0CAN082101, Units 1 and 2 - Changes to the Quality Assurance Program Approval Form for Radioactive Material Package No. 0341

Units 1 and 2 - Changes to the Quality Assurance Program Approval Form for Radioactive Material Package No. 0341

ML21222A112
Person / Time
Site:	Arkansas Nuclear, 07100341
Issue date:	08/10/2021
From:	Keele R Entergy Operations
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
0CAN082101
Download: ML21222A112 (6)

Text

Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-7826 Riley D. Keele, Jr.

Regulatory Assurance Manager Arkansas Nuclear One 10 CFR 71.106 0CAN082101 August 10, 2021 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Changes to the Quality Assurance Program Approval Form for Radioactive Material Package No. 0341 Arkansas Nuclear One - Units 1 and 2 NRC Docket Nos. 50-313 and 50-368; 71-0341 and 72-13 Renewed Facility Operating License Nos. DPR-51 and NPF-6 REFERENCE 1) U. S. Nuclear Regulatory Commission (NRC) to Entergy Operations, Inc.

(Entergy), "Revised Quality Assurance Program Approval Form for Radioactive Material Packages No. 0341, Revision 9," Arkansas Nuclear One, (0CNA081505) (ML15236A124), dated August 17, 2015.

2) NRC to Entergy, "Arkansas Nuclear One, Units 1 and 2 - Request for Approval to Changes to the Entergy Quality Assurance Program Manual (EPID L-2020-LLQ-0005," (0CNA052104) (ML21132A279), dated May 19, 2021.

On June 12, 2015, the NRC issued a final rulemaking to amend 10 CFR 71 regulations. Among the changes made was an update to the administrative procedures for the quality assurance program requirements described in 10 CFR 71, Subpart H. Specifically, 10 CFR 71.38 has been amended to remove the requirements for the renewal of Quality Assurance Program Approvals, and 10 CFR 71.106 was added to establish requirements that will apply to changes to quality assurance programs.

Quality Assurance Program Approval for Radioactive Material Packages Number 0341, Revision 9, was issued to Entergy Operations, Inc., Arkansas Nuclear One (ANO), Units 1 and 2, on August 17, 2015 (Reference 1). 10 CFR 71.106 requires changes that are made to the ANO quality assurance program that do not reduce commitments must be submitted to the NRC every 24-months, with the reporting period starting on the date the latest approval was

0CAN082101 Page 2 of 2 given. This submittal is required even if no changes were made to the program in the previous 24-months.

The purpose of this submittal is to provide the required notification to the NRC of changes made to the quality assurance program for radioactive material packages during the reporting period of August 2019 to July 2021.

A summary of the changes made during this reporting period to the Entergy Quality Assurance Program Manual (QAPM) is provided in the attachment to this letter. It should be noted that all but the current revision (Revision 41) of the QAPM were made with no reductions to any commitment. Revision 41 represents a reduction in a commitment; however, the change is related to the American Society of Mechanical Engineers Code,Section XI, Repair /

Replacement programs only. The NRC approved the revision to the QAPM (Reference 2).

All the changes to the Entergy QAPM during this reporting period, summarized in the attachment, did not reduce any commitments related to the Quality Assurance Program Approval for Radioactive Material Packages Number 0341, Revision 9.

This submittal fulfills the 10 CFR 71.106 reporting requirements for this time period.

This letter contains no new regulatory commitments.

If you have any questions or require additional information, please contact Riley D. Keele Jr.,

Manager, Regulatory Assurance, at 479-858-7826.

Sincerely, ORIGINAL SIGNED BY RILEY D. KEELE, JR.

RDK/rwc

Attachment:

Summary of Changes to Entergy's Quality Assurance Program Manual - from August 2019 to July 2021 cc: NRC Region IV Regional Administrator NRC Senior Resident Inspector - Arkansas Nuclear One NRC Project Manager - Arkansas Nuclear One

Attachment to 0CAN082101 Summary of Changes to Entergy's Quality Assurance Program Manual from August 2019 to July 2021

Attachment to 0CAN082101 Page 1 of 3

SUMMARY

OF CHANGES TO ENTRGY'S QUALITY ASSURANCE PROGRAM MANUAL FROM AUGUST 2019 TO JULY 2021 Provided below are the summaries of the changes made to Entergy Operations, Inc., (Entergy)

Quality Assurance Program Manual (QAPM) during the reporting period of August 2019 to July 2021.

REVISION 38

1. This change to the Entergy Quality Assurance Program Manual (QAPM) separated the Indian Point Energy Center (IPEC) QAPM from the Entergy Fleet QAPM. The separation of IPEC from the Entergy QAPM is in preparation for the decommissioning of the IPEC.

To support the implementation of ongoing quality assurance activities and the transition to a decommissioning facility, IPEC adopted the Entergy QAPM under the guidance provided in 10 CFR 50.54(a)(3) and established a site-specific IPEC QAPM using the Entergy QAPM as the basis. The IPEC QAPM contains the same requirements and commitments as the current Entergy QAPM. The changes made to support this transition and allow the adoption of the Entergy QAPM involved primarily administrative changes to reflect a site-specific QAPM. These changes were assessed using the guidance provided in 10 CFR 50.54(a)(3) and did not constitute a reduction in commitments to the previously approved quality assurance program. (Reference letter NL-20-024 (ML20113E817) to the NRC dated April 22, 2020).

2. The Entergy QAPM cover sheet was changed to reflect the removal of the IPEC Unit 1, Unit 2, and Unit 3 docket numbers from the cover page. The Energy QAPM revision number was updated on all pages to Revision 38.

REVISION 39

1. Entergy QAPM Revision 38, Change 1, allows a grace period not to exceed 25% for audit interval for supplier audits. This is a reduction in commitment from the previously approved QAPMs. The current requirement of a 90-day grace period was submitted and approved in the Entergy QAPM, Revision 3, submitted via CNRO2000-00012 and accepted by the NRC, ADAMS Accession No.: ML003711555 and IPEC QAPM, Revision 0, submitted via NL-20-04 and accepted by the NRC. While the 25% grace period represents a reduction in commitment from the previously approved Entergy and IPEC QAPMs, the change has been previously evaluated and approved by the NRC, as documented in Southern Nuclear Company SER, approved June 17, 2005, ADAMS Accession No.: ML051570349.

2. Entergy QAPM Revision 38, Change 2, reduces the meeting frequency for the Safety Review Committee (SRC) meeting from twice per year to once per year. This is a reduction in commitment from the previously approved QAPMs. Entergy is committed to ANSI N18.7 1976, section 4.3.2.2, defining the meeting frequency for the independent review body as no less than twice per year. Entergy never took exception to this requirement; thus, Entergy is committed to this requirement in Revision 0 of the Entergy QAPM, submitted via CNRO1998-00025 and accepted by the NRC, letter dated

Attachment to 0CAN082101 Page 2 of 3 November 6, 1998; and IPEC QAPM, Revision 0, submitted via NL-20-04 and accepted by the NRC. While changing the SRC meeting frequency to once per year represents a reduction in commitment from the previously approved Entergy and IPEC QAPMs, the change has been previously evaluated and approved by the NRC, as documented in Nuclear Management Company, LLC, (NMC) SER, dated January 13, 2005, ADAMS Accession No.: ML050210276. This SER removes the requirement for the SRC completely; however, Entergy will use this SER to reduce the frequency for the meeting of the SRC and the SRC will still meet once per year and perform reviews as specified by ANSI N18.7-1976.

The On-site Safety Review Committee and Nuclear Independent Oversight currently perform the reviews the SRC performs, and these reviews will be used to supplement the reviews by the SRC when the meeting frequency is reduced.

These changes to the Entergy QAPM were issued in conjunction with the same changes to the IPEC QAPM. Entergy QAPM Revision 38, Change 1 and Change 2 were incorporated into Entergy QAPM Revision 39, effective July 16, 2020. IPEC QAPM Revision 1, Change 1 and Change 2 were incorporated into IPEC QAPM Revision 2, effective July 16, 2020.

REVISION 40

1. QAPM Revision 39, Change 1, modifies the QAPM to exempt American Society of Mechanical Engineers (ASME) Code Case N-752 Low Safety Significant (LSS) Class 2 and 3 structures, systems, and components (SSCs) from the requirements of the QAPM. This change has been submitted to the NRC for approval in letter 0CAN112001 dated November 17, 2020. This change has not been completed.

2. QAPM Revision 39, Change 2, is an update to the Entergy nuclear corporate and site organizational structure which alters the site records management reporting relationship. The management position for site records management will no longer report off-site to the Vice-President (VP) Regulatory Affairs, but instead will report to the site VP through the site Performance Improvement manager.

3. QAPM Revision 39, Change 3, reflects organizational changes made within the Entergy Nuclear senior executive organization as allowed by 10 CFR 50.54(a)(3)(iii) and 10 CFR 50.54(a)(3)(vi). This organizational change eliminates the position Senior VP Nuclear Operations, changes the reporting relationships for all three Chief Operating Officer (COO), Nuclear Operations positions from reporting to the Senior VP Nuclear Operations to reporting to the Executive VP, Nuclear Operations / Chief Nuclear Officer (CNO), creates a new position Senior VP, Corporate Services reporting to the CNO, and changes the reporting relationships for the following positions from reporting to the Senior VP Nuclear Operations to reporting to the new position Senior VP, Corporate Services: VP, Outage Services, VP, Operations Support, and VP, Regulatory Assurance.

These changes to the Entergy QAPM were issued in conjunction with the same changes to the IPEC QAPM. These changes were incorporated into Entergy QAPM Revision 40, effective February 7, 2021 and the IPEC QAPM Revision 3, effective February 7, 2021.

Attachment to 0CAN082101 Page 3 of 3 REVISION 41 (Current revision)

This change added an exemption to the Entergy QAPM, Section A.7 for the implementation of ASME Section XI Code Case N-752, "Risk-Informed Safety Classification and Treatment for Repair/Replacement Activities in Class 2 and 3 Moderate Energy Systems," for treatment of safety-related Structures Systems and Components (SSCs) regarding treatment of Low Safety Significant (LSS) in lieu of the associated QA requirements provided 10 CFR 50 Appendix B or NQA-1 is not required at the nuclear site.

Revision 41 represents a reduction in a commitment; however, the change is related to the American Society of Mechanical Engineers Code,Section XI, Repair / Replacement programs only. The NRC approved the revision to the QAPM (Reference 1).

CONCLUSION All the changes to the Entergy QAPM during this reporting period, summarized in the attachment, did not reduce any commitments related to the Quality Assurance Program Approval for Radioactive Material Packages Number 0341, Revision 9.

REFERENCE

1. NRC to Entergy, "Arkansas Nuclear One, Units 1 and 2 - Request for Approval to Changes to the Entergy Quality Assurance Program Manual (EPIDL 2020-LLQ-0005," (0CNA052104)

(ML21132A279), dated May 19, 2021.