NOC-AE-13003050, Submittal of Operations Quality Assurance Plan Change QA-080

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Submittal of Operations Quality Assurance Plan Change QA-080
ML13330A015
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 11/11/2013
From: Koehl D
South Texas
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
G09.19, NOC-AE-13003050, QA-080, STI: 33775002
Download: ML13330A015 (14)


Text

Nuclear Operating Company South Tcas Project Electric GeneratinSStation P.. Box 28.9 Wdsworth, Texas 77483 November 11, 2013 NOC-AE-13003050 File No.: G09.19 10CFR50.54(a)

STI: 33775002 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-080 The STP Nuclear Operating Company (STPNOC) submits the attached change to revision 20 of the Operations Quality Assurance Plan (OQAP). These changes provide the necessary revision to the applicable chapters of the OQAP to incorporate an organizational realignment.

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 1 OCFR50.54(a)(3).

There are no commitments in this letter.

If there are any questions ,*'1~2-7765regarding this matter, please contact Mr. T. F. Walker at (361) 972- 392 or John Sav e(6 2-75.

Dennis L. Koehl President and CEO

Attachment:

Operations Quality Assurance Plan change QA-080

NOC-AE-1 3003050 Page 2 of 2 cc:

(paper copy) (electronic copy)

Regional Administrator, Region IV A. H. Gutterman, Esquire U. S. NuclearRegulatory 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 B1) 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. O. Box 289, Mail Code: MN116 Wadsworth, TX 77483 Jim Collins* 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 Heallth Services Robert Free Texas Department of State Health Services

CHANGE QA-080

SUMMARY

OF CHANGES Page 1 of 3 ALL CHANGES ARE IN BOLD TYPE CHAPTER LOCATION ACTION TEXT TOC CH 1.0 INSERT QA-080 CH 16.0 INSERT QA-080 CH 1.0 5.1 DELETE Senior Vice President, Operations INSERT Site Vice President, General Manager, Corporate Communications, and General Manager, Financial Services 5.3 DELETE Senior Vice President, Operations (2 places) and operations, regulatory affairs, plant protection (emergency response, plant protection support, security, access authorization), projects, and nuclear oversight INSERT Site Vice President (2 places) and staffing STP with qualified personnel and acquiring and coordinating the assistance of internal and external organizations for the following functions including: plant general management, engineering, training, and regulatory affairs 5.3.1 DELETE The Site Vice President is responsible for implementing quality program requirements applicable to staffing STP with qualified personnel and acquiring and coordinating the assistance of internal and external organizations for the following functions including: plant general management, engineering, and training.

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

INSERT from The Plant General Manager has prime deleted 5.3.1.1 responsibility for the safe operations of the units.

and 5.3.1.2 The plant staff, under the direction of the Plant General Manager, develops detailed procedures and instructions for testing, operation, modification, and maintenance of the STP. The Plant General Manager is responsible for implementing quality program requirements applicable to the following functions including:

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

CHANGE QA-080

SUMMARY

OF CHANGES Page 2 of 3 ALL CHANGES ARE IN BOLD TYPE CHAPTER LOCATION ACTION TEXT CH 1.0 5.3.1.1 and DELETE Text moved to 5.3.1 5.3.1.2 ,.__.

New 53.2 INSERT The flew text is inserted from old 5.3.1.3 New 5.3.2.1 INSERT The new text is inserted from old 5.3.1.3.1 5.4 DELETE fitness for duty program, contracts &

procurement, information technology, support &

technology, and records management system INSERT projects, security, support & information technology, nuclear oversight, and human resources, knowledge transfer and retention and organizational development.

5.4.1 - INSERT The new text is inserted from old 53.2 New 5.4.1.1 INSERT The new text is inserted from old 5.3.2.1 through through 5.4.1.3. 5.3.2.3 New 5.4.2 '_ INSERT The new text is inserted from old 5.3.3. Insert engineering before projects DELETE independent spent fuel storage installation and dry cask storage system New 5.4.3 INSERT The new text is inserted from old 5.4.1. Insert strategic projects New 5.4.4 INSERT The new text is inserted from old 5.4.3. Insert and

  • _access authorization New 5.5 INSERT The new text is inserted from old 5.4.2 New 5.6 INSERT The General Manager, Corporate Communications is responsible for implementing quality program requirements applicable to emergency response. The management of this function reports to the General Manager, Corporate Communications.

CH 16.0 5.1 DELETE Chief Nuclear Officer INSERT Vice President, Corporate Services

CHANGE QA-080

SUMMARY

OF CHANGES Page 3 of 3 ALL CHANGES ARE IN BOLD TYPE CHAPTER LOCATION ACTION TEXT 5.2 INSERT Assurance CH 16.0 6.6 DELETE and Chief Nuclear Officer INSERT and before the President and Chief Executive Officer

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV.

NO.

Chapter OPERATIONS QUALITY ASSURANCE PLAN TABLE 20 OF CONTENT TABLE OF CONTENTS PAGE I 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 QA-079, QA-080 2.0 Program Description 18 2-1-12 QA-074,QA-075, QA-076, QA-079 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, QA-079 8.0 Control and Issuance of Documents 6 2-1-98 QA-078 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 Control 6 2-1-98 QA-078 13.0 Control Of Conditions Adverse to 14 2-1-12 QA-074, QA-078 Quality QA-079

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV.

Chapter NO.

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.

14.0 Records Control 8 2-1-06 QA-074, QA-078 15.0 Quality Oversight Activities 13 2-1-12 QA-074, QA-079 16.0 Independent Technical Review 12 2-1-12 QA-074,QA-075, QA-080 17.0 ASME Code Section XI - Repairs 10 2-1-12 QA-074, QA-079 and Replacements 18.0 ASME Code Section XI - Inservice 11 2-1-12 QA-074, QA-079 Inspection and Testing 19.0 Administrative Controls 5 2-1-12 QA-074, QA-075 QA-079 20.0 Dry Cask Storage System and 0 8-9-12 QA-075, QA-077 Independent Spent Fuel Storage QA-078, QA-079 Installation

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV.

Chapter NO.

OPERATIONS QUALITY ASSURANCE PLAN 1.0 16 ORGANIZATION PAGE 1 OF 4 EFFECTIVE DATE 02-01-12 1.0 PURPOSE 1.1 The purpose of this chapter is to describe the organizational structure as related to quality assurance and to establish the responsibilities of organizations for the South Texas Project (STP).

2.0 SCOPE 2.1 STP Nuclear Operating Company (STPNOC), as licensee, has the Quality responsibility for design, engineering, procurement, fabrication, modification, maintenance, repair, in-service inspection, refueling, testing, and operation of the STP Units 1 & 2, Dry Cask Storage System (DCSS), and Independent Spent Fuel Storage Installation (ISFSI).

3.0 DEFINITIONS 3.1 None

4.0 REFERENCES

4.1 None 5.0 RESPONSIBILITIES 5.1 The STPNOC organization includes the Vice President, Corporate Services, Site Vice President, General Manager, Corporate Communications, and General "

Manager, Financial Services. The senior management of these groups report to the President and Chief Executive Officer. <

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

5.3 The Site Vice President is responsible for implementing quality program requirements applicable to staffing STP with qualified personnel and acquiring and coordinating the assistance of internal and external organizations for the following functions including: plant general management, engineering, training, and regulatory affairs. The senior management of these functions report to the CY Site Vice President.

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV.

NO.

Chapter OPERATIONS QUALITY ASSURANCE PLAN 1.0 16 ORGANIZATION PAGE 2 OF 4 EFFECTIVE DATE 02-01-12 5.3.1 The Plant General Manager has prime responsibility for the safe cc operations of the units. The plant staff, under the direction of the Plant

.General Manager, develops detailed procedures and instructions for testing, operation, modification, and maintenance of the STP. The Plant General Manager is responsible for implementing quality program C?

requirements applicable to the following functions including: operations, <

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

5.3.2 The General Manager, Engineering is responsible for implementing quality program requirements applicable to the following functions: design C engineering, testing/program engineering, systems engineering, maintenance engineering, special projects, and nuclear fuel & analysis (includes risk management). The management of these functions report to 0' the General Manager, Engineering.

5.3.2.1 The Manager, Nuclear Fuel & Analysis is responsible for implementing quality program requirements applicable to the following functions: reactor engineering, core design, reload safety analysis, nuclear fuel performance and supply, risk management (probabilistic risk assessment and risk-informed applications).

Activities related to the Comprehensive Risk Management Program include oversight of Probabilistic Safety Assessment activities. The Comprehensive Risk Management Expert Panel guides the implementation of the Comprehensive Risk Management Program and is composed of a Chairman and additional senior level management designated by the President and Chief Executive Officer.

00 5.4 The Vice President, Corporate Services is responsible for implementing quality o program requirements applicable to the following functions: projects, security, support & information technology, nuclear oversight, and human resources, knowledge transfer and retention and organizational development. The senior management of these functions report to the Vice President, Corporate Services. ,

5.4.1 The Manager, Nuclear Oversight is responsible for implementing quality program requirements applicable to organizational effectiveness and quality assurance. The management of these functions report to the Manager, Nuclear Oversight.

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV.

Chapter NO.

OPERATIONS QUALITY ASSURANCE PLAN 1.0 16 ORGANIZATION PAGE 3 OF 4 EFFECTIVE DATE 02-01-12 5.4.1.1 The Manager, Quality Assurance has the independence to conduct Quality activities without undue pressure of cost or schedule and is responsible for the following:

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

5.4.1.2 The Manager, Nuclear Oversight and the Manager, Quality Assurance, at their discretion, have unfettered access to the President and Chief Executive Officer and the Board of Directors.

5.4.1 .3, The Manager, Nuclear Oversight and the Manager, Quality <

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

0C 5.4.2 The General Manager, Projects (Outage/PIP/PMPI) is responsible for implementing quality program requirements applicable to the following functions: strategic projects, engineering projects, outage management, and major projects. The management of these functions report to the General Manager, Projects (Outage/PIP/PMPI). C?

o'

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV.

NO.

Chapter OPERATIONS QUALITY ASSURANCE PLAN 1.0 16 ORGANIZATION PAGE 4 OF 4 EFFECTIVE DATE 02-01-12 5.4.3 The General Manager, Support & Information Technology is responsible for implementing quality program requirements applicable to the following functions: information technology, cyber security, strategic projects, and records management. The management of these functions rreport to the General Manager, Support & Information Technology.

5.4.4 The General Manager, Human Resources, Knowledge Transfer &

Organizational Development is responsible for implementing quality program requirements applicable to fitness for duty and access authorization. The management of this function reports to the General Manager, Human Resources, Knowledge Transfer & Organizational Development.

5.5 The General Manager, Financial Services is responsible for implementing quality program requirements applicable to contracts & procurement. The management of this function reports to the General Manager, Financial Services.

5.6 The General Manager, Corporate Communications is responsible for implementing quality program requirements applicable to emergency response.

The management of this function reports to the General Manager, Corporate Communications.

6.0 REQUIREMENTS 6.1 The fundamental responsibility for implementing quality program requirements is assigned-to all personnel performing activities affecting the safe and reliable operation of STP. These personnel and their management are responsible for implementing through approved procedures and other work documents, the quality assurance program controls described in the OQAP. Line organizational details and responsibilities for Units 1 & 2 are further described in STP UFSAR Chapter 13.1.

7.0 DOCUMENTATION 7.1 None 8.0 ATTACHMENTS 8.1 None

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV.

Chapter NO.

OPERATIONS QUALITY ASSURANCE PLAN 16.0 12 Independent Technical Review PAGE 1 OF 3 EFFECTIVE DATE 02-01-12 1.0 PURPOSE 1.1 The purpose of this chapter is to describe the requirements and responsibilities for independent technical review for the South Texas Project (STP).

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

3.0 DEFINITIONS 3.1 None

4.0 REFERENCES

4.1 OQAP Chapter 1.0, Organization 4.2 OQAP Chapter 2.0, Program Description 4.3 OQAP Chapter 4.0, Qualification, Training, and Certification of Personnel 4.4 OQAP Chapter 13.0, Deficiency Control 4.5 OQAP Chapter 14.0, Records Control 4.6 OQAP Chapter 15.0, Quality Oversight Activities 5.0 RESPONSIBILITIES 5.1 The Vice President, Corporate Services is responsible for implementing quality 0 0C program requirements including independent technical review.

0Y 5.2 The Manager, Quality Assurance is responsible for independent oversight activities performed to accomplish the independent technical reviews.

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

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV.

NO.

Chapter OPERATIONS QUALITY ASSURANCE PLAN 16.0 12 Independent Technical Review PAGE 2 OF 3 EFFECTIVE DATE 02-01-12 6.2 Independent technical reviews shall be used to observe and verify that activities are performed correctly and that human errors are reduced as much a's practical.

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

6.3.1 Unit-operating characteristics 6.32 Nuclear Regulatory Commission issuances 6.3.3 Industry advisories 6.3.4 Licensee Event Reports 6.3.5 Other sources of unit design and operating experience information, including units of similar design, which may indicate areas for improving unit safety.

6.3.6 Plant operations 6.3.7 Maintenance activities 6.3.8 Equipment modifications 6.3.9 Independent Spent Fuel Storage Installation and Dry Cask Storage System t 6.4 As determined by Quality management, several personnel performing independent technical reviews will be required to have a degree in engineering or related science and at least 3 years of professional level experience in the nuclear field.

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

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

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

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV.

Chapter NO.

OPERATIONS QUALITY ASSURANCE PLAN 16.0 12 Independent Technical Review PAGE 3 OF 3 EFFECTIVE DATE 02-01-12 7.0 DOCUMENTATION 7.1 Procedures which are generated as required by this chapter shall identify the records which are required to implement and document those activities. The records shall be controlled in accordance with Reference 4.5.

8.0 ATTACHMENTS 8.1 None