ML20138H650
| ML20138H650 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 05/02/1997 |
| From: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20138H654 | List: |
| References | |
| NLS970087, NUDOCS 9705070238 | |
| Download: ML20138H650 (6) | |
Text
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NLS970087 May 2,1997 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 4
Gentlev.en:
Subject:
Quality Astura,cc Program for Operation Policy Document Revision Cooper Nuclear Station, NRC Docket 50-298, DPR-46 This letter transmits proposed Revision 13 of the Cooper Nuclear Station (CNS) Quality Assurance Program for Operation Policy Document (Policy Documentl This revision contains proposed reductions of commitment and is therefore being submitted for NRC review and approval in accordance with the provisions of 10CFR50.54(a)(3).
The proposed changes pertain to the removal and clarification of commitments regarding Quality Assurance organizational reviews of procedures and select other line-organization generated documents. Since these reviews are not activities described by specific Appendix B criteria, the Policy Document will continue to satisfy the criteria of10CFR50, Appendix B. Further, these changes will result in improved implementation of the CNS Quality Assunnce Program by describing the focus responsibility for quality input to line documents at ti ir respective point of origin, and by enhancing the capability to apply Quality Assurance Depanment resources to issues of higher safety significance, as necessary. The Quality Assurance Department will continue to conduct performance based reviews ofline documents as warranted by performance trends and by routine auditing.
Attachment I contains a summary of the specific changes and the reasons for concluding that the implementation of the CNS Quality Assurance Program will be enhanced. Should you have any questions concerning this matter, please contact me.
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T NLS970087 May 2,1997 Page 2 of 2 I
/crm Attachment Enclosure cc: Regional Administrator l
USNRC - Region IV Senior Project Manager USNRC - ?aR Project Directorate IV-1 Senior Resident Inspector USNRC i
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Attachment I to NLS970087 Page1of3 COOPER NUCLEAR STATION QUALITY ASSURANCE PROGRAM FOR OPERATION POLICY DOCUMENT REVISION 13 -
SUMMARY
OF CilANGES Section/
Change Descriptions Paragraph l
l Section 2.3 Para. 3 Removed the commitment for Quality Assurance (QA) to independently Page 2-5 review and evaluate all design changes, and for such reviews to include verification of compatibility with applicable codes, standards, and j
regulatory requirements, considerations of reactor physics, stress, thermal l
hydraulic and accident analysis, etc. Such reviews are a function of independent review by the line organization and in compliance with the provisions of ANSI N45.2.11-1974 to which the District is committed 1
pursuant to paragraph 5 item 1 of this section. The continuation of such reviews by QA strictly to maintain compliance with this excerpt has the J
potential to effect the more appropriate dispatch of resources for evaluation ofissues and activities ofhigher safety significance. The i
addition of the commitment that "the QA Division will periodically review design changes during any phase of development or implementation" provides both the description of the intent and desire to i
provide oversight of design related activities, and the necessary fiexibility l
to apply QA resources to activities having high safety significance at any given time.
i Section 2.4 Para. 3 Removed the commitment for in-line review of procurement documents Page 2-11 by QA and replaced it with the commitment to " periodically review procurement documents.. " Analysis of historical review comments by QA reveals that this in-line review process has had the effect of over-reliance by the line organization on the intended independent faction of QA. The primary responsibility for technical adequacy of procurement documents resides with the line organization.
Section 2.5 Para. I Replaced the commitment regarding QA in-line review of Page 2-13
" documentation for special processes, special test procedures, and special maintenance procedures" with a more reasonable commitment for periodic review of governing procedures for these processes and their resultant products. Such in-line reviews by QA provides no significant value because the line organization monitoring and reviews have been demonstrated to be effective at precluding any significant findings by QA over the past several years. In addition, as with other such in-line review commitments, this has the potential to negatively impact more effective use of QA resources to be evaluating issues and actisities of higher safety significance.
Attachment I to NLS07008)
Page.y.of3 Section/
Change Descriptions Paragraph Section 2.9 Para.1 Removed the statement that control procedures provide for QA review Page 2-18 and inspection. This excerpt unnecessarily implies that all procedures which govern activities affecting quality must be subject to review by the QA Division. Such in-line review by the QA Division has the effect of usurping the responsibility for quality assurance functional activity by the line organization, specifically the First and Second Level line organization responsibilities as described in Table 2 of this Policy Document. The commitment for QA Division procedure review is revised as indicated in Sections 4.1 (Para.1), 5.0 (Para. 3) and Table 2 Second Level, as discussed below for those changes.
Section 2.9 Para. 2 The addition of the word " periodically" is consistent with the intent to Page 2-18 change the commitment for QA Division review of procedures as discussed in the previous change description, and below for the change to Table 2.
Section 3.6 Para.1 It is impractical to require specific QA review of all procurement Page 3-13 documents to suppliers and contractors prior to awarding of contracts.
Processes for pursuit of qualification of suppliers have the necessary provisions for timely and comprehensive involvement of the QA Division.
Such processes are in the form of Nuclear Quality Procedures; refer to Definition in Section 1.5 which describes the interface between QA Division and procurement procedures for such involvement. Review of procurement documents and assurance of their quality prior to issuance are necessary functions of the line organization to fulfill First and Second Level responsibilities. Refer to the description provided for the change to Section 2.4 Paragraph 3 above, which also describes the replacement commitment for periodic review of procurement documents by the QA Division.
Section 4.1 Para.1 Revised the commitment regarding QA review of work procedures, Page 4-1 which results in reducing the commitment from QA review of all work procedures, to oversight by QA randomly, periodically, and situationally at any stage of procedure initiation, implementation, or closcout. Added a clarification of the responsibility of the line organization to apply the applicable criteria of 10CFR50 Appendix B during initiation and use of work procedures. This commitment change is necessary to align responsibilities consistent with the intent to apply the Three Level QA Program as described in Table 2, and to provide more appropriate latitude for application of QA resources to pursue and address issues of potentially higher safety significance.
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to NLS970087 l
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l Section/
Change Descriptions Paragraph i
Section 5.0 Para. 3 Revised the commitment to describe the intent for QA to perform reviews
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Page 5-1 of procedures randomly, periodically, and situationally. This revision is consistent with the intent to require the line organization to be responsible for First and Second level quality assurance, and for QA to remain independent to conduct such oversight as described, and use resources appropriately for pursuit of more significant issues.
Section 5.0 Para. 4 Revised the commitment consistent with the previous paragraph change Page 5-1 description and rephrased the intent for QA reviews of procedures to consider compatibility oflower tier procedures with requirements and commitments of higher level documents.
Table 2 Revised the description of QA Manager responsibility regarding reviews Page 9-5 of procedures. This description of Second Level QA is intended to focus on supervision and management of the organizations having primary responsibility for implementing the quality assurance program. The change is consistent with the previously described changes to remove QA from in-line review responsibilities by characterizing QA organization
" periodic review" ofline supervision and management products.
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l ATTACHMENT 3 LIST OF NRC COMMITMENTS l
Correspondence No: NLS970087 The following table identifies those actions committed to by the District in this document. Any other actions discussed in the submittal represent intended or planned actions by the District. They are described to the NRC for the NRC's information and are not regulatory commitments.
Please notify the Licensing Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.
COMMITTED DATE COMMITMENT OR OUTAGE None.
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l PROCEDURE NUMBER 0.42 l
REVISION NUMBER 4 l
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