ML103200451
| ML103200451 | |
| Person / Time | |
|---|---|
| Site: | North Anna |
| Issue date: | 11/15/2010 |
| From: | Lane N Virginia Electric & Power Co (VEPCO) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 10-114D | |
| Download: ML103200451 (29) | |
Text
VIRGINIA ELECTRIC AND POWER COMPANY RIC H M O N D, VIRGINIA 23261 November 15, 2010 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 Serial No.:
NAPS/MPW Docket No.:
License No.:
10-1140 50-338 NPF-4 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)
NORTH ANNA POWER STATION UNIT 1 SUPPLEMENTAL RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION FOR EXEMPTION REQUEST FOR THE RCP OIL COLLECTION SYSTEM In an April 23, 2010 letter (Serial No.10-114), Dominion requested an exemption from the requirements of 10 CFR 50, Appendix R, Section 111.0, for Operating License NPF-4 for North Anna Unit 1. Section 111.0 requires that the Reactor Coolant Pumps (RCP) be equipped with an oil collection system if the containment is not inerted.
In addition, Section 111.0 requires that collection systems shall be capable of collecting lube oil from all potential pressurized and unpressurized leakage sites in the RCP lube oil system.
In an E-mail dated August 19, 2010 from Dr. V. Sreenivas, the NRC requested additional information to complete their review of the exemption request for Unit 1.
When the request for additional information (RAI) was received, North Anna was preparing for and subsequently completed a refueling outage.
Therefore, Dominion provided a partial response to the RAls and committed to provide the remaining information by November 15, 2010.
In a letter dated October 10, 2010 (Serial Number 10-114C), Dominion provided a response to questions 1, 2, 4, 6, 7, and 9. The attachment to this letter provides answers to questions 3, 5, and 8. This attachment also contains an editorial correction of the previous response to question 7.2.
If you have any questions or require additional information, please contact Mr. Thomas Shaub at (804) 273-2763.
Sincerely, n120~
N. Larry Lane Site Vice President North Anna Power Station Commitments contained in this letter: None Attachments:
- 1. Supplemental Response to Request for Additional Information
- 2. Drawings for Reactor Coolant System Piping Orientation
Serial No. 10-1140 Docket No. 50-338 Response to Request for Additional Information Exemption Request Oil Collection System Page 2 of 2 cc:
U.S. Nuclear Regulatory Commission - Region II Marquis One Tower 245 Peachtree Center Ave., NE, Suite 1200 Atlanta, Georgia 30303-1257 Mr. J. E. Reasor, Jr.
Old Dominion Electric Cooperative Innsbrook Corporate Center 4201 Domin ion Blvd.
Suite 300 Glen Allen, Virgin ia 23060 NRC Senior Resident Inspector North Anna Power Station Dr. V. Sreenivas NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, Maryland 20852-2738 Ms. K. R. Cotton NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, Maryland 20852-2738
Serial No. 10-114D Response to Request for Additional Information Exemption Request Oil Collection System ATTACHMENT 1 SUPPLEMENTAL RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION EXEMPTION REQUEST FOR THE RCP OIL COLLECTION SYSTEM VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)
NORTH ANNA POWER STATION UNIT 1
Serial NO.1 0-1140 Docket No. 50-338 Response to Request for Additional Information Exemption Request Oil CollectionSystem Page 1 of 22 Response to Request for Additional Information
Background
By letter dated April 23, 2010, (Serial No.1 0-114), Agencywide Documents Access and Management System (ADAMS), accession number ML101160376, the Virginia Electric and Power Company (Dominion) requested an exemption from the requirements of Title 10 of the Code of Federal Regulations Part 50 (10 CFR 50), Appendix R, Section 111.0, for Operating Licenses NPF-4 and NPF-7 for North Anna Units 1 and 2. Section 111.0 requires that the Reactor Coolant Pumps (RCPs) be equipped with an oil collection system arid that collection system be capable of collecting lube oil from all potential pressurized and unpressurized leakage sites. The exemption request is intended to address verbatim compliance with 10 CFR 50 Appendix R as it applies to oil misting rather than oil leakage that is collectible.
It was later determined that an exemption request was not an appropriate method to address this issue for North Anna Unit 2 based on the effective date of the regulation. Therefore, in a letter dated May 13, 2010 ADAMS, accession number ML101380270), Dominion withdrew the exemption request for North Anna Unit 2 and will instead address the issue in accordance with the existing North Anna Unit 2 licensing condition 2.D. In the same letter, Dominion provided its documentation of special circumstances for consideration under 10 CFR 50.12 for North Anna Unit 1, for this exemption request.
In an August 19, 2010 E-mail from Dr. V. Sreenivas, the NRC requested additional information (RAI) to complete the NRC review. As noted in the cover letter, a partial response to the RAI (Questions 1, 2, 4, 6, 7 and 9) was provided in a letter dated October 10,2010 (Serial NO.10-114C). The remaining information (Questions 3, 5, and
- 8) is provided in this attachment.
The sketches referred to in this attachment were provided in the October 10, 2010 letter (Serial NO.10-114C).
NRC Question Serial No.10-114D Docket No. 50-338 Response to Request for Additional Information Exemption Request Oil Collection System Page 2 of 22 Dominion Response Background RAI 3:
Dominion's letter dated April 23, 2010, states, "Additional defense-in-depth is achieved through the physical properties of the oil itself combined with the limited amount of ignition sources within the area. The flashpoint of the oil currently used is 374°F, with an auto-ignition temperature of 608°F. Nominal temperatures of the RCP motor and pump flange are approximately 220°F and 550°F, respectively. These temperatures would not be sufficient to cause auto-ignition of the oil. However, given the flashpoint of the oil, it is conceivable that the oil could be ignited in the presence of an lqnltion source. "
3.1 Discuss defense in depth and specifically, As described in the Oil Collection System (OCS) Exemption Request, the physical the physical properties of the RCP oil that properties of the oil including the flashpoint and auto-ignition temperature provide provides additional defense in depth.
additional defense in depth against the oil auto-igniting. According to the Material Safety Data Sheet (MSDS) the flashpoint is 374°F and through information received from the vendor the auto-ignition temperature was found to be 608°F. The Reactor Coolant Pump (RCP) motor and pump flange are at 220°F and 550°F, respectively. Therefore, the physical properties of the oil, specifically the auto-ignition temperature, provide defense-in-depth since the oil should not contact any temperatures higher than 550°F, which is well below the auto-lqnltlon temperature.
3.2 Describe the physical properties of the oil when it is above the flashpoint of 374°F and the effect of chemical breakdown and subsequent lowering of auto-ignition temperature.
3.3 Describe in detail the type of RCP oil used, include flash point, fire point, auto ignition temperature, and controls in place to assure RCP oil of different (more combustible) properties will not be used in the future.
The physical properties of the oil (above the flashpoint of 374°F) were discussed with the manufacturer, Chevron. The following information was received :
Product code CPS 273210, Chevron Regal R&O ISO 46 is used for North Anna RCP motor lubrication systems. Chevron has no data on the physical properties of this oil above the flash point as this temperature far exceeds the operating temperature of this oil. In general, petroleum based circulating oils should be kept at an operating temperature below 1600F to minimize oxidation of the oil.
As stated in RAI 3.2, the type of oil used is Chevron Regal R&O ISO 46, Product code CPS 273210. According to the vendor data sheet, and information received from Chevron, the characteristics of the oil are the following:
- Flashpoint: 374°F MSDS
- Fire point: Unknown
- Auto ignition temperature: 608°F
NRC Question Serial NO.1 0-114D Docket No. 50-338 Response to Request for Additional Information Exemption Request Oil Collection System Page 3 of 22 Dominion Response The Station Lubrication Manual functions as the procedural controls to ensure that RCP oil of different properties is not used. The Station Lubrication Manual is procedurally controlled and requires authorization to be changed. Each RCP has its own entry in the Station Lubrication Manual.
Background RAI5:
Dominion's letter of April 23, 2010, states, "Industry events have shown the most credible ignition source for RCP oil is hot RCS piping.
Ignition has typically occurred due to the oil soaking combustible insulation. Combustible insulation is not used at North Anna; the intermediate leo and cold leq plplnq are insulated with reflective, non-combustible insulation."
5.1 Describe in detail the type of insulation used on RCS piping including directly on the piping and describe any material that covers that layer of insulation such as reflective material.
5.2 Discuss any properties of RCS piping insulation that could lead to reduced auto ignition temperature such as has been seen at other facilities and how NA ensures non-combustible fibrous insulation materials do not soak up oil.
Refer to Table 4 for a detailed list of all insulation contained in Unit 1, Cubicle 1 (Elevation 262') and Loop Room 1 (Elevation 241'), for RCP 1-RC-P-1 A. Recent containment walkdowns identified that the insulation types and quantities are similar in all six areas.
Table 4 also provides information regarding the jacket material that covers each section of insulation.
Recently three sections of insulation under the RCP motor have been replaced with Tempmat insulation covered with fiberglass cloth. These three panels are located on the RCP outlet nozzle, on the RCP pump casing, and under the intermediate RCS leg. Refer to the highlighted rows in attached Table 4 for insulation panels on 31" RC-2-2501 R-Q1 (1-RC-P-1A, intermediate leg piping), 27-1/2" RC-3-2501R-Q1 (1-RC-P-1A, cold leg outlet nozzle) and 1-RC-P-1A, pump casing. The drawings in Attachment 2 of this letter detail the orientation of Unit 1 Loop 1 RC piping and the insulation panels.
This material is noncombustible and is not an Appendix R concern with respect to combustible loading. Only the insulation panel on 27-1/2" RC-3-2501 R-Q1 is an area of concern for absorption of misted oil because the 1-RC-P-1 A cold leg outlet nozzle is located more or less directly underneath the RCP motor stator air cooler. The other two Tempmat insulation panels are not located within the zone of possible oil misting discharge. Using 1-RC-P-1 A as an example, Sketch 2, in Attachment 2 of the letter dated October 10, 2010, shows the orientation of the two stator air coolers located on the RCP motor. Sketch 1, in Attachment 2 of the letter dated October 10, 2010, shows the orientation of the RC piping located at an elevation approximately 10 feet below the coolers. While the cold leo between the pump and the reactor is below one of the
NRC Question Serial NO.10-1140 Docket No. 50-338 Response to Request for Additional Information Exemption Request Oil Collection System Page 4 of 22 Dominion Response coolers, the intermediate leg is at right angles to the cooler discharge and this Tempmat panel is located approximately 20 ft. away from the pump motor. The Tempmat panel located on 1-RC-P-1A pump casing is located below the pump flange and is shielded from exposure to possible oil misting.
Tempmat insulation panels are absorbent and industry experience at ANa and Haddam Neck show that oil-soaked absorbent pipe insulation can lead to fires. However, OE establishes that these fires were caused by large breaks in sections of the RCP Oil.
System piping, which were additionally not protected by an oil collection system.
At North Anna, the RCP oil system is protected by an oil collection system with piping connected to an oil storage tank. This oil collection system is verified to be functional every 18 months in accordance with procedures 1/2-PT-108.5. Repeat events similar to ANa and Haddam Neck are not considered to be credible at North Anna given the present oil collection system design.
Regardless, over the past few outages (N1-R-20 and N2-R-19), oil misting has been observed at the outlets of the RCP motor stator air coolers. To address oil misting, oil collection trays were installed on the stator coolers with piping connected to the RCP Oil Collection System in Unit I during the Fall 2010 refueling outage. These collection trays have been installed for six months on Unit 2, and a walkdown of Unit 2 RCP A and B on October 14, 2010 verified that the oil collection trays were performing as designed.
Evidence of oil inside the trays indicates that the oil misting has been collected with the exception of a very insignificant amount (several drops of oil were noted on the external surface of the collection tray). This insignificant amount is not capable of creating a hazard, even if it were to reach the Tempmat panel.
As defense-in-depth due to the increase in absorptive insulation installed in Unit 1 and Unit 2, procedures 1/2-PT-108.5 were revised to require inspection of the absorptive insulation every refueling outage for any evidence of contact with RCP oil. This enhancement of procedures 1/2-PT-108.5 will ensure that Tempmat insulation showing indications of potentially absorbed oil will be replaced, thereby limiting the cumulative effects of the oil misting. In addition, annunciator response procedures for the RCP oil reservoir alarms, 1-AR-C-F1, 1-AR-C-F2, and 1-AR-C-F3 were revised to include direction to inspect the Tempmat panels in the affected loop room for evidence of oil
NRC Question 5.3 Discuss the expected temperatures on the RCS piping during normal power operations and shutdowns and outages including temperatures on reflective insulation coverings.
Serial No. 10-114D Docket No. 50-338 Response to Request for Additional Information Exemption Request Oil Collection System Page 5 of 22 Dominion Response absorption if a containment entry is made as part of the response to a low level alarm.
Therefore, the insulation changes in response to the GSI-191 concerns will not adversely impact the 10CFR50 Appendix R requirements to protect safe-shutdown euulnment.
During operation, the nominal temperature of the RCS piping in the vicinity of the RCP motor is approximately 550°F.
Calculations were located that provide the following information:
The calculated temperature at base of support steel adjacent to the reflective insulation covering is 325°F.
The calculated temperature of the stainless steel jacket sheath in contact with concrete is 195°F with an ambient temperature of 110°F At power, the external sheath temperature would be expected to be approximately 195°F to 325°F depending on the location and other material in contact with the jacket.
During outages and shutdown conditions, the ambient temperature generally ranges between 70°F to 95°F.
Background RAI 8:
Dominion's letter dated May 13, 2010, states, "To reduce oil misting, which is common in Reactor Coolant Pump (RCP) motor designs, resetting of the labyrinth seal would be required each refueling cycle. Currently, industry standards for Westinghouse RCPs are taken from Technical Bulletin (TB)-04-5 Westinahouse RCP Motor Recommended 1-Year, 5-Year, and 10-Year Insoection and Maintenance'."
8.1 Discuss the actions NA has taken with North Anna follows the manufacturer's recommendations for maintenance under regard to manufacturers recommendations Technical Bulletin (TB)-04-5 'Westinghouse RCP Motor Recommended 1-Year, 5-Year, and to recommendations from the Electrical and 10-Year Inspection and Maintenance". In the 10-Year Inspection and Maintenance Power Research Institute (EPRI) to eliminate or section Part 27.g. (Upper Bearing Assembly) states:
significantly reduce misting.
"Reset upper guide bearing shoes (0.004" to 0.006"), runner seal clearances (0.007" to 0.012"), and flywheel seal clearance (0.012" to 0.018"). Record results."
The 1O-Year Inspection and Maintenance section Part 31.c. (Lower Bearing Assembly) states:
"Reset quide bearinq (0.004" to 0.006") and seal clearances (0.007" to 0.012")."
NRC Question 8.2 Discuss RCP maintenance schedule with respect to the 1, 5 and 10 year manufacturers recommended maintenance. Specifically address such items as Flywheel Seal Upgrade, Top Oil Pot Cover Modification, Truncated Flow Chamber Modification, Viscosity Pump Upgrade and other manufacturer recommendations for maintenance items to reduce oil leaks and misting issues for each RCP. If the maintenance schedule is different from the manufacturers' recommended schedule, explain the differences and any impact on safe shutdown.
8.3 Discuss post maintenance effectiveness of the modifications made and when the last time these RCPs have had these maintenance items performed on them, and controls in place to assure that 10 year manufacturers recommended maintenance frequencies are not exceeded.
Serial NO.10-114D Docket No. 50-338 Response to Request for Additional Information Exemption Request Oil Collection System Page 6 of 22 Dominion Response This step is performed at a vendor rewind facility on a 6 refueling outage (RFO) (9 Year) frequency. In order to reduce the oil misting that has been described, this maintenance would have to be completed every refueling cycle. That is not feasible. A refurbishment of this type cannot be completed during a normal refueling outage. In order to replace the labyrinth seals, every cycle would require a spare motor for replacement of every installed motor each refueling cycle.
EPRI Document Number 1013456 "Nuclear Maintenance Applications Center: Reactor Coolant Pump/Reactor Recirculation Pump Motor Lubrication Oil Systems Maintenance Guide" recommends performing PMs in line with the vendor recommendations. North Anna follows those recommendations.
The RCP motor rewind vendor for North Anna, Electric Motor Contractors (EMC), was contacted to discuss the work performed on the RCP motors. North Anna follows the OEM recommended schedule for upgrades and they are performed during refurbishment.
Refer to attached Table 1 for a detailed list of maintenance/modifications performed on these motors. This work was performed during the latest refurbishment or rewind of the motors. Some motors have already have had certain maintenance/modifications performed and therefore the lists of work performed by EMC may be different depending on the motor. Each motor is tracked by its serial number performed on these motors.
Post Maintenance Testing (PMT) is conducted under the PMT Program. The PMT program has proven to be effective by ensuring that required maintenance is performed at the correct interval. When a modification is made to a Reactor Coolant Pump Motor, the Design Change Process updates the PMT to ensure that the modification was a success and to measure the effectiveness of the modification. As stated in response 8.1, the modifications are performed in accordance with manufacturer's recommendations.
This includes the normal 10 year refurbishment process. The Unit 1 RCP motors have a 1 year (18 month) PM performed everv RFO. Attached Table 2 includes the PMs that
NRC Question 8.4 Compare differences in maintenance schedules and leakage rates between RCPs A, B, and C.
8.5 Discuss RCP oil spray sources such as from insufficient baffling of vents from upper oil enclosure for the lift pump, and unsealed penetrations for passage of conduit and actions NA is taking to address these apparent design issues.
Serial NO.10-114D Docket No. 50-338 Response to Request for Additional Information Exemption Request Oil Collection System Page 7 of 22 Dominion Response have been, and are, performed on the RCP motors on a recurring basis. All PMs are controlled by established preplanned work orders under the recurring task evaluation (RTE) process. Deferral of any of these work orders will require a RTE that will be evaluated by Engineering on a case by case basis.
North Anna's RCPs are refurbished every nine years by an offsite vendor. The maintenance for every motor is the same. The past refurbishments (installed dates) and serial numbers for the RCP motors are shown in attached Table 3.
It should be noted that due to scheduling and discovery of partial discharge on RCP Motor -1 s81p355, RCP Motor-1s81p398 was deferred one outage until 2010.
Walkdowns of containment show that as the motor ages (time since refurbishment) there is an increase of leakage. Therefore, since RCP Motor-1s81p398 was the oldest it had the most leakace.
The source of the oil misting is neither from insufficient baffling of vents from upper oil enclosure for the lift pump nor unsealed penetrations for passage of conduit. Rather, the source is from small amounts of oil migrating through the lower reservo ir oil seal located just inches above the oil level into the motor ventilation ports above the seals. The small amounts of oil (less than 1-1/2 gallons over an 18 month period for the worst-case motor) find an exit path as mist through the outlets of the RCP motor stator air coolers.
Industry experience at ANO and Haddam Neck show that oil-soaked absorbent pipe insulation can lead to fires. OE shows that these fires were caused by large breaks in sections of the RCP Oil System piping not protected by an oil collection system resulting in significant oil discharge over a relatively short period of time.
At North Anna, the RCP oil system is protected by an oil collection system with piping connected to an oil storage tank. This oil collection system is verified to be functional every 18 months in accordance with procedures 1/2-PT-108.5. This inspection also verifies that there are no open penetrations (for example, no new unsealed conduit penetrations) in the oil collection system enclosures. The oil piping external to the collection enclosures is seal-welded, seismically supported piping rather than the threaded fittings and plastic pipe found at ANO and Haddam Neck. Therefore, repeat events similar to ANO and Haddam Neck are not considered credible at North Anna.
NRC Question Serial NO.10-1140 Docket No. 50-338 Response to Request for Additional Information Exemption Request Oil Collection System Page 8 of 22 Dominion Response Over the past few outages (N1-R-20 and N2-R-19), oil misting has been observed at the outlets of the RCP motor stator air coolers.
Two recent design changes have improved the effectiveness of the oil collection system.
To enhance the baffled ventilation openings of the RCP oil lift pump enclosure, modifications to these vents were performed to ensure all oil will be contained in the event of pressurized oil leakage inside these enclosures. To address oil misting, oil collection trays have been installed on the stator coolers with piping connected to the RCP Oil Collection System..These collection trays have been installed for six months on Unit 2 and a walkdown of RCP A on October 14, 2010 verified that the oil collection trays were performing as designed. Evidence of oil inside the trays indicates that the oil misting has been collected with the exception of a very insignificant amount (several drops of oil were noted on the external surface of the collection tray). This insignificant amount is not capable of creating a hazard. As defense-in-depth, additional Engineering inspections are required and the Annunciator Response Procedures were enhanced to facilitate early detection of any oil misting that may be deposited on insulation and to provide for immediate inspection for oil misting if a RCP Motor Low Oil Level alarm is received in the Main Control Room.
In conclusion, Rep oil misting has been controlled to collect all oil misting with the exception of an insiunificant amount (a few drops over a six month period).
Serial No. 10-1140 Docket No. 50-338 Response to Request for Additional Information Exemption Request Oil Collection System Page 9 of 22 Table 1 - RA18.2 {Status of RCP Motor Modifications}
RCP Motor SIN 2S-81 P777 07/12105 Sheet 1 of 4 Modification I Upgrade Status Lower Bearing Reservoir Level Indicator Reference Procedure RCPM-DOM-NA-10, Modification (Multi-Port Drain Sump) includes vent line modification Steel Pan and Standpipe Upgrade Previously Completed Replace Magnetrol Level Switches Performed by EMC Complete Motor Painting Performed by EMC Flywheel Anti-Rotation Pawl Upgrade Previously Completed Motor Heater Upgrade Performed by EMC Dual-Element RTDs Performed by EMC Rep Motor SIN 3S-81 P355 06/28/07 Sheet 2 of 4 Table 1 - RA18.2 {Status of RCP Motor Modifications}
Modification I Upgrade Status Upgrade to Viscosity Pumping System Previously Completed Motor Oil Lift System Modification Previously Completed Thrust Runner & Lower Thrust Bearing Support Previously Completed Truncated Flow Chamber Modification Previously Completed Lower Bearing Reservoir Level Indicator Mod.
By EMC lAW RCPM-DOM-NA-10 Upgrade to Viscosity Pumping System Previously Completed Motor Oil Lift System Modification Previously Completed Lower Oil Pot Joint Modification See Steel Oil Pan & Standpipe Upgrade Complete Motor Painting Performed by EMC Replace Magnetrol Level Switches Performed by EMC Motor Heater & Straps Upgrade Performed by EMC Lower Bearing Cooling Coil Connect Upgrade By EMC lAW RCPM-DOM-NA-10 Flywheel Anti-Rotation Pawl Upgrade Previously Completed Dual Element RTD Upgrade Performed by EMC Relocation of Lower Guide Bearing RTD Previously Completed Upgrade Steel Oil Pan and Standpipe Upgrade Performed by EMC Thrust Runner Seal Upgrade Performed by EMC lAW RCPM-DOM-NA-10
Rep Motor SIN 1S-81P777 09/17/08 Serial No. 10-1140 Docket No. 50-338 Response to Request for Additional Information Exemption Request Oil Collection System Page 10 of 22 Modification I Upgrade Status Upgrade to Viscosity Pumping System Previously Completed Motor Oil Lift System Modification Previously Completed Thrust Runner & Lower Thrust Bearing Support Previously Completed Truncated Flow Chamber Modification Previously Completed Lower Bearing Reservoir Level Indicator Performed by EMC Modification lAW RCPM-DOM-NA-10 Upgrade to Viscosity Pumping System Previously Completed Motor Oil Lift System Modification Previously Completed Stator Rewind Completed by EMC Lower Oil Pot Joint Modification Superseded by Steel Oil Pan & Standpipe Upgrade Complete Motor Painting Performed by EMC (Alaron)
Replace Magnetrol Level Switches Performed by EMC Motor Heater & Straps Upgrade Performed by EMC Lower Bearing Cooling Coil Connection Performed by EMC Upgrade lAW RCPM-DOM-NA-10 Flywheel Anti-Rotation Pawl Upgrade Previously Completed Dual Element RTD Upgrade Performed by EMC Relocation of Lower Guide Bearing RTD Applies only to Surry Upgrade Steel Oil Pan and Standpipe Upgrade Performed by EMC Thrust Runner Seal Upgrade Performed by EMC lAW RCPM-DOM-NA-10
Serial No.1 0-114D Docket No. 50-338 Response to Request for Additional Information Exemption Request Oil Collection System Page 11 of 22 Table 1 - RAI 8.2 (Status of Rep Motor Modifications)
Rep Motor SIN 1S-81P355 07115/09 Sheet 3 of4 Modification I Upgrade Status Upgrade to Viscosity Pumping System Previously Completed Motor Oil Lift System Modification Previously Completed Thrust Runner & Lower Thrust Bearing Support Previously Completed Truncated Flow Chamber Modification Previously Completed Stator Rewind Completed by EMC Lower Bearing Reservoir Level Indicator Performed by EMC Modification (Includes Multi-port Drain Sump lAW RCPM-DOM-NA-10 Cover) (Includes Lower Oil Pot Vent Line Modification)
Lower Oil Pot Joint Modification Superseded by Steel Oil Pan & Standpipe Upgrade Complete Motor Painting Performed by EMC Replace Magnetrol Level Switches Performed by EMC Motor Heater & Straps Upgrade Performed by EMC Flywheel Anti-Rotation Pawl Upgrade Previously Completed Lower Bearing Cooling Coil Connection Performed by EMC Upgrade lAW RCPM-DOM-NA-10 Dual Element RTD Upgrade Performed by EMC Relocation of Lower Guide Bearing RTD Applies only to Surry Upgrade Steel Oil Pan and Standpipe Upgrade Performed by EMC Thrust Runner Seal Upgrade Performed by EMC lAW RCPM-DOM-NA-10
Serial No. 10-1140 Docket No. 50-338 Response to Request for Additional.Information Exemption Request Oil Collection System Page 12 of 22 Table 1 - RAI 8.2 (Status of RCP Motor Modifications)
RCP Motor SIN 2S-81 P355 09/02/10 Sheet 4 of 4 Modification I Upgrade Status Upgrade to Viscosity Pumping System Previously Completed Motor Oil Lift System Modification Previously Completed Thrust Runner & Lower Thrust Bearing Support Previously Completed Truncated Flow Chamber Modification Previously Completed Stator Rewind Performed by EMC Lower Bearing Reservoir Level Indicator Performed by EMC lAW RCPM-DOM-NA-10 Modification (Includes Multi-port Drain Sump Cover and Lower Oil Pot Vent Line Modification)
Lower Oil Pot Joint Modification Superseded by Steel Oil Pan & Standpipe Upgrade Complete Motor Painting Performed by EMC Replace Magnetrol Level Switches Performed by EMC Motor Heater & Straps Upgrade Performed by EMC Lower Bearing Cooling Coil Connection Performed by EMC lAW RCPM-DOM-NA-10 Upgrade Flywheel Anti-Rotation Pawl Upgrade Previously Completed Dual Element RTD Upgrade Performed by EMC Steel Oil Pan and Standpipe Upgrade Performed by EMC lAW RCPM-DOM-NA-10 Main Key Upgrade Performed by EMC lAW RCPM-DOM-NA-10 Thrust Runner Seal Upgrade Performed by EMC lAW RCPM-DOM-NA-10
Serial NO.10-1140 Docket No. 50-338 Response to Request for Additional Information Exemption Request Oil Collection System Page 13 of 22 Table 2 - RA18.3 (Status of Rep Motor Periodic Maintenance)
Sheet 1 of 2 PM Description Work Against RE514251 EPM Procedure 0-EPM-1405-01; 01-RC-P-1 01-RC-P-1 A-MOTOR RE526536 Obtain Motor Oil Samples 01-RC-P-1 A-MOTOR RE501222 EPM Procedure 0-ECM-1405-01 01-RC-P-1A-MOTOR Teardown/Inspect/Motor RE501223 Remove/Clean/lnspectiReinstall Coolers 01-RC-P-1 A-MOTOR RE528118 Online Testing Of Large Motors 4160V 01-RC-P-1A-MOTOR RE528117 Online Testing Of Large Motors 4160V 01-RC-P-1 A-MOTOR RE528119 Offline Testing Of Large Motors 4160V 01-RC-P-1 A-MOTOR RE87991 EPM Procedure DC STEP, SURGE, TESTING Of 01-RC-P-1 A-MOTOR RCP Motors RE88378 EPM Procedure Vendor Perform Motor Rewind 01-RC-P-1 A-MOTOR During Rebuild RE88385 Engineering Evaluate Motor History PM Data 01-RC-P-1A-MOTOR History RE514252 EPM Procedure 0-EPM-1405-01 ; 01-RC-P-1 01-RC-P-1B-MOTOR RE526537 Obtain Motor Oil Samples 01-RC-P-1 B-MOTOR RE501224 EPM procedure 0-ECM-1405-01 Teardown Inspect 01-RC-P-1B-MOTOR Motor RE501225 Remove Clean Inspect Reinstall Coolers 01-RC-P-1 B-MOTOR RE528120 Online Testing Of Large Motors 4160v (Pre-01-RC-P-1 B-MOTOR Planned)
RE528122 Offline Testing Of Large Motors 4160V 01-RC-P-1 B-MOTOR RE528121 Online Testing Of Large Motors 4160V 01-RC-P-1 B-MOTOR RE87992 EPM Procedure DC Step Surge Testing RCP o1-RC-P-1 B-MOTOR Motors RE88379 EPM Procedure Vendor Perform Motor Rewind 01-RC-P-1 B-MOTOR During Rebuild RE88386 Engineering Evaluate Motor History PM Data 01-RC-P-1B-MOTOR History RE514253 EPM Procedure 0-EPM-1405-01; 01-RC-P-1 01-RC-P-1 C-MOTOR RE526538 Obtain Motor Oil Samples 01-RC-P-1 C-MOTOR RE528191 Offline Testing Of Large Motors 4160V 01-RC-P-1 C-MOTOR
Serial No. 10-114D Docket No. 50-338 Response to Request for Additional Information Exemption Request Oil Collection System Page 14 of 22 Table 2 - RAI 8.3 (Status of Rep Motor Modifications)
Sheet 2 of 2 PM Description Work Against RE501226 EPM Procedure 0-ECM-1405-01 Teardown Inspect 01-RC-P-1 C-MOTOR Motor RE501227 Remove Clean Inspect Reinstall Coolers 01-RC-P-1 C-MOTOR RE528123 Online Testing Of Large Motors 4160V (Pre-01-RC-P-1 C-MOTOR Planned)
RE87993 EPM Procedure DC Step Surge Testing RCP 01-RC-P-1C-MOTOR Motors RE88380 EPM Procedure Vendor Perform Motor Rewind 01-RC-P-1 C-MOTOR During Rebuild RE88387 Engineering Evaluate Motor History PM Data 01-RC-P-1 C-MOTOR History RE528124 Online Testing Of Large Motors 4160V 01-RC-P-1 C-MOTOR
Serial No.10-114D Docket No. 50-338 Response to Request for Additional Information Exemption Request Oil Collection System Page 15 of 22 Table 3 - RA18.4 (Rep Motor Replacement Schedule)
Sheet 1 of 1 Motor Serial Maintenance Date (Location)
(Installed In Plant) 1s81p398 (was1-RC-P-1A, now March 2000 SPARE)
(Not Currently Installed) 3s81p777 (1-RC-P-1C)
March 2001 2s81p777 (2-RC-P-1A)
October 2005 3s81p355 (1-RC-P-1B)
October 2005 1s81p777 (2-RC-P-1 B)
September 2008 1s81p355 (2-RC-P-1C)
April 2010 2s81p355 (was SPARE, now 1-September 2010 RC-P-1A)
Serial NO.1 0-1140 Docket No. 50-338 Response to Request for Additional Information Exemption Request Oil Collection System Page 16 of 22 Table 4 - RA15.1 (Insulation Types in Unit 1 Cubicle 1/Loop Room 1)
LENGTH INSULATION INSULATION INSULATION JACKET MARK NUMBER 00 (IN)
(FT)
THICKNESS VOLUME TYPE MATERIAL (IN)
(FT3)
Reflective Metal 29"-RC Insulation 1/8" Stainless 2501R-01 38 11.7 4
43 (RMI)
Steel 29"-RC Thermal-1/8" Stainless 2501R-01 38 3.54 4
12.97 Wrap Steel 29"-RC 1/8" Stainless 2501R-01 35.5 5.13 4
17.68324 RMI Steel
!'~Ji:.£¥:,T,"::
.,~.,_",,:,~,,'ii
'~\\f "'.:
i;Yc~:,,~;,~r ',:;.:1
~'
c',,,
'_W"*""'*~'
271/2"-RC 1/8" Stainless 2501R-01 35.5 9.3 4
32.05733 RMI Steel 27 1/2"-RC 1/8" Stainless 2501R-01 35.5 12.5 4
43 RMI Steel I '::'~"';:-)f',li~,;.
rs
""-,,,0 r"" __
crt I ~
,.ii',....
'li,
.~
-y, 31"-RC-2501R-1/8" Stainless 04 53.5 3.1 3
11.46354 RMI Steel 31"-RC-2501R-1/8" Stainless 03 69.7 3.1 3
14.75043 RMI Steel 31"-RC-2501R-1/8" Stainless 02 72.1 1.55 3
7.618689 RMI Steel 31"-RC-2501R-1/8" Stainless 01 74.4 0.78 3
3.951338 RMI Steel 31"-RC 2501R-Q1 FOIL 1/8" Stainless AREA 35.5 20.3 4
635.82 RMI Steel 31"-RC 1/8" Stainless 2501R-01 38 11.5 3
37.8 RMI Steel 31"-RC Thermal-1/8" Stainless 2501R-01 38 2.7 4
9.9 Wrap Steel 31"-RC-2-250 Fiberglass 1R-Q1 N1A 4.5 3
4.35 Tempmat Cloth
- 'g'--, -:.,'"
~;
i:
,_,,0;
"!';I;r~
I
-'~
"j~'. '"
Serial No. 10-1140 Docket No. 50-338 Response to Request for Additional Information Exemption Request Oil Collection System Page 17 of 22 Table 4 - RA15.1 (Insulation Types in Unit 1 Cubicle 1/Loop Room 1)
LENGTH INSULATION INSULATION INSULATION JACKET MARK NUMBER 00 (IN)
(FT)
THICKNESS VOLUME TYPE MATERIAL (IN)
(FT3) 2 1/2"-WGCB-Thermal-1/8" Stainless 4-601-03 2.875 20 2
4.25 Wrap Steel Ii iel,."
lin'01'liite"
,"iV"I" 2 1/2"-WGCB-Therm al-1/8" Stainless 5-601-03 2.875 33.1 2
7.04 Wrap Steel l i"'~':
C~~'
- 'lc,,%~~e
.~
~"I~" ""L~ibr:"~i\\'\\ I ",;:jfi;,"~;C%,,"
I".
e,~
~
<I, 3"-WGCB 601-03 Thermal-0.016 inch Thermal Wrap 3.5 1.75 2
0.42 Wrap Stainless Steel 3"-WGCB 0.016 inch 601-03 PAROC 3.5 8.1 3
3.45 PAROC Stainless Steel 3"-WGCB 601-03 3.5 9.6 0
0 NONE NONE i~(',~{,;"""""
",,"IJ:!C"'"
n,
~£s l~'!' ~,K
~,.
'~i
~
Serial NO.1 0-1140 Docket No. 50-338 Response to Request for Additional Information Exemption Request Oil Collection System Page 18 of 22 Table 4 - RA15.1 (Insulation Types in Unit 1 Cubicle 1/Loop Room 1)
LENGTH INSULATION INSULATION INSULATION JACKET MARK NUMBER 00 (IN)
(FT)
THICKNESS VOLUME TYPE MATERIAL (IN)
(FT3) 2"-CH-14-1502-02 2.375 10.9 0
0 NONE P
NONE
~,
'c 3"-CH-A01-1/8" Stainless 1502-01 3.5 7.5 3
3.19068 RMI Steel 2"-CH-A02-1/8" Stainless 1502-01 2.375 9.3 3
3.271674 RMI Steel 2"-CH-5-1502-1/8" Stainless 01 2.375 5.9 3
2.075578 RMI Steel I.t
~,
~. ~
- ~ ~
~
~~ ~
~
I
~,
c
~ x,x ~, ~
~
- ,,,gg
~,X
~
~ ~
4"-RC-14-1502-1/8" Stainless
~
4.5 15.3 3
7.51037 RMI Steel
,c~~ 'c eess 8"-RC 1/8" Stainless 2501R-01 8.625 23.5 3
17.88~8 RMI Steel 6"-RC-16-1502-1/8" Stainless 01 6.625 2.6 3
1.637882 RMI Steel
'~
~~
,~
,,~~
~
6"-RC-17-1502-1/8" Stainless 01 6.625 5.6 3
3.527747 RMI Steel It, '
~.:
~
~,:,X',
~
,'~.
3/8"-SS-103-0.010" ICN9-01 0.375 74.2 1.5 4.553 Cal-Sil Stainless Steel 3/8"-SS-102-0.010"
~
0.375 32.25 1.5 1.979 Cal-Sil Stainless Steel
, ~'
'~
,':~..' 2~
~
~
--- -~-- - ~
~----
Serial No. 10-1140 Docket No. 50-338 Response to Request for Additional Information Exemption Request Oil Collection System Page 19 of 22 Table 4 - RA15.1 (Insulation Types in Unit 1 Cubicle 1/Loop Room 1)
LENGTH INSULATION INSULATION INSULATION JACKET MARK NUMBER OD (IN)
(FT)
THICKNESS VOLUME TYPE MATERIAL (IN)
(FT3) 3/8"-SS-103-ICN9-Q1 0.375 8.9 1.5 0.546 TempMat NONE 3/4"-RC 1502-Q1 1.05 0
0 0
N/A N/A
~,
~'
j,
"~""'C'~~~;~('
';}
fl" d~'".."
f of
~ - "
3/8"-SS-100-ICN9-Q1 TempMat 0.375 9.5 1.5 0.583 TempMat NONE 3/8"-SS-100-ICN9-Q1 0.016 inch PAROC 0.375 3.42 1.5 0.21 PAROC Stainless Steel 3/8"-SS-100-0.010" ICN9-Q1 0.375 14.8 0
0 Cal-Sil Stainless Steel 3/4"-RC 1502-Q1 1.05 0
0 0
N/A N/A
Serial No. 10-1140 Docket No. 50-338 Response to Request for Additional Information Exemption Request Oil Collection System Page 20 of 22 Table 4 - RA15.1 (Insulation Types in Unit 1 Cubicle 1/Loop Room 1)
LENGTH INSULATION INSULATION INSULATION JACKET MARK NUMBER OD (IN)
(FT)
THICKNESS VOLUME TYPE MATERIAL (IN)
(FT3) 3/4"-RC 1502-01 1.05 2.5 1
0.11 TempMat SS Mesh 2"-RC-45-1502-01 2.375 6.5 1
0,48 TempMat SS Foil 2"-RC-45-1502-1/8" Stainless 01 2.375 2
2 0.5726861 RMI Steel 2"-RC-45-1502-1/8" Stainless 01 2.375 2
2 0.7035859 RMI Steel 2"-RC-45-1502-1/8" Stainless 01 2.375 7
4 3.894266 RMI...
~ IVI,::,I,"III
~! !I!M':H III'VVH'H,VV, VVVVdVd"
",H"",;:,:HVd':,H H,
14"-RH-1-1502-1/8" Stainless 01 14 2.5 3
8.84 RMI Steel 14"-RH-1-1502-1/8" Stainless 01 14 21.6 4
33.9292 RMI Steel
,H,dk;VHHHH~-
VH,
"" "!!!!!@!!:@.Illillilirv :,,:,;,:
- !H; !!!!Hlli:"I!!!!:HHllilHllillilli:H_
12"-RC 1/8" Stainless 1502-01 12.75 7.3 3
7.525096 RMI Steel VHV"dBdHHuH,
- 'V
- ;"
3/4"-RC 1/8" Stainless 1502-01 1.05 16.3 3
4.320672 RMI Steel 3"-RC-215-1502-01 3.5 2,4 1
0.24 TempMat SS Mesh 2"-RC-55-1502-01 2.375 5.2 1
0.38 TempMat SS Foil 2"-RC-53-1502-1/8" Stainless 01 2.375 14.9 3
5.241714 RMI Steel 2"-RC-216-1502-01 FOIL 1/8" Stainless AREA 2.375 25.7 3
79.94 RMI Steel l1li
- !!lHF
- ,ii Thermal-1/8" Stainless 1-RC-E-1A N/A N/A 4
57.94 Wrap Steel
,RiC::
I I:::H:,,!!>!!!
" 'dA"L~
1"-RC-71-153A-03 1.315 25.2 0
Serial No. 10-1140 Docket No. 50-338 Response to Request for Additional Information Exemption Request Oil Collection System Page 21 of 22 Table 4 - RAI 5.1 (Insulation Types in Unit 1 Cubicle lILoop Room 1)
LENGTH INSULATION INSULATION INSULATION JACKET MARK NUMBER 00 (IN)
(FT)
THICKNESS VOLUME TYPE MATERIAL (IN)
(FT3)
I', ~ '-
""""ir I~~,~
~
a-
~~,',".,,£=, ~,
,r"':..
- ,:Lee.,
3/4"-RC-169-Silicone Impreg 153A-Q3 1.05 1
3 0.27 TempMat Cloth 3/4"-RC-169-153A-Q3 1.05 42.67 0
- tS." ;$1;';;.
"~
\\j;l "I',,,,.~ ~~'~:
'iC,
- c, 27-1I2""RC.......
2501R-Q1, (1-RC-P-1A cold leg outlet Fiberglass nozzle)
NJA NJA 1 and 2 4.04 Tempmat Cloth
':+.
';..\\'
~
"~i'~,,'~ rEi<
~ ~~ _ ~'i.':;
'"'~....
~..~~-J;!;i' e'
1-RC-P-1A, f:'iberglass pump casing NJA NJA 1
2.83 Tempmat Cloth
Serial NO.10-114D Docket No. 50-338 Page 22 of 22 Editorial correction of previous response to RA17.2 shown in italic font 7.2 Discuss in detail manual fire suppression capability including CO2 extinguisher's sufficiency to suppress a postulated RCP oil mist fire in FA 1-
- 1. Include a description of the floor elevation relative to the postulated fire location.
Manual fire suppression equipment for the Unit 1 Containment consists of a 100 Ib wheeled C02 unit on each floor of Containment, three (3) C02 extinguishers and one (1) dry chemical extinguisher (Unit 2 only) at the personnel entrance to Containment (elevation 291'-10"), and a dry standpipe system with 2 hose stations on the top elevation (291'-10") and 3 hose stations on the level below (elevation 262'-10"). Hoses are not normally connected to the hose valve. A fire brigade equipment locker is provided outside of the personnel entrance to Containment. The locker contains 200 feet of 1-1/2" hose, one - 5 gallon can of foam, one - foam eductor, two spanner wrenches, one 1/2" nozzle, and two -spare 1-1/2" hose coupling washers.
The C02 extinguishers and the dry chemical extinguisher are rated for a Class B fire (flammable and combustible liquids). The initial fire fighting attack can be made using either a C02 or dry chemical extinguisher, followed by hose if needed. If required to extinguish the oil fire, foam can be used.
Serial No. 10-1140 Docket No. 50-338 DRAWINGS FOR REACTOR COOLANT SYSTEM PIPING ORIENTATION 11715-FM-093A Sheet 1, FlowNalve Operating Diagram, RCS NAPS Unit 1 Loop 1 N-07129-1-59T562AB404452 Rev. 1, Transco, Inc. Coolant Pump Sections N-07129-1-59T562AB4044102 Rev. 0, Transco, Inc. Coolant Loop Cold Legs VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)
NORTH ANNA UNIT 1
-- --_.._--. v
_._. ~. _. _._._. - - - _._._--._.-._._.- --- - - --- - -_._._.- --_._.--- - _._._._._._._._._.- --- - _._._.- _._._._.--- - - - --- _._._-- - --- -- _._.- - _._._.- - _._.- - - -_._._._.-._._._.-.--- --- --- --_._._-_.- _.- - - _._.- - _._._-- - - -
I l
~
5
~
\\
.;".'.' ': " ~~~r~~
l lX" J*\\l'l Q/I(.!o ";Q DOMINION V ENDOR DR A WI N G RE VI SION I!fy11 1lt1 DEstRI~ l l [lj ' SI\\'"TW: S "" t 1111 I5Sll0fCllDJjSl!UlH)l r1'lXJ ]*11'l KRFe I.
UIIl tCh.lll'Wl 'ez.....
!>><N:.;;'~~I.;'I~~~ ~~&!,£,':-IO-..
or.-.
- ,~
- '**.*t*.'1~,***. *J
.'t.~*i1
- I
'~
r Kr~
-~"\\~5
~!
1-""1
~
~~/~ '
[
'.~
I,\\r-/
<::J
..,:,,~
'", >/."' *~ r'~'"
.*. ; P ~i',~. -.;:. *,-
.* _:~<"
- . ~,, r
_ :;t (j *u.~* ~ 9 -<> *
....... ~-:..""' '"; '.~
._I '; *l!, ~
_ <zH :5".U,d
,I
.'~..,
'0- ',1-..._-_.:i" r ",.,'" '"
__---;;-:1.
1
~
i I
~
.-\\'1""'. --' --
~. ~ ".'..
'....J~~~
- 'i" "'~'"
t.
~'~-
~- -
~
I J2 Z~'~"
I'
_..t,. ~
~.
./
h~
1" I
~I _ '
_~
, /
._ ' b" Ii '
~
, _cZ.V.....4,3 *'fj 4- -
- ~.*.!.=:.=;.c~
)--
~.* _ - - :::.- --- -
A 2""" " "
..ji
'~lu-1J/
-'~".'T/:!'
' j 00U21 WkK)
-j----
~'
- 14 ' "","",'. '>-3/)
~,
~i
~l.~_...
~~
~.,..;!
..L- ',-" ~
, I
~. 3 ~'DE. XP=' LOCI"
~
~.
- \\..ClOP2
~:~. _OOP3 r Ut£'J:; U"'"
M""'::S"'-r> T~""",,"'::;:""" ) ""
~~.&T~l~ :
f~ tit~~
'to o:
._ 1!.fJ2 i'! Jlll
- ?t ll'~O::'-~
- ;Ji'h
- Stir;.
.~
- ' _ ZC1 ;.r 'e.~
~
J
_-'J:'1A ;)
i' "(J.')A I
?'
_.:;: ~ *.!c;. ","
/,--f/:ill
~_ _
~'1j t
~U
-.~
~ ! \\
\\ \\
.\\
IWX~ " "*;:ii.~;;.,;I'i'&jB:'i5iJ TRAN8CO; INC.
- ~
- ;
l '~ ';
i~ ~
+_
~\\ *lt..l i,
)
l i J
'_5I, " ~~ff_<S'
__.,;. ~~~_.;;,::::,, _,.w i l.l!UY
- t{6 '.t e.um. '1'"
')'io-~~..._
._ &( ' -4C'1ffJ1.*"
>1:~'.! CU~
-!:~
._"".,...,t:"....,*r
.. __ tYJZ.J ~ lt.. !: fJ 0 31 1lf.1rll
_/"" -S:1~
,_ 5:til "'i' C<mWr/NS*
RIl l
../*-*U:,?iA
~_2Oi_ 'LClITDU r
. ~* :.::.::.:~.=f-"""',",- s:!&
1
<ti
+
t l+- -
~
I
~ i r -oi'?
>t.
~ i i-4 i
iI..~
- ~l
~~
'+.-;'1-7.;
I Ivl I'.
v
,t.....
~
~,..,,:
- ' ::': ;' i:::" ":'""f, : ~.* C
~
"i~..... _-'.:""
e
)<l'f ' ;
'I
~..
I, J
~,
"'4,_, ~/
,.~
~.;
," ~.:t.,::;~.;:::g~u-
- ~
~.
'j ?,.:-.ih
~ '"V "L J\\' -".,
1
" "~'
i
'-'~ '-~~::: "t~-::'"
.u ;;*....,._...
II
(
I,tr-
"1.(/ ;1;."
..;)'-;;,.. ~.
I J.
I
~
CD
.. ~
~~
~L I-I I
~
1 ~ ;
j
~
H r
[
s
~
$1
~
~
~~
~ n
[08 '7 1 5 1.
FROM RUU Mu,. ATOR Il1lS *FM *0'l6B.SH.y loB-B) 117'5.n~
- 0%S. S~
'oF ' 8 '
~;~:: ~::;;.SH. 1
<1J7J5*'M*O'15C,SH. 1
'~F-a, FROH 5~ F E T Y I ~EC TION 1-I....
I
... /
r
~
L-.-------====_=__=
=4_+=:
__"""~,- -- - - ---- ------ -- -- ---- -;--~.h'~
It, 1._
liS ilJis!~~~L~
_r
- "1 -- '-'*1