ML13025A306
| ML13025A306 | |
| Person / Time | |
|---|---|
| Site: | Palisades, Indian Point, Grand Gulf, Pilgrim, Arkansas Nuclear, River Bend, Vermont Yankee, Waterford, Big Rock Point, FitzPatrick  |
| Issue date: | 03/14/2013 |
| From: | Kalyanam N Plant Licensing Branch IV |
| To: | Mccann J 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: ML13025A306 (23) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 IVJarch 14, 2013 Mr. John F. McCann Director, Nuclear Safety and licensing Entergy Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601
SUBJECT:
CORRECTION TO AMENDMENTS ISSUED ON DECEMBER 28, 2012, FOR THE ENTERGY FLEET RE: REQUEST FOR APPROVAL OF CHANGE TO THE ENTERGY QUALITY ASSURANCE PROGRAM MANUAL AND ASSOCIATED PLANT TECHNICAL SPECIFICATIONS REGARDING STAFF QUALIFICATIONS REQUIREMENTS (TAC NOS. ME7774 TO ME7786)
Dear Mr. McCann:
By letter dated December 28, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12347A140), the U.S. Nuclear Regulatory Commission (NRC) issued the following amendments consisting of changes to the Technical Specifications (TSs) in response to your application dated December 13, 2011, as supplemented by letters dated May 21 and November 20,2012 (ADAMS Accession Nos. ML11356A278, ML12145A195, and ML12328A039, respectively):
Amendment Nos. 248 and 296 to Renewed Facility Operating license Nos. DPR-51 and NPF-6 for Arkansas Nuclear One, Unit Nos. 1 and 2; Amendment No. 304 to Renewed Facility Operating license No. DPR-59 for James A. FitzPatrick Nuclear Power Plant; Amendment No. 193 to Facility Operating license No. NPF-29 for Grand Gulf Nuclear Station, Unit 1; Amendment Nos. 271 and 248 to Facility Operating license Nos. DPR-26 and DPR-64 for Indian Point Nuclear Generating Unit Nos. 2 and 3; Amendment No. 249 to Renewed Facility Operating license No. DPR-20 for Palisades Nuclear Plant; Amendment No. 239 to Renewed Facility Operating license No. DPR-35 for Pilgrim Nuclear Power Station; Amendment No. 178 to Facility Operating license No. NPF-47 for River Bend Station, Unit 1;
J. McCann
- 2 Amendment No. 253 to Renewed Facility Operating License DPR-28 for Vermont Yankee Nuclear Power Station; and Amendment No. 240 to Facility Operating License No. NPF-38 for Waterford Steam Electric Station, Unit 3.
The licensee's letter dated December 13, 2011, did not discuss or include the proposed amendment to Big Rock Point. The licensee's letter dated November 20, 2012, which was essentially a response to the request for additional information, mentioned the change to the Big Rock Point TS. This lack of clarity resulted in the exclusion of Big Rock Point from the fleet amendment issued on December 28, 2012. Subsequently, Mr. Bryon Ford of Entergy Operations, Inc, in a telephone conversation clarified the need for inclusion of Big Rock Point in the November 20, 2012, letter.
Accordingly. we are revising the fleet amendment dated December 28,2012, and the enclosure to this letter includes the following revised/new pages to be replaced in the fleet amendment:
Corrected page 2 of the December 28, 2012, transmittal letter and the concurrence page (to include the Big Rock Point amendment as the last bUlleted item and revise the list of enclosures);
New Enclosure 12 with Attachment - Amendment No. 128 to Facility Operating License No. DPR-6 for Big Rock; page 3 of Facility Operating License DPR-6; and page 6-2 of the Big Rock Point Defueled Technical Specifications; and Revised safety evaluation (SE) page 1 (to renumber as Enclosure 13) and pages 15-25 (to add new SE Section 3.1.12 for Big Rock Plant and subsequent renumbered SE pages).
This correction does not change the NRC staff's conclusions regarding the amendments for the Entergy plants listed in the December 28, 2012, letter.
A correction to the Notice of Issuance published in the Federal Register on January 22, 2013 (78 FR 4475-4476), will be forwarded to the Office of the Federal Register.
J. McCann
- 3 If you have any questions, please contact me at (301) 415-1480 or by-mail at kaly. kalyanam@nrc.gov.
Sincerely, N. Kalyanam, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-313, 50-368, 72-13, 50-155,72-43,50-333,72-12, 50-416, 72-50,50-003,50-247,50-286,72-51, 50-255,72-7,50-293,50-458,72-49, 50-271,72-59,50-382, and 72-75
Enclosures:
- 1. Corrected page 2 of transmittal letter dated December 28, 2012
- 2. New Enclosure 12 dated December 28, 2012, for Amendment No. 128 to DPR-06
- 3. Corrected SE pages 1 and 15-25 dated December 28,2012 cc w/encls: Distribution via Listserv
ENCLOSURE Corrected page 2 of the December 28, 2012, transmittal letter and the concurrence page (to include the Big Rock Point amendment as the last bulleted item and revise the list of enclosures);
New Enclosure 12 with Attachment - Amendment No. 128 to Facility Operating license No. DPR-6 for Big Rock; page 3 of Facility Operating license DPR-6; and page 6-2 of the Big Rock Point Defueled Technical Specifications; and Revised safety evaluation (SE) page 1 (to renumber as Enclosure 13) and pages 15-25 (to add new SE Section 3.1.12 for Big Rock Plant and subsequent renumbered SE pages).
J. McCann
- 2 Amendment No. 178 to Facility Operating License No, NPF-47 for River Bend Station, Unit 1; Amendment No. 253 to Renewed Facility Operating License DPR-28 for Vermont Yankee Nuclear Power Station; Amendment No. 240 to Facility Operating License No. NPF-38 for Waterford Steam Electric Station, Unit 3; and Amendment No. 128 to Facility Operating License No. DPR-06 for Big Rock Point.
The amendment changes the Entergy Quality Assurance Program Manual and Associated Plant TSs regarding staff qualifications. The changes standardize unit staff qualification requirements for the Entergy fleet.
A copy of our related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.
Sincerely,
~~p~
N. Kalyanam,~(~ect Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-313, 50-368, 72-13 50-155,72-43,50-333,72-12,50-416, 72-50,50-003, 50-247, 50-286, 72-51, 50-255,72-7,50-293,50-458,72-49, 50-271, 72-59, 50-382, and 72-75
Enclosures:
1, Amendment No. 248 to DPR-51
- 2. Amendment No. 296 to NPF-6
- 3. Amendment No. 304 to NPF-59
- 4. Amendment No. 193 to NPF-29
- 5. Amendment No. 271 to NPF-26
- 6. Amendment No. 248 to NPF-64
- 7. Amendment No. 249 to DPR-20
- 8. Amendment No. 239 to DPR-35
- 9. Amendment No. 178 to NPF-47
- 10. Amendment No. 253 to DPR-28
- 11. Amendment No. 240 to NPF-38
- 12. Amendment No. 128 to DPR-06
- 13. Safety Evaluation cc w/encls: Distribution via Listserv
J. McCann
- 2 Amendment No. 178 to Facility Operating License No. NPF-47 for River Bend Station, Unit 1; Amendment No. 253 to Renewed Facility Operating License DPR-28 for Vermont Yankee Nuclear Power Station; Amendment No. 240 to Facility Operating License No. NPF-38 for Waterford Steam Electric Station, Unit 3; and Amendment No. 128 to Facility Operating License No. DPR-06 for Big Rock Point.
The amendment changes the Entergy Quality Assurance Program Manual and Associated Plant TSs regarding staff qualifications. The changes standardize unit staff qualification requirements for the Entergy fleet.
A copy of our related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.
Sincerely, IRA!
N. Kalyanam, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-313, 50-368, 72-13 50-155,72-43,50-333,72-12,50-416, 72-50,50-003, 50-247, 50-286, 72-51, 50-255,72-7, 50-293,50-458,72-49, 50-271,72-59,50-382, and 72-75
Enclosures:
- 1. Amendment No. 248 to DPR-51
- 2. Amendment No. 296 to NPF-6
- 3. Amendment No. 304 to NPF-59
- 4. Amendment No. 193 to NPF-29
- 5. Amendment No. 271 to NPF-26
- 6. Amendment No. 248 to NPF-64
- 7. Amendment No. 249 to DPR-20
- 8. Amendment No. 239 to DPR-35
- 9. Amendment No. 178 to NPF-47
- 10. Amendment No. 253 to DPR-28
- 11. Amendment No. 240 to NPF-38
- 12. Amendment No. 128 to DPR-06
- 13. Safety Evaluation cc w/encls: Distribution via Listserv DISTRIBUTION:
PUBLIC RidsNrrDssStsb Resource RidsNrrPMlndianPoint Resource RidsRgn4MailCenter Resource LPLIV r/f RidsNrrLAJBurkhardt Resource RidsNrrPMPalisades Resource SGiebel. FSME/DWMEPIDURLD RidsAcrsAcnw MailCTR Resource RidsNrrLAKGoldstein Resource RidsNrrPMPilgrim Resource SAnderson, NRR/DSS/STSB RidsNrrDorlDpr Resource RidsNrrLASRohrer Resource RidsNrrPMRiverBend Resource PLongmire, NMSS/DSFSTILB RidsNrrDorlLpl1-1 Resource RidsNrrPMANO Resource RidsNrrPMVermontYankee Resource AArmstrong, NROIDCIP/CMVB RidsNrrDorlLpl3-1 Resource RidsNrrPMFitzPatrick Resource RidsNrrPMWaterford Resource GLapinsky. NRRIDRAlAHPB RidsNrrDorlLpl4 Resource RidsNrrPMGrandGulf Resource RidsOgcRp Resource ADAMS Accession No ML12347A140
'SE dated OFFICE NRR/DORUILPl4/PM NRR/DORl1LPL41LA NRO/DCIP/COABIBC NRR/DRAlAHPBIBC NRRIDSSISTSB/BC NAME NKalyanam JBurkhardt KKavanagh*
UShoop' RElliott DATE 12119112 12/14/12 1217112 12117/12 12118112 OFFICE OGC-NlO NRRlDORULPl3-1/BC NRRIDORULPL1-11BC NRRIDORULPL41BC NRRlDORULPL41PM NAME RWeisman TBeitz for RCarlson RGuzman for GWilson FLyon for MMarkley NKalyanam DATE 12/26112 12127/12 12/27/12 12/28112 12/28112 OFFICIAL RECORD COpy
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 ENTERGY OPERATIONS INC.
DOCKET NO. 50-155 BIG ROCK POINT FACILITY AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 128 License No. DPR-06
- 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Entergy Operations, Inc. (the licensee), dated December 13, 2011, as supplemented by letters dated May 21 and November 20,2012, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.
The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.
There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.
The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; or the environment; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied. 2
-2
- 2.
Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment.
- 3.
The license amendment is effective as of its date of issuance and shall be implemented within 120 days from the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION
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Mark D. Lombard, Director Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards
Attachment:
Changes to Facility Operating License No. DPR-06 Date of Issuance: December 28, 2012
-3 B.(5)
Pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility C.
This license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:
C.(1) Reactor Operation The reactor is not licensed for power operation. Fuel shall not be placed in the reactor vessel.
C.(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 128, are hereby incorporated in the license. ENO shall maintain the facility in accordance with the Technical Specifications.
C.(3) Physical Protection The licensee shall fully implement and maintain in effect all provisions of the physical security, guard training and qualification, and safeguards contingency plans approved by the Commission and all amendments and revisions to such plans made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p}, as modified by NRC-approved exemptions. The plan, which contains safeguards information protected under 10 CFR 73.21, is entitled: "Big Rock Point ISFSI Security Plan," as submitted on July 31, 2001, and modified by letter dated March 6, 2002. Changes made in accordance with 10 CFR 73.55 shalf be implemented in accordance with the schedule set forth therein.
C.(4)
License Termination Plan The license Termination Plan (LTP) dated April 1, 2003, as supplemented by L TP, Rev. 1, dated July 1, 2004, is approved by NRC License Amendment No. 126.
In addition to those criteria specified in 10 CFR 50.59, 10 CFR 50.82(a)(6},
and 10 CFR 50.82(a)(7), changes to the approved LTP shall require NRC approval prior to being implemented if the change:
(a) Increases in radionuclide-specific derived concentration guideline levels of area factors (discussed in Chapter 6 of the L TP);
Amendment No. 120, 127, 128 December 28,2012
BIG ROCK POINT DEFUELED TECHNICAL SPECIFICATIONS 6.0 ADMINISTRATIVE CONTROLS 6.3 STAFF QUALIFICATIONS Each member of the unit staff shall meet or exceed the minimum qualifications of ANSIIANS 3.1-1978 for comparable positions with exceptions specified in the Entergy Quality Assurance Program Manual (QAPM).
6.4 REVIEW AND AUDIT Requirements for onsite and offsite reviews and audits are described in the Quality Program Description for Big Rock Point.
6-2 Amendment 125, 127, 128 December 28,2012
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 248 AND 296 TO RENEWED FACILITY OPERATING LICENSE NOS. DPR-51 AND NPF-6 FOR ARKANSAS NUCLEAR ONE, UNIT NOS. 1 AND 2; AMENDMENT NO. 304 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-59 FOR JAMES A. FITZPATRICK NUCLEAR POWER PLANT; AMENDMENT NO. 193 TO FACILITY OPERATING LICENSE NO. NPF-29 FOR GRAND GULF NUCLEAR STATION, UNIT 1; AMENDMENT NOS. 271 AND 248 TO FACILITY OPERATING LICENSE NOS. DPR-26 AND DPR-64 FOR INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3; AMENDMENT NO. 249 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-20 FOR PALISADES NUCLEAR PLANT; AMENDMENT NO. 239 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-35 FOR PILGRIM NUCLEAR POWER STATION; AMENDMENT NO. 178 TO FACILITY OPERATING LICENSE NO. NPF-47 FOR RIVER BEND STATION, UNIT 1; AMENDMENT NO. 253 TO RENEWED FACILITY OPERATING LICENSE DPR-28 FOR VERMONT YANKEE NUCLEAR POWER STATION; AND AMENDMENT NO. 240 TO FACILITY OPERATING LICENSE NO. NPF-38 FOR WATERFORD STEAM ELECTRIC STATION, UNIT 3 AMENDMENT NO. 128 TO FACILITY OPERATING LICENSE NO. DPR-06 FOR BIG ROCK POINT INDIAN POINT NUCLEAR GENERATING UNIT NO.1 DOCKET NOS. 50-313,72-13,50-368,50-155.72-43,50-333,72-12,50-416, 72-50,50-003,50-247,72-51,50-286,50-255,72-7, 50-293, 50-458,72-49, 50-271,72-59,50-382 AND 72-75
1.0 INTRODUCTION
By application dated December 13, 2011 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML11356A278), as supplemented by letters dated May 21 and November 20,2012 (ADAMS Accession Nos. ML12145A195 and ML12328A039, respectively),
Entergy Operations, Inc. (Entergy, the licensee), submitted a fleet license amendment request.
The request consisted of changes to the Technical Specifications (TSs) for Arkansas Nuclear 3
- 15 Current TS 6.4 states:
6.4 TRAINING 6.4.1 A retraining and replacement training program for the unit staff shall be maintained under the direction of the Training Manager-Nuclear and shall meet or exceed the requirements and recommendations of Section 5.2 of ANSI 3.1-1978 and 10 CFR Part 55.
Revised TS 6.4 would state:
6.4 Not Used 3.1.12 Big Rock Point Current TS 6.3 states:
6.3 STAFF QUALIFICATIONS Each member of the facility management and supervisory staff shall meet the minimum requirements of ANSI N18.1 1971 for comparable positions. The individual responsible for radiation protection functions shall meet the minimum requirements of Regulatory Guide 1.6, September 1975. 1 Revised TS 6.3 would state:
6.3 STAFF QUALIFICATIONS Each member of the unit staff shall meet or exceed the minimum qualifications of ANSIIANS 3.1-1978 for comparable positions with exceptions specified in the Entergy Quality Assurance Program Manual (QAPM).
Current footnote for TS 6.3 states:
As applied to this specification, "equivalent," as used in Regulatory Guide 1.8 for the bachelor's degree requirement, may be met with four years of anyone or combination of the following: (a) formal training in science engineering or (b) operational or technical experience and training in nuclear power.
Revised footnote for TS 6.3 would be blank (there is no footnote).
- 16 3.2
NRC Staff Evaluation
3.2.1
Background
The Entergy OAPM provides an overview of the quality program controls which govern the operation and maintenance of Entergy's quality-related items and activities. The OAPM ensures conformance to Appendix B to 10 CFR Part 50, and applies to all of the units in Entergy's nuclear fleet. In accordance with 10 CFR 50.54(a)(4), Entergy requested NRC approval of proposed changes to unit staff qualification requirements contained in the OAPM.
Some changes to the qualification requirements for the RPM and OA Manager are considered a reduction in commitments. Therefore, NRC approval is required prior to implementation. Other individual changes are clarifications or administrative changes that do not reduce commitments, but are included in the evaluation for completeness.
The Entergy OAPM and plant TSs specify requirements for unit staff qualifications. Exceptions to the requirements are also included in both the OAPM and the TS. Currently, Entergy's OAPM references ANSIIANS 3.1-1978 as the overall standard for unit staff qualifications.
ANSJlANS 3.1-1978 was not officially endorsed by a regulatory guide; however, this standard was found acceptable as referenced in Entergy's OAPM and TSs for Entergy plants in accordance with an NRC staff safety evaluation dated November 6, 1998 (ADAMS Legacy Accession Nos. 9811170123 and 9811170129).
Entergy's use of exceptions in both the OAPM and the TSs has resulted in confusion over the applicability and extent to which requirements apply. Entergy proposed to revise the OAPM and each plant's TSs for consistency, and to allow the use of the OAPM as the single document to control exceptions or clarifications to a standard.
Entergy's OAPM is organized in a format that is consistent with NUREG-0800, Section 17.3, which lists RG 1.8, Revision 1, "Personnel Selection, and Training" as one of the regulatory guides to which applicants should comply or provide acceptable alternatives.
3.2.2 Personnel Training and Qualification 3.2.2.1 Training Requirements The licensee has taken an exception to the training standards in Section 5 of ANSIIANS 3.1-1978 in favor of the training requirements of 10 CFR Part 55 and 10 CFR 50.120.
The regulations in 10 CFR Part 55 address licensed operator training. The regulations in 10 CFR 50.120 require licensees to provide training for specific categories of non-licensed plant personnel that is derived from a systems approach to training (SAT). However, the current OAPM does not commit to ANSIIANS 3.1-1978, Section 5, and its omission does not represent a reduction in commitment, and is acceptable.
Entergy commits to ANSIIANS 3.1-1978 Sections 1-4. Section 5 contains standards for a training program that was developed prior to the issuance of 10 CFR 50.120, "Training and
- 17 qualification of nuclear power plant personnel," that established training requirements for all licensees. The regulations in 10 CFR 50.120 require licensees to establish, implement, and maintain a training program that meets specified requirements. The nuclear industry has developed training guidance through the Institute of Nuclear Power Operations (lNPO), which Entergy is implementing to meet the requirements of 10 CFR 50.120. The training program must be developed to be in compliance with the facility license, including all TS and applicable regulations. These training programs are periodically evaluated and revised as appropriate to reflect industry experience as well as changes to the facility, procedures, regulations, and QA requirements.
Criterion II, "Quality Assurance Program," of Appendix B to 10 CFR Part 50 states, in part, that "The program shall provide for indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained."
In its submittal, Entergy stated that the QAPM sentence is an administrative change that clarifies which sections of ANSIIANS 3.1-1978 apply to the Entergy fleet and does not reduce any commitments in the QAPM or affect compliance with Appendix B, Criterion II.
3.2.2.2 Evaluation of Standardization Regarding Use of ANSIIANS 3.1-1978 Entergy's QAPM qualification requirements for personnel, other than licensed operators covered under 10 CFR Part 55, currently meet ANSIIANS 3.1-1978, except for positions where an exception to either ANSIIANS 3.1-1978 or N18.1-1971, is stated in the applicable unit's TS. If an exception exists for a given position, the applicable unit's TS qualification requirements apply. The intent of the QAPM is to apply the qualification requirements of ANSIIANS 3.1-1978 to all Entergy units except to the extent that exceptions are specifically stated in the QAPM or the TSs. The current wording of the QAPM is intended to ensure that each unit complies with both the QAPM and TSs regarding staff qualifications. In its submittal, Entergy proposed to clarify the scope of the 1978 standard to be applied to its units, clarify the exceptions, and eliminate TS disparities by revising both the QAPM and the TSs. Entergy proposed committing to Sections 1-4 of ANSIIANS 3.1-1978 with the following clarifications and exceptions:
The radiation protection manager shall meet or exceed the qualifications of Regulatory Guide 1.8, Revision 2, 1987.
Entergy managers required to hold a Senior Reactor Operator (SRO) license are specified in the applicable unit's Technical Specifications.
Entergy's QAPM will state that licensed operators shall be qualified in accordance with the requirements of 10 CFR Part 55.
The following new sentence is proposed for clarification:
Entergy is committed to Sections 1 - 4 of ANSIIANS 3.1-1978 with the following clarifications and exceptions.
Currently, all of Entergy's units are committed to ANSIIANS 3.1-1978, so the use of ANSIIANS 3.1-1978 for qualification of the general personnel is not a change. However, the
~ 18 -
Entergy fleet is also committed to ANSI N18.1-1971. Entergy stated that this dual commitment has caused confusion in the past and requested to delete any commitment to and any exceptions from ANSI N18.1~1971 from the TSs and the QAPM. The ANSI/ANS 3.1-1978 standard was not officially endorsed by a regulatory guide, but this standard has been found acceptable by the NRC staff as discussed in Section 3.2.1 of this safety evaluation. In its submittal, Entergy proposed adoption of the ANSI/ANS 3.1-1978 standard, which is currently contained in the QAPM and plant TSs.
Since there are several precedents within the Entergy fleet in which the NRC approved replacing N18.1-1971 with ANSIIANS 3.1-1978 (ANO~1 (ADAMS Accession No. ML013050554), ANO-2 (ADAMS Accession No. ML042720521), GGNS (ADAMS Accession No. ML031130220), IP2, and IP3 (ADAMS Accession No. ML071990307>>, the NRC staff concludes that the replacing references to ANSI N18.1-1971 with ANSIIANS 3.1-1978 in the Entergy QAPM and the fleet's administrative TSs is acceptable.
Based on the above, the NRC staff concludes that the proposed changes describe controls that, when properly implemented, will meet the guidance provided in NUREG~0800, Section 17.3, and the requirements of Appendix B to 10 CFR Part 50. Therefore, the NRC staff concludes that the proposed changes to standardize the Entergy commitments to the ANSIIANS 3.1-1978 standard are acceptable.
3.2.2.2 Evaluation of RPM Qualifications Entergy's QAPM changes propose that the RPM qualification requirements be relocated from the TS to the QAPM and revised to be consistent across the fleet. Currently, the individual plant TSs specify the qualification requirements for the RPM. The latest standard to which any plant is committed is RG 1.8, Revision 2,1987. All other units are committed to RG 1.8, Revision 1, 1975. In its submittal, Entergy proposed to apply RG 1.8, Revision 2, 1987, to all Entergy plants. The relocated exception in the QAPM would state, The radiation protection manager shall meet or exceed the qualifications of Regulatory Guide 1.8, Revision 2, 1987.
The educational requirements for RG 1.8, Revision 1, 1975 states that the RPM should have a bachelor's degree or the equivalent in a science or engineering subject, including some formal training in radiation protection. The educational requirements from RG 1.8, Revision 2,1987, state that the RPM should have a bachelor's degree in a science or engineering subject, including formal training in radiation protection.
Although Revision 2 of RG 1.8 does not use the term "or equivalent" when referring to a bachelor's degree, section 4,1 of ANSIIANS 3.1-1981 as endorsed by RG 1.8 provides an allowance for the RPM to be qualified without a bachelor's degree. The standard states, in part that Individuals who do not possess the formal educational requirements specified in this section shalf not be automatically eliminated where other factors provide sufficient demonstration of their abilities. These other factors shall be evaluated
- 19 on a case by-case basis and approved and documented by the plant management.
The current revision of Entergy's QAPM contains an allowance to preclude disqualifying individuals who met previous commitments but do not meet the more restrictive new commitments. The QAPM currently states, in part, that 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.
This allowance is retained in the QAPM and would apply to any individual currently serving in the RPM position that does not fully meet the updated guidance.
The guidance of RG 1.8, Revision 1, states that the RPM should have at least 5 years of professional experience in applied radiation protection, and at least 3 years of this professional experience should be in applied radiation protection work in a nuclear facility dealing with radiological problems similar to those encountered, preferably, in an actual nuclear power station. In comparison, RG 1.8, Revision 2,1987, indicates that the RPM should have 4 years of experience in applied radiation protection, and 3 years of this experience should be in applied radiation protection work in a nuclear facility dealing with radiological problems similar to those encountered preferably in a nuclear power plant. The change is a reduction in commitment of total professional experience for the RPM from 5 years to 4 years.
The guidance of RG 1.8, Revision 1, 1975, states a master's degree is to be considered equivalent to 1 year of professional experience, and a doctors degree may be considered equivalent to 2 years of professional experience where course work related to radiation protection is involved. This allowance is not contained in RG 1.8, Revisions 2, 1987, or the endorsed ANSI standard. ANSIIANS 3.1-1981 includes additional standards for the 3 years experience at a nuclear facility. The ANSI standard indicates that during the 3 years, the individual should participate in the radiation protection section of an operating nuclear power plant during the following periods: routine refueling outage for up to 2 months, and 2 months operation above 20 percent power. Six months experience should be onsite. In addition to this guidance, ANSI/ANS 3.1-1981 includes new standards for the individual who temporarily replaces the radiation protection group leader. The ANSI standard indicates that the replacement should have a bachelor's degree in a science or engineering subject and 2 years experience, one of which should be nuclear power plant experience. As noted in regards to education above, alternatives to the bachelor's degree may also be applied to a temporary replacement.
There is a reduction in the total minimum years of experience (from 5 years to 4 years); but the reduction is offset by more specific commitments on the type of experience. The 4 years experience should include 3 years of radiation protection professional-level experience. The individual should also have participated in the radiation protection section of an operating nuclear power plant during a routine refueling outage (1 to 2 months) and 2 months above 20 percent power. The individual should also have 6 months of on-site experience. Accordingly,
- 20 the proposed change to standardize and/or upgrade in experience level in a specific area, outweighs the small reductions for years of experience in Entergy plants.
Based on the above, the NRC staff concludes that the proposed QAPM change, when properly implemented, will meet the guidance in SRP 17.3, and therefore, will meet the requirements of Appendix B to 10 CFR Part 50.
Therefore, the NRC staff concludes that the proposed change to the RPM qualifications is acceptable.
3.2.2.3 Evaluation of Managers Required to Hold an SRO License Section 4.2.2 of ANSIIANS 3.1-1978, which was accepted by the NRC in its safety evaluation dated November 6, 1998, indicates that at the time of initial core loading or appointment to the position, whichever is later, the operations manager should hold an SRO's license. The Entergy plant TSs take exception to this provision, specifying that either the operations manager or an operations middle manager (or assistant operations manager) shall hold an SRO license. The current QAPM proposed revision plans to delete the general reference to exceptions specified in the TS to avoid confusion. Therefore, the exception for this provision is specifically stated in the QAPM as, "Qualification requirements for personnel shall meet ANSIIANS 3.1-1978 except the following," and, "Managers required to hold an SRO license are specified in the applicable unit's Technical Specifications."
The NRC staff concludes that the change is administrative in nature and has no impact on current commitments, but is included here for completeness of the overall requested change, and, therefore, finds it acceptable.
3.2.2.4 Evaluation of Licensed Operators Entergy's QAPM currently states, "Qualification requirements for personnel, other than Licensed Operators covered under 10CFR55, shall meet ANSI/ANS 3.1-1978." Entergy's exception for licensed operators is reworded and relocated to the list of exceptions as follows, "Qualification requirements for personnel shall meet ANSI/ANS 3.1-1978 except the following...
- c.
Licensed Operators shall be qualified in accordance with the requirements of 10 CFR 55.
This change is administrative and does not alter existing commitments. Licensed operators will continue to be qualified in accordance with 10 CFR Part 55. This exception remains consistent with the NRC staffs safety evaluation dated November 6, 1998, that consolidated Entergy's QAPM, which states, "In addition, more restrictive requirements are still in place in Technical Specifications, and other regulations where appropriate (e.g., licensed operator qualifications)."
The NRC staff concludes that the change is administrative in nature and has no impact on current commitments, but is included here for completeness of the overall requested change, and, therefore, finds it acceptable.
- 21 3.2.2.5 Evaluation of Functional Titles In its submittal, Entergy proposed to add Insert 2, below, to clarify the different functional titles and the titles reference in ANSI/ANS 3.1-1978, Section 4.4. Entergy's proposed clarification, regardless of the title, ensures the position has the authority and specified qualifications to accomplish the functional responsibilities.
Individuals assigned to professional-technical comparable positions shall have the authority and specified qualifications to accomplish the functional responsibilities of the position.
ANSIIANS 3.1-1978 provides qualification standards for specified functional areas of responsibility for nuclear organizations. For differences between functional level titles used in the ANSI standard and those used by Entergy organizations, Entergy proposed the above clarification to ensure that the comparable position has the authority, and specified qualifications to accomplish the functional responsibilities.
The NRC staff concludes that the change is administrative in nature and has no impact on current commitments, but is included here for completeness of the overall requested change, and, therefore, finds it acceptable.
3.2.2.6 Shift Technical Advisor (STA)
For STA qualification, Entergy proposed to commit all plants in its fleet to the latest standard, ANSI/ANS 3.1-1993 as endorsed by RG 1.8, Revision 3, 2000, including a clarification as to which plant MODES the STA must be on-shift serving in the STA role.
NUREG-0737, "Clarification of TMI Action Plan Requirements," November 1980 (ADAMS Accession No. ML051400209), states, in part, that "... an STA (shall) be available for duty on each operating shift when a plant is being operated in Modes 1-4 for a PWR and Modes 1-3 for a BWR. At other times, an STA is not required to be on duty." The TS wording proposed by the licensee includes plant-specific terminology that differs slightly from the NUREG-0737 wording, but accomplishes the same purpose. Accordingly, the NRC staff concludes that the licensee's commitment to RG 1.8, Revision 3, is acceptable.
3.2.2.7 Evaluation of Quality Assurance Manager Qualifications Section 4.4.5 of ANSI/ANS 3.1-1978 prescribes the following qualifications for the person responsible for Quality Assurance:
At the time of initial core loading or assignment to the active position, the responsible person shall have six years experience in the field of quality assurance, preferably at an operating nuclear plant, or operations supervisory experience. At least one year of this six years experience shall be nuclear power plant experience in the overall implementation of the quality assurance program.
(This experience shall be obtained within the quality assurance organization). A minimum of one year of this six years experience shall be related technical or
- 22 academic training. A maximum of four years of this six years experience may be fulfilled by related technical or academic training Neither the current QAPM nor ANSI/ANS 3.1-1978, approved by the NRC staff's safety evaluation dated November 6, 1998, provides consideration for candidates for the position that do not fully meet all of the above criteria, but; based upon other factors, may be an appropriate choice for the position. However, the NRC staff guidance in NUREG-0800, Section 17.5, includes this allowance. Entergy's revision to the QAPM would include this allowance as Insert 3 below:
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, approved, and documented by senior management.
As a minimum, the Special Requirements of ANSIIANS 3.1-1993 Section 4.3.7 should be met if the manager responsible for QA does not meet the standards of Section 4.4.5 of ANSIIANS 3.1-1978.
In its submittal, Entergy proposed the following new exception to ANSI/ANS 3.1-1978 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 Entergy requested to apply the NUREG-0800, Section 17.5 allowance by adding it to the QAPM as an exception to Section 4.4.5 of ANSIIANS 3.1-1978. This change is a reduction in commitment. Nonetheless, an individual being considered for the position will be evaluated on a case-by-case basis as to their capabilities to perform the duties and responsibilities of the position. Use of the exception would be approved by senior management and documented.
Without the exception, some candidates that are fully capable of fulfilling the duties and responsibilities would be automatically excluded from consideration. Appendix B to 10 CFR Part 50 does not specify particular qualification requirements, but requires that an organization be capable of fulfilling the duties and responsibilities specified in the QA Program. The proposed change continues to ensure that the QA manager is sufficiently qualified to fulfill the duties and responsibilities of the position.
In view of the above, the proposed change describes controls that, when properly implemented, will meet the guidance or SRP, and, therefore, meet the requirements of 10 CFR Part 50, Appendix B. The QAPM does not leave the qualifications open, but preserves minimum qualification standards by specifying, "Special Requirements of ANSI/ANS 3.1-1993 Section 4.3.7 must be met if the manager responsible for Quality Assurance does not meet the requirements of section 4.4.5 of ANSIIANS 3.1-1978."
- 23 3.2.2.7 Evaluation of Training for Managers, Supervisors, and General Personnel The current OAPM addresses qualification commitments; it does not clearly specify training program commitments. Entergy has proposed a change to provide a single point of reference for a Training Program commitment in the OAPM to train applicable licensee staff identified in the ANSI standard that are not covered by 10 CFR 50.120 or 10 CFR Part 55.
In its submittal, Entergy proposed to modify the proposed OAPM exception to Section 5 of ANSI/ANS 3.1-1978 to specifically address training commitments with the proposed OAPM Insert 4 as follows:
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.
Proposed OAPM Insert 4 allows certain training programs to be accredited by the National Nuclear Accrediting Board (NNAB) as part of the training accreditation program developed by the INPO in lieu of meeting Section 5 of ANSIIANS 3.1-1978. Typical accredited training programs include training for licensed and non-licensed operators (initial and requalification programs), professional technical personnel (engineering support personnel), technicians, and maintenance personnel. Entergy states that programs which are not accredited by the NNAB, such as general employee training and supervisor training, will continue to meet the standards of Section 5 of ANSI/ANS 3.1-1978.
The above change describes controls that, when properly implemented, will meet the guidance in NUREG-0800, Section 17.3 and, therefore, will meet the requirements of 10 CFR Part 50, Appendix B. The proposed upgrade from the current standard of ANSIIANS 3.1-1978 to the more rigorous NNAB accreditation is an enhancement and an upgrade in commitment.
Therefore, the NRC staff concludes that the above change to training for managers, supervisors, and general personnel is acceptable.
3.2.2.8 "Grandfathering" without Justification and Documentation Because the only personnel who will be affected by this exception are already qualified incumbents who are performing their jobs on a daily basis, confirming and documenting that they satisfy the education and/or experience requirements for their positions would serve no purpose, and could represent a significant administrative burden for the licensee. When the incumbents leave their positions, new candidates will be judged in accordance with the proposed qualification standards. According to the licensee, implementation of this "Grandfather" clause will necessitate changes to fleet procedure EN-HR-137, "Complying with the Standards for Selecting Nuclear Power Plant Personnel," to ensure that replacements of incumbents meet the new requirements prior to employment in the position. Based on the lack of value added, the staff finds that re-documenting the qualifications of qualified incumbents is not necessary. Therefore, the NRC staff concludes that the "grandfathering" clause proposed by Entergy is acceptable.
- 24 3.2.2.9 Relocation of Qualification Requirements and Exceptions from TSs to the QAPM Allowing exceptions to qualification requirements to be documented in the QAPM instead of TSs is less restrictive, but justifiable in terms of workload efficiency for both the licensee and the NRC staff. The relocation of the exceptions from TSs to the QAPM is acceptable because 10 CFR 50.54(a)(4) provides adequate control over changes to the exceptions in the QAPM.
Specifically, § 50,54(a)(4) requires prior NRC approval of (1) a change to all or any portion of an exception if the change would delete or otherwise reduce one or more of the qualifications called for by the exception, and (2) addition or modification of any exception that would allow for fewer qualifications than those called for by ANSlfANS 3.1-1978. Further, a change to the QAPM that adds qualifications, whether in an existing exception in the QAPM or a new one, will not impair the existing provisions regarding qualification, and the NRC need not approve such changes through the license amendment process, Accordingly, the NRC staff concludes that this change is acceptable.
3.2.3 Summary Based on the above evaluation, the NRC staff concludes that the Entergy QA program described in the revised QAPM satisfies the Commission's requirements for QA programs as established by Appendix B to 10 CFR Part 50. The program description adequately describes how the requirements of Appendix B will be implemented, Therefore, the staff concludes that the proposed Entergy QAPM changes continue to meet the 10 CFR Part 50 requirements for the QA program.
4.0 STATE CONSULTATION
S In accordance with the Commission's regulations, the State officials for Arkansas, Mississippi, Louisiana, New York, Massachusetts, Vermont, and Michigan were notified of the proposed issuance of the amendments. The State officials had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendments change recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
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6.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors: G. Lapinsky, A. Armstrong Date: December 28,2012
J. McCann
- 2 If you have any questions, please contact me at (301) 415-1480 or by-mail at kaly.kalyanam@nrc.gov.
Docket Nos. 50-313, 50-368,72-13, 50-155, 72-43, 50-333, 72-12, 50-416, 72-50,50-003,50-247,50-286,72-51, 50-255,72-7, 50-293,50-458,72-49, 50-271, 72-59, 50-382, and 72-75
Enclosures:
- 1. Corrected page 2 of transmittal letter dated December 28, 2012 Sincerely, IRAJ N. Kalyanam, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
- 2. New Enclosure 12 dated December 28,2012, for Amendment No. 128 to DPR-06
- 3. Corrected SE pages 1 and 15-25 dated December 28,2012 cc w/encls: Distribution via Listserv DISTRIBUTION:
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