ML19343C564
| ML19343C564 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 03/19/1981 |
| From: | Widner W GEORGIA POWER CO. |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| TAC-43754, TAC-43755, NUDOCS 8103240509 | |
| Download: ML19343C564 (14) | |
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Mn7 March 19,1981
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Directer of ?bclear Reactor Regulation fqg j
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U. S. tbclear Regulatory Comission Washington, D. C.
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m..c m,sv-NRC OCCKETS 50-321, 50-366 gen CPEPATING LICENSES dor-57, NPF-5 y\\ "d' S,me EDWIN I. nATCH NUCLEAR PLANT UNITS 1 AN 2^-
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RESPONSE TO 10 CFR 50.43 AND APPENDIX R d4e w.g Gentlemen:
Georgia Power Company has reviewed the final version of 10 CFR 50.48 and Appendix R thereto, and the IPC's letter dated Febr"ary 20, 1981, requesting information concerning our resconse to the rule.
Submitted herein are our comments and requests 'for certain exenptions from the regulation and its acpendix:
I.
General Paragraoh (b) of 10 CFR 50.48 states in part:
"Except for the requirements of Sections III.G, III.J and III.0, the provisions of Appendix R to this part shall not be applicable to ntclear power plants licensed to operate prior to January 1,1979, to the extent that fire protection features proposed or implemented by the licensee have been accepted by the NRC staff as satisfying the provisions of Appendix A to... STP APCS 8 9.5-1" Plant Match Units 1 and 2 were licensed to operate prior to January 1,1979, Georgia Power Company has received a staff approved Safety
' Evaluation Report and, via NRC letter dated November 24, 1980, has received concurrence that no open items exist.
We have concluded, therefore, that Plant Hatch is excluded from the general provisions of Appendix R.
Accordingly, this resocnse addresses only the requirements of Sections III.G, III.J, and III.0 of Appendix R.
II..
. Oil Collection System Section III.0 of Appendix R specifically applies to plants without inerted containments. Plant Hatch Unit I has been operating in the inerted mode since initial :startup We plan to comply with Appendix. R, :Section III,0 by inerting the Unit 2 containment prior
'to startup of the earliest of the.following outages commencing 180 days after February 17,.1981 per paragraph C.3 of 10 CFR 50.48:
9)'
the first refueling outage;
.b) another planned outage that lasts for at least 60 days; or.
81082.405 %
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GeorgiaPou. A U. S. Puclear Regu'atory Ccamission
.varch 19, 1981 Page 2 c) an unplanned cutage tnat lasts for at les: 120 cays.
III.
Emercency Lichtino Gecrgia Power Comoany is reviewing the requirement for emergency lighting.
We have fc id that the repaire ents of Appencix R,
Section III.] will necessitate the additien of certain S-hcur emergency lights.
This action will ce ccccleted within nine months of February 17, 1981, as required by 10 CFR 50.aS, paragra:h C.2.
IV.
Protecticn of Safe Shutccwn Ecuicment Section III.G of 10 CFR 50 Oppendix R provides criteria for the protection of safe shutdown eculpment.
Gecrgia Pcwer Conpany intends to comoly with tne intent of this secticn.
Section III.G, paragraons 2.b and 2.c require the additien of fire detectors and fire sucaression systans in all areas where equipment protection' is proviced via either separation er one-neur fire barriers.
Our interpretation of the_ c pendix is that sprinklers e
and detectors installed under these requirenents shculd protect the safe shutdcwn equipment in the area. We plan to crevide sprinklers and detectors for only the safe shutdown eculpment in the affected areas.
We do not censider this to constitute an exce0 tion to
~Oppendix R.
Prior to the new ruling, during the review _ of plant equipcent separation under BTP APCSS 9.5-1, certain: interferences were noted and the acpropriate protection was prcvided.
Frcn this excerience it was learned that extensive' time and manocwer sculd be required to identify such interferences. ~Inasnuch as the review criteria recuired under STP A? CSS 9.5-1 were not the same as the criteria of
'Section III.G of Appendix R, Georgia Pcwer Ccmpany anticipates that the nine ecnth schedule of 10 CFR 50.4S(c)(2) cannot reascnably be met.
Our approach to Section III.G is based ucen an engineering review to determine a minimum train of. ecui,~,::ent and a ' redundant counterpart recuired for safe ~ shutdcwn..
Following
- this, a
ecmcrenensive field walkdown, suoplemented by a review of olant layout drawings, will be nade - to identify the existing 'secaraticn
' and : to.allcw determinatic7 of the optimum acticn to take if codifications are necessary.
Georgia Power Company believes that
.the engineering - review, field walkdown, and. modifications, which could entall new s;ecifications, purchase centracts, sprinkler system installation, major rercuting of alectrical cables, and precperational testing, cannot be done in a safe and cccorehensive
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manner within a nine-ocnth schedule.
Georgia Power d U. S. tA; clear Regulatory Commission March 19, 1981 Page 3 A bar chart schedule (figure 1) is attached illustrating the seQJence or the reautree engineering errort and the acoroximate duration of the various steps in the process.
This chart represents our best estimate of the time required to perform tha activities described in the necessary detail.
The intern dates en the chart are for illustrative purposes only an n
t constitute scheduled milestones.
Georgia Power Company, therefore, re;uests an exenption fra
'N nine month implementation schedule of 10 CFR 50.48 (C)(2).
Geow' Power Company hereby commits to complete the field work necessary to locate all interferences, and to provide the NRC with a listing of modifications required with a completion schedule within twelve months; specifically by March 19, 1982.
V.-
Alternative Shutdown - River Water Structure Section III.G.3 of Appendix R remires that alternative or dedicated shutdown be provided - for areas which cannot meet the criteria of III.G.2.
The Plant Hatch intake structure has been analyzed under the criteria of APCSS 9.5-1.
Modifications made as a result of that review include a combination of barriers and sprinkler systems.
In their review of the " Evaluation of the Hatch Nuclear - Plant Fire Protection Program" report, the modifications were found by the NRC staff to constitute an adequate level of fire protection - for the structure.
Specifically, adjacent train pumps and motors are provided with automatic wet pipe sprinkler systems
. with directional nozzle protection.
Spray barriers are provided between each pump division.
Also, the motor control centers are protected from the effects of spray.
Fire retardent coverings are provided for overhead cables and conduit for approximately ten feet on either side of divisional crossings.
However, this protection does not ' meet the requirements of Section III.G.2 of Appe.ndix R.
The pumps are essential to plant shutdown, and it is not possible, within the existing intake structure, to provide separation of the pumps and associated equipment by full fire barriers per-Section III.G.2 (a), (b), or (c) without a blockage of cooling air flow to the pump motors.
Such blockage would endanger the pump motors and would constitute a condition ~that is detrimental to overall facility. safety.
In addition,- the probability of experiencing a fire is very low due to the.small amount of comcustible materials The BTU /ftgresent.
for. cable combustible-loading consists of 42,570 insulation: and.12,440 STU/ft2 for oil.
In order to realize this fire loading, catastrochic failure and total ~ involvement of all combustible materials present would be required.
Each of the eight RH1 service water pump motors contain 24 gallons of oil and each of the eight service water pump motors contain six gallens of oil.
Georgia Pw.er d U. S. tbc1mr Regulatory Commission March 19, 1991 Page 4 Retaining certs have been provided arcund the RHR service water pumps to contain any oil leakage.
A fire in a cable " ray uculd not spread due to the nonprepagating cables used and the fire barriers i
installed in the cable trays.
For these reasons, Gaorgia Power Company requests an exemtion as previded in section (c)(6) of the Regulation frcm the repuirements of Secticn III.G.2 and 3 for the river intake structure en the basis that it would not enhance fire protection at the intake structure and is not feasable within the ex11 ting structure.
It shculd t'2 notad that the river intake structure will be included in the review of plant systems discussed in paragraph IV a0cve.
The river intake structure will be reevaluated and the fire protection to meet the requirements of Appendix R to the extent enetical within the present intake structure will be defined and
-explained in our submittal of proposed modifications and cocoletion schedule by March 19, 1982.
VI.
' Alternative Shutdown - Control Room and Cable Screadinc Rooms Plant Hatch has an alternative shutdown system for the centrol room and cable spreading rooms.
A general design description for the existing systems is attached as Attachment 1.
Paragraph 'III.G.3 of @pendix R requires that fire detection and a fixed fire suppressicn system be provided for those areas for which alternative ' shutdown is provided.
The cable spreading room has a detection system and an automatic sprinkler systen, as well as a
-manually initiated CO2 system.
Therefore, it meets this requirement.
The control reem has a detection system,.but it has no fixed fire suppressien system such as_ area sprinklers or a gas mcpression system.
The placement of a fixed area fire suppressic i system in the constantly manned centrol rocc. would constitute a hazard to plant-safety due to the possibility of inadvertent actuation.
A hose station and: fire extinguishers have been - installed inside tne control ~ rocm at Plant ' Hatch.
It is Georgia Pcwer Company's position that the. hose n ation. and " ire extinguishers orevide adequate fire _ fighting capability in the room and constitute an adequate fixed fire suppression system for the area.
Howev er,
inasmuch as - the term " fixed ennrcssion" has been used to conncte scrinklers cr cas suppression systems, we. feel that it is necessary to request an exemptien from the recuirements of III.G.3 to provide fixed sucpression for this area.
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Georgia Power d U. S. tuclear Regulatory Commission March 19, 1981 Page 5 4
Therefore, Cecrgia Power Comcany recuests an exemotion as provided for in (c)(6) from the requirement to suoply fixed suppression for the control room based or the safety hazard represented by the possibility of inadvertent actuation of such a system.
VII.
Associated Circuits In the review and walkdown of safe shutdown systems for additional protective measures, associated circuits will be considered.
Associated. circuits for safe shutdown systems operated from the control room will be defined as those circuits not isolated from safe shutdown circuits by protection devices such as fuses and/or circuit breakers.
VIII.
Information Recuested by the PRC February 20 Letter The February 20 letter referenced above requested that certain information be provided by March 19, 1981, with more detailed information requested to be submitted by May 19, 1981.
The information reauested in Enclosure 1 to the letter consists of technical data related to the alternative shutdown system.
As noted above, a description of the alternative shutdown system for Plant Hatch ~ is attached (Attachment 1).
The supplemental information requested in Enclosure 1 to the Februc y 20 letter will be addressed by Georgia Power Company by May 19, 1981. to the February 20 letter consists of two parts:
1) information concerning-details of cable secaration and assurance that fire induced failures are avoided in the alternative shutdown system and 2) prevention of an intersystem LOCA.
The data for part-1 will be obtained as a part of the engineering analysis described in-paragraph IV above.
While the portion of the data related to alternative shutdown will be given firrt priority in the evaluation,.it.is not ' feasible to perform this portion of tne evaluation. separate from the other work.
Georgia Power Company will submit the infonnation requested in - part 1 of Enclosure 2 to the F#Jruary 20 letter by: March 19, 1982,' or as soon ' before that date as the data becomes available.
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GeorgiaPoner A U. S. Nuclear Regulatory Conr. J.ssion March 19, 1981 Page 6 Regarding prevention of an intersystem LOCA; due to the fact that several systems may be invol.ed in this analysis, the analysis cannot be separated from the overall program described in paragraph IV. The quest'cn !n part 2 of Enclosure 2 will be addressed in the March 19,1952, response.
IX Execotien Summary 10 CFR 50.48 - Schedule - Exception taken to schedule dates for Appendix R,Section III.G itens.
Appendix R Section III.G.2 Exception taken to full fire barriers at river intake structure.
Appendix R Section III.G.3 Exception taken to alternative shutdown for river intake.
Exception taken to fixed suppression in control room.
Appendix R - Section III.J - Georgia Power Company will comply.
Appendix R - Section III.0 - Georgia Power Company will ;omply -by inerting thit 2 containment.
W. A. Wicner states that he is Vice President of Georgia Power Company and is authorized to execute this oath on behalf of Georgia Power Company, and that to the best of his knowledge and belief the facts set forth in this letter are true.
Georgia Power Company by:
- w. A. Wioner Sworn to,and subscribed before me this 19th day of March 1981.
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Notary Puchc Georgta. State at Large
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3 i -f / / /j My Commassen Empires Sept. 20,1983 Notary Puolic WEB /mb-f Attachments xc: Max Manry R. F. Rogers, III
TENTATIVE SOlEDULE FOR PROVIDING MOD]FICATIONS AND COMPLETION SCHEDULE TO MEET APPENDIX R REQUIREMENT.
MAROI 191981 JULY 3,1981
FEB.19,1982 MAR.19,1982 I
I PROVIDE
RESPONSE
TO NRC I
I REMOTE SliulDOWN SYSTEM DESCRIPTION I
I DEFINE SYSTEMS AtlD EQUIR REQUIRED FOR SAFE SHUTDOWil UNDER APPENDIX R l
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j DEFINE CIRCUITS ASSOC.
WITH SAFE SHUTDOWN EQUIR 1
I REVIEW CIRCUITS AND EQUIR WITil RESPECT TO APPENDIX R CRITERIA E
I DETERMINE MODIFICATIONS REGUIRED I
I CONCEPTUAL DESIGil FOR FIRE DETECTION / SUPPRESS 10tl SYSTEMS REROUTE AND BARRIERS I
I FIGURE 1 WRITE PLAN AtlD IMPLEMENTATION SCHEDULE S
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E%'IN I. HATCH NUCLEAR P0kT.R Pl. ANT 1; NITS 1 ASD 2 RDiOTE SHLTDO*WN SYSTDi DESCRIPTICS
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TABLE OF CONTEhIS 3
PAGE 1.0 SCOPE' 1
.2.0 SYSTEM RINCTION 1
3.0 APPLICABLE FEDERAL REGULATIONS 1
4.0 '
DESIGN BASIS 1
5.0 SYSTEM COMPONENTS 2
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6.0 REMOTE SHUTDOWN ~AND RELATED SYSTD4S INTERFACE 3
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7.0 REFERENCES
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O 1.0 SCOPE 1.1 This document describes the remote shutdown system of the Edwin I. Hatch Nuclear Power Plant Unit 2.
(Unit I system is identical unless otherwise noted.)
2.0 SYSTEM FUNCTION 2.1 The re=ote shutdown system provides remote control capabilities for those systems needed to carry out a reactor shutdown function, maintain hot shutdown, proceed to and maintain cold shutdown, from outside the main Control room.
3.0 APPLICABLE FEDERAL REGULATIONS 3.1 10CFR50 Appendix A Criterion 19 3.1.1 The remote shutdown system is designed in accordance with 10CFR50 Appendix A Criterion 19.
This criterion in part requires a system with suitable controls, instrumentation, and procedures which provide the capability to achieve hot and cold shutdown from outside the main control room.
'3.2.1 The remote shutdown system serves as an alternate / dedicated safe shutdown system for the cable spreading and main control room fire areas as required and described in Section G.3 of Appendix R.
Section G.3 in part requires alternate or dedicated shutdown capability where protection of syste=s required for hot shutdown do not satisfy the fire protection requirements of G.'.
4.0 DESIGN BASIS 4.1 The remote shutdown system is designed to control the necessary active shutdown co=ponents irrespective of any damage to the electrical circuits of those components which may occur as a result of a fire or fire related event in the main control or cable spreading room.
4.2 The system is designed and is capable of functioning if necessary exclusive of the main turbine pressure regulator anc feedwater systems.
4.3 All components and control of those components requiring electrical pcwer are supplied frem either an onsite power source, or an offsite power source with automatic switchover capability to an onsite source.
. 4.4 In the event a fire in the cable spreading or control room-causes a loss of electrical power to a bus supplying power to a shutdown component, procedures exist for restoring power in a period of time which assures the continued maintenance of hot shutdown until such time as cold shut-down~can be achieved or reachieved.
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4.5 The re=ote shutdown syste= is designed to function assu=ing the reactor is initially at or less than its design power and no loss of coolant accident occurs.
5.0 SYSTEM COMPONENTS 5.1 Control Panels 5.1.1 Control panels are strategically located in the power plant and house the controls, indication, instru=entation, and transfer switches included in the re=ote shutdown system.
5.2 Transfer Switches 5.2.1 The purpose of the transfer switches is to switch control of the shutdown co=ponents (pu=ps, valves, etc.) from the main control room to the re=ote shutdown panels.
5.2.2 Af ter the transfer switch is actuated, the control of all shutdown components is unaffected by events in the cable spreading or control room.
5.2.3 Actuation of the transfer cwtich establishes a new source of control power.
Therefore, any da= age such as a blown fuse in the control rocm control circuit prior to transfer is of no consequence.
NOTE The above state =ent does not apply to the RHR, RER service water, plant service water et control rod drive pu=p control circuits. In these instances loss of control power due to da= age occurring prior to actuation :f the transfer switches, could result in loss of control due to the automatic opening of a protective control power circuit breaker. However, procedures exist to re-establish control of these pu=ps in a time period which allows maintenance of a safe shutdown condition.
5.3 Control Switches 5.3.1 Each valve and pu=p controlled by rhe remote shutdown system is provided with control switches located on f.he remote shutdown panels. Operation of these switches is similar to that which is available in the main control room.
5.4 Indicating Lights 5.4.1 Each component controlled by the remete shutdown system is provided with indicating lights similar to the 2ndicating lights in the main control room.
5.5 Instru=entation 2
5.5.1 Sufficient instrumentation is available at the remote shutdown panels to safely bring the plant to a safe shutdown condition indefinitely.
5.3.2 The majority of instrumentation loops are cempletely independent of the control and cable spreading rocm areas.
5.5.3 Those instrumentation loops which are shared in part with the main control room are suitably isolated from the main centrol and cable spreading rooms after actuation of the transfer switches. Section 5.2.3 is applicable to instrumene.atien pcwer.
6.0 REMOTE SHUTDOW AND REI.ATED SYSTEMS INTERFACE 6.1 General 6.1.1 Activation of the relief valves and the Reactor Core Isolation Cooling (RCIC) system will be utilized to cool and depressurize the reactor after a Scram and isolaticn are achieved. During thir phase of the shutdown, the suppression p.;ol will be cooled as required by operating the Residual Heat Removal (RHR) system in the suppression pool cooling mode. Reactor pressure will be controlled, and core decay and sensible heat rejected to the suppression pool by dumping steam through the relief vs..ves.
Reactor water inventory will be maintained by the RCIC system. When the reactor is cooled down and depressurized and the decay heat is within the capabilities of the RHR shutdown cooling mode, the RHR system will be operated in this mode to bring the reactor to a cold shutdown.
6.2 Reactor Protection System (RPS) 6.2.1 Operation of the remote shutdown system is predicated on a Scram of the reactor. The RPS Scram function as per procedures can be carried out in the main control roem prior to evacuation, or in the RPS MG set equiptent room, or locally at the scram discharge volu=e high - high level switches.
l 6.3 Reactor Depressurization System 6.3.1 ihe safety-relief valves provided on the main steam lines discharge to the suppression pool when actuated by their appropraite controls or mech-anically on high pressure in order to control reactor pressure.
6.3.2 Manual' control and position indication of three (two for Unit 1) blevdown valves is provided on the remote shutdown panels.
6.4 Reactor Core Isolation Cooling (RCIC) System 6.4.1-The RCIC system maintains sufficient water in ene reactor to cool the core i
in the event of reactor vessel isolation.
6.4.2 Electrical control and position indication for all active components, system flow information, and turbine speed (Unit 2 only) is provided on the re=ote shutdown panels.
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6.4.3 On Unit 2 only, four a=ber warning lights are provided on the remote shutdown panels, which when illuminated indicate the turbine coupling end bearing te=perature is high, turbine brearing oil pressure is low, turbine governor bearing temperature is high, or RCIC turbine has tripped.
6.4.4 On Unit 2 only, manual as well as automatic flow control is providei for on the remote shutdown panels 6.4.5 On Unit 1 manual control of flow, by operation of the turbine trip and throttle valve is provided for on the remote shutdown panels.
6.5 Residual Heat Removal ORRR) System 6.5.1 The RER system has two modes of operation which are used to achieve and maintain cold shutdown. These modes of operation are the suppression pool cooling mode and the shutdown cooling mode.
The suppression pool cooling mode is designed to remove heat from the suppression chamber during primary system hot standhror station cooldown operations. The RER pu=p is used to circulate suppression chamber water through the RER beat exchanger and back to the suppression pool. Heat is removed from the heat exchanger by.the RHR Service Water (RHRSW) system which circulates river water through the heat exchanger and back to the river.
The shutdown cooling mode of operation is designed to maintain the reactor in a cold shutdown condition by circulating the primary coolant through the RER heat exchanger.
6.5.2 control and indication of active valves, RHR and RRRSW pumps, RHR and RHRSW flow, to achieve the suppression and shutdown cooling modes, are available on the reacte shutdown panels.
NOTE No control of the RER service water tube side discharge valve is provided on the remote shutdown system. Automatic operaticiof this valve is assumed. However, malfunctioning automatic operation of this valve is detectable by RHR service water flow indication on the remote shutdown panel.
Sufficient time exists to manually control this valve before the maintenance of a safe shutdown is affected.
6.6 Nuclear. Boiler Instrumentation 6.6.1-Reactor water level and pressure information are provided on the remote shutdown panels.
These instrumentation loops are ce=pletely independent of the control and cable spreading rocm area.
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F 6.7 Suppressien Pool Instru=entation 6.7.1 Suppression pool water te=perature, vapor te=perature, water level, and drywell pressure infor=ation are provided en the re=ote shutdown panels.
These instru=entatica loops are ec=pletely independent of the centrol and cable spreading roc = area.
6.8 Drywell Cooling Syste= Instru=entation 6.8.1 Drywell dc=e, =id level side, sacrificial shield side, and centrol rod drive cavity te=perature infor=atica are provided en the recote shutdown panels. The instru=entation loops are ce=pletely independent of the control and cable spreading roc = area.
6.9 Reactor Recirculation Syste=
6.9.1 Control and positien indication of the B loep recirculation pu=p suctica valve are provided on the re=cte shutdown panels. The B Icep recirculation pu=p suction valve is closed to assure that the discharge flew frc= the RER pu=p in the shutdown cooling =cde is directed to the core to assure cooling.
6.10 Control Rod Drive Hydraulic System 6.10.1 Control and indication of the B (A and B for Unit 1) centrol red drive water Epc=p are provided on the re=cte shutdewn panel. This provides for an additional although not essential source of cooling water.-
6.11 Plant Service Water Syste=
6.11.1 Electrical centrol and indication of the B plant service water pu=p are available on the re=ote shutdown panels.-
7.0 REFEFINCES 7.1 Electrical ele =entary drawings of the remote shutdown syste=.
Unit 2 H-27970 thru H-27980 Unit l' -- H-19572, E-19573, and H-19610 thru H-19614 l'
7.2 Procedures for Shutdown Fro = Outside the Control Rec =
Unit 2 - ENP-2-1908 Unit 1- - -ENP-1-1908 l
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