ML18018B635
| ML18018B635 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 04/02/1984 |
| From: | Baker E, Kleinsorge W, Norman D, Patapovs U, Potapovs U NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML18018B636 | List: |
| References | |
| 50-400-84-05, 50-400-84-5, NUDOCS 8404230274 | |
| Download: ML18018B635 (13) | |
See also: IR 05000400/1984005
Text
~ ENCLOSURE
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
DIVISION OF QUALITY ASSURANCE,
SAFEGUARDS,
AND INSPECTION
PROGRAMS
VENDOR PROGRAM BRANCH
4
Report No.:
50-400/84-05
Docket No.:
50-400
Licensee:
Carolina
Power
8 Light Company
411 Fayetteville Street
Ra1eigh,
27602
Facility Name:
Shearon Harris Nuclear Power Plant.(SHNPP),
Unit I
Inspection at:
Shearon Harris Nuclear:Power Plant,
New Hill, North Carolina
,Inspection
Conducted:
February
6 to February
10,
1984
= Inspectors:
~ i J i
E. T. Baker, Reactor Construction
Engineer,
(Team Leader)
E
g,i,s,,
D. Norman, Mechanica
ngineer,
E
8A ~~
Date Signed
at
igned
~II.P.K
i
1.
gi
ngineer,
Region
t
S gne
4
Approved by:
is Pot
s,
ie
~~ Vendor Program Branch
Division of Quality Assurance,
Safeguards,
and Inspection
Programs
. Office of Inspection
and Enforcement
Ins ection Sugar:
Inspection
on February
6 to February 10, 1984.
Areas Ins ected:
This announced
inspection involved 88 inspection
hours onsite
. sn the areas
o .licensee
implementation of the
SHNPP qua1i.ty assurance
progra~
with respect
to The 'Bahnson
Company
(HVAC equipment supplier)
and the Heating,
. Ventilating, and Air Conditioning
(HVAC) equipment supplied
by The Bahnson
Company installed in the field.
Results:
In the. areas
examined
two potential enforcement'ctions
were identified
and were provided to Region II for appropriate action;
one potential
enforcement
action
was found in the area of adequate
corrective action and the other was, for
failure to control purchased
equipment.
Both potentia1
enforcement actions are
based
on
a failure to identify and correct nonconforming conditions
on
equipment.
h
DETAILS
1.
Persons
Contacted
Carolina- Power 5 Li ht
CP8L
N. J. Chiangi, Harris Plant gA/gC Manager
- D. Deal, Engineering
- G. L. Forehand,
Director gA/QC
- P. Foscolo; Assistant
General
Project Manager
- E. M. Harris, Jr., Principle Mechanical
Engineer
- K. V. Hate', Princip1e
gA Engineer
J.
Hooks, Engineering
- T. W. Johnson,
Resident
Engineer,
L. I. Loflin, Manager,
Engineering
- D. A. McGaw, Superintendent
- gA
- G; R. Osman, Principle gA/qC Specialist - NDE
- R. M. Parson,
Project General
Manager
W. Pere,
Welding Inspector
J. Pierce,
Engineering
- A. H. Rager,
Resident
Engineer - Hangers
- L. Rowell, Engineering
- G. M. Simpson, Principle Construction
- R. A. Stewart, Project Engineer
- M. f. Thompson, Jr., Principle Mechanical
Engineer
- M. D. Vernon, Superintendent
- gC
- R. A. Watson,
Vice President - Harris Nuclear Project
Daniel Construction
Com an
DCC
- W. D. Goodman, Project Manager
~II
i
h
fl
- B. Blevins, Engineering
- J. J. Blake, Section Chief, Region II
- G. F. Maxwel'l, Senior Resident - Operations
- R. L. Prevatte,
Senior Resident - Construction
~
- denotes attendees
at exit meeting february 10, 1984.
h
" 'NOTE."
The inspectors
also conferred with other -licensee
and contractor
personnel
during the course of the inspection.
2..
Exit Interview
The inspection
scope
and findings were summarized
on February
10, 1984,
with those
persons
indicated in paragraph
1 above.
The inspectors
described
the areas
inspected
and described
in detail the. inspection
findings. listed below.
At no time during this inspection
was written material
provided to the
licensee
by the inspectors.
3.
Licensee Action on Previous
Ins ection Findin s
Not applicable.
4.
Unresolved
Items
Unresolved
items are matters
about which more information is required to
determine whether they are violations or deviations.
Unresolved
items are
discussed
in paragraphs
5.d.(1), 5.d.(2), 6.a.(1),
and 6.c.(1).
5.
Heatin
Yentilatin
, and Air Conditionin
HVAC Air Cleanin
Un'its
The inspectors
performed detailed inspections of six safety. related
'ir
Cleaning Units manufactured
by The Bahnson
Company for CTI-Nuclear
(CTIN) to be supplied to Carolina
Power and Light (CP8L).
The inspections
as-indicated
below, were conducted
using criteria established
to the
applicable
Ebasco Specification
(CAR-. SH-BE-31),
CTIN Drawings, Seismic
gualification Reports,
and
CPRL drawings, to determine whether the
fabrication', receiving inspection,
handling,
and storage
were consistent
with applicable drawings,
procedures,
specifications
and regulatory
requirements.
All the Air Cleaning Units had been accepted
by CPSL.
a.
Weldin
Visual Ins ection
The inspectors
made
a visual examination of selected
on the
below listed units relative to the following:
location, length,
size
and shape;
weld surface finish and appearance;
transitions
between different wall thicknesses;
weld reinforcement height
and appearance;
joint configuration of permanent
attachments
and
structural
supports;
removal of temporary attachments;
arc strikes
and weld spatter; finish-grinding of machining of weld surface--
surface finish and absence of wall thinning; surface defects
cracks,
laps,
and lack of penetration,
lack of fusion, porosity,
slag, oxide film and undercut exceeding
prescribed limits.
Ident ification
1A - SA
,2A -* SA
2B - SB
.- 1A-SA-1B-SB
2A-SA-2B-SB
~Sd
. T
HVAC Air Cleaning Unit E-6
HVAC Air Cleaning Unit E-6
HVAC Air Cleaning Unit E-6
HYAC Air Cleaning Unit E-6
HVAC Air Cleaning Unit R-2
HVAC Air Cleaning Unit R-2
During the inspection
the following conditions were obser ved:
(1)
The weld requirements for attaching
the High Energy Particulate
Absorption
(HEPA) filter rack (Item 2 on CTIN Drawing 32735A)
to the unit housing are for a continuous fillet weld and an
interrupted
(2-10) flair bevel weld,
(shown in Section
C-C of
the drawing).
Contrary to the above,
both
HEPA filter racks are attached
to
the unit housing with an intermittent (2-10) fillet weld and
a continuous flair bevel weld.
This condition existed
on both
R-2 units examined.
(2)
The weld requirement for attaching
Item 27 to Item 28, both
3" x 3" x 3/16" angle,
on CTIN Drawing 32629 is
a square
bevel
partial penetration butt, welded from both sides,
(shown in
section
Z-Z of the drawing).
Contrary to the above,
the welds attaching
Item 27 to Item 28
are welded from one side only.
This condition exists in four
p1aces
on the
E6 unit examined.
(3)
The inspectors
reviewed the documentation
packages
for the Air
Cleaning Units to determine whether or not the nonconformances
noted above
had been
documented
and evaluated.
There was
no
documentation
to indicate that the nonconformances
had ever been
detected.
The inspectors
informed
CP8L management
that failure to identify
and evaluate
nonconforming welds in purchased
equipment is contrary
to 10 CFR 50, Appendix B, Criterion VII as
implemented
by CPSL
section 1.8.5.7.
10 CFR 50.55(f)(1) requires
CP8L to implement the
gA program documented
in the
PSAR.
This is an example of the findings
which led to Potential
Enforcement Action l.
U
Weldin
Li uid Penetrant
Examination
The inspectors
selected
a -portion of a weld for reexamination that,
fabrication records
indicated,
had been liquid penetrant
examined
by
Bahnson
as required
by Ebasco specification
CAR-SH-BE-31.
This
reexamination
was
made to determine whether the .surface
was suitable
for liquid penetrant
examination
and acceptable
to the applicable
acceptance
criteria.
The weld selected
was
a portion of the continuous flair bevel weld
attaching
the upstream
HEPA filter rack to the top of the 2A-SA-28-SB
'2
unit. housing.
This examination
was performed
by a"CPSL, Level II,
examiner,
using the solvent
removable
method in,
accordance
with,CPSL Procedure
201 Revision 2.
(This was the
same
type of liquid penetrant
examination
performed
by Bahnson - color
contrast,
solvent removable.)
As a result of the liquid penetrant
examination,
the inspectors
observed
the following conditions:
4
c ~
.(1)
The surface
was suitable for liquid penetrant
examination.
s
(2)
An area of lack of fusion at the toe of the weld between
the
weld and the
HEPA filter rack was identified.
(3).
An area of undercut at the fusion line between
the weld and the
HEPA filter rack was identified.
Later measurement,
by a
CP8L
welding inspector,
revealed
the undercut to be in excess of
- 1/64".
(4)
Paragraph
16,,of the
HVAC Addendum A, to Ebasco Specification
CAR-SH-BE-31, "Air Cleaning Units", prohibits any lack of
fusion, and undercut in excess of 1/64".
The inspectors
reviewed
the documentation
packages for the Air Cleaning Units to determine
whether or not the nonconformances
noted in (2) and (3) above
had been
documented
and evaluated.
There was
no documentation
to indicate that the nonconformance
had ever been detected.
The inspectors
=informed CPSL management
that failure to identify
and evaluate
nonconforming welds,in purchased
equipment is contrary
to 10 CFR 50, Appendix B, Criterion VII as
implemented
by CPSL
section 1.8.5.7.
10 CFR 50.55(f)(l) requires
COL to implement the
gA program documented
in the
PSAR.
This is an exa'mple of the findings
which lead to Potential
Enforcement Action 1.
r
Boltin
Visual Ins ection
The inspectors
made
a visual examination of selected
connections
for appropriate fastener material
type, size, traceability,
and
material.
No violations or deviations
were found in this area.
Review of ualit
Records
The inspectors
reviewed the documentation
packages for the 1A-SA-IB-SB
and 2A-SA-2B-SB R-2
MVAC air cleaning units to determine
conformance
with procurement,
storage,
and fabrication specifications,
and
regulatory requirements.
The review revealed
the following conditions:
(1)
Records. for the liquid penetrant
examination
performed
by
- Bahnson
on July 16, 1982,
and partially reexamined
as
described
in paragraph
c, above revealed
the following
statement:
".Item 2 to housing,
Typ. area,
100K, reject
. RM July 16, 1982, Repair Accept July 16, 1982."
It should
be noted that there are
two number
2 items installed in
each
R2 unit and there are welds
on both the upstream
and down-
stream sides of each
item 2, attaching
them
( Item 2) to the unit
housing, that require liquid penetrant
examination,
as specified
by'TIN drawing 32735-A Section
C C.
At the time of this
inspection, it could not be determined whether the above statement
.meant that all of the welds attaching all of the Item 2s to the
housing of the 2A-SA-2B-SB R-2 unit had been repaired or just
'ome of them.
The licensee
indicated that they would investigate
. the above matter and make
a determination
as to the number of
'- welds repai,red.
Pending,
NRC review of the licensee's
investi-
gation, this matter will be identified as unresolved
item
400/84-05-01:
(2)
The 2A-SA-2B-SB R2 unit was subjected
to a vigorous receipt
inspection
by CP&L which resulted in the issuance
of DDR-1053.
DDR-1053 accepted
"as-is" all weld defects
including two cracks,
on the 2A-SA-2B-SB R2'unit.
At the time of this inspection the
licensee
could not provide
a justification for leaving the two
cracks uncorrected
in the unit.
Pending resolution of the
above
issue this matter will be identified as unresolved
item
400/84-05-02:
"Cracks in R2
HVAC Unit."
(3)
The "Preventative
Measures"
block of the Corrective Action
Report for DDR-1053 was marked
"NA", Not Applicable, with an
accompanying
note which stated that preventative
measures
were
not applicable
because
the Air Cleaning Unit inspected
and
rejected
was the last unit in production.
No reinspection of
. previously received units of Bahnson
equipment
was initiated.
The inspectors
informed
CP&L management
that failure to perform
adequate
corrective action is contrary to 10 CfR 50, Appendix B, .
Criterion XVI, as
implemented
by
10 CFR 50.55(f)(l) requires
CP&L to implement the gA program
documented
in the
PSAR.
This is an example of the findings
which led to Potential
Enforcement Action 2.
6.
Heatin
, Ventilatin
and Air Conditionin
HVAC Air Handlin
Units
The inspectors
performed detailed inspections, of 17 of the 47 safety
related
HVAC Air Handling Units manufactured
by The Bahnson
Company
'or
CP&L's Shearon Harris Project.
The inspections
were conducted
using criteria established
in the applicable
Ebasco Specification
(CAR-SH-BE-08),
Bahnson
.Drawings (drawing only. available for four
units),
and Seismic gualification Reports to determine whether the
fabrication, receiving inspection,
handling
and storage were-
consistent with applicable drawings,
procedures,
specifications
and regulatory requirements.
All the Air Handling Units inspected
had been accepted
by CP&L.
a.
Weldin
Visual Ins ection
The inspectors
made
a visual examination of accessible
on the below'isted un'its relative to the following:
locati'on,
length, size,
and shape;
weld surface finish and appearance;
weld reinforcement-height
and appearance;
joint configuration
of permanent
attachments
and structural
supports;
arc strikes
'and weld splatter; finish grinding or machining of weld surface
surface finish and absence
of wall thinning; surface defects-
cracks," laps, lack of penetration,
lack of fusion, porosity,
slag
and undercut exceeding
prescribed limits.
During the
.inspection
the following conditions were observed:
-6-
Identification
'=AH-5 (1A-SA)
- AH-5 (1B-SB)
Defect Descri tion
Missing floor to frame welds, missing weld
on cooling coil frame
Lack of fusion, burn through
on side panel
frames
AH-6 (1A-SA)
AH-7 (lA-SA)
AH-15 (2A-SA)
AH-17 (1-4A-SA)
AH-17 (1-4B-SB)
AH-19 (1A-SA)
AH-E9 (IB-SB)
AH-20 (lA-SA)
AH-20 (1B-SB)-
AH-25 (1X-SB)
'AH-28 (IA-SA)
AH-28 (1B-SB)
AH-29
None
Crack in skin to frame weld; weld craters,
lack of fusion, burn through, overlap in
skin to frame welds
and side panel
frames
No weld symbol
on drawing for skin to
coo'ling coil frame channel stitch weld
Stitch fillet weld on fan housing did not
extend to end of joint, end weld less
than
2" long, lack of fusion, insufficient weld
reinforcement,
unconsumed
weld rod protruding
from weld joint, tack welds not removed or
incorporated into final weld in panel
frame
and skin to frame welds
In addition to nonconformances
noted under
AH-17 (1-4A-5A), floor panel joints were
mismatched,
roof skin to cooling coil frame
welds were corroded,
one fan housing anchor
bolt missing,
and
7 cooling coil mounting
.
bolts were an incor rect material
Missing nut on coiling coil mounting bolt,
missing cooling coil mounting bolt
Missing welds
on side panel
framing
None
None
Missing welds
on cooling coil frame and side
panel
frames,
undercut
and lack of fusion on
skin to frame welds, missing side panel
frame
welds, missing cooling. coil mounting bolts
\\
Lack of fusion, weld craters
in side panel
frames
and skin to frame wel ds, pitch on
stitch weld more than 10" center to center
Missing 2 welds
on cooling coil channel
Missing side panel
frame welds, missing cooling
coil mounting bolts, skin to frame welds less
than 2" long
7
Identification
AH-85 (lA-SA)
Oefect Oescri tion
. (I)
The Bahnson
Company considers their drawings proprietary
.
information and therefore
CP&L did not have copies of
the drawings.
CP&L did request that The Bahnson
Company
supply drawingS for three units selected
by the
NRC
inspectors,
units AH-15, AK-28, and.AH-85.
The remaining
units were inspected for weld location and joint design
based
on typical weld details contained
on the drawings
for units AH-15, AH-28, and AH-85.
At the time of this
inspection, it could not be determined,
except for units
AH-15, AH-28, and AH-85, with 100K confidence that the welds
listed as missing in the remaining units were required
by the drawings=for the specific unit.
However, the welds
listed as missing
on side panel
frames were typically
required to be welded all the way around
and were actually
only welded on two or three sides.
The licensee
indicated
that they would investigate
the above matter and make
a determination
as to the
number
and location of missing
Pending
NRC review of the licensee's
investigatiorl,
this matter will be identified as unresolved
item
400/84-05-03:
"Missing HVAC Welds", except for those
welds found missing
on Unit AH-28 (IB-SB) [see para.
6.a.(3)].
(2)
.Inspection of weld quality was based
on Ebasco Specification
CAR-SK-BE-05, Addendum A, "guality Assurance
Requirements
for Nuclear Safety Related
HVAC Equipment", which invokes
AWS 01.1
and specifically prohibits cracks,
crater s, lack
of fusion, and undercut which exceeds
I/64".
As noted in
the listing above there were seven Air Handling Units which
did not meet the acceptance
criteria for welds.
(3)
The inspectors
reviewed the documentation
packages
for the
Air Handling Units to determine whether or not the missing
welds in Unit 28 (1B-SB) and the weld quality nonconformances
in the other units
had been .documented
and evaluated.
There
was
no documentation
to indicate
the nonconformances
had eyer been detected.
The inspectors
informed
management
that failure to identify and evaluate
noncon-
forming welds in purchased
equipment is contrary to 10 CFR 50, Appendix B, Criterion VII as
implemented
section 1.8.5.7..
10 CFR 50.55(f)(1) requires.CP&L to
..implement, the gA program'ocumented'in'he'SAR.
This is
an example of the findings which lead to Potential
Enforcement Action 1.
b.
Boltin
Visual Examination
(I)
The inspectors
made
a visual examination of selected
connections for appropriate
fastener material
type, size,
and material traceability.
One instance of substituting
carbon steel bolts for stainless
steel bolts and four
-8-
instances
of missing fastener
hardware
were discovered
,by the inspectors.
(2)
The inspectors
informed
CPSL management
that failure to
identify nonconforming bolted connections
and fastener
~aterials
in purchased
equipment is contrary to
- Appendix B, Criterion VII as
implemented
by CPSL
section 1.8.5.7.
10 CFR 50.55(f)(1) requires
CPSL to
implement the gA program documented
in the
PSAR.
Thi's is
an example of the findings which lead to Potential
Enforcement Action l.
c.
Review of ualit
Records
(I)
The inspectors
reviewed the Ebasco
procurement specifica-
tion, Bahnson general
arrangement
drawing and Bill-of
Material
(BOM} for unit AH-17 (I-4A-SA) to establish=- material
requi rements.
The Certified Material Test Reports
(CMTR)
or Certificates of Compliance
(COC) supplied with the
documentation
package for the unit were, then compared with
the material
requirements.
The review revealed 'the following
conditions:
(a)
The
BOM and procurement specification were inconsistent
on material
requirements
in the following areas:
- Interior Casing
(Fan and Coil Sections)
Specification
required
20ga
ASTM A240, Type 304.
The
BOM specified
20ga
304 stainless
steel with no ASTM designation.
- Floor (Coil and
Fan Sections)
Specification
required
20ga
ASTM A240, Type 304.
The
BOM specified
10 ga,304 stainless
steel with no ASTM designation.
- Drain Pan Liner Specification required
10ga
ASTM A240,
Type 304.
The
BOM specified
20ga stainless
steel
with no
ASTM designation.
(b}
The following questions
or inconsistencies
resulted
from
reviewing the data
package:
- An Edcomb Metals
COC was for 18-8 Type 304 stainless
steel with no ASTH designator.
- No material
CMTR's or COC's were provided for the..fan
~
.
.
housing which was supplied
by Westinghouse
an'd required
to be
ASTM A283.
- COC's or CMTR's for the following materials,
specified
in the
BOM could not be found;
Unit Casing Exterior - 14ga
ASTM A366
Interior Casing in fan and coil sections - 20ga
Type 304 stainless
steel
-9-
Drain Pan Liner - 20ga Type 304 stainless
steel
- The Ebasco
release for shipment report was signed
and
stated that there were no special
conditions
and deviations
from purchase
contract;
however, there
was
an open
DDR (No. 80-00?0)'nd
attached
correspondence
'permitting shipment with .open documentation
and
without fan motors.
The inspectors
did not identify any violations, but did
inform the licensee that the material substitutions identi-
fied by the
NRC are considered
unresolved
items.
Pending
the licensee's
evaluation
and
NRC review during a subsequent
inspection, this matter will be identified as unresolved
item 400l84-05-04:
"Material Substitutions".
CP8L instituted
a
l00% receipt inspection at the Shearon
Harris Plant site in approximately
September
1982.
Bahnson
supplied air handling units AH-85, AH-86, AH-92, and AH-93
were received after the institution of. the
100K receipt
inspection
program.
The inspectors
reviewed the
CPSL
receipt inspection reports
and accompanying deficiency
documentation
reports.
CPIWL had rejected all the units
for a combination of nonconforming weld quality, weld joint
configuration,
and missing welds.
At the time of the
inspection,
Units AH-85, AH-86, and AH-93 had already
been repaired
and accepted
by CPKL.
However,
CPKL had not
performed
any kind of reinspection
on air handling units
received prior to i'nstituting the 1005 receipt inspection.
The inspectors
informed
CPSL management
that failure to
perform adequate
corrective action is contrary to 10 CFR 50,
Appendix B, Criterion XVI, as
implemented
by CPEL
section 1.8.5.16.
10 CFR 50.55(f)(l) requires
CP8l
to
implement the gA program*documented
in the
PSAR.
This is
an example of the findings which Ied to Potential
Enforcement Action 2.
The inspectors
reviewed reports of Ebasco facility evaluations
and Bahnson
commitment to corrective actions
to cited
deficiencies for 19??,
19?8,
1980,
and 1983.
The review
revealed
the following conditions:
The corrective actions
committed to by Bahnson indicated
a
lack of adequate-measures
to prevent'ecurrence
of the
problems;
however; most commitments
were never questioned
by Ebasco
and there
was. no evidence that Ebasco
performed
followup to review implementation of corrective action
until the next facility evaluation
was performed.
The
following areas of Bahnson's
gA program were repetitively
cited by Ebasco
and reflects
a lack of adequate
corrective
action by Bahnson
and
a lack of vendor control by Ebasco:
- 10
-.
- Failure to maintain adequate
vendor program control
for nuclear suppliers
- Failure to maintain adequate
controls of procedures
and
personnel
relating to performance of the quality function
including NDE.
This is an example of. the findings which led to Potential
Enforcement Action 2.
- 11-
ATTACHMENT A
Documents
Reviewed
The documents listed below were reviewed
by the inspection
team members to
the extent necessary
to satisfy the objectives
of. the inspection.
References
to specific documents
are contained within the body of the report.
1.
Ebasco specification
CAR-SH-BE-08
2.
Addendum
A to CAR-SH-BE-08
3.
Ebasco specification
CAR-SH-BE-31
4.
Addendum A to CAR-SH-BE-31.
5.
Seismic Qualification Report 9Q-BE-08-20-S1
6.
Seismic Qualification Report 9Q-BE-08-20-S181
7.
Seismic Qualification Report 9Q-BE-08-20-S1B2
8.
Documentation
Package for AH-5 (.1A-SA) and
(1B-SB)
9.
Documentation
Package for AH-15 (2A=SA)
.
10.
Documentation
Package for AH-17
1-4A-SA) and (1-4B-SB)
11.
Documentation
Package for AH-85 (IA-SA)
12.
Documentation
Package for AH-93
13.
Documentation
Package for
R2 (lA-SA-1B-SB)
14.
Documentation
Package for R2 (2A-SA-2B-SB)
15.
CTIN Drawing 32735A
16.
CTIN Drawing 32629
17.
Bahnson
Drawings for AH-15, AH-28, and AH-85
18.
Bahnson
WPS GMI-1/2/3
19.
Bahnson
WPS GM8-1/2
20.
Bahnson
WPS
GT l-l
21.
Bahnson
WPS
GT 8-4
22.
Bahnson
WPS SMI-6/7/8
23.
Reports for Ebasco Facility Evaluation at Bahnson for years
1977,
1978,
1980,
and
1983
24.
Drawing 2728-1-7 (Air Handling Unit AH-17)
- 0
I,