ML17305A476

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LER 89-024-00:on 891212,start of Reactor Coolant Pump 2A Motor Caused Voltage Perturbation in Electrical Sys That Tripped Radiation Monitors.Investigation Underway.All Actuations reset.W/900111 Ltr
ML17305A476
Person / Time
Site: Palo Verde Arizona Public Service icon.png
Issue date: 01/11/1990
From: Bradish T, James M. Levine
ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
192-00616-JML, 192-616-JML, LER-89-024, LER-89-24, NUDOCS 9001180411
Download: ML17305A476 (18)


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.'ACCELERATED DISII&3UTION DEMONSTlRATION SYSTEM REGULATORY- INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9001180411 DOC DATE: 90/01/11

~ NOTARIZED: NO Palo Verde Nuclear Station, Unit 1, Arizona Publi 05000528 DOCKET.4'ACIL:STN-50-528 AUTH. NAME AUTHOR AFFILIATION BRADISH,T.R. Arizona Public Service Co. (formerly Arizona Nuclear Power LEVINE,J.M. Arizona Public Service Co. (formerly Arizona Nuclear Power RECIP.NAME RECIPIENT AFFILIATION

SUBJECT:

LER 89-024-00:on 891212,ESF actuation during reactor coolant pump test.

DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR TITLE: 50.73/50.9 Licensee Event Report (LER),

NOTES j ENCL L SIZE:

Incident Rpt, etc.

R 05000528 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD5 LA 1 1 PD5 PD 1 1 CHAN,T '1 1 DAVIS,M. 1 1 INTERNAL: ACRS MICHELSON 1 1 ACRS MOELLER 2 2 ACRS WYLIE 1 1 AEOD/DOA 1 1 AEOD/DS P/TPAB 1 1 AEOD/ROAB/DSP . 2 2 DEDRO 1 1 NRR/DET/ECMB 9H 1 '1 NRR/DET/EMEB9H3 1 1 NRR/DET/ESGB 8D 1 1 NRR/DLPQ/LHFB11 1 1 NRR/DLPQ/LPEB10 1 1' NRR/DOEA/OEAB11 1 1 NRR/DREP/PRPB11 2 NRR/DST/SELB 8D 1 1 NRR/D SICB 7E 1 1 NRR/DST/SPLB8D1 1 1 SZ. XB 8E 1 1 NUDOCS-ABSTRACT 1 1 REG FIL 02 1 1 RES/DSIR/EIB 1 1 GN5 FILE 01 1 1 EXTERNAL EG&G WILLIAMSI S 4 L ST LOBBY WARD 1 1 LPDR 1 1 NRC PDR 1 1 NSIC MAYS,G 1 1 NSIC MURPHYIG A ~

'1 1 NUDOCS FULL TXT 1 1 NOTES 1 1 NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISHUBUTION LISTS FOR DOCUMENTS YOU DON'T NEED1 FULL TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES REQUIRED: LTTR 40 ENCL 40

I Arizona Public Service Company'A'II

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I~ ~ r I p P.O, BOX 52034 ~ PHOENIX, ARIZONA85072-2034 JAMES M. LEVINE 192-00616-JML/TRB/SBJ viC5 P4Esm<NT NUCLEAR PAGO~0 .'-Ct~ January 11, 1990 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555

Dear Sirs:

Sub j ect: Palo Verde Nuclear Generating Station (PVNGS)

Unit 1 Docket No. STN 50-528 (License No. NPF-41)

Licensee Event Report 1-89-024-00 File: 90-020-404 Attached please find Licensee Event Report (LER) No. 1-89-024-00 prepared and submitted pursuant to 10CFR50.73. In accordance with 10CFR50.73(d), we are herewith'orwarding a copy of the LER to the Regional Administrator of the Region V office.

If you have any questions, please contact T. R. Bradish, (Acting) Compliance Manager at (602) 393-2521, Very truly yours, JML/TRB/SBJ/kj Attachment cc: W. F. Conway (all with attachment)

E. E. Van Brunt J. B. Martin n ('nn M. J. Davis A. C. Gehr INPO Records Center 90011804 1 i 900111 F'CIR Ao jlIP, 0~'I II I 0< rq F LlI"

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NRC FORM 366 U.S. NUCLEAR REGULATOR Y COMMISSiON (64)9) APPROVED OMB NO. 31504)104 EXPIRES: 4I30192 ESTIMATED BURDEN PER RESPONSE TO COMPLY WTH THIS INFORMATION COLLECTION REOUESTI 50.0 HRS. FORWARD LICENSEE EVENT REPORT (LER) COMMENTS REGARDING BURDEN ESTIMATE TO THE RECORDS AND REPORTS MANAGEMENT BRANCH (P630), U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON, DC 20555. AND TO

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THE PAPERWORK REDUCTION PROJECT (31500104). OFFICE OF MANAGEMENTAND BUDGET, WASHINGTON, OC 20503.

FACILITY NAME (1) DOCKET NUMBER (2) PA E

>a1o Verde Unit 1 o 5 o o 0'5t2 S 1 QFQ 7 TITLE (4)

Engineered Safety Feature Actuation During Reactor Coolant Pump Test EVENT DATE 15) LER NUMBER (6) REPORT DATE LT) OTHER FACILITIES INVOLVED (6)

MONTH DAY YEAR YEAR '<<Sag; SEQUENTIAL IIEvrsloN OAY YEAR FACrLITY NAMES DOCKET NUMBER(5)

.<<vr'NVMSER SN NUMBER MDNTH N/A 0 5 0 0 0 12 12 89 89 0 2 4 00 0 11 19 0 N/A 0 5 0 0 0 OPERATING i ~ na ni.ron l la aoomrl lair rUnavnnI M Itic naclvrncMcnla Ul. Ill Lrn S. lt,nrci onr or mol ~ ol lnr lo >onmrrl Ilil MODE (9) 20.402(ill 20.405(c) 50.73(e) (2)(iv) 73.7((S)

POWER 20A05( ~ ) 11) Ii) 50.36 (c) I 11 60.73(el(2) (vl 73.71(cl LE v E L 0 0 0 20.405( ~ ) (I ) (ii) 50.36(c)(21 50.73( ~ l(2)(vii) OTHER fSorcllr in Aorrrrct orlow end in Trit, NIIC Form 20.405( ~ l(1) (iiil 50.73( ~ l(2)(il 60.73 I~ I (2) I v iiiI I Al 366AI 20AOS(c I (1 I (iv) 50.73( ~ I(21(ill 50.73 I ~ l(21(viiiI (6 I 20.405( ~ l(1)(vl 50.73( ~ )12)(iii) 50.7 3 ( ~ I ( 21(i)

LICENSEE CONTACT FOR THIS LER (12)

NAME TELEPHONE NUMBER AREA CODE Thomas R. Bradish, (Acting) Compliance Hanager 6 0 2 3 9 3 - 2 5 2 1 COMPLETE ONE LINE FOR EACH COMPONENT FAILUAE DESCRIBED IN THIS REPORT l13)

CAUSE MANUFAC EPOATABLE C~r.,~<<n.,,r;,j<<sIg@ M A N V F' C. EI OR TABLE,aY4~np: Nt@~~.

SYSTEM COMPONENT CAUSE SYSTEM COMPONENT TVAER TVRER kw)rM If)SF(aL'JaL S~3rSOnlg'sv'tn96 SUPPLEMENTAL REPORT EXPECTED (14) MONTH DAY YEAR EXPECTED SV 6 M I SS ION DATE (15(

YES Ilf yrt, complete EXPECTED SVBSIISSION DATE) NO 0 2 2 8 9 0 ABSTRACT (Limit to 1400 lorcrL I, ~,, epprorfmrtrly fifteen tinplr lprtr rrprwrinrn linrtl (16)

On December 12, 1989 Unit 1 was in Mode 6 with the reac"or coolant sy tom pressure and approximately 95 degrees Fahrenheit. At a'tmospheric approximately 1055 MST, a test was initiated on reactor coolant pump 2A motor prior to coupling the impeller. The motor start caused a voltage perturbation in the electrical syst: em that tripped radiation monitors and initiated a containment purge isolation actuation signal, a fuel building essential ventilation actuation signal, and a control, room essential filtration actuation signal. All systems responded as designed.

The RCP motor was immediately stopped. All actuations were reset by approximately 1300 MST.

An investigation into .the event is in progress. Upon completion of the investigation, a supplemental report will be issued providing the root cause ATIFI AT)y rorrer";ive artions t.o prevent recurrence.

NRC Form 366 (64)9)

NR C FORM 3 SEA U.S. NUCLEAR REGULATORY COMMISSION (SSS) APPROVED 0MB NO.31500')04, EXPIRES: 4/30/92 LICENSEE EVENT REPORT ILER) ESTIMATED BURDEN PER AESPONSE TO COMPLY WTH THIS INFORMATION COLLECTION REOUEST: 50.0 HRS. FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE RECORDS TEXT CONTINUATION AND REPORTS MANAGEMENT BRANCH IP4)30). U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON. OC 20555. AND TO THE PAPERWORK REDUCTION PROJECT (31504104), OFFICE OF MANAGEMENTAND BUDGET,WASHINGTON, DC 20503.

FACILITY NAME (1I DOCKET NUL'IBER 12)

LER NUMBER (6) PAGE 13)

YEAR 42 sECIIENTIAL i.:A FEVrSION NUMSSII P('3 NrrMSEA Palo Verde Unit 1 o s o o o 52 889 0 2 4 0 0 Q 2 QF 0 7 TEXT /// moro 4/rooo io roooirod, oro oddroBrro/ hiRC Form 3////AB/ (17)

I. DESCRIPTION OF WHAT OCCURRED:

h T<<4 <<4 ql F'pnroo <<4 mar On December 12, 1989 at the time of this event, Palo Verde Unit 1 was in Mode 6 (REFUELING). The reactor coolant system (RCS)(AB) was at atmospheric pressure and approximately 95 degrees Fahrenheit.

B. Reportable Event Description (Including Dates and Approximate Times of Major Occurrences):

Event Classification: Engineered Safety Feature Actuation On December 12, 1989 at approximately 1055 MST, re'actor coolant pump (RCP)(AB) 2A motor (MO) was started to perform a test with the motor uncoupled from the impeller. The pump start caused a voltage perturbation in the AC electrical distribution system and resulted in an undervoltage condition on the "AH AC vital instrument distribution panel (EF) which tripped radiation monitor actuation relays. This resulted in the initiation of a containment purge isolation actuation signal (CPIAS)(JE), a control room essential filtration actuation signal (CREFAS)(VI),

and a fuel building essential ventilation actuation signal (FBEVAS)(VG).

Pri'or to the event on December 12, 1989 at approximately 0615 MST, the emergency power supply (the "A" class 1E battery (EI)(BTRY))

was disconnected from the 125 vol't DC control center (EJ) in order'o support outage work. The normal power supply to the 125 volt DC control center (battery charger (BYC)) remained connected. The battery charger was powered via the 480 volt AC Motor Control Center (ED), the 13.8 kv AC bus (BU) NAN-S03 (EA), and ultimately from the startup transformer (NAN-X03)(EA)(XFMR). (See attached sketch.)

The RCP 2A motor was powered from 13.8 kv AC bus NAN-S01 (EA).

Since Unit 1 was not in operation, the 13.8 kv AC bus NAN-S01 was Dowered via the 13.8 kv AC bus NAN-S03 and from the startuD transformer (NAN-X03). (See attached sketch.)

Prior to the test, operations personnel (utility, licensed) questioned the possible effects the RCP 'motor test could have on plant equipment. However, after discussions with engineering personnel (utility, non-licensed), it was decided the test could NRC Form 366A (666)

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NRC FORM 3S6A U.S. NUCLEAR REGULATORY COMMISSION (64)9) APPROVEO 0MB NO.SI50PIP4 EXPIRES: 4/30/92 LICENSEE EVENT REPORT (LER) ESTIMATED BURDEN PER RESPONSE TO COMPLY WTH THIS INFORMATION COLLECTION REOUESTI 50.0 HRS. FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE RECORDS TEXT CONTINUATION AND REPORTS MANAGEMENT BRANCH (P$ 30), U.S. NUCLEAR REGULATORY COMMISSION, lVASHINGTON. DC 20555. AND TO THE PAPERWORK REDUCTION PROJECT (3(500104), OFFICE OF MANAGEMENTAND BUDGET, WASHINGTON. OC 20503.

FACILITY NAME Il) DOCKET IIIUMBER (2)

LER NUMBER (6) PAGE (3)

YEAR 'II+I SEOVENZIAL r:, 3 REVISION NVMSER .',/SK NVMSSR Palo Verde Unit 1 0 5 0 0 0 5 2 8 8 9 0 2 4 0 0 03 OF 0 7 TEXT lllmaw e>>aa /4 rar)rrr'rad. Irla addrrr)rrral /t/RC Farm 356A 3/ (IT) be performed without impacting plant equipment.

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J voltage perturbation in the AC electrical system. This perturbation propagated from the 13.8 kv busses (NAN-S01 & S03),

through the ESF transformer (NBN-X03), the load center transformer, the battery charger (PKA-H11), the 125 VDC bus, and the 120 VAC inverter (PNA-Nll), and finally to the 120 VAC distribution panel. This perturbation caused an undervoltage condition on the 120 volt AC instrument and control distribution panel (EF). The undervoltage condition on the 120 volt AC instrument and control distribution panel deenergized (tripped) the actuation relays for the containment purge effluent radiation monitor (RU-37)(IL), control building effluent radiation monitor (RU-29)(IL) and the fuel building area radiation monitor (RU-31)(IL) and initiated a CREFAS, FBEVAS, and CPIAS. Upon receipt of the CREFAS, the "BH train essential chiller (CHU)(KM),

essential cooling water (CC) pump (P), and essential spray pond (BS) pump started. The "A" train essential chiller, essential cooling water, and essential spray pond systems were in service prior to the event.

The RCP 2A motor was immediately stopped. At approximately 1112 MST the control building (NA) normal, air handling unit (AHU) and engineered safety features (ESF) equipment room AHU vere stopped operating procedures. At approximately 1120 MST, all 'er equipment actuations were verified per plant procedures.

The CPIAS, FBEVAS, and CREFAS were reset at approximately 1243 MST. 'he fuel building (ND) ventilation was returned to normal at approximately 1247 MST.. The control room and control building ventilation were returned to normal at approximately 1258 MST.-

The "BH train essential cooling water, essential chiller, and essential spray pond systems were stopped at approximately 1300 MST.

Status of structures, systems, or components that were inoperable at the start of the event that contributed to the event:

The ventilation to the DC equipment room and battery rooms was inoperable at the time of the event., In order to support the outage work on the ventilation'See LER 528/89-23-00), the "Av class 1E battery was disconnected from the distribution bus.

NRC F arm 366A (669)

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NRC FORM 355A U S. NUCLEAR REGULATORY COMMISSION (666) APPROVED 0M B NO. 3'I 50410S EXPIRES: S/30/62 ESTIMATED BURDEN PER RESPONSE TO COMPLY WTH THIS LICENSEE EVENT, REPORT (LER) INFORMATION COLLECTION REOUESTI 500 HRS. FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE RECORDS TEXT CONTINUATION AND REPORTS MANAGEMENT BRANCH (P430), U.S. NUCLEAR REGULATORY COMMISSION. WASHINGTON, DC 20555, AND TO THE PAPERWORK REDUCTION PRO/ECT (31500104). OFFICE OF MANAGEMENTAND BUDGET, WASHINGTON,DC 20503.

FACILITY NAME (1) DOCKE1'UMBER (2) LER NUMBER (6) PAGE (3)

YEAR SEQUENTIAL REVISION NUMBER NUMSSR Palo Verde Unit 1 o s o o o 52 88 9 0 2 4 00 04 oF 07 TEXT /I/ mort sport is roti td. Ust tddrsiont/ HRC Form 366r('s/ ((2)

Cause of each component or system failure, if known:

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, E. Failure mode, mechanism, and effect of each failed component, if known:

Not applicable - No failures were involved.

For failures of components with multiple functions, list of systems or secondary functions that were also affected:

Not applicable - No failures were involved.

For failures that rendered a train of a safety system inoperable, estimated time elapsed from the discovery of the failure until the trains were returned to service:

Not applicable - No failures were involved.

H. Method of discovery of each component or system failure or procedural error:

Not applicable - No failures were involved.

I. Cause of Event:

An investigation is being performed to determine the root cause of the event. In support of the investigation, voltage data from the inverter to the 120 volt AC instrumentation and control distribution panel, the voltage regulator to the 120 volt AC instrumentation and control distribution panel, and the battery charger to the 125 volt DC distribution panel were recorded during the reperformance of the RCP 2A uncoupled impeller motor run on January 5, 1990. A supplemental report will be submitted providing the results of this investigation.

J. Safety System Response:

The. containment purge (CP)(BK) isolation valves were isolated prior to the event; therefore, the CPIAS did not result in actuation of any CP components per design.

The FBEVAS stopped the normal fuel building AHUs, isolated the normal supply and exhaust dampers (DMP), and started the fuel NRC Form 356A (686)

NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION (64) 9) APPROVED OMS NO. 31504')04 EXPIRES: 4/30/92 ESTIMATED BURDEN PER RESPONSE TO COMPLY WTH THIS LICENSEE EVENT REPORT (LER) INFORMATION COLLECTION AEQUESTI 500 HRS. FORWARD COMMENTS REGARDING SUADEN ESTIMATE TO THE RECORDS TEXT CONTINUATION

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AND REPORTS MANAGEMENT BRANCH (P4)30), U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON, OC 20555, AND TO THE PAPERWORK REDUCTION PROJECT (3150hl)04. OFFICE OF MANAGEMENTAND BUDGET,WASHINGTON, DC 20503, FACILITY NAME (I) DOCKET NVMSEK (2I LEA NUMBER I6) PAGE (3)

YEAR 5 5 0 V5 N T IAL REVISION NVMSER NVM ER Palo Verde Unit 1 0 5 o 0 o 52 889 0 2 4 00 05 oF 0 TEXT ///moro 4/Moo /4 roqhr/rod. oro oddkr/ooo//I/RC form 366h(3/()7) building essential exhaust air filtration units per design.

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~ l r - I - 44 ~E r control room normal AHUs, and started the control room essential AHUs per design. The "B" train essential cooling water pump, essential chiller, and essential spray pond pump also started as a result of the CFEFAS per design. The HAH train essential chiller, essential cooling water pump, and essential spray pond pump were in service prior to this event.

K. Failed Component Information:

Not applicable - No failures were involved.

II. ASSESSMENT OF THE SAFETY CONSEQUENCES AND IMPLICATIONS OF THIS EVENT:

The undervoltage condition on the "A" AC vital instrument distribution panel, caused by the starting of the RCP 2A motor, only lasted a few seconds as indicated by computer printout following the event. The voltage returned 'to normal immediately after the RCP motor was stopped.

Alarms were only received on the KA" AC vi.tal instrumentation and control distribution bus indicating the undervoltage conditi.on only affected one of the four vital instrumentation and control distribution panels. The availability of redundant instrumentation and control Gistributio2) panels and the short dura"ion of the electrica transien did not effect the ability to monitor and operate systems requir'ed by technical specifications.

The initiation of emergency ventilation and emergency cooling water systems was the result of an undervoltage condition and not the re'suit of abnormal levels of radiation. The safety systems responded as designed. Therefore, this event did not have an effect on the health and safety of the public.

III. CORRECTIVE ACTIONS:

A. Immediate Tl r TTI"T) IIIo, /))" wzc jporrrorli R/ n1v st onTT(s/I PTI/I (so() jP)II('T)t a( tT)A( joT)c were verified.

Action to Prevent Recurrence:

An investigation is in progress to determine the root cause of the event. Upon completion of this investigation, a supplemental NRC Form 366A (6()9)

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NRC FORM 366A U.S, NUCLEAR REGULATORY COMMISSION (649) APPROVEO 0MB NO.31500104 EXPIRES: S)30/92 ESTIMATED BURDEN PER RESPONSE TO COMPLY WTH THIS LICENSEE EVENT REPORT (LER) INFORMATION COLLECTION REOUESTI 50.0 HRS. FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE RECORDS TEXT CONTINUATION AND REPORTS MANAGEMENT BRANCH IP430>, U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON. OC 20555, AND TO THE PAPERWORK REDUCTION PROJECT (3150410S>. OFFICE OF MANAGEMENTAND BUDGET, WASHINGTON, DC 20503.

FACILITY NAME (1) DOCKET NUMBER (2> LER NUMBER (6> PAGE (3)

YEAR SEOUENTIAL sw?: REVISION NUMSER NOMOOR Palo Verde Unit 1 0 5 0 0 0 5 2 8 8 9 0 2 4 0 0 06 oF 0 7 TEXT N mors spsss )s rsqvusd, vss sddrrioosl NRC Form 366A'sl (12) report will be submitted. The supplement will be submitted by February 28, 1990.

IV. PREVIOUS SIMILAR EVENTS:

There have been no previous similar events reported pursuant to 10CFR 50.73. There have been several reported engineered safety feature actuations caused by the deenergization of an instrumentation and control. distribution panel. However, none of the previous events were caused by an undervoltage condition associated with the starting of a reactor coolant pump motor.

NRC Form 366A (649)

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NRC FORM366A US. NUCLEAR REGULATORY COMMISSION (689) APPAOVEO 0MB NO. 31500104 EXPIR ESI 4/30/92 ESTIMATED BURDEN PER RESPONSE TO COMPLY WTH THIS LICENSEE EVENT REPORT (LER) INFORMATION COLLECTION AEQUESTI 50.0 HRS. FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE RECOADS TEXT CONTINUATION AND REPORTS MANAGEMENT BRANCH IP4)30), US. NUCLEAR REGULATORY COMMISSION. WASHINGTON, DC 20555, AND TO THE PAPERWORK REDUCTION PROJECT (3I504)104). OFFICE OF MANAGEMENTAND BUDGET,WASHINGTON,DC 20503.

FACILITY NAME (I) DOCKET NUMBER (2I LER NUMBER (6) PAGE (3)

YEAR SEQUENTIAL /Ijjc REVISION NUMSER NUMSER Palo Verde Unit 1 .o 5 o o o 5 2,.8 8 9 0 2 0 0 07 oF 0 7 TEXT ///more specie reouired, use eddroorM///'/IC Form 3564's/112)

ATTACHMENT

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NAN X03 STARTUP XFJIIR JIIAN X01 AIN XFIIR 005 ) CLOS:-9 NAN - 13.9 KV Ii'ITERIIIEOIATE BUS IIIAIN GENERATOR CLOSEO IIIAN X02 UNIT AUX XFMR OPEN NAN 503 13.9 KV BUS )

AN S01 13.9 KV BUS I,

) CLOSEO JCLOSEO jCI OSEO I

NBN X03 ESF 5 XFIIIR RCP 2A

) CLOSEO PAB en~ I 4 (R LOAO CENTER XFIIIR

)CLOSEO

)'PGA L35 490 V LOAD CENTER j CLOSEO PHA lilac 4 V 01 T R NTR NTER

) OPEN

) CLOSFO BATTERY PKA H11 PNA V2S VOLTAGE REGULATOR BATTERY CHARGER OPER" PKA NTROL CENT

)CLOSEO PNA r'J11 INVERTER TRANSFER SUITCH

)CLOSEO PIJA 025 0 IJ AC TAC OISTRIBUTION PANEL NAC Form 366A (64)91

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