Nuclear Facility Quality Assurance Program Description ... · 900 East Main Street Richmond, Virginia 23219 Senior Resident Inspector North Anna Power Station U. S. Nuclear Regulatory

Dominion

Nuclear Facility Quality AssuranceProgram Description

Topical Report DOM-QA-1-A

Revision 0

September 12, 2005

September 9, 2005

Mr. David A. ChristianSr. Vice President and Chief Nuclear OfficerDominion Nuclear Connecticut, Inc. Innsbrook Technical Center5000 Dominion BoulevardGlen Allen, VA 23060-6711

SUBJECT: APPROVAL OF DOMINION NUCLEAR CONNECTICUT AND VIRGINIAELECTRIC AND POWER COMPANY QUALITY ASSURANCE PROGRAMDESCRIPTION TOPICAL REPORT FOR MILLSTONE POWER STATION, UNITNOS. 1, 2 AND 3, NORTH ANNA POWER STATION UNIT NOS. 1 AND 2, ANDSURRY POWER STATION, UNIT NOS. 1 AND 2 (TAC NOS. MC4414, MC4415,MC4416, MC4417, MC4418, MC4419, AND MC4420)

Dear Mr. Christian:

By letter dated August 24, 2004, as supplemented by letter dated May 5, 2005, DominionNuclear Connecticut, Inc. and Virginia Electric and Power Company (the licensees) submittedtheir Nuclear Facilities Quality Assurance Program Description (NFQAPD) Topical Report(DOM-QA-1) for review and approval by the Nuclear Regulatory Commission (NRC) staff inaccordance with Title 10 of the Code of Federal Regulations (10 CFR), Section 50.54(a)(4),Part 71 Subpart H, and Part 72 Subpart G

In their submittal, the licensees proposed to replace and consolidate the site-specific qualityassurance programs for Millstone Power Station, Unit Nos. 1, 2, and 3 (MPS1, 2 and 3), SurryPower Station, Unit Nos. 1 and 2 (SPS1 and 2), and North Anna Power Station, Units 1 and 2(NAS1 and 2), into a common Quality Assurance (QA) program. The new NFQAPD is basedon 10 CFR Part 50, Appendix B and American Society of Mechanical Engineers (ASME)NQA-1-1994.

The enclosed Safety Evaluation (SE) documents the basis for the NRC staff’s conclusion thatthe proposed consolidation of the QA programs for MPS1, 2, and 3, SPS1 and 2, and NAS1and 2, into a common QA program, as revised by the referenced supplemental letter, meets thecriteria of Appendix B to 10 CFR Part 50 and is, therefore, acceptable.

In accordance with the guidance provided on the NRC website, the NRC requests that thelicensees publish an accepted version of this topical report within three months of receipt of thisletter. The accepted version shall incorporate this letter and the enclosed SE between the titlepage and the abstract. It must be well indexed such that information is readily located. Also, itmust contain, in appendices, historical review information, such as questions and acceptedresponses, and original report pages that were replaced. The accepted version shall include an“-A” (designated accepted) following the report identification symbol.

D.A. Christian - 2 -

If the NRC’s criteria or regulations change such that its conclusions as to the acceptability ofthe topical report are invalidated, then the licensees will be expected to revise and resubmit itsrespective documentation, or submit justification for the continued applicability of the topicalreport without revision of the respective documentation.

If there are any further questions, please contact Victor Nerses, at (301) 415-1484 [email protected].

Sincerely,

/RA/

Cornelius F. Holden, Project DirectorProject Directorate IDivision of Licensing Project ManagementOffice of Nuclear Reactor Regulation

Docket Nos. 50-245, 50-336, 50-423, 50-338, 50-339, 50-280, and 50-281

Enclosure: As stated

cc w/encl: See next pages

D.A. Christian - 2 -

If the NRC’s criteria or regulations change such that its conclusions as to the acceptability ofthe topical report are invalidated, then the licensees will be expected to revise and resubmit itsrespective documentation, or submit justification for the continued applicability of the topicalreport without revision of the respective documentation.

If there are any further questions, please contact Victor Nerses, at (301) 415-1484 [email protected].

Sincerely,

/RA/

Cornelius F. Holden, Project DirectorProject Directorate IDivision of Licensing Project ManagementOffice of Nuclear Reactor Regulation

Docket Nos. 50-245, 50-336, 50-423, 50-338, 50-339, 50-280, and 50-281

Enclosure: As stated

cc w/encl: See next pages

DISTRIBUTION:PUBLIC AWang GMatakas,RGN-1 DRobertsPDI-2 Reading CRaynor DThatcher RLewisACRS OGC GHill (7) SMonarqueJPearson KKavanagh CHolden

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DATE 9/07/05 9/07/05 08/17/05 08/22/05 08/22/05 7/11/05 09/06/05 9/09/05

OFFICIAL RECORD COPY

Millstone Power Station Unit 1

cc:Lillian M. Cuoco, EsquireSenior CounselDominion Resources Services, Inc.Rope Ferry RoadWaterford, CT 06385

Edward L. Wilds, Jr., Ph.D.Director, Division of RadiationDepartment of Environmental Protection79 Elm StreetHartford, CT 06106-5127

Mr. Allan Johanson, Assistant DirectorOffice of Policy and ManagementPolicy Development & Planning Division450 Capitol Avenue - MS# 52ERNP.O. Box 341441Hartford, CT 06134-1441

Regional Administrator, Region IU.S. Nuclear Regulatory Commission475 Allendale RoadKing of Prussia, PA 19406

First SelectmenTown of Waterford15 Rope Ferry RoadWaterford, CT 06385

Attorney Nicholas J. Scobbo, Jr.Ferriter, Scobbo, & Rodophele, PC125 High StreetBoston, MA 02110

Ernest C. Hadley, Esquire1040 B Main StreetP.O. Box 549West Wareham, MA 02576

Mr. Evan W. Woollacott, Co-ChairNuclear Energy Advisory Council128 Terry's Plain RoadSimsbury, CT 06070

Citizens Regulatory CommissionATTN: Ms. Susan Perry Luxton180 Great Neck RoadWaterford, CT 06385

Deborah Katz, PresidentCitizens Awareness NetworkP.O. Box 83Shelburne Falls, MA 03170

Mr. John BuckinghamDepartment of Public Utility ControlElectric Unit 10 Liberty SquareNew Britain, CT 06051

Nancy Burton, Esquire147 Cross HighwayRedding Ridge, CT 06876

Mr. W. R. MatthewsSenior Vice President - Nuclear OperationsDominion Nuclear Connecticut, Inc.Rope Ferry RoadWaterford, CT 06385

Mr. P. J. ParulisManager - Nuclear OversightDominion Nuclear Connecticut, Inc.Rope Ferry RoadWaterford, CT 06385

Mr. S. E. ScaceAssistant to the Site Vice PresidentDominion Nuclear Connecticut, Inc.Rope Ferry RoadWaterford, CT 06385

Mr. J. Alan PriceSite Vice President - MillstoneDominion Nuclear Connecticut, Inc.Rope Ferry RoadWaterford, CT 06385

Millstone Power Station Unit 1 - 2 -

cc:Mr. G. D. Hicks, DirectorNuclear Station Safety and LicensingDominion Nuclear Connecticut, Inc.Rope Ferry RoadWaterford, CT 06385

Mr. A. J. Jordan, Jr.Director - Nuclear EngineeringDominion Nuclear Connecticut, Inc.Rope Ferry RoadWaterford, CT 06385

Mr. S. P. Sarver, DirectorNuclear Station Operations & MaintenanceDominion Nuclear Connecticut, Inc.Rope Ferry RoadWaterford, CT 06385

Mr. Chris L. FunderburkDirector, Nuclear Licensing and Operations SupportDominion Resources Services, Inc.Innsbrook Technical Center5000 Dominion BoulevardGlen Allen, VA 23060-6711

Mr. David W. DodsonLicensing SupervisorDominion Nuclear Connecticut , Inc.Rope Ferry RoadWaterford, Connecticut 06385

Millstone Power Station, Unit Nos. 2 and 3

cc:

Lillian M. Cuoco, EsquireSenior CounselDominion Resources Services, Inc.Building 475, 5th Floor Rope Ferry RoadWaterford, CT 06385

Edward L. Wilds, Jr., Ph.D.Director, Division of RadiationDepartment of Environmental Protection79 Elm StreetHartford, CT 06106-5127

Regional Administrator, Region IU.S. Nuclear Regulatory Commission475 Allendale RoadKing of Prussia, PA 19406

First SelectmenTown of Waterford15 Rope Ferry RoadWaterford, CT 06385

Charles Brinkman, DirectorWashington Operations Nuclear ServicesWestinghouse Electric Company12300 Twinbrook Pkwy, Suite 330Rockville, MD 20852

Senior Resident InspectorMillstone Power Stationc/o U.S. Nuclear Regulatory CommissionP. O. Box 513Niantic, CT 06357

Mr. John MarkowiczCo-ChairNuclear Energy Advisory Council9 Susan Terrace Waterford, CT 06385

Ms. Nancy Burton147 Cross HighwayRedding Ridge, CT 00870

Mr. Evan W. WoollacottCo-ChairNuclear Energy Advisory Council128 Terry’s Plain RoadSimsbury, CT 06070

Mr. Joseph RoyDirector of Operations Massachusetts Municipal Wholesale Electric CompanyP.O. Box 426Ludlow, MA 01056

Mr. David W. DodsonLicensing SupervisorDominion Nuclear Connecticut, Inc.Building 475, 5th FloorRoper Ferry RoadWaterford, CT 06385

Mr. J. Alan Price Site Vice PresidentDominion Nuclear Connecticut, Inc.Building 475, 5th FloorRope Ferry RoadWaterford, CT 06385

Mr. Chris L. FunderburkDirector, Nuclear Licensing and Operations SupportInnsbrook Technical Center5000 Dominion BoulevardGlen Allen, VA 23060-6711

North Anna Power Station, Units 1 & 2

cc:

Mr. C. Lee LintecumCounty AdministratorLouisa CountyPost Office Box 160Louisa, Virginia 23093

Ms. Lillian M. Cuoco, Esq.Senior CounselDominion Resources Services, Inc.Building 475, 5 th floorRope Ferry RoadWaterford, Connecticut 06385

Dr. W. T. LoughVirginia State Corporation CommissionDivision of Energy RegulationPost Office Box 1197Richmond, Virginia 23218

Old Dominion Electric Cooperative4201 Dominion Blvd.Glen Allen, Virginia 23060

Mr. Chris L. Funderburk, DirectorNuclear Licensing & Operations SupportDominion Resources Services, Inc.Innsbrook Technical Center5000 Dominion Blvd.Glen Allen, Virginia 23060-6711

Office of the Attorney GeneralCommonwealth of Virginia900 East Main StreetRichmond, Virginia 23219

Senior Resident InspectorNorth Anna Power StationU. S. Nuclear Regulatory Commission1024 Haley DriveMineral, Virginia 23117

Mr. Jack M. DavisSite Vice PresidentNorth Anna Power StationVirginia Electric and Power CompanyPost Office Box 402Mineral, Virginia 23117-0402

Dr. Robert B. Stroube, MD, MPHState Health CommissionerOffice of the CommissionerVirginia Department of HealthPost Office Box 2448Richmond, Virginia 23218

Surry Power Station, Units 1 & 2

cc:

Ms. Lillian M. Cuoco, Esq.Senior CounselDominion Resources Services, Inc.Building 475, 5th FloorRope Ferry RoadWaterford, Connecticut 06385

Mr. Donald E. JerniganSite Vice PresidentSurry Power StationVirginia Electric and Power Company5570 Hog Island RoadSurry, Virginia 23883-0315

Senior Resident InspectorSurry Power StationU. S. Nuclear Regulatory Commission5850 Hog Island RoadSurry, Virginia 23883

ChairmanBoard of Supervisors of Surry CountySurry County CourthouseSurry, Virginia 23683

Dr. W. T. LoughVirginia State Corporation Commission Division of Energy RegulationPost Office Box 1197Richmond, Virginia 23218

Dr. Robert B. Stroube, MD, MPHState Health CommissionerOffice of the CommissionerVirginia Department of HealthPost Office Box 2448Richmond, Virginia 23218

Office of the Attorney GeneralCommonwealth of Virginia900 East Main StreetRichmond, Virginia 23219

Mr. Chris L. Funderburk, DirectorNuclear Licensing & Operations SupportDominion Resources Services, Inc.Innsbrook Technical Center5000 Dominion Blvd.Glen Allen, Virginia 23060-6711

SAFETY EVALUATION OF PROPOSED CHANGE

TO THE QUALITY ASSURANCE PROGRAM

QUALITY ASSURANCE PROGRAM CONSOLIDATION

MILLSTONE POWER STATION, UNIT NOS. 1, 2 AND 3

NORTH ANNA POWER STATION, UNIT NOS. 1 AND 2

SURRY POWER STATION, UNIT NOS. 1 AND 2

DOCKET NOS. 50-245, 50-336, 50-423, 50-338, 50-339, 50-280, AND 50-281

1.0 INTRODUCTION

By letter dated August 24, 2004 (Reference 1), as supplemented by letter dated May 5, 2005(Reference 2), Dominion Nuclear Connecticut, Inc. and Virginia Electric and Power Company(the licensees) submitted a revision to the respective stations’ quality assurance (QA) program. In their submittal, the licensees have proposed to replace and consolidate the QA programs forMillstone Power Station, Unit Nos. 1, 2, and 3 (MPS1, 2 and 3), Surry Power Station, UnitNos. 1 and 2 (SPS1 and 2 ), and North Anna Power Station, Unit Nos. 1 and 2 (NAS1 and 2),into a common QA program.

2.0 BACKGROUND

The licensees accomplished the consolidation through their new Nuclear Facilities QualityAssurance Program Description (NFQAPD) Topical Report (DOM-QA-1) that was submitted bythe August 24, 2004 letter (as Attachment 1) for Nuclear Regulatory Commission (NRC or theCommission) review and approval in accordance with the provisions of Title 10 of the Code ofFederal Regulations (10 CFR) Section 50.54(a)(4), Part 71 Subpart H, and Part 72 Subpart G. The to-be-replaced site-specific QA programs for NAS1 and 2, SPS1 and 2 and MPS1, 2 and 3were included as Attachments 5 and 6, respectively, of the licensees’ August 24, 2004submittal.

The letter dated May 5, 2005 provided additional information in support of and revisions to theNFQAPD submitted as Attachment 1 of the original submittal. The QA program described inthe NFQAPD commits to the guidance of the American Society of Mechanical Engineers(ASME) Nuclear Quality Assurance (NQA) standard NQA-1-1994, “Quality AssuranceRequirements for Nuclear Applications.” NQA-1-1994, Part I sets forth programmaticrequirements for the establishment and execution of QA programs for the siting, design,construction, operation, and decommissioning of nuclear facilities. NQA-1-1994, Part II setsforth non-programmatic QA requirements for the planning and execution of identified tasksduring the fabrication, construction, modification, repair, maintenance, and testing of structures,

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systems and components (SSCs) for nuclear facilities. The guidance of Parts I and II ofNQA-1-1994 is similar to that provided by American National Standards Institute (ANSI) N45.2standards developed in the 1970s and early 1980s. The licensees propose to adoptNQA-1-1994 in lieu of certain current commitments to N45.2 standards.

The NRC staff has previously approved the use of NQA-1-1994, as supplemented by theguidance of ANSI N18.7-1976, “Administrative Controls and Quality Assurance for theOperational Phase of Nuclear Power Plants,” for nuclear operating facilities (References 3and 4). The most notable changes incorporated into the NFQAPD include: 1) a commitment toANSI/ASME NQA-1-1994 as the basic QA standard as a replacement for the previous ANSIN45.2 series of standards; 2) a commitment to establish and implement administrative controlsand QA requirements within the NFQAPD for the operating phase activities that are consistentwith the guidance of Regulatory Guide (RG) 1.33 rather than through a specific commitment toANSI N18.7-1976/American Nuclear Society (ANS) 3.2; 3) the use of generic managementposition descriptions for implementing programs based more on the function or objective ratherthan the specific nomenclature used at the facilities, since these program titles vary betweenlocations; 4) the use of generic functional descriptions of the organization rather than specifictitles and the use of organization charts to depict the reporting relationships; and 5) the use ofalternative methods from those described in NQA-1-1994 to ensure the requirements of10 CFR Part 50 Appendix B are satisfactorily implemented.

3.0 REGULATORY EVALUATION

The Commission’s regulatory requirements related to QA programs are set forth in 10 CFRPart 50 Appendix B; 10 CFR 50.34(b)(6)(ii), “Contents of applications; technical information;”10 CFR 50.54(a), “Conditions for licenses;” 10 CFR Part 71, “PACKAGING ANDTRANSPORTATION OF RADIOACTIVE MATERIAL,” Subpart H, “Quality Assurance;” and10 CFR Part 72, “LICENSING REQUIREMENTS FOR THE INDEPENDENT STORAGE OFSPENT NUCLEAR FUEL, HIGH-LEVEL RADIOACTIVE WASTE, AND REACTOR-RELATEDGREATER THAN CLASS C WASTE”, Subpart G, “Quality Assurance”.

RG 7.10, Revision 1, “Establishing Quality Assurance Programs for Packaging used in theTransport of Radioactive Materials Packaging” and NUREG-1567, “Standard Review Plan forSpent Fuel Dry Storage Facilities” were used as guidance during the NRC staff’s review of thelicensees’ proposed revision .

Part 50 of 10 CFR Appendix B establishes QA requirements for the design, construction, andoperation of SSCs of the facility. The pertinent requirements of Appendix B apply to allactivities affecting the safety-related functions of those SSCs and include designing,purchasing, fabricating, handling, shipping, storing, cleaning, erecting, installing, inspecting,testing, operating, maintaining, repairing, refueling, and modifying. Also, the NRC staffconsiders that the requirements of Appendix B are acceptable for meeting the requirements ofPart 71 Subpart H, and Part 72 Subpart G and, therefore, formed the basis that the NRC staffused to evaluate and accept the licensees’ proposed revision to their QA program. Notwithstanding the fact that the requirements of Appendix B were used as the main basis forprogram acceptance, the NRC staff, as an adjunct to the evaluation done against theAppendix B requirements, performed an assessment of the licensees’ NFQAPD against therequirements under 10 CFR Part 71 Subpart H, and 10 CFR Part 72 Subpart G.

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Section 50.34 of 10 CFR requires that every applicant for an operating license include in its finalsafety analysis report (FSAR) information on managerial and administrative controls to be usedto assure safe operation. The information on the controls shall also include a discussion of howthe applicable requirements of Appendix B will be satisfied. Section 50.54(a) of 10 CFR statesthat licensees may make a change to a previously accepted QA program description includedor referenced in the FSAR without prior NRC approval, provided the change does not reducethe commitments in the program description as accepted by the NRC. Changes to the QAprogram description that do reduce the commitments must be submitted to the NRC andreceive NRC approval prior to implementation.

4.0 EVALUATION

In evaluating the adequacy of the format and level of detail of the revised QA programdescription, the NRC staff followed the guidance of the Standard Review Plan (SRP)(NUREG-0800), Chapter 17.3, “Quality Assurance Program Description.” SRP 17.3 providesan outline of a standardized QA program for construction permit holders, their principalcontractors, and operating facility licensees. In their submittal, the licensees stated that theexisting licensees’ facilities were all based on QA programs written to the structure of SRP 17.1and 17.2, which follow the specific outline of 10 CFR 50 Appendix B. However, since SRP 17.3was developed on the basis of a program that follows NQA-1-1994, the licensees usedSRP 17.3 to determine the appropriate regulatory guidance that applies to the proposedNFQAPD as well as providing other useful insight into QA program requirements.

The NRC staff’s review concentrated on three specific aspects of the licensees’ proposedchange and consolidation of the QA program description for MPS1, 2 and 3, NAS1 and 2, andSPS1 and 2. These aspects included the proposed program format, attributes and level ofdetail (SRP 17.3), changes in regulatory commitments, and the basis for the change from ANSIN45.2 to NQA-1-1994.

4.1 Acceptability of the QA Program Description

4.1.1 Organization

The NFQAPD is the top-level policy document that establishes the quality policy and assignsmajor functional responsibilities for the licensees’ facilities. The licensees are committed toestablishing and maintaining an organization in accordance with the quality standards describedin NQA-1-1994, Basic Requirement 1 and Supplement 1S-1. The organization consists of threemain parts: corporate management, support organizations, and facility operations. The ChiefNuclear Officer (CNO) is responsible for overall corporate policy and implementation of the QAprogram. The organizational relationships of key management and functional groups forcorporate and technical support are identified in Appendix A of the NFQAPD. Reporting to theCNO are executive managers responsible for nuclear operations, engineering services, andsupport services via staff at both the corporate and site levels. The executive manager ofnuclear operations is responsible for overall operating activities of the licensees’ nuclearfacilities. The executive manager of engineering services is responsible for the engineeringfunctions supporting design and construction activities and long-term nuclear operations. Theexecutive manager of support services is responsible for direction and support of informationtechnology for the nuclear organizations and facilities. In all cases, the executive managers

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retain responsibility for the scope and effective implementation of the QA program for theirfunction responsibilities.

The licensees’ site organizations are directed by an executive manager for facility operations. Each executive manager for facility operations reports to the executive manager for nuclearoperations, who reports to the CNO. This position is responsible for station compliance with theNRC operating license, governmental regulations, and ASME Boiler and Pressure Vessel Code(Code) requirements, if applicable, and provides day-to-day direction and management of plantoperations activities. The site reporting structure and management positions responsible forplant operations, training, business support, engineering, regulatory affairs, performanceassessment, and nuclear oversight are identified in Appendix A of the NFQAPD. Responsibilityand authority for executing an effective overall QA program and delegation of programresponsibilities are clearly described and defined.

4.1.2 QA Program

The licensees have established a QA program for the nuclear power stations and independentspent fuel storage installations. The QA program accomplishes two objectives: provide orderly,uniform administrative and managerial documents to assure safe and reliable operation ofnuclear facilities, and assure compliance with regulations promulgated by the NRC. Provisionsfor establishing and maintaining formal indoctrination and training programs for personnelperforming, verifying or managing activities within the scope of the NFQAPD are described inthe QA program. In establishing qualification and training programs, the licensees commit toimplementing the QA program in accordance with the quality standards described inNQA-1-1994, Basic Requirement 2 and its associated Supplements, and Appendix 2A-1(Part III of NQA-1-1994), including alternatives described in Section 4.3 of this SafetyEvaluation (SE). The licensees’ staff qualifications for positions within the scope of10 CFR 50.120 are delineated in plant technical specifications. The licensees’ staff training forpositions identified in 10 CFR 50.120 is accomplished according to programs accredited by theNational Nuclear Accrediting Board of the National Academy for Nuclear Training.

4.1.3 Design Control

The licensees have established and implemented administrative controls to assure quality isachieved in establishing and changing the design for the nuclear facilities in accordance withindustry standards and regulatory requirements. The licensees’ design control programincludes provisions to control design inputs, processes, outputs, changes, interfaces, records,and organizational interfaces. In establishing its program for design control, the licenseescommit to meeting the standards of NQA-1-1994, Basic Requirement 3, Supplement 3S-1, andthe standards for computer software contained in Subpart 2.7.

4.1.4 Procurement Document Control

The licensees have established and implemented administrative controls and processes toassure that applicable regulatory, technical, and QA program requirements are included or

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referenced in procurement documents. The licensees commit to meeting the QA standards forprocurement document control of NQA-1-1994, Basic Requirement 4 and Supplement 4S-1.

4.1.5 Instructions, Procedures, and Drawings

The licensees have established and implemented administrative controls to assure thatactivities affecting quality are prescribed by, and performed in accordance with, documentedinstructions, procedures, and drawings. Types of procedures and instructions to be developedand used, according to the phase that a facility is in, as well as the type of the facility andactivities conducted, are described. The licensees commit to meeting the QA standards forinstructions, procedures, and drawings of NQA-1-1994, Basic Requirement 5. The licenseesalso commit to implement additional requirements regarding the content of procedures forspecific activities delineated in NQA-1-1994, Part II, as appropriate to the activity.

4.1.6 Document Control

The licensees have established and implemented administrative controls to assure the review,approval, and issuance of controlled documents. Measures are provided to assure thatdocuments, including revisions or changes, are reviewed for adequacy by independentknowledgeable personnel (other than those who originated or prepared the document),approved for release by authorized personnel, and distributed in accordance with currentapproved methods. In establishing provisions for document control, the licensees commit tomeeting the QA standards for document control of NQA-1-1994, Basic Requirement 6 andSupplement 6S-1.

4.1.7 Control of Purchased Material, Equipment, and Services

The licensees have established and implemented programs, procedures, and processes for thecontrol of purchased items and services, selection of suppliers, and assessing the acceptabilityof quality. Purchased items (components, spare and replacement parts necessary for plantoperation, refueling, maintenance and modifications) and services are subject to quality andtechnical requirements at least equivalent to those specified for original equipment or specifiedby properly reviewed and approved revisions to assure the items are suitable for the intendedservice, and are of acceptable quality, consistent with their effect on safety. The licenseescommit to meeting the QA standards for control of purchased material, equipment, and servicescontained in NQA-1-1994, Basic Requirement 7, and Supplement 7S-1, with the exceptiondescribed in Section 4.3 of this SE.

4.1.8 Identification and Control of Materials, Parts, and Components

The licensees have established and implemented administrative controls and processes for theidentification and control of items such as materials (including consumables), parts,components, and partially fabricated subassemblies. Methods used for identification of itemsassure traceability of the items to the appropriate documentation such as drawings,specifications, purchase orders, manufacturing and inspection documents, problem reports,and physical and chemical mill test reports. The licensees commit to meeting the QA standardsfor identification and control of items contained in NQA-1-1994, Basic Requirement 8 andSupplement 8S-1.

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4.1.9 Control of Special Processes

The licensees have established and implemented programs, procedures, and processes toassure the acceptability of special processes through the use of procedures, technique sheets,travelers and inspection verification reports, and personnel qualified in accordance with theapplicable codes, specifications, and standards of the specific work. The licensees commit tomeeting the QA standards for control of special processes from NQA-1-1994, BasicRequirement 9 and Supplement 9S-1.

4.1.10 Inspection

The licensees have established and implemented administrative controls and processes toinspect activities for the nuclear facilities that affect quality to verify conformance with theapproved documents for accomplishing the activities, including specifications and qualitystandards. The licensees commit to meeting the programmatic standards for inspection ofNQA-1-1994, Basic Requirement 10, and Supplement 10S-1, with the alternative described inSection 4.1 of this SE. The licensees also commit to incorporate into the inspection programthe appropriate inspection requirements described in NQA-1-1994, Part II, as appropriate to theactivity.

4.1.11 Test Control

The licensees have established and implemented programs, procedures, and processes tocontrol tests that assure the nuclear facility structures, systems, and components (items)function satisfactorily in service. The licensees commit to meeting the programmatic standardsfor test control of NQA-1-1994, Basic Requirement 11, and Supplements 11S-1 and 11S-2. The licensees also commit to incorporate the appropriate surveillance and testing requirementsdescribed in NQA-1-1994, Part II.

4.1.12 Control of Measuring and Test Equipment

The licensees have established and implemented administrative controls and processes for thecalibration, maintenance, and use of measuring and test equipment (including instruments,tools, gauges, fixtures, reference and transfer standards, and non-destructive test equipment). The licensees commit to meeting the standards for control of measuring and test equipment ofNQA-1-1994, Basic Requirement 12, Supplement 12S-1, and Subpart 2.16, with thealternatives described in Section 4.2 of this SE.

4.1.13 Handling, Storage, and Shipping

The licensees have established and implemented programs, procedures, and processes tocontrol handling, storage, shipping, cleaning, packaging, and preservation of items. Thelicensees commit to meeting the standards for handling, storage, and shipping of NQA-1-1994,Basic Requirement 13, Supplement 13S-1, and Subparts 2.2 and 2.15, with the alternativesdescribed in Section 13.3 of the NFQAPD.

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4.1.14 Inspection, Test, and Operating Status

The licensees have established and implemented administrative controls and processes toindicate and document the inspection, test, and operating status of SSCs to prevent theirinadvertent use or the bypassing of inspections and tests. The licensees commit toimplementing a status control program in accordance with the quality standards described in |NQA-1-1994, Basic Requirement 14.

4.1.15 Nonconforming Materials, Parts, or Components

The licensees have established and implemented administrative controls and processes thatassure control of nonconforming items (materials, parts, components), and services (includingcomputer codes) to prevent their inadvertent use or installation in the licensees’ nuclearfacilities. Nuclear oversight processes verify that nonconformance dispositions are adequate,analyze for quality trends, and report results to upper management in accordance withapplicable procedures. The licensees commit to meeting the standards for control ofnonconforming items of NQA-1-1994, Basic Requirement 15 and Supplement 15S-1.

4.1.16 Corrective Action

The licensees have established and implemented corrective active programs, procedures, andprocesses to assure that conditions adverse to quality at the licensees’ nuclear facilities arepromptly identified and corrected. The licensees’ corrective action procedures describe themethods for follow-up action to verify proper implementation of corrective action and ensurethat corrective actions are closed out in a timely manner, and include follow-up through nuclearoversight processes. The licensees commit to meeting the standards for corrective action ofNQA-1-1994, Basic Requirement 16.

4.1.17 QA Records

The licensees have established and implemented administrative controls and processes toensure sufficient records of items and activities for the nuclear facilities that reflect completedwork are generated, identified, retained, maintained, and retrievable. Records storedelectronically will follow the guidance given in the Nuclear Information and RecordsManagement Association (NIRMA) technical guidance, TG-15-1998, “Management ofElectronic Records.” The licensees are committed to implementing a QA records program inaccordance with the quality standards of NQA-1-1994, Basic Requirement 17 andSupplement 17S-1. The licensees will also meet Regulatory Position C.2 of RG 1.28,Revision 3, regarding the retention of QA records.

4.1.18 QA Audits

The licensees have established and implemented administrative controls and processes foraudits to systematically verify compliance with, and determine the effectiveness of, all aspectsof the QA program for nuclear facilities. The licensees’ documents ensure that triennialexternal audits, annual supplier QA program evaluations, reviews of audits conducted byexternal organizations (e.g., other utilities and the Nuclear Procurement Issues Committee),and maintenance of the approved supplies list which are performed to assure suppliers’ QA

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programs meet applicable requirements and that only qualified suppliers are used. Internalaudits include verification of compliance and effectiveness of the administrative controlsestablished for implementing the requirements of the NFQAPD; regulations and licenseprovisions; provisions for training, retraining, qualification, and performance of personnelperforming activities covered by the NFQAPD; corrective actions taken following abnormaloccurrences; and observation of the performance of construction, fabrication, operating,refueling, maintenance, modification, and decommissioning activities. The licensees arecommitted to implementing an audit program in accordance with the quality standardsdescribed in NQA-1-1994, Basic Requirement 18 and Supplement 18S-1.

Based on the NRC staff’s review, the NRC staff concludes that the NFQAPD adequatelydescribes the licensees’ QA program.

4.2 Changes to Current QA Commitments

Enclosure 4 of the supplemental letter dated May 5, 2005 (Reference 2) provides a comparisonof each plant’s approved QA program with the new NFQAPD. Changes are characterized as: 1) a reduction in commitment, 2) not a reduction in commitment, or 3) an increase incommitment. The regulatory change control process described in 10 CFR 50.54(a) classifieschanges as non-reductions (50.54(a)(3)) or reductions (50.54(a)(4)) in commitment. Changesthat increase commitments (i.e., are clearly more conservative in meeting Appendix Brequirements) are made at the discretion of the licensee.

Many of the non-reductions in commitment are the result of changes in format or level of detail. The regulation as described in 10 CFR 50.34(b)(6)(ii) requires that QA program descriptionsdiscuss how the requirements of Appendix B regarding managerial and administrative controlwill be satisfied. Several changes, which were previously reviewed by the NRC staff for otherlicensees, were characterized as non-reductions under the provisions of 10 CFR 50.54(a)(3)(ii). Two NRC SEs which approved QA changes were cited by the licensee.

1. NRC SE for Exelon (Reference 3) stated that NQA-1-1994 was equivalent toNQA-1-1983. As such, the licensees replaced the references in its commitments toRG 1.8 Revision 3, and RG 1.28 Revision 3, to NQA-1-1994.

2. NRC SE for Perry Nuclear Power Plant (Reference 5) allowed the minimum number offull-time engineers serving on the Independent Safety Engineering Group to be reducedfrom five to four. MPS1, 2 and 3 had adopted this change prior to the proposedNFQAPD submittal. The licensees will make this alternative applicable to all facilitieswith the implementation of the NFQAPD.

The NRC staff reviewed the bases cited by the licensees and concluded that the bases for thechanges are applicable to the licensees’ facilities.

The provisions of 10 CFR 50.54(a)(4) require NRC staff review of any changes characterizedas reductions in commitment prior to implementation. Enclosure 4 of the May 5, 2005,supplemental letter identifies changes characterized by the licensees as “reductions incommitment,” and provides the basis for the acceptability of each change. The followinglicensee-stated reductions in commitment were identified:

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1. Commitment to Regulatory Position C.2.1.1 and C.2.1.3 of RG 1.8, Revision 3, hasbeen modified to allow approval and documentation by the plant manager or theresponsible executive of ‘other factors’ that sufficiently demonstrate an individual’sabilities who does not have formal education and experience requirements for QA.

2. Current commitment to RG 1.30, August 1972, and ANSI N45.2.4-72 is replaced. Withthe adoption of NQA-1-1994 Subpart 2.4 (ANSI/IEEE [Institute of Electrical andElectronics Engineers] Std. 336-85), commitment to RG 1.30 and ANSI N45.2.4-72 is nolonger necessary since NQA-1-1994 contains equivalent requirements.

3. Current commitment to implement parts of RG 1.33, February 1978, is updated. In lieuof a commitment to ANSI N18.7-76, the applicable parts of NQA-1-1994 will be usedand augmented with additional administrative requirements as documented in theNFQAPD.

4. Current commitment to RG 1.37, March 1973, and ANSI N45.2.1-73 is replaced. Withthe adoption of NQA-1-1994 Subpart 2.1, commitment to RG 1.37 and ANSI N45.2.1-73is no longer necessary since NQA-1-1994 contains equivalent requirements.

5. Current commitment to RG 1.38, May 1977, and ANSI N45.2.2-72 is replaced. With theadoption of NQA-1-1994 Subpart 2.2, commitment to RG 1.38 and ANSI N45.2.2-72 isno longer necessary since NQA-1-1994 contains equivalent requirements.

6. Current commitment to RG 1.39, September 1977, and ANSI N45.2.3-73 is replaced. With the adoption of NQA-1-1994 Subpart 2.3, commitment to RG 1.39 andANSI N45.2.3-73 is no longer necessary since NQA-1-1994 contains equivalentrequirements.

7. Current commitment to RG 1.94, April 1976, and ANSI N45.2.5-74 is replaced. With theadoption of NQA-1-1994 Subpart 2.5, commitment to RG 1.94 and ANSI N45.2.5-74 isno longer necessary since NQA-1-1994 contains equivalent requirements.

8. Current commitment to RG 1.116, May 1977, and ANSI N45.2.8-75 is replaced. Withthe adoption of NQA-1-1994 Subpart 2.8, commitment to RG 1.116 andANSI N45.2.8-75 is no longer necessary since NQA-1-1994 contains equivalentrequirements.

9. NAS1 and 2 and SPS1 and 2 are committed to RG 1.74, February 1974, andANSI N45.2.10-73. With the commitment to RG 1.28, Revision 3, and the adoption ofNQA-1-1994, commitment to RG 1.74 and ANSI N45.2.10-73 is no longer necessarysince NQA-1-1994 contains equivalent requirements.

The NRC staff reviewed the bases for these commitments and concluded that they continue tomeet Appendix B requirements and, therefore, are acceptable. Consolidation of thesite-specific programs is acceptable in that it continues to meet the requirements of 10 CFRPart 50 Appendix B.

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Although not a requirement, the licensee identified changes that were characterized as beingan increase in commitment. The identified increases in commitment are as follows:

1. Qualification requirements for support staff, including QA and Quality Control, havebeen changed to ANSI/ANS 3.1-1993 as endorsed by RG 1.8, Revision 3, May 2000.

2. Increase in MPS1, 2 and 3 commitment which adds a conditional commitment toRG 1.26, Revision 3, based on a current commitment in NAS1 and 2, and SPS1 and 2Updated Final Safety Analysis Reports. The alternative indicates that the specific A, B,C, and D quality groups of RG 1.26 are not used. This maintains consistency with theclassification programs presently used at the facilities.

3. Increase in commitment to implement the requirements of Subpart 2.15 to NQA-1-1994with one alternative. Although the licensees may choose to not use the specificclassification of Categories A, B, and C, it will ensure that items to be handled areevaluated and the appropriate range of controls and requirements for the activity areapplied consistent with this Subpart.

4. Increase in commitment to implement the requirements of Subpart 2.16 to NQA-1-1994with two alternatives. All references to NQA-1, NQA-2 and ANSI/ANS-3.2 are changedto refer to NQA-1-1994. The second alternative states that instrumentation and controldevices installed in operating facilities are not required to be labeled as described inSubpart 2.16, subsection 5.5, provided the information is maintained in suitabledocumentation traceable to the device.

5. Increase in commitment to implement the requirements of Subpart 2.18 to NQA-1-1994with two alternatives. All references to ANS-3.2 are changed to refer to NQA-1-1994. The second alternative states that personnel responsible for performance of the workare required to ensure that they are using the appropriate maintenance procedure.

6. New commitment for NAS1 and 2 and SPS1 and 2 to RG 1.28, Revision 3. UnlikeMPS1, 2 and 3, NAS1 and 2 and SPS1 and 2 were not committed to an earlier revisionof RG 1.28.

The NRC staff reviewed the basis for each increase in commitment and concluded that therevised commitments continue to meet Appendix B requirements and, therefore, areacceptable.

4.3 The Licensees’ NFQAPD

The currently-approved QA programs for MPS1, 2 and 3, NAS1 and 2, SPS1 and 2, follow theguidance of ANSI N18.7-1976, ANSI N45.2 series of standards, and corresponding RGs. Sincethe proposed NFQAPD is based on a newer standard, understanding the evolution of NQA-1 isimportant to establishing the acceptability of the proposed basis for the NFQAPD.

In 1979, the ASME Committee on Nuclear Quality Assurance issued a new standardNQA-1-1979, based on N45.2-1977 and seven programmatic standards of the N45.2 series. In1985, NRC RG 1.28 Revision 3 endorsed NQA-1-1983 as an acceptable method for complying

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with the provisions of Appendix B with regard to implementing the requisite QA program for thedesign and construction of nuclear power plants. In 1994, NQA-1-1994 incorporated anadditional seven, non-programmatic N45.2 standards. As such, NQA-1-1994 sets forthrequirements and nonmandatory guidance for the establishment and execution of QA programsfor nuclear facility applications. In addition, NRC RG 1.33 Revision 2 endorsed ANSIN18.7-1976 as an acceptable basis for complying with the QA program provisions ofAppendix B for the operations phase of nuclear power plants. In December 2002, the NRCstaff approved NQA-1-1994, in conjunction with ANSI N18.7-1976, as a method acceptable tothe NRC staff for complying with the Commission’s regulations for Exelon’s operational QAprograms (Reference 3).

As stated in the licensees’ application, the proposed NFQAPD is based on NQA-1-1994. Attachment 3 of the submittal provides a comparison of the current N45.2 series QA standards,to which the licensees’ QA programs have made commitments, with NQA-1-1994. Based on itsreview, the NRC staff concludes that the licensees’ adoption of NQA-1-1994, as implementedthrough the NFQAPD, adequately addresses the commitments to the subject N45.2 standardsand is, therefore, an acceptable method of implementing the applicable Appendix Brequirements.

The administrative requirements of ANSI N18.7-1976 are incorporated into the text of theNFQAPD. The principal difference between ANSI N18.7-1976 and NQA-1-1994 is that theinclusion of administrative controls were not incorporated into NQA-1-1994. Attachment 4 ofthe licensees’ submittal compares ANSI N18.7-1976 guidance with the proposed NFQAPDcommitments and the applicable requirements of NQA-1-1994. Attachment 4 demonstratesthat, where differences between the QA requirements of ANSI N18.7-1976 and NQA-1-1994exist, substantive commitments have been included in the NFQAPD. The NRC staff hasreviewed the comparison presented in Attachment 4, applicable sections of the NFQAPD, andthe licensees’ stated positions with respect to RG 1.28, Revision 3 and RG 1.33, Revision 2. Based on its review, the NRC staff concludes that the licensees adequately incorporated ANSIN18.7-1976, as necessary, into the proposed NFQAPD.

4.3.1 Exceptions and Alternatives to NQA-1-1994

Where the licensees have taken an exception or alternative to the guidance of NQA-1-1994, oran existing ANSI standard, it is addressed in the applicable section of the NFQAPD. Attachment 2 of the submittal, as supplemented by Enclosure 4 of Reference 2, provides thebases for each NFQAPD alternative or exception to NQA-1-1994 or existing ANSI standard,some of which have been previously approved by the NRC via license amendments. Theexceptions or alternatives to Part I of NQA-1-1994 include the following:

1. RG 1.28, Revision 3, Regulatory Position 3.2 establishes external auditing requirementsthat are acceptable to the NRC during the design and construction phases. Theguidance provided regarding external audits will also be implemented during theoperational phase.

2. NQA-1-1994, Supplement 2S-1, “Supplementary Requirements for the Qualification ofInspection and Test Personnel,” will include use of the guidance provided inAppendix 2A-1, the same as if it were a part of the Supplement. However, in lieu of

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being certified as Level I, II, and III in accordance with NQA-1-1994, the licensees’personnel performing operations-phase independent quality verification inspections,examinations, measurements, or test of material, products, or activities will be requiredto possess qualifications equal to, or better than, those required for performing the taskbeing verified; and the verification is within the skills of these personnel and/or isaddressed by procedures. These individuals will not be responsible for the planning ofquality verification inspections and tests (i.e., establishing hold points and acceptancecriteria in procedures, and determining who will be responsible for performing theinspections), evaluating inspection training programs, nor certifying inspectionpersonnel. This alternative was approved for the Nuclear Management Company byNRC letter, dated March 24, 2005 (Reference 4).

3. An additional alternative to NQA-1-1994 Appendix 2A-1 is the definition of a qualifiedengineer. Specifically, a qualified engineer may be used to plan inspections, evaluatethe capabilities of an inspector, or evaluate the training program for inspectors. For thepurposes of these functions, a qualified engineer is one who has a baccalaureate inengineering in a discipline related to the inspection activity (such as electrical,mechanical, civil) and has a minimum of five years engineering work experience with atleast two years of this experience related to nuclear facilities.

4. NQA-1-1994, Supplement 2S-2, “Supplementary Requirements for the Qualification ofNondestructive Examination Personnel,” subsection 2.1, requires application ofRecommended Practice SNT-TC-1A, June 1980 Edition to nondestructive examinationpersonnel. The company will implement the qualification program required by thissupplement in accordance with the applicable standard for the facilities’ commitment tothe ASME Code or other applicable code governing the activity.

5. NQA-1-1994, Supplement 7S-1, “Supplementary Requirements for Control ofPurchased Items and Services,” Section 10 addresses requirements for CommercialGrade Items. Based on NRC Generic Letter 89-02 and its endorsement of ElectricPower Research Institute (EPRI) NP-5652, “Guideline for the Utilization of Commercial-Grade Items in Nuclear Safety-Related Applications,” the licensees will use the guidancecontained in EPRI NP-5652 instead of the NQA-1-1994 requirements.

6. NQA-1-1994, Supplement 10S-1, “Supplementary Requirements for Inspection,”subsection 3.1 addresses reporting independence and requires that inspectionpersonnel shall not report directly to the immediate supervisors who are responsible forperforming the work being inspected. During operational phase activities whereinspections are performed by line personnel (e.g., maintenance group), the inspectorsfunctionally report to the appropriate management position responsible for nuclearstation safety and licensing or for assuring supplier quality while performing theinspection activity. The inspection program maintains reporting independence ofinspectors by ensuring individuals performing the inspections are not the sameindividuals or supervisors responsible for performing the activity being inspected.

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7. NQA-1-1994, Supplement 17S-1, “Supplementary Requirements for Retention ofRecords,” subsection 2.8 states that the retention period for nonpermanent records isrequired to be established in writing. The licensees will meet NRC RG 1.28 RegulatoryPosition C.2 except that the reference to ASME NQA-1 will be to the 1994 edition.

The NRC staff has examined the licensees’ basis for adopting NQA-1-1994, as implementedthrough the NFQAPD, as the basis for the licensees’ QA program description and finds it to bean acceptable method for complying with the with the Commission’s regulations with regard tooverall QA program requirements for the operation phase of nuclear power plants. The NRCstaff has also reviewed the basis for each exception and alternative to NQA-1-1994 andconcluded that the exceptions and alternatives continue to meet Appendix B requirements and,therefore, are acceptable.

4.4 Assessment of QA Program Against 10 CFR Part 71 Subpart H, and Part 72 Subpart G

As noted in Section 3 of this SE, the NRC staff also performed an assessment of the NFQAPD,Topical Report DOM-QA-1, Revision 0 against the requirements under 10 CFR Part 71Subpart H, and 10 CFR Part 72 Subpart G. This assessment covered the same areasidentified in Sections 4.1.1 - 4.1.18 of this SE.

The NFQAPD describes requirements, procedures, and controls that, when properlyimplemented, comply with requirements of 10 CFR Part 71, and 10 CFR Part 72. In particular:

The structure of the organization and assignment of responsibility for each activityensure that designated parties will perform the work to achieve and maintain specifiedquality requirements.

Conformance to established requirements will be verified by qualified personnel andgroups not directly responsible for the activity being performed. These personnel andgroups report through a management hierarchy which grants the necessary authorityand organizational freedom and provides sufficient independence from economic andscheduling influences.

The Quality Program Description is well-documented and provides adequate controlover activities affecting quality, as well as structures, systems, and componentsimportant to safety, consistent with their relative importance to safety.

Based on the assessment of the NFQAPD, the NRC staff determined that the NFQAPD meetsthe requirements of Subpart H of 10 CFR Part 71, and Subpart G of 10 CFR Part 72 and,therefore, is acceptable. While this assessment determined that the NFQAPD is acceptable,continued proper implementation of the NFQAPD will be assessed during future NRCinspections.

5.0 CONCLUSION

The NFQAPD conforms to the format of SRPs 17.1 and 17.2 while following SRP 17.3 forguidance on attributes and level of details. Appendices to the NFQAPD address commitmentsfor management and independent review, RG and quality standards, definitions of terms in

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addition to those provided in NQA-1-1994, and additional QA record requirements for operatingfacilities. The NRC staff used the acceptance criteria of SRP 17.3 as the basis for evaluatingthe acceptability of the NFQAPD in conformance with the provisions of 10 CFR 50.34(b)(6)(ii). On the basis of the NRC staff’s review of the licensees’ NFQAPD, the NRC staff concludes thefollowing:

1. The NFQAPD acceptably describes the authority and responsibility of management andsupervisory personnel, performance/verification personnel, and self-assessmentpersonnel.

2. The organizations and persons responsible for performing the verification and self-assessment functions have the authority and independence to conduct their activitieswithout undue influence from those directly responsible for costs and schedules.

3. The NFQAPD applies to activities and items that are important to safety.

4. The NFQAPD describes a philosophy and controls that, when properly implemented,comply with the requirements of Appendix B and Criterion 1 of Appendix A to 10 CFRPart 50, 10 CFR Part 21, 10 CFR 50.55a, and 10 CFR 50.55(e), with the criteriacontained in SRP 17.3, and in conformance with 10 CFR Part 71 Subpart H, and10 CFR Part 72 Subpart G, and with the regulatory positions in the following RGs:

RG 1.8, Revision 1-R (Reissued May 1977) - applies to MPS1, 2 and 3 only.

RG 1.8, Second Proposed Revision 2 (September 1980) - applies to NAS1 and 2, andSPS1 and 2 facilities only.

RG 1.8, Revision 3 (May 2000).

RG 1.26, Revision 3 (February 1976).

RG 1.28, Revision 3 (August 1985).

ANSI/ASME NQA-1-1994.

RG 1.29, Revision 3 (September 1978).



RG 1.54, Revision 0 (June 1973).

RG 1.152, Revision 1 (January 1996).

RG 1.143, Revision 2 (November 2001).


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RG 7.10, Revision 1 (June 1986).

Generic Letter 89-02/EPRI-NP-5652.

Branch Technical Position ASB/CMEB 9.5-1.

Generic Letter 85-06 (commitments are site-specific, see each facility’s safety analysisreport (SAR) for details).

RG 1.97 (commitments are site-specific, see each facility’s SAR for details).

NUREG-1567.

Based on review of the licensees’ consolidated QA program, described in the proposedNFQAPD, the NRC staff concludes that the single QA program can be applied to the sevennuclear plants referenced in the submittal. The NRC staff’s review included a comparison ofthe commitments contained in the current, approved QA programs for each of the referencedplants. The NRC staff evaluated the bases provided by the licensees for each of the numerousreductions in program commitments. The adoption of NQA-1-1994 in conjunction with theNFQAPD, which incorporates supplementary requirements of ANS N18.7-1976, wasdetermined to provide an acceptable basis for the QA program description. The licensees’positions with respect to applicable standards and RGs were reviewed and found acceptable. The acceptance criteria of SRP 17.3 were used in evaluating the content of the licensees’ QAprogram description. On the basis of its review, the NRC staff concludes that the NFQAPDadequately describes the licensees’ QA program. Accordingly, the NRC staff concludes thatthe licensees’ NFQAPD complies with the applicable NRC regulations and industry standardsand can be implemented for MPS1, 2 and 3, NAS1 and 2, and SPS1 and 2 nuclear facilities.

6.0 REFERENCES

1. Christian, D. A., Dominion Nuclear Connecticut, Inc. and Virginia Electric and PowerCompany, to the NRC, “Virginia Electric and Power Company, Dominion NuclearConnecticut, Inc., Surry Power Station Units 1 and 2 and ISFSI, North Anna PowerStation Units 1 and 2 and ISFSI [independent spent fuel storage installation], MillstonePower Station Units 1, 2, and 3 and ISFSI Associated Radioactive Material PackagesNuclear Facility Quality Assurance Program Description Topical Report DOM-QA-1,Revision 0,” August 24, 2004.

2. Grecheck, E. S., Dominion Nuclear Connecticut, Inc. and Virginia Electric and PowerCompany, to the NRC, “Dominion Nuclear Connecticut, Inc., Virginia Electric and PowerCompany, Millstone Power Station Units 1, 2, and 3, North Anna Power Station Units 1and 2, Surry Power Station Units 1 and 2, Response to Requests for AdditionalInformation on Nuclear Facility Quality Assurance Program Description and AssociatedProposed Technical Specifications Changes,” May 5, 2005.

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3. Chawla, M., NRC, to J. L. Skolds, Exelon Nuclear, “Approval of Proposed Revision 70 ofQuality Assurance Topical Report EGC-1A, Rev. 70, in Accordance with10 CFR 50.54(a) Requirements for Exelon/Amergen Plants,” (ADAMS AccessionNumber ML023440300), December 24, 2002.

4. Spaulding, D. W., NRC, to E. J. Weinkam, “Approval of Nuclear Management CompanyQuality Assurance Topical Report,” (ADAMS Accession Number ML050700416),March 24, 2005.

5. Pickett, D. V., NRC, to L. W. Meyers, Centerior Service Company, “10 CFR 50.54(a)(3)Organizational Change for the Independent Safety Engineering Group - Perry NuclearPower Plant, Unit No. 1 (TAC MA3325),” September 16, 1998.

Principal Contributors: K. Kavanagh J. Pearson V. Nerses

Date: September 9, 2005

Dominion Nuclear FacilityQuality Assurance Program Description

DOM-QA-1-A i Revision 0

Introduction and Policy

Introduction

This topical report provides the quality assurance program description (QAPD) for Dominion’snuclear power stations and independent spent fuel storage installations, hereinafter referred to asfacility or nuclear facility. The quality assurance program applies to activities during design,construction, operation, and decommissioning of the nuclear facility. Activities affecting qualityinclude siting, designing, procuring, fabricating, handling, shipping, receiving, storing, cleaning,erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, modifying,and decommissioning. The quality assurance program provides adequate confidence tomanagement and regulatory agencies that structures, systems, and components will performsatisfactorily in service and that programs for coping with emergencies perform as required. Thisreport describes the policy, principles, and standards that establish the planned and systematicactions used to assure quality is achieved in all activities affecting the safety of the nuclearfacility. These policies, principles, and standards are developed into administrative andimplementing documents. The administrative and implementing documents govern the variousaspects of day-to-day activities for the facility.

Dominion’s Nuclear Facility QAPD is referred to by several generic titles within theadministrative controls for the facilities. These include Chapter 17.2 of the UFSAR, theOperational Quality Assurance Program, the Quality Assurance Plan (or Program), the QATopical Report, and other similar designations. These are used interchangeably to refer to thisdocument which represents Dominion Management’s philosophy and methodologies forcomplying with the 18 criteria of 10 CFR 50, Appendix B. Within this QAPD, the term“Company” is used to refer to those parts of the parent company (Dominion) that are under thepurview of the Chief Nuclear Officer as described in Section 1 of this QAPD.

This QAPD is formatted to specifically follow the 18 criteria of 10 CFR 50, Appendix B, withSections 1 through 18 describing Dominion’s quality principles and methods for complying withthose 18 criteria. As such, this QAPD is formatted similar to the NUREG-0800 Standard ReviewPlan, Sections 17.1 and 17.2, but modified consistent with the current NRC guidance on contentof QAPDs and addressing the commitment to NQA-1 in place of the ANSI N45.2 seriesstandards.

The quality assurance measures and administrative controls established by this QAPD arecomparable to those implemented during the construction, operational, and decommissioningactivities conducted prior to the effective date of this QAPD. Conformance of the existingstructures, systems, and components (including new, spare, and replacement items in storage, instock, or on order) to the previous QA program requirements shall be treated as conforming tothe requirements of this QAPD. Where new or updated requirements are established by thisQAPD, they are not retroactively applied, but will be applied to the activities conductedsubsequent to the effective date of this QAPD.


DOM-QA-1-A ii Revision 0

Policy

This policy provides the expectations to safely design, construct, operate, and decommissionDominion’s nuclear facilities. Each employee and Supplier is responsible for the quality of theirwork. Maintaining quality of workmanship, whether physical or programmatic, ensures that ournuclear facilities are designed, constructed, operated, and decommissioned safely, efficiently,and economically and that regulatory commitments are met. Suppliers providing items andservices affecting safety of the nuclear facilities are also expected to implement a qualityassurance program or quality controls that meet regulatory requirements.

Quality programs focus employees’ and Suppliers’ attention on regulatory requirements andmanagement expectations while requiring identification of concerns. These programs will beimplemented for safety-related activities affecting structures, systems, and components. Asidentified within the QAPD and Company documents, applicable elements of the qualityassurance program will be applied to selected activities that are not safety-related, but supportsafe facility operations. The Dominion Nuclear quality program will comply with therequirements of 10 CFR 50, Appendix B, the approved facility license, and applicable codes andstandards as further described in this QAPD.

SignedDavid A. ChristianSenior Vice President Nuclear Operationsand Chief Nuclear Officer


DOM-QA-1-A iii Revision 0

Basis

This QAPD is based on 10 CFR 50, Appendix B, as amended. The requirements of 10 CFR 50,Appendices A (General Design Criterion I) and R, 50.54, 50.55, 50.55(a), 50.59, 50.82;10 CFR 21; 10 CFR 71, Subpart H; and 10 CFR 72, Subpart G are also included in thedevelopment and application of this QA program.

Dominion is committed to carrying out the provisions of various NRC Regulatory Guides andindustry quality standards of ASME, ANSI, and ANS that expound on the 18 criteria of10 CFR 50, Appendix B. The specific commitments, clarifications, and alternatives are describedin detail within the QAPD.

This QAPD is intended to be a comprehensive, up-to-date description of Dominion’s qualityassurance program for nuclear facilities. This topical report will be revised in accordance with10 CFR 50.54(a) and 50.55(f).


DOM-QA-1-A iv Revision 0

Table of Contents

Introduction and Policy.................................................................................................................... iIntroduction.................................................................................................................................. iPolicy .......................................................................................................................................... iiBasis........................................................................................................................................... iii

Table of Contents........................................................................................................................... iv1.0 Organization.......................................................................................................................... 1

1.1 General Description .......................................................................................................... 11.2 Responsibility and Authority ............................................................................................ 1

1.2.1 Chief Nuclear Officer ................................................................................................ 11.2.2 Nuclear Operations .................................................................................................... 21.2.3 Facility Operations..................................................................................................... 21.2.4 Engineering Services ................................................................................................. 41.2.5 Support Services ........................................................................................................ 61.2.6 Nuclear Oversight ...................................................................................................... 7

1.3 Succession of Responsibility for Overall Plant Operation ............................................... 81.4 Organization Charts .......................................................................................................... 81.5 Quality Standards Commitment........................................................................................ 8

2.0 Quality Assurance Program.................................................................................................. 92.1 General Description .......................................................................................................... 92.2 Applicability ..................................................................................................................... 92.3 Oversight of the Quality Program Implementation ........................................................ 102.4 Identification of Structures, Systems, and Components (SSC) ...................................... 102.5 Selection, Training, and Qualification of Personnel ....................................................... 10

2.5.1 Operating Facility Staff............................................................................................ 112.5.2 Support Organizations ............................................................................................. 122.5.3 Quality Assurance Verification Personnel............................................................... 122.5.4 Quality Assurance Audits ........................................................................................ 132.5.5 Quality Control Verification .................................................................................... 132.5.6 Non-Destructive Examination Technicians ............................................................. 132.5.7 ASME Code Visual Examinations........................................................................... 14

2.6 Control of Activities ....................................................................................................... 142.7 Quality Standards Commitment...................................................................................... 14

3.0 Design Control.................................................................................................................... 143.1 General Description ........................................................................................................ 143.2 Design Control Program ................................................................................................. 14

3.2.1 Design Change Control............................................................................................ 153.2.2 Design Interface Control.......................................................................................... 153.2.3 Design Verification.................................................................................................. 153.2.4 Software Design and Control................................................................................... 15

3.3 Quality Standards Commitment...................................................................................... 154.0 Procurement Document Control ......................................................................................... 15

4.1 General Description ........................................................................................................ 154.2 Preparation, Review, and Approval of Procurement Documents ................................... 164.3 Quality Standards Commitment...................................................................................... 16


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5.0 Instructions, Procedures, and Drawings ............................................................................. 165.1 General Description ........................................................................................................ 165.2 Procedure Adherence ...................................................................................................... 175.3 Procedure Content........................................................................................................... 175.4 Types of Procedures and Instructions ............................................................................. 175.5 Quality Standards Commitment...................................................................................... 21

6.0 Document Control............................................................................................................... 226.1 General Description ........................................................................................................ 226.2 Applicability ................................................................................................................... 226.3 Document Review and Approval.................................................................................... 226.4 Additional Operations and Decommissioning Phase Review Requirements ................. 236.5 Distribution of Controlled Documents............................................................................ 236.6 Quality Standards Commitment...................................................................................... 23

7.0 Control of Purchased Material, Equipment, and Services .................................................. 247.1 General Description ........................................................................................................ 247.2 Selection of Suppliers ..................................................................................................... 247.3 Conformance of Items and Services ............................................................................... 247.4 Quality Verification ........................................................................................................ 247.5 Quality Standards Commitment...................................................................................... 25

8.0 Identification and Control of Materials, Parts, and Components ....................................... 258.1 General Description ........................................................................................................ 258.2 Quality Standards Commitment...................................................................................... 25

9.0 Control of Special Processes............................................................................................... 269.1 General Description ........................................................................................................ 269.2 Qualification of Special Processes Personnel, Procedures and Equipment .................... 269.3 Quality Standards Commitment...................................................................................... 26

10.0 Inspection.......................................................................................................................... 2610.1 General Description ...................................................................................................... 2610.2 Inspection Program ....................................................................................................... 2710.3 Inspector Qualification.................................................................................................. 2710.4 Quality Standards Commitment.................................................................................... 27

11.0 Test Control ...................................................................................................................... 2811.1 General Description ...................................................................................................... 2811.2 Test Procedures ............................................................................................................. 2911.3 Evaluation of Test Results ............................................................................................ 2911.4 Scheduling..................................................................................................................... 2911.5 Quality Standards Commitment.................................................................................... 29

12.0 Control of Measuring and Test Equipment....................................................................... 3012.1 General Description ...................................................................................................... 3012.2 Installed Instrument and Control Devices..................................................................... 3012.3 Quality Standards Commitment.................................................................................... 30

13.0 Handling, Storage, and Shipping ...................................................................................... 3013.1 General Description ...................................................................................................... 3013.2 Special Handling, Storage, Shipping, Cleaning and Preservation Requirements......... 3113.3 Quality Standards Commitment.................................................................................... 31


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14.0 Inspection, Test, and Operating Status ............................................................................. 3214.1 General Description ...................................................................................................... 3214.2 Control of Systems and Equipment for Operating Facilities ........................................ 3214.3 Quality Standards Commitment.................................................................................... 33

15.0 Nonconforming Materials, Parts, or Components ............................................................ 3315.1 General Description ...................................................................................................... 3315.2 Nonconformance Responsibilities ................................................................................ 3315.3 Nonconformance Documentation ................................................................................. 3415.4 Quality Standards Commitment.................................................................................... 34

16.0 Corrective Action.............................................................................................................. 3416.1 General Description ...................................................................................................... 3416.2 Corrective Action Documentation ................................................................................ 3416.3 Follow-up...................................................................................................................... 3516.4 Quality Standards Commitment.................................................................................... 35

17.0 Quality Assurance Records............................................................................................... 3517.1 General Description ...................................................................................................... 3517.2 Records of Activities..................................................................................................... 3517.3 Record Storage.............................................................................................................. 3517.4 Quality Standards Commitment.................................................................................... 36

18.0 Quality Assurance Audits ................................................................................................. 3618.1 General Description ...................................................................................................... 3618.2 Audit Scope................................................................................................................... 3718.3 Audit Responsibilities and Procedures ......................................................................... 3718.4 Supplier Quality Assurance .......................................................................................... 3718.5 Internal Audits .............................................................................................................. 3718.6 Quality Standards Commitment.................................................................................... 38

Appendix A.................................................................................................................................... ACorporate and Technical Support ................................................................................................... 1Operating Facility Organization ..................................................................................................... 2Operating Facility Staff Reporting To Support Organizations ....................................................... 3Appendix B .....................................................................................................................................B

Management and Independent Review Activities ...................................................................... 11.0 General .............................................................................................................................. 12.0 Qualifications .................................................................................................................... 13.0 Management Safety Review Committee (MSRC)............................................................ 2

3.1 Review Responsibilities................................................................................................ 23.2 Composition.................................................................................................................. 23.3 Alternates ...................................................................................................................... 23.4 Meeting Frequency ....................................................................................................... 23.5 Quorum ......................................................................................................................... 33.6 Records ......................................................................................................................... 3

4.0 Facility Safety Review Committee ................................................................................... 34.1 Composition.................................................................................................................. 34.2 Alternates ...................................................................................................................... 34.3 Meeting Frequency ....................................................................................................... 34.4 Quorum ......................................................................................................................... 3


DOM-QA-1-A vii Revision 0

4.5 Responsibilities ............................................................................................................. 44.6 Authority ....................................................................................................................... 54.7 Records ......................................................................................................................... 5

5.0 Independent Nuclear Safety Review................................................................................. 55.1 Function ........................................................................................................................ 55.2 Composition.................................................................................................................. 55.3 Responsibilities ............................................................................................................. 65.4 Authority ....................................................................................................................... 65.5 Records ......................................................................................................................... 6

Appendix C .....................................................................................................................................CRegulatory Guides and Quality Standards Commitments .......................................................... 1

1. Regulatory Guide 1.8, Revision 1-R (Reissued May 1977) .............................................. 12. Regulatory Guide 1.8, Second Proposed Revision 2, (September 1980) .......................... 23. Regulatory Guide 1.8, Revision 3, May 2000 ................................................................ 34. Regulatory Guide 1.26, Revision 3, February 1976 .......................................................... 45. Regulatory Guide 1.28, Revision 3, August 1985 ............................................................. 46. ANSI/ASME NQA-1-1994................................................................................................ 47. Regulatory Guide 1.29, Revision 3, September 1978........................................................ 88. Regulatory Guide 1.33, Revision 2, February 1978 .......................................................... 89. Regulatory Guide 1.36, Revision 0, February 1973 .......................................................... 910. Regulatory Guide 1.54, Revision 0, June 1973 ................................................................ 911. Regulatory Guide 1.152, Revision 1, January 1996 ......................................................... 912. Regulatory Guide 1.143, Revision 2, November 2001..................................................... 913. Regulatory Guide 4.15, Revision 1, February 1979 ......................................................... 914. Regulatory Guide 7.10, Revision 1, June 1986 .............................................................. 1015. Generic Letter 89-02/EPRI-NP-5652 ............................................................................. 1016. Branch Technical Position ASB/CMEB 9.5-1................................................................ 1017. Generic Letter 85-06 ....................................................................................................... 1018. Regulatory Guide 1.97 .................................................................................................... 10

Appendix D.................................................................................................................................... DTerms and Definitions ................................................................................................................ 1

Appendix E .....................................................................................................................................EAdditional QA Records Requirements for Operating Facilities ................................................. 1


DOM-QA-1-A 1 Revision 0

1.0 Organization

1.1 General Description

This section describes the key organizations performing activities for Dominion’s nuclearfacilities and their responsibilities governed by the Quality Assurance Program Description(QAPD) Topical Report. The reporting relationships are depicted in the organization charts ofAppendix A.

The Company’s organizational structure ensures compliance with regulatory requirements andindustry standards for the implementation of this QAPD. The organizational structure isdelineated through the organizational charts, the duties and responsibilities described below andin the policy statement, and written job or functional descriptions contained in implementingdocuments. These individuals and groups described herein are responsible for performing orverifying activities affecting quality. The Company may delegate all or part of the activities ofplanning, establishing, and implementing the quality assurance program to others, but retains theresponsibility for the program’s effectiveness. When activities are delegated to organizationsoutside the Company, procedures require the establishment of interface requirements includingdefining authorities and lines of communication as appropriate for the delegated functions.However, the Company retains and exercises responsibility for the scope and effectiveimplementation of the quality assurance program.

The organization consists of three main parts: corporate management, support organizations, andfacility operations. Corporate management is responsible for overall management of theCompany’s nuclear facilities through all the phases from initial siting to decommissioning. Thesupport groups provide management, technical, and oversight support for activities such asdesign, construction, operation, modification, and decommissioning and report to corporatemanagement. The support groups may be located at corporate offices or at a nuclear facility site.The facility operations groups are responsible for overall operational activities of assignednuclear facilities in accordance with the facility license. The operations groups are typicallyassigned responsibility for one or more nuclear power station units and any associatedIndependent Spent Fuel Storage Installations at a particular site.

The overall structure of the organization described herein is applied for all facilities, however,there may be slight variations in responsibilities between facilities, but the overall reportingrelationships remain. Depending on the scope of the activities, one or more individuals may beassigned the described management responsibilities. As the amount of certain activities changes,such as construction or decommissioning, the organizational structure may change and will bereflected in a change to these descriptions.

1.2 Responsibility and Authority

1.2.1 Chief Nuclear Officer

The chief nuclear officer (CNO) has overall responsibility and authority for the implementationof all activities associated with the safe and reliable design, construction, operation, anddecommissioning of Dominion’s nuclear facilities. The CNO establishes the Company’s quality



assurance policy and provides guidance regarding its implementation. The CNO has theauthority to resolve disputes related to implementation of this QAPD for which resolution is notachieved at lower levels within the organization. There are four functional organizationsreporting to the CNO that affect the safety of the nuclear facilities: operations, engineering,support services, and oversight.

1.2.2 Nuclear Operations

An executive management position is responsible for overall operating activities of theCompany’s nuclear facilities. This executive is responsible for implementing the qualityassurance program during operating activities, including related decommissioning activities.

1.2.3 Facility Operations

An executive management position is responsible for operations of their assigned Companynuclear facilities. The necessary responsibility and authority for the management and direction ofall activities related to the safe and efficient operation and decommissioning has been delegatedby the senior executives. This responsibility includes ensuring quality through implementation ofthis QAPD in all the activities related to operation such as maintenance, testing, start-up andshut-down, refueling, fuel storage, and modification.

1.2.3.1 Facility Operations and Maintenance

A senior management position is responsible for safe operations and maintenance of theirassigned nuclear facilities including those activities necessary for safe storage and handling ofspent nuclear fuel during decommissioning. The position responsibilities include: directing theoperations, maintenance, planning, and site services groups; implementing facility modifications;and maintaining compliance with requirements of the operating license, TechnicalSpecifications, and applicable federal, state, and local laws, regulations, and codes.

1.2.3.1.a Operations

Operations is responsible for operating the facility in accordance with the applicable license,including those in a decommissioning phase that still contain nuclear fuel. Overall facilityoperation is directed by a management position responsible for Operations activities.

Operations activities include monitoring and controlling day-to-day operation of the nuclearfacility; responding to alarms; manipulating facility equipment; coordinating facility operationsto manage work such as maintenance, testing, and modifications; and moving nuclear fuel. TheOperations organization contains supervision and staff for shift operations, including shiftmanagers, unit supervisors, licensed control room operators, and non-licensed operators.

The staff for operating units, when approved by the NRC and documented in this QAPD, may beresponsible for activities related to an adjacent decommissioned unit’s spent fuel pool andauxiliary systems, providing that the transfer of responsibility does not impact the capability toperform their operating duties, including day-to-day functions, and accident and transient



mitigation. Minimum shift composition will be in accordance with the nuclear facility’sTechnical Specifications. Specifically, the following allowances are approved:

Millstone Unit 2 Operations is responsible for operations regarding the Millstone Unit 1Spent Fuel Pool Island and auxiliary systems.

1.2.3.1.b Maintenance

Maintenance is responsible for directing and coordinating facility maintenance activitiesincluding on-line maintenance, installation, maintenance, alterations, adjustment and calibration,replacement and repair of plant electrical and mechanical equipment, and instruments andcontrols. The responsibilities include performance of surveillances required by TechnicalSpecifications, establishing standards and frequency of calibration for instrumentation andcontrol devices, and ensuring instrumentation and related testing equipment are properly used,inspected and maintained.

1.2.3.1.c Outage & Planning

Outage & Planning is responsible for planning and scheduling online-maintenance and outageactivities.

1.2.3.1.d Site Services

Site Services is responsible for facility project support, including project construction and projectcontrols.

1.2.3.2 Facility Safety & Licensing

A senior management position is responsible for ensuring that facility safety and licensingrequirements are implemented. This position is responsible for directing and coordinatingradiological protection and assessment of nuclear safety issues at the facility, includingindependent review functions through the facility safety review committee and the independentnuclear safety review group. The responsibilities also include managing licensing activities;interfacing with corporate management on operating experience and licensing issues, managingfacility procedures, controlling documents and records at MPS, and administering the facilityenvironmental compliance program in VA. This position is independent of cost and schedulingconcerns associated with operations, maintenance, and modification activities. This position hasthe authority to suspend unsatisfactory work and control further processing or installation of non-conforming materials. The authority to stop work delegated to quality control inspectionpersonnel is delineated in procedures.

1.2.3.2.a Organizational Effectiveness

Nuclear Organizational Effectiveness is responsible for the corrective action program, theoperating experience program, and the independent nuclear safety review group that includes the



Shift Technical Advisors and performs the independent safety engineering review function inaccordance with the applicable facility commitment to NUREG-0737.

1.2.3.2.b Radiological Protection & Chemistry

Radiological Protection & Chemistry carries out health physics and chemistry functions andmaintains sufficient organizational freedom and independence from operating pressures asrequired by the facility Technical Specifications. A qualified supervisor or manager is assignedto fulfill the radiological protection manager position described in Section 2.5 of this QAPD. Theradiological protection responsibilities include scheduling and conducting radiological surveys,contamination sample collection, determining contamination levels, assigning work restrictionsthrough radiation work permits, administering the personnel monitoring program, andmaintaining required records in accordance with federal and state codes. The chemistryresponsibilities include maintaining primary and secondary plant chemistry in accordance withestablished program requirements.

1.2.3.2.c Procedures

The Procedures group is responsible for ensuring that procedures are prepared in accordancewith applicable regulatory requirements, industry quality standards, and this QAPD.

1.2.3.2.d Document Control and Records Management (MPS)

Document control and records management groups are assigned responsibility to ensure thatcontrolled documents (such as manuals, instructions, procedures, and drawings) and facilityrecords are maintained in accordance with applicable regulatory requirements, industry qualitystandards, and this QAPD.

1.2.3.2.e Quality Control Inspections (VA)

The Quality Control Inspection group plans and conducts inspections of maintenance andmodification activities for operating facilities to ensure quality in accordance with therequirements of the QA program. The Quality Control Inspectors from the Maintenance and SiteServices groups report through this functional organization while performing maintenance andmodification inspections for the operating facilities in Virginia.

1.2.4 Engineering Services

An executive management position is responsible for the engineering functions supportingdesign and construction activities and long-term nuclear operations. These are accomplishedthrough nuclear engineering, projects, nuclear analysis and fuel, information technology, anddocument control and records management groups. Responsibilities include system levelimplementation of the requirements established by this QAPD for the nuclear facilities andfacility specific engineering and technical support required for day-to-day operations. Whereimplementation of any or all of these functions is delegated to organizations outside theCompany, procedures require the establishment of interface documents including defining lines



of communication and authorities as appropriate for the delegated functions. However, thisexecutive management position retains responsibility for the scope and effective implementationof the quality assurance program for those functions.

1.2.4.1 Nuclear Engineering

A senior management position is responsible for design engineering functions; supportingactivities such as independent design checks and reviews, developing and maintainingengineering programs, including those for nondestructive examination (NDE), and the facilityinservice inspection and test (ISI/IST) programs; configuration management including designand configuration control, and developing and revising facility drawings; and engineeringtechnical support at the operating facilities.

1.2.4.1.a Facility Engineering

Facility Engineering is responsible for managing engineering resources providing day-to-daytechnical support for facility operations. The functions include engineering and technical supportat a system and component level to ensure optimum design basis performance, system reliability,and optimum component performance and reliability. Support is also provided in developing andimplementing testing programs, tracking and scheduling test performance, and evaluating testresults. The test programs include inservice inspections, Technical Specification surveillances,postmodification and postmaintenance testing, and nondestructive examinations.

1.2.4.1.b Design Engineering

Design Engineering is responsible for classifying SSCs, implementing the design controlprogram, and ensuring the design basis for the facility is maintained.

1.2.4.1.c Document Control and Records Management (VA)

Document control and records management groups are assigned responsibility to ensure thatcontrolled documents (such as manuals, instructions, procedures, and drawings) and facilityrecords are maintained in accordance with applicable regulatory requirements, industry qualitystandards, and this QAPD.

1.2.4.2 Nuclear Analysis and Fuel (NAF)

A senior management position is responsible for activities related to safety and management ofnuclear fuel. NAF is responsible for engineering activities, evaluation, and analysis of: coredesign, fuel and reactor performance, probabilistic risk assessment, spent fuel storage, andradiological effects. NAF provides reactor engineering support for the operating power stations.NAF is responsible for nuclear fuel procurement, assurance of nuclear fuel quality throughsurveillances and inspections at Company and Supplier facilities, and special nuclear materialaccountability. This position has the authority to control further processing or installation ofnonconforming materials. The authority delegated to inspection and surveillance personnel is



delineated in procedures. NAF is also responsible for providing engineering oversight of drycask spent fuel storage system fabrication, including approval of nonconformance disposition. 1.2.4.3 Nuclear Projects

A senior management position is responsible for the implementation of large projects for thenuclear facilities on behalf of the Company. Implementation includes development of thedetailed scope, estimate, schedule, cost, design, procurement, construction, testing, and closeoutof each project. Nuclear Projects focuses on defined projects separate from ongoing routineengineering projects.

1.2.4.4 Information Technology

A senior management position is responsible for direction and support of information technologyfor the Nuclear organizations and facilities. Responsibilities include: network infrastructuremaintenance and upgrade, network and application security, network operations; automationstrategy, application development and support, automation training; development andmaintenance of the software control program; and oversight, maintenance, and repair of theEmergency Response Facility Computer System. 1.2.5 Support Services

An executive management position is responsible to provide licensing, fire protection, security,emergency preparedness, training, and procurement support services to the NuclearOrganization. This position is also responsible for activities associated with the permitting andlicensing process for new nuclear power plant construction. Where implementation of any or allof these functions is delegated to organizations outside the Company, procedures require theestablishment of interface documents including defining lines of communication and authoritiesas appropriate for the delegated functions. However, this executive management position retainsresponsibility for the scope and effective implementation of the quality assurance program forthose functions.

1.2.5.1 Licensing & Operations Support

A senior management position is responsible for providing regulatory compliance and licensingsupport through NRC communications, maintaining and acquiring licenses required forcontinued and extended operations and providing operations, chemistry and health physicssupport.

1.2.5.2 Protection Services & Emergency Preparedness

A senior management position is responsible for providing nuclear facility security, and overallmanagement of Nuclear Emergency Preparedness activities.



1.2.5.2.a Protection Services

Protection Services is responsible for facility protective services, including physical security,nuclear facility access programs, and fitness for duty programs. Protection Services is alsoresponsible for industrial safety and loss prevention including oversight of fire protectionmeasures.

1.2.5.2.b Emergency Preparedness

Emergency Preparedness is responsible for development and maintenance of the Companyradiological emergency plans and coordination with required off-site radiological emergencyresponse groups for the nuclear facilities. This includes managing the overall scheduling andcoordination of emergency plan testing, training and exercises with federal, state, and localagencies, and working with corporate and facility personnel to ensure emergency plans meet allthe requirements and commitments.

1.2.5.3 Training

A senior management position is responsible for the training of personnel who operate or supportthe nuclear facilities. Training responsibilities include: determining the need for training basedon information provided by the various groups, developing performance-based trainingprograms, implementing training programs to support employee and facility needs, andevaluating training programs. Certain functional groups may be assigned responsibility for thedevelopment and conduct of their own training programs provided these groups are not requiredto have a systems approach to training under 10 CFR 50.120.

1.2.5.4 Supply Chain Management

A senior management position is responsible for material management, purchasing, procurementengineering, Supplier surveillance functions, and source and receipt inspection. This position hasthe authority to control further processing or installation of nonconforming materials. Thisauthority is delegated to inspection and surveillance personnel as delineated in procedures.

1.2.6 Nuclear Oversight

A senior management position is responsible for the verification of effective Company andSupplier QA program development, documentation, and implementation. This position isindependent of cost and scheduling concerns associated with construction, operations,maintenance, modification, and decommissioning activities for performing quality assuranceprogram verification. Where implementation of any or all of these functions is delegated toSuppliers, procedures require the establishment of interface documents including defining linesof communication and authorities as appropriate for the delegated functions. However, thissenior management position retains responsibility for the scope and effective implementation ofthe quality assurance program for those functions. This management position has the necessaryauthority and responsibility for verifying quality achievement; identifying quality problems,recommending solutions and verifying implementation of the solutions; and escalating quality



problems to higher management levels. This position has the authority to suspend unsatisfactorywork and control further processing or installation of non-conforming materials. The authority tostop work delegated to Nuclear Oversight personnel is delineated in procedures.

Nuclear Oversight is responsible for the evaluation of Suppliers’ quality programs through asystem of external audits, evaluations, and reviews of Supplier performance in accordance withquality assurance requirements. A list of approved Suppliers is maintained.

Nuclear Oversight is responsible for assuring Company compliance with this QAPD throughadministration of a comprehensive and systematic internal audit program.

Nuclear Oversight is responsible for developing and maintaining an appropriate qualityverification inspection program where not provided for in the facility construction or operatingorganization functions.

1.2.6.1 Facility Nuclear Oversight

A management position is responsible for the effective performance of Nuclear Oversightactivities. This position performs independent assessment of facility operations related to qualityand safety with lines of communication to the executive management position responsible forfacility operations.

1.2.6.1.a Quality Control Inspections (MPS)

The Quality Control Inspection group plans and conducts inspections of operating facilitymaintenance and modification activities to ensure quality in accordance with the requirements ofthe QA program. The Quality Control Inspectors report through this functional organizationwhile performing maintenance and modification inspections for the operating facilitiesassociated with MPS.

1.3 Succession of Responsibility for Overall Plant Operation

The succession of responsibility for overall plant instructions or special orders, in the event ofabsences, incapacitation of personnel, or other emergencies, is as follows, unless otherwisedesignated in writing:• the executive management position responsible for facility operations• the senior management position responsible for facility operations & maintenance

1.4 Organization Charts

Organization charts depicting reporting relationships are contained in Appendix A to this QAPD.

1.5 Quality Standards Commitment

The Company is committed to establishing and maintaining an organization in accordance with thequality standards described in NQA-1-1994, Basic Requirement 1 and Supplement 1S-1.



2.0 Quality Assurance Program


Dominion has established a quality assurance program for the nuclear power stations andindependent spent fuel storage installations that complies with 10 CFR 50, Appendix B, asamended. A description of this program is contained within Topical Report DOM-QA-1 entitledNuclear Facility Quality Assurance Program Description. This quality assurance program isbased on the requirements of the Regulatory Guides and Industry Standards (with approvedalternatives) described in Appendix C to this QAPD. The total quality assurance programconsists of (1) the Policy statement on quality assurance (included in DOM-QA-1), (2) thisQuality Assurance Program Description (QAPD), plus the (3) administrative controls andinterface documents, and (4) training and qualification programs developed in accordance withthis QAPD.

The application of this program accomplishes two important objectives: (1) provide orderly,uniform administrative and managerial documents to assure safe and reliable operation ofnuclear facilities, and (2) assure compliance with regulations promulgated by the U.S. NuclearRegulatory Commission. Quality assurance activities include planned and periodic audits,reviews, inspections, and other forms of verification to ensure adequacy and completeness ofwork and the effectiveness of quality programs. Measures are implemented to ensure individualsperforming quality assurance audit and inspection/test activities have the authority andorganizational freedom (including independence from cost and schedules relative to safetyconsiderations) to identify problems, to recommend solutions, and to verify implementation andeffectiveness of corrective actions.

2.2 Applicability

This program applies to those activities that involve the safety-related functions of structures,systems, and components (SSCs) during design, construction, operation, and decommissioningof the Company’s nuclear facilities. The applicable provisions of this QAPD are put into place asearly as practicable for the above phases of the facilities. Activities important to safetyincorporate applicable portions of this program into their governing documents. In addition tothis QAPD, the following documents further describe application of portions of the QA program,where appropriate, for their associated nuclear facilities: the Safety Analysis Report (SAR),nuclear design control program, physical security plan, emergency plan, radiological protectionplan including radioactive material transport and radioactive waste processing, fire protectionplan, station blackout program, nuclear chemistry laboratory quality assurance program.Personnel participating in activities where this QA program is applicable are required to followthe established program requirements.

Designated activities may be performed by Suppliers under their quality assurance program. TheSupplier’s quality assurance program will comply with the criteria expressed in 10 CFR 50,Appendix B, as amended, and with the appropriate Regulatory Guides and nuclear industryStandards listed in Appendix C, as stipulated in contractual documents. The Companyimplements measures to review and accept the Supplier’s quality assurance program.



2.3 Oversight of the Quality Program Implementation

In order to maintain an effective QA program, Nuclear Oversight performs periodic andsystematic evaluations through internal and external audits of the program’s implementation. Theresults of the evaluations and recommendations for improving the QA program are provided tothe appropriate management responsible for implementation in the areas audited. Managementprovides oversight of quality program implementation and effectiveness by reviewing the resultsof audits in their area of responsibility and acting upon any deficiencies identified. In addition,management oversight of the quality program effectiveness is provided through the activities ofreview groups reporting to management. The composition and function of the review groups aredescribed in Appendix B to this QAPD.

Quality Control inspection programs are established that provide for independent inspection ofquality attributes. These inspections may be performed by craft personnel, but the inspectionprogram ensures individuals performing the inspections are not the same individuals orsupervisors responsible for performing the activity being inspected. Individuals are assignedresponsibility for the effective implementation of the quality inspection programs, to certify thequalification of inspection and test personnel, and to facilitate the raising of quality issuesaffecting nuclear safety to management. The authority to stop work delegated to personnelperforming quality assurance roles is delineated in Company documents.

2.4 Identification of Structures, Systems, and Components (SSC)

Programs are established to identify those SSCs where the QA program applies. These programsare administratively controlled and are implemented by the groups responsible for design of thefacility. The SAR for the facility provides an overview of the SSCs that are safety-related orimportant to safety and require application of quality assurance measures of this program.

2.5 Selection, Training, and Qualification of Personnel

The Company has established and implements programs and processes to ensure that personnelare knowledgeable in the applicable quality requirements before performing the activities towhich this QAPD is applied. Management is responsible to ensure they have a trained andqualified staff. The Nuclear Training group assists in this by establishing and maintainingtraining programs that meet the systematic approach to training of 10 CFR 50.120 and areaccredited by the National Nuclear Accrediting Board of the National Academy for NuclearTraining (NANT). Additional training is provided as needs are identified. The Company iscommitted to providing training (initial and continuing) that meets the standards, withalternatives, identified below for the applicable facility. These standards and alternatives arefurther addressed in Appendix C to this QAPD.

The retraining and replacement training programs for the NRC licensed facility staff meet orexceed the requirements of 10 CFR 55.59 and 55.31(a)(4) for the respective units and shall bemaintained. In addition, for units being decommissioned, an NRC approved training andretraining program for CERTIFIED FUEL HANDLERS shall be maintained as required by thelicense.



2.5.1 Operating Facility Staff

The facility staff meet the qualifications described herein for the stated facilities.

2.5.1.1 Millstone Power Station

Each member of the facility staff shall meet or exceed the minimum qualifications of ANSIN18.1-1971 for comparable positions, except that:

(1) The radiation protection manager shall meet or exceed the qualifications of RegulatoryGuide 1.8, Revision 1, May 1977.

(2) As of November 1, 2001, applicants for reactor operator and senior reactor operatorqualification shall meet or exceed the education and experience guidelines of RegulatoryGuide 1.8, Revision 3, May 2000.

The following additional unit specific requirements will be maintained:

Millstone Power Station Unit 1The Operations Manager or Assistant Operations Manager shall be a CERTIFIED FUELHANDLER in accordance with the facility Technical Specifications.

Millstone Power Station Unit 21. If the operations manager does not hold a senior reactor operator license for Millstone

Unit No. 2, then the operations manager shall have held a senior reactor operatorlicense at a Pressurized Water Reactor and an individual serving in the capacity of theassistant operations manager shall hold a senior reactor operator license for MillstoneUnit No. 2.

2. The Shift Technical Advisor (STA) who shall meet the requirements of l or 2 below:1. Dual-role individual: Must hold a senior reactor operator’s license at Millstone

Unit No. 2, meet the STA training criteria of NUREG-0737, Item I.A.l.1, andmeet one of the following educational alternatives: a. Bachelor’s degree in engineering from an accredited institution:b. Professional Engineer‘s license obtained by the successful completion of the

PE examination;c. Bachelor’s degree in engineering technology from an accredited institution,

including course work in the physical, mathematical, or engineering sciences;d. Bachelor’s degree in a physical science from an accredited institution,

including course work in the physical, mathematical, or engineering sciences;e. Successful completion of the Memphis State University (MSU) STA program.

(Note: This alternative is only acceptable for individuals who have completedthe program prior to December 31, 1986); or

f. Successful completion of the Thames Valley State Technical Collegeassociate’s degree in Nuclear Engineering Technology program, provided thatthe individual was enrolled in the program by October 1, 1987.

2. Dedicated STA: Must meet the STA training criteria of NUREG-0737, Item I.A.1.1,and have received specific training in plant design, and response and analysis of theplant for transients and accidents.




Unit No. 3, then the operations manager shall have held a senior reactor operatorlicense at a pressurized water reactor, and the assistant operations manager shall holda senior reactor operator license for Millstone Unit No. 3.

2. The Shift Technical Advisor shall have a bachelor’s degree or equivalent in ascientific or engineering discipline and shall have received specific training in theresponse and analysis of the unit for transients and accidents, and in unit design andlayout, including the capabilities of instrumentation and controls in the control room.

2.5.1.2 North Anna and Surry Power Stations

These qualification requirements apply to the power stations and their associated IndependentSpent Fuel Storage Installations. Each member of the facility staff shall meet or exceed theminimum qualifications of ANS-3.1 (12/79 Draft) for comparable positions except that theRadiological Protection Manager shall meet or exceed the qualifications of Regulatory Guide1.8, September 1975. The following additional unit specific requirements will be maintained:

North Anna Power StationThe individual filling the role of operations manager and the individual filling the role of

operations middle manager (supervisor shift operations) will meet the licenserequirements of North Anna Units 1 and 2 Technical Specification 5.2.2.e.

Surry Power StationThe individual filling the role of operations manager and the individual filling the role of

operations middle manager (supervisor shift operations) will meet the licenserequirements of Surry Units 1 and 2 Technical Specification 6.1.2.2.d.

2.5.2 Support Organizations

Personnel performing support activities may either meet the qualification requirements ofstandards referenced above for the facility they are performing the function for, or thequalification requirements of ANSI/ANS-3.1-1993 as endorsed by NRC Regulatory Guide 1.8,Revision 3.

2.5.3 Quality Assurance Verification Personnel

Personnel performing the following quality verification activities meet the qualificationrequirements of ANSI/ANS-3.1-1993, and the applicable Regulatory Positions of NRCRegulatory Guide 1.8, Revision 3, for the activities they perform:

2.5.3.1 Management Position Responsible for Nuclear Oversight

The person filling the Management Position Responsible for Nuclear Oversight will meet therequirements of Section 4.3.7 and Regulatory Position 2.1.1.



2.5.3.2 Supervisor/Coordinator Responsible for Quality Assurance or Quality Control

The person filling the supervisor or coordinator position responsible for quality assurance orquality verification (audits, inspections and tests, and surveillances of Company or Supplieractivities, and NDE) will meet the requirements of Section 4.4.13. This position includesresponsibility for certification that personnel performing the quality assurance or qualityverification activities are qualified for their assigned tasks. For visual examinations to meet theASME code, the training group may be delegated responsibility for the certification.

2.5.4 Quality Assurance Audits

Personnel performing audits are trained and qualified in accordance with a program that meetsthe applicable requirements of NQA-1–1994, Basic Requirement 2 and Supplement 2S-3.

2.5.5 Quality Control Verification

Personnel performing quality control verification through inspection and test, or surveillanceactivities (inspectors) are trained and qualified in accordance with a program that meets theapplicable requirements of NQA-1–1994, Basic Requirement 2, Supplement 2S-1, and Appendix2A-1. The following alternatives may be applied to the qualification requirements:

(1) In lieu of being certified as Level I, II, or III in accordance with NQA-1-1994, personnelperforming operations phase independent quality verification inspections, examinations,measurements, or tests of material, products, or activities will be required to possessqualifications equal to or better than those required for performing the task beingverified; and the verification is within the skills of these personnel and/or is addressed byprocedures. These individuals will not be responsible for the planning of qualityverification inspections and tests (i.e., establishing hold points and acceptance criteria inprocedures, and determining who will be responsible for performing the inspections),evaluating inspection training programs, nor certifying inspection personnel.

(2) A qualified engineer may be used to plan inspections, evaluate the capabilities of aninspector, or evaluate the training program for inspectors. For the purposes of thesefunctions, a qualified engineer is one who has a baccalaureate in engineering in adiscipline related to the inspection activity (such as, electrical, mechanical, civil) and hasa minimum of five years engineering work experience with at least two years of thisexperience related to nuclear facilities.

2.5.6 Non-Destructive Examination Technicians

Personnel performing NDE are trained and qualified in accordance with a program that meets theapplicable requirements of NQA-1–1994, Basic Requirement 2 and Supplement 2S-2 except thatthe reference to SNT-TC-1A, June 1980 is changed to the qualification standard as specified inthe applicable facility’s commitment to the ASME code or other applicable code governing theactivity.



2.5.7 ASME Code Visual Examinations

Personnel performing visual examinations (VT) required by the ASME code are qualified andcertified according to the Code requirements for the applicable facility.

2.6 Control of Activities

The Company has established administrative controls over activities for the nuclear facilities inaccordance with the quality assurance program. These ensure that the applicable elements of10 CFR 50, Appendix B are addressed during the performance of the activities. These programsinclude the appropriate use of qualified personnel, procedures, and methods when performing theactivities. They also address special controls necessary such as environmental conditions,cleanliness, use of special or calibrated equipment, and specific operating modes or conditions.Where appropriate, the controls include specifying acceptance criteria that assure suitableperformance of the SSCs. These controls are further addressed throughout this QAPD and withinthe standards committed to by this QAPD.


The Company is committed to implementing a quality assurance program in accordance with thequality standards described in NQA-1-1994, Basic Requirement 2, its associated Supplements, andAppendix 2A-1 as described above, including alternatives. The Company also commits toimplementing the other standards with alternatives described within Section 2 and those delineated inAppendix C to this QAPD.

3.0 Design Control


The Company has established and implements administrative controls to assure quality isachieved in establishing and changing the design for the nuclear facilities in accordance withindustry standards and regulatory requirements. These provisions address control of designinputs, processes, outputs, changes, interfaces, records, and organizational interfaces. Theadministrative controls designate the design organization that has approval authority for thedesign, including design changes and modifications.

3.2 Design Control Program

The design control program ensures design inputs are correctly translated into specifications,drawings, procedures, and instructions in sufficient detail to permit verification. The designprocess controls the selection and independent verification of items and activities consistent withtheir importance to safety, to ensure that they are suitable for their intended application. Thedesign process includes provisions for performing appropriate reviews by nuclear management,operating and corporate safety review committees, and for required regulatory evaluations.Errors and deficiencies in design, including the design process, that could adversely affect



quality structures, systems, and components are documented and corrective action is taken inaccordance with Sections 15 and 16 of this QAPD.

3.2.1 Design Change Control

Procedures and instructions govern identifying the need to change the design and a documentedmethod to control these changes. Design and specification changes are subject to design controlmeasures commensurate with those applied during the original design as amended by applicabledesign or licensing basis changes. The design change process includes notifications of changes toresponsible plant personnel prior to implementation in accordance with applicable procedures.

3.2.2 Design Interface Control

Procedures and instructions establish interface controls between functional groups and withprincipal Suppliers. The interface controls include processes for the resolution of designquestions related to the nuclear facilities.

3.2.3 Design Verification

The design control program establishes and implements design verification procedures andinstructions to ensure that an appropriate verification method (including, but not limited to,design reviews, alternate calculations, and qualification testing) is used, the appropriate designparameters are chosen, the acceptance criteria are identified, the verification is satisfactorilyaccomplished, and the results are properly recorded. Measures are included that assure theindependence of individuals performing design verification. The Company is responsible forassuring that the design documents generated by Suppliers for the Company’s nuclear facilitiesare technically correct, approved, and maintained.

3.2.4 Software Design and Control

The Company has established programs and procedures to ensure that computer software isappropriately procured or designed and verified suitable for the intended application. Measuresare also taken to control the use of software.


The Company commits to meeting the standards for design control of NQA-1–1994, BasicRequirement 3 and Supplement 3S-1, and the standards for computer software contained inSubpart 2.7.

4.0 Procurement Document Control


The Company has established and implements administrative controls and processes to assurethat applicable regulatory, technical, and QA program requirements are included or referenced in



procurement documents. These measures ensure procurement documents identify applicableregulatory, technical, administrative, and reporting requirements (such as specifications, codes,standards, tests, inspections, special processes, and 10 CFR Part 21); drawings; specifications;codes and industrial standards; test and inspection requirements; and special process instructionsthat must be complied with by Suppliers. Procedures further define when procurementdocuments require Suppliers and subtier Suppliers to provide acceptable quality assuranceprograms.

4.2 Preparation, Review, and Approval of Procurement Documents

Established procedures and instructions describe organizational responsibilities that include:procurement planning; the preparation, review, approval, and control of procurement documents;Supplier selection; bid evaluations and review and concurrence of Supplier QA programs prior toinitiation of activities affected by the program. Procedures ensure procurement documents arereviewed to verify that quality requirements are: (1) correctly stated, inspectable, andcontrollable; (2) have adequate acceptance and rejection criteria; and (3) are prepared, reviewed,and approved in accordance with this QAPD. These procedures also identify those personnelauthorized to perform the reviews and their qualification requirements including training in QApractices and concepts. The Company performs applicable internal and external audits,assessments, and inspections to ensure compliance with quality assurance program requirementsfor the control of procurement documents.


The Company commits to meeting the quality assurance standards for procurement documentcontrol of NQA-1–1994, Basic Requirement 4 and Supplement 4S-1.

5.0 Instructions, Procedures, and Drawings


The Company has established and implements administrative controls to assure that activitiesaffecting quality are prescribed by and performed in accordance with documented instructions,procedures, and drawings. Provisions include the preparation, review, approval, control anddistribution of procedures, instructions and drawings for activities affecting quality structures,systems, and components of Company nuclear facilities. These documents are controlled inaccordance with Section 6 of this QAPD.

Instructions, procedures, and drawings are prepared and approved prior to implementation. Thesedocuments are sufficiently detailed to allow a qualified individual to perform the requiredfunction without direct supervision, and assure consistent and acceptable results in accordancewith regulatory guidance and industry quality standards. Management responsible for eachfunctional group has responsibility for assuring that their activities affecting quality are(1) prescribed by documented instructions, procedures, and drawings and (2) accomplishedthrough implementation of these documents.



5.2 Procedure Adherence

The Company policy is that procedures are followed, and the requirements for use of procedureshave been established in administrative procedures. Where procedures cannot be followed aswritten, provisions are established for making changes in accordance with Section 6 of thisQAPD. Requirements are established to identify the manner in which procedures are to beimplemented, including identification of those tasks that require (1) the written procedure to bepresent and followed step-by-step while the task is being performed, (2) the user to havecommitted the procedure steps to memory, (3) verification of completion of significant steps, byinitials or signatures or use of check-off lists. Procedures that are required to be present andreferred to directly are those developed for extensive or complex jobs where reliance on memorycannot be trusted, tasks that are infrequently performed, and tasks where steps must beperformed in a specified sequence.

5.3 Procedure Content.

This QAPD does not establish any specific format or style for procedures, this information willbe contained in the administrative controls applicable to the facility. The format of proceduresmay vary based on the applicable facility or the tasks being performed. Where appropriate,checklists (check-off lists) are used with the procedures to ensure accurate completion.Procedures include the applicable elements described in NQA-1-1994, Part II, Introduction,Section 4.2, (a)-(p), and the following additional elements, where appropriate:

Title. Each procedure contains a title descriptive of the work or system or unit to which itapplies, a revision number or date, and an approval status.

Statement of Applicability/Purpose. When the procedure’s purpose is not clear from the title,a separate statement of applicability is provided.

Limitations and Actions. Limitations on the parameters being controlled and appropriatecorrective measures to return the parameter to the normal control band are specified.Limitations and setpoints may be identified in a separate section. Where appropriate,quantitative control guides are provided.

5.4 Types of Procedures and Instructions

The types of procedures and instructions to be developed and used will vary according to thephase that a facility is in as well as the type of facility and activities conducted. This subsectionis intended to provide an overview of these types, but is not intended to specify any particularname or format for these documents and some types may be combined. Certain types ofprocedures and instructions are common to all facilities, but individual facility terminology mayvary. The Company programs ensure that the applicable types of procedures described inRegulatory Guide 1.33, Rev. 2, Appendix A, are developed, maintained, and implemented for thenuclear facilities in the operational phase.

Administrative Controls. These include administrative procedures, directives, policies,standards, and similar documents that control the programmatic aspects of facility activities.



These administrative documents ensure that the requirements of regulatory and licensecommitments are implemented. Several levels of administrative controls are applied rangingfrom those affecting the entire Company down to those prepared at the implementing grouplevel. These documents establish responsibilities, interfaces, and standard methods (rules ofpractice) for implementing programs. In addition to the administrative controls describedthroughout this QAPD, instructions governing the following activities are provided:

(1) Operating Orders/Procedures. Instructions of general and continuing applicability to theconduct of business to the plant staff are provided. Examples where these are appliedinclude, but are not limited to, job turnover and relief, designation of confines of controlroom, definition of duties of operators and others, transmittal of operating data tomanagement, filing of charts, limitations on access to certain areas and equipment,shipping and receiving instructions. Provisions are made for periodic review and updatingof these documents, where appropriate.

(2) Special Orders. Management instructions, which have short-term applicability andrequire dissemination, are issued to encompass special operations, housekeeping, datataking, publications and their distribution, plotting process parameters, personnel actions,or other similar matters. Provisions are made for periodic review, updating, andcancellation of these documents, where appropriate.

(3) Plant Security and Visitor Control. Procedures or instructions are developed tosupplement features and physical barriers designed to control access to the plant and, asappropriate, to vital areas within the plant. Information concerning specific designfeatures and administrative provisions of the plant security program is confidential andthus accorded limited distribution. The security and visitor control procedures consider,for example, physical provisions, such as: fences and lighting; lock controls for doors,gates and compartments containing sensitive equipment; and provisions for traffic andaccess control. Administrative provisions, such as: visitor sign-in and sign-outprocedures; escorts and badges for visitors; emphasis on inspection, observation andchallenging of strangers by operating crews; and a program of pre-employment screeningfor potential employees are also considered.

(4) Temporary Procedures. Temporary procedures may be used to direct operations duringtesting, refueling, maintenance, and modifications to provide guidance in unusualsituations not within the scope of the normal procedures. These procedures ensure orderlyand uniform operations for short periods when the plant, a system, or a component of asystem is performing in a manner not covered by existing detailed procedures or has beenmodified or extended in such a manner that portions of existing procedures do not apply.Temporary Procedures include designation of the period of time during which they maybe used and are subject to the procedure review process as applicable.

Engineering Procedures. These documents provide instructions for the preparation ofengineering documents and implementation of engineering programs. This includes activitiessuch as preliminary and final designs; calculations; fabrication, purchasing, construction, andinstallation specifications; drawings; analysis and topical reports; and testing plans or



procedures. They include appropriate reference to industry codes and standards, design inputs,and technical requirements.

Installation Procedures. These documents provide instructions for the installation ofcomponents generally related to new construction and certain modification activities. Theyinclude appropriate reference to industry standards, installation specifications, design drawings,and Supplier and technical manuals for the performance of activities. These documents includeprovisions, such as hold or witness points, for conducting and recording results of requiredinspections or tests. These documents may include applicable inspection and test instructionssubject to the requirements for test and inspection procedures below.

System Procedures. These documents contain instructions for energizing, filling, venting,draining, starting up, shutting down, changing modes of operation, and other instructionsappropriate for operations of systems related to the safety of the plant. Separate procedures maybe developed for correcting off-normal conditions for those events where system complexitymay lead to operator uncertainty.

Start-up Procedures. These documents contain instructions for starting the reactor from cold orhot conditions and establishing power operation. This includes documented determination thatprerequisites have been met, including confirmation that necessary instruments are operable andproperly set; valves are properly aligned, necessary system procedures, tests and calibrationshave been completed; and required approvals have been obtained.

Shutdown Procedures. These documents contain guidance for operations during controlledshutdown and following reactor trips, including instructions for establishing or maintaining hotshutdown/standby or cold shutdown conditions, as applicable. The major steps involved inshutting down the plant are specified, including instructions for such actions as monitoring andcontrolling reactivity, load reduction and cooldown rates, sequence for activating or deactivatingequipment, requirements for prompt analysis for causes of reactor trips or abnormal conditionsrequiring unplanned controlled shutdowns, and provisions for decay heat removal.

Power Operation and Load Changing Procedures. These documents contain instructions forsteady-state power operation and load changing. These type documents include, as examples,provisions for use of control rods, chemical shim, coolant flow control, or any other systemavailable for short- or long-term control of reactivity, making deliberate load changes,responding to unanticipated load changes, and adjusting operating parameters.

Process Monitoring Procedures. These documents contain instructions for monitoringperformance of plant systems to assure that core thermal margins and coolant quality aremaintained in acceptable status at all times, that integrity of fission product barriers ismaintained, and that engineered safety features and emergency equipment are in a state ofreadiness to keep the plant in a safe condition if needed. Maximum and minimum limits forprocess parameters are appropriately identified. Operating procedures address the appropriatenature and frequency of this monitoring.



Fuel Handling Procedures. These documents contain instructions for core alterations,accountability of fuel and partial or complete refueling operations that include, for example,continuous monitoring of neutron flux throughout core loading, periodic data recording, audibleannunciation of abnormal flux increases, and evaluation of core neutron multiplication to verifysafety of loading increments. Procedures are also provided for receipt and inspection of new fuel,and for fuel movements in the spent fuel storage areas. Fuel handling procedures includeprerequisites to verify the status of systems required for fuel handling and movement; inspectionof replacement fuel and control rods; designation of proper tools, proper conditions for spent fuelmovement, proper conditions for fuel cask loading and movement; and status of interlocks,reactor trip circuits and mode switches. These procedures provide requirements for refueling,including proper sequence, orientation and seating of fuel and components, rules for minimumoperable instrumentation, actions for response to fuel damage, verification of shutdown margin,communications between the control room and the fuel handling station, independent verificationof fuel and component locations, criteria for stopping fuel movements, and documentation offinal fuel and component serial numbers (or other unique identifiers) and locations.

Maintenance Procedures. These documents contain instructions in sufficient detail to permitmaintenance work to be performed correctly and safely, and include provisions, such as hold orwitness points, for conducting and recording results of required inspections or tests. Thesedocuments may include applicable inspection or test instructions subject to the requirements fortest and inspection procedures below. Appropriate referencing to other procedures, standards,specifications, or Supplier manuals is provided. When not provided through other documents,instructions for equipment removal and return to service, and applicable radiation protectionmeasures (such as protective clothing and radiation monitoring) will be included. Additionalmaintenance procedure requirements are addressed in NQA-1-1994, Subpart 2.18, Section 2.2,Procedures.

Radiation Control Procedures. These documents contain instructions for implementation of theradiation control program requirements necessary to meet regulatory commitments, includingacquisition of data and use of equipment to perform necessary radiation surveys, measurementsand evaluations for the assessment and control of radiation hazards. These procedures providerequirements for monitoring both external and internal exposures of employees, utilizingaccepted techniques; routine radiation surveys of work areas; environmental monitoring in thevicinity of the plant; radiation monitoring of maintenance and special work activities, and formaintaining records demonstrating the adequacy of measures taken to control radiationexposures to employees and others.

Calibration and Test Procedures. These documents contain instructions for periodiccalibration and testing of instrumentation and control systems, and for periodic calibration ofmeasuring and test equipment used in activities affecting the quality of these systems. Thesedocuments provide for meeting surveillance requirements and for assuring measurementaccuracy adequate to keep safety-related parameters within operational and safety limits.

Chemical and Radiochemical Control Procedures. These documents contain instructions forchemical and radiochemical control activities and include: the nature and frequency of samplingand analyses; instructions for maintaining coolant quality within prescribed limits; and



limitations on concentrations of agents that could cause corrosive attack, foul heat transfersurfaces, or become sources of radiation hazards due to activation. These documents also providefor the control, treatment and management of radioactive wastes, and control of radioactivecalibration sources.

Emergency Operating Procedures. These documents contain instructions for response topotential emergencies so that a trained operator will know in advance the expected course ofevents that will identify an emergency and the immediate actions that should be taken inresponse. Format and content of emergency procedures are based on regulatory and Owner’sGroup(s) guidance that identify potential emergency conditions and generally require suchprocedures to include a title, symptoms to aid in identification of the nature of the emergency,automatic actions to be expected from protective systems, immediate operator actions foroperation of controls or confirmation of automatic actions, and subsequent operator actions toreturn the reactor to a normal condition or provide for a safe extended shutdown period underabnormal or emergency conditions.

Emergency Plan Implementing Procedures. These documents contain instructions foractivating the Emergency Response Organization and facilities, protective action levels,organizing emergency response actions, establishing necessary communications with local, stateand federal agencies, and for periodically testing the procedures, communications and alarmsystems to assure they function properly. Format and content of such procedures are such thatrequirements of each facility’s NRC approved Emergency Plan are met.

Test and Inspection Procedures. These documents provide the necessary measures to assurequality is achieved and maintained for the nuclear facilities. The instructions for tests andinspections may be included within other procedures, such as installation and maintenanceprocedures, but will contain the objectives, acceptance criteria, prerequisites for performing thetest or inspection, limiting conditions, and appropriate instructions for performing the test orinspection, as applicable. These procedures also specify any special equipment or calibrationsrequired to conduct the test or inspection and provide for appropriate documentation andevaluation by responsible authority to assure test or inspection requirements have been satisfied.Where necessary, hold or witness points are identified within the procedures and requireappropriate approval for the work to continue beyond the designated point. These proceduresprovide for recording the date, identification of those performing the test or inspection, as-foundcondition, corrective actions performed (if any), and as-left condition, as appropriate for thesubject test or inspection.


The Company commits to meeting the standards for instructions, procedures, and drawings ofNQA-1–1994, Basic Requirement 5. Additional requirements regarding the content ofprocedures for specific activities delineated in NQA-1–1994, Part II, will also be implemented asappropriate to the activity.



6.0 Document Control


The Company has established and implements administrative controls to assure the review,approval, and issuance of controlled documents and changes thereto. These controls assuretechnical adequacy and inclusion of appropriate quality requirements prior to implementation.Measures are provided to assure that documents, including revisions or changes, are reviewed foradequacy by independent knowledgeable personnel other than those who originated or preparedthe document, approved for release by authorized personnel, and distributed in accordance withcurrent approved methods. In order to ensure that the documents in current use provide the bestpossible instructions for performance of the work involved, reviews and/or feedback ofinformation based on use is provided for within the implementing programs. During constructionand modification activities, drawings and related documentation are updated in a timely mannerto accurately reflect the actual facility design.

6.2 Applicability

The provisions for controlling documents include, but are not limited to, the following types ofdocuments:

(1) Engineering calculations and analyses, design and as-built drawings, design andinstallation specifications, computer codes

(2) Purchase orders and related documents, Supplier provided documents(3) Instructions, procedures, and drawings used for activities such as siting, designing,

procuring, fabricating, handling, shipping, receiving, storing, cleaning, erecting,installing, inspecting, testing, operating, maintaining, calibrating, repairing, refueling,responding to emergencies, modifying, and decommissioning (including those documentsdescribing organizational interfaces)

(4) Topical reports, quality assurance and quality control manuals and procedures(5) License documents, Technical Specifications, and Safety Analysis Reports(6) Reports of nonconformance resolution and corrective actions

6.3 Document Review and Approval

Administrative procedures provide measures to control and coordinate the approval and issuanceof documents, including changes thereto, that prescribe all activities affecting quality. Proceduresdescribe the review process and establish who is to perform document reviews and anyapplicable qualification requirements.

Each procedure (including those that are programmatic in nature) is reviewed and approved priorto initial use. The frequency of subsequent reviews varies depending on the frequency of use,type and complexity of the activity involved. Applicable procedures are reviewed following anunusual incident, such as an accident, an unexpected transient, significant operator error, orequipment malfunction; and following any modification to a system.

Installation, maintenance, modification, and inspection procedures include inspectionrequirements, methods, and acceptance criteria according to the established QA inspection



program. When a change is made to any of these inspections, the change is reviewed bypersonnel knowledgeable in QA requirements.

Documents, including procedures, programs and changes thereto are approved by responsiblemanagement or the facility safety review committee, as applicable. Where common proceduresor programs are used for multiple facilities, responsible management or the facility safety reviewcommittee from each facility must approve the procedures or programs.

6.4 Additional Operations and Decommissioning Phase Review Requirements

Procedures and programs, including subsequent changes, for operations and decommissioningphase activities are screened to determine if further regulatory evaluation is required to meet10 CFR Parts 50.59 and 72.48. Procedures and programs that are determined to require furtherregulatory evaluation are reviewed and approved by the facility safety review committee asdescribed in Appendix B, of this QAPD. The facility safety review committee may require anyprocedure, program, or changes thereto to be brought before the committee for review.

Administrative controls ensure periodic reviews are performed for procedures that have specificregulatory review requirements. Additional administrative and programmatic controls ensureprocedures are maintained current. These controls include pre-job preparation practices and theprocedural adherence policy (as discussed in Section 5). In addition, plant procedures are auditedor reviewed as part of routine Nuclear Oversight processes providing assurance that existingadministrative controls for procedure verification, review, and revision are effective in maintainingthe quality of plant procedures.

If a temporary procedure change is required, it will be reviewed and approved in accordance with(1) the applicable facility technical specification requirements, or (2) the provisions of thisQAPD when not addressed in the technical specifications. Such changes are documented and, ifappropriate, incorporated in the next revision of the affected procedure.

6.5 Distribution of Controlled Documents

Provisions ensure current documents are available prior to commencing work. Computerizedprocesses may be used to make controlled documents available to users. Where computerizeddistribution is made, administrative controls ensure that the record file for the document containsthe appropriate review and approval documentation.

Administrative controls are established to assure the timely removal and replacement of obsoleteor superseded documents in work areas with applicable revisions. The Company maintains arecord of all holders of controlled documents and drawings. An index or file of all controlleddocuments that lists the current revision or date is maintained so personnel can readily identifythe current revision.


The Company commits to meeting the quality assurance standards for document control ofNQA-1–1994, Basic Requirement 6 and Supplement 6S-1.



7.0 Control of Purchased Material, Equipment, and Services


The Company has established and implements programs, procedures, and processes for thecontrol of purchased items and services, selection of Suppliers, and assessing the acceptability ofquality. The Company procedures define the organizational responsibilities for the control ofpurchased items and services including interfaces between design, procurement, and qualityverification organizations.

7.2 Selection of Suppliers

Procedures describe the Supplier selection process, including measures to ensure continuedacceptable quality from Suppliers. Prospective Suppliers are evaluated based on the items andservices they provide and the degree of quality required. The evaluation process ensures onlyqualified Suppliers are selected. The Suppliers are periodically evaluated to ensure they continueto provide acceptable products and services. A controlled list of qualified Suppliers is maintainedby Nuclear Oversight and made available to the organizations responsible for procuring itemsand services. Audits, surveillances, inspections, and NRC correspondence used in the evaluationof Suppliers are specifically identified in the evaluation documentation to allow retrieval of theinformation.

7.3 Conformance of Items and Services

Procurement documents identify to the Supplier applicable technical, regulatory, administrative,and reporting requirements. These requirements include specifications, codes, standards, tests,inspections, special processes, reporting in accordance with 10 CFR 21, documentation thatidentifies the purchased item and the specific procurement requirements met by the item,documentation identifying any procurement requirements that have not been met, and adescription of those nonconformances from the procurement requirements dispositioned acceptas-is or repair. The procurement documents identify the technical and quality requirements basedon the intended service and the requirements of the current Company QAPD in effect at the timeof procurement. These requirements also apply to the procurement of spare and replacementparts such that the specifying of technical requirements is equal to or better than the originalrequirements to preclude repetition of defects. For commercial grade (off-the-shelf) items,special quality verification requirements are established and described in Company documents toprovide the necessary assurance an item will perform satisfactorily in service. The Companydocuments address determining the critical characteristics that ensure an item is suitable for itsintended use, technical evaluation of the item, receipt requirements, and quality evaluation of theitem.

7.4 Quality Verification

Nuclear Oversight, Nuclear Analysis and Fuel, and Supply Chain Management use a systematicapproach through audits, independent inspections, surveillances, or tests to verify Supplierquality. Personnel from these groups verify Suppliers’ activities during fabrication, inspection,testing, and shipment of items. Suppliers’ certificates of conformance are periodically evaluated



to assure they are valid. Additional quality verifications are performed to assure conformancewith purchase requirements during receipt inspection, or through pre-installation orpost-installation tests. Prior to items being placed in service or used at Company nuclearfacilities, responsible inspection personnel verify that required Supplier documentary evidencethat the items conform to purchase requirements is available on site. These verification activitiesare planned, performed, and documented in accordance with written Company documents. TheCompany documents identify: (1) the characteristics or processes to be witnessed, inspected,verified, evaluated, and accepted; (2) the method of verification; (3) at what interval in thefabrication or manufacture to perform verification; (4) the extent of documentation required; and(5) those responsible for implementing these verification activities.


The Company commits to meeting the quality assurance standards for control of purchasedmaterial, equipment, and services contained in NQA-1–1994, Basic Requirement 7, andSupplement 7S-1, with the exception of Section 10, “Commercial Grade Items.” Controls forcommercial grade items are established in Company documents using the guidance of EPRINP-5652 as discussed in GL 89-02.

8.0 Identification and Control of Materials, Parts, and Components


The Company has established and implements administrative controls and processes for theidentification and control of items such as materials (including consumables), parts, components,and partially fabricated subassemblies. Implementing procedures establish the responsibilitiesand requirements for the identification and control of items throughout fabrication, receipt,handling, storage, and installation to assure that incorrect or defective items are not used. Suchrequirements include instruction on the use of markings, tags, labels, or record keeping foridentification so that the items are not adversely affected by the method of identification.

The methods used for identification of items assure traceability of the items to the appropriatedocumentation such as drawings, specifications, purchase orders, manufacturing and inspectiondocuments, problem reports, and physical and chemical mill test reports. Procedures includeresponsibilities and methods for verification and documentation of the correct identification ofitems prior to release for fabrication, assembling, shipping, and installation.


The Company commits to meeting the quality assurance standards for identification and controlof items contained in NQA-1–1994, Basic Requirement 8 and Supplement 8S-1.



9.0 Control of Special Processes


The Company has established and implements programs, procedures, and processes to assure theacceptability of special processes through the use of procedures, technique sheets, travelers andinspection verification reports, and personnel qualified in accordance with the applicable codes,specifications, and standards for the specific work. Special processes are those where interimprocess controls (such as using qualified procedures and personnel, or interim inspections ortests) are necessary to ensure a final acceptable product and where reliance on a final inspectionor test is insufficient to determine quality. Special processes include, but are not limited to, thoseinvolving: welding; heat treating; cadwelding; non-destructive examination and testing; paintingand coatings; concrete and grout; soils and earthwork; and removal of undesirable substancesduring shop and site cleaning, degreasing, and flushing. In instances where Suppliers areassigned such work at Company facilities, the Supplier must submit their procedures andpersonnel qualifications to the Company for approval prior to the start of work.

9.2 Qualification of Special Processes Personnel, Procedures and Equipment

Company documents assure that procedures, equipment, and personnel associated with specialprocesses are qualified and are in conformance with applicable codes, standards, QA procedures,and specifications. In addition, Company documents establish the method for recording evidenceof the acceptable accomplishment for special processes. The Company conducts inspectionsand/or audits of work involving special processes to assure that procedures and personnel areproperly qualified and their workmanship is in compliance with applicable specifications, codes,standards, and QA procedures.

Qualification records of procedures, equipment, and personnel associated with special processesare established, filed, and kept current in accordance with the provisions of this QAPD.


The Company commits to meeting the standards for control of special processes fromNQA-1-1994, Basic Requirement 9 and Supplement 9S-1.

10.0 Inspection


The Company has established and implements administrative controls and processes to inspectactivities for the nuclear facilities that affect quality to verify conformance with the approveddocuments for accomplishing the activities including specifications and quality standards. Theprograms govern establishment of inspection hold points beyond which work is not to continueuntil a satisfactory inspection is achieved. The inspections are performed by trained and qualifiedindividuals, in accordance with controlled documents, and to established acceptance criteria. Theinspection program maintains reporting independence of inspectors by ensuring individuals



performing the inspections are not the same individuals or supervisors responsible forperforming the activity being inspected. Where quality verification inspections at operatingfacilities are performed by the Maintenance group, to meet the independence requirements ofNQA-1, Supplement 10S-1, Section 3.1, the inspectors report to the Facility Safety andLicensing organization while performing the inspection. Management review and audit ofinspection results is established to ensure effectiveness of the inspection program.

10.2 Inspection Program

The inspection program establishes inspections (including surveillance of processes), asapplicable: (1) at the source of supplied items or services, (2) in-process during fabrication at aSupplier’s facility or at a Company facility, (3) for final acceptance of fabricated and/or installeditems during construction, (4) upon receipt of items for a facility, as well as (5) duringmaintenance, modification, inservice, operating and decommissioning activities. The post-maintenance testing program ensures that a functional test can be performed as additionalassurance demonstrating the quality of work where inspections for breach of a pressure boundaryare performed by an individual within the same functional group (e.g., Maintenance).

The inspection program establishes requirements for planning inspections, such as the group ordiscipline responsible for performing the inspection, where inspection hold points are to beapplied, determining applicable acceptance criteria, the frequency of inspection to be applied,and identification of special tools needed to perform the inspection. Inspection planning isperformed by personnel qualified in the discipline related to the inspection and include qualifiedinspectors or engineers. Inspection plans are based on, as a minimum, the importance of the itemto the safety of the facility, the complexity of the item, technical requirements to be met, anddesign specifications. Where significant changes in inspection activities for the facilities are tooccur, management responsible for the inspection programs evaluate the resource and planningrequirements to ensure effective implementation of the inspection program.

Inspection program documents establish requirements for performing the planned inspections,and documenting required inspection information such as: reject, acceptance, and reinspectionresults; and the person(s) performing the inspection.

10.3 Inspector Qualification

The Company has established qualification programs for personnel performing qualityverification inspections. The qualification program requirements are described in Section 2 ofthis QAPD. These qualification programs are applied to individuals performing qualityverification inspections regardless of the functional group where they are assigned. Whereinspections are to be performed by individuals within the same functional group, an independentaudit of the qualification criteria for inspection personnel will be performed prior toimplementing such an inspection program.


The Company commits to meeting the programmatic standards for Inspection of NQA-1–1994,Basic Requirement 10, and Supplement 10S-1 with the alternative regarding independence of



Maintenance group inspectors stated above. The inspection programs will also incorporate theappropriate inspection requirements described in Part II, “Quality Assurance Requirements forNuclear Facility Applications,” of NQA-1–1994. Regarding Subpart 2.4 (ANSI/IEEE Std. 336-1985) and Subpart 2.18 invoked by NQA-1–1994, Part II, any and all references to ANSI/ASMENQA-1, ANSI/ASME NQA-2, and ANSI/ANS-3.2 are changed to mean the appropriaterequirements of NQA-1–1994 and this QAPD.

11.0 Test Control


The Company has established and implements programs, procedures, and processes to controltests that assure the nuclear facility structures, systems, and components (items) functionsatisfactorily in service. The test control programs identify (1) the items to be tested, (2) methodsof testing, (3) documentation, and (4) evaluation of test results. The tests are systematic andinclude, as necessary, proof tests prior to installation, construction tests, preoperational tests,production tests, operational tests, surveillance and inservice tests, and tests following repairs,rework, replacement, preventive maintenance, or modification.

Tests during the preoperational period are conducted to demonstrate that performance of facilitysystems is in accordance with design intent and that the coordinated operation of the facility as awhole is satisfactory, to the extent feasible. Tests during the initial operational phase areconducted to demonstrate the performance of systems that could not be tested prior to operationand to confirm those physical parameters, hydraulic or mechanical characteristics that need to beknown, but which could not be predicted with the required accuracy, and to confirm thatbehavior conforms to design criteria. The preoperational testing program will demonstrate, asnearly as can be practicably simulated, the overall integrated operation of the plant systems atrated conditions, including simultaneous operation of auxiliary systems. It may be necessary todefer portions of these tests until nuclear heat is available.

The initial start-up test program is planned and scheduled to permit safe fuel loading andstart-up; to increase power in safe increments; and to perform major testing at specified powerlevels. If tests require the variation of operating parameters outside of their normal range, thelimits within which such variation is permitted will be prescribed. The scope of the testingdemonstrates, insofar as practicable, that the plant is capable of withstanding the designtransients and accidents. For new facility construction, the suitability of facility operatingprocedures is checked to the maximum extent possible during the preoperational and initialstart-up test programs.

The tests are performed and results documented in accordance with applicable technical andregulatory requirements including those described in the nuclear facility Technical Specificationsand SAR. The test programs ensure appropriate retention of test data in accordance with therecords requirements of this QAPD. The personnel performing or evaluating tests are qualified inaccordance with the requirements established in Section 2 of this QAPD.



11.2 Test Procedures

Tests are conducted in accordance with approved written procedures or instructions that arebased on the applicable design requirements for the structures, systems, and components beingtested. Section 5 of this QAPD describes the requirements for test procedures. The proceduresinclude prerequisites and instructions for performing the test that ensure the item is ready fortesting, appropriate test equipment with suitable accuracy is used, and any necessary controlledenvironmental conditions are established and maintained. The prerequisites are completed priorto commencement of the test or portion of the test where they are applicable. Test proceduresalso identify acceptance criteria, any required inspection hold or witness points, and provisionsfor documenting test performance data and review of test results by appropriate management.When acceptance criteria are not met, provisions are made for retest of corrected areas.

11.3 Evaluation of Test Results

The test control programs contain measures for a qualified individual or group to evaluate testresults against predetermined acceptance criteria. The acceptance status of the test isdocumented. Any deficiencies identified by the tests are documented and dispositioned inaccordance with procedures.

11.4 Scheduling

Scheduling or similar measures are used to ensure that appropriate tests are performed andevaluated on a timely basis so that the safety of the plant is never dependent on the performanceof an untested system. Preoperational tests, including start-up tests following fuel loading, aregenerally performed sequentially to demonstrate functional adequacy and are scheduled to beperformed at the time when plant conditions are appropriate for the test. Surveillance testing andinspections for operating facilities (and required operating items of facilities beingdecommissioned) are scheduled at prescribed intervals to ensure that items important to safetywill continue to operate, keeping parameters within normal bounds, or will act to put the plant ina safe condition if they exceed normal bounds. These intervals are established in facilitytechnical documents.


The Company commits to meeting the programmatic standards for Test Control of NQA-1–1994, Basic Requirement 11, Supplement 11S-1, and Supplement 11S-2, along with thesurveillance and testing requirements described in Part II, “Quality Assurance Requirements forNuclear Facility Applications,” of NQA-1–1994. Regarding Subpart 2.4 (ANSI/IEEE Std. 336-1985) invoked by NQA-1–1994, Part II, any and all references to ANSI/ASME NQA-1,ANSI/ASME NQA-2, and ANSI/ANS-3.2 are changed to mean the appropriate requirements ofNQA-1–1994 and this QAPD.



12.0 Control of Measuring and Test Equipment


The Company has established and implements administrative controls and processes for thecalibration, maintenance, and use of measuring and test equipment (including instruments, tools,gauges, fixtures, reference and transfer standards, and non-destructive test equipment). Thesecontrols are applicable to those items used in the measurement, inspection, maintenance, andmonitoring of structures, systems, and components important to safety. The measuring and testequipment (M&TE) does not include: measuring equipment used for preliminary checks orutility troubleshooting where accuracy is not required, nor rulers, tape measures, levels, andother basic tools where normal commercial practices provide adequate accuracy. Controls forM&TE include selection of equipment; establishing and implementing calibration requirements;documentation and/or markings to trace equipment usage, calibration, and calibration status;handling and storage to maintain accuracy; and measures to address nonconforming or deviatingconditions including evaluation, disposition, and retest where indicated.

12.2 Installed Instrument and Control Devices

For the operations phase of the facilities, the Company has established and implementsprocedures for the calibration and adjustment of instrument and control devices installed in thefacility. The calibration and adjustment of these devices is accomplished through the facilitymaintenance programs to ensure the facility is operated within design and technicalrequirements. Appropriate documentation will be maintained for these devices to indicate thecontrol status, when the next calibration is due, and identify any limitations on use of the device.


The Company commits to meeting the standards for Control of Measuring and Test Equipmentof NQA-1–1994, Basic Requirement 12, Supplement 12S-1, and Subpart 2.16 with the followingalternatives:

(1) All references to ANSI/ASME NQA-1, ANSI/ASME NQA-2, and ANSI/ANS-3.2 arechanged to indicate the appropriate Sections of ANSI/ASME NQA-1–1994 and thisQAPD.

(2) Instrumentation and control devices installed in operating facilities are not required to belabeled as described in Subpart 2.16, subsection 5.5 (ANSI/IEEE Std 498-1985),provided the information is maintained in suitable documentation traceable to the device.This alternative also applies to the calibration labeling requirement of Subpart 2.4,subsection 7.2.1 (ANSI/IEEE Std 336-1985).

13.0 Handling, Storage, and Shipping


The Company has established and implements programs, procedures, and processes to controlhandling, storage, shipping, cleaning, packaging, and preservation of items. The programs



delineate controls to prevent damage, loss, and deterioration by environmental conditions (suchas temperature or humidity) of material and equipment received for the nuclear facility. Theprograms also describe the measures taken, including control of shelf life, for the storage ofchemicals, reagents, lubricants, and other consumable materials. Suitable procedures,instructions, and procurement documents are used to define the requirements, training, andresponsibilities for implementing the programs. The established requirements are consistent withthe regulatory positions of the NRC regulatory guides and their related standards listed inAppendix C, or specifications and/or Supplier technical manuals, including special toolutilization and use, operator experience and training, and appropriate marking and labeling.

13.2 Special Handling, Storage, Shipping, Cleaning and Preservation Requirements

Special or additional handling, storage, shipping, cleaning and preservation requirements areidentified and implemented as specified in procurement documents and applicable procedures.Where special requirements are specified, the items and containers (where used) are suitablymarked.


The Company commits to meeting the standards for handling, storage, and shipping ofNQA-1-1994, Basic Requirement 13, Supplement 13S-1, Subpart 2.2, and Subpart 2.15 with thefollowing alternatives:

Regarding Subpart 2.2(1) For items in storage, as determined by facility management the packaging

requirements described under Section 3, “Packaging,” may include alternate methodsof affording the required protection such as maintaining a storage atmosphere freefrom harmful contaminants in concentrations that could produce damage to the storeditems, or utilizing storage practices that obviate the need for capping all openings.

(2) For items in storage at Company facilities, the items and the outside of containers(when present) need to meet the appropriate criteria of subsection 3.9, “Marking,”necessary to ensure the identity of the item, and proper instructions for preservationduring storage and future handling are retained.

(3) Regarding maintenance of items in storage in accordance with subsection 6.4.2, “Careof Items”: the requirement of item (f) will not apply to rotating electrical equipmentless than 50 HP, the requirement of item (g) will not apply to rotating equipmentweighing less than 50 pounds, the requirements of (e), (f), and (g) may be exemptedfor specific items on a case-by-case basis provided that a documented engineeringevaluation determines that such care is not required.

(4) Subsection 6.6, “Storage Records,” requires written records be prepared containinginformation on personnel access. As an alternative to this requirement, Companydocuments establish controls for storage areas that describe those authorized to accessareas and the requirements for recording access of personnel. However, these recordsof access are not considered quality records and will be retained in accordance withthe administrative controls for the facility.



Regarding Subpart 2.15(1) The Company may choose to not use the specific classification of Categories A, B,

and C, but ensures items to be handled are evaluated and the appropriate range ofcontrols and requirements for the activity are applied consistent with this Subpart.

14.0 Inspection, Test, and Operating Status


The Company has established and implements administrative controls and processes to indicateand document the inspection, test, and operating status of structures, systems, and components toprevent their inadvertent use or the bypassing of inspections and tests. The requirements foridentification of status also apply to nonconforming, inoperative, or malfunctioning structures,systems, and components. Company administrative procedures delineate the requirements,methods, and responsibilities for status identification through the use of stickers, tags andtagging systems, test and inspection records, checklists, or logs. The procedures identify(1) those who are authorized to apply and remove the various status tags, stickers, and otherindicators and (2) the authority to operate the item and/or equipment. The operating status is alsocontrolled through the normal nuclear facility operating procedures.

The administrative procedures also describe the measures taken to control altering the sequenceof required tests, inspections, and other operations. The review and approval for these actions issubject to the same control as taken during the original review and approval of tests, inspections,and other operations.

14.2 Control of Systems and Equipment for Operating Facilities

Permission to release systems and equipment for maintenance or modification is controlled bydesignated operating personnel and documented. Measures, such as installation of tags or locksand releasing stored energy, are used to ensure personnel and equipment safety. When entry intoa closed system is required, the Company has established control measures to prevent entry ofextraneous material and to assure that foreign material is removed before the system is reclosed.

Administrative procedures require the designated operating personnel to verify that the system orequipment can be released and determine the length of time it may be out of service. In makingthis determination, attention is given to the potentially degraded degree of protection where onesubsystem of a redundant safety system is not available for service. Conditions to be consideredin preparing equipment for maintenance include, for example: shutdown margin; method ofemergency core cooling; establishment of a path for decay heat removal; temperature andpressure of the system; valves between work and hazardous material; venting, draining andflushing; entry into closed vessels; hazardous atmospheres; handling hazardous materials; andelectrical hazards.

Where temporary modifications, such as temporary bypass lines, electrical jumpers, liftedelectrical leads, and temporary trip point settings, are necessary, they are controlled inaccordance with approved documents that include requirements for independent verification. A



log, or similar documentation, is maintained of the current status of such temporarymodifications.

When systems or equipment are ready to be returned to service, designated operating personnelcontrol placing the items in service and document its functional acceptability. Attention is givento restoration of normal conditions, such as removal of jumpers or signals used in maintenance ortesting, or actions such as returning valves, breakers or switches to proper start-up or operatingpositions from "test" or "manual" positions. Where necessary, the equipment placed into servicereceives additional surveillance during the run-in period.

Independent verifications, where appropriate, are used to ensure that the necessary measureshave been implemented correctly. The minimum requirements and standards for usingindependent verification are established in Company documents.


The Company is committed to implementing a status control program in accordance with the qualitystandards described in NQA-1-1994, Basic Requirement 14.

15.0 Nonconforming Materials, Parts, or Components


The Company has established and implements administrative controls and processes that assurecontrol of nonconforming items (materials, parts, components), and services (including computercodes) to prevent their inadvertent use or installation in Company nuclear facilities. Documentsdescribe the methods for identification, documentation, segregation, review, disposition, andnotification to affected organizations of nonconforming items or services when the disposition isother than to scrap the items or services. Instructions require that the individual discovering anonconformance identify, describe, and document the nonconformance. Procedures identifyauthorized individuals to review, disposition, and closeout nonconformances. Nonconformancesare corrected or resolved prior to the initiation of the preoperational test of the item.

15.2 Nonconformance Responsibilities

Nonconformances are evaluated for impact on operability of quality structures, systems, andcomponents in accordance with Company procedures to assure that the final condition does notadversely affect safety, operation, or maintenance of the item or service. Nonconforming itemreports dispositioned as use-as-is or repair that involve deviation from design requirements areforwarded to the appropriate engineering organization for review and approval of the disposition.Company documents address the controls established to conditionally release nonconformingitems for use on a risk basis prior to resolution and disposition of the nonconformance, includingmaintaining identification of the item and documenting the basis for such release. Conditionalrelease of nonconforming items for installation requires appropriate senior management approvalfor the facility or construction project. Resolution of nonconformances for purchased services arealso controlled by Company documents.



15.3 Nonconformance Documentation

Company procedures assure that documentation identifies the nonconforming item and describesthe nonconformance, the disposition of the nonconformance, and applicable inspectionrequirements. The documentation requires approval of the disposition by an authorizedindividual. Reworked, repaired, and replacement items are inspected and tested in accordancewith the original inspection and test requirements or approved alternatives.

Nuclear Oversight processes verify that nonconformance dispositions are adequate, analyze forquality trends, and report results to upper management in accordance with applicable Companyprocedures. Any significant trends are reported to upper management in accordance withCompany documents, regulatory requirements, and industry standards.


The Company commits to meeting the standards for control of nonconforming items ofNQA-1-1994, Basic Requirement 15 and Supplement 15S-1.

16.0 Corrective Action


The Company has established and implements corrective action programs, procedures, andprocesses to assure that conditions adverse to quality at Company nuclear facilities are promptlyidentified and corrected. Company management at all levels fosters a no-fault attitude toward theidentification of problems. Verification of the proper implementation of corrective actionmeasures and close-out of corrective action documentation is assured through the monitoringeffort of facility personnel and Nuclear Oversight processes.

16.2 Corrective Action Documentation

Company procedures assure that corrective action is documented and initiated following thedetermination of a condition adverse to quality (such as a nonconformance, failure, malfunction,deficiency, deviation, and defective material and equipment) in accordance with regulatoryguidance and industry quality standards. When complex issues arise where it cannot be readilydetermined if a condition adverse to quality exists, Company documents establish therequirements for documentation and timely evaluation of the issue.

In the case of significant conditions adverse to quality, the cause of the condition is determinedand corrective action taken to preclude repetition. For these significant conditions, the cause ofthe conditions, and the corrective action taken to preclude repetition are documented andreported to immediate management and upper levels of responsible management for review andassessment.



16.3 Follow-up

Company corrective action procedures describe the methods for follow-up action to verify properimplementation of corrective action and ensure that the corrective actions are closed out in atimely manner, and include follow-up through Nuclear Oversight processes. Independent reviewof corrective action is conducted in accordance with the requirements of Appendix B of thisQAPD.


The Company commits to meeting the standards for corrective action of NQA-1-1994, BasicRequirement 16.

17.0 Quality Assurance Records


The Company has established and implements administrative controls and processes to ensuresufficient records of items and activities for the nuclear facilities that reflect completed work aregenerated, identified, retained, maintained, and retrievable. Company programs and proceduresidentify specific records, their retention periods, and storage methods.

17.2 Records of Activities

Company documents ensure that records of activities for design, engineering, procurement,manufacturing, construction, inspection and test, installation, preoperation, startup, operations,maintenance, modification, decommissioning, and audits include the appropriate contentrequirements of NQA-1–1994, Parts I and II. The records and their retention times are based onRegulatory Position C.2, Table 1, of NRC Regulatory Guide 1.28, Revision 3. This tableaddresses design, construction and initial start-up records and will be applied to operating anddecommissioning phase records that are similar in nature to the construction records. Additionaloperations phase records and their retention periods are identified in Appendix E to this QAPD.Where State, local or other agencies have more restrictive requirements, those requirements willbe met.

17.3 Record Storage

Implementing procedures assure that identification and retrievability of records is facilitatedthrough proper indices and an established basic filing system. Records are stored in a manner topreclude deterioration of the item. The Company’s records storage facilities are constructed,located, and secured to provide access control and fire protection measures.

Records stored electronically will follow the guidance given in the Nuclear Information andRecords Management Association (NIRMA) technical guideline, TG-15-1998, Management ofElectronic Records. Information Technology will determine appropriate media based upon dataformat and level of access required. Records originally created in hard-copy form will be



retained in hard copy until such time as electronic versions of these records are created, copied,and verified as legible on two (2) independent copies of an appropriate electronic storage media.File legibility verifications will be completed on all records stored on electronic storage media byeither visually verifying the file legibility or by electronically verifying exact binary file transfer.Periodic documented media inspections to monitor image degradation will be conducted inaccordance with approved procedures that incorporate applicable media manufacturer’srecommendations. Records stored on electronic media will be refreshed or copied onto newmedia and subsequently verified if the projected lifetime of that media does not exceed theretention period of the records stored on that media.

Records originally created in electronic form may be retained in electronic form. Backup copiesof electronic records will be maintained in multiple physically independent electronic locationsuntil such time as images of these records are created, copied, and verified on two (2) copies ofan appropriate electronic storage media. The two copies of electronic storage media will then bestored in separate physical locations. These requirements meet the intent of Generic Letter 88-18,Plant Record Storage on Optical Disks, dated October 20, 1988.


The Company is committed to implementing a quality assurance records program in accordancewith the quality standards described in NQA-1-1994, Basic Requirement 17 and Supplement17S-1. The Company will also meet the NRC Regulatory Position C.2 of Regulatory Guide 1.28,Revision 3, August 1985 except that the reference to ASME NQA-1 will be to the 1994 edition.

18.0 Quality Assurance Audits


The Company has established and implements administrative controls and processes for audits tosystematically verify compliance with and determine the effectiveness of all aspects of the QAprogram for Dominion nuclear facilities. Nuclear Oversight conducts, participates on, or hasperformed for them, audits to ensure comprehensive independent verification and evaluation ofSuppliers, activities, and documents. The audits are performed in accordance with writtenprocedures or checklists and are conducted by appropriately trained personnel having no directresponsibilities in the areas being audited.

An audit schedule is prepared to identify the planned and periodic audits to be performed, theirfrequencies, and dates for performance. Audits are scheduled based upon the status and safetyimportance of the activities being performed and are initiated early enough to assure effectiveQA during design, construction, operation, and decommissioning. When necessary, thescheduled audits are supplemented with audits of specific subjects to ensure adequate coverageor reaudit of deficient areas.



18.2 Audit Scope

The audits include an objective evaluation of quality-related practices, procedures, instructions,activities, and items; and review of documents and records. Audits are performed in all areaswhere the requirements of this QAPD are applicable including activities associated withindoctrination and training programs; interface control between the Company and principalSuppliers; corrective action, calibration, and nonconformance control systems; facility SARcommitments; and activities associated with computer codes. For facilities under construction,the audits will also include, as applicable, the determination of site features which affect plantsafety (e.g., core sampling, site and foundation preparation, and methodology) and thepreparation, review, approval, and control of early procurements.

18.3 Audit Responsibilities and Procedures

Audit data is analyzed by the audit team. The results of the analysis are reviewed by NuclearOversight management. Audit reports indicate any quality problems identified, the effectivenessof the QA program elements assessed, and identify the deficiencies that require follow-up ofcorrective actions. The reports are distributed to affected management for review. Managementwith responsibility for the area audited review, investigate, and correct (with a view towardpreventing recurrence) conditions adverse to quality that involve QA program deficiencies.Follow-up of audit findings involving program deficiencies is performed by Nuclear Oversightas necessary to verify appropriate actions have been taken to resolve audit findings.

Items not effectively resolved by assigned management are submitted to the senior managementposition responsible for Nuclear Oversight for resolution with successively higher levels ofCompany or Supplier executive management, as applicable.

18.4 Supplier Quality Assurance

Company documents ensure that (1) triennial external audits, (2) annual Supplier QA programevaluations, (3) reviews of audits conducted by external organizations (e.g., other utilities andNUPIC), and (4) maintenance of the approved Suppliers list are performed to assure Suppliers’quality programs meet applicable requirements and that only qualified Suppliers are used.

18.5 Internal Audits

During the design, construction, and decommissioning phases of a facility, internal audits areperformed of selected activities at appropriate times commensurate with scheduled activities toassure timely and effective implementation of QA requirements. During the operations phase andperiods of prolonged lay-up for facilities awaiting final decommissioning, audits are performedat a frequency commensurate with the safety significance of the activities and in such a mannerto assure audits of all applicable QA program elements are completed within a period of twoyears. These audits will include, as a minimum, activities in the following areas:

(1) The conformance of facility operation to provisions contained within the TechnicalSpecifications and applicable license conditions including administrative controls.

(2) The performance, training, and qualifications of the facility staff.



(3) The performance of activities required by the QAPD to meet the criteria of 10 CFR 50,Appendix B.

(4) The Fire Protection Program and implementing procedures. A fire protection equipmentand program implementation inspection and audit utilizing either a qualified offsitelicensed fire protection engineer or an outside qualified fire protection consultant.

(5) Other activities and documents considered appropriate by the MSRC, the ExecutiveManagement Position Responsible for Nuclear Operations, or the CNO.

Audits may also be used to meet the periodic review requirements of the code for the Security,Emergency Preparedness, and Radiological Protection programs within the provisions of theapplicable code.

Internal audits include verification of compliance and effectiveness of the administrative controlsestablished for implementing the requirements of this QAPD; regulations and license provisions;provisions for training, retraining, qualification, and performance of personnel performingactivities covered by this QAPD; corrective actions taken following abnormal occurrences; and,observation of the performance of construction, fabrication, operating, refueling, maintenance,modification, and decommissioning activities.


The Company is committed to implementing an audit program in accordance with the qualitystandards described in NQA-1-1994, Basic Requirement 18 and Supplement 18S-1.

Dominion


DOM-QA-1-ARevision 0

Appendix A

Organizational Relationships of Key ManagementAnd Functional Groups

Appendix AOrganizational Relationships of Key Management

And Functional Groups


Corporate and Technical Support

Executive ManagementPosition Responsible for

Engineering Services

Senior Management PositionResponsible for Nuclear

Oversight

Internal Audits

Supplier Quality


Support Services

Early SitePermitting Project

Protection Services &Emergency

Preparedness

Management SafetyReview Committee

Chief Nuclear Officer (CNO)


Operations

NuclearAnalysis and Fuel

NuclearProjects

Document Controland Records

(VA)

NuclearEngineering

OrganizationalEffectiveness

Supply ChainManagement

Principal Suppliersfor Design andConstruction *

Principal Suppliersfor Design andConstruction *

InformationTechnology

FacilityNuclear Oversight

* When principal Suppliers are used.Shadowed boxes indicate functions for facility operations.Dotted lines represent matrixed relationships.


Facility Operations

Training

Licensing &Operations Support

DOM-Q
A-1-A
OperSite Services

OperationsSupport

OperMan

Shift M

O

LicensedLicensed

* Includes document control and recOperating facility organizations are

Unit Su



2 Revision 0

Operating Facility Organization

ations Maintenance Outage &Planning

Operations WorkControl

ationsager

anager

Management PositionResponsible for Facilityperations & Maintenance

and Non-Operators


Facility Operations

Procedures ∗ Licensing

OrganizationalEffectiveness

Management PositionResponsible for Facility

Safety & Licensing

RadiologicalProtection

& Chemistry

Facility SafetyReview Committee

ords management functions for Millstone. responsible for power plants and associated independent spent fuel storage installations for the site.

Facility QCInspections

(VA)

pervisor




Operating Facility Staff Reporting To Support Organizations

InformationTechnology

Information Technology

* For Millstone, this position does not include the document control and records management function.Shadowed boxes indicate Support organizations.

Training

Training

Security

Fire Protection Program

Facility ProtectionServices Emergency Preparedness

Protection Services &Emergency Preparedness

Reactor Engineer

Nuclear Analysis and Fuel

Nuclear Engineering *

Facility Engineering

Document Control andRecords Management

(VA)

Testing and NDE

System/ComponentEngineering

Nuclear Oversight

Facility NuclearOversight

Internal Audits

Facility QC Inspections (Millstone)



Dominion



Appendix B

Management and Independent Review Activities

Appendix B


Management and Independent Review Activities

1.0 General

The Company ensures that operational phase activities of the facilities are independentlyreviewed on a periodic basis. The purpose of these reviews is to: (1) verify that operational phaseactivities are performed in accordance with this QAPD and Company administrative controls,procedures, and license provisions; (2) review significant proposed plant changes, tests, andprocedures; (3) verify that events that are reportable to the NRC are promptly investigated andcorrected so as to reduce the probability of recurrence; and (4) detect trends that may not beapparent to a day-to-day observer.

These review functions are performed through a combination of safety review committees,independent nuclear safety review groups for facility safety, and internal audits. This Appendixdescribes the review program implemented by the committees and the independent nuclear safetyreview groups. The internal audit program is addressed in Section 18 of this QAPD. The reviewprograms of this appendix ensure that the personnel performing this review collectively have theexperience and competence necessary to review problems in the following areas:

1. Nuclear power plant operations2. Nuclear engineering3. Chemistry and radiochemistry4. Metallurgy5. Nondestructive testing6. Radiological safety7. Mechanical engineering8. Electrical engineering9. Instrumentation and control

10. Administrative controls and quality assurance practices11. Training12. Emergency plans and related procedures and equipment

An individual may possess competence in more than one specialty area. The establishedadministrative controls contain provisions to assure the appropriate expertise is applied to theindependent reviews, including the use of consultants when necessary.

2.0 Qualifications

Personnel performing the independent review functions meet the qualification requirements ofANS-3.1-1993, subsection 4.7, as clarified in NRC Regulatory Guide 1.8, Revision 3, and thisQAPD. The provisions of Section 4.1.1.1 of ANS-3.1-1993 may be applied with the limitationthat not more than 50% of the personnel performing the independent nuclear safety review groupfunctions for each facility use the alternatives to degree requirements for qualification.Independent review personnel shall also complete the required qualification training for thefunction they are performing.

Appendix B


3.0 Management Safety Review Committee (MSRC)

The MSRC shall ensure that periodic independent reviews and audits of activities are conductedby qualified individuals free from the pressures of plant operations. For new nuclear power plantconstruction, the MSRC shall be functional at least one year prior to initial core loading. TheMSRC serves in an advisory capacity to the CNO.

3.1 Review Responsibilities

The MSRC shall ensure periodic independent reviews and audits of activities as stated in thefacility Technical Specifications and this QAPD are performed. Review of events shall includethe results of any investigations made and the recommendations resulting from suchinvestigations to prevent or reduce the probability of recurrence of the event. Additional reviewactivities by the MSRC should be performed to verify adequate organizational response toadverse performance trends.

The MSRC should monitor the results of audits, evaluations, and assessment activities to ensurethat items that could affect plant safety are reviewed. The MSRC may delegate review functionsto subcommittees, that may include MSRC members, provided that the subcommittees report theresults of their reviews to the MSRC.

3.2 Composition

The MSRC shall be composed of the Chairperson and a minimum of four members, of whom nomore than a minority are members of the plant operating organization. The CNO shall appoint, inwriting, a Chairperson. The Chairperson shall appoint, in writing, a minimum of four members tothe MSRC and shall designate from this membership, in writing, a Vice Chairperson.Consultants should be utilized as determined by the MSRC Chairperson to provide expert adviceto the MSRC.

3.3 Alternates

Alternates shall be designated in advance, but their use shall be restricted to legitimate absencesof principals.

3.4 Meeting Frequency

The MSRC shall meet at least once per six months. During initial operation of a newlyconstructed power plant the meeting frequency shall be at least once per calendar quarter.

MSRC decisions should be made at formal meetings. However, in extenuating circumstanceswhere it is impractical to convene a quorum for a formal meeting within a necessary timeconstraint, alternative means such as a conference call may be used. In such cases, action takenshall be reviewed by a quorum of the MSRC at its next regularly scheduled meeting.

Appendix B


3.5 Quorum

The quorum of the MSRC shall consist of a majority of regular members including theChairperson or Vice Chairperson. No more than a minority of the quorum shall have lineresponsibility for operation of a Company nuclear facility.

3.6 Records

Minutes of all MSRC meetings shall be prepared and retained. All documents reviewed shouldbe identified. Decisions and recommendations made by the MSRC shall be documented.Minutes of each MSRC meeting shall be disseminated promptly to appropriate members ofmanagement having responsibility in the area reviewed. Records of meeting minutes shall beretained in accordance with Section 17 of this QAPD.

4.0 Facility Safety Review Committee

The facility safety review committee serves in an advisory capacity to the executive managementposition responsible for facility operations on all matters related to nuclear safety for theirassigned Company facilities.

4.1 Composition

The facility safety review committee shall be composed of a minimum of five members. Theexecutive management position responsible for facility operations shall appoint, in writing, themembers of facility safety review committee, including the facility safety review committeeChairperson and the Vice Chairperson drawn from the committee members.

4.2 Alternates

Alternate members shall be appointed in writing by the facility safety review committeeChairperson to serve on a temporary basis. Each alternate shall meet the minimum qualificationsdescribed above for facility safety review committee members, and shall have the same area ofexpertise as the member being replaced.

4.3 Meeting Frequency

The facility safety review committee shall meet at least once per calendar month and asconvened by the facility safety review committee Chairperson.

4.4 Quorum

A quorum of the facility safety review committee shall consist of the Chairperson or ViceChairperson and two members or designated alternates. However, a maximum of one third of thevoting membership may be designated alternates.

Appendix B


For any facility safety review committee decision affecting site-wide issues, the Chairpersonshall ensure appropriate representation.

4.5 Responsibilities

The facility safety review committee shall be responsible for:

(a) Review of (1) all procedures and programs required by facility Technical Specificationsadministrative controls and changes thereto that require a regulatory evaluation under thefacility’s 10 CFR 50.59 and 10 CFR 72.48 screening program, (2) changes to the qualityprogram determined to be reductions in the commitment to quality under the provisionsof 10 CFR 50.54(a), (3) any other proposed procedures, programs, or changes theretoaffecting facility nuclear safety as determined by the executive management positionresponsible for facility operations.

(b) Review of all proposed changes to nuclear facility Technical Specifications.

(c) Review of all proposed tests and experiments that affect nuclear safety.

(d) Review of all proposed changes or modifications to systems or equipment that affectnuclear safety.

(e) Rendering determinations in writing or meeting minutes if any item considered under (a)through (d) above, as appropriate and as provided by 10 CFR 50.59, 10 CFR 50.92, or10 CFR 72.48 requires a license amendment or requires a significant hazardsconsideration determination.

(f) Performance of special reviews and investigations and reports as requested by theChairperson of the facility safety review committee or the executive managementposition responsible for facility operations.

(g) Investigations of all violations of Technical Specifications, including the preparation andforwarding of reports covering evaluation and recommendations to prevent recurrence, tothe executive management position responsible for facility operations, the CNO,executive management position responsible for nuclear operations, and to theChairperson of the MSRC.

(h) Review of all nuclear facility reportable events.

(i) Review of facility operations to detect potential safety hazards.

(j) Review of Millstone Unit 3 Turbine Overspeed Protection Maintenance and TestingProgram and revisions thereto, where applicable. (Based on regulatory commitment.)

Appendix B


4.6 Authority

The facility safety review committee shall:

Recommend to the executive management position responsible for facility operations writtenapproval or disapproval in meeting minutes of items considered under Responsibilities (a)through (j) above. The executive management position responsible for facility operations willreport any issues that require higher level of authority to the executive management positionresponsible for nuclear operations.

Provide written notification within 24 hours to the executive management position responsiblefor nuclear operations, and the Chairperson of the MSRC of disagreement between the facilitysafety review committee and the executive management position responsible for facilityoperations. The executive management position responsible for nuclear operations shall haveresponsibility for resolution of such disagreement.

4.7 Records

The facility safety review committee shall maintain written minutes of each meeting and copiesshall be provided to the executive management position responsible for facility operations, theexecutive management position responsible for nuclear operations and the facility safety reviewcommittee. Records of the minutes shall be maintained in accordance with this QAPD, Section17.

5.0 Independent Nuclear Safety Review

5.1 Function

Independent nuclear safety review functions1 are performed for Company nuclear facilities by agroup of qualified individuals reporting through a management line not directly responsible foroperation and maintenance of the facility. The functions include examination of unit operatingcharacteristics, NRC issuances, industry advisories, Licensee Event Reports, and other sourcesthat may indicate areas for improving unit safety. The review group functions to advise theexecutive management position responsible for facility operations on matters related to nuclearsafety.

5.2 Composition

The review group shall be composed of a minimum of four full-time engineers located on site toperform the independent nuclear safety review functions.

1 These groups perform the reviews to meet the guidelines of NUREG-0737, Section I.B.1.2 for the IndependentSafety Engineering Group.

Appendix B


5.3 Responsibilities

The review group shall be responsible for monitoring of unit activities to provide independentverification, not including responsibility for sign-off functions, that these activities are performedcorrectly and that human errors are reduced as much as practical.

5.4 Authority

The review group shall make detailed recommendations for revised procedures, equipmentmodifications, maintenance activities, operations activities, or other means of improving nuclearsafety to appropriate facility and corporate management.

5.5 Records

Quarterly reports of completed evaluations will be made to appropriate levels of managementresponsible for facility operations. Records of safety-related activities shall be prepared andmaintained in accordance with Section 17 of this QAPD.

Dominion



Appendix C

Regulatory Guides and Quality Standards Commitments

Appendix C



Through this QAPD, the Company commits to compliance with the regulatory guidance andindustry standards governing quality assurance as described below along with any exceptions,alternatives, or clarifications described within this QAPD. Commitment to a particularRegulatory Guide or industry standard does not constitute commitment to Regulatory Guides orother standards that may be referenced therein; unless otherwise stated within this QAPD, thosereferenced documents are considered as guidance. When applicable, for Class 1, 2, and 3 itemscovered by Section III of the ASME Boiler and Pressure Vessel Code, the code QualityAssurance requirements are supplemented by the guidance of applicable regulatory guides andthis QAPD.

1. Regulatory Guide 1.8, Revision 1-R (Reissued May 1977)– Personnel Selection and Training

This commitment applies to the Millstone Power Station Facilities only. This RegulatoryGuide endorses ANSI N18.1-1971, Selection and Training of Nuclear Power Plant Personnel.Where these editions of the Regulatory Guide and ANSI standard are invoked by this QAPDand/or facility Technical Specifications, the Company will implement the requirements andguidance of the standard and Regulatory Guide subject to the following alternatives:

1. ANSI N18.1-1971, subsection 4.2.2, states in part “The Operations Manager shall hold aSenior Reactor Operator’s license.” The following alternative to this requirement may beused:

The provisions of the Millstone Unit 2 and Unit 3 Technical Specifications paragraph6.3.1.a.

2. ANSI N18.1-1971, subsection 4.3.1, states in part, “A Supervisor (requiring an AEClicense) shall have a minimum of a high school diploma or equivalent, and four years ofresponsible power plant experience, of which a minimum of one year shall be nuclearpower plant experience. A maximum of two years of the remaining three years of powerplant experience may be fulfilled by academic or related technical training on a one-for-one basis.” The following alternative to this requirement will be applied:

Beginning November 1, 2001, applicants for senior reactor qualification shall meet orexceed the education and experience guidelines given in Revision 3 to RegulatoryGuide 1.8. Reference license amendments 258 (MP2) and 199 (MP3).

3. ANSI N18.1-1971, subsection 4.5.1, states in part, “An operator (to be licensed by theAEC) shall have a minimum of a high school diploma or equivalent, and two years ofpower plant experience, of which a minimum of one year shall be nuclear power plantexperience.” The following alternative to this requirement will be applied:

Beginning November 1, 2001, applicants for reactor qualification shall meet orexceed the education and experience guidelines given in Revision 3 to RegulatoryGuide 1.8 (May 2000). Reference license amendments 258 (MP2) and 199 (MP3).

Appendix C


2. Regulatory Guide 1.8, Second Proposed Revision 2, (September 1980)– Personnel Qualification and Training

This commitment applies to the North Anna and Surry facilities only. This Regulatory Guideendorses ANSI/ANS-3.1 (Draft 12/79), Qualification and Training of Personnel for NuclearPower Plants. Where these editions of the Regulatory Guide and ANSI standard are invokedby this QAPD and/or facility Technical Specifications, the Company will implement therequirements and guidance of the standard and Regulatory Guide subject to the followingalternatives:1. ANS-3.1 (Draft 12/79), subsection 4.2.2 c. for the Operations Manager Training requires

the individual filling this position to obtain and hold a senior operator license. Thefollowing alternative to this requirement will be applied:

The individual filling the role of operations manager and the individual filling the roleof operations middle manager (supervisor shift operations) will meet the licenserequirements of North Anna Units 1 and 2 Technical Specification 5.2.2.e or SurryUnits 1 and 2 Technical Specification 6.1.2.2.d as applicable.

2. ANS-3.1 (Draft12/79), Section 4.1 addresses those circumstances where individuals donot possess the formal educational requirements specified in the standard by indicatingthat other factors should be evaluated to ensure qualified individuals fill theorganizational functions. As part of that evaluation, either of the following additionalexperience requirements may be considered equivalent to a Bachelor’s Degree:(1) Six years of applied engineering experience at a nuclear facility in the area for which

qualification is sought. In addition, experience and training requirements for thefunction shall be met as delineated.

(2) Six years of operational or technical experience/training related to engineering innuclear power. In addition, experience and training requirements for the functionshall be met as delineated.

3. ANSI/ANS-3.1 (Draft 12/79), subsection 4.4.5, Quality Assurance, identifies therequirements for professional or technical group leaders in the Quality Assurancefunction. The individuals filling this function within the Company’s Nuclear Oversightorganization will comply with the following alternative:

ANSI/ANS-3.1-1993, subsections 4.3.7, Quality Assurance, and 4.4.13, QualityAssurance or Quality Control, subject to the description of the commitment to NRCRegulatory Guide 1.8, Revision 3 below.

4. ANSI/ANS-3.1 (Draft 12/79), subsection 4.3.2.b, describes the experience requirementsfor supervisors not requiring NRC license. The following alternate experiencerequirements may be applied to personnel filling the supervisory function:

At the time of appointment to the position; the supervisor shall have 4 yearsexperience in the craft or discipline he supervises or an equivalent number of yearsnuclear plant experience in a supervisory position with a Senior Reactor Operator’slicense.

Appendix C


5. ANSI/ANS-3.1 (Draft 12/79), subsection 5.3.3 describes the training requirements for theShift Technical Advisor with Bachelor Degree without an NRC Senior Operator License.In lieu of the requirement of item 3) to that subsection, the following alternative may beapplied:

The Shift Technical Advisors will observe control manipulations on the simulator asappropriate.

6 ANSI/ANS-3.1 (Draft 12/79), Section 5.5 describes the retraining program requirements.The following alternative requirements will be applied for the following functionalpositions:

Requalification training requirements for Nuclear Shift Supervisor, Nuclear AssistantShift Supervisor, Control Room Operator - Nuclear, and Shift Technical Advisor areaddressed in the Technical Specifications of the individual nuclear facility.

3. Regulatory Guide 1.8, Revision 3, May 2000– Qualification and Training of Personnel for Nuclear Power Plants

This commitment applies to quality verification functions and support functions responsiblefor multiple facilities. This Regulatory Guide endorses ANSI/ANS-3.1-1993, Selection,Qualification, and Training of Personnel for Nuclear Power Plants. Where these editions ofthe Regulatory Guide and ANSI standard are invoked by this QAPD and/or facility TechnicalSpecifications, the Company will implement the requirements and guidance of the standardand Regulatory Guide subject to the following alternatives:

1. Regulatory Guide 1.8, Rev. 3, C. Regulatory Position, paragraphs 2.1.1 and 2.1.3 addressapproval by the plant manager of the equivalents for education and experience forpersonnel filling Quality Assurance functional positions. The following alternativerequirement for approval of the equivalents will be used by replacing the second sentencein each of the above paragraphs with the following sentence:

These other factors are to be evaluated on a case-by-case basis and approved anddocumented by the plant manager or the responsible executive.

2. Regulatory Guide 1.8, Rev. 3, C. Regulatory Position, paragraphs 2.1.2, 2.3, 2.11, and2.12 address endorsement of ANSI/ASME NQA-1-1983 related to qualification ofQuality Control and Quality Assurance Personnel. The following alternative standard willbe used for the qualification of these personnel:

References to ANSI/ASME NQA-1-1983 and associated Supplements andAppendices are replaced with references to ANSI/ASME NQA-1-1994 and itsassociated Supplements and Appendices.

Appendix C


4. Regulatory Guide 1.26, Revision 3, February 1976 – Quality Group Classifications and Standards for Water-, Steam-, and Radioactive

Waste-Containing Components of Nuclear Power Plants

The commitment to this Guide (including revision/date) is site specific as described in theapproved SAR or License for each Company nuclear facility. Where items do not conform tothe requirements of the Guide they are addressed in the applicable facility’s SAR. Thequality group classification systems used for the facilities conforms with the requirements ofthis Regulatory Guide with the following alternative:

The Company does not use the specific A, B, C, and D quality groups set forth in thisguide. However, the Company met the requirements of this guide in developing the list ofSSCs and the corresponding association to quality standards. The specific items the QAprogram applies to are described in detail in the lists maintained by the NuclearEngineering group.

5. Regulatory Guide 1.28, Revision 3, August 1985– Quality Assurance Program Requirements (Design and Construction)

This Regulatory Guide addresses requirements for assuring quality during the design andconstruction phases of nuclear power plants. The Company will implement the requirementsand guidance of the standard and Regulatory Guide during the design and constructionphases of the facilities subject to the following alternatives:

1. Part C, Regulatory Position of this Regulatory Guide endorses the basic andsupplementary requirements of ANSI/ASME NQA-1-1983 and the ANSI/ASME NQA-1a-1983 Addenda for the establishment and execution of quality assurance programsduring the design and construction phases of nuclear power plants.

In place of the specific edition and addenda of NQA-1 addressed in the RegulatoryGuide, the Company commits to implement the requirements of the 1994 Edition.The Company’s commitment to these requirements and any alternatives to therequirements are addressed below.

2. Regulatory Position 3.2 establishes external auditing requirements that are acceptable tothe NRC during the design and construction phases.

The guidance provided regarding external audits will also be implemented during theoperational phase.

6. ANSI/ASME NQA-1-1994– Quality Assurance Requirements for Nuclear Facility Applications

The Company’s quality assurance program will implement the basic and supplementaryrequirements of Part I and the requirements of Part II to the 1994 edition of NQA-1 subject tothe alternatives addressed below:

Appendix C


1. The Introduction to Part I of NQA-1, Section 4, and certain Subparts to Part II of NQA-1,define terms to be used with the quality assurance requirements.

Additional definitions applicable to implementation of the Company’s QualityAssurance Program are contained in Appendix D to this QAPD.

2. Supplement 2S-1, Supplementary Requirements for the Qualification of Inspection andTest Personnel will include use of the guidance provided in Appendix 2A-1 the same as ifit were a part of the Supplement. The following two alternatives may be applied to theimplementation of the requirements of this Supplement and Appendix:(1) In lieu of being certified as Level I, II, or III in accordance with NQA-1-1994,

personnel performing operations phase independent quality verification inspections,examinations, measurements, or tests of material, products, or activities will berequired to possess qualifications equal to or better than those required for performingthe task being verified; and the verification is within the skills of these personneland/or is addressed by procedures. These individuals will not be responsible for theplanning of quality verification inspections and tests (i.e., establishing hold points andacceptance criteria in procedures, and determining who will be responsible forperforming the inspections), evaluating inspection training programs, nor certifyinginspection personnel.

(2) A qualified engineer may be used to plan inspections, evaluate the capabilities of aninspector, or evaluate the training program for inspectors. For the purposes of thesefunctions, a qualified engineer is one who has a baccalaureate in engineering in adiscipline related to the inspection activity (such as, electrical, mechanical, civil) andhas a minimum of five years engineering work experience with at least two years ofthis experience related to nuclear facilities.

3. Supplement 2S-2, Supplementary Requirements for the Qualification of NondestructiveExamination Personnel, subsection 2.1 requires application of Recommended PracticeSNT-TC-1A, June 1980 Edition to NDE personnel.

The Company will implement the qualification program required by this supplementin accordance with the applicable standard for the facility’s commitment to theASME code or other applicable code governing the activity.

4. Supplement 7S-1, Supplementary Requirements for Control of Purchased Items andServices, Section 10 addresses requirements for Commercial Grade Items.

The Company will use the guidance contained in EPRI NP-5652 instead of theserequirements.

5. Supplement 10S-1, Supplementary Requirements for Inspection, subsection 3.1 addressesreporting independence and requires that inspection personnel shall not report directly tothe immediate supervisors who are responsible for performing the work being inspected.

Where quality verification inspections at operating facilities are performed by theMaintenance group, to meet the independence requirements of NQA-1, Supplement10S-1, Section 3.1, the inspectors report to the Facility Safety and Licensingorganization while performing the inspection.

Appendix C


6. Subpart 2.2, Quality Assurance Requirements for Packaging, Shipping, Receiving,Storage, and Handling of Items for Nuclear Power Plants, requirements will beincorporated into the Company program subject to the following alternatives:(1) For items in storage, as determined by facility management the packaging



(3) Regarding maintenance of items in storage in accordance with subsection 6.4.2, “Careof Items,” the requirement of item (f) will not apply to rotating electrical equipmentless than 50 HP, the requirement of item (g) will not apply to rotating equipmentweighing less than 50 pounds, the requirements of (e), (f), and (g) may be exemptedfor specific items on a case-by-case basis provided that a documented engineeringevaluation determines that such care is not required.

(4) Subsection 6.6, “Storage Records,” requires written records be prepared containinginformation on personnel access. As an alternative to this requirement, Companydocuments establish controls for storage areas that describe those authorized to accessareas and the requirements for recording access of personnel. However, these recordsof access are not considered quality records and will be retained in accordance withthe administrative controls for the facility.

7. Subpart 2.3, Quality Assurance Requirements for Housekeeping for Nuclear PowerPlants, will be implemented with the following alternative that will be applied during theoperational phase:

The Company may choose to not utilize the five-level zone designations, but willutilize work practices, as described in administrative controls, that provide anequivalent level of cleanliness control required by the subpart. This will include as aminimum documented cleanliness inspections which will be performed prior tosystem closure. As necessary, (e.g., the size of the opening would permit entry of thetools being used) control of personnel, tools, equipment, and supplies will beestablished when major portions of the reactor system are opened for inspection,maintenance, or repair.

8. Subpart 2.4, Installation, Inspection, and Testing Requirements for Power,Instrumentation, and Control Equipment at Nuclear Facilities (ANSI/IEEE Std. 336-1985), will be implemented with the following alternatives:(1) All references to ANSI/ASME NQA-1, ANSI/ASME NQA-2, and ANSI/ANS-3.2

are changed to refer to the appropriate sections of ANSI/ASME NQA-1–1994 andthis QAPD.

(2) With regard to subsection 3.3, “Procedures and Instructions,” as an alternative to therequirement to utilize a checklist and mark as required or not appropriate the listeditems during preparation of procedures or instructions, the Company utilizes

Appendix C


administrative controls to ensure the appropriateness and correctness of proceduresand instructions including reviews against standards that may not require a checklistto be marked.

(3) Instrumentation and control devices installed in operating facilities are not required tobe labeled as described in subsection 7.2.1, provided the information is maintained insuitable documentation traceable to the device.

9. Subpart 2.5, Quality Assurance Requirements for Installation, Inspection, and Testing ofStructural Concrete, Structural Steel, Soils, and Foundations for Nuclear Power Plants,will be implemented with the following alternative:(1) Where important to safety structures other than concrete reactor vessels and

containments are constructed or modified, other appropriate industry codes andstandards may be invoked in place of ACI 359 as specified by the responsible designorganization so long as they meet any current license commitments.

(2) With regard to subsection 7.7, “Curing,” ASTM C 1315 is added to the firstparagraph as another applicable standard for test methods for curing compounds.

10. Subpart 2.15, Quality Assurance Requirements for Hoisting, Rigging, and Transportingof Items for Nuclear Power Plants, will be implemented with the following alternative:

The Company may choose to not use the specific classification of Categories A, B,and C, but ensures items to be handled are evaluated and the appropriate range ofcontrols and requirements for the activity are applied consistent with this Subpart.

11. Subpart 2.16, Requirements for the Calibration and Control of Measuring and TestEquipment Used in Nuclear Facilities (ANSI/IEEE Std. 498-1985) will be implementedwith the following alternatives:(1) All references to ANSI/ASME NQA-1, ANSI/ASME NQA-2, and ANSI/ANS-3.2

are changed to refer to the appropriate sections of ANSI/ASME NQA-1–1994 andthis QAPD.

(2) Instrumentation and control devices installed in operating facilities are not required tobe labeled as described in Subpart 2.16, subsection 5.5, provided the information ismaintained in suitable documentation traceable to the device.

12. Subpart 2.18, Quality Assurance Requirements for Maintenance of Nuclear Facilities,will be implemented with the following alternative:(1) Where this subpart references the requirements of ANS-3.2, it shall be interpreted to

mean the applicable standards and requirements established within this QAPD.(2) Regarding subsection 2.5, “Work Authorization,” paragraph (d), the requirement that

the description of work reference the applicable maintenance procedures will betreated as guidance. Personnel responsible for performance of the work are requiredto ensure that they are using the appropriate maintenance procedure.

Appendix C


7. Regulatory Guide 1.29, Revision 3, September 1978– Seismic Design Classification

The commitment to this guide is site specific as described in the approved SAR or Licensefor each Company nuclear facility. The specific design criteria and seismic designations arereflected in each plant’s SAR, and in other docketed analysis.

8. Regulatory Guide 1.33, Revision 2, February 1978– Quality Assurance Program Requirements (Operation)

This Regulatory Guide endorses ANSI N18.7-1976/ANS-3.2 as providing overall acceptablequality assurance program requirements for the operations phase of nuclear power facilities.The Company commits to implementing administrative controls and quality assurancemeasures during the operations phase for its facilities that are equivalent in nature to thosecontained in the endorsed standard subject to the following alternatives:

1. The operational phase quality assurance program requirements will be establishedthrough the Company’s commitment to ANSI/ASME NQA-1-1994 as described withinthis QAPD. This edition of NQA-1 contains overall quality assurance requirementsequivalent to those of ANSI N18.7-1976, and the Company has included within thisQAPD the required administrative controls from ANSI N18.7-1976. Therefore, theCompany does not commit to compliance with the requirements of ANSI N18.7-1976/ANS-3.2.

2. As recommended by Regulatory Position C.1, the Company uses Appendix A ofRegulatory Guide 1.33 as guidance in establishing the types of procedures required forplant operation and support.

3. The Company’s commitment to the applicable Regulatory Guides and associatedstandards listed in Regulatory Position C.2 is addressed within this QAPD. A number ofthese Regulatory Positions and Standards have been incorporated into NQA-1.

4. The Company complies with Regulatory Position C.3, as described in Appendix B of thisQAPD. Appendix B of this QAPD describes the Company’s independent reviewprograms.

5. The Company complies with Regulatory Position C.4 as described within Section 18 ofthis QAPD, subject to the following alternatives that are comparble to those approvedunder the previous operational quality assurance programs:(1) The results of actions taken to correct deficiencies affecting nuclear safety that occur

in the facility SSCs or methods of operation are evaluated as a part of each auditperformed as related to that audited area. An audit of the effectiveness of thecorrective action program is performed at a frequency not to exceed two years.

(2) Audits of conformance of facility operation to provisions of the TechnicalSpecifications and applicable license conditions are performed at a frequency not toexceed two years.

(3) Audits of the performance, training, and qualifications of the facility staff areperformed at a frequency not to exceed two years.

6. In lieu of compliance with Regulatory Position C.5, the Company has establishedappropriate equivalent requirements within this QAPD.

Appendix C


9. Regulatory Guide 1.36, Revision 0, February 1973– Nonmetallic Thermal Insulation for Austenitic Stainless Steel

None of the current Company nuclear facilities were committed to this Regulatory Guideduring original construction. The Company does not commit to this Regulatory Guide for itsexisting plants but will use this guidance for the construction of any new nuclear powerplants. This Regulatory Guide may be used for plant modifications on a case-by-case basis.

10. Regulatory Guide 1.54, Revision 0, June 1973– Quality Assurance for Protective Coatings Applied to Nuclear Power Plants

This Regulatory Guide endorses ANSI N101.4-1972. The commitment to this RegulatoryGuide during construction and earlier operations was site specific as listed in the approvedSAR or License for each Company nuclear facility. The Company commits to the QArequirements of this Regulatory Guide and Standard for design and construction activities.Applicability and implementation of this guide, including quality inspection requirements,for modifications will be determined as needed, by a qualified engineer.

11. Regulatory Guide 1.152, Revision 1, January 1996– Criteria for Digital Computers in Safety Systems of Nuclear Power Plants

This Regulatory Guide endorses IEEE/ANS-7-4.3.2–1993. The Company commits to using theguidance of this Standard within the provisions of the Regulatory Guide with the followingalternative:

Where this Standard makes reference to ASME NQA-1 and ASME NQA-2, the referencewill be interpreted to mean the applicable requirements of NQA-1–1994 and this QAPD.

12. Regulatory Guide 1.143, Revision 2, November 2001– Design Guidance for Radioactive Waste Management Systems, Structures and

Components Installed in Light-water-cooled Nuclear Power Plants

The commitment to this Regulatory Guide (including specific revision) during constructionand earlier operations was site specific as listed in the approved SAR or License for eachCompany nuclear facility. The Company commits to this Regulatory Guide for theconstruction of any new nuclear power plants. The applicable requirements of thisRegulatory Guide will be used for plant modifications on a case-by-case basis.

13. Regulatory Guide 4.15, Revision 1, February 1979– Quality Assurance for Radiological Monitoring Programs (Normal Operations)

The Company programs for radiological environmental monitoring comply with therequirements of this Regulatory Guide.

Appendix C


14. Regulatory Guide 7.10, Revision 1, June 1986– Establishing Quality Assurance Programs for Packaging Used in the Transport of

Radioactive Material

The Company programs for issuing radioactive material for transport complies with the QArequirements for procurement, use, and maintenance of packaging used in the transport ofradioactive material as describe in this Regulatory Guide.

15. Generic Letter 89-02/EPRI-NP-5652– Actions to Improve the Detection of Counterfeit and Fraudulently Marketed Products

The Company commits to use of the endorsed industry guidance regarding the selection andqualification of commercial grade Suppliers and for the dedication of commercial gradeitems used in applications that are important to safety.

16. Branch Technical Position ASB/CMEB 9.5-1– Guidelines for Fire Protection for Nuclear Power Plants

The Company commits to implementing the guidance of this Technical Position, however,application of the requirements is site specific as described in the applicable facility SAR andlicense documents. The Company QA program complies with the QA requirements describedin Position C.4.

17. Generic Letter 85-06–Quality Assurance Guidance for ATWS Equipment That is Not Safety-Related

The Company commitment to the guidance of this Generic Letter is site specific as indicatedin the SAR for the applicable facility and the facility’s response to the Generic Letter.

18. Regulatory Guide 1.97- Instrumentation for Light-Water-Cooled Nuclear Power Plants To Assess Plant and

Environs Conditions During and Following an Accident

The Company commitment to this Regulatory Guide is site specific as indicated in the SARfor the applicable facility and the facility’s response to the NRC regarding this guidance.

Dominion



Appendix D

Terms and Definitions

Appendix D



In addition to those terms defined in NQA-1–1994, the following definitions of terms are to beused in the context of this QAPD and activities governed by this QAPD.

Administrative Controls – Rules, orders, instructions, procedures, policies, practices anddesignations of authority and responsibility.

Experiment – Performance of those plant operations carried out under controlled conditions inorder to establish characteristics or values not previously known.

Deleterious Corrosion – corrosion that cannot be subsequently removed and that adverselyaffects form, fit, or function.

Independent Review – Review completed by personnel not having direct responsibility for thework function under review regardless of whether they operate as a part of an organizational unitor as individual staff members.

Lifetime (Records) – Lifetime in defining the retention period for records is until (1) terminationof the applicable Facility Operating License, (2) termination of employment (training andqualification records), (3) transfer of ownership (i.e., fuel), (4) end of service life of the facility,system, or component, as applicable.

MPS – Millstone Power Station.

NAPS – North Anna Power Station

Nuclear Power Plant – Any plant using a nuclear reactor to produce electric power, processsteam or space heating.

Operating Activities – Work functions associated with normal operation and maintenance of theplant, and technical services routinely assigned to the facility operating organization.

Operational Phase – That period of time during which the principal activity is associated withnormal operation of the plant. This phase of plant life is considered to begin formally withcommencement of fuel loading, and ends with plant decommissioning.

Organization, Facility Operating – Personnel concerned with operation, maintenance andcertain technical services such as reactor engineering and performance of tests/inspections. Thisorganization is also referred to in various standards as the onsite organization and comprises thefacility staff.

Organization, Support – Personnel providing support functions to the operating organizationregardless of their physical location. This organization is also referred to in various standards asthe offsite organization.

Appendix D


Program Deficiency – Failure to develop, document or implement effectively any applicableelement of the QA Program.

Quality Verification – The act of reviewing, inspecting, testing, checking, auditing, orotherwise determining and documenting whether items, processes, services, or documentsconform to specified requirements integral to the QA Program.

Safety Analysis Report (SAR) – This term is used generically to refer to the SAR required byNRC regulations that is applicable for the particular nuclear facility for which the activity isbeing performed. This usage includes, but is not limited to preliminary, final, updated final, anddecommissioning safety analysis reports.

Supervision – Direction of personnel activities or monitoring of plant functions by an individualresponsible and accountable for the activities he directs or monitors.

SPS – Surry Power Station

Surveillance Testing – Periodic testing to verify that safety-related structures, systems andcomponents continue to function or are in a state of readiness to perform their functions.

System – An integral part of a nuclear power plant comprising components which may beoperated or used as a separate entity to perform a specific function.

Time Intervals – With the exception of time intervals from applicable Codes or the facilityTechnical Specifications, the following definitions shall be applied for other activities and maybe extended by up to 25%:

Weekly: at least once per 7 days

Monthly: at least once per 31 days

Quarterly or every 3 months: at least once per 92 days

Semiannually or every 6 months: at least once per 184 days

Every 9 months: at least once per 276 days

Yearly or annually: at least once per 366 days

Biennial (2 years): at least once per 732 days

Triennial (3 years): at least once per 1098 days

VA – Virginia Power Stations, i.e., NAPS and SPS

Dominion



Appendix E

Additional QA Records RequirementsFor Operating Facilities

Appendix E


Additional QA Records Requirements for Operating Facilities

The following Table lists the type of records and the required retention times and providesadditional requirements to those described in the Quality Standards Commitment discussed inSection 17 of this QAPD.

Description of Records RetentionPeriod

Records and drawing changes reflecting plant design modifications made tosystems and equipment described in the SAR

Lifetime

Records of new, irradiated, and spent fuel inventory, transfers of fuel, andassemblies history

Lifetimeplus 3 years

Records of plant radiation and contamination surveys LifetimeRecords of off-site environmental monitoring surveys LifetimeRecords of radiation exposure of all individuals who enter radiation controlareas

Lifetime

Records of radioactive levels of liquid and gaseous waste released to theenvirons

Lifetime

Records of reviews performed for changes made to the offsite dosecalculation manual and the process control program

Lifetime

Records of meetings of the facility safety review committee and theManagement Safety Review Committee

Lifetime

Records of transient or operational cycles for those facility componentsdesignated to operate safely for a limited number of transients or operationalcycles

Lifetime

Records of the service lives of all hydraulic and mechanical snubbers onsafety-related systems, including the date at which the service lifecommences and associated installation and maintenance records (VA)

Lifetime

Records of Environmental Qualification in accordance with 10 CFR 50.49 LifetimeRecords of secondary water sampling and water quality LifetimeRecords of normal plant operation, including power levels and periods ofoperation at each power level

5 years

Records of principal maintenance activities, including inspection, repair,substitution or replacement of principal items of equipment important tonuclear safety

5 years (exceptISFSI activitiesare Lifetime)

Records of reportable events 5 yearsRecords of special reactor tests or experiments 5 yearsRecords of changes made in procedures pursuant to 10 CFR 50.59 or 72.48 5 yearsRecords of radioactive material shipments 3 yearsRecords of sealed source leak test results and physical inventories of sealedsource material

5 years

Appendix E


Description of Records RetentionPeriod

Records of current individual plant staff members qualifications, experience,training and retraining

Lifetime or asnoted below

• Radiological protection training records (e.g., general trainingprovided to personnel with access to the facilities, AdvancedRadiation Worker, Radiation Protection Technician, etc.)

Lifetime

• Initial training and qualification records Lifetime• Requalification records (except licensed individuals) 3 training cycles• Requalification records for licensed individuals 6 years after

license renewal• Training materials – Revision 0 records Lifetime

• Licensed Operators training materials – superceded revisions 6 years• Non-licensed Facility staff training materials – superceded

revisions3 training cycles

• Radiation Protection training materials – superceded revisions Lifetime• Retraining, specialized training, continuing training records (except

licensed individuals and Radiological Protection technicians3 training cycles

• Contractor training (except general training for facility access,Advanced Radiation Worker, Radiation Protection Techniciantraining and retraining, etc.)

3 training cycles

NANT Accreditation records – Initial accreditation– Superceded material

Lifetime4 Years

• Simulator facility records (e.g., certification and basis documents,NRC Form-474, performance test, fidelity reports, maintenance andmodifications, and basis documents, etc.)

– Initial accreditation records Lifetime– Superceded material 4 years after

submittal ofNRC Form-474

Dominion



Attachment 1

NRC Request for Additional Information QuestionsWith Dominion Response

Serial No. 05-251Response to Request for Additional Information

ATTACHMENT 1

RESPONSE TO REQUESTS FOR ADDITIONAL INFORMATIONNUCLEAR FACILITY QUALITY ASSURANCE PROGRAM DESCRIPTION

DOMINION NUCLEAR CONNECTICUT, INC.VIRGINIA ELECTRIC AND POWER COMPANY


Quality Assurance Program DescriptionAttachment 1 Page 1 of 10

RESPONSE TO REQUESTS FOR ADDITIONAL INFORMATIONTHE NUCLEAR FACILITY QUALITY ASSURANCE PROGRAM DESCRIPTION

In a letter dated August 24, 2004, Dominion Nuclear Connecticut, Inc. (DNC) andVirginia Electric and Power Company (Dominion) submitted a revision to therespective station’s Quality Assurance Program for NRC review and approval.

In a facsimile dated February 24, 2005, the NRC forwarded a request foradditional information (RAI) related to the DNC and Dominion submittal. DNCand Dominion provide their response below.

The revisions to DOM-QA-1 and Discussion of Changes document are includedwith the response to the Draft RAI dated February 24, 2005. Changes to the QATopical Report have been included in DOM-QA-1, Rev. 0a (Enclosure 2), and areindicated by strikethrough for deleted text and underline for inserted text with avertical line in the right margin to indicate a change was made. A similar changehas been made to Enclosure 4, Discussion of Changes, however, Tables 2 and 3have been added without change markings to provide for better clarity of the text.

NRC Question 1

Provide a matrix that describes the migration of each unit/facility current qualityassurance commitments to the proposed commitments for each unit/facility. Thematrix should state whether each commitment is a non-reduction, reduction, oran increase in commitment. Provide justification for all reductions incommitments. Also provide references to any safety evaluation precedents usedto change existing commitments. Demonstrate that these precedents areapplicable to the licensee’s facilities.

Dominion Response

Enclosure 4 of this submittal contains the information requested. A specific matrixof each commitment by former QA program description is provided as Table 2 forMillstone Power Station and Table 3 for North Anna and Surry Power Stations.

Attachment 1 to NFQAPD

Attachment 1 provides the proposed NFQAPD for the licensee’s facilities.



NRC Question 1

Section 11.2, test procedures, states “the prerequisites are normally completedprior to commencement of the test.” How do you ensure the item is ready fortesting if the prerequisites are not completed? What is the basis for thisstatement?

Dominion Response

Based on ANSI N18.7-1976, subsection 5.3.2(4), there may be prerequisites thatonly apply to a specific part of a test (procedure) and therefore would only needto be satisfied at the point when those steps will be implemented. The statementin the QAPD has been clarified to address the question.

NRC Question 2

Section 13.3 provides the quality standards commitment and providesalternatives for Subpart 2.2 and subpart 2.15. What are the bases for theseproposed alternatives?

Dominion Response

These are alternatives carried over from the existing NRC-approved North Annaand Surry QA program. The alternatives were first proposed in Virginia Electricand Power Company Quality Assurance Program VEP-1, Revision 4 andapproved by the NRC as documented in letter to E. A. Baum, datedOctober 6, 1982. The basis for the subpart 2.15 alternative is addressed in theDiscussion of Changes under the NQA-1, Subpart 2.15, and Tables 2 and 3.

NRC Question 3

Section 17.2, records of activities, states that the “records and their retentiontimes are based on Regulatory Position C.2, Table 1, of NRC Regulatory Guide1.28.” The applicable revision number, i.e., Rev. 3, should be used to beconsistent with the remainder of the NFQAPD.

Dominion Response

This editorial change has been made. The specific information regarding theRegulatory Guide revision was provided in subsection 17.4 listing thecommitments for this section.




Attachment 2 provides a discussion of changes to the current Quality Assurance(QA) program for Millstone, North Anna and Surry.

NRC Question 1

In attachment 2, an evaluation of alternatives to committed standards is provided.Specifically, pages 5 and 6 discuss commitments to ANS-3.1 (draft 12/79) andalternatives to ANS-3.1-1993. Since the proposed NFQAPD is adoptingNQA-1-1994 and ANS-3.1-1994, in part, it is not clear why the licensee haschosen to maintain its commitment to ANS-3.1 (draft 12/79). Although approvedas part of the licensing basis for North Anna and Surry, the draft 12/79 ANS-3.1standard was not endorsed by the NRC staff. Provide a discussion as to why youare maintaining your commitment to ANS-3.1 (draft 12/79) for North Anna andSurry and why ANS-3.1 (draft 12/79) is applicable to Millstone (as it appears tobe in this section).

Dominion Response

The current facility technical specifications commit North Anna and Surry PowerStations to this draft standard and the draft Reg. Guide. This was discussedwhen Dominion presented the overview of Dominion’s project to have aconsolidated QA program to the NRC. Dominion’s intent was to relocate thecommitments from the Technical Specifications to the QA program, as much aspractical, in the same form. As allowed in the guidance of Administrative Letter95-05, a controlled change to a later edition standard, common for all theDominion sites, could be made in the future in accordance with the provisions of10 CFR 50.54(a). The change to a common standard would require thatDominion adopt a more recent standard, previously approved by the NRCthrough a Regulatory Guide or SER. Alternatively, Dominion would submit thechange to the NRC for review and approval. Since Dominion understood thiswould be a two-part change process, the procedures and programs have notbeen updated to implement the requirements of the common standard across thefleet. Since the request to relocate the information from the TechnicalSpecifications to the QA Program is being denied, Dominion will be required tomake a concurrent change to the Technical Specifications and QA Program inorder to adopt a common standard at a future date.

It was not the intent of this change to make these commitments applicable to anyother Dominion stations. Millstone is currently committed to ANSI N18.1-1971 bytechnical specifications. It is Dominion’s intent for this standard to remain for thefacility until the subsequent change to a common later edition standard for allsites is processed. Dominion has clarified the application of these commitments



both in the NFQAPD, Appendix C and the discussion in Attachment 2 of theoriginal submittal. Also, as a clarification, Dominion is committing toANS-3.1-1993 in part, as endorsed by NRC Regulatory Guide 1.8, Revision 3,rather than ANS-3.1-1994.

NRC Question 2

In attachment 2, page 8 describes an alternative to NQA-1-1994 Appendix 2A-1regarding the use of Level I, II, and III for qualification of inspectors. As proposed,the alternative does not provide an adequate description of the education andexperience requirements for those individuals performing quality controlverification. Provide further description of what is meant by “the qualificationprogram will ensure that only personnel that meet the education and experiencerequirements, and have demonstrated appropriate capabilities in the inspectionand test activities they are assigned will be certified and used to perform thoseinspections” (page 13 of proposed NFQAPD). How does the proposed alternativemeet the requirements of 10 CFR 50 Appendix B, Section II (Quality AssuranceProgram)?

Dominion Response

The alternative has been revised to state the qualification requirements forpersonnel who are not certified using the levels of qualification designated inAppendix 2A-1. These changes have been reflected in DOM-QA-1, subsection2.5.5 (Enclosure 2) and 6.2 of Appendix C. The revised alternative is as follows:

In lieu of being certified as Level I, II, or III in accordance with NQA-1-1994,personnel performing operations phase independent quality verificationinspections, examinations, measurements, or tests of material, products, oractivities will be required to possess qualifications equal to or better than thoserequired for performing the task being verified. The verification shall be within theskills of these personnel and/or is addressed by procedures. These individualswill not be responsible for the planning of quality verification inspections and tests(i.e., establishing hold points and acceptance criteria in procedures, ordetermining who will be responsible for performing the inspections), evaluatinginspection training programs, or certifying inspection personnel.

This alternative meets the requirements of 10 CFR 50, Appendix B, Criterion II,by requiring training and qualification of personnel that assures suitableproficiency in the skills necessary to perform quality verification inspections andtests is achieved and maintained. The individuals qualified in accordance withthis alternative participate in an accredited SAT-based training program thatmeets 10 CFR 50.120.



This alternative is similar to the qualification requirements documented in thebasis for the Nuclear Management Company Quality Assurance Topical Report(NMC QATR) Exception A.5 for NQA-1-1994, Supplement 2S-1 in Enclosure 3 ofthe NMC letter dated March 31, 2003 (ML033070161). The NMC QATR providesthe minimum qualifications of the inspector conducting inspections, examinationsor tests that are in the same organization as that which performed the work. Theapproval for this alternative was originally addressed in a letter from NRC RegionIII to Consumers Power Company, Docket Nos. 50-155 and 50-255, datedFebruary 27, 1992. The basis for the Dominion change is equal to that indicatedin the NMC alternative in that (1) the same level of qualification is required,(2) the personnel will be required to have the necessary skills and/or have theverification requirements specified in procedures, and (3) where the workinvolves the breaching of a pressure boundary, additional assurance of thequality of work can be obtained through a functional test (addressed inDOM-QA-1, subsection 10.2). The inspection planning process, performed bypersonnel qualified in accordance with Dominion’s commitment to NQA-1-1994,Supplement 2S-1 and Appendix 2A-1, takes the above three factors into accountby establishing who will be responsible for performing the inspection. If the abovethree factors can not be met, the inspection responsibility would be assigned topersonnel qualified in accordance with the commitment to NQA-1-1994.

To further clarify this alternative, the information regarding the use of a qualifiedengineer for certain inspection activities is being stated as a separate alternativein DOM-QA-1, subsection 2.5.5 and in item 6.2 of Appendix C.

NRC Question 3

In attachment 2, page 8 describes an alternative to NQA-1-1994 Appendix 2A-1.The alternative to the education requirement of a high school graduation isproposed to be satisfactory demonstration of reading, writing, and mathematicalskills through completion of an NANT accredited training development programor an approved inspector training program for nuclear facility personnel. Providethe justification for this proposed alternative. Specifically, how is the proposedalternative equivalent to the education and experience qualifications described insection 3.1 of NQA-1-1994 Appendix 2A-1 for Level I inspectors and testpersonnel?

Dominion Response

After further evaluation of the quality verification inspection/test programs,Dominion has determined that this alternative is no longer needed and will deleteit from its QA program.




Attachment 3 contains the ANSI N45.2 requirements that are addressed byNQA-1-1994 standards and/or the new QA topical report.

NRC Question 1

ANSI N45.2.12 section 4.3.2.7 states that specific attention should be given tocorrective action on program deficiencies identified during previous audits. In thecomments section of page 21 of 22 (Audits), it states that this requirement is notaddressed in NQA-1 and that “corrective action is an element evaluated in eachaudit as stated in the NFQAPD, Appendix C.” Neither the NFQAPD nor AppendixC of the NFQAPD address this requirement. Provide an explanation as to howthis requirement is met in the proposed NFQAPD.

Dominion Response

The reference to Appendix C in the table is in error. The correct reference is toSection 18 of the QAPD. In particular, subsection 18.3 addresses auditing andfollow-up of corrective actions for programmatic deficiencies.


Attachment 4 contains the ANSI N18.7 requirements that are addressed byNQA-1-1994 standards and/or the new QA topical report.

NRC Question 1

ANSI N18.7 section 2.2 Glossary of Terms contains the following terms:operational phase, surveillance testing, and system. Attachment 4 states thatthese definitions are contained in the NFQAPD, Appendix D. However, AppendixD does not contain these definitions.

Dominion Response

This appears to be a clerical error. Dominion’s master copy of Appendix D, keptas a separate document, contained those definitions. However, the copy that wasappended to the submittal document does not contain all the definitions.DOM-QA-1, Appendix D, (in Enclosure 2) has been modified to include themissing definitions.



NRC Question 2

ANSI N18.7 Section 5.2.2 Procedure Adherence discusses temporary changeswhich do not change the intent of the approved procedure. Attachment 4 statesthat this information is located in NFQAPD Section 6. However, Section 6 doesnot discuss temporary changes to approved procedures. Specify where thisinformation is located.

Dominion Response

The paragraph that contained the referenced information was inadvertentlydeleted during the last revision of this section. Section 6.4 of DOM-QA-1(Enclosure 2) has been modified to correct the error.

NRC Question 3

ANSI N18.7 section 5.2.9 discusses plant security and visitor control. Attachment4 states that “administrative controls are established through the securitymeasures required by regulation (10 CFR 73) and NRC orders. These regulatoryrequirements have superceded the requirements of ANSI N18.7.” However,NFQAPD section 5.4 item (3) is a restatement of ANSI N18.7 section 5.2.9. If therequirements of ANSI N18.7 are superceded, why are they listed in NFQAPDsection 5.4.

Dominion Response

Through this QA program submittal, Dominion is no longer committingspecifically to ANSI N18.7-1976, however Dominion is still committed to haveand control, procedures of the type that are described in Appendix A ofRegulatory Guide 1.33, Revision 2, which includes administrative procedures forSecurity and Visitor Control. ANSI N18.7-1976 did provide some generaldiscussions of procedures for security and these have been incorporated withinthe NFQAPD because they do not conflict with any regulatory requirements. Thisensures appropriate control of the procedures in accordance with RegulatoryGuide 1.33, Revision 2. However, the commitment stated withinANSI N18.7-1976 to follow the guidance and provisions of ANSI N18.17-1973 isnot being carried forward since that information has been superceded by theregulations.



North Anna and Surry

NRC Question 1

Section 17.2.1.2D.3.c describes the function of the Manager NuclearEngineering. Where is this function located in the proposed NFQAPD?

Dominion Response

That position responsibility is described under the broader managementresponsibility contained in 1.2.4.1, Nuclear Engineering, of the NFQAPD. Thiswas necessary because there are some differences in the specific organizationalstructure within the Nuclear Engineering organizations for each site. However,the responsibilities are retained within the Nuclear Engineering organization andare described within the Engineering administrative procedures for the respectivegroups.

Millstone

NRC Question 1

Section 1.3.9 of the current Millstone QA Program states that Unit No. 2 NuclearOperations is responsible for operations regarding the Millstone Power Station,Unit No. 1 Spent Fuel Pool Island and auxiliary systems. Section 1.2.3.a of theproposed NFQAPD states that “the staff for operating units may be responsiblefor activities related to a decommissioned unit’s spent fuel pool and auxiliarysystems,…” The proposed NFQAPD is no longer specific as to who isresponsible for Millstone Power Station, Unit No. 1 and it could be assumed thatoperators at other operating facilities may have that responsibility. In addition, nobasis for the change for the change was provided. Provided the basis for thechange and justification for the applicability to the North Anna and Surry facilities.

Dominion Response

It was not the intent to allow other operating facilities to be responsible forMillstone Unit 1. Therefore, DOM-QA-1, Subsection 1.2.3.a (Enclosure 2), hasbeen modified to appropriately address the specific responsibilities of MillstoneUnit 2 staff for Millstone Unit 1 spent fuel pool and auxiliary systems.

NRC Question 2

Section 1.3.13 of the current Millstone QA program list the radiological protectionresponsibilities which includes “maintaining records and reports on radioactivecontamination levels.” This responsibility is not listed in section 1.2.3.2.b of the



proposed NFQAPD. Since 1.2.3.2.b is the same wording as section 1.3.13,explain why this responsibility is no longer listed.

Dominion Response

There are a number of other required records and reports that the RadiationProtection (RP) organization is responsible for that were not previously listed inthe QA program. However, regulations and other commitments, such asinsurance requirements, establish what records and reports must be generated.The proposed QA program states in 1.2.3.2.b that the RP organization isresponsible for “maintaining required records in accordance with federal andstate codes.” Though not to the same level of detail, the responsibilities are thesame and would include records of contamination levels that are determinedthrough the responsibilities stated earlier in the sentence.

NRC Question 3

Section 2.1 of the current Millstone QA Program states that the “QAP applies toother quality programs including Anticipated Transient Without Scram (ATWS)Quality Assurance that is applicable to Millstone Power Station, Unit No. 2only…. And to Electrical Equipment Qualification (EEQ), as defined by companycommitments.” Basic Requirement 2 of NQA-1-1994 states that the programshall identify the activities and the items to which it applies. However, section 2.2of the proposed NFQAPD does not list the above programs as being applicable.Specify the current commitments with regards to ATWS Quality Assurance andEEQ.

Dominion Response

EEQ and ATWS quality assurance for the power stations are covered by theproposed QA program through the facility listing of SSCs (currently referred to asMEPL at Millstone and Q-List or EDS at North Anna and Surry). These lists takeinto account the quality requirements based on the importance to safety of theitem. Section 2.4 of the proposed QA program discusses these programs. Theyare further described in the applicable facility’s FSAR/UFSAR.

The programs controlling the SSC listing include addressing 10 CFR 50.49requirements. In addition, NQA-1-1994, Subpart 2.4 (ANSI/IEEE Std. 336-1985),Installation, Inspection, and Testing Requirements for Power, Instrumentation,and Control Equipment at Nuclear Facilities, considers the need to addresselectrical equipment qualification for the environment to which it is subjected. Toclarify, the quality assurance measures applied meet the guidance of RegulatoryGuide 1.97. A reference to that guide is included in the commitments ofAppendix C to DOM-QA-1 (Enclosure 2).



The ATWS items, although not required to meet the 10 CFR 50, Appendix Bquality assurance program, are addressed through the existing procedures andpractices (e.g., design control, procedures, procurement control, independentverifications (by line personnel), and special process controls) that the facilitiesalready have in place. To clarify, the quality assurance measures applied meetthe guidance of Generic Letter 85-06. A reference to that generic letter isincluded in the commitments of Appendix C (Enclosure 2).

Dominion



Attachment 2

Revised Pages In Response to the NRCRequest For Additional Information

Dominion


Topical Report DOM-QA-1

Revision 0a

Final DraftRAI Response July 06, 2004April 22, 2005

iv

Table of Contents

Introduction and Policy.................................................................................................................... iIntroduction.................................................................................................................................. iPolicy .......................................................................................................................................... iiBasis........................................................................................................................................... iii

Table of Contents........................................................................................................................... iv1.0 Organization.......................................................................................................................... 1

1.1 General Description .......................................................................................................... 11.2 Responsibility and Authority ............................................................................................ 1

1.2.1 Chief Nuclear Officer ................................................................................................ 11.2.2 Nuclear Operations .................................................................................................... 21.2.3 Facility Operations..................................................................................................... 21.2.4 Engineering Services ................................................................................................. 41.2.5 Support Services ........................................................................................................ 61.2.6 Nuclear Oversight ...................................................................................................... 7

1.3 Succession of Responsibility for Overall Plant Operation................................................ 81.4 Organization Charts .......................................................................................................... 81.5 Quality Standards Commitment........................................................................................ 8

2.0 Quality Assurance Program .................................................................................................. 92.1 General Description .......................................................................................................... 92.2 Applicability...................................................................................................................... 92.3 Oversight of the Quality Program Implementation......................................................... 102.4 Identification of Structures, Systems, and Components (SSC) ...................................... 102.5 Selection, Training, and Qualification of Personnel ....................................................... 10

2.5.1 Operating Facility Staff............................................................................................ 112.5.2 Support Organizations ......................................................................................... 13122.5.3 Quality Assurance Verification Personnel............................................................... 132.5.4 Quality Assurance Audits ........................................................................................ 132.5.5 Quality Control Verification .................................................................................... 132.5.6 Non-Destructive Examination Technicians ............................................................. 142.5.7 ASME Code Visual Examinations .......................................................................... 14

2.6 Control of Activities ................................................................................................... 15142.7 Quality Standards Commitment.................................................................................. 1514

3.0 Design Control .................................................................................................................... 153.1 General Description ........................................................................................................ 153.2 Design Control Program ................................................................................................. 15

3.2.1 Design Change Control........................................................................................ 16153.2.2 Design Interface Control...................................................................................... 16153.2.3 Design Verification.............................................................................................. 16153.2.4 Software Design and Control................................................................................... 16

3.3 Quality Standards Commitment...................................................................................... 164.0 Procurement Document Control ......................................................................................... 16

4.1 General Description ........................................................................................................ 16

v

4.2 Preparation, Review, and Approval of Procurement Documents ............................... 17164.3 Quality Standards Commitment...................................................................................... 17

5.0 Instructions, Procedures, and Drawings ............................................................................. 175.1 General Description ........................................................................................................ 175.2 Procedure Adherence .................................................................................................. 18175.3 Procedure Content....................................................................................................... 18175.4 Types of Procedures and Instructions ............................................................................. 185.5 Quality Standards Commitment...................................................................................... 22

6.0 Document Control........................................................................................................... 23226.1 General Description .................................................................................................... 23226.2 Applicability.................................................................................................................... 236.3 Document Review and Approval .................................................................................... 236.4 Additional Operations and Decommissioning Phase Review Requirements ............. 24236.5 Distribution of Controlled Documents............................................................................ 246.6 Quality Standards Commitment.................................................................................. 2524

7.0 Control of Purchased Material, Equipment, and Services .............................................. 25247.1 General Description .................................................................................................... 25247.2 Selection of Suppliers ................................................................................................. 25247.3 Conformance of Items and Services ............................................................................... 257.4 Quality Verification .................................................................................................... 26257.5 Quality Standards Commitment.................................................................................. 2625

8.0 Identification and Control of Materials, Parts, and Components ....................................... 268.1 General Description ........................................................................................................ 268.2 Quality Standards Commitment.................................................................................. 2726

9.0 Control of Special Processes........................................................................................... 27269.1 General Description .................................................................................................... 27269.2 Qualification of Special Processes Personnel, Procedures and Equipment .................... 279.3 Quality Standards Commitment...................................................................................... 27

10.0 Inspection...................................................................................................................... 282710.1 General Description .................................................................................................. 282710.2 Inspection Program ................................................................................................... 282710.3 Inspector Qualification.............................................................................................. 292810.4 Quality Standards Commitment................................................................................ 2928

11.0 Test Control .................................................................................................................. 292811.1 General Description .................................................................................................. 292811.2 Test Procedures ......................................................................................................... 302911.3 Evaluation of Test Results ............................................................................................ 3011.4 Scheduling..................................................................................................................... 3011.5 Quality Standards Commitment................................................................................ 3130

12.0 Control of Measuring and Test Equipment................................................................... 313012.1 General Description .................................................................................................. 313012.2 Installed Instrument and Control Devices..................................................................... 3112.3 Quality Standards Commitment.................................................................................... 31

13.0 Handling, Storage, and Shipping .................................................................................. 323113.1 General Description .................................................................................................. 323113.2 Special Handling, Storage, Shipping, Cleaning and Preservation Requirements......... 32

vi

13.3 Quality Standards Commitment.................................................................................... 3214.0 Inspection, Test, and Operating Status ......................................................................... 3332

14.1 General Description .................................................................................................. 333214.2 Control of Systems and Equipment for Operating Facilities ........................................ 3314.3 Quality Standards Commitment.................................................................................... 34

15.0 Nonconforming Materials, Parts, or Components ............................................................ 3415.1 General Description ...................................................................................................... 3415.2 Nonconformance Responsibilities ............................................................................ 353415.3 Nonconformance Documentation ............................................................................. 353415.4 Quality Standards Commitment.................................................................................... 35

16.0 Corrective Action.............................................................................................................. 3516.1 General Description ...................................................................................................... 3516.2 Corrective Action Documentation ............................................................................ 363516.3 Follow-up.................................................................................................................. 363516.4 Quality Standards Commitment.................................................................................... 36

17.0 Quality Assurance Records............................................................................................... 3617.1 General Description ...................................................................................................... 3617.2 Records of Activities..................................................................................................... 3617.3 Record Storage.......................................................................................................... 373617.4 Quality Standards Commitment.................................................................................... 37

18.0 Quality Assurance Audits ............................................................................................. 383718.1 General Description .................................................................................................. 383718.2 Audit Scope............................................................................................................... 383718.3 Audit Responsibilities and Procedures ......................................................................... 3818.4 Supplier Quality Assurance ...................................................................................... 393818.5 Internal Audits........................................................................................................... 393818.6 Quality Standards Commitment.................................................................................... 39

Appendix A.................................................................................................................................... ACorporate and Technical Support ................................................................................................... 1Operating Facility Organization ..................................................................................................... 2Operating Facility Staff Reporting To Support Organizations ....................................................... 3Appendix B .....................................................................................................................................B

Management and Independent Review Activities ...................................................................... 11.0 General .............................................................................................................................. 12.0 Qualifications .................................................................................................................... 13.0 Management Safety Review Committee (MSRC)............................................................ 2

3.1 Review Responsibilities................................................................................................ 23.2 Composition.................................................................................................................. 23.3 Alternates ...................................................................................................................... 23.4 Meeting Frequency ....................................................................................................... 23.5 Quorum ......................................................................................................................... 33.6 Records ......................................................................................................................... 3

4.0 Facility Safety Review Committee ................................................................................... 34.1 Composition.................................................................................................................. 34.2 Alternates ...................................................................................................................... 34.3 Meeting Frequency ....................................................................................................... 3

vii

4.4 Quorum ......................................................................................................................... 34.5 Responsibilities ............................................................................................................. 44.6 Authority....................................................................................................................... 54.7 Records ......................................................................................................................... 5

5.0 Independent Nuclear Safety Review................................................................................. 55.1 Function ........................................................................................................................ 55.2 Composition.................................................................................................................. 55.3 Responsibilities ............................................................................................................. 65.4 Authority....................................................................................................................... 65.5 Records ......................................................................................................................... 6

Appendix C .....................................................................................................................................CRegulatory Guides and Quality Standards Commitments .......................................................... 1

1. Regulatory Guide 1.8, Revision 1-R (Reissued May 1977) .............................................. 12. Regulatory Guide 1.8, Second Proposed Revision 2, (September 1980) .......................... 23. Regulatory Guide 1.8, Revision 3, May 2000.................................................................... 34. Regulatory Guide 1.26, Revision 3, February 1976 .......................................................... 45. Regulatory Guide 1.28, Revision 3, August 1985 ............................................................. 46. ANSI/ASME NQA-1-1994................................................................................................ 57. Regulatory Guide 1.29, Revision 3, September 1978........................................................ 88. Regulatory Guide 1.33, Revision 2, February 1978 .......................................................... 89. Regulatory Guide 1.36, Revision 0, February 1973 .......................................................... 910. Regulatory Guide 1.54, Revision 0, June 1973 ............................................................ 10911. Regulatory Guide 1.152, Revision 1, January 1996 ....................................................... 1012. Regulatory Guide 1.143, Revision 2, November 2001................................................... 1013. Regulatory Guide 4.15, Revision 1, February 1979 ....................................................... 1014. Regulatory Guide 7.10, Revision 1, June 1986 .............................................................. 1015. Generic Letter 89-02/EPRI-NP-5652.......................................................................... 111016. Branch Technical Position ASB/CMEB 9.5-1................................................................ 11

Appendix D.................................................................................................................................... DTerms and Definitions ................................................................................................................ 1

Appendix E .....................................................................................................................................EAdditional QA Records Requirements for Operating Facilities ................................................. 1


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decommissioning of Dominion’s nuclear facilities. The CNO establishes the Company’s qualityassurance policy and provides guidance regarding its implementation. The CNO has theauthority to resolve disputes related to implementation of this QAPD for which resolution is notachieved at lower levels within the organization. There are four functional organizationsreporting to the CNO that affect the safety of the nuclear facilities: operations, engineering,support services, and oversight.

1.2.2 Nuclear Operations

An executive management position is responsible for overall operating activities of theCompany’s nuclear facilities. This executive is responsible for implementing the qualityassurance program during operating activities, including related decommissioning activities.

1.2.3 Facility Operations

An executive management position is responsible for operations of their assigned Companynuclear facilities. The necessary responsibility and authority for the management and direction ofall activities related to the safe and efficient operation and decommissioning has been delegatedby the senior executives. This responsibility includes ensuring quality through implementation ofthis QAPD in all the activities related to operation such as maintenance, testing, start-up andshut-down, refueling, fuel storage, and modification.

1.2.3.1 Facility Operations and Maintenance

A senior management position is responsible for safe operations and maintenance of theirassigned nuclear facilities including those activities necessary for safe storage and handling ofspent nuclear fuel during decommissioning. The position responsibilities include: directing theoperations, maintenance, planning, and site services groups; implementing facility modifications;and maintaining compliance with requirements of the operating license, TechnicalSpecifications, and applicable federal, state, and local laws, regulations, and codes.

1.2.3.1.a Operations

Operations is responsible for operating the facility in accordance with the applicable license,including those in a decommissioning phase that still contain nuclear fuel. Overall facilityoperation is directed by a management position responsible for Operations activities.

Operations activities include monitoring and controlling day-to-day operation of the nuclearfacility; responding to alarms; manipulating facility equipment; coordinating facility operationsto manage work such as maintenance, testing, and modifications; and moving nuclear fuel. TheOperations organization contains supervision and staff for shift operations, including shiftmanagers, unit supervisors, licensed control room operators, and non-licensed operators.

The staff for operating units, when approved by the NRC and documented in this QAPD, may beresponsible for activities related to an adjacent decommissioned unit’s spent fuel pool andauxiliary systems, providing that the transfer of responsibility does not impact the capability to


3 Revision 0a

perform their operating duties, including day-to-day functions, and accident and transientmitigation. Minimum shift composition will be in accordance with the nuclear facility’sTechnical Specifications. Specifically, the following allowances are approved:

Millstone Unit 2 Operations is responsible for operations regarding the Millstone Unit 1Spent Fuel Pool Island and auxiliary systems.

1.2.3.1.b Maintenance

Maintenance is responsible for directing and coordinating facility maintenance activitiesincluding on-line maintenance, installation, maintenance, alterations, adjustment and calibration,replacement and repair of plant electrical and mechanical equipment, and instruments andcontrols. The responsibilities include performance of surveillances required by TechnicalSpecifications, establishing standards and frequency of calibration for instrumentation andcontrol devices, and ensuring instrumentation and related testing equipment are properly used,inspected and maintained.

1.2.3.1.c Outage & Planning

Outage & Planning is responsible for planning and scheduling online-maintenance and outageactivities.

1.2.3.1.d Site Services

Site Services is responsible for facility project support, including project construction and projectcontrols.

1.2.3.2 Facility Safety & Licensing

A senior management position is responsible for ensuring that facility safety and licensingrequirements are implemented. This position is responsible for directing and coordinatingradiological protection and assessment of nuclear safety issues at the facility, includingindependent review functions through the facility safety review committee and the independentnuclear safety review group. The responsibilities also include managing licensing activities;interfacing with corporate management on operating experience and licensing issues, managingfacility procedures, controlling documents and records at MPS, and administering the facilityenvironmental compliance program in VA. This position is independent of cost and schedulingconcerns associated with operations, maintenance, and modification activities. This position hasthe authority to suspend unsatisfactory work and control further processing or installation of non-conforming materials. The authority to stop work delegated to quality control inspectionpersonnel is delineated in procedures.

1.2.3.2.a Organizational Effectiveness

Nuclear Organizational Effectiveness is responsible for the corrective action program, theoperating experience program, and the independent nuclear safety review group that includes the


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2. Dedicated STA: Must meet the STA training criteria of NUREG-0737, Item I.A.1.1,and have received specific training in plant design, and response and analysis of theplant for transients and accidents.


Unit No. 3, then the operations manager shall have held a senior reactor operatorlicense at a pressurized water reactor, and the assistant operations manager shall holda senior reactor operator license for Millstone Unit No. 3.

2. The Shift Technical Advisor shall have a bachelor’s degree or equivalent in ascientific or engineering discipline and shall have received specific training in theresponse and analysis of the unit for transients and accidents, and in unit design andlayout, including the capabilities of instrumentation and controls in the control room.

2.5.1.2 North Anna and Surry Power Stations

These qualification requirements apply to the power stations and their associated IndependentSpent Fuel Storage Installations. Each member of the facility staff shall meet or exceed theminimum qualifications of ANS-3.1 (12/79 Draft) for comparable positions except that theRadiological Protection Manager shall meet or exceed the qualifications of Regulatory Guide1.8, September 1975. The following additional unit specific requirements will be maintained:

North Anna Power Station1. The individual filling the role of operations manager and the individual filling therole of operations middle manager (supervisor shift operations) will meet the licenserequirements of North Anna Units 1 and 2 Technical Specification 5.2.2.e.The ShiftManager (SS), Unit Supervisor (Assistant SS), Control Room Operator-Nuclear, and theindividual providing advisory technical support to the unit operations shift crew, shallmeet or exceed the minimum qualifications of 10 CFR 55.59(c) and 55.31(a)(4).2. For the purpose of 10 CFR 55.4, a licensed SRO and a licensed RO are those

individuals who, in addition to meeting the requirements of TS 5.3.1, perform thefunctions described in 10 CFR 50.54(m).

Surry Power Station1. The individual filling the role of operations manager and the individual filling therole of operations middle manager (supervisor shift operations) will meet the licenserequirements of Surry Units 1 and 2 Technical Specification 6.1.2.2.d.The OperationsManager (Superintendent Operations) shall hold (or have previously held) a SeniorReactor Operator License for Surry Power Station or a similar design Pressurized WaterReactor plant.2. The (Supervisor Shift Operations) shall hold an active Senior Reactor Operator

License for Surry Power Station.3. Incumbents in the positions of Shift Manager (Shift Supervisor), Unit Supervisor

(Assistant Shift Supervisor) (SRO), Control Room Operator-Nuclear (RO), and ShiftTechnical Advisor (STA), shall meet or exceed the requirements of 10 CFR 55.59(c)and 55.31(a)(4).


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2.5.2 Support Organizations

Personnel performing support activities may either meet the qualification requirements ofstandards referenced above for the facility they are performing the function for, or thequalification requirements of ANSI/ANS-3.1-1993 as endorsed by NRC Regulatory Guide 1.8,Revision 3.

2.5.3 Quality Assurance Verification Personnel

Personnel performing the following quality verification activities meet the qualificationrequirements of ANSI/ANS-3.1-1993, and the applicable Regulatory Positions of NRCRegulatory Guide 1.8, Revision 3, for the activities they perform:

2.5.3.1 Management Position Responsible for Nuclear Oversight

The person filling the Management Position Responsible for Nuclear Oversight will meet therequirements of Section 4.3.7 and Regulatory Position 2.1.1.

2.5.3.2 Supervisor/Coordinator Responsible for Quality Assurance or Quality Control

The person filling the supervisor or coordinator position responsible for quality assurance orquality verification (audits, inspections and tests, and surveillances of Company or Supplieractivities, and NDE) will meet the requirements of Section 4.4.13. This position includesresponsibility for certification that personnel performing the quality assurance or qualityverification activities are qualified for their assigned tasks. For visual examinations to meet theASME code, the training group may be delegated responsibility for the certification.

2.5.4 Quality Assurance Audits

Personnel performing audits are trained and qualified in accordance with a program that meetsthe applicable requirements of NQA-1–1994, Basic Requirement 2 and Supplement 2S-3.

2.5.5 Quality Control Verification

Personnel performing quality control verification through inspection and test, or surveillanceactivities (inspectors) are trained and qualified in accordance with a program that meets theapplicable requirements of NQA-1–1994, Basic Requirement 2, Supplement 2S-1, and Appendix2A-1. The following alternatives may be applied to the qualification requirements:

(1) In lieu of being certified as Level I, II, or III in accordance with NQA-1-1994, personnelperforming operations phase independent quality verification inspections, examinations,measurements, or tests of material, products, or activities will be required to possessqualifications equal to or better than those required for performing the task beingverified; and the verification is within the skills of these personnel and/or is addressed byprocedures. These individuals will not be responsible for the planning of quality


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verification inspections and tests (i.e., establishing hold points and acceptance criteria inprocedures, and determining who will be responsible for performing the inspections),evaluating inspection training programs, nor certifying inspection personnel.TheCompany may choose to not specifically use the designations of Level I, II, and III forqualification of inspectors. However, the qualification program will ensure that onlypersonnel that meet the education and experience requirements, and have demonstratedappropriate capabilities in the inspection and test activities they are assigned will becertified and used to perform those inspections. The inspectors used in planninginspections will meet or exceed the education and experience requirements for a Level IIinspector plus have an additional three years of related inspection experience for nuclearfacilities. The inspectors used to evaluate the capabilities of other inspectors will meet orexceed the education and experience requirements for a Level II inspector plus have anadditional five years of related experience in inspection, examination, or testing activitiesfor nuclear facilities. This related experience may include ASME VT 1, 2, or 3examinations, NDE, or ASME Section XI inservice inspection or testing activities. Aqualified engineer may also be used to plan inspections or evaluate the capabilities of aninspector. The training program for inspectors will be evaluated and approved bypersonnel who meet the education, experience, and capabilities designated for a Level IIIperson specific to the discipline or a qualified engineer. For the purposes of thisalternative, a qualified engineer is one who has a baccalaureate in engineering in adiscipline related to the inspection activity (such as, electrical, mechanical, civil) and hasa minimum of five years engineering work experience with at least two years of thisexperience related to nuclear facilities.

(2) A qualified engineer may be used to plan inspections, evaluate the capabilities of aninspector, or evaluate the training program for inspectors. For the purposes of thesefunctions, a qualified engineer is one who has a baccalaureate in engineering in adiscipline related to the inspection activity (such as, electrical, mechanical, civil) and hasa minimum of five years engineering work experience with at least two years of thisexperience related to nuclear facilities.As an alternative to the education requirement ofhigh school graduation (or GED), satisfactory demonstration of reading, writing, andmathematical skills through completion of an INPO accredited training developmentprogram or an approved inspector training program for nuclear facility personnel will bedeemed equivalent.

2.5.6 Non-Destructive Examination Technicians

Personnel performing NDE are trained and qualified in accordance with a program that meets theapplicable requirements of NQA-1–1994, Basic Requirement 2 and Supplement 2S-2 except thatthe reference to SNT-TC-1A, June 1980 is changed to the qualification standard as specified inthe applicable facility’s commitment to the ASME code or other applicable code governing theactivity.

2.5.7 ASME Code Visual Examinations


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Installation, maintenance, modification, and inspection procedures include inspectionrequirements, methods, and acceptance criteria according to the established QA inspectionprogram. When a change is made to any of these inspections, the change is reviewed bypersonnel knowledgeable in QA requirements.

Documents, including procedures, programs and changes thereto are approved by responsiblemanagement or the facility safety review committee, as applicable. Where common proceduresor programs are used for multiple facilities, responsible management or the facility safety reviewcommittee from each facility must approve the procedures or programs.

6.4 Additional Operations and Decommissioning Phase Review Requirements

Procedures and programs, including subsequent changes, for operations and decommissioningphase activities are screened to determine if further regulatory evaluation is required to meet10 CFR Parts 50.59 and 72.48. Procedures and programs that are determined to require furtherregulatory evaluation are reviewed and approved by the facility safety review committee asdescribed in Appendix B, of this QAPD. The facility safety review committee may require anyprocedure, program, or changes thereto to be brought before the committee for review.

Administrative controls ensure periodic reviews are performed for procedures that have specificregulatory review requirements. Additional administrative and programmatic controls ensureprocedures are maintained current. These controls include pre-job preparation practices and theprocedural adherence policy (as discussed in Section 5). In addition, plant procedures are auditedor reviewed as part of routine Nuclear Oversight processes providing assurance that existingadministrative controls for procedure verification, review, and revision are effective in maintainingthe quality of plant procedures.

If a temporary procedure change is required, it will be reviewed and approved in accordance with(1) the applicable facility technical specification requirements, or (2) the provisions of thisQAPD when not addressed in the technical specifications. Such changes are documented and, ifappropriate, incorporated in the next revision of the affected procedure.

6.5 Distribution of Controlled Documents

Provisions ensure current documents are available prior to commencing work. Computerizedprocesses may be used to make controlled documents available to users. Where computerizeddistribution is made, administrative controls ensure that the record file for the document containsthe appropriate review and approval documentation.

Administrative controls are established to assure the timely removal and replacement of obsoleteor superseded documents in work areas with applicable revisions. The Company maintains arecord of all holders of controlled documents and drawings. An index or file of all controlleddocuments that lists the current revision or date is maintained so personnel can readily identifythe current revision.


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The initial start-up test program is planned and scheduled to permit safe fuel loading andstart-up; to increase power in safe increments; and to perform major testing at specified powerlevels. If tests require the variation of operating parameters outside of their normal range, thelimits within which such variation is permitted will be prescribed. The scope of the testingdemonstrates, insofar as practicable, that the plant is capable of withstanding the designtransients and accidents. For new facility construction, the suitability of facility operatingprocedures is checked to the maximum extent possible during the preoperational and initialstart-up test programs.

The tests are performed and results documented in accordance with applicable technical andregulatory requirements including those described in the nuclear facility Technical Specificationsand SAR. The test programs ensure appropriate retention of test data in accordance with therecords requirements of this QAPD. The personnel performing or evaluating tests are qualified inaccordance with the requirements established in Section 2 of this QAPD.

11.2 Test Procedures

Tests are conducted in accordance with approved written procedures or instructions that arebased on the applicable design requirements for the structures, systems, and components beingtested. Section 5 of this QAPD describes the requirements for test procedures. The proceduresinclude prerequisites and instructions for performing the test that ensure the item is ready fortesting, appropriate test equipment with suitable accuracy is used, and any necessary controlledenvironmental conditions are established and maintained. The prerequisites are normallycompleted prior to commencement of the test or portion of the test where they are applicable.Test procedures also identify acceptance criteria, any required inspection hold or witness points,and provisions for documenting test performance data and review of test results by appropriatemanagement. When acceptance criteria are not met, provisions are made for retest of correctedareas.

11.3 Evaluation of Test Results

The test control programs contain measures for a qualified individual or group to evaluate testresults against predetermined acceptance criteria. The acceptance status of the test isdocumented. Any deficiencies identified by the tests are documented and dispositioned inaccordance with procedures.

11.4 Scheduling

Scheduling or similar measures are used to ensure that appropriate tests are performed andevaluated on a timely basis so that the safety of the plant is never dependent on the performanceof an untested system. Preoperational tests, including start-up tests following fuel loading, aregenerally performed sequentially to demonstrate functional adequacy and are scheduled to beperformed at the time when plant conditions are appropriate for the test. Surveillance testing andinspections for operating facilities (and required operating items of facilities beingdecommissioned) are scheduled at prescribed intervals to ensure that items important to safetywill continue to operate, keeping parameters within normal bounds, or will act to put the plant in


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a closed system is required, the Company has established control measures to prevent entry ofextraneous material and to assure that foreign material is removed before the system is reclosed.

Administrative procedures require the designated operating personnel to verify that the system orequipment can be released and determine the length of time it may be out of service. In makingthis determination, attention is given to the potentially degraded degree of protection where onesubsystem of a redundant safety system is not available for service. Conditions to be consideredin preparing equipment for maintenance include, for example: shutdown margin; method ofemergency core cooling; establishment of a path for decay heat removal; temperature andpressure of the system; valves between work and hazardous material; venting, draining andflushing; entry into closed vessels; hazardous atmospheres; handling hazardous materials; andelectrical hazards.

Where temporary modifications, such as temporary bypass lines, electrical jumpers, liftedelectrical leads, and temporary trip point settings, are necessary, they are controlled inaccordance with approved documents that include requirements for independent verification. Alog, or similar documentation, is maintained of the current status of such temporarymodifications.

When systems or equipment are ready to be returned to service, designated operating personnelcontrol placing the items in service and document its functional acceptability. Attention is givento restoration of normal conditions, such as removal of jumpers or signals used in maintenance ortesting, or actions such as returning valves, breakers or switches to proper start-up or operatingpositions from "test" or "manual" positions. Where necessary, the equipment placed into servicereceives additional surveillance during the run-in period.

Independent verifications, where appropriate, are used to ensure that the necessary measureshave been implemented correctly. The minimum requirements and standards for usingindependent verification are established in Company documents.


The Company is committed to implementing an audit status control program in accordance with thequality standards described in NQA-1-1994, Basic Requirement 14.

15.0 Nonconforming Materials, Parts, or Components


The Company has established and implements administrative controls and processes that assurecontrol of nonconforming items (materials, parts, components), and services (including computercodes) to prevent their inadvertent use or installation in Company nuclear facilities. Documentsdescribe the methods for identification, documentation, segregation, review, disposition, andnotification to affected organizations of nonconforming items or services when the disposition isother than to scrap the items or services. Instructions require that the individual discovering a


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requirements of NQA-1–1994, Parts I and II. The records and their retention times are based onRegulatory Position C.2, Table 1, of NRC Regulatory Guide 1.28, Revision 3. This tableaddresses design, construction and initial start-up records and will be applied to operating anddecommissioning phase records that are similar in nature to the construction records. Additionaloperations phase records and their retention periods are identified in Appendix E to this QAPD.Where State, local or other agencies have more restrictive requirements, those requirements willbe met.

17.3 Record Storage

Implementing procedures assure that identification and retrievability of records is facilitatedthrough proper indices and an established basic filing system. Records are stored in a manner topreclude deterioration of the item. The Company’s records storage facilities are constructed,located, and secured to provide access control and fire protection measures.

Records stored electronically will follow the guidance given in the Nuclear Information andRecords Management Association (NIRMA) technical guideline, TG-15-1998, Management ofElectronic Records. Information Technology will determine appropriate media based upon dataformat and level of access required. Records originally created in hard-copy form will beretained in hard copy until such time as electronic versions of these records are created, copied,and verified as legible on two (2) independent copies of an appropriate electronic storage media.File legibility verifications will be completed on all records stored on electronic storage media byeither visually verifying the file legibility or by electronically verifying exact binary file transfer.Periodic documented media inspections to monitor image degradation will be conducted inaccordance with approved procedures that incorporate applicable media manufacturer’srecommendations. Records stored on electronic media will be refreshed or copied onto newmedia and subsequently verified if the projected lifetime of that media does not exceed theretention period of the records stored on that media.

Records originally created in electronic form may be retained in electronic form. Backup copiesof electronic records will be maintained in multiple physically independent electronic locationsuntil such time as images of these records are created, copied, and verified on two (2) copies ofan appropriate electronic storage media. The two copies of electronic storage media will then bestored in separate physical locations. These requirements meet the intent of Generic Letter 88-18,Plant Record Storage on Optical Disks, dated October 20, 1988.


The Company is committed to implementing a quality assurance records program in accordancewith the quality standards described in NQA-1-1994, Basic Requirement 17 and Supplement17S-1. The Company will also meet the NRC Regulatory Position C.2 of Regulatory Guide 1.28,Revision 3, August 1985 except that the reference to ASME NQA-1 will be to the 1994 edition.

Appendix C

1


Through this QAPD, the Company commits to compliance with the regulatory guidance andindustry standards governing quality assurance as described below along with any exceptions,alternatives, or clarifications described within this QAPD. Commitment to a particularRegulatory Guide or industry standard does not constitute commitment to Regulatory Guides orother standards that may be referenced therein; unless otherwise stated within this QAPD, thosereferenced documents are considered as guidance. When applicable, for Class 1, 2, and 3 itemscovered by Section III of the ASME Boiler and Pressure Vessel Code, the code QualityAssurance requirements are supplemented by the guidance of applicable regulatory guides andthis QAPD.

1. Regulatory Guide 1.8, Revision 1-R (Reissued May 1977)– Personnel Selection and Training

This commitment applies to the Millstone Power Station Facilities only. This RegulatoryGuide endorses ANSI N18.1-1971, Selection and Training of Nuclear Power Plant Personnel.Where these editions of the Regulatory Guide and ANSI standard are invoked by this QAPDand/or facility Technical Specifications, the Company will implement the requirements andguidance of the standard and Regulatory Guide subject to the following alternatives:

1. ANSI N18.1-1971, subsection 4.2.2, states in part “The Operations Manager shall hold aSenior Reactor Operator’s license.” The following alternative to this requirement may beused:

The provisions of the Millstone Unit 2 and Unit 3 Technical Specifications paragraph6.3.1.a.The individual filling the role of Operations Manager will meet therequirements of subsection 4.2.2, “Operations Manager” of ANSI/ANS-3.1-1993,subject to Regulatory Position C.2.5 of NRC Regulatory Guide 1.8, Revision 3. Sincethe Operations Middle Manager function is not discussed in ANSI N18.1-1971, theindividual filling this role (e.g. Supervisor Shift Operations) will meet therequirements for Operations Manager of ANSI N8.1-1971, including holding a SeniorOperator’s License.

2. ANSI N18.1-1971, subsection 4.3.1, states in part, “A Supervisor (requiring an AEClicense) shall have a minimum of a high school diploma or equivalent, and four years ofresponsible power plant experience, of which a minimum of one year shall be nuclearpower plant experience. A maximum of two years of the remaining three years of powerplant experience may be fulfilled by academic or related technical training on a one-for-one basis.” The following alternative to this requirement will be applied:

Beginning November 1, 2001, applicants for senior reactor qualification shall meet orexceed the education and experience guidelines given in Revision 3 to RegulatoryGuide 1.8. Reference license amendments 258 (MP2) and 199 (MP3).

3. ANSI N18.1-1971, subsection 4.5.1, states in part, “An operator (to be licensed by theAEC) shall have a minimum of a high school diploma or equivalent, and two years of

Appendix C

2

power plant experience, of which a minimum of one year shall be nuclear power plantexperience.” The following alternative to this requirement will be applied:

Beginning November 1, 2001, applicants for reactor qualification shall meet orexceed the education and experience guidelines given in Revision 3 to RegulatoryGuide 1.8 (May 2000). Reference license amendments 258 (MP2) and 199 (MP3).

2. Regulatory Guide 1.8, Second Proposed Revision 2, (September 1980)– Personnel Qualification and Training

This commitment applies to the North Anna and Surry facilities only. This Regulatory Guideendorses ANSI/ANS-3.1 (Draft 12/79), Qualification and Training of Personnel for NuclearPower Plants. Where these editions of the Regulatory Guide and ANSI standard are invokedby this QAPD and/or facility Technical Specifications, the Company will implement therequirements and guidance of the standard and Regulatory Guide subject to the followingalternatives:1. ANS-3.1 (Draft 12/79), subsection 4.2.2 c. for the Operations Manager Training requires

the individual filling this position to obtain and hold a senior operator license. Thefollowing alternative to this requirement will be applied:

The individual filling the role of Ooperations Mmanager and the individual filling therole of operations middle manager (supervisor shift operations) will meet the licenserequirements of North Anna Units 1 and 2 Technical Specification 5.2.2.e or SurryUnits 1 and 2 Technical Specification 6.1.2.2.d as applicable.subsection 4.2.2,“Operations Manager” of ANSI/ANS-3.1-1993, subject to Regulatory Position C.2.5of NRC Regulatory Guide 1.8, Revision 3. Since the Operations Middle Managerfunction is not discussed in ANSI/ANS-3.1 (Draft 12/79), the individual filling thisrole (e.g. Supervisor - Shift Operations) will meet the requirements for OperationsManager of ANSI/ANS-3.1 (Draft 12/79), including holding a Senior Operator’sLicense.

2. ANS-3.1 (Draft12/79), Section 4.1 addresses those circumstances where individuals donot possess the formal educational requirements specified in the standard by indicatingthat other factors should be evaluated to ensure qualified individuals fill theorganizational functions. As part of that evaluation, either of the following additionalexperience requirements may be considered equivalent to a Bachelor’s Degree:(1) Six years of applied engineering experience at a nuclear facility in the area for which

qualification is sought. In addition, experience and training requirements for thefunction shall be met as delineated.

(2) Six years of operational or technical experience/training related to engineering innuclear power. In addition, experience and training requirements for the functionshall be met as delineated.

3. ANSI/ANS-3.1 (Draft 12/79), subsection 4.4.5, Quality Assurance, identifies therequirements for professional or technical group leaders in the Quality Assurancefunction. The individuals filling this function within the Company’s Nuclear Oversightorganization will comply with the following alternative:

Appendix C

3

ANSI/ANS-3.1-1993, subsections 4.3.7, Quality Assurance, and 4.4.13, QualityAssurance or Quality Control, subject to the description of the commitment to NRCRegulatory Guide 1.8, Revision 3 below.

4. ANSI/ANS-3.1 (Draft 12/79), subsection 4.3.2.b, describes the experience requirementsfor supervisors not requiring NRC license. The following alternate experiencerequirements may be applied to personnel filling the supervisory function:

At the time of appointment to the position; the supervisor shall have 4 yearsexperience in the craft or discipline he supervises or an equivalent number of yearsnuclear plant experience in a supervisory position with a Senior Reactor Operator’slicense.

5. ANSI/ANS-3.1 (Draft 12/79), subsection 5.3.3 describes the training requirements for theShift Technical Advisor with Bachelor Degree without an NRC Senior Operator License.In lieu of the requirement of item 3) to that subsection, the following alternative may beapplied:

The Shift Technical Advisors will observe control manipulations on the simulator asappropriate.

6 ANSI/ANS-3.1 (Draft 12/79), Section 5.5 describes the retraining program requirements.The following alternative requirements will be applied for the following functionalpositions:

Requalification training requirements for Nuclear Shift Supervisor, Nuclear AssistantShift Supervisor, Control Room Operator - Nuclear, and Shift Technical Advisor areaddressed in the Technical Specifications of the individual nuclear facility.

3. Regulatory Guide 1.8, Revision 3, May 2000– Qualification and Training of Personnel for Nuclear Power Plants

This commitment applies to quality verification functions and support functions responsiblefor multiple facilities. This Regulatory Guide endorses ANSI/ANS-3.1-1993, Selection,Qualification, and Training of Personnel for Nuclear Power Plants. Where these editions ofthe Regulatory Guide and ANSI standard are invoked by this QAPD and/or facility TechnicalSpecifications, the Company will implement the requirements and guidance of the standardand Regulatory Guide subject to the following alternatives:

1. Regulatory Guide 1.8, Rev. 3, C. Regulatory Position, paragraphs 2.1.1 and 2.1.3 addressapproval by the plant manager of the equivalents for education and experience forpersonnel filling Quality Assurance functional positions. The following alternativerequirement for approval of the equivalents will be used by replacing the second sentencein each of the above paragraphs with the following sentence:

These other factors are to be evaluated on a case-by-case basis and approved anddocumented by the plant manager or the responsible executive.

Appendix C

5

6. ANSI/ASME NQA-1-1994– Quality Assurance Requirements for Nuclear Facility Applications

The Company’s quality assurance program will implement the basic and supplementaryrequirements of Part I and the requirements of Part II to the 1994 edition of NQA-1 subject tothe alternatives addressed below:

1. The Introduction to Part I of NQA-1, Section 4, and certain Subparts to Part II of NQA-1,define terms to be used with the quality assurance requirements.

Additional definitions applicable to implementation of the Company’s QualityAssurance Program are contained in Appendix D to this QAPD.

2. Supplement 2S-1, Supplementary Requirements for the Qualification of Inspection andTest Personnel will include use of the guidance provided in Appendix 2A-1 the same as ifit were a part of the Supplement. The following two alternatives may be applied to theimplementation of the requirements of this Supplement and Appendix:(1) In lieu of being certified as Level I, II, or III in accordance with NQA-1-1994,

personnel performing operations phase independent quality verification inspections,examinations, measurements, or tests of material, products, or activities will berequired to possess qualifications equal to or better than those required for performingthe task being verified; and the verification is within the skills of these personneland/or is addressed by procedures. These individuals will not be responsible for theplanning of quality verification inspections and tests (i.e., establishing hold points andacceptance criteria in procedures, and determining who will be responsible forperforming the inspections), evaluating inspection training programs, nor certifyinginspection personnel.The Company may choose to not specifically use thedesignations of Level I, II, and III for qualification of inspectors. However, thequalification program will ensure that only personnel that meet the required educationand experience requirements, and have demonstrated appropriate capabilities in theinspection activities they are assigned will be certified and used to perform thoseinspections. The inspectors used in planning inspections will meet or exceed theeducation and experience requirements of for a Level II inspector plus have anadditional three years of related inspection experience for nuclear facilities. Theinspectors used to evaluate the capabilities of other inspectors will meet or exceed theeducation and experience requirements for a Level II inspector plus have anadditional five years of related experience in inspection, examination, or testingactivities for nuclear facilities. This related experience may include ASME VT 1, 2,or 3 examinations, NDE, or ASME Section XI inservice inspection or testingactivities. A qualified engineer may also be used to evaluate the capabilities of aninspector. The training program for inspectors will be evaluated and approved bypersonnel who meet the education, experience, and capabilities designated for a LevelIII person specific to the discipline or a qualified engineer. For the purposes of thisalternative, a qualified engineer is one who has a baccalaureate in engineering in adiscipline related to the inspection activity (such as, electrical, mechanical, civil) and

Appendix C

6

has a minimum of five years engineering work experience with at least two years ofthis experience related to nuclear facilities.

(2) A qualified engineer may be used to plan inspections, evaluate the capabilities of aninspector, or evaluate the training program for inspectors. For the purposes of thesefunctions, a qualified engineer is one who has a baccalaureate in engineering in adiscipline related to the inspection activity (such as, electrical, mechanical, civil) andhas a minimum of five years engineering work experience with at least two years ofthis experience related to nuclear facilities.As an alternative to the educationrequirement of high school graduation (or GED), satisfactory demonstration ofreading, writing, and mathematical skills through completion of an NANT accreditedtraining development program or an approved inspector training program for nuclearfacility personnel will be deemed equivalent.

3. Supplement 2S-2, Supplementary Requirements for the Qualification of NondestructiveExamination Personnel, subsection 2.1 requires application of Recommended PracticeSNT-TC-1A, June 1980 Edition to NDE personnel.

The Company will implement the qualification program required by this supplementin accordance with the applicable standard for the facility’s commitment to theASME code or other applicable code governing the activity.

4. Supplement 7S-1, Supplementary Requirements for Control of Purchased Items andServices, Section 10 addresses requirements for Commercial Grade Items.

The Company will use the guidance contained in EPRI NP-5652 instead of theserequirements.

5. Supplement 10S-1, Supplementary Requirements for Inspection, subsection 3.1 addressesreporting independence and requires that inspection personnel shall not report directly tothe immediate supervisors who are responsible for performing the work being inspected.

Where quality verification inspections at operating facilities are performed by theMaintenance group, to meet the independence requirements of NQA-1, Supplement10S-1, Section 3.1, the inspectors report to the Facility Safety and Licensingorganization while performing the inspection.

6. Subpart 2.2, Quality Assurance Requirements for Packaging, Shipping, Receiving,Storage, and Handling of Items for Nuclear Power Plants, requirements will beincorporated into the Company program subject to the following alternatives:(1) For items in storage, as determined by facility management the packaging



Appendix C

11

15. Generic Letter 89-02/EPRI-NP-5652– Actions to Improve the Detection of Counterfeit and Fraudulently Marketed Products

The Company commits to use of the endorsed industry guidance regarding the selection andqualification of commercial grade Suppliers and for the dedication of commercial gradeitems used in applications that are important to safety.

16. Branch Technical Position ASB/CMEB 9.5-1– Guidelines for Fire Protection for Nuclear Power Plants

The Company commits to implementing the guidance of this Technical Position, however,application of the requirements is site specific as described in the applicable facility SAR andlicense documents. The Company QA program complies with the QA requirements describedin Position C.4.

17. Generic Letter 85-06–Quality Assurance Guidance for ATWS Equipment That is Not Safety-Related

The Company commitment to the guidance of this Generic Letter is site specific as indicatedin the SAR for the applicable facility and the facility’s response to the Generic Letter.

18. Regulatory Guide 1.97- Instrumentation for Light-Water-Cooled Nuclear Power Plants To Assess Plant and

Environs Conditions During and Following an Accident

The Company commitment to this Regulatory Guide is site specific as indicated in the SARfor the applicable facility and the facility’s response to the NRC regarding this guidance.

Appendix D

1


In addition to those terms defined in NQA-1–1994, the following definitions of terms are to beused in the context of this QAPD and activities governed by this QAPD.

Administrative Controls – Rules, orders, instructions, procedures, policies, practices anddesignations of authority and responsibility.

Experiment – Performance of those plant operations carried out under controlled conditions inorder to establish characteristics or values not previously known.

Deleterious Corrosion – corrosion that cannot be subsequently removed and that adverselyaffects form, fit, or function.

Independent Review – Review completed by personnel not having direct responsibility for thework function under review regardless of whether they operate as a part of an organizational unitor as individual staff members.

Lifetime (Records) – Lifetime in defining the retention period for records is until (1) terminationof the applicable Facility Operating License, (2) termination of employment (training andqualification records), (3) transfer of ownership (i.e., fuel), (4) end of service life of the facility,system, or component, as applicable.

MPS – Millstone Power Station.

NAPS – North Anna Power Station

Nuclear Power Plant – Any plant using a nuclear reactor to produce electric power, processsteam or space heating.

Operating Activities – Work functions associated with normal operation and maintenance of theplant, and technical services routinely assigned to the facility operating organization.

Operational Phase – That period of time during which the principal activity is associated withnormal operation of the plant. This phase of plant life is considered to begin formally withcommencement of fuel loading, and ends with plant decommissioning.

Organization, Facility Operating – Personnel concerned with operation, maintenance andcertain technical services such as reactor engineering and performance of tests/inspections. Thisorganization is also referred to in various standards as the onsite organization and comprises thefacility staff.

Organization, Support – Personnel providing support functions to the operating organizationregardless of their physical location. This organization is also referred to in various standards asthe offsite organization.

Appendix D

2

Program Deficiency – Failure to develop, document or implement effectively any applicableelement of the QA Program.

Quality Verification – The act of reviewing, inspecting, testing, checking, auditing, orotherwise determining and documenting whether items, processes, services, or documentsconform to specified requirements integral to the QA Program.

Safety Analysis Report (SAR) – This term is used generically to refer to the SAR required byNRC regulations that is applicable for the particular nuclear facility for which the activity isbeing performed. This usage includes, but is not limited to preliminary, final, updated final, anddecommissioning safety analysis reports.

Supervision – Direction of personnel activities or monitoring of plant functions by an individualresponsible and accountable for the activities he directs or monitors.

SPS – Surry Power Station

Surveillance Testing – Periodic testing to verify that safety-related structures, systems andcomponents continue to function or are in a state of readiness to perform their functions.

System – An integral part of a nuclear power plant comprising components which may beoperated or used as a separate entity to perform a specific function.

Time Intervals – With the exception of time intervals from applicable Codes or the facilityTechnical Specifications, the following definitions shall be applied for other activities and maybe extended by up to 25%:

Weekly: at least once per 7 days

Monthly: at least once per 31 days

Quarterly or every 3 months: at least once per 92 days

Semiannually or every 6 months: at least once per 184 days

Every 9 months: at least once per 276 days

Yearly or annually: at least once per 366 days

Biennial (2 years): at least once per 732 days

Triennial (3 years): at least once per 1098 days

VA – Virginia Power Stations, i.e., NAPS and SPS

Dominion



Index

Index


Subject Tab Page

ANS-3.1 (Draft 12/79) 7 2ANS-3.1-1993 7 3ANSI N18.1-1971 7 1Appendix A, Organizational Relationships of Key Management and

Functional Groups5

Appendix B, Management and Independent Review 6Appendix C, Regulatory Guides and Quality Standards Commitments 7Appendix D, Terms and Definitions 8Appendix E, Additional QA Records Requirements for Operating Facilities 9Approval Letter, NRC 1Attachment 1, NRC Request for Additional Information (RAI) Questions

with Dominion Response10

Attachment 2, Revised Pages in Response to the NRC RAI 11Audits 4 36Branch Technical Position ASB/CMEB 9.5-1 7 10Corporate and Technical Support Organizations 5 1Corrective Action 4 34Definitions 8 1Design Control 4 14Discussion of QA Requirements by 10 CFR 50, Appendix B Criteria 4Document Control 4 22Drawings 4 16Engineering Organization 4 4Facility Safety Review Committee 6 3Generic Letter 85-06 7 10Generic Letter 89-02/EPRI-NP-5652 7 10Handling 4 30Identification and Control of Material 4 25Identification of Structures, Systems, and Components 4 10Independent Nuclear Safety Review 6 5Inspection 4 26Inspection, Test, and Operating Status 4 32Instructions 4 16Introduction, Policy, and Basis 3M&TE 4 30Management Safety Review Committee, MSRC 6 2Material Identification and Control 4 25Measuring and Test Equipment Control 4 30MSRC, Management Safety Review Committee 6 2Nonconforming Materials, Parts, or Components 4 33NQA-1-1994 7 4Nuclear Oversight Organization 4 7Operating Facility Organizational Relationship 5 2Operations, Nuclear, Organization 4 2Organization Description 4 1

Index


Subject Tab Page

Organization, Corporate and Technical Support 5 1Organization, Operating Facility 5 2Organization, Operating Facility Staff Reporting to Support Organization 5 3Organizational Relationships, Functional 5Oversight of QA Program Implementation 4 10Procedures 4 16Procurement Document Control 4 15Purchased Items Control 4 24QA Audits 4 36QA Records 4 35Qualification 4 10Quality Assurance Program 4 9RAI, NRC Questions/Comments 10Records 4 35Records, Operations Phase 9 1Reg. Guide 1.143, Rev. 2, 11/2001 7 9Reg. Guide 1.152, Rev. 1, 1/96 7 9Reg. Guide 1.26, Rev. 3, 2/76 7 4Reg. Guide 1.28, Rev. 3, 8/85 7 4Reg. Guide 1.29, Rev. 3, 9/78 7 8Reg. Guide 1.33, Rev. 2, 2/78 7 8Reg. Guide 1.36, Rev. 0, 2/73 7 9Reg. Guide 1.54, Rev. 0, 6/73 7 9Reg. Guide 1.8, Rev. 1-R, 5/77 7 1Reg. Guide 1.8, Rev. 3, May 2000 7 3Reg. Guide 1.8, Second Proposed Revision 2 7 2Reg. Guide 1.97 7 10Reg. Guide 4.15, Rev. 1, 2/79 7 9Reg. Guide 7.10, Rev. 1, 6/86 7 10Response, Dominion Reply to NRC RAI 10Revised Pages 11Safety Evaluation, NRC 2Shipping 4 30Special Process Control 4 26Status Control for Inspection, Test and Operating 4 32Storage 4 30Support Services Organization 4 6Test Control 4 28Training 4 10