ML120960449

ANO 1 & 2, Big Rock, FitzPatrick, GGNS, Indian Point 1, 2 & 3, Palisades, Pilgrim, RBS, Vermont Yankee, and Waterford - Request for Additional Information, Revise Quality Assurance Program Manual and Staff Qualification Technical Specificat

ML120960449
Person / Time
Site:	Palisades, Indian Point, Grand Gulf, Pilgrim, Arkansas Nuclear, River Bend, Vermont Yankee, Big Rock Point, FitzPatrick
Issue date:	04/05/2012
From:	Kalyanam K Plant Licensing Branch IV
To:	Ford B Entergy Operations
Kalyanam N, NRR/DORL/LPL4, 415-1480
Shared Package
ML120960412	List: ML120960423 ML120960449
References
TAC ME7774, TAC ME7775, TAC ME7776, TAC ME7777, TAC ME7778, TAC ME7779, TAC ME7780, TAC ME7781, TAC ME7782, TAC ME7783, TAC ME7784, TAC ME7785, TAC ME7786
Download: ML120960449 (3)

Text

REQUEST FOR ADDITIONAL INFORMATION REGARDING THE ENTERGY QUALITY ASSURANCE PROGRAM MANUAL (QAPM) AND ASSOCIATED PLANT TECHNICAL SPECIFICATIONS REGARDING STAFF QUALIFICATIONS, REVISION 22 Regulatory Commitments - Table 1.

1.0.1 Entergys QAPM, Revison 21, Table 1, Regulatory Commitments states that Entergy is committed to Regulatory Guide 1.8, Revision 1, dated 1975. The QAPM, Revision 21, Clarification/Exception section states, Qualification requirements for personnel, other than Licensed Operators covered under 10 CFR 55, shall meet ANSI/ANS 3.1 1978 except for positions where an exception to either ANSI/ANS 3.1-1978 or N18.1 -1971 is stated in the applicable units Technical Specifications. If an exception exists for a given position, the applicable units Technical Specification qualification requirements shall apply. The proposed revision to the QAPM will delete the above statement and replace it with:

Entergy is committed to Sections 1 - 4 of ANSI/ANS 3.1-1978 with following clarifications and exceptions.

Qualification requirements for personnel shall meet ANSI/ANS 3.1-1978 except the following:

a. The radiation protection manager shall meet or exceed the qualifications of Regulatory Guide 1.8, Revision 2, 1987.

b. Managers required to hold an SRO license are specified in the applicable unit's Technical Specifications.

c. Licensed Operators shall be qualified in accordance with the requirements of 10 CFR 55.

The proposed QAPM revision will remove the referenced N18.1 -1971 Standard that Regulatory Guide 1.8 endorses. Please provide clarification of what revision of Regulatory Guide 1.8 Entergy will be committed to when the Regulatory Guide 1.8, Revision 1, which endorsed Standard N18.1-1971, is removed.

1.0.2 Entergys current QAPM states in part:

Individuals filling positions who met the previous commitment at the time of implementation of this commitment can be considered to meet any more restrictive aspects of the requirements of this commitment for that position without further review and documentation.

Entergys proposed revision to the QAPM adds the proposed insert:

Individuals who do not possess the formal education and minimum experience requirements for the manager responsible for quality assurance should not be eliminated automatically when other factors provide sufficient demonstration of their abilities. These other factors are evaluated on a case-by-case basis and approved and documented by senior management.

The current statement in the QAPM and the proposed insert are in conflict with each other.

Please provide clarification on how Entergy plans to evaluate individuals on a case-by-case basis for acceptability if the current statement is not removed.

1.0.3 Entergys proposed revision to the QAPM will state:

Entergy is committed to Sections 1 - 4 of ANSI/ANS 3.1-1978 with following clarifications and exceptions.

Qualification requirements for personnel shall meet ANSI/ANS 3.1-1978 except the following:

a. The radiation protection manager shall meet or exceed the qualifications of Regulatory Guide 1.8, Revision 2, 1987.

b. Managers required to hold an SRO license are specified in the applicable unit's Technical Specifications.

c. Licensed Operators shall be qualified in accordance with the requirements of 10 CFR 55.

Entergys proposed revisions to the affected plants TS states, Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI/ANS 3.1-1978 for comparable positions with exceptions specified in the Entergy QAPM. Please provide clarification on the extent of use of ANSI/ANS 3.1-1978.

1.0.4 Entergy QAPM, Table 1, Regulatory Commitments, page 21 commits to Regulatory Guide 1.8, Revision 1, dated September 1975. The Clarification/Exception of this section does not clearly state the affected sections of the standard requiring the clarification or exception. Please provide clarification by identifying the clarifications and exceptions taken from Regulatory Commitments as in other sections of Table 1.

1.0.5 10 CFR 50.54(a)(4) states in part that, Changes to the quality assurance program description that do reduce the commitments must be submitted to the Nuclear Regulatory Commission (NRC) and receive NRC approval prior to implementation. The regulation also states, the submittal of a change to quality assurance program description must include all pages affected by that change and must be accompanied by a forwarding letter identifying the change, the reason for the change, and the basis for concluding that the revised program incorporating the change continues to satisfy the criteria of appendix B of this part and the Safety Analysis Report quality assurance program description commitments previously accepted by the NRC (the letter need not provide the basis for changes that correct spelling, punctuation, or editorial items). The use of ANSI/ANS 3.1-1978 is not approved by the NRC for Fitzpatrick, Palisades, Pilgrim and Vermont Yankee. Entergys current submittal does not provide an evaluation of this standard and reasons for change.

Please provide an evaluation on the acceptability of a quality assurance alternative that deviates from the earlier NRC approved N18.1 -1971 standard.

1.0.6 Entergys QAPM, Revision 21, Table 1, Regulatory Commitments states that Entergy is committed to Regulatory Guide 1.8, Revision 1, dated 1975. The QAPM, Revision 21, Clarifications/Exception section states, Qualification requirements for personnel, other than Licensed Operators covered under 10 CFR 55, shall meet ANSI/ANS 3.1 1978 except for positions where an exception to either ANSI/ANS 3.1-1978 or N18.1 -1971 is stated in the applicable units Technical Specifications. If an exception exists for a given position, the applicable units Technical Specification qualification requirements shall apply. Entergy is proposing to change the QAPM to the following:

Entergy is committed to Sections 1 - 4 of ANSI/ANS 3.1-1978 with following clarifications and exceptions.

Qualification requirements for personnel shall meet ANSI/ANS 3.1-1978 except the following:

a. The radiation protection manager shall meet or exceed the qualifications of Regulatory Guide 1.8, Revision 2, 1987.

b. Managers required to hold an SRO license are specified in the applicable unit's Technical Specifications.

c. Licensed Operators shall be qualified in accordance with the requirements of 10 CFR 55.

10 CFR 50.120 provides for a system approach to training in accordance with 10 CFR 55.4.

The requirements are for a non-licensed operator, shift supervisor, shift technical advisor, instrument and control technician, electrical maintenance personnel, mechanical maintenance personnel, radiological protection technician, chemistry technician, engineering support personnel. Please provide clarification on how Entergys QAPM will address training for managers, supervisors, and general personnel.