ML23117A217

Safety Evaluation for Quality Assurance Program Manual Reduction in Commitment

ML23117A217
Person / Time
Site:	Palisades, Indian Point, Grand Gulf, Arkansas Nuclear, River Bend, Vermont Yankee, Waterford, Big Rock Point, FitzPatrick
Issue date:	05/01/2023
From:	James Drake Plant Licensing Branch IV
To:	Gaston R Entergy Services
Drake, J
References
EPID L-2023-LLL-0004
Download: ML23117A217 (1)

Text

May 1, 2023 Mr. Ron Gaston Vice President, Regulatory Assurance Entergy Services, LLC M-ECH-29 1340 Echelon Parkway Jackson, MS 39213

SUBJECT:

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 (EPID L-2023-LLL-0004)

Dear Mr. Gaston:

By letter dated January 18, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23018A220), Entergy Operations, Inc. (Entergy, the licensee) submitted to the U.S. Nuclear Regulatory Commission (NRC), for review and approval, a revision to the Entergy Quality Assurance Program Manual (QAPM) for 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. The proposed change is a reduction in commitment in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.54(a)(4).

Specifically, Entergy requested NRC approval to revise the education and work experience requirements for Radiation Protection Technicians to be consistent with industry standards.

The NRC staff reviewed Entergys proposed change to its QAPM, as documented in the enclosed safety evaluation, and finds that Entergy will continue to comply with the criteria of Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Processing Plants, to 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, and is therefore, acceptable.

If you have any questions, please contact me at (301) 415-1564 or via e-mail to Siva.Lingam@nrc.gov.

Sincerely,

/RA/

Siva P. Lingam, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-313, 50-368, 50-416, 50-458, and 50-382

Enclosure:

Safety Evaluation cc: Listserv

Enclosure SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO QUALITY ASSURANCE PROGRAM MANUAL REDUCTION IN COMMITMENT ENTERGY OPERATIONS, INC.

ARKANSAS NUCLEAR ONE, UNITS 1 AND 2 GRAND GULF NUCLEAR STATION, UNIT 1 RIVER BEND STATION, UNIT 1 WATERFORD STEAM ELECTRIC STATION, UNIT 3 DOCKET NOS. 50-313, 50-368, 50-416, 50-458, AND 50-382

1.0 INTRODUCTION

By letter dated January 18, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23018A220), Entergy Operations, Inc. (Entergy, the licensee),

submitted to the U.S. Nuclear Regulatory Commission (NRC), for review and approval, a revision to the Entergy Quality Assurance Program Manual (QAPM) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.54(a)(4).

Specifically, Entergy requested NRC approval to revise the education and work experience requirements for Radiation Protection Technicians to be consistent with industry standards. The proposed change is a reduction in commitment in accordance with the provisions in 10 CFR 50.54(a)(4).

The Entergy QAPM describes the quality assurance (QA) program for the following plants:

Arkansas Nuclear One, Units 1 and 2; Grand Gulf Nuclear Station, Unit 1; Waterford Steam Electric Station, Unit 3; and River Bend Station, Unit 1.

2.0 REGULATORY EVALUATION

The regulatory requirements for nuclear power plant QA programs are set forth in Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, 10 CFR 50.34(b)(6)(ii), and 10 CFR 50.54(a). In addition, the regulations under 10 CFR 50.120 provides regulatory requirements for training and qualification of nuclear power plant personnel.

Appendix B to 10 CFR Part 50 establishes the requirements for the design, fabrication, construction, and testing of structures, systems and components. Criterion II, Quality Assurance Program, of Appendix B to 10 CFR Part 50, establishes requirements for indoctrination and training of personnel. Criterion II 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.

The regulation, 10 CFR 50.34(b)(6)(ii), requires the final safety analysis report for a nuclear power plant to include information on the managerial and administrative controls that would ensure safe operation. The information on the controls shall also include a discussion on how the applicable requirements of Appendix B to 10 CFR Part 50 will be satisfied.

The regulation, 10 CFR 50.54(a), requires each nuclear power plant licensee subject to the requirements of Appendix B to implement a QA program. The regulation, 10 CFR 50.54(a)(4),

sets forth the NRCs regulatory requirements regarding changes to a QA program description that are considered a reduction in commitment. Changes to a QA program description that reduce the licensees commitments must be submitted to the NRC and receive approval prior to implementation. This includes changes made to the QA program description as presented in the safety analysis report or in a topical report that must be submitted as specified in 10 CFR 50.4, Written communications.

The regulation, 10 CFR 50.120, requires each nuclear power plant licensee to establish, implement, and maintain a training and qualification program that is derived from a systems approach to training as defined in 10 CFR 55.4, and must provide for the training and qualification of various categories of nuclear power plant personnel.

3.0 TECHNICAL EVALUATION

In its letter dated January 18, 2023, Entergy requested approval of a proposed change to its QAPM that is a reduction in commitment. Entergy proposed to change the education and work experience requirements for Radiation Protection Technicians to be consistent with industry standards. Entergy included the justification for the proposed change as well as markups of the affected pages in the QAPM.

The current qualification requirements for Radiation Protection Technicians are from the American National Standards Institute/American Nuclear Society (ANSI/ANS)-3.1-1978, Selection and Training of Nuclear Power Plant Personnel, standard, which require 3 years of working experience in their specialty, of which 1 year should be related technical training.

The proposed qualification requirements are from the ANSI/ANS-3.1-2014, Selection, Qualification, and Training of Personnel for Nuclear Power Plants, standard, which requires the Radiation Protection Technicians to possess a high school diploma, 2 years of related experience, and 1 year of nuclear power plant experience. Section 4.1 of ANSI/ANS-3.1-2014 clarifies that the nuclear power plant experience may be earned concurrently with other experience. Entergy further clarified that related experience (i.e., 2000 working hours), is acceptable as representing 1 year of experience. There is no expectation of a minimum timeframe for accumulating these 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br />, nor is there a limit applied to the number of hours that can be credited in a week. However, no more than 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> can be credited toward related experience in any one calendar year. This is consistent with Regulatory Guide (RG) 1.8, Qualification and Training of Personnel for Nuclear Power Plants, Revision 4 (ML19101A395).

The NRC staff reviewed Entergys request for the proposed change to its QAPM. The NRC staff determined that the proposed change to the education and work experience requirements for Radiation Protection Technicians is consistent with the requirements of ANSI/ANS 3.1-2014, which has been endorsed by the NRC in RG 1.8, Revision 4. This change will continue to provide the minimum experiential, professional, and educational requirements necessary to ensure that assigned personnel can independently evaluate risks and safely execute the responsibilities associated with the position of Radiation Protection Technician.

4.0 CONCLUSION

The NRC staff reviewed Entergys proposed change to its QAPM. The NRC staff found that the proposed change to revise the education and work experience requirements for the position of Radiation Protection Technician is consistent with RG 1.8, Revision 4, and will continue to comply with Criterion II of Appendix B to 10 CFR Part 50, 10 CFR 50.34(b)(6)(ii),

10 CFR 50.54(a), and 10 CFR 50.120, and is therefore, acceptable.

Principal Contributor: Y. Law Date: May 1, 2023

ML23117A217

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