Entergy Nuclear Operations, Inc., Annual report for Quality ...Subject: Annual report for Quality Assurance Program Manual changes under 10 CFR 50.54(a)(3) and 10 CFR 72.140(d) Notification

En terv-v Entergy Nuclear NortheastEntergy Nuclear Operations, Inc.440 Hamilton Ave.White Plains, NY 10601-1813

June 15, 2007ENOC-07-00020

U. S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001

Subject: Annual report for Quality Assurance Program Manual changes under 10 CFR50.54(a)(3) and 10 CFR 72.140(d) Notification of Application of Approved Appendix B to 10CFR 72 subpart G.

Arkansas Nuclear OneUnits 1 & 2Docket Nos. 50-313 & 50-368License Nos. DPR-51 & NPF-6Docket No. 72-13

Grand Gulf Nuclear StationDocket No. 50-416License No. NPF-29Docket No. 72-50

River Bend StationDocket No. 50-458License No. NPF-47Docket. No. 72-49

Waterford 3 Steam Electric StationDocket No. 50-382License No. NPF-38

Vermont Yankee Nuclear Power StationDocket No. 50-271License No. DPR-28

Palisades Nuclear Power PlantDocket No. 50-255License No. DPR- 20Docket No. 72-07

Indian Point 1 Nuclear Power PlantDocket No. 50-003License No. DPR-05



Pilgrim Nuclear Power StationDocket No. 50-293.License No. DPR-35

James A. FitzPatrick Nuclear Power PlantDocket No. 50-333License No. DPR-59Docket No. 72-12

Big Rock Point Nuclear Plant-ISFSlDocket No. 50-1 ,55License No. DPR-6Docket No. 72-043

Dear Sir or Madam:

Entergy Nuclear Operations, Inc. is submitting the attached Quality Assurance ProgramManual (QAPM), Revision 16 in accordance with 10 CFR 50.54(a)(3). Revision 16 has an

nboq

effective date of April 11, 2007. The last annual submittal, dated May 2006, viacorrespondence memo CNRO-2006-00029, encompassed QAPM Revision 13. Since thatdate there have been four updates noted as revisions 14, 15, 15-1 and 16. A synopsis of therevisions is provided under Attachment A. The QAPM change pages for each revision areincluded under Attachment B. The Entergy QAPM revision 16 is included under AttachmentC.

Entergy is currently applying its NRC approved Appendix B Quality Assurance (QA) Programto satisfy 10 CFR 72 subpart G "Quality Assurance", under the allowances of 10 CFR 72.140(d) at the James A. FitzPatrick (Docket No. 72-12), Arkansas Nuclear One (Docket No. 72-13),River Bend Station (Docket No. 72-49) and Grand Gulf Nuclear Station (Docket No. 72-50).Entergy is now also applying its NRC approved 10 CFR 50 Appendix B QA Program to satisfy10 CFR 72 subpart G "Quality Assurance", under the allowances of 10 CFR 72.140 (d) at BigRock Point (Docket No. 72-43) and Palisades Nuclear Power Plant (Docket No. 72-07). TheNRC initially approved the Entergy QAPM in a safety evaluation dated November 6, 1998, andmost recently in safety evaluation dated December 9, 2004.

The QAPM, as revised, continues to satisfy the requirements of 10 CFR 50 Appendix B andthe. Regulatory Guides and ANSI Standards referenced, in the QAPM Table of Contents andQAPM Attachment, Table 1.

I hereby certify to the best of my knowledge, information and belief that the informationprovided herein accurately reflects changes made to the QAPM since the last annual submittalof May 15, 2006.

There are no new commitments in this letter. Should you have any questions, please contactMr. Thomas P. White at (601) 368-5742.

Very truly yours,

Jon c~ann*Director, Nuclear Safety & Licensing

Entergy Nuclear Operations

Attachments: A. Synopsis of QAPM 10 CFR 50.54(a)(3) ChangesB. QAPM 10 CFR 50.54(a)(3) Change PagesC. QAPM Revision 16

cc: See Next Page

I

cc: Mr. M. A. Balduzzi (WPO)Mr. B. C. Williams (ECH)Mr. F. R. Dacimo (IPEC)Mr. J. P. DeRoy (ECH)Mr. K. H. Bronson (PIL)Mr. P. T. Dietrich (JAF)Mr. J S. Forbes (ECH)Mr. J. T. Herron (ECH)Mr. M. R. Kansler (ECH)Mr. T. G. Mitchell (ANO)Mr. C. J. Schwarz (PAL)Mr. 0. Limpias (WPO)Mr. J. McGaha (ECH)Mr. K. T. Walsh (W3)Mr. T. A.' Sullivan (VY)Mr. J. E. Venable (RB)Mr. W. R. Brian (GGNS)(All Copies Above w/o Attachments)

Mr. A. B. Wang, Project Manager, ANO-1 & ANO-2Mr. M. 0. Miller, Senior Resident Inspector, RBSMr. R. W. Deese, Senior Resident Inspector, ANO-1 & ANO-2Mr. D. E. Jackson, Acting Senior Resident Inspector's Office, IP3Mr. M. R. Cox, Senior Resident Inspector, IPi & 2Mr. G. F. Larkin, Senior Resident Inspector, W3Mr. 0. B. Miller, Senior Resident Inspector, GGNSMr. K. Kalyanam, Project Manager, W3Mr. J. P. Boska, Project Manager, IP2 & 3 & JAFMr. S. J. Collins, Regional Administrator, Region IMr. J. L. Caldwell, Regional Administrator, Region III,Dr. B. S. Mallett, Regional Administrator, Region IVMr. D. L. Pelton, Senior Resident Inspector, VYMr. J. P. Kim, Project Manager, VY & PNPSMr. G. K. Hunegs, Senior Resident Inspector, JAFMr. W. J. Raymond, Senior Resident Inspector, PNPSMr. B. K. Vaidya, Project Manager, GGNS, & RBSMr. T. B. Smith, Project Manager, IPiMr. J. Ellegood, Senior Resident Inspector, PalisadesMr. M. L. Chawla, Project Manager, PalisadesMr. D. O'Brien, Commissioner, Vermont Department of Public ServiceMr. P. Eddy, NYS Department of Public ServiceMr. P. R. Smith, President, NYSERDAMr. L. Brandon, Chief, NFU/RPMWS/WHMD, Michigan Dept. of Environmental Quality

Attachment AENOC-07-00020

Synopsis of Quality Assurance Program Manual (QAPM)1.0 CFR 50.54(a)(3) Changes Revisions 14, 15, 15-1 & 16


Synopsis of Quality Assurance Program Manual (QAPM)10 CFR 50.54(a)(3) Changes Revisions 14, 15, 15-1 & 16

QAPM Rev 14

Entergy QAPM revision 14 is an erratum to revision 13. The Entergy Quality AssuranceProgram Manuai annuai submittal (revision 13) was issued with changes. Threelocations (pages 24, 31, & 42) were identified with change bars indicating revision whenno actual changes were made. This error was introduced when three proposededitorial changes were removed from the 10 CFR 50.54(a) evaluation. The error wasthe non-change. The revision change bars have been removed from theaforementioned pages.

These changes are editorial and are being made without prior NRC approval under the10 CFR 50. 54(a)(3) "editorial" clause. There were no text changes in this revision;therefore the QAPM continues to satisfy 10 CFR 50 Appendix B and commitmentspreviously accepted by NRC.

QAPM Rev 15

Entergy QAPM revision 15 incorporates an organizational change. Energy Nuclear hasshifted from a two region organizational structure to a single fleet organizationalstructure to strengthen consistent execution and governance of quality functions. Thereis a President of Nuclear Operations and a President of Planning, Development andOversight reporting to the Chief Executive Officer. The "review and audit" qualityfunction is the responsibility of the President of Planning, Development and Oversight.All other quality functions are the responsibility of the President of Nuclear Operations.The quality functions have not been revised. The quality functions have been assignedto generic organizational position titles. The generic position titles remain in lower casein keeping with QAPM format and. 10 CFR 50.54(a)(3)(iii) that allows "The use ofgeneric organizational position titles that clearly denote the position function,supplemented as necessary by descriptive text, rather than specific titles".

These changes were made without prior N RC approval under 10 CFR 50.54(a)(3)(vi)"1organizational revision" clause. The persons and organizations performing the qualityassurance functions continue to have the requisite authority and organizational freedomto perform these functions. The QAPM continues to satisfy 10 CFR 50 Appendix B andcommitments previously accepted by NRC

Page 1 of 2


Synopsis of Quality Assurance Program Manual (QAPM)10 CFR 50.54(a)(3) Changes Revisions 14, 15, 15-1 & 16

QAPM Rev 15-1

Entergy QAPM revision 15-1 incorporates an organizational change. The position ofPresident Nuclear Operations has been eliminated from the organization. The "reviewand audit" quality function remains the responsibility of the President of Planning,Development and Oversight. All other quality functions are the responsibility of theChief Executive Officer. The quality functions have not been revised. The assignment ofresponsibility for the implementation of the quality functions to generic executiveorganizational position titles has not been revised. This change removes a layer ofmanagement which allows for a more direct reporting relationship between the Entergyexecutives and the chief executive officer. This change was made without prior NRCapproval under 10 CFR 50.54(a)(3)(vi). The persons and organizations performing thequality assurance functions continue to have the requisite authority and organizationalfreedom to perform these functions. The Entergy QAPM continues to satisfy 10 CFR 50Appendix B and commitments previously accepted by NRC.

QAPM Rev 16

Entergy QAPM revision 16 extends the Entergy Quality Assurance (QA) Program to thePalisades Nuclear Plant and Big Rock Point Independent Spent Fuel StorageInstallation (ISFSI). Revision 16 also incorporates a clarification. The Palisades NuclearPlant, Palisades Nuclear Plant ISESI and Big Rock Point ISFSl licenses weretransferred to Entergy by the NRC. This QAPM revision adds the Palisades NuclearPlant, Palisades Nuclear Plant ISFSI and Big Rock Point ISESI docket and licensesnumbers to the cover of the Entergy QA Program Manual cover. A clarification wasadded to section C.2 'Audit Performance" to address that audit areas for stand alonelSFSls may be combined and are limited to programs defined in ISFS1 technicalspecifications.

These changes were made without prior NRC approval under 10 CER 50.54(a)(3)(ii)"NRC approved safety evaluation" clause and the 10 CFR 50.54(a)(3) "clarification"clause. This is an adoption of the existing NRC approved Entergy QA Program by thenewly acquired Palisades Nuclear Plant and Big Rock Point ISESI. It is not aconsolidation of the Palisades Nuclear Plant and Big Rock Point Quality Programs withthe Entergy QA Program. All of the changes to the Palisades Nuclear Plant and BigRock Point QA Programs to convert to the Entergy QA Program were explicitlyaddressed in NRC safety evaluation reports and the basis for the NRC approval wasvalidated to be applicable. To accomplish this adoption the Palisades and Big Rock Pointlicensing basis documents were also reviewed. There were no changes to the licensingbasis documents that required NRC approval prior to implementation. Selected PalisadesQA related commitments were relocated from the Palisades NMC-1 QA Program to thePalisades FSAR. The QAPM continues to satisfy 10 CFR 50 Appendix B andcommitments previously accepted by NRC.

Page 2 of 2

Attachment BENOC-07-00020

Quality Assurance Program Manual (QAPM)10 CFR 50.54(a)(3) Change Pages

Revisions 14, 15, 15-1 & 16

QAPM Rev 14 Change Pages

Cover Sheet

Page 24

Page 31

Page 42


Cover Sheet

Page 2

Page 3

Page 4

QAPM Rev 15-1 Change Pages

Cover Sheet

Page 2


Cover Sheet

Page 17

Pagel 9

Qual ity Assurance Program ManualArkansas Nuclear OneUnits I & 2Docket Nos. 50-313 & 50-368License Nos. DPR-51 & NPF-6Docket No. 72-13


River Bend StationDocket No. 50-458License No. NPF-47Docket No. 72-49






Pilgrim Nuclear Power StationDocket No. 50-293License No. DPR-35


Effective: October 27, 2006Resin1 Revision 14

24

Table IRegulatory Commitments

C. Regulatory Guide 1.33 (continued)

Clarification/Exception

14. ANSI N18.7Section 5.2.2




18. ANSI N18.7Section 5.2.7.1

19. ANSIN18.7Section 5.2.8

The person who holds a senior reactor operators license for theaffected unit and approves a temporary change to a procedure is notrequired to be in charge of the shift.

In addition to the temporary procedure change process described forchanges which clearly do not change the Intent of a procedure,temporary procedure changes which may change the intent of aprocedure may be made following the process described in thissection. Except that the person normnally responsible for approvingrevisions to the procedure is the approval authority for the change.

Instead of the requirements of this section concerning non-conforming conditions, non-conforming conditions will be evaluatedand controlled in accordance with the corrective action program.

The requirement of the fifth paragraph of this section to have a log ofthe status of temporary modifications is not applicable to temporarymodifications for routine tasks installed in accordance withprocedures. These procedures shall provide assurance thatapprovals are obtained, temporary modification activities areindependently verified by an individual cognizant of the purpose andthe effect of the temporary modification, and that activities areadequately documented to indicate the status of the temporarymodification.

This section will be implemented by adding the words "Wherepractical" in front of the first and fourth sentences of the fifthparagraph. For modifications where the requirements of the fourthsentence are not considered practical, a review in accordance withthe provisions of 10 CFR 50.59 will be conducted.

In lieu of a "master surveillance schedule," the following requirementshall be complied with: "A surveillance testing schedule(s) shall beestablished reflecting the status of all in-plant surveillance tests andinspections."

24 Revision 14

Table 1Regulatory Commitments,

E. Regulatory Guide 1.38 (continued)

ClIarification/Exception

21. ANSI N45.2.2Appendix (A-3)Section A.3.7.1

22. ANSI N45.2.2Appendix (A-3)Section A.3.9

23. ANSI N45.2.2,Appendix (A-3)Section A.3.9



In lieu of A3.7.1(3) and (4), Entergy will comply with the following:Fiberboard boxes shall be securely closed either with a waterresistant adhesive applied to the entire area of contact betweenthe flaps, or all seams and joints shall be sealed with not less than2-inch wide, water resistant tape.

Instead of the requirement that container markings appear on aminimum of two sides of the container, preferably on one side andone end, Entergy will comply with the following: Containers areadequately marked for storage, identification, and retrieval.Multiple marking requirements are imposed, where necessary.

Instead of the requirement that container markings be no lessthan 314" high, Entergy will comply with the following: Containermarkings are of a size which permits easy recognition.

Instead of the specific container marking requirements, Entergywill comply with the following: The information required incontainer marking is evaluated on a case-by-case basis.

The last paragraph of A.3.9 could be interpreted as prohibiting anydirect marking on bare austenitic stainless steel and nickel alloymetal surfaces. As a alternate, paragraphs A.3.9.(11) and (2) maybe used to control marking on the surface of austenitic stainlesssteels and nickel base alloys based on documented engineeringevaluations. Contamination levels are controlled such that thematerial used for marking is not detrimental to the materialsmarked.

31 31 Revision 14


M. Regulatory Guide 1.123 Revision 1, dated July 1977


1. RG 1.123Paragraph C.6.e

2. ANSI N45.2.13Section 1.2.2

3. ANSI N45.2.13Section 1.3


6. ANSI N45,2.13Section 3.1

6. ANSI N45.2,13Section 3.4

This paragraph shall be implemented as originally written inN45.2.13 (i.e., with the verb "should" instead of the verb'shall"). Entergy retains the ultimate responsibility forperformance of purchased equipment. The appropriateengineering discipline will exercise thismanagement/engineering prerogative with respect to the finaldecision on post installation test requirements.

Item c Is an option which may be used to assure quality;however, any option given in 10 CFR 50 Appendix B, CriterionVII as implemented by the QAPM may also be used.

Instead of the definition provided for QA ProgramRequirements, Entergy will comply with the following: "Thoseindividual requirements of the QAPM which, when invoked intotal or in part, establish quality assurance programrequirements for the activity being controlled. Although notspecifically used in the QAPM, ANSI N45.2 may be imposedupon suppliers."

The "~same degree of control" is stipulat ed to mean "equivalentlevel of review and approval." The changed document may notalways be reviewed by the originator; however, at least anequivalent level of management/supervision shall review andapprove any changes.

Changes to procurement documents which are changes inquantity, estimated price, cost codes, taxes, format or editorialchanges that do not affect the quality of the item or service donot require an equivalent level of review and approval as theoriginal document.

The requirements of the QAPM will be implemented instead ofthis section.

42 42 Revision 14

EritergyQuality Assurance Program ManualArkansas Nuclear OneUnits-11 & 2Docket Nos, 50-313 & 50-368License Nos. DPR-51 & NPF-6Docket No. 72-13










Effective: February 14, 2007 Revision 15

0

A.2 (continued)

b. The president responsible for nuclear operations is responsible for theoverall strategy and direction in safely and reliably operating thenuclear sites. The president responsible for planning, development andoversight provides guidance and interpretation for implementing thecompany quality assurance policy. These presidents report to the chiefexecutive officer.

c. The following executive reports to the president responsible forplanning, development and oversight:

I1. The executive responsible for oversight Is responsible forestablishing the policies, goals and objectives of the qualityassurance policy, including oversight and maintenance of theQAPM in accordance with regulatory requirements.Independent oversight groups Including the off-site safetyreview committee report to this executive.

d. The following executives report to the president responsible foroperations and provide guidance in regards to implementing companyquality assurance policy:

1. The senior vice president responsible for nuclear operationsis responsible for the implementation of all activitiesassociated with the safe and reliable operation of Entergy'snuclear sites and reports to the president responsible fornuclear operations.

2. The senior vice president responsible for engineering isresponsible for providing engineering services, projectmanagement services, materials, purchasing, and contracts,information technology, nuclear safety, and licensingactivities.

e. The following executives report to the senior vice president responsiblefor nuclear operations:

1. The executive responsible for overall regional and plantnuclear safety are responsible for implementing qualityassurance policies, goals, and objectives.

2. The executive responsible for nuclear support is responsiblefor implementing quality assurance policies, goals, andobjectives of Entergy's corporate support activities.

2 Iev son as

C,

laitergy' QUALITY ASSURANCE PROGRAM MANUAL

A.2 (continued)

f. The following executive reports to the senior vice presidentresponsible for engineering and technical services:

1. The executive responsible for engineering is responsible forproviding engineering services including implementingquality assurance policies, goals, and objectives.

2. The executive responsible for project management isresponsible for providing project management services,including implementing quality assurance policies, goals, andobjectives.

g. The indiv iduals fulfilling the following management functions report to theexecutives identified above. These individuals may report through anadditional layer of management but shall maintain sufficient authorityand organizational freedom to implement the assigned responsibilities.These individuals may be responsible for a single unit/location or formultiple units/locations and may fulfill more than one function describedbelow:

1 . The manager responsible for quality assurance has overallauthority and responsibility for establishing, controlling, andverifying the implementation and adequacy of the qualityassurance program as described in this QAPM including activitiesrelated to vendor quality. The manager responsible for qualityassurance has the authority and responsibility to escalate mattersdirectly to the chief executive officer when needed.

2. The manager responsible for overall plant operations assures thesafe, reliable, and efficient operation of the plant within theconstraints of applicable regulatory requirements and theoperating license. The onsite safety review committee reports tothe manager responsible for plant operations.

3. The manager responsible for plant modification providesdirection, control, and overall supervision of the implementationof plant modifications and assigned maintenance. Separatemanagers may be responsible for different modification activities.

4. The manager responsible for training provides direction, control,and overall supervision of all training of personnel required byregulations.

5. The manager responsible for records management providesdirection, control, and overall supervision of the recordsmanagement program and associated activities.

3 0-rlý v",i

A.2 (continued)

6. The manager responsible for document control providesdirection, control, and overall supervision of the document controlprogram and associated activities.

7. The manager responsible for the corrective action programprovides direction, control, and overall supervision of thecorrective action program and associated activities.

8. The manager responsible for engineering is responsible for thedevelopment and maintenance of engineering programs, policies,and procedures and for providing engineering services. Differentaspects of these responsibilities (e.g., fuel design) may befulfilled by separate managers.

9. The manager responsible for materials, purchasing, andcontracts is responsible for procurement, services, receipt,storage, and issue of materials, parts, and components. Differentaspects of these responsibilities may be fulfilled by separatemanagers,

h. The on-site and off-site safety review committees independently reviewactivities to provide additional assurance that the units are operated andmaintained in accordance with the Operating License and applicableregulations that address nuclear safety.

3. Responsibility

a. Entergy has the responsibility for the scope and implementation of aneffective quality assurance program.

b. Entergy may delegate all or part of the activities of planning,estab 'lishing, and implementing the quality assurance program to others,but retains the responsibility for the program's effectiveness.

c. deleted

d. Entergy is responsible for ensuring that the applicable portion(s) of thequality assurance program is properly documented, approved, andimplemented (people are trained and resources are available) before anactivity within the scope of the QAPM is undertaken by Entergy or byothers.

e. Individual managers are to ensure that personnel working under theirmanagement cognizance are provided the necessary training andresources to accomplish their assigned tasks within the scope of theQAPM.

4 RevIsion 16 1

I= 1100=21 EritergyQuality Assurance Program Manual






Indian Point I Nuclear Power PlantDocket No. 50-003License No. DPR-05





Effective: April 2, 2007 Revision 15Change I

.4'

A.2 (continued)

b. The president responsible for planning, development and oversight providesguidance and interpretation for implementing the company quality assurancepolicy. This president reports to the chief executive officer.

c. The following executive reports to the president responsible for planning,development and oversight:

1 . The executive responsible for oversight Is responsible forestablishing the policies, goals and objectives of the qualityassurance policy, including oversight and maintenance of theQAPM in accordance with regulatory requirements. Independentoversight groups including the off-site safety review committeereport to this executive.

d. The following executives report to the chief executive officer and provideguidance in regards to implementing company quality assurance policy:

1 . The senior vice president responsible for nuclear operations isresponsible for the implementation of all activities associated withthe safe and reliable operation of Entergy's nuclear.

2. The senior vice president responsible for engineering isresponsible for providing, engineering services, projectmanagement services, materials, purchasing, and contracts,information technology, nuclear safety, and licensing activities.

e. The following executives report to the senior vice president responsible fornuclear operations:

1 . The executive responsible for overall regional and plant nuclearsafety are responsible for implementing quality assurancepolicies, goals, and objectives.

2. The executive responsible for nuclear support is responsible forimplementing quality assurance policies, goals, and objectives ofEntergy's corporate support activities.

2 Revision 15Change 1

Ente~rgjyQuality Assurance Program Manual











James A. FitzPatrick Nuclear Power PlantDocket No. 50-333License No. DPR-59Docket No. 72-12,

Big Rock Point Nuclear Plant-ISFSIDocket No. 50-1655License No. DPR-6Docket No. 72-43

Effective: April 11, 2007 Revision 16

B.15 (continued)

c. The program includes provisions for the use of various record storagemedia to maintain QA records. Procedures are developed to implementthe regulatory guidance associated with the media used. The NRCGeneric Letter 88-18 "Plant Record Storage on Optical Disk" isimplemented for optical disk media. The Regulatory Issue Summary2000-18 "Guidance on Managing QA Records in Electronic Media" isimplemented for electronic media.

d. Additional details concerning record requirements may be found in theRegulatory Guides and associated Standards as committed to in SectionA.7 and Table I (e.g., Regulatory Guide 1.88).

C. AUDIT

1. Methodology

a. Personnel responsible for carrying out audits are maintained cognizantof day-to-day activities by the ongoing involvement in the qualityassurance program requirements so that they can act in a managementadvisory function.

b. Organizations performing audits are to be technically and performanceoriented commensurate with the activity being reviewed.

C. Personnel performing audits have no direct responsibilities in the areathey are assessing.

d. Audits are accomplished using instructions, procedures, or otherappropriate means that are of a detail commensurate with the activity'scomplexity and importance to safety.

2. Performance

a. A program of planned and periodic audits is established andimplemented to confirm that activities affecting quality comply with theQAPM and that the QAPM has been implemented effectively. Auditfrequencies will be implemented as required by the applicable Code ofFederal Regulations, safety analysis report, and commitments by variouscorrespondence to the NRC. Audits will be conducted at a frequency inaccordance with either Section C.2.a.i1 or Section C.2.a.2 below. Auditsof stand alone Independent Spent Fuel Storage Installations (ISFSls)(e.g. those not sited With an operating nuclear power plant) may beconducted in accordance with Section C.2.a.4.

17 17 Revision 16

-ia

C.2 (continued)

c. The results of actions taken to correct deficiencies occurringin unit equipment, structure, systems, or method of operationthat affect nuclear safety is audited at least once every 24months.

d. The performance of activities required by the QAPM to meetthe criteria of 10 CFR 50, Appendix B is audited at leastonce every 24 months.

e. The Offsite Dose Calculations Manual and Process ControlProgram and implementing procedures are audited at leastonce every 24 months.

f. The radiological environmental monitoring program and theresults thereof is audited at least once every 24 months.

g. A fire protection and loss prevention program inspection andaudit shall be performed using either off-site licenseepersonnel or an outside fire protection firm at least onceevery 24 months.

h. The fire protection program and implementing proceduresaudit shall be performed at least once every 24 months.

i. A fire protection and loss prevention program inspection andaudit shall be performed using an outside fire consultant atleast once every 36 months.

3. A grace period of 90 days may be applied to the 24-monthfrequency for internal audits. For activities deferred inaccordance with the 90-day grace period, the next performancedue date will be based on their originally scheduled date.

4. The audit schedule for stand alone ISFSIs may combineaudits to cover the areas defined in section C.2.a.2 that areinvoked by the ISFSI technical specifications.

b. Audits shall provide an objective evaluation of quality related practices,procedures, instructions, activities, and items and a review of documentsand records, as applicable.

c. Audits shall be performed in accordance with approved writtenprocedures or checklists. Items from previous audits shall be reviewedand reaudited, as appropriate. The checklists are used as guides to theauditor.

19 Revision 16 1

Attachment CENOC-07-00020

Quality Assurance Program Manual (QAPM)Revision 16

EntergyQuality Assurance Program Manual





Vermont Yankee Nuclear Power StationDocket No. 50-27 1License No. DPR-28







Big Rock Point Nuclear Plant-ISIFSIDocket No. 50-155License No. DPR-6Docket No. 72-43

Effective: April 11, 2007Reion1 Revision 16 1

4

TABLE OF CONTENTS

SECTION

A. MANAGEMENT

1. Methodology

2. Organization

3. Responsibility

4. Authority

5. Personnel Training and Qualification

6. Corrective Action

7. Regulatory Commitments

B. PERFORMANCENVERIFICATION

1. Methodology

2. Design Control

3. Design Verification

4. Procurement Control

5. Procurement Verification

6. Identification and Control of Items

7. Handling, Storage, and Shipping

8. Test Control

9. Measuring and Test Equipment Control

10. Inspection, Test, and Operating Status

11. Special Process Control

12. Inspection

PAGE

4

5

5

5

6

7

7

8

9

10

11

11

12

12

13

14

14Revision 16

TABLE OF CONTENTS

SECTION PAGE

B. PERFORMANCENVERIFICATION (continued)

13. Corrective Action 15

14. Document Control 15

15. Records 16

C. AUDIT

1. Methodology 17

2. Performance 17

D. INDEPENDENT SAFETY REVIEW

1. Description 20

Table 11- Regulatory Commitments

Regulatory Guide 1.8 Revision 1, dated September 1975 21"Personnel Qualification and Training"

Regulatory Guide 1.30, dated August 1972 22"Quality Assurance Requirements for the Installation, Inspection, andTesting of Instrumentation and Electric Equipment"

Regulatory Guide 1.33 Revision 2, dated February 1978 23"Quality Assurance Program Requirements"

Regulatory Guide 1.37, dated March 1973 27"Quality Assurance Requirements for Cleaning of Fluid Systems andAssociated Components of Water-Cooled Nuclear Power Plants"

Regulatory Guide 1.38 Revision 2, dated May 1977 28"Quality Assurance Requirements for Packaging, Shipping, Receiving,Storage, and Handling of Items for Water-Cooled Nuclear Power Plants"

Regulatory Guide 1.39 Revision 2, dated September 1977 33"Housekeeping Requirements for Water-Cooled Nuclear Power Plants"

ii Revision 16

4

TABLE OF CONTENTS

SECTION PAGE

Table 11- Regulatory Commitments (continued)

Regulatory Guide 1.58 Revision 1, dated September 1980 34"Qualifications of Nuclear Power Plant Inspection, Examination, andTesting Personnel"

Regulatory Guide 1.64 Revision 2, dated June 1976 35"Quality Assurance Requirements for the Design of Nuclear Power Plants"

Regulatory Guide 1.74 dated February 1974 36"Quality Assurance Terms and Definitions"

Regulatory Guide 1.88 Revision 2, dated October 1976 37"Collection, Storage and Maintenance of Nuclear Power PlantQuality Assurance Records"

Regulatory Guide 1.94 Revision 1, dated April 1976 39"Quality Assurance Requirements for Installation, Inspection andTesting of Structural Steel during the Construction Phase ofNuclear Power Plants"

Regulatory Guide 1.116 Revision O-R, dated June 1976 42"Quality Assurance Requirements for Installation, Inspection andTesting of Mechanical Equipment and Systems"

Regulatory Guide 1.123 Revision 1, dated July 1977 43"Quality Assurance Requirements for control of Procurement of Itemsand Services for Nuclear Power Plants"

Regulatory Guide 1.144 Revision 1, dated September 1980 45."Auditing of Quality Assurance Programs for Nuclear Power Plants"

Regulatory Guide 1.146 Revision 0, dated August 1980 47"Qualification of Quality Assurance Program Audit Personnelfor Nuclear Power Plants"

iii iii Revision 16 1

.4

A. MANAGEMENT

1. Methodology

a. The Quality Assurance Program Manual (QAPM) provides aconsolidated overview of the quality program controls which govern theoperation and maintenance of Entergy's (Entergy Operations, Inc.'s(EQI) and Entergy Nuclear Operations, Inc. (ENQI)) quality related itemsand activities. The QAPM describes the quality assurance organizationalstructure, functional responsibilities, levels of authority, and interfaces.

b. The requirements and commitments contained in the QAPM aremandatory and must be implemented, enforced, and adhered to by allindividuals and organizations. Employees are encouraged to activelyparticipate in the continued development of the QAPM as well as itsimplementation. Changes should be promptly communicated whenidentified.

c. The QAPM applies to all activities associated with structures, systems,and components that are safety related or controlled by 10 CFR 72. TheQAPM also applies to transportation packages controlled by 10 CFR 71.The methods of implementation of the requirements of the QAPM arecommensurate with the item's or activity's importance to safety. Theapplicability of the requirements of the QAPM to other items andactivities is determined on a case-by-case basis. The QAPM implements10 CER 50 Appendix B, 10 CFR 71 Subpart H, and 10 CFR 72 SubpartG.

d. The QAPM is implemented through the use. of approved procedures(e.g., policies, directives, procedures, instructions, or other documents)which provide written guidance for the control of quality related activitiesand provide for the development of documentation to provide objectiveevidence of compliance.

2. Organization

The organizational structure responsible for-implementation of the QAPM isdescribed below. The specific organization titles for the quality assurancefunctions described are identified in procedures. The authority to accomplishthe quality assurance functions described is delegated to the incumbent's staffas necessary to fulfill the identified responsibility.

a. The chief executive officer is responsible for providing top-level directionfor the safe and reliable, operation of Entergy's nuclear sites: The chiefexecutive officer provides guidance with regards to company qualityassurance policy.

1 I Revision 16 1

A.2 (continued)

b. The president responsible for planning, development and oversight providesguidance and interpretation for implementing the company quality assurancepolicy. This president reports to the chief executive officer.

c. The following executive reports to the president responsible for planning,development and oversight:

.1. The executive responsible for oversight is responsible forestablishing the policies, goals and objectives of the qualityassurance policy, including oversight and maintenance of theQAPM in accordance with regulatory requirements. Independentoversight groups including the off-site safety review committeereport to this executive.

d. The following executives report to the chief executive officer and provideguidance in regards to implementing company quality assurance policy:

1 . The senior vice president responsible for nuclear operations isresponsible for the implementation of all activities associated withthe safe and reliable operation of Entergy's nuclear.

2. The senior vice president responsible for engineering isresponsible for providing engineering services, projectmanagement services, materials, purchasing, and contracts,information technology, nuclear safety, and licensing activities.

e. The following executives report to the senior vice president responsible fornuclear operations:

1 . The executive responsible for overall regional and plant nuclearsafety are responsible for implementing quality assurancepolicies, goals, and objectives.

2. The executive responsible for nuclear support ýis responsible forimplementing quality assurance policies, goals, and objectives ofEntergy's corporate support activities.

2 2 Revision 16 1

A.2 ( continued)

f. The following executive reports to the senior vice president responsiblefor engineering and technical services:

1. The executive responsible for engineering is responsible forproviding engineering services including implementing qualityassurance policies, goals, and objectives.

2. The executive responsible for project management is responsiblefor providing project management services, includingimplementing quality assurance policies, goals, and objectives.

g. The individuals fulfilling the following management functions report to theexecutives identified above. These individuals may report through anadditional layer of management. but shall maintain sufficient authorityand organizational freedom to implement the assigned responsibilities.These individuals may be responsible for a single unit/location or formultiple units/locations and may fulfill more than one function describedbelow:

1 . The manager responsible for quality assurance has overallauthority and responsibility for establishing, controlling, andverifying the implementation and adequacy of the qualityassurance program as described in this QAPM including activitiesrelated to vendor quality. The manager responsible for qualityassurance has the authority and responsibility to escalate mattersdirectly to the chief executive officer when needed.

2. The manager responsible for overall plant operations assures thesafe, 'reliable, and efficient operation of the plant within theconstraints of applicable regulatory requirements and theoperating license. The onsite safety review committee reports tothe manager responsible for plant operations.

3. The manager responsible for plant modification providesdirection, control, and overall supervision of the implementationof plant modifications and assigned maintenance. Separatemanagers may be responsible for different modification activities.

4. The manager responsible for training provides direction, control,and overall supervision of all training of personnel required byregulations.

5. The manager responsible for records management providesdirection, control, and overall supervision of the recordsmanagement program and associated activities.

3 3 Revision 16 1

A.2 (continued)

6. The manager responsible for document 'control providesdirection, control, and overall supervision of the document controlprogram and associated activities.

7. The manager responsible for the corrective action programprovides direction, control, and overall supervision of thecorrective action program and associated activities.

8. The manager responsible for engineering is responsible for thedevelopment and maintenance of engineering programs, policies,and procedures and for providing engineering services. Differentaspects of these responsibilities (e.g., fuel design) may befulfilled by separate managers.

9. The manager responsible for materials, purchasing, andcontracts is responsible for procurement, services, receipt,storage, and issue of materials, parts, and components. Differentaspects of these responsibilities may be fulfilled by separatemanagers.

h. The on-site and off-site safety review committees independently reviewactivities to provide additional assurance that the units are operated andmaintained in accordance with the Operating License and applicableregulations that address nuclear safety.

3. Responsibility

a. Entergy has the responsibility for the scope and implementation of aneffective quality assurance program.

b. Entergy may delegate all or part of the activities of planning,establishing, and implementing the quality assurance program to others,but retains the responsibility for the program's effectiveness.

C. deleted

d. Entergy is responsible for ensuring that the applicable portion(s) of thequality assurance program is properly documented, approved, andimplemented (people are trained and resources are available) before anactivity within the scope of the QAPM is undertaken by Entergy or byothers.

e. Individual managers are to ensure that personnel working under theirmanagement cognizance are provided the necessary training andresources to accomplish their assigned tasks within the scope of theQAPM.

4 Revision 16 1

A.2 (continued)

f. Procedures that implement the QAPM are approved by the managementresponsible for the applicable quality function. These procedures are toreflect the QAPM and work is to be accomplished in accordance withthem.

4. Authority

a. When Entergy delegates responsibility for planning, establishing, orimplementing any part of the overall QA program, sufficient authority toaccomplish the assigned responsibilities is delegated.

b. The manager responsible for quality assurance has the responsibilityand the authority to stop unsatisfactory work and control furtherprocessing, delivery, installation, or use of non-conforming items orservices. Cost and schedule considerations will not override safetyconsiderations.

5. Personnel Training and Qualification

a. Personnel assigned to implement elements of the quality assuranceprogram are capable of performing their assigned tasks.

b. Training programs are established and implemented to ensure thatpersonnel achieve and maintain suitable proficiency.

C. Personnel training and qualification records are maintained inaccordance with procedures.

d. Additional details concerning Personnel Training and Qualification maybe found in the Regulatory Guides and associated Standards ascommitted to in Section A.7 and Table 1 (e.g., Regulatory Guides 1.8,1.58, and 1.146).


a.. It is the responsibility of each individual to promptly identify and reportconditions adverse to quality. Management at all levels encourages theidentification of conditions that are adverse to quality.

b. A corrective action program is established and implemented thatincludes prompt identification, documentation, and correction ofconditions adverse to quality. The corrective action program forsignificant conditions adverse to quality shall require causedetermination and a corrective action plan that precludes repetition.

5 5 Revision 16 1

.1

A.6 (continued)

c. Specific responsibilities within the corrective action program may bedelegated, but Entergy maintains responsibility for the program'seffectiveness.

d. Non-conforming items are properly controlled to prevent their inadvertenttest, installation, or use. They are reviewed and either accepted,rejected, repaired, or reworked.

e. Reports of conditions that are adverse to quality are analyzed to identifytrends in quality performance. Significant conditions adverse to qualityand significant trends are reported to the appropriate level ofmanagement.

f. Additional details concerning corrective action activities may be found inthe Regulatory Guides and associated Standards as committed to inSection A.7 and Table 1 (e.g., Regulatory Guide 1.33).

7. Regulatory Commitments

a. Except where alternatives are identified, Entergy complies with the QAguidance documents listed on Table 1. If the guidance in one of thesedocuments is in conflict with the QAPM, the guidance provided in theQAPM is the controlling guidance. Additionally, the followingclarifications apply to all guidance documents listed in Table 1:

1. For modifications and nonroutine maintenance, guidanceapplicable to construction-like activities is applicable tocomparable plant activities. Except that the inspection ofmodifications, repairs, rework, and replacements shall be inaccordance with the original design and inspection requirementsor a documented approved alternative.

2., The definitions provided by Regulatory Guide 1.74 andassociated clarifications as described in Table 1 apply whereverthe defined term is used in the QAPM and associated guidancedocuments.

3. Clarification to a guidance document applies wherever theguidance document is invoked.

4. In each of the ANSI standards, other documents (e.g., otherstandards, codes, regulations, tables, or appendices) arereferenced or described. These other documents are only qualityassurance program requirements if explicitly committed to in theQAPM. If not explicitly committed to, these documents are notconsidered as quality assurance program requirements, although

6 Revision 16

A.7 (continued)

they may be used as guidance.

5. Guidance applicable to safety related items and activities isapplicable to comparable items and activities controlled by 10CFR 72 and transportation packages controlled by 10 CFR 71.

b. The NRC is to be notified of QAPM changes in accordance with 10 CFR50.54(a)(3).

B. PERFORMANCENVERIFICATION

1. Methodology

a. Personnel performing work activities such as design, engineering,procurement, manufacturing, construction, installation, startup,maintenance, modification, operation, and decommissioning areresponsible for achieving acceptable quality.

b. Personnel performing verification activities are responsible for verifyingthe achievement of acceptable quality and are different personnel thanthose who performed the work.

c. Work is accomplished and verified using instructions, procedures, orother appropriate means that are of a detail commensurate with theactivity's complexity and importance to safety.

d. Criteria that define acceptable quality are specified, and quality isverified against these criteria.

2. Design Control

a. The design control program is established and implemented to assurethat the activities associated with the design of systems, components,structures, and equipment and modifications thereto, are executed in aplanned, controlled, and orderly manner.

b. The program includes provisions to control design inputs, processes,outputs, changes, interfaces, records, and organizational interfaces.

C. Design inputs (e.g., performance, regulatory, quality, and qualityverification requirements) are to be correctly translated into designoutputs (e.g., specifications, drawings, procedures, and instructions).

d. The final design output is to relate to the design input in sufficient detailto permit verification.

7 7 Revision 16 1

.8

B.2 (continued)

e. The design process is to ensure that items and activities are selectedand independently verified consistent with their importance to safety toensure they are suitable for their intended application.

f. Changes to final designs (including field changes and modifications) a nddispositions of non-conforming items to either use-as-is or repair are tobe subjected to design control measures commensurate with thoseapplied to the original design and approved by the organization thatperformed the original design or a qualified designee.

g. Interface controls (internal and external between participating designorganizations and across technical disciplines) for the purpose ofdeveloping, reviewing, approving, releasing, distributing, and revisingdesign inputs and outputs are defined in procedures.

h. Design documentation and records, which provide evidence that thedesign and design verification process was performed in accordancewith this program, shall be collected, stored, and maintained inaccordance with documented procedures. This documentation includesfinal design documents, such as drawings and specifications, andrevisions thereto and documentation which identifies the important steps,including sources of design inputs that support the final design.

i. Additional details concerning design control activities may be found inthe Regulatory Guides and associated Standards as committed to inSection A.7 and Table 1 (e.g., Regulatory Guide 1.64).

3. Design Verification

a. A program is established and implemented to verify the acceptability ofdesign activities and documents for the design of items. The selectionand incorporation of design inputs and design processes, outputs, andchanges are verified.

b. Verification methods include, but are not limited to, design reviews,alternative calculations, and qualification testing. The extent of thisverification will be a function of the importance to safety of the item, thecomplexity of the design, the degree of standardization, the state of theart, and the similarity with previously proven designs. Standardized orpreviously proven designs will be reviewed for applicability prior to use.

c. When a test program is used to verify the acceptability of a specificdesign feature, the test program is to demonstrate acceptableperformance under conditions that simulate the most adverse designconditions that are expected to be encountered.

8 8 Revision 16 1

B.3 (continued)

d. Independent design verification is to be completed before design outputsare used by other organizations for design work and before they areused to support other activities such as procurement, manufacture, orconstruction. When this timing cannot be achieved, the unverifiedportion of the design is to be identified and controlled. In all cases, thedesign verification "is to be completed before relying on the item toperform its function.

e. Individuals or groups responsible for design reviews or other verificationactivities shall be identified in procedures and their authority andresponsibility shall be defined and controlled. Design verification shallbe performed by any competent individuals or groups other than thosewho performed the original design but who may be from the sameorganization. The designer's immediate supervisor may perform thedesign verification provided:

1. the supervisor is the only technically qualified individual capableof performing the verification,

2. the need is individually documented and approved in advance bythe supervisor's management, and

3. the frequency and effectiveness of the supervisor's use as adesign verifier are independently verified to guard against abuse.

f. Design verification procedures are to be established and implemented toensure that an appropriate verification method is used, the appropriatedesign parameters to be verified are chosen, the acceptance criteria areidentified, the verification is satisfactorily accomplished, and the resultsare properly recorded.

g. Additional details concerning design verification activities may be foundin the Regulatory Guides and associated Standards as committed to inSection A.7 and Table 1 (e.g., Regulatory Guide 1.64).

4. Procurement Control

a. A program is established and implemented to ensure that purchaseditems and services are of acceptable quality.

b. The program includes provisions for evaluating prospective suppliersand selecting only qualified suppliers.

9 9 Revision 16 1

B.4 (continued)

C. The program includes provisions for ensuring that qualified supplierscontinue to provide acceptable products and services.

d. The program includes provisions (e.g., source verification, receiptinspection, pre-installation and post-installation tests, and certificates ofconformance) for accepting purchased items and services.

e. Applicable technical, regulatory, administrative, and reportingrequirements (e.g., specifications, codes, standards, tests, inspections,special processes, and 10 CFR Part 21) are invoked for procurement ofitems and services.

f. The program includes provisions for ensuring that documented evidenceof an item's conformance to procurement requirements is available at thesite before the item is placed in service or used unless otherwisespecified in procedures.

g:, The program includes provisions for ensuring that procurement,inspection, and test requirements have been satisfied before an item isplaced in service or used unless otherwise specified in procedures.

h. The procurement of components, including spare and replacement parts,is subject to quality and technical requirements suitable for their intendedservice.

i. Appropriate controls for the selection, determination of suitability forintended use (critical characteristics), evaluation, receipt, and qualityevaluation of commercial grade items are to be imposed to ensure thatthe items will perform satisfactorily in service.

j. Additional details concerning procurement control may be found in theRegulatory Guides and associated Standards as committed to in SectionA.7 and Table 1 (e.g., Regulatory Guides 1.33 and 1.123).

5. Procurement Verification

a. A program is established and implemented to verify the quality ofpurchased items and services at intervals and to a depth consistent withthe item's or service's importance to safety, complexity, and quantity andthe frequency of procurement.

b. The program is executed in all phases of procurement. As necessary,this may require verification of activities of suppliers below the first tier.

10 10 Revision 16 1

B.5 (continued)

C. Additional details concerning procurement verification may~be found inthe Regulatory Guides and associated Standards as committed to inSection A.7 and Table 1 (e.g., Regulatory Guides 1.123 and 1.144).

6. Identification and Control of Items

a. A program is established and implemented to identify and control itemsto prevent the use of incorrect or defective items.

b. Identification of each item is maintained throughout fabrication, erection,installation, and use so that the item can be traced to its documentation.Traceability is maintained to an extent consistent with the item'simportance to safety.

C. Additional details concerning identification and control of items may befound in the Regulatory Guides and associated Standards as committedto in Section A.7 and Table 1 (e.g., Regulatory Guide 1.33).

7. Handling, Storage, and Shipping

a. A program is established and implemented to control the handling,storage, shipping, cleaning, and preserving of items to ensure the itemsmaintain acceptable quality.

b. Special protective measures (e.g., containers, shock absorbers,accelerometers, inert gas atmospheres, specific moisture content levels,and temperature levels) are specified and provided when required tomaintain acceptable quality.

C. Specific procedures are developed and used for cleaning, handling,storage, packaging, shipping, and preserving items when required tomaintain acceptable quality.

d. Items are marked and labeled during packaging, shipping, handling, andstorage to identify, maintain, and preserve the items' integrity andindicate the need for special controls.

e. Additional details concerning handling, storage, and shipping activitiesmay be found in the Regulatory Guides and associated Standards ascommitted to in Section M. and Table 1 (e.g., Regulatory Guide 1.38).

11 11 Revision 161

8. Test Control

*a. A test control program is established and implemented to demonstratethat items will perform satisfactorily in service.

b. Criteria are defined that specify when testing is required.

c. The test control program includes, as appropriate, proof tests beforeinstallation, pre-operational tests, post-maintenance tests, post-modification tests, and operational tests.

d. Test procedures are developed that include:

1 . instructions and prerequisites to perform the test,

2. use of proper test equipment,

3. acceptance criteria, and

4. mandatory inspections as required.

e. Test results are evaluated to assure that test objectives and inspectionrequirements have been satisfied.

f. Unacceptable test results shall be evaluated.

g. Additional details concerning test control may be found in the RegulatoryGuides and associated Standards as committed to in Section A.7 andTable 1 (e.g., Regulatory Guide 1.33).

9. Measuring and Test Equipment Control

a. A program is established and implemented to control the calibration,.maintenance, and use of measuring and test equipment. Measuring andtest equipment does not include permanently installed operatingequipment or test equipment used for preliminary checks where dataobtained will not be used to determine acceptability or be the basis fordesign or engineering evaluation. Additionally, calibration and controlmeasures are not required for rulers, tape measures, levels and othersuch devices if normal commercial manufacturing practices provideadequate accuracy.

b. The types of equipment covered by the program (e.g., instruments, tools,gauges, and reference and transfer standards) are defined inprocedures.

12 12 Revision 16 1

B.9 (continued)

C. Measuring and test equipment is calibrated at specified intervals orimmediately before use on the basis of the item's required accuracy,intended use, frequency of use, and stability characteristics and otherconditions affecting its performance.

d. Measuring and test equipment is labeled, tagged, or otherwise controlledto indicate its calibration status and to ensure its traceability to calibrationtest data.

e. Measuring and test equipment is calibrated against standards that havean accuracy of at least four times the required accuracy of theequipment being calibrated or, when this is not possible, have anaccuracy that ensures the equipment being calibrated will be within therequired tolerance.

f. If nationally recognized standards exist, calibration standards are to betraceable to them. Except where calibration standards with the sameaccuracy as the instruments being calibrated are shown to be adequatefor the requirements, calibration standards are to have a greateraccuracy than the standards being calibrated.

g. Measuring and test equipment found out of calibration is tagged orsegregated. The acceptability shall be determined of items measured,inspected, or tested with an out-of-calibration device.

h. Additional details concerning measuring and test equipmen t control maybe found in the Regulatory Guides and associated Standards ascommitted to in Section A.7 and Table 1 (e.g., Regulatory Guides 1.30,1.33, 1.94, 1.116, and 1.123).

10. Inspection, Test, and Operating Status

a. The status of required inspections and tests and the operating status ofitems is verified before release, fabrication, receipt, installation, test, anduse, as applicable. This verification is to preclude inadvertent bypassingof inspections and tests and to prevent inadvertent operation ofcontrolled equipment.

b. The application and removal of inspection, test, and operating statusindicators are controlled in accordance with procedures.

13 13 Revision 16 1

B.10 (continued)

c. Additional details concerning inspection, test, and operating statuscontrol may be found in the Regulatory Guides and associatedStandards as committed to in-Section A.7 and Table 1 (e.g., RegulatoryGuide 1.33).

11. Special Process Control

a. A program is established and implemented to ensure that specialprocesses are properly controlled.

b. The criteria that establish which processes are special are described inprocedures. The following are special processes:

1. welding,

2. heat-treating,

3. NDE (Non-Destructive Examination),

4. chemical cleaning, and

5. unique fabricating or testing processes that require in-processcontrols.

c. Special processes are accomplished by qualified personnel, usingappropriate equipment, and procedures in accordance with applicablecodes, standards, specifications, criteria, and other special requirements.

d. Additional details concerning special process control may be found in theRegulatory Guides and associated Standards as committed to in SectionA.7 and Table 1 (e.g., Regulatory Guide 1.33).

12. Inspection

a. A program is established and implemented for inspections of activities inorder to verify conformance to the documented instructions, proceduresand drawings for accomplishing the activity. The inspection programmay be implemented by or for the organization performing the activity tobe inspected.

b. Provisions to ensure inspection planning is properly accomplished are tobe established. Planning activities are to identify the characteristics andactivities to be inspected, the inspection techniques, the acceptancecriteria, and the organization responsible for performing the inspection.

14 14 Revision 16 1

q,

B.12 (continued)

c. Provisions to identify inspection hold points, beyond which work is not toproceed without the consent of the inspection organization, are to bedefined.

d. Inspection results are to be documented by the inspector and reviewedby qualified personnel.

e. Unacceptable inspection results shall be evaluated and resolved inaccordance with procedures.

f. Inspections are performed by qualified personnel other than those whoperformed or directly supervised the work being inspected. Whileperforming the inspection activity the inspectors functionally report to theassociated manager responsible for quality assurance or a managerresponsible for materials, purchasing, and contracts as appropriate.

g. Additional details concerning inspections may be found in the RegulatoryGuides and associated Standards as committed to in Section A.7 andTable 1 (e.g., Regulatory Guides 1.33 and 1.58).


a. Procedures shall provide for identification, evaluation, and resolution ofconditions adverse to quality.

b. Reworked, repaired, and replacement items are to be inspected andtested in accordance with the original inspection and test requirementsor specified alternatives.

C. Additional details concerning corrective action activities may be found inSection A.6 and the Regulatory Guides and associated Standards ascommitted to in Section A.7 and Table 1 (e.g., Regulatory Guide 1.33).

14. Document Control

a. A program is established and implemented to control the development,review, approval, issue, use, and revision of documents.

15 15 Revision 16 [

B.14 (continued)

b. The scope of the document control program includes:

1. safety analysis report,

2. design documents,

3. procurement documents,

4. Technical Specifications,

5. procedures, manuals, and plans,

6. corrective action documents, and

7. other documents as defined in procedures.

C. Revisions of controlled documents are reviewed for adequacy andapproved for release by the same organization that originally reviewedand approved the documents or by a designated organization that isqualified and knowledgeable.

d. Copies of controlled documents are distributed to and used by theperson performing the activity.

e. The distribution of new and revised controlled documents is inaccordance with procedures. Superseded documents are controlled.

f. Additional details concerning document control may be found in theRegulatory Guides and associated Standards as committed to in SectionA.7 and Table 1 (e.g., Regulatory Guide 1.33).

15. Records

a. A program is established and implemented to ensure that sufficientrecords of items and activities (e.g., design, engineering, procurement,manufacturing, construction, inspection and test, installation, pre-operation, startup, operations, maintenance, modification,decommissioning, and audits) are generated and maintained to reflectcompleted work.

b.. The program provides provisions for the admini stration, receipt, storage,preservation, safekeeping, retrieval, and disposition of records.

16 16 Revision 16 1

B.15 (continued)

C. The program includes provisions for the use of various record storagemedia to maintain QA records. Procedures are developed to implementthe regulatory guidance associated with the media used. The NRCGeneric Letter 88-18 "Plant Record Storage on Optical Disk" isimplemented for optical disk media. The Regulatory Issue Summary2000-18 "Guidance on Managing QA Records in Electronic Media" isimplemented for electronic media.

d. Additional details concerning record requirements may be found in theRegulatory Guides and associated Standards as committed to in SectionA.7 and Table 1 (e.g., Regulatory Guide 1.88).

C. AUDIT

1. Methodology

a. Personnel responsible for carrying out audits are maintained cognizantof day-to-day activities by the ongoing involvement in the qualityassurance program requirements so that they can act in a managementadvisory function.

b. Organizations performing audits are to be technically and performanceoriented commensurate with the activity being reviewed.

C. Personnel performing audits have no direct responsibilities in the areathey are assessing.

d. Audits are accomplished using instructions, procedures, or otherappropriate means that are of a detail commensurate with the activity'scomplexity and importance to safety.

2. Performance

a. A program of planned and periodic audits is established andimplemented to confirm that activities affecting quality comply with theQAPM and that the QAPM has been implemented effectively. Auditfrequencies will be implemented as required by the applicable Code ofFederal Regulations, safety analysis report, and commitments by variouscorrespondence to the NRC. Audits will be conducted at a frequency inaccordance with either Section C.2.a.1 or Section C.2.a.2 below. Auditsof stand alone Independent Spent Fuel Storage Installations (lSFSls)(e.g. those not sited with an operating nuclear power plant) may beconducted in accordance with Section C.2.a.4.

17 17 Revision 16 1

C.2 (continued)

1. Audit frequencies will be determined in accordance with aperformance based audit-schedu ling program. The schedulingprogram, through an expert panel, uses assessment indicators toidentify and schedule audits based on performance results andimportance of the activity relative to safety. Potential audit subjectareas are periodically assessed against appropriate performancecriteria. From these reviews a determination is made in regard tothe depth, scope, and scheduling of specific audits. Functionalareas important to safety are assessed annually (± 25%) to identifystrengths and weaknesses (if applicable) to determine the level andfocus of independent oversight activities for the upcoming year.The basis for the assessment shall include the results of audits andsurveillance, NRC inspections, LERs, self-assessments, andapplicable conditions reports (e.g., non-conformance and correctiveaction reports). Personnel changes, change/increase in functionalarea responsibilities, industry operating experience, and INPOevaluations will also be considered. Each area will be assigned arating with a comparison to previous years. This assessment will bedocumented, reviewed, and approved by quality assurancemanagement.

This document is considered a quality assurance record and will beavailable for NRC review. Audit subject areas of Section C.2.a.2shall continue to be audited on the frequencies designated unlessexpert panel judgment, based on performance results, determinessuch an audit to be unnecessary. In such cases the expert panelbasis shall be documented.

2. Audit schedules assure that the following areas are audited at theindicated frequencies, or more frequently as performancedictates.

a. The conformance of each unit's operation to provisionscontained within the Technical Specifications and applicablelicense conditions is audited at least once every 24 months.

b. The performance, training, and qualifications of the entirestaff are audited at least once every 24 months.

18 18 Revision 161

C.2 (continued)

C. The results of actions taken to correct deficiencies occurringin unit equipment, structure, systems, or method of operationthat affect nuclear safety is audited at least once every 24months.

d. The performance of activities required by the QAPM to meetthe criteria of 10 CER 50, Appendix B is audited at leastonce every 24 months.

e. The Offsite Dose Calculations Manual and Process ControlProgram and implementing procedures are audited at leastonce every 24 months.

f. The radiological environmental monitoring program and theresults thereof is audited at least once every 24 months.

g. A fire protection and loss prevention program inspection andaudit shall be performed using either off-site licenseepersonnel or an outside fire protection firm at least onceevery 24 months.

h. The fire protection program and implementing proceduresaudit shall be performed at least once every 24 months.

i. A fire protection and loss prevention program inspection andaudit shall be performed using an outside fire consultant atleast once every 36 months.

3. A grace period of 90 days may be applied to the 24-monthfrequency for internal audits. For activities deferred inaccordance with the 90-day grace period, the next performancedue date will be based on their originally scheduled date.

4. The audit schedule for stand alone 1SFSIs may combineaudits to cover the areas defined in section C.2.a.2 that areinvoked by the ISFSI technical specifications.

b. Audits shall provide an objective evaluation of quality related practices,procedures, instructions, activities, and items and a review of documentsand records, as applicable.

c. Audits shall be performed in accordance with approved writtenprocedures or checklists. Items from previous audits shall be reviewedand reaudited, as appropriate. The checklists are used as guides to theauditor.

19 Revision 16 1

C.2 (continued)

d. Scheduling and resource allocation are based on the status and safetyimportance of the activity or process being assessed.

e. Scheduling is dynamic and resources are supplemented when theeffectiveness of the quality assurance program is in doubt.

f. Audit reports are written and distributed to the appropriate levels ofmanagement for review. Follow-up action, including re-look at deficientareas, is initiated as deemed appropriate.

g. Implementation of delegated portions of the quality assurance programis assessed.

h. Audits are conducted using predetermined acceptance criteria.

L Additional details concerning audits may be found in the RegulatoryGuides and associated Standards as committed to in Section A.7 andTable 1 (e.g., Regulatory Guides 1.33 and 1.144).

0. INDEPENDENT SAFETY REVIEW

1. Description

a. Independent safety review is performed to meet the individual unit'scommitment to NUREG-0737, Section l.B.1.2, "Independent SafetyEngineering Group," as described in the unit's safety analysis report.

20 20 Revision 16 1


A. Regulatory Guide 1.8 Revision 1, dated September 1975


1. General

2. General

Qualification requirements for personnel, other than LicensedOperators covered under IOCFR55, shall meet ANSI/ANS 3.11978 except for positions where an exception to either ANSI/ANS3.1-1978 or N 18.1 -1971 is stated in the applicable unit'sTechnical Specifications. If an exception exists for a given position,the applicable unit's Technical Specification qualificationrequirements shall apply.

Individuals filling positions who met the previous commitment atthe time of implementation of this commitment can be consideredto meet any more restrictive aspects of the requirements of thiscommitment for that position without further review anddocumentation.

The following qualifications may be considered equivalent to a

bachelor's degree:

a. 4 years of post secondary schooling in science or engineering,

b. 4 years of applied experience at a nuclear facility in the areafor which qualification is sought,

c. 4 years of operational or technical experience/training innuclear power, or

d. any combination of the above totaling 4 years.

Years of experience used to meet the education requirements asallowed by this exception shall not be used to also meet theexperience requirements.

21 21 Revision 16 1

Table 1Regulatory Commitments

B. Regulatory Guide 1.30, dated August 1972


1. ANSI N45.2.4General

2. ANSI N45.2.4Section 3



ANSI N45.2.4 identifies Various tests to be performed. Theapplicability of these tests will be determined as discussed inQAPM Section B.8 and based upon the significance of change ormodification.

Documented routine inspections and audits of the storage areamay be performed instead of the requirements of this Section.

In some cases, testing requirements may be met by post-installation surveillance testing in lieu of a special post-installationtest.

The last sentence of this section states: "Items requiring calibrationshall be tagged or labeled on completion indicating date ofcalibration and identity of the person that performed thecalibration." Instead of requiring the tagging or labeling of allequipment this statement is changed to require the equipment tobe suitably marked to indicate the date of the next requiredcalibration and the identity of the person that performed thecalibration.

22 22 Revision 16 1


C. Regulatory Guide 1.33 Revision 2, dated February 1978


1. Section C.1

2. Section 0.4

3. ANSI N18.7Section 1



Entergy will provide procedures for the guide's Appendix A activities'as discussed. However, Entergy does not consider all activitieslisted to be "safety-related" (e.g., activities in 7.e).

This section establishes minimum 2-year audit frequency for allsafety related functions and recommends audit frequencies specificto Corrective Action, Facility Operation, and Staff Performance,Training, and Qualifications. Entergy will perform audits atfrequencies as discussed in QAPM Section C.2.a instead of thissection.

Sentences 4 and 5 state, "However, applicable sections of thisstandard should be used as they apply to related activities. Activitiesincluded are: Design Changes, Purchasing, Fabricating.."Withregard to radioactive material transportation activities, Entergy willonly implement the requirements associated with those activitiesconducted in accordance with the applicable NRC Quality AssuranceProgram Approval for Radioactive Material Packages.

The specific areas of experience described in this section are notapplicable to the on-site safety review committee but the committeemust be comprised of site operating or engineering supervisorypersonnel. Additionally, the off-site safety review committee needcontain experience in only a majority of the areas.

The statement that "no more than a minority of the quorum shallhave line responsibility for the operation of the plant" is notapplicable to the on-site safety review committee.

23 23 Revision 161




6. ANSI N18.7Section4.3.4.(1) & (2)

7. ANSI N18.7Section 4.3.4(2)

8. ANSI N 18.7Section 4.3.4(3)

9. ANSI N 18.7Section 4.3.4(4)

10. ANSI N18.7Section 4.3.4(5)

11. ANSINI18.7Section 4.5

12. ANSI N18.7Section 4.5

13. ANSI N18.7Section 5.1

10 CFR,50.59 was revised through Federal Register Notice19991001 R1 N3150-AF94 eliminating the terms "safety evaluation"and "unreviewed safety question." The term "safety evaluation" hasbeen replaced with 10 CFR 50.59 "evaluation." The term"unreviewed safety question," as defined in the previous version of10 CFR 50.59 (a)(2), was replaced by criteria provided in 50.59(c)(2)to determine if a license amendment pursuant to 50.90 is requiredprior to implementing the change, test, or experiment.

Reviews associated with changes to the technical specifications willbe performed in accordance with Section 4.3.4(3) instead of thissection.Revision to proposed Technical Specification changes only requirereview in accordance with this section when the revision involves asignificant change to the technical basis for the proposed change.

In place of the requirements of this section, the on-site and off-sitesafety review committees shall review facility operations to detectpotential nuclear safety hazards and all reports made in accordancewith 10 CFR 50.73.

An example of the matters reviewed by the on-site safety reviewcommittee in accordance with this section is a change to theEmergency Plan (except editorial changes).

This section establishes minimum 2-year audit frequency for allsafety related functions. Entergy will perform audits at frequenciesas discussed in QAPM Section C.2.a instead of this section.

The independent review body discussed in this section is the off-sitesafety review committee.

Instead of the requirements of this section to have a summarydocument, a method of cross-referencing these requirements to theimplementing procedures will be maintained.

24 24 Revision 16 1










The person who holds a senior reactor operators license for theaffected unit and approves a temporary change to a procedure is notrequired to be in charge of the shift.

In addition to the temporary procedure change process described forchanges which clearly do not change the intent of a procedure,temporary procedure changes which may change the intent of aprocedure may be made following the process described in this*section. Except that the person normally responsible for approvingrevisions to the procedure is the approval authority for the change.

Instead of the requirements of this section concerning non-conforming conditions, non-conforming conditions will be evaluatedand controlled in accordance with the corrective action program.

The requirement of the fifth paragraph of this section to have a log ofthe status of temporary modifications is not applicable to temporarymodifications for routine tasks installed in accordance withprocedures. These procedures shall provide assurance thatapprovals are obtained, temporary modification activities areindependently verified by an individual cognizant of the purpose andthe effect of the temporary modification, and that activities areadequately documented to indicate the status of the temporarymodification.

This section will be implemented by adding the words "Wherepractical" in front of the first and fourth sentences of the fifthparagraph. For modifications where the requirements of the fourthsentence are not considered practical, a review in accordance withthe provisions of 10 CFR 50.59 will be conducted.

In lieu of a "master surveillance schedule," the following requirementshall be complied with: "A surveillance testing schedule(s) shall beestablished reflecting the status of all in-plant surveillance tests andinspections."

25 25 Revision 16 1





21. ANSI N18.7Section.5.2.13.1

22. ANSI N 18.7Section 5.2.14




26. ANSI N 18.7Section 5.3.9.3

The requirements of the Physical Security Plan shall be implementedin place of these general requirements.

Consistent with ANSI N45.2,1 1 Section 7.2, minor changes todocuments, such as inconsequential editorial corrections, orchanges to commercial terms and conditions may not require thatthe revised document receive the same review and approval as theoriginal documents.

Where marking, tagging, or physical separation of the non-conforming item is not feasible, the non-conforming item may becontrolled by the use of appropriate documentation.

Required procedure reviews following the occurrences discussed inSection 5.2.15, paragraph 3, sentence 3, are determined andcontrolled in accordance with the QAPM Section A.6 instead of thissection.

This section requires plant procedure review by an individualknowledgeable in the area affected by the procedure no lessfrequently than every two years to determine if changes arenecessary or desirable. Instead of this review, controls are in effectto ensure that procedures are reviewed for possible revision uponidentification of new or revised source material potentially affectingthe intent of procedures.

Instead of the requirements of this section, the format and content ofthe emergency operating procedures follow the applicable NRCapproved format for the specific unit.

Entergy's NRC accepted Emergency Plan will be implemented in lieuof the requirements in this section.

26 26 Revision 16 1


D. Regulatory Guide 1.37, dated March 1973


1. General

2. Section C.3

3. Section C.4

4. ANSI N45.2.1Section 5

Instead of using the cleanliness level classification system ofANSI N45.2.1, the required cleanliness for specific items and activitiesis addressed on a case-by-case basis. Cleanliness is maintained,consistent with the work being performed to prevent introduction offoreign material. As. a minimum, cleanliness inspections are performedprior to system closure and such inspections are documented.

The water quality for final flushes of fluid systems and associatedcomponents is at least equivalent to the quality of the operatingsystem water, except for the oxygen and nitrogen content.

As an alternate to the requirements of this section, contaminationlevels in expendable products may be based upon safe practices andindustrial availability with documented engineering evaluations.Contaminant levels are controlled such that subsequent removal bystandard cleaning methods results in the achievement of finalacceptable levels that are not detrimental to the materials.

Any nonhalogenated material may be used which is compatible withthe parent material not just plastic film.

27 27 Revision 16 1


E. Regulatory Guide 1.38 Revision 2, dated May 1977








Storage of an item in a higher-level storage area meets the lowerlevel storage requirements.

As an alternate to the requirements in Section 3.2.1 items (4), (5),and 7, Section 3.2.2, Section 3.2.3 item (1), and Section 3.2.4 item(2), the storage atmosphere may be controlled such that it is free ofharmful contaminants in concentration that could produce damage tothe stored item and protecting weld end preparations and threads bycontrolling the manner in which the item is stored.

Cleated, sheathed boxes may be used up to 1000 lb. rather than 500lb. as specified in 3.7.1 (1). Special qualification testing may berequired for loads over 1000 lb.

Skids and runners will normally be fabricated from a minimum 2 X 4inch nominal lumber size and laid flat except where this is impracticalbecause of the small dimensions of the container. If forklift handling,is required, minimum floor clearance for forklift tines will be provided.

Inspections of packages and/or preservative coatings are madeimmediately prior to loading rather than after loading.

Warehouse personnel will normally visually scrutinize incomingshipments for damage of the types listed in this section, this activity isnot necessarily performed prior to unloading. Separatedocumentation of the shipping damage inspection is not necessary.Release of the transport agent after unloading and the signing forreceipt of the shipment provides adequate documentation ofcompletion of the shipping damage inspection. Any non-conformances noted will be documented and dispositioned. Personsperforming the visual scrutiny during unloading are not considered tobe performing an inspection function as defined under Reg. Guide1 .74; therefore, while they will be trained to perform this function,they may not be certified (N45.2.6) as an inspector.

28 28 Revision 16 1





The second division of this subsection requires six additionalinspection activities if an item was not inspected or examined at thesource. Entergy will consider that a source inspection has beenconducted if the supplier of the item is required to comply with ANSIN45.2.2 for the purchased item and if the supplier's program hasbeen audited and found acceptable in the area (i.e., the supplierperforms a source inspection of his supplier or conducts a receiptinspection that includes, as applicable, the six additional itemslisted).

Instead of the requirement that receiving inspections be performedin an area equivalent to the level of storage required for the item,receiving inspections will be performed in a manner and in anenvironment which does not endanger the requisite quality of anitem. The receiving inspection's location environmental controls maybe less stringent than storage environmental requirements for thatitem; however, the short time spent in the less stringent receivinginspection area shall be of such duration that it will not adverselyaffect the item being received.

The "Special Inspection" procedure is not required to be attached tothe item or container but shall be readily available-to inspectionpersonnel.

Items which fall within the Level D classification of the standard willbe stored in an area which may be posted to limit access, but otherpositive controls such as fencing or guards may not be provided.

The sentence is replaced with the following: "The use or storage offood, drinks, and salt tablet dispensers in any storage area shall becontrolled and shall be limited to designated areas where such useor storage is not deleterious to stored items."




29 29 Revision 16 1









The sentence is replaced with the following: " Exterminators or otherappropriate measures shall be used to control animals to minimizepossible contamination and mechanical damage to stored material.If evidence of animal activity is detected, a survey or inspection willbe utilized to determine the extent of the damage."

An alternate to the stated requirement is the following: "Hazardouschemicals, paints, solvents, and other materials of a like nature shallbe stored in approved cabinets or containers which are not in closeproximity to installed systems required for safe shutdown.'

Care of items in storage shall be exercised in accordance with thefollowing: "Types of components that could require maintenancewhile in storage shall be identified and evaluated for specificmaintenance requirements. Maintenance activities 6.4.2 (6) through6.4.2 (8) listed in this requirement shall be considered during thisevaluation and any deviations shall be justified and documented."

The last sentence of this section is not applicable to the operationsphase.

Entergy will comply with this section's requirements with theclarification that, for record purposes, only the access of personnelwithout key cards into indoor storage areas shall be recorded.Unloading or pickup of material shall not be considered "access," norshall inspection by NRC or other regulatory agents, nor shall toursby nonlicensee employees who are accompanied by licenseeemployees.

30 30 Revision 16 1









Re-rating hoisting equipment will be considered only whennecessary. Prior to performing any lift above the load rating, theequipment manufacturer must be contacted for his approval anddirection. The manufacturer must be requested to supply a,document granting approval for a limited number of lifts at the newrating and any restrictions involved, such as modifications to bemade to the equipment and the test lift load. At all times, thecodes governing re-rating of hoisting equipment must beobserved.

During printing of the standard, a transposition occurred betweenthe last sentence of A3.4.1(4) and A3.4.1(5). The correctrequirements are: (4) "However, preservatives for inaccessibleinside surfaces of pumps, valves and pipe systems containingreactor coolant water shall be the water flushable type." (5) "Thename of the preservative used shall be indicated to facilitate touchUP."

There may be cases involving large or complex shaped items forwhich an inert or dry air purge is provided, rather than a static gasblanket, in order to provide adequate protection due to difficulty ofproviding a leak proof barrier. In these cases, a positive pressurepurge flow may be utilized as an alternate to a leakproof barrier.

Instead of the requirement for. non-metallic plugs and caps to bebrightly colored, non-metallic plugs and caps shall be anappropriately visible color.

This paragraph limits halogen and sulfur content of tape. The useof tapes containing greater amounts of halogens than thoseidentified will be allowed after appropriate evaluation; however,the quantities shall not be such that harmful concentrations couldbe leached or released by breakdown of the compounds underexpected environmental conditions.

31 31 Revision 16 1









In lieu of A3.7.1(3) and (4), Entergy will comply with the following:Fiberboard boxes shall be securely closed either with a water -

resistant adhesive applied to the entire area of contact betweenthe flaps, or all seams and joints shall be sealed with not less than2-inch wide, water resistant tape.

Instead of the requirement that container markings appear on aminimum of two sides of the con tainer, preferably on one side andone end, Entergy will comply with the following: Containers areadequately marked for storage, identification, and retrieval.Multiple marking requirements are imposed, where necessary.

Instead of the requirement that container markings be no lessthan 3/4" high, Entergy will comply with the following: Containermarkings are of a size which permits easy recognition.

Instead of the specific container marking requirements, Entergywill comply with the following: The information required incontainer marking is evaluated on a case-by-case basis.

The last paragraph of A.3.9 could be interpreted as prohibiting anydirect marking on bare austenitic stainless steel and nickel alloymetal surfaces. As a alternate, paragraphs A.3 '9.(1) and (2) maybe used to control marking on the surface of austenitic stainlesssteels and nickel base alloys based on documented engineeringevaluations. Contamination levels are controlled such that thematerial used for marking is not detrimental to the materialsmarked.

32 32 Revision 161


F. Regulatory Guide 1.39 Revision 2, dated September 1977


1. ANSI N45.2.3General






The ANSI five level zone designation system may not be utilized, butthe intent of the standard will be met for the areas of housekeeping,plant and personnel safety, and fire protection.

This section is not applicable.

The Fire Protection Program shall be used in lieu of the generalrequirements in this section.

The first paragraph is not applicable to the operations phase.


Subparagraph (1) is not applicable to the operations phase; (2), (3),and (4) will be implemented.

33 33 Revision 16 1


G. Regulatory Guide 1.58 Revision 1, dated September 1980


1. General

2. General






Entergy may choose not to apply the requirements of this guide tothose personnel who are involved in day-to-day operations,surveillance', maintenance, and certain -technical and supportservices whose qualifications are controlled by the TechnicalSpecifications or other QAPM commitment requirements.

Certification of inspectors in accordance with this guide isapproved by a manager responsible for quality assurance exceptfor inspectors performing inspections as part of the procurementprocess. These inspectors may be approved by a managerresponsible for materials, purchasing, and contracts.

Paragraph 4 requires that the standard be imposed on personnelother than licensee employees; the applicability of this standard tosuppliers will be documented and applied, as appropriate, inprocurement documents for such suppliers.

The requirements of this standard do not apply to personnel usinglater editions of ASNT contained within 1 OCFR5O.55a approvedASME editions or addenda.

This section requires, in part, that any person who has notperformed inspection, examination, or testing activities in hisqualified area for a period of one year shall be re-evaluated. A 90-day grace period may be applied to this activity. For activitiesdeferred in accordance with the 90-day grace period, the nextperformance due date will be based on their originally scheduleddate.This section's requirements are clarified with the stipulation that,where no special physical characteristics are required, none will bespecified. The converse is also true: if no special physicalrequirements are stipulated, none are considered necessary.

Entergy reserves the right to use personnel who do not meet theseexperience requirements but have shown capability throughtraining and testing or capability demonstration.

34 34 Revision 16 1


H. Regulatory Guide 1.64 Revision 2, dated June 1976



For the documentation of inter-disciplinary design reviews, there mustbe documented evidence of the acceptability of design documents, orportions thereof, prior to release (material, stress, physics,mechanical, electrical, concrete, etc.). Indication of the positiveconcurrence of those who determine the design acceptability relativeto their respective disciplinary area of concern should be on thedocument or on a separate form traceable to the document. Adocument that indicates the reviewer's comments need not beretained.

35 35 Revision 16 1


Regulatory Guide 1.74, dated February 1974


1. ANSI N45.2.10,Section 2

Definitions for "Certificate of Conformance" and "Certificate ofCompliance" will be exchanged based upon the guidance in ANSIN45.2.13 Section 10.2.

36 36 Revision 161


J. Regulatory Guide 1.88 Revision 2, dated October 1976


1. RG 1.88Section.C

Entergy will meet the requirements of NFPA No. 232-1975,"Standards for the Protection of Records", as allowed by theRegulatory Guide 1.88 -1976 or ANSI/ ASME NQA-1-1983,Supplement 17S-1 Section 4.4 in lieu of N45.2.9 Section 5.6 or thediscussions in this section for Records Storage Facilities with theclarification that penetrations providing fire protection, lighting,temperature/humidity control, or communications are acceptable aslong as the penetration maintains the required fire resistance.

Except that as an alternate to these requirements non-permanentrecords (e.g., 3 years retention records) may be stored andmaintained by the originating organization in one-hour minimum firerated file cabinets located in environmentally controlled facilities thathave suitable fire protection. Suitable fire protection is provided byeither an automatic sprinkler system or a combination of two or moreof the following: 1) automatic fire alarms, 2) hose stations, or 3)portable extinguishers.

Documents are considered completed when they are "completelyfilled out" (i.e., when sufficient information is recorded to fulfill therecord's intended purpose) and the adequacy of the document (e.g.,legibility) has been accepted by the document control or recordsmanagement organizations or designees.

The requirements for an index discussed in this section areconsidered to only require that a method of retrieving the record andcontrolling the identified information be established.

Instead of the requirements of this section, Entergy will comply withthe following: Records shall not be stored loosely. They shall besecured for storage in file cabinets or on shelving in containers.Methods other than binders, folders, or envelopes (e.g., dividers orboxes) may be used to organize records for storage. This section isnot applicable to special processed records controlled in accordancewith Section 5.4.3 when the requirements of this section are notappropriate for the record type.




37 37 Revision 16 1


J. Regulatory Guide 1.88 (continued)





Instead of the requirements of this section, Entergy will comply withthe following: Provisions shall be made for special processedrecords such as radiographs, photographs, negatives, microfilm, andmagnetic media to prevent damage from excessive light, stacking,electromagnetic fields, temperature, and humidity as appropriate tothe record type with appropriate consideration of packaging andstoring recommendations as provided by the manufacturer of thesematerials.

Routine general office and nuclear site security systems and accesscontrols are provided; no special security systems are required to beestablished for record storage areas.

Entergy will meet the requirements of NFPA No. 232 - 1975,"Standards for the Protection of Records", as allowed by theRegulatory Guide 1.88 - 1976 or ANSI/ASME NQA-1-1983,Supplement 1 7S-1 Section 4.4 in lieu of this section for RecordsStorage Facilities with the clarification that penetrations providing fireprotection, lighting, temperature/humidity control, or communicationsare acceptable as long as the penetration maintains the required fireresistance.

Except that as an alternate to these requirements non-permanentrecords (e.g., 3 years retention records) may be stored andmaintained by the originating organization in one-hour minimum firerated file cabinets located in environmentally controlled facilities thathave suitable fire protection. Suitable fire protection is provided byeither an automatic sprinkler system or a combination of two or moreof the following: 1) automatic fire alarms, 2) hose stations, or 3)portable extinguishers.

38 38 Revision 16 1


K. Regulatory Guide 1.94 Revision 1, dated April 1976




The last sentence requires that all items inspected with maintenanceand test equipment, which is found to be out of calibration, shall beconsidered unacceptable. Entergy will comply with QAPM SectionB.9.g as an alternate. QAPM Section B.9.g requires an evaluation todetermine the validity of previous measurements.

When using ACI-305-72 and ACI-306-66, Entergy may apply thefollowing requirements:

PLACING TEMPERATURES OF CONCRETE

A. During hot weather concreting, placing temperatures of concretewill be limited to the following: 1) Concrete members less than 3 feetin least dimension will not exceed 900F; 2) Concrete members from3 feet to 6 feet in least dimension will not exceed 700F; and 3)Concrete members more than 6 feet in least dimension will haveplacing temperature as near 50OF as can be obtained by use of ice asnecessary up to 100 percent of adding mixing water; and by shadingaggregate and sprinkling the coarse aggregate the day it is to beused. Care will be taken so that no unmelted ice remains in theconcrete at the end of the mixing period.

B. During cold weather concreting: In heating the water andaggregate, live steam to heat the fine and coarse aggregate shall notbe used. The permissible range for concrete temperature shall be asfollows: 1) Sections less than 3 feet in least dimensions 550F to 750F;and 2) Mass concrete 3 feet or more in least dimension 450F to 650F.The mixing water and aggregate will be purchased as required. Thematerials will be free of ice, snow and frozen lumps before they enterthe mixer.

As an alternate to daily testing grout for compressive strength, forprepackaged shelf item, non-shrink grout, the grout's compressivestrength tests may be performed once on each batch of non-shrinkgrout received, rather than each day grout is placed.

3. ANSI N45.2.5Table B

39 39 Revision 16 1


K. Regulatory Guide 1.94 (continued)


4. ANSI N45.2.5 For the performance of correlation tests, the requirements of thisSection 4.8 standard may be modified as discussed below:

Table B, REINFORCING STEEL: In-process testing of reinforcingsteel will include the mechanical properties of yield strength, tensilestrength and percent elongation on full size specimens for each barsize for each 50 tons or fraction thereof from each mill heat. Bendtests are performed during material qualification testing only, exceptas noted below for bar sizes #14 through #18.

Table A, "Required Qualification Tests" as applied to reinforcing steelwill include bend tests as required by ASTMV A615 and summarized inthe following: a) For bar sizes #3 through #11, one full size specimenfrom largest bar size rolled from each mill heat, unless material fromone heat differs by three or more designation numbers. When thisoccurs, one bend test shall be made from both the highest and lowestdesignation number of the deformed bars rolled; b) For bar sizes #14through #18, Supplementary Requirements S1 of ASTMV A615 will beapplied, i.e., one fullsize specimen for each bar size for each millheat. If supplementary requirements are not followed for mill tests,they will be applied as in-process tests.

In-process test specimens may be selected at the rebar fabricationshop, prior to start of fabrication of the rebar from the heat or fractionthereof represented by the test specimen.

Acceptance criteria for any failed test (qualifications as well as in-process) may be the same as that for tensile tests specified inSubarticle CC-2331.2 of ASME Section III, Div. 2 Code (1975). Thisstates that if a test specimen fails to meet the specified strengthrequirements, two (2) additional specimens from the same heat andof the same bar size would be tested, and if either of the twoadditional specimens fails to meet the specified strengthrequirements, the material represented by the tests would be rejectedfor the specified use. Alternative use of rejected material under strictcontrol may be subject to evaluation by engineering.

40 40 Revision 161


K. Regulatory Guide 1.94 (continued)




Entergy may interpret the terms "horizontal, vertical and diagonalbars", to apply respectively to the following types of splice positions: a.Horizontal, including 100 to horizontal; b. Vertical, including 100 tovertical; and c. 450 angle, including 100 to 800 angle. The words"1splicing crew" are interpreted to refer to all project members that areactively engaged in preparing and assembling cadweld mechanicalsplices at the final splice location. Separate test cycles will beestablished for each bar size and each splice position.

Entergy will comply with inspection requirements of the applicablewelding codes and any exceptions instead of this section.

41 41 Revision 161


L. Regulatory Guide 1.116 Revision O-R, dated June 1976


1. ANSI N45.2.8 Documented routine inspections and audits of the storage area maySection 3 be performed instead of the requirements of this section.

42 42 Revision 16 1

4 -1


M. Regulatory Guide 1.123 Revision 1, dated July 1977


1. RGI1.123Paragraph C.6.e






This paragraph shall be implemented as originally written inN45.2.13 (i.e., with the verb "should" instead of the verb"shall"). Entergy retains the ultimate responsibility forperformance of purchased equipment. The appropriateengineering discipline will exercise thismanagement/engineering prerogative with respect to the finaldecision on post installation test requirements.

Item c is an option which may be used to assure quality;however, any option given in 10 CFR 50 Appendix B, CriterionVII as implemented by the QAPM may also be used.

Instead of the definition provided for QA ProgramRequirements, Entergy will comply with the following: "Thoseindividual requirements of the QAPM which, when invoked intotal or in part, establish quality assurance programrequirements for the activity being controlled. Although notspecifically used in the QAPM, ANSI N45.2 may be imposedupon suppliers."

The "same degree of control" is stipulated to mean "equivalentlevel of review and approval." The changed document may notalways be reviewed by the originator; however, at least anequivalent level of management/supervision shall review andapprove any changes.

Changes to procurement documents which are changes inquantity, estimated price, cost codes, taxes, format or editorialchanges that do not affect the quality of the item or service donot require an equivalent level of review and approval as theoriginal document.

The requirements of the QAPM will be implemented instead ofthis section.

43 43 Revision 16 1


M. Regulatory Guide 1.123 (continued)



8. ANSI N45.2.13Section 8.2Item b

9. ANSI N45.2.13Section 10.2Item d

Supplier evaluations may be performed any time prior toplacing the purchased item in service.

Non-conformance notices for conditions described in thissection are only required to be submitted to Entergy when thenon-conformance could adversely affect the end use of an itemrelative to safety, interchangeability, operability, reliability,integrity or maintainability.

The section states that the certificate should be attested to by aperson who is responsible for this QA function whose functionand position are described in the Purchaser's/Supplier's QAprogram. As an alternate to this requirement, Entergy will usethe following: 'The person attesting to a certificate shall be anauthorized and responsible employee of the supplier, and shallbe identified by the supplier."

44 44 Revision 161


N. Regulatory Guide 1.144 Revision 1, dated September 1980


1. RG 1.144Section C.3.a.(2)

2. RG 1.144Section C.3.b.(2)

3. RG 1.144Section C.3.b.(2)

4. RGI1.144Section C.3.b.(2)




In addition to the requirements of this section, previously evaluatedand approved active suppliers for which auditing is not theselected method of source verification should be evaluatedconcurrent with the award of a contract. Regardless of theevaluation results, active suppliers (except those excluded underC.3.b(1)) are source verified (audit, surveillance or inspection)within two years prior to award of a contract or have sourceverification performed. Inactive suppliers are evaluated prior tosupplying items or services. An audit shall be conducted ifrequired to determine the acceptability of procured items orservices (i.e., acceptability cannot be determined by receiptinspection or another method allowable under 10 CFR 50Appendix B, Criterion VII).

This section requires that supplier audits be performed on atriennial basis. A 90-day grace period may be applied to thisactivity. For activities deferred in accordance with the 90-daygrace period, the next performance date will be based on theiroriginally scheduled date.

Instead of the annual documented evaluation of suppliersdiscussed in this section, an ongoing evaluation of supplierperformance is conducted which takes into account, whereapplicable, the other considerations of this section and paragraphof the Regulatory Guide.

Pre-audit and post-audit conferences may be fulfilled by a varietyof communications, such as telephone conversation.

Pre-audit and post-audit conferences are only held when deemednecessary by quality assurance or when requested by the auditedorganization.

45 45 Revision 16 1

.I I r I A


N. Regulatory Guide 1.144 (continued)


7. ANSI N45.2.12Section 4.3.2.2





This subsection could be interpreted to limit auditors to the reviewof only objective evidence; sometimes and for some programelements, no objective evidence may be available. Entergy willcomply with an alternate sentence which reads: "When available,objective evidence shall be examined for compliance with QAPMrequirements. If subjective evidence is used (e.g., personnelinterviews) then the audit report must indicate how the evidencewas obtained."

Pre-audit and post-audit conferences are only held when deemednecessary by quality assurance or when requested by the auditedorganization.

Pre-audit and post-audit conferences may be fulfilled by a varietyof communications, such as telephone conversation.

Instead of the last sentence of the last paragraph of the section,Entergy will comply with the following: The audit report shall beissued within thirty working days after the last day of the audit.The last day of an audit shall be considered to be the day of thepost-audit conference. If a post-audit conference is not heldbecause it was deemed unnecessary, the last day of the auditshall be considered to be the date the post-audit conference wasdeemed unnecessary as documented in the audit report.

The QAPM Section A.6 corrective action program may be usedinstead of these requirements as long as the appropriate timelimits are applied to significant conditions adverse to quality. Also,no additional documentation is necessary if needed correctiveactions are taken and verified prior to audit report issuance.

46 46 Revision 16 1

4 .4t i

.Table 1Regulatory Commitments

0. Regulatory Guide 1.146 Revision 0, dated August 1980


1. ANSI N45.2.23Section 2.3.1.3


3. ANSI N45.2.23Sections 3.2 and5.3

Holders of NRC-issued Reactor Operator/Senior Reactor OperatorLicenses comply with the requirements of this section and may beawarded two credits.

Prospective lead auditors shall demonstrate their ability to effectivelyimplement the audit process and lead an audit team. They shallhave participated in at least one audit within the year preceding theindividual's effective date of qualification. Upon successfuldemonstration of the ability to effectively lead audits, licensee.Management may designate a prospective lead auditor as a "leadauditor"'.

These sections require that an annual assessment be performed ofeach lead auditor's qualification and that each lead auditor's recordsbe updated annually. A 90-day grace period may be applied to theseactivities. For activities deferred in accordance with the 90-day graceperiod, the next performance due date will be based on theiroriginally scheduled date.

47 47 Revision 16 1