ML20150F918

Affidavit of Js Wiley.* Responds to Six Questions Raised by ASLB Re Iodine Spike. Certificate of Svc Encl

ML20150F918
Person / Time
Site:	Limerick
Issue date:	03/29/1988
From:	Wiley J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
Shared Package
ML20150F876	List: ML20150F872 ML20150F918
References
OLA, NUDOCS 8804060079
Download: ML20150F918 (9)

Text

,

UNITED STATES OF AMERICA NUCLEAR REGULATORY COSMISSION Before the Atomic Safety and Licensing Board In the Matter of

)

)

Philadelphia Electric Company

)

Docket No. 50-352-OLA

)

(TS Iodine)

(Limerick Generating Station,

)

Unit 1)

)

AFFIDAVIT OF J0fN S. WILEY John S. Wiley, being duly sworn according to law, does depose and say:

1.

My name is John S. Wiley.

I am Director of the Nuclear Plant Chemistry Section for Philadelphia Electric Company.

In that position, 1 am responsible for the technical direction of chemical programs at the Company's nuclear facilities.

My experience and qualifications are stated in Paragraph 4-6 of my prior Affidavit of November 20, 1987, submitted in support of Licensee's motion for summary disposition in this proceeding, which are incorporated herein by reference.

2 I am responding to the six questions raised by the Atomic Safety and Licensing Board Order dated March 17, 1988 which I shall address in order.

Question 1 Please define "iodine spike" as used in the proposed amendment.

I An iodine spike is an increase and subsequent decrease in iodine dose. equivalent in the primary reactor coolant following a change in reactor power or pressure.

As "iodine spike" is used in the proposed amendment, the increase in iodine dose equivalent must be to a level greater than 0.2 microcurie per gram, h$[ ADO 32 O

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f.

._ Question 2 Based on the definition used in Question 1, how is the presence or absence of iodine spikes detemined?

The presence or absence of iodine spike is determined by sampling for iodine coolant activity in accordance with Technical Specification 4.4.5 (including Table 4.4.5-1), a copy of which is attached hereto.

In addition to the prima:y coolant specific activity sample and analysis required by Technical Specification 4.4.5, iodine sampling is conducted daily during operation of the plant.

Question 3 Are iodine spikes required to be reported to NRC?

If so, describe the specific reporting requirements.

r Existing Technical Specification 3/4.4.5 requires the Licensee to submit special 30- and 92-day reports if the reportable iodine coolant activity level of 0.2 microcurie per gram were exceeded or if the events specified in Technical Specification 3/4.5.c were to occur.

The requested amendment would delete this requirement so that such infomation would be t

included in the annual report required by the Technical Specifications.

Section 6.9.1.5(d) of the Administrative Controls section of the Technical Specifications (copy attached) will be added to implement this requirement.

In addition, the requested amendment proposed to eliminate as unnecessary the requirement under Technical Specification 4.4.5 to submit a special report within 30 days if the iodine coolant activity were exceeded for a period of 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> in any consecutive six-month period.

. Other specific reporting requirements which relate to iodine levels in the reactor coolant are set forth in Paragraphs 16-18 of my prior Affidavit dated November 20, 1987, submitte) in support of the Licensee's motion for summary disposition, which are incorporated herein by reference.

Question 4 Volumes 1, 2 and 3 of NUREG/Cr-3950 summarize fuel performance for the years 1983, 1984 and 1985.

The fuel performance data for 1986 and later is not yet published.

Assuming the data is available, have there been any incidents of iodine spiking (as defined in response to Question 1) at any BhR's in the United States since 1985?

If so, identify the iodine spike as to Plant name and time of event.

This infomation is not available to the Licensee.

h'e are advised that the NRC Staff will provide this infomation in its response.

Question 5 Have there been

./ iodine spiking events at the Limerick Plant?

No.

Question 6 The Licensee's affidavit provides some information on iodine concentrations in the reactor coolant.

There is some question as to the peak iodine concentration, subsequent to the first fuel cycle of operation.

Please state the highest iodine concentration measured in the reactor coolant in any fuel cycle up to and including the current date (end of February 1988 would suffice).

If the highest reading was in the first cycle, state the highest iodine concentration found in reactor coolant in any later cycles.

t

a.

-. The peak value for iodine concentration in the primary reactor coo 1 Ant for the first cycle of operation was 1.2 x 10-4 microcurie per gram.

As of March 29, 1988, the peak value for the second (present) fuel cycle is 2.2 x 10'4 microcurie per gram, which occurred on March 25, 1988.

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Johns.Wileg J

Subscribed and sworn to A

before me this 2 9 day of March,1988, i

s b "' '.,. < J l,,4b

<.s Notary Public MEL. ANTE R. CAMPANELLA ge, PNisdci;hi3. pnanf#s Co.

II' Copssica EartS RtF4

REACTOR COOLANT SYSTEM 3/4.4.5 SPECIFIC ACTIVITY 1

LIMITING CONDITION FOR OPERATION l

3.4.5 The specific activity of the primary coolant shall be limited to:

Less than or equal to 0.2 microcurie per gram DOSE EQUIVALENT I-131, a.

and b.

Less than or equal to 100/E microcuries per gram.

APPLICABILITY:

OPERATIONAL CONDITIONS 1, 2, 3, and 4.

ACTION:

In OPERATIONAL CONDITION 1, 2, or 3 with the specific activity of a.

the primary coolant; 1.

Greater than 0.2 microcurie per gram DOSE EQUIVALENT I-131 but less than or equal to 4 microcuries per gram, operation may continue for up to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> provided that the cumulative operating time under these circumstances does not exceed 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> in any consecutive 12 month period.

With the total cumulative operating time at a primary coolant specific activity greater than.0.2 micro-curie per gram DOSE EQUIVALENT I-131 exceeding 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, prepare and submit a Special Report to the Commission pursuant to Specification 6.9.2 within 30 days indicating the number of hours of operation above this limit.

The provisions of Specification 3.0.4 are not applicable.

2.

Greater than 0.2 microcurie per gram DOSE EQUIVALENT I-131 for more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> during one continuous time interval or for more than 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> cumulative operating time in a consecutive 12-montt period, or greater than 4 microcuries per gram, be in at least HOT SHUTOOWN with~the main steam line isolation valves closed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

3.

Greater than 100/E microcuries per gram, be in at least HOT SHUTDOWN with the main steamline isolation valves closed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, b.

In OPERATIONAL CONDITION 1, 2, 3, or 4, with the specific activity of the primary coolant greater than 0.2 microcurie per gram DOSE EQUIVALENT I-131 or greater than 100/l microcuries per gram, perform j

the sampling and analysis requirements of Item 4.a) of Table 4.4.5-1 I

until the specific activity of the primary coolant is restored to within its limit.

A Special Report shall be prepared and submitted to the Commission pursuant to Specification 6.9.2 within 30 days.

i l

This report shall contain the results of the specific activity analyses and the time duration when the specific activity of the coolant exceeded 0.2 microcurie per gram DOSE EQUIVALENT I-131 together with the following additional information.

l l

l LIMERICK - UNIT 1 3/4 4-15 i

REACTOR COOLANT SYSTEM LIMITING CONDITION FOR OPERATION (Continued)

ACTION:

(Continued) c.

In OPERATIONAL CONDITION 1 or 12, with:

1.

THERMAL POWER changed by more than 15% of RATED THERMAL POWER in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />", or 2.

The off gas level, at the SJAE, increased by more than 10,000 microcuries per second in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> during steady-state operation at release rates less than 75,000 microcuries per. second, or 3.

The off gas. level, at the SJAE, increased by more than 15% in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> during steady state operation at release rates greater than 75,000 microcuries per second, perform the sampling and analysis requirements of Item 4.b) of Table 4.4.5-1 until the specific activity of the primary coelant is restored to within its limit.

Prepare and submit to the Commission a Special Report pursuant to Specification 6.9.2 at least once per 92 days containing the results of the specific activity analysis together with the below additional information for each occurrence.

Additional Information 1.

Reactor power history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to:

a)

The first sample in which the limit was exceeded, and/or b)

The THERMAL POWER or off gas level change.

2.

Fuel burnup by core region.

3.

Clean-up flow history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to:

a)

The first sample in which the limit was exceeded, and/or b)

The THERMAL POWER or off gas level change.

4.

Off gas level starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to:

a)

The first sample in which the limit was exceeded, and/or b)

The THERMAL POWER or off gas level change.

SURVEILLANCE REQUIREMENTS 4.4.5 The specific activity of the reactor coolant shall be demonstrated to be within the limits by performance of the sampling and analysis program of Table 4.4.5-1.

• Not applicable during the startup test program.

LIMERICK - UNIT 1 3/4 4-16

e-j{

TABLE a.4.5-1

}

PRIMARY COOLANT SPECIFIC ACTIVITY SAMPLE AND ANALYSIS PROGRAM OPERATIONAL CONDITIONS EE TYPE OF MEASUREMENT SAMPLE AND ANALYSIS IN WHICH SAMPLE El AND ANALYSIS FREQUEh;Y AND ANALYSIS IS REQUIRED w

1.

Gross Beta and Gamma Activity At least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

1,2,3 Determination 2.

Isotopic Analysis for DOSE At least once per 31 days 1

EQUIVALENT I-1 131 Concentration 3.

Radiochemical for E Determination At least once per 6 months

• 1 4.

Isotopic Analysis for Iodine a) At least once ptr 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, 1**,

2**,

3**, 4**

EY whenever the specific activity exceeds a limit, j[

as required by ACTION b.

u b) At least one sample, between 1, 2 2 and 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> following the change in THERMAL POWER or off gas level, as required by ACTION c.

S.

Isotopic Analysis of an Of f-At least once per 31 days 1

gas Sample Including Quantitative Measurements for at least Xe-133, Xe-135, and Kr-88

• Semple to be taken af ter a minimum of 2 EFPD and 20 days of POWER OPERATION have elapsed since reactor was last subcritical for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or longer.

^^Until the specific activity of the primary coolant systed is restored to within its limits

,wm a i.:,. m. < :. w a s m.

ANNUAL REPORTS (Continued) fropoud Sedicn (c. '~f. 1. 5 o

dosimeter, thermoluminescent dosimeter (TLD), or film badge measurements.

Small exposures totalling less than 20% of the individual total dose need not be accounted for.

In the aggregate, at least 80% of the total whole-body dose received from external sources should be assigned to specific major work functions; b.

Documentation of all challenges to safety / relief valves; and c.

Any other unit unique reports required on an annual basis; and d.

The results of specific activity analysis in which the primary coolant exceeded the limits of Specification 3.4.5.

The following information shall be included: (1) Reactor power history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in which the limit was exceeded; (2) Results of tb.a last isotopic analysis for radiciodine performed prior to exceeding the limit, results of analysis while limit was exceeded and results of one analysis after the radioicdine activity was reduced to less than limit.

Each result should include date and time of sampling and the radiciodine concentrations; (3) Cleanup system flow history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in which the limit was exceeded; (4) Graph of the I-131 concentration and one other radiciodine isotope concentration in microcuries per gram as a function of time for the duration of the specific activity above the steady-state level; and (5) The time duration when the specific activity of the primary coolant exceeded the radiciodine limit.

MONTHLY OPERATING REPORTS 6.9.1.6 Routine reports of operating statistics and shutdown experience, including documentation of all challenges to the main steam system safety / relief valves, shall be submitted on a monthly basis to the Director, Office of Resource Management, U.S. Nuclear Regulatory Commission, Washington, D.C.

20555, with a copy to the Regional Administrator of the Regional Office of the NRC no later than the 15th of each month following the calendar month covered by the report.

ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT

• 6.9.1.7 Routine Annual Radiological Environmental Operating Reports covering the operation of the unit during the previous calendar year shall be submitted prior to May 1 of each year.

The initial report shall be submitted prior to May 1 of the year following initial criticality.

The Annual Radiological Environmental Operating Reports shall include l

summaries, interpretations, and an analysis of trends of the results of the radiological environmental surveillance activities for the report period, including a comparison (as appropriate), with preoperational studies, operational controls and previous LIMERICK - UNIT 1 6-16 t

r-I f s.

D'L KE ii.0 U5NHC UNITED STATES OF AMERICA 88 A

-4 P7 :30 NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensioty!Soard(,ng,w 00GM iiho 4 SE8vlCf.

BRANCH In the Matter of

)

)

Philadelphia Electric Company

)

Docket No. 50-352-OLA

)

(TS Iodine)

(Limerick Generating Station,

)

Unit 1)

)

CERTIFICATE OF SERVICE I hereby certify that copies of "Licensee's Response to Order of March 17, 1988 Requesting Clarifying Information" dated March 31, 1988 and "Affidavit of John S.

Wiley" dated March 29, 1988 in the captioned matter have been served upon the following by deposit in the United States mail this 31st day of March, 1988:

Sheldon J. Wolfe, Benjamin H. Vogler, Esq.

Chairman Robert M. Weisman, Esq.

Atomic Safety and Counsel for NRC Staff Licensing Board Panel Office of the General U.S. Nuclear Regulatory Counsel Commission U.S. Nuclear Regulatory Washington, D.C.

20555 Commission Washington, D.C.

20555 Dr. Richard F. Cole Atomic Safety and Docketing and Service Licensing Board Panel Section U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.

20555 Washington, D.C.

20555 Dr. George A.

Ferguson Mr. Frank R.

Romano Atomic Safety and 61 Forest Avenue Licensing Board Panel Ambler, Pennsylvania 19002 5307 Al Jones Drive Columbia Beach, MD 20764 Mr. Robert L.

Anthony Box 186 103 Vernon Lane Moylan, PA 19065 M/h. A

.