ML20202B879

Forwards Response to RAI Re Rev 13 to Quality Assurance Program for Operation Policy Document, for Cooper Nuclear Station

ML20202B879
Person / Time
Site:	Cooper
Issue date:	02/03/1998
From:	Horn G NEBRASKA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLS980019, NUDOCS 9802120116
Download: ML20202B879 (6)

Text

- ---- -- _ _ _ _ __ _

P.O M A O Lk l $M $5121 Nebraska Public Power District r- .

"m=m,""

rawnnumum=~azaturamamamm--ux.mc-au=amman NLS980019 February 3,1998 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Gentlemen:

Subject:

Response to Request for AdditionalInformation Revision 13 to Quality Assurarice Program for Operation Policy Document Cooper Nuclear Statica, NRC Docket 50-298, DPR-46

Reference:

1. Letter NLS970087 to Document Control Desk (USNRC) from G. R. llorn (NPPD) dated May 2,1997," Quality Assurance Program for Operation Policy Document Revision, Cooper Nuclear Station, NRC Docket 50-298, DPR-46"

2. Letter to G. R. llorn (NPPD) from J. R. IIall(USNRC) dated December 15, 1997," Revision 13 to Quality Assurance Program for Operation Policy Document for Cooper Nuclear Station; Docket 50-298"

(

11y letter dated May 2,1997 (Reference 1), the Nebraska Public Power District (District) submitted proposed Revision 13 to Quality Assurance Program for Operation Policy Document for Cooper Nuclear Station. Under Reference 2, the NRC requested additional information to complete its review. The District's response to the request for additionalinformation is provided as Attachment I to this letter.

Should you have any questions concerning this matter, please contact me. Il Sine rely, i

/

' io ' ice Presidei Of finergy Supply

/crm Attachment 9002120116 900203 w? ll Ill!I !!I!

Ill PDR ADOCK 05000298 P PDR

_- ady-k..--.,'.U. _ ..,..v., ,.h.r. - ' '. n y * " , _ _ _ ' ' e 'm -uisy - .m-.

As - --

I NLS980019 1 February ),1998 Page 2 0f 2 cc: Regiona* Administrator USNRC Region IV-Senior Project Manager USNRC NRR Project Directorate IV 1 _

Senior Resident inspector USNRC r

• ~

NPO Distribution t

._ 5 k

-f f

i s

. = . _

4 f

,,vn,,,-,, ,,r A , w., -

n-- -

-s w - -v r- . 4 <--r, ~rd

Attachment I to NLS98.0019 Page1of3 Response to Request for AdditionniInformation Revision 13 to Quality Assurance Program for Operation Policy Document Cooper Nuclear Station, NRC Docket 50-298, DPR-46 Ily letter dated May 2,1997, the Nebraska Public Power District (District) submitted proposed Revision 13 to Quality Assurance Program for Operation Policy Document for Cooper Nuclear Station. By letter dated December 15,1997, the NRC requested additional information to complete its review. The District's response to the request for additional information is provided below. Since cach response may address multiple questions, the responses identify the corresponding question (s) to which they apply.  ;

Requested Information:

a. What traming programs and qualification requirements will be established for peer personnel to assure that their reviews of the quality assurance aspects of the documents will be properly performed?

b. What quality assurance training programs and qualification requirements will be established t for the supervisors of the originating line organizations and related management personnel involved in the preparation and review of documents?

c Will there be opportunities for interactions between peer prsonnel and quality assurance personnel to resolve areas of difliculty?

d. Ilow will independence be maintained between the document originator and the document reviewer?

c. What is meant by " periodic" oversight by QAD of document review activities performed by the line organizations? Also, what is meant by QAD oversight randomly and situationally?

Response

(Questions a. and b.) The quality assurance training administered to all personnel, in addition to specialized training for select personnel pursuant to the Quality Control Program, ensures that personnel responsible for input and review of quality assurance provisions into controlling does nents are capable of fulfilling such responsibilities. At Cooper Nuclear Station, this responsibility has always resided with the line organization. As further clarification, it should be noted that the historical practice of QAD reviews has focused on (but was not limited to) verification ofline organization input of quality criteria into documents, rather than having primary responsibility for such input. Recent historical performance of additional reviews by the Quality Assurance Division has revealed minimal engagement required regarding quality assurance criteria input to process documents, with the exception of procurement documents.

i i

Attachment 1 to NLS9&0019 j

l

Pa'g e 2 of 3  :

^

'As a result ornegative performance trends in the area of quality program criteria input to l procurement documents, the Quality Assurance Division is continuing extensive reviews. Such  !

reviews are being conducted as " situational" reviews as described below.

(

(Question d.) Quality Assurance requirements, specifically the commitments contairx1 within the  !

- Quality Asaurance Program for _ Operation Policy Document, describe prohibitions to select -  !

Leircumstances regarding the independence of performers of tasks from subsequent reviewers / approvers. These circumstances are limited to compliance with ANSI N45.2.11 for

' design reviews, Quality _ Control Program task execution, and compliance with 10CFR50 ,

Appendix B Criterion VI regarding revisions to quality affedting documents. Beyond the scope of -'

these specific requirements, which are explicitly incorporated into controlling process procedures,

. independence between document originators and reviewers is depicted by signatures as such documents are prepared and processed for approval.-

L (Questions c. and e.) Continued engagement by the Quality Assurance Division will entail the l following: J t

1. " Periodic" reviews of contrcling documents are those typically conducted in conjunction with scheduled audit or surveillance activity. Such reviews result from stmetured consideration of

)

}

standard audit objectives or developed surveillance objectives, respectively. These reviews J

_ include, but are not limited to, performance-based evaluation of the adequacy and effect of the 1 controlling documents, and of field execution of the document as intended. Each audit performed by Quality Assurance addresses the following objectives pertaining to procedures,-  ;

instmetions and document control: '>

a. Evaluate procedure adherence, the adequacy of procedures and instructions, and the Il effectiveness of procedure implementation; i

b. _ Evaluate the effectiveness of document control practices; and, J

c; Evaluate the adequacy of program' documents in conforming to commitments, licensing  !

-_ basis and/or design basis requirements (as appropriate), and the effectiveness of program document implementation.

= a 2J " Situational" reviews are those that include the routine opportunity to evaluate the adequacy of controlling documents by participation as a permanent, non voting member of the Station Operations Review Committee (SORC)J In addition to select controlling documents which ar.e processed .by SORC, all process procedures which contain the quality assurance criteria for executing lower level implementing procedures are afforded SORC review and approval, hence QA review and concurrence.  !

h _ _ _ , , _ , _ _ __ ,,__ _ _ _ , _ _ _ _

,= .. . .

Attachment 1.

to NLS980019 Pa'ge 3 of 3 4

Situational reviews also may result from response to precursors, negative performance trends, or events Quality Assurance will respond with an audit, surveillance, or dedicated reviews with a process signature required, when there is indication that performance may be (or have

- been) adversely affected by adequacy or execution of a quality affecting document. The most

, typical opponunities include Quality Assurance follow-up to a line originated issue (Problem

= identification Report), an issue that is perceived during direct observation of work in progress l

by an auditor, or as in the case referred to above regarding the negative performance trend with procurement documents.

l

3. " Random" reviews are those conducted by Quality Assu7ance during performance of any audit or surveillance activity, during any phase of generation, processing, or execution when there l may be no initiating impetus for such a resiew, in addition to these engagement opportunities, the Quality Assurance Division interacts with the .

lice organizatic,n, as required, when difficulties or questions arise regarding quaFay program measures input to (or execution of) quality implementing procedures.

_m_U

I'

• ATTACHMENT 3 LIST OF MRC COMMITMENTS l Correspondence Hof NLS980019 Ttte 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 Nont l

l

. _ =

PROCEDURE NUMBtR O.42 l REVISION NUMBER 5 l PAGE 9 OF 13 l

. .  ;