ML20237A050

North Atlantic Energy Svc Corp Response to Proposed Contentions.* Petitioners Failed to Propose Admissible Contention.Request for Hearing & Petition to Intervene,As Applied to Both Petitioners Should Be Denied

ML20237A050
Person / Time
Site:	Seabrook
Issue date:	08/10/1998
From:	Repka D NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO), NORTHEAST UTILITIES SERVICE CO., WINSTON & STRAWN
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20237A053	List: ML20237A050 ML20237A063
References
CON-#398-19408 LA, NUDOCS 9808130048
Download: ML20237A050 (16)

Text

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. 00CKETED USHRC August 10,1998

% E 12 All 35 UNITED STATES OF AMERICA _.,. _

NUCLEARREGULATORYCOMMfSSgj ST w ADJUUOr o 2$$p BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

North Atlantic Energy Service Corporation ) Docket No. 50-443-LA

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(Scabrook Station) )

NORTH ATLANTIC ENERGY SERVICE CORPORATION'S RFRPONSE TO PROPOSED CONTENTIONS I. INTRODUCTION In accordance with the Licensing Board's " Memorandum and Order (Initial Order)"

ofJune 18,1998, North Atlantic Energy Service Corporation ("NAESCO") hereby responds to'the proposed contentions submitted on behalf of the Seacoast Anti-Pollution League ("SAPL") and the New England Coalition on Nuclear Pollution ("NECNP") (collectively, the " Petitioners").

NAESCO specifically responds to the Petitioners' filing of July 9,1998 (" Amended Petition"), and addresses the issue of admissibility of the contentions."

Petitioners propose four contentions for litigation on this docket, all directed at the NRC's "no significant hazards consideration determination," which is outside the scope of this proceeding. In addition, putting this defect aside, only one of the four contentions -- Proposed

. Contention 1 -- raises a matter even arguably related to the License Amendment Request at issue.

v NAESCO has previously addressed issues related to the Petitioners' standing to intervene in this matter and the timeliness of NECNP's request to become a party, by filings dated July 2,1998 ("NAESCO's Initial Answer") and July 27,1998 ("NAESCO's Standing Answer").

9808130048 980810 . ~~

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0 Proposed Contentions 2 through 4 address matters outside the scope of this proceeding and should not be admitted on that basis alone. With respect to Proposed Contention 1, NAESCO further concludes that the Petitioners have failed to meet the Commission's requirements of 10 C.F.R. @

2.714(b)(2), in that the proposed contention fails to identify a specific alleged problem with the proposed amendment and lacks a sufficient basis to demonstrate a genuine issue in dispute. In sum, because Petitioners have failed to identify an admissible contention, their request for hearing and petition to intervene should be denied.

II. BACKGROUND A. The Annroval at Issue As previously discussed in NAESCO's Initial Answer and NAESCO's Standing Answer, the Federal Register Notice giving rise to this proceeding relates to NAESCO's License Amendment Request of April 8,1998.2r As described in the Notice, the specific proposed change would:

. . . revise [Ser. brook Station) Technical Specifications (TSs) 4.4.5.3, Steam Generators -- Inspection Frequencies, and 3.4.6.2.c, Reactor Coolant System (RCS) Leakage, and the associated bases to accommodate fuel cycles of up to 24 months with respect to the allowed time interval between steam generator inservice inspections.

63 Fed. Reg. 25113, at col.1. This is a narrow approval focused on the frequency of steam generator inspections. It would also impose a more restrictive Limiting Condition for Operation for RCS l'

l NAESCO License Amendment Request 98-03 (T. C. Feigenbaum) to NRC (Document l Control Desk), Docket No. 50-443, NYN-98053, " Changes in Technical Specification Surveillance Intervals to Accommodate A 24-Month Fuel Cycle Per Generic Letter 91-04//

l Submittal No. 2," dated April 8,1998.

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4' l leakage through steam generators. Id. It does not address other changes to Technical Specifications related to 24-month operating cycles.# As is clear from a perusal of the License Amendment Request and the FederalRegister Notice, the application also does not address any issues related to fuel; it does not propose authorizing higher enrichment fuel or any changes related to fuel bumup. i l

With respect to fuel, this is also explained in an Affidavit of Ted C. Feigenbaum (" Affidavit"), at j 18, included as Attachment A.

As explained in the License Amendment Request (at page 2), the specific proposed changes in the Technical Specifications have been evaluated in accordance with generic guidance contained in NRC Generic Letter 91-04, " Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle." However, as explained in the attached Affidavit, NAESCO's present plans do not include operating Seabrook Station with a 24-month operating cycle (Affidavit, at $116-17). Instead, NAESCO's application will allow the current operating cycle (planned as an operating cycle ofjust over 20 months) to be completed with full utilization of the fuel despite two unexpected mid-cycle outages (Affidavit, at jj 3-7).

In the Federal Register Notice for this particular amendment application, for the reasons explained therein, the NRC Staff concluded that ". . . it appears that the three standards of

[10 C.F.R. Q 50.92(c)] are satisfied." The Staff proposed "to determine that the amendment request involves no significant hazards consideration." Id. at col. 3. Under 10 C.F.R. { 50.58(b)(5), if the Commission makes a final determination that an amendment involves no significant hazards i

As explained in the License Amendment Request, this particular application is only one "in a planned series of License Amendment Requests which propose changes to the Seabrook Station Technical Specifications to accommodate fuel cycles of up to 24 months."

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M consideration, it may issue an amendment and make it immediately effective notwithstanding a i

hearing request.

All four of the proposed contentions are specifically addressed to the NRC Staff's proposed "no significant hazards consideration" determination. The no significant hazards I consideration determination is relevant only to whether any hearing requested and determined to be required may be held after issuance and effectiveness of the amendment. It is not a matter properly before the Licensing Board. See 10 C.F.R. 50.58(b)(6).

B. NRC Requirements for Admission of Contentions To be admissible, proposed contentions must meet the detailed basis and specificity thresholds provided in the Commission's requirements of 10 C.F.R. jQ 2.714(b)(2) and (d)(2), as revised in 1989. The Commission, in Yankee Atomic Flectric Co. (Yankee Nuclear Power Station), CLI-96-7,43 NRC 235,248-49 (1996)(footnote omitted), held:

For a contention to be admissible, a petitioner must refer to a specific portion of the license application being challenged, state the issue of fact or law associated with that portion, and provide a " basis" of alleged facts or expert opinions, together with references to specific sources and documents that j establish those facts or expert opinions. 10 C.F.R. j 2.714(b)(2), (d)(2). The basis must show that a genuine dispute exists on a material issue of fact or law.10 C.F.R. Q2.714(b)(2). "A contention may be refused ifit does not meet the requirements of Section 2.714(b) or if the contention, even if proven, would I

'be of no consequence in the proceeding because it would not entitle the petitioner to relief.' 10 C.F.R. Q 2.714(d)(2)(ii)." Sacramento Municipal Utility District (Rancho Seco Nuclear Generating Station),

CLI 93-3,37 NRC 135,142 (1993).

54 Fed. Reg. 33,168 (1989).

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In the Supplementary Information accompanying Section 2.714, the Commission i

emphasized that the rule " require [s] the proponent of the contention to supply infonnation showing the existence of a genuine dispute with the applicant on an issue oflaw or fact." 54 Fed. Reg. at 33,168. The Commission further emphasized that contentions cannot be admitted when l

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unaccompanied by supporting facts. Id. at 33,171. In Ari7ona Pub. Serv. Co. (Palo Verde Nuclear l Generating Station, Unit Nos.1,2 and 3), CLI-91-12,34 NRC 149 (1991), the Commission stated its intent that {2.714(b)(2)(i)-(iii) be interpreted strictly: "If any one of these requirements is not f

met, a contention must be rejected." 34 NRC at 154 (citing the Supplementary Information,54 Fed. l' Reg. at 33,171). The Commission further stated:

(

These requirements are designed to raise the '

Conunission's threshold for admissible contentions and to require a clear statement as to the basis for the contentions and the submission of more supporting information and references to specific documents and sources which establish the validity of the contention.

See 54 Fed. Reg. 33168,33170 (Aurat 11,1989).

34 NRC at 154 (emphasis added). The mies on admission of contentions therefore require precision in the contention pleading process to ensure that a proposed contention is specific and has factual support." The Petitioners in Propoced Contention I have not satisfied the Commission's strict requirement that the supporting basis for proposed contentions be adequate to show a genuine issue. .

Moreover, under longstanding Commission precedent, proposed contentions must also fall within the scope of the issues set forth in the notice of hearing. See Vem:ont Yankee Nuclear Power Com. (Vermont Yankee Nuclear Power Station), LBP-90-6,31 NRC 85,91 (1990);

F j In IInion of Concerned Scientists v. IInited States Nuclear Regulatorv Comm'n,920 F.2d 50 (D.C. Cir.1990), the Court upheld the NRC's revisions to {2.714, compared 2.714(b),

as amended, to the prior version, and confinned that "[t]he new rule perceptibly heightens th[e] pleading standard" for contentions. Id. at 52.

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Public Serv. Co. ofIndiann inc. (Marble Hill Nuclear Generating Station, Units 1 and 2), ALAB-316,3 NRC 167,170 (1976). See also Wisconsin Elec. Power Co. (Point Beach Nuclear Plant, Units I and 2), ALAB-739,18 NRC 335,339 (1983)." In this case, the Petitioners offer three proposed contentions (Proposed Contentions 2 through 4) that fail to address material matters that could warrant reliefin this proceeding.

III. DISCUSSION.

A. Prooosed Contention 1 Proposed Contention 1 states:

CONTENTION 1 The staff erred in its May 6 finding of no significant hazards consideration in regard to the request of NAESCO to change the Technical Specifications for '

Seabrook Station to accommodate fuel cycles of up to 24 months with respect to the allowed time between steam generator inservice inspections. Contrary to the staff's conclusion, the proposed changes may cause a significant increase in the probability or consequences of an accident previously evaluated, and may involve a significant reduction in the margin of safety, contrary to the requirements of 10 CFR 50.92.

For a proposed contention to be admissible, a petitioner must refer to a specific portion of the application being challenged and state the issue of fact or law associated with that portion of the application. 10 C.F.R. Q 2.714(b)(2). The Petitioners' statement of Proposed Contention 1 is expressly directed at the NRC Staff's proposed no significant hazards consideration determination, and therefore raises a matter beyond the scope of this proceeding. 10 C.F.R.

~{ 50.58(b)(6). This is underscored by the fact that the proposed contention does not refer to any Sec 54 Fed. Reg. at 33,169-171 (revised rules on admissibility of contentions did not alter pre-existing case law).

4 specific portion of the amendment application, but rather only to the NRC Staft's no significant hazards consideration analysis. The proposed contention, therefore, should not be admitted.

The " basis" statement for the proposed contention does not remedy the admissibility problem.2/ It is clear from this statement that Petitioners are unhappy with the alleged " safety

! consequence of reducing the required surveillance for the steam generators by twenty-five percent."

i However, this is neither a specific contention nor a basis; it is no more than a general statement of opposition to the License Amendment Request. The License Amendment Request demonstrates l why the proposed amendment is technically acceptable. Petitioners fail to state specifically where the analysis is flawed.

Reading further into the " basis" statement (at page 3), one comes upon a twofold argument that can be summarized as follows:

a 1991 inservice inspection data suggests that some steam generator tubes might have y crossed the line into the defective classification had the plant operated for 25% I l longer; and F

the current amendment would reduce margin because it has "apparently redefined"-

the criterion for a " defective tube" from 40% wall loss to 75% wall loss.

However, this is not a " basis" for a contention; it is a blatant distortion of the License Amendment Request as well as the other documents cited by the Petitioners.

- Addressing the second point first, there simply is nothing in the proposed amendment that would redefine the present criteria for steam generator tube repairs. This is revealed by even a cursory read through the License Amendment Request and the proposed Technical Specification 2r The statement of the contention should control the admissibility question. There should be no need for the applicant or the Licensing Board to search through the " basis" discussion to l

. glean the "true"(or potentially admissible) direction o ther contention. See also Statement l l of Policy on Conduct of Adjudientney Proceedings, CLI-98-12, NRC , dated July 28, )

1998, slip op. at p. 7 ("A contention's proponent, not the licensing board, is responsible for l formulating the contention and providing the necessary information to satisfy the basis requirement for the admission of contentions in 10 C.F.R. 2.714(b)(2)").

Q changes attached thereto. This does not require the Licensing Board to make a determination "on the merits." It requires only a " thoughtful" review of the claimed basis for the contention, comnare k

l Vermont Yankee Nuclear Power Corn. (Vernant Yankee Nuclear Power Station), ALAB-919,30 l NRC 29,48-49 (1989), and a recognition that there is simply no basis for a contention to be built 4 around the issue.

I With respect to steam generator surveillance and repairs, Seabrook Station has I

imple.nented criteria consistent with NRC Regulatery Guide 1.121 (see, e.g. License Amendment f

Request, at page 3). Seabrook applies an allowable 75% through-wall structural limit (i.d., at 5).

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a This limit is not the criterion for tube plugging. The plugging, or repair, criterion at a surveillance I i is the 40% criterion referenced by the Petitioners. This criterion is more accurately discussed in the )

Seabrook Station Technical Specification Bases Section 3/4.4.5.8' For steam generator tubes determined at a surveillance to have experienced 40% or greater loss, plugging is performed. For i

tubes determined to have experienced wall loss less than 40%, NAESCO must either conservatively plug the tube or demonstrate by analysis, based upon test data and history, that during the next anticipated operating cycle the degradation will not exceed the 75% through-wall structural limit.

The License Amendment Request does not change this approach.

'With respect to the first point summarized above, the Petitioners are assembling an unsupported attack on the proposed surveillance schedule by mis-applying and distorting the relevant inspection and acceptance criteria. Regardless of the length of the next planned cycle, tubes 1

exhibiting less than 40% wall loss at a surveillance (and that are not plugged) will have been

' demonstrated to be sufficient to meet the 75% through-wall structural limitfor the duration ofthe l:

5' Technical Specifications Bases, Section 3/4.4.5, is not attached to the License Amendment ,

Request. A copy is provided as Attachment B. l next operating cycle. There will be no " reduction in a margin of safety," precisely because the 40%

plugging criterion and the 75% stmetural limit are unchanged. Nothing offered by Petitioners supports a conclusion othenvise, including the 1991 and 1997 data cited. The argument, based on the data cited, that "some steam generator tubes might have crossed the line into the defective classification had the plant operated for 25% longer,"is not support for a contention. It is obviously wrong. The contention therefere fails for the lack of genuine basis and the lack of a genuine issue.

In sum, the contention is inadmissible as a challenge to the Staff's proposed "no significant hazards co'videration determination." In addition, even if the Licensing Board were willing to re-write the contention to focus it on the License Amendment Request, the Licensing Board must still find that the materials submitted by the Petitioners fail to challenge a specific aspect of the application and EC1 to show that a genuine dispute exists on a material issue of fact or law.

10 C.F.R. Q 2.714(b)(2). The contention lacks support and should not be admitted. Comnare Georgia In:*itute of Technology (Georgia Tech Research Reactor), LBF-95-6,41 NRC 281,304-5 (1995).

B. Pronosed Contentions 2 through 4 Proposed /'untentions 2,3, and 4 state as follows:

CONTENTION 2 )

l The staff erred in its May 6 finding of no significant j hazards consideration in regard to the request to '

change the Technical Specifications for Seabrook Station to accommodate a 24 month fuel cycle because the staff failed to analyze the impact of a 25%

longer operational run on fuel rod failure, and because the result of a longer run will be to increase fuel rod failure, thereby breaching the first line of defense against offsite radioactive releases. Therefore, the finding is contrary to the requirements of 10 C.F.R..

50.92 in that the analyzed consequences of an l

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increased risk of fuel failure would involve a significant increase in the probability or consequences of a previously analyzed accident and involves a significant reduction in the margin of safety.

CONTENTION 3 The staff erred in its May 6 finding of no significant hazards consideration in regard to the request of NAESCO request to change the Technical Specification for Seabrook Station to accommodate a 24 month fuel cycle because the staff failed to analyze the effect ofincreasing the operational run by 25%

- with a resulting requirement for an increased reliance on on-line maintenance, which may cause an increase in the probability or consequences of an accident previously analyzed, or may cause an accident not previously analyzed, and which - may cause a significant reduction in the margin of sa ety, contrary to the requirements of 10 C.F.R. 50.92.

CONTENTION 4 The staff erred in its May 6 finding of no significant hazards consideration in regard to the request of NAESCO to change the Technical Specifications for Seabrook Statica to accommodate f,el cycles up to 24 months because the decreased opportunity to conduct surveillance within the areas of the plant inaccessible during normal operations may create an increased hazard as the result of the failure to timely detect abnormal or improper conditions (such as mi aligned or mispositioned valves), which may result in an increased probability of a previously analyzed accident and which may result in a significant reduction in the margin of safety, contrary to the requirements of 10 C.F.R. 50.92.

These three proposed contentions are all inadmissable for several reasons. First, as with Proposed Contention 1, all three of these proposed contentions are expressly directed at the NRC Staffs proposed no significant hazards consideration determination. Therefore, all three t

contentions address matters beyond the scope of this proceeding.10 C.F.R. % 50.58(b)(6). If there is any doubt as to the focus of the contentions, that doubt is unambiguously resolved by the Petitioners in their filing of July 31,1998.* There (at page 4), the Petitioners proclaim that "[t]he very issue the petitioners are proffering in this proceeding is whether the Staff's proposed (no significant hazards consideration] determination is corr ct."*

Second, even if the proposed contentions were re-drafted to focus on the merits of the amendment application (and they should not be, as discussed above), they would still be inadmissible. Contrary to the Petitioners' claim, these proposed contentions do not raise matters material to this proceeding. NAESCO's License Amendment Request relates to steam generator surveillance schedules; it does not propose any changes with respect to fuel, on-line maintenance practices, or other surveillance. Petitioners may not bootstrap these issues into this proceeding, which is jurisdictionally limited to the amendment application at hand.

Petitioners offer an argument analogizing this situation to case law related to the National Environmental Policy Act ("NEPA") on " segmentation." Petitioners maintain that, because this present License Amendment Requesi is one of a planned series of amendments related to 24-month operating cycles it would be improper to review the present application in isolation. This theory, however, is completely off target because the " segmentation" concept and the case law cited

" Reply to Staff and NAESCO objections to Joinder of NECNP and to NAESCO Objection to Standing," Docket No. 50-443, dated July 30,1998.

• The no significant hazards consideration determination is distinct from a decision on the merits of a proposed amendment. Even a finding in agreement with the Petitioners that the proposed no significant hazards consideration determination is not correct (for example, that there would be a " reduction in a margin of safety" as a result of the proposed amendment),

would not necessarily entitle the Petitioners to any reliefin this proceeding. This wou!d not equate to a finding that the proposed amendment is unacceptable.

are inapposite. First, this is not a NEPA case and the precedent does not apply. And second, in any event, the analogy does not hold. In the prese it circumstances, by virtue of the serial submittals, Petitioners do not lose any hearing opportunity that would otherwise exist.

Every license amendment that NAESCO requests will be noticed for opportunity for hearing, including all of NAESCO's planned submittals related to 24-month operating cycles. To the extent that NAESCO is requesting a change that is subject to the license amendment process, Petitioners either had or will have an opportunity to file comments and request a hearing. Petitioners do not lose any hearing rights by virtue of NAESCO's decision to file its applications in series.

Petitioners simply need to timely request a hearing and raise admissible, material issues. There is no reason given why the Petitioners' various and unrelated issues need to be raised in this par'icular proceedig.

Furthermore, the fact that this is one amendment in a series should not create hearing rights where none exist. If no license amendment is necessary to accommodate a 24-month operating cycle (or indeed any other action), and no such change is being sought by NAESCO, Petitioners have no hearing rights. " Segmentation" theories do not support expanding the scope of this proceeding into matters where there are no changes planned or where no license amendment is required.* To the extent Petitioners have comments to make on matters outside the scope of the hearing opportunity, other NRC avenues exist to voice their concerns.

In Proposed Contention 2, Petitioners raise a concem regarding the potential impact of a 25% longer operational run on fuel rod failures. Obviously, this is not a steam generator  !

I surveillance issue. In addithn, and as mentioned above, NAESCO is not proposing any change

• For example, certain changes can be made pursuant to 10 C.F.R. { 50.59 and/or { 50.71(e) without prior NRC approval and without an opponunity for hearing.

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related to fuel in any of the license amendment applications intended to accommodate 24-month cycles. See Affidavit, at j 18. Fuelissues are addressed for each cycle in a Core Operating Limits Report required by the Seabrook Station Technical Specifications." This is a matter of public record, but outside the license amendment process. NEPA precedents cannot support inserting these matters into this proceeding.

Proposed Contention 3 argues that 24-month operating cycles will " increase reliance on on-line maintenance." Obviously, this also is not a steam generator surveillance issue within the scope of this proceeding. In addition, NAESCO's License Amendment Request does not propose changes in this area for steam generators. Likewise, for other equipment, the NRC's maintenance rule (10 C.F.R. Q 50.65), Seabrook Station Technical Specifications, and NRC and industry guidance documents addressing en-line maintenance will continue to apply -- regardless of the length of the operating cycle." At bottom, this is an issue more appropriate for a petition for rulemaking. NEPA analogies cannot change the NRC's well-defined procedural regime.

• For example, Technical Specification 6.8.1.6.c states:

The core operating limits shall be determined so that all applicable limits (e.g., fuel thermal-mechanical limits, core thermal-hydraulic limits, ECCS limits, nuclear limits such as Shutdown Margin, and transient and accident analysis limits) of the safety analysis are met.

The Core Operating Limits Report for each reload cycle, including any mid-cycle revisions or supplements thereto, shall be provided upon issuance, to the NRC Document Control Desk with copies to the Regiona! Admmistrator and the Resident Inspector.

• For example, see 10 C.F.R. Q50.65(a)(3). The regulation provides that "[i]n performing monitoring and preventative maintenance activities, an assessment of the total plant equipment that is out of service should be taken into account to determine the overall effect on performan:e of safety functions." This generic requirement pertains to on-line maintenance. The requirement is also the subject of an ongoing NRC rulemaking initiative,

[ which would be a more appropriate forum for Petitioners to voice their on-line maintenance l issue.

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c Proposed Contention 4 raises a concern regarding "the decreased opportunity to conduct surveillance within the areas of the plant inaccessible during normal operations." However, to the extent that NAESCO either has or wi. propose a change to a Technical Specification surveillance interval, that change will be '1oticed for comment and opportunity for heari.1g. The l Petitioners' " basis" statement for this proposed contention explicitly recognizes (at page 16) that a proposed extension of the surveillance requirement for the emergency diesel generator was previously noticed, and that the Petitioners have commented on that proposal." Petitioners have demonstrated neither a practical need nor a legal basis to raise this issue and other surveillance issues in this proceeding.

Finally, all of these proposed contentions, and the supporting " segmentation" l

argument, are based on Petitioners' focus on 24-month operating cycles and reflect Petitioners' desire to force fit allissues potentially related to 24-month cycles into this proceeding. However, a as explained in the attached Aflidavit, NAESCO is not presently contemplating 24-month operating cycles. Src Affidavit, at $1 16-17. NAE 9N is seeicing to extend surveillance schedules to 3 l

accommodate 24-month operating cycles, only because this relief will allow NAESCO to efficiently l

utilize fuel during the present 20-month operating cycle. Affidavit, at 113-7. The Petitioners' generic concerns regarding longer operating cycles and longer surveillance intervals lack a fundamental factual basis and do not need to be ventilated in this proceeding.

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In sum, Proposed Contentions 2 through 4 improperly attack the NRC staff's "no 4 significant hazards consideration" determination, raise matters otherwise outside the scope of the l

{ Petitioners did not request a hearing on that application. Petitioners comments presumably l will be addressed by the NRC Staff as part of the review of that application.

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present proceeding, and lack sufficient factual basis. As such, all three proposed contentions are inadmissible.

IV. CONCLUSION For reasons set forth above, the Petitioners have failed to propose an admissible contention. The Petitioners' request for hearing and petition to intervene, as applied to both Petitioners, should be denied.

Respectfully submitted, k n David A. Repka I WINSTON & STRAWN 1400 L Street, N.W.

Washington, D.C. 20005-3502 (202)371-5726 Lillian M. Cuoco NORTHEAST UTILITIES SERVICE COMPANY 107 Selden Street Berlin, Connecticut 06037 ATTORNEYS FOR NORTH ATLANTIC ENERGY SERVICE CORPORATION Dated in Washington, D.C.

this 10th day of August,1998 i

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