NOC-AE-18003588, Submittal of Operations Quality Assurance Plan Change QA-086

Submittal of Operations Quality Assurance Plan Change QA-086

ML18218A577
Person / Time
Site:	South Texas
Issue date:	08/06/2018
From:	Gerry Powell South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-18003588, STI: 34700098
Download: ML18218A577 (54)

Text

Nuclear Operating Company South Texas Project Electric Generating Station P.O. Box 289 Wadsworth, Texas 77483 August 06,2018 NOC-AE-18003588 File No: G25 10CFR50.54(a)

Attention: Document Control Desk U. S. Nuclear Regulatory Commission 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-086 STP Nuclear Operating Company (STPNOC) submits the attached change to Revision 23 of the Operations Quality Assurance Plan (OQAP). The purpose of this OQAP change is to provide clarity and consistent terminology regarding the Dry Cask Storage System and the Independent Spent Fuel Storage Installation (Affected Chapters 2.0, 19.0 and 20.0). In accordance with the provisions of 10CFR50.54(a)(3), the changes are editorial items and provide clarification, and as such do not represent a reduction in commitment and therefore do not require NRC approval prior to implementation.

There are no commitments in this letter.

If there are any questions regarding this matter, please contact Mr. J. R. Mertink at (361) 972-7392 or Randall Exum at (361) 972-7099.

^^v.

G. T. Powell Interim President & CEO, CNO Attachments: 1. 10CFR 50.54 (a) Evaluation for QA-086

2. QA-086 Summary of Changes

3. Operations Quality Assurance Plan change QA-086 STI:34700098

NOC-AE-18003588 Page 2 of 2 ec:

Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 1600 E. Lamar Boulevard Arlington, TX 76011-4511 Lisa M. Regner Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North (09E01) 11555RockvillePike Rockville, MD 20852 NRC Resident Inspector U. S. Nuclear Regulatory Commission P. 0. Box 289, Mail Code: MN116 Wadsworth.TX 77483

NOC-AE-18003588 Attachment 1 10CFR 50.54 (a) Evaluation for QA-086

ATTACHMENT 10CFR50.54 (a) EVALUATION QA-086 Page 1 of 1 This OQAP change is to achieve alignment/provide clarity and consistent terminology within applicable Chapters of the OQAP involving or associated with the Dry Cask Storage System (DCSS) and the Independent Spent Fuel Storage Installation (ISFSI). (Affected Chapters 2.0,19.0, 20.0)

The changes are editorial in nature, or provide clarification, and as such do not represent a reduction in commitment and therefore do not require NRC approval prior to implementation in accordance with the provisions of 10CFR50.54(a)(3).

NOC-AE-18003588 Attachment 2 QA-086 Summary of Changes

CHANGE QA-086

SUMMARY

OF CHANGES SECTIONS (TEXT) WITH CHANGES IN BOLD TYPE CHAPTER LOCATION ACTION TEXT TOC CH 2.0 INSERT QA-086 CH 19.0 INSERT QA-086 CH 20.0 FNSERT QA-086 CH 2.0 5.1.1 DESERT DCSS/ (immediately preceding ISFSI)

CH 19.0 5.2.1.15 DELETE fuel 5.2.1.15 INSERT cask CH 20.0 2.1 DELETE regarding the ISFSI 2.1 INSERT DCSS and (immediately preceding ISFSI - 2 places) 3.1 INSERT DCSS/ (immediately preceding ISFSI) 3.4 INSERT DCSS/ (immediately preceding ISFSI) 5.2.2 FNSERT cask 5.10.4 ENSERT DCSS/ (immediately preceding ISFSI) 5.11.3 INSERT /ISFSI (immediately after DCSS) 5.13.3 DELETE , high level radioactive waste, 5.13.3 INSERT DCSS/ (immediately preceding ISFSI) 5.17.2 DELETE ISFSI 5.17.2 DELETE DCSS

NOC-AE-18003588 Attachment 3 Operations Quality Assurance Plan change QA-086

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Chapter TABLE OF 23 OPERATIONS QUALITY ASSURANCE PLAN CONTENTS TABLE OF CONTENTS PAGE 1 OF 2 EFFECTIVE DATE 01-15-18 Chapter Title Effective Effective Change Number Chapter Revision Date Notice No.

Definitions 10 2-1-14 1.0 Organization 19 1-15-18 2.0 Program Description 20 1-15-18 QA-086 3.0 Conduct of Operation 9 2-1-14 4.0 Qualification, Training, and 7 2-1-14 Certification of Personnel 5.0 Maintenance, Installation of 6 2-1-14 Modifications, and Related Activities 6.0 Design and Modification Control 11 2-1-14 7.0 Procurement 15 1-15-18 8.0 Conb-ol and Issuance of Documents 7 2-1-14 9.0 Control of Material 7 2-1-14 10.0 Inspection 12 2-1-14 11.0 Test Control 9 2-1-14 12.0 Instrument and Calibration Control 7 2-1-14 13.0 Control Of Conditions Adverse to 16 1-15-18 Quality 14.0 Records Control 9 2-1-14

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Chapter OPERATIONS QUALITY ASSURANCE PLAN TABLE OF 23 CONTENTS TABLE OF CONTENTS PAGE 2 OF 2 EFFECTIVE DATE 01-15-18 Chapter Title Effective Effective Change Number Chapter Revision Date Notice No.

15.0 Quality Oversight Activities 15 1-15-18 16.0 Independent Technical Review 15 1-15-18 17.0 ASME Code Section XI - Repau-s 11 2-1-14 and Replacements 18.0 ASME Code Section XI - Inservice 12 2-1-14 Inspection and Testing 19.0 Admimstrative Controls 8 1-15-18 QA-086 20.0 Dry Cask Storage System and 1 2-1-14 QA-086 Independent Spent Fuel Storage Installation

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Chapter OPERATIONS QUALITY ASSURANCE PLAN 2.0 20 PROGRAM DESCRIPTION PAGE 1 OF 19 EFFECTWE DATE 01-15-18 1.0 PURPOSE 1.1 The purpose of this chapter is to define criteria and establish administrative controls for implementation of the Quality Assurance (QA) Program for the South Texas Project (STP).

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

2.2 The QA Program will also extend, as applicable and/or determined by STP management, to programs including 10CFR71, Subpart H (except design and fabrication ofNRC certified radioactive waste shipping casks), 10CFR72, Subpart G (those features, activities, and SSCs of an Independent Spent Fuel Storage Installation (ISFSI), Dry Cask Storage System (DCSS), or a transportation package important to safety that maintain the conditions required to prevent damage to a container during handling and storage, or provide reasonable assurance that radioactive material can be received, handled, stored, and retrieved without undue risk to the health and safety of the public), ASME Boiler and Pressure Vessel Code, Sections III, V, IX, and XI; and to quality-related areas as defined herein including the Fire Protection Program, Emergency Plan, Radiological Environmental Monitoring Program, Radwaste Management Program, Computer Program Verification and Control, Seismic and Environmental Equipment Qualification Programs, Radiation Protection Program, and Station Blackout (SB 0) systems and equipment.

2.3 Additional quality requirements specific to ISFSI and DCSS are located in Reference 4.9.

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

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Chapter OPERATIONS QUALITY ASSURANCE PLAN 2.0 20 PROGRAM DESCRIPTION PAGE 2 OF 19 EFFECTFVE DATE 01-15-18 3.2 Graded Quality Assurance - The process by which risk-based methodology [i.e.,

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

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

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

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

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

3.7 Graded Approach to Quality - Used as required by 1 OCFR72 to apply to all activities affecting the important to safety functions of those SSCs of the ISFSIor DCSS that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public. The identification of important to safety SSCs for each type ofDCSS used at STP is contained within its own unique 10CFR72 (Certificate Holder's) Final Safety Analysis Report (FSAR) (as updated), and Certificate of Compliance (C of C).

4.0 REFERENCES

4.1 1 OCFR50, Appendix B 4.2 10CFR71,SubpartH 4.3 ASME B&PV Code 4.4 OQAP Chapter 14.0, Records Control 4.5 10CFR50.63, Loss of All Alternating Current Power

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Chapter OPERATIONS QUALITY ASSURANCE PLAN 2.0 20 PROGRAM DESCRIPTION PAGE 3 OF 19 EFFECTWE DATE 01-15-18 4.6 10CFR50.54(a) 4.7 Updated Final Safety Analysis Report 4.8 Safety Evaluation on Exemption Requests from Special Treatment Requirements of 10 CFR Parts 21, 50, and 100 (TAG NOS. MA6057 AND MA6058) 4.9 OQAP Chapter 20.0, Dry Cask Storage System and Independent Spent Fuel Storage Installation 4.10 10CFR72,SubpartG 5.0 REQUIREMENTS 5.1 General Program Requirements 5.1.1 The OQAP shall be prepared and maintained to prescribe the STP QA Program. The OQAP reflects the quality program policies to be implemented. The OQAP describes the organization and responsibilities for attainment of quality objectives and verification of conformance to

^p established requirements. The QA Program shall be in effect throughout 00 the operating life of the STP (Units 1 & 2) and the DCSS/ISFSI. 0 a

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

5.1.3 The operations phase of the STP includes design, procurement, fabrication, repair, testing, operation, maintenance, refueling, inspection, independent oversight, modification, and other activities as discussed Table I to this chapter and throughout the OQAP. STP and its vendors are required, as appropriate, to comply with the criteria established by 10CFR50, Section 50.55a; 10CFR50, Appendix A, General Design Criterion (GDC) 1; 10CFR50, Appendix B, 10CFR72, Subpart G, and 10CFR71, Sub-Part H (except design and fabrication ofNRC certified radioactive waste shipping casks). These regulations are not applicable to LSS and NRS safety-related components, to the extent that the Nuclear Regulatory Commission has granted STP an exemption from the regulations as described in Reference 4.8.

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Chapter OPERATIONS QUALITY ASSURANCE PLAN 2.0 20 PROGRAM DESCRIPTION PAGE 4 OF 19 EFFECTIVE DATE 01-15-18 STP will implement, as specified, the Regulatory Guides (RG) and implementing American National Standards Institute (ANSI) standards contained in Table I of this chapter.

5.1.4 STP shall maintain the OQAP as an effective and meaningful document to provide programmatic direction for the station. Changes to the OQAP shall be accomplished as prescribed by 10CFR50.54(a).

5.2 Organizational Independence 5.2.1 The reporting arrangement utilized by the Quality organization ensures that those personnel perfonning independent oversight have the organizational freedom to:

5.2.1.1 Identify quality problems.

5.2.1.2 Initiate, recommend, or provide solutions.

5.2.1.3 Verify implementation of solutions.

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

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

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

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

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Chapter OPERATIONS QUALITY ASSURANCE PLAN 2.0 20 PROGRAM DESCRIPTION PAGE 5 OF 19 EFFECTIVE DATE 01-15-18 5.3.3 Selected systems are evaluated, at the component level, by a cross-discipline Expert Panel comprised of high level station management.

Initial evaluations are performed by the Working Group.

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

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

5.3.5 Program control recommendations are developed by the Working Group and ultimately approved by the Expert Panel and forwarded to the site for implementation. Controls are implemented in four graded applications (i.e., "Full", "Basic", "Targeted", and "Limited").

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

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

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

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Chapter OPERATIONS QUALITY ASSURANCE PLAN 2.0 20 PROGRAM DESCRIPTION PAGE 6 OF 19 EFFECTWE DATE 01-15-18 5.3.8.1 Those elements in Chapter 1.0 that are needed to implement and control activities described above; 5.3.8.2 Applicable requirements in this Chapter; 5.3.8.3 Modification/design activities as described in Chapter 6.0; and 5.3.8.4 Corrective action as described in Chapter 13.0.

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

5.3.10 Safety-related components that are highly reliable, yet whose failure would result in a significant increase in risk, will receive Full program coverage, or will be evaluated based on their risk significance to ensure that Full program controls are applied to their critical attributes.

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

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

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

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

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Chapter OPERATIONS QUALITY ASSURANCE PLAN 2.0 20 PROGRAM DESCRIPTION PAGE 7 OF 19 EFFECTWE DATE 01-15-18 5.5 Identification of Safety Significant Structures, Systems, and Components 5.5.1 The program described herein is applied to activities affecting the safety functions of those structures, systems, and components which prevent, or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public. The structures, systems, and components controlled are listed in UFSAR Section 3.2, along with their associated fire protection systems. UFSAR Section 3.2 also identifies those structures, systems, and components which may not represent a safety significant/risk important concern but to which the STP OQAP is applied.

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

5.5.3 Expendable or consumable items necessary for the functional performance of structures, systems, and components are subjected to quality assurance requirements as specified in written procedures. These procedures include provisions for review and control in accordance with industry standards and specifications.

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

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Chapter OPERATIONS QUALITY ASSURANCE PLAN 2.0 20 PROGRAM DESCmPTION PAGE 8 OF 19 EFFECTIVE DATE 01-15-18 5.7 Personnel Indoctrination and Training 5.7.1 General indoctrination and training programs shall be provided for site personnel to assure that they are knowledgeable regarding quality programs and requirements. The training requirements for STP personnel are described in UFSAR Section 13.2. Personnel performing complex, unusual, or potentially hazardous work shall be instmcted in special indoctrination or briefing sessions. Emphasis shall be on special requirements for safety of personnel, radiation control and protection, unique features of equipment and systems, operating constraints, and control requirements in effect during performance of work. Where required by codes and standards, personnel are trained, qualified, and certified according to written procedures in the principles and techniques of performing specific activities.

5.8 Policies and Goals 5.8.1 STP policy is to assure that the design, procurement, construction, testing, and operation of the STP are in conformance with specifications, procedures, codes, commitments and Nuclear Regulatory Commission (NRC) regulations to the extent not exempted. The responsibility of each organization supporting the STP is to ensure that the requirements stated in this QA Program are incorporated into procedures. Adherence to those procedures is mandatory for all STP organizations and contractors or vendors providing items or services covered by the QA Program.

5.8.2 The OQAP identifies activities and establishes requirements for procedures which identify, report, and verify the resolution of quality problems. The implementing procedures call for the resolution of quality problems at the lowest possible authorized level. However, if a dispute is encountered in the resolution of a quality problem which cannot be resolved at lower levels, the Manager, Nuclear Oversight shall present the problem to the President and Chief Executive Officer for resolution.

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

Procedures will comply with the appropriate standards.

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Chapter OPERATIONS QUALITY ASSURANCE PLAN 2.0 20 PROGRAM DESCRIPTION PAGE 9 OF 19 EFFECTIVE DATE 01-15-18 5.9.2 STP personnel attend planning, scheduling, and status meetings as necessary to assure adequate quality coverage and program application exists.

5.10 Management Review 5.10.1 The implementation of both line and OQAP requirements shall be verified through independent oversight activities. The Quality organization shall conduct independent oversight activities of the operating plant, DCSS, ISFSI and of the interfacing organizations' activities.

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

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

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

6.0 DOCUMENTATION 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 Table I - Program Commitments

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

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

Operator license are met by the Unit Operations Managers.

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

ANSI N45.2, 1971 This standard is not applicable to operations phase activities. Same as full.

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

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

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

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

frequency.

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

Operator license.

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

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

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

time as) work performance.

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TABLE I PROGRAM COMMITMENTS R.G./ANSI STANDARD FULL PROGRAM BASIC PROGRAM ANSIN18.7/ANS 3.2 (cont'd) 5.2.7 (1st paragraph) - STP will use current approved design bases as opposed to Same as full.

original design bases.

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

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

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

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

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

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

5.2.13.4 (5th paragraph) - refer to table coverage ofANSI N45.2.2, 1972.

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

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

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

Operations Quality Assurance Plan, Chapter 2.0, Revision 20 Page 11 of 19

TABLE I PROGRAM COMMITMENTS R.G./ANSI STANDARD FULL PROGRAM BASIC PROGRAM ANSI N18.7/ANS 3.2 (cont'd) 5.2.17 (3rd paragraph) - STP may not implement the requirement for conduct of inspections in a manner similar to that associated with construction phase activities (i.e.,

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

R.G. 1.3 8, rev. 2 (5/77) No exceptions taken. No exceptions taken.

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

1.146/ANSI45.2.23.

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

5.2.1 - These activities do not constitute an "inspection" as defined in Same as Full ANSVASME NQA-1, 1983, Supplement S-l, Tenns and Definitions. Therefore, the requirements for qualification to ANSI N45.2.6 as stated in Section 2.4 do not apply to personnel performing these activities.

R.G. 1.5 8, rev. 1(9/80) C.2 - STP is committed to ASNT-TC-1A, 1980. STP treats the recommendation Same as full.

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

ANSI N45.2.6, 1978 1.2 (1st paragraph) - with the exception of receipt inspection, personnel may perform inspections, examinations and tests provided they are experienced, task qualified journeymen, or supervisors, who did not perfonn or du-ectly supervised the I

activity being inspected, examined or Operations Quality Assurance Plan, Chapter 2.0, Revision 20 Page 12 Of 19

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

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

1.4.4 - refer to table coverage ofR.G. 1.74/ANSI N45.2.10. Same as full.

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

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

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

Operations Quality Assurance Plan, Chapter 2.0, Revision 20 Page 13 of 19

TABLE I PROGRAM COMMITMENTS R.G./ANSI STANDARD FULL PROGRAM BASIC PROGRAM ANSIN45.2.U, 1974(Con't.) 6.3 - Verification and checking of design may be accomplished through supervisory or management review/approval as provided for in 6.1.

Personnel will be requu-ed to consider items 1 through 19, but a documented checklist may not be required.

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

Assurance Terms and Definitions.

ANSIN45.2.10,1973 Same as R.G. 1.74 above. Same as full.

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

ANSIN45.2.9,1974 Section 5.6 - supplement the provisions of this section by providing for alternate Same as full.

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

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

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

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

ANSIN45.2.

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TABLE I PROGRAM COMMITMENTS R.G./ANSI STANDARD FULL PROGRAM BASIC PROGRAM ANSI N45.2.13, 1976(cont'd) 3.2.3 - When purchasing commercial-grade calibration services from calibration Same as full laboratories accredited by a nationally-recognized accrediting body, the procurement documents are not required to impose a quality assurance program consistent with 10CFR50, Appendix B. In such cases, accreditation may be accepted in lieu of the Purchaser imposing a QA Program consistent with 10CFR50, Appendix B, provided all of the following are met:

1) The accreditation is to ANSMSO/IEC 17025

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

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

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

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

6) The alternative method is limited to the domestic calibration service suppliers.

7) The alternative method is applicable to sub-suppliers ofcalibration service suppliers, provided the above conditions are met.

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

approval, completion of these activities after award of contract.

Operations Quality Assurance Plan, Chapter 2.0, Revision 20 Page 15 of 19

TABLE I PROGRAM COMMITMENTS R.G./ANSI STANDARD FULL PROGRAM BASIC PROGRAM ANSI N45.2.13, 1976(cont'd) 9.0 - This section will be implemented based on the scope, complexity and safety Same as full.

significance of the items being procured.

10.3.1 - This section will only be implemented as deemed necessary.

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

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

C.3a(l) - refer to table coverage ofR.G. 1.33 regarding audit frequency. Same as full.

Operations Quality Assurance Plan, Chapter 2.0, Revision 20 Page 16 of 19

TABLE I PROGRAM COMMITMENTS R.G./ANSI STANDARD FULL PROGRAM BASIC PROGRAM R.G. 1.144, rev. 1 (9/80) (cont'd) C.3.b(2) - When purchasing commercial-grade calibration services from Same as fall for commercial-grade calibration laboratories accredited by a nationally-recognized accrediting body, calibration services the accreditation process and accrediting body may be credited with carrying out a portion of the Purchaser's duties of verifying acceptability and effective STP will audit vendors only as deemed implementation of the calibration service supplier's quality assurance program. necessary. STP will perform biennial evaluations.

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

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

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

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

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

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

6) The alternative method is limited to the domestic calibration sendce suppliers.

7) The alternative method is applicable to sub-suppliers ofcalibration service suppliers, provided the above conditions are met.

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

Operations Quality Assurance Plan, Chapter 2.0, Revision 20 Page 17 Of 19

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

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

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

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

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

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

2.3.3.1 -refer to table coverage ofR.G 1.28. Same as fall.

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

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

Operations Quality Assurance Plan, Chapter 2.0, Revision 20 Page 18 Of 19

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

For ANSI Standards addressed by this table, and unless specific clarification or exception is mdicated, STP will treat ANSI requirements (i.e., "shall") as such - except in instances where the standard itself provides options or requires a graded approach - this notwithstanding the general applicability statements found in many standards (i.e., section 1.0)

Operations Quality Assurance Plan, Chapter 2.0, Revision 20 Page 19 of 19

SOUTH TEXAS PROJECT ELECTMC GENERATING STATION NUMBER REV.

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Chapter 8

OPERATIONS QUALITY ASSURANCE PLAN 19.0 ADMINISTRATIVE CONTROLS PAGE 1 OF 10 EFFECTIVE DATE 01-15-18 1.0 PURPOSE 1.1 The purpose of this chapter is to describe the administrative controls (as previously documented in the Technical Specifications) as related to quality assurance for the South Texas Project (STP).

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

3.0 DEFINITIONS 3.1 None

4.0 REFERENCES

4.1 OQAP Chapter 2.0, Table I 4.2 STP Technical Specifications 4.3 Updated Final Safety Analysis Report 4.4 OQAP Chapter 8, Control and Issuance of Documents 4.5 OQAP Chapter 14, Records Control 4.6 OQAP Chapter 15, Quality Oversight Activities 4.7 1 OCFR72, Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater Than Class C Waste 5.0 REQUIREMENTS 5.1 The Plant Operations Review Committee (PORC) shall function to advise the Plant General Manager on all matters related to nuclear safety.

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Chapter 8

OPERATIONS QUALITY ASSURANCE PLAN 19.0 ADMINISTRATIVE CONTROLS PAGE 2 OF 10 EFFECTWE DATE 01-15-18 5.1.1 The PORC shall be composed of six members, who shall be appointed in writing by the Plant General Manager from senior experienced onsite individuals, at the manager level or equivalent, representing each of the following disciplines: engineering, operations, chemistry, health physics, quality assurance/quality control and maintenance. The quality assurance/quality control representatives shall not be appointed as PORC Chairman.

5.1.2 The PORC Chairman shall be appointed in writing from among those members by the Plant General Manager. One of the members shall meet the requirements of Regulatory Guide 1.8 (Personnel Selection and Training - Revision 1-R), Radiation Protection Manager.

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

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

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

5.1.6 The PORC shall be responsible for:

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

5.1.6.2 Review of safety evaluations for (1) procedures, (2) changes to procedures, structures, components, or systems, and (3) tests or experiments completed under the provisions of 10CFR50.59 to verify that such actions did not require prior Nuclear Regulatory Commission (NRC) approval.

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

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Chapter 8

OPERATIONS QUALITY ASSURANCE PLAN 19.0 ADMINISTRATIVE CONTROLS PAGE 3 OF 10 EFFECTIVE DATE 01-15-18 5.1.6.4 Review of all required programs by Technical Specification 6.8 and the Technical Requirements Manual 6.8 and changes thereto.

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

5.1.6.6 Review of all REPORTABLE EVENTS.

5.1.6.7 Review of reports of significant operating abnormalities or deviations from normal and expected performance of plant equipment or systems that affect nuclear safety.

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

5.1.6.9 Review of Security Plans: Physical Security Plan, Training and Qualification Plan, Safeguards Contingency Plan, Cyber Security Plan, and implementing procedures and changes thereto.

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

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

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

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

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Chapter 8

OPERATIONS QUALITY ASSURANCE PLAN 19.0 ADMINISTRATIVE CONTROLS PAGE 4 OF 10 EFFECTIVE DATE 01-15-18 5.1.6.14 Review of any accidental, unplanned, or uncontrolled release of liquid or gaseous radioactive effluents to the offsite environment and groundwater contamination events resulting in offsite notifications. The review shall include the preparation of reports covering evaluation, recommendations, and disposition of the corrective action(s) to prevent recurrence and the forwarding of these reports to the Plant General Manager and to the SMT.

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

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

5.1.6.17 Review of activities related to the Independent Spent Fuel Storage Installation and the Dry Cask Storage System pursuant to the provisions of 10CFR72.

5.1.7 The PORC shall recommend in writing to the Plant General Manager approval or disapproval of items considered under section 5.1.6.1 through 5.1.6.5 prior to their implementation, and items considered under sections 5.1.6.9 through 5.1.6.12 and 5.1.6.17.

5.1.8 The PORC shall render determinations in writing with regard to whether or not each item considered under sections 5.1.6.1 through 5.1.6.5 and 5.1.6.15 may require prior NRC approval under the provisions of 10CFR50.59.

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

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Chapter 8

OPERATIONS QUALITY ASSURANCE PLAN 19.0 ADMINISTRATIVE CONTROLS PAGE 5 OF 10 EFFECTWE DATE 01-15-18 5.1.10 The PORC shall maintain written minutes of each PORC meeting that, at a minimum, document the results of all PORC activities performed under the responsibility provisions of this chapter. Copies shall be provided to the President and Chief Executive Officer and the appropriate organizational unit.

5.2 Appropriate organizational units shall function to provide independent review of designated activities as required by ANSI N18.7-1976/ANS-3.2, Sections 4.3, 4.3.1,4.3.3, and 4.3.4.

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Chapter 8

OPERATIONS QUALITY ASSURANCE PLAN 19.0 ADMINISTRATIVE CONTROLS PAGE 6 OF 10 EFFECTWE DATE 01-15-18 5.2.1 Staff personnel required to perform these independent reviews shall collectively have the experience and competence to review operational activities in the following areas:

5.2.1.1 Nuclear power plant operations; 5.2.1.2 Nuclear engineering; 5.2.1.3 Chemistry and radiochemistry; 5.2.1.4 Metallurgy; 5.2.1.5 Instrumentation and control; 5.2.1.6 Radiological safety; 5.2.1.7 Mechanical and electrical engineering; 5.2.1.8 Civil engineering; 5.2.1.9 Training; 5.2.1.10 Nuclear assurance; 5.2.1.11 Nuclear licensing; 5.2.1.12 Plant security, and; 5.2.1.13 Environmental impact 5.2.1.14 Nondestructive testing

\0 00 5.2.1.15 Dry cask storage operations 0 a

Note: If sufficient expertise is not available from within the STPNOC for the areas noted above, appropriate expertise shall be brought to bear in the independent reviews through the use of outside consultants.

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

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Chapter 8

OPERATIONS QUALITY ASSURANCE PLAN 19.0 ADMINISTRATIVE CONTROLS PAGE 7 OF 10 EFFECTIVE DATE 01-15-18 5.2.3 Appropriate organizational units shall be responsible for the review of:

5.2.3.1 The safety evaluations for: (1) changes to procedures, equipment, or systems; and (2) tests or experiments completed under the provision of 10CFR50.59, to verify that such actions did not require prior NRC approval; 5.2.3.2 Proposed changes to procedures, equipment, or systems which require prior NRC approval under the provisions of 10CFR50.59; 5.2.3.3 Proposed tests or experiments which require prior NRC approval under the provisions of 10CFR50.59; 5.2.3.4 Proposed changes to Technical Specifications or the Operating License; 5.2.3.5 Violations of Codes, regulations, orders, Technical Specifications, license requirements, or of internal procedures or instructions having nuclear safety significance; 5.2.3.6 Significant operating abnormalities or deviations from normal and expected performance of unit equipment that affect nuclear safety; 5.2.3.7 All REPORTABLE EVENTS; 5.2.3.8 All recognized indications of an unanticipated deficiency in some aspect of design or operation of structures, systems, or components that could affect nuclear safety; and 5.2.3.9 Reports and meeting minutes of the PORC.

5.2.3.10 Review of activities related to the Independent Spent Fuel Storage Installation and the Dry Cask Storage System pursuant to the provisions of 10CFR72.

5.2.4 Reports of audits of unit activities shall be reviewed by the Senior Management Team.

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Chapter 8

OPERATIONS QUALITY ASSURANCE PLAN 19.0 ADMINISTRATIVE CONTROLS PAGE 8 OF 10 EFFECTIVE DATE 01-15-18 5.2.5 Records of organizational unit independent review activities shall be prepared, approved, and distributed as indicated below:

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

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

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

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

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

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

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Chapter 8

OPERATIONS QUALITY ASSURANCE PLAN 19.0 ADMINISTRATIVE CONTROLS PAGE 9 OF 10 EFFECTWE DATE 01-15-18 5.3.1.2 Proposed changes or modifications to systems or equipment that affects nuclear safety shall be reviewed as designated by the Plant General Manager. Each such modification shall be reviewed by an individual/group other than the individual/group who designed the modification, but who may be from the same organization as the individual/group who designed the modification.

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

Each such test or experiment shall be reviewed by an individual/group other than the individual/group who prepared the test or experiment but who may be from the same organization as the individual/group who prepared the test or experiment.

5.3.1.4 The Plant General Manager or the Plant General Manager's designee shall approve, prior to implementation, each proposed test and experiment that affects nuclear safety and is not described in the Final Safety Analysis Report, and each modification to systems or equipment that affects nuclear safety.

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

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

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

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

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Chapter 8

OPERATIONS QUALITY ASSURANCE PLAN 19.0 ADMINISTRATIVE CONTROLS PAGE 10 OF 10 EFFECTIVE DATE 01-15-18 6.0 DOCUMENTATION 6.1 Procedures which are generated as required by this chapter shall identify the records which are required to implement and document those activities. The records shall be controlled in accordance with the requirements of this chapter and Reference 4.4.

7.0 ATTACHMENTS 7.1 None

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Chapter OPERATIONS QUALITY ASSURANCE PLAN 20.0 1

DRY CASK STORAGE SYSTEM and INDEPENDENT SPENT FUEL STORAGE INSTALLATION PAGE 1 OF 16 EFFECTFVE DATE 2-1-14 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, and components regulated by 10 CFR Part 72.

2.0 SCOPE 2.1 The policies and procedures identified within this chapter will form the

<0 basis for plant-life operation of the STP DCSS and ISFSI. The 00 0

responsibility and authority for the establishment and execution of the <;.

Quality Plan for the operation of the STP DCSS and ISFSI will be 0 retained by STP Nuclear Operating Company (STPNOC) and described in the OQAP.

2.2 This program is designed to meet the requirements of 10 CFR Part 72, Subpart G for a quality assurance program.

3.0 DEFINITIONS 3.1 Important to Safety CITS) Structures, Systems, and Components ^0 00 CSSCs) - those features of the DCSS/ISFSI whose functions are: 0 a

to maintain the conditions required to store spent fuel safely; to prevent damage to the spent fuel container during handling and storage; and

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Chapter OPERATIONS QUALITY ASSURANCE PLAN 20.0 1

DRY CASK STORAGE SYSTEM and INDEPENDENT SPENT FUEL STORAGE INSTALLATION PAGE 2 OF 16 EFFECTWE DATE 2-1-14 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, Categor^B, and Category C - as described below:

Classification Importance to Description Category Safety A Critical to Safe Category A items include structoes, 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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Chapter OPERATIONS QUALITY ASSURANCE PLAN 20.0 1

DRY CASK STORAGE SYSTEM and INDEPENDENT SPENT FUEL STORAGE INSTALLATION PAGE 3 OF 16 EFFECTWE DATE 2-1-14 3.4 Basic, or Fundamental, Safety Criteria - the following are considered ^0 00 to be the basic nuclear safety criteria for design of the DCSS/ISFSI. 0 (NUREG-1567): <:.

0 3.4.1 IVtaintain 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 CC of Q - 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 1 OCFR72, 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 ofCompliance/FSAR) 4.3 Regulatory Guide 7.1 0, Establishing Quality Assurance Programs for Packaging used in Transport of Radioactive Material 4.4 10CFR50.55a, Codes and Standards 4.5 10CFR20, Appendix G.

4.6 1 OCFR72.48, Changes, Tests and Experiments 4.7 SNT-TC-1A, American Society for Nondestructive Testing; Recommended Practice

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Chapter OPERATIONS QUALITY ASSURANCE PLAN 20.0 1

DRY CASK STORAGE SYSTEM and INDEPENDENT SPENT FUEL STORAGE INSTALLATION PAGE 4 OF 16 EFFECTIVE DATE 2-1-14 4.8 ANSI/ASNT CP-189, ANST Standard for Qualification and Certification ofNondestmctive Testing Personnel 4.9 NUREG/CR-6407, Classification of Transportation Packaging and Dry Spent Fuel Storage System Components According to Importance to Safety 4.10 NOC-AE-12002873, Independent Spent Fuel Storage Installation (STI

1. 33563580) 4.11 NUREG 1 567, Standard Review Plan for Spent Fuel Dry Storage Facilities 5.0 REQUIREMENTS 5.1 DC SS/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.

<0 00 0

§ 5.2.2 The determination of the ISFSI and dry cask 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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Chapter OPERATIONS QUALITY ASSURANCE PLAN 20.0 1

DRY CASK STORAGE SYSTEM and INDEPENDENT SPENT FUEL STORAGE INSTALLATION PAGE 5 OF 16 EFFECTFVE DATE 2-1-14 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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Chapter OPERATIONS QUALITY ASSURANCE PLAN 20.0 1

DRY CASK STORAGE SYSTEM and INDEPENDENT SPENT FUEL STORAGE INSTALLATION PAGE 6 OF 16 EFFECTIVE DATE 2-1-14 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 structires, 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 stmctures, components, 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.

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Chapter OPERATIONS QUALITY ASSURANCE PLAN 20.0 1

DRY CASK STORAGE SYSTEM and INDEPENDENT SPENT FUEL STORAGE INSTALLATION PAGE 7 OF 16 EFFECTWE DATE 2-1-14 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 CofC 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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Chapter OPERATIONS QUALITY ASSURANCE PLAN 20.0 1

DRY CASK STORAGE SYSTEM and INDEPENDENT SPENT FUEL STORAGE INSTALLATION PAGE 8 OF 16 EFFECTIVE DATE 2-1-14 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 SSCs 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:

5.4.4.1 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 10CFR71, 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.

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV.

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Chapter OPERATIONS QUALITY ASSURANCE PLAN 20.0 1

DRY CASK STORAGE SYSTEM and INDEPENDENT SPENT FUEL STORAGE INSTALLATION PAGE 9 OF 16 EFFECTIVE DATE 2-1-14 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 perfomied 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.

NO.

Chapter OPERATIONS QUALITY ASSURANCE PLAN 20.0 1

DRY CASK STORAGE SYSTEM and INDEPENDENT SPENT FUEL STORAGE INSTALLATION PAGE 10 OF 16 EFFECTFVE DATE 2-1-14 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-confonnance 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 1 OCFR72, 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 Nondestmctive examinations associated with DCS S 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.

NO.

Chapter OPERATIONS QUALITY ASSURANCE PLAN 20.0 1

DRY CASK STORAGE SYSTEM and INDEPENDENT SPENT FUEL STORAGE INSTALLATION PAGE 11 OF 16 EFFECTIVE DATE 2-1-14 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 CofC and 10CFR72, Subpart G requirements.

5.9.3 NDE performed on DCSS shall be in compliance with referenced ASME Boiler & Pressure Vessel Code, Sections Ill 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 ofC/FSAR) and have not been inadvertently bypassed or that SSC are not inadvertently operated outside of specified requirements.

5.10.3 Personnel performing examinations and tests shall be qualified as required by OQAP, Chapter 4.0 Qualification, Training and Certification of personnel.

5.10.4 The 1 OCFR72 C of C, for the storage systems in use at the ^0 00 STP DCSS/ISFSI establishes technical specifications that 0 0

ensure the systems are loaded, transferred, and maintained functional for safe storage.

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV.

NO.

Chapter OPERATIONS QUALITY ASSURANCE PLAN 20.0 1

DRY CASK STORAGE SYSTEM and INDEPENDENT SPENT FUEL STORAGE INSTALLATION PAGE 12 OF 16 EFFECTWE DATE 2-1-14 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 DCSS 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 ^0 00 CofC for DCSS/ISFSI used at the STPEGS. 0 a

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.

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV.

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Chapter OPERATIONS QUALITY ASSURANCE PLAN 20.0 1

DRY CASK STORAGE SYSTEM and INDEPENDENT SPENT FUEL STORAGE INSTALLATION PAGE 13 OF 16 EFFECTWE DATE 2-1-14

^0 00 5.13.3 This program includes the storage of spent fuel and reactor- 0 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

^0 facility licensed under 10CFR72 (the DCSS/ISFSI), 00 0

10CFR72, Subpart G quality assurance requirements apply.

0 5.14 Records 5.14.1 Record control is in acfcordance 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 terminates the license or C of C as required by 10CFR72.174.

5.14.3 The term lifetime record is applicable to both the 1 OCFR50 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 bumup histories.

SOUTH TEXAS PROJECT ELECTMC GENERATING STATION NUMBER REV.

NO.

Chapter OPERATIONS QUALITY ASSURANCE PLAN 20.0 1

DRY CASK STORAGE SYSTEM and INDEPENDENT SPENT FUEL STORAGE INSTALLATION PAGE 14 OF 16 EFFECTIVE DATE 2-1-14 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 10CFR72.212.

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.

NO.

Chapter OPERATIONS QUALITY ASSURANCE PLAN 20.0 1

DRY CASK STORAGE SYSTEM and INDEPENDENT SPENT FUEL STORAGE INSTALLATION PAGE 15 OF 16 EFFECTWE DATE 2-1-14 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 ofDCSS/ISFSI important to safety functions will be performed on a nominal biennial frequency to ensure the \D 00 requirements of the 10CFR72 licensed operation provisions 0 contained within the Certificate of Compliance for the 0

storage system(s) in use and applicable license conditions are maintained.

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV.

NO.

Chapter OPERATIONS QUALITY ASSURANCE PLAN 20.0 1

DRY CASK STORAGE SYSTEM and INDEPENDENT SPENT FUEL STORAGE ENSTALLATION PAGE 16 OF 16 EFFECTIVE DATE 2-1-14 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