NOC-AE-05001908, Submittal of Operations Quality Assurance Plan Change OA-058
| ML052020220 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 07/18/2005 |
| From: | Sheppard J South Texas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| G09.19, NOC-AE-05001908, RG-1.064, Rev. 2, STI: 31903934 | |
| Download: ML052020220 (16) | |
Text
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Nuclear Operating Company South TssPrd Ekctrkc GCIerngS bon PO. S 289 HbdawoA, Tms 77483 _
July 18, 2005 NOC-AE-05001908 File No.: G09.19 10CFR50.54(a)
STI: 31903934 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 South Texas Project Units 1 and 2 Docket Nos. STN 50-498 and STN 50-499 Submittal of Operations Quality Assurance Plan Change OA-058
Reference:
(1) Letter, T.W. Alexion to W.T. Cottle, "Graded Quality Assurance Operations Quality Assurance Plan," dated November 6, 1997; (2) J.A. Zwolinski to W.T. Cottle, "Safety Evaluation on Exemption Requests from Special Treatment Requirements of IOCFR Parts 21, 50, and 100," dated August 3, 2001.
The South Texas Project Nuclear Operating Company (STPNOC) submits the attached change to revision 16 of the Operations Quality Assurance Plan. This change provides the necessary revision to the applicable section of Chapter 6.0, Design and Modification Control, of the Operations Quality Assurance Plan (OQAP) in order to clarify the applicability of exceptions to Regulatory Guide 1.64, rev. 2 (6/76), position C.2 that were previously approved by the Nuclear Regulatory Commission in Reference 1 for items in the "Basic" program (safety-related Medium, Low, or Non-Risk Significant SSCs). The change clarifies that these exceptions continue to safety-related Low or Non-Risk Significant SSCs, but which are now part of the "Limited" program. The "Limited" program was developed as part of the Exemption to Special Treatment Requirements approved by the Nuclear Regulatory Commission in Reference 2. See Attachment 1 for further clarification.
This change does not reduce any element of or responsibilities for implementation of the QA program. This change therefore does not represent a reduction in commitment and does not require NRC approval prior to implementation in accordance with the provisions of 10CFR50.54(a)(3).
There are no commitments in this letter.
Qom4
NOC-AE-05001908 Page 2 of 3 If there are any questions regarding this matter, please contact Mr. M. A. McBurnett at (361) 972-7206 or me at (361) 972-8434.
J. heppard President and Chief Executive Officer Attachments: (1) Clarification of OQAP changes to Chapter 6.0 for Limited Components (2) QA-058
NOC-AE-05001908 Page 3 of 3 cc:
(paper copy) (electronic copy)
Bruce S. Mallett A. H. Gutterman, Esquire Regional Administrator, Region IV Morgan, Lewis & Bockius LLP U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 David H. Jaffe Arlington, Texas 76011-8064 U. S. Nuclear Regulatory Commission Richard A. Ratliff Jack A. Fusco Bureau of Radiation Control Michael A. Reed Texas Department of State Health Services Texas Genco, LP 1100 West 49th Street Austin, TX 78756-3189 Jeffrey Cruz C. Kirksey U. S. Nuclear Regulatory Commission City of Austin P. 0. Box 289, Mail Code: MN1 16 Wadsworth, TX 77483 Jon C. Wood Cox Smith Matthews C. M. Canady J. J. Nesrsta City of Austin R. K. Temple Electric Utility Department E. Alarcon 721 Barton Springs Road City Public Service Austin, TX 78704
1 ATTACHMENT
Attachment I Page 1 of 3 Clarification of OQAP changes to Chapter 6.0 for Limited Components Revision 13 of the South Texas Project Operations Quality Assurance Plan (OQAP) was approved by the NRC on November 6, 1997 (Reference 1). This revision incorporated the methodology for implementation of Graded Quality Assurance (GQA) and provided for the establishment of three levels of controls as shown below:
QA Scope Controls Program Full Safety related High risk Highest levels of program controls and significant SSCs oversight. These programmatic controls are in full compliance with the requirements of 10 CFR 50 Appendix B, and additionally represent compliance with the applicable STP commitments relative to USNRC Regulatory Guides and ANSI Standards that they endorse.
Other recognized industry standards are applied, as appropriate.
Basic Safety related Medium, Lower levels of control and oversight, designed Low, or Non-Risk to maintain and/or preserve those identified significant SSCs critical attributes of SSCs needed to support risk significant functions. They reflect economical and efficient business practices while maintaining compliance with the basic requirements of 10 CFR 50 Appendix B. They do not necessarily reflect the strict controls as depicted in USNRC Regulatory Guides and the ANSI standards they endorse. Other industry standards are applied, as appropriate.
Targeted Non-safety related High Specific program controls which are consistent or Medium risk with applicable portions of the "Full" and significant SSCs "Basic" program controls, applied in a selected manner and specifically "targeted" at those attributes which placed the component into that category.
The specific program controls applicable to the Full and Basic programs are delineated, in part, in Table I of Chapter 2.0 of the OQAP. This table provides the specific STP commitments to applicable Regulatory Guides and/or ANSI standards and highlights the differences between the Full and Basic programs. In the area of independent design verification, these differences are shown in the following excerpt from Table 1.
Attachment 1 Page 2 of 3 R.G./ANSI Full Program Basic Program Standard R.G. 1.64, rev. 2 No exceptions Regulatory Position C.2 - STP may implement taken the requirement regarding design verification as prescribed in ANSI N45.2.11, 1974, 6.1, second sentence as opposed to R. G. wording.
ANSI N45.2.11 No exceptions 3.2 (1st paragraph) - STP will require personnel taken to consider items 1 through 28, but a documented checklist may not be required.
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 required to consider items 1 through 19, but a documented checklist may not be required.
Revision 13 of the OQAP was determined to be acceptable based on a safety evaluation performed by NRC staff. In regard to the Basic program controls for independent design verification shown above, the safety evaluation stated the following in paragraph 3.4.1.2.c:
"Staff Evaluation: The licensee's exception to Regulatory Position C.2 of RG 1.64 (Reference 28) is considered acceptable since it is included in NQA-1-1983 (Reference 16) which was endorsed by the NRC in RG 1.28, Rev. 3 (Reference 29).
In addition, this alternative is consistent with the provisions of Draft RG DG-1064 (Reference 3).
With regard to documentation of the 19 design review question checklist, the licensee will continue to consider the technical aspects of the 19 questions and the staff considers documentation to be implemented only as deemed necessary to be acceptable, and consistent with the provisions contained in Draft RG DG-1064 (Reference 3)."
Chapter 6.0 of the OQAP provides requirements and responsibilities for design and modification control of SSCs. Paragraph 5.4.3 of this chapter specifies design verification controls and incorporates the exception to RG 1.64 discussed above for SSCs in the Basic program.
Subsequent to the incorporation of the GQA methodology into the OQAP, STP was granted an exemption from Special Treatment Requirements of IOCFR Parts 21, 50, and 100 (Reference 2). The main impact of this exemption on the OQAP was to incorporate a new category of program controls called Limited, as shown below.
Attachment 1 Page 3 of 3 QA Scope Controls Program Limited Safety related Low and Lower levels of oversight than those under the Non-Risk significant Basic program, limited to design, modification, SSCs or corrective action activities, as described in Chapters 6.0 and 13.0 of the OQAP. They reflect economical and efficient business practices while maintaining compliance with those requirements of 10 CFR 50 Appendix B that relate to design control, corrective action, and nonconforming materials, parts, or components. They do not necessarily reflect the strict controls as depicted in USNRC Regulatory Guides and the ANSI standards they endorse. Other industry standards are applied, as appropriate.
In incorporating the Limited program category into the OQAP, STP, through an oversight, neglected to clarify that the Chapter 6 exception for design verification that applies to the Basic Program also applies to the Limited Program. It is clear that safety related SSCs categorized as Low or Non-Risk significant that, prior to the exemption, had been afforded this exception by being part of the Basic Program, should continue to have this exception and should not have more stringent controls than safety related Medium risk components.
It is noted that this change to the OQAP is in full compliance with the requirements of 10CFR Appendix B, criterion m, Design Control and with the STP UFSAR, section 13.7 (Risk-Informed Special Treatment Requirements).
ATTACHMENT 2 CHANGE QA-058
SUMMARY
OF CHANGES Page 1 of I ALL CHANGES ARE IN BOLD TYPE 1.0 2.0 CHAPTER LOCATION ACTION TEXT TOC CH 6.0 INSERT QA-058 CH 6.0 5.4.3 INSERT (This paragraph's recommendation does not apply to verification of design for items in the "Basic" or "Limited" program category)
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV.
Chapter NO.
OPERATIONS QUALITY ASSURANCE PLAN TABLE 16 OF TABLE OF CONTENTS CONTENT PAGE 1 OF 2 EFFECTIVE DATE 02-01-04 Chapter Title Effective Effective Change Number Chapter Revision Date Notice No.
Definitions 9 2-1-02 1.0 Organization 12 2-1-04 QA-057 2.0 Program Description 14 2-1-04 QA-056,QA-057 3.0 Conduct of Plant Operations 7 2-1-98 4.0 Qualification, Training, and 6 2-1-98 Certification of Personnel 5.0 Maintenance, Installation of 5 2-1-98 Modifications, and Related Activities 6.0 Design and Modification Control 8 2-1-02 QA-058 7.0 Procurement 9 2-1-02 QA-057 8.0 Control and Issuance of 6 2-1-98 Documents 9.0 Control of Material 6 2-1-98 10.0 Inspection 9 2-1-02 QA-057 11.0 Test Control 7 2-1-00 12.0 Instrument and Calibration 6 2-1-98 Control 13.0 Control Of Conditions Adverse 10 2-1-02 QA-057 to Quality 14.0 Records Control 7 2-1-02 QA-057 15.0 Quality Oversight 9 2-1-04 QA-057 Activities
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV.
Chapter NO.
OPERATIONS QUALITY ASSURANCE PLAN TABLE OF 16 TABLE OF CONTENTS CONTENT PAGE 2 OF 2 EFFECTIVE DATE 02-01-04 Chapter Title Effective Effective Change Number Chapter Revision Date Notice No.
16.0 Independent Technical 8 2-01-04 QA-057 Review 17.0 ASME Code Section XI - 6 2-01-00 QA-057 Repairs and Replacements 18.0 ASME Code Section XI - 7 2-01-00 QA-057 Inservice Inspection and Testing 19.0 Administrative Controls 1 2-01-04 QA-056, QA-057
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV.
Chapter NO.
OPERATIONS QUALITY ASSURANCE PLAN 6.0 8 DESIGN AND MODIFICATION CONTROL PAGE I OF 5 EFFECTIVE DATE 02-01-02 1.0 PURPOSE 1.1 The purpose of this chapter is to establish the requirements and responsibilities for design and modification control of structures, systems, or components at the South Texas Project Electric Generating Station (STP).
2.0 SCOPE 2.1 This chapter applies to the design and modification activities associated with the preparation and review of design documents including the translation of applicable Code of Federal Regulation requirements and design bases into design documents.
3.0 DEFINITIONS 3.1 None
4.0 REFERENCES
4.1 STP Technical Specifications 4.2 OQAP Chapter 5.0, Maintenance, Installation of Modifications, and Related Activities 4.3 OQAP Chapter 14.0, Records Control 4.4 10CFR50.59, Changes, Tests and Experiments 4.5 OQAP Chapter 13.0, Control of Conditions Adverse to Quality 4.6 OQAP Chapter 2.0, Table I 5.0 REQUIREMENTS 5.1 Measures shall be established to document selection of design inputs. Changes to specified design inputs, including identification of their source, shall be identified and documented. As the design evolves, unreviewed safety question evaluations shall be performed as required by Reference 4.4.
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV.
Chapter NO.
OPERATIONS QUALITY ASSURANCE PLAN 6.0 8 DESIGN AND MODIFICATION CONTROL PAGE 2 OF 5 EFFECTIVE DATE 02-01-02 5.2 Measures shall be established to control design activities to assure design inputs are translated into design documents such as specifications, drawings, procedures, or instructions.
5.2.1 Design activities involving reactor physics; stress, thermal, hydraulic, and accident analysis; materials compatibility; and accessibility for maintenance, inservice inspection, and repair will be performed according to approved procedures by appropriately qualified individuals. Results of analyses will be appropriately verified and documented.
5.2.2 Design documents shall include appropriate quality standards. If an alternate quality requirement is used (e.g., other than the originally specified quality standard) the change shall be documented and approved.
5.2.3 Design analyses shall be sufficiently detailed as to purpose, method, assumptions, design input, references, units, and status (preliminary or final) such that a technically qualified person can review and understand the analyses and verify the adequacy of the results without recourse to the originator.
5.2.4 A review for application suitability of materials, parts, equipment, and processes essential to the functions of structures, systems, and components is done as part of the design document preparation and review process.
The procedures, which govern the preparation and review of design documents, require that valid industry standards and specifications be used for this review. Review of standard off-the-shelf commercial materials, parts, and equipment for suitability of application with structures, systems, and components will be conducted before selection.
5.3 Measures shall be established to identify and control design interface among participating organizations (internal and external).
5.4 Measures shall be established to verify adequacy of design and design changes.
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV.
Chapter NO.
OPERATIONS QUALITY ASSURANCE PLAN 6.0 8 DESIGN AND MODIFICATION CONTROL PAGE 3 OF 5 EFFECTIVE DATE 02-01-02 5.4.1 The design process shall include verification by qualified persons to assure that the design is adequate and meets specified design input. Design control procedures shall specify requirements for the selection and performance of design verification methods. Design verification shall be either by design review, alternate calculation, qualification testing, or a combination of these. The depth of design verification shall be commensurate with the importance of the system or component to plant safety, complexity of the design, and similarity of design to previous designs.
5.4.1.1 If the verification method performed is only through qualification testing, the following are required.
- Procedures shall provide criteria that specify when verification should be by test.
- Prototype, component, or feature testing shall be performed as early as possible before installation of plant equipment, or before the point when the installation would become irreversible.
- Verification by test shall be performed under conditions that simulate the most adverse design conditions as determined by analysis.
5.4.2 Design verification shall be performed by competent individuals or groups other than those who performed the original design.
5.4.3 Design verification should not be performed by individuals that have immediate supervisory responsibility for the individual performing the design; have specified a singular design approach; have ruled out certain design considerations; or have established the design inputs for that ,o particular design aspect. (This paragraph's recommendation does not >
6 apply to verification of design for items in the "Basic" or "Limited" VI program category) 00
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV.
Chapter NO.
OPERATIONS QUALITY ASSURANCE PLAN 6.0 8 DESIGN AND MODIFICATION CONTROL PAGE 4 OF5 EFFECTIVE DATE 02-01-02 5.4.4 Design verification will normally be performed prior to release for procurement, manufacture, installation, or use by another organization in other design activities. Exceptions shall be justified and documented.
Procedures shall control the justification of exceptions and the completion of the verification of all affected design output documents prior to relying on the component, system, or structure to perform its function.
5.5 Measures shall be established to control the approval, issuance, and changes of design documents to prevent the inadvertent use of superseded design information.
5.6 Changes made to design documents are reviewed and approved by the same groups or organization, which reviewed and approved original design documents.
If the organization which originally approved a particular design document is no longer responsible, another organization may be designated if competent in the specific design area, has access to pertinent background information and has an adequate understanding of the requirements and intent of the original design.
5.7 Conditions adverse to quality found in approved design documents, including design methods, that could adversely affect structures, systems, or components shall be documented and action taken to correct and prevent recurrence, in accordance with Reference 4.5.
5.8 Measures shall be established for the identification and control of deviations from specified quality standards.
5.9 Measures shall be established which assure that maintenance and modifications associated with design changes which may affect the functioning of structures, systems, or components are performed in a manner to ensure quality at least equivalent to that specified in the UFSAR or current design bases and requirements.
5.10 Measures shall be established to maintain the list of structures, systems, and components current after modifications are made.
5.11 Measures shall be established to assure that only appropriately verified, qualified and controlled computer codes are authorized for use.
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION NUMBER REV.
Chapter NO.
OPERATIONS QUALITY ASSURANCE PLAN 6.0 8 DESIGN AND MODIFICATION CONTROL PAGE 5 OF 5 EFFECTIVE DATE 02-01-02 5.12 Modifications 5.12.1 Modifications to structures, systems, and components shall be controlled, reviewed, and approved.
5.12.2 Installation and testing of modifications shall be performed in accordance with Reference 4.2 and approved procedures. These procedures shall contain provisions as appropriate to ensure quality of installation and appropriate post modification testing. (This paragraph does not apply to components in the "Limited" program category, unless design verification testing is being performed in accordance with 5.4.1.1.)
5.12.3 Structures, systems, and components shall not be declared operable after a modification until the following provisions are satisfied:
5.12.3.1 Affected procedures are revised and distributed to appropriate users.
5.12.3.2 Appropriate personnel are trained.
5.13 Modifications will be checked against the design change documentation for proper implementation prior to closing out the design change process.
6.0 DOCUMENTATION 6.1 Procedures, which are generated as required by this chapter, shall identify the records, which are required to implement and document those activities. The records shall be controlled in accordance with Reference 4.3.
7.0 ATTACHMENTS 7.1 None