NOED-02-4-001 - Grand Gulf Nuclear Station (Entergy Operations, Inc.)

April 2, 2002

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


Dear Mr. Eaton:

By letter dated March 29, 2002, 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 telephone conversations on March 28, 2002, at 4 p.m. and 12 midnight (all times are CST). Participants in the final telephone conversation included Ken Brockman, Director, Division of Reactor Projects, and members of the Region IV staff; Robert A. Gramm, Section Chief, Project Directorate IV-1, Division of Licensing Project Management, Office of Nuclear Reactor Regulation (NRR), and members of the NRR staff; and Jerry Roberts, Director of Nuclear Safety Assurance, Grand Gulf Nuclear Station, and other members of the Grand Gulf staff. Mr. Roberts stated that on March 29, 2002, at 4:02 a.m. the plant would no longer be in compliance with TS 3.8.1, Required Action B.4, which requires that, if an inoperable diesel generator (DG) is 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 4:02 a.m. on March 26, 2002, for the Division 2 DG. Entergy Operations requested that an 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 4:02 a.m. on March 29 until 4:02 a.m. on April 1, 2002, a period of 72 hours past the Limiting Condition for Operation completion time.

According to your staff, the Division 2 DG was declared inoperable at 4:02 a.m. on March 26, 2002, for planned maintenance. At that point, the 72-hour completion time was entered in accordance with TS 3.8.1, Action B.4. During the planned maintenance, the process of pressurizing and depressurizing the control air system combined with the infant mortality failures of some of the process sensors caused trips of the DG, keeping the DG inoperable until additional repairs could be performed. The remaining completion time was insufficient for repair of the process sensors and completion of the required surveillance. The degraded condition of the DG had two potential outcomes: either maintain the plant at power for a period not to exceed an additional 72 hours to complete repairs and the required surveillance test or proceed to COLD SHUTDOWN in accordance with the TS.

Entergy Operations asserted that, based on your quantitative and qualitative assessment and the combined compensatory measures, the proposed enforcement discretion did not involve an increase in radiological risk and that the granting of enforcement discretion would not be a potential detriment to public health and safety. Your compensatory measures included 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 72 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 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 2 DG for the period of time not to exceed from March 29, 2002, at 4:02 a.m. until April 1, 2002, at 4:02 a.m. or the time the Division 2 DG is returned to an operable status. This letter documents our telephone conversation of March 29, 2002, at 12:30 a.m. when we orally issued this NOED. 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 March 29 at 1:36 p.m.

However, as stated in the NRC's 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.

    Ellis W. Merschoff
Regional Administrator

Docket: 50-416
License: 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 39215

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

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