NOC-AE-09002418, Submittal of Operations Quality Assurance Plan Change QA-068

Submittal of Operations Quality Assurance Plan Change QA-068

ML091210115
Person / Time
Site:	South Texas
Issue date:	04/22/2009
From:	Halpin E Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
G09.19, NOC-AE-09002418, QA-068, STI: 32460443
Download: ML091210115 (52)

Text

Nuclear Operating Company "a

South Texas Project Electrnc GeneratingStation PO. Box289 Wadsworth, Texas 77483 April 22, 2009 NOC-AE-09002418 File No.: G09.19 10CFR50.54(a)

STI: 32460443 U. S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 South Texas Project Units 1 and 2 Docket Nos. STN 50-498 and STN 50-499 Submittal of Operations Quality Assurance Plan Change QA-068 The STP Nuclear Operating Company (STPNOC) submits the attached change to revision 18 of the Operations Quality Assurance Plan (OQAP). These changes to the affected chapters of the Operations Quality Assurance Plan facilitate organization re-alignment and title changes for members of executive management.

This change does not reduce any element of or responsibilities for implementation of the QA program. This change therefore does not represent a reduction in commitment and does not require NRC approval prior to implementation in accordance with the provisions of 10CFR50.54(a)(3).

There are no commitments in this letter.

If there are any questions regarding this matter, please contact Mrs. D. I.

Towler at-(361) 972-7222 or me at (361) 972-7849.

E. D. Halpin Executive Vice President and Chief Nuclear Officer

Attachment:

1. Operations Quality Assurance Plan change QA-068 p(LI

NOC-AE-09002418 Page 2 of 2 cc:

(paper copy) (electronic copy)

Regional Administrator, Region IV A. H. Gutterman, Esquire U. S. Nuclear Regulatory Commission Morgan, Lewis & Bockius LLP 612 East Lamar Blvd, Suite 400 Arlington, Texas 76011-4125 Mohan C. Thadani U. S. Nuclear Regulatory Commission Mohan C. Thadani Kevin Howell Senior Project Manager Catherine Callaway U.S. Nuclear Regulatory Commission Jim von Suskil One White Flint North (MS 7 D1) NRG South Texas LP 11555 Rockville Pike Rockville, MD 20852 Ed Alarcon Senior Resident Inspector J. J. Nesrsta U. S. Nuclear Regulatory Commission R. K. Temple P. 0. Box 289, Mail Code: MN1 16 Kevin Polio Wadsworth, TX 77483 City Public Service C. M. Canady Jon C. Wood City of Austin Cox Smith Matthews Electric Utility Department 721 Barton Springs Road C. Mele Austin, TX 78704 City of Austin Richard A. Ratliff Texas Department of State Health Services Alice Rogers Texas Department of State Health Services

CHANGE QA-068

SUMMARY

OF CHANGES Page 1 of 3 ALL CHANGES ARE IN BOLD TYPE CHAPTER LOCATION ACTION TEXT TOC CH 1.0 INSERT QA-068 CH 2.0 INSERT QA-068 CH 13.0 INSERT QA-068 CH 15.0 INSERT QA-068 CH 16.0 INSERT QA-068 CH 19.0 INSERT QA-068 CH 1.0 5.1 DELETE Vice President Engineering and Site INSERT Senior and Executive Vice President and (2 places) 5.2 INSERT Executive Vice President and (2 places) 5.3 DELETE Site (2 places)

INSERT Engineering and Senior (2 places) 5.3.1 (new text) INSERT The Vice President Engineering is responsible for implementing quality program requirements applicable to the following functions including:

fuels & analysis, engineering (testing/programs, design engineering, systems engineering, maintenance engineering), and administrative support. The senior management of these functions report to the Vice President Engineering.

5.3.2 thru 5.3.5 RENUMBER These sections renumbered when new 5.3.1 text above was added New 5.3.4 DELETE and plant protection (emergency response, access authorization, and security)

INSERT and (before training) 5.3.4.3 INSERT Executive Vice President and 5.3.4.4 INSERT Executive Vice President and

CHANGE QA-068

SUMMARY

OF CHANGES Page 2 of 3 ALL CHANGES ARE IN BOLD TYPE CHAPTER LOCATION ACTION TEXT CH 1.0 5.4 DELETE The Vice President Engineering is responsible for implementing quality program requirements applicable to the following functions including:

fuels & analysis, engineering (testing/programs, design engineering, systems engineering, maintenance engineering), and administrative support. The senior management of these functions report to the Vice President Engineering.

5.5 thru 5.6.2.3 RENUMBER When 5.4 was deleted above, these sections became new 5.4 thru 5.5.2.3 New 5.4 INSERT plant protection (emergency response, access authorization, and security) and system after records management DELETE (for Units 1 through 4) and services and administration after records management 5.5 DELETE Group (2 places)

INSERT Senior (2 places) 5.5.1 DELETE Group INSERT Senior 5.5.2.3 DELETE Group INSERT Senior CH 2.0 5.1.2 INSERT Executive Vice President and 5.8.2 INSERT Executive Vice President and (2 places)

DELETE Group (2 places)

INSERT Senior (2 places) and 5.10.2 INSERT Executive Vice President and CH 13.0 5.6 DELETE Group INSERT Senior

CHANGE QA-068

SUMMARY

OF CHANGES Page 3 of 3 ALL CHANGES ARE IN BOLD TYPE CHAPTER LOCATION ACTION TEXT CH 15.0 5.2.1.11 DELETE Group INSERT Senior and Executive Vice President and 5.2.5.6 DELETE Group INSERT Senior and Executive Vice President and 5.4.1.3 INSERT Executive Vice President and CH 16.0 6.6 INSERT Executive Vice President and CH 19.0 5.1.9 INSERT Executive Vice President and 5.1.10 INSERT Executive Vice President and 5.2.2 INSERT Executive Vice President and 5.2.5.1 INSERT Executive Vice President and

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OPERATIONS QUALITY ASSURANCE PLAN TABLE 18 OF CONTENT TABLE OF CONTENTS PAGE 1OF2 EFFECTIVE DATE 02-01-08 Chapter Title Effective Effective Change Number Chapter Revision Date Notice No.

Definitions 9 2-1-02 1.0 Organization 14 2-1-08 QA-067, 068 2.0 Program Description 16 2-1-08 QA-067, 068 3.0 Conduct of Plant Operations 7 2-1-98 4.0 Qualification, Training, and 6 2-1-98 Certification of Personnel 5.0 Maintenance, Installation of 5 2-1-98 Modifications, and Related Activities 6.0 Design and Modification Control 9 2-1-06 7.0 Procurement 11 2-1-08 8.0 Control and Issuance of 6 2-1-98 Documents 9.0 Control of Material 6 2-1-98 10.0 Inspection 11 2-1-08 11.0 Test Control 8 2-1-08 12.0 Instrument and Calibration 6 2-1-98 Control 13.0 Control Of Conditions Adverse 12 2-1-08 QA-068 to Quality 14.0 Records Control 8 2-1-06

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OPERATIONS QUALITY ASSURANCE PLAN TABLE 18 OF CONTENT TABLE OF CONTENTS PAGE 2 OF 2 EFFECTIVE DATE 02-01-08 Chapter Title Effective Effective Change Number Chapter Revision Date Notice No.

15.0 Quality Oversight 11 2-1-08 QA-067, 068 Activities 16.0 Independent Technical 10 2-1-08 QA-067, 068 Review 17.0 ASME Code Section XI 8 2-1-08 QA-067 Repairs and Replacements 18.0 ASME Code Section XI - 9 2-1-08 QA-067 Inservice Inspection and Testing 19.0 Administrative Controls 3 2-1-08 QA-067,068

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OPERATIONS QUALITY ASSURANCE PLAN 1.0 14 ORGANIZATION PAGE 1OF5 EFFECTIVE DATE 02-01-08 1.0 PURPOSE 1.1 The purpose of this chapter is to describe the organizational structure as related to quality assurance and to establish the responsibilities of organizations for the South Texas Project (STP).

2.0 SCOPE 2.1 STP Nuclear Operating Company (STPNOC), as licensee, has the Quality responsibility for design, engineering, procurement, fabrication, modification, maintenance, repair, in-service inspection, refueling, testing, and operation of the STP.

3.0 DEFINITIONS 3.1 None

4.0 REFERENCES

4.1 None 5.0 RESPONSIBILITIES

.5.1 The STPNOC (Units 1 & 2) includes the Senior Vice President and the Vice President Shared Services. The senior management of these groups report to the Executive Vice President and Chief Nuclear Officer. The Executive 0, Vice President and Chief Nuclear Officer reports to the President and Chief Executive Officer.

5.2 The Executive Vice President and Chief Nuclear Officer has overall responsibility for the implementation of the Operations Quality Assurance Program and approving the Operations Quality Assurance Plan (OQAP) and revisions thereto. The Executive Vice President and Chief Nuclear Officer shall designate those members of senior management to function as the Senior Management Team.

5.3 The Senior Vice President is responsible for implementing quality program requirements applicable to staffing STP with qualified personnel and ,0 acquiring and coordinating the assistance of internal and external C?

organizations for the following functions including: engineering, plant CY general management,,projects & outages, and oversight. The senior management of these functions report to the Senior Vice President.

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OPERATIONS QUALITY ASSURANCE PLAN 1.0 14 ORGANIZATION PAGE 2 OF 5 EFFECTIVE DATE 02-01-08 5.3.1 The Vice President Engineering is responsible for implementing quality program requirements applicable to the following functions including: 00 fuels & analysis, engineering (testing/programs, design engineering, systems engineering, maintenance engineering), and administrative <

support. The senior management of these functions report to the Vice President Engineering.

5.3.2 The Plant General Manager has prime responsibility for the safe operations of the units. The plant staff, under the direction of the Plant General Manager, develop detailed procedures and instructions fortesting, operation, modification, and maintenance of the STP.

5.3.3 The Plant General Manager is responsible for implementing quality program requirements applicable to the following functions including:

operations, maintenance, chemistry, environmental, health physics, and work control. The senior management of these functions report to the Plant General Manager.

5.3.4 The General Manager, Oversight is responsible for implementing quality program requirements applicable to the following functions including:

licensing, quality, risk management, performance improvement, and training. The senior management of these functions report to the General <

Manager, Oversight.

5.3.4.1 The Manager, Quality has the independence to conduct Quality activities without undue pressure of cost or schedule and is responsible for the following:

Development, maintenance, and independent verification of implementation of the STP Quality Program; making periodic reports on its effectiveness; review of selected documents which control activities within its scope; and preparation, control, and approval of the OQAP and revisions thereto; <

Identify, initiate, recommend, or provide solutions to quality-related problems and verify the implementation and effectiveness of the solutions; and Independent oversight activities, including audits, independent assessments, evaluations, surveillances, performance monitoring, inspections, independent oversight of NDE examinations, and administration of organizational unit

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OPERATIONS QUALITY ASSURANCE PLAN 1.0 14 ORGANIZATION PAGE 3 OF 5 EFFECTIVE DATE 02-01-08 independent review activities. (see section 5.5.2.1 for vendor oversight responsibilities) 5.3.4.2 General Manager, Oversight and the Manager, Quality, at their discretion, have unfettered access to the President and Chief Executive Officer and the Board of Directors.

5.3.4.3 The General Manager, Oversight and the Manager, Quality have the authority to stop work for cause. This authority has been granted by the Executive Vice President and Chief \0 Nuclear Officer. The Quality organization, including the inspection staff, is based upon the anticipated Quality involvement in operations, modification, and maintenance activities.

5.3.4.4 The Manager, Risk Management is responsible for activities related to the Comprehensive Risk Management Program, including oversight of Probabilistic Safety Assessment activities. The Comprehensive Risk Management Expert Panel guides the implementation of the Comprehensive Risk Management Program and is composed of a Chairman and additional senior level management designated by the Executive Vice President and Chief Nuclear Officer.

5.3.5 The General Manager, Projects & Outages is responsible for implementing quality program requirements applicable to the following functions:

engineering projects, project alliance, replacement reactor vessel head, outage management, and projects. The senior management of these functions report to the General Manager, Projects & Outages.

5.4 The Vice President, Shared Services is responsible for implementing quality program requirements applicable to the following functions: plant protection (emergency response, access authorization, and security), supply 'D chain, records management system, and information technology. The senior management of these functions report to the Vice President, Shared CY Services.

5.5 The STPNOC (Units 3 & 4) includes the Vice President, Oversight &

Regulatory Affairs, the Vice President Engineering & Construction, Plant General Manager, and General Manager Support Services. The senior management of these groups report to the Senior Vice President. The Senior ,

Vice President reports to the President and Chief Executive Officer.

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Chapter OPERATIONS QUALITY ASSURANCE PLAN 1.0 14 ORGANIZATION PAGE 4 OF 5 EFFECTIVE DATE 02-01-08 5.5.1 The Senior Vice President is responsible for implementing quality program requirements applicable to the overall efforts associated with the C?

activities related to Early Site Permit/Construction Operating License. 5' I 5.5.2 The Vice President, Oversight & Regulatory Affairs is responsible for implementing quality program requirements applicable to the following functions including: regulatory affairs (licensing and probabilistic risk assessment) and quality. The senior management of these functions report to the Vice President, Oversight & Regulatory Affairs.

5.5.2.1 The Manager, Quality has the independence to conduct Quality activities without undue pressure of cost or schedule and is responsible for the following:

Development, maintenance, and independent verification of implementation of the STP Quality Program; making periodic reports on its effectiveness; review of selected documents which control activities within its scope; and preparation, control, and approval of the OQAP and revisions thereto; Identify, initiate, recommend, or provide solutions to quality-related problems and verify the implementation and effectiveness of the solutions; and Independent oversight activities, including audits, independent assessments, evaluations, surveillances, performance monitoring.

Vendor oversight activities for Units 1 through 4. For those vendor oversight activities specifically related to Units I & 2, the Manager, Quality reports to the General Manager, Oversight (Units 1 & 2).

5.5.2.2 The Vice President, Oversight & Regulatory Affairs and the Manager, Quality at their discretion, have unfettered access to the President and Chief Executive Officer and the Board of Directors.

5.5.2.3 The Senior Vice President, the Vice President, Oversight &

Regulatory Affairs, and the Manager, Quality have the <

authority to stop work for cause. This authority has been granted by the President and Chief Executive Officer.

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OPERATIONS QUALITY ASSURANCE PLAN 1.0 14 ORGANIZATION PAGE 5 OF 5 EFFECTIVE DATE 02-01-08 6.0 REQUIREMENTS 6.1 The fundamental responsibility for implementing quality program requirements is assigned to all personnel performing activities affecting the safe and reliable operation of STP and safety-related and quality-related activities associated with Early Site Permitting/COL Application activities for additional units (3 & 4) at STP. These personnel and their management are responsible for implementing through approved procedures and other.

• work documents, the quality assurance program controls described in the OQAP. Line organizational details and responsibilities for Units 1 &'2 are further described in STP UFSAR Chapter 13.1.

7.0 DOCUMENTATION 7.1 None 8.0 ATTACHMENTS 8.1 None

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OPERATIONS QUALITY ASSURANCE PLAN 2.0 16.

PROGRAM DESCRIPTION PAGE 1 OF 18 EFFECTIVE DATE 02-01-08 1.0 PURPOSE 1.1 The purpose of this chapter is to define criteria and establish administrative controls for implementation of the Quality Assurance (QA) Program for the South Texas Project (STP).

2.0 SCOPE 2.1 The QA Program is implemented and controlled in accordance with the Operations Quality Assurance Plan (OQAP) and is applicable to structures, systems, and components to an extent consistent with their importance to safety, and complies with the requirements of 10CFR50, Appendix B and other program commitments as appropriate.

2.2 The QA Program will also extend, as applicable and/or determined by STP management, to programs including 1 OCFR7 1, Subpart H (except design and fabrication of NRC certified radioactive waste shipping casks), ASME Boiler and Pressure Vessel Code, Sections III and XI; and to quality-related areas as defined herein including the Fire Protection Program, Emergency Plan, Radiological Environmental Monitoring Program, Radwaste Management Program, Computer Program Verification and Control, 'Seismic and Environmental Equipment Qualification Programs, Radiation Protection Program, and Station Blackout (SBO) systems and equipment.

2.3 The QA Program provides the basis for the control and performance of safety-related and quality-related activities associated with Early Site Permitting/COL Application activities for additional units (3 & 4) at the STPEGS. Controls, as currently stated in the OQAP, will be extended to specific activities associated with the new units by inserting an applicability statement in the Purpose and Scope of station procedures. These specific QA Program controls for the new units remain in effect until the Nuclear Regulatory Commission approves a Quality Program specific to the new units, and the associated implementing procedures are in place.

3.0 DEFINITIONS 3.1 Comprehensive Risk Management - A process by which the change in risk to station personnel, the public's health and safety are evaluated as a result of changes in commitments, processes, activities, and human and equipment performance.

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OPERATIONS QUALITY ASSURANCE PLAN 2.0 16 PROGRAM DESCRIPTION PAGE 2 OF 18 EFFECTIVE DATE 02-01-08 3.2 Graded Quality Assurance - The process by which risk-based methodology [i.e.,

Probabilistic Safety Assessment (PSA)] and deterministic and performance-based information analyses are combined to establish appropriate levels of programmatic controls for SSCs and appropriate levels of first line and independent oversight needed to provide the necessary assurance that SSCs will operate safely.

3.3 Full program controls - The highest levels of controls and oversight applied to safety-related SSCs categorized as High Safety Significant (HSS), as prescribed in Table I to this chapter and throughout individual OQAP chapters.

3.4 Basic program controls - Levels of control and oversight, lower than in the Full Program, applied to safety-related SSCs categorized as Medium Safety Significant (MSS), as prescribed in Table I to this chapter and throughout individual OQAP chapters.

3.5 Targeted program controls - Selected program controls applied to certain non-safety-related SSCs categorized as either HSS or MSS.

3.6 Limited program controls - Limited controls applied to safety-related SSCs categorized as either Low Safety Significant (LSS) or Non-Risk Significant (NRS).

4.0 REFERENCES

4.1 10CFR50, Appendix B 4.2 10CFR71, Subpart H 4.3 ASME B&PV Code 4.4 OQAP Chapter 14.0, Records Control 4.5 10CFR50.63, Loss of All Alternating Current Power 4.6 10CFR50.54(a) 4.7 Updated Final Safety Analysis Report 4.8 Safety Evaluation on Exemption Requests from Special Treatment Requirements of 10 CFR Parts 21, 50, and 100 (TAC NOS. MA6057 AND MA6058)

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OPERATIONS QUALITY ASSURANCE PLAN 2.0 16 PROGRAM DESCRIPTION PAGE 3 OF 18 EFFECTIVE DATE 02-01-08 5.0 REQUIREMENTS 5.1 General Program Requirements 5.1.1 The OQAP shall be prepared and maintained to prescribe the STP QA Program. The OQAP reflects the quality program policies to be implemented. The OQAP describes the organization and responsibilities for attainment of quality objectives and verification of conformance to established requirements. The QA Program shall be in effect throughout the operating life of the STP.

5.1.2 The Executive Vice President and Chief Nuclear Officer has overall responsibility for quality assurance. The General Manager, Oversight is responsible for the development and maintenance of the OQAP for Units 1 <

& 2. The Vice President Oversight & Regulatory Affairs is responsible for the development and maintenance of the OQAP for Units 3 & 4.

5.1.3 The operations phase of the STP includes design, procurement, fabrication, repair, testing, operation, maintenance, refueling, inspection, independent oversight, modification, and other activities as discussed Table I to this chapter and throughout the OQAP. STP and its vendors are required, as appropriate, to comply-with the criteria established by 1 OCFR50, Section 50.55a; I OCFR50, Appendix A, General Design Criterion (GDC) 1; 10CFR50, Appendix B, and 10CFR71, Sub-Part H (except design and fabrication of NRC certified radioactive waste shipping casks). These regulations are not applicable to LSS and NRS safety-related components, to the extent that the Nuclear Regulatory Commission has granted STP- an exemption from the regulations as described in Reference 4.8.

STP will implement, as specified, the Regulatory Guides (RG) and implementing American National Standards Institute (ANSI) standards contained in Table I of this chapter.

5.1.4 STP shall maintain the OQAP as an effective and meaningful document to provide programmatic direction for the station. Changes to the OQAP shall be accomplished as prescribed by I OCFR50.54(a). When changes are made in the OQAP to the organizational elements only, appropriate notification will be made to the NRC within 30 days of implementation.

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OPERATIONS QUALITY ASSURANCE PLAN 2.0 16 PROGRAM DESCRIPTION PAGE 4 OF 18 EFFECTIVE DATE 02-01-08 5.2 Organizational Independence 5.2.1 The reporting arrangement utilized by the Quality organization ensures that those personnel performing independent oversight have the organizational freedom to:

5.2.1.1 Identify quality problems.

5.2.1.2 Initiate, recommend, or provide solutions.

5.2.1.3 Verify implementation of solutions.

5.2.2 Personnel verifying compliance with quality requirements do not have direct responsibility for the performance of or directly supervise the activity being verified.

5.3 Graded Quality Assurance 5.3.1 Graded Quality Assurance (GQA) is fundamental to the STP QA Program.

It is described in more detail in the implementing procedure for the STP Comprehensive Risk Management (CRM) Program.

5.3.2 GQA is a process by which risk-based methodology [i.e., Probabilistic Safety Assessment (PSA)], deterministic insights, and performance-based information are combined and analyzed to determine what levels of, programmatic controls are needed for structures, systems, and components (SSCs) and what levels of first line and independent oversight are needed to provide assurance that items will operate safely and activities are

/ accomplished as prescribed.

5.3.3 Selected systems are evaluated, at the component level, by:a cross-discipline Expert Panel comprised of high level station management.

Initial evaluations are performed by the Working Group.

5.3.4 These recommendations are developed in consideration of the risk significance of system functions; components' contribution to core damage frequency and large early release frequency, components' critical attributes (needed to support risk significant system functions),

performance, regulatory/QA requirements, and other deterministic considerations as prescribed-in the Comprehensive Risk Management procedures.

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OPERATIONS QUALITY ASSURANCE PLAN 2.0 16 PROGRAM DESCRIPTION PAGE 5 OF 18 EFFECTIVE DATE 02-01-08 5.3.5 Program control recommendations are developed by the Working Group and ultimately approved by the Expert Panel and forwarded to the site for implementation. Controls are implemented in four graded applications (i.e., "Full", "Basic", "Targeted", and "Limited").

5.3.6 "Full" program controls are applied to safety-related SSCs categorized as HSS. These "Full" levels of controls and oversight are designed to provide a high degree of confidence that SSCs perform safely and activities are performed as expected. Table I to the OQAP chapter prescribes the program commitments applicable to "Full" program activities.

5.3.7 "Basic" program controls are applied to safety- related SSCs categorized as MSS. These are lower levels of control and oversight, designed to maintain/preserve those identified critical attributes of SSCs needed to support risk significant system functions. These controls are intended to reflect economical and efficient business practices. Table I to the OQAP chapter prescribes the program commitments applicable to "Basic" program activities.

5.3.8 "Limited" program controls are applied to safety-related SSCs categorized as either LSS or NRS. Only specific program controls related to the activities listed in the following subparagraphs are applicable to these SSCs. The other chapters of the OQAP are not applicable to safety-related LSS and NRS SSCs. Instead, the treatment processes applicable to these SSCs are described in the Updated Final Safety Analysis Report Section 13.7.3.3 and implementing procedures:

5.3.8.1 Those elements in Chapter 1.0 that are needed to implement and control activities described above; 5.3.8.2 Applicable requirements in this Chapter; 5.3.8.3 Modification/design activities as described in Chapter 6.0; and 5.3.8.4 Corrective action as described in Chapter 13.0.

5.3.9 "Targeted" program controls are applied to non-safety related SSCs, for which 10CFR50, Appendix B is not applicable, categorized as HSS or MSS. Specific program controls consistent with applicable portions of the "full" and "basic" program controls are applied to those items in a selected manner, "targeted" at those characteristics or critical attributes that render the SSC risk significant.

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OPERATIONS QUALITY ASSURANCE PLAN' 2.0 16 PROGRAM DESCRIPTION PAGE 6 OF 18 EFFECTIVE DATE 02-01-08 5.3.10 Safety-related components that are highly reliable, yet whose failure would result in a significant increase in risk, will receive Full program coverage, or will be evaluated based on their risk significance to ensure that Full program controls are applied to their critical attributes.

5.3.1 1 SSCs governed by the OQAP shall retain their current program coverage until such time as prescribed risk-informed, performance-based analyses are completed and approved, and they are placed into the graded program categories (i.e., "Full", "Basic", "Targeted", or "Limited") as appropriate.

5.3.12 A vital element of the GQA program is the "feedback" loop. On a periodic basis, and as prescribed in the Comprehensive Risk Management procedure, the GQA Working Group and Expert Panel shall review any changes to the PSA information and performance/operating experience that could result in recategorization of an SSC. These reviews are also used to assess the effectiveness and appropriateness of in-place quality program controls. Adjustments shall be made as determined necessary.

5.4 Delegation of QA Functions 5.4.1 The OQAP may be executed in whole or part by subcontract personnel.

However, STP will retain responsibility for the total quality assurance program, and Quality organization personnel will perform appropriate oversight activities of subcontracted activities.

5.5 Identification of Safety Significant Structures, Systems, and Components 5.5.1 The program described herein is applied to activities affecting the safety functions of those structures, systems, and components which prevent, or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public. The structures, systems, and components controlled are listed in UFSAR Section 3.2, along with their associated fire protection systems. UFSAR Section 3.2 also identifies those structures, systems, and components which may not represent a safety significant/risk important concern but to which the STP OQAP is applied.

5.5.2 The fire protection QA Program is part of the overall STP Operations QA Program. Fire protection QA Program criteria are implemented as part of the Operations QA Program.

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OPERATIONS QUALITY ASSURANCE PLAN 2.0 16 PROGRAM DESCRIPTION PAGE 7 OF 18 EFFECTIVE DATE 02-01-08 5.5.3 Expendable or consumable items necessary for the functional performance of structures, systems, and components are subjected to quality assurance requirements as specified in written procedures. These procedures include provisions for review and control in accordance with industry standards and specifications.

5.6 QA Program Documents 5.6.1 The QA Program shall be implemented with documented instructions, procedures, and drawings which include appropriate quantitative and qualitative acceptance criteria for determining that prescribed activities have been satisfactorily accomplished. Procedures shall include the control of the sequence of required inspections, tests, and other operations when important to quality. To change these controls, the individual procedure must be changed and shall require the same level of review and approval given to the original procedure. Such instructions, procedures, and drawings are reviewed and approved for compliance with requirements appropriate to their safety significance by individuals qualified to do so.

5.7 Personnel Indoctrination and Training 5.7.1 General indoctrination and training programs shall be provided for site personnel to assure that they are knowledgeable regarding quality programs and requirements. The training requirements for STP personnel are described in UFSAR Section 13.2. Personnel performing complex, unusual, or potentially hazardous work shall be instructed in special indoctrination or briefing sessions. Emphasis shall be on special requirements for safety of personnel, radiation control and protection, unique features of equipment and systems, operating constraints, and control requirements in effect during performance of work. Where required by codes and standards, personnel are trained, qualified, and certified according to written procedures in the principles and techniques of performing specific activities.

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OPERATIONS QUALITY ASSURANCE PLAN 2.0 16 PROGRAM DESCRIPTION PAGE 8 OF 18 EFFECTIVE DATE 02-01-08 5.8 Policies and Goals 5.8.1 STP policy is to assure that the design, procurement, construction, testing, and operation of the STP are in conformance with specifications, procedures, codes, commitments and Nuclear Regulatory Commission (NRC) regulations to the extent not exempted. The responsibility of each organization supporting the STP is to ensure that the requirements stated in this QA Program are incorporated into procedures. Adherence to those procedures is mandatory for all STP organizations and contractors or vendors providing items or services covered by the QA Program.

5.8.2 The OQAP identifies activities and establishes requirements for procedures which identify, report, and verify the resolution of quality problems. The implementing procedures call for the resolution of quality problems at the lowest possible authorized level. However, if a dispute is encountered in the resolution of a quality problem which cannot be resolved at lower levels, the General Manager, Oversight or Manager, Quality for Units 1 & 2 shall present the problem to the Executive Vice President and Chief Nuclear Officer for resolution. The Vice President 00 Oversight & Regulatory Affairs or the Manager, Quality for Units 3 & 4 shall present the problem to the Senior Vice President. For quality problems associated with vendor oversight activities for Units I through 4, '

the General Manager, Oversight (Units 1 & 2) or Manager, Quality (Units 0' 3 & 4) shall present the problem to the Executive Vice President and Chief Nuclear Officer or the Senior Vice President respectively.

5.9 Control of Activities 5.9.1 The OQAP requires Quality department review and/or approval of procedures which control selected activities. These procedures shall require the use of the proper equipment, completion of prerequisites for starting an activity, and suitable environment for performing the activity.

Procedures will comply with the appropriate standards.

5.9.2 STP personnel attend planning, scheduling, and status meetings as necessary to assure adequate quality coverage and program application exists.

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OPERATIONS QUALITY ASSURANCE PLAN 2.0 16 PROGRAM DESCRIPTION PAGE 9OF 18 EFFECTIVE DATE 02-01-08 5.10 Management Review 5.10.1 The implementation of both line and OQAP requirements shall be verified through independent oversight activities. The Quality organization shall conduct independent oversight activities of the operating plant and of the interfacing organizations' activities.

5.10.2 Independent oversight of the implementation of the OQAP is conducted' 0 under the cognizance of the Senior Management Team and results are o transmitted to appropriate line and senior management, including the Executive Vice President and Chief Nuclear Officer for review and/or action.

5.10.3 STP may use the services of architect-engineer firms, Nuclear Steam Supply System (NSSS) suppliers, fuel fabricators, constructors, and others which provide or augment STP efforts during operations. As applicable, the QA programs of such contractors or consultants shall be subject to review, evaluation, and acceptance by the Quality organization before initiation of activities affected by the program.

5.11 Computer Code Programs 5.11.1 The development, maintenance, and use of computer code programs will be controlled. Prior to use of a computer code program, the appropriateness of the program -shall be verified.' In addition, all such programs shall be appropriately certified for use.

6.0 DOCUMENTATION 61 Procedures which are generated as required by this chapter shall identify the records which are required to implement and document those activities. The records shall be controlled in accordance with Reference 4.4.

7.0 ATTACHMENTS 7.1 Table I - Program Commitments

TABLE I PROGRAM COMMITMENTS R.G./ANSI STANDARD FULL PROGRAM BASIC PROGRAM R.G. 1.8, rev. 1 (9/75) No exceptions taken. No exceptions taken.

ANSI N18.1, 1971 4.2.2-The Operations Manager requirements regarding holding a Senior Reactor Same as full.

Operator license are met by the Unit Operations Managers.

R.G. 1.28, rev. 0 (6/72) This R.G. is not applicable to operations phase activities. Same as full.

ANSI 45.2, 1971 This standard is not applicable to operations phase activities. Same as full.

R.G. 1.33, rev. 2 (2/78) C.2 - the specific revisions of the listed standards to which STP is committed are Same as full.

in this table and are not necessarily the "latest" revision.

C.4 - Chapter 15.0 of the STP OQAP describes the audit program at STP that Same as full.

meets the intent of R.G. 1.33, rev. 2, position C.4 regarding frequency of audits C.4.a.b.c - STP performs these audits in accordance with a nominal biennial Same as full.

frequency.

ANSI N18.7 - 1976/ANS 3.2 3.4.2 - refer to R.G. 1.8 regarding Operations Manager holding a Senior Reactor Same as full.

Operator license.

3.4.2 refer to R.G. 1.58 regarding use of personnel not qualified in accordance with ANSI N45.2.6.

4.5 - refer to R.G. 1.33 coverage regarding audit frequency. Same as full.

5.2.6 (5th paragraph) - independent verification may be concurrent with (same Same as full.

time as) work performance.

Operations Quality Assurance Plan, Chapter 2.0, Revision 16 Page 10 of 18'

TABLE I PROGRAM COMMITMENTS RG./ANSI STANDARD FULL PROGRAM BASIC PROGRAM ANSI NI 8.7/ANS 3.2 (cont'd) 5.2.7 (1 st paragraph) - STP will use current approved design bases as opposed to Same as full.

original design bases.

5.2.7 - STP will perform inspection as deemed necessary, based on the relative complexity of the work.

5.2.7.1 (5th paragraph) - STP takes exception to use of the word "promptly" with Same as full.

regard to determining, evaluating and recording the causes of malfunctions. The STP Corrective Action Program includes the elements with regard to timeliness of action associated with causal analyses.

5.2.7.2 - refer to table coverage of ANSI N45.2.11, 1974.

5.2.13 (1 st paragraph) - refer to table coverage of ANSI N45.2.13, 1976.

5.2.13.1 (1 st paragraph) - refer to table coverage of ANSI N45.2, 1971.

5.2.13.4 (5t h paragraph) - refer to table coverage of ANSI N45.2.2, 1972.

5.2.15 (4th paragraph)- Chapter 8.0 of the OQAP describes the requirements for Same as full.

control and issuance of documents, which meets the intent of R.G. 1.33, rev. 2.

The intent of the biennial review is accomplished by other controls that assure that procedures are appropriately reviewed and revised to incorporate information based on plant operations, design changes, regulatory requirements, industry experience and other conditions that may impact plant procedures.

Operations Quality Assurance Plan, Chapter 2.0, Revision 16 Page I I of 18

TABLE I PROGRAM COMMITMENTS R.G./ANSI STANDARD FULL PROGRAM BASIC PROGRAM ANSI N I 8.7/ANS 3.2 (cont'd) 5.2.17 (3rd paragraph) - STP may not implement the requirement for conduct of inspections in a manner similar to that associated with construction phase activities (i.e.,

regarding use of personnel not qualified to ANSI N45.2.6)

R.G. 1.38, rev. 2 (5/77) No exceptions taken. No exceptions taken.

ANSI N45.2.2, 1972 2.4 - Audit personnel are qualified in accordance with STP's commitment to R.G. Same as full.

1.146/ANSI 45.2.23.

2.4 - Offsite oversight of vendors of items in the Basic category will only be performed as deemed necessary.

5.2.1- These activities do not constitute an "inspection" as defined in Same as Full ANSI/ASME NQA-1, 1983, Supplement S-I, Terms andDefinitions. Therefore, the requirements for qualification to ANSI N45.2.6 as stated in Section 2.4 do not apply to personnel performing these activities.

R.G. 1.58, rev. 1 (9/80) C.2 - STP is committed to ASNT-TC-1 A, 1980. STP treats the recommendation Same as full.*

("should") of the 1980 edition as requirements ("shall").

ANSI N45.2.6, 1978- 1.2 (1st paragraph) -'with the exception of receipt inspection, personnel may perform inspections, examinations and tests provided they are experienced, task qualified journeymen, or supervisors, who did not perform or directly supervised the activity being inspected, examined or Operations Quality Assurance Plan, Chapter 2.0, Revision 16 Page 12 of 18

TABLE I PROGRAM COMMITMENTS R.G./ANSI STANDARD FULL PROGRAM BASIC PROGRAM ANSI N45.2.6, 1978 (cont'd) tested. These individuals shall also receive training to the applicable inspection procedure, processes, methods in accordance with a Quality approved training program; and Quality will provide periodic oversight of' the inspection activities.

1.2 (3rd paragraph) - refer to table coverage of R.G. 1.28. Same as full.

1.4.4 - refer to table coverage of R.G. 1.74/ANSI N45.2. 10. Same as full.

Personnel performing the activities stated in ANSI N45.2.2, Section 5.2.1 do not Same as Full require qualification to this Standard. (see exception to ANSI N45.2.2)

R.G. 1.64, rev. 2 (6/76) No exceptions taken. C.2 - STP may implement the requirement regarding design verification as prescribed in ANSI N45.2.11, 1974, 6.1, second paragraph/second sentence, as opposed to R.G. wording.

ASNI N45.2.11, 1974 No exceptions taken. 3.2 (1st paragraph) - STP will require personnel to consider items I through 28, but a documented checklist may not be required.

Operations Quality Assurance Plan, Chapter 2.0, Revision 16 Page 13 of 18

TABLE I PROGRAM COMMITMENTS R.G./ANSI STANDARD FULL PROGRAM BASIC PROGRAM ANSI N45.2.11, 1974 (Con't.) 6.3 - Verification and checking of design may be accomplished through supervisory or management review/approval as provided for in 6.1.

Personnel will be required to consider items I through 19, but a documented checklist may not be required.

R.G. 1.74 (2/74) Not applicable to STP. STP uses ANSI/ASMENQA-1-1983 for Quality Same as full.

Assurance Terms and Definitions.

ANSI N45.2.10, 1973 Same as R.G. 1.74 above. Same as full.

R.G. 1.88, rev. 2 (10/76) No exceptions taken. Same as full.

ANSI N45.2.9, 1974 Section 5.6 - supplement the provisions of this section by providing for alternate Same as full.

temporary storage of records. Allow the use of 1-hour fire rated cabinets to store records that are awaiting processing (e.g., processing into Optical Disk Storage).

Storage of these records in 1-hour fire rated cabinets will be controlled by procedure which specify a maximum allowable time limit. Cabinets housing these records shall be controlled for access and shall be located in an area protected by sprinklers.

R.G. 1.123, rev. 1 (7/77) C.6.b.and e. - The referenced section of ANSI N45.2.13 will be implemented as written.

ANSI N45.2.13, 1976 Various sections refer to ANSI N45.2. Refer to table coverage of R.G. 1.28 and Same as full.

ANSI N45.2.

___________ I__________________________ I_____________

Operations Quality Assurance Plan, Chapter 2.0, Revision 16 Page 14 of 18

TABLE I PROGRAM COMMITMENTS RG./ANSI STANDARD FULL PROGRAM ._BASICPROGRAM ANSIN45.2.13, 1976 (cont'd) 3.2.3 - When purchasing commercial-grade calibration services from calibration Same as full laboratories accredited by a nationally-recognized accrediting body, the procurement documents are not required to impose a quality assurance program consistent with 10CFR50, Appendix B. In such cases, accreditation may be accepted in lieu of the Purchaser imposing a QAProgram consistent with 10CFR50, Appendix Bprovided all of the following are met:

1) The accreditation is to ANSI/ISO/IEC 17025

2) The accrediting body is either the National Voluntary Laboratory Accrediting Program (NVLAP) administered by the National Institute of Standards and Technology (NIST) or American Association for Laboratory Accreditation (A2LA). The A2LA accreditation is recognized by NVLAP through the International Laboratory Accreditation Cooperation (ILAC) Mutual Recognition Arrangement'(MRA).

3) The published scope of accreditation for the calibration laboratory covers the needed measurement parameters, ranges, and uncertainties. This requires the supplier to provide a measurement of collective uncertainty and obviates the need to impose the four-to-one ratio requirement discussed in NIST Information Report (NISTIR) 6989.

4) The purchase documents impose additional technical and administrative requirements, as necessary, to satisfy STPNOC QA Program and technical requirements. This requires the calibration certificate/report include identification of the laboratory equipment/standards used.

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

5.3 and 5.4 - Provision are established for, in special cases and with management Same as full.

approval, completion of these activities after award of contract.

9.0 - This section will be implemented based on the scope, complexity and safety Same as full.

___significance of the items being procured.

1- +

Operations Quality Assurance Plan, Chapter 2.0, Revision 16 Page 15 of 18

TABLE I PROGRAM COMMITMENTS R.G./ANSI STANDARD FULL PROGRAM BASIC PROGRAM ANSI N45.2.13, 1976 (cont'd) 10.3.1 -This section will only be implemented as deemed necessary.

12 - This section will only be implemented as deemed necessary for audits of suppliers.

R.G. 1.144, rev. 1 (9/80) C. I - refer to table coverage of R.G. 1.28 and ANSI N45.2. Same as full.

C.3a(1) - refer to table coverage of R.G. 1.33 regarding audit frequency. Same as full.

C.3.b(2) - When purchasing commercial-grade calibration services from Same as full for commercial-grade calibration laboratories accredited by a nationally-recognized accrediting body, calibration services the accreditation process and accrediting body may be credited with carrying out a portion of the Purchaser's duties of verifying acceptability and effective STP will audit vendors only as deemed implementation of the calibration service supplier's quality assurance program. necessary. STP will perform biennial evaluations.

In lieu of performing an audit, accepting an audit by another licensee, or performing a commercial-grade survey, a documented review of the supplier's accreditation shall be performed by the Purchaser. This review shall include, at a minimum, verification of the following:

1)The accreditation is to ANSI/ISO/IEC 17025

2) The accrediting body is either NVLAP or A2LA. The A2LA accreditation is recognized by NVLAP through the ILAC MRA.

3) The published scope of accreditation for the calibration laboratory covers the needed measurement parameters, ranges, and uncertainties. This requires the supplier to provide a measurement of collective uncertainty and obviates the need to impose the four-to-one ratio requirements discussed in NISTIR 6989.

The licensee is responsible for ensuring that the procured services are within the accredited scope of the NVLAP and A2LA certificates.

Operations Quality Assurance Plan, Chapter 2.0, Revision 16 Page 16 of 18

TABLE I PROGRAM COMMITMENTS R.G./ANSI STANDARD FULL PROGRAM BASIC PROGRAM ANSI N45.2.12, 1977 No exceptions taken. STP will audit vendors only as deemed necessary. These audits will be conducted as ufiplanned/unscheduled audits.

R.G. 1.146, rev. 0 (8/80) C. I - refer to table coverage of R.G. 1.28 and ANSI N45.2.

Refer to table coverage of R.G. 1.74 and ANSI N45.2.10 Same as full.

ANSI N45.2.23, 1978 1.2 - refer to table coverage of R.G. 1.28. Same as full.

1.4 - refer to table coverage of R.G. 1.74. Same as full.

2.21 - refer to table coverage of R.G. 1.28. Same as full.

2.3.3.1 - refer to table coverage of R.G 1.28. Same as full.

2.3.4 - In lieu of the requirements of section 2.3.4 of ANSI N45.2.23-1978 Same as full the following alternative is acceptable:

Prospective lead auditors shall demonstrate their ability to properly implement the audit process and effectively lead an audit team. This demonstration process will be described in implementing procedures and will include the evaluation and documentation of the results of the demonstration. Regardless of the methods used for the demonstration, the prospective lead auditor is required to participate in at least one nuclear quality assurance audit within the year preceding the individual's effective date of qualification. Upon successful-demonstration of the ability to effectively implement the audit process and effectively lead audits, and having met the other provisions of Section 2.3 of ANSI N45.2.23-1978, the individual may be certified as being qualified to lead audits.

_________________ .1

_________________________________________ 1* ]

Operations Quality Assurance Plan, Chapter 2.0, Revision 16 Page 17 of 18

TABLE I PROGRAM COMMITMENTS For Regulatory Guides addressed by the table, and unless specific clarification or exception is indicated, STP will implement the Regulatory Guide positions, including recommendations.

For ANSI Standards addressed by this table, and unless specific clarification or exception is indicated, STP will treat ANSI requirements (i.e., "shall")

as such - except in instances where the standard itself provides options or requires a graded approach - this notwithstanding the general applicability statements found in many standards (i.e., section 1.0)

Operations Quality Assurance Plan, Chapter 2.0, Revision 16 Page 18 of 18

SOUTH TEXAS PROJECT ELECTRICGENERATING STATION NUMBER REV.

NO.

Chapter OPERATIONS QUALITY ASSURANCE PLAN 13.0 12 Control of Conditions Adverse to Quality PAGE 1 OF 4 EFFECTIVE DATE 02-01-08 1.0 PURPOSE 1.1 The purpose of this chapter is to establish requirements and responsibilities for the identification, documentation, evaluation, resolution, control and reporting of conditions adverse to quality.

2.0 SCOPE 2.1 This chapter applies to conditions adverse to quality discovered in items, services and activities under the scope of the Operations Quality Assurance Plan and the reporting of items to the Nuclear Regulatory Commission (NRC) in accordance with Title 10 Code of Federal Regulations.

3.0 DEFINITIONS 3.1 None

4.0 REFERENCES

4.1 10CFR50, Appendix B 4.2 10CFR2 1, Reporting of Defects and Noncompliance 4.3 10CFR50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors 4.4 10CFR50.73, Licensee Event Report System 4.5 South Texas Project Electric Generating Station (STP) Technical Specifications 4.6 OQAP Chapter 14.0, Records Control 4.7 OQAP Chapter 2.0, Table I 5.0 REQUIREMENTS 5.1 All personnel working under the jurisdiction of the Operations Quality Assurance Plan are responsible for reporting conditions adverse to quality to appropriate management for resolution in accordance with approved procedures.

5.2 Procedures shall be developed for the control of items, services or activities which do not conform to established requirements. These procedures shall provide for the following:

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV.

Chapter NO.

OPERATIONS QUALITY ASSURANCE PLAN 13.0 12 Control of Conditions Adverse to Quality PAGE 2 OF4 EFFECTIVE DATE 02-01-08 5.2.1 Identification and documentation of conditions adverse to quality.

5.2.2 Identification of the requirements, source, or reference information being

.violated.

5.2.3 Notification of responsible management.

5.2.4 Control of conditions adverse to quality by tagging, segregation, administrative controls, or other appropriate means to prevent inadvertent installation, use, or continuation of the activity and removal of such controls when returned to service or availability.

5.2.5 Resolution and/or disposition approved by authorized personnel prior to closing out the documentation and restoring to normal service.

5.2.5.1 Material conditions adverse to quality disposition categories are:

o "Use-as-is" o "Reject" o "Rework" in accordance with documented procedures' o "Repair" in accordance with documented procedures 5.2.5.2 "Use-as-is" and "repair" dispositions shall be approved and justified in writing by Engineering.

5.2.5.3 Evaluations shall be performed to ascertain recurrence control measures.

5.2.6 Documentation of the corrective action taken.

5.2.7 Review and/or verification of the corrective action by the Quality organization, as appropriate.

5.2.8 Repaired and reworked items shall be reinspected in accordance with*

applicable procedures. Reinspection results are documented on inspection reports or other work process control documents.

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Chapter NO.

OPERATIONS QUALITY ASSURANCE PLAN 13.0 12 Control of Conditions Adverse to Quality PAGE 3 OF 4 EFFECTIVE DATE 02-01-08 5.2.9 Installation of nonconforming material, parts, and components may be performed after the effect of their installation has been evaluated and the installation approved by Plant Management, Quality, and Engineering.

Nonconforming items which may not be installed are those which, because of their makeup and intended use, cannot be repaired or reworked after being installed and those which, if installed and later removed, would degrade that system, structure, or component. Once installed, nonconforming items are not energized, used, or placed in service until the action required by the disposition, including reinspection, has been completed or an engineering evaluation has been prepared to justify the intended use of the nonconforming item.

5.2.10 Conditions adverse to quality identified on installed items will be evaluated for operability.

5.2.11 Disputes over corrective action are normally resolved by Plant Management. Should this resolution not be satisfactory, the parties may elevate the matter to higher management for resolution.

5.3 Procedures shall provide the following administrative controls:

5.3.1 Unique identification and numbering of conditions adverse to quality.

5.3.2 Preparing. and'maintaining status reporting of conditions adverse to quality.

5.3.3 Actions to be taken to assure timely corrective action on conditions adverse to quality.

5.4 Procedures which identify and track conditions adverse to quality shall require management review of each report to determine if the condition is significant.

For significant conditions adverse to quality, the cause of the condition and the corrective action taken to preclude repetition shall be documented and reported to appropriate levels of management.

5.5 Measures shall be established for review and evaluation of conditions adverse to.

quality for reportability to the NRC as required by References 4.2 (to the extent not exempted), 4.3, and 4.4, as appropriate.

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV.

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Chapter OPERATIONS QUALITY ASSURANCE PLAN 13.0 12 Control of Conditions Adverse to Quality PAGE 4 OF 4 EFFECTIVE DATE 02-01-08 5.6 The authority to stop work has been assigned to General Manager, Oversight or Manager, Quality (Units 1 & 2) for any activity being performed by company cc personnel or contractors which do not conform to established requirements. The Senior Vice President, the Vice President, Oversight & Regulatory Affairs, and the Manager, Quality have stop work authority for Units 3 & 4.

5.7 Measures shall be established for the evaluation and trending of conditions adverse to quality. The results of these reviews and analyses are reported to the affected organization and executive management, and are audited by the Quality organization. Adverse trends shall be evaluated and processed in accordance with controlling procedures.

6.0 DOCUMENTATION 6.1 Procedures which are generated as required by this chapter shall identify the records which are required to implement and document those activities. The records shall be controlled in accordance with Reference 4.6.

7.0 ATTACHMENTS 7.1 None

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV.

Chapter NO.

OPERATIONS QUALITY ASSURANCE PLAN 15.0 11 QUALITY OVERSIGHT ACTIVITIES PAGE 1 OF 7 EFFECTIVE DATE 02-01-08 1.0 PURPOSE 1.1 The purpose of this chapter is to establish requirements for a system of independent oversight activities of quality assurance programs for the South 0?

Texas Project (STP).

2.0 SCOPE 2.1 This chapter provides for implementing a program of independent oversight activities which includes audits, assessments, evaluations, performance monitoring, and surveillances to ensure the requirements of the Operations Quality Assurance Program are being properly implemented.

3.0 DEFINITIONS 3.1 None

4.0 REFERENCES

4.1 OQAP Chapter 2.0, Table I 4.2 OQAP Chapter 4.0, Qualification; Training and Certification of Personnel 4.3 OQAP Chapter 7.0, Procurement 4.4 OQAP Chapter 13.0, Control of Conditions Adverse .to Quality 4.5. OQAP Chapter 14.0, Records Control 5.0 REQUIREMENTS 5.1 Independent Oversight Activities 5.1.1 Procedures shall be developed to control independent oversight activities.

These activities include, but are not limited to, audits, assessments, evaluations, performance monitoring, and surveillances. These activities shall be used to observe and verify that activities are accomplished in accordance with prescribed requirements.

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV.

NO.

Chapter OPERATIONS QUALITY ASSURANCE PLAN 15.0 11 QUALITY OVERSIGHT ACTIVITIES PAGE 2 OF 7 EFFECTIVE DATE 02-01-08 5.2 Audits 5.2.1 A comprehensive audit program in compliance with Reference 4.1 shall be established and implemented by STP Nuclear Operating Company (STPNOC) to verify internal and external quality activity compliance with the Quality Program. The audit program shall assure that applicable elements of the program have been developed, documented, and are effectively implemented and shall provide for reporting and reviewing audit results by appropriate levels of management. These audits shall encompass:

5.2.1.1 The conformance of unit operation to provisions contained within the Technical Specifications and applicable license conditions; 5.2.1.2 The training and qualification of theunit staff; 5.2.1.3 Actions taken to correct deficiencies occurring in equipment, structures, systems, components, or method of operation that affect nuclear safety; 5.2.1.4 The performance of activities required by the Operational Quality Assurance Program to meet the criteria of Appendix B, 10CFR50; 5.2.1.5 The fire protection programmatic controls including the implementing procedures; 5.2.1.6 The fire protection equipment and program implementation utilizing either a qualified offsite licensee fire protection engineer or an outside independent fire protection consultant; 5.2.1.7 The Radiological Environmental Monitoring Program and the results thereof; 5.2.1.8 The OFFSITE DOSE CALCULATION MANUAL and implementing procedures; 5.2.1.9 The PROCESS CONTROL PROGRAM and implementing procedures for processing and packaging of radioactive wastes;

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV.

NO.

Chapter OPERATIONS QUALITY ASSURANCE PLAN 15.0 11 QUALITY OVERSIGHT ACTIVITIES PAGE 3 OF 7 EFFECTIVE DATE 02-01-08 5.2.1.10 The performance of activities required by the Quality Assurance Program for effluent and environmental monitoring; and 5.2.1.11 Other activities and documents as requested by the Senior o Management Team, the Senior Vice President (for Units 3 & 4) or the Executive Vice President and Chief Nuclear Officer.

5.2.2 Qualified personnel assigned auditing responsibilities shall be independent of any direct responsibility for the performance of the activities which they audit; shall be experienced or trained commensurate with the scope, complexity, or. special nature of the activities to be audited; and shall be qualified in accordance with the requirements of Reference 4.2.

512.2.1 An audit team consists of one (or more) qualified person(s). A qualified lead auditor shall be appointed as the audit team leader. The audit team leader shall be responsible for the written plans, checklists, team orientation, audit notification, pre-audit conference, audit performance, post-audit conference, reporting, and follow-up activity to assure corrective action.

The audit team leader shall promptly report conditions requiring immediate corrective action to the appropriate management of the audited organization. Other audit findings will be identified to the audited organization at the post-audit conference.

5.2.2.2 Other qualified personnel may assist in the conduct of audits, such as technical specialists or management representatives.

5.2.3 Internal Audits 5.2.3.1 Internal audits shall be conducted by the Quality Department and performed with a frequency commensurate with their safety significance, past performance and regulatory requirements. Audits are scheduled on a nominal biennial frequency, except those audits whose frequency is specifically governed by regulation.

If a decision is made to extend an audit beyond that nominal frequency, the basis for that decision shall be documented.

Decisions shall be approved by the Manager, Quality and notifications made to the General Manager, Oversight and the

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV.

Chapter NO.

OPERATIONS QUALITY ASSURANCE PLAN 15.0 11 QUALITY OVERSIGHT ACTIVITIES PAGE 4 OF 7 EFFECTIVE DATE 02-01-08 Senior Management Team and the Vice President Oversight &

Regulatory Affairs for Units 3 & 4.

5.2.3.2 Review of the audit program shall be performed at least semiannually by the Senior Management Team or by a management representative to verify that audits are being accomplished in accordance with the requirements of the Quality Program.

5.2.3.3 Audit results shall be reviewed periodically by the Quality organization for quality trends and overall audit program effectiveness. The results of these reviews shall be reported to appropriate management in periodic summary reports.

5.2.3.4 Audited organizations are responsible for providing timely corrective action including action to prevent recurrence for programmatic problems identified by an audit.

5.2.4 Supplemental audits shall be conducted when:

5.2.4.1 Significant changes are made to the quality assurance program.

5.2.4.2 It is necessary to determine the root cause of problem areas which may impact the effectiveness of the quality assurance program.

5.2.4.3 A systematic, independent assessment of program effectiveness is necessary.

5.2.4.4 Requested by appropriate management.

5.2.5 Audit implementation shall include the following:

5.2.5.1 Written notification to the audited organization of the audit, if an announced audit.

5.2.5.2 Development of an individual audit plan/scope. The audit plan and any necessary reference documents shall be available to the audit team members.

5.2.5.3 A pre-audit and post-audit conference with responsible organizational management.

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV.

Chapter NO.

OPERATIONS QUALITY ASSURANCE PLAN 15.0 11 QUALITY OVERSIGHT ACTIVITIES PAGE 5 OF 7 EFFECTIVE DATE 02-01-08 5.2.5.4 Use of a checklist or procedure as a guide during the performance of the audit.

5.2.5.5 Identifying and documenting conditions- adverse to quality.

5.2.5.6 Audit reports shall be prepared and submitted to the audited organization, Senior Management Team, the Senior Vice President (for Units 3 & 4), and the Executive Vice President and Chief Nuclear Officer within thirty days after the post-audit conference. The audit report shall address those items required by Reference 4.1.

5.2.5.7 Audited organizations provide timely and thorough corrective action and recurrence control to discrepancies identified during the audit. In the event that corrective action cannot be completed within thirty days, the audited organization's response shall include a scheduled date for the corrective action. Earlier dates for corrective action may be established if circumstances dictate.

5.2.5.8 Evaluation of corrective action for conditions adverse to quality and follow-up verification as appropriate.

5.3 Surveillance/Quality Performance Monitoring 5.3.1 Procedures and/or instructions shall be developed to control surveillance/quality performance monitoring activities.

Surveillance/quality performance monitoring activities shall be used to observe and verify that activities are accomplished in accordance with prescribed procedures.

5.3.2 Surveillance/quality performance monitoring activities will be performed during refueling outages, startup activities, and normal and off-normal operational activities. Areas to be monitored will be determined based on safety significance, past performance, regulatory requirements, and customer request.

5.3.3 The frequency of surveillance/quality performance monitoring activities is based upon the complexity of the activity, importance of the activity, and severity level of conditions noted during previous oversight activities.

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV.

NO.

Chapter OPERATIONS QUALITY ASSURANCE PLAN 15.0 11 QUALITY OVERSIGHT ACTIVITIES PAGE 6 OF 7 EFFECTIVE DATE 02-01-08 5.3.4 Surveillance/quality performance monitoring results'shall be documented and a summary shall be prepared and transmitted to responsible management.

5.4 Assessments/Evaluations 5.4.1 Assessments are conducted on a nominal biennial frequency in accordance with written procedures to assess the Quality organization's implementation of the Operations Quality Assurance Plan.

5.4.1.1 These assessments will be conducted by organizations independent of the activities performed to assure the STPNOC OQAP is being properly implemented.

5.4.1.2 The Senior Management Team shall review the scope and schedule of the assessment.

00 5.4.1.3 The results of these assessments will be transmitted to the Executive Vice President and Chief Nuclear Officer and the "0 Senior Management Team.

5.4.2 Other assessments/evaluations may be performed to verify activities are accomplished in accordance with applicable requirements and prescribed procedures.

5.4.2.1 These assessments/evaluations will be performed on areas based on their safety significance, past performance, regulatory requirements, and customer request.

5.4.2.2 Assessment/evaluation results shall be documented and transmitted to appropriate management.

5.5 An approved oversight plan shall be issued annually to include:

5.5.1 Activities/organizations to receive independent oversight.

5.5.2 Time frame in which the oversight activity will be conducted.

5.6 Conditions adverse to quality identified during an independent oversight activity shall be documented in accordance with Reference 4.4.

5.7 Personnel performing independent oversight activities shall be trained and qualified in accordance with Reference 4.2.

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV.

Chapter NO.

OPERATIONS QUALITY ASSURANCE PLAN 15.0 11 QUALITY OVERSIGHT ACTIVITIES PAGE 7 OF 7 EFFECTIVE DATE 02-01-08 6.0 DOCUMENTATION 6.1 Procedures which are generated as required by this chapter shall identify the records which are required to implement and document those activities. The records shall be controlled in accordance with Reference 4.5.

7.0 ATTACHMENTS 7.1 None

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV.

NO.

Chapter OPERATIONS QUALITY ASSURANCE PLAN 16.0 10 Independent Technical Review PAGE 1 OF3 EFFECTIVE DATE 02-01-08 1.0 PURPOSE 1.1 The purpose of this chapter is to describe the requirements and responsibilities for independent technical review for the South Texas Project (STP).

2.0 SCOPE 2.1 This chapter describes the independent technical review activities within the scope of the Operations Quality Assurance Plan (OQAP).

3.0 DEFINITIONS 3.1 None

4.0 REFERENCES

4.1 OQAP Chapter 1.0, Organization 4.2 OQAP Chapter 2.0, Program Description 4.3 OQAP Chapter 4.0, Qualification, Training, and Certification of Personnel 4.4 OQAP Chapter 13.0, Deficiency Control 4.5 OQAP Chapter 14.0, Records Control 4.6 OQAP Chapter 15.0, Quality Oversight Activities 5.0 RESPONSIBILITIES 5.1 The General Manager, Oversight is responsible for implementing quality program requirements including independent technical review.

5.2 The Manager, Quality is responsible for independent oversight activities performed to accomplish the independent technical reviews.

6.0 REQUIREMENTS 6.1 Independent oversight activities, as described in Reference 4.6, shall be performed in accordance with implementing procedures to ensure the completion of independent technical reviews.

SOUTH TEXAS PROJECTELECTRIC GENERATING STATION NUMBER REV.

NO.

Chapter OPERATIONS QUALITY ASSURANCE PLAN 16.0 10 Independent Technical Review PAGE 2 OF 3 EFFECTIVE DATE 02-01-08 6.2 Independent technical reviews shall be used to observe and verify that activities are performed correctly and that human errors are reduced as much as practical.

6.3 Independent technical reviews shall include, but not be limited to, the following activities:

6.3.1 Unit-operating characteristics 6.3.2 Nuclear Regulatory Commission issuances 6.3.3 Industry advisories 6.3.4 Licensee Event Reports 6.3.5 Other sources of unit design and operating experience information, including units of similar design, which may indicate areas for improving unit safety.

6.3.6 Plant operations 6.3.7 Maintenance activities 6.3.8 Equipment modifications 6.4 As determined by Quality management, severa'l personnel performing independent technical reviews will be required to have a degree in engineering or related science and at least 3 years of professional level experience in the nuclear field.

6.5 Personnel performing independent technical reviews should be independent of performance function, signoff function, and the plant management chain while performing this oversight activity.

6.6 The results of independent technical reviews will be periodically transmitted to appropriate line and senior management, the Senior Management Team, and the Executive Vice President and Chief Nuclear Officer for review and/or action and advise management on the overall quality and safety of operations.

6.7 Conditions adverse to quality and recommendations identified during the performance of independent technical reviews shall meet the requirements of Reference 4.4

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OPERATIONS QUALITY ASSURANCE PLAN 16.0 10 Independent Technical Review PAGE 3 OF 3 EFFECTIVE DATE 02-01-08 7.0 DOCUMENTATION 7.1 Procedures which are generated as required by this chapter shall identify the records which are required to implement and document those activities. The records shall be controlled in accordance with Reference 4.5.

8.0 ATTACHMENTS 8.1 None

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Chapter OPERATIONS QUALITY ASSURANCE PLAN. 19.0 3 ADMINISTRATIVE CONTROLS PAGE 1 OF 8 EFFECTIVE DATE 02-01-08 1.0 PURPOSE 1.1 The purpose of this chapter is to describe the administrative controls (as previously documented in the Technical Specifications) as related to quality C, assurance for the South Texas Project (STP).

2.0 SCOPE 2.1 STP Nuclear Operating Company (STPNOC), as licensee, has the Quality responsibility for administrative controls of the STP.

3.0 DEFINITIONS 3.1 None

4.0 REFERENCES

4.1 OQAP .Chapter 2.0, Table I 4.2 STP Technical Specifications 4.3 Updated Final Safety Analysis Report 4.4 OQAP Chapter 8, Control and Issuance of Documents 4.5 OQAP Chapter 14, Records Control 4.6 OQAP Chapter 15, Quality Oversightl Activities 5.0 REQUIREMENTS 5.1 The Plant Operations Review Committee (PORC) shall function to advise the Plant General Manager on all matters related to nuclear safety.

5.1.1 The PORC shall be composed of six members, who shall be appointed in writing by the Plant General Manager from senior experienced onsite individuals, at the manager level or equivalent, representing each of the following disciplines: engineering, operations, chemistry, health physics; quality assurance/quality control- and maintenance. The quality assurance/quality control representatives shall not be appointed as PORC Chairman'.

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OPERATIONS QUALITY ASSURANCE PLAN 19.0 3 ADMINISTRATIVE CONTROLS PAGE 2 OF 8 EFFECTIVE DATE 02-01-08 5.1.2 The PORC Chairman shall be appointed in writing from among those members by the Plant General Manager. One of the members shall meet the requirements of Regulatory Guide 1.8 (Personnel Selection and Training - Revision I -R), Radiation Protection Manager.

5.1.3 All alternate members shall be appointed in writing by the Plant General Manager to serve on a temporary basis; however, no more than two alternates shall participate as voting members in PORC activities at any one time.

5.1.4 The PORC shall meet at least once per calendar month and as convened by the PORC Chairman or his designated alternate.

5.1.5 The quorum of the PORC necessary for the performance of the PORC responsibility and authority provisions shall consist of the Chairman or his designated alternate and three other members including alternates.

5.1.6 The PORC shall be responsible for:

5.1.6.1 Review of all safety-related station administrative procedures and changes thereto.

5.1.6.2 Review of safety evaluations for (1) procedures, (2) changes to procedures, structures, components, or systems, and (3) tests or experiments completed under the provisions of 10CFR5 0.59 to verify that such actions did not require prior Nuclear Regulatory Commission (NRC) approval.

5.1.6.3 Review of proposed (1) procedures, (2) changes to procedures, structures, components, or systems, and (3) tests or experiments completed under the provisions of 10CFR50.59 which may require prior NRC approval.

5.1.6.4 Review of all required programs by Technical Specification 6.8 and the Technical Requirements Manual 6.8 and changes thereto.

5.1.6.5 Review of all proposed changes to the Technical Specifications or the Operating License.

5.1.6.6 Review of all REPORTABLE EVENTS.

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OPERATIONS QUALITY ASSURANCE PLAN 19.0 3 ADMINISTRATIVE CONTROLS PAGE 3 OF 8 EFFECTIVE DATE 02-01-08 5.1.6.7 Review of reports of significant operating abnormalities or deviations from normal and expected performance of plant equipment or systems that affect nuclear safety.

5.1.6.8 Review of reports of unanticipated deficiencies in the design or operation of structures, systems, or components that affect nuclear safety.

5.1.6.9 Review of the Security Plan and implementing procedures and changes thereto.

5.1.6.10 Review of the Emergency Plan and implementing procedures and changes thereto.

5.1.6.11 Review of the PROCESS CONTROL PROGRAM and implementing procedures and changes thereto.

5.1.6.12 Review of the OFFSITE DOSE CALCULATION MANUAL and implementing procedures and changes thereto.

5.1.6.13 Performance of special reviews, investigations, or analyses and reports thereon as requested by the Plant General Manager or the Senior Management Team (SMT).

5.1.6.14 Review of any accidental, unplanned, or uncontrolled radioactive release including the preparation of reports covering evaluation, recommendations, and disposition of the corrective action to prevent recurrence and the forwarding of these reports to the Plant General Manager and to the SMT.

5.1.6.15 Reports of violations of codes, regulations, orders, Technical Specifications, or Operating License requirements having nuclear safety significance or reports of abnormal degradation of systems designed to contain radioactive material.

5.1.6.16 Review of the Fire Protection Program, quality-related implementing procedures and changes thereto.

5.1.7 The PORC shall recommend in writing to the Plant General Manager approval or disapproval of items considered under section 5.1.6.1 through 5.1.6.5 prior to their implementation, and items considered under sections 5.1.6.9 through 5.1.6.12.

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Chapter OPERATIONS QUALITY ASSURANCE PLAN 19.0 3 ADMINISTRATIVE CONTROLS PAGE 4 OF 8 EFFECTIVE DATE 02-01-08 5.1.8 The PORC shall render determinations in writing with regard to whether or not each item considered under sections 5.1.6.1 through 5.1.6.5 and 5.1.6.15 may require prior NRC approval under the provisions of 10CFR50.59.

5.1.9 The PORC shall provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Executive Vice President and Chief Nuclear Officer and the Senior Management Team of disagreement between the PORC and the Plant General Manager; however, the Plant General Manager shall have the responsibility for resolution of such disagreements.pursuant to Technical Specification 6.1.1.

01 5.1.10 The PORC shall maintain written minutes of each PORC meeting that, at a minimum, document the results of all PORC activities performed under the responsibility provisions of this chapter. Copies shall be provided to the Executive Vice President and Chief Nuclear Officer and the appropriate organizational unit.

5.2 Appropriate organizational units shall function to provide independent review of designated activities asrequired by ANSI N 18.7-1976/ANS-3.2, Sections 4.3, 4.3.1, 4.3.3, and 4.3.4.

5.2.1 Staff personnel required to perform these independent reviews shall collectively have the experience and competence to review operational activities in the following areas:

5.2.1.1 Nuclear power plant operations; 5.2.1.2 Nuclear engineering; 5.2.1.3 Chemistry and radiochemistry; 5.2.1.4 Metallurgy; 5.2.1.5 Instrumentation and control; 5.2.1.6 Radiological safety; 5.2.1.7 Mechanical and electrical engineering; 5.2.1.8 Civil engineering; 5.2.1.9 Training;

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Chapter OPERATIONS QUALITY ASSURANCE PLAN 19.0 3 ADMINISTRATIVE CONTROLS PAGE 5 OF 8 EFFECTIVE DATE. 02-01-08 5.2.1.10 Nuclear assurance; 5.2.1.11 Nuclear licensing; 5.2.1.12 Plant security, and; 5.2.1.13 Environmental impact Note: If sufficient expertise is not available from within the STPNOC for the areas noted above, appropriate expertise shall be brought to bear in the independent reviews through the use of outside consultants'.

00 5.2.2 The Senior Management Team shall functionally report to and advise the Executive Vice President and Chief Nuclear Officer on those areas of responsibility specified in sections 5.2.3 and 5.2.4.

5.2.3 Appropriate organizational units shall be responsible for the review of:

5.2.3.1 The safety evaluations for: (1) changes to procedures, equipment, or systems; and (2) tests or experiments completed under the provision of 10CFR50.59, to verify that such actions did not require prior NRC approval; 5.2.3.2 Proposed changes to procedures, equipment, or systems which require prior NRC approval under the provisions of

.10CFR50.59; 5.2.3:3 Proposed tests or experiments which require prior NRC approval under the provisions of 10CFR50.59; 5.2.3.4 Proposed changes to Technical Specifications or the Operating License; 5.2.3.5 Violations of Codes, regulations, orders, Technical Specifications, license requirements, or of internal procedures or instructions having nuclear safety significance; 5.2.3.6 Significant operating abnormalities or deviations from normal and expected performance of unit equipment that affect nuclear safety; 5.2.3.7 All REPORTABLE EVENTS;

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Chapter OPERATIONS QUALITY ASSURANCE PLAN 19.0 3 ADMINISTRATIVE CONTROLS PAGE 6 OF 8 EFFECTIVE DATE 02-01-08 5.2.3.8 All recognized indications of an unanticipated deficiency in some aspect of design or operation of structures, systems, or components that could affect nuclear safety; and 5.2.3.9 Reports and meeting minutes of the PORC.

C?

5.2.4 Reports of audits of unit activities shall be reviewed by the Senior <

Management Team.

5.2.5 Records of organizational unit independent review activities shall be prepared, approved, and distributed as indicated below:

5.2.5.1 Reports of organizational unit independent reviews encompassed by sections 5.2.3 and 5.2.4, shall be prepared, approved, and forwarded to the Executive Vice President and Chief Nuclear Officer and the Senior Management Team.

5.3 Technical Review and Control 5.3.1 Activities that affect nuclear safety shall be conducted as follows:

5.3.1.1 Procedures required by Technical Specification 6.8 and Technical Requirements Manual 6.8, and other procedures that affect nuclear safety, and changes thereto, shall be prepared, reviewed, and approved. Each such procedure, or change thereto, shall be reviewed by an individual/group other than the individual/group who prepared the procedure, or change thereto, but who may be from the same organization as the individual/group who prepared the procedure, or change thereto. Procedures other than station administrative procedures shall be approved by the Plant General Manager or the head of the responsible department prior to implementation.

The Plant General Manager shall approve station administrative procedures, security plan implementing procedures, and emergency plan implementing procedures.

Temporary changes to procedures, which clearly do not change the intent of the approved procedures, shall be approved prior to implementation by two members of the plant'staff, at least one of whom holds a Senior Reactor Operator's License.

Changes to procedures that may involve a change to the intent of the original procedure shall be approved by the individual authorized to approve the procedure prior to implementation of the change.

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Chapter OPERATIONS QUALITY ASSURANCE PLAN 19.0 3 ADMINISTRATIVE CONTROLS PAGE 7 OF 8 EFFECTIVE DATE 02-01-08 5.3.1.2 Proposed changes or modifications to safety-related structures, systems, and components shall be reviewed as designated by the Plant General Manager. Each such modification shall be reviewed by an individual/group other than the individual/group who designed the modification, but who may be from the same organization as the individual/group who designed the modification. Proposed modifications to safety-related structures, systems, and components shall be approved by the Plant General Manager prior to implementation.

5.3.1.3 Proposed tests and experiments that affect nuclear safety and that are not addressed in the Final Safety Analysis Report shall be prepared, reviewed, and approved prior to implementation.

Each such test or experiment shall be reviewed by an individual/group other than the individual/group who prepared the test or experiment but who may.be from the same organization as the individual/group who prepared the test or experiment. Proposed tests and experiments shall be approved by the Plant General Manager.

5.3.1.4 Individuals responsible for reviews performed in accordance with sections 5.3.1.1, 5.3.1.2, and 5.3.1.3 shall be members of the plant management staff previously designated by the Plant General Manager. Each review shall include a determination of whether or not additional, cross-disciplinary review is necessary. If deemed necessary, such review shall be performed by qualified personnel of the appropriate discipline.

5.3.1.5 Each review will include a determination of whether or not prior NRC approval is involved pursuant to 10CFR50.59.

NRC approval of items will be obtained prior to Plant General Manager approval for implementation.

5.3.2 Records of the above activities shall be provided to the Plant General Manager, PORC, and/or the appropriate organizational unit as necessary for required reviews.

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OPERATIONS QUALITY ASSURANCE PLAN 19.0 3 ADMINISTRATIVE CONTROLS PAGE 8 OF 8 EFFECTIVE DATE 02-01-08 6.0 DOCUMENTATION 6.1 Procedures which are generated as required by this chapter shall identify the records which are. required to implement and document those activities. The records shall be controlled in accordance with the requirements of this chapter and Reference 4.4.

7.0 ATTACHMENTS 7.1 None