ML13101A069

Letter to D. L. Koehl South Texas Project Electric Generating Station - Quality Assurance Program Changes Approval

ML13101A069
Person / Time
Site:	South Texas, 07201041
Issue date:	04/09/2013
From:	Eric Benner NRC/NMSS/SFST/LID/RIOB
To:	Koehl D South Texas
Pearson J
References
Download: ML13101A069 (4)

Text

April 9, 2013 Mr. Dennis L. Koehl President and CEO South Texas Project Nuclear Operating Company Electric Generating Station, Units 1 and 2 P.O. Box 289 Wadsworth, Texas 77483

SUBJECT:

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION -

QUALITY ASSURANCE PROGRAM CHANGES APPROVAL

Dear Mr. Koehl:

By letter dated November 1, 2012, the South Texas Project Nuclear Operating Company (STPNOC) submitted a proposed revision to the Operations Quality Assurance Plan for South Texas Project Electric Generating Station (Units 1 and 2). The revision was submitted as a reduction in commitment in regard to the application of the provisions of 10 CFRPART 21, REPORTING OF DEFECTS AND NONCOMPLIANCE to Category B Important to Safety items.

While the changes essentially cannot impact Part 50, Appendix B, the changes were evaluated to ensure continued compliance of the Quality Assurance (QA) program with quality assurance regulations for ISFSIs per 10 CFR 72.140(d). Evaluation of the acceptability of the QA program changes relative to the ISFSI was performed in accordance with the guidance of NUREG-1567, Standard Review Plan for Spent Fuel Dry Storage Facilities, which provides a well-defined, uniform basis for evaluating proposed changes to license commitments.

An acceptable way of establishing QA program compliance with the requirements of 10 CFR Part 72, Subpart G, quality assurance criteria in support of ISFSI operation and maintenance is by reviewing and evaluating the licensee=s commitment to the applicable ANSI Standards and corresponding Regulatory Guides. The proposed changes to the QA program for STPNOC were qualitatively evaluated and judged based on changes and exceptions to previous commitments to these ANSI standards and associated regulatory guides in the context of the current decommissioning status of the facility.

Therefore, this evaluation reviews the QA program changes for conformance with 10 CFR Part 72, Subpart G.

The staff reviewed and evaluated the proposed changes to Chapter 20, Revision 0, of the QA program for STPNOC, with the intent to determine if the QA program for STPNOC continues to comply with the requirements of 10 CFR Part 72, Licensing Requirements for the Independent Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater than Class C Waste, Subpart G-Quality Assurance.

D. L. Koehl The complete submittal was reviewed by the staff to determine the existence of corresponding guidance for each of the Part 72 quality criteria listed below:

Quality assurance organization.

Quality assurance program.

Design control.

Procurement document control.

Instructions, procedures, and drawings.

Document control.

Control of purchased material, equipment, and services.

Identification and control of materials, parts, and components.

Control of special processes.

Licensee and certificate holder inspection.

Test control.

Control of measuring and test equipment.

Handling, storage, and shipping control.

Inspection, test, and operating status.

Nonconforming materials, parts, or components.

Corrective action.

Quality assurance records.

Audits.

NUREG-1567 provides specific guidance for evaluating the licensees QA program changes against the above 18 quality criteria in regard to Spent Fuel Dry Storage Facilities. Based on the staffs review of the QA program, the staff has determined that the proposed revision continues to meet the requirements of Subpart G of 10 CFR Part 72. While this evaluation has determined that the QA program is acceptable, continued proper implementation of the QA program plan will be assessed during future NRC inspections.

The QA program describes requirements, procedures, and controls that, when properly implemented, complies with requirements of 10 CFR Part 72.

The structure of the organization and assignment of responsibility for each activity ensures that designated parties will perform the work to achieve and maintain specified quality requirements.

The staff reviewed the proposed revision and found that the reduction in commitment will continue to satisfy the criteria of 10 CFR 72.140(d).

The staff finds the proposed changes to the QA Operations Quality Assurance Plan for South Texas Project Electric Generating Station (Units 1 and 2) acceptable.

D. L. Koehl For any additional information or clarification on this subject you may contact me at 301-492-3294 or Jim Pearson at 301-492-3337.

Sincerely,

/RA/

Eric Benner, Chief Rules, Inspections, and Operations Branch Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards Docket Nos. 50-498, 50-499 and 72-1041

D. L. Koehl For any additional information or clarification on this subject you may contact me at 301-492-3294 or Jim Pearson at 301-492-3337.

Sincerely,

/RA/

Eric Benner, Chief Rules, Inspections, and Operations Branch Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards Docket Nos. 50-498, 50-499 and 72-1041 Distribution:

WBlaney, OCFO MLombard/SFST Ahsia/SFST MSampson/SFST WAllen/SFST NMSS r/f Balwant Singal/NRR/DORL SFST r/f BSpitzburg/R-IV JLoya/jaloya@STPEGS.COM PUBLIC MMurray/STPNOC G:\SFPO\TSISQA\LETTERS\72-1041r0docdocx ADAMS P8 Accession No.: ML13101A069 OFC: SFST E SFST E SFST E NAME: JPearson MDeBose EBenner DATE: 4/4/13 4/9/13 4/9/13