ST-HL-AE-1120, Forwards Rev 17 to QA Program Description for Design & Const Phase & Rev 8 to ETR-1001, Nuclear QA Program Manual, Per 10CFR50.55(f)(3)

Forwards Rev 17 to QA Program Description for Design & Const Phase & Rev 8 to ETR-1001, Nuclear QA Program Manual, Per 10CFR50.55(f)(3)

ML20134P095
Person / Time
Site:	South Texas
Issue date:	07/27/1984
From:	Oprea G HOUSTON LIGHTING & POWER CO.
To:	Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20134P098	List: ML20134P128 ML20134P148 ST-HL-AE-1120, Forwards Rev 17 to QA Program Description for Design & Const Phase & Rev 8 to ETR-1001, Nuclear QA Program Manual, Per 10CFR50.55(f)(3)
References
ST-HL-AE-1120, NUDOCS 8509060133
Download: ML20134P095 (16)

Text

-

The Light COE y flouston 1iglaing & Iwer ito. tw 1700 lionuon.'leus 77001 (713) 22p21I i

July 27, 1984 ST-HL-AE-1120 File Nc: G9.11/Q39.

Mr. John T. Collins 1 g@MOMMi 7 Regional Administrator, Region IV j Nuclear Regulatory Commission i![(3-ISM i 611 Ryan Plaza Drive, Suite 1000 h6 L~

Arlington, TX 76011 ML i South Texas Project Units 1 & 2 Docket Nos. STN 50-498, STN 50-499 Quality Assurance Program for the Design and Construction Phase of the South Texas Project

Dear Mr. Collins:

Enclosed is Revision 7 of the Quality Assurance Program Description (QAPD) for the design and construction phase of the South Texas Project (STP). This revision is being submitted in accordance with the require-ments of 10CFR50.55(f)(3).

Included in this submittal are complete replacerrents for Part A, Houston Lighting and Power Company (HL&P) QAPD, and Part C, Ebasco Nuclear Quality Assurance Program for the South Texas Project. Replace-ment pages for Part B, Bechtel Energy Corporation QAPD for the South Texas Project are also included, along with correspondence between Bechtel Power Corporation and the NRC concerning various organizational changes. This should be used in conjunction with the Bechtel Topical Report BQ-TOP-1, Revision 3A.

Part A has been revised to define a reorganization of the Engineer-ing and Construction groups; to include position descriptions of various personnel either not previously discussed or new positions; to describe the change in responsibility for raterial control; to clarify the extent of Stop Work authority for QA personnel; and to respond to NRC questions on previous revisions of the QAPD. Specifically:

A clarification of the HL&P position on ANSI N45.2.6/ Regulatory Guide 1.58 for the design and construction pLase.

8509060133 040727 PDR ADOCK 05000490 A PDR y )-

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ilouston Lighting & Power Company July 27, 1984 ST-HL-AE-1120 File No: G9.11/Q39.

Page 2 A clarification of the general categories of documents to be trended, and that approved procedures would specify the fre-quency of trending. This comitment was agreed to by our Mr. T. J. Jordan, Program Quality Assurance Manager (PQAM), and personnel from the Region IV office on June 26, 1984.

Part B has been revised to incorporate a clarification of Bechtel's PQAM involvement in review of turnover packages; to include additional design control features for work performed by the Site Engineering organization; to include revised charts to portray the actual orga-nization versus a typical organization; and to respond to NRC questions

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on previous revisions of the QAPD. Also included is a cover sheet explaining the correspondence included with the submittal of Part B, which amends BQ-TOP-1, Rev. 3A.

Part C has been revised to reflect the approval of Revision 12 of the Ebasco Corporate Manual ETR-1001; to reflect the extensive changes in the corporate structure; to include Site QA activities as a means of evaluating the QA Program effectiveness; to indicate that the Assistant Superintendents have Stop Work authority; to include the requirements and responsibilities for control of field sketches; to reflect a change >

in Ebasco's responsibility on recommended disposition of nonconformance reports; to add in that Deficiency Notices shall be issued for t

deficiencies which violate the restrictions of the manual or which are detected during final inspection; to clarify activities related to the audit program; to clarify the requirements for narking of materials; to clarify the traceability of calibration standards; and to respond to NRC questions on previous revisions of the QAPD. Although changes to Part C are noted by Revision 7 change bars in the right margin, the revision status in the upper right hand corner of each individual section may differ from the Revision 7 indicators in the body of the document and are not applicable to this submittal.

2 These changes to Parts A, B, and C do not reduce the comitments contained in Revision 6 of the QAPD. The revised QAPD continues to satisfy criteria for 10CFR50 Appendix B. The changes described in Revision 7 of the QAPD are being implemented immediately. Attached is a detailed description of the changes, including a basis for concluding that the previous commitments have not been reduced. In addition to the changes sunnarized above, a number of editorial changes have been made to the QAPD.

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Ilouston Lighting & Power Company July 27, 1984 ST-HL-AE-1120 File No: G9.11/Q39.

Page 3 Copies of Revision 7 to the QAPD are also being submitted to the NRC Resident Inspector at the South Texas Project site and to the NRC Document Control desk as requested by 10CFR50.55(f)(3)(1).

If you have any questions, please contact Mr. Michael E. Powell at (713)993-1328.

Very tru y yours, i

s' / /

. .f rea r .

' Exec ive VTce President JWE/BSN:sk Attach *ent: QAPD for the Design and Construction Phase of the South Texas Project (Revision 7)

liouston Lighting & Power Company July 27, 1984 ST-HL-AE-1120 File No: G9.11/Q39.

Page 4 cc:

Darrell G. Eisenhut, Director Brian E. Berwick, Esquire Division of Licensing Assistant Attorney General for Office of Nuclear Reactor Regulation the State of Texas U.S. Nuclear Regulatory Comission P. O. Box 12548, Capitol Station Washington, DC 20555 Austin, TX 78711 Victor Nerses, Project Manager Lanny Sinkin U.S. Nuclear Regulatory Comission Citizens Concerned About Nuclear Power 7920 Norfolk Avenue 114 W. 7th, Suite 220 Bethesda, PD 20016 Austin, TX 78701 D. P. Tomlinson Robert G. Perlis, Esquire Resident Inspector / South Texas Project Hearing Attorney c/o U.S. Nuclear Regulatory Comission Office of the Executive Legal Director P. O. Box 910 U.S. Nuclear Regulatory Comission Bay City, TX 77414 Washington, DC 20555 M. D. Schwarz, Jr., Esquire Charles Bechhoefer, Esquire Baker & Botts Chairman, Atomic Safety & Licensing Board One Shell Plaza U.S. Nuclear Regulatory Comission .

Houston, TX 77002 Washington, DC 20555 J. R. Newman, Esquire Dr. James C. Lamb, III Newman & Holtzinger, P.C. 313 Woodhaven Road 1025 Connecticut Avenue, N.W. Chapel Hill, NC 27514 Washington, DC 20036 Judge Ernest E. Hill Director, Office of Inspection Hill Associates and Enforcement 210 Montego Drive U.S. Nuclear Regulatory Comission Danville, CA 94526 Washington, DC 20555 William S. Jordan, III, Esquire E. R. Brooks /R. L. Range Harmon & Weiss Central Power & Light Company 1725 I Street, N.W.

P. O. Box 2121 Suite 506 Corpus Christi, TX 78403 Washington, DC 20006 H. L. Peterson/G. Pokorry Citizens foi Equitable Utilities, Inc.

City of Austin c/o Ms. Peggy Buchorn P. O. Box 1088 Route 1 Box 1684 Austin, TX 78767 Brazoria, TX 77422 J. B. Poston/A. vonRosenberg City Public Service Board P. O. Box 1771 San Antonio, TX 78296 Revised 04/03/84 1

QUALITY ASSURANCE PROGRAM DESCRIPTION FOR THE DESIGN AND CONSTRUCTION OF THE SOUTH TEXAS PROJECT REVISION 7 CHANGES i

Part A, Houston Lighting & Power Company (HL&P QAPD) o Section 1.0 was rearranged and correspondingly renumbered to reflect a major reorganization of the Engineering and Construction organizations; and other changes. This change was to better coordinate the activities of the two groups and is thus an upgrade. Change bars were not used to indicate a new paragraph number; below is a comparison of new paragraph numbers to old paragraph .1 umbers:

New No. Old No. New No. Old No. New No. Old No.

l 1.1 1.1 1.5.19 New 1.2 1.2 1.5.8 1.3.13 1.5.20 New 1.3 1.3 1.5.9 1.3.15 1.6 1.3.10 1.4 New 1.5.10 1.3.16 1.7 1.3.2 1.5 1.3.1 1.5.11 1.3.12 1.7.1 1.3.3 1.5.1 1.3.11 1.5.12 1.3.17 1.7.2 1.3.5 1.5.2 New 1.5.13 1.3.24 1.7.3 1.3.8 1.5.3 1.3.18 1.5.14 1.3.25 1.7.4 1.3.6 1.5.4 New 1.5.15 1.3.26 1.7.5 1.3.7 1.5.5 1.3.21 1.5.16 New 1.7.6 1.3.9 1.5.6 1.3.14 1.5.17 New 1.7.7 1.3.4 1.5.7 1.3.23 1.5.18 New 1.8 1.4 The positions of Startup Manager (1.3.19), Startup General Supervisor (1.3.20) and Supervising Site Engineer, Construction Support (1.3.22) were

deleted.

f o Paragraph 1.3.6: Changed " Project Quality Assurance Program" to " Project Quality Program Manual" to reflect actual title of Bechtel's QA manual.

Clarification; no reduction in commitment has occurred.

o Paragraph 1.4: Added in a position description for the Executive Vice President, Nuclear Group. This is an upgrade; no reduction in commitment has occurred.

l o Paragraph 1.5: Editorial change to enhance readability; and Manager, Nuclear Engineering was promoted to General Manager. Clarification; no reduction in commitment has occurred.

o Paragraph 1.5.2: Added a new position of Deputy Project Manager, on site, to coordinate the activities between Construction and Startup. This is an upgrade (see first comment); no reduction in commitment has occurred.

o Paragraph 1.5.3: Site Manager now reports to the Deputy Project Manager. ,

This is an upgrade (see first connent); no reduction in commitment has occurred.

1 o Paragraph 1.5.4: Added a new position of Site Support Services Manager to provide direction to the activities necessary to support Construction; also, clarified responsibilities of the Material Control personnel. This is an upgrade (see first coment); no reduction in comitment has occurred.

o Paragraph 1.5.5: Position title change from Construction Superintendent, Nuclear Construction to Site Engineering and Construction Manager. This is -

an upgrade (see first comment); no reduction in comitment has occurred.

o Paragraph 1.5.6: Supervising Site Engineer, Site Engineering, now reports to the Site Engineering and Construction Manager; additionally, the SPE, Site Engineering is now responsible for monitoring of prime contractor's construction engineering groups. This is an upgrade (see first coment);

no reduction in comitment has occurred, o Paragra3h 1.5.7: Deleted the word " Area" from position titles; addition-ally, t1ey now report to the Site Engineering and Construction Manager.

New position of Startup Superintendent to provide an interface for turn-over. This is an upgrade (see first coment); no reduction in comitment has occurred.

o Paragraphs 1.5.9 and 1.5.10: Nuclear Licensing became STP Licensing.

Clarification; no reduction in comitment has occurred, o Paragraph 1.5.12: Changed "He is ..." to "The Manager, RMIP is ..." to eliminate the gender reference. Clarification; no reduction in commitment has occurred, o Paragraph 1.5.14: Moved responsibility for the comprehensive Material Control Program to Site Support Services Manager, and added a responsibil-ity for stores operations. This is an upgrade; no reduction in comitment has occurred.

o Paragraphs 1.5.16, 1.5.17, 1.5.18, 1.5.19, and 1.5.20: Added in position descriptions for the General Manager, Nuclear Engineering; Manager, Nuclear 4

Licensing; Manager, Nuclear Fuel; Manager, Nuclear Services; and Manager, Engineering Assurance. This is an upgrade; no reduction in comitment has occurred.

, o Paragraph 1.7: Added a note to explain why the responsibilities of the j Operations QA Manager are not containn in the QAPD. Clarification; no i reduction in comitment has occurred.

o Paragraphs 1.7.1, 1.7.2, 1.7.3, 1.7.4, 1.7.5, and 1.7.6: Clarified the extent of Stop Work Authority for the Project QA Manager and Supervisors.

No reduction in comitment has occurred.

! o Paragraph 1.7.7: The Support QA Audits and Technical Services groups were combined into one group - the Vendor Evaluation group. This is an upgrade; no reduction in comitment has occurred i

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J o Section 8.0: The requirements for material traceability were clarified in response to an NRC comment concerning Revision 5 of the QAPD. This is an upgrade; no reduction in commitment has occurred.

o Section 16.0: A clarification of the general categories of documents to be trended, and that approved procedures will specify the frequency of trend-ing; this is in response to an NRC comment concerning Revision 6 of the QAPD. No reduction in commitment has occurred.

o Table 1, Exception Note #1: Clarification on when correlation tests would be required. No reduction in commitment has occurred.

o Table 1, Exception Note #12: Removed the word " material", thus removing the possibility that " components" would be excluded. This is an upgrade; no reduction in commitment has occurred.

o Table 1 Exception Note #33: Removed a previous exception note related to start-up and operational activities; the portion relating to HL&P Vendor Surveillance certification requirements is unchanged. This is in response to an NRC comment concerning Revision 5 of the QAPD. No reduction in commitment has occurred.

o Figure 1: Completely redrawn to be consistent with the text of Sec-tion 1.0. Clarification; no reduction in commitrent has occurred.

o Fisure 2: Added the position of Deputy Project Manager. Clarification; no recuction in commitment has occurred.

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DESCRIPTION OF REVISION TO THE SOUT'i TEXAS PROJECT QUALITY ASSURANCE PROGRAM DESCRIPTION PART B REVISION 7 Section 1 - Page 2, Paragraph 1.6.1, Items 4 and 5 Item 4 Delete phrase telative to Project Quality Assurance Manager review of completed quality verification record packages. (This review is clarified in the new Item 5, described immediately below)

Iteg,1 Add Project Quality Assurance Manager (PQAM) involvement in turnover packages and clarify that selected quality verification record packages are reviewed. This change is classified as a clarification to the previous program.

Section 3 - page 30. Paragraph 3 Response to NRC Comment This revised paragraph adds the design control features currently.in place at the design office to any design work performed by Site Engineering at the site. In addition, detailing work performed by contractors is clar-ified and requires checking. Therefore, this revision is classified as an upgrade to the previous program.

Appendix A

! This revised appendix aligns Part B of the QAPD with Part A for ANSI Standard and Regulatory Guide compliance, and provides clarifications.

Therefore, this revision is classified as an upgrade to the previous program.

j Appendix A - Page A-4, Item 2, Response to NRC Comment

! This revision, deleting the word " material", removes the possibility that the previous wording excluded " components". Therefore, this revision is classified as an upgrade to the previous program.

, Figure 9 - Page 67 Response to NRC Comment j This actual chart replaces a Typical Chart and as such is classified as an upgrade to the previous program.

l Figure 11 - Page 12 This revised chart adds positions and reflects new reporting relationships.

This revision is classified as an upgrade to the previous program.

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a bg Page 1 of 8 Revisions to STP QAPD Part C Revision 6 DESCRIPTION OF REVISIONS TO THE SOUTH TEXAS PROJECT QUALITY ASSURANCE PROGRAM DESCRIPTION PART C REVISION 6 DATED 3/26/84 TABLE OF CONTENTS Revision numbers and dates are changed to reflect applicable revisions of Manual sections. Listing for " Introduction & Scope of Services" has been added.

INTRODUCTION & SCOPE OF SERVICES

1.

Introduction:

Revised first paragraph to reflect that this revision of the project-related Manual is based on ETR-1001 Revision 12 which was accepted by the USNRC on 5/4/84. (clarification)

2. Scope of Services:

Revised first paragraph to reflect ETR-1001 Revision 12. (clarification)

SECTION QA-I-l

1. Paragraphs 2.0 and 5.0:

Revised to reflect recent extensive changes in the Ebasco corporate organization structure which includes change in designation of the Quality Assurance organization. (clarification)

2. Paragraph 3.1:

Revised to reflect recent extensive changes in the Ebasco corporate organization structure which include changes in designations of Ebasco quality-related organizations and position titles. (clarification)

3. Paragraph 3.2.2:

Revised to reflect change in title of Quality Program Procedure No. 5.

(clarification)

)

6 Page 2 of 8 Revisions to STP QAPD Part C Revision 6 SECTION QA-I-1 (Cont'd)

4. Paragraphs 4.2.1, 4.2.2, 4.2.5, 4.2.6, 4.2.7, 4.2.8, and 4.2.9:

Revised titles of STP procedures manuals to be consistent with change in designation of applicable Ebasco organizations. (clarification)

5. Paragraph 6.2:

Revised to include reference to audits performed by Site Quality Assurance as an additional means by which the effectiveness of the project Quality Program is evaluated. (clarification)

6. Paragraph 6.3:

Revised title of procedure to be consistent with change in designation of the Quality Assurance organization. (clarification)

7. Table 1-1.2:

Revised to provide separate colunn for Site Quality Assurance Procedures for clarity; to describe acronyms for " ASP", " CSP", and "CMI" procedures; to reflect change in acronym of Quality Program Procedures from "QP" to "QPP"; and to reflect additional procedures, including "NDE" and "QC" Quality Control Procedures. (clarification)

8. Table I-1.3:

Updated to reflect procedure additions / deletions and changes in titles of certain procedures previously listed. (clarification)

SECTION QA-I-2

1. Paragraphs 1.0, 2.1, 2.2, 2.3, 3.0, 3.1, 3.1.1, 3.1.1.1, 3.1.1.2, 3.1.2, 3.1.3, 3.1.4, 3.2, 3.3, 3.4, 4.0, 4.1, 4.1.1, 4.1.2, and 6.0:

General revision to reflect recent extensive changes in Ebasco quality-related organizations, positions, titles, and project-specific responsibilities. (clarification)

2. Paragraph 3.1.1.2.1(a):

Revised to indicate " safety-related" in lieu of " quality-related." (clarification)

1 Page 3 of 8 Revisions to STP QAPD Part C Revision 6 SECTION QA-I-2 (Cont'd)

3. Paragraph 3.1.1.2.1(c):

Revised to include review of nondestructive examination precedures by Site Quality Assurance. (clarification)

4. Paragraph 3.1.1.2.3(b):

Revised to reflect that Ebasco Site Quality Records records review responsibility is limited to those quality assurance records generated at the site by Ebasco. (clarification)

5. Paragraph 3.1.2(b):

Added second and third sentences to clarify reporting responsibilities of Quality Assurance Education Specialists assigned to the construction site.

(clarification)

6. Paragraph 3.4:

Added third and fourth sentences to clarify reporting responsibilities of the NDE Laboratory Supervisor. (clarification)

7. Paragraph 4.1.6:

Added last sentence to indicate that the Assistant Superintendents have stop work authority. (upgrade)

8. Figures I-2.1, I-2.2, I-2.4, 1-2.6, I-2.7, and I-2.9:

Revised to reflect recent extensive changes in Ebasco quality-related organizations, positions, titles, and project-specific responsibilities.

(clarification)

SECTION OA-I-3

1. Paragraph 3.1:

Revised first sentence to clarify that written lessons shall be preplanned, as per actual practice. (clarification)

2. Paragraph 3.2:

Revised first,'second, fif th, and sixth sentences to clarify that training lessons shall be preplanned, as per actual practJce. (clarification)

5 Page 4 of 8 Revisions to STP QAPD Part C Revision 6 SECTION QA-I-3 (Cont'd)

3. Paragraph 7.1:

Revised first line to change " Resource" to " Resources" in order to reflect correct name of group. (clarification)

4. Paragraph 8.0:

Revised second sentence to insert "or his designee" after the " Quality Control Site Supervisor." Revised position title in fourth sentence from

" Chief Quality Assurance Engineer" to " Director Quality Assurance" to reflect organization change. (clarification)

SECTION QA-I-6

1. Paragraph 4.7:

Revised end of last sentence to indicate that initials shall be traceable to the authorized individual. (clarification)

2. Paragraphs 5.2, 6.2, and 6.4:

Revised to add "of this Section" to clarify cross-references. (clarification)

3. Paragraph 6.S.1:

Revised for clarification purposes to specify "QA records which have been processed into the records facility" in lieu of " logged-in QA records,"

and to indicate inclusion of "those records that have been logged-out and removed away from the storage system." (clarification)

SECTION QA-III-l

1. Paragraph 4.2:

Revised to indicate that the historical file shall be maintained by the

" applicable" organization responsible, or as may be described in the applicable " organization's" procedures. (clarification)

2. Paragraph 6.0:

Added to reference audit requirements. (clarification)

s Page 5 of 8 Revisions to STP QAPD Part C Revision 6 SECTION QA-III-2

1. Paragraphs 3.2.2 and 3.2.3:

Deleted content of Paragraph 3.2.2, and renumbered previous Paragraph 3.2.3 as 3.2.2. (clarification)

2. Paragraph 3.7:

This paragraph (and subparagraphs) added to include requirements and responsibilities for preparation, review, approval, and distribution of field sketches. (clarification)

SECTION QA-III-6

1. Paragraphs 2.4:

Revised to add "of this Section of the !!anual" in lieu of "below" to clarify cross-reference. (clarification)

2. Paragraphs 4.1.2, 4.1.3, 4.1.4, 4.2, and 4.3:

Revised to reflect change in Ebasco's responsibility on the " recommended disposition of nonconf ormance report" function to be performed by the Client or his designee in lieu of the Senior Resident Engineer. Also, the previous Paragraphs 4.3 and 4.1.4 have been partially revised and renumbered as 4.1.4 and 4.2, respectively. (clarification)

3. Paragraph 5.1:

Revised first sentence for clarification purposes to add that Deficiency Notices shall be issued for deficiencies "which either violate the restrictions of Paragraphs 5.2 and 5.3 of this Section or are detected during final inspection" at the construction site. (clarification)

4. Paragraph 5.3:

Added to provide exclusion of Code-related welds found during the normal welding / inspection process, which will not require a Deficiency Notice, since they are tracked by a " Process Data Checklist" form. (clarification)

5. Paragraph 5.4:

Renumbered previous Paragraph 5.3 as 5.4.

6. Paragraph 6.1:

Deleted the words " quality assurance" from the fif th line in order to broaden the scope of the statement. (clarification)

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, Page 6 of 8 Revisions to STP QAPD Part C Revision 6 SECTION QA-III-7 i 1. Paragraph 2.6:

, Revised referenced paragraph in third line from "3.2" to "2.2" to reflect I correct reference. (clarification)

2. Paragraph 2.7:

Added second sentence to indicate that "Nonconformance Reports shall be initiated and processed in accordance with Section QA-III-6." Revised position title in third sentence from " Chief Quality Assurance Engineer" j to " Director Quality Assurance" to reflect organization change. (clarification) j 3. Paragraph 4.0:

4 Revised to add "of this Section" in lieu of "above" to clarify cross-reference. (clarification)

4. Paragraph 5.1:

Deleted the words " Quality Assurance" from the seventh and eighth lines in order to broaden the scope of the statement. (clarification)  ;

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l SECTION QA-III-9 '

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! 1. Paragraph 3.3:

Revised paragraph (and subparagraphs) to limit scope of proficiency j requirements to Lead Auditors to reflect the requirements of

ANSI N45.2.23-1978. (clarification) i i

2. Paragraph 3.3.2

Revised position title from " Chief Quality Assurance Engineer" to

" Director Quality Assurance" to reflect organization change. (clarification)  :

3. Paragraph 3.6.1:

t  ;

Added third sentence to clarify that if an audit is performed by only one

] individual, then such individual must be a qualified Lead Auditor. (clarification)

} 4. Paragraph 3.9.2: ,

I l Revised end of sentence to clarify that issuance of the audit report  ;

j "shall not exceed 30 days from the post-audit conference." (clarification)  !

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1 Page 7 of 8 Revisions to STP QAPD Part C Revision 6 SECTION QA-III-9 (Cont'd)

5. Paragraph 3.10.1:

Revised end of first sentence to clarify that the time period for submittal of a response to the audit report "shall not exceed 30 days."

6. Paragraph 3.11:

Deleted the word " quality" from the second line in order to broaden the scope of the statement.

7. Paragraphs 4.1.2, 4.1.3, and 4.1.4:

Revised position title and organization designations to reflect organization changes.

8. Paragraph 4.2.4:

Revised to indicate that evaluations of the construction site will be conducted " annually."

SECTION QA-III-10

1. Paragraph 2.1(b):

Revised to add "of this Section of the Manual" in lieu of "below" to clarify cross-reference.

2. Paragraph 3.1:

Revised first sentence to change "by any of the following means" to "by the following means, as applicable" in order to clarify that construction is not given multiple choice in marking material; materials are marked in accordance with the applicable criteria for a particular ites.

3. Paragraph 3.7: Added to provide additional control details as requested by the Client.

SECTION QA-III-11

1. Paragraph 2.3:

Revised to add "of this Section of the Manual" in lieu of "herein" to clarify cross-reference.

2. Paragraph 4.5:

Revised position title froa " Chief Quality Assurance Engineer" to

" Director Quality Assurance" to reflect organization change.

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Page 8 of 8 Revisions to STP QAPD Part C Revision 6 SECTION QA-III-12 Paragraph 2.3:

Revised to clarify that procedure requirements shall be in writing, as per actual practice.

SECTION QA-III-13

1. Paragraph 3.1:

Revised first sentence to clarify that the standard of calibration shall be traceable to the National Bureau of Standards (NBS) or a nationally recognized standard.

2. Paragraph 3.2, second paragraph: Delete in its entirety as per Client's request.

SECTION QA-III-14 Paragraph 2.2(c):

Revised to add "of this Section" in lieu of "above" to clarify cross-reference.

APPENDIX II

1. Exceptions to ANSI N45.2.5-1974, Item No. 1:

Revised first sentence of next-to-last paragraph to change " limits and tolerances" to " limits and/or tolerances."

2. Exceptions to ANSI N45.2.2-1972, Item No. 7:

Revised first sentence of second paragraph to delete the word " material" from " responsible for material storage."

3. Exceptions to ANSI N45.2.2-1972, Item No. 10:

Revised reference to Manual to indicate Ebasco " Nuclear Quality Assurance Program Manual" in lieu of "QA Program Manual" to be consistent with correct title'.

NOTE: All Manual sections have been revised to reflect the change in position title of the approval signatory from " Chief Quality Assurance Engineer" to " Director Quality Assurance."