ML20236R913

SER Accepting Rev 13 to Quality Assurance Program for Operation Policy Document for Plant

ML20236R913
Person / Time
Site:	Cooper
Issue date:	07/20/1998
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20236R909	List: ML20236R906 ML20236R913
References
NUDOCS 9807240010
Download: ML20236R913 (3)

Text

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a RE g 1 UNITED STATES g

e j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 30806 4001 o .

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION QUALITY ASSURANCE PROGRAM FOR OPERATION POLICY DOCUMENT REVISION 13 NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLEAR STATION DOCKET NO 50-298

1.0 INTRODUCTION

in a letter dated May 2,1997, Nebraska Public Power District (NPPD) submitted Revision 13 to the Quality Assurance Program for Operations Policy Document (QAPOPD) for the Cooper Nuclear Station (CNS). Revision 13 contains proposed changes to the QAPOPD that are reductions in commitment requiring NRC review for acceptability in accordance with 10 CFR 50.54(a)(3). The changes involve the removal and clarification of prior commitments regarding the reviews of procedures and certain other line-organization generated documents by the Quality Assurance Department (QAD) and instead the QAD will perform periodic oversight reviews. The QAD will continue to conduct performance based reviews of line documents as determined necessary by performance trending analyses, as well as routine auditing and surveillance. The NRC staff requested additionalinformation on the proposed changes by letter dated December 15,1997. NPPD responded to that request by letter dated February 3,1998.

2.0 EVALUATION Through Revision 12, the Quality Assurance Program (QAP) for the CNS provided for three levels of quality assurance responsibilities:

a. The First Level assigns responsibility to each person performing work to adhere to quality practices and procedures in accordance with the QAPOPD and applicable procedures.

Other individuals from the line organization, other than the one doing the work, are responsible for the quality control (QC) functions.

b. The Second Level assigns responsibility to supervision and management personnel to assure the availability of necessary procedures and guidance for performing quality work.

The supervisors and managers are responsible for oversight of the work involved. The j QAD managers are responsible for assuring controlling documents include appropriate quality requirements,

c. The Third Level assigns responsibility to the QA staff for the conduct of surveillance, evaluations and audits of activities which affect quality to assure that QC inspections are implemented and that quality requirements are met. These are independent personnel that may be from the line organizations but not involved in the work activities being 9907240010 990720 PDR ADOCK 05000298

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2 audited and assigned to the QAD for this effort. The QA staff is also responsible for the evaluation of audit results and for verifying that corrective action requirements have been implemented. {

I in Revision 13, the licensee proposes to modify the Second Level responsibilities of the QAD by deleting day-to-day involvement in assuring that work controlling documents include appropriate quality requirements instead, QAD would perform a periodic review of such documents for

, quality requirements, leaving the day-to-day responsibilities to the line organization. Activities affected by this modification include: j

. review and evaluation of all design changes including verification of compatibility with applicable codes, standards and regulatory requirements, and consideration of technical requirements such as reactor physics, stress, thermal-hydraulics, and accident analysis,

. review of procurement documents for technical and quality adequacy,

. review of control procedures and documentation for special processes, special test procedures, and special maintenance procedures,

. review of maintenance modification control methods and Station Operating procedures to verify that necessary codes, standards, quality requirements, and acceptance criteria are incorporated, and a review of allwork procedures.

The licensee's justification for the reduction of the QAD involvement in day-to-day review of documents affecting the above listed activities is that all line organization personnel at CNS, including supervisors and managers, are held responsible for performing quality work in accordance with the three level quality assurance program (Table 2 in the QAPOPD) which is the foundation for the CNS QAP. All Nuclear Power Group personnel are given QA indoctrination training and all CNS personnel receive training to familiarize them with the quality assurance program. In Revision 13, the licensee has also committed, as a facet of the Second Level of QA responsibilities, that the QAD will perform periodic reviews of controlling documents in the above listed areas to evaluate the inclusion of appropriate quality requirements. Further, under the Third Level of QA responsibilities, the QAD conducts surveillance, evaluations, and audits of activities which affect quality to assure that QC and inspection programs are property implemented and include appropriate quality requirements, The licensee's February 3,1998, response to the staff's December 15,1997, request for additional information was discussed in greater detail in a meeting with NRC staff on April 29, 1998. In that meeting, the licenses stated that, based on problems identified by performance trending analyses, current negative performance of quality input to procurement documents of a

. recurring nature, especially in the receipt inspection and services contracting activities, has resulted in continued oversight by QAD rather than the planned relaxation as described above.

In addition, incidences of improper input to procurement documents discovered and documented as conditions adverse to quality within the formal corrective action program are representative of the negative trend. The licensee has indicated that performance trending analyses will continue to be used to assess the adequacy of QA functional performance by the line organizations to determine the need for restoration of day-to-day rather than periodic QA staff oversight.

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3.0 CONCLUSION

S Based on the staffs review of the proposed changes to the QAPOPD for CNS, Revision 13, and the supplementary information provided by the licensee in their February 3,1998, response to the NRC request for additional information dated December 15,1997, the staff concludes that the proposed changes to Revision 13 of the QAPOPD to eliminate day-to-day reviews of l procedures and certain other line-organization generated documents by QAD are acceptable and Revision 13 continues to satisfy the criteria of 10 CFR Part 50, Appendix B. Line organization i individuals will continue the prior commitment to perform these functions with periodic oversight i

by QAD personnel. QAD personnel will perform periodic oversight of these QA activities and i audits and surveillance will be conducted by QAD with assistance by qualified and independent l line organization personnel as necessary. Performance trending analyses will continue to be

conducted to identify problem areas needing a restoration of full time QAD oversight.

t l Principal Contributor: Walter P. Haass l Dated:

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