ML14210A266
| ML14210A266 | |
| Person / Time | |
|---|---|
| Site: | Palisades, Indian Point, Grand Gulf, Pilgrim, Arkansas Nuclear, River Bend, Vermont Yankee, Waterford, Big Rock Point, FitzPatrick  |
| Issue date: | 08/08/2014 |
| From: | Pickett D Plant Licensing Branch 1 |
| To: | Mccann J Entergy Nuclear Operations |
| Pickett D | |
| References | |
| TAC MF4071, TAC MF4072, TAC MF4073, TAC MF4074, TAC MF4075, TAC MF4076, TAC MF4077, TAC MF4078, TAC MF4079, TAC MF4080, TAC MF4081 | |
| Download: ML14210A266 (8) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 8, 2014 Mr. John F. McCann Director, Nuclear Safety and Licensing Entergy Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601
SUBJECT:
ARKANSAS NUCLEAR ONE, UNIT NOS. 1 AND 2; BIG ROCK POINT PLANT; JAMES A. FITZPATRICK NUCLEAR POWER PLANT; GRAND GULF NUCLEAR STATION, UNIT 1; INDIAN POINT NUCLEAR GENERATING UNIT NOS. 1, 2, AND 3; PALISADES NUCLEAR PLANT; PILGRIM NUCLEAR POWER STATION; RIVER BEND STATION, UNIT 1; VERMONT YANKEE NUCLEAR POWER STATION; AND WATERFORD STEAM ELECTRIC STATION, UNIT 3- SAFETY EVALUATION FOR THE ENTERGY QUALITY ASSURANCE PROGRAM MANUAL, REVISIONS 24 AND 25 (TAG NOS. MF4071 THROUGH AND INCLUDING MF4081)
Dear Mr. McCann:
By letter dated April 25, 2014, Entergy Operations, Inc. and Entergy Nuclear Operations, Inc.
(collectively referred to as "Entergy") submitted the annual report for the Quality Assurance Program Manual (QAPM), including Revisions 24 and 25 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14120A021 ), in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Section 50.54(a)(3).
The changes contained in Entergy QAPM Revision 24 include exceptions to selected sections of American National Standards Institute/American Nuclear Society (ANSI/ANS) 3.1-1978 for qualifications of personnel, which had been previously documented in a safety evaluation transmitted by the Nuclear Regulatory Commission (NRC) by letter dated December 28, 2012 (ADAMS Accession No. ML12347A140). Other minor changes were not considered to be reductions in commitment, in accordance with 10 CFR 50.54(a), and did not require prior NRC approval.
The changes in Entergy QAPM Revision 25 include changes made in response to NRC Confirmatory Order EA-11-096 (ADAMS Accession No. ML11224A255), to require that individuals performing quality control inspections functionally report to the associated manager responsible for quality assurance. Other changes were not considered to be reductions in commitment, in accordance with 10 CFR 50.54(a), and did not require prior NRC approval.
J. McCann The NRC Office of New Reactor's Quality Assurance Vendor Inspection Branch staff has reviewed Entergy's submittal and finds that the quality assurance program described in the Entergy QAPM Revisions 24 and 25 meets the criteria of Appendix B to 10 CFR Part 50, and is, therefore, acceptable.
Sincerely, Douglas V. Pickett, Senior Project Manager Plant Licensing Branch 1-1 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, 72-07, 50-293,72-1044, 50-458, 72-49, 50-271, 72-59, 50-382, and 72-75
Enclosure:
Safety Evaluation cc w/encl: Distribution via Listserv
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION FOR THE ENTERGY QUALITY ASSURANCE PROGRAM MANUAL. REVISIONS 24 AND 25 FOR ARKANSAS NUCLEAR ONE, UNIT NOS. 1 AND 2; BIG ROCK POINT NUCLEAR PLANT ISFSI; GRAND GULF NUCLEAR STATION; INDIAN POINT NUCLEAR POWER PLANT, UNIT NOS. 1, 2, AND 3; JAMES A. FITZPATRICK NUCLEAR POWER PLANT; PALISADES NUCLEAR POWER PLANT; PILGRIM NUCLEAR POWER STATION; RIVER BEND STATION, UNIT 1; VERMONT YANKEE NUCLEAR POWER STATION; AND WATERFORD STEAM ELECTRIC STATION, UNIT NO.3; DOCKET NOS. 50-313, 72-13, 50-368, 50-155, 72-43, 50-416, 72-50,50-003,50-247,72-51,50-286,50-333,72-12,50-255,72-07, 50-293, 72-1044, 50-458, 72-49, 50-271, 72-59, 50-382, and 72-75
1.0 INTRODUCTION
By letter dated April 25, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14120A021 ), Entergy Operations, Inc. and Entergy Nuclear Operations, Inc. (collectively referred to as "Entergy") submitted the annual report for the Quality Assurance Program Manual (QAPM), including Revisions 24 and 25, in accordance with the guidance of NUREG-0800, "Standard Review Plan (SRP) for the Review of Safety Analysis Reports for Nuclear Power Plants," Section 17.3, "Quality Assurance Program Description,"
dated August 1990.
The Entergy QAPM provides an overview of the quality program controls which govern the operation and maintenance of Entergy's quality related items and activities. The QAPM is based on the applicable portions of Appendix B, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," to Title 10 of the Code of Federal Regulations (1 0 CFR)
Part 50, "Domestic Licensing of Production and Utilization Facilities."
The Nuclear Regulatory Commission (NRC or Commission) staff notes that the QAPM also implements Subpart H, "Quality Assurance", of 10 CFR Part 71, "Packaging and Transportation of Radioactive Material" and Subpart G, "Quality Assurance," of 10 CFR Part 72, "Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater than Class C Waste." Since there were no changes to the Enclosure
portions of the QAPM addressing the requirements of 10 CFR 71, Subpart H and 10 CFR 72, Subpart G, compliance with these requirements is not addressed in this Safety Evaluation.
2.0 REGULATORY EVALUATION
The Commission's regulatory requirements related to Quality Assurance (QA) programs are set forth in Appendix B, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," to 10 CFR Part 50 (Appendix B), 10 CFR 50.34(b)(6)(ii), and 10 CFR 50.54(a).
Appendix B establishes the requirements for the design, fabrication, construction, and testing of structures, systems, and components (SSCs) for the facility. The pertinent requirements of Appendix B apply to all activities affecting the safety-related functions of those SSCs and include designing, purchasing, fabricating, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, and modifying SSCs.
The regulations in 10 CFR 50.34, "Content of applications; technical information," require that every applicant for an operating license include information in its Final Safety Analysis Report (FSAR) on the managerial and administrative controls to be used to ensure safe operation.
The information on the controls shall also include a discussion on how the applicable requirements of Appendix B will be satisfied.
The regulations in 10 CFR 50.54 require each power plant subject to the requirements of Appendix B to implement a QA program and 10 CFR 50.54(a)(3) allows licensees to make changes to their QA Program, provided that those changes do not reduce commitments and the licensee submits a copy of the changes to the NRC.
3.0 TECHNICAL EVALUATION
The annual report for the Entergy QAPM changes was submitted by letter dated April 25, 2014, in accordance with the provisions of 10 CFR 50.71 (e). The letter included Revisions 24 and 25 to the QAPM (provided in Attachment C thereto).
In evaluating the adequacy of the Entergy QAPM, the NRC staff used the guidance contained in NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," Section 17.3, "Quality Assurance Program Description," dated August 1990 (ADAMS Accession No. ML052350376), hereafter referred to as Section 17.3, which provides acceptance criteria for quality assurance program descriptions. The staff noted that Entergy's QAPM is organized in a format that is consistent with NUREG-0800, Section 17.3.
3.1 QAPM Revision 24 The changes made in QAPM Revision 24 include the following:
- a. Changes involving administrative improvements, clarifications, and editorial items.
Such changes included updates to page numbering in the QAPM Table of Contents and editorial changes in Sections A.2.d.1 and A.2.f. The staff determined that these changes are not considered to be reductions in commitment in accordance with 10 CFR 50.54(a) and did not require prior NRC approval.
- b. Changes involving the use of generic organizational position titles that clearly denote the position function, supplemented as necessary by descriptive text, rather than specific titles. Such changes included the use of the generic title, "highest level nuclear executive officer," in Section A.2 of the document. The staff determined that these changes are not considered to be reductions in commitment in accordance with 10 CFR 50.54(a) and did not require prior NRC approval.
- c. Changes made to Table 1, Sections A.1, A.3, A.4, and A.5 that take exception to Sections 1 through 5 of ANSI/ANS 3.1-1978 for qualifications of personnel. These changes required prior NRC approval, which had been previously documented in a Safety Evaluation Report transmitted by the NRC by letter dated December 28, 2012 (ADAMS Accession Number ML12347A140).
The staff reviewed the QA measures to be implemented by the licensees and concluded that the Entergy QAPM, including the changes introduced in Revision 24 of the document, continues to meet the guidance of NUREG-0800, Section 17.3.
3.2 QAPM Revision 25 The changes made in QAPM Revision 25 include the following:
- a. Changes involving administrative improvements, clarifications, and editorial items.
Such changes included updates to page numbering in the QAPM Table of Contents, editorial changes to the QAPM cover page, and the addition of the Policy Statement.
The staff determined that these changes are not considered to be reductions in commitment in accordance with 10 CFR 50.54(a) and did not require prior NRC approval.
- b. Organizational revisions that ensure that persons and organizations performing quality assurance functions continue to have the requisite authority and organizational freedom, including sufficient independence from cost and schedule when opposed to safety considerations. Such changes are provided in Section A.2 of the document. The staff determined that these changes are not considered to be reductions in commitment in accordance with 10 CFR 50.54(a) and did not require prior NRC approval.
- c. Changes made in response to NRC Confirmatory Order EA-11-096 (ADAMS Accession No. ML11224A255), as described in Entergy's letter ENOC-11-00021 dated November 14, 2011 (ADAMS Accession No. ML11335A045) and supplemented by the description provided in Entergy's letter ENOC-13-00029 dated November 4, 2013 (ADAMS Accession No. ML14002A120). The changes made to the QAPM in response to NRC Confirmatory Order EA-11-096 are contained in Section B.12.f and Table 1, Section G.2.
NRC Confirmatory Order EA-11-096, Action 1 states, in part: "Entergy will reorganize the Quality Control (QC) reporting relationship so that those persons whose primary function is to assign or perform QC inspections will report directly to a manager in the Quality Assurance (QA) organization. The same persons may have a dotted line reporting relationship to the site Maintenance department and may be tasked to perform maintenance activities other than QC inspections." Entergy's letter ENOC-11-00021 describes the reorganization of the Quality Control reporting relationship required by
Action 1 of NRC Confirmatory Order EA-11-096 and states, in part: "The existing reporting relationship for those individuals whose primary function is site Quality Specialist (QC) in the maintenance organization will be changed to report to the new position described in item 2 (Supervisor, QA) in the oversight organization." Further, Entergy's letter ENOC-13-00029 supplemented the response provided in letter ENOC-11-00021, by providing the plan for a modification of the QAPM to require that individuals performing inspection in accordance with QAPM Section 8.12, Inspection, functionally report to the associated manager responsible for quality assurance.
Entergy QAPM, Section B.12.f, will be modified to read:
"f. Inspections are performed by qualified personnel other than those who performed or directly supervised the work being inspected. While performing the inspection activity the inspectors functionally report to the associated manager responsible for quality assurance."
Further, Entergy's QAPM, Table 1, Regulatory Commitments, Section G, Regulatory Guide 1.58 Revision 1, dated September 1980, Item 2, General, will be modified to read:
"General certification of inspectors in accordance with this guide is approved by a manager responsible for quality."
The proposed change provides for independence between persons and organizations executing performance activities and those executing verification and self-assessment activities. The proposed change, when properly implemented, will meet the guidance of NUREG-0800, Section 17.3, and, therefore, meet the requirements of Appendix B.
The NRC staff reviewed the QA measures to be implemented by the licensees and concluded that the Entergy QAPM, including the changes introduced in Revision 25 of the document, continues to meet the guidance of NUREG-0800, Section 17.3.
4.0 CONCLUSION
The NRC staff used the acceptance criteria of NUREG-0800, Section 17.3 as the basis for evaluating the acceptability of the Entergy's QA program in conformance with the applicable portions of Appendix B to 10 CFR Part 50. The program description adequately describes how the requirements of Appendix B will be implemented. The staff concludes that Entergy's QAPM Revision 24 and 25 follows the NRC guidance contained within, and conforms to the format of NUREG-0800, Section 17.3, complies with Appendix B to 10 CFR Part 50 requirements for the QA program and is, therefore, acceptable.
Principal Reviewer: Victoria Huckabay Date: August 8, 2014
5.0 REFERENCES
- 1. NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," Section 17.3, "Quality Assurance Program Description" dated August 1990 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML052350376).
- 2. Submittal of Annual Report for Quality Assurance Program Manual Changes under 10 CFR 50.54(a)(3) and 10 CFR 72.140(d), Notification of Application of Approved Appendix B to 10 CFR 72 Subpart G (ADAMS Accession No. ML14120A021), dated April25, 2014.
- 3. NRC letter to Entergy Operations, Inc., "Arkansas Nuclear One, Unit Nos. 1 and 2; Big Rock Point Plant; James A. Fitzpatrick Nuclear Power Plant; Grand Gulf Nuclear Station, Unit 1; Indian Point Nuclear Generating Unit Nos. 1, 2, and 3; Palisades Nuclear Plant; Pilgrim Nuclear Power Station; River Bend Station, Unit 1; Vermont Yankee Nuclear Power Station; and Waterford Steam Electric Station, Unit 3 -Issuance of Amendments Re: Request for Approval of Change to the Entergy Quality Assurance Program Manual and Associated Plant Technical Specifications Regarding Staff Qualifications (ADAMS Accession No. ML12347A140), dated December 28, 2012.
- 4. NRC Confirmatory Order EA-11-096 to Entergy Operations, Inc. and Entergy Nuclear Operations, Inc., Modifying Licenses Nos. DPR-51; NPF-6; DPR-59; NFP-29; DPR-26; DPR-64; DPR-20; DPR-35; NFP-47; DPR-28; and NFP-38 (ADAMS Accession No. ML11224A255), dated August 24, 2011.
- 5. Entergy Operations, Inc. and Entergy Nuclear Operations, Inc. Letter ENOC-11-00021 to NRC, subject "NRC Confirmatory Order EA-11-096; Planned Reorganization of Quality Control Reporting Relationship" (ADAMS Accession No. ML11335A045), dated November 14, 2011.
- 6. Entergy Operations, Inc. and Entergy Nuclear Operations, Inc. Letter ENOC-13-00029 to NRC, subject "Planned Modification of the Entergy Quality Assurance Program Manual (QAPM)" (ADAMS Accession No. ML14002A120),
dated November 4, 2013.
ML14210A266 *SEdated OFFICE LPL 1-1/PM LPL 1-1/LA NRO/DCIP/CQAB/BC LPL 1-1/BC NAME DPickett KGoldstein KKavanagh* BBeasley DATE 08/07/2014 08/07/2014 07/23/2014 08 /08/2014