ML20197H017
| ML20197H017 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 12/19/1997 |
| From: | Johnson W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20197G998 | List: |
| References | |
| 50-285-97-19, NUDOCS 9712310164 | |
| Download: ML20197H017 (16) | |
See also: IR 05000285/1997019
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ENCLOSURE.2
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U.S. NUCLEAR REGULATORY' COMMISSION
' REGION IV .
Docket No.:
50 295-
' License No.: .
. DPR-40 :
Report No.:
50 285/97 19
Licensee:
Omaha Public Power District
' Facility:
Fort Calhoun Station
Location:
Fort Calhoun Station FC 2 4 Adm.
P.O. Box 399, Hwy. 75 - North of Fort Calhoun
Fort Calhoun, Nebraska
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. Dates: .
October 26 through December 6,-1097-
Inspectors:
W. Walker, Senior Resident inspector
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V. Gaddy, Resident inspector
N. Salgado, Resident inspector
. Approved By:
W. D. Johnson, Chlet, Project Branch B
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ATTACHMENT:
Supplemental Information
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- 9712310164 971219
ADOCK 05000283
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EXECUTIVE SUMMARY -
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l Fort Calhoun ' Station .
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' NRC Inspection Report 50 285/97-19
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Ooerations '
' in general, the conduct of operations was professional and safety-conscious.
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However, the inspectors identified an atmosphere which was nonprofessional in that
breakfast was being ~ cooked in the main control room (Section 01.2). =
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' A weakness existed in the' licensee's controls for replacing burned out light bulbs in
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- that, after initial shift supervisor approval was obtained, no further approval was.
required even if the approved work was delayed 'or_ several days (Section 02.1).'
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The licensee's containment integrity operating instruction'was inadequate in that all
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containment penetrations needed to establish containment integrity were not
. included in the operating instruction (Section 02.2).
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Improper installation of a locking device on a raw water intet valve would not have
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prevented manipuistion of the valve (Section 02.3),
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Maintenance
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The inspectors determined that the licensee had a program for addressing
Model CR120A relay f ailures (Section M2).
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Inadequate corrective actions resulted in licensee personnel failing to properly test e .
containment penetration (Section M8.2).
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Enoineerino
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-In 1995, licensee personnel f ailed to perform an annual evaluation of nonfuel it' ems
in the spent fuel pool (Section E1.1).
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' Elant Suncort
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Radiation protection personnel were prompt in resolving housekeeping deficiencies
inside the radiologically controlled area (Section R2.1).
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Reoort Details
Summarv of Plant Status
Tne Fort Calhoun Station began this inspection period at 100 percent power and
maintained that level until November 14,1997. On November 14,1997, power was
reduced to 84 percent to facilitate repairs on the leaking stator cooling water heat
exchangers. On November 16,1997, repairs were completed and a power ascension
began with 100 percent power attained on November 17,1997. The platit reme;ned at
100 percent power throughout the remainder of the inspection period.
1. Operations
01
Conduct of Operations
01.1
General Comments (717071
Using Inspection Procedure 71707, the inspectors conducted frequent reviews of
ongoing plant operations, in general, the conduct of operations was professional
and safety conscious; specific events and noteworthy observations are detailed in
the sections below.
01.2 Control Room Observations (71707)
The inspectors observed control room activities during the early morning hours on
November 21,1997. The activities ongoing when the inspectors entered the
control room included cooking of breakf ast in the main control room area. This
activity did not provide a professional atmosphere in the control room. in addition,
several nonoperations personnel were eating in the control room and were not
oiscussing official business.
The inspectors reviewed the licensee's conduct of operations procedure and
determined that failing to ensure that all control room business is conducted in such
a manner that neither licensed control room operator attentiveness nor the
professional atmosphere of the control room is compromised is a violation of
Standing Order SO O 1, " Conduct Of Operations," Revision 36,(50-285/9719 01).
As a corrective actior., the manager of operations issued a memorandum to all
operations personnel stating that all cooking of food within the main control room
was to stop. Food was to be cooked in the designated kitchenette area and no food
or drink was alloweo over the main control boards in the control room. The
inspector: concluded that these actions were appropriate.
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'02.
Operational Status of Facilities and Equipment
02.1
Reolacement of Eauinment Indicatino Lichts
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a.
lDweetion Scooe (71707)
The inspectors reviewed the licensee's procedural controls for replacement of
burned out indicating bulbs.
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b.
- Observations and Findinos
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On November 3,1997, an electrical maintenance technician was replacing a burnod.
out indicating light bulb on the 125 Vdc manual transfer switch panel for Diesel
Generator 2. This switch would be used to transfer de control power for the diesel
generator from the normal source, which is Battery 2, to the emergency power
source, which is Battery 1. During the replacement of the bulb, a fuse failure made
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the transfer to the emergency (alternate) supply source for 125 Vdc power
inoperable. Based on Technical Specifications, the diesel was still considered
operable without the alternate source.
. The inspectors questioned the licensee regarding why work was being performed on
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Diesel Generator 2 when Diesel Generator 1 was out of service and inoperable for
preplanned maintenance. The licensee stated that the indicating light bulb
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replacement had originally been scheduled and approved by'the shift supervisor for
October 31. The indicating light bulb replacement was postponed until November 3.
Based on discussions with the electrical maintenance supervisor, it was expected
that the electrical maintenance technician would notify the control rocm again prior
to beginning replacement of the indicating light bulb on November 3. The electrical
maintenance technician failed to notify the control room prior to replacing the
indicating light bu'b. The inspectors considered this to be a weakness in the
licensee's work cuntrol process.
A risk assessment had been performed as required by the licensee's procedures prior
to beginning work on Diesel Generator 1. However, no risk assessment was
performed taking into account t.
adicating light bulb replacement on Diesel
Generator 2. Based on the inspectors' discussions with the risk assessment
personnel, the indicating light bulb replacement would not have been approved for
performance on November 3 with Diesel Generator 1 inoperable.
The licensee made the following changes to preclude this from recurring:
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All electrical maintenance personnel were counseled on proper
communicatic as with the control room immediately prior to replacing
indicating lights.
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' A warning sign will be posted at the' door of any inoperable diesel generator z
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. to inform plant personnel that work on the operable diesel ganerator is
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Conclusions .
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A weakness existed in the licensee's controls for replacing burned c ,t adicating
light bulbs in that, after initial shift supervisor approval was obtained, rn. Nrther
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- approval was required even if the approved work was delayed for several days.
- 02.2; Containment Inteoritv Verification
a.
insoection Scone (717071
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,The inspectors performed a. verification of containment integrity.
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b.
- Observations and Findinas
On November 19,1997, the inspectors performed a verification of containment
integrity using Operating Instruction Ol CO 5, " Containment Integrity," Revision 11.
While venfying the integrity of electrical and piping penetrations in the main steam
room using Checklist Ol CO-5 CL Di the inspectors identified that E.ectrical
Penetrations G1 through G4 and Piping Penetration H1 were not included on the
checklist. This operating instruction was used to verify that containment piping .
penetrations were properly capped and that the nitrogen pressure of containesnt
electrical penetrations was greater than 20 psig.
The inspectors informed system engineering persennel of the observation. System
engineering determined that the panetrations had been included in Revision 10 of
the operating instruction. However, while reiormatting the operating instruction for
Revision 11, these penetrations were omitted. Revision 11 became effective on
April 2,1997 : Revision 10 of the operating instruction was last performed during
the 1996 refueling outage. The inspectors reviewed Operating Instruction OI CO-5
and noted that it did not have a performance frequency. lThe inspectors asked if.
Revision 11 had been used to verify containment integrity. The licensee stated that
Revision 11 had been used to verify containment integrity during reactor startup
from the steam pipe rupture in May 1997. The licensee stated that performing
Operating Instruction Ol-CO 5 was a condition for satisfying Surveillance
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Test OP ST-CONT 0002, " Secured Closed, Containment Penetration isolation
Verification ".-The inspector verified that Surveillance Test OP-ST-CONT-0002 was
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documented as completed on May 8,1997. Section C.5 of. Surveillance
Test OP-ST CONT 0002 states, in part, t_ hat, in preparation for reactor startup,
= containment integrity has been established in accordance with Operating
Instruction OI-CO 5. Although in May 1997 the licensee performed Revision 11 of
Operating instruction OI CO 5 to verify the referenced surveillance, it was
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inedequate in that it did not include four electrical penetrations and one piping -
penetration for containment integrity verification (50-285/9719-02).
As corrective action, the licensee initiated Condition Report 199701506 to
document the deficiency, initiated a change to correct the procedur6, performed a
review of Operating instr 0ction Ol-CO-5, and verified that the penetrations met their
acceptance criteria. The inspectors verified that no Technical Specifications were
violated.
c.
Conclusions
The licensee's containment integrity operating instruction was inadequate in that all
containment penetrations needed to establish containment integrity were not
included in the operating instruction.
02.3 Imorocerlv Installed Lockina Device on Valve HCV-2812C
a.
Insoection Scoce (71707)
The inspectors reviewed the installation of locking devices on valves in the high
pressure safety injection system,
b.
Observations and Findings
On December 3,1997, the inspectors verified that locking devices were correctly
installed on several valves in the high pressure safety injection system. However,
the inspectors identified that the locking device on Valve HCV-2812C (raw water
inlet to High Pressure Safety injection Pump 2C bearing cooler) did not appear to
provide a physical restraint to prevent operation of the valve. The inspectors
questioned the licensee on this particular locking device and the auxiliary building
operator was sent to investigate. The auxiliary building operator deterrnined that the
locking device on the valve was incorrectly installed and did not provide a physical
restraint to prevent operation of the valve. The licensee's immediate corrective
action was to reinstall the locking device correctly. The licensee initiated Condition
Report 199701642 to further resolve the issue. The auxiliary building operator
erified that the valve was in its required closed position.
The inspectors reviewed Standing Order S0-O-44, " Administrative Controls For
Locking Of Cornponents," and noted that Valve HCV-2812C was required to be
locked closed. The standing order also stated that locking devices shall at the very
least provide a limited physical restraint on the operation of the valve. Failing to
ensure that the locking device installed on Valve HCV 2812C provided the required
physical res%nt was a violation (50 285/9719 03).
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Conclusions
The inspectors identified a violation of the licensee's administrative controls for
locking valves. The locking device on Valve HCV 2812C was improperly installed
and would not have prevented manipulation of the valve. The licensee promptly
initiated corrective action to properly lock the valve.
07.1 Licensee Safety Canmittee Activity
During the inspection period, the inspectors attended several sessions of the safety
audit and review committee. This is the offsite safety review committee for the Fort
Calhoun Station. The sessions attended included discussions on:
An integrated assessment schedule with oversight provided by the nuclear
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safety review group,
Closeout of several action items from previous meetings, and
Review of the quarterly trend report for the third quarter.
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The inspectors observed that Fort Calhoun Station senior management was present
as an active participant at the safety audit and review committee meeting. The
inspectors determined that the reviews and root cause analysis af events completed
by the nuclear safety review committee were rigorous and self-critical. The
inspectors concluded that the self-assessment activities observed were effective.
II. Maintenance
M1
Conduct of Maintenance
M 1.1 General Comments
a.
Insoection Scoce (62707)
The inspectors observed all or portions of the following activities:
Repair of Charging Pump CH-1B,
Troubleshooting the bypass transformer for Inverter 1,
Oilleak repairs on Feedwater Pump FW-48,
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Thermography on safety-related breakers, and
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Cleaning raw water / component cooling water Heat Exchanger AC-1C.
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Observations and Findings
The inspectors found the work' performed under these activities to be professional.
.nnd thorough. - All work observed was performed with the work package present .
and in active use. Maintenance technicians were experienced and knowledgeable of--
their assigned tasks., The inspectors frequently observed supervisors and system
engineers monitoring job progress, and quality control personnel were present when
required by procedure.-
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In addition, see the' specific discussions of maintenance obseved in Section M2,
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Conclusions
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- The maintenance activities observed were conducted in a controlled and professional
manner.
Mi.2 - Surveillance Activities
a.
Insnection Scoce (61728)
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The inspecto'rs observed all or portions of the following surveillance activities:
OP ST DG-0002, Diesel Generator 2 Check," Revision 24;
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OP ST OF 3002, " Diesel Generator 2 Fuel Oil System Pamp inservice Test,
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Revision 15;
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OP ST-DG-0001, " Diesel Generator 1 Check," Revision 23; and
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OP-PM AFW-0004, " Third Auxiliary Feedwater Pump Operability
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Verification," Revision 12. .
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.Qbservations and Findinos -
b.
Surveillance activities were generally completed thoroughly and professionally. The
inspectors noted that. in all of the safety related surveillances observed, a test
monitor was present and actively involved in ensuring that procedures were
completed exactly as written and that any changes needed to ensure the accuracy
' of the procedures were identified for revision,
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Conclusions -;
The surveillance activities observed by the inspectors were completed in a controlled
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M2
Maintenance and Material Condition of Facilities and Equipment
M2.1 Review of Material Condition durina Plant Tout.s
a,
jnsoection Scoce (62707)
The inspectors followed up on the failure of a relay in the back panels of the control
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room.
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b.
Observations and Findinas
On November 29.1997, at 5 a.m., the opvators in the control room detected a
burning smell and immedia:ely began searching for the cause. The smell was
strongest in the walk-in back panel area behind Contro' Boards 1, 2, ar.d 3 in the
control room. While the operator was M the back panel, Relay A14A K11 caught
fire and was immediately extinguished with a carbon dioxide fire extinguisher. The
fire lasted less than 1 minute and the licensee entered Abnormal Operating
Procedure AOP-06, " Fire Emergency," for 1 minute.
The main equipment effected by the relay failure was the loss of pressurizer ievel
control when Pressurizer Channel X failed low. This caused the letdown isolation
valve to go closed and one of the two charging pumps in service to trip, as
expected. The operators then secured the second charging pump and letdown was
isolated for approximately 20 minutes while the operators transferred pressurizer
level control to Channel Y and then restored letdown. No power fluctuations were
observed and all equipment functioned as expected.
The inspectors discussed the relay f ailure with the system engineer and were
informed that the relay was a General Electric, Model CR120A,120 Vac,
continuously energized relay. The inspectors discussed with the system engineer
whether similar failures had beer, observed. The system engineer provided the
8cllowing information on the relays and f ailure history:
There are 596 Model CR120A relays installed in 1.ie plant.
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In the mid to late 1980's the licensee identified degradation from excessive
heat on Model CR120A relays in dc applications and began a systematic
replacement of these relays.
Criteria for selecting which relays to replace was: de application, normally
energized, critical quality element, and operational difficulties could be
caused by the failure of the relay.
165 relays were identified for replacement.
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Four Model CR120A relays in de applications and one relay in an ac
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application had f ailed in the last 3 years.
Additional data provided from the plant computer database indicated that a
total of 12 relays 10 de applications and two relays in ac applications had
f ailed since 1985.
The inspectors discussed with the system engineer whether the rotay which f ailed
would be sent out for a root cause determination. The system engineer stated that,
due to the age of the relay, the f ailure was considered to be age related, and no
further analysis was planned. The system engineer also stated that no plans existed
for replacement of the Model CR120A relays in ac applications since only two
f ailures had been identified since 1985,
c.
Conclusions
The inspectors determined that the licensee had a program for addressing
Model CR120A relay f ailures. Systems engineering personnel had implemented and
nearly completed a program for replacement of the de relays most susceptible to
f ailure. A similar program for replace.nent of ac relays had not been implemented
due to the limited number of f ailures.
M8
Miscellaneous Maintenance issues
M8.1 (Closed) Insoector Foliowon item (IFil 50 285/9718-04: diesel generator field
flashing circuit. On September 17,1997, the inspectors observed a normal start of
Diesel Generator 1. During the test, the electrical field for the generator failed to
flash. The electrical maintenance technicians identified that a diode in the field
flashing circuit was degraded. Based on testing of the field flashing circuit and the
vendor's recommendation, the diode was replaced in both diesel generators. T he
inspectors followed up on the maintenance history regarding degradation of the
diode in the field flashing circuit for the diesels. No previous indications of the diode
being degraded were identified. Additionally, the inspectors reviewed
documentation for the design application for the diesel generator field flashing circuit
diodes and found them to be appropriate.
MB.2 (Closed) Licensee Event Renart (LER) 50-285/96-13: fai'ure to satisfy surveillance
requirement for Containment Penetration M-80. On November 16,1996, the
licensee discovered that a pipe nipple, used to pressurize Containment
Penetration M-80 for leak rate testing, did not penetrate the system piping. The
licensee's record review indicated that tests performed during the 1993 and
1995 refuelir's outages using this pipe nipple were invalid as a result of this
problem.
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Containment Penetration M 80 and associated boundary valves werd not checked
' for leakage as required by Technical Specification 3.5(5) since no pressure was
applied to the penetration.
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The licensee performed a root cause analysis that determined the cause of the event
to be a lack of complete and thorough corrective action. Piping system nipples
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which did not penetrate piping boundaries had been previously identified by the
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licenseo in 1993. However, the corrective actions taken failed to identify and
resolve the concern for Containment Penetration M 80.
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The licensee's current corrective action included modifying the pipe nipple to
pressurize Containment Penetration M-80. .The Technical Specification required leak
rate test was subsequently performed satisfactorily.- The licensee also performed a
review of all similarly configured penetrations to verify that no other blocked or
undrilled pipe nipples were being used for leak rate testing. No other problems were
identified;
Failing to perform the Technical Specification required leak rate test is a violation.
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Th;s nonrepetitive, licensee-identified and corrected violation is being treated as a
noncited violation consistent with Section Vll.B.1 of the NRC Enforcement Policy
(50 285/9719-04).
111. Engineering
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Conduct of Engineering
E1.1
Soent Fuel Pool inventorv Review
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a.
insoection Scooe (71707)
The inspectors performed an evaluation to assess the licensee's control of material
stored in the spent fuel pool.
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b,
dbservations and Findinas
On November 17.1997, the inspectors performed an inventory of items stored in
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the spent fuel pool and assessed the foreign material exclusion controls of the spent
. fuel pool and the area immediately adjacont to the spent fuel pool. Spent fuel pool
inventory was controlled ny Standing Order S0-0-47, " Spent FuelInventory
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- Control," and cleanliness was controlled by Standing Order S0-M 10, " Foreign
. Material Exclusion."
The inspectors obtained a copy of the spent fuel pool inventory ledger. This ledger
contained a list of all nonfuel items stored in the spent fuel pool. The ledger
contained 10 entries. The inspectors verified that these nod
items were in the
spent fuel pool.
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During the inspection, the inspectors noted the area immediately surrounding the
pool was free of debris. Allitems wero properly anchored or secured. However, the
inspectors did note a few discrepancias with the _ foreign material exclusion logs.
The inspectors noted five entries from September 1996 and one entry from
November 7,1997, which indicated inaterial had entered the foreign material
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exclusion area but had not been logged as being removed from the area. During the
inspection, the inspectors could not find these items. The reactor engineer indicated
that the log should have been updated to show that the items had been previously
removed.
The inspectors also noted a plastic bucket hanging from a rope inside the spent fuel
- pool. The inspectors asked the reactor engineer about the bucket. The reactor
enginaer stated that two plastic buckets were actually inside the spent fuel pool.
The reactor engineer cisad that one plastic bucket had been inside the pool since
1994 and the oth sr since 1930
i..a reactor engineer stated that the buckets were
on the spent fuel )ool inventory Itciger. The inspectors asked if the licensee had
performed an evalJation to determine what effect the spent fuel pool environment
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(radiation, thermalt would have on the two plastic buckets. The reactor engineer
stated that, in 1916, he gave a verbal authorization to allow the buckets to remain
inside the spent fuit pool because Standing Ordr.r *0-0-47 did not require that a
written evaluation Ls performed. The reactor engineer stated that he based this
decision on the fact ti,et the plastic buckets were located inside a stainless steel
basket and, if the plastic buckets degraded, their contents would be captured by the
stainless steel basket.
Standing Order SO O 47 required the licensee to annually evaluate nonfuelitems in
the spent fuel pool. The licensee stated that, in 1995, the reactor engineer did not
perform this annual evaluation. Failing to perform the annual inventory evaluation of
nonfuelitems in 1995 is a violation. Once identified, the licensee performed the
annual evaluation. This licensee-identified and corrected violation is being treated as
a noncited viciation consistent with Section Vll.B.1 of the NRC Enforcement Policy
(50-285/9719 05).
Standing Ordar S0-O 47 did not require that nonfuelitems deposited into the spent
fuel pool be evaluated by the reactor engineer prior to being placed in the spent fuel
pool. However, the standing order did require that annual evaluations of nonfuel
items inside the spent fuel pool be performed. Since the spent fuel pool inventory
control standing order failed to require nonfuelitems to be evaluated by the reactor
engineer prior to being placed in the spent fuel pool, nonfuel items could be in the
spent fuel pool for a year before being evaluated to determine their compatibility
with the spent fuel pool. The inspectors discussed with the rmtor engineer
whether nonfuel items were evaluated prior to placing them in the spent fuei pool.
The reactor engineer stated that it was his practice to evaluate nonfuel items prior
to placing them in the spent fuel pool.
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c.
Condusions
The npent fuel pool inventory control program did not require nonfuelitems be
evalJated to determine their compatibility with the spent fuel pool prior to being
pla;ed in the spent fuel pool. The inspectors considered this to be a weakness in
ths spent fuel pool inventory control program. Failure to perform the 1995 annual
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e'ialuation of nonfuel items in the spent fuel pool resulted in a noncited violation,
IV. Plant SuoRQd
R2
Status of Radiological Protection and Chemistry Facilities and Equipment
R2.1 Badioloaicallv Conitolled Area Housekeeoina
a.
Inspegion and Scoce (71750)
The inspeu: ors assessed housekeeping inside the radiologically controlled area.
b.
Qhigtvations and Findinas
During the inspection period, the inspectors made numerous hourokeeping tours
throughout the radiologically controlled area, in general, the inspectets noted thct
housekeeping was good with a few exceptions. On October 31,1997, the
inspectors noted severalitems had been left inside the contamination boundary of
Containment Spray Pumps SI 38 and SI 3C. Inside the contamination boundary of
Containment Spray Pump SI 38, there was a plastic bag, a pair of rubber gloves,
and a pair of cloth gloves, inside the contamination boundary of Containment Spray
Pump SI 3C, there was a lab coat, rubber gloves, and cloth gloves.
On November 17,1997, the inspectors noted housekeeping weaknesses in
Drumming Room 27. The inspectors noted an open bag of trash labeled radioactive
materiallying on the floor in the room. Fart of the trash had spilled onto the floor.
The inspectors asked radiation protection personnelif the trash was contaminated.
Radiation protection personnel stated the trash had been removed from clean areas
inside the plant and it was not contamiliated in each instance, radiation protection
personnel immediately resolved the inspectors' housekeeping concerns.
c.
Conclusions
Radiation protection personnel were prompt in resolving housekeeping deficiencies
inside the radiologically controlled area.
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V. Manaamment Meetinas
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Exh Meetinc Summary
The inspectors presented the inspection results to members of licensee management
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-on December 8,1997. The licensee, acknowledged tha findings as presented. .
The inspectors asked the licensee whether any materials examined during the
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inspection period should be considereo proprietary. No proprietary information was
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identified.
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- ATTACHMENT
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- SUPPLEMENTAL INFORMATION
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PARTIAL LIST OF PERSONS CONTACTED--.
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Licensee
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M. Bare, System Engineer?
- D. Buell, System Engineer .
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J. Chase, Manager, Fort Calhoun Station
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D. Dryden, Station Licensing Engineer-
M. Ellis,' Supervisor, Maintenance Support
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- J. Foleyt System Engineer-
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T. Gurtis,- Electrical Maintenance Supervisor
i R. Phelps, Manager, Station Engineering
R. Short, Manager.. Operations
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C. Stafford, Reactor Engineer.
INSPECTION PROCEDURES USED
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IP 37551:
_ Or. site Engineering -
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. IP 61726:
- Surveillance Observations
. IP 62707:
Maintenance Observations.
IP 71707:
. Plant Operations -
- IP 71750:
Plant Support Activities
,
ITEMS OPENED AND CLOSED
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Openad
~.50 285/9719 02
inadequr,:a containment integrity operating instruction
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(Section 02.2)
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- 50 285/9719 03
improperly installed locking device (Section 02.3)
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- C101ad
y
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- 50 285/9718-04
IFl -
~ diesel generator field flashing circuit (Section M8,1)
50 285/96 13:
LERL failure to satisfy surveillance requirement for Containment
i
- Perietration' M 80 (Section M8.2)
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Onanad_and_ Closed
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- 50 285/9719-01.
_.VIO.
- cooking in main. control room area'(Section 01.2) -
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-50 285/9719-04:-
NCV ' fsiling to satisfy surveillance requirement for containment'
3
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' Penetration M-80 (Section M8.2):
50 285/9719 05;
- NCV falling to perform annual inventory evaluation of nonfuel items -
,
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(Section E1.11
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