ML24116A303
| ML24116A303 | |
| Person / Time | |
|---|---|
| Site: | South Texas, 07201041  |
| Issue date: | 04/25/2024 |
| From: | Harshaw K South Texas |
| To: | Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| NOC-AE-24004034 | |
| Download: ML24116A303 (1) | |
Text
April 25, 2024 NOC-AE-24004034 10 CFR 50.54(a)(4)
STI: 35586611 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 South Texas Project Units 1 and 2 Docket Nos. 50-498; 50-499; 72-1041 Operations Quality Assurance Plan Condition Adverse to Quality Definition Change Resulting in a Reduction in Commitment
In accordance with 10 CFR 50.54(a)(4), STP Nuclear Operating Company (STPNOC) hereby requests approval of a revision to the Operations Quality Assurance Plan (OQAP). The proposed changes are considered a reduction in commitment, which require approval by the NRC prior to implementation. Specifically, STPNOC is proposing to revise the OQAP to
The enclosure is included pursuant to 10 CFR 50.54(a)(4) and includes a description of the change, justification of the proposed change, and provides a basis for concluding the revised OQAP will continue to satisfy the criteria of 10 CFR 50 Appendix B. Attachments 2 and 3 to the Enclosure provide markup and retyped pages, respectively, of the affected pages in the OQAP.
The OQAP will be revised by August 31, 2024, to support plant activities.
There are no commitments in this submittal.
If there are any questions regarding this submittal, please contact Chris Warren at (361) 972-7293 or Michael Chandler at (361) 972-7416.
Kimberly A. Harshaw Acting President and Chief Executive Officer
Enclosure:
Description and Justification of Proposed OQAP Change QA-093 NOC AE 24004034 Page2of2
cc:
Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 1600 E. Lamar Boulevard Arlington, TX 76011-4511
John Vera Senior Resident Inspector, South Texas Project U.S. Nuclear Regulatory Commission
Leanne Flores Resident Inspector, South Texas Project U.S. Nuclear Regulatory Commission
NOC-AE-24004034 Enclosure
ENCLOSURE
DESCRIPTION AND JUSTIFICATION OF PROPOSED OQAP CHANGE QA-093
NOC-AE-24004034 Enclosure Page 1 of 4
1.0
SUMMARY
DESCRIPTION STP Nuclear Operating Company (STPNOC) is submitting a revision to the South Texas Project Electric Generating Station (STPEGS) Operations Quality Assurance Plan (OQAP) in accordance with 10 CFR 50.54(a)(4). The proposed changes are considered a reduction in commitment which require approval by the Nuclear Regulatory Commission (NRC) prior to implementation. Specifically, STPNOC is proposing to revise the OQAP to decommit from NQA-1-1983 only
2.0 DESCRIPTION
OF THE CHANGE The proposed changes to the STPNOC OQAP will do the following:
Add specific definitions from NEI 16-07, Improving the Effectiveness of Issue
Definitions Chapter of the OQAP
Add statements to OQAP Chapter 2.0, Table 1, Program Commitments, regarding the exception STPNOC is taking to the NQA-1-1983 definition for CAQ, which includes a definition for SCAQ and a statement that STPNOC will ensure Targeted Program Controls are applied to certain non-safety related systems, structures, or components (SSCs)
Because this proposed change does not meet any of the criteria provided in 10 CFR 50.54(a)(3)(i) through (vi), STPNOC considers it a reduction in commitment and shall be processed in accordance with 10 CFR 50.54(a)(4).
Attachment 2 of this Enclosure provides the marked-up pages of the OQAP with the proposed changes and Attachment 3 provides the retyped pages. It should be noted that STPNOC is not requesting NRC endorsement of NEI 16-07 by submitting this proposed OQAP change.
3.0 JUSTIFICATION FOR THE PROPOSED CHANGE The proposed change to the definitions of CAQ and SCAQ align with the implementation of the industry-developed definitions in NEI 16-07. The CAQ definition from NQA-1-1983, committed to by STPNOC, encompasses failures, malfunctions, deficiencies, defective items. The scope of this definition, and the definition of SCAQ, which is included in the CAQ definition, has resulted in the undesirable and distracting accumulation of process controls and administrative requirements over the years. This accumulation affects the effectiveness of plant supervisors and managers by:
Creating administrative distractions not focused on conditions affecting the safety-related functions of SSCs.
Creating an over-reliance on the Corrective Action Program (CAP) to address issues.
NOC-AE-24004034 Enclosure Page 2 of 4
Duplicate use of CAP as a tool for departmental work tracking or management of lower-level issues.
Establishing additional reviews or committees to address issues of relatively low significance.
The proposed change continues to allow for condition reports to serve as the primary tool for raising and documenting issues; however, the issues that do not affect the safety-related function of an SSC will not be categorized as a CAQ.
This will allow station leaders and workers to have a greater focus on conditions adverse to quality and improve the prioritization of resources when addressing conditions adverse to quality.
4.0 BASIS FOR CONCLUDING THAT THE REVISED PROGRAM CONTINUES TO SATISFY THE CRITERIA OF 10 CFR 50 APPENDIX B AND THE PREVIOUSLY ACCEPTED QUALITY ASSURANCE PROGRAM COMMITMENTS
within NQA-1 (1983), except for the CAQ and SCAQ definitions. Multiple utilities have incorporated the CAQ and SCAQ definitions from NEI 16-07 into their fleet or site quality assurance plans.
The quality assurance requirements presented in 10 CFR 50, Appendix B, apply to the design, manufacture, construction, and operation of SSCs preventing or mitigating the consequences of postulated accidents that could cause undue risk to the health and safety of the public. Such structures, systems, and
provide adequate confidence that a safety-related structure, system, or component will perform satisfactorily in service. The associated requirements apply to all activities affecting the safety-related functions of SSCs, including designing, purchasing, fabricating, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, and modifying.
While the regulation does not strictly define what a CAQ is, the introduction of this part of the regulation describes the impact on the function of a safety-related system in consideration of how to determine if a CAQ exists.
NOC-AE-24004034 Enclosure Page 3 of 4
the implementation of dry cask storage, STPNOC will remain in compliance with 10 CFR 72.172, Corrective Action, with implementation of the proposed change.
STPNOC has implemented the Important to Safety (ITS) categories A, B, and C
Approach to Developing Quality Assurance Programs for Packaging Radioactive
purposes of identifying CAQs and SCAQs. This interpretation is based on the guidance in Regulatory Guide 7.10, Appendix A, where consequences of a failure or malfunction could directly or indirectly result in a condition that would adversely affect public health and safety.
Implementation of this proposed change to the CAQ and SCAQ definitions will
and Graded Quality Assurance Programs to the extent that the NRC has granted STP an exemption from the regulations as described in the Safety Evaluation on Exemption Requests from Special Treatment Requirements of 10 CFR Parts 21, 50, and 100 (TAC NOS. MA6057 AND MA6058). This includes Full Program Controls that are the highest levels of controls and oversight applied to safety-related SSCs categorized as High Safety Significant (HSS), and Targeted Program Controls that are selected program controls applied to certain non-safety-related SSCs categorized as either HSS or Medium Safety Significant (MSS) as prescribed in the STPEGS OQAP.
The proposed change for the CAQ and SCAQ definitions will continue to allow for condition reports to serve as the primary tool for raising and documenting issues; however, the issues that do not affect the safety-related function of an SSC will not be categorized as a CAQ. This will allow station leaders and workers to have a greater focus on conditions adverse to quality and improve the prioritization of resources when addressing conditions adverse to quality.
This improvement opportunity does not change the current expectations involving issue identification; therefore, employees will continue to be encouraged and expected to maintain a low threshold for condition reporting.
Supervisors, managers, and executives will ensure that a workplace environment supportive of problem identification, consistent with a healthy nuclear safety culture is maintained.
5.0 PRECEDENT No precedent NOC-AE-24004034 Enclosure Page 4 of 4
6.0 CONCLUSION
The proposed change continues to satisfy the criteria of 10 CFR 50, Appendix B, as incorporated into the OQAP.
7.0 REFERENCES
- 1. NEI 16-07, Improving the Effectiveness of Issue Resolution to Enhance Safety and Efficiency
- 2. NQA-1 (1983), Quality Assurance Program Requirements for Nuclear Facilities
- 3. Regulatory Guide 7.10, Establishing Quality Assurance Programs for Packaging Used in Transport of Radioactive Material 8.0 ATTACHMENTS
- 1. QA-093 Summary of Changes
- 2. STPEGS OQAP Markup Pages
- 3. STPEGS OQAP Clean Pages
NOC-AE-24004034 Attachment 1
ATTACHMENT 1
QA-093 Summary of Changes CHANGE QA-093
SUMMARY
OF CHANGES ALL CHANGES ARE IN BOLD TYPE CHAPTER LOCATION ACTION TEXT TOC CH 1.0 Insert QA-093
Definitions Condition Adverse Insert Condition Adverse to Quality (CAQ) - A failure, to Quality (CAQ), malfunction, deficiency, deviation, defective material or page 2 of 7 equipment, or nonconformance affecting the safety-related function of a structure, system, or component.
Definitions Condition Adverse Insert QA-093 to Quality (CAQ).
page 2 of 7
Definitions Significant Insert Significant Condition Adverse to Quality (SCAQ) -A Condition Adverse to condition adverse to quality that, if left uncorrected, Quality (SCAQ), could have a serious effect on nuclear safety.
page 6 of 7
Definitions Significant Insert QA-093 Condition Adverse to Quality (SCAQ),
page 6 of 7
CH 2.0 Table I, page 13 of 19 Insert (Full Program) STP takes exception to the definition of Condition Adverse to Quality (CAQ) which includes Significant Condition Adverse to Quality (SCAQ).
Reference the Definitions Chapter of the OQAP for the CAQ and SCAQ definition.
(Basic Program) STP will ensure Targeted Program Controls are applied to certain non-safety-related SSCs.
CH 2.0 Table I, page 13 of 19 Insert QA-093 NOC-AE-24004034 Attachment 2
ATTACHMENT 2
STPEGSOQAP Markup Pages NUMBER REV.
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION Chapter NO.
TABLE OF 26 CONTENTS OPERATIONS QUALITY ASSURANCE PLAN
TABLE OF CONTENTS
PAGE 1 OF 2 EFFECTIVE DATE 01-03-2024
Chapter Title Chapter Effective Effective Change Number Revision Notice No.
Date
Definitions 10 2-1-14 QA-093
1.0 Organization 22 1-2-24
2.0 Program Description 23 1-2-24 QA-093
3.0 Conduct of Operation 9 2-1-14
4.0 Qualification, Training, and 8 1-6-22 Certification of Personnel
5.0 Maintenance, Installation of 6 2-1-14 Modifications, and Related Activities
6.0 Design and Modification Control 11 2-1-14
7.0 Procurement 16 1-6-22
8.0 Control and Issuance of Documents 7 2-1-14
9.0 Control of Material 7 2-1-14
10.0 Inspection 12 2-1-14
11.0 Test Control 9 2-1-14 SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV. NO.
Chapter 10 OPERATIONS QUALITY ASSURANCE PLAN DEF.
PAGE 2 OF 7 DEFINITIONS EFFECTIVE DATE 02-01-2014
Authorized Nuclear Inservice Inspector (ANII) - Inspectors performing inspections required by Section XI of the ASME code. The ANII is a representative of an authorized inspection agency or a state or municipality of the United States, Canadian Province, or other enforcement authority having jurisdiction over the Nuclear Power components at the plant site.
Calibration - The process by which standards or working equipment are checked against standards of known higher accuracy and adjusted as necessary to ensure their compliance with designated specifications.
Certification - The action of determining, verifying, and attesting in writing to the qualifications of personnel or material.
Cleanness - A state of being clean in accordance with predetermined standards, and usually implies freedom from dirt, scale, heavy rust, oil, or other contaminating impurities.
Commercial Grade Item - A commercial grade item (as defined in 10CFR21) is one which:
A structure, system, or component, or part thereof that affects its safety function that was not designed and manufactured as a basic component. Commercial grade items do not include items where the design and manufacturing process require in-process inspections and verifications to ensure that defects or failures to comply are identified and corrected (i.e., one or more critical characteristics of the item cannot be verified)
Component - A piece of equipment such as a vessel, piping, pump, valve, or core support structure, which will be combined with other components to form an assembly.
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.
Contaminants - Foreign materials such as mill scale, dirt, oil, chemicals, and any matter that renders a fluid, solid, or surface impure and unclean according to present standards of acceptable cleanness.
vendor, supplier, subcontractor, fabricator, and subtier levels of these, where appropriate. Prime contractor is used to indicate either the architect engineer, NSSS supplier, constructor, or nuclear fuel supplier.
Corrective Action - Any appropriate measure applied for the purpose of making less likely the recurrence of the initial deficiency. Examples are:
- a. Revision of procedures, practices, and/or design documents.
- b. Increased surveillance of procedures and practices.
- c. Work stoppage until problem situation is alleviated.
- d. Special training of personnel.
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV. NO.
Chapter 10 OPERATIONS QUALITY ASSURANCE PLAN DEF.
PAGE 6 OF 7 DEFINITIONS EFFECTIVE DATE 02-01-2014
Repair - The process of restoring a nonconforming characteristic to a condition such that the capability of an item to function reliably and safety is unimpaired even though the item still may not conform to the original statement.
Replacements - Spare and renewal components, appurtenances and subassemblies or parts of a component or system. Replacements also include the addition of components but do not include the addition of complete systems.
Review - A deliberately critical examination, including observation of plant operation, evaluation of audit results, procedures, certain contemplated actions, and after-the-fact investigations of abnormal conditions.
Rework - The process by which a nonconforming item is made to conform to a prior specified requirement by completion, remachining, reassembling, or other corrective means.
Safety-Related - Those plant features necessary to assure the integrity of the reactor coolant pressure boundary, the capability to shut down the reactor and maintain it in a safely shutdown condition, or the capability to prevent or mitigate the consequences of accidents which could result in off-site exposures comparable to the guideline exposure of NRC Regulations 10CFR100.
Significant Condition Adverse to Quality (SCAQ) - A condition adverse to quality that, if left uncorrected, could have a serious effect on nuclear safety.
Special Process - A process, the results of which are highly dependent on the control of the process or the skill of the operators, or both, and in which the specified quality cannot be readily determined by inspection or test of the product.
Specification - A concise statement of a set of requirements to be satisfied by a product, material, or process indicating, whenever appropriate, the procedure by means of which it may be determined whether the requirements given are satisfied. (Specifications may also be used to describe technical services to be provided.)
Standard - The result of a particular standardization effort approved by a recognized authority.
Stop Work - The suspension of an activity.
Storage - The act of holding items at the construction site or in an area other than its permanent location in the plant.
Surveillance/Quality Performance Monitoring - The act of observing real time activities and/or reviewing documentation to verify conformance with specified requirements and industry good practices, and to evaluate their adequacy and effectiveness.
Surveillance Testing - Periodic testing to verify that safety-related structures, systems, and components continue to function or are in a state of readiness to perform their function.
QA-093 NOC-AE-24004034 Attachment 3
ATTACHMENT 3
STPEGSOQAP Clean Pages
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV. NO.
Chapter 10 OPERATIONS QUALITY ASSURANCE PLAN DEF.
PAGE 2 OF 7 DEFINITIONS EFFECTIVE DATE 02-01-2014
Authorized Nuclear Inservice Inspector (ANII) - Inspectors performing inspections required by Section XI of the ASME code. The ANII is a representative of an authorized inspection agency or a state or municipality of the United States, Canadian Province, or other enforcement authority having jurisdiction over the Nuclear Power components at the plant site.
Calibration - The process by which standards or working equipment are checked against standards of known higher accuracy and adjusted as necessary to ensure their compliance with designated specifications.
Certification - The action of determining, verifying, and attesting in writing to the qualifications of personnel or material.
Cleanness - A state of being clean in accordance with predetermined standards, and usually implies freedom from dirt, scale, heavy rust, oil, or other contaminating impurities.
Commercial Grade Item - A commercial grade item (as defined in 10CFR21) is one which:
A structure, system, or component, or part thereof that affects its safety function that was not designed and manufactured as a basic component. Commercial grade items do not include items where the design and manufacturing process require in-process inspections and verifications to ensure that defects or failures to comply are identified and corrected (i.e., one or more critical characteristics of the item cannot be verified)
Component - A piece of equipment such as a vessel, piping, pump, valve, or core support structure, which will be combined with other components to form an assembly.
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.
Contaminants - Foreign materials such as mill scale, dirt, oil, chemicals, and any matter that renders a fluid, solid, or surface impure and unclean according to present standards of acceptable cleanness.
vendor, supplier, subcontractor, fabricator, and subtier levels of these, where appropriate. Prime contractor is used to indicate either the architect engineer, NSSS supplier, constructor, or nuclear fuel supplier.
Corrective Action - Any appropriate measure applied for the purpose of making less likely the recurrence of the initial deficiency. Examples are:
- a. Revision of procedures, practices, and/or design documents.
- b. Increased surveillance of procedures and practices.
- c. Work stoppage until problem situation is alleviated.
- d. Special training of personnel.
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV. NO.
Chapter 10 OPERATIONS QUALITY ASSURANCE PLAN DEF.
PAGE 6 OF 7 DEFINITIONS EFFECTIVE DATE 02-01-2014
Repair - The process of restoring a nonconforming characteristic to a condition such that the capability of an item to function reliably and safety is unimpaired even though the item still may not conform to the original statement.
Replacements - Spare and renewal components, appurtenances and subassemblies or parts of a component or system. Replacements also include the addition of components but do not include the addition of complete systems.
Review - A deliberately critical examination, including observation of plant operation, evaluation of audit results, procedures, certain contemplated actions, and after-the-fact investigations of abnormal conditions.
Rework - The process by which a nonconforming item is made to conform to a prior specified requirement by completion, remachining, reassembling, or other corrective means.
Safety-Related - Those plant features necessary to assure the integrity of the reactor coolant pressure boundary, the capability to shut down the reactor and maintain it in a safely shutdown condition, or the capability to prevent or mitigate the consequences of accidents which could result in off-site exposures comparable to the guideline exposure of NRC Regulations 10CFR100.
Significant Condition Adverse to Quality (SCAQ) - A condition adverse to quality that, if left uncorrected, could have a serious effect on nuclear safety.
Special Process - A process, the results of which are highly dependent on the control of the process or the skill of the operators, or both, and in which the specified quality cannot be readily determined by inspection or test of the product.
Specification - A concise statement of a set of requirements to be satisfied by a product, material, or process indicating, whenever appropriate, the procedure by means of which it may be determined whether the requirements given are satisfied. (Specifications may also be used to describe technical services to be provided.)
Standard - The result of a particular standardization effort approved by a recognized authority.
Stop Work - The suspension of an activity.
Storage - The act of holding items at the construction site or in an area other than its permanent location in the plant.
Surveillance/Quality Performance Monitoring - The act of observing real time activities and/or reviewing documentation to verify conformance with specified requirements and industry good practices, and to evaluate their adequacy and effectiveness.
Surveillance Testing - Periodic testing to verify that safety-related structures, systems, and components continue to function or are in a state of readiness to perform their function.
QA-093