IR 05000358/1979019
| ML19208B623 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 08/01/1979 |
| From: | Julie Hughes, Knop R, Vandel T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19208B621 | List: |
| References | |
| 50-358-79-19, NUDOCS 7909210090 | |
| Download: ML19208B623 (35) | |
Text
{{#Wiki_filter:. U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMEhr
REGION III
t
Report No. 50-358/79-19 Docket No. 50-358 Licerse No. CPPR-88 Licensee: Cincinnati Gas and Electric Company 139 East 4th Street Cincinnati, OH 45201 Facility Name: Wm H. Zinsner Nuclear Power Plant Investigation At: Amelia and Moscow, Ohio Dates of Investigation: July 18-20, 1979 hVY [. l/ [ / Investigators: T. E. Vande '/ ' t (b T-/- 7 9 u s . .&> odL kG.A.Phillip f !'
f.d.M ou Q I-Reviewed By: C. E. Norelius f[I[7 7 Assistant to the Director R.
/ f . '/ Projects Section 1 Reactor Construction and Engineering Support tranch Investigation Summary Investigation on July 18-20, 1979 (Report No. 50-358/79-19) Areas Investigated: Because of concerns regarding electrical components and equipment expressed in an affidavit signed by an electrician who had worked at the Zimmer site, the investigators reviewed pertinent records and procedures, examined electrical components and equipment and conducted interviews of personnel. The investigation involved 92 investigation hours by three investigators.
Ob'lMid ? 9 09 210 O c/ O
. Results: Regarding the seven areas of concern in the affidavit; (1) overloading of cable trays, (2) overloading of seismic hangers, (3)
overloading of wall penetrations, (4) quality of control devices, (5) planned use of walkie-talkies, (6) connections of electrical circuits, and (7) redundant systems on one seismic hanger, it was determined that: The item had been either identified and was being evaluated; or, the matter had been previously identified and reworked or scheduled for rework; or, the item met applicable specifications; or, the item did not involve safety-related components or equipment. Other specific concerns identified by the electrician during an interview and a subsequent site visit were similarly resolved. No items of noncompliance were identified.
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. REASON FOR INVESTIGATION
An affidavit dated June 26, 1979, signed by an electrician employed at that time at the Zimmer site was submitted to the Atomic Safety and ' Licensing Board during hearings on June 29, 1979, and was referred. to Region III, by the board, to look into the items of concern expressed therein.
SUMMARY OF FACTS On June 29, 1979, the Miami Valley Power Project, an intervenor organization, in rebuttal to testimony by the licensee, Cincinnati Gas and Electric Company, submitted an affidavit dated June 26, 1979, signed by Donald Blanch, who identified himself in the affidavit as an electrician who was currently employed at the Zimmer site. The affidavit identified seven " problems and/or possible problems" he had observed while working at the Zimmer site.
On July 18, 1979, Blanch was interviewed at his residence in Amelia, Ohio, ir. the presence of two lawyers representing the Miami Valley Power Project to obtain additional details regarding the matters contained in his affidavit and to obtain information regarding any other specific concerns he might have regarding the electrical work st the Zimmer site.
Arrangements were also made for Blanch to visit the Zimmer site on July 19, 1979, to physically point out his matters of concern to NRC, licensee and contractor personnel who accompanied him.
At the conclusion of the site visit, Blanch indicated that although an evaluation may determine that cable tray loadings do not exceed the criteria specified in the Final Safety Analysis Report, some cable trays were, in his opinion, overloaded. He further indicated that he was otherwise satisfied that his other concerns, as they related to Class 1 (safety-related) components and equipment, had been resolved through rework or had been identified for evaluation and/or rework.
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. DETAILS , 1.
Persons Contacted . Donald Blanch, Former Site Electriciac - , Lewis Seiler, Attorr.ey, Miami Valley Power Project Tawn Fichter, Attornay, Miami Valley Power Project Cincinnati Gas and Electric Ccapany
- J.
R. Schott, Plant Superintendent
- B. K. Culver, Project Manager
- W. W. Schwiers, Principal QA&S Engineer
- R. P. Ehas, QA&S Engineer
- D. C. Kramer, QA&S Engineer
- J. F. Weissenberg, QA&S Engineer
- C. A. Burgess, QA Electrical J. Seibert, Site Electrical Engineer Sargent and Lundy Larry Szumski, Electrical Engineer Steve Tutich, Site Electrical Engineer Kaiser Engineers Incorporated
- R. Marshall, Project Manager
- E. V. Knox, QA Manager
- R.
E. Turner, Site QA Foothill Electric Ben Evans, Electrical Superintendent
- Denotes those present at the exit interview.
2.
Introduction On June 29, 1979, the Miami Valley Power Project, an intervenor organization, submitted an affidavit to the Board during the hearing on the Zimmer Nuclear Power Plant. The affidavit which was signed on June 26, 1979, by Donald Blanch, who was at that time employed as an electrician at the Zimmer site, identified seven items as problems and/or possible problems he had observed. The affidavit was submitted in rebuttal to testimony by the licensee. A copy of the affidavit is attached to this report as Exhibit A.
The Board at the June 29, 1979, session did not decide whether to admit all or part of the items in the affidavit but referred the affidavit to Region III to look into all of the items contained in it.
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. On July 13, 1979, Blanch was contacted by telephone by Region III - and arrangements were made to interview him on July 18, 1979.
3.
Intereiew with Donald Blanch On July 18, 1979, Donald Blanch was interviewed at his residence in ~ Amelia, Ohio, in the presence of Lewis Seiler and Tawn Fichter, attorneya representing the Miami Valley Power Project. Also present during part of this interview wa~ Charles A. Barth, Office of the Executive Legal Director, NRC.
Blanch stated that, although Seiler and Fichter were present at his invitation, he had not retained them for legal counsel nor was he a member of the organization they represented.
Blanch said that he had executed the affidavit as a means of bringing his concerns to the attention of the NRC and site management so that they could be evaluated and, if appropriate, remedied.
Blanch also advised that he is no longer employed at the Zimmer site having been laid off recently and was currently employed elsewhere.
During the interview, Blanch identified some conditions such as excess lengths of given cables, intertwining of cables in trays and the arrangement of large and small diameter cables in trays which, while not desirable, were not contrary to specifications or NRC requirementr.
Blanch stated that he was aware of cable trays that were physically overloaded, that is, piled high in trays. He was informed that the cr!;cria in the FSAR in this regard require that cable shall not exceed 40 pounds per square foot and the summation of cross sectional areas of the cables shall not exceed 50% of the tray usable cross sectional area or two layers of cables, whichever is larger, but not to exceed 60% of the cross sectional areas in any case. He was further informed that the addition of side plates to the trays to accommodate cables was permissible provided these criteria were met.
Blanch indicated that, even if an evaluation demonstrated that these criteria were met, he would still consider some trays to be overloaded.
During the interview the other matters in this affidavit were discussed and, in some instances, it was agreed he would identify some specific areas on concern if a visit to the site was arranged.
Prior to the conclusion of the interview, Blanch stated that all problems or potential problems he had become aware of during his employment at Zimmer about which he was still concerned had been discussed.
4.
Site Tour with Donald Blanch Arrangements were made with the licensee for Blanch to visit the Zimmer site during the evening of July 19, 1979, to point out specific matters of concern. During this visit Blanch was accompanied by NRC personnel as well as the following: -5-35100
. W. W. Schwiers, Principal QA&S Engineer, CG&E R. E. Turner, Site QA, KEI S. Tutich, Site Electrical Engineer, S&L B. Evans, Electrical Super'intendent, Foothill At the conclusion of the tour, Blanch indicated he was satisfied that all of his concerns involving safety-related matters had been identified, were being evaluated and/or reworked, or met requirements.
5.
Affidavit Concerns A listing of all seven items in the affidavit of Donald Blanch as well as a summary of the findings follows: a.
Item One Concerns Concern: (1) As much as 80% of the cable trays throughout the plant are ove cloaded beyond National Electrical Code specifications of volume per tray.
Observation: (a) Of the approximately 15,000 cables installed at Zimmer only 25% are Class 1E, i.e. essential for emergency reactor shutdown, containment isolation, reactor core cooling, containment and reactor heat removal, or are otherwise essential in preventing significant release of radioactive material to the environment. Class 1E systems are defined as " Safety Related" (10 CFR 50, Appendix B, introduction) and are the systems under review / inspection by the NRC.
(b) Article 90-2 of the National Electric Code (NEC) 1975, scope b(5) states: It (NEC) does not cover installations under the exclusive control of electric utilities for the purpose of. . generation control, . transformation, transmission and distribution of electric energy located in buildings used exclusively by utilities for such purposes. Section 8, ... " Electric Power" of the CG&E Final Safety Analysis Report (FSAR) for Zimmer station makes no committment to utilize the NEC standards in its design.
Concern: (2) Trays are filled to as much as 150% of capability in some cases, requiring addition of side plates. Addition is merely cosmetic and does not add to the capacity of the trays: bl ir7)({
' Observation: (a) FSAR, Section 8.3.3.1.3, " Fill," states: The summation of the cross-sectional areas of the cables shall not . (1) exceed 50% of the tray usable cross-sectional area or, (2) two layers of cables, whichever i's larger, but not to exceed 60% of the cross-sectional areas in any case.
(b) The subject of cable tray filling has been discussed in several NRC inspection reports, concerning thermal ampacity (80 watts /ft) and loading fill limits (40 lbs/ftz), e.g. 358/76-10; CG&E audit performed November 14-15, 1977, of Sargent and Lundy (S&L) the Architect-Engineer (A/E); and S&L's letter dated April 11, 1978; tray side plates (rails) were installed in accordance with approved design document change (DDC) E-2599. Portions of NRC inspections are attached to this report as Exhibit B.
(c) The NRC inspector reviewed S&L's letter dated July 9, 1979, to the licensee regarding tray loadings. S&L on May 15, 1979, analyzed 33 routing points of the worst conditions and determined in one case to re-route one non-safety related power cable out of tray sections 4564A, 4010A and 4011A into conduit.
In another instance there are three cables, which have not been pulled and will be route into conduit, thus reducing all tray loads below the FSAR committment of 60% volume fill. These cables were also evaluated for thermal ampacity and mass weight fill and determined to be well within the design criteria.
(d) The NRC inspector randomly selected several Class 1E cable tray sections in the reactor building, cable spreading room, auxiliary building, switchgear rooms and control room.
It was requested that S&L calculate the themal ampacity and actual loading fill for the following cable trays sections 2141C,,2157B, 2158B, 1218B, 1058A, 1300A, 1055B, 1301A, 1275B, 1111B, 1092B, 1082K, 1086B, 3039A, 2056B, 2023A, 2023B, 2245B, 2016B, and 2030A. These trays appeared to the NRC inspector to be overfilled due to poor installation practices e.g. permissible use of random layed cables (criss-crossed) which fails to promote ideal conditions.
This example results in what appears to be an overfilled tray. Though aesthetically unpleasent, the tray may not be overfilled from a specification or requirements standpoint. The NRC inspector on Jaly 25, 1979, reviewed S&L's calculations for thermal ampacity and - - 3&i272
. loading fill for the aforementioned cable tray sections. The worst tray section was well within the design criteria. Example: Allowable llmits for a 2 (FSAR, , 2-foot tray is 80 watts /ft and 40 lbs/ft Section 3, Paragraph 3.10.1.2.3).
The worst condition reviewed by the inspector was power tray sectron 1058A, B which was calculated to be 47.76 watt's/ft and 28.97 lbs/fta, Concern: (3) Overloading will cause inductance (heat) which will cause breakdown of cables if the heat generated is of sufficient level.
Observation: (a) Refer to the above example for allowable heat dissipation limits.
(b) Power cables are derated, i.e. the allowable current carrying capability (ampacity) of the NRC or manuf te-turer are drastically reduced. The method includes use of IPCEA tables and consensus paper e.g. Stolpe papers. Example of derated cable ampacity; size of cable No. 6; current carrying capacity; NEC 70 amps, Mfg 75 amps and S&L 21 amps. Power cable current carrying capacity of Zimmer are described in the FSAR table 8.3-18.
(c) Derating of power cable has been discussed in NRC inspection report 77-13, Exhibit C attached and S&L letter of April 11, 1978. Based on the conservation of S&L's deration, it is concluded cables will not be operated at values which would produce excessive amounts of heat.
Concern: (4) Instrument malfunctions and fires are a direct possibility due to the overloading.
Observation: (a) Malfunctions of instruments could occur if a fire were to occur.
Power and control cables are by design, segregated from instrument cables in order to isolate " noise." Power and control cables are inherently " noisier," than instrument cables. Instrument cables operate in the milliampere range, therefore pose no-8-000T/0
threat to fire from overheating. Example: Instrument cable tray section 1082K was calculated for watts /ft and mass weight fill. There were 438 No. 16 conductors and 1016 No. 20 conductors, which combines into 216 . total cables. Total watts /ft was.00616 and actual loading weight was 13.56 lbs/ft2 The design " engineer assumed the maximum possible current of 20 millicamps.
Therefore, the heat generated is so small, that it is impossible to overheat the cables and cause a fire.
(b) Instrument cable trays are designed to have ferrous material covers, so that there is a magnetic enclosure for these cables.
Note: All Class 1E cables installed at the Zimmer plant are qualified tc IEEE 383, Section 2.5 " Flame Tests." Refer NRC inspection reports 76-04, 76-05, 76-08, and 76-10 (Exhibit D attached). The cable spreading room and other areas of the plant is equipped with fire protection systems.
b.
Item Two Concerns Concern: (1) The spreader room (cable spreading room) is directly below the control room and contains all monitoring cables for the plant though trays and conduit.
In this room the cable trays are overloaded, as are cable risers.
Observation: Cable trays overloading was discussed in Paragraph 1(b)(3).
Ten of the worst conditions of cable risers were analyzed on January 22, 1979, the highest watt /ft was 24.01, which is well below the allowable limits of 80 watts /ft.
Concern: (2) During the plant tour, Mr. Blanch, pointed out one hanger support (1H187) that he knew of that did not meet the design specification. The hanger was tagged with a yellow ribbon. Quality control inspectors use this method to identify a hanger support that does not meet the design specification.
If the hangers are accepted, a yellow 1" square tag is placed on the hanger.
Observation: (a) During this inspection, the NRC inspector observed areas, such as the cable spreading room that was-9-361274
. . being inspected by the quality control inspectors, all areas have not been inspected at this time.
(b) The NRC inspector reviewed the following cable tray hangers and loads that were evaluated by S&L's designers; Hanger Nos. 2HV2, 14H11, 15H2, 24HV2 and
3H3, hangers are designed for 40 lb/ft. The highest
loading was hanger 15H2 which was 26.98 lbs/ft, well within the design criterion of 40 lbs/fta, Concern: (3) Original fireproofing specifications cannot be met due to the doubling of the original cable amount, in the Spreader Room and throughout the plant.
Obse rvation: The fire stop (barrier) material was not selected until this past year. Thoce walls, other than flood walls will have fire stops of foam silicone rubber compound or high density silicone rubber compound. Fire tests were conducted by CG&E during the past year on this material. Fire stops are not being installed on essential electrical systems at this time.
c.
Item Three Concerns Concern: (1) Where cables penetrate a wall there is a " grid" penetration which specifications require be sealed for possible fire and contaminant control. Due to excessive cables penetrating these walls, the original specified sealant cannot be installed throughout the plant.
Observation: (a) Mr. Blanch states that due to excessive cables that the original Nelson sealent fittings which are used for the sealent cannot be installed. The NRC inspector reviewed 4 essential and 19 non-essential DDC's for the installation of the Nelson seals. DDC's are being written where the configuration of cables through wall block outs (grid) does not conform with drawings. The DDC's are then incorporated on the installation drawings S&L No. E270, Sheets 1 through 22. Wall block outs are being inspected by the site field engineers.
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(b) Nelson sealent fittings are primarily used for flood . protection, but are qualified as a fire stop (barrier), also.
Concern: ' (2) The overloading through the wall penetration has caused cables to be cut in half at the point of the wall penetration, , and similarly could have caused damage to the insulation on other cables in the plant.
Observation: The specific cable was not mentioned in the affidavit nor pointed out by Mr. Blanch during the site tour. Discussions with the electrical field engineers could not reveal any instances where cables had been cut in half at the wall penetration (conduit sleeves).
Mr. Blanch pointed out conduit sleeves located in the cable spreading room, which in his opinion, were overfilled.
The NRC inspector observed conduit sleeves in several areas, including the cable spreading room, which was pointed out by Mr. Blanch. The inspector determined that the worst case of apparent overfill was located at the 546' elevation brtween the control room and reactor building.
On July 25, 10i9, the NRC inspector reviewed the designers (S&L) ocLJuit sleeve calculation for the above conduit sleeves and determined that cable loading was within the limits of the criteria established by S&L.
d.
Item Four Concern Concern: Control devices are in many instances of very poor quality and sometimes unreliable. Components for jobs such as this are sometimes ordered as much as 3 to 4 years ahead of installation.
Many as of this date have been discontinued for.a more reliable component. For example, Power Drawers at supervisor locations, I.C. signal boxes, which measure vibration, eccentricity, and thermal (thrust) bearing wear of reactor feed pumps, which have since been changed on newer installations to more reliable components.
Observation: During a plant tour with Mr. Blanch, on July 19, 1979. These concerns were pointed out to the NRC inspector and the licensee, - 11 - - b' ISM
. - most of the items pointed out were non-essential components.
The items concerning essential cable trays i.e. are covered in Paragraphs 1 and 2 of this report.
As in the construction of any large project, long lead times
are required for the purchase of equipment. During the construc-tion period the state of art will in some cases improve instru-ments and control devices. The devices at Zimmer were purchased to contract and design criteria. The reactor feed pumps, including the various supervisory control devices are not essential (safety related).
e.
Item Five Concerns Concern: The use of radio signal walkie-talkie, as used by CG&E will cause I.C. boxes and other microamp high frequency monitoring devices to emit false signals.
Observation: The NRC inspector discussed this item with CG&E's design engineer and plant superintendent. The radio signal that is going to be used is a very low level frequency. Most relay cabinets have a metal door enclosure which will shield out extraneous radio frequencies. There will be a survey performed by the licensee in critical areas and these areas will be posted so as not to use radio frequencies in this area.
f.
Item Six Concerns Concern: There is a lack of coordination between four concerns responsible for electrical testing at the plant: Multi-Amp, I&C, CG&E Maintenance and Westinghouse Electric.
In many instances circuits previously checked have mysteriously become disconnected.
As a result, I am unable to assure that the circuit condition ' after it is cheried will remain the same.
Observation: Multi-Amp and Westinghouse Electric do not perform tests on essential (safety related) components and systems.
I&C testing department has been reviewed previously by NRC inspectors.
CG&E maintenance department is reviewed by the NRC operations section.
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The NRC inspector discussed the interface of all four testing departments with the lead testing engineers. Each section has a log which is used to record all cables that have been deter-minated. Determination of cablen is sometimes required to perform construction and functional testing. There are pre-operation tests performed on all components and systems efter construction and functional testing has been completed. ~ g.
Item Seven Concerns Concern: Within the last year I observed redundant conduit systems installed on the same seismic hanger, in direct violation of specifications.
I do not know whether this problem has been corrected to date. A large problem is that these are essential cables, monitored by Quality Control, and should have been yellow tagged before cable pulling was done.
Such was not the Case.
Otservation: Mr. Blanch, pointed out one hanger, located in the cable spreading room. The hanger supported a blue division conduit and orange (RPS) channel conduits. This item had previously been documented on a licensee nonconformance report and dispositioned by S&L; the conduits were not redundant. Divisional conduits must be separated from each other, channelized conduits must be separated from each other. However, divisional-channelized conduits do not require separation.
Exit Interview The inspectors met with licensee representatives (denoted in the Persons Contacted paragraph) at the conclusion of the investigation on July 20, 1979. The inspectors outlined the scope of the investication and presented the results for each identified concern.
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. , . . 'f l trical 4. ' ,%cre is 'a lack of c:drdination between'4 concerns respcodble; or. e ec .. _., _ 6. , . , . - .., . testing at the plant: IMultii-kh. L&c., C.G.& E. Maintenance, :and Westinghouse {,) .. ' . . , , ...:,. ... ., ,. l ,- . . ,g . .. -.. . . y ,., - . . $.. l. jylectric. J.In manyl instances, circuits previously checked have myster , . . .. . . , , .., .
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. _., . , Exhibit 8 - . . Page 1 of 2 . UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
'. Report of Construction Inspection IE Inspection Report No. 050-358/76-10 . Licensee: Cincinnati Gas and Electric Company 139 East 4th Street Cincinnati, Ohio 45201 Wm. H. Zimmer Nuclear Power Station License No. CPPR-88 , Moscow, Ohio Category: A Type of Licensee: BWR (GE) 807 MWe Type of Incpection: Routine, Unannounced Dates of Inspection: November 2-4, 1976 Prinicpal Inspector: E Lee M /8 b / (Date) 6/>-
- 3
, , Accompanying Inspector: F. J. Jablonski / '/ h * 7b (Date) Other Accompanying Personnel: None . 7, <::p Q c.W Reviewed By: E. L. Jordan, A ting Chief // /r7/,76 Engineering Support Section / (Dat6) . . Q . _. - _ ..
. . .. Exhibit B
- ,
Page 2 of 2 & a 3.
Facility Items (Plsns and Procedures) Unresolved Item - Raceway Loading Procedures ~ / m Considerations used for controlli 3 raceway thermal arid mass fill , limits were not available for res sew.
Architect-Engineer logs, computer program and/or other methode will be reviewed during aj.
subsequent inspection.
~ -
C.
Managerial Items The inspectors were informed that CG&E's Quality Assurance and Standard Section is now located permanently on site until the completion of construction.
. D.
Nonecapliance Identified and Larrected by Licensee None.
E.
Deviations None.
F.
Status of Previously Reported Unresolved Items 1.
Pipe Hanger InAlation Procedure (IE Inspection Report No. 050-358/76A071 Ol ~f e IE Inspection Report No. 050-358/76-06 identified that the oil and gasket material used in hydraulic snubbers to with-stand radiation and environmental conditions remain a concern.
During this inspection, the inspector reviewed Bergen-Patterson Pipe aspport Corporation (BP) letter dated September 17, 1976, and Sargent and Lundy Engineers (S&L) letter dated October 5, 1976. The inspector determined that the oil (GE SF 1154 Silicone Fluid) is capable of withstanding radiation and environmental conditions for the duration of 40 year plant life. However, the above letters indicated that radiation testing of the ethylenepropylenesealsand"0"ringswi}lnotmeetthe specified total integrated dose of 3 x 10 rado for the design life of 40 years. Furthermore, tests required by S&L Specification H-2259, Paragraph 2.04B.a remain to be performed.
The licensee stated that tests will be performed either at the end'of this year or early next year. The inspector stated this natter remains unresolved pending review of test data.
DI2/$3 .... _ _ - - - . - -. _... Exhibit C Page 1 of 8
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
"- Report No. 50-358/77-13 Docket No. 50-358 License No. CPPR-08 Licensee: Cincinnati Cas and Electric Company 139 East 4th Street Cincinnati, OH 45201 Facility Name: Wm. H. Zimmer Nuclear Power Station Inspection at: Zimmer Site, Moscow, OH Inspection Conducted: October 5-7, 1977 ' . L' /0[23/77 Inspectors: F udablonski - g M Ebf7l Ka e11 Other Accompanying Personnel: P. A. Barrett (Training) Ch >$4 X!T/ Approved by: R.L.Spe[sard, Chief /C Engineering Support Section 1 Inspection Sum =ary Inspection on October 5-7 1977 (Report No. 50-358/77-13) Areas Inspected: Work performance and record review concerning electrical testing; work performance and record review concerning installation of electrical cables; work performance and record review concerning A.C. motors and AC/DC components. The inspection involved 44 inspector-hours onsite by two NRC inspectors.
Results: Of the three areas inspected, no items of noncompliance were found in one area; one apparent iter of concompliance was found in each of the other areas (Infraction - failure to implement procedures, Section I, Paragraph 1.g; Section II, Paragraph 2.b. (1)). . 38G284 - .. --.
. Exhibit C - Page 2 of 8 t'
b.
Throughout the plant the RIII inspector obsented that power cables were " bunched," 1.e., installed predominately along one side of the cable trays. In some cases cables were completely covered. The inspector was concerned \\ that there was no apparent requirement to install catrie in \\ such a way as to allow adequate heat dissipation, e.g., \\ ' single layers and edequate spacing. InZ9rmation is required regarding the method of analysis or other engineering justi-fication of the installation. This item is unresolved and will be reviewed during a subsequent inspection.
(358/77-13-05)
. "$ ' -6- _
Exhibit C - . - , Page 3 of 8 " U.S. NUCLEAR REGULATORY C0!ci1SSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-358/78-03 , Docket No. 50-358 License No. CPPR-88 - licensee: Cincinnati Gas and Electric Company 138 East 4th Street Cincinnati, OH 45201 Facility name: Vm. H. Zimmer Nuclear Power Plant Inspection at: Zin:mer Site, Moscow, OH Inspection conducted: Februar 14-17,, 1978 Y$0'cl , Inspectors: T. E. Vandel ' d'.26-77 / R. 3. Coo 20 1h dur?hr-/P ' ' ' J. Hughes 3[2e>/"/fs ' ' gn., }% - . 5/Q' [K.R.Naidu / Other Accompanying Personnel: K. D. Ward ~a C 'o Approved by: D'. W. Hayes, ief M/)76 ' ' Projects Section Inspection Sut: mary Inspection on February 14-17, 1978 (Report No. 50-358/78-03) Areas Inspected: Reactor Pressure Vessel Internals installation, elec-trical and instrumentation cables and components installation, fire protection, recirculation pump NDE records, safety related pipe welding, s and followup of previ y entified noncompliance and unresolved matters.
The inspection involv
pector-hours onsite by five NRC inspectors.
Results: Of the seven reas inspected, three items of noncompliance were identified in two are (Infractions - failure to follow established pro-cedures, failure to ovide adequate protection of safety related components, and ina equate documentation of test results) bb'UU[3b
. 6 -, Exhibit C . Page 4 of 8 / l / f ,' (open) Unresolved item (358/77-13-01) - Seismic and environmental . . The R111 documentation for electrical components supplied by NSSS.
ic, inspector's review of licensee QA audit reports which verify the validity of the NSSS certificates of conformance and the ef fectiveness i of the NSSS certification system remains to be accomplis _h_ed.
- s m (Open) Unresolved Item (358/77-13-04) - Electrical cables not tie \\ The licensee's Architect-Engineer wrapped in horizontal cable trays.
supplied the following information in letter to Cincinnati Gas and 14, 1978. The cable tray / support sys-Electric Company dated February tem is conservatively designed assuming the entire cable mass is accelerated with the same acceleration as that of the cable tray / support system. During a seismic (vent, the acceleration response of the cable tray / support system is transmitted to the cable through friction since the cables are not securely attached to the cable tray.
The transmissibility of dynamic response from one system to the other is a function of the natural frequency ratio of the two systems
The natural frequency of cables with small tension is very involved.
low and thus the natural f requency ratio of the cable tray / support At high ratios (3 to 4), only a fraction system to the cable is high.
(less than 10%) of the cable tray / support system acceleration is trans-mitted to the cable. Thus the cables inertia force is much smaller co= pared to the one used for the design of cable tray / support system.
Therefore, cable deflections during a seismic event are not detrimental to the safety of the cable tray / support system. This matter remains open pending further evaluation by the NRC.
( ,(ar (Open) Unresolved Item (358/77-13-05) - Heat dissipation of power cables A review of this matter predominately along one side of cable trays.
was made by the Architect-Engineer as documented in Sargent & Lundy letter to Cincinnati Gas and Electric Company dated February 14, 1978.
the The letter did not state whether this review and/or results meet requirements of Insulated Power Cable Engineers Association (IPCEA) Publication No. 46-426, which is a commitment included in Section 8.3.3v1.1 of the FSAR.
Other Inspection Areas 1.
Licensee Audits A review was conducted of the licensee auditing activities for the year 1977 and those scheduled for 1978.
The results of the review are as follows: 1977 Auditing Activities a.
It was learned that auditing activities, as follows, were performed during the year: ( -3-bOdt2[N .
j.
- Exhibit C
- /
Page 5 of 8 ,> ' U.S. NUCLEAR REGULATORY COMMISSION - OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-358/78-13 Docket No. 50-358 License No. CPPR-88 Licensee: Cincinnati Gas and Electric Company 139 East 4th Street Cincinnati, OH 45201 Facility Name: Wm. H. Zi:mner Nuclear Power Plant Inspection At: Zimmer Site, Moscow, OH Inspection Conduct : J e 12-16, 1978 /(.
h-Inspectors: T. E. Vande / / 9 "f7O ' ' u, . / 5~" Accompani d By: . Pulsipher ' . I Approwa By:V. W. H ye, C Projects Section ,/ ' ' . Inspection Su= mary Inspection on June 12-16, 1978 (Report No. 50-358/78-13) - Areas Inspected: Observation of work and review of records for recirculation pump installations, and for electrical and instrumenta-tion activities; review of procedural provisions for 10 CFR Part 21 handling and reporting; and review of previously identified noncom-pliance and unresolved matters. The inspection involved 62 inspector hours onsite by two NRC inspectors.
Results: Of the eight areas inspected, no items of noncompliance or deviations were identified.
muss .
~. .. Exhibit C Page 6 of 8 (Closed) Unresolved item (50-358/77-13-05, updated 50-358/78-03): Heat dissipation of power cables which were " bunch" installed pre-dominately along one side of cable trays. The licensee's Architect-Engineer issued another letter concerning this matter to CG&E, dated April 11, 1978, which states, in part: "... size smaller than 3/0 in Table 8.3-18 of FS B are more conservative than those in the IPCEA tables. In fact, at the smaller size (19/22) the ampacity in Table " 8.3-18 is approximately 1/2 that listed in the IPCEA publicatio (Close Unresolved item (50-358/78-03-02): Rosemount Company's (Rosemount) supplemental mounting brackets for Class 1E instruments.
Rosemount's " Quality Certification of Compliance" has been revised to indicate the correct revision. Rosemount letter, dated March 31, 1978, to CG6E, Verification Report states, in part: "This is to certify that the below listed temperature sensors were supplied with brackets (Rmt P/N 104-1667-1) containing the supplemental support."
. (open) Unresolved item (50-358/78-01-02): Cable trays CB-7, CB-8, and CB-9 bolted directly to the terminal boxes, which are mounted directly to the diesel generator equipment. Design Document Change E-2987 was issued on May 18, 1978, to prevent transmission of vibration from diesel generator to cable bus. Work has not been ' completed as of this inspection. Further review will be conducted O, in the future.
(Open) Unresolved item (50-358/78-01-03): Environmental qualifications for electrical penetration terminal boxes. The inspector was notified by the licenset that Conax Corporation, manufacturer of the penetrations, would be doing a protype test on terminal boxes and cable splices in mid-August. The inspector will conduct review of the final test results in the future.
(Closed) Unresolved item (50-358/78-03-13 and 50-358/78-08): The applicable ASME Code year and addenda not being specified in KEI's radiographic procedures. The inspector reviewed the following KEI procedures: SPPM-4.1 Radiographic Testing SPPM-4.2 Liquid Penetration Testing SPPM-4.3 Ultrasonic Testing SPPM-4.4 Magnetic Particle Testing SPPM-4.5 Personnel Qualifications-3-a u ss .- -
Exhibit C - . - Page 7 of 8 U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT .
REGION III
Report No. 50-358/78-01 Docket No. 50-358 License No. CPPR-88 Licensee: Cincinnati Gas and Electric Company 139 East 4th Street Cincinnati, OH 452F1 Facility name: Wm. H. Zisuner Nuclear Power Station Inspection at: Wm. H. Zimmer Site, Moscow, OH Inspection conducted: January 11-13 and 18-20, 1978 t, (fe-Inspectors: T. E. Vande
/ fA' R. J. Cook /'? 77 f 124 o l } c2 /~7/ 7 7 , / J. Hugh d /9 ) / Approved by: D. W.
Aye's, - f 2 //7/77 ' ' Projects Section Inspection Summary Inspection on Janaury 11-13 and 18-20,1978 (Report No. 50-358/78-01) Areas Inspected: Work and records review for recirculation pump internal installation, electrical installation, and reactor pressure vessel internals installation, and previously identified noncom-pliance and unresolved matters. The inspection involved 74 inspector-hours onsite by three NRC inspectors.
Results: Of the four areas inspected, two items of noncompliance were identified in two areas (Infractions - failure to provide a procedure for cable loading review and failure to follow procedure regarding cleaning materials).
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____ Exhibit C Page 8 of 8 pulling, QACMI No. E-7 Revision 6, dated January 12, 1978, and deter-e mined that the necessary measures had been established in Section 1.1.4, which states in part, " pull cards may be corrected to indicate route corrections received from Sargent & Lundy by revision to cable . tabulations or by DDC's.
Applicable DDC number shall be indicated.
The entry shall be initialed and dated by an authorized FEC' Engineer."
(Open) Unresolved Item (358/77-13-05): Power cables were " bunched", installed predominately along one side of the cable trays.
In some cases cables were completely covered. The inspector was concerned that there was no apparent requirement to install cable in such a way as to allow adequate heat dissipation (single layers and adequate spacing).
Information is required regarding the method of analysis or other engineering justification of the installation, The licensee stated that the Architect-Engineer is analyzing this problem. This item will remain open pending review of the analysis.
(0 pen) Unresolvec Atem (358/7 b O1): Site documentation did not include seismic and environmental qualification for components supplied by the NSSS including the HPCS pump motor and RER pump motor. The information is available at the supplier's office, however, no evidence of review and approval was apparent. Also, certifications for the reactor building fan motor are required.
This item will remain open until adequate documentation is reviewed.
Other Inspection Areas The NRC inspector reviewed the status of open 10 CFR 50.55(e) reported items. The results cf the review are as follows: Second Actuation of the Main Steam Relief Valves The inspector learned during discussions with licensee represen-tatives that NRR licensing personnel were informed during a meeting on January 5,1978 in Bethesda, Maryland of the Safety Relief Valve second actuation problem design review progress.
It is understood that further review activity is to be undertaken to: (1) double check design calculations, (2) review computer models for possible ~ changes, (3) coccider mitigating devices to reduce.1oading, and (4) meet further with NRR licensing in February 1978.
Functional or Program Areas Inspected-6- , \\ 3842M . - - - -. -- .- . .. _
Exhibit D ,. Page 1 of 10 , ' U. S. NUCLEAR REGULATORY COMMISSION GFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report of Construction Inspection IE Inspection Report No. 050-358/76-04 ' - Licensee: Cincinnati Gas and Electric Company 139 East 4th Street Cincinnati, Ohio 45201 Zinsner Nuclear Power Station License No. CPPR-88 Moscow, Ohio Category: A Type of Licensee: BWR (GE) 807 MWe Type of Inspection: Routine, Unannounced Dates of Inspection: April 28-30, 1976 /A- Y g,'c!7 d Principal Inspector: E. W. K.
ee (Date) bu.h
- Accompanying Inspectors: F. J.
ablonski 6[/C'f7 b* (Date) ( ' W. J. Key j / ( / (6 ate) Other Accomp in Personn None - f rs/ jM7 - Reviewed By: J. C. LeDoux, Chief Engineering Support Section (Date) 00'520.2 . T' . - . . - . - . ' i
Exhibit D . Page 2 of 10 , . The matter stated in IE Inspection Report No. 050-358/76-03 had not been answered by the licensee. The matter above is considered to be unresolved and will be reviewed as part of the licensee's answer to Report No. 050-358/76-03 con- > cerning corrective action to be taken to avoid further noncompliance.
e.
Cable Identification - (1) Each cable reel has a label attached with purchase order number, size, stranding of conductors, type of insulation, trade name, bill of material and date of manufacture. The cable is likewise identified.
(Reference - Receiving Inspection Plan, Cable) . (2) Specification requirements are verified including flame tests and design base tecident withstand tests.
(3) No cable installations were in progress.
(4) No cable pulling procedures have been formalized.
3.
Observations of Work and Activities a.
Emerge:scy Diesel Engine - Generator 1C (1) Concurrent with this inspection, a diesel engine-generator was delive ed to the site.
Portions of the
receipt inspection and preparation for handling and storage were observed by the inspector.
(2) A standard " Receiving Inspection Plan" was in effect, i.e. verify identification, examine for damage, source release, machined surfaces coated, ver. dor instructions for receiving, handling, and storage.
(3) The customer purchase order No. 2082 was listed on the packing list.
(4) A " hold tag" was placed on all three units.
The CG&E Quality Assurance and Standards approved document chech-list was not available.
(5) As received, no tarpaulin covered the generator.
(6) The generator. rotor was not restrained from free wheeling.
(7) Both engines had damaged tarpaulins.
. - 14 r " 3:b3dk31N3
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- T Exhibit D - Page 3 of 10 ' UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report of Construction Inspection IE Inspection Report No. 050-358/76-05 Licensee: Cincinnati Cas & Electric Company 139 E. 4th Street Cincinnati, Ohio 45201 Zimmer Nuclear Power Station License No. CPPR-88 Moscow, Ohio Category: A Type of Licensee: BWR (GE) 807 MWe Type of Inspection: Routine, Announced Dates of Inspection: June 22-24, 1976
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Principal Inspector: C.
. Erb // i / ' 'r @at e)' ~ Y Accouipanying Inspectors: K. R. Naidu 7/7/7f (Date) 9 8 d s s L-F. J.
ablonski 7///7d '(Ddte) Other Accompany h, Personnel: None O Eh
7/, [[ Reviewed By J. C. LeDoux, Chief Engineering Support Section ' / (Dite) L . P,, ,
, e . \\ , Exhibit D Page 4 of 10 ' ' - tensions, pulling methods, pulling compounds, minimum temperatures and bending radius.
Before pulling, all raceway inspections including separation are verified to D have been completed, routing card and cable tabulation verified to be complementary and while pulling, maximum tensions are recorded.
Raceway loading is included as part of the computerized cable tabulation process.
Excess - fill is automatically flagged. CG&E has ultimate, f responsibility for cable insulation testing. Cables are identified both by color and number at th,e end; and incremently throughout the routing.
Balance of ?.' ant (BOP) cable routed in class 1E raceway is also distinctly identified.
b.
Cable storage areas were observed.
Cable reels were stored off the ground and pertinent types, i.e. instrument cable, were covered per manufacturer's direction.
c.
To date only minimal BOP cables have been installed.
Raceway seals, floor and wall penetration seals and fire barrier considerations were not reviewed.
3.
Review of Quality Records a.
Cable is supplied in reference to three S&L specifications: H-2160, H-2161 and H-2162. All cable supplied, including BOP, has the same basic fire and other design base event requirements. Receipt inspections have been performed.
b.
Inspection records confirmed that certain requirements had not been met, i.e. all prototype test data was not provided by all suppliers.
c.
Of the data available for review, no certifications were included which would provide evidence that cable materials supplied to the site were directly traceable to documented prototype flame and other design base event tests. The above item was determined to be unresolved.
- 20 - 3[942[b . . -
. Exhibit.D . Page 5 of 10
UNITED STATES NUCLEAR REGULATORY COMMISSION ' OFFICE OF IhSPECTION AND ENFORCEMENT ,
REGION III
Report of Construction Inspection , . ~ IE Inspection Report No. 050-358/76-06 Licensee: Cincinnati Gas and Electric Company 139 East 4th Street Cincinnati, Ohio 45201 Wm. H. Zimmer Nuclear Power Station License No. CPPR-88 Moscow, Ohio Category: A2 Type of Licensee: BWR (GE) 807 MWe Type of Inspection: Routine, Announced Dates of Inspection: July 21-23, 1976 /'![[. ' Principal Inspector: T.
. Va .(Date) O .- Accompanying Inspectors: None Other Accompanying Personnel: None.
' .$ - -f' //!76, Reviewed By: D. W. Hayes, Chief Projects Section (Date) . . Y
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f' Exhibit D g/ Page 6 of 10
3.
Handling of Safety Related Piping (IE Inspection Report " No. 050-358/76-03) KEI has prepared, approved, and issued QACMI No. SM-4, , Revision 0, effective July 22, 1976, entitled " Procedure @ for Release from Storage and Handlir.g of 3afety Related, , - Special Piping and Piping Components Weighing Over 1000 Pounds." This procedure prescribes the requiremen,ts to be followed for release and handling of pipirg components.
This resolves the concern previously identified.
4.
Pipe Hanger Installation Procedure (IE Inspection Report ~ No. 050-358/76-03) The referenced inspection report identified 4 specific criteria which would be considered during the preparation of an installation proc +iure.. During this inspection the ____.. inspector reviewed a KEI issued Field Construction Proce-dure No. 2-112, Revision 0, dated April 29, 1976, entitled " Pipe Support Installation - Large Bore Piping" and con-sidered it acceptable to resolve the identified concerns except for the oil and gasket material radiation resistance concern. The inspector was informed that the licensee plans to obtain additional information from the manufacturer pertaining to the radiation suitability. This matter remains . open.
5.
Inland-Ryerson Post Tensioning QC Procedures (IE Inspection Report No. 050-358/76-04) The referenced report identified a concern regarding tendon protection activities observed that were not prescribed within the applicable procedure. The inspector reviewed the Field Installation Manual revised to add the indicated pro-visions.
In addition, it was learned that CG6E had approved the revision and had determined its implementation by the performance of an audit. This matter is considered resolved.
6.
Electrical Cable Test Data and Certifications (IE Inspection Report No. 050-358/76-05) The inspector was informed that activity is in progress to obtain test data for flame or other design base event tests for two of the four cable types. Also, documentation is being obtained to show cable type traceability to prototype tests prescribed by the specifications. This matter will be reviewed further during the next inspection.
. . -4-OdMfs' S - - y.
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Exhibit D -*- '. Page 7 of 10
UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT ' REGION III - Report of Construction Inspection IE Inspection Report No.
050-358/76-08 Licensee: Cincinnati Gas and Electric Company 139 East 4th Street Cincinnati, Ohio 45201 Wm. B. Zimmer Nuclear Power Station License No. CPPR-88 - Moscow, Ohio Category: A2 Type of Licensee: BWR (GE) 807 NWe Type of Inspection: Routine, Announced Dates of Inspection: August 24-25, 1976 Principal Inspector: F.
b n
74 . /(%te) - , . Accompanying Inspector: None . . Other Accompanying Personnel: None Reviewed By: D. W. Hayes, Chie d-7d ' Projects Section / (Date) . % / 381238 . - . -.... _ _
= .
Exhibit D
- -
Page 8 of 10, E.
Deviations
fl }l Contrary to Section 8. Table 8.1-1 of the Final Safety Analysis - Report (FSAR) and the Institute of Electrical and Electronic Engineers (IEEE) Standard 336-1971 Sections 2.5.2, 5.1.3, 6.l(6), 7 and 8, the licensee has failed to develop procedures for calibration and control of test equipment, inspection of temporary conditions such as jumpers or lif ted wires, data analysis and evaluation by quality assurance, and provisions to make records such as test data sheets and working drawings part of the official project record.
F.
Status of Previously Reported Unresolved Items Electrical Cable Test Data and Certifications (IE Inspection Reports No. 050-358/76-05 and No. 050-358/76-06) . . The inspector reviewed test data and certifications for cables supplied by Kerite Company and determined them to be acceptable.
Certifications f_or cable supplied by the Okonite Company were not reviewed by the inspector.
No certifications for cables supplied by Samuel Moore and Company, and Raychem were available. The licensee has placed the above cables on hold thus prohibiting installation until certifications are received, reviewed and approved by the licensee and architect-engineer. This item will be reviewed further during subsequent f inspections.
I E nagement Interview . A.
The following persons attended a management interview held at the conclusion of the inspection.
, Cincinnati Gas and Electric Company (CG&E) R. P. Ehas, QA and Standards Engineer J. E. Hoffman, QA and Standards Engineer R. J. Schlunt, Electrical Field Engineer - W. W. Schwiers, Field Project Engineer Gearco, Incorporr.+.ed H. B. Gear, Site Construction Manager % ' -3-3b4230 . e ... -... .
' - - - I/ Exhibit D Page 9 of 10 , . . UNITED STATES NUCLEAR REGULATORY C01&!ISSION OFFICE OF INSPECTION AND ENFORCEMENT .
REGION III
Report of Construction Inspection - IE Inspection Report No. 050-358/76-10 . Licensee: Cincinnati Cas and Electric Company 139 East 4th Street Cincinnati, Ohio 45201 Wm. H. Zimmer Nuclear Power Station License No. CPPR-88 , Moscow, Ohio Category: A Type of Licensee: BWR (GE) 807 MWe Type of Inspection: Routine, Unannounced Dates of Inspection: November 2-4, 1976 . [[ /8 b Prinicpal Inspector: E Lee / (Date) - q.9. aGau [I-/h~7b Accompanying Inspector: F. J. Jablonski (Date) Other Accompanying Personnel: None ' a.C fcir-c Reviewed By: E. L. Jordan, A g Chief // rT/,7(a Engineering Support Section / (Date) . , . . . 88.uw
. ^ . - -.. -.-w . u .~ , ,, . :. _ _ ; :. ~ - - --
-- - - .. Exhibit D -
Page 10 of 10
- /
. 2.
Shielding Gas Flow Rate (IE Inspection Report No. 050-358/76-07) g The inspector re-examined KEI Welding Procedures No. 3.1.22, Revision 1; No. 3.1.36 Revision 1; and weld data sheets and . determined that the gas flow rate specified on the data sheets is within procedural limits.
This matter is cons'idered to , be resolved.
3.
RCI UT Procedure (IE Increction Report No. 050-358/76-07) Questions raised in the above referenced report were discussed.
The inspector determined that the answers were acceptable.
, This matter is considered to be resolved.
4.
RCI Visual Examination Procedure (IE Inspection Report No.
. 050-358/76-07) The inspector reviewed RCI Procedure No. VE-1, Revision 1, dated July 23, 1976, and determined it to be acceptable. This matter is considered to be resolved.
5.
RCI Audit Requirement (IE Inspection Report No. 050-358/76-07) . The inspector reviewed additional information relative to audit procedures, frequency, scope and purpose, qualifications and responsibilities of auditors and determined them to be acceptable.
Thin matter is considered to be resolved.
N - 6.
Electrical Cable Test Data and Certification, (IE Inspection Reports No. 050-358/76-05, No. 76-06 and No. 76-08) , Flame and loss of coolant accident (LOCA) test data for Samuel Moore and Raychem cables were reviewed by the inspector and deter-mine to be acceptable. Also reviewed were certifications which indicated that cable types supplied to the Wm. H. Zimmer were \\ traceable to those cables which successfully passed prototype } tests. Two new electric cable vendors have been approved by the licensee; Cerro Wire and Cable Company, and Anoconda Company, Wire and Cable Division.
Cable supplied ^by Anoconda was certif-ied to meet or exceed all flame and LOCA tests.
Cerro cable is lacking LOCA test certification and is being used only in balance of plant circuits. Suitable means of identification were in force to preclude inadvertent use of Cerro cable in Class 1E systems. This item is considered to te resolved.
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