CNRO-2015-00023, Request for Approval of Change to the Entergy Quality Assurance Program Manual (QAPM)

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Request for Approval of Change to the Entergy Quality Assurance Program Manual (QAPM)
ML15310A388
Person / Time
Site: Palisades, Indian Point, Grand Gulf, Pilgrim, Arkansas Nuclear, River Bend, Waterford, Big Rock Point, FitzPatrick, 07201004  Entergy icon.png
Issue date: 11/06/2015
From: Mike Perito
Entergy Nuclear Operations, Entergy Operations
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
CNRO-2015-00023
Download: ML15310A388 (8)
v • d • e


Text

Entergy Nuclear Operations, Inc.

Entergy Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213 Tel: 601-368-5711 Mike Perito Vice President, Oversight CNRO-2015-00023 November 6, 2015 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Request for Approval of Change to the Entergy Quality Assurance Program Manual (QAPM).

Arkansas Nuclear One Indian Point Nuclear Power Plant Units 1 & 2 Units 1, 2, & 3 Docket Nos. 50-313 & 50-368 Docket Nos.50-003, 50-247, & 50-286 License Nos. DPR-51 & NPF-6 License Nos. DPR-05, DPR-26, & DPR-64 Docket No. 72-13 Docket No. 72-51 Grand Gulf Nuclear Station Big Rock Point Nuclear Plant-ISFSI Docket No. 50-416 Docket No. 50-155 License No. NPF-29 License No. DPR-6 Docket No. 72-50 Docket No. 72-43 River Bend Station James A. FitzPatrick Nuclear Power Plant Docket No. 50-458 Docket No. 50-333 License No. NPF-47 License No. DPR-59 Docket No. 72-49 Docket No. 72-12 Waterford 3 Steam Electric Station Palisades Nuclear Power Plant Docket No. 50-382 Docket No. 50-255 License No. NPF-38 License No. DPR- 20 Docket No. 72-75 Docket No. 72-07 Pilgrim Nuclear Power Station Docket No. 50-293 License No. DPR-35 Docket No. 72-1044

Dear Sir or Madam:

Entergy Operations, Inc. and Entergy Nuclear Operations, Inc. (collectively referred to as Entergy) are submitting for your approval a change to the Entergy Quality Assurance Program Manual (QAPM). The proposed change represents a reduction in commitment pursuant to 10 CFR 50.54(a)(4). The proposed change eliminates section K.3 from Table 1 of the QAPM (Rev.

29). This section currently reads as follows:

CNRO-2015-00023 Page 2 of 3 As an alternate to daily testing grout for compressive strength, for prepackaged shelf item, non-shrink grout, the grouts compressive strength tests may be performed once on each batch of non-shrink grout received, rather than each day grout is placed.

This deletion reduces the commitment established in the consolidated QAPM as approved by the NRC via Safety Evaluation Report dated November 6, 1998, which included section K.3 in Table 1.

Elimination of the requirement to perform compressive strength testing for prepackaged non-shrink grout is based on an ASME inquiry for testing requirements of prepackaged non-shrink grout. The ASME responded via QA92-003, as provided in Attachment 1, that testing of prepackage non-shrink grout did not fall under the jurisdiction of Table B of ANSI N45.2.5, Supplementary Quality Assurance requirements for Installation, Inspection and Testing of Structural Concrete and Structural Steel during the Construction Phase of Nuclear Power Plants, dated 1974. Therefore, the Entergy QAPM continues to meet the requirements of ANSI N45.2.5. Additionally, quality related grout is procured from a qualified (audited) supplier and tested by the manufacturer with certified results provided to the licensee. A mark-up of the proposed change to the QAPM is provided in Attachment 2.

The QAPM, as revised and noted, continues to satisfy the requirements of 10 CFR 50 Appendix B and the Regulatory Guides and ANSI Standards referenced in the QAPM Table of Contents and QAPM Attachment, Table 1.

Entergy will implement the change 60 days after submittal as allowed by 10 CFR 50.54 unless directed otherwise by the Commission prior to the 60 days.

Should you have any questions, please contact Mr. Edward D. Harris, Manager - QA at (601) 368-5649.

I declare under penalty of perjury that the foregoing is true and correct. Executed on November 6, 2015 Yours truly, MP/EDH/NWE Attachments: 1. ASME QA92-003

2. QAPM Affected Pages

CNRO-2015-00023 Page 3 of 3 cc: T. G. Mitchell (ECH)

J. A. Ventosa (IPEC)

D. Jacobs (ECH)

M. Perito (ECH)

M. W. Woodby (ECH)

J. G. Browning (ANO)

K. J. Mulligan (GGNS)

E. W. Olson (RBS)

M. R. Chisum (WF3)

L. M. Coyle (IPEC)

B. R. Sullivan (JAF)

J. A. Dent (Pilgrim)

A. J. Vitale (PAL)

D. J. Mannai (WPO)

B. S. Ford (ECH)

All above w/o attachments NRC Region I Administrator NRC Region III Administrator NRC Region IV Administrator NRC PM (ANO)

NRC PM (GGNS)

NRC PM (RBS)

NRC PM (WF3)

NRC PM (IPEC)

NRC PM (JAF)

NRC PM (Pilgrim)

NRC PM (PAL)

NRC PM (BRP)

NRC Senior Resident Inspector (ANO)

NRC Senior Resident Inspector (GGNS)

NRC Senior Resident Inspector (RBS)

NRC Senior Resident Inspector (WF3)

NRC Senior Resident Inspector (IPEC)

NRC Senior Resident Inspector (JAF)

NRC Senior Resident Inspector (PILGRIM)

NRC Senior Resident Inspector (PAL)

CNRO-2015-00023 ATTACHMENT 1 ASME QA92-003 to CNRO-2015-00023 Page 1 of 2 ASME NQA-1 Interpretations Replies to Technical Inquiries Foreword General Information This publication includes all of the written replies issued between the indicated dates by the Secretarial Staff, speaking for the ASME Committee on Nuclear Quality Assurance, to inquiries concerning interpretations of technical aspects of ASME NQA-1 , Quality Assurance Requirements for Nuclear Facility Applications.

These replies are taken verbatim from the original letters except for a few typographical corrections and some minor editorial corrections made for the purpose of improved clarity. In some instances, a review of the interpretation revealed a need for corrections of a technical nature; in these cases a corrected interpretation follows immediately after the original reply.

These interpretations were prepared in accordance with the accredited ASME procedures. ASME procedures provide for reconsideration of these interpretations when or if additional information is available which the inquirer believes might affect the interpretation. Further, persons aggrieved by this interpretation may appeal to the cognizant ASME committee or subcommittee. ASME does not approve, certify, rate, or endorse any item, construction, proprietary device, or activity.

An interpretation applies to the Edition and Addenda stated in the interpretation itself or, if none is stated, to the latest published Edition and Addenda at the time it is issued. Subsequent revisions to the rules may have superseded the reply.

For detailed instructions on the preparation of technical inquiries, refer to the Preparation of Technical Inquiries to the Nuclear Quality Assurance Committee (p. vi of ASME NQA-1).

Subject and Numerical Indexes Subject and numerical indexes have been prepared to assist the user in locating interpretations by subject matter or location in this Standard. These indexes, which are the compilation of former NQA-I and NQA-2 interpretations indexes, will be updated with each Edition and Addenda.

to CNRO-2015-00023 Page 2 of 2 File: QA92-003

Subject:

ASME NQA-2-I 989, Part 2.5; Table 5.6, Required In-process Tests ANSI/ASME N45.2.5-1974; Table B, Required In-Process Tests, Nonshrink Grout Date Issued: April 1 0, 1992 Question (1): Do prepackaged shelf item nonshrink grout products fall under the jurisdiction of Table B of N45.2.5?

Reply (1): No. Testing of nonshrink grout does not fall under the jurisdiction of Table B of N45.2.5.

Question (2): If a prepackaged nonshrink grout does not fall under the jurisdiction of Table B of N45.2.5, what testing procedures and frequency is recommended for testing?

Reply (2): The designer is responsible for identifying necessary testing and frequency requirements.

File: QA93-003

Subject:

ASME NQA-2a-1990, Part 2.7 Date Issued: August 13, 1993 Question (1): In regard to NQA-2, Part 2.7, is the verification review of Section 7 intended to be a design review beyond that required under Section 4?

Reply (1): No, provided the design verification requirements of NQA-1, Supplement 35-1 are met.

Question (2): Is the term ensure as used in NQA-2, Part 2.7, Section 4, intended to be interpreted as provided adequate confidence, provided reasonable assurance, or guarantee software performance?

Reply: The key term ensure, as it appears in para. 4.2 of NQA-2, Part 2.7, is intended to be interpreted as provide adequate confidence.

File: QA85-008

Subject:

ANSI N45.2.8-1975, Para. 1.1; ANSI/ASME NQA-2-1983, Part 2.8: Scope Date Issued: October 16, 1985 Question: Does ANSI N45.2.8 and ANSI/ASME NQA-2 apply to modifications performed after initial construction and cold functional testing are completed?

Reply: The intent of both Standards is that they apply to modifications. In each use the application will depend on the organizations commitments. In ANSI/ASME NQA-2, the applicability section states, The requirements of this Standard apply to fabrication, construction, modifications, and testing activities that affect the quality of structures, systems, and components of nuclear power plants.

File: QA99-03

Subject:

ASME NQA-1-I997, Subpart2.15, Para. 403.1

CNRO-2015-00023 ATTACHMENT 2 QAPM AFFECTED PAGES to CNRO-2015-00023 Page 1 of 1

Entergy Nuclear Operations, Inc.

Entergy Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213 Tel: 601-368-5711 Mike Perito Vice President, Oversight CNRO-2015-00023 November 6, 2015 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Request for Approval of Change to the Entergy Quality Assurance Program Manual (QAPM).

Arkansas Nuclear One Indian Point Nuclear Power Plant Units 1 & 2 Units 1, 2, & 3 Docket Nos. 50-313 & 50-368 Docket Nos.50-003, 50-247, & 50-286 License Nos. DPR-51 & NPF-6 License Nos. DPR-05, DPR-26, & DPR-64 Docket No. 72-13 Docket No. 72-51 Grand Gulf Nuclear Station Big Rock Point Nuclear Plant-ISFSI Docket No. 50-416 Docket No. 50-155 License No. NPF-29 License No. DPR-6 Docket No. 72-50 Docket No. 72-43 River Bend Station James A. FitzPatrick Nuclear Power Plant Docket No. 50-458 Docket No. 50-333 License No. NPF-47 License No. DPR-59 Docket No. 72-49 Docket No. 72-12 Waterford 3 Steam Electric Station Palisades Nuclear Power Plant Docket No. 50-382 Docket No. 50-255 License No. NPF-38 License No. DPR- 20 Docket No. 72-75 Docket No. 72-07 Pilgrim Nuclear Power Station Docket No. 50-293 License No. DPR-35 Docket No. 72-1044

Dear Sir or Madam:

Entergy Operations, Inc. and Entergy Nuclear Operations, Inc. (collectively referred to as Entergy) are submitting for your approval a change to the Entergy Quality Assurance Program Manual (QAPM). The proposed change represents a reduction in commitment pursuant to 10 CFR 50.54(a)(4). The proposed change eliminates section K.3 from Table 1 of the QAPM (Rev.

29). This section currently reads as follows:

CNRO-2015-00023 Page 2 of 3 As an alternate to daily testing grout for compressive strength, for prepackaged shelf item, non-shrink grout, the grouts compressive strength tests may be performed once on each batch of non-shrink grout received, rather than each day grout is placed.

This deletion reduces the commitment established in the consolidated QAPM as approved by the NRC via Safety Evaluation Report dated November 6, 1998, which included section K.3 in Table 1.

Elimination of the requirement to perform compressive strength testing for prepackaged non-shrink grout is based on an ASME inquiry for testing requirements of prepackaged non-shrink grout. The ASME responded via QA92-003, as provided in Attachment 1, that testing of prepackage non-shrink grout did not fall under the jurisdiction of Table B of ANSI N45.2.5, Supplementary Quality Assurance requirements for Installation, Inspection and Testing of Structural Concrete and Structural Steel during the Construction Phase of Nuclear Power Plants, dated 1974. Therefore, the Entergy QAPM continues to meet the requirements of ANSI N45.2.5. Additionally, quality related grout is procured from a qualified (audited) supplier and tested by the manufacturer with certified results provided to the licensee. A mark-up of the proposed change to the QAPM is provided in Attachment 2.

The QAPM, as revised and noted, continues to satisfy the requirements of 10 CFR 50 Appendix B and the Regulatory Guides and ANSI Standards referenced in the QAPM Table of Contents and QAPM Attachment, Table 1.

Entergy will implement the change 60 days after submittal as allowed by 10 CFR 50.54 unless directed otherwise by the Commission prior to the 60 days.

Should you have any questions, please contact Mr. Edward D. Harris, Manager - QA at (601) 368-5649.

I declare under penalty of perjury that the foregoing is true and correct. Executed on November 6, 2015 Yours truly, MP/EDH/NWE Attachments: 1. ASME QA92-003

2. QAPM Affected Pages

CNRO-2015-00023 Page 3 of 3 cc: T. G. Mitchell (ECH)

J. A. Ventosa (IPEC)

D. Jacobs (ECH)

M. Perito (ECH)

M. W. Woodby (ECH)

J. G. Browning (ANO)

K. J. Mulligan (GGNS)

E. W. Olson (RBS)

M. R. Chisum (WF3)

L. M. Coyle (IPEC)

B. R. Sullivan (JAF)

J. A. Dent (Pilgrim)

A. J. Vitale (PAL)

D. J. Mannai (WPO)

B. S. Ford (ECH)

All above w/o attachments NRC Region I Administrator NRC Region III Administrator NRC Region IV Administrator NRC PM (ANO)

NRC PM (GGNS)

NRC PM (RBS)

NRC PM (WF3)

NRC PM (IPEC)

NRC PM (JAF)

NRC PM (Pilgrim)

NRC PM (PAL)

NRC PM (BRP)

NRC Senior Resident Inspector (ANO)

NRC Senior Resident Inspector (GGNS)

NRC Senior Resident Inspector (RBS)

NRC Senior Resident Inspector (WF3)

NRC Senior Resident Inspector (IPEC)

NRC Senior Resident Inspector (JAF)

NRC Senior Resident Inspector (PILGRIM)

NRC Senior Resident Inspector (PAL)

CNRO-2015-00023 ATTACHMENT 1 ASME QA92-003 to CNRO-2015-00023 Page 1 of 2 ASME NQA-1 Interpretations Replies to Technical Inquiries Foreword General Information This publication includes all of the written replies issued between the indicated dates by the Secretarial Staff, speaking for the ASME Committee on Nuclear Quality Assurance, to inquiries concerning interpretations of technical aspects of ASME NQA-1 , Quality Assurance Requirements for Nuclear Facility Applications.

These replies are taken verbatim from the original letters except for a few typographical corrections and some minor editorial corrections made for the purpose of improved clarity. In some instances, a review of the interpretation revealed a need for corrections of a technical nature; in these cases a corrected interpretation follows immediately after the original reply.

These interpretations were prepared in accordance with the accredited ASME procedures. ASME procedures provide for reconsideration of these interpretations when or if additional information is available which the inquirer believes might affect the interpretation. Further, persons aggrieved by this interpretation may appeal to the cognizant ASME committee or subcommittee. ASME does not approve, certify, rate, or endorse any item, construction, proprietary device, or activity.

An interpretation applies to the Edition and Addenda stated in the interpretation itself or, if none is stated, to the latest published Edition and Addenda at the time it is issued. Subsequent revisions to the rules may have superseded the reply.

For detailed instructions on the preparation of technical inquiries, refer to the Preparation of Technical Inquiries to the Nuclear Quality Assurance Committee (p. vi of ASME NQA-1).

Subject and Numerical Indexes Subject and numerical indexes have been prepared to assist the user in locating interpretations by subject matter or location in this Standard. These indexes, which are the compilation of former NQA-I and NQA-2 interpretations indexes, will be updated with each Edition and Addenda.

to CNRO-2015-00023 Page 2 of 2 File: QA92-003

Subject:

ASME NQA-2-I 989, Part 2.5; Table 5.6, Required In-process Tests ANSI/ASME N45.2.5-1974; Table B, Required In-Process Tests, Nonshrink Grout Date Issued: April 1 0, 1992 Question (1): Do prepackaged shelf item nonshrink grout products fall under the jurisdiction of Table B of N45.2.5?

Reply (1): No. Testing of nonshrink grout does not fall under the jurisdiction of Table B of N45.2.5.

Question (2): If a prepackaged nonshrink grout does not fall under the jurisdiction of Table B of N45.2.5, what testing procedures and frequency is recommended for testing?

Reply (2): The designer is responsible for identifying necessary testing and frequency requirements.

File: QA93-003

Subject:

ASME NQA-2a-1990, Part 2.7 Date Issued: August 13, 1993 Question (1): In regard to NQA-2, Part 2.7, is the verification review of Section 7 intended to be a design review beyond that required under Section 4?

Reply (1): No, provided the design verification requirements of NQA-1, Supplement 35-1 are met.

Question (2): Is the term ensure as used in NQA-2, Part 2.7, Section 4, intended to be interpreted as provided adequate confidence, provided reasonable assurance, or guarantee software performance?

Reply: The key term ensure, as it appears in para. 4.2 of NQA-2, Part 2.7, is intended to be interpreted as provide adequate confidence.

File: QA85-008

Subject:

ANSI N45.2.8-1975, Para. 1.1; ANSI/ASME NQA-2-1983, Part 2.8: Scope Date Issued: October 16, 1985 Question: Does ANSI N45.2.8 and ANSI/ASME NQA-2 apply to modifications performed after initial construction and cold functional testing are completed?

Reply: The intent of both Standards is that they apply to modifications. In each use the application will depend on the organizations commitments. In ANSI/ASME NQA-2, the applicability section states, The requirements of this Standard apply to fabrication, construction, modifications, and testing activities that affect the quality of structures, systems, and components of nuclear power plants.

File: QA99-03

Subject:

ASME NQA-1-I997, Subpart2.15, Para. 403.1

CNRO-2015-00023 ATTACHMENT 2 QAPM AFFECTED PAGES to CNRO-2015-00023 Page 1 of 1

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