ML20076D859

Amends 122 & 104 to Licenses NPF-09 & NPF-17,respectively. Amends Revise Carbon Adsorber Test Method & Methyl Iodide Penetration Criteria Re TS 3/4.6.1.8

ML20076D859
Person / Time
Site:	McGuire, Mcguire
Issue date:	07/15/1991
From:	Mathews D Office of Nuclear Reactor Regulation
To:
Shared Package
ML20076D866	List: ML20076D859 ML20076D871
References
NUDOCS 9107300289
Download: ML20076D859 (13)

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DUKE POWER COMPAhT DOCKET No. 50-369 McGUIRE NUCLEAR STATION, UNIT 1 AMENDNENT TO FACILITY OPERATING LICENSE Amendment No. 122 License No. NPF-9 1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment to the McGuire Nuclear Station, Unit 1 (the facility) Facility Operating License No. NPF-9 filed by the Duke Power Company (the licensee) dated April 11, 1991, as supplemented July 3, 1991, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act),

and the Commission's rules and regulations as set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations set forth in 10 CFR Chapter I; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

9107300289 910715 PDR ADOCK 05000369 P

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Accordingly, the license is heceby amended by page changes to the Technical Specificationa as indicated in the attachment to this license amendment, i

and Paragraph 2.C.(2) of Facility Operating License No. NPF-9 is hereby j

amended to read as follows:

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No.122, are hereby incorporated into the license.

The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3.

This license amendment is effective as of its date of issuance.

FOR THE NUCLEAR REGULATORY COFDilSSION David B.

atthews, Director Project Directorate II-3 Division of Reactor Projects-I/II Office of Nuclear Reactor Regulation

Attachment:

Technical Specification Changes Date of Issuance:

July 15, 1991

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,p DUKE POWER COMPANY DOCKET No. 50-370 McCUIRE KUCLEAR STATION, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No.104 License No. NPF-17 1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment to the McGuire Nuclear Station, Unit 2 (the facility) Facility Operating License No. NPF-17 filed by tha Duke Power Company (the licensee) dated April 11, 1991, as supplemented July 3, 1991, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act),

and the Commission's rules and regulations as set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulatiens of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations set forth in 10 CFR Chapter I; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

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.g 2.

Accordingly, the license is hereby amended by page changes to the Technical Specifications as indicated in the attaclanent to thih license amendment, and Paragraph 2.C.(2) of Facility Operstit.g License No. NPF-17 is hereby amended to read as follows:

Technical Specifications.

The Technical Specifications contained in Appendix A, as revised through Amendment No.104, are hereby incorporated into the license.

The licensee shall operate the facility in accordance with the Technical Specliacations and the Envirotunental Protection Plan.

3.

Ihis license amendment is effective as of its date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION (d

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Davfd B. Matthews, Director Project Directorate II-3 Division of Reactor Projecta-1/II Office of Nuclear Reactor Regulation

Attachment:

Technical Specification Chan6cs Date of Issuance:

July 15, 1991 l

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ATTACHMENT TO LICENSE AMENDMENT NO. 122 FACILITY OPERATING LICENSE NO. NPE 9 DOCKET NO. 50-369 A!!Q TO LICENSE AMENDMENT NO. 104 FACILITY OPERATING LICENSE NO. NPF-17 DOCKET _NO._$0-370 Repl6ce the following pages of the Appendix "A" Technical Specifications with the enclosed pages. The revised pages are identified by Amendment number and contain vertical lines-indicating the areas of change.

Remove Pages insert _Pages 3/4 6-16 3/4 6 16 3/4 6-17 3/4 6-17 3/4 7-13 3/4 7-13 3/4 7-14 3/4 7-14 3/4 7 15 3/4 7-15 B 3/4 6-3 B 3/4 6-3 B 3/4 6-4 8 3/4 6-4 8 3/4 7-4 B 3/4 7-4 s.

g CONTAlkMENT SYSTEMS f

ANNULUS VENTILATION SYSTEM LIMITING CONDITION FOR OPERATION _

3.6.1.8 Two independent Annulus Ventilation Systems shall be OPERABLE.

i APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTION:

a.

With one Annulus Ventilation System inoperable for reasont other than the pre-heaters tested in 4.6.1.8.a and 4.6.1.8.d 5, restore the inoperable system to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTOOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />, b.

With the pre-heaters tested in 4.6.1.8.a and 4.6.1.8.d.5 inoperable, i

restore tie inoperable pre-heaters to OPERABLE status within 7 days, or file a $pecial Report in accordance with Specification 6.9.2

. ithin 30 days specifying the reason for inoperability and the w

planned actions to return the pre-i. eaters to OPERABLE status.

SURVEILLANCE REQUIREMENTS 4.6.1.8 Each Annulus Ventilation System shall be demonstrated OPERABLE:

a.

At least once per 31 days on a STAGGERED TEST BASIS, by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />s-with the pre-heaters operating; b.

At least once per 18 months, or (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following paintingIththesystem,by:

fire, or chemical release in any ventilation zone communi-cating w 1)

Verifying that the ventilation system satisfies the in place penetration and bypass leakage testing acceptance criteria of less than 1% and uses the test procedure guidance of Regulatory Positions C.S.a. C.S.c and C.S.d of Regulatory Guide 1.52,.

-Revision 2, March 1978, and the system flow rate is 8000 cfm i-10%;-

2) - Verifying within 31 days after n

'al that a laboratory analysis of a representative carbo sample:obtained in accordance with Regulatory Position C.6.b of Regulatory Guide-1.52, Revision 2, March 1978, and tested per ASTM 03803-89 has a methyl-iodide penctration of less than 4%;-and 3)

Verifying a system flow rate'of 8000 cfm i 10% during system operation when tested in-accotdance with ANSI N510-1975.

- McGUIRE - UNITS 1 and 2 3/4 6-16 Amendment No.12XUnit 1)

Amendment No.10{ Unit 2)

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CONTAINMENT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) c.

After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> 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, and tested per ASTM 03803-89, has a methyl iodide penetration of less than 4%;

d.

At least once per 18 months, by:

1)

Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 6 inches Water Gauge while operating the system at a flow rate of 8000 cfm i 10%;

2)

Verifying that the system starts automatically on any Phase B Isolation test signal; 3)

Verifying that the filter cooling electric motor-operated bypass valves can be opened; 4)

Verifying that each system produces a negative pressure of greater than or equal to 0.5 inch W.G. in the annulus within 22 seconds after a start signal and that this negative pressure goes to -3.5 inches W.G. within 48 seconds after the start signal.

Verifying that upon reaching a negative pressure of

-3.5 inches W.G. in the annulus, the system switches into its recirculation mode of operation anJ that the time required for the annulus pressure to increase to -0.5 inch W.G. is greater than or equal to 278 seconds; 5)

Verifying that the pre-heaters dissipate 43.0 1 6.4 kW at a nominal voltage of 600 VAC when tested in accordance with l

ANSI N510-1975, i

e.

After cach complete or partial replacement of a HEPA filter bank, by verifying that the HEPA filter bank satisfies the in place penetration and bypass leakage testing acceptance criteria of less than 1% in accordance with ANSI N510-1975 for DOP test aerosol while operating the system at a fiow rate of 8000 cfm i 10%; and f.

After each complete or partial replacement of a charcoal adsorber bank, by verifying that the charcoal adsorber satisfie:; the in-place penetration and bypass leakage testing acceptance criteria of less than 1% in accordance with ANSI N510-1975 for a halogenated hydrocarbon refrigerant test gas while operating the system at a flow rate of 8000 cfm i 10%.

McGUIRE - UNITS 1 and 2 3/4 6-17 Amendment No,122(Unit 1)

Amendment He.104(Unit 2)

PLANT SYSTEMS 3/4.7.6 CONTROL AREA VENTILATION SYSTEM LIMITING CONDITION FOR OPERATION 3.7.6 Two independent Control Area Ventilation Systems shall be OPERABLE.

APPLICABILITY:

ALL MODES ACTION:

(Units 1 and 2)

MODES 1, 2, 3 and 4:

a.

With one Control Area Ventilation System inoperable for reasons other than the heaters specified in 4.7.6.a and 4.7.6.e.4, restore the in-operable system to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTOOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />, b.

With the heaters tested in 4.7.6.b and 4.7.6.e.4 inoperable, restore the inoperable heaters to OPERABLE status within 7 days or file a SpecialReportinaccordancewithSpecification6.9.2wIthin30 days, specifying the reason for inoperability and the planned actions to return the heaters to OPERAf6E status.

MODES S and 6:

a.

With one Control Area Ventilation System inoperable for reasons other than the heaters specified in 4.7.6 a and 4.7.6 e.4, restore the inoperable system to OPERABLE status within 7 days or initiate and maintain operation of the remaining OPERABLE Control Area Ventilation System in the recirculation mode; and b.

With both Control Area Ventilation Systems inoperable for reasons other than the heaters specified in 4.7.6.a and 4.7.6.e 4, or with the OPERABLE Cor. trol Area Ventilation System, required to be in the recirculation mode by ACTION a., not capable of being powered by an OPERABLE emergency power source, suspend all operations involving CORE ALTERATIONS or positive reactivity changes.

c.

The provisions of Specification 3.0.4 are not applicable, d.

With the heaters tested in 4.7.6.b and 4.7.6.e.4 inoperable, restore the inoperable heaters to OPERABLE status within 7 days, or file a Special Report. in accordarce with Specification 6.9.2 within 30 days, specifying the reason for inoperability and the planned acations to return the heaters to OPERABLE status.

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McGUIRE - UNITS 1 and 2 3/4 7-13 Amendment No.122 (Unit 1)

Amendment No.10',(Unit 2)

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PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

SURVEILLANCE REQUIREMENTS 4.7.6 Each Control Area Ventilation System shall be demonstrated OPERABLE:

a.

At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, by verifying that the control room air temperature is less than or equal to 90'F; b.

At least once per 31 days on a STAGGERED TEST BASIS, by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> with the heaters operating; c.

At least once per 18 months, or (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following painting, fire or chemical release in any ventilation zone communicating with the system, by:

1)

Verifying that the system satisfies the in place penetration and bypass leakage testing acceptance criteria of less than 0.05% and uses the test procedure guioance of Regulatory Posi-tions C.S.a. C.5.c, and C.5.d of Regulatory Guide 1.52. Revi-sion 2, March 1979, and the system flow rate is 2000 cfm i 10%;

2)

Verifying, within 31 days af ter removal, that a laboratory analysis of a representative carbon nmple obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, and tested per ASTM D3803-89, has a methyl iodide penetration of less than 0.95%; and 3)

Verifying a system flow rate of 2000 cfm i 10% during system operation when tested in accordance with ANSI N510-1975, d.

After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation, by verifying within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Pusition C 6.b of Regulatory Guide 1.52, Revision 2, March 1978, l

and tested per ASTM D3803-89, has a methyl iodide penetration of l

less than 0.95%;

e.

At least once per 18 months, by:

l 1)

Verifying that the pressure drop across the combined pre-filters, HEPA filters and charcoal adsorber banks is less than 5 inches Water Gauge while operating the cystem at a flow rate of 2000 cfm i 10%;

McGUIRE - UNITS 1 and 2 3/4 7-14 Amendment No.122 (Unit 1)

Amendment No.104 (Unit 2)

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) 2)

Verifying that upon actuation of a diesel generator sequencer the system automatically switches into a mode of operation with flow through the HEPA filters and charcoal adsorber banks; 3)

Verifying that the system maintains the control room at a positive pressure of greater than or equal to 1/8 inch W.G.

relative to the outside atmosphere during system operation; and l

4)

Verifying that the heaters dissipate 10 i 1.0 kW at a nominal voltage of 600 VAC when tested in accordance with ANSI N510-1975.

f.

After each complete or partial replacement of a HEPA filter bank, by verifying that the HEPA filter bank satisfies the in place penetration and bypass leakage. testing acceptance criteria of less than 0.05% in accordance with ANSI N510-1975 for a DOP test aerosol while operating the system at a flow rate of 2000 cfm i 10%; and g.

After each complete or partial replacement of a charcoal adsorber bank, by verifying that the charcoal adsorber $stisfies the in place penetration and bypass leakage testing acceptance criteria of less than 0.05% in accordance with ANSI N510-1975 for a halogenated hydro-carbon refrigerant test gas while operating the system at a flow rate of 2000 cfm i 10%.

1

.McGUIRE - UNITS 1 and 2 3/4 7-15 Amendment No.122 Unit 1)

Amendment No.104 Unit 2) 1.-

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CONTAINMENT SYSTEMS BASES 3/4.6.1.7 REACTOR BUILDING STRUCTURAL INTEGRITY This limitation ensures that the structural integrity of the containment reactor building will be maintained comparable to the original design standards for the life of the facility.

Structural integrity is required to provide:

(1) protection for the steel vessel from external missiles, (2) radiation shielding in the event of a LOCA, and (3) an annulus surrounding the steel vessel that can be maintained at a negative pressure during accident conditions.

A visual inspection is sufficient to demonstrate this capability.

3/4.6.1.8 ANNULUS VENTILATION SYSTEM The OPERABILITY of the Annulus Ventilation System ensures that during LOCA conditions, containment vessel leakage into the annulus will be filtered through the HEPA filters and charcoal adsorber trains prior to discharge to the atmos-phere.

Cumulative operation of the system with the heaters on for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> over a 31-day period is sufficient to reduce the buildup of moisture on the adsorbers and HEPA filters.

The specified laboratory test method, ASTM-3803-89, implies that heaters may be unavailable for controlling the relative humidity of the influent air entering the charcoal absorber section to 5 70 percent.

This is ecceptable since the accident analysis with appropriate absorber efficiencies for radioiodine in elemental and organic forms based on the above test shows that the control room radiation doses to be within the 10 CFR Part 50, Appendix A GDC 19 limits during design basis LOCA conditions.

However, specifications are included to ensure heater operability and corrections ACTIONS are identified to address the contigency of inoperable heaters; these are in place to increase the safety margin of the filters.

Heater operation is not necessary to meet the assumptions used in the accident analyses and limit the SITE BOUNDARY radiation doses to within the dose guideline values of 10 CFR Part 100 during LOCA conditions.

3/4.6.1.9 CONTAINMENT VENTILATION SYSTEM The containment purge supply and exhaust isolation valves for the lower compartment (24-inch) and instrument room (12-inch and 24-inch) are required to bd sealed closed during plant operations since these valves have not been demonstrated capable of closing during a LOCA.

Maintaining these valves sealed closed during plant operation ensures that excessive quantities of radioactive material will not be released via the Containment Purge System.

To provide assurance that these containment valves cannot be inadvertently opened, the valves are sealed closed in accordance with Standard Review Plan 6.2.4 which includes mechanical devices to seal or lock the valve closed, or prevents power from being supplied to the valve operator.

The use of the containment purge lines is restricted to the purge supply and exhaust isolation valves in the upper compartment (24-inch) since, unlike the valves in the lower compartment and instrument room, the upper compartment valves will close during a LOCA.

Therefore, the SITE BOUNDARY dose guideline values of 10 CFR Part 100 would not be exceeded in the event of an accident during containment ourging operation.

Operation with these valves open will be limited to 250 hours0.00289 days <br />0.0694 hours <br />4.133598e-4 weeks <br />9.5125e-5 months <br /> during a calendar year.

McGUIRE - UNITS 1 and 2 B 3/4 6-3 Amendment No.122 (Unit 1)

Amendment No.104 (Unit 2)

CONTAINMENT SYSTEMS BASES 3/4.6.1,9 CONTAINMENT VENTILATION SYSTEM (Continued)

Leakage integrity tests with a maximum allowable leakage rate for contain-ment purge supply and exhaust supply valves will provide early indication of resilient material seal degradation and will allow opportunity for repair before gross leakage failures could develop.

The 0.60 L leakage limit of Specifica-tion 3.6.1.2b. shall not be exceeded when the leakage rates determined by the leakage integrity tests of these valves are added to the previously determined total for all valves and penetrations subject to Type B and C tests.

3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS CONTAINHENT SPRAY SYSTEM The OPERABILITY of the Containment Spray System ensures that containment depressurization and cooling capability will be available in the event of a LOCA.

The pressure reduction and resultant lower containment leakage rate are consistent with the assumptions used in the accident analyses.

3/4.6.3 CONTAINMENT ISOLATION VALVES The OPERABILITY of the containment isolation valves ensures that the containment atmosphere will be isolated from the outside environment in the event of a release of radioactive material to the containment atmosphere or pressurization of the containment and is consistent with the requirements of GDC 54 thru 57 of Appendix A to 10 CFR Part 50.

Containment isolation within the time limits specified for those isolation valves designed to close automatically ensures that the release of radioactive material to the environment will be consistent with the assumptions used in the analyses for a

LOCA, Containment isolation valves are listed in FSAR Table 6.2.4-1.

Those valves with a required isolation time have c value given in the " MAX ISOLATION TIME (SEC)" column.

Penetration test type (type B, type C, or None) is listed in the " TEST TYPE" column of the table for each containment penetration.

Changes to the FSAR are made in accordance with 10 CFR 50.59.

3/4.6.4 COMBUSTIBLE GAS CONTROL The OPERABILITY of the equipment and systems required for the detection and control of hydrogen gas ensures that this equipment will be available to

naintain the hydrogen concentration within containment below its flammable limit during post-LOCA conditions, Either recombiner unit is capable of controlling the expected hydrogen generation associated with

(1) zirconium-water reactions, (2) radiolytic decomposition of water, and (3) corrosion of metals within containment.

These hydrogen control systems are consistent with the recommendations of Regulatory Guide 1.7, " Control of Combustible Gas Concentrations in Containment following a LOCA", March 1971.

The OPERABILITY of at least 64 of 66 igniters ensures that the Distributed Ignition System will maintain an effective coverage throughout the containment.

This system of igniters will initiate combustion of any significant amount of hydrogen released af ter a degraded core accident.

This system is to ensure burning in a controlled manner as the hydrogen is released instead of allowing it to be. ignited at high concentrations by a random ignition source.

McGUIRE - UNITS 1 and 2 B 3/4 6-4 Amendment No.122(Unit 1)

Amendment No.104(Unit 2)

PLANT SYSTEMS BASES STANDBY NUCLEAR SERVICE WATER POND (Continued)

The linitations on minimum water level and maximum temperature are based on providing a 30-day cooling water supply to safety-related equipment with:,at exceeding their design basis temperature and is consistent with the recommend-ations of Regulatory Guide 1.27, " Ultimate Heat Sink for Nuclear Plants,"

March 1974.

The Surveillance Requirements specified for the dam inspection will conform to tne recommendations of Regulatory Guide 1.127, Revision 1, March 1978 3/4.7.6 CONTROL AREA VENTILATION SYSTEM The OPERABILITY of the Control Area Ventilation System ensures that:

(1) the ambient air temperature does not exceed the allowable temperature for continuous duty rating for the equipment and instrumentation cooled by this system, and (2) the control room will remain habitable for operations personnel during and following all credible accident conditions.

Cumulative operation of the system with the heaters on for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> over a 31-day period is sufficient to reduce the buildup of moisture on the adsorbers and HEPA filters.

The specified laboratory test rethod, namely, ASTM D3803-89, implies that heaters may be unavailable for controlling the relative humidity of the influent air entering the charcoal absorber section to 5 70 percent.

This is acceptable since accident analysis with appropriate absorber efficiencies for radioicdine in el mental and ogranic forms based on the abova test shows the site boundary radiation doses to be within the 10 CFR Part 100 limits during design basis LOCA conditions.

However, specifications are included to ensure heater operability and corrective ACTIONS are identified to address the contingency of inoperable heaters; these are in place to increase the safety margin of the filters.

The OPERABILITY of this system in conjunction with control room design provisions is based on limiting the radiation exposure to personnel occupying the control room to 5 rem or less whole body, or its eqtivalent.

This limitation is consistent with the requirements of General Design Criterion 19 of Appendix A, 10 CFR 50.

ANSI N510-1975 will be used as a procedural guide for surveillance testing.

3/4.7.7 AUXILIARY BUILDING FILTERED VENTILATION EXHAUST SYSTEM The OPERABILITY of the Auxiliary Building Filtered Ventilation Exhaust System ensures that radioactive materials leaking from the ECCS equipment within the auxiliary building following a LOCA are filtered prior to reaching the environment.

The operation of this system and the resultant effect on offsite dosage calculations were assumed in the accident analyses.

ANSI N510-1980 will be used as a procedural guide for surveillance testing.

The methyl iodide penetration test criterion for the carbon samples has been established at 10% (i.e., 90% removal) which is greater than the iodine removal in the accident analysis.

McGuire - UNITS 1 and 2 B 3/4 7-4 Artendment No.122 (Unit 1)

Amendment No.104 (Unit 2)