ML20082D179
| ML20082D179 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 03/30/1995 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20082D176 | List: |
| References | |
| NUDOCS 9504070330 | |
| Download: ML20082D179 (14) | |
Text
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h UNITED STATES ye j-j NUCLEAR REGULATORY COMMISSION
's WASHIN3 ton, D.C. 2066H001
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 96 TO FACILITY OPERATING LICENSE NO. NPF-30' UNION ELECTRIC COMPANY
.1 CALLAWAY PLANT. UNIT 1
- )
E0CKET NO. 50-483 M:
1.0 INTRODUCTION
s,
By letter dated August 4, 1994, as supplemented on March 14, 1995, and M' N March 28, 1995, Union Electric Company (the licensee) requested an amendment to Operating License NPF-30, which would replace Technical Specification (TS) 3/4.6.2.2, Spray Additive System, with a new TS 3/4.6.2.2 entitled Recirculation Fluid pH Control (RFPC) system. The associated TS Bases section and the Refueling Water Storage Tank (RWST)
System Bases would also be revised.
The request eliminates the need for 4,
the sodium hydroxide additive in the containment spray system and instead
- _ J I' uses trisodium phosphate for controlling sump pH in the Callaway Plant.
The March 14, 1995, and March 28, 1995, submittals provided supplemental M
information which did not affect the initial proposed no significant hazards consideration determination.
m
2.0 BACKGROUND
In the original design, sodium hydroxide additive was used to control pH of the containment spray solution in order to enhance removal of elemental 1
iodine from the post-accident containment atmosphere and prevent stress y
corrosion cracking of austenitic steel components. The pH was maintained at 8.5 to 11. At the time the plant was designed it was thought that di these high pH values were required to remove elemental iodine. As more information was gained on iodine removal, it was found that in an iodine free solution pH could be maintained at much lower values and still be effective in removing elemental iodine.
In addition, it was found that
.4s some of the iodine is in a cesium iodide form and could dissolve in water regardless of its pH. There was no need, therefore, to control pH of the ~
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spray water as long as it was free of dissolved iodine. However, when iodine containing water is used, as for example, during the recirculation 9~
phase spraying, pH has to be maintained above 7, otherwise reevolution of dissolved iodine will occur. A pH higher than 7 has to also be maintained 3
to prevent chloride induced stress corrosion cracking of austenitic steel l
components exposed to spray water and minimize evolution of hydrogen from the corrosion of zine on galvanized surfaces and in zine based paints.
These requirements are reflected in Sections 6.1.1 and 6.5.2 of the Standard Review Plan (SRP).
In the submittal, the licensee proposes to use borated water with the lowest pH of 4 and control sump water pH q
9504070330 950330 PDR ADOCK 05000483 P
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- t between 7.1 and 9 with trisodium phosphate from the baskets placed in the
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containment sump. The licensee will incorporate the proposed changes in s
amended Technical Specification 3/4.6.2.2 and in appropriate se::tions of the plant's Final Safety Analysis Report (FSAR).
3.,
3.0 EVALUATION f;
3.]
Iodine Removal from Containment Atmosphere
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During the injection phase, the.11censee proposes to operate the containment sprays with borated water without sodium hydroxide additive' The pH of this water could be as low as 4.
Using the information currently available on iodine removal and the guidance provided in Section N'
6.5.2 of the SRP, the licensee has demonstrated that this low value of pH 2;
would not affect removal rates of elemental and particulate iodine from M-the post-accident containment atmosphere. These rates are determined by 9
the first-order removal coefficients which are independent of pH and are not affected, therefore, by elimination of the pH controlling additive.
c3; The same applies to the removal coefficient for particulate iodine which W
is controlled by the hydrodynamic characteristics of the sprays.
j During the spray recirculation phase, water will come from the sump and J
will contain dissolved iodine removed from the containment atmosphere i
during the injection phase.
In a radiation environment, this iodine could be revolatilized and released to the containment atmosphere if the Ph of the solution is acidic.
In order to prevent this from happening, the pH of the sump solution should be kept above 7.
The licensee proposes to control Ph by having between 9000 and 13440 pounds of hydrated trisodium j
phosphate (TSP) in the two baskets located in the sump. This TSP will 9
dissolve as it comes in contact with the spray water and will buffer pH between 7.1 and 9.
Based on Reference 1, the licensee assumed a y
dissolutior, rate of 0.7 lbm/ft2-min.
Since the new sump pH differs from 7
the pH currently specified, there will be some differer.
in the amount of 3
iodine removed from the containment atmosphere and in the resulting radiation doses. These doses were, therefore, revised by the licensee.
3 The iodine removal coefficients (A) remained unchanged because removal e4 rates for both elemental and particulate iodine are independent of pH and are not affected by the change of the pH control agent. The coefficients s
used by the licensee were found to be conservative, relative to the values
_M determined by the methodology described in Section 6.5.2 of the SRP.
+);.
The change in the total amount of iodine removed from the containment [
atmosphere is due to a significant effect of pH on the amount of iodine <
q' dissolved in spray solution, before it becomes saturated. Saturation '
- concentration of iodine is determined by equilibrium between its
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concentrations in the containment atmosphere and the sump water. This equilibrium is determined by a partition coefficient (H) for iodine 4
between air and water which decreases with pH.
It is expected, therefore,
~
that the decontamination factor (DF), which is a measure of the amount of iodine removed from the containment atmosphere, will be decreased for lower values of pH.
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_3-Currently, sodium hydroxide will maintain sump pH at a value. between 8.5 l
and 11.- Using trisodium phosphate this value will change to between 7.1 to 9.
This represents a marked difference and should be reflected in.the decontamination factors.used in dose-calculations. - The current value of -
DF used by the licensee for calculating offsite and control. room radiation doses is DF-100 for both elemental and particulate iodine. 'For equipment i
qualification,.the licensee used decontamination factors of DF=200 and DF-10000 for elemental and particulate iodine, respectively.
In the i
submittal, a new value of DF=28.7 for elemental iodine was provided. This
.value is based on the partition coefficient of H-1100 which was calculated for lower pH using information from Reference 2.
For particulate iodine,.
the licensee used a very conservative value of DF=50.
Another reason for maintaining an alkaline solution in the containment sump is to minimize corrosion of metallic surfaces.
Chloride induced stress corrosion cracking of austenitic stainless steel components is
=
considerably reduced if pH of the solution to which the components are exposed is maintained above 7.
Short exposure to low pH water during the a.
injection phase will not cause significant stress corrosion cracking, but I
more extended exposure during the recirculation phase or in the sump may result in significant damage.
Section 6.1.1 of the SRP (Branch Technical Position MTEB 6-1) recommends naintaining pH in a 7 to 9.5 range.
Control of the sump pH is also required to minimize hydrogen generation by J.
corrosion of aluminum and zinc on galvanized surfaces and in the organic coatings on containment surfaces.
The licensee has demonstrated that less corrosion of aluminum will occur and less hydrogen will be generated at an.
ci-equilibrium sump pH of 7.1 than predicted by the current analysis which assumed a constant recirculation sump pH of 9.5.
The generation of hydrogen due to the corrosion of zine below 170 *F will increase with the lower pH values. However, this effect would be cffset by a considerably smaller' generation of hydrogen from the corroding aluminum surfaces.
i Based on the above evaluation, the staff concludes that the modifications to the Callaway containment spray system, proposed by the licensee, meet the requirements of General Design Criterion (GDC) 41 for providing a satisfactory means of post-accident containment atmosphere cleanup. The staff further concludes that the proposed revised TSs for surveillance of trisodium phosphate in the containment sump meet the requirements of GDC-42 for inspection of containment atmosphere cleanup systems.
Therefore, the staff review concludes that, relative to iodine removal,.
the licensee's proposed deletion of the sodium hydroxide containment spray additive system and addition of trisodium phosphate containment sump f[t control system is acceptable.
3.2 Eauipment Oualification l
The staff also reviewed the replacement of the Containment Spray Additive System with the RFPC system with respect to environmental qualification of electric equipment.
The licensee stated that post-accident airborne gamma doses increase slightly with the new system, but the margins available i
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between the affected equipment's qualifiej test doses and the currently required doses are sufficient to accommodate these-increases.
The proposed change was evaluated for the effects of radiation dose on environmental qualification of electric equipment.
Radiation and chemical Aj ;
spray are part of environmental qualification. The changes in the containment spray system could affect post-accident radiation levels and j
pH of the spray fluid.
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The licensee calculated accident radiation doses with the RFPC system in 7}
place. Airborne gamma doses inside containment were estimated to increase
-l by 3%. Doses in penetration rooms were estimated to increase up to 8%.
<l The licensee evaluated affected equipment and found that the margins d
available between the qualified test doses and the currently required doses are sufficient to actommodate these increases. The components that M,,
had the least margin for rtdiation dose were motor control centers located 7:
in electrical penetration rooms.
There is margin available for the motor ~
control centers, even with the new doses.
The staff reviewed the a
radiation doses and agrees that there is adequate margin for environmental 4_ !
qualification.
/
The current design of the Containment Spray Additive System raises pH of M'
containment spray to high levels (9.3 to 11.0) during the injection phase.
p; With the new RFPC system, the initial pH of the spray fluid-is between 4.0 4
i and 7.0 during the injection phase of containment spray operation. The 4 i passive RFPC system'will maintain the containment recirculation sump water fi equilibrium pH above 7.0.
The equilibrium spray pH during the.
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recirculation phase will be a minimum of 7.1 and a maximum of 9.0 with the 3,
new pH control system. Since the resulting pH level will be closer to
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4 neutral, post-LOCA corrosion of containment components will not be increased.
The staff reviewed the. change in' containment spray pH.and w,
agrees that environmental qualification will not be affected.
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+
The proposed change of the Containment Spray System affects radiation doses and chemical spray composition for environmental qualification of l
electric equipment.
The new radiation doses do not exceed the qualified i
doses for electric equipment. The change in pH of the spray will not
,I affect environmental qualification of equipment. The staff has determined that deletion of the Containment Spray Additive System and replacement with the passive RFPC system will not affect the qualification of electric M4 equipment.
Therefore, the staff concludes that the licensee's proposal is-acceptable relative to equipment qualification.
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1 3.3' Offsite and Control Room Dose Calculations
,v; The licensee assessed the impact of the elimination of the spray additive system on iodine removal during a LOCA. The licensee determined that iodine removal during the inje tion phase can still be effectively performed by boric acid sprays without using NaOH as an additive and that e
long-term iodine retention in the sumps is assured as long as the s.;
equilibrium sump pH level is maintained above 7.0.
In the licensee's t
prior offsite' and control room operator dose' calculations, spray removal
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rate constants of 10/hr and 0.45/hr were utilized for the elemental and
-l particulate forms of iodine, respectively.. The licensee assumed in their -
prior calculations that the spray removal constants were effective until' a j i
- DF of 100 was.obtained for both chemical forms of iodine.
y For this amendment request, the licensee assesse'd the impact of the '
a removal of the spray additive system on the elemental and particulate spray removal constants and on the DFs for the two forms of iodine. 'In' d, i the licensee's analysis to support the removal of the spray. additive
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system, they determined that a larger elemental spray removal constant a.c '
could be assigned, but chose to continue with the value of 10/hr in their
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calculations.
In their revised analysis, the licensee determined that
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effectiveness of the elemental iodine spray removal constant would only continue until a DF of 28.7 was obtained.
For the particulate form of ~
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removal was only considered to continue until a DF of 50 was obtained.
iodine, the licensee assumed no change in the' spray removal constant, but l
l In the licensee's prior assessment of the control room operator's thyroid dose evaluation, they assumed a charcoal adsorber efficiency of 90% for' i
the elemental and organic forms of iodine.
In the licensee's current assessment to support this amendment request, an adsorber efficiency of d "!
95% was assumed.
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The licensee calculated the thyroid dose resulting from a ' postulated LOCA.'
Doses were evaluated for the control room operators and individuals i
located at the exclusion area boundary (EAB) and low population zone Ci (LPZ). At Callaway, the potential sources' of releases in the event. of a LOCA are containment leakage, emergency core cooling system (ECCS).
-recirculation loop leakage, and leakage from the recirculation of containment sump liquid past ECCS isolation valves to the RWST.
.j Containment sources'were assumed to be reduced by the sprays.
Leakage was I
assumed to occur to the environment unfiltered during the duration of the-
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accident, and was assumed to be ground level.
j ECCS recirculation loop leakage was assumed to be released to the I
auxiliary building with no credit for holdup,'but with credit for filtration by the emergency exhaust system high efficiency particulate air (HEPA) filter and charcoal adsorber system. The release would be
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exhausted through the unit vent, which is located atop containment. The q
licensee assumed that the X/Q value for the unit vent was different from vi the y/Q values utilized for the containment releases. The licensee q-
<M, considered these two release locations to be different,'because they considered the unit vent to be an elevated release point.
,q In the licensee's analysis of the leakage back to the RWST, they assumed the volume of the release from the RWST was at the same' rate at which the liquid volume was discharged into the tank. Thus, the licensee did not assume a changing air volume in the tank based upon 3 gallons of-liquid i
entering the tank each minute, and a certain portion of the activity in the liquid becoming airborne in the RWST air volume.
Instead, the j
licensee assumed that for the leakage to the RWST, 10% of the iodine i
ve
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- 1,
',. activity became airborne, was mixed in the RWST air volume and then vented directly to the environment.
The release from the RWST vent was-assumed to occur at ground-level. Therefore, the containment y/Q values were assumed to be applicable for the RWST releas:.
The staff has assessed the radiological impact resulting from the elimination of the spray additive system for iodine. The staff performed an independent assessment of the control room operator thyroid dose and the EAB and LPZ thyroid doses resulting from a LOCA. The assumptions utilized by the staff are presented in Table 1.
The thyroid doses calculated by the staff are presented in Table 2.
As shown in Table 2,. -
the thyroid doses at the EAB and LPZ were found acceptable, but the control room operator dose exceeded the limits of GDC-19.
As noted in Table 1, the staff assumed adsorber efficiencies of 90% for 1
the charcoal in both the control room pressurization and filtration systems.
This was consistent with the value assumed by the licensee in y
previous analyses. The staff assessed crediting the adsorber with an d
efficiency of 95%, but could not justify such an efficiency.
The basis for not providing such credit is discussed below. Had the staff credited the control room systems' adsorbers with an efficiency of 95%, the control room operator thyroid doses would have met GDC-19.
The staff's review resulted in the determination that there were certain positions and assumptions made by the licensee which the staff found unacceptable. One such example was the licensee's assumption that the unit vent is an elevated release. As noted in Regulatory Guide 1.145, a stack release is one in which the release point is at a level that is at
. east 2.5 times higher than the height of adjacent solid structures. That is not the case with the unit vent.
Its discharge point is only a few feet above the dome of the containment.
Therefore, since ECCS leakage is discharged from the unit vent, a ground-level X/Q should be assumed.
Therefore, the staff can not concur with the licensee's assumption on the X/Q for the unit vent.
Another area where the staff could not accept one of the licensee's assumptions involved the increase in control room pressurization and filtration systems' efficiency for the charcoal adsorber.
The staff concluded that increasing the adsorber efficiency from 90% to 95% was unwarranted based upon the following:
- 1. The existir.g testing protocol and test conditions for the laboratory test of the charcoal are inappropriate and overestimate q'
the actual capability of the charcoal.
2.
The residence time associated with the control room filtration system is less than 0.25 seconds at certain allowed TS flow rates.
The existing TSs have the laboratory test for the control room charcoal utilizing the RDT 16-lT-1973 military standard as the test protocol with the test conducted at a temperature of 80 C and a relative humidity of 70%.
The staff has concluded that the performance of the laboratory tests 1
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at those test conditions and with that test protocol would not ensure that the charcoal would perform at an efficiency of 95%.
In NRC Information Notice (IN) 86-76, the staff identified problems with licensees performing laboratory tests of charcoal at test conditions which are not representative of the most limiting condition that might be expected in the event of an accident.
IN 87-32 specifically identified problems associated with the testing protocol.
IN 87-32 concluded that utilization of the protocol scheduled to be published in the next revision of American Society for Testing and Materials (ASTM) D3803 (this became the 1989 revision), was the most appropriate test protocol. Therefore, since the licensee does not have laboratory test conditions appropriate for the control room and does not have an appropriate test protocol, the staff concluded that it was inappropriate to credit the control room charcoal adsorbers with an adsorber efficiency of 95% with the existing TS in place.
In addition, when the staff performed a review of the existing TSs as to the appropriateness of increasing the credit for the efficiency of the control room charcoal adsorbers from 90% tc 95%, the staff determined that there existed a question as to the adequacy of the charcoal's residence time, i.e., 0.25 seconds.
In the current TSs, the allowable flow for the control room filtration unit is 2000 cfm +700/-200 and is 500 cfm +500/-50 for the control room pressurization system. The licensee indicated that the design flow rate for the control room filtration unit was 3000 cfm, while that for the pressurization system was 1000 cfm. The staff evaluated this information and information presented in the Callaway FSAR.
Based upon the control room filtration system, fan capacity and the quantity of charcoal in the filtration systems relative to that of the pressurization system, the staff concluded that the design basis flow for the control room filtration unit is 2000 cfm. With that as a design flow rate, the staff concluded that the licensee would be unable to meet the 0.25 residence time commitrrant in the FSAR at a TS flow rate greater than 2200 cfm.
This was a secon reason for not increasing the adsorber efficiency from 90% to 95%.
The staff discussed interim compensatory measures with the licensee.
In a letter dated March 14, 1995, the licensee committed to change the laboratory tests of the control room charcoal performed at a temperature of 30 *C and at a relative humidity of 70% for the control room filtration
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charcoal and for the control room pressurization charcoal. The ASTM l
D3803-1989 test protocol would be utilized for such tests.
In a l
subsequent letter dated March 28, 1995, the licensee modified the allowable flow rate to ensure that the control room filtration system has a residence time of at least 0.25 seconds. Since these changes cannot be incorporated into TS prior to the issuance of this amendment, the licensee has committed to interim compensatory measures pending the staff's i
processing the amendment request on the laboratory testing conditions and protocol and the control room filtration system flow rate. With these actions, the staff credits a removal efficiency of 95% for the control room systems' charcoal, and the control room operator's thyroid dose will
_^
meet the limit of GDC-19.
Therefore, the staff concludes that the licensee's proposal is acceptable relative to the offsite and control room dose calculations, based upon the licensee's interim compensatory measures 1
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to administratively implement the following until the additional test protocol and control room filtration flow rate TS change is processed:
1.
Perform the laboratory tests of the control room charcoal at a temperature of 30 *C and at a relative humidity of 70%.
2.
Perform the laboratory test of the control room charcoal in accordance with the protocol of ASTM D3803-1989.
3.
Modify the allowable flow rate for the control room filtration system so that the maximum flowrate allowed will maintain a residence time of 0.25 seconds.
t Other differences between the staff and the licensee's assumptions can be determined by comparing the information contained in Callaway FSAR Chapter 1
15, and their submittals in support of this amendment request with the
~
information contained in Table 1.
The most significant differences were noted above.
The staff has assessed the capability of the Callaway Plant to meet the thyroid dose limits of 10 CFR 100 and GDC-19 with the elimination of the spray additive system for iodine. As a result of this assessment and the licer:see's commitment to the above-mentioned interim compensatory measures and subsequent TS changes, the staff has concluded that the thyroid doses would not exceed the dose guidelines presently contained in 10 CFR Part 100 or GDC-19 of 10. CFR Part 50, Appendix A for either offsite locations or control room operators.
Therefore, the staff finds the proposed TS amendment request acceptable.
4.0 STATE CONSULTATION
.a In accordance with the Commission's regulations, the Missouri State official was notified of the proposed issuance of the amendment. ~The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATIQB 3
The amendment changes a requirement with res)ect to the installation or use of a facility component located within tie restricted area as defined in 10 CFR Part 20 and changes surveillance requirements.
The staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effiuents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that this amendment involves no significant hazards consideration and there has been no public comment on such finding (59 FR 49440). Accordingly, this amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.
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6.0 CONCLUSION
- The staff has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance.with the Commission's regulations, and (3) the issuance of this amendment will not be inimical te the commo~n defense and security or to the health and safety of the public.
7.0 REFERENCES
(1) WCAP-12477, " Spray Additive Elimination Analysis for the South Texas Project," December 1989.
(2) NUREG/CR-4697, " Chemistry and Transport of Iodine in Containment,"
October 1986.
Principal Contributors: K. Parczewski
^
A. Dummer J. Hayes R. Wharton Date: March 30,1995 1'
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Table 1 Assumptions for LOCA Analysis g'
Core Thermal Power (MWt) 3636 Activity Released to the Reactor a
i Buildino Airborne (fraction of core)
Iodine 0.5 X*4 Iodine Plateout Factor 0.5 R$
Iodine Species (fraction)
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Elemental 0.91 a
Particulate 0.05 Organic 0.04 Activity Released to Sump
- .j '
(fraction)
Iodine 0.5
- ffy Containment Free Volume (ft )
2.5E6 9
3 Leakage Rate (%/ day) 4<
0-24 hours 0.2
.a
> 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 0.1 3
Sump Liquid Volume (ft )
4.6E5 Containment Coolina Unit Flow Rate (cfm) 6.7E4' ej Containment Sorav System
^M Actuation Time (sec) 60 Spray Duration Elemental (hrs) 0.5 Particulate (hrs)
Duration of accident ATTACHMENT
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,$A Table 1 continued Spray: Removal Constants -(/hr) y Elemental-10
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Particulate O.45 until'DF = 50 s
-0.045 after DF = 50 Spray Removal DF a
Elemental-Particulate
~28.7 no limit
-g Fraction of Containment 0.15 Unsprayed a
Recirculation Looo Leakage Rate (gpm) 2 Minimum Time till Recirculation 0.42
'(hr)
Fraction Iodine Airborne 0.1 3
Passive Component Failure Leak 0
, ~,J.
-Rate (gpm) for 30 minutes 924
^Y hours post-LOCA I.ih ESF Filter Efficiency (%)
90 7
' Sump Volume (gal) 460,000 3}
o RWST Leakaae i
Leakage Rate (gpm) 3
. s. LIL,
Time Leak Begins (hr) 0.42 j s,.,j $~
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Y Fraction Iodine Airborne 0.1 ESF Filter Efficiency (%)
0 3,y, q
kWST Volume (gal) 400,000
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Table 1 continued
. Control Room __
t w1 Free Volume (ft )
1.50E5 I{
3 Pressurization Air Filtration 450-1000-Rate (cfm)
Unfiltered Air Infiltration Rate 300 (cfm)
N Control Room Filtration Rate 450-675 (cfm) g Filtered Recirculation Flow 1350-2026 (cfm)
'^3 Recirculation Efficiency (%) for 90 all forms of Iodine
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Occupancy Factors
.;g 0-1 day 1.0 1-4 days 0.6
.g :
,4-30 days 0.4
'A
.. Gy" -
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. Atmosoberic Dispersion Factors Isec/m')
f EAB 1.5E-4 v4 '
LPZ a
0-8 hours 2.lE-5 j,
8-24 hours 1.4E-5 i
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l-4 days 5.9E-6 4-30 days 1.7E-6
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4 Control Room
',.. j',, g, p,\\,
d; 0-8 hours 7.6E-4 D
l 8-24 hours 5.6E-4 1-4 days 2.5E-4
?;* t s 4-30 days 1.2E-4 s.
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Table 1 continued
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~ Breathina Rates (m /sec)
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Offsite 0-8 hours 3.47E-4 J:
8-24 hours 1.75E-4 y'
1-30 days
-2.32E-4.
Control Room 3.47E 7i f9Ej l i
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f Table 2 Thyroid Doses from Postulated LOCA (Rem)
Source EAR MZ Control Room Containment 69 73 48 " i Leakage' ECCS Leakage 15 37 5.
Flow to RWST J
ZQ Zi Total 84 130 77 Regulatory 300 300 30 Limit i
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