NOED-01-4-001 - Grand Gulf (Entergy Operations, Inc.)

February 23, 2001

William A. Eaton, Vice President
Operations-Grand Gulf Nuclear Station
P. O. Box 756
Port Gibson, Mississippi 39150


Dear Mr. Eaton:

By letter dated February 22, 2001, Entergy Operations, Inc. requested that the NRC exercise discretion not to enforce compliance with the actions required in Technical Specification (TS) 3.8.1, "AC Sources - Operating." That letter documented information previously discussed with the NRC in a telephone conversation on February 21, 2001, at 2:30 p.m. (all times are CST). Participants in the telephone conversation included Ken Brockman, Acting Regional Administrator, RIV, and members of his staff; Stuart Richards, Director, Project Directorate IV, Division of Licensing Project Management, Office of Nuclear Reactor Regulation (NRR), and members of the NRR staff; and you, William Eaton, Vice President, Operations, and members of your staff. During the conversation, you stated that on February 22, 2001, at 1:00 a.m. the plant would not be in compliance with TS 3.8.1, Required Action B.4, which would require that if an inoperable diesel generator (DG) was not restored to an operable status within 72 hours, the unit must be placed in HOT SHUTDOWN (Mode 3) within the following 12 hours and in COLD SHUTDOWN (Mode 4) within the following 36 hours. The Limiting Condition for Operation was entered at 1:00 a.m. on February 19, 2001, for the Division 1 DG. You requested that a Notice of Enforcement Discretion (NOED) be issued pursuant to the NRC's policy regarding exercise of discretion for an operating facility, set out in Section VII.c, of the "General Statement of Policy and Procedures for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600, and be effective for the period 1:00 a.m. on February 22 until 1:00 p.m. on February 23, 2001, a period of 36 hours past the Limiting Condition for Operation completion time.

According to your staff, the Division 1 DG was declared inoperable at 1:00 a.m. on February 19, 2001, due to a cooling water leak that occurred during a planned surveillance test. At that point, the 72-hour completion time was entered in accordance with TS 3.8.1, Action B.4. Following the repair to the cooling water system, the surveillance was restarted. During the second surveillance, a fuel oil leak occurred which required the DG to be shutdown prior to completion of the surveillance. The remaining completion time was insufficient for repair of the leak and completion of the required surveillance. The degraded condition of the DG had two potential outcomes: either maintain the plant at power for an additional 36 hours to complete repairs and the required surveillance test, or proceed to COLD SHUTDOWN in accordance with the TS. The increase in core damage probability associated with the Division 1 DG being out of service for an additional 36 hours was determined to be minimal. This minimal risk was compared to a qualitative assessment of the potential risk associated with a plant shutdown to comply with TS 3.8.1. You stated that the minimal change in risk in allowing the additional 36 hours is preferable to the potential consequences associated with a plant shutdown.

Your compensatory measures include increased staffing and management oversight during the enforcement discretion period, assuring and verifying the availability of all remaining electrical supplies and reactor water injection paths, curtailment of activities that could affect the availability or operability of electrical power sources or cause plant transients, and review of the compensatory measures during preshift briefings.

NRC staff evaluated your request, and agreed that maintaining the plant stable at power for an additional 36 hours was preferable to the potential for a plant transient that could occur during a plant shutdown. The NRC agreed that your no significant hazards consideration was appropriate, your compensatory measures were appropriate, and your corrective actions were appropriate for the Division 1 DG, including actions to ensure that the condition did not exist on the Division 2 DG.

On the basis of the staff's evaluation of your request, including the compensatory measures described above, the staff has concluded that an NOED is warranted because we are clearly satisfied that this action involves minimal or no safety impact and has no adverse radiological impact on public health and safety. Additionally, we determined that the request satisfied the NRC's policy for enforcement discretion. Therefore, it is our intention to exercise discretion not to enforce compliance with TS 3.8.1, Required Action B.4 for the inoperable Division 1 DG for the period of time not to exceed from February 22, 2001, at 1:00 a.m. until February 23, 2001, at 1:00 p.m. or the time the Division 1 DG is returned to an operable status. This letter documents our telephone conversation of February 21, 2001, at 2:30 p.m. when we orally issued this notice of enforcement discretion. We understand that the condition causing the need for this NOED was corrected by you causing you to exit from TS 3.8.1 and from this NOED on February 22 at 6:11 p.m.

However, as stated in the Enforcement Policy, action will normally be taken, to the extent that violations were involved, for the root cause that led to the noncompliance for which this NOED was necessary.

  /original signed by E. W. Merschoff/
  Ellis W. Merschoff
Regional Administrator

Docket No: 50-416
License No: NPF-29


Executive Vice President
  and Chief Operating Officer
Entergy Operations, Inc.
P.O. Box 31995
Jackson, Mississippi 39286-1995

Wise, Carter, Child & Caraway
P.O. Box 651
Jackson, Mississippi 39205

Winston & Strawn
1400 L Street, N.W. - 12th Floor
Washington, DC 20005-3502

Sam Mabry, Director
Division of Solid Waste Management
Mississippi Department of Natural
P.O. Box 10385
Jackson, Mississippi 39209

President, District 1
Claiborne County Board of Supervisors
P.O. Box 339
Port Gibson, Mississippi 39150

General Manager
Grand Gulf Nuclear Station
Entergy Operations, Inc.
P.O. Box 756
Port Gibson, Mississippi 39150

The Honorable Richard Ieyoub
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

Robert W. Goff, Program Director
Division of Radiological Health
Mississippi Dept. of Health
P.O. Box 1700
Jackson, Mississippi 39215-1700

Vice President
Operations Support
Entergy Operations, Inc.
P.O. Box 31995
Jackson, Mississippi 39286-1995

Director, Nuclear Safety
  and Regulatory Affairs
Entergy Operations, Inc.
P.O. Box 756
Port Gibson, Mississippi 39150

Vice President, Operations
Grand Gulf Nuclear Station
Entergy Operations, Inc.
P.O. Box 756
Port Gibson, Mississippi 39150

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