ML20216C719

Ack Receipt of 970630 Ltr,In Response to Nov,Dtd 970529 Re Insp Rept 50-416/97-05.Two Concerns Raised in Ltr Being Addressed

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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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 p

- regulatory criteria which are part of your license basis. At the time of the inspection, it <0

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 ..

event which was part of your safety analysis, i.e., loss-of-coolant accident coincident with [

loss-of-offsite power. However, we note that you provided new information related to this o

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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E-Mail report to Document Control Desk (DOCDESK)

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Regional A,dministrator Senior Resident inspector (River Bend)

DRP Director DRS-PSB

Branch Chief (DRP/G) MIS System

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Branch Chief (DRP/TSS) Senior Resident inspector (Grand Gulf)

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Entergy Operations , Inc. 2-

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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 j

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 '

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. -3-

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

l limit on the nurnber of spent fuel assemblies in the fuel pool. At that time, your staff

should have recognized that the new license basis assumption effected the standby service

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l water system design basis analysis and taken the steps necessary to update this analysis

l and tne affected Updated Final Safety Analysis Report tables. Maintaining a clear

i understanding of bounding equipment performance specifications is important for both

! adverse condition identification and operability determinations. Since your staff did not

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recognize that the fuel pool cooling and cleanup heat exchangers were not being

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. 4-

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

l 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. 5-

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

! Jackson, Mississippi 39280 1995

Director, Nuclear Safety

and RegJlatory Affairs

Entergy Operations, Inc.

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P.O. Box 750

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Port Gibson, Mississippi 39150

l Vice President, Opernions

Grand Gulf Nuclear Station

Entergy Operations, Inc.

P.O. Box 750

Port Gibson, Mississippi 39150

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