ML11356A244

Revisions to the Technical Requirements Manual and Units 1 and 2 Technical Specification Bases

ML11356A244
Person / Time
Site:	Sequoyah
Issue date:	12/16/2011
From:	James Shea Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML11356A244 (17)

Text

Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 December 16, 2011 10 CFR 50.4 10 CFR 50.71(e)

ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Sequoyah Nuclear Plant, Units 1 and 2 Facility Operating License Nos. DPR-77 and DPR-79 NRC Docket Nos. 50-327 and 50-328

Subject:

Revisions to the Sequoyah Nuclear Plant Technical Requirements Manual and Units 1 and 2 Technical Specification Bases

References:

1. NRC Letter to TVA, "Issuance of Exemption to 10 CFR 71 (e)(4) for the Sequoyah Nuclear Plant, Units 1 and 2 (TAC Nos. MA0646 and MA0647),"

dated March 9, 1998

2. TVA Letter to NRC, "Revisions to the Sequoyah Nuclear Plant Technical Requirements Manual and Sequoyah Nuclear Plant, Units 1 and 2, Technical Specification Bases," dated May 24, 2010 Pursuant to 10 CFR 50.71(e) and the Reference 1 letter, updates to the Sequoyah Nuclear Plant (SQN) Updated Final Safety Analysis Report (UFSAR) for both Units 1 and 2 are to be submitted after each Unit 2 refueling outage, not to exceed 24 months between successive revisions. The SQN Technical Requirements Manual (TRM) is incorporated by reference into the SQN UFSAR. SQN Technical Specification 6.8.4.j, "Technical Specification (TS) Bases Control Program," requires changes to the SQN TS Bases to be submitted in accordance with 10 CFR 50.71(e). The previous revisions of the SQN TRM and TS Bases were submitted in Referenced Letter 2. The last Unit 2 refueling outage ended on June 22, 2011. As such, TRM and TS Bases revisions issued since May 24, 2010, are required to be submitted by December 19, 2011. The enclosure to this letter provides a description of the TRM and TS Bases revisions with attachments of the updated pages, respectively.

Printed on recycled paper

U.S. Nuclear Regulatory Commission Page 2 December 16, 2011 There are no commitments contained in this letter. If you have any questions, please contact Clyde Mackaman at (423) 751-2834.

I certify that I am duly authorized by TVA, and that, to the best of my knowledge and belief, the information contained herein accurately presents changes made since the previous submittal, necessary to reflect information and analyses submitted to the Commission or prepared pursuant to Commission requirements.

Respectf J

.Shea a ager, Corporate Nuclear Licensing

Enclosure:

Description of Revisions for the Sequoyah Nuclear Plant (SQN), Technical Requirements Manual and SQN, Units 1 and 2 Technical Specification Bases cc (Enclosure):

NRC Regional Administrator-Region II NRC Senior Resident Inspector - Sequoyah Nuclear Plant

ENCLOSURE DESCRIPTION OF REVISIONS FOR THE SEQUOYAH NUCLEAR PLANT (SQN),

TECHNICAL REQUIREMENTS MANUAL AND SQN, UNITS I AND 2 TECHNICAL SPECIFICATION BASES Revision 46 to the Sequoyah Nuclear Plant (SQN) Technical Requirements Manual (TRM) was approved and implemented on November 29, 2010. This revision was associated with SQN, Units 1 and 2, Amendments Nos. 264 and 255 for Technical Specification (TS) Change 00-05, "Relocation of Reactivity Control Requirements to the TRM in Accordance with 10 CFR 50.36."

This TRM revision corrects a typographical error that was created during the relocation.

Specifically, the Action Statement corrected the plant mode to be in if the necessary boron injection flow paths were not restored Operable within the allowed action time.

Revision 36 to the SQN, Units 1 and 2 TS Bases was approved on May 18, 2010 and implemented on May 27, 2010. The revision was in light of TS Change 07-05, "Emergency Core Cooling Systems (ECCS)" for SQN, Units 1 and 2, Amendment Nos. 326 and 319. This revision further describes necessary manual actions for realignment of the residual heat removal (RHR) train in the event of a loss of coolant accident during Mode 4 operation. These actions are reflected in the TS limiting condition for operation (LCO) 3.5.3, "ECCS - Shutdown" and LCO 3.6.2.1, "Containment Spray Subsystems."

Attachments:

1.

2.

3.

Sequoyah Nuclear Plant, Technical Requirements Manual - Changed Pages Sequoyah Nuclear Plant, Unit 1, Technical Specification Bases - Changed Pages Sequoyah Nuclear Plant, Unit 2, Technical Specification Bases - Changed Pages

ATTACHMENT 1 SEQUOYAH NUCLEAR PLANT TECHNICAL REQUIREMENTS MANUAL CHANGED PAGES TRM Affected Pages EPL - 2 EPL - 8 3/4 1-3

SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 TECHNICAL REQUIREMENTS MANUAL EFFECTIVE PAGE LISTING Page Revision 3/4 1-3 11/29/10 3/4 1-4 10/12/05 3/4 1-5 01/04/01 3/4 1-6 10/19/05 3/4 1-7 01/04/01 3/4 1-9 06/20/05 3/4 1-10 09/26/03 3/4 1-11 01/04/01 3/4 1-12 01/04/01 3/4 3-1 01/20/06 3/4 3-2 01/20/06 3/4 3-3 01/20/06 3/4 3-4 01/20/06 3/4 3-5 01/20/06 3/4 3-6 10/17/06 3/4 3-7 04/26/06 3/4 3-8 04/26/06 3/4 3-9 01/20/06 3/4 3-10 01/20/06 3/4 4-1 01/20/06 3/4 4-2 01/20/06 3/4 4-3 01/20/06 EPL-2 November 29, 2010

SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 TECHNICAL REQUIREMENTS MANUAL REVISION LISTING Date Revision Initial Issue, Revision 1 Revision 2 Revision 3 Revision 4 Revision 5 Revision 6 Revision 7 Revision 8 Revision 9 Revision 10 Revision 11 Revision 12 Revision 13 Revision 14 Revision 15 Revision 16 Revision 17 Revision 18 Revision 19 Revision 20 Revision 21 Revision 22 Revision 23 Revision 24 Revision 25 Revision 26 Revision 27 Revision 28 Revision 29 Revision 30 Revision 31 Revision 32 Revision 33 Revision 34 Revision 35 Revision 36 Revision 37 Revision 38 Revision 39 Revision 40 Revision 41 Revision 42 Revision 43 Revision 44 Revision 45 Revision 46 Revision 0 02/02/98 10/01/98 02/12/99 03/18/99 09/14/99 10/24/99 09/29/99 12/09/99 03/23/00 06/02/00 06/13/00 06/15/00 11/09/00 01/04/01 04/05/01 07/11/01 04/05/02 03/27/02 07/19/02 07/25/02 10/11/02 03/06/03 08/11/03 09/14/03 09/28/03 10/31/03 09/26/03 09/26/03 05/15/04 10/13/04 10/13/04 04/22/05 05/27/05 06/20/05 06/24/05 10/12/05 10/19/05 01/20/06 03/08/06 03/17/06 04/26/06 07/25/06 09/15/06 10/17/06 11/14/06 05/18/09 11/29/10 EPL-8 November 29, 2010

REACTIVITY CONTROL SYSTEMS FLOW PATHS - OPERATING LIMITING CONDITION FOR OPERATION TR 3.1.2.2 At least two of the following three boron injection flow paths shall be OPERABLE:

a.

The flow path from the boric acid tanks via a boric acid transfer pump and a charging pump to the Reactor Coolant System.

b.

Two flow paths from the refueling water storage tank via charging pumps to the Reactor Coolant System.

APPLICABILITY: MODES 1,2, and 3.

ACTION:

With only one of the above required boron injection flow paths to the Reactor Coolant System OPERABLE, restore at least two boron injection flow paths to the Reactor Coolant System to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY and borated to a SHUTDOWN MARGIN equivalent to at least 1% delta k/k at 200OF within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />; restore at least two flow paths to OPERABLE status within the next 7 days or be in HOT SHUTDOWN within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE REQUIREMENTS TR 4.1.2.2 At least two of the above required flow paths shall be demonstrated OPERABLE:

a.

At least once per 7 days by verifying that the temperature of the areas containing flow path components from the boric acid tanks to the blending tee is greater than or equal to 630F when it is a required water source.

b.

Whenever the area temperature(s) is(are) less than 630F and the boric acid tank is a required water source, the solution temperature in the flow path components from the boric acid tank must be measured to be greater than or equal to 630F within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter until the area temperature(s) has(have) returned to greater than or equal to 63 0F.

c.

At least once per 31 days by verifying that each valve (manual, power operated or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position.

d.

At least once per 18 months during shutdown by verifying that each automatic valve in the flow path actuates to its correct position on a safety injection test signal.

e.

At least once per 18 months by verifying that the flow path required by TR 3.1.2.2a delivers at least 35 gpm to the Reactor Coolant System.

SEQUOYAH - UNITS 1 AND 2 3/4 1-3 November 29, 2010 TECHNICAL REQUIREMENTS Revision Nos. 13, 46

ATTACHMENT 2 SEQUOYAH NUCLEAR PLANT, UNIT 1 TECHNICAL SPECIFICATION BASES CHANGED PAGES TS Bases Affected Pages EPL - 20 EPL - 33 B 3/4 5-13 B 3/4 6-3

SEQUOYAH NUCLEAR PLANT UNIT 1 TECHNICAL SPECIFICATIONS EFFECTIVE PAGE LISTING Page Revision B3/4 4-23 11/09/04 B3/4 5-1 03/25/10 B3/4 5-2 03/25/10 B3/4 5-3 03/25/10 B3/4 5-4 03/25/10 B3/4 5-5 03/25/10 B3/4 5-6 03/25/10 B3/4 5-7 03/25/10 B3/4 5-8 through B3/4 5-12 03/25/10 B3/4 5-13 05/27/10 B3/4 5-14 through B3/4 5-19 03/25/10 B3/4 6-1 through B3/4 6-2 04/13/09 B3/4 6-3 05/27/10 B3/4 6-4 through B3/4 6-6 04/13/09 B3/4 6-7 through B3/4 6-12 04/13/09 B3/4 6-13 through B3/4 6-18 04/13/09 B3/4 6-19 through B3/4 6-20 04/13/09 B3/4 6-21 04/13/09 B3/4 7-1 04/30/02 B3/4 7-2 08/14/01 B3/4 7-2a 11/17/95 EPL-20 May 27, 2010

SEQUOYAH NUCLEAR PLANT UNIT 1 TECHNICAL SPECIFICATIONS AMENDMENT LISTING Amendments Revisions Bases Revision Bases Revision Amendment 328 issued by NRC 03/25/10 (BR-35) 05/27/10 (BR-36) 12/21/10 EPL-33 December 21, 2010

ECCS - Shutdown B 3/4.5.3 BASES LCO (continued)

This LCO is modified by a Note that allows an RHR train to be considered OPERABLE during alignment and operation for decay heat removal, if capable of being manually realigned (remote or local) to the ECCS mode of operation and not otherwise inoperable. The manual actions necessary to realign the RHR subsystem may include actions to cool the RHR system piping due to the potential for steam voiding in piping or for inadequate NPSH available at the RHR pumps. This allows operation in the RHR mode during MODE 4.

APPLICABILITY In MODES 1, 2, and 3, the OPERABILITY requirements for ECCS are covered by LCO 3.5.2.

In MODE 4 with RCS temperature below 350 0F, one OPERABLE ECCS train is acceptable without single failure consideration, on the basis of the stable reactivity of the reactor and the limited core cooling requirements.

In MODES 5 and 6, plant conditions are such that the probability of an event requiring ECCS injection is extremely low. Core cooling requirements in MODE 5 are addressed by LCO 3.4.1.4, "Reactor Coolant System Cold Shutdown." MODE 6 core cooling requirements are addressed by LCO 3.9.8.1 "Residual Heat Removal and Coolant Circulation - All Water Levels," and LCO 3.9.8.2 "Residual Heat Removal and Coolant Circulation - Low Water Level."

ACTIONS A Note prohibits the application of LCO 3.0.4b to an inoperable ECCS high head subsystem when entering MODE 4. There is an increased risk associated with entering MODE 4 from MODE 5 with an inoperable ECCS high head subsystem and the provisions of LCO 3.0.4b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

A second Note allows the required ECCS RHR subsystem to be inoperable because of surveillance testing of RCS pressure isolation valve leakage (FCV-74-1 and FCV-74-2). This allows testing while RCS pressure is high enough to obtain valid leakage data and following valve closure for RHR decay heat removal path. The condition requiring alternate heat removal methods ensures that the RCS heatup rate can be controlled to prevent MODE 3 entry and thereby ensure that the reduced ECCS operational requirements are maintained. The condition requiring manual realignment capability, FCV-74-1 and FCV-74-2 can be opened from the main control room ensures that in the unlikely event of a DBA during the one hour of surveillance testing, the RHR subsystem can be placed in ECCS recirculation mode when required to mitigate the event.

May 27, 2010 SEQUOYAH - UNIT 1 B 3/4 5-13

CONTAINMENT SYSTEMS BASES 3/4.6.1.8 EMERGENCY GAS TREATMENT SYSTEM (EGTS)

The OPERABILITY of the EGTS cleanup subsystem ensures that during LOCA conditions, containment vessel leakage into the annulus will be filtered through the HEPA filters and charcoal adsorber trains prior to discharge to the atmosphere. This requirement is necessary to meet the assumptions used in the accident analyses and limit the site boundary radiation doses to within the limits of 10 CFR 100 during LOCA conditions. Cumulative operation of the system with the heaters on for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> over a 31 day period is sufficient to reduce the buildup of moisture on the absorbers and HEPA filters. ANSI N510-1975 will be used as a procedural guide for surveillance testing.

3/4.6.1.9 CONTAINMENT VENTILATION SYSTEM This specification has been relocated.

3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS 3/4.6.2.1 CONTAINMENT SPRAY SUBSYSTEMS The OPERABILITY of the containment spray subsystems ensures that containment depressurization and cooling capability will be available in the event of a LOCA. The pressure reduction and resultant lower containment leakage rate are consistent with the assumptions used in the accident analyses.

Manual actions are required to align the containment spray system for sump recirculation. In Mode 4 when RHR shutdown cooling is in service, these manual actions may include local actions to cool the RHR suction piping (portions of which is shared by Containment Spray) to ensure adequate NPSH.

3/4.6.2.2 CONTAINMENT COOLING FANS The OPERABILITY of the lower containment vent coolers ensures that adequate heat removal capacity is available to provide long-term cooling following a non-LOCA event. Postaccident use of these coolers ensures containment temperatures remain within environmental qualification limits for all safety-related equipment required to remain functional.

May 27, 2010 SEQUOYAH - UNIT 1 B 3/4 6-3 Amendment No. 67, 114, 150, 159, 203, 323

ATTACHMENT 3.

SEQUOYAH NUCLEAR PLANT, UNIT 2 TECHNICAL SPECIFICATION BASES CHANGED PAGES TS Bases Affected Pages EPL - 19 EPL - 31 B 3/4 5-13 B 3/4 6-3

SEQUOYAH NUCLEAR PLANT UNIT 2 TECHNICAL SPECIFICATIONS EFFECTIVE PAGE LISTING Paqe Revision B3/4 5-1 03/25/10 B3/4 5-2 03/25/10 83/4 5-3 03/25/10 B3/4 5-4 03/25/10 B3/4 5-5 03/25/10 B3/4 5-6 03/25/10 B3/4 5-7 03/25/10 83/4 5-8 through B3/4 5-12 03/25/10 83/4 5-13 05/27/10 83/4 5-14 through 83/4 5-19 03/25/10 B3/4 6-1 through 83/4 6-2 04/13/09 B3/4 6-3 05/27/10 B3/4 6-4 through B3/4 6-6 04/13/09 B3/4 6-7 through 83/4 6-12 04/13/09 83/4 6-13 through B3/4 6-18 04/13/09 83/4 6-19 through B3/4 6-20 04/13/09 83/4 6-21 04/13/09 83/4 7-1 04/30/02 83/4 7-2 08/14/01 B3/4 7-2a 11/17/95 83/4 7-2b 04/11/05 83/4 7-3 06/12/09 EPL-19 May 27, 2010

SEQUOYAH NUCLEAR PLANT UNIT 2 TECHNICAL SPECIFICATIONS AMENDMENT LISTING Amendments Amendment 288 Issuedby NRC Amendment 289 Issued by NRC Amendment 290 Issued by NRC Amendment 291 Issued by NRC Amendment 292 Issued by NRC Amendment 293 Issued by NRC Amendment 294 Issued by NRC Bases Revision Amendment 295 Issued by NRC Amendment 296 Issued by NRC Amendment 297 Issued by NRC Amendment 298 Issued by NRC Amendment 299 Issued by NRC Amendment 300 Issued by NRC Amendment 301 Issued by NRC Amendment 302 Issued by NRC Amendment 303 Issued by NRC Amendment 304 Issued by NRC License Condition Issued by NRC Bases Revision Amendment 305 Issued by NRC EPL Revised License Condition Issued by NRC Amendment 306 Issued by NRC Amendment 307 Issued by NRC Amendment 308 Issued by NRC Date and Revision 03/09/05 (R288) 04/05/05 (R289) 04/11/05 (R290) 05/03/05 (R291) 05/24/05 (R292) 08/18/05 (R293) 09/02/05 (R294) 09/11/03 (BR-28) 12/28/05 (R295) 04/06/06 (R296) 06/16/06 (R297) 08/02/06 (R298) 09/13/06 (R299) 09/14/06 (R300) 10/04/06 (R301) 11/07/06 (R302) 11/16/06 (R303) 12/11/06 (R304) 02/08/07 03/07/07 (BR-29) 05/22/07 (R305) 05/22/07 08/09/07 (B.5.b) 09/20/07 (R306) 09/28/07 (R307) 10/11/07 (R308) 12/12/07 (BR-30) 03/24/08 (R309) 04/02/08 (R31 0) 04/04/08 (R31 1) 08/29/08 (R312) 08/29/08 (BR-31) 08/28/08 (BR-32) 10/28/08 12/04/08 04/13/09 06/12/09 06/12/09 (BR-33) 08/14/09 10/19/09 10/19/09 (BR-34) 01/28/10 02/02/10 03/25/10 (BR-35) 05/27/10 (BR-36) 12/21/10 Bases Revision Amendment 309 Amendment 310 Amendment 311 Amendment 312 Bases Revision Bases Revision Amendment 313 Amendment 314 Amendment 315 Amendment 316 Bases Revision Amendment 317 Amendment 318 Bases Revision Amendment 319 Amendment 320 Bases Revision Bases Revision Amendment 321 Issued by NRC Issued by NRC Issued by NRC Issued by NRC Issued by NRC Issued by NRC Issued by NRC Issued by NRC Issued by NRC Issued by NRC Issued by NRC Issued by NRC Issued by NRC EPL-31 December 21, 2010

ECCS - Shutdown B 3/4.5.3 BASES LCO (continued)

This LCO is modified by a Note that allows an RHR train to be considered OPERABLE during alignment and operation for decay heat removal, if capable of being manually realigned (remote or local) to the ECCS mode of operation and not otherwise inoperable. The manual actions necessary to realign the RHR subsystem may include actions to cool the RHR system piping due to the potential for steam voiding in piping or for inadequate NPSH available at the RHR pumps. This allows operation in the RHR mode during MODE 4.

APPLICABILITY In MODES 1, 2, and 3, the OPERABILITY requirements for ECCS are covered by LCO 3.5.2.

In MODE 4 with RCS temperature below 350'F, one OPERABLE ECCS train is acceptable without single failure consideration, on the basis of the stable reactivity of the reactor and the limited core cooling requirements.

In MODES 5 and 6, plant conditions are such that the probability of an event requiring ECCS injection is extremely low. Core cooling requirements in MODE 5 are addressed by LCO 3.4.1.4, "Reactor Coolant System Cold Shutdown." MODE 6 core cooling requirements are addressed by LCO 3.9.8.1 "Residual Heat Removal and Coolant Circulation - All Water Levels," and LCO 3.9.8.2 "Residual Heat Removal and Coolant Circulation - Low Water Level."

ACTIONS A Note prohibits the application of LCO 3.0.4b to an inoperable ECCS high head subsystem when entering MODE 4. There is an increased risk associated with entering MODE 4 from MODE 5 with an inoperable ECCS high head subsystem and the provisions of LCO 3.0.4b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

A second Note allows the required ECCS RHR subsystem to be inoperable because of surveillance testing of RCS pressure isolation valve leakage (FCV-74-1 and FCV-74-2). This allows testing while RCS pressure is high enough to obtain valid leakage data and following valve closure for RHR decay heat removal path. The condition requiring alternate heat removal methods ensures that the RCS heatup rate can be controlled to prevent MODE 3 entry and thereby ensure that the reduced ECCS operational requirements are maintained. The condition requiring manual realignment capability, FCV-74-1 and FCV-74-2 can be opened from the main control room ensures that in the unlikely event of a design basis accident during the one hour of surveillance testing, the RHR subsystem can be placed in ECCS recirculation mode when required to mitigate the event.

May 27, 2010 SEQUOYAH - UNIT 2 B 3/4 5-13

CONTAINMENT SYSTEMS BASES 3/4.6.1.8 EMERGENCY GAS TREATMENT SYSTEM (EGTS)

The OPERABILITY of the EGTS cleanup subsystem ensures that during LOCA conditions, containment vessel leakage into the annulus will be filtered through the HEPA filters and charcoal adsorber trains prior to discharge to the atmosphere. This requirement is necessary to meet the assumptions used in the accident analyses and limit the site boundary radiation doses to within the limits of 10 CFR 100 during LOCA conditions. Cumulative operation of the system with the heaters on for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> over a 31 day period is sufficient to reduce the buildup of moisture on the absorbers and HEPA filters. ANSI N510-1975 will be used as a procedural guide for surveillance testing.

3/4.6.1.9 CONTAINMENT VENTILATION SYSTEM This specification has been relocated 3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS 3/4.6.2.1 CONTAINMENT SPRAY SUBSYSTEMS The OPERABILITY of the containment spray subsystems ensures that containment depressurization and cooling capability will be available in the event of a LOCA. The pressure reduction and resultant lower containment leakage rate are consistent with the assumptions used in the accident analyses.

Manual actions are required to align the containment spray system for sump recirculation. In Mode 4 when RHR shutdown cooling is in service, these manual actions may include local actions to cool the RHR suction piping (portions of which is shared by Containment Spray) to ensure adequate NPSH.

3/4.6.2.2 CONTAINMENT COOLING FANS The OPERABILITY of the lower containment vent coolers ensures that adequate heat removal capacity is available to provide long-term cooling following a non-LOCA event. Postaccident use of these coolers ensures containment temperatures remain within environmental qualification limits for all safety-related equipment required to remain functional.

May 27, 2010 SEQUOYAH - UNIT 2 B 3/4 6-3 Amendment No. 59, 140, 149, 193, 315