ML20138A913

Proposed Tech Specs,Withdrawing Petition to Implement Option B Performance Based Requirements to App J of 10CFR50

ML20138A913
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	04/22/1997
From:	CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML20138A904	List: ML20138A899 ML20138A906 ML20138A913
References
NUDOCS 9704280283
Download: ML20138A913 (15)

Text

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I ATTACHNENT 1 i

i CONSUMERS ENERGY COMPANY BIG ROCK POINT PLANT DOCKET 50-155 As Proposed r

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l 9704290283 970422 PDR ADOCK 05000155 6 Pages p

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6.1.3 Reactor Safety System Bypass The following tabulation gives the permissive functional conditions during which certain-reactor safety system sensors are bypassed by the reactor safety system mode selector switch. A keylock reactor mode switch shall be provided having " Shutdown," " Refuel," " Bypass Dump Tank" and "Run" positions.

l These positions shall have the following. functions:

Mode Selector Switch Position Trio Function Bvoassed Run None *)

I Bypass Dump Tank ")

Low Steam Drum Water Level I

Recirculation Waterline Valves Closed Steam Line Backup Isolation Valve Closed High Water Level in Scram Dump Tank (b)

High Condenser Pressure Refuel (d)

Low Steam Drum Water Level Recirculation Waterline Valves Closed Steam Line Backup Isolation Valve Closed High condenser Pressure 5

Shutdown Low Steam Drum Water Level"

/

Steam Line Backup Isolation Valve

/

Closed

/

High Condenser Pressure

/

Recirculation Waterline Valves Closed

/

(a) Control rod withdrawal is prevented by interlock while switch is in this mode position.

(b) Bypass of this trip function is necessary to enable emptying the -

dump tank after a scram.

(c)With the mode switch in the " shutdown" position, both the scram circuit and the control rod withdrawal circuit are open.

The ventilating duct circuit power supply is transferred to a point which provides penetration closure protection through signals from "high containment sphere pressure" and " low water level in reactor vessel."

This permits normal ventilation in the containment sphere during shutdown when the control rods are held in the full-in position.

(d)With the mode switch in the refuel position and the crane positioned over the reactor vessel, crane operation is prevented if any one rod

.is withdrawn from full-in position.

I')High condenser pressure reactor trip i:, automatically bypassed any time steam drum pressure is below a set point maximum of 500 psig.

54 As Proposed

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(

4.1.2 (Contd)

]

i is above 300 psig. The shutdown cooling system shall be OPERABLE and ready for service during REFUELING OPERATIONS and the breakers for M0-7070 and M0-7071 shall be tagged "open".

The primary coolant shall be sampled and ant: tyred daily during pert,ds of POWER OPERATION.

The followint 3re absoluta lini n which if exceeded 1

shall necessitate reactor U:UTDOWF. Corrective action will necessarily be taken at mrre stringent limits to minimize the possibility of these ab elute limits ever being reached.

i Conductivity (Micromho/cm)

Maximum

')

Maximum Transient

• 10 j

pH (Lower and Upper Limits) 4.0 and 10.0 Chloride Ion (ppm) 1.0

/

Boron (ppm) 100

/

j Isotopic analysis of the primary coolant to determine the DOSE EQUIVALENT I-131 concentration shall be performed at least every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> during periods of operation.

1.

If the DOSE EQUIVALENT I-131 concentration excaeds 0.2 pCi/ml and is less than or equal to 4.0 yC1/ml, isotopic analysis to determine DOSE EQUIVALENT I-131 shall be performed every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> until the activity is less than 0.2 pCi/ml.

2.

If the DOSE EQUIVALENT I-131 exceeds 4.0 pCi/m1, the plant.

shall be placed in a SHUTDOWN condition with the main steam isolation valve closed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

(c)

Leakaae limits 1.

If the primary coolcnt system leakage exceeds 1 gpm and the source of leakage is not identified, the reactor shall be SHUTDOWN as described in Section 1.2.5(a) within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, and cooldown to a COLD SHUTDOWN condition shall be initiated within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

2.

If leakage from the primary ccolant system exceeds 10 gpm, the reactor shall be SHUTDOWN as described in Section 1.2.5(a) within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, and cooldown t> a COLD SHUTDOWN condition shall be initiated within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

• Conductivity is expected to increase temporarily after startups from cold shutdown. The maximum transient value here stated is the maximum permissible and applies only to the period subsequent to a cold shutdown between criticality and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after reaching 20% rated power.

23 As Proposed

l L. * ' ' %

ADMINISTRATIVE CONTROLS l

I 6.9.2.2.A (Contd) 3.

Solid Waste The Radioactive Effluent Release Reports shall include the following information for each class of solid waste (as defined a

by 10 CFR Part 61) shipped offsite during the report period:

a.

Container burial volume, b.

Total curie quantity (specify whether determined by l

measurement or estimate),

j c.

Principal radionuclides (specify whether determined by measurement or estimate),

d.

Source of waste and processing employed (e.g., dewatered i

spent resin, compacted dry waste, evaporator bottoms),

i e.

Type of container (e.g., LSA, Type A, Type B, Large Quantity),and f

f.

Solidification agent or absorbent (e.g., cement, asphalt).

I 4.

Radiological Impact on Man The Radioactive Effluent Release Report shall include

/

potential doses to individuals and populations calculated

/

using measured effluent and averaged meteorological data in /

accordance with the methodologies in the Offsite Dose

/

Calculation Manual.

/

^

a. Total body and significant organ doses (greater than 1 millirem) to individuals in unrestricted areas from receiving water-related exposure pathways.

b. The maximum offsite air doses (greater than 1 millirad)*

due to beta and ganna radiation at locations near ground level from gaseous effluents.

I

c. Organ doses (greater than 1 millirem) to individuals in unrestricted areas from radioactive iodine and radioactive material in particulate form from the major pathways of exposure.

d. Total body doses (greater than 1 manRem) to the population and average doses (greater than 1 millirem) to individuals in the population from receiving water-related pathways to a distance of 50 miles from 4

the site.

86 As Proposed

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AQtilNISTRATIVE CONTROLS 6.12.1-(Contd) c.

A radiation protection qualified individual (e.g., liealth Physics Technician) with a radiation dose rate monitoring device, who is responsible for providing positive control over the activities within the area, and shall perform periodic radiation surveillance as specified by the Radiation Protection Supervisor in the RWP.

/

6.12.2 In addition to the requirements of Specification 6.12.1, areas accessible to personnel with radiation levels greater than 1000 mres/h at 30 cm (12 inches) but less than 500 rad /h at 1 meter from the radiation source or from any surface from which the radiation

/

penetrates shall be provided with locked doors to prevent unauthorized entry, and the keys shall be maintained under the administrative control of the Shift Supervisor on duty and/or health physics supervision. Doors shall remain locked except during periods of access by personnel under i

an approved RWP which sha.11 specify the dose rate levels in the imediate work areas and the maximum allowable stay time for individuals in that area.

In lieu of the stay time specification of the RWP, direct or remote (such as closed circuit TV cameras) continuous surveillance may be made by personnel qualified in radiation i

protection procedures to provide positive exposure control over the activities being performed within the area.

For individual high radiation areas accessible to personnel with radiation levels of greater than 1000 mR/h that are located within large areas where no enclosure exists for purposes of locking, and no enclosure can be reasonably constructed around the individual areas, then that individual area shall be barrir.aded, conspicuously posted, and a flashing light shall 1

be activated as a warning device.

6.13 ENVIRONMENTAi OVALIFICATION 2

(Deletod) 6.14 PROCESS CONTROL PROGRAM (PCP) 6.14.1 Changes to the PCP shall be submitted to the Commission in the Radioactive Effluent Release Re) ort for the period in which the change (s) was made i

effective. This su)mittal shall contain:

J i

a.

Sufficiently detailed information to support the rationale for the change; b.

A determination that the change did not reduce the overall conformance of the solidified waste product to existing criteria for solid wastes; and l

c.

Documentation of the fact that the change has been reviewed L

and approved by the responsible Nuclear Operations Department per CPC-2A (Quality Program).

90 As Proposed

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Limitina Conditions for Ooeration Surveillance Reauirements 11.3.5.3 EMERGENCY POWER SOURCES (Contd) 11.4.5.3 EMERGENCY POWER SOURCES (Contd) initiated stithin one (1) hour and (h) Verify that the capacity of the the reactor shall be shutdown as station battery, the RDS batteries described in Section 1.2.5(a) within and the alternate shutdown battery twelve (12) hours and shutdown as is adequate to supply and described in Section 1.2.5(a) and maintain in OPERABLE status (b) within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

all of the actual emergency loads for the design time 7.

One RDS uninterruptible power supply interval when the battery is including battery may be out of service subjected to a battery service as described in Section 3.1.5 Action a.

test. The design time interval

/

for the RDS batteries is one 8.

During reactor power operation, the hour, two hours for the 138 kV line may be out of service for station battery and seventy-repair for periods up to three (3) days.

two hours for the alternate shutdown battery.

9.

If Specification A.8 is not met, a normal orderly shutdown shall be (i) Test and calibrate the 2400 volt initiated within one (1) hour and bus undervoltage trip control the reactor shall be shutdown as components as follows:

described in Section 1.2.5(a) within twelve (12) hours and shutdown as (1) The undervoltage relays described in Section 1.2.5(a) and 127-10XY, XZ and YZ will (b) within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

drop out on decreasing voltage of no lower than 107.1 volts, after a delay B.

During power and refueling operations of <.6 seconds.

the 2400 volt bus undervoltage components shall be operable or placed in the tripped (2) The auxiliary timing relay condition, except during the monthly 162-104 will be actuated channel functional testing period.

after a 10 1 0.5 second time delay upon receiving a signal from all three (3) undervoltage relays.

As Proposed

. =

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BASES FOR 13.1.3.1 - GASE0US EFFLVENT DOSE RATE (Contd) or to less than or equal to 3000 mrems/yr to the skin.

These release rate

/

limits also restrict, at all times, the corresponding thyroid dose rate above background to a child via the inhalation pathway to less than or equal to 1500 mrems/yr.

The required detection capabilities for radioactive materials in gaseous waste samples are tabulated in terms of the lower limits of detection (LLDs).

Detailed discussion of the LLD and other detection limits can be found in HASL Procedures Manual, HASL-300 (revised annually), Currie, L A, " Limits for Qualitative Detection and Quantitative Determination - Application to Radiochemistry," Anal Chem 40, 586-93 (1968), and Hartwell, J K, " Detection Limits for Radioanalytical Counting Techniques," Atlantic Richfield Hanford Company Report ARH-SA-215 (June 1975).

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4 135 As Proposed

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ATTACHMENT 2 CONSUMERS ENERGY COMPANY BIG ROCK P0 INT PLANT DOCKET 50-155 i

I CURRENT TECHNICAL SPECIFICATION PAGES MARKED UP TO ILLUSTRATE CHANGES i

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4.1.2 (C:std) is above 300 pois. m shutdows coollas systes shall be OrtaASLE j,,

and ready for service durlag gffUELING OptRATI0us and the breakers for MO-7470 and NO-7071 shall be tagged "open". The primary coetant shall be sampled and analysed daily durlag periode of POWER OPERATICW. The fo110 wing are absolute !! nits which if esceeded J

shall necessitate reacter suvfDOWW. Corrective action will accessar!!y be takes at more stringent limits to alsinise the j

possibility of these absolute liales ever belas reached.

Conducttv(ty (Nicromho/ca) j Nasimum 5

i Maalaus Transiente 10 pE (tmer and Upper Limits) 4.0 and 10.0 i

Chlori Ion Qpe) 1.0 Borea

)

f 100 f

Isotopic analysts of the primary coolant to deterstas the Dost i

EQUIVALENT I-131 concentraties shall be performed at least every l

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> durlag periods of operation.

i 1.

If the DOSE EQUIVALENT I-131 concentraties escoeds 0.2 pC1/mi

)

and is less than er equal to 4.0 pC1/at Isotopic analysts to l

deterslae DOSE Equ1Valmf I-131 shall be performed every 24 j

heers until the activity is less than 0.2 pC1/al.

2.

If the Dost EQUIVALENT I-131 exceeds 4.0 pct /st, the plant j

('

shall be placed le a suUTDOWN condition with the mala staan j

Isetaties valve closed within 12 boers.

l (c) Leakanw Limits

~

1.

If the primary coolaat system leakass exceeds 1 gas and the seeece of leakage is not identitled, the roastec shell be suurDout as described la secties 1.2.5(e) l within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, and cooldous to a COLD Suttt0WE condities l

shall be lattisted withia 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

l 2.

If leakage from the primary coolant system escoeds le gym, the reactor shall be surrDOWN as descrlhed la secties 1.2.5(a) i...

withia 12 heers, and seeldoun to a COLD saufDOWN conditlen l

shall be lattisted withis'24 heers.

.j c

l

• Conductivity in espected to lacrease temporarily after startups from cold shutdows. m maahms transiest wetee.bere stated is the mastnum permissible and applies only to.the period edsequent to a cold shutdown between criticality and 24 hears after reachlag 205 rated power.

23

s._e Amendment 107 rehr.ar,1., >=

TS SECTTON 4

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• 6.1.3 Reacter Safety Systes Bypass h followlag tabulation gives the permissive functional conditions during which certain reactor safety systes sensors are bypassed by the reactor safety system mode selector switch. A kaylock reactor mode Tank" sad "tua" provided having "Shutdove," " Refuel," "Sypass Dump switch shall be j

positions.

j These positions shall have the followlag functions:

1 Mode Selector Sultch position Tris Function Bypassed tua Mons *I I

Bypass Dump Tank (a)

Low Steam Drum Vater Level Recirculation Vaterline Valveo closed Steam Line Backup Isolation Valve l

Closed i

Migh Water Level la Scram Dump Tank (b) i Migh condenser Pressure RefuelId)

Low Steam Drum Vater Level i

tecirculatloa Waterline Valves Closed Steam Line Backup Isolatloa Valve closed j

i j

'Elgh condenser pressure M filAM b

E CLDSL Shuth MER GWDEWSE8. Pt1560 20tt0UmodWRTERMMt.

CLOSED i (a) Control red withdrawal is prevented by interteck while switch is In this mode pos!'tles.

2 (b)Sypass of this trip function is necessary to enable emptying the dump tank after a scram.

l

(*)With the mode switch in the " shutdown" position, both the scram circuit and the control rod withdrawal circuit ama open. N l

vent!!sttag duct circuit pouer supply is transferrM to a point ubich contalement sphere pressere" protecties threagh signists from "hi provides penetration closure and " low estor level !s :Sactor vesset."

This permits normat weatilatten la the centalement sphere ductas s.,

shutdeum when the control rods are held la the inti-la posittaa.

5:n ;" ": n:::= x"=y ;;== ;!p!: n; "j,;.xd ;k.a * :-ce ". _

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l (d)With the mode sultch to the refuel position and the crane positioned over the reacter vessel, crane operatten is prevented if any one rod is withdreum from full-in posittoa.

i

(*INigh condenser pressure reacter trip is automatically bypassed any time steam drum pressure is below a set point maalaus of 500 pets.

54 a-. w., ley February 19,1992 Ys sectiow 6

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ADMINISTRATIVE C0W1101.8 e

}

l 6.9.2.2.A (conte) l 3.

sotid weste The Radioactive Ef fluent Release Reports shall include the following informstlos for each class of solid waste (as defined by 10 CFR Part 61) shipped offsite during the report period I

a.

Containec burist volume, j

b.

Total curie quansity (specify whether determined by j

measurement or esclaste),

c.

Principal radionuclides (speelfy whether determined by

]

J asasurement or estimate),

{

d.

Source of waste and processing employed (e.g., devatored spent resia, compacted dry waste, evaporator bottone),

3

)

Type of container (e.g., t.sA, type A, Type 8, Large i

e.

i Quantity),and l

f.

golidification agent or absorbent (e.g., cement, asphalt).

)

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4.

gadiological Impact on Nas mg W

The gadioactive affluent Release soport 2 h _

'r:f d2' -

?" '._j; c!t:: f:: :q ! Of :::t x :S" lactado potential doses to ladividsets and populatless: calentated estas measured effluent and averaged noteorelegical data la accordance with the met'hodologies la the Offsite Dose Cateolaties Mammal.

i I

Total body sad sigalficant organ doses (greater than a.

I al111 tem) to ladividuals la unrestricted areas free receivtag water-related exposure pathways.

b.

The maalaum offsite air doses (greater than 1 alltited)

!s.J des to beta' and gaans radiaties at toestions amar ground level from gaseous effluents.

c.

Organ deses (greater than 1 m11113en) to ladividuals j

la marestricted areas from radleactive lodine and "

radioactive materlat la particolate form frea 'the major pathusys of esposure.

d.

Total body doses (greater than 1 mantend to 'the populaties and average doses (greater than 1 milliten) to ladividents la the populaties from receivtag l

usts.r-related patbusys to a distance of Se, elles fran j

the site.

l

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86 W 1er

'i February 19,1991 I

Ts section le

, 3 4'

6 ADMINISTRATIVE CONTROLS 6.12.1(Contd)

A A radiation protection qualified individual (e.g., Health physics c.

Technician) with a radiation dose rate monitoring device, who is i

]

responsible for providing positive control over the activities within l

the area, and shall perform periodic radiation surveillance as specified by the Sk,ht;; xf Radiation protection Supervisor in the j

RWP.

gegoc6

)

6.12.2 In addition to the requirements of Spe fication 5.12.1, areas j

accessible to per anel with radiatt levels greater than 1000 mres/h

/

at 30 cm (12 inches) but less thanf)0 rad /h at 1 meter from the

/

/

radiation source or fror; any ;;..te from which the radiation penetrates shall be provided with locked doors to prevent unauthorized i

entry, and the keys sht11 be maintained under the administrative control i

of the Shift Supervisor on duty and/or health physics supervision. Doors shall remain locked except durinfi periods of access by personnel under an approved RWp which shall spec fy the dose rate levels in the immediate work areas and the maximus allowable stay time for 4

individuals in that area. In lieu of the stay time specification of the RWp direct or remoto (such as closed circuit TV cameras) continuous surveillance may be made by personnel qualified in radiation i

protection procedures to provide positive exposure control over the i

l i

activities being performed within the area.

l-For individual high radiation areas accessible to personnel with radiation levels of greater than 1000 mR/h that are located withis large areas where no enclosure exists for purposes of lockingl areas, enclosure can be and no reasonably con (tructed around the individua thes that individual j

area shall be barricaded, conspicuously posted, and a flashing light shall be activated as a warning device.

t E.13 ENVIR0fttENTAL CUALIFICATION l

(Deleted) j Ll4.

PROCESS C0KTROL PROGRAN (PCP1 h

6.14.1 Changes to the pCP shall be submitted to the Commission in the.

Radteactive Effluent Release Report for the period is dich

/

the change (s) was made effective. This submittal shall contain:

a.

sufficiently detailed information to support the rationale for j

the changes t

l

b. A determination that the change did not reduce the overall confermance of the solidified waste product to existing.

4 criteria for solid wastes and c.

Documentation of the fact that the change has been reviewed l

and approved by the responsible Nuclear Operations Department per Cpt-2A (Quality Program).

i' i

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Amendment 4 4, 116 August 2, 1995

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l 7

7-laftlas Condi~ ionsTor Operation ---

serveillance teemirements L

t i

Q 11.3.3.3 a sRGENCY FOWER 9000CES (Contd) 11.4.5.3 DERCENCY 70WER SOURCES (Contd) i initiated withis one (1) hour and (h) Verify that the capacity of the

/

the remeter shall be ehmtdema as staties bettery, the RDS betteries deseribed la secties 1.2.5(a) within and the alternate ehmadeum bettery

/

twelve (12) hours and shutdeus as is adequate to empply and described la sosties 1.2.5(a) and esistain la OPERABLE status (b).within the following 24 heers.

all of the actual energency leads for the design time 7.

Coe BBS untaterruptible power supply interval when the battery is imeloding bettery may be e t of service embjected to a battery service se'describedlasecties3.b5Aetienha..

test. The desima ties interval for the BBS batteries is one j

8.

Derlag reester power operettee, the heer, two hours for the 138 kV line any be set of servlee for station bettery and seventy-repair for periods up to three (3) days.

two hours for the altevante shutdeum battery.

9.

If spesifiestica A.8 is met met, a norant ouderly sketdeus shall be (1) Test and calibrate the 2400 volt initiated wichts one (1) heer and bos underwettese trip eentret

/

the,reseter shall be ebendous as eenpeneete as fellowss l

deseribed la seetten 1.2.5(a) withia -

/

twelve (12) hears and skatdeus as (1) The undervoltage relays j

described la Seetles 1.2.5(a) and 127-10ET, II and YI will i

(b) within the following 24 heers.

drop out om decreasias I

voltage of me lower than 107.1 volts, after a delay l

3.

During power and refuellas operations of 1 6 seceeds.

t the 2400 volt bue underweltage esepenents shall be operebte er placed in.the tripped (2) The maalliary timing relay sendities, easept during the monthly 162-104 will be actuated skammet fonetissel teettag period.

efter a le 2 0.3 seeemd time delay open resolving e signal free all three (3) underweltase relayo.

110

• 107 February 19, 1992

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i RASES FOR 13.1.3.1 - GASE0US EFFLUENT DOSE RATE (Contd) 4 or to less than or equal to 3000 aress/he to the skin. These release rate

- /

limits also restrict, at all times, the corresponding thyroid dose rate above background to a child via the inhalation pathway to less than or equal to 1500aress/yr.

The required detection capabilities for radioactive materials in gaseous wasta Detailed discussion of the LLD and other detection limits c samples are tabulated 'in terms of the lower limits of detecties (LLDs j

in NASL i

Procedures Manual, NASL-300 (revised annually), Currie, L A, " Limits for Qualitative Detection and Quantitative Determination - Application to 1968), and Hartwell, J K. " Detection Radiochemistry,' Anal Chan 40, 586-93 (hniques " Atlantic Richfield Hanford Limits for RadioanaLytica'. Counting Tec j

Company Report ARH-SA-215 (June 1975).

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135 Amendment 407 116 August 2,199I l

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AtlCNtGAN's PROGRESS Patrick M Donnep s., n s.., Piani. sons us.3 Plant \\fJnJw y

un po.ni u Num cn.o.,o, w 4sno D->M October 15, 1996 Document Control DeskNuclear Regulatory Commission Washington, DC 20555 CHANGE REQUEST - CONTAINNENT E TESTING PROGRAN R EDITORIAL CHANGES.

TION NINOR A request for change to the Big Rock P This change is required to impleme t oint Technical Specifications is enclo to Appendix J of 10 CFR Part 50 n

Option 8 included.

. In addition, s,everal editorial changes a sed.

On October 25, also

1995, performance-based option for leakage cooled nuclear power plants. This actithe Commissio

-rate testing of containments of light-wate u a ions by eliminating prescriptive requirem to provide provides licensees greater flexibilitrule allows test int on improves the focus of the regulati a

ents that are marginal to safety r

e ons of regulatory safety objectivesy for cost effective implementationon

. The amended the Type A (containmentThe proposed Technical Specificati methods Type B (pneumatic tests to detecton Change w (pneumatic tests to measure contaileakage rates acro on B for e a ning, Type A test to measure the contai nment isolation valve leakage rates) t and measure local met, Option B will then be adopted fwill continue to be nment system overall integrated le

s. The ge rate or the Type A test.

s are