05000416/FIN-2012002-04
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Finding | |
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| Title | Modification of the Spent Fuel Pool without Prior NRC Approval |
| Description | The inspectors identified a Severity Level IV non-cited violation of 10 CFR 50.59, Changes, Tests and Experiments, when the licensee failed to obtain a license amendment prior to implementing a proposed change to the plant that required a change to Technical Specifications. The 10 CFR 50.59 evaluation performed by the licensee is dated January 24, 2001, thus it was performed under the requirements of the old rule based on the Entergy Operations letter dated March 5, 2001. In the 10 CFR 50.59 evaluation for the removal of Blackness Testing and the division of the spent fuel pool into two regions, the licensee determined that the modifications did not require a change to Technical Specifications. However, 10 CFR 50.36, Technical Specifications, Section 4, Design Features, requires that design features such as geometric arrangements, which, if altered or modified, would have a significant effect on safety, must be incorporated into Technical Specifications. The NRC considers that the establishment of two regional zones in the spent fuel pool, each having specific loading criteria to maintain keff less than 0.95, constitutes design features which, if altered or modified would have a significant effect on safety. Therefore, these design features should have been incorporated into the Technical Specifications. In a letter dated September 8, 2010, (ML102660403), the licensee submitted a power up-rate license amendment request. The NRC staff is currently reviewing the license request, which includes the licensees technical justification for the spent fuel pool changes described above. Based on preliminary review of the amendment request, the NRC staff has determined that an immediate safety concern does not exist. The licensee has entered this issue into their corrective action program as condition report CR-GGN-2012-01077. The finding is more than minor because it is associated with the design control attribute of the Barrier Integrity Cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers (fuel cladding, reactor coolant system, containment) protect the public from radionuclide releases caused by accidents or events. Inspectors performed a Phase 1 screening, in accordance with Inspection Manual Chapter 0609, Attachment 4, Phase 1 Initial Screening and Characteristics of Findings, and determined that the finding was of very low safety significance (Green) because it did not result in the loss of cooling to the spent fuel pool, did not result from fuel handling errors that caused damage to fuel clad integrity, and it did not result in a loss of spent fuel pool inventory. This finding is a latent issue and is not indicative of current performance; therefore, no cross-cutting aspect was identified |
| Site: | Grand Gulf  |
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| Report | IR 05000416/2012002 Section 1R15 |
| Date counted | Mar 31, 2012 (2012Q1) |
| Type: | TEV: Severity level IV |
| cornerstone | Barrier Integrity |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.15 |
| Inspectors (proximate) | L Ricketson R Smith V Gaddy B Rice D Reinert J Braisted N Greene |
| INPO aspect | |
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Finding - Grand Gulf - IR 05000416/2012002 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Grand Gulf) @ 2012Q1
Self-Identified List (Grand Gulf)
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