ML20045E975

Forwards Proposed Change to OL (PCOL-93/05) to License NPF-29,revising TS Operability & SRs for MSIV Leakage Control Sys,Per NUREG-1434,Rev 0 & Annual Regulatory Info Conference on 930504 & 0608 Meeting W/Nrr Staff

ML20045E975
Person / Time
Site:	Grand Gulf
Issue date:	06/25/1993
From:	Hutchinson C ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20045E976	List: ML20045E975 ML20045E982
References
RTR-NUREG-1434 GNRO-93-00069, GNRO-93-69, NUDOCS 9307060265
Download: ML20045E975 (16)

Text

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=~ENTERGY l"n!"7?l"""*" '"'

PM Gtsm M5 3960 T6 601437 P&30

c. n. Hutchinson June 25, 1993 w e pu ue Ih g f!'

r,x anon w U.S. Nuclear Regulatory Commission Mail Station P1-37 Washington, D.C. 20555 Attention: Document Control Desk

Subject:

Grand Gulf Nuclear Station

• Unit 1 Docket No. 50-416 l License No. NPF-29 Modification of the Technical Specifications Operabjlity and Surveillance

• Requirements for the Main Steam isolation Valve Leakage Control System  ;

Proposed Amendment to the Operating License (PCOL-93/05)  :

Reference:

NUREG-1434, Revision O of the Improved Standard Technical Specifications.

GNRO-93/00069 l

Gentlemen:

Entergy Operations, Inc. by this letter is submitting a proposed amendment to the Grand Gulf Nuclear Station (GGNS) Operating License. These changes, which largely follow the guidance of NUREG-1434 Revision 0, are requested to allow GGNS to modify the main -

steam isolation valve leakage control system (MSIV-LCS) to achieve safety enhancements and reduce surveillance and maintenance costs. i Unlike other MSIV-LCS proposals being entertained by the NRC, Grand Gulf is not >

requesting elimination of the MSIV-LCS. Rather, our request involves a more limited scope: initially, to relocate surveillance requirements to our administrative control; and i ultimately, to convert the system from an active to a passive system under the restrictions  !

of 10CFR50.59. It is our understanding that the Staff has already completed a technical ,

review of alternative proposals for the MSIV-LCS which go well beyond the scope ,

requested by Grand Gulf.

On May 4 at the annual Regulatory Information Conference, Dr. Murley announced a pilot .

program established by NRR to give special consideration to licensee requests for changes requiring staff review that involve high cost and low safety benefit. In response to Dr.

Murley's initiative, Entergy Operations met with NRR staff on June 8,1993 to present an ,

initial list of cost beneficiallicensing actions (CBLAs) and to resolve process questions '

associated with the CBLA pilot program. '

i As we discussed on June 8, the proposed change to the MSIV-LCS is being submitted under the CBLA program. Although the change does have safety benefit, particularly with i respect to other MSIV-LCS attematives, its major benefit is economic. Grand Gulf expects cost reductions on the order of $3 million over the remaining life of the plant due mostly to reduced surveillance and maintenance requirements. \ l 9307060265 930625 'A tQ- -

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• ea As additional submittals are made under the CBLA program, Entergy Operations intends to provide sufficient information to determine relative priorities for those submittals competing for common review resources. However, because the MSIV-LCS submittalis the first, relative priority is not an issue, We should note, though, that benefit is cumulative and can begin accruing from the time of approval.

' Attachment 2 of this letter provides a detailed description of the proposed Technical Specification (TS) changes and justification for the changes. Attachment 2 also details the basis for the Entergy Operations, Inc. determination that the proposed amendment involves no significant hazards considerations based on the guidelines presented in 10CFR50.92.

The affected TS pages marked up indicating the proposed changes are included as Attachment 3.

In accordance with the provisions of 10CFR50.4, the signed original of the requested amendment is enclosed. This amendment request has been reviewed and accepted by the Plant Safety Review Committee and the Safety Review Committee.

Yours truly,

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. . tlt liinson i Vice President, Operations GGNS

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June 25, 1993 I

GNRO-93/00069 Page 3 of 4 t

attachments: 1. Affirmation per 10CFR50.30  ;

2. GGNS PCOL-93/05

3. Mark-up of Affected Technical Specifications

4. Sample Proposed Technical Specifications cc: Mr. R. H. Bernhard (w/a)

Mr. H. W. Keiser (w/a)

Mr. R. B. McGehee (w/a)

Mr. N. S. Reynolds (w/a)  ;

Mr. H. L. Thomas (w/o)

]

Mr. Stewart D. Ebneter (w/a)

Regional Administrator U.S. Nuclear Regulatory Commission Region 11 >

101 Marietta St., N.W., Suite 2900 Atlanta, Georgia 30323 Mr. P. W. O'Connor, Project Manager (w/2) ,

Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 13H3 Washington, D.C. 20555 i

Dr. Alton B. Cobb (w/a)

State Health Officer State Board of Health  ;

P.O. Box 1700 Jackson, Mississippi 39205 l

i

e .- < - Attachment 1 to GNRO-93/00069 Page 1 of 1 BEFORE THE -

UNITED STATES NUCLEAR REGULATORY COMMISSION I

LICENSE NO NPF-29  ;

DOCKET NO. 50-416 IN THE MATTER OF MISSISSIPPI POWER & LIGHT COMPANY and SYSTEM ENERGY RESOURCES, INC.

and ,

SOUTH MISSISSIPPI ELECTRIC POWER ASSOCIATION and ENTERGY OPERATIONS, INC. L F

AFFIRMATION 1, C. R. Hutchinson, being duly sworn, state that I am Vice President, Operations GGNS of Entergy Operations, Inc.; that on behalf of Entergy Operations, Inc., System Energy Resources, inc., and South Mississippi Electric Power Association 1 am authorized by Entergy Operations, Inc.

to sign and file with the Nuclear Regulatory Commission, this application for amendment of the Operating License of the Grand Gulf Nuclear Station; that I signed this application as Vice President, Operations GGNS of Entergy Operations, Inc.; and that the statements made and the matters set forth therein are true and correct to the best of my knowledge,information and belief.

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C. R. Hutchinson STATE OF MISSISSIPPI l COUNTY OF CLAlBORNE [

SUBSCRIBED Ng SWORN TO efore me, a Notary Public, in and for the County and State above named, this f

Je day of 'o hlf _ ,1993. i t

(SEAL) b LL .- . W

/ Notary Public ,

My commission expires: l Miss:sMm STAtr7tra TWXT PUmJe N ~ N @r$ Y 5fl Y_'i*rT)3 D _d N

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Attachment 2 to GNRO-93/00069 Page 1 of 12

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Attachment 2 to GNRO-93/00069 Page 2 of 12 A. SUBJECT PCOL-93/05 Affected Technical Specification: 3/4.6.1.4, Containments Systems, MSIV Leakage Control System, page 3/4 6-7 and associated bases.

B. DISCUSSION OF SYSTEM DESIGN Concerns with the Current System Design As discussed in General Electric (GE) Topical Report NEDC-31858P (Reference 2),

main steam isolation valve leakage control system (MSIV-LCS) designs comparable to Grand Gulf Nuclear Station's (GGNS's) have been the focus of industry and NRC concerns as to the reliability and ability of the systems to function in the event of an accident. Also, the safety-related parts of the system such as the blowers, heaters, and flow elements have become increasingly difficult to find and the lead tirne excessively long.

Proposed Conceptual Solution The current requirements for the MSIV-LCS have been identified by the NRC staff in NUREG/CR-4330 (Reference 2) as requirements marginal to safety. NUREG/CR-4330 reviewed the elimination of the system (using GGNS as the reference plant) and the associated impact on risk and determined that the increase risk to the public associated with removing this system was minimal.

To address this issue, the Boiling Water Reactor Owners Group (BWROG)

(Reference 3) has proposed that the MSIV-LCS be eliminated and that instead the leakage past the main steam isolation valves (MSIVs) be " processed" by the condenser. The proposed method consists of opening a path from the main steam lines to the condenser using main steam line drain lines. This direction of the MSIV leakage results in a reduction in the potential release of radioactivity to the environment due to the extended time for radioactive decay while the leakage is processed by the system. The resulting post accident doses may be slightly higher for low MSIV leakage rates but the proposed method is effective for leakage rates greater than the leakage rate at which the current MSIV-LCS is effective.

The BWROG reviewed the proposed pathway, including the condenser, and determined that the proposed pathway is capable of processing the MSIV leakage following a design basis accident coincident with a seismic event (plant specific review requirements are contained in Reference 3). Since the proposed method uses non seismically designed equipment, an exemption from the current requirements of 10 CFR 100 is needed to apply this method.

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.- ' > .. y Attachment 2 to GNRO-93/00069 Page 3 of 12 i

The BWROG and the NRC staff have resolved the technicalissues relating to the radiological effects and the equipment qualification concerns associated with the proposed methods and are workhg at resolving the administrative requirements ,

associated with implementat4cn. 3GNS is fully in support of this BWROG proposal. i GGNS understands the first-of a kind aspects of the BWROG proposal and the extended period of time that plant specific application of the proposal may require. .

Therefore, GGNS wishes to pursue, on an immediate basis, simplifying the MSIV-LCS design to reduce surveillance and maintenance costs and provide safety benefits by increasing system reliability. Although the design has not been  :

finalized, the system conceptually will consist of only four (4) valves (F006 and F007 powered from Division I and F008 and F009 powered from Division 11) that ,

are manually opened from the control room following a LOCA. The conceptual '

design will not result in an increase in the postulated design bases LOCA doses or require an exemption from the requirements' of 10 CFR 100. Figure 2 provides a conceptual drawing of the proposed design.  ;

Opening these valves will provide a path from down stream of the Outboard MSIVs to the secondary containment. The 1/4" vacuum drawn by the standby gas treatment system (SGTS) will provide the driving force to direct leakage to t secondary containment (as it does in the current design during the depressurization i phase) instead of through the main steam line to the environs via the ,

condenser / turbine. The system will continue to meet the current design requirements for the MSIV-LCS as discussed below including the seismic requirements. GGNS wishes to proceed to the final design in stages controlled by cost concems provided allintermediate and final designs meet the rigorous ,

requirements of 10CFR50.59.

The primary intermediate step envisioned would be the disconnection of the system blowers, heaters and most of the associated control logic. This modification would leave the system with the current inboard and outboard subsystems but the new system would be essentially passive requiring only the opening of valves from the >

control room. This will result in a simplified system with greatly reduced operational costs and increased reliability.

The planned modifications to the MSIV-LCS allowed by the proposed TS changes are expected to result in a decrease in MSIV-LCS related operational costs of approximately 3 million dollars over the life of the plant. The TS pages affected by .

this proposed amendment are included as Attachment 3 and are marked up to i reflect the proposed changes.

• L Current System Design Requirements The MSIV-LCS controls and minimizes the release of fission products which could l leak through the closed main steam isolation valves (MSIVs) after a Loss of Coolant Accident (LOCA). The system provides this control by processing MSIV leakage prior to release to the atmosphere. This is accomplished by directing the leakage

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Attachment 2 to GNRO-93/00069 i Page 4 of 12 into an area served by the SGTS. )

i As discussed in Updated Final Safety Analysis Report Section 6.7.1, the following i criteria represent system design, safety, and performance requirements imposed upon the MSIV-LCS:

a. The MSIV-LCS is designed with suffk,iert capacity and capability to control the leakage from the main steam liae isolation valves consistent with containment leakage limits imposed for the conditions associated with a ,

postulated design-basis LOCA. Spacifically, a complete severance of a recirculation line would not result in a radiological dose to any offsite or control room personnel that exceeds che guidelines of 10 CFR 100 or 10  ;

CFR 50 General Design Criterion 19.  ;

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b. The MSIV-LCS is capable of performing its safety function during and subsequent to the postulated accident conditions and following a coincident  ;

loss of all offsite power. f

c. The MSIV-LCS is designed in accordance with seismic Category I requirements.

t

d. The MSIV-LCS is protected from adverse conditions such as:

1. internally generated missiles within the containment, l

2. the dynamic effects associated with pipe whip and jet forces, and

3. normal operating and accident-caused containment environmental '

conditions consistent with the design-basis recirculation line break,

e. The MSIV-LCS is capable of performing its intended function following any <

single active component failure (including failure of any one of the main -

steam line isolation valves to close). In addition, the MSIV-LCS is designed 1 so that the effects resulting from a leakage control system single active -

component failure will not affect the integrity of the main steam lines or MSIVs.

f. Steam discharged from the MSIV-LCS is directed such that it does not affect  ;

the functioning of structures, systems, or components important to safety.

The MSIV-LCS does not prevent the SGTS from performing its safety <

. functions,

g. The MSIV-LCS is manually initiated and controlled and is designed to permit i actuation in a time period no sooner than 20 minutes following the j postulated design-basis LOCA. The required actuation time period is ,

consistent with loading requirements on the emergency electrical buses and with reasonable times for operator information, decision, anc* action.  ;

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Attachment 2 to GNRO-93/00069  ;

Page 5 of 12 4

h. Instrumentation and controls .necessary for the functioning of the MSIV-LCS are designed in accordance with standards applicable to nuclear plant ,

safety-related instrumentation and control systems. The MSIV-LCS is -  !

designed to IEEE 279-1971 and IEEE 323-1971. The Grand Gulf initial j design conforms to the requirements of IEEE 344-1971 as modified by ,

EICSB Branch Technical Position 10. q A seismic review was subsequently performed against IEEE 344-1975.

Oualification during the plant operating license stage is in accordance with IEEE 344-1975.  ;

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i. The MSIV-LCS controls are provided with interlocks actuated from appropriately designed safety systems or circuits to prevent inadvertent i MSIV-LCS operation.

j. The MSIV-LCS is designed to permit testing of the operability of controls and actuating devices during power operation to the extent practical, and testing ,

of the complete functioning of the system during plant shutdowns. -

Current MSIV-LCS System Description f Figure 1 provides a drawing of the current MSIV-LCS.

Outboard Subsystem

• 7 The outboard subsystem is connected to the segments of the main steam lines, between the outboard MSIV and the downstream main steam shutoff valve. The ,

bleed line from each main steam line connects to a bleed header. The bleed header outlet is provided with two valves in series which permit the main steam lines to be '

depressurized by venting following a LOCA. A parallel set of valves, which are -

automatically opened following depressurization to connect the blower suction to l the steam lines, is provided. Pressure sensors, sensing steam line and vessel  ;

pressures are used for depressurization interlock control to prevent accidental valve opening at reactor pressure vessel pressures above 20 psig. Another pressure sensor is used for interlock control on the valves in the line to the blower suction to ,

prevent valve actuation when main steam line pressure is greater than 1 psig. I Pressure indicators are provided for monitoring the pressure in the main steam lines between the outboard MSIV and the main steam shutoff valve. The major flow to >

the blower suction is dilution air from the auxiliary building. A dilution air flow  ;

indicator utilizing a differential pressure sensor is provided to monitor blower flow rate. An alarm is annunciated if a predetermined differential pressure is not established. A timer is used to actuate a high steam line pressure alarm within a  ;

preset time period after system actuation if a sub-atmospheric main steam line l pressure is not established.

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Attachment 2 to GNRO-93/00069  !

Page 6 of 12 j e

A bleed line depressurization branch is discharged to a building volume served and q processed by the standby gas treatment system while depressurizing the steam ~

lines without adversely affecting equipment. The blower discharge line is l terminated at a location in a building volume such that the discharge flow is  ;

processed by the SGTS.

Manual switches are provided for functional testing of the bleed valves. These valves are not tested during operation. This precludes inadvertent dumping of steam due to equipment malfunction or operator error, inboard Subsystem ,

The inboard subsystem is connected to the upstream nozzle of the outboard MSIV.

An individually controlled bleed line is provided for each main steam line. For each  ;

bleed line, two bleed valves, which are the motor-operated-globe type, are connected in series followed by a flow element and a motor operated bypass valve. '

Flow through the four flow elements passes to a common blower which discharges to a building volume processed by SGTS. Discharge through the flow element  ;

bypass (depressurization) valve is similarly routed to a volume processed by the SGTS. Pressure sensors are used for interlock control to prevent any inadvertent actuation of the syrtem as described for the outboard subsystem. An added safety '

feature is that the bleed valves on each of the bleed lines are interlocked to remain closed if the associated inboard MSIV failed to close following the reactor scram.

Pressure indicators are provided for monitoring the pressure in the main steam lines between the MSIVs. In case of gross leakage through an inboard MSIV, a delay  :

timer and pressure sensor are used for closing the bleed valves if 5 psig is not achieved in about 1 minute after the inboard subsystem is activated. Another '

timer, together with a high flow limiter, is used to monitor and close the bleed valves should the totalleakages through both MSIVs exceed a high flow setpoint.

Electric heaters are used, one at the low point of each bleed line, to boil off any condensate and pass it through the flow limiter. -

A differential pressure sensor is provided to monitor dilution air flow. The bleed i valves are interlocked to remain closed upon actuation of the inboard subsystem i until flow is established. A low differential pressure indicates that the blower is not l running and the system valves will remain closed, thus assuring that the low f pressure manifold will always be maintained at a negative pressure whenever the bleed valves are open. Bleed valve closure is also initiated whenever dilution air flow is lower than a preset value.  !

The bleed line depressurization branches are discharged to a building volume served and processed by the SGTS. The blower discharge line is also terminated at a location in the building such that the discharge flow will be processed by the SGTS. ,

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Attachment 2 to GNRO-93/00069 -

Page 7 of 12 i

Manual switches are provided for testing the bleed valves. These valves are not  !

tested during operation. This precludes inadvertent dumping of steam due to  !

equipment malfunction or operator error. +

C. PROPOSED TS CHANGES l Currently the GGNS Technical Specifications (TSs) provide detailed surveillance requirements for the MSIV-LCS. These details are in many cases in excess of the requirements of NUREG-1434, Revision 0, " Improved Standard Technical Specifications" (Reference 1). GGNS proposes to modify the TS to reflect i appropriate portions of the guidance of NUREG-1434 (including relocating required surveillances and other editorial changes). In addition, GGNS proposes to relocate to plant administrative control the requirement for the 31 day surveillance of the blowers and heaters identified in NUREG-1434 and the current TS.

Specifically GGNS proposes to make the following changes to TS 3/4.6.1.4  :

following the guidance of NUREG-1434:

1. Relocate surveillance requirements 4.6.1.4b and 4.6.1.4d to plant administrative control.

2. Relocate the procedural details of the surveillance requirement 4.6.1.4 to plant administrative control. The details of the surveillance are removed while the requirement to perform a system functional test of each  ;

subsystem every 18 months is maintained. '

i Additionally, GGNS proposes to relocate to plant administrative control the surveillance requirements of TS 4.6.1.4a (SR 3.6.1.9.1 and SR 3.6.1.9.2 in NUREG-1434). These surveillances will continue to be performed until the .

necessary design changes are implemented such that the blowers and associated heaters are not necessary for the MSIV-LCS to perform its design function.

Relocating the controls on these surveillance requirements involve no substantive changes to the surveillance and operability requirements currently contained in the GGNS TS. The details of these surveillance requirements are currently in plant procedures. GGNS adheres to a policy of verbatim compliance with all plant procedures. This information will be adequately controlled via the administrative requirements specified in TS 6.8 and TS 6.5.3. Those requirements include review of changes for unreviewed safety questions in accordance with the provisions of 10CFR50.59. Such changes are reported to the NRC in the annual report submitted pursuant to 10CFR50.59. These changes, therefore, constitute an '

administrative revision only.

These changes will provide GGNS the necessary flexibility to pursue enhancements to MSIV-LCS on a schedule controlled by prioritizing the available resources.

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Attachment 2 to GNRO-93/00069 Page 8 of 12 D. NO SIGNIFICANT HAZARDS CONSIDERATIONS

1. Entergy Operations, Inc. is proposing that the GGNS TS be amended to relocate the control of most of the surveillance requirements relating to the main steam isolation valve leakage control system (MSIV-LCS) to plant administrative control. These changes will allow the system to be modified to achieve safety enhancements and reduce surveillance and maintenance  :

costs.

2. The Commission has provided standards for determining whether a no ,

significant hazards consideration exists as stated in 10CFR50.92(c). A proposed amendment to an operating license involves no significant hazards if operation of the facility in accordanca with the proposed amendment would not: (1) involve a significant increase in the probability or i consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of ,

safety.  !

3. Grand Galf Nuclear Station (GGNS) has evaluated the no significant hazards considerations in its request for a license amendment. In accordance with 10CFR50.91(a), GGNS is providing the following analysis of the proposed amendment against the three standards in 10CFR50.92:

a. No significant increase in the probability or consequences of an '

accident previously evaluated results from this change.

The relocation of the control of these surveillance requirements relating to the main steam isolation valve leakage control system (MSIV-LCS) involve no substantive changes to the surveillance and operability requirements currently contained in the Grand Gulf Nuclear Station (GGNS) Technical Specification (TS). The details of the  :

surveillance requirements are currently in plant procedures. GGNS ,

adheres to a policy of verbatim compliance with all plant procedures. l The information will be adequately controlled via the administrative requirements specified in TS 6.8 and TS 6.5.3. Those requirements include review of changes for unreviewed safety questions in  ;

accordance with the provisions of 10CFR50.59. The requirements of  ;

10CFR50.59 include a review of the evaluated change for impact on i the probability or consequences of an accident previously evaluated.

The requirements of 10CFR50.59 prevent any evaluated change l which increases the probability or consequences of an accident previously evaluated from being made without prior NRC approval. ,

These changes, therefore, constitute an administrative revision only.

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Page 9 of 12 B

Therefore, there is no significant increase in the probability or _

i consequences of a previously evaluated accident due to the proposed  ;

changes.  !

b. This change would not create the possibility of a new or different i kind of accident from any previously analyzed.

The relocation of the control of these surveillance requirements l involve no substantive changes to the surveillance and operability l requirements currently contained in the Grand Gulf Nuclear Station  !

(GGNS) Technical Specification (TS). The details of the surveillance requirements are currently in plant procedures. GGNS adheres to a policy of verbatim compliance with all plant procedures. i The information will be adequately controlled via the administrative  ;

requirements specified in TS 6.8 and TS 6.5.3. Those requirements '

include review of changes for unreviewed safety questions in accordance with the provisions of 10CFR50.59. The requirements of 10CFR50.59 include a review of the evaluated change to ensure that  :

the change would not create the possibility of a new or different kind ,

of accident from any previously analyzed. The requirements of "

10CFR50.59 prevent any evaluated change which would not create l the possibility of a new or different kind of accident from any I previously analyzed from being made without prior NRC approval. i I

These changes, therefore, constitute an administrative revision only.

t Therefore, the possibility of a new or different kind of accident from  :

any previously evaluated is not created.

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c. This change would not involve a significant reduction in the margin of safety.  ;

i The relocation of the control of these surveillance requirements involve no substantive changes to the surveillance and operability requirements currently contained in the Grand Gulf Nuclear Station (GGNS) Technical Specification (TS). The details of the surveillance requirements are currently in plant procedures. GGNS adheres to a policy of verbatim compliance with all plant procedures. .

The information will be adequately controlled via the administrative i

requirements specified in TS 6.8 and TS 6.5.3. Those requirements include review of changes for unreviewed safety questions in accordance with the provisions of 10CFR50.59. The requirements of 10CFR50.59 include a review of the evaluated change for impact on the margin of safety. The requirements of 10CFR50.59 prevent any evaluated change which decreases the margin of safety from being >

made without prior NRC approval. These changes, therefore,

.. . .- .- . = . . .

Attachment 2 to GNRO-93/00069 Page 10 of 12 constitute an administrative revision only. .,

i Therefore, the proposed TS changes do not involve a significant  !

reduction in a margin of safety.

4. Based on the above evaluation, Entergy Operations, Inc. has concluded that i operation in accordance with the proposed amendment involves no significant hazards considerations.

E. REFERENCES ,

1) NUREG-1434, Revision 0 of the improved Standard Technical Specifications.

2) NUREG/CR-4330, PNL-5809, Review of Light Water Reactor Regulatory Requirements, Volume 2.

3) NEDC-31858P, Revision 1, BWROG Report for increasing MSIV Leakage Rate Limits and Elimination of Leakage Control Systems, October 1991.

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EXISTING -

MSIV LEAKAGE CONTROL SYSTEM (E32)

LOW PRESSURE MANIFOLD ~~~ ld = DILUTION AIR FROM OTHER[ EXHAUST STEAM LINES

• BLOWER TO AUXILIARY

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PRIMARY CONTAINMENT 4- TO AUXlLIARY 3

= BUILDING VOLUME O SERVED BY SGTS TURBINE C BUILDING $

Yl U 2* TO AUXIUARY y DRW = BUILDING VOLUME 2 SERVED BY SGTS F007 g F009 g DRYWELL STEAM TUNNEL F006 g F008 g 2h' M

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