IR 05000425/1988027
| ML20153F007 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 08/19/1988 |
| From: | Conlon T, Hunt M, Mccormick R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20153F003 | List: |
| References | |
| 50-425-88-27, NUDOCS 8809070091 | |
| Download: ML20153F007 (33) | |
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UNITEO STAT ES
[A HQu o NUCLEAR REGULATORY COMMISSION
[" REGION il j g,
", 3 j 101 M ARIETTA STREET, t ATLANTA, GEORGI A 30323 ,
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Report No.: 50-425/88-27 f Licensee: Georgia Power Company P. O. Box 4545 Atlanta, GA 30302 Docket No.: 50-425 Licensee No.: CPPR-109 Facility Name: Vogtle Unit 2 Module No. 6, Electrical !
Equipment Reviews Conducted: May 4 - 26, 1988
On-Site Inspections Conducted: May 16-26, 1988 ;
Inspectors: b 4 }%-l [ .
M. D. Kunt, Team L'eader'
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k U)*) I WA 0' ate 'S i g ned
hN kk R. D. McCormick, Consult (nt, EG&G Idaho, In Wllc){T$
(TaiW Signed i Approved by: & MN /V b(7- I '
T. G. Conlon. Chief Date Signed Plant Systems Section Division of Reactor Safety j SUMMARY
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Background: This evaluation was performed fc: one of eleven Readiness Review Modules produced as part of a Pilot Readiness Review Program being operated by the licensee pursuant to a recommendation contained in NUREG 1055. The NRC agreed to participate in the ;
program by reviewing and commenting on each modul l
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Scope: This evaluation was performed by reviewing the module repor l examining supporting documer.tation and inspecting associated !
hardwar The licensee's review was verified by sampling I hardware and documentation seen by the licensee's reviewers, i sampling hardware and documentstion not selected by the i licensee's reviewers, by reviewing records of previous NRC inspections at Vogtle and by interviewing licensee personnel who were closely associated with preparing the modul ;
Results: Major weaknesses and verification errors were not foun Two l Unresolved Items (UR!s) were identified. One involved inade- t quate clearance above a cabinet, wrong color code of equipment !
labels, no drip-loop on equipment cables, and possible heat !
buildup in the regulating transformers junctions boxe The other concerns licensee design of protective relaying system l
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which is otherwise specified by the Final Safety Analysis Report i (FSAR) for Architect / Engineer accomplishmen $88'*l889888886 PDC n l
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l REPORT DETAILS l Persons Contacted Licensee Employees ;
- D. Edenfield, RRT Engineering Supervisor !
- A. Gallant, Technical Support Supervisor ,
"A. W. Harrelson, Manager, Electrical Construction ,
- R. Holla'nds, Supervisor, Electrical Compliance
- E. Laner, Supervisor, Electrical Engineering Group
- J. Lavoy, RRT I&C Team Leader J. Lovekamp Deputy Supervisor, Civil Engineering Group ;
D. G. Lunsford, QC Inspector i
- R. McManus, Manager, Readiness Review
- W. Ramsey, Manager, Engineering
- P. D. Rice, Vice President and Project Director l l
U. C. Roumillat, Jr., Senior Protection Engineer NRC Resident inspector - l R. Scheppens, Senior Resident Inspector, Construction
- "Attended exit interview Acronyms and abbreviations used througnout this report are listed in the last paragraph.
i Module 6 Electrical Equipment 1 t l Unit 2 Review l l ?
l The Readiness Review Program is being conducted at the initiative of f
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Georgia Power Company (GPC) management to assure that all design, i procurement, construction, and operational commitments have been >
properly identified and implemented at the Vogtle Electric Generating Plant (VEGP) Unit 2. Module 6, which was submitted on December 17, 1987, presents an assessment of the comnitance of the Electrical Equipment contained in Seismic Category I structures with Final
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Safety Analysis Report (FSAR) commitments and regulatory require-ments. This evaluation was conducted to determine if the results of i the program review of the design fabrication and installation of <
Electrical Equipment presented in this module represent an effective '
and accurate assessment of the requirements, that the requirements I were properly implemented, and that the resolutions of the findings identified in Module 6 were correc It should be noted that a comparable review had been completed for VEGP Unit 1 during 1985 and ,
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b. NRC Review Objective The objective of this review and inspection was to evaluate the licensee's VEGP Unit 2 Readiness Review of Electrical Equipment. The evaluation was to be accomplished through a detailed examination of all sections of the module to include:
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Assuring the accuracy of the information containe Verifying that the Electrical Equipment commitments identified in the module are correct along with being in conformance with FSAR commitments and regulatory requirements.
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Checking a representative sample of the documents reviewed by l the Readiness Review Staff along with other documents selected l by the inspectors.
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Inspecting a representative sample of the Electrical Equipment components currently installed in Unit Reviewing reports of past Nuclear Regulatory Commission (NRC)
inspections at Vogtle Unit 2 that pertain to Module 6.
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Assessing the Module 6 findings and the licensee's resolution I
thereo Assuring that the findings and lessons learned from the Unit I review were appropriately recognized in the Unit 2 revie Verifying that credit can be taken for those aspects of the Unit I review that are directly applicable to Unit Review Scope The total module was reviewed for organization and content. This part of the NRC review disclosed that Module Sections 1, 2, 3, 4, and 5 presented data on module organization, project organization, commitments, program description, audits and special investigation These sections were descriptive and presented material that was i similar to that presented in the similar numbered sections in 1 Module 6 for Unit 1. These sections did not require the review depth l given to Sections 6 and 8 which covered the program verification and
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review assessment plan respectivel Sections 1 through 5 were reviewed relative to changes that occurred in the Vogtle Project and Readiness Review programs since the Unit I review, however. Module Section 7 was similar to Section 8 of the Unit 1 module and consisted of management's certification of the review effort and finding Section 7 of the Unit 1 module reflected the Independent Design Review made as part of the Unit I review. The licensee did not l
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repeat this in the Unit 2 Readiness Review on the basis that the design was essentially similar for both units, was performed by the l
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same organization and was essentially complate at the time of the Unit 1 Readiness Review. It was considered that reverification of an essentially completed program would be redundant within the Unit 2 review. Sections A and 8 contain the majority of the new material and disclosed those bpects of the Unit 2 review that differed from that examined by NRC pursuant to the Unit I revie Review of these two sections included an examination of content; a review of findings, :
concerns and observations; a review of a sample of. items reviewed by I the GPC Readiness Review Team (RRT); and an examination of an independently selected sample of records and field construction, d. Site Inspection
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l The site inspection was conducted at Vogtle Unit 2 during May 16-26,
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Determining the RRT organizational element responsible for
- Module 6 and interviewing key staff member i I -
Verifying the module review boundar .
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Making a general verification of the material presented in Sections 1 through 5 and 7 of the module repor Obtaining supplemental documentation copies required for review use, l
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Reviewing programmatic and review methodology changes taking +
place since the review of Unit 1 Module Assessing the lic.ansee's Module Assessment Plan for adequacy of depth and coverage within the module boundary.
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Performing commitment tracing for commitments that were new
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Performing a construction program verification review of Module .
J Sections 6 and '
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. The new and the changed commitments were traced 19to selected first j and second order verification documents. They were traced backward I
through the FSAR, or other commitment source, to the parent
} requirements.
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"ontinued of fice review was made after the inspection trip to
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evaluate data gathered, draft the module review report, and identify any items that might require further field review and analysis. The ,
review plan, module report, and examination data gathered to date
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l were checked for potential gaps and incomplete work. The results of j the office review disclosed that sufficient information had been
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obtained during the site visit and that the data gathered fully '
supports the NRC findings presented in this module review repor !
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4 Evaluations'
The evaluation of each Module 6 section is provided below using a module section-by-section ' format. ' Included are a description of the section, subject matter reviewed, the basis for acceptance, and a. statement of any required followup or evaluatio Section 1 - Introduction (1) Review Introduction and Section Examination This Section of the module provided a description of the intent and contents of Module 6.- Also provided was a description of the Vogtle Unit 2 hardware covered within the module, an
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overview of the project status, and an outline of the module organization. This section was examined by the NRC Region II Inspectors for content, background, and accuracy of informatio Clarification of information concerning the module boundary and project status was require This was accomplished 'during discussions with the RRT personne .
(a) Boundary Definition The ir, formation given in Module 6 Subsection 1.1 was reviewed with the RRT counterpart to verify the correctness of the boundary definition information presente The information gained during the review disclosed that protec-tive relaying was part of this module, although this was not delineated in the outline presented in this subsection of the modul (b) Module Organization The Module organization portion of the section was examined ,
by the NRC Inspectors, and no instance of inaccuracies or t need for clarification were foun _,
l A specific question was asked concerning the existence of !
significant changes subsequent to the July'1,1987 cutoff l date for Module 6 data. The RRT counterpart responded with !
a statement that there were no changes to the information i contained in the module. Evidence of significant modula-
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basis change since the July 1,1987 cutoff date was not discovered during the revie ;
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(c) Project Status Module 6, Section 1.3, states that the design of the electrical equipment was essentially completed by July 1, 1987, and the overall Unit 2 major electrical equipment
installation was mostly complet Inquiry was made concerning any significant changes that had been made subsequent to the July 1, 1987, cutoff date. The RRT counterpart responded that no changes had been made except that the equipment installation is complete and is about 90*4 energize (2) Inspection Results The clarifications provided by the RRT, as noted above, corre-lated with other information reviewed by the NRC Inspector The examination did not disclose significant verification errors or a basis for programmatic concer Followup or additional evaluation of Module Section 1 is not required, b. Section 2 - Organization (1) Review Introduction and Section Examination This section of the module provided a description of the.organi-zations employed for project design and field construction activitie The integration of these into the total project management matrix for the subject of Module 6 also was provide This section was examined by the inspectors for content and background informatio The information presented agreed with that obtained by the inspectors during past inspections at both Unit 1 and Unit 2. No instances of variance from the Section 2 information were found during the course of the total module review. Also, the information presented did not differ essen-tially from that examined during the review of Unit 1 Module 6, except for engineering and project management changes occurring subsequent to the Unit I revie These primarily were the transfer of Bechtel Home Office Engineering (HOE) functions to the Bechtel Project Field Engineering (PFE) office at the plant sit The transfer was accompanied by some reorganizatio These changes were found to have low programmatic impact since PFE originally was an extension of HOE, many of the same people were involved and the design was at the nearly-complete stag Further evolution of the engineering organization has taken place since the July 1,1987 module cutoff dat The separate functions of design and installation engineering depicted on Figures 2-2 and 2-3 of the module are undergoing consolidatio l This is caused by the decreasing number of personnel required as j hardware installation nears completio . .
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Inspector Certifications Module Table 2-1 summarized inspector qualification certi-fication requirements for the hardware covered by Module .
These were compared with those listed in Unit 1 Module 6 and found to be similar. Penetrations have been added to the Unit 2 list. Credit was taken for previous NRC inspection of Inspector Certification ,
(2) Inspection Results i
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The examination did not disclose significant verification errors or a basis for programmatic concer Followup or additional <
evaluation of Module Section 2 is not require c. Section 3 - Commitments (1) Review Introduction and Section Examination <
This section of the module describes the commitment selection I and sources along with containing a list of commitments and -
implementing document They are displayed in two matrice The first is entitled "Commitment Matrix" and lists 197 commit-ments by the Georgia Power Company for VEGP Unit 2 along with the source document reference for each commitment. The second is entitled "Implementation Matrix" and lists source documents and requirement features referred to within each commitment along with the document reference where the feature has been implemented. An identification review was made to verify if the commitments listed in the Unit 1 Module 6 had been accurately carried forward into Module 6 for Unit 2. A sample was selected and reviewed to verify the proper implementation of the listed commitments. This was accomplished by examining the sample to check the commitment source (typically the FSAR and referenced standards) for the exact requirement and to verify (within the *
documentation listed in the Implementation Matrix) that the ,
requirement was accurately carried throug (a) Identification Review !
The examination of Section 3 started with a reading of the ,
module for content. The commitment listings of Section 3 i of the module were compared with the corresponding listings '
of Unit 1 Module The following anomalies were :
discovered: l
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Four commitments (1552,1553, 4688, and 1253) which !
appeared in the Unit 1 matrix were not listed in the !
Unit 2 matri l
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Eleven commitments (1491, 264, 2399, 2445, 3527, 2319, i 2320, 4880, 4881, 2905, and 4289) which were 11sted in l the Unit 2 matrix which were not in the Unit 1 matrix.
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During the assessment of the Module 6 Section 6 l
inconsistencies were noted between the number of I design and construction commitments in the matrix and l
the numbers quoted in the Module 6 Subsection 6.4.1.1.
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These were 197 design and 12 construction, and 186 design and 16 construction commitments, i respectivel :
All of the 15 commitment anomalies we.e resolved during the inspection period. The disposition of the four commit-ments, which were in the Unit 1 matrix but not in the Unit 2 matrix, was as follows. Commitment 4688 was in the l Unit 2 implementation matrix but had been inadvertently
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lef t out of the commitment matrix. Commitments 1557 and -
1553 were moved to Module 20 because their scope was the !
protection syste Commitment 1253 was deleted because [
it's requirement had been deleted from the FSAR Subsection ,
3.11.8.1-2 by Amendment 2 The disposition of the 11 commitments which vtre in Unit 2 i
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but not in Unit 1 is as follows. Commite.it 2905 was included in the commitment matrix but wa', inadvertently ;
l 1 eft out of the implementation matrix. This cemmitment was "
I generated for this module where previously h had been f contained (in a general way) in the Unit Qualt a Assurance l l program General Appendix Commitments 4880 and 4881 were ;
moved from Unit 1 Module 20 into Unit 2 Module 6 but were ;
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inadvertently lef t out of the implementation matri The
- remaining 8 commitments were moved from Unit 1 Module 4 to l Unit 2 Module 6. All commitment moves between modules were !
verified by the NRC Inspecto l
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l The Commitments 10, 31,182, 754, and 2968 were found to l l
have been both design and construction commitments but were l l
not indicated as being construction on the commitment ;
matrix. Also, Commitment 182 was not indicated as being >
construction on the implementation matri ,
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(b) Implementation Review. Two of the 15 anomalous commitments '
listed above in Subsection 3.c.1.(a) were selected for l verification. An additional 2 were selected independently l from the commitment matrix. The examination of this sample ;
consisted of: ;
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Verifying correspondence between the Module Commitment ;
Matrix and the Module Implementation Matrix for each
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commitment.
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Reviewing the referenced commitment source-documenta-tion for a clear statement of requirement for each commitment within the sampl Checking the document listed in the Module Implemen-tation Matrix for proper first and second order implementation of the requirements embraced by the -
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commitmen The commitments listed in the Unit 1 Module 6 had been extensively examined by NRC during the review of that module. Accordingly, a detailed examination of commitments carried forward from that module into the Unit 2 Module 6 was limited to a sample of tw (2) Inspection Results lhe individual commitments reviewed along with the review results are listed in Table 1 of this report, i
The examination of Module Section 3 did not disclose substantial verification errors, other than noted above, or programmatic concerns. Followup or additional evaluation is not require , d. Section 4 - Program Description
(1) Review Introduction and Section Examination 4 This section of the Module describes work process and control for the design and construction of hardware covered by the module. This is supplemented by documentation listings, flow charts, and an outline of program changes. The section was
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examined by the inspectors for content, background for the 1 review of later sections (especially Section 6, Program Assessment) and for the accuracy of the information presented.
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A detailed examination of the section was not made by the inspectors since the material contained was largely deacriptive and not in the nature of an assessment. Credit was taken for the examination of similar material during the Unit I revie l (a) Design Subsection 4.1 was examined for content and general agreo-ment with information developed during past NRC inspec-
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tion In addition, the flow chart referenced in this subsection was reviewed for logic and accurac The
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foregoing provided general agreement between commitments and the activities covered by the Design Progra ,
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(b) Construction Subsectinn 4.2 was examined for content and general agree-s ent with information developed during past NRC inspec-ions. The flow charts referenced in this subsection were reviewed for general logic and compared with programmatic documents for accuracy. No anomalies were apparent in the flow chart (c) Program Changes Subsection 4.3 outlined program changes involving activi-ties directly related to Electrical Equipment that had occurred since the Unit 1 Readiness Review. Two of the four items concerned procedures and personnel and another was the initiation of the component removal program. The remaining item was the addition of interdiscipline separa-tion criteria to upfront installation and inspection activities in order to place less reliance on after-the-fact finalization walkdown This last item was not discussed in the referenced text locatio Review of the documentation covering these changes did not disclose error or ambiguit (2) Inspection Results The Section 4 examination revealed that a discussion of the item above, interdiscipline separation, was not in the text. The RRT counterpart indicated that this had been inadvertently edited out during document review. The NRC Inspector did not consider this to be a serious detriment to the section. No further i
programmatic concerns were identified. Followup or additional evaluation is not require e. Section 5 - Audits J.nd Inspections (1) Review Introduction and Section Examination l
This section provides a discussion of the audits of Moduit 6 related activities and documents made by GPC and BPC along with the inspections made by HRC. The audits and inspections performed subsequent to the Readinass Review of Unit 1 Module 6
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review were those reported. Also included was a discussion of the Unit 1 Readiness Review findings and certain conditicns iiscovered since the Unit 1 Readiness Review that wore report-ble or potentially reportable under 10 CFR 50.55(e) or 10 CFR 21.
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'l It was noted that Unit 1 General Appendix I entitled "Project Quality Assurance Organization" provides the description and validation of the various audit programs used at VEGP. Indi-- '
vidual audits of design and construction activities had been .
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screened by the RRT for items applicable to Module 6. Section 5
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of Module 6 provides specific information relative to these in Module Tables 5-1 through 5-4, These tables were reviewed and sampled in order to assess the thoroughness and accuracy of the
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j (a) QA Audits l Table 5-1 is a list of the audits performed by GPC and BPC.
- GPC performed fourteen audits and listed eight findings
- specifically on Module 6. BPC made three general audits
- which included three Modula 6 items. The NRC Inspector -
sampled four GPC audits, two which had resulted in findings
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and two of which had not. Some of the sampled items had -
- ended in a finding which 1 cad to corrective actio The audit sample-items were found to have been closed satis-j factorily and are listed on Table j
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l (b) NRC Inspections
An updated NRC Region II Outstanding Items List dated l
May 2,1988 was compared to the Module 6 Table 5-2 list of i NRC Inspecti m to verify completeness of the table, ,
CDR 87-140, which applied to Module 6 but was not included ,
in Table 5-2, was found to be addressed by the licensee's ;
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Deficiency Evaluation Report (DER) 18 !
(c) Reportability Evaluations I i
Table 5-3 contains a list of 11 Unit 1 Module 6 deviating *
conditions applicable to the scope of this module which !
required formal evaluation for reportability using the DER i procedure. The NkC Inspector reviewed two items from this I table, one which had been judged to be reportable and one t which had not. These were evaluation numbers 108 and 125 i respectively. Both items had been processed in a satisfac- i'
tory manner, although the DER-125 (CDR-M103) was still cpen. The NRC Inspector verified the licensee's reporta- !
bility decision for both of these item l The DER 46 (CDR-M53) was closed out prior to the modula !
cutoff date of July 1, 1987 and did not appear in ;
Table 5-3. This DER package was examined to obseive the :
corrective process where design had not provided adequate i protective relaying for a penetration. Both penetaations !
and protective relaying are cart of Module 6, although were i not indicated as so in Module Section 1. The review did <
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j The NRC Inspector investigated omission of DER-186 l (r0R-M140) from Table 5- The RRT. counterpart indicated that this OER was generated by one of the RRT findings
' af ter the module cut off date of July 1,1987. The status
! of DER 186 (CDR-M140) is that the second Wyle Laboratory i report on separation has been submitted to the NRC for j approval of reduced separation. NRC evaluation of this
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report is still underwa The- itcensee has already :
redesigned the documentation to incorporate the separation criteria as allowed by both Wyle Laboratory reports in anticipation of approval of the second Wyle repor '
c 1 Not including DER 186 in Table 5-3 is not considered to reflect incomplete reporting within the Module. Further
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I identification for NRC followup is not required since the
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! (d) Unit 1 Finding Followup .
1 t i Table 5-4 listed 71 Unit I audit findings which were - t
! followed-u The RRT reported the examination of a sample
of 34 to assess their securacy and adequacy. A sample of i j three of these Unit 1 findings were reviewed by the NRC .
4 Inspector to verify Unit 2 followup action. The followup !
j action reflected by the sample was satisfactor Sample .:
! details are listed in Table 3 of this repor !
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A review was made of a sample of six equipment document l
) files selected from the list of Module 6 equipment. Of !
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particular interest was equipment which had been removed *
to expedite Unit 1 startup and how the restoration was- !
f perforned. The file on the 480 Volt Motor Control Center ,
(2-1805-53-B88) was examined to assess the process used by i
) the licensee to track removed equipment and the restoration !
'j process. The sample documentation did not disclose error ~
and the restoration process was satisfactor The Quality
Assurance audit book was reviewed in order to assess the ,
j RRT checksheets used during the review of the audits. The ;
] equipreent document files checked and verification results ,
I are listed in Table 4 of this repor l j (2) Inspection Results ;
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The examination did not disclose significant verification errors
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- evaluation of Section 5 is not required other than for CDR 87-140 ;
j listed within the NRC Outstanding Items File, j l
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4 f. Section 6_- Program Assessment (1) Review introduction and Section Examination .
This. section of the module describes the program developed and j actions performed to ascertain whether the design and construc- i tion activities related to Electrical Equipment for VEGP Unit 2 !
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have been adequately controlled in the manner that implemented 1~
licensing commitment In addition, it. describes the program used to ascertain whether the corrective actions resulting from
the Unit 1 Readiness Review were applied to Unit 2, and to .
- verify that design and construction activities conformed to
project procedures and design requirements. Subsections were '
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prvvided for program description, summary and conclusions, '
i assessment activities and results, along with finding The i i licensee review t5ecifically was intended to assure that:
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Project procedures implemented licensing commitments, j
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Actions taken to resolve problems identifiw during the l J Unit 1 Readiness Review have been effective in preventing -
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, recurrence in Unit !
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Program and organizational enhancements made for Unit 2 i j have maintained the quality of the design and construction t
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Design completion and design change activities complied .
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Installed hardware complied with engineering and vendor t q
requirement ;
This section of the module presented most of the new material (Unit 2 specific) and reflected that portion of the licensec's
, review of matters not covered by the earlier review of Unit !
- Accordingly, this section received a detailed examination by the l NRC Inspector l (a) Introduction, Program Description and Summary
- i Subsections 6.1 and 6.2 were read for content and to assure that they were in consonance with material presented
earlier in the module. These subsections are largely descriptive and were found to agree with information presented in other sections of the module. Subsection j t summarizes later portions of the module, viz. Sections 6.4, i j 6.5, and Error in the summary was not found.
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(b) Assessment Activities and Results The licensee assessment activities were divided into three parts at follows:
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Part 1 - Commitment implenientation and Unit I finding followu Part 2 -
Design and Construction Programs and activitie Part 3 - Design and Construdtton Completio The licensee reviewed the information presented in Section 5 of the module (Audits and Inspections) along with NRC reports of inspections at four non-GPC plants to identify new areas of industry concern that might have been overlooke The result of the foregoing was an assessment plan detailed in Section 8 of the module and reported on in Subsections 6.4 and 6.5 of the modul The NRC Inspectors examined a sample of the licensee's verifications in each of the three assessment activity parts along with selecting an independent sample of examination items in assessment Parts 1 and '
(2) Part 1 Examination Part 1 of the licensee's assessment was divided into verifica- ,
tion of (1) the commitments listed in Section 3 of the module !
and (2) followup of the Unit 1 Readiness Review Finding !
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(a) Commitment Verification The RRT found that the design and construction licensing commitments had been appropriately and adequately imple-mented with one exception, 2RRF-006-011 Level I. Two design findings, 2RRF-006-008 and 2RRF-006-013, both i
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Level III, identified inconsistencies in the method of specifying references to FSAR commitments within the design criteri The construction commitments findings 2RRF-006-001 (Level II), 2RRT-006-002 (Level III), and 2RRF-006-003 (Level III) were written to identify require- l ments which were not included in the procedures.
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Finding 2RRF-006-011 (Level I) involved differences t
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between the reduced separation criteria (based on testing) presented in the FSAR and that presented in the Construction Specification X3AR01. The deficiency noted in this finding had previously been reported to the NRC in the OER 186 which was scheduled for final evaluations by March 1, 198 . .
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The NRC Inspectors interviewed licensee personnel and preliminarily reviewed applicable documentation to verify the corrective action taken on this findin The com-plexity of the separation criteria and the many supporting documents precluded verification by the Inspectors during the onsite visi No documentation was offered by the licensee that described differences in the criteria as reflected by the various document The difficulty noted in recognizing the differences, in verifying the correct-ness, and in proving the assertion of a conservative program operation together resulted in a contribution to Unresolved Item 425/88-26-01 detailed in the Unit 2 Module 17/19 Repor The NRC Inspectior reviewed findings 2RRF-006-001, 2RRF-006-003, 2RRF-006-008, and 2RRF-006-013, and the licensee's responses to them in detai The inspector verified that these RRT findings were adequately ,
incorporated into the Unit 2 commitments.
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A sample of two commitments was selected from the commit-ment matrix in Section 3 of Module 6 for detailed NRC revie In addition, a comparison was made of the Unit 2 and Unit I commitment matrices to determine if all applic-able commitments were contained in the Unit 2 matri As detailed in Subsection 3.c.(1) of this report, 15 commitments were found which appeared to be new or were missing. These additional 15 commitments were reviewed to verify their origin or present locatio Commitments transferred from other modules into Module 6 were subject to the same probability of having been sampled during the Unit I review as any other commitment. For that reason
the 10 commitments transferred into Unit 2 Module 6 were not identified as needing special samplin There were discrepancies between the number of design and construction commitments referenced in this subsection of the module and the number in the matrices. The discrepancy was due to improperly marked matrices and an arithmetic erro The document sample and examination results are listed in Table 1 of this repor The examination of the implementation of the commitments resulted in no NRC findings. However, the commitment and implementation matrices contained errors, omissions, and unexplained additions. These items were all satisfactorily resolved during the inspection perio ,
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(b) Unit 1 Findings Followup The RRT objective of the Unit I finding followup was to determine if the corrective actions taken on these findings were sufficient to prevent their recurrence in Unit The RRT Unit 1 finding followup consisted of compiling a list of 71 Unit 1 findings which were applicab*,e to Unit This list was submitted to the VEGP Project Engineering organization who then determined if:
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This was an isolated occurrence
- The Unit 1 corrective action romained in place l
- The Unit I corrective action changed but was acceptable
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The corrective action has not been entirely effective The RRT then sampled the Project Engineering Organization work to validate their results. The NRC Inspector selected -
a random sample of three firdings from the Module 6 Table 5-4. These were reviewed in detail to verify the project's disposition of them. Verification e*ror was not I found in the review of the sample. Table 3 of this report contains details of the NRC sample and examination result (3) Part 2 Examination The RRT objectives of Part 2 of the assessment were to examine the in process activities associated with design procedures and construction processe (a) RRT Assessment The RRT reviewed the design programs used to control design changes and calculation development. Field Change Requests (FCRs) and Design Change Notices (DCNs) were evaluated to assess compliance with applicable procedures and licensing commitments and control of design changes. The review i included an evaluation of interdiscipline review, evalua-
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tion of ef fects on FSAR statements, incorporation in drawing within procedural limits, end impact on previous l installations gnd revision of calculations to support the
! change. The above attributes of the design change program I were assessed and determined to be acceptabl Finding i 2RRF-006-012 (Level III) identified instances of failure to l
follow procedures when assigning an approved disposition to FCR _ - _ _ _ _ - - _ - _ _ _ _ _ _ _ _ .
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Calculations were assessed to evaluated compliance with project calculation control procedure The review addressed conformance to design criteria, reference to appropriate codes and standards, compliance with guidelines for documenting input data, and proper entry in control log The calculations were determined to be acceptabl '
Finding 2RRF-006-010 (Level III) identified a discrepancy in the listing schat: ing of calculations requiring revie Both of those RRT findings were reviewed by the NRC Inspector and it was verified that appropriate actions had beer taken to correct these deficiencie The construction portion of Part 2 reported the examination of the process for component removal / replacement, changes to equipment internals performed under the Field Equipment Change Order (FECO) program, in process equipment installa-tion, and changes resulting from Unit 1 firdings. The RRT review produced no findings for this subsectio ,
(b) Component Removal Activities The NRC examination of the in process activities consistea of reviewing five complete equipment document files. This sample contained, where appropriate, FCRs, DCNs, FECOs, and Component Removal Special attention was paid to the methodology of component removal and reprocurement where electrical equipment components were obtained from Unit 2 to support startup activities in Unit The sample revealed many instances where the components were found to be removed and the component removal documentation was performed after the fact. The NRC inspection verified that the sampled in-process activities documentation and methodology were sati s f actory. Table 4 of this report contains the list of the five equipment document files reviewed and the verification result (c) Protective Engineering Activities Traditionally, the task of Protective Engineering, also identified as Protective Relaying, has been accomplished by the GPC System Protection and Control Department. This department's QA program defines the responsibilities as follow The System Protection and Control Department h responsible for the development and implementation of the votection policy for the GPC transmission system, generating plants, and distribution substantions. The Protection Engineering
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Section of this department is responsible for carrying out this policy through specific design activities for all.GPC generating plants, including nuclear plants. These design activities include:
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Review of architect-engineer preliminary drawings to ensure that GPC protection policy has been implemente Review of architect-engineer final drawings to verify that protection design meets GPC standard Development of major tripping and control scheme Selection of relay and manufacturer, relay type and model, and specification of CT and PT ratio Calculation and documentation of protective relay settings and their tripping function The design function of the System Prntaction and Control -
Department was reviewed during the Readiness - Review Module 6 field inspection. Discussions with responsible System Protection and Control Department personnel were held to clarify various items identified in the QA program such as personnel qualification, documentation control, drawing approval and document revision contro During these discussions a deficiency noted earlier by the inspector was confirme The Protection Engineering Group which is part of the System Protectior and Control Depa-tment has the responst-bility for the design of the Relaying Data Sheet However, this design function is not identified in the FSA Subsection 1.4.5.3 of the FSAR specifically assigns design, engineering, and procurement responsibility of the standard power block to the Architect / Engineer (Bechtel PowerCorporation). This includes all systems, equipment, and structures for design and specification. There is no provision for BpC to review the set points specified on the Relaying Data Sheets designed by the Protection Engineering-Grou The foresaing deficiency is identified as URI 425/88-27-02, Incorporate Protective Relaying Design into the FSAR.
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(4) Part 3 Examination The RRT objectives of Part 3 of the assessment were to evaluate the design complet.on process by examining the incorporation of material into documents and drawings, and evaluating the construction completion by physical examinatio The same equipment sample examined during Part 2 was used for the sample during Part 3 by the RR (a) RRT Assessment The RRT assessment determined that the design completion activities evaluated were performed adequately and in accordance with applicable procedure One finding, 2RRF-006-007 ('.evel II) was writtan to identify a calcula-i tion that had not been updated with available data, i The RRT assessed the installed equipment and penetrations for installation attributes directly related to licensing commitment requirement Those were:
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Attachment to foundatio Configuratio Clearance from adjacent components or structure Internal separatio Installation of replacement component Inspector certificatio Conformance of inspector document to hardwar No findings were made by the RRT pursuant to their review of construction completion The NRC examination of the design completion included reviewing the same five complete equipment document files examined in Part 2. The documentation was found to be complete including Maintenance Work Orders, QA Inspection and drawings. The NRC inspection verified that construc-tion and design completion were satisfactory within the sampl Table 4 of this report contains the list of equipment document files reviewed and the individual verification result .
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(b) NRC Independent Sample Verification An independent sample of 12 components was selected by the NRC Inspector for field walkdown. The sample was selected to provide a broad range of hardware types and Category I locations. The details of the foregoing walkdown are shown in Table 5 of this report. The NRC walkdown included three components which had been part of the RRT sample and 12 new component Each piece of equipment was inspected for specified checklist items that were selected to reflect problems commonly associated with the individual hardware categor Emphasis was placed on physical attributes such as component clearances, cable and cabinet labeling, support welds, cable entry into cabinets, conduit sealing, and separation of cabling from different train The walkdown resulted in IRO 99-27-01 made up of four different elements and detailed belo Color Labels - The external labels on the electrical equipment associated with a train is required to be color coded according to DC 1816 Rev. Brown, green, blue, and yellow are to correspond to trains A through 0 respec-tively. Two examples were found of equipment which had a black external label in addition to the appropriate colored labels. After an investigation, the Operations organiza-tion reported that the deficiency was common in Unit The RRT counterpart reported that some of the black labels were vendor mount 6d because of a deficiency in their specifications. The licensee is continuing to investigate the causes of the mis-labelin Cable Drip-Loop - The 480 Volt MCC (2-1805-b3-BBB) was found to have cables routed from one cable tray into the ccoinet without a drip-loop in a room containing a sprinkler system. If the sprinkler were activated water would enter the equipment via the cables, l
Regulating Transformers - The regulating transformers at full load conditions have high exterior temperatures. In many cases, junction boxes are mounted above the trans-former bank and are connacted to the transformers by cable enclosed in jacketed flexible metal condui Inspection of transformer bank 2-1807-Y3-RX7 revealed that one of the conduits was touching a transformer case and the conduit jacket appeared to be melted where contact was being made to the transformer. The conduit and junction box was hot i to the touch. There is a concern that the conduit can '
channel heated air up into the junction box where transi-tion is made to low temperature wire, and that this wire's ambient temperature specificatica may be exceeded. This possibility also exists when the conduit was not touching a transforme '
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i Seismic Clearance - The vertical clearance between the top -
hat on the 125 Volt de panel 2-1806-Q3-DA1 and the cable: -
tray support arm was . observed to be less than the 1-1/2 inches specified in the X3AR01 Appendix SC, Seismic ,
Criteria Rev 4 t Credit was taken for a previous NRC . inspection of the Module 6 electrical equipment which had been released for -
functional testing. This inspection was of 15 components I'
and included examined of completed work, work in progress, and the QC records' associated with receiving, storage, handling, and installation of the equipmen The !
referenced NRC Inspection is Report Nos. 50-425/88-05, ;
January 198 l (5) Inspection Results !
The examination of the program assessment section of Module 6 '
resulted in two URIs as follows: l (a) 425/88-27-01. This is comprised of four items found during -
f the NRC independerit walkdow (
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The licensee has used unspecified colors on the external cabinet labels on some electrical equipmen Black labels are found on equipment which is otherwise color coded for the particular trai No drip-loop was provided in .some of the cables entering Cabinet 2-1805-53-BBB in a room contain-ing automatic fire protection sprinkler The licensee has not provided assurance that there will not be excessive heat buildup in the junction boxes above the Regulating Transformers. The cable conduit could be acting as 'a convection channel for hot air into the junction boxes. The condition could be aggravated in transformer bank 2-1807-Y3-RX7 where the conduit is in physical contact with the hot transforme he vertical clearance between the 2-1806-Q3-DA1 cabinet and the cable tray support arm is less than the specified 1-1/2 inche (b) 425/88-27-02 This was found during the NRC review of the Protective Engineering Program and activities. The GPC Protection Engineering Section designs the reley protection system for L -
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l all the GPC generating plants, including the Relaying Data l Sheets at VEGP Unit 2. This design function is assigned to l the Architect / Engineer (Bechtel Power Corporation) by the
FSAR, and no design function is icentified for GPC.
l (c) Commitment Verification. During the assessment of the Module 6 Section 6, inconsistencies were found between the number of comn'itments quoted in the text and those l listed in the matrices in Section 3 of the module, as detailed in Section 3.c.1(a) of thts report. In addition
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there were sume typographical errors. Followup or addi-tional evaluation is not indicated for the commitment i verification errors.
1 Section 7 - Assessment of Module Adequacy (1) Review Introduction and Section Examination Section 7 of the module contains certifications by the following:
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Project Engineering Manager l
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Vice President Vogtle Construction
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Readiness Review Board Chairman l These certifications reflected review by upper management of l the module and assurance that it accurately reflected both the I review made and the plant / programs reviewed by the RR The l Readiness Review Board certification added assurance that corrective actions, then proposed, were acceptable and would bring Electrical Equipment into full FSAR compliance upon implementatio The Inspectors examined the certifications and considered them to reflect the a:;tions of appropriate managers who had the responsibility to closely monitor the Readiness Review and to assure its qualit (2) Inspection Results The examination did not disclose error or perfunctory certifica-tion. The certifications given are supported by the reselts found in the NRC examination of the other sections of the modul Followup or additional evaluation of Module Section 7 l
is not required.
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h. Section 8 - Assessment Plans and Checklists
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(1) Review Introduction and Section Examination This section of the module provides the licensee's formal plan for the documentation and hardware to be reviewed for Module The plan details the review approach including objectives, scope, assessment, and general instructions. An extensive set of checklists covering 12 designated review areas included:
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Design Commitment Implementation
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Construction Commitment Implemer.tation
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Design Change Control
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FECOs
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Calculations
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Inprocess Installation and Corrective Actions j
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Installed Equipment, Installed Penetrations
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Document - Equipment, Penetrations
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Incorporation of FCRs DCNs, CSCNs, Finalization Walkdowns
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System Turnover /RFT
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Section 8 of the module was read for content. The check lists were examined for relevancy to the objective and scope of the i assessment pla Section 6 of the module was checked to verify
- that all aspects of the assestment plan were followed in the execution of the Readiness Review. The completed Section 8 check lists were spot checked in the RRT review files to assure that the check lists were used, that re'.2vant information was obtained/ analyzed / entered and that all cases of deviation were pursued to an adequate resolution / reportin ,
(2) Inspection Results
The Section 8 examination did not disclose substantial verifica-i tion errors or the basis for programmatic concern. Followup or !
additional evaluation of Module Section 8 is not require '
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{ Review Findings lwo findings were identified during the NRC evaluation of the module. All j of the deficiencies noted within these findings are considered to have
minimal safety significance at this point of review but should be eval-
- uated further to preclude safety problems. These ~have been identified >
j as URIs based on the nature of the followup action required. They will be addressed by. the NRC during the routine inspection program unless
]j designated as. closed in the finding. These URIs are as fo11cws:
- /88-27-01 This was made up of four items found during the NRC independent walkdow l
- The licensee has used unspecified colors on the external cabinet i labels on some electrical equipment. Black labels are found on j equipment which is otherwise color coded for the particular train.
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No drip-loop was provided in some of the cables entering Cabinet 2-1805-53-BBB in a room containing automatic fire-protection a
sprinkler I l - The licensee has not provided assurance that there will not j be excessive heat buildup in the junction boxes above the
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Regulating Transformers. The cable conduit could be acting as a convection channel for hot air into the junction boxe The condition could be aggravated in transformer bank 2-1807-Y3-RX7 where the conduit is in physical contact with the hot transforme The vertical clearance between the 2-1806-Q3-DA1 cabinet and the cable tray support arm is less than the specified 1-1/2 inche /88-27-02 This was found during the NRC review of the Protective Engineering Program and activitie The GPC Protection Engineering Section designs the relay protection system for all the GPC generating plants, including the Relaying Data Sheets at VEGP Unit 2. This design function was assigned to the Architect / Engineer (BPC) by the FSAR, and no design function was identified for GP . Conclusions The NRC has reached the following conclusions for Electrical Equipment at VEGP Unit 2 based on the review of Module L
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a. Summary of Specific Cone'tusions l The module sections have been determined to be acceptable with the j exception of items and areas discussed earlier in this report. A
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summary of the report comments for each Module 6 section is as follows:
(1) Section 1 - Introduction The boundary between Module 6 and the related modules is l generally clear as defined in Section 1. Minor clarification of the data presented was required for definition completeness.
The module Organization and Project Status were correct as of
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the date of module publication. Electrical Equipment installa-I tion was essentially complete as of the site visit and was about J 90% energize ] (2) Section 2 - Organization and Division of Responsibilities-
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The organization description and responsibility presented in
Section 2 of the module were reviewed and ytrified as being j correct as of the time of modult, preparatio Some minor j changes have taken place during the interim to consolidate i design and installation functions within the site engineering l office. This is an adaptation to the reduced staffing require-
- ments as construction nears completion.
] (3) Section 3 - Commitments i
- The es mitments listed in Section 3 were reviewed to determine
- changes from those itsted in the Unit 1 Module Fif teen of i 197 gave evidene, of change or difference from the Unit 1
review. Examination of these was made to assure correct origin
and location. Two other randomly selected commitments were j examined for source and implementatio Verification error was
- not found in this sample, f (4) Section 4 - Program Description The design program description pr3sented in Section 4 was reviewed and verified as being correct (5) Section 5 - Audits and Special Investigations t
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The audits and special investigations information presented in l Section 5 was reviewed and verified as being correct.
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(6) Section 6 - Program Verification The program assessment reported in Section 6 of the Module was verified as being generally adequate. The NRC review disclosed five areas of incomplete verification which resulted in URIs 88-27-01 and 88-27-02. These involved label color coding, compnnent clearances, cable drip-loops, potentially overheated junction boxes, and deviation from FSAR responsibility commit-ment for protective relaying desig The nine findings by the RRT were found to be clearly stated, adequately documented, and properly recognized by managemen (7) Section 7 - Assessment of Module Adequacy ,
The certifications presented in Section 7 of the module were '
found to reflect action on the part of the cognizant managers having responsibility to assure the adequacy of the Readiness Revie (8) Section 8 - Assessment Plan and Checklist
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The assessment plan presented in Section 8 of the module was l verified as being adequate for the purpose and being followed substantially during the Readiness Revie b. General Conclusions
1 The examination performed by the NRC indicated that GPC management I
supported the Readiness Review by active participation and adequate resources. No evidence of coercion, or attempt to dilute either l the effort or the findings, was disclosed. The RRT displayed the I
requisite competence and professionalism for a review of this natur The licensee's program was comprehensive and provided adequate assurance that the plant Electrical Equipment will perform in accord with NRC requirements and FSAR commitments. Possible exception i to this are the open Unresolved Items (URI-425/88-27-01 and I
URI-425/88-27-02) resulting from the NRC examination and which are l listed in Section 4 of this repor It does not appear that the foregoing represent significant program-matic weakness provided that additional licensee response is sufficient to enable closure for currently open NRC item for VEGP Unit 2. Pending resolution of the open items identified above, the NRC concludes that the GPC program for Electrical Equipment complies with NRC requirements and FSAR commitments. This conclusion is based on information currently available to the inspectors and reviewer Should subsequent contradictory information become available, it will i
be evaluated to determine what effect it may have on the above conclusio '
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6. Exit Interview The review scope and findings were summarized on May 26, 1988, with those persons indicated in Section 1 of this repor The inspectors described the areas inspected and discussed in detail the inspection findings listed below. The licensee did not identify as proprietary any of the material provided to or reviewed by the inspectors during this inspectio Item Number Description and Reference 425/88-27-01 Non-specified color coding of cabinet labels, inadequate cable drip-loops, inadequate component clearance, and potential junction box overheatin /88-27-02 Unauthorized relay protection desig Dissenting comments were not received from the license . Acronyms and Abbreviations BPC -
Bechtel Power Corporation CCP -
Change Control Package CSCN -
Construction Specification Change Notices DC -
Design Criteria DCN -
Design Change Notice DER -
Deficiency Evaluation Report FCR -
Field Change Request FECO -
Field Equipment Change Order FSAR -
Final Safety Analysis Report Gl'C -
Georgia Power Company HOE -
Home Office Engineering IEEE -
Institute of Electrical and Electronic Engineers NRC -
Nuclear Regulatory Commission PFE - Project Field Office QA -
Quality Assurance QC -
Quality Control RFT -
Request for Turnover RG -
Regulatory Guide RRT -
Readiness Review Team URI -
Unresolved Item VEGP -
Vogtle Electric Generating Plant i
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I IAELE CCAMITMtmi ylu!FICATICa Ref crent e Conus 4tsen1 Scmsrce Verifled Verified
_tanw and Settton Causttmant %Aject ist Order 2ndOrq (krument* Doramaret Ontweent / Feat ure verified Orista/tocatson, 82 f 5AR s.3.1. Cable routlag--cable 6 inch separatson er barriers are Yes Tes --
separation within panels and provided control board AR 5.4. Des 19 e base TMI Act6on Itco ll k.3.2% -- --
tes f rum Nsule 4 82$3 Deleted from 80P EQDP sununary--9ua IEEE 331 (daughter std.) Yes T5AR 3.11.8.1 2 segecace. L ic(tr kal
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Yes deleted penetratten assemblic i 1268 F5A6e 3.13. Oval, tests and analysts litt 323-1974 Para. 6. Tes -- ..
accept. cret. env. gua safety rel, egulpmen i 1491 f5AR I.2.12.3.?! Slagte f ailure redundancy and ![1[ 279-1911 Tes ladependence criteria,
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Yes f rom Ndule 4 i
l 1%2 f5AR I.9.53 Appikation of stacle f ailure 1[it 379 1972 --
criteria to protection system,
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8%3 T5AR I.9. Application of single f allere lit [ 279-1971 Section !
-- +- To N441, 20 criteres to prote(teon systee.
l 2319 f 5AR IfA. Ausiliary f eestwater systes #G I.7%
gAyskal separat see between
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les f rom Ndule 4 electrical component T'At 104. Aus titary f eeduster system ![t[ 3a4
, physkal separation between
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Yes f rom Ndele 4 electrical companent TSAR 6.2 2.1.1.lG Centainment Cedlag system RG 1.32 safety desig Tes frein No.1e 4
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! 244% f5AR 6.2.S. (lettrtC hydrogen rec.emblae [ach unit powered from separate -- --
Yes f rom Ndule 4 11 tms and panel ,
290% I5AR 17. Ovality Assurance pro 9 ra aG l.3:s (8-11-12) Yes --
Yes generated 4239 estC Ques pressertier relief valu Pancred free Class 11 systems -- --
Corres. 02s.0.61 block valve level ladttato Yes f ree Gw34 ale 4 I
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1ACLE (centinued)
Ver t f 6ed Verified Referege (smanitaret 'Ar v te 1st Order 2nd Org verif 6cd Origin /twatton*
y,er _ and ' M on _ Commmitment SubjMt IW unret /f eat vre Doriament* Dorwment 4688 T'E 3.F.8. Setsmic subsystein analyses-- [f f ects combined 6 $R5$ -- -- Ves lef t out 3 components of earth swit io arthod analysis 4 835) I'W 32.1.4. Power $mpplies (ARMS). 1[ monitors suppIted by 1[ penser -- -- fes f rons Module 20 4383 T5AR 82.3.4. Power supplied ( ARW5), hon-1[ mnnitors supplied by fes from Mudule to t, ached instrument power 3521 f5AR 9.2.1-) k',CW (caponent dat Class l[ power supply -- -- Des from pkd.le 4 A das.h (--) in these colpens notes verification not made by mRC Inspecto .
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l TABLE GPC OVALITY ASSURANCE AUDITS VERIFICATION
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Audit Number Finding Number Subject Verified .
CP02-85/77 None Cannibalization of mechanical Yes and electrical components CP09-86/60 AFR 0995 Inverter welding to support Yes with shims SP01-87/17 None* Installation and protection Yes of electrical equipment for Module 6
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D SP01-87/37 None Module 6, Part 3, electrical Yes equipment installation Batteries in Rooms CR32 and CR37 had cell numbers in incorrect sequenc No finding was issued, A later specification change put this finding (AFR 1026) within tolerance, i
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TABLE VERIFICATION OF UNIT I FINDING FOLLOW-UP Finding Description of Finding Unit 2 Follow-up Action Verif,1 cation
__ Number IDR De valve specification Same as Unit 1-- Yes 22-F010 specified incorrect Specifications updatec minimuta de voltage and data reviewed to ensure proper performance RRF ED-T-19 contains Same as Unit 1--Procedure Yes 6-006 conflicting require- revised to agree with ment vendor requirement RRF Vendor and field Same as Unit 1--Wiring Yes 6-016 wiring of regulated analyzed, field wiring tranformers do not modified meet separation requirements i
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7ABLE AUDIT PACKAGE VERIFICATION TAG Number Equipment Description Verification 2-1805-53-BBB 480 V MCC Yes 2-1806-B3-BYB 125 V de battery and rack Yes 2-1821-U3-001 Safe feature system board Yes Train A 2-1806-03-DA1 125 V de distribution panel Yes 2-1818-H3-P29 Electrical penetration Yes l
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TAPtf NPC VERIFICATION AMD WALEDOWN LIST FOR fit (TirlCAL IQUIPMEni
[quipewet FRT ?RC IAC muc6er Descript ion 5mple g le pewi ts, 7 -17104-5 3-1483 Med voltage $WGR 2RB03 /
2 18fh-53-BUB 430 V MCC 2EEB / / Wrong color ID label, no cable drip-toop e
2 18t%-83-ETA 12% V dc battery /
2-lHim,-83-CEB Battery charger /
1-154-R3-878 125 V dc battery and rxk 20018 /
7- l Him-Q 3-DA l 125 V dc dist. panet / s Setssic clearance less than spectf 6 cat tons 2-lH01.-53-DA l 175 V dc dist. panel /
7-18fs,-53-D'A 175 V dc switch gear /
?-1801-Q 3.VI I 12% V dc dist. panel /
2 1801-0 3- V If, 175 V ac dist, panel /
7-1801-Y3-18t? Inverter /
7-lH07-V3-R11 Regulating transformer / Potential of overheated junct ton tes 7-IM18-T3-IIA Regulat ing transf ormer /
2 1816-03-007 [ lect . aus, teoard /
2-IBl8-H3-PI3 M.V. penetration / /
2-1858 H3-P?9 480 V penetrat ice s 2 1818-H 3-PVI Control penetrat+94 /
2-181A-H} P11 Instrumentation penetration /
7-lH21-U3-at! Saf ety feat. seg. board Trn. A /
7-Itt?S-13-EAB 13.8 h v RCP SWGR /
2-1801-QS-MLB Mata cntl. board Sect. A01 /
I 7-lM)l-U3-121 termination cabinet /
2-lM15-QS-LPA So!6d state protection systee /
a. Ver6fication error not found unless specfically liste l r
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