supplier generated documen ts shall be controlled, handled, and approved in accordance with established methods. Means shall be implemented to assure that the submittal of these documents is accomplished in accordance with the procurement document requirements.

Similar requirement.

05/21/04Control of Purchased Material, Equipment, (Items) and ServicesPage 10 of 22 CRITERION 7 ANSI N45.2 - ANSI N45.2.13 - ANSI N18.7 BASIC REQUIREMENT 7 NQA-1 1994 COMMENTSshall be sufficient to identify the specific requirementssuch as codes, standards and specifications met by the purchased item.

N45.2.13 § 6.3 Control of Supplier Generated Documents- The Purchaser and Supplier shall assure that established measures for the control, handling and approval of Supplier generated documents are implemented, and that the submittal time and frequency for these documents is accomplished in accordance with the procurement documents. These measures shall provide for the

acquisition, processing and recorded evaluation of

inspection and test data against acceptance criteria.These measures shall provide for the acquisition, processing, and recorded evaluation of technical, inspection, and test data against acceptance criteria.

7 CONTROL OF CHANGES IN ITEMS OR SERVICES N45.2.13 § 6.4 Control of Changes in items or Services -The Purchaser and Supplier shall assure that measures to control changes in procurement documents are established, implemented and documented, and are in

accordance, with ANSI N45.2 Section 7.The Purchaser and Supplier shall assure that measures to control changes in procurement documents are established, implemented, and documented and are in

accordance with this Part (Part I).Similar requirement.For NQA-1 this is primarily addressed by Basic Requirement 4 and Supplement 4S-1.

N45.2.13 § 10. ACCEPTANCE OF ITEM OR SERVICE 8 ACCEPTANCE OF ITEM OR SERVICE

8.1 General

N45.2 Where required by code, regulation, or contractrequirements, documentary evidence that items' conform to procurement requirements shall be available at the nuclear facility site prior to installation or use of such items.N18.7 Where required by code, regulation, or contractrequirements, documentary evidence that items conform to procurement requirements shall be available at the nuclear power plant site prior to installation or use of such items.

N45.2.13 § 10.1 General - The Purchaser shall establishthe method of acceptance of an item or service being furnished by the Supplier. Prior to offering the item or

service for acceptance, the Supplier shall verify that theitem or service being furnished complies with the procurement requirements. Where required by code, regulation or contract requirement, documentary evidence that items conform to procurement documents shall be

available at the nuclear power plant site prior to Methods shall be established for the acceptance of an item or service being furnished by the Supplier. Prior to offering the item or service for acceptance, the Supplier shall verify that the item or service being furnished complies with the procurement requirements. Where required by code, regulation, or contract requirement,documentary evidence that items conform to procurement documents shall be available at the nuclear facility site

prior to installation or use.Similar requirement.NRC Regulatory Position C.4 from

Reg. Guide 1.123 is addressed in NQA-1 § 8.2.3 by requiring receiving inspection to be performed in

accordance with established

procedures and instructions.

05/21/04Control of Purchased Material, Equipment, (Items) and ServicesPage 11 of 22 CRITERION 7 ANSI N45.2 - ANSI N45.2.13 - ANSI N18.7 BASIC REQUIREMENT 7 NQA-1 1994 COMMENTSinstallation or use of such items regardless of acceptancemethods.Reg. Guide 1.123 Regulatory Position C.

4. Section 10.1 of ANSI N45.2.13-1976 states that the Purchaser shall establish the method of acceptance of an item or service being furnished by the Supplier. In order for receiving inspection personnel to be aware of what methods of

acceptance are established, the applicable portion of the procurement document identifying the method of acceptance of an item or service, or other documents containing the same procurement document information, should be on hand.

8.2 Methods

of Acceptance N45.2 Where not precluded by other requirements, suchdocumentary evidence may take the form of written certifications of conformance which identify the requirements met by the items, provided means are available to verify the validity of such certifications.

N18.7 Where not precluded by other requirements, suchdocumentary evidence may take the form of written certifications of conformance which identify the requirements met by the items, provided means are available to verify the validity of such certifications.

N45.2.13 § 10.3 Methods of Acceptance, Selection andImplementation - Purchaser methods used to accept an item or service from a Supplier are source verification, receiving inspection, Supplier certificate of conformance, post installation test at the nuclear power plant site, or a combination thereof.Purchaser methods used to accept an item or related service from a Supplier shall be Supplier Certificate of Conformance, source verification, receiving inspection, or post-installation test at the nuclear facility site, or a combination thereof.Similar requirement.

N45.2.13 §10.2 Certificate of Conformance - Where notprecluded by other requirements, documentary evidence may take the form of written certificates of conformance which identify the requirements met by the items. Where certificates of conformance are used, the following minimum criteria shall be met:

Reg. Guide 1.123 Regulatory Position C.6 In addition tothe requirements of the standard, the guidelines (indicated by the verb "should") identified below are considered to

8.2.1 Certificate

of Conformance. When a Certificate of Conformance is used, the minimum criteria of (a) through (f) below shall be met.Similar requirement.The NRC Regulatory Position C.6 from Reg. Guide 1.123 has been

addressed in NQA-1.

05/21/04Control of Purchased Material, Equipment, (Items) and ServicesPage 12 of 22 CRITERION 7 ANSI N45.2 - ANSI N45.2.13 - ANSI N18.7 BASIC REQUIREMENT 7 NQA-1 1994 COMMENTShave sufficient safety importance to be treated the same asthe requirements of the standard. - c. Section 10.2 (a though f) - The guidelines that specify the minimum criteria for Certificates of Conformance.

N45.2.13 § 10.3.3 Acceptance by Supplier Certificate ofConformance. In certain procurement actions which do not involve direct inspection by the Purchaser, the Purchaser may accept an item or service from a Supplier based only on a Supplier's certificate of conformance that the specified requirements have been met. However, specific supplemental documentation, such as material certificates or reports of tests performed, may be required by procurement documents. Acceptance by this method is satisfactory when the item or service is of simple design and involves standard materials, processes and tests. Such items may be fabricated subject to selected qualification, sample, or batch testing to establish or maintain a minimum quality confidence level.

N45.2.13 § a. The certificate should identify the purchasedmaterial or equipment, such as by the purchase order number.(a) The certificate shall identify the purchased material or equipment, such as by the purchase order number.Similar requirement.

N45.2.13 § b. The certificate should identify the specificprocurement requirements met by the purchased material or equipment, such as codes, standards, and other specifications. This may be accomplished by including a list of the specific requirements or by providing, onsite, a copy of the purchase order and the procurement

specifications or drawings, together with a suitable certificate. The procurement requirements identified should include any approved changes, waivers, or deviations applicable to the subject material or equipment.(b) The certificate shall identify the specific procurementrequirements met by the purchased material or equipment, such as codes, standards, and other specifications. This may be accomplished by including a list of the specific requirements or by providing, on-site, a copy of the purchase order and the procurement specifications or

drawings, together with a suitable certificate. The procurement requirements identified shall include any

approved changes, waivers, or deviations applicable to thesubject material or equipment.Similar requirement.

N45.2.13 § c. The certificate should identify anyprocurement requirements that have not been met, together with an explanation and the means for resolving the nonconformances.(c) The certificate shall identify any procurement requirements that have not been met, together with an explanation and the means for resolving the nonconformances.Similar requirement.

N45.2.13 § d. The certificate should be attested to by a person who is responsible for this quality assurance function and whose function and position are described in (d) The certificate shall be signed or otherwise authenticated by a person who is responsible for this quality assurance function and whose function and Similar requirement.

05/21/04Control of Purchased Material, Equipment, (Items) and ServicesPage 13 of 22 CRITERION 7 ANSI N45.2 - ANSI N45.2.13 - ANSI N18.7 BASIC REQUIREMENT 7 NQA-1 1994 COMMENTSthe Purchaser's or Supplier's quality assurance program.position are described in the Purchaser's or Supplier'squality assurance program.

N45.2.13 § e. The certification system, including the procedures to be followed in filling out a certificate and the administrative Procedures for review and approval of the certificates, should be described in the Purchaser's or Supplier's quality assurance program.(e) The certification system, including the procedures to

be followed in filling out a certificate and the administrative procedures for review and approval of the certificates, shall be described in the Purchaser's or Supplier's quality assurance program.Similar requirement.

N45.2.13 § f. Means should be provided to verify thevalidity of Supplier certificates and the effectiveness of the certification system, such as during the performance of

audits of the Supplier or independent inspection or test of the items. Such verifications should be conducted by thePurchaser at intervals commensurate with the Supplier's past quality performance. (Section 7 of this standard provides requirements and guidance relative to the

conduct of source verification activities and receiving

inspections.)(f) Means shall be provided to verify the validity of

Supplier certificates and the effectiveness of the certification system, such as during the performance of

audits of the Supplier or independent inspection or test of the items. Such verification shall be conducted by the Purchaser at intervals commensurate with the Supplier's past quality performance.Similar requirement.

N45.2.13 § 7.3.1 Source Verification Activities. When planning requires Purchaser source surveillance, it shall be implemented to monitor, witness or observe activities.

Similarly, source inspection shall be implemented in accordance with plans to perform inspections, examinations, or tests at predetermined points. Source surveillance and inspection may require the assignment of personnel to a Supplier's facilities.

N45.2.13 § 10.3.1 Acceptance by Source Verification.Acceptance by source verification should be considered when the item or service is:a. vital to plant safety; orb. difficult to verify quality characteristics after delivery;

orc. complex in design, manufacture, and test.

The source verification activities should include but not be limited to the following as applicable:a. Documentation has been submitted as required and provides verification of approvals, material, applicable

inspections, and tests.

b. Fabrication procedures and processes have been

8.2.2 Source

Verification. When source verification is used, it shall be performed at intervals consistent with the importance and complexity of the item or service, and it shall be implemented to monitor, witness, or observe activities. Source verification shall be implemented in accordance with plans to perform inspections, examinations, or tests at predetermined points. Upon Purchaser acceptance of source verification, documented

evidence of acceptance shall be furnished to the receivingdestination of the item, to the Purchaser, and to the

Supplier.Similar requirement.

05/21/04Control of Purchased Material, Equipment, (Items) and ServicesPage 14 of 22 CRITERION 7 ANSI N45.2 - ANSI N45.2.13 - ANSI N18.7 BASIC REQUIREMENT 7 NQA-1 1994 COMMENTSapproved and complied with and the applicable qualifications, process records, and certifications are

available.c. Components and assemblies have been inspected, examined, and tested as required and applicable

inspection, test and certification records are available.d. Nonconformances have been dispositioned as required.e. Components and assemblies are cleaned, preserved, packed and identified in accordance with specifiedrequirements.Upon Purchaser acceptance by source verification, documented evidence of acceptance shall be furnished to the receiving destination of the item, to the Purchaser, and

to the Supplier.

N45.2.13 § 7.2.2 Receiving Inspection Planning. Thereceiving inspection plans shall identify the characteristics to be verified and documentation to be reviewed at

receiving inspection. For characteristics to be considered

during receiving inspection, see ANSI N45.2.2.

N45.2.13 § 7.3.2 Receiving Inspection. When planning requires Purchaser receiving inspection, it shall be implemented and coordinated with source verifications performed. During receiving inspection, emphasis shall be placed on assuring that items have not sustained damage in shipment that would influence subsequent fabrication, construction, installation, or end use. Sampling may be

utilized during receiving inspection when conducted in

accordance with established procedures or recognized standards. Receiving inspection measures shall include provisions for receiving documentation (such as drawings, certifications, test results and other materials) offered as objective evidence in satisfaction of requirements. These measures shall also include provisions for dispositioning (i.e., accept, reject or hold) and handling of items received and services performed. See ANSI N45.2.2 for additional requirements.

N45.2.13 § 10.3.2 Acceptance by Receiving Inspection.Acceptance solely by receiving inspection is satisfactory when the items or services are

8.2.3 Receiving

Inspection. When receiving inspection is used, purchased items shall be inspected as necessary toverify conformance to specified requirements, taking into

account source verification and audit activities and the demonstrated quality performance of the Supplier.

Receiving inspection shall be performed in accordance

with established procedures and inspection instructions, to verify by objective evidence such features as proper configuration; identification; dimensional, physical, and other characteristics; freedom from shipping damage; and

cleanness. Receiving inspection shall be coordinated with review of Supplier documentation when procurement documents require such docum entation to be furnished prior to receiving inspection.Similar requirement.

Within NQA-1, Subpart 2.2 is commensurate with ANSI N45.2.2.NRC Regulatory Position C.6 from

Reg. Guide 1.123 related to N45.2.13,

§ 10.3.2 is addressed in the wording

of NQA-1.

05/21/04Control of Purchased Material, Equipment, (Items) and ServicesPage 15 of 22 CRITERION 7 ANSI N45.2 - ANSI N45.2.13 - ANSI N18.7 BASIC REQUIREMENT 7 NQA-1 1994 COMMENTSa. relatively simple and standard in design, manufacture, and test; andb. adaptable to standard or automated inspections and/or tests of the end product to verify quality characteristics after delivery; and

c. such that receiving inspection does not require operations which could adversely affect the integrity, function, or cleanness of the item.

Receiving inspection should be coordinated with review ofSupplier documentation when procurement documents require such documentation to be furnished prior to

receiving inspection.

Reg. Guide 1.123 Regulatory Position C.6 In addition tothe requirements of the standard, the guidelines (indicated by the verb "should") identified below are considered to have sufficient safety importance to be treated the same as the requirements of the standard. - d. Section 10.3.2 - The guideline concerning acceptance by receiving inspection.

N45.2.13 § 10.3.4 Acceptance by Post Installation Test atthe Nuclear Power Plant Site. Acceptance by this method is satisfactory when performed following the accomplishment of at least one of the preceding methods

and whena. it is difficult to verify the quality characteristics of the item without it being installed and in use; orb. the item requires an integrated system checkout or test with other items to verify its quality characteristics; orc. the item cannot demonstrate its ability to perform its

intended function except when in use.Post installation test requirements and acceptance documentation should be mutually established by the

Purchaser and Supplier.

Reg. Guide 1.123 Regulatory Position C.6 In addition tothe requirements of the standard, the guidelines (indicated by the verb "should") identified below are considered to have sufficient safety importance to be treated the same as the requirements of the standard. - e. Section 10.3.4 - The guidelines concerning the establishment of post-installation test requirements and acceptance 8.2.4 Post-Installation Testing. When post-installation testing is used, post-installation test requirements and acceptance documentation shall be mutually established by the Purchaser and Supplier.Similar requirement.

NQA-1 does not address the reasons why a post-installation test would be chosen as the method for acceptance of an item. This is left to the implementing program to determine

when to use this testing.

05/21/04Control of Purchased Material, Equipment, (Items) and ServicesPage 16 of 22 CRITERION 7 ANSI N45.2 - ANSI N45.2.13 - ANSI N18.7 BASIC REQUIREMENT 7 NQA-1 1994 COMMENTSdocumentation.

8.3 Acceptance

of Services Only N45.2.13 § 10.3.5 Acceptance of Services Only. Theguidelines outlined in Section 10.3 above primarily deal with hardware items and related services. In certain cases involving procurement of services only, such as third party

inspection; engineering and consulting services; and installation, repair, overhaul or maintenance work; the Purchaser may accept the service by any or all of the following methods:

a. Technical verification of data produced.b. Surveillance and/or audit of the activity.c. Review of objective evidence for conformance to the procurement document requirements such as certifications, stress reports, etc.In certain cases involving procurement of services only, such as third party inspection; engineering and consulting services; and installation, repair, overhaul, or maintenance

work, the Purchaser shall accept the service by any or allof the following methods: (a) technical verification of data produced;(b) surveillance and/or audit of the activity;(c) review of objective evidence for conformance to the procurement document requirements such as certifications, stress reports, etc.Similar requirement.

N45.2.13 § 8. CONTROL OF NONCONFORMANCES 9 CONTROL OF SUPPLIER NONCONFORMANCES N45.2.13 § 8.1 General - The Purchaser and Supplier shallestablish and document measures for the identification, control, and disposition of items and services that do not meet procurement document requirements.The Purchaser and Supplier shall establish and document methods for disposition of items and services that do not meet procurement documentation requirements.Similar requirement. NQA-1 also addresses Nonconformances under Basic Requirement 15 and Supplement 15S-1.

8.2 DispositionThese

measures shall contain provision for the following:These methods shall contain provision for (a) through (e)

below:Similar requirement.a. Review of nonconforming items.(a) evaluation of nonconforming items;Similar requirement.b. Submittal of nonconformance notice to Purchaser by Supplier as directed by the Purchaser. These submittals shall include Supplier recommended disposition (i.e.,

"use-as-is" or "repair") and technical justification.

Nonconformances to the procurement requirements or Purchaser approved documents and which consist of oneor more of the following shall be submitted to the Purchaser for approval of the recommended disposition:1) Technical or material requirement is violated2) Requirement in Supplier documents, which have been approved by the Purchaser, is violated.3) Nonconformance cannot be corrected by continuation of the original manufacturing process or by rework.4) The item does not conform to the original requirement even though the item can be restored to a condition such (b) submittal of nonconformance notice to Purchaser by Supplier as directed by the Purchaser. These submittals shall include Supplier-recommended disposition (e.g., use-

as-is or repair) and technical justification.

Nonconformances to the procurement requirements or Purchaser-approved documents, which consist of one ormore of the following, shall be submitted to the Purchaser for approval of the recommended disposition:(1) technical or material requirement is violated;(2) requirement in Supplier documents, which has been approved by the Purchaser, is violated;(3) nonconformance cannot be corrected by continuation of the original manufacturing process or by rework;(4) the item does not conform to the original requirement even though the item can be restored to a condition such Similar requirement.

05/21/04Control of Purchased Material, Equipment, (Items) and ServicesPage 17 of 22 CRITERION 7 ANSI N45.2 - ANSI N45.2.13 - ANSI N18.7 BASIC REQUIREMENT 7 NQA-1 1994 COMMENTSthat the capacity of the item to function is unimpaired.that the capability of the item to function is unimpaired;c. Purchaser disposition of Supplier recommendation.(c) Purchaser disposition of Supplier recommendation;Similar requirement.

d. Verification of disposition.(d) verification of the implementation of the disposition;Similar requirement.e. Maintenance of records of Supplier nonconformances.(e) maintenance of records of Supplier-submittednonconformances.Similar requirement.

10 COMMERCIAL GRADE ITEMSWhere the design utilizes commercial grade items, the following requirements are an acceptable alternate to other requirements of this Supplement, except as noted in (b) below and the requirements of Supplement 4S-1.This is a new set of requirements not previously in the N45.2 series standards. The company will commit to meeting Generic Letter 89-02 and

EPRI NP-5652 in lieu of these requirements.(a) The commercial grade item is identified in an approved design output document. An alternate commercial grade item may be applied, provided the cognizant design

organization provides verification that the alternate commercial grade item will perform the intended function and will meet design requirements applicable to both the replaced item and its application.(b) Source evaluation and selection, where determined necessary by the Purchaser based on complexity and importance to safety, shall be in accordance with para. 3.1 of this Supplement.(c) Commercial grade items shall be identified in the purchase order by the manufacturer's published product description (for example, catalog number).(d) After receipt of a commercial grade item, the Purchaser shall determine that:(1) damage was not sustained during shipment;(2) the item received was the item ordered;(3) inspection and/or testing is accomplished, as required by the Purchaser, to assure conformance with the manufacturer's published requirements;(4) documentation, as applicable to the item, was received

and is acceptable.

N45.2.13 § 1.2 Responsibility

1.2.1 General

The responsibilities for Purchaser and Supplier are NQA-1 addresses responsibilities in a general sense within the Introduction,

§3, of Part I.

05/21/04Control of Purchased Material, Equipment, (Items) and ServicesPage 18 of 22 CRITERION 7 ANSI N45.2 - ANSI N45.2.13 - ANSI N18.7 BASIC REQUIREMENT 7 NQA-1 1994 COMMENTS identified with recognition that an organization can be either a Purchaser or a Supplier depending upon the level of procurement. However, for any given procurement

action the organization is one or the other and this standard applies accordingly. For example, an organization may be a supplier but may have to purchase items or services from a subtier level.

N45.2.13 § 1.2.2 Purchaser's Responsibilitya. Establishment and implementation of a procurementcontrol process consistent with the requirements and

guidelines of this standard.b. Incorporation of quality assurance program requirements, appropriate to the scope of work, into procurement documents.c. Evaluation of Supplier's quality assurance program to assure that it is appropriate and satisfies the requirements for the items or services being purchased.d. Where interfacing, but separate, procurement actions are initiated by a single Purchaser to purchase the design, manufacture, shop assembly and test, field installation and field test of equipment or a system, the single Purchaser shall assure that the quality assurance requirements incorporated in separate procurement documents, in conjunction with the Purchaser's quality assurance program, will collectively satisfy the requirements of ANSI N45.2 and applicable supplementary standards as applicable to the total items and services procured. An example of this is the case where one Supplier has responsibility for design, manufacture, shop assembly and test; another Supplier has responsibility for field assembly; and a third Supplier has responsibility for field tests.

NQA-1 addresses responsibilities in a

general sense within the Introduction,

§3, of Part I.

N45.2.13 § 1.2.3 Supplier's Responsibilitya. Establish and implement a documented qualityassurance program that complies with procurement document requirements.b. Permit Purchaser review of Supplier's quality assurance program and its implementation.c. Incorporate appropriate quality assurance program requirements in subtier procurement documents.

NQA-1 addresses responsibilities in a

general sense within the Introduction,

§3, of Part I.

05/21/04Control of Purchased Material, Equipment, (Items) and ServicesPage 19 of 22 CRITERION 7 ANSI N45.2 - ANSI N45.2.13 - ANSI N18.7 BASIC REQUIREMENT 7 NQA-1 1994 COMMENTS N45.2.13 § 1.3 Definitions The following definitions are provided to assure a uniformunderstanding of selected terms as they are used in this standard. Other terms and their definitions are contained in

ANSI N45.2.10.The following definitions are from NQA-1, Part I, Introduction NQA-1 contains definitions in the

Introduction to Part I.

N45.2.13 Designated Representative - An individual ororganization authorized by the Purchaser to perform functions in the procurement process.

Not defined in NQA-1.

N45.2.13 Procurement Document - Purchase requisitions, purchase orders, drawings, contracts, specifications or instructions used to define requirements for purchase.Procurement document - purchase requisitions, purchase

orders, drawings, contracts, specifications, or instructions used to define requirements for purchaseSame definition.

N45.2.13 Purchaser - The organization responsible forestablishment of procurement requirements and for issuance, administration, or both, of procurement documents.Purchaser - the organization responsible for establishment of procurement requirements and for issuance or administration, or both, of procurement documentsSimilar definition.

N45.2.13 Quality Assurance Program Requirements -Those individual requirements listed in ANSI N45.2

which when invoked in total or in part establish the requirements of a quality assurance program.

Not defined in NQA-1.

N45.2.13 Quality Assurance R ecords - Those recordswhich furnish documentary evidence of the quality of items and of activities affecting quality.Quality assurance record - a completed document that furnishes evidence of the quality of items and/or activities

affecting qualitySimilar definition.

N45.2.13 Right of Access - The right of a Purchaser ordesignated representative to enter the premises of a

Supplier for the purpose of inspection, surveillance, or quality assurance audit.

Right of access - the right of a Purchaser or designated representative to enter the premises of a Supplier for the purpose of inspection, surveillance, or quality assurance

auditSimilar definition.

N45.2.13 Services - The performance by a Supplier of activities such as design, fabrication, inspection, non-destructive examination, repair, or installation.Service - the performance of activities such as design, fabrication, inspection, nondestructive examination, repair, or installationSimilar definition.

N45.2.13 Subtier Procurement - Procurement by aSupplier from a subsupplier of items or services Not defined in NQA-1. Covered by

the definition of Supplier.

N45.2.13 Supplier - Any individual or organization whofurnishes items or services to a procurement document. It includes the terms Vendor, Seller, Contractor, Subcontractor, Fabricator, Cons ultant, and subtier levels.Supplier - any individual or organization who furnishesitems or services in accordance with a procurement document. An all-inclusive term used in place of any of

the following: vendor, seller, contractor, subcontractor, fabricator, consultant, a nd their subtier levels.Similar definition.

N45.2.13 Surveillance - The physical presence to monitorby observation the designated activities to assure that they Surveillance - the act of monitoring or observing to verify whether an item or activity conforms to specified Similar definition.

05/21/04Control of Purchased Material, Equipment, (Items) and ServicesPage 20 of 22 CRITERION 7 ANSI N45.2 - ANSI N45.2.13 - ANSI N18.7 BASIC REQUIREMENT 7 NQA-1 1994 COMMENTSare performed in a specified manner.requirements N45.2.13 § 1.4 Referenced DocumentsDocuments that are required to be included as part of this standard are identified at the point of reference and

described in Section 13 of this standard. The issue or edition of the referenced document that is required will be

specified either at the point of reference or in Section 13

of this standard unless otherwise specified in the procurement document.

Reg. Guide 1.123 Regulatory Position C.1.

Section 1.4 ofANSI N45.2.13-1976 states that other documents that are

required to be included as part of this standard will be identified at the point of reference and described in Section 13 of the standard. The specific applicability of these listed documents has been or will be covered separately in other regulatory guides or in Commission

regulations where appropriate.No similar statement in this section of NQA-1. As a general statement, will

need to include in the QAPD that any referenced documents or standards are

considered guidance unless stated

otherwise in the QAPD.

N45.2.13 § 7.3.1 ¶ 2 - When conformance to procurementrequirements is verified by audit, such audits shall be conducted in accordance with established methods.Auditing requirements are addressed in NQA-1, Basic Requirement 18, and Supplement 18S-1.

N45.2.13 § 7.4 Measuring and Test Equipment7.4.1 Selection. Inspection, examination, and testingequipment utilized to implement the requirements of this standard shall be selected to have accuracy and tolerance sufficient to determine conformance to specified requirements.7.4.2 Calibration and Control. As appropriate, measuring and test equipment shall be adjusted and calibrated at prescribed intervals against certified equipment having

known valid relationships to nationally recognized standards. If no standards exist, the basis for calibration shall be documented. Records shall be maintained and equipment suitably marked to indicate calibration status or the records shall be traceable to the equipment. When inspection, measuring and test equipment are found to be out of calibration, an evaluation shall be made and documented of the validity of previous inspection or test results and of the acceptability of items previously NQA-1 addresses measuring and test equipment in Basic Requirement 12, Supplement 12S-1, and Subpart 2.16.

05/21/04Control of Purchased Material, Equipment, (Items) and ServicesPage 21 of 22 CRITERION 7 ANSI N45.2 - ANSI N45.2.13 - ANSI N18.7 BASIC REQUIREMENT 7 NQA-1 1994 COMMENTS inspected or tested.

N45.2.13 § 7.5 Personnel QualificationsPersonnel responsible for performing verification activities shall be qualified in accordance with ANSI

N45.2.6 as applicable.

NQA-1 addresses personnel qualifications in Basic Requirement 2, Supplement 2S-1 (inspection and test personnel), and Supplement 2S-3 (audit personnel).

N45.2.13 § 7.6 Reporting Measures shall be established to provide for the reportingof activities performed to verify conformance to requirements of procurement documents. These measures

shall include reporting of source surveillances and

inspections, audits, receiving inspections, nonconformances, dispositions, waivers, and corrective

actions.In addition, the Purchaser shall assure that these reportsare evaluated to determine the Supplier's quality assurance program effectiveness.NQA-1 does not specifically address the reporting of these items in a

separate paragraph of this section (Basic Requirement 7 and Supplement 7S-1). However, reporting of these type documents are

addressed under the respective sections of the Supplement. Reporting is also addressed in the Requirement and Supplemental sections that would govern these programs, such as

Inspections, Tests, and Audits that relate to NQA-1 Requirements 10, 11, and 18.N45.2.13 § 9. CORRECTIVE ACTION

9.1 GeneralThe

Purchaser shall establish and document measures thatdescribe the method for the identification of and timely corrective action for conditions adverse to quality which occur during the procurement process and are the responsibility of the Purchaser.

9.2 Significant

conditions In the case of significant conditions adverse to quality which may arise during the procurement process, the Purchaser's measures shall describe the method used to:a. Identify and document deviations andnonconformances.b. Review and evaluate the conditions to determine the cause, extent, and measures need ed to correct and prevent recurrence.

c. Report the conditions and corrective action to the appropriate levels of management.d. Assure corrective action is implemented and maintained NQA-1 addresses corrective action in Basic Requirement 16.

05/21/04Control of Purchased Material, Equipment, (Items) and ServicesPage 22 of 22 CRITERION 7 ANSI N45.2 - ANSI N45.2.13 - ANSI N18.7 BASIC REQUIREMENT 7 NQA-1 1994 COMMENTSas necessary.

9.3 Verification

- The Purchaser's corrective actionmeasures shall include verification of implementation of Supplier corrective action system. These measures shall determine that conditions adverse to quality such as deficiencies, deviations, defective items and nonconformances have had corrective action implemented and maintained as necessary.

Reg. Guide 1.123 Regulatory Position C.3 Section 9.3 ofANSI N45.2.13-1976 states, "The Purchaser'sCorrective action measures shall include verification of implementation of Supplier's corrective action system."

The Purchaser should verify the implementation of the Supplier's corrective action system when such a system is required, but this verification need not be included as part of the Purchaser's corrective action measures. While Section 9.0 of ANSI N45.2.13-1976 addresses elements of the Purchaser's corrective action system, these same elements are applicable to the Supplier's corrective actionsystem when one is required.

N45.2.13 § 12. AUDIT OF PROCUREMENT PROGRAMPeriodic or random audits shall be performed to verify compliance with procurement activities described in thisstandard. The scope of planned auditing activity may

cover individual operations, events, processes, or the complete quality assurance program. When deemed necessary by the Purchaser, audits of subtier Suppliers shall be carried out to assure that their quality assurance programs on procurement adequately translate the necessary requisites of the governing procurement documents to the items or services involved. The audits

shall be conducted in accordance with established methods.NQA-1 addresses all Quality

Assurance auditing under Basic Requirement 18 and Supplement

18S-1.

05/19/04 Identification and Control of Materials, Parts, and Components (Items)Page 1 of 3 CRITERION 8ANSI 45.2-1977, § 9 /N18.7-1976 § 5.2.13.3BASIC REQUIREMENT 8 NQA-1994 COMMENTS N45.2 - Measures shall be established and documented forthe identification and control of materials, parts, and components including partially fabricated subassemblies.

N18.7 - Measures shall be provided for the identificationand control of materials, parts, and components including partially fabricated subassemblies.Controls shall be established to assure that only correct and accepted items are used or installed.Similar requirement.

N45.2 - When codes, standards, or specifications requiretraceability of materials, parts, or components to specific inspection or test records, the program shall be designed to provide such traceability.

N18.7 - When codes, standards or specifications requiretraceability of materials, parts or components to specific inspection or test records, the program shall be designed to provide such traceability.Identification shall be maintained on the items or in documents traceable to the items, or in a manner which assures that identification is established and maintained.Similar requirement. The additional information in the Basic Requirement is similar to that

contained later in the N45.2 and

N18.7 text.

SUPPLEMENT 8S-1 SUPPLEMENTARY REQUIREMENTS FOR IDENTIFICATION AND

CONTROL OF ITEMS 1 GENERALThis Supplement provides amplified requirements foridentification and control of items.It supplements the requirements of Basic Requirement 8 of

this Part (Part 1) and shall be used in conjunction with that Basic Requirement when and to the extent specified by the

organization invoking this Part (Part l).

2 IDENTIFICATION METHODS 2.1 Item Identification N45.2 These measures shall provide for assuring that onlycorrect and accepted items are used and installed, and relating an item of production (batch, lot, component, part) at any stage, from initial receipt through fabrication, installation, repair or modifica tion, to an applicable drawing,specification, or other pertinent technical document.

N18.7 - These procedures shall be implemented to provideinsurance that only correct and accepted items are used and installed, and relating an item of production (batch, lot, component, part) at any stage, from initial receipt through fabrication, installation, repair or modification, to an

applicable drawing, specification, or other pertinent Items of production (batch, lot, component, part) shall be identified from the initial receipt and fabrication of the items

up to and including installation and use. This identification shall relate an item to an applicable design or other pertinent specifying document.Similar requirements.

05/19/04 Identification and Control of Materials, Parts, and Components (Items)Page 2 of 3 CRITERION 8ANSI 45.2-1977, § 9 /N18.7-1976 § 5.2.13.3BASIC REQUIREMENT 8 NQA-1994 COMMENTStechnical document.

2.2 Physical

Identification N45.2.- Physical identification shall be used to themaximum extent possible.

N18.7 - Physical identification shall be used to themaximum extent possible. Physical identification shall be used to the maximum extent

possible.Same requirement.

N45.2 - Where physical identification is either impractical orinsufficient, physical separation, procedural control, or other appropriate means shall be employed.

N18.7 - Where physical identification is either impractical orinsufficient, physical separation, procedural control or other appropriate means shall be employed.Where physical identification on the item is either impractical or insufficient, physical separation, procedural control, or other appropriate means shall be employed.Same requirement.

2.3 Markings

N45.2 - Identification may be either on the item or onrecords traceable to the item, as appropriate. Where identification marking is employed, the marking shall be clear, unambiguous, and indelible , and shall be applied insuch a manner as not to affect the function of the item.

N18.7 - Identification may be either on the item or onrecords traceable to the item, as appropriate. Where identification marking is employed, the marking shall be clear, unambiguous and indelible , and shall be applied insuch a manner as not to affect the function of the item. Identification markings, when used, shall be applied using materials and methods which provide a clear and legible identification and do not detrimentally affect the function or service life of the item.Similar requirement, NQA-1

includes affect on service life of the component as well as function.

(Note: Markings are covered in more detail in NQA-1, Subpart 2.2

that corresponds with ANSI

N45.2.2. Addressed in a separate

table.)N45.2 - Markings shall be transferred to each part of an item when subdivided and shall not be obliterated or hidden bysurface treatment or coatings unless other means of

identification are substituted.

N18.7 - Markings shall be transferred to each part of an item when subdivided and shall not be obliterated or hidden bysurface treatment or coatings unless other means of

identification are substituted.

Markings shall be transferred to each part of an identified item when subdivided and shall not be obliterated or hiddenby surface treatment or coatings unless other means of

identification are substituted.Similar requirement.

3 SPECIFIC REQUIREMENTS

3.1 Identification

and Traceability of Items N45.2, ¶ 3 -

When codes, standards, or specificationsrequire traceability of materials, parts, or components to specific inspection or test records, the program shall be designed to provide such traceability.

N18.7, ¶ 3 - When codes standards or specifications require When specified by codes, standards, or specifications thatinclude specific identification or traceability requirements (such as identification or traceability of the item to applicable specification and grade of material; heat, batch, lot, part, or serial number; or specified inspection, test, or Similar requirement. NQA-1 provides examples "such as identification or traceability-. test, or other records."

05/19/04 Identification and Control of Materials, Parts, and Components (Items)Page 3 of 3 CRITERION 8ANSI 45.2-1977, § 9 /N18.7-1976 § 5.2.13.3BASIC REQUIREMENT 8 NQA-1994 COMMENTStraceability of materials, parts or components to specificinspection or test records, the program shall be designed to provide such traceability.other records), the program shall be designed to provide such identification and traceability control.3.2 Limited Life ItemsWhere specified, items having limited calendar or operating life or cycles shall be identified and controlled to preclude use of items whose shelf life or operating life has expired.New requirement. Already factored into Dominion's administrative

controls.3.3 Maintaining Identification of Stored ItemsProvisions shall be made for the control of item

identification consistent w ith the planned duration and conditions of storage, such as:(a) provisions for maintenance or replacement of markings and identification records due to damage during handling or

aging;(b) protection of identifications on items subject to excessive

deterioration due to environmental exposure;(c) provisions for updating existing plant records.Similar requirement to N45.2.2, § 6.4.1 in that an inspection would identify the need to correct these types of deficiencies.

05/17/04 Control of Special Processes / Control of ProcessesPage 1 of 3 CRITERION 9 ANSI 45.2 §10/ANSI N18.7 § 5.2.18 BASIC REQUIREMENT 9 NQA-1-1994 COMMENTS Overall notes:

NQA 1983 and 1994 leave the word Special out of the title. The text

does address special processes.The requirements of N45.2 and ANSI N18.7 are similar in nature to that expounded on in Supplement 9S-1.

Therefore, the specific wording from

these standards is not repeated over and over next to the similar statements

of NQA-1.N45.2 Measures shall be established and documented toassure that special processes, - are accomplished under

controlled conditions in accordance with applicable codes, standards, specifications, criteria, and other special requirements, -

N18.7 5.2.18 Measures shall be established anddocumented to assure that special processes, accomplished

under controlled conditions in accordance with applicable

codes, standards, specifications, criteria, and other special requirements, -Processes affecting quality of items or services shall be

controlled.Similar requirements for controlling processes, but NQA-1 doesn't limit

the processes at this point to those that are deemed special processes.

N45.2 Measures shall be established and documented to assure that special processes, including welding, heat treating, cleaning, and nondestructive examination, are accomplished under controlled conditions in accordance

with applicable codes, standards, specifications, criteria, and other special requirement s, using qualified personnel and procedures.

N18.7 5.2.18 Special processes are those that requireinterim inprocess controls in addition to final inspection to assure quality including such processes as welding, heat treating, chemical cleaning, and nondestructive examination.Special processes that control or verify quality, such as

those used in welding, heat treating, and nondestructive examination, shall be performed by qualified personnel using qualified procedures in accordance with specified requirements.

ANSI N18.7 defines special processes and includes chemical cleaning as a

special process. (Will address within

the text of the QAPD, Section 9)

SUPPLEMENT 9S-1 SUPPLEMENTARY REQUIREMENTS FOR CONTROL OF PROCESSES 1 GENERALThis Supplement provides amplified requirements for control of processes.

05/17/04 Control of Special Processes / Control of ProcessesPage 2 of 3 CRITERION 9 ANSI 45.2 §10/ANSI N18.7 § 5.2.18 BASIC REQUIREMENT 9 NQA-1-1994 COMMENTSIt supplements the requirements of Basic Requirement 9 of this Part (Part 1) and shall be used in conjunction with that Basic Requirement when and to the extent specified by the

organization invoking this Part (Part 1).

2 PROCESS CONTROL N45.2 Measures shall be established and documented toassure that special processes, - are accomplished - using

qualified - procedures.

N18.7 5.2.18 Measures shall be established anddocumented to assure that special processes, - use

qualified - procedures.Processes shall be controlled by instructions, procedures, drawings, checklists, travelers, or other appropriate means.Similar requirements.

N45.2 Measures shall be established and documented toassure that special processes, - are accomplished under

controlled conditions -.

N18.7 5.2.18 Measures shall be established anddocumented to assure that special processes, accomplished

under controlled conditions -

use qualified personnel and procedures.These means shall assure that process parameters are controlled and that specified environmental conditions are maintained.Similar requirements.

3 SPECIAL PROCESSES Each special process shall be performed in accordance with appropriate instructions wh ich include or reference procedure, personnel, and equipment qualificationrequirements.

Procedure adherence is addressed in

Section 5 of the QAPD.

3.1 ResponsibilityIt

is the responsibility of the organization performing the

special process to adhere to the approved procedures and

processes.

Procedure adherence is currently

addressed in the QA Standards related to Criterion 5. Similar requirements

exist.N45.2 Qualification of personnel, procedures, andequipment shall comply with the requirements of

applicable codes and standards.

N18.7 5.2.18 Qualification of personnel, procedures, andequipment shall comply with the requirements of

applicable codes and standards.

3.1.1 Qualification

of personnel, procedures, and equipment shall comply with specified requirements.Similar requirements.

05/17/04 Control of Special Processes / Control of ProcessesPage 3 of 3 CRITERION 9 ANSI 45.2 §10/ANSI N18.7 § 5.2.18 BASIC REQUIREMENT 9 NQA-1-1994 COMMENTS N45.2 Measures shall be established and documented toassure that special processes, - are accomplished under

controlled conditions -.

N18.7 5.2.18 Measures shall be established anddocumented to assure that special processes, accomplished

under controlled conditions -3.1.2 Conditions necessary for accomplishment of the

process shall be included in procedures or instructions.

These conditions shall include proper equipment, controlled parameters of the process, and calibration requirements.Similar requirements.

3.2 Acceptance

CriteriaThe requirements of applicable codes and standards, including acceptance criteria for the process, shall be

specified or referenced in the procedures or instructions.

Acceptance criteria currently

addressed in the QA Standards related to Criterion 5. Similar requirements

exist.3.3 Records N45.2 - Documentation shall be maintained for currentlyqualified personnel, processes, or equipment in accordance with the requirements of pertinent codes and standards.

N18.7 - 5.2.12 requires provisions "be made for preparation and retention of plant records as appropriate."Records shall be maintained as appropriate for the currently qualified personnel, processes, and equipment of

each special processSimilar requirements.

3.4 Special

Requirements N45.2 For special processes not covered by existing codesor standards, or where item quality requirements exceed the requirements of established codes or standards, the necessary qualifications of personnel, procedures, or equipment shall be defined.

N18.7 For special processes not covered by existing codesor standards, or where item quality requirements exceed the requirements of established codes or standards, the necessary qualifications of personnel, procedures, or equipment shall be defined.For special processes not covered by existing codes and standards or where quality requirements specified for an item exceed those of existing codes or standards, the necessary requirements for qualifications of personnel, procedures, or equipment shall be specified or referenced

in the procedures or instructions.Similar requirements.

05/17/04InspectionPage 1 of 6 CRITERION 10 ANSI N45.2-77/ANSI N18.7-76 BASIC REQUIREMENT 10 NQA-1 1994 COMMENTS N45.2 § 11, N18.7 § 5.2.17 N45.2, ¶ 1 A program for inspection of activities affectingquality shall be established and executed by or for the organization performing the activity to verify conformance to the documented instructions, procedures, and drawings for accomplishing the activity.

N45.2, ¶ 2 Examinations, measurements, or tests of itemsprocessed shall be performed for each work operation where necessary to assure quality.

N18.7, ¶ 1 A program for inspection of activities affectingsafety shall be established and executed by or for the organization performing the activity to verify conformance with applicable documented instructions, procedures, and

drawings.¶ 2 Inspections, examinations, measurements, or tests ofmaterial, products, or activities shall be performed for each work operation where necessary to assure quality.Inspections required to verify conformance of an item or activity to specified requirements shall be planned and

executed.Similar requirement.

N18.7, ¶ 4 Inspections of safety-related activities shall beperformed in accordance with approved written procedures, which set forth the requirements and acceptance limits and specify the inspection

responsibilities.Characteristics to be inspected and inspection methods to be employed shall be specified.Similar requirement.

N18.7, § 5.3.10, ¶ 1 Test and inspection results shall bedocumented -Inspection results shall be documented.Similar requirement.

N45.2 ¶ 1 Inspection activities to verify the quality ofwork shall be performed by appropriately trained personsother than those who performed the activity being

inspected.

N18.7 ¶ 2 Such inspections shall be performed byqualified individuals other than those who performed or directly supervised the activity being inspected.These independent inspections, i.e., those performed by

individuals not assigned first-line supervisory responsibility for the conduct of the work, are not intended to dilute or replace the clear responsibility of first-line supervisors for the quality of work performed under their

supervision.Inspection for acceptance shall be performed by persons other than those who performed or directly supervised the

work being inspected.Similar requirement. NQA-1 and N18.7 both specify that it should not be those who preformed the activity or directly supervised the activity (work)

being inspected. N45.2 addresses this

below.N18.7, ¶ 6 -

The owner organization shall evaluateNot specifically addressed by NQA-1.

05/17/04InspectionPage 2 of 6 CRITERION 10 ANSI N45.2-77/ANSI N18.7-76 BASIC REQUIREMENT 10 NQA-1 1994 COMMENTS inspection results along with test results (see Section5.2.19) to determine whether the individual inspection and test programs demonstrate that the plant can be operated safely and as designed.

Addressed within the QAPD as an inspection program function subject to

audit.SUPPLEMENT 1OS-1 SUPPLEMENTARY REQUIREMENTS FOR INSPECTION 1 GENERALThis Supplement provides amplified requirements forinspection of items and activities.It supplements the requirements of Basic Requirement 10

of this Part (Part I) and shall be used in conjunction with that Basic Requirement when and to the extent specified by

the organization invoking this Part (Part I).

2 INSPECTION REQUIREMENTS N18.7, ¶ 4 Information concerning inspection shall beobtained from the related design drawings, specifications and/or other controlled documents.Inspection requirements and acceptance criteria shall include specified requirements contained in the applicable design documents or other pertinent technical documents approved by the responsib le design organization.Similar requirement.

N18.7, ¶ 4 Inspections of safety-related activities shall beperformed in accordance with approved written

procedures, -

N18.7, § 5.3.10, ¶ 1 Test and inspection results shall bedocumented -

Inspection activities shall be documented and controlled by instructions, procedures, drawings, checklists, travelers, or other appropriate means.Similar requirement.NQA-1 allows use of documents other

than procedures to control the

inspection.

3 PERSONNEL

3.1 Reporting

Independence N45.2, ¶ 1 - Such persons shall not report directly to theimmediate supervisors who are responsible for the work

being inspected.

N18.7, ¶ 2 -

Inspection of operating activities (workfunctions associated with normal operation of the plant, routine maintenance, and certain technical services routinely assigned to the onsite operating organization) may be conducted by second-line supervisory personnel orby other qualified personne l not assigned first-linesupervisory responsibility for conduct of the work.Inspection personnel shall not report directly to the immediate supervisors who are responsible for performing

the work being inspected.Similar requirement, but NQA-1 adds a requirement for inspectors to not report to the immediate supervisor for

the work. (consistent with N45.2)

Current VA practice is to allow persons to perform inspections who were not performing the work, but who report directly to the immediate

supervisor responsible for the work

with a provision that, during the inspection period, they are reporting

through the organization responsible for the inspection program. The 05/17/04InspectionPage 3 of 6 CRITERION 10 ANSI N45.2-77/ANSI N18.7-76 BASIC REQUIREMENT 10 NQA-1 1994 COMMENTS QAPD, Appendix C, contains the following clarification: "Where quality verification inspections at operating facilities are performed by the Maintenance group, to meet the independence requirements of NQA-1, Supplement 10S-1, Section 3.1, the inspectors report to the Facility Safety

and Licensing organization while performing the inspection."

3.2 Qualification

N45.2 ¶ 1 Inspection activities to verify the quality ofwork shall be performed by appropriately trained

persons-.N18.7, ¶ 4 -

When inspection techniques requirespecialized qualifications or skills, personnel performing the inspection shall meet applicable licensing requirements, codes, and st andards appropriate to the discipline involved (see also Sections 5.2.7, 5.2.6 and

5.3.10).Each person who verifies conformance of work activities for purposes of acceptance shall be qualified to perform the

assigned inspection task.Similar requirement.Inspections by persons during on-the-job training for qualification shall be performed under the direct

observation and supervision of a qualified person andverification of conformance shall be by the qualified

person until certification is achieved.New requirement to this standard, but

consistent with those of the standards

for training and qualification.

4 INSPECTION HOLD POINTS N45.2, ¶ 4 - If mandatory inspection hold points, whichrequire witnessing or inspecting by the purchaser's designated representative and beyond which work shall not proceed without the consent of the purchaser's designated

representative, are required, the specific hold points shall be indicated in appropriate documents.

N18.7, ¶ 4 - If mandatory inspection hold points are required, the specific hold points shall be indicated in appropriate documents. If mandatory inspection hold points are required beyond

which work shall not proceed without the specific consent

of the designated representative, the specific hold points shall be indicated in appropriate documents.Similar requirement.

N45.2, ¶ 4 - Such consent shall be documented prior to thecontinuation of work beyond the designated hold point.

Consent to waive specified hold points shall be recorded prior to continuation of work beyond the designated hold

point.Similar requirement.

05/17/04InspectionPage 4 of 6 CRITERION 10 ANSI N45.2-77/ANSI N18.7-76 BASIC REQUIREMENT 10 NQA-1 1994 COMMENTS 5 INSPECTION PLANNING

5.1 PlanningPlanning

for inspection activities shall be accomplishedand documented. The documentation shall identify characteristics, methods, and acceptance criteria, and shall

provide for recording objective evidence of inspection

results.New requirement.This currently is met through the development of inspection documents.5.2 Sampling N45.2, ¶ 2 - Where a sample is used to verify acceptabilityof a group of items, the sampling procedure shall be based

on recognized standard practices and shall provide adequate justification for the sample size and selection

process.Where a sample is used to verify acceptability of a group of items, the sampling procedure shall be based on

recognized standard practices.Similar requirement.

6 IN-PROCESS INSPECTION

6.1 InspectionInspection

of items in-process or under construction shall be performed for work activities where necessary to verifyquality.New requirement addressing items in-

process or under construction. This is

consistent with current practice.

N45.2, ¶ 3 -If inspection of processed items is impossibleor disadvantageous, indirect control by monitoring of processing methods, equipment, and personnel shall be

provided.

N18.7, ¶ 5 - If inspection is impossible ordisadvantageous, indirect control by monitoring processing methods, equipment and pers onnel shall be provided. If inspection of processed items is impossible ordisadvantageous, indirect control by monitoring of processing methods, equipment, and personnel shall be

provided.Similar requirement.

N45.2, ¶ 3 - Both inspection and process monitoring shall be provided when control is inadequate without both.

N18.7 ¶ 5 - Both inspection and process monitoring shall be provided when control is inadequate without both..Both inspection and process monitoring shall be provided when control is inadequate without both.Similar requirement.

6.2 Combined

Inspection and Monitoring N18.7 ¶ 5 - In cases where documented verification ofquality implied by the above requirements is not possible or feasible, the extent of inspection or performance testing to verify adequacy of structures, systems, or components

for service should be, in general, greater than otherwise

required.6.2.1 A combination of inspection and process monitoring methods, when used, shall be performed in a systematic manner to assure that the specified requirements for control of the process and quality of the item are being achieved

throughout the duration of the process.NQA-1 meets the intent of N18.7.

NQA-1 is more descriptive of how to combine inspection and monitoring

that is not addressed in N45.2 or specifically addressed in N18.7.

6.2.2 Controls, where required, shall be established and documented for the coordina tion and sequencing of these 05/17/04InspectionPage 5 of 6 CRITERION 10 ANSI N45.2-77/ANSI N18.7-76 BASIC REQUIREMENT 10 NQA-1 1994 COMMENTS activities at established inspection points during successive stages of the conducted process or construction.

7 FINAL INSPECTIONS7.1 Resolution of Nonconformances Final inspections shall include a records review of the results and resolution of nonconformances identified by

prior inspections.Requirements carried forward from

the N45.2.4 and N45.2.8 standards on

Electrical/I&C and Mechanical

Installations. These are also addressed in comparing NQA-1, Subparts 2.4

and 2.8 to the N45.2 series standards.

The final inspection shall be planned to arrive at a conclusion regarding conformance of the item to specified requirements.

7.2 Inspection

RequirementsCompleted items shall be inspected for completeness, markings, calibration, adjustments, protection from damage, or other characteristics as required to verify the quality and conformances of the item to specified requirements.Quality records shall be examined for adequacy andcompleteness if not previously so examined.

7.3 AcceptanceThe

acceptance of the item shall be documented and approved by authorized personnel.

7.4 Modifications, Repairs, or Replacements N18.7, ¶ 3 - For modifications and nonroutinemaintenance, inspections shall be conducted in a mannersimilar (frequency, type, and personnel performing such

inspections) to that associated with construction phase

activities (see also Section 5.2.7).Modifications, repairs, or replacements of items performed

subsequent to final inspecti on shall require reinspection orretest, as appropriate, to verify acceptability.Similar requirement.NQA-1 uses the term "reinspection or

retest, as appropriate," in lieu of "in a manner similar to - construction

phase activities." NQA-1 also applies

to construction.

8 INSERVICE INSPECTION

8.1 Planning

and Performance N45.2, ¶ 5 -

A program for required inservice inspection ofcompleted systems, structures, and components shall be planned and executed by or for the organization responsible for operation of the nuclear facility.

N18.7, § 5.2.8, ¶ 1 Provisions shall be made forperforming required surveillance testing and inspections, including inservice inspections. Additional control Required in-service inspection or surveillance of structures, systems, or components shall be planned and executed by or for the organization responsible for

operation.Similar requirement.

05/17/04InspectionPage 6 of 6 CRITERION 10 ANSI N45.2-77/ANSI N18.7-76 BASIC REQUIREMENT 10 NQA-1 1994 COMMENTSprocedures shall be instituted, as necessary, to assuretimely conduct of surveillance tests and inspections and appropriate documentation, reporting, and evaluation of the results.

8.2 MethodsInspection

methods shall be established and executed to verify that the characteristics of an item continue to remain within specified limits. Inspection methods shall include evaluations of performance capability of essential emergency and safety systems and equipment, verification of calibration and integrity of instruments and instrument systems, and verification of maintenance, as appropriate.NQA-1 addresses requirements of the

inservice inspection/testing program

that were not addressed in the previous Quality Standards. Not a new requirement above the existing ASME inservice inspection requirements.

9 RECORDS N18.7, ¶ 6 -

Records shall be kept in sufficient detail topermit adequate confirmation of the inspection program.

The person recording the data as well as the person

approving the inspection results shall be identified.

Deviations, their cause, and any corrective action completed or planned as a result of the deviations shall be documented. Inspection records shall be identified as such

and shall be retrievable (see also Section 5.2.12).Records shall, as a minimum, identify (a) through below: (a) item inspected (b) date of inspection (c) inspector(d) type of observation (e) results or acceptability(f) reference to information on action taken in connection with nonconformancesSimilar requirement.Requirement to identify the person recording data is eliminated.

Requirement for inspection records to be specifically identified as such is not

included in NQA-1. This allows for inspections being documented within maintenance and test procedures.

05/19/04Test ControlPage 1 of 11 CRITERION 11 ANSI N45.2-77/ANSI N18.7-76 BASIC REQUIREMENT 11 NQA-1 1994 COMMENTS N45.2 §12 / N18.7 § 5.2.19 BASIC REQUIREMENT N45.2, ¶ 1 A test program shall be established to assurethat all testing required to demonstrate that the item will perform satisfactorily in service is identified and documented, -

N18.7, ¶ 1 A test program shall be established to assurethat testing required to demonstrate that the item will perform satisfactorily in service is identified and documented, -

N18.7, § 5.2.19.2 Tests Prior to and During Initial Plant Operation.

¶ 1 Prior to placing a nuclear power plant into operation, apreoperational test program shall be performed to demonstrate the functional adequacy of plant components, systems and structures. Following fuel loading an initial start-up test program shall be conducted to evaluate plant performance as the start-up progresses.

¶ 2 Responsibilities The ultimate responsibility for the preparation and execution of adequate preoperational andinitial start-up test programs rests with the owner organization. If design or construction is performed by

other than the owner organization, design organizations involved should participate in definition of the programs, and the construction organization involved may supplymanpower or supervision for execution of part or all of the program, but the owner organization shall determine that the program is adequate and that the results are satisfactory.

¶ 3 Scheduling A schedule shall be provided andmaintained to provide assurance that all necessary tests areperformed and properly evaluated on a timely basis.

Testing shall be scheduled so that the safety of the plant is never dependent on the performance of an untested system (see also Section 5.2.8).Tests required to verify conformance of an item or computer program to specified requirements and to demonstrate satisfactory performance for service shall be

planned and executed.NQA-1 adds requirement for test of computer software.N18.7 provides more specifics on "demonstrating satisfactory performance for service" at the point

where initial operation of a plant is

beginning and will be addressed in the

QAPD. The organization section of

the new QAPD addresses the responsibilities from N18.7.

N45.2, ¶ 1 - and that the testing is performed in accordance with written test procedures which incorporate or reference the requirements and acceptance limits contained in applicable design documentsCharacteristics to be tested and test methods to be employed shall be specified.Similar Requirement.

05/19/04Test ControlPage 2 of 11 CRITERION 11 ANSI N45.2-77/ANSI N18.7-76 BASIC REQUIREMENT 11 NQA-1 1994 COMMENTS N18.7, ¶ 1 - and that the testing is performed in accordance with written test procedures which incorporate or reference the requirements and acceptance limits contained in applicable design documents.

N45.2, ¶ 2 Test results shall be documented and evaluatedby responsible authority to assure that test requirements

have been satisfied.

N18.7, § 5.3.10, ¶ 1 Test and inspection results shall bedocumented and evaluated by responsible authority toassure that test and inspection requirements have been

satisfied.

N18.7, § 5.2.17, ¶ 6 The owner organization shall evaluate inspection results along with test results (see Section 5.2.19) to determine whether the individual inspection and test programs demonstrate that the plant can be operated safely and as designed.

N18.7, § 5.2.8, ¶ 1 Provisions shall be made forperforming required surveillance testing and inspections, including inservice inspections. - Additional control procedures shall be instituted, as necessary, to assure timely conduct of surveillance tests and inspections and appropriate documentation, reporting, and evaluation of the results.Test results shall be documented and their conformance

with acceptance criteria shall be evaluated.Similar Requirement.

Tests required to collect data, such as for siting or design input, shall be planned, executed, documented, and

evaluated.NQA-1 adds requirement for siting

and design input to address new

construction and design changes.

SUPPLEMENT 11S-1 SUPPLEMENTARY REQUIREMENTS FOR TEST CONTROL 1 GENERALThis Supplement provides amplified requirements for test control.It supplements the requirements of Basic Requirement 11

of this Part (Part 1) and shall be used in conjunction with that Basic Requirement when and to the extent specified by

the organization invoking this Part (Part 1).

2 TEST REQUIREMENTS N45.2, ¶ 1 Test requirements and acceptance criteria shallbe provided by the organization responsible for the design Test requirements and acceptance criteria shall be provided or approved by the organization responsible for the design Similar Requirement.

05/19/04Test ControlPage 3 of 11 CRITERION 11 ANSI N45.2-77/ANSI N18.7-76 BASIC REQUIREMENT 11 NQA-1 1994 COMMENTSof the item under test, unless otherwise designated.of the item to be tested unless otherwise designated.

N45.2, ¶ 1 The test program shall cover all required tests,including, as appropriate, prototype qualification tests, proof tests prior to installation, preoperational tests, and operational tests to verify continued satisfactory performance during operation.

N18.7, ¶ 1-5 The test program shall cover all required tests including:(1) Tests during the preoperational period to demonstrate that performance of plant systems is in accordance with

design intent and that the coordinated operation of theplant as a whole is satisfactory, to the extent feasible.

(2) Tests during the initial operational phase to demonstrate the performance of systems that could not be tested prior to operation and to confirm those physical parameters, hydraulic or mechanical characteristics that

need to be known, but which could not be predicted withthe required accuracy, and to confirm that plant behavior conforms to design criteria. The initial start-up test program shall be planned to permit safe fuel loading and start-up; to increase power in safe increments; and to perform major testing at specified power plateaus. If tests

require the variation of operating parameters outside oftheir normal range, the limits within which such variation is permitted shall be prescribed. Prerequisites and record

keeping shall be given attention and the scope of the testing shall demonstrate insofar as practicable that the

plant is capable of withstanding the design transients and accidents. The suitability of plant operating procedures should be checked to the maximum extent possible during the preoperational and initial start-up test programs.

(3) Surveillance tests during the operational phase to provide assurance that failures or substandard performance do not remain undetected and that the required reliability of safety-related systems is maintained (see Section 5.2.8).

(4) Tests during design, fabrication and construction

activities associated with plant maintenance andmodifications during the operational phase and the demonstration of satisfactory performance following plant Required tests, including, as appropriate, prototype

qualification tests, production tests, proof tests prior to

installation, construction tests, pre-operational tests, and

operational tests shall be controlled.

NQA-1 includes production tests that are not addressed by ANSI N45.2 or

N18.7.ANSI N18.7 gives more detail on the

purpose and extent of the described

tests. This is addressed in the QAPD, Section 11.1.

05/19/04Test ControlPage 4 of 11 CRITERION 11 ANSI N45.2-77/ANSI N18.7-76 BASIC REQUIREMENT 11 NQA-1 1994 COMMENTSmaintenance and modifications or procedural changes (see Section 5.2.7).

NRC Reg. Guide 1.33, Regulatory Position C.5.f - Theguidelines (indicated by the verb "should") of ANSI

N18.7-1976/ANS-3.2 contained in the following sections have sufficient safety importance to be treated the same as the requirements (indicated by the verb "shall") of the

standard: f. Section 5.2.19(2) - The guideline for checking plant operating procedures during the testing program.

Alternative from current VA QA Topical Report - (6)Paragraph C.5.f of Regulatory Guide 1.33 (and Section

5.2.19.(2) of ANSI N18.7 which it references) will be implemented when determined by station management.

N18.7, § 5.2.19.3 Tests Associated with Plant Maintenance, Modifications or Procedure Changes. Tests shall be performed following plant modifications or significant change in operating procedures to confirm that the modifications or changes reasonably produce expected results and that the change does not reduce safety of

operations.

N45.2, ¶ 1 - and that the testing is performed in accordance with written test procedures which incorporate or reference the requirements and acceptance limits contained in applicable design documents N18.7, ¶ 1 - and that the testing is performed in accordance with written test procedures which incorporate or reference the requirements and acceptance limits contained in applicable design documents.Test requirements and acceptance criteria shall be based upon specified requirements contained in applicable design or other pertinent technical documents.

NQA-1 addresses other pertinent documents other than design documents that may be a source of technical requirements or acceptance limits.3 TEST PROCEDURES N45.2, ¶ 2 Test procedures shall include provisions forassuring that prerequisites for the given test have been met, that adequate instrumentation is available and used, and that necessary monitoring is performed.

N18.7, § 5.3.10, ¶ 1 Test and inspection procedures shall contain a description of objectives; acceptance criteria that

will be used to evaluate the results; prerequisites for performing the tests or inspections including any special conditions to be used to simulate normal or abnormal Tests procedures shall include or reference test objectives

and provisions for assuring that prerequisites for the given test have been met, that adequate instrumentation is available and used, that necessary monitoring is performed, and that suitable environmental conditions are maintained.Similar requirement.ANSI N18.7 contains more detail on

the objectives of preoperational and

operational tests. This is addressed in

the QAPD (sections 5 & 11).

05/19/04Test ControlPage 5 of 11 CRITERION 11 ANSI N45.2-77/ANSI N18.7-76 BASIC REQUIREMENT 11 NQA-1 1994 COMMENTSoperating conditions; limiting conditions; and the test or inspection procedure. These procedures shall also specify any special equipment or calibrations required to conduct

the test or inspection.

ANSI N18.7, § 5.3.10, ¶ 2 Where tests and inspections areto be witnessed, the procedure shall identify hold points in the testing sequence to permit witnessing. The procedure

shall require appropriate appr oval for the work to continuebeyond the designated hold point.

N18.7, § 5.2.19.1 Preoperational Tests

¶ 1 Preoperational tests are generally performedsequentially in accordance with written procedures.

¶ 4 A component test is a functional, operational orperformance test of an individual piece of equipment or unit system under prescribed conditions. Typical parameters to be examined are direction of rotation, bearing temperatures, vibration, time delays, and ability to operate with remote and lo cal controls. The procedureshould list checks to be made and provide acceptance

criteria. Consideration should also be given to providing arun-in period to minimize early failures during operation of

the plant.

¶ 5 Individual system tests establish the functionaladequacy by operation under prescribed conditions. The tests shall be designed to permit evaluation of system performance including, for example, the measurement of flow, temperature, pressure, response time and vibration, transfer of power supply to emergency power and accuracy

and response of control devices.

¶ 6 The preoperational testing program shoulddemonstrate, as nearly as can be practicably simulated, the overall integrated operation of the plant systems at rated conditions, including simultane ous operations of auxiliarysystems. It may be necessary to defer portions of these

tests until nuclear heat is available. The procedures used should be similar to those discussed in 5.3.3 and 5.3.4, and they should be modified to require variation in control parameters, such as pump stops and restarts, cycling valves and varying flows so that system performance can be

05/19/04Test ControlPage 6 of 11 CRITERION 11 ANSI N45.2-77/ANSI N18.7-76 BASIC REQUIREMENT 11 NQA-1 1994 COMMENTSevaluated. For additional requirements in matters relatingto preoperational test programs, American National

Standard N45.2.8-1975 is generally applicable. [8]

NRC Reg. Guide 1.33, Regulatory Position C.5.g - Theguidelines (indicated by the verb "should") of ANSI

N18.7-1976/ANS-3.2 contained in the following sections have sufficient safety importance to be treated the same as the requirements (indicated by the verb "shall") of the

standard: g. Section 5.2.19.1 - The guideline for

preoperational tests, except the guideline that refers to a run-in period for equipment. In addition to these guidelines, the prerequisite steps for each equipment test should be completed prior to the commencement of the

preoperational test.

Alternative from current VA QA Topical Report - (7)Paragraph C.5.g of Regulatory Guide 1.33 (and Section

5.2.19.1 of ANSI N18.7 which it references) will be implemented with the addition of the modifier "normally"

after each of the verbs (should) which the Regulatory Guide converts to "shall." It is the Company's intent to fully comply with the requirements of this paragraph, and any conditions which do not fully comply will be documented and approved by station management personnel. In these areas, the reason for the exception shall also be documented. The documentation shall be retained for the same period of time as the affected preoperational

test.N45.2, ¶ 2 Prerequisites include such items as calibratedinstrumentation, appropriate equipment, trained personnel,condition of test equipment and the item to be tested, suitable environmental conditi ons, and provisions for data acquisition.

N18.7, § 5.3.10, ¶ 1 Test and inspection procedures shall contain a description of objectives; acceptance criteria that

will be used to evaluate the results; prerequisites for performing the tests or inspections including any special conditions to be used to simulate normal or abnormal operating conditions; limiting conditions; and the test or

inspection procedure. These procedures shall also specify Prerequisites shall include the following, as applicable:

calibrated instrumentation, appropriate equipment, trainedpersonnel, condition of test equipment and the item to be tested, suitable environmental conditions, and provisions

for data acquisition.Basic requirements are similar.ANSI N18.7 provides more detail on

the nature and content of prerequisites.

This is addressed in the QAPD.

05/19/04Test ControlPage 7 of 11 CRITERION 11 ANSI N45.2-77/ANSI N18.7-76 BASIC REQUIREMENT 11 NQA-1 1994 COMMENTSany special equipment or calibrations required to conduct the test or inspection.

N18.7, § 5.2.19.1 Preoperational Tests

¶ 2 Procedures should ensure that prerequisite steps forequipment testing, such as completion of necessary construction, prior testing, safety precautions, and measures to preserve equipment status have been or will be performed (see also Sections 5.2.17 and 5.3.10).

¶ 3 A detailed prescribed physical inspection of equipmentcomponents and facilities should be performed to ensure readiness for operation. Typical items to be covered include cleanliness, lubrication, setting of limit switches, calibration of instruments and presence of safety devices.

The test procedure should list the checks to be made and

include acceptance criteria and reference sources, such as vendor's literature, engineering drawings or plant

specifications.

NRC Reg. Guide 1.33, Regulatory Position C.5.g - Theguidelines (indicated by the verb "should") of ANSI

N18.7-1976/ANS-3.2 contained in the following sections have sufficient safety importance to be treated the same as the requirements (indicated by the verb "shall") of the

standard: g. Section 5.2.19.1 - The guideline for

preoperational tests, except the guideline that refers to a run-in period for equipment. In addition to these guidelines, the prerequisite steps for each equipment test should be completed prior to the commencement of the

preoperational test.

Alternative from current VA QA Topical Report - (7)Paragraph C.5.g of Regulatory Guide 1.33 (and Section

5.2.19.1 of ANSI N18.7 which it references) will be implemented with the addition of the modifier "normally"

after each of the verbs (should) which the Regulatory Guide converts to "shall." It is the Company's intent to fully comply with the requirements of this paragraph, and any conditions which do not fully comply will be documented and approved by station management personnel. In these areas, the reason for the exception shall also be documented. The documentation shall be retained

05/19/04Test ControlPage 8 of 11 CRITERION 11 ANSI N45.2-77/ANSI N18.7-76 BASIC REQUIREMENT 11 NQA-1 1994 COMMENTSfor the same period of time as the affected preoperational test.In lieu of specially prepared written test procedures, appropriate sections of related documents, such as ASTMmethods, Supplier manuals, equipment maintenance

instructions, or approved drawings or travelers with

acceptance criteria, can be used. Such documents shall include adequate instructions to assure the required quality

of work.NQA-1 addresses using standard test methods or other forms of instructions.

4 TEST RESULTS N45.2, ¶ 2 Test results shall be documented and evaluatedby responsible authority to assure that test requirements

have been satisfied.

N18.7, § 5.3.10, ¶ 1 Test and inspection results shall bedocumented and evaluated by responsible authority toassure that test and inspection requirements have been

satisfied.Test results shall be documented and evaluated by a responsible authority to assure that test requirements have

been satisfied.Similar requirement.

5 TEST RECORDS ANSI N18.7, § 5.3.10, ¶ 2 The test and inspection procedures shall require recording the date, identification of those performing the test or inspection, as found condition, corrective actions performed, if any, and as-left

condition.Test records shall, as a minimum, identify (a) through (g)

below:(a) item tested (b) date of test (c) tester or data recorder(d) type of observation (e) results and acceptability(f) action taken in connection with any deviations noted (g) person evaluating test resultsSimilar requirement.

SUPPLEMENT 11S-2 SUPPLEMENTARY REQUIREMENTS FOR COMPUTER PROGRAM

TESTINGNQA-1-1994 adds requirements in thisSupplement for QA for Computers and Software. Additional requirements are contained in Basic Requirement 3 with Supplement 3S-1 and Subpart 2.7 of NQA-1. These quality assurance requirements were not specifically

addressed in the previous standards.

However, the NRC required licensees to commit to controlling computer software in their QA Programs.

05/19/04Test ControlPage 9 of 11 CRITERION 11 ANSI N45.2-77/ANSI N18.7-76 BASIC REQUIREMENT 11 NQA-1 1994 COMMENTS 1 GENERALThis Supplement provides amplified requirements fortesting of computer programs and associated computer systems.It supplements the requirements of Basic Requirement 11

of this Part (Part 1) and shall be used in conjunction with that Basic Requirement when and to the extent specified by

the organization invoking this Part (Part 1).

2 TEST REQUIREMENTSTest requirements and acceptance criteria shall be provided or approved by the organization responsible for the design of the item to be tested unless otherwise designated.

Required tests including (as appropriate) verification tests, hardware integration tests, and in-use tests shall be

controlled.Test requirements and acceptance criteria shall be based

upon applicable design or other pertinent technical documents.

2.1 Verification

TestsVerification tests shall demonstrate the capability of the computer program to produce valid results for test problems encompassing the range of permitted usage defined by the program documentation.Acceptable test problem solutions are as follows: (a) hand calculations;(b) calculations using comparable proven programs; orI empirical data and information from technical literature.For programs used for operational control, testing shall demonstrate required performance over the range of

operation of the controlled function or process.Depending on the complexity of the computer program being tested, testing may range from a single test of the completed computer program to a series of tests performed at various stages of computer program development to verify correct translation between stages and proper working of individual modules, followed by an overall computer program test.Regardless of the number of stages of testing performed, 05/19/04Test ControlPage 10 of 11 CRITERION 11 ANSI N45.2-77/ANSI N18.7-76 BASIC REQUIREMENT 11 NQA-1 1994 COMMENTS verification testing shall be sufficient to establish that testrequirements are satisfied and that the computer program

produces a valid result for its intended function.

2.2 In-Use TestsTest problems shall be developed and documented to permit confirmation of acceptable performance of the computer program in the operating system.Test problems shall be run whenever the computer program is installed on a different computer, or when significant hardware or operating system configuration changes are made. Periodic in-use manual or automatic self-check routines shall be prescribed and performed for those applications where computer failures or drift can affect required performance.

3 TEST PROCEDURESTest procedures or plans shall specify the following, as

applicable: (a) required tests and test sequence(b) required ranges of input parameters (c) identification of the stages at which testing is required (d) criteria for establishing test cases(e) requirements for testing logic branches(f) requirements for hardware integration (g) anticipated output values (h) acceptance criteria (i) reports, records, standard formatting, and conventions.

4 TEST RESULTSTest results shall be documented.Verification test results shall be evaluated by a responsibleauthority to assure that test requirements have been

satisfied.

5 TEST RECORDS(a) Verification test records shall identify (1) through (10)

below.(1) computer program tested(2) computer hardware used(3) test equipment and calibrations, where applicable

.

05/19/04Test ControlPage 11 of 11 CRITERION 11 ANSI N45.2-77/ANSI N18.7-76 BASIC REQUIREMENT 11 NQA-1 1994 COMMENTS (4) date of test (5) tester or data recorder(6) simulation models used, where applicable(7) test problems (8) results and acceptability (9) action taken in connection with any deviations noted (10) person evaluating test results.(b) in-use test results shall identify (1) through (6) below:(1) computer program tested(2) computer hardware used(3) test equipment and calibrations, where applicable (4) date of test (5) tester or data recorder(6) acceptability.

04/28/04Control of Measuring and Test Equipment Page 1 of 7 CRITERION 12ANSI N45.2-77/ANSI N18.7-76BASIC REQUIREMENT 12 NQA-1 1994 COMMENTSN45.2 §13 / N18.7 § 5.2.16 N18.7 ¶ 2 Tools, instruments, testing equipment and measuringdevices used for measurements, tests and calibration - shall be controlled, calibrated and adjusted and maintained at specified intervals or prior to use to assure the necessary accuracy ofcalibrated devices. Tools, gages, instruments, and other measuring and test equipment used for activities affecting quality shall be controlled

and at specified periods calibrated and adjusted to maintainaccuracy within necessary limits.Similar requirement.SUPPLEMENT 12S-1 SUPPLEMENTARY REQUIREMENTS FOR CONTROL OF MEASURING

AND TEST EQUIPMENTAdditional M&TE requirements arecontained in NQA-1, Subpart 2.16, a standard not previously committed to at any of the current facilities.

1 GENERALThis Supplement provides amplified requirements for control of measuring and test equipment.

N18.7 ¶ 1 The method and interval of calibration for eachinstalled instrument and control device shall be defined and shall be based on the type of equipment, stability and reliability

characteristics, required accuracies and other conditions affectingcalibration.

N18.7 ¶ 4 Special calibration shall be performed when theaccuracy of - installed - equipment is questionable.

N18.7 ¶ 4 American National Standard N45.2.4-1972 shall beapplied to those activities occurring during the operational phase that are comparable in nature and extent to related activities occurring during construction.It supplements the requirements of Basic Requirement 12 of this Part (Part 1) and shall be used in conjunction with that Basic Requirement when and to the extent specified by the organization invoking this Part (Part 1).

NQA-1 applicability is discussed in the Introductions to Parts I and II. It likewise applies to the operations phase. However, NQA-1 doesn't specifically state that the M&TE program is applicable to installed instrument and control devices. Installed instrument and control devices are

calibrated and adjust ed in accordance withthe maintenance and testing programs and

the controls are addressed in the new

QAPD.2 SELECTION N45.2 ¶ 1 Measures shall be established and documented toassure that tools, gages, instruments, and other inspection, measuring, and testing equipment and devices used in activities

affecting quality are of the pr oper range, type, and accuracy toverify conformance to established requirements.

N18.7 ¶ 2 Tools, instruments, testing equipment and measuringdevices used for measurements, tests and calibration shall be of the proper range and type and shall be controlled, calibrated andadjusted and maintained at specified intervals or prior to use to assure the necessary accuracy of calibrated devices.ANSI N45.2.1 § 2.5 Test Equipment2.5.1 Selection. Inspection and test equipment used to implement the requirements of this standard shall be selected to have

sufficient accuracy and sensitivity tolerance to determineconformance to specified requirements.N45.2.2 § 2.5 Measuring and Test Equipment.2.5.1 Selection. Inspection, examination, and testing equipment Selection of measuring and test equipment shall be controlled to assure that such items are of proper type, range, accuracy, andtolerance to accomplish the function of determining conformance to specified requirements.ANSI N45.2.5 contains additional information on the selection of M&TE along with a Virginia alternative to the QA requirements. This is addressed in NQA-1 Subpart 2.5. Based on discussion with VA NSS civil folks and NO personnel knowledgeable in concrete QA requirements, this alternative is no longer needed. Dominion has been calibrating this type of equipment and currently requires the supplier of these services to have this equipment in their calibration program.

04/28/04Control of Measuring and Test Equipment Page 2 of 7 CRITERION 12ANSI N45.2-77/ANSI N18.7-76BASIC REQUIREMENT 12 NQA-1 1994 COMMENTSutilized to implement the requirements of this standard shall be selected to have accuracy and tolerance sufficient to determineconformance to specified requirements.N45.2.4 § 2.5 Measuring and Test Equipment2.5.1 SelectionInspection and testing equipmen t with acceptable accuracy forperforming the required function shall be selected. When generalvoltage levels, flow directions, or other parameters are checked, an instrument without high precision may be used. When characteristics, efficiencies, capabilities, or other properties are measured to appraise complia nce with specifications, theinstrument must have adequate accuracy to determine themeasured quantity to the precision required by the stated limits of the specifications. Use shall be made of approved industry standards relating to measuring procedures. Test equipment and/or apparatus supplying electrical, mechanical, or other test inputs shall have adequate capacity and be compatible with items

under test so that the results will not be distorted.N45.2.5 § 2.5 Measuring and Test Equipment.2.5.1 Selection.Measuring and test equipment used to implement the requirements of this standard shall be selected on the basis of

accuracy sufficient to determine conformance to specifiedrequirements.These measuring devices shall include but not to be limited to thermometers, balances, scales, air entrainment meters, humidity meters, volumetric buckets, field soil density measuring devices, pressure gages, and torque wrenches.

Clarification from the current VA QATR:(1) With regard to Section 2.5.1 of ANSI N45.2.5-1974, titled Selection: The Company complies with the requirement set forthin the first paragraph of this Section for selection of measuring and test equipment on the ba sis of sufficient accuracy todetermine conformance to the standard's requirements: This is accomplished without the use of calibrated balances or volumetric buckets. Clarification meets or exceeds applicableguides and standards. The proposed clarification is used to translate construction oriented documents to operational regulations.N45.2.8 § 2.8 Measuring and Test Equipment2.8.1 Selection. Measuring and test equipment used to implement the requirements of this standard shall be selected to have range, 04/28/04Control of Measuring and Test Equipment Page 3 of 7 CRITERION 12ANSI N45.2-77/ANSI N18.7-76BASIC REQUIREMENT 12 NQA-1 1994 COMMENTS type and accuracy sufficient to determine conformance tospecified requirements.N45.2.13 § 7.4 Measuring and Test Equipment7.4.1 Selection. Inspection, examination, and testing equipment utilized to implement the requirements of this standard shall be

selected to have accuracy and tolerance sufficient to determineconformance to specified requirements.

3 CALIBRATION AND CONTROL3.1 Calibration N45.2 ¶ 1 To assure accuracy, inspection, measuring, and testequipment shall be controlled, calibrated, adjusted, and maintained at prescribed intervals or prior to use against certified equipment having known valid relationships to nationallyrecognized standards.

N18.7 ¶ 2 Tools, instruments, testing equipment and measuringdevices used for measurements, tests and calibration shall be of the proper range and type and shall be controlled, calibrated andadjusted and maintained at specified intervals or prior to use to assure the necessary accuracy of calibrated devices.ANSI N45.2.1 § 2.5 Test Equipment2.5.2 Calibration and Control. Test equipment shall be adjusted

and calibrated at prescribed intervals against certified equipmenthaving known valid relationships to nationally known standards.N45.2.2 § 2.5 Measuring and Test Equipment.2.5.2 Calibration and Control. As appropriate, measuring and testequipment shall be adjusted and calibrated at prescribed intervalsagainst certified equipment having known valid relationships to nationally recognized standards.N45.2.4 § 2.5 Measuring and Test Equipment2.5.2 Calibration and Control. Measuring and test equipment used to determine compliance with specifications, shall be

adjusted and calibrated at prescribed intervals against certifiedequipment having known valid relationships to nationallyrecognized standards. If no national standards exists, the basis for calibration shall be documented. Records of the calibrations shall be maintained and equipment suitably marked to indicate date of next required calibration. When inspection and testing equipmentare found to be out of calibration, an evaluation shall be made of the validity of previous inspection or test results and of the acceptability of items previously inspected or tested. Testequipment found to be out of calibration shall be clearly identified as such.Measuring and test equipment shall be calibrated, adjusted, and maintained at prescribed interv als or, prior to use, againstcertified equipment having known valid relationships to nationally recognized standards.Similar requirements.

04/28/04Control of Measuring and Test Equipment Page 4 of 7 CRITERION 12ANSI N45.2-77/ANSI N18.7-76BASIC REQUIREMENT 12 NQA-1 1994 COMMENTSN45.2.5 § 2.5 Measuring and Test Equipment.2.5.2 Calibration and Control. The equipment shall be adjusted orcalibrated or both at prescrib ed intervals against certifiedstandards having known valid relationships to national standards, where such exists.

N45.2.8 § 2.8 Measuring and Test Equipment2.8.2 Calibration and Control. Measuring and test equipment used to determine compliance with Specifications, shall be

adjusted and calibrated at predetermined intervals, based onequipment stability and use, against certified equipment having known valid relationships to nationally recognized standards.N45.2.13 § 7.4 Measuring and Test Equipment7.4.2 Calibration and Control. As appropriate, measuring and test equipment shall be adjusted and calibrated at prescribed intervalsagainst certified equipment having known valid relationships to nationally recognized standards.

N45.2 ¶ 1 If no national standards exist, the basis for calibrationshall be documented.ANSI N45.2.1 § 2.5 Test Equipment2.5.2 Calibration and Control. If no national standards exist, the basis of calibration shall be documented.N45.2.2 § 2.5 Measuring and Test Equipment.2.5.2 Calibration and Control. If no national standards exists, the basis for calibration shall be documented.N45.2.4 § 2.5 Measuring and Test Equipment2.5.2 Calibration and Control. If no national standards exists, the basis for calibration shall be documented.N45.2.5 § 2.5 Measuring and Test Equipment.2.5.2 Calibration and Control. If no national standards exists, the basis for the adjustment or calibration shall be documented.

Records shall be maintained and equipment suitably marked to indicate calibration status. Measures shall be taken to assure proper handling, storage and care of installation of inspection and testing equipment after calibration in order to maintain the required accuracy of such equipment.

N45.2.8 § 2.8 Measuring and Test Equipment2.8.2 If no national standards exist, the basis for calibration shall be documented.N45.2.13 § 7.4 Measuring and Test Equipment7.4.2 Calibration and Control. If no standards exist, the basis for calibration shall be documented.If no nationally recognized standards exist, the bases for calibration shall be documented.Similar requirement.

04/28/04Control of Measuring and Test Equipment Page 5 of 7 CRITERION 12ANSI N45.2-77/ANSI N18.7-76BASIC REQUIREMENT 12 NQA-1 1994 COMMENTS 3.2 Control N45.2 ¶ 2 The method and interval of calibration for each itemshall be defined and shall be based on the type of equipment, stability characteristics, require d accuracy, and other conditionsaffecting measurement control.The method and interval of calibration for each item shall be defined, based on the type of equipment stability characteristics, required accuracy, intended use, and other conditions affectingmeasurement control.Similar requirement.

N45.2 ¶ 2 When inspection, measuring, and test equipment arefound to be out of calibration, an evaluation shall be made and documented of the validity of previous inspection or test results and of the acceptability of items pr eviously inspected or tested.

N18.7 ¶ 2 When calibration, testing, or other measuring devicesare found to be out of calibration, an evaluation shall be made and documented concerning the validity of previous tests and the

acceptability of devices previously tested from the time of theprevious calibration. ANSI N45.2.1 § 2.5 Test Equipment2.5.2 Calibration and Control. When inspection and testing equipment is found to be out of calibration, an evaluation shall be made of the validity of previous inspection or test results and acceptability of items previous ly inspected or tested.N45.2.4 § 2.5 Measuring and Test Equipment2.5.2 Calibration and Control. When inspection and testingequipment are found to be out of calibration, an evaluation shall be made of the validity of previous inspection or test results and of the acceptability of items prev iously inspected or tested.N45.2.5 § 2.5 Measuring and Test Equipment.2.5.2 Calibration and Control. Test equipment found to be out ofcalibration shall be clearly identified as such. When discrepancies, malfunctions, or inaccuracies in inspection andtesting equipment are found during calibration, all items inspected with that equipment since the last previous calibration

shall be considered unacceptabl e until an evaluation has beenmade by the responsible authority and appropriate action taken.N45.2.8 § 2.8 Measuring and Test Equipment2.8.2 Calibration and Control. When measuring and test equipment is found to be out of calibration, an evaluation shall be made of the validity of previous inspection or test results and the acceptability of mechanical items inspected or tested since thelast calibration check. Where necessary to determine theacceptability of items or data, the required original inspections ortests or applicable portions thereof shall be repeated using properly calibrated equipment. In the event that the status ofequipment precludes using the originally specified methods, When measuring and test equipment is found to be out of calibration, an evaluation shall be made and documented of the validity of previous inspection or test results and of the acceptability of items previous ly inspected or tested.Similar requirement.

04/28/04Control of Measuring and Test Equipment Page 6 of 7 CRITERION 12ANSI N45.2-77/ANSI N18.7-76BASIC REQUIREMENT 12 NQA-1 1994 COMMENTSequipment or procedures, alternat e inspections or tests agreeableto the responsible organizations may be used.N45.2.13 § 7.4 Measuring and Test Equipment7.4.2 Calibration and Control. When inspection, measuring and test equipment are found to be out of calibration, an evaluation shall be made and documented of the validity of previous

inspection or test results and of the acceptability of items previously inspected or tested.N45.2.4 § 2.5 Measuring and Test Equipment2.5.2 Calibration and Control. Test equipment found to be out of calibration shall be clearly identified as such.Out-of-calibration devices shall be tagged or segregated and not

used until they have been recalibrated.Similar requirement.

N45.2 ¶ 2 If any inspection, measuring, or test equipment isconsistently found to be out of calibration, it shall be repaired or replaced.N18.7 ¶ 2 If any calibration, testing or measuring device isconsistently found to be out of calibration, it shall be repaired or replaced.If any measuring or test equipment is consistently found to be out

of calibration, it shall be repaired or replaced.Similar requirement.

N45.2 ¶ 2 Special calibration shall be performed when accuracyof the equipment is suspect.

N18.7 ¶ 4 Special calibration shall be performed when the accuracy of - calibrating equipment is questionable.A calibration shall be performed when the accuracy of theequipment is suspect.Similar requirement.

3.3 Commercial

Devices N45.2 ¶ 1 This requirement is not intended to imply a need forspecial calibration and control measures on rulers, tape measures,levels, and such other devices, if normal commercial practices

provide adequate accuracy.

N18.7 ¶ 3 It is not the intent of this Standard to imply a need forspecial calibration and control measures on rulers, tape measures,levels and other such devices if normal commercial practices

provide adequate accuracy.Calibration and control measures may not be required for rulers,tape measures, levels, and other such devices, if normal commercial equipment provides adequate accuracy.Similar requirement.

4 HANDLING AND STORAGEN45.2.5 § 2.5 Measuring and Test Equipment.2.5.2 Calibration and Control. Measures shall be taken to assure proper handling, storage and care of installation of inspection and testing equipment after calibration in order to maintain the required accuracy of such equipment.N45.2.8 § 2.8 Measuring and Test Equipment2.8.2 Calibration and Control.Measures shall be taken to assure proper handling, storage, and care of the measuring and test equipment after calibration in order to maintain the required accuracy of such equipment.Measuring and test equipment shall be properly handled andstored to maintain accuracy.Similar requirement.

04/28/04Control of Measuring and Test Equipment Page 7 of 7 CRITERION 12ANSI N45.2-77/ANSI N18.7-76BASIC REQUIREMENT 12 NQA-1 1994 COMMENTS 5 RECORDS N45.2 ¶ 3 Records shall be maintained and equipment suitablymarked to indicate calibration status.

N18.7 ¶ 4 Records shall be made and equipment suitably marked to indicate calibration status.ANSI N45.2.1 § 2.5 Test Equipment2.5.2 Calibration and Control. Records shall be maintained and equipment suitably marked to indicate calibration status.N45.2.2 § 2.5 Measuring and Test Equipment.2.5.2 Calibration and Control. Records shall be maintained and equipment suitably marked to indicate calibration status.N45.2.4 § 2.5 Measuring and Test Equipment2.5.2 Calibration and Control. Records of the calibrations shall be maintained and equipment suitably marked to indicate date of next required calibration.N45.2.5 § 2.5 Measuring and Test Equipment.2.5.2 Calibration and Control. Records shall be maintained and equipment suitably marked to indicate calibration status.N45.2.8 § 2.8 Measuring and Test Equipment2.8.2 Calibration and Control. Records of calibrations shall be maintained and equipment suitably marked so that the calibration status can be determined. Records of calibration shall be included in inspection and test results where applicable.N45.2.13 § 7.4 Measuring and Test Equipment7.4.2 Calibration and Control. Records shall be maintained and equipment suitably marked to indicate calibration status or the

records shall be traceable to the equipment.Records shall be maintained and equipment shall be suitablymarked to indicate calibration status.Similar requirement.N45.2.8 § 2.8 Measuring and Test Equipment2.8.2 Calibration and Control. - Records of calibration shall be included in inspection and test results where applicable.N45.2.8 addresses inclusion of records of calibration in with inspection and test results where applicable. This level of detail is not specifically addressed in NQA-1, but the intent is met through the

standard for QA records.

05/20/04 Handling, Storage, and Shipping Page 1 of 3 CRITERION 13 ANSI N45.2-77/ANSI N18.7-76 BASIC REQUIREMENT 13 NQA-1 1994 COMMENTS N45.2 § 14 / N18.7 § 5.2.13.4 unless otherwise noted.

N45.2 ¶ 1 Measures shall be established - to control handling, storage, and shipping, including cleaning, packaging, and preservation of material and equipment- to

prevent damage, deterioration, and loss.

N18.7 ¶ 1 Measures shall be provided to control handling, storage and shipping, including cleaning, packaging and preservation of material and equipment - to prevent

damage, deterioration and loss.

Handling, storage, cleaning, packaging, shipping, and preservation of items shall be controlled to prevent damage

or loss and to minimize deterioration.

Similar requirement.

SUPPLEMENT 13S-1 SUPPLEMENTARY REQUIREMENTS FOR HANDLING, STORAGE, AND

SHIPPING 1 GENERAL This Supplement provides amplified requirements for handling, storage, and shipping.

It supplements the requirements of Basic Requirement 13 of this Part (Part 1) and shall be used in conjunction with

that Basic Requirement when and to the extent specified by

the organization invoking this Part (Part 1).

2 INSTRUCTION N45.2 ¶ 1 Measures shall be established and documented to control handling, storage and shipping - in accordance with established instructions, procedures, or drawings to prevent damage, deterioration, and loss.

N18.7 ¶ 1 Measures shall be provided to control handling, storage and shipping - in accordance with established instructions, procedures or drawings, to prevent damage, deterioration and loss.

Handling, storage, and shipping of items shall be conducted in accordance with established work and inspection

instructions, drawings, specifications, shipment instructions, or other pertinent documents or procedures specified for

use in conducting the activity.

Similar requirement.

3 REQUIREMENTS

3.1 General

N45.2 ¶ 1 When necessary for particular items, special coverings, special equipment, and special protective environments such as inert gas atmosphere, specific When required for particular items, special equipment (such as containers, shock absorbers, and accelerometers) and

special protective environments (such as inert gas Similar requirement.

05/20/04 Handling, Storage, and Shipping Page 2 of 3 CRITERION 13 ANSI N45.2-77/ANSI N18.7-76 BASIC REQUIREMENT 13 NQA-1 1994 COMMENTS moisture content levels, and temperature levels shall be specified provided, and their existence verified.

N18.7 ¶ 1 When necessary for particular items, special coverings, special equipment and special protective environments, such as inert gas atmosphere, specific

moisture content levels and temperature levels shall be

specified, provided, and their existence verified.

atmosphere, specific moisture content levels, and temperature levels) shall be specified, provided, and their

existence verified.

3.2 Procedures

N45.2 ¶ 2 For critical, sensitive, perishable, or high-value articles, specific written procedures for handling, storage, packaging, shipping, and preservation should be used.

N18.7 ¶ 2 For critical, sensitive, perishable or high-value articles, specific written procedures for handling, storage, packaging, shipping and preservation should bc used.

When required for critical, sensitive, perishable, or high-value articles, specific procedu res for handling, storage, packaging, shipping, and preservation shall be used.

Similar requirement.

3.3 Tools

and Equipment N45.2 ¶ 2 Special handling tools and equipment should be provided and controlled as necessary to ensure safe and adequate handling.

N18.7 ¶ 2 Special handling tools and equipment should be provided and controlled as necessary to ensure safe and adequate handling.

Special handling tools and equipment shall be utilized and controlled as necessary to ensure safe and adequate

handling.Changed from guidance to a requirement of NQA-1-1994.

N45.2 ¶ 3 Special handling tools and equipment shall be inspected and tested, in accordance with written procedures and at specified times, to verify that the tools and equipment

are adequately maintained N18.7 ¶ 3 Special handling tools and equipment shall be inspected and tested in accordance with written procedures and at specified times, to verify that the tools and equipment

are adequately maintained.

Special handling tools and equipment shall be inspected and tested in accordance with procedures and at specified time

intervals to verify that the tools and equipment are

adequately maintained.

Similar requirement.

3.4 Operators

Operators of special handling and lifting equipment shall be experienced or trained in use of the equipment.

A similar requirement is currently contained in ANSI N45.2.2, § 7.5.

4 MARKING 05/20/04 Handling, Storage, and Shipping Page 3 of 3 CRITERION 13 ANSI N45.2-77/ANSI N18.7-76 BASIC REQUIREMENT 13 NQA-1 1994 COMMENTS N45.2 ¶ 4 Special attention shall be given to providing adequate instructions for marking and labeling for packaging, shipment, and storage of items. Marking shall be

adequate to identify, maintain, and preserve the shipment, including indication of the presence of special environments

or the need for special control.

N18.7 ¶ 4 Attention shall be given to providing adequate instructions for marking and labeling of items for packaging, shipment and storage. Marking shall be adequate to identify, maintain and preserve the shipment, including indication of

the presence of special environments or the need for special

control.Instructions for marking and labeling for packaging, shipment, handling, and storage of items shall be established

as necessary to adequately identify, maintain, and preserve

the item, including indication of the presence of special

environments or the need for special controls.

Similar requirement.

N18.7 ¶ 5 American National Standard for Packaging, Shipping, Receiving, Storage and Handling of Items for Nuclear Power Plants (During the Construction Phase),

N45.2.2-1972, shall be applied to those activities occurring

during the operational phase that are comparable in nature

and extent to related activities occurring during

construction.

ANSI N45.2.2 is addressed as NQA-1-1994, Subpart 2.2. A separate table is used to compare these two documents.

05/20/04Inspection, Test, and Operating StatusPage 1 of 3 CRITERION 14 ANSI N45.2-77/ANSI N18.7-76 BASIC REQUIREMENT 14 NQA-1 1994 COMMENTS N45.2 § 15 / N18.7 § 5.2.6 Unless otherwise noted.

N45.2, ¶ 1 Measures shall be established anddocumented to identify inspection and test status. Such measures shall provide means for assuring that required inspections and tests are performed and that the acceptability of items with regard to inspections and tests performed is known throughout manufacturing, installation, and operation.

N45.2, ¶ 2 The measures shall provide for assuring thatonly items that have passed the required inspections

and tests are used, installed, or operated.

N18.7, § 5.2.6, ¶ 5 Procedures shall also provide forthe identification of items which have satisfactorily

passed required inspections and tests, where necessary to preclude inadvertent bypassing of such inspections and tests. In cases where required documentary evidence is not available, the associated equipment or materials must be considered nonconforming in

accordance with Section 5.2.14. Until suitable documentary evidence is available to show the equipment or material is in conformance, affected systems shall be considered to be inoperable and reliance shall not be placed on such systems to fulfill their intended safety functions.

N18.7, § 5.2.7, ¶ 4 Measures shall be established anddocumented to identify the inspection and test status of items to be used in maintenance and modification activities. Normally, the point of control for such items

should be the plant storage area.

The status of inspection and test activities shall be identified either on the items or in documents traceable to the items where it is necessary to assure that required inspections and tests are performed and to assure that items which have not passed the required inspections and tests are not inadvertently installed, used, or

operated.Similar requirement.

N45.2, ¶ 1 Nonconforming items shall be clearly identified.

N45.2, ¶ 2 The inspection and test status of items shallbe maintained through the use of status indicators such as physical location and tags, markings, shop travelers, stamps, or inspection records.

N18.7, § 5.2.6 , ¶ 2 Equipment and systems in acontrolled status shall be clearly identified. Strict control measures for such equipment shall be enforced.Status shall be maintained through indicators, such asphysical location and tags, markings, shop travelers, stamps, inspection records, or other suitable means.Similar requirement.Nonconforming items from N45.2 are further addressed by NQA-1 under Basic Requirement 15 and Supplement 15S-1.

05/20/04Inspection, Test, and Operating StatusPage 2 of 3 CRITERION 14 ANSI N45.2-77/ANSI N18.7-76 BASIC REQUIREMENT 14 NQA-1 1994 COMMENTS N18.7, § 5.2.6, ¶ 5 The procedures shall also requirethat the status of inspections and tests performed upon individual items on the nuclear power plant be indicated by the use of markings such as stamps, tags, labels, routing cards, or other suitable means. Suitable means include identification numbers which are

traceable to records of the status of inspections and

tests.N45.2, ¶ 2 These measures shall include procedures forcontrol of status indicators, including the authority for application and removal of tags, markings, labels, andstamps.N18.7, § 5.2.6 , ¶ 1 Permission to release equipment orsystems for maintenance shall be granted by designated operating personnel. Prior to granting permission, such operating personnel shall verify that the equipment or system can be released, and determine how long it may be out of service. Granting of such permission shall be documented.

N18.7, § 5.2.6, ¶ 6 When equipment is ready to be returned to service, operating personnel shall place the equipment in operation and verify and document its functional acceptability.The authority for application and removal of tags, markings, labels, and stamps shall be specified.Similar requirement.NQA-1 doesn't add the detail regarding operating personnel verifying that equipment can be released and determining

how long it can be released, or the return to service requirements. The QAPD, Section

14.2 addresses these issues.

N45.2, ¶ 3 Measures shall also provide for indicatingthe operating status of systems and components of the nuclear facility, such as by tagging valves and

switches, to prevent inadvertent operation.

N18.7, § 5.2.6 , ¶ 4 Procedures shall be provided forcontrol of equipment, as necessary, to maintain personnel and reactor safety and to avoid unauthorized operation of equipment. These procedures shall require control measures such as locking or tagging to secure and identify equipment in a controlled status. The

procedures shall require i ndependent verifications,where appropriate, to ensure that necessary measures, such as tagging equipment, have been implemented correctly.

Status indicators shall also provide for indicating the operating status of systems and components of the nuclear facility, such as by tagging valves and

switches, to prevent inadvertent operation.Similar requirement.Procedure requirements are addressed by NQA-1 in Basic Requirement 5. The company will commit to having procedures of the type stated in Reg. Guide 1.33, Appendix A (the same as the current commitment).

05/20/04Inspection, Test, and Operating StatusPage 3 of 3 CRITERION 14 ANSI N45.2-77/ANSI N18.7-76 BASIC REQUIREMENT 14 NQA-1 1994 COMMENTS N18.7, § 5.2.6, ¶ 1 Attention shall be given to thepotentially degraded degree of protection when one subsystem of a redundant safety system has been removed for maintenance.

NQA-1 does not provide guidance on this aspect of controlling equipment. The

QAPD, Section 14.2 addresses these issues.

N18.7, § 5.2.6, ¶ 2 After permission has been grantedto remove the equipment from service, it shall be made

safe to work on. Measures shall provide for protection of equipment and workers.

NQA-1 does not provide guidance on this aspect of controlling equipment. The

QAPD, Section 14.2 addresses these issues.

N18.7, § 5.2.6, ¶ 3 Conditions to be considered inpreparing equipment for maintenance include, for example: shutdown margin; method of emergency core cooling; establishment of a path for decay heat removal; temperature and pressure of the system; valves between work and hazardous material; venting, draining and flushing; entry into closed vessels; hazardous atmospheres; handling hazardous materials; and electrical hazards. When entry into a closed system is required, control measures shall be established to prevent entry of extraneous material and to assure that foreign material is removed before the system is

reclosed.NQA-1 does not provide guidance on this aspect of controlling equipment. The

QAPD, Section 14.2 addresses these issues.

N18.7, § 5.2.6, ¶ 5 Temporary modifications, such astemporary bypass lines, electrical jumpers, lifted electrical leads, and temporary trip point settings, shall be controlled by approved procedures which shall include a requirement for independent verification. A log shall be maintained of the current status of such temporary modifications.

NQA-1 does not provide guidance on this aspect of controlling equipment. Temporary modifications are addressed in QAPD, Section 14.2.

N18.7, § 5.2.6, ¶ 6 Attention shall be given torestoration of normal conditions, such as removal of jumpers or signals used in maintenance or testing or

such as returning valves, breakers or switches to proper start-up or operating positions from "test" or "manual" positions. When placed into service, the equipment

should receive additional surveillance during the run-in

period.NQA-1 does not provide guidance on this aspect of controlling equipment. QAPD, Section 14.2 addresses these issues.

05/20/04Nonconforming Materials, Parts, or Components (Items)Page 1 of 3 CRITERION 15 ANSI 45.2-77/ANSI N18.7-76 BASIC REQUIREMENT 15 NQA-1 1994 COMMENTS N45.2 § 16 / N18.7 § 5.2.14 Unless otherwise noted.

N45.2, ¶1 Measures shall be established and documentedto control items, services, or activities which do not conform to requirements.

N18.7, ¶ 1 Measures shall be provided to control items,services or activities which do not conform to requirements (Note in N18.7 text: see also Section 5.2.6).Items that do not conform to specified requirements shall

be controlled to prevent inadvertent installation or use.Similar requirement.

N45.2, ¶ 1 These measures shall include, as appropriate,procedures for identification, documentation, segregation, disposition, and notification to affected organizations.

N18.7, ¶ 1 These procedures shall include as appropriate,instructions for identification, documentation, segregation, disposition and notification to affected organizations.Controls shall provide for identification, documentation, evaluation, segregation when practical, and disposition of nonconforming items, and for notification to affected

organizations.Similar requirement.

SUPPLEMENT 15S-1 SUPPLEMENTARY REQUIREMENTS FOR THE CONTROL OF

NONCONFORMING ITEMS 1 GENERALThis Supplement provides amplified requirements for thecontrol of nonconforming items.It supplements the requirements of Basic Requirement 15

of this Part (Part I) and shall be used in conjunction with that Basic Requirement when and to the extent specified by

the organization invoking this Part (Part I).

2 IDENTIFICATION N45.2, ¶ 2 Measures which control further processing,delivery, or installation of a nonconforming or defective item pending a decision on its disposition shall be established and maintained. - Such measures shall provide assurance that the item is identified as nonconforming and controlled.

N45.2, ¶ 3 As a guideline, control of nonconforming itemsby tagging, marking, or other means of identification is acceptable where physical segregation is not practical, although physical segregation and marking are preferred.

N18.7, ¶ 2 Measures which control further processing,delivery or installation of a nonconforming or defective item pending a decision on its disposition shall be established and maintained. - Such measures shall provide assurance that the item is identified as (a) Identification of nonconforming items shall be by marking, tagging, or other methods which shall not adversely affect the end use of the item. The identification shall be legible and easily recognizable. (b) If identification of each nonconforming item is not

practical, the container, package, or segregated storage

area, as appropriate, shall be identified.Similar requirement.

05/20/04Nonconforming Materials, Parts, or Components (Items)Page 2 of 3 CRITERION 15 ANSI 45.2-77/ANSI N18.7-76 BASIC REQUIREMENT 15 NQA-1 1994 COMMENTSnonconforming and controlled.

N18.7, ¶ 2 As a guideline, control of nonconforming itemsby tagging, marking or other means of identification is acceptable where physical segregation is not practical, although physical segregation and marking are preferred.

3 SEGREGATION N45.2, ¶ 3 As a guideline, control of nonconforming itemsby tagging, marking, or other means of identification is acceptable where physical segregation is not practical, although physical segregation and marking are preferred.

N18.7, ¶ 3As a guideline, control of nonconforming itemsby tagging, marking or other means of identification is acceptable where physical segregation is not practical, although physical segregation and marking are preferred.(a) Nonconforming items shall be segregated, whenpractical, by placing them in a clearly identified and designated hold area until properly dispositioned. (b) When segregation is impractical or impossible due to physical conditions such as size, weight, or access limitations, other precautions shall be employed to preclude inadvertent use of a nonconforming item.Similar requirement.

4 DISPOSITION

4.1 Control

N45.2, ¶ 1 Nonconforming items shall be reviewed and accepted, rejected, repaired, or reworked in accordancewith documented procedures.

N18.7, ¶ 1 Nonconforming items shall be reviewed and accepted, rejected, repaired or reworked in accordancewith documented procedures.Nonconforming characteristics shall be reviewed and recommended dispositions of nonconforming items shallbe proposed and approved in accordance with documented

procedures.Similar requirement.The four types of dispositions are

addressed in 4.4 of the NQA-1

standard N45.2, ¶ 2 Measures which control further processing,delivery, or installation of a nonconforming or defective item pending a decision on its disposition shall be established and maintained. - Such measures shall provide assurance that the item is identified as nonconforming and controlled.

N18.7, ¶ 2 Measures which control further processing,delivery or installation of a nonconforming or defective item pending a decision on its disposition shall be established and maintained. - Such measures shall provide assurance that the item is identified as nonconforming and controlled.Further processing, delivery, installation, or use of a nonconforming item shall be controlled pending anevaluation and an approved disposition by authorized

personnel.Similar requirement.

4.2 Responsibility

and Authority N45.2, ¶ 1 The responsibility and authority for thedisposition of nonconforming items shall be defined.

N18.7 - The responsibility and authority for thedisposition of nonconforming items shall be defined.The responsibility and authority for the evaluation anddisposition of nonconforming items shall be defined.Similar requirement.

05/20/04Nonconforming Materials, Parts, or Components (Items)Page 3 of 3 CRITERION 15 ANSI 45.2-77/ANSI N18.7-76 BASIC REQUIREMENT 15 NQA-1 1994 COMMENTS 4.3 PersonnelPersonnel performing evaluations to determine adisposition shall have demonstrated competence in the specific area they are evaluating, have an adequate understanding of the requirements, and have access to pertinent background information.This requirement from NQA-1 was not specifically addressed in the

corresponding sections of the ANSI Standards, but is a requirement of the

training and qualification standard.

4.4 Disposition

N45.2, ¶ 2 Nonconforming items may be disposed of byacceptance "as is," by scrapping or repairing the defective item, or by rework to complete or correct to a drawing or

specification.

N18.7, ¶2 Nonconforming items may be disposed of byacceptance "as is," by scrapping or repairing the defective item, or by rework to complete or correct to a drawing or

specification.

The disposition, such as use-as-is, reject, repair, or rework, of nonconforming items shall be identified and documented.Similar requirement.

N45.2, ¶ 2 The measures shall require documentationverifying the acceptability of nonconforming items which have the disposition of repair or use as is.

N18.7, ¶ 2 The measures shall require documentationverifying the acceptability of nonconforming items which

have the disposition of "repair" or "use as is."Technical justification for the acceptability of a nonconforming item, dispositi oned repair, or use-as-isshall be documented.Similar requirement.NQA-1 is more specific that the content of the documentation include

technical justification.Nonconformances to design requirements dispositioned

use-as-is or repair shall be subject to design control measures commensurate with those applied to the original

design.This requirement from NQA-1 was not specifically addressed in the

corresponding sections of the ANSI

Standards, but is in line with requirements of the design and procurement standards.

N45.2, ¶ 2 A description of the change, waiver, ordeviation that has been accepted shall be documented to

record the change and denote the as-built condition.

N18.7, ¶ 2 A description of the change, waiver ordeviation that has been accepted shall be documented to

record the change and denote the as-built condition.

The as-built records, if such records are required, shall reflect the accepted deviation.Similar requirement.

4.5 Repaired

or Reworked Items N45.2, ¶ 1 Repaired and reworked items shall be reinspected in accordance with applicable procedures.

N18.7, ¶ 1 Repaired and reworked items shall be reinspected in accordance w ith applicable procedures.Repaired or reworked items shall be reexamined in accordance with applicable procedures and with the original acceptance criteria unless the nonconforming item

disposition has established alternate acceptance criteria.Similar requirement.

NQA-1 further addresses the

acceptance criteria to use in the inspection/examination.

05/24/04 Corrective ActionPage 1 of 1 CRITERION 16 ANSI N45.2-77/ANSI N18.7-76 BASIC REQUIREMENT 16 NQA-1 1994 COMMENTS N45.2 § 17 / N18.7 § 5.2.11 N45.2, ¶ 1 Measures shall be established and documentedto assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances, are promptly

identified and corrected as soon as practicable.

N18.7, ¶ 1 The program shall provide measures to ensurethat conditions adverse to plant safety, such as failure, malfunctions, deficiencies, deviations, defective material and equipment, abnormal occurrences, and nonconformances are promptly identified and corrected.Conditions adverse to quality shall be identified promptly and corrected as soon as practical.Similar requirement.

NQA-1 defines "Condition adverse to quality" as "failures, malfunctions, deficiencies, deviations, defective items, and nonconformances."

N45.2, ¶ 1 In the case of significant conditions adverse toquality, the measures shall assure that the cause of the condition is determined a nd corrective action taken to preclude repetition.

N18.7, ¶ 1 In the case of significant conditions adverse tosafety, the measures shall assu re that the cause of thecondition is determined and corrective action taken -.In the case of a significant condition adverse to quality, the cause of the condition shall be determined and corrective

action taken to preclude recurrence.Similar requirement.

N45.2, ¶ 1 The identification of significant conditionsadverse to quality, the cause of the condition, and the

corrective action taken shall be documented and reported toappropriate levels of management.

N18.7, ¶ 1 -

In the case of significant conditions adverse tosafety, the measures shall assu re that the cause of thecondition is determined and co rrective action taken shall bedocumented and reported to appropriate levels ofmanagement and for independent review in accordance

with Section 4.3.

The identification, cause, and corrective action for significant conditions adverse to quality shall be documented and reported to appropriate levels ofmanagement; Similar requirement.

N18.7 addresses the need for

independent review. This is addressed under the requirements for

independent review within the QAPD.follow-up action shall be taken to verify implementation of

this corrective action.New stated requirement from NQA-1.

This is in line with the intent of the

current standards regarding corrective

action precluding recurrence.

05/24/04Quality Assurance RecordsPage 1 of 32 CRITERION 17 ANSI 45.2-77/ANSI N18.7-76/ANSI N45.2.9 BASIC REQUIREMENT 17 NQA-1 1994 COMMENTS N45.2 § 18 / N18.7 § 5.2.12 unless otherwise noted.

N45.2, ¶ 1 Sufficient records shall be prepared as work isperformed to furnish documentary evidence of the quality of items and of activities affecting quality.

N18.7, ¶ 1 Provisions shall be made for preparation and retention of plant records as appropriate.Records that furnish documentary evidence of quality shall be specified, prepared, and maintained. Similar requirement.

N45.2, ¶ 2 Required records shall be legible, identifiable, and retrievable.

N18.7, ¶ 1 American National Standard Requirements forCollection, Storage and Maintenance of Quality Assurance

Records for Nuclear Power Plants, N45.2.9-1974, shall be used for management of plant records during the

operational phase.

Records shall be legible, identifiable, and retrievable. Similar requirement.

N18.7 refers to N45.2.9 for management of records. N45.2.9 is compared with NQA-1 Basic and Supplementary Requirements below.

N45.2, ¶ 4 These records shall be indexed, filed, andmaintained in facilities that provide suitable environment to minimize deterioration or damage and to prevent loss.Records shall be protected against damage, deterioration, or loss.Similar requirement.

N45.2, ¶ 3 Requirements and responsibilities for recordtransmittal, retention, and maintenance subsequent to completion of work shall be established and documented

consistent with applicable codes, standards, and procurement documents.

N18.7, ¶ 1 The responsibility for maintaining records andstoring them at a specified location or locations shall be

assigned. Retention periods of sufficient duration to assure the ability to reconstruct significant events and satisfy any statutory requirements which apply shall be specified.

N45.2.9 § 2.

GENERAL REQUIREMENTSThis section sets forth general requirements for the controlof quality assurance records. The requirements include collection, filing, storing, maintenance and disposition of records that are required by other codes, standards, specifications, or regulatory requirements. The procedures to be employed to perform the required activities shall be planned and documented.Requirements and responsibilities for record transmittal, distribution, retention, maintenance, and disposition shall be established and documented.Similar requirement.

05/24/04Quality Assurance RecordsPage 2 of 32 CRITERION 17 ANSI 45.2-77/ANSI N18.7-76/ANSI N45.2.9 BASIC REQUIREMENT 17 NQA-1 1994 COMMENTS SUPPLEMENT 17S-1 Supplementary Requirements for Quality Assurance Records 1 GENERAL N45.2.9 § 1. INTRODUCTION

1.1 ScopeThis

standard provides general requirements andguidelines for the collection, storage, and maintenance of quality assurance records asso ciated with the design,manufacture, construction, and operation phase activities

of nuclear power plants. It is not intended to cover the preparation of the records, nor to include working documents not yet designated as quality assurance records.This Supplement provides amplified requirements for quality assurance records. It supplements the requirements of Basic Requirement 17 of this Part (Part I) and shall be used in conjunction with that Basic Requirement when and to the extent specified by the organization invoking this

Part (Part I).The requirements of this Supplement apply to quality assurance records which have been completed.The term records, used throughout this Supplement, is to be interpreted as Quality Assurance Records.

NQA-1 further addresses applicability

in the Introduction to Part I.

2 RECORDS ADMINISTRATION

2.1 Records

System N45.2.9 § 2.1 Quality Assurance Record SystemA quality assurance records system shall be established by the organization responsible at the earliest practicable time, consistent with the schedule for accomplishing work activities and in compliance with the general requirements of this standard. The quality assurance records system shall be defined, implemented and enforced in accordance with

written procedures, instructions and other documentation.A records system(s) shall be established by theorganization responsible at the earliest practicable time consistent with the schedule for accomplishing work activities and in compliance with the general requirements of this Supplement. The records system(s) shall be defined, implemented, and enforced in accordance with written procedures, instructions, or other documentation.Similar requirement.

N45.2.9 § 3. TECHNICAL REQUIREMENTS

3.1 GeneralThis

section provides requirements for the retention and

control of those records generated during the various

phases of the project.Introductory statement, no requirements specified.

2.2 Generation

of Records N45.2, ¶ 1 Records shall be consistent with applicable codes, standards, specifications, and contracts and shall be adequate for use in management of the program.

N45.2.9 § 3.2.1 Generation of Quality Assurance Records. It is not the intent of this standard to specify thepreparation of the quality assurance records to be

generated. The applicable design specifications, procurement documents, test procedures, operational The applicable design specifications, procurement documents, test procedures, operational procedures, or other documents shall specify the records to be generated, supplied, or maintained by or for the Owner.Similar requirement.

05/24/04Quality Assurance RecordsPage 3 of 32 CRITERION 17 ANSI 45.2-77/ANSI N18.7-76/ANSI N45.2.9 BASIC REQUIREMENT 17 NQA-1 1994 COMMENTSprocedures or other documents shall specify the qualityassurance records to be generated by, supplied to, or held

for the owner.

N45.2, ¶ 2 The records shall include the results of reviews,inspections, tests, audits, monitoring of work performance, materials analyses, and facility operating logs. The records shall also include, as appropriate, closely related data such

as qualifications of personnel, procedures, and equipmentand other documentation required by the applicable parts of this standard. Inspection and test records shall, as a minimum, identify the date of inspection or test, the inspector or data recorder; the type of observation, the results, the acceptability, and the action taken in connection with any deficiencies noted.

N45.2.9 § 3.2.1 All such quality assurance records shall belegible, completely filled out and adequately identifiable tothe item involved.Documents that are designated to become records shall belegible, accurate, and completed appropriate to the work accomplished.Similar requirement.

NQA-1 identifies appropriate related

data in the sections governing specific

activities.

2.3 Record

Validation N45.2.9 § 3.2.1 The applicable quality assurance recordsshall be considered valid only if stamped, initialed, signed,or otherwise authenticated and dated by authorized personnel. These records may be either the original or a reproduced copy.Documents shall be considered valid records only if stamped, initialed, or signed and dated by authorized

personnel or otherwise authenticated. This authenticationmay take the form of a statement by the responsible

individual or organization. Handwritten signatures are not required if the document is clearly identified as a statement by the reporting individual or organization. These records may be originals or reproduced copies.Similar requirement. NQA-1 further

describes authentication that allows for

electronic processing of records.

2.4 Index

N45.2.9 § 3.2.2 Index. The quality assurance records shall be listed in an index.

The records shall be indexed.Similar requirement.

N45.2.9 § 3.2.2 The index shall indicate, as a minimum,record retention times, where the records are to be stored and the location of the records within the storage area. The index should be established prior to receipt of the records.

Index systems used by organizations for the retention of project records should include sufficient identifying information to be compatible with the index system used by the owner for final storage of records.

Alternative from current VA QA Topical Report - (1)

The indexing system(s) shall include, as a minimum,record retention times and the location of the record within the record system.Similar requirement.N45.2.9 contains information for

records on a construction project and compatibility with the owner's record system. This requirement would be addressed by the purchase and interface requirements of other related standards.

The VA alternative is no longer necessary since the NQA-1 standard

05/24/04Quality Assurance RecordsPage 4 of 32 CRITERION 17 ANSI 45.2-77/ANSI N18.7-76/ANSI N45.2.9 BASIC REQUIREMENT 17 NQA-1 1994 COMMENTS With regard to Section 3.2.2 of ANSI N45.2.9-1974, titled Index: The phrase "an index" is clarified to mean acollection of documents or indices which, when taken together, supply the information attributed to "an index" in

the standard. The specific loca tion of a record "within astorage area" may not be delineated (e.g., The specific location within a computer record file may not be constant.

Further, the Company may utilize a computer assisted random access filing system where such location could not be readily "documented", nor would such a location be

"relevant"). The storage location will be delineated, but where file locations change within time, the specific location of a record within that file may not always be documented. Clarifications and alternatives meet or exceed

applicable guides and standards.addresses the indexing system(s).

Regarding the location within the system, the indexing system(s) should still get you to the location in some manner whether through a link or a file location/path, disk number and file name, or some similar, but appropriate, location description.

NQA-1 incorporates current technological advances (computer

databases, etc.)

2.5 Distribution

N45.2.9 § 3.2.3 Distribution. The quality assurance records shall be distributed and handled in accordance with

written procedures.

The records shall be distributed, handled, and controlled in

accordance with written procedures.Similar requirement.

2.6 Identification

N45.2.9 § 3.2.4 Identification. Quality assurance recordsshall provide sufficient information to permit identification between the record and the item, items, or activity to which

it applies.Records and/or indexing system(s) shall provide sufficient information to permit identification between the record and the item(s) or activity(ies) to which it applies.Similar requirement.

2.7 Classification

N45.2.9 § 2.2 CategoriesTwo categories of quality assurance records are established

- lifetime and nonpermanent.

N45.2.9 § 3.2.5 Classification. Quality assurance recordsshall be classified as "Lifetime" or "Nonpermanent" in

accordance with Section 2 of this standard.Records shall be classified as Lifetime or Nonpermanent by the Owner, or his agent wh en authorized, in accordance with the criteria given in paras. 2.7.1 and 2.7.2 below. Similar requirement.

2.7.1 Lifetime

Records.

N45.2, ¶ 4 In general, records which correctly identify theas-built conditions of items in the nuclear facility shall be maintained for the life of the particular item while it is installed in the nuclear facility and stored for future use by or for the owner. These records should include material certification and test data for traceability and quality Lifetime records are those that meet one or more of the

following criteria: (a) those which would be of significant value in demonstrating capability for safe operation;(b) those which would be of significant value in maintaining, reworking, repairing, replacing, or modifying Similar requirement.

05/24/04Quality Assurance RecordsPage 5 of 32 CRITERION 17 ANSI 45.2-77/ANSI N18.7-76/ANSI N45.2.9 BASIC REQUIREMENT 17 NQA-1 1994 COMMENTSverification; reports of inspections, examinations, and testresults for conformance verification; drawings, specifications, procedures, and instructions for use in control of configuration; and records of nonconformances, and their resolution.N45.2.9 § 2.2.1 Lifetime Quality Assurance Records

.Lifetime records are those which meet one or more of the

following criteria:

1. Those which would be of significant value in demonstrating capability for safe operation.

2. Those which would be of significant value in maintaining, reworking, repairing, replacing, or modifying the item.3. Those which would be of significant value in determining the cause of an accident or malfunction of an item.4. Those which provide required baseline data for inservice

inspection.an item;(c) those which would be of significant value in determining the cause of an accident or malfunction of an item;(d) those which provide required baseline data for in-

service inspections.

N45.2.9 § 2.2.1 Lifetime quality assurance records arerequired to be maintained by or for the plant owner for the life of the particular item while it is installed in the plant or

stored for future use.

Alternative from current VA QA Topical Report - (15)

Consistent with ANSI N45.2.9, Section 2.2, the definition of lifetime for record retention is footnoted as follows: a. Lifetime is (1) until the termination of the Facility Operating License; (2) until termination of employment (training and qualification records); (3) transfer of ownership (i.e., fuel); or (4) service life of the facility, system, or component, as applicable.Lifetime records are required to be maintained by or for the plant owner for the life of the particular item while it is

installed in the plant or stored for future use.Similar requirement.The VA definition of Lifetime Record

is retained as a definition in the new

QAPD to ensure consistent application of the QA requirements.

2.7.2 Nonpermanent

Records. N45.2.9 § 2.2.2 Nonpermanent Quality Assurance Records. Nonpermanent records are those which meet all of the following criteria:1. Those of no significant value in demonstrating capability for safe operation.2. Those of no significant value in maintaining, reworking, repairing, replacing, or modifying the item.Nonpermanent records are those required to show evidence that an activity was perform ed in accordance with theapplicable requirements but need not be retained for the life of the item because they do not meet the criteria for lifetime records. Similar requirement.NQA-1 eliminated the use of this list by referring to records that do not meet the criteria for lifetime records.

05/24/04Quality Assurance RecordsPage 6 of 32 CRITERION 17 ANSI 45.2-77/ANSI N18.7-76/ANSI N45.2.9 BASIC REQUIREMENT 17 NQA-1 1994 COMMENTS3. Those of no significant value in determining the cause ofan accident or malfunction of an item.

4. Those which do not provide baseline data for inservice

inspection.Nonpermanent records are required to show evidence that an activity was performed in accordance with theapplicable requirements but need not be retained for the life of the item.

2.8 Retention

of Records N18.7 Retention periods of sufficient duration to assure theability to reconstruct significant events and satisfy any statutory requirements which apply shall be specified.

N45.2.9 § 3.2.7 Retention of Records. Types of qualityassurance records with recommended minimum retention

periods are listed in Appendix A of this standard. It shouldbe recognized that the nomenclature of these records may vary. For records not listed in Appendix A, the type most nearly describing the record in question should be followed

with respect to its retention period.For records generated prior to commercial operation, the

retention period begins on the date of commercial operation. For records generated on items installed aftercommercial operation, the rete ntion period begins on thedate upon which satisfactory operation of the item, as part of a system, has been demonstrated. For periodic maintenance, inspection and test records, such as

calibration records, generated after the date of commercialoperation, the retention time begins on the date of their

generation. When a record is generated as a result of an operational phase activity, the classification of those records will be the same as those types of records

generated during the in itial construction period.

The organization responsible shall establish in writing theretention times of records not listed in Appendix A.(Note: The content of Appendix A is inserted at the end of this comparison table.)

Alternative from current VA QA Topical Report - (12)

With regard to Section A.6 of Appendix A to ANSI Records shall be retained in accordance with the aboveclassifications. The retention period for nonpermanent

records shall be established in writing.

NRC Reg. Guide 1.28, Rev. 3, Regulatory Position C.2.Section 2.8, "Retention of Records," of Supplement 17S-1,"Supplementary Requirements for Quality Assurance Records," states that the retention period for nonpermanent

records is required to be established in writing.

Programmatic nonpermanent records 4 should be retainedfor at least 3 years and product nonpermanent records 5should be retained for at least 10 years. For programmatic nonpermanent records, the retention period should e considered to begin upon completion of the activity. For product nonpermanent records generated before commercial operation begins, the retention period shouldbe considered to begin upon completion of delivery. In addition, product and programmatic nonpermanent records

should be retained at least until the date of issuance of the

full-power operating license of the unit. Table 1 provides a list of nonpermanent and lifetime records and their respective retention times. Although Table 1 is intended to be a comprehensive list, it is the responsibility of the

owner to assure itself, in accordance with Criterion 17 of

Appendix B to 10 CFR 50, that sufficient records are maintained to furnish evid ence of activities affectingquality. It should be recognized that the nomenclature of these records may vary. For records not listed in Table 1, the type most nearly describing the record in question

should be followed with respect to its retention period.

---

Similar requirement as far as

establishing retention periods.NQA-1 doesn't contain a mandatory Appendix listing record types and

retention periods. It does contain a nonmandatory appendix with this type of information as Appendix 17A-1.

NRC Reg. Guide 1.28 does establish a regulatory position on the types of

records and the duration or retention.The new QAP commits to meeting the record requirements of Reg. Guide

1.28. In addition a table of operations

phase records is included in the QAPD to supplement the construction phase

records of the Reg. Guide.

05/24/04Quality Assurance RecordsPage 7 of 32 CRITERION 17 ANSI 45.2-77/ANSI N18.7-76/ANSI N45.2.9 BASIC REQUIREMENT 17 NQA-1 1994 COMMENTS N45.2.9-1974 entitled, Operation Phase Activity Records

, Section A.6.1, "Operation, Maintenance & Testing," is replaced by the information in Table 17.2-2.(Note: The content of this table is inserted directly after the table of Appendix A from N45.2.9)

Alternative from current VA QA Topical Report - (13)For the collection, storage and maintenance of electronically stored QA records, see Section 17.2.17 of

the QA Topical Report.(Note: The content of Table 1 is inserted following the contents from N45.2.9, Appendix A, and the VA Table that

replaces Appendix A)

---

Footnote 4 - Programmatic nonpermanent records are those documents that were used to prescribe activities affecting quality but that are not considered permanent records. Such records include documents prescribing the

planning, execution, and auditing of activities affecting quality. Records such as audit checklists, audit results, andactual examinations used to qualify inspection and test personnel are included in this category.Footnote 5 - Product nonpermanent records document that specific structures, systems, and components of a nuclear

power plant have been d esigned and constructed in accordance with applicable requirements but are such thatit is not necessary to retain them as lifetime records. These

records include design verification data, receiving records, calibration records, mainte nance records, inspection records, radiographs not associated with inservice

inspection, and test records that are not otherwise designated as lifetime records.

2.9 Corrected

Information in Records N45.2.9 § 3.2.6 Supplemental Information to Quality Assurance Records. Quality assurance records may becorrected or supplemented in accordance with procedures

which provide for appropriate review or approval by theoriginating organization. The correction or supplement

shall include the date and the identification of the person authorized to issue such corrections or supplements.Records may be corrected in accordance with procedures which provide for appropriate review or approval by the originating organization. The correction shall include the

date and the identification of the person authorized to issue

such correction.Similar requirement.

3 RECEIPT 3.1 Responsibility N45.2, ¶ 4 These records shall be - maintained infacilities that provide suitable environment to minimize deterioration or damage and to prevent loss.

N45.2.9 § 1.3 Responsibility The organization or organi zations responsible forestablishing the applicable requirements for the activities The individual or organization responsible for receiving records shall provide protection from damage or loss during the time that the records are in their possession.Similar requirement.

05/24/04Quality Assurance RecordsPage 8 of 32 CRITERION 17 ANSI 45.2-77/ANSI N18.7-76/ANSI N45.2.9 BASIC REQUIREMENT 17 NQA-1 1994 COMMENTScovered by this standard sh all be identified and the scopeof their responsibilities shall be documented. The work of

establishing practices and procedures and providing the resources in terms of personnel, facilities, and services necessary to implement the requirements of this standard may be delegated to othe r organizations and such delegation shall also be docum ented. It is the responsibilityof each organization performing work covered by this standard to comply with requirements of this standard

applicable to its work.

N45.2.9 § 4. RECEIPT OF RECORDS

4.1 GeneralThis

section defines requirements for receipt of documentation During the design, procurement, manufacturing, installation, startup and operation of a

nuclear power plant.The designated authority or authorities for receiving quality assurance records shall be aware of the value of such records and shall control their safety during the time

that the records are in their possession.

3.2 Receipt

Control N45.2.9 § 4.3 Receipt Control Each organization responsible for the receipt of quality

assurance records shall designate a person or agency

responsible for receiving the records.

Each organization responsible for the receipt of records

shall designate a person or organization responsible for receiving the records. Similar requirement.

N45.2.9 § 4.3 The designated authority shall beresponsible for organizing and implementing a system of receipt control of quality assurance records.

The designee shall be responsible for organizing and implementing a system of receipt control of records for permanent and temporary storage. Similar requirement.

N45.2.9 § 4.3 As a minimum, a receipt control system shall include:As a minimum, a receipt control system shall include the

following:Similar requirement.

N45.2.9 § 4.3 -

1. A records check list designating therequired quality assurance records.(a) a method for designating the required records;Similar requirement.

N45.2.9 § 4.3 - 2. A record of quality assurance records received.(b) a method for identifying records received;Similar requirement.

N45.2.9 § 4.3 -

3. Procedures for receipt and inspection ofincoming records.(c) procedures for receipt and inspection of incoming

records;Similar requirement.N45.2.9 § 4.2 TimelinessTo assure their availability, a specific submittal plan shall (d) a method for submittal of completed records to the storage facility without unnecessary delay.NQA-1 broadens the requirement by not limiting it to just a supplier.

05/24/04Quality Assurance RecordsPage 9 of 32 CRITERION 17 ANSI 45.2-77/ANSI N18.7-76/ANSI N45.2.9 BASIC REQUIREMENT 17 NQA-1 1994 COMMENTSbe established for quality assurance records by agreement between the purchaser and supplier.

Alternative from current VA QA Topical Report - (2)

With regard to Section 4.2 of ANSI N45.2.9-1974, titled Timeliness: The Company's contractual agreement with its contractors and suppliers will constitute fulfillment of therequirements of this Section.

The VA alternative is no longer necessary since the "method" for submittal of completed records by a

Supplier could be through a contractual agreement.

3.3 Status

N45.2.9 § 4.3 This system shall apply to the receipt ofrecords into a temporary working file and the permanent

storage file.

N45.2.9 § 4.4 Status Each receipt control system shall bestructured to permit a current and accurate assessment of the status of quality assurance records during the receiving

process.Each receipt control system shall be structured to permit a current and accurate assessment of the status of records

during the receiving process.Similar requirement.

N45.2.9 § 5. STORAGE, PRESERVATION AND SAFEKEEPING

5.1 GeneralThis

section establishes storage requirements for themaintenance, preservation and protection of quality assurance record files from the time of receipt until theirultimate disposal.

4 STORAGE, PRESERVATION, AND SAFEKEEPINGLead in statement, no requirements.

4.1 Storage

N45.2, ¶ 1 Records shall be consistent with applicable codes, standards, specifications, and contracts and shall be adequate for use in management of the program.

N45.2.9 § 5.2 Location of FacilitiesThe quality assurance record files shall be stored in predetermined locations as necessary to meet the requirements of applicable standards, codes, and regulatory

agencies.The records shall be stored in predetermined location(s) that meet the requirements of applicable standards, codes, and regulatory agencies.Similar requirement.

N45.2.9 § 5.3 Storage -

Prior to storage of records in aquality assurance record file, a written storage procedure

shall be prepared and a custodian shall be designated with the responsibility to enforce the procedure.

Prior to storage of records, a written storage procedure shall be prepared and responsibility assigned for enforcing the requirements of that procedure.Similar requirement.

N45.2.9 § 5.3 This procedure shall include the following asa minimum:

1. A description of the storage area.This procedure shall include, as a minimum, (a) through (g) below:(a) a description of the storage facility;Similar requirement.

05/24/04Quality Assurance RecordsPage 10 of 32 CRITERION 17 ANSI 45.2-77/ANSI N18.7-76/ANSI N45.2.9 BASIC REQUIREMENT 17 NQA-1 1994 COMMENTS2. The filing system to be used.3. A method for verifying that the records received are inagreement with the transmittal document and that the

records are in good condition.4. A method of verifying that the records agree with the

pre-established records check list (see paragraph 4.3).

5. The rules governing access to and control of the files.6. A method for maintaining control of and accountability for records removed from the storage facility.7. A method for filing supplemental information (see

paragraph 3.2.6) and dispos ing of superseded records.(b) the filing system to be used;(c) a method for verifying that the records received are inagreement with the transmittal document and that the

records are legible;(d) a method of verifying that the records are those

designated (see para. 3.2 above);(e) the rules governing access to and control of the files;(f) a method for maintaining control of and accountability for records removed from the storage facility;(g) a method for filing supplemental information (see para.

2.9 above) and disposing of superseded records.

4.2 Preservation

N45.2.9 § 5.4 PreservationRecords shall be stored in a manner approved by the

organization or organizations responsible for the files.Records shall be stored in a manner approved by the

organization or organizations responsible for storage.Similar requirement.

N45.2.9 § 5.4 In order to preclude deterioration of therecords the following requirements shall apply:

In order to preclude deterioration of the records, the requirements of (a) through (c) below shall apply.Similar requirement.

N45.2.9 § 5.4 - 1. Condensation. Provisions shall be madein the storage arrangement to prevent damage from

condensation.(a) Provisions shall be made in the storage arrangement to prevent damage from moisture, temperature, and pressure.Similar requirement.

N45.2.9 § 5.4 -

2. Loose Records. Records shall not bestored loosely. They shall be firmly attached in binders or

placed in folders or envelopes for storage on shelving in

containers. Steel file cabinets are preferred.

Alternative from current VA QA Topical Report - (3)

With regard to Section 5.4 of ANSI N45.2.9-1974, titled Preservation

The following clarification is substituted for the current subsection 5.4.2: "Records shall be stored in enclosed containers, cabinets or other comparable document storage hardware."(b) Records shall be firmly attached in binders or placed in

folders or envelopes for storage in steel file cabinets or on

shelving in containers.Similar requirement.

Alternative is no longer needed. NQA-

1 allows cabinets or containers and is

broad enough of a description to include "other comparable document

storage hardware."

05/24/04Quality Assurance RecordsPage 11 of 32 CRITERION 17 ANSI 45.2-77/ANSI N18.7-76/ANSI N45.2.9 BASIC REQUIREMENT 17 NQA-1 1994 COMMENTS N45.2.9 § 5.4 -

3. Special Processed Records. Special processed records (such as radiographs, photographs, negatives, and microfilm) which are light-sensitive, pressure sensitive or temperature sensitive shall be packaged and stored as recommended by the manufacturer of these materials.

Alternative from current VA QA Topical Report - The following clarification is substituted for the current subsection 5.4.3 "Provisions shall be made for special

processed records (such as radiographs, photographs, negatives, microfilm and magnetic media) to prevent damage as appropriate to the record type and will address the manufacturer's recommendations."(c) Provisions shall be made for special processed records (such as radiographs, photographs, negatives, microform,and magnetic media) to prevent damage from excessive light, stacking, electromagnetic fields, temperature, and humidity.Similar requirement.

Alternative is no longer required.

4.3 Safekeeping

N45.2.9 § 5.5 SafekeepingA full time security system shall be established to preclude the entry of unauthorized personnel into the storage area.

Alternative from current VA QA Topical Report - (4)

With regard to Section 5.5 of ANSI N45.2.9-1974, titled Safekeeping

Routine general office and nuclear sitesecurity systems and access controls are provided.Measures shall be established to preclude the entry of

unauthorized personnel into the storage area.

NQA-1 reduced the need for a "full-time security system" to measures to "preclude the entry of unauthorized

personnel."

Alternative is no longer required.

N45.2.9 § 5.5 - This system shall guard against larceny andvandalism.These measures shall guard against larceny and vandalism.Similar requirement.Measures shall be taken to provide for replacement, restoration, or substitution of lost or damaged records.New requirement that was not

addressed in N45.2.9.

4.4 Storage

Facilities N45.2.9 § 5.6 FacilityPermanent and temporary record storage facilities shall be

so constructed or located as to protect contents from possible destruction by causes such as fire, flooding, tornadoes, insects, rodents and from possible deterioration by a combination of extreme variations in temperature and humidity conditions.

N45.2.9 § 5.6 - For storage of film and other specialprocessed records, humidity and temperature controls shall be provided to maintain an environment as recommended by the manufacturer.

Records shall be stored in facilities constructed and maintained in a manner which minimizes the risk of damage or destruction from the following: (a) natural disasters such as winds, floods, or fires; (b) environmental conditions such as high and low temperatures and humidity;(c) infestation of insects, mold, or rodents.Similar requirements.

N45.2.9 § 5.6 - A satisfactory alternative to the There are two satisfactory methods of providing storage Similar requirement.

05/24/04Quality Assurance RecordsPage 12 of 32 CRITERION 17 ANSI 45.2-77/ANSI N18.7-76/ANSI N45.2.9 BASIC REQUIREMENT 17 NQA-1 1994 COMMENTSestablishing of a record storage facility is maintenance ofduplicate records stored in a separate remote location.

facilities, single or dual.

N45.2.9 § 5.6 -

Records discussed in this standard areappropriately classified for fire protection purposes as

National Fire Protection Association Class 1 and as such

should be afforded the equivalent protection of a NFPA Class A, four hour minimum rated facility.

Alternative from Current VA Topical Report -

Regulatory Guide 1.88

- Collection, Storage and Maintenance of Nuclear Power Plant Quality Assurance Records - (Rev. 2, 10/76) -

Endorses ANSI N45.2.9-1974 The Operational QualityAssurance Program complies with this guide with the

following clarifications and alternatives:

These proposals are the results of experience gained at

operating nuclear facilities for over a decade. As with all guides and standards, additional clarity is sometimes

required. Further the alternative (6) presented herein reflects the "as-built" condition of the Company's records

storage facilities. These facilities were constructed prior to any regulatory position being defined, and, at the time of

construction, were considered more than adequate toassure permanent records re tention. The discrepancieswhich might exist between current guides and standards and "as-built" conditions are more than compensated for by other more stringent measures such as: a) constant surveillance of the facility both by monitoring devices, security patrols, and fire inspections, andb) Permanently installed dedicated fire suppression

apparatus.

Alternative from current VA QA Topical Report - (5)

With regard to Section 5.6 of ANSI N45.2.9-1974, titled Facility: Records shall be forwarded to the appropriaterecords storage facility promptly after completion when required processing and reviews have been completed.Not a requirement. Alternatives were

contained in all the current QA programs to reduce the fire protection rating down from 4 to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. This is

consistent with the NQA-1 standard as

shown below.

4.4.1 Single

Storage Facility.

N45.2.9 § 5.6 - Where a single record storage facility ismaintained, at least the following features should be Design and construction of a single record storage facility shall meet the criteria of (a) through (i) below:Similar requirement.

05/24/04Quality Assurance RecordsPage 13 of 32 CRITERION 17 ANSI 45.2-77/ANSI N18.7-76/ANSI N45.2.9 BASIC REQUIREMENT 17 NQA-1 1994 COMMENTS considered in its construction:

N45.2.9 § 5.6 -

1. Reinforced concre te, concrete block,masonry, or equal construction.(a) reinforced concrete, concrete block, masonry, or equal construction;Similar requirement.

N45.2.9 § 5.6 -

2. Concrete floor and roof with sufficient slope, for drainage; if a floor drain is provided, a check

valve (or equal) shall be included.(b) floor and roof with drainage control; if a floor drain is

provided, a check valve (or equal) shall be includedSimilar requirement.

N45.2.9 § 5.6 - 3. Structure, doors, frames and hardwareshould be Class A fire-rated with a recommended four hour minimum rating.

Alternative from current MPS QAP Topical Report -

Regulatory Guide 1.88

- Collection, Storage and Maintenance of Nuclear Power Plant Quality Assurance Records - (Rev. 2, 10/76) -Endorses ANSI N45.2.9-1974ANSI N45.2.9, states in part, "structure, doors, frames, and hardware should be Class A fire-related with a recommended four-hour minimum rating." The three record

storage vaults onsite have a two-hour rating. The licensee's vaults are used for storage of documentation that is unsuitable for filming or awaiting filming. A records

organization exists along with written procedures addressingthe control of quality assurance records.

Alternative from current VA QA Topical Report - (5)

With regard to Section 5.6 of ANSI N45.2.9-1974, titled Facility: Paragraph 4, subsection 3 is clarified to require atwo-hour minimum fire rating to be consistent with the 1979 version of the Standard and NRC Criteria for Record Storage Facilities (Guidance - ANSI N45.2.9, Section 5.6) issued 7/15/79.

Alternatives from current VA QA Topical Report regarding fire rating of existing facilities.(6) The Surry Power Station facility conforms to ANSI N45.2.9-1974 as clarified in this Table except that it is rated at approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />; doors, frames, and hardware are three-

hour rated. This facility is considered to meet the intent of ANSIN45.2.9 and provides adequate protection for records.

(7) The North Anna Power Station Records Vault meets theintent of Chapter 3 of NFPA No. 232-1975, subject to the following provisions:(a)The file room is constructed with a minimum fire rating of (c) doors, structure and frames, and hardware shall bedesigned to comply with the requirements of a minimum 2

hr fire rating;Requirement revised to a 2-hour fire

rating rather than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The

alternatives are no longer necessary since the current Company facilities all meet the two hour fire rating.

05/24/04Quality Assurance RecordsPage 14 of 32 CRITERION 17 ANSI 45.2-77/ANSI N18.7-76/ANSI N45.2.9 BASIC REQUIREMENT 17 NQA-1 1994 COMMENTStwo (2) hours.(b)Heating, cooling and ventilation for the file room isby means of a forced air system, with all fans, filters, and heating and cooling elements located in an equipment room which is external to the file room. Ducts for this system are located on the ceiling of the file room and are provided with the standard door dampers with a minimum rating of two (2) hours where they penetrate the file room barrier to other areas of the building.(c)The file room is provided with an early warning firedetection system and automatic fire suppression system. A protective signaling system is provided, with a remote alarm

located at a constantly attended station.(d)Telephone service is provided to the file room, with the

wire penetration constructed and sealed in accordance with NFPA No. 232-1975

.(e)All records stored in the file room are stored in metalcabinets or rolling file shelves, which are arranged to provide

adequate access and aisleways. Work not directly related tothe storage, retrieval or auditing of records is not allowed in the file room. Smoking, eating, and drinking is prohibited in the file room.(f) A wall divides the file room into two sections, with one section used as a file room and the other section used for microfilming of records and/or supply storage. The dividing wall has a minimum fire rating of two (2) hours, including the fire door dampers in the duct penetrating the wall.(8) The North Anna Power Station Training Center Vault meets the intent of Chapter 3 of NFPA No. 232-1975, subject to the following provisions:(a)The file room is constructed with a minimum fire rating of two (2) hours.(b)Heating, cooling and ventilation for the file room is by means of a forced air system, with all fans, filters, and heating and cooling elements located in an equipment roomwhich is external to the file room. Ducts for this system are located above the ceiling of the file room and are provided with accordion dampers with a minimum rating of two (2) hours where they penetrate the file room barrier to other areas of the building. (c)The file room is provided with an early warning fire

05/24/04Quality Assurance RecordsPage 15 of 32 CRITERION 17 ANSI 45.2-77/ANSI N18.7-76/ANSI N45.2.9 BASIC REQUIREMENT 17 NQA-1 1994 COMMENTSdetection system and automatic fire suppression system. Aprotective signaling system is provided, with a remote alarm

located at a constantly attended station.(d)Telephone service is provided to the file room, with the

wire penetration constructed and sealed in accordance with NFPA No. 232-1975.(e)All records stored in the file room are stored in metal

cabinets, which are arranged to provide adequate access and aisleways. Work not directly related to the storage, retrieval or auditing of records is not allowed in the file room. Smoking, eating, and drinking is prohibited in the file room.(9) The Innsbrook Technical Center's Vital Records Vaults for nuclear records conform to the requirements of Section 5.6 of ANSI N45.2.9-1974 as clarified in (5) above without exceptions.(10) The Surry Training Center training records vault (Main Building) conforms to the requirements of section 5.6 ANSI N45.2.9-1974 without exceptions.(11)Quality Assurance records may be stored in an approved offsite facility. The offsite facility must meet or exceed requirements of an onsite facility N45.2.9 § 5.6 - 4. Sealant applied over walls as a moisture or condensation barrier.(d) sealant applied over walls as a moisture or

condensation barrier;Similar requirement.

N45.2.9 § 5.6 -

5. Surface sealant on floor providing ahard-wear surface to minimize concrete dusting.(e) surface sealant on floor providing a hard wear surface to minimize concrete dusting;Similar requirement.

N45.2.9 § 5.6 -

6. Foundation sealant and provision for drainage.(f) foundation sealant and provisions for drainage;Similar requirement.

N45.2.9 § 5.6 - 7. Forced-air circulation with filter system.(g) forced air circulation with filter system;Similar requirement.

N45.2.9 § 5.6 - 8. Adequate fire protection system.(h) fire protection system;Similar requirement.

N45.2.9 § 5.6 -

9. No pipes other than those providing fireprotection to the storage facility are to be located within the facility.

Alternative from current VA QA Topical Report - (5)

With regard to Section 5.6 of ANSI N45.2.9-1974, titled Facility: Paragraph 4, subsection 9 is clarified to read: "No pipes or penetrations except those providing fire protection, lighting, temperature/humidity control, or communications are to be located within the facility and they shall comply with a minimum two-hour fire

protection rating.(i) only those penetrations used exclusively for fire protection, communication, lighting, or temperature/humidity control are allowed; all such penetrations shall be sealed or dampered to comply with the minimum 2 hr fire protection rating.

NQA-1 clarifies the construction of the facility to allow other penetrations.

This is in line with the VA alternative and eliminates the need for this

alternative.

The construction details shall be reviewed for adequacy of New requirement for review of the

05/24/04Quality Assurance RecordsPage 16 of 32 CRITERION 17 ANSI 45.2-77/ANSI N18.7-76/ANSI N45.2.9 BASIC REQUIREMENT 17 NQA-1 1994 COMMENTSprotection of contents by a person who is competent in the technical field of fire protection and fire extinguishing.facility design.If the storage facility is located within a building or structure, the environment and construction of that

building can provide a portion or all of these criteria.

New allowance when within another facility.4.4.2 Alternate Single Storage Facility.

NRC Reg. Guide 1.88, Regulatory Position C. 2. Twomethods for protection of quality assurance records from

the hazards of fire are described in Subdivision 5.6 of

ANSI N45.2.9-1974. NFPA No. 232-1975, "Standard for

the Protection of Records,"(2) also contains provisions for records protection equipment and records handling techniques that provide protection from the hazards of fire.

This standard, within its scope of coverage, is consideredby the NRC staff to provide an acceptable alternative to the

fire protection provisions listed in Subdivision 5.6 of

N45.2.9-1974. When NFPA No. 232-1975 is used, quality

assurance records should be classified as NFPA Class 1

records (NFPA No. 232-1975, Chapter 5, Section 5222).

The following are acceptable alternatives to the criteria of para. 4.4.1 above for a single storage facility: (a) 2 hr fire rated vault meeting NFPA 232-1986 or NFPA 232AM-1986 or both; 1(b) 2 hr fire rated Class B file containers meeting the requirements of NFPA 232-1986 or NFPA 232AM-1986 or both;1 or(c) 2 hr fire rated file room meeting the requirements of

NFPA 232-1986 or NFPA 232AM-1986 or both 1 with the following additional provisions:(1) early warning fire detection and automatic fire suppression capability with electronic supervision at a constantly attended central station; (2) records storage in fully enclosed metal cabinets;(3) adequate access and aisle ways;(4) prohibition in the room of work not directly associated with record storage or retrieval;(5) prohibition in the room of smoking, eating, or drinking;(6) 2 hr fire rated dampers or doors in all boundary

penetrations.This alternative is similar to NRC Reg.

Guide 1.88, Regulatory Position C.2.4.4.3 Temporary Storage. When temporary storage of records (such as for

processing, review, or use) is required by an organization's procedures, the records shall be stored in a 1 hr fire rated

container.The procedures shall specify the maximum allowable time limit for temporary storage.

The container shall bear a UL label (or equivalent) certifying 1 hr fire protection or be certified by a person competent in the technical field of fire protection.NQA-1 1994 Added flexibility to allow temporary storage when archiving immediately is not practical.

4.4.4 Dual Storage Facilities.

N45.2.9 § 5.6 - A satisfactory alternative to the If dual storage facilities for each record are provided, the Similar requirement.

05/24/04Quality Assurance RecordsPage 17 of 32 CRITERION 17 ANSI 45.2-77/ANSI N18.7-76/ANSI N45.2.9 BASIC REQUIREMENT 17 NQA-1 1994 COMMENTSestablishing of a record storage facility is maintenance ofduplicate records stored in a separate remote location.storage facilities shall be at locations sufficiently remote from each other to eliminate the chance of exposure to a simultaneous hazard.Each storage facility is not required to satisfy the requirements of para. 4.4.1, para. 4.4.2 or para. 4.4.3above, but shall meet the other requirements of this Part (Part I).Clarification to the above requirement that is consistent with the requirement

of N45.2.9 § 5.6 for duplicate storage.

5 RETRIEVAL N45.2.9 § 6. RETRIEVAL

6.1 GeneralThis

section is intended to establish requirements for the retrieval of documents that are stored within the quality

assurance record files.

6.2 AccessibilityStorage

systems shall provide for the accurate retrieval of information without undue delay.Storage systems shall provide for retrieval of information in accordance with planned retrieval times based upon the record type.Similar requirement.

N45.2.9 § 6.2 -

A list shall be generated designating those personnel who shall have access to the files.A list shall be maintained designating those personnel who

shall have access to the files.Similar requirement.

N45.2.9 § 6.2 - Quality Assurance records maintained by amanufacturer at his facility or other location shall be accessible to the Buyer or Owner, in the case of lifetime records for the life of the items involved or for the designated retention periods for nonpermanent records.Records maintained by a Supplier at his facility or other

location shall be accessible to the Purchaser or his

designated alternate, e.g., the Owner.Similar requirement.

6 DISPOSITION N45.2.9 § 7. DISPOSITION

7.1 GeneralThis

section is intended to provide requirements for the transfer of quality assurance records to the Owner, who has ultimate responsibility for these documents, and their

disposition.

7.2 Accumulation

and Transfer of Records.Quality assurance records accumulated at various locations prior to final transfer to the Owner shall be made accessible to the Owner directly, or through the procuring organization. Examples of such records are vendor manufacturing records, construction documentation, and

startup data. Upon final transfer, the Owner shall inventory the submittals, acknowledge receipt and process these Records accumulated at various locations, prior to transfer, shall be made accessible to the Owner directly or through

the procuring organization. The custodian shall inventory the submittals, acknowledge receipt, and process these

records in accordance with this Part (Part I).Similar requirement.

05/24/04Quality Assurance RecordsPage 18 of 32 CRITERION 17 ANSI 45.2-77/ANSI N18.7-76/ANSI N45.2.9 BASIC REQUIREMENT 17 NQA-1 1994 COMMENTS records in accordance with this Standard.N45.2.9 § 7.3 Disposition of Nonpermanent RecordsRecords classified as nonpermanent should be retained forat least the minimum period of time as recommended in Appendix A. After this time, these records may be disposed of by or with concurrence of the Owner.Various regulatory agencies have requirements concerning

records that are within the scope of this Part (Part I). The most stringent requirements shall be used in determining

the final disposition.Similar requirement.The Supplier's nonpermanent records shall not be disposed

of until the applicable conditi ons listed in (a) through (e) below are satisfied:(a) items are released for shipment, a Code Data Report is signed, or a Code Symbol Stamp is affixed;(b) regulatory requirements are satisfied;(c) operational status permits;(d) warranty consideration is satisfied;(e) Purchaser's requirements are satisfied.

NQA-1 provides additional detail on disposition of nonpermanent records from a supplier. N45.2.9 § 4.2 only addresses controlling timely turnover

of records.

N45.2.9 § 1.2 ApplicabilityThe requirements of this standard apply to the work of any

individual or organization that participates in collection, storage, or maintenance of quality assurance records

associated with nuclear power plants. The extent to which the individual or total requirements of this standard apply

will depend upon the nature and scope of the work to be performed and the importance of the item or service involved, and shall be specified in the procurement documents. The requirements are intended to assure that

records are available when needed for their intended purpose.The ASME Boiler and Pressure Vessel Code (Here-after

referred to as the Code) as well as other ANSI Standards, has been considered in the development of this standard, and this standard is intended to be compatible with theirrequirements. However, this standard does not apply to activities covered by Section III Division 1 and 2 and Section XI of the Code for those activities covered by the Code.

This standard is intended to be used in conjunction with ANSI N45.2.NQA-1 addresses applicability in the

Introduction to Part I.

N45.2.9 § 1.4 DefinitionsDefinition from Introduction to Part I - quality assurance Similar requirement.

05/24/04Quality Assurance RecordsPage 19 of 32 CRITERION 17 ANSI 45.2-77/ANSI N18.7-76/ANSI N45.2.9 BASIC REQUIREMENT 17 NQA-1 1994 COMMENTS The following definition is provided to assure a uniformunderstanding of select terms as they are used in this

standard.Quality Assurance Records - Those records which furnishdocumented evidence of the quality of items and of activities affecting quality. For the purposes of this standard a document is considered a quality assurance record when the document has been completed.Other terms and their definitions are contained in ANSI

N45.2.10.Alternative from current MPS QAP Topical Report -

ANSI N45.2.9-1974, paragraph 1.4, definition of "Quality Assurance Records" states in part: "For the purposes of thisstandard, a document is considered a quality assurance record when the document has been completed." The

licensee has developed the following alternative definition to provide guidance during the interim period from the time a document is completed until it is transmitted to the licensee records retention facilities: "A record is considered a working document until it is transmitted to the licensee records retention facilities at which time it is designated as a Quality Assurance Record. The following maximum time limits are established for the transmittal of working documents to the licensee records retention facilities: Operations Documents - Documentation generatedduring plant operations may be maintained, as needed,by operating plant departments, for up to one year. New Construction or Betterment Documents -Documents which evolve during new construction orbetterment projects shall be transmitted to licensee records retention facilities within 90 days of completion of a new construction project or turnover of a betterment

project or plant operations. Procurement Documents - Inspection/Surveillance/Audit Reports generated during vendor oversight activitieswhich are used to maintain vendor status for current and future procurements may be maintained, as needed, by Document Administration for up to three years. record - a completed documen t that furnishes evidence ofthe quality of items and/or activities affecting quality NQA-1 contains definitions in the

Introduction to Part I, § 4.The alternatives from the current QA programs are no longer needed.With regard to the time frame (in the

MPS definition) for sending a completed document to the storage facility, NQA-1 allows the organization to establish a program to address this as long as interim measures are established to protect the document.

This is a level of detail that should be contained in the administrative

controls. Reference 4.4.3 of NQA-1, Supplement 17S-1.

With regard to the VA definition, the added detail on when a document becomes a record and the disposal of records upon completion of the time frame for storage is no longer necessary with the NQA-1 standard.

Reference § 2.3 and § 6 of NQA-1, Supplement 17S-1.

05/24/04Quality Assurance RecordsPage 20 of 32 CRITERION 17 ANSI 45.2-77/ANSI N18.7-76/ANSI N45.2.9 BASIC REQUIREMENT 17 NQA-1 1994 COMMENTS All Other Working Documents - All other workingdocuments shall be transmitted to licensee recordsretention facilities within 6 months of their r eceipt orcompletion." The requirements of ANSI N45.2.9-1974 do not apply to these "working documents" based on paragraph 1.1 of the ANSI standard which states: "It (ANSI N45.2.9) is not intended to cover the preparation of the records nor to include working documents not yet designated as Quality Assurance Records." Alternative from the current VA QA Topical Report - (14)

With regard to Section 1.4 of ANSI N45.2.9-1974 entitled, Definitions. The definition of "Quality Assurance Records" is revised to the following:

"Those records which furnishdocumentary evidence of the quality of items and activities affecting quality or compliance with the NRC regulations.

Documents are considered to be quality records when thedocument has been completed, including all required

signatures, reviews, and appr ovals. At the expiration of aQA record period, the document is declassified and may be disposed of, if appropriate, as determined by Company management."

N45.2.9 § 1.5 Referenced DocumentsOther documents that are required to be included as a part of this standard are either identified at the point of

reference or described in Section 8 of this standard. The issue or edition of the referenced document that is required

will be specified either at the point of reference or in

Section 8 of this standard.

Reg. Guide 1.88, Regulatory Position C.1. Subdivision 1.5of ANSI N45.2.9-1974 states, "Other documents that are

required to be included as part of this standard are either

identified at the point of reference or described in Section 8 of this standard." The specific applicability or acceptability of these listed documents has been or will be covered separately in other regulatory guides or in Commission regulations where appropriate.The QAPD addresses other documents

referenced in the standards.

N45.2.9 § 8. REVISIONS OF REFERENCED ANSI STANDARDS The QAPD addresses what revision of a standard is to be used in implementing the QA program.

05/24/04Quality Assurance RecordsPage 21 of 32 CRITERION 17 ANSI 45.2-77/ANSI N18.7-76/ANSI N45.2.9 BASIC REQUIREMENT 17 NQA-1 1994 COMMENTSWhen any of the following standards referred to in thisdocument is superseded by a revision approved by the American National Standards Institute, the revision is not mandatory until it has been incorporated as a part of this

standard.Revisions to the referenced standards, and revisions to this

standard issued after the date of a specific contract invoking this standard may be used by mutual consent of

the purchaser and the supplier.N45.2 Quality Assurance Program Requirements for

Nuclear Power Plants N45.2.10 Quality Assurance Terms and Definitions N45.2.9 § 5.7 AuditsAn audit system shall be established to assure that the quality assurance records storage system is effective. Thefollowing shall be performed as a minimum:1 Periodic surveys to assure that records logged in are

available and have been placed in their proper location within the files, and to assure that the control system is

adequate.2. Periodic audits to assure that the facilities are in good condition and that the temperature/humidity controls and protective devices are functioning properly.

3. Periodic audits of the records to assure that the documents are not deteriorating due to improper storage

practices or rough handling.

NQA-1 addresses audits under Basic Requirement 18 and Supplement 18S-

1.

01/05/04 Page 22 of 32 ANSI N45.2.9-1974APPENDIX AThe following is a list of types of records with the recommended minimum retention periods indicated (see paragraph3.2.7). For definition of lifetime records see paragraph 2.2.1, and for nonpermanent records see paragraph 2.2.2. In thenonpermanent column the number indicates the retention period in years after which the record need not be maintained.The 0 years minimum recommended retention period is intended to permit dispositioning of the records on the dayfollowing the date of commercial operation. One year retention is intended to require maintenance of the record for thecustomary periods of warranty. Two year retention is intended to require maintenance of the record through the firstOverhaul or reload. Five and six year retention is intended to achieve compliance with regulatory requirements.

Record Types Lifetime Nonpermanent A.1 Design Records Applicable Codes and Standards Used in Design X As-Constructed Drawings X Design Calculations and Record of Checks X Design Change Requests 1 Design Deviations X Design Procedures and Manuals 2 Design Reports X Design Review Reports 1 Drawing Control Procedures 2Purchase and Design Specifications and Amendments XQA System Audit Reports 6 Reports of Engineering Surveillance of Field Activity 1Safety Analysis Report X Stress Reports XSystems Descriptions XSystems Process and Instrumentation Diagrams XTechnical Analysis, Evaluations, and Reports X A.2 Procurement Records Audit Reports 6Procurement Procedures 0Procurement Specification XPurchaser Order (Unpriced) Including Amendments 2Purchaser's Pre-Award Quality Assurance Survey 2 Receiving Records 0Supplier's Quality Assurance Program Manual 2 A.3 Manufacturing Records Applicable Code Data Reports X As-Built Drawings and Records X Certificate of Inspection and Test Personnel Qualification 0Certificates of Compliance X Cleaning Procedures 0Eddy-Current Examination Procedure 2Eddy-Current Examination Final Results X Electrical Control Verification Test Results 2 Ferrite Test Procedure 2 Ferrite Test Results XForming and Bending Procedure Qualifications 0Heat Treatment Procedures 0Heat Treatment Records X Hot Bending Procedure 0Inspection and Test Instrumentation and Tooling Calibration Procedures and Records (Until Recalibrated) 01/05/04 Page 23 of 32 Record Types Lifetime NonpermanentLiquid Penetrant Examination Procedure 2liquid Penetrant Examination Final Results X Location of Weld Filler Material XMagnetic Particle Examination Procedure 2Magnetic Particle Examination Final Results X Major Defect Repair Records X Material Properties Records XNonconformance Reports X Packaging, Receiving, Storage Procedures 0Performance Test Procedure and Results Records X Pipe and Fitting Location Report X Pressure Test Procedure 2 Pressure Test Results XProduct Equipment Calibration Procedure (Until Recalibrated)Product Equipment Calibration Records (Until Recalibrated)QA System Audit Report 6 QA Manuals, Procedures and Instructions 2 Radiographic Procedures 2Radiographic Review Forms and Radiographs XUltrasonic Examination Procedures 2Ultrasonic Examination Final Results X Welding Materials Control Procedures 2 Welding Personnel Qualification 2 Welding Procedure Qualifications and Data Reports 2 Welding Procedures XWork Processing and Sequencing Documents 2 A.4 Installation-Construction Records A.4.1 Receiving and StorageInspection Reports for Stored Items 0Nonconformance Reports XReceipt Inspection Reports on Items 1 Receiving, Storage, and Inspection Procedures 2Storage Inventory and Issuance Records 0Vendor Quality Assurance Releases 0 A.4.2 Civil Aggregate Test Reports 1 Batch Plant Operation Reports 1Cement Grab Sample Reports 0 Check-Off Sheets for Tendon Installation XConcrete Cylinder Test Reports and Charts X Concrete Design Mix Reports XConcrete Placement Records X Inspection Reports for Channel Pressure Tests XMaterial Property Reports on Containment Liner and Accessories XMaterial Property Reports on Metal Containment Shell and Accessories XMaterial Property Reports on Reinforcing Steel XMaterial Property Reports on Reinforcing Steel Splice Sleeve Material XMaterial Property Reports on Steel Embedments in Concrete XMaterial Property Reports on Steel Piling 1Material Property Reports on Structural Steel and Bolting XMaterial Property Reports on Tendon Fabrication Material XMix Water Chemical Analysis 1

01/05/04 Page 24 of 32 Record Types Lifetime Nonpermanent Pile Drive Log X Pile Loading Test Reports XProcedure for Containment Vessel Pressure-Proof Test and Leak Rate Tests and Results X Reinforcing Steel Splice Operator Qualification Reports 0 Releases to Plate Concrete 0 Reports for Periodic Tendon Inspection X Reports of High-Strength Bolt Torque Testing 1Slump Test Results 0Soil Compaction Test Reports X User's Tensile Test Reports on Reinforcing Steel 1User's Tensile Test Reports on Reinforcing Steel Splices 1 A.4.3 Welding Ferrite Test Procedures 2 Ferrite Test Results XHeat Treatment Procedures 0Heat Treatment Records X Liquid Penetrant Test Procedures 2 Liquid Penetrant Test Final Results X Magnetic Particle Test Procedures 2 Magnetic Particle Test Final Results X Major Weld Repair Procedures and Results X Radiographic Test Procedures 2 Radiographic Test Final Results X Ultrasonic Test Procedures 2 Ultrasonic Test Final Results X Weld Fit-Up Reports 1Weld Location Diagrams 2 Weld Procedures X Weld Procedures Qualifications and Results 2 Welding Filler Metal Material Reports X Welding Materials Control Procedures 2 Welding Personnel Qualifications 2 A.4.4 MechanicalChemical Composition User's Test (Grab Samples) for Thermal Insulation 1Chemical Tests of Water Used for Mixing Insulation Cement 1 Cleaning Procedures and Results 1 Code Data Reports X Construction Lifting and Handling Equipm ent Test Procedures, Inspection and Test Data 0Data Sheets or Logs on Equipment Installation, Inspection and Alignment 2Documentation of Systems Check-Off (Logs or Data Sheets) 1Erection Procedures for Mechanical Components 1Hydro-Test Procedures and Results XInstalled Lifting and Handling Equipmen t Procedures, Inspection and Test Data X Lubrication Procedures X Lubrication Records XMaterial Property Records XMaterial Property Test Reports for Thermal Insulation X Pipe and Fitting Location Reports XPipe and Fittings Material Property Reports X Pipe Hanger and Restraint Data X

01/05/04 Page 25 of 32 Record Types Lifetime NonpermanentSafety Valve Response Test Procedures XSafety Valve Response Test Results 6 A.4.5 Electrical and I&C Cable Pulling Procedures 0 Cable Separation Check Lists 1 Cable Splicing Procedures XCable Terminating Procedures X Certified Cable Test Reports XDocumentation of Testing Performed After Installation and Prior to Systems Conditional Acceptance 2Field Workmanship Checklist or Equivalent Logs 1Instrument Calibration Results (Until Recalibrated)Relay Test Procedures and Results X Reports of Preinstallation Tests 2 Voltage Breakdown Tests on Liquid Insulation X A.4.6 General"As-Built" Drawings and Records XCalibration of Measuring and Test Equipment and Instruments Procedures and Reports (Until Recalibrated)

Certificate of Inspection and Test Personnel Qualification 1 Field Audit Reports 6Field Quality Assurance Manuals 2 Final Inspection Reports and Releases XNonconformance Reports X Special Tool Calibration Records (Until Recalibrated)

Specifications and Drawings X A.5 Preoperational and Startup Test RecordsAutomatic Emergency Power Source Transfer Procedures and Results XFinal Systems Adjustment Data X Flushing Procedures and Results 2Hydrostatic Pressure Test Procedures and Results X Initial Heatup, Hot Functional a nd Cooldown Procedures and Results X Initial Plant Loading Data XInitial Reactor Criticality Test Procedures and Results XInstrument AC Systems and Inverters Test Procedures and Reports XMain and Auxiliary Power Transformer Test Procedures and Results X Off-Site Power-Source Energizing Procedures and Test Reports XOn-Site Emergency Power Source Energizing Procedure and Test Reports XPlant Load Ramp Change Data X Plant Load Step Change Data XPower Transmission Substation Test Procedures and Results X Preoperational Test Procedures and Results XPrimary and Secondary Auxiliary Power Test Procedures and Results XReactor Protection System Tests and Results X Startup Logs XStartup Problems and Resolutions 6 Startup Test Procedures and Results XStation Battery and DC Power Distribution Test Procedures and Reports XSystem Lubricating Oil Flushing Procedures 2Water Chemistry Reports X A.6 Operation Phase Activity Records A.6.1 Operation, Maintenance and Testing 01/05/04 Page 26 of 32 Record Types Lifetime Nonpermanent Records and Drawing Changes Reflecting Plant Design Modifications Made toSystems and Equipment Described in the Final Safety Analysis Report XNew and Spent Fuel Inventory, Transfers of Fuel, and Assembly Histories XPlant Radiation and Contamination Survey Records XOff-Site Environmental Monitoring Survey Records X Radiation Exposure Records of All Pl ant Personnel, and Others who Enter Radiation Control Areas XRadioactivity Levels of Liquid and Gaseous Waste Released to Environment XTransient or Operational Cycling Records for Those Plant Components That HaveBeen Designed to Operate Safely for a limited Number of Transients or Operational Cycles XCurrent Individual Plant Staff Member Qualifications, Experience, Training and Retraining Records XReactor Coolant System In-Service Inspection Records XMinutes of Meetings of the Plant Nuclear Safety Committee and Company Nuclear Review Board XNormal Nuclear Unit Operation, Including Power Levels and Periods of Operation at Each Power Level 5 Principal Maintenance Activities, Incl uding Inspection Repair, Substitution orReplacement of Principal Items of Equipment Pertaining to Nuclear Safety 5Abnormal Occurrence Records 5Periodic Checks, Inspections and Calibrations Performed to Verify thatSurveillance Requirements are Being Met 5Special Reactor Test or Experiment Records 5 Changes Made in the Operating Procedures 5Radioactive Shipment Records 5 Alternative table of records retention requirements from current VA QA Topical Report related to Appendix A of ANSI N45.2.9-1974 Table 17.2-2 RECORDS RETENTION REQUIREMENTS Description of Records (Operational Phase Activities)

Retention PeriodRecords and drawing changes reflecting plant design modifications made to systems and equipment described in the final safety analysis reportLifetime a (1)Records of new and spent fuel inventory, transfers of fuel, and assemblies historiesLifetime a (1) plus 3 yearsRecords of plant radiation and contamination surveysLifetime a (1)Records of off-site environmental monitoring surveysLifetime a (1)Records of radiation exposure of all plant personnel, and others who enter radiation control areasLifetime a (1)Records of radioactive levels of liquid and gaseous waste released to the environmentLifetime a (1)Records of transient or operational cycles for those plant components that have beendesignated to operate safely for a limited number of transients or operational cyclesLifetime a (4)Records of inservice inspectionsLifetime a (4)Records of meetings of the Station Nuclear Safety and Operating Committee and theManagement Safety Review CommitteeLifetime a (1)Records of the service lives of all hydraulic and mechanical snubbers on safety-related systems, including the date at which the service life commences and associatedinstallation and maintenance recordsLifetime a (4)Records of secondary water sampling and water quality Lifetime a (1)Records of Environmental Qualification in accordance with 10 CFR 50.49 Lifetime a (1)Records of reviews performed for changes made to the offsite dose calculation manual and the process control programLifetime a (1) 01/05/04 Page 27 of 32 Table 17.2-2 RECORDS RETENTION REQUIREMENTS Description of Records (Operational Phase Activities)

Retention PeriodRecords of normal plant operation, including power levels and periods of operation at each power level5 yearsRecords of principal maintenance activities, including inspection, repair, substitution orreplacement of principal items of equipment related to nuclear safety5 years Reportable events reports 5 years Records of periodic checks, inspections, and calibrations performed to verify thatsurveillance requirements are being met 5 yearsRecords of special reactor tests or experiments 5 yearsRecords of changes made in procedures pursuant to 10 CFR 50.59 5 yearsRecords of Audits Performed to 10 CFR 50, Appendix B, Quality Assurance Program5 yearsRecords of radioactive material shipments 3 yearsRecords of sealed source leak test results and physical inventories of sealed sources material 5 yearsRecords of current individual plant staff members qualifications, experience, training and

retraining Lifetime or as noted below* Radiological protection training records (e.g., Nuclear Employee Training, Advanced

Radiation Worker, Radiation Protection Technician, etc.)Lifetime a (1)* Initial training and qualification recordsLifetime a (2)* Requalification records (excepted licensed individuals)3 cycles* Requalification records for licensed individuals6 years after license

renewal* Training materials - Revision 0 recordsLifetime a (1)-- Plant Staff training materials - Superceded Revisions3 cycles-- Licensed Operators training materials - Superceded Revisions6 years-- Radiation Protection training materials - Superceded RevisionsLifetime a (1)* Retraining, specialized training, continuing training records (except licensed individual

and Radiological Protection technicians)3 cycles* Contractor training (except Nuclear Employee Training, Advanced Radiation Worker, Radiation Protection Technician training and retraining etc.)3 cycles* INPO Accreditation records Initial accreditations -

Lifetime a (1) andsuperceded material - 4 years* Simulator facility records (e.g., certification and basis documents, NRC Form-474, performance test, fidelity reports, maintenance and modifications, and basis documents, etc.)Initial accreditation records

- Lifetime a (1) andsuperceded material - 4 years after submittal of NRC Form-474a. Lifetime - is (1) until the termination of the Facility Operating License, (2) until termination of employment (training and qualification records); (3) transfer of ownership (i.e., fuel); or (4) service life of the facility, system, or component, as applicable.

01/05/04 Page 28 of 32 NRC Reg. Guide1.28 - Rev. 3, Regulatory Position C.2 TABLE 1Retention Times for Lifetime and Nonpermanent Records Nonpermanent*

Record Type Lifetime 3 yr.10 yr.1.Design Records Applicable codes and standards used in deign X Design drawings X Design calculations and, record of checks X Approved design change requests XDesign deviations and nonconformances X Design reports X Design verification data XDesign specifications aid amendments XSafety analysis report XCertified stress reports for code items XSystem descriptions XSystem process and instrumentation diagrams XTechnical analysis, evaluations, and reports X Master change record XReliability analysis, evaluation, and reports XEquipment qualification documentation X Design review reports XDesign procedures and manuals X Design control procedures X Reports of engineering surveillance of field activity X2. Procurement RecordsProcurement specification XPurchase order (unpriced) including amendments XProcurement procedures XPurchaser's pre-award quality assurance survey X Receiving records XSupplier's quality assurance program manual X Source surveillance data plans, audit and surveillance reports X 3. Manufacturing Records Applicable code data reports X As-built drawings and records XCertificate of compliance XEddy-current examination final results X Electrical control verification test results X Ferrite test results XHeat treatment records XLiquid penetrant examination final results XLocation of weld filler material XMagnetic particle examination final results X Major defect repair records X Material properties records XNonconformance reports XPerformance test procedure and results records X Pipe and fitting location report XPressure test results (hydrostatic or pneumatic)

X Radiograph review records X

01/05/04 Page 29 of 32 Nonpermanent*

Record Type Lifetime 3 yr.10 yr.Ultrasonic examination final results X Welding procedures XRadiographs not required by ASME Section Xl X Certificate of inspection and test personnel qualification X Cleaning procedures XEddy-current examination procedure X Ferrite test procedure XForming and bending procedure qualifications XHeat treatment procedures X Hot bending procedure XInspection and test instrumentation and tooling calibration records (after last calibration)

XLiquid penetrant examination procedure XMagnetic particle examination procedure X Packaging, receiving, storage procedures XProduct equipment calibration procedure XQA manuals, procedures, and instructions X Radiographic procedures XUltrasonic examination procedures XWelding materials control procedures X Welding procedure qualifi cations and data reports XWork processing and sequencing documents XProduct equipment calibration records (after last calibration)

X Installation Construction Records

4.1 Receiving

and StorageNonconformance reports XInspection reports for stored items XReceipt inspection reports on items X Receiving, storage, and inspection procedures XStorage inventory and issuance records XVendor quality assurance releases X 4.2 Civil Checkoff sheets for tendon installation XConcrete cylinder test reports and charts XConcrete design mix reports XConcrete placement records X Inspection reports for channel pressure tests XMaterial property reports on containment liner and accessories XMaterial property reports on metal containment shell and accessories XMaterial property reports on reinforcing steel XMaterial property reports on reinforcing steel splice sleeve material XMaterial property reports on steel embedments in concrete XMaterial property reports on structural steel and bolting XMaterial property reports on tendon fabrication material X Pile drive log X Pile loading test reports XProcedure for containment vessel pressure proof test and leak-rate tests and results X Reports for periodic tendon inspection X Reports of high-strength bolt torque testing XSoil compaction test reports X Aggregate test reports X

01/05/04 Page 30 of 32 Nonpermanent*

Record Type Lifetime 3 yr.10 yr.Batch plant operation reports XCement grab sample reports XMaterial property reports on steel piling XMix water chemical analysis X Releases to place concrete XSlump test results X User's tensile test reports on reinforcing steel XUser's tensile test reports on reinforcing steel splices X4.3Welding Ferrite test results XHeat treatment records X Liquid penetrant test final results XMaterial property records X Magnetic particle test final results X Major weld repair procedure and results X Radiograph review records and final results X Ultrasonic test final results XWeld location diagrams X Weld procedures XWelding filler metal material reports X Ferrite test procedures XHeat treatment procedures X Liquid penetrant test procedures X Magnetic particle test procedures X Radiographic test procedures X Ultrasonic test procedures XWelding materials control procedures X Welding personnel qualifications X Weld fitup reports X Weld procedure qualifications and results X 4.4 Mechanical Cleaning procedures and results XInstalled lifting and handling equipment procedures, inspection, and test data X Lubrication procedures X Material properties records X Pipe and fitting location reports X Pipe hanger and restraint data ...

XSafety valve response test procedures X Code data reports XPressure test results (hydrostatic or pneumatic)

XChemical composition user's test (grab samples) for thermal insulation XChemical tests of water used for mixing insulation cement XData sheets or logs on equipment installations inspection, and alignment XDocumentation of system checkoffs (logs or data sheets)

XMaterial property test reports for thermal insulation XSafety valve response test results X Cleaning procedures X Construction lifting and handling equipment test procedures XErection procedures for mechanical components XHydrotest procedures X 4.5 Electrical and Instrumentation and Control 01/05/04 Page 31 of 32 Nonpermanent*

Record Type Lifetime 3 yr.10 yr.Cable pulling tension data X Cable separation data XCable terminating procedures X Certified cable test reports XRelay test procedures and test results X Voltage breakdown test results on liquid insulation X Cable pulling procedures X Cable separation checklists XInstrument calibration results (after last calibration)

XDocumentation of testing performed afte r installation and prior to conditionalacceptance of systems XField workmanship checklist or equivalent logs X Reports of preinstallation tests X 4.6 General As-built drawings and records X Final inspection reports and releases XNonconformance reports X Specifications and drawings XIndex system to record file XQuality assurance and quality control manuals X Fire protection reports XSecurity plan procedures and activities XEmergency plan, procedures, and activities X Evaluation of results of reportable safety concerns as required by regulations XCalibration reports for measuring and test equipment and instruments (after last calibration)

XCalibration procedures for measuring and test equipment and instruments X Certificate of inspection and test personnel qualification X Field audit reports XField quality assurance manuals XQuality assurance system audit re ports and related correspondence X Special tool calibration records (after last calibration)

X 5. Preoperational and Startup Test RecordsFinal system adjustment data X Initial plant loading data XPlant load ramp change data X Plant load step change data X Preoperational test procedures and results XReactor protection system tests and results X Startup test procedures and results X Inservice inspection reports XRecords of reactor tests and experiments XRecords and logs of maintenance activities, inspections, repair, mid replacement ofprincipal items of structures, systems, and components XAutomatic emergency power source transfer procedures and results X Initial heatup, hot functional, a nd cooldown procedures and results XInitial reactor criticality test procedures and results XInstrument AC system and inverter test procedures and reports XMain and auxiliary power transformer test procedures and results X Offsite power source energizing procedures and test reports XOnsite emergency power source energizing procedure and test reports X

01/05/04 Page 32 of 32 Nonpermanent*

Record Type Lifetime 3 yr.10 yr.Primary and secondary auxiliary power test procedures and results X Startup logs XStation battery and DC power dist ribution test procedures and reports XWater chemistry report XRecords of reviews performed for changes made to procedures or equipment orreviews of tests and experiments XStartup problems and resolutions X Flushing results XPower transmission substation test procedures and results X Surveillance activities. inspections, and calibrations required by the technical specifications records XSystem lubricating oil flushing procedures X Flushing procedures X Pressure test procedures X Periodic checks, inspections, and calibrations performed to verify that surveillancerequirements are being met X* Table 1 is to be used in conjunction with Regulatory Position C.2, which states that nonpermanent records should be retained at least until the date of issuance of the full-power operating license of the unit.

05/24/04AuditsPage 1 of 22 CRITERION 18 ANSI N45.2-77/N45.2.12-77 /ANSI N18.7-76 BASIC REQUIREMENT 18 NQA-1 1994 COMMENTS N45.2 § 19 / N18.7 § 4.5 , unless noted otherwise.

Reg. Guide 1.144, C. Regulatory Position - Therequirements that are include in ANSI/ASME N45.2.12-1977 for auditing quality assurance programs for nuclear

power plants are acceptable to the NRC staff and provide an adequate basis for complying with the pertinent quality assurance requirements of Appendix B to 10 CFR 50.

Reg. Guide 1.28 addresses the Regulatory Position on quality assurance audit requirements relative to

NQA-1.N45.2 ¶ 1 A comprehensive system of planned anddocumented audits shall be carried out to verify compliancewith all aspects of the Quality Assurance Program.

N18.7 A comprehensive system of planned and documentedaudits shall be carried out to verify compliance with all aspects of the administrative controls and quality assurance program.N45.2.12 § 3. AUDIT SYSTEM - 3.1 General - This sectionestablishes requirements for a comprehensive audit system

which shall be planned, documented, and implemented toverify compliance with the elements of a quality assurance program. -

N45.2.12 § 3.4 Audit Planning - The audit system, including both internal and external audits, shall be planned,documented, and conducted to assure coverage of theapplicable quality assurance program, and overall

coordination and scheduling of audit activities.

Planned and scheduled audits shall be performed to verifycompliance with all aspects of the quality assurance program and to determine its effectiveness.Similar requirements.

N45.2 ¶ 1 The audits shall be performed in accordance withwritten procedures or check lists by appropriately trained

personnel not having direct responsibilities in the areas being

audited.N18.7 ¶ 3 Those performing the audits may be members ofthe audited organization; however, they shall not audit activities for which they have immediate responsibility.

While performing the audit, they shall not report to a management representative who has immediate responsibility for the activity being audited.

N45.2.12 § 3. AUDIT SYSTEM - 3.1 General - - The auditsystem shall be described in approved, written policies, plans, procedures, instructions, or such other documents as

appropriate.

N45.2.12 § 4. AUDIT IMPLEMENTATION - 4.1 General -

These audits shall be perform ed in accordance with writtenprocedures or checklists by pe rsonnel who do not have directresponsibility for performing the activities being audited.Similar requirements. N18.7 is more

prescriptive regarding use of line personnel to perform audits.

05/24/04AuditsPage 2 of 22 CRITERION 18 ANSI N45.2-77/N45.2.12-77 /ANSI N18.7-76 BASIC REQUIREMENT 18 NQA-1 1994 COMMENTSIndividual audits shall be implemented as scheduled and planned in Section 3.

N45.2 ¶ 1 Audit results shall be documented by auditing personnel and shall be reviewed by management havingresponsibility in the area audited.

N18.7 ¶ 2 Written reports of such audits shall be reviewed bythe independent review body and by appropriate members ofmanagement including those having responsibility in the area

audited.Audit results shall be docum ented and reported to andreviewed by responsible management.Similar requirements. N18.7 adds requirement for review by independent review body. Independent review is

addressed in the QAPD, Appendix B.

N45.2 ¶ 1 Responsible management shall take necessaryaction to correct the deficiencies revealed by the audit.

N18.7 ¶ 3 Appropriate and timely followup action, -, shall be taken.Follow-up action shall be taken where indicated.Similar requirements.

SUPPLEMENT 18S-1 SUPPLEMENTARY

REQUIREMENTS FOR AUDITSANSI N45.2.12-1977 provides much of the supplemental information for audits

found in N45.2 and NQA-1.

1 GENERAL N45.2.12 This standard provides requirements and guidancefor establishing and implementing a system of internal and external audits of quality assurance programs for nuclear power plants, including the preparation, performance, reporting, and follow-up of audits by both the auditing and

audited organizations.This Supplement provides amplified requirements for quality

assurance audits.

N45.2.12 This standard amplifies the audit requirements of ANSI N45.2 and shall be used in conjunction with that

standard.It supplements the audit requirements of Basic Requirement

18 of this Part (Part I) and sh all be used in conjunction withthat Basic Requirement when and to the extent specified by

the organization invoking this Part (Part I).

N45.2.12 § 3.5 Scheduling 2 SCHEDULING N45.2 ¶ 6 Audits should be conducted periodically or on arandom, unscheduled basis, or both.

N45.2.12 § 3.5.1 Auditing shall be initiated as early in thelife of the activity as practicable, consistent with the schedule for accomplishing the activity, to assure timely implementation of quality assurance requirements. In any case, auditing shall be initiated early enough to assure effective quality assurance during the design, procurement

and contracting activities.

N45.2.12 § 3.4 Audit Planning - The audit system, including Internal or external quality assurance audits, or both, shall bescheduled in a manner to provi de coverage and coordinationwith ongoing quality assurance program activities.Similar requirement.NQA-1 uses the term schedule in place of the term plan used by the ANSI

standards to address the overall audit

plan (not to be confused with the

individual audit plans).

Reg. Guide 1.28 provides the Regulatory Position on Scheduling.

This position affects several of the requirements of this section, but to

05/24/04AuditsPage 3 of 22 CRITERION 18 ANSI N45.2-77/N45.2.12-77 /ANSI N18.7-76 BASIC REQUIREMENT 18 NQA-1 1994 COMMENTS both internal and external audits, shall be planned,documented, and conducted to assure coverage of theapplicable quality assurance program, and overall

coordination and scheduling of audit activities. - prevent repeating the information, it is

inserted in the next cell to align with the Regulatory Position from Reg. Guide

1.144.N45.2.12 § 3.5.2 Audits shall be regularly scheduled on thebasis of the status and importance of the activities to assure the adequacy of, and conformance with, the program.

N18.7 ¶ 1 Audits of selected aspects of operational phaseactivities shall be performed with a frequency commensurate with their safety significance and in such a manner as to assure that an audit of all safety-related functions is completed within a period of two years.

Alternative from current MPS QA Topical Report ANSI N18.7-1976, paragraph 4.5, states in part, 'Audits of selected aspects of operational phase activities shall beperformed with a frequency commensurate with their safety significance and in such a manner as to assure that an audit of all safety-related functions is completed within a period oftwo years.'The licensee has established a 90 day grace period applied to the 24 month frequency for internal audits. This grace period will not be applied to audits of the Emergency Preparedness Program which satisfy the requirements of 10CFR50.54(t) or to audits of the Security Plan which satisfy the requirements

of 10CFR50.54(p)(3) 73.56(g)(1) and (g)(2), and 73.55(g)(4). The audit frequency of these audits are

described in their respective pl ans. For activities deferred inaccordance with the 90 day grace period, the next performance due date for such activities will be based on

their original scheduled date, i.e., in all cases the periodicity

for these activities will not be a llowed to exceed the originalcommitment plus 90 days."

Alternative from the current VA QA Topical Report.

(2) Paragraph C.4 (Audit Program) of Regulatory Guide 1.33 (and Section 4.5 of ANSI N18.7-1976 which it references) will be implemented as required by the applicable nuclear facility Technical Specifications, Emergency Plan, Security Plan, Fitness for Duty Program, and administrative controls which designate the minimum Audits shall be scheduled at a frequency commensurate with the status and importance of the activity.

NRC Reg. Guide 1.28, Regulatory Position 3. Audits:Section 2, "Scheduling," of Supplement 18S-1, "Supplementary Requirements for Audits," requires audits to be scheduled in a manner that provides coverage and coordination with ongoing quality assurance program

activities. The following guidelines are considered

acceptable for scheduling audits:

3.1 Internal

AuditsApplicable elements of an organization's quality assurance program should be audited at least once each year or at least once during the life of the activity, whichever is shorter. In determining the scope of the audit, an evaluation of the activity being audited may be useful. The evaluation may include results of previous quality assurance program audits and the results of audits from other sources, including the nature and frequency of identified deficiencies and any

significant changes in personnel, organization, or quality assurance program.

3.2 External

AuditsAfter the award of a contract, the applicant or licensee may determine, based on the evaluation conducted in accordance

with Section 5.1 of Appendix 4A-1, that external audits are not necessary for procuring items that are (1) relatively simple and standard in design, manufacturing, and testing and (2) adaptable to standard or automated inspections or tests of the end product to verify quality characteristics after delivery.For other procurement actions not covered by the above

exceptions, audits should be conducted as described below.

1. The applicant or licensee should either audit its supplier's quality assurance program on a triennial basis or arrange for such audit. In either case, the audit should be implemented in accordance with Supplement 18S-1 of ANSI/ASME NQA-1 doesn't establish a minimum frequency. Frequency commensurate

with the Reg. Guides and previous

alternatives is addressed in the text of

the QAPD.The grace period for the frequencies is

addressed through the Definitions of the

QAPD.Necessary alternatives are addressed

through the new QAPD, Appendix C.Additional information is contained in NQA-1 as nonmandatory guidance of

Appendix 18A-1 § 2.3.Where the regulatory guide refers to NQA-1-1983, Dominion will use NQA-

1-1994 as described in the QAPD.

05/24/04AuditsPage 4 of 22 CRITERION 18 ANSI N45.2-77/N45.2.12-77 /ANSI N18.7-76 BASIC REQUIREMENT 18 NQA-1 1994 COMMENTSareas to be audited. The audit program is further defined andwill be implemented as required by the commitment to ANSI

N45.2.12 as stated in Table 17.2.0 of the Operational Quality Assurance Program. Paragraph C.4.c of Regulatory Guide

1.33 (and ANSI N18.7 to which it references) will be implemented as clarified in Section 17.2.18 of the Operational Quality Assurance Program Topical Report.

Specifically, the frequency for conducting audits of the performance, training, and qualifications of the facility staff may vary based on performance and the safety significance of the audited activity but will not be less frequent than biennial (2 years).

Reg. Guide 1.144 , C.3. - Section 3.5.2 of ANSI/ASMEN45.2.12-1977 requires that audits of quality assurance activities be regularly scheduled to ensure that the quality assurance program is adequate and that activities are being performed in accordance with the quality assurance program.The frequency of the scheduling of audits is dependent onthe status and importance of the activities to be audited, and

the following is considered acceptable scheduling:

a. Internal Audits - (1) Operational Phase Activities-Regulatory Guide 1.33, "Quality Assurance Program Requirements (Operation)," s hould be followed. (2) Designand Construction Phase Activities-Applicable elements of an organization's quality assurance program should be audited at least annually or at least once within the life of the activity, whichever is shorter.

b. External Audits - (1) External audits, after the award of a contract, are not necessary for procurement actions when the items or services are all of the following: (a) Relatively simple and standard in design, manufacture, and test, and (b)

Adaptable to standard or automated inspections or tests of the end product to verify quality characteristics after delivery, and (c) Such that receiving inspection does not

require operations that could adversely affect the integrity,function, or cleanness of the item. (2) For other procurement actions not listed in Item C.3.b.(1), audits should be

conducted as follows:Elements of a supplier's quality assurance program should NQA-1-1983. The triennial period begins when an audit is performed. An audit may be performed when the supplier has completed sufficient work to demonstrate that its organization is implementing a quality assurance program

that has the required scope for purchases placed during the

triennial period. If a subsequent contract or a contract modification significantly enlarges the scope of or changes the methods or controls for activities performed by the same supplier, an audit of the modified requirements should be

conducted, thus starting a new tr iennial period. If the supplieris implementing the same quality assurance program for other customers that is proposed for use on the auditing party's contract, the pre-award survey may serve as the first

triennial audit if conducted in accordance with the requirements of ANSI/ASME NQA-1-1983. Therefore, when such pre-award surveys are employed as the firsttriennial audits, they should satisfy the same audit elements

and criteria as those used on other triennial audits.2. The applicant or licensee should perform or arrange for

annual evaluations of supplie rs. This evaluation should bedocumented and should take in to account, where applicable,(1) review of supplier furnished documents and records such as certificates of conformance, nonconformance notices, and

corrective actions; (2) results of previous source

verifications, audits, and recei ving inspections; (3) operatingexperience of identical or similar products furnished by the same supplier; and (4) results of audits from other sources, e.g., customer, ASME, or NRC audits.3. If more than one purchaser buys from a single supplier, a purchaser may either perform or arrange for an audit of the

supplier on behalf of itself and other purchasers to reduce the number of external audits of the supplier. The scope of this audit should satisfy the needs of all of the purchaser, and the

audit report should be distributed to all the purchasers for whom the audit was conducted. Nevertheless, each of the purchasers relying on the results of an audit performed on behalf of several purchasers remains individually responsible for the adequacy of the audit.

05/24/04AuditsPage 5 of 22 CRITERION 18 ANSI N45.2-77/N45.2.12-77 /ANSI N18.7-76 BASIC REQUIREMENT 18 NQA-1 1994 COMMENTSbe audited by the purchaser on a triennial basis with the auditimplemented in accordance with Section 4, "Audit Implementation," of ANSI/ASME N45.2.12-1977. The triennial period should begin with performance of an audit when sufficient work is in progress to demonstrate that the organization is implementing a Quality Assurance Program

having the required scope for purchases placed during the

triennial period.

N45.2.12 § 3.4 Audit Planning - - The audit system shallbe periodically reviewed, and revised as necessary, to assure

that coverage and schedule reflect current activities.

N18.7, ¶ 4 Periodic review of the audit program shall beperformed by the independent review body or by a management representative at least semiannually to assure that audits are being accomplished in accordance with requirements of technical specifications and of this Standard.The audit schedule shall be reviewed periodically and revised as necessary to assure that coverage is maintained

current.Similar requirement.

N18.7 assigns the review responsibility to the independent review body or a management representative and

specifies the review to be at least semiannually. Addressed in the QAPD by the Section on Independent Review (Appendix B).

N45.2 ¶ 6 Audits should be conducted periodically or on arandom, unscheduled basis, or both. It is desirable to conduct audits when one or more of the following conditions exist:(1) When it is necessary to determine the capability of a subcontractor's Quality Assurance Program prior to awarding

of contract or purchase order.(2) When, after award of contract, sufficient time has elapsed for the implementation of the Quality Assurance Program, and it is appropriate to determine that the organization isperforming the functions as defined in the Quality Assurance Program description, codes, standards, and other contract documents.(3) When significant changes are made in functional areas of the Quality Assurance Program, including significant

reorganizations and procedure revisions.(4) When it is suspected that safety, performance, or reliability of the item is in jeopardy due to deficiencies and nonconformances in the Quality Assurance Program.(5) When a systematic, independent assessment of program effectiveness or item quality or both is considered necessary.(6) When it is considered necessary to verify implementation

of required corrective actions.

N45.2.12 § 3.5.3 Regularly scheduled audits should be Regularly scheduled audits shall be supplemented byadditional audits of specific subjects when necessary to

provide adequate coverage.Similar requirement, but NQA-1 is not

as specific as to when additional audits are necessary.

The list of conditions for conducting supplemental audits is contained in

NQA-1, Appendix 18A-1, § 2.4, as nonmandatory guidance.This alternative is encompassed by Reg.

Guide 1.28, Reg. Position C.3.2.

05/24/04AuditsPage 6 of 22 CRITERION 18 ANSI N45.2-77/N45.2.12-77 /ANSI N18.7-76 BASIC REQUIREMENT 18 NQA-1 1994 COMMENTSsupplemented by audits for one or more of the following conditions:3.5.3.1 When it is necessary to assess the capability of a contractor's quality assurance program prior to awarding a

contract or purchase order.

Alternative from the current VA QA Topical Report.

(6) With regard to Section 3.5 of ANSI N45.2.12-1977, titled Scheduling: Subsection 3.5.3.1 is interpreted to mean thatthe Company may procedurally review qualification of a contractor's or supplier's quality assurance program prior to awarding a contract or purchase order by means other than

audit.3.5.3.2 When, after award of a contract, sufficient time has elapsed for implementing the quality assurance program and it is appropriate to determine that the organization is adequately performing the functions as defined in the quality assurance program description, codes, standards, and other contract documents.3.5.3.3 When significant changes are made in functional areas of the quality assurance program such as significant

reorganization or procedure revisions.3.5.3.4 When it is suspected that the quality of the item is in jeopardy due to deficiencies in the quality assurance program.3.5.3.5 When a systematic, independent assessment of program effectiveness is considered necessary.3.5.3.6 When necessary to verify implementation of required

corrective action.

Reg. Guide 1.144, C.4.a.- The guideline [indicated by theverb "should"] concerning supplementing regularly scheduled audits for Sections 3.5.3.3 through 3.5.3.5 [-

have sufficient safety importance to be treated the same as the requirements (indicated by the verb "shall") of the

standard.]

Reg. Guide 1.144 , C.6 - The guideline in Section 3.5.3.6 ofANSI/ASME N45.2.12-1977 recommending an audit "when necessary to verify implementation of required corrective action" does not meet the provisions of Criterion XVIII of

Appendix B to 10 CFR Part 50. Audits as well as other

05/24/04AuditsPage 7 of 22 CRITERION 18 ANSI N45.2-77/N45.2.12-77 /ANSI N18.7-76 BASIC REQUIREMENT 18 NQA-1 1994 COMMENTSmethods of surveillance can be used to verifyimplementation of required corrective action.

N45.2.12 § 4. AUDIT IMPLEMENTATION - 4.1 General -- The mechanics involved in implementation of an audit are preparation, performance, reporting, and follow-up.Not a requirement.

N45.2.12 § 4.2 Preparation - Preparation includes thedevelopment of a written audit plan, the selection and

orientation of the auditor(s), and notification of the

organization to be audited.

3 PREPARATIONNot a requirement.

3.1 Audit

Plan N45.2 ¶ 5 An audit plan should be developed to provideinformation about the audit, such as the functional areas to be audited, the names and assignments of those who will perform the audit, the scheduling arrangements, and the method of reporting findings and recommendations.

N45.2.12 § 4.2.1 Written Plan. An individual audit plandescribing the audit to be performed shall be developed and documented by the auditing organization. This plan shall identify the audit scope, the requirements, the activities to be

audited, organizations to be notified, the applicable documents, a schedule, and written procedures or checklists.

The auditing organization shall develop and document an audit plan for each audit. This plan shall identify the auditscope, requirements, audit pers onnel, activities to be audited, organizations to be notified, applicable documents, schedule, and written procedures or checklists.Similar requirement.

3.2 Personnel

N45.2, ¶ 1 The audits shall be performed - by personnel not having direct responsibilities in the areas being audited.

N18.7, ¶ 3 Those performing the audits may be members ofthe audited organization; however, they shall not audit activities for which they have immediate responsibility.

N45.2.12 § 2. PERSONNEL - 2.1 General - The responsible auditing organization shall select and assign auditors who are independent of any direct responsibility for performance of the activities which they will audit. -

The auditing organization shall select and assign auditors who are independent of any direct responsibility for performance of the activities which they will audit.Similar requirement.

N45.2.12 § 2. PERSONNEL - 2.1 General - - In the case of internal audits, the persons having direct responsibility forperformance of the activities being audited shall not be involved in the selection of the audit team.

In the case of internal audits, personnel having direct responsibility for performing the activities being audited shall not be involved in the selection of the audit team.Similar requirement.

N18.7, ¶ 3 While performing the audits they shall not reportto a management representative who has immediate responsibility for the activity being audited.Audit personnel shall have sufficient authority and organizational freedom to make the audit process meaningful

and effective.Similar requirement.

3.3 Selection

of Audit Team 05/24/04AuditsPage 8 of 22 CRITERION 18 ANSI N45.2-77/N45.2.12-77 /ANSI N18.7-76 BASIC REQUIREMENT 18 NQA-1 1994 COMMENTSAn audit team shall be identified prior to the beginning of each audit.New requirement. This is met in current programs.N45.2.12 § 4.2.2 Team Selection. One or more auditorscomprise an audit team. A Lead Auditor shall be appointed team leader. His responsibilities include orientation of the team, coordinating the audit process, establishing the pace of the audit, assuring communications within the team and with

the organization being audited, participation in the auditperformance, and coordinating the preparation and issuance

of reports.This team shall contain one or more auditors and shall havean individual appointed to lead the team who organizes and

directs the audit, coordinates the preparation and issuance of

the audit report, and evaluates responses.Similar requirement.

N45.2.12 § 2.3.1 Orientation to provide a working knowledge and understanding of ANS I N45.2, this standard,and the auditing organization's procedures for implementing

audits and reporting results.

N45.2.12 § 4.2.3 Team Orientation. The team leader shallassure that the audit team is prepared prior to initiation of the

audit. Pertinent policies, procedures, standards, instructions, codes, regulatory requirements and prior audit reports, shall be made available for information and review by the

auditors. Each auditor shall be provided with the audit plan.

The procedures or checklists shall be prepared to assure orderly accomplishment of the audit. During the familiarization phase of the audit, particular attention shall be

directed toward an understanding of internal and external

organization and contractual interfaces and responsibilities of

the organization to be audited.The audit team leader shall ensure that the audit team is prepared prior to initiation of the audit.Similar requirement to prepare the team.

However, some of the specifics from

N45.2.12 § 4.2.3 have been changed to nonmandatory guidance in NQA-1, Appendix 18A-1 § 3.2.

4 PERFORMANCE N45.2.12 § 4.3.2 Audit Process - 4.3.2.1 Checklists orprocedures shall be used to ensure depth and continuity of

audits. The audit checklist is intended for use as a guide and

should not restrict the audit investigation when findings raise further questions that are not specifically included in

checklist.Audits shall be performed in accordance with written

procedures or checklists.Similar requirement.

N45.2.12 § 3.5 Scheduling - 3.5.1 Auditing shall be initiatedas early in the life of the activity as practicable, consistent with the schedule for accomplishing the activity, to assure timely implementation of quality assurance requirements. In any case, auditing shall be initiated early enough to assure effective quality assurance during the design, procurement Auditing shall begin as early in the life of the activity as

practical and shall be continue d at intervals consistent withthe schedule for accomplishing the activity.Similar requirement.

05/24/04AuditsPage 9 of 22 CRITERION 18 ANSI N45.2-77/N45.2.12-77 /ANSI N18.7-76 BASIC REQUIREMENT 18 NQA-1 1994 COMMENTS and contracting activities.

N45.2 , ¶ 4 Audits should include an evaluation of quality assurance practices, procedures, and instructions; the effectiveness of implementation; and conformance with policy directives. In performing this evaluation, the audits

should include evaluation of work areas, activities, processes, and items; and review of documents and records.

N45.2 Audits should be performed: (1) to provide anobjective, evaluation of compliance with established requirements, methods, and procedures; (2) to assess progress in assigned tasks; (3) to determine adequacy of Quality Assurance Program performance; and (4) to verify implementation of recommended corrective action.

N45.2.12 § 4.3.2.2 Objective evidence shall be examined forcompliance with quality assurance program requirements.

N18.7, ¶ 2 Audits shall include as a minimum verification ofcompliance and effectiveness of implementation of internal rules, procedures (for example, operating, design, procurement, maintenance, modification, refueling, surveillance, test, security and radiation control procedures and the emergency plan), regulations and license provisions; programs for training, retraining, qualification and performance of operating staff; corrective actions taken following abnormal occurrences; and observation of performance of operating, refueling, maintenance and modification activities, including associated record keeping.

Alternative from current VA QA Topical Report.

(8) With regard to Section 4.3.2 of ANSI N45.2.12-1977, titled Audit Process

(a)Subsection 4.3.2.2 could beinterpreted to limit auditors to the review of only objective evidence; sometimes and for some program elements, no objective evidence may be ava ilable or subjective evidencemay be more appropriate. The Company will comply with an

alternate sentence which reads: "When available, objective evidence shall be examined for compliance with QualityAssurance Program requirements. When subjective evidence

is used (e.g., personnel interviews, direct observations by theauditor), then the audit report must indicate how the evidence

was obtained."Elements that have been selected for audit shall be evaluatedagainst specified requirements.

Objective evidence shall beexamined to the depth necessary to determine if these elements are being implemented effectively.Similar requirements between N45.2.12

and NQA-1. ANSI N18.7 requirements addressed in

the QAPD.

05/24/04AuditsPage 10 of 22 CRITERION 18 ANSI N45.2-77/N45.2.12-77 /ANSI N18.7-76 BASIC REQUIREMENT 18 NQA-1 1994 COMMENTS N45.2.12 § 4.3.2.3 Selected elements of the qualityassurance program shall be audited to the depth necessary to determine whether or not they are being implemented effectively.

N45.2 ¶ 1 Audit results shall be documented by auditing personnel and shall be reviewed by management havingresponsibility in the area audited.

N18.7 ¶ 2 Written reports of such audits shall be reviewed bythe independent review body and by appropriate members ofmanagement including those having responsibility in the area

audited.Audit results shall be documented by auditing personnel andshall be reviewed by management having responsibility for the area audited.Similar requirements. N18.7 adds requirement for review by independent review body. Addressed in the QAPD, Appendix B.

N45.2.12 § 4.3.2.6 Conditions requiring immediatecorrective action shall be reported immediately to management of the audited organization.Conditions requiring prompt corrective action shall be reported immediately to management of the audited

organization.Similar requirement.

5 REPORTING N45.2.12 § 4.4 ReportingAn audit report, which shall be signed by the audit team leader, shall provide:

Alternative from the current VA QA Topical Report.

(10) With regard to Section 4.4 of ANSI N45.2.12-1977, titled Reporting: (a)This Section requires that the auditreport shall be signed by the audit team leader; this is not always the most expeditious route to take to assure that the audit report is issued as soon as practical. The Company will comply with Section 4.4 as clarified in the following opening statement: "An audit report, which shall be signed by the audit team leader, the Nuclear Specialist (Audit Coordinator)

or his supervisor in his absence, shall provide": In cases where the audit report is not signed by the Audit Team Leader due to his absence, one record copy of the report must be signed by the Audit Team Leader upon his return.

The report shall not require the Audit Team Leader's review, concurrence, or signature if the Audit Team Leader is no longer employed by the auditing organization at the time the

audit report is issued.

N45.2.12 § 4.4.1 Description of the audit scope.

N45.2.12 § 4.4.2 Identification of the auditors.

N45.2.12 § 4.4.3 Persons contacted during pre-audit, audit, and post-audit activities.The audit report shall be signed by the audit team leader and issued, and it shall include the following information, as

appropriate: (a) description of the audit scope;(b) identification of the auditors;(c) identification of persons contacted during audit activities;(d) summary of audit results, including a statement on the effectiveness of the quality assurance program elements

which were audited;(e) description of each reported adverse audit finding in sufficient detail to enable corrective action to be taken by the

audited organization.Similar requirement.

NQA-1 does not require the reporting on recommendations for correcting program deficiencies or improving the quality assurance program. This is

consistent with one of the previous

alternatives.

The other alternatives are no longer considered necessary for the program.

05/24/04AuditsPage 11 of 22 CRITERION 18 ANSI N45.2-77/N45.2.12-77 /ANSI N18.7-76 BASIC REQUIREMENT 18 NQA-1 1994 COMMENTS Alternative from the current VA QA Topical Report.(b) The Company will comply with subsection 4.4.3 clarifiedto read: "Supervisory level personnel with whom significant

discussions were held during the course of pre-audit (where

conducted), audit, and pos t-audit (where conducted) activities.

N45.2.12 § 4.4.4 A summary of audit results, including anevaluation statement regarding the effectiveness of the quality assurance program elements which were audited.

N45.2.12 § 4.4.5 Description of each quality assuranceprogram deficiency in sufficient detail to assure that corrective action can be effectively carried out by the audited

organization.

N45.2.12 § 4.4.6 Recommendations for correcting programdeficiencies or improving the quality assurance program as

appropriate.

Alternative from the current VA QA Topical Report.(c) Subsection 4.4.6 requires audit reports to includerecommendations for corrective actions; the Company may choose not to comply with this requirement. Instead, Audit Team Leaders are required to document all adverse findings on audit finding forms. The procedure for processing audit findings allows the Audit Team Leader to document actions which are considered necessary to correct the finding; the Audit Team Leader may also document actions which are

considered unacceptable for correcting the finding: the audit finding with these "Recommendations" is then transmitted to the audited organization. In addition, the Audit Team Leader

is required to review the response to the audit finding and determine if it is acceptable. Any disagreements must be escalated to higher management for resolution.

6 RESPONSE N45.2, ¶ 1 Responsible management shall take necessaryaction to correct the deficiencies revealed by the audit.

N18.7, ¶ 3 Appropriate and timely followup action, - , shall be taken.N45.2.12 § 4.3.2.4 When a nonconformance or qualityassurance program deficiency is identified as a result of an

audit, further investigation shall be conducted by the audited Management of the audited organization or activity shall investigate adverse audit findings, schedule corrective action, including measures to prevent recurrence, and notify the

appropriate organization in writing of action taken or planned.Similar requirements to ensure the

objective of correcting deficiencies is achieved. NQA-1 uses the terms

"adverse audit findings" as opposed to "a nonconformance or quality assurance program deficiency."NQA-1 doesn't specify a time period

05/24/04AuditsPage 12 of 22 CRITERION 18 ANSI N45.2-77/N45.2.12-77 /ANSI N18.7-76 BASIC REQUIREMENT 18 NQA-1 1994 COMMENTSorganization in an effort to identify the cause and effect andto determine the extent of the corrective action required.

Alternative from current VA QA Topical Report.

(8) With regard to Section 4.3.2 of ANSI N45.2.12-1977, titled Audit Process: (b)Subsection 4.3.2.4 is modified asfollows to take into account the fact that some non-conformances are virtually "obvious" with respect to the needed corrective action: "When a non-conformance or quality assurance program deficiency is identified as a result

of an audit, unless the apparent cause, extent and corrective action are readily evident, further investigation shall be conducted by the audited organiza tion in an effort to identifythe cause and effect and to determine the extent of the

corrective action required."

N45.2.12 § 4.5 Follow-up - 4.5.1 By Audited Organization.Management of the audited organization or activity shallreview and investigate any adverse audit findings to determine and schedule appropriate corrective action

including action to prevent recurrence and shall respond as requested by the audit report, giving results of the review and

investigation. The response shall clearly state the corrective action taken or planned to prevent recurrence. In the event that corrective action cannot be completed within thirty days, the audited organization's response shall include a scheduled

date for the corrective action. The audited organization shall

provide a follow-up report stating the corrective action taken and the date corrective action was completed. They shall also

take appropriate action to assure that corrective action is accomplished as scheduled.

Alternative from current VA QA Topical Report.

(11) With regard to Section 4.5.1 of ANSI N45.2.12-1977, titled By Audited Organization: The Company will comply with the following clarification of this Section:

"Management of the audited organization or activity shall review and investigate all adverse findings, as necessary, (e.g., where the cause is not already known, another organization has not already investigated and found the cause, etc.) to determine and schedule appropriate corrective action including action to prevent recurrence. They shall for the response and this will be specified in the implementing program.

Appendix 18A-1 of NQA-1 provides nonmandatory guidance related to the follow-up by the audited organization recommending that the organization

respond prior to the requested date.

Also, the guidance recommends that the

organization provide a follow-up report

on corrective action, but this is not required, and is similar to a previous alternative used by Dominion.

The alternatives to 4.3.2.4 and 4.5.1 are

no longer required. NQA-1 does not specify the performance of further

investigation, and even when the

"needed corrective action" is "virtually

'obvious'" that would still include some

level of investigation into the condition in order to determine corrective action;

therefore, the language of NQA-1 encompasses the intent of the

alternatives.

05/24/04AuditsPage 13 of 22 CRITERION 18 ANSI N45.2-77/N45.2.12-77 /ANSI N18.7-76 BASIC REQUIREMENT 18 NQA-1 1994 COMMENTSrespond, in writing, within thirty days after the date of issuance of the audit report.The response shall clearly state the corrective action taken or

planned to prevent recurrence and the results of the

investigation if conducted. In the event that corrective action is not completed by the time the response is submitted, the audited organization's response shall include a scheduled date for completion of planned corrective action. The audited organization shall take the a ppropriate action to assure thatcorrective action is accomplished as scheduled.

N45.2.12 § 4.5.2.2 Evaluate the adequacy of the response.The adequacy of audit responses shall be evaluated by or for the auditing organization.Similar requirement.

7 FOLLOWUP ACTION N45.2 , ¶ 3 Deficient areas should be re-audited untilcorrections have been accomplished.

N18.7, ¶ 3 Appropriate and timely followup action, including re-audit of deficient areas, shall be taken.

N45.2.12 § 4.5.2 By Auditing Organization. Whennecessary, follow-up actions shall be performed by the audit team leader or management of the auditing organization to:4.5.2.l Obtain the written response when required by the

audit report.

4.5.2.3 Assure that corrective action is identified and

scheduled for each adverse, finding.4.5.2.4 Confirm that corrective action is accomplished as

scheduled.Follow-up action shall be taken to verify that corrective action is accomplished as scheduled.Similar requirement. NQA-1 does not contain as much detail on how to accomplish the follow-up in the requirements section.Details of performing followup is considered nonmandatory guidance in

Appendix 18A-1 § 7.

8 RECORDS N45.2.12 § 5.2 Audit Records - Records shall be generated and retained for all audits. Records shall include the audit system plan, individual audit plans, audit reports, written replies, and the record of completion of corrective actions.

Reg. Guide 1.144, C.7 - The requirements of ANSI/ASME N45.2.12-1977 contained in the second sentence of Section

5.2, "Audit Records," read "Records shall include - [seeabove text]." Additionally, these records should include documents associated with the conduct of audits that support audit findings (for example, audit checklists or procedures).

Audit records shall include audit plans, audit reports, written replies, and the record of completion of corrective action.Similar requirement.

N18.7 ¶ 5 Further guidance on requirements for auditing ofquality assurance programs for nuclear power plants exists inNot a requirement.

05/24/04AuditsPage 14 of 22 CRITERION 18 ANSI N45.2-77/N45.2.12-77 /ANSI N18.7-76 BASIC REQUIREMENT 18 NQA-1 1994 COMMENTSANSI N45.2.12, "Requirements for Auditing QualityAssurance Programs for Nuclear Power Plants." N45.2.12 § 1.2 Applicability - The requirements of thisstandard apply to both internal and external audits performedby or for the plant owner, contractors, and other

organizations participating in activities affecting the qualityof structures, systems, and components of nuclear power plants in accordance with requirements of ANSI N45.2. This

standard is not applicable to surveillance or inspections for

the sole purpose of process control or product acceptance.

The ASME Boiler and Pressure Vessel Code (here after referred to as the Code) as well as other American National Standards, have been considered in the development of this

standard, and this standard is intended to be compatible withtheir requirements. However, a standard does not apply to activities covered by Section III, Div. I and 2, and Section XI of the Code for those activities covered by the Code.

Reg. Guide 1.144 , C.2. - The Foreword and Section 1.2,"Applicability," of ANSI/ASME N45.2.12-1977 state: "The ASME Boiler - [See above text]" While Section III, Divisions 1 and 2, and Section XI of the ASME Boiler and Pressure Vessel Code address general requirements for quality assurance program audits, these sections do not explicitly address all the activities described in ANSI/ASME

N45.2.12-1977. ANSI/ASME N45.2.12-1977, subject to the exceptions of the regulatory position, should be used in

conjunction with Section III, Di visions 1 and 2, and Section XI of the ASME Boiler and Pressure Vessel Code for auditing quality assurance programs where the ASME Code does not address the activities covered by N45.2.12-1977.Applicability is addressed in the

Introduction to NQA-1, Part I. The requirements are similar.The limitation regarding surveillance or

inspections of N45.2.12, § 1.2, Sentence

2 is addressed in the NQA-1 definition for audit. The applicability of the QAPD

includes using its provisions to supplement the ASME Code QA requirements.

N45.2.12 § 1.3 Responsibility - The organization ororganizations responsible for implementation of the applicable requirements of this standard shall be identified

and the scope of their responsibilities and authorities shall be documented. The work of establishment practices and procedures and providing the resources in terms of personnel, equipment and services necessary to meet the requirements of this standard may be delegated to other Reg. Guide 1.28, Rev. 3, C.3.2.3 - If more than onepurchaser buys from a single supplier, a purchaser may either perform or arrange for an aud it of the supplier on behalf ofitself and other purchasers to reduce the number of external

audits of the supplier. The sc ope of this audit should satisfy the needs of all of the purchasers, and the audit report should be distributed to all the purchasers for whom the audit was conducted. Nevertheless, each of the purchasers relying onResponsibility is addressed by NQA-1

in the Introduction to Part I. The requirements are similar to the first

paragraph of N45.2.12. The second

paragraph of N45.2.12 is essentially

addressed in NQA-1, Basic Requirement 1 and Supplement 1S-1

dealing with the Organization.

05/24/04AuditsPage 15 of 22 CRITERION 18 ANSI N45.2-77/N45.2.12-77 /ANSI N18.7-76 BASIC REQUIREMENT 18 NQA-1 1994 COMMENTS organizations and such delegation shall also be documented.

It is the responsibility of each organization performing anyactivity covered by this standard to comply with the requirements of this standard applicable to its work.

The organizational structure, functional responsibilities, levels of authority, and lines of internal and external communication for management direction of audits of the quality assurance program shall be documented. Where multiple organizational arrangements exists, the interface responsibilities of each organization shall be clearly defined and documented. In no way shall the performance of audits by an organization diminish the responsibility of the audited

organization or contractor for audit of his designated portion of the quality assurance program or the quality of his product

or services.

Reg. Guide 1.144, C.5 - Regulatory Position C.3 provides guidance on scheduling internal and external audits. Section 1.3, "Responsibility," of ANSI/ASME N45.2.12-1977 states:

"The work of - [see above text]." Where more than one purchaser buys from a single supplier, a purchaser may perform an audit of the supplier on behalf of more than one purchaser in order to reduce the number of external audits of

the supplier. The results of this audit should be distributed to all purchasers for whom the audit was conducted.the results of an audit performed on behalf of several purchasers remains individually responsible for the adequacy

of the audit.

N45.2.12 § 1.4 Definitions - The following definitions areprovided to assure a uniform understanding of select terms as they are used in this standard:The following definitions are taken from NQA-1, Part I, Introduction.Definitions are addressed by NQA-1 in

the Introduction to Part I.

N45.2.12 Audit - A documented activity performed inaccordance with written procedures or checklists to verify, by examination and evaluation of objective evidence, that applicable elements of the quality assurance program have been developed, documented and effectively implemented inaccordance with specified requirements. An audit should not

be confused with surveillan ce or inspection for the sole purpose of process control or product acceptance.Audit - a planned and documented activity performed to determine by investigation, examination, or evaluation of

objective evidence the adequacy of and compliance with established procedures, instru ctions, drawings, and otherapplicable documents, and the effectiveness of implementation. An audit should not be confused with

surveillance or inspection activities performed for the sole purpose of process control or product acceptance.Similar definition.

N45.2.12 Internal Audits - Audits of those portions of anorganization's quality assurance program retained under its

direct control and within its organizational structure.

Audit, internal - an audit of those portions of an organization's quality assurance program retained under its

direct control and within its organizational structureSimilar definition.

05/24/04AuditsPage 16 of 22 CRITERION 18 ANSI N45.2-77/N45.2.12-77 /ANSI N18.7-76 BASIC REQUIREMENT 18 NQA-1 1994 COMMENTS N45.2.12 External Audits - Audits of those portions of anorganization's quality assurance program not retained under its direct control and not within its organizational structure.

Audit, external - an audit of those portions of anotherorganization's quality assurance program not under the direct

control or within the organizational structure of the auditing

organizationSimilar definition.

N45.2.12 Auditor - Any individual who performs any portion of an audit, including lead auditors, technical specialists and others such as management representatives

and auditors in training.

Not defined in NQA-1, but described in Supplement 2S-3 in a way that is similar

to the definition of N45.2.12.

N45.2.12 Lead Auditor - An individual qualified to organize and direct an audit, report audit findings and evaluate

corrective actions.

Not defined in NQA-1, but described in NQA-1, Supplement 18S-1 (subsection 3.3) and Supplement 2S-3 in a way that is similar to the definition of N45.2.12.

N45.2.12 Program Deficiencies - Failure to develop,document or implement effectively any applicable element of the quality assurance program required by ANSI N45.2.

Not defined in NQA-1. NQA-1 uses the term adverse findings, but does not

define that. Will address in Appendix D

to the new QAPD.

N45.2.12 Other terms and their definitions are contained in ANSI N45.2.10.Definitions are addressed by NQA-1 in

the Introduction to Part I. This is comparable to N45.2.10.

N45.2.12 § 1.5 Referenced Documents - Documents that are required to be included as a part of this standard are

identified at the point of reference or described in Section 6

of this standard. The issue or edition of the referenced document that is required will be specified either at the point

of reference or in Section 6 of this standard unless otherwisespecified in the contract document.

Reg. Guide 1.144 , C.1. - Section 1.5, "ReferencedDocuments," of ANSI/ASME N45.2.12-1977 states that documents that are required to be included as a part of the

standard are identified at the point of reference or described in Section 6 of the standard. The specific applicability of these listed documents has been addressed in the latest revision of the following regulatory guides:ANSI StandardRegulatory GuideN45.21.28N45.2.91.88N45.2.101.74There are no referenced documents for

this section of NQA-1. The QAPD addresses Dominion's position on referenced documents and the Reg.

Guides and Standards that apply to the QA program.

N45.2.12 § 2.2 Personnel Qualification - The responsible auditing organization shall establish the audit personnel Personnel Qualification is addressed inNQA-1 Basic Requirement 2 and 05/24/04AuditsPage 17 of 22 CRITERION 18 ANSI N45.2-77/N45.2.12-77 /ANSI N18.7-76 BASIC REQUIREMENT 18 NQA-1 1994 COMMENTSqualifications and the requirements for the use of technicalspecialists to assist in the auditing of the quality assuranceprograms. Personnel selected for quality assurance auditing assignments shall have experience or training commensurate with the scope, complexity or special nature of the activities

to be audited.

Alternative from the current VA QA Topical Report.

(2) With regard to Section 2.2 of ANSI N45.2.12-1977, titled Personnel Qualifications: The qualification of Companyaudit personnel will be accomplished as described to meet the requirements of ANSI N45.2.23-1978 as endorsed in

Table 17.2.0 and Sections 17.2.2 and 17.2.18 of the Operational QA Program.Supplement 2S-3.

Alternative not needed since NQA-1

contains training and qualification requirements in one location.

N45.2.12 § 2.3 Training - Auditors shall have, or be given, appropriate training or orie ntation to develop theircompetence for performing required audits. Competence of personnel for performance of the various auditing functions shall be developed by one or more of the following methods:

Alternative from the current VA QA Topical Report.

(3) With regard to Section 2.

3 (and subsections 2.3.1 through 2.3.3) of ANSI N45.2.12-1977, titled Training: The trainingof Company audit personnel will be accomplished as described to meet the requirements of ANSI N45.2.23-1978

as endorsed in Table 17.2.0 and Sections 17.2.2 and 17.2.18 of the Operational QA Program.Training requirements are addressed in NQA-1 Basic Requirement 2 and Supplement 2S-3.

Alternative not needed since NQA-1

contains training and qualification requirements in one location.

N45.2.12 § 2.3.2 Training programs to provide general andspecialized training in audit performance. General training shall include fundamentals, objectives, characteristics, organization, performance and results of quality assurance program auditing. Specialized training shall include methods of examining, questioning, evaluating, and documenting specific audit items and methods of closing out audit

findings.Training requirements are addressed in NQA-1 Basic Requirement 2 and Supplement 2S-3.

N45.2.12 § 2.3.3 On-the-job training, guidance, andcounseling performed under the direct supervision of a Lead Auditor. Such training shall include planning, performing, reporting, and follow-up ac tion involved in conducting audits.Training requirements are addressed in NQA-1 Basic Requirement 2 and Supplement 2S-3.

N45.2.12 § 2.4 Maintenance of ProficiencyRequirements to maintain proficiency 05/24/04AuditsPage 18 of 22 CRITERION 18 ANSI N45.2-77/N45.2.12-77 /ANSI N18.7-76 BASIC REQUIREMENT 18 NQA-1 1994 COMMENTSLead Auditors shall maintain their proficiency through oneor more of the following methods:

2. 4.1 Regular, active participation in the audit process.2.4.2 Review and study of codes, standards, procedures, instructions, and other documents related to qualityassurance programs and program auditing.2.4.3 Participation in training programs as described in

Section 2.3.

Alternative from the current VA QA Topical Report.

(4) With regard to Section 2.4 of ANSI N45.2.12-1977, titled Maintenance of Proficiency: The maintenance ofproficiency of the Company audit personnel will be accomplished as described to meet the requirement of ANSI

N45.2.23-1978 as endorsed in Table 17.2.0 and Sections 17.2.2 and 17.2.18 of the Operational QA Program.

are addressed in NQA-1 BasicRequirement 2 and Supplement 2S-3.

Alternative not needed since NQA-1

contains training and qualification requirements in one location.

N45.2.12 § 3.2 ObjectivesThe objectives of the audit system are:3.2.1 To determine that a quality assurance program has beendeveloped and documented in accordance with specified requirements;3.2.2 To verify by examination and evaluation of objective evidence that the documented quality assurance program has been implemented;3.2.3 To assess the effectiveness of the quality assurance program;3.2.4 To identify nonconformances and quality assurance program deficiencies; and3.2.5 To verify correction of identified quality assurance program deficiencies.Addressed as nonmandatory guidance in

NQA-1, Appendix 18A-1, § 2.1 N45.2.12 § 3.3 Essential Elements of the Audit SystemAn effective audit system shall be established andmaintained and shall include the following essential elements:3.3.1 A management policy statement or procedure which establishes organizational independence and authority of the auditors and commits the organization to an audit system meeting the requirements of a standard.3.3.2 Manpower, funding, and facilities to implement the audit system.Addressed as nonmandatory guidance in

NQA-1, Appendix 18A-1, § 2.2.

Alternatives to 3.3.5, 6, and 7 no longer

needed since this is now guidance and not requirements.

05/24/04AuditsPage 19 of 22 CRITERION 18 ANSI N45.2-77/N45.2.12-77 /ANSI N18.7-76 BASIC REQUIREMENT 18 NQA-1 1994 COMMENTS3.3.3 Identification of those responsible for the audit system, including a delineation of their authorities, responsibilities, and organizational independence.3.3.4 Provisions for reasonable and timely access of audit personnel to facilities, documents, and personnel necessary in the planning and performance of the audits.

3.3.5 Provisions

for reporting on the effectiveness of a quality assurance program to the responsible management of

both the audited and a uditing organizations.

Alternative from the current VA QA Topical Report.

(5) With regard to Section 3.3 of ANSI N45.2.12-1977, titled Essential Elements of the Audit System: The Companywill comply with subsection 3.6.5 [should be 3.3.5] as it was originally written (subsection 3.2.5) in ANSI N45.2.12, Draft

3, Revision 4: "Provisions for reporting on the effectiveness of the Quality Assurance Program to the responsible management." For the auditing organization (The Company), effectiveness is reported as required by the Technical Specifications for Surry Power Station and

Appendix C of this topical report for North Anna Power Station. Other than audit reports, the Company may not directly report on the effectiveness of the quality assurance programs to the audited organization when such organizations are outside of the Company.3.3.6 Provisions for access by audit teams to levels of management of the auditing a nd audited organizations shallhave the responsibility and authority to assure corrective

action.Alternative from the current VA QA Topical Report.

(5) With regard to Section 3.3 of ANSI N45.2.12-1977, titled Essential Elements of the Audit System

Subsection 3.3.6requirements are considered to be fulfilled by compliance with the organization and reporting measures outlined in the Operational QA Program, the Technical Specifications for Surry Power Station and Appendix C of this topical report

for North Anna Power Station.

3.3.7 Provision

for verification of effective corrective action on a timely basis.

Alternative from the current VA QA Topical Report.

05/24/04AuditsPage 20 of 22 CRITERION 18 ANSI N45.2-77/N45.2.12-77 /ANSI N18.7-76 BASIC REQUIREMENT 18 NQA-1 1994 COMMENTS (5) With regard to Section 3.3 of ANSI N45.2.12-1977, titled Essential Elements of the Audit System

Subsection 3.3.7 requires verification of effective corrective action on a "timely basis." Timely basis is interpreted to mean within theframework or period of time for completion of corrective action that is accepted by Nuclear Oversight. Each finding requires a response and a corrective action completion date;

these dates are subject to revision (with the approval of Nuclear Oversight) and must be escalated to higher authority when there is disagreement between the audited and the auditing organization on what constitutes "timely corrective

action.."N45.2.12 § 4.2.2 Team Selection. - In selecting personnelfor auditing assignments, consideration shall be given to

special abilities, specialized technical training, prior pertinent

experience, personal characteristics, and education.

NQA-1 addresses considerations for personnel selection as nonmandatory

guidance in Appendix 18A-1 § 3.1.

N45.2.12 § 4.2.4 Audit Notification. Involved organizationsshall be notified of a scheduled audit a reasonable time

before the audit is to be performed. This notification shouldbe in writing and include such information as the scope and schedule of the audit and the name of the audit team leader.

With prior agreement of the parties involved, unannounced audits may be performed.

NQA-1 addresses the audit notification as nonmandatory guidance in Appendix

18A-1 § 3.3.

The VA QA Topical Report alternative

related to notification is no longer

needed.N45.2.12 § 4.3 Performance - 4.3.1 Pre-Audit Conference. A brief preaudit conference sha ll be conducted with cognizantorganization management. The purpose of the conference shall be to confirm the audit scope, present the audit plan, introduce auditors, meet counterparts, discuss audit sequence

and plans for the post-audit conference, and establish channels of communication.

Alternative from current VA QA Topical Report.

(7) With regard to Section 4.3.1 of ANSI N45.2.12-1977, titled Pre-Audit Conference: The Company will complywith requirements of this Section by inserting the word "Normally" at the beginning of the first sentence. This

clarification is required because in the case of certain

unannounced audits or audits of a particular operation orwork activity, a pre-audit conference might interfere with the spontaneity of the operation or activity being audited. In NQA-1 addresses the preauditconference as nonmandatory guidance

in Appendix 18A-1 § 4.1.

05/24/04AuditsPage 21 of 22 CRITERION 18 ANSI N45.2-77/N45.2.12-77 /ANSI N18.7-76 BASIC REQUIREMENT 18 NQA-1 1994 COMMENTS other cases, persons who should be present at a pre-auditconference may not always be available. Such lack ofavailability should not be an impediment to beginning an audit. Even in the above examples, which are not intended to be all inclusive, the material set forth in Section 4.3.1 will normally be covered during the course of the audit.

N45.2.12 § 4.3.2.5 Nonconformances or quality assuranceprogram deficiencies should be acknowledged by a member

of the audited organization.

Alternative from current VA QA Topical Report.

(8) With regard to Section 4.3.2 of ANSI N45.2.12-1977, titled Audit Process

(c)Subsection 4.3.2.5 contains arecommendation which is clarified with the definition of "acknowledged by a member of the audited organization" tomean that a "member of the audited organization has been informed of the findings." Agreement or disagreement with a finding may be expressed in the response from the audited

organization.Not a requirement and not addressed in

NQA-1.Alternative should no longer be necessary since this is guidance.

N45.2.12 § 4.3.2.7 Specific attention should be given tocorrective action on program deficiencies identified during

previous audits.

Reg. Guide 1.144, C.4.b. - The guideline [indicated by theverb "should"] concerning corrective action on program deficiencies identified during previous audits - [have sufficient safety importance to be treated the same as the requirements (indicated by the verb "shall") of the standard.]

In this regard, corrective action on program deficiencies

identified during previous audits is construed to mean"corrective action on program deficiencies in the area that is

being audited.Requirement not addressed in NQA-1.

Corrective action is an element

evaluated in each audit as stated in the

QAPD, Appendix C.

N45.2.12 § 4.3.3 Post-Audit Conference. At the conclusion of the audit process, a post-audit conference shall be held with management of the audite d organization to present auditfindings and clarify misunderstandings.

Alternative from current VA QA Topical Report.

(9) With regard to Section 4.3.3 of ANSI 45.2.12-1977, titled Post-Audit Conference: The Company will substitute andcomply with the following paragraph: "For all external

audits, a post-audit conference shall be held with NQA-1 addresses the postaudit conferences as nonmandatory guidance

in Appendix 18A-1 § 4.3 Alternative is no longer needed for NQA-1 since the requirements have become guidance. Internal procedures

use that guidance in directing the

postaudit conference.

05/24/04AuditsPage 22 of 22 CRITERION 18 ANSI N45.2-77/N45.2.12-77 /ANSI N18.7-76 BASIC REQUIREMENT 18 NQA-1 1994 COMMENTSmanagement of the audited organization to present auditfindings and clarify misunde rstandings; where no adversefindings exist, this conference may be waived by management of the audited organization: such waiver shall be documented in the audit report. Unless unusual operatingor maintenance conditions preclude attendance by appropriate managers/supervis ors, a post-audit conferenceshall be held with managers/supe rvisors for all internal auditsfor the same reasons as above. Again, if there are no adverse findings, management of the in ternal audited organizationmay waive the post-audit conference: such waiver shall be documented in the audit report."

N45.2.12 § Distribution of the report shall includeresponsible management of both the audited and auditing organizations. The audit report shall be issued within thirty days after the post-audit conference.

NQA-1 requires reporting audit results to management in Basic Requirement

18. The details of report distribution are addressed as nonmandatory guidance in

Appendix 18A-1 § 5.

N45.2.12 § Follow-up action can be accomplished throughwritten communication, re-audit, or other appropriate means.Not a requirement.

N45.2.12 § 5. RECORDS - 5.1 General - Records shall beretained by the auditing or ganizations responsible foractivities associated with implementation of this standard.

These records shall be collected, stored, and maintained in accordance with ANSI N45.2.9.

NQA-1 addresses general records requirements, including those for audits, in Basic Requirement 17 and Supplement 17S-1 along with other

records.N45.2.12 § 5.3 Personnel Records - Records shall includedocumentary evidence of the qualifications and training of auditors and shall be retained for the same period of time as

required for the audit report with which the auditors are

associated.

NQA-1 addresses qualification and

training records for audit personnel in Basic Requirement 2 and Supplement

2S-3.

5/25/04 Page 1 of 34 Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants ANSI N45.2.1 -1973 Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components for Nuclear Power Plants NQA-1-1994, Subpart 2.1 Comments 1. INTRODUCTION 1 GENERAL 1.1 Scope This standard covers on-site cleaning of materials and components, cleanness control, and pre-operational cleaning

and layup of important nuclear power plant fluid systems during construction. These systems include those whose satisfactory performance is required for safe and reliable

operation of the plant. The requirements may also be extended

to other parts of nuclear power plants when specified in

contract documents. The standard covers requirements

necessary to ensure an adequately clean system upon

completion of construction activities, and covers the period

from which the materials and equipment are removed from

storage or receiving for installation at the construction site until

the systems are ready for preoperational testing. The intent of

this standard is to require close attention to cleanness control

during erection of a nuclear power plant so that only water

flushing or rinsing of an installed system is required to render it

ready for service. When more than a water flush or rinse is

needed to produce the specified cleanness, additional cleaning, in accordance with this standard may be necessary. This

standard is intended to be used in conjunction with ANSI

N45.2 Quality Assurance Requirements for Nuclear Power

Plants.Subpart 2.1 provides amplified requirements for the management of cleaning and cleanness control of fluid systems

and associated components for nuclear power plants during

manufacturing, construction, repairs, and modifications. It

supplements the requirements of Part I and shall be used in

conjunction with applicable Basic and Supplementary Sections

of Part I when and to the extent specified by the organization

invoking Subpart 2.1.

N45.2.1 was applicable just during construction. NQA-1

refers to "

manufacturing, construction, repairs, and modifications."

1.2 Applicability

The requirements of this standard apply to the work of any individual or organization that participates in the construction

phase cleaning of items to be incorporated into nuclear power

plants as discussed in Subsection 1.1. The extent to which the

individual requirements of this standard will apply will depend

upon the nature and scope of work to be performed and the

importance of the item or service involved. The requirements

are intended to ensure that only proper cleaning materials, equipment, processes and procedures are utilized during the See NQA-1, Introduction, Section 2 for Applicability NQA-1 is similar but refers to Operating Units also.

VA Clarification not required

under NQA-1-1994.

5/25/04 Page 2 of 34 Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants ANSI N45.2.1 -1973 Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components for Nuclear Power Plants NQA-1-1994, Subpart 2.1 Comments construction of power plants and that the quality of items is maintained as a result of the use of proper cleaning practices

and techniques during construction.

Reg. Guide 1.37-3/73 Position C.2 states: Although subdivision 1.2 of ANSI N45.2.1-1973 states that the requirements promulgated apply during the construction phase

of a nuclear power plant, many of the requirements and

recommendations contained in the standard are also

appropriate to cleaning of fluid systems and associated

components during the operation phase of a nuclear power

plant, and they should be used when applicable. In this regard, however, it should be particularly noted that decontamination

and cleanup of radioactively contaminated systems and

components are not addressed by ANSI N45.2.1-1973. These

operations will be considered separately in future regulatory

guides.The following is a clarification made in the current VA QATR: (1)The guide and standard are applicable to those areas of the Quality Assurance Program addressing on-site cleaning of materials and

components, cleanness control, and preoperation cleaning and layup of fluid systems.

1.3 Responsibility

The organization or organizations responsible for the activities covered by this standard shall be identified and the scope of

their responsibility shall be documented. Such responsibility

should be assigned at the earliest practical point in time so as to

facilitate incorporation of cleaning requirements in design

drawings and purchase specifications. The establishment of

practices and procedures and provision of resources, in terms

of personnel, equipment, and services necessary to implement

the requirements of this standard, may be delegated to other

organizations and such delegations shall also be documented.

Each organization participating in site construction activities

shall comply with procedures and instructions issued for the See NQA-1, Subpart 2, Introduction, Section 3 for Responsibility and NQA-1, Subpart 2, Section 4 for General

Planning and Procedures.

ANSI N45.2.1 focuses on construction phase.

Otherwise, similar

requirements if considering

other parts of NQA-1 (e.g.

Basic Requirements 1, 5, etc.)

5/25/04 Page 3 of 34 Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants ANSI N45.2.1 -1973 Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components for Nuclear Power Plants NQA-1-1994, Subpart 2.1 Comments project and with those requirements of this standard applicable to his work. The organization responsible for performing the

cleaning shall identify and document detailed cleaning

procedures unless they are specified in the procurement

documents. Requirements for review and/or approval of such

procedures shall be specified in the procurement documents.

1.4 Definitions

1.1 Definitions The following definitions are provided to assure a uniform understanding of select terms as they are used in this standard.

The following definitions are provided to assure a uniform understanding of unique terms as they are used in Subpart 2.1.

No change except reference to standard Acid Cleaning -

The removal of metal oxides by either dissolution of the oxide or undercutting the oxide by dissolution of the base metal with an acid solution.

acid cleaning - the removal of metal oxides by either dissolution of the oxide or undercutting the oxide by dissolution of the base metal with an acid solution No change Alkaline Cleaning -

The removal of organic contaminants by converting them to an emulsion with an alkaline solution such as trisodium phosphate.

alkaline cleaning - the removal of organic contaminants by converting them to an emulsion with an alkaline solution such as trisodium phosphate No change Chelate Cleaning -

The removal of slightly soluble compounds such as iron oxide, by complexing the metallic ions with organic chelating compounds such as ethylene diamine tetra-acetic acid (EDTA).

chelate cleaning - the removal of slightly soluble compounds such as iron oxide, by complexing the metallic ions with organic chelating compounds such as ethylene diamine tetra-acetic acid (EDTA)

No change Chemical Conditioning -

The addition of chemicals in low concentration to flush, rinse, or layup water to prevent precipitation of dissolved solids, inhibit corrosion, etc.

chemical conditioning - the addition of chemicals in low concentration to flush, rinse, or lay up water to inhibit precipitation of dissolved solids, corrosion, and other

detrimental effects No change Cleaning -

The removal of any contaminants that might have a deleterious effect on plant safety and reliable operation.

cleaning - the removal of any contaminants that might have a deleterious effect on operation of the plant Similar Contractor -

Any individual or organization entering into a contract to furnish items or services to a purchaser. The term contractor includes the terms Vendor, Supplier, and

Subcontractor or sub-tier levels of these where appropriate.

NQA-I, INTRO , Terms and Definitions:

Supplier - any individual or organization who furnishes items or services in accordance with a procurement document. An all-inclusive term used in place of any of the following: vendor, seller, contractor, subcontractor, fabricator, consultant, and

their subtier levels.

NQA-1, Terms and Definitions, describes

"Supplier" similar to N45.2.1

"Contractor" (each

references other term)

Contamination -

Any undesirable foreign material on the surface of an item, in the atmosphere, or in process liquids or Contamination - any unwanted or undesirable foreign material on the surface of an item, in the atmosphere, or in Similar 5/25/04 Page 4 of 34 Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants ANSI N45.2.1 -1973 Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components for Nuclear Power Plants NQA-1-1994, Subpart 2.1 Comments gases.process liquids or gases Corrosion Resistant Alloy - Materials, such as stainless steel, nickel-base, or cobalt-base alloys, that inherently resist oxidation or chemical attack in water, air, and the operating

environment.

corrosion-resistant alloys - materials that inherently resist oxidation or chemical attack in water, air, and the operating environment, such as stainless steel, nickel-base alloys, or

cobalt-base alloys Similar Crevice -

Any narrow opening in a surface or any open juncture between mating surfaces in which solutions can be trapped and not readily removed during rinsing or flushing

operations; for example, the annular spaces in threaded

connections and socket assemblies, tube-to-tube sheet joints, and tube-to-tube support joints.

crevice - a narrow opening in a surface or an open juncture between mating surfaces in which solutions or contaminants can be trapped and not readily removed during rinsing or

flushing operations (for example, the annular spaces in

threaded connections and socket assemblies, tube-to-tubesheet joints, and tube-to-tube support joints)

Similar Dead Leg -

Any area that does not have flow during the cleaning operation or which cannot be drained without special provisions.

dead leg - an area that does not have flow during the cleaning operation or that cannot be drained without special provisions fluid - any gas or liquid Similar Documentation -

Any written or pictorial information describing, defining, specifying, reporting, or certifying activities, requirements, procedures or results.

NQA-1 INTRO Definition

document - any written or pictorial information d scribing, defining, specifying, reporting, or certifying activities, requirements, procedures, or results. A document i s not

considered to be a Quality Assurance Record until it satisfies

the definition of a Quality Assurance Record as defined in this

Supplement.

N45.2.1 definition for "Documentation" is similar to

definition in NQA-1 INTRO

definition for "document."

Flushing -

Flowing water through a component or system at adequate velocity to suspend and carry away anticipated contaminants.

flushing - flowing fluid through a component or system at adequate velocity to suspend and carry away anticipated contaminants No change Inhibitor -

A chemical additive which retards some specific chemical reaction.

inhibitor - a chemical additive that retards some specific chemical reaction Similar Inaccessible Area -

An area or opening in an item which is not directly accessible for cleaning or inspection.

inaccessible area - an area or opening in an item that is not directly accessible for cleaning or inspection Similar Item - Any level of unit assembly, including structure, system, subsystem, subassembly, component, part or material.

NQA-1 INTRO Definition

i tem - an all-inclusive term used in place of any of the following: appurtenance, assembly, component, equipment, material, module, part, structure, subassembly, subsystem, system, or unit.

Similar to definition in NQA-1 INTRO definition 5/25/04 Page 5 of 34 Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants ANSI N45.2.1 -1973 Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components for Nuclear Power Plants NQA-1-1994, Subpart 2.1 Comments Layup - The protection of an item after it has been cleaned, to prevent corrosion of interior surfaces while the item is out of service or awaiting subsequent operations.

lay-up - the protection of an item after it has been cleaned to prevent corrosion of interior surfaces while the item is out of service or awaiting subsequent operations Same Mechanical Cleaning -

A method in which contaminant removal is accomplished solely by mechanical means, including wiping, abrasive blasting, brushing, grinding, sanding, chipping, etc.mechanical cleaning - a method in which contaminant removal is accomplished solely by mechanical means, including wiping, abrasive blasting, high pressure water jetting, brushing, sanding, grinding, and chipping Similar Pitting -

Localized corrosion resulting in surface defects.

pitting - surface defects resulting from localized corrosion Similar Purchaser -

The agency responsible for issuance and administration of a contract, subcontract, or purchase order imposing this standard or portions hereof.

NQA-1 INTRO Definition

Purchaser - the organization responsible for establishment of procurement requirements and for issuance or administration, or both, of procurement documents Similar definition Rinsing -

(1) Filling and draining an item with water until contaminants in the effluent water are reduced to some predetermined concentration, or (2) flowing water through the

system or component at low velocity until contaminants in the

effluent water are reduced to some predetermined

concentration.

rinsing: (a) filling and draining an item with water until soluble contaminants in the effluent water are reduced to some predetermined concentration; or (b) flowing water through the

system or component until water soluble contaminants in the

effluent water are reduced to some predetermined

concentration Similar Rust - Corrosion products, consisting largely of iron oxide.

Such oxides may vary in color from red to black and may form a loosely adherent heavy covering to a tightly adherent light

film. Pitting or general surface roughening, may or may not be

present.rust - corrosion products consisting largely of iron oxide. Such oxides may vary in color from red to black and may form anything from a loosely adherent heavy covering to a tightly

adherent light film. Pitting or general surface roughening may

or may not be present.

Same Sensitized Corrosion Resistant Alloy -

Any alloy which has been subjected to heating that causes intergranular precipitation of chromium carbides in quantities sufficient to be

detected by methods of ASTM A262-68, Recommended

Practices for Detecting Susceptibility to Intergranular Attack in

Stainless Steel or ASTM A393-63, Recommended Practices

for Conducting Acidified Copper Sulfate Test for Intergranular

Attack in Austentic Stainless Steel.

sensitized corrosion-resistant alloy - a corrosion-resistant alloy that has been subjected to heating that causes intergranular precipitation of chromium carbides in sufficient

quantities to be detected by Practice B, C, D, E, or F of ASTM A 262, Practices for Detecting Susceptibility to Intergranular Attack in Austenitic Stainless Steels Similar 5/25/04 Page 6 of 34 Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants ANSI N45.2.1 -1973 Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components for Nuclear Power Plants NQA-1-1994, Subpart 2.1 Comments Solvent Cleaning -

Dissolving organic contaminants with an organic solvent.

solvent cleaning - removing contaminants with an organic solvent Similar 1.5 Referenced Documents Other documents that are required to be included as part of this standard are either identified at the point of reference or

described in Section 10 of this standard. The issue or edition of

the referenced document that is required will be specified

either at the point of reference or in Section 10 of this

standard. Other terms and definitions are contained in ANSI

N45.2.10 Reg. Guide 1.37-3/73 Position C.1 states: Subdivision 1.5 of ANSI N45.2.1-1973 states that other documents required to be included as a part of the standard are either identified at the

point of reference or described in Section 10 of the standard.

The specific applicability or acceptability of these listed

documents has been or will be covered separately in other

regulatory guides or in Commission regulations, where

appropriate..

See Part II, INTRODUCTION, Section 7 which refers to the NQA-1 Table entitled "Codes, Standards, and Specifications

Referenced in Text" for information regarding referenced

documents in NQA-1 Referenced documents are addressed in the QAPD, Appendix C.

2.0 GENERAL

REQUIREMENTS 2 GENERAL REQUIREMENTS This section contains requirements that are to be fulfilled by the contractor who is responsible for performing any segment

of work described in paragraphs 3 through 9 of this standard.

Cleanness classification for an item shall be specified in

accordance with paragraph 3.1 of this standard.

Not requirement.

The work and quality assurance requirements for the cleaning of items and systems to be incorporated in the nuclear power

plant and control of cleanness thereof shall be established in

order to The work and quality assurance requirements for the cleaning of components and systems and for the control of their

cleanness shall be established in order to:

Similar (1) ensure the removal of any deleterious contaminants, (a) ensure the removal of deleterious contaminants; Same (2) minimize recontamination of cleaned surfaces, and (b) minimize recontamination of cleaned surfaces; and Same (3) minimize the cleaning required after installation.(c) minimize the cleaning required after installation, repair, or modification.

Similar- NQA-1 includes "repair or modification" 5/25/04 Page 7 of 34 Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants ANSI N45.2.1 -1973 Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components for Nuclear Power Plants NQA-1-1994, Subpart 2.1 Comments N45.2.1 was for construction.

The cleanness classification of each item shall be specified in accordance with para. 3.2 of Subpart 2.1

2.1 Planning

2.1 Planning The cleanness and cleanness control activities shall be planned and outlined to define cleaning and inspection operations to be

used. It shall detail the systematic, sequential progression of

cleaning operations for each item or system, the responsibilities

of parties concerned for each operation, and measures to be

employed to preserve the cleanness of cleaned surfaces.

Cleaning and cleanness control activities for each phase (manufacturing, construction, modification, repair, etc.) shall be

planned in accordance with the requirements of the

Introduction to this Part (Part lI). The plan(s) shall define the cleaning and inspection operations to be used, the system, the responsibilities of the parties concerned for each operation, and

the measures to be employed to preserve the cleanness of

cleaned surfaces.

Similar - with NQA-1 expanded to additional

activities (modification, repair, etc.)Planning for cleaning activities shall include a review of the system and component design specifications and drawings and

of the construction work plans and schedules to ensure that

provisions for cleaning have been incorporated; that they can

be accomplished as specified; and that time and resources are

sufficient to accomplish the required actions.

Covered in Subpart 2 INTRO 4.1, Planning This review shall consider the following items as appropriate:

In addition, planning shall consider the following factors, as appropriate, recognizing that this list may not be complete nor

applicable to each phase covered by this Part (Part II):

Similar 1. Adequacy of vents and drains, inspection access points, bypass or recirculation lines;(a) adequacy of vents, drains, inspection access points, and bypass or recirculation lines; Similar 2. Facilities for filters, and flushing and/or drain connections, in locations where dead legs are unavoidable;(b) facilities for filters and flushing and drain connections in locations where dead legs are unavoidable; Similar 3. Piping system design and installation in a manner which minimizes the necessity for installation of temporary piping

during the cleaning operations; (Where possible, divide the

system into a number of separate cleaning circuits to facilitate

cleaning);(c) design and installation of piping in a manner that minimizes the necessity for installing temporary piping during the cleaning

operations, such as dividing the system into a number of

separate cleaning circuits to facilitate cleanability; Similar 4. Sequencing of the installation operations to provide for visual inspection (crawl through) of the inside surfaces of large

diameter piping;(d) sequencing of installation operations to provide for visual inspection of inside surfaces of large diameter piping; Similar 5. Control of the installation operations so that piping and (e) control of installation operations so that piping and Same 5/25/04 Page 8 of 34 Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants ANSI N45.2.1 -1973 Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components for Nuclear Power Plants NQA-1-1994, Subpart 2.1 Comments components which have already been installed are not subject to contamination when subsequent installation operations are

performed; components that have already been installed are not subject to contamination when subsequent installation operations are

performed;

6. Adequate pumping and heating capacities when these are important factors in the cleaning operations.(f) adequacy of pumping and heating capacities when these are important factors in the cleaning operations; Same (g) disposal of cleaning solutions and waste water; Added to NQA-1 (Environmentally correct)(h) safety, fire protection, and other hazards.

Added to NQA-1 (Env./Safety concerns)

2.2 Procedures

and Instructions

2.2 Procedures

and Instructions

2.2.1 Cleaning

procedures as well as procedures or work instructions for cleanness control practices and inspections, examinations or tests to verify cleanness of items shall be

prepared.Written procedures and instructions for cleaning, cleanness control, inspections, and tests to verify cleanness of items shall

be prepared in accordance with the requirements of the

Introduction to this Part (Part Il).Similar These documents shall include as appropriate:

List covered in introduction of NQA-1 regarding procedures.

1. Detailed cleaning-cleanness control procedures

2. Personnel safety considerations

3. Structure or facility protection consideration

4. Inspection and test equipment requirements

5. Sequence of work activities, inspections and tests

6. Sequential steps for a given activity

7. Acceptance criteria including methods for verifying cleanness 8. Preparatory checks

9. Approvals

10. Responsibilities

11. Data report forms 2.2.2 The preparation of the actual working procedures or instructions to be used should consider:

Preparation of the actual cleaning procedures or instructions shall consider the following:

Similar 1. Work practices, housekeeping, access control, and (a) work practices, housekeeping, access control, and Same 5/25/04 Page 9 of 34 Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants ANSI N45.2.1 -1973 Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components for Nuclear Power Plants NQA-1-1994, Subpart 2.1 Comments prevention of contamination and recontamination; prevention of contamination and recontamination;

2. Effectiveness of cleaning procedures for removal of the contaminants;(b) effectiveness of cleaning methods for removal of the contaminants; Same (c) effects of residual quantities of cutting fluids, liquid penetrants, weld fluxes, precleaning solutions, engineering test

fluids, and other process compounds that may have been

intentionally or advertently applied to the surface of the item during prior steps of manufacture, installation, or use; Added to NQA-1

3. Corrosiveness of cleaning solutions in contact with the material of an item, particularly in the case of dissimilar metals;(d) corrosiveness of cleaning solutions in contact with the material of an item, particularly in the case of dissimilar metals

and entrapment of cleaning solutions; Similar 4. Chemical composition, concentration, and temperature limits of cleaning solutions to avoid deleterious effects;(e) chemical composition, concentration, and temperature limits of cleaning solutions to avoid deleterious effects; Similar 5. Proposed solution and metal temperatures, solution concentrations, velocity, and contact times during cleaning;(f) solution and metal temperatures, solution concentrations, velocity, and contact times during cleaning; Similar 6. Methods for monitoring cleaning solution concentration and temperatures during cleaning operations;(g) methods for monitoring cleaning solution concentration, temperatures, and velocities during cleaning operations; Similar 7. Identification of the systems and subsystems with which the procedures are to be used;(h) identification of the items for which the procedures are to be used;Similar 8. Proposed sequence of operations and methods of filling, system circulation, draining, and flushing;(i) sequence of operations and methods of filling system circulation, draining, and flushing; Same 9. Proposed equipment isolation, location of temporary piping and valves, location of strainers and where possible, the

location of temporary equipment;(j) (1) equipment isolation (2) location of: (a) temporary piping and valves (b) strainers (c) temporary equipment (d) connections for filling, flushing, rinsing, and draining equipment; Similar 10. Construction operations prohibited during cleaning operations;(k)activities to be prohibited or constrained before, during, and after cleaning operations Similar 11. Methods for rinsing and neutralizing including number of rinses;(I) methods for rinsing and neutralizing, including estimated number of rinses; Same 12. Methods for verifying cleanness;(m) methods for verifying cleanness; Same 5/25/04 Page 10 of 34 Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants ANSI N45.2.1 -1973 Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components for Nuclear Power Plants NQA-1-1994, Subpart 2.1 Comments 13. Methods of drying and lay-up of the system;(n) methods for drying and lay-up; Similar 14. Methods for protecting installed equipment which are not used in the cleaning operations;(o) methods for protecting installed items which are not involved in the cleaning operation; Similar 15. Methods for disposal of cleaning solutions.(p) method of disposal of cleaning solution.

Similar 2.3 Results Inspection and test results shall be documented in a suitable test report or data sheet. Each report shall identify the item to

which it applies, the procedures or instruction followed in

performing the task and the identification of the following:

NQA-1 does not repeat information across sections-

this is covered under

inspection and test sections

1. Conditions encountered which were not anticipated, including nonconformance.

2. Identity of inspector or tester.

3. Completion date.

Test reports and data sheets shall include an evaluation of the acceptability of inspection and test results and provide for

identifying the individual who performed the evaluation.

2.3 Rectification

of Unacceptable Cleanness If indications of contamination in excess of specified limits are observed at the end of a cleaning operation or at any

subsequent inspections for cleanness, the item shall be

recleaned using an approved procedure. If such indications are

observed at the anticipated end of a cleaning operation, continued cleaning shall be performed to reduce the level to the

specified limit.

Added to NQA-1 If necessary, an evaluation shall be made to determine the cause of the unacceptable cleanness and the actions required

to preclude recurrence.

Added to NQA-1

7.4 Control

of Cleaning Solutions

2.4 Control

of Cleaning Solutions Cleaning solutions should be prepared in accordance with the applicable cleaning procedure and shall be checked for proper

chemical composition and effectiveness of inhibitors (if used).

Solution temperatures must be maintained and controlled to

assure adequate cleaning and to prevent decomposition and Cleaning solutions shall be prepared in accordance with the applicable cleaning procedure and shall be checked for proper

chemical composition and effectiveness of inhibitors, if used.

Solution temperatures shall be maintained and controlled to

ensure adequate cleaning and to prevent cleaning agent Similar, but changed from recommendations to

requirements in NQA-1.

5/25/04 Page 11 of 34 Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants ANSI N45.2.1 -1973 Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components for Nuclear Power Plants NQA-1-1994, Subpart 2.1 Comments possible damage to the system.

decomposition and possible damage to the item.

2.4 Personnel

Qualifications Those personnel who perform inspection, examination or testing activities required by this standard shall be qualified in

accordance with ANSI N45.2.6 Qualifications of Inspection, Examination, and Testing Personnel for the Construction Phase

of Nuclear Power Plants.

Covered in PART 2 INTRO, Basic/Supplementary

Requirements 2 of NQA-1, and Section 2 of the QAPD 2.5 Test Equipment 2.5.1 Selection.

Inspection and test equipment used to implement the requirements of this standard shall be selected to have

sufficient accuracy and sensitivity tolerance to determine

conformance to specified requirements.

Covered in NQA-1 PART II Introduction, Basic

Requirements 2 and 12, and

Supplement 12S-1, as well as

other sections relating to

inspection and test.

2.5.2 Calibration

and Control.

Test equipment shall be adjusted and calibrated at prescribed intervals against certified equipment having known valid

relationships to nationally known standards.

If no national standards exist, the basis of calibration shall be documented. Records shall be maintained and equipment

suitably marked to indicate calibration status.

When inspection and testing equipment is found to be out of calibration, an evaluation shall be made of the validity of

previous inspection or test results and acceptability of items

previously inspected or tested.

Covered in Subpart 2.16 of NQA-1. NQA-1 doesn't generally repeat information that is common between

requirements and Subparts.

2.6 Housekeeping

In areas, facilities and environments where the cleanness controls of this standard are required, the housekeeping

requirements shall be in accordance with ANSI N45.2.3, Housekeeping During Construction Phase of Nuclear Power

Plants.Note - See NQA-1 Subpart 2.3 for comparison with ANSI

N45.2.3.3.0 CRITERIA FOR CLEANING 3 CLEANNESS CRITERIA 5/25/04 Page 12 of 34 Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants ANSI N45.2.1 -1973 Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components for Nuclear Power Plants NQA-1-1994, Subpart 2.1 Comments It is intended that systems that have been cleaned in accordance with this standard should require only water

flushing or rinsing as a final cleaning step in preparing them for

service. However, where more than normal water flushing or

rinsing is required to produce the specified cleanness, additional

cleaning in accordance with this standard may be necessary.

Note - See NQA-1 Subpart 2.3 for additional information

regarding Dominion

commitments and

clarifications.

While this standard is primarily concerned with the cleaning and cleanness of internal surfaces, external surface cleanness

may be of equal importance in some cases and should be

recognized during the cleaning operations. Internal and external

surfaces may have different cleaning and cleanness

requirements.

Not a requirement.

3.1 Cleanness

Classifications

3.1 Cleanness

Classification The degree of cleanness required is a function of the particular item under consideration.

The level of cleanness required for any particular application is a function of the particular item under consideration.

Similar The assignment of a cleanness classification shall consider the susceptibility to corrosion of the material, the consequences of

malfunction or failure of the item and the probability of

contaminants contributing to or causing such malfunction or

failure.The assignment of a cleanness classification shall consider the following: (a) the function of the item to be cleaned;(b) the

susceptibility of its materials of construction to various forms of

corrosion, including intergranular cracking, or stress corrosion

cracking under fabrication, installation, or operating conditions; (c) the consequences of malfunction or failure of the item; (d)

the possibility of contaminants (introduced during fabrication, storage, installation, repairs, or service) contributing to or

causing such malfunction or failure.

Similar NQA-1 expanded -

covers storage, operation, repairs, etc) and with

additional specificity.

This standard does not establish the cleanness classification of any specific item. However, typical examples are presented as

a guide. The specification for the required cleanness class shall

be the responsibility of the purchaser.

Four classes of surface cleanness (Classes A, B, C, and D) with criteria for each are provided in Subpart 2.1.

Four classes defined - see Appendix C of the Dominion

QAPD for additional

clarifications/alternatives.

The class of cleanness required for any given application shall be specified in design drawings or specifications associated

with the cleaning of items, and the method of verification of

cleanness shall be documented.

The cleanness class or classes applicable to the item or specific parts of the item shall be established and specified in

the applicable drawings, specifications, or other appropriate

documents.

Similar NOTE The following cleanness classifications are not directly Different cleanness classes may be assigned to internal and Similar 5/25/04 Page 13 of 34 Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants ANSI N45.2.1 -1973 Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components for Nuclear Power Plants NQA-1-1994, Subpart 2.1 Comments related to component classifications assigned by the ASME Boiler and Pressure Vessel Code for design and inspection or

for other purposes external surfaces, or to different parts of the same item based on the cleanness needs of the specific item. Guidelines for

assigning cleanness classifications are listed in Part III, Subpart

3.2, Appendix 2.1

3.2 Cleanness

Class Criteria

3.1.1 Class

A -

3.2.1 Class

A.

A very high level of cleanness in which there is no evidence of contamination of a surface either under visual examination, with or without magnification, or with the aid of sensitive

detection methods. Class A cleanness applies to special items

such as fuel elements, control rod drive mechanisms, delicate

instruments, and other close tolerances or carefully controlled

surfaces or assemblies. Such items should receive their

required level of cleanness at the point of manufacture and

cleanness must be maintained at the construction site. For

these reasons, requirements of this level of cleanness are considered to be outside of the scope of this document.

-: A very high level of cleanness as evidenced by the freedom from all types of surface contamination, according to the

acceptance criteria of the inspection methods specified in the

procedures required by para. 2.2.1. If close control of particulate contamination is required, a clean room, in accordance with para. 8.5.5 of ASTM A 380-78, Practice for Cleaning and Descaling Stainless Steel Parts, Equipment, and Systems, shall be employed during the manufacturing, assembly, and installation operations when particulate

contamination could occur. Gross and precision inspection

methods applicable to Class A are described in paras. 7.2 and 7.3 of ASTM A 380-78; other special tests shall be specified as necessary.

Similar Where the cleanness of internal surfaces is evaluated by flushing, criteria shall be specified in the cleaning procedure.

NQA-1 added requirement.

3.1.2 Class

B

3.2.2 Class

B.

A high level of cleanness applicable to reactor coolant systems, components, and other items, such as the reactor coolant

purification system, which have similar cleanness

requirements. Piping and components in systems which are

designed as requiring Class B cleanness shall meet the

following requirements A high level of cleanness as evidenced by the following characteristics.

Similar (a) Corrosion-Resistant Alloys (1) The surface shall appear metal clean and free of organic films and contaminants when examined in accordance with para. 7.2.1 of ASTM A 380-78, Practice for Cleaning and

Descaling Stainless Steel Parts, Equipment, and Systems, except light deposits of atmospheric dust are permissible and NQA-1 provides similar guidance as N45.2.1, but

breaks it down to Corrosion

Resistant Alloys and Carbon and Low Alloy Steels.

5/25/04 Page 14 of 34 Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants ANSI N45.2.1 -1973 Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components for Nuclear Power Plants NQA-1-1994, Subpart 2.1 Comments shall show no evidence of deleterious contamination when subjected to the wipe test of para. 7.2.2 of ASTM A 380-78.

When visual inspection is impossible but surfaces are accessible for wipe tests, sufficient wipe tests in different

areas of the item shall be made to evaluate the general

cleanness level of the surface. Scattered areas of rust are

permissible, provided the aggregate area does not exceed 2 sq in. in any 1 sq ft area (14 cm2 per 1000 cm2). Temper films and discolorations resulting from welding are acceptable.

(2) If flushing is the only practical means for evaluating the cleanness of internal surfaces, a 20mesh (850 µm, ASTM E

11, Specification for Wire Filter Cloth Sieves for Testing

Purposes) or finer filter (or the equivalent) shall be installed

and the item flushed with water or other fluid meeting the

requirements of para. 3.4. The item shall be flushed at the design velocity (or other flow velocity if specified in the procedure) until the screen shows no more than slight

speckling (as specified in the procedure in qualitative or

quantitative terms, such as the number of particles per unit

surface area of the screen) and no more than slight rust

staining. There shall be no particles larger than 1/32 in. x 1/16

in. long (0.8 mm x 1.6 mm). In water flushed systems there

shall be no visual evidence of contamination (e.g., oil, discoloration) of the effluent flush water or screen.

NOTE Localized rusting may indicate pitting of the surface and should be evaluated metallurgically. Thin temper films resulting from welding or post-weld heat treatment are acceptable.

1. The surface shall appear "metal clean" when examined without magnification under a lighting level (background plus

supplementary lighting) of at least 100 foot candles. Scattered

areas of rust are permissible provided the aggregate area of

rust does not exceed 2 square inches in any one square foot

area.

5/25/04 Page 15 of 34 Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants ANSI N45.2.1 -1973 Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components for Nuclear Power Plants NQA-1-1994, Subpart 2.1 Comments 2. The surface shall be free of particulate contaminants such as sand, metal chips, weld slag, etc

3. The surface shall be free of organic films and contaminants such as oils, paint, and preservatives as determined by a visual

examination or an organic solvent-dampened white cloth or an

equivalent alternate method.

4. When a visual inspection is not possible and the surfaces are accessible, a dry white-cloth wipe, followed by a solvent-

dampened white cloth wipe, may be used to evaluate the

cleanness of the surface. If either cloth exhibits indications of

contamination, the system shall either be recleaned or the specific contaminant shall be determined and evaluated as to its potential deleterious effect.

5. If flushing is the only practical means for determining system cleanliness, the system shall be evaluated by examining

a 20-mesh (ASTM E11-70, Specifications for Wire Cloth

Sieves for Testing Purposes) or finer filter, or the equivalent, installed on the outlet of the cleaning circuit. The system shall

be flushed at its normal design velocity (or other velocity if

specified by procurement documents) until the screen shows

no more than slight particle speckling and no more than slight

rust staining. There shall be no particles larger than 1/32 inch in

any dimension, except fine hairline slivers of less than 1/32 inch

thickness are permissible up to l/16 inch long. There shall be no

evidence of organic contamination in the effluent water or on

the filter (b) Carbon and Low Alloy Steels (1) The surface shall appear metal clean when examined in accordance with para. 7.2.1 of ASTM A 380-78, except light deposits of atmospheric dust are permissible, and shall show no deleterious contamination when subjected to the wipe test of

para. 7.2.2 of ASTM A 380-78. Wipe tests shall be made prior

to the application of any preservative film (some type of

protective film may be required in order to maintain a clean 5/25/04 Page 16 of 34 Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants ANSI N45.2.1 -1973 Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components for Nuclear Power Plants NQA-1-1994, Subpart 2.1 Comments carbon or low alloy steel surface at Class B level). When visual inspection is impossible, but surfaces are accessible for a

wipe test, sufficient wipes of different areas of the item shall

be made to evaluate the general cleanness of the surface.

Scattered areas of rust are permissible, provided the aggregate

area does not exceed 2 sq in. in any 1 sq ft area (14 cm 2 per 1000 cm 2).(2) If flushing is the only practical means for evaluating the cleanness of internal surfaces, a 20mesh (850 µm, ASTM E

11, Specification for Wire Cloth Sieves for Testing Purposes)

or finer filter (or the equivalent) shall be installed and the item

flushed with water or other fluid meeting the requirements of

para. 3.4. The item shall be flushed at the design velocity (or

other flow velocity if specified in the procedure) until the

screen shows no more than slight speckling (as specified in the

procedure in qualitative or quantitative terms, such as the

number of particles per unit area of the screen) and no more

than slight rust staining. There shall be no particles larger than

1/32 in. x 1/16 in. long (0.8 mm X 1.6 mm). In water flushed

systems there shall be no visual evidence of contamination (e.g., oil, discoloration) of the effluent flush water or screen NOTE: Class B cleanness should be specified for carbon steel and low alloy steel surfaces only in special cases because of

the difficulty in maintaining such surfaces in that condition after

they have been cleaned.

3.1.3 Class

C -

3.2.3 Class

C.

An intermediate level of cleanness generally applicable to closed service water systems that cool components containing

reactor coolant, engineered safety systems, and other high

integrity systems. Surfaces shall meet the requirements for

Class B cleanness, except:

An intermediate level of cleanness in which the surfaces meet the requirements for Class B except:

Similar - Differences in NQA-1 recognize addditonal alloys, etc., not recognized in the older N45.2.2 standard.

1. Thin uniform rust films are acceptable on carbon steel surfaces.(a) Corrosion-Resistant Alloys. Scattered areas of rust are permissible, provided the aggregate area does not exceed 15 sq in. per 1 sq ft area (100 cm 2 per 1000 cm 2).Similar 5/25/04 Page 17 of 34 Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants ANSI N45.2.1 -1973 Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components for Nuclear Power Plants NQA-1-1994, Subpart 2.1 Comments 2. Scattered areas of rust are permissible provided that the area of rust does not exceed 15 square inches in any 1 square

foot on corrosion resistant alloys.(b) Carbon and low Alloy Steels. A uniform light rust bloom which can be removed by brushing or wiping is acceptable.

Similar 3. Flush-test filters may exhibit considerable rust staining.(c) Corrosion-Resistant Alloys and Carbon and Low Alloy Steels. Screens installed for evaluation of internal surfaces by

flushing may exhibit considerable particle speckling (as

specified in the procedures in qualitative or quantitative terms, such as the number of particles per unit area of the screen)

and considerable rust staining.

Similar 3.1.4 Class D -

3.2.4 Class

D.

The level of cleanness applicable to fire protection, open service water, and similar systems requiring only a nominal

degree of cleanness. The following are acceptable on items

which meet Class D cleanness:

A nominal level of cleanness in which the following are acceptable:

Similar 1. Tightly adherent mill scale on carbon steel surfaces.(b) tightly adherent mill scale on nonmachined carbon and low alloy steel surfaces that resist removal by hand scrubbing with a stiff wire brush; Similar 2. Paint or preservative coatings on carbon steel surfaces that will not peel or flake when exposed to cold-water flushing.(c) paint or preservative coatings on carbon or low alloy steel surfaces that will not peel or flake when subjected to cold

water flushing Similar 3. Rust films on carbon steel and stainless steel surfaces that resist removal by scrubbing with a bristle brush.(a) rust films on both corrosion-resistant alloys and carbon and low alloy steel surfaces; Similar 4. If flushing is the only practical means of determining system cleanness, the system shall be evaluated by examining a 14-

mesh (ASTM E11-70, Specification for Wire Cloth Sieves for

Testing Purposes) or fine filter, or the equivalent, installed on

the outlet of the cleaning circuit. The system shall be flushed at

its normal velocity until the screen shows no more than

occasional particle speckling. There shall be no particles larger

than 1/16 inch in any dimension, except hairlike slivers of less than 1/16 inch thickness are permissible up to 1/8 inch long.

There shall be no evidence of organic contamination on the

screen; considerable rust-staining is acceptable.(d) particles no larger than 1/16 in. x 1/8 in. long (1.6 mm x 3.2 mm) on a 14-mesh (1.4 µm, ASTM E 11), or finer filter (or the

equivalent).

Similar, but not as specific.

3.2.5 Summary.

5/25/04 Page 18 of 34 Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants ANSI N45.2.1 -1973 Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components for Nuclear Power Plants NQA-1-1994, Subpart 2.1 Comments The cleanness classes are summarized in Table 3.2 of Subpart 2.1. See Table at end of document 3.3 Hydraulic, Instrument Control, and Lubrication Lines and Systems The preceding cleanness classifications and criteria in para. 3.2 are primarily applicable to relatively large items which are generally amenable to visual inspection of internal surfaces at

some time during manufacture and installation operations.

Interior surfaces of hydraulic, instrument control, and

lubrication systems are generally not accessible for visual

inspection during manufacture and installation, and may have

much more stringent requirements on particulate contamination

than those specified in the preceding cleanness classes. Where

special characteristics and specific requirements are needed

for such systems, they shall be specified. Guidelines for

classifying hydraulic, instrument, and lubrication cleanness are

presented in Part III, Subpart 3.2, Appendix 2.1.

3.4 Cleaning

and Flushing Fluid Quality Requirements

3.2 Water

Quality Requirements 3.4.1 Water.

The selection of the water quality for a specific application shall be made by the organization responsible for the cleaning

operations unless otherwise specified in the purchase

document. In cases where the water quality for operating

systems is lower than that specified below (e.g., open service

water systems), the water used for cleaning can be equivalent

to the quality of the operating system water. When cleaning

water quality is not otherwise specified, it shall comply with the

following specifications:

Reg. Guide 1.37-3/73 Position C.3 states: Subdivision 3.2 of ANSI N45.2.1-1973 states that the selection of the water quality for a specific application shall be made by the

organization responsible for the cleaning operations unless

otherwise specified in the purchase document. The water

quality for final flushes of fluid systems and associated The water quality for mixing cleaning solutions, rinsing, and flushing shall be specified by the organization responsible for

cleaning unless otherwise stipulated in procurement documents

or approved procedures. Table 3.4.1 lists water quality

requirements commonly used for such purposes in nuclear

cleaning operations.

Similar.The guidance in the Reg.

Guide and the level of detail in

the alternative should be

addressed in the

administrative controls for

cleaning.

5/25/04 Page 19 of 34 Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants ANSI N45.2.1 -1973 Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components for Nuclear Power Plants NQA-1-1994, Subpart 2.1 Comments components should be at least equivalent to the quality of the operating system water.

The following is a clarification made in the current VA QATR: (2)With regard to Paragraph C.3 of Regulatory Guide 1.37: The water quality for final flushing of fluid systems and associated components

shall be at least equivalent to the quality of the operating system

water except for the oxygen and nitrogen content; but this does not

infer that chromates or other additives, normally in the system water, will be added to the flush water.

Fresh Water Fresh water shall meet the following requirements:

pH at 25 C (77 F) 5.5 to 8

Chloride Less than 100 ppm Fluoride Less than 5 ppm Sulfide Less than 1 ppm Total Dissolved Solids Less than 500 ppm Turbidity Less than 5 Jackson Turbidity Units Demineralized Water

Demineralized water shall meet the following requirements:

pH at 25 C (77 F) 5.5 to 8

Chloride Less than 1 ppm Fluoride Less than 1 ppm Sulfide Less than 1 ppm Conductivity at 25 C (77 F) Less than 3 micro mho/cm Silica Less than 0.05 ppm Turbidity Less than 1-Jackson Turbidity Unit When fresh water is used on components or systems containing austenitic stainless steel, attention shall be given to

methods for minimizing the possible effects of chlorides.

Table copied from NQA-1-1994, Subpart 2.1.

Similar Table from NQA-1 contains

this information.

3.4.2 Gaseous

Fluids.

The requirements for gaseous fluids used for flushing are NQA-1 additional 5/25/04 Page 20 of 34 Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants ANSI N45.2.1 -1973 Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components for Nuclear Power Plants NQA-1-1994, Subpart 2.1 Comments dependent upon the particular item being flushed. The requirements for any given item shall incorporate restrictions

on particulate Contaminants, organic contaminants, water

soluble contaminants, and water content as appropriate for the

item.requirements/clarifications.

3.4.3 Organic

Fluids.

Requirements for organic fluids used for flushing are dependent upon the particular item being flushed. The

requirements for any given item shall incorporate restrictions

on particulate contaminants, water soluble contaminants, and

water content as appropriate for the item.

NQA-1 additional requirements/clarifications.

3.4.4 Fluids

for Hydraulic, Instrument Control, and Lubrication Systems.

In addition to the requirements of para. 3.4.1, 3.4.2, or 3.4.3, as applicable for the system being flushed, fluids used for final flushing or rinsing of components and installed systems

covered by this paragraph shall meet the particulate

contamination limits specified in Table 3.4.4 for the system

class specified.

NQA-1 additional requirements/clarifications.

3.4.5 If acid cleaning is used, particular attention shall be given NQA-1 additional 5/25/04 Page 21 of 34 Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants ANSI N45.2.1 -1973 Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components for Nuclear Power Plants NQA-1-1994, Subpart 2.1 Comments to: (a) avoidance of entrapment of acids in crevices; (b) effects on either welded or sensitized corrosion-resistant

alloys and nonferrous materials; (c) complete removal of any residual acid solution from the

item; (d) neutralization treatment followed by thorough rinsing or

flushing.requirements/clarifications.

3.4.6 The use of contaminated tools shall be avoided. Tools which contain, or which may become contaminated with, materials that could contribute to stress-corrosion or

intergranular cracking shall not be used on corrosion-resistant

alloys.NQA-1 additional requirements/clarifications.

4 MANUFACTURING PHASE CLEANNESS The cleanness of an item at the point of manufacture is critical to the final cleanness level ultimately attained after installation.

Where practicable, the cleanness classification of an item listed

in the purchase specification shall be the same as that for final

service. The capability of construction site cleaning operations

may not be sufficient to upgrade the cleanness level of a

complex item since a much wider variety of cleaning facilities

and procedures are generally available for use at the

manufacturer's shops than are available at the construction

sites.New section for manufacturing phase, contains

similar requirements to

installation phase.

Purchase specifications shall specify the required as-shipped cleanness level for the item. Shop cleaning procedures shall be

in accordance with para. 2.2, and inspection and test results shall be documented, as appropriate, in accordance with approved procedures.

Listed below are cleaning considerations that are appropriate to all manufacturing operations. Additional information is

presented in ASTM A 380-78; where applicable, they shall be

considered.(a) Operations which generate chemical or particulate 5/25/04 Page 22 of 34 Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants ANSI N45.2.1 -1973 Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components for Nuclear Power Plants NQA-1-1994, Subpart 2.1 Comments contaminant such as welding and grinding shall be controlled during fabrication steps, after which removal of such

contaminants becomes difficult because of limited access.

Under such conditions, protection of openings shall be provided

to prevent entry of contaminants, especially particulate

contaminants. If practical, manufacturing sequence shall be

based on considerations related to cleaning of individual items

as the component is assembled, unless the component is readily

cleanable in its final assembled state.(b) Cleaning methods and materials used during manufacture shall be compatible with the materials of construction of the

item being cleaned (see para. 2.2.2). Cutting fluids, lubricants, liquid penetrants, marking materials, precleaning solutions, engineering test fluids, tools, and other materials and process

compounds to be used on surfaces of items made from

austenitic stainless steel or corrosion-resistant alloy during

manufacture shall be evaluated from the standpoint of

potentially harmful contaminants. Such contaminants include

chlorides, fluorides, and low melting point materials such as

sulfur, lead, zinc, copper, and mercury. Where potentially

harmful quantities of such contaminants can be leached or are

in a form that they could be released by breakdown of the

compound during subsequent manufacturing, installation, or

operation, they shall not be used. Paint, chalk, scribing inks, and

other temporary marking materials shall be removed from the

affected surfaces prior to heat treatment or welding.(c) Use of tools, such as those used for grinding, polishing, filing, deburring, and brushing during manufacture shall be controlled when surface contaminatio n of the item from such tools i s Considered an important factor.(d) The quality of fluid used for final flushing or rinsing shall be equivalent to the quality of the operational fluid of the item, unless otherwise specified in approved procedures (see para.3.4.1). Particular attention shall be paid to flushing of pockets, 5/25/04 Page 23 of 34 Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants ANSI N45.2.1 -1973 Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components for Nuclear Power Plants NQA-1-1994, Subpart 2.1 Comments crevices, or dead legs to assure that cleaning solutions are not trapped in such areas.(e) Fresh water may be used for mixing oil cleaning solutions and for initial rinsing and flushing when permitted by approved

procedures.(f) The final cleaned item shall be sealed in a dried condition to prevent subsequent recontamination and then packaged in

accordance with the requirements established in the

procurement documents.

4.0 PRE-INSTALLATION CLEANNESS 5 CLEANNESS PRIOR TO INSTALLATION Items should not be delivered to the point of installation site sooner than necessary unless the installation location is

considered a better storage area. Inspections, examinations, and tests as appropriate shall be performed immediately prior

to installation to determine the cleanness of the item. If

contaminants are detected, they shall be removed if it is judged

that they will not be removed in subsequent cleaning

operations. Items having surfaces to which temporary paint or

preservative coatings have been applied shall be identified, the

composition of the coating and methods for its removal shall be

determined and removal of coatings, where required, recorded

in the inspection report. Unless otherwise required by the job

specifications, the temporary coatings shall be removed prior to

installation of items.

From a cleanness standpoint, consideration shall be given as to whether items should be delivered to the point of installation

sooner than necessary, .e., whether the installation location is

a better storage area [see Subpart 2.2 of this Part (Part Il)].Inspections and tests, as appropriate, shall be made immediately prior to installation to determine the cleanness of

the item. If potentially harmful contaminants are detected, they

shall be removed if they will not be removed in subsequent

cleaning operations. Items having surfaces to which temporary

paint or preservative coatings have been applied shall be

identified; the composition of the coating and methods for its

removal shall be determined and removal of coatings, when

required, recorded in the inspection report. Unless otherwise

required by the job specifications, the temporary coatings shall

be removed prior to installation of items.

Similar 5.0 INSTALLATION CLEANING 6 CLEANNESS DURING INSTALLATION The installation process represents an opportunity for the introduction of contaminants into a cleaned item and care

should be taken to minimize contamination. Operations which

generate particulate matter, such as grinding and welding, should be controlled. Local cleanup of contaminated areas is

recommended as installation progresses, rather than one

cleanup operation when installation is completed.

Reg. Guide 1.37-3/73 Position C.5 states: Section 5 of ANSI The installation process represents an opportunity for the introduction of contaminants into a cleaned item, and care shall

be taken to minimize contamination. Operations that generate

particulate matter, such as grinding and welding, shall be

controlled. Cleanup of locally contaminated areas as installation

progresses is recommended (rather than one cleanup operation

when installation is completed).

Similar 5/25/04 Page 24 of 34 Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants ANSI N45.2.1 -1973 Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components for Nuclear Power Plants NQA-1-1994, Subpart 2.1 Comments N45.2.1 1973 states, in part, that operations such as grinding and welding which generate particulate matter should be

controlled. Adequate control of tools used in abrasive work

operations such as grinding, sanding, chipping, or wire brushing

should be provided. Specifically, tools which contain materials

that could contribute to intergranular cracking or stress-

corrosion cracking or which, because of previous usage, may

have become contaminated with such materials should not be

used on surfaces of corrosion-resistant alloys. Examples of

such materials are listed in Regulatory position 4. 6. Subdivision

1.4 of ANSI N45.2.1-1973 suggests the use of ASTM A 262-

68 or ASTM A 393-63 for detection of intergranular

precipitation of chromium carbides in corrosion-resistant alloys.

ASTM A 393-63 has been withdrawn by ASTM and is no

longer considered a valid test.

Consideration should be given to sequencing installation and erection operations, when practical, to facilitate cleaning and

cleanness control. Where visual inspection of internal surfaces

of a portion of a system can be blocked, that part of the system

should be fabricated as a complete unit and a visual inspection

should be performed just before the access points are closed.

Consideration shall be given to sequencing of installation and erection operations to facilitate cleaning, cleanness control, and

inspection. Insofar as practicable, internal surfaces of a portion

of a system that can be blocked or obscured by subsequent

operations shall be visually inspected and verified as being

clean before the access points are closed.

Similar Openings and pipe ends shall be sealed at all times except when they must be unsealed to carry out necessary operations.

Fitted and tack-welded joints (which will not be immediately

sealed by welding) shall be wrapped with polyethylene or other

nonhalogenated plastic film until the welds can be completed.

Openings and pipe ends shall be sealed at all times except when they must be unsealed to carry out necessary operations.

Similar Precautions shall be taken to avoid contamination of crevices, blind holes, dead legs, undrainable cavities, and inaccessible areas. When grinding, sanding, chipping or wire brushing, the item shall be so oriented that chips fall away from the openings

or covers shall be provided for the openings..

Precautions shall be taken to avoid contamination of crevices, blind holes, dead legs, undrainable cavities, and accessible areas. When grinding, sanding, chipping, or wire brushing, the item shall be so oriented that chips fall away from the

openings, or covers shall be provided for the openings.

Similar Marking materials containing sulfur, lead, zinc, mercury and other low melting alloys as a basic chemical constituent shall

not be brought into contact or shall not be used on the surfaces The use of cleaning methods and materials, cutting fluids, lubricants, liquid penetrants, marking materials, precleaning

solutions, engineering test fluids, tools, and other materials and Similar The level of detail in the

alternative should be 5/25/04 Page 25 of 34 Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants ANSI N45.2.1 -1973 Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components for Nuclear Power Plants NQA-1-1994, Subpart 2.1 Comments of corrosion resistant alloys. Low-sulfur, low-fluorine, and/or low-chlorine compounds may be used on austenitic stainless

steels. Low-sulfur, low-lead compounds may be used on

nickelbase alloys. Paints, chalk and other temporary marking

materials shall be removed by solvent-wiping or mechanical

means.Reg. Guide 1.37-3/73 Position C.4 states: Section 5 of ANSI N45.2.1-1973 states, in part, that low sulfur, low fluorine, and/or low chlorine compounds may be used on austenitic

stainless steels and that low sulfur and low lead compounds

may be used on nickel-base alloys. Chemical compounds that

could contribute to intergranular cracking or stress-corrosion

cracking should not be used with austenitic stainless steel and

nickel-base alloys. Examples of such chemical compounds are

those containing chlorides, fluorides, lead, zinc, copper, sulfur, or mercury where such elements are leachable or where they could be released by breakdown of the compounds under expected environmental conditions (e.g., by radiation). This

limitation is not intended to prohibit the use of

trichlorotrifluoroethane which meets the requirements of

Military Specification Mil-C-81302b for cleaning or degreasing

of austenitic stainless steel provided the precautions of

subdivision 7.3(4) of ANSI N45.2.1-1973 are observed.

The following is a clarification made in the current VA QATR: (3)With regard to Paragraph C.4 of Regulatory Guide 1.37: Expendable materials such as inks and related products, temperature indicating

stick, tapes, gummed labels, wrapping materials (other than

polyethylene), water soluble dam materials, lubricants, NDE penetrant materials and couplants, desiccants, and like materials which contact stainless steel or nickel alloy surfaces; shall not contain lead, zinc, copper, mercury, cadmium and other low melting point metals, their

alloys or compounds as basic and essential chemical constituents.

No more than 0.1 percent (1000 ppm) halogens will be allowed where such elements are leachable or where they could be released by breakdown of the compounds under expected environmental process compounds used during installation of items made from austenitic stainless steel or other corrosion-resistant alloys shall

be subject to the limitations on such methods and materials

specified in Section 4.

contained in the implementing procedures and is within the

requirements of the NQA-1

standard.

5/25/04 Page 26 of 34 Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants ANSI N45.2.1 -1973 Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components for Nuclear Power Plants NQA-1-1994, Subpart 2.1 Comments conditions.

Surfaces should be cleaned after completion of work on them, before proceeding to the next installation or construction step.

Surfaces shall be visually inspected upon completion of work on them, and obvious contamination removed before

proceeding to the next installation or construction step.

Similar The use of mineral acids and organic acids on austenitic stainless steels and nickel alloys should be avoided except

when the material is in the solution annealed condition. Pre-

cleaning and post-cleaning of weld joint areas and welds shall

be performed by wire brushing and scrubbing with a solvent-

moistened clean cloth unless specified otherwise.

The use of mineral acids and organic acids to clean austenitic stainless steel and nickel alloys shall be evaluated and

approved prior to use. Precleaning and post-cleaning of weld

joint areas and welds shall be performed by wire brushing and

scrubbing with a solvent-moistened clean cloth unless

otherwise specified.

Similar Local rusting on corrosion resistant alloys should be removed by mechanical methods.

The following is a clarification made in the current VA QATR: (4)With regard to Section 5 of ANSI N45.2.1-1973, titled Installation Cleaning: The recommendation that local rusting on corrosion resistant alloys be removed by mechanical methods is interpreted to mean that local rusting may be removed mechanically, but the use of

other removal means is not precluded as determined by Engineering.

This guidance not contained in NQA-1. Alternative no longer

required since cleaning is to

be as specified.

Large openings, such as the open reactor vessel shall be protected against falling and windblown contaminants.

Large openings, such as the open reactor vessel, shall be protected against falling and windblown contaminants.

Similar requirement.

6.0 MAINTENANCE

OF INSTALLATION CLEANNESS 7 MAINTENANCE OF INSTALLATION CLEANNESS After any isolable system has been installed in a clean condition and cleanness control measures have been established, access control into the system is essential to

minimize the introduction of contaminants between the time of

system isolation and pre-operational testing. Access control

shall be established to exclude personnel and contaminants.

Where environmental contamination could cause degradation

of quality, seals must be installed which must be hermetically

tight and difficult to remove After any isolable item has been installed in a clean condition, cleanness control measures and access control shall be established to minimize the introduction of contaminants

between the time of system isolation and preoperational

testing. Where environmental contamination could cause

degradation of quality, seals shall be installed to prevent

contamination of interior surfaces. Materials used for sealing

items made from austenitic stainless steel or other corrosion-

resistant alloys shall be subject to the limitations specified in

Section 4. Seals shall be installed in a manner to prevent

accidental removal.

Similar Gasketed metal seals with welded metal strap closures, or seal Removal shall be only with proper authorization. If access to Similar 5/25/04 Page 27 of 34 Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants ANSI N45.2.1 -1973 Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components for Nuclear Power Plants NQA-1-1994, Subpart 2.1 Comments welded metal caps are recommended for Class B systems and components. Items in this condition shall be tagged with

identifications and instructions for seal removal. If access to a

sealed system is required, precautions shall be taken to prevent

introduction of contaminants. Prior to opening the seals, the

immediate surroundings should be cleaned to remove solid

contaminants which might be introduced in the system.

Personnel entering the system should wear clean outer clothing

and shoe covers. When the necessary work is completed, the

interior surface shall be locally cleaned to its original condition

and the system should be resealed.

such sealed items is required, precautions shall be taken to prevent introduction of contaminants. Such precautions include

masking and tenting of surrounding areas with plastic film or

tape, cleanup of the immediate surroundings to remove

particulate matter that can be introduced into the opening, requiring personnel to wear clean outer clothing and shoe

covers, etc. Control of tools, loose items, and access shall be

maintained in accordance with applicable requirements. When

the necessary work is completed, the interior surface shall be

locally cleaned, if necessary, to its original condition and the

item resealed.

7.0 PRE-OPERATIONAL CLEANING 8 PREOPERATIONAL CLEANING

7.1 Preparations

8.1 Preparations Cleaning and flushing operations shall be scheduled so as to minimize interference from other plant operations. Areas in

which cleaning operations are being performed shall be isolated

to the extent that personnel performing other construction

phase operations are aware that the cleaning operations are

being conducted.

Insofar as practicable, cleaning and flushing operations shall be scheduled so as to minimize interference from other plant

operations. Areas in which cleaning operations are being

performed shall be isolated and marked to the extent that

personnel performing other construction phase operations are

aware that the cleaning operations are being conducted.

Similar Personnel shall be familiarized with the intended procedure and associated hazards. Means for communicating shall be

provided between the local areas in which the cleaning is

performed and any remote areas (e.g., control rooms) that may

be related to the cleaning operations.

Personnel shall be familiarized with the intended procedure and associated hazards. Means for communicating shall be

provided between the local areas in which the cleaning is

performed and any remote areas (e.g., control rooms) that may

be related to the cleaning operations.

Same Loose tools should be attached to either the workman or the exterior of the system with a lanyard. The actual circulating

flow path shall be checked for agreement with specified

requirements in regard to location, position and Status of all

components.

Tools and other loose items in controlled areas shall be controlled as specified in Section 7. The actual circulating flow

path shall be checked for agreement with specified

requirements with regard to location, position, and status of all

components.

Similar Critical valves, controls and switches shall be tagged to prevent inadvertent actuation during the cleaning operation. The interior

of all accessible components (e.g., tanks) and large diameter

piping shall be inspected for cleanness; all debris and

contamination shall be removed.

Demineralizers, filters, Critical valves, controls, and switches shall be tagged to prevent inadvertent actuation during the cleaning operation.

The interior of all accessible components (i.e., tanks) and large

diameter piping shall be inspected for cleanness; all debris and

contamination shall be removed.

Demineralizers, filters, Similar 5/25/04 Page 28 of 34 Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants ANSI N45.2.1 -1973 Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components for Nuclear Power Plants NQA-1-1994, Subpart 2.1 Comments instruments, valve internals and other items that may be damaged by the cleaning process shall be blanked off, bypassed or removed.

instruments, valve internals, and other items that may be damaged by the cleaning process shall be blanked off, bypassed, or removed.

Protective screens shall be installed on the suction side of all pumps and other components that may be subject to damage

during the cleaning operations. Instrumentation (e.g., pressure, temperature and flow) shall be used where possible to monitor

the cleaning operations. All other permanently installed

instrumentation shall be isolated where possible.

Protective screens shall be installed on the suction side of all pumps and other components that may be subject to damage

during the cleaning operations. Instrumentation (e.g., pressure, differential pressure temperature, and flow) shall be used as

necessary to monitor flushing and recirculatory cleaning operations. Instrumentation installed in the system but not used to monitor the cleaning operations shall be isolated where

necessary.

Similar Cleaning should be completed before installation of fuel, reactor vessel internals and control rods. Provisions shall be

made to collect leakage and to protect insulation from being

wetted. Where the use of installed plant components, such as

pumps, may be affected by the cleaning operations, recommendations shall be obtained from the component

manufacturers regarding the use of their components.

Procedures used to protect installed components which are not

used in the cleaning operations but which are included in the

cleaning circuit should be reviewed.

Cleaning of the reactor vessel and reactor vessel internals shall be completed before installation of fuel and control rods.

Provisions shall be made to collect liquid leakage and to

prevent wetting of insulation. Where the use of installed plant

components such as pumps may be affected by the cleaning

operations, recommendations shall be obtained from the

component manufacturers regarding precautions to be taken

for the use of their components. Procedures shall be

established to protect or isolate installed components that could

be adversely affected by cleaning or flushing operations.

Similar 7.2 Flushing and Cleaning Methods

8.2 Flushing

and Cleaning Methods

7.2.1 Water

Flushing.

.8.2.1 Flushing.

If the intended level of cleanness has been maintained during erection of the plant, only water flushing will be required. The

system shall be filled with water of the quality specified and

flushed in accordance with approved procedures. Completion

of flushing shall be determined by filter, turbidimetric or chemical analyses If the intended level of cleanness has been maintained during erection of the plant, only flushing or rinsing will normally be

required. The system shall be filled with fluid of the type and

quality specified and flushed in accordance with approved

procedures. Completion of flushing shall be determined by

filter, turbidimetric or chemical analysis, or any combination of these, as applicable.

Similar If the final flushes for removal of particulate contaminants are directed toward the reactor vessel, soluble contaminants shall

be removed from the system by first flushing away from the

reactor vessel until a specified water quality is achieved on the If flushes are directed toward the large components, provisions shall be made to prevent contaminants from collecting in areas

where they cannot be removed in subsequent cleaning

operations. Provisions shall be made to assure that organics do Similar 5/25/04 Page 29 of 34 Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants ANSI N45.2.1 -1973 Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components for Nuclear Power Plants NQA-1-1994, Subpart 2.1 Comments effluent from the system. At this time, high velocity flushes may be made toward the reactor vessel. This procedure is not

recommended unless reactor vessel internal surfaces are

accessible for subsequent mechanical cleaning and inspection, or unless provisions are made to collect particulate

contaminants at some accessible location within the reactor

vessel by filtration or other technique.

not remain on the surfaces.

After system flushing is completed, but before system drain, all pockets and dead legs shall be flushed through their drain

connections. If conditioned water is used, particular attention

should be given to assure that large volumes of solution do not

remain trapped in the system. Care shall be taken to assure

that organics do not remain on the surfaces.

After system flushing is completed, but before draining, all pockets and dead legs shall be thoroughly flushed. Where

conditioned water is used, particular attention should be given

to assure that large volumes of solvent do not remain trapped

in the system.

Similar A final flush with demineralized water is desirable but is not necessarily required at this time. The system shall be sealed to prevent the subsequent entry of contamination. If no further

cleaning is required, system layup may be performed.

After cleaning, the item shall be sealed where appropriate to prevent the subsequent entry of contaminants. If no further

cleaning is required, system lay-up shall be performed if

specified.

Similar 7.2.2 Alkaline Cleaning.

8.2.2 Alkaline

Cleaning.

Although it shall be the intent of those involved in erecting the nuclear plant to install piping systems in a clean condition, this

may not be achieved. One relatively common source of

organic contamination in piping systems is lubricating oils from

air tools. When local cleanup is not performed following

grinding operations on internal surfaces of piping welds, full

system cleaning to remove organic contaminants may be

necessary.

Although it is the intent of those involved in erecting the nuclear plant to install piping systems and components in a

clean condition, this may not be fully achieved. Common

sources of organic contamination in items are lubrication oils

from air tools, preservative films, and valve lubricants. When

immediate local cleanup is not performed, full item cleaning to

remove such organic contaminants may be necessary.

Similar If required, the cleaning shall be performed according to the cleaning procedures established for the operation and the

procedure shall assure that quantities of organics do not remain on the surfaces.

Such cleaning shall be performed according to the cleaning procedures established for the operation, and the procedure

shall assure that quantities of organic contaminants do not

remain on the surfaces.

Similar Alkaline cleaning should consist of the circulation of an appropriately heated solution until a selected area or a coupon

contaminated with the expected contamination is cleaned by

the cleaning solution.

Alkaline cleaning consists of the circulation of an appropriately heated solution until a selected area represented by the worst

contamination or a coupon contaminated with the expected

contamination is cleaned by the cleaning solution to the Similar 5/25/04 Page 30 of 34 Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants ANSI N45.2.1 -1973 Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components for Nuclear Power Plants NQA-1-1994, Subpart 2.1 Comments specified cleanness level.

After system cleaning is completed, a flush with water of a quality consistent with the system requirements shall be

performed to remove the cleaning agents. In particular, all

pockets and dead legs should be flushed and attention should

be given to assure that large volumes of solution do not remain

in the system.

After item cleaning is completed, the item shall be flushed with water of the specified quality to remove the cleaning agents. In

particular, all pockets and dead legs shall be flushed and

attention given to assure that large volumes of solution do not

remain.Similar The system should be sealed to prevent the subsequent entry of contamination. If no further cleaning is required, system

layup may be performed. Precautions related to the use of

alkaline cleaning solutions are listed in paragraph 7.3.

Where appropriate, the item shall be sealed to prevent subsequent contamination. If no further cleaning is required, system lay-up shall be performed, if specified. Precautions

related to the use of alkaline cleaning solutions are listed in

Part III, Subpart 3.2, Appendix 2.1.

Similar 7.2.3 Chelate Cleaning.

8.2.3 Chelate

Cleaning.

Chelate cleaning of carbon or low-alloy steel surfaces to remove light corrosion product films is not a required cleaning

operation. If chelating cleaning is used, flushing with water of a quality consistent with the system requirements should be performed to remove the chelating agents. All pockets and dead legs in particular should be flushed and attention should be given to assure that large volumes of the chelating solution do not remain in the system.

If chelate cleaning is used, attention shall be given to all pockets and dead legs to ensure that large volumes of solution do not remain in the item. Unless it is considered desirable to

leave a film of chelating agent on the surfaces as a protective film, the item shall be flushed with water of a quality consistent with the item requirements to remove residual chelating agents.

Similar, but changed from recommendations to

requirements of NQA-1where

determined to be appropriate.

The system should be sealed to prevent the subsequent entry of contaminants. If no further cleaning is required, layup may be performed. Precautions related to the use of chelating agents are listed in paragraph 7.3.

Where appropriate, items shall be sealed to prevent subsequent contamination. If no further cleaning is required, lay-up shall be

performed, if specified. Precautions related to the use of

chelating agents are listed in Part III, Subpart 3.2, Appendix

2.1.Similar, but changed from recommendations to

requirements of NQA-1where

determined to be appropriate.

7.3 Cleaning

Precautions There are a number of precautions that should be observed during cleaning operations. The following should be considered

as appropriate.

Recommendations, not requirements.

1. The addition of a suitable chloride stress cracking inhibitor is recommended if fresh water flushing of systems containing

austenitic stainless steels is planned.

2. The use of alkaline cleaning compounds which contain free 5/25/04 Page 31 of 34 Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants ANSI N45.2.1 -1973 Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components for Nuclear Power Plants NQA-1-1994, Subpart 2.1 Comments caustic is not recommended on components or systems in which cleaning solutions may be entrapped. Cleaners based on

compounds which produce hydroxyl ions by hydrolysis, such as

trisodium phosphate, are recommended. If heavy organic solids

are present, the addition of an emulsifier and a wetting agent

may be considered.

3. The use of acid-chelating agents on welded or furnace sensitized stainless steels and nickel base alloys is not recommended.

4. The use of halogenated organic solvents is not recommended except upon crevice-free, open, freely-evaporating surfaces. This recommendation is not intended to

prohibit the use of such solvents under other conditions, providing adequate removal is assured prior to any subsequent

operations.

5. Acid cleaning of installed systems is not recommended.

However, if used, particular attention shall be given to: (a) Avoiding the entrapment of acids in the crevices.(b) Avoiding contact with either welded or furnace sensitized corrosion resistant alloys, and non-ferrous materials.(c) Complete removal of any residual acid solution from the system.(d) Neutralization treatment as a final operation.

8.0 LAYUP

AND POST-LAYUP CLEANING 9 LAYUP AND POST-LAYUP CLEANING 8.1 Upon completion of pre-operational cleaning, unless the system is to be released for the next series of operations or tests, the system should be placed in layup condition, if required, by filling with dry inert gas, the process fluid that will be used in the system during operation, water of purity

equivalent to that used to make up the system, or chemically-

conditioned water.

Upon completion of preoperational cleaning, unless the item is to be released for the next series of operations or tests, the

item shall be placed in lay-up condition by filling with dry, contaminant-free inert gas or dry air; the process fluid that will

be used in the system during operation; fluid of purity

equivalent to that used to make up the system; chemically

conditioned fluid; or other specified method.

Similar 8.2 Prior to the next series of operations or tests residual cleaning solutions or layup chemicals shall be removed from Prior to the next series of operations or tests, residual cleaning solutions or lay-up media shall be removed, if required, from Similar 5/25/04 Page 32 of 34 Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants ANSI N45.2.1 -1973 Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components for Nuclear Power Plants NQA-1-1994, Subpart 2.1 Comments the system by flushing, or draining and filling until the effluent water from the system meets the pre-operational test water

quality requirements for the system.

the item by flushing or by draining and filling until the effluent fluid from the item meets the preoperational test fluid quality

requirements for the system.

10 POST-OPERATIONAL REPAIRS AND MODIFICATIONS Subpart 2.1 does not address radioactive decontamination operations that may be required prior to post-operational

repairs or system modifications, although some of its

requirements may be applicable to such decontamination

Operations. For the purposes of maintenance of cleanness as

defined in Subpart 2.1, post-operational repairs or system

modifications shall be considered identical to preoperational

installation procedures and treated in accordance with Sections

5, 6, and 7.

New requirements to address operations phase activities.

If system cleaning following repair or modification operations is deemed necessary, such cleaning shall be performed in

accordance with Section 8, except that flushes directed toward

the reactor vessel shall, to the extent possible, first be preceded

with flushes directed away from the reactor vessel until

expected contamination is removed and the specified water

quality level is achieved. If lay-up is deemed necessary, it shall

be performed in accordance with Section 9.

9.0 RECORDS

11 RECORDS Record copies of completed procedures; reports; personnel qualification records; test equipment calibration records, test

deviation or exception records; inspection and examination

records shall be prepared.

The following shall be prepared: (a) record copies of procedures;(b) reports;(c) test equipment calibration records;(d) test deviation or exception records;(e) inspection and examination records; (f) other records

necessary to document the cleaning and cleanness history of

the items during manufacture, shipment, storage, installation, preoperational cleaning, modifications, and repairs.

Similar These shall be placed with other project records as required by code, standard, specification, or project procedures. Collection, storage and maintenance records shall be in accordance with

ANSI N45.2.9.

These records shall be retained with other project records as required by code, standard, specification, or project

procedures.

Similar 5/25/04 Page 33 of 34 Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants ANSI N45.2.1 -1973 Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components for Nuclear Power Plants NQA-1-1994, Subpart 2.1 Comments 10.0 REVISION OF ANSI STANDARDS REFERRED TO IN THIS DOCUMENT When the following standards referred to in this document are superseded by a revision approved by the American National

Standards Institute, the revision shall apply.

Commitment to specific standards will be controlled

through compliance with the

regulations regarding QA

programs.N45.2 Quality Assurance Program Requirements for Nuclear Power Plants

N45.2.3 Housekeeping During the Construction Phase of

Nuclear Power Plants

N45.2.6 Qualification of Inspection, Examination, and Testing

Personnel for the Construction Phase of Nuclear Power Plants

N45.2.9 Requirements for Collection, Storage and

Maintenance of Quality Assurance Records

• N45.2.10 Terms and Definitions.

• These Standards are being approved by The American National Standards Institute and they should (will) be available

in 1973 5/25/04 Page 34 of 34 5/25/04 Page 1 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments 1. INTRODUCTION 1 GENERAL 1.1 Scope This standard defines requirements for packaging, shipping, receiving, storage, and handling of nuclear power plant items.

These items include the parts of structures, systems, and

components whose satisfactory performance is required for the

plant to operate reliably, to prevent accidents that could cause

undue risk to the health and safety of the public, or to mitigate

the consequences of such accidents if they were to occur. The

requirements stated herein deal with the protection and control

necessary to assure that the requisite quality of those important

parts of the plant arc preserved from the time items are

fabricated until they are incorporated in the plant.

This standard is intended to be used in conjunction with ANSI

N45.2, Quality Assurance Program Requirements for Nuclear

Power Plants. The requirements may also be extended to other

appropriate parts of nuclear power plants when specified in

contract documents.

NRC Regulatory Guide 1.38 Regulatory Position C.1. The requirements for the packaging, shipping, receiving, storage, and handling of items for water-

cooled nuclear power plants that are included in ANSI N45.2.2-

1972, "Packaging, Shipping, Receiving, Storage, and Handling of

Items for Nuclear Power Plants During the Construction

Phase,"(2) are acceptable to the NRC staff and, when

supplemented by the guidelines identified in Regulatory Position

2, provide an adequate basis for complying with the pertinent

quality assurance requirements of Appendix B to 10 CFR Part

50, subject to the following:

d. Although ANSI N45.2.2-1972 is entitled "Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear

Power Plants During the Construction Phase," the requirements

included in the standard are considered to be applicable during

the operation phase and should be used, where applicable, consistent with the recommendations of this regulatory guide.

Subpart 2.2 provides amplified requirements for packaging, shipping, receiving, storage, and handling of nuclear power plant

items. It supplements the requirements of Part l and shall be

used in conjunction with applicable Basic and Supplementary

Sections of Part I when and to the extent specified by the

organization invoking Subpart 2.2.

Similar requirement.

NRC position is that the ANSI

standard applies to the

operations phase in addition to

construction.

NQA-1 makes this Subpart

applicable to all phases of the

facility's life, from siting and

design through

decommissioning.

5/25/04 Page 2 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments 1.2 Applicability The requirements of this standard apply to the work of any individual or organization that participates in the packaging, shipping, receiving, storage and handling of items to be

incorporated into nuclear power plants as discussed in

Subsection 1.1 of this standard. The extent to which the

individual requirements of this standard shall apply will depend

upon the nature and scope of the work to be performed and the

importance of the item or service involved. The requirements

are intended to assure that the quality of items is not degraded

as a result of packaging, shipping, receiving, storage, and

handling practices and techniques.

The following is an Exception made in the current MP QATR: ANSI N45.2.2 - 1972 , paragraph 1.2, states in part that, "The requirements of this standard apply to the work of any individual or organization that participates in the packaging, shipping, receiving, storage, and handling of items to be incorporated into

nuclear power plants." Since a portion of the licensee

procurement activities involve commercial suppliers which do

not fully comply with the requirements of ANSI N45.2.2, the

licensee's Supply Chain Management organization verifies

through source inspections, receipt inspection, and/or survey

activities that the quality of the materials, items, components or

equipment is preserved by those suppliers to the extent that

packaging, shipping, storage and handling methods are

employed which are commensurate with the nature of the

product.See NQA-1-1994 Part II Introduction for Applicability.

Similar requirements.

Alternative not needed under

the proposed program.

1.3 Responsibility

The organization or organizations responsible for establishing the applicable requirements for the activities covered by this

standard shall be identified and the scope of their responsibilities

shall be documented. The work of establishing practices and

procedures and providing the resources in terms of' personnel, equipment and services necessary to implement the See NQA-1-1994 Part II Responsibility for Applicability.

Similar requirements.

5/25/04 Page 3 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments requirements of this standard may be delegated to other organizations and such delegation also shall be documented.

However , it is the responsibility of each organization performing work covered by this standard to comply with the procedures and instructions issued for the project and to conform to the

requirements of this standard applicable to his work.

The following shall be used as a guide in determining those responsibilities which shall be established and documented:

1. Classification of items (protection level)

2. Packaging design and methods

3. Shipping requirements and methods

4. Receiving requirements and methods

5. Storage requirements and procedures

6. Handling requirements and procedures

7. Records Guidance in NQA-1 is not as specific to this subpart.

1.4 Definitions

1.1 Definitions The following definitions are provided to assure a uniform understanding of select terms as they are used in this standard.

The following definitions are provided to assure a uniform understanding of unique terms as they are used in Subpart 2.2.

See NQA-1, Part I Introduction for additional

definitions Barrier - A flexible material designed to withstand the penetration of water, water vapor, grease, or harmful gases.

barrier - a flexible material designed to withstand the penetration of water, water vapor, grease, or harmful gases Same Carrie r - The transporting agency

.carrier -

the transporting agency Same Classification - The organization of items according to their susceptibility to damage during shipping, receiving and storage only. It does not relate to the function of the item in the

completed system.

classification - the organization of items according to their susceptibility to damage during shipping,, receiving, and storage only. It does not relate to the function of the item in the

completed system.

Similar Documentation - Any written or pictorial information describing, defining, specifying, reporting, or certifying activities, requirements, procedures or results.

Definition in Part I is similar in wording.

Similar Dynamic Load Test - A test to demonstrate the ability of hoisting equipment to safely handle its rated load by exercising the equipment through vertical and horizontal movement along

its lines of travel, using a load of specified weight.

dynamic load test - a test wherein designated loads are hoisted, rotated, or transported through motions and accelerations required to simulate handling of the intended item Similar Handling - The act of physically moving items by hand or by See Subpart 2.15 for this definition. 2.15 limits the term to use All of the handling information 5/25/04 Page 4 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments mechanical machinery, not including transport modes.

of equipment for handling.

from this standard has been added to Subpart 2.15.

Item - Any level of unit assembly, including system, subsystem, subassembly, component, part, or material.

Definition in Part I is similar in wording.

Similar Nonconformance - A deficiency in characteristic, documentation, or procedure which renders the quality of an item unacceptable or indeterminate. Examples of

nonconformance include: physical defects, test failures, incorrect or inadequate documentation, and deviation from

prescribed processing, inspection or test procedures.

Definition in Part I is similar in wording.

Similar Package - The shipping container plus the contents of the container.

Not defined in NQA-1 Package Unit - Any assembly of mechanical and/or electrical components and parts which can be disassembled without destroying the integrity of the individual parts.

Not defined in NQA-1 Receiving - To take delivery of material at the construction site or other location designated by the purchaser.

Definition in Part I is similar in wording.

Similar Storage - The act of holding items at the construction site or in an area other than its permanent location in the plant.

storage - the act of holding items in storage facilities Similar Storage Facilities - Warehouse or yard area designated and prepared for holding of items.

storage facilities - warehouse, yard, or other areas designated and prepared for holding of items Similar Transit Carrier (Open) - Trucks, Trailers, Railroad cars, Barges, Aircraft, or Ships which do not provide protection of items from the environment.

Not defined in NQA-1 Transit Carrier (Closed) - Trucks, Trailers, Railroad cars, Barges, Aircraft or Ships which do provide protection of items from the environment by nature of their inherent design.

Not defined in NQA-1 Transportation Mode - A method identified by the conveyance used for transportation of items and includes any motor vehicles, ships, railroad cars, or aircraft. Each cargo-

carrying body (trailer, van, box car, etc.) is a separate vehicle.

transportation mode - a method identified by the conveyance used for transportation of items and includes any motor vehicles, ships, railroad cars, or aircraft. Each cargo carrying

body (trailer, van, boxcar, etc.) is a separate vehicle.

Similar Wrap - A flexible material, formed around the item or package to exclude dirt and to facilitate handling, marking or labeling.

wrap - a flexible material formed around the item or package to exclude dirt and to facilitate handling, marking, or labeling Same Other terms and their definitions are contained in ANSI Not stated in this subpart, but note that other definitions are 5/25/04 Page 5 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments N45.2.10.contained in Part I, Introduction and other Subparts.

1.5 Referenced

Documents Other documents that are required to be included as a part of this standard are either identified at the point of reference or

described in Section 9 of this standard. The issue or edition of

the referenced document that is required will be specified either

at the point of reference or in Section 9 of this standard.

NRC Regulatory Guide 1.38 Regulatory Position C.1.a. Subdivision 1.5 of ANSI N45.2.2-1972 states that other documents required to be included as a

part of this standard are either identified at the point of

reference or described in Section 9 of the standard. The

specific acceptability of these listed documents has been or will

be covered separately in other regulatory guides or in

Commission regulations where appropriate.

Other documents and standards are addressed in the

new QA program, Appendix

C.2. GENERAL REQUIREMENTS 2 GENERAL REQUIREMENTS This section contains requirements that are to be fulfilled by the organization or organizations responsible for performing any

segment of work described in Sections 3 through 8 of this

standard.

Measures shall be established and implemented for the

packaging, shipping, receiving, storage and handling of specified

items to be incorporated in the nuclear power plant and for the

inspections, examinations, testing and documentation to verify

conformance to specified requirements.

Measures shall be established and implemented for the packaging, shipping, receiving, storage, and handling of specified

items to be incorporated in the nuclear power plant, and for the

inspection, testing, and documentation to verify conformance to

specified requirements.

Similar 2.1 Planning

2.1 Planning

and Procedures The specific items to be governed by this standard shall be identified. Planning shall take into account the need for the

preparation and control of procedures and work instructions as

necessary to comply with specified requirements. Planning shall

include a review of the design specifications and drawings for

the items covered by this standard to assure that packaging, shipping, receiving, storage, and handling activities have been

incorporated and that they can be accomplished as specified.

Clarification from the current VA QATR:

Planning and procedure preparation shall be in accordance with the requirements of the introduction to this Part (Part II).

Similar requirements in the referenced section of NQA-1.

Clarification not needed under

the proposed program.

5/25/04 Page 6 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments Planning: (First sentence.) The specific items to be governed by the Standard shall be identified in Administrative Procedures.

2.2 Procedures

and Instructions Procedures and instructions shall be generated, used, and maintained current; these shall contain sufficient detail to

provide for the listed items (See Subsection 2.1 of this

Standard) a basis for packaging design, shipping requirements, receiving, storage and handling procedures, implementation

thereof, and inspection, in accordance with this standard.

See NQA-1-1994 Part II Introduction for Procedures.

Similar requirements in the referenced section of NQA-1.

2.3 Results

Inspection and test results shall be documented in a suitable test report or data sheet.

Each report shall identify the item to which it applies , the procedures or instruction followed in performing the task and the identification of the following:

(1) Conditions encountered which were not anticipated, including nonconformance.

(2) Identity of inspector or tester.

(3) Completion date.

Test reports and data sheets shall include an evaluation of the

acceptability of inspection and test results and provide for

identifying the individual who performed the evaluation.

Clarification from the current VA QATR:

(2) With regard to Section 2.3 of ANSI N45.2.2-1972, titled Results: The specific methods for performing and documenting tests and inspections are given in Sections 17.2.10 and 17.2.11 of the Operational QA Program. The requirements in these

Sections will be implemented in lieu of the general requirements

here.Documentation of inspection and test results is addressed in

Part I of NQA-1, Basic

Requirements 10 and 11.

Clarification not needed under

the proposed program.

2.4 Personnel

Qualifications Those personnel who perform inspection, examination or testing activities at the job site shall be qualified in accordance with

N45.2.6. Off-site inspection, examination or testing shall be

audited and monitored by personnel who are qualified in

accordance with N45.2.6.

Qualification is covered by NQA-1, Part I, Supplement

2S-1, and Part III, Appendix

2A-1.

5/25/04 Page 7 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments 2.5 Measuring and Test Equipment M&TE is covered by NQA-1 Part I, Requirement 12, and

Part II, Subpart 2.16, and

contain similar requirements to

N45.2.2.2.5.1 Selection.

Inspection, examination, and testing equipment utilized to implement the requirements of this standard shall be selected to

have accuracy and tolerance sufficient to determine

conformance to specified requirements.

2.5.2 Calibration

and Control.

As appropriate, measuring and test equipment shall be adjusted and calibrated at prescribed intervals against certified

equipment having known valid relationships to nationally

recognized standards. If no national standards exists, the basis

for calibration shall be documented. Records shall be

maintained and equipment suitably marked to indicate

calibration status.

2.6 Housekeeping

In job-site areas, facilities, and environments where packaging, shipping. receiving, storage and handling of items is performed

in accordance with the requirements of this standard, the

housekeeping requirements shall be in accordance with

N45.2.3.Housekeeping is covered by NQA-1, Part II, Subpart 2.3

2.7 Classification

of Items

2.2 Classification

of Items The requirements for activities covered by this standard (packaging, shipping, receiving, storage and handling) are

divided into four levels with respect to protective measures to

prevent damage, deterioration or contamination of the items, based upon the important physical characteristics and not upon

the important functional characteristic of the item with respect

to safety, reliability and operation.

Clarification from the current VA QATR:

(3) With regard to Section 2.7 of ANSI N45.2.2-1972, titled Clarification of Items

The Company may choose not to Requirements are divided into four levels with respect to protective measures to prevent damage, deterioration, or

contamination of the items based upon the important physical

characteristics, and not upon the important functional

characteristics of the item with respect to safety, reliability, and

operation.

Similar requirements.

Clarification not needed under

the proposed program.

5/25/04 Page 8 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments explicitly use the four level classification system. However, the specific requirements of the Standard that are appropriate to

each class are applied to the items suggested in each

classification and to similar items as determined by station

management.

It should be recognized, however, that within the scope of each level there may be a range of controls and that the detailed

requirements for an item are dependent on the importance of

the item to safety or reliability. For example, even though a

reactor vessel and structural steel are classified as level D, the

degree of protection and control over the reactor vessel should

exceed that of the structural steel. Each of the specific items

governed by this procedure (See Subsection 2.1 of this

standard) shall be classified into one of these four levels by the

buyer or contractor.

It should be recognized, however, that within the scope of each level there may be a range of controls, and that the detailed

requirements for an item are dependent on the importance of

the item to safety reliability. For example, even though a reactor

vessel and structural steel are classified as Level D, the degree

of protection and control over the reactor vessel should exceed

that of the structural steel. Each of the specific items governed

by Subpart 2.2 shall be classified into one of these four levels by

the buyer or the contractor.

Similar The manufacturer's documented standard or minimum requirements shall be considered when classifying the items.

Items, once classified, shall be restricted to the level or higher

for each of the packaging, shipping, receiving, storage and

handling operations. Items shall not be classified according to

the requirements of one level, then packaged, shipped, received, stored or handled according to a level of lower grade. Any

package unit or assembly made up of items of different levels

shall be classified to the highest level designated for any of the

respective parts. If the unit is disassembled, a level shall be

indicated for each part. When the unit cannot be physically

disassembled, special rules are contained herein.

The manufacturer's documented standard or minimum requirements shall be considered when classifying the items.

Items, once classified at a level, shall be restricted to that level

or a higher level for each of the packaging, shipping, receiving, storage, and handling operations. Any package unit or assembly

made up of items of different levels shall be classified to the

highest level designated for any of the respective items. If the

unit is disassembled, a level shall be indicated for each part.

Similar Items covered by this standard shall be categorized under the following levels:

Items covered by Subpart 2.2 shall be categorized under the following levels.

Similar 2.7.1 Level A -Items classified to level A are those that are exceptionally sensitive to environmental conditions and require special measures for protection from one or more of the

following effects:

2.2.1 Level

A.

Items classified to Level A are those that are exceptionally sensitive to environmental conditions and require special measures for protection from one or more of the

following effects:

Similar temperatures outside required limits, (a) temperatures outside required limits Similar sudden temperature changes, (b) sudden temperature changes Similar 5/25/04 Page 9 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments humidity and vapors, (c) humidity and vapors Similar gravitational (g) forces, (d) accelerating forces Similar physical damage (e) physical damage Similar and airborne contamination (e.g. rain, snow, dust, dirt, salt spray, fumes).(f) airborne contamination (e.g., rain, snow, dust, dirt, salt spray, fumes)Similar The following shall be used as a guide for classifying items intended for this level classification:

Types of items to be categorized under this classification level are: Similar (1) Special electronic equipment and instrumentation.(a) special electronic equipment and instrumentation Similar (2) Special materials, such as chemicals that are sensitive to environment.(b) special materials, such as chemicals, that are sensitive to environment Similar (3) Special nuclear material (fuel) and sources. The requirements of the AEC fuel license and conditions and other

governmental agencies shall be met.(c) special nuclear material and sources.

The requirements of the NRC fuel license and conditions and of

other governmental agencies shall be met.

Similar 2.7.2 Level B -

Items classified to level B are those that are sensitive to environmental conditions and require measures for protection from the effects of temperature extreme, humidity

and vapors, g-forces, physical damage and airborne

contamination and should not require special protection required

for level A items.

2.2.2 Level

B.

Items classified to Level B are those that are sensitive to environmental conditions and require measures for protection from the effects of temperature extremes, humidity

and vapors, accelerating forces, physical damage, and airborne

contamination, and do not require special protection required for

Level A items.Similar The following shall be used as a guide for classifying items intended for this level classification:

Types of items to be categorized under this classification level are Similar (1) Instrumentation (a) instrumentation Similar (2) Electrical penetrations (b) electrical penetrations Similar (3) Batteries (c) batteries Similar (4) Welding electrode and wire (d) welding electrode and wire (Welding electrodes hermetically sealed in metal containers may be stored under conditions

described for Level C, unless other storage requirements are

specified by the manufacturers.)

NQA-1 added clarifying information in parentheses.

(5) Control rod drives (e) control rod drives Similar (6) Motor control centers, switchgear and control panels (f) motor control centers, switchgear, and control panels Similar (7) Motors and generators (g) motors and generators Similar (8) Precision machined parts (h) precision machine parts Similar (9) Erection spares, such as gaskets, "O" rings (i) spares, such as gaskets, O-rings Similar (10) Air handling filters (j) air handling filters Similar 5/25/04 Page 10 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments (11) Computers (k) computers Similar 2.7.3 Level C -

Items classified to level C are those that require protection from exposure to the environment, airborne contaminants, g-forces and physical damage. Protection from

water vapor and condensation is not so important as that for

Level B items.

2.2.3 Level

C.

Items classified to Level C are those that require protection from exposure to the environment, airborne contamination, acceleration forces, and physical damage.

Protection from water vapor and condensation is not as

important as for Level B items.Similar The following shall be used as a guide for classifying items intended for this level classification:

Types of items to be categorized under this classification level are Similar (1) Pumps (a) pumps Similar (2) Valves (b) valves Similar (3) Fluid filters (c) fluid filters Similar (4) Reactor internals (d) reactor internals Similar (5) Compressors (e) compressors Similar (6) Auxiliary Turbines (f) auxiliary turbines Similar (7) Instrument cable (g) instrument cable (unjacketed)

NQA-1 adds unjacketed.

(8) Refueling equipment (h) refueling equipment Similar (9) Thermal insulation (i) thermal insulation Similar (10) Fans and blowers (j) fans and blowers Similar (11) Cement (k) cement Similar (l) fabricated fuel rods and assemblies Added in NQA-1-1994.

2.7.4 Level

D -

Items classified to Level D are those that are less sensitive to the environment than level C. These items require protection against the elements airborne contamination, and physical damage.

2.2.4 Level

D.

Items classified to Level D are those that are less sensitive to the environment than those for Level C. These items require protection against the weather, acceleration

forces, airborne contamination, and physical damage.

Similar The following shall be used as a guide for classifying items intended for this level classification:

Types of items to be categorized under this classification level are: Similar (1) Tanks (a) tanks Similar (2) Heat exchangers and parts (b) heat exchangers and parts Similar (3) Accumulators (c) accumulators Similar (4) Demineralizers (d) demineralizers Similar (5) Reactor vessel (e) reactor vessel Similar (6) Evaporators (f) evaporators Similar (7) Steam generators (g) steam generators Similar (8) Pressurizer (h) pressurizers Similar 5/25/04 Page 11 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments (9) Piping (i) piping Similar (10) Electrical cable (j) electrical cable (jacketed)

NQA-1 adds jacketed.

(11) Structural items (k) structural items Similar (12) Reinforcing steel (I) reinforcing steel.

Similar (13) Aggregates (m) aggregates Similar 3. PACKAGING 3 PACKAGING

3.1 General

3.1 General This section contains the requirements for packaging of items for protection against corrosion, contamination, physical damage

or any effect which would lower the quality or cause the item to

deteriorate during the time it is shipped, handled and stored. The

degree of protection specified will vary according to storage

conditions and duration, shipping environment, and handling

conditions.

This Section contains the requirements for packaging of items for protection against corrosion, contamination, physical

damage, or any effect that would lower the quality or cause the

items to deteriorate during the time they are shipped, handled, and stored. The degree of protection specified will vary

according to conditions and duration of storage, shipping

environment, and handling conditions.

Similar statements.

Implementation of this packaging section is accomplished by identifying the item and the appropriate packaging level, and

then applying the appropriate criteria contained herein

concerning cleaning, preservatives, desiccants, inert gas

blankets, cushioning, caps and plugs, barrier and wrapping

materials, tapes, blocking and bracing, containers, marking, other quality assurance provisions and documentation.

Implementation of this Section is accomplished by identifying the item and the appropriate packaging level, and then applying

the appropriate criteria contained herein concerning cleaning, preservatives, desiccants, inert gas blankets, cushioning, caps

and plugs, barrier and wrapping materials, tapes, blocking and

bracing, containers, marking, other quality assurance provisions, and documentation.

Similar statements.

Appendix A-3 contains additional requirements generally not available in other documents. These requirements are a mandatory part of this standard.

Appendix A3* Packaging The following are additional minimum requirements to be used with the rules of Section 3, of N45.2.2: "Packaging, Shipping, Receiving, Storage and Handling of Items for

Nuclear Power Plants".

NOTE: *The paragraph numbers contained herein are not sequential but correspond to the respective paragraph of section 3

of this standard where they are referenced.

Note: NQA-1 places the equivalent information from N45.2.2, Appendix within the text section and doesn't use an Appendix.

To provide consistent comparison, Appendix A-3 information in the N45.2.2 column is placed in order of the paragraphs similar to the layout of NQA-1. Those sections in

the N45.2.2 column starting with an A are the Appendix

paragraphs.

Wording from N45.2.2 regarding additional

requirements found in

Appendix.3.2 Levels of Packaging

3.2 Levels

of Packaging The packaging requirements are based on the protection the items should receive during shipping, handling, and storage. The The packaging requirements shall be based on the protection that is necessary during shipping, handling, and storage of the Similar 5/25/04 Page 12 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments requirements of this standard are intended to be in addition to industry classification or tariff rules for rail, truck, air and water

shipments and regulatory agency rules already established in the

transportation industry and in no way are they intended to

reduce the minimum standards established by these regulatory

agency rules.

item to satisfy Levels A, B, C, and D protection requirements set forth below. The requirements herein are intended to be in

addition to industry classifications or tariff rules for rail, truck, air, and water shipments and regulatory agency rules already

established in the transportation industry; and in no way are

they intended to reduce the minimum standards established by

these regulatory agency rules.

The following packaging criteria are divided into four levels corresponding to the categories of Subsection 2.7 of this

Standard.The following packaging criteria are divided into four levels corresponding to the classification categories of para. 2.2 of Subpart 2.2 Similar 3.2.1 Level A Items. (See Paragraph 2.7.1). Level A items require the highest degree of protection and shall conform to the

following criteria:

3.2.1 Level

A Items. (See para. 2.2.1.) Level A items require the highest degree of protection and shall conform to the following criteria Similar (1) Package design requirements are for extraordinary environmental protection to avoid the deleterious effects of

shock and vibration, to control temperature or humidity within

specified limits, or for any other special requirements.(a) Package design requirements shall be for extraordinary environmental protection to avoid the deleterious effects of

shock and vibration, to control temperature or humidity within

specified limits, or for any other special requirements.

Similar (2) Items shall have been inspected for cleanness immediately before packaging. Dirt, oil residue, metal chips or other form of

contamination shall have been removed by approved cleaning

methods. Any entrapped water shall have been removed.(b) Items shall have been inspected for cleanness immediately before packaging. Dirt, oil residue, metal chips, or other forms

of contamination shall have been removed by approved cleaning

methods. Any entrapped water shall have been removed.

Similar (3) Items which are not immediately packaged shall be protected from contamination.(c) Items which are not immediately packaged shall be protected from contamination Similar (4) All Items shall be packaged with a barrier (See Subsection 3.6 of this Standard) so that water vapor, salt air, dust, dirt and

other forms of contamination do not penetrate the package.(d) Items requiring protection from water vapor, salt air, dust, dirt, and other forms of contamination penetrating the package

shall be packaged with a barrier (see para. 3.6).

Similar (5) Items shall be packaged in containers of crates (See Subsection 3.7 of this Standard).(e) Items which require protection from damage during shipping and handling shall be packaged in containers or crates (see

para. 3.7).

Similar (6) Items which can be damaged by condensation trapped within the package shall be packaged with approved desiccant (See Paragraph 3.6.3) inside the sealed water-vapor-proof

barrier or by an equivalent method (for example, see paragraph

3.6.2).(f) Items which can be damaged by condensation trapped within the package shall be packaged with approved desiccant (see para. 3.6.3) inside the sealed water- and vapor-proof barrier or by an equivalent method (for example, see para.3.6.2).Similar (7) All openings into items shall be capped, plugged or scaled (g) All openings into items shall be capped, plugged, or sealed Similar 5/25/04 Page 13 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments (See Subsection 3.5 of this Standard). Weld end preparations shall be protected against corrosion and physical damage.(see para. 3.5). Weld end preparations shall be protected against corrosion and physical damage (8) Items packed in containers shall be blocked, anchored, braced and/or cushioned (See Subsection 3.8 of this Standard)

to prevent physical damage to the item or barrier.(h) Items packed in containers shall be blocked, anchored, braced, or cushioned (see para. 3.8) to prevent physical damage to the item or barrier.

Similar (9) Items and their containers shall be identified by marking (See Subsection 3.9 of this Standard).(i) Items and their container shall be identified by marking (see para. 3.9).

Similar Clarification from the current VA QATR:

(4) With regard to Section 3.2.1 of ANSI N45.2.2-1972, titled Level A Items

As an alternate to the requirements for packaging and containerizing items in storage to control contaminants (Items (4) and (5)), the Company may choose a

storage atmosphere which is free of harmful contaminants in

concentrations that could produce damage to stored items as

determined by station management. Similarly (for Item (7)) the

Company may obviate the need for caps and plugs, as

determined by station management, with an appropriate storage

atmosphere, and may choose to protect weld-end preparations

and threads by controlling the manner in which the items are

stored. These clarifications apply whenever items (4), (5) or (7) are subsequently referenced and to Section 3.5.1, titled Caps and Plugs, and Section 3.4, titled Methods of Preservation.

Similar A similar alternative proposed

as part of the new QAPD.

3.2.2 Level

B Items. (See Paragraph 2.7.2) Level B items require a high degree of protection and the package shall be

designed to avoid the deleterious effects of shock, vibration, physical damage, water vapor, salt spray, condensation and

weather during shipping, handling and storage.

3.2.2 Level

B Items. (See para. 2.2.2.) Level B items require a high degree of protection, and the package shall be designed to avoid the deleterious effects of shock, vibration, physical

damage, water vapor, salt spray, condensation, and weather

during shipping, handling, and storage.

Similar This packaging shall be equivalent to that for Level A except that the extremes of paragraph 3.2.1 (1) need not apply.

This packaging shall be equivalent to that for Level A, except that the package design requirements need not be equivalent to

satisfy the level of extraordinary environmental protection

indicated in para. 3.2.l(a) where such protection is not justified.

Similar Level B items such as control panels or similar special items may be shipped with a minimum of protection when transported

in a fully enclosed furniture type van with special suspension, provided the shipment goes through to destination in the original Shipment of Level B items in fully enclosed vehicles or equivalent protective enclosure or packaging is acceptable, provided the above-stated high degree of protection for Level B

items is maintained throughout shipment, and the shipment goes Similar 5/25/04 Page 14 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments vehicle and Level B storage facilities are available at the site.

through to destination in the original vehicle and Level B storage facilities are available on site. If transfer becomes necessary to

transit, transfer procedures shall be subject to purchaser

acceptance.

3.2.3 Level

C Items. (See Paragraph 2.7.3) Level C items require protection from exposure to salt spray, rain, dust, dirt, and other airborne and windblown contaminants. Protection

from water vapor and condensation is less important than for

Level B items.

3.2.3 Level

C Items. (See para. 2.2.3.) Level C items require protection from exposure to salt spray, rain, dust, dirt, and other contaminants. Protection from water vapor and condensation is

less important than for Level B items.

Similar The following criteria shall apply:

The following criteria shall apply.

Similar (1) Criteria (2) (3) (5) (7) (8) and (9) for Level A items (See Paragraph 3.2.1) shall apply to Level C items.(a) Criteria (b), (c), (e), (g), (h), and (i) for Level A items (see para. 3.2.1) shall apply to Level C items.

Similar (2) Items shall be packaged with a waterproof enclosure so that water, salt spray, dust, dirt, and other forms of contamination do

not penetrate to the item.

Clarification from the current VA QATR: (5) With regard to Section 3.2.3 of ANSI N45.2.2 1972, titled Level C Items

(Subpart 2) states "Items shall be packaged with a waterproof enclosure-," as an alternative, the company may choose

appropriate packaging when the storage environment prevents

harmful contaminants in concentrations that could produce

damage to stored items as determined by Station mgmt.(b) Items shall be packaged with a waterproof enclosure so that water, salt spray, dust, dirt, and other forms of contamination do

not penetrate to the item..

Similar A similar alternative proposed

as part of the new QAPD.

(3) Items subject to detrimental corrosion, either internal or external, shall be suitably protected.(c) Items subject to detrimental corrosion, either internal or external, shall be suitably protected Similar 3.2.4 Level D Items. (See paragraph 2.7.4) Level D items require protection from physical and mechanical damage.

3.2.4 Level

D Items. (See para. 2.2.4.) Level D items require protection from physical and mechanical damage.

Similar The following criteria shall apply:

The following criteria shall apply Similar (1) Items, just before packaging, shall have been inspected for cleanness according to the requirements specified in the

purchasing document. Dirt, oil residue, metal chips or other

forms of contamination shall have been removed by approved

cleaning methods. Any entrapped water shall have been

removed.(a) Items, just before packaging, shall have been inspected for cleanness according to the requirements specified in the

purchasing document. Dirt, oil residue, metal chips, or other

forms of contamination shall have been removed by approved

cleaning methods. Any entrapped water shall have been

removed.Similar (2) All openings into items shall be capped, plugged and sealed (b) All openings into items shall be capped, plugged, and sealed Similar 5/25/04 Page 15 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments (See Subsection 3.5 of this Standard). Weld end preparations shall be protected from corrosion and physical damage.(see para. 3.5). Weld end preparations shall be protected from corrosion and physical damage.

(3) Items subject to detrimental corrosion, either internal or external, shall be suitably protected.(c) items subject to detrimental contamination or corrosion, either internal or external, shall be suitably protected.

Similar (4) Items packed in containers shall be blocked, braced and/or cushioned to prevent physical damage (See Subsection 3.8 of

this Standard).(d) items packed in containers shall be blocked, braced, or cushioned to prevent damage (see para. 3.8).

Similar (5) Items such as aggregate and reinforcing steel shall be suitably protected against detrimental contamination or

corrosion.

Addressed in NQA-1, Part II, Subpart 2.5.

(6) The identity of the item shall be maintained by marking (See Subsection 3.9 of this Standard) or other appropriate means.(e) The identity of the item shall be maintained by marking (see para. 3.9) or other appropriate means.

Similar 3.3 Cleaning

3.3 Cleaning

Cleaning includes the preparation of items for preservation or packaging, or both, to minimize the requirements for site

cleaning. Items shall be inspected for cleanness immediately

before packaging according to the cleaning requirements

specified in the purchase document. Any dirt, oil residue, metal

chips or other forms of contamination shall be removed by

documented cleaning methods. Any entrapped water shall be

removed. Any item which is not immediately packaged shall be

protected from further contamination. (See Appendix section A3.3 for additional requirements.)

Clarification from the current VA QATR:

(6) With regard to Section 3.3 of ANSI N45.2.2-1972, titled Cleaning: (Third sentence) the Company interprets "documented cleaning methods" to allow generic cleaning procedures to be written which are implemented, as necessary, by trained personnel. Each particular cleaning operation shall

have an individual cleaning procedure or reference a generic

procedure. The generic procedures will specify methods of

cleaning or which type(s) of solvent may be used in a particular

application.

Cleaning includes the preparation of items for preservation or packaging, or both, to minimize the requirements for site

cleaning. items shall be inspected for cleanness immediately

before packaging according to the cleaning requirements

specified in the procurement documents. Any dirt, oil residue, metal chips, or other forms of contamination shall be removed

by documented cleaning methods. Any entrapped water shall be

removed.Similar Alternative not required under

the new program.

A3.3 Cleaning Specific cleaning procedures are considered to be part of the The following general criteria shall apply as part of the Similar 5/25/04 Page 16 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments manufacturing specifications. The following general criteria shall apply:

manufacturing specifications specific cleaning procedures (1) The cleaning process including cleaning compounds chosen shall in no way damage the item during cleaning or subsequent

service when considering the composition, surface finish, complexity or other inherent features or other interface

equipment after installation.(a) The cleaning process, including cleaning compounds chosen, shall in no way damage the item during cleaning or subsequent

service when considering the composition, surface finish, complexity, or other inherent features, or other interface

equipment after installation.

Similar (2) The cleaning process or processes chosen shall remove loose mill and heat scale, oil, rust, grease, paint, welding fluxes, chalk, abrasives, carbon deposits, coatings used for

nondestructive testing process and other contaminants which

would render ineffective the method of preservation and

packaging, or other specified requirements.(b) The cleaning process or processes chosen shall remove loose mill and heat scale, oil, rust, grease, paint, welding fluxes, chalk, abrasives, carbon deposits, coatings used for

nondestructive testing processes, and other contaminants that

would render ineffective the method or preservation and

packaging or other specified requirements.

Similar (3) Item surfaces after cleaning shall be free of cleaning media, such as aluminum oxide, silica, grit, lint, chemical cleaning

residue, petroleum solvent residue, etc.(c) item surfaces after cleaning shall be free of cleaning media, such as aluminum oxide, silica, grit, lint, chemical cleaning

residue, and petroleum solvent residue, etc.

Similar (4) After cleaning, the item shall be protected from contamination until preservation or packaging is complete.(d) After cleaning, the item shall be protected from contamination until preservation or packaging is complete.

Similar 3.4 Methods of Preservation

3.4 Methods

of Preservation Items subject to deleterious corrosion shall be protected by using either contact preservatives, inert gas blankets, or vapor-

proof barriers with desiccants (See Subsection 3.6 of this

Standard for vapor-proof barriers and desiccants.)

Clarification from the current VA QATR: (7) With regard to Section 3.4 of ANSI N45.2.2-1972, titled Methods of Preservation

(First sentence) the Company will comply with these requirements subject to the clarifications of Section 3.2.1, (4) and (5) above, and the definition of the phrase

"deleterious corrosion" to mean that corrosion which cannot be

subsequently removed and which adversely affects form, fit or

function.Items subject to deleterious corrosion shall be protected by using either contact preservatives, inert gas blankets, or vapor-

proof barriers with desiccants. (See para. 3.6 for vapor-proof barriers and desiccants.)

Similar To clarify, definition of

"deleterious corrosion" is

included in Appendix D of the

new QA program.

3.4.1 Contact

Preservatives.

3.4.1 Contact

Preservatives.

Contact preservatives are compounds applied to bare metal surfaces to prevent surface corrosion during shipping and

storage and generally require removal prior to installation. (See Contact preservatives are compounds applied to bare metal surfaces to prevent surface corrosion during shipping and

storage and generally require removal prior to installation.

Similar 5/25/04 Page 17 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments Appendix Section A3.4.1 for additional requirements.)

A3.4.1 Contact Preservatives.

The following criteria shall be used when considering the type of contact preservative to be used.

The following criteria shall be used when considering the type of contact preservative to be used.

Similar (1) The contact preservative shall be compatible with the material on which it is applied.(a) The contact preservative shall be compatible with the material on which it is applied.

Similar (2) Contact preservatives which are nondrying shall require a neutral-grease-proof protective wrap when packaged.(b) Contact preservatives which are nondrying shall require a neutral grease-proof protective wrap when packaged, Similar (3) The procedure for applying contact preservatives shall not require disassembly of the item nor shall it be necessary to

disassemble the item at the site for complete removal. An

exception would be for long time storage protection to be

agreed upon by the owner, buyer and manufacturer.(c) The procedure for applying contact preservatives shall not require disassembly of the item nor shall it be necessary to

disassemble the item at the site for complete removal. An

exception would be for long-term storage protection to be

agreed upon by the owner, buyer, and manufacturer.

Similar (4) The method of contact preservative removal shall be accomplished with approved solvents and wiping cloths or by

flushing internal cavities with solvents which are not deleterious

to the item or other interconnecting material. However, preservatives for inaccessible inside surfaces of pumps, valves

and pipe for systems containing reactor coolant water shall be

the water flushable type.(d) The method of contact preservative removal shall be accomplished with approved solvents and wiping cloths or by

flushing internal cavities with solvents which are not deleterious

to the item or other interconnecting material. However, preservatives for inaccessible inside surfaces of pumps, valves, and piping for systems containing reactor coolant water shall be

the water flushable type.

Similar (5) The name of the preservative used shall be indicated to facilitate touchup.(e) The name of the preservative used shall be provided to facilitate touch-up..

Similar (6) When motors, pumps, turbines, etc., are shipped with oil reservoirs and bearings cavities filled with preservative oil the

item shall be so tagged and instructions for draining, flushing, refilling and periodic rotation shall be included with the item.(f) When motors, pumps, turbines, etc., are shipped with oil reservoirs and bearing cavities filled with preservative oil, the

item shall be so tagged and instructions for draining, flushing, refilling, and periodic rotation shall be included with the item.

Similar (7) When it is anticipated that the item might require an extended storage period, six (6) months or longer, a

preservative needed for the long term protection of the item

shall be applied or arrangements shall be made to periodically

reapply the preservatives.(g) When it is anticipated that the item might require an extended storage period (6 months or longer), a preservative needed for the long-term protection of the item shall be applied or arrangements shall be made to periodically reapply the

preservatives.

Similar 3.4.2 Inert Gas Blankets.

3.4.2 Inert

Gas Blankets.

Purging and pressurizing the interior of an item or its container or both with a dry inert gas provides a means of preventing

moisture or corrosive atmospheres from acting on sensitive bare Purging and pressurizing the interior of an item or its container, or both, with a dry inert gas provides a means of preventing

moisture or corrosive atmospheres from acting on sensitive, Similar 5/25/04 Page 18 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments metal surfaces or other materials. The item or its container shall be either evacuated prior to filling with the inert gas or

adequately purged with the same gas prior to applying the gas

blanket. (See Appendix section A3.4.2 for additional requirements.)

bare metal surfaces or other materials. The item or its container shall be either evacuated prior to filling with the inert gas or

adequately purged with the same gas prior to applying the gas

blanket.A3.4.2 Inert Gas Blankets

.When inert gas blankets are used, the following criteria shall apply: When inert gas blankets are used, the following criteria shall apply.Similar (1) Inert gas blankets shall be used only when the exterior shell of the item or its container can be tightly sealed to form a

leakproof barrier.(a) Inert gas blankets shall be used only when the exterior shell of the item or its container can be tightly sealed or an inert gas

blanket can otherwise be maintained, Similar (2) Only a commercial grade of dry, oil-free, inert gas shall be used.(b) Only dry, oil free, inert gas shall be used.

Similar (3) Provisions shall be made for measuring and maintaining the blanket pressure within the required range within each

pressurized purged item or container. Closures and seals shall

be tightly secured so that the absolute (by mass) pressure after

final seal is maintained for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> without adding gas, prior to

shipping the item from the manufacturer's plant.(c) Provisions shall be made for measuring and maintaining the blanket pressure within the required range and within each

pressurized purged item or container. Closures and seals, when

used to maintain a static pressure, shall be tightly secured so

that the absolute pressure (by mass) after final seal is

maintained for 24 hr, without adding gas, prior to shipping the

item from the manufacturer's plant.

Similar (4) The item or container shall be marked in bold letters cautioning that an inert gas blanket has been used. The required

pressure range also shall be marked on the item or container.(d) The item or container shall be marked in bold letters cautioning that an inert gas blanket has been used. The required

pressure range also shall be marked on the item or container.

Similar 3.5 Caps, Plugs, Tapes, and Adhesives 3.5 Caps, Plugs, Tapes, and Adhesives These items shall be of materials which enable them to perform their intended function adequately without causing deleterious

effects on items or systems operation.

These items shall be of materials that enable them to perform their intended function adequately, without causing deleterious

effects on the items or system operation.

Similar 3.5.1 Caps and Plugs.

3.5.1 Caps and Plugs.

Caps and Plugs shall be used to seal openings in items having sensitive internal surfaces, and to protect threads and weld end

preparations. (See Appendix section A3.5.1 for additional requirements.)

Caps and plugs shall be used to seal openings in items having sensitive internal surfaces and to protect threads and weld end

preparations.

Similar A3.5.1 Caps and Plugs.

Caps and plugs shall conform to the following criteria:

Caps and plugs shall conform to the following criteria.

Similar 5/25/04 Page 19 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments (1) Nonmetallic plugs and caps shall be brightly colored. Clear plastic closures are not to be used except when specified for a

special purpose; for example, as a window for humidity

indicator cards. Special attention shall be given in the control of

these closures.(a) Nonmetallic plugs and caps shall be brightly or contrastingly colored. Clear plastic closures are not to be used except when specified for a special purpose: for example, as a window for

humidity indicator cards. Special attention shall be given in the

control of these closures.

Similar (2) Metallic plugs and caps contacting metal surfaces shall not cause galvanic corrosion at the contact areas.

Gasketing or other nonmetallic materials used in conjunction with metallic caps or plugs shall exhibit no corrosive effect on the material.(b) Metallic plugs and caps contacting metal surfaces shall not cause galvanic corrosion at the contact areas.

Gasketing or other nonmetallic materials used in conjunction with metallic caps or plugs shall exhibit no corrosive effect on the material.

Similar (3) Simplicity of installation, inspection, and removal without damage to the item shall be considered.(c) Simplicity of installation, inspection, and removal without damage to the item shall be considered.

Similar (4) Provisions shall be made to preclude the plug or cap from falling into or being pushed into the opening after its installation.(d) Provisions shall be made to preclude the plug or cap from falling into or being pushed into the opening after its installation.

Similar (5) Plugs or caps shall be secured with tape (See Paragraph A3.5.2 of this Appendix) or other means as necessary to

prevent accidental removal.(e) Plugs or caps shall be secured with tape (see para. 3.5.2) or other means as necessary to prevent accidental removal.

Similar (6) All plugs and caps shall be clean and free of visible contamination such as, but not limited to dust, dirt, stains, rust, discoloration or scale.(f) All plugs and caps shall be clean and free of visible contamination such as, but not limited to, dust, dirt, stains, rust, discoloration, or scale.

Similar (7) Plugs and caps used in contact with austenitic stainless steel shall be made from non-halogenated materials or stainless steel.(g) Plugs and caps used in contact with austenitic stainless steel shall be made from non-halogenated materials or stainless steel Similar 3.5.2 Tapes and Adhesives.

3.5.2 Tapes

and Adhesives.

Pressure sensitive, removable, tape should be used in lieu of adhesives in contact with bare metal surfaces. Tapes or

adhesives which could have damaging effects on the item or

system shall not be used. Tapes near a weld shall be removed

completely immediately prior to performing a weld or closure.

Tapes used for identification rather than sealing which are not

near a welding operation may remain until system testing. (See Appendix section A3.5.2 for additional requirements.)

Pressure-sensitive, removable tape shall be used in lieu of adhesives in contact with bare metal surfaces. Tapes or

adhesives that could have damaging effects on the item or

system shall not be used. Tapes near a weld shall be removed

completely, immediately prior to performing a weld. Tapes used

for identification rather than sealing that are not near a welding

operation may remain until system testing is complete, but shall

be removed before plant operations unless qualified for

operating conditions.

Similar, use changed from should to shall in NQA-1.

A3.5.2 Tapes and Adhesives

.Tapes and adhesives shall conform to the following criteria:

Tapes and adhesives shall conform to the following criteria.

Similar (1) When contacting austenitic stainless steel and nickel alloy (a) When contacting austenitic stainless steel and nickel alloy Similar 5/25/04 Page 20 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments surfaces: surfaces: (a) The halogen and sulfur contents of tapes should not be in excess of 0.10% by weight each. Paperbacked (masking) tape shall not be used.

NRC Regulatory Guide 1.38, Regulatory Position C.2.c:

Subdivision A.3.5.2(1)(a)-This guideline states that the halogen and sulfur content of tapes should not be in excess of 0.10% by

weight when used in contact with austenitic stainless steel and

nickel alloy surfaces. In lieu of this guidelines, tapes, when used

with austenitic stainless steel or nickel alloy materials, should

not be compounded from or treated with chemical compounds

containing elements in such quantities that harmful

concentrations could be leached or be released by breakdown

of the compound under expected environmental conditions (e.g.,

by radiation). Examples of such compounds are those

containing fluorides, chlorides, sulfur, lead, zinc, copper, and

mercury.(1) tapes shall not be compounded from or treated with chemical compounds containing elements in such quantities that harmful concentrations are leachable, or that they could be released by breakdown under expected environmental conditions and could contribute to intergranular cracking or

stress corrosion cracking, such as those containing fluorides, chlorides, sulfur, lead, zinc, copper, and mercury [paperbacked (masking) tape shall not be used];

Additional detail regarding tape in NQA-1-1994.

Addresses Regulatory Position

from RG 1.38.(b) Upon removal of tape, all residual adhesive shall be removed by a non-halogenated solvent (acetone, alcohol or

equal) wiping.

(2) upon removal of tape, all residual adhesive shall be removed by wiping with a non-halogenated solvent (acetone, alcohol, or

equal);Similar (c) Starch, silicone and epoxy type material may be used for tape adhesives.

(3) starch, silicone, and epoxy tape material may be used for tape adhesive.

Similar (2) When contacting other surfaces and containers: (b) When contacting other surfaces and containers:

Similar (a) Tapes and adhesives used to seal non-austenitic materials or containers are not subject to the above restrictions.

(1) tapes and adhesives used to seal non-austenitic materials or containers are not subject to the above restrictions; Similar (b) Tape shall be impervious to water and not subject to cracking or drying out if exposed to sunlight, heat or cold.

(2) tape shall be impervious to water and not subject to cracking or drying out if exposed to sunlight, heat, or cold.

Similar (3) Tapes should be brightly colored to preclude their loss into a system.NRC Regulatory Guide 1.38, Regulatory Position C.2.d:

Subdivision A.3.5.2(3)-This guideline states that tapes should be brightly colored to preclude their loss into a system. In lieu of

this guidelines, tapes should be colored to contrast with the

materials on which they are used.(c) When used on surfaces of items, tapes shall be visibly distinguishable from the materials on which they are used.

Similar NQA-1 addresses NRC

position in RG 1.38.

5/25/04 Page 21 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments 3.6 Barrier and Wrap Materials and Desiccants

3.6 Barrier

and Wrap Materials and Desiccants A barrier generally is a flexible material designed to withstand the penetration of water, water vapor, grease, or harmful gases.

A wrap is a flexible material, formed around the item or

package to exclude dirt and to facilitate handling, marking or

labeling. Material thickness shall be selected on the basis of

type, size and weight of equipment or item to be protected, such

that the barrier or wrap will not easily be damaged by puncture, abrasion, weathering, cracking, temperature extremes, wind

conditions, and the like.

Material thickness shall be selected on the basis of type, size, and weight of equipment or item to be protected, such that the

barrier or wrap will not easily be damaged by puncture, abrasion, weathering, cracking, temperature extremes, wind

conditions, and the like.

Similar Barrier and wrap materials shall be non-halogenated when used in direct contact with austenitic stainless steel, shall be

noncorrosive, shall not readily support combustion and shall not

be otherwise harmful to the item packaged. Vapor-proof barrier

material, used with desiccants constitutes another preservation

system (See Subsection 3.4 of this Standard); it protects against

potential damage by water vapor condensate.

Clarification from the current VA QATR:

(8) With regard to Section 3.6 of ANSI N45.2.2-1972, titled Barrier and Wrap Material and Desiccants

This section requires the use of non-halogenated materials in contact with austenitic stainless steel. Refer to Regulatory Guide 1.37 above for the Company position. (Company position from RG 1.37, (3) With regard to Paragraph C.4 of Regulatory Guide

1.37: Expendable materials such as inks and related products, temperature indicating stick, tapes, gummed labels, wrapping

materials (other than polyethylene), water soluble dam

materials, lubricants, NDE penetrant materials, and couplants, desiccants, and like materials which contact stainless steel or nickel alloy surfaces; shall not contain lead, zinc, copper, mercury, cadmium and other low melting point metals, their

alloys or compounds as basic and essential chemical

constituents. No more than 0.1 percent (1000 ppm) halogens will be allowed where such elements are leachable or where they could be released by breakdown of the compounds under Barrier and wrap materials shall be non-corrosive and shall not be otherwise harmful to the item packaged. When barrier and

wrap materials are used in direct contact with austenitic

stainless steels, the total and water leachable content of halogen shall not be harmful to the item packaged. Also , barrier and wrap materials shall not readily support combustion. Vapor-proof barrier materials used with desiccants constitute another

preservation system that protects against potential damage by

water vapor condensate.

Similar requirement.

Alternative not needed under

the new QA program.

5/25/04 Page 22 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments expected environmental conditions.

3.6.1 Water-proof Barrier Material.

3.6.1 Waterproof

Barrier Material.

Water-proof barrier material shall be resistant to grease and water; it shall protect items from airborne and windblown soils.

Waterproof barrier material shall be resistant to grease and water; it shall protect items from airborne and windblown soils.

.Similar 3.6.2 Vapor Barrier Material.

3.6.2 Vapor-proof Barrier Material.

Vapor-proof barrier materials shall be sealable and the edge of the barrier which normally will be opened at destination shall be of sufficient area to permit at least two subsequent sealing operations. (See Appendix A3.6.2 for additional requirements).

Vapor-proof barrier materials shall be sealable, and the edge of the barrier that normally will be opened at destination shall be of sufficient area to permit at least two subsequent sealing

operations.

Similar A3.6.2 Vapor Barrier Material.

When maximum vapor protection is required, barrier material shall meet the maximum water vapor transmission rate of 0.05

grams per 100 square inches per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per ASTM E96

Tests for Water Vapor Transmission Of Materials In Sheet

Form, Procedure E and shall be packaged with an approved

desiccant. The barrier material should be brightly colored to

preclude loss within a system.

NRC Regulatory Guide 1.38, Regulatory Position C.2.e:

e. Section A.3.6.2-This guidelines states that the vapor barrier material should be brightly colored to preclude loss within a

system. In lieu of this guidelines, vapor barrier material should

be colored to contrast with the materials on which they are

used.When maximum vapor protection is required, barrier material shall meet the maximum water vapor transmission rate of 0.05

g/100 sq in. per 24 hr required by ASTM E 96, Test Methods for Water Vapor Transmission of Materials, Procedure E, and shall be packaged with an approved desiccant. Vapor-proof barrier material should be colored to contrast with the material

on which it is used.

Similar NQA-1 addresses the NRC

position from RG 1.38.

3.6.3 Desiccants.

3.6.3 Desiccants.

Desiccants may be used within a vapor-proof barrier when condensation or high humidity could damage an item by corrosion, mold, or mildew. (See Appendix A3.6.3 for additional requirements).

Desiccants shall be used within a vapor-proof barrier when condensation or high humidity could damage an item by

corrosion, mold, or mildew.

Change from may to shall in NQA-1.A3.6.3 Desiccants.

Desiccants shall consist of nondeliquescent, nondusting, chemically inert, dehydrating agents. The following criteria apply when they are used.

Desiccants shall consist of nondeliquescent, non-dusting, chemically inert, dehydrating agents. The following criteria shall apply.Similar 5/25/04 Page 23 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments (1) When used with austenitic stainless steel, the desiccant and the bag material shall not have a halogen content over 0.25%.

The desiccant bag shall be made of puncture, tear and burst

resistant material.

NRC Regulatory Guide 1.38, Regulatory Position C.1.c:

Subdivision A.3.6.3(1) of ANSI N45.2.2-1972 permits desiccants and desiccant bag materials containing not more than

0.25% halogens to be used with austenitic stainless steels. In

lieu of this requirement, desiccants and the materials for the

desiccant bags, when used with austenitic stainless steel or

nickel alloy materials, should not be compounded from or

treated with chemical compounds containing elements in such

quantities that harmful concentrations could be leached or be

released by breakdown of the compounds under expected

environmental conditions (e.g., by radiation). Examples of such

compounds are those containing fluorides, chlorides, sulfur, lead, zinc, copper, and mercury.(a) The desiccant bag shall be made of puncture-, tear-, and burst-resistant material (b) When used with austenitic stainless steel and nickel alloy

materials, tapes, desiccants, and the materials for the desiccant

bag shall not be compounded from or treated with chemical

compounds containing elements in such quantities that harmful

concentrations are leachable, or they could be released by breakdown under expected environmental conditions and could contribute to intergranular cracking or stress corrosion cracking, such as those containing fluorides, chlorides, sulfur, lead, zinc, copper, and mercury.

NQA-1 splits the statements from A3.6.3.(1) into two

parts. It also addresses the

NRC position from RG 1.38.

(2) The reactivation temperature and time shall be marked on the desiccant container.(c) The reactivation temperature and time shall be marked on the desiccant container..

Similar (3) Canisters used to contain desiccants shall be placed so as to cause no deleterious effects such as galvanic corrosion, even

when the desiccant has reached its absorptive capacity for

water vapor.(d) Canisters used to contain desiccants shall be placed so as to cause no deleterious effects such as galvanic corrosion, even

when the desiccant has reached its absorptive capacity for

water vapor.

Similar (4) Desiccant bags and canisters, when used, shall be secured to prevent movement, rupture of the bags, or damage to the

item being protected.(e) Desiccant bags and canisters, when used, shall be secured to prevent movement, rupture of the bags, or damage to the

item being protected.

Similar (5) Water-vaporproof flexible barriers shall be used to seal items containing desiccants. The included air volume within the flexible barrier shall be kept to a minimum.(f) Water- and vapor-proof flexible barriers shall be used to seal items containing desiccants. The included air volume within the flexible barrier shall be kept to a minimum.

Similar (6) Items which contain desiccants shall have all openings securely scaled. When flange connections are a part of the

barriers, O-rings or gaskets shall be used with all bolts in place

and tightened sufficiently to insure a water-vapor-proof seal.

Weld end preparations, after capping, shall be covered with a

water-vapor proof seal.(g) Items that contain desiccants shall have all openings securely sealed. When flange connections are a part of the

barriers, O-rings or gaskets shall be used with all bolts in place and tightened sufficiently to ensure a water- and vapor-proof seal. Weld end preparations, after capping, shall be covered

with a water- and vapor-proof seal Similar 5/25/04 Page 24 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments (7) Packages and items containing desiccant shall be marked.

The total number of separate bags and/or containers in the

package shall be indicated.(h) Packages and items containing desiccants shall be marked.

The total number of separate bags or containers of desiccants

in the package shall be indicated.

Similar (8) The minimum quantity of desiccant for use in each package shall be determined in accordance with Formula I or Formula II, as applicable.(i) The minimum quantity of desiccant for use in each package shall be determined in accordance with Formula I or Formula II, as applicable.

Similar Formula I: To determine minimum of desiccant for use with other than sealed rigid metal barrier:

U= 1.6A plus XD.

Formula I To determine minimum units of desiccant for use with other than sealed rigid metal barrier:

U = 1.6A + XD Similar Formula II: To determine minimum units of desiccant for use within sealed rigid metal barrier:

U= KV plus XD.

Formula II To determine minimum units of desiccant for use with sealed rigid metal barrier:

U = KV + XD Similar In the above formulas:

A= Areas of barrier in square feet

U= Number of units* of desiccant to be used

D= Pounds of dunnage (other than metal) within barrier K= 0.0007 when volume is given in cubic inches K= 1.2 when volume is given in cubic feet

V= Volume within barrier in cubic inches or cubic feet

X= 8 for hair felt, cellulosic material (including wood) and other material not categorized below X= 6 for bound fibers (animal hair, synthetic fiber or vegetable

fiber bound with rubber)

X= 2 for glass fiber

X= 0.5 for synthetic foams and rubber

• A desiccant unit is that quantity of desiccant, as received, which will absorb at equilibrium with air at 25 C at least the

following quantities of water vapor: 3.00 grams at 20% relative

humidity and 6.00 grams at 40% relative humidity.

Where A = area of barrier, sq ft (m2 x 0.0929)

U = number of units of desiccant to be used (see Note)

D = dunnage (other than metal) within barrier, lb. (kg x 2.2)

K = 0.0007 when volume is given in cu in.

K = 1.2 when volume is given in cu ft

K = 0.0000425 when volume is given in cm 3 (42.5 in m3)

V = volume within barrier in CU in. or CU ft (cm 3 or m 3)X = 8 for hair felt, cellulosic material (including wood), and other material not categorized below X = 6 for bound fibers (animal hair, synthetic fiber, or vegetable

fiber bound with rubber)

X = 2 for glass fiber

X = 0.5 for synthetic foams and rubber

NOTE: A desiccant unit is that quantity of desiccant, as received, that will absorb at equilibrium with air at 78° F (25°C)at least the following quantities of water vapor: 3.00 g at 20%

relative humidity and 6.00 g at 40% relative humidity.

Similar, NQA-1 adds K factors for volumes in cubic

centimeters and cubic meters.

(9) A humidity indicator shall be included in every water-vapor-proof envelope containing desiccant. As applicable, the indicator

shall be located behind inspection windows or immediately

within the closing edge, face, or cover of the barrier, and as far

as practical from the nearest unit of desiccant.(j) A humidity indicator shall be included in every water- and vapor-proof envelope containing desiccant. As applicable, the

indicator shall be located behind inspection windows or

immediately within the closing edge, face, or cover of the

barrier and, as far as practical, from the nearest unit of Similar 5/25/04 Page 25 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments desiccant.

3.7 Container, Crating and Skids 3.7 Containers, Crating, and Skids 3.7.1 Containers.

3.7.1 Containers.

Containers are used when maximum protection for the item or its barrier is required. Domestic types used shall be limited to:

Containers shall be used when maximum protection for the item or its barrier is required. Domestic types used shall be limited to

the following:

Similar (1) Cleated, sheathed boxes (500 lb. maximum net weight).

Clarification from the current VA QATR: (9) With regard to Section 3.7.1 of ANSI N45.2.2-1972, titled Containers

Cleated, sheathed boxes may be used up to 1000 lb rather than 500 lb as specified in 3.7.1(1). This type of box is safe for, and has been tested for, loads up to 1000 lb. Other national standards allow this (see Federal Specification PPP-B-601).

Special qualifications testing shall be required for loads above

1000 lb.(a) cleated, sheathed boxes [500 lb. (227 kg) maximum net weight]Similar Alternative not required under

new QA program.

(2) Nailed wood boxes.(b) nailed wood boxes Similar (3) Wood-cleated solid fiberboard boxes.(c) wood-cleated solid fiberboard boxes Similar (5) Metal or fiber drums.(d) metal or fiber drums Similar (6) Crates (See Paragraph 3.7.2).(e) crates (see para. 3.7.2)

Similar (7) Wire bound boxes (200 lb. maximum net weight).(f) wire bound boxes [200 Lb. (91 kg) maximum net weight]

Similar (8) Other specially designed containers for special equipment.(g) other specially designed containers for special equipment Similar (4) Fiberboard boxes (120 lb. maximum net weight. See Appendix A3.7.1 for additional requirements).(h) fiberboard boxes [120 lb. (54.5 kg) maximum net weight].

NQA-1 changed the order of the list to coincide with the

additional information below

for fiberboard boxes.

Cleated boxes in excess of 50 lb. shall be bound with steel strapping or equivalent around the container at not less than two places. (See Appendix A3.7.1 for additional requirements.)

Addressed in item 5 below for NQA-1.A3.7.1 Fiberboard Boxes.

The following criteria apply for fiberboard boxes used as exterior containers:

The following criteria shall apply for fiberboard boxes used as exterior containers.

Similar (1) Boxes shall be weather-resistant fiberboard preferably from the following grade types (or compliance symbol): V2 s, V3 s, or V3 c. (Federal Specification PPP-B-636.)

(1) Boxes shall be weather-resistant fiberboard preferably from the grade types (or compliance symbol): V2 s, V3 s, or V3 c (Federal Specification PPP-B-636).

Similar 5/25/04 Page 26 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments (2) Box style shall be RSC - Regular slotted box, (Outer flaps meet, inner flaps and outer flaps are of equal length).

(2) Box style shall be RSC regular slotted box (outer flaps meet, inner flaps and outer flaps are of equal length).

Similar (3) Fiberboard boxes shall be securely closed with a water resistant adhesive applied to the entire area of contact between

the flaps. All seams, and joints shall be further sealed with not

less than two inch wide, water resistant tape (3) Fiberboard boxes shall be securely closed with a water-resistant adhesive applied to the entire area of contact between the flaps. All seams and joints shall be further sealed with not

less than 2 in. (5 cm) wide, water-resistant tape.

Similar (4) Boxes shall be strapped with pressure-sensitive reinforced tape, length-wise (top, bottom and ends), girthwide (top, bottom and sides) and horizontal sides and ends.

(4) Boxes shall be strapped with pressure-sensitive reinforced tape, lengthwise (top, bottom, and ends), girthwise (top, bottom, and sides), and horizontal sides and ends.

Similar (5) Wood cleating on fiberboard boxes shall be fabricated from sound, well-seasoned lumber.

(5) Wood cleating on fiberboard boxes shall be fabricated from sound, well-seasoned lumber. Cleated boxes in excess of 50 lb (22.7 kg) shall be bound with steel strapping, or equivalent, around the container at not less than two places.

Similar, 2 nd sentence also compares to N45.2.2 (See section 3.7.1)

3.7.2 Crates

and Skids.

3.7.2 Crates

and Skids.

Crates and skids shall be used for equipment in excess of 500 lb. Skids and runners shall be used on boxes with a gross weight

of 100 lb. or more, allowing a minimum floor clearance for

forklift tines as provided by 4 inch lumber.

Clarification from the current VA QATR:

(10) With regard to Section 3.7.2 of ANSI N45.2.2-1972, titled Crates and Skids

Skids or runners will normally be used on containers with a gross weight of 100 lb or more. Skids or runner will normally be fabricated from 4 x 4 inch nominal lumber size, minimum, and laid flat except where this is

impractical because of the small dimensions of the container. If

forklift handling is required, minimum floor clearance for forklift

tines will be provided.

Crates and skids shall be used for equipment in excess of 500 lb. (227 kg). Skids and runners shall be used on boxes with a

gross weight of 100 lb. (45.5 kg) or more, allowing a minimum

floor clearance for forklift tines as provided by 4 in. (10 cm)

lumber.Similar Clarification not required

under the new QAPD.

3.8 Cushioning, Blocking, Bracing and Anchoring 3.8 Cushioning, Blocking, Bracing, and Anchoring

3.8.1 Cushioning

3.8.1 Cushioning.

Cushioning shall be used where protection from shock and vibration is required; the cushioning materials shall have

sufficient strength to perform this function. (See Appendix A3.8.1 for additional requirements.)

Cushioning shall be used where protection from shock and vibration is required. The cushioning materials shall have

sufficient strength to perform this function.

Similar A3.8.1 Cushioning.

Selection of cushioning materials shall be based on the Selection of cushioning material shall be based on the following.

Similar 5/25/04 Page 27 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments following:

(1) It shall exhibit no corrosive effect when in contact with the item being cushioned.(a) It shall exhibit no corrosive effect when in contact with the item being cushioned.

Similar (2) It shall have low moisture content and exhibit low moisture absorption properties; or if the cushioning material has some

moisture absorbing capacity, the item shall be protected with a

water-vapor-proof barrier.(b) It shall have low moisture content and exhibit low moisture absorption properties, or if the cushioning material has some

moisture absorbing capacity, the item shall be protected with a

water-vapor-proof barrier.

Similar (3) It shall have negligible dusting characteristics.(c) It shall have negligible dusting characteristics.

Similar (4) It shall not readily support combustion.(d) It shall not readily support combustion.

Similar 3.8.2 Blocking and Bracing.

3.8.2 Blocking

and Bracing.

Blocking and bracing used for protection of the load to be supported, shall be compatible with the size, shape, and strength

of bearing areas of the shipment. The blocking and bracing used

to prevent item movement shall withstand thrust and impact

applied in any direction. Blocking and bracing used in direct

contact with the item being blocked shall not have a corrosive

effect on the item.

Blocking and bracing used for protection of the load to be supported shall be compatible with the size, shape, and strength

of bearing areas of the shipment. The blocking and bracing used

to prevent item movement shall withstand thrust and impact

applied in any direction. Blocking and bracing used in direct

contact with the item being blocked shall not have a corrosive

effect on the item.

Similar 3.8.3 Anchoring.

3.8.3 Anchoring.

Anchoring of the item within a crate or on a skid shall adequately fasten the item during shipment and protect the item

from potential damage due to rough handling. To facilitate

disassembly and minimize damage when removing container contents, bolting is preferred. (See Appendix A3.8.3 for additional requirements).

Anchoring of the item within a crate or on a skid shall adequately fasten the item during shipment and protect the item

from potential damage due to rough handling.

Similar A3.8.3 Anchoring.

When bolts are used for anchoring the following criteria shall apply When bolts are used for anchoring, the following criteria shall apply.Similar (1) If precision bolt holes in the item are used for anchoring, precaution shall be taken to insure that properly fitting bolts of

the correct dimension and characteristics are used to prevent

marring or elongation of the holes.(a) If precision bolt holes in the item are used for anchoring, precaution shall be taken to ensure that properly fitting bolts of

the correct dimension and characteristics are used to prevent

marring or elongation of the holes.

Similar (2) Holes bored through containers or mounting bases shall provide a snug fit.(b) Holes bored through containers or mounting bases shall provide a snug fit.

Similar (3) When mounting items to container bases equipped with (c) When mounting items to container bases equipped with Similar 5/25/04 Page 28 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments skids, bolts shall be extended through the skids whenever practical. In such instances counter-sinking of the bolt in the

sliding surface of the skid is necessary.

skids, bolts shall be extended through the skids whenever practical. In such instances, countersinking of the bolts in the

sliding surface of the skid shall be done.

(4) Washers shall be used under the nuts to decrease the possibility of the bolt pulling through the wood.(d) Washers shall be used under the nuts to decrease the possibility of the bolt pulling through the wood.

Similar (5) Nuts shall be properly torqued. To prevent their loosening during shipment, lock nuts, lock washers, cotter pins, or staking shall be employed.(e) Nuts shall be properly tightened. To prevent their loosening during shipment, lock nuts, lock washers, cotter pins, or staking

shall be employed.

Similar (From 3.8.3, not the appendix.) Temporary cushioning, blocking, bracing or anchoring placed within an item for shipping

protection that must be removed prior to operation of the item

shall be identified by warnings placed in a conspicuous manner

to effect proper removal of the packing material.

Temporary cushioning, blocking, bracing, or anchoring placed on an item for shipping protection that needs to be removed prior to

operation of the item shall be identified by warnings placed in a

conspicuous manner to effect proper removal of the packing

material.Similar 3.9 Marking

3.9 Marking

To maintain proper identification and instructions or both during shipping, receiving and storage, and to provide for identification

after the outside of the container has been removed, the item and the outside of containers shall be marked. (See Appendix 3.9 for additional requirements.)

To maintain proper identification and instructions, or both, during shipping, receiving, and storage and to provide for identification

after the outside of the container has been removed, the item

and the outside of the containers shall be marked. If equipment

does not lend itself to marking, records shall be maintained that

are uniquely identifiable to the item.

Similar A3.9 Marking Items shall be marked to preserve identity in accordance with the following criteria Items shall be marked to preserve identity in accordance with the following criteria.

Similar (1) The specified identification shall be stamped, etched, stenciled or otherwise marked on the item or on tags to be

affixed securely to the item in plain, unobstructed view. When

metal stamps are employed, low stress rounded bottom type

stamps shall be used when the item proper is marked. When

vibrating marking tools are used they shall be fitted with a

carbide marking tip or equivalent; and shall be designed to

provide a rounded impression not to exceed 0.010 inches in

depth. Etching shall not be used on nickel alloys or on weld

areas or sensitized areas of stainless steel. Electric arc marking

pencils shall not be used.(a) The specified identification shall be stamped, etched, stenciled, or otherwise marked on the item or on tags to be

affixed securely to the item in plain, unobstructed view. When

metal stamps are employed, low stress, rounded bottom type

stamps shall be used when the item proper is marked. When

vibrating marking tools are used, they shall be fitted with a

carbide marking tip or its equivalent, and shall be designed to

provide a rounded impression not to exceed 0.010 in. (0.25 mm)

in depth. Etching shall not be used on nickel alloys, weld areas, or sensitized areas of stainless steel. Electric-arc marking

pencils shall not be used.

Similar (2) The marking shall not be deleterious to the material nor (b) The marking shall not be deleterious to the material nor Similar 5/25/04 Page 29 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments violate any other section of this standard.

violate any other Section of Subpart 2.2.

(3) When tags are employed, they shall be of a material which will retain the marking, withstand weathering deterioration, and

other normal shipping and handling effects and shall not be

detrimental to the item.(c) When tags are employed, they shall be of a material which will retain the marking, withstand weathering deterioration, and

other normal shipping and handling effects, and shall not be

detrimental to the item.

Similar (4) The English language shall be used. Duplicate marking may be made in other languages.(d) The English language shall be used. Duplicate marking may be made in other languages.

Similar (5) References to weights shall be in avoirdupois units.

Duplicate markings in other systems may also be indicated.(e) References to weights shall be in avoirdupois units.

Duplicate markings in other systems may also be indicated Similar Markings on the outside container shall be in accordance with the following criteria:

Markings on the outside container shall be in accordance with the following criteria.

Similar (1) Container markings shall appear on a minimum of two sides of the container, preferably on one side and one end.(a) Container markings shall appear on a minimum of two sides of a container, preferably on one side and one end.

Similar (2) The English language shall be used. Duplicate marking may be made in other languages or in pictorial markings according to

ISO Recommendation R780 Pictorial Markings For Handling of

Goods (general symbols) or ANSI MH6.1.(b) The English language shall be used. Duplicate marking may be made in other languages or in pictorial marking according to

IS0 Recommendation R780, Pictorial Markings for Handling of

Goods (general symbols) or ANSI MH6.1.

Similar (3) References to weights shall be in avoirdupois units.

Duplicate marking in other systems may also be indicated.(c) References to weights shall be in avoirdupois units.

Duplicate markings in other systems may also be indicated.

Similar (4) Container markings shall be applied with waterproof ink or paint in characters no less than 3/4 inch high, container size

permitting.

Clarification from the current VA QATR:

(24) With regard to Section A3.9 of ANSI N45.2.2-1972, titled Marking: As an alternative to the requirements in Subpart 4, the Company may choose to mark containers with waterproof ink or paint with legible characters. (See 6 below for

continuation.)(d) Container markings shall be applied with waterproof ink or paint in characters that are legible. When information relative to

handling and special instructions is required, such information

shall be preceded by the word CAUTION in letters that are at

least 1/2 in. (1 2.7 mm), as permitted by container size.

Modified requirement in NQA-1.

Alternative has been

addressed in NQA-1-1994.

(5) Where tags or labels are used, they shall be affixed to the container using a waterproof adhesive, tacks where practical, or

a corrosion resistant wire.(e) Where tags or labels are used, they shall be affixed to the container using a waterproof adhesive, tacks where practical, or

a corrosion-resistant wire.

Similar (6) Container marking shall include the following information: (a) Destination (b) Return address (c) Package numbers showing the purchase order number, (f) Container markings shall include the following information (1) destination (2) return address

(3) package numbers showing the purchase order number, Similar A similar alternative proposed

in the new QAPD.

5/25/04 Page 30 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments followed by the package number and the total number of packages.

(d) Material identification number (e) Handling instructions - Fragile, Center of Gravity, Keep

Dry, This Side Up, Sling Here, Do Not Freeze, stacking

limitations as appropriate.

(f) Weight of package (in excess of 100 pounds).

(g) Special Instructions. Desiccant Inside, Special Inspection, Storage, Unpacking Restrictions, etc. as appropriate.

Clarification from the current VA QATR:

(24) With regard to Section A3.9 of ANSI N45.2.2-1972, titled Marking: - Additionally, the requirements of Subpart 6 shall only apply to shipment of items. Items in storage shall be affixed with labels or tags with sufficient information to

preserve the item's identity.

followed by the package number and the total number of packages (4) material identification number

(5) handling instructions (e.g., Fragile, Center of Gravity, Keep Dry, This Side Up, Sling Here, Do Not Freeze) and

stacking limitations, as appropriate

(6) weight of package [in excess of 100 Lb. (45.5 kg)

(7) special instructions (Desiccant Inside, Special Inspection, Storage, Unpacking Restrictions, etc.) as appropriate Marking of items not within a container, such as pipe, tanks and heat exchangers, shall exhibit specified information in a location

which is in plain unobstructed view, but not directly applied to

bare austenitic stainless steel and nickel alloy metal surfaces of

the item.Marking of items not within a container, such as pipe, tanks, and heat exchangers, shall exhibit specified information in a location

which is in plain unobstructed view. Marking may be applied

directly to bare metal surfaces provided it has been established

that the marking material is not deleterious to the item.

Similar 4.0 SHIPPING 4 SHIPPING

4.1 General

4.1 General This section covers the requirements for loading and shipment of items as defined in Subsection 2.7 of this standard.

Described are environmental protection during transit, procedures to minimize damage in transit, precaution required

when handling items during loading and transit, and identification

and inspection on overseas shipments.

The mode of transportation used shall be consistent with the

protection classification of the item (See Subsection 2.7 of this

Standard) and with the packaging methods employed (See

Subsection 3.2 of this Standard).

NRC Regulatory Guide 1.38, Regulatory Position C.1.e:

Notwithstanding the provisions of subdivision 1.2 of ANSI N45.2.2-1972 with respect to the applicability of this standard This Section covers the requirements for loading and shipment of items as defined in para. 2.2. The mode of transportation used shall be consistent with the protection classification of the item (see para. 2.1) and with the packaging methods employed (see para. 3.2).

Similar 5/25/04 Page 31 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments and the definition of carrier contained in subdivision 1.4 of ANSI N45.2.2-1972, nothing contained in Section 4, "Shipping,"

of ANSI N45.2.2-1972 should be deemed to require a common

or contract carrier transporting or shipping byproduct, source, or

special nuclear material in the ordinary course of its business to

comply with the provisions set forth in this section of the

standard. In this situation these carriers are exempt from NRC

regulation under the provisions of 10 CFR [SECTIONS] 30.13, 40.12, and 70.12. Therefore, the provisions of Section 4 of

ANSI N45.2.2-1972 apply only to the extent that they affect the

activities of an NRC licensee (e.g., requirements related to

shipping contained in 10 CFR Part 71) or a private carrier

subject to NRC regulations.

4.2 Transportation

Requirements

4.2 Transportation

Requirements 4.2.1 Open Carriers.

4.2.1 Open Carriers.

For shipment on open carriers where items may be exposed to adverse environmental conditions, the following shall apply:

For shipment on open carriers where items may be exposed to adverse environmental conditions, the following shall apply.

Similar (1) Level A, B, and C items shall be covered for protection from environmental conditions. Tarpaulins, when used, shall be

fire retardant; and they shall be installed in a manner to provide

drainage and to insure air circulation to prevent condensation.(a) Levels A, B, and C items shall be covered for protection from environmental conditions. Tarpaulins, when used, shall be

fire retardant, and they shall be installed in a manner to provide

drainage and to ensure air circulation to prevent condensation.

Similar (2) Barrier and wrapping materials (See Subsection 3.6 of this Standard) subject to transportation damage shall be covered

with waterproof shrouds such as tarpaulins, so that they are not

exposed directly to the environment.(b) Barrier and wrapped materials (see para. 3.6) subject to transportation damage shall be covered with waterproof shrouds, such as tarpaulins, so that they are not exposed directly

to the environment.

Similar 4.2.2 Closed Carriers.

4.2.2 Closed

Carriers.

For shipment on closed carriers the following shall apply:

For shipment on closed carriers the following shall apply.

Similar (1) When level A, B, and C items cannot be adequately protected from weather or environment on open carriers, closed

carriers shall be used.

When Levels A , B, and C items cannot be adequately protected from weather or environment on open carriers, closed carriers or fully enclosed vehicles shall be used.

Similar (2) Use of fully enclosed furniture vans is recommended when shipping large delicate items such as control panels.

Not a requirement.

4.2.3 Special

Shipments.

NRC Regulatory Guide 1.38, Regulatory Position C.2.a

4.2.3 Special

Shipments.

NRC position is that the term should be treated as shall.

Position is incorporated into 5/25/04 Page 32 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments 2. The guidelines (indicated by the verb "should") of ANSI N45.2.2-1972 contained in the following section are considered

to have sufficient safety importance to be treated the same as

the requirements of the standard, subject to any exceptions

noted:

a. Section 4.2.3-The guidelines concerning special shipments.

NQA-1.Items that exceed established weight or size limitations for railroads or highways, or require special handling should be

given additional consideration in the following areas:

Items that exceed established weight or size limitations for railroads or highways or require special handling shall be given

additional consideration in the following areas.

Similar (1) The type of bracing and tie down methods to be used with the mode of transportation selected for special shipment shall be

specified.(a) The type of bracing and tie down methods to tie used with the mode of transportation selected for special shipments shall

be specified.

Similar (2) "NO HUMPING" shall be specified on rail shipments of these items, and "NO HUMPING" signs shall be prominently

displayed.(b) NO HUMPING shall be specified on rail shipments of these items, and NO HUMPING signs shall be prominently displayed.

Similar (3) Use of impact recording meters should be specified on shipments of heavy or relatively large items incorporating

delicate factory installed instrumentation. Meters, when

specified, shall be installed prior to loading (to record any rough

handling during loading). Procedures shall be established to

interpret recorded data, and to thoroughly check the integrity of

an item when there is evidence of rough handling. A notice that

impact recording meters are being used shall be prominently

displayed. Special recording meters with operating time limits

greater than the expected transit time shall be specified or, if

the expected transit time exceeds the operating time limit of the

recorders being used, provisions shall be made to service the

meters during transit.(c) Use of impact recording meters shall be specified on shipments of heavy or relatively large items incorporating

delicate factory-installed instrumentation. Meters, when

specified, shall be installed prior to loading (to record any rough

handling during loading). Procedures shall be established to

interpret recorded data and to thoroughly check the integrity of

an item when there is evidence of rough handling. A notice that impact recording meters are being used shall be prominently displayed. Special recording meters with operating time limits

greater than the expected transit time shall be specified or, if

the expected transit time exceeds the operating time limit of the

recorders being used, provisions shall be made to service the

meters during transit.

Similar (4) The use of "Escorts" may be specified to accompany shipments, when additional surveillance is required during transit

of certain items.

Not a requirement.

(5) For special shipments, the conveyance used for transport shall be certified to be structurally adequate to take the loads

imposed during loading while enroute, and during unloading.

Prior to shipment the route shall have been investigated to (d) For special shipments, the conveyance used for transport shall be certified to be structurally adequate to take the loads

imposed during loading, while enroute, and during unloading.

Prior to shipment the route shall have been investigated to Similar 5/25/04 Page 33 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments assure safe transit.

assure safe transit.

4.3 Precautions

During Loading and Transit

4.3 Precautions

During loading and Transit Clarification from the current VA QATR:

(11) With regard to Sections 4.3, 4.4 and 4.5 of ANSI N45.2.2-1972, titled, respectively, Precautions During Loading and Transit, Identification and Marking, and Shipment from Countries Outside the United States

The Company will comply with the requirements of these Sections subject to the clarifications taken to other Sections which are referenced

herein.Similar Clarification not needed for

the new QA program.

4.3.1 Loading.

4.3.1 Loading.

The weight, lifting points, or center of gravity indicated on the crate, skid, or package by the shipper (See Subsection 3.9 of

this Standard) shall be utilized to insure proper handling during

loading, transfer between carriers, and unloading (See Section 7

of this Standard).

The weight, lifting points, or center of gravity indicated by the shipper on the crate, skid, or package by the shipper (see para.3.9) shall be utilized to ensure proper handling during loading, transfer between carriers, and unloading (see Section 7).

Similar 4.3.2 Rigging.

4.3.2 Rigging.

Carbon steel rigging equipment shall not come in direct contact with stainless steel except when attached to lifting lugs, eyes, or

pads, in order to avoid surface damage.

Carbon steel rigging equipment shall not come in direct contact with stainless steel, except when attached to lifting lugs, eyes, or pads in order to avoid surface damage.

Similar 4.3.3 Handling Precautions.

4.3.3 Handling

Precautions.

All Austenitic Stainless steel and nickel base alloy materials shall be handled in such a manner that they are not in contact

with lead, zinc, copper, mercury, or other low melting elements, alloys, or halogenated material.

All austenitic stainless steel and nickel-base alloy materials shall be handled in such a manner that they are not in contact with lead, zinc, copper, mercury, or other low melting point elements, alloys, or halogenated material.

Similar 4.3.4 Package/Preservative Coatings.

4.3.4 Package

and Preservative Coatings.

Packages and/or preservative coatings shall be visually inspected after loading, and damaged areas repaired prior to

shipment. Items shipped with desiccants shall be inspected after

loading to assure that sealed areas are intact.

Package or preservative coatings shall be visually inspected after loading and damaged areas repaired prior to shipment.

Items shipped with desiccants shall be inspected after loading to

assure that sealed areas are intact.

Similar 4.3.5 Sealed Openings.

4.3.5 Sealed

Openings.

Sealed Openings shall be visually inspected after loading to assure closures are intact. Materials used for resealing shall be

in accordance with Section 3 of this Standard.

Sealed openings shall be visually inspected after loading to assure closures are intact. Materials used for resealing shall be

in accordance with Section 3.

Similar 5/25/04 Page 34 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments 4.3.6 Stacking.

4.3.6 Stacking.

Written instructions covering the location and stacking limits of the crates or boxes on the transport vehicle shall be specified;

these should be marked on the container.

NRC Regulatory Guide 1.38, Regulatory Position C.2.b:

2. The guidelines (indicated by the verb "should") of ANSI N45.2.2-1972 contained in the following section are considered

to have sufficient safety importance to be treated the same as

the requirements of the standard, subject to any exceptions

noted:

b. Section 4.3.6-The guideline that addresses written instruction

on stacking.

Where special care is deemed necessary to avert damage, written instructions concerning the location or stacking limits for

crates or boxes shall be marked on the containers.

NRC position is that the term should be treated as shall.

Position is incorporated into

NQA-1.4.3.7 Theft and Vandalism.

4.3.7 Theft

and Vandalism.

Precautions shall be taken to minimize the possibility of theft and vandalism during shipment of items.

Precautions shall be taken to minimize the possibility of theft and vandalism during shipment of items.

Similar 4.4 Identification and Marking

4.4 Identification

and Markings Identification and markings on the outside of all packages, skids or protective covering shall be maintained in accordance with

Subsection 3.9 of this standard.

Identification and markings on the outside of all packages, skids, or protective covering shall be maintained.

Similar 4.5 Shipments From Countries Outside United States

4.5 Shipments

From Countries Outside the United States

4.5.1 Overseas

Shipment.

4.5.1 Overseas

Shipment.

When overseas shipments are involved, use of deck cargo facilities shall be avoided unless necessary due to physical

dimensions. Shipments utilizing approved watertight containers

may be carried on deck.

When overseas shipments are involved, use of deck cargo facilities shall be avoided unless necessary due to physical

dimensions. Shipments utilizing approved watertight containers

may be carried on deck.

Similar 4.5.2 Inspection at Point of Shipment.

4.5.2 Inspections

at Point of Shipment.

For Special shipments, items shall be inspected to insure integrity of packaging or protective enclosures after being

loaded aboard ship.

Items shall be inspected to ensure integrity of packaging or protective enclosures after being loaded aboard ship.

Similar 4.5.3 Inspection at Port of Entry.

4.5.3 Inspection

at Port of Entry.

For special shipments, items shall be inspected to insure integrity of packaging or protective enclosures when items are

off loaded at the port of entry.

Items shall be inspected to ensure integrity of packaging or protective enclosures when items are off-loaded at the port of

entry.Similar 5/25/04 Page 35 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments 4.5.4 Identification and Markings.

4.5.4 Identification

and Markings.

Identification and markings shall follow the procedure outlined in Subsection 3.9 of this standard. The English language and

avoirdupois weight shall be used for all identification and

marking. Duplicate markings and identification in other

languages or weight systems may be used.

Identification and markings shall follow the procedure outlined in para. 3.9.

Similar 4.5.5 Transportation Requirements

.4.5.5 Transportation Requirements.

Requirements outlined in Subsection 4.2 (Transportation) and in Section 7 of this standard shall be followed where applicable.

Requirements outlined in para. 4.2 and Section 7 shall be followed where applicable.

Similar 4.6 Nuclear Material Shipment

4.6 Nuclear

Material Shipments Special nuclear material and sources shall be shipped as specified in the AEC fuel license and by other regulatory

agencies.Special nuclear material and sources shall be shipped as specified in the NRC fuel license and by other regulatory

agencies.Similar 5. RECEIVING 5 RECEIVING

5.1 General

5.1 General This section contains requirements that are to be fulfilled by the organization or organizations responsible for the receiving of

items. Receiving starts when the items arrive at a storage

facility or construction site before unloading or unpacking.

Included are procedures, inspections, marking, identification and

documentation prior to placing the item in storage or directly in

its final location. Shipping damage claims, transfer of ownership, financial responsibility and contractual obligations are

commercial obligations which are not included in the scope of

this standard.

The requirements that shall be fulfilled by the organization(s) responsible for the receiving of items. Receiving starts when

the items arrive at a storage facility or construction site before

unloading or unpacking.

Similar, but examples of items included in receiving have not

been included in this

paragraph of NQA-1

5.2 Receiving

Inspection Requirements

5.2 Receiving

Inspection Requirements

5.2.1 Shipping

Damage Inspection.

5.2.1 Shipping

Damage Inspection.

Preliminary visual inspection or examination shall be performed prior to unloading to determine if any damage occurred during

shipping.Clarification from the current VA QATR:

(12) With regard to Section 5.2.1 of ANSI N45.2.2-1972, titled Shipping Damage Inspection

Warehouse personnel will normally visually scrutinize incoming shipments for damage of Preliminary visual inspection shall be performed prior to or immediately after unloading to determine if any damage

occurred during shipping.

Similar Clarification no longer needed

with the new QA program.

5/25/04 Page 36 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments the types listed in this Section; this activity is not necessarily performed prior to unloading. Since all required items receive

the Item Inspection of Section 5.2.2, separate documentation of

the Shipping Damage Inspection is not necessary. Release of

the transport agent after unloading and signing for receipt of the

shipment may be all of the action taken to document completion

of the Shipping Damage Inspection. Any non-conformance

noted will be documented and dispositioned as required by

Section 17.2.15 of the Operational QA Program. The person

performing the visual scrutiny during unloading is not considered

to be performing an inspection function as defined under

Regulatory Guide 1.74; therefore, while he will be trained to

perform this function he may not necessarily be certified (N45.2.6) as an Inspector.

Observations for unusual conditions shall include:

Observations for unusual conditions shall include:

Similar (1) Fire - Charred paper, wood or paint, indicating exposure to fire or high temperature.(a) fire - charred paper, wood, or paint, indicating exposure to fire or high temperature; Similar (2) Excessive Exposure - Weather-beaten, frayed, rusted, or stained containers indicating prolonged exposure during transit.(b) excessive exposure - weather-beaten, frayed, rusted, or stained containers, indicating prolonged exposure during transit; Similar (3) Environmental Damage - Water or oil marks, damp conditions, dirty areas, or salt film (indicating exposure to sea water or winter road salt chemicals).(c) environmental damage - water or oil marks, damp conditions, dirty areas, or salt film, indicating exposure to seawater or winter road salt chemicals; Similar (4) Tie Down Failure - Shifted, broken, loose or twisted shipping ties, and worn material under ties, indicating improper blocking and tie down during shipment.(d) tie down failure - shifted, broken, loose, or twisted shipping ties, and worn material under ties indicating improper blocking and tie down during shipment; Similar (5) Rough Handling - Splintered, torn, or crushed containers indicating improper handling. Review of impact recording instrument readings.(e) rough handling - splintered, torn, or crushed containers, indicating improper handling;(f) review of impact recording instrument readings against

established criteria. See para. 4.2.3(c).

Clarified by separating into two separate checks in

NQA-1.5.2.2 Item Inspection.

5.2.2 Item Inspection.

Unless the package marking prohibits unpacking, the content of all shipments shall be visually inspected to verify that the

specified packaging and shipping requirements have been

maintained. When items are contained in transparent separate Unless the package marking prohibits unpacking, the contents of all shipments shall be visually inspected to verify that the

specified packaging and shipping requirements have been

maintained. When items are contained in transparent, separate Similar 5/25/04 Page 37 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments moisture-proof bags or envelopes, visual inspection without unpacking the contents is acceptable.

moisture-proof bags or envelopes, visual inspection without unpacking the contents shall be acceptable.

Statistical sampling methods may be used for groups of similar items. Care shall be taken to avoid contamination of the items

during inspection. The inspections shall be performed in an area, equivalent to the level of storage requirement for the item (See

Section 6 of this Standard).

Where specific inspection requirements can be achieved, statistical sampling methods may be used for groups of similar

items. Care shall be taken to avoid contamination of the items

during inspection. The inspections shall be performed in an area

equivalent to the level of storage requirement for the item (see

Section 6).

Similar These inspections and examinations shall include the following as appropriate:

These inspections and examinations shall include the following, as appropriate:

Similar (1) Identification and Marking. Verification that identification and markings are in accordance with applicable codes, specifications, purchase orders, drawings, and this

standard.(a) identification and marking - verification that identification and markings are in accordance with applicable codes, specifications, purchase orders, and drawings, and with

requirements in this Part (Part II);

Similar (2) Manufacturing Documentation - Assurance that the item received was fabricated. tested and inspected prior to shipment in accordance with applicable code, specification, purchase

order and/or drawings.(b) manufacturing documentations - assurance that the item received was fabricated, tested, and inspected prior to shipment in accordance with applicable code, specification, purchase

order, or drawings; Similar (3) Protection Covers and Seals - Visual inspection to assure that covers and seals meet their intended function.(c) protective covers and seals - visual inspection to assure that covers and seals meet their intended function; Similar (4) Coatings and Preservatives - Verification that coatings and preservatives are applied in accordance with specifications, purchase orders or manufacturer's instructions.(d) coatings and preservatives - verification that coatings and preservatives are applied in accordance with specifications, purchase orders, or manufacturer's instructions; Similar (5) Inert Gas Blanket - Verification that the inert gas blanket pressure is within the acceptable limits.(e) inert gas blanket - verification that the inert gas blanket pressure is within the acceptable limits; Similar (6) Desiccant - Verification that the desiccant is not saturated, as indicated through the use of humidity indicators. Desiccants shall be regenerated or replaced as necessary in accordance

with special instructions.(f) desiccant - verification that the desiccant is not saturated, as indicated, through the use of humidity indicators. Desiccants

shall be regenerated or replaced as necessary in accordance

with special instructions.

Similar (7) Physical Damage - Visual inspection to assure that parts of items are not broken, cracked, missing, deformed or misaligned and rotating parts turn without binding. Accessible internal and external areas shall be free of detrimental gouges, dents, scratches and burns.(g) physical damage - visual inspection to assure that parts of items are not broken, cracked, missing, deformed, or misaligned, and that rotating parts turn without binding. Accessible internal and external areas shall be free of detrimental gouges, dents, scratches, and burns.

Similar 5/25/04 Page 38 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments (8) Cleanness - Visual inspection to assure that accessible internal and external areas are within the specification requirements for dirt, soil, mill scale, weld splatter, oil, grease, or

stains. If inspection for cleanness was performed prior to

sealing and shipping, and inspection upon receipt indicates that

there has been no penetration of the sealed boundary, then

inspection for internal cleanness is optional.(h) cleanness - visual inspection to assure that accessible internal and external areas are within the specification

requirements for dirt, soil, mill scale, weld splatter, oil, grease, or

stains. If inspection for cleanness was performed prior to

sealing and shipping, and inspection upon receipt indicates that

there has been no penetration of the sealed boundary, then

inspection for internal cleanness is optional.

Similar Unless the completed item was inspected or examined at the source, it shall be inspected or examined at the point of

receiving to verify that the following characteristics conform to

the specified requirements. These inspections or examinations

shall include such items as:

Clarification from the current VA QATR:

(13) With regard to Section 5.2.2 of ANSI N45.2.2-1972, titled Item Inspection

The second division of this subsection requires six additional inspection activities if an item was not inspected or examined at the source. Procurement Engineering

shall determine and document the extent of receipt inspection

based on consideration of Paragraph 5.2.2 Unless the completed item was inspected at the source, it shall be inspected at the point of receiving to verify that the following

characteristics conform to the specified requirements. These

inspections shall include such items as:

Similar Clarification not needed in the

new QA program, this is a

level of detail to be addressed

by the administrative controls

for the inspection program.

(1) Physical Properties - Assurance that physical properties conform to the specified requirements and that chemical and physical test reports, if required, meet the requirements.(a) physical properties - assurance that physical properties conform to the specified requirements and that chemical and

physical test reports, if required, meet the requirements; Similar (2) Dimensions - Random visual inspection to assure that important dimensions conform with drawings and specifications.

Examples are; base plate mounting holes, overall external size, configuration and orientation of parts.(b) dimensions - random visual inspection to assure that important dimensions conform with drawings and specifications, i.e., baseplate mounting holes, overall external size, and configuration and orientation of parts; Similar (3) Weld Preparations - Random verification that weld preparations are in accordance with applicable drawings and specifications.(c) weld preparations - random verification that weld preparations are in accordance with applicable drawings and

specifications; Similar (4) Workmanship - Visual inspection of accessible areas to assure that the workmanship is satisfactory to meet the intent of the requirements.(d) workmanship - visual inspection of accessible areas to assure that the workmanship is satisfactory to meet the intent of

the requirements; Similar (5) Lubricants and Oils - Verification of presence of proper lubricants and oils, if required, by either specification, purchase (e) lubricants and oils - verification of presence of proper lubricants and oils, if required, by either specification, purchase Similar 5/25/04 Page 39 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments order, or manufacturers' instructions.

order, or manufacturer's instructions; (6) Electrical Insulation - Performance, of insulation resistance tests for motors, generators, control and power cable, to ensure conformance with specifications.(f) electrical insulation - performance of insulation resistance tests for motors, generators, and control and power cable to

ensure conformance with specifications.

Similar 5.2.3 Special Inspection -

5.2.3 Special

Inspection.

Where receiving inspection in addition to that described above is required, the "Special Inspection" procedure, complete with

documentation instructions, shall be attached to the item or

container (See Section 3 of this Standard); this is in addition to

the copy sent through normal channels. The special inspection

shall be performed and the results of the inspection shall be

documented.

Where receiving inspection in addition to that described above is required, the special inspection procedure, complete with

documentation instructions, shall be attached to the item or

container. This is in addition to the copy sent through normal

channels. The special inspection shall be performed, and the

results of the inspection shall be documented.

Similar 5.3 Disposition of Received Items

5.3 Disposition

of Received Items

5.3.1 Acceptable

- Containers and items inspected or examined and found in conformance with specified requirements shall be

identified as acceptable in accordance with the status indicating

system employed (See Subsection 5.4 of this Standard) and

placed in a storage area for acceptable items or moved to the

final location for installation or use.

5.3.1 Acceptable.

Containers and items inspected and found in conformance with specified requirements shall be identified as acceptable (see para. 5.4) and placed in a storage area for acceptable items, or moved to the final location for installation or use.Similar 5.3.2 Nonconforming - Items which do not conform to the specified requirements shall be identified as nonconforming in

accordance with the system employed (See Subsection 5.4 of

this Standard) and when practical the item shall be placed in a

segregated storage area or removed from the project site to

prevent inadvertent installation or use.

5.3.2 Nonconforming.

Items which do not conform to the specified requirements shall be controlled in accordance with Part I.Similar when taking into consideration the information

addressed in NQA-1, Part 1.

5.3.3 Conditional

Release - If the nonconformance which caused the item to be classified "unacceptable" can be

corrected after installation, the item may be released for

installation on a conditional release basis. A statement

documenting the authority and technical justification for the

conditional release of the item for installation shall be prepared, and made part of the documentation.

5.3.3 Conditional

Release.

If the nonconformance that caused the item to be classified unacceptable can be corrected after installation, the item may be released for installation on a

conditional release basis. A statement documenting the authority and technical justification for the conditional release of the item for installation shall be prepared and made part of the

documentation.

Similar 5.4 Status Indicating System

5.4 Status

Indicating System A system or method for identifying the status of items (e.g. an inventory system, tagging, labeling, color code) shall be A status indicating system is a system or method for identifying the status of items (e.g., an inventory system, tagging, labeling, Similar Clarification not needed under 5/25/04 Page 40 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments employed that clearly indicates whether items are acceptable or unacceptable for installation. A controlled physical separation is

an acceptable equivalent method. The system shall indicate the

date the item was placed in the acceptable or unacceptable

installation status. The use of the system shall be regulated by

the Quality Control program. The system shall provide for the

conditional release of items for installation pending subsequent

correction of the nonconformance. When tags are used the

stock shall be made from material which will not deteriorate

during storage; tags shall be securely affixed to the items and

displayed in an area that is readily accessible. The stock used

shall not be deleterious to the item.

Clarification from the current VA QATR:

(14) With regard to Section 5.4 of ANSI N45.2.2-1972, titled Status Indicating System

The Section states in part "Tags shall be securely affixed to the items and displayed in an area that is readily accessible." As an alternative, the company may

choose to use Labels or Tags to identify items.

color code) that clearly indicates whether items are acceptable or unacceptable for installation. A controlled physical

separation is an acceptable equivalent method. The system shall

provide for indication of the date the item was placed in the

acceptable or unacceptable installation status and the

conditional release of the items for installation pending the

subsequent correction of the nonconformance. When tags are

used, the stock shall be made from material that will not

deteriorate during storage. The stock used shall not be

deleterious to the item. Tags shall be securely affixed to the

items and displayed in an area that is readily accessible.

the new QA program.

5.5 Correction

of Nonconformances Items designated nonconforming or unacceptable for installation or use shall be corrected using authorized procedures, to meet

specified requirements, or accepted "As is". If this is not

possible, the item shall be scrapped or otherwise discarded See NQA-1, Part I, Basic Requirement 15 and Supplement 15S-1. Wording is

similar.5.5.1 Reinspection -Items that have been corrected shall be reinspected. The area of inspection may be confined to the area

of the nonconformance. When it has been determined that the

corrected item is satisfactory, the status of the item as denoted

by the system shall be changed to acceptable. An appropriate

entry shall be made in the documentation after acceptance is

determined.

See NQA-1, Part I, Basic Requirement 15 and Supplement 15S-1. Wording is

similar.5.6 Marking

5.5 Marking

Required marking shall be verified to provide positive identification during receiving, storage, and installation. Items

not properly identified at receiving may be marked using the

method in the appendix (See Appendix A 3.9 of this Standard).

Not a requirement.

5/25/04 Page 41 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments Changing, correcting or any other marking on Code Stamp name plate is prohibited, unless authorized by the manufacturer

whose serial number is applied.

Changing, correcting, or any other marking on Code stamp nameplate shall be prohibited, unless authorized by the

manufacturer of the item.

Similar 5.7 Documentation

5.6 Documentation

A written record of the receiving inspection, package identification, tagging, corrective actions, and justification for

conditional acceptance shall be prepared. These records shall

be made a part of the permanent records provided for in

Section 8 of this standard.

A written record of the receiving inspection, package identification, tagging, corrective actions, and justification for

conditional acceptance shall be prepared Similar 6. STORAGE 6 STORAGE 6.1 General

6.1 General

6.1.1 Scope. This section contains requirements that are to be fulfilled by the organization responsible for performing the

storage of items. Levels and methods of storage necessary are

defined to minimize the possibility of damage or lowering of

quality due to corrosion, contamination, deterioration or physical

damage from the time an item is stored upon receipt until the

time the item is removed from storage and placed in its final

location.6.1.1 Scope.

This Section contains requirements that shall be fulfilled by the organization responsible for performing the storage of items. Levels and methods of storage are defined to

minimize the possibility of damage or lowering of quality due to

corrosion, contamination, deterioration, or physical damage from

the time an item is stored upon receipt until the time the item is

removed from storage and placed in its final location.

Similar 6.1.2 Levels of Storage. Environmental conditions for items classified as Levels A, B, C, and D described in Subsection 2.7

of this standard shall meet requirements as described in the

following paragraphs:

6.1.2 Levels

of Storage.

Environmental conditions for items classified as Levels A , B, C, and D described in para. 2.2 shall meet the requirements as described in the following paragraphs.

Similar (1) Level A items shall be stored under special conditions similar to those described for Level B items but with additional

requirements such as temperature and humidity control within

specified limits, a ventilation system with filters to provide an

atmosphere free of dust and harmful vapors, and any other

appropriate requirements.(a) Level A items shall be stored under special conditions similar to those described for Level B items but with additional requirements such as temperature and humidity control within specified limits, a ventilation system with filters to provide an

atmosphere free of dust and harmful vapors, and any other

appropriate requirements.

Similar (2) Level B items shall be stored within a fire resistant, tear resistant, weather-tight, and well-ventilated building or

equivalent enclosure. Precautions shall be taken against

vandalism. This area shall be situated and constructed so that it

will not be subject to flooding, the floor shall be paved or equal, and well drained. Items shall be placed on pallets or shoring to (b) Level B items shall be stored within a fire-resistant, tear-resistant, weather-tight, and well-ventilated building or

equivalent enclosure. Precautions shall be taken against

vandalism. This area shall be situated and constructed so that it

will not be subject to flooding; the floor shall be paved or equal, and well drained. Items shall be placed on pallets or shoring to Similar Clarification not needed for

the new QA program.

5/25/04 Page 42 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments permit air circulation. The area shall be provided with uniform heating and temperature control or its equivalent to prevent

condensation and corrosion. Minimum temperature shall be 40 F

and maximum temperature shall be 140 F or less if so stipulated

by a manufacturer.

Clarification from the current VA QATR: (15) With regard to Section 6.1.2 of ANSI N45.2.2-1972, titled Levels of Storage

Subpart (2) is replaced with the following:

(2) Level B items shall be stored within a fire resistant, weather-tight, and well ventilated building or equivalent

enclosure in which measures have been taken against

vandalism. This building shall be situated and constructed so

that it will not normally be subject to flooding; the floor shall be

paved or equal, and well drained. If any outside waters should

come in contact with stored equipment, such equipment will be

labeled or tagged non-conforming, and then the non-

conformance document will be processed and evaluated in

accordance with Section 17.2.15. Items shall be placed on

pallets, shoring or shelves to permit air circulation. The building

shall be provided with uniform heating and temperature control

or its equivalent to prevent condensation and corrosion.

Minimum temperature shall be 40

°F and maximum temperature shall be 140

°F or less if so stipulated by a manufacturer.

permit air circulation. The area shall be provided with uniform heating and temperature control or its equivalent to prevent

condensation and corrosion. The minimum temperature shall be

40°F (5°C), and the maximum temperature shall be 140°F

(60°C) or less if so stipulated by the manufacturer.

(3) Level C items shall be stored indoors or equivalent with all provisions and requirements as set forth in Level B items

except that heat and temperature control is not required.(c) Level C items shall be stored indoors or in an equivalent environment with all provisions and requirements as set forth

for Level B items, except that heat and temperature control is not required.

Similar (4) Level D items may be stored outdoors in an area marked and designated for storage, which is well drained, preferably

gravel covered or paved and reasonably removed from the

actual construction area and traffic so that possibility of damage

from construction equipment is minimized. Items shall be stored

on cribbing or equivalent to allow for air circulation and to avoid

trapping water.(d) Level D items may be stored outdoors in an area marked and designated for storage that is well drained, preferably

gravel covered or paved, and reasonably removed from the

actual construction area and traffic so that the possibility of

damage from construction equipment is minimized. Items shall

be stored on cribbing or equivalent to allow for air circulation

and to avoid trapping water.

Similar 5/25/04 Page 43 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments 6.2 Storage Areas

6.2 Storage

Areas Periodic inspections shall be performed to assure that storage areas are being maintained in accordance with these

requirements. The housekeeping requirements shall be in

accordance with N45.2.3.

Periodic inspections shall be performed to assure that storage areas are being maintained in accordance with applicable

requirements.

Similar 6.2.1 Access to Storage Areas.

6.2.1 Access

to Storage Areas.

Access to storage areas shall be controlled and limited only to personnel designated by the responsible organization.

Clarification from the current VA QATR:

(16) With regard to Section 6.2.1 of ANSI N45.2.2-1972, titled Access to Storage Areas

Items which fall within the Level D classification of the standard will be stored in an area which may be posted to limit access, but other positive controls such

as fencing or guards will not normally be provided.

Access to storage areas for Levels A, B, and C items shall be controlled and limited only to personnel designated by the responsible organization. Access to storage areas involving

Level D items shall be controlled as designated by the

responsible organization.

Similar Clarification not needed for

the new QA program.

6.2.2 Cleanliness

and Housekeeping practices.

6.2.2 Cleanness

and Housekeeping Practices.

Cleanliness and good housekeeping practices shall be enforced at all times in the storage areas. The storage areas shall be

cleaned as required to avoid the accumulation of trash, discarded packaging material and other detrimental soil.

Cleanliness and good housekeeping practices shall be enforced at all times in the storage areas. The storage areas shall be

cleaned as required to avoid the accumulation of trash, discarded packaging materials, and other detrimental soil.

Similar 6.2.3 Fire Protection.

6.2.3 Fire Protection Fire protection commensurate with the type of storage area and the material involved shall be provided and maintained.

Fire protection commensurate with the type of storage area and the material involved shall be provided and maintained.

Similar 6.2.4 Storage of Food and Associated Items.

6.2.4 Storage

of Food and Associated Items.

The use or storage of food, drinks, and salt tablets dispensers in any storage area shall not be permitted.

Clarification from the current VA QATR:

(17) With regard to Section 6.2.4 of ANSI N45.2.2-1972, titled Storage of Food and Associated Items

The sentence is replaced with the following: "The use or storage of food, and drinks in any storage area shall be controlled and shall be limited

to designated areas where such use or storage is not deleterious

to stored items where station management deems appropriate.

The use or storage of food, drinks, and salt tablet dispensers in controlled storage areas shall not be permitted.

Similar Clarification not needed for

the new QA program.

6.2.5 Measures

to Prevent Entrance of Animals.

6.2.5 Measures

to Prevent Entrance of Animals.

Measures shall be taken to prevent the entrance of rodents and Measures shall be taken to prevent the entrance of rodents and Similar 5/25/04 Page 44 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments other animals into indoor storage areas or equipment to minimize possible contamination and mechanical damage to

stored material.

Clarification from the current VA QATR:

(18) With regard to Section 6.2.5 of ANSI N45.2.2-1972, titled Measures to Prevent Entrance of Animals

The sentence is replaced with the following: "Exterminators or other appropriate measures shall be used to control animals to minimize possible

contamination and mechanical damage to stored material."

other animals into indoor storage areas or equipment to minimize possible contamination and mechanical damage to

stored material.

Clarification not needed for the new QA program.

6.3 Storage

Methods

6.3 Storage

Methods Storage methods and procedures shall comply with the requirements described in the following paragraphs.

Storage methods and procedures shall comply with the requirements described in the following paragraphs.

Similar 6.3.1 Ready Access to Stored Items.

6.3.1 Ready

Access to Stored Items.

All items shall be stored in such a manner as to permit ready access for inspection or maintenance without excessive

handling, to minimize risk of damage.

All items shall be stored in such a manner as to permit ready access for inspection or maintenance without excessive

handling to minimize risk of damage.

Similar 6.3.2 Arrangement of Items.

6.3.2 Arrangement

of Items.

Items stacked for storage shall be arranged so that racks, cribbing or crates are bearing the full weight without distortion

of the item.

Items stacked for storage shall be arranged so that racks, cribbing, or crates are bearing the full weight without distortion

of the item.

Similar 6.3.3 Storage of Hazardous Material.

6.3.3 Storage

of Hazardous Material.

Hazardous chemicals, paints, solvents, and other materials of a like nature shall be stored in well ventilated areas which are not

in close proximity to important nuclear plant items.

Hazardous chemicals, paints, solvents, and other materials of a like nature shall be stored in well-ventilated areas and not in

close proximity to important nuclear plant items.

Similar 6.3.4 Identification 6.3.4 Identification.

All items and their containers shall be plainly marked so that they are easily identified without excessive handling, or

unnecessary opening of crates and boxes.

Clarification from the current VA QATR:

(19) With regard to Section 6.3.4 of ANSI N45.2.2-1972 titled Identification

The section states "All items and their containers shall be plainly marked so that they are easily identified without excessive handling or unnecessary opening of

crates and boxes." The company shall substitute "All items (or, Items and their containers shall be plainly marked so that they are easily identified without excessive handling or unnecessary

opening of crates and boxes.

Similar Clarification not needed for

the new QA program.

5/25/04 Page 45 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments if in containers, their containers) shall be plainly marked so that they are easily identified without excessive handling or

unnecessary opening of crates and boxes."

6.3.5 Coverings.

6.3.5 Coverings.

Weatherproof covering, when used for outdoor storage, shall be flame resistant type of sheeting or tarpaulins. They shall be

placed so as to provide drainage and to insure air circulation to

minimize condensation. They shall be tied down to prevent

moisture from entering laps and to protect the coverings from

wind damage.

Weatherproof Coverings, when used for outdoor storage, shall be the flame-resistant type of sheeting or tarpaulins. They shall

be placed so as to provide drainage and to ensure air circulation

to minimize condensation, They shall be tied down to prevent

moisture from entering laps and to protect the coverings from

wind damage.

Similar 6.3.6 Outdoor Storage.

Items stored outdoors shall be positioned or covered to avoid trapping moisture in pockets or internally. For example, valves

shall be positioned such that water does not collect under the

bonnet but can drain from the valve packing area.

Added in NQA-1-1994.

6.4 Control

of Items in Storage

6.4 Control

of Items in Storage Control of items in storage is described in the following paragraphs.

Control of items in storage is described in the following paragraphs.

Not a requirement

6.4.1 Inspections

and Examinations. Inspections and examinations shall be performed and documented on a periodic

basis to assure that the integrity of the item and its container as

provided under Section 3 of this standard is being maintained.

Deficiencies noted shall be corrected and documented.

6.4.1 Inspections.

Inspections shall be performed and documented on a periodic basis to assure that the integrity of the item and its container, as provided for under Section 3, is

being maintained. Deficiencies noted shall be corrected and

documented.

Similar The characteristics verified during this inspection or examination shall include such items as:

The characteristics verified during this inspection shall include such items as:

Similar (1) Identification and marking (See Subsection 3.9 of this Standard).(a) identification and marking (see para. 3.9)

Similar (2) Protective covers and seals (See Subsection 3.9 of this Standard).(b) protective covers and seals (see para. 3.6)

Similar (3) Coatings and preservatives (See Paragraph 3.4.1).(c) coatings and preservatives (see para. 3.4.1)

Similar (4) Desiccants and inert gas blankets (See Paragraph 3.6.3 and 3.4.2).(d) desiccants and inert gas blankets (see paras. 3.6.3 and 3.4.2)Similar (5) Physical damage.(e) physical damage Similar (6) Cleanness.(f) cleanness Similar 5/25/04 Page 46 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments 6.4.2 Care of Items. Care of items in storage shall be exercised in accordance with the following. Requirements for proper

maintenance during storage shall be documented and written

procedures or instructions shall be established.

6.4.2 Care of Items.

Requirements for proper maintenance during storage shall be documented. Care of items in storage (includes storage in place) shall be exercised in accordance with the following.

Similar (1) Items in storage shall have all covers, caps, plugs or other closures intact. Methods used to seal openings shall be in

accordance with Section 3 of this standard. Covers removed for

internal access at any time for any reason shall be immediately

replaced and resealed after completion of the purpose for

removal.(a) Items in storage shall have all covers, caps, plugs, or other closures intact. Methods used to seal openings shall be in

accordance with Section 3. Covers removed for internal access

shall be immediately replaced and resealed after completion of

the purpose for removal.

Similar (2) Temporary preservatives shall be left intact during storage.

Should reapplication of preservatives be required at the site, only those previously approved shall be used.(b) Temporary preservatives shall be left intact during storage.

Should reapplication of preservatives be required at the site, only those previously approved shall be used.

Similar (3) Items pressurized with inert gas shall be monitored at such a frequency as to insure that the gas pressure is maintained within

specified limits during storage. Desiccant humidity indicators

shall also be monitored and desiccants shall be changed or

reprocessed when specified.(c) Items pressurized with inert gas shall be monitored at such a frequency as to ensure that the gas pressure is maintained

within specified limits during storage. Desiccant humidity

indicators shall also be monitored, and desiccants shall be

changed or reprocessed when specified.

Similar (4) Instrumentation racks shall be energized as specified by the manufacturer (d) Instrumentation racks shall be energized as specified by the manufacturer.

Similar (5) Space heaters enclosed in electrical items shall be energized.

Alternative from the current VA QATR:

(20) With regard to Section 6.4.2 of ANSI N45.2.2-1972, titled Care of Items

The following alternatives are provided for the indicated subpart:

(5)"Space heaters in electrical equipment shall be energized

unless a documented engineering evaluation determines that

such space heaters are not required."(e) Space heaters enclosed in electrical items shall be energized.

Similar A similar alternative proposed

for the new QA program.

(6) Rotating electrical equipment shall be given insulation resistance tests on a scheduled basis.

Alternative from the current VA QATR:

(20) With regard to Section 6.4.2 of ANSI N45.2.2-1972, titled Care of Items

The following alternatives are provided for the indicated subpart: (f) Rotating electrical equipment shall be given insulation resistance tests on a scheduled basis.

Similar A similar alternative proposed

for the new QA program.

5/25/04 Page 47 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments (6) "Large (greater than or equal to 50HP) rotating electrical equipment shall be given insulation resistance tests on a

scheduled basis unless a documented engineering evaluation

determines that such tests are not required."

(7) The shafts of rotating equipment shall be rotated on a periodic basis. The degree of turn shall be established so that

the parts receive a coating of lubrication where applicable, and

so that the shaft does not come to rest in a previous position.

(90 degree and 450 degree rotations are examples.)

Alternative from the current VA QATR:

(20) With regard to Section 6.4.2 of ANSI N45.2.2-1972, titled Care of Items

The following alternatives are provided for the indicated subpart:

(7) "Within thirty days of having been placed in storage, rotating

equipment weighing over approximately 50 pounds shall be

evaluated by engineering personnel to determine if shaft rotation

in storage is required: The results of the evaluation shall be

documented. If rotation is required, it shall be performed at

specific intervals, be documented, and be conducted so that

parts receive a coating of lubrication where applicable and so

that the shaft does not come to rest in the same position

occupied prior to rotation. For long shafts or heavy equipment

subject to undesirable bowing, shaft orientation after rotation

shall be specified and obtained."(g) The shafts of rotating equipment shall be rotated on a periodic basis. The degree of turn shall be established so that

the parts receive a coating of lubrication, where applicable, and

so that the shaft does not come to rest in a previous position (90

deg. and 450 deg. rotations are examples).

Similar A similar alternative proposed

for the new QA program.

(8) Other maintenance requirements specified by the manufacturer's instruction for the item shall be performed.(h) Other maintenance requirements specified by the manufacturer's instructions for the item shall be performed.

Similar 6.4.3 Post Fire Evaluation.

6.4.3 Post-Fire Evaluation.

In the event a fire should occur in the storage area or at any time, each item known to have been heated to an ambient

temperature of over 150 F or subjected to smoke contamination

shall be withheld from installation or use until it has been

thoroughly examined and the item has been verified to be in

conformance with specified requirements.

In the event a fire should occur in the storage area at any time, each item known to have been heated to an ambient

temperature of over 150°F (65°C) or subjected to smoke

contamination shall be withheld from installation or use until it

has been thoroughly examined, and the item has been verified to

be in conformance with specified requirements.

Similar 6.5 Removal of Items from Storage

6.5 Removal

of Items From Storage Only items which have been inspected and are considered Only items which have been inspected and are considered Similar 5/25/04 Page 48 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments acceptable for installation or use in accordance with the receiving inspection procedure shall be removed from storage

for installation or use. (See Section 5 of this Standard.) Items

released from storage and placed in their final locations within

the power plant, shall be inspected and cared for in accordance

with the requirements of Section 6 of this standard, and other

applicable standards.

Clarification from the current VA QATR:

(21) With regard to Section 6.5 of ANSI N45.2.2-1972, titled Removal of Items from Storage

The Company does not consider the last sentence of this Section to be applicable to the operations phase due to the relatively short period of time

between installation and use. The first sentence of the Section

is replaced with: "the Company will develop, issue, and

implement a procedure(s) which cover(s) the removal of items

from storage. The procedure(s) will assure that the inspection

status of all material issued is known, controlled and

appropriately dispositioned."

acceptable for installation or use in accordance with the receiving inspection procedure shall be removed from storage

for installation or use (see Section 5). Items released from

storage and placed in their final locations and items stored in

place within the power plant shall be inspected and cared for in

accordance with the requirements of paras. 6.4.1 and 6.4.2 and other standards, as applicable.

Clarification not required for the new QA program.

6.6 Storage

Records

6.6 Storage

Records Written records shall be prepared that include such pertinent information as storage location, inspection results, protection, and personnel access.

Clarification from the current VA QATR:

(22) With regard to Section 6.6 of ANSI N45.2.2-1972, titled Storage Records

The Company will comply with the requirements of this Section with the clarification that, for record purposes, only the access of personnel not specifically

authorized such by station management into indoor storage

areas shall be recorded. Unloading or pick-up of material shall

not be considered "access," nor shall inspection by maintenance

and modification inspection personnel or audit by Nuclear

Oversight personnel, authorized contractors, NRC or other

regulatory agents, nor shall tours by non-employees.

Written records shall be prepared that include such pertinent information as storage location, inspection results, protection, and personnel access.

Similar Alternative proposed in the

new QA program to clarify

the records requirements for

access to storage facilities.

5/25/04 Page 49 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments 7. HANDLING 7 HANDLING

7.1 General

7.1 General This section contains requirements that are to be fulfilled by the organizations responsible for handling items. This section covers

the requirements for the handling of items in Subsection 2.7 of

this standard utilizing appropriate equipment in accordance with

methods and procedures specified to minimize damage and

preserve the quality of the item and container.

The requirements that shall be fulfilled by the organizations responsible for handling items are contained in subpart 2.15.

Subpart 2.15 requirements are compared to these

requirements of N45.2.2 in the

table for Subpart 2.15.

7.2 Methods

and Procedures Detailed handling instructions and procedures shall be prepared for all items that require special handling instructions because of

weight, size, susceptibility to shock damage, high nil ductility

transition temperatures, or any other conditions that warrant

special instructions. Such instructions or procedures shall be

made available prior to the time the item is to be handled and

shall give weights, sling locations, balance points, methods of

attachment, maximum hoist line speeds and other pertinent

features to be considered as necessary for safe handling.

Items not specifically covered above shall be handled in

accordance with sound material handling practices.

7.3 Hoisting

Equipment All equipment for handling items shall be used and maintained in accordance with the following:

7.3.1 Hoisting

equipment used for handling shall be certified by the manufacturer. The certification shall indicate the various

parameters for the maximum load to be handled.

7.3.2 Hoisting

equipment shall not be loaded beyond its rated load, as certified by the manufacturer, except for test purposes.

7.3.3 The requirements of ANSI B30.2.0, Safety Standard for Overhead and Gantry Cranes, ANSI B30.5, Safety Standard

for Crawler, Locomotive and Truck Cranes, ANSI B30.6, Safety Standard for Derricks, and ANSI A10.5, Safety

Requirements for Material Hoists shall be followed.

7.3.4 For special lifts, hoisting equipment may be re-rated, or modified and re-rated, upon approval by the manufacturer or if 5/25/04 Page 50 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments the manufacturer's specifications are not available, the limitations assigned to the equipment shall be based on the

determinations of a qualified engineer competent in this field

and such determination shall be documented and recorded

appropriately. Re-rated equipment shall be given a dynamic load

test over the full range of the lift using a test weight at least

equal to the lift weight. A dynamic test includes raising, lowering and traversing the load in contrast to a static test

where the test weight may be increased incrementally with no

movement.NRC Regulatory Guide 1.38, Regulatory Position C.1.b:

b. Subdivision 7.3.4 of ANSI N45.2.2-1972 delineates requirements for re-rating hoisting equipment for special lifts.

This subdivision requires that re-rated equipment be given a

dynamic load test over the full range of the lift, using a test

weight at least equal to the lift weight. In lieu of this

requirement, the test weight used in temporarily re-rating

hoisting equipment for special lifts in accordance with the

provisions of subdivision 7.3.4 should be at least equal to 110%

of the lift weight.

Clarification from the current VA QATR:

(23) With regard to Section 7.3 of ANSI N45.2.2-1972, titled Hoisting Equipment

Rerating of hoisting equipment will be considered only when absolutely necessary. Prior to performing any lift above the load rating, the equipment manufacturer must

be contacted for his approval and direction. The manufacturer

must be requested to supply a document granting approval for a

limited number of lifts at the new rating and any restrictions

involved, such as modifications to be made to the equipment, the

number lifts to be made at the new rating, and the test lift load.

At all times, the codes governing rerating of hoisting equipment must be observed. If rerating hoisting equipment is necessary and the Company cannot or does not contact the equipment manufacturer as described above, the test weight used in

temporarily rerating hoisting equipment for special lifts will be at 5/25/04 Page 51 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments least equal to 110% of the lift weight. A dynamic load test over the full range of the lift using a weight at least equal to the lift

weight shall be performed.

7.4 Inspection

of Equipment and Rigging An inspection program shall be established for equipment and rigging. A system shall be established that will indicate

acceptability of all equipment and rigging after each inspection.

This system shall specify control of nonconforming lifting

equipment.

Periodic inspections shall be supplemented with special visual and non-destructive examinations and dynamic load tests prior

to handling of items described in Subsection 7.2 of this standard

7.4.1 Rigging

that is frayed, worn or otherwise deteriorated shall not be used.

7.4.2 Hoisting

equipment that does not meet manufacturer's specifications shall not be used.

7.4.3 Equipment

and rigging shall be kept clean and free of contaminants that are detrimental to the material being handled.

7.4.4 Rigging

items such as hooks, shackles and turnbuckles that appear to have yielded or are distorted shall not be used.

7.5 Personnel

The responsible organization shall determine that the personnel engaged in operating material handling, equipment are

competent and have demonstrated satisfactory ability in

operating similar lifting equipment.

8. RECORDS 8 RECORDS Record copies of completed procedures: reports; personnel qualification records; test equipment calibration records; test

deviation or exception records; and inspection and examination

records shall be prepared as required by this standard. These

records shall be placed with other project records as required

by code, standard, specification or project procedures.

Record copies of procedures, reports, personnel qualification records, test equipment calibration records, test deviation or

exception records, and inspection records shall be prepared as

required by this Subpart. These records shall be retained with

other project records as required by code, standard, specification, or project procedures.

Similar 9. AMERICAN NATIONAL STANDARDS REFERRED TO IN THIS DOCUMENT When the following standards referred to in this document are The new QA program 5/25/04 Page 52 of 52 Packaging, Shipping, Receiving, Storage And Handling Of Items For Nuclear Power Plants (During The Construction Phase)

N45.2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants NQA-1 1994 Subpart 2.2 Comments superseded by a revision approved by the American National Standards Institute the revision shall apply:

N45.2 Quality Assurance Program Requirements for Nuclear Power

Plants

• N45.2.3 Housekeeping During the Construction Phase of Nuclear

Power Plants

• N45.2.6 Qualifications of Quality Assurance Personnel for the

Construction Phase of Nuclear Power Plants

• N45.2.10 Quality Assurance Terms and Definitions

M H 6.1 Pictorial Markings for Handling of Goods

B30.2.0 Safety Code for Overhead and Gantry Cranes

B30.5 Safety Code for Crawler, Locomotive, and Truck Cranes

B30.6 Safety Code for Derricks

A I 0.5 Safety Requirements for Material Hoists

These Standards are being approved by the American National

Standards Institute and they should be available early in 1973.

addresses the standards to be applied to the QA program in

accordance with NRC

regulations.

05/27/04 Page 1 of 13 Housekeeping During the Construction Phase of Nuclear Power Plants N45.2.3-1973 Quality Assurance Requirements for Housekeeping for Nuclear Power Plants NQA-1 1994 Subpart 2.3 COMMENTS 1. INTRODUCTION 1 GENERAL 1.1 Scope This standard defines the housekeeping requirements for the control of work activities, conditions, and environments

that can affect the quality of important parts of a nuclear

power plant during the construction phase.

NRC Regulatory Guide 1.39 , Position C.3 Although ANSI N45.2.3-1973 is entitled "Housekeeping During the Construction Phase of Nuclear Power Plants,"

the requirements included in the standard, subject to the

provision of Regulatory Position C.2, are considered to be

applicable for housekeeping activities occurring during the

operations phase that are comparable to those occurring

during the construction phase.

Generic Statement from the current VA QATR:

For operations phase maintenance and modification activities which are comparable in nature and extent to

similar activities conducted during the construction phase, the Company shall control these activities under this

Operational Quality Assurance Program. Designated

modifications may be controlled under a contractor's

Quality Assurance Program which has been approved by

the Company's Quality Assurance Program. When this

Operational Quality Assurance Program or an approved

contractor's Quality Assurance Program is used, the

Company shall comply with the Regulatory Position

established in the guides listed herein in that quality

assurance programmatic/administrative requirements

included therein (subject to the clarification in this table)

shall apply to these maintenance and modification activities

even though such requirements may not have been in effect

originally. Maintenance or modifications which may affect

the function of safety related structures, systems, or

components shall be performed in a manner at least

equivalent to that specified in original design bases and Subpart 2.3 provides housekeeping requirements for the control of work conditions and environments that can affect

the quality of important parts of a nuclear power plant.

Similar introductory statement.

05/27/04 Page 2 of 13 Housekeeping During the Construction Phase of Nuclear Power Plants N45.2.3-1973 Quality Assurance Requirements for Housekeeping for Nuclear Power Plants NQA-1 1994 Subpart 2.3 COMMENTS requirements, materials specifications, and inspection requirements. A suitable level of confidence in structures, systems, or components on which maintenance or

modifications have been performed shall be attained by

appropriate inspection and performance testing.

These parts include the structures, systems, and components whose satisfactory performance is required for

the plant to operate reliably, to prevent accidents that cause

undue risk to the health and safety of the public, or to

mitigate the consequences of such accidents if they were to

occur. Housekeeping encompasses all activities related to

control of cleanness of facilities, cleanness of material and

equipment, fire prevention and fire protection including

disposal of combustible materials and debris, control of

access, and protection of equipment not denoted in other

standards.

No similar statement in NQA-1, but these items are addressed within the

standard.The requirements may also be extended to other appropriate parts of nuclear power plants when specified in

contract documents. This standard is intended to be used in

conjunction with ANSI N45.2, Quality Assurance

Requirements For Nuclear Power Plants.

It supplements the requirements of Part I and shall be used in conjunction with applicable Basic and Supplementary

Sections of Part I when and to the extent specified by the

organizations invoking Subpart 2.3.

Similar introductory statement. NQA-1, Part I is comparable to ANSI

N45.2 as referenced in N45.2.3.

1.2 Applicability

The requirements of this standard apply to the work of any individual or organization that participates in housekeeping

activities during construction activities of nuclear power

plants as discussed in paragraph 1.1. The extent to which

the individual requirements of this standard apply will

depend upon the nature and scope of the work to be

performed and the importance of the item or service

involved. The requirements are intended to assure that only

proper materials, equipment, processes, and procedures are

utilized in the maintenance of housekeeping during the

construction of power plants and that the quality of items is

not degraded as a result of housekeeping practices and

techniques during construction processing.

See Intro to NQA-1-1994, Part II, for general information regarding Applicability.

NQA-1 addresses similar application statements in the Introduction to Part

II and in Section 2 of Subpart 2.3

below.

05/27/04 Page 3 of 13 Housekeeping During the Construction Phase of Nuclear Power Plants N45.2.3-1973 Quality Assurance Requirements for Housekeeping for Nuclear Power Plants NQA-1 1994 Subpart 2.3 COMMENTS 1.3 Responsibility The organization or organizations responsible for establishing the applicable requirements for the activities

covered by this standard shall be identified and the scope of

their responsibilities shall be documented. The work of

establishing practices and procedures and providing the

resources in terms of personnel, equipment, and services

necessary to implement the requirements of this standard

may be delegated to other organizations, and such

delegations shall also be documented. However, it is the

responsibility of each organization performing work covered

by this standard to comply with the procedures and

instructions issued for the project and to conform to the

requirements of this standard applicable to his work.

It is the responsibility of the organization performing these

activities to specify the detailed methods and procedures

unless they are specified in the contract documents.

See Intro to NQA-1-1994, Part II, for general information regarding Responsibility.

Similar requirements for responsibility are addressed in the Introduction to

Part II of NQA-1.

1.4 Definitions

The following definition is provided because it is used uniquely in this standard:

Generic Statement from the current VA QATR:

Definitions in the referenced standards in this table which are not included in ANSI N45.2.10 will be used as clarified

in the Company's commitment to Regulatory Guide 1.74.

Definitions are addressed in the Introduction to Part I of NQA-1.

Additional definitions are included in

the QAPD, Appendix D.

Construction Phase - The period of time beginning with the start of construction activity and ending as each plant area

is turned over to the plant operator.

Other terms and their definitions are contained in ANSI N45.2.10 1.5 Referenced Documents Other documents that are required to be included as a part of this standard are either identified at the point of

reference or identified in paragraph 5 of this standard.

NRC Regulatory Guide 1.39 , Position C.1 Subdivision 1.5 of ANSI N45.2.3-1973 states that other The QAPD addresses referenced documents.

05/27/04 Page 4 of 13 Housekeeping During the Construction Phase of Nuclear Power Plants N45.2.3-1973 Quality Assurance Requirements for Housekeeping for Nuclear Power Plants NQA-1 1994 Subpart 2.3 COMMENTS documents that are required to be included as a part of this standard are either identified at the point of reference or

identified in Paragraph 5 of the standard. The specific

acceptability of these listed documents has been or will be

covered separately in other regulatory guides and in

Commission regulations, where appropriate.

2. GENERAL REQUIREMENTS 2 GENERAL REQUIREMENTS This paragraph contains requirements that are to be fulfilled by the contractor who is responsible for performing any

segment of work described in paragraphs 3 and 4 of this

standard. Measures shall be established and implemented

for documenting housekeeping operations to verify

conformance to specified requirements.

Housekeeping activities shall include documented methods and techniques for control of the site area, the plant, and

the materials and equipment being incorporated in the plant

to preserve the requisite quality of the items being

constructed or installed.

Similar requirements.

2.4 Personnel

Qualifications All personnel working in zone controlled areas shall be familiar with the necessities and requirements for cleanness

control applicable to the various zones. Training programs

shall be utilized for this purpose where appropriate.

Personnel working in zone controlled areas shall be familiar with the necessities and requirements for cleanness control

applicable to the various zones. Training programs shall be

utilized for this purpose, where appropriate.

Similar requirements.

2.1 Planning

2.1 Planning and Procedures The work and the quality assurance requirements for the housekeeping activities at the nuclear power plant site shall

be delineated. The planned activities shall include the

methods and techniques for control of the site area, the

facilities, and the materials and equipment being

incorporated in the plant to preserve the requisite quality of

the items being constructed or installed. Necessary

procedures and work instructions that are needed to assure

compliance with the specified requirements shall be

identified and provisions shall be made for their preparation, approval, release, and control. Methods to be used for the

collection, handling, and disposition of records, data, and

reports shall be designated.

Planning and procedure preparation shall be in accordance with the requirements of the Introduction to this Part (Part

II); procedures and instructions shall contain sufficient

detail to provide for control of the site area, the plant, and

the materials and equipment being incorporated in the plant

to preserve the requisite quality of the item being

constructed or installed.

NQA-1 combines planning and procedures and contains less detail in

this section, but addresses procedures

for all the subparts in the Introduction

to Part II. The result is similar

requirements.

N45.2.1, § 2.1, ¶¶ 2-7 -The second paragraph of this section, the descriptions of the 5 Zones, and the Restriction List table is inserted following § 2.2, Procedures and The Zone descriptions and Restriction List are part of 2.1 Planning in

N45.2.3, but 2.2 Classification of 05/27/04 Page 5 of 13 Housekeeping During the Construction Phase of Nuclear Power Plants N45.2.3-1973 Quality Assurance Requirements for Housekeeping for Nuclear Power Plants NQA-1 1994 Subpart 2.3 COMMENTS Instructions to align with the text of NQA-1.

Cleanness in NQA-1.

N45.2.1, § 2.1, ¶ 8 regarding recording entry and exit of personnel and material is moved down to § 3.1 to align with the text of NQA-1.

2.2 Procedures

and Instructions The procedures and instructions for housekeeping practices shall be prepared and may be issued in segments to

conform with the project construction schedule. The first

segment establishing regulations for control of site area, site

preparation, fire prevention and protection, and records

shall be in force with the start of construction activity. The

remaining segments shall be prepared and approved no

later than the start of equipment installation work.

Clarification from the current VA QATR:

(1) Additional clarifications for ANSI N45.2.3-1973 are indicated below for specific Sections: Section 2.2 -

Procedures and Instructions

Appropriate procedures will be written and implemented.

Procedures and instructions providing for the control of site areas, site preparation, fire prevention and protection, and

records shall be in force with the start of the construction

activity. Other procedures and instructions shall be

prepared and approved no later than the start of equipment

installation work.

Similar requirements. The clarification from the VA QATR is not being

carried forward into the new QAPD.

2.2 Classification

of Cleanness N45.2.3, § 2.1, ¶2 -

Cleanness requirements for housekeeping activities shall be established on the basis of the following zone designations. Time for implementation of

the zone designations shall be as required by the

construction progress.

Clarification from the current VA QATR:

ANSI N45.2.3-1973 Section 2.1 -

Planning: The Company may choose not to utilize the five-level zone designation system, but will utilize standard janitorial and

work practices to maintain a level of cleanliness as

delineated in the Company's Nuclear Operations Industrial

Safety & Health Accident Prevention Manual which is

equivalent to the requirements contained in the referenced

section. Clarifications meet or exceed applicable guides and

standards. These clarifications are proposed to perform a

twofold function: (A) To translate construction criteria to Cleanness requirements for housekeeping activities shall be established on the basis of the following zone designations.

The timing for implementation of the zone designations shall

be as required by the need for cleanness.

Similar requirements. An alternative is proposed with the new QAPD

regarding not specifically using the

five-level zone designations, but

ensuring that an equivalent level of

cleanness control is maintained.

05/27/04 Page 6 of 13 Housekeeping During the Construction Phase of Nuclear Power Plants N45.2.3-1973 Quality Assurance Requirements for Housekeeping for Nuclear Power Plants NQA-1 1994 Subpart 2.3 COMMENTS operating plant oriented requirements. (B) To reflect experience gained at operational nuclear facilities. It should

be noted that where the Company does not specifically

implement requirements as delineated herein, the proposed

alternatives are reflected in written procedures and policy

and contain all necessary elements to assure quality is

maintained. Cleanliness will be maintained, consistent with

the work being performed, so as to prevent the entry of

foreign material into safety-related systems. This will

include, as a minimum, documented cleanliness inspections

which will be performed prior to system closure. As

determined by station management, (e.g., the size of the

opening would permit entry of the tools being used) control

of personnel, tools, equipment, and supplies will be

established when the reactor system is opened for

inspection, maintenance or repair. Additional housekeeping

requirements will be implemented as required for control of

radioactive contamination.

Zones Restriction List I II III IV V Clothing change Yes No No No No Clean gloves, shoe covers Yes Yes No No No head covering Filtered air Yes No No No No Material precleaning Yes No No No No Material accountability Yes Yes Yes No No Personnel accountability Yes Yes Yes No No No use of tobacco or eating Yes Yes Yes Yes No Zones Restriction List I II III IV V Clothing change Yes No No No No Clean gloves, shoe covers Yes Yes No No No head covering Filtered air Yes No No No No Material precleaning Yes Yes No No No Material accountability Yes Yes Yes No No Personnel accountability Yes Yes Yes No No No use of tobacco or eating Yes Yes Yes Yes No Zone Restriction II requires Material precleaning under NQA-1-1994.

Zone I - Areas requiring the highest order of cleanness and shall be equipped with a clean clothing change facility at the

vestibule or entrance, preferably with toilet facilities

immediately adjacent so that personnel working in the

controlled area do not have to wear the special clothing in

other areas. Such areas shall provide for complete outer

change of clothing by personnel, including use of shoe Zone I Areas requiring the highest order of cleanness shall be equipped with a clean clothing change facility at the vestibule or entrance. Such areas shall provide for complete

outer change of clothing by personnel, including the use of

shoe covers, head covers, and gloves to protect all

equipment surfaces from outside contamination. Material

entering this zone shall have been appropriately cleaned Similar requirements.

05/27/04 Page 7 of 13 Housekeeping During the Construction Phase of Nuclear Power Plants N45.2.3-1973 Quality Assurance Requirements for Housekeeping for Nuclear Power Plants NQA-1 1994 Subpart 2.3 COMMENTS covers, head covers, and gloves to protect all equipment surfaces from outside contamination. Material entering this

zone shall have been appropriately cleaned prior to entry as

specified in ANSI N45.2.1.

prior to entry.

Zone II - Intermediate cleanness requirements less restrictive than Zone I but where foreign matter may have

detrimental effects.

Zone II. Intermediate cleanness requirements less restrictive than Zone I, but where foreign matter may have

detrimental effects.

Similar requirements.

Zone III - Areas less restrictive than Zones I and II but requiring access control over personnel and materials.

Zone III. Areas less restrictive than Zones I and II, but requiring access control over personnel and materials.

Similar requirements.

Zone IV - Areas where it is desired to regulate the use of tobacco and eating for material and equipment protection or

for health and fire hazards.

Zone IV. Areas where it is desired to regulate the use of tobacco and eating of food for material and equipment protection or for health and fire hazards.

Similar requirements.

Zone V - Unrestricted construction areas requiring good construction site housekeeping practices only.

Zone V. Unrestricted construction areas requiring good construction site housekeeping practices only.

Similar requirements.

2.3 Results

Inspection and test results shall be documented in a suitable test report or data sheet. Each report shall identify the item

to which it applies, the procedures or instruction followed in

performing the task, and the identification of the following:

Similar requirements addressed in NQA-1, Part I and the Introduction to

Part II.1. Conditions encountered which were not anticipated, including nonconformance.

2. Identity of inspector or tester.

3. Completion date.

Test reports and data sheets shall include an evaluation of

the acceptability of inspection and test results and provide

for identifying the individual who performed the evaluation.

Similar requirements addressed in NQA-1, Part I and the Introduction to

Part II.3. REQUIREMENTS 3 REQUIREMENTS

3.1 Control

of Site Area

3.1 Control

of Site Area Areas for specific activities shall be assigned and regulated.

Areas which shall be designated include where appropriate

refuse and garbage dumps, refuse burning sites, storage

locations, parking lots, eating places, non-smoking areas, subcontractor work areas, common areas, and waste

collection container locations. Personnel entrance to Areas for specific activities shall be assigned and regulated.

Areas that shall be designated include, where appropriate, refuse and garbage dumps, refuse burning sites, storage

locations, parking lots, eating places, nonsmoking areas, subcontractor work areas, common areas, and waste

collection container locations. Personnel entrance to Similar requirements.

05/27/04 Page 8 of 13 Housekeeping During the Construction Phase of Nuclear Power Plants N45.2.3-1973 Quality Assurance Requirements for Housekeeping for Nuclear Power Plants NQA-1 1994 Subpart 2.3 COMMENTS controlled areas, admission of visitors to the work site, and identification of all personnel shall be regulated in

accordance with established procedures and regulations.

controlled areas, admission of visitors to the work site, and identification of all personnel shall be controlled in

accordance with established procedures and instructions.

N45.2.1, § 2.1, ¶ 8 - For Zones I, II, and III a written record of the entry and exit of all personnel and material shall be established and maintained.

For Zones I, II, and III a written record of the entry and exit of all personnel and material shall be established and

maintained Similar requirements.

Grading, drainage, roads, construction facilities, plant fencing, and utilities shall be provided in accordance with

specified requirements and shall be maintained as required

in good condition throughout the construction phase or until

replaced with the permanent facilities.

Grading, drainage, roads, construction facilities, plant fencing, and utilities shall be provided in accordance with

specified requirements and shall be maintained as required

in good condition throughout the construction phase or until

replaced with the permanent facilities.

Similar requirements.

3.2 Control

of Facilities

3.2 Control

of Facilities Control of work and storage areas where important items are handled shall be established and maintained to conform

to the appropriate zone defined in paragraph 2.1 of this

standard. Atmospheric control shall be provided where

necessary.

Control of work and storage areas where important items are handled shall be established and maintained to conform

to the appropriate zone defined in para. 2.2 of this Subpart.

Atmospheric control shall be provided where necessary.

Similar requirements.

The control of all tools, equipment, materials, and supplies that are used in Zones I, II, and III shall be maintained to

prevent the inadvertent inclusion of deleterious materials or

objects in critical systems. Appropriate control measures

shall be provided through utilization of such items as log

books and tethered tools.

Clarification from the current VA QATR:

Section 3.2 -

Control of Facilities

The Company may choose not to utilize the five-level zone designation system, but will utilize the Company's Nuclear Operations Industrial

Safety & Health Accident Prevention Manual to maintain a

level of cleanliness commensurate with the requirements of

this section. Cleanliness will be maintained, consistent with

the work being performed, so as to prevent the entry of

foreign material into safety-related systems. This will

include, as a minimum, documented cleanliness inspections

which will be performed prior to system closure. As

necessary, (e.g., the size of the opening would permit entry The control of tools, equipment, materials, and supplies that are used in Zones I, II, and III shall be maintained to

prevent the inadvertent inclusion of deleterious materials or

objects in critical systems. Appropriate control measures

shall be provided through utilization of such items as log

books and tethered tools.

Similar requirements.

An alternative is proposed with the

new QAPD regarding not specifically

using the five-level zone designations, but ensuring that an equivalent level of

cleanness control is maintained.

05/27/04 Page 9 of 13 Housekeeping During the Construction Phase of Nuclear Power Plants N45.2.3-1973 Quality Assurance Requirements for Housekeeping for Nuclear Power Plants NQA-1 1994 Subpart 2.3 COMMENTS of the tools being used) control of personnel, tools, equipment, and supplies will be established when major

portions of the reactor system are opened for inspection, maintenance or repair. Additional housekeeping

requirements will be implemented as required for control of

radioactive contamination.

3.2.1 Cleanness.

3.2.1 Cleanness.

The work areas shall be kept sufficiently clean and orderly that construction activity can proceed in an efficient

manner that will produce and maintain quality in

conformance with specified requirements. Where large

accumulations of materials occur on a nonroutine basis, such as the stripping of concrete forms, the material shall be promptly removed or stored neatly. Garbage, trash, scrap, litter, and other excess materials shall be collected, removed from the job site, or disposed of in accordance

with specified requirements or planned practices. Such

excess material shall not be allowed to accumulate and

create conditions that will adversely affect quality. The

disposal of cleaning chemicals shall be accomplished so

additional hazards are not created at the disposal site.

The work areas shall be kept sufficiently clean and orderly so that construction activity can proceed in an efficient

manner that will produce and maintain quality in

conformance with specified requirements. Where large

accumulations of materials occur on a nonroutine basis, such as the stripping of concrete forms, the material shall be promptly removed or stored neatly. Garbage, trash, scrap, litter, and other excess materials shall be collected, removed from the job site, or disposed of in accordance

with specified requirements or planned practices. Such

excess material shall not be allowed to accumulate and

create conditions that will adversely affect quality. The

disposal of cleaning chemicals shall be accomplished so

additional hazards are not created at the disposal site.

Similar requirements.

3.2.2 Environment.

3.2.2 Environment.

Areas of activity shall be adequately lighted, ventilated, protected, and accessible as appropriate for the work being

performed. Temporary lighting may be utilized but shall be

installed and maintained to provide good visibility.

Ventilation shall be provided where necessary to prevent

accumulation of dust, noxious fumes, and temperature

extremes. Adequate working space for construction

personnel shall be provided utilizing proper work stages and

platforms having accessibility by stairs or ladders. Barriers, screens, shields, restricted access, or other protection shall

be provided as necessary for isolation of areas where noise, welding arcs, dust, inclement weather, or other conditions

exist that may affect the quality of work being performed.

Areas of activity shall be adequately lighted, ventilated, protected, and accessible as appropriate for the work being

performed. Temporary lighting may be utilized but shall be

installed and maintained to provide good visibility.

Ventilation shall be provided where necessary to prevent

accumulation of dust, noxious fumes, and temperature

extremes. Adequate working space for construction

personnel shall be provided utilizing proper work scaffolds

and platforms having accessibility by stairs or ladders.

Barriers, screens, shields, restricted access, or other

protection shall be provided as necessary for isolation of

areas where noise, welding arcs, dust, inclement weather, or other conditions that may affect the quality of work Similar requirements.

05/27/04 Page 10 of 13 Housekeeping During the Construction Phase of Nuclear Power Plants N45.2.3-1973 Quality Assurance Requirements for Housekeeping for Nuclear Power Plants NQA-1 1994 Subpart 2.3 COMMENTS being performed.

3.2.3 Fire Protection and Prevention.

3.2.3 Fire Protection and Prevention.

Equipment and instructions for the protection from and prevention of, damage by fire shall be provided in

accordance with the NFPA National Fire Codes, Volume 4, Building Construction Facilities. Procedures or instructions

for fire protection shall include provisions for fighting fires

involving the use of available community fire departments, trained project brigades, and others. Procedures or

instructions shall include plans for provision of water

supplies, hydrants, automatic sprinklers, access for fire

fighting, and distribution of extinguishers and fire fighting

equipment.

NRC Regulatory Guide 1.39 , Position C.2 Subdivision 3.2.3 of ANSI N45.2.3-1973 includes general guidelines and requirements for fire protection and

prevention. The requirements and guidelines of Subdivision

3.2.3 are not considered a part of this regulatory guide, since this subject is addressed separately in more detail in

other NRC documents. Thus, a commitment to follow this

regulatory guide does not imply a commitment to follow the

guidelines and requirements of Subdivision 3.2.3.

Equipment and instruction for the protection from, and prevention of, damage by fire shall be provided in

accordance with the requirements of the NFPA National

Fire Codes. Procedures or instructions for fire protection

shall include provisions for fighting fires involving the use of

available community fire departments, trained project

brigades, and others. Procedures or instructions shall

include plans for provision of water supplies, hydrants, automatic sprinklers, access for fire fighting, and

distribution of extinguishers and fire fighting equipment.

Similar requirements.

Fire watches during and immediately following welding operations should be specified.

Fire surveillance during and immediately following operations such as welding and heat treating shall be

provided when materials are located such that flames, flying sparks, weld spatter, or excessive heat resulting from

the operation could cause combustion, with resulting

damage to items of the nuclear plant.

Fire watch/surveillance requirements are clarified in NQA-1-1994.

Fire protection facilities shall be in service beginning with the initial stages of permanent construction. Pre-fire

planning should be considered as a requirement of the fire

protection procedures or instructions which shall include

evacuation of confined areas.

Fire protection facilities shall be in service beginning with the initial stages of permanent construction. Pre-fire

planning shall be conducted as a requirement of the fire

protection procedures or instructions, which shall include

evacuation of confined areas.

Similar requirements.

3.3 Materials

and Equipment

3.3 Material

and Equipment Materials and equipment delivered to the work area shall be Materials and equipment delivered to the work area shall be Similar requirements. N45.2.2 is 05/27/04 Page 11 of 13 Housekeeping During the Construction Phase of Nuclear Power Plants N45.2.3-1973 Quality Assurance Requirements for Housekeeping for Nuclear Power Plants NQA-1 1994 Subpart 2.3 COMMENTS placed so that they are accessible but do not hinder construction progress. However, material and equipment

shall be so positioned that it will not be damaged by

construction activity.

The receiving, storage, and handling activities required by

this standard shall be performed as specified in ANSI

N45.2.2. The cleaning of important parts for the plant that

is necessary during these activities shall he performed as

specified in ANSI N45.2.1.

Clarification from the current VA QATR:

Section 3.3 -

Materials and Equipment

See Generic Statement which prefaces this table. (Copied on page 1 of this particular comparison table.)

so positioned, or protected when necessary, to assure that the quality of the item will not be degraded by the

construction activity. The cleaning of important materials

and equipment for the plant that is necessary during

receiving, storage, and handling activities shall be in

accordance with applicable requirements.

replaced with Subpart 2.2 of NQA-1.

Clarification not needed for the new

QAPD.3.4 Construction Tools, Supplies, and Equipment

3.4 Construction

Tools, Supplies, and Equipment The use, location, and deployment of construction tools, supplies, and equipment shall be regulated to keep access

and work areas clear and prevent conditions that will

adversely affect quality. These provisions shall include, but

are not limited to such items as the movement of materials

to the work area, welding and stress relieving leads, power

leads, temporary heating equipment, pumps, air and water

hoses, welding machines, air compressors, hoisting

equipment, air tools, grinding tools and burning tools.

Clarification from the current VA QATR:

Section 3.4 -

Construction Tools, Supplies and Equipment: See Generic Statement which prefaces this table.The use, location, and deployment of construction tools, supplies, and equipment shall be controlled to keep access

and work areas clear and to prevent conditions that will

adversely affect quality. These provisions shall include, but

are not limited to, such items as the movement of materials

to the work area, welding and stress relieving leads, power

leads, temporary heating equipment, pumps, air and water

hoses, welding machines, air compressors, hoisting

equipment, air tools, grinding tools, and burning tools.

Similar requirements.

Clarification not needed for the new

QAPD.3.5 Surveillance, Inspections, and Examinations

3.5 Surveillance

and Inspections Periodic inspection and examination of the work areas and the construction practices shall be performed at scheduled

intervals to assure adequacy of cleanness and

housekeeping practices. These inspections and

examinations shall include the following as appropriate:

Periodic inspection of work areas and construction practices shall be performed at scheduled intervals to

assure adequacy of cleanness arid housekeeping practices.

These inspections shall include the following, as

appropriate:

Similar requirements. Throughout subsection 3.5, the term examination is

not used in NQA-1 since it is a part of

inspection. The term inspection is

favored by the standard.

1. Examination of construction site roads, access ways, and ramps for conditions that may result in damage to items (a) inspection of construction site roads, access ways, and ramps for conditions that may result in damage to items Similar requirements.

Clarification not needed for the new 05/27/04 Page 12 of 13 Housekeeping During the Construction Phase of Nuclear Power Plants N45.2.3-1973 Quality Assurance Requirements for Housekeeping for Nuclear Power Plants NQA-1 1994 Subpart 2.3 COMMENTS being transported or handled.

Clarification from the current VA QATR:

Section 3.5 -

Surveillance, Inspections and Examination

Subparagraph (1) See Generic Statement which prefaces this table.

being transported or handled; QAPD.2. Examination of storage area for conformance to procedures and instructions in the following categories:

(a) adequacy of access control.

(b) evidence of damage or deterioration.

(c) adequacy of protection from fires, weather, movement

of equipment, and other factors that may result in damage

to stored items.

(d) adequacy of solvent storage facilities.(b), inspection of storage and work areas for conformance to procedures and instructions in the following categories:

(1) adequacy of access control

(2) evidence of damage or deterioration

(3) adequacy of protection from fires, weather, movement of equipment, and other factors that may result in damage to stored and installed items

(4) adequacy of hazardous chemicals, paints, and solvent

storage facilities Similar requirements.

Slightly more detail regarding

hazardous materials in NQA-1.

3. Inspection of work areas for maintenance of environmental conditions within specified limits.(c) inspection of work areas for maintenance of environmental conditions within specified limits; Similar requirements.

4. Surveillance over installed items to assure the adequacy of:

(a) maintenance of protection.

(b) preservation of precautionary signs.

(c) preservation of item identity.

(d) protection from fire, weather, movement of materials or

equipment and other factors which may result in damage to

installed items.(d) surveillance over installed items to assure the adequacy of:

(1) maintenance of protection

(2) preservation of precautionary signs

(3) preservation of item identity (4) protection from fire, weather, movement of materials or equipment, and other factors which may result in damage to

installed items.

Similar requirements.

Where these requirements duplicate the requirements of other standards such as ANSI N45.2.1, duplicate activities

and reports are not required.

Not a requirement.

4. RECORDS 4 RECORDS Copies of approved procedures, reports; personnel training and qualification records; controlled zone registry, fire and

accident investigations; and inspection and examination

records shall be prepared and placed with other project

records.

Final disposition of records shall be in accordance with

ANSI N45.2.9.

Record copies of procedures, reports, personnel qualification records, zone control registries, fire and

accident investigations, surveillance, and inspection records

shall be prepared as required in this Part (Part lI). These records shall be retained with other project records as required by code, standard, specification, or project

procedures.

Similar requirements.

ANSI N45.2.9 is replaced with Basic Requirements 17 and Supplemental Requirements

17S-1 for NQA-1.

05/27/04 Page 13 of 13 Housekeeping During the Construction Phase of Nuclear Power Plants N45.2.3-1973 Quality Assurance Requirements for Housekeeping for Nuclear Power Plants NQA-1 1994 Subpart 2.3 COMMENTS 5. REVISIONS OF AMERICAN NATIONAL STANDARDS REFERRED TO IN THIS

DOCUMENT When the following Standards referred to in this document are superseded by a revision approved by the American

National Standards Institute, the revision shall apply.

A10.2-1944 Safety Code for Building Construction

N45.2 Quality Assurance Program Requirements for

Nuclear Power Plants

N45.2.1 Cleaning of Fluid Systems and Associated

Components During the Construction Phase of Nuclear

Power Plants

N45.2.2 Packaging, Shipping, Receiving, Storage and

Handling of Items for Nuclear Power Plants (During the

Construction Phase)

N45.2.9 Requirements for Collection, Storage and

Maintenance of Quality Assurance Records

N45.2.10 Quality Assurance Terms and Definitions The QAPD addresses the standards for the program.

05/26/04 Page 1 of 26 Installation, Inspection, and Testing of Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations N45.2.4-1972/IEEE Std 336-1971 NQA-1 1994 Subpart 2.4 IEEE Standard Installation, Inspection, and Testing Requirements for Power, Instrumentation, and Control Equipment at Nuclear Facilities ANSI/IEEE Std 336-1985 COMMENTS Reg. Guide 1.30 8/72 Position C.1 states: .ANSI N45.2.4-1972 should be used in conjunction with ANSI N45.2-1971,"Quality Assurance Program Requirements for Nuclear Power

Plants." (It is expected that future revisions of ANSI N45.2.4-

1972 will include this provision.)

NQA-1-1994 is used with Part I of NQA-1-1994 that is

comparable to the Quality

Assurance Program

requirements of N45.2-1971.

1. INTRODUCTION

1. Introduction NQA-1, Subpart 2.4 consists of ANSI/IEEE Std. 336-1985

IEEE Standard Installation, Inspection, and Testing

Requirements for Power, Instrumentation, and Control

Equipment at Nuclear

Facilities.

1.1 Scope

1.1 Scope This standard sets forth the requirements for installation, inspection and testing of Class I and Class IE electric power, instrumentation and control equipment and systems during the

construction phases of a nuclear power generating station.

These requirements are intended to assure that only materials

and equipment of acceptable quality are incorporated into the

plant, that quality is maintained and quality workmanship

prevails throughout the construction process, and that

completed installations conform to specified requirements, so

as to promote public safety, prevent accidents and mitigate the

consequences of accidents if they occur, and provide a high

degree of plant reliability.

Reg. Guide 1.30 8/72 Position C.3 states: Although subdivision 1.1 of ANSI N45.2.4-1972 states that the requirements promulgated apply during the construction phase

of a nuclear power plant, these requirements are also to be

considered applicable for the installation, inspection, and testing

of instrumentation and electric equipment during the operation

phase of a nuclear power plant.

This standard sets forth the requirements for installation, inspection, and testing of power, instrumentation, and control

equipment and systems during the construction phase of a

nuclear facility. These requirements also cover modifications

and those operating phase activities that are comparable in

nature and extent to related initial construction activities of the

facility.The intent of this standard is to establish requirements for safety systems equipment. (Safety systems equipment is

defined in IEEE Std 603-1980 [5]1) However, this standard

may also be applied to non-safety systems equipment.

Similar requirements.

Regulatory Position

incorporated into the standard.

05/26/04 Page 2 of 26 Installation, Inspection, and Testing of Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations N45.2.4-1972/IEEE Std 336-1971 NQA-1 1994 Subpart 2.4 IEEE Standard Installation, Inspection, and Testing Requirements for Power, Instrumentation, and Control Equipment at Nuclear Facilities ANSI/IEEE Std 336-1985 COMMENTS The following is a clarification made in the current VA QATR: Regulatory Guide 1.30

- Quality Assurance Requirements for the Installation, Inspection, and Testing of Instrumentation and Electric Equipment (8/72). Endorses ANSI N45.2.4-1972 The Operational Quality Assurance Program complies with this guide with the following clarifications and alternatives:

(1) See Generic Statement which prefaces this table with

regard to construction related guides, standards, and instructions.

Generic Statement from the current VA QATR: For operations phase maintenance and modification activities which are comparable in nature and extent to similar activities

conducted during the construction phase, the Company shall

control these activities under this Operational Quality

Assurance Program. Designated modifications may be

controlled under a contractor's Quality Assurance Program

which has been approved by the Company's Quality

Assurance Program. When this Operational Quality Assurance

Program or an approved contractor's Quality Assurance

Program is used, the Company shall comply with the

Regulatory Position established in the guides listed herein in

that quality assurance programmatic/administrative

requirements included therein (subject to the clarification in this

table) shall apply to these maintenance and modification

activities even though such requirements may not have been in

effect originally. Maintenance or modifications which may

affect the function of safety related structures, systems, or

components shall be performed in a manner at least equivalent

to that specified in original design bases and requirements, materials specifications, and inspection requirements. A

suitable level of confidence in structures, systems, or

components on which maintenance or modifications have been

performed shall be attained by appropriate inspection and 05/26/04 Page 3 of 26 Installation, Inspection, and Testing of Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations N45.2.4-1972/IEEE Std 336-1971 NQA-1 1994 Subpart 2.4 IEEE Standard Installation, Inspection, and Testing Requirements for Power, Instrumentation, and Control Equipment at Nuclear Facilities ANSI/IEEE Std 336-1985 COMMENTS performance testing.

1.1.1 In addition to the Class I and Class IE systems, the requirements also apply to the following auxiliary equipment

that are a part thereof.

1) Connecting cables and raceways

2) Electric and instrumentation containment penetrations

3) Instrumentation sensing lines from the process root valves to

and including input transducers

4) Primary sensing devices (for example, orifices, flow nozzles, venturi tubes, and reference columns)

5) Pneumatic instrumentation

6) Output control transducers including tubing and piping

7) Fluid systems associated with standby generators and

transformer cooling systems

8) Switchgear fluid systems

9) Panels, enclosures, and mountings This specific list is not included in the 1985 edition, but the above paragraph

addresses safety systems

equipment that, based on the

definition referenced, would

include the items in this list.

1.1.2 These

requirements may also be extended to other appropriate parts of nuclear power generating stations when specified in

contract documents.

Not a requirement.

1.1.3 1.1.1 This standard does not set forth specific requirements for the following, though related to the above equipment and systems:

1) Inspection or testing, or both, of welds

2) Cleaning and flushing of instrument sensing lines

3) Aligning or verifying alignment, or both, of Class I rotating

equipment

4) Verifying structural integrity of support for Class I or Class

IE electric equipment

For applicable codes on the above refer to Section 9.

This standard does not set forth specific requirements for the following, though they are related to the above equipment and

systems

1) Installation, inspection, and testing of welds

2) Cleaning and flushing of instrument sensing lines

3) Aligning or verifying alignment, or both, of rotating

equipment

4) Verifying structural integrity of supports for equipment

5) Activity governed by Section III of [6]

6) Preoperational tests of the integrated systems and

equipment Similar exclusions, these items are addressed by other

standards or the QAPD.

05/26/04 Page 4 of 26 Installation, Inspection, and Testing of Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations N45.2.4-1972/IEEE Std 336-1971 NQA-1 1994 Subpart 2.4 IEEE Standard Installation, Inspection, and Testing Requirements for Power, Instrumentation, and Control Equipment at Nuclear Facilities ANSI/IEEE Std 336-1985 COMMENTS 7) Periodic testing and maintenance after initial operation

8) Receiving inspection and test

9) Non-destructive examination when required

1.1.2 During

the construction phase and when modifications are being performed, this standard shall be used in conjunction with

the applicable portions of ANSI/ASME NQA-l-1983 [l] and

ANSI/ASME NQA-2-1983 [2]. During the operations phase

this standard shall be used with the applicable portions of

ANSI/ANS 3.2-1982 [3]. The numbers in brackets

correspond to those of the references listed in Section 2.

NQA-1-1994 replaces NQA-1-1983 and NQA-2-1983 for

the Dominion QAPD

In addition, Dominion's

commitment to other

standards is addressed in the

QAPD, Appendix C.

1.2 Applicability

1.2 Applicability The requirements set forth in this standard apply to the work of any organization that participate in the construction phase of

electric and instrumentation equipment and systems from the

time that the equipment is turned over to the installers until the

time it is integrated into systems in a condition to commence

system performance testing. The requirements of this standard

are basic minimum requirements which relate to nuclear power

generating stations during construction or construction phases

of modification or expansion. For supplementary requirements

applicable to the construction phase of multi-unit stations, including expansions to existing stations, refer to Appendix A.

The requirements set forth in this standard apply to the work of any organization that participates in the installation, inspection, testing, or modification of power, instrumentation, and control

equipment and systems in a nuclear facility from the time that

the equipment is turned over for installation until it is integrated

into a system. The extent to which the individual requirements

of this standard apply either wholly or in part depends upon the

nature and scope of the work to be performed and the

importance of the item or service involved.

Similar requirements.

Supplementary requirements

for construction of multi-unit

stations and operating plants is

addressed in Section 10 of the

1985 edition.

1.3 Responsibility

1.3 Responsibility The organization or organizations responsible for establishing the applicable requirements for the activities covered by this

standard shall be identified, and the scope of their

responsibilities shall be documented. The work of establishing

practices and procedures and providing the resources in terms

of personnel, equipment and services necessary to implement

the requirements of this standard, may be delegated to other It is the responsibility of the organization invoking this standard to identify the equipment and systems to which this standard is

applicable. The planning operations stipulated in Section 3.2

shall specify the inspections and tests to be performed on the

identified equipment and systems consistent with this standard.

The work of establishing practices and procedures and

providing the resources, in terms of personnel, equipment, and Similar requirements.

05/26/04 Page 5 of 26 Installation, Inspection, and Testing of Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations N45.2.4-1972/IEEE Std 336-1971 NQA-1 1994 Subpart 2.4 IEEE Standard Installation, Inspection, and Testing Requirements for Power, Instrumentation, and Control Equipment at Nuclear Facilities ANSI/IEEE Std 336-1985 COMMENTS organizations, and such delegation also shall be documented. It is the responsibility of each organization participating in site

construction activities to comply with procedures and

instructions issued for the project.

services, to implement the requirements of this standard, may be delegated to other organizations. Such delegation shall be

documented. In any case, the organization invoking this

standard shall retain responsibility for overall program

effectiveness.

1.4 Definitions

The following definitions are provided to assure a uniform understanding of select terms as they are used in this standard.

NQA-1 contains definitions in Part I, Introduction.

Class I Equipment - Equipment that is essential to the safe shutdown and isolation of the reactor or whose failure or damage could result in significant release of radioactive

material.Class IE Electric Systems - The systems that provide the electric power used to shut down the reactor and limit the release of radioactive material following a design basis event.

System Performance Testing - Tests performed on completed systems, including all their electric, instrumentation, controls, fluid and mechanical subsystems under normal or

simulated normal process conditions of temperature, flow, level, pressure, etc.

Set Point - A predetermined level at which a bistable device changes state to indicate that the quantity under surveillance has reached the selected value.

Lay-Up - Idle condition of equipment and systems during and after installation, with protection measures applied as appropriate.

1.5 Referenced

Documents

2. References Other documents that are required to be included as a part of this standard, as well as the issue or edition of such documents, are either identified at the point of referenced or described in

Section 9 of this standard.

When the following standards referred to in this document are superseded by a revision approved by the American National

Standards Institute, the revision is not mandatory until it has

been incorporated as part of this standard.

[1] ANSI/ASME NQA-1-1983, Quality Assurance Program

Requirements for Nuclear Power Plants .

Commitment to specific editions of standards is

controlled through the QAPD.

05/26/04 Page 6 of 26 Installation, Inspection, and Testing of Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations N45.2.4-1972/IEEE Std 336-1971 NQA-1 1994 Subpart 2.4 IEEE Standard Installation, Inspection, and Testing Requirements for Power, Instrumentation, and Control Equipment at Nuclear Facilities ANSI/IEEE Std 336-1985 COMMENTS[2] ANSI/ASME NQA-2-1983, Quality Assurance Requirements for Nuclear Power Plants.

[3] ANSI/ANS 3.2-1982, Administrative Controls and Quality

Assurance for the Operational Phase of Nuclear Power

Plants.

[4] IEEE Std 498-1985, IEEE Standard Requirements for the

Calibration and Control of Measuring and Test Equipment

Used in the Construction and Maintenance of Nuclear Power

Generating Stations.

[5] IEEE Std 603-1980, IEEE Standard Criteria for Safety

Systems for Nuclear Power Generating Stations.

[6] 1984 ASME Boiler and Pressure Vessel Code.

2. GENERAL REQUIREMENTS

3. General Requirements Measures shall be established and implemented for documenting installation, inspection, and testing operations to

verify conformance to specified requirements.

Measures shall be established and implemented for planning and control of installation, inspection, and testing activities to

verify conformance to specified requirements.

Similar requirement.

2.2 Prerequisites

3.1 Prerequisites The following conditions shall have been met as required by other standards before the requirements set forth in this

standard are applied.

Not specifically addressed in the 1985 standard.

1) Qualification of personnel assigned to the construction phase has been in accordance with the requirements of appropriate

codes and standards.

Section 3.7 of the 1985 standard covers Personnel Qualification

2) Systems have been designed and engineered and equipment has been specifi ed in accordance with the published applicable standards and specifically within the framework of the Quality Assurance program described in the Safety Analysis Report.

Not specifically addressed in the 1985 standard.

3) Materials have been selected, and equipment has been fabricated and shop assembled, in accordance with the

specifications and the applicable published codes and

standards, the conformance to which has been demonstrated

by the manufacturer.

Not specifically addressed in the 1985 standard.

05/26/04 Page 7 of 26 Installation, Inspection, and Testing of Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations N45.2.4-1972/IEEE Std 336-1971 NQA-1 1994 Subpart 2.4 IEEE Standard Installation, Inspection, and Testing Requirements for Power, Instrumentation, and Control Equipment at Nuclear Facilities ANSI/IEEE Std 336-1985 COMMENTS 4) Materials and equipment have been shipped, received, handled and stored in accordance with the requirements of

applicable codes, standards, and manufacturers'

recommendations to preserve their integrity and prevent

physical, mechanical, and/or electrical damage.

Not specifically addressed in the 1985 standard.

5) The following documents relating to the specific equipment to be installed are available at the construction site The following applicable documents relating to the specific equipment to be installed shall be available in legible form at a

predetermined retention area or area of usage.

Similar requirement.

a) The latest applicable approved-for construction drawings b) Installation specifications

c) Manufacturers' instructions

d) Evidence of compliance by manufacturer with purchase

requirements including quality assurance requirements

e) Records of inspections and tests during on-site storage and

handling.1) The latest applicable approved-for-construction drawings

2) Installation specifications

3) Manufacturers' instructions

4) Evidence of compliance by manufacturer with purchase

requirements, including quality documentation

5) Records of inspections and tests during receiving and on-site

storage, handling, and maintenance.

Similar requirement.

2.1 Planning

3.2 Planning The installation, inspection, and testing activities shall be planned and outlined to define the operations to be used and

the systematic, sequential progression of operations for each

item or system, the responsibilities of parties concerned for

each operation, and the measures employed to preserve the

quality of equipment. Planning shall take into account the need

for the preparation and control of procedures and work

instructions as necessary to comply with the requirements for

installation, inspection, and testing of components and systems.

Planning shall include a review of the system, and component

design specifications and drawings, and of the construction

work plans and schedules, to assure that installation, inspection

and testing activities have been incorporated, and that they can

be accomplished as specified, and that time and resources are

sufficient to accomplish the required actions.

The installation, inspection, and testing activities shall be performed in accordance with documented plans that define

the operations to be used, the systematic, sequential

progression of operations for each item or system, the

responsibilities of parties concerned for each operation, and the

measures employed to preserve the quality of equipment.

Planning shall take into account the need for the preparation

and control of procedures and work instructions necessary to

comply with the requirements for installation, inspection, and

testing of equipment and systems. Planning shall include a

review of the system and equipment specifications and

drawings and of the construction work plans and schedules to

assure that installation, inspection, and testing activities have

been incorporated and that they can be accomplished as

specified.

Similar requirement.

The following is a clarification made in the current VA QATR: (2) Section 2.1 -

Planning requirements, as This clarification is not required to be carried forward

to the new QAPD. It is 05/26/04 Page 8 of 26 Installation, Inspection, and Testing of Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations N45.2.4-1972/IEEE Std 336-1971 NQA-1 1994 Subpart 2.4 IEEE Standard Installation, Inspection, and Testing Requirements for Power, Instrumentation, and Control Equipment at Nuclear Facilities ANSI/IEEE Std 336-1985 COMMENTS determined by station management, will be incorporated into maintenance and modification procedures. Clarifications and

alternatives meet or exceed applicable guides and standards.

These clarifications to ANSI N45.2.4-1972 are required to

ensure that QA program continuity is maintained. In actuality

these clarifications have been extracted from other standards

and guides and are considered more conservative. These

clarifications also insure that only one standard or guide is

committed to for its applicable circumstance covered by Subsection 1.3 of the standard.

2.3 Procedures

and Instructions

3.3 Procedures

and Instructions Installation, inspection, and test procedures and work instructions shall be prepared and documented for those

activities falling within the scope of this standard.

Procedures shall be prepared and documented as determined by the planning in 3.2. These procedures and instructions may

be in the form of manuals or drawings.

Similar requirement.

These documents shall be kept current and revised as necessary to assure that installation, inspections, and tests are

performed in accordance with latest information and shall

include as appropriate:

These documents shall be kept current by controlled supervision so that installation, inspections, and tests axe

performed in accordance with the latest approved design and

manufacturers' instructions. The documents shall include or

reference:

Similar requirement.

(1) Installation specifications (2) Inspection and test objectives

(3) Precautions to avoid component or system damage during

testing or inspection

(4) Inspection and test equipment required

(5) Sequence of tests (if applicable)

(6) Sequential actions to be followed

(7) Frequency of inspection or test

(8) Prerequisites

(9) Approvals

(10) Data report form

(11) Identification of test equipment and date of required

recalibration where required for interpretation of test results

(12) Inspection and test acceptance limits

1) Installation specifications

2) Inspection and test objectives

3) Precautions to avoid equipment or system damage during

installation, testing, or inspection

4) Inspection and test equipment required

5) Sequence of tests

6) Sequential actions to be followed

7) Frequency of inspection or test

8) Test prerequisites

9) Appropriate approvals

10) Suitable form for reporting data

11) Provision for identification of test equipment and date of

next required recalibration (where required) for interpretation of test results

12) Inspection and test acceptance limits

13) References Similar requirement, references and other pertinent

items are added to the list.

05/26/04 Page 9 of 26 Installation, Inspection, and Testing of Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations N45.2.4-1972/IEEE Std 336-1971 NQA-1 1994 Subpart 2.4 IEEE Standard Installation, Inspection, and Testing Requirements for Power, Instrumentation, and Control Equipment at Nuclear Facilities ANSI/IEEE Std 336-1985 COMMENTS 14) Other pertinent items The above items shall be included as a checklist and shall be marked as required or not appropriate when preparing

procedures or instructions.

New requirement. Alternative proposed to administrative

controls in procedures and

instruction in lieu of a

checklist.

2.4 Results

3.4 Results Inspection and test results shall be documented in a suitable test report or data sheet. Each report shall identify the item to

which it applies, the procedures or instruction followed in

performing the task, and the identification of the following:

Inspection and test results shall be documented in a suitable test report or data sheet. Each report shall identify the item to

which it applies, the procedures or instructions and its revision

number used in performing the task, and the identification of

the following:

Similar requirement.

1) Conditions encountered which were not anticipated, including nonconformance

2) Identity of inspector or tester

3) Completion date

1) Conditions encountered that were not anticipated, including nonconformance

2) Identity of inspector or testor 3) Completion date Similar requirement.

Test reports and data sheets shall include an evaluation of the acceptability of inspection and test results and provide for

identifying the individual who performed the evaluation.

Test reports or data sheets shall include an evaluation of the acceptability of the results and provide for identifying the

individual who performed the evaluation.

Similar requirement.

2.5 Measuring

and Test Equipment

3.5 Measuring

and Test Equipment

2.5.1 Selection

.Inspection and testing equipment with acceptable accuracy for performing the required function shall be selected. When

general voltage levels, flow directions, or other parameters are

checked, an instrument without high precision may be used.

When characteristics, efficiencies, capabilities, or other

properties are measured to appraise compliance with

specifications, the instrument must have adequate accuracy to

determine the measured quantity to the precision required by

the stated limits of the specifications. Use shall be made of

approved industry standards relating to measuring procedures.

Test equipment and/or apparatus supplying electrical, mechanical, or other test inputs shall have adequate capacity Measuring and test equipment used to determine compliance with specifications shall be controlled in accordance with the

requirements of IEEE Std 498-1985 [4].

NQA-1 addresses M&TE in Subpart 2.16 (IEEE Std 498-

1985).

05/26/04 Page 10 of 26 Installation, Inspection, and Testing of Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations N45.2.4-1972/IEEE Std 336-1971 NQA-1 1994 Subpart 2.4 IEEE Standard Installation, Inspection, and Testing Requirements for Power, Instrumentation, and Control Equipment at Nuclear Facilities ANSI/IEEE Std 336-1985 COMMENTS and be compatible with items under test so that the results will not be distorted.

2.5.2 Calibration

and Control

.Measuring and test equipment used to determine compliance with specifications, shall be adjusted and calibrated at

prescribed intervals against certified equipment having known

valid relationships to nationally recognized standards. If no

national standards exists, the basis for calibration shall be

documented. Records of the calibrations shall be maintained

and equipment suitably marked to indicate date of next

required calibration. When inspection and testing equipment

are found to be out of calibration, an evaluation shall be made

of the validity of previous inspection or test results and of the

acceptability of items previously inspected or tested. Test

equipment found to be out of calibration shall be clearly

identified as such.

NQA-1 addresses in Subpart 2.16.2.6 Nonconforming Items

3.6 Nonconforming

Items Defects, deficiencies, discrepancies, or other nonconforming situations shall be resolved in accordance with established

procedures. These procedures shall provide for identifying, documenting, and obtaining authorization for resolving each

nonconforming situation.

Defects, deficiencies, discrepancies, or other nonconforming situations shall be resolved in accordance with established

procedures. These procedures shall provide for identifying, documenting, and obtaining authorization for resolving each

nonconforming situation.

Similar requirement.

3.7 Personnel

Qualification Personnel performing the verifications required by this standard shall be qualified in accordance with an approved

quality assurance program.

Qualification is a prerequisite under N45.2.4, Subsection

2.2, item 1.

3. PRECONSTRUCTION VERIFICATION

4. Preinstallation Verification While it is recognized that the requirements for initial receipt inspections and storage are covered by another standard, ANSI N45.2.2, it is necessary to verify that the quality of an

item has not suffered during the interim period. It is not

intended to duplicate inspections but rather to verify that items

are in a satisfactory condition for installation. The verification Verifications shall be performed just prior to installation.

05/26/04 Page 11 of 26 Installation, Inspection, and Testing of Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations N45.2.4-1972/IEEE Std 336-1971 NQA-1 1994 Subpart 2.4 IEEE Standard Installation, Inspection, and Testing Requirements for Power, Instrumentation, and Control Equipment at Nuclear Facilities ANSI/IEEE Std 336-1985 COMMENTS shall include:

2. Verification that approved procedures, instruction manuals, and/or any special work instructions if required for specific

equipment are available

1) The following, relating to the specific equipment to be installed, shall be available at the construction site in legible

form:

a) The latest applicable approved-for-construction drawings

b) Installation specifications, procedures, or any special work

instructions Similar requirements, 1985 edition includes construction

drawings and removes

approved instruction manuals.

1. Verification that materials and equipment received by the installers are identified in accordance with the latest approved-

for construction drawings, equipment lists, and specifications

2) Identification of materials and equipment in accordance with the latest approved-for-construction drawings, equipment lists, and specifications Similar requirements.

3. Checking of records of protective measures maintained during storage for conformance to storage requirements

3) Documentation of protective measures taken during storage Similar requirements.

4. Visual examination of materials and equipment to assure physical integrity such as absence of physical damage, rust or

corrosion, contact contamination, and condensation

4) Physical integrity by visual examination of materials and equipment for damage, corrosion, contamination, and

condensation Similar requirements.

The following is a clarification made in the current VA QATR: (3) Section 3 -

Preconstruction Verification

(a)verification is required only for the modification(s) (b) will be implemented with the clarification that "approved instruction

manuals" shall be interpreted to mean the manuals provided by

the supplier as required by the procurement order. These

manuals will not be reviewed and approved, per se, by the

Company; (c) no special checks will be made by the person

withdrawing a replacement part from the warehouse-

equivalent controls are assured by compliance with ANSI

N45.2.2 as set forth in this table; and (d) will be complied with, as determined by station management as part of the

maintenance/modification program.

Based on the requirements of the new standard, this

clarification is not needed for

the new QAPD.

4. INSTALLATION

5. Installation

5.1 Equipment

Placement Equipment shall be located, installed, assembled, and/or connected in strict accordance with the following as applicable:

Equipment shall be located, installed, assembled, and connected in strict accordance with the following:

Similar requirements.

05/26/04 Page 12 of 26 Installation, Inspection, and Testing of Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations N45.2.4-1972/IEEE Std 336-1971 NQA-1 1994 Subpart 2.4 IEEE Standard Installation, Inspection, and Testing Requirements for Power, Instrumentation, and Control Equipment at Nuclear Facilities ANSI/IEEE Std 336-1985 COMMENTS 1. Latest approved-for-construction drawings

2. Manufacturers' instructions

3. Installation specifications and procedures

1) Latest approved-for-construction drawings

2) Installation specifications and procedures, where required by

the planning of 3.2 Similar requirements.

The following is a clarification made in the current VA QATR: Section 4 -

Installation

instructions will be implemented by inclusion, as determined by station management, in the appropriate maintenance or modification

procedure for safety-related items. Standard Company

maintenance practices require that care be exercised in the six

areas listed whether a procedure is required or not.

Clarification not needed for the new QAPD.

5.2 Precautions

Care shall be especially exercised in following the provisions of the above documents for operations such as:

1. Cable pulling

2. Cable splicing

3. Cable terminating

4. Cable routing including maintaining required separation

between redundant systems

5. Tagging and/or identifying various items including cable

6. Installing electric and instrumentation penetration assemblies

and assuring the integrity of the containment seals Care shall be exercised in following the provisions of the documents listed in 5.1 for operations such as:

1) Cable pulling

2) Cable splicing

3) Cable terminating

4) Cable and instrument sensing line routing, including

maintenance of required separation between redundant

systems

5) Tagging or identifying, or both, various items, including

cable, and temporary conditions

6) Installing electric and instrumentation penetration assemblies

and assuring the integrity of the containment seals

7) Installation of fire stops and fire barriers

8) Installation of instrumentation piping or tubing

9) Mounting and supporting of equipment

10) Removal of temporary shipping supports and holddown bolts 11) Installation of environmental and pressure seals Similar requirements, but the 1985 edition has been updated

to include additional

appropriate items based on

operating experience and

regulatory requirements.

5. VERIFICATION DURING CONSTRUCTION

6. Verification During Installation Verification during installation shall include inspections and tests performed in accordance with the QA program

requirements.

In context with the below subsections, this is similar to

the N45.2.4 standard.

05/26/04 Page 13 of 26 Installation, Inspection, and Testing of Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations N45.2.4-1972/IEEE Std 336-1971 NQA-1 1994 Subpart 2.4 IEEE Standard Installation, Inspection, and Testing Requirements for Power, Instrumentation, and Control Equipment at Nuclear Facilities ANSI/IEEE Std 336-1985 COMMENTS 5.1 Inspections

6.1 Inspections

Surveillance of construction activities shall include inspections of the work areas in progress to assure conformance to

applicable requirements. Inspections shall include the following, as appropriate:

Inspections performed during installation shall include the following: Similar requirement, reference to surveillance is omitted and

just the term inspection is

used.5.1.1 Inspections to Verify Correctness of Installation

.6.1.1 Inspections to Verify Correctness of Installation Inspection shall be made to verify, that equipment is being located, installed, assembled, and/or connected to comply with

latest approved-for-construction drawings, manufacturers'

instructions, and installation specifications.

Inspections shall be performed to verify that equipment is being located, installed, assembled, and connected to comply with

latest approved-for-construction drawings and installation

specifications and procedures.

Similar requirement.

Such inspections shall include, as appropriate, verification of:

(1) Leveling and alignment

(2) Clearances and tolerances

(3) Proper location and routing of cables and sensing lines

(4) Tightness of connections and fastenings

(5) Freedom of movement

(6) Correct polarity

(7) Proper grounding

(8) Terminations

(9) Fluid levels and pressures

(10) Absence of leaks

(11) Physical integrity

(12) Identifications Inspections shall include such items as verification of:

1) Leveling and alignment (nonrotating equipment)

2) Clearances and tolerances

3) Location, support, and routing of cables and sensing lines

4) Tightness of connections and fastenings and use of proper

tools

5) Freedom of movement

6) Polarity

7) Grounding and shielding

8) Terminations

9) Fluid levels and pressures

10) Absence of leaks

11) Physical integrity

12) Identifications

13) Circuit fusing

14) Equipment rating

15) Fire stops and fire barriers

16) Installation of mountings and supports

17) Lubrication of bearings

18) Environmental and pressure seals Similar requirement, but the 1985 edition includes

additional items that are

representative of industry

operating experience.

5.1.2 Inspections

to Verify Housekeeping

6.1.2 Inspections

to Verify Housekeeping and Protective Measures Inspections shall be made to verify adequacy of housekeeping, Inspections shall be performed to verify the adequacy of Similar requirement, the 1985 05/26/04 Page 14 of 26 Installation, Inspection, and Testing of Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations N45.2.4-1972/IEEE Std 336-1971 NQA-1 1994 Subpart 2.4 IEEE Standard Installation, Inspection, and Testing Requirements for Power, Instrumentation, and Control Equipment at Nuclear Facilities ANSI/IEEE Std 336-1985 COMMENTS in work areas. Adequacy of barriers and protection covers shall be evaluated to assure that items will not be damaged as

a result of adjacent construction activity. Adequacy of

protection measures shall be evaluated to assure that

equipment being used for testing will not be damaged.

housekeeping in work areas [2]. Inspections shall be performed on a regular schedule and properly documented to

verify that the following protective measures are adequate.

1) Protective measures applied for lay-up during construction

are in accordance with procedures or specifications

2) Protective measures to prevent damage as a result of

adjacent activity

3) Protective measures to prevent damage to measuring and

test equipment during field use standard more detail on the inspection requirements.

5.1.3 Inspection

of Temporary Conditions

.6.1.3 Inspections of Temporary Conditions Inspections shall be made to verify adequacy of protective measures applied for lay-up during construction. All temporary

connections, such as jumpers and bypass lines, and temporary

set points of control equipment shall be clearly identified and

documented so that subsequent restoration can be ascertained

prior to placing the item in service.

Inspections shall be performed to verify that all temporary connections, such as jumpers and bypass lines and temporary

setpoints of control equipment, are clearly identified and

documented so that subsequent restoration can be ascertained

prior to placing the item in service.

Similar requirement, protective measures

addressed in 6.1.2 above for

the 1985 standard.

The following is a clarification made in the current VA QATR: Section 5.1 -

Inspections

including subsections 5.1.1, 5.1.2, and the first sentence in 5.1.3, will be implemented as set forth in Section 17.2.10 of the Operational QA Program.

The inspection program will incorporate, as determined by

station management, those items listed in these subsections.

The remaining sentence in 5.1.3 is covered in equivalent detail

in the Company's commitment to ANSI N18.7, section 5.2.6;

the requirements as set forth in that commitment will be

implemented in addition to the requirements stated here.

Clarification deemed not necessary for the new

QAPD. Inspections will be

conducted in accordance with

the planning requirements of

the standard and the

inspection program

commitment.

5.2 Tests

6.2 Tests Surveillance of construction activities shall include tests performed in accordance with written test procedures to verify

that items being installed comply with specified quality and

performance requirement. These tests should be performed at

appropriate points in the construction phase as access permits

or when questions arise as to the quality of components or Manufacturers' tests on fabricated items may be accepted for equipment not disturbed during the construction phase. Tests

performed during installation shall be those specified in the

planning in 3.2 and shall include a selection of the following.

The 1985 standard is not as specific about the tests, rather

it refers back to those

identified during planning.

05/26/04 Page 15 of 26 Installation, Inspection, and Testing of Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations N45.2.4-1972/IEEE Std 336-1971 NQA-1 1994 Subpart 2.4 IEEE Standard Installation, Inspection, and Testing Requirements for Power, Instrumentation, and Control Equipment at Nuclear Facilities ANSI/IEEE Std 336-1985 COMMENTS workmanship. Where preliminary operation of equipment, during construction, is utilized for a testing function, the

purpose of the test, its scope, and results shall be clearly

established and documented. Tests shall be repeated if

construction or associated activity affects the results of the

tests. The need to repeat a test shall be ascertained at the time

of preparing for post construction testing in accordance with

6.2.The following is a clarification made in the current VA QATR: Section 5.2 -

Tests: including subsections 5.2.1 through 5.2.3, will be implemented as set forth in Sections 17.2.3 and .11 of the Operational QA Program. The test

program will consider the elements outlined in this Section, as

determined by station management, when developing test

requirements for inclusion in maintenance and modification

procedures. In some cases, testing requirements may be met

by post-installation surveillance testing in lieu of a special post-

installation test. Where elements of Section 5.2 are not being

met they shall be documented and justified.

Clarification deemed not necessary for the new

QAPD. Tests will be

conducted in accordance with

the planning requirements of

the standard and the test

program commitment.

Tests during construction shall include the following:

5.2.1 Electrical

Tests.

6.2.1 Electrical

Tests The following electrical tests shall be performed:

1. Tests to ascertain circuit continuity, absence of short

circuits, correct polarity and correct direction of rotation

2. Tests to ascertain proper functioning of systems, including

indicating meters, recorders, transducers, targets and lamps, enunciators and alarms, controls and interlocks

3. Voltage breakdown tests on liquid insulation

4. Over-potential tests as specified

5. Insulation resistance measurements as specified When over-

potential tests are performed, the values shall conform to the

applicable codes and standards. The manufacturers

recommendations shall always be considered.

1) Tests to ascertain circuit continuity, absence of improper grounds and short circuits, correct polarity and correct

direction of rotation

2) Tests to ascertain proper phasing and functioning of

equipment, including indicating meters, recorders, transducers, targets and lamps, annunciators and alarms, controls, interlocks, protective relays and breakers

3) Voltage breakdown tests on fluid insulation

4) Overpotential tests as specified

5) Insulation resistance measurements as specified When overpotential tests are performed, the manufacturers' recommendations shall be considered.

Similar requirement.

05/26/04 Page 16 of 26 Installation, Inspection, and Testing of Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations N45.2.4-1972/IEEE Std 336-1971 NQA-1 1994 Subpart 2.4 IEEE Standard Installation, Inspection, and Testing Requirements for Power, Instrumentation, and Control Equipment at Nuclear Facilities ANSI/IEEE Std 336-1985 COMMENTS 5.2.3 Physical and Chemical Tests

.6.2.2 Physical and Chemical Tests These tests shall include, as appropriate:

1. Chemical analyzing of fluids for oxygen or moisture content

and purity

2. Radiation sensitivity testing to confirm that radiation sensors

and controlling devices are properly functioning These tests

shall be in accordance with the applicable codes in Appendix

B.1) Chemical analysis of fluids for oxygen or moisture content and purity

2) Radiation testing to confirm that radiation sensors and

controlling devices are properly functioning.

Similar requirement.

5.2.2 Mechanical

Tests

.6.2.3 Mechanical Tests Mechanical tests shall be performed to ascertain that electric and/or instrumentation components or systems can withstand

systems pressure ratings. As a minimum, such tests shall be

applied to pressure sensing and transmitting devices operating

in steam, hydraulic, and vacuum systems and their hydraulic or

pneumatic interconnecting piping or tubing and associated

instruments. Pressurized equipment which is a part of electric

apparatus such as heat exchangers, circulating systems, actuating systems, and electric and instrumentation

containment penetrations shall likewise be tested if site

assembled or fabricated. Manufacturer's tests on fabricated

items may be accepted for equipment not disturbed during the

construction phase. These tests shall be in accordance with the

applicable codes and standards. If equipment is assembled at

the construction site, tests shall be conducted after the

assembly is completed even though the components may have

been previously tested.

Leak or flow tests shall be performed to demonstrate the operation of electric instrumentation equipment or systems. As

a minimum, such tests shall be applied to pressure sensing and

transmitting devices operating in steam, hydraulic, or pneumatic

interconnecting piping or tubing and associated instruments to

ascertain that they can withstand systems pressure ratings.

Pressurized equipment that is a part of electric apparatus, such

as heat exchangers, circulating systems, actuating systems, and

electric and instrumentation containment penetrations, shall be

tested.Similar requirement.

Manufacturers test statement

is addressed in Section 6.2 of

the 1985 standard.

6. POST-CONSTRUCTION VERIFICATION

7. Post-Installation Verification

6.1 Inspection

7.1 Inspections Installed equipment and systems shall be inspected to verify the following:

1. That equipment and materials have not sustained damage

during installation

2. That good and proper workmanship has prevailed Installed equipment and systems shall be inspected to verify that:

1) Equipment and materials have not sustained damage during

installation

2) Good and proper workmanship has prevailed Similar requirement.

05/26/04 Page 17 of 26 Installation, Inspection, and Testing of Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations N45.2.4-1972/IEEE Std 336-1971 NQA-1 1994 Subpart 2.4 IEEE Standard Installation, Inspection, and Testing Requirements for Power, Instrumentation, and Control Equipment at Nuclear Facilities ANSI/IEEE Std 336-1985 COMMENTS 3. That the installation has been made in accordance with specified requirements

4. That all nonconforming items have been satisfactorily

resolved

5. That appropriate protective measures are applied for lay-up

after installation

6. That all temporary conditions such as jumpers, bypass lines

and temporary set points have been clearly identified so that

subsequent restoration can be ascertained prior to placing the

items in service To satisfy the above objectives, inspections

defined in 5.1 shall be repeated, as appropriate.

3) The installation has been made in accordance with specified requirements

4) All nonconforming items have been satisfactorily resolved

5) Appropriate protective measures are applied for lay-up after

installation

6) All temporary conditions, such as jumpers, lifted leads, bypass lines, and temporary setpoints, have been clearly

identified so that subsequent restoration can be ascertained

prior to placing the items in service.

To satisfy the above objectives, it may be necessary to repeat

some of the inspections defined in 6.1.

6.2 Tests

7.2 Tests Installed equipment and systems shall be tested to demonstrate that the installation has been made in accordance with design

requirements and that the operation gives the desired result.

Temporary electrical connections, temporary piping sections, abnormal chemical solutions, unspecified setting of devices, the

fixing of a moving component, or the effecting of any other

abnormality if made previously shall be rectified before final

testing except in cases where fuel loading or other critical

operations prevent using the complete assembly for the test. In

these instances, a documented notice shall be prepared stating

the substitutions that existed for the test. In final testing that

precedes system performance testing, normal system readout

devices and installed transducers shall be used as far as

possible to monitor the operation. Where the installed

equipment is not adequate for the purpose of conducting tests, special measuring instruments and simulating devices shall be

used. Test equipment used shall have adequate capacity and

be compatible with system under test so that the results will not

be distorted.

Installed equipment and systems shall be tested to demonstrate that they have been installed in accordance with design

requirements and that the operation gives the desired result.

Temporary electrical connections, temporary piping sections, abnormal chemical solutions, unspecified setting of devices, the

temporary blocking or the effecting of any other abnormality

previously made shall be rectified before final testing except in

cases where fuel loading or other operations prevent using the

complete assembly for the test. In these instances, a

documented notice stating the temporary test conditions shall

be prepared and be referenced to the appropriate test report or

data sheet. In final testing that precedes preoperational testing, normal system readout devices and installed transducers shall

be used as far as possible to monitor the operation. Where the

installed equipment is not adequate for the purpose of

conducting tests, special measuring instruments and simulating

devices shall be used. Test equipment used shall have

adequate capacity and tolerance and be compatible with the

system under test.

Similar requirement.

6.2.1 Equipment

Tests

.7.2.1 Equipment Tests Tests shall be performed to verify that the quality of installed equipment has not deteriorated during the construction phase.

Tests shall be performed to demonstrate that the installed equipment is in an acceptable condition to be energized where Similar requirement.

Alternative for labeling 05/26/04 Page 18 of 26 Installation, Inspection, and Testing of Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations N45.2.4-1972/IEEE Std 336-1971 NQA-1 1994 Subpart 2.4 IEEE Standard Installation, Inspection, and Testing Requirements for Power, Instrumentation, and Control Equipment at Nuclear Facilities ANSI/IEEE Std 336-1985 COMMENTS Tests and shakedown runs shall be made on energized systems where necessary to evaluate operations and to properly

condition for service (for example, the seating of brushes or

bearings, the stabilization of instrumentation and burn-in of

electronic devices). Tests shall be made to assure that

instrumentation and control channels are properly calibrated. In

addition, specific tests shall be made at critical levels such as "set points" in a manner simulating the approach toward the set

point. These calibrations shall be made with these devices in

their normal positions if the calibration is dependent upon

location or attitude. Tests shall be made to determine that

proper response is obtained over the operating range of the

device. Particular attention shall be given to verifying

independence and dependence, as appropriate, of the elements

of the systems. Items requiring calibration shall be tagged or

labeled on completion indicating date of calibration and identity

of person that performed the calibration.

The following is a clarification made in the current VA QATR: (5) Section 6.2.1 -

Equipment Tests

The last paragraph of this section deals with tagging and labeling. The Company will comply with an alternate last paragraph which

reads: "Each safety-related item of process instrumentation is

identified with a unique number. This number is utilized in

instrument maintenance records so that current calibration

status, including data such as the date of the calibration and

identity of the person that performed the calibration, can be

readily determined. Such information may also be contained on

tags or labels which may be attached to installed

instrumentation."

manufacturers' tests or calibrations cannot be accepted (see 6.2). Tests and shakedown runs shall be made on energized

systems where necessary to evaluate operation and to properly

condition for service (for example, the seating of brushes or

bearings, the stabilization of instrumentation and burn-in of

electronic devices). Tests shall be made to assure that

instrumentation and control channels are properly calibrated. If

the calibration is dependent upon location or orientation, then

calibrations shall be made with these devices in their normal

positions. Tests shall be made to determine that proper

operation is obtained over the range of the device. Particular

attention shall be given to verifying independence and

dependence, as appropriate, of the elements of the systems.

Items requiring calibration shall be identified by tags or labels

indicating the identity of the person who performed the

calibration and the date of the next required calibration.

installed measuring and test equipment addressed in the

new QAPD.6.2.2 System Tests

.7.2.2 System Tests These tests shall be made to verify that all parts of a system properly coordinate with each other. Tests shall be made with

attention given to demonstrating required independence and

dependence of subsystems. Consideration shall be given to Tests shall be made to verify that all parts of a system properly coordinate with each other. Tests shall be made with attention

given to demonstrating required independence and dependence

of subsystems. Consideration shall be given to the need for Similar requirement.

05/26/04 Page 19 of 26 Installation, Inspection, and Testing of Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations N45.2.4-1972/IEEE Std 336-1971 NQA-1 1994 Subpart 2.4 IEEE Standard Installation, Inspection, and Testing Requirements for Power, Instrumentation, and Control Equipment at Nuclear Facilities ANSI/IEEE Std 336-1985 COMMENTS demonstrating freedom from unwanted or harmful effects of conducted or induced electrical noise. A review shall be made

of all testing that has preceded the final integrated system

testing including both the tests made on assemblies and

components with particular attention given to those that

demonstrate functional or operational results. When these tests

serve as a prerequisite or a part of the final system test, a

review of construction activity which may have affected the

results shall be made. The final construction-phase testing shall

be made with all assemblies and components of subsystems

complete except where a critical operation requires that

temporary, electrical connections, piping sections, or structural

supports be installed to make the tests demonstrating freedom from unwanted or harmful effects of Conducted or induced electrical noise. A review shall be made

of testing that has preceded the final integrated system testing, including the tests made on equipment with particular attention

given to those that demonstrate functional or operational

results. When these tests serve as a prerequisite or a part of

the test of the completed system, a review of construction

activity that may have affected the results shall be made. The

final construction-phase testing shall be made with all

equipment of subsystems complete except where an operation

requires that temporary electrical connections, piping sections, or structural supports be installed to make the tests.

The following is a clarification made in the current VA QATR: (4) Section 6 -

Post Construction Verification

is not generally considered applicable at operating facilities because of the scope of work and the relatively short interval

between installation and operation. Where considered

necessary by station management, the elements described in

this section will be used in the development and implementation

of inspection and testing programs as described in Sections

17.2.3, .10, and .11 of the Operational QA Program.

Clarification deemed not necessary for the new

QAPD.7. DATA ANALYSIS AND EVALUATION

8. Data Analysis and Evaluation Procedures shall be established for processing inspection and test data and their analysis and evaluation. These procedures

shall include acquisition and reduction of inspection and test

data for prompt evaluation against acceptance criteria, operating limits and performance standards.

Procedures shall be established for processing inspection results and analyzing and evaluating test data. These

procedures shall include requirements for reduction of

inspection and test data for review or evaluation against

acceptance criteria.

Similar requirement.

The data processing procedures shall provide for "on-the-spot" evaluation to determine the validity of the inspection and test

results, the appropriateness of continuing the inspection or test.

The data shall be analyzed and evaluated to verify

completeness of results, achievement of inspection and test

objectives, and operational proficiency of equipment and The data shall be analyzed and evaluated to verify completeness, achievement of objectives, and correct operation

of equipment and systems, and to identify any additional

inspection or tests required.

Similar requirement, but does not require "on-the-spot"

evaluation. Clarification from

the current VA deemed not

necessary for the new

QAPD.

05/26/04 Page 20 of 26 Installation, Inspection, and Testing of Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations N45.2.4-1972/IEEE Std 336-1971 NQA-1 1994 Subpart 2.4 IEEE Standard Installation, Inspection, and Testing Requirements for Power, Instrumentation, and Control Equipment at Nuclear Facilities ANSI/IEEE Std 336-1985 COMMENTS systems; to identify additional inspection and/or tests required; and to identify necessary changes to the installation inspection

or test procedures. Inspection and test results that include

inspection and test data, together with a report of data analysis

and evaluation, shall be provided as specified in Section 8.

The following is a clarification made in the current VA QATR: (6) Section 7 -

Data Analysis and Evaluation

will be implemented as stated herein after adding the clarifying phrase "when determined by station management" at the

beginning of that paragraph.

8. RECORDS

9. Records Record copies of completed procedures, reports, personnel qualification records, test equipment calibration records, test

deviation or exception records, and inspection and examination

records shall be prepared. These shall be placed with other

project records as required by code, standard, specification, or

project procedures.

Copies of construction records such as approved procedures, personnel qualifications, test equipment calibration records, deviation or exception records, and inspection and test records

shall be prepared. These shall be placed with other project

records as required by codes, standards, specification, or

project procedures.

Similar requirement.

9. APPLICABLE CODES, STANDARDS AND GUIDES The applicable published codes, standards, and guides shall be used. In cases where codes or standards were intended to

cover the manufacturing phase of an item, these codes shall be

used as guides. Refer to Appendix B for a listing, not

necessarily complete, of additional codes, standards, and guides

that should be considered during the construction phase. The

following guides or standards refer specifically to nuclear

power generating stations and their construction and shall be

considered applicable.

The QAPD establishes the quality assurance standards to

be applied to the activities.

1) IEEE Std 279-1971, Criteria for Protection Systems for Nuclear Power Generating Stations

2) IEEE Std 308-1971, Criteria for Class IE Electric Systems

for Nuclear Power Generating Stations

3) IEEE Std 317-1971, Electric Penetration Assemblies in

Containment Structures for Nuclear Fueled Power Generating Reg. Guide will be met with NQA-1-1994 in lieu of N45.2

and other criteria as defined in

NQA-1-1994.

05/26/04 Page 21 of 26 Installation, Inspection, and Testing of Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations N45.2.4-1972/IEEE Std 336-1971 NQA-1 1994 Subpart 2.4 IEEE Standard Installation, Inspection, and Testing Requirements for Power, Instrumentation, and Control Equipment at Nuclear Facilities ANSI/IEEE Std 336-1985 COMMENTS Stations 4) IEEE Std 323-1971, Guide for Qualification of Class I

Electric Equipment for Nuclear Power Generating Stations

5) ANSI 18.2-1965, Nuclear Safety Criteria for the Design of

Stationary Pressurized Water Reactor Plants

6) ANSI B31.7-1969, Nuclear Power Piping

7) IEEE Std 334-1971, Guide for Type Tests of Continuous-

Duty Class I Motors Installed Inside the Containment of

Nuclear Power Generating Stations

8) IEEE Std 336-1971, Installation, Inspection and Testing

Requirements for Instrumentation and Electric Equipment

During the Construction of Nuclear Power Generating Stations

9) IEEE Std 338-1971, Trial-Use Criteria for the Periodic

Testing of Nuclear Power Generating Station Protection

Systems

10) IEEE Std 344-1971, Trial-Use Guide for Seismic

Qualification of Class I Electric Equipment for Nuclear Power

Generating Stations Reg. Guide 1.30 8/72 Position C.2 states: Section 9 of ANSI N45.2.4-1972 lists additional guides and standards made applicable by ANSI N45.2.4. The specific applicability or

acceptability of these listed guides and standards has been or

will be covered separately in other safety guides or in

appropriate Commission regulations.

Appendixes (The Appendixes are not a part or IEEE Standard Installation, Inspection, and Testing Requirements for Instrumentation and

Electric Equipment During the Construction of Nuclear Power

Generating Stations.)

Not a requirement.

Appendix A Supplementary Provisions for Multi-Unit Stations

10. Supplementary Provisions for Multiunit Stations and Operating Plants For construction activity in nuclear power generating stations For construction activity in nuclear facilities where one or more Similar requirement.

05/26/04 Page 22 of 26 Installation, Inspection, and Testing of Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations N45.2.4-1972/IEEE Std 336-1971 NQA-1 1994 Subpart 2.4 IEEE Standard Installation, Inspection, and Testing Requirements for Power, Instrumentation, and Control Equipment at Nuclear Facilities ANSI/IEEE Std 336-1985 COMMENTS where one or more units are already operating or have reached a stage in their own construction where the fuel has been

loaded in the reactor and associated systems energized for

whatever purpose, the following measures shall be taken in

addition to the provision defined in the body of this document.

units are already operating or have reached a stage in their construction where the fuel has been loaded in the reactor and

associated systems energized for whatever purpose, the

following measures shall be taken in addition to the provisions

defined elsewhere in this standard.

Al. Planning and Preparation 10.1 Planning and Preparation Instructions, procedures or drawings shall be prepared to control installation, inspection and testing activities at areas of

interface between the new and existing units.

Instructions, procedures, or drawings shall be prepared to control installation, inspection, and testing activities at areas of

interface between the new and existing units.

Similar requirement.

These instructions and procedures or drawings shall define:

1) The areas of interface between the new and existing units

2) Access control and authority for work at these interface

areas

3) Nature of potential hazards to and/or from the existing

equipment

4) Precautions required to be taken during installation

5) Supplementary objectives for inspection and testing These instructions and procedures or drawings shall define the following:

1) The areas of interface between the new and existing units

2) Access control and authority for work at these interface

areas

3) Nature of potential hazards to or from the existing

equipment

4) Precautions required to be taken during installation

5) Supplementary objectives for inspection and testing Similar requirement.

A2. Documentation 10.2 Documentation A2.1 The instructions, procedures or drawings described in Section Al shall be documented and shall be kept current by revisions as necessary.

10.2.1 The instructions, procedures, or drawings described in 10.1 shall be kept current by revisions.

Similar requirement.

A2.2 The equipment and/or systems which are associated with existing unit(s) that are electrically energize or charged with pressurized and/or radioactive fluids and which are in the

vicinity of the construction activity associated with the new unit

shall be properly tagged or identified.

10.2.2 The equipment or systems which are associated with existing unit(s) that are electrically energized or charged with pressurized or radioactive fluids and which are in the vicinity of

the construction activity associated with the new unit shall be

properly tagged or identified.

Similar requirement.

A2.3 The documentation associated with installation described in Section 2.2 of the main document shall additionally include:

10.2.3 The documentation associated with installation described in 10.2.2 shall also include:

Similar requirement.

A2.3.1 The identification of the equipment and/or system defined in 2.2 above, which poses a potential hazard in the vicinity of current construction activity.

1) The identification of the equipment or system defined in 10.2.2 which poses a potential hazard in the vicinity of current

construction activity Similar requirement.

A2.3.2 Level of potential hazard from such neighboring

2) Identification of the potential hazard of such neighboring Similar requirement.

05/26/04 Page 23 of 26 Installation, Inspection, and Testing of Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations N45.2.4-1972/IEEE Std 336-1971 NQA-1 1994 Subpart 2.4 IEEE Standard Installation, Inspection, and Testing Requirements for Power, Instrumentation, and Control Equipment at Nuclear Facilities ANSI/IEEE Std 336-1985 COMMENTS energized systems, such as: voltage, radiation level, fluid pressure and/or temperatures.

energized systems as voltage, radiation level, fluid pressure, or temperatures A2.4 Authorizations for access to and work at the areas of interface between the new and existing units shall be documented.

10.2.4 Authorizations for access to and work at the areas of interface between the new and existing units shall be documented.

Similar requirement.

10.2.5 Provisions of Section 9 shall be implemented to supplement or supersede documents or records as required New requirement regarding records.A3. Installation 10.3 Installation A3.1 Suitable protective barriers shall be erected to prevent damage to equipment and/or systems associated with the existing unit(s).

10.3.1 Suitable protective barriers shall be erected, where needed, to prevent damage to equipment or systems associated with the existing unit(s).

Similar requirement.

A3.2 Spare capacities available in existing facility such as in cable raceways or in panelboards shall not be used unless expressly indicated on the latest applicable approved for construction drawings or installation specification.

10.3.2 Spare capacities available in the existing facility, such as in cable raceways or in panelboards, shall not be used unless expressly indicated on the latest applicable approved-for-construction drawings or installation specification. This

does not prohibit authorized temporary use of such spare

capacities.

Similar requirement. Adds allowance for approved

temporary use of spare

capacities.

A3.3 When working in an area common to the new and the existing units, such as the cable spreading room, control room, radioactive waste building or the battery room, care shall be

especially exercised to avoid interference with existing

facilities and to maintain required separation, where

appropriate, between the systems associated with existing and

new units.

10.3.3 When working in an area common to the new and the existing units, such as the cable spreading room, control room, or radioactive waste building, care shall be especially exercised

to avoid interference with existing facilities and to maintain

required separation, where appropriate, between the systems

associated with existing and new units.

Similar requirement.

A4. Inspection 10.4 Inspection A4.1 Inspection shall be performed to verify that existing equipment and/or systems neighboring current construction activity are properly tagged and identified, and potential

hazards therefrom identified and documented.

10.4.1 Inspection shall be performed to verify that the requirements of 10.2 and 10.3 have been satisfied.

Similar requirement.

A4.2 Inspection shall be performed to verify that the existing facilities are properly protected from current construction activity.10.4.2 Inspection shall be performed to verify that the existing facilities are properly protected from construction activity.

Similar requirement.

05/26/04 Page 24 of 26 Installation, Inspection, and Testing of Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations N45.2.4-1972/IEEE Std 336-1971 NQA-1 1994 Subpart 2.4 IEEE Standard Installation, Inspection, and Testing Requirements for Power, Instrumentation, and Control Equipment at Nuclear Facilities ANSI/IEEE Std 336-1985 COMMENTS A5. Testing 10.5 Testing A5.1 In testing integrated electrical control and/or instrumentation systems where the plant design calls for interconnection between the existing and new systems, care

shall be especially exercised to prevent tripping or otherwise

dislocating the operation of equipment and/or systems

associated with the existing unit(s).

In testing integrated electrical control or instrumentation systems, or both, where the plant design calls for

interconnection between the existing and new systems, care

shall be exercised to prevent tripping or otherwise disturbing

the operation of equipment or systems associated with the

existing unit(s).

Similar requirement.

Appendix B Additional Codes, Standards and Guides

1. ANSI C1-1963, National Electrical Code (NFPA 70-1968)(to be used as a guide when appropriate)

2. ANSI C29.1-1961, Test Methods for Electrical Power

Insulators

3. ANSI Appendix C57.93, Guide for Installation and

Maintenance of Oil-Immersed Transformers

4. ANSI Appendix C57.94, Guide for Installation and

Maintenance of Dry-Type Transformers

5. ANSI C96.1-1969, Temperature Measurement

Thermocouples

6. API RP550-1965, Manual on Installation of Refinery

Instruments and Control Systems. Part I - Process

Instrumentation and Control

7. API RP550-1965, Manual on Installation of Refinery

Instruments and Control Systems, Part II - Process Stream

Analyzers

8. ASME Boiler and Pressure Vessel Code,Section III, Nuclear Power Plant Components, 1971

9. IEEE Std 4-1968, Techniques for Dielectric Tests (ANSI

C68.1- 1968)

10. IEEE Std 43-1961, Recommended Practice for Testing, Insulation Resistance of Rotating Machinery 11. IEEE Std 51-

1955, Guiding Principles for Dielectric Tests

12. IEEE Std 56-1958, Guide for Insulation Maintenance for

Large AC Rotating Machinery 05/26/04 Page 25 of 26 Installation, Inspection, and Testing of Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations N45.2.4-1972/IEEE Std 336-1971 NQA-1 1994 Subpart 2.4 IEEE Standard Installation, Inspection, and Testing Requirements for Power, Instrumentation, and Control Equipment at Nuclear Facilities ANSI/IEEE Std 336-1985 COMMENTS 13. IEEE Std 62-1958, Guide for Making Dielectric Measurements in the Field

14. IEEE Std 64-l969, Guide for Acceptance and Maintenance

of Insulating Oil in Equipment

15. IEEE Std 81-1962, Guide for Measuring Ground

Resistance and Potential Gradients in the Earth

16. IEEE Std 95-1962, Guide for Insulation Testing of Large

AC Rotating Machinery with High Direct Voltage

17. IEEE Std 112A-1964, Test Procedure for Polyphase Induction Motors and Generators

18. IEEE Std 114-1969, Test Procedure for Single-Phase

Induction Motors

19. IEEE Std 115-1965, Test Procedure for Synchronous

Machines

20. IEEE Std 118-1949, Master Test Code for Resistance

Measurement

21. IEEE Std 120-1955 (withdrawn), Master Test Code for

Electrical Measurement in Power Circuits

22. IEEE Std 262-1968, Test Code for Distribution, Power and

Regulating Transformers, and Shunt Reactors (ANSI

C57.12.90- 1968)

23. IEEE Std 283-1968, Guide for Installation of Oil-Immersed

Transformers

24. ISA-RP3.1, Flowmeter Installations, Seal and Condensate Chambers, 1960

25. ISA-S5.1, Instrumentation Symbols and Identification, 1968

26. ISA-RP7.1, Pneumatic Control Circuit Pressure Test, 1956

27. ISA-RP7.2, Color Code for Panel Tubing, 1957

28. ISA-RP8.1, Instrument Enclosures for Industrial

Environments

29. ISA-RP25.1, Materials for Instruments in Radiation

Service, 1957

30. ISA-S26, Dynamic Response Testing of Process Control

Instrumentation, 1968 05/26/04 Page 26 of 26 Installation, Inspection, and Testing of Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations N45.2.4-1972/IEEE Std 336-1971 NQA-1 1994 Subpart 2.4 IEEE Standard Installation, Inspection, and Testing Requirements for Power, Instrumentation, and Control Equipment at Nuclear Facilities ANSI/IEEE Std 336-1985 COMMENTS 31. ISA-S37.1, Electrical Transducers Nomenclature and Terminology, 1969

32. ISA-RP42.1, Nomenclature for Instrument Tubing Fittings (Threaded), 1965

33. NEMA ICS-1970, Industrial Controls and Systems

34. NEMA IS 1.1-1969, Enclosures for Industrial Controls and

Systems

35. NEMA SG 3-1965, Low-Voltage Power Circuit Breakers

36. NEMA SG 5-1971, Power Switchgear Assemblies

37. NEMA VE 1-1965, Ventilated Cable Trays 05/26/04 Page 1 of 35 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants N45.2.5 Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete, Structural Steel, Soils, and Foundations for Nuclear Power Plants NQA-1 1994 SUBPART 2.5 COMMENTS 1. INTRODUCTION 1 GENERAL 1.1 Scope This standard sets forth the supplementary quality assurance requirements of installation, inspection and testing of structural

concrete and structural steel for nuclear power plant

construction.

Subpart 2.5 provides amplified requirements for installation, inspection, and testing of structural concrete, structural steel, soils, and foundations.

Similar It is intended for application to those structures from which satisfactory performance is required.

1. For the plant to operate reliably

2. To prevent accidents that could cause undue risk to the health

and safety of the public

3. To mitigate the consequences of such accidents if they were to

occur.It supplements the requirements of Part I and shall be used in conjunction with applicable Basic and Supplementary Sections of

Part I when and to the extent specified by the organization

invoking Subpart 2.5.

This is an overall objective of NQA-1, Basic

Requirement 2, related to

providing control over

activities affecting quality

consistent with their

importance to safety.

Included are the following:

1. Formwork 2. Steel Reinforcement

3. Embedded Items

4. Foundation Preparation

5. Concrete

6. Structural Steel See Section 2 of NQA-1-1994, Subpart 2.5 below The requirements may also be extended to other appropriate parts of nuclear power plants when specified in contract

documents.

This standard is intended to be used in conjunction with ANSI N45.2.1.2 Applicability The requirement of this standard apply to the work of any organization or individual participating in the production, preparation, placement, inspection and testing of structural

concrete and the erection, inspection and testing of structural

steel as identified in section 1.1.

See NQA-1, Part II, Introduction for Applicability 05/26/04 Page 2 of 35 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants N45.2.5 Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete, Structural Steel, Soils, and Foundations for Nuclear Power Plants NQA-1 1994 SUBPART 2.5 COMMENTS The extent to which the individual requirements of this standard apply will depend upon the nature and scope of the work to be

performed and the importance of the item or service involved.

The requirements are intended to assure that only specified materials and workmanship are incorporated into the plant; that

quality of materials and quality of workmanship are maintained

throughout the construction process; that the work is performed

in accordance with applicable construction procedures; and that

the completed installation conforms to the specified requirements.

The ASME Boiler and Pressure Vessel Code,Section III, Divisions 1 and 2, as well as other American National Standards, have been considered in the development of this standard; and

this standard is intended to be compatible with their requirements.

This standard applies to structural concrete and structural steel

components of nuclear power plants not covered by the Code.

For items covered by the Code, it is intended that the

requirements of this standard shall supplement the requirements

of the Code. In cases where conflict may exist, the requirements

of the Code shall govern.

1.3 Responsibility

The organization or organizations responsible for establishing the applicable requirements for the activities covered by this standard

shall be identified and the scope of their responsibilities shall be

documented. The work of establishing practices and procedures

and providing the resources in terms of' personnel, equipment and

services necessary to implement the requirements of this

standard may be delegated to other organizations and such

delegation also shall be documented. It is the responsibility of

each organization performing work covered by this standard to

comply with the procedures and instructions issued for the project

and to conform to the requirements of this standard applicable to

their work. It is the responsibility of the organization performing

these activities to specify the detailed methods and procedures See NQA-1, Part II, Introduction for Responsibility Similar requirements between both standards.

05/26/04 Page 3 of 35 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants N45.2.5 Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete, Structural Steel, Soils, and Foundations for Nuclear Power Plants NQA-1 1994 SUBPART 2.5 COMMENTS unless they are specified in the procurement documents.

1.4 Definitions

1.1 Definitions The following definitions are provided to assure a uniform understanding of select terms as they are used in this standard.

Additional definitions of terms are included in ANSI N45.2.10.

The following definitions are provided to assure a uniform understanding of unique terms as they are used in Subpart 2.5.

Similar. For NQA-1, additional definitions are

contained in the

Introduction to Part I.

Class of Concrete - Identifies each individual design mix.

Class of concrete - identifies each individual design mix Similar Curing - The process of maintaining a satisfactory moisture content and a favorable temperature in concrete during hydration of the cementitious materials so that desired properties of the concrete are developed.

Curing - the process of maintaining a satisfactory moisture content and a favorable temperature in concrete during hydration of the cementitious materials so that desired properties of the concrete are developed.

Similar Correlation testing - a form of in-process testing accomplished consistent with established procedures, which provides for the comparison of results of specified tests of concrete samples

taken of corresponding batches from two different points to

establish to what extent the conditions and method of transit have

impacted on specified requirements for plastic concrete at the

placement point New definition in NQA-1 (Not in N45.2.5 or

N45.2.10)Delivery point - the point of discharge in the case of a truck agitator unit, or non-agitating unit when another conveying device is to be used to transport the plastic concrete to the placement

point. Where a truck agitator unit is used in the transit of

concrete, the delivery point and the mixing point are considered

coincident when:

(a) the delivery point is not more than a distance of 2 mi (3.22 km) and a maximum time of 1/2 hr in transit from the mixing point, and (b) the delivered concrete commences to be placed within a maximum time of 1/2 hr from the time the transporting vehicle arrives at the delivery point.

When a non-agitating unit is used, the delivery point and the

mixing point shall not be considered coincident.

New definition in NQA-1 (Not in N45.2.5 or

N45.2.10) - clarifies

"Sampling point" from

N45.2.5 05/26/04 Page 4 of 35 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants N45.2.5 Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete, Structural Steel, Soils, and Foundations for Nuclear Power Plants NQA-1 1994 SUBPART 2.5 COMMENTS Finishing - The process of obtaining specified surface characteristics of hardened concrete.

Finishing - the process of obtaining specified surface characteristics of hardened concrete Similar Qualified Procedures - Procedures which incorporate applicable codes and standards, manufacturer's parameters and engineering specifications.

NQA-1-1994 defines "Qualified Procedure" as "an approved procedure that has been demonstrated to meet the specified

requirements for its intended purpose" Not in Subpart but in Definition section of NQA-

1-1994 Qualification Tests -

Tests performed to qualify the basic material source or manufacturer. These tests are mandatory unless current documentary test data are available to establish

complete confidence in conformance to specification

requirements Qualification tests

- tests performed to qualify the basic material source or manufacturer to assure conformance to specification requirements Definition shortened, still same basic intent.

In-Process Tests - Tests performed during the course of construction to maintain control of structural materials. These tests may be performed by the manufacturer or supplier, but

samples for these tests must be taken from the lot or batch of

materials supplied to the site for use.

Inprocess tests - tests performed during the course of construction to determine compliance with specified requirements and maintain control of materials. These tests may be performed

by the purchaser (or his agent), constructor, manufacturer, or

supplier, but samples for these tests must be taken from the lot or

batch of materials supplied and used at the site of construction.

NQA-1 Definition expands on who may perform the

tests but under same

requirements.

Sampling Point - The point at which the concrete leaves the last piece of mixing or agitating equipment prior to being discharged to conveying equipment systems.

Clarified in NQA-1 by use of "Delivery Point" and

"Mixing Point" Mixing point - the point of discharge of plastic concrete from a central mix plant. For truck mixed concrete, the mixing point and delivery point are defined as coincident.

New definition in NQA-1 (Not in N45.2.5 or

N45.2.10) - clarifies

"Sampling point" from

N45.2.5 Placement point - the point of discharge of plastic concrete into the forms. Except for pumped concrete, the placement point and the delivery point are considered coincident when 5 min or less is

used in transit of the concrete from the delivery point to the

placement point.

New definition in NQA-1 (Not in N45.2.5 or

N45.2.10) - clarifies

"Sampling point" from

N45.2.5 1.5 Referenced Documents Other documents that are required to be included as a part of this standard are identified at the point of reference and listed in The QAPD addresses the standards and codes that 05/26/04 Page 5 of 35 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants N45.2.5 Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete, Structural Steel, Soils, and Foundations for Nuclear Power Plants NQA-1 1994 SUBPART 2.5 COMMENTS Section 8 and the Appendix of this Standard. The issue or edition of the referenced document that is required is specified in the

Appendix.

Regarding this subdivision, NRC Regulatory Guide 1.94-4/76

states: "The specific applicability or acceptability of documents

listed in Section 8 has been covered separately in other regulatory

guides. Other standards and codes listed in ANSI N45.2.5-1974

provide useful guidance for the installation, inspection, and testing

of structural concrete and structural steel. Prior to use of these

other referenced codes and standards, however, the suitability of

the standard or code should be reviewed for the particular

application under consideration."

apply to the activities. Use of NQA-1 is not a specific

commitment to those

referenced standards.

2. GENERAL REQUIREMENTS 2 GENERAL REQUIREMENTS The requirements of Subpart 2.5 apply to any organization or individual participating in work relating to production, preparation, placement, installation, inspection, and testing of structural

concrete, structural steel, soils, and foundations, and applies to the

following Similar to 1.2 of N45.2.5.

N45.2.5 covers this in Section 1.1 as follows: (Included are the following:

1. Formwork 2. Steel Reinforcement

3. Embedded Items

4. Foundation Preparation

5. Concrete

6. Structural Steel)(a) formwork (b) steel reinforcement (c) embedded items (d) foundation preparation (e) concrete (f) structural steel (g) soils and earthwork (h) special foundations (i) foundation underpinning NQA-1 Subpart 2.5 adds: (g) soils and earthwork (h) special foundations (i) foundation underpinning

2.1 Planning

3 REQUIREMENTS Measures shall be established and implemented for documenting installation, inspection, and testing operations to verify

conformance to specified requirements.

Measures shall be established and implemented for documenting installation, inspection, and testing activities to verify conformance

to specified requirements.

Similar 05/26/04 Page 6 of 35 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants N45.2.5 Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete, Structural Steel, Soils, and Foundations for Nuclear Power Plants NQA-1 1994 SUBPART 2.5 COMMENTS 3.1 Planning and Procedures Planning shall take into account the need for the preparation and control of procedures and work instructions as necessary to

comply with specified requirements for installation, inspection and

testing.

Planning shall include a review of the structure, system, or

component design and procurement specifications, materials lists, drawings, construction work plans, procedures, and schedules to

assure that installation, inspection and testing activities have been

incorporated and that they can be accomplished as specified; and

that time and resources are sufficient to accomplish the

scheduled construction without degradation of quality.

Regarding this subdivision, NRC Regulatory Guide 1.94-4/76

states: "The provisions of Subdivision 2.1 - should be used in

conjunction with Regulatory Guide 1.55, 'Concrete Placement in

Category 1 Structures.'" Note that Reg. Guide 1.55 has been

withdrawn by the NRC.

Planning and procedure preparation shall be in accordance with the Introduction to this Part (Part II).

The Introduction to NQA-1, Part II addresses these

items from N45.2.5 for

Planning.2.2 Procedures and Instructions Installation, inspection and test procedures, and work instructions shall be prepared and documented for those activities falling

within the scope of this standard.

The Introduction to NQA-1, Part II addresses these

items from N45.2.5 for

Procedures These documents shall be kept current and revised as necessary to assure that installation, inspections and tests are performed in

accordance with latest information and shall include as

appropriate:

Addressed in NQA-1, Part I, Basic Requirement 6.

1. Installation specifications.

2. Inspection and test objectives and requirements.

3. Precautions to avoid component or system damage during

installation, inspection and following inspection but prior to use.

4. Inspection and test equipment required.

5. Sequence of tests (if applicable).

6. Sequential actions to be followed.

Item 4 of N45.2.5 reads

"(g) special equipment

required" in NQA-1.

Item 12 of N45.2.5 reads

"(j) acceptance criteria and

methods for verifying" in

NQA-1.

05/26/04 Page 7 of 35 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants N45.2.5 Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete, Structural Steel, Soils, and Foundations for Nuclear Power Plants NQA-1 1994 SUBPART 2.5 COMMENTS 7. Frequency of inspections and tests.

8. Prerequisites.

9. Approval.

10. Data report form.

11. Identification of test equipment and date of required

recalibration where required for interpretation of test results.

12. Inspection and test acceptance limits.

NQA-1 adds the following: (a) personnel safety (k) responsibility and

required qualifications of

personnel 2.3 Results Inspection and test results shall be documented in a suitable test report or data sheet. Each report shall identify the item to which it

applies, the procedures or instructions followed in performing the

task, and the identification of the following:

Covered in Supplement 10S-1 for Inspection requirements and Supplement 11S-1, Section 4 for documenting test

results. These are written as general requirements for all

quality activities.

NQA-1 contains equivalent requirements in Part I.

1. Pertinent inspection and test data such as identification of location where testing was performed or where test samples

were taken.

2. Significant dates and times.

3. Inspection acceptance and test completion signatures.

4. Conditions encountered which were not anticipated, including

nonconformance.

Test reports and data sheet shall include an evaluation of the

acceptability of inspection and test results and provide for

identifying the individual who performed the evaluation.

2.4 Personnel

Qualifications Personnel performing tests and inspections required by this standard shall be qualified in accordance with ANSI N45.2.6.

Personnel performing field inspections and testing activities shall

be certified for Level I capability.

On-site supervisors of Level I personnel shall be certified for

Level II capability and shall be responsible for the proper

performance of onsite inspections and tests. Persons charged

with engineering managerial responsibility of the inspection and

testing organization at the site in either a resident or nonresident

capacity shall be certified for Level III capability.

For NQA-1, qualification of inspection and test personnel is not repeated in this subpart. They are contained in

Supplement 2S-1, 2; Supplement 10S-1, Section 3.2; and

Appendix 2A-1 (although this appendix is nonmandatory, the NRC requires commitment to this for an acceptable program, ref.

Reg Guide 1.28).

NQA-1 contains equivalent requirements in Part 1. The

QAPD addresses

additional qualification

requirements.

05/26/04 Page 8 of 35 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants N45.2.5 Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete, Structural Steel, Soils, and Foundations for Nuclear Power Plants NQA-1 1994 SUBPART 2.5 COMMENTS Personnel performing nondestructive examinations shall be qualified to appropriate levels of capability as specified in

American Society for Nondestructive Testing Recommended

Practice SNT-TC-1A.

2.5 Measuring

and Test Equipment.

3.2 Measuring

and Test Equipment 2.5.1 Selection.

Measuring and test equipment used to implement the requirements of this standard shall be selected on the basis of

accuracy sufficient to determine conformance to specified

requirements.

Further details for M&TE is contained in Supplement 12S-1 and Subpart 2.16 rather than repeated in this Subpart

(2.5).The overall requirements of NQA-1 are equivalent to

those of N45.2.5.

These measuring devices shall include but not to be limited to thermometers, balances, scales, air entrainment meters, humidity meters, volumetric buckets, field soil density measuring devices, pressure gages, and torque wrenches.

The following is a clarification made in the current VA QATR:

(1) With regard to Section 2.5.1 of ANSI N45.2.5-1974, titled Selection: The Company complies with the requirement set forth in the first paragraph of this Section for selection of measuring and test equipment

on the basis of sufficient accuracy to determine conformance to the

standard's requirements: This is accomplished without the use of

calibrated balances or volumetric buckets. Clarification meets or exceeds

applicable guides and standards. The proposed clarification is used to

translate construction oriented documents to operational regulations.

Measuring and test equipment used to implement the requirements of Subpart 2.5 shall include (but not be limited to)

thermometers, balances, scales, air entrainment meters, volumetric buckets, field measuring devices, pressure gages, and torque wrenches.

Similar The clarification from the

current VA QA program

will not be carried into the

new QAPD. Appropriate

calibration of this

equipment is currently

performed and required by

procedure/contract.

2.5.2 Calibration

and Control The equipment shall be adjusted or calibrated or both at prescribed intervals against certified standards having known

valid relationships to national standards, where such exists. If no

national standards exists, the basis for the adjustment or

calibration shall be documented. Records shall be maintained and

equipment suitably marked to indicate calibration status.

Measures shall be taken to assure proper handling, storage and

care of installation of inspection and testing equipment after

calibration in order to maintain the required accuracy of such Addressed in NQA-1, Part 1 and Subpart 2.16.

05/26/04 Page 9 of 35 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants N45.2.5 Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete, Structural Steel, Soils, and Foundations for Nuclear Power Plants NQA-1 1994 SUBPART 2.5 COMMENTS equipment.

Test equipment found to be out of calibration shall be clearly identified as such. When discrepancies, malfunctions, or

inaccuracies in inspection and testing equipment are found during

calibration, all items inspected with that equipment since the last

previous calibration shall be considered unacceptable until an

evaluation has been made by the responsible authority and

appropriate action taken.

Addressed in NQA-1, Part 1 and Subpart 2.16.

3.3 Laboratory

Testing Laboratory operations and testing associated with concrete and soils shall be controlled using a Quality Assurance Program.

New requirement in NQA-1.2.6 Housekeeping In job-site areas, facilities, and environments where installation, inspection, and testing of structural steel items are performed in

accordance with the requirements of this standard, the

housekeeping requirements shall be in accordance with ANSI

45.2.3.Note: See NQA-1, Subpart 2.3 for Housekeeping Standards Similar requirements. Refer to table comparing the

stated standards.

3. PRECONSTRUCTION VERIFICATION PRECONSTRUCTION VERIFICATION

3.1 General

4.1 General While it is recognized that the requirements for initial receipt inspections and storage are covered by another standard, ANSI

N45.2.2, it is necessary to verify that the quality of an item has

not suffered during the interim period. It is not intended to

duplicate inspections but rather to verify that items are in a

satisfactory condition for installation.

Receipt and interim storage inspections shall be used to verify that items are in a satisfactory condition for installation.

Similar requirements.

Subpart 2.2 of NQA-1

addresses receipt and

storage requirements.

N45.2.2 and Subpart 2.2

are compared in a separate

table.The verification shall include:

1. Visual examination of materials for proper identification, physical damage, and contamination.

2. Review of manufacturer's documentation, test reports, or other

evidence of quality conformance for correctness and compliance

with specifications if not reviewed at time of receipt.

The verification shall include the following: (a) visual inspection of material for proper identification, physical

damage, and contamination; (b) review of manufacturer's documentation, test reports, or

other evidence of quality conformance for correctness and

compliance with specifications if not reviewed at time of receipt.

Similar requirements.

05/26/04 Page 10 of 35 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants N45.2.5 Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete, Structural Steel, Soils, and Foundations for Nuclear Power Plants NQA-1 1994 SUBPART 2.5 COMMENTS 3.2 Materials Suitability

4.2 Materials

Suitability Verification that materials meet specified requirements shall be accomplished through qualification tests and in-process tests.

To assure that materials meet specified requirements, preconstruction qualification tests and inspections of the materials

to be used and in-process tests of materials being used shall be

conducted.

Similar requirements.

3.2.1 Qualification

Tests.

Qualification tests shall be performed and the results evaluated prior to the initial use of the materials to establish conformance of

the materials to the specified requirements. A list of minimum

required qualification tests or certifications is contained in Table

A. This list contains tests necessary to qualify materials for

normal application.

Qualification tests shall be performed and the results evaluated prior to the initial use of the material to establish conformance of

the materials to the specified requirements. These tests are

mandatory unless current documentary test data are available to

establish complete confidence in conformance to specification

requirements. The specifications shall identify the required

qualification tests and the frequency for their repetition. The tests

required for concrete, concrete constituents, materials for

reinforcing systems, materials for prestressing systems and welding materials shall be in accordance with the ASME Boiler and Pressure Vessel Code,Section III, Division 2 (AC1 Standard

359). Lightweight concrete mix designs shall be made in

accordance with AC1 21 1.2. Lightweight concrete aggregates

shall be qualified by tests for conformance with ASTM C 330:

When splitting tensile strengths are required for lightweight

concrete mix, the methods given in ASTM C 330 shall be used.

Similar requirements, NQA-1 does not contain an

equivalent to Table A, rather, the subpart refers to

other equivalent standards

that would control this

testing.Additional tests may be required to qualify materials for special applications.

Additional tests may be required to qualify materials for special application.

Similar requirement.

ANSI N 45.2.5-1974, Table 'A' Qualification Tests Material Test For Test Method Concrete Aggregates Compliance with ASTM C33 As referenced in ASTM C33 Cement Compliance with ASTM C150 As referenced in ASTM C150 Admixtures Compliance with ASTM C260 or C494 whichever is applicable Manufacturer's Certification Fly Ash &

Pozzolans Compliance with ASTM C618 As referenced in ASTM C618 05/26/04 Page 11 of 35 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants N45.2.5 Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete, Structural Steel, Soils, and Foundations for Nuclear Power Plants NQA-1 1994 SUBPART 2.5 COMMENTS Water & Ice Compliance with AASHO T-26 for effect on:

Compressive Strength ASTM C109 Setting Time ASTM C191 Soundness ASTM C151 Liquid Membrane Forming Curing Compound Compliance with ASTM C309 As referenced in ASTM C309 Sheet Materials for Concrete Curing Compliance with ASTM C171 As referenced in ASTM C171 Concrete Mixes Compliance with ACI 211 As referenced in ACI 211 Reinforcement

• Physical properties of full section test specimen per ASTM A615

• One full section test in accordance with ASTM A370 for each bar size Structural Steel Compliance with appropriate specifications such as ASTM A36, A440, etc.

Manufacturer's certification High Strength Bolts Compliance with ASTM A325 or A490 Manufacturer's certification

• Reduced section test specimen may be used for determination of the percentage of elongation.

3.3 Construction

Processes

4.3 Construction

Processes Inspections shall be performed to verify that the prerequisites for control of construction processes such as welding, bolting, structural reinforcement splicing, and concrete measuring, mixing, transporting, placing, and curing have been accomplished.

Inspections shall be performed to verify that the prerequisites for control of construction processes such as welding, structural

bolting, mechanical splicing of reinforcement, and concrete

measuring, mixing, transporting, placing, and curing have been

accomplished.

Similar requirements.

These inspections shall include:

1. Verification that the process has been qualified as required.

2. Verification that process controls are in effect.

3. Verification that qualified procedures, instruction manuals, or

both, if required for specific equipment, are available for use

during construction.

4. Verification that the process is suitable for the particular

application.

5. Verification that manpower, equipment, and materials are

readily available and adequate to perform the work in accordance These inspections shall include verification of the following: (a) the process has been qualified as required; (b) process controls are in effect; (c) approved procedures, instruction manuals, or both, if required

for specific equipment, are available for use during construction; (d) the process is suitable for the particular application; (e) manpower, equipment (including measuring and testing

equipment), and materials are readily available and adequate to

perform the work in accordance with drawing and specification

requirements.

Similar requirements.

05/26/04 Page 12 of 35 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants N45.2.5 Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete, Structural Steel, Soils, and Foundations for Nuclear Power Plants NQA-1 1994 SUBPART 2.5 COMMENTS with drawing and specification requirements.

5 INSPECTION OF SOILS AND EARTHWORK NQA-1 adds requirements for Soils and Earthwork

that were not included in

N45.2.5-1974. Since there

is nothing to compare to, the text is omitted.

6 INSPECTION OF FOUNDATION PILE AND CAISSON CONSTRUCTION Not addressed in N45.2.5-1974, since there is nothing

to compare it to, the text is

omitted here.

4.0 INSPECTION

OF CONCRETE CONSTRUCTION 7 INSPECTION OF CONCRETE CONSTRUCTION

4.1 General

7.1 General Inspection of concrete construction shall include inspections of preparation for concreting, as well as in-process inspections of concrete measuring, mixing, transporting, placement, curing, and protection to assure conformance to specified requirements. The

inspection shall follow the Recommended Practice for Concrete

Inspection, ACI 311.

Inspection of concrete construction shall include inspection of preparations for concreting, as well as in-process inspections of concrete measuring, mixing, transporting, placement, curing, and protection to assure conformance to specified requirements. The

inspection of pretensioning or post-tensioning systems shall be included, if applicable. The inspection shall follow ACI 311.4R, Guide for Concrete Inspection, and PCI MNL-116 and MNL-

117.Similar requirements, updated reference to

applicable standards.

4.2 Protection

of Materials

7.2 Protection

of Materials Inspections shall be performed to verify the adequacy and proper maintenance of material storage conditions and handling

techniques.

Inspections shall be performed to verify the adequacy and proper maintenance of material storage conditions and handling

techniques.

Similar requirements.

These inspections shall include the following:

These inspections shall include the following:

Similar requirements.

1. Inspection of cement storage facilities to verify weather tightness, cement temperature and the absence of lumps, and

review of records to verify type and age of cement.(a) inspection of cement storage facilities to verify weather tightness, cement temperature and the absence of lumps, and

review of records to verify type and age of cement; Similar requirements.

2. Inspection of aggregate stockpiles to verify: handling techniques are not resulting in segregation; storage and handling

adequately prevent contamination with deleterious substances;(b) inspection of aggregate stockpiles to verify that:

(1) handling techniques are not resulting in segregation; (2) storage and handling adequately prevent contamination Similar requirements.

05/26/04 Page 13 of 35 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants N45.2.5 Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete, Structural Steel, Soils, and Foundations for Nuclear Power Plants NQA-1 1994 SUBPART 2.5 COMMENTS proper temperature and uniform moisture control; and use of frozen materials is prevented.

with deleterious substances; (3) specified temperature and uniform moisture control are maintained; and (4) use of frozen materials is prevented;

3. Inspection of admixture storage and handling facilities to verify that deterioration and contamination are prevented.(c) inspection of admixture storage and handling facilities to verify that deterioration and contamination are prevented; Similar requirements.

4. Inspection of water sources and cooling and heating facilities to verify the specified water quality and assure that the

specifications for concrete temperature are met.(d) inspection of water sources and cooling and heating facilities to verify the specified water quality and to assure that the

specifications for concrete temperatures are met; Similar requirements.(e) inspection of reinforcing material, embedments, and prestressing systems materials (wire, strand, tendons, tendon tubes, and temporary or permanent anchor hardware) to verify

protection against excessive corrosion, contamination, and

physical damage.

New requirements for NQA-1.4.3 Measuring, Mixing, and Transporting Equipment 7.3 Measuring, Mixing, and Transporting Equipment Inspections shall be performed prior to and during the production of concrete to verify the adequacy and proper operation of

measuring, mixing, and transporting equipment in accordance with

ACI 304, ASTM C94, and National Ready Mix Concrete

Association - Concrete Plant Standard and Truck Mixer and

Agitator Standard.

Inspections shall be performed prior to and during the production of concrete to verify the adequacy and proper operation of

measuring, mixing, and transporting equipment in accordance with

AC1 304, ASTM C 94, and National Ready Mix Concrete

Association Concrete Plant Standard and Truck Mixer and

Agitator Standard.

Similar requirements.

These inspections shall include the following:

These inspections shall include the following:

Similar requirements.

1. Inspection of measuring facilities for the specified accuracy of measuring, weighing, and weight recording devices to control the

following:

7.3.1 Inspection

of measuring facilities for the specified accuracy of measuring, weighing, and weight recording devices to control the following:

Similar requirements.

a. Proportions of cement, water and aggregates

b. Quantities of admixtures

c. Aggregate moisture compensation

d. Mixing time

e. Temperature control: Heating or cooling of concrete (a) proportions of cement, water, and aggregates (b) quantities of admixtures (c) aggregate moisture compensation (d) mixing time (e) temperature control, heating or cooling of concrete

( f ) method of adding water when batching lightweight aggregates in accordance with AC1 301.

Similar requirements, NQA-1 adds requirement

concerning lightweight

aggregates.

05/26/04 Page 14 of 35 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants N45.2.5 Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete, Structural Steel, Soils, and Foundations for Nuclear Power Plants NQA-1 1994 SUBPART 2.5 COMMENTS 2. Inspection of central mix plant and truck mixers for wear of drum blades, function of revolution counter and water measuring

device, proper speed of rotation, and ability to mix concrete

completely in the specified time.

7.3.2 Inspection

of central mix plant and truck mixers for wear of drum blades, availability of revolution counter and water measuring devices, proper speed of rotation, and ability to mix

concrete completely in the specified time Similar requirements.

4.4 Preplacement

Preparations

7.4 Preplacement

Preparations Inspection of preparations for concrete placement shall include the following:

Inspection of preparations for concrete placement shall include the following Similar requirements.

1. Inspection of compacted structural fill during placement to verify correct material, condition of material, gradation, moisture

content, in place density, and compliance with compaction

procedures.(a) inspection of the compacted structural fill or undisturbed soil to verify correct condition;

2. Inspection of rock surfaces which will be in contact with structural concrete to verify surface cleanness, removal of loose

rock and free water, correct contour, and specified subgrade condition (b) inspection and field testing, in accordance with the specifications of all structural fill, undisturbed soil, and rock

surfaces which will be in contact with structural concrete to

verify surface cleanness, removal of loose rock and free water, correct contour, and specified subgrade condition; Similar requirements when considering these two items

together. NQA-1 separated

the requirements a little

different that N45.2.2.

3. Inspection of previously placed concrete to verify proper preparation for the next lift.(c) inspection of previously placed concrete to verify proper preparation for the next lift; Similar requirements.

4. Inspection of formwork, reinforcing and embedded items to verify: correct location and configuration of formwork; installation and integrity of water stops and membrane waterproofing; condition of form material to produce the specified concrete

finish; installation of ties, anchors, bracing, shoring and supports;

correct size, orientation, and installation of reinforcing steel and

embedded items; correct location and dimension of control joints, expansion joints, construction joints, blockouts, and waterstops; proper form coating; and cleanness.(d) inspection of formwork to verify:

(1) correct location and configuration, dimensional accuracy, and proper line and grade of formwork;(2) installation and integrity of water stops and membrane waterproofing;

(3) condition of form material to produce the specified concrete finish, installation of ties, anchors, bracing, shoring, and supports to prevent movement during concrete placement;

(4) correct location and dimensions of block-outs, proper form

coating, and cleanness inspection of forms for tightness and

placement of grout and vent pipes when preplaced aggregate concrete is used; Similar requirements.(e) inspection of reinforcing steel, prestressing components (if applicable), and other embedded items to verify:

New requirements in NQA-1.

05/26/04 Page 15 of 35 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants N45.2.5 Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete, Structural Steel, Soils, and Foundations for Nuclear Power Plants NQA-1 1994 SUBPART 2.5 COMMENTS (1) correct size, number, location, position, cleanness, and leak tightness, if applicable; (2) proper stringing and absence of physical damage

5. Inspection of mechanical reinforcing bar splicing operations to verify conformance to the requirements of Section 4.9 (f) inspection of mechanical reinforcing bar splicing operations to verify conformance to the requirements of para. 7.12; Similar requirements.(g) inspection by use of a mandrel or similar device to ensure that the tendon conduits are open and remain open during the

concrete placing operation; New requirements in NQA-1.(h) inspection of pretensioning load cells and pressure gages for accuracy and calibration, if applicable; New requirements in NQA-1.(i) inspection of pretensioning system strand vises for cleanness, proper lubrication, wear, distortion, and cracking, if applicable; New requirements in NQA-1.(j) inspection of the pretensioning operation, if applicable, to verify: (1) initial tensioning of each strand to eliminate slack and to provide a uniform initial stress condition in all strands prior to final stressing;

(2) proper measurement and correlation of jack pressure (or load

cell reading) and strand or tendon elongation;

(3) proper correction for elongation losses due to strand slippage in the rises and movement of anchorage abutments;(k) inspection of groundwater control, as specified; New requirements in NQA-1.(l) inspection for embedments.

New requirements in NQA-1.6. Documentation of inspections (1) through (5) above shall be verified as being complete and indicate that all results are

satisfactory.

Documentation of the inspections required by steps (a) through (l) above shall be verified as being complete and

indicating that all inspection results are satisfactory.

Similar requirements, but expanded to cover the

additional activities above.

4.5 Concrete

Placement

7.5 Concrete

Placement Inspection of concrete placement shall be performed to verify the following Inspection of concrete placement shall be performed to verify the following:

Similar requirements.

1. Specified tests of concrete have been performed.(a) specified tests of concrete have been performed; Similar requirements.

2. Adherence to specified requirements for: class of concrete, (b) adherence to specified requirements for class of concrete, Similar requirements.

05/26/04 Page 16 of 35 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants N45.2.5 Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete, Structural Steel, Soils, and Foundations for Nuclear Power Plants NQA-1 1994 SUBPART 2.5 COMMENTS age, rate of placement, lift height, placing sequence, and hot or cold weather concreting practice. (ACI 305-72 or ACI 306-66 respectively) age, rate of placement, lift height, placing sequence, concrete temperature, and hot or cold weather concreting practice (AC1 305 or AC1 306 , respectively);

3. Proper use of adequate conveying and placing equipment.(c) proper use of adequate conveying and placing equipment; Similar requirements.(d) harmful materials are not used in covering or placing equipment; New requirement in NQA-1.4. Adequate concrete consolidation equipment and technique of operation.

Reg. Guide 1.94-4/76, Position C.3 indicated that ACI 309-72

"should be used as a basis for determining the adequacy of the

equipment for concrete consolidation and of the technique of

operation."(e) adequate concrete consolidation equipment and technique of operation (AC1 309

);NQA-1 incorporates the reference to the ACI

standard mentioned in the

NRC Reg. Guide, but

doesn't limit to a specific

year. (Ref. NQA-1, Part

II, Introduction, Section 7)

5. Embedded items are not distributed nor forms displaced.(f) embedded items are not disturbed nor forms displaced.

Similar requirements.

4.6 Finishing

and Repair

7.6 Finishing

and Repairs Inspections shall be performed to verify that specified finishes, i.e., wood float, steel trowel, as cast, or other type, are obtained.

After forms have been removed, inspections shall be performed

to verify that the formed surfaces have been repaired and

finished in accordance with specified requirements.

Inspections shall be performed to verify that specified finishes are obtained, i.e., wood float, steel trowel, as cast, or other type.

After forms have been removed, inspections shall be performed

to verify that the formed surfaces have been repaired and

finished in accordance with specified requirements.

Similar requirements.

Any indications of voids or contamination, such as at a construction joint, shall be explored, by physical removal of

concrete if necessary, to determine the extent of such voids or

contamination. Appropriate repairs shall be made.

Any indication of voids or contamination, such as at a construction joint, shall be explored by physical removal of

concrete, if necessary, to determine the extent of such voids or

contamination. Appropriate repairs shall be made.

Similar requirements.

4.7 Curing

7.7 Curing Qualification tests shall be performed on liquid membrane forming curing compounds and sheet materials for concrete curing for

compliance with ASTM C 309 in accordance with test methods

given therein or ASTM C 171, as applicable.

New requirement in NQA-1. Additional ASTM proposed for use in the QAPD (ASTM C 1315).

Inspections shall be performed throughout the specified curing period to verify the following:

Inspections shall be performed throughout the specified curing period to verify the following:

Similar requirements.

1. Correct curing method is used, i.e., use of ponding, fog spray, (a) correct curing method is used, i.e., use of ponding, fog spray, Similar requirements.

05/26/04 Page 17 of 35 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants N45.2.5 Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete, Structural Steel, Soils, and Foundations for Nuclear Power Plants NQA-1 1994 SUBPART 2.5 COMMENTS wet burlap, curing compound, or other method in accordance with specified requirements.

wet burlap, curing compound, or other methods in accordance with specified requirements

2. Concrete is kept continuously, i.e., not periodically, wet during the entire curing period, if one of the wet curing methods is used.(b) concrete is kept continuously, i.e., not periodically, wet during the entire curing period, if one of the wet curing methods is used; Similar requirements.

3. Membrane curing compounds are specifically approved for use prior to application.(c) membrane curing compounds are specifically approved for use prior to application; Similar requirements.

4. Curing temperatures is maintained within specified limits during the entire curing period.(d) curing temperature is maintained within specified limits during the entire curing period; Similar requirements.

5. Shoring and forms are left in place until concrete has reached the specified strength necessary to preclude the possibility of

damage from construction loads.(e) shoring and forms are left in place, and precast concrete members are left in the forms until concrete has reached specified strength necessary to preclude the possibility of damage

from construction loads; Similar requirements, NQA-1 addresses precast members.(f) concrete test cylinders are subjected to the same curing process as the concrete when field cured cylinders are required

to evaluate curing methods New requirement in NQA-1 Subsections 7.8 through 7.10 NQA-1 adds new requirements for:

Stress Transfer of Pretensioned Members (Subsection 7.8), Post-Tensioning (Subsection 7.9), and Shipping and Handling of Precast Concrete Members (Subsection 7.10)

Requirements of these subsections were not

addressed by N45.2.5-

1974, since there is nothing

to compare them to, they

are omitted from this table.

4.8 In-Process Tests on Concrete and Reinforcing Steel 7.11 In-Process Tests on Concrete and Reinforcing and Prestressing Steel In-process tests shall be performed during the course of construction to maintain control of structural concrete. A list of

the required in-process tests is contained in Table B. The test

frequencies given shall be considered minimums. In-process tests

shall be performed more frequently if test results are erratic or if

the trend of results or an apparent change in material

characteristics indicate that the frequency should be increased.

Samples for in-process tests of concrete shall be taken at the In-process tests shall be performed during the course of construction to maintain control of structural, prestressed, and

precast concrete. The tests which are required and the frequency

shall be in accordance with the ASME Boiler and Pressure

Vessel Code,Section III, Division 2 (AC1 Standard 359) except

as follows.

The ASME Boiler and Pressure Vessel Code,Section III, Division 2 (AC1 Standard 359) test frequencies for the following Requirements are similar, but NQA-1 includes the

additional items from the

above new sections and

refers to an equivalent ACI

standard rather than

including a table like

N45.2.5.

05/26/04 Page 18 of 35 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants N45.2.5 Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete, Structural Steel, Soils, and Foundations for Nuclear Power Plants NQA-1 1994 SUBPART 2.5 COMMENTS sampling point in accordance with ASTM C172. This point may be at the truck mixer discharge if the last piece of conveying

equipment is a chute, bucket, conveyor system, or similar

equipment. Pumped concrete must be sampled from the pump

line discharge. No water or other ingredients may be added to

any concrete batch at the sampling point for inprocess tests.

Samples shall not be taken from concrete after it has been deposited in the form.

tests shall be considered minimum, unless current documentary test data are available to establish adequate confidence in

conformance of materials to specified requirements.

(a) for concrete materials - unit weight/yield (b) for aggregate materials (1) unit weight of aggregate (2) fixed water and iron content of aggregate only for

radiation-shielding concrete

(3) organic impurities

(4) flat and elongated particles

(5) lightweight particles (6) soft fragments (7) specific gravity and absorption

(8) Los Angeles abrasion (9) potential reactivity (10) soundness From N45.2.5-1978, Section 6.11 - Millstone only commitment.

6.11 In-Process Tests on Concrete and Reinforcing and Prestressing Steels In-process tests shall be performed during the course of construction to maintain control of structural, prestressed and

precast concrete. A list of the required in-process tests is

contained in Table B. The test frequencies given shall be

considered minimums. In-process tests shall be performed more

frequently if test results are erratic or if the trend of results or an

apparent change in material characteristics indicates that the

frequency should be increased.

Samples for in-process tests of concrete shall be taken following

the procedures of ASTM C-172 except as defined herein

regarding location of sampling. No water or other ingredients may

be added to any batch after making the in-process tests. Samples

shall not be taken from concrete deposited in the form. Except as

noted below for pumped concrete and when correlation testing is The reduction of frequency of testing must be documented, and referenced documentation must be representative of the material

currently being certified with the results of prior testing.

In-process tests shall be performed more frequently if test results

are erratic, or if the trend of results or an apparent change in

material characteristics indicates that the frequency should be

increased.

Samples for in-process tests of concrete shall be taken following

the procedures of ASTM C 172, except as defined herein

regarding location of sampling. No water or other ingredients may

be added to any concrete batch after making the in-process tests.

Samples shall not be taken from concrete deposited in the form.

Except as noted below, the sampling point for taking in-process

test samples of plastic concrete shall be performed at the

placement point or other points coincident thereto.

When concrete is pumped during its movement from the delivery

point to the placement point, in-process strength samples shall be New requirement in NQA-1 for the Virginia sites. Millstone had a commitment for this section

to a more recent edition of

N45.2.2. The requirements

between that edition and

NQA-1 are similar.

05/26/04 Page 19 of 35 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants N45.2.5 Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete, Structural Steel, Soils, and Foundations for Nuclear Power Plants NQA-1 1994 SUBPART 2.5 COMMENTS performed, the sampling point for taking in-process test samples of plastic concrete shall be performed at the placement point, or

other points coincident thereto.

In the case where concrete is pumped during its movement from

the delivery point to the placement point, in-process strength

samples shall be taken at the placement point, unless correlation

tests of air content, slump, and temperature are performed.

Where correlation testing is in effect, in-process strength samples

may be taken at the delivery point.

In-process strength testing conducted at the mixing point is

permitted, but unless the mixing point and the delivery point are

considered coincident, correlation strength tests between samples

taken at the mixing point and the delivery point are required. In

this case the frequency of the correlation of strength samples

taken at the delivery point shall be each 500 cubic yards of

concrete or twice each week, whichever provides the greater

number of samples.

If sampling is not accomplished at the placement point and if the

delivery point and the placement point are not considered

coincident, correlation tests will be established and performed for

air content, slump, and temperature. The frequence of correlation tests shall be at an interval four times greater than that noted in Table B for in-process tests. When any of the specified limits and

tolerances on loss of air content, slump, or temperature are

exceeded at the placement point, correlation strength tests

between the delivery point and the placement point shall be

accomplished for each 100 cubic yards of concrete placed as

long as limits and tolerances are exceeded. If no limits and

tolerances are specified, the ASTM C-94 shall apply.

taken at the placement point, unless correlation tests of air content, slump, and temperature are performed. When correlation

testing is in effect, in-process strength samples may be taken at

the delivery point.

In-process strength testing conducted at the mixing point is

permitted, but unless the mixing point and the delivery point are

considered coincident, correlation strength tests between samples

taken at the mixing point and the delivery point are required. In

this case, the frequency of the correlation of strength samples

taken at the delivery point shall be taken each 500 CU yd (382

m3) of concrete or twice each week, whichever provides the

greater number of samples.

If sampling is not accomplished at the placement point and if the

delivery point and the placement point are not considered

coincident, correlation tests will be established and performed for

air content, slump, and temperature. The frequency of the

correlation tests shall be at an interval of four times greater than

the required test frequency. When any of the specified limits and

tolerances on loss of air content, slump, or temperature are

exceeded at the placement point, correlation strength tests

between the delivery point and the placement point shall be

accomplished for each 100 CU yd (76.5 m3) of concrete places

as long as limits and tolerances are exceeded. If no limits and

tolerances are specified, ASTM C 94 shall apply Table B, "Required In-Process Tests," is reproduced below this section for readability.

05/26/04 Page 20 of 35 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants N45.2.5 Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete, Structural Steel, Soils, and Foundations for Nuclear Power Plants NQA-1 1994 SUBPART 2.5 COMMENTS ANSI N45.2.5-1974 Table B Required In-Process Tests Material Requirement Test Method Test Frequency Concrete Mixer uniformity ASTM C94 Initially and every 6 months thereafter Sampling method ASTM C172 Compression cylinders ASTM C31 Compressive strength ASTM C39 2 cylinders for 28-day test from each 100 cu yd or a minimum of 1set/day for

each class of concrete Slump ASTM C143 First batch produced each day and every 50 cu yd placed Air content ASTM C173 or C231 First batch produced each day and every 50 cu yd placed Temperature First batch produced each day and every 50 cu yd placed Unit weight/yield ASTM C138 Daily during production Grout Compressive strength ASTM C109 Daily during production 05/26/04 Page 21 of 35 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants N45.2.5 Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete, Structural Steel, Soils, and Foundations for Nuclear Power Plants NQA-1 1994 SUBPART 2.5 COMMENTS Aggregate Compliance with requirements for: Gradation Moisture content

Material finer than No. 200

sieve Organic impurities

Friable Particles

Lightweight pieces

Soft fragments

Los Angeles abrasion

Flat and elongated particles

Potential reactivity Soundness ASTM C136 ASTM C566 ASTM C117 ASTM C40 ASTM C142 ASTM C123 ASTM C235 ASTM C131 or C535

CRD C119 ASTM C289 ASTM C88 Daily during production Daily during production

Daily during production Weekly during production*

Monthly during production*

Monthly during production*

Monthly during production*

Every 6 months*

Every 6 months*

Every 6 months*

Every 6 months*

Water & Ice Compliance with AASHO T26 for effect on:

Compressive strength ASTM C109 Every 6 months Setting time ASTM C191 Every 6 months Soundness ASTM C151 Every 6 months Admixtures Chemical Composition Infrared spectrophotometry analysis Composite of each shipment Fly Ash &

Pozzolans Chemical & physical properties per ASTM C618 ASTM C311 Each 200 tons Cement Standard physical and chemical properties ASTM C150 Each 1200 tons ASTM C183 Reinforcing Steel

• • Physical properties of full section test specimen per

ASTM A615 ASTM A370**One full section test for each bar size for each 50 tons or fraction thereof

from each heat Cadweld Reinforcing Bar Splices Section 4.9.3 Section 4.9.3 Section 4.9.4 05/26/04 Page 22 of 35 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants N45.2.5 Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete, Structural Steel, Soils, and Foundations for Nuclear Power Plants NQA-1 1994 SUBPART 2.5 COMMENTS* These test frequencies shall be considered minimum unless current documentary test data are

available to establish complete confidence in

conformance to specification requirements.

• • Reduced section test specimen may be used for determination of the percentage of elongation ANSI N45.2.5-1978 (MPS Commitment)

Table B Required In-Process Tests Material Requirement Test Method Test Frequency Concrete Mixer uniformity ASTM C-94 Initially and every 6 months thereafter Sampling method ASTM C-172 Compression cylinders ASTM C-31 Compression cylinders-pre-placed aggregate concrete CRD-C-84 Compressive strength ASTM C-39 2 cylinders for 28-day test from each 100 cu yd or a minimum of 1 set/day

for each class of concrete Slump ASTM C-143 First batch produced each day and every 50 cu yd placed Air content ASTM C-173 or C-231 With each set of compression cylinders Temperature First batch produced each day and every 50 cu yd placed Unit weight/yield ASTM C-138 Daily during production*

Grout Compressive strength ASTM C-109 (for expansive grout use CRD-C 589)

Daily during production Grout for Preplaced Aggregate Concrete Time of set CRD-C 82 Daily during production Flow CRD-C 79 Daily during production Expansion and Bleeding CRD-C 81 Daily during production 05/26/04 Page 23 of 35 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants N45.2.5 Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete, Structural Steel, Soils, and Foundations for Nuclear Power Plants NQA-1 1994 SUBPART 2.5 COMMENTS Aggregate Compliance with requirements for: Gradation ASTM C-136 Daily during production Moisture content ASTM C-566 Twice daily during production Material finer than No. 200 sieve ASTM C-117 Daily during production Unit weight of aggregate ASTM C-29 Daily during production*

Fixed water and iron content of aggregates only for radiation-shielding concrete ASTM C-637 Daily during production*

Organic impurities ASTM C-40 Weekly during production*

Flat and elongated particles CRD-C-119 Monthly during production*

Lightweight particles ASTM C-123 Monthly during production*

Soft fragments ASTM C-235 Monthly during production*

Specific gravity & Absorption ASTM C-127 or ASTM C-128 Monthly during production*

Los Angeles abrasion ASTM C-131 or C-535 Every 6 months*

Potential reactivity ASTM C-289 Every 6 months*

Soundness ASTM C-88 Every 6 months*

Water & Ice Compliance with project specifications for effect on:

Compressive strength ASTM C-109 Monthly Setting time ASTM C-191 Monthly Chlorides ASTM D-512 Monthly Total solids ASTM D-1888 Monthly Admixtures Chemical Composition, Ph, and specific gravity ASTM C-494 Composite of each shipment Fly Ash &

Pozzolans Chemical & physical properties per ASTM C618 ASTM C-311 As specified in ASTM C-311 05/26/04 Page 24 of 35 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants N45.2.5 Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete, Structural Steel, Soils, and Foundations for Nuclear Power Plants NQA-1 1994 SUBPART 2.5 COMMENTS Cement Standard physical and chemical properties ASTM C-150 As specified in ASTM C-183 Reinforcing Steel

• • Physical properties of full section test specimen per ASTM A-615 ASTM A-370 One full section test for each bar size for each 50 tons or fraction thereof

from each heat Cadweld Reinforcing Bar Splices Section 6.12 Section 6.12.3 Section 6.12.4 Soil Compaction Test ASTM 698 or 1557, Method A, B, C, or D, as specified.

One for each 10,000 cu yd with at least one for each soil type, and when soil type is

questionable Grain Size ASTM D-422 hydrometer or sieve as appropriate One for each compaction test Plasticity Index ASTM D-424 One for each compaction test and when volume change characteristics are

questionable Borrow Moisture ASTM D-1556, 2167, 3017, or 2937, as specified One for each soil type, one before each work shift, and when moisture content

changes or is questionable Fluid Density Test ASTM D-1556, 2167, 2922, or 2937 as specified Test as specified in owner's specs and when compaction of soil type is

questionable. Minimum every 10,000 sq ft Fines Content ASTM D-1140 Every 100,000 sq ft Note 1. See definition of In-Process tests.

• These test frequencies shall be considered minimum unless current documentary test data are

available to establish complete confidence in

conformance to specification requirements.

• • Reduced section test specimen may be used for determination of the percentage of elongation.

4.9 Mechanical

(Cadweld) Splice Testing 7.12 Mechanical (Sleeve With Ferrous Filler Metal) Splice Testing The mechanical (sleeve with ferrous filler metal) splice testing NQA-1 refers to equivalent 05/26/04 Page 25 of 35 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants N45.2.5 Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete, Structural Steel, Soils, and Foundations for Nuclear Power Plants NQA-1 1994 SUBPART 2.5 COMMENTS shall be done in accordance with the requirements of the ASME Boiler and Pressure Vessel Code,Section III, Division 2 (AC1

Standard 359).

ACI standard rather than stating all the requirements

in the subpart.

4.9.1 Qualification

of Operators.

Prior to the production splicing of reinforcing bars, each member of the splicing crew (or each crew if the members work as a

crew) shall prepare two qualification splices for each of the splice

positions (e.g., horizontal, vertical, diagonal) to be used. The

qualification splices shall be made using the same materials (e.g.,

bar, sleeve, powder) as those to be used in the structure. To

qualify, the completed splices must meet the specified visual

inspection acceptance requirements and meet the tensile test

requirements of Section 4.9.3.

Each member of the splicing crew (or each crew if the members work as a crew) is subject to requalification (1) if the specific

splice position (e.g., horizontal, vertical, diagonal) has not been

used by member or crew for a period of three months or more or

(2) if there is another reason to question their ability, such as the

completed splices not passing visual inspection or tensile testing.

The requalification procedure should be identical to the original

qualification procedure.

VA QATR exception for restoring containment during reactor vessel head replacement project.

Modified commitment to ASME Code, 1995 edition, subparagraph 4333.4, states:

CC- 4333.4 Initial Qualification Tests.

[A95] Each splicer shall prepare two qualification splices on the largest bar size to be used. In additional, for ferrous filler metal splices, cementitious grouted splices, and swaged splices only, each of the splice positions to be used (e. g., horizontal, vertical, diagonal) shall be

qualified. The qualification splices shall be made using reinforcing

bar identical to that to be used in the structure. The completed This alternative was for a specific application during

the Reactor Vessel Head

Replacement Projects and

will not be carried forward

in the new QA program

since that activity is

completed.

05/26/04 Page 26 of 35 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants N45.2.5 Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete, Structural Steel, Soils, and Foundations for Nuclear Power Plants NQA-1 1994 SUBPART 2.5 COMMENTS qualifications splices shall be tensile tested using the loading rates set forth in SA-370 and the tensile results shall meet those

specified in Tables CC-4334-1. [A95]

4.9.2 Visual

Inspection.

All completed mechanical splices shall be inspected at both ends of the splice sleeve and at the tap hole in the center of the splice

sleeve for longitudinal centering of sleeve on the spliced ends, permissible gap between rebar ends, allowable voids in filler metal, extent of leaking of filler metal, gas blowout, amount of packing and slag at the tap hole. All visual inspections on

completed splices shall be performed only after the splices have

cooled to ambient temperatures. Splices that fail to pass visual

inspection shall be discarded and replaced and shall not be used

as tensile test samples.

4.9.3 Tensile

Testing Splice samples may be production splices (i.e., those cut directly from in-place reinforcing) or sister splices (i.e., those removable

splices made in place next to production splices and under the

same conditions). A record shall be kept of all splices tested, showing the splice location, splice identification number, and

whether the tested splice was a production or sister splice. Splice

samples shall be subjected to tensile tests in accordance with the

sampling frequency specified in Section 4.9.4 to determine

conformance with the following acceptance standards:

1. The tensile strength of each sample tested shall equal or exceed 125 percent of the minimum yield strength specified in

ASTM A615 using loading rates set forth in ASTM A370.

2. The average tensile strength of each group of 15 consecutive samples shall equal or exceed the ultimate tensile strength

specified for the reinforcing bar.

Since curved reinforcing bars will not tensile test accurately, production splice samples should not be removed from curved 05/26/04 Page 27 of 35 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants N45.2.5 Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete, Structural Steel, Soils, and Foundations for Nuclear Power Plants NQA-1 1994 SUBPART 2.5 COMMENTS reinforcing bars for tensile testing. Straight sister splice samples should be made for each of the required curved reinforcing bar

production splices. Production samples should also not be cut

from the structure where the mechanical splicing sleeve is

welded to an anchorage in a region of high stress concentration, or at a leak tight barrier (e.g., embedded structural steel sections

or liner plate). Representative sister splice samples shall be used

in such cases. The sampling frequency specified in Section

4.9.4(2) should then be followed, except that all splices tested

shall be sister splices.

VA QATR exception for restoring containment during reactor vessel head replacement project.

Modified commitment to ASME Code, 1995 edition, subparagraph 4333.5.2, states:

CC- 4333.5.2 Splice Samples.

Splice samples may be production splices (cut directly from in- place reinforcement) or straight sister splices (removable splices made in place next to

production splices and under the same conditions), in accordance

with the schedule established in CC- 4333.5.3.

This alternative was for a specific application during

the Reactor Vessel Head

Replacement Projects and

will not be carried forward

in the new QA program

since that activity is

completed.

4.9.4 Tensile

Test Frequency.

Separate test cycles shall be established for mechanical splices in horizontal, vertical, and diagonal bars, for each bar size, and for

each splicing crew as follows:

1. Test Frequency For Production Splice Test Samples.

If only production splices are tested, the sample frequency shall be:

a. One of the first 10 splices

b. One of the next 90 splices

c. Two of the next and subsequent units of 100 splices

2. Test Frequency for Combination of Production and Sister Splices.If production and sister splices are tested, the sample frequency 05/26/04 Page 28 of 35 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants N45.2.5 Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete, Structural Steel, Soils, and Foundations for Nuclear Power Plants NQA-1 1994 SUBPART 2.5 COMMENTS shall be: a. One production splice of the first 10 production splices

b. One production and three sister splices for the next 90 production splices

c. Three splices, either production or sister splices for the next and subsequent units of 100 splices. At lease 1/4 of the total

number of splices tested shall be production splices.

VA QATR exception for restoring containment during reactor vessel head replacement project.

Modified commitment to ASME Code, 1995 edition, subparagraph 4333.5.3, states:

CC- 4333.5.3 Testing Frequency.

[A95] Splice samples shall be tensile tested in accordance with the following schedule for the appropriate splice system.

(a) Separate test cycle shall be established for sleeve with

ferrous filler metal splices, sleeve with cementitious grout splices, and swaged splices in the horizontal, vertical, and diagonal bars.

Straight sister splices may be substituted for production test

samples on radius bent bars and for splicing sleeves arc welded

to structural steel elements or the liner.

1) For sleeve with ferrous filler metal splices, one splice shall be

tested for each unit of 100 production splices.

Modified commitment to ASME Code, 1995 edition, subparagraph 4333.5.2, requires testing of either production or

sister splices, as stated in paragraph (4b).

This alternative was for a specific application during

the Reactor Vessel Head

Replacement Projects and

will not be carried forward

in the new QA program

since that activity is

completed.

4.10 Welded Reinforcing Bar Splices 7.13 Welded Reinforcing Bar Splices Welded reinforcing bar splices shall be subject to the requirements of Section 5.5, except that provisions of AWS

D12.1 shall apply.

Reg. Guide 1.94-4/76 , Position C.4 states: "In addition, the provisions of Articles CC4334 and CC4330 of the 'Code for Concrete Reactor Vessels and Containments' (ASME Boiler and Welded reinforcing bar splices shall be subject to the requirements of para. 8.5, except that provisions of the ASME Boiler and Pressure Vessel Code,Section III, Division 2 (AC1 Standard 359) shall also apply.

NQA-1 addresses the code the NRC Reg. Guide

makes reference to.

05/26/04 Page 29 of 35 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants N45.2.5 Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete, Structural Steel, Soils, and Foundations for Nuclear Power Plants NQA-1 1994 SUBPART 2.5 COMMENTS Pressure Vessel Code,Section III, Division 2, 1975 Edition) for testing of welded reinforcing bar splices should be used as

guidance pending endorsement of that code by the NRC staff."

5. INSPECTION OF STEEL CONSTRUCTION 8 INSPECTION OF STEEL CONSTRUCTION

5.1 General

8.1 General Inspection of steel construction in accordance with the AISC Manual of Steel Construction shall include inspection of assembly

and erection operations, fastening or connecting operations such

as high strength bolting, and welding and finishing operations to

include cleaning and protective painting or coating.

Inspection of steel construction shall include inspection of related

items, such as anchor bolts and base plates, which may be part of

the supporting structure and installed as part of structural

concrete work.

Structural steel qualification shall be documented by manufacturer's certification showing conformance to

specifications such as ASTM A 36, A 441, or as otherwise

specified. Inspection of steel construction in accordance with the

AISC S326, Specification for the Design, Fabrication, and

Erection of Structural Steel for Buildings shall include inspection

of assembly and erection operations, fastening or connecting

operations such as high strength bolting and welding, and finishing

operations to include cleaning and protective painting or coating.

Inspection of steel construction shall include inspection of related

items, such as anchor bolts and baseplates, which may be part of the supporting structure and installed as part of the structural concrete work.

Similar requirements, but NQA-1 give examples of

specifications to be used.

5.2 Supporting

Structures

8.2 Supporting

Structures Prior to erection of steel, anchor bolts and base plates and other structural embedments shall be checked for correct orientation, spacing, and elevation. Base plate surfaces and supporting concrete surfaces shall be checked to verify satisfactory

condition for grouting.

Grouting of base plates, beam pockets, etc., shall be controlled to

assure that only specified materials are used, proportioned

properly, placed correctly, and cured properly to achieve the

specified compressive strength Prior to erection of steel, anchor bolts, baseplates, and other structural embedments shall be checked for correct orientation, spacing, and elevation.

Baseplate surfaces and supporting concrete surfaces shall be checked to verify satisfactory conditions for grouting. Grouting of baseplates, beam pockets, etc., shall be controlled and inspected to verify that only specified materials are used, proportioned properly, placed correctly, and

cured properly to achieve the specified compressive strength Similar requirements.

5.3 Assembly

and Erection

8.3 Assembly

and Erection Assembly and erection operations shall be inspected to verify compliance with installation procedures and work instructions.

Alignment operations shall be carried out early enough and as Assembly and erection operations shall be inspected to verify compliance with installation procedures and work instructions.

Alignment operations shall be carried out early enough and as Similar requirements.

05/26/04 Page 30 of 35 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants N45.2.5 Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete, Structural Steel, Soils, and Foundations for Nuclear Power Plants NQA-1 1994 SUBPART 2.5 COMMENTS often as is necessary as erection progresses to insure that specified requirements are met.

Particular attention shall be given to verification of the condition

of contact surfaces of friction type connections and bolt hole

alignment. Correction of fabrication errors shall be closely

controlled to prevent correction of misaligned holes by reaming in excess of AISC tolerances. Burning of bolt holes is not permitted.

All equipment used in connecting operations shall be inspected to

verify conformance with specification requirements. For example, air compressors must be of sufficient capacity to maintain the

required operating pressure for impact tools.

often as is necessary as erection progresses to ensure that specified requirements are met. Particular attention shall be given

to verification of the condition of contact surfaces of friction type

connections and bolt hole alignment. Correction of fabrication

errors shall be closely controlled to prevent correction of

misaligned holes by reaming in excess of AISC tolerances.

Burning of bolt holes is not permitted. Equipment used in

connecting operations shall be inspected to verify conformance

with specification requirements. For example, air compressors

shall be of sufficient capacity to maintain the required operating

pressures for impact tools.

5.4 High Strength Bolting 8.4 High Strength Bolting Bolt tightening shall be in accordance with the specified method, i.e., automatic cut-off impact wrench or turn-of-nut method. If

the turn-of-nut method is used, inspections shall be made to verify

that the bolting crews understand the meaning of "snug tight"

condition before the nut is turned through the required angle. If an

automatic cut-off impact wrench is used, it shall be calibrated at

least twice daily. The calibration of automatic cut-off impact

wrenches shall be performed by tightening in a device capable of

indicating actual bolt tension, using no less than three typical bolts

of each diameter from the bolts being installed. Installation of

bolts shall be done in accordance with "Specifications for

Structural Joints Using ASTM A325 or A490 Bolts."

Bolt tightening shall be in accordance with the specified method, e.g., automatic cut-off impact wrench, turn-of-nut method, or

direct-tension indicator. If the turn-of-nut method is used, inspections shall be made to verify that the bolting crews

understand the meaning of snug tight condition before the nut is

turned through the required angle. If an automatic cutoff impact

wrench is used, it shall be calibrated at least twice daily. The

calibration of automatic cut-off impact wrenches shall be

performed by tightening in a device capable of indicating actual

bolt tension, using no less than three typical bolts of each

diameter from the bolts being installed. Installation of bolts shall

be done in accordance with AISC 5329, Specifications for

Structural Joints Using ASTM A 325 or A 490 Bolts.

Qualification of bolts shall be documented by manufacturer's

certification or as otherwise specified.

Similar requirements.

NQA-1 adds allowance for direct-tension indicator and requires manufacturer

certification of bolt

qualification or other

specified assurance of

qualification.

8.4.1 Inspection

of Bolting.

Inspection of bolting shall include visual inspections of bolting operations and torque wrench inspection of completed

connections. All connection points shall be visually inspected for

the following items:

1. Bolts are the correct length as indicated by at least two threads Inspection of bolting shall include visual inspection of bolting operations and torque wrench inspection of completed

connections. Connection points shall be visually inspected for the

following items:

(a) bolts are long enough as indicated by the point of the bolts Similar requirements, but NQA-1 revised minimum

bolt length requirement.

05/26/04 Page 31 of 35 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants N45.2.5 Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete, Structural Steel, Soils, and Foundations for Nuclear Power Plants NQA-1 1994 SUBPART 2.5 COMMENTS extending beyond the nut.

2. Correct type bolt is used as indicated by the manufacturer's

marking on the head.

3. Torque has been applied as indicated by the burnishing or

peening of the corners of the nut.

4. Turning elements are on the correct face; washers are used

when required.

- The schedule of bolt tension inspection shall be as specified in

the latest edition of "Specification for Structural Joints Using

ASTM A325 or A490 Bolts." In addition, at the beginning of

tightening operations, all bolts tightened by each bolting crew shall

be checked until the results are consistently acceptable.

being flush with or outside the face of the nuts;(b) correct type bolt is used as indicated by the manufacturer's

marking on the head; (c) torque has been applied as indicated by the burnishing or

peening of the corners of the nut; (d) turning elements are on the correct face; properly sized

washers are used when required.

Bolt tension inspection shall be as specified in AISC S329, Specification for Structural Joints Using ASTM A 325 or A 490

Bolts. In addition, during the initial phase of bolting operations, all

bolts tightened by each bolting crew shall be checked until the

results are consistently acceptable.

8.4.2 Inspection

Tools and Procedure.

Hand torque wrenches used for inspection shall be controlled in accordance with Section 2.5.2 and must be calibrated at least

weekly and more often if deemed necessary. Impact torque

wrenches used for inspection must be calibrated at least twice

daily. -Hand torque wrenches used for inspection shall be controlled in accordance with Part I, Basic and Supplementary Requirements, and shall be calibrated at least weekly, more often if deemed

necessary. Impact torque wrenches used for inspection shall be

calibrated at least twice daily. Feeler gauges used for inspection

of direct-tension indicators shall be controlled.

Similar requirements, NQA-1 adds requirement

to control feeler gauges

used for inspections.

5.5 Welding

8.5 Welding Inspection of structural steel welding shall be performed in accordance with the provisions of AWS D1.1, Section 6, entitled

"Structural Welding Code" and supplemental addenda. This

inspection shall include visual examination of preparations, welding processes, and post-welding operations. Prior to welding, verification of welding procedure and welder qualification shall be

documented and shall include all essential variables identified in

the procedure.

Inspection of structural steel welding shall be performed in accordance with the provisions of Section 6.0 of AWS D1.1, Structural Welding Code - Steel. This inspection shall include

visual examination of preparations, welding processes, post-

welding operations, and if deemed necessary, some NDE

inspections which are appropriate to the application. Prior to

welding, verification of welding procedure and welder

qualification shall be documented and shall include all essential

variables identified in the procedures.

Similar requirements, NQA-1 adds requirement

for NDE when deemed

necessary.

In-process inspections shall include joint fit up prior to start of welding, preheat and interpass temperature requirements, filler metal, control of distortion, and post-weld heat treatment and cleaning requirements. Procedures shall be established to control In-process inspections shall include acceptability of environmental conditions, joint fit-up prior to start of welding, preheat and

interpass temperature requirements, filler metal, control of

distortion, post-weld heat treatment, and cleaning requirements.

Similar requirements, NQA-1 added inspection

point for environmental

conditions.

05/26/04 Page 32 of 35 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants N45.2.5 Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete, Structural Steel, Soils, and Foundations for Nuclear Power Plants NQA-1 1994 SUBPART 2.5 COMMENTS the purchase, receiving, distribution, storage and use of welding electrode.

Procedures shall be established to control the purchase, receiving, distribution, storage, and use of welding electrodes.

Weld repairs necessitated by visual or nondestructive examinations shall be made in accordance with the procedure

used to perform the original weld or a qualified repair procedure

and reinspected by the same method which disclosed the repairable defect. All weld repairs necessitated by nondestructive examinations shall be documented.

Weld repairs necessitated by visual or nondestructive examinations shall be made in accordance with the procedure

used to perform the original weld or a qualified repair procedure

and reinspected by the same method that disclosed the repairable defect. All weld repairs necessitated by nondestructive examination shall be documented.

Similar requirements.

6. DATA ANALYSIS AND EVALUATION 9 DATA ANALYSIS AND EVALUATION

6.1 General

9.1 General Procedures shall be established for processing inspection and test data and their analysis and evaluation. These procedures shall

provide for acquisition and preparation of inspection and test data

for prompt evaluation against acceptance criteria, operating limits, and performance standards.

Procedures shall be established for processing inspection and test data and their analysis and evaluation. These procedures shall

provide for acquisitions and preparation of inspection and test

data for prompt evaluation against acceptance criteria, operating

limits, and performance standards.

Similar requirements.

The data processing procedures shall provide for "on-the-spot" evaluation to determine the validity of the inspection and test

results, and the appropriateness of continuing the inspection or

test. The data shall be analyzed and evaluated to verify the

completeness of results, achievement of inspection and test

objectives, and to identify additional inspection and tests required;

and necessary changes to the installation inspection or test

procedures. Inspection and test results that include inspection and

test data, together with a report of data analysis and evaluation, shall be prepared as specified in Section 7.

The data processing procedures shall provide for on-the-spot evaluation to determine the validity of the inspection and test

results and the appropriateness of continuing the inspection or

test. The data shall be analyzed and evaluated to verify

completeness of results and achievement of inspection and test

objectives; and to identify additional inspection and tests required, and necessary changes to the installation inspection or test

procedures. Inspection and test results that include inspection and

test data, together with a report of data analysis and evaluation, shall be provided as specified in Section 10.

Similar requirements.

6.2 Concrete

and Mechanical (Cadweld) Splice Test Data Evaluation and Analysis

9.2 Concrete

and Mechanical (Sleeve With Ferrous Filler Metal) Splice Test Data Evaluation and Analysis

6.2.1 Evaluation

of Concrete Test Results.

9.2.1 Evaluation

of Concrete Test Results.

Standard deviation data shall be developed, evaluated, and maintained for permanent records in accordance with ACI 214.

Concrete quality and acceptance criteria shall conform to the

requirements of ACI 318, Chapter 4.

Standard deviation data shall be developed, evaluated, and maintained for permanent records in accordance with ACI 214.

Concrete quality and acceptance criteria shall conform to the

requirements of ACI 318, Chapter 4.

Similar requirements.

05/26/04 Page 33 of 35 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants N45.2.5 Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete, Structural Steel, Soils, and Foundations for Nuclear Power Plants NQA-1 1994 SUBPART 2.5 COMMENTS 6.2.2 Evaluation of Mechanical (Cadweld) Splice Test Results.

9.2.2 Evaluation

of Mechanical Splice Test Results.

The following procedure shall be used for substandard tensile test results.The evaluation of mechanical splice test results shall be in accordance with ASME Boiler and Pressure Vessel Code,Section III, Division 2 (AC1 Standard 359).

NQA-1 refers to an equivalent ACI standard

rather than containing the

information in the subpart.

1. If any production of sister splice tested fails to meet the tensile test specification of Section 4.9.3(1) and the observed rate of

splices that fail the tensile test at that time does not exceed one

for each 15 consecutive test samples, the sampling procedure

shall be started anew. If any production or sister splice used for

testing fails to meet the tensile test specification in Section

4.9.3(1) and the observed rate of splices that fail the tensile test

exceeds one for each 15 consecutive test samples, mechanical

splicing shall be stopped. In addition, the adjacent production

splices on each side of the last failed splice and four other splices

distributed uniformly throughout the balance of the 100 production

splices under investigation shall be tested, and an independent

laboratory analysis shall be made to identify the cause of all

failures. The results of these tests shall be evaluated by the

responsible engineering organization to determine the required

corrective action. The responsible engineering organization shall

specify the extent of repairs necessary and the actions required

to prevent further failures from the identified causes. If two or

more splices from any of these six additional splice samples fail to

meet the tensile test specification of Section 4.9.3(1), the balance

of the 100 production splices under investigation shall be rejected

and replaced. When mechanical splicing is resumed, the sampling

procedure shall be started anew.

2. If the average tensile strength of the 15 consecutive samples fails to meet the provisions of Section 4.9.3(2), the responsible

engineering organization shall evaluate and assess the

acceptability of the reduced average tensile strength with respect

to the required strength of the location from which the samples 05/26/04 Page 34 of 35 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants N45.2.5 Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete, Structural Steel, Soils, and Foundations for Nuclear Power Plants NQA-1 1994 SUBPART 2.5 COMMENTS were taken.

9.2.3 Evaluations

of Aggregate Test Results.

When any aggregate tests specified fail to meet the specified requirements, two additional tests shall be made from samples of

the same lot of aggregate. If one or both of the two additional

tests fails to meet the specified requirements, the data shall be

submitted to the responsible engineering organization for

evaluation and corrective action New requirement in NQA-1.6.3 Steel Construction Test Data Evaluation and Analysis

9.3 Steel

Construction Test Data Evaluation and Analysis These data shall be evaluated for conformance to project specifications, the AISC Manual of Steel Construction and AWS

D1.1 and supplemental addenda.

This data shall be evaluated for conformance to project specifications of the AISC M011, Manual of Steel Construction

and AWS D1.l, Structural Welding Code - Steel.

Similar requirements.

9.4 Soils

Test Data Evaluation and Analysis This data shall be evaluated daily during progress of the work for conformance to project specifications. The control techniques

given in the specifications, such as specific test methods for the

type of soil compacted, shall be verified. Data shall include

determination of parameters specified, including use of proper

materials, amounts and uniformity of soil moisture, and thickness

of layers being placed. In-place compacted fill density shall be

determined using standard approved methods and the results

evaluated for compliance to specified requirements. Data shall

include verification that the soils are fully compacted or

consolidated to contours and the grades specified. When

statistical methods are required by the specification, the desired

level of confidence shall be specified.

New requirement in NQA-1 7. RECORDS 10 RECORDS Record copies of completed procedures, reports, personnel qualification records, test equipment calibration records, test

deviation or exception records, and inspection and examination

records shall be prepared. These shall be placed with other

project records as required by code, standard, specification, or Record copies of procedures, reports, personnel qualification records, test equipment calibration records, test deviation or

exception records, and inspection and examination records shall

be prepared. These shall be retained with other project records as

required by code, standard, specification, or project procedures.

Similar requirements.

05/26/04 Page 35 of 35 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants N45.2.5 Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete, Structural Steel, Soils, and Foundations for Nuclear Power Plants NQA-1 1994 SUBPART 2.5 COMMENTS project procedures.

Collection, storage and maintenance of records shall be in accordance with ANSI N45.2.9.

N45.2.9 is similar to NQA-1, Supplement 17S-1 (mandatory) and Appendix 17A-1 (non-mandatory),

additional requirements are

addressed in the QAPD.

8. REVISIONS OF AMERICAN NATIONAL STANDARD REFERRED TO IN THIS DOCUMENT When the following standards referred to in this document are superseded by a revision approved by the American National

Standards Institute the revision shall apply:

N45.2 Quality Assurance Program Requirements for Nuclear

Power Plants

N45.2.2 Packaging, Shipping, Receiving, Storage and Handling of

Items for Nuclear Power Plants

N45.2.3 Housekeeping During the Construction Phase of Nuclear

Power Plants

N45.2.6 Qualifications of Inspection, Examination and Testing

Personnel for the Construction Phase of Nuclear Power Plants

N45.2.9 Requirements for Quality Assurance Records for

Nuclear Power Plants

N45.2.10 Quality Assurance Terms and Definitions The QAPD addresses commitment to specific

editions of standards.

05/26/04 Page 1 of 27 Supplementary Quality Assurance Requirements For Installation, Inspection And Testing Of Mechanical Equipment And Systems For The Construction Phase Of Nuclear Power Plants ANSI N45.2.8 - 1975 Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for Nuclear Power Plants NQA-1 1994 Subpart 2.8 COMMENTS 1.1 Scope 1 GENERAL This standard contains requirements and guidelines to assure the quality of important items of nuclear power

plants including structures, systems and components. The

requirements and guidelines are intended to assure that

these important items are installed, inspected and tested in

a manner that will provide adequate confidence that they

will perform satisfactorily in service. The requirements

and guidelines for installation, inspection and testing

activities during construction are intended to assure the

quality of mechanical items not covered by Section III of

the ASME Boiler and Pressure Vessel Code. The

requirements of this standard deal with the protection and

control necessary to assure that the requisite quality of

mechanical items of the plant are preserved from the time

items are removed from storage or receiving until they are

incorporated into the plant up to but not including, fuel

loading of PWR plants and the completion of cold

functional testing of BWR and HTGR plants. This

standard is intended to be used in conjunction with ANSI

N45.2. If any conflict exists, ANSI N45.2 shall govern.

The following is a clarification made in the current VA QATR: The Operational Quality Assurance Program complies with this guide with the following clarification:

See Generic Statement which prefaces this table.

Clarification meets or exceeds applicable guides and

standards. The proposed clarification is proposed as a

construction to operations device.

Generic Statement from the current VA QATR:

For operations phase maintenance and modification activities which are comparable in nature and extent to

similar activities conducted during the construction phase, the Company shall control these activities under this Subpart 2.8 provides amplified requirements for installation, inspection, and testing of mechanical

equipment and systems. It supplements the requirements

of Part I and shall be used in conjunction with applicable Basic and Supplementary Sections of Part I when and to the extent specified by the organization invoking Subpart

2.8.Clarification not required under NQA-1, since it applies to construction and

operations phase activities..

05/26/04 Page 2 of 27 Supplementary Quality Assurance Requirements For Installation, Inspection And Testing Of Mechanical Equipment And Systems For The Construction Phase Of Nuclear Power Plants ANSI N45.2.8 - 1975 Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for Nuclear Power Plants NQA-1 1994 Subpart 2.8 COMMENTS Operational Quality Assurance Program. Designated modifications may be controlled under a contractor's

Quality Assurance Program which has been approved by

the Company's Quality Assurance Program. When this

Operational Quality Assurance Program or an approved

contractor's Quality Assurance Program is used, the

Company shall comply with the Regulatory Position

established in the guides listed herein in that quality

assurance programmatic/administrative requirements

included therein (subject to the clarification in this table)

shall apply to these maintenance and modification

activities even though such requirements may not have

been in effect originally. Maintenance or modifications

which may affect the function of safety related structures, systems, or components shall be performed in a manner at

least equivalent to that specified in original design bases

and requirements, materials specifications, and inspection

requirements. A suitable level of confidence in structures, systems, or components on which maintenance or

modifications have been performed shall be attained by

appropriate inspection and performance testing.

1.2 Applicability

The requirements and guidelines of this standard apply to the work of any individual or organization that participates

in installation, inspection or testing of mechanical

equipment during construction activities of nuclear power

plants as discussed in Subsection 1.1. The extent to which

the individual requirements of a standard apply will

depend upon the nature and scope of the work to be

performed and the importance of the item or service

involved. Important mechanical items to be covered and

the extent of coverage shall be identified by the individual

or organization invoking this standard. The requirements Applicability is discussed in NQA-1-1994, Part II, Introduction.

The NQA-1, Part II, Introduction section on applicability does not contain as much

detail as N45.2.8, but it does address the

substance of N45.2.8 regarding assuring

use of proper materials, equipment, processes, and procedures.

05/26/04 Page 3 of 27 Supplementary Quality Assurance Requirements For Installation, Inspection And Testing Of Mechanical Equipment And Systems For The Construction Phase Of Nuclear Power Plants ANSI N45.2.8 - 1975 Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for Nuclear Power Plants NQA-1 1994 Subpart 2.8 COMMENTS are intended to assure that only proper materials, equipment, processes and procedures are utilized during

the construction of power plants and that the quality of

items is not degraded as a result of installation, inspection

and testing practices and techniques during construction.

The ASME Boiler and Pressure Vessel Code (herewith

referred to as the Code), as well as other American

National Standards has been considered in the

development of this standard, and this standard is intended

to be compatible with their requirements. However, this

standard does not apply to activities covered by Section Ill

Division 1 and 2 and Section XI of the Code for those

activities covered by the Code.

Reg. Guide 1.30 8/72 Position C.2 states:. Although ANSI N45.2.8-1975 is entitled "Supplementary Quality Assurance Requirements for Installation, Inspection, and

Testing of Mechanical Equipment and Systems for the

Construction Phase of Nuclear Power Plants," the

requirements included in the standard are considered to be

applicable during the operations phase as well as the

construction phase and should be followed for those

applicable operations phase activities that are comparable

to activities occurring during the construction phase. In

this regard, it should be noted that N45.2.8-1975 does not

address radiological considerations associated with

installation, inspection, and testing of mechanical

components in radioactively contaminated systems.

1.3 Responsibility

The organization or organizations responsible for establishing the applicable requirements for the activities

covered by this standard shall be identified and the scope

of their responsibilities shall be documented. The work of

establishing practices and procedures and providing the Responsibility is discussed in NQA-1-1994, Part II, Introduction, and programmatically in NQA-1, Part I, Basic Requirement 1 with Supplement 1S-1.

The combination of the requirements from NQA-1 are equivalent to the

requirements stated by N45.2.8.

05/26/04 Page 4 of 27 Supplementary Quality Assurance Requirements For Installation, Inspection And Testing Of Mechanical Equipment And Systems For The Construction Phase Of Nuclear Power Plants ANSI N45.2.8 - 1975 Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for Nuclear Power Plants NQA-1 1994 Subpart 2.8 COMMENTS resources in terms of personnel, equipment and services necessary to implement the requirements of this standard

may be delegated to other organizations and such

delegation shall also be documented. It is the responsibility

of each organization performing work covered by this

standard to comply with the procedures and instructions

issued for the project and to conform to the requirements

of this standard applicable to this work. It is the

responsibility of the organization performing these

activities to specify the detailed methods and procedures

unless they are specified in the procurement documents.

1.4 Definitions

1.1 Definitions The following definitions are provided to assure a uniform understanding of select terms as they are used in this

standard.The following definitions are provided to assure a uniform understanding of unique terms as they are used in Subpart

2.8.NQA-1 defines the common terms used throughout the standard in Part I, Introduction § 4.

Acceptance Criteria - A limit or limits placed on the variation permitted in the characteristics of an item

expressed in definitive engineering terms such as

dimensional tolerances, chemical composition limits, density and size of defects, temperature ranges, time

limits, operating parameters, and other similar

characteristics.(From Part I) acceptance criteria - specified limits placed on characteristics of an item, process, or service defined in

codes, standards, or other requirement documents.

Similar definition, but doesn't list the examples.Checks - The tests, measurements, verifications or controls placed on an activity by means of investigations, comparisons, or examinations to determine satisfactory

condition, accuracy, safety or performance.

Checks - The tests, measurements, verifications, or controls placed on an activity by means of investigations, comparisons, or examinations to determine satisfactory

condition, accuracy, safety, or performance Similar definition.

Engineering Limitations - Restrictions which, if disregarded, may result in damage to the item, shortening

the life of the item, or preventing the item from

functioning as intended.

Engineering limitations - restrictions which, if disregarded, may result in damage to the item, shortening the life of the

item, or preventing the item from functioning as intended Similar definition.

Examination - An element of inspection consisting of investigation of materials, components, supplies and Examination - an element of inspection consisting of investigation of materials, components, supplies, and Similar definition.

05/26/04 Page 5 of 27 Supplementary Quality Assurance Requirements For Installation, Inspection And Testing Of Mechanical Equipment And Systems For The Construction Phase Of Nuclear Power Plants ANSI N45.2.8 - 1975 Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for Nuclear Power Plants NQA-1 1994 Subpart 2.8 COMMENTS services to determine conformance to those specified requirements which can be determined by such

investigation. Examination is usually nondestructive and

includes simple physical manipulation, gaging and

measurement.

services to determine conformance to those specified requirements which can be determined by such

investigation. Examination is usually nondestructive and

includes simple physical manipulation, gaging, and

measurement.

Inspection - An element of quality control which by means of examination, observation or measurement

determines the conformance of materials, supplies, components, parts, appurtenances, systems, processes or

structures to predetermined quality requirements.(From Part I) inspection - examination or measurement to verify whether an item or activity conforms to specified

requirements.

Similar definition.

Mechanical Items - Parts, components, or systems that function primarily for pressure retaining, mass moving, or

heat exchange purposes. Examples of mechanical items

are rotating equipment (motors, pumps, blowers), handling

equipment (cranes, hoists, conveyors), piping systems (pipe, valves, hangers), fuel handling systems, and waste

effluent systems.

Mechanical items - parts, components, or systems that function primarily for pressure retaining, mass moving, or

heat exchange purposes. Examples of mechanical items

are rotating equipment (motors, pumps, blowers), handling

equipment (cranes, hoists, conveyors), piping systems (pipe, valves, hangers), fuel handling systems, and waste

effluent systems.

Similar definition.

Testing - The determination or verification of the capability of an item to meet specified requirements by

subjecting the item to a set of physical, chemical, environmental or operating conditions.(From Part I) testing - an element of verification for the determination of the capability of an item to meet specified

requirements by subjecting the item to a set of physical, chemical, environmental, or operating conditions Similar definition.

Verification - An act of confirming, substantiating and assuring that an activity or condition has been

implemented in conformance with the specified

requirements.(From Part I) verification - the act of reviewing, inspecting, testing, checking, auditing, or otherwise

determining and documenting whether items, processes, services, or documents conform to specified requirements.

NQA-1 definition encompasses the N45.2.8 definition in substance, but not

using the same terminology.

Other terms and their definitions are contained in ANSI N45.2.10.Other terms for NQA-1 are defined in Part I, Introduction § 4.

1.5 Referenced

Documents Documents that are required to be included as a part of this standard are identified at the point of reference and

described in Section 8 of this standard. The issue or

edition of the referenced document that is required will be Similar statement exists in NQA-1, Part II, Introduction, § 7. The QAPD will

address that these are references for

guidance unless otherwise stated in the 05/26/04 Page 6 of 27 Supplementary Quality Assurance Requirements For Installation, Inspection And Testing Of Mechanical Equipment And Systems For The Construction Phase Of Nuclear Power Plants ANSI N45.2.8 - 1975 Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for Nuclear Power Plants NQA-1 1994 Subpart 2.8 COMMENTS specified either at the point of reference or in Section 8 of this standard unless otherwise specified in the contract

document.Reg. Guide 1.30 8/72 Position C.1 states: Subdivision 1.5 of ANSI N45.2.8-1975 states: "Documents that are required to be included as a part of this standard are

identified at the point of reference and described in

Section 8 of this standard." The specific acceptability of

these listed documents has been or will be covered

separately in other regulatory guides or in Commission

regulations where appropriate.

QAPD. Implementing documents, procedures, specifications, contracts, etc

will have to ensure appropriate standards

are referenced for the activity in

accordance with NRC or other regulatory

requirements.

2. GENERAL REQUIREMENTS 2 GENERAL REQUIREMENTS This section contains requirements that are to be fulfilled by the organization or organizations responsible for

performing any segment of work described in Section 3

through 5 of this standard. Measures shall be established

and implemented for documenting the necessary

installation, inspection and testing to verify conformance

to specified requirements Measures shall be established and implemented for documenting the necessary installation, inspection, and

testing to verify conformance to specified requirements.

Similar requirement.

2.1 Planning

2.1 Planning and Procedures Activities shall be planned and documented to be consistent with engineering and design requirements

including those which define the degree of importance to

safety and reliability of the item. Planning shall define the

operations to be used and the systematic, sequential

progression of operations, the personnel responsibilities for

each activity and the measures employed to preserve the

quality of the item. Planning shall take into account the

need for the identification, preparation and control of

procedures and work instructions necessary to comply

with requirements for installation, inspection and testing of

components and systems; and the need for trained

personnel necessary to comply with these procedures, Planning and procedure preparation shall be in accordance with the requirements of the Introduction to this Part (Part

II).NQA-1, Part II, Introduction, § 4.1 addresses Planning and contains similar

requirements to N45.2.8.

05/26/04 Page 7 of 27 Supplementary Quality Assurance Requirements For Installation, Inspection And Testing Of Mechanical Equipment And Systems For The Construction Phase Of Nuclear Power Plants ANSI N45.2.8 - 1975 Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for Nuclear Power Plants NQA-1 1994 Subpart 2.8 COMMENTS work instructions, and requirements. Planning shall include a review of the system and component design

specifications, procurement documents and drawings and

of the construction work plans and schedules to assure

that applicable installation, inspection, and testing activities

have been identified; that they can be accomplished as

specified; and that time and resources are sufficient to

accomplish the required actions. Deficiencies identified

during reviews shall be brought to the attention of the

responsible organization for action.

2.2 Procedures

and Instructions Installation, inspection and test procedures and work instructions identified during planning shall be prepared

and documented for those activities falling within the

scope of this standard. Where the planning review

identifies new procedures and inspections that are

necessary, appropriate target dates and effort shall be

scheduled for their preparation and approval. These

documents shall be kept current and revised as necessary

to assure that installation, inspections, and tests are

performed in accordance with latest approved information

and shall include as appropriate:.

a. Prerequisites identified in Subsection 2.9.

b. Precautions to be observed.

c. Installation requirements.

d. Sequential actions to be followed.

e. Test objectives.

f. Special equipment required for installation, inspection

and test.

g. Identification of inspection and test equipment.

h. Frequency of inspection or test.

i. Inspection and test acceptance criteria.

j. Specific document references where required.

NQA-1, Part II, Introduction, § 4.2 addresses Procedures and contains

similar requirements to N45.2.8. The

specific list of items in N45.2.8 are all

encompassed by the list in NQA-1.

05/26/04 Page 8 of 27 Supplementary Quality Assurance Requirements For Installation, Inspection And Testing Of Mechanical Equipment And Systems For The Construction Phase Of Nuclear Power Plants ANSI N45.2.8 - 1975 Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for Nuclear Power Plants NQA-1 1994 Subpart 2.8 COMMENTS k. Data report forms.

l. Approvals

2.3 Results

Inspection and test results shall be documented in a suitable test report or data sheet. Each report shall

identify the item to which it applies, the procedures or

instruction followed in performing the task and include the

following:

a. Pertinent inspection and test data.

b. Significant dates and times.

c. Signature or stamp of inspector or tester.

d. Measuring and test equipment used where required.

e. Identification of nonconformances and action taken on

other conditions that were not anticipated.

Test reports and data sheets shall include an evaluation of

the acceptability of inspection and tests results and

provide for identifying the individual who performed the

evaluation.

NQA-1 addresses these requirements under the programmatic controls of Basic

Requirements 10 and 11, and

Supplements 10S-1 and 11S-1.

2.4 Cleaning

Cleaning activities required by this standard shall be performed in accordance with ANSI N45.2.1 and Section

4 of this standard.

NQA-1, Part II addresses cleaning activities under Subpart 2.1.

2.5 Receiving, Storage and Handling Receiving, storage and handling activities required by this standard shall be performed in accordance with ANSI

N45.2.2 NQA-1, Part II addresses receiving, storage, and handling activities under

Subpart 2.2.

2.6 Housekeeping

In areas, facilities, and environments where installation, inspection and testing of mechanical items is performed in

accordance with the requirements of this standard, the

housekeeping requirements shall be in accordance with

ANSI N45.2.3.

NQA-1, Part II addresses housekeeping activities under Subpart 2.3.

05/26/04 Page 9 of 27 Supplementary Quality Assurance Requirements For Installation, Inspection And Testing Of Mechanical Equipment And Systems For The Construction Phase Of Nuclear Power Plants ANSI N45.2.8 - 1975 Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for Nuclear Power Plants NQA-1 1994 Subpart 2.8 COMMENTS 2.7 Personnel Qualifications Those personnel who perform inspection and testing activities required by this standard shall be qualified in

accordance with ANSI N45.2.6.

NQA-1, Part I addresses inspection and testing qualifications under Supplements

2S-1 and 2S

-2.2.8 Measuring and Test Equipment NQA-1 addresses Measuring and Test Equipment under Basic Requirement 12, Supplement 12S-1, and Subpart 2.16.

2.8.1 Selection.

Measuring and test equipment used to implement the requirements of this standard shall be selected to have

range, type and accuracy sufficient to determine

conformance to specified requirements.

2.8.2 Calibration

and Control.

Measuring and test equipment used to determine compliance with Specifications, shall be adjusted and

calibrated at predetermined intervals, based on equipment

stability and use, against certified equipment having

known valid relationships to nationally recognized

standards. If no national standards exist, the basis for

calibration shall be documented. Records of calibrations

shall be maintained and equipment suitably marked so that

the calibration status can be determined. Records of

calibration shall be included in inspection and test results

where applicable. Measures shall be taken to assure

proper handling, storage, and care of the measuring and

test equipment after calibration in order to maintain the

required accuracy of such equipment. When measuring

and test equipment is found to be out of calibration, an

evaluation shall be made of the validity of previous

inspection or test results and the acceptability of

mechanical items inspected or tested since the last

calibration check. Where necessary to determine the 05/26/04 Page 10 of 27 Supplementary Quality Assurance Requirements For Installation, Inspection And Testing Of Mechanical Equipment And Systems For The Construction Phase Of Nuclear Power Plants ANSI N45.2.8 - 1975 Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for Nuclear Power Plants NQA-1 1994 Subpart 2.8 COMMENTS acceptability of items or data, the required original inspections or tests or applicable portions thereof shall be

repeated using properly calibrated equipment. In the event

that the status of equipment precludes using the originally

specified methods, equipment or procedures, alternate

inspections or tests agreeable to the responsible

organizations may be used.

2.9 Prerequisites

2.2 Prerequisites The following minimum conditions shall have been met or evidence thereof shall be available as applicable before

the requirements set forth in this standard are applied:

a. Qualification of individuals, organizations and

procedures have been completed in accordance with the

requirements of applicable codes and standards.

b. Systems have been designed and engineered in

accordance with applicable codes, standards and

specifications.

c. Materials have been selected and equipment has been

fabricated and assembled in accordance with the design

specifications and the applicable published codes and

standards, the conformance to which has been

demonstrated by the responsible organization.

d. Engineering limitations, as applicable, have been

incorporated in the procedures and instructions. These

limitations and requirements shall include, as a minimum, installation, testing, and on-site fabrication processes such

as cleaning, welding, nondestructive examination and

parameters such as pressure, flow, speed, load limits (static and dynamic), travel limits, physical clearances, control and alarm settings, environmental and thermal

limits which are included in design specifications, manufacturers data sheets, instruction manual and design

reports.The following minimum conditions shall have been met, or evidence thereof shall be available as applicable, before

the requirements set forth in Subpart 2.8 are applied.

(a) Qualification of individuals, organizations, and

procedures have been completed in accordance with the

requirements of applicable codes and standards.

(b) Systems have been designed and engineered in

accordance with applicable codes, standards, and

specifications.

(c) Materials have been selected and equipment has been

fabricated and assembled in accordance with the design

specifications and the applicable published codes and

standards, the conformance to which has been

demonstrated by the responsible organization.

(d) Engineering limitations, as applicable, have been

incorporated in the procedures and instructions. These

limitations and requirements shall include, as a minimum, installation, testing, and on-site fabrication processes such

as cleaning, welding, nondestructive examination, and

parameters such as pressure, flow, speed, load limits (static and dynamic), travel limits, physical clearances, control and alarm settings, and environmental and thermal

limits, which are included in design specifications, manufacturer's data sheets, instruction manual, and design

reports.Similar requirement.

ANSI N45.2.8 refers to "construction

site" and NQA-1-1994 uses "work site."

This is in line with the standard being

applicable to construction and operational

activities.

05/26/04 Page 11 of 27 Supplementary Quality Assurance Requirements For Installation, Inspection And Testing Of Mechanical Equipment And Systems For The Construction Phase Of Nuclear Power Plants ANSI N45.2.8 - 1975 Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for Nuclear Power Plants NQA-1 1994 Subpart 2.8 COMMENTS e. To substantiate (b) and (c) above, the following documents relating to the specific stage of installation

activity for the item shall be available at the construction

site:

(1) The latest applicable approved-for-construction

drawings.

(2) Equipment specifications.

(3) Manufacturers installation instructions.

(4) Installation procedures.

(5) Evidence of compliance by manufacturer with

purchase requirements, including quality assurance

requirements.

(6) Evidence that engineering or design changes are

documented and approved prior to installation.

(7) Records of inspections and tests during onsite

receiving, storage and handling.

(8) Release of mechanical items for installation.

(9) Evidence that nonconformances have been

satisfactorily resolved or controlled.(e) To substantiate (b) and (c) above, the following documents relating to the specific stage of installation

activity for the item shall be available at the work site:

(1) the latest applicable approved-for-construction

drawings (2) equipment specifications

(3) manufacturer's installation instructions

(4) installation procedures

(5) evidence of compliance by manufacturer with

purchase requirements, including quality assurance

requirements

(6) evidence that engineering or design changes are

documented and approved prior to installation

(7) records of inspections and tests during on-site

receiving, storage, and handling

(8) release of mechanical items for installation

(9) evidence that nonconformances have been satisfactorily resolved or controlled

3. PRE-INSTALLATION VERIFICATION 3 PREINSTALLATION VERIFICATION

3.1 General

3.1 General Prior to the actual installation of mechanical items, there are certain preliminary inspections, checks and similar

activities that shall be completed to verify that the item

and the installation area conform to specified

requirements and the necessary resources are available to

assure that the quality of the mechanical item will be

maintained as the installation proceeds. The quality

requirements and quality assurance actions that are

necessary during installation shall be reviewed and

planned so that they are understood by responsible

individuals.

Prior to the actual installation of mechanical items, there are certain preliminary inspections, checks, and similar

activities that shall be completed to verify that the item and

the installation area conform to specified requirements, and

the necessary resources are available to assure that the

quality of the mechanical item will be maintained as the

installation proceeds.

The quality requirements and quality assurance actions

that are necessary during installation shall be reviewed and

planned so that they are understood by responsible

individuals.

Similar requirement.

05/26/04 Page 12 of 27 Supplementary Quality Assurance Requirements For Installation, Inspection And Testing Of Mechanical Equipment And Systems For The Construction Phase Of Nuclear Power Plants ANSI N45.2.8 - 1975 Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for Nuclear Power Plants NQA-1 1994 Subpart 2.8 COMMENTS 3.2 Identification

3.2 Identification

Checks shall be made to verify that the identity of received mechanical materials and equipment has been

maintained and is in accordance with the latest approved-

for-construction drawings, equipment lists, specifications

and established procedures. If these checks disclose

apparent loss of identification, the identity shall be

reaffirmed prior to release for installation.

Checks shall be made to verify that a control system for

maintaining identification of mechanical items throughout

installation has been established including provisions for

control of substitution or exchange of equipment or

materials. The procedures for control of identification

shall provide a system of traceability to drawings, specifications or other records when identification or

markings must be destroyed, hidden or removed from an

item.Checks shall be made to verify that the identity of received mechanical materials and equipment has been maintained

and is in accordance with the latest approved-for-

construction drawings, equipment lists, specifications, and

established procedures. If these checks disclose apparent

loss of identification, the identity shall be reaffirmed prior

to release for installation.

Checks shall be made to verify that a control system for

maintaining identification of mechanical items through

installation has been established, including provisions for

control of substitution or exchange of equipment or

materials. The procedures for control of identification shall

provide a system of traceability to drawings, specifications, or other records when identification or markings must be

destroyed, hidden, or removed from an item.

Similar requirement.

3.3 Processes

and Procedures

3.3 Processes

and Procedures Consistent with the construction activities schedule, inspections or checks shall be performed to verify that

processes and procedures are ready when needed for use

in the installation of mechanical items. These inspections

or checks shall include, but not be limited to the following

verifications:

a. Approved procedures, drawings, manuals or other work

instructions are provided to the installer at the construction

site.

b. Special instructions and check lists as required are

available at the installation area or attached to the item.

c. Approved procedures and instructions for special

processes such as coating, welding, heat treating and

nondestructive examination are available at the site.

d. Where applicable, personnel, procedures and Consistent with the construction activities schedule, inspections, or checks shall be performed to verify that

processes and procedures are ready when needed for use

in the installation of mechanical items. These inspections

or checks shall include, but not be limited to, the following

verifications.

(a) Approved procedures, drawings, manuals, or other

work instructions are provided to the installer at the work

site.

(b) Special instructions and checklists as required are

available at the installation area or attached to the item.

(c) Approved procedures and instructions for special

processes such as coating, welding, heat treating, and

nondestructive examination are available at the site.

(d) Where applicable, personnel, procedures, and Similar requirement.

05/26/04 Page 13 of 27 Supplementary Quality Assurance Requirements For Installation, Inspection And Testing Of Mechanical Equipment And Systems For The Construction Phase Of Nuclear Power Plants ANSI N45.2.8 - 1975 Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for Nuclear Power Plants NQA-1 1994 Subpart 2.8 COMMENTS instructions shall have been qualified through the preparation of workmanship standards, samples, or

mockups that simulate actual job conditions.

e. Installation preparations have been completed, including

such tasks as removal of packaging, conditioning, cleaning, and preliminary positioning.

f. Jigs, fixtures and equipment for special processes, if

required, are available at the site and conform to specified

requirements.

g. Equipment for handling and placement of mechanical

items is available at the site and is adequate to perform

the work in accordance with specified requirements.

h. Warnings and safety notices, appropriate to the activity, are posted.

instructions shall have been qualified through the preparation of workmanship standards, samples, or

mockups that simulate actual job conditions.

(e) Installation preparations have been completed, including such tasks as removal of packaging, conditioning, cleaning, and preliminary positioning.

(f) Jigs, fixtures, and equipment for special processes, if

required, are available at the site and conform to specified

requirements.

(g) Equipment for handling and placement of mechanical

items is available at the site and is adequate to perform the

work in accordance with specified requirements.

(h) Warnings and safety notices appropriate to the activity

are posted.

3.4 Physical

Condition

3.4 Physical

Condition Inspections or checks as appropriate shall be performed to verify that mechanical items at the installation are in

accordance with the specified requirements and that

quality has been maintained. These inspections or checks

shall include, but not be limited to, the following

verifications:

a. Protective measures and physical integrity during

storage have been maintained in conformance with

specified requirements.

b. Nonconformances have been satisfactorily

dispositioned or controlled.

c. Items have been cleaned in accordance with specified

requirements.

Inspections or checks, as appropriate, shall be performed to verify that mechanical items at the installation are in

accordance with the specified requirements and that

quality has been maintained. These inspections or checks

shall include, but not be limited to, the following

verifications.

(a) Protective measures and physical integrity during

storage have been maintained in conformance with

specified requirements.

(b) Nonconformances have been satisfactorily

dispositioned or controlled.

(c) Items have been cleaned in accordance with specified

requirements.

Similar requirement.

3.5 Site Conditions 3.5 Site Conditions Inspections or checks as appropriate shall be performed to verify that conditions of the installation area conform to

specified requirements and precautions have been taken

to prevent conditions that will adversely affect the quality Inspections or checks, as appropriate, shall be performed to verify that conditions of the installation area conform to

specified requirements and precautions have been taken to

prevent conditions that will adversely affect the quality of Similar requirement.

05/26/04 Page 14 of 27 Supplementary Quality Assurance Requirements For Installation, Inspection And Testing Of Mechanical Equipment And Systems For The Construction Phase Of Nuclear Power Plants ANSI N45.2.8 - 1975 Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for Nuclear Power Plants NQA-1 1994 Subpart 2.8 COMMENTS of the item during installation. These inspections or checks shall include, but not be limited to, the following to verify

that:

a. Protection from adjacent construction activities is being

provided including, implementation of appropriate

exclusion and area cleanness requirements.

b. Protection from inclement weather and other ambient

conditions adverse to quality is being provided.

c. Materials that may be deleterious to the mechanical

items being installed, are controlled.

d. Installation of the mechanical item will not adversely

affect the subsequent installation of materials and

equipment and that repair or rework on any

nonconforming items can be performed satisfactorily.

e. Nonconformances for adjacent items have been

dispositioned or controlled.

f. Adequate permanent or approved temporary supports

and mountings have been installed that will properly

interface with the mechanical item.

g. Mating parts such as couplings and flanges are properly

positioned and conditioned.

h. Servicing or maintenance activity related to installation

has been performed.

the items during installation. These inspections or checks shall include, but not be limited to, verification of the

following.

(a) Protection from adjacent construction activities is being

provided, including implementation of appropriate exclusion

and area cleanness requirements.

(b) Protection from inclement weather and other ambient

conditions adverse to quality is being provided.

(c) Materials that may be deleterious to the mechanical

items being installed are controlled.

(d) Installation of the mechanical item will not adversely

affect the subsequent installation of materials and

equipment, and repair or rework on any nonconforming

items can be performed satisfactorily.

(e) Nonconformances for adjacent items have been

dispositioned or controlled.

(f) Adequate permanent or approved temporary supports and mountings have been installed that will properly interface with the mechanical item.

(g) Mating parts such as couplings and flanges are

properly positioned and conditioned.

(h) Servicing or maintenance activity related to installation

has been performed.

4. CONTROL DURING INSTALLATION PROCESS 4 CONTROL DURING INSTALLATION PROCESS 4.1 General

4.1 General

Checking, inspection, examination or testing activities shall be performed during the installation of mechanical items

to assure that the required quality is being obtained in

accordance with prescribed procedures. These activities

shall be performed in a systematic manner to assure

surveillance throughout the installation process. A

procedure shall be provided for the coordination and Checking, inspection, and examination of testing activities shall be performed during the installation of mechanical

items to assure that the required quality is being obtained in

accordance with prescribed procedures. These activities

shall be performed in a systematic manner to assure

surveillance throughout the installation process. A

procedure shall be provided for the coordination and Similar requirement.

05/26/04 Page 15 of 27 Supplementary Quality Assurance Requirements For Installation, Inspection And Testing Of Mechanical Equipment And Systems For The Construction Phase Of Nuclear Power Plants ANSI N45.2.8 - 1975 Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for Nuclear Power Plants NQA-1 1994 Subpart 2.8 COMMENTS sequencing of these activities at established inspection points in successive stages of installation. A method shall

be implemented to assure that engineering and design

changes are documented and controlled during installation.

sequencing of these activities at established inspection points in successive stages of installation. A method shall

be implemented to assure that engineering and design

changes during installation are documented and controlled.

4.2 Process

and Procedure Control

4.2 Process

and Procedures Control Checks shall be made to verify that a system of controls has been established and is being maintained at the

construction site to assure the following:

a. The applicable revision of approved procedures, drawings and instructions are being followed.

b. Qualified and approved processes, materials, tools and

other equipment are being, used by qualified personnel.

c. The status of installation, inspections, examinations or

tests is clearly indicated or identified in inspection records.

d. The installation, inspection and testing sequence is

being maintained.

e. Identification, appropriate segregation, and disposition

of nonconforming items are being controlled.

f. "As-built" information is being processed.

g. Inspection and test reports are current, accurate and

complete.Checks shall be made to verify that a system of controls has been established and is being maintained at the

construction site to assure the following.

(a) The applicable revision of approved procedures, drawings, and instructions is being followed.

(b) Qualified and approved processes, materials, tools, and

other equipment are being used by qualified personnel.

(c) The status of installation, inspections, examinations, or

tests is clearly indicated or identified in inspection reports.

(d) The installation, inspection, and testing sequences are

being maintained.

(e) Identification, appropriate segregation, and disposition

of nonconforming items are being maintained.

(f) As-built information is being processed.

(g) Inspection and test reports are current, accurate, and

complete.Similar requirement.

4.3 Examination

Nondestructive examinations, when required, shall be performed to approved applicable procedures. Examples

of these examinations are liquid penetrant, magnetic

particle, ultrasonic, eddy current and radiography.

NQA-1 doesn't contain this wording, but NDE is programmatically controlled

under Basic Requirements 10 and 11 and

Supplements 10S-1 and 11S-1.

4.4 Inspection

4.3 Inspection Inspections of the work areas and the work in progress shall be performed to verify that mechanical items are

being located, installed, assembled or connected in

compliance with the latest approved-for-construction

drawings, manufacturers instructions, codes, installation Inspections of the work areas and the work in progress shall be performed to verify that mechanical items are

being located, installed, assembled, or connected in

compliance with the latest approved-for-construction

drawings, manufacturer's instructions, and procedures.

Similar requirement.

05/26/04 Page 16 of 27 Supplementary Quality Assurance Requirements For Installation, Inspection And Testing Of Mechanical Equipment And Systems For The Construction Phase Of Nuclear Power Plants ANSI N45.2.8 - 1975 Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for Nuclear Power Plants NQA-1 1994 Subpart 2.8 COMMENTS instructions and procedures. Inspections performed shall include as appropriate, but not be limited to the following:

a. Identification.

b. Location and orientation of components.

c. Leveling and alignment.

d. Clearances and tolerances.

e. Tightness of connections and fastenings.

f. Fluid levels and pressures.

g. Absence of leakage.

h. Physical integrity.

i. Cleanness.

j. Welding operations including materials and process

controls, adequate purging, and the removal of purge

dams on completion.

k. Adequacy of protective measures to assure that the

item will not be damaged during installation.

l. Adequacy of housekeeping, barriers and protective

equipment to assure that items will not be damaged or

contaminated as a result of adjacent construction activities Inspections performed shall include as appropriate, but not be limited to, the following:

(a) identification (b) location and orientation of components (c) leveling and alignment (d) clearances and tolerances (e) tightness of connections and fastenings (f) fluid levels and pressures (g) absence of leakage (h) physical integrity (i) cleanness (j) welding operations, including materials and process

controls, adequate purging, and the removal of purge dams

on completion (k) adequacy of protective measures to assure that the item will not be damaged during installation (l) adequacy of housekeeping, barriers, and protective

equipment to assure that items will not be damaged or

contaminated as a result of adjacent construction activities

4.5 Installation

Checks

4.4 Installation

Checks Checks shall be performed to verify that mechanical items have been correctly installed and will function properly so

that the initial starting of items and preoperational testing

can proceed with a minimum amount of problems and

delays. If construction or associated activity affects the

results of these checks, the checks shall be repeated if

necessary to assure that the quality has not been

adversely affected.

These activities shall include as appropriate, but not be

limited to the following:

a. Checkout procedures are prepared and approved to

verify correctness of installation and ability to function.

b. Proper greasing or lubrication has been completed.

Checks shall be performed to verify that mechanical items have been correctly installed and will function properly so

that the initial starting of items and preoperational testing

can proceed with a minimum amount of problems and

delays. If construction or associated activity affects the

results of these checks, the checks shall be repeated, if

necessary, to assure that the quality has not been

adversely affected.

These activities shall include as appropriate, but not be

limited to, the following.

(a) Checkout procedures are prepared and approved to

verify correctness of installation and ability to function.

(b) Proper greasing or lubrication has been completed.

Similar requirement.

05/26/04 Page 17 of 27 Supplementary Quality Assurance Requirements For Installation, Inspection And Testing Of Mechanical Equipment And Systems For The Construction Phase Of Nuclear Power Plants ANSI N45.2.8 - 1975 Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for Nuclear Power Plants NQA-1 1994 Subpart 2.8 COMMENTS c. Lubricating and cooling water systems are in service.

d. Protection strainers are installed where necessary.

e. Rotation of prime movers is correct.

f. Electrical circuits, controls and relay settings are

correct.

g. Phasing of electrical busses is correct.

h. Instrumentation is calibrated and in service as required.

i. Item is correctly valved and isolated.

j. Casings, reservoirs, etc. are primed, vented and filled.

k. Proper communications are established for control.

1. Tags are issued, where appropriate, for isolation and

control.

m. Piping system alignment is correct.

n. Pipe hanger placement is correct and hangers will

function properly.

o. Seismic anchors and restraints are properly installed.

p. Valve glands and packing are installed.

q. Pneumatic lines have been blown.

r. Valve stroking, actuation and settings are proper.

s. Pump seals and packing are properly installed.

t. Limit switches, interlocks and stops are properly

adjusted and set.(c) Lubricating and cooling water systems are in service.(d) Protection strainers are installed where necessary.

(e) Rotation of prime movers is correct.

(f) Electrical circuits, controls, and relay settings are

correct.

(g) Phasing of electrical buses is correct.

(h) Instrumentation is calibrated and in service as required.

(i) Item is correctly valved and isolated.

(j) Casings, reservoirs, etc., are primed, vented, and filled.

(k) Proper communications are established for control.

(I) Tags are issued, where appropriate, for isolation and

control.

(m) Piping system alignment is correct.

(n) Pipe hanger placement is correct and hangers will

function properly.

(o) Seismic anchors and restraints are properly in stalled.

(p) Valve glands and packing are installed.

(q) Pneumatic lines have been blown.

(r) Valve stroking, actuation, and settings are proper.

(s) Pump seals and packing are properly installed.

(t) Limit switches, interlocks, and stops are properly

adjusted and set.

4.5.1 Cleaning.

4.4.1 Cleaning.

Installed systems and components shall be cleaned, flushed and conditioned according to the requirements of

ANSI N45.2.1. Special attention shall be given to the

following requirements:

a. Chemical Conditioning. Procedures shall be prepared

including the scope, acceptance criteria, sequence, temperatures, soak periods and neutralizing solutions to be

used. Checks shall be made to verify that the proper

chemicals at the designated strength and temperature are Installed systems and components shall be cleaned, flushed, and conditioned according to applicable

requirements. Special attention shall be given to the

following requirements.

(a) Chemical Conditioning. Procedures shall be prepared

including the scope, acceptance criteria, sequence, temperatures, soak periods, and neutralizing solutions to be

used. Checks shall be made to verify that the proper

chemicals at the designated strength and temperature are Similar requirement.

As noted previously, NQA-1 addresses

cleaning and flushing of components and

systems in Subpart 2.1.

05/26/04 Page 18 of 27 Supplementary Quality Assurance Requirements For Installation, Inspection And Testing Of Mechanical Equipment And Systems For The Construction Phase Of Nuclear Power Plants ANSI N45.2.8 - 1975 Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for Nuclear Power Plants NQA-1 1994 Subpart 2.8 COMMENTS being used in the conditioning operations. Other operations shall be performed as specified in Paragraph 4.5.1.c.

b. Flushing. Procedures shall be prepared including routes, boundaries, velocities and acceptance criteria, restoration, and lay-up for high integrity systems where appropriate.

Checks shall be made to verify that mechanical items are

being flushed in accordance with specified requirements

so that contaminants or flow velocities will not adversely

affect subsequent operations. Other operations shall be

performed as specified in Paragraph 4.5.l.c.

c. Process Controls. Checks shall be performed to verify

that controls are functioning for the following:

(1) Removal and installation of parts or components such

as metering devices, orifice plates and valve internals that

are removed from the system to facilitate flushing.

(2) Installation and removal of temporary strainers, blind

flanges, and piping.

(3) Isolation of sensitive instrumentation.

(4) Water and chemical quality.

(5) Acceptance data, specimens, or progressive samples

if required.

Where appropriate for disassembly and reassembly of

components, procedures or instructions shall be prepared

or manufacturers technical manuals shall be used to

assure adherence to match marks, protection of seats and

proper reassembly and to preclude damage to the

component.

being used in the conditioning operations. Other operations shall be performed as specified in (c) below.

(b) Flushing. Procedures shall be prepared including

routes, boundaries, velocities and acceptance criteria, restoration, and lay-up for high integrity systems, where

appropriate. Checks shall be made to verify that

mechanical items are being flushed in accordance with

specified requirements so that contaminants or flow

velocities will not adversely affect subsequent operations.

Other operations shall be performed as specified in (c)

below.

(c) Process Controls. Checks shall be performed to verify

that controls are functioning for the following:

(1) removal and installation of parts or components such as metering devices, orifice plates, and valve internals

that are removed from the system to facilitate flushing;

(2) installation and removal of temporary strainers, blind

flanges, and piping;

(3) isolation of sensitive instrumentation; (4) water and chemical quality; (5) acceptance data, specimens, or progressive samples, if required.

Where appropriate for disassembly and reassembly of components, procedures or instructions shall be prepared

or manufacturer's technical manuals shall be used to

assure adherence to match marks, protection of seats, and

proper reassembly and to preclude damage to the

component.

4.5.2 Pressure

Testing.

4.4.2 Pressure

Testing.

Checks shall be made to verify that mechanical items are being pressure tested in accordance with specified

requirements to assure that the strength and integrity of

the installed systems or portions thereof conform to Checks shall be made to verify that mechanical items are being pressure tested in accordance with specified

requirements to assure that the strength and integrity of

the installed systems or portions thereof conform to Similar requirement. NQA-1 adds requirement for verifying evidence of

calibration of test gages.

05/26/04 Page 19 of 27 Supplementary Quality Assurance Requirements For Installation, Inspection And Testing Of Mechanical Equipment And Systems For The Construction Phase Of Nuclear Power Plants ANSI N45.2.8 - 1975 Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for Nuclear Power Plants NQA-1 1994 Subpart 2.8 COMMENTS specified requirements. The purpose of the test, scope, test boundary, duration for inspection, acceptance criteria, restoration, and lay-up shall be clearly established and

documented. Checks shall include, but not be limited to, the following:

a. Appropriate pressures, temperatures, water chemistry, and pressure test cycles are established.

b. Sufficient time at test pressure is specified to determine

acceptance.

c. Provisions are available to protect and isolate

instrumentation during hydrostatic testing.

d. Items external to test boundary are protected to

prevent inadvertent over-pressurization.

e. Relief devices are controlled to prevent system over-

pressurization.

f. Gagging and ungagging of relief valves.

g. Piping and equipment supports have hydrostatic pins

installed where applicable for testing and removed upon

completion of testing.

specified requirements. The purpose of the test, scope, test boundary, duration for inspection, acceptance criteria, restoration, and lay-up shall be clearly established and

documented. Checks shall include, but not be limited to, the

following.

(a) Appropriate pressures, temperatures, water chemistry, and pressure test cycles are established.

(b) Sufficient time at test pressure is specified to

determine acceptance.

(c) Provisions are available to protect and isolate

instrumentation during hydrostatic testing.

(d) Items external to test boundary are protected to

prevent inadvertent over-pressurization.

(e) Relief devices are controlled to prevent system over-

pressurization.

(f) Gagging and ungagging of relief valves.

(g) Piping and equipment supports have hydrostatic pins

installed where applicable for testing and are to be

removed upon completion of testing.

(h) Evidence of calibration of test gages 4.6 Care of Items 4.5 Care of Items Items on which inspection and testing activities are being performed shall be protected from personnel traffic, weather, and adjacent construction activities such as

sandblasting, acid cleaning, welding, jack hammering, chipping, burning and stress relieving that would adversely

affect the quality of the item or test results. Such

protection shall be provided through good cleanliness and

housekeeping practices, temporary packaging, erection of

barriers, protective covers, and walkways, as required in

accordance with Subsection 2.6. Temporary use of

equipment or facilities to which this standard applies that

are to become part of the completed project may be Items on which inspection and testing activities are being performed shall be protected from personnel traffic, weather, and adjacent construction activities such as

sandblasting, acid cleaning, welding, jack hammering, chipping, burning, and stress relieving, which would

adversely affect the quality of the item or test results.

Such protection shall be provided through good cleanliness

and housekeeping practices, temporary packaging, erection

of barriers, protective covers, and walkways, as required.

Temporary use of equipment or facilities to which this Part

applies that are to become part of the completed project

may be desirable. Authorization for such usage shall be as Similar requirement.

05/26/04 Page 20 of 27 Supplementary Quality Assurance Requirements For Installation, Inspection And Testing Of Mechanical Equipment And Systems For The Construction Phase Of Nuclear Power Plants ANSI N45.2.8 - 1975 Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for Nuclear Power Plants NQA-1 1994 Subpart 2.8 COMMENTS desirable. Authorization for such usage shall be as provided for in the contract or by written approval from

the responsible organization. Such temporary use shall not

subject the equipment or systems to conditions for which

they were not designed.

The temporary use authorization shall include:

(1) conditions of use or operation;

(2) maintenance requirements; and

(3) inspections and tests as required to maintain

operability and quality during period of temporary use of

the item.

When temporary use is completed, conditions of

temporary use shall be evaluated to verify that the

permanent plant equipment continues to satisfy the

specified requirements.

provided for in the contract or by written approval from the responsible organization. Such temporary use shall not

subject the equipment or systems to conditions for which

they were not designed.

The temporary use authorization shall include:

(a) conditions of use or operation; (b) maintenance requirements; and (c) inspections and tests as required to maintain operability

and quality during the period of temporary use of item.

When temporary use is completed, conditions of temporary

use shall be evaluated to verify that the permanent plant

equipment continues to satisfy the most specified

requirements.

5. INSTALLED SYSTEMS INSPECTION AND TESTS 5 INSTALLED SYSTEMS INSPECTION AND TESTS 5.1 General

5.1 General

Following the installation of mechanical items, the checking, inspection, and testing activities shall be

performed to verify, that the completed systems are in

conformance with specified requirements. This is a final

verification that the requirements defined by licensing

commitments, drawings, specifications and other contract

documents are reflected in the completed installation. It is

also a time to verify that field modifications and other

changes made and controlled during installation activities

have been incorporated in the "as-built" documents.

Controls shall be provided for the identification, documentation, and resolution of nonconformances

disclosed by inspections or tests. Tests shall be conducted

on completed plant systems. Test procedures shall identify

prerequisites for system testing including required Following the installation of mechanical items, the checking inspection and testing activities shall be performed to

verify that the completed systems are in conformance with

specified requirements. This is a final verification that the

requirements defined by licensing commitments, drawings, specifications, and other contract documents are reflected

in the completed installation. It is also a time to verify that

field modifications and other changes made and controlled

during installation activities have been incorporated in the

as-built documents.

Controls shall be provided for the identification, documentation, and resolution of nonconformances

disclosed by inspections or tests.

Tests shall be conducted on completed plant systems. Test

procedures shall identify prerequisites for system testing, Similar requirement.

05/26/04 Page 21 of 27 Supplementary Quality Assurance Requirements For Installation, Inspection And Testing Of Mechanical Equipment And Systems For The Construction Phase Of Nuclear Power Plants ANSI N45.2.8 - 1975 Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for Nuclear Power Plants NQA-1 1994 Subpart 2.8 COMMENTS completed construction activities. The test procedure shall identify and describe any temporary or simulated condition

or equipment. If not previously planned, a documented

notice shall be prepared and issued with approval of the

responsible organization stating the substitutions that

existed for the test. Written verification shall also be

provided that temporary installations have been

satisfactorily replaced by the permanent installations.

Checks and inspections shall be performed to verify the

operational readiness and completeness of components

and systems. These systems or partial systems shall be

identified, tagged and released for operational testing.

These checks and inspections shall be performed to verify

the following as a minimum:

a. Equipment and materials have not sustained external

physical damage.

b. The installation has been made in accordance with

specified requirements.

c. All nonconforming items have been satisfactorily

dispositioned.

d. Internal and external restrictions and obstructions to

flow and full travel have been removed.

e. Supports and restraints are properly installed.

f. Interfacing connections with adjacent systems are

compatible.

g. Original material and component identification has been

preserved with provisions for traceability throughout the

installed systems.

h. Safety features such as interlocks, cable separation, guards, warning devices, and lockouts have been installed, are being used and comply with applicable codes and

regulations.

i. Temporary, connections such as jumpers and bypass including required completed construction activities. The test procedures shall identify and describe any temporary

or simulated condition or equipment. If not previously

planned, a documented notice shall be prepared and issued

with approval of the responsible organization stating the

substitutions that existed for the test. Written verification

shall also be provided that temporary installations have

been satisfactorily replaced by permanent installations.

Checks and inspections shall be performed to verify the

operational readiness and completeness of components

and systems. These systems or partial systems shall be

identified, tagged, and released for operational testing.

These checks and inspections shall be performed to verify

the following, as a minimum.

(a) Equipment and materials have not sustained external

physical damage.

(b) The installation has been made in accordance with

specified requirements.

(c) All nonconforming items have been satisfactorily dispositioned.(d) Internal and external restrictions and obstructions to

flow and full travel have been removed.

(e) Supports and restraints are properly installed.

(f) Interfacing connections with adjacent systems are

compatible.

(g) Original materials and component identification have

been preserved with provisions for traceability throughout

the installed systems.

(h) Safety features such as interlocks, cable separations, guards, warning devices, and lockouts have been installed, are being used, and comply with applicable codes and

regulations.

(i) Temporary connections, such as jumpers and bypass 05/26/04 Page 22 of 27 Supplementary Quality Assurance Requirements For Installation, Inspection And Testing Of Mechanical Equipment And Systems For The Construction Phase Of Nuclear Power Plants ANSI N45.2.8 - 1975 Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for Nuclear Power Plants NQA-1 1994 Subpart 2.8 COMMENTS lines and temporary trip points of control equipment are identified and, documented so that their final condition can

be verified.

j. System water chemistry is appropriate for operational

testing.

k. External surface chemistry requirements have been

maintained.

1. Permits and authorizations have been obtained.

lines, and temporary trip points of control equipment are identified and documented so that their final condition can

be verified.

(i) System water chemistry is appropriate for operational

testing.

(k) External surface chemistry requirements have been

maintained.

(I) Permits and authorizations have been obtained.

5.2 Preoperational

Testing

5.2 Preoperational

Testing This testing involves the operation of all items in a system, partial systems or systems to assure that operation is in

accordance with the design criteria and functional

requirements. The testing shall include, but not be limited

to the following:

a. Systems integrity.

b. In-line instrument installation is consistent with

specified flow directions.

c. Sensing lines are phased correctly to in-line elements

and sensors.

d. Service requirements for initial operation such as flow

alignments, limiting flow orificing and relief devices have

been performed.

e. Operation of controls, valves, dampers, operators, and

load limiting devices.

f. Rotating equipment (motors, pumps, blowers) - rotation, speed, vibration, noise, and no-load operation.

g. Handling equipment - load tests of cranes, hoists, conveyors, hooks, and handling adapters, and accessories.

h. Containment systems.

i. Air handling systems.

j. Fuel storage and handling systems.

k. Reactor components handling systems.

1. Instrument air systems.

This testing involves the operation of all items in a system(s) or partial system(s) to assure that operation is in

accordance with the design criteria and functional

requirements.

The testing shall include, but not be limited to, the

following:

(a) systems integrity; (b) in-line instrument installation is consistent with

specified flow directions; (c) sensing lines are phased correctly to in-line elements

and sensors; (d) service requirements for initial operation such as flow

alignments, limiting flow orificing, and relief devices have

been performed; (e) operation of controls, valves, dampers, operators, and

load limiting devices; (f) rotating equipment (motors, pumps, blowers),

rotation, speed, vibration, noise, and no-load operation; (g) handling equipment (load tests of cranes, hoists, conveyors, hooks, handling adapters, and accessories);

(h) containment systems; (i) air handling systems; (j) fuel storage and handling systems; (k) reactor component handling systems; Similar requirement.

05/26/04 Page 23 of 27 Supplementary Quality Assurance Requirements For Installation, Inspection And Testing Of Mechanical Equipment And Systems For The Construction Phase Of Nuclear Power Plants ANSI N45.2.8 - 1975 Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for Nuclear Power Plants NQA-1 1994 Subpart 2.8 COMMENTS m. Fluid service systems.

n. Waste effluent systems.

o. Auxiliary building systems.(l) instrument air systems;(m) fluid service systems; (n) waste effluent systems; (o) auxiliary building systems.

Where mechanical equipment and systems interface with, and their operation must coordinate with, non-mechanical

equipment or systems, the test performed shall include

verifying the compatibility of interfacing equipment and

functions. For additional information on inspections. tests

and procedures, see Section 6 of ANSI N18.7.

Where mechanical equipment and systems interface with, and their operation must coordinate with, nonmechanical

equipment or systems, the test performed shall include

verifying the compatibility of interfacing equipment and

functions.

Similar requirement.

Additional information on inspections and

tests is addressed in NQA-1, Basic

Requirements 10 and 11, and

Supplements 10S-1 and 11S-1.

5.3 Cold Functional Tests 5.3 Cold Functional Tests These tests follow preoperational testing of individual systems including reactor coolant systems. This testing

shall be performed to obtain operational data of equipment

with maximum allowable simultaneous operation of

interfacing systems and equipment and final verification of

functional performance of these systems..

These tests follow preoperational testing of individual systems, including reactor coolant systems. This testing

shall be performed to obtain operational data of equipment

and maximum allowable simultaneous operation of

interfacing systems and equipment, the final verification of

functional performance of these systems.

Similar requirement.

5.3.1 Reactor

Coolant System Hydrostatic Tests.

5.3.1 Reactor

Coolant System Hydrostatic Tests.

As applicable to the reactor system type, hydrostatic tests to verify conformance to specified requirements when

performed on the reactor coolant system, shall include all

or parts of connected systems which cannot be isolated

from the test pressure. The applicable test requirements

are contained in Section III of the Code.

As applicable to reactor system type, hydrostatic tests to verify conformance to specified requirements, when performed on the reactor coolant system, shall include all

or parts of connected systems which cannot be isolated

from the test pressure. The applicable test requirements

are contained in Section Ill of the ASME Boiler and Pressure Vessel Code.

Similar requirement.

5.3.2 Functional

and Flow Testing.

5.3.2 Functional

and Flow Testing.

The required individual systems shall be tested to demonstrate cold functional operability of individual

components, subsystems and systems, and to demonstrate

compatibility with other systems. These tests, where

appropriate, shall demonstrate the following:

a. System pressure drop.

The required individual systems shall be tested to demonstrate cold functional operability of individual components, subsystems, and systems, and to demonstrate compatibility with other systems. These tests, where

appropriate, shall demonstrate the following:

(a) system pressure drop Similar requirement.

05/26/04 Page 24 of 27 Supplementary Quality Assurance Requirements For Installation, Inspection And Testing Of Mechanical Equipment And Systems For The Construction Phase Of Nuclear Power Plants ANSI N45.2.8 - 1975 Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for Nuclear Power Plants NQA-1 1994 Subpart 2.8 COMMENTS b. Flow rate.

c. Controls and throttling device settings.

d. Function of interlocks, alarms and automatic features.

e. Instrument calibration.

f. Setting of meter biases.

g. Systems stability.

h. Adequacy of pipe and equipment support settings.

I. Heat runs on rotating equipment.

j. Adequacy of ventilation, lubrication and cooling systems

under sustained operating conditions.

k. Ability to meet water chemistry requirements (b) flow rate (c) controls and throttling device settings (d) function of interlocks, alarms, and automatic features (e) instrument calibration (f) setting of meter biases (g) system stability (h) adequacy of pipe and equipment support settings (i) heat runs on rotating equipment (j) adequacy of ventilation, lubrication, and cooling systems

under sustained operating conditions (k) ability to meet water chemistry requirements 5.4 Hot Functional Tests 5.4 Hot Functional Tests These tests are not applicable to BWR and HTGR nuclear plants because these plants use nuclear heat to

produce the system temperatures. Hot functional tests for

PWR plants follow cold functional tests and simulate plant

operating conditions at elevated temperatures and

pressures. All auxiliary and support systems exclusive of

those required for pre-criticality testing must be available

for these tests. If any of these systems are not available, the responsible organization shall specifically authorize

exclusion of these systems or subsystems from testing

and document those exceptions.

These systems shall include the following as a minimum:

a. System pressure drop.

b. Flow rate.

c. Controls and throttling device settings.

d. Function of interlocks, alarms and automatic features.

e. Instrument calibration.

f. Setting of meter biases.

g. Systems stability.

h. Adequacy of pipe and equipment support settings.

I. Heat runs on rotating equipment.

These tests are not applicable to BWR and HTGR nuclear plants because these plants use nuclear heat to produce

the system temperatures. Hot functional tests for PWR

plants follow cold function tests and simulate plant

operating conditions at elevated temperatures and

pressures. All auxiliary and support systems exclusive of those required for precriticality testing must be available for these tests. If any of these systems is not available, the

responsible organization shall specifically authorize

exclusion of these systems from testing and document

those exceptions.

These systems shall include the following as a minimum:

(a) system pressure drop (b) flow rate (c) controls and throttling device settings (d) function of interlocks, alarms, and automatic features (e) instrument calibration

( f ) setting of meter biases (g) system stability (h) adequacy of pipe and equipment support settings (i) heat runs on rotating equipment Similar requirement.

05/26/04 Page 25 of 27 Supplementary Quality Assurance Requirements For Installation, Inspection And Testing Of Mechanical Equipment And Systems For The Construction Phase Of Nuclear Power Plants ANSI N45.2.8 - 1975 Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for Nuclear Power Plants NQA-1 1994 Subpart 2.8 COMMENTS j. Verification of heat exchanger performance.

k. Verification of boron control system performance.

1. Thermal insulation effectiveness.

m. Set points of temperature, pressure and level devices.

n. System heatup tests.

o. System cooldown tests.

p. Hot flow tests.

q. Setting protective devices.

r. Hot clearances.

s. Vibration measurements of major equipment and piping, as applicable.(j) verification of heat exchanger performance (k) verification of boron control system performance (l) thermal insulation effectiveness (m) set points of temperature, pressure, and level devices (n) system heatup tests (o) system cooldown tests (p) hot flow tests (q) setting protective devices (r) hot clearances (s) vibration measurements of major equipment and piping, as applicable

6. DATA ANALYSIS AND EVALUATION 6 DATA ANALYSIS AND EVALUATION Procedures shall be established for processing inspection and test data and their analysis, evaluation, and final

acceptance. These procedures shall identify individuals or

organizations responsible for the acquisition and reduction

of inspection and test data and evaluation against

acceptance criteria, operating limits, and performance

standards. The data processing procedure should provide

for preliminary evaluation to determine the validity of the

inspection and test results, and the appropriateness of

continuing the inspection or test. The data shall be

analyzed and evaluated to verify completeness of results, achievement of inspection and test objectives, and

operational proficiency of equipment and systems; to

identify additional inspection or test requirements or both;

and to identify necessary changes to the installation

inspection or test procedures. Inspection and test results

supported by the inspection and test data, together with a

report of data analysis and evaluation, shall be provided as

specified in Section 7.

Procedures shall be established for processing inspection and test data and their analysis, evaluation, and final

acceptance. These procedures shall identify individuals or

organizations responsible for the acquisitions and reduction

of inspection and test data, and evaluation against

acceptance criteria, operating limits, and performance

standards. The data processing procedure shall provide for

preliminary evaluation to determine the validity of the

inspection and test results and the appropriateness of

continuing the inspection or test. The data shall be

analyzed and evaluated to verify completeness of results, achievement of inspection and test objectives, and

operational proficiency of equipment and systems; to

identify additional inspection or test requirements or both;

and to identify necessary changes to the installation

inspection or test procedures. Inspection and test results

supported by the inspection and test data, together with a

report of data analysis and evaluation, shall be provided as

specified in Section 7.

Similar requirement.

7. RECORDS 7 RECORDS Record copies of completed procedures; reports; required Record copies of procedures, reports, required Similar requirement. NQA-1 establishes 05/26/04 Page 26 of 27 Supplementary Quality Assurance Requirements For Installation, Inspection And Testing Of Mechanical Equipment And Systems For The Construction Phase Of Nuclear Power Plants ANSI N45.2.8 - 1975 Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for Nuclear Power Plants NQA-1 1994 Subpart 2.8 COMMENTS qualification records, test equipment calibration records; test deviation or exception records; and inspection, examination and check records shall be prepared. These

shall be placed with other project records as required by

code, standard, specification or project procedures.

Collection, storage and maintenance of quality assurance

records shall be in accordance with ANSI N45.2.9.

qualification records, test equipment calibration records, test deviation or exception records, and inspection, examination, and check records shall be prepared. These

records shall be retained with other project records as

required by code, standard, specification, or project

procedures.

requirements for collection, storage, and maintenance of records in Part I, Basic

Requirement 17 and Supplement 17S-1.

8. REVISION OF AMERICAN NATIONAL STANDARDS REFERRED TO IN THIS DOCUMENT

When the following, standards referred to in this

document are superseded by a revision approved by the

American National Standards Institute, the revision is not

mandatory until it has been incorporated as a part of this

standard. Revisions of the referenced standards, and

revisions to this standard issued after the date of a

specific contract invoking this standard may be used by

mutual consent of the purchaser and the supplier.

N18.7-1972 Administrative Controls for Nuclear Power

Plants N45.2-1971 Quality Assurance Program Requirements

for Nuclear Power Plants

N45.2.1-1973 Cleaning of Fluid Systems and Associated

Components During the Construction Phase of Nuclear

Power Plants

N45.2.2-1972 Packaging, Shipping, Receiving, Storage

and Handling of Items for Nuclear Power Plants (During

the Construction Phase)

N45.2.3-1973 Housekeeping During the Construction

Phase of Nuclear Power Plants

N45.2.6-1973 Qualifications of Inspection, Examination

and Testing Personnel for the Construction Phase of

Nuclear Power Plants

N45.2.9-1974 Requirements for Collection, Storage and See the comment associated with N45.2.8 § 1.5 regarding referenced standards.

05/26/04 Page 27 of 27 Supplementary Quality Assurance Requirements For Installation, Inspection And Testing Of Mechanical Equipment And Systems For The Construction Phase Of Nuclear Power Plants ANSI N45.2.8 - 1975 Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for Nuclear Power Plants NQA-1 1994 Subpart 2.8 COMMENTS Maintenance of Quality Assurance Records for Nuclear Power Plants

N45.2.10-1973 Quality Assurance Terms and Definitions 05/26/04 Page 1 of 23 ANSI N45.2.2-1972, Section 7. Handling Quality Assurance Requirements for Hoisting, Rigging, and Transporting Items for Nuclear Power Plants NQA-1 1994 Subpart 2.15 COMMENTS Note: Some of this information was previously addressed in ANSI N45.2.2-1972 and endorsed by NRC Regulatory Guide

1.38-Rev. 2. Applicable sections are shown below. One

Regulatory Position and VA alternative are described below

regarding re-rating of hoisting equipment (NQA-1, § 6.1.4).

1 GENERAL Subpart 2.15 provides requirements for the design, manufacture, acceptance, testing, and use of hoisting, rigging, and transporting equipment to maintain the quality of

designated nuclear power plant items which require special

handling. It supplements the requirements of Part I and shall

be used in conjunction with applicable Basic and

Supplementary Sections of Part I when and to the extent

specified by the organization invoking Subpart 2.15.

This subpart of NQA-1 addresses additional functions

above the actual handling

discussed in N45.2.2, Section 7.

1.4 Definitions

1.1 Definitions The following definitions are provided to assure a uniform understanding of select terms as they are used in this standard.

The following definitions are provided to assure a uniform understanding of unique terms as they are used in Subpart

2.15.NQA-1 includes additional definitions above what was in

N45.2.2.accepted industry standard - a standard established by a group representing individual members from various facets of an

industry who normally are those engaged in manufacturing.

This standard is accepted by the responsible organization.

Examples are:

AGMA - American Gear Manufacturers Association AISC - American Institute of Steel Construction

AISE - Association of Iron and Steel Engineers consensus standard - a standard established by a group representing a cross section of a particular industry or trade, or

a part thereof. A cross section includes those who purchase or

use a product of the industry or trade, as well as those who

produce these products.

Dynamic Load Test - A test to demonstrate the ability of hoisting equipment to safely handle its rated load by exercising the equipment through vertical and horizontal movement along

its lines of travel, using a load of specified weight.

dynamic load test - a test wherein designated loads are hoisted, lowered, rotated, or transported through motions and

accelerations required to simulate handling of the intended item Similar 05/26/04 Page 2 of 23 ANSI N45.2.2-1972, Section 7. Handling Quality Assurance Requirements for Hoisting, Rigging, and Transporting Items for Nuclear Power Plants NQA-1 1994 Subpart 2.15 COMMENTS equipment - manufactured assemblies which are used for the handling of items failure stress - that stress at which failure is imminent due to direct loads, excessive deflections or vibrations, or permanent

deformations that may lead to unsafe conditions handled load - the weight of the item to be lifted plus the weight of any required rigging, such as lifting beam, slings, hooks, and blocks Handling -

The act of physically moving items by hand or by mechanical machinery, not including transport modes.

handling - hoisting, rigging, or transporting of items for nuclear power plants Similar intent, but NQA-1 includes transport as part of

handling.person-in-charge (PIC) - the person who has overall responsibility for handling operations for his organization principal load carrying members - those components of a system whose structural integrity must be maintained to ensure

a safe operation principal structural welds - those welds which join or affect the integrity of principal load carrying members responsible organization - a company which is in direct charge of the equipment and manpower actually engaged in a handling

operation system - a combination of components arranged for a handling operation 7.1 General 2 GENERAL REQUIREMENTS This section contains requirements that are to be fulfilled by the organizations responsible for handling items. This section

covers the requirements for the handling of items in Subsection

2.7 of this standard utilizing appropriate equipment in

accordance with methods and procedures specified to

minimize damage and preserve the quality of the item and

container.

The requirements of Subpart 2.15 apply to any organization or individual participating in work relating to hoisting, rigging, and

transporting. Hoisting equipment used for handling shall be

certified by the manufacturer. The certification shall indicate

the various parameters for the maximum load to be handled.

Measures shall be established and implemented to perform

handling activities for nuclear power plant items (see Subpart

2.2, para. 2.2) and to perform the inspections, examinations, testing, and documentation to verify conformance to specified requirements. These measures are applicable to items that

require special handling because of weight, size, susceptibility Similar, but addresses the added scope of the standard. Includes

relevant general information of

N45.2.2, subsection 7.2.

05/26/04 Page 3 of 23 ANSI N45.2.2-1972, Section 7. Handling Quality Assurance Requirements for Hoisting, Rigging, and Transporting Items for Nuclear Power Plants NQA-1 1994 Subpart 2.15 COMMENTS to shock damage, high nil-ductility transition temperatures, or any other conditions that warrant special instructions to

preserve the quality of items and container. Where this

Subpart references the use of consensus standards, these

measures shall include the applicable requirements of the

ASME/ANSI B30 series, Safety Standards for Cableways, Cranes, Derricks, Hoists, Hooks, Jacks, and Slings, and of ANSI/ASME A l 0.5, Safety Requirements for Material

Hoists. Subpart 2.15 applies from the time these items are

ready for delivery.

Use of permanent plant handling equipment during the

construction phase is prohibited unless specifically authorized

by the plant owner and conducted in accordance with the plant

owner's Quality Assurance Program. If such equipment is to

be used during the construction phase, it shall be reviewed to

assure that such use conforms to paras. 4.1, 4.2, and 4.3; paras. 5.1, 5.2, and 5.3; paras. 6.1, 6.2, and 6.3, and Section 7, as applicable, in addition to the other requirements of Subpart 2.15.

After construction use and prior to release to the owner, the

permanent plant handling equipment shall be restored to its

design configuration, and it shall be inspected and tested as

specified in a procedure furnished by the owner or his

designee.

During subsequent use, the testing, inspection, and

maintenance shall be performed as specified by applicable

standards.

The requirements of Subpart 2.15 may also be extended to

other appropriate parts of nuclear power plants when specified

in contract documents, or to modifications involving operating

plants. For other requirements, see applicable sections of

Subpart 2.2.

7.2 Methods

and Procedures

2.1 Planning

and Procedures Detailed handling instructions and procedures shall be prepared for all items that require special handling instructions because Planning and procedure preparation shall be in accordance with the requirements of the introduction to this Part (Part II).

Similar requirements, includes requirement to comply with 05/26/04 Page 4 of 23 ANSI N45.2.2-1972, Section 7. Handling Quality Assurance Requirements for Hoisting, Rigging, and Transporting Items for Nuclear Power Plants NQA-1 1994 Subpart 2.15 COMMENTS of weight, size, susceptibility to shock damage, high nil ductility transition temperatures, or any other conditions that warrant

special instructions. Such instructions or procedures shall be

made available prior to the time the item is to be handled and

shall give weights, sling locations, balance points, methods of

attachment, maximum hoist line speeds and other pertinent

features to be considered as necessary for safe handling.

Items not specifically covered above shall be handled in

accordance with sound material handling practices.

Procedures and instructions shall contain sufficient detail such as weights, sling locations, balance points, methods of

attachment, maximum hoist line speeds, and other pertinent

features to be considered as necessary for safe handling to

govern handling operations, inspection thereof, and

documentation in accordance with this Part. Planning shall

provide for compliance with applicable federal, state, and local

regulations.

applicable regulations.

2.2 Classification

of Items Handled The requirements for activities covered by Subpart 2.15 are based on classifying the items into three categories according

to their important physical characteristics. It is recognized that

within the scope of each category there may be a range of

controls, and that the need for, and extent of detailed handling

requirements for an item, is dependent on the importance of

the item to safe, reliable operation of the plant and the

complexity of the operation. Pertinent manufacturer's

requirements shall be considered when classifying the items.

Items for which handling activities are covered by Subpart

2.15 shall be classified into one of the three categories below.

An item shall not be reclassified to a lower status without

approval by the responsible organization which assigned the

original category.

Classification not addressed in N45.2.2, and the current

programs may not specifically

use these categories. Alternative

proposed to not necessarily use

these specific category

designations, but ensure the

applicable requirements are met

for the individual handling

operations.

2.2.1 Category

A.

Items classified in Category A are those that require specially selected equipment and detailed procedures for handling

operations because of large size and weight. Examples of

items that may be assigned to this category are:

(a) reactor vessels (b) steam generators (c) major components of reactor vessel internals (d) primary system pressurizers (e) spent fuel casks (f ) subassemblies requiring specially selected equipment 05/26/04 Page 5 of 23 ANSI N45.2.2-1972, Section 7. Handling Quality Assurance Requirements for Hoisting, Rigging, and Transporting Items for Nuclear Power Plants NQA-1 1994 Subpart 2.15 COMMENTS because of size or weight, such as prestressed concrete reactor vessel liners

2.2.2 Category

B Items classified in Category B are those that may be handled with conventional handling equipment but which require

detailed procedures because of the susceptibility to damage.

Examples of items that may be assigned to this category are:

(a) reactor vessel head (b) primary and intermediate coolant pumps and their internals (c) designated instrument cabinets and control boards (d) control rod drive mechanisms (e) helium circulators (f ) fuel handling equipment (g) purification equipment (h) fuel (i) core components (small)

2.2.3 Category

C.

Items classified in Category C are those that may be handled with conventional equipment using sound rigging practice.

Included in this category are both construction and permanent plant items not included in Categories A and B

.3 TYPES OF HANDLING EQUIPMENT Equipment used for handling of items, as covered by this Part, can be divided into four general types. Paragraphs 3.1, 3.2, 3.3, and 3.4 define these four types of handling equipment and list

some examples.

3.1 Standard

Manufactured Component Handling equipment classed as a standard manufactured component is equipment which is available for several sources.

This equipment is normally a catalog item, generally kept in

stock, and normally used as a component of a handling system.

Examples of standard manufactured components are:

(a) chains and chain accessories such as hooks, shackles, and

links; (b) fiber ropes and accessories; 05/26/04 Page 6 of 23 ANSI N45.2.2-1972, Section 7. Handling Quality Assurance Requirements for Hoisting, Rigging, and Transporting Items for Nuclear Power Plants NQA-1 1994 Subpart 2.15 COMMENTS (c) hooks such as link or eye type, single, sister, and miscellaneous; (d) transporting devices such as casters, rollers, shoes, and

wheels; (e) wire rope and wire rope accessories such as blocks, clamps, sockets, thimbles, and turnbuckles; (f) miscellaneous items such as cribbing, eyebolts, pads, swivel

devices, links, shackles, and sheaves.

3.2 Commercial

Standard Design Equipment Commercial standard design equipment for handling is equipment which is available as an item of standard design and

manufacture. Examples of commercial standard design

equipment are:

(a) gantry, mobile, overhead, and jib cranes; (b) guys and stiffleg derricks;(c) hoists, winches, and trolleys;(d) jacks and jacking systems; (e) transporting devices such as forklift trucks, railcars, tractors, trailers, and transporters; (f) elements of commercial standard design equipment such as

booms, masts, and struts; (g) other optional standard accessories and adaptations

available from the equipment manufacturer, 3.3 Special Designed Equipment Special designed equipment for handling is equipment which is not available from a commercial source as a catalog or

standard designed item, or equipment for which no generally

accepted consensus standard exists. This type of equipment

may be designated and fabricated by using standard

manufactured components and commercial standard designed

equipment or by using a combination of nonstandard and standard equipment. Examples of special designed equipment are:

(a) special gin poles, derricks, and jacking towers; (b) special crane supports such as runways, columns, and 05/26/04 Page 7 of 23 ANSI N45.2.2-1972, Section 7. Handling Quality Assurance Requirements for Hoisting, Rigging, and Transporting Items for Nuclear Power Plants NQA-1 1994 Subpart 2.15 COMMENTS frames;(c) rigging devices such as spreader beams, strongbacks, upend and downend devices, bolsters, and yokes;(d) transporting systems such as dollies, special rail cars, and transporters.

3.4 Permanent

Plant Handling Equipment Permanent plant handling equipment employed for handling nuclear plant items is equipment which is intended primarily for

maintenance and operation of the nuclear power plant but

which may also be used for construction. It may consist of

standard manufactured components as defined in para. 3.1, commercial standard design equipment as defined in para. 3.2, or special designed equipment as defined in para. 3.3.

Examples of permanent plant handling equipment are: (a) fuel handling equipment; (b) overhead and gantry cranes for reactor and auxiliary (spent

fuel) buildings.

4 DESIGN REQUIREMENTS Due to the wide range of equipment normally used in the handling of items for nuclear plants, it is appropriate that

different criteria be used for designing different types of

handling equipment. This Section describes specific design

criteria which are appropriate for most applications and which

are recommended for general use. If it can be shown that

these criteria are not appropriate for specific application, the

engineer responsible shall select compatible criteria and

document the justification. It is recognized that some items are

also covered by other standards, which may be more stringent

than Subpart 2.15, and items must meet requirements of both.

Hoisting, rigging, and transporting equipment which is to be

used exclusively during the construction phase shall be

designed in accordance with paras. 4.1, 4.2, and 4.3.

Permanent plant handling equipment is designed and selected in accordance with other standards.

The organization responsible for the design shall establish a 05/26/04 Page 8 of 23 ANSI N45.2.2-1972, Section 7. Handling Quality Assurance Requirements for Hoisting, Rigging, and Transporting Items for Nuclear Power Plants NQA-1 1994 Subpart 2.15 COMMENTS program for assuring that the handling equipment conforms to the design requirements of the applicable potions of Subpart

2.15.4.1 Standard Manufactured Components Standard manufactured components shall be selected to safely perform the intended operations structurally, mechanically, and

electrically. They shall have been designed to conform to

accepted industry standards.

4.2 Commercial

Standard Design Commercial standard design equipment shall be selected to safely perform the intended operations structurally, mechanically, and electrically. They shall have been designed

to conform to consensus standards, or when a consensus

standard is not totally adequate, to accepted standards.

4.3 Special

Designed Equipment Special designed equipment shall be designed to safely perform the intended operations structurally, mechanically, and

electrically. Standard manufactured components or

commercial standard design equipment, or elements thereof, incorporated into the total system, shall meet the requirements

of paras. 4.1 and 4.2, respectively, with safety factors as recommended by the manufacturer of the components and equipment.

4.3.1 Structural.

Structural design of the equipment, except as noted in (a) through (j), shall be in accordance, as applicable, with the latest

accepted edition of Manual of Steel Construction of the

American Institute of Steel Construction, Timber Construction

Manual of the American Institute of Timber Construction, and

Building Code Requirements for Reinforced Concrete (AC1

318) of the American Concrete Institute.

(a) Equipment components shall be designed for the

appropriate combination of vertical and horizontal loads.

(b) The effects of seismic activity need not be included in

combination with lifting or transporting operations during 05/26/04 Page 9 of 23 ANSI N45.2.2-1972, Section 7. Handling Quality Assurance Requirements for Hoisting, Rigging, and Transporting Items for Nuclear Power Plants NQA-1 1994 Subpart 2.15 COMMENTS construction.(c) Winds in excess of 50 mph (80.5 km/h) normally need not

be considered in combination with lifting or transporting

operations as these operations are normally suspended before

winds exceed 50 mph (80.5 km/h). If available historical wind

data indicate the likelihood of operations occurring during

winds greater than 50 mph (80.5 km/h), such data shall be

utilized as the basis of design. ANSI A58.1, Minimum Design

Loads for Buildings and Other Structures, shall be used to

determine the appropriate wind loads. If these forces have not

been considered in design, the lifting and transporting activities

shall be suspended before winds reach 50 mph (80.5 km/h).

(d) Special designed equipment normally is designed for a

limited number of operations. Fatigue factors shall be included

where applicable.

(e) Vertical impact shall be considered in the design, and

selection of impact loads shall be supported by analysis. In no

case shall vertical impact load be less than 10% of maximum

handled load, excluding test load.

(f) Longitudinal and transverse horizontal forces shall be

determined by the maximum acceleration or deceleration

which can be delivered by the complete hoisting or transporting

system, the maximum grades or slide slopes encountered, maximum out-of-plumb lift, wind, and similar loads. In no case

shall longitudinal or transverse horizontal forces be less than

2% of maximum handled load.

(g) For the entire system considered as a whole, the ratio of failure stress to calculated stress shall be no less than 1.67.

This minimum ratio shall exist after considering such factors as

unequal load distribution, stability, slenderness ratios, and joint

efficiencies.

(h) Calculated stresses developed by handling the combination

of dynamic test load and vertical impact, plus longitudinal or

transverse horizontal loads, if applicable, shall not exceed

133% of allowable stresses.

05/26/04 Page 10 of 23 ANSI N45.2.2-1972, Section 7. Handling Quality Assurance Requirements for Hoisting, Rigging, and Transporting Items for Nuclear Power Plants NQA-1 1994 Subpart 2.15 COMMENTS (i) Nondestructive examinations to be performed during manufacture and the acceptance criteria for these

examinations shall be specified by the responsible design

organization. Particular attention shall be given to lamellar tearing, highly restrained connections, and welds joining load carrying members.

(j) Guys and guyed systems, such as column supported girders

with traveling hoists, gallows, frames, guyed derricks, and

similar equipment, shall be designed to provide system stability

and restraint by:

(1) maintenance columns, poles, or masts in the desired position and within desired tolerances; (2) providing capability to resist forces caused by handling

Operations, impact, wind, opposing guys, eccentricity, and

other similar causes.

The design shall consider the following as a minimum: (a) handled load (b) height of column and column capability (c) slope of the guys (d) load sharing of multiple guyed systems (e) pretension requirements (f )physical characteristics or wire rope, such as area, modulus of elasticity, and spring constant (g) footing and anchorage adequacy (h) secondary loads caused by stretch of guys (i) safety factors (j) end connections (k) Nil-ductility transition temperatures shall be considered in the design. Design criteria shall be selected by the organization responsible for the design.

4.3.2 Mechanical.

The following special conditions apply to the mechanical design.

(a) Special designed equipment normally is designed for a

single operation, or for a limited number of operations. Life, 05/26/04 Page 11 of 23 ANSI N45.2.2-1972, Section 7. Handling Quality Assurance Requirements for Hoisting, Rigging, and Transporting Items for Nuclear Power Plants NQA-1 1994 Subpart 2.15 COMMENTS durability, and fatigue factors shall be included where applicable.(b) Gearing shall be designed by use of American Gear Manufacturers Association formulas, or equivalent formulas, for strength only.

(c) Each independent wire rope or chain and sprocket hoisting

unit shall have at least one holding brake. At the place where

the brake is applied, the minimum static torque rating shall be

150% of the torque required to hold the maximum load to be

handled, excluding the test load.

(d) Engines, gear boxes, torque converters, couplings, hydraulic

jacks, pumps, valves, fittings, lines, and similar components

used for hoisting operations shall be designed in conformance

with the consensus standard and shall be sized to:

(1) handle load, excluding test load, within the manufacturer's rated capacity;

(2) operate continuously during the specified duty cycle;

(3) safely resist maximum loads imposed by emergency braking.(e) Hydraulic circuit design shall take into consideration the need for design features which minimize possibilities of

unexpected lowering of loads.

(f) Engines, electric motors, brakes, gear boxes, cylinders, bearing housings, and similar components which support any part of the load shall be secured to the main structure in such a

way that the entire system, including components, meets

structural requirements to adequately support the load.

(g) Rigidity of machinery base, shafts, and similar components

shall be adequate to permit proper functioning of the equipment

under operating conditions.

4.3.3 Electrical.

The following special conditions apply to the electrical design.(a) Electrical components and wiring used for hoisting

operations shall be designed in conformance with consensus

standards and shall be sized to:

05/26/04 Page 12 of 23 ANSI N45.2.2-1972, Section 7. Handling Quality Assurance Requirements for Hoisting, Rigging, and Transporting Items for Nuclear Power Plants NQA-1 1994 Subpart 2.15 COMMENTS (1) lift the handled load, excluding test load, within the manufacturer's rated capacity;

(2) operate continuously during the specified duty cycle;

(3) be compatible with mechanical requirements for brakes in accordance with para. 4.3.2(c).(b) Electrical circuits shall contain provisions for proper grounding and shall incorporate design features to minimize

possibilities of unexpected lowering of load.

5 ACCEPTANCE CRITERIA FOR MANUFACTURED HANDLING EQUIPMENT

7.3 Hoisting

Equipment All equipment for handling items shall be used and maintained in accordance with the following:

7.3.1 Hoisting

equipment used for handling shall be certified by

the manufacturer. The certification shall indicate the various

parameters for the maximum load to be handled.

7.3.2 Hoisting

equipment shall not be loaded beyond its rated

load, as certified by the manufacturer, except for test

purposes.

7.3.3 The requirements of ANSI B30.2.0, Safety Standard for

Overhead and Gantry Cranes, ANSI B30.5, Safety Standard

for Crawler, Locomotive and Truck Cranes, ANSI B30.6, Safety Standard for Derricks, and ANSI A10.5, Safety

Requirements for Material Hoists shall be followed.

This Section contains the requirements for manufacture and acceptance of manufactured equipment, structures, and

accessories used in the handling of nuclear power plant items.

There is not a one-for-one correlation of these N45.2.2

requirements to the NQA-1, Subpart 2.15 requirements.

However, the requirements from

N45.2.2 are all addressed, and/or expounded upon, throughout Sections 5, 6, and 7

of the NQA

-1 Subpart.

5.1 Standard

Manufactured Components Standard manufactured components shall be manufactured and accepted in accordance with accepted industry standards.

5.2 Commercial

Standard Design Commercial standard design equipment shall be manufactured and accepted in accordance with applicable consensus

standards.

5.3 Special

Design Equipment Special design equipment shall be based upon one of the following criteria.

5.3.1 Acceptance

of existing equipment shall be based upon 05/26/04 Page 13 of 23 ANSI N45.2.2-1972, Section 7. Handling Quality Assurance Requirements for Hoisting, Rigging, and Transporting Items for Nuclear Power Plants NQA-1 1994 Subpart 2.15 COMMENTS one of the following criteria.(a) Historical data which show satisfactory performance in

handling loads within the design capability, which are equal to

or greater than the intended loads. This history would include

records of tests, inspections, and maintenance performed on

the equipment, along with the record of actual handling

operations.

(b) A load test in accordance with Section 6.

(c) Recognition of capability by an engineer or other qualified materials handling individual when the equipment is handling Category C items only.

5.3.2 Acceptance

criteria for new equipment and modifications to existing equipment shall conform with the following requirements.

(a) The design shall have been performed in accordance with

Section 4.

(b) Standard manufactured components or commercial

standard design equipment incorporated in the total system

shall meet the requirements of para.5.1 or 5.2.

(c) Structural steel elements shall be fabricated and erected in

accordance with the latest edition of AISC S302, Code of

Standard Practices for Buildings and Bridges. The following

additional items shall be required.

(1) Principal load carrying members shall be designated by the design organization responsible for either or both the design and application of the equipment. Materials of

principal load carrying members shall meet any one of the

following three qualifications: (a) record of meeting the minimum mechanical properties as documented by certified material test reports; (b) mechanical test report of a sample of the material

showing adequate mechanical properties (this may be

made by the manufacturer or a testing laboratory);

(c) conservatism of design, documented by engineer's

calculations [this option is acceptable only in emergency 05/26/04 Page 14 of 23 ANSI N45.2.2-1972, Section 7. Handling Quality Assurance Requirements for Hoisting, Rigging, and Transporting Items for Nuclear Power Plants NQA-1 1994 Subpart 2.15 COMMENTS situations, where last minute changes have proved necessary by field conditions, and where options (a) and (b) above are not available].

(2) Structural welds shall be made by qualified welders using qualified procedures in accordance with the applicable

requirements of the AWS D1.l, Structural Welding Code -

Steel.(3) Welds joining principal load carrying members shall be

inspected as described in Section 6.

(4) Structural elements of material other than steel shall be

constructed in accordance with applicable consensus or

accepted industry standards.(d) Operational tests of the entire system shall be conducted in accordance with Section 6.

(e) Recognition of capability by an engineer or other qualified

materials handling individual will suffice in lieu of (a), (c)(l),

and (d) above when the equipment is handling Category C

items only.

6 TESTING, INSPECTION, AND MAINTENANCE This Section defines requirements for testing, inspection, and maintenance to assure that the equipment will perform as

required for the safe handling of items at nuclear facilities.

6.1 Testing

A test program shall be established to demonstrate that the handling component or equipment will perform satisfactorily in

service. Testing may involve either operational or load type

tests, or a combination of the two. Operational type tests cover

checks of control functions and capabilities. Load type tests

ensure structural and mechanical capability. Test loads shall

normally be handled at the same speeds and rates of

acceleration (deceleration) as planned for the intended item, except that when dynamic test loads greater than 100% are

designated, the rates of acceleration (deceleration) may be

adjusted downward. in addition, the following shall apply as

applicable.

05/26/04 Page 15 of 23 ANSI N45.2.2-1972, Section 7. Handling Quality Assurance Requirements for Hoisting, Rigging, and Transporting Items for Nuclear Power Plants NQA-1 1994 Subpart 2.15 COMMENTS 6.1.1 Standard Manufacturing Components.

One of the following will satisfy the requirements for testing of these components:

(a) tests as required by applicable accepted industry standards (b) actual proof load tests by the manufacturer (c) dynamic load tests as part of the system being tested to

110% of the maximum load to be handled

6.1.2 Commercial

Standard Design Equipment.

One of the following will satisfy the requirements for testing of this equipment:

(a) tests as required by applicable consensus standard (b) a dynamic load test equal to 110% of the maximum load to

be handled

6.1.3 Special

Designed Equipment.

Requirements for testing of this equipment shall be as follows.(a) An operational test shall be performed. This test shall be

over the portion of the motions applicable to the handling

system tested.

(b) A dynamic load test equal to 110% of the maximum load to

be handled by the complete system shall be performed, except

that documented proof of equivalent handling ability as

described in para. 5.3.1(a) may be substituted. Transport equipment tests shall demonstrate adequacy of braking, drawbar pull, stability, and other similar factors. Testing shall

take place with equipment in the location where it will be used

for actual handling of the item, except that in cases where the

test would interfere with, or needlessly endanger an existing

item or the item to be lifted, testing may be conducted at

another location, on or near the construction site. Where

practical and useful, load tests shall be applied over the entire

range of motions required for the actual handling of the item, with the following exceptions.

(1) Spreader bars, jacks, slings, or similar items whose loading is independent of travel may be tested in test fixtures at locations other than the construction site.

05/26/04 Page 16 of 23 ANSI N45.2.2-1972, Section 7. Handling Quality Assurance Requirements for Hoisting, Rigging, and Transporting Items for Nuclear Power Plants NQA-1 1994 Subpart 2.15 COMMENTS (2) Transporting vehicles need not be tested over the entire length of travel.

During subsequent use, the testing, inspection, and maintenance shall be performed as specified by other

standards.

6.1.4 Rerated

Equipment.

7.3.4 For special lifts, hoisting equipment may be re-rated, or modified and re-rated, upon approval by the manufacturer or if

the manufacturer's specifications are not available, the

limitations assigned to the equipment shall be based on the

determinations of a qualified engineer competent in this field

and such determination shall be documented and recorded

appropriately. Re-rated equipment shall be given a dynamic

load test over the full range of the lift using a test weight at

least equal to the lift weight. A dynamic test includes raising, lowering and traversing the load in contrast to a static test

where the test weight may be increased incrementally with no

movement.NRC Regulatory Guide 1.38, Regulatory Position C.1.b:

b. Subdivision 7.3.4 of ANSI N45.2.2-1972 delineates requirements for re-rating hoisting equipment for special lifts.

This subdivision requires that re-rated equipment be given a

dynamic load test over the full range of the lift, using a test

weight at least equal to the lift weight. In lieu of this

requirement, the test weight used in temporarily re-rating

hoisting equipment for special lifts in accordance with the

provisions of subdivision 7.3.4 should be at least equal to 110%

of the lift weight.

Clarification from the current VA QATR:

(23) With regard to Section 7.3 of ANSI N45.2.2-1972, titled Hoisting Equipment

Rerating of hoisting equipment will be considered only when absolutely necessary. Prior to performing any lift above the load rating, the equipment

manufacturer must be contacted for his approval and direction.

The manufacturer must be requested to supply a document For special lifts, hoisting equipment may be rerated, or modified and rerated, upon approval by the manufacturer or, if the manufacturer's specifications are not available, the limitations assigned to the equipment shall be based on the

determinations of a qualified engineer competent in this field

and such determination shall be documented and recorded

appropriately.

Rerated equipment shall be given a dynamic load test over the

full range of the lift using a test weight at least equal to 110%

of the lift weight. A dynamic test includes raising, lowering, and traversing the load, in contrast to a static test, in which the

test weight may be increased incrementally with no movement.

NRC Regulatory Position is incorporated into the NQA-1

requirements.

The level of detail in the

previous QA program alternative

should be contained in the

implementing procedures rather

than the QA Program

description.

05/26/04 Page 17 of 23 ANSI N45.2.2-1972, Section 7. Handling Quality Assurance Requirements for Hoisting, Rigging, and Transporting Items for Nuclear Power Plants NQA-1 1994 Subpart 2.15 COMMENTS granting approval for a limited number of lifts at the new rating and any restrictions involved, such as modifications to be made

to the equipment, the number lifts to be made at the new

rating, and the test lift load. At all times, the codes governing

rerating of hoisting equipment must be observed. If rerating hoisting equipment is necessary and the Company cannot or does not contact the equipment manufacturer as described

above, the test weight used in temporarily rerating hoisting equipment for special lifts will be at least equal to 110% of the lift weight. A dynamic load test over the full range of the lift

using a weight at least equal to the lift weight shall be

performed.

7.4 Inspection

of Equipment and Rigging

6.2 Inspection

An inspection program shall be established for equipment and rigging. A system shall be established that will indicate

acceptability of all equipment and rigging after each inspection.

This system shall specify control of nonconforming lifting

equipment. Periodic inspections shall be supplemented with

special visual and non-destructive examinations and dynamic

load tests prior to handling of items described in Subsection 7.2

of this standard.

7.4.1 Rigging

that is frayed, worn or otherwise deteriorated

shall not be used.

7.4.2 Hoisting

equipment that does not meet manufacturer's

specifications shall not be used.

7.4.3 Equipment

and rigging shall be kept clean and free of

contaminants that are detrimental to the material being

handled.

7.4.4 Rigging

items such as hooks, shackles and turnbuckles

that appear to have yielded or are distorted shall not be used.

Handling equipment in use shall be subjected to inspection.

Inspections as detailed herein include three types: frequent, periodic, and major. Evidence of inspections and the results of

periodic and major inspections shall be documented.

There is not a one-for-one correlation between the

subsections of N45.2.2 to the

Inspection requirements of

NQA-1. However, the intent of

the required inspections is met

through the requirements of this

subsection to NQA-1, Subpart

2.15.6.2.1 Frequent Inspections.

Frequent inspections are those performed on a day-to-day or similarly frequent basis. The inspections shall conform to the

consensus standards and federal, state, and local health and

safety regulations. The inspection coverage shall include parts 05/26/04 Page 18 of 23 ANSI N45.2.2-1972, Section 7. Handling Quality Assurance Requirements for Hoisting, Rigging, and Transporting Items for Nuclear Power Plants NQA-1 1994 Subpart 2.15 COMMENTS essential to safe operation plus those parts recommended by the manufacturer. A checklist shall be used to perform the

inspections. These inspections shall be performed by the

individual responsible for the operation of the particular

equipment or by another competent individual.

6.2.2 Periodic

Inspections.

Periodic inspections are those performed on a preset interval.

The inspections shall conform to the consensus standards and

federal, state, and local safety regulations. The inspection

coverage shall include parts essential to safe operation plus

those parts recommended by the manufacturer. If a system or

component is not included in established codes or standards, it

shall be included in a planned, scheduled inspection program

developed by the organization responsible for its use and

operation. Personnel qualified by experience or special training, as determined by the organization responsible for the

inspection, shall perform such inspections. Results of periodic

inspections shall be documented.

6.2.3 Major

Inspections.

Major inspections are those performed on an as-specified basis and shall conform to a procedure prepared by the responsible

organization. The procedure shall also state when the

inspections are to be performed. Inspection coverage shall

include recommendations of the manufacturer or designer.

Visual examinations or nondestructive examinations shall be

used for these inspections as deemed necessary by the

designer of the component or system and by the organization

responsible for its use and operation. Particular attention shall

be paid to the following as applicable:

(a) welds at joints between highly stressed members; (b) welds at joints in principal load carrying members and

highly restrained members; (c) excessive deformation in principal load carrying members

or parts; (d) adequacy of brakes under both static and dynamic 05/26/04 Page 19 of 23 ANSI N45.2.2-1972, Section 7. Handling Quality Assurance Requirements for Hoisting, Rigging, and Transporting Items for Nuclear Power Plants NQA-1 1994 Subpart 2.15 COMMENTS loadings;(e) response and positiveness of controls;(f) accuracy and response of load indicators;(g) overheating of power supply.

Welds to be inspected shall be inspected in accordance with

the applicable requirements of AWS D1.l, Structural Welding

Code - Steel. Nondestructive examinations performed during

these inspections shall be performed by an individual certified

to Recommended Practice SNT-TC-1A.

Other parts of these inspections shall be performed by

personnel qualified by experience or special training, as

determined by the organization responsible for the inspections.

Results of major inspections shall be documented.

6.3 Maintenance

A maintenance program shall be established to ensure that the handling equipment is maintained in good operating condition.

The program shall provide for adequate protection of

equipment which is used in an environment other than the

environment for which it is designed. Those responsible for

operation of equipment shall be responsible for maintenance.

6.3.1 Prerequisites.

Equipment shall be serviced at specified intervals in accordance with the manufacturer's recommendations, severity of service, and environment. Items damaged or worn

sufficiently to affect operation of equipment shall be repaired

or replaced before continuing operations. Replacement parts

shall meet or exceed the specifications of the part being

replaced.6.3.2 Records.

Maintenance shall be documented and the records kept current. These records shall show lubrication, servicing, adjustments, repairs, and replacement of the equipment.

7 CONTROL OF THE USE OF HANDLING EQUIPMENT This Section contains requirements to be fulfilled by the 05/26/04 Page 20 of 23 ANSI N45.2.2-1972, Section 7. Handling Quality Assurance Requirements for Hoisting, Rigging, and Transporting Items for Nuclear Power Plants NQA-1 1994 Subpart 2.15 COMMENTS organizations that will have operational control of the handling equipment in use at a nuclear power plant. These organizations

shall appoint a person-in-charge (PIC). The PIC shall assure

that procedures are provided as required; and he shall provide

surveillance over the activities of personnel associated with the

handling operations to ensure that the procedures are being

followed, that specified quality assurance requirements are

being met, and that good handling practices are being followed.

7.1 Handling

Category A Items 7.1.1 Prerequisites.

Prior to the handling of a specified item and initial use of equipment, it shall have been verified that:

(a) design and manufacture of the equipment are in

accordance with Sections 4 and 5;(b) the load carrying capability has been established in accordance with Section 6, and it equals or exceeds the load to

be handled; (c) the equipment has been maintained in accordance with Section 6;(d) handling and moving clearances have been investigated and

are satisfactory; (e) set down and installation areas have been cleared and

prepared as required and are ready to receive the item.

7.1.2 Procedures.

The handling of Category A items shall be in accordance with written approved procedures, and associated instructions or

drawings, as applicable. The procedures shall include the

following as a minimum.

(a) Responsibilities shall be defined for organizations and key

responsible individuals. Their qualifications shall be in

accordance with Section 8.

(b) Handling equipment to be used shall be identified, and its

selection shall be on the basis of its capability to handle the

load. Loads handled shall not exceed the loads used in the

design of the equipment.

05/26/04 Page 21 of 23 ANSI N45.2.2-1972, Section 7. Handling Quality Assurance Requirements for Hoisting, Rigging, and Transporting Items for Nuclear Power Plants NQA-1 1994 Subpart 2.15 COMMENTS (c) Manufacturer's instructions and conditions of operation shall be followed for the handling equipment and items to be

handled.

(d) Work instructions shall be issued for tasks which, because

of their relationship to each other, must be accomplished in a

certain sequence.

(e) Where applicable, acceptance criteria shall be specified for

determining when a task has been satisfactorily completed.

(f) Inspection checkpoints shall be included when

documentation by specific individuals is required as proof of

satisfactory completion. Final documentation review and sign-

off shall be made to verify that the operations have been

performed in accordance with the procedures.

(g) Procedures shall identify maximum safe loads which are

permissible and shall describe specific methods of ensuring

that these safe loads are not exceeded. Load indicating

devices, properly calibrated, shall be used in systems where

the primary source of power has the capability of imposing

excessive loads on the equipment, component, or item being

handled.

(h) The need for soils tests shall be considered. (See Section 3

of Appendix 2.15, Subpart 3.2, Part III.)

7.1.3 Variations.

Variations from the procedures shall be approved and documented. Some situations may require emergency

variations from the procedure. The individual with authority to

act in emergencies shall have been previously identified (see

para. 7.1.2). Such variations shall be documented after the

fact.7.2 Handling Category B Items 7.2.1 Prerequisites.

Prior to the actual handling of a specified item, it shall have been determined that the prerequisites of paras. 6.1 through 6.4 have been implemented. Handling and moving clearances shall have been investigated 05/26/04 Page 22 of 23 ANSI N45.2.2-1972, Section 7. Handling Quality Assurance Requirements for Hoisting, Rigging, and Transporting Items for Nuclear Power Plants NQA-1 1994 Subpart 2.15 COMMENTS 7.2.2 Procedures.

The handling of Category B items shall be in accordance with written procedures as set forth under paras. 7.1.2(b), (c), and (d).7.2.3 Variations.

Variations from the procedure shall be in accordance with para. 7.1.3.

7.3 Handling

Category C Items 7.3.1 Prerequisites.

Evidence of maintenance in accordance with para. 6.3 shall be verified.7.3.2 Procedures.

Written detailed procedures are not required. Category C items shall be handled by experienced personnel in accordance

with good rigging and handling practices as described in safety

handbooks, consensus standards, and corporate or contractor

standards designated for the job, and in compliance with

regulations. Manufacturer's load charts and general safe

rigging manuals shall be available to personnel

7.5 Personnel

8 QUALIFICATIONS OF PERSONNEL The responsible organization shall determine that the personnel engaged in operating material handling, equipment are

competent and have demonstrated satisfactory ability in

operating similar lifting equipment.

This Section contains minimum qualifications for certain key personnel involved in assuring safe handling of nuclear power

plant items. Qualifications of these personnel shall be verified

by objective evidence and documented.

Similar requirement.

8.1 Person-In-Charge (PIC)

The PIC of handling operations shall be designated by his management. He shall have demonstrated supervisory

experience in the hoisting, rigging, and transporting activities

for which he is responsible, to the satisfaction of the cognizant

management.

8.2 Engineer

The engineer responsible for the design, selection, or application of special equipment, or a combination of these, shall have demonstrated capability in the technical aspects of

similar work. This capability shall be achieved through 05/26/04 Page 23 of 23 ANSI N45.2.2-1972, Section 7. Handling Quality Assurance Requirements for Hoisting, Rigging, and Transporting Items for Nuclear Power Plants NQA-1 1994 Subpart 2.15 COMMENTS education and experience. He shall be an engineering graduate of an accredited college or university, or a Professional

Engineer registered to practice in an applicable discipline.

8.3 Inspector

The inspector of hoisting, rigging, and transporting equipment shall have demonstrated experience in the activity for which he

is responsible. Nondestructive examiners shall meet the

qualifications of Recommended Practice SNT-TC-1A

8. RECORDS 9 RECORDS Record copies of completed procedures: reports; personnel qualification records; test equipment calibration records; test

deviation or exception records; and inspection and examination

records shall be prepared as required by this standard. These

records shall be placed with other project records as required

by code, standard, specification or project procedures.

Record copies of procedures, reports, personnel qualification records, test equipment calibration records, test deviation or

exception records, and inspection and examination records

shall be prepared. These records shall be retained with other

project records as required by code, standard, specification, or

project procedures.

Similar requirements.

12/03/03 Page 1 of 11 M&TE was previously addressed in a number of ANSI standards. These are addressed below with notation of the applicable standard.

Quality Assurance Requirements for Calibration and Control of Measuring and Test Equipment Used in Nuclear Facilities NQA-1 1994 Subpart 2.16 COMMENTS Subpart 2.16 consists of ANSI/IEEE Std. 498-1985 Subpart 2.16 consists of ANSI/IEEE Std. 498-1985

, IEEE Standard Requirements for the Calibration and Control of Measuring and Test Equipment Used in Nuclear Facilities.

The following text is from the above referenced standard.

IEEE Standard Requirements for the Calibration and Control of Measuring and Test Equipment Used in

Nuclear Facilities ANSI N18.7 § 5.2.16 Measuring and Test Equipment.

¶ 4 American National Standard N45.2.4-1972 shall be applied to those activities occurring during the operational phase that

are comparable in nature and extent to related activities

occurring during construction.

NQA-1-1994, Part II Applicability.

Applicability for all of the Subparts (i.e., 2.x) is addressed in a general sense in the Introduction to Part II.

Requirements from ANSI N45.2.4 have been incorporated

into NQA-1, Basic Requirement

12, Supplement 12S-1, and

Subpart 2.16.

1. Introduction 1.1 Scope.

This standard sets forth the requirements for a calibration program to control and verify the accuracy of measuring and

test equipment used to ensure that important parts of a nuclear

facility are in conformance with prescribed technical

requirements and that data provided by testing, inspection, or

maintenance are valid. These requirements also cover

modifications and those activities occurring during the

operating phase that are comparable in nature and extent to

related activities occurring during the initial construction of the

facility.NQA-1 adds introductory statement that is similar to the

overall introduction to the various

standards that contained M&TE

as a subsection of the

requirements. This standard is

designed to capture the

information from all the previous

standards into one location to

avoid repetition.

During the construction phase and when modifications are being performed, this standard shall be used in conjunction

with the applicable portions of ANSI/ASME NQA-1-1983 [1]

and ANSI/ ASME NQA-2-1983 [2]. During the operations phase this standard shall be used with the applicable portions of ANSI/ANS 3.2-1982 Dominion identifies in the QAPD the specific Quality Standards

and editions in lieu of these

standards.

12/03/03 Page 2 of 11 M&TE was previously addressed in a number of ANSI standards. These are addressed below with notation of the applicable standard.

Quality Assurance Requirements for Calibration and Control of Measuring and Test Equipment Used in Nuclear Facilities NQA-1 1994 Subpart 2.16 COMMENTS 1.2 Applicability.

ANSI N18.7 § 5.2.16 Measuring and Test Equipment.

The method and interval of calibration for each installed instrument and control device shall be defined and shall be

based on the type of equipment, stability and reliability

characteristics, required accuracies and other conditions

affecting calibration.

The requirements of this standard apply to the measuring and test equipment used during the installation, inspection, test, or

maintenance activities performed at a nuclear facility.

Measuring and test equipment does not include test equipment

used for preliminary checks where data obtained will not be

used to determine acceptability or be the basis for design or

engineering evaluation.

The maintenance and testing activities addressed by NQA-1

would be comparable to the

statement in N18.7 regarding

calibration of each installed

instrument and control device.

Addressed in the QAPD.

The extent to which the individual requirements of this standard apply will depend upon the nature and scope of the

work to be performed and the importance of the item or

service involved.

Similar words to the N45 daughter standards that became

the basis of this standard.

The requirements of this standard are intended to be applied to measuring and test equipment used in safety systems

equipment.

2 However, they may also be applied to measuring and test equipment used on non-safety related systems equipment.

---

Footnote 2 Safety systems equipment is defined in IEEE Std 603-1980.1.3 Responsibility.

It is the responsibility of the organization invoking this standard to provide for the establishment and execution of a calibration

program for the plant consistent with the provisions of this

standard. The work of establishing practices and procedures

and providing the resources in terms of personnel, equipment, and services to implement the requirements of this standard

may be delegated to other organizations, and such delegation

shall be documented. In any case, the organization invoking

this standard shall retain responsibility for overall program

effectiveness.

New requirement.

12/03/03 Page 3 of 11 M&TE was previously addressed in a number of ANSI standards. These are addressed below with notation of the applicable standard.

Quality Assurance Requirements for Calibration and Control of Measuring and Test Equipment Used in Nuclear Facilities NQA-1 1994 Subpart 2.16 COMMENTS 2. Definitions.

The following definitions are provided to assure a uniform understanding of selected terms as they are used in this

standard.These definitions are not contained in the current

standards.

accuracy.

A measure of the degree by which the actual output of a device approximates the output of an ideal device nominally performing the same function.

calibration.

Comparison of items of measuring and test equipment with reference standards or with items of measuring and test equipment of equal or closer tolerance to

detect and quantity [quantify in context and 1990 edition]

inaccuracies and to report or eliminate those inaccuracies.

Clarification, the word quantity should be replaced with quantify.

measuring and test equipment.

Devices or systems used to calibrate, measure, gage, test, inspect or control to acquire research, development, test or operational data or to determine

compliance with design, specifications or other technical

requirements.

reference standards.

Standards (that is, primary, secondary and working standards, where appropriate) used in a calibration program. These standards establish the basic

accuracy limits for that program.

tolerance.

The allowable deviation from a specified or true value.3. References When the following standards referred to in this standard are superseded by a revision approved by the American National

Standards Institute, the revision is not mandatory until it has

been incorporated as part of this standard.

[l] ANSI/ASME NQA-1-1983, Quality Assurance Program

Requirements for Nuclear Facilities.

[2] ANSI/ASME NQA-2-1983, Quality Assurance

Requirements for Nuclear Power Plants.

The Dominion QAPD establishes the standards to be used with any

approved alternatives.

12/03/03 Page 4 of 11 M&TE was previously addressed in a number of ANSI standards. These are addressed below with notation of the applicable standard.

Quality Assurance Requirements for Calibration and Control of Measuring and Test Equipment Used in Nuclear Facilities NQA-1 1994 Subpart 2.16 COMMENTS[3] ANSI/ANS 3.2-1982, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power

Plants.

[4] IEEE Std 603-1980, IEEE Standard Criteria for Safety Systems for Nuclear Power Generating Stations.

4. General Requirements N45.2 ¶ 1 Measures shall be established and documented to assure that tools, gages, instruments, and other in spection, measuring, and testing equipment and devices used in activities affecting quality are of the proper range, type, and accuracy to

verify conformance to established requirements.

A documented program shall be established, implemented and maintained for the calibration and control of measuring and

test equipment and reference standards. It shall be designed to

determine and assure the accuracy of measuring and test

equipment and reference standards and shall provide for the

prompt detection of inaccuracies and for timely and effective

corrective action. This documented program shall include as a

minimum the following general requirements.

NQA-1 adds detail.

4.1 Equipment

Identification.

A list of measuring and test equipment, and reference standards and their assigned locations shall be prepared to

specifically identify those items within the calibration program.

NQA-1 adds a requirement to have a list of equipment and

standards.

4.2 Calibration

Procedures.

N45.2.4 § 2.5 Measuring and Test Equipment 2.5.1 Selection. Use shall be made of approved industry standards relating to measuring procedures.

Documented procedures for calibrating measuring and test equipment and reference standards shall be used. Procedures

such as published standard practices, written instructions that

accompany purchased equipment, or other acceptable

instructions may be used.

Calibration procedures shall include the following minimum

basic information:

(1) Identity of the item to be calibrated

(2) Calibration equipment and reference standards to be used

(3) Checks, tests, measurements, and acceptable tolerances

(4) Sequence of operations (5) Special instructions when necessary NQA-1 adds detail on procedure content.

12/03/03 Page 5 of 11 M&TE was previously addressed in a number of ANSI standards. These are addressed below with notation of the applicable standard.

Quality Assurance Requirements for Calibration and Control of Measuring and Test Equipment Used in Nuclear Facilities NQA-1 1994 Subpart 2.16 COMMENTS 4.3 Records.

ANSI N45.2 § 13. Control of Measuring and Test Equipment N45.2 ¶ 3 Records shall be maintained and equipment suitably marked to indicate calibration status.

Records shall be maintained for each individual piece of equipment to show that established schedules and procedures

for the calibration of measuring and test equipment and

reference standards have been followed. The records shall

contain a history of calibration and other means of control

showing calibration interval, date of last calibration, when next

calibration is due, conformance or nonconformance to required

tolerances prior to and following adjustments, and any

limitations on use.

NQA-1 adds detail on information to be included in the

records.Each record shall identify the equipment to which it applies, the procedure or instruction followed in performing the

calibration, the calibration data, the identity of the standard

used, the identity of the person performing the calibration, and

the calibration date.

NQA-1 adds detail on information to be included in the

records.5. Elements of Control The documented program shall include as a minimum the elements of control described in the following subsections:

NQA-1 adds details in Section 5 on the elements of control.

5.1 Adequacy

of Reference Standards.

Reference standards used for calibrating measuring and test equipment shall have calibration ranges, precisions and accuracies so that the measuring and test equipment and plant equipment can be calibrated and maintained within the

required tolerances. In general, the inaccuracy of the

reference standards shall contribute no more than one fourth

of the allowable measuring and test equipment tolerance.

However, when the actual inaccuracy of the measuring and

test equipment is less than one fourth of the plant equipment

tolerance, or if reference standards less than one fourth of the

tolerance of the measuring and test equipment are not

available, the requirement for one fourth may not be

necessary. The rationale for deviating from these New requirement.

12/03/03 Page 6 of 11 M&TE was previously addressed in a number of ANSI standards. These are addressed below with notation of the applicable standard.

Quality Assurance Requirements for Calibration and Control of Measuring and Test Equipment Used in Nuclear Facilities NQA-1 1994 Subpart 2.16 COMMENTS requirements shall be justified and documented.

5.2 Environmental

Controls.

Measuring and test equipment and reference standards shall be transported, stored and calibrated in environments that will

not adversely affect their accuracy. Environmental factors

that shall be considered include, but shall not be limited to, temperature, humidity, vibration, radio-frequency interference, electromagnetic interference, background radiation, dust, cleanliness, and fumes. When inaccuracy of measuring and test equipment or reference standards, because of environmental effects, cannot be avoided, compensating

corrections shall be determined and applied.

New requirement.

5.3 Intervals

of Calibration.

ANSI N45.2 § 13. Control of Measuring and Test Equipment N45.2 ¶ 2 The method and interval of calibration for each item shall be defined and shall be based on the type of equipment, stability characteristics, required accuracy, and other conditions affecting measurement control.

The program shall require that measuring and test equipment and reference standards be recalled for recalibration at prescribed intervals to verify the required accuracy. Such intervals may be in calendar time or relate to usage. Interval

selection should consider experience, inherent stability, purpose of use, and accuracy required. Historical records

which contain sufficient experience data for evaluating and

adjusting calibration intervals shall be maintained.

Similar requirement, more detail added in NQA-1 5.4 Traceability.

N45.2 ¶ 1 To assure accuracy, inspection, measuring, and test equipment shall be controlled, calibrated, adjusted, and maintained at prescribed intervals or prior to use against

certified equipment having known valid relationships to

nationally recognized standards.

N18.7 ¶ 2 Tools, instruments, testing equipment and measuring devices used for measurements, tests and calibration shall be of the proper range and type and shall be

controlled, calibrated and adjusted and maintained at specified

intervals or prior to use to assure the necessary accuracy of Measuring and test equipment shall be calibrated utilizing reference standards whose calibration has a known valid

relationship to nationally recognized standards or accepted

values of natural physical constants.

Similar requirements in the context of Section 5 of NQA-1, Subpart 2.16.

12/03/03 Page 7 of 11 M&TE was previously addressed in a number of ANSI standards. These are addressed below with notation of the applicable standard.

Quality Assurance Requirements for Calibration and Control of Measuring and Test Equipment Used in Nuclear Facilities NQA-1 1994 Subpart 2.16 COMMENTS calibrated devices.

ANSI N45.2.1 § 2.5 Test Equipment

2.5.2 Calibration

and Control. Test equipment shall be adjusted and calibrated at prescribed intervals against certified

equipment having known valid relationships to nationally

known standards.

N45.2.2 § 2.5 Measuring and Test Equipment.

2.5.2 Calibration

and Control. As appropriate, measuring and test equipment shall be adjusted and calibrated at prescribed

intervals against certified equipment having known valid

relationships to nationally recognized standards.

N45.2.4 § 2.5 Measuring and Test Equipment

2.5.2 Calibration

and Control. Measuring and test equipment used to determine compliance with specifications, shall be

adjusted and calibrated at prescribed intervals against certified

equipment having known valid relationships to nationally

recognized standards. If no national standards exists, the basis

for calibration shall be documented. Records of the

calibrations shall be maintained and equipment suitably marked

to indicate date of next required calibration. When inspection

and testing equipment are found to be out of calibration, an

evaluation shall be made of the validity of previous inspection

or test results and of the acceptability of items previously

inspected or tested. Test equipment found to be out of

calibration shall be clearly identified as such.

N45.2.5 § 2.5 Measuring and Test Equipment.

2.5.2 Calibration

and Control. The equipment shall be adjusted or calibrated or both at prescribed intervals against certified

standards having known valid relationships to national

standards, where such exists.

N45.2.8 § 2.8 Measuring and Test Equipment

2.8.2 Calibration

and Control. Measuring and test equipment used to determine compliance with Specifications, shall be 12/03/03 Page 8 of 11 M&TE was previously addressed in a number of ANSI standards. These are addressed below with notation of the applicable standard.

Quality Assurance Requirements for Calibration and Control of Measuring and Test Equipment Used in Nuclear Facilities NQA-1 1994 Subpart 2.16 COMMENTS adjusted and calibrated at predetermined intervals, based on equipment stability and use, against certified equipment having

known valid relationships to nationally recognized standards.

N45.2.13 § 7.4 Measuring and Test Equipment

7.4.2 Calibration

and Control. As appropriate, measuring and test equipment shall be adjusted and calibrated at prescribed

intervals against certified equipment having known valid

relationships to nationally recognized standards.

N45.2 ¶ 1 If no national standards exist, the basis for calibration shall be documented.

N45.2.1 § 2.5 Test Equipment

2.5.2 Calibration

and Control. If no national standards exist, the basis of calibration shall be documented.

N45.2.2 § 2.5 Measuring and Test Equipment.

2.5.2 Calibration

and Control. If no national standards exists, the basis for calibration shall be documented.

N45.2.4 § 2.5 Measuring and Test Equipment

2.5.2 Calibration

and Control. If no national standards exists, the basis for calibration shall be documented.

N45.2.5 § 2.5 Measuring and Test Equipment.

2.5.2 Calibration

and Control. If no national standards exists, the basis for the adjustment or calibration shall be

documented. Records shall be maintained and equipment

suitably marked to indicate calibration status. Measures shall

be taken to assure proper handling, storage and care of

installation of inspection and testing equipment after calibration

in order to maintain the required accuracy of such equipment.

N45.2.8 § 2.8 Measuring and Test Equipment 2.8.2 If no national standards exist, the basis for calibration shall be documented.

N45.2.13 § 7.4 Measuring and Test Equipment

7.4.2 Calibration

and Control. If no standards exist, the basis for calibration shall be documented.

If no national standard exists, the basis for calibration shall be documented.

Similar requirement.

12/03/03 Page 9 of 11 M&TE was previously addressed in a number of ANSI standards. These are addressed below with notation of the applicable standard.

Quality Assurance Requirements for Calibration and Control of Measuring and Test Equipment Used in Nuclear Facilities NQA-1 1994 Subpart 2.16 COMMENTS Reference standards used in the calibration program shall be identified on calibration data records and supported by

certificates, reports, or data sheets attesting to the calibration

date, calibration facility, environmental conditions, and data

that shows conformance to accuracy requirements.

NQA-1 adds detail on record information related to reference

standards used in calibration.

5.5 Labeling.

Measuring and test equipment shall be labeled to indicate their control status. The label shall indicate when the next

calibration is due. When size or functional characteristics of

measuring and test equipment or reference standards prevent

the application of a label, an identifying code shall be applied to

reflect status. When neither labeling nor coding is practical, the procedures shall provide for monitoring of records to

ensure control. Measuring and test equipment whose use shall

be limited shall be identified and controlled; for example, a

multi-scaled instrument which may be acceptable on one or

more scales but limited on a specific scale or an instrument

that is intended to be used for making preliminary checks.

New requirement.

5.6 Precalibration

Checks.

Measuring and test equipment and reference standards submitted for calibration shall be checked and the results

recorded, before adjustments or repairs are made.

New requirement.

5.7 Nonconformance.

ANSI N18.7 § 5.2.16 Measuring and Test Equipment.

¶ 2 When calibration, testing, or other measuring devices are found to be out of calibration, an evaluation shall be made and

documented concerning the validity of previous test and the

acceptability of devices previously tested from the time of the

previous calibration.

ANSI N45.2 § 13. Control of Measuring and Test Equipment N45.2 ¶ 2 When inspection, measuring, and test equipment Measuring and test equipment and reference standards found to be out of calibration or which have not been properly maintained or calibrated, or which have been subjected to possible damage, shall be identified as nonconforming and

removed from service until such time as corrective measures

have been taken. All equipment tested or calibrated by the

item since the last calibration shall be identified and sufficient

investigations performed to either re-establish the acceptability

of the equipment or to confirm a nonconformance. The results Similar requirement, but detail added in NQA-1.

12/03/03 Page 10 of 11 M&TE was previously addressed in a number of ANSI standards. These are addressed below with notation of the applicable standard.

Quality Assurance Requirements for Calibration and Control of Measuring and Test Equipment Used in Nuclear Facilities NQA-1 1994 Subpart 2.16 COMMENTS are found to be out of calibration, an evaluation shall be made and documented of the validity of previous inspection or test

results and of the acceptability of items previously inspected or

tested.N45.2.4 § 2.5 Measuring and Test Equipment

2.5.2 Calibration

and Control. When inspection and testing equipment are found to be out of calibration, an evaluation

shall be made of the validity of previous inspection or test

results and of the acceptability of items previously inspected or

tested. Test equipment found to be out of calibration shall be

clearly identified as such.

N45.2.5 § 2.5 Measuring and Test Equipment.

2.5.2 Calibration

and Control. Test equipment found to be out of calibration shall be clearly identified as such. When

discrepancies, malfunctions, or inaccuracies in inspection and

testing equipment are found during calibration, all items

inspected with that equipment since the last previous

calibration shall be considered unacceptable until an evaluation

has been made by the responsible authority and appropriate

action taken.

N45.2.13 § 7.4 Measuring and Test Equipment

7.4.2 Calibration

and Control. When inspection, measuring and test equipment are found to be out of calibration, an evaluation

shall be made and documented of the validity of previous

inspection or test results and of the acceptability of items

previously inspected or tested.

of such investigations shall be documented.

5.8 Control

of Measuring and Test Equipment and Reference Standards.

Measuring and test equipment and reference standards shall be controlled to assure consistent results of acceptable

accuracy. The following controls shall be considered.

(1) Environmental and handling controls (2) Training and qualification of personnel New requirement.

12/03/03 Page 11 of 11 M&TE was previously addressed in a number of ANSI standards. These are addressed below with notation of the applicable standard.

Quality Assurance Requirements for Calibration and Control of Measuring and Test Equipment Used in Nuclear Facilities NQA-1 1994 Subpart 2.16 COMMENTS (3) Checking calibration status before use (4) Interim checks between calibrations (5) Documenting and recalibrating possible damaged measuring and test equipment and reference standards (6) Limiting use to authorized personnel

6. Audits The calibrating program, in its entirety, is subject to audit in accordance with the requirements of the Quality Assurance

Program.NQA-1 states a requirement from 10 CFR 50, Appendix B regarding audits.

7. Document Control Equipment identification lists, procedures, calibration records, personnel qualification reports, and nonconformance reports

shall be retained with other project records as required by

codes, standards, specifications, or project procedures.

Collection, storage and maintenance of these records shall be

in accordance with the Quality Assurance Program.

NQA-1 adds detail to what is contained in ANSI N45.2.9

regarding records.