ML20217H724

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SER Accepting Proposed Change to Operational Quality Assurance Program for Plant
ML20217H724
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 03/30/1998
From:
NRC (Affiliation Not Assigned)
To:
Shared Package
ML20217H701 List:
References
NUDOCS 9804060036
Download: ML20217H724 (2)


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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION OPERATIONAL QUALITY ASSURANCE PROGRAM (OQAP) CHANGE WOLF CREEK NUCLEAR OPERATING CORPORATION WOLF CRFFK GENERATING STATION DOCKET NO. 50-482

1.0 INTRODUCTION

By letter dated September 12,1997, Wolf Creek Nuclear Operating Corporation (WCNOC) requested a change to the Operational Quality Assurance Program (OQAP) for the Wolf Creek Generating Station to permit the continued use of the existing Qualified Reviewer Program (QRP) to review administrative procedures, and changes thereto, and to delete the redundant in-line review of these procedures by the Safety Evaluation Group. By letter dated January 27, 1998, supplemental information was provided to indicate the specific procedures that will be reviewed under cognizance of the QRP with a sampling overview by the Performance Improvement and Assessment (PIA) organization.

I 2.0 EVALUATION The QRP had previously been approved by Amendment 73 to Facility Operating License No.

NPF-42 (letter dated April 28,1994) for use in reviewing all procedures and changes thereto, including administrative procedures, that did not involve the need for a 10 CFR 50.59 safety evaluation. The licensee proposes to continue this program. The controls for implementation of this program are described in Section 6.8.2 of the licensee's Technical Specifications. This program satisfies the requirements of Criterion VI of 10 CFR Part 50, Appendix B.

i in addition to the above, the Quality Evaluation (QE) Group within the PIA organization is also responsible for the review of isdministrative procedures.' The licensee is requesting that the QA review of these procedures be eliminated since it is redundant. The current QE responsibility is to review the administrative procedures and changes thereto with regard to the quality

- assurance (QA) aspects. The Qualified Reviewer (QR), under the proposed change, will now be responsible to perform the entire procedure review, including the QA aspects, since the QR

. is qualified to do so.. Under the QRP process, if necessary, the QR has access to QA expertise in the PIA organization. The review of procedures applicable to maintenance, modifications, inspections, and special processes will continue to be performed by the Quality Control (QC)

Group within the PIA organization. Under the licensee's commitment to Regulatory Guide 1.33, Revision 2. " Quality Assurance Program Requirements (Operations)," the QE group conducts a

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- random sampling review of procedures for audit, surveillance and plant evaluation during the QE evaluation process to determine the effectiveness of all plant procedures. As part of existing audit activities, the QC group within the PIA organization reviews a selection of quality program procedures to assure that they are properly maintained. The Plant Safety Review Committee (PSRC) continues to review administrative control procedures and revisions, as well as any procedures and revisions that require a 10 CFR 50.59 evaluation.

As noted above, the licensee has established numerous programmatic controls that assure procedures are appropriately reviewed and revised to incorporate information based on plant operations, design changes, vendor recommendations, regulatory requirements, corrective actions, industry experience and other inputs that may affect plant procedures.' The redundant QE reviews of administrative procedures are not necessary and can be deleted.

3.0 CONCLUSION

Based on the previously determined acceptability of the QRP process in Amendment 73 as noted above, and the provisions for procedure reviews by the QR, sampling reviews by the QE.

and QC Groups, and the PSRC, deletion of the redundant responsibility of the QE Group to

. review administrative procedures, a function already performed under the QRP, is determined to be acceptable. This programmatic change is consistent with acceptance criterion 2 in Part 17.2.6 in NRC's Standard Review Plan (NUREG-0800) Section 17.2, and continues to meet the requirements of 10 CFR Part 50, Appendix B.

' Principal Contributor:.W. Haass Date:

March 30,1998 I

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