ML20093L824
| ML20093L824 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 10/13/1984 |
| From: | Fiedler P GENERAL PUBLIC UTILITIES CORP. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| GL-84-15, NUDOCS 8410190214 | |
| Download: ML20093L824 (12) | |
Text
f, GPU Nuclear Corporation Nuclear
- g = 888 Forked River,New Jersey 08731-0388 609 971-4000 Writer's Direct Dial Number:
October 13, 1984 i
Mr. Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission i
l Washington, DC 20555
Dear Mr. Eisenhut:
Subject:
Oyster Creek Nuclear Generating Station l
Docket No. 50-219 Generic Letter 84-15 The atta'chment to this letter provides our response to the subject Generic Letter concerning diesel generator reliability.' A notification was made on Tuesday, October 2,1984 via telephone to our Project Manager indicating that several additional days were necessary for resolution of comments resulting from the review of our intended response.
If there are any questions regarding our response, please contact the undersigned or Mr. Drew Holland at (609)971-4643.
Very truly yours, As)
P er eifler Vice President and Director Oyster Creek PBF/ dam Attachments Sworn and subscribed to before me this d day of
,1984.
SA)Y A Notary PublinLofA NUMALDET A Notary Public of New Jersey cc: Dr. Thomas E. Murley, Administrator Region I U.S. Nuclear Regulatory Comission 631 Park Avenue King of Prussia, PA 19406 NRC Resident Inspector Oyster Creek Nuclear Generating Station N
Forked River, NJ 08731 8410190214 e41013
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hDRADOCK 05000219
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GPU Nuclear Corporation is a suouuiai
... _.. si Public Utilities Corporation
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Page 1 of 2 r
ITEM 1 - REDUCTION OF COLD FAST START SURVEILLANCES l
The Oyster Creek diesel generators are energized in the fast start mode during conduct of two surveillance procedures.
One procedure, " Diesel Auto Actuation Test", is performed on each diesel during refueling outages in accordance with Technical Specifications.
During this test, offsite power is interrupted to the safeguards power bus and the diesel fast starts to assume safeguard loads ' via sequence. timing.and single failure simulations.
This demonstration is performed once per diesel during each refueling outage.
l The second fast start sequence is performed on a staggered basis monthly for each diesel ~ generator. Since offsite power.and safeguards power buses ar e not interrupted during this = survelliance, the diesel generator breaker is racked down _to the test position such that breaker closure may occur without connection to1 the. power bus..In this manner, a complete fast start logic Lsequence 'is exercised although the diesel does not assume load.
Monthly fast
-start surveillance _ is not required by Oyster Creek Technical Specifications,
'but demonstrates fast start logic capability in accordance with the
. surveillance program.
'All other required Technical Specification operability demonstrations required are performed through automatic synchronous peaking load controls.
i?
In this. mode, the manufacturer's automatic 90 second idle period prewarms and lubricates the engine -prior to speed acceleration and auto synchronization to
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'the power bus.
. HPriori to_ August of 1983, the diesel generator monthly fast start logic
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tests ware conducted only after prewarming the diesel vla an automatic peaking
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' load start as _a prudent action recommended by the diesel vendor.
A significant -experience evolved in August,1983 during a scheduled fast start
. test that ultimately uncovered a " masking" effect due to prewarming diesels.
L-It was.found.that an " improved model"~ governor placed on' Diesel Generator No..
'l!had-decreased the speed pickup rate during cold fast' start attempts causing f-
' a lag in generator voltage buildup.
The impact was not observed until the surveillance 'was " inadvertently" performed without prewarming.
In an effort
(
to avoid " masking" problems.as observed, one of the corrective actions stated l
In R.O. J #83-17 was to preclude prewarming diesels prior to fast start
'surveillances.. As a result of the 1983 experience, and concerns by L Oyster Creek personnel. of additional cold fast star ts, a decision had been made to reduce 1 frequency from monthly to quarterly ~ for tests after newer model gove'rnors were installed and' tested.
Since these governors have recently been
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- installed and successfully tested, the ability exists to reduce the number of
' cold fast _ starts as requested.
The original LER will be revised indicating L
additional findings-from the experience and corrective action changes from l1 this Generic Letter.
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Page 2 of 2 ITEM 1 - REDUCTION OF COLD' FAST START SURVEILLANCES Based on the above, Oyster Creek will take the following actions to
- reduce the number of cold fast starts during diesel generator surveillances:
I.
0.C. ~ Procedure 636.2.002 - Frequency of test will be reduced from monthly to quarterly.
Since this surveillance was originally intended to exercise the fast start logic for proper sequence, all starts in this ' manner will be prewarmed, except one during refueling outages.
This reduces the cold fast start from 12 per year to 1 per operating cycle, while still checking logic sequence on a quarterly basis.
Technical Specification changes are not. required for such a procedure revision.
-- II.
0.C. Procedure 636.2.001 - NO CHANGE This procedure is presently performed once per diesel during refueling periods at Oyster Creek.
The Oyster Creek Technical Specifications do not require tests of diesels for. Inoperability of core cooling system components.
Therefore, changes to Technical Specifications are not required.
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Page 1 of 1 ITEM.2.- DIESEL GENERATOR RELIABILITY DATA e
-The reliability of ' Diesel Generators (DG) at Oyster Creek presented as described 'in Generic Letter 84-15 and per the criteria of Regulatory Guide
-1.108, position C.2.e thru 9/3/84 are given as follows:
Last 20 Valid Tests Last 100 Valid Tests D.G.
Failures Reliability Failures Reliability
~ D.G.'.1 1
.95 1
.99
'D.G. 2 1
.95 1
.99 It should_ be noted that the monthly fast start surveillance is performed with the diesel generator breaker racked down.
As such, this surveillance does not meet criteria of Reg. Guide l'.108, position C.2.e (4) for a valid test.
Therefore, some failures and maintenance have occurred.(and been
. hich.are not. included reported in accordance' with Technical Specifications) w above.
Since -a diesel _1oad surveillance is always oerformed following the monthly fast start surveillance,, the data does include all Technical Specification required operability demonstrations.
Appendix A contains a log compiled from plant records which itemizes the valid starts-and failures in-accordance with Reg. Guide 1.108, position C.2.e.
Tests which were terminated intentionally. by order of the Group Shift Supervisor (due to potential - diesel 'or component damage) are recorded as invalid. If, the diesel would.have ~ started successfully in. an emergency, and were considered valid failures if the condition would have prevented a successful emergency start.
A. formal log 'or record of diesel generator demands, failures and
. operation in the format. suggested by Regulatory Gaide 1.108 has previously not been kept at Oyster Creek.
However, several reliability studies have been performed, including one in similar, but varied format for earlier periods of time.
Those: studies reviewed numerous plant documents to -arrive at the format for the~ He acknowledge the benefit of a centralized log in uniform required data.
many corporate reviews of diesel generator performance.
Therefore, we will incorporate the -appropriate methods and administrative controls for'an integrated, uniform' log for diesel generator operation, t
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Page 1 of 1 1
ITEM 3 - DIESEL GENERATOR RELIABILITY 4
a Reliability improvement actions : at Oyster Creek have included detailed reviews by,various independent GPUN departments, and by maintenance personnel
- closely associated with ' diesel generator operation.
With approximately 30 years of diesel _ operating experience, Oyster Creek has observed original failures along.with the varied actions which have -been successful.in correction of those deficiencies.
Increased diesel reliability,, root cause investigations,'and positive corrective actions continue to be the key points in-review of any deviation from normal operation observed.
During conduct of diesel performance reviews,-a specific numerical reliability goal has not been
-used,- although histories of ~ failures have been reviewed to affirm all actions have.been. taken, and that actions are' appropriate for. resolution.
In recent
.. years, greater levels. of action ' have been taken to provide recommended vendor improvements and upgrades to enhance performance and reduce failures encountered.
As indicated in. Item 2, logs which will be. maintained will provide data fore future evaluations regarding diesel generator reliability.
Efforts to install identified improvements will continue as they become apparent from vendor's recommendations, and from operating experience.
Improvements-in
. training, root 'cause evaluations, and attention.to recommended upgrades to increase operability and maintainability have been the essential elements in the reliability of diesel generators.
.NUREG/CR 0660, Enhancement of On-Site Emergency Diesel Generator Reliability", was reviewed' as prescribed to determine how the findings relate to : improvements to diesel performance.
Since the Oyster Creek station was one of the sites ' visited during compilation of this document, we have been previo:: sly aware of and have drawn attention to some of its findings.
A brief
. synopsis of review findings follows:
. 1.)
Air Start Systems < --Diesels at Oyster Creek are electric start units -
air start systems do not apply.
I 2'. )
Diesel Room Air Quality - Controls and most equipment described are contained presently in protective control cabinets.
Our experience has not-indicated any failures due to environmental contaminants via -air sources or flow. The inertial air inlet filters and generator oil bath
' filters appear to be adequate.
Turbocharger Heavy Duty Gear Drive - Note: This item closely relates to 3.)
a vendor recommended Turbocharger / Bearing Oil Modification. - Oyster Creek will review. the vendor's recommendation to determine if installation would benefit the diesel engines.
We have found through inspections recently conducted, that there is a minimum of 30 psi oil pressure in Turbocharger bearings at all times, even when diesels are in ' the Standby Mode.
He feel that the lack of turbocharger bearing wear indicates there is ample lube oil pressure available.
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Page 1 of 3 i -
ITEM 3 - COMMENTS; ATTACHMENT TO ENCLOSURE 3
(" Diesel Generator _ Performance Technical Specifications")
As requested,, the 'following are comments on the propose'd performance specifications:
Rella'bil'ity Program:
/
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lThe suggested -level of.95 as' a minimum desired reliability goal is reasonable._.However, it is our opinion.that certain repairs are
_ corrective in nature and of-themselves restore the reliability.
Without consideration of actions previously taken (or reliability data correction), one could proceed to further remedial activities based on 100: start data with no tangible increase of diesel-reliability. A more
' accurate. assessment can be provided when -a _ corrected failure proves successful -during the next 10 to' 20 component cycles, indicating: that
~
risk of repeated component. failure in 100 starts has been significantly reduced.
Whereas, a repeat failure in _10 to. 20 component' cycles clearly indicates actions. were not sufficient and further remedial actions are required.
2.
Reliability level remedial actions should depend on and vary dramatically _ with : the type of component failure, how often it has
~
failed, land the corrective action to preclude further failures.
An example might. be - failure of.a fuel _ transfer motor contactor.
When 2
failure occurs, it will be replaced and demonstrated by a start of the
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diesel.
If the diesel operates for one or two hours, the' transfer pump relay has. operated (3 to 6 times for one start of the diesel unit and certainly " works" or the test demonstration would have failed.
For a repeat failure. there is obviously_ some other action required.
Increasing. surveillance frequency, or providing -specific numbers of
~ tartsfof-the' diesel unit, will_ provide undue wear and tear on all s
engine and control-components. He believe that root cause analysis and proper: -corrective actions require a case ' by. case determination of appropriate actions.
He cannot concur that considering a diesel unit inoperable, for - the 1 purpose - of statistical enhancement through more diesel
- starting, is prudent remedial action.
On completion of
. appropriate corrective measures and proper testing, there would be no reason'to continue _to test without a basis for doing so.
3b.
Comments regarding' ~ accelerated surveillance testing are described in section' 2.
Increased surveillance. frequency should only occur when such a. test is' judged prudent due 'to the uncertainty of repair actions.
.4.
'Although-we have no - objection to supply information and data as e
suggested, our recommendation regarding report requirements would be to f
utilize 10CFR 50.73 (b) (6) (c), " Supplemental Information" instead of imposing unique reporting mechanisms for individual plant systems.
If
'such information is required by -others in the NRC, we recommend the information be obtained at the plant site through appropriate channels.
- The requirements for information reports suggested in - 'to. Table 4.8-2, particularly the explanatory paragraph following item f), are complex and should be simplified.
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ac Page 2 of 3 ITEM 3 COMMENTS; ATTACHMENT TO ENCLOSURE.3
(" Diesel Generator Performance Technical Specifications")
-5.
We agree that levels as described indicate unsatisfactory performance. ' The method, however, to resolve the deficient conditions should be close scrutiny and more positive corrective a<
action. An unscheduled thorough maintenance inspection may be called for,'along with review and adjustment.of Preventive s Maintenance timing.' A requirement which dictates large numbers
- ~
of starts when'other auxiliary components have failed would certainly take a toll.on all engine and control components,
~ possibly resulting 'in future-additional failures.
It would appear such requalification mAy shift the proper haintenance intervals, Mean Time Between Failures (MTBF), that have over the years been incorporated in Preventive Maintenance programs.
6.
-No Comment.
- 7..
Generator to be inoperable during power operation for 7 days in Concur - Qyster Creek inoperability limits allow one Diesel any 30 day period, however,'.there will have to be a' proper balance of-planned maintenance intervals vs. availability criteria or diesel reliability in the long run will be degraded.
~
8.:
Qyster Creek agrees Reg. Guide 1.108 position C.2.e criteria are reasonable.:
9.
-Qyster Creek concurs with maintaining a diesel operation log as u
t previously described. - However, Attachment 1 to Table 4.8-2, as
. referenced.in Sec. 9,' appears to add significant reporting.
l-requirements. Qyster Creek believes with required data-available on site, in a uniform format, that there are ample methods to audit, review or request copies via NRC Resident Inspectors. We would not favor or recommend additional unique L
reporting requirements.
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Page 3 of 3
= ITEM 3'--COMMENTS; ATTACHMENT TO ENCLOSURE 3
. (" Diesel. Generator Performance Technical Specifications")
Appendix A,'" Typical Technical Specifications", goes further than the question of diesel reliability programs, since it would be unique for each plant
.' design.
Comments relative to diesel reliability and pertinent to Appendix A
-were included above.
In regard to Attachment 2 to Table 4.8-2,
" Diesel Generator Requalification Program", we must restate our position given in Section 2 and 5 comments, indicating such a program for operating power plants could be counterproductive.
In summary,. diesel engine demands are unsuccessful because of (sub) component failures.
Subsequent. testing to. requalify the diesel should consider failed component reliability and appropriate testing applied to. the subject component.
The entire diesel generator should not be subjected to wear and tear unnecessarily.
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APPENDIX A EMERGENCY DIESEL GENERATOR START DATA DIESEL GENERATOR NO. 1 Page_,.L. of-4 START DATE COLD OR VALID LOADED ND.
HOT START Cl # rCC FAILURE YES ND 1 HR - MIN.
CDD94ENTS 1
9-03-84 WARM X
X-YES 2
8-27-84 WARM X
X YES 3
8-20-84
. WARM X
X YES 4
8-14-84 WARM X
X YES FOLLOWING RADIATOR AND GOVERNOR REPLACEMENT 5
7-30-84 WARM X
X YES 6
7-23-84 WARM X
X YES 7
7-16-84 WARM X
X YES 8
7-09-84 WARM X
X YES
+
9 7-02-84 WARM X
X YES ADJUSTED LOAD LIMIT TO SLM4ER CURVE (2750 KW 9100 F) 10 6-18-84 WARM X
X YES
'11 6-04-84 WARM X
X l
NO (10 MIN)
FUEL TRANS. SWITCH OFF GSS TERMIN. TEST (AFTER SWTICH TURNED BACK ON) 12 6-04-84 WARM X
X YES 13 5-28-84 WARM X
X YES 14 5-21-84 WARM X
X YES 15 5-07 WARM X
X YES 16 4-30-84 WARM X
X YES 17 4-23-84 WARM X
X YES 18
'4-16-84 WARM X
X YES 19 4-14-84 WARM X
X YES 20 4-07-84 WARM X
X YES al 3-26-84 WARM X
X YES 22 3-20-84 WARM X
X YES 23 3-15-84 WARM X
X YES 24 3-10-84 WARM X
X YES 25 2-27-84 WARM X
X YES 26 2-20-84 WARM X
X YES FUEL OIL NOT TRANSFERRED FOLLOWING TEST (GAUGE ERROR) 27 2-13-84 WARM X
X YES SLIGHT DRIFT IN VARS DURING WARMUP - TESTED 0.K.
28 2-06-84 WARM X
X YES j
A9 2-01-84 WARM X
X YES MOMENTARY HIGH F.O. TANX ALARM - ADJ. SW.- TO PROPER LEVEL i
30 1-30-84 WARM X
X YES 31 1-25-84 WARM X
X YES 32 1-24-84 WARM X
X YES 33 1-22-84 WARM X
X YES (AFTER F.O. TRANSFER MOTOR REPLACMENT) 34 1-21-84 WARM X
X NO (30 MIN)
TEST TERMINATED BY GSS - NO.1 F.O. PUMP MOTOR FAILING - NO. 2 PUMP 0.K.
i 35 10-03-83 WARM X
X YES 36 9-26-83 WARM X
X YES 37 9-20-83 WARM X
X YES l
38 9-12-83 WARM X
X-YES 39 9-06-83 WARh X
X YES 40 8-29-83 WARM X
X YES 41 8-27-83 WARM X
X YES 42 8-08-83 WARM X
X YES 43 8-01-83 WARM X
X YES 44 7-25-83 WARM X
X YES 45 7-18-83 WARM X
X YES 43 7-12-83 WARM X
X YES ADJUSTED LOAD LIMIT TO SUP91ER CURVE I
47 7-05-83 WARM X
X YES 48 7-05-83 WARM X
X YES 49 6-27-83 WARM X
X YES l 50 6-20-83 WARM Y
X YES 1
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APPENDIX A EMERGENCY DIESEL GENERATOR START DATA DIESEL GENERATOR NO. 1 Page_1, of 4 START DATE COLD OR VALID LOADED Mo.
NOT START C M*G FAILURE YES NO 1 HR - MIN.
ColetENTS 51 6-24-83 WAIM X
X YES 52 6-06-83 WARM
.X X
YES 53 6-01-83 WARM X
X YES 54 5-26-83 WARM X
X YES 55 5-23-83 WARM X
X YES 50 5-16-83 WARM X
X YES -
57 5-09-83 WARM X
X YES
' 58 5-02-83 WARM X
X YES 59 4-25-83
. WARM X
X YES 60 4-18-83 WARM X
X YES 61 4-11-83 WARM X
X YES-62 4-04-83 WARM X
X YES 63 3-28-83 WARM X
X YES i
64 3-21-83 WARM X
X YES 65 3-14-83 WARM X
X YES 1
66 3-08-83 WARM-X X
YES i
67 2-28-83 WARM X
X YES 68 2-22-83 WARM X
X YES 69 2-14-83 WARM X
X YES 70 2-07-83 WARM-X X
YES 71 1-31-83 WARM X
X YES 72 1-24-83 WARM X
X YES 73 1-17-83 WARM X
X YES 74 1-10-83 WARM X
X YES' 75 1-03-83 WARM X
X YES 76 12-27-82 WARM X
X YES
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77 12-20-82 WARM X
X YES i
78 12-16-82 WARM X
X YES 79 12-06-82 WARM X
X YES 80 11-29-82 WARM X
X YES 12/3/82 - CHECKED F.O. TANK LEVEL SWTICHES FOR SETTING j
81 11-22-82 WARM X
X YES 83 11-15-82 WARM X
X YES 83 11-08-82 WARM X
X YES 84 11-01-82 WARM X
X YES 85 10-25-82 WARM X
X YES 86 10-21-82 WARM X
X YES l
87 10-20-82 WARM X
X YES 88 -
10-19-82 WARM X
X YES 89 10-18-82 WARM X
X YES 90 10-13-82 WARM X
X YES j
91 10-04-82 WARM X
X YES 92 9-27-82 WARM X
X YES.
93 9-20-82 WARM X
X YES 94 9-13-82 WARM X
X YES 95 9-7-82 WARM X
X YES 96 8-31-82 WARM X
X YES 97 8-24-82 WARM X
X YES 98 8-16-82 WARM X
X YES 99 8-10-82 WARM X
X YES 100 8-09-82 WARM X
X YES 101 B-02-82 WARM X
X YES 2
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APPENDIX A EMERGEleCY DIESEL GE.iRATOR START DATA DIESEL GENERATOR NO. 2 Page 1_.'e 4
START DATE COLD OR VALID LOALED No.
NOT START CI W rtC FAf t ilDE YES NO-1 MR - MIN.
C0f00ENTS 1
9-03-d4 WA8M X-X YES 2
3-01-84 WARM X
X.
-YES.
3 7-23-84
- WAIB1 X
X
,YES 4
7-09-84 WAeIM
.X X
YES 5 26-84 WAllH X
X YES 6'
6-11-84 WAllM X
X'
.YES-7 6-05-f!4 WARM X
X
~ YES
'8 5-28-84 WAllM X
X MO START GOV. FAILED (BLOCKED LOW SPEED PORT-AGE RFLATED) REPLACED.
9 5-04-84 WARM X
X YES 10 4-16-84 WARM X
X
- YES, 11 4-09-84.
WAllM X
X YES 12 4-02-84 WARM X
X YES 13 3-22-84 WARM X
X YES.
14.
3-25-84 WAllM X
X YES 15 3-15-84 WARM-X X'
YES-16 3-06-84 WAllM X
X YES 17 3-05-84 WAllM X
X YES 18 3-03-84 WAllM -
X X
YES 19 3-02-84 WAllM X
X YES 20 1-25-84 WAllM X
X YES i
21 1-16-84 WAllM X
X YES 22 1-09-84 WARM X
X YES 23 -
1-02-84 WARM X
X YES 24 12-26-83 WAllM X
X YES 25 12-19-83 WAllM
.X X
YES 26 12-12-83 WAllM X
X.
YES 27 12-05-83 WAllM X
X YES 28 11-28-83 WARM X
X YES 29 11-21-83 WAllM X
X YES 30 11-14-83 COLD X
X APP. 8HR a70% EMEllG. START-LOSS OF OFFSITE POWER DUE TO SWITCH YARD FIRE 31 11-07-83 WAllM -
X X
YES 32 10-31-83 WAllM X
X YES 33 10-26-83 WAllM X
.X YES 34 10-18-83 WAllM X
X YES 35 10-13-83 WAllM X
X YES 36 10-12-83 WARM X
X YES 37 10-11-83 WARM X
.X YES-38 10-10-83 WARM X
X YES 39 10-04-83 WAllM X
X YES 40 9-20-83 WAllM X
X YES 41 9-06-83 WAllM X
X YES l
42 8-27-83 WAllM X
X YES 43 8-26-83 WAllM X
X YES 44 8-25-83 WAllM X
X YES 45 8-24-83 WAllM X
X YES-ADJUSTED GOV. LOAD SWITCH. FROM 600 KW TO 400 KW i
46 8-23-83 WAltM X
X YES 47 8-22-83 WAllM X
X YES 4
48 8-21-83 WAllM X
X YES 49 8-20-83 WAllM X
X-YES 50 8-19-83 WAHM X
X YES 4
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