ML20195E662

From kanterella
Jump to navigation Jump to search
Forwards Responses to 980901,0902 & 0904 RAIs for Review of Ccnpp,Units 1 & 2 Integrated Plant Assessment Repts for HVAC Sys
ML20195E662
Person / Time
Site: Calvert Cliffs  Constellation icon.png
Issue date: 11/16/1998
From: Cruse C
BALTIMORE GAS & ELECTRIC CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9811190060
Download: ML20195E662 (23)
v • d • e


Text

{{#Wiki_filter:. CHARLES H. CRUSE Baltimore Gas and Electric Company Vice President Calvert Cliffs Nuclear Power Plant Nuclear Energy 1650 Calvert Cliffs Parkway Lusby, Maryland 20657 410 495-4455 l November 16,1998 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Document Control Desk

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Response to Request for Additional Information for the Review of the Calvert Cliffs Nuclear Power Plant, Units 1 & 2, Integrated Plant Assessment Reports for Heating. Ventilation. and. Air Conditioning Systems Reference (a) forwarded the Baltimore Gas and Electric Company (BGE) License Renewal Application (LRA) for the Calvert Cliffs Nuclear Power Plant. References (b), (c) (in part), and (d) forwarded questions from NRC staff on those BGE LRA sections that addressed heating, ventilation, and air conditioning systems. Reference (e) forwarded a numbering system for tracking BGE's response to all of the BGE License Renewal Application requests for additional information and the resolution of the responses. Attachment (1) provides our responses to the heating, ventilation, and air conditioning questions contained in References (b), (c) and (d). The questions are renumbered in accordance with Reference (e). ) 9811190060'4811'1A f PDR ADOCK 05000317 P PDR; NRC Distribution Code A036D

i..

Document Control Desk November 16,1998 Page 2. Should you have further questions regarding this matter, we will be pleased to discuss them with you. Very truly yours, STATE OF MARYLAND

TO WIT:

COUNTY OF CALVERT 1, Charles H. Cruse, being duly sworn, state that I am Vice President, Nuclear Energy Division, Baltimore Gas and Electric Company (BGE), and that I am duly authorized to execute and file this response on behalf of BGE. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other BGE employees and/or consultants. Such information has been reviewed in accordance with company practice and I believe it to be reliable. Jt / W Aw / Supscribed and sworn before me, a Notary Public in and for the State cf Maryland and County of ( dlLAd > ,this //dLday of 71rtdanh(A/.1998. WITNESS my Hand and Notarial Seal: lA4M1 b U1 Notary Public My Commission Expires: S I!3d 1 Date CHC/KRE/ dim

Attachment:

(1) Response to Request for Additional Information; Integrated Plant Assessment Report for Heating, Ventilation, and Air Conditioning Systems cc: R. S. Fleishman, Esquire C. I. Grimes, NRC [ J. E. Silberg, Esquire D. L. Solorio, NRC l S. S. Bajwa, NRC Resident Inspector, NRC l A. W. Dromerick, NRC R. I. McLean, DNR l H. J. Miller, NRC J. H. Walter, PSC

Document Control Desk November 16,1998 Page 3 '

REFERENCES:

(a) - Letter from Mr. C. H. Cruse (BGE) to NRC Document Control Desk, dated April 8,1998," Application for License Renewal" (b) Letter from Mr. D. L. Solorio (NRC) to Mr. C. H. Cruse (BGE), September 1,1998," Request for Additional Information for the Review 1 of the Calvert Cliffs Nuclear Power Plant, Unit Nos.1 & 2, Integrated Plant Assessment Report for the Auxiliary Building Heating and Ventilation System, and the Control Room and Diesel Generator Buildings' Heating, Ventilation, and Air Conditioning System" (c) Letter from Mr. D. L. Solorio (NRC) to Mr. C. H. Cruse (BGE), September 2,1998," Request for Additional Information for the Review of the Calvert Cliffs Nuclear Power Plant, Unit Nos.1 & 2, Integrated Plant Assessment Reports for the Containment Isolation Group, Containment Spray System, and Primary Containment Heating and Ventilation System" (d)' Letter from Mr. D. L. Solorio (NRC) to Mr. C. H. Cruse (BGE), September 4,1998, " Request for Additional Information for the Review of the Calvert Cliffs Nuclear Power Plant, Unit Nos.1 & 2, Integrated Plant Assessment for Heating and Ventilation Systems" (e) Letter from Mr. D. L. Solorio (NRC) to Mr. C. H. Cruse (BGE), September 24,1998, " Renumbering of NRC Requests for Additional l Information on Calvert Cliffs Nuclear Power Plant License Renewal Application Submitted by the Baltimore Gas and Electric Company" l f

ATTACHMENT (1) l RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT REPORT FOR HEATING, VENTILATION, AND 1 AIR CONDITIONING SYSTEMS l l l l Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant November 16,1998 i

e ATTACHMENT (1) RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT REPORTS FOR HEATING, VENTILATION, AND AIR CONDITIONING SYSTEMS NRC Ouestion No. 5.11.1 While Section 5.11C.l.l [of the Baltimore Gas and Electric Company (BGE) License Renewal Application (LRA)J in System Level Scoping provides a summary description of the system boundaries and components within the scope oflicense renewal for both the Control Room Heating, Ventilation, and Air Conditioning (HVAC) System and the Diesel Generator Buildings' HVAC System. drawings showing the system scoping boundaries were not included. The corresponding drawings for these systems in Updated Final Safety Analysis Report (UFSAR) for Calvert Cliffs Nuclear Power Piant (CCNPP) do not have sufficient details for the staff to clearly understand the system renewal scopes. Please provide half or full-size (18"x24") UFSAR Control Room HVAC System and Diesel Generator Building HVAC System figures (such as Control Room HVAC System Figure 9-20B, Revision 21; the Diesel Generator Building HVAC System has no UFSAR figure) or equivalent that would encompass the system scoping boundaries so that the NRC staff can revir"'he system level scoping boundaries and system components. As an alternative to providing drawings that show the system scoping boundaries, markups of existing UFSAR drawings or piping and instrument diagrams would also provide sufficient detail to assist the staffin reviewing the system scoping boundaries. BGE Respenst Please refer to the attached Figures 5.11C-1, -2, and -3 (Appendix A) for a depiction of the scoping boundaries for the Control Room HVAC System and the Diesel Generator Buildings' HVAC Systems. Bolded lines indicate portions of the system within the scope oflicense renewal. Note that components within the bolded lines (i.e., dampers, fans, heating elements, filters, etc.) are also within the scope of license renewal. Please refer to Section 5.11C.1.2 of the BGE LRA for the specific device types in the Control Room HVAC System that were designated as within the scope oflicense renewal. Refer to Section 5.11C.1.4 of the BGE LRA for a discussion of the Diesel Generator Buildings' HVAC System scoping. NRC Ouestion No. 5.11.2 While Section 5.ll A.l.1, " System Level Scoping," provides a summary description of the system boundaries and components within the scope oflicense renewal for the Auxiliary Building Heating and Ventilation (H&V) System, drawings showing the system scoping boundaries were not included. The corresponding drawing for this system in the CCNPP UFSAR does not have sufficient details for the staff to clearly understand the system renewal scope. Please provide a half or full-size (18"x24") UFSAR Auxiliary Building H&V System figure (such as the Auxiliary Building H&V System Figure 9-21, Revision 21) or equivalent that would encompass the system scoping boundaries so that the NRC staff can review the system level scoping boundaries and system components. As an alternative to providing drawings that show the system scoping boundaries, markups of the existing UFSAR drawing or the applicable piping and instrument diagrams would also provide sufficient detail to assist the staffin reviewing the system scoping boundaries. BGE Responic Please refer to Figure 5.11 A-1 in Appendix (A) for a depiction of the Auxiliary Building H&V System scoping boundaries. Bolded lines indicate portions of the system within the scope oflicense renewal. Note that components within the bolded lines (i.e., dampers, fans, heating elements, filters, etc.) are also within the scope oflicense renewal. Please refer to Section 5.11 A.I.2 of the BGE LRA .1

. g n a -a ATTACHMENT (1) RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT REPORTS FOR HEATING, VENTILATION, AND AIR CONDITIONING SYSTEMS for the specific device types in the Auxiliary Building H&V System that were designated as within the scope oflicense renewal. NRC Ouestion No. 5.11.3 Section 5.118.1.2 of the LRA states that the portion of the Containment Air Recirculation and Cooling System within the scope includes: cooling units, fans, and connecting ductwork up to and including fusible dropout plates. Section 6.5.5, " Containment Air Recirculation and Cooling System," of the CCNPP UFSAR states that each fan discharge duct is provided with a fusible door link that opens at an abnormally high containment temperature such as would occur under a loss-of-coolant-accident. While Section 6.5.6 of the CCNPP UFSAR also states the containment air cooler blowdown door fusible links are to be replaced every refueling outage to ensure that the links perform their design function and as a result would not be subject to an aging management review (AMR), clarify on what basis were the fusible links excluded from the scope oflicense renewal. BGE Response Baltimore Gas and Electric Company considers the fusible links of Section 6.5.5 of the CCNPP UFSAR as active subcomponents of the device type DUCT, which are within the scope of license renewal. The fusible links are considered active because they change state (e.g., melt) in order to perform their intended function and, therefore, are not subject to AMR. NRC Ouestion No. 5.11.4 Section 6.5.6, " Containment Air Recirculation and Cooling System," of the UFSAR concludes that water-logging of the cooling units' coils is not a problem because the coil section drainage characteristics were validated by the manufacturer's sizing and test program. For this conclusion to remain valid, the staff believes that to drain condensate would have to be an intended function of the system. If it is an intended function of the system, clarify whether the piping described in Section 6.5.4 of the UFSAR which transfers the condensate leaving the coils to the containment sump and ultimately to the waste processing system is within the scope oflicense renewal and subject to an AMR7 If not, justify why this function is excluded. BGE Response As stated in Section 6.5.4 of the UFSAR, "The condensate leaving the coils is conveyed over individual stainless steel drip pans to the sides of the coils out of the mixture flow stream. These pans cascade the liquid into the main sump of the housing from which it is drained via the Containment sump to one of the Auxiliary Building sumps, from which it is pumped to the Waste Processing System." In the event the drainage lines do not perform their function, the condensate would drain l from the main sump of the cooling coil housing directly into Containment. The cooling coil units would still be able to perform their intended function. Therefore, the non-safety-related drainage lines do not perform any of the system intended functions as defined in 10 CFR 54.4(a)(1), (2), (3) and are not within the scope oflicense renewal. NRC Ouestion No. 5.11.5 Clarify whether the instrument lines are included in the scope of license renewal.10 CFR 54.21(a)(1)(i) excludes instrumentation from the scope of renewal, in part because the instruments are routinely subjected to surveillance testing. The sample lines to such instruments as pressure transmitters, pressure indicators, water level indicator, and containment atmosphere draw samples (like those described in 2

V i 1 ATTACIIMENT (1) RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT REPORTS FORIIEATING, VENTILATION, AND AIR CONDITIONING SYSTEMS Section 6.8 of the UFSAR, " Hydrogen Control Systems," are not always tested to the same extent as the associated instruments. If the instrument lines have been excluded from the scope of license renewal, provide thejustification for that exclusion with consideration of the foregoing concern. BGE Response Section 6.4, of the BGE LRA," Instrument Lines Commodity Evaluation," contains BGE's evaluation ofinstrument lines that are within the scope oflicense renewal. NRC Ouestion No. 5.116 Section 6.8.2," Electric Hydrogen Recombiner," of the CCNPP UFSAR states that the service life of the recombiners is 40 years. Describe how this component was addressed for license renewal. BEEResponse The hydrogen recombiners were determined to be within the scope of License Renewal during the component level scoping process. They are environmentally qualified. They have no passive intended functions, therefore they are not subject to AMR. The recombiners are included in the environmentally qualified time-limited aging analysis, described in Section 2.1.3.1 of the LRA. NRC Ouestion No. 5.11.7 Section 5.11B.1.3 of the LRA states that the hydrogen recombiner only functions actively. This appears to be inconsistent with Section 6.8.2.3 of the CCNPP UFSAR which states that the recombiner is a completely passive device. Because the recombiner housing acts as a passive hoidup volume to allow the containment atmosphere to be heated to a temperature above 1150 F, please provide the basis for considering the hydrogen recombiner to only have active functions and therefore not subject to an AMR. BGE Response The use of the term " completely passive device" in the CCNPP UFSAR refers to the fact that there are no moving parts. In accordance with Section 5.1, " Categorize Intended System Functions as Active or Passive," of tre Integrated Plant Assessment Methodology in Section 2.0 of the BGE LRA, an active function may only re.luire a change in structure / component properties or configuration to carry out the intended fueti;n. The recombiner has an electric heater section that consists of a thermally-insulated vertical metal duct with electric resistance metal-sheathed heaters to heat the air to the recombination temperature. These electric resistant heaters are required to change state in order for the heating to take place, thus making the intended function for this component active. The electric heater section is open to the containment atmosphere and draws the air through the recombiner by natural convection. There is no holdup of the air. Therefore, there is no pressure boundary function associated with the recombiners. NRC Ouestion No. 5.11.8 Are there any parts of the systems, structures, or components described in Section 5.5, " Containment Isolation Group," that are inaccessible for inspection? If so, describe what aging management program will be relied upon to maintain the integrity of the inaccessible areas. If the aging management program for the inaccessible areas is an evaluation of the acceptability of inaccessible areas based on conditions found in surrounding accessible areas, please provide information to show that conditions would exist in accessible areas that would indicate the presence of or result in degradation to such inaccessible areas. If different aging effects or aging management techniques are needed for the inaccessible areas, please 3

4 ATTACHMENT (1) RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT REPORTS FOR HEATING, VENTILATION, AND AIR CONDITIONING SYSTEMS provide a summary to address the following elements for the inaccessible areas: (1) Preventive actions that will mitigate or prevent aging degradation; (2) Parameters monitored or inspected relative to degradation of specific structure and component intended functions; (3) Detection of aging effects before loss of structure and component intended functions; (4) Monitoring, trending, inspection, testing frequency, and sample size to ensure timely detection of aging effects and corrective actions; (5) Acceptance criteria to ensure structure and component intended functions; and (6) Operating experience that provides objective evidence to demonstrate that the effects of aging will be adequately managed. BGE Respons.e Baltimore Gas and Electric Company can access all Containment H&V System components if required. NRC Ouestion No. 5.11.9 Sections 5.ll A.1,5.11B.1 and 5.11C.1 of the application state that representative historical operating experien,:e pertinent to aging is included in appropriate areas, to provide insight supporting the aging management demonstration. From the past operating experience, provide specific examples of how the corrective actions (including types, methods, criteria, etc.) related to the aging degradation of H&V systems were taken in the Auxiliary Building, Primary Containment, and Control Room and Diesel Generator Buildings. BGE Response For the representative historical operating experience pertinent to aging that has been included in the subject reports, specific examples of the corrective actions taken are provided in the BGE LRA along with the operating experience discussions. For example, on BGE LRA page 5.11 A-4, following the statement that some cracking has been discovered in HVAC ducting, the BGE LRA continues that in one case, additional supports were added to prevent recurrence. In another case, the fans were balanced to minimize the vibration. Further discussion indicates that vibration-related aging concerns are minimized through system design and existing maintenance practices, such as by using vibration isolators and monitoring fan vibration following belt maintenance. Detailed information concerning specific operating experience is readily available onsite for review. NRC Ouestion No. 5.11.10 As described in Sections 5.ll A and 5. llc of the application, for the H&V systems located in the Auxiliary Building, and Control Room and Diesel Generator Buildings, some cracking has been discovered in plant HVAC ducting due to vibration-induced fatigue. The application also states that these isolated failures were due to a combination of design and installation deficiencies. Please address the following: Clarify the basis for the conclusion that these isolated failures did not involve any age-related a. degradation mechanisms (ARDMs).

b. With regard to the corrective actions, provide details of how these cracks were corrected and how these failures affected the intended function.

BGE Response a. The cracking in HVAC ducting was the result of high cycle fatigue caused by vibrations in the vicimty of the local failures due to a combination of design and installation deficiencies. One i 4

~ ATTACHMENT (1) RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT REPORTS FOR HEATING, VENTILATION, AND AIR CONDITIONING SYSTEMS failure was the result ofinsufficient HVAC ducting support in the Auxiliary Building, causing the loosening of self-tapping screws on a cantilever and ultimately the cracking of the ducting. The installation of an additional support successfully prevented recurrence. Another failure resulting in cracking of the cavity cooling ducting supports was apparently caused by installation of fixed welded hangers vice hangers designed to allow axial movement. Subsequently, the cost effective resolution involved balancing of the cooling fans to minimize vibration instead of replacing the fixed hangers. No additional high cycle fatigue related ducting failures have occurred at these, or any other, HVAC ducting locations. High cycle fatigue is considered a potential aging mechanism for the HVAC components. It is not considered to be plausible because the HVAC systems are designed to minimize vibration by incorporating equipment support isolators and equipment-to-duct isolators (such as cloth / rubber boots). ) l b. Both failures described in "a." above were in non-safety-related portions cf the HVAC systems. The addition of a duct support and the balancing of the fans was done in conjunction with patching the ducting. Sheet metal was applied over the cracked areas with a gasket and sealant and then fastened with sheet metal screws. One joint location was additionally strengthened by adding angle iron bolted into place. Neither failure caused the system engineer to consider the systems inoperable. The Auxiliary Building failure occurred at the discharge of the waste processing exhaust fans prior to where the duct connects with the main exhaust plenum. The combination of high discharge pressure due to the waste processing exhaust fans and high suction pressure inside the main exhaust plenum due to the main exhaust fans resulted in adequate air flow at all times. The cavity cooling duct failure was less than one foot long and no increase in cavity temperatures was observed. Therefore, the systems continued to meet their functional requirements. NRC Ouestion No. 5.11.11 As described in the operating experience for Sections 5.ll A, 5.llB, and 5. llc of the application, loosening of fasteners due to dynamic loading was identified as an ARDM. Provide a justification of why this ARDM is identified as plausible only for fans in the ARDMs tables (Tables 5.ll A-2,5.11B 2 and 5.11C-2) and not fasteners or other device types exposed to dynamic loads. BGE Response Fasteners associated with the device type ' fan' are considered subcomponents of the fans and are not identified as a separate " device type"in Tables 5.11 A-2,5.11B-2, and 5.11C-2 of the BGE LRA. The reason for dynamic loading being plausible only for the fans is contained in the " Aging Mechanism Effects" sections in the Group 3 discussions in each of the Sections 5.11 A.2,5.11B.2, and 5.11C.2 of the BGE LRA. As stated,"this mechanism is plausible for the fans but is not considered plausible for adjacent HVAC equipment due to the dynamic isolation provided by flexible collars." In the " Methods to Manage Aging" sections in the Group 3 discussions in each report, BGE further states that " dynamic loading can be mitigated by minimizing the mechanical loading due to vibration. The system is designed to minimize vibration by using equipment support isolators and equipmera-to-duct isolators such as cloth boots." l NRC Ouestion No. 5.11.12 Sections 5.II A.2,5.11B.2 and 5. llc.2 of the application describe ARDM and device type combinations for aging management. Provide a justification as to why mechanical wear of the duct systems is not considered as a plausible ARDM. 5

ATTACHMENT (1) RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT REPORTS FORIIEATING, VENTILATION, AND AIR CONDITIONING SYSTEMS BGE Response In Tables 3.ll A-2,5.11B-2, and 5. llc-2 wear is identified as a plausible ARDM for the device type duct. Age-related degradation mechanism / device type combinations are grouped together in the BGE LRA where there are similar characteristics, and the discussion is applicable to all components within that group. Demonstration of aging management for the effects of wear of non-metallic ducting components is discussed in the appropriate groups in BGE LRA Sections 5.llA.2, 5.11B.2, and 5.11C.2. Baltimore Gas and Electric Company has concluded that wear is not a plausible ARDM for the metallic ducting components due to design considerations that eliminate relative motion between adjacent parts. j NRC Ouestion No. 5.11.13 As described in the application (Sections 5.11 A.I.3,5.11B.I.3 and 5.11C.I.3), some of the device types (such as damper, filters, hand valve, and pressure differential indicator in the Auxiliary Building; damper, filter and solenoid valve in the Primary Containment; analyzer element, gravity damper, hand valve and temperature transmitter in the Control Room and Diesel Generator Buildings) are subject to a detailed evaluation of ARDMs as part of the AMR. However, there are no entries of potential and plausible ARDMs under these device types in Tables 5.11 A-2,5.11B-2 and 5.1IC-2 of the application. Provide a summary description of the ARDMs considered for these device types and the basis for the plausible ARDM conclusion. BGE Response Tables such as 5.llA-2, 5.11B-2, and 5. llc-2 list potential ARDMs for all device types that are subject to AMR. A check mark is then used to indicate whether a listed potential ARDM was determined to be plausible for the each device type. For the device types mentioned in this question, no ARDMs were determined to be plausible. Therefore, no check marks appear in the tables in the columns for those device types. The details of each particular non-plausibility determination were not generally included in the BGE LRA, but are available on site. NRC Ouestion No. 5.11.14 In describing the aging management programs for components such as ducting and heat exchangers, the application (Discoverv in Pages 5.11 A-13,5.11B-15 and 5.11C-11) states that crevice corrosion, general corrosion, and pitting can be readily detected through visual examination. Clarify how these aging effects will be managed for locations such as lap joints that cannot be readily inspected visually. BGE Resnonse One of the objectives of the visual examinations, credited to manage the effects of crevice corrosion, l general corrosion, and pitting, is to detect symptoms of degradation. Lap joints used in the l fabrication of HVAC ducting systems and component housings (i.e., fan housings, filter housing, heat exchanger housings, etc.) will initially exhibit specific symptoms indicative of age-related degradation that do not result in loss of pressure boundary integrity. These symptoms will include discoloration, buildup of corrosion products, or damage to surface protective coatings. The symptoms will be readily detectable during visual inspections such that the degradation will be repaired before the pressure boundary integrity function isjeopardized. t l ? l 6

_ _ ~ 1 1 ATTACIIMENT (1) RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT REPORTS FORllEATING, VENTILATION, AND AIR CONDITIONING SYSTEMS NRC Ouestion No. 5.11.15 Tables 5.11 A-1,5.11B-1 and 5.11C-1 of the application list all the H&V system device types for which the AMR is required. Also, Sections 5.11 A.I.3,5.11B.I.3 and 5.11C.I.3 of the application include a statement that only the pressure-retaining function (the passive intended function) for these device types is considered in the AMR for the if&V systems in the Auxiliary Building, Primary Containment, and Control Room and Diesel Generator Buildings. liowever, no description of how to maintain this passive intended function is included in the application. Clarify how the aging management programs described in the application maintain the pressure-retaining function of these device types. BGE Resonna Sections 5.11 A.2,5.11B.2 and 5.1IC.2 of the BGE LRA provide the demonstration that the effects of aging will be adequately managed so that the intended function (s) will be maintained consistent with the current licensing basis for the period of extended operation. Each of the aging mechanisms considered plausible for the device types for which an AMR is required are grouped together where there are similar characteristics, and the discussion is applicable to all components within that group, Each of the Group discussions include a summary of the materials and environment, aging mechanism effects, methods to manage aging, and aging management programs. Included are plant programs BGE credits for the mitigation and discovery of the aging effects. Upon discovery of any aging effects, corrective actions are implemented in accordance with the CCNPP Corrective Actions Program. It is this entire discussion that comprises the demonstration of how the aging management programs described in the application will maintain the pressure-retaining function of these device types. NRC Ouestion No. 5.11.16 Pages 5.11 A-7 and 5.11C-6 of the application indicate that certain device types "do not require a detailed evaluation of specific aging mechanisms because they are considered part of a complex assembly whose only passive function is closely linked to active performance." The listed device types include accumulators, piping, and valves. Clarify how the passive functions of these devices are adequately managed by such performance monitoring. In particular, describe the nature of the monitoring and demonstrate that the degradation of the particular component intended function is " closely linked" to the parameters being monitoring in a performance monitoring program, such that the component intended function would be maintained for the period of extended operation. BGE Response The Integrated Plant Assessment Methodology, Section 2.0 of the BGE LRA, describes in Section 6.1.1 the reasoning behind reliance on performance and condition monitoring as an l acceptable aging management technique for certain complex assembles. The following conditions l must be met for this technique to be relied on: A complex assembly of components where the pressure-retaining function directly supports active performance of the assembly; The passive function is the pressure-retaining function and is not a fission product boundary l function; The active intended functions are performed by redundant trains; Performance testing is well documented with verification that corrective actions assure the continued performance of all intended active functions; and 7

e - ATTACHMENT (1) RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT REPORTS FOR HEATING, VENTILATION, AND AIR CONDITIONING SYSTEMS I The complex assembly is covered by the Maintenance Rule l The Auxiliary Building H&V System utilizes redundant refrigeration loops to provide cooling to the Emergency Switchgear Rooms. The Control Room liVAC System also utilizes redundant refrigeration loops to provide cooling to the Control Room and other serviced areas. It is these refrigeration loops that are considered complex assemblies where the aging management technique is performance and condition monitoring. The pressure-retaining boundary includes the compressor, receiver, condenser, and associated piping, valves, instrumentation and ancillary devices. Loss of refrigerant pressure boundary would be readily detected because the system would lose its cooling capability. If there is an indication that the system is not able to provide adequate cooling, corrective actions are initiated in accordance with the CCNPP Corrective Actions Program to ensure the systems' intended functions are not lost. Performance, condition monitoring, and surveillance programs manage aging effects with activities governed by the Maintenance Rule, CCNPP Technical Specifications, and Maintenance Program l Condition Monitoring. Under the Maintenance Rule, both systems are included in a performance l monitoring program that is continuously reviewed against reliability and availability expectations. l The performance data is monitored as follows: Obtain all valid run data from each period of refrigeration unit operation; Review all operating logs for all entries pertaining to refrigeration unit operation and e availability; Review surveillance test procedure records affecting the operation and testing of the e refrigeration units, and; Review and plot system data reflecting component reliability. l l l Degradation of the passive function to maintain the refrigerant pressure boundary and cooling would l become evident through negative performance trends. Both systems have clearly defined operability requirements that must be met during various modes of operation. The Control Room liVAC System has a Technical Specification (TS) Limiting Conditions for Operation requiring two refrigeration units be operable while in Modes 1,2,3, and 4. A bi-I monthly test is performed to verify operability by deenergizing the backup refrigeration unit and verifying the emergency units maintain the air temperature less than or equal to 104*F for at least 12 hours when in the recirculation mode. The Auxiliary Building H&V System is governed by an operating instruction which specifies corrective actions, if the emergency switchgear room temperature cannot be maintained below 104 F. It also includes instructions for establishing alternate modes of cooling if either or both refrigeration units becomes unavailable. Condition monitoring is conducted in accordance with the Maintenance Program at the component level through a wide variety of test, inspection, overhaul, trending, and repair activities. There are Operations Performance Evaluations, Engineering Test Procedures, and scheduled preventive maintenance tasks that are conducted on a periodic basis that afford ample opportunity to visually observe and inspect pressure boundary components. The effectiveness of the condition monitoring activities is demonstrated by nine routine inspection activities for the Control Room HVAC System and ten routine inspection activities for the Auxiliary Building H&V System. 8

.e ATTACHMENT (1) RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT REPORTS FORilEATING, VENTILATION, AND AIR CONDITIONING SYSTEMS l l NRC Ouestion No. 5.11.17 Page 5.11B-6 of the application indicates that temperature elements do not require an AMR because they have only active functions. However, thermocouples and resistance temperature detectors are installed in thermowells which perform a pressure-retaining function and have housings which serve as environmental barriers. Clarify BGE's basis for concluding that temperature elements do not have any passive functions. BGE Response The temperature elements that are in the scope oflicense renewal for the Primary Containment H&V System (Section 5.1IB of the BGE LRA) monitor the containment atmosphere dome temperature, are not installed in piping thermowells, and do not provide a pressure boundary function. These temperature elements only perform active intended functions and are, therefore, excluded from AMR. NRC Ouestion No. 5.11.18 On Page 5.11B-10, the application includes a description of two aging degradation experiences for valves: (1) some wear of the containmer* purge supply and exhaust containment isolation valves (control valves) were identified, and (2) check valves have experienced pressure boundary failures with several valves failing back-leakage tests. The application also states that the root cause of these failures is due to a combination of wear and misapplication of the valve for its intended function. Please address the following: Clarify the basis for the conclusion that these failures did not involve any ARDMs. a. b. Provide a description of the corrective actions implemented for these two cases. BGE Resnome a. The containment purge supply and exhaust containment isolation valves have rubbers seats that were typically in compression because the valves needed to remain closed during reactor operations. The rubber seat would tend to form into a set position during the typical operating cycle and any relative motion between the disk and seat would cause the valve to loose its air-tight integrity. Then, when the valves had to be tested at the maximum containment design pressure of a loss-of-coolant accident, they may fail the leak test. The ARDM wear has been determined to be plausible for these control valves and they are addressed in Group 1 of the report. The check valve failures were identiF.ed in testing implemented in response to NRC and industry concerns involving check valves, which included testing of instrument air valves in response to NRC Generic Letter 88-14, " Instrument Air Supply System Problems Affecting Safety-Related Equipment." Repeated occurrences of unacceptable leakage in instrument air check valves led to the replacement of many of the valves with new valves containing soft seats. Root causes include wear and the valve being inappropriately chosen for its intended application. The ARDM wear has been determined to be plausible for check valves in the containment penetration portion of the l hydrogen purge supply lines and they are addressed in Group 1 of Section 5.llB of the BGE ( LRA. Information related to design problems is provided below. l 1 9

I ATTACIIMENT (1) REe MNSE TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT REPORTS FOR IIEATING, VENTILATION, AND AIR CONDITIONING SYSTEMS

b. There were two containment purge isolation valt a penetration, one inside Containment and one outside Containment. The two valves lowl outside Containment for each unit have been replaced by blank flanges during normal operations. These blank flanges are relied on for providing containment integrity during Modes I through 4. During Modes 5 and 6 the blank flanges are removed so that containment purge can be initiated. The remaining valves are then relied on for closure in the event of a fuel handling accident inside Containment or a loss of shutdown cooling event. Ilowever, the leak testing performed on these valves is at a much lower pressure than that required for a loss-of-coolant accioent and, therefore, these valves are expected to experience less failures.

l Repeated occurrences of unacceptable leakage in instrument air check valves led to the replacement of many of the valves with new valves containing soft seats. These valve replacements were successful in correcting the leakage problems in all applications except for two cases. In the first case, the existing check valve was primarily designed to function with a higher header pressure (i.e., about 250 psig instead of an actual operating pressure of 100 psig) and used a hard seat and disk. The check valve needed the higher differential pressure and rapid flow reversal to assure an airtight closure. The failing check valve was a lift type ball check valve and was replaced with a spring loaded piston check valve that also allowed for the use of soft seats. In the second case, a few check valves associated with the safety-related supply to the Auxiliary Feedwater System air-operated valves would prematurely wear out. These valves are in a line with an air amplifier that maintains a higher pressure in the accumulators for these safety-related auxiliary feedwater valves than normal instrument air header pressure. Constant cycling of the air amplifiers has caused excessive wear of these check valves. They are currently scheduled for replacement with valves better suited for the application. NRC Ouestion No. 5.11.19 Are there any parts of the systems, structures and components within the H&V systems that are inaccessible for inspection? If so, describe what aging management program will be relied upon to maintain the integrity of the inaccessible areas. If the aging management program for the inaccessible areas is an evaluation of the acceptability ofinaccessible areas based on conditions found in surrounding accessible areas, please provide information to show that conditions would exist in accessible areas that would indicate the presence of, or result in degradation to, such inaccessible areas. If different aging effects or aging management techniques are needed for the inaccessible areas, please provide a summary to address the following elements for the inaccessible areas: (a) Preventive actions that will mitigate or prevent aging degradation; (b) Parameters monitored or inspected relative to degradation of specific structure and component intended functions; (c) Detection of aging effects before loss of structure and component intended functions; (d) Monitoring, trending, inspection, testing frequency, and sample size to ensure timely detection of aging effects and corrective actions; (e) Acceptance criteria to ensure structure and component intended functions; and (f) Operating experience that provides objective evidence to demonstrate that the effects of aging will be adequately managed. BGE Respojise Baltimore Gas and Electric Company can access all HVAC components if required. 10

...,.;~. - ~.. ATTACHMENT (1) - A'PPENDIX (A) l l 1 1 FIGURES i Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant November 16,1998

t 2 3 4 5 6 $idili:iW%y r._1..-., -:r u Y: Q n-g.. -- -, A*-- h' O 4 s p. k'. @ 6 6*- 1,.. 6. 3 E s j .g .--l gb.. e = hM 9 M i 4f M .-M

  • ~ "... '

g i_ g iIe .a =- l 3 l l l, 4h *=da iei .e{.w

  • ~ ~

L l !z - y n.- i

  • a' T.

iC = 9 ?: -cr g e g - g O I 7k,, @ e.-m -e i g ".1 4.~ g* a. i g,s

  • , ~

g;, Q h 8 I i- '.".? a ..m e&. eT 1 I 't I . J.j E -~ 4

  • ~~'*

(... }--Q n i-Tf y. ..7. .d g ,4 ~ i ' g d' ' I I I I -.s i. 1 g b b b b 5T- ['... r..,. T -T ct"Y I 4"V t ":V U"" (.'. .. 3 p.n. .7 7 7 -.- y- _., ,_me,, d{ -+ ,I.*. "e - 4 -. w 4 _.._ - _.- -((}--_.! I O , :n. = -- j j .':2 @I t h b f N f ~' I I E... I...... ll Il-- / lk __mT

4. _

i 1 l t t t J = Figure 5.11C.1 (Control Room H I 2 i ) I

1 l I s I is i si l in I is (...... t .m .=__:.=.= =.:=:.-c "J.'.'::",l":":.". T= h, @mp,J @ - 4@ 4 1.- 4.. - s; -- y . -=. p b,.. ! T - x9 ,,g ,Le_J. ---~ n _ a_ l _-u_ z c L' *J { l 9 wSL.R FOR AUX.. EUL HI,Y 4 y'.,, :~M g 34 g ,,4 - - -} -q = sd i i i i .i g. e# = I a p

iF? I

@< ::::e::: 1 l i J t i 8 Ip i.i T p.p-i i . }' s+, ~. - i '.g cia ,g _ g 3. '%*g.'. ". g*"

  • I I

f++ e a l ...a.a tt -t g g -l l -g I: : _.) i = 6 I g g ,e .a n. g APERTUR d C CARD i i s { Also Avanee c 1 Af)er'itir r ,$*d -e 1 m, y_ .B D-- .. 9,, _2 ~~ (f8 @I m ,,~ .r Q -Q =:.: s x- :. 1 - I.: ../ x x x x i .,,.3 _}_36". =u twe9NA'flot4 ONL4 s. 9nt -t i . ict L 3 " = %'" m 1 .T' "'.Y.l*i' ^ P 3;i A ~ .-{y'~~" .a. ,a n a ' ~ ~ ~ w t i l SY5ff w "' B-4 2 .='a OC. CONTRC POCes 8 NIA'!!' lN "*' l'

  • ~ ~*%

3 mai A8tt $PR[ ADlhG A00M vtNI. SL 06$8 aja l f ei-m - -.%,/ .w " u - C " w,,3,, I f_h '"~ ~ " AC System) .l._ n c. -J==:.:::7==j 23 is :m. = ~

w.C a 2 3 4 5 6 10 l*1!C 10503 .c ar----) .e e. ) p q h b E f !O +1 o.a +_.m. s

== ionsci iu qs 1 n.c.,,. e 3 + s u... r Q.., a hh' ' - -h" ' yd :. Wisi 510E c-a O ,,. n c., os., ) a -i. mu +a~~o > 7 - g $ p,> - 8Ca D Fa# O ....,,,e i O. i-luta4( -"$9.o'm cs u ~[R.01 Afoas T..c. 4.o. o rr. : s "g is tiet f ,, g{'. ' "" ' N ~~~l VQ vj p,;,,oa g, i.ri.n* ice -+- 4 ...,s .4.... +

  • m.

p p =<imW _p. cii: w pg, 16 .c v ['- 'i,6'... MMu} '1 : 8" ~ ~ ~ ' s, 33./.. ' tick. :.3 -- ~ g* M i dip !._______ ___1_ _ _ _ _ _ _ _ _ _ _ _ _ _2_0_ _..________1 I SI,e.p,.... T -@-Q e $~ Sh i', @ypto "L g, 0,& h,.x 5 O _a s $e__.. A _+ j &eag, j YI 4 ,m,,,t - $..;^) cx-unu U " er$- n. y emin O o i.e r y [aEt 4pr yg' e-g am g f d' I ~ d A . 2 A.i' + E d, r6 =.. y g M" e e .e 9 4. -r 1 g n -. - g y smus ruct m,o,t s e u,o o @ 2. ro .g~ CON TR0t. l s ww-+. 4 g.,, !,'!,* M am @. l

  • " O

. +.c n..,. -

== i -n 9 9 ~- 2: 2 Saa &!h. d ^* t,. t It

  1. ~?f U.xt sqgy e

n as... n;

  1. 1 f

u <h b ~ 4.e., D( T alt a* ca o .@,, A., e.43r l_N.- Oe ~ ?,e aa c,s.a >e tr :..n = um;s.c e a:r,s 'wo, v.u.... c

= m.

=> . is c. c c ,,m J Figure 5.11C-2 (Diesel G i i l i I a I

l 3 l 9 l . THINK. ACT AND REVIEW l_ -. 13 10 l STOP. C,,t_h[RAl NOTE 5:

i. se una.ou su sm 2

/ ~ .s . e-WR,." Qf @g >d,Kf.','. e', e e 6 t.<. m .., m. n,. APEFa 0E. ~ s........... :g"rg..T . ;........n.c - 'T,..,,,;., , A. ,,s, s,, p CA D n ~- ww g:7 e. eg ;tn ~ v .v t Aho Availa1 a A. i A.g N@b Aperture Card g5 i V iy ~ e a - eurtex - a,"so-s 4. --- ~ . g., og d ',=.., y /j.uay,,, 5 p g d a' ~________'4~~______________,l "" I%* At-01 -10 f 4y y,___q__f-,,7 7__- ______q,4g..i.,.s,.,g...o,n;. 7.._____ i..e m.o+ g... ,,,,,,,u,-, ,4 ,. g...- i n,- su.uns .r. 3 1 : - ,,,p d a ..,,.1 1 ,.5 ea i m,, m, i ..c.,............. Q' -*n c s g ~ - f G __

k

@Kh*.;. @ '"j s l !d Q,@'i. T ? 3~f _jk-u.! O G G Iff. g '- @,cte

,'r,re..

' ': N g U, _

."'.., n. i,s ieso..

a ? e o t a g m 8 #1 .1 tt. s.10s ..i.s.c. m s, n." s o '- c .. n

  • ies"

'a ". n 3 ,,,,3. x 'n',Uo. $w. -. ? 4t( ~r.,. :.~.. l.... ..n s c, '@,, l 7.1 J ..,n,IM,.. =n. e E

  • ji MT,f,g* g 3 onun, mm.,m, geo.cu,,

o t V V $.,- biw - + ?!*:'",mini,tu ct 5i t t t ~/*_s " - "5" .a.. ~.. ,n s w .. n. _;g 2s% i i x. x,= x -. ;,. :,.. ; a 7. j ate,p4,,. u m e

7. ;,on is,os,.

, a e ro-s> 3 Da a. M ~ ~ M l ~.. b$ b im m...., ' '" I l g."" ~ If fJ~ tac.inica mSi

."... e a

a0TE O is sa et I, 4. a. :. s gj: o 2. e . d. .-e. .2L. ) $n C

h. $$,5Y,o,33 Y

av,,in.is.esn +, pig,_ .sn

n. g tmvts 4.

mu ~ 3,. ] ,e ..M._._ L II*aRaton 30. y g,g IT e F9. F *1F t 1___1 $. 1 oIEE90t i ft e v 4-ROOM Q-g l J j '. d '- er 4- %" ' 7 I,a g es "' }*' 6*N M Dit5it CEintliAIOR ') ROCm I > lfL. V.* G Il ~f_ a .._~__.--- CI N,t SE L 0; 4 20 P Ra10R ".c u ".Y ) THt N(H "k G k kh _ +-[I/w3 o g g en. g e Olt

6. c's e p

J I f ( w i s[P.naion ,,, % -.~ R*=

n.. o i s, w., -- w I

c .g aa %9

w. J w._o..R M.._,.68AH 4 oWf,,,...,,=......

.y. c.f 6 SYSTEM 5 ll ('"~@..nn.. ....$7,%~~' ,d I r-Z, T- ~1.,,s ~~~ lerator Building HVAC System) . i-a 10 l H p r, e j. h.yg_,:gg gic,;,,M E 13

, 4M"*

1 2 3 4 5 6 7 i 8 ~ % ggs,,3q .-.... c 2-- !(I(R (ff(E += .g if l @ 89 5 so,$o,,s la 884 4 sici.ta ass st6 f !.01( i es 5 alkulLL 80

  • - {*"'t e

~'- mss ran. vo-n 's ' r r *..e

i. IRE f.

o -a ) F F iiis +-t ) j ant w.i S' h vo o 80-2 2 y'D 14 gg'g r -4 a ~ 0 .t i h .m#d'Ahnd ~ 3 I ]- m-ise-fg iza7 catex moon ar. uun ea+ t i > 144-1 -i?ses ao # b 'i~' a C e. ) ,8y3 b' O-* TANL ROON uvat tau:Nat anta ano oc noca g3 g, ...... m., ev s-e y vo[JL.,h ha

e l

' ' g' ='w e d I 4 a ' ga, <.,R. Raou y., e 58' ...( q. i., ( f oon t i + hA. s-i ~ ~ ,,., ' ~ p ...( . ( n ~ f saw s -2 i n v es- $si

; - -( ra*an,n<

r.3 Y,A- .{e-D....( ~ Da u ... ( saa s.4 a0 4 UN ts p-d 0-4 g 582 a e 4* MN ~ s su a DG ROOM humussummes e e.. wg_seo_ _,g ..j a s vo.is e I M D f h.-. < w 3 $85l l A I( R o,..,4,s. i os r. l I A UN i C 4-is - lM 7 T I un-u m-is-ios 's l y y y ow ite ?s ioste G

i. vo n 1'

<ASL{ SPR( ADING ARE A DG MD($1Al AR[ A WW3=,....o ~ ni c o T k,,. w-e,s._; ,, I o .4 e ..j + ,_! w >sm,. n ,e,a ,,e .m ..a i z. ,yt,, e ,1 m. r n y qJ- =_%. =_._.f'. ~. 4,. +__ a [Un i. ,nen7 Neo - .~t us p *D(d [as >in .,_ues a m h,;, _. a ! >1T yM3b >=; 4 t y,qq,,,. o ,, j n n; ,a n 'n., - m..." a. n! q m a s ---d-T[~q d--

+-qui

't il

i

.".F ys,., t./,,, 1 M,, .4i 1, , m.., ,r.,. n - Tg .. i . i 'i-1 W."- _ Tj l'" "i 3-j i Figure 5.11C-3 (Diesel Ge . u M ,.r -..- 1 l 2 l l 4 _ _,, _ 3 -__._ _l esv"?WEum fem

_. _. j.. ..1.-... .......-..).-.....-.-.f..-.-....-..--...--:-..---. 9 10 STOP THINK ACT AND REVIEW l 13 3 l C(NIRAL l#0T(si gg

e. gna toenism a

a y

. s.. es,..

u.. ws. as w.

m.......

i.n.....,. r1 .....w. 5" i ..,.,uu m. em ii sna.. ., siars.o. 5.cw +.i g ieiun sa wa n.u u n e 4 oc si ai as -so n "$','%'u'? ! !' ,rj =. a.aa. M a== = = .G.*S...g, a "*. ' a u ma u., i =.7,"_.'"? ... m..

  • L 13 v a Y...a

.......i m .. + g ; ge,, e,,,o., m _.: = n.=,=.

===,:----,-- w O_.. e j =_. =... =.. _, m., _ =. _=, e,. me s< ao..:.. o,a,,wr, . =.m :=.:,,.=.. .m s w = ,,, _ = _== n '). 07 ,3 ..,,.c a n,Fim..* a , - (of 7 o c (.84 s d, e ._,m,. ,_.c, i.[i"*E" ED Irh EaEm*ES. Tie to 6

n. n. 66.s-Eim:*=a'5-L.m a.., =e., a 3

m v a Dut,ca av s. i sit alls s WO 9 &*g.*l.% L"% q 3

m..v...,

.m set c. s d, i.;v-.,=, a."_..N< y.._ _,_ % ~ ~ em..., . 3.... n... O., s ...g.o o,,.,.,&+* '. A u e u. c' - ....s., g < .n 0 .rsaw' g --..;3f e J,.... _- p i... ~ 7

m,s..:.:.

o_...Q. g. d =-, _._m,,..,, o,,3,QR7(,p, $ !_$~M,s.io . $N t ' ' ' " b IL5 t 4, .... 6g+.] oc i,i_t., g,,...... % e F APERTURE m.. 'M CARD s

e. g Alno Avd!able on Apciture Card V) Il e'i,l'.3 ' x

@'o wi r-0 .0^A BA11[RT ROOM l M .!ut. nx e 1 Jt 3~. .,d, rya,., ~ u_ h O' i ! } C A A [ f,U A Utt '" 't;- T 0 i

UU oU a?~ >t e

m.,. __ _1=. ! mu, H4 FORM # Hon OHLN EK. - -- L p j. ..c sTsic. ~.. =. m

    • n====

i ri i ,,,,u ....,.,,<.o ,. m, 7_. U i... aci..e c"! iEE';F.~='h r, o-m _ t.f %. -@W- 'i ~ -.'"w. m erator Building HVAC System) f-e =.. w ,,.. ~ l 11 g->. **-, n a,m..,.a.,:..;.;=e d m m1 is e wem 18

F Aiaet a eaa%ie@.e areeg -> mu i I gm**eaem+eemo eow me e 3 l 4 s _.-..e.,,........ 4 -sef94+ -bef8W -eedEb+ ,:J L.,,r. ,: J 2 iL it r 1r,, r i -- 7.!., !.{-" 1.{" l/=v l m6 ii i 4 -i .:s.1I = l l =-l l =- l.:se. E r I l.='1.ll~=h l'?llC'L'Ml l Z*i/2 l lJ.*r.:.l - t t i t__ r .. n a.st H6 -p.y F ps:..] j = l Hs: l l.= =.l @ i ^ l I r [ 1 I l I I I I I I I >=l l f.- l l + l l=l l :s l l =-l K+ l PfA Gig R5-l E i

f--i M

Ii i [ a'*. "u !r i 4.~.. g* / [=. _~ ~ >...... ', m,__,,, g'- _ _ sstxrca _ano._ mon.syy - - c

= E f '* G l"l'g, k. ;i y
i p

m, j a t----------~~l %,,,,,g,

L

/"J".@ ^ ). .. ) (. .., c n-A A [5 3..... l )"~ '~~M f'~ '~" ff7 p_ >..._ J Q -.-.-<>-- m t e- - - _- E, L, .,m.,m l I - <. = ' = < 4Lg t i j j d+ + W,,p,,}.

.

a.= i v ^ lt @,0 2 - "" i 7 r p.r= us.r.p .y u. 3. f~ 4Q m4 get e .i [i.;. dcmp ~"~isc.@cht_. 3 25. f ~ - _ = ? _ gam _'. adm"W. ia e(y { Q) rmd ce. e e ,,... s....;. w %. i 1 3 l 4 I s i s 6

..,m,- J l s I e j is 1 STOP. THINK. ACT ANO REVIEW \\ 13 arcniund 6$ 'g'" d i l @"9g CARD p w. io -_g.._. __g. ..,..; -.. +-h., ._.r. -.. ++,, F - ^*i"p ^gd$j,f" _ ,, = = ~ v@ o cs>x @= i i .+ 4.+ c ~B. [ h t 1:_ _.,_. _] .:_. _ _. ++,,-F - -=w E. -. + - l = t -cp = 2 i .Ef. 3,. a i m__,_... w _r.. r. = . 41 7 s i m.:r._ - = = - mw .=..=-: w;,g,a,g t gg = 'a i] [ = i i I i .. -l l i Bl:3l[==-l F- -jl =.zl r..=j ~ -4 M Fe. ' l w--n-%nar. ., p.u.e i .= = 8 l =s.-l [=t==j j =a j w .w @s l ~~ 7 = . ~ - ._T"..Q. .] Hbef. - i.:neng _.+g..-- 3 .1_ yl =4 ~ @c -- y .o = mee.- 1 .1 i Q = ,= ~~ ,,7,m-.m,.k-g .,-u e r ,-mr. m. .: = :=.v = i 1 I h 2=.;. _...... m --.. I I y v0 j. =.= = =- g -a v 4... - - c t, t k i >.. -..n -. - < I IMO,SMATioed op4LY u""., g.+ =... -- s,sim, F = i i, . ~.. rm.w.,.n, a l r.:-l I T E.'ItM.Tr.'.=' [ _i *sta.;;;-- g o Bull 0{N NillA110N ,....l' Figure 5.11 A-1 (Auxiliary Building M&V System) 3 - 4 -w-l p I II G. . ss s s stestn4sessinn.-'- gg _}}

Retrieved from "https://kanterella.com/w/index.php?title=ML20195E662&oldid=4120884"