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05000416/FIN-2017007-0431 December 2017 23:59:59Grand GulfNRC identifiedFailure to Update the Final Safety Analys is ReportThe team identified three examples of a Severity Level IV, non-cited violation of 10 CFR 50.71, Maintenance of Records, Making of Reports, Section (e), which states, in part, Each person licensed to operate a nuclear power reactor shall update periodically the final safety analysis report originally submitted as part of the application for the license, to assure that the information included in the report contains the latest information developed. This submittal shall contain all the changes necessary to reflect information and analyses submitted to the Commission by the applicant or licensee, or prepared by the applicant or licensee pursuant to Commission requirement since the submittal of the original or the last update to the final safety analysis report. Specific ally, prior to September 29, 2017, the licensee failed to ensure the final safety analysis report reflected the current plant configuration. In response to this issue, the licensee created a corrective action to update the final safety analysis report. The finding was entered into the licensees corrective action program as Condition Reports CR -GGN -2017- 09154, CR- HQN- 2017- 01356, and CR -GGN -2017 -09747. 5 The team determined that the failure to update the final safety analysis report in accordance with 10 CFR 50.71(e) was a performance deficiency. Following the Reactor Oversight Process (ROPs) significance determination process, the team determined this violation was associated with a minor performance deficiency. The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to also address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter non- compliance. Assessing the performance deficiency in accordance with the NRC Enforcement Policy, the team determined it to be a Severity Level IV violation because the lack of up- to-date information in the final safety analysis report has not resulted in any unacceptable change to the facility or procedures. This finding did not have an assigned cross-cutting aspect because cross-cutting aspects are not assigned to traditional enforcement violations
05000416/FIN-2017002-0430 June 2017 23:59:59Grand GulfLicensee-identifiedLicensee-Identified ViolationLicense Condition 2.C (46)( g) requires, at the end of the second refueling outage following the implementation of the EPU, the licensee shall submit a long- term steam dryer inspection plan based on industry operating experience along with the baseline inspection results f or NRC review and approval. Contrary to the above, since May 15, 2014, the licensee did not submit a long -term steam dryer inspection plan based on industry operating experience along with the baseline inspection results for NRC review and approval. The NRCs significance determination process is not designed to assess the significance of violations that impact or impede the regulatory process. Therefore, the issue of an untimely inspection plan submittal was assessed using the traditional enforcement process in accordance with the Enforcement Policy. The inspectors determined the violation to be at Severity Level IV because it is similar to examples in the Enforcement Policy Section 6.9.d. Since this issue was entered into the licensees corrective action program as Condition Report CR -GGN -1-2017 -03404, compliance was restored within a reasonable period of time, the violation was not repetitive, and the violation was not willful, this violation is being treated as a n on-cited violation (NCV), consistent with Section 2.3.2.a of the Enforcement Policy. Traditional enforcement violations are not assigned a cross -cutting aspect.
05000416/FIN-2017002-0530 June 2017 23:59:59Grand GulfLicensee-identifiedLicensee-Identified ViolationTitle 10 CFR 50.72(b)(2)(iv)(B) requires, in part, the licensee shall notify the NRC as soon as practical , and in all cases within 4 hours of the occurrence, of any event or 24 condition that results in actuation of the reactor protection system (RPS) when the reactor is critical. Contrary to the above, on April 4, 2017, the licensee did not notify the NRC within 4 hours of the occurrence of any event or condition that resulted in actuation of the RPS when the reactor was critical. Specifically, the licensee failed to notify the NRC within 4 hours after they performed a manual scram of the reactor due to a failure in the condensate system. The NRCs significance determination process is not designed to assess the significance of violations that impact or impede the regulatory process. Therefore, the issue of an untimely notification was assessed using the traditional enforcement process in accordance with the Enforcement Policy. The inspectors determined the violation to be at Severity Level IV in accordance with Enforcement Policy Section 6.9.d.9. Since this issue was entered into the licensees corrective action program as Condition Report CR -GGN -1-2017 -03331, compliance was restored within a reasonable period of time, the violation was not repetitive, and the violation was not willful, this violation is being treated as a non-cited violation (NCV), consistent with Section 2.3.2.a of the Enforcement Policy. Traditional enforcement violations are not assigned a cross -cutting aspect.
05000416/FIN-2017002-0230 June 2017 23:59:59Grand GulfLicensee-identifiedLicensee-Identified ViolationTitle 10 CFR 72.44(d)(3) requires, in part, that an annual report be submitted to the Commission, specifying the quantity of each of the principal radionuclides released to the environment in liquid and in gaseous effluents during the previous 12 months of operation and such other information as may be required by the Commission to estimate maximum potential radiation dose commitment to the public resulting from effluent releases. The report must be submitted within 60 days after the end of the 12- month monitoring period. Contrary to the above, from March 2, 2017 , until April 27, 2017, the licensee did not submit the annual report within 60 days after the end of the 12- month monitoring period. The NRCs significance determination process is not designed to assess the significance of violations that impact or impede the regulatory process. Therefore, the issue of an untimely annual report submittal was assessed using the traditional enforcement process in accordance with the Enforcement Policy. The inspectors determined the violation to be at Severity Level IV because the licensee submitted the annual report approximately 2 months late, and it is similar to examples in the Enforcement Policy , Section 6.9.d. Since this issue was entered into the licensees corrective action program as Condition Report CR-GGN-1-2017-03092 , compliance was restored within a reasonable period of time, the violation was not repetitive, and the violation was not willful, this violation is being treated as a n on-cited violation (NCV), consistent with Section 2.3.2.a of the Enforcement Policy. Traditional enforcement violations are not assigned a cross -cutting aspect .
05000416/FIN-2017002-0330 June 2017 23:59:59Grand GulfLicensee-identifiedLicensee-Identified ViolationLicense Condition 2.C (46)(f) requires, during the first two scheduled refueling outages after reaching full EPU (extended power uprate) conditions, Entergy shall conduct a visual inspection of all accessible, susceptible locations of the steam dryer in accordance with BWRVIP -139 and GE inspection guidelines. Entergy shall report the results of the visual inspections of the steam dryer to the NRC staff within 60 days following startup. Contrary to the above, on August 16, 2012 , and May 15, 2014, the licensee did not report the results of the visual inspections of the steam dryer to the NRC staff within 60 days following startup. The NRCs significance determination process is not designed to assess the significance of violations that impact or impede the regulatory process. Therefore, the issue of an untimely inspection results submittal was assessed using the traditional enforcement process in accordance with the Enforcement Policy. The inspectors determined the violation to be at Severity Level IV because it is similar to examples in the Enforcement Policy Section 6.9.d. Since this issue was entered into the licensees corrective action program as Condition Report CR -GGN -1-2017 -03404, compliance was restored within a reasonable period of time, the violation was not repetitive, and the violation was not willful, this violation is being treated as a n on-cited violation (NCV), consistent with Section 2.3.2.a of the Enforcement Policy. Traditional enforcement violations are not assigned a cross -cutting aspect.
05000416/FIN-2015007-0731 December 2015 23:59:59Grand GulfNRC identifiedFailure to Update the Final Safety Analysis ReportThe team identified six examples of a Severity Level IV, non-cited violation of 10 CFR 50.71, Maintenance of Records, Making of Reports, Section (e) which states, in part, each person licensed to operate a nuclear power reactor shall update periodically the final safety analysis report originally submitted as part of the application for the license, to assure that the information included in the report contains the latest information developed. This submittal shall contain all the changes necessary to reflect information and analyses submitted to the Commission by the applicant or licensee or prepared by the applicant or licensee pursuant to Commission requirement since the submittal of the original or the last update to the final safety analysis report. Specifically, since July 18, 2012, the licensee failed to ensure the updated final safety analysis report reflected the current plant configuration. In response to these issues, the licensee initiated corrective actions to update the updated final safety analysis report with the correct information. This violation was entered into the licensees corrective action program as Condition Reports CR-GGN-2015-4381, CR-GGN-2015-4671, CR-GGN-2015-4733, CR-GGN-2015-4753, CR-GGN-2015-4811, and CR-GGN-2015-4867. The team determined that the failure to update the final safety analysis report in accordance with 10 CFR 50.71(e) was a performance deficiency. Traditional enforcement was applied to this performance deficiency because it involved a violation that impacted the ability of the -8- Attachment NRC to perform its regulatory oversight function. Assessing the violation in accordance with the NRC Enforcement Policy, the team determined it to be a Severity Level IV violation because the lack of up-to-date information in the final safety analysis report has not resulted in any unacceptable change to the facility or procedures. This violation did not have an assigned crosscutting aspect because crosscutting aspects are not assigned to traditional enforcement violations.
05000416/FIN-2015007-0831 December 2015 23:59:59Grand GulfNRC identifiedIncomplete and Inaccurate Response to NRC Bulletin 88-04The team identified a Severity Level IV, non-cited violation of 10 CFR 50.9, Completeness and Accuracy of Information, Section (a) which requires information provided to the Commission by an applicant for a license or by a licensee or information required by statute or by the Commissions regulations, orders, or license conditions to be maintained by the applicant or the licensee shall be complete and accurate in all material respects. Specifically, since November 1, 1991, the licensees response did not include verification from the pump suppliers that the minimum flow rates were sufficient to ensure that there will be no pump damage from low flow operation, or a plan to obtain additional test data and/or modify the minimum flow capacity as needed, per Requested Actions 3 and 6 of NRC Bulletin 88-04. In response to this issue, the licensee initiated corrective actions to submit the correct information. This violation was entered into the licensees corrective action program as Condition Report CR-GGN-2015-4681. The team determined that the failure to correct an incomplete and inaccurate response to NRC Bulletin 88-04, Requested Actions 3 and 6 was a performance deficiency. Traditional enforcement was applied to this performance deficiency because it involved a violation that impacted the ability of the NRC to perform its regulatory oversight function. Assessing the violation in accordance with Section 6.9 of the NRC Enforcement Policy, the team determined it to be a Severity Level IV violation because it resulted in no or relatively inappreciable potential safety or security consequences. This violation did not have a crosscutting aspect because crosscutting aspects are not assigned to traditional enforcement violations.
05000416/FIN-2015008-0431 December 2015 23:59:59Grand GulfNRC identifiedFailure to Make Required Event NotificationThe team identified two examples of a Severity Level (SL) IV non-cited violation of 10 CFR 50.72(b)(3)(v)(C), for the failure to make an eight-hour report to the NRC for a condition that prevented the fulfillment of the safety function needed to control the release of radioactive material. Specifically, on August 1, 2015, and again on October 1, 2015, after failed secondary containment surveillance tests, the licensee failed to make an eight-hour report to the NRC for the loss of secondary containment barrier safety function needed to control the release of radioactive material. The licensee entered this issue into their corrective action program as Condition Report CR-GGN-2015-05826. The failure to report a condition that could have prevented the fulfillment of a systems safety function as required by 10 CFR 50.72(b)(3)(v)(C) is a performance deficiency. This performance deficiency was screened using Inspection Manual Chapter 0612 and was determined to be minor in the Reactor Oversight Process. However, due to the performance deficiency affecting the NRCs ability to perform its regulatory oversight function, this performance deficiency was evaluated for traditional enforcement in accordance with the NRC Enforcement Policy. This performance deficiency was determined to be a Severity Level IV violation in accordance with Section 6.9.d.9 of the NRC Enforcement Policy, dated February 4, 2015. No cross-cutting aspect was assigned to this violation because no Reactor Oversight Process finding exists.
05000416/FIN-2015004-0331 December 2015 23:59:59Grand GulfNRC identifiedFailure to Make a Required Eight-Hour Report for Loss of Safety FunctionThe inspectors identified a Severity Level IV, non-cited violation of 10 CFR 50.72(b)(3)(v)(C), for the licensees failure to make a required eight-hour report to the NRC for a condition that could have prevented fulfillment of the safety function of structures or systems that are needed to control the release of radioactive material. Specifically, on October 14, 2015, the licensee failed to make the required eight-hour report following two primary containment isolation valves, 1P11F130 and 1P11F131, in the same flow path being declared inoperable. On October 15, 2015 at 9:07 pm, the licensee made a late Event Notification, EN 51473. The licensee entered this issue into their corrective action program as Condition Report CR-GGN-2015-6043. The failure to make an eight-hour report, as required by 10 CFR 50.72(b)(3)(v)(C), for a condition that could have prevented fulfillment of a safety function was a performance deficiency. This performance deficiency was screened using Inspection Manual Chapter 0612 and was determined to be a minor violation in the Reactor Oversight Process. However, due to the performance deficiency affecting the NRCs ability to perform its regulatory oversight function, this performance deficiency was evaluated for traditional enforcement in accordance with the NRC Enforcement Policy. This performance deficiency was determined to be a Severity Level IV violation in accordance with Section 6.9.d.9 of the NRC Enforcement Policy, dated February 4, 2015. No cross-cutting aspect was assigned to this violation because no Reactor Oversight Process finding existed.
05000416/FIN-2015007-0531 December 2015 23:59:59Grand GulfNRC identifiedFailure to Maintain a Safety-Related Cable Tray Overfill Analysis RecordThe team identified a Severity Level IV, non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVII, Quality Assurance Records, which states, in part, that sufficient records shall be maintained to furnish evidence of activities affecting quality and shall be identifiable and retrievable. Specifically, prior to August 11, 2015, the licensee failed to maintain and retrieve the cable tray overfill analysis for safety-related cable tray 1BATNQ01. In response to the issue, the licensee recreated the cable tray overfill analysis. This violation was entered into the licensees corrective action program as Condition Report CR-GGN-2015-4602. The team determined that the failure to retrieve the safety-related cable tray overfill analysis record in accordance with 10 CFR 50 Appendix B, Criterion XVII was a performance deficiency. Traditional enforcement was applied to this performance deficiency because it involved a violation that impacted the ability of the NRC to perform its regulatory oversight function. Assessing the violation in accordance with the NRC Enforcement Policy, the team determined it to be a Severity Level IV violation because the cable tray overfill analysis was not retrievable. This violation did not have an assigned crosscutting aspect because crosscutting aspects are not assigned to traditional enforcement violations.
05000416/FIN-2015406-0130 September 2015 23:59:59Grand GulfLicensee-identifiedSecurity
05000416/FIN-2015002-0330 June 2015 23:59:59Grand GulfNRC identifiedFailure to the Update the Final Safety Analysis Report after the Extended Power UprateThe inspectors identified a non-cited violation with three examples for the licensees failure to update the Updated Final Safety Analysis Report in accordance with 10 CFR Part 50.71(e). Specifically, the licensee failed to update the Grand Gulf Nuclear Station Updated Final Safety Analysis Report, Section 15.2.2.2.2.1, Generator Load Rejection with Bypass, to appropriately reflect the anticipated plant response to a full load reject after the completion of the extended power uprate. Additionally, the inspectors determined that the licensee did not adequately describe the extended power uprate changes in the Updated Final Safety Analysis Report Chapters 11 (Radioactive Waste Management) and 12 (Radiation Protection) and submit an update to the NRC. The licensee documented this issue in Condition Reports CR-GGN-2015-00892, CR-GGN-2015-01607, and CR-GGN-2015-01610. The licensees failure to update the Updated Final Safety Analysis Report in a timely manner is a performance deficiency. This performance deficiency was evaluated using traditional enforcement because it has the potential to impact the NRCs ability to perform its regulatory function. The inspectors used the NRC Enforcement Policy to evaluate the significance of this violation. Consistent with Section 6.1.d.3 of the NRC Enforcement Policy, the inspectors determined that the performance deficiency is a Severity Level IV non-cited violation because the lack of up-to-date information in the Updated Final Safety Analysis Report has not resulted in any unacceptable change to the facility or procedures. This non-cited violation has no cross-cutting aspect because there was no finding associated with this traditional enforcement violation.
05000416/FIN-2013004-0230 September 2013 23:59:59Grand GulfNRC identifiedFailure to Obtain NRC Approval for a Change in Method of Evaluation for Determining Reactor Vessel FluenceThe team identified a Severity Level IV non-cited violation of 10 CFR 50.59, Changes, Tests, and Experiments, involving the licensees failure to obtain a license amendment pursuant to 10 CFR 50.90 prior to implementing a new method of evaluation for determining reactor vessel neutron fluence. On November 4, 2003, the NRC issued Amendment Number 160 to the Facility Operating License of the Grand Gulf Nuclear Station. The amendment revised the Updated Final Safety Analysis Report (UFSAR) to change the Reactor Vessel Material Surveillance Program to reflect participation in the Boiling Water Reactor Vessel and Internals Project (BWRVIP) Integrated Surveillance Program (ISP). Additionally, the amendment revised the UFSAR to state that neutron fluence calculations performed after 2002 will be in accordance a methodology that has been approved by the NRC staff and is consistent with the attributes identified in NRC Regulatory Guide 1.190, Calculation and Dosimetry Methods for Determining Pressure Vessel Neutron Fluence. The licensee developed a new neutron fluence calculation method which was based on a neutron fluence calculation method that had been previously approved by the NRC for another facility, which was documented in Nine Mile Point Nuclear Station, Unit No. 1 Issuance of Amendment RE: Pressure-Temperature Limit Curves and Tables, dated October 27, 2003. The NRC identified that the calculation, which was developed for GGNS, used the CASMO-4/SIMULATE code package to calculate the neutron source, whereas the prior calculation performed for Nine Mile Point Nuclear Station (NMP) used the ORIGEN code to calculate the neutron source. The inspectors determined that, although these codes are intended for the same purpose, they are distinct codes and the NRC approved only the use of one neutron source code (i.e., ORIGEN) in the neutron fluence calculation method of evaluation at Nine Mile Point. This finding was entered into the licensees corrective action program as Condition Report CR-GGN-2013-04743. The licensees failure to determine that a change to their method of evaluation for calculating reactor vessel neutron fluence was a departure from a method of evaluation approved by the NRC and required NRC review and approval prior to implementation was a performance deficiency. The performance deficiency was evaluated using traditional enforcement because the finding had the ability to impact the regulatory process. The performance deficiency was more than minor because there was a reasonable likelihood that the change would require NRC review and approval prior to implementation. In accordance with the NRC Enforcement Manual, risk insights from Inspection Manual Chapter 0609, Significance Determination Process, are used in determining the significance of 10 CFR 50.59 violations. Using the Inspection Manual Chapter 0612, Appendix B, Issue Screening, the team determined the finding adversely affected the Barrier Integrity Cornerstone. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, the team determined the finding required a detailed risk evaluation because the finding involved the reactor coolant system boundary. A Senior Reactor Analyst performed the evaluation and determined the finding had very low safety significance (i.e., Green) because the NRC performed calculations and did not determine that the licensees Pressure-Temperature limits had or would have expired or been invalid; therefore, the change in risk was negligible. Since the finding had very low safety significance, the finding was determined to be Severity Level IV, in accordance with the NRC Enforcement Policy. The finding does not have a cross-cutting aspect because cross-cutting aspects are not assigned to traditional enforcement violations.
05000416/FIN-2013003-0230 June 2013 23:59:59Grand GulfNRC identifiedFailure to Revise Figures and Tables in the Updated Final Safety Analysis ReportThe inspectors identified a non-cited violation of 10 CFR 50.71(e)(4), which requires the Final Safety Analysis Report be updated, at intervals not exceeding 24 months, and states in part, the revisions must reflect all changes made in the facility or procedures described in the FSAR. Specifically, the inspectors identified three examples of changes to figures or tables that had not been included in the licensees Updated Final Safety Analysis Report submittal in November, 2012: (1) Figure 9.2-027, Sheet 2, Revision 16 Plant Service Water Radial Well System Unit 1 (2) Figure 10.4-011, Condensate System (Drawing M-1053B, Revision 28), and (3) Table 9.1-12, Maximum Fuel Pool Heat Load did not include values associated with the extended power uprate. This finding has been entered into the licensees corrective action program as Condition Reports CR-GGN-2013-00426, CR-GGN-2013-02661, and CR-GGN-2013-02471. The failure of the licensee to include all changes made to the facility or procedures in their November 2012 update to the original revision of the Final Safety Analysis Report is a performance deficiency. The issue is a performance deficiency because it was a failure to meet a requirement, 10 CFR 50.71(e)(4), and it was within the licensees ability to correct this problem. Using Inspection Manual Chapter 0612, Appendix B, the performance deficiency was assessed through both the Reactor Oversight Process and traditional enforcement because the finding had the potential for impacting the NRCs ability to perform its regulatory function. By screening through the Reactor Oversight Process, the finding resulted in a minor performance deficiency. Following the traditional enforcement path, the inspectors used the NRC Enforcement Policy, dated January 28, 2013, to evaluate the significance of this violation. Consistent with the NRC Enforcement Policy and in accordance with Section 6.1.d.3, this finding was determined to be a Severity Level IV non-cited violation because the licensee failed to update the Final Safety Analysis Report as required by 10 CFR 50.71(e)(4). However, the lack of up-to-date information had not resulted in any unacceptable change to the facility or procedures. This finding had no crosscutting aspect.
05000416/FIN-2013201-0130 June 2013 23:59:59Grand GulfNRC identified10 CFR 54.13 Apparent Violation for failure to provide complete and accurate information in response to RAIsThis letter refers to the evaluations by the U.S. Nuclear Regulatory Commission (NRC) Office of Nuclear Reactor Regulation (NRR) of responses dated May 25,2012, provided by Entergy Operations, Inc. (EOI), to requests for additional information (RAls) associated with the license renewal application for the Grand Gulf Nuclear Station. The responses pertained to requests by the NRC regarding the site\'s implementation of aging management activities for components included in two aging management programs. The NRC evaluation identified one apparent violation of NRC requirements that is being considered for escalated enforcement action in accordance with the NRC Enforcement Policy. The NRC evaluation determined that EOI apparently failed to provide complete and accurate information to the NRC in responses dated May 25, 2012, to RAls B.1.22-1, B.1.22-2, and B.1.41-3. The three RAls addressed several issues with the aging management activities for the Flow-Accelerated Corrosion program and the Service Water Integrity program. The license renewal application stated that both of these programs were consistent with the corresponding programs described in NUREG-1801, \"Generic Aging Lessons Learned (GALL) Report.\" However, during its reviews of operating experience associated with these programs, the staff found indications that aspects of these programs were inconsistent with corresponding programs in the GALL Report. Enforcement is not being considered for the statements in the initial license renewal application, but for the apparent incomplete or inaccurate information in the responses to RAls intended to evaluate potential inconsistencies with the programs in the GALL Report. The RAI responses were material because the NRC needed the requested information to verify that certain components would be adequately managed for erosion mechanisms so that the intended functions will be maintained consistent with the current licensing basis, as required by 10 CFR 54.21 (a)(3). Therefore, EOI appears to be in violation of 10 CFR 54.13.
05000416/FIN-2012008-0330 September 2012 23:59:59Grand GulfNRC identifiedFailure to Obtain NRC Approval for a Change to Credible Passive Failures in the Standby Service Water SystemThe team identified a Severity Level IV non-cited violation of 10 CFR 50.59, Changes, Tests and Experiments which states, in part, that a licensee shall obtain a license amendment pursuant to Section 50.90 prior to implementing a proposed change, test, or experiment if this activity would; result in more than a minimal increase in the likelihood of occurrence of a malfunction of a structure, system, or component important to safety previously evaluated in the final safety analysis report (as updated). Specifically, on August 18, 1987, the licensee implemented a change to the updated safety analysis report which limited credible passive failures in the standby service water system to pump and valve sea! leakage without obtaining a license amendment. This finding was entered into the licensee\'s corrective action program as Condition Report CR-GGN-2012-09267. The team determined that the licensee\'s failure to receive prior NRC approval for changes in licensed activities regarding single passive failure criteria for the standby service water system was a performance deficiency. The performance deficiency was evaluated using traditional enforcement because the finding had the ability to impact the regulatory process. The performance deficiency was more than minor because there was a reasonable likelihood that the change would require NRC review and approval prior to implementation. In accordance with the NRC Enforcement Manual, risk insights from the Inspection Manual Chapter 0609, Significance Determination Process, are used in determining the significance of 10 CFR 50.59 violations. Using the Inspection Manual Chapter 0609, A, Significance Determination Process for Findings At-Power, the team determined that the finding represented a loss of safety function in that the standby service water system could not meet its 30-day mission time to provide decay heat removal. Therefore, a Detailed Risk Evaluation was necessary. In accordance with Manual Chapter 0609, Appendix A, Section 6, Detailed Risk Evaluation, the senior reactor analyst evaluated the risk of the degraded condition that resulted from the finding. According to the Risk Assessment of Operational Events Handbook, Volume 1-lnternal Events, Section 4.1, Mission Time Modeling, in most events, 24 hours is sufficient time to bring numerous resources to bear on core cooling. In some events, the choice is conservative and the analysis results are overestimates. Additionally, the analyst determined that Section 4.2 on increasing mission time was not applicable to the subject finding because the decrease in standby service water system water inventory would be obvious and there would be days to respond with makeup sources. Therefore, the analyst determined that the finding was of very low safety significance (Green) because, although the standby service water system could not provide 30 days of decay heat removal without operator action to provide makeup water to the system, it would have been able to complete its 24-hour risk significant mission time. Since the finding had very low safety significance, the finding was determined to be Severity Level IV, in accordance \\, Iith the NRC Enforcement Policy. The finding does not have a crosscutting aspect because the most significant contributor to the finding does not reflect current licensee performance.
05000416/FIN-2012002-0431 March 2012 23:59:59Grand GulfNRC identifiedModification of the Spent Fuel Pool without Prior NRC ApprovalThe 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
05000416/FIN-2011006-0231 December 2011 23:59:59Grand GulfNRC identifiedFailure to Report a Condition Prohibited by Technical SpecificationsThe team identified a Severity Level IV noncited violation of 10 CFR 50.73, Licensee Event Report System, associated with the licensee\'s failure to submit a licensee event report within 60 days following discovery of an event meeting the reporting criteria as specified. Specifically, the licensee was not meeting the technical specification surveillance requirement for venting the reactor core cooling isolation system and subsequently the system was inoperable in excess of the allowed outage time which constituted a condition prohibited by technical specifications. The licensee entered this condition into their corrective action program as condition report CR-GGN- 2011-8890. This finding affects the mitigating systems cornerstone and is greater than minor because the NRC relies on licensees to identify and report conditions or events meeting the criteria specified in the regulations in order to perform its regulatory function. Because this issue affected the NRC\'s ability to perform its regulatory function, it was evaluated with the traditional enforcement process. Consistent with the guidance in Section 6.9 of the Enforcement Policy, this finding was determined to be a Severity Level IV noncited violation. This finding has no crosscutting aspect, as it is not indicative of current performance.
05000416/FIN-2011002-0231 March 2011 23:59:59Grand GulfNRC identifiedFailure to Update Available Low Pressure Coolant Injection Loops in the Updated Final Safety Analysis ReportInspectors identified a noncited violation of 10 CFR 50.71(e)(4), which requires the final safety analysis report be updated, at intervals not exceeding 24 months, to reflect changes made in the facility or procedures described in the final safety analysis report. Licensee personnel failed to update the original revision of the final safety analysis report to reflect the actual number of low pressure coolant injection loops available for automatic initiation during shutdown cooling operations in Mode 3. The licensee plans to update the final safety analysis report at the next scheduled revision. This finding was entered into the licensees corrective action program as condition report CR-GGN-2011-01631. The failure of licensing personnel to update the final safety analysis report to reflect the available low pressure coolant injection loops for automatic initiation during shutdown cooling operations in Mode 3 was a performance deficiency. This finding was evaluated using traditional enforcement because it had the potential for impacting the NRCs ability to perform its regulatory function. The inspectors used the NRC Enforcement Policy, dated September 30, 2010, to evaluate the significance of this violation. Consistent with the NRC Enforcement Policy, this finding was determined to be a Severity Level IV noncited violation.