Text

Proposed Tech Specs 3/4.6.5 Re Secondary Containment & 4.6.5.1.1 Re Surveillance Requirements
	ML20128N776
Person / Time
Site:	Limerick
Issue date:	09/27/1996
From:	; PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	;
Shared Package
ML20128N759	List: ML20128N755; ML20128N776;
References
	NUDOCS 9610170038
	Download: ML20128N776 (11)
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ATTACHMENT 2 LIMERICK GENERATING STATION UNITS 1 AND 2 Docket Nos, l

50-352 50-353 License Nos.

NPF-39 ;

NPF-85 l TECHNICAL SPECIFICATIONS CHANGE REQUEST ,

NO. 96-07-0 l AFFECTED PAGES UNIT 1 UNIT 2 3/4 6-46 3/4 6-46 3/4 6-53 3/4 6-53 3/4 6-54 3/4 6-54 B3/46-5 B3/46-5 B 3/4 6-6 B3/46-6 l

9610170039 960927 PDR ADOCK 05000352 P PDR j

, CONTAINMENT SYSTEMS

' 3/4.6.% SECONDARY CONTAINMENT

! REACTOR ENCLOSURE SECONDARY CONTAINMENT INTEGRITY j LIMITING CONDITION FOR OPERATION

3.6.5.1.1 REACTOR ENCLOSURE SECONDARY CONTAINMENT INTEGRITY shall be maintained.

' APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, and 3.

ACTION

i Without REACTOR ENCLOSURE SECONDARY CONTAINMENT INTEGRITY, restore REACTOR

ENCLOSURE SECONDARY CONTAllMENT INTEGRITY within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or be in at least HOT

! SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 24 l

hours, t

SURVEILLANCE REQUIREMENTS l

4.6.5.1.1 REACTOR ENCLOSURE SECONDARY CONTAINMENT INTEGRITY shall be demon-l strated by:

I

a. Verifying at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months that the pressure wit.hin the reactor enclosure secondary containment is greater than or equal to 0.25 inch of vacuum water gauge.

) b. Verifying at least once per 31 days that:

! 1. All reactor enclosure secondary containment equipment hatches and '

blowout panels are closed and sealed.

u

. 2. At least one door in each access to the reactor enclosure secondary containment is closed.

l.

1

3. All reactor enclosure secondary containment penetrations not

, capable of being closed by OPERABLE secondary containment auto-

. matic isolation dampers / valves and required to be closed during

. accident conditions are closed by valves, blind flanges, slide gate dampers or deactivated automatic dampers / valves secured in position.

j c. At least once per 24 months:

1. Verifying that one standby gas treatment subsystem will draw down i the reactor enclosure secondary containment to greater than or iu

? 1 to 0.25 inch of vacuum water gauge in less than or equal to J AI i

Cy(, seconds with the reactor enclosure recirc system in operation l[C VO

'd i

2. Operating one standby gas treatment subsystem for one hour and

maintaining greater than or equal to 0.25 inch of vacuum water

! gauge in the react osure secondary containment at a flow rate not exceeding measured on the wi fa with wind speeds of 5 7.0 mph as trument on Tower 1 elevation 30' or, aM Icrr-if that instrument is unavailable, Tower 2,, elevation 159'. g5 Su

{ EM i

. LIMERICK UNIT 1 3/4 6-46 Amendment No. 8,7f,106

~

} FEB 121996

9,,7 CONTAINMENT SYSTEMS ,

l SURVEILLANCE RE0VIREMENTS (Continued)

b. At least once per 24* months or (1) after any structural maintenance l on the HEPA filter or charcoal adsorber housings, or (2) following painting, fire, or chemical release in any ventilation zone comunicating with the subsystem by:

1. Verifying that the subsystem satisfies the in-place penetration and bypass leakage testing acceptance criteria of less than 0.05%

and uses the test procedure guidance in Regulatory Positions C.5.a, i l C.S.c and C.5.d of Regulato uide 1.52, Revision 2, March 1978, @c l and the system flow rate i 4000: fm

10%.

5764 DO

2. Verifying within 31 days after removal that a laboratory analysis of a representative carbon sample obtained in acecrdance with l Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978, for a methyl iodide penetration of less than 0.175%; and

3. Verify that when the fan is running the subsystem flowrate is 2800 cfm minimum from each reactor enclosure (Zones I and II) and 2200 cfm minimum from the refueling area (Zone III) when tested in accordance with ANSI H510-1980.

4. Verify 'that the pressure drop across the refueling area to SGTS prefilter is less than 0.25 inches water gage while operating at a flow rate of 2400 cfm

10%.

c. After every 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months of charcoal adsorber operation by verify"-

within 31 days after removal that a laboratory analysis of a repre-sentative carbon sample obtained in accordance with Regulatory Pesition C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria. of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978, for a methyl iodide penetration of less than 0.175%.

d. At least once per 24 months by: l

1. Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 9.1 inches water gauge while operating the filter train at a flow rate of 8400 cfm 10%.

Surveillance interval is an exception to the guidance provided in Regulatory Guide 1.52, Revision 2, March 1978.

JUL 281934

> %t No. 6, 33, 71 LIMERICK - UNIT 1 3/4 6-53

CONTAINMENT SY3TEMS l 'SURVEf ttANCE REOUIREMENTS (Continued)

I

' 2. Verifying that the fan starts and isolation valves necessary to-j draw a suction from the refueling area or the reactor enclosure recirculation discharge open on each of the following test signals:

a) Manual initiation from the control room, and t

b) Simulated autcmatic initiation signal.

3. Verifying that the temperature differential across each heater is 2: 15'F when tested in accordance with ANSI N510-1980.

i; e. After each complete or paitial replacement of a HEPA filter bank by verifying that the HEPA filter bank satisfies the inplace penetration and leakage testing acceptance criteria of less than 0.05% in accordan ith ANSI N510-1980 while operating the system at a flow rate o fm 2 10%. '

- it

[ f. After each complete or partial replacement of a charcoal adsorber i 4

bank by verifying that the charcoal adsorber bank satisfies the inplace penetration and leakage testing acceptance criteria of less than 0.05% g' in accordance with ANSI N510-1980 for a halogenated hydrocarbon a t t st gas while operating the system at a flow rate of C

g. After any major system alteration:

1.

' Verify that when the SGTS fan is running the subsystem flowrate is 2800 cfm minimum from each reactor enclosure IZones I and II) and 2200 cfm minimum from the refueling area ie III). l l

2. Verify that one standby gas treatment subsystem will drawdown reactor enclosure Zone I secondary containment to greater than

. or equal 0.25 inch of vacuum water gauge in less than or g!

i equal t j seconds with the reactor enclosure recirculation system operation and the adjacent reactor enclosure and refue ng area zones are in their isolation modes. {li j

ol si 21 9%

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LIMERICK - UNIT 1 3/4 6-54 Amendment No. # ,106 j

FEB 1 i5

I

, CONTAINMENT SYSTEMS

BASES 3/ .5 SECONDARY CONTAINMENT i Secondary containment is designed to minimize any ground level release of radioactive material which may result from an accident. The Reactor Enclosure i

and associated structures provide secondary containment during normal operation when the drywell is sealed and in service. At other times the drywell may be

! open and, when required, secondary containment integrity is specified.

4 Establishing and maintaining a vacuum in the reactor enclosure secondary 1 containment with the standby gas treatment system once per 24 months, along with

] the surveillance of the doors, hatches, dampers and valves, is adequate to ensure

that there are no violations of the integrity of the secondary containment.

The OPERABILITY of the reactor enclosure recirculation system and the standby gas treatment systems ensures that sufficient iodine removal capability will be available in the event of a LOCA or refueling accident (SGTS only). The reduction in containment iodine inventory reduces the resulting SITE BOUNDARY radiation doses associated with containment leakage. The operation of this system and resultant iodine removal capacity are consistent with the assumptions used in the LOCA and refueling accident analyses. Provisions have been made to continuously purge the filter plenums with instrument air when the filters are not in use to prevent buildup of moisture o he adsorbers and the HEPA filters. c Mo ab Although the safety analyses as a the reactor enclosure secondary C containment draw down time will ta MD econds, these surveillance require- O i ments specify a draw down time o seconds. This 14 second difference is 8 l

due to the diesel generator startin part of this surveillance requirement. g nd se uence loading delays which is not 8 l g

The reactor enclosure secondary containment draw down time analyses assumes d l

a starting point of 0.25 inch of vacuum water gauge and worst case SGTS dirty l filter flow rate of 2800 cfm. The surveillance requirements satisfy this as-sumption by starting the drawdown from ambient conditions and connecting the adjacent reactor enclosure and refueling area to the SGTS to split the exhaust flow between-the three zones and verifying a minimum flow rate of 2800 cfm from the test zone. This simulates the worst case flow alignment and verifies ade-quate flow is available to drawdown the test zone within the required time.

The Technical Specification Surveillance Requirement 4.6.5.3.b.3 is intended to be a multi-zone air balance verification without isolating any test zone.

The SGTS fans are sized for three zones and therefore, when aligned to a single zone or two zones, will have excess capacity to more quickly drawdown the affected zones. There is no maximum flow limit to individual zones or i pairs of zones and the air balance and drawdown time are verified when all l three zones are connected to the SGTS.

The three zone air balance verification and drawdown test will be done [o after any major system alteration, which is any modification which will have r-an effect on the SGTS flowrate such that the ability of the SGTS to drawdown o* l the reactor enclosure to great an or equal to 0.25 inch of vacuum water gage in less than or equal to econds could be affected. l$

9 g 5

LIMERICK - UNIT 1 B 3/4 6-5 Amendment No. 6,H ,7f,106 fEB121996

' i The icke<ab acake er (med

.5 O Mo ihe <pn 9 kM\ be N5

= -

uT a Ve t of i knSe o i

CONTAINMENT SYSTEMS}'s% pQgvi gudegge, fjHmnog, !

BASES 3/4.6.5 SECONDARY CONTAINMENT (Continued) bb !

l The field tests for bypass leakage across th W <

l SMi2IN"28 agperformed Ka, gow rate o _

charcoal dsorber_and 33 c_fm_. , ;,,

- Q {

g wmm-t .

m x __ m _

l The SGTS filter train pressure drop is a function of air flow rate and g l

! filter conditions. Surveillance testing is performed usin either the SGTS or j drywell purge fans to provide operating convenience. ;

g !

! Each reactor enclosure secondary containeen ne and re unling area i i

' secondary containment zone is tested i tly to verify the design leak 'C-b -

tightness. A design leak tightness of cfm or less for each reactor wC enclosure and 764 cfm or less for the re ualing area at a 0.25 inch of vacuum MC water gage will ensure that containment integrity is maintained at an acceptable level if all zones are connected to the SGTS at the same time.

The Reactor Enclosure Secondary Containment Automatic Isolation Valves and Refueling Area Secondary Containment Automatic Is ation Valves can be found in the UFSAR.

g The post-LOCA offsite dose analysis ass reactor enclosure secondary containment post-draw down leakage rate of 4000 cfm and certain post-accident 1 e-X/Q values. While the post-accident X/Q va ues represent a statistical inter- oc pretation of historical meteorological data, the highest ground level wind M speed which can be associated with these values is 7 mph (Pasquill-Gifford stability Class G for a ground level release). Therefore, the surveillance requirement assures that the reactor enclosure secondary containment is verified under meteorological conditions consistent with the assumptions utilized in the design basis analysis. Reactor Enclosure Secondary Containment leakage tests that are successfully performed at wind speeds in excess of 7 aph would also satisfy the leak rate surveillance requirements, since it shows compliance with more conservative test conditions.

3/4.6.6 PRIMARY CONTAINMENT ATMOSPHERE CONTROL The OPERABILITY of the systems required for the detection and control of hydrogen combustible mixtures of hydrogen and oxygen ensures that these systems will be available to maintain the hydrogen concentration within the primary containment below the lower flammability limit during post-LOCA conditions.

The primary containment hydrogen recombiner is provided to maintain the oxygen concentration below the lower flassability limit. The combustible gas analyzer is provided to continuously monitor, both during normal operations and post-LOCA, the hydrogen and oxygen concentrations in the primary containment. The primary containment atmospheric mixing system is provided to ensure adequate mixing of the containment atmosphere to prevent localized accumulations of hydrogen and oxygen from exceeding the lower flannability limit. The hydrogen control system is consistent with the recommendations of Regulatory Guide 1.7, " Control of Combustible Gas Concentrations in Containment Following a LOCA," March 1971.

'r . .

DE.C 2 010J95 LIMERICK - UNIT 1 B 3/4 6-6 Amendment No. 8,105

CONTAINMENT SYSTEMS 3/4.6.5 SECONDARY CONTAINMENT REACTOR ENCLOSURE SECONDARY CONTAINMENT INTEGRITY

~

LIMITING CONDITION FOR OPERATION i 3.6.5.1.1 REACTOR ENCLOSURE SECONDARY Cor.'TAINMENT INTEGRITY shall be maintained.

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, and 3.

ACTION:

4 Without REACTOR ENCLOSURE SECONDARY CONTAINMENT INTEGRITY, restore REACTOR i 1

' ENCLOSURE SECONDARY CONTAINMENT INTEGRITY within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or be in at least HOT I SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 24 i j hours.

SURVEILLANCE RE0VIREMENTS 5

! 4.6.5.1.1 REACTOR ENCLOSURE SECONDARY CONTAINMENT INTEGRITY shall be demon-strated by:

\

i a. Verifying at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months that the pressure within the !

j reactor enclosure secondary containment is greater than or equal ;

to 0.25 inch of vacuum water gauge.

i i b. Verifying at least once per 31 days that: I f 1 1.

4 All reactor enclosure secondary containment equipment hatches and

blowout panels are closed and sealed.

2.- At least one door in each access to the reactor enclosure secondary containment is closed, l

3. All reactor enclosure secondary containment penetrations not capable of being closed by OPERABLE secondary containment auto-matic isolation dampers / valves and required to be closed during accident conditions are closed by valves, blind flanges slide gate dampers or deactivated automatic dampers / valves sec,ured in position.

c. At least once per 24 months: @

1. Verifying that one standby gas treatment subsystem will draw down N the reactor enclosure secondary containment to greater than or 6 -

al to 0.25 inch of vacuum water gauge in less than or equal to $

seconds with the reactor enclosure recirc system in operation,

2. Operating one standby gas treatment subsystem for one hour and maintaining greater than or equal to 0.25 inch of vacuum water gauge in the react closure secondary containment at a flow rate not exceedin fm with wind speeds of s 7.0 mph as measured on the wi trument on Tower 1, elevation 30' or, af le *D if that instrument unavailab!c, Tower 2, elevation 159'.

zsm LIMERICK - UNIT 2 3/4 6-46 Amendment No. M , 51 FEB 1 61995

'~ ~ ~ -

CONTAINMENT SYSTEMS ~~~ ~ ~ ~~ J ~~- 7--

SURVElllANCE RE00?REMENTS (Continued) -

b. At least once per 24* months or (1) after any structural maintenance l on the HEPA filter or charcoal adsorber housings, or (2) following painting, fire, or chemical release in any ventilation zone consnunicating with the subsystem by:

1. Verifying that the subsystem satisfies the in-place penetration m and bypass leakage testing acceptance criteria of less than 0.05% f and uses the test procedure guidance in Regulatory Positions C.S.a. g C.5.c and C.5.d of Regulator uide 1.52, Revision 2 March 1978, .

and the system flow rate i Efm

10%.

2. -Verifying vtthin 311ays after removal that a laboratory-analysis y of a representative carbon sample obtained in accordance with Regulatory Position C.6.D of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978, for a methyl iodide penetration of_less than 0.175%; and

3. Verify that when the fan is running the subsystem flowrate is 2800 cfm minimum from each reactor enclosure (Zones I and II) and 2200 cfm minimum from the refueling area (Zone III) when tested in accordance with ANSI N510-1980.

4. Verify that the pressure drop across the iefueling area to SGTS prefilter is less than 0.25 inches water gage while operating at a flow rate of 2400 cfm

10%.

c. After every 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months of charcoal adsorber operation by verifying within 31 days after removal that a laboratory analysis of a repre-sentative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978, for a methyl iodide penetration of less than 0.175%.

d. At least once per 24 months by: l

. 1. Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 9.1 inches water gauge while operating the filter train at a flow rate of 8400 cfm

10%.

Surveillance interval is an exception to the guidance provided in Regulatory Guide 1.52, Revision 2, March 1978.

Jul 2 819N LIMERICK . UNIT 2 3/4 6-53 Wmant No. 34

CONIAINMENT SYSTEMS SURVEILLANCE RE0VIREMENTS (Coitinued)

2. terifying t1at the fan starts ano isolation valves necessary to draw a suction from the refueling area or the reactor enclosure recirculation discharge open on each of the following test signals:

~

a) Manual initiation from the control room, and b) Simulated automatic initiation signal.

i

3. Verifying that the temperature differential across each heater

is 2 15'F when tested in accordance with ANSI N510-1980, i

e. After each complete or partial replacement of a HEPA filter bank by verifying that the HEPA filter bank satisfies the inplace penetration and leakage testing acceptance criteria of less than 0.05% in accorda ith ANSI H510-1980 while operating the system at a flow lm rate o fm 2 10%.

[@

l f.

~

After each complete or partial replacement of a charcoal adsorber oe i bank by verifying that the charcoal adsorber bank satisfies the inplace g' i

$M penetration and leakage testing acceptance criteria of less than 0.05%

in accordance with ANSI H510-1980 for a halogenated hydrocarbon g, i igerant test gas while operating the system at a flow rate of u <

! fm 10%. W

g. After any major system alteration:

i

! 1. Verify that when the SGTS fan is running the subsystem flowrate .

i is 2800 cfm minimum from each reactor enclosure (Zones I and II) and 2200 cfm minimum from the refueling area (Zone III). i 4

2. Verify that one standby gas treatment subsystem will drawdown W !

reactor enclosure Zone II secondary containment to greater than O l I or equal t .25 inch of vacuum water gauge in less than or C i equal t seconds with the reactor enclosure recirculation 9i

system o eration and the adjacent reactor enclosure and y

} refuel ng area zones are in their isolation modes. l cf '

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1 l

4 1-j .

1

j. LIMERICK - UNIT 2 3/4 6-54

e * =nt No. 51 4

j FEB 161995 4

t

w e a CONTAINMENT SYSTEMS

.k B NS ,

3/4.6.5 SECONDARY CONTAINMENT Secondary containment is designed to minimize any ground level release of radioactive material which may result from an accident. The Reactor Enclosure and associated structures provide secondary containment during nomal operation when the drywell is sealed and in service. At other times the drywell may be j open and, when required, secondary containment integrity is specified.

Establishing and maintaining a vacuum in the reactor enclosure secondary I containment with the standby gas treatment system once per 24 months, along with the surveillance of the coors, hatches, dampers and valves, is adequate to ensure i

that there are no violations of the integrity of the secondary containment.

t The OPERABILITY of the reactor enclosure recirculation system and the standby i gas treatment systems ensures that sufficient iodine removal capability will i

, be available in the event of a LOCA or refueling accident (SGTS only). The

reduction in containment iodine inventory reduces the resulting SITE BOUNDARY 1 radiation doses associated with containment leakage. The operation of this

. system and resultant iodine removal capacity are consistent with the assumptions i used in the LOCA and refueling accident analyses. Provisions have been made to continuously purge the filter plenums with instrument air when the filters are .

not in use to prevent buildup of moisture on the ers and the HEPA filters.

1 Although the safety analyses assume at the reactor enclosure secondary C l containment draw down time will tak seconds, these surveillance require- O ments specify a draw down time of econds. This 14 second difference is i j due to the diesel generator startin nd sequence loading delays which is not e i part of this surveillance requirement, g j The reactor enclosure secondary containment draw down time analyses assumes W a starting point of 0.25 inch of vacuum water gauge and worst case SGTS dirty filter flow rate of 2800 cfm. The surveillance requirements satisfy this as-

sumption by starting the drawdown from ambient conditions and connecting the adjacent reactor enclosure and refueling area to the SCTS to split the exhaust flow between the three zones and verifying a minimum flow rate of 2800 cfm from

the test zone. This simulates the worst case flow alignment and verifies ade-i quate flow is available to drawdown the test zone within the required time.

1 The Technical Specification Surveillance Requirement 4.6.5.3.b.3 is intended

to be a multi-zone air balance verification without isolating any test zone.

l The SGTS is common to Unit I and 2 and consists of two independent i

subsystems. The power supplies for the comon portions of the subsystems are

, from Unit I safeguard busses, therefore the inoperability of these Unit 1 i supplies are addressed in the SGTS ACTION statements in order to ensure adequate ,

j onsite power sources to SGTS for its Unit 2 function during a loss of offsite l 2

power event. The allowable out of service times are consistent with those in the Unit 1 Technical Specifications for SGTS and AC electrical power supply out

of service condition combinations.

i l

LIMERICK - UNIT 2 B 3/4 6-5 An=aht No. M, 51 FEB 1 61995 l

4

CONTAINMENT SYSTEMS BASES SECONDARY CONTAINMENT (Continued) single zone or two zones, will have excess capacity to more the affected zones.

pairs of zones and the air balance and drawdown time are verified three zones are connected to the SGTS.

after any major system alteration, which is any modification ey w

an effeet the reactoron the SGTS enclosure flowrate such that the ability of the SGTS to drr.vdown to greate -

gage in less than or equal t than or equal to 0.25 inch of vacuum water .3 ' (

ig econds could be a'ffected. g HEPAThe filterfield ankstests for bypass eakage across the GTS charcoa are performed sorber and 3L a_flowgf y4o 1

33~ry - , _ _-

-. l@

i . p. I a filter conditions.The SGTS filter train pressure drop is a function of air flow rate and drywell purge fans to provide operating convenience. Surveillance testing is perf

! Each reactor enclosure secondary containme l

secondary containment zone is tested ind zone and refueling area !

To tightness. A design leak tightness of i.ly to verify the design leak "m or less for each reactor $C WO

' enclosure and 764 cfm or less for the re ing area at a 0.25 inch of vacuum water gage will ensure that containment integrity is maintained at an acceptable >

level if all zones are connected to the SGTS at the same time.

The Reactor Enclosure Secondary Containment Automatic Isolation Valves and Refueling found in the UFSAR.

Area Secondary Containment Automatic Isolation Valves can be Ti e post-LOCA offsite dose analysis. assu containment a reactor enclosure seconriary dO X/Q values. post-draw down leakage rate of( cfm and certain post-accident While the post-accident X/Q va s represent a statistical inter- d pretation of historical meteorological data, the highest ground level wind spied which can be associated with these values is 7 mph (Pasquill-Gifford stability Class G for a ground level release). Therefore, the surveillance requirement assures that the reactor enclosure secondary containment is verified designmeteorological under basis analysis. conditions consistent with the assumptions. utilized in the that are successfully performed at wind speeds in excess of 7 mph wou satisfy the leak rate surveillance requirements, since it shows compliance with more conservative test conditions.

F(hmeck 00

%e scers don k\e4 wdl De-teh.d d a veicet of a gx had g $ gh Me9tO9MR TI M

vf DEC 2 01995 LIMERICK - UNIT 2 B 3/4 6-6 Amendment No. 51, 69

ML20128N776

Text

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