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Category:TECHNICAL SPECIFICATIONS
MONTHYEARML20211P2871999-09-0909 September 1999 Proposed Tech Specs Pages,Increasing Present 100% Authorized Rated Thermal Power Level of 3579 Megawatts Thermal to 3758 Megawatts Thermal ML20216E4631999-09-0909 September 1999 Proposed Tech Specs Change Eliminating Requirement in EPP to Sample Lake Erie Sediment in Perry & Eastlake Plant Area for Corbicula,Since Corbicula & Zebra Mussels Have Already Been Identified & Control & Treatment Plans Are Implemented ML20216E4791999-09-0909 September 1999 Proposed Tech Specs Revising Allowable Values for CST Low Water Level Limits from Greater than or Equal to 59,700 Gallons to Greater than or Equal to 90,300 Gallons ML20210M7851999-08-0404 August 1999 Proposed Tech Specs 3.9.1,incorporating Addl Option Into Required Actions When Refueling Interlocks Are Inoperable ML20196A2021999-06-17017 June 1999 Proposed Tech Specs SRs Implementing 24-month Operating Cycle at Pnpp ML20204E4971999-03-15015 March 1999 Proposed Tech Specs,Correcting Typos Found in Table 3.3.6.1-1 ML20207K1041999-03-0404 March 1999 Proposed Tech Specs Improving Licensing & Design Basis for Isolation of FW Penetrations ML20206Q3571999-01-0606 January 1999 Proposed Tech Specs Improving Licensing & Design Basis for Isolation of Feedwater Penetrations ML20155D9431998-10-27027 October 1998 Proposed Tech Specs 2.1.1.2,applying Addl Conservatism by Modifying MCPR Safety Limit Values,As Calculated by GE ML20155D8241998-10-27027 October 1998 Proposed Tech Specs Adding Two Paragraphs to TS 5.2.2.e, Organization - Unit Staff ML20151V4831998-09-0909 September 1998 Proposed Tech Specs Stipulating That Water Leakage from Feedwater motor-operated CIVs Will Be Added Into Primary Coolant Sources Outside of Containment Program & Check Valves Do Not Need to Be Included in Hydrostatic Program ML20151V1111998-09-0303 September 1998 Proposed Tech Specs Permitting EDG TS Action Completion Time of Up to 14 Days for Div 1 or 2 EDG & Allowing Performance of EDG 24-hour TS SR Test in Modes 1 & 2 ML20151V6861998-09-0303 September 1998 Proposed Tech Specs Increasing Present Div 3 DG Fuel Oil Level Requirements to Account for Rounding Error in Calculation & Unusable Volume Due to Vortex Formation at Eductor Nozzles Located in Fuel Oil Storage Tank ML20151S9561998-08-31031 August 1998 Proposed Tech Specs,Allowing Blind Flange in Inclined Fuel Transfer Sys (Ifts) Containment Penetration to Be Removed While Primary Containment Is Required to Be Operable ML20236T7911998-07-22022 July 1998 Proposed Tech Specs Revising MSL Leakage Requirements & Eliminating Msli Valve Leakage Control Sys ML20151P1921998-07-13013 July 1998 Proposed Tech Specs,Increasing Present +/- 1% Tolerance on Safety Mode Lift Setpoint for SRVs to +/- 3% ML20236H8411998-06-30030 June 1998 Proposed Tech Specs,Increasing Boron Concentration in Standby Liquid Control Sys for Pnpp Cycle 8 Fuel Design & Providing Margin for Future Cycles as Required ML20216H9361998-04-14014 April 1998 Rev 1 to Proposed TS Bases,Reflecting Changes Made Since Original Implementation of TS in Improved Format in June 1996 ML20197F7871997-12-23023 December 1997 Proposed Tech Specs,Revising 3.8.1 Re AC Sources to Be Consistent W/Recommendations in GL 94-01, Removal of Accelerated Testing & Special Reporting Requirements for Edgs ML20217K6501997-10-22022 October 1997 Proposed Tech Specs Incorporating Temp Control Valves & Associated Bypass Lines Around Emergency Closed Cooling Sys Heat Exchanger ML20217F5911997-10-0202 October 1997 Proposed Tech Specs,Adding Note to TS 2.1.1.2 Re MCPR SL Values & Adding Footnote to TS 5.6.5.b to Reference NRC SER That Approved MCPR SL Values for Cycle 7 ML20210T9631997-09-0808 September 1997 Proposed Tech Specs 5.2.2.e,removing Reference to NRC Policy Statement on Working Hours.Rev Allows Changes to Specific Overtime Limits & Working Hours to Be Evaluated IAW 10CFR50.59, Changes,Tests & Experiments ML20217Q4591997-08-28028 August 1997 Proposed Tech Specs 3.4.11,revising Pressure-Temp Limits,Per Reactor Vessel Matl Surveillance Program Requirements Contained in App H of 10CFR50.90 ML20148A6591997-05-0202 May 1997 Proposed Tech Specs,Revising Existing Exception to LCO 3.0.4 as Applies to LCO 3.6.1.9 for MSIV Leakage Control Sys ML20148A6871997-05-0202 May 1997 Proposed Tech Specs Re Surveillance Requirement for MSIV Leakage Rate Acceptance Criteria ML20137S7761997-04-0909 April 1997 Proposed TS Requirements 3.9.1.1 & 3.9.2.2 Re Frequency on Refueling Equipment & one-rod-out Interlocks ML20134D8251997-01-31031 January 1997 Proposed Tech Specs 1.1 Re definitions,3.6.1.1 Re Primary Containment - operating,3.6.1.2 Re Primary Containment Air locks,3.6.1.3 Re PCIVs,3.6.5.1 Re Drywell & 5.5 Re Programs & Manuals ML20134D8751996-10-24024 October 1996 Proposed Tech Specs 2.1.1.2,safety Limits Applying Conservatism by Increasing MCPR Safety Limit Values ML20117E7891996-08-27027 August 1996 Proposed Tech Specs,Revising Mls Leakage Requirements & Eliminating MSIV Control Sys ML20108A2581996-04-26026 April 1996 Proposed Improved Tech Specs ML20100N9501996-03-0101 March 1996 Proposed TS Pages Re Drywell Leak Rate Testing Requirements ML20100L3331996-02-27027 February 1996 Proposed Tech Specs Re Drywell Personnel Air Lock Shield Door Analyses ML20100J5971996-02-24024 February 1996 Proposed Tech Specs,Revising Definition of Core Alteration ML20149K2221996-02-17017 February 1996 Proposed Tech Specs,Reflecting Mod of Leakage Rate Requirements for Main Steam Lines Until End of Operating Cycle 6 ML20096D4651996-01-16016 January 1996 Proposed TS Requirements for Drywell Leak Rate Testing ML20096C0591996-01-10010 January 1996 Proposed Tech Specs,Requesting one-time Surveillance Interval Extension to Support Current Schedule for Refueling Outage 5,scheduled to Begin 960127 ML20095H4721995-12-20020 December 1995 Proposed Tech Specs Re Replacement of Selected Analog Leak Detection Sys Instruments W/Ge Numac Leak Detection Monitor ML20094E6751995-11-0202 November 1995 Proposed Tech Spec,Requesting Rev to TS for Onsite Power Distribution Sys:Ts 3/4.8.3.1, Distribution - Operation ML20094F2051995-11-0202 November 1995 Proposed Tech Specs for Handling Irradiated Fuel in Containment or Fuel Handling Bldg & Performing Core Alterations ML20091R1911995-08-29029 August 1995 Proposed Tech Specs,Incorporating New Instrumentation Trip Setpoints & Allowable Values ML20086C7281995-06-30030 June 1995 Proposed Tech Specs Re Surveillance Test Interval Extension Request ML20084U0781995-06-0909 June 1995 Proposed Tech Specs Reflecting one-time Extension of Performance Intervals of Certain SRs ML20084Q5351995-06-0101 June 1995 Proposed Tech Specs for Implementation of Control Rod Drive Scram Time Testing Consistent W/Requirements in Pnnp Improved TS LAR ML20083Q1991995-05-18018 May 1995 Proposed Tech Specs for Conversion to TS Based on NUREG-1434, Improved BWR6 Ts ML20083A6841995-05-0505 May 1995 Proposed Tech Specs Re Changes to App a TSs ML20087H8911995-05-0101 May 1995 Proposed Tech Specs Re Incorporation of Results of Work Performed by BWROG ML20087H9411995-04-28028 April 1995 Proposed Tech Specs Re Removal of License Conditions for Tdi EDGs Specified by Paragraph 2.c & in Attachment 2 to Operating License ML20087H9311995-04-28028 April 1995 Proposed Tech Specs,Proposing Extension for One Operating Cycle of Exception to LCO 3.0.4 as Applies to TS for MSIV LCS ML20082C2681995-04-0303 April 1995 Proposed Tech Specs,Adding New Programmatic Requirements Governing Radiological Effluents & Relocating Procedural Details of RETS to ODCM or PCP ML20081K3191995-03-24024 March 1995 Proposed Tech Specs Re one-time Extension of Performance Intervals for Certain TS Surveillance Requirements 1999-09-09
[Table view] Category:TECHNICAL SPECIFICATIONS & TEST REPORTS
MONTHYEARML20216E4791999-09-0909 September 1999 Proposed Tech Specs Revising Allowable Values for CST Low Water Level Limits from Greater than or Equal to 59,700 Gallons to Greater than or Equal to 90,300 Gallons ML20216E4631999-09-0909 September 1999 Proposed Tech Specs Change Eliminating Requirement in EPP to Sample Lake Erie Sediment in Perry & Eastlake Plant Area for Corbicula,Since Corbicula & Zebra Mussels Have Already Been Identified & Control & Treatment Plans Are Implemented ML20211P2871999-09-0909 September 1999 Proposed Tech Specs Pages,Increasing Present 100% Authorized Rated Thermal Power Level of 3579 Megawatts Thermal to 3758 Megawatts Thermal ML20210M7851999-08-0404 August 1999 Proposed Tech Specs 3.9.1,incorporating Addl Option Into Required Actions When Refueling Interlocks Are Inoperable ML20209B3391999-06-28028 June 1999 Simulator Four Yr Test Rept ML20196A2021999-06-17017 June 1999 Proposed Tech Specs SRs Implementing 24-month Operating Cycle at Pnpp ML20205C6351999-03-16016 March 1999 Preliminary Rev 0 to Wps 01-43-T-801, Preliminary Weld Procedure for Perry Nuclear Power Plant Feedwater Nozzle Repair ML20204E4971999-03-15015 March 1999 Proposed Tech Specs,Correcting Typos Found in Table 3.3.6.1-1 ML20207K1041999-03-0404 March 1999 Proposed Tech Specs Improving Licensing & Design Basis for Isolation of FW Penetrations ML20206Q3571999-01-0606 January 1999 Proposed Tech Specs Improving Licensing & Design Basis for Isolation of Feedwater Penetrations ML20195H5381998-11-18018 November 1998 Rev 4 to Pump & Valve Inservice Testing Program Plan ML20155D9431998-10-27027 October 1998 Proposed Tech Specs 2.1.1.2,applying Addl Conservatism by Modifying MCPR Safety Limit Values,As Calculated by GE ML20155D8241998-10-27027 October 1998 Proposed Tech Specs Adding Two Paragraphs to TS 5.2.2.e, Organization - Unit Staff ML20196H5131998-10-0808 October 1998 Rev 4,Vol 1 to Inservice Exam Program for Perry Nuclear Power Plant ML20151V4831998-09-0909 September 1998 Proposed Tech Specs Stipulating That Water Leakage from Feedwater motor-operated CIVs Will Be Added Into Primary Coolant Sources Outside of Containment Program & Check Valves Do Not Need to Be Included in Hydrostatic Program ML20151V1111998-09-0303 September 1998 Proposed Tech Specs Permitting EDG TS Action Completion Time of Up to 14 Days for Div 1 or 2 EDG & Allowing Performance of EDG 24-hour TS SR Test in Modes 1 & 2 ML20151V6861998-09-0303 September 1998 Proposed Tech Specs Increasing Present Div 3 DG Fuel Oil Level Requirements to Account for Rounding Error in Calculation & Unusable Volume Due to Vortex Formation at Eductor Nozzles Located in Fuel Oil Storage Tank PY-CEI-NRR-2395, Rev 5 to Perry NPP Odcm. with1998-09-0202 September 1998 Rev 5 to Perry NPP Odcm. with ML20151S9561998-08-31031 August 1998 Proposed Tech Specs,Allowing Blind Flange in Inclined Fuel Transfer Sys (Ifts) Containment Penetration to Be Removed While Primary Containment Is Required to Be Operable ML20236T7911998-07-22022 July 1998 Proposed Tech Specs Revising MSL Leakage Requirements & Eliminating Msli Valve Leakage Control Sys ML20151P1921998-07-13013 July 1998 Proposed Tech Specs,Increasing Present +/- 1% Tolerance on Safety Mode Lift Setpoint for SRVs to +/- 3% ML20236H8411998-06-30030 June 1998 Proposed Tech Specs,Increasing Boron Concentration in Standby Liquid Control Sys for Pnpp Cycle 8 Fuel Design & Providing Margin for Future Cycles as Required ML20236T8451998-06-24024 June 1998 Rev 3,Change 3 to Vol 1 of Inservice Examination Program, for Pnpp ML20216H9361998-04-14014 April 1998 Rev 1 to Proposed TS Bases,Reflecting Changes Made Since Original Implementation of TS in Improved Format in June 1996 ML20203G4781998-02-23023 February 1998 Maint Progress Review for Perry Nuclear Power Plant ML20197F7871997-12-23023 December 1997 Proposed Tech Specs,Revising 3.8.1 Re AC Sources to Be Consistent W/Recommendations in GL 94-01, Removal of Accelerated Testing & Special Reporting Requirements for Edgs ML20217K6501997-10-22022 October 1997 Proposed Tech Specs Incorporating Temp Control Valves & Associated Bypass Lines Around Emergency Closed Cooling Sys Heat Exchanger ML20217F5911997-10-0202 October 1997 Proposed Tech Specs,Adding Note to TS 2.1.1.2 Re MCPR SL Values & Adding Footnote to TS 5.6.5.b to Reference NRC SER That Approved MCPR SL Values for Cycle 7 ML20210T9631997-09-0808 September 1997 Proposed Tech Specs 5.2.2.e,removing Reference to NRC Policy Statement on Working Hours.Rev Allows Changes to Specific Overtime Limits & Working Hours to Be Evaluated IAW 10CFR50.59, Changes,Tests & Experiments ML20210U8701997-09-0808 September 1997 Rev 3,change 2 to Vol 1 of Inservice Exam Program, for Pnpp ML20217Q4591997-08-28028 August 1997 Proposed Tech Specs 3.4.11,revising Pressure-Temp Limits,Per Reactor Vessel Matl Surveillance Program Requirements Contained in App H of 10CFR50.90 ML20148A6871997-05-0202 May 1997 Proposed Tech Specs Re Surveillance Requirement for MSIV Leakage Rate Acceptance Criteria ML20148A6591997-05-0202 May 1997 Proposed Tech Specs,Revising Existing Exception to LCO 3.0.4 as Applies to LCO 3.6.1.9 for MSIV Leakage Control Sys ML20137S7761997-04-0909 April 1997 Proposed TS Requirements 3.9.1.1 & 3.9.2.2 Re Frequency on Refueling Equipment & one-rod-out Interlocks ML20134D8251997-01-31031 January 1997 Proposed Tech Specs 1.1 Re definitions,3.6.1.1 Re Primary Containment - operating,3.6.1.2 Re Primary Containment Air locks,3.6.1.3 Re PCIVs,3.6.5.1 Re Drywell & 5.5 Re Programs & Manuals ML20147B8271997-01-24024 January 1997 Rev 3 to Vol 1 of Inservice Exam Program ML20134D8751996-10-24024 October 1996 Proposed Tech Specs 2.1.1.2,safety Limits Applying Conservatism by Increasing MCPR Safety Limit Values ML20117E7891996-08-27027 August 1996 Proposed Tech Specs,Revising Mls Leakage Requirements & Eliminating MSIV Control Sys ML20108A2581996-04-26026 April 1996 Proposed Improved Tech Specs ML20100N9501996-03-0101 March 1996 Proposed TS Pages Re Drywell Leak Rate Testing Requirements ML20100L3331996-02-27027 February 1996 Proposed Tech Specs Re Drywell Personnel Air Lock Shield Door Analyses ML20100J5971996-02-24024 February 1996 Proposed Tech Specs,Revising Definition of Core Alteration ML20149K2221996-02-17017 February 1996 Proposed Tech Specs,Reflecting Mod of Leakage Rate Requirements for Main Steam Lines Until End of Operating Cycle 6 ML20100G0161996-02-0101 February 1996 Draft Rev 0 to Pnpp NUMARC/NESP-007 Plant-Specific EAL Guidelines ML20096D4651996-01-16016 January 1996 Proposed TS Requirements for Drywell Leak Rate Testing ML20096C0591996-01-10010 January 1996 Proposed Tech Specs,Requesting one-time Surveillance Interval Extension to Support Current Schedule for Refueling Outage 5,scheduled to Begin 960127 ML20095H4721995-12-20020 December 1995 Proposed Tech Specs Re Replacement of Selected Analog Leak Detection Sys Instruments W/Ge Numac Leak Detection Monitor ML20108B2851995-11-22022 November 1995 Rev 5 to Offsite Dose Calculation Manual ML20094F2051995-11-0202 November 1995 Proposed Tech Specs for Handling Irradiated Fuel in Containment or Fuel Handling Bldg & Performing Core Alterations ML20094E6751995-11-0202 November 1995 Proposed Tech Spec,Requesting Rev to TS for Onsite Power Distribution Sys:Ts 3/4.8.3.1, Distribution - Operation 1999-09-09
[Table view] |
Text
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,. Attachment 2 I
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PY-CEI/NRR-il40 L Page i of 4 1
3/4. 6.1 PRIMARY CONTAINMENT PRIMARY CONTAINMENT INTEGR!TY - SHlffDOWN LIMITING CONDITION FOR OPERATION l
3.6.1.1.2 PRIMARY CONTAINMENT INTEGRITY
- shall be maintained.8 APPLICABILITY:
, When irradiated fuel is being handled in the primary containment, and during li i
CORE ALTERATIONS, and operations with a potential for draining the reactor l L vessel. Under these conditions, the requirements of PRIMARY CONTAINMENT ,
INTEGRITY do not apply to normal operation of the inclined fuel transfer !
system. i l ACTION:
L l Without. PRIMARY CONTAINMENT INTEGRITY, suspend handling of irradiated fuel in l= the primary containment, CORE ALTERATIONS, and operations with a potential for draining the reactor vessel.
SURVEILLANCE REQUIREMENTS l 4. 6.1.1. 2 PRIMARY CONTAINMENT INTEGRITY shall be demonstrated:
l
- a. At least once per 31 days by verifying that all primary containment penetrations not capable of being closed by OPERABLE primary contain-ment automatic isolation valves and required to be closed during accident conditions are closed by valves, blind flanges, or deacti- -
) vated automatic valves secured in position, .except as provided in l
Table 3.6.41 of Specification 3.6.4.#
- b. By verifying each primary containment air lock is in compliance with the requirements of Specification 3.6.1.3.
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<NS gga- *The primary contaissent leakage rates in accordance with Specification 3.6.1.2 go are not applicable.
a$
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, Excep6 R.:* wJ 3/4" vent and drain line patW may be opened fi?.he co o surpose of perfom., i
$8 primary containment to g g Q { leak rate rential pressure testing arovided is ::.ain-
-e :ained within the limit is in effect for i i ,-
- t N :he first refueling outage only.
ott 4
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& Q. R.
PERRY - UNIT 1 3/46-2 Amendment No. 19
Attachment 2
'.i" ' ' PY-CEI/NRR-l140 L Page 2 of 4 3.4.6 CONTAINMENT SYSTEMS i(n.
l
. LUi BASES 3/4.6.1 CONTAINMENT 3/4.6.1.1 " PRIMARY CONTAINMENT INTEGRITY L PRIMARY CONTAINMENT INTEGRITY ensures that the release of radioactive materials from the containment atmosphere will be restricted to those leakage paths and associated leak rates assumed in the accident analyses. This restriction, in conjunction with the leakage rate limitation, will limit the site boundary radiation doses to within the limits of 10 CFR Part 100 during g accident conditions, g During shutdown when irradiated fuel is being handled in the primary / ,
con ent, and-dut ^%E ALTERATIONS and operations with a potential for I draining eacte % # footnote pennits the opening of two vent and drain line valve leak rate surve 7 m of *-4te performing containment isolation doses have been calculated for the postulated-fuel handlin rv contaia=*at $55u=ia9 a 100 cfm flowrate through the open e*[
two vent / drain pathways could be open w 4 ws.. Although more than in the bounds of the
- o avoid the need for 1
l I
analysis, the number of open pathways was 11m l constant monitoring of the containment pressure th .dministrative controls.
By adding the requirement to periodically check primary irunent to secondary containment differential pressure while the 3/4" vent / drain pa s are open, l
! . (*
l there is assurance that sufficient primary containment to outside a ere ,
l differential pressure does not exist to create a 100 cfm flow through the l vent / drain pathways. s 3/4.6.1.2 CONTAINMENT LEAKAGE The limitations on containment leakage rates ensure that the total contain-ment leakage volume will not exceed the value assumed in the accident analyses (
at the peak accident pressure of 11.31 psig, Pa. As an added conservatism, the j measured overall integrated leakage rate is further limited to less than or i equal to 0.75 La during perfonnance of the periodic tests to account for possible degradation of the containment leakage barriers between leakage tests.
i l Overall integrated leakage rate means the leakage rate which obtains from l a sunenation of leakage through all potential leakage paths. Where a leakage l- path contains more than one valve, fitting, or component in series, the leakage j for that path will be that leakage of the worst leaking valve, fitting, or
! component and not the sununation of the leakage of all valves, fittings, or l' components in that leakage path.
i
- Operating experience with the main steam line isolation valves has indicated that degradation has occasionally occurred in the
' of the valves; therefore the special requirement for testing, theseleak tightness valves.
I PERRY - UNIT 1 B 3/4 6-1 Amendment No.19 ll 1
c t'
Attachment 2 PY-CEI/NRR-1140 L
.,7 Page 3 of 4
. CONTAINMENT SYSTEMS "Uh BASES 3/4.6.1.6 CONTAINMENT INTERNAL PRESSURE l The limitations on primary centainment to secondary containment differential pressure ensure that the primary containment peak pressure of 11.31 psig does not exceed the design pressure of 15.0 psig during LOCA conditions or that the external pressure differential-does not exceed the design maximum external pressure differential of +0.8 psid. The limit of
-0.1 to +1.0 psid for initial positive primary containment to secondt.ry containment pressure will limit the primary containment pressure to 11.31 M psid which is 'less than the design pressure and is consistent with the hpWdMA safety analysis. 02-4 g c're' 4 g :^-di tc i r this d4"e e-t e' - et e e i >
4, 4 . .a m. -- 4 - ,raa .-_.a_.4. . . , . . . , .. - - _ , - __ 3 . u ....
&ne+4mn ne ?ne =4e 1 { * (Jas* a 1 1 *^ f-
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S cr i'i c: t -- ?/ ^ E ' '
i 3/4.6.1.7 CONTAINMENT AVERAGE AIR TEMPERATURE i=
1 The limitation on containment average air temperature ensures that i the containment peak air temperature does not exceed ~the design temperature of 185'F during LOCA conditions and is consistent with the safety analysis, e' 3/4.6.1.8 DRYWELL AND CONTAINMENT PURGE SYSTEM
-(
The use of the drywell and containment purge lines is restricted to the 42-inch outboard and 18-inch purge supply and exhaust isolation valves. These valves will close during a LOCA or steam line break accident and therefore the site boundary dose guidelines of 10 CFR Part 100 would not be exceeded in'the event of. an accident during purging operations. The term sealed closed as i
used in this context means that the valve is' secured in its closed position t by deactivating the valve motor operator, and does not pertain to injecting seal water between the isolation valves by a seal water system.
l i
=sp
.)
PERRY - Unit i B 3/4 6-2a Anendment No.19 , l (Next page is B 3/4 6-3)
g
- Attech::nt 2 PY-CEI/NRR-1140 L Page 4 of 4 ,
Insert 1
- Except that six (6) 3/4" vent and drain line pathways may be opened for the purpose of performing containment isolation valve leak rate testing provided the plant has been suberitical for at least seven (7) days.
Insert 2
-During shutdown when irradiated fuel is being handled in the primary containment, and during CORE ALTERATIONS and operations with a potential for.
draining the reactor vessel, the # footnote permits the opening of six vent and-drain pathways for the purpose of performing containment isolation valve leak rate surveillance testing provided the reactor has been suberitical for at least seven days. Offsite doses vere calculated assuming the postulated fuel handling accident inside primary containment after a seven day decay time, and assuming all the airborne activity existing inside containment after the accident is immediately discharged directly to the environment (i.e. no containment). Although this analysis vould indicate that no restriction on the number of vent and drain pathways was required, the number of open pathways was restricted to six for van:;ervatism. i NJC/ CODED /3209