ML20009A195
| ML20009A195 | |
| Person / Time | |
|---|---|
| Issue date: | 06/22/1981 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| REF-10CFR9.7 NUDOCS 8107090178 | |
| Download: ML20009A195 (18) | |
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DGEisenhut BSnyder D*AF MEMORANDUM FOR: Samuel J. Chilk, Secretary RLTedesco MRushbrook w/ incoming EAdensam JLee w/ incoming FROM:
Wiiiian J. Dircks, Executive Director for Operations
SUBJECT:
STAFF REOUIREMENTS - DISCUSSI0H OF SECY-81-200 - POLICY ON PROCEEDING WITH PENDING CP AND ML APPLICATIONS In response to your memorandum of June 4,1981, the staff has made the following changes to Enclosure 3 of the subject paper, as; indicated by underlining on the revised pages:
1.
The words " light-water-reactor" have been inserted before the word p n-struction" in the first sentence under 10 CFR SD.34(e) and footnote-has _ been added at the word "pending" in the sv:e sentence, identifying the soecific applicants to which the rule applies. These changes are indicated on pages 62 and 63. Also underlined on page 63 is a sentence that has been added to section (1) of paragraph (e) to cla.'ify the staff's intent that the studies called for therein are to be completed within two years following the issuance of a construction permit or aanufacturing license.
2.
The discussion of USDI's coments on pages 17 and 18 has been modified to replace the legal rationale relative to Public Law %-295 with a statement that the Coetuission declines as a matter of policy to recon-sider the sites for the units affected.
3.
Availability dates for the IEEE/ANS methodology for the PRA study aee indicated in the revised first sentence under " Discussion" on page 33.
Several additional changes in Enclosure 3 to the subject paper have been made in consideration of coments by CGC.
4.
To eliminate apparent incensistencies in the cost trade-off discussions, the sentences under " Discussion" on page 24 have been reordered, the
" Discussion" on page 28 has been nodified, and the last sentence under
" Discussion" on page 34 has been deleted.
O 5.
To clininate possible misunderstanding about the adequacy of applicant g
responses to TMI-related requirenents, the word " currently" has been l
substituted for "can" in the second line under " Discussion" on page 29
}8g and in the seventh line on page 61.
" Current" has also been inserted y
in the fifth line of the second paragraph on page 61.
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Because of the possibility that an ATHS rule may not be adopted, the words "and not before issuance of an ATHS rule" have been deleted from require-ment (2)(x) on pages 43 (line 13 under " Discussion") and 68 (line 11).
The staff also found that the coment at the top of page 40 was incorrectly shown as applying to requirement (2)(v), whereas it should have bcen (3)(v). The con-raent is n w treated on page 36.
Copies of the revised page., only are enclosed.
(siges Wil!iam 1.Dircks M1111am J. Dircks, Executive Director for Operations
Enclosure:
Revised pages of the subject paper cc: Chairman Itendrie Comissioner Gilinsky Comissioner Bradford Conmissioner Ahearne Comission Staff Offices
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r One commentor (0PS) suggested that either Option 1 or Option 3 would provide a reasonable basis for resuming licensing.
One comentor (Duke) proposed its affected units (Perkins) be exempted from the ruiemaking altogether because those units'are intendea to be identical to other units (Cherokee) already granted CP's.
One comentor (USDI) recommended that no construction permits be issued until the siting rulemaking has been completed. While it is true that a siting rule is being formulated, it is not expected to be so drastically different from the present guidelines as to make these previously evaluated sites grossly deficient.
The Commission therefore declines as a matter of policy to delay consideration of the pending applications for conclusion of the siting rulemaking.
One commentor (Lewis) asserted that any action at this time is unnecessary and/or p remature. Among other things the comentor stated that there is no demand or "need.for poder" from new plants at this time. The Comission finds that those considerations are outside the scope of this rulemaking.
Need for power and related issues have been or will be addressed in the individual CP (or ML) pro-ceedings by the licensing boards.
This comentor also stated that many new requirements will eventually be developed in answer to the accident at TMI-2.
Included are proposed rule changes on population density, and consideration of
" Class 9" accidents.
In his view, concurrent consideration of several rule-makings at one time makes for duplicative efforts. However, the comments in this regard overlook the fact that ongoing licensing proceedings are always subject ~ to matters in rulemaking and that applications are in any event judged against current ' licensing requirements.
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. On balance, the Comission continues to believe that Option 3, as modified by revisions to II.A.2, II.B.8, and II.C.4, is the most suitable course of action to take.
II. Coments to FR Notice of March 23, 1981 Coments were received from:
1.
J. D. Sloan, Charlotte, North Carolina (Sloan)
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Southern Cogany Services, Inc, Birmingham, Alabama (SCS) 3.
Minnesota Pollution Control Agency, Roseville, Minnesota (MPCA) 4.
Offshore Power Systems (0PS) 5.
Baltimore Gas and Electric Cogany (BG&E) 6.
Boston Edison Cogany (Boston Edison) 7.
Gilbert Associates, Inc., Reading, Pennsylvania (Gilbert) 8.
Town of Hampton Falls, New Ha@ shire (Hampton Falls) 9.
Marty Casella, Sun Valley, California (Casella)
- 10. Jane J. Estes, Blacksburg, Virginia (Estes)
- 11. Stone & Webster Engineering Corporation, Bcstc', Massachusetts (S&W)
- 12. Atomic Industrial Forum, Washington, D C. (AIF)
- 13. Edison Electric Institute, Washingten, D.C. (EEI) 1
l
. Another comentor (Lowenstein) said, "we also think it essential that the Com-mission recognize that in many instances applicants have already completed designs, procured equipment, or comitted to fabrication of equipment on much of the proposed plants. The Comission should make clear to the NRC staff that the new requirements should be interpreted to minimize extensive redesign and procurement of new equipment to replace that already purchased."
Discussion The Comission agrees that new requirements should be based on favorable cost /
. benefit evaluations, but this is not possible, in quantifiable terms, at present due to the lack of a specified safety goal. The Comission and its staft recog-k nize that unnecessary extensive redesign and procurement of new equipment should be avoided. However, in its extensive deliberations concerning TMI-related l
requirements, the Comission has decided that the requirements in the new rule l
are necessary for protection of the public and that their costs are not exorbi-tant.
Acceptable alternative methods of meeting the requirements stated in the rule will be considered.
5.
IMPOSING REQUIREMENTS NOW UNDER RULEMAKING Several comentors (S&W, CEC, Lewis, Ebasco) oppose the dnposition of require-ments subject to other nilemaking proceedings, particularly relative to degraded core conditions, as premature.
Another comentor (W) said that "in light of the ongoing generic NRC proceedings l
with respect to safety goals and methodology, degraded core cooling, siting and emergency planning, the Comission should make it clear that the final rule when
a "2.
Implement only those changes in the proposed rule which have been pronulgated and issued for use by the near term operating license plants.
For other changes, retain the existing rules pending completion of the post-TMI rulemakings."
Discussion The Comission has adopted Option 3, which will ensure that approved action items in the TMI Action Plan are applied to the new cps and will provide for early consideration of these added safety measures so as to minimize the costs of incorporating them into the design of the facility.
9.
COMMENTS ON PROMPT AD0PTION OF THE RULE l
Many of the comentors (AIF, EEI, Lowenstein, etc.) expressed strong support I
for the prompt adoption of the rule. One comentor (Boston Edison) submitted "that the Comission would be shirking its vital responsibility in this area if it did not issue a rule such as this and if this rule were not intended as binding upon the Comission's subsidiary boards." Another stated, "C-E agrees with the Comission's intent of defining the set of TMI-related requirements that are both necessary and sufficient to resume NRC review and approval of pending and ML applications. These requirements (as modified to reflect public coments) should therefore be issued expeditiously in conjunction with a clear enunciation of the sufficiency of those requirements, so that NRC staff action on pending applications can recomence."
Discussion The Comission believes that issuance of the final. rule is the proper response to these co'ments.
,. 10.
BASIS FOR COMPLIANCE WITH THE RULE A.
One commentor (Bechtel) noted that most of the items contained in the pro-posed rule reference action plan items in NUREG-0718 and WUREG-0660 and recom-mended that where the referenced paragraph in these NUREGs amplifies the requirements of the rule, it should be recognized as an acceptable means of compliance. Another commentor (Ebasco) aisc pointed out that the proposed rule imposes new requirements in areas where final NRC acceptance criteria have not been finalized and that NRC policy relative to implementation of those criteria must be flexible because of the different types of requirements. To expedite the CP hearing process, Ebasco suggested that " compliance with NUREG-0718 be considered prima facie evidence that TMI requirements have been met."
Discussion The Commission agrees with the comments. The Commission has reviewed NUREG-0718 and has concluded that.the positions contained therein currently provide a basis for responding to the TMI-2 accident. Applicants may, of course, f
propose to satisfy the rule's requirements by a method other than detailed in NUREG-0718, but in such cases must provide a basis for determining that the requirements of the rule have been met. NRC acceptance criteria will be suf-ficiently flexible to permit appropriate alternative methods of meeting the l
requirements.
B.
Two commentors (Boston Edison, Lowenstein) noted that "Some of the pro-visions of the proposed rule require the applicant to conduct studies and submit them to the NRC for review and appropriate action. Boston Edison
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pointed ou,t that "these studies will be completed af ter issuance of the con-struction permit, in some instances several years later. We believe it is
. by provisions of the proposed rule or are not applicable or appropriate for construction permit and manufacturing license applications.
- 12. COMMENTS ON CERTAIN RULE REQUIREMENTS The following discussion responds to the comments received on the specific items of 10 CFR 50.34(e) listed below:
(1)(i) - Plant / Site Specific PRA Study A. - Two commentors (S&W, CEC) point out that the NRC has not yet defined the methodology to be used in the PRA study.
Discussion The Commission notes that a PRA Procedures Guide is scheduled to be issued as a draft for discussion by an IEEE technical symposium in October 1981, and in proposed final form for consideration at an AHS conference in April 1982.
It is expected that the Guide will be published soon after the AflS conference.
Meanwhile, plans for a PRA study, and the actual conduct of the study, need I
not wait until the safety goal and degraded core cooling rulemakings are resolved. During a meeting with the CP/ML applicants on April 8,1981, the HRC staff made available a PRA program outline which should. serve as a guide-line for CP/ML applications. The program outline addresses issues such as the scope of the PRA study, how the PRA study should be performed, what should be considered in setting up a schedule, and, most importantly, how the results of the risk study should be factored into the design, fabrication and eventual operation of the plant to improve the reliability of core and containment heat i
It is reasonable to expect that an applicant can utilize the removal systems.
staff guidelines to develop its own program for performing a meaningful PRA study. Consequently, the Commission will retain this requirement.
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B.
Another commentor (GE) expressed the belief that " completion of the PRA studies and comparison to a reasonable safety goal will demonstrate that the f
Boiling Water Reactor includes design features which ensures that the public f
health and safety is protected.
If, on the other hand, the results of the i
studies...show that further risk reduction is appropriate, plant modifications...
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sho;ild be considered".
Discussion, i
Based on the risk studies performed to date, accident sequences relating to
-core and containment heat removal systems contribute substantially to overall accident risk. To reduce such risk, alternate system designs for core and con-tainment heat removal systems should be considered and PRA studies should be performed in comparison with the PRA study for the original design.
The outcome of the comparison should be selection of a system design from among several design alternative incorporates significant improvements in the relia-bility of core and containment heat removal systems. This-appreaeh-n-Mkely to be. cost-effective 4a-the-leng-tera.
C.
Two commentors (TVA, B&W) suggested that the improvements that may result
~ from the risk assessment should be those that are significant with respect to public health and safety, not just generally significant and practical.
Discussion The aim of the probabilistic risk assessment, as expressed in the requiremen,t, is to seek such improvements in the reliability of core and containment heat removal systems as are practical and do not impact excessively on the plant.
The Commission believes that such improvements in reliability would also be
40 -
(2)(v) - Hydrogen Control Measure Options (The connent was incorrectly shown as pertaining to (2)(v)-it was meant for (3)(v) and has now been included under that number on page 56.)
(2)(vi) - Reactor Coolant System Vents The commentor (CEC) notes that it may be well to review this requirement carefully on a plant specific basis to determine if any core cooling benefit can be identified; for some plants, reactor coolant system vents may offer no real benefit.
Discussion The reactor coolant system high point vent requirement was developed to provide a means to eliminate gases that could inhib' core coo'ing. Since all plants have a potentia ~i to release non-condensible gases, this requirement applies to all plants. Although events in which gas venting would be required are highly, unlikely, there does not appear to be an acceptable substitute at this time for those, cases where venting may be needed. Consequently, the Commission is retaining this requirement, but has made a minor wording change for clarifi-cation. The paragraph now reads:
" Provide the capability of high point venting of nonco'ndensible..."
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of sequences. Parametric analysis that adequately scopes the physical pro-cesses for the sequences under consideration woeld be acceptable.
(2)(x) - Relief and Safety Valves Two comentors (Bechtel, B&W) pointed out that this requirement appears to elevate ATWS to the status of a design basis event.
Discussion This is not intended, as the Comission is presently reviewing a proposed ATWS rule. Appropriate valve qualification requirements for ATWS can only be finalized after the Comission issues a final ATWS rule or decides that plants do not have to be designed to withstand an ATWS event. To clarify the intent of this requirement, it has been revised to read as follows:
" Provide a test program and associated model development and conduct tests to qualify reactor coolant system relief and safety valves and, for PWR's, PORV block valves for all fluid conditions expected under Consideration of oqerating conditions, transients and accidents.
anticipatedtransientswithoutscram(ATWS)conditionsshallbeincluded in the test program. Actual testing under ATWS conditions need not be i
carried out until subsequent phases of the test program are developed."
a n d -n eMef e re -hwa nee -eit-an -ATWS -sle,"
(2)(xii) - Auxiliary Feedwater System l
A comentor (CE) suggests that the requirement to " provide an analysis of the.
effect on containment integrity and return to reactor power of automatic AFW system initiation with a postulated main steam line lesk inside containment" be deleted since it would institute a regulatory requirement for an analysis
. degraded core rulemaking. Therefore, the Comr.iission has retained this requirement so as not to preclude later installation of containment venting systems, if required.
(3)(v) - Containment Design A.
One commentor (OPS) interpretes the information requested on post-inerting and ignition systems as not allowing pre-inerting as a hydrogen control measure.
Another commentor (CE) states that the level of detailed criteria requested by the Commission for hydrogen control obviates the use of alternative approaches to hydrogen control which may be developed in the future, and recommends elimi-nating the detailed criteria.
Discussion The Commission is not limiting the options for hydrogen control by including criteria for post-inerting and ignition systems. Other systems (e.g., pre-inerting) may be proposed to meet the requirements stated in the proposed rule.
Also, the level of detail in the criteria does not restrict design options for the post-inerting and ignition systems. The information requested on these systems is needed to ensure tnat operation of these systems will not adversely inpact the safe shutdown of the plant, B.
A commentor (OPS) suggested that, to be consistent with (2)(ix), " requirement I
(3)(v)(A) should be modified to permit containment analysis to be based on the performance characteristics of existing systems and/or systems to be added during final design." Th! commentor also suggested rewording (3)(v)(A) to make the text easier to read. In doing so, the commentor suggested deleting the explicit requireme'nt that the containment withstand the added pressure resulting from post-accident operation of the inerting system and inserted "the internal pressure shall be the maximum calculated pressure or 45 psig, whichever is greater."
In addition, this rule does not identify, as does NUREG-0718, the items from the TMI-2 Action Plan, NUREG-0660, that are considered either not applicable to pending con-struction permit (and manufacturing license) applications, or to be requirements of the type customarily left for the operating license stage. However, the Commission has reviewed NUAEG-0718, as revised to account for the changes made between the proposed and final rule, and has concluded that the list of THI-related requirements con-tained therein currently provides a basis for responding to the TM1-2 accident.
Applicants may, of course, propose to satisfy the rule's requirements by a method other than that detailed in NUREG-0718, but in such cases must provide a basis for determining that the requirements of the rule have been met.
Based upon its extensive review and consideration of the issues arising as a result of the Three Mile Island accident, the Commission has decided that pending applications for a construction permit (or marufacturing license) should be measured by the NRC staff and Presiding Officers in adjudicatory proceedings against the existing regulations, as augmented by this rule. It is the Commission's current view that this new rule, together with the existing regulations, form a set of regulations, conformance with which neets the re luirements of the Cenission for icsuance of a construction permit or manufacturing ifcense.
Some of the proposed rule's provisions deal with studies to be conducted by the license applicants. The Commission intends to impose license conditions upon all permits (and licenses) covered by this rule which will require submf ttal of these l
studies to the NRC for revied and appropriate action. The license conditions will l
specify due dates or may require that studies be submitted prior to harddare pro-
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curement or other construction events.
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, Regulatory Flexibility Statement In acenrdance with the Regulatory Flexibility Act of 1980, 5 U.S.C. 605(b), the Com-mission hereby certifies that this rule will not have a significant impact on a sub-stantial number of small entities. This rule affects six applicants for construction permits (and one applicant for a manufacturing license). These applications are for permits (or a license) for plants that do not fall within the scope of the definition of "small entities" set forth in the Regulatory Flexibility Act in the Small Business Size Standards set out in regulations issued by the Small Business Administration at 13 CFR Part 121.
OMB Regulatory Requirements Clearance The application requirements contained in this final rule affect fewer than 10 persons (applicants) and, therefore, are not subject to Office of Management and Budget clear-ance as required by F.L.96-511.
Pursuant to the Atomic Energy Act of 1954, as amended, the Energy Reorganization Act of 1974, a.s amend-J, and Section 552 and 553 of Title 5 of the United States Code, the Commission proposes to amend Part 50 of Chaptec 1, Title 10 of the Code of Federal Regulations as follows:
1.
A new paragraph (e) is added to 50.34 to read as follows:
50.34 Contents of applications; technical information (e) Additional TMI-related requirements.
In addition to the requirements of paragraph (a) of this section,
. each applicant for a light-water-reactor construe. tion permit or
- manufacturing 1. cense whose application was pendingMas of (insert effective date of rule) shall meet the require-ments in the following paragraphs (1) thru (3).
(1) To satisfy the following requirements, the application shall provide sufficient information to describe the nature of the studies, how they are to be conducted, estimated submittal dates, and a program to ensure that the results of such studies are factored into the final design of the facility. All studies shall be completed no later than two years
_following issuance of the construction permit or manufacturir.g license.
j (1)
Perform a plant / site specific probabilistic risk assessment, the
. aim of which is to seek such improvements in the reliability of core and containment heat removal systems as are significant and practical and do not impact excessively on the plant.
(II.B.8) 2,/
(ii)
Perform an evaluation of the proposed auxiliary feedwater system (AFWS), to include (applicable to PWR's only):
(II.E.1.1)
(A) A simplified AFWS reliability analysis using event-tree and fault-tree logic techniques.
(B) A design review of AFWS.
.(C) An evaluation of AFWS flow design bases and criteria.
MThis rule applies only to the pending applications by Boston Edison Company (Pilgrim Station, Unit 2), Duke Power Company (Perkins Nuclear Station Units 1, 2 and 3), Houston Lighting & Power Company (Allens Creek Nuclear Generating Station, Unit 1), Portland General Electric Company (Pebble Springs Nuclear Plant, Units 1 and 2), Public Service Company of Oklahoma (Black Fox Station,,
Units 1 and 2), Puget Sound Power & Light Company (Skagit Nuclear Power Pro-ject, Units 1 and 2), and [0ffshore Power Systems (License to Manufacture Floating Nuclear Plants)].
2/ Alphanumeric designations corresoond to the related action plan items in NUREG 0718 and NUREG 0660, "NRC Action Plan Developed as a Result of the TMI-2 Accident." They c.re provided herein for information only.
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(iii)
Perform an evaluation of the potential for and impact of reactor coolant pump seal damage following small-break LOCA with loss of offsite power.
If damage cannot be precluded, I
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(ix)
Provide a system for hydrogen control that can safely accomodate hydrogen generated by the equivalent of a 100% fuel-clad metal water reaction.
(II.B.8)
(x)
Provide a test program and associated model development and conduct tests, to qualify reactor coolant system relief and safety valves and, for PWR's, PORY block valves, for all fluid conditions expected under operating conditions, transients and accidents. Consideration of anticipate.i transients without scram (ATWS) conditions shall be included in the test program. Actual testing under ATWS conditions need not be carried out until subsequent phases of the test program are developed.
and-net before issuanse-es an-ATWS-nfier- (II.D.1)
(xi)
Provide direct indication of relief and safety valve position (open or closed) in the control room.
(II.D.3)
(xii)
Provide automatic and manual auxiliary feedwater (AFW) system initi-i ation, and provide auxiliary feedwater system fica indication in
, the control room.
(Applicable to PWR's only) (II.E.1.2)
(xiii) Provide pressurizer heater power supply and associated motive and control power interfaces sufficient to establish and maintain natural circulation in hot standby conditions with only onsite power available.
(Applicable to PWR's only)
(II.E.3.1)
(xiv) Provide containment isolation systems that:
(II.E.4.2)
(A) Ensure all non-essential systems are isolated automatically by the containment isolation system, l
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IN RESPONSE, PLEASE REFER T0: M810527A p.p n Ktc.,3*e
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UNITED STATES
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June 4, 1981 Cornell Rehm OFFICE OF THE Purple SECRETARY Minogue Shapar MEMORANDUM FOR:
Leonard Bickwit, Jr., Generit] Counsel
$Mliam J. Dircks, Execut
' Director for Operations FROM:
Samuel J. Chilk, Secreta
/
SUBJECT:
STAFF REQUIREMENTS - DI CUS ON OF SECY-81-20D - POLICY ON PROCEEDING WITH PEND:flG P AND ML APPLICATIONS, 2:50 P.M., WEDNESDAY, MAY 27, 1981, COMMISSIONERS' CONFERENCE ROOM, D.C. OFFICE (OPEN TO PUBLIC ATTENDANCE)
The Commission discussed the subject paper without reaching a final decision.
The Commission requested that the proposed final rule be revised to:
1.
clarify the language in the rule to identify that the rule would not apply to the CRBR; (EiS)N R R 2.
modify the reason for rejecting USDI's comments (pgs. 17-18 of to the subject paper) to remove the legal rationale and to indicate instead that as a matter of policy it is not necessary to. await the-completion of a siting rulemaking for these specific applicants; (EM) d Rf
- -3 ;
update the expected availability date for the IEEE/ANS methodology for the PRA study (pg. 33 of Attachment 3 to the subject paper).
(EM)flR R-The Commission requested that the appropriate conforming changes to Appendix B of Part 2 be prepared for Commission consideration.
(OGC)
Pending further Commission guidance, the staff was authorized, if it deems appropriate, to proceed with a review of applications on the basis of the revised NUREG-0718 and enter into hearings with that position.
cc:
Chairman Hendrie Commissioner Gilinsky Commissioner Bradford Commissioner Ahearne
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Da Public Document Room
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