Text

March 25, 2024, Pre-Submittal Meeting for STP QA Plan Change
	ML24080A129
Person / Time
Site:	South Texas
Issue date:	03/25/2024
From:	; South Texas
To:	Byrd T; NRC/NRR/DORL/LPL4
	Galvin D
References
	Download: ML24080A129 (1)
	v • d • e

Pre-Submittal Meeting for STP QA Plan Change March 25, 2024

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Background===

The accumulation of process controls and administrative requirements placed on corrective action programs over the years is impacting the effectiveness of plant supervisors and managers and challenging sustained high levels of plant performance. This burden has been created in several ways, including:

Administrative distractions not focused on conditions affecting the safety-related function of a structure, system, or components

Over-reliance on the corrective action program (CAP) to address issues

Use of CAP as a tool for departmental work tracking or to manage a range of low-level issues

A tendency to layer on corrective actions and establish additional reviews or committees to address issues of relatively low significance Public Meeting March 25, 2024

Desired Outcomes Public Meeting March 25, 2024

Condition reports continue to serve as the primary tool to raise issues, however, those issues that dont affect safety-related functions of a SSC will not be categorized as a condition adverse to quality (CAQ)

Station leaders and workers have greater focus on conditions adverse to quality

Station leaders are empowered to direct actions for preventing events and improving station performance for conditions not adverse to quality (CNAQs) without the unnecessary expenditure of resources related to CAP compliance

Improved prioritization of resources

Why STP is seeking NRC approval Public Meeting March 25, 2024 50.54(a) Allows STP to change the following without prior NRC approval Administrative improvements and clarifications, spelling corrections, punctuation, or editorial items (i) The use of a QA standard approved by the NRC which is more recent than the QA standard in the licensees current QA program at the time of the change; (ii) The use of a quality assurance alternative or exception approved by an NRC safety evaluation, provided that the bases of the NRC approval are applicable to the licensee's facility; (iii) The use of generic organizational position titles that clearly denote the position function, supplemented as necessary by descriptive text, rather than specific titles; (iv) The use of generic organizational charts to indicate functional relationships, authorities, and responsibilities, or, alternately, the use of descriptive text; (v) The elimination of quality assurance program information that duplicates language in quality assurance regulatory guides and quality assurance standards to which the licensee is committed; and (vi) Organizational revisions that ensure that persons and organizations performing quality assurance functions continue to have the requisite authority and organizational freedom, including sufficient independence from cost and schedule when opposed to safety considerations.

This change doesnt fit in any of these categories

Current Commitments Public Meeting March 25, 2024

STP is currently committed to NQA-1-1983 for Quality Assurance Terms and Definitions

Condition Adverse to Quality - an all inclusive term used in reference to any of the following: failures, malfunctions, deficiencies, defective items, and nonconformances. A significant condition adverse to quality is one which, if uncorrected, could have a serious effect on safety or operability

Current Commitments - STP Operations Quality Assurance Plan, Chapter 2 Public Meeting March 25, 2024

Condition Adverse to Quality (CAQ) Definition Public Meeting March 25, 2024 Reg Guide 1.74 - Contained no specific definitions and generally endorsed N45.2.10-1973 N45.2.10-1973 - Does not have a definition for Condition Adverse to Quality NQA-1-1983 - Condition Adverse to Quality - An all inclusive term used in reference to any of the following: failures, malfunctions, deficiencies, defective items, and nonconformances. A significant condition adverse to quality is one which, if uncorrected, could have a serious effect on safety or operability

Includes both CAQ and SCAQ definitions

Proposed Definitions Public Meeting March 25, 2024

Proposed definitions are contained in NEI 16-07, Improving the Effectiveness of Issue Resolution to Enhance Safety and Efficiency

- Note - STP is not requesting NRC endorsement of NEI 16-07**

Condition Adverse to Quality (CAQ) - A failure, malfunction, deficiency, deviation, defective material or equipment, or nonconformance affecting the safety-related function of a structure, system, or component

Significant Condition Adverse to Quality (SCAQ) - A condition adverse to quality that, if left uncorrected could have a serious effect on nuclear safety