View source for JPN-92-043, Forwards Revised App R Exemption Request,Per 920723 Telcon W/Nrc Re Torus Room,As Suppl to .Exemption Would Permit Use of General Outdoor Lights,Outdoor Security Lights & Vehicle Headlights &/Or Flashlights for Exterior Access

{{Adams
| number = ML20141M274
| issue date = 07/31/1992
| title = Forwards Revised App R Exemption Request,Per 920723 Telcon W/Nrc Re Torus Room,As Suppl to .Exemption Would Permit Use of General Outdoor Lights,Outdoor Security Lights & Vehicle Headlights &/Or Flashlights for Exterior Access
| author name = Beedle R
| author affiliation = POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000333
| license number = 
| contact person = 
| document report number = JPN-92-043, JPN-92-43, NUDOCS 9208110015
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 11
| project = 
| stage = Other
}}

=Text=
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l I                123 M6n street -
Wh% ?!ains. New York 10601
      ''         914 681 6846
         #> NewYorkPower                                                                            a.i,s c. ... .
         & Authority                                                                                ~ " ' ~ ~ " ~
Nadear Geneabon July 31,1992 JPN 92-043 U.S. Nuclear Regulatory Commission Attn.: Document Control Desk Mail Station P1137 Washington,DC 20555

==SUBJECT:==
James A. FitzPatrick Nuclear Pow 9r Plant Docket No. 50-333 Revision To Exemption From 10 CFR 50, Apr,;.adix R

==REFERENCE:==
: 1. NYPA letter JPN-92-032, R. E. Boedle to NRC Document Control Desk, .
dated June 26,1992, regarding revised, new or temporary exemptions from 10 C.'H 60, Appencilx R.

==Dear Sir:==

The Authority submitted Appendix R exemption requests to the NRC in Reference 1. On July .
23,1992 a teleconference was held with the NRC to discuss the Tcus Room Exemption Request.
L        As a result of this discussion, the Authority is providing the attached revised pages to the Tcrus -
I        Room Exemption Request. Revision bars indicate the changes to the excmption request. The revised pages supersede the originally submitted pages with the same page numbers in their entirety.
Authority personnel are available to meet with your staff to further discuss this exemption or any of the other exemptions. If you have any questions, please contact Mr. J. A. Gray, Jr.
Very truly yours, -
                                                                         -}-
                                                          <V           k GL Ralph E. Beedle -
                                                                                            '~N Executive Vice President Nuclear Generation ec:           Next Page 92081f0015 920731                                                                                      .
PDR- ADOCK 05000333                                                                                               I P                         PDR                                                                         !'      -[/
s               (-

I cc:  Regional Administrator U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Office of the Resident inspector U. S. Nuclear Regulatory Commission P. O. Box 136 Lycoming, NY 13093 Mr. Brian C. McCabe Project Directorate 11 Division of Reactor Projects - 1/Il U. S. Nuclear Regulatory Commission Mail Stop 14 B2 Washington,DC 20555 l
i

INSTRUCTION SHEET ATTACHMENT 1 TO JPN-92W; INCORPORATE REVISION 1 AS FOLLOWS:
Remove Pages            Insert Pages Page 5 of 49            Page 5 of 49 Page 12 of 49           Page 12 of 49 Page 13 of 49           Page 13 of 49 Page 14 of 49           Page 14 of 49 Page 15 of 49           Page 15 of 49 -
Page 16 of 49           Page 16 of 49 Page 17 of 49           Pago 17 of 49 Page 18 of 49           Page 18 of 49 2
                                                                     -i

ATTACHMENT 1 TO JPN-92-032 2.0      

==SUMMARY==
OF EXEMPTION REQUESTS 2.1      Revised
: 1. Revise an existing exemption from the requirements of 10 CFR 50, Appendix R, Sections Ill.L1.b and Ill.L2.b so that the reactor coolant level be permitted to drop below the top of the core for BWRs during use of alternative safe shutdown procedures which includes the possibility of Control Room evacuation following a fire in any of five fire zones: (1) Control Room; (2) Relay Room; (3) Cable Spreadiro Room; (4) North Cable Tunnel; (5) Battery Room Corridor.
: 2. Revise an existing exemption from the requirements of 10 CFR 50, Appendix R, Sections Ill.G.2, Ill.G.3 and Ill L with respect to the separation of redundant safe shutdown circuits in that they are not in accordance with Section Ill.G.2 and alterrate shutdown capability has not been provided in accordance with Sections lli.G.3 and Ill.L in the Torus Room (Fire Area XV).                          l 2.2      New
: 1. Grant a new exemption from the rc<;uirements of 10 CFR 50, Appendix R, Section Ill.J that mandates permanently installed 8-hour Appendix R 0ll hting in outdoor areas. The requosted exemption is to use general outdoor lights, outdoor security lights, vehicle headlights and/or flashlights for exterior access and egress routes not only for the Fire Areas listed in the exemption request, but for any Fire Area where exterior access and egress routes may be used.
2.3      Temporary
: 1. Grant a temporary exemption from the requirements of 10 CFR 50, Appendix R, Section Ill.G.1 with respect to the ventilation systems In the Emergency Service Water (ESW) and Residual Heat Removal Service Water (RHRSW) Pump Rooms (Fire Areas XII and XI!!) being free of fire damage.- The exemption is needed until the modifications can be completed to assure that one division of RHRSW and l             ESW and either the electric or diesel driven fire pump and the associated ventilation systems will be available in tne event of a fire in Fire Areas IB or ll.
Interim compensatory actions will be implemented until the modifications are completed. See NYPA LER 91-021-00, dated November 27,1991.
l l                                                                                                      l l
Rev.1                                    Page 5 of 49

ATTACHMENT 1 TO JPN-92-032 e
3.2               Torus Room Exemption Requested In accordance with the provisions of 10 CFR 50.12(a), the New York Power Authority requests a revised exemption from the requirements of 10 CFR 50, Appendix R, Sections ill.G.2, Ill.G.3 and Ill.L with respect to the separation of redundant safe shutdown circuits in that they are not in accordance with Section Ill.G.2 and afternate shutdown capability has not bcon provided in accordance with Sections Ill.G.3 and Ill.L in the Torus Room (Fire Area XV).                                               l This exemption would revise the current exemption to more accurately reflect the equipment in the Torus     '
Room. It would also provide a revised technical basis for the exemption to reflect the new description of the area.
The Authority has reviewed the existing NRC exemptions for the adjacent four Fire Areas (IX, X, XVil and XVill), These exemptions state that the boundarles separating the Torus Room from these four Fire Areas i         are 3-hour-rated fire barriers. Although these barriers are not 3-hour rated fire barriers because of the unsealed penetrations, they are adequate to assure that redundant safe shutdown functions are not lost.
Therefore, the technical basis for these exemptions remain valid.
Fire Areas / Fire Zones Affected FIRE AREA                  FIRE ZONE             AREA DESCRIPTION 4
XV                        SU-1              Torus Room                                                l Technical Justification lackoround In Reference 3.2-1, the NRC granted an exemption from the requirements of 10 CFR 50, Appendix R, Sections Ill G.2, Ill.G.3 and Ill.L which stated that neither separation, suppression, detection and/or protection of redundant shutdown divisions nor the installation of an alternate shutdown capability is required for the Torus Room. Page 4 of the NRC's Safety Evaluation includes a description of the Torus Room:
* the area contains only the suppression pool and is a controlled access area bounded on all sides by three-hour rated masonry construction; there are no combustible materials and no significant fire hazards in the area; and that shutdown related components in the area consist only of the RHR pump suction valves of both divisions. These valves are in an open position and ait power cables to them have been disabled under a previously -
approved plant modification."
This paragraph does not accurately describe the Torus Room. However, the technical basis for the exemption remains valid.
Rev.1                                        Page 12 of 49

ATTACHMENT 1 TO JPN-92-032 Physical Arrangement The Torus Room (Fire Area XV) is located in the Reactor Building with its floor being at el. 227'. This room   )
is a contro!!cd access area and is tmnded on all sides by masonry construction.                                j l
The floor and more than half of the walls of the Torus Room are below grade proximately el. 27l'),
'                                                                                                                     1 adjacent to the exterior and thus noi an issue since fire propagation from the merlor is not a concom.
The walls that separate the Torus Room from the crescent areas (Fire Areas XVil and XVill) are three-foot thick reinforced concrete. The untoaled penetrations in these walls are shown in Figures 3.2-1 and 3.2 2.
The ceiling that separates the Torus Room from Reactor Building el. 272' (Fire Areas IX and X) is two foot thick reinforced concreto. The unsealed penetrations in this ceiling are shown in Figure 3.2 3.
The Torus Room contains the torus, valves, pipes, non-combustible insulation, instrument tubes and cables installed in conduits. This area is essentially devold of exposed combustibles.
Although Fire Areas IX, X, XVil and XVill are discussed in this exemption request, the Authority is not extending the exemption request to them because the presence of these unsealed penetrations does not -
render the barriers inadequate for the fire hazards in these areas, in Generic Letter 86-10 (Reference 3.2-2) the NRC states:
                "The term ' fire area' as used in Appendix R means an area sufficiently bounded to withstand the hazards associated with the fire area and, as necessary, to protod important equipment within the fire area from a fire outside the area. In order to meet this regulation, fire area boundaries need not ce completely sealed with floor-to-ceilin0 and/or wall to-wall boundaries. . . . Where fire area boundarios with all penetrations scaled to the fire rating required of the boundaries, licensees must perform an evaluation to assess the adequacy of fire area boundaries in their plants to determine if the boundaries will withstand the hazards associated with the area . . . . (Enclosure 1, Section 4, Page 2; and Enclosure 2,
!               Response to Question 3.1.2, Pages 4 and 5)
!      Therefore, since there are no significant fire hazards in the Torus Room, the wall between the Crescent Area (Fire Areas XVil and XVill) and the Torus Room (Fire Area XV) is an adequate fire area boundary for the Crescent Area because these unsealed penetrations do not pose a threat of fire propagation into the Crescent Area. Applying the same rationale, the floor / ceiling boundary between the Reactor Building el. 272' (Fire Areas IX and X) and the Torus Room (Fire Area XV) is an adequate fire area boundary for the Reactor Building el. 272' because these unsealed penetrations do not pose a threat of fire propagation into the Reactor Building cl. 272'.
i      However, the reverse is not true for the Torus Room. Since there are fire hazards associated with Fire       i l      Areas IX, X, XVI! and XVill, the associated wall and ceiling of the Torus Room are not suitable as fire area boundaries for the Torus Room with respect to the guidance given in Generic Letter 8S-10 because these unsealed penetrations may pose a threat of fire propagation into the Torus Room.
For the fire hazards in Fire Areas IX, X, XVil and XVill, this exemption request demonstrates why the l      subject wall and ceiling are adequate fire area boundaries for the Torus Room.
Rev.1                                        Page 13 of 49                                                   l

A1TACHMENT 1 TO JPN-92-032 Fire Protection Features The Torus Room has neither an automatic fire detection system nor an automatic fire suppression system.
Due to the area configuration and the combustible loading, this area vtas exempted (Reference 3.2-1) from the requirements necessitating these systems. Manual sprays are available from hose stations located in Fire Area IX.
Adjacent to the Torus Room are the East and West Crescent Areas (Fire Areas XVil and XVill respectively). They are provided with automatic smoke detection systems. Water curtains are provided to sepa ate the East and West Crescent Areas and to separate the East Crescent Area from Firo Area IX.
Manual sprays are available from hose stations located in Fire Areas IX, X, XVil and XVill.
The RCIC enclosure, which is in the West Crescent Area, !s constructed of three-hour fire-rated walls and ceiling. Curbs are also provided to prevent the spread of oil. Finally the RCIC Turbine is protected with an automatic water spray system. Consequent!y a fire in this enclosure will neither affect the West Crescent Area nor the Torus Room.
l     The HPCI enclosure straddles the boundary between the East and West Crescent Areas and since the enclosure is open (i.e., it has no ceiling) It is split by the water curtain between the crescent areas. The enclosure consists of a seven-and-one-half foot high spray shield wall to limit the spread of spraying oil and a curb to limit the epread of leaking oil in the event of a HPCI system oil line break. Finally the HPCI i     turbine is protected with an automatic water spray and manual foam suppress!on system. Consequently, a fire in this enclosure is not likely to affect the crescent areas or the Torus Room.
From above, the Torus Room is bounded by Reactor Building el 272' (Fire Areas IX and X). This area is provided with automatic smoke detection systems. Water curtains are provided to separate Fire Area IX from Fire Areas X and XVil and to separate Fire Area X from Fire Area IX. Manual sprays are available from hose sta' ions located in Fire Areas IX and X.
Shutdown Systems Affected The Torus Room contains valves and components associated with the HPCI and RCIC systems.
Conservatively, these systems will be considered ditabled for a postulated fire in the Torus Room.
This area also contains equipment and cables associated with the Containment Atmosphere Dilution (CAD) System, specifically the nitrogen supply :or the ACS accumulators. Although the CAD System is .
not required for Appendix R safe shutdown, a postulated failure (i.e., the spurious opening of a CAD valve) may divert the nitrogen supply and could, if not detected and corrected,JYact the long-term operability of the ADS valves. Manual actions will be taken per procedures to assure CAD operabiEy.
In addition, the Torus Room contains Core Spray suction valves 14MOV-7A and 14MOV 7B. VMie neither of these valves are needed for a ' ire originating in the Torus Room,14MOV 7A needs tc be available for a fire in the eastem portion of the HPCI enclosure while 14MOV-7B needs to be available for a fire in the -
westem portion of the HPCI enclosure. See the discussion on the HPCI enc'osure provided under " Fire Originating Within the Crescent Area (Fire Areas XVil and XVill)".
Cinc!iy the Torus Room contains valves 10MOV 151 A and 10MOV-151B (RHR suction valves) which are in tr e open position with all power cables to them disabled. Thus this flow path would be available for safe shutdown during a fire in this area. This valve configuration was accepted by the NRC in grantirig the        i Torus Room exemption (Reference 3.21).                                                                         1 i
l Re 1.1                                         Page 14 of 49 u                                                                                                                  a

i ATTACHMENT 1 TO JPN-92-032 l
Shutdown Systems Available Either RHR-LPCl/ Suppression Pool Cooling (Division As or RHR~LPCl/ Suppression Pool Cooling (Division B) will be available for safe shutdown in the Torus Room. Control Room ADS actuation capability is available, in addition, for a fire originating in the HPCI enclosure either Core Spray (Division A) or Core Spray (Division B) will be available.
Fire Originating Within the Torus Room (Fire Area XV)
The required safe shutdown equipment which is located in the Toms Room and subject to fire-induced failures is limited to the following instrumentstion: Torus level (23LT-202A and 23LT 2028) and Torus temperature (161 TI-131 A and 161TI-1318). As described above, all RCIC and HPCI valves located in the Torus Room and 10MOV 151 A,10MOV 1518.14MOV-7A, and 14MOV 78 are assumed lost in the event of a torus fire.
Redundant torus level sensors are separated by a distance of greater than 110 feet c the oppos!te side of the torus without intervening exposed combustibles (see Figure 3.2-4). Considering a type, spacing -
and quantities of fixed combustibles and the low probability of transient combustibled to be located within the Torus Room, it is not considered possible for a fire la the Torus Room to propagate the intervening distance. Any associated fire damage would be localized to the immediate vicinity of the fire. The 110 foot separation with the radiant shielding of the drywell is more than adequate to assure that both the redundant torus level sensors are not lost.
For torus temperature measurement, the plant uses Resistance Temperature Detectors (RTDs). There are 32 RTDs (16 per Division) installed in 16 thermowells uniformly spaced around the torus. Each thermowe!I containe one Division A RTD and one Division B RTD. The 16 Division A RTDs enter the west side of the Torus Room from el. 272' of the reactor building. A portion of the RTDs are routed clociovise with the remainder routed ccunter-clockwise. The 16 Divirion B RTDs enter the east side of the Torus Room from the East Crescent Area, a portion of the RTDs are routed clockwise with the remainder routed counter-clockwise (see Figure 3.2-4).
Each channel of torus temperature instrumentation averages the temperature from its associated division RTDs. This instrumentation has the capability to recognize and discard failed RTDs. Conscquently, the loss of multiple RTDs within a division does not disable an entire channel, in addition, the operator can survey the RTDs individually in the Relay Room.
Although considered incredible, if it is assumed that all the RTDs and associated cabling located within a 120 degree arc of the Torus Room is lost due to a fire. sufficient RTTis would be unaffected to assure the operability of at least one division of torus temperature sensors.                                             l l
Since the Torus Room is essentially devoid of exposed combustibles, there is no fire exposure hazard to equipment and/or cabling in the crescent areas or Reactor Building el. 272'.                                   i l
Rev.1                                         Page 15 of 49 l
L

ATTACHMENT 1 TO JPN-92-032 Fire Orloinating Within the Crescent Area (Fire Areas XVil and XVill)
The wall separating the East and West Crescent Areas from tho Torus' Room is three-foot thick reinforced concreto containing a number of unsealed openings (see Figures 32-1 and 32-2).
A fire in either the East or West Crescent Area 13 not expected to damage circuits and/or equipment in the Torus Room via the unrated seals and/or unsealed openings based on the following:
a)       The crescent area has a floor to-ceiling height of approximately 40 feet, th!s allows vnrtical rise of the thermai plume, thus limiting its horizontal spread and decreasing its temperature due to mixing with air, b)       The vast majority of exposed combustibles in this area are installed above the non-fire-rated flood control bulkhead penetrations into the Torus Room, thereby limiting the fire exposure to the bulkhead, c)       Except for the flood control bulkhead, which is not near the HPCI enclosure (see Figures 32-1 and 32-2), the non-fire-rated seal assemblies and unsealed penetrations are small, d)       The HPCI oil will be contained in the HPCI enclosure and the Torus Room circuitry and/or       '
i equipment will not be d'rectly aposed to the oil, e)       The suppression systems (water spray and foam) installed in the HPCI enclosure will limit the extent and severity of the fire, and f)       Fire detection and manual fire fighting would rimit the extent of fire damage in this area.
In the unlikely event that a fire in the East or West Crescen. . Jea caused damage in the Torus Room, this '
damage would not cause loss of redundant safe shutdown ; 'peb!!ity based on the following:
a)       There are no exposed combustibles in the immediate vicinity of the unsealed openings, therefore, fire spread cannot occur and any damago which does occur would be limited to the immediate vicinity of the opening, b)       For a fire in the East Crescent Area, Division A systems are relied upon for safe shutdown and Division A torus level and temperature indication will not be lost even if it is assumed that all circuitry and/or equipment within the portion of the Torus Room adjacent to the East Crescent Area is lost, c)       For a fire in the West Crescent Area, Division B systems are relied upon for safe shuMown ar'd Division B torus level and temperature indication will not be lost even if it is assumed that all circuitry and/or equipment within the portion of the Torus Room adjacent to the West Crescent Arealslost, d)       For a HPC; enclosuro fire, circuitry associated with Core Spray suction valves 14MOV-7A i                       and 14MOV-78 (the only equipment in the Torus Room required to support Core Spray
!                       operation) is located in excess of 60 feet from the HPCI enclosure, thus due to the lack of l                       fixed intervening exposed combustibles, it is not credible to postulate that a HPC!
enclosure fire can spread within the Tcrus Room in such a manner that the circuitry for either Core Spray cuction valves would be rendered inopersNe, Rev.1                                          Page 16 of 48

ATTACHMENT 1 TO JPN-92-032 1
e)      Sensing lines associated with torus level sensors 23L1 202A and 23LT 202B are located in    ;
excess of 100 feet from the HPCI enclosure, therefore, for the same reasons stated in (d) aoove, it is not credible to assume that either torus level sensors would be rendered inoperable, and f)      If all cabling and equipment associated with torus temperature sensors 161TI 131 A and 161TI 131B located in a 120 degree arc of the torus adjacent to the HPCI enclosure was assumed lost, both 161TI-131 A and 161TI-131B would be available.
Fire Origination on Reactor Building el. 272' (Fire Areas IX and X)
Fire Area IX is abovo the east portion of the Torus Room and contains Division B circuitry and equipment.
Therefore, the plant relies on Division A circuitry and equipment for safe shutdown.
Fire Area X is above the west portion of the Torus Room and contains Division A circuitry and equipment.
Therefore, the plant relies on Division B circuitry and equipment for safe shutdown.
The various unsealed mechanical penetrations (see Figure 3.2 3) that are in the fire barrier separating the Reactor Building el. 272' from the Torus Room are either spares or contain pipes, conduits sod /or tubing.
In addition, there is a personnel access (ladder penetration RS-7) which is covered by grating.
Due to the confirurstion of these penetrations and surrounding combustibles,it is unlikely that any burning 6ebris will fall into the Torus Room.
Further, buming debris from Fire Area IX, with the exceptior o'he torus temperature indication, will only .
fall on Division B circuitry and/or equipment in the Torus Room. Since Fire Area IX coritains Division B circuitry and equipment, the plant relies on Division A circuitry and equipment for safe shutdown due to a fire in Fire Area IX.
Similarly, burning debris from Fire Area X, with the exception of the torus temperaturo indication, will only fall on Division A circuitry and/or equipment in the Torus Room.. Since Fire Area X contains Division A circuitry and equipment, the plant relies on Division B circuitry and equipment for safe shutdown due to a fire in Fire Area X.
The impact of e.ny of this flaming debris on the Torus Room including the impact on the torus temperature indication is enveloped by the previous discussion provided under
* Fire Originating Within the Torus Room (Fire Area XV)".
Hardship to the Authority The ha-dship to the Authority if this exemption is not granted is that the plant will have to remain shutdown until modifications are complete. Tne modifications that would be required are: provide fall area suppression and detection, seal open penetrations in the fire barriers and provide additional one-hour-rated fire barriers and wraps. These modifications are estimated to cost approximate'y
         $3,350,000. The Autho..ly estimates that it will take approximately two months after the present refueling outage to design, install and test these modifications. At a cost of $12,000,rF0 per month in lost revenue (i.e., S400,000 per day and 30 days per month) the estimated total lost revenue to the Authnrity is           j
        - $24,000,000 if FitzPatilck had to remain shutdown for an additional two months. This lost revenue            '
estimate only includes the Icas of income from FitzPatrick generated power and does not include the cost of replacement power. Therefore, the estimated total cost to the Authorig :s $27,350,000.
I Rev.1                                          Page 17 of 49 i
s

ATTACHMENT 1 TO JPN-92-032 These are only preliminary estimates of the time and cost that it would take to complete the above modifications. Detailed engineering, cost and schedule evaluations have not been prepared to support these estimates.
10 CFR 50.12 Criteria This request satisfies the criteria outlineri in 10 CFR 50.12(a)(1) for granting an exemption because (a) the     ,
exemption is authorized by law, (b) it will not present an undue risk to public health and safety and (c) it is consistent with the common defense and security.
10 CFR 50.12(a)(2) states that the Commission will not consider granting an exemption request unless special circumstances are present. Special circumstances are present whenever:
(i) Application of the regulation in the particular circumstances conflicts with other rules or requirements of the Commission; (ii) Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule; or (iii)
Compliance would result in undue hardship or other costs that are cignificantly in excess of those contemplated when the regulation was adopted or that are significantly in excess of those incurred by others similarly situated; or (iv) The exemption would result in benefit to the public health and safety that compensates for any decrease in safety that may result from the grant of the exemption; or (v) The exemption would provide only temporary relief from the applicable regulation and the licensee or applicant has . ,ade good faith efforts to comply with the regulation; or (vi) There is present any other materla! circumstances not considered when the regulation was adopted for which !! would be in the public interest to grant an exemption.
This exemption request satisfies criteria 10 CFR 50.12(a)(2)(ii) and (iii) as follows:
a)      The modifications required to achieve compliance with Sectkm t!!.G and lillwedd not significantly enhance the level of fire safety above that provided by existing fire protec?im, and b)       It would be costly to modify the Torus Room to comply with Sections Ill.G and Ill.L References                                                                                                         '
3.2 1            NRC Letter from D. D. Vassallo; to J. P. Bayne; dated July 1,1983; subject: " Exemption Requests- 10 CFR 50.48 Fire Protecuon and Appendix R to 10 CFR 50' 3.2 2            NRC Generic Letter 86-10; dated April 24,1986; subject: *lmplementation of Fire Protection Requirements
* Rev.1                                         Page 18 of 49
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