ML20206J074

Forwards Rev 14 to CNS QA Program for Operation, Per 10CFR50.54(p) & 10CFR50.71.None of Changes Represent Reduction of Commitments.Summary of Changes,Encl

ML20206J074
Person / Time
Site:	Cooper
Issue date:	05/04/1999
From:	Swailes J NEBRASKA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20206J078	List: ML20206J074 ML20206J081
References
NLS990045, NUDOCS 9905120108
Download: ML20206J074 (10)

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Nebraska Public Power District Nebraska's Energy Leader NLS990045 May 4,1999 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 l

Subject:

Cooper Nuclear Station Quality Assurance Program NRC Docket No. 50-298, DPR-46 Gentlemen:

This letter transmits Revision 14 of the Cooper Nuclear Station Quality Assurance Program per 10CFR50.54(a) and 10CFR50.71.

Attachment "A"is a summary of the changes made and submitted herein. None of the changes represent a reduction of commitment in the CNS Quality Assurance Program.

Should you have any ques ons or comments concerning this revision, please contact me.

. H. Swaiies -

-P dent of i ear nergy

/nr

' 1:' 00 cc: Regional Administrator w/ attachments USNRC - Region IV Senior Project Manager w/ attachments USNRC - NRR Project Directorate IV-1 1 I

Senior Resident Inspector w/ attachments USNRC NPG Distribution (w/o attachments)

Cooper Nuclear Station Po. Box 98/ Brownville. NE 683210098 Tel*nhane.' (402) 825-3811/ Fax: (402) 825-s211 9905120108 990504 .- http//ww nppd com PDR ADOCK 05000299 P PDR

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1 Attachment A l to NLS990045 i Page 1 of 7 l l Cooper Nuclear Station )

Quality Assurance Program For Operation l Policy Document Revision 14 l

I l This listing describes changes to the Policy Document since the last (revision 13) submittal to the I Nuclear Regulatory Commission. Inconsequential changes (e.g,.; page numbers, Table of l

Contents references, and typographical errors) have also been appropriately changed; however, those particular changes are not described in detail. Each Change Description is followed by a

" bolded" explanation or phrase depicting why that specific change is not considered a reduction in QA Program commitment.

l Section/ Change Description / Explanation Commitment Paragraph Reduction

! Page Assessment Cornorate Policy Changed title of Division Manager of Quality Assurance No Statement, to Senior Manager of Quality Assurance and Vice President-page vi Nuclear to Senior Vice President of Energy Supply l Organizational title changes.

1.5, Deleted definitions of" Assessment" and " Evaluation", and No page 1-8 thru l-10 added new term / definition for Conditions Adverse to Ouality Previous activities " assessment" and " evaluation" are now performed as a part of QA audits and surveillances. New I guidance is provided for issues referenced as " Conditions Adverse to Quality".

1.5, Changed Vice President-Nuclear to Senior Vice President No page 1-12,13 of Energy Supply, changed Site Manager to Vice President of Nuclear Energy, and changed Division Manager of Quality l Assurance to Senior Manager of Quality Assurance in l Section titled Nuclear Power Groun Management)

Organizational title changes.

1.5, Deleted " assessment / evaluation" and reworded final sentence No page 1-13 in section titled Nuclear Ouality Procedures (NQPs)

Previous activities " assessment" and " evaluation" are now performed as a part of QA audits and surveillances.

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Attachment A to NLS990045 l Page 2 of 7 1.5, Changed Vice President-Nuclear to Senior Vice President No page 1-16 of Energy Supply in Section titled Review l Organizational title change.

j 1.5, Deleted section titled Significant Conditions Adverse to No page 1-16 Ouality Definition was more applicable to Conditions Adverse to Quality, therefore, SCAQ definition was deleted and used as the definition for CAQ.

1.5, Revised the definition of Surveillance No page 1-17 Definition was refined to more clearly describe this QA activity without deleting any overview commitment.

l 2.1, para 1, Changed Senior Vice President of Energy Supply to Vice No page 2-1 President of Nuclear Energy as the delegated NPPD Nuclear I Officer, changed Vice President-Nuclear to Senior Vice President of Energy Supply, removed the terms

" assessments, evaluations", replaced the wording " audits, surveillances, inspections, verifications" with "all QA overview functions" Organizational title changes; assessments and evaluations are i

now included with QA audits and surveillances; general wording l used to depict QA overview rather than specific terminology.

l 2.2,1., Added new paragraph detailing commitment to Regulatory No l l page 2-3 Guide 1.8, revision 2 Added commitment per NPPD correspondence NLS980129 from J.H. Swailes to the U.S. NRC, dated August 24,1998.

l 2.2, para 6, Changed Division Manager of Quality Assurance to Senior No page 2-4 Manager ofQuality Assurance Organizational title change.

2.5, para 2, Relocated from Technical Specifications-entire paragraph No page 2-13 Information not altered, only relocated.

2.5, para 3 Relocated from Technical Specifications-items

• Technical No page 2-14 Requirements Manual and *Offsite Dose Assessment Manual Information not altered, only relocated.

2.7, para 5, Changed Site Menager to Vice President of Nuclear Energy No page 2-17 Organizational title change.

Attachment A to NLS990045 l Page 3 of 7 2.10, para 2, Removed the term " Assessments / Evaluations" No page 2-19 Assessments / Evaluations now a part of QA audits /surveillances.

2.11, para 2, Removed the term " Assessments / Evaluations" No page 2-21 Assessments / Evaluations now a part of QA audits /surveillances.

i 2.13(c), Removed the term " Assessments / Evaluations" No page 2-24 Assessments / Evaluations now a part of QA audits /surveillances.

2.16, para 3 & 5, Changed Vice President-Nuclear to Vice President of No ;

page 2-27 Nuclear Energy and to Senior Vice President of Energy l

Supply, respectively Organizational title changes.

2.17, para 1, Relocated from Technical Specifications-the wording No page 2-28 "Section 6.0 of this standard" Information not altered, only relocated.

2.18, para 1, Changed Division Manager of Quality Assurance to No ,

page 2-29 Senior Manager of Quality Assurance Organizational title change.

2.18, para 2 Relocated from Technical Specifications-entire paragraph No and a.-g., Information not altered, only relocated.

page 2-29 & 2-30 2.19.1.(a)(6), Removed the term " Assessments / Evaluations" No page 2-32 Assessments / Evaluations now a part of QA audits /surveillances.

3.1, para 1, Removed the term " Assessments" No page 3-1 Assessments now a part of QA audits / sun eillances.

3.2, para 2 Changed Vice President-Nuclear to Senior Vice President No page 3-2 of Energy Supply, subsequently changed responsibility and authority for the Safety Review and Audit Board (SRAB) l from the Senior Vice President of Energy Supply to the Vice President of Nuclear Energy l Organizational title changes. Responsibility as NPPD's nuclear officer changed so that it would be assigned to the Vice President located at CNS. Similarly, the responsibility for the Safety Review and Audit Board (SRAB) was also then reassigned.

Attachment A to NLS990045 Page 4 of 7 3.2.1, Changed Vice President-Nuclear to Senior Vice President No page 3-2 of Energy Supply Organizational title change.

3.2.2, para 1 thru 5, Changed Vice President-Nuclear to Senior Vice President No page 3-2,-3 & -4 of Energy Supply and changed Division Manager of Quality Assurance to Senior Manager of Quality Assurance Organizational title changes.

I 3.2.3, para 1 & 8, Changed Division Manager of Quality Assurance to Senior No I page 3-4 & 3-5 Manager of Quality Assurance and changed Site Manager to Vice President of Nuclear Energy, respectively Organizational title changes.

3.2.3, para 11, Changed the wording "SORC qualified" to " designated" No page 3-6 A position paper was developed which provides explanation l and logic concerning the recognized need to make this change l while continuing to ensure that the appropriate degree of QA '

experience and knowledge is provided to SORC.

3.2.4, para 1 & 5, Changed Division Manager of Quality Assurance to Senior No page 3-6 and 3-7 Manager of Quality Assurance l Organizational title change.

3.2.4, para 2, Removed the term "/ Evaluation" No page 3-6 Evaluation is now part of QA audits /surveillances.

3.2.6, para 2 & 3, Removed the term "/ evaluations" and " assessments, No page 3-8 evaluations", respectively 3.2.6, Resolution Changed Division Manager of Quality Assurance to Senior No of Disagreements, Manager of Quality Assurance page 3-9 Organizational title change.

Attachramt A to NL5990045 Page 5 of 7 3.2.7 thru 3.2.13, Rearranged / renumbered sections to enhance readability. No page 3-9 thru 3-11 Combined Senior Manager of Site Support with Senior Manager of Safety Assessment into new section 3.2.10, titled Senior Manager of Safety Assessment / Site Support.

Combined Nuclear Fuels Supervisor with Senior Manager of Engineering into new section 3.2.11 (By combining those sections there are now 11 vs 13 sections in 3.2). In section 3.2.7, changed Site Manager to Vice President of Nuclear Energy and Vice President-Nuclear to Senior Vice President of Energy Supply, added Training and Nuclear Licensing and Safety as direct reports to the Vice President of Nuclear Energy.

Organizational title changes and assignment of functional responsibilities. No QA Program responsibilities have been deleted.

3.2.8 Added new section General Manager of Technical Services, No page 3-9 assigned Materials Services and all Engineering to this position responsibility.

Organizationai title change and assignment of functional responsibilities. No QA Program responsibilities have been deleted.

3.2.9, Added Performance Analysis and Scheduling to responsibility No page 3-10 for Plant Manager and removed responsibility for Station Engineering, which was added to the Senior Manager of Engineering in 3.2.11, changed Site Manager to Vice President of Nuclear Energy Organizational title change and assignment of functional responsibilities. No QA Program responsibilities have been deleted.

3.2.11, Changed reporting relationship of Senior Manager of No page 3-10 Engineering from Vice President of Nuclear Energy to General Manager of Technical Services Reassignment of functional responsibilities.

3.3, Changed Site Manager to Vice President of Nuclear Energy No page 3-11 Organizational title change.

Attachment A to NLS990045 Page 6 of 7 3.4, para 1 Relocated from Technical Specifications- Replaced existing No and 1. thru 6., responsibility wording with the wording from Tech Specs page 3-11 thru with the exception ofitem 1. which was retained from the 3-14 previous version of the Policy Document (page 3-13)

Information not altered, only relocated.

3.4.5., Changed Safety Review and Audit Board (SRAB) No page 3-13 reporting responsibility from the Senior Vice President of Energy Supply to the Vice President of Nuclear Energy Responsibility as NPPD's nuclear officer changed so that it would be assigned to the Vice President located at CNS.

Similarly, the responsibility for the Safety Review and Audit Board (SRAB) was also then reassigned.

3.5, para 2 Relocated from Technical Specifications- Replaced existing No and 1. thru 7., paragraph, which only references Tech Specs, with the actual page 3-14 thru wording from Tech Specs 3-18 Information not altered, only relocated.

3.5.1.b., Added words of commitment to Regulatory Guide 1.8, No page 3-15 revision 2 Added commitment per NPPD correspondence NLS980129 from J.H. Swailes to the U.S. NRC , dated August 24,1998.

4.1.2, Changed Division Manager of Quality Assurance to Senior No page 4-3 Manager of Quality Assurance and changed Vice President-Nuclear to Senior Vice President of Energy Supply Organizational title changes.

4.1.3, para 3, Changed Division Manager of Quality Assurance to Senior No page 4-4 Manager of Quality Assurance Organizational title changes.

4.1.3 a), para 3 & 4, Combined paragraphs 3 and 4 into new paragraph 3 No page 4-5 Reworded to more clearly depict QA overview.

4.1.3 b), para 1, Removed the term " evaluations" No page 4-5 Evaluations are now a part of QA audits /surveillances.

5.0, para 7, Changed Vice President-Nuclear to Senior Vice President No page 5-2 of Energy Supply and changed Division Manager of Quality Assurance to Senior Manager of Quality Assurance .

Organizational title changes.  !

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Attachment A

( to NLS990045 Page 7 of 7

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j 6.0, Relocated from Technical Specifications- added, in their No page 6-1 thru entirety, new sections 6.1 and 6.2, as transferred from 6-5 Tech Specs Information not altered, only relocated.

6.2.g),2,i, Removed words which reference Section 3.5.4.a. This No page 6-4 referenced Tech Spec Section was removed by Tech Spec Amendment 102, but was inadvertenth got yet removed from the Policy Document Inclusion of previously approved change.

7.0, Relocated from Technical Specifications- added new No page 7-2 references 7.16 thru 7.18 and deleted the word Radiological from the title of reference 7.14 Information not altered, only relocated.  ;

1 Figure 1, Changed Division Manager of Quality Assurance to Senior No page 8-1 Manager-Quality Assurance Organizational title change.

Table 2 c), Relocated from Technical Specifications- changed the wording No page 9-5 " Technical Specifications" to "Section 3.4 of this standard",

and removed the term " evaluations" l Information not altered, only relocated; inserted the correct l reference to location ofinformation; evaluations now a part of QA audits / sun'cillances.

l The following signatures represent those individuals who have personally reviewed the information contained in the attachment to correspondence NLS990045. Initials and date are provided on the top right-hand corner of the attachment indicating that each page has been reviewed.

Printed Name/ Title Initials Signature /Date M. D. Allen, QA Programs Supervisor l

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l ATTACHMENT 3 LIST OF NRC COMMITMENTS l 1

Correspondence No: NLS990045 The following table identifies those actions committed to by the District in this j 1

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 l information and are not regulatory commitments. Please notify the NL&S Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments, i

l COMMITTED DATE COMMITMENT OR OUTAGE None i

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l l PROCEDURE NUMBER 0.42 l REVISION NUMBER 6 l PAGE 9 OF 13 l t