ML20100R277
| ML20100R277 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 12/12/1984 |
| From: | Hollar D CAROLINA POWER & LIGHT CO. |
| To: | |
| Shared Package | |
| ML20100R257 | List: |
| References | |
| OL, NUDOCS 8412170368 | |
| Download: ML20100R277 (16) | |
Text
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D'ecember hhhE
- '0A WC14 N{fg UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION (cricdfn reca 1
S, gv-BEFORE THE ATOMIC SAFETY AND LICENSING BOARD '
P In the Matter of . ) <" .
)- .
- CAROLINA POWER & LIGHT COMPANY )
AND NORTH CAROLINA EASTERN ) Docket No. 50-400 OL -
MUNICIPAL POWER AGENCY
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(Shearon Harris Nuclear Power Plant) )
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AFFIDAVIT OF JESSE T. PUGH, IIIIN SUPPORT OF APPLICANTS' MOTION FOR
SUMMARY
DISPOSITION OF EDDLEMAN CONTENTION 57-C-13
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' County of Wake.
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, ) SS:
- State of North' Carolina )
JESSE T. PUGH, III, being duly sworn, deposes and says:
- 1. I'am the Director of the Division of Emergency Management of the North
- Carolinac Department of Crime Control and Public Safety. In my position, I am
> responsible for the State's planning for and response to all emergenciefi including accidents at' any of the. four nuclear plants that affect North Carolina.
e In that
- professional capacity, I have been involved in the development of the off-site emergency l
response capability for the'Shearon Harris Nuclear Power Plant as well as the Catawba, McGuire' and Brunswick nuclear plants. Through the Division of Emergency Management, .
1 -have directed the State's response to .more than 650 cases in the last year alone, i
' including the tornadoes in March and Hurricane Diana in September. As a result of both
! these disasters, several thousand persons had to be sheltered for various lengths of
, 8412170368 841212 l
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time. ~ In addition to these practical experiences, I have completed the Shelter Manager
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. Course and Radiological Defense Officer Course conducted by this Division. 'A' current
- statement of "my- professional , qualifications and experience is attached hereto as
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Nttachment. l. My business address is 116 West Jones Street, Raleigh, North Carolina i 27611. I have personal knowledge of the matters stated herein and believe them to be
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- true and correct.E I make this Affidavit in response to Eddleman ContentiEn 57-C-13. I.
have reviewed-this contention and am familiar with the substance of the' allegations ' "
contained theeein.
'2 . I am aware that the Licensing Board admitted Eddleman Contention 57-C-13
. into this proceeding insofar as it calls for the best protection factors in each hospital and
" ~ nursing home _ within the plume exposure pathway EPZ of the Harris Plant to be-determined in advance of the emergency preparedness exercises for the Harris Plant. In 41 response to the coneerns raised by this contention, a. survey of each nursing home, hospital and family care facility within the EPZ has been undertaken. As a result of this
. survey, the areas of each facility which would provide the greatest protection from a radiation release are now known. I believe that the availability of this information satisfies all of the concerns raised by Eddleman Contention 57-C-13, as admitted by the
. Board., The purpose of this- Affidavit is.to describe the criteria that were used in t
determining which areas provided the greatest protection, how the survey was. conducted,. .
and what the results are.-
- 3. Atmospheric releases of radioactivity resulting from accidents at nuclear power plants like the Shearon Harris Nuclear Power Plant would form a cloud or plume carrying Y ' gaseous fission products and particulates. The' effectiveness of a given shelter -in providing protection against a passing radioactive plume can be measured by the degree of reduction in the direct exposure and inhalation doses it affords its occupants. T1.!s reduction can be characterized by a protection factor (the ratio of the dose outside to
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- the dose inside) for each exposure pathway. For the direct exposure pathway, the shelter
- will reduce the dose two ways: first,' by being a barrier or shield against the radiation coming from a cloud, and, second, by, increasing the distance .between the outside
- radioactive cloud and an occupant inside. Therefore, the greater the number of barriers .
between'the outside of the radioactive plume and the shelter occupant and the denser the J
barrier material, the better will be the protection factor ("PF") for the direct exposure
. pathway. In addition, in order to benefit from distance, the further away from outside '
T walls, the lesser the direct dose will be. For the inhalation exposure pathway, the degree
-of protection will be' a function of the air exchange rate with the outside. This -
phenomenon is governed by the type of apertures and outside covering of a structure. .
With leakage occurring through outside doors and windows, the rooms with these openings will have'the highest radionuclide concentrations since it would take a longer period of i
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time for a volume of ' air in a' centrally located room to be exchanged with outside contaminated air. -
~4. 'Given the information outlined in paragraph 3, criteria for determining the best PF areas within hospitals, nursing homes and family care centers within the Harris plume EPZ.have been developed. Within a given structure, areas having the best PFs will be
' centrally locat'ed, away from doors and windows, and will have the maximum number of horizontal and vertical partitions (e.g., outside and inside walls, upper floors, and roof) .
between them and the outside environs.
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- 5. A survey was conducted of each nursing home, hospital, and family care facility located within the Harris plume EPZ during the week of October 15,1984. The names and capacities of the . facilities surveyed are identified in Attachment 2 to this Affidavit. The su.vev was' conducted by two engineers, under contract with Carolina Power ~& Light Company, who are certified by the Federal Emergency Management Agency as fallout shelter analysts.
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,6. The survey procedure involved interviewing the owners or administrators of 3.each facility and inspecting.the interior and exterior structural features of the facility.
- Special emphasis was placed on those aspects
- of the facilities which determine.their
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' effectiveness in ~ reducing radiological doses received via direct exposure and inhalation .
pathways. In this regard, the following features were noted in the survey:
type of structure (e.g., single stocy, frame) presence of basement - --
outside covering (shingle, clapboard,' brick, etc.)
type of interior and exterior windows type of roof and roof covering construction materialof exterior walls c -
construction material of interior walls presence of corridors and hallways capability to isolate rooms with windows from hallways or corridors 7.- The survey revealed that the structures fallinto three general categories: (1) family care centers which were formerly private residential houses, (2) nursing homes
..which are designed and built especially for care of elderly persons, and (3) hospitals. The '
only exception is Homes for the Elderly in Fuquay-Varina, which is a community of 72 l one- and two-bedroom apartments. .
- 8. A -detailed listing-of the descriptive features for each facility surveyed is
. contained in Attachment 3 to this Affidavit. Attachment 3 also identifies those areas l
within each facility which afford the best protection factor. The following general conclusions can be drawn from the survey: (1) Some of the family care fricilities do not-have~an area which offars substantially better shelter effectiveness than the remainder t _
- of the facility, and (2) the nursing homes and hospitals, due to floor plan layouts and
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construction materials of interier and exterior walls, have locations with significantly i'
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, L better protection factors than other locations within the same facility. -
- 9. - As can be seen from the Information in Attachment 3, most of the family care
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- facilities were formerly . single family homes having one ~ story and no basement. : Theh-general floor plan is such that rooms that can be occupied for relatively long periods of -
time are usually off hallways ~or have' at-least one-wall, with windows which have an exterior wall. The symmetry of the facility's floor plan and the use of'the same construction materials for different sections-of the facility result in a homogenous " ->
structure. ' The occupants- of, the various parts of :such -houses ~ will receive roughly; comti arable protection from the radiation of a plume ' carrying gaseous radionuclides.
. Attachment 3 contains guidance on steps to be taken to minimize the dose received by persons in each facility and identifies a "best" PF area where possible.
- 10. . The areas with better PFs in the nursing homes and hosplials were determined
- . ' to be those sections of their large corridors away from entrances and lobbies. These
. Institutions are generally constructed of concrete blocks, sometimes with brick veneer
. exteriors.' Their interior walls are also of concrete blocks. Consequently, occupants
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temporarily placed in a corridor would be protected from .the source of direct radiation by at least two sets of concrete block walls along either side of the corridor. Further, the areas close to the ends of the corridors, usually near side entrance doors, should be
, eliminated as potential "better" sheltering locations.- ,,
l l -. 11. On the basis of my review of the methodology used to conduct this survey, I f
l believe that it was conducted professionally and that the results accurately identify the h best PF areas of each facility surveyed. Accordingly, the Division of Emergency l
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l Management accepts the survey results and will utilize them in its planning for a l potential accident' at the Harris Plant.
- 12. ~ When the survey.was conducted, the owners or administrators of all facilities j- were orally apprised of which areas within their facility provide the best protection from L
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a radiation release. As a followup, a letter will be sent to each owner or administrator telling him or her the survey results and recommending a preferred sheltering location
. within the facility. In addition, the -Division of Emergency Management will retain information from the survey on file for use at the time any accident may occur. The availability of this information affords assurance that maximum protection is provided to
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all hospital, nursing home or family care facility patients, should sheltering be required .
in the event of an accident at the Harris Plant.
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/ ESSE T PUGE Ill
! Subscribed and sworn to before me, this /fd day of December 1984.
4&c M, -SC Notpy Public My commission expires: /j M7[V ^
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b W' Attachm nt 1 JESSE THOMAS PUGH, III .Paga.1.of 2 \
Profess'ional-Qualifications EDUCATION Graduated Asheboro High~ School, Asheboro, North Carolina, 1965 North Carolina State -University, Raleigh, North' Carolina, 1969, B.S . ,- Textile Technology -
Computer Appiication Certificate Program, NCSU, Spring 1982 ~ -
Enrolled in Master of Public- Administration Program, NCSU
' Graduate, 1 Governmen t Executives Institute, University of North Carolina, Chapel Hill,1980
-EMPLOYMENT Area Coordin'ator, Division of Civil Preparedness, Asheboro, North Carolina, July 1978 - May 1979. Responsible for 15-county area, working with local coordinators and governmental officials in-preparing plans to-prevent and/or. respond to disasters, both natural and man-made. Also responsible for arranging specialized-training for local volunteers and governmental employees.
Assistant Director, Division of Emergency Management, May 1979. -
May 1980, promoted to -Deputy Director May 1980. Responsible-for dall'y' opera tions of the Division. Supervise 53 employees, administer budget of approximately $2 million, managed grant program to local governments, represent the State in business transactions and in meetings with local; and federal government.
Division Directcr, Division of Emergency Management, May 1982 to present. Responsible for the State of North Carolina emergency response.and planning. This includes the coordination of all
- emergency response activities of the 17 State agencies. Serve as State Coordinating Officer and Governor's Authoriz ed Representative in all disaster related matters. In em ergencies serve as leader of the State Emergency Response Team.
MILITARY '
United States Marine Corps, June 1969 - April 1982, highest rank:
' First Lieutenant
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a Attachm:nt 1 Page 2 of 2 \
Radiological Monitoring: Instructor Course, August 1978 Basic Seminar for Civil Preparedness Personnel, September 1978 _
Civil Preparedness Career Development, Phase I, September 1978 Basic Radiological Defense Officer Course, - September 1979 United State Coast Guard National Search and Rescue School, Governor's Island, New York, March 1984.
PROFESSIONAL ORGANIZATIONS North Carolina ^ Emergency Management Association National Coordinating Council on Emergency Management
- National Association for Search and Rescue National Emergency Management Association Association'of State Dam Safety Officials Oe d
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. Atta hment 2
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. HOSPITALS,' NURSING HOMES AND FAMILY CARE FACILITIES LOCATED WITHIN THE SHNPP PLUME EXPOSURE PATHWAY EMERGENCY PLANNING ZONE Number of
- A. Hospitals . ~ Beds or Rooms
- l. ~ Southern Wake Hospital 28
- 2. . . Western Wake Hospital 20 B.? Nursing Homes
- 1. Kinton Nursing Home l 80
- '2.- Atwater Rest Home 27 3.'
- James Rest Home 27
' C.' Family Care Facilities
- 1. - Adams Famil'y Care 2 18 2.' Morrison Family Care 3 19
- 3. Friendship Family Care . 8 4.' .' Anderson Family Care. 7
- 5. . Seagraves Family Care . 7
. " 6.' - Brown Family Care Center 10 '
' 7. . Jack and Clarice Family Care 6
- 8. : - Lyles Family Care .
10
- 9. ' Apex Family Care Center 7
-D.. Senior Citizen Community
- 1. Homes for the Elderly 4 72 Notes: ,,,
!' (1)l Complex . consists of 16 one-bedroom apartments and 1. forty-nine bedroom L . structure -
l: (2)- Facility consists of 2 houses
! ;(3)- Facility consists of 3 houses . .
l- '(4) Complex is made up of 12 two-bedroom and 48 one-bedroom apartments 1
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.c Attachment 3
..Page 1 of 7 -
DESCRIPTIVE FEATURES AND BEST PF AREAS OF HOSPITALS, I
' NURSING HOMFS AND FAMILY CARE CENTERS LOCATED WITHIN ~
. : SHNPP PLUME EXPOSURE PATHWAY EPZ
- A. - - Hospitals j l. 1 Facility: - Southern Wake Hospital Location: Fuquay-Varina, NC - ,
Structure: Single story, no basement ,
Building height: Approximately 10 ft.
E Exterior: Concrete blocks with formed stone
. . covering
- Roof: - Flat built-up, base is concrete over metal decking ' .
. Windows: .
Sliding with aluminum frame Interior walls: . Concrete blocks
- Best protection factor area: Portions of corridors away from entrance doors. .
2.- Facility: Western Wake Hospital ,
- Location: Apex, NC l Structure: Single story, no basement -
- Building height: - Approximately 10 ft..
- - Exterior: Brick veneer covering concrete blocks Roof: Flat _ built-up, base is concrete over.- !
- metal decking
. Windows: . Rear of building has large windows
- with floor to sill height of-approximately 3 ft.-
- Front of building has no windows Left side has windows at' approximately a floor to si,11 height of- ,
7 ft.
I Right side of building ha1large -
.. windows and a double vestibule entrance.
'All window frames are aluminum .'
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' Interior walls: Concrete blocks General note: Building has interior rooms with no direct connection to the outside.
p' However, these rooms (e.g. surgery C room, recovery room, X-ray room)
, are not suitabla fc* 7,chgcJ periods of shelter.
De?' puts;O. lhetoe area: Portions of corridors away from r e entrance doors. ,
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Attachment 3-Page 2 of 7 B. Nursing Homes
- 1. Facility: ; Kiriton Nursing Home
. Location: ; Fuquay-Varina, NC
. ' Building: . . Main Complex- y Structure: Single Story, U-shape, no basement Exterior: Brick veneer covering concrete ~ '
blocks Windows:. Horizontal sliding with aluminum frame with floor to floor sill height -
of approximately 4 ft., 6 f t.' on bathrooms Roof: . Sloped,_ asphalt shingles . over tar paper and plywood Interior walls: Concrete blocks General floor layout: U-shape, centrally divided by corridor '
with rooms on both sides. All rooms have at least one wall which is .an
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exterior wall Building: ' Apartments Structure: Single-story, one-bedroom, no basement
-Exterior: Brick veneer over wood frame Roof: Sloped, asphalt shingles over tar paper and plywood Interior walls: Gypsum board Best' protection factor area: . Portions of main complex- corridors away from entrance doors.
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- 2. Facility: Atwater Rest Location: Apex, NC Structure: Partial two-story, uninhabitable partial basement Exterior: Concrete blocks -
Windows: Aluminum frames inside with outside storm windows
. Roof: Front part has flat built-up roofing, rear section is sloped, covered with asphalt shingles over tar paper and plywood Interior walls: Concrete blocks General floor layout: T-shape, centrally divided by wide corridors with rooms on both sides.
Rear section is two-story structure.
Best protection factor areas: Corridors of both first and second floor.
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Attachment 3 Page 3 of 7
~ 3. - Facility: James Rest Home
" Location: ,
- New Hill, NC '
Structure: Single story, no basement Exterior:- -
Front is . brick veneer covering ~-
concrete blocks, rear is concrete blocks Roof: Sloped, asphalt shingles covering tar ~
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paper and plywood Interior walls: Concrete blocks General floor -layout: Long, rectangular, centrally divided by wide corridor with rooms on both sides -
Best protection factor area: Portions of corridor away from entrance doors.
C.3 . Family Care Facilities
- 1. Facility: Adams Family Care Location: Apex, NC Structure A: Single story, no basement, 5 years old Exterior: Brick veneer covering concrete block walls Roof: Sloped, asphalt shingles *
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Windows: Sliding with aluminum frames =
Interior walls: ' Gypsum board '
Structure B: Single . story, no . basement, 70-80 years old .
Exterior: Clapboard covering wood frame Roof: Sloped,' asphalt shingles Windows: Wood frame sash Best protection factor area: Structure A will offer- better protection than. StruWture B .' ,
Residents should be moved from -
Structure B to Structure A. Within Structure A, ' no . single area - offers significantly greater protection than remainder of house. However,
. moving away from windows and entrance doors will increase distance between direct rcdiation source and i in-leaking radioectivity.
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Attachment 3 s Page 4 of 7 f 2. = Facility: Morrison Family Care Location: ~ New Hill, NC Structure. A: Single. story, no basement, 20 years old '
Exterior: Brick veneer covering wood frame Roof: Sloped, asphalt shingles covering tar " '
paper and plywood Windows: Wood frame sash Interior walls: Gypsum board - . .
Strmtures B and C: Single. story, .no ' basement.
Approximately 20 years old Exterior: Shinglas covering wood frame Roof: .
Sloped, asphalt shingles Best - protection factor. area: Structure 'A will . offer better protection than structures B and C. .
Residents should be moved to Structure A. Within Structure A, no
- single area . offers _ significantly greater protection than remainder of house. - However, moving away from i' windows and entrance doors will increase distance between - direct radiation source and in-leaking radioactivity.
- 3. Facility: Friendship Family Care Location: Apex,' NC .
Structure: Single story, no basement, 24 years -
old
, - Exterior: Brick veneer covering wood frame
- Roof: Sloped, asphalt shingles epvering tar paper and plywood Windows: Wood frame sash : -
Interior walls: Gypsum board Best protection factor area: No area offers significantly better protection than other locations ' of house. However, moving away from windows and entrance doors will increase distance between direct radiation source -and in-leaking radioactivity.
- 4. Facility: Anderson Family Care Location: Apex, NC Structure: Single story, no basement,14 years old
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Attachment 3 -
Page 5 of 7
- Exterior: Brick veneer over wood frame..
Roof: Sloped, asphalt shingles over tar-Paper and plywood ...
. Windows: Wood frame sash with aluminum
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storm windows outside '
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Interior walls: Gypsum board .
Best protection factor area: Centrally locatedikitchen area and dining room enclosed by interior walls T '
only.
- 5. Facility: - Seagraves Family Care Location: Apex, NC Structure: . Single story, no basement Exterior: ' Brick veneer over wood frame Roof: Sloped, asphalt tiles Windows: Wood frame Interior walls: Gypsum board Best protection factor- area: No area offers significantly better protection than other locations of the house. However, sheltered residents should stay in the centrallocation of -
-the house which consists of the portions of the living room and family
, room farthest from the front windows and entrance doors.
, 6. Facility: Brown Family Care
< Location: New Hill, NC .
Structure: Single story, habitable- -partial basement,10 years old Exterior: Brick veneer covering wood frame Roof: Sloped, asphalt tiles Windows: Wood frame sash, outside storm t : windows -
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Interior walls: Gypsum board
' Best protection factor area: Habitable partial basement which is normally used as a recreation room.
!..u 7. Facility: Jack and Clarice Family Care p' n Location: Apex, NC Structure Single story, no basement I. Exterior: Masonite siding over wood frame
! ' Roof: Sloped, asphalt shingles
[ Windows: Wood frame sash with exterior aluminum storm windows Interior walls: Gypsum board l
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' Attachment 3 Page 6 of 7
- General floor layout: . Rectangular, center, . hallway beginning with living room at one end and kitchen / dining room at the
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other. -Bedrooms are on both sides of hallway. .. .
Best protection factor area: . Hallway. (It should be noted that this _
facility is ace the street. from Atwater Rest Home wid@ has good protecticn factor areas. Both facilities are owned by the same person. - Consideration should be given to shelter the family care residents in Atwater Rest Home.)
- 8. Facility: Lyles Family Care Location: Apex, NC Structure: Single story, no basement Exterior: Brick veneer over wood frame Roof: Sloped, asphalt shingles Windows: Wood frame sash, aluminum storm
- windows Interior walls: Gypsum board Best protection factor area: Large family - room enclosed by. ,
interior walls.-
- 9. Facility: Apex Family Care Center Location: Apex, NC Structure: Two-story wood frame, no basement,80-100 years old Exterior: Clapboard Roof: Shingles ,
Windows: Aluminum sash,. outside storm windows. '
Interior walls: Plaster Best protection factor area: First floor living room, away from windows j
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Attachment 3-Page 7 of 7 D. Senior Citizen Community
- 1. ~ Facility: Homes for the Elderly ' ~
Location: Fuquay-Varina, NC Structures: Six clusters of 12 two-bedroom and '~
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48 one-bedroom apartments, single '
story, no basement, 6 years old Exterior: Wood shingles covering wood frame, brick and' concrete firewall separating apartment units Roof: Sloped, asphalt shingles Windows: Sliding with aluminum frame Interior walls: Gypsum board Best protection factor area: Portion of apartments farthest from windows and entrance door, for example, kitchen area.
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UNITED STATES OF AMERICA NUCLEAR REGULATOR.Y COMMISSION *84 DEC 14 g) .38 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD.
dOCdf7I5G h yh*
BRANCH In the Matter of- )
) ..
CAROLINA POWER & LIGHT COMPANY )
AND NORTH CAROLINA EASTERN ) Docket No. 50-400 OL MUNICIPAL POWER AGENCY )
)
(Shearon Harris Nuclear Power Plant) )
CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Motion for Summary. Disposition of Eddleman Contention 57-C-13," " Applicants' Statement of Material Facts As To Which
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There Is No Genuine Issue To Be Heard on Eddleman Contention 57-C-13," and " Affidavit of Jesse T. Pugh, III In Support of Applicants' Motion for Summary Disposition of Eddleman Contention 57-C-13" were served this 12th day of December,1984 by deposit in the United States mail, first class, postage prepaid, to the parties on the attached Service List.
> OJu &. Udlw Dale E. Hollar Associate General Counsel Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolina 27632 (919) 836-8161 Dated: December 12,1984 l
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SERVICE LIST -
James L. Kelley,' Esquire 2 M. Travis Payne, Esquire ;
Atomic Safety and Licensing Board Edelstein and Payne U. S.' Nuclear Regulatory Commission Post Office Box 12643
. Washington, D. C. 20555
. Raleigh, North Carolina ' 27605
-Mr. Glenn O. Bright . Dr. Richard D. Wilson
, Atomic Safety and Licensing Board '
729 Hunter Street - f" -
U. S. Nuclear Regulatory Commission . Apex, North Carolina 27502 h Washington, D. C. 20555 ' .
Mr. Wells Eddleman Dr. James H. Carpenter. 718-A Iredell Street Atomic Safety and Licensing Board Durham,' North Carolina 27705
,, . U. S.- Nuclear. Regulatory Commission .
. Washington,' D. C. 20555 Tho' mas A. Baxter, Esquire
.. Delissa A. Ridgway, Esquire
, Charles A.' Barth, Esquire Shaw, Pittman, Potts & Trowbridge
- Myron Karman, Esquire 1800 M Street, NW Office of Executive Legal Director Washington, D.C. 20036 U. S. Nuclear Regulatory Commission l
Washington, D. C. 20555 Bradley W. Jones, Esquire U. S. Nuclear Regulatory. Commission
- .; : Docketing and Service Section Region II
- Office of the Secretary . 101 Marietta Street 3 U. S. Nuclear Regulatory Commission Atlanta, Georgia 30303 Washington, D. C. 20555 l Mr. Daniel F. Read, President Executive Director
-, Chapel Hill Anti-Nuclear Public Staff Group Effort North Carolina Utilities Commission
- Post Office Box 2151 Post Office Box 991
-Raleigh, North Carolina 27602 Raleigh, North. Carolina 27602 Dr. Linda Little Mr. Spence W. Perry.
Governor's Waste Management Board Federal Emergency Management Agency a s
513 Albemarle Building 500 C Street, S.W.
i~ ' 325 Salisbury Street . Room 640 Raleigh, North Carolina 27611 Washington, D. C. 20740 Mr. Steven Crockett, Esquire Steven Rochlis Atomic Safety and Licensing FederalEmergency Management Agency Board Panel .
1371 Peachtree Street, N.E.
U. S. Nuclear Regulatory Commission Atlanta, Georgia 30309
[ = Washington, D. C. 20555 I' John D. Runkle, Esquire Conservation Councilof North Carolina 307 Granville Road Chapel Hill, North Carolina 27514 4
' .