ML20032C640
| ML20032C640 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 11/04/1981 |
| From: | Nichols T SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8111100678 | |
| Download: ML20032C640 (37) | |
Text
[
i
\\ \\D f I.
SOUTH CAROLINA ELECTRIC a GAS COMPANY
/
M
(&
/
],
post or ri-r so. m CotuksiA, south CARollNA 292f8
/(
,NO g [O.
.g f
~ L T. C. Nicwo t s, J R.
Novmber 4, 1981 7 '.i 6
8fA i
wet P.ts.ot=,==o c.oo neem ik\\
A/,
%g' *n )~f7 hwettan ceru w e
Mr. Harold R. Dmiton N/
3 Office of Nuclear Reactor Pegulation
$l f U. S. Nuclear Regulatory Ccnmission Washington, D. C.
20555
Subject:
Virgil C. SunTner Nuclear Station Docket No. 50/395 Solid Radwaste Handling and Disposal - Open SER Item 1.7.17
Dear Mr. Denton:
As a result of recent industry difficulties involving the use of urea four. aldehyde as a radwaste solidification agent, South Carolina Electric & Gas
@mpany (SCE&G) has contracted with Gm Nuclear Systems, Inc. (OGI) for portable solidificatim services using the cement process. This portable (skid mounted) system will be located inside the Auxiliary Building in the existing radwaste handling area.
Per conversations between Mrs. Nancy Clark and Mr. Giry Ebffatt of SCE&G and mmbers of your staff, the following is being subnitted:
a.
FSAR Gapter 11.5, " Solid Waste Systen," marked to reflect these changes ( Attachtrent I).
b.
" Operating Procedure for OEI Portable Cement Solidification Unit No. 21," document number SD-OP-020, Rev. 0 ( Attachnent II).
c.
" Dewatering Procedure for OGI Conical-Bottm High Integrity Containers 1% Free-Standing Water," document number FO-OP-003, Pev. C (Attachment III).
d.
" Process Control Program for OGI Cement Solidification Units,"
document number SD--OP-003, Rev. D ( Attachment IV).
e.
"P&ID PSU C-21," document number 313-2101-E01, Rev. 0 (T." chnent V).
Please note that attachments C through F are Gm Nuclear proprietary information. 'Ihe attached affidavit is in support that these docununts are to O}
]O be withheld frca public disclosure (Attachnent VI).
5 CI I
D.sk g6;b2#
8111100678 811104 PDR ADOCK 05000395 E
l l
Mr. Harold R. Denton November 4,1981 Page 2 Based on the above, we feel that sufficient information nas been provided to cmplete your review. However, if you require further information, please advise.
Very truly
- urs, T. C. Nichols, Jr.
GDM:'ICN:glb Attachments cc:
V. C. Sunmer G. H. Fischer T. C. Nichols, Jr.
H. N. Cyrus J. C. Ruoff D. A. Nauman W. A. Williams, Jr._,
R. B. Clary O. S. Bradham A. R. Koon M. N. Browne B. A. Bursey J. L. Skolds J. B. Knotts, Jr.
H. E. Yocm NPCF File
o A Tr/9 CHB 7E/t/ 7.2-Attacament 1 4
Mr. Harold R. Denton Docket No. 50/395 11/4/81 i-s.
11.5 SOLID L'AST" SYSTD!
11.5.1 DESIGN OBJECTIVES he solid waste syste= is designed to package =lCr and solidify radioactive wastes for shipment to.a approved of fsite burial facility in accordance with applicable Department of Transportation (DOT), NRC and State regu-lations.
The syste= confor=s to 10 CFR 20 and 10 CFR 50 requirements by
~ [
providing shielding so that radiation exposure of operating personnel an'd the public is within acceptable limits.
Solid waste packaging is fN acco=plished in : 11 '
=' -
- area located on the ground floor (elevati.on 436') of the auxiliary building, a Seismic Category I struc-ture. ^'r-e - '= '=^^' '-
" c ' " ~ ' Th : r ilin ; ': ilding ;;
gN c
-^-- ch' eld 211, :::::p t for en ^;:nfng into d.n tr d ::: r I
-cc--ider S'ee':: t' rc ugh
'is -:-peciag_ic.; ntre11ed.
S cre ir cleo
--4-te medict: con:::t; chi Id 1:tucca thi: Opening r.d the fill ::::..
f dq Design, fabrication and test of solid waste system components and piping is in accordance with ANSI B31.1 and other accepted standards referenced 1 M by A';SI B31.1.
Additional onsite system tests will be performed using nonradioactive materials prior to commercial operation.
The shipping containers are DOT Type A.
Overpacks for highly radioactive materials satisfy DOT regulations. Packaging and shipping conform to 49 CFR 171 through 49 CFR 178.
ond ca S k.s Individual container shields becing nr ' d '_ '_/2 ::2 '
in? thi:bn ::::
2-7
-of
- d are usad, when required, to maintain radiation levels within j
200 mR/hr at surf ace contact and 10 =R/hr at 3 feet.
11.5.2 SYSTEM INPUTS
('
i Radioactive waste packaged includes:
11.5-1 AMENDMENI )$'
sm==
+
1.
Evaporator bottoms.
2.
Lnemical taooratory samples.
3.
Spent resins.
4 Used filter cartridges.
5.
Radioactive hardware, r
6.
Compacted waste such as rags, paper, clothing,.etc.
[-
- ainers holding high level solidified radioactive materials are stored w their individual shields, within a concrete cubic t
]r grade.
Contal holding low level wastes are stored their individual shields, quired, on a mezzanine or 11 feet above this area. They are lifte 10 ton, r driven trolley and crane g
which locates containers in this The filling, flush *,,
solidification proce erformed auto-
)#
matically o-e manually from a control panel in a ded room.
e Figur 1
-1 is a flow diagram of the system. A layout of th rea is n bv Figure 1.2-25.
,J Design quantities and activity levels of the various wastes are listed in Tables 11.5-1 through 11.5-4.
39 11.5.3 EQUIPMENT DESCRIPTION 11.5.3.1 Processing 34' The input to the solid waste system consists of the contents of four radioactive waste storage tanks containing waste evaporator concen-trates, che=ical laboratory samples, pri=ary spent resins and nuclear blowdown spent resins and the associated valves, piping and umps.
These co=ponents are located at elevation 412' in the auxi.ary building 14 excepr for the chemical drain tank which contains spent ca.amical labo-Rt ratory samples and is located at elevation 37 ' of the auxiliary build-
^
ing.
R' \\
2.f 11.5-2 M NDMEFI' #
~YF %
~
'DVSER T A
chemical processing area is located on the auxiliary building mez-za ine floor at elevation 447' to locate as much equipment as possibi in a onradioactive area for service and maintenance purposes. The follow g equipment is located in this area:
1.
The un.
.h formaldehyde concentrates (UFC) storage tank whi contains urea fo idehyde, water and a small amount of a propri ary.
a' ive.
is mixture comprises the solidificatioc a cut (SA).
2.
The urea catal t storage tank which contains aanno um sulfate, prilled urea, wat r and a small amount of a propr'etary additive.
This mixture compri es the catalyst.
3.
T[esulfuricacidstoraetankcontainsthe Ifuric acid which can be used to lower the pH o liquid waste bel w 6.9, if required, prior to packaging.
1 4.
The chemical process module whi h cont ins the catalyst pump, UFC
- g. r pump, valves and piping to direct th SA and catalyst to the vaste T.
container.
v 5.
The sodium hydroxide storage tan cent ns sodium hydroxide. which is usedtoraisethepHoftheli!idwaste bove 6.0, if required, prior to packaging.
29 f
Liquid waste is routed to a.wa te blending tank (
T) prior to packag-
)
ing, where the liquid is re rculated through a pH ter by a recircu-1 l (
lating/radwaste pump.
Su uric acid and/or sodium h roxide is added to the WBT as necessary to djust the pH of the tank liqui to within 6.0 to 7.0.
By appropriate valving, a sample of the WBT cons ituents can be obtained to demonst ate solidification capability as requi d by NRC regulations.
Th WBT is equipped with a mechanical mixer to naure a homogenious mi ture for sampling and for greater assurance of lidifi-cation. The WBT is also heated to permit close temperature contr 1.
The recir ulating pump is located in a shielded cubicle below the T
and a cent to the fill area at elevation 436'.
The WBT is located n
>i(
/
. t e floor above the pump within the same cubicle at elevation 445'.
l 11.5-2a AMENDMENT g 7.9
-- --m ssvu 1
---.,e._-,.-----.--,-4.,m
,,*e....
. -. -..,,, - - -. --- ~. -.-
-.-,c
IIVSER T A
kd waste selidiV c e a 1;cn
- 3 a c comp la A e.d o.siy n
po r table ce~,e-t solid:Pien t/on process scpp /;ed b
Chem A/velear S'y s te m s In c.
L,yuid waste
(
y con tatu e d i n the Chemical benin Tan k a n d (Naste Evapo<a to <
C on c e n f-n te s Tn, k is e e ctc c s la te d usin3 f4ein ve sp ec five p vmps
(:
sample i.s fa ke n,
T%;s sa mple is and a
Asynm to use d ih ff e h-oces.s Contvo/
29 de te< min e H
a djustm e n f, waste / hinder Me f urfose o?
fes t ta i to,
an solidr Tica tion,
L;yu,-d wasfe is fra,s Ve e e d' io the
?;//
h er d an d into f4 e liner locate al( '[
18 14e solid; Fica fion area.
cas ceet p H
<ang e acconpi luki the fes t
.so /;d; Pie., fibn is bas ect on hy addim calcium h dvoxide
%,ouy h w,e By y
heg d to the I:ne v.
A u lik cem e,t an d calcium b d<cx;de ac e s fore c/
in ci bulk fvaile e y
ou 1 s id e f4e Aoxiiia<y /Avildiy Lc A access. '
offec csn di tio n i83 ch e m ic e I.s may be a<lde d I T n e ce ss qry Ivo~
fbe condif;onisyi c he mical ta n k phd fem s ?er pumf.
(
(
H 5 ' 2- 0 Amendme st z <j
e WBT provides a means to accomplish the following:
1.
Tho ghly mix and homogenize the waste.
2.
Add chemica for pH adjustment.
3.
Control radwaste tem rature.
Based upon solidification data led by the process manufacturer for various chemical solutions, the or et bar.d of ratios of waste SA and '
catalyst is selected.
The contirol of waste m erial content before dition of SA provides thel means for assuring adre consistent results. Whe the radioactive waste solidification fi operation is terminated, the ma rial within the container is a owed to solidii' and then only SA and talyst are added to seal the op surface of the uolidified waste.
1[
The d atering module is located in a shielded cubicle on the a iliary bu' ding operating floor (elevation 436').
It consists of a resin
, lurry dewatering pump and the associated piping and valves.
Prmakr fran sleced and S ecen da y sp en t resin s r
are
- frm, e; r respec tNe h:Id up anks to eifber 'a f
J;sposable linee in lhe solld) Picafrom oren er a I;ner whic h i.s q/ read in a cash re ad for Yvansport y
(-
in ih e fruc k bay.
T$e resins thay then he eiMee M
solid; Vied or dewa fece d for ship enenf.
Bewa ter retucn is through the ven dor 's piping proce=s sl<id to L
de water c onn ec tio n in he soli di Fica tion area and Prom. there to eilhe c
+h e Exce ss L iyoid was fe.
(
IMLp Tank or fbe Spe8 t Resin sforag e Ta n K.
1 AMENDMENT [ 2.7 11.5-3
.r=, =
6 h shield walls separate the drumming state n m t M,vum, c
gl dewatering modu e t I area from one another.
N
(
Equi.
escribed in more detat n 11.5.3.2.
~
i 11.5.3.2 Equipment The equipment comprising the solid waste system is described in Sections 11.5.3.2.1 through 11.5.3.2.7.
Tcble 11.5-5 provides equipment design Seier 5 CIVSI Opeea tig frece doo e : decom en f 0
parameters.
Sp oP-020 and 9/cd diaya m 313 - 210 I - Eol.
7S 11.5.3.2.1 Waste Storage Tanks an] Pumps
[(.
19 l
Tanks containing radioactive waste and wetted parts of pumps are fabricated from stainless steel, type 304, except as noted.
The chemical drain and the primary spent resin storage tanks and pumps are described in Section 11.2.
Other radwaste tanks and pumps are the waste evaporator concentrates pump, nuclear blowdown spent resin storage tank,gnd I
nuclear blowdown spent resin storage tank pump, r d ti '2 7.
n c ""T'Ic 2,7
[
l -rem erte! S_:,r :: cat.:Asa ata C
11.5.3.2.2 Chemical Storage and Process Equipment SA, catalyst, sulfuric acid and sodium hydroxide are stored i anks N6k7 in a che al storage area on the auxiliary building mez
~ e floor at b
elevation 447,
bove the drumming control room and ill area.
A chemical process modu "s also located in t area, with appropriate valving and pumps for directin to e waste container, or sulfuric N
acid and/or sodium hydroxide to eb Containers of dry chemicals for addition to the SA or alyst tanks are o stored in this area.
(
l The SA (UPC) and cat st tanks are of coated carbo teel construction, whereas the sul ic acid tank is constructed of 316 stai ss steel and the sodium droxide is fabricated from polyethylene.
e chemical process module consists of the following skid mounted
,, equipment: [
(
t7 11.5-4 AMENDMENT g a=,
- m I
l l
s livsER T S
are s fece d -
LIk cemen t an d ca /ctum Agnxi2/e a bulk
+ea rle r-loca fe d oufsNe f4e Aun %'e>7 i n Butthng.
hoc k aecess,
A pn eumafic,
}yp e cemen t con vey or lo c d e d' in f4/s same
- are9, fr nsfers th e.
cemen f fbrough a fruck a
wall pene fee fron to a portable access area hose lea dinJ to f4 e Fillhead.
The Pm VI head norma fl
/ ace te d in ibe so//diVice fis8 y
a lo n g w i f ii
/ f e pp;ng process sk;d area an d b
J ra v lic untf.
The con di /in r3 y
chemice/ sforage an ci process area is a
co r be d' are9 in fb e-located within
>,ent feuck access.
Liner ven fila fion epu,p&
is lo c afed in 9
curbed 9 re e in I
-f ruc k access. Th disch n eye Yeom
+ke lin e <
venfilafion ey vip m e n f is.
direcfed 40 h
p la n f tien f.
l l
l 1
l
- 11. s - +
A m *ncor 27 L
1 SA pur_po 2.
Ca alyst pump.
,/
3.
Flow d ectors to indicate solidification agent and catalyst flow.
4.
Pressure sw ches in pump discharge lines.
5.
Electrical termi al box.
6.
Associated piping.
11.5.3.2.3 Radwaste Module The radwaste module consists of t e following skid ounted equipment:
1.
Liquid radwaste pump._
2.
Preserve switch in pump discharge l_in
.(~
3.
Flow detector for radwaste flow.
4.
Three motor operated valves:
one to admit th WBT effluent; another to recirculate the WBT con, tents; and the last t discharge the WBT g
effluent to the disposab e sontainer.
~ ~ ~ ~
5.
Electrical terminal ox.
6.
Associated pipin.
11.5.3.2.3.1 ewatering Module The dewater'ng module consists of the following skid mounted equipme t:
1.
De tering pump 2.
Flow detector for dewatering flow.
AMENDMENT g 11.5-5
,g_
3 Y
Procgura cwitch in pump sucticn lina.
4.
A motor ope d three-way valve to admit water f the WBT or the
[
disposable containe N
5.
A manual valve to isolate th ump.
6.
Electrical te
~ al box.
Associated piping.
11.5.3.2.4 Instrumentation and Controls The system uses temperature, flow, pressure, and level instruments to monitor and/or control the process located throughout the system.
The inplanf
(
4n additica, thcrc i; a control panel, power panel and radiation monitor gre located in the drutcming station control room. J d:: riptivu v f G,c.
27 1m i== i== e=11==-
The cni.sz conMI pned is also lccafe d in YhlS SG% e QYe9.
(
In plan f L
1 4 Control Panel inpknf The# control panel is a standard enclosure of NEMA 12 construction.
A functional flow chart showing valve positions, pumps, etc., is presented on its face.
This provides a visual presentation of system performance and gives the operator full understanding of current system status.
The control panel is designed to provid av of operational controls and safety limi e required solid-state cir
~ -> for manipulation of the-system is located
~
within the panel.
Manual oy ded to allow for system
~
malfunction correction 1 operati of the process, r,
(
The cop ol panel provides proof circuits which indicate t the various valves are properly positioned before the required pump
/
/g start and that the pumps are operating.
The inpkt ca., trol pan el prov; des
%it ope,5;enal co&ol w; th de,dcQg')
rah,
knsYee ope ~t: ens ~to the ve"d" e
. % resin and hpid waste ment. It is algo used fo l'1VGface ment Per dewater reken and Dr
~m = > =
?lrk 63 opera 7 ichS,
2.
Pow:r Pcnel The power panel provides power for the operation of the various pump r(
19 motors and valve motors in the system.
E oof of Flow Systems
'C.
Proof of flow uitry and solid-state, thermally actuated w
switches for the dewat g, waste, solidification ag t,
and g
catalyst lines are furnished.
als fr>
e flow switches
~
~
interface with the solid-state co nel to provide a method of 27 i
pr.eventing either operati of the pumps with liquids present so that the pumps ar ot damaged by being run " dry" or ssion of o' of the th components required to make a solidified mass o oactive material in the disposable liner.
e"
-(
3 27 11.5-6 AMENDMENT. W
__ -dung-isstr-
4.
Radiation Monitoring
.'Tsv.5ER T C
(
' radiation monitoring is located on the wall of the control cubicle ~1
(
to ert the operator in the event of excessive radiation.
In yf additi two radiation sensors, one measuring the radiatio evel-
~~
at the con iner or shield surface, the other measuri radiation six feet away, re located in the container fill es.
These are connected to a ra
- tion monitor located on op of the eontrol panel.
There is also radiation sens located near the WBT to measure radiation level in he WB cubicle.
The radiation monitor AY is located on the control pa If excess radiation levels exist, an alarm is sounded and fill op ation is automatically 2y
$ terminated.
If this ccurs, a decision n be made to either dilute, ship a s ler volume and/or provide dditional shielding.
The radia on sensors in the container fill area als serve to segre te filled containers by radiation level.
This pe
- ts some 1
specific activity (LSA) shipments to be made.
[-(s The radiation monitors are in addition to those discussed in 14 Sections 11.4, 12.1.4 and 12.2.4.
11.5.3.2.5 Waste Containers and Shielding Compacted wastes are packaged in standard 55 gallon drums.
Other wastes are packaged in 50 f t3 containers having dimensions of 4 feet in 1
diameter and 4 feet high or other DOT Type A containers. - S.: :cateiner-
,a
-/
g
--84 P-5 20 pre -15ien Oc cenacct ; : ster tc an internaldisposable-mixer.-
I Qu.;k disconnect fittings are located in the container top for the fellowing:
In/5ER T D enting from the container through a filter to the plant exhau system.
l l
2.
Ad n of liquid waste to the container.
X I
~
(
1 e7 11.5-7 AMENDMENT 8
- M N&r 4 980---
Tiv5ER T C
Radia tio n manifac ing is provided by fl,e vendoc ',
e7vipmen t in th e
-Pollowin3 areas:
- l 1.
was te.
1.so la tio n volve oY fl, e pfin3 proces s skrd 2.
line r ftll hea d.
3.
con fro /
ro o m.
InisiR T b I.
bewa ter thcoy h a
Filfew ha e k io
+kg Excess L;yurd was fe
&Idup Tank or i.
Spen f hes;n s toeay e 7a' n k.
e.
cemen f Calctum hya%xide Pill con 8eafs'on 3
condifroning che mica /
supply 4.
Vent to Tillers an d plan t ven t VIus A.
5.
An dwa.ste supply
// F ~ 7 j)p2mo/',cz/rZ7
4 3.
ission of SA to the coorainer.
4.
Admission o ata st.
5.
Admissio of air for s ging.
6, watering of resin slurry.
JiVSER T E
'Th e procesSjng of mes f of
-/fg wasfe t/o/um e will be ha n d 7e d in h
solidnica fron are a be hind a
rho va.ble
.shie /d.
//igher ac fivit y
wasie s,
howe ve e, ws/l be proc e.ssed with Me liner alrea d in Ne fra nsp o< f cas k Jacated C.
y in +/n fruc k access are a.
A dou ble
//d cask dep w,ll be use d
+o I;miy exposure in flas area.
Affec tfe wasle p ecess b
compie te,
th e FiVI heed is e mo v ed, an d r
the se con dg ry cas k lid is insfa //e d.
(
(
(
M ll.5-7a AMENDMENT Y
--JUNEy-1480
I9 e expected container design for packaging radioactive filters and har 3
/
ware 's a 50 f t container having a removable lid and a centrally ocated basket in which the filter or hardware is lowered.
The lid is then re-placed and lig d waste is packaged and solidified in and ar d the
.m basket.
ggg y When the radiation level of t waste requires s elding, the container G
E is completely enclosed in lead sh ds havi 1-1/2 inch or 4 inch nomina:
thicknesses.
A centrally located shi plug, approximately two feet in diameter, on the top of the shie is plac in position after filling by a pendant controlled overb jib crane.
When the Curie ntent of radioisotopes packaged within container ex-A
[_
ceeds DO rescribed limits, the container and its shield a ackaged L
wi n a DOT approved overpack for transport to the. burial site.
I 11.5.3.2.6 Contamination Control Facilities An adjacent decontamination area is provided for cleanup of contaminated containers.
Exposed surfaces of filled containers or casks are surveyed by the health physics group to identify the presence of removable radio-active contamination prior to transfer to storage or shipment.
Containers m
i are decontaminated in the adjacent deconta21 nation area, if required.
11.5.3.2.7 Handling Equipment handI;n eq uir""
i n
- (
Equipment used fory-epcrti..g the waste containers and shi+M within
/ -7 7
the radwaste area. and for truck loading includes the following:
m
- (
27 11.5-8 AMEFDMENT. W
__JUIC, 1000
I 1.
Leod g liec.
q 2.
Lend p:11c; and personnci chield.~
-3.
Lib k.
4.
One con jib crane.
5.
nree ton jib crane.
6.
Ten ton bridge crane.
7.
IVenty con hoist and monorail.
8.
nree ton bridge crane.
9.
Ten ton bridge cranc.
[,
The v ontainer and individual shield, if needed, are placed pallet by-the ten ridge crane in the hot cachine or by the overhead twenty ton hoist.
If t iatio el of waste to be pack-27 aged is expected to be high, a pa
, having additional 3 inch thick stainless steel shield, sed for additional protect the operater.
. er, shield and pallet are transported within theN dwaste The waste co 1
at floor elevation 4 36' by the lif t truck.
a
- L-The one ton jib crane is located on a wall above the truck access f,loor at It is used for hoisting chemicals and equipment M the elevation 435'.
W 2 'I truck access arec -t-e-4he-eezzanine-floor,- It has a lift of 23 feet at a speed of 22 ft/=in.
solid.Scdch j
The three ton jib crane is located on a wall above the container fil area.] It is used to remove and replace the lead shield fro = the top oN' h n*= % r.
It is also used to support the filter trar ead cask N
while transferring a spent h t e cask to the con-tainer.
The flexible rubb s, used when fill n ontainer, are this crane for removal of the hoses fro =
ne q,
also connec completion of the filling operation.
It has a 23 foot lift at a u
i, speed of 11 f t/ min.
II/ SERT Itis used to })an d/e ff 1
[
@f Offer eyvij)Meh f, n
a 11.5-9 AENDENT.,PT
__-m, M so __..
compet;ble e rewcompebble J The ten ton bridge crane is used for transporting eert: ccataine w h/457c at__
.a t _
.a.t_..
3 -inch leed shielb in the low radiation j
level s torage area at floor elevation 447'.
It has a lift of 14 feet at a speed of 11 f t/ min and a trolley speed of 65 ft/ min.
W(
The twenty con hoist and monorail is used 2: h;;kg fer the lif t truck-
~
e lletwr--
~2 [
to load the containerSend chield, if r:quiad, s either e e
on a truck for transport to a burial site.
It has a lift of 25 feet at a
^-
speed of 10 f t/ min.
(.
The three ton bridge crane is located over the radioactive filter area at floor elevation 463'.
It is used in conjunction with a 3-1/2 inch thic'- lead filter transfer cask to remove spent radioactive filter 14 cartridged from the filter housings located in concrete cubicles on the floor below at elevation 452'-6".
The trolley has a transfer mechanism which permits the hoist and the cask to engage a monorail which extends over the radwaste fill area. A hatch at floor elevation 463' is removed and the hoist lowers the cask to the radwaste area at floor elevatioa
- ('
436'.
It has a lift of 47 feet at a speed of 22 ft/ min and a trolley speed of 65 ft/ min.
Another ten ton bridge crane is located in the hot machine shop.
It is 14 chiefly used to service the =achine shop.
However, a portion of the floor area in the machine shop is partitioned from the rest of the shop for storage of unused containers.-aed 55 gallon dru=s, pallets, c[C.
i2]
g WA - d the mzeg wi.
The storage area is also serviced by this crane.
l The hoist has a lif t of 24 feet at either 7 or 20 ft/ min.
The trolley has a speed of either 32-1/2 or 65 f t/ min.
e(
11.5.3.2.8 Waste Compactor An electrotechanical cocpactor, with a compressive force capacity of four tons, is used to compact dry wastes into 55 gallon dru=s.
During compaction the drum is coc:pletely enclosed.
A self-contained HEPA filter e\\
z7 11.5-10
/#.ENDMEh7 W
-rs., a n
~ - -.
and blower system filters the air released in the compaction process before it is discharged to the auxiliary building atmosphere.
An elec-trical interlock prevents operations of the compactor if the door, which encloses the drum, is not completely closed.
This prevents injury to the operator and unfiltered air from escaping to the auxiliary building atmosphere.
This compactor satisfies Occupational Safety and Health Act (OSilA) requirements.
11.5.3.2.9 Truck Loading Features A wall pene~ ration is provided between the fill and truck access areas to fill directly to containers on a truckgif cxccos was to osu u luce.s.
ka.s l
chemi d vent lines are provided with qui cts on both sides of the wall.
e wall is stepped to permit two,
~ '
2 intermed' wo inch thick lead shields t D eT6TEiLed deh W 1.
11.5.4 EXPECTED VOLUMES The expected annual volume of solid radioactive vastes together with the associated Curie content of principal nuclides to be processed are des-cribed in Sections 11.5.4.1 through 11.5.4.4.
11.5.4.1 Activity Levels The activity level of the vastes generated directly from operation of the nuclear steam supply system is based upon reactor plant operation at a base load f actor of 80 percent power with reactor coolant activity levels determined on the basis of fission product diffusion through cladding defects in 0.12 percer.t of the fuel rods.
The system is con-servativelv designed to accommodate solid wastes generated by plant op-erations with up to 1 percent fuel defects.
Source term data used for m
((
system design are presented in Section 11.1.
11.5-11 MNDENTM
._as,im -
every six full power months of operation and that one of the three nuclear blowdown system filters will require cartridge renewal, normally for high AP, weekly.
All other filters are assumed to be renewed annually.
These replacement rates are approximations only sicce suf-ficient specific operational data is not yet obtainable (see Table 11.5-4).
r The maximum expected activity of expended filter cartridges shipped from the site is conservatively based upon a shielding criteria of a maximum contact dose rate.
11.5.4.4 Miscellaneous Solid Wastes The annual volume of miscellaneous solid wastes processed by the solid waste hydraulic baler is assumed to amount to 350, 55 gallon drums of l3 compacted refuse.
The wastes consist of rags, coveralls, ventilation filter cartridges and various other potentially contaminated refuse.
The activity of this refuse is low level and does not present a radia-f' tion hazard (less than 1.0 C1/yr).
L w,,
11.5.5 PACKAGING 11.5.5.1 Evaporator Bottoms and Chemical Samples Evaporator bottoms, concentrated to 12 percent, or less, boric acid in i14 the boron recycle or waste evaporator, are stored in the heat traced 5000 gallon vaste evaporator concentrates tank.
Lines from this tank dischu to the"T rge m.ste catmi valve (me/-2),
=1:s heat-tracedy Chemical sa=ples are stored in a 600 M
gallon chemical drain tank. [When a sufficient quantity /
has acmmuistef Yor paciurghg, tb vaate is transferred to the_WBT-fn batches of 700 7.!]
/
g gallons or less.
Thia vaste T ume will fill three tainers g
[
vhen solidiff and catalyst chemicals are added in the normal
. 111tsGT mp/
ortions-l G
I
\\
19 ll.5-12a AMENDMENT R JUNE, 1979 k
4
.TNSERr G when a ss TDeten f q ue 1 sty has accum v/a fed in etf4 r mste ta n k '
ifs conten fs nee recirculafed
-f'or a 1 leasf fwo vo /um e cbanges and a sample is fahen.
The sa~p le i.s use d by The Peccess con trol kroya m For +es f solibPicobs.
A7ter sampling,
the was te velv,~ e s ave then f<ans Ye ce d
+o f4e v e n d o v 's eyuymen f for p<ccess13 4
i f
L I
l
{}pf6f)N/1EW
- 11. 5 -12. a
_ j
liquid wasta is recirculatsd by tha rceirculcting/radwsste puup (d the echanical mixer is started to thoroughly homogenize the waste This p ocedure also emulsifies or holds in suspension small qua ities of other a s t e.4, such as oil and anti-foam agents.
Sulfuric id and/or codium hydr xide can be added from their respective tanks,
- required,
-~~
until a pH me er in the recirculation line indicates a sty dy reading of 6.0 to 7.0.
A mple can be withdrawn for analysis if equired.
B: sed upon solidific tion data provided by the proc ss manufacturer for verious chemical analy es, the desired waste temp rature is maintained by the WBT heater and th correct band of ratio of waste, catalyst and g
SA is selected.
In ad; li
, small samples a e periodically solidified using the selected proportio to assure co lete solidification.
/
A radiat:_on sensor located in the WBT cup cle is used to determine the size of the lead shield required fo t e. 50 ft3 container.
It is
2_ f anticipated that the 1-1/2 inch thic ead shield will be more than edequate and that in many cases no hie ing will be rep ired.
The container (with or without shield as requ ed) on a pallet is located r
in the fill area by a lift truc.
Five conn tions are made to the e;\\
container with flexible wire d fiber braid r 'nforced hoses designed for 1500 psig (6000 psig mi mum burst pressure).
These hoses have quick disconnects and are nelosed within a fill s ' eld asse.sbly. An electrical connection is 31so made to a disposable 1 vel probe and temp-erature probe within t container.
The hoses are conne ted as follows:
-(
1.
Vent to the auxiliary building exhaust system.
2.
Waste f om the WBT.
3.
Sol' ification agent.
(
4.
atalyst.
/
Station air for sparging of the mixture.
11.5-13 MNDENT g
_ mt, 19o0-
P e control panel is placed in the fill and solidify mode and fill flush nd termination of flew are done automatica11j under con ol of a level prob in the container.
Provisions are also made 1-$p automatic flushing of lin fram the radwaste module to the WBT d to the container.
Radiati monitors located at the con iner (or sh'ield) surface and 6 feet away cuate an alarm if e radiation level exceeds that. anticipated.
Should an larm be a ated, the operation is automatically terminated.
A de 'si is then made concerning dilution,
[f shipping of a lower volume or vi on of additional shielding.
f C
The air sparger is.sta ed and waste is pum d by the radwaste module from the WBT to th disposable container.
Flow s stopped when the container leve probe indicates the container is 50 60 percent full.
M Equal propo. ions of catalyst and SA are added to fill t container and the air parger stopped when solidification reactions increase e
Normal proportions of waste to SA to catalyst are 2.5 bac ressure.
o to 1.
N C
(
C
('
i l
2.1 11.5-14 AMENDMENT d A mi., 1^00 -
W Th ve flexible hoses and one electrical lead are disconnecte chains attac to the overhead jib crane which lift snaps the g
quick disconnects free.
fill shiel m ly is removed and the lid hield cask by use of the pendant N
shiel? is installed on the in controlled jib The container is auto ally sealed when the disconnec are freed.
The filled container is store
~
storage area un shipment.
11.5.5.2 Spent Resin Resin in a demineralizer is considered spent when its decontamination factor falls below a permissible level or the demineralizer surface dose rate exceeds its limit.
The spent resin, from demineralizers in the 3
primary system is stored in a 350 ft storage tank.
The spent resin 3
from demineralizers in the secondary system is stored in a 600 ft nuclear blowdown system storage tank.
The resin stored in the primary system is allowed to decay for a period of up to several months but not less than 30 days.
The resin stored in the nuclear blowdown system
.f' storage tank is surveyed to determine the minimum decay period required. This period is expected to be less than 30 days.
When a sufficient quantity of resin has accumulated and decayed, the resin is sampled for radiation level and packaged.
Prior to packaging, resin sluice water recirculated in the tank to form a slurry which is dur~
p transferred to the p by nitrogen cover gas pressure.
Dewatering of theresin]
the]I is accomplished througbMiltermn hETv--Orh%uid radwaste may be added to~ rtre-MBT =
(
is a ccompirsh ed usk5 L ven der 's e7v;p men t wiih tb wafec ben re tve 8e d 29 g
edbec to
+b e 2 x cess Lyuid w s te HeMup a
14e Spent hesh S begge Te k.
Ta n k or t
11.5-15 AMENDMENT 8
?E, 1980 -
hi 111ing the container with resin slurry, en coditional flex
- hose conne J n must be made to the container for dewat g the resin i
slurry. With this nection, six hoses are no onnected to the con-tainer.
Filling of the co ner with r n slurry and dewatering are performed simultaneously. When t ntainer is approximately 50 per-N cent filled with dewatered in, the fill ation is terminated.
The resin is then solidi by the addition of SA and lyst as described
~
in Section 11 1.
The air sparger is operated continuo eduring I
/
the f.
operation.
The radiation level of the primary resin is expected to require use of s
4 ehti 4 inch lead shield on some occasions.
The radiation level of the 27 nuelear blowdown system resin is expected to require not more than.shir 4, 1-1/2 inch lead shield.
The primary spent resin storage tank has a two inch discharge line.
located along the tank center line, protruding from its top and extend-ing to within 3 inches above the dished head bottom.
In preparation for packaging, the discharge valve is opened and the center discharge tube cleared by backflush with a burst of flush water from the reactor makeup water system.
Pressure to 100 psig is available, if required.
Flush water may continue to be added if needed to obtain a reasonable slurry.
-The discharge valve is then closed.
Loosening of the resin is achieved by introducing nitrogen through seven spargers at the tank bottom.
Resin sluice water can be recirculated through the spargers to loosen the resin if desired. When the nitrogen pressure increases to that required for
~
r' sin transfer, the resin discharge valve is opened, nd th; resin trana--
-fer :: the N
- ~
h 4e1 edject-ent as n;;crearyc Nitrogen continues
[
to bubble through the re, sin bed to maintain a gas pressure for transfer 2c7 loner of the resin until the.WWreaches the full level.
/ he
//ner Ved daring thi.s opera h m is direc te d
-h, & pin t ven t.
The nuclear blowdown system spent resin st'orage tank is discharged by
(
use of a procedure similar to that used for the primary spent resin
(.
57 11.5-16 AMENDMENT g am, w8n
storage tank.
The resin slurry is discharged through a 2 inch nozzle
-{
located at the tank bottom.
Prior to discharge, this line is flushed k
with resin sluice water or demineralized water.
The resin sluice pump is started to loosen and fluff the resin.
When a resin and water slurry is established within the tank, nitrogen gas is bubbled into the tank bottom pump suction connection to loosen and mix the resin and 7
pressurize the tati. When the tank gas pressure increases to that required for resin transfer, the resin slurry discharge valve t A ".",T f
is opened. Operation of both tanks from this point is similar.
() pen C em mL'hicafyn from Ye 1/Chdor f d f e fecn3Ver S Confefe Jr m var 4pt cf : ;ig.1 fre-the level prch; in the-WBT, the resin 17 d
dischargeandnitrogensupplyvalveAcloseandatankventvalveopents.h to discharge the nitrogen cover gas from the storage tank.
In addition, 15
)
the flush water supply valveAopenrto backflush and forward flush and decontaminate the res*
transport line. A flow diagram of the primary resin system is provided by Figure 11.2-2, Sheet 3.
Figure 10.4-15 describes the nuclear blowdown resin storage tank.
27 A flow of approximately 40 gpm is required t:. i.cansfer the resin slurry
.'.yy-Hner to the SBT~in the radwaste area.
It is anticipated that approximately 3
3 1300 std ft and 2200 std ft of nitrogen gas will be the maximum 3
required for each resin transfer operation from the 350 ft primary 3
resin storage tank and 600 ft nuclear blowdown resin storage tank, respectivel'y.
Actual gas pressure required, as well as system operation will be verified using nonradioactive resins during preoperational testing.
k-The nitrogen system is set to supply nitrogen to the resin storage tanks at a pressure of 100 psig, if needed.
The resin storage tanks are designed for 150 psig.
Relief valves on the primary and nuclear blowdown 1
17 11.-5-i /
AENDENT _W M
t
I resin storage tanks are set to relieve at 110 psig and 140 psig, res-pectively.
The primary resin storage tank relieves to the waste holdup tank.
The nuclear blowdown resin storage tank relieves to the nuclear blowdown system reservoir by way of an onen d r a_in.
11.5.5.3 Filter Disposal Filters are of the disposable cartridge type contained in housings having hinged tops.
Iney are replaced when surface dose rate or pres-
. sure drop exceeds established levels.
Filters stich are potentially radioactive are located in individual cubicles in an area close to the drumming station-area.
If the radiation level of the cartridge requires shielding during removal,. a concrete, plug in the floor above the}effed c housing ith F1/2 inc..es -e. gced in k S in i is fl Wi plujl, "th a hele is removed and a,jner' crato U'So
_ead-encased i.. -o t c i
_ Iter ec
/
d w er fh A. V;;}efpu sk Lyith,3li " lead encase,d in 4_cc)a>tc.1) esp. steel is ca ta pening, e f,e/e etee_ 2n_,t; vva cmcs, ::
in--the-step The filter housing is opened and the cartridge is drawn into the cask OnCC 1he fi/Yer is by the use of special tools having extension rods. 5% *ilter ;cs< ic-r The e tefs insk/ led
(
S id cleSed cosd G plac?
fhe CQSk bettem th l
is Oil 2 le'd gl a,lo ing port in the tcp.
cask is--lif-ted
%.,. m 7'
mm,-u, A > a c Pad it s bete ir 2 t :2 ch ed c The cask is then trans-u by an caerheca cmne portedAto a hatch at floor elevation 463' of the auxiliary building.
This hatch is located above the dru==ing station area on the floor be-low.
The cask is lowered into the drumming st3 tion area, lits bo. tom is' }
/
a 3-ton removed and the cask is raised above a shipping container by/
j ib c r Filters with high radiation levels are place into a con-tainer of specia cinn which has a centrally ed, perforated 26 basket into which the filter
-* ridge overed.
The filter caraM dge
/
is detached from the grapple x after 1 5.ithin the cask.
FL-srs d ers used for with low radiation e s are randomly dropped into c licufd wa *.
The space around filters with either high or low b a-N tevels is filled with liquid waste which is solidified.
Filte r s are ib en rew nd Yve~ Ac C9sk 0"d hi3 h Me ye ty co,ksee deposited in a
disi o sal-o fe,-
2] ('
11.5-18 g/&tfMT
11.5.5.4 Radioactive Hardware Radioactive hardware can consist of damaged or used equipment or instru-ments, which due to geometry or materials of fabrication, cannot be readily decontaminated.
Such material is disposed of in much the same way as are filter cartridges or as compacted waste, depending upon radiation levels.
11.5.5.5 Compacted Waste An electromechanical compactor provides four tons of compressive force for the compaction of compressible waste into 55 gallon drums.
During compac, tion the drum and compacting mechanism are enclosed and the en-closure is vented to the auxiliary building atmosphere through a HEPA f5.lter by a blower.
The blower and filter are contained within the compactor.
The compactor conforms to current OSHA requirements.
The compactor will not operate unless the door is closed, preventing the operator from injury and preventing escape of unfiltered air to the atmosph ere.
[\\.
11.5.6 STORAGE F1 ' d containers are stored either on the radwaste operating floor a grade or
=ezzanine floor 11 feet above the operating floo, depend-ing upon contain activity. Filled 50 ft containers uiring 1-1/2 or 4 inch thick indiv. al lead shields are stor ron the operating floor which has storage capacity.
at least containers.
These shielded ggg containers are located between cc ete walls and 3 inch thick steel k.
g plates for additional shiel g.
Containers requir g no shielding are stored on t upper floor.
This floor has suf icient load capacity to permit storage o iners having
-C.
indivi 1-1/2 inch thick lead shields, if required.
Sto e capacity 3
fo 20, 50 ft containers is provided. These containers are al.
located ehind concrete walls for additional shielding.
/
w 4
/'
11.5-19
/W@AENT 27
TMSER T H
l Co~99 c h h/e wa ste and Fille d confa iners oV are s fore d in f4e s hie ld'e d' cm,pqe te d wasie aren s of th e va d was te opera fly floor and on -lh e me zz aning floor ll Peef alvve.
Con fa mina te d he< dwa re and fools may also be store d in
+b is areq.
i 1
I e
g
(
D N
redit is taken for decay in storage since rpent resins will have/had l
[
at leas one month decay period in either of the spent resin, storage
(
tanks before idification, when required. Evaporator bottoms do not normally require a ay period.
27r The area adjacent to the compact a storage capacity of approxi-
\\s_
mately 10 drums.
Additional ons t
ge is provided to accommodate one full offsite shipment of compacted wast Storage area, fo,r idified wastes, based on estima s presented in Section 11
.4, are thus capable of accommodating greater han 30 days wa generation.
11.5.7 SHIPMENT Shipment, in accordance with applicable regulations, is made as necessary dependent upon operational considerations and storage area availability'.
11.5.8 POTENTIAL FOR RELEASES 11.5.8.1 Potential for Release during Container Filling The filling operation is automatically terminated under any of the fol-loving conditions:
Overfill, indicated by the level probe. f The waste is stilMhi3' 1.
M4 er. The container __at4 hem
,orfull,condi-j 1
.m' 5 percent 4Q[
(
tion-is ^astu' ally oniv about 9
~
c,~.
u 2.
Loss of. ale.ctrical pouer en *he 1-vel probe. #ffl ovamgre in the vaste ptm:p_ discharge--11C '
4., -Overp 6 1n the venc litm fren tha rnntaig r.g Hi h preaso e in the Pill hen d,/ liner.
(
3, 3
r d ia h 'e ', mcWiceing Va rious o ther co n tro ls such 95 a
used by efc.,
h; h level alarm, +F:ll head TV camera,fion r
a e,
.%g opecatoc to e cnoin a re a F;// cpera iV q
(
e a p ecbien.;s encov.,tued 11 5-20 namEuT.w-M 1Y/y
mi-o flow in any of the feed es k,
6.
Excessive radiation, he radiation monitor at ner surface or 6 feet away.
t:=
airbarM8 There is noArelease to the atmosphere in the fill areas, Air in the container and gas, if any, from the waste entering the container are vented to the building exhaust through a local filter. Only one line feeds waste to the container.
This is flushed with water as the final phase of the fill cycle. When the lines are disconnected, the quick
- disconnects automatically seal so that no drippage. occurs.
There, are no physical barriers in the immediate fill argqS er-ee to contain l 2.9 spills, since the radiation sensors automatically stop M
ftionitraciutir "h2yve_a safe operatin
. The in-corporation of a concrete curb vo ermit use of the lift truck.
W Floor drains e
plugged as a res f solidification of the urea formaldehyde solidification agent in the unlikely of r
, a-si ficant spill.
In addition 8 pills from the shipping container
(,
would need to be drained to a special container since spilled material could not be mixed with the contents of any other tank.
The floor surfaces have a special nonporous finish to permit decontam-ination of the surface, if required.
11.5.8.2 Potential for Release from Storage Tanks l
11.5.8.2.1 Waste Evaporator Concentrates Tank i
Essentially all radioactive gases are stripped from the concentrates in the vaste evaporator. A normally closed vent is ducted to the auxiliary building exhaust system. A water seal, set for 2 feet of water, vents g
to the waste evaporator concentrates tank cubicle which is serviced by the auxiliary building exhaust system.
f 11,5-21 AMENDMENT g
._. m t, i m
.~
normal plant operating conditions.
Overflow protection is provided by a
,k high level alarm at the solid waste system control panel.
Excess water can either be pumped or drained to the waste holdup tank.
Overflow, if it occurs, is to the waste holdup tank through a relief valve.
The tank is enclosed within a concrete cubicle with entrance from an overhead shield slab.
Any leakage is directed to the floor drain tank through a floor drain.
11.5.8.2.4 Nuclear Blowdown Spent Resin Storage Tank This tank contains only trace amounts of radioactive gas. The gas is normally contained in the tank by a closed vent valve.
The tank is vented to the cubicle, which is serviced by the building exhaust sys-tem, only during transfer of resin from the demineralizers or at the conclusion of resin transfer from this tank to the radwaste packaging area.
4(
Overflow is not anticipated since the nuclear blowdown spent resin storage tank capacity is sufficient to accomnodate at least 30 days waste generation under nor=al plant operating conditions.
Overflow protection is provided by a high level alarm at the solid waste system control panel.
Excess water can either be punped or drained to the nuclear blowdown system reservoir.
Overflow, if it occurs, is to the nuclear blowdown system reservoir through a relief valve.
The tank is enclosed within a concrete cubicle with entrance from an overhead shield slab.
Any leakage is directed to the nucir.ar blowdown system reservoir through a floor drain.
f 1.5.8.2.5 W g Tank The WBT is used to on radioactive liqu e and resin W~
r o packaging.
Waste will not be stored in this ll.5-22a 29 AMENDMENT M ~
=J"Z, lm -
except for the quantity prepared for immediate packaging and solid-/
f ificatt Any radioactive gases that may have been present in evaporator co. entrates or chemical drains' w.
'.d have been r ased either in the resp tive storage tanks or during oper
'ons prior to 2
storage.
However, the T is vented to the ding exhaust system through a filter and water ented point is located at the top
~
of the tank.
The WBT is e pe
'th normal and high level probes.
Overflow is not a
- 1 pated since filli of the WE'" is closely moni-tored pri o the solidification operation.
e cubicle housing is de ~ ned to contain the WBT contents in the event of nk rupture.
/
- \\
l
(
<(
(b
- (
- (
'2-9 11.5-23 AMENDMENT [
-JUNE, 1980-
1
- 11..
Radvaste Module Cubicle The radwaste/ recirculation pum ropriate valving are located within a, concrete cubici neath the WBT cu A 6 inch high 1h m
concrete curb aics any leakage which may occur in thi ca.
The cub' is serviced by the building exhaust system.
l
.C
. ~
C
(
2 '1 11.5-24 AMENDMENTJV JUNE, 1980
7 TABLE 11.5-5 (Continued)
C'-
SOLID WASTE SYSTEM EQUIPMENT DESIGN PARAMETERS Urea Catalyst Tank l
Quantity 1
-Volume, gal 5000 f
Type Horizontal Design Pressure Atmospheric Design Temperature, F
150 Urea Formaldyhyde Concentrates (
)
Storage Tank Zf Quantity 1
Volume, gal 5000 Type Horizontal Design Pressure Atmospheric Design Temperature, F
150 Urea Formaldehyde Concent ates (UFC) Day Tank Quantity 1
Y Volu ae, gal 750 l
Type ertical Design Pres ure At ospheric Design T perature, F
10 Sodium Hydr ide Addition Tank Quan ty 1
Vo ume, gal 200 ype Vertical Design Pressun Atmospheric Design Temperature, F
150
(
l 2.7 11.5-30 AMENDMENT W J NE, 1987
l
/
TABLE 11.5-5 (continusd) l
(-
SOLID WASTE SYSTEM EQUIPMENT DESIGN PARAMET Sulfuric Acid Additio Tank Quantity 1
gp Volume, gal 100 Type Vertical
.. Design Pressure Atmospheric Design Temperature, F
150 Waste Blending Tank Qua'ntity 1
I*
- Volume,
-1 800 Type Vertical D
ign Pressure A ospheric Design Temperature, F
1
!c a
C k.
[
27 11.5-30a AMENDMENT W J'J"C, 1080
aa O
sJ,
EE o~*;
3 A
e US
- 2. 7 7 I
gg j ] j _-
t 4
I 1
t 1
I
=
=
I st
-d E
* d G-;
'T
- di jr t e.j
'** m
.s.i;; f.:s g-d L*
o e
E 8
- I a
- :; d5 qg i ii 4
gI c:
F, c.
s
' 3 2-g i :'% is :
ER 3
'li s
4,Q.0 t
tj i
5lk.
y.,
{-c M dg i;3
'!.II!i.i it,i 58 3
s-V s
f.,k !.,!
- . a.
=_
y Id.
EE
~,,_
.. M :I {
3 6, j. k' K'fe IM j.8 t
_../
F*
.Sa o-a.[ s A.
~
!l
- s!i 11 II g (s.J.
if
) !I.) s,M,e g i
i, i
t.
he. {lJlll%,[
E' -- '
-8 l
.:-;'i=f d " P (4 ', gW.*P E
,h d
i c)
'l e
h' s
ii e@2:i Y';s 0
a:
' D':i i he th!ir- )%
e i l1 1: 94 I
89 s
r d
N
-- ! j 9:!
_ l'p T '~" :.
' - + - - - - - '
r L
i,
(.! -
l L' W.;
j
[<*
~
I
+
- rF a-
==
g j; s
lg*hk w]- il,:
h
. E t !ll [-
gt:
i.' ; i a5
@J e L. '.............
g~o
}
y
- g3 l
,\\
{N E
w a
+
di 4
~
/
e m-N o
a y
9 aa s
s I
E gt r-------
4k'
$L[
15 0 e
d' e
4 U
l i
J 4
8 i
$p x{p ::J+i;p.j w a.geg g, m,;,
3, s
p}-
pa a
1:
I
- c s 1i t ra.c h
1 v...i l O,y m
-1 4
_3 m.
s o
u : i.I 3:; o:
V
.f
~,1
',y :"s,
if -
-41 "mi gC:: *i
'g 3:..'iM_.
E J
~
i kaw,e' i
s.
ec El z
N<
T '_
\\.. s......'
3 t
e
- F-il
'3 M
- tj ni
- c o I
f3 s
Q, f 13 d
sb h'
i I
14 q
gS g,
+
,1.t J
N,.! il
~!'
2'_
4,a<.7 \\
p% ~*ii%f l
=
H
,f ;;e
, re G
., Jh.-
z_
> r g
g f[.)dir-~!!!
hi
.I Leie t, 9 ( p<
<tfe~ = ri rc d'..
.i l
n
- rii'
!, guy i;f
..m t
i T
t
~y e
I-y, l
- n e
i
- "'I l
S L.J ~;r e el 9 *:
s tu
~
3..
l
@?
E
) 'N f
i'
l l[it' 3
.M.4 f 3 i
d J
ti ti h iji g',
)
7 l
ll!Illit; tij g=3.q ri;ris:str.:g g"
l t
r l
2 3 E',Irr ete sirs
- p+ 8?? e( 12 3
?
e;s.g F { s s...s e s s,;.
f i
- , U. nil l
.i.......
- f t..,
i t'
I i
1 1
i i
L
-