Entergy Operations Inc., (Grand Gulf Nuclear Station, Unit No. 1); Exemption

NUCLEAR REGULATORY COMMISSION

[Docket No. 50-416]

Entergy Operations Inc., (Grand Gulf Nuclear Station, Unit No.

1); Exemption

I

Entergy Operations, Inc., (the licensee) is the holder of Facility

Operating License No. NPF-29, which authorizes operation of the Grand

Gulf Nuclear Station, Unit 1. The operating license provides, among

other things, that the licensee is subject to all rules, regulations,

and orders of the Commission now and hereafter in effect.

The facility consists of a boiling water reactor at the licensee's

site in Claiborne County, Mississippi.

II

By letter dated August 13, 1993, as supplemented by letters dated

April 15, May 11, June 24, and July 20, 1994, and April 18, 1995,

pursuant to 10 CFR 50.12(a), Entergy Operations Inc. requested an

exemption to Sections III.D.1(a), III.D.2, III.D.2(b)(i),

III.D.2.(b)(iii) and III.D.3 of 10 CFR Part 50, Appendix J, to permit

the selection of containment leakage rate testing intervals for

components on the basis of performance.

Although the staff had issued an Advanced Notice of Proposed Rule

Making to revise Appendix J on November 24, 1992 (57 FR 55156), the

licensee stated in the August 13, 1993, submittal that the ``plant

specific needs [[Page 21834]] of Grand Gulf'' would best be met by a

plant specific submittal. The staff agreed to review the licensee's

proposal in the context of the ongoing rulemaking activities. In SECY

94-036, dated February 17, 1994, the staff informed the Commission that

it would review the Grand Gulf proposal because of its potential

usefulness in the rulemaking process due to its scope and the technical

information it provides. Testing methods were not included in the scope

of the licensee's proposal. The licensee proposed changes to the

frequency of testing only. The staff has reviewed the licensee's

proposed exemption. The staff's safety evaluation is enclosed.

III

The licensee proposed changes to the frequency of performing Type

A, B, and C tests including changes to the frequency of leakage rate

testing of air locks. The test frequencies will be determined

individually for each component based on previous performance. The

licensee presented plant specific data and plant specific risk analyses

to support the proposed changes. In addition to information supplied by

the licensee, the staff, in reviewing this exemption request, utilized

technical information available from the on-going Appendix J

rulemaking, including NUREG-1493 ``Performance-Based Containment Leak-

Test Program'', dated December 1994. This rulemaking will also revise

the frequency of leakage rate testing so that the intervals between

tests is a function of individual component performance.

Because an Appendix J rulemaking is in progress, this exemption

shall be valid until startup following Refueling Outage 9.

IV

A Type A test assures that the overall or integrated leakage rate

from the whole containment is below the acceptance criterion specified

in Appendix J. This exemption does not change this value. Appendix J

presently specifies the test frequency for a Type A test as a set of

three tests, at approximately equal intervals during each 10-year

service period. The licensee proposes to change the test frequency to

one Type A test in 10 years. Both an analysis of the test results from

operating reactors over an extended period (NUREG-1493) and a risk

analysis (EPRI TR-104285, ``Risk Impact Assessment of Revised

Containment Leak Rate Testing Intervals'') support extending the Type A

test interval to once in 10 years.

The staff proposed that the exemption include a precondition before

extending the Type A test. Two consecutive Type A tests must be

successful before the interval is extended. This is included in the

exemption. By letter dated April 18, 1995, the licensee agreed to this

change. The following exemption is granted until startup from Refueling

Outage (RFO) 9, currently scheduled for Spring 1998.

Exemption From Section III.D.1(a)

Type A tests shall be performed on a 10-year interval provided that

the two previous consecutive Type A tests, performed on the test

interval specified in Appendix J (three tests, at approximately equal

intervals in a 10-year period), have been successful.

If a Type A test is failed, and the failure is not due to a Type B

or C component, acceptable performance must be reestablished by

performing a Type A test within 48 months of the unsuccessful Type A

test. Following a successful Type A test, the surveillance frequency

may be returned to once per 10 years.

In addition, the licensee must perform general inspections of the

accessible interior and exterior surfaces of the containment

structures, as specified in Section V.A of Appendix J, at the test

interval specified in Appendix J for Type A tests, even when no Type A

test is required during that outage. By letter dated April 18, 1995,

the licensee agreed to this change.

There is no relationship between Type A testing and the inservice

inspection (ISI) service period. This exemption will continue in effect

until startup from RFO 9.

V

The licensee proposed an exemption from Sections III.D.2(a) and

III.D.3 of Appendix J to permit Type B and C testing to be done based

on previous performance of a component. The licensee presented data and

analyses to show that the risk from using a performance-based approach

to Type B and C testing is negligible. This is in agreement with the

conclusions of NUREG-1493.

The licensee proposed that the test interval be determined as

follows: (1) One successful test or a failure would require maintaining

the present test interval of 2 years. (2) Two successful consecutive

tests would permit extending the test interval to five years. (3) Three

successful consecutive tests would result in increasing the test

interval to 10 years. The staff does not agree with a 10-year interval.

It is the staff's judgment that the licensee has not justified the 10-

year interval to the same degree of confidence as the 5-year interval.

By letter dated April 18, 1995, the licensee agreed to this change.

In addition, there are certain valves which the staff considers to

be so safety significant that the test interval for these valves should

not be extended without prior staff review and approval. The staff has

specified these valves in the exemption. By letter dated April 18,

1995, the licensee agreed to this change.

Exemption From Sections III.D.2(a) and III.D.3 of Appendix J

After two successful consecutive tests, performed at the present

Appendix J test interval of no more than 2 years, a Type B or C

component may be tested once every 5 years. If this test or a

subsequent test is a failure, the test interval for this component

shall revert to a 2-year interval until the component passes two

consecutive tests. The 5-year interval may then be resumed. By letter

dated April 18, 1995, the licensee agreed to this change.

Main steam isolation valves, feedwater valves and containment

system supply and exhaust isolation valves shall remain on a 2-year

test interval. Any change will require prior review and approval by the

NRC. This exemption will continue in effect until startup from RFO 9.

VI

The licensee proposed to increase the test intervals for air locks

based on the good performance of the air locks at Grand Gulf. The

licensee's August 13, 1993, submittal provides a summary of test data

which shows excellent performance in both air lock and air lock door

seal testing.

The staff proposed an addition to the requested exemption to

account for the contingency that the performance may not be maintained

at this high level. If an air lock fails a test, the extended interval

would revert to the Appendix J test intervals until two consecutive

successful's tests demonstrate that the problem has been resolved. By

letter dated April 18, 1995, the licensee agreed to this change.

Exemption From Section III.D.2(b)(i) and (b)(iii)

Air locks may be leakage rate tested at intervals of no more than 2

years. If an air lock fails a leakage rate test, the air lock shall

then be required to pass two consecutive leakage rate tests at a test

interval of 6 months prior to returning to the 2-year test interval.

During a period of frequent opening of air lock doors, the air locks

shall be tested at least every 30 days. If an air [[Page 21835]] lock

fails a leakage rate test during a period of frequent opening, the air

lock shall be required to pass two consecutive leakage rate tests at a

test interval of 72 hours prior to returning to the 30-day interval.

Since the Grand Gulf air lock doors have testable seals, testing the

seals fulfills the 30-day test requirement. This exemption will

continue in effect until startup from RFO 9.

VII

The staff's safety evaluation, which is enclosed and summarized

above, concludes that the licensee's proposed extension of Appendix J

test intervals is acceptable. This exemption will remain valid until

startup following Refueling Outage 9. This approval is based on the

assumption that all other aspects of Appendix J testing not explicitly

addressed will be conducted in accordance with Appendix J.

Section 50.12 of Title 10 of the Code of Federal Regulations,

``Specific Exemptions'', delineates the conditions which must be

satisfied in order for the Commission to grant an exemption from the

regulations of 10 CFR Part 50. The proposed exemption must not violate

applicable law, it must not ``present an undue risk to the public

health and safety'', and must be ``consistent with the common defense

and security''. The licensee states that it believes these conditions

are satisfied. The staff concurs.

In addition, 10 CFR 50.12 states that the Commission will not

consider granting an exemption unless special circumstances are

present. The licensee, in the August 13, 1993, submittal presented its

argument as to why this exemption request meets several of the special

circumstances specified in 10 CFR 50.12. It is the staff's opinion that

the licensee's proposal satisfies special circumstance 50.12(a)(2)(iv).

Special circumstance (iv) states that: The exemption would result in

benefit to the public health and safety that compensates for any

decrease in safety that may result from the grant of the exemption.

It is the staff's judgment that there is a significant public

benefit to be derived from granting the licensee's exemption request to

10 CFR Part 50, Appendix J. The licensee's proposal was detailed and

well thought-out and thoroughly considered the effect on safety of the

proposed changes. Reviewing this exemption request was beneficial to

the staff's Appendix J rulemaking effort. Granting the exemption will

assist the staff in assessing the process of implementing a

performance-based containment leakage rate testing rule which, inturn,

is of a clear benefit to the public. The staff considers any decrease

in safety that may result from granting the exemption to be very small.

This was confirmed by the risk studies discussed in Section 3 of the

safety evaluation on this exemption request.

Accordingly, the Commission has determined, pursuant to 10 CFR

50.12(a), that this exemption is authorized by law and will not present

an undue risk to the public health and safety, and is consistent with

the common defense and security. In addition, the Commission has found

special circumstances in that granting of this exemption will result in

a benefit to public health and safety that compensates for any decrease

in safety that may result from the grant of the exemption. Therefore,

the Commission hereby grants the exemption from 10 CFR Part 50,

Appendix J, Sections III.D.1(a), III.D.2(a) and III.D.3 and Section

III.D.(b)(i) and III.D.2(b)(iii). The specific exemptions are stated as

in Sections IV, V, and VI above.

Pursuant to 10 CFR 51.32, the Commission has determined that the

granting of this exemption will have no significant impact on the

quality of the human environment (60 FR 19791). The exemption is

effective upon issuance.

Dated at Rockville, Maryland, this 26th day of April 1995.

For the Nuclear Regulatory Commission.

Elinor G. Adensam

Acting Director, Division of Reactor Projects-III/IV, Office of Nuclear

Reactor Regulation.

[FR Doc. 95-10887 Filed 5-2-95; 8:45 am]

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