Text

Quality Assurance Program Manual Reduction in Commitment
	ML23018A220
Person / Time
Site:	Grand Gulf, Arkansas Nuclear, River Bend, Waterford, 07100341, 07100536, 07100566, 07100604
Issue date:	01/18/2023
From:	Couture P; Entergy Operations
To:	; Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk
References
	CNRO2023-00001
	Download: ML23018A220 (1)
	v • d • e

Phil Couture Senior Manager Fleet Regulatory Assurance - Licensing 601-368-5102

Entergy Operations, Inc., 1340 Echelon Parkway, Jackson, MS 39213 CNRO2023-00001 10 CFR 50.54(a)(4)

January 18, 2023 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Quality Assurance Program Manual Reduction in Commitment Arkansas Nuclear One, Units 1 and 2 NRC Docket Nos. 50-313 & 50-368 Renewed License Nos. DPR-51 & NPF-6 NRC Docket No. 72-13, 71-0341 Grand Gulf Nuclear Station, Unit 1 NRC Docket No. 50-416 Renewed License No. NPF-29 NRC Docket No. 72-50, 71-0536 Waterford Steam Electric Station, Unit 3 NRC Docket No. 50-382 Renewed License No. NPF-38 NRC Docket No. 72-75, 71-0604 River Bend Station, Unit 1 NRC Docket No. 50-458 Renewed License No. NPF-47 NRC Docket No. 72-49, 71-0566 In accordance with the requirements of Title 10, Code of Federal Regulations (10 CFR) 50.54(a)(4), Entergy Operations, Inc. (Entergy) hereby requests approval of a revision to the Entergy Quality Assurance Program Manual (QAPM) which is used by each of the referenced sites. The proposed change is considered to be a reduction in commitment, which requires approval by the Nuclear Regulatory Commission (NRC) prior to implementation.

Specifically, Entergy is proposing to revise the QAPM to reflect the education and work experience requirements for Radiation Protection Technicians to be consistent with industry standards (References 1 and 2).

The proposed change to the QAPM applies to the above listed docket numbers.

The enclosure is included pursuant to 10 CFR 50.54(a)(4) and includes a description of the change, justification for the proposed change, and provides a basis for concluding the revised QAPM will continue to satisfy the criteria of 10 CFR 50 Appendix B. Attachments 1 and 2, to the Enclosure, provide markup and retyped pages, respectively, of the Entergy QAPM.

Approval of the change is requested within the 60 days identified in 10 CFR 50.54(a)(4). The QAPM will be revised within 30 days of approval to support fleet activities.

CNRO2023-00001 Page 2 of 2 This letter contains no new regulatory commitments. Should you have any questions or require additional information, please contact Phil Couture, Senior Manager Fleet Regulatory Assurance - Licensing at 601-368-5102.

Respectfully, Phil Couture PC/chm

Enclosure:

Description and Justification of Proposed QAPM Change Attachments to

Enclosure:

1.

Entergy QAPM Markup Pages

2.

Entergy QAPM Clean Typed Page

References:

1) American National Standard, ANSI/ANS-3.1-2014, "Selection, Qualification, and Training of Personnel for Nuclear Power Plants,"

November 20, 2014

2) Regulatory Guide 1.8, "Qualification and Training of Personnel for Nuclear Power Plants," Revision 4, (ML19101A395), June 2019 cc:

NRC Region IV Regional Administrator NRC Senior Resident Inspector - ANO GGN RBS WF3 NRC Project Manager - ANO GGN RBS WF3

Enclosure CNRO2023-00001 Description and Justification of Proposed QAPM Change

CNRO2023-00001 Enclosure Page 1 of 4 TABLE OF CONTENTS 1.0

SUMMARY

DESCRIPTION................................................................................................ 2

2.0 DESCRIPTION

OF THE CHANGE..................................................................................... 2 3.0 JUSTIFICATION FOR THE PROPOSED CHANGE.......................................................... 3 4.0 BASIS FOR CONCLUDING THAT THE REVISED PROGRAM CONTINUES TO SATISFY THE CRITERIA OF 10 CFR 50 APPENDIX B AND THE PREVIOUSLY ACCEPTED QUALITY ASSURANCE PROGRAM COMMITMENTS................................. 3 5.0 PRECEDENT...................................................................................................................... 4

6.0 CONCLUSION

.................................................................................................................... 4

7.0 REFERENCES

................................................................................................................... 4 8.0 ATTACHMENTS................................................................................................................. 4

CNRO2023-00001 Enclosure Page 2 of 4 DESCRIPTION AND JUSTIFICATION OF PROPOSED QAPM CHANGE 1.0

SUMMARY

DESCRIPTION In accordance with the requirements of Title 10, Code of Federal Regulations (10 CFR) 50.54(a)(4), Entergy Operations, Inc. (Entergy) hereby requests approval of a revision to the Entergy Quality Assurance Program Manual (QAPM). The proposed change is considered to be a reduction in commitment, which requires approval by the Nuclear Regulatory Commission (NRC) prior to implementation. Specifically, Entergy is proposing to revise the QAPM to reflect the education and work experience requirements for Radiation Protection Technicians to be consistent with industry standards (Reference 1 and 2). The proposed change applies to the Arkansas Nuclear One, Units 1 and 2, Grand Gulf Nuclear Station, Unit 1, River Bend Station, Unit 1, and Waterford Steam Electric Station, Unit 3.

2.0 DESCRIPTION

OF THE CHANGE The proposed changes will revise the QAPM to reflect the education and work experience requirements for Radiation Protection Technicians to be consistent with the latest industry standards (References 1 and 2). The changes will be placed in QAPM Table 1, "Regulatory Commitments". Details below.

A. Regulatory Guide 1.8 Revision 1, dated September 1975 Clarification/Exception

1. General 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 units Technical Specifications.

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

d. Radiation protection technicians shall meet or exceed the qualifications of Regulatory Guide 1.8, Revision 4, 2019.

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.

CNRO2023-00001 Enclosure Page 3 of 4 provides the marked-up pages of Entergy QAPM showing the proposed changes, and Attachment 2 provides the retyped pages.

3.0 JUSTIFICATION FOR THE PROPOSED CHANGE The proposed change to the Radiation Protection Technicians education and work experience requirements aligns the requirements with currently accepted industry standards. The existing requirements were recognized as unnecessarily limiting Entergy outage management ability to fill Radiation Protection Technician positions. The criteria proposed were adopted from the latest revision of American National Standards Institute/American Nuclear Society (ANSI/ANS) 3.1 (Reference 1) and endorsed by the NRC in Regulatory Guide 1.8, Revision 4 (Reference 2).

The use of these criteria does not imply a commitment to ANSI/ANS 3.1-2014 or Regulatory Guide (RG) 1.8, Revision 4.

The current qualifications requirements from ANSI/ANS-3.1-1978 for Radiation Protection Technicians to which Entergy is committed, (section 4.5.2) are:

Technicians shall have 3 years of working experience in their specialty of which 1 year should be related technical training. They should possess a high degree of manual dexterity and ability and should be capable of learning and applying basic skills.

The proposed qualifications requirements from ANSI/ANS-3.1-2014 for Radiation Protection Technicians (section 4.5.3.2) are:

Education: High school diploma.

Minimum experience for the position:

Related experience which shall include:

2 yr.

Nuclear power plant experience:

1 yr.

Entergy will follow Regulatory Guide 1.8 Rev 4 Exception / Clarification 1.5:

In regard to "related experience" for radiation protection technicians, 2000 working hours is acceptable as representing one year of experience. There is no expectation of a minimum timeframe for accumulating these 2000 hours0.0231 days 0.556 hours 0.00331 weeks 7.61e-4 months (e.g., not less than 40 weeks),

nor is there is limit applied to the amount of hours that can be credited in a week.

However, no more than 2000 hours0.0231 days 0.556 hours 0.00331 weeks 7.61e-4 months can be credited toward related experience for radiation protection technicians in any one calendar year.

Entergy will meet the requirements for Radiation Protection Technicians in accordance with ANSI/ANS 3.1-2014 as endorsed by RG 1.8 Revision 4.

4.0 BASIS FOR CONCLUDING THAT THE REVISED PROGRAM CONTINUES TO SATISFY THE CRITERIA OF 10 CFR 50 APPENDIX B AND THE PREVIOUSLY ACCEPTED QUALITY ASSURANCE PROGRAM COMMITMENTS The proposed changes, though considered a reduction in commitment, continue to satisfy the

CNRO2023-00001 Enclosure Page 4 of 4 Criteria of 10 CFR 50 Appendix B. Specifically:

The reduction in education and experience requirements for Radiation Protection Technicians is consistent with an accepted and endorsed industry standard (References 1 and 2). Radiation Protection Technicians Technicians are responsible for specific maintenance activities or analytical laboratory work. They are responsible for troubleshooting, performance of tests, calibration, inspections, surveys, maintenance, and repair of equipment. Radiation Protection Technicians interpret and verify field data accumulated from tests such as radiation surveys, instrumentation systems tests, liquid and gaseous analysis, and calibration of electronic circuits. Radiation Protection Technicians will continue to be qualified to perform these tasks.

5.0 PRECEDENT This change is consistent with a recently approved change to the Tennessee Valley Authority (TVA) Nuclear Quality Assurance Plan which requested a revision to the education and work experience requirements for Quality Assurance management to be consistent with industry standards (Reference 3).

6.0 CONCLUSION

The proposed change is compliant with, and continues to satisfy, the criteria of 10 CFR 50 Appendix B, as incorporated in the Entergy QAPM.

7.0 REFERENCES

1.

American National Standard, ANSI/ANS-3.1-2014, "Selection, Qualification, and Training of Personnel for Nuclear Power Plants," November 20, 2014

2.

Regulatory Guide 1.8, "Qualification and Training of Personnel for Nuclear Power Plants," Revision 4, (ML19101A395), June 2019

3.

NRC Letter to Tennessee Valley Authority, "Browns Ferry Nuclear Plant, Units 1, 2, and 3; Clinch River Nuclear Site; Sequoyah Nuclear Plant, Units 1 and 2; Watts Bar Nuclear Plant, Units 1 and 2 - Review of Quality Assurance Plan Changes,"

(ML22084A001), dated April 5, 2022 8.0 ATTACHMENTS

1.

Entergy QAPM Markup Pages

2.

Entergy QAPM Clean Typed Page

Enclosure, Attachment 1 CNRO2023-00001 Entergy QAPM Markup Pages (2 QAPM Pages)

Effective: December 11, 2022 Revision 46 Quality Assurance Program Manual Arkansas Nuclear One (Units 1 & 2)

Docket Nos. 50-313 & 50-368 License Nos. DPR-51 & NPF-6 Docket No. 72-13 Docket No.: 71-0341 River Bend Station Docket No. 50-458 License No. NPF-47 Docket No. 72-49 Docket No.: 71-0566 Grand Gulf Nuclear Station Docket No. 50-416 License No. NPF-29 Docket No. 72-50 Docket No.: 71-0536 Waterford 3 Steam Electric Station Docket No. 50-382 License No. NPF-38 Docket No. 72-75 Docket No.: 71-0604 No Changes to this Page For Information Only

QUALITY ASSURANCE PROGRAM MANUAL Revision 46 21 Table 1 Regulatory Commitments A.

Regulatory Guide 1.8 Revision 1, dated September 1975 Clarification/Exception

1. General 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 units Technical Specifications.

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

d. Radiation protection technicians shall meet or exceed the qualifications of Regulatory Guide 1.8, Revision 4, 2019.

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.

2. General The following qualifications may be considered equivalent to a bachelors degree:

a. 4 years of post-secondary schooling in science or engineering,

b. 4 years of applied experience at a nuclear facility in the area for which qualification is sought,

c. 4 years of operational or technical experience/training in nuclear power, or

d. any combination of the above totaling 4 years.

Years of experience used to meet the education requirements as allowed by this exception shall not be used to also meet the experience requirements.

Enclosure, Attachment 2 CNRO2023-00001 Entergy QAPM Clean Typed Page (1 QAPM Page)

QUALITY ASSURANCE PROGRAM MANUAL Revision 21 Table 1 Regulatory Commitments A.