ML20235S297

Summary of 870923 Meeting W/Westinghouse Re Technical Basis for Westinghouse Recommended Actions,Criteria & Conclusions in to Utils That Use Models DS-416,DSL-416, DS-420,DS-206 & DSL-206 Switchgear in Class 1E Svc

ML20235S297
Person / Time
Site:	Calvert Cliffs
Issue date:	10/02/1987
From:	Hood D Office of Nuclear Reactor Regulation
To:	Jabbour K Office of Nuclear Reactor Regulation
References
TAC-65955, TAC-65956, NUDOCS 8710080419
Download: ML20235S297 (56)

Text

{{#Wiki_filter:_ cw,q km Rig +f o UNITED STATES 8 (gg NUCLEAR REGULATORY COMMISSION 3 {7 /.E WASHINGTON, D. C. 20555 5.- a ., / october 2, 1987 MEMORANDUM FOR: Kahtan N. Jabbour, Acting Director Project Directorate 11-3 Division of Reactor Projects I/II FROM: Darl S. Hood, Project Manager Project Directorate II-3 Division of Reactor Projects I/II

SUMMARY

OF SEPTEMBER 23, 1987 MEETING ON WESTINGHOUSE SWITCHGEAR FAILURES (TACS 65955/65956) On September 23, 1987 the NRC staff met in Bethesda, Maryland with Westinghouse to discuss the technical basis for Westinghouse's recommended actions, criteria and conclusions in its letter of September 11,1987 (Enclosure 1) to utilities of the Westinghouse Owners Group (WOG) that use its Models DS-416, DSL-416, DS-420, DS-206 and DSL-206 switchgear in Class IE service. The letter is based upon the DS-416 reactor trip breaker (RTB) which would not open at McGuire Unit 2 on July 2,19F.7, because of a failed pole shaft to center pole lever weld (References a, b & c). Related breaker failures at Calvert Cliffs Unit 1 (05-?06) in September 19116 (Reference d) and at Sequoyah Unit 2 (Enclosure 2) in June 1987 were also discussed. Meeting attendees are listed in Enclosure 3. = 1. WESTINGHOUSE PRESENTATIONS Westinghouse provided presentations in 5 areas (Enclosure 4): (1) Desion Adequacy of the Pole Shaft-Lever Assembly To show that the design weld is adequate, Westinghouse described calcula-tions showing that the working torque of the 3/16" fillet weld of the 3/4" diameter pole shaft exceeds the peak calculated actuation (closing) torque. Calculations of the failure torque were performed to show that the pole shaft would deform before the design weld. The calculations were confirmed by three tests for the failure torque of a shaft lever. Tests also showed that only 10% of the length of the design weld would still carry the actuation load. Other calculations were described to show that fatigue would not occur in the design weld. (2) Inspection Program Westinghouse described the failure torques resulting from tests of several l 0.19" and 0.125" fillet weld specimens of varying lengths used to establish I its inspection criteria. A general discussion of desirable and undesirable l indications for visual inspections of fillet welds was presented. l 8710080419 071002 PDR ADOCK 0"000317 P PDR

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(3) Design, Manufacturing and Test Criteria Westinghouse described the various uniform industry standards used for the design and endurance tests of the breakers. Westinghouse has performed about 90,000 total breaker test operations on various DS-416 tests to satisfy different requirements. The highest number of operations on a given breaker was 10,964 and occurred during WOG tests. No failure of a pole shaft was known to have occurred during any of these Westinghouse tests. (4) Westinghouse's Commercial Dedication Process The breakers are manufactured as a commercial-grade device and subsequently certified (dedicated) as qualified for use in a safety-related application. This process of comraercial dedication is presented in Enclosure 4 (5) Quality Assurance Process for Procured Hardware Westinghouse discussed the QA process for vendor control and vendor programs at its East-Pittsburgh, Puerto Rico, and North Carolina facilities. 11. NRC CONMENTS AND CONCERNS The NRC expressed several concerns during the meeting. These were not resolved. (1) The staff disagrees that a RTB with a cracked center pole lever weld can be used es a bypass breaker. Such a breaker should be considered inoperable until the weld is repaired or the pole shaft replaced. (E) Cracks in the fillet weld may be missed unless the pole shaft is removed from the breaker for this visual inspection. Also, the zinc coating on the welds can n:ask fabrication cracks. (3) Weld inspection criteria and qualifications of the welding inspector are not included in the letter. (4) A weld " safety factor" of 1.5 is not sufficient for Class IE application. (5) Westinghouse's recommended actions, in essence, accept as satisfactory a weld less than the requirements of the original drawing. Such a weld has not been tested to ANSI standards. (6) Westinghouse has not effectively connunicated the endurance limits of the I pole shaft to its Class IE users. (7) Westinghouse's letter was sent only to WOG users. Other utilities also use these breakers for Class IE applications. All DS Model Class IE breakers need to be inspected. (8) Westinghouse does not have recorcs for individual Class IE breakers. Its records are based upor. e given purchase order which usually covered several { breakers urdered by a utility. The number of breakers per purchase order is unknown.

l I l (9) Considerable peening of the close cam surface surrounding the stop roller was observed to have occurred at McGuire Unit 2. Binding of the stop roller inside the close cam could impede closing of the breaker. This is of concern for those Class IE breaker applications in which the safety j l function is to close. j s (10) The staff remains skeptical about Westinghouse's weld stress calculations l which are based upon static rather than dynamic factors. Westinghouse suggested and the NRC agreed that fatigue testing of known weld lengths would be useful here. (11) Licensees are not required to report Class IE breaker failures to Westinghouse or the NRC. Westinghouse had limited knowledge of the Calvert Cliffs 1 or Sequoyah 2 failures. The NRC learned of these failuias by chance and after the McGuire failure. III. STAFF CONCLUDING REMARKS I The NRC staff stated that in view of its above concerns, consideration will be given to separate regulatory actions in order to assure that Class IE breakers are designed, fabricated, erected and tested to quality standards and will operate commensurate with the importance of the safety functions perfomed. IV. REFERENCES a. Licensee Event Report 370/87-09, " Reactor Trip Breaker Failure Due to Mechanical Failure," McGuire Nuclear Station - Unit 2, Duke Power Company, dated August 3, 1987, b. NRC Inspection Report Nos. 50-369/87-22 and 50-370/87-22, dated August 31, 1987. c. NRC Information Notice 87-35, dated July 30, 1987. d. Memorandum from B. A. Wright to J. P. McVicker, "Calvert Cliffs Nuclear Power Plant 480 Volt Breaker No. 52-1108-NCR 3894", Baltimore Gas and Electric Company, dated September 18, 1986 (same as Enclosure 2 of Meeting Notice, 9/21/87, D. Hood). Is} Darl S. Hood, Project Manager Project Directorate 11-3 Division of Reactor Projects, I/II

Enclosures:

As stated .B S / / i lo PD#11-3/DRP-I/II PE#11-3/DRP-l/II DHood/mac KJabbour, Acting PD 10/ L /87 10/ /07 2 i

,)# - ENCLOSURE 1 ( j l { 4 [ { l t 6 g i Thefo1}owinginformationandrecommendationsareprovidedforyouruse,if you have Westinghouse Models DS-416, DSL-416, DS-420, DS-206 and DSL-206 switchgear installed in your plant in IE service. I BACKGROUND On July 2,1987, it was reported that a DS-416 reactor trip breaker did not open on demand at McGuire Unit 2 during rod drop testing following a refueling outage. This malfunction was determined when plant personnel observed smoke in the yicinity of the reactor trip switchgear. Since the breaker had not opened Qn demand the shunt coil current was not interrupted resulting in a damaged. coil. The breaker could not be tripped manually, but did trip when i I the manual charging handle was r.anipulated. During subsequent cycling on the test bench, the breaker jammed again. An inspection was conducted at the site jointly by Westinghouse, Duke Power and the NRC, during which the breaker was cycled for 37-38 times. It operated successfully each time. Visual inspection noted wear (nearly 3000 cycles of operation) and separation of the weld whtch attached the center pole lever to the pole shaf t, The NRC issued 1 Informai. ion Notice 87-35 on July 30, 1987 reporting this event. INVEST 1dATIONRESULTS ThebrekkerwassubsequentlyshippedtoWestinghousewhereadetailed investigation following the guidelines jointly developed by Duke Power, the NRC and Westinghouse. The breaker malfunctioned after some 130 operations. i i k 6

I., r... ^ j Septembe'r 11,l1987' I Page 2 I After observing the condition it was found that the jauning could be repeated by manually forcing the close cam and main drive link-into The breaker did not assume this unique position on its. own through about thirty subsequent operations. The roller attached to The scen'ario at McGuire can be explained as follows: The the main drive link normally rests on the outer close cam laminations. broken weld permitted lateral movement of the main drive link which mo roller close to its tolerance limits. The force exerted by the breaker { slipped off the outer laminate of the cam. closing action induced a twisting motion which caused the roller to we'dge Although it was between the close cam lamination and the side frame. established that the stacking of part tolerances played a part in the jamming of the b,reaker, it was also concluded that the breaker to wedge Subseque t evaluation of the broken weld revealed that the weld had abo fusion. 8 The machanism producing the weld separation was low cycle fatigue with the' fatigue striations indicating separation after about 2,500 cycles A conservatively (consist'ent with Duke's estimate of operating cycles). The designed calculated load on the weld was determined to be 10,000 psi. weld str'pngth is 35,000 psi giving a " safety factor

• of 3.5.

s l POTENTIAI. SAFETY IMPACT Westinghouse considers this malfunction of the DS-416 Reactor Trip Bre } 05-416 breakers have operated through many thousands ~ of cycle's without any malfunction similar to that reported at McGuire. be a ran' dom occurrence. DespitelthequalityoftheweldintheMcGuirebreaker,itperformedfor I l It about 3,000 cycles confirming that the weld as designed is conservative. was also, evident that while it is necessary to have a w f maximum.; For thes~e reasons, )festinchouse does not_rojtommead_tba.t_any_in This, however, does not preclude recommended actions in line w l be taken'. Ji10rmal_ShtY#_illance 4WaiThienilice practices. 3 RECOMMENDED ACTIONS Primary ' attention has been focused on the weld separation with con Because Westinghouse performed a random factors, rom tolerance build-up.inspectipn of the pole' shaf ts (weTds f I 1 wi

7 c, 3 t,. 1 t. b l s Septembe'r 11, 1987 '-l 3 1 1 Page 3 i I' 1 I instance of the roller rubbing the side frame surfaced durina the irdesOgiUon Westinghouse _ reconne1 Mis _the_f6flodng_Actinns for__1r g alig_at. ions of DS-416 switchgear: A.{ShortTermInspection(NextSurysillance) i l i Weld Inspe'etEen (On Three Pole Lever Welds) ! This inspection may be performed with the breaker disconnected and ! racked out fully on the cell rails, or on a bench, as is suitable to the user. Minimum tools are - small mirror, fillst gauge (1/8" and ,3/16"), flash light, screwdriver, socket wrench and long handled pliers. Proc ~edure 1. Trip ~the breaker if energized and closed.- Rack it out on call rails fully extended, or transfer to bench. t i 2. Remove front panel. 3. Disconnect motor leads, and the link for the auxiliary j switches. 4. Remove the top cover towards the front of the breaker, I making sure that wires -in the harness are not damaged, i 5. Inspect the weld (s) visually to the criteria given below. I 6. Reinstall all items removed or disconnected. Criteria and Actions j 1. Weld Separation Action: If separated welds are found, remove from service i as' sain or bypass creater. 1 j 2. Cracked Weld _ For checking the presence of weld cracking, exclude the ends ) which may show evidence of cold start. Action: If cracks are found, use only-as bypass. breaker until weld condition can be corrected. 4 8 I l l 1

r n,,, l s i Septetbdr 11, 1987 Page 4 j. 6 3. Size and Length of Weld Exclusive of the ends of the weld, which may show e'vidence of cold start, the weld should have at least 3/16" fillet for 90' continuously around the pole shaft. If the fillet is under 3/16", then the weld must be at least 1/8" fillet for 120' continuously around the pole shaft. Either size weld provides a " safety factor" in excess of 1.5. Action: If dimensions are not met, use only as bypass breaker until weld condition can be corrected. I B.' Long Term Ingpection (Next Refueling) 1. Examine Welds for Separation, Cracks or Size Inspect remainder of pole shaft welds'with"the exception of stop Replace pole levers which do not perform a safety function. shaft if necessary. i ' 2. AlignmenkofBreakerMechanism Refer to Figure 1. This tolerance check should be performed on the bench with the closing springs disconnected from the cam-shaft (common shaft going through the close cam). 1 Procedure 1. Remove front panel of the breaker. 2. Disconnect the closing springs from the cam shaft. The other end may be lef t undisturbed., j 1 3. De-energize control powers to the breakers, if wired to ) I power supplies. Breakers should be open with springs J discharged. 4. Resthain the UVTA with a wire loop so that the breaker is not in a trip-free mode. Simulate manual charge of the closing springs to the charged 5. position, to turn the close cam to the " Ready to Close" position. I i i c.

/ ecsc us l l 8 E. September 11, 1987 - i Pago 5 i E. With' pressure applied to roller as indicated in Figure 1, slowly turn the closing cam manually by the a ring charging handle. (Note: To release the can to turn, press both manual trip and close buttons simultaneously Continue to turn the cam until the breaker contacts reach the closed . position. t At this time, the maximum lateral play of the roller is in j effect. 7. Through the front of the breaker, sight the close cam, the roller and the side frames. Using a flashlight, check to see that - roller is making contact with the two outer laminates of a. the close cam. It is not required to be centrally pinced. b. there is visible gap between the side frame and the roller side at each and of the mechanism. If either of the two checks are not satisfactory, contact Westinghouse. 8. Reinstall all components removed. 8 Other Switchoear Models i Other switchgea'r models which utilize the identical pole shaft and mechanism sh9uld also be inspected. 1. DSL-(16 and 05-420 Inspection schedule should be identical to that outlined abovpforDS-416. l 2. DS-206 and DSL-206 Since the stresses on these welds are considerably less than those on the DS-416 application, (resulting in a much larger " safety factor"), it is recomended that all the above inspections be accomplished at the utilities' convenience in a time frame not to exceed the next refueling outage. l l 0 t k

PIGE'F#9 s/ Septembe'r 11, 1987 l i Page 6 3 g l \\ l CONCLUSIONS l Westinghouse believes that the above actions are prudent and when accomplished on a one-time basis will provide assurance that a similar circumstance will not be repeated. r Sincerely, j l H. C. Walls, Manager Mid-America Region ProjectsDepartment Attachmejnt-Figure 1 HT/32779. cc: G. J. Plim1 T. A. Rieck G J. A. Johnson W F.i Lentine ~ E.,J Fuerst D. L. Farrar A J. Marianyi WOG Rep. J.I.UsemW i f, I I l 4 I i i I i l l _ _ _ _ _._._ _ _ j

-ch FIGbRE1_ l f i f' MECHANISM SIDE FRAME MAIN DRIVE LINK ~' b. Ag /',,,'/ CONSTRAINING /, g MOVE ROLLER LEFT R0tt.ER & RIGHT LINK J. ' 'i l I JF 3 ~'N ^j b .. s s R i \\ L x 1 INSPECT FOR VISIBLE d INSPECT T 7' GAP FOR VISIBLE GAP l i I \\. / CAM 1 MAIN ROLL r s r n i f i a i I, g l t 8 <e l 8 i

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I l [TE y:.,.Q.s3;.. ~. . s .. ~ ji ~ QA Record Enclosuro 2 v......... ~ UNsTED STATES GOVERNMENT Q {Q Q Memorandum TENNESSEE VALLEY AUTHORITY 870721S0629 g To L. H. Nobles, Plant Manager, P08-2, Sequoyah Nuclear Plant raoM J. B. Hosmer, Project Engineer, Sequoyah Engineering Project, DSC-E, Sequoyah Noclear Plant D^ JUI.101987 1 staurCT: SEQUOYAH NUCLEAR PLANT UNIT 2 - FAILURE ANALYSIS OF DIERGENCY FIRE PROTECTION PUMP CIRCUIT BREAKER POLE SHAFT ASSD*4LY This memorandum supersedes my memorandum to you dated June 15, 1987 (B25 870615 026). i Attached for your review is an engineering analysis of the broken pole shaft assembly. The preifminary results indicate that the failure is not generic and is probably an isolated oase. However, the Division of Nuclear Engineering is coordinating with Westinghouse to review all weld documentation and procedures to make this determination. After an evaluation of this information is completed, my recommendations for revisions t.c maintenance and surveillance instructions will be submitted to you for incorpc.,.ation in the appropriate plant instructions. ~ J. B. Hosmer

bB P:HC Attachment cc (Attachment):

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0. P. Cooper, 5-215 SB-K G. T. Hall, DSC-P, Sequoyah l

R. M. Jessee, W9 A60 C-K J. A. Roach, W9 C135 C-K H. A. Skarzinski, P08 2, Sequoyah (Attn: T. Konovitch) R. C. Williams, DSC-P, Sequoyah \\ DE05;HC7182.05 E m m. .m m

e. L O g,' y- ,,Q ? V ~ ~. p.. ( s b j , PRE!.IMINARY FINDINGS REPORT Mq u ABSTRACT ? This report briefly covers the laboratory results of the examination of two failed fillet welds on the pole shaft assembly of a circuit breaker that enFrsites The emergencyTire protection pumps located in the plant. It describes the plain carbon steel materials used,_the porosity,'the. crater q-cracks, and the fillet weld size and concludes that nore clan I circuit breakers be examined on a routine basis in accordance with aIevision to Electrical Maintenance Instruction (D(I) 10 5 9d Surveillance Instruction ] (SI) 275.1 and SI 275.2 in _-order to look for porous or cracked welds. This is not a generic probles based on data Yo'be suppliec r th rtLET O, j Westinghouse and the observations of the Materials Eng eering Etction as descr3ed in this rt. J INTRODUCTION A pole shaft assembly with oaas welded onto it was brought to the Materials Engineering Section for examination of two fillet welds connecting the can and the rod, which are the principal components of the assembly (see figures IA and B). It was determined at that moment that it should be sent to the TVA metallurgical laboratory for further destructive examination. RESULTS AND DISCUSSION X-Ray spectrographic analysis for chemical oneposition shows a plain carbon' a steel rod and a corr.osion resisting copper bearing plain carbon steel plate a for the cas (see Data Sheet 1). Wsid metal

• chemical analysis by induction furnace ocebustion techniques and a visual examination of the weld and adjacent metal for arc strikes, weld spatter, or slag show evidence of a

= mild steel composit!ca, probably an AWS SFA 5 18 E703-6 gas shielded aro welding filler material (see Data Sheet 2). Average hardness values of the rod, cas, and weld were taken and found to be acceptable (Data Sheet 4). j The two failed welds, as visually examined, give more detail to the mode of failure than chemical composition. Visible poroatty in photos 2A and 28

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shows almost a 20 percent reduction in surface area of the oroas section photo (see figure 25), which oculd be assumed to be a 25 percent volumetric reduction of metal along the length of the weld since the line of fracture runs irregularly free void to void the entire lonath of the weld. In figure 23, it is also noted that the weld was of multiple passes, as if they tried to aburn out" the aneamitv. Figure 3A is equally interesting although evidence of porosity is not demonstrated. The weld fractured down. the center of the weld in a atrataht_ line with almost equal volumes of metal deposited on both the bar and the = plate. This led to the belief that while a sound weld was made to join the 7 plate and rod, it may not have been of sufficient aise to carry the load -j that the assembly was designed to carry. After examining how the pole ]j shaft assembly functions in the eiecutt henkar. It van determined that after the porous weld failed. the one nett to it failed because all of the l Lid ~d -1 l 5 j l_oad for the two welds was now placed on it (these two cats were connected at the end by a pin through the holes seen in'firure 11). Since the pin was connected about 1-1/2 inches away from the shaft, a twistine force would have also been placed upon it adding to its shear and subseouent _ raj 1 ure. The failed pole shaft assembly was repaired with a replacement from spare parts, and four more have.been ordered. Any future welds encountered with excessive porosity or cracking can either be replaced or rewelded at the direction of the Materials Engineering Section. CONCLUSI0'JS After sesing several of these welds on existing pole shaft assemblies in the field, it is rocossmended that revisions be made to EMI 10 5 and SI 27f.1 and SI 275.2 to look for porous or cracked welds on all circuit breakers using this type of pole shaft assembly. ] This is not a generic problem based on data to be supplied from the vendor Westinghouse, and the observations of the Haterials Engineering Section. ADDITIONAL ACTION REQUIRED The Haterials Engineering Section will request Westinghouse to supply the following documentation, which further supports the bela r that a generlo condition does not exist with regard to these fillet we ca breaking on pole shaft assemblissa 1. Data about related failures reported to Westinghouse to date. 2. Process and mate?ial specifications relating to the fabrication of the pole shaft assembly and any applicable industrial codes, such as AWS ? welding standards, used in its fabrication. d 3 Engineering date reflooting the weld site and length, said to be 1800 t around the pole and the 1/8-inch fillet weld site. 4 Alternate engineering data regarding weld site and length if said length and stae on the pole shaft asseebly proves to be less than 1800 but greater than the specified 1/8-inch fillet weld site. Upon receipt of this information, the Materials Engineering Section will issue a final report detailing the changes to be made in the EMI and SI procedures. } Edward W. Pugh Codes. Standards. Welding, and NDg HC715).05 i \\ k \\

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l I l l Meetina Attendecs 1 September 23, 1987 NAME ORGANIZATION i Darl Hood NRR/PD#11-3 Carl H. Berlinger NRR/DOEA/0GCB Ellis W. Merschoff flRR/DRIS/VIB James C. Stone NRR/DRIS/VIB C. Y. Cheng NRC/NRR/EMTB A. Toalston NRR/ DEST /SELB W. S. Hazelton NRR/ DEST /EMTB C. D. Sellers NRR/ DEST /EMTB J. E. Richardscn NRC/NRR/EAD K. R. IJaidu NRC/NRR/VIB K. R. Wichman NRC/NRR/EMTB l l S. Hou NRC/NRR/EMEB l Vern Hodge NRC/NRR/0GCB l Cindy Pezze W/GTSD/MT Barry Parnett U/NSID/QA Chuck Geis W/NSID/EOP Anup Deb W/NSID/EOP Dick tiiller W/NSID/NS Warrer. Barvford W/GTSD/ Material Technology Joe Jelovich W/NSID/EQP i i Howard Fishman Franklin Research Center l l Gary Toman Franklin Research Center Brian McIntyre Westinghouse Nuclear Safety Pete florris Westinghouse Nuclear Safety

i e LNCLOSURE 4 Viewgraph Slides and Handouts for Westinghouse Presentation September 23, 1987

1 l 9/u/37I unop Design Adequacy of the Pole Shaft - Lever Assembly

• Actuation Torque H

e Calculation of Working Torque e Calculation of Failure Torque e Determination of Allowable Weld Degradation e Experimental Validation e Fatigue Evaluation

• Conservatism 1

Actuation Torque e Linkage for Opening and Closing Contains 5 Members e Shaft Actuation is Soley Through Pole Shaft Lever e Loading is Essentially Pure Shear on the Weld e Actuation Torque Measured by Duplicate Strain Gage Rosettes e 12 Tests Were Mode, and Results Were Very Reproduceable e Peak Torque Was + 814 in. Ib. on Closing + 615 in. Ib. on Opening e Range of Torque Was 814 in. Ib. to -692 in. Ib.

'd

SUMMARY

OF ACTUATION TORQUE MEASUREMENTS ' BRIDGE A BRIDGE B MAX. MIN MAX MIN . D1 Track 5 800 -700 620 -360 ] D1 Track 6 840 -600 615 -350 D1 Track 7 830 -710 620 -350 D1 Track 8f 840 -730 620 -370 j D2 Track 1 800 -730 610 -380 D2 Track 2 815 -705 610 -400 D2 Track 3 805 -705 605 -405 D2. Track 4. 810- -730 620 -405 4 D2 Track 5. 800 -700 620 -400 D2 Track 6 815 -700 605 -390 D2 Track 7 805 -680 620 -360 D2 Track 8 805 -620 610 -350 -AVERAGE: 814 -692 615 -g -si7 RANGE: 1506 IN.LB. 1292 IN.LB.

6 [ 0 '2 l? l;r p 8 'I i: 4 4 4 91 4 P, I! I 7 "I 6 .b t 2 "I f 4 i h a 4 0 W 0 *I m .WI 8 'O x k 7" [ T 9 'O V 'O I eO { l g.0 G G G G G G G G G G G G G G G G G G G G G G OD 0 4 N N 4 0 0D G M i i i I 1 87-NI '300801

..(.. k l l " g. "2 l \\ l l 4 8 'I l i gI 1 i

l tr " I l

=_ 2 "I s UW 0.I l; m .W I 8 "O m l b l 9 'O it 'O 1 2 "O l l l O 'O G G G G G G G G G G G l 5 G G G G G G G 'S G G W D 4 N N 4 D D G 1 I I i i 87-NI '3n0B01

4 i Calculation of Working Torque ~

1. s#

I k/ +3ns j l l SHAFT j .750 1 From AISC Guidelines, For A 70XX Electrode 0.3 F, = A LLew. ug = 2.t kst 1 i Working Torque: T = %...(vR.5)A R = 17.30 tu LB. I Actuation Torque is 814 in. Ib, maximum, z. Weld is Adequately Designed. l 0

9 Calculation of Failure Torque For the Weld: T = T. JwL , Tr% mR*f R 1. w o vsa.at jw-3 4., wsw I ax

• 6 = rs g

13(.% (d.L3, M 1 TYlELD Y" 2 30 I"I' For the Shaft: T = Trax T d' E Fo T " = g*3 T 2400 N.ts. q "f = y Ty T v'e m M ar iu.us = Conslusion: Shaft Will Deform Before The Weld

Experimental Validotion

• Failure Torque for o Shaft Lever
• Three Tests Performed, Average Foilure Torque = 4285 in. Ib.
• For a Given Torque (900 in. Ib.), How Much Weld Degradation Will Still Carry The Load?
• Result: 0.16 in. Length of Weld, or 10% of the Weld
• This Result is Consistent With the Mc Guire Failure 1

l

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p.

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s = =1 =-Na_ -.=.j + -C_ _%.q. 3 _ _. . _iL. _ _- 4=== d =r= = =t =i-

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g.;:3.j-L.

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..fi

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21-t

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23r= = r =2-j

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l 1 i Fatigue Evaluation i 1 j T=TJu2. R. T = T T R2 4 [(v Rt Q T* s = w -r_x s 2.511F pd

• From ASME Section 111, Allowable Cycles = 55,000 If Half the Weld is Gone, Allowable Cycles = 6,000

Conservatism

• AISC Guidelines Were Used
• No Credit Take for Reinforcement from Adjacent Lever
• Maximum Measured Torque Used - No Energy Associated With the Peak j

l L_ ---

4 1 Inspection Program o Criteria Development

• Criteria Validation Tests o Capabilities for Finding Degradation l

I l l 4

INSPECTION CRITERIA VALIDATION TESTS We3d Weld Specimen Failure Torque Average Fillet Size (IN.LB.) (IN.LB.) (Degrees) J .1875 180 2E 3784 4285 180 3D 4181 180 2D 4890 .1875 90 1B 2416 2883 90 2B 3322+ 90 3A 2913 I .1875 45 4A 2667+ i 45 2A 2126 2142 45 3F 1633 .125 120 1A 1873+ 120 3B 3431 2641 120 1F 2618 .125 90 4B 2938 90 4E 3699 3321 90 4F 3326 1 l l 1 l l i 1 I I l

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===l

{

~. ~=r s

1 irry j.

=q

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n r

-f= + =. _ T_- . ; a '. 7

_ l-

= _..}. n -:,1 4 - .._-.i: - .n; 5. r r.._

.:..=-.

' -- f a w . - j._ f [ = _.

l J } ^^ 5 {

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g;

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.=: .:.2..___ .-.__L. , j. g

ca

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}

. L. I i D l

u. __1

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=

q 1 I . _ _. } _.. _ _ _. c . _ _d._ _. I 4 l l t i i o o O o b o o C o s "- ? 5 a.s. m ew e a 6 i at w.en p D '. 4 M g

C. fy 9/z2/97 { e i i Visual Inspection

• Surface Cracks
• Crater Cracks
• Lock of Side Wall Fusion
• Cold Weld
• Weld Contour
• Size of Fillet

p L Fillet WeH Profiles / CONCAVE

• Desirable fillet Weld i
• Indicative of Hot Weld l
• Good Side Wall Fusion
• Indicative of Good Root Fusion CONVEX L

,'\\

• Desirable fillet Weld
• Good Side Wall Fusion
• Indicative of Good Root Fusion HIGHLY CONVEX l

)

• Undesirable Fillet Weld
• Indicative of Cold Weld i

Q

• Indicative of Poor Side Wall Fusion
• Indicative of Poor Root Fusion 1

) )

1/'o/s7 DESIGN, MANUFACTURING & TEST CRITERIA A. UNIFORM INDUSTRY STANDARDS NEMA SG L.V. POWER CIRCUlT BREAKERS ANSl/IEEE C37.13 -L.V. A.C. POWER CIRCUlT BREAKERS USED IN ENCLOSURES ANSI C37.16 - PREFERRED RATINGS, RELATED REQUIREMENTS, AND APPLICATION RECOMMENDATIONS FOR L.V. POWER CIRCUlT BREAKERS ANSI C37.17 - TRIP DEVICES FOR AC..L.V. POWER CIRCUIT BREAKERS i ANSI C37.50 - TEST PROCEDURES FOR L.V. AC POWER CIRCUlT BREAKERS USED IN ENCLOSURES ENVELOPE OF ABOVE STANDARDS ARE: DESIGN TESTS DIELECTRIC WITHSTAND TEST i CONTINUOUS CURRENT TEST SHORT-CIRCUlT CURRENT INTERRUPTING TEST ENDURANCE TEST REQUIREMENTS OF ENDURANCE TEST CRITERIA IS THAT IT ... SHALL NOT NECESSITATE THE REPAlR OR REPLACEMENT 1 1 OF ANY FUNCTIONAL PARTS PRIOR TO COMPLETION" (OF ENDURANCE TEST). MINIMUM LIMITS FOR ACCEPTANCE ON ENDURANCE TEST ARE t SPECIFIED IN THE STANDARDS. - PRODUCTION TESTS - DIELECTRIC WITHSTAND TEST - MECHANICAL OPERATION TEST - CALIBRATION TEST B. INDUSTRY CERTIFICATION l BREAKER HAS BEEN CERTIFIED BY UNDERWRITERS LABORATORIES (UL AFTER TECTS WERE SUCCESSFULLY COMPLETED PER UL) STANDAF D 498 IN APRIL-MAY, 1974. s RETEST REQUIREMENTS FOR PRODUCT, AS DEFINED IN ANSI C37.50 HAVE BEEN COMPLETED. LAST SERIES OF TEST W8RE PERFORMED IN 1985. i

i TEST PERFORMED ON DS-416 BREAKERS BY WESTINGHOUSE DESIGN VERIFICATION TEST (TEST DESIGN INTEGRITY) i - SWITCHGEAR DIVISION PROTOTYPE TESTS (TO ANSI STD) - SWGR. DIVISION l TYPE TESTS (TO UL STD) - SWGR. DIVISION l RETEST (TO ANSI STD) - SWGR. DIVISION l QUALIFICATION TESTS (TO IEEE STD) - SWGR. DIV. QUALIFICATION TESTS (TO IEEE STD) - NUC. DIV. WOG TESTS - NUC. DIVISION 1 i These tests were done to; satisfy different requirements as noted in patenthsis against eacli. The time period spans from 196d/69 to 1985.,Different specimens were used in each of the test's, and dlfferent amount of cycles operations were induced in etch. in total, approximately 90 000 breaker test operations were encountered through this series of tests. 3 \\ q Of the total 90,000, about 50,000 test operations were done during WOG tests. No failure of pole shaft occurred. iHighest three numbers of operations on a breaker are 10,964, b ' 10305 and 8,469, all induced during the WOG tests. i e 7 f I tj f i t 4 \\ "i i 't '$ s t i f 2.. \\ 'N t ~ + a w I, h k g i 'l e s ~ \\ ) g \\ L:W

1 9/Z3/E? 1 f

y. @

l J ABSTRACT THE DEDICATION OF COMMERCIALLY PROCURED PARTS FOR USE IN SAFETY-RELATED APPLICATIONS J. J. JELOVICH; J. R. HILL; F. B. HYLAND WESTINGHOUSE ELECTRIC CORPORATION PITTSBURGH, PENNSYLVANIA 15230 In resolving the problem of diminishing support of original equipment manufacturers for supply of safety-related parts to the nuclear industry, Westinghouse has developed a technique which permits the use of parts manufactured under comercial procedures, in safety-related applications. The process transfers responsibility for.c:FR50 and 10CFR21 compliance from the primary manufacturer to the dedicating agency. Two years of experience with the formal process has demonstrated that adherence with certain key guidelines will assure qualification of the commercially manufactured parts for use in safety-related applications. I i I l ) l I Published in the American Nuclear Society Proceedings of the International l Meeting on Nuclear Power Plant Maintenance l March 1986 l

THE DEDICATION OF CO MMERCIALLY PROCURED PARTS FOR USE IN SAFETY-RELA 1ED APPLICATIONS J. J. JELOVICH; J. R. HILL; F. B. HYLAND WESTINGHOUSE ELECTRIC CORPORATION PITTSBURGH, PENNSYLVANIA 15230, U.S.A. With the diminishing support of original equipment manufacturers for supply of parts to the nuclear industry, utilities are being faced with the problem of maintaining safety-related equipment as the sources of qualified replacement and spare parts dwindle. From the equipment manufacturer's viewpoint, the evolution of the nuclear power industry has come to a point'where the absence of new plant construction has depressed his market for qualified equipment to the level where he cannot, justify the cost of maintaining the organizational structure and processes required for compliance with 10CFR50 and 10CFR21. With all aspects of the situation considered, and particularly the pragmatic aspect of the commercial world, the problem reduces to that of how to comply with the intent of the federal regulations without imposing the requirements of 10CFR50 and 10CFR21 upon the primary manufacturer of the equipment. As an NSSS supplier, Westinghouse has a continuing interest in seeking a viable solution to this problem and disseminating the results of our efforts and the apparent solution to the industry. Basic to the resolution of the problem is acceptance of the fact that the part to be secured for use in the safety-related application will originate as a commercial device, not intended especially for the nuclear industry, and when procured from the manufacturer, it will be no different from identical parts provided to the industrial and commercial market in general. A review of the philosophy employed in the original design and development of the vast majority of safety-related equipment reveals that the designer selected " commercially" available components for his design, built the prototype, proved his

design, and then qualified the equipment by analysis and testing, finally imposing design control and manufacturing control upon the production of the equipment to assure compliance with the regulations.

\\ The Westinghouse approach parallels the earlier philosophy by again utilizing comercial components. However, today, that component configuration has already been qualified and it remains merely to prove that the component procured today is identical in all critical attributes to the qualified component specimen, establishing the link I to qualification, and accomplishing this without resorting to strict l design control and manufacturing control on production of the comercial component. Once purchased, the specific part must be subjected to a process which will result in certification of the part as qualified for use in a safety-related application. That process, which will probably be defined as " conditioning" by the IEEE, has been described as "comercial dedication" in the Westinghouse program. This paper describes the commercial dedication process as developed by Westinghouse and presents it as a reference point for the dedication of parts by other agencies. KEY ELEMENTS OF COMMERCIAL DEDICATION In formulating a policy addressing comercial dedication, Westinghouse considered past experience and looked at the variations of procurement and supply anticipated in the long term. There are three categories of equipment which must be accommodated in a comercial dedication program: a) supply of a component which is available as a commercial product; b) supply of a component to replace an obsolete component no longer available, even as a comercial product and c) supply of components for new systems intended for safety-related applications. The decision was made to establish rt single policy and subsequently implement a program which would envelope all three of these categories. The comercial dedication process consists of establishing that the part is similar in all critical attributes to the specimen part which was manufactured under a 10CFR50 program and qualified by actual testing to the requirements of IEEE-323 and IEEE-344. Essential to the process are certain key elements: 1. The component must be qualified by documented testing or analysis. Whether a component starts life as a comercial device or is subjected to stringent 10CFR50 controls from its inception, it must be proven qualified for use in a safety-related application by actual test or anaylsis in compliance with the regulatory guidelines. A key element is to identify that qualification reference and establish the physical configuration of the referenced specimen.

9 4 2. A second key element, the heart of the comercial dedication process,.and the one which most affects the quality of the dedication, is establishing that the component is similar in all critical attributes to the specimen component which was qualified by actual testing to the requirements of IEEE-323 and IEEE-344. This process is carried out through application of engineering evaluations, physical measurement, functional testing, and material analysis, all relating back to the qualified design. 3. To distinguish the dedicated component from the straight comercial version in the field and facilitate compliance with 10CFR21, the component must be uniquely identified to facilitate tracking. Techniques such as marking with special part numbers and serial. numbers may be used. This third key element must also be documented in traceable femat associated with the end user's purchase order. 4. Because rigorous design control is not employed in the comercial dedication process, material changes and subtle design changes, particularly in the area of tolerances, may be incorporated in the coamercial part. To detect such changes, which could compromi::e the qualification of the component, periodic requalification of the component must be employed. The frequency of this periodic requalification testing is established by engineering evaluation, taking into account the degree of sophistication of the specific product design and manufacturing techniques, the state of the art of commercial manufacturing in this area, reputation of the manufacturer and comercial version user experience. 5. The key element which is of prime importance to the components end user is the assumption of 10CFR21 responsibility and certification ) of that responsibility by the dedicating agency. The dedicating agency must comply with all aspects of the 10CFR21 responsibility. The comercial manufacturing origin of the component does not mitigate this responsibility. 6. The final key element is satisfying the intent of 10CFR50 by the application of a comprehensive quality assurance program to all ) aspects of the comercial dedication process.

IMPLEMENTATION OF THE COP 91ERCIAL DEDICATION PROCESS The comercial dedication process is considered a significant departure from past practice by a good portion of the industry and as

such, it receives a great deal of visibility.

Almost as important as the process itself is the control and documentation of the process. The process must be structured to accomodate detailed audit by the end user and the USNRC. It is essential that the objectives of the process, its' structure and procedure be formally described in a policy statement endorsed by the pertinent corporation management. At Westinghouse this has been accomplished by a formal

report, the

" Renewal Parts Dedication Process", which delineates the actions necessary to enable the dedication of a " commercial grade item" for basic component application. In this document, the purpose, scope and dedication process are described, along with the responsibilities of the participating working groups; Engineering; Order Administration anti Requisition; Test and Manufacturing Operations; Quality Assurance; and Nuclear Safety. In addition, guidelines for the working structure are given, establishing the overall program controlling vehicles, the " Engineering Work Order" and the

detailed, product

specific,

" Engineering Control Instruction". The commercial dedication program has been fully implemented and in use at Westinghouse's Monroeville, Pa. facility for two years. In practice, we have found that three technical groups must work together in a closely-coupled relationship in order to respond quickly and adequately to the user's requirements. The Engineering group provides detailed technical direction by designing the program to produce the specific product in response to the customer's request, and by defining the exact procedure to be used in the production process. This is accomplished by the issuing of an Engineering Work Order which tells each party in the process exactly what they are to do in filling the customer order. The Purchasing group is told exactly what materials to buy and from whom to buy them. The Test and Manufacturing group is told how to carry out the inspection, manufacturing, assembly and testing operations. These instructions define the critical aspects of the parts important to performance of the safety-related function, such as dimensions, materials and material hardnesses and finishes, the tolerance stackups among related parts, etc. The Quality Assurance group is given the information necessary to show the tie between the product and the supporting qualification testing program. Direction for periodic sampling and examination of materials, and directions for including samples in ongoing requalification seismic testing programs are al.so permit (an provided to Quality Assurance. The Engineering Work Order a so provides the cross-reference and infomation necessary to audit of the process, beginning with the customer's order and ending with the quality release information at shipment.

In order to carry out this phase of the process, the Dedication Agency's engineering -group must have access to the specific qualification records, at -least to the depth which allows the test specimen physical configuration to be established. Without information on a past related qualification test, the Engineering group must undertake to document the present commercial product, carry out a qualification test and thereby establish the qualification reference for future work wFere the part would be obtained from the primary manufacturer as a Tommercial part. This technique addresses the l categories of obsolett component replacement and new system components. The Engineering grvip must also have access to the design information or, as a mitimum, complete operational characteristic information sufficient to permit an analysis of the critical function and associated physical cht.racteristics important to performance of the critical function. The specific technical procedure for dedication of the component is provided by means of the ' Engineering Control Instruction", a formal document giving step-by-step detailed direction for the inspection, measurement, modification and testing of the commercial component. During the past two years, a library of several hundred of these component specific documents has been developed. They are written in response to the initial end user's request for a component and then utilized, intact, to satisfy all subsequent requests from all end users of that component. The majority of the actual work involved in the commercial dedication process is performed by the Test and Manufacturing group at a facility established for the purpose of producing obsolete spare parts in support of the nuclear industry. The facility is organized as a light manufacturing operation with sophisticated inspection and testing capabilities. J The core personnel at the Assembly and Test facility consist of manufacturing engineers and technicians.

However, because of the commercial dedication requirements, the Quality Assurance group plays a major role.

10CFR50 AND 10CFR21 COMPLIANCE In a commercial dedication program all 18 criteria of Appendix B to 10CFR Part 50 must be addressed and applied to the process. The dedicating agency relives the primary manufacturer of 10CFR50 responsibility, as well as the 10CFR21 responsibility and assumes those responsibilities. The quality assurance aspects thus become crucial to the success of such a program. )

{ 1 + i e In the Westinghouse program, Quality Assurance personnel are involved in the process from manufacturer evaluation to verification that the dedication process has been faithfully followed. Inspection is part of the dedication process, and as such, Quality Assurance has a verification role as well as a surveillance function establishing that others have accomplished their objectives, as required. Quality Assurance also initiates the " Certificate of Conformance/ Compliance" and retains auditable documentation supporting 10CFR21 reporting requiments. Because of. our role as an NSSS supplier, with a major role in supporting the licensing of plants, Westinghouse has in place, a large Nuclear Safety and Licensing department. The comercial dedication program draws upon this existing organization for regulatory support. It is the utilization of this existing capability which makes practical the transfer of responsibility for regulatory compliance from the primary equipment manufacturer to Westinghouse's Nuclear Services Integration Division (NSID). Copt1ERCIAL DEDICATION EXPERIENCE Because of the pressing need to continue support of the obsolete "DB" line of Westinghouse switchgear in operating nuclear power plants, the initial products undertaken in the comercial dedicat. ion program were DB air circuit breaker parts and complete DB circuit breakers. The original manufacturing division had comitted to produce some " wear" parts for a limited period to the commercial market, but, not the nuclear market. NSID found it necessary to transition all aspects of this switchgear product line from the original division. This included design calculations; drawings; manufacturing procedures; processes; manufacturing and test fixtures, tooling and qualification test reports. During the past two years, we have produced qualified parts for all models of DB air circuit breakers, complete DB air circuit breakers and have refurbished DB breakers for reactor trip switchgear application. Among the lessons learned, or rather among the suspicions verified, was that comercial products are subject to evolution. Comercial products which are initially designed and manufactured to very stringent specifications may evolve over the years to a product significantly different from the original product, particularly in the area of materials used. This is due, of course, to the need to optimize production and the related costs.

In the DB circuit breaker experience, this meant that we have had to manufacture certain parts or modify certain commercial parts so that we could control aspects such as dimensional tolerances, material hardness, plating and surface finishes important to performance of critical functions. Every safety-related part provided by the dedicating agency must be subjected to the dedication process _in order to identify manufacturing changes affecting critical functions. An example of a " standard" commercially dedicated product is the 1 'DS" type air circuit breaker. The circuit breaker is procured as a comercial product and subjected to a commercial dedication process which includes the replacement of certain commercial parts with qualified, Class IE,

parts, such as wiring, shunt trip attachment, amptector and control relay.

In this product, computer access to the manufacturing instructions permits NSID to identify design changes in a comercial product. No special requirements are imposed upon the primary manufacturer. The manufacturer treats NSID as he would any other commercial customer and NSID accepts the circuit breaker as a comercial product. A wide variety of products have been produced using the commercial dedication technique. They range from small parts such as terminal

blocks, switches, protection and control relays, up through more sophisticated devices such as printed circuit cards and molded case circuit breakers to switchgear lineups and dry type transformers.

The 1000 KVA dry type transformer is typical of a new product which required seismic and environmental qualification of the product by actual testing and analysis and documenting the product such that subsequent transformers in this family can be commercially dedicated using this qualification work as the reference. Other ratings in this

family, from 250 KVA to 2500 KVA will be qualified by analysis based upon the detailed instrumentation of the actual test and computer modeling of other ratings. All of the dedication is performed by NSID.

The manufacturer will continue to provide the transformers as comercial devices to NSID. SumARY After two years of use, the comercial dedication technique for meeting the utility need for acquiring qualified spare and replacement components for safety-related applications has been proven viable and successful. The commercial dedication process has been accepted by the utilities, equipment manufacturers, and the USNRC as evidenced by the pm chase of Westinghouse dedicated components and the successful audit of the process.

s [ l' ' There are certain elements which are essential for a valid l commercial dedication program. The dedicated component must be l demonstrated to be essentially identical to a qualified component which was qualified by actual testing, and the related qualification report must be referenced and traceable. The requirements of 10CFR50 must be applied by the dedicating agency. The dedicating agency must assume 10CFR21 responsibility and put into place the organizational structure required to support that responsibility. The overall program is based upon the sophistication of the dedicating agencies engineering, quality assurance and licensing support capabilities. I i

QA PROCESS (HDWE PROCURED FROM E-PGH) 1 - REQUIREMENT 10CFR50 Appendix B e -lNTERNAL QA PROGRAM e RESAR 3 WCAP 8370 (1974) e Operating Procedures e Departmental Manuals / Procedures e QA Engineering Purchasing Drafting Internal Audit Program i e 1 - VENDOR CONTROL e Approved Vendor Vendor Audits QCS-1 e Vendor Surveillance Test Witness Final Examination Quality Release Quality Procurement Specification e QPS 386-2 (March 77)

l l 1 - VENDOR PROGRAM ) e Formal QA Manual Supplemental Procedures e Manufacturing MI's l 'e Process Control i Written Procedures Qualified Personnel e inspection Receiving in Process First Article Roving Random Sample e Final Product Test inspection

l QA PROCESS (HDWE PROCURED FROM E-PGH/P.R.) - REQUIREMENT 10CFR50 Appendix B e - INTERNAL QA PROGRAM WCAP 8370 e Operating Procedures e Departmental Manuals / Procedures e QA Engineering Purchasing Drafting - VENDOR CONTROL Approved Vendor (East Pgh) e Vendor Audits QCS-1 Approved Subtier (WICO - PR) e Subtier Audit QCS-1 Vendor /Sub-Vendor Surveillance e Test Witness Final Examination Quality Release Quality Procurement Specification o QPS-386-2

QA PROCESS (HDWE PROCURED FROM E-PGH/P.R.) - REQUIREMENT e 10CFR50 Appendix B -INTERNAL QA PROGRAM e YlCAP 8370 e Operating Procedures Departmental Manuals / Procedures e QA Engineering Purchasing Drafting - VENDOR CONTROL Approved Vendor (East Pgh) e Vendor Audits QCS-1 Approved Subtier (ElCO - PR) e Subtier Audit QCS-1 Vendor /Sub-Vendor Surveillance e Test Witness Final Examination Quality Release e Quality Procurement Specification QPS-386-2 1

1 ? ~ VENDOR PROGRAM ] e Formal QA Manual Supplemental Procedures e Procurement f East Pgh. Responsibility l .WICO Procured Misc. Services, e.g. Plating e Receiving Parts supplied via East Pgh. Control Rl at PR Qty. { Damage l Correct Part e Manufacturing j MI's j e Process Control Written Procedures Qualified Personnel in Process inspection e First Article Roving Random Sample e Final Product Test inspection i

QA PROCESS - COMMERCIAL DEDICATION - REQUIREMENT i e 10CFR50 Appendix B Internal QA Program e WCAP 8370 i WCAP 9245 Operating Procedures QA Manual and Procedures A&T Procedures Manual 1 1 - VENDOR CONTROL l t l e Vendor Audit QCS-2 1 e Procured Commercial Grade I - A&T CONTROLS e Requirements Document EWO ECl 1 e Manufacture Auditable Trail I e Test [ Documented l l

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q i

1 inspection e Documented QA and Engineering Certification e Package and Ship e QA Witness - VENDOR PROGRAM e Formal QA Manual Supplemental Procedures Manufacturing e MI's e Process Control Written Procedures Qualified Personnel e inspection Receiving in Process Roving Random Sample in Process Assembly 100 % 1 l e Final Product inspection ) L

MEETING

SUMMARY

DISTRIBUTION JTD5'cbtNilE" NRC Participants < t?RC" PDR~~ D. Hood E. McKenna C. Berlinger NSIC E. Merschoff PRC System J. Stone PD#11-3 Rdg C. Y. Cheng Project Manager D. Hood A. Toalston M. Duncan W. Hazelton B. Kolcstyak C. Sellers W. Troskoski (MNEB 6113) J. Richardson OGC-Bethesda K. Naidu ACRS (10) K. Wichman B. McIntyre, W S. Hou J. Jelovich, R V. Hodge S. McNeil l

1. Peebles l

S. West l l l l l l l i l l l l l - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _}}