ML20215A797

From kanterella
Jump to navigation Jump to search
Rev 2 to Sequoyah Element Rept 240.0(B), Cable Ampacity, TVA Employee Concerns Special Program
ML20215A797
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 04/14/1987
From: Lyke C, Mcnutt G, Russell J
TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20215A652 List:
References
240.0(B), 240.0(B)-R02, 240.0(B)-R2, NUDOCS 8706170089
Download: ML20215A797 (25)


Text

y TVA EMPLOYEE CONCERNS. REPORT NUMBER: 240.0(B) f SPECIAL PROGRAM REVISION NUMBER: 2 ]

REPORT TYPE: SEQUOYAH ELEMENT 1

i TITLE: CABLE AMPACITY ]

Cable Derating (Design) and Cable. PAGE.1 0F 23 Coating Derating REASON FOR REVISION:

1. Revised to incorporate SRP.and TAS comments, to comply with current.

format, and to add Section 10, Corrective Action-

2. Revised to Correct Cable Coating Derating Values.

1 PREPARATION PREP

)

U d /SWD427

,-,)

t f SIGNATURE D' ATE l REVIEWS REVIEW COMMITTEE

//ffY w 4 //7/97 SIGNATURE / DATE

..s TASD p(' '

df'cDow - 5/2R/87-DATE Se M ,6,& ,5IGNATURE CONCURRENCES 6 d C.LA Sol'E2 4/xh7 CEG-H:d d M/ 4 29.s-1 DATE SRP: wkSIGNATURE

  • 5- n-8 r DATE SIGNATURE n

AFPROVED B f 3

i .Ih '

t b b}

DAT M [A MANAGER OF NUCLEAR POWER DATE

/ ECSP MANAGER I

- CONCURRENCE (FINAL REPORT ONLY)

  • SRP Secretary's signature denotes SRP concurrences are in files.

A 50 27 hDR PDR M.

r TVA EMPLOYEE CONCERNS REPORT NUMBER: 240.0(B)

SPECIAL PROGRAM REVISION NUMBER: 2

' PAGE 2 0F 23

1. CHARACTERIZATION OF ISSUES:

Concerns: Issues:

WI-85-100-009 XX-85-122-027, -028, -029 a. Cable ampacity and cable derating i "Sequoyah: Cable ampacity were not properly considered (e.g.,

problems where cable derating overcrowding of cables, penetration, was not properly considered." and conduit sealing were not considered in cable derating).

IN-85-272-004-WBN Overfilled conduits may cause

"'Valcoat,' used in fireproof induction / heat problems.

electrical cables in both units may cause cables to overheat b. Bundling of cables and fireproof coating applied to cables may cause causing degradation of the cable insulation." cable overheating and insulation degradation.

IN-85-289-006-WBN "Vermasco was applied to cables c. Overheating of cables makes prematurely. Penetrations and instrument readings indeterminate.

._ conduits were sealed. Vermasco was determined to keep heat in d. Potential cable damage could result and deteriorated the insulation. from cable pulling in overfilled This application wa discontinued conduits, and insulation is damaged 1-1/2 years ago but ,a Vermasco by fishtapes. (Addressed in Sequoyah already applied has not been Element Report 238.1(B).) {

removed."

IN-86-254-005 l

" Electrical cables are bundled together and then covered with Vamasco. The thick coating of ,

Vamasco potentially causes heat i build up which may cause failure.

This is a generic condition throughout Units I and II. It effects low, medium, and high voltage cables."

IN-86-262-002

" Units 1 and 2, the overcrowding of cables and the application of a fire retardant to the cables causes an overheating condition.

Therefore making the instrument readings indeterminate."

)

03670-2 (04/14/87)

TVA EMPLOYEE CONCERNS REPORT NUMBER: 240.0(B)

SPECIAL PROGRAM 2  !

REVISION NUMBER:

PAGE 3 0F 23 Concerns:

IN-86-036-001

" Electrical conduits in Units 1 and 2 are overfilled. This may cause induction / heat problems.

Some cables may also have been damaged by pulling in these tight conditions, and by using excessive force in installing fish tape in the conduits."

2. HAVE ISSUES BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES X NO Documentation Identifiers: l o Identified by Black & Veatch Finding Report G901 Date 11/02/82 i o Identified by Nuclear Safety Review Staff Report (NSRS)

' I-85-569-WBN, " Cable Overheating and Fire Retardant" Date 11/20/85 o Identified by Nuclear Safety Review Staff Report (NSRS) 1-85-705-WBN, " Cable _ Overheating Due to fire Retardant" Date l',/19/85 o Identified by Nuclea* Safety Reviev. ~+aff Report (NSRS) 1-85-299-WBN, " Cable Overheating Due to Fire Retardant" Date 12/10/85 o Identified by Nuclear Safety Review Staff Report (NSRS) 1-85-766-SON, " Proper Cable Derating" Date 03/07/86 03670-2 (04/14/87)

l TVA EMPLOYEE CONCERNS ' REPORT NUMBER: 240.0(B) I SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 4 0F 23 ,

l DOCUMENT NOS., TAG NOS., LOCATIONS OR OTHER SPECIFIC DESCRIPTIVE l

3. J IDENTIFICATIONS STATED IN ELEMENT:

l Valcoat, Vermasco, and Vamasco for WBNP. (Vimasco is the correct {

name of the cable coating compound used at WBNP.)

4. INTERVIEW FILES REVIEWED:

The following files were reviewed and no additional information for Sequoyah was identified for the concerns addressed in this report.

IN-85-122 IN-86-254 WI-85-100 IN-85-272 IN-86-262 IN-85-289 IN-86-036 File IN-86-036 contains additional information for concern IN-86-036-001 regarding conduit numbers. This information, however, is specific to WBN.

i

}

4

5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:

See Appendix A.

6. WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS, OR OTHER APPLY OR CONTROL IN THIS AREA?

See Appendix A. l

7. LIST RE00ESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED TO ELEMENT.

See Appendix A. .

I i

03670-2 (04/14/87)

TVA EMPLOYEE CONCERNS REPORT NUMBER: 240.0(B)

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 5 0F 23

8. EVALUATION PROCESS:
a. Reviewed available transcripts of NRC investigative interviews for additional information on the concerns.
b. Reviewed FSAR to establish commitments for cable installation and fill requirements.
c. Reviewed engineering design standards and design criteria for cable sizing to assess their adequacy.
d. Reviewed existing Institute of Nuclear Power Operations (INP0), NSRS, and other TVA reports (e.g., I-85-766-SQN) and findings on cable derating to determine the extent to which '

they satisfy the concerns and whether corrective actions have been identified.

e. Reviewed existing TVA Construction, QA/QC, Operations, and TVA Material Control Reports for the TVA Employee Concerns Special Program for applicability to the concerns discussed in this report,
f. Reviewed derating test reports on cable coating compound and firestop sealing material (silicone foam) and their effect on cable ampacities.
g. Reviewed design drawings and TVA Construction procedures and specifications to determine requirements for installation of cable tray penetration firestops and cable coating compound.
h. Assessed overall adequacy of the cable derating practices and installation and identified areas that require further investigation.
i. Performed SQN walkdown to assess adequacy of installation to design. .
9. DISCUSSION, FINDINGS, AND CONCLUSIONS:

Chronoloav:

09/28/76: TVA conducts derating test for cables transitioning firestops to determine the optimum foam depth 1

03670-2 (04/14/87) j

_ ~

l TVA EMPLOYEE CONCERNS REPORT NUMBER: 240.0(d) i SPECIAL PROGRAM REVISION NUMBER: 2  ;

i PAGE 6 0F 23 01/17/77: TVA issues memo to SQN and WBN transmitting details-fo recommended firestops 11/02/82: Black & Veatch performs review at WBN and identifies areas of the plant that did not meet FSAR commitment for 6.9 kV cable separation (ampacity) i 11/08/83: A TVA Task Force reviews and responds to the Black &

Veatch finding concerning the 6.9 kV cable separation and cable coating 1985: Six employee concerns are issued 11/20/85: NSRS Report I-85-569 concludes that cables in V1, V2, and V3 trays had been bundled and coated with fire -

retardant compound and recommends a review of the present installation to determine whether a problem exists 03/07/86: NSRS Report I-85-766-SQN states that no evidence was found to justify cable ampacity and derating factors

  • j in the V-3 trays 01/06/86: Office of Engineering issues calculation B43 860117 924 justifying the existing design standard ampacity tables 01/07/86: Significant Condition Report (SCR) SQNEEB8620 R1 indicates that abandoned cables in cable trays were not tracked. Engineering Report SCR SQNEEB8620 R1 indicates that unlabeled and untracked abandoned cables existed and tray fill criteria were violated 04/10/86: SCR SQNEEB8620 R1 indicates that abandoned cables in cable trays were not tracked. Engineering Report SCh SQNEEB8620 R1 indicates that unlabeled and untracked abandoned cables existed and tray fill criteria were ,

violated )

1 06/17/86: SCR SQNECB8601 R0 indicates that the cable tray fill design criteria were exceeded. Engineering Report SCR SQNECB8601 RO indicate that there were no known violations of tray fill criteria 09/02/86: TVA issues new lesign standard 05-E12.6.3 which supersedes existing ampacity tables and establishes new requirements for derating cables 03670-2 (04/14/87)

TVA EMPLOYEE CONCERNS REPORT NUMBER: 240.0(B)

SPECIAL PROGRAM REVISION NUMBER: 2 1 r PAGE 7 0F 23 10/07/86: TVA issues memo to all nuclear plants to provide direction and guidance in the performance of corrective action.for ampacity and to establish a sampling program to determine the adequacy of installed cables Discussion:

Problems regarding cable derating and cable coating derating (Issues "a" through "c") are discussed in this report. Issue "d" dealing with conduit _ overfill and cable damage is addressed in Sequoyah Element Report 738.l(B).

The sizing and derating of cables installed in raceway is'the responsibility of the design engineer. Failure to properly size cables could result in excessive heat buildup in the raceway and eventual cable failure or fire. In general, the employee concerns question the adequacy of cable sizing with and without application of fire-retardant cable coating compound.

a. Cable Ampacity and h ble Derating Cables in Firestops. TVA conducted an ampacity test for firestop penetrations from October 5 to 23,1976 (App. A, 5 99). This test concluded that no cable derating was required for penetrations using 12 inches of silicone foam (Dow-Corning number 3-6548). The fire test was conducted because Electrical Design Standard DS-E12.1.2, (App. A, 5.rr, 09/28/76) Rev. O, did not address the additional derating requirements for cables transitioning firestop penetrations (App. A,'5.hh, 02/10/77). A TVA memo from Chandler to Pierce (App. A, 5.ii, 01/17/77) on the ampacity test results I indicated that the optimum depth of the firestop sealant (silicone foam) material was one foot, and a revision to design depths was required to seal cable penetrations. This memo transmitted recommended design information for firestop l details to be used for installation ~in cable tray )

penetrations.on the SQN and WBN projects.

The evaluator compared the TVA test procedures and results with tests performed by Detroit Edison and published November 1981 in IEEE Transaction of Power Apparatus and System (App. A, 5.kk). The results of these tests were similar'and supported TVA's conclusion that no additional derating is required.

1 03670-2 (04/14/87)

TVA EMPLOYEE CONCERNS . REPORT NUMBER: 240.0(B)

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 8 0F 23 i

Conduits are sealed for smoke and hot gases.in accordance with SQN drawing 45W880-26, Firestop Penetrations. This drawing requires a depth of sealant (RTV silicone) from 1/2 inch to a maximum depth of 2 inches. The maximum depth 1 2

of 2 inches is less than the 12 inches tested for the )

silicone foam and, therefore, would not require any additional derating.

The TVA test used a test configuration of 30 percent tray fill through the_ penetration. However, the TVA tcsts do not ,

i consider the effect of tray overfill on ampacity. A TVA memo from Raughley to Those Listed (App. A, 5.s, 10/07/86) requests all nuclear plants to conduct a sampling. program'to i evaluate actual installation and to determine effects on  !

cable ampacity. Completion of this program shotild addresa I overfill in penetrations.

Cables in Raceway. The Black and Veatch Finding Report, FIiiding No. G901, on the review at Watts Bar (App. A, 5.a.

11/02/82) identified areas of the plant that did not meet an g',

FSAR commitment for 6.9 kV physical cable separation, and i' noted that these cables were coated with a " fire resistive a compound"-(Vimasco). (The cable coating material used at SQN is Flamemastic.)

The TVA Task Force for Review of Black & Veatch Findings, Category 39 Evaluation Sheet ( App. A, 5.b,11/08/83) for Sequoyah, indicated that the FSAR commitment for separation of 6.9 kV cables was intended to reduce the electromotive  ;

force (EMF) between phases under load and to provide a more conservative design for heat dissipation.. However, the Task Force concluded that no credit for this separation was taken for cable derating. The task force also addressed the issue dealing with the cable coating, which is discussed in "b" below.

~

A field walkdown (App. A,'7.b) at SQN revealed that the 6.9 kV cable installation in trays was in compliance with the G-38 Specification (App. A, 5.uu). Cables 2/0 and smaller were randomly laid whereas larger' cables were in groups of three. No cable bundles were noted.

}

0367D-2 (04/14/87)

TVA EMPLOYEE CONCERNS REPORT NUMBER: 240.0(B)

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 9 0F 23 The NSRS Report No. I-85-766-SQN (App. A, 5 g, 03/07/86) cited the Bellefonte Electrical Evaluation Report, Finding E-3 (App. A, 5.pp, 01/85): "No documentation was found to justify the cable ampacity and derating factors in the application of voltage-level .V3 (control level) cables in 60 percent filled trays;" Finding E-5: " Electrical Design Standards for all current carrying ampacities are not correct for all voltage levels;" and INP0 review of the Bellefonte Project Report, Finding DC3-1 (App. A, 5.qq, 03/84): "Some electrical calculations were not performed and others did not address all design conditions," e.g., low voltage cable sizing adequacy, and inclusion of the effect of conduit grouping on cable ampacity. .

The NSRS report indicated that since the design standards and 4 process for cable sizing are basically the same for all of TVA's nuclear plants the findings were applicable for SQN. i As a result, the Office of Engineering (0E) performed an evaluation of SQN to document the basis for the design standard used for cable sizing, the adequacy of the existing design, and the need for additional studies. OE issued  !

/

N calculation B43 860117 924 (App. A, 5 y, 01/16/86) in

' response to the Bellefonte Review Team finding and concluded

_~

that the ampacities presented in TVA Electrical Design Standards DS-E12.1.1,12.1.2,12.1.3, and 12.1.4 are acceptable for all previous designs.

The cable ampacity issue is further complicated by the uncertainties regarding actual raceway fills. This has been addressed by TVA in the following documents:

o Significant Condition Report SCR SQNECB8601 R0 ( App. A, 5.k,06/27/86) indicated that the cable tray fill design criteria were exceeded. Engineering Report SCR SQNECB8601 R0 (App. A, 5.m) indicated that there were no known violations of tray fill criteria.

o Significant Condition Report SCR SQNEEB8620 R1 (App. A, 5.q,04/10/86) indicated that abandoned cables in cable trays were not tracked. Engineering Report SCR SQNEEB8620 R1 (App. A, 5.r, 05/20/86) indicated that unlabeled and untracked abandoned cables existed and tray fill criteria were violated.

03670-2 (04/14/87) l i

-TVA EMPLOYEE CONCERNS REPORT NUMBER: 240.0(B) 1 I

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 10 0F 23 i

o Significant Condition Report SCR SQN EEB8601 R0 (App. A, 5.n,01/07/86) indicated that verified cable weights and outside diameters were not available. Engineering Report SCR SQNEEB8601 R0 (App. A, 5.p, 04/16/86) agreed with the SCR and included a list of verified cable data that was used in issuance of new design standards for cable ,

DS-E12.1.13 and DS-E12.1.14. I Although the extent of raceway overfill problem is discussed in detail in Element Reports 238.l(B), 238.3(B), and 239.0(B), the effect of the overfill on ampacity is aodressed in this report. )

1 Office of Engineerinc) calculation B43 860117 924 (App. A, j 5.y,01/16/86) was issued to justify the ampacity tables in j Design Standards OS-E12.1.1 through E12.1.4. No evidence was  ;

found by the evaluation team that any type of review was to be conducted to verify that the derating of the installed cables was in accordance with these' tables. As a result of on-going Employee Concern Task Group investigations of ,

ampacity concerns, calculation B43 860117 924 was .

reevaluated, and a memo from Raughley to Those Listed (App.  ;

A,5.i,08/06/86) was issued to distribute a Problem  ;

'~

Identificatiun Report (PIR) GENEEB8605 to all nuclear t plants. This PIR indicated that the design standards are incomplete, lack the definition and information required for { '

proper application, and are suppor.ted by incorrect calculations. The proposed corrective action in the PIR was to revise the design standard criteria to reflect the minimum )

requirements necessary to properly size cables for all ~

applications.

TVA issued a new Electrical Design Standard DS-E12.6.3 (App. A, 5.h, 09/02/86), applicable to all TVA plants. This.

design standard supersedes Design Standards DS-E12.1.1,  !

DS-E12.1.2, DS-E12.1.3, and OS-E12.1.4 and establishes new requirements for sizing control and power cables for installation in conduits and cable trays. It also gives details on additional derating for cable coating compounds '

l and conduit arranagement (duct banks and exposed).

Review of this design standard by.the evaluation team 4 determined that althoutjt it identifies tray covers and fire wrapping material, it does not actually provide standards for derating. Also, design standard DS-E12.6.3 indicates that f

0367D-2 (04/14f87)

o

, TVA EMPLOYEE CONCERNS -REPORT-NUMBER: 240.0(B) . j

'SPECIAL PROGRAM

-REVISION NUMBER: PAGE 11 0F 23 the 'sorst-case configuration.ofl conduits of six wide j norizontally and one deep vertically was used to establish ~ i the tables for V4-V5 (480 V - 6.9 kV) cables. No justification was given.as to why this configuration was  !

chosen since the other c'onfigurations in the table'in Section 3 show more conservative values'.

On the basis 'of the above discussion and with' consideration of the uncertainity of the current cable installation with regard to their ampacities, a corrective action was.

established through a TVA memo from Raughley to Those Listed (App. A, 5.s, 10/07/86). The memo was issued to all nuclear plants to provide direction and guidance in the performance- I of corrective action for cable ampacity, and to establish a- 1 sampling program to determine the. adequacy of installed -]

cables with respect to their ampacity rating- The_ memo j supplements DS-E12.6.3 and addresses.the derating of cables i installed in cable trays with solid top-and bottom covers and ]

in trays covered or enclosed in Appendix R fire wrap materials. As stated in this memo,-the information regarding -

covers and fire wrap will be incorporated in the next 7) revision of. Design Standard DS-E12.6.3. This memo does not ~

specifically address the sampling or evaluation of. overfilled raceway.

Although this memo provides instructions.for additional -

derating resulting from the fire wrap materials, a test .

J conducted by Thermal Science, 'Inc. at Underwriters Laboratory  !

(UL) on September 28-29, 1986 (Ref mailgram App. A, 5.tt)  ;

determined that the fire protection material Thermo-Lag 330 l may require derating figures greater than those. indicated by a previous test. Thermo-Lag 330.is used at SQN, and the revised derating 'for a 1-hr rating was shown to increase from 12.5 percent to 28 percent and for a-3-hr'. rating from 20.5 _

percent to 31 percent. When the official UL ' report is issued, Thermal Science Inc. will evaluate this report and  ;

revise Thermo-Lag 330.derating values as required. -

j l

b. Bundling of Cables and Fireproof Coating 4 NSRS Reports I-85-299-WE 12/10/85, I-85-705-WBN 11/19/85, and I-85-569-WBN 11/20/85 addressed application of the cable ,

coating compound used at Watts Bar Nuclear Plant. Reports I-85-299-WBN (App A, 5.f)'and I-85-705-WBN (App A, 5.e) reference Report I-85-569-WBN (App A, 5.c), which covers'the bunching of cables and application of the fire-retardant coating for WBN.

t 03670-2 (04/14/87)

.( .

TVA EMPLOYEE CONCERNS REPORT. NUMBER:- 240.0(B)

SPECIAL PROGRAM REVISION. NUMBER: 2 PAGE 12 0F 23 Report I-85-569-WBN concluded that Voltage Level VI, V2, and-V3 trays (Control and Instrumentation)'were bunched together for ease in application of the fire-retardant coating, and this configuration was approved for cable. installation in V1, V2, and V3 trays for WBN (App.:A, 5.nn, 04/27/81), but not in V4 (480 V.) and V5 (6.9 kV) trays.(App. A,-5 mm).

Installation, requirements for. General Construction-Specification G-38, Section 3.2.1.8-(App. A, 5.uu,.03/17/86) 1 state that cable shall be placed in trays "in,a neat and.

~

orderly fashion." However, no design or installation ~ .] ;

criteria regarding cable bundling at SQN were identified. ]

The evaluation team observed during the SQN plant walkdown~

-l (App.A,7.a,10/09/86) that one 480 V'(V4) tray (GG-A, Node- ~

103-104) had all of the cable bundled -in the middle of- the tray and coated with Flamemastic. 'This bundling of cable -

creates a cable depth. greater than'the depths established in:

Insulated Cable Engineers Association (ICEA)'P-54-440 standard and Design Standard DS-E12.6.3. The ICEA-established depths are based upon a depth of cables randomly-routed in the cable tray, not bundled in the middle.

'm Therefore, the applicability of the ICEA standard to 'a ,

} bundled configuration is indeterminate. 1

.. . 1 Regarding cable coating, NSRS Report I-85-So9-WBN noted that' even though there was no evidence to conclude that application of cable coating would cause' overheating, the effect of the coating on ampacity was not.specifically documented for all applications. This supported the WBN pre-INP0 Finding PDC 3-4.F (App. A. 5.00, 11/06/85) that necessary documentation has not always been developed to support design criteria and to qualify, designs.

The NSRS report recommended a review of present cables with the application of the coating compound to determine or document that no problems exist.

SQN Report GCA-03-49 (App A, 5.w, 06/06/86) addresses the effect of the coating compound (Flamemastic 77) used at SQN on cable derating. This report referenced two Joslyn Research Tests'(App. A, 5.cc, 09/09/77 and 5.dd, 02/24/86).

conducted on Flamemastic for coating thickness up to 2 inches. The results of these tests indicated a maximum derating of 13.0 percent for Flamemastic 77, and 20.9 percent for Flamemastic 71A for a 2-inch thickness. The Joslyn 02/24/86 Test Report (App. A,-5 dd) revised the derating of 0367D-2 (04/14/87)

TVA EMPLOYEE CONCERNS REPORT NUMBER: 240.0(B)

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 13 0F 23 l

'l 1 i

1/4 inch of Flamemastic 77 upward from 1.41 percent to 4.0 l percent. Cables installed in the plant were covered with Flamemastic 77 cable coating compound, at a thickness of l 3/16 inch + 1/16 inch. However, additional cables were added l to these trays after the initial application of coatings. j The new cables were then coated, creating coating thicknesses greater than originally tested (1/4-inch).

)

The Joslyn test (App A, 5.dd) did not address coating applied on top of existing coated cables when additional cables were installed. In this configuration, the existing TVA standard {

3/16-inch coat is combined with a new coat of 3/16-inch, so '

the total thickness could exceed 3/8 inch. A TVA memo from Killian to Chandler (App A, 5.gg, 11/09/76) indicated that "any buildup of Flamemastic also causes a significant increase in temperatures," when used on cable firestop l penetrations and " extreme care is required during application j to reduce the number of these hot spots."

Cable ampacity tests conducted in 1986 (App. A, 5.dd) with a l coating depth of 2 inches exceed any probable thickness the m' coating could reach during plant construction since this

_l a

s_.. would require the application of at least 10 coats of i material to equal the 2-inch thickness tested. The derating  !

presently indicated in Design Standard DS-E12.6.3 has been l revised upward to better reflect the probable present thickness of greater than 3/16 inch that may be installed in the plant. Also, these derating value tables for thickness from 1/8 to 2 inches are similar to those indicated in the l Joslyn test.

c. Instrument Readings The NSRS I-85-569-WBN (App. A, 5.c) report also indicated that the concern related to indeterminate instrument readings resulting from cable overheating could not be substantiated because the instrumentation system is low current and, therefore, does not result in overheating of instrument cables or cause indeterminate readings. The evaluating team agrees with NSRS conclusion regarding instrument readings.

1 03670-2 (04/14/87)

q TVA EMPLOVEE CONCER'NS ~ REPORT NUMBERi ~ 240.0(B) i 1

SPECTAL' PROGRAM ~-

REVISION NUMBER:. 2 PAGE 14 0F 23

- q Findinas:

a. Although TVA has ? demonstrated by test Lthat no' additional' cable derating is required for cables transitioning firestops, no evaluation or: test.has been conducted on overfilled cable trays in firestops. In view of the~ current uncertainity regarding adequate ~deratings of installed

~

cables, TVA has now initiated a sampling program to determine:

the extent and effect of tray' covers and fire wraps on' cable ampacity. No specific requirements were identified for.the' sampling . program to include evaluation of overfilled raceways.

The originally issued Design Standards.DS-E12.1.1, E12.1.2, E12.1.3, and E12.1.4 did-not furnish the definition and information.necessary for proper. appl.icatio'n of the ampacity tables. In September 1986, TVA issued Desig~n Standard-DS-E12.6.3 which voided these existing design s'.andards. The-new standard reflects the new QA cable data sh';wn in. Design Standards DS-E12.1.13 and DS-E12.1.14 as well as application for derating ca' oles for tray covers, coating.:ompound, and-Appendix R fire wrap (App. A, 5.s). The new design standard, i

'_ 1 however, does not justify why a conduit configuration of six g/ wide horizontally and one deep vertically was established for ampacity tables for V4 and V5 (480 V and 6.f' kV) cables.

b. The use of Flamemastic cable coating compound on cables has been tested by an independent-laboratory, and cable derating values have been established. TVA'has incorporated the derating values into Design Standard DS-E12.6.3.to be used-for cable sizing. Since the values used in the design standard are similar to the values. established by test, the l implementation of the design standard values represents acceptable practice. Therefore, cables coated with .

Flamemastic will not be degraded by overheating, provided the design standard is properly implemented.

As noted during a field walkdown at-the SQN plant, some V4 (480 V) cables.were bundled in the center of the tray and coated with Flamemastic. Therefore, the adequacy of applying ICEA standards for the derating of bundled V4 (480 V) cables.

cannot be determined.

c. Because they have low current levels, instrument cables are not overheated. Therefore, no effect is imposed on instrument readings by cable heating.

i 0367D-2 (04/14/87)

. TVA' EMPLOYEE CONCERNS REPORT NUMBER: 240.0(B)

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 15 0F 23

Conclusion:

The issues expressed in the employee concerns are valid to the extent that the cable derating and sizing did'not properly address the cable tray fill, cable' coating compound, cable bundling, overfilled trays in firestops, tray covers, and Appendix R fire wrap at the time the concerns were expressed. TVA has since recognized the problem 3reas and has initiated corrective actions, except for derating for overfilled raceway, cable bundling, and overfilled raceway in firestops.

Satisfactory completion of current corrective actions and establishment of corrective actions for the outstanding items, will adequately address the cable derating problem. Proper application of Design Standard DS-E12.6.3.should prevent recurrence of similar problems, provided the derating value assumption for the conduit arrangement of six wide and one deep is adequately justified,

10. CORRECTIVE ACTION:

fz s Corrective action plans (CAPS) have been generated by TVA as identified by TCAB-053, dated 12/18/86 (App. A, 5.yy) and TCAB-075, dated 02/14/87 (App. A, 5.zz) in response to four general categories of problems identified in CATDs 240.00-SQN-01, -02, -03, and -04. The four general issues are:

a. 240.00-SQN-01: No evaluation / test conducted on overfilled cable trays in firestops was identified.
b. 240.00-SQN-02: The new Design Standard DS-E12.6.3 does not justify worst case conduit configuration of six wide horizontally and one deep vertically for ampacity tables on V4-V5 (480 V - 6.9 kV) cables.
c. 240.00-SQN-03: V4 (480 V)' power cables are bundled in trays and coated with Flamemastic. The configuration creates cable depths greater than ICEA-P-54-440 and DS-El2.6.3 established depths,
d. 240.00-SQN-04: The cable derating in overfilled raceway has j not been evaluated. Current sampling program for determining the adequacy of electrical cables with respect to their ampacities does not specifically require sampling of overfilled raceways.

i.

03670-2 (04/14/87) l

TVA EMPLOYEE CONCERNS REPORT NUMBER: 240.0(B)

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 16 0F 23 H

The CAP for CATD 240.00-SQN-01 states:

"The fire stop test configuration will be reviewed to-determine the effect of overfilled conditions on the allowable ampacity of the cables. An appropriate derating factor will be determined to ensure that cables in an overfilled firestop do not exceed their qualified insulation temperature rating. All SQN power cables trays which pass through a fire stop and exceed the maximum established fill will be determined. The ampacity of all cables (safety-related and nonsafety-related routed with safety-related

[ associated]) in these trays will be verified using the established derating and DS-E12.6.3. All other power cable trays which pass through fire stops will have their tray fill frozen at or below the maximum established value."

This action is an acceptable solution to the problem.

_., The CAP for CATD 240.00-SQN-02 states:

S y' "DNE calculation EEB-CSTF-0001 titled ' Methodology Used as a Basis for Cable Ampacities Shown in TVA Electrical Design Standards 05-E12.6.3' will be revised to add an appendix titled ' Documentation and Justification of Assumed Worst Case Conduit Grouping (1 Vertical 6 Horizontal, 0.86 Multiplying Factor).'"

This action is an acceptable solution to the problem.

The CAP for CATD 240.00-SQN-03 states:

"An analysis will be performed to determine the effect on the ampacity of a cable due to bundl-ing the cables in a portion of the tray, as opposed to spreading them out over the full width, as we'll as the application of multiple coats of fire retardant cable coatings. The analysis will be based on data on overfilled trays in<

calculation SQN-E2-017 which was prepared for SCR SQNEEB8620 and SCR SQNCEB8622. Installation spec. G-38 will be revised to mandate installation over the full tray width. All discrepancies discovered during this review will be documented on an SCR."

This action is an acceptable solution to the problem.

-)

03670-2 (04/14/87)

TVA EMPLOYEE CONCERNS REPORT NUMBER: 240.0(B)

SPECIAL PROGRAM

' REVISION NUMBER: 2 PAGE 17 0F 23 j

The CAP for CATO 240.00-SQN-04 states:

"The determination of the effects of overfilled tray raceways will be limited to V4 level cables. Cables in V5 level trays, above size 2/0 are installed with 1 maintained spacing. The ECTG verified by field inspection that V5 level cables were properly ,

installed. Cables in V3 trays were shown in calculation EEB-CSTF-001 to have sufficient margin to be independent ]

of the expected variations in tray fill.

The ampacities of cables in V4 tray in DS-E12.6.3 are based on a maximum fill of 30 percent. All i safety-related and associated nonsafety-related cables routed in V4 trays which exceed 30 percent will be individually reviewed to ensure that they will not operate above their qualified insulation temperature  ;

rating. The technical basis for this evaluation will be l DS-E12.6.3, IPCEA P-54-440 and IEEE Transactions Paper 70 TP-557-PWR.

'N' In order to have an accurate database on which to evaluate tray fill, corrective action for the following must be completed before this effort can begin.

1. ECTG CATO 239.00-SQN-01
2. ECTG CATD 239.00-SQN-03
3. PIR SQNEEB8754
4. ECTG CATD 109,.00-NPS-05 for verified cable 0.0.'s Design standard DS-E12.6.3 will be revised to include.

the derating effects of overfilled trays in firestops.

Completion of items 1-4 above will ensure that an accurate database exists by which to limit tray fills to '

1 the predetermined maximum."

This action is an acceptable solu' tion to the problem.

l 1

)

t i

l 03670-2 (04/14/87) l l

i l

TVA EMPLOYEE. CONCERNS REPORT NUMBER: 240.0(B)

SPECIAL PROGRAM REVISION NUMBER: 2

]

PAGE 18 0F 23 APPENDIX A l

5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT: l
a. Black and Veatch Finding Report G901, (11/02/82)
b. TVA Task Force for Review of Black and Veatch Findings - Task f Force Category 39 for Sequoyah Nuclear Plant Units 1 and 2 l l

Rev.1,(11/08/83) I

c. Nuclear Safety Review Staff Report I-85-569-WBN, " Cable Overheating and Fire Retardant Coating," (11/20/85)  ;

3 d, TVA memo from Cottle to Whitt, (No RIMS), " Response to NSRS {

-l Report I-85-569-WBN," (01/30/86)

e. Nuclear Safety Review Staff Report I-85-705-WBN, " Cable Overheating Due to Fire Retardant," (11/19/85)
f. Nuclear Safety Review Staff Report I-85-299-WBN, " Cable

,e Overheating Due to Fire Retardant," (12/10/85)

g. Nuclear Safety Review Staff Report I-85-766-SQN, " Proper Cable Derating," (03/07/86) i
h. Electrical Design Standard DS-E12.6.3, R0 (805 860905 501), '

" Cable, Ampacity Tables For Auxiliary and Control Power Cables (0-15,000V)," (09/02/86)

i. TVA memo from Raughley to Those Listed, (B42 860808 908),

"All Nuclear Plants - Problem Identification Report PIR GENEEB8605," (08/06/86)

j. TVA memo from Raughley to Those Listed (No RIMS), "Ampacity of Power Cables in Duct Bank," (05/30/86)
k. Significant Condition Repo'rt SCR SQNECB8601 R0, (B42 860707 014), " Cable Tray Fill Design Criteria Exceeded,"

(06/27/86)

m. Engineering Report SQNECB8601 R0, (S56 860804 820), " Cable Tray Design Criteria Exceeded," (08/04/86) l 1

I 03670-2 (04/14/87) l

l TVA EMPLOVEE CONCERNS REPORT NUMBER: 240.0(B)

(

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 19 0F 23 l

APPENDIX A (cont'd)-

i n, Significant Condition Report SCR SQNEEB8601 R0, l I

(B43 860117 919), " Cable Weights and Outside Diameters Not Available from a QA Source," (01/17/86)

TVA memo from Wilson to Brimer, (B25 860416 007), "Sequoyah i

p. l Nuclear Plant Units 1 and 2 - Engineering Report for CAQ.

Report No. SCR SQNEEB8601 R0, Rev.1," (04/16/86) l

q. Significant Condition Report - SCR SQNEEB8620 R1, (B43 860410 910), " Cable Tray Loading" (No method of tracking or identifying abandoned cables in cable trays), (04/10/86)
r. TVA memo from Wilson to Brimer, (B25 860520 002),

" Engineering Report - SCR SQNEEB8620R1, Rev. O, " Cable Tray  :

Loading" (No method of tracking or identifying abandoned l cables in cable trays)," (05/20/86)

s. TVA memo Raughley to Those Listed, (B43 861008 909), "All Nuclear Plants - Corrective action and Sampling Program For Electrical Cable Ampacity," (10/07/86)

../

t. Letter from Mills, TVA, to Denton, NRC, (L44 841018 800)," Fire Retardant Coating - Vimasco &

Flamemastic," (10/18/84)

u. Sequoyah Generic Concern Task Force Report GCA-01-46, (No RIMS), " Overfill of Cable Trays and Conduits," (05/20/86)
v. Sequoyah Report GCA-03-48, (No RIMS), " Plant Procedures on Overfill of Cable Trays," (04/25/86)
w. Sequoyah Report GCA-03-49, (No PsIMS), " Thickness of_ Fire Protection Coating on Cables," (06/06/86)
x. Sequoyah Report GCA-04-50,' (No RIMS), " Cable Tray Fill Criteria"
y. Office of Engineering Calculation B43 860117 924,

" Justification For Use of TVA's Ampacity Tables," (01/16/86)'

z. Office of Engineering Calculation B43 860331928,

" Determination of Class IE Electrical Cable Weight / Foot and Outside Diameter," (03/31/86) aa. Electrical Design Standard 05-E12.1.13, (805. 860423 501),

" Cable, Class 1E Cable 00s and Weights," (04/15/86) 03670-2 (04/14/87)

TVA EMPLOVEE CONCERNS REPORT NUMBER: 24000(B)

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 20 0F 23 APPENDIX A (cont'd) bb. Electrical Design Standard DS-E12.1.14, R0, (805 860429 505),

" Cable, Class NC Cable 00s and Weights," (04/15/86) cc. Joslyn Research Center, " Test Report - The Effect of Flamemastic 77 Fire Protective Coating on the Ampacity of A Grouped Power and Control Cable Assembly Tested for the Flamemaster Corporation, Sun Valley, California, Test Number 77-098," (09/09/77) dd. Joslyn Corporation. " Test Report of The Effect of Flamemastic 71A and Flamemastic 77 Fire Protective Coatings on the Ampacity of a Grouped Power and Control Cable Assembly Tested -

for the Tennessee Valley Authority, Knoxville, Tennessee, Test Number 85-033," (02/24/86) ee. TVA memo from Beasley to Vineyard, (B05 860214 001),

"Sequoyah Nuclear Plant - QA Review of Operational Readiness - NSRS Open Items - Surveillance Report No. S86-10"

.- . Watts Bar Nuclear Plant FSAR, Section 8.3.1.4.1, " Cable s Derating and Cable Tray Fill" gg. TVA memo from Killian to Chandler, (WBN 761111 013), " Watts Bar Nuclear Plant - Sequoyah Nuclear Plant Units 1 and 2 - q Cable Sleeve Penetration Tests," (11/09/76) 4 hh. TVA memo from Sudduth to Electrical Engineering Files, (EEB 770211908), "Sequoyah Nuclear Plant Units 1 and 2 -

Evaluation of Test Results of Cable Ampacity Tests for Completed Fire Stop Penetrations," (02/10/77) ii. TVA memo from Chandler to Pierce, (EEB 770118 910), "Sequoyah 3 Nuclear Plant Units 1 and 2 - Design of Electrical Fire Stop Penetrations," (01/17/77) ,

jj. IEEE Transaction on Power Apparatus and Systems, Volume 90/1971, (IEEE paper 70 TP557 PWR), "Ampacity For Cables in Randomly Filled Trays By J. Stolpe", (January-June 1971)

I 03670-2 (04/14/87)

I TVA EMPLOYEE CONCERNS REPORT NUMBER: 240.0(B)

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 21 0F 23 APPENDIX A (cont'd) kk. IEEE Transaction of Power Apparatus and System, Volume PAS-100, No. 11, 4680-5, "Ampacity Test of a Silicone Foam Firestop in a Cable Tray," Detroit Edison Co., (Nov 1981) mm. TVA Design Information Request - Wilkins to Cantrell (WBN 810729 162) "4 Voltage Level Cable Grouped - Designed Information Request (DIR) - No. E-56" (07/29/81). Response to DIR (SWP 81 0902 028) nn. TVA Design Information Request - (WBN 810427101)" Cable Grouped in Tray and Coated with Vimasco - Design Information Request (DIR) - No. E-55," (04/27/81).

oo. TVA memo from Lyons to Coan (B49 851106 001), " Watts Bar Nuclear Plant - Pre-INPO Design Evaluation," and attached Pre-INP0 report, (11/06/85) pp. Bellefonte Electrical Evaluation - January 1985 qq. Bellefonte Nuclear Plants, Units 1 & 2, Tennessee Valley j Authority - March 1984 rr. Electrical Design Standard 05-E12-1.2, R0, " Cable - Conductor Current Carrying Capacity Cross-Linked Polyethylene Insulated  !

Cable (0 - 15,000 V), (09/28/76) ss. Insulated Cable Engineers Association ICEA Pub. No. P-54-440, "Ampacity, Cables in Open-Top Cable Trays, August 1979" tt. Mailgram Rubin Feldman to Bechtel Power Corp. Re: Thermo-Lag 330, dated 10/02/86 uu. General Construction Specification, G-38, Rev. 8, " Installing Insulated Cables Rated up to 15,000 volts" (03/17/86; vv. TVA SQN Drawing 45W880-26 (Sheet 26) Rev. 19, " Conduit and Grounding - Cable Trays - Fire Stop Penetrations Detail Sheet 13," (07/18/85) ww. Electrical Design Standard DS-E13.5.1, R0, " Raceways, Electrical Penetration Firestops and Pressure Seals,"

(12/05/77) 03670-2 (04/14/87)

i i

i

. TVA EMPLOYEE CONCERNS- REPORT NUMBER: 240.0(B) j SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 22 0F 23 f i

APPENDIX A (cont'd) i xx. Letter from B. J. Youngblood, NRC, to S. A. White, TVA,  ;

(06/23/86) with the attached transcript of the investigative {

interview conducted by the NRC on 02/21/86 at the First i

Tennessee Bank Building in Knoxville,.TN yy. Letter from G. R. McNutt, TVA, to G. L. Parkinson, Bechtel,-

TCAB-053, " Corrective Action Plan," date 12/18/86' .

zz. Letter from G. R. McNutt, TVA, to G. L'. Parkinson, Bechtel, <

I TCAB-075, " Corrective Action Plan," date 02/14/87

6. WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS OR OTHER l

APPLY OR CONTROL IN THIS AREA?

a. FSAR 8.3.1.4.1 - Cable Derating and Cable Tray Fill
b. Engineering Design Standard E12.1.13, Rev. 1, (01/13/86)

Engineering Design Standard - DS-E12.1.14, Rev. 1, (01/13/86)  !

c.

x

d. Engineering Design Standard - DS-E12.6.3, Rev. O, (09/02/86)
e. SNP Inspection Instruction No. A4, Rev. 9, (06/16/83)
f. SNP Construction Procedure No. E-10, Rev. 2, (09/06/79)
7. LIST RE00ESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER J DISCUSSIONS RELATED TO ELEMENT.
a. Field Walkdown at Sequoyah site conducted by Jack Wheeler (Bechtel), and George Bell (TVA) 10/09/86.

l

b. Field Walkdown at Sequoyah' site conducted by David Knudsen  !

(Bechtel) (11/21/86) I l

03670-2 (04/14/87)

- TVA EMPLOYEE CONCEL. REPORT NUMBER: 240.0(B) ,

i SPECIALLPROGRAM

" e" REVISION. NUMBER: 2 PAGE 23 0F 23 i

f,

- < .c l

CATD LIST The following CATDs identify and provide corrective actions for the findings in this report:

240 00 SQN 01 (CAP revised 02/13/87)-

240 00 SQN 02 (CAP revised 02/13/87) 240 00 SQN 03 (CAP revised 02/13/87) 1 240 00 SQN 04 (CAP revised 02/13/87) r i

l o

i i

i l

O I

1 1

I l

l 1

l 1

d

'l 03670-2 (04/14/87) l E

s ,I v i [._ .

. ^

P TITL NO AI

. 97 BE T E U Y B R '- ..ASIL I D FNOUF PSS PL F RT 38 D- EDS E' DCE I , CO UUA O . AENEEO SN EI

~8:/ N N2TC- E HEA .L CE- SILDF AI DDR 989 N ESI/0N LETCTYA NSSTHENN H DE 51 IG- LM RETN EAUUGH R EU P EAT PA HMAOITSE HAEMND L 4

N 1fO

/ HE C IONOPIO GA L T
33 EI LS H1S FSIF LI TACHH AC TCHAOH V G EHN O DS ET TXI NN BOE 10 BU .O T AT R AT IO ANL E .II D .YUDR C

-- AA YC DHP V .GENVSTD NFAONAIC NEG C . TI AT SA CC LSDE E OSIITND AOMRA C ALNNUN RI . EAI EE EAEUDD H D . BIORO MLSIEA EDR RHV MT LT RMTNE EELSUD RGHT ,E T SAKITI DDE E IA AA- URAIIN RLUEDI0, CNC MI .P ECATSTt AT HIN 1 TD CE- TERTLO ABPCNFN MIINUF2E L MAfA E T HCR E E N IH- AVOllPI M IoPT O XON TTHOII7D EAHIDT7 BEAHEOCR C0M LOE GNN RR.

TE 2RYECOSCA G0 TEN N CTRL- OO F BHL S .C CVN R E .RCAC-AUU O PB A MD3 I ES U OCPIMEDO t PRR T EOO PDTIYR & GE H T K UD DNI FOFOTE .MI.N CSA EE0 P L I EEDDT . TDNHO N ,IAT AI LRC EOT SLD ASN 1AE:TTI- DCDOH REO EHV BE I

R TAL EA SENO EGS C EILC0S U ,C GTETOR R ODS C F LEDAROI SHAUNE HHI 1A7R NNHARE EIN RIU HCR PSONM DSU BSNHLCT T/M IU ICTUC BISR7SE5T IATN H S

E OES A A A INAY D .

DD IRT H' E D RLN CE HRN0OSR A .M NODBEPDR N '

UE RTASO N NRHMER S .C N TCN YOY PBI UI TNDALE BHTEC OADRDU O N EA OEIICTO TANECtC I RTIEAF MDO I R RCE TH TAMNN TSIF IUEAHHN NCENTEC E EEFI0 CETTE EEC CYH E L RRIERO LR ALA C

I FEB DSACRUI SN DB SHO

.ITC R .HGFFI A EIT . E DDPH BES PR ODU ME N

OUC SA ETEIE ilHLVHE TIESFI OSA CAN VENNS RIO AP .

O C TA P TR I VN HT SCE ESSSIPEI TEVO OROI IC ,S A PSM OH ,

C* huDPPEOO UEAOEDSHIH,P E LAUI SLT EF SVH NY ER0 ,

D I PNEAHBM NU TTCD I BMA EA HTANNLIE GGE D YON LPI B T EYT AOE T CKS O OAOI AACS .

,M TCO IIECR I I CYA N ATA Y SA CCSDGGN- CV II . R COM UMF S IT .N YHIEGO R

O ,O ADOHUD LNN 0 .

U1N LHLT LNF .FTD OAA* .U Q PR AL e NR O

EEi

~

G - ,

"SH HNTTBES A VA L Y AA A OI.T Ci T O ATL DBIN 2 . HSF TTD O D OOH ICMY lsCIIHI CIA.ACL NADI 8HHR3NE MEOO

. E 1DR 7RR APN AAN T CSE .GM ATAiUT IET E YHI R TE IR STVNECP ERI D

)C A

DNT AII CUA SNlNAEI AOIO l

RC RSMHTHRA TI GS0TM TDNRIEUE CHSINHSR CEEU GBH IC TAOEHtU LPT UGL l

SB D MIMIS MT0 B A QNA ERTLSA'.T L

PU CS AHA VTR EAEAAE RTRTRN . L ETETIKNO L OF LEDITT R NINU CH ATM EIH E/

.(Y "OG VRILEEN E BEHSCN EVPAILXU ULARS O COR STO Y- R T MO N

IREG RN-RETE EI C~ C C C OWST CG C C C T T' T-HOYA HI T T T T Q Q Q TPSCY OR Q Q Q Q U T ARMYI CO-AABC YER A N N
ELGNP N N B Q LCOOM L AT B B H S LVRIA H N --
AfPT l CR -

6 ^

V AE IO - 9 FNML #RP- 9 5 6 6-x EORRB E EOA OE TR 9

2 0

7 5

7 S - - 5 5 SECFC a

r.

SCNN EIOI I

H 5

8 5

8 8'

I 8

I NFC 0 _

I I

l hFt N0 _

EOER0 T EE4 R R R S '

YC2 DB_ R R R R YS YS YS 7 OH1 hS YS YS YS PEH_ YS L' R S PCY R R R R MR WiaQ_ R R YS YS YS YS EEO tS_ YS YS YS YS TE A R S EG A A R R A NN YS YS u YE YS YS HN OT R O BRL __ MN HN S

-z LA PC PF EAF_ R R R R YS R

YS R

YS-R-

YS MB RSB_ YS Y S. YS YS EU 12 12 12 12 12 12

, X S I2 12 12

- y'. TC_ N H B

N B

H B

H B

H B'

N 7

N Q

S B

H H M H -

T LPLO __ H H t N U S S N N C P SHRJ. 1 1

N 1 T 0 0 2 U 0 0 0 0 0 1 0 0 0

~ 1 O -

0 0 0 0 0 _

BT 0 0 0 0 S 0 8 0 4' 4 P & UA 0 4 3 4 4 4 2 2 C 3C 4 2 2 2 2 E S 2 2

- , r - S N N J E N E

~

N N E C T_ I t E E E

", 0T O A_

E lt -

E- - E 2S 1E R C_

SU P 1 1-1

~. PQ 1 1 2 1 0 0 0 CEM S R l'*

b 0 0 0 2 9 7-ERH E E 0

4 6 1 5 0 0 2 R D 0 0 0 0 0 B

M _-

0 0 0 0 0

t U_ - - 2 0 2 4

S E t

N M78 9

87 6

39 58 68 24 01 I1 25 11 EYS N 26 08 -

20 1 2 2 A

CCS ll llI Y R 2M--

50 1 - 1 60 2

60 50 85 50 85 EE R E 50

%b5 85 85 T

RU- O C 85 85 T - T T G ll T - T -- T EQ X-FEP E o H N N I X

ERN T C N N I I I H I I RFO A .

~

(

C

~- .

I

)

3 ) ) ) )

' ') I -j ) .) ) ) ) )-

}

4

_4 ( ( C I F 4 M c C [i..

1 C L l .

97 EDR E R 38 _

9:/ _ DDE LOE 989 _ AT BNT 51 _ E T A T

/ _ LOE CSE 33 _ BNL AL 10 _ A EH CSA R A _

- - - AI EII _

EHV HCV _

EE R l W N MT EIt _

IA HCR S .R _

TD WE MDE E

GNt t N S C

l

.f EEC LRl t AUU O MD0 BE0 PRR I EEC ODC T LR RI P BES PSS I ODU l tU R RIO Y0O C PSM TCM S NY I Y E YON CYN _

D TCO ALO I N PRN N CYA MEA R AL AP E PR O C 1E t

. ER .

N APN LPl l O OO E 0 C ERI ATI LPT C0T B A fA l

ATM  : M Y C0R YSR R

1 tO RAO _

O  : F RHF G ESN E N E TAI FGI -

T tH l

N A 0 L SIR

)C SB PU FGA ENl LI0 t

"TE t

HRT AH CS LTI OER _

E/ EAT RDU (Y BRI . B F . _

Y R _

T MO 1 IREG fl .

RETE Rl OWST EI HOYA CG C C _

TPSCY lI t T Q

T Q

U T 0R ARMYI CO v AABC YERlA ELGtP LCO0M L L0RIA AT A11PT CR V AE IO FNML RP -

EORRB OE  :

E EOA TR _

SECFC l*

S SCti I EI0I H lFC f 0 i

HF i0 EOER0 T EE4 0 YC2 .

Ot l LDB R R 0 L0: PEH YS YS 0 PCY PT 4 _

M R AAQ R R 2 _

EEO LS YS YS _

EG TE Y YE dRL R R R _

O? . B YS YS O ._

L F G _

R P AF R E M~ SB YS YS T E" A S 12 12 12 C B _

U S

TC H H -

LO L F N .

T PL B B E U

C P SHRD i t N Y 1 T R _

2 U O 1 O 0 0 G S BT 0 0 E P & UA 0 0 T C SC 4 4 A E S 2 2 C

- S J E R 0T C T t t N O 2S O A E E F 1E R C SU P S P4 N CLM S 1 1 R ._

ERU E R 0 0 E __ _

R D E 8 9 lC

- - B 2 2 t

- M 0 0 0 t

t U - - C S E lt 2 2 _._

EYS 25 25 9 CCS  : N .

11 11 _

ll llI Y R 2 2 _

EE R E 50 50 _

RU- O C 85 85 EQ G l l T - T FEP E o ERN T C X X RFD A X X C _

i - ~ _

.  : _