L-14-360, Firstenergy Nuclear Operation Company, Quality Assurance Program Manual, Revision 19

Firstenergy Nuclear Operation Company, Quality Assurance Program Manual, Revision 19

ML14339A455
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Site:	Beaver Valley, Davis Besse, Perry
Issue date:	11/24/2014
From:	FirstEnergy Nuclear Operating Co
To:	Office of Nuclear Reactor Regulation
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Text

FENOC nrc Quality Assurance Program Manual Approved By:

Beaver Valley Porver Station Units 1 8{,2 Docket Nos. 50-334 & 50-412 Operating License Nos. DPR-6 6 &, NPF-73 Davis-Besse Nuclear Porver Station Docket No. 50-346 Operating License No. NPF-3 Perry Ntrclear Poler Plant Docket No. 50-440 Operating Liceuse No. NPF-58

/1ilr-'l Date:

Vice President

- Fleet Oversight Revision: 19 I of36

FENOC Quali TABLB OF CONTENTS A.

IVIANAGBI\\,I EN'I-l.

2, 3,

4.

3.

6.

7, C.

ASSESSMENT Methodolog!'

Organization Responsibility Authority Persorrnel Training and Qualification Corrective Action Regulatory Commitments Nlethodology Design Control Dcsign Verificntion Procurenretrt Cotrtrol Procu renrent Verific ation Identification and Control of Iteltrs Handling, Storage' and ShipPing Test Control Measuring and Test Equipnrent Control Inspectiort, Test, and Operating Stattrs Special Pt'ocess Control Inspection Con'eetive Actiott Document Control Records 5

5 8

8 9

9 l0 B.

PERFORMANCE/VERIFI C ATION I,

7.

h{ethodology Audit l0 il l2 t3 l4 t4 t4 l5 l6 t7 t7 T7 t8 l8 I9 r9 20 D.

INDEPBNDENT SAF'E]'Y REVIEW

1.

Descr'iption Revision: 19 2 of36

f,FruOG f r/slFrh,.gil ryuajc..,. O*r"rrrrna Quality Assurance Program Manual IABLE OF CONTENTS (Continued)

Table 1 - Regulatory Commitnrents A,

Regulatory Guide 1.8 (Revision 1) [Septenrber 19751' Personnel Selection and Training IANSI Nl8.1]

B.

Regulatory Guidc 1.30 (Revisiort

0) lAugust 19721' Quality AssHr$fice Requiyements for the Instollntiort, I.

Regulatory Guitle 1.74 {Revisiolt 0) [F-ebruarY 19741, Quality Assuycrnce Terms and Detinitions IANSI N45.2.101 C.

D, Ii.

F, G,

I:I.

Inspectiott, und Testittg of Instrumentstiort snd Electric Equipmettl IANSI N45.2.41 Regulatory Guide 1.33 (Revision 2) [February 79781, Qanlity Assursnce Program Requirenrcnts (Operrfiiansl [ANSI N18.71 Regulatoly Guide 1.37 (Revision 0) [March 19731]

Quality Assurunce Requirements for Cleartittg of Fluid S,ys/ettts snd Associsted Cottrponents of ll/ster-Cooled Nuclesr Pox,er Plnnts IANSI N45.2.11 Regutatory Guide 1.38 (Revisiorr

2) [May 19771, Qualiry Assursnce Requirements for Prckaging, Shrpping, Receiving, Storage, and Hortdling of fiems for Water-Cooled Nuclear Power Plants IANSI N45.2.21 Regrrlatory Guide 1.39 (Revision 2) [septernber l977lt Housekeeping Requiremeuts for lYuter-Cooled Nuclear Power Plnnts IANSI N45,2.31 Regulatory Guide 1.58 (Revision 1) lsepternber 1980f '

QuuliJicqtion of Nuclesr Pov'er Plcutt hrspectiott, Examinutiott srtl Testing Personnel IANSI N45.2.61 Regulatory Guide 1.64 (Revision 2) [June 19761, Quality Assurunce Requirements for the Design of Nuclear Power Plants IANSI N45.2'l1l 24 I{evisionl 19 3 of36

FENOG f,';lf r:c'rgi' Nrr:'-.*'

"ru.ntr,,,offiQQ Quality Assurance Proglqm Manual TABLE OF CONTENf'S (Continued)

Table I - Regulatory Conttnittrrettts (Continued)

J, Regulatory Guitle 1.88 (Revisiort 2) [October 1976]'

Collectiotr, Storage snd Maintenance of Nuclesr Potver Plant Quality Assurunce Records IANSI N45.2.9f K.

Regulatory Guide 1.94 (Revision l) [April 19761, Qualit.lt Assurance Requirem ents for Instullatiott, Inspection und Testittg of Concrete and Structufal Steel During the Cortstructiott Phase of Nucleur Power Plants IANSI N45.2.5J Regulatory Guide 1.116 (Revision 0) [May 19771, Quatity Assursnce Rerluirements fot lrtstollatiort, Inspectiott snd Testirtg of Mechanical Equiprnent and

^Sysferus IANSI N45'2.81 Regrrlatory Guide 1,I23 (Revision 1) [July 19771, Quulity Assursrtce Requirements fot Control af Procurement of ltems snd Services for Nucleor Po*'er P4ants IANSf N45.2.13J Regrrlatory Guide 1.144 (Revision l) [septernber' 1980],

Auditing of Quality Assursnce Programs for Nuclear Power Plsnts IANSI N45'2.121 Regulatory Gtricle 1.146 (Revision 0) [August 19801' Qualilication of Quality Assursnce Progrsm Audit Personnel for Nucleqr Poner Plnnts IANSI N45.2'231 L.

n{,

N.

o.

30 3l 32 33 34 36 Revision: 19

FE'VOC t{tlLt:ttr)/Nrr..'e-n-f

/pirdlr:a't-"r-T.

Quality Assurance Prygl4ry Manual A.

MANAGEi\\{BNT 1.

Methodology The Quality Assurance Program Manual (QAPM) provides a consolidated oveliew of the quality program controls which govern the operation and maintenance of FirstEnergy Nuclear Operating Company's (FENOC's) quality relatecl items and activities. This includes nuclear plant and FENOC fleet locations, as well as FirstEnergy corporate locatiotts that provide safety related seruices. The QAPM describes the quality assurance organizational structure, ftinctional responsibiIities, levels of autltority, and interfaces.

The requirements ancl commitrnents contained in the QAPM are mandatory and must be implemented, enforcecl, and adhered to by all individuals and orgagizatioirs.

Employees are expected to actively participate in the continued developrnept of the QAPM as rvell as its irnplementation.

Changes are prornptly commullicated rvhen identifi ed.

T}e QAPM inrplernents l0CIrR50, Appendix B and applies to all activities associatecl with structures,

systenrs, and componsnts rvhich are saf-ety

related, T1e requirernents of the QAPM are applied to these iterns atrd activities to an extcnt com)Iensurate rvith their importance to safety.

The eApM also applies to the packaging and transportation of radioactive rvaste activities controlled by 10CFR71, as the quality assul'ance plogl'am required by

IOCFRTI, Subpart H.

The QAPM also applies to the inclependent storage of spent nuclear fuel and high-level rajioactive rvaste activities controlled by 10CFR72, as the quality assurance progratn requiled by 10CFR72, Subpart G.

The applicability of the requirements of the QAPM to othel itenrs and activities is deterrnined on a case-by-case

basis, The QAPM is implementecl through the use of approved procedtn'es ii.e.,

policies, clirectives, procedul'es, or other docunrents) u'hich provide rvritten guidapce fbr the control of quality related activities and provide fbr the ilevelopment of docurnentation to provide objective evidence of cotnpliartce.

Organization T6e organizirtional stlucture respor.lsible for in-rpletnentation of tlte QAPM is described belou,. Tlre specific organization titles for the quality assul'allce fi,tnctions described are identified in procechl'es. The authority to accomplish the quality assurauce functions a.

b.

c.

d.

e.

2.

Revision: 19 5 o f 3 6

FENOO Quality Assurance qryg1qry Manual a.

described is clelegated to the incumbent's staff as necessary to fultrll the identified responsibility.

T[e Presiclept FENOC alcl chief nuclear officer (CNO) is responsible for establishing expeclations ancl providing top level direction of all aetivities associated rvith the safe and reliable operation of FENOC's nuclear power plants and activities of corpolate functions. The FENOC President and CNO provides guiclance rvith regards to the company quality assufance policy.

1.

The executive responsible for oversight reports to the President FEG FENOC and chief nuclear officer and is responsible for the audit and assessilrent of the quality assurance proglatn of FENOC's nuclear activities, both site and corporate, and maintaining this QAPM in accordance u,ith regulatory requiremettts, This executive is also responsible for establislring the quality assurance prograrn policies, goals and objectives, for irnplenrentation of the quality asslu'ance program, and for rnaintaining the Quality Assurance Prograrn Mattual. This executive also has overall responsibility for the quality assllrance ancl independent off-site safety revierv cornmittee functions, as rvell as supplier auditing.

a)

The jndividual responsible for quality assurance repofis to the exectitive responsible fol oversight and has ovet'all autlrority and responsibility for velifying the implementation and adequacy of the quality assurance program (auditing) as described irr this QAPM. The incliviclual responsible for quality asstlrance has the authority and responsibility to report nratters directly to the prcsident and chief nrclear offiser rvhen neerled. This individual is also responsible for ttre quality control frrnction, and receipt and supplier soul'ce inspectiotts.

b)

These inclividuals above may be respotrsible for a single unit/location or for rntrltiple units/locations and rnay fttlfill more than one function desclibed. Corrvcrsely, responsibilities tnay be fulfilled by nrore tlran one inclividual, Indivicluals may be located at the nuclear plant or FirstEnergy col'porate locations.

T5e follolving nralragernent positions report to tJre President FENOC and chief nuclear officer:

I. T5e executive responsible for operations provides a singular point of conlact rvith respect to the operation of the four FENOC porvel plants, arrd provides operational oversight of the fortl'plants.

a. The executives lesponsible fol overall plant nrtclear safety and operations support at eaclr site report to the exccutive responsible for operations' b.

Revision: 19 6 of36

FENOG

,^

Quality Assurance Program Manual These executives nlay report through an additional layer of management but shall rnaintain sufficient authority and organizational freedom to implement the assigned responsibilities, These executives are responsible for establishing and iurplernenting the quality assurancs proglam at the respective site.

2. The executive responsible for engineering is responsible for providing engineering services at all sites.

3. A managernent position responsible for licerrsing and regulatory affairs.

The individuals fulfilling the following rnanagement functiorrs repott to the appropriate rnanagement position identified in Paragraphs 2.b.1.a or 2.b.2' above.

These individuals may repofi through an additional layer of managetnent but slrall maintain sufficient authority and organizational fi'eedom to implement the assigned responsibilities.

These individuals may be respotrsible for a single unitllocation or for multiple units/locations and may ftllfill ll'Iol'e than oue function described belorv. Conversely, responsibilities may be fulfilled by more than one indiviclual, The flinctions clescribed belolv may also be irnplernented by nop-FENOC organizations q,ithin the FirstEnergy Corporation

horvever, FENOC nraintains respollsibil ity and authority.

1.

Tle individual responsible for plant operations asstlres the safe, reliable, a1c1 efficient operation of the plant rvithin the coustraints of applicable regrrlatory reqnirements and the operating licetlse.

Tle inclividual restrronsible for plant ntodiflcatiou ptovides direction, control, ancl overall supclvision of the implemetrtation of piant modifi cations atrcl tlssigned tnaitttenance.

The indiviclual lesponsible tbr trairtiug provicles direction, control, and ovcrall supervision of all tlairiing of personuel required by regulatiotts.

The indiviclual responsible tbr records ruanagenrent provicles directiott, control, ancl gverall supervision of the records maltagement progfatn and associated activiti es.

The indir.'idual responsible for docutnent control provicles direction, corrtrol, atrcl overall strpervision of the document control ptogram and associated activities.

The inclivirlual responsible for the cotlective actioit progratrt provides dilectiop, coutrol, ancl overall supervisiort of tlrc corrective action prcgraln and associated activities.

2.

n-).

4.

5.

6.

Rcvision: l9 7 of36

FE'VOG firs tEne/gy,\\'dcl. OOroUnnO Quality Assurance Prograrn Manual 3.

7.

The individual responsible for engineering is responsible for the developrnent and maintenance of engineering progralns, policies, and procedures attd for providing engitteering services.

8.

The inclividual resporrsible tbr materials, purchasing, aud coutracts is responsible for supplier evaluations, procurernent,

services, receipt, storage, and issue of lnaterials, parts, and components.

d, The on-site and off-site safety review cornmittees independently revielv astivities to provide additional assurance that the units are operated and maintained in accordance lvith the Operating License aud applicable regulations rvhich addrcss nuclear safety. (Refer to Table 1, Item C.2 for additional details.)

Rcsponsibilit)'

a.

F'ENOC has the rcsponsibility fbr the scope and implementation of an eflbstive quality assurance progl atn, b,

FENOC nray delegate all or part of the activities of planning, establishing, and implementing the quality assurance program to others, but retains the respons ibi li ty for the pro gram's effecti ven es s.

c.

The adequacy of the QAPM's implernentation is cotttinually assessed by the individual(s) responsible for quality assurarlce and the associated executive for orrerall plant nuclear safety, and is reported to tlre executive responsible for' oversight and to the prcsident and chief nuclear officer.

d.

FENOC is responsible l-or ensuring that the applicable poltion(s) of the quality assurarlcc prograln is ploperly docurnented, approvecl, and irnplernented (people are trained and resources are available) before an activity rvithirr the scope of the QAPM is undefiaken by FENOC or by others.

e.

Responsi6le irrdivicluals are to erlsure that personnel rvorking utrtler their management cognizance are provided the necessal'y training and resottrces to accomplish their assigned tasks rvithin the scope of the QAPM.

f.

Procetlures that implerrerrt the QAPM are approved by the managetnent respolsible lbr the applicable quality ftinction. These procedttres are to reflect the QAPM ancl rvork is to be accomplished in accordallce rvith tlrern.

Authority

a.

When FENOC delegates responsibility for planning, establishirrg, or irlplenrenting any part of the overall QA program, stt{ficietlt atrtholity to accomplish the assigned responsibilities is delegatecl, 4.

Revision: 19 8 of36

FFfVOG Irrsf frl.'rgil il'u..'c',. O^rrrtnffifr Quaf ity Assurance Program Manual

b.

The individual responsible for quality assurallce ltas the tesponsibility and the authority to stop unsatisfactory work (including reactor operation throtrgh ploper channels) and contlol ftirther processing, delively, installation, or use of non-conforrning items or selices. Cost and schedule considerations lvill not override safety consi derations.

5, Personltel Training and Qualification Personnel assigrrcd to implement elemcuts of the quality assul'Allce prograln al'e capable of perfortning their assigrred tasks.

Training ptograltls are established and irnplemented to ensttre that personnel achieve and nraintain suitable proficiency.

Persomel training and qualification records are maitrtained in accordance with procedures, Acklitional cletails concerning personnel ttaining and qualification nray be found in the Regulatory Gtrides ancl associated Standards as committed to in Sectiorr A.? aricl 'fable 1 (e.g., Regulatory Guides 1.8, 1.58, and 1.146)'

Corrcctive Actiott It is the responsibility of each individual to promptly identify and reporl conditions adverse to quality. Mauagernettt at all levels encotlrages the identification of conclitions that are adverse to quality.

A corective action plogtaln is established and inrplemetrted that incltrdes prompt icleptification, clocurnentation, significance evaluatiotl, aud conection of conditions aclverse to quality. For significant conditions aclveme to quality, the cause is cleteurrirrecl ancl comective actiort to preclude repetition is identifiecl and tracked until it is contpleted and verified.

Specific responsibilities lvithin tlre corrective action plogranl llray be delegated, but FENOC maintains lesponsibility for the program's effectivelless.

Nolt-conforrning itelns al'e pl'operly conttolled to prevent their inadvertetlt test, iustallation, or use, Tley are reviewed and either accepted, rejected, repaircd, or reurorked.

Reports of conclitions that are adverse to quality at'e analyzeri to identify trends in quality perfonnance, Significant conditiotts adverse to quality artd significant trencls Bre l'epol'ted to the appropriate level of tnanagetnent.

A b,

d.

6.

a.

b, c.

d.

e.

Revision: l9 9 of36

FF,VCIO Quality Assurance Prograrn Manual 7,

Additional details concerning conective action activities may be found in Section B.l3 ancl the Regulatory Guides and associated Standatds as cornlnitted to irr Section A.7 and Table I (e.g., Regulatory Guides 1.33 and I,144)'

Regulntory Conrndtments Except rvhere alternatives are identified, FENOC complies with the QA guidance documents listed on Table 1. If the guidance in any of these dosuments is itt conflict with the QAPM, the guidance provided in the QAPM is the controlling guidance, Additionally, the follorving clarifications apply to all guidance documents listed in Table I :

l.

For rnoclifications aucl nonroutine maiutenance, gttidance applicable to sonstruction-like activities is applicable to comparable plant activities, except that the inspection of tnodifications, repaits, retl'otk, and replacements shall be in accordance lvith the original design and inspection recluirernetrts or a docutnented approved altetnative' The {efirritions ploviclecl by Itegulatory Guide 1.74 apply lvherever the defiped terrl is usccl in the QAPM and associated guidance documents,

3.

Clarificatiotts and alternatirres to a guidance document apply wherever the guidanee docutrtent is invoked.

ln each of the ANSI Standards, othel documents (e.g., other Standards, Codes, Rcgulations, tables, or appendices) are t'eferenced or described' These other docurnents are only quality assurance progtam requirements if explicitly committecl to in the QAPM. If not explicitly committed to, these clocurlents are not considered as quality assurance progl'am requiremettts, although they may be used as grridance' Itegulatory guidance originally intended to apply to design or constutction phase actiyities rvill be appliecl to activities during the operations phase that are coilparable in nature ancl extent to cottsttuction phase activities'

b.

The NitC is to be notifiecl of QAPM clranges in accorclance r'vith 10CFR50.5a(a).

c.

In cases rvhere license rcquirernents ciiffer fi'om the QAPM, the most stringeut lequirements apply.

PBRF'ORh{ AN CE/V ERI FI C A TI ON 1.

N{ethodolog},

2.

4.

5.

B.

Revision: l9 l0 of36

FENOG

,^ffi Quality Assurance Program Manual a.

b.

c.

Personnel perfonning u,ork activities such as design, ettgineering, ptocurement, manufacturing, constluction, instaIlation, startup, maintenance, modification, operation, and clecomrnissioning are responsible for achieving acceptable quality.

Personnel performing verification activities are responsible tbr verifying the achievement o f acceptabl e quality.

Work is accomplished and verified using instructions, procedttt'es, or other appropriate means that are of a detail commensurate with the activity's complexity and importance to safety.

Cliteria that dcfirre acccptable quality are specified, and quality is verified agairrst these criteria.

d.

2.

Design Control a.

The design control proglarn is established and irnplemented to assure that the activities associated with the design of systems, components, sttuctures, and eqgipmelt and rnodifi.cations thereto, al'e executed in a plamed, controlled, and orderly manner.

Tfue pragtam irrclucles provisions to control design inputs, pl'ocesses,

outputs, chauges, interfaces, records, atrd organizational interfaces.

Design ilputs (e.g., perforrnance, regulatory, quality, and quality verilication requirements) are to be correctly translated into design orttpttts (e.9.,

specifi cations, dra,,vings, procedures, atld instructions).

The final design output is to relate to the design input in sutficient detail to per:rnit verification.

The desigtl process is to ensut'e that itenrs and activities are selected and ildepenclently velifiecl consistent with tlreir itnportauce to safety to ensure they are suitable for their intended application, Changes to final designs (including field chatrges and modifications) and clispositions of non-conforming itenr.s to either use-as-is or repair are to be subjectecl to <lesig1 control lneasures cornnlensurate lvith those applied to the origiual design and approved by the orgatrizatiorr that perfouned the original design or a qualified clesignee.

llterface eorrtrols (internal and external betlveeu participating design o;ganizatiols ancl across technical disciplines) fbr the ptllpose of developing, b.

c.

d.

Revision: l9 11 of36

FENOG f r.'S lfi't rg). r\\ir /e.a. OO.n *ra*

Quality Assurance Program Manual reviewing, appt'oving, releasing, distributing, and revising design inputs and outputs are defined in procedures.

Design documentation arrd records, whiclr provide evideuce that the design and design verification plocess was perfonned in accordance with this proglam, shall be collected, stored, and maintairred in aceordance with documented procedures.

This tlocurnentation includes final design documents, such as drawings and specifications, and revisions tlrereto and docunrentation which identifies tire important steps, includiug sources of design inputs that support the final design.

Adclitional details concelning design control activities may be fbund in the Regulatory Cuicles ancl associated Standards as comtnittecl to in Section A.7 and Table 1 (e,g., Regulatory Guide 1.64).

Design Verification A program is established ancl irnplemented to verify the acceptability of design uriiuiti"* and documents for the design of items, The selection and incorporation of clesign inputs ancl design processes, outputs, and changes are verified' Verification methocls inclucle, but are not limited to, design revieu's, altemative calculations, and qualification testing. The extent of this verification will be a fi.lnctio1 of the importance to safety of the item, the cornplexity of the design, the degree of stanclardization, the state of the art, atrd the sirnilariiy rvith previously prou*,r designs. Stanclardized or previor.tsly proveu designs rvill be revie$'ed for applicability prior to use.

Whep a test progranr is usecl to verify the acceptability of a specific design feature, the test program is to demonstrate acceptable perfonnallce under corrclitions that simulate the most adverse design cor-rditions that are eKpected to be encouutered, Indepeldent tiesign verification is to be completed betbre design outpttts are used by oiher organizations tbr design u,ork and before they are used to support other o"tiuiti.r such as procurement, nranufacture, or coustructiott. trVhen this timing ca6ot be aclieved, the unverified portion of the design is to be identified and contr.ollecl, Irr all cases, the design verification is to be completed before relying ou the itetn to perfotrn its fitrtction.

Ilclividuals or grol.]ps responsible for design reviervs or other verification activities shall be iclentifiecl in procedures and their authority and responsibility shall be defined ancl controlled, Desigrr verif-ication shall be perfonnecl by any competent inclividuals or groups other than those u4ro perfonned the original h,

3.

a.

b.

c.

d.

Revision: l9 12 of36

FFruSG Frrslfrc'tg/ i\\'.Jcleat O'n'r^r* m\\

Quality Assurance Program Manual clesign but who rnay be fi'om tlre same organization.

The designer's irnrnediate supervisor may perfornr the design verification provided: the supervisor is the only teclinically qualified individual capable of perforrning the verification, the nced is inclividually docuntented and approved in advattce by the supetvisor's rnanagement, and the frequency and effectiveness of the supelisor's use as a design verifier are independently verified to guard against abuse.

Design rrerification procedutes are to be established and irnplemented to ensure that an appropriate verification method is used, the appropriate design pararneters to be verified are chosen, the acceptance criteria are identified, the verification is satisfactorily accomplished, and the results are properly recorded.

Adclitional details concerning design verification activities may be found in the Regulatory Cuicles and associated Standards as committed to in Section A,7 and Table I (e.g., Regulatory Guide 1.64).

4.

Procureltreut Control lr.

A program is establishecl and implemented to ensure that purchasecl items atrd serices are of acceptable quality.

The prog'am inchrcles provisions for evaluating prospective suppliers attcl selecting only qualifi ed snppliers.

The program inclucles provisions for ensuring that qualifred suppliers cotltitrue to plovide acceptable products atrd seryices' The program inclucles provisions (e.g., sollrce verification, receillt inspection, pre-installation and posrinstallation tests, and certificates of confotrnance) for accepting purchasecl iterns and seryices' Applicable teslurical, regnlatory, aclrninistt'ative, and reporling requiremettts

(".g., specifications, codes, stanclarcls, tests, inspectiotrs, special processes, atrcl 10CFR2l ) are invoketl for procuretnent of items and selices.

The progr.arn inclndes provisions for ensuling that docutnented eviclence of an itepris confonnance [o procrlrernent lequirenrents is available at the site before the iterp is placed i1 service or used unless othenvise specified in procedures.

The prog1am inclucles provisions fbr ensuling that procuremetrt, inspection, and test requirernents have been satisfiecl befole an iten is placecl in service or used unless othct'u'ise specified in procedures.

-l'he procurement of conrponents, including spare ancl replacemetrt pafis, is subject to quality and tecllrical requircrnents suitable for their intended sert'ice.

a.

b.

c.

d.

Il.evision: l9 13 of36

FEffOC FrrslFaergy rYrrle". Op.rr"n *n Quality Assuranee ProgrSm Manual Appropriate controls for the selection, detenninatiott of suitability for intended use (critical characteristics),

evaluation, teceipt, and quality evaluation of col'nmercial glade items are to be irnposed to ensure that the items rvill perform satisfactorily in sewice.

Aclditional details concerning procurernent control may be found in the Regulatory Guides ancl associatecl Standards as committed to in Section A,7 and Table I (e.g., Regulatory Guides 1.33 and 1.123).

Pro curernent Verific atiolr A program is establishecl and irnplenrented to verify the quality of purchased items and services at intewals and to a depth consistent with the itetrr's or senrice's inpofiance to safety, cornplexity, and quantity and the frecluency of procurernent.

The prograrn is executed in all phases of procurement.

As necessary, this may require verification of activities of suppliers below the first tier.

Additional cletails concerning proclx'ement verification lnay be found in the Regulatoly Guides ancl associated Standards as committed to in Section A.7 and Table 1 {e,g., Regulatory Guides 1.123 ancl L144).

Identificatiott and Cotrtrol of Iterus

a.

A prograrn is establishecl and implenrented to identify and control itenrs to prevent the use ol'itrcotlect or defective ifetns' Iclentification of each item is rnaintained throughout fabrication, erection, installation, ancl use so that the itern can be traced to its documetrtation' Traceability is maintained to an extent consistent rvith the item's importance to safety.

Aclditional cletail.s concerning iclentification and control of itetls may be found in the Regulatory Guicles ancl associated Standarcls as corrlrnitted to in Section A'7 and Table I (e.g., Regrrlatoly Gtride L33).

Handling, Storage, ancl Shiglpittg

a.

A progran is established ancl irnplenrented to control the handling, storage, shipping, cleaning, ancl irleserving of items to etrsttre the iterns maintain acccptable quality.

5.

6.

a.

b, c.

b, c.

7 Rcvision: 19 l4 of 36

FENOG Quality Assurance Progr?ry Manual Special protective lneasures (e.g., contairters, shock absorbers, accelerotneters, inert gas atmospheres, specific moisfure content levels, and temperature levels) are specified and provided when required to rnaintain acceptable quality.

Speci{ic procedures are developed and used tbl cleaning, handling, storage, packaging, shipping, and preserving iterns rvlten required to rnaintain acceptable quality.

Iterns are marked ancl labeled cluring packaging, shipping, handling, and storage to identify, maintain, arrd preserve the items'integrity and indicate the need for special cotttrols.

Additional details concerning lrandling,

storage, and shipping activities rnay be found in the Regulatory Guides arrd associated Standards as committed to in Section A.7 and Table I (e,g,, Regulatory Guide I '38).

8, Test Control a,

A test control pro$'am is established and irnplemented to cletnonstrate that iterns will perform satisfactorily in seryice,

b.

Criteria are dcfined that specity lvlren testing is required.

The test control prograrn inclucles, as appropriate, proof tests before installation, pre-operational tests, post-rnaintertance tests, post-rnodification tests, and operational tests.

'lest procedures are developed that irrclude:

l.

instructions and prerequisitcs to pertbrtn the test,

2.

use of proper test equiptnettt,

3.

acceptance ct'iteria, attcl 4,

tnandatory inspectiorts as required.

Test results are evahrated to assure that test objectives aud ittspectiort requiremetrts have beetr satisfi ed.

Unacceptable test results shall be evaluated.

b.

c.

d.

e.

c.

d.

e.

15 of 36 Rcvision:

FHruOC 4"s Quality Assurance Pryglqry Manual

g.

Aclditional details concerning test control may be found in the Regulatory Guides and associated Standards as colltmitted to in Section A.7 and Table I (e.9.,

Regulatory Guide I.33).

9.

h{easurittg and Test Equipnrent Control A program is established and irnplemerrted to control the calibration, maintenance, and use of rneasuring and test equipmeut. Measuring and test equiprnent does not include permanently installed operating equipment or test equipment usecl for prelirninary checks where data obtained will not be used to cletermine acceptability or be the basis for design or engitteering evaluation, AdclitionallS calibration and control measures are trot required for rulers, tape measures, levels and other such devices if norrral conrmercial tnanufacturing practices provide adequate accuracy.

The types of equipment coverecl by the ploglalr (e,g., insttutnetlts, tools, gages' ancl reference and trattsfer statrclards) are defined irr procedttres.

It4easurirrg ancl test equipment is calibrated at specified intervals or imttrediately befbre gse ol1 the basis of the itern's required accuracy, intetrded use, fi'equency of use, aud stability characteristics and other conditions affecting its pertbnnance.

Measuring and test equipment is labeled, tagged, or otherwise controlled to inclicate its calibration status and to ensure its traceability to calibration test data' Measuring ancl test eqniprnent is calibrated against standards that irave atr accuracy of ut least four tiures tlre required accul'acy of the equipnrent being calibratecl or, rvhen this is not possible, have an acclll'acy that ensttt'es the equipment beitig calibrated lvill be rvitlrin the requilecl tolcrance' If nationally recognized strindards exist, calibration stanclards are to be tfaceable to tlern. Except u4rere calibration standards rvith the sattre accuracy as tlte ipstruments being calibrated are shown to be adeqnate for the requiremertts, calibration standards are to have a greater accuracy than the standards beirtg calibratecl.

Measuring ancl test equipment founcl out of calibration is tagged or segregated.

The acceptabitity shall be cleterrnined of items tneasured, inspected, or tested u,ith att out-oflcaliblatiotr device.

h.

Aclclitional details concenring lneasuring and test equipntetrt control nray be foun6 ir-r the Regulatoly Guides ancl associated Standards as cornmitted to in Sectiop A.l and Table I (e.g,, Regrrlatory Guides I.30, 1.33, 1.94,1.1 16, and

l. r 23).

a.

b.

d.

Rel'ision: 19 16 of36

FE'ruOG f rstEttttgyNt,ha".op*rt*O-rr-nT, Quality Assurance Program Manual

10. Ins;reetion, Test, and Operatirrg Status The status of requirecl inspections and tests and the operating status of items is verified before release, fabrication, receipt, installation, test, and Llse, as applicable. This verification is to preclude inadvertent bypassing of inspectiotrs and tests and to prevent inadvertent operation of controlled equipment.

The application ancl rernoval of inspection, test, and operating status indicators arc controlled iu accordance rvith procedures.

Additional cletails concerning inspection, test, and operating status conttol may be founcl in the Regrrlatory Gtricles aud associated Standards as cotnmitted to in Section A.7 and Table I (e.g., Regulatory Guide 1,33).

11. Special Process Control

a.

A program is established and irnplemented to ensttre that special processes are properly controlled.

b.

The criteria that establish rvhich proccsses are special ate described irt procedures.

Special processes al'e accornplished by qualified personnel, ttsittg appropriate eqpipmept, ancl proceclures in accordance rvith applicable coties, standards, specificatiorrs, criteria, attd other special requirements' Additional details concelning special process control may be found in the Regulatory Guides ancl associated Stanclards as conrmitted to in Sectiort A,7 and Table 1 (e.g., Regulatory Gtride 1.33).

12. Inspectiotr A progranr is establishecl ancl irnplenrented fbr inspections of activities in order to verify confonnancc to the docurnented instructiotls, procedut.es and drau'ings fbr acconrlriishing the activity, 'l'he inspection plogt'am may be implemented by or for the orgatrization perforrning the activity to be inspected.

Provisions to ensgre iuspection planning is properly accomplished are to be established.

Planning activities are to identify the characteristics attcl activities to be inspectecl, the inspection tcchniques, the acceptance criteria, and the organization responsible for perfortnittg tlte inspection.

a.

b.

c.

a.

b.

d.

Revision: l9 17 of36

FFTVOG t "

Quality Assurance Prog-ram Manual c.

d.

Provisions to identifo inspection hold points, beyond whichwork is not to proceed lvithout the consent of the inspection organizatioll, are to be defined' Inspection results are to be documented by the inspector and reviewed by qualified persottnel.

Unacceptable inspection results slrall be evaluated and resolved in accordance with procedures.

Inspections are perfonned by qualified percorulel other than those who prr.-fornt*d or directly supervised the rvork being inspected. While performing ih" in*p"ction activity the inspectors functionally report to the associated individual responsible for quality control or an individual responsible for matettals, purchasitrg, and contracts as appl'opriate.

Adclitional cletails corrcerning inspections nray be fbtrnd in the Regulatory Guides arrcl associated Stanclards as committecl to in Section A.7 arld Table I (e.g.'

Ilegulatory Guides 1.33 and 1.58).

Corrcctive Actiolt

a.

Procedures slrall prot icle for iclentilicatiort, er,aluatiott, and resolution of conditions adverse to qualitY.

b.

Rervorkecl, repaired, and replacemeut items are to be inspected and tested in accorclan.* *ith the original inspection and test requirements or specified alternatives.

c.

Arlditiontrl iietails concelrring corrective action activities may be tound in Sectiop A.6 and the Rcgr,rlatory Guides ancl associated Starrdards as collllnitted to irr Section A,? and Tablc 1 (e.g., Regulatory Guides 1.33 and 1.144).

I)ocurtrent Control a,

A prograrn is establishecl ancl irlplementecl to control the developrnent, revier,v, approval, isstte, use, and revisiotr of docutnetlts.

b.

The docqment control proglanl shall be appliecl to documents that prescribe activities affecting quality of safety-related structnres, systems or colnpotrents.

Such activities incluile clesign, pl'ocurentettt, ntalerial control, installation, ilspectiol, testing, nraintcnance, rnoclificzttiotr, operatiott, refuelitrg arrd decotnnrissioning.

e.

g.

13.

14.

Revision: l9 18 of36

FFruOC f rst?ntrgy Nucle"ri.

O*r"r*a*n*

Quality Assurance Proglqm Manual Revisions of controllecl docunrents are reviewed for adequacy and approved for relcase by the saffle orgarrization that originally revicwed and apploved the clocuments or by a clesignated organization that is qualified and knowledgeable.

Contrclled docurnents are available to and used by the person perfornring the activity.

The distribution of nerv ancl revisecl controlled documents is in accordance with procedures.

Superseded documents are coutrolled to prevent inadvettent use' Arlditiolal details conceruing clocuurent control rnay be found in the Regulatory Guicles and associated Standards as corlllnitted to in Sectiorr A.7 and Table 1 (e.9., Regulatory Guide 1,33).

15. Records

a.

A prograrn is establishecl and irnplemented to eltsure that sufficient records of itenrs lncl activities (e.g., clesign, engitreering procuremeut, manufactttring, construction, inspection ancl test, installatiolt, preoperation, startup, operations, rnaintenance, rnodification, clecomrnissiotting, and audits) are generated and rnaintained to reflect cornpleted work,

b.

TIte program pl'ovides provisiorrs fbr tlre adrnirristration, receipt, storage, preselatiott, safekeepiug, retrieval, and disposition of records'

c.

Aclditional cletails concerning record requiretnents may be lbund in the Regulatory Guides ancl associatecl Stanclards as colnmitted to in Section A.7 and Table I (e.9., Regulatory Guicle 1.88).

C.

ASSESSJ\\{ENT t

l.

l\\'Icthoclology a,

Pelsonnel responsible fbr carrying out auclits al'e maintained cognizatrt of day-to-day activities by the ongoing involvemetrt in the quality asstlrance pl.6gt'am requirements so that they can act in a tnanagetnent advisory function'

b.

Orgapizations perfonling audits arc to be technically and perfoltlatlce oriented con)rnensurate rvith the activity being revier,ved.

c.

personnel perfonning audits have no direct responsibilities in the area tltey are assessing.

c.

d.

Rcvision:19 19 of36

FFfUSG Frrslfnerot Nuc/eu. *t Utt Quality Assurance Program Manual I

d.

Audits are accomplished using procednres, or other appropriate tneaus that are of a detail cornmeusurate with the activity's cornplexity and importance to safety.

Audit A prograrn of planned and periodic audits is established and implemented to confirm that activities affccting quality cornply with thc QAPM ancl that the QAPM lras been im;rlemented effectively. Audits will be cotrducted as required by the applicable Code ol'Federal Regulations, Tecltnical Specifications, safety analysis reports, and commitments by various correspottdence to the NRC.

Andits will be conducted at a fi'equency in accotdance rvith either Section C.2.a.1 or Sectio n C.2.a,2 below.

Audit frequencies will be determined in accordance witir a performance based audit scheduling pro$'am. The scheduling pl'ogram, through an expert panel, uses assessrnent indicators to identiff and schedule audits based on perfor:nance results and irnportatrce of the activity relative to safety. Potential audit subject areas are periodically assessed against appropriate perforrnance criteria. Frotn these reviervs a deterrlinatiott is rnade in regard to tlre depth, scope, and schedr.rling of specific audits, Frinctional areas important to safety at'e assessed annually (t 25%) ta iclentify strengths and weaknesses (if applicable) to deternrine the level and focus of independent oversight activities for the upcoming year, The basis tbr the assessment shall include the results of audits and srtrveillance, NI{C inspections, LERs, self-assessments, and applicable conditions leports (e.g., non-confonrlance and con'ective action reports). Personnel chaltges, change/irlcrease in ftinctional area responsibi l ities, indtrstry operating experience, and INPO evalnations rvill also be considered. Each area lvill be assigned a rating rvitlr a colltpalisotr to llrevious years. This assessment rvill be docutrtented, revierved, and approved by quality assulance rnanagemettt, This docnment is considered a quality assul'altce record and will be available for NRC revien,. Audit subject areas of SectionC,2.a,2 shall confinue to be audited on the fi'equencies designated unless expert parreljudgnent, based on perfornlance results, cletemritres snch an audit to be nrulecessary. In such cases the expert pattel basis shall be docunrettted.

Audit schedules assul'e that the follog,ing areas ale audited at the indicated li'equencies, or ntol'e li'equently as perfolllrance dictates.

a.

Tlre conformalrce of'unit operation to provisiotrs contained lvithin the Teclrnical Specifications and applicable license conditiorts at least once pl"r 24 months.

a.

l.

2.

Revision: 19 20 of36

F'E'VOG b,

The perforrnarlce, training and qualification of the statioir staff at least once per 24 tnontlts, Tlre results of actiorrs taken to correct deficiencies occurring in unit equipnretrt, sttuctures, systetns or tnetltod of operation that affect nuclear safety at least once per 24 months.

The performance of activities required by the QAPM to meet tlte requirements of 10CFR50, Appendix B at least once per 24 months.

The fire protection progt'am controls and irnplementing procedures at least once per 24 montlu.

The fire protection equipment and program implernentatiotr at least once per 24 months utilizing either qualified licensee pelsontlel or an outside fi re protectiort cottsultant.

The file protection equipment arrd prograrn irnplementatiott at least orlce pel36 mottths utilizing a qualified outside fire protection consultant, The Radiological Ettvironmental Monitorittg Program (REMP) and radiological efflueuts mottitoring astivities and implenrenting procedures at least oncc per 24 months.

The Offsite Dose Calculatiorr Manual and implernenting procedures at least oltce per 24 montlrs, The Process Control Proglanr and irnplementing procednres for processiug artd packaging of radioactive wastes at least ollce pet 24 nrontlts.

A grace lreriod of 90 clays nray be applied to the 24 rnonth fi'eqttency for internal auclits. For activitics defen'ed in accot'dance rvith the 90 ttay gtace periocl, the next pelformance due date rvill be based on their ortginally scheduled date.

I Auclits sirall provide an objective evaluatiott of quality related practices, procectures, instnrctions, activities, and items atrd a revierv of docunlents ancl records, as applicable.

d.

e.

ct b'

h, J.

3.

4.

5.

Auclits shall be pelforrned in accoldance u,ith approvecl rvritten or checklists. Iterns fi'om previous auclits shall be revierved and as appropriate.

The checklists ale nsed as gtrides to the auditor.

Scheduling and lesource allocation are basecl on the statlts and safety importance of the activity ol process beirrg assessed.

Schecltrling is clynamic ancl rcsoul'ces are srpplernented lvhen the effbctiveness of tlre quality asstlrallce proglanr is in doubt.

procedures reaudited, 6.

4 Revision: 19 2l of36

FF,VOC Quality Assurance Progjem Manual Audit reports are rvlitten and distributed to the appropriate levels of management for review. Follorv-up action can be accornplished tlu'ouglr written comlnunication, te-audit, or other appropriate rneans' as deemed necessary.

Implementation of delegated portions of the quality assurance progtam is assessed.

Audits are conclucted gsing predetermined acceptance criteria, which are tlre indiviclual requiretnents within the QAPM, applicable Regulatory Gqicles and ANSI Stanclards, procedures, and documents that are used to perform the audited activity or process.

Additional details concelning audits may be found in the Regulatory Guides ancl associated Stanclards as committed to in Section A.7 and Table 1 (e.g., Regulatory Guides 1.33 and I.144).

D.

INDEPENDIINT SAFETY REVIBW Description

a.

Inclepenclent safety revierv is pertbrmed to tneet the individual ttnit's commitment to perfbrrn the ftinctions described irr NUREG-0737, Section LB. L2,'*Independent Safety Etrgineering Group."

8.

9.

10.

l l.

l,

Revisionl 19 22 of 36

FENCIC Quality Assurance Prog-ram Manual Table 1 - Regulatory Commitnreltts A.

Rcgulatory Guicle 1.8 (Revisiolr 1) [Septcnrber 19751, Personnel Selection snd Training

1. FENOC commits to the regulatory position of this Guide with the following clarifications:

a. Regulatory Guide 1.8 states "The RPM should have a bachelor's degree or the equivalent in a science or engineering subject including solne formal tlaining in radiation protection and at least 5 years of professional experience in applied racliation protection." It is FENOC's positiorr that equivalent as nsed in this Regulatory Guide for the bachelor's deglee nreans (a) fbur years of post secondary schooling irr science or engineering, or (b) four yeals of applied experience at a nuclear facility in the area for rvhich qualification is sottght, or (c) four years of operational or technical experience ol training irt nucleal'power, or (d) any cornbination of the above totaling foul years. The years of expelience used to meet the education requirements as allowed by this exception shall not be used to also meet the experiettce requit etnents.

2. F'ENOC comrnits to tlre requirernents of ANSI N18.1-19? I as moclified by plant-specific Technical Speci fications.

B.

Regulatory Guirle 1.30 (Revision 0) lAugust 19721, Qualitl,Assurgrtce Reqt+irententsfar the Instrtllatiott, Inspection, snd Testing af Inslrumentfiion tnd Electric Equipment L FENOC commits to the regulatory position of this Guide.

2, FENOC conrmits to the lequirements ot'ANSI N45,2.4-1972 rvith the following clarificatiotts:

a. Section 1.1 specifies ecluipment to rvhich this Standard applies. In lieu of this, requircrnents of this Stanclarcl shall apply to tlrose systems and compotlents that are x,ithin the scope of the QAPM. Each plant nraintains a list of equiprnent subject to eApi\\4 reqnirements. This Standard is also applied to other systenrs and cotnponents vvhen lcquilecl by approvecl procedures, errgineering specifications, or other rvork controlling tlocunr en ts.

b. Section Z,Z rcquircs that eviclence of compliance by the tnanufactnrer rvith purchase requirernents, including quality assurance requirements, be available at the site prior to applying the requirernents of ANSI N45.2,4. In lieu of this t'eqttirenretrt, installation, inspection, arrcl tcsting activities of equiptnerrt lackirtg its quality documeltation rnay proceecl provided that this equiptnent has been identified and releasecl in accorclance rvith non-conforrning material irrocedures anct that all reqnired qpality clocurnentatiorr has been received and accepted prior to the itein being placed in sewice.

Rcvision: l9 23 of36

FFAJOG f :t jt f n.tgfN+: t'a' Oix'ral,irnffi*q Quality Assurance Program Manual C,

c. Section 3 requires that records of protective tneasures rnaintained durirrg storage for conformance to storage requirements be checked to verify that iterns are in satisfactory condition for installation. This check shall be rnade only if equiprnertt requires special storage or handlitlg as specified in proculement docnrnents,

d. Sections 5.2 and 6.2 list the tests which are to be cotrducted during consttuction and post-construction activities. In lieu of these tests, FENOC shall conduct only those tests lecessary to verify that wolk activities specified by work controlling documents have been satisfactorily accomplished during rnaintenance or modification activities' Tlre requilernents of Sections 5.2 and 6.2 of ANSI N45.2.4 shall be used as guidelines irt detertnining these testing requiremetlts' e, Section 6.2,1states in part tlrat "ltems requiring calibration shall be tagged or labeled on completion irrdicating date of calibration and identity of person tlrat performed the calibration." In lieu of this requirement, FENOC rnay alternatively irnplemetrt programs that require the eqnipment to be suitably marked to indicate the date of the pext calibratiol anrl the identity of the person that pertbnned the calibration. Irt actclition, ipstallecl plant equiprnent that is used as measuring antl test equiptnent (M&TE) may be controlled to indicate its calibration status and to ensllre traceability to calibration test data by alternate rneans in lieu of physically tagging or labeliilg (e.g., preventive maintetlallce plogram).

Rcgulatory Guide 1.33 (Revision 2) [February l9?81, Quali\\, Assursnce Progrnm Il eq u ire m e n ts (Oper at iorts)

l. FENOC comrlits to tfue regulatory position of this Guide rvith the follorving altenratives:

a, Regulatory position C.4 specifles audit fi'equencies for several audit topics. QAPM Section C.2 (Audit) describes alternatives to these fi'eqltcncies,

2. FENOC commits to the reqnirenrents of ANSI N 18.?-1976/ANS 3.2 rvith the follor,ving clarificatious and alternatives:

a. Sectiorr I reqnircs that this Stanclard "apply to all activities affecting the safety-related fupctiops of nuclcal'power plant structures, systetns, ttnd componellts."

F-ENOC slall apply the requirernents of this Standarcl to tltose structut'es,

systents, aucl conrponents iclentifiecl as safety-related in the respective plant's USAR.

b, Section 5.1 states in part that "a sunlnrary clocunrent should be cornpiled by eaclr owfler orgarrization to iclentify the sources, to index such sources to the requirernetrts of this Standard, ancl to provide a consoliclated base for the description of the plograln." In lieu of this requirenrent, a tnethorl of cross-refereucing these i"q,,ir.tttents to the intplementitrg procedures rvill be lnaintairred.

c. Sectigrr S.Z.Z lcqlires that "ternporary chatrges rvhich clearly do not change the intent of t5e approved procedure shall, as a rninilnurn, be approved by tlvo trtetnbers of the Revision: l9 24 of 36

FENOG a"

Quality Assurance Program Manual 1) plant staff knowledgeable in the areas affected by the procedure. At least otte of these shall be the supervisor in charge of the shift and hold a senior operating licettse on the gnit af-fectecl."

Such changes shall be documented and if appropriate, incotporated into the rrext rerrision of the affected procedure. In lieu of these requiretnents, FENOC commits to the follorving:

Temporary changes to procedures which do not change the intent of the approved prccedure shall be approved for implementation by two members of the plant management staff, at least one of whom holds a Seniol Reactor Operating License for the unit affected. The ternporary procedures shall be approved by the original approval authority rvithin 14 days. For chauges to procedures which may involve a change in intent of the procedure, the original approval authority shall approve the change prior to irnplernentatiou. OR Tcrnporary changes to proceclures rvill be approved by two knorvledgeable members of the plant staff plior to irnplententation. At least one of these persolls rvill be a menrber of snpervision. If tire change affects operations procedures, at least one of these pet'sorls n ill hold a senior reactor operator license for the unit affected. Prior to irnplementation, the OSC (PORC) shall revierv and recomtnend approval of ternporary clranges to procedures rvhich require a 10CFR50.59 safety evaluation. Within 14 days of irnplernentation, ternporary changes will be revierved by an independent qualified revier,r,,er and approved by the Responsible Discipline Martagsl'tll'lris clesignec.

Section 5.2.6 recluires that a log be maintained to identify the cutrent status of tentporary modifications such as bypass lines, electricaljumpers, lifted electrical leacls, aud ternpol'ary trip point settings. FENOC takes exception to this requiremettt rvhclt tlre institllation and rernoval of such teurporarynrodificatiotts is specifically aclchcssecl in approved procedules. These pracedrtres ellsrlre that the circuitry is l'etumed to its original configuration rvhen the operatiott is cornpleted, Section 5.2.7 - Since ccrtain emergeltcy situations could arise whish rnight prel'ent preplaruring activities, FENOC cortrplies r,vith au altemative to the first seutence in the second paraglaph as follo\\l,s: "Except uttder emergeltcy or abnonnal operating conclitions u,here irnmecliate actions are required to protect the health and safety of the public, to pt'otect equiprncnt or personnel, or to prevent the deterioraticn of platrt conclitions to a possibly unsafe or unstable level, maintetrallce 01'nrodification of equiprnent slrall be preplanned arrd perfbnncd in accordance rvith approved proccclures. When ivritten proceclules u,oulcl be required and are trot used, the activities that are accomplishecl are docutttented after-the-fact ancl teceil'e the satne clegrec of t'eviervs as if they had been preplatttted."

Section 5,2.13 (l) establishes tlre requiretnent for identifying quality asslrrance progl'am requirenrents applicable to the items or selices being proctrred. When purchasirlg comlnercial grade services fronr cerlain accredited calibration laboratories, the procurellrent docurnents are not required to irnpose a quality asssl'ance pl'ogram consistent rvith ANSI N 18.7. Altemative requiretnettts described 2) d.

e.

Revision: l9 25 of 36

FFruOC f, f s/f,l("gi,, r\\tuctPar O*r rtna-Quality Assurance Program Manual in this QAPM for Regulatory Guide 1.123 may be implemented irr lieu of irnposing a quality assut'ance proglaln consistent with ANSI N18.7.

g. Section 5.2.15 contains a requirement for biennial revierv of plant procedures.

In lieu of this requirernent, FENOC nray use one of the following tnethods as altematives:

hnplernent process controls that ensure procedures are revierved for possible revisiol upon identification of llew or revised source tnaterial potentially affecting the intent of procedurcs.

Implement process controls related to procedure t'eview, a rlaximum six year revierv period and biennial auclits of operating organizations that include a review of their procednres to assure that controls result in timely procedure revision in response to operations expedence deficiencies and procedure deficiencies iclentified by users.

h. Section 4.3.4 (3) cliscusses the requirement for the on-site and off-site independent revies, bodies to revierv license arnendrnents and technical specification chartges. As an altenrative to the requirenrents for the off-site review body to review license arpepdrnents and technical specification changes, FENOC will utilize the on-site lcvierv body firr thcse reviervs. To eusure tlrat the ort-site revierv body maintains ipdepeldenqe cluring these reviels, any voting member that has a potential conflict of interest in a change under revierv u'ill be replaced by another meinber to achieve a quorLlm, In addition, the off:site revieu'body rvill review on-site review body meeting minutes ancl inclepenclent oversight (QA) audit and assessment results of on-site review body activities to evaluate their effectiveness.

D.

Regulatory Guicle 1.37 (Revision 0) flVlarch 19731, Quality Assurqnce Rerluirements for Cleuning of Fluid Systems ancl Associrtted Contponents o.f l\\ater-Cooled Nuclear Pou'er PIants l. ITENOC cornmits to the regulatoly positiorr of tlris Guide rvith tlie follolving clalit-lcations:

a. Regulatory llosilion C.3 requires that rvater quality for final flushes of fluicl systenrs ancl associated cotnpollents be at least equivalent to the quality required for not'mal operatiol. Tfiis requireurent is not appliecl to dissolved oxygerl or nitrogen nor does ilfel that additives nonnally in the systern lvater shall be added to the flush water,

b. I{egulatory Position C.4 r'equires that chernical cornponettts that cotrld contribute to intirgranrrlur.,rurkirrg or stress corrosion cracking should not be used rvith austettitic stainless steel and nickel-based alloys. It is FENOC's position that rnaterials such as ipks, temperature inclicating cl'ayons, labels, rvrapping naterials (other than polycthylene), u,ater soluble materials, dcsiccauts, lubricattts, and NDE penetrant materials arrd couplants, rvhich contact stainless steel or nickel-based alloy material sur.f'aces contain no lnole than trirce amounts of lead, zittc, copper, or lorver rnclting r) 2)

Revision: 19 26 of 36

FE'VOC trrffi Quality Assurance Program Manual alloys or compounds. Maximum allowable levels of water leachable chloride ions, total halogens and sulfur cornpounds shall be defined and irnposed on the aforenrentioned rnaterials. These rnaterials will be controlled through adrninistrative procednres that are, irr palt, designed to rnininrize their effects on intergranulaf cracking or stress cotrosion cracking.

2. FENOC comrnits to the requirements of ANSI N45.2.l-1973 rvith the following clarifications:

a. During maintenance ancl modification activities, FENOC shall control the opening of clean systems and shall conduct inspections to verify that affected system cleanliness levels shall not be adversely affected by the maitrtenance 01'rnodification activity.

When system cleanliness is affected, specific cleaning procedures rvhich incorporate the appticable portions of this Standald shall bc developed and implernented to rtraintaitt systcm sl eanl iness.

b. Section 2.4 requrires that personnel u,ho pelfbnn inspectiotr, exantination or testing activities required by this Stanclard be qualifiecl in accordance lvith ANSI N45.2.6. In lieu of this, personnel lvho perform sleanliness inspections ffiay altematively be qualified in accordance lvith Regulatory Guide 1.8-E.

Regulatory Guide 1.38 (Revision 2) [May 19771, Quality Assurunce Rerluirements for Packaging, Shipping, Receivirtg, Storage, and Hsrtdting of ltemsfor ll/uter-Cooled Nuclesr Power Plfints FENOC conrttrits to the legttlatory position of this Gtride-FENOC commits to the requirenrents of ANSI N45.2.2-1918 clariflcations:

the follorving Sections 3 and 4 specify a four level clas.sification systetn for the packaging and shipping of items. Irr lieu of these reqnilemettts, commercial grade itents slrall be packaged anC shipped in accordance u,ith standard commel'cial practices.

Section 5.2,l requires preliminary visual inspection or exarninatiott fbr shippittg clamage to be performed plior to unloading. In licu of this requirelnent, visual inspection shall be perfbnned during unloading and unlrackiug.

c. Section 5.5 proviclcs for "re$,ol'k" and "nse-as-is" clispositions for uoucortlbtrning itcms. As au altenrative, tlre "repail'" dispositiotr (as defined by ANSI N45.2'l0-1973) tnay also be used.

d. Section 6.5 requires that items released fronr storage and placed in their'final locations u,ithin the porver plant be in.spected and cared for in accordatrce rvith the requireurents of Section 6 of this Stanclard and other applicabie Standat'cls.

In lieu of

_this requirement, FENOC shall, lvhenever feasible, stot'e itettts rvitlrin their' l.

l.

a.

b.

Revision:19 27 of36

FEJ\\JOG l-:tt{t!"tlil

^1}:?r' OrU'n r,,rg, Quality Assurance Program Manual appropriate storage area and rnove the equiprnent to the plant al'eas for staging only in sutficieut tirne to support its installation. Within the plarrt, the equipmettt shall be staged at locations which provide equivalent environrnental conditions under which it is designed to operate. Materials placed in staging at'eas shall be stored in accordance rvith the applicable requirements of Paraglaphs 6,1, 6,3 and 6.4.2 of ANSI N45,2,2,

e. Various Sectious of ANSI N45.2,2 address the use of notr-halegenated materials rvhen in contact with austenitic stainless steel or nickel-based alloys. The exceptions applicable to Regulatory Guide 1,3? regarding this subject also apply to ANSI N45,2.2.

f. Scction A.3.4.2 addresses inert gas blankets. There tnay be cases involving large or cornplex shapes for which an inert or dry air purge f'lolv is provided rather than static gas blankets in order to provide adequate protection due to diff,rculty of providing a leak-proof banier. In these cases, a positive pressure purge florv may be used as an altemative to a leak-proof barrier.

F.

Regulatory Guide 1,39 (Revision 2) [September 19771, Housekeeping Requirententsfor IVster-Cooleil Nuclesr Power Plants L FENOC cotnmits to the regulatot'y position of this Guide.

2. FENOC sommits to thc reryuirements of ANSI N45.2.3-1973 tvith the following alter natirte.

a. The ANSI five level zone dcsignation systern may not be utilized, btrt the itttent of the stanclarcl w,ill be nret for the areas of housekeeping, plant and pet'sonnel safety, and fire protectiotr.

G.

Regrrlatory Guicle 1.58 (Revision 1) [Septenrber 19801, Quulilication of Nuclecr Power Plant Inspection, Excntinotion and Testing Personnel I. ITENOC cornnrits to the regulatory position of this Guide rvith the follorving clarifications:

a. The guidance of this Regulatory Guicle shall be follolved as it pertains to the qualification of personnel u,ho verify con{buuance of rvork activities to quality lequirements.

b, Personnel r,vill not be certified as stated in this Guide in the follorving areas:

1) Individuals that handle test results ol pelform documeut corltrol activities.

2) Quality assut'allce ancl staff personnel respottsible for tlte revielv of docnments fbr clality and cotnpleteness, Revision:19 28 of36

FENOG f, t s t7n e ey l\\\\Er-ur O*"UrnC Quality Assurance Program Manual

3) Test personnel utilizing gas test methods for infonnation or data collection activities (this includes those persor)nel perfonning local leak rate testing (LLRT) as stated in 10CFR50 Appendix J). The qualifications of these personxel shall corrfonn to the requiremettts of Regulatory Guide 1.8.

4) Plant opelation pel'sonllel concelltecl rvith day-to-day operation, maintettance, and ceftain teclutical services (the qualifications of these personnel shall confonn to the requirernents of Regrrlatory Guide 1.8).

c. Regrrlatory Position C,2 indicates that SNT-TC-lA-1975 is to be used for the qualification of nondestnrctive examination [NDE) personnel who apply various NDE rnethods. It also indicates that personnel performing nondesttuctive examinations requirecl by Section III and Section XI of theASME Code should be qualified to SNT-TC-lA-1975 as well as additional provision of the Code. For the qualification of NDE personnel, FENOC commits to the ASME Section XI requirenrents specified lvithin the applicable code year edition(s) as defined by 10CFR50.55a. This altemative rnay be applieil regardless of lvhether examinations are of a tlpe required by the Code.

2. FENOC cornrnits to the requirenrents of ANSI N45,2.6-1978 as nrodified by the comrnitrnents to Regulatory Guide 1.58 rvith the follolving claritications:

a. Section 2,5 of this Stanrlard discusses special physical charactet'istics. FENOC cotnmits to the folior,ving: Examinations to r,,crify that personnel have the required physical characteristics lvill be schecluled ou an arutual basis rvith a maximum allorvable extension of 90 daYs.

b. Sectiol 3.5 of tfuis Standard discusses education and experience, FENOC contmits to thc follorving: The initial qualiticatiorrs of individnals to Level I, II, or III B'ill generally bc to the education and experience lecontmendations in the Standard' However, in cefiain instanccs as determined by appropriate tnanagetnent, qualifications lrlay be altenratively detenttined througlr test results and/or clernonstration of capabilities. For Level I, FENOC lviil also accept a four year college cleE"ee plus one month of related experience or eqtiivalent inspectiot:,

exalrination or testing activities. Individual requalitication rvill meet or exceetl tlte recomlnenelation of this Standard.

c, Section 2.3 of this Standard cliscusses evaluating pel'sonnel rvho have not perfottned inspection activities fol rnore than a year. A 90 day grace period is applied to this evaluatiou.

H.

Regplatory Guide 1.64 (Revision 2) [June 19761, Quality Assurance Rerluirements fot the Design of Nuclear Potver Plottts 1, FENOC commits to the regulatory position of this Guide rvith the following clarifrcatiotts:

Revision: 19 29 af 36

FENOG

,"*ffi Quality Assurance Program Manual I.

J.

a. Regulatory Position C.2(l ) adclresses the use of a superuisor in clesign verificatiotl, If, irr exceptional circumstances, the supervisor is the only technically qualified indiviclual available, the design verification or checking shall be conducted by the superuisor rvith the following plovisiotts:

l) The other requirements of Regulatory Position C.2 of tlris Guide shall be met.

2) The justification shall be individually docunrented and approved by the next level of supervision.

3) Quality assurance auclits shall include revierv of fi-equency and effectiveness of the use of the immeciiate superuisor to assure that this provision is used only in exceptiottal circutttstauces.

b. An individual g'ho contributed to a given desigrr rnay participate in a group verification of that design providetl that the individual who contributed to the design does not (1) verify lris contribution to the design, or (2) selve as chairman or leader of the group verification activity.

Z. FENOC comrnits to the reqnirements of ANSI N45,2.ll-1974 with the clarifications as noted above for the use of an immediate supervisor for design verification activities and conduct of group verification activities.

Regulatory Guide 1.74 fReyision 0) {Febmral'y 19741, Quality Assurnnce Tenns and DeJinitions I. F'ENOC comtnits to the regulatot'y position of this Guide.

2. FENOC comtnits to the reqrtiretneuts of ANSI N45.2,l0- l9?3.

Regulatory Ggide 1.88 (Revision 2) [Octobcr' 19761, Collectiort, Staruge and Mnintenilnce of Nuclecr Potper Plunt Quulits' Assurance Records

l. FENOC conttnits to the t'egttlatory positiorr olthis Guicle.

2. FENOC cornrnits to the recluiremeuts of ANSt N45.2.9-1974lvifh the following altenratives:

a. Sectiol 5.6 arlcllesses recorfls storagc facilities. In lieu of this, the desigtt and constnrctiol of quality assurarlce record storage facilities will follow the grridance of ANSI/ASh4E NQA-I - 1 983, Supplenrent I 73-1, Section 4.4. When temporary storage of recorcls is required, the guidarrce of ASIT4E NQA-l - 1989, Supplement l7S-l, Sectiort 4,4,3 r,vill be follorvcd. For storage of special processecl records (such as racliographs and rnicrofilm), hurnidity and ternperature cotrtrols shall be provided so as to nraintain an environnrental conclition as pl'escribecl in Paragraph 6'1.1 of ANSI PH 1.43-1 979 (Also required by Section 5.4)'

Revision: 19 30 of36

f,EtrOC Frrslfnc.rgy rVucle"r OOor^rO"O-Quafity Assurance Program Manual Appendix A of ANSI N45.2.9, requires that records of measnring and test equiprnent calibration be rnaintained "until recalibration." This irnplies tltat the full storage requirernents of this Standard apply until the equipttrent is recalibrated.

In lieu of this requirement, FENOC rnay store measuring ancl test equipurent calibratiou records in one-hourfir'e ratecl containers. This exception does not apply to records of calibration required by the Technical Specifications.

For managing QA records in electronic media FENOC commits to tlre guidance of RIS-2000-018, This NRC Regulatory Issue Snnrmary (RIS) endorses:

NIRMA Technical Guide (TG) I l-1998, Auttrentication of Records and Media o NIRMA TG 15-1998, Managetnent of Electronic Recorcls c NIRMA TG l6-1998, Softwale Configuration Management atrd Quality Assurance c NIRMA TG 2l-1998, Electronic Records Protectiott antl Restoratiott K.

Regulatory Guiclc 1.94 (Revision l) [April 79761, Quulity Assurunce Requirements for htstsllstiol, Inspectiort anl Testing of Structural Concrete snd Structurul Steel During the Construction Phnse of Nuclesr" Power Plants

1. FENOC comrnits to the regulatory position of tlris Guide,

2. FENOC cornmits to the requirernents of ANSI N45.2.5-1914 rvith the follou'ing clarifi cations and altentat ives:

a. Sectiop 2.2 requires that installation, inspection, and test procedures be kept ctttrent with the latest infognation. This Standard rvas rvritten to address requit'etnents associated lvith construction phase uctivities. However, dndng the operations phase, actir.ities associatecl rvith installation, irrspection, and testitrg of strtlctural concrete agd structural steel are very minor in fi'equency and extetrt, Consequently, procedures for fhese activities shall only be reviervecl ot'updated prior to cottrntencing the activity. The procetlnres for structural concrete attcl sttnctural steel installation, inspection, and testing activities rvill be developcd using the provisions of ANSI N4s.2.5 - 1974.

b. Altenratives to this Stanclarcl are taken rvith respect to fi'equency of calibration of iprpact rvrenches and bolt projection criteria. Inrpact and torque rvrenches shall be checked at least once claily per shift, and at least one ftill thread of all bolts shall project beyoncl the nut of all tightened comections. These criteria conrply rvith the recomfirendations of the Research Council on Riveted ancl Bolted Structural Joints.

b.

c.

Rcvisiorr: l9 31 of36

FENQC i,

Quality Assurance Program Manual Section 4.9.1 discusses the qualification requirements for rnechanical (cadweld) splice operators. In lieu of this, Davis-Besse and Beaver Valley lvill comply with qualification requirements of ASME Section III, 1995 Editiott, subparagraph CC-4333.4.

Section 4.9.3 discusses tensile testing of mechanical (cadrveld) splices. In lieu of this, Davis-Besse and Beaver Valley rvill cornply with the requiretnents of ASME Section III, 1995 Edition, subparagraph CC-4333.5.2.

Section 4.9.4 discusses tensile testing fi'equency. In lieu of this, Davis-Besse and Beaver Valley u,ill comply with ASME Section III, 1995 Edition, subparagraph CC-4333.5.3.

Section 4.9,4 discusses testing of both production and sister mechanical (cadweld) splices. In lieu of tlris, Davis-Besse and Beaver Valley will test sister mechanical (cadweld) splices as described in ASME Section III, 1995 Editiotr, subparagraph CC-4333.5.2, Section 5.5 discusses inspection of structnral steel rvelding. In lieu of this, Davis-Besse and Beaver Valley rvill cornply rvith inspection requirements of the applicable welding codes and any exceptions.

Thc mecharrical splice llel'sonnel qualification, testing and testing frequency requircrnerrts tbr mechanical (cadrveld) splices addressed in K.2,e through K.2.f apply to other full positive connection technologies that meet tlre desigu code of record, The fiequency of shear screw and sleeve splice testing shall nteet the sanre requit'ements as swaged splices, Regulatory Guirle 1.116 (Revision 0) [i\\{ay 1977], Quality Assnrrttrce Requirementsfor hwtallation, fnspection afid Testing of Mechunicsl Eryuipment und Systems

1. F'ENOC conrmits to the regulatot'y position of this Guide.

?, FENOC commits to thc requilernents of ANSI N45.2.8-lg75 rvith thc fbllou'ing clarifications:

a. Sections 2.4 antj 2.6 require tlrat llrocedulcs define system restot'atiott requirements as needed to prevent contarnination after cleanliness class is achieved in accordattce rvitlt cornmitrnents to ANSI N45.2.1 and ANSI N45.2.3,

b. Section 2.9 requires that evidence of compliance by the mamtfacturer u,ith purchase requirements, including qtrality assurance requiretnertts, be available at the site prior to applying the requirements of this Stanclarcl. In lieu of this requirement, section 8.4 (Procurement Control) of this nranual describes the controls for equipment lacking quality docurnentation.

c.

d.

f.

g a>'

h.

L, Revision:19 32 of36

FE'VOC Quafity Assurance Program Manual

c. Section 4.5.1 provides requirements for the cleaning, flushing, ar:d conditioning of installed systerns.

FENOC's position on Regulatory Guide 1.37 and ANSI N45.2.1 also apply to this Section and take precedence over the requirements of ANSI N45.2.8 rvhen conflicts exist.

M.

Regrrlatory Guide 7,723 (Revision 1) [July 19771, Quality Assurance Requirementsfor Control of Procurement of ltems and Services for Nuclear Power Plants

1. FENOC cornmits to the regulatory position of this Guide.

2, FENOC conrrnits to the requirements of ANSI N45.2.13-1976 with the following clarifi cations, exceptions and alternatives:

a. Subsection 3.2.3 discusses quality assural'rce progt'am requiretncnts for procurement docurnents.

For the purchasirrg of corllnlercial grade calibration selices from domestic caliblatiotr labolatories accredited by a nationally lecognized acct'editing body, the procurernent documents are not required to impose a quality assurance progranl consistent rvitlr ANSI N18.7.

In such cases, accreditation may be acceptable in lieu of the purchaser imposing a QA progl'am consistent u'ith ANSI N18.7, provided all the following are met:

1) The accreditation is to ISO/lF,C 17025,

2) The calibratiorr laboratory holds a clomestic accreditation by orre of the following accrediting bodies, rvhich are recognized by the International Laboratory Accleditation Cooperation (ILAC) Mrrtual Recognition Atrangement (MRA):

- Natiorurl Voluntary Laboratory Accreditation Progtarn [NVLAP), administered by NIST

- Arnerican Association for Laboratory Accreditatiort (A2LA)

- ACLASS Accreditation Services (ACLASS)

- Intemational Accreclitation Ser.rice (lAS)

- Laboratory Accreditation Bureau (L-A-B)

3) The published scope of accrerlitation for the calibratiott laboratory covrs the needed meastlrelnent parameters, ranges, atrd ttncertainties.

4) The purchase ciocurnerrts inrpose aclclitional tecltnical ancl aclministrative requireurents, as ncccssary, to satisty FENOC QA Proglatn attd technical rcquilernents. 't'liis rvill include re<luiring that the supplier identify the laboratory equiilnent/stanclards used and the as-fouttd ancl as-left data in the calibration certificateh'e1;ort.

5) The purchase docurnents require reporling as-fountl ealibration data rvhen calibrated itenrs are found to be out-of-tolerance.

Revision: 19 33 of 36

FFAfOC t"

Quality Assurance Program Manual The altenrative rnethod is applicable to sub-suppliers of calibration selice suppliers, provided the above conditions are met.

Section 4 provides for the selection of procurelnent sources. For "sornmercial grade" items and for non-safety related items within the scope of the Quality Assurance Program for which there are llo quality assurance prcgrarn or quality docunrentation requirements, the requirernents of this Section need not be adhered to. Howevet',

the procurelnent documents shall specify requirernents specific to the item being

procured, sufficient to provide adequate certification or other records to ensure that itetns and activities rneet the specified lequirements, Section 8.2 providcs requirenrents for the control of nonconfotmances, Suppliers qualifiecl by FENOC as design agents in accordance lvith Regulatory Guides 1.64 and 1.123 may be pernritted under specific contractnal provisions to disposition nonconfonnances as "use-As-is" or "repair'" on behalf of FENOC. All nonconfolrnances dispositioned "use-as-is" or "repair" by suppliers qualified by FENOC as design agents on behalf of FENOC are required to be submitted to FENOC for engineering alrproval at the tirne equipnreut is received on site. If FENOC detennines that a disposition has been incorectly tnade, a llonconfot'mance report is generated on site to document the problem and effect resolution.

e. Section 10.2.d is interpleted as follou,s: The persoil attesting to a certificate shall be an authorized ancl responsible ernployee of the supplier and shall be identified by the

supplier, N.

Regulatory Guide L,144 (Revision l) [Septcnrber

19801, Auditittg of Quality Assur'flnce Progruns for Nuclecr Power Plants L FENOC commits to the regulatory position of this Guide r,vith the follorving alternatives:

Section C,3.b (2) outlines the requiremerrts for triennial auclits and atuual evalnations of suppliers. A 90 day grace period nray be applied to these activities, For triennial audits and amrnal evaluations tlrat are defelled, the next perfonrrance drte date rvill be based on the origirrally schcduled date.

Scction C.3.b (2) outlines the recluircnrcnts for triennial audits atrd annual evalnations of suppliers. When purchasing colnnlercial grade calibration services fi'om don'restic calibration laboratories accredited by a nationally recognized accrediting body, the accreditation process and accrediting body may be creclited r,vith carrying ottt a portion of the purcliaser's duties of verifying acceptability and elfective implementation of the calibratiorr service supplier's quality assurance prograln.

In lieu of perfbnning an audit, accepting an audit by another licensee, or performing a commercial grade sllrvey, a documented revien,of the supplier's accreditation shall be per'flontred by the pulchaser. This revieu, shall irtclucle, at a rnitrin]uln) all of the fbllotving:

b, c.

d.

b.

R c v i s i o n : 1 9 34 of 36

FFIVOC f,6lE*rgy N).lea. OOrot ffi Quaf ity Assurance Program Manual l) The accreditation is to ISO/IEC 17025.

2) The calibration laboratory holds a domestic accreditation by one of the following accrediting bodies, which are recognized by the International Laboratory Accredi tation Cooperation (ILAC) Mutual Recognition Arrangement (MRA):

- National Voluntary Laboratory Accreditation Plograrn (NVLAP), adrninistered by the National Institute of Standards and Techrtology ( NfST)

- American Association for Laboratory Accreditation ( zLA)

- ACLASS Accreditation Services (ACLASS)

- Intemational Accreditation Service (IAS)

- Laboratory Accreditation Bureau (L-A-BI

3) The published scope of accreditation for the calibration labolatory covers tlte needed measul'ement parameters, ranges, and uncertainties.

c. The alterrrative method is applicable to sub-suppliers of calibration service suppliers, provicled the above conditions are urct,

d. Section C.3.b (2) outlines the requiretnents for triennial audits and atmual evaluations of suppliers. Instead of docurnenting evaluations of suppliers on an annual basis, FENOC lnay document evaluations of suppliers on an ongoing basis, using the guidance of Section C.3.b of this Regulatoly Guide. The results of these ongoing evaluatiolts are reviewed and appropriate comective actions taken. Adverse findings resnlting from these evaluations are periodically revierved in order to determine if, as a rvhole, they result in a significant condition adverse to quality and to provide input to supporl supplier audit activities conducted by the licensee 01'a third party auditing entity.

2. FENOC-conrnrits to the lequirernents of ANSI N45.2. 12-1971 u'ith the follorving clarification:

a. Section 4.5.1of this Standard discusses fbllorv-up and cot:'ective actious. F'ENOC rnay utili ze tl'te provisions of the corrective action progranl outlined in Section A.6 instead of these requirements, as long as the appropliate tirne lirnits are applied to significant conditions adverse to quality. Also, no additional docutnentatiotr is necessal'y if needed con'ective actiorrs are taken ancl verified priol to audit report issnance.

Sections 4.3.1 and 4.3.3 of this Standarcl cliscLtss pre-audit and post-audit conferences.

Pre-audit arrcl post-audit conferences llraybe fulfilled by a r.ariety of comtlnttications, such as telephone convcrsation.

Section 4.3.1 and 4.3.3 of this Standarcl cliscuss pre-auclit atrd post-audit confbretrces, I,re-audit and post-auclit confelences are only hcld rvhett cleemed tlecessary by quality assul'ance or rvhen reque.sted by the audited organizatiott.

b.

c.

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l _ E fr st Ene ry y N*:!ea! Opera:;1g C..\\rnpant, FENOG Quality Assurance Program Manual

d. Section 4.4 discusses audit reporting. Audit reports shall be issued rvithin thirty working days after the last day of the audit. The last day of an audit shall be considered to be the day of the post-audit conference.

If a post-audit conference is rrot held because it was deemed unnecessary, the last day of the audit shall be considered to be the date the post-audit conference was deerned uru)ecessary as docurnented in the audit report, O,

Regulatory Guide 1,746 (Revision 0) [August 1980J, Qualification of Quulity Assurance Program Auelit Personnel for Nuclear Power Plants FENOC conlnits to the regulatory position of this Guicle.

FENOC conrrrrits to the lequirerrrents of ANSI N45.2.23 -1978 rr,'ith the follorvins alternatives, Section 2.3.1.3 discusses other credentials of professional competence. Holders of NRC issued Reactor Operator/Senior Reactor Operator Licenses comply rvith the tequirements of this section and may be arvarded trvo credits.

Section 2.3,4 discnsses audit participation, Prospective lead auditors shall dernonstrate their ability to effectively implelnent the audit process and lead an audit team. They shall have parlicipated in at least one nuclear audit rvithin the year precedirrg the individual's effective date of qualification. Upon successftil derrtonstration of the ability to effectively Iead audits, licensee n'lanagement may dcsignate a prospective lead auditor as a lcad auditor',

Sectiort 3.2 requil'es an annual evaluation of lead auditors. A 90 clay grace periocl may be applied to the annual evaluation. For those evaluations that are deferred, the next performance due date rvill be based ou the originally scheduie date.

Section 5.3 requires that records for leacl auditors be rnaintained and updated annually. A 90 day grace period may be applied to the arrnual update. For those rupdates that are defered, the next perfbrrlance due date n'ill be based on tlre originally schedule date.

I.

2.

a.

b.

c.

cl.

Rcvision: 19 36 of36