TXX-9827, Informs That Via ,Util Advised NRC That It Was in Compliance with Confirmatory Order & Rework Schedule Remains Effectual.Items Which Have Been Completed to Date to Bring Thermo-Lag Barriers in Compliance with Open Items,Listed
| ML20198K603 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/22/1998 |
| From: | Terry C, Walker R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-98276, NUDOCS 9812310104 | |
| Download: ML20198K603 (3) | |
Text
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L 2 Log #.TXX-98276
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File # 10010 -
p tilELECTRIC 909.5B
- . Ref. # 10CFR50.48 l
- c. Imee 7hery December 22,1998 !
- Senior Mce Presidens_,
& Principn!Nancieer OBicer '
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U. S. Nuclear Regulatory Commission '
' Attn: Document Control Desk t
- - Washington, D.C. 20555 l
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) i i+ DOCKET NO. 50-445 -
CONFlRMATORY ORDER MODIFYING LICENSE FOR TU ELECTRIC !
CPSES UNIT 1 i REF: 1) NRC Letter from Elinor G. Adensam to C. L. Terry :
- dated May 20,1998 1
. 2) TU Electric Letter logged TXX-98256 from !
Mr. C. L. Terry to the NRC dated November 25,1998
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- As part of the action plan for closure of the remaining open items associs , & Comanche 1 :
Peak Steam Electric Station (CPSES) Unit 1 Thermo-Lag fire barriers (items 1 e id 4) as 4
- described in the NRC Safety Evaluation Repo-!(SER) dated May 22,1996, arn. ine
' Confirmatory Order sent via Reference 1, TU Electric responded to Reference 1 and stated
- that," Texas Utilities (TU) Electric shall complete final implementation of Thermo-Lag 330-1 fire barrier corrective actions'at Comanche Peak, Unit 1 described in the TU Electric submittals to !
- the NRC dated April 9 and May 1,1998, by December 31,1998."
E The April 9,1998 letter stated that TU Electric will perform a fire endurance test to resolve the
- issues which remain open in NRC SER dated May 22,1996. The objective of the test is to
- qualify the specimen fire barrier configurations including the as built 12 inch cable trays,2 inch ]
conduits, and silicone foam firestops as well as the potential upgrade raceway configurations. j The May 1,1998, letter was in response to the NRC request in which Mr. T. J Polich of your staff informed TU Electric that the preliminary review by the NRR staff of the test criteria L
provided in the April 9,1998, letter indicated that the criteria are adequate, and the NRC staff believes that TU Electric has resolved previous comments. .in addition, Mr. Polich requested a ;
. copy of the' test plan for the hot oven insulation resistance'(IR) testing, and the time and place for both the fire endurance _ test and insulation resistance testing.' 1he May 1,1998, letter -
responded to this request and provided the draft copy of the test plan for the hot oven f . insulation resistance (IR) testing, and the time and place for both the fire endurance test dasjoy g 7 DOgCj
.- COMANCHE PEAK STEAM ELECTRIC STATION t O 1
[h ' P.O. Box 1002 _ Glen Rose, Texas 76043 1002 a
. . 1 T,XX-98276 Page 2'of 3 and any hot oven insulation resistance testing that subsequently would be required as a consequence of the fire endurance testing. Copies of both the April 9 and May 1,1998, letters from TU Electric are enclosed for your expedience in the review of the subject matter.
Via Reference 2, TU Electric informed the NRC that it had performed a fire endurance test on I October 27,1998, and provided preliminary results of the test. Additionally, via this letter ]
(Reference 2), TU Electric advised the NRC Staff that it was in compliance with the !
confirmatory order and that the rework schedule as stated in response to the aforementioned .
confirmatory order remains effectual. )
l Via this letter TU Electric is listing the items below which have been completed to date to bnng l the Thermo-lag barriers in compliance with the open items described in the NRC Safety l Evaluation Report (SER) dated May 22,1996, and the Confirmatory Order (Reference 1).
- Airdrops 1 % inch and 2 inch have been upgraded (SER open item) l e Silicone foam firestops (SER and confirmatory order open item, no additional rework is required based on favorable test results) e Conduits 1 % inch (SER open item, these conduits have been upgraded)
- 2 inch conduits have been upgraded based on favorable test results of the upgraded configuration (SER and confirmatory order open item) e 12 inch cable tray (SER and confirmatory order open item, no additional rework is required based on favorable test results)
TU Electric believes that the Thermo-Lag raceway barriers at CPSES Unit 1 are functional, this is based on the 7 day cure time previously accepted by the NRC in its SSER 27 section 9.5. Additionally, TU Electric asserts that all actions required of TU Electric by the confirmatory order are complete and the confirmatory order is in effect closed.
l T,XX-98276 )
Page 3'of 3 The only matter left open for this subject matter is the submittsi of the test reports, an action not covered by the confirmatory order, the schedule of which has verbally been communicated to Mr. T.J Polich of your staff. Should you have any questions or require additional information, please contact Obald Bhatty at (254) 897-5839. !
l This correspondence contains no new commitments regarding -;PSES Units 1 and 2.
Sincerely, 9.6. % g C. L. Terry By: %
Roger D. Walker Regulatory Affairs Manager OB:grj Enclosures cc: Mr. E. W. Merschoff, Region IV Mr. T. J. Polich, NRR Mr. J. l. Tapia, Region IV Resident inspectors, CPSES i
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- = Log # TXX 98098 l C C File # 10010 l l
909.5 yJn-"cr7R!C Ref. # 10 CFR 50.48 April 9, 1998 I c.t s.=.rwe,rr w.=
' &PrmcipalNacinarOficer U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 l
UNIT 1
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) i DOCKET NO. 50 445 THERMO LAG ENCLOSED RACEWAY, THERMAL MA",S OPEN ITEM AND MATRIX OF THERMO LAG UPGRADES f J
(TAC NO. M85536) l REF: 1) TU Electric letter, logged TXX 97252, from Mr. C. L. Terry )
to NRC dated December 10, 1997
- 3) NRC letter from Suzanne C. Black to William J. Cahill dated October 29, 1992, as clarified bf NUREG 0797 Supplement 26 of Fabruary 1993, NUREG 0797 Supplement 27 of April 1993, l
and HRC letter from T. J. Polich to C. L. Terry dated May 22, 1996
- 4) Generic Letter 86 010 Sup. 1 " Fire Endurance Test Acceptance Criteria for Fire Barrier Systems Used to Separate Redundant Safe Shutdown Trains Within the Same Fire Area (Supplement 1 To Generic Letter 86 10. ' Implementation of Fire Protection
. Requirements *)" dated March 25, 1994 j
- 5) NRC letter from Timothy J. Polich to C. Lance Terry dated April 1, 1998 Gentlemen:
This letter is a follow up to references 1) and 2). In reference 1).
TU Electric stated that it intended to test selected fire barrier configurations to resolve the two remaining Open Items pertaining TV to the Electric NRC's final acceptance of the fire barriers for CPSES Unit 1.
committed to perform this test using the criteria agreed upon in reference 3) [the October 29, 1992, Criteria). The NRC staff pointed out l in subsequent phone calls that reference 4) [GL 86-10, Sup.1] provides the j- most recent NRC guidance concerning the criteria to be used for fire barrier testing. In reference 2), Tl! Electric compared two sets of criteria (the October 29, 1992. Criteria and GL 86 10. Sup.1). The NRC I
l staff provided comments on reference 4) in reference 5) and requested that COstANCHE PEAK STE A%1 ELECTRIC STATION P.O. Box 1002 Glen Rose. Tem 60GIOD:
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l TXX-98098 !
Page 2 of 4 l TU Electric respond to these comments to resolve any issues prior to the start of any fire endurance tests.
On March 17, 1998. TU Electric discussed the protocols to be used in this l test with the NRC Staff. Based on these discussions TU Electric amends l the test proposal of reference 1) in the following manner:
a) For the test specimens which are demonstrating the capability of the !
Thermo Lag barriers on 12 inch cable trays and 2 inch conduits in lieu of placing thermocouples at six inch intervals on selected cables (per the October 29, 1992. Criteria), TU Electric will place a No. 8 AWG bare copper conductor inside the raceway on top of the cable (s) (and attached to one of the cable (s)), and will instrument the bare copper conductor with thermocouples at six inch intervals (per GL 86 10, Sup.1).
If a cable functionality evaluation is required. the evaluation will f b) be based on acceptable cable insulation resistance (IR) values and acceptable instrument loop accuracies.
The cable IR values will be obtained during a hot air test (e.g., !
using a programable hot air oven). The temperature profile for the hot air test will be based on a composite, worst case profile obtained during the fire endurance test, using the temperature data obtained from the thermocouples mounted on'the No 8 AWG bare copper wire. The hottest valid thermocouple reading dw mg each one minute .
interval of the fire test will be utilized to establish the composite profile.
A minimum of 2 feet of instrument cable will Because be exposed to the the raceways elevated temperatures in the hot air test.
being tested in the fire test have a low percentage fill, no cable compressive loads will be present and the hot air cable test data will not need to be adjusted for compressive loading.
The insulation resistance of the cable will be measured the lastaset minimum of three times (at approximately 20, 40 and 60 minutes of measurements to be completed as close to 60 minutes as reasonably achievable) . The insulation resistance values obtained during the hot air test will then be used to determine if the instrument accuracies are within acceptable limits.
c) As confirmed with the NRC staff during a conference call, burn through is defined as consumption of all the Thermo Lag material l
such that the inner layer of stress skin can be seen upon visual
! inspection.
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TXX 98098 Page 3 of 4 The test specimens for the fire test (Test Scheme 13 3) will be fabricated using TU Electric stock material similar to the as installed ,
configurations for a specific limited TU application Electric of 12utilize will inch cable a testtray plan, I and 2 inch cr-duit at CPSES Unit 1.
acceptance cr'. ceria, and test specimens as described in reference 1) except as modified above. The objective of the test is to qualify the specimen fire barrier configurations including the as built 12 inch cable trays 2 inch conduits, and silicone foam fire stops (Note asthe that wellfire asstop the potential upgrade raceway configurations.
testing is not based upon IEEE Std 634.)
The methodology and criteria described above. when considered in its entirety, constitutes a valid qualification test of these raceways for CPSES and responds to the comments in reference 5) as necessary to resolve the issues raised by the NRC. In particular, the comments concerning the j measurement of temperature inside the raceway and cable functionality have '
been resolved with the proposal to use thermocouples at six inch intervals on a bare copper wire inside the raceway and to use a hot air test to demonstrate cable functionality, if required.
In addition. TU Electric has attached to this letter a matrix of matrix The the upgrades for the Thermo Lag installations at CPSES Unit 1.
lists the upgrades and provides the time periods when these upgrades were completed. The upgrades which TU Electric determined to be necessary following the testing for Unit 1 in 1993 were completed in the 1993 95 time frame. The matrix also provides details of the remaining upgrades which will be performed to resolve the questions / concerns provided by the NRC staff in the Safety Evaluation Report of May 22, 1996.
Should you have any questions or need additional information, please I t
contact Obaid Bhatty at (254) 897 5839.
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TXX 98098 Page 4 of 4 This communication contains the following commitment:
Commitment A fire test will be performed to confirm the acceptability for CPSES Unit 1 of the as built Thermo-Lag barrier for 2 inch conduit with low thermal mass, the as built Therso Lag barrier for 12 inch cable tray with low thermal mass, the silicone foam fire-stops, and potential upgrade raceway configurations.
The fire test shall be performed using the methodology and criteria described in TXX 98098.
Sincerely.
0.$.
C. L. Terry By: 0004 .
RogerD. Walker Regulatory Affairs Manager 08:ob .
Attachment cc: E. W. Herschoff, Region IV J. I. Tapia, Region IV T. J. Polich. NRR Resident Inspectors, CPSES
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Attachment to TXX-98098 Page 1 of 4 STATUS OF UNIT 1 UPGRADES - CONDUITS AND JUNCTION BOXES UNIT 1 ACCEPTANCE ACCEPTED BY NRC VIA REMARKS UPGRADE STATUS TEST COMMODITY Sche.ne 9-1 NUREG 0797 UPGRADED IN THE SAME MANNER AS UNIT 2 3/4" COMPLETE (DM 92-077 09/92-12/92) (Unit 2 test) SUPPLEMENT 26 Scheme 9-1 NUREG 0797 UPGRADED IN THE SAME MANNER AS UNIT 2 1" COMPLETE (DM 92-077 (Unit 2 test)_ SUPPLEMENT 26 09/92-12/92)
Scheme 9-1 NUREG 0797 WILL BE UPGRADED IN THE SAME MANNER AS 1-1/2" UFGRADES PARTIALLY UNIT 2 WITH 1/4" PREFORMED OVERLAYS VIA COMPLETE *(DM 92-077 (Unit 2 test) SUPPLEMENT 26 DM-97-014' 08/93-05/94) Scheme 13-2 (Unit 1 test)
Scheme 13-2 NRC SAFETY 1) CONDUITS WITH LESS THAN 8.3 8 i FILLS 2' UPGRADES PARTIALLY WILL BE UPGRADED VIA DM-97-014 :
(UNIT 1 test EVALUATION OF COMPLETE'(DM 92-077 2) PROPOSED TEST SCHEME 13-3 WILL 08/93-0S/94) with cable MAY 22. 1996 functionality ADDRESS FILLS a 8.3 i BUT s 43.47t:
evaluation) 3) FILLS 2 43.471 HAVE BEEN PREVIOUSLY
> ACCEPTED BY THE NRC IN HAY 22, 1996 LETTER Scheme 9-1 NUREG 0797 UPGRADED IN THE SAME MANNER AS UNIT 2 3" & COMPLETE (DH 92-077 LARGER 08/93-0S/94) (Unit 2 test) SUPPLEMENT 26 Scheme 10-2 NUREG 0797 UPGRADED IN THE SAME MANNER AS UNIT 2 JUNCTION COMPLETE (DM 92-077 BOXES 08/93-05/94) (Unit 2 test) SUPPLEMENT 26
- All radial bends upgraded with stainless steel mesh based on Unit 1 Test Scheme 13-2
' DM-97-014 for conduit upgrades is presently scheduled to be completed 12/31/98.
_..._._m ______ _ . _ _ . . _ _ _ _ . _ _ _ . _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _____ _____ _ _ _ ___ _ ._ _ _ _
Attachment to TXX-98098 Page 2 of 4 STATUS OF UNIT 1 UPGRADES - CABLE TRAYS ACCEPTANCE ACCEPTED BY UNIT 1 REMARKS TEST NRC VIA.
COMMODITY UPGRADE STATUS Scheme 13-2 NRC SAFETY 1) CABLES TRAY TEE SECTIONS UPGRADED 12" UPGRADES PARTIALLY BASED ON UNIT 2 TEST SCHEME 14-1:
COMPLETE (DH 92-077 (Unit I test EVALUATION OF HAY 22, 1996 2) TRAYS WITH LESS THAN 5.6% FILL WILL 08/93-05/94) with cable functionality BE UPGRADED VIA DM-97-0148:
evaluation) 3) PROPOSED TEST SCHEME 13-3 WILL ADDRESS FILLS 2 5.6% BUT s 14.68%
- 4) FILLS 2 14.68% HAVE BEEN PREVIOUSLY ACCEPTED BY THE NRC IN MAY 22, 1996 LETTER SCHEME 11-5 NRC SAFETY N/A i 18" COMPLETE (DH 92-077 08/93-05/94) (Unit I test) EVALUATION OF MAY 22. 1996 SCHEME 11-5 NRC SAFETY N/A 24* COMPLETE (DH 92-077 08/93-05/94) (Unit 1 test) EVALUATION OF HAY 22, 1996 SCHEME 14-1 NUREG 0797 UPGRADED IN THE SAME MANNER AS UNIT 2 30" . COMPLETE (DH 92-077 08/93-05/94) (Unit 2 test) SUPPLEMENT 26 NOT APPLICABLE FOR UNIT 1. THE FSSA N/A SCHEHE 15-1 NUREG 0797 36" CABLES WERE RE-ROUTED IN SMALLER TRAYS (Unit 2 test) SUPPLEMENT 27 OR CONDillIS
' DH-97-014 for cable tray upgrades is presently scheduled to be completed by 12/31/98.
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p Attachsent to.TXX-98098 Page 3 of 4 STATUS OF UNIT 1 UPGRADES - CABLE TRAYS (CONTD.)
I UNIT 1 ACCEPTANCE ACCEPTED BY TEST NRC VIA. REMARKS COMMODITY UPGRADE STATUS SCHEME 14-1 NUREG 0797 UPGRADED IN THE SAME MA*:MER AS UNIT 2 TEE COMPLETE (DM 92-077 :
SECTIONS 08/93-05/94) (Unit 2 test) SUPPLEMENT 26 ,
ALL SIZES
' SCHEME 14-1 NUREG 0797 INSTALLED FIRE STOPS ON UNIT 1 ARE THE FIRE NONE REQUIRED 5AME AS THE FIRE STOPS ON UNIT 2 l STOPS. (Unit 2 test) SUPPLEMENT 26 j SILICONE SCHEME 11-2 ELASTOMER (Unit 1 test) j i
I SCHEME 14-1 NUREG 0797 SAME AS UM_iT 2 FOR SILICONE ELASTCi4ER FIRE NONE REQUIRED STOPS. (Unit 2 test) SUPPLEMENT 26 INSTALLED FIRE STOPS CONSTRUCTED WITH i
SILICONE SCHEME 11-2 (Unit I test) NRC SAFETY SILICONE F0AM WILL BE ADDRESSED VIA ,
FOAM EVALUATION OF PROPOSED TEST SCHEME 13-3 NEI TEST 2-8 i MAY 22. 1996 NEI TEST 2-8 NRC SAFETY THERMO-LAG FIRE STOPS INSTALLED AS FIRE COMPLETE (DM 92-077 TESTED VIA NEI TEST i 08/93-05/94) EVALUATION OF -
STOPS.
THERMO-MAY 22. 1996 !
LAG 330-1 f
SCHEME 15-2 NRC SAFETY THREE LAYERS OF FLEXI-BLANKET (330-CABLES COMPLETE (DM 92-077 )
-(Unit 1 test) EVALUATION OF 660) INSTALLED WRAPPED 08/93-05/94) MAY 22, 1996 ' !
IN SCHEME 11-1 (Unit 2 test) l EXPOSED t TRAY i
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Attachment to TXX-98098 t Page 4 of 4 :
STATUS OF UNIT 1 UPC4ADES - AIRDROPS AND FLEX CONDUII A
UNIT 1 ACCEPTANCE. ACCEPTED BY NRC VIA REMARKS UPGRADE STATUS TEST COMMODITY !
SCHEME 11-1 NUREG 0797 UPGRADED IN THE SAME MANNER AS UNIT 2 LESS THAN COMPLETE (DM 92-077 1-1/2" 08/93-05/94) (Unit 2 test) SUPPLEMENT 26 DIAMETER I SCHEME 11-1 NUREG 0797 1) ACCEPTABLE VIA NRC LETTER DATED 1-1/2" & TO BE UPGRADED SAME NOVEMBER 6, 1997 t 2" AS UNIT 2 (Unit 2 test) SUPPLEMENT 26
- 2) THREE LAYERS OF FLEXI-BLANKET (330- '
8 DIAMETER 660) WILL BE INSTALLED VIA DM-97-014 SCHEME 11-1 NUREG 0797 INSTALLATION THE SAME AS UNIT 2 GREATER NONE REQUIRED .
THAN 2" (Unit 2 test) SUPPLEMENT 26 I DIAMETER ,
12/31/98.
' DM-97-014 for airdrop upgrades is presently scheduled to be completed by i
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- Log # TXX-98122 C C File f 10010 ;
l 909 5 i TUELECTRIC Ref. # 10 CFR 50.48 I
riay 1,1998 c t w rry m m a id w a ramarp.m=*.r op=r l
U. S. Nuclear Regulatory Commission i Attn: Document Control Cesk l Washington, DC 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) - UNIT 1 ;
DOCKET NO. 50-445 l THERMO-LAG ENCLOSED RACEWAY (TAC NO. M85536)
REF: TU Electric letter, logged TXX-98098. from Mr. C. L. Terry to NRC dated April 9, 1998 Via the above referenced letter TU Electric submitted its plan and Moreover, via the aforementioned I criteria for an additional fire test. l letter, TU Electric itemized the remainder of the upgrades which are in process and will be completed by December 31. 1998.
Subsequently, Mr. T.J Polich of your staff informed TU Electric that the preliminary review by the NRR staff of the test criteria provided in the referenced letter indicated that the criteria are adequate, and the NRC In t.
staff believes that TU Electric has resolved their previous comments.
addition, Mr. Polich requested a copy of the test plan for the hot oven insulation resistance testing, and the time and place for both the fire endurance test and insulation resistance testing.
The " draft" test plan for the insulation resistance is attached for your review and comments. TV Electric has not finalized the exact dates of the upcoming fire endurance testing, however: TU Electric commits to performing the insulation test and the fire endurance test by December 31, 1998.
TU Electric will notify the staff via a letter and will provide ample time for the staff to witness the tests, if they so desire.
COMANCHE PEAK STEAM ELECTRIC STATION P,0. Box 1002 Glen Rose. Texas 7600 1002 WEO$Od O $~ _
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- TXX-98122 l Page 2 of 2 1
Should you have any questions or need additional information, please )
l contact Obaid Bhatty at (254) 897-5839.
L I i l t
Sincerely. l e.S. 6 vey C. L. Terry By: N
- Roger D. Walker Regulatory Affairs Manager OB:ob Enclosure cc: E. W. Merschoff Region IV J. I. Tapia. Region IV T.'J. Polich. NRR.
Resident Inspectors. CPSES r
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i Enclosure to TXX-98122 l 3
Page 1 of 2 Test Plan Rev 0 April 27, 1998 i
SCOPE
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! uti to This test plan describes the methods and guidelines to c at l
j determine the Insulation Resistance of an instrumenta elevated temperatures.
OBJECTIVE The objective of this test is to determin I ation R temperatu an instrumentat on cable when subjected t e that cables will
- results of this test will provide document strument accuracy have adequate insulation resistance to ens rformed to the will not be significantly degraded. This t l
requirements of this Test Plan.
I RESP 0 l
t tric j Texas Utilities Electric (TV l
i
- . Establish criteria a uide s to ern the installation of l' test items.
Prepare the t embly all required test equipment.
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. e in able tative of CPSES Unit 1 1
ati
[
. tes ent the results in accordance with this 1
l te A EQUIPMENT b.l i; Blue M ove 1366 with a Blue M Pro 550 or Pro-350 temperatu ontrol system.
Biddle lation Resistance tester, model BM25.
Ii sonal computer
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i EnclostJre to TXX-98122 Page 2 of 2 l
i TEST CONFIGURATION i
The test cable is a Rockbestos instrumentation cable (2/C,16 AWG, j
shielded twisted pair), which is the tyce of cable used a j Comanche Peak Steam Electric Station.
i n.
A minimum of two feet of cable will be ced 1 j
. betw the The insulation resistance will be mea insulated conductors and ground. The le sh iliz 4
j as the ground plane.
i Where cables enter or exit the oven "
le insulati e used to seal the oven penetration.
In order to prepare the cable sampi on , each end of the j _f the cable cable will have the jacket strippe 'oack.
inal will be will have th! test leads attached it . The-a attached to cie of the conduct # ( _the (-) al will be 1
' able will have i
attachedcothedrainwire.fntaFe===pnd its drain wire cut at the Ne of t s the cable jacket. The conductors be - aped to insulate j
them from each other.
l 1 be established during The temperature pr for oven' l neme 3. A bounding temperature ,
i the fire enduranc t fo emperature control system. l j profile will ramme )
4 the e hot test. the insulation resistance l
me nimum m hree times, at approximately 20, 40 j
' nut EST REPORT ass ble the final test report. containing the ollecte The test r hall be precared in sufficient detail to summarQe e total testing activity. The report shall include as a minimu e of the test.
cation of the test.
Description of the test equipment and test articles.
Calibration documentation for equipment.
Test Plan used.
Temperature profile utill:ed.
Insulation resistance values verse time.
All raw data.
__ _ _ . ___ _ _ _ . - _. _