ML13007A136

Review of Operations Quality Assurance Plan, Revision 20

ML13007A136
Person / Time
Site:	South Texas
Issue date:	01/31/2013
From:	Balwant Singal Plant Licensing Branch IV
To:	Koehl D South Texas
Singal B
References
TAC ME8955, TAC ME8956
Download: ML13007A136 (10)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 January 31, 2013 Mr. Dennis L. Koehl President and CEO/CNO STP Nuclear Operating Company South Texas Project P.O. Box 289 VVadsworth, TX 77483

SUBJECT:

SOUTH TEXAS PROJECT, UNITS 1 AND 2 - REVIEVV OF OPERATIONS QUALITY ASSURANCE PLAN CHANGE (TAC NOS. ME8955 AND ME8956)

Dear Mr. Koehl:

By letter dated June 4, 2012 (Agencywide Document Access and Management System (ADAMS) Accession No. ML12163A131), as supplemented by letter dated September 27,2012 (ADAMS Accession Nos. ML12285A231), STP Nuclear Operating Company (STPNOC, the licensee) submitted change QA-074 to Revision 20 of the Operations Quality Assurance Plan (OQAP) for South Texas Project (STP), Units 1 and 2, to the U.S. Nuclear Regulatory Commission, in accordance with the provisions of Title 10 of the Code of Federal Regulations (10 CFR), paragraph 50.54(a)(3). During its review of the proposed changes, the NRC staff determined that additional information was required to complete its review. By letter dated September 27. 2012, STPNOC responded to the NRC staff request for additional information (RAJ) dated August 30, 2012, and submitted the revised OQAP chapters that incorporated the RAI responses as change QA-076 to the OQAP. The changes to the OQAP include:

Incorporate organizational realignments in to appropriate chapters of the OQAP; Include reference to NRC Regulatory Issue Summary (RIS) 2000-18, "Guidance on Managing Quality Assurance Records in Electronic Media," dated October 23, 2000; and Correct formatting error in Chapter 19.0 of the plan.

The licensee stated that the proposed changes to the OQAP do not reduce any element of or responsibilities for implementation of the quality assurance program for STP, Units 1 and 2.

The NRC staff has completed the review of the proposed changes to the OQAP and concludes that the proposed changes to the OQAP, meets the criteria of Appendix B to 10 CFR 50 and are acceptable.

D. Koehl

- 2 If you have any questions, please contact me at 301-415-3016 or bye-mail at Balwant. Singal@nrc.gov.

Sincerely, b~-\\l~l~~

Balwant K. Singal, Senior Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-498 and 50-499

Enclosure:

Safety Evaluation cc w/encl: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION OPERATIONS QUALITY ASSURANCE PLAN CHANGE STP NUCLEAR OPERATING COMPANY SOUTH TEXAS PROJECT, UNITS 1 AND 2 DOCKET NOS. 50-498 AND 50-499

1.0 INTRODUCTION

By letter dated June 4, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12163A131), as supplemented by letter dated September 27,2012 (ADAMS Accession No. ML12285A231), STP Nuclear Operating Company (STPNOC, the licensee) submitted the Operations Quality Assurance Program (OQAP) Change QA-074 for South Texas Project (STP), Units 1 and 2, to the U.S. Nuclear Regulatory Commission (NRC) in accordance with the provisions of Title 10 of the Code of Federal Regulations (10 CFR),

paragraph 50.54(a)(3). The licensee stated that the proposed changes to the OQAP do not reduce any element of or responsibilities for implementation of the quality assurance (QA) program for STP, Units 1 and 2. During the review of the proposed changes, the NRC staff determined that additional information was required to complete its review. By letter dated September 27, 2012, STPNOC responded to an NRC staff request for additional information (RAI) dated August 30,2012 (ADAMS Accession No. ML12243A214), and submitted the revised OQAP chapters that incorporated the RAI responses as change QA-076 to the OQAP.

2.0 REGULATORY EVALUATION

The Commission's regulatory requirements related to QA programs are set forth in Appendix B, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," to 10 CFR Part 50, and 10 CFR 50.54(a).

Appendix B to 10 CFR Part 50 establishes QA requirements for the design, construction, and operation of structures, systems, and components (SSCs) of the facility. The pertinent requirements of Appendix B to 10 CFR Part 50 apply to all activities affecting the safety-related functions of those SSCs and include designing, purchasing, fabricating, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, and modifying.

The regulations in 10 CFR Section 50.54(a)(3) state, in part, that licensees may make a change to a previously accepted QA program description included or referenced in the Safety Analysis Enclosure

- 2 Report without prior NRC approval, provided the change does not reduce the commitments in the program description as accepted by the NRC. The regulations in 10 CFR SO.S4(a)(4) state, in part, that changes to the QA program description that do reduce the commitments must be submitted to the NRC and receive NRC approval prior to implementation.

3.0 EVALUATION The QAPD is based on the guidance of the American National Standards Institute (ANSI) N4S.2 series of standards, which were developed in the 1970s and early 1980s. The staff reviewed changes considered not to be reductions in QA program commitments for conformance with the provisions of 10 CFR SO.S4(a)(3). During the review of the proposed changes, the NRC staff determined that additional information was required to complete its review.

The format and content of the OQAP was previously evaluated in accordance with the guidance of NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition" (SRP) Section 17.2, "Quality Assurance During the Operations Phase" (ADAMS Accession No. MLOS23S0361), which provide guidelines for review of QA programs based upon ANSI N4S.2, "Quality Assurance Program Requirements for Nuclear Facilities," and its daughter standards. Since the changes that were evaluated in QA-074 are new commitments, those changes were evaluated in accordance with the guidance of SRP Section 17.S, "Quality Assurance Program Description - Design Certification, Early Site Permit and License Applicants" (ADAMS Accession No. ML06310019), which provides guidelines for review of QA programs according to American Society of Mechanical Engineers (ASME) standard NQA-1 (1994 Edition), "Quality Assurance Requirements for Nuclear Facility Applications," Regulatory Guide (RG) 1.28, Revision 3, "Quality Assurance Program Requirements (Design and Construction)," August 1985 (ADAMS Accession No. ML003739981), and RG 1.33, Revision 2, "Quality Assurance Program Requirements (Operation)," February 1978 (ADAMS Accession No. ML00373999S). The acceptability of the level of detail provided by QA-074 is determined in part, by its adequacy in addressing the acceptance criteria of SRP Section 17.S.

3.1 Format and Content of the QAPD The format used for the following evaluation follows the sequence of the 18 criteria of Appendix B to 10 CFR Part SO and the acceptance criteria of SRP Section 17.S.

3.1.1 Organization In establishing its organizational structure, STPNOC commits to compliance with Appendix B to 10 CFR Part SO, Criterion I and the American National Standards Institute (ANSI)

N18.7-1976/ANS 3.2. The NRC staff has reviewed the QA changes to be implemented by STPNOC and concludes that the changes met the requirements in 10 CFR SO.S4(a)(3) for changes that are administrative in nature and have no impact on current commitments in the QA program description as accepted by the NRC, but they are included here for completeness of the overall requested change.

- 3 3.1.2 Quality Assurance Program In establishing its QA program, STPNOC commits to compliance with Appendix B to 10 CFR Part 50, Criterion II with clarifications and exceptions, which are addressed in Section 3.1.4 of this document. The NRC staff has reviewed the QA measures to be implemented by STPNOC and concludes that the controls for the program meet the guidance in SRP Section 17.5.

3.1.3 Design Control STPNOC made no changes to the OQAP related to design control.

3.1.4 Procurement Document Control STPNOC has established the necessary controls to ensure that purchased items and services are subject to quality and technical requirements at least equivalent to those specified for original equipment or specified by properly reviewed and approved revisions to the original requirements to ensure an item is suitable for the intended service, and of acceptable quality, consistent with its effect on safety. Procurement documents are subject to the same degree of control as utilized in the preparation of the original documents.

In establishing controls for procurement documents, STPNOC commits to compliance with Appendix B to 10 CFR Part 50, Criterion IV and ANSI N45.2.13, 1976 with the following clarification and exception:

The STPNOC OQAP includes provisions consistent with the regulatory guidance provided in SRP Section 17.5, Paragraph 11.L.8, for the procurement of commercial grade calibration services for safety-related applications from a calibration laboratory.

The STPNOC OQAP proposes not to require procurement source evaluation and selection measures, provided each of the following conditions are met:

a.

Purchase documents impose additional technical and administrative requirements as necessary, to comply with the STPNOC QA program and technical provisions.

b.

Purchase documents shall require that the calibration certificate/report include identification of the laboratory equipment and standard used.

c.

Purchase documents require reporting as-found calibration data when calibrated items are found to be out of tolerance.

d.

The accreditation is based on American Nuclear Societyllnternational Organization for Standardizationllnternational Electrotechnical Commission (ANSIISO/I E C) 17025, "General Requirements for the Competence of Testing and Calibration Laboratories."

e.

The calibration laboratory holds a domestic accreditation by anyone of the following accrediting bodies, which are recognized by the International

- 4 Laboratory Accreditation Cooperation (lLAC) Mutual Recognition Arrangement (MRA):

1.

National Voluntary Laboratory Accreditation Program (NVLAP),

administered by the National Institute of Standards & Technology (NIST)

2.

American Association for Laboratory Accreditation (A2LA)

3.

ACLASS Accreditation Services (ACLASS)

4.

International Accreditation Service (lAS)

5.

Laboratory Accreditation Bureau (L-A-B)

6.

Other NRC-recognized laboratory accrediting bodies

f.

The published scope of accreditation for the calibration laboratory covers the contracted services (Le., necessary measurement parameters, range, and uncertainties).

g.

The alternative method is limited to the domestic calibration service suppliers.

h.

The alternative method is applicable to sub-suppliers of calibration service suppliers, provided the above conditions are met.

The NRC staff has approved the use of calibration laboratories that hold domestic accreditation from an approved accrediting body. This method for qualifying a calibration supplier and accepting its calibration services is applicable only to dedicating commercial-grade calibration services as defined by 10 CFR Part 21. The current regulatory position regarding the acceptability of procuring commercial grade calibration services from NRC-recognized calibration laboratories is documented in SRP Section 17.5, Paragraph II.L.B, as well as associated letters documenting the NRC recognized laboratories. On this basis, the NRC staff concludes that the proposed exception is acceptable.

3.1.5 Instructions, Procedures, and Drawings STPNOC made no changes to the OQAP related to control of instructions, procedures and drawings.

3.1.6 Document Control STPNOC made no changes to the OQAP related to document control.

3.1.7 Control of Purchased Material, Equipment, and Services STPNOC made no changes to the OQAP related to control of purchased material, equipment, and services.

- 5 3.1.8 Identification and Control of Materials, Parts, and Components STPNOC made no changes to the OQAP related to identification and control of materials, parts, and components.

3.1.9 Control of Special Processes STPNOC made no changes to the OQAP related to control of special processes.

3.1.10 Inspection STPNOC made no changes to the OQAP related to control of inspection.

3.1.11 Test Control STPNOC made no changes to the OQAP related to test control.

3.1.12 Control of Measuring and Test Equipment In establishing a measuring and test equipment calibration program, STPNOC commits to compliance with Appendix B to 10 CFR Part 50, Criterion XII with clarifications and exceptions, which are addressed in Section 3.1.4 of this document. The NRC staff has reviewed the QA measures to be implemented by STPNOC and concludes that the controls for measuring and test equipment meet the guidance in SRP Section 17.5, Paragraph 11.L.8.

3.1.13 Handling, Storage, and Shipping STPNOC made no changes to the OQAP related to handling, storage, and shipping controls.

3.1.14 Inspection, Test, and Operating Status In establishing control for inspection, tests, and operating status requirements, STPNOC commits to compliance with Appendix B to 10 CFR Part 50, Criterion XIV. The NRC staff has reviewed the QA changes to be implemented by STPNOC and concludes that the changes met the requirements in 10 CFR 50.54(a)(3) for changes that are administrative in nature and have no impact on current commitments in the QA program description as accepted by the NRC, but they are included here for completeness of the overall requested change.

3.1.15 Nonconforming Materials, Parts, or Components In establishing control for nonconforming materials, parts or components, STPNOC commits to compliance with Appendix B to 10 CFR Part 50, Criterion XV. The NRC staff has reviewed the QA changes to be implemented by STPNOC and concludes that the changes met the requirements in 10 CFR 50.54(a)(3) for changes that are administrative in nature and have no impact on current commitments in the QA program description as accepted by the NRC, but they are included here for completeness of the overall requested change.

- 6 3.1.16 Corrective Action In establishing corrective action controls, STPNOC commits to compliance with Appendix B to 10 CFR Part 50, Criterion XVI. The NRC staff has reviewed the QA changes to be implemented by STPNOC and concludes that the changes met the requirements in 10 CFR 50.54(a)(3) for changes that are administrative in nature and have no impact on current commitments in the QA program description as accepted by the NRC, but they are included here for completeness of the overall requested change.

3.1.17 Quality Assurance Records In establishing quality assurance records requirements, STPNOC commits to compliance with Appendix B to 10 CFR Part 50, Criterion XVII and ANSI N45.2.9, 1974 with the following clarification and exception:

When using electronic records storage and retrieval systems, the STPNOC OQAP provides for compliance with the NRC guidance contained in Regulatory Issue Summary 2000-18, "Guidance on Managing Quality Assurance Records in Electronic Media," dated October 23,2000 (ADAMS Accession No. ML003739359), and the associated Nuclear Information and Records Management Association, Inc. (NIRMA)

Technical Guidelines (TG), including TG 11-1998, TG 15-1998, TG 16-1998, and TG 21-1998.

The current NRC staff position regarding the acceptability of the NIRMA guidance for electronic records storage and retrieval systems is documented in SRP Section 17.5, Paragraph II.Q.

RIS 2000-18, referenced in SRP Section 17.5, Paragraph II.Q, states that when NIRMA TGs TG-11, TG-15, TG-16, and TG-21 are implemented together, these guidelines provide an acceptable basis for managing electronic quality assurance records. STPNOC has committed to using the guidance provided by these NIRMA TGs. On this basis, the NRC staff concludes that the proposed exception is acceptable.

3.1.18 Audits In establishing audits controls, STPNOC commits to compliance with Appendix B to 10 CFR Part 50, Criterion XVIII. The NRC staff has reviewed the QA changes to be implemented by STPNOC and concludes that the changes met the requirements in 10 CFR 50.54(a)(3) for changes that are administrative in nature and have no impact on current commitments in the QA program description as accepted by the NRC, but they are included here for completeness of the overall requested change.

- 7

4.0 CONCLUSION

Based on its evaluation of STPNOC's submittal and the referenced correspondence, the NRC staff concludes that the QA program described in the OQAP satisfies the Commission's requirements for QA programs as established by Appendix B to 10 CFR Part 50. The program description adequately describes how the requirements of Appendix B will be implemented.

Therefore, the staff concludes that the proposed OQAP continues to meet the 10 CFR Part 50 requirements for the QA program and is, therefore, acceptable.

Principal Contributors: Aixa Beleb-Ojeda Date: January 31, 2013

D. Koehl

- 2 If you have any questions, please contact me at 301-415-3016 or bye-mail at Batwant.Singal@nrc.gov.

Sincerely, IRA!

Balwant K. Singal, Senior Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-498 and 50-499

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