ML12278A386
| ML12278A386 | |
| Person / Time | |
|---|---|
| Site: | Palisades, Indian Point, Grand Gulf, Pilgrim, Arkansas Nuclear, River Bend, Vermont Yankee, Big Rock Point, FitzPatrick  |
| Issue date: | 10/04/2012 |
| From: | Kalyanam N Plant Licensing Branch IV |
| To: | Ford B Entergy Operations |
| Kalyanam N | |
| 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: ML12278A386 (7) | |
Text
From:
Kalyanam, Kaly To:
Ford, Bryan Cc:
BICE, DAVID B; CLARK, ROBERT W; MASON, MICHAEL E (WF3)
Subject:
Request for Additional Information - Entergy Fleet LAR on Change to QAPM and Asociated ISs regarding Staff Qualifications Date:
Thursday, October 04, 2012 3:21:00 PM DATE: October 4, 2012
TO: BRYAN FORD
SUBJECT:
WATERFORD STEAM ELECTRIC STATION, UNIT 3 - REQUEST FOR ADDITIONAL INFORMATION ON REQUESTED LICENSING ACTION RE: LICENSE AMENDMENT REQUEST FOR APPROVAL OF CHANGE TO THE ENTERGY QUALITY ASSURANCE PROGRAM MANUAL (QAPM) AND ASSOCIATED PLANT TECHNICAL SPECIFICATIONS REGARDING STAFF QUALIFICATIONS (TAC NOS. ME7774, ME7775, ME7776, ME7777, ME7778, ME7779, ME7780, ME7781, ME7782, ME7783, ME7784, ME7785, AND ME7786)
ME7774, ARKANSAS NUCLEAR 1 Docket No. 50-313 ME7775, ARKANSAS NUCLEAR 2 Docket Nos. 50-368 and 72-13 ME7776, BIG ROCK POINT Docket Nos. 50-155 and 72-43 ME7777, FITZPATRICK Docket Nos. 50-333 and 72-12 ME7778, GRAND GULF 1 Docket Nos. 50-416 and 72-50 ME7779, INDIAN POINT 1 Docket No.50-003 ME7780, INDIAN POINT 2 Docket No. 50-247 ME7781, INDIAN POINT 3 Docket Nos. 50-286 and 72-51 ME7782, PALISADES Docket Nos. 50-255 and 72-7 ME7783, PILGRIM 1 Docket No. 50-293 ME7784, RIVER BEND 1 Docket Nos. 50-458 and 72-49 ME7785, VERMONT YANKEE Docket Nos. 50-271 and 72-59
- Bryan,
By letter dated December 13, 2011, as supplemented by your letter dated May 21, 2012, Entergy Operations Inc. submitted a license amendment request for the above subject plants. The proposed amendment requests approval of proposed changes to the Quality Assurance Program Manual (QAPM) and Technical Specifications (TS) for the above subject plants. The proposed changes standardize unit staff qualification requirements for the Entergy fleet. Some proposed changes to the QAPM are a reduction in commitment, in accordance with 10 CFR 50.54(a)(4), NRC approval is required prior to implementation.
The related TS changes for unit staff qualifications were requested in accordance with 10 CFR 50.90.
The NRC Staff has reviewed the amendment request and determined that we require
additional information to complete our review. The request for additional information is provided below. The NRC staff requests you to provide a response to the RAI within 45 days from the date of this email.
Thanks
Kaly N, Kalyanam PM, Waterford 3 and ANO 1 & 2 NRR/DORL/LPL4
REQUEST FOR ADDITIONAL INFORMATION REGARDING THE CHANGES
TO THE ENTERGY QUALITY ASSURANCE PROGRAM MANUAL (QAPM)
AND ASSOCIATED PLANT TECHNICAL SPECIFICATIONS
REGARDING STAFF QUALIFICATIONS
The Nuclear Regulatory Commission (NRC) staff is reviewing the Entergy license amendment request (LAR) dated December 13, 2011. The LAR proposes to update Technical Specifications (TSs) having to do with personnel qualifications in order to standardize TSs across the fleet, and also, to relocate them in the common fleet QAPM.
The NRC staff has determined that the following information is required to complete its review.
- 1. In Enclosure 1 on page 7 of 12, the licensee makes the following statement:
The QAPM states 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.
If there is no documentation that justifies how these individuals are qualified for their positions, explain how auditors or inspectors will know that these individuals are in compliance with licensee commitments. For example, if the commitment in the QAPM requires a four-year degree and the individual has extensive experience but no degree, how would one know that this person has been grandfathered?
- 2. Because the text description of the proposed changes that was provided by the licensee is so complex and difficult to follow, the staff requests that a Table or Tables be provided that shows each plant on the Y-axis and the current commitments and proposed commitments on the X-axis. For example:
Plant Name Current Commitments Proposed Commitments
ANS/ANSI RG 1.8 TS ANS/ANSI RG 1.8 TS ANO-1, Units 1 & 2
General Population ANS/ANSI 3.1-1978
?
?
ANS/ANSI 3.1-1978
?
Exceptions in QAPM, not TS
QA Manager
?
?
?
Exception to ANS/ANSI 3.1-1978
?
This position will not be in TS
Rad. Pro.
Mgr
?
Rev.1, Sept.
1975
?
N/A Rev 2,
1987
?
?
?
Ref.
Commission policy statement ANS/ANSI 3.1-1993 Rev.
3, 2000 ISTS wording plus Modes
Ops Manager
?
?
or Assistant are SRO licensed N/A
N/A or Assistant are SRO licensed
- 3. It is not clear what is being changed in the TS markups. The staff is not sure whether the rev bars are part of the markup or whether the rev bars are from a previous revision. Therefore, the staff requests that the proposed TS be provided in a clean, typed format.
- 4. Entergy's proposed revision to the QAPM adds Insert 4 to specifically address training commitments as follows:
Insert 4:
- 5. ANSI/ANS 3.1 Section 5 Entergy will maintain a training program for the unit staff that meets the applicable regulations and either a) is accredited by the National Nuclear Accrediting Board (NNAB) or b) meets the standards of Section 5 of ANS/ANS 3.1-1978.
Entergy stated that the commitment to the accredited program is an enhancement to the current standard of ANSI/ANS 3.1-1978, as the NNAB accreditation is more rigorous.
The accreditation alternative to the ANSI requirements is consistent with the NRC's previous positions on the adequacy of operator training programs accredited by the NNAB. Entergy stated that commitment to the accredited program is an enhancement to the current standard of ANSI/ANS 3.1-1978. Entergy states in Insert 4 it will meet the more rigorous elements of the National Nuclear Accrediting Board (NNAB) or the less rigorous Section 5 of ANS/ANS 3.1-1978.
Provide clarification on the how Entergy will implement Insert 4 to enhance the ANS/ANS 3.1-1978 standard and not circumvent the more restrictive NNAB requirements.
- 5. Entergys proposed Insert 1 to the QAPM states:
- a. The radiation protection manager shall meet or exceed the qualifications of Regulatory Guide 1.8, Revision 2, 1987.
Entergy is currently committed to ANSI/ANS 3.1-1978. Section 4.4.4 of this standard states the following: At the time of initial core loading or appointment to active position, the responsible person shall have a minimum of five years experience in radiation protection at a nuclear reactor facility. A minimum of two years of this five years experience should be related technical training. A maximum of four years of the five years experience may be* fulfilled by related technical or academic training.
ANSI/ANS 3.1-1987, endorsed by Regulatory Guide 1.8, Revision 2, states:
4.3.3 Radiation Protection. The individual responsible for management of the radiological protection program.
Education: Baccalaureate in science, health physics, or engineering.
Minimum experience for the position:
Related experience 4 Yr which shall include Nuclear Power Plant 3 Yr Supervisory or Management 1 yr On-site 0.50 yr.
Special Requirements:
(1) Management and supervisory skills in accordance with those specified in 6.3.
(2) During the years of nuclear power plant experience, the individual shall have participated in supervision or management activities at an operating nuclear power plant during the following periods:
(a) 1 month of routine refueling outage, and (b) 2 months of operation above 20% power.
ANSI/ANS 3.1-1987, Section 6.3, Initial Training, states:
An initial training program shall be established to develop or enhance the skills, knowledge and ability of personnel to perform job assignments. These personnel shall not make decisions or take actions affecting plant safety until they meet the performance requirements of the job position assigned.
However, they may independently perform specific tasks or job assignments for which they are qualified.
Provide clarification on the reduction in the minimum years experience required for the radiation protection manager at the Entergy facilities. Also, provide clarification if Entergy intends to meet the above Special Requirements in ANSI/ANS 3.1-1987
- 6. Entergy proposes adding the following Inserts to Entergys QAPM:
Insert 2:
- 3. ANSI/ANS 3.1 Section 4 Individuals assigned to professional-technical comparable positions shall have the authority and specified qualifications to accomplish the functional responsibilities of the position.
Insert 3:
- 4. ANSI/ANS 3.1 Section 4.4.5 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 factor are evaluated on a case-by-case basis and approved and documented by senior
management.
Insert 4:
- 4. ANSI/ANS 3.1 Section 5 Entergy will maintain a training program for the unit staff that meets the applicable regulations and either a) is accredited by the National Nuclear Accrediting Board (NNAB) or b) meets the standards of section 5 of ANSI/ ANS 3.1-1978.
Provide clarification on what revision of ANSI/ANS 3.1 Entergy is using for the above Inserts. Also, provide clarification if Insert 2 is citing the correct section of the ANSI-3.1 standard that Entergy is using.
- 7. Entergy proposes adding the following insert to the QAPM:
Insert 3:
- 4. ANSI/ANS 3.1 Section 4.4.5 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 factor are evaluated on a case-by-case basis and approved and documented by senior management.
The NRC believes Insert 3 is a partial statement from RG 1.8, Revision 3, which states:
2.1.1 Section 4.3.7, Quality Assurance Individuals who do not possess the formal educational and experience requirements specified in this section for this position will not be eliminated automatically when other factors provide sufficient demonstration of their abilities. These other factors are to be evaluated on a case-by-case basis and approved and documented by the plant manager. However, the individual assigned to this position is to meet the Special Requirements in Section 4.3.7.
ANSI/ANS 3.1-1993, section 4.3.7 states in part:
Special Requirements:
- 1. Management and supervisory skills in accordance with those specified
in 6.3.
- 2. Shall have 1 year of experience performing quality verification activities.
Also, ANSI/ANS 3.1-1993, section 6.3 states:
Managers (see 4.2) and Middle Managers (see 4.3) should have had training or experience in supervision or management. Training for supervisors (see 4.4) should develop their skills in the following:
- 1. Leadership
- 2. Interpersonal communication
- 3. Management responsibilities and limits
- 4. Motivation of personnel 5 Problem analysis and decision making
- 6. Administrative policies and procedures
Provide clarification if Entergy intends to meet the above Special Requirements in ANSI 3.1-1993 when implementing the proposed Insert 3. Also, provide clarification on the reduction in the minimum years experience required at the Entergy facilities.