NOC-AE-18003599, Submittal of Operations Quality Assurance Plan Change QA-087

Submittal of Operations Quality Assurance Plan Change QA-087

ML18269A354
Person / Time
Site:	South Texas
Issue date:	09/24/2018
From:	Gerry Powell South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-18003599, STI: 34725727
Download: ML18269A354 (14)

Text

Nuclear Operating Company South Texas Project Electric Generating Station RO. Box 289 Wadsworth, Texas 77483 September 24, 2018 NOC-AE-18003599 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 Subm itta I of Ope ratio ns Q ualitv^Ass u rance Plan Change QA-087 STP Nuclear Operating Company (STPNOC) submits the attached change to revision 23 of the Operations Quality Assurance Plan (OQAP). The purpose of this change is to add clarifying information regarding Organizational responsibilities (Affected Chapter 1.0) for weld inspections and non-destructive examination (NDE). This change states that Engineering is responsible for the performance of weld inspections and NDE, and Nuclear Oversight (Quality) has responsibility for independent oversight of these activities. This change strictly provides clarification regarding associated organizational responsibilities and does not represent a reduction in commitment. Therefore, the attached change does not require NRC approval prior to implementation in accordance with the provisions of 10 CFR 50.54(a)(3).

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.

G. T. Powell President & CEO Attachments: 1.10 CFR 50.54(a) Evaluation for Change QA-087

2. Summary of Change QA-087

3. Operations Quality Assurance Plan Change QA-087 STI:34725727

NOC-AE-18003599 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 D. S. Nuclear Regulatory Commission P. 0. Box 289, Mail Code: MN116 Wadsworth,TX 77483

NOC-AE-18003599 Attachment 1 10 CFR 50.54(a) Evaluation for Change QA-087

ATTACHMENT 10CFR50.54 (a) EVALUATION QA-087 Page 1 of 1 This OQAP change adds clarifying discussion regarding Organizational responsibilities (Affected Chapter 1.0) involving weld inspections and non-destructive examination (NDE). This change describes that Engineering is responsible for the performance of weld inspections and NDE, while Nuclear Oversight (Quality) has responsibility for independent oversight of these activities. This change strictly provides clarification regarding associated organizational responsibilities, and as such does not represent a reduction in commitment and therefore does not require NRC approval prior to implementation in accordance with the provisions of 10CFR50.54(a)(3).

NOC-AE-18003599 Attachment 2 Summary of Change QA-087

CHANGE QA-087

SUMMARY

OF CHANGES SECTIONS (TEXT) WITH CHANGES IN BOLD TYPE CHAPTER LOCATION ACTION TEXT TOC CH 1.0 INSERT QA-087 CH 1.0 5.3.3 INSERT (includes NDE and weld inspections, ref. CR 18-7326) 5.4.1.1 DELETE examinations 5.4.1.1 mSERT and weld inspections

NOC-AE-18003599 Attachment 3 Operations Quality Assurance Plan Change QA-087

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV.

NO.

Chapter OPERATIONS QUALITY ASSURANCE PLAN TABLE OF 23 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 QA-087 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 Control and Issuance of Documents 7 2-1-14 9.0 Control of Material 7 2-1-14 10.0 Inspection 12 2-1-14 11.0 Test Control 9 2-1-14 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

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV.

NO.

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 - Repairs 11 2-1-14 and Replacements 18.0 ASME Code Section XI - Inservice 12 2-1-14 Inspection and Testing 19.0 Administrative 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

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV.

NO.

Chapter OPERATIONS QUALITY ASSURANCE PLAN 1.0 19 ORGANIZATION PAGE 1 OF 5 EFFECTIVE DATE 01-15-18 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 Executive Vice President and Chief Nuclear Officer, the Executive Vice President and Chief Administrative Officer, and the Executive Vice President and Chief Financial Officer. 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 Executive Vice President and Chief Nuclear Officer is responsible for implementing quality program requirements applicable to the following functions:

generation, engineering and projects. The management of these functions report to the Executive Vice President and Chief Nuclear Officer.

SOUTH TEXAS PROJECT ELECTMC GENERATING STATION NUMBER REV.

NO.

Chapter OPERATIONS QUALITY ASSURANCE PLAN 1.0 19 ORGANIZATION PAGE 2 OF 5 EFFECTIVE DATE 01-15-18 5.3.1 The Senior Vice President, Operations is responsible for implementing quality program requirements applicable to the following function:

Projects (Out/PIP/PMPI). The management of this function reports to the Senior Vice President, Operations.

5.3.1.1 The General Manager, Projects (Out/PIP/PMPI) is responsible for implementing quality program requirements applicable to the following functions: strategic projects, projects, outage management. Spent Fuel Management Project, major, and corporate projects. The management of these functions report to the General Manager, Projects (Out/PIP/PMPI).

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

5.3.2.1 The Plant General Manager has prime responsibility for the safe operations of the units. The plant staff, under the direction of the Plant General Manager, 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.

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

§ r-design engineering, testing/program engineering (includes NDE and 00 Q

weld inspections, ref: CR 18-7326), systems engineering, maintenance engineering, nuclear fuel & analysis (includes risk management), and engineering projects. The management of these functions report to the General Manager, Engineering.

SOUTH TEXAS PROJECT ELECTMC GENERATING STATION NUMBER REV.

NO.

Chapter OPERATIONS QUALITY ASSURANCE PLAN 1.0 19 ORGANIZATION PAGE 3 OF 5 EFFECTIVE DATE 01-15-18 5.3.3.1 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, and 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.

5.4 The Executive Vice President and Chief Administrative Officer is responsible for implementing quality program requirements applicable to the following functions:

corporate services, quality assurance, plant protection, emergency response, access authorization, fitness for duty, and regulatory affairs. The management of these functions report to the Executive Vice President and Chief Administrative Officer.

5.4.1 The Manager, Nuclear Oversight is responsible for implementing quality program requirements applicable to quality assurance.

5.4.1.1 The Manager, Nuclear Oversight 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

SOUTH TEXAS PROJECT ELECTMC GENERATING STATION NUMBER REV.

NO.

Chapter OPERATIONS QUALITY ASSURANCE PLAN 1.0 19 ORGANIZATION PAGE 4 OF 5 EFFECTIVE DATE 01-15-18 Independent oversight activities, including audits, independent assessments, evaluations, surveillances, performance i

t~~

00 monitoring, inspections, independent oversight ofNDE and 0 weld inspections, vendor oversight, and administration of organizational unit independent review activities.

5.4.1.2 The Manager, Nuclear Oversight, at his discretion, has unfettered access to the President and Chief Executive Officer and the Board of Directors.

5.4.1.3 The Manager, Nuclear Oversight has 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.

5.4.2 The General Manager, Corporate Services is responsible for implementing quality program requirements applicable to the following functions: information technology, cyber security, records management and technical support services. The management of these functions report to the General Manager, Corporate Services.

5.4.3 The Manager, Plant Protection/Emergency Response is responsible for implementing quality program requirements applicable to plant protection, emergency response, fitness for duty and access authorization. The management of these functions report to the Manager, Plant Protection /Emergency Response.

5.5 The Executive Vice President and Chief Financial Officer is responsible for implementing quality program requirements applicable to contracts &

procurement. The management of this function reports to the Executive Vice President and Chief Financial Officer.

SOUTH TEXAS PROJECT ELECTMC GENERATING STATION NUMBER REV.

NO.

Chapter OPERATIONS QUALITY ASSURANCE PLAN 1.0 19 ORGANIZATION PAGE 5 OF 5 EFFECTWE DATE 01-15-18 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