IR 05000302/1988019

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Insp Rept 50-302/88-19 on 880627-0701.No Violations or Deviations Noted.Major Areas Inspected:Licensee Conformance to Reg Guide 1.97
ML20151T219
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 07/28/1988
From: Conlon T, Hunt M
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20151T214 List:
References
RTR-REGGD-01.097, RTR-REGGD-1.097 50-302-88-19, NUDOCS 8808160291
Download: ML20151T219 (10)


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p Hc UNITED STATES oq'o, j

NUCLEAR REGULATOnY COMMISSION

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i REGION il

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,j 101 MARIETTA STREET,N.W.

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t ATLANTA, GEORGI A 30323

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Report No.:

50-302/88-19 Licensee:

Florida Power Corporation 3201 34th Street South St. Petersburg, IL 33733

Docket Fo.:

50-302/88-19 License No.:

OPR-72 Facility Name:

Crystal River 3 Inspection Conducted:

June 27 - July 1, 1988 Inspector:

(l/j M d m h 7/2g/W

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M. D. Hunt

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W ate &51gned Team Members P. J. Fillion M. N. Miller

Approved by:

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}/f/PP 1.~E.~ Conlon, Chief f /

Uate Signed

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Plant Systems Section l

Engineering Sranch

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Division of Reactor Safety SUMMARY Scope:

This routine, announced inspection was in the areas of the licensee's conformance to Regulatory Guide (RG) 1.97.

Results:

In the areas inspected, violations or deviations were not identified.

In general the licensee has performed the insta11at'on and modifica-tions of instrumentation needed to comply with RG 1.97.

There were exceptions noted in the Safety Evaluation Report (SER) issued June 16,1987, as well as items identified during this inspection which are discussed in this report i

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The licensee had recognized the need for updating drawings after completion of modifications (as builts)

and develop:ng instrumentation loop drawings but had placed no priority to the effort.

During the inspectors's review of RG 1.97, discussions were held regarding the updating and develop' ment of drawings.

The licensee was responsive to the inspector s concerns regarding the need to commit more engineering effort to this task and committed to expand this effort.

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REPORT DETAILS 1.

Persons Contacted Licensee Employees-C. Doyel, Mana er, Nuclear Mechanical / Structural Engineering E. E. Freats$e for Nuclear Licensing Engineer upervisor, Nuclear Licensing

  • E. M. Good, Senior Nuclear I&C Engineer
  • R.

Iwachow,

  • W. N. Johnson Nuclear Modification Specialist director,MaintenanceandOutage
  • P.

F. McKee Plant Operations

  • V.

R. Roppe Manager,

  • W.L.RassfId,Manag&CEngineer er, Nuclear Compliance S. H. Slearns, Lead I
  • D. Shook, ink,NuclearEngineer/I&CEngineeringNuclear Electrical /I&C Eng Manager J. E. Uhr E. Welch, Manager, Nuclear Electrical /I&C Engineering Services
  • R. C. Widell, Director, Nuclear Operations Site Support
  • H Williams, Nuclear Regulatory Specialist X. Wilson, Manager, Nuclear Licensing Other licensee employees contacted during this inspection included craftsmen, engineers'nistrative p,ersonnel. mechanics, security force memb operators technicians, and admi NRC Resident Inspector
  • J. E. Tedrow
  • Attended exit interview Acronyms and initialisms used throughout this report are listed in the last paragraph.

2.

The purpose of this inspection was to verify that the licensee has an instrumentation system for assessing variables and systems durin following an accident, as discussed in Regulatory Guide (RG) 1.97.g and Under accident. conditions it is necessary that the operating personnel have (1)

informamn that permits the operator to take prealanned actions to accomplish a safe plant shutdown; (2) determine whe;her the reactor trip, Engineered Safety-Feature Systems (ESFS), and manually initiated safety and other systems important to safety are performing their intended functions; and, (3) provide information to operators that will enable them to determine the potential for a breach of tne radiation release barriers or l' a breach has already occurred.

It is essential that indications be provided to the operator if the barriers are being challenged that will allow the release of radioactive materials.

For this reason multiple instruments with overlapping ranges may be necessary.

The required instrumentation must be capable of surviving the accident environment for the length of time its operability is required.

It is desirable components continue to function following seismic event _ _ - - _ - - - - - - - - - - - - - - - - - - - - - - - - - ------------ - _ ------- - -- - ----------

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As a result, three types of variables have been specified that serve as guides in defininc criteria and the selection of accident-monitoring instrumentation.

The types are:

Type A - Those variables that 3rovided information needed to permit the control room operating personne'

to take specified manual actions for which no automatic control is provided and that are required for safety systems to accomplish their functions for design basis accident events.

Type B - Those variables that 3rovide information to indicate whether plint safety functions are seing accomplished.

Type C - Those variables that provide information to indicate the potential of barriers bein barriers out fission product release. g breached or the actual breach of Type 0 - Those variables that provide information to indicate operation of individual safety systems and other systems important to safety.

Type E - Those variables to be monitored in determining the magnitude of the release of radioactive materials and for continuously assessing such release.

The design and qualification criteria are separated into three separate categories that provide a graded approach to requirements depending on the importance to safety of the measurement of a specific var,able.

Category 1 provides the most stringent requireme * snd intended for key variables.

Category 2 provides less stringent requirements and generally applies to instrumentation designated for indicating system operating status.

Category 3 is intended to provide requirements that will ensure that high quality off-the-shelf instrumentation is obtained and applies to backu) and diagnostic instrumentation.

A key variable is that single variaale (or minimum number of variables) that most directly indicates the accomplishment of a safety function (Types B and C), or the operation of a safety system (Type D), or radioactive material release (Type E).

Type A variables are plant specific and depend; on the operations that the designer chooses for planned manual actions.

Ins and 2 equipment was performed as described below, pection of Categories 1 a.

Category 1 Instrumentation The instrumentation listed in the category 1 Table, of this section, was examined to verify that the design and qualification criteria of RG 1.97 had been satisfied.

The instrumentation was inspected by reviewing drawings, procedures, data sheets, other documentation, and performiag walkdowns for visual observation of the installed equipment.

The following areas were inspected:

(1) Equipment Qualification - The EQ Master Equipment List and the Q-List were reviewed for confirraatio'1 that the licensee had addressed environmental qualification requirements for class 1E equipment.

(2) Redundancy - Walkdowns were performed to verify by visual observation the the specified instrume.its were installed and separation requirements were met.

In addition loop drawin were reviewed, to verify redundancy and channel separation gs

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i (3) Power Sources - Loop drawings were reviewed to verify the instrumentation is energized from a safety-related power source.

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(4) Display and Recording - Walkdowns were performed to verify by visual observation that the specified display and recording t

instruments were installed.

Loop drawings were reviewed to verify there was at least-onc recorder in a redundant channel and two indicators, one per division (channel) for each measured variable.

(5) Ranae - Walkdowns were performed to verify the actual range of the' indicator / recorders was as specified in RG 1.97 or the SER.

Review' of calibration procedures verified sensitivity and overlapping requirements of RG 1.97 for instruments measuring the same variable.

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Interfaces - The loop drawings and Q-List were reviewed to

verify that safety-rela la j isolation devices were used when

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required to isolate the circuits from ncn safety systems.

l (7) Direct Heasurement - Loop drawings were reviewed to verify that the parameters are directly measured by the sensors.

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(8) Service Testing, and Calibration - The maintenance program for perform}ng calibrations and surveillances was reviewed and discussed with the licensee Calibration and surveillance procedures and the latest data sheets for each instrument were reviewed to verify the instruments have a valid calibration.

In several instances the post modification testing was used to verify calibration,.

CATEGORY 1 TA'.g Instrument No.

Instrument Variable (Channel)

Loop Drawings

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1. RCS RC-158PT(A)

205-047 t

Pressure RC-159 PT (B)

Sheet RC-02

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RC-158 PIR

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RC-158 PI2 RC-159 PI2 2. Reactor Vessel (This system is not in service.

See discussion i

of RV Level in Section 2.c 3. Borated water DH-007-LT 1 (A)

205-021

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Storage Tank DH-007-LIR (A)

Sheet DH-03 DH-037-LT(B)

DH-037-LT (8)

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Instrument No.

Instrument Variable (Channel)

Loop Drawings (cont'd)

4. Staam Ger,erator SP-017-LT (A)

205-074 Level SP-017-LIR Sheet SP-01 SP-018-LIl thru SP-04 SP-018-LT (A)

SP-025-LT (A)

SP-025-LIR SP-026-LT (B)

SP-026-LIl SP-021-LT(A)

SP-021-LIR & LI SP-022-LT(B)

SP-022-LT1 5. Steam Generator SP-029-LT (A)

SP-029-LIR and LI SP-030-LT(B)

SP-030-LIR and LI Steam Generator MS-106 PT A & D 205-029 Pressure MS-107 PT Sheet MS-01 MS-110 PT Sheet MS-02 MS-111 MS-106-PIR MS-106-PI MS-107-PIR MS-007-PI MS-110-PIR MS-110-PI MS-111-PIR MS-111-PI Pressurizer RC-001-LT 1 (A)

205-047 Level RC-001-LI 3 (B)

Sheet RC-01 RC-001-LIR 1 RC-001-LIR 3 RC-001-LI 1 RC-001-LT 3 Aux FW Flow EF-23-FT (A)

205-026 EF-23-FI Sheet EF-01 & 02 EF-25-FT (A)

EF-25-FI EF-24-FT (B)

EF-24-FT EF-26-FT(B)

EF-26-FI i

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Instrument No.

i Instrument Variable (Channel)

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Loop Drawings (cont'd)

4. Steam Generator SP-017-LT(A)

205-074.

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Condensate EF-098-LT(A)

205-026

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Tank Laval EF-098-LI Sheet EF-05 (Emergency EF-099-LT(B)

Feedwater EF-099-LI Supply)

Containment WD-3038-LT(A)

205-060 Sump Level WD-303-LR Sheet WD-03 (Flood Level)

WD-3038-LI WD-3048-LT (B)

WD-304-LR WD-304-LI A)

205-047 RCS Hot Leg RC-004A-TE-1(A)

RC-005A-TE-2 (

Sheet RC-04- & 10 Temperature RC-004A-TIR1 RC-005A-TI RC-0048-TE4(B)

RC-005B-TE4 (B)

i RC-0048-RI 4-1 Containment BS-016-PT(A)

205-009 Pressure BS-016-PI Sheet 85-01 BS-017-PT(B)

BS-017-PI BS-090-PT(A)

BS-090-FI

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BS-090-PR BS-091-PT(B)

BS-091-PI BS-091-PR b.

Category 2 Instrumentation The instrumentation listed in the Category 2 Table, of this section,

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was examined to verify that the design and qualification criteria of

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j RG 1.97 had been satisfied.

The instrumentation was inspected by reviewing drawings, procedures, data sheets, other documentation and performing walkdowns for visual observation of the installed equipment.

The following areas were inspected:

(1) Equipment Qualification - The EQ Master Equipment List and the

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Q-List were reviewed for confirmation that the licensee had addressed environmental qualification requirements for Class IE

equipment.

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(2) Power Sources - Loop drawings were reviewed to verify the instrumentation is energized from a high quality or a safety-related pcwer source.

(3) Display and Recording - Walkdowns were performed to verify by visual observation that the specified display and recording instruments were installed.

Loop drawings were reviewed to verify there was a least one recorder, where required by RG 1.97, in a redundant channel and two indicators, one per division (channel) for each measure variable.

(4) Range - Walkdowns were performed to varify the actual range of the indicators / recorders was as specified in PG 1.97 or the SER.

Review of calibration procedures verified sensitivity and overlapping requirements of RG 1.97 for instruments measuring the same variable.

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Interfaces - The loop drawings and Q-List were reviewed to verify that safety-related isolation devices are used when required to isolate the circuits from computer systems (Not safety-related).

(6) Direct Measurement - Loop drawings were reviewed to verify that the parameters are directly measured by the sensors.

(7) Service Testing, and Calibration - The maintenance program for performing calibrations and surveillances was reviewed and discussed with the licensee.

Calibration and surveillance procedures and the latest data sheets for each instrument were reviewed to verify the instruments have a valid calibration.

In several instances, the post modification testing was used to verify calibration.

CATEGORY 2 TABLE Variable Instrument (Channel)

Loop Drawing Containment Sump WD-301-LT (A)

205-060 Water Level (Narrow WD-301-LI Sheet WD-01 Range)

WD-301-LR

WD-302-LT (B)

WD-302-LI 302-LR

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Containment Atmosphere AH-536-Tf.

205-005 AH-537-TE Sheet AH-01 AH-538-TE AH-539-TE

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Variable Instrument (Channel)

Loop Drawing (cont'd)

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Containment Spray BS-001-0PT1(A)

803 4036E Flow BS-001 FIl 85-001DPT2(B)

8S-001 FI2 RHR System DH-001-FT3 (A)

205-021 Flow OH-001-FI3-1 Sheet DH-01-02 DH-001-FT4 (B)

DH-001-FI4-4 Low Pressure Same as RHR Flow by valve positioning

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InjectionFlow UH-002-TE1(A)

205-021 RHR Heat

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DH-002-TIl and 7E2 (B)

Sheet DH-04 Exchanger Outlet DH-002-TI2 Temperature Accumulator Tank Indicating 208-013 Isolation Valve Lights from Sheet CF-01 Position MOV position Limit Switches CFV-5 & CFV-6

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High Pressure MU-023-0PT8 A 205-041 Injection Flow MU-023-FI8-1 Sheet MU-01 T004 MU-023-0PT6(B)

MU-023-FI6-1 MU-023-0PT7 MU-023-FI7-1

MU-023-0PT5 MU-023-FI5-1 l

RCS Relief Valve RC-160-ME 1 RE-160 mil 205-047 Monitoring RC-160-ME 2 RE-160-MI2 Sheet RC-17

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RC-160-ME 3 RE-160-MI3 c.

Discussion The licensee, Florida Power Corporation (FPC), was requested by generic Letter 82-33 to provide a report to the NRC describing how

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the post-accident monitoring instrumentation meets the guidelines

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of Regulatory Guide (RG) 1.97 as applied to emergency response i

facilities.

The licensee's response to RG 1.97 was provided by letters dated August 21, 1984, November 15, 1985, and March 27, 1986.

As the result of a detailed review and technical evaluation of the submittals, the NRC issued the Safety Evaluation Report (SER) b[on letter dated June 16, 1987.

Tr.e evaluation identified an except for the instrumentation for monitoring the status of the pressurizer heaters.

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FPC submittal a revised set of variable sheets by letter dated

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March 21, 1988, which stated (1) FPC will install environmentally qualified current measurement instrumentation to monitor the status of the pressurizer heaters during an emergency.

(2) FPC will install valve position indication for the Main Steam Safety / Relief Valves and the Atmospheric Dump Valves.

(3) FPC is still planning to complete the "on demand" displays for the Reactor Building High Range Radiation Monitors and the sump level variables into Recall by September 1988.

This will be accomplished by the end of Refuel VII scheduled for Fall 1989.

During the walkdowns and review of docume_nts and drawings, the following three Inspector Followp Items (IFIs) were identified i

which will require further evaluation by the NRC to determine acceptability:

F IFI 302/88-19-01, No Specific Identification for Instruments on the Control Boards.

There is no special designation for the operator to easily discern which instruments are intended for RG 1.97 under accident conditions.

This identification for type A, B, and C instruments designated a!, Categories 1 and 2 is characteristically identified by specially colored name plates.

The licensee advised that the Emergency Operation Procedure (EOP) do not specify meters, indicators recorders... etc by name plate.

The E0P's are system and

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symptom oriented and the operator is required to know the control

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board location of the system of which the specific meter is a 3 art.

The inspector was advised that the control board labeling wou'd be addressed in a control board labeling review.

IFI 302/88-19-02, Verify that Containment Atmospheric Temperature Recorder is located Properly.

The March 21, 1988, submittal regarding the containment atmospheric temperature states that this Category 2 variable is recorded in the control room.

It was assumed by the reviewers that this statement mean the recorder is located on the front on the main control board.

The recorder is locsted on the back of the control ocard.

This location will be evaluated further.

IFI 302/88-19-03, Verify Adequacy of Emercency Power Source Indication.

The licensee has installed ind:cating lights on the control board to indicate the status of standby power.

There are RED and GREEN indication lights to indicate the failure to Inverter 3A, 3B 30, and 30; 250 VDC battery 3A and 3B; 4160 Volt Bus IA and 3B; 48d volt bus 3A and 3B; and Diesel Generator A and B.

While a light

r may indicate that power is available or not available it in no way

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L indicates the quality of power.

Since a relay is make or break type component, a determining voltage condition would not be observed until the voltage had reached the operation point of the relay or sensing device.

These items will be examined further by the staff to determine the acceptability of each application.

It should be noted that the licensee has installed level transmitters i

to measure the reactor vessel level.

The taps are located between the reactor coolant hot and cold legs, and results in a measurement

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of flow when there is flow through the system.

The NRC has not given the licensee the necessary criteria to place these level transmitters

in service.

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Within the area examined, no violation or deviations were identified.

3.

Exit Interview The inspection scope and results were summarized on July 1,1988, with those persons indicated in

)aragraph 1.

The inspectors described the areas 'nspected and ciiscussec in detail the inspection items and concerns.

Proprietary information is not contained in this report.

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Acronyms and Initialisms AUXFW(AFW)

Auxiliary Feedwater (System)

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Differential Pressure Transmitter OPT

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FI Flow Indicator

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F1 Flow Transmitter

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LI Level Indicators

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LIR Level Indicating Recorder

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Level Recorder LR

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Level Transmitter LT

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Pressure Indicator PI

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Pressure Indicating Recorder PIR

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PR Pressure Recorder

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Pressure Transmitter PT

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Residual Heat Removal (System)

RHR

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Reactor Coolant RC

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Reactor Coolant System RCS

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Rcgulator Guide RG

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Safety Evaluation Report SER

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Temperature Element TE

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Temperature Indicator TI

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Temperature Indicating Recorder TIR

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Temperature Transmitter TI

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