ML20216C719
| ML20216C719 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 09/05/1997 |
| From: | Dyer J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Hagan J ENTERGY OPERATIONS, INC. |
| References | |
| 50-416-97-05, 50-416-97-5, NUDOCS 9709090127 | |
| Download: ML20216C719 (6) | |
See also: IR 05000416/1997005
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NUCLEAR REGULATORY COMMISSION
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611 RYAN PLAZA drive, SulTE 400
AR LINoToN. T E XAS 760118064
September 5, 1997
Joseph J. Hagan, Vice President
Operations Grand Gulf Nuclear Station
Entergy Operations, Inc.
P.O. Box 756
Port Gibson, Mississippi 39150
SUBJECT:
NRC INSPECTION REPORT 50-416/97-05 AND REPLY TO A NOTICE OF
VIOLATION
Dear Mr. Hagan:
Thank you for your letter (GNRO 97/00059) of June 30,1997, in response to our letter
and Notice of Violation dated May 29,1997. We have reviewed your reply and, with the
exceptions noted below, find it responsive to the concerns raised in our Notice of Violation.
In addition to discussing your specific violation responses, we are responding to the two
concerns you raised in your cover letter.
With respect to Example 3 of Violation 50-416/9705-01, we note that you were concerned
that our assertion regarding a new worst-case single failure condition bordered on
establishing a new regulatory position. It is not NRC's policy that the inspection process
be used to change facility license requirements without review through the appropriate
agency back fit process. However,'we expect that the worst case single failure be
evaluated for the design basis events in your accident analysis, considering the design and
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- regulatory criteria which are part of your license basis. At the time of the inspection, it
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appeared that the worst-case single failure had not been evaluated to ensure conformance Y
with your commitment to General Design Criteria 44, " Cooling Water," for a design basis
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event which was part of your safety analysis, i.e., loss-of-coolant accident coincident with
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loss-of-offsite power. However, we note that you provided new information related to this
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example. The NRC has considered the results of your revised analysis. Since you
concluded that the loss of an emergency diesel generator is the bounding failure with
respect to usable Hventory at the end of 30 days, we will withdraw Example 3 of design
control Violation W-416/9705-01.
We understand that you were concerned with the NRC view that credit could not be given
for your Updated Final Safety Analysis Report review program. However, as you
recognized in your letter, our policy is not to normally apply enforcement discretion for
violations identified by the NRC. In order to apply discretion, the NRC must conclude that
your staff would have identified the violation considering the scope, thoroughness, and
schedule of your initiative. Since your description was general in nature, and neither
specified which portions of the Updated Final Safety Analysis Report you planned to
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sample nor describi d the depth of the initiative, the inspectors concluded that your staff
would not necessaiily have found the specific examples cited in NRC Inspection
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Report 50-416/97C 5 03.
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We note thet you provided new information related to Example 1 of
Violat!on 50 416/9705 03 in the violation response. Considering the additional license
basir information you have provided in your response, we agree that this example should
be withdrawn. However, we also note that your subsequent license basis research has
determined that it was a requirement to maintain the service water pump bases sealed to
prevent water from backing up into the room during flooding. This appears to be a
long term failure to meet License Condition 2.c(5), Since further NRC review of the license
basis and your current flood calculations is required to determine the acceptability of this
issue, we will consider this issue to be unresolved (Unresolved item 50 416/9705 07).
With respect to Example 2 of Violation 50-416/9705-03, we considered your view that
single failure analysis is not required for long term heat removal and determined that it is
incorrect. We based our determination on the following:
1)
A primary safety function of the ultimate heat sink is to remove heat for
30 days following a design basis accident.
2)
Your view is not consistent with other information in the same Updated Final
Safety Analysis Report section. For example, Table 9.21 is defined similarly
in the Updated Final Safety Analysis Report and this table clearly includes
30 day (long term) attributes for the ultimate heat sink.
3)
We believe you are interpreting Question and Response 010.15 too
narrowly. While not a requirement, the Standard Review Plan is useful for
determining the intent of Question and Response 010.15. We note that the
Standard Review Plan for this system specifies that an acceptable single
f ailure analysis results in a system which has heat transfer capabilities that
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meet or exceed minimum requirements. This violation example related to
heat transfer capabilities, which did not meet minimum requirements.
As a result of our review, we conclude that Table 9.2 2 should have noted that operator
action is necessary for standby service water Loop A to meet minimum heat transfer
capabilities. The failure to correct the table is a violation of 10 CFR 50.71(e).
With respect to Example 3 of Violation 50-416/9705-03, we acknowledge that different
tables in the Updated Final Safety Analysis Report have different purposes. We note that
you plan to perform a thorough evaluation of the fuel pool decay heat load calculations and
heat removal capabilities, and to revise the Updated Final Safety Analysis Report to clarify
the license basis. Based on this commitment and your conclusion that the information in
each table is appropriate for the pulpose of that table, we will withdraw Example 3 of
Violation 50-416/9705-03.
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Entergy Operations, Inc.
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With respect to Example 4 of Violation 50-416/9703 03, we considered your argument
that Tables 9.216 and 9.217 accurately reflect the current design bases accident
analyses. In our view, the license basis for the fuel pool cooling and cleanup system was
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updated when you received the license amendment to remove your Technical Specification
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limit on the nurnber of spent fuel assemblies in the fuel pool. At that time, your staff
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should have recognized that the new license basis assumption effected the standby service
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water system design basis analysis and taken the steps necessary to update this analysis
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and tne affected Updated Final Safety Analysis Report tables. Maintaining a clear
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understanding of bounding equipment performance specifications is important for both
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adverse condition identification and operability determinations. Since your staff did not
recognize that the fuel pool cooling and cleanup heat exchangers were not being
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maintained consistent with the information in your license amendment request, we
conclude that Example 4 of Violation 50-416/9705-03 is valid.
Sincerely,
James E. Dyer, Deputy
Regional Administrator
Docket No.: 50-416
License No.: NPF-29
cc:
Executive Vice President
and Chief Operating Officer
Entergy Operations, Inc.
P.O. Box 31995
Jackson, Mississippi 39286 1995
Wise, Carter, Child & Caraway
P.O. Cox 651
Jackson, Mississippi 39205
Winston & Strawn
1400 L Street, N.W.
12th Floor
Washington, D.C. 20005 3502
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Entergy Operations, Inc.
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Sam Mabry, Director
Division of Solid Weste Management
Mississippi Department of Natural
Resources
P.O. Box 10385
Jackson, Mississippl 39209
President
Claiborne County Board of Supervisors
Port Gibson, Mississippi 39150
Manager of Operations
Bechtel Power Corporation
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P.O. Box 2166
Houston, Texas 77252 2166
General Manager
Grand Gulf Nuclear Station
Entergy Operations, Inc.
P.O. Box 756
Port Gibson, Mississippi 39150
The Honorable William J. Guste, Jr.
Attorney General
Department of Justice
State of Louisiana
P.O. Box 94005
Baton Rouge, Louisiana 70804 9005
Office of the Governor
State of Mississippi
Jackson, Mississippi 39201
Mike Moore, Attorney General
Frank Spencer, Asst. Attorney General
State of Mississippi
P.O. Box 22947
Jackson, Mississippi 39225
Dr. f. E. Thompson, Jr.
State Health Officer
State Board of Health
P.O. Box 1700
Jackson, Mississippi 39205
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Entergy Operations, Inc.
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Eddie S. Fuente, Director
State Liaison Officer
Division of Radiation Health
Mississippi Department of Health
P.O. Box 1700
Jackson, Mississippl 39215 1700
Vice President
Operations Support
Entergy Operations, Inc.
P.O. Box 31995
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Jackson, Mississippi 39280 1995
Director, Nuclear Safety
and RegJlatory Affairs
Entergy Operations, Inc.
P.O. Box 750
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Port Gibson, Mississippi 39150
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Vice President, Opernions
Grand Gulf Nuclear Station
Entergy Operations, Inc.
P.O. Box 750
Port Gibson, Mississippi 39150
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