NOC-AE-13002955, Submittal of Operations Quality Assurance Plan Change QA-078
| ML13038A620 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 01/24/2013 |
| From: | Koehl D South Texas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| G09.19, NOC-AE-13002955, QA-078, STI: 33648245 | |
| Download: ML13038A620 (78) | |
Text
Nuclear Operating Company South Texas ProjectElectric GeneratinSStation PO.Box 289 Wadsworth, Texas 77483 v January 24, 2013 NOC-AE-13002955 File No.: G09.19 10CFR50.54(a)
STI: 33648245 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 South Texas Project Units 1 and 2 Docket Nos. STN 50-498 and STN 50-499 Submittal of Operations Quality Assurance Plan Change QA-078 The STP Nuclear Operating Company (STPNOC) submits the attached change to revision 20 of the Operations Quality Assurance Plan (OQAP). These changes are editorial and provide consistency in use of terms, correct typographical errors and formatting issues.
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 Mr. T. F. Walker at (361) 972-73 2 or me at (361) 97,' 800.
Dennis L. Koehl President and CEO/CNO
Attachment:
Operations Quality Assurance Plan change QA-078 Dooq4
NOC-AE-13002955 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 1600 East Lamar Boulevard Arlington, TX 76011-4511 Balwant K. Singal U. S. Nuclear Regulatory Commission Balwant K. Singal John Ragan Senior Project Manager Chris O'Hara U.S. Nuclear Regulatory Commission Jim von Suskil One White Flint North (MS 8 B31) NRG South Texas LP 11555 Rockville Pike Rockville, MD 20852 Kevin Polio Senior Resident Inspector Richard Pena U. S. Nuclear Regulatory Commission City Public Service P. 0. Box 289, Mail Code: MN 116 Wadsworth, TX 77483 C. M. Canady Peter Nemeth City of Austin Crain Caton & James, P.C.
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-078
SUMMARY
OF CHANGES Page 1 of 2 ALL CHANGES ARE IN BOLD TYPE CHAPTER LOCATION ACTION TEXT TOC CH 5.0 INSERT QA-078 CH 6.0 INSERT QA-078 CH 7.0 INSERT QA-078 CH 8.0 INSERT QA-078 CH 9.0 INSERT QA-078 CH 10.0 INSERT QA-078 CH 11.0 INSERT QA-078 CH 12.0 INSERT QA-078 CH 13.0 INSERT QA-078 CH 14.0 INSERT QA-078 CH 20.0 INSERT QA-078 CH 5.0 1.1 DELETE Electric Generating Station 5.1.2 DELETE delete a return to tie the sentence back together 5.6.1.3 2 nd bullet DELETE delete a return to tie the sentence back together CH 6.0 1.1 DELETE Electric Generating Station CH 7.0 1.1 DELETE Electric Generating Station CH 8.0 1.1 DELETE Electric Generating Station CH 9.0 1.1 DELETE Electric Generating Station CH 10.0 1.1 INSERT of activities and structures, systems, and components at the South Texas Project (STP).
2.1 DELETE at the South Texas Project Electric Generating Station (STP)
INSERT activities and and to demonstrate compliance with design and operational requirements.
CH 11.0 1.1 INSERT at the South Texas Project (STP).
CHANGE QA-078
SUMMARY
OF CHANGES Page 2 of 2 ALL CHANGES ARE IN BOLD TYPE CHAPTER LOCATION ACTION TEXT CH 12.0 1.1 DELETE Electric Generating Station CH 13.0 1.1 INSERT at the South Texas Project (STP) 4.5 DELETE South Texas Project Electric Generating Station and 0 4.8 INSERT NRC Regulatory Issue Summary 2005-20 4.9 INSERT STP Reporting Manual 5.2.10 INSERT and functionality CH 14.0 2.1 DELETE Electric Generating Station CH 20.0 2.2 DELETE 20 and Appendix INSERT 72 and Subpart 4.5 DELETE Part
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Chapter OPERATIONS QUALITY ASSURANCE PLAN TABLE 20 OF CONTENT TABLE OF CONTENTS PAGE 1 OF 2 EFFECTIVE DATE 02-01-12 Chapter Title Effective Effective Change Number Chapter Revision Date Notice No.
Definitions 9 2-1-02 QA-075 1.0 Organization 16 2-1-12 QA-074, QA-075 2.0 Program Description 18 2-1-12 QA-074,QA-075, QA-076 3.0 Conduct of Operation 8 2-1-10 QA-075 4.0 Qualification, Training, and 6 2-1-98 QA-075 Certification of Personnel 5.0 Maintenance, Installation of 5 2-1-98 QA-078 Modifications, and Related Activities 6.0 Design and Modification Control 10 2-1-12 QA-078 7.0 Procurement 13 2-1-12 QA-074 QA-076, QA-078 8.0 Control and Issuance of 6 2-1-98 QA-078 Documents 9.0 Control of Material 6 2-1-98 QA-078 10.0 Inspection 11 2-1-08 QA-078 11.0 Test Control 8 2-1-08 QA-078 12.0 Instrument and Calibration 6 2-1-98 QA-078 Control 13.0 Control Of Conditions Adverse 14 2-1-12 QA-074, QA-078 to Quality 14.0 Records Control 8 2-1-06 QA-074, QA-078
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Chapter OPERATIONS QUALITY ASSURANCE PLAN TABLE 20 OF CONTENT TABLE OF CONTENTS PAGE 2 OF 2 EFFECTIVE DATE 02-01-12 Chapter Title Effective Effective Change Number Chapter Revision Date Notice No.
15.0 Quality Oversight 13 2-1-12 QA-074 Activities 16.0 Independent Technical 12 2-1-12 QA-074, QA-075 Review 17.0 ASME Code Section XI - 10 2-1-12 QA-074 Repairs and Replacements 18.0 ASME Code Section XI - 11 2-1-12 QA-074 Inservice Inspection and Testing 19.0 Administrative Controls 5 2-1-12 QA-074, QA-075 20.0 Dry Cask Storage System and 0 8-9-12 QA-075 Independent Spent Fuel Storage QA-077, QA-078 Installation
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OPERATIONS QUALITY ASSURANCE PLAN 5.0 5 MAINTENANCE, INSTALLATION OF MODIFICATIONS, AND RELATED ACTIVITIES PAGE 1 OF 7 EFFECTIVE DATE 2-1-98 1.0 PURPOSE 1.1 The purpose of this chapter is to establish requirements for the conduct of maintenance and installation controls for modifications on structures, systems, 0H and components at the South Texas Project (STP). cy-2.0 SCOPE 2.1 This chapter is applicable to maintenance and the installation of modifications, including related activities such as special processes (e.g., welding, cleaning, and housekeeping), of structures, systems, and components subject to the controls of this OQAP.
3.0 DEFINITIONS 3.1 None
4.0 REFERENCES
4.1 OQAP Chapter 2.0, Table I 4.2 OQAP Chapter 3.0, Conduct of Plant Operations 4.3 OQAP Chapter 4.0, Qualification, Training and Certification of Personnel 4.4 OQAP Chapter 8.0, Control and Issuance of Documents 4.5 OQAP Chapter 12.0, Instrument and Calibration Control 4.6 OQAP Chapter 14.0, Records Control 4.7 OQAP Chapter 13.0, Control of Conditions Adverse to Quality 5.0 REQUIREMENTS 5.1 Maintenance, the installation of modifications, and related activities which may affect the functioning of structures, systems, or components shall:
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Chapter OPERATIONS QUALITY ASSURANCE PLAN 5.0 5 MAINTENANCE, INSTALLATION OF MODIFICATIONS, AND RELATED ACTIVITIES PAGE 2 OF 7 EFFECTIVE DATE 2-1-98 5.1.1 Be performed in a manner to ensure quality equivalent to that specified in design bases and requirements, materials specifications, and inspection requirements.
5.1.2 Be preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances which conform to applicable codes, standards, specifications, and criteria, <
and:
5.1.2.1, Address controls which assure quality of maintenance and modification installation activities (for example: inspections, measurements, tests, welding, heat treatment, cleaning, nondestructive examination, and personnel qualifications) and contain provisions to document the performance thereof.
5.1.2.2 Contain measures, which identify the inspection and test status of material, equipment, and components used in maintenance and modification installation activities.
5.1.2.3 Assure that the equipment has been returned to prescribed operating status at the completion of the work, which includes verification of functional acceptability.
.5.1.2.4 Be performed by or under the supervision of qualified personnel and in such a manner that the activity can be safely performed under the existing plant operating conditions.
5.1.2.5 Be performed only after authorized release of equipment in accordance with procedures that meet the requirements of Reference 4.2.
5.1.2.6 Provide measures for the protection of workers and equipment, including personnel entry into enclosed spaces such as tanks and voids.
5.1.2.7 Provide means of preventing unauthorized operation of equipment (e.g., locking or tagging).
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Chapter OPERATIONS QUALITY ASSURANCE PLAN 5.0 5 MAINTENANCE, INSTALLATION OF MODIFICATIONS, AND RELATED ACTIVITIES PAGE 3 OF 7 EFFECTIVE DATE 2-1-98 5.1.2.8 Assure control of temporary modifications (e.g., blank flanges or temporary electrical jumpers).
5.1.2.9 Provide a method of ensuring that required tests and inspections are complete prior to return to service of the item on which the work was performed.
5.1.3 Assure procedures, and changes thereto, are reviewed and approved in accordance with Reference 4.4.
5.2 Preventive Maintenance 5.2.1 A preventive maintenance program shall be maintained which prescribes the frequency and type of maintenance to be performed. This program is based on service conditions, manufacturer's recommendations, and equipment performance experience.
5.3 Corrective Maintenance 5.3.1 Equipment failures, malfunctions and degradation shall be corrected in accordance with Reference 4.7. This shall include determination of root cause and implementation of recurrence controls, as appropriate.
5.3.2 Replacement components of a new type shall receive adequate testing or be of a design for which experience indicates a high probability of satisfactory performance.
5.3.3 Consideration should be given to an augmented testing and inspection program following a large-scale component replacement (or repair) until a suitable level of performance has been demonstrated.
5.4 Emergency Maintenance Should operating conditions occur which warrant immediate corrective maintenance in order to prevent or mitigate the release of radioactive material, hazards to personnel, or extensive equipment damage, then the following shall apply:
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Chapter OPERATIONS QUALITY ASSURANCE PLAN 5.0 5 MAINTENANCE, INSTALLATION OF MODIFICATIONS, AND RELATED ACTIVITIES PAGE 4 OF 7 EFFECTIVE DATE 2-1-98 5.4.1 Direct action shall be taken to stabilize the condition. Procedures shall designate those operating individuals responsible for authorizing this initial action.
5.4.2 Once the condition has stabilized, the initial action taken shall be documented and reviewed in accordance with approved procedures. If the initial action taken is judged to be incorrect or inadequate, alternative action shall be taken.
5.5 Control of Special Process 5.5.1 Special processes include manufacturing processes, inspections, tests, and others, which require qualification of the procedures, technique or personnel to control the quality of the process. Special processes (e.g.,
welding, heat treating, chemical cleaning, protective coating, and nondestructive examination) shall be performed in accordance with applicable codes, standards, specifications, criteria and other special requirements.
5.5.1.1 Written procedures shall be established and utilized to assure these activities are accomplished in a controlled manner.
5.5.1.2 Special processes shall be performed by qualified personnel using qualified procedures. Personnel shall be qualified under Reference 4.3. Procedures and equipment shall be qualified under applicable codes and standards, or if not covered, the qualification requirements shall be defined.
5.5.1.3 Records shall be maintained and kept current for the qualification of procedures, equipment, and personnel associated with special processes. Records shall be in sufficient detail to clearly define the procedures, equipment, or personnel being qualified, criteria or requirements used for qualification and the individual approving the qualification.
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Chapter OPERATIONS QUALITY ASSURANCE PLAN 5.0 5 MAINTENANCE, INSTALLATION OF MODIFICATIONS, AND RELATED ACTIVITIES PAGE 5 OF 7 EFFECTIVE DATE 2-1-98 5.5.1.4 Procedures shall provide for the control of special process identification indicators, such as welder's stamps, as appropriate.
5.5.2 Control of Outside Contractors 5.5.2.1 Qualified outside organizations may be employed to perform special processes and shall be required to conform to the requirements described in this chapter. Special process procedures submitted by an outside organization in accordance with procurement document requirements shall receive a technical review by the responsible site organization.
5.6 Housekeeping and Cleanness Control 5.6.1 Housekeeping and cleanness control practices shall be established which assure that:
5.6.1.1 The nature of work activities, conditions, and environments that can affect the quality of structures, systems, and components is controlled. Control measures shall be established to exclude the entry of foreign material into a closed system and to ensure that foreign material is removed before the area is closed.
5.6.1.2 Appropriate cleaning materials, equipment processes, and procedures are used to assure that the quality of an item is not degraded as a result of housekeeping or cleaning practices or techniques and provide for the disposal of combustible material and debris to support fire protection.
5.6.1.3 Access is controlled to prevent foreign material introduction during the maintenance or modification of systems.
- Cleaning following maintenance or modification of radioactively contaminated systems or equipment shall
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OPERATIONS QUALITY ASSURANCE PLAN 5.0 5 MAINTENANCE, INSTALLATION OF MODIFICATIONS, AND RELATED ACTIVITIES PAGE 6 OF 7 EFFECTIVE DATE 2-1-98 require special consideration for radioactive contamination control and storage of radioactive waste.
- Prior to closure of designated systems or components, an inspection shall be conducted to assure cleanness. The results of the inspection shall be documented.
5.6.1.4 Where necessary, special cleaning requirements associated with certain equipment are addressed in appropriate procedures.
5.7 Documents Associated with Maintenance/Modifications 5.7.1 Documents, such as maintenance, modifications, and installation procedures, maintenance requests, drawings, specifications and others shall be issued, reviewed and controlled in accordance with Reference 4.4.
5.7.2 Maintenance, modification, and installation documents shall be traceable to the structure, system or component repaired, replaced, or maintained and shall as a minimum contain the following:
5.7.2.1 Description of components 5.7.2.2 Description of work 5.7.2.3 Names of responsible persons doing work 5.7.2.4 Traceability of parts used 5.7.2.5 Reference to measuring and test equipment used 5.7.2.6 Inspection and test status
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OPERATIONS QUALITY ASSURANCE PLAN 5.0 5 MAINTENANCE, INSTALLATION OF MODIFICATIONS, AND RELATED ACTIVITIES PAGE 7 OF 7 EFFECTIVE DATE 2-1-98 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
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OPERATIONS QUALITY ASSURANCE PLAN 6.0 10 DESIGN AND MODIFICATION CONTROL PAGE 1OF6 EFFECTIVE DATE 02-01-12 1.0 PURPOSE 1.1 The purpose of this chapter is to establish the requirements and responsibilities for design and modification control of structures, systems, or components at the 90 o'
2.0 SCOPE 2.1 This chapter applies to the design and modification activities associated with the preparation and review of design documents including the translation of applicable Code of Federal Regulation requirements and design bases into design documents.
3.0 DEFINITIONS 3.1 None
4.0 REFERENCES
4.1 STP Technical Specifications 4.2 OQAP Chapter 5.0, Maintenance, Installation of Modifications, and Related Activities 4.3 OQAP Chapter 14.0, Records Control 4.4 10CFR50.59, Changes, Tests and Experiments 4.5 OQAP Chapter 13.0, Control of Conditions Adverse to Quality 4.6 OQAP Chapter 2.0, Table I
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OPERATIONS QUALITY ASSURANCE PLAN 6.0 10 DESIGN AND MODIFICATION CONTROL PAGE 2 OF 6 EFFECTIVE DATE 02-01-12 5.0 REQUIREMENTS 5.1 Measures shall be established to document selection of design inputs. Changes to specified design inputs, including identification of their source, shall be identified and documented. As the design evolves, a review pursuant to the requirements of 10CFR50.59 shall be performed as required by Reference 4A4.
5.2 Measures shall be established to control design activities to assure design inputs are translated into design documents such as specifications, drawings, procedures, or instructions.
5.2.1 Design activities involving reactor physics; stress, thermal, hydraulic, and accident analysis; materials compatibility; and accessibility for maintenance, inservice inspection, and repair will be performed according to approved procedures by appropriately qualified individuals. Results of analyses will be appropriately verified and documented.
5.2.2 Design documents shall include appropriate quality standards. If an alternate quality requirement is used (e.g., other than the originally specified quality standard) the change shall be documented and approved.
5.2.3 Design analyses shall be sufficiently detailed as to purpose, method, assumptions, design input, references, units, and status (preliminary or final) such that a technically qualified person can review and understand the analyses and verify the adequacy of the results without recourse to the originator.
.5.2.4 A review fior application suitability of materials, parts, equipment, and processes essential to the functions of structures, systems, and components is done as part of the design document preparation and review process.
The procedures, which govern the preparation and review of design documents., require that valid industry standards and specifications be used for this review. Review of standard off-the-shelf commercial materials, parts, and equipment for suitability of application with structures, systems, and components will be conducted before selection.
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Chapter OPERATIONS QUALITY ASSURANCE PLAN 6.0 10 DESIGN AND MODIFICATION CONTROL PAGE 3 OF 6 EFFECTIVE DATE 02-01-12 5.3 Measures shall be established to identify and control design interface among participating organizations (internal and external).
5.4 Measures shall be established to verify adequacy of design and design changes.
5.4.1 The design process shall include verification by qualified persons to assure that the design is adequate and meets specified design input.
Design control procedures shall specify requirements for the selection and performance of design verification methods. Design verification shall be either by design review, alternate calculation, qualification testing, or a combination of these. The depth of design verification shall be commensurate with the importance of the system or component to plant safety, complexity of the design, and similarity of design to previous designs.
5.4.1.1 If the verification method performed is only through qualification testing, the following are required.
" Procedures shall provide criteria that specify when verification should be by test.
- Prototype, component, or feature testing shall be performed as early as possible before installation of plant equipment, or before the point when the installation would become irreversible.
" Verification by test shall be performed under conditions that simulate the most adverse design conditions as determined by analysis.
5.4.2 Design verification shall be performed by competent individuals or groups other than those who performed the original design.
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Chapter OPERATIONS QUALITY ASSURANCE PLAN 6.0 10 DESIGN AND MODIFICATION CONTROL PAGE 4 OF 6 EFFECTIVE DATE 02-01-12 5.4.3 Design verification should not be performed by individuals that have immediate supervisory responsibility for the individual performing the design; have specified a singular design approach; have ruled out certain design considerations; or have established the design inputs for that particular design aspect. (This paragraph's recommendation does not apply to verification of design for items in the "Basic" or "Limited" program category) 5.4.4 Design verification will normally be performed prior to release for procurement, manufacture, installation, or use by another organization in other design activities. Exceptions shall be justified and documented.
Procedures shall control the justification of exceptions and the completion of the verification of all affected design output documents prior to relying on the component, system, or structure to perform its function.
5.5 Measures shall be established to control the approval, issuance, and changes of design documents to prevent the inadvertent use of superseded design information.
5.6 Changes made to design documents are reviewed and approved by the same groups or organization, which reviewed and approved original design documents.
If the organization which originally approved a particular design document is no longer responsible, another organization may be designated if competent in the specific design area, has access to pertinent background information and has an adequate understanding of the requirements and intent of the original design.
5.7 Conditions adverse to quality found in approved design documents, including design methods, that could adversely affect structures, systems, or components shall be documented and action taken to correct and prevent recurrence, in accordance with Reference 4.5.
5.8 Measures shall be established for the identification and control of deviations from specified quality standards.
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OPERATIONS QUALITY ASSURANCE PLAN 6.0 10 DESIGN AND MODIFICATION CONTROL PAGE 5 OF 6 EFFECTIVE DATE 02-01-12 5.9 Measures shall be established which assure that maintenance and modifications associated with design changes which may affect the functioning of structures, systems, or components are performed in a manner to ensure quality at least equivalent to that specified in the UFSAR or current design bases and requirements.
5.10 Measures shall be established to maintain the list of structures, systems, and components current after modifications are made.
5.11 Measures shall be established to assure that only appropriately verified, qualified and controlled computer codes are authorized for use.
5.12 Modifications 5.12.1 Modifications to structures, systems, and components shall be controlled, reviewed, and approved.
5.12.2 Installation and testing of modifications shall be performed in accordance with Reference 4.2 and approved procedures. These procedures shall contain provisions as appropriate to ensure quality of installation and appropriate post modification testing. (This paragraph does not apply to components in the "Limited" program category, unless design verification testing is being performed in accordance with 5.4.1.1.)
5.12.3 Structures, systems, and components shall not be declared operable after a modification until the following provisions are satisfied:
5.12.3.1 Affected procedures are revised and distributed to appropriate users.
5.12.3.2 Appropriate personnel are trained.
5.13 Modifications will be checked against the design change documentation for proper implementation prior to closing out the design change process.
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OPERATIONS QUALITY ASSURANCE PLAN 6.0 10 DESIGN AND MODIFICATION CONTROL PAGE 6 OF 6 EFFECTIVE DATE 02-01-12 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 4.3.
7.0 ATTACHMENTS 7.1 None
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OPERATIONS QUALITY ASSURANCE PLAN 7.0 13 PROCUREMENT PAGE 1 OF 13 EFFECTIVE DATE 02-01-12 1.0 PURPOSE 1.1 The purpose of this chapter is to establish the requirements for procurement of 00 items and services for the South Texas Project (STP).
2.0 SCOPE 2.1 This chapter applies to the procurement of items and services for use at STP which are subject to the controls of this Quality program. These activities include procurement document control, bid evaluation, vendor evaluation, verification of vendor activities and receiving inspection.
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 OQAP Chapter 2.0, Table I 4.4 EPRI NP-5652 (NCIG-07), Guideline for the Utilization of Commercial Grade Items in Nuclear Safety Related Application 4.5 OQAP Chapter 4.0, Qualification, Training and Certification of Personnel 4.6 OQAP Chapter 13.0, Control of Conditions Adverse to Quality 4.7 OQAP Chapter 14.0, Records Control 4.8 Generic Letter 89-02, Actions to Improve the Detection of Counterfeit and Fraudulent Marketed Products
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Chapter OPERATIONS QUALITY ASSURANCE PLAN 7.0 13 PROCUREMENT PAGE 2 OF 13 EFFECTIVE DATE 02-01-12 5.0 REQUIREMENTS 5.1 Procurement Document Preparation, Review and Control 5.1.1 Responsibility for procurement is a joint effort of all the departments within the STP Nuclear Operating Company (STPNOC). The department requesting the material or service provides technical content and quality requirements. Engineering/Contracts & Procurement is responsible to provide input to the requesting department on technical content and quality requirements, as requested. Quality will concur with all changes to quality requirements.
5.1.2 The sequence of preparation, review, approval, and issuance of procurement documents is generally as follows:
5.1.2.1 Purchase Requisitions
" Purchase requisition forms shall be used to initiate the procurement of materials, parts, components, and services.
Procurement may be initiated by any STPNOC personnel.
- Purchase requisitions shall include material and component identification requirements, drawings, specifications, standards, inspection and test requirements, and special process instructions as appropriate.
- Purchase requisitions for materials, parts, components, or services shall be reviewed by the cognizant technical organization to verify that adequate technical and quality requirements have been specified.
- The reviews for technical and quality requirements shall be performed by someone other than the originator of the requisition. Quality will concur with all changes to quality requirements.
5.1.2.2 Purchase Orders and Contracts
- Purchase orders and contracts are prepared and issued by Contracts & Procurement and establish for the suppliers the technical and quality requirements which must be met.
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Chapter OPERATIONS QUALITY ASSURANCE PLAN 7.0 13 PROCUREMENT PAGE 3 OF 13 EFFECTIVE DATE 02-01-12 Purchase orders and contracts shall accurately reflect the technical and quality requirements established by the purchase requisition. If, during the bid negotiations with the supplier, it becomes necessary or commercially desirable to change the technical or quality requirements, such changes shall be presented for approval to the cognizant technical organization which approved the original requirements.
5.1.2.3 Change Controls Changes to procurement document quality and technical requirements shall require a review and approval equivalent to that of the original document. Commercial consideration changes not affecting the technical or quality requirements do not require review and concurrence by the originator.
5.1.3 For the procurement of spare or replacement parts, equipment, materials, and services, the quality and technical requirements shall be equal to or greater than the design basis requirements for the original part, equipment, materials or services; except where less stringent quality or technical requirements may be established based on specific evaluations and justification. The cognizant technical organization shall document such justification.
5.1.3.1 Items may be procured as Commercial Grade Items (CGIs) if a documented engineering evaluation indicates the CGI will provide equivalent performance. CGI dedication will comply with established.procedures designed to satisfy the requirements of References 4.2 and 4.8.
5.1.3.2 The cognizant technical organization shall verify that quality requirements are correctly stated, verifiable, and controllable; that acceptance/rejection criteria are included; and that the documents have been prepared, reviewed, and approved in accordance with STP Quality Program requirements.
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Chapter OPERATIONS QUALITY ASSURANCE PLAN 7.0 13 PROCUREMENT PAGE 4 OF 13 EFFECTIVE DATE 02-01-12 5.2 Procurement Document Content 5.2.1 Procurement document control measures shall assure that appropriate regulatory requirements, design bases, and other requirements are included in the procurement process. The following shall be included or invoked by reference in procurement documents as appropriate:
5.2.1.1 Applicable regulatory, code, and design requirements, including material and component identification requirements, drawings, specifications, standards, inspection and test requirements, special process instructions and handling, preservation, cleaning, storage, packaging and shipping requirements. These requirements shall equal or exceed the original requirements (unless changed by established design control processes).
5.2.1.2 Extent that supplier QA program shall comply with 10CFR50, Appendix B or the QA program requirements of other nationally recognized codes and standards, as applicable; or for CGIs to be dedicated for safety related use by STPNOC based on the results of a survey of the vendor's controls, the vendor's STPNOC approved and/or surveyed program.
5.2.1.3 Requirements for supplier documents, such as instructions, procedures, drawings, specifications, inspection and test records, and suppliers' QA records to be prepared, submitted, or be made available for review and/or approval by STP personnel.
5.2.1.4 Requirements for suppliers to maintain the status of required inspections or tests throughout the manufacturing process to preclude inadvertent bypassing of inspections and tests.
5.2.1.5 Requirements for STPNOC's right of access to suppliers' facilities and work documents for inspection and audit.
5.2.1.6 Requirements for extending applicable STP procurement requirements to lower-tier suppliers and subcontractors, including STPNOC's access to facilities and records.
5.2.1.7 Requirements for supplier reporting to STP nonconformances to procurement document requirements and conditions for their disposition.
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Chapter OPERATIONS QUALITY ASSURANCE PLAN 7.0 13 PROCUREMENT PAGE 5 OF 13 EFFECTIVE DATE 02-01-12 5.2.1.8 Requirements for the retention, control, and maintenance of supplier QA records that are not maintained by STPNOC.
Supplier-furnished records shall include:
- Documentation (e.g., certification) that identifies the purchased item and the specific procurement requirements (e.g., codes, standards, and specifications) met by the item.
- Documentation identifying any procurement requirements that have not been met.
- A description of those nonconformances from procurement requirements dispositioned "accept-as-is" or "repair".
5.2.1.9 Requirement for the supplier to submit a copy of its QA program description (does not apply for CGIs).
5.2.1.10 Requirements for the performance of maintenance and receipt inspection checks where applicable.
5.2.1.11 Applicability of 10CFR21 reporting requirements.
" The reporting requirements of 10CFR21 do not apply to vendors of CGIs to be dedicated for use by STPNOC.
- The reporting requirements of 10CFR21 do not apply to suppliers of commercial-grade calibration services.
5.2.2 When purchasing commercial-grade calibration services from calibration 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.
5.2.2.1 In such cases, accreditation may be accepted in lieu of imposing a QA Program consistent with 10CFR50, Appendix B, provided all of the following are met:
- The accreditation is to ANSI/ISO/IEC 17025
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Chapter OPERATIONS QUALITY ASSURANCE PLAN 7.0 13 PROCUREMENT PAGE 6 OF 13 EFFECTIVE DATE 02-01-12
- The accreditation body is either the National Voluntary Laboratory Accrediting Program (NVLAP) administered by 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).
" 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.
- 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.
- Purchase documents require reporting as-found calibration data when calibrated items are found to be out-of-tolerance.
- The alternative method is limited to the domestic calibration service suppliers.
" The alternative method is applicable to sub-suppliers of calibration service suppliers, provided the above conditions are met.
5.3 Bid Evaluation 5.3.1 Bid Evaluations shall be performed to evaluate adherence to technical and quality assurance requirements.
5.4 Supplier Selection
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Chapter OPERATIONS QUALITY ASSURANCE PLAN 7.0 13 PROCUREMENT PAGE 7 OF 13 EFFECTIVE DATE 02-01-12 5.4.1 Suppliers of items (for CGIs, when basis for dedication includes commercial grade survey) or services shall be required to submit copies of their QA program description for evaluation prior to the issuance of a purchase order or execution of a contract, and acceptability shall be documented. The process by which suppliers are judged as being a capable procurement source is described as follows:
5.4.1.1 Procurement source evaluation and selection involves Engineering, Quality, Contracts & Procurement, and STP plant personnel, as appropriate. These organizations participate in the qualification evaluation of suppliers in accordance with written procedures.
5.4.1.2 Measures for the evaluation and selection of procurement sources shall be specified in procedures and may vary depending upon the complexity and risk significance of the item or service. When procurement source evaluations are performed, the information to be considered shall include one or more of the following:
- Experience of users of identical or similar products of the prospective supplier, other utility or approved contractor audits/evaluations, audits/evaluations by cooperative utility groups, American Society of Mechanical Engineers (ASME) Certificates of Authorization, STP records accumulated in previous procurement actions, and STP product operating experience may be used in this evaluation. When other utility, contractor or cooperative utility audits/evaluations are used, the documentation will be obtained and reviewed. Supplier history shall reflect recent capability. Previous favorable experience with suppliers may be an adequate basis for judgments attesting to suppliers' capability.
- An evaluation of the suppliers' current quality records supported by documented qualitative and quantitative information which can be objectively evaluated. This may include review and evaluation of the suppliers' QA Program Manual, procedures, and responses to questionnaires, as appropriate.
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- A source evaluation of the suppliers' technical and quality capability as determined by a direct evaluation of facilities and personnel (audit, survey, or surveillance) and quality program implementation. Resolution or a commitment to resolve unacceptable technical or quality requirements identified by the bid evaluation or vendor evaluation shall be obtained prior to the award of a purchase order or contract.
5.4.1.3 Procurement source evaluations involve a review of technical and quality .considerations to an extent considered appropriate by each participant. Technical considerations include the design or manufacturing capability and technical ability of suppliers to produce or provide the design, service, item or component. Quality considerations include one of the previously stated methods of supplier evaluation and a consideration of a suppliers' current quality program or capabilities.
5.4.1.4 A documented quality assurance evaluation of a vendor's quality program shall be performed to assure it meets the appropriate requirements of 10CFR50 Appendix B, or where applicable, other nationally recognized codes and standards, or, for CGIs, to assure the program provides adequate control over established critical characteristics.
5.4.1.5 Vendors may be placed on the Approved Vendors List after passing this evaluation.
5.4.1.6 A vendor shall not be issued a purchase order or contract unless they have been accepted for placement on the Approved Vendors List or an exception has been approved by the Chief Nuclear Officer or the Manager, Quality.
5.4.1.7 Service organizations which will supply only manpower and no other service are not required to be on the Approved Vendors List or have an STP approved quality assurance program as long as the supplied personnel are trained and work under the auspices of the STP Operations Quality Assurance Plan.
5.4.2 Each vendor on the Approved Vendors List shall be periodically evaluated by Quality as provided by Reference 4.3 (i.e., annually for "Full" program, biennially for "Basic" program).
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Chapter OPERATIONS QUALITY ASSURANCE PLAN 7.0 13 PROCUREMENT PAGE 9 OF 13 EFFECTIVE DATE 02-01-12 5.4.2.1 A vendor may be removed from the Approved Vendors List if evaluation determines the vendor is unacceptable, the vendor requests removal or by direction of the Chief Nuclear Officer or the Manager, Quality. 0 5.4.3 Planning of verification activities to be employed for item or service acceptance shall begin during the purchase requisition or contract preparation and review stage. The extent of the verification activities will vary and be a function of the relative safety significance, complexity of the purchased item or service, and the supplier's past performance. The verification activities may include vendor surveillance, receipt inspection, or post-installation testing. Verification activities are planned to assure conformance to procurement document requirements. Procedures shall establish the organizational responsibilities for identifying required verifications and methods, performing and documenting the verification activities.
5.4.3.1 Verification activities shall be performed using plans developed in accordance with procedures with appropriate input from the cognizant technical organization. The plan shall specify the characteristics or processes to be witnessed, inspected or verified.
5.4.3.2 Specified source inspections may be waived by Chief Nuclear Officer or the Manager, Quality.
0 5.4.3.3 Vendor related reports shall be evaluated to determine the effectiveness of the vendor's quality assurance program.
5.5 Receiving Activities 5.5.1 Received purchased items shall be observed for shipping damage and the requirements of ANSI N45.2.2 Section 5.2.1. (This activity does not constitute an inspection and does not require qualification in accordance with Reference 4.5).
5.5.2 Receiving inspection shall be coordinated with verification activities. If source inspection is not performed or did not address all applicable attributes, receipt inspection shall be performed and shall include the applicable additional attributes listed in ANSI N45.2.2 Section 5.2.2, except for commercial grade items dedicated by survey which shall be receipt inspected as required by the procurement document.
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Chapter OPERATIONS QUALITY ASSURANCE PLAN 7.0 13 PROCUREMENT PAGE 10OF13 EFFECTIVE DATE 02-01-12 5.5.3 Receiving inspection checklists shall be developed using the requirements specified in the procurement documents and applicable attributes of ANSI N45.2.2.
5.5.4 Statistical sampling methods may be used for groups of similar items.
Sampling shall comply with nationally recognized methods or approved engineering alternates.
5.5.5 Receiving inspections shall be performed by personnel trained and qualified in accordance with Reference 4.5. Technical assistance shall be provided by Contracts & Procurement or Engineering as applicable.
5.5.6 Receiving inspection activities shall include:
5.5.6.1 Identifying materials, parts, and components and their status upon receipt by tagging or other acceptable means of identification, or segregating and controlling items in receiving hold areas separate from the storage facilities for acceptable items. Identification of items shall correspond to the identification required by procurement documents and be noted on receiving documentation.
5.5.6.2 Verification of items for acceptance includes correctness of identification and specified quality documentation.
5.5.6.3 Inspecting or testing using approved procedures and calibrated tools, gauges, and measuring equipment for verification acceptance of items, including off-the-shelf items.
5.5.6.4 Items determined to be acceptable for use shall be identified with an "accept" tag or other acceptable means of identification prior to release for storage or use.
5.5.6.5 Received items which do not conform to procurement documents are controlled and segregated (if practical) and processed in accordance with Reference 4.6.
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Chapter OPERATIONS QUALITY ASSURANCE PLAN 7.0 13 PROCUREMENT PAGE 11OF13 EFFECTIVE DATE 02-01-12 5.5.7 Acceptance by post-installation test may be utilized following one of the preceding verification methods. Post-installation testing may be used for acceptance verification when it is difficult to verify item quality characteristics, the item requires an integrated system checkout or test, or the item cannot demonstrate its ability to perform when not in use.
Engineering specifications shall be used for developing post-installation test instruction requirements and acceptance documentation. Post-installation testing is the responsibility of the Plant General Manager and is witnessed by Engineering or Quality personnel at specified hold points.
5.5.8 Acceptance of Procured Items and Services 5.5.8.1 Acceptance of items and services shall be based on one or more of the following:
Written certifications (Note: This shall not be the sole method of acceptance for items in the "Basic" program)
Surveillance/Audit of procured service Source verification Receiving inspection/testing Commercial Grade Item dedication Vendor surveillance Post-installation test 5.5.9 Documented evidence from the supplier that procured items meet procurement quality requirements, when required, such as codes, standards, or specifications will be maintained at the plant site. Such evidence shall be provided by the supplier, at the time of source or receipt inspection, for review and verification before acceptance. The documented evidence will be retrievable and available at the plant site prior to installation or use of the procured item, unless otherwise controlled in accordance with Reference 4.6.
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Chapter OPERATIONS QUALITY ASSURANCE PLAN 7.0 13 PROCUREMENT PAGE 12 OF 13 EFFECTIVE DATE 02-01-12 5.6 Vendor Surveys, Surveillance and Audit 5.6.1 For items in the Full Program, Suppliers Certificates of Conformance shall be periodically evaluated by audits, independent inspections, surveys, or tests to assure that they are valid and results are documented. When acceptance is based upon source inspection, documented evidence shall be furnished to the plant receiving organization.
5.6.1.1 Acceptance by source inspection may be considered when the item or service is vital to plant safety; or the quality characteristics are difficult to verify after receipt; or the item or service is complex in design, manufacture, inspection, or test.
Vendor surveillance/source inspection involves a physical presence to monitor, by observation, designated activities for the purpose of evaluating supplier performance and product acceptance (source inspection only).
5.6.2 The STP survey and audit program provide for periodic scheduled audits or surveys of suppliers, the site procurement program, contractors, subcontractors, and others performing work. The audit and survey schedule is prepared and updated by Quality. Frequency of these surveys and audits is based upon the safety, complexity, and quality requirements, and as a minimum shall be in compliance with Reference 4.3.
5.6.3 When purchasing commercial-grade calibration services from calibration laboratories accredited by a nationally-recognized accrediting body, the accreditation process and accrediting body may be credited with carrying out a portion of the STPNOC's duties of verifying acceptability and effective implementation of the calibration service supplier's quality assurance program.
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 STPNOC. This review shall include, at a minimum, verification of the following:
" The accreditation is to ANSI/ISO/IEC 17025
- The accrediting body is either NVLAP or A2LA. The A2LA accreditation is recognized by NVLAP through the ILAC MRA.
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Chapter OPERATIONS QUALITY ASSURANCE PLAN 7.0 13 PROCUREMENT PAGE 13 OF 13 EFFECTIVE DATE 02-01-12
- 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 NISTIR 6989.
- 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 the identification of the laboratory equipment/standards used.
- Purchase documents require reporting as-found calibration data when calibrated items are found to be out-of-tolerance.
- The alternative method is limited to the domestic calibration service suppliers.
- The alternative method is applicable to sub-suppliers of calibration service suppliers, provided the above conditions are met.
- STPNOC is responsible for ensuring that the procured services are within the accredited scope of the NVLAP and A2LA certificates.
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 4.7.
7.0 ATTACHMENTS 7.1 None
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV.
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Chapter 8 OPERATIONS QUALITY ASSURANCE PLAN 6 CONTROL AND ISSUANCE OF DOCUMENTS PAGE 1 OF 4 EFFECTIVE DATE 2-1-98 1.0 PURPOSE 1.1 The purpose of this chapter is to establish the requirements for review, approval, distribution and use of documents such as instructions, procedures and drawings, 00 including changes thereto for the South Texas Project (STP).
2.0 SCOPE 2.1 This chapter is applicable to documents, which control activities for the licensing, operation, testing, maintenance, and plant modification of the STP. These documents include, but are not limited to, instructions; procedures; specifications; drawings; vendor manuals; status registers (such as drawing lists, equipment list);
procurement documents; design documents; design change requests; as-built documents; non-conformance and deficiency reports; Updated Final Safety Analysis Report and program manuals (such as OQAP, Emergency Plan, Inservice Inspection Plan, etc.).
3.0 DEFINITIONS 3.1 None
4.0 REFERENCES
4.1 OQAP Chapter 6.0, Design and Modification Control 4.2 OQAP Chapter 14.0, Records Control 4.3 OQAP Chapter 2.0, Table I 5.0 REQUIREMENTS 5.1 Procedures shall be established which identify the organizations or individuals responsible for the preparation, review, approval, and issuance of documents and changes thereto.
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Chapter 8 OPERATIONS QUALITY ASSURANCE PLAN 6 CONTROL AND ISSUANCE OF DOCUMENTS PAGE 2 OF 4 EFFECTIVE DATE 2-1-98 5.2 Departments responsible for program-implementing documents shall be required to provide and assure the necessary review and approval, prior to use, for instructions, procedures, and drawings. Review and approval assures that issued documents include proper quality and technical requirements, and are correct for their intended use. Additionally, individual departments are responsible for controlling documents generated or reviewed in the department for which the department has preparation and final approval or external interface responsibility.
5.3 Document reviews shall be performed by appropriately qualified personnel with access to pertinent background information to establish a basis for an adequate review. The Quality organization shall review selected documents for quality requirements.
5.4 Procedures shall establish controlled distribution of documents and changes thereto including:
5.4.1 Establishing current and updated distribution lists 5.4.2 Personnel or organizations acknowledging receipt and insertion of controlled. documents and changes thereto 5.4.3 Controlling documents to avoid the use of outdated or inappropriate documents 5.4.4 Establishing and maintaining master document lists identifying the current revision of documents 5.4.5 Temporary changes 5.5 Documents shall be available and used at work locations by individuals or organizations performing activities when required based upon the nature of the work. Clearly identified controlled copies of documents shall be available at the point of use prior to commencing activities.
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OPERATIONS QUALITY ASSURANCE PLAN 6 CONTROL AND ISSUANCE OF DOCUMENTS PAGE 3 OF 4 EFFECTIVE DATE 2-1-98 5.6 Revisions or changes to documents shall be reviewed and approved by the same organizations that performed the original review and approval unless other organizations are designated and have knowledge of the requirements and intent of the original document. Personnel using a document to perform activities are responsible for assuring the documents being used are the correct revision prior to such use.
5.7 Safety-related procedures shall be maintained in an accurate and usable condition.
Changes to safety-related procedures shall be made as necessary. The root cause of significant deficiencies regarding safety-related procedures shall be identified and corrected. The following activities provide ongoing confirmation of this.
5.7.1 Applicable plant procedures shall be reviewed following an unusual incident such as an accident, an unexpected transient, significant operator error, or equipment malfunction and following any modification to a system.
5.7.2 Non-routine procedures (procedures such as emergency operation procedures, off-normal procedures which implement the Emergency Plan, and other procedures whose usage may be dictated by an event) shall be reviewed at least every two years and revised as appropriate.
5.7.3 At least every two years, quality assurance audits and other independent oversight activities shall review a representative sample of the routine plant procedures that are used more frequently than every two years.
These reviews shall ensure the acceptability of the procedures and verify that the procedure review and revision program is being implemented effectively. The root cause of significant deficiencies shall be determined and corrected.
5.7.4 Routine plant procedures that have not been used for two years shall be reviewed before use to determine if changes are necessary or desirable.
5.8 Procedures shall be developed for the control and distribution of vendor/contractor documents such as approved drawings, specifications, technical manuals and instructions.
5.9 Control of design documents is addressed in Reference 4.1.
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Chapter 8 OPERATIONS QUALITY ASSURANCE PLAN 6 CONTROL AND ISSUANCE OF DOCUMENTS PAGE 4 OF 4 EFFECTIVE DATE 2-1-98 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 4.2.
7.0 ATTACHMENTS 7.1 None
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Chapter OPERATIONS QUALITY ASSURANCE PLAN 9.0 6 CONTROL OF MATERIAL PAGE 1 OF 4 EFFECTIVE DATE 2-1-98 1.0 PURPOSE 1.1 The purpose of this chapter is to describe requirements and assign responsibility 00 c--
for control of material at the South Texas Project (STP).
2.0 SCOPE 2.1 This chapter applies to identification, control and traceability of material, parts and components (luring receipt, storage, handling, issuance, installation and shipping activities.
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 14.0, Records Control 4.5 STP UFSAR Table 3.12-1 5.0 REQUIREMENTS 5.1 Material, equipment, and components shall be handled, stored, shipped, cleaned, and preserved to assure that the quality of items is maintained from fabrication through installation.
5.2 Identification and Traceability Requirements
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Chapter OPERATIONS QUALITY ASSURANCE PLAN 9.0 6 CONTROL OF MATERIAL PAGE 2 OF 4 EFFECTIVE DATE 2-1-98 5.2.1 Physical identification of material (including consumables), parts and components shall be used whenever possible or practical and identification shall be traceable to the appropriate documentation such as drawings, specifications, purchase orders, manufacturing and inspection documents, deviation reports, and physical and chemical test reports.
5.2.2 Identification marking requirements include:
5.2.2.1 Where physical identification marking is used, the marking shall be clear, unambiguous and indelible and shall be applied in such a manner as not to affect the function of the item.
5.2.2.2 Markings shall be transferred to each part of an item whenever possible or practical when subdivided and shall not be hidden or obliterated by surface treatment or coatings unless other means of identification are substituted (e.g., color-coding).
5.2.2.3 Procedures shall specify that identification be maintained, either on the item or on records traceable to the item, and verified as required throughout fabrication, erection, installation, and use of the item. The identification must be verified and documented prior to release for fabrication, erection, installation and/or use of the item.
5.3 Material Storage 5.3.1 Measures shall be established for the control of items in storage which include: storage location, storage levels, procedures which require periodic surveillance of stored items to verify specific protective environmental requirements, inspection results, item care and protective measures, personnel access to storage areas, and material issues.
Control of items in storage shall comply with Reference 4.1. Storage conditions commensurate with the safety classification of the materials will be maintained.
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OPERATIONS QUALITY ASSURANCE PLAN 9.0 6 CONTROL OF MATERIAL PAGE 3 OF 4 EFFECTIVE DATE 2-1-98 5.3.2 Procedures shall be developed for storage of chemicals, reagents, lubricants, and other consumable materials, which will be used in conjunction with systems. Items having limited shelf or operating life shall be identified and controlled to preclude the use of expired items.
5.4 Material Handling 5.4.1 Measures shall be developed for handling of items which, because of weight, size, susceptibility to shock damage or other conditions, require special handling.
5.4.2 Measures shall be established to rate and inspect hoisting and handling equipment in accordance with Reference 4.1.
5.5 Shipping 5.5.1 Measures shall be established for the packaging, loading and transportation of items in accordance with Reference 4.1.
5.6 Housekeeping 5.6.1 Measures shall be established for housekeeping activities in the storage areas, which include: zone designation, environment control, work area cleanliness, fire protection, inspection, and surveillance. These measures shall meet the applicable requirements of Reference 4.5.
5.7 Personnel performing handling, preservation, storage, cleaning, packaging, shipping, and inspection to the requirements of this chapter shall be trained and qualified per Reference 4.2.
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 4.4.
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Chapter OPERATIONS QUALITY ASSURANCE PLAN 9.0 6 CONTROL OF MATERIAL PAGE 4 OF 4 EFFECTIVE DATE 2-1-98 7.0 ATTACHMENTS 7.1 None
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Chapter OPERATIONS QUALITY ASSURANCE PLAN 10.0 11 TNSPECTION PAGE 1 OF 5 EFFECTIVE DATE 02-01-08 1.0 PURPOSE 1.1 The purpose of this chapter is to prescribe the requirements and the responsibilities for inspection of activities and structures, systems, and components at the South Texas Project (STP).
2.0 SCOPE 2.1 This chapter is applicable to inspection activities associated with activities and c' systems, structures and components to demonstrate compliance with design and operational requirements.
3.0 DEFINITIONS 3.1 None
4.0 REFERENCES
4.1 OQAP Chapter 4.0, Qualification, Training and Certification of Personnel 4.2 OQAP Chapter 12.0, Instrument and Calibration Control 4.3 OQAP Chapter 14.0, Records Control 4.4 OQAP Chapter 2.0, Table I 5.0 REQUIREMENTS 5.1 Inspection 5.1.1 Inspections shall be performed in accordance with written and approved procedures. The inspection criteria established for performing inspections and the detail of the inspection process shall be determined based on the complexity of the activity and possible safety impact to the plant.
Qualification of individuals performing inspections shall be in accordance with Reference 4.1 and 4.4. These individuals shall be other than those who performed or directly supervised the activity being inspected.
Inspection requirements may be included as a part of the document controlling the activity, or a separate inspection procedure prepared to specify, as appropriate, the inspection performance requirements as noted below.
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Chapter OPERATIONS QUALITY ASSURANCE PLAN 10.0 11 INSPECTION PAGE 2 OF 5 EFFECTIVE DATE 02-01-08 5.1.1.1 Identification of characteristics and activities to be inspected 5.1.1.2 Acceptance and rejection criteria 5.1.1.3 Inspection process utilized 5.1.1.4 Identification of procedures, drawings, specifications, and revisions utilized 5.1.1.5 Specification of the necessary measuring and test equipment including accuracy and calibration due dates as applicable 5.1.2 For "Full" program implementation, when inspections associated with normal operations of the plant are performed by individuals other than those who performed or directly supervised the work, but are within the same group, the following additional controls apply:
5.1.2.1 The quality of work can be demonstrated through a functional test when the activity involves breaching a pressure-retaining item; and 5.1.2.2 The qualification criteria for inspection personnel are reviewed and found acceptable by the Quality organization prior to initiating the inspection.
5.1.3 For "Basic" program implementation, with the exception of receipt inspection, personnel may perform inspections, examinations and tests provided:
5.1.3.1 They are experienced, task qualified journeymen, or supervisors, who did not perform or directly supervise the activity being inspected, examined or tested, and 5.1.3.2 These individuals shall also receive training to the applicable inspection procedure, processes, methods in accordance with a Quality approved training program; and 5.1.3.3 Quality will provide periodic oversight of the inspection activities.
5.1.4 Examples of the activities subject to inspection include:
5.1.4.1 Special processes
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Chapter OPERATIONS QUALITY ASSURANCE PLAN 10.0 11 INSPECTION PAGE 3 OF 5 EFFECTIVE DATE 02-01-08 5.1.4.2 Modifications 5.1.4.3 Receipt of materials, parts and components 5.1.4.4 Maintenance 5.1.4.5 Packaging, shipping and handling of radioactive waste material 5.1.5 Process Monitoring 5.1.5.1 Process monitoring of work activities, equipment, and personnel shall be utilized as a control method when direct inspection of processed items is impossible or impracticable.
Monitoring shall be performed to verify that activities are performed in accordance with documented instructions, procedures, drawings, and specifications.
5.1.6 Supporting Inspections 5.1.6.1 Both inspections and process monitoring shall be used when control of the activity is inadequate without both. The need for such monitoring shall be determined prior to initiation of the activity, if possible, or may be stipulated later if circumstances warrant.
5.1.7 Mandatory Inspections 5.1.7.1 Mandatory inspection holdpoints are established by the organization performing the work, Quality or Engineering personnel. Witnessing or inspection of hold points by Engineering or Quality personnel shall be accomplished before work can proceed. Plant procedures and work instructions shall be reviewed by Engineering and/or Quality personnel for concurrence with the established mandatory hold points.
5.1.7.2 Engineering and/or Quality personnel also establish notification points for the purpose of being informed of upcoming activities (e.g., prior to the start of a test) where a mandatory holdpoint may not be appropriate, but Engineering and/or Quality personnel involvement may be desired.
5.1.8 Inspection results shall be reviewed and approved by qualified personnel to verify that the inspection requirements were satisfied.
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OPERATIONS QUALITY ASSURANCE PLAN 10.0 11 INSPECTION PAGE 4 OF 5 EFFECTIVE DATE 02-01-08 5.1.9 Inspection activities shall be documented and as a minimum, shall identify the following:
5.1.9.1 Item inspected 5.1.9.2 Date of inspection 5.1.9.3 Inspector 5.1.9.4 Type of observation/inspection 5.1.9.5 Results and acceptability 5.1.9.6 Reference to information on action taken in connection with nonconformances 5.1.9.7 Test equipment used 5.1.10 Inspection requirements for modifications, repairs, and replacements shall be equivalent to the inspection requirements of the original design or approved alternatives.
5.1.11 Procedures shall be reviewed by personnel sufficiently knowledgeable in the requirements of the activity to ensure that the necessary hold points are designated.
5.1.12 Measuring and test equipment utilized as part of the inspection process shall be controlled by the requirements of Reference 4.2.
5.1.13 Acceptance 5.1.13.1 Procedures shall be established for processing, evaluation, and final acceptance of inspection data. The qualified inspector performing the inspection is responsible for the immediate evaluation and acceptability of inspection results. Designated individuals or groups are responsible for reviewing and evaluating inspection results including recording of data, computations, drawings, or specification interpretations.
5.2 Nondestructive Examination (NDE) 5.2.1 NDE shall be performed in accordance with procedures which address the applicable requirements of ASME, ASTM, or other appropriate codes and standards.
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OPERATIONS QUALITY ASSURANCE PLAN 10.0 11 INSPECTION PAGE 5 OF 5 EFFECTIVE DATE 02-01-08 5.2.2 The applicable requirements of Section 5.1 shall apply to the performance, evaluation, and documentation of NDE results.
5.3 Inspection Status 5.3.1 The status of individual item inspections shall be identifiable through the use of stamps, tags, labels, routing cards or documentation traceable to the item.
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 4.3.
7.0 ATTACHMENTS 7.1 None
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OPERATIONS QUALITY ASSURANCE PLAN 11.0 8 TES'T CONTROL PAGE 1 OF 4 EFFECTIVE DATE 2-01-08 1.0 PURPOSE 1.1 The purpose of this chapter is to establish requirements for testing of structures, systems, and components at the South Texas Project (STP).
2.0 SCOPE 2.1 This chapter is applicable to the testing of structures, systems, and components during the operational phases to demonstrate compliance with design and operational requirements.
3.0 DEFINITIONS 3.1 None
4.0 REFERENCES
4.1 South Texas Project Electric Generating Station (STP) Technical Specifications 4.2 OQAP Chapter 4.0, Qualification, Training and Certification of Personnel 4.3 OQAP Chapter 1:2.0, Instrument and Calibration Control 4.4 OQAP Chapter 1.4.0, Records Control 4.5 OQAP Chapter 2.0, Table I 5.0 REQUIREMENTS 5.1 The test programs shall be developed to demonstrate that plant structures, systems, and components will perform in accordance with design requirements.
5.1.1 Tests performed following maintenance or modification shall satisfy the original design or test requirements or an engineering approved alternative.
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Chapter OPERATIONS QUALITY ASSURANCE PLAN 11.0 8 TEST CONTROL PAGE 2 OF 4 EFFECTIVE DATE 2-01-08 5.1.2 Test programs include operability tests, surveillance tests, and equipment tests, including those associated with plant maintenance, modification, procedure changes, and the acceptance of purchased material.
5.2 Procedures shall be developed to control tests of structures, systems, and components to assure satisfactory service upon completion of maintenance or modifications.
5.3 Procedures shall be developed to schedule and control surveillance testing of those items and systems required by Reference 4.1.
5.4 Test procedures shall provide, as necessary, for the following:
5.4.1 The requirements and acceptance limits contained in applicable licensing, design and procurement documents.
5.4.2 Instructions for performing the test, including prerequisites, test sequence, and caution or safety notes, and shall be in sufficient detail so that the test operator's interpretation is not required.
5.4.3 Calibrated test equipment with the accuracy required for performing the activity.
5.4.4 Provisions for documenting or recording test data and results 5.4.5 Acceptance criteria.
5.4.6 Inspection hold and/or notification points for inspection/witness by Engineering or Quality.
5.4.7 Provisions for assuring the test prerequisites have been met.
5.4.8 Provisions for control of jumpers, lifted leads, blank flanges, strainers or safety tags, etc.
5.4.9 Provisions for returning a system to normal configuration upon completion of the test.
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OPERATIONS QUALITY ASSURANCE PLAN 11.0 8 TEST CONTROL PAGE 3 OF 4 EFFECTIVE DATE 2-01-08 5.4.10 Environmental conditions shall be noted in test procedures, as appropriate.
5.5 Measuring and Test equipment (M&TE) used during test activities shall be controlled in accordance with Reference 4.3.
5.6 Procedures shall be developed to ensure that test data and results are reviewed by a qualified individual(s) and are evaluated for compliance with applicable test acceptance criteria.
5.7 Personnel performing test activities, including developing and implementing test procedures and evaluating and reporting test results, shall be qualified in accordance with Reference 4.2.
5.8 Administrative procedures shall provide for identification of structure, system, and component test status through the use of status indicators (e.g., clearance tags, markings, records) to assure only items that have passed required tests are used or operated.
5.9 Test records, where applicable, shall include:
5.9.1 Identification of items or systems tested.
5.9.2 Date of test.
5.9.3 Tester and data recorder identification.
5.9.4 Type of observation/test.
5.9.5 Test results and acceptability.
5.9.6 References to nonconformance and corrective action.
5.9.7 Person reviewing and evaluating test results.
5.9.8 Test equipment used.
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Chapter OPERATIONS QUALITY ASSURANCE PLAN 11.0 8 TEST CONTROL PAGE 4 OF 4 EFFECTIVE DATE 2-01-08 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 4.4.
7.0 ATTACHMENTS 7.1 None
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Chapter OPERATIONS QUALITY ASSURANCE PLAN 12.0 6 INSTRUMENT AND CALIBRATION CONTROL PAGE 1 OF 3 EFFECTIVE DATE 2-1-98 1.0 PURPOSE 1.1 The purpose of this chapter is to establish requirements to ensure measuring and test equipment (M\I&TE), and installed instrument and control devices used in activities or structures, systems and components are properly controlled, 00 maintained, and calibrated at the South Texas Project (STP).
2.0 SCOPE 2.1 This chapter is applicable to equipment used to measure, test, evaluate, and inspect items and systems during operational phases and to installed instrument and control devices used to measure, record, and control plant operations.
3.0 DEFINITIONS 3.1 None
4.0 REFERENCES
4.1 OQAP Chapter 4.0, Qualification, Training and Certification of Personnel 4.2 OQAP Chapter 14.0, Records Control 4.3 OQAP Chapter 2.0, Table I 5.0 REQUIREMENTS 5.1 Procedures shall be developed to establish the method and interval of calibration for installed instrument and control devices. The calibration method and interval shall be based on the type of equipment, stability, and reliability characteristics, required accuracies and other conditions affecting calibration.
5.2 Procedures shall be developed for the control and calibration of measuring and test equipment at prescribed intervals or prior to use. Reference standards having known valid relationships to national standards shall be used. Each organization shall be responsible for assuring that the measuring and test equipment (MTE) it uses has been calibrated to the accuracy required for its intended use.
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Chapter OPERATIONS QUALITY ASSURANCE PLAN 12.0 6 INSTRUMENT AND CALIBRATION CONTROL PAGE 2 OF 3 EFFECTIVE DATE 2-1-98 5.3 Reference standards shall have an uncertainty (error) requirement of no more than 1/4 of the tolerance of the equipment or device being calibrated. When commercial standards with the required uncertainty error are not available; a reference standard may be used if the standard error tolerance is equal to or less than the error tolerance of the equipment being calibrated. The basis of this acceptance shall be documented and authorized by responsible management. In those cases where a reference standard is not traceable to a national standard because a national standard does not exist, the basis for calibration shall be documented.
5.4 Measuring and test equipment shall be uniquely identified. The records directly traceable to the equipment shall indicate the date of calibration, the identity of the person who calibrated the equipment, the results of the calibration and the next calibration due date.
5.4.1 A calibration label will be attached to measuring and test equipment to indicate the calibration due date. If this label interferes with the equipment function or is impractical, the calibration label will be attached to the equipment case.
5.5 Measures shall be established to trace the use of each item of measuring and test equipment. When measuring and test equipment or installed instrument and control devices are found out of calibration, an evaluation shall be made and documented for the validity of previous inspection and test results and for the acceptability of items previously inspected or tested.
5.6 Measuring and test equipment, installed instruments and control devices suspected or known to be in error or defective shall be immediately removed from service or properly tagged to indicate the error or defect.
5.7 Measuring and test equipment, installed instruments and control devices consistently found to be out of calibration shall be repaired or replaced.
5.8 Measuring and test equipment shall be handled and stored commensurate with their environmental and sensitivity requirements.
5.9 Measuring and test equipment, which becomes lost, shall be considered out of tolerance and upon its recovery, it shall be recalibrated.
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Chapter OPERATIONS QUALITY ASSURANCE PLAN 12.0 6 INSTRUMENT AND CALIBRATION CONTROL PAGE 3 OF 3 EFFECTIVE DATE 2-1-98 5.10 Personnel calibrating measuring and test equipment and installed instrument and control devices shall be qualified per Reference 4.1.
5.11 Contractors and vendors, who provide their own measuring and test equipment, shall have a program that meets the requirements of this chapter.
5.12 This chapter does, not require the calibration and control of rulers, tape measures, levels and other such devices if normal commercial practices provide adequate accuracy.
5.13 Inspection, test, maintenance, repair, and other procedures shall include provisions to assure that M&TE used in activities affecting quality are the proper range, type and accuracy.
5.14 Measuring and test equipment, utilized for chemical and radiological control purposes are not required to meet the requirements of this chapter, provided laboratory control practices are implemented to ensure accuracy of analyses.
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 4.2.
7.0 ATTACHMENTS 7.1 None
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Chapter OPERATIONS QUALITY ASSURANCE PLAN 13.0 14 Control of Conditions Adverse to Quality PAGE 1 OF 4 EFFECTIVE DATE 02-01-12 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 at the South Texas Project (STP).
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 C?
4.0 REFERENCES
4.1 10CFR50, Appendix B 4.2 10CFR21, 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 00 4.5 STP Technical Specifications 4.6 OQAP Chapter 14.0, Records Control 0
4.7 OQAP Chapter 2.0, Table I 4.8 NRC Regulatory Issue Summary 2005-20 oo 4.9 STP Reporting Manual 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.
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OPERATIONS QUALITY ASSURANCE PLAN 13.0 14 Control of Conditions Adverse to Quality PAGE 2 OF 4 EFFECTIVE DATE 02-01-12 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:
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 arid/or verification of the corrective action by the Quality organization, as appropriate.
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Chapter OPERATIONS QUALITY ASSURANCE PLAN 13.0 14 Control of Conditions Adverse to Quality PAGE 3 OF 4 EFFECTIVE DATE 02-01-12 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.
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 and functionality.
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.
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OPERATIONS QUALITY ASSURANCE PLAN 13.0 14 Control of Conditions Adverse to Quality PAGE 4 OF 4 EFFECTIVE DATE 02-01-12 5.6 The authority to stop work has been assigned to Chief Nuclear Officer or Manager, Quality for any activity being performed by company personnel or contractors which do not conform to established requirements.
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
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Chapter OPERATIONS QUALITY ASSURANCE PLAN 14.0 8 RECORDS CONTROL PAGE 1 OF 6 EFFECTIVE DATE 02-01-06 1.0 PURPOSE 1.1 The purpose of this chapter is to describe the requirements and the responsibilities for the collection., storage, retrieval, and maintenance of records.
2.0 SCOPE 2.1 This chapter is applicable to those records acquired and developed as a result of, 00 or in support of, the South Texas Project (STP).
01 3.0 DEFINITIONS 3.1 None
4.0 REFERENCES
4.1 OQAP Chapter 2.0, Table I 4.2 ST-HL-AE-2722, Request for Optical Disc Storage of Plant Records dated July 15, 1988 4.3 ST-AE-HL-91757, Optical Disc Storage of Plant Records for the South Texas Project, Units 1 and 2 dated August 29, 1988 4.4 NRC Regulatory Issue Summary 2000-18, Guidance on Managing Quality Assurance Records in Electronic Media dated October 23, 2000 5.0 REQUIREMENTS 5.1 Records shall be collected, filed, stored, maintained, and dispositioned.
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Chapter OPERATIONS QUALITY ASSURANCE PLAN 14.0 8 RECORDS CONTROL PAGE 2 OF 6 EFFECTIVE DATE 02-01-06 5.1.1 Records include, but are not limited to: plant history; operating logs; records of principal maintenance and modification activities; reportable occurrences and other records required by the Technical Specifications; results, of:reviews, inspections, tests, audits, and material analyses; monitoring of work performance; qualification of personnel, procedures, and equipment; drawings, specifications, procurement documents, warehousing documents, calibration procedures and calibration reports; and nonconformance and corrective action reports.
5.1.1.1 The records control program provides evidence that activities affecting quality are defined and implemented, and that inspection and test documents contain a description of the type of observation; the identification of inspector or data recorder; the date and inspection or test results; acceptability of the results; and reference any action taken in documenting or resolving any nonconformances.
5,2 Record storage facilities shall meet the requirements of Reference 4.1.
5.3 A list of record types and the classification of these record types as to retention period shall be maintained.
5A4 An index of stored records shall be maintained. The index shall include retention period and location of the records within the storage area. The STP DTL (an electronic database) is used as a record index/checklist. If a conflict of retention times exists between regulatory, standard, technical specification requirements, or the technical requirements manual, the longer retention period shall be specified.
5.5 Records indexing systems shall provide sufficient cross-reference between the record and items or activities to which the record applies.
5.6 The receipt, processing, and handling of records shall be controlled by procedures.
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Chapter OPERATIONS QUALITY ASSURANCE PLAN 14.0 8 RECORDS CONTROL PAGE 3 OF 6 EFFECTIVE DATE 02-01-06 5.7 To ensure that records are identifiable and retrievable, a computerized records management system has been developed. This system provides for a method to identify the document(s)/record(s) or document/ record package(s) for retrieval purposes. The system also provides the ability to cross-reference the identification with other possible identifiers of the document (i.e., specification number, purchase order number, equipment number). Records may be stored on photographic, optical, or electronic media; the file locations of documents are available from the computer.
5.8 Controlled access to the record storage facility shall be established.
5.9 Records may be corrected/supplemented in accordance with procedures, which provide for appropriate review or approval by the originating or other authorized organization. Corrections/supplements shall include the date and identification of the person making the correction/supplement, and 5.9.1 For hard copy (i.e. paper) originals, shall be in ink and be entered in a manner such that the original information is not obliterated, or 5.9.2 For originals in an electronic format, shall be annotated in a manner such that the correction/supplement is easily identified as a correction or supplement and the original information is not obliterated.
5.10 Organizations generating records are responsible for ensuring activities are documented accurately, legibly, and with sufficient traceability; and submitting designated documents for independent review prior to entering into the records system in accordance with appropriate procedures.
5.11 Record Retention 5.11.1 In addition to the applicable record retention requirements of Title 10, Code of Federal Regulations, the following records shall be retained for at least the minimum period indicated.
5.11.2 The following records shall be retained for at least 5 years:
5.11.2.1 Records and logs of unit operation covering time interval at each power level;
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Chapter OPERATIONS QUALITY ASSURANCE PLAN 14.0 8 RECORDS CONTROL PAGE 4 OF 6 EFFECTIVE DATE 02-01-06 5.11.2.2 Records and logs of principal maintenance activities, inspections, repair, and replacement of principal items of equipment related to nuclear safety; 5.11.2.3 All REPORTABLE EVENTS; 5.11.2.4 Records of surveillance activities, inspections, and calibrations required by the Technical Specifications; 5.11.2.5 Records of changes made to the procedures required by Technical Specification 6.8 and Technical Requirements Manual 6.8; 5.11.2.6 Records of sealed source and fission detector leak tests and results; and 5.11.2.7 Records of annual physical inventory of all sealed source material of record.
5.11.3 The following records shall be retained for the duration of the unit Operating License:
5.11.3.1 Records and drawing changes reflecting unit design modifications made to systems and equipment described in the Final Safety Analysis Report; 5.11.3.2 Records of new and irradiated fuel inventory, fuel transfers, and assembly burnup histories; 5.11.3.3 Records of doses received by all individuals for whom monitoring was required; 5.11.3.4 Records of gaseous and liquid radioactive material released to the environs; 5.11.3.5 Records of transient or operational cycles for those unit components identified in the Updated Final Safety Analysis Report;
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Chapter OPERATIONS QUALITY ASSURANCE PLAN 14.0 8 RECORDS CONTROL PAGE 5 OF 6 EFFECTIVE DATE 02-01-06 5.11.3.6 Records of reactor tests and experiments; 5.11.3.7 Records of training and qualification for current members of the unit staff; 5.11.3.8 Records of inservice inspections performed pursuant to the Technical Specifications; 5.11.3.9 Records of quality assurance activities required by the Operations Quality Assurance Plan; 5.11.3.10 Records of reviews performed for changes made to procedures or equipment or reviews of tests and experiments pursuant to 10CFR50.59; 5.11.3.11 Records of meetings of the PORC; 5.11.3.12 Records of organizational unit independent reviews; 5.11.3.13 Records of secondary water sampling and water quality; 5.11.3.14 Records of analyses required by the Radiological Environmental Monitoring Program that would permit evaluation of the accuracy of the analysis at a later date. This should include procedures effective at specified times and QA records showing that these procedures were followed; 5.11.3.15 Records of reviews performed for changes made to the OFFSITE DOSE CALCULATION MANUAL and the PROCESS CONTROL PROGRAM; and 5.11.3.16 Records of radioactive shipments.
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 this chapter.
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OPERATIONS QUALITY ASSURANCE PLAN 14.0 8 RECORDS CONTROL PAGE 6 OF 6 EFFECTIVE DATE 02-01-06 7.0 ATTACHMENTS 7.1 None
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OPERATIONS QUALITY ASSURANCE PLAN 20.0 0 DRY CASK STORAGE SYSTEM and INDEPENDENT SPENT FUEL STORAGE INSTALLATION PAGE 1 OF 16 EFFECTIVE DATE 8-9-12 1.0 PURPOSE 1.1 The purpose of this chapter is to supplement the basic policies established and documented as stated in the previously approved 10CFR50, Appendix B Operations Quality Assurance Plan (OQAP) to include specific requirements applicable to the design, construction, and operation of the Independent Spent Fuel Storage Installation (ISFSI) and Dry Cask Storage System (DCSS) at the South Texas Project (STP).
1.2 The objective of this chapter is to maintain administrative control over activities relative to the important to safety structures, systems, equipment, arid components regulated by 10 CFR Part 72.
2.0 SCOPE 2.1 The policies and procedures identified within this chapter regarding the ISFSI will form the basis for plant-life operation of the STP ISFSI.
The responsibility and authority for the establishment and execution of the ISFSI Quality Plan for the operation of the STP ISFSI will be retained by STP Nuclear Operating Company (STPNOC) and described in tfhe OQAP.
2.2 This program is designed to meet the requirements of 10 CFR Part 72, Subpart G for a quality assurance program for the classification and 61.55 and characterization of radioactive waste under 10 CFR Parts 61.56.
3.0 DEFINITIONS 3.1 Important to Safety (ITS) Structures, Systems, and Components (SSCs) - those features of the ISFSI whose functions are:
3.1.1 to maintain the conditions required to store spent fuel safely; 3.1.2 to prevent damage to the spent fuel container during handling and storage; and
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OPERATIONS QUALITY ASSURANCE PLAN 20.0 0 DRY CASK STORAGE SYSTEM and INDEPENDENT SPENT FUEL STORAGE INSTALLATION PAGE 2 OF 16 EFFECTIVE DATE 8-9-12 3.1.3 to provide reasonable assurance that spent fuel can be received, handled, packaged, stored, and retrieved without undue risk to the health and safety of the public.
3.2 Dry Cask Storage Quality Categories - Regulatory Guide 7.10 presents a method of classification of various components in transportation packaging (10CFR71) and dry cask storage systems (10CFR72). Each component is first identified as either Important to Safety (ITS) or Not Important to Safety" (NITS). Then, components that are considered ITS are further categorized into one of three classification categories (A, B, or C), depending on that component's importance to safety.
3.3 Category A, Category B, and Category C - as described below:
Classification Importance to Description Category Safety A Critical to Safe Category'A items include structures, components, Operation and systems whose failure could directly result in a condition adversely affecting public health and safety. The failure of a single item could cause loss of primary containment leading to release of radioactive material, loss of shielding, or unsafe geometry compromising criticality control.
B Major Impact Category B items include structures, components, on Safety and systems whose failure or malfunction could indirectly result in a condition adversely affecting public health and safety. The failure of a Category B item, in conjunction with the failure of an additional item, could result in an unsafe condition.
C Minor Impact Category C items include structures, components, on Safety and systems whose failure or malfunction would not significantly reduce the packaging effectiveness and would not be likely to create a situation adversely affecting public health and safety.
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OPERATIONS QUALITY ASSURANCE PLAN 20.0 0 DRY CASK STORAGE SYSTEM and INDEPENDENT SPENT FUEL STORAGE INSTALLATION PAGE 3 OF 16 EFFECTIVE DATE 8-9-12 3.4 Basic, or Fundamental, Safety Criteria - the following are considered to be the basic nuclear safety criteria for design of the ISFSI (NUREG-1567):
3.4.1 Maintain sub-criticality, 3.4.2 Prevent release of radioactive material above acceptable amounts, 3.4.3 Ensure radiation rates and doses do not exceed acceptable levels, 3.4.4 Maintain retrievability of the stored radioactive materials.
3.5 Certificate of Compliance (C of C) - the certificate issued by the Commission that approves the design of a spent fuel storage cask in accordance with the provisions of 10CFR72, Subpart L.
4.0 REFERENCES
4.1 10CFR72, Licensing Requirements For The Independent Storage of Spent Nuclear Fuel And High-Level Radioactive Waste, and Reactor Related Greater Than Class C Waste - Subpart G, Quality Assurance.
4.2 ASME B&PV Code, Sections III, V, and IX (as required by DCSS Certificate of Compliance/FSAR) 4.3 Regulatory Guide 7.10, Establishing Quality Assurance Programs for Packaging used in Transport of Radioactive Material 4.4 10CFR50.55a, Codes and Standards 4.5 10CFR20, Appendix G. 00 4.6 10CFR72.48, Changes, Tests and Experiments 4.7 SNT-TC-1A, American Society for Nondestructive Testing; Recommended Practice
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OPERATIONS QUALITY ASSURANCE PLAN 20.0 0 DRY CASK STORAGE SYSTEM and INDEPENDENT SPENT FUEL STORAGE INSTALLATION PAGE 4 OF 16 EFFECTIVE DATE 8-9-12 4.8 ANSI/ASNT CP-189, ANST Standard for Qualification and Certification of Nondestructive Testing Personnel 4.9 NUREG/CR-6407, Classification of TransportationPackaging and Dry Spent Fuel Storage System Components According to Importance to Safety 4.10 NOC-AE-12002873, Independent Spent Fuel Storage Installation (STI
- 33563580) 4.11 NUREG 1567, Standard Review Plan for Spent Fuel Dry Storage Facilities 5.0 REQUIREMENTS 5.1 DCSS/ISFSI Organization 5.1.1 The responsibility for implementing quality program requirements for activities associated with the ISFSI and DCSS is described in the OQAP Chapter 1.0, Organization.
5.2 DCSS/ISFSI Quality Program 5.2.1 The requirements described in the OQAP Chapter 2.0, Program Description apply to all DCSS and ISFSI construction and operation activity and as specified below.
5.2.2 The determination of the ISFSI and dry storage and transport systems, structures, and components important to safety is in accordance with 10CFR71 Subpart H and 10CFR72 Subpart G, and includes those:
5.2.2.1 Which comprise or are necessary to maintain the conditions required to store spent fuel or high-level radioactive waste safely,
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OPERATIONS QUALITY ASSURANCE PLAN 20.0 0 DRY CASK STORAGE SYSTEM and INDEPENDENT SPENT FUEL STORAGE INSTALLATION PAGE 5 OF 16 EFFECTIVE DATE 8-9-12 5.2.2.2 Which are necessary to prevent damage to the spent fuel or the high-level radioactive waste container during handling, storage, or transport, or 5.2.2.3 Which comprise or are necessary to provide reasonable assurance that spent fuel can be received, handled, packaged, stored, and retrieved without undue risk to the health and safety of the public.
5.2.3 Quality assurance requirements apply to design, purchase, fabrication, handling, shipping, storing, cleaning, assembly, inspection, testing, operation, maintenance, repair, modification of structures, systems, and components, and decommissioning activities that are important to safety as defined by the DCSS Certificate of Compliance (C of C) and the DCSS Final Safety Analysis Report (FSAR).
5.2.4 The OQAP will provide the required control over activities affecting the quality of the identified structures, systems, and. components to an extent commensurate with the importance to safety and, as necessary, to ensure conformance with the approved design of the ISFSI and DCSS.
5.2.5 STP will ensure that activities affecting quality are accomplished under suitably controlled conditions which include the use of appropriate equipment; suitable environmental conditions for accomplishing the activity, and assurance that pre-requisites for a given activity have been satisfied.
5.2.6 The need for special controls, processes, test equipment, tools and skills will be evaluated and resources will be provided to attain the required quality and the need for verification of quality by inspection and test.
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OPERATIONS QUALITY ASSURANCE PLAN 20.0 0 DRY CASK STORAGE SYSTEM and INDEPENDENT SPENT FUEL STORAGE INSTALLATION PAGE 6 OF 16 EFFECTIVE DATE 8-9-12 5.2.7 The degree of application of requirements and procedures will be based on the following considerations concerning the complexity and proposed use of the structures, systems, or components.
5.2.7.1 The impact of malfunction or failure of the item on safety; 5.2.7.2 The design and fabrication complexity or uniqueness of the item; 5.2.7.3 The need for special controls and surveillance over processes and equipment; 5.2.7.4 The degree to which functional compliance can be demonstrated by inspection or test; and 5.2.7.5 The quality history and degree of standardization of the item.
5.2.8 Category A items are those items that are critical to safe operation and include structures, components, and systems whose failure could directly result in a condition adversely affecting public health and safety. The failure of a single item could cause loss of primary containment leading to release of radioactive material, loss of shielding, or unsafe geometry compromising criticality control.
5.2.9 Category B items have a major impact on safety and include structures, components, and systems whose failure or malfunction could indirectly result in a condition adversely afficting public health and safety. The failure of a Category B item, in conjunction with the failure of an additional item, could result in an unsafe condition.
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OPERATIONS QUALITY ASSURANCE PLAN 20.0 0 DRY CASK STORAGE SYSTEM and INDEPENDENT SPENT FUEL STORAGE INSTALLATION PAGE 7 OF 16 EFFECTIVE DATE 8-9-12 5.2.10 Category C items have a minor impact on safety and include structures, components, and systems whose failure or malfunction would not significantly reduce the packaging effectiveness and would not be likely to create a situation adversely affecting public health and safety.
5.3 Design Control 5.3.1 Design Control activities are performed in accordance with OQAP Chapter 6.0, Design and Modification Control and as
.specified below.
5.3.2 STP will control DCSS and ISFSI design bases documents received from vendors and developed internally.
5.3.3 Design changes, tests and experiments must be reviewed pursuant to the requirements 10CFR72.48. The C of C holder may initiate 10CFR72.48 activities independent of station activities.
5.3.4 Design basis documents applicable to the ISFSI and DCSS will be included in the STP document control system, Master Equipment Database (MED), and Master Parts List (MPL) as applicable.
5.4 Procurement Document Control 5.4.1 Procurement Control activities are performed in accordance with OQAP Chapter 7.0, Procurement and as specified below.
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OPERATIONS QUALITY ASSURANCE PLAN 20.0 0 DRY CASK STORAGE SYSTEM and INDEPENDENT SPENT FUEL STORAGE INSTALLATION PAGE 8 OF 16 EFFECTIVE DATE 8-9-12 5.4.2 Procurement Document Control applies to documents employed to procure important to safety materials, parts, components, and services required to modify, maintain, repair, test, inspect, or operate as a result of, or in support of, the 10CFR72 licensed facilities at the STP relating to the ISFSI and DCSS. STPNOC controls procurement documents by written procedures that establish requirements and assign responsibility for measures to ensure that applicable regulatory requirements, design bases, and other requirements necessary to ensure quality are included in or invoked by reference in documents employed for the procurement of important to safety materials, parts, components, and services.
5.4.3 Procurement of SSCs applicable to the ISFSI and DCSS will meet requirements of 10CFR72 Subpart G. The graded approach to quality will be used in the quality classification of S SCs for use on the dry cask storage systems.
5.4.4 Originating and reviewing organizations shall require that the following be included or invoked by reference in procurement documents for important to safety items or services, as appropriate:
5A.4.1 The supplier shall provide a description of a 10CFR72, Subpart G quality assurance program, or; 5.4.4.2 A 10CFR50, Appendix B or a IOCFR71, Subpart H quality assurance program that meets 10CFR72, Subpart G requirements and the recordkeeping requirements of 10CFR72.174.
5.4.4.3 10CFR21 is applicable to Category A.
0<
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OPERATIONS QUALITY ASSURANCE PLAN 20.0 0 DRY CASK STORAGE SYSTEM and INDEPENDENT SPENT FUEL STORAGE INSTALLATION PAGE 9 OF 16 EFFECTIVE DATE 8-9-12 5.4.5 Vendors supplying important to safety materials, parts, components, and services required to modify, maintain, repair, test, inspect, or operate as a result of, or in support of, the 10CFR72 licensed facilities at the STP will be evaluated for inclusion on the Approved Vendor List as required by OQAP Chapter 7.0, Procurement.
5.4.6 Vendors supplying important to safety materials, parts, components, and services required to modify, maintain, repair, test, inspect, or operate as a result of, or in support of, the 10CFR72 licensed facilities at the STP will be evaluated by Quality on an annual basis.
5.4.7 Vendors supplying important to safety materials, parts, components, and services required to modify, maintain, repair, test, inspect, or operate as a result of, or in support of, the 10CFR72 licensed facilities at the STP will be audited on a triennial basis.
5.5 Instructions, Procedures, and Drawings 5.5.1 Document control activities are performed in accordance with OQAP Chapter 8.0, Control and Issuance of Documents and as specified below.
5.5.2 Where the OQAP addresses control of Safety Related documents, Important to Safety Category A & B documents are to be included.
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV.
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OPERATIONS QUALITY ASSURANCE PLAN 20.0 0 DRY CASK STORAGE SYSTEM and INDEPENDENT SPENT FUEL STORAGE INSTALLATION PAGE 10OF16 EFFECTIVE DATE 8-9-12 5.5.3 These requirements are applicable to documents, which control activities Important to Safety for design, licensing, construction, operation, testing, maintenance, and modification of the ISFSI and DCSS. These documents include, but are not limited to, instructions, procedures, specifications, drawings, vendor manuals, status registers (such as drawing lists, equipment list), procurement documents, design documents, design change requests, as-built documents, non-conformance and deficiency reports, and Certificate Holder's Final Safety Analysis Report..
5.6 Control of Purchased Materials, Equipment, and Services 5.6.1 Purchased Materials, Equipment and Service control activities are performed in accordance with OQAP Chapter 7.0, Procurement. Capability to comply with the requirements of 10CFR72, Subpart G will be maintained.
5.7 Identification and Control of Materials, Parts and Components 5.7.1 Material, Part and Component control activities are performed in accordance with OQAP Chapter 9.0, Control of Material. Capability to comply with the requirements of 10CFR72, Subpart G will be maintained.
5.8 Control of Special Processes 5.8.1 Special Processes are controlled in accordance with OQAP Chapter 5.0, Maintenance, Installation of Modifications, and Related Activities, Section 5.5. Capability to comply with the requirements of 10CFR72, Subpart G will be maintained.
5.8.2 Nondestructive examinations associated with DCS activities will be evaluated by Engineering Department personnel independent of the activity. When ASME Section V is referenced personnel will be qualified in accordance with SNT-TC- 1A and ANSI/ASNT CP- 189.
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV.
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OPERATIONS QUALITY ASSURANCE PLAN 20.0 0 DRY CASK STORAGE SYSTEM and INDEPENDENT SPENT FUEL STORAGE INSTALLATION PAGE 11 OF 16 EFFECTIVE DATE 8-9-12 5.9 Inspection 5.9.1 Inspection is controlled in accordance with OQAP Chapter 10.0, Inspection. Capability to comply with the requirements of 10CFR72, Subpart G will be maintained.
5.9.2 Inspections related to DCSS/ISFSI activities shall be in accordance with the DCSS C of C and 10CFR72, Subpart G requirements.
5.9.3 NDE performed on DCSS shall be in compliance with referenced ASME Boiler & Pressure Vessel Code, Sections III and Section V, Articles 6, 9 and 10 or as specified in the applicable C of C and FSAR.
5.10 Inspection, Test and Operating Status 5.10.1 Inspection, Test and Operating Status is controlled in accordance with OQAP Chapters 3.0, Conduct of Operations, 5.0, Maintenance, Installation of Modifications, and Related Activities, 10.0, Inspection, and 11.0, Test Control. Capability to comply with the requirements of 10CFR72, Subpart G will be maintained.
5.10.2 Measures shall be established to ensure that necessary inspections of items meet the requirements and acceptance limits contained in the DCSS (C of C/FSAR) and have not been inadvertently bypassed or that SSC are not inadvertently operated outside of specified requirements.
5.10.3 Personnel performing examinationsand tests shall be qualified as required by OQAP, Chapter 4.0 Qualification, Training and Certification of personnel.
5.10.4 The 10CFR72 C of C, for the storage systems in use at the STP ISFSI establishes technical specifications that ensure the systems are loaded, transferred, and maintained functional for safe storage.
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV.
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OPERATIONS QUALITY ASSURANCE PLAN 20.0 0 DRY CASK STORAGE SYSTEM and INDEPENDENT SPENT FUEL STORAGE INSTALLATION PAGE 12 OF 16 EFFECTIVE DATE 8-9-12 5.10.5 Sequence Change Control - Procedures will include the control of the sequence of required tests, inspections, and other operations when important to safety. To change these controls, the individual procedure must be changed, which requires the same review and approval cycle as that which authorized the original procedure.
5.11 Test Control 5.11.1 Tests are controlled in accordance with OQAP Chapter 11.0, Test Control. Capability to comply with the requirements of 10CFR72, Subpart G will be maintained.
5.11.2 Provisions will be established for the performance of DCS and ISFSI surveillance testing to ensure that the necessary quality of systems and components is maintained, that facility operations are within the safety limits, and that limiting conditions of operation can be met.
5.11.3 The testing frequency will be at least as frequent as prescribed in the Technical Specifications for the 10CFR72 C of C for DCSS used at the STPEGS.
5.12 Control of Measuring and Test Equipment 5.12.1 M&TE is controlled in accordance with OQAP Chapter 12.0, Instrument and Calibration Control. Capability to comply with the requirements of 10CFR72, Subpart G will be maintained.
5.13 Handling, Storage, and Shipping 5.13.1 Handling, Storage, and Shipping is controlled in accordance with OQAP Chapter 9.0, Control of Material. Capability to comply with the requirements of 10CFR72, Subpart G will be maintained.
5.13.2 Measures will be established to control the handling of licensed radioactive materials in accordance with 10CFR72.
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OPERATIONS QUALITY ASSURANCE PLAN 20.0 0
.DRY CASK STORAGE SYSTEM and INDEPENDENT SPENT FUEL STORAGE INSTALLATION PAGE 13 OF 16 EFFECTIVE DATE 8-9-12 5.13.3 This program includes the storage of spent fuel, high level radioactive waste, and reactor-related Greater than Class C waste. When this material is stored in the facility licensed under 10CFR50, the OQAP applies. When this material is stored in the portion of the facility licensed under 10CFR72 (the ISFSI), 10CFR72, Subpart G quality assurance requirements apply.
5.14 Records 5.14.1 Record control is in accordance with OQAP Chapter 14.0, Records Control. Capability to comply with the requirements of 10CFR72, Subpart G will be maintained.
5.14.2 Records include, but are not limited to, those pertaining to the design, fabrication, erection, testing, maintenance, and use of structures, systems, and components important to safety and are required to be maintained by or under the control of the licensee or certificate holder until the NRC tenrminates the license or C of C as required by 10CFR72.174.
5.14.3 The term lifetime record is applicable to both the 10CFR50 and 10CFR72 licensed facilities at the STPEGS. In the case where lifetime records are applicable to both license types, the record will be maintained until the termination of the last license.
5.14.4 Records of the following activities performed in support of or as required for the ISFSI and/or DCSS shall be retained for the duration of the 10CFR72 licensed facility.
5.14.4.1 Record and drawing changes reflecting facility design modifications made to systems and equipment described in the Final Safety Analysis Report.
5.14.4.2 Records of new and irradiated fuel inventory, fuel transfers and assembly burnup histories.
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV.
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OPERATIONS QUALITY ASSURANCE PLAN 20.0 0 DRY CASK STORAGE SYSTEM and INDEPENDENT SPENT FUEL STORAGE INSTALLATION PAGE 14 OF 16 EFFECTIVE DATE 8-9-12 5.14.4.3 Records of facility radiation and contamination surveys.
5.14.4.4 Records of radiation exposure for all individuals for whom monitoring was required.
5.14.4.5 Records of gaseous and liquid radioactive material released to the environment.
5.14.4.6 Records of training and qualification for members of the plant staff.
5.14.4.7 Records of in-service inspections performed pursuant to the Technical Specifications.
5,14.4.8 Records of Quality Assurance activities required by the OQAP.
5.14.4.9 Records of reviews performed for changes made to procedures or equipment or reviews for tests and experiments pursuant to 10CFR72.48.
5.14.4.10 Records of reviews performed pursuant to IOCFR72.212.
5.14.4.11 Records of meetings of the PORC.
5.14.4.12 Records of results of analyses required by the radiological environmental monitoring program.
5.14.4.13 Records of reviews performed for changes made to the Offsite Dose Assessment Manual and the Process Control Program.
5.14.4.14 Licensed radioactive waste disposal records.
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV.
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OPERATIONS QUALITY ASSURANCE PLAN 20.0 0 DRY CASK STORAGE SYSTEM and INDEPENDENT SPENT FUEL STORAGE INSTALLATION PAGE 15 OF 16 EFFECTIVE DATE 8-9-12 5.15 Nonconforming Items 5.15.1 Control of conditions adverse to quality is covered in OQAP Chapter 13.0, Control of Conditions Adverse to Quality.
Capability to comply with the requirements of 10CFR72, Subpart G will be maintained.
5.15.2 The Certificate Holder shall address any fabrication nonconformances identified that require NRC approval.
5.16 Corrective Action 5.16.1 Corrective Action is covered throughout the OQAP, in Chapter 13.0, Control of Conditions Adverse to Quality and others. Capability to comply with the requirements of 10CFR72, Subpart G will be maintained.
5.17 Audits 5.17.1 Audits are covered in OQAP Chapter 15.0, Quality Oversight Activities and as specified below.
5.17.2 Audits of DCSS/ISFSI important to safety functions will be performed on a nominal biennial frequency to ensure the requirements of the 10CFR72 licensed ISFSI operation provisions contained within the DCSS Certificate of Compliance for the storage system(s) in use and applicable license conditions are maintained.
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV.
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OPERATIONS QUALITY ASSURANCE PLAN 20.0 0 DRY CASK STORAGE SYSTEM and INDEPENDENT SPENT FUEL STORAGE INSTALLATION PAGE 16 OF 16 EFFECTIVE DATE 8-9-12 6.0 DOCUMENTATION 6.1 Procedures which are generated as required by this procedure shall identify the records which are required to implement and document those activities. The records shall be controlled in accordance with this Chapter 20.0, Dry Cask Storage System and Independent Spent Fuel Storage Installation, Section 5.14 and Chapter 14.0, Records Control.
7.0 ATTACHMENTS 7.1 None