Reporting Requirements on Primary Coolant Iodine Spikes (Generic Letter No. 85-19)

                                UNITED STATES
                           WASHINGTON, D. C. 20555

                             September 27, 1985



SUBJECT:  Reporting Requirements on Primary Coolant Iodine Spikes - (Generic
          Letter No. 85-19) 

Generic Letter No. 83-43 was issued on December 19, 1983, to provide 
guidance on Technical Specification revisions required as the result of the 
revisions to 10 CFR 50.72 (Immediate Notification Requirements of 
Significant Events at Operating Nuclear Power Reactors) and of 
implementation of 10 CFR 50.73 (Licensee Event Report System). That generic 
letter discussed changing the requirement from a Licensee Event Report to a 
Special Report for operating conditions where the specific activity limits 
of the reactor coolant are exceeded. 

As part of our continuing program to delete unnecessary reporting 
requirements, we have reviewed the reporting requirements related to primary
coolant specific activity levels, specifically primary coolant iodine 
spikes. We have determined that the reporting requirements for iodine 
spiking can be, reduced 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 is similar to that 
previously required in the Licensee Event Report but has been changed to 
more clearly designate the results to be included from the specific activity 
analysis and to delete the information regarding fuel burnup by core region.

In our effort to eliminate unnecessary Technical Specification requirements,
we have also determined that the existing requirements to shut down a plant 
if coolant iodine activity limits are exceeded for 800 hours in a 12-month 
period can be eliminated. The quality of nuclear fuel has been greatly 
improved over the past decade with the result that normal coolant iodine 
activity (i.e. in the absence of iodine spiking ) is well below the limit. 
Appropriate actions would be initiated long before accumulating 800 hours 
above the iodine activity limit. In addition, 10 CFR 50.72(b)(1)(ii) 
requires the NRC to be immediately notified of fuel cladding failures that 
exceed expected values or that are caused by unexpected factors. Therefore, 
this Technical Specification limit is no longer considered necessary on the 
basis that proper fuel management by licensees and existing reporting 
requirements should preclude ever approaching the limit. 

Licensees are expected to continue to monitor iodine activity in the primary
coolant and take responsible actions to maintain it at a reasonably low 
level (i.e., accumulated time with high iodine activity should not approach 
800 hours). 


                                    - 2- 

Enclosed are model Technical Specifications in Standard Technical 
Specification (STS) format showing the revisions that may be used in a 
submittal of proposed Technical Specifications or proposed changes to 
existing Technical Specifications. These changes will also be incorporated 
in the next revision of the STS for all nuclear power reactor vendors. The 
changes are indicated by a line in the margin of the Action Statement for 
the Limiting Condition for Operation. A Technical Specification amendment 
request should be submitted to the NRC for each facility which currently has
Technical Specification reporting requirements upon exceeding coolant iodine
activity limits or which has a requirement to shut down after 800 hours with
iodine above the limit. Your request should include appropriate changes to 
the bases section of your Technical Specifications. 

As a matter of information, when Technical Specification changes or other 
proposed license amendments and approvals (i.e., proposed facility 
modifications requiring NRC approval are required as a result of this or 
another generic letter, they are subject to the fee provisions of 10 CFR 170
and a $150 application fee should accompany your request (see 10 CFR 
170.12(c) and 170.21). 

If you have any questions relating to this subject, please contact M. Virgil
of my staff on (301-492-8947). 

This request has been approved by OMB Clearance Number 3150-0011, which 
expires September 30, 1986. 


                              Hugh L. Thompson, Director 
                              Division of Licensing 

"Model Technical Specifications showing Revisions to STS Reporting 
Requirements for Primary Coolant Specific Activity" 

List of Generic Letters 

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