ML20247L265

Safety Evaluation Supporting Amend 20 to License NPF-39

ML20247L265
Person / Time
Site:	Limerick
Issue date:	05/19/1989
From:	Office of Nuclear Reactor Regulation
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ML20247L255	List: ML20247L251 ML20247L265
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NUDOCS 8906020119
Download: ML20247L265 (6)

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-SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION i

l SUPPORTING AMENDMENT NO. 20 T0 FACILITY OPERATING LICENSE NO. NPF-39 PHILADELPHIA ELECTRIC COMPANY LIMERICK GENERATING STATION, U' NIT 1 DOCKET NO. 50-352 i

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1.0 INTRODUCTION

l By letter dated August 19, 1986, Philadelphia' Electric Company (the licensee) requested an-amendment to Facility Operating License No..NPF-39 for the Limerick Generating Station, Unit 1.

The proposed amendment would replace the requirement for a short term report on iodine. spiking events with a requirement that an item discussing iodine spiking be included in-the Annual Report. Additionally, the amendment eliminates the existing.

requirement to shutdown the plant if coolant iodine activity limits are exceeded for 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> in a 12 month period. Generic Letter No. 85-19,

" Reporting Requirements on Primary Coolant Iodine Spikes" was issued on September 27, 1985 to all licensees and holders of construction permits.

The Generic Letter stated that the NRC staff had determined that the reporting requirements for iodine spiking could be changed from a short term report (Special Report or Licensee Event Report) to an item which is to be included in the Annual Report. The information to be included in the Annual Report would be similar to that previously required in the Licensee Event Report but would be changed to more clearly designate certain desired information. Accordingly, by application dated August 19 1986, the licensee reouested that the Limerick Technical Specification (TS)

Section 3.4.5, BASES Section 3/4.4.5 and Section 6.9.1.5 be amended to incorporate the revised reporting requirements as described in the Model TS accompanying Generic Letter No. 85-19.

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1 2.0 EVALUATION J

i The current Limerick TS require short term Special Reports within 30 or 90 days in response to the requirements of TS 3.4.5 ACTION statements a.1, b and c.

Certain additional information is also specified by TS 3.4.5

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for inclusion in several of these short term reports.

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In addition to these short term reporting requirements currently contained l

in the Limerick TS's, the Commission's regulations in 10 CFR 50.72 (Immedi-i ate Notification Requirements of Significant Events at Operating Nuclear Power Reactors) and in 10 CFR 50.73 (Licensee Event Report System) impose reoorting requirements which include the following:

(1)

An LER is required following)the completion of any plant shutdown, required by the TS [50.73 (a (2)(1)].

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(2) One. hour notification of the.NRC is required when initiating a non-emergency event plant shutdown, which is required by the TS [50.72(b)

(1)(1)].

(3) One hour notification of the NRC is required.in the' event of fuel cladding failures that exceed ex unexpected: factors [50.72(b)(1)(pectedvaluesorthatarecausedby ii)].

As stated in the' BASES of the TS's, the purpose of.the short term reporting requirements was to obtain information to assess ~the parameters associated with spiking phenomena. The staff's safety concerns associated with iodine spiking are primarily with respect to changes in coolant activity which may indicate a significant degradation of fuel cladding. The immediate notification and reporting requirements of 10 CFR 50.72 and 50.73 will provide the NRC with adequate notification of and information on an increase

.in coolant activity which is indicative of.significant fuel degradation.

Therefore, the staff has concluded that the notification and reporting' requirements of the Commission's regulations in 10 CFR 50.72 and 10 CFR 50.73 in conjunction with the augmentation of the plant's annual Report as proposed by the licensee in accordance with the staff's Generic Letter 85-19 are sufficient to provide adequate information to the Connission.

Accordingly, the Special Reports now specifically required by TS 3.a.5 may.

be eliminated in lieu of the other reporting requirements as discussed above.

Generic Letter No. 85-19 also stated that the staff had determined that the existing requirement to shutdown a plant if coolant iodine activity limits are exceeded for 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> in a 12-month period could be eliminated.

The Generic Letter indicated that (a) on the basis o_f the improved quality i

L of nuclear fuel which results in normal coolant iodine activity being well l

below the limit, (b) the likelihood of appropriate actions being taken long before accumulating 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> above the normal coolant iodine activity limit,and9c)therequirementof10CFR50.72(b)(1)(fi)forpromptnotifi-cation of NRC in the event of fuel cladding failures which exceed expected values, this 800 hour0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> TS limit is no longer considered necessary since proper fuel management by licensees and existing reporting requirements should preclude ever approaching the limit. Accordingly, in the application dated August 19, 1986, the licensee also requested that Limerick TS Section 3.4.5 and BASES Section 3/4.4.5 be amended to delete the 800-hour limit.

The shutdown requirements of Technical Specification 3.4.5 are based on the consideration (TS BASES Section 3/4.4.5) that the specific activity level in the primary coolant should be limited to a relatively low level during plant operation so that, should a main steam line failure occur 4

outside the containment, the dose rate from activity in the released coolant will not result in doses exceeding a small fraction of the dose guidelines of 10 CFR Part 100.

Iodine spiking is a temporary increase in coolant iodine concentration associated with reactors having leaking fuel rods. These temporary increases in iodine concentrations have been observed to occur following changes in thermal power. An iodine spike is characterized by a rapid increase in coolant iodine concentration followed by a return to prespike concentrations.

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. During the course of the' operating license review, the staff performed i

an analysis of the radiological consequences of main steam line failure 1

outside the containment as discussed in Section 15 of the Safety Evaluation Report. The analysis was performed following the guidelines and criteria specified in-Standard Review Plan (SRP) Section 15.6.4.

An iodine con-centration for continued full power operation was used in the analysis.

This is the_same equilibrium value stated in the licensee's Technical I

l Specification. To account for the effect of potential iodine spiking.

(per Re of 20 (gulatory Guide 1.5) the equilibrium value was increased by a factor to 4 micro Ci/gm) in the analysis.

Other conservative assumptions used in the safety analysis include no plateout of iodine from the released coolant,'no radioactive decay of Iodine 131 in transit and pessimistic meteorological conditions. Results of the analysis show that the doses will_not exceed a small fraction of the dose guideline values of 10 CFR Part 100 for the equilibrium value and will not exceed the dose guideline values of 10 CFR Part 100 for the maximum value permitted, consistent with the criteria set forth-in the Standard Review Plan.

Technical Specification 3.4.5 is intended to assure that the plant will operate within the values assumed in the safety analysis. The current TS imposes requirements for plant shutdown within 12-hours if the following activity level of the primary coolant is indicated:

a.

Greater than 0.2 micro Ci/gm dose equivalent I-131, but less than 4 micro Ci/gm for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> continuous operation-(to allow for iodine spiking by permitting temporary excursions); or, b.

Greater than 4 micro Ci/gm dose equivalent I-131 at any time; or, c.

Greater than 0.2 micro Ci/gm dose equivalent I-131, but less than 4 l

micro Ci/gm for cumulative 800-hours operation in any consecutive t

12-month period.

In addition, Technical Specification 3.4.5 requires that, with the specific activity of the primary coolant ~ greater than 0.2 micro Ci/gm dose equivalent I-131, the operator shall perform the sampling and analysis of the coolant activity level at least once every 4-hours until the activity level has-returned to within the 0.2 micro C1/gm limit.

Review of these requirements indicated that Items a. and b. in conjunction

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with the surveillance requirements provide reasonable assurance of operation j

within the bounds of the safety analyses. This is based on the following considerations:

1) Item b requires shutdown any time an activity level of 4 micro Ci/gm is exceeded. This value of 4 micro C1/gm is the upper limit value used in the staff analysis which indicated that doses would not exceed the guideline values in 10 CFR Part 100. 2) Item a. requires shutdown under conditions which indicate that significant fuel degradation may be occurring; and 3) the surveillance requirements require sampling every 4-hours once the activity level exceeds 0.2 micro Ci/gm, thus assuring that an activity level which exceeds 4 micro C1/gm will be detected

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., :within 4-hours and shutdown will then be. required. Therefore, Items a, l

and b. require-plant shutdown once significant fuel. degradation is

. indicated and Item c. would only allow the plant to operate for a cumu-lative 800-hour period if: the activity. level remains between O'.2 to 4 l

micro C1/gm for many successive periods of. operation.

Each of these l:

periods which exceeded 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> would be followed by a shutdown, as.noted in a. above, making such operation highly impractical. However, if the.

activity level is; restored to a level below 0.2 micro Ci/gm within 48-l hours, this indicates no significant fuel degradation.. Thus, it is unlikely '

l that 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> of operation above 0.2; micro Ci/gm without violating the

. requirements of item a. or ~ item b. would occur, and the. cumulative 800-hours limit necessitates a record-keeping requirement for fuel conditions which is not significant to safety. Moreover, none of the' conservative assumptions used in-the staff's dose assessment will be degraded by the-deletion of the 800-hour limit. Therefore, based on the above consider-ations, the staff has concluded that the current TS 800-hour operating limit is unnecessary and can be eliminated.

The licensee's request for a revision of the Limerick Unit 1 Technical Specifications Section 3.4.5, BASES 3/4.4-5 and Administrative Controls

Section 6.9.1.5 are acceptable on the bases discussed above and the finding _that the proposed changes are consistent with the staff position and guidance described in the Model TS contained in Generic Letter No. 19.

3.0 COMMENTS AND HEARING REQUESTS PRIOR TO NOTICE By letter dated August 19, 1986, the licensee applied to the NRC for an amendment of the TSs for Limerick Unit 1 in response to the staff's Generic Letter No. 85-19. On August 25, 1986, prior to the publication by the staff of any notice of its intent,to issue the amendment or any finding with regard to the no significant hazards consideration, Mr.

Robert A. Anthony (Anthony) filed a petition for leave to intervene and a request for a hearing on the licensee's proposed amendment. On September 4,1986, also prior to the staff publication of any notice, Mr. Frank R.

Romano, representing the Air and Water Pollution Patrol (AWPP), filed a petition to intervene and a request for a hearing.

The staff published in the Federal Register its intent to issue the requested amendment on March 12, 1987, in which it provided an opportunity to request a hearing and made a proposed determination that the requested amendment involved a no significant hazards consideration.

The notice provided that any request for hearing must be received by April 13, 1987. Although no request for hearing was received during the period specified by the notice in the Federal Register, an Atomic Safety and Licensing Board (Board) was convened to rule on the prematurely filed pleadings.

Ultimately, over the objections of the Licensee and the Staff, the two interveners were admitted as parties and a consolidated contention was admitted as an issue in controversy. Thereafter, on November 23, 1987, the Licensee filed its motion for summary disposition. The Staff filed its response in support of the Licensee's motion on February 18, 1988.

Subsequently the Staff and Licensee responded in affidavit form to additional qu,estions posed by the Licensing Board.

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-In a Memorandum' and Order dated fiay 5,1988, LBP-88-12, 27 NRC 495(1988),

d the Licensing Board determined that the Licensee, as supported by the j

Staff, had sustained its burden of showing that there was'no genuine issue I

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of material fact to.be litigated and held that the Licensee was entitled l

to a decision as.a matter of law.

In its Memorandum and Order, the.

j Licensing Board found that' the requested amendment, contrary to the allegations.of~the interveners, would not. result in a decrease in i

regulatory control; would not change release limits or reporting -

requirements.for such releases; would not permit' excessive;one time releases and does not involve limits for radioactive gaseous releases.

Accordingly, the' Licensing Board granted the motion for sumary

disposition, terminated the proceeding and authorized the Director of

. Nuclear Reactor Regulation to issue the requested amendment.

The AWPP' appealed the Order.

In a Decision issued July 18,'1988, the

. Atomic Safety and Licensing (Appeal Panel affirmed the Licensing Board's s

Order. :ALAB-897,128.NRC 33 1988) By memorandum dated September 30, 1988, the Secretary of the Comission informed the Board and Parties that the Commission declined any review of the Appeal Board decision, ALAB-897, and that the decision was the final agency action on the issue.

4,0 ENVIRONMENTAL CONSIDERATION This, amendment involves a change to a requirement with respect to the installation.or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes to the surveillance require-ments. The staff has determined that the amendment involves no significant.

increase in the amounts, and no significant change in the types, of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure.

The Comission has previously issued a proposed finding that this amendment involves no significant hazards consideration [52 FR 7691-7693] and there h~as been no public coment on such finding other than the hearing requests that were received. Hearing requests that were received prior to the staff's proposed finding of no significant hazard consideration, were considered by the Atomic Safety and Licensing Board, and were disposed of on suimmary disposition.- Accordingly, this amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuantto10CFR51.22(b),noenvironmentalimpactstatementor environmental assessment need be prepared in connection with the issuance of this amendment.

5.0 CONCLUSION

The Comission made a proposed determination that the amendment involves no significant hazards consideration which was published in the Federal Register (52 FR 7691) on March 12, 1987 and consulted with the State

-of Pennsylvania. The State of Pennsylvania did not have any comments.

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. l The staff has concluded, based on the considerations d'iscussed 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, and (2) such activities will be conducted in compliance with the Commission's regulations and.the issuance of this amendment will not be inimical to the-common defense and the security nor to the health and safety of the public Principal Contributor: Dick Clark Dated: May 19, 1989

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