ML20117A568
| ML20117A568 | |
| Person / Time | |
|---|---|
| Site: | Waterford |
| Issue date: | 07/28/1996 |
| From: | Burke J, Gropp P, Viener D ENTERGY OPERATIONS, INC. |
| To: | |
| Shared Package | |
| ML20117A554 | List: |
| References | |
| W2.302, NUDOCS 9608260203 | |
| Download: ML20117A568 (28) | |
Text
'
}l s
s MANAGEMENT MANUAL Site Directive No. W2.302 ENTERGY OPERATIONS VOLUME IV Attachment i Rev. No. 2 Page l of 9 SIGNATURE PAGE Activity
Title:
LDCR 97-0047 - Location of Cabinets C-3A(B) and C-4 Outside the CVAS Boundary - Rev.1 The signatures below apply to the following marked items. (Each item should be marked YES or NO.)
PART A
- PRELIMINARY 10CFR50.59 SCREENING X YES NO PART B,C,D
- 10CFR50.59 SAFETY SCREENING X YES NO ENVIRONMENTAL IMPACT SCREENING
~,
RADIOACTIVE WASTE SYSTEMS SCREENING 10CFR50.59 SAFETY EVALUATION X YES NO ENVIRONMENTAL IMPACT EVALUATION YES X NO RADIOACTIVE WASTE SYSTEMS ADDITIONAL SAFETY EVALUATION YES X NO LICENSE DOCUMENT CHANGE REQUEST X YES NO Preparer /Date do6N 3orke b
7-E6 94 V Print Na e/ Signature Reviewer /Date Ib ll64x.
7 p 4 P/fnt Na e/Signatufe '
Supervisor /Date Ad!N/2aFr,
[hp 7// f/';P6 Print Name/ Signature Environmental Dept./Date
- Print Name/ Signature j
If there is no Environmental Impact Evaluation required, this line may be marked NA by the preparer.
hDR i
ADO 050 82 P
.t ENTERGY MANAGEMENT MANUAL Site Directive No. W2.302 C-C' OPERATIONS VOLUME IV Attachment l Rev. No. 2 Page 2 of 9
SUMMARY
INFORMATION FOR 10CFR50.59 AND ENVIRONMENTAL IMPACT SCREENING AND EVALUATION Activity
Title:
LDCR 97-0047 - Location of Cabinets C-3A(B) and C-4 Outside the CVAS Boundary - Rev.1 l
1.
Description of the proposed change The proposed change will prescribe Local Leak Rate testing requirements for penetrations 53 & 65 to address these potential bypass leakage paths created by the location of cabinets C-3A(B) and C-4.
In response to NRC Question 480.36, LP&L stated that instrumentation lines through penetration 53 and 65, form a closed system outside containment, are seismically qualified, and terminate in an area exhausted through the filters of Controlled Ventilation Area System (CVAS). Therefore they do not need to be bypass leakage tested. The design of penetrations 53& 65 was approved by the NRC (SER) based on this information.
Contrary to the above the current plant configuration indicates that these lines terminate in C-3A(B) and C-4 cabinets which are outside CVAS boundary thus resulting in potential bypass leakage paths.
Waterford 3 FSAR will be updated to place the sensing lines in the Leak Rate Testing program, and include the isolation valves on monitoring lines for Type C testing.
Additionally, the FSAR will be updated to clarify that the sensing lines meet the design criteria for a closed system for instrumentation lines outside containment.
Reg. Guide 1.11 provides guidance on design requirements for instrument lines penetrating primary reactor containment. The instrument lines up to the downstream isolation valves at penetrations 53 & 65 meet the requirements of Reg. Guide 1.11.
There is no guidance in Reg. Guide 1.11 for the design of instrumentstion lines downstream of the outside containment isolation valve. ISA 67.02-1980 and ANSI /ANS-56.2/N271-1976 Section 3.6.2 provides the criteria to meet a closed system for instrumentation lines outside containment.
The sensing lines run from containment to a manual globe valve followed by an excess flow check valve. The lines terminate at C-3A(B) cabinets outside an area exhausted or filtered by CVAS. The instrumentation for sensing lines measure differential pressure between containment and annulus and send signal to CVR system, opening CVR-101 and CVR-201 in presence of vacuum inside containment.
t a
ENTERGY MANAGEMENT MANUAL Site Directive No. W2.302 W
OPERATIONS VOLUME IV Attachment i 2
Rev. No. 2 Page a of 9 The monitoring' lines run from containment to a solenoid globe valve followed by an j
excess flow check valve. The lines terminate at C-4 cabinet outside an area j
exhausted or filtered by CVAS. The instrumentation for monitoring lines measure j
differential pressure between containment and annulus, and provide signal to the i
plant computer and containment purge. The solenoid valves, CVR 401 A(B), normal position was changed to normally closed per OP-002-010.
i The tubing for both sensing and monitoring lines up to the excess flow check valves are ASME safety Class 2, Seismic Category I. The sensing line tubing downstream of j
the isolation valves (CVR-302A&B) has been designed and built to seismic category 1, ASME Safety Class 3 requirements, and is located such that it would not be j
subjected to any jet impingement loads, pipe whip or missiles in accordance with ANSI /ANS-56.2/N271-1976 and ISA 67.02-1980.
1 This 50.59 revision is adding clarification that the CVR sensing lines constitute a j
closed system for instrument lines outside containment in accordance with ANSI /ANS-
{
56.2/N271-1976 and ISA 67.02-1980.
i 2.
Documents and FSAR sections reviewed Reg. Guide 1.11 FSAR Sections 1.8,1.9.37, 6.2.4, 6.3.3.8, 7.1, Tables 3.9-9, 6.2.32, 6.2-43 ANSI /ANS-58.9-1981 j
ANSI /ANS-56.2/N271-1976 2
ANSI N658-1976 ASME Code, Section Ill, Subsection NC & ND, '71 Ed. through Winter '72 Ad.
Mercury Isometric Drawings V 10.65-1001-4, 3,11 & 12 Drawing G-1113, Sh. 2 & 4 Drawing B-430, Sh. DP-26 & BM-01, DP-31 Ebasco Letter LW3-1128-83 Spec LOU-1564.407 Tech Manual 457000494 SER 6.2.4 (NUREG 0787)
SER Supp. 9 issue #2 (NUREG 0787)
SRP 6.2.4 (NUREG 0800)
FSAR Question 480.26 Seismic Qualification Report SQ-IC-61 l
.t ENTERGY MANAGEMENT MANUAL Site Directive No. W2.302 C: ' OPERATIONS VOLUME IV Attachment i Rev. No. 2 Page 4 of 9 Tech Spec. 3/4.6.1.2 TRM Table 3.6-2 TRM Table 3.6-1 SK 407, Sh. 244 PEIR OM-129 i
OP-002-010 lSA-67.02-1980 1
Draft Reg. Guide - Instrument Sensing Lines Dated March 1982.
3.
Function of affected equipment / procedure The Containment Vacuum Relief (CVR) system protects the vessel from excessive differential pressure when the containment pressure is lower than the annulus pressure. The CVR system acts to equalize pressure across the containment during an inadvertent spray which lowers containment pressure. Penetrations 53 and 65 each contain two instrument lines. One senses differential pressure across the containment vessel and provides a signal to actuate the CVR system and the other monitors the differential pressure and provides an input to the plant computer and containment purge. The sensing line contains a manually operated valve and an excess flow check valve, located outside containment. Due to its primary safety function, the sensing instrument lines of the CVR system are designated as
" essential" thus, not requiring automatic containment isolation. The monitoring line contains a solenoid operated valve and an excess flow check valve, also located outside containment.
4.
Impact of change on function of equipment / procedure The proposed change will prescribe Local Leak Rate requirements to penetrations 53 i
& 65 to address these potential bypass leakage paths. Since the CVR sensing lines are designed and built to ASME Class 3, the CVR sensing lines constitute a closed system for instrument lines outside containment in accordance with ANSI /ANS-56.2/N271-1976 and ISA-67.02-1980 and will maintain its integrity during all Design Basis Events.
5.
Brief summary of screening / evaluation results This change will not affect the associated equipment and containment integrity. In addition, the radiological dose releases remain below acceptable limits because CVR-401 A(B) will remain closed per OP-002-010. The proposed change will prescribe Local Leak Rate requirements to penetrations 53 & 65 to address these potential bypass leakage paths. The safety evaluation did not raise any unreviewed safety questions.
1 ENTERGY MANAGEMENT MANUAL Site Directive No. W2.302
-' OPERATIONS VOLUME IV Attachment i Rev. No. 2 Page 5 of 9 PART A - PRELIMINARY 10CFR50.59 SCREENING Activity
Title:
LDCR 97-0047 - Location of Cabinets C-3A(B) and C-4 Outside the CVAS Boundary - Rev.1 l
Does the proposed change or activity represent:
YES NO X (1)
A change or activity which, in its entirety. has received prior NRC approval?
YES NO X (2)
A change or activity which, in its entirety. is addressed by an existing approved 10CFR50.59 evaluation?
YES NO X (3)
A change or activity which, in its entirety. constitutes a change to the QA Program, Emergency Plan, Security Plan, Operator Requalification Program?
j YES NO X (4)
A clearly editorial change or typographical correction?
YES NO X (5)
A correction of a nonconformance which results in preserving any applicable licensing basis?
YES NO X (6)
A change to the Technical Specifications and/or Operating License?
YES NO X (7)
A change to the approved fire protection program which would adversely affect the ability to achieve and maintain safe shutdown in the event of a fire, or a significant change to the basemat cracking surveillance program?
Provide an explanation and references for any YES answer below:
YES X NO A change to the FSAR is required for this proposed change or activity. If yes, complete page 7 of Attachment 1.
- ENTERGY MANAGEMENT MANUAL Site Directive No. W2.302 W~ OPERATIONS VOLUME IV Attachment i Rev. No. 2 Page 6 of 9 LICENSE DOCUMENT CHANGE REQUEST FORM LDCR NO.
LDCR 97-0047 - Location of Cabinets C-3A(B) and C-4 Outside the CVAS Boundarv - Rev.1 l
FSAR SECTIONS, TABLES, OR FIGURES REQUIRING CHANGES:
FSAR Section 1.9.37 FSAR Section 7.1.2.7 FSAR Table 3.9-9 FSAR Table 6.2-32 FSAR Table 6.2-43 TRM Table 3.6-1 TRM Table 3.6-2 i
i i
Received and logged by LDCC:
Initials:
Date:
SE #:
WSES-FSAR-UNIT-3 (2)
Continuing Leak Reduction - Establish and implement a program of preventive maintenance to reduce leakage to as-low-as-practical levels. This program shallinclude periodic integrated leak tests at intervals not to exceed each refueling cycle.
Response
LP&L has instituted a program to maintain leakage rates of systems outside containment which could contain radioactivity to as low as practical. To support this program, a review of plant systems has identified the systems outside containment which could potentially contain highly radioactive fluids following a serious accident.
A.
Systems included in the leak reduction program:
1)
Containment Spray System - that portion of the system located outside containment that would be in use in the recirculation mode of operation including that suction piping from the Safety injection Sump up through the pumps and heat exchangers to the containment isolation valve.
2)
Low Pressure Safety injection - the piping outside of containment in use during operation in the shutdown cooling mode.
3)
High Pressure Safety injection - the piping from the recirculation suction header through the pump up to containment.
4)
Hydrogen Analyzer System - that portion of piping from the outside containment isolation valve to the Hydrogen Analyzer Panels, along with the piping to the containment atmospheric grab sampler in the post accident sampling area and retum piping back to the containment isolation valve.
5)
Post-accident Sampling System (PASS)- For the liquid portion of the system, testing includes the piping from the Si sump suction header through the sample pump to the PASS skid packages back to the outside containment isolation valve. Also included is the piping from the RCS Hot leg Sample outside containment isolation valve to the j
PASS skid package and back to the containment isolation valve. For the gas portion of the system, also included is that portion of the tubing from the liquid / gas separator j
through the skid package back to the outside containment isolation valve.
j 6)
Containment Vacuum Relief (CVR) - the essential instrument tubino from outside containment to the differential oressure instruments.
B.
Systems excluded from the program (their isolation will not preclude any option of cooling the reactor core nor prevent the use of needed safety systems):
1)
The Gaseous Waste Management System. This system isolates on CIAS and is not required for use post-accident. The Reactor Coolant Vent System provides RCS venting l
as discussed in Subsection 1.9.18.
l 1.9-37 1
,y WSES-FSAR-UNIT-3 R G.1.11 Instrument Lines Penetratina Primary Reactor Containment (3/1061)
The recommendations of Regulatory Guide 1.11 are complied with by the following design:
a)
A manually operated valve shall be installed as close to the containment as practicable and, b)
Essential system instrument lines shall have a A-self actuated excess flow check valve th:!! be installed as close to the containment as practicable downstream of the manually operated valve.
T4us-ext = Ov! check valve v>"! pene= n e';u !!:!ng !'ne. The ^qu !!:ing !ine "" have I
need!e ve!ve be!!* Ia to keep !ed:ge p = the ded v !ve v"'M-the !!Ov; b! !"!!:!" c"ce of an acciden' Upon hiah pressure in containment. the excess flow check valve will close. Since the excess flow check valve is orificed. the sensina line will eaualize causina the excess flow check valve to oDen and Dermit normal oDeration of the monitorin's system. The instrument lines downstream of the excess flow check valves are desioned to Sa' sty Class 3. Seismic Cateaory
- l. therefore meet a closed system for instrument lines outside co' tainment.
M c)
Nonessential system instrument lines will be fit with solenoid val ves in lieu.of manual valves.
The solenoid valves will close on SlAS-CIAS and sh !! be reope ned manu !!y 'r0m a !Oce!
contro!Ste!!On Up^n h!;h pre =ure !a 'he cont:!." ment, the excen '5t! ded v !v:;'"! c'ere And st:y O'Oc-d i'*here ! 0 bred 'a the !:ne downctream Of'he V:!ve. "'here !: no brech, the eque!!:ing !tne v'"! O!!OW qua!!::t!On of pre =ure on either !de Of 'he check v !ve. This v""
e!!Ove the ded va!ve to Op^n and per"" no"". ! Op retion of 'he monit0dng rytter d)
The containment extreme wide range pressure instrumentation for post accident monitoring consists of a sealed liquid filled system with bellows, following the guidelines in ANS-56.2/N271-1976.
R.G.1.22 Periodic Testina of Protection Systems Actuation Function (2/17n2)
Testing of the RPS and ESFAS in compliance with Regulatory Guide 1.22 is described in sections 7.2 and 7.3.
R.G.1.29 Seismic Desian (6092)
The (1strumentation and control of safety-related systems and safety-related portions of systems comply with Regulatory Guide 1.29.
R.G.1.30 Quality Assurance Reauirements For the Installation. Inspection and Testina of Instrumentation and Electric EauiDment (08/1192)
References discussing comparison of the design with the recommendations of Regulatory Guide 1.30 is provided in Table 8.13.
R.G.1.40 Qualification Test of Continuous Duty Motors Installed Inside the Containment of Water Cooled Nuclear Power Plants (3/1693 i
A comparison of the design with the recommendations of Regulatory Guide 1.40 is provided in section 3.11.
7.1-8
b
.e WSES-FSARAMT-3
=
TABLE 3.9-9 (Sheet 14 of 19)
NON-NSSS SUPPUED ACTWE VALVES AND PUMPS System System Safety Design Operateg Eaurenent Taa No.
Quanhtv Ing!!
Operator Manufacturer Class Ratma Condlions She Funchon 2FP-V128 2
Check TRW Mission 2
175 peig 130 psig 3"
Operate 2FP-V130 120"F 100"F Baron Hanonement System
[
Valves 3
Contemment isolahon 28M10lWB 2
Gate Deephragm ITT GnnneN 2
50 psig S psig 3"
Close 28W109AS 2637 120*F t
HVAC-Purse Valves 2HV41508 6
Butterfly Piston Fesher Controls 2
44 psig 44 psig 48" Close 2HV-8151A 300 7 300"F 2HV-8152A 2HV4153B 2HV4154B 2HV4155A t
Vacuum Rehof Valves 2HV4156A 2
Butlergy Piston Fisher contrats 2
44 psig 44 psig 24" Close 2HV4157B 3007 3007 2HV-V180A 2
Check GPE Controls 2
44 peig 44 psig 24*
Operate 2HV-V1818 300T 300"F 2HV-E634A 2
Globe Solenoid Valcar 2
44 osia 44 osia
_ar close l
[
2HV-E6338 300"F lp00T l
?
oranon 2
44 osia 44 osia E
Oonale l
I aggi 3
ceux*
=
300"F 300"F l
QARS Valves Exhaust 2HV-F253A 2
Butter #y Motor Fisher Contro6s 2
Vac Vac 4'
Open 2HV-F2548 150"F 1507 2HV-8167#
2 Butterey Motor Fesher Controis 2
Vac Vac 4'
Open 2HV41688 150"F 1507 Supply 2HV-V184A 2
Check GPE Controls 2
150 psig Vac 4"
Operate 2HV-V1858 261T 150"F
- - - ~
. ~
-- - -~~
.e WSES-FSAR-UNIT-3 TABLE 6.2-32 (SHEET 60 OF 65) Revisen 8 (5/96)
CONTAINMENT PENETRATIONS AND ISOLATION VALVES 4
(MODIFIED)
PENETRATION Nor 53 TYPE @: E CLASS: D VENTEDORAINED FOR TYPE *A* TESTN: NO TYPE FLUID *I: CONTAMENT ATMOSPHERE I
VALVE TAG NO.: UNO CVRMVAAA301 A CVRM/AAA30M CVRISVD401 A CVRM, AAA402A l
EBASCO 2CA-VtiOO 3401 2HVE634A 3401 VALVE TYPE GLOBE EXCESS FLOW CHECK GLOBE EXCESS FLOW CHECK VALVE OPERATOR MANUAL SELF SOLENOID SELF ACTUATION MODEU: PRIMARY MANUAL SELF SOLENOID SELF SECONDARY NOT APPUCABLE NOT APPUCABLE VALVE POSITION @:
NORMAL OPEN OPEN OPEN OPEN SHUTDOWN OPEN OPEN OPEN OPEN POST 6 OPEN OPEN CLOSED OPEN CLOSED l
LOSS OF POWER TO ACTUATOR NOT APPUCABLE NOT APPUCABLE CLOSED NOT APPUCABLE I
ACTUATION SIGNAL @:
NONE NONE CIAS NONE MAXIMUM CLOSURE TNE (SEC.)
NOT APPUCABLE NOT APPUCABLE 5
NOT APPUCABLE UNE SIZE (E4CH)
ESSENTIAL @:
YES ygg NO NQ l
FLOW DIRECTIONM; EFFLUENT FROM CONTAMENT EFFLUENT FROM CONTAMENT EFFLUENT FROM CONTAMAENT EFFLUENT FROM CONTAMENT l LOCATION REFERENCE TO CONTAINMENT @:
OUTSOE OUTSIDE OUTSIDE OUTSIDE POWER SOURCE (ACOC)
NONE NONE AC-SA NONE APPROXNATE LENGTH OF PIPE (FT.-N.)M:
5 5
5 5
TYPE V TESTSO:
NO NO NG_Yg1 NO l
TEST ARRANGEMENT @:
NOT APPUCABLE B430 Sheet DP-31 l
SYSTEM NSTRUhENT H&V NSTRUhENT H&V NSTRUhENT H&V WSTRUhENT H&V REMARKS I
=
.C WSES-FSAR-UNIT-3 TABLE 6.2-32 (SHEET 72 OF 85) Revisson 8 (5/96)
CONTAINMENT PENETRATIONS AND ISOLATION VALVES I
PENETRATION NO; 85 TYPEO: E CLASS: 0~
VENTEDORMNED FOR TYPE "A" TEST @I: YES*
TYPE FLUID *I: CONTAMENT ATMOSPHERE VALVE TAG NO.: UNO LR1MVAAA202 LRTMVAAA204 CVRMVAAA3018 CVRMVAAA3028 l
EBASCO
. 2SA-V909 2SA-V611 2CA-V501 3401 VALVE TYPE GLOBE GLOBE GLOBE EXCESS FLOW CHECK VALVE OPERATOR MANUAL MANUAL MANUAL SELF ACTUATION MODEN: PRNARY MANUAL MANUAL MANUAL SELF SECONDARY NONE NONE NOT APPUCABLE VALVE POSITION @:
NORMAL LOCKED CLOSED LOCKED CLOSED OPEN OPEN SHUTDOWN LOCKED CLOSED LOCKED CLOSED OPEN OPEN POST-ACCIDENT CLOSED CLOSED OPEN OPEN LOSS OF POWER TO ACTUATOR NOT APPUCABLE NOT APPUCABLE NOT APPUCABLE NOT APPUCABLE ACTUATION SIGNALN:
NONE NONE NONE NONE 5
MAXNUM CLOSURE TWE (SEC.)
LINE SIZE (INCH) 1 1
ESSENTIALN:
NO YES Hj5 l
FLOW DIRECTIONN:
WFLUENT TO CONTANENTI EFFLUENT FROM CONTANWENT EFFLUENT FROM CONTAMENT l EFFLUENT FROM CONTAMMENT LOCATION REFERENCE TO CONTAINhENTN:
OUTSOE OUTSOE OUTSOE OUTSOE POWER SOURCE (AC/DC)
NONE NONE NONE NONE APPROXNATE LENGTH OF PIPE (FT.-N )N:
5 5
5 5
TYPE"C" TESTS @:
YES YES NO NO TEST ARRANGENENTN:
NOT APPUCABLE SYSTEM CONTAINRENT LEAKAGE RATE CONTAINMENT LEAKAGE RATE CONTAINMENT LEAKAGE RATE CONTAsNMENT LEAKAGE RATE
' TEST CONNECTION AND TEST CONNECTION AND TESTCONNECTION AND TEST CONNECTION ANO INSTRUhENT H&V NSTRUDENT H&V NSTRUNENT H&V NSTRURENT H&V REMARKS
- YES FOR 2SA-VOO9
" REFER TO LOU 1564-G-164 SH1 (ZONE N-14)
.. -.. - ~. ~.. _, _,.. _ - -~~.
. -.. -. -... - - ~.... ~. - ~ - -.. ~. - ~ - -. - ~..
-.. ~ -... _...
9 r
L
.t r
WSES-FSAR-UNIT-3 TABLE 6.2-32 (SHEET 73 OF 85) Rewsion 2 (5/96)
, i CONTAINMENT PENETRATIONS AND ISOLATION VALVES I
(MODIFIED)
PENETRATION NO.: 85 (CONTNUEDI TYPE @: N CLASS: D
' VENTEDORAINED FOR TYPE *A* TEST ); _YES*
TYPE FLUID "):__ CONTAltmENT ATMOSPHERE 8
I i
VALVE TAG NOz Ut3D CVRISV04018 CVRMVAAA4028 LRTMVAAA201 LRTMVAAA203 l
l E8ASCO 2HV-E6338 3401 2SA-V610 2SA-V612 VALVE TYPE GLOSE EXCESS FLOW CHECKVALVE GLOSE GLOBE SOLENOID SELF heANUAL MANUAL VALVE OPERATOR @: PR844RY ACTUATION MODE SOLENOID SELF MANUAL MANUAL SECONDARY NOT APPUCABLE NONE NONE VALVE POSITION @:
i NORMAL OPEN OPEN LOCKED CLOSED LOCKED CLOSED t
f SHUTDOWN OPEN OPEN LOCKED CLOSED LOCKED CLOSED POST-ACCOENT CLOSED QPEN CLOSED LOCKED CLOSED LOCKED CLOSED l
l LOSS OF POWER TO ACTUATOR CLOSED NOT APPUCABLE NOT APPLICABLE NOT APPUCABLE ACTUATION SIGNAL *):
CIAS NONE NONE I
hmXNUM CLOSURE TBE (SEC.)
5 5
UNE SIZE (INCH) 1 1
L ESSENTIALN:
NO
!g2 l
[
FLOW DIRECTION ):
EFFLUENT FROM CONTAIPSENT EFFLUENT FROM CONTAIPGENT EFFLUENT FROM CONTANMENT EFFLUENT FROM CONTAINMENT l
N i
LOCATION REFERENCE TO CONTAINMENT ):
OUTSIDE OUTSIDE OUTSOE OUTSOE N
POWER SOURCE (ACDC)
AC-58 NONE NONE NONE j
APPROXMATE LENGTH OF P!PE (FT.-N )@):
5 5
}
t TYPE V TESTS ):
NORS NO NO NO l
0 TEST ARRANGERENT@):
5430 Sheet DP-31 G-164 SH1 (L.12)
G-164 SH1 (M-14) l
. SYSTEM CONTAINhENT LEAKAGE RATE CONTAIP8ENT LEAKAGE RATE CONTAIPMENT LEAKAGE RATE CONTAINhENT LEAKAGE RATE
{
TEST CONNECTION AND TESTCONNECTION AND TEST CONNECTION AND TEST CONNECTION AND NSTRUhENT H&V NSTRUlWENT H&V NSTPUhENT H&V NSTRUhENT H&V i
REMARKS
i I
WSES FSAR-UNIT-3 TABLE 6.2-43 (Sheet 2 of 2) 15,16,17,18,19,20,21,22 The Component Cooling Water Supply and retum to the Containment Fan Cooler Units form a closed seismic Category I system inside of containment. Isolation valves in these penetrations will not be exposed to the contaimment atmosphere during a loss of coolant accident.
27,32,33,34,35,36,37,38, The Charging, High & Low Pressure Safety injection, 39,40,41, 55, 56,57, 58,69,70 Safety injection, Shutdown Cooling Suction, Containment Spray and ECCS Sump Suction penetrations are all connected to closed seismic safety class 2 systems outside of containment. These penetrations from the ECCS system will be in operation during a loss of coolant accident. The piping systems are designed for pressure and temperature equal to or greater than containment design pressure and tempemture. In all of these penetrations, except 32 thru 35,40 &41 water pressure can be guaranteed to exist under loss of coolant accident conditions, even considering single active failure criteria. Penetrations 32 thru 35,40 and 41 can be guaranteed to have a wate seal under post LOCA conditions. Figures 6.2-59 thru - 64 show the routing and elevation of safety grade piping and associated components that indicate the existence of a water seal.
53,S5*
Th::: penetret!:nc ere t::t:d durin; !.t:;rried !::h ; ::t test 4ee
- h:::fer: de net :;u! : : : pr :t: Type 'C' tet.
25 Per the requirements of 10CFR50 APP J,11-G, this penetration will be Type B tested.
50,64,72 These penetrations are welded blank spares containing no piping or valves.
4 54 This penetration, used to monitor containiment pressure, is a sealed fluid system.
":ndet!:n SS !: p:t:l!y t :t:f te Type C : ;u! :m:nt:. 9:fer :: T:b!e S.2 32 for bre:Eder'-
ef t :t!n;: ;u!rrment:.
l
TABLE 3.6-1 (Continued)
CONTAINMENT LEAKAGE PATHS PENETRATION NO SYSTEM NAME VALVE TAG NO.
TEST TYPE 45 CARS Makeup to Containment CARMVAAA101B BypassT" pe C CARMVAAA102B 46 CARS Makeup to Containment CARMVAAA101A Bypass /T pe C 3
CARMVAAA102A 47 CARS Exhaust from Containment CARMVAAA202B B passfrype C 3
CARMVAAA201B Containment Pressure Exhaust CARMVAAA2008 48 CARS Exhaust from Containmentt CARMVAAA202A B passfr3pe C 3
CARMVAAA201A 49 Containment Atmosphere ARMISVolle Type C Monitoring Inlet and
. ARMISV0109 Outlet ARMMVAAAIS4 ARMISV0103 l
51 Refueling Cavity FS MVAAA405 Bypass / Type C Purification Inlet FS MVAAA406 53 CVR Non Essential Monitorine CVRISV040lA Bypass / Type C LJne 59 Safety Injection System SI MVAAA344 Bypass / Type C from SI Tank to Refueling SI MVAAA343 Water Storage Pool 60 Fire Protection System FP MVAAA601A Bypass / Type C to Reactor Building FP MVAAA602A B pass / Type C 61 Fire Protection System FP MVAAA601B 3
to Reactor Building FP MVAAA602B 3/4 6-4 AMENDMENT NO. 2 l
TABLE 3.6-1 (Continued)
CONTAINMENT LEAKAGE PATHS PENETRATION NO.
SYSTEM NAME VALVE TAG NO.
TEST TYPE 62 Water from Refueling FS MVAAA416 Bypass /T pe C 3
Cavity to RWSP FS MVAAA415 63 Containment leakage Rate LRTMVAAA109 Type C Test Connection Blind Flange 65 Containment Leakage Rate LRTMVAAA202 Type C Test Connectiosund LRTMVAAA204 lestemment-H&V CVR Non Esstatial Monitorine CVRISV0401B Bypass /Twe C Li.!!!
TpeC 66 Hydrogen AnalyzerSupply HRAISV0110A 3
and Return HRAISV0109A HRAISV0126A HRAMVAAAl28A T pe C 67 Hydrogen AnalyzerSupply HRAISV0110B 3
and Return HRAISV0109B HRAISV0126B HRAMVAAAl28B B passff pe C 71 Demineralized Water CMUMVAAA244 3
3 CMUMVAAA245 Escape Inck NA Bypass /T pe B 3
PersonnelImk NA Type B Electrical NA Type B Penetrations Equipment Hatch NA Type B T pe B Expansion Bellows Various 3
1,2,3,4,25,32,33,43 3/4 6-5 AMENDMENT NO. 2 l
TABLE 3.6-2 CONTAINMENT ISOLATION VALVES PENETRATION VALVE NUMBER NUMBER FUNCTION IV. Check Valves (Continued) 13 CVRMVAAA202 Vacuum Relief 14 NG MVAAA158 Containment N2 Supply 23 CC MVAAA644 CCW to RCPS and CEDM Cooler 27 CVCMVAAA219 CVCS Charging Une 34A&B CS MVAAAl28A Containment Spray 35A&B CS MVAAAl288 Containment Spray 36 SI MVAAA143B Si from LPSI Pumps to Imp 1 A 37 SI MVAAA142B Si from LPSI Pumps to Imp 1B 38 St MVAAA143A Si from LPSI Pumps to Imp 2A 39 SI MVAAA142A SI from LPSI Pumps to Imp 2B 45 CARMVAAA102B CARS Makeup 46 CARMVAAA102A CARS Makeup 49 ARMMVAAA194 Containment Atmosphere Monitor 53 CVRMVAAA302A Containment Vacuum Relief Essential l
Instrument Line Excess Flow CVRMVAAA402A Containment Vacuum Relief Non-Essential Instrument Line Excess Flow 55 St MVAAA241 SIS from HPSIImp IA 56 St MVAAA242 SIS from HPSI imp IB 57 SI MVAAA243 SIS from HPSI imp 2A 58 St MVAAA244 SIS from HPSIimp 2B 60 FP MVAAA602A Containment Fire Water Hender 3/4 6-12 AMENDMENT NO. 02 l
6 TABLE 3.6-2 CONTAINMENT ISOLATION VALVES PENETRATION VALVE NUMBER NUMBER FUNCTION IV. CheckValves(Continued) 61 FP MVAAA602B Containment Fire Water Hender 65 CVRMVAAA302B Containment Vacuum Relief Essential Instrument Line Excess Flow CVRMVAAA402B Containment Vacuum Relief Non-Essential Instrument IJae Excess Flow 66 HRAMVAAAl28A Hydrogen Anal}ier 67 HRAMVAAAl28B Hydrogen Anal}2er 69 St MVAAA510A St Hot Lag Injection 70 St MVAAA510B St Hot leg Injection 71 CMUMVAAA245 Dennineralized Water V. Valves Which Operate Automatically on an ESFAS Signal (The Safety Function for the valves in this section is the actuated position.)
- 1. Safety injection Actuation Signal (SIAS) 15 CC MVAAA807B CCW to Containment Fan Cooler Units 16 CC MVAAA823B CCW from Containment Fan Cooler Units 17 CC MVAAA823A CCW from Containment Fan Cooler Units 18 CC MVAAA807A CCW to Containment Fan Cooler Units 19 CC MUAAA822A CCW froen Containment Fan Cooler Units 20 CC MUAAA808A CCW to Containment Fan Cooler Units 21 CC MVAAA808B CCW to Containment Fan Cooler Units 22 CC MVAAA822B CCW from Containment Fan Cooler Units 26 CVCMVAAA103 CVCS Letdown 3/4 6-13 AMENDMENT NO. 02 l
_m m. _
.~
TABLE 3.6-2 CONTAINMENT ISOLATION VALVES PENETRATION VALVE NUMBER NUMBER FUNCTION V. Valves Which Operate Automatically on an ESFAS Signal (The Safety Function for the valves in this section is the actuated position.)(Continued)
- 4. Emergency Feedwater Actuation Signal (EFAS) 1 MS MVAAA401 A Steam to Emergency Steam Generator Feed Pump Turbine 2
MS MVAAA401B Steam to Emergency Steam Generator Feed Pump Turbine VL Valves whose Safety Function is 'OPEN' 1
MS MVAAAll6A Atmospheric Steam Dump 2
MS MVAAA116B Atmospheric Steam Dump 12 CVRMVAAA101 Vacuum Relief 13 CVRMVAAA201 Vacuum Relief 27 CVCMVAAA209 CVCS Charging Line 27 CVCMVAAA218B CVCS Charging Line 27 CVCMVAAA218A CVCS Charging Line 53 CVRMVAAA301A
'--'. _..c' aY CVR Essential Instrument Line CVRMVAAA302A CVR EssentialInstrument une 65 CVRMVAAA301B leetemment-HAVCVR Essential Instrument une CVRMVAAA302B CVR Essential Instrument Line 3/4 6-16 AMENDMENT NO. 02 l
ENTERGY MANAGEMENT MANUAL Site Directive No. W2.302 W~ OPERATIONS VOLUME IV Attachment i Rev. No. 2 Page 7 of 9 PART B - 10CFR50.59 SAFETY SCREENING Activity
Title:
LDCR 97-0047 - Location of Cabinets C-3A(B) and C-4 Outside the CVAS Boundary - Rev.1 i
Does the proposed change or activity represent:
YES X NO (1)
A change to the facility which alters, or has the potential to alter, the information, operation, function, or ability to perform the function of a system, structure, or component as described in the SAR7 Explain:
The proposed change will prescribe Local Leak Rate requirements to penetrations 53 & 65 to address these potential bypass leakage paths. The FSAR will be updated by placing these lines (passing through penetrations 53 & 65) for LRT or Type C testing as applicable.
Additionally, the FSAR will be clarified to designate the CVR sensing lines as a closed system for instrument lines outside containment.
YES NO X (2)
A change to a procedure which alters, or has the potential to alter, a procedure as described, outlined or summarized in the SAR7 Explain:
There are no procedural changes involved.
YES NO X (3)
A test or experiment not described in the SAR or which requires that a system be operated in an abnormal manner that is not described or previously analyzed in the SAR7 Explain:
This change is not a test or experiment and does not involve operation of a system in an abnormal manner.
YES X NO (4)
A potential to cause either an uncontrolled, unplanned, or unmonitored radioactive effluent release? Explain:
The postulated rupture of the sensing line outside of the CVAS boundary in the switchgear room during normal operation has the potential to cause an unmonitored release. However, the source term during normal operation is negligible.
4 ENTERGY MANAGEMENT MANUAL Site Directive No. W2.302
' OPERATIONS VOLUME IV Attachment I l
Rev. No. 2 Page 8 of 9 PART C - ENVIRONMENTAL IMPACT SCREENING Activity
Title:
LDCR 97-0047 - Location of Cabinets C-3A(B) and C-4 Outside the CVAS Boundary - Rev.1 Does the proposed change or activity represent:
YES NO X (1)
A change to the Environmental Protection Plan (EPP)? Provide the basis for the answer below:
There will be no changes to the environmental protection plan as a result this change.
YES NO X (2)
Measurable non-radiological effects not confined to onsite areas previously disturbed during site preparation and construction?
Provide the basis for the answer below:
There are no non-radiological effects associated with this change.
i i
ENTERGY MANAGEMENT MANUAL Site Directive No. W2.302 OPERATIONS VOLUME IV Attachment l l
Rev. No. 2 Page 9 of 9 PART D - RADIOACTIVE WASTE SYSTEMS SCREENING Activity
Title:
LDCR 97-0047 - Location of Cabinets C-3A(B) and C-4 Outside the CVAS Boundary - Rev.1 Does the proposed change or activity:
YES NO X (1)
Alter or affect a radioactive waste system (e.g., Gaseous, Liquid, Resin, or Solid Waste Management)? Provide the basis for the answer below:
This does not affect any radioactive waste systems.
YES NO X (2)
Significantly increase the amount of radioactive waste stored or l
processed? Provide the basis for the answer below:
l There are no hardware changes associated with this change and no radioactive waste is being generated.
l YES NO X (3)
Affect the potential for an unplanned or unmonitored release from a radioactive waste system? Provide the basis for the answer below:
There are no hardware changes associated with this change and no radioactive waste system is being affected.
l i
l 4
ENTERGY MANAGEMENT MANUAL Site Directive No. W2.302 C' OPERATIONS VOLUME IV Attachment ll Rev. No. 2 Page 1 of 6 10CFR50.59 SAFETY EVALUATION Activity
Title:
LDCR 97-0047 - Location of Cabinets C-3A(B) and C-4 Outside the CVAS Boundary - Rev.1 Safety Evaluation Questions YES NO X (1)
Does the proposed change or activity increase the probability of occurrence of an accident previously evaluated in the SAR7 A. List accidents in the SAR that may be caused or affected by the proposed change or activity or justify that there is no effect.
B. For each accident, discuss the effect of the proposed change or activity on the likelihood of the accident occurring.
Reg. Guide 1.11 provides guidance on design requirements for instrument lines penetrating primary reactor containment. It states that in the absence of an isolation valve inside containment, that there be a high degree of assurance that the piping from the containment up to and including the outside valve retain its integrity during normal reactor operation and under all Design Basis Accident conditions. At Waterford 3 this is accomplished by locating the valve as close to the containment as practical and by adopting a conservative approach in the design of this section of piping (Seismic Category 1, Safety Class 2) and supports.
ASME Code Class 2 and 3 stainless tubing for the sensing line has been designed and built to meet seismic category I criteria of LOU-1564-B-430 which defines support spans for weight, seismic, and thermal expansion and movements. The monitoring line tubing from containment up to the excess flow check valves are ASME Code Class 2, Seismic Category 1. The remaining of the monitoring lines are non-seismic, non-safety tubing.
The position of the containment isolation valves for the monitoring lines, CVR-401 A(B),
was changed to normally closed per OP-002-010.
The sensing line tubing is rated for a design pressure in excess of 4,500 psig at 300 'F in l
accordance with the manufacturers data. The system design for this section of tubing is 44 psig at 300 *F. Therefore, the tubing design conditions are approximately 1% of its rated capacity. Even though the expected MSLB temperature inside the containment peaks above 300 'F, it should be noted that the containment will be above 300 *F for a very short period of time, and the instrument tubing is not expected to reach this temperature due to delayed heat transfer.
The tubing support / span criteria used at Waterford 3, limits bending stresses in the tubing to less than 50% of the allowable. This fact, combined with the extremely low internal pressure stress gives a combined stress well below the break exclusion criteria.
ENTERGY MANAGEMENT MANUAL Site Directive No. W2.302 C-S' OPERATIONS VOLUME IV 1 Rev. No. 2 Page 2 of 6 All safety related instrument tubing at Waterford 3 was purchased to ASME Class 2 requirements. Cabinets C-3A(B) are seismic Category I and safety related. The instruments are Safety Class 1E and have a static pressure rating of 1000 psig. The sensing lines and valves downstream of CVR-302A(B) are designed to ASME Class 3 and meet the requirements for a closed system for instrument lines outside containment based on the following:
- 1) Per ANSI /ANS-56.2/N271-1976, the CVR sensing lines are fabricated to withstand the maximum containment test pressure of the structural integrity test, the maximum containment temperature, and are protected from missiles and dynamic effects.
- 2) ISA 67.02-1980 requires the sensing lines downstream of the isolation valves meet ANSI B31.1 Seismic Category I design requirements.
g*
- 3) Draft Reg. Guide - Instrument Sensing Lines endors#lSA 67.02-1980 excepnhe sensing line downstream of the containment isolation valves must meet ASME Class 3 design requirements.
The Waterford 3 design meets Reg. Guide 1.11 requirements up to the downstream isolation valves and meets the requirements of A.NSI/ANS-56.2/N271-1976, ISA 67.02-1980 and the Draft Reg. Guide - Instrument Sensing Lines as a closed system for instrument lines outside containment. The proposed change incorporates required testing criteria to ensure acceptable leakage rates associated with potential bypass leakage paths. The proposed change does not increase the probability of occurrence of an accident evaluated in the SAR.
YES NO X (2)
Does the proposed change or activity increase the consequences of an accident previously evaluated in the SAR?
A.
List the accidents in the SAR that may have radiological release consequences altered by the proposed change or activity, or justify that no accidents are affected.
B. For each accident, discuss the effect of the proposed change or activity on the radiological release consequences. Include the effect of the proposed change or activity on mitigating system performance and analysis assumptions credited in the accident analysis.
C. If applicable, provide the results of a new analysis that accounts for the proposed change or activity.
i 1
- lSFENTERGY MANAGEMENT MANUAL Site Directive No. W2.302 OPERATIONS VOLUME IV 1 i
Rev. No. 2 Page 3 of 6 The Containment Vacuum Relief (CVR) system protects the containment vessel by maintaining the pressure differential across the vessel lower than the design value. The CVR system acts to equalize pressure across the containment during an inadvertent spray which lowers containment pressure. The CVR penetrations 53 and 65 each contain two instrument lines. One senses differential pressure across the containment vessel and provides a signal to actuate the CVR system and the other monitors the differential pressure and provides an input to the plant computer and containment purge.
The monitoring line contains an excess flow check valve and a solenoid operated globe valve that will close automatically on a CIAS. The sensing line contains a manually operated valve and an excess flow check valve, both located outside containment. Due to its primary safety function, the sensing instrument lines of the CVR system are designated as " essential" thus, not requiring automatic containment isolation.
The CVR system penetrations are GDC 56 penetrations. They connect directly to the containment atmosphere. Waterford 3 has applied the recommendations of RG 1.11 to demonstrate that the design of penetrations 53 & 65 (as described above) is acceptable on "some other defined bases" The licensing basis indicatas that the leakage testing of the instrument I:nes for penetrations 53 & 65 is not required because these lines form a closed system outside containment, are seismically qualified, and terminate in an area filtered or exhausted by the CVAS. However, contrary to the above, a small portion (less than 10%) of these lines do not terminate within the CVAS boundary.
Also, although seismically supported, the monitoring line downstream of the isolation valve is not classified as seismic category I.
This proposed change will correct the FSAR to include the instrumentation passing through penetration 53 & 65 in Type C or LRT testing as appropriate and clarify the CVR sensing lines as a closed system for instrument lines outside containment in accordance with ANSI /ANS-56.2/N271-1976 and ISA-67.02-1980.
The sensing lines form a seismically qualified, closed system outside containment. The instrument tubing is safety class 2 up to and including CVR-302A(B), and the tubing and valves downstream of the containment isolation valve up to the instruments is safety class 3. The instruments are safety related class 1E. The lines are capable of withstanding containment design pressure and temperature, and protected against a high energy line break outside containment. Therefore, the CVR sensing lines meet the requirements of ANSI /ANS-56.2/N271-1976 and ISA-67.02-1980 as a closed system for instrument lines outside containment.
j ENTERGY MANAGEMENT MANUAL Site Directive No. W2.302 -
" OPERATIONS VOLUME IV Attachment ll Rev. No. 2 Page 4 of fi l
As previously stated, for the containment isolation function, one isolation barrier is l
required after the occurrence of a single active failure. The single failure analysis for these instrument lines is consistent with ANSI N658-1976, Single Failure Criteria for PWR Fluid Systems (this ANSI Standard is also used as indicated in FSAR 6.3.3.8, l'ost LOCA Maintenance Considerations). Pursuant to ANSI N658 the single failure during the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the event is limited to an active failure. During the long-term, the single failure may be active or passive. However, pursuant to paragraph 3.6 passive failures in the sensing instrument lines are limited to leakage, such as from valve stems, rather than a complete severance of the line. In light of the above the proposed change incorporates the sensing line into the administrative program described in FSAR Section 1.9.37 to reduce leakage from systems outside containment that could contain highly radioactive fluids during a serious transient or accident.
The dose contribution due to a rupture in the monitoring line and a single failure to close of the isolation valve in the line does not have to be considered since OP-002-010 changed CVR-401 A(B)'s normal position to closed.
Due to the above, this penetration will be added to TRM Table 3.6-1, Containment Leakage Paths, for Type C leak testing pursuant to 10CFR50 Appendix J, and the excess flow check valves will be added to TRM Table 3.6-P. Containment isolation Valves. The proposed changes described above will ensure that leakage within the acceptance limits, will not have an unacceptable impact on offsite dose and control room dose limits.
Therefore, the proposed change will not increase the consequences of an accident previously evaluated in the SAR.
YES NO X (3)
Does the proposed change or activity increase the probability of occurrence of a malfunction of equipment important to safety previously evaluated in the SAR7 A. Identify the equipment important to safety that could be affected by the proposed change or activity, or justify why no equipment important to safety is affected.
B. Discuss the effect of the proposed change or activity may have on equipment important to safety. Include a determination of whether the likelihood of malfunction will increase.
B,__ENTERGY MANAGEMENT MANUAL Site Directive No. W2.302
. OPERATIONS VOLUME IV Attachment ll Rev. No. 2 Page 5 of 6 l
There are no design changes, and the function or operation of any equipment important to safety will not be effected as a result of this change. Therefore, the probability of occurrence of a malfunction remains unchangad.
YES NO X -(4)
Does the proposed change or activity increase the consequences of a malfunction of equipment important to safety previously evaluated in the SAR7 A. List the accidents for which the equipment important to safety in 3A above is required to perform a safety function.
B. For each accident, discuss how the consequences may be different if the equipment in 3A above were to malfunction.
The function of the instrument lines in containment penetrations 53 & 65 or any of its components is not affected by this change. The integrity of the instrument tubing remains in compliance with Reg. Guide 1.11 and the CVR sensing lines meet the requirements of ANSI /ANS-56.2/N271-1976 and ISA 67.02-1980 as a closed system for instrument lines outside containment. Therefore, the consequences of a malfunction of equipment important to safety remains within acceptable limits as described in question 2 of the safety evaluation.
YES NO X (5)
Does the proposed change or activity create the possibility of an accident of a different type than previously evaluated in the SAR?
A. Discuss new system interactions or connections that previously did not exist.
B. Discuss how these new system interactions or connections could or could not create a new accident.
There are no design / hardware changes, no new system interaction or connections being created that could create a new accident. Therefore, no new accidents will occur as a result of this change.
YES NO X (6)
Does the proposed change or activity create the possibility of a malfunction of equipment important to safety of a different type than any previously evaluated in the SAR7 A. Identify new methods of failure that the proposed change or activity could create.
No new modes of failure or accident initiators is introduced as a result of this change.
Therefore, the proposed change will not create the possibility of a malfunction of equipment important to safety other than those evaluated in the SAR.
4 ENTERGY MANAGEMENT MANUAL Site Directive No. W2.302
" OPERATIONS VOLUME IV Attachment ll Rev. No. 2 Page 6 of 6 YES NO X (7)
Does the proposed change or activity reduce the margin of safety as defined in the basis for any technical specification or the appropriate safety analysis?
A. If the change is to a protective boundary, discuss how the boundary is affected.
B. Identify the margins of safety (related to boundary performance) that may be affected by the proposed change or activity.
C. Discuss how the accident response, as affected by the proposed change or activity, relates to the appropriate acceptance limits.
D. If applicable, provide the results of an analysis that accounts for the proposed change or activity and shows the impact on margin of safety.
The proposed change corrects the FSAR by incorporating appropriate leak testing requirements for identified potential bypass leakage paths associated with penetrations 53 & 65. The margin of safety related to the containment boundary and offsite dose limits is potentially affected, however CVR-401A(B) will remain normally closed per OP-002-010, This will ensure the radiological releases remain within the acceptance limits for offsite and control room dose. This evaluation for the sensing lines shows that the containment barrier's margin of safety is not reduced since Penetrations 53 and 65 meet Reg. Guide 1.11 and the sensing lines meet the requirements of ANSI /ANS-56.2/N271-1976 and ISA 67.02-1980 as a closed system for instrument lines outside containment.
The proposed change will provide for appropriate leak testing which ensures specified leakage limits are maintained to preserve the margin of safety.
i i
4
o, Inside cf Contamment CVR301A l
(Manual Valve To DP Transmitters with remote Which Signal Vacuum Essential Line indication)
Relief Valve Class 3 Tubing
]
[
Downstream of i
CVR-302A U
\\
p y m* N eq CVR-302A CVR-402A e
)
- )
{
L NNS Tubing I
Downstream of
^
CVR 401 A (Solenoid Valve with remote indication)
No--*i=I
= To DP Transmitters Which Provide O
Computer Indications Annulus CVR 401B (Solenoid Valve
~~
with remote indication)
NNS Tubing Downstream of h
CVR-402B D
- >W CVR-402B
?
CVR 302B y
)(
l *b h
A Class 3 Tubeg Downstream of I-CVR 3018 CVR-3028 (Manual Valve l
with remote L lMh...]
indication) w.
?
To DP Transmitters Which Signal Vacuum Relief Valve ES - Limit Switch h - Solenoid Valve Sketch IST-96 E-
) -Excess Flow Containment Vacuum Relief Sensing Lines l
Waterford 3 S E.S.
1 I