ML25217A492

Quality Assurance Program Manual Reduction in Commitment

ML25217A492
Person / Time
Site:	Grand Gulf, Arkansas Nuclear, River Bend, Waterford, 07100341, 07100536, 07100566, 07100604
Issue date:	08/05/2025
From:	Couture P Entergy Operations
To:	Office of Nuclear Material Safety and Safeguards, Document Control Desk, Office of Nuclear Reactor Regulation
References
CNRO2025-00015
Download: ML25217A492 (1)

Text

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

Entergy Operations, Inc., 1340 Echelon Parkway, Jackson, MS 39213 CNRO2025-00015 10 CFR 50.54(a)(4)

August 5, 2025 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 to the QAPM applies to the above listed docket numbers. 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 Chemistry Technicians to be consistent with industry standards (References 1 and 2).

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).

CNRO2025-00015 Page 2 of 2 This letter contains no new regulatory commitments. Should you have any questions or require additional information, please contact me 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 Entergy Fleet Digitally signed by Philip Couture DN: cn=Philip Couture, o=Entergy, ou=Regulatory Assurance, email=pcoutur@entergy.com Date: 2025.08.05 11:33:17 -05'00' Philip Couture

Enclosure CNRO2025-00015 Description and Justification of Proposed QAPM Change

CNRO2025-00015 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

CNRO2025-00015 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 Chemistry 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 Chemistry 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 and chemistry 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.

CNRO2025-00015 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 Chemistry Technicians education and work experience requirements aligns the requirements with currently accepted industry standards. 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 (RG) 1.8, Revision 4 (Reference 2). The use of these criteria does not imply a commitment to ANSI/ANS 3.1-2014 or RG 1.8, Revision 4.

The current qualifications requirements from ANSI/ANS-3.1-1978 for Chemistry 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 Chemistry Technicians (section 4.5.3.1) 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 meet the requirements for Chemistry 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 Criteria of 10 CFR 50 Appendix B. Specifically:

The reduction in education and experience requirements for Chemistry Technicians is consistent with an accepted and endorsed industry standard (References 1 and 2).

Chemistry 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. Chemistry Technicians interpret and verify field data accumulated from tests such as instrumentation systems tests, and calibration of electronic circuits. Chemistry Technicians will continue to be qualified to perform these tasks.

CNRO2025-00015 Enclosure Page 4 of 4 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). Also, Entergy fleet change to revise the QAPM to reflect the education and work experience requirements for Radiation Protection Technicians to be consistent with the latest industry standards (References 4).

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

4.

NRC letter to Entergy, "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

- Safety Evaluation for Quality Assurance Program Manual Reduction in Commitment,"

(ML23117A217), dated May 1, 2023 8.0 ATTACHMENTS

1.

Entergy QAPM Markup Pages

2.

Entergy QAPM Clean Typed Page

Enclosure, Attachment 1 CNRO2025-00015 Entergy QAPM Markup Pages (1 QAPM Pages)

QUALITY ASSURANCE PROGRAM MANUAL 21 Revision 50 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 and chemistry 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 CNRO2025-00015 Entergy QAPM Clean Typed Page (1 QAPM Page)

QUALITY ASSURANCE PROGRAM MANUAL 21 Revision 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 and chemistry 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.