ML20149L026
| ML20149L026 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 02/18/1988 |
| From: | Clark R Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20149K984 | List: |
| References | |
| GL-85-19, OLA, NUDOCS 8802240077 | |
| Download: ML20149L026 (10) | |
Text
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ATTACHMENT A UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the matter of
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Philadelphia Electric Company 1
Docket No. 50-352-OLA
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(TS Iodine)
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(Limerick Generating Station, 1
I! nit 1)
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Affidevit o# Richard J. Clark in Succort of 'iotion For Sumarv Disnosition Mr. Clark being dulv sworn according to law states as follows-1.
Mu name is Richard J. Clark, Jr.
I am emnloyed in the Office of Nuclear D.eactor Reculation (NRP1 of the Nuclear Regulatory Comission.
I am presentiv the Licensino Project Manager for Philadelphia Electric Company's Limerick Generating Station Units 1 & 2.
I hold a Bachelor of Enaineering degree from Penssoleer Dolytechnic Institute, with post graduate studies in Chemical Enoineering and Nuclear Engineering at Renssolaer Polytechnic Institute and the University of South Carolina.
I have over 30 years experience in the design, operation and regulation of nuclear power olants.
2.
The responsibilities of my present position include reviewing chances to the Technical Specificatinns (TSs) prooosed by the licensee, to prepare Notices of Significant Hazards Considerations, to prepare a safety evaluation on the proposed chance and if the proposed chance is acceptable, to prepare tha license amendment for issuance by the Project Director.
Assistance in nrecarinq the safety evaluation is obtained, as appropriate, from technical specialists in NRC's Office of Nucleer Peactor Regulation.
8802240077 880218 PDR ADOCK 05000352 Q
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The purpose of this affidevit is to respond to the consolidated contention admitted by the Atomic Safety and Licensing Board in its October 9, 1987 Memorandum and Order and to. support the Licensee's Motion of November 23, 1987 for Surrnary Disposition.
The consolidated contention formulated by the Board is as follows:
Consolidated Contention.
The proposed amendment to the Licensee's technical specifications would downgrade reporting requirements for iodine spikes which would have an adverse effect en public health and safety.
Rases. The change in the reporting requirements would eliminate or decraase Special Reports and Licensee Event Reports on iodine spiking, and thus would decrease tha regulatory control exercised by the NRC, would permit a situation where Licensee could release radioactive iodine in excess of the one-time release limits, and, in not reouiring the reportina of such releases, avcept on en annual basis, would endanger the health and safety of the uninformed public.
4.
In item 8 of the affidavit attached to the licensee's motion, Fessrs.
Doeriro and Wiley concluded that the proposed amendment wnuld not change reporting requirements related to iodine spikes such that there would be an adversa affect on public health and safety. As will be amplified subsequentiv, I have independantly evaluated the propoted amendment in consultetion with other NRC staff members and reach the same conclusion.
5.
The croposed amendment wnuld not change the existing Technical Specification (TS) limits on casanus and liquid effluents.
No matter what the concantration of fodine or any other nuclide mav be in the primary coolant, the licensae is linited both by Comission regulations (10 CFR Part ?01 and TS limits on the amount of activity that can be I
l
' 4 released offsite through all potentiel pathways.
The subject license amendment application does not renuest any relief from these TS require-ments or regulations related to release limits from Limerick.
This amendment proposed no changes in the TS requirements for surveillance, mori+oring, sampling or reporting of radioactive releases.
6.
In item 9 of the affidavit to the licensee's motion, Messrs Doering and Miley point out that the nroposed amendment was submitted in resoonse to a r?ouest by the NCC staff in generic letter 85-19. The discussion in items 10,11, and 12 of the affidavit by the licensee of what the proposed amendment would and would not change is factually correct.
As stated in eeneric letter 85-19 and in item 12 of the licensee's affidavit, there have been significant improvements in the design of BWR fuel over the past decade oreceeding the generic letter that greatly reduce the potential for stress corrosion cracking of the cladding and thus the release of iodine into the coolant.
Imoroved fuel management such as restrictions on power changes and preconditioning significantly reduce stresses that could open a crack in the cladding.
7.
As stated in item 14 of the affidavit supporting the licensee's motion, the TSS require that iodine levels in the primary coolant he checked daily.
This is routinely verified by the NRC inspectors. This requirement would not be changed by the oroposed amendment.
With the assistance of a national laboratory, NRC regional inspectors also check the accuracy of the radiochemical analyses performed by the licensee.
The average iodine concentrations in the orimary coolant at Limerick 1 are a fraction of one-percent of the allowable limit in the TS. With daily analyses and in-line instrumentation, iodine levels in the crimary coolant are closely monitored, j
I II.
t 8.
One of the bercr. #cr the contentier ir that the amendment would eliminate or decrease Licensee Event Raports (LERs) on iodine spiking and thus would decrease the regulatory control exercised by the NRC. This is incorrect.
The requirements governing when a licensee must submit a LER are specified in Commission reculaticr 10 CFR 50.73.
The proposed amendmerit does not recuest a') exemption from this regulation.
The proposed amendment will not eliminate or decrease any LERs. The only raporti'g require m " W rF u uio be char.ced by the cr.endment are the requirements to submit special 30- 6:4 SC day reports if the coolant iodine v.t.ivity exceeds the TS limit of 0.2 microcurie per gram or if it exceeds the limit for 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> in any consecutive 6 month period.
In eeneric letter 85-19, the NRC staff recoamended that these special reports on todire activity be deleted from TSs since they served no useful purpose and were duplicative of other reports - specifically, the rev repcrting requirements of 10 CFR 50.72 and the revised LER p ti g requircrrrtr of 10 CFR 50.73.
If the iodine activity cyceeds 0.?
microcurie per gram for just 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, thy present TSs recuire the plant
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to shutdowr; this requirement would not ba changed bv tho proposed arendeent.
If this were to occur the licensee would have to notify NRC withir. cne hour pursuert te 50.72(b)(1) arc' submit a 30 day LER report pursuant to 50.72(t}(P.
With the current reporting requirements of 10 CFD 50.7; and 10 CFR 50.73, the NRC determined that it would serve no I
useful purpose either to the licensee or to NRC to also require a separate, special report. Moreovar, with the revised regulations, the TS requ'rerert 'o submit a special 30 day report if the coolant iodine activity exceeds 0.2 microcurie per gram for 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> in any consecutive 6 month period is also unnecessary. ?,efore reaching the 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br />, the licensee would have had 10 shutdown /startuos (due to the 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> limit) in a 6 month period, each of which would require reportina of the shutdown in accordrice Wth 10 CFR 50.72 and submittal of a LER.
If a licensee were to attempt to oporate for 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> with repeated shutdowns /startups, a special M d'" trport would not provide any additional information or enhance reculatery control beyond thet provided by the multiple LERs and 50.72 rarn 't which would have been submitted.
Based en ry 15 years as a
, !,[ 1 iff,
s project manager with NPC, I'm confident that both the licensee and NRC would have focused on the fuel degradation long before the special report celled for in the presert TSs would be due.
Items 15,16,17,18, arid 19 of the affidavit supporting the licensee's notion also discuss the other repertirn uc.uirements on fuel failures that would provide early notification te NRC.
In sumary, the amendment would not change the reporting requirements on iodine spiking in any manner that would reduce the timeliness of informatter aveilable to the NRC and to the public.
The change in reporting requirements will ir no way affect the regulatory control exercised by NRC.
9.
One of the bases for the contention is that the proposed change in reporting requirements...."would permit a situation where Licensee could release radioactive iodine in excess <of the one-time release limits".....
As I discussed in item 5 above and the licensee discussed in item 21 of the a?"dN' upporting their motio'n, the amendment would not change any offsite releese limits or any reports related to offsite releases.
Repor'., "Mr. tea to of fsite releases and the release limits are governed by other TS requirerertr and NRC regulatiers which are totally unaffected by the requested charges.
l 10.
Ir. item 23 of the affidavit supporting the licensee's motinn, the licensee discusced the NRC's safety evaluation in NUREG-0991 of a main steam line break.
I want to crphasize - as did the licensee-that this steamline
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break evaluation is not relevant to the contention because the proposed amendment would not change either the surveillance requirenerts or any of tFr. radioactivity valuee Used ir, the analysis.
However, it does ilhstrate the crr rervatisrr. in the limits in the TSs on iodine activity in i
the coolant.
As the licensee has stated, the averace iodine activity in I
the' coolant at Limerick het averaged only 8 X 10" nicrocurie per gram durir;g the first forl cycle.
This is a factor of about 2500 below the TS lir.it of 0.2 microcuria per gram.
With the improved fuel now used in RWRs crA t% iuei roariagenert rostrictions, it is unlikely that significant cracks or defects would develop in the fuel claddinq, such that the iodine u-
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activity would exceed the TS limits.
The basis for limiting iodine activity in the coolant is to limit offsite doses to the public in the event of en accident.
The shutdown requirements of Technical Specifi-cation 3.4.5 are based on the consideration (TS 9ASES Section 3/4.4.5) thet the specific activity level of coolank should be limited to a relatively low level during nlant oneration so that, should a main steam line failure occur outside the containment, the dose rate from activity in the released coolant will not result in doses exceeding a small frav r
of the dose guidelines of 10 CFR Part 100.
During the course of the operatir,g license reviaw, the staff perforned an analysis of the radiolonicci consequences of a main steam line failure outside the containment.
The analysis was perforned following the guidelines and criteria specified in Standard Review Plan (SRPi Section 15.6.A.
For conservat(sm, tha analyiis assumed that the plar.t was operating at full power with an iodine concentration in the coolant at the shutdown limit of 0.2 microcurie per gran.
k'hile iodine spikes i
coincident with a Main Staanline Break are not likely, the analysis assuned that the eq'tilibrium shutdeun limit of 0.2 microcurie per gram was increased by a factor of 500 - to 100 micr'ocurie per gran. Other cerservative assumptions used in the safety analysis included no platenut of iodine from the released coolant, no radioactive decay of lodine 131 in transit and pessinistic meteorological conditions.
Results of the artlysis show that the dores will not exceed a small fraction of tha dose guidelines values of 10 CtR Part 100 consistent with the criteria set forth in the Standard Review Plan.
Thus the present limits on iodine concentration in the Linerick TSs are very conservative.
Even though iodine spikes are not espected, they have been conservatively factored into the analysis of postulated desinn basis accidents.
11.
I have reviewed Mr. Robert Arthony's February 9, 19PP, response to tha licensee's Motion for Sunr.arv Disposition.
Mr. Anthony misinterorets n.y letter to the licensee 0# November 23, 1987, regarding revision 4 to the f
y a
7 Offsite Dose Calculation Manual (00CM).
This letter, which speaks for itself, is sttached hereto as attachment B.
Mr. Anthony's pleading
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expresses other concerns related to plant boundary distances, offsite dose calculations and radioactive nuclide releases outside of the containment.
Clearly, this letter does not relate to the licensee's preposed amendment.
The proposed amendment does not change any NRC requirement that relates to these stated concerns.
12.
I have reviewed AWPP's February 9, 1988, response to the licensee's Motion for Sumary Disposition.
In its response, AWPP questioned the NRC staff's statistical basis for issuing generic letter 85-19.
The NRC publistrr 'uel performance anreal reports, which centain the bases for generic letter 85-19.
These reports, which carry a designation of NL'PfG/CR 3950, are readily avtilable for copyino at the NRC Public Pccunent room, as well as being available for sale from the NRC ard the fational Technical Information Service.
These reports discuss all erne-+t of fuel perfornance--buenup experience, fuel damage, cladding degradation, h cridirg, etc., including iodine spikino. A review of all 3
volunes of NUREr,/CR 30E0 establishes that there has been only one incident c' iridine spiking ir t BPP. lat Big Rock Point) since 1982.
Thus, the PPr 5
baseo its recomendations in generic letter 85-19 on an extnLively researched basis.
/Prr also speculated that boric acid corresion right affect fuel performance.
Urlite PWE's BWRs do not use a soluble poison such as boric actd #6*
S :i. c or.tt 01.
fecause BWR primary coolant does not contain horic acid, there has been no boric acid corrosion problers in BWR primary ccolart ryttur.s.
In my view, neither of AWPP's above statenents relates to the proposed arendre u. Al:PP's statements do rot show that the proposed amendment woulc elirire*o ruerts that are not redundant.
Furtherrrore, the
8 nroposed amendment would not change the limits in the Technical Specification on iodine in the primary coolant or on radioactivity that might possibly be released to the environment.
13.
In sumary, I am satisfied that the proposed amendment would not downarade reporting-requirements on iodine spikes. The bases for the consolidated contention rests on erroneous assumptions that are fundamentally flawed and provide no supoort for the contention.
The forecoinq statements are true and correct to the best of my knowledge and belief.
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Subt.cribed and swnrn to j
hefore me this //// dav of February 1988 k
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,. i ATTACHMENT B p uop o
UNITED STATES 3,
~,j NUCLEAR REGULATORY COMMISSION r,
WASHINGTON, D. C. 20555 November 23, 1987 Docket No. 50-352/353 Mr. Edward G. Bauer, Jr.
Vice President and General Counsel Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101
Dear Mr. Bauer:
SUBJECT:
OFFSITE DOSE CALCULATION MANUAL, REVISION 4 (TAC NO. 64657)
RE:
Limerick Generating Station, Unit Nos. 1 and 2 Our letter of October 3, 1984 approved Revision 2 of your Of' site Dose Calculation Manual (ODCM) as a reference document for Limerick Units 1 and 2.
Since 1984, a number of changes have been made in the Limerick ODCM and reported to us in accordance with the requirements in Section 6.14.2 of the Limerick Technical Specifications (TSs).
The most recent revisions of the ODCM-Revision 4 - were submitted with your letter of August 29, 1986 transmitting the semi-annual Effluent Release Report No. 4 for the period January 1, 1986 through June 30, 1986.
We have reviewed Revision 4 to the ODCM with the technical assistance of our contractor, EG8G Idaho, Incorporated and find that this ODCM generally uses documented and approved methods that are consistent with the methodology and guidelines in NUREG-0133, and is an acceptab1n reference.
A copy of our Safety Evaluation (SE) is enclosed.
Attached to the SE is our contractor's Technical Evaluation Report (TER). A number of typographical errors are identified in the TER, as well as problems relative to liquid flows and gaseous effluent pathways.
A number of small errors have crept into this document with the change in fomat in goireg from the original ODCM to Revision 1, and in succeeding changes incorporated in Revisions 2, 3, and 4.
The chenge; to the Limerick ODCM discussed in the enclosed TER are refinements to a basically sound document.
However, all of the points raised in the TER should be addressed in a revision to the ODCM.
In discussions with your staff, it was agreed that the ODCM would be revised by April 1, 1988.
Secticn 6.14.2 of the Limerick Technical Specification states that Licensee-initiated changes 4
l i
2 to the ODCM shall be submitted in the Semi-annual Radioactive Effluent Release Report.. In this case, where the proposed changes could be characterized as NRC initiated, it was agreed that the revised ODCM would be submitted separately by April 1,1988 for NRC review.
4CC1 k h o k Manager roject Dire torate I-2 Division of Reactor Projects I/II
Enclosures:
Safety Evaluation Technical Evaluation Report ec:
Service List I
I i
l C0CKETED U5NRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'88 FEB 19 P3 :34 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD OFFICE OF Sh.ht. tar V 00CKETING A SLRvicf.
In the Matter of
)
BRANCH
)
Docket No. 50-352-OLA PHILADELPHIA ELECTRIC COMPANY )
(TS lodine)
)
(Limerick Generating Station,
)
( ASLPP No. 87-550-03-LA)
Unit 1)
)
CERTIFICATE OF SERVICE i
I hereby certify that copies of "RESPONSE OF NRC STAFF IN SUPPORT OF LICENSEE'S MOTION FOR SUYMARY DISPOSITION" in the above-captioned proceeding have been served on the following by deposit in the United States mall, first class, or as indicated by an asterisk through deposit in the Nuclear Regulatory Commission's internal mall system, this 18th day of February,1988 Sheldon J. Wolfe, Chairman Mr. Edward G. Bauer, Jr.
Administrative Judge Vice President E. General Counsel Atomic Safety and Licensing Board Panel Philadelphia Electric Company U.S. Nuclear Regulatory Commission 2301 Market Street Washington, D.C.
20555*
Philadelphia, PA 19101 Dr. George A. Ferguson Troy B. Conner, Jr., Esa.
Administrative Judge Mark J. Wetterhahn, Esq.
Atomic Safety and Licensing Board Panel Conner and Wetterhahn U.S. Nuclear Regulatory Commission 1747 Pennsylvania Avenue, N.W.
Washington, D.C.
20555*
Washington, D.C.
20006 Richard F. Cole Mr. Frank R. Romano Administrative Judge Chairman Atomic Safety and Licensing Board Panel Air and Water Pollution Patrol U.S. Nuclear Regulatory Commission 61 Forest Avenue Washingten, D.C.
20555*
Ambler, PA 19002 Robert L. Anthony Gene Kelly i
4 Friends of the Earth of the Senior Resident inspector Delaware Valley U.S. Nuclear Regulatory Commission 103 Vernon Lane, Box 186 P.O. Box 47 Moylan, PA 19065 Sanatoaa, PA 19464 i
~,,
Atomic Safety and Licensing Jay Gutierrez Board Panel Regional Counsel U,S. Nuclear Regulatory Commission USNRC, Region I Washington, D.C.
20555*
475 Allendale Road King of Prussia, PA 19406*
Atomic Safety and Licensing Appeal Board Panet U.S. Nuclear Regulatory Commission Washington, D.C.
20555*
Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C.
20555*
t e 6 1-e, p
Benjamin H. Vogler Senior Supervisory Trial Attorney
.