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{{Adams
#REDIRECT [[MNS-16-023, Response to Request for Supplemental Information Needed for Acceptance of Requested Licensing Action Regarding License Amendment Request for Control Room Chilled Water System Technical Specifications]]
| number = ML16081A135
| issue date = 03/16/2016
| title = McGuire and Catawba, Response to Request for Supplemental Information Needed for Acceptance of Requested Licensing Action Regarding License Amendment Request for Control Room Chilled Water System Technical Specifications
| author name = Capps S D
| author affiliation = Duke Energy Carolinas, LLC
| addressee name =
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000369, 05000370, 05000413, 05000414
| license number = NPF-009, NPF-017, NPF-035, NPF-052
| contact person =
| case reference number = MNS-16-023
| document type = Letter, Response to Request for Additional Information (RAI)
| page count = 6
}}
 
=Text=
{{#Wiki_filter:DUKE Steven D. Capps~ Vice PresidentENERGY° McGuire Nuclear StationDuke EnergyMG01VP I112700 Hagers Ferry RoadHuntersville, NC 27078o: 980.875.4805f: 980.875.4809Steven.Capps@duke-energy.comSerial No. MNS-16-023March 16, 2016 10 CFR 50.90U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001
 
==SUBJECT:==
Duke Energy Carolinas, LLC (Duke Energy)McGuire Nuclear Station (MNS), Units 1 and 2Docket Numbers 50-369 and 50-370,Renewed Facility Operating License NPF-9 and NPF-17Catawba Nuclear Station, Units 1 and 2Docket Numbers 50-413 and 50-414Renewed Facility Operating License NPF-35 and NPF-52Response to Request for Supplemental Information Needed for Acceptance ofRequested Licensing Action Regarding License Amendment Request for ControlRoom Chilled Water System Technical Specifications
 
==REFERENCES:==
: 1. Letter from Steven D. Capps (Duke Energy) to NRC (Serial: MNS-16-002), datedJanuary 7, 2016 (ADAMS Accession Number ML16029A077), Proposed TechnicalSpecifications (TS) Amendment TS 3. 7.10, "Con trol Room Area Chilled Water System"(MNS), and TS 3. 7.11, "Control Room Area Chilled Water System" (CNS)2. NRC letter from G. Edward Miller to Steven D. Capps (Duke Energy), datedMarch 1, 2016 (ADAMS Accession Number ML1 6055A333), McGuire Nuclear Station,Units 1 and 2 and Catawba Nuclear Station, Units 1 and 2 -Supplemental InformationNeeded For Acceptance of Requested Licensing Action RE: License AmendmentRequest for Control Room Chilled Water System Technical Specifications (TAC Nos.MF7224, MF7225, MF7226, and MF7227)
U.S. Nuclear Regulatory CommissionMNS-1 6-023Page 2By letter dated January 7, 2016 (Reference 1), Duke Energy submitted a License AmendmentRequest (LAR) for Technical Specifications (TS) TS 3. 7.10, "Con trol Room Area Chilled WaterSystem" (MNS), and TS 3.7.11, "Control Room Area Chilled Water System" (CNS).The NRC staff reviewed the LAR and determined that supplemental information is neededregarding the acceptability of the proposed LAR in terms of regulatory requirements and theprotection of public health and safety and the environment. By letter dated March 1, 2016(Reference 2), the supplemental information was requested. The supplemental informationrequires submission by March 17, 2016. The Duke Energy responses to the supplementalinformation are provided in the Enclosure to this letter.The conclusions of the original Significant Hazards Consideration and EnvironmentalConsiderations contained in the January 7, 2016, LAR (Reference 1) are unaffected as a resultof this supplemental response.Pursuant to 10 CER 50.91, a copy of this LAR supplement is being provided to the appropriateStates of North and South Carolina officials.There are no regulatory commitments contained in this letter or its enclosure.If you have any questions or need additional information on this matter, please contactLee A. Hentz at (980) 875-4187.I declare under penalty of perjury that the foregoing is true and correct. Executed onMarch 16, 2016.Sincerely,Steven D.
 
==Enclosure:==
Response to Supplemental Information U.S. Nuclear Regulatory CommissionMNS-1 6-023Page 3cc: (with enclosure)Catherine HaneyRegional AdministratorU.S. Nuclear Regulatory Commission -Region IIMarquis One Tower245 Peachtree Center Ave., NE Suite 1200Atlanta, GA 30303-1 257G.A. Hutto Ill (Catawba)Senior Resident InspectorU.S. Nuclear Regulatory CommissionCatawba Nuclear StationJ. ZeilerSenior Resident Inspector (McGuire)U.S. Nuclear Regulatory CommissionMcGuire Nuclear StationG.E. MillerNRC Project Manager (McGuire)U.S. Nuclear Regulatory CommissionOne White Flint North, Mail Stop 8-G9A111555 Rockville PikeRockville, MD 20852-2738J.A. WhitedProject Manager (Catawba)U.S. Nuclear Regulatory CommissionOne White Flint North, Mail Stop 8 B1A11555 Rockville PikeRockville, MD 20852-2738S.E. Jenkins ManagerRadioactive & infectious Waste ManagementDivision of Waste ManagementSouth Carolina Department of Health and Environmental Control2600 Bull St.Columbia, SC 29201W.L. Cox, IlISection Chief, Division of Environmental HealthRadiation Protection SectionNorth Carolina Department of Environment and Natural Resources1645 Mail Service CenterRaleigh, NC 27699 U.S. Nuclear Regulatory CommissionM NS-1 6-023Enclosure 1Page 1 of 3Response to Request for Supplemental Information Needed for Acceptance of RequestedLicensing Action Regarding License Amendment Request for Control Room Chilled WaterSystem Technical SpecificationsBy letter dated January 7, 2016 (Agencywide Documents Access and Management SystemAccession No. ML 16029A077), Duke Energy Carolinas, LLC (Duke Energy or the licensee),submitted a license amendment request for McGuire Nuclear Station, Units 1 and 2 (MNS 1 and2) and Catawba Nuclear Station, Units 1 and 2 (CNS 1 and 2). The proposed amendment wouldmodify the Control Room Area Chilled Water System Technical Specifications to allow a finitetime to address a loss of both trains provided Control Room temperature remains below 90°F.The NRC staff has reviewed your application and concluded that the information delineatedbelow is necessary to enable the staff to make an independent assessment regarding theacceptability of the proposed amendment in terms of regulatory requirements and the protectionof public health and safety and the environment.For MNS and CNSNRC Question 1With both trains of the Control Room Area Chilled Water System inoperable, the effects of heatstress due to the rising temperature, under some circumstances, may impede the operators'ability to take actions required to safely operate the nuclear power unit. From a human factorsperspective, please describe any effects that the proposed change may have on the controlroom operators. In this description, include a justification that any impacted persons will still beable to successfully perform their job role.Duke Energy Response to Question 1This question was further clarified during the March 1, 2016, conference call between the NRCStaff and Duke Energy: "What would be the impact on the Control Room Operators if theControl Room remained at or near 90°F for the duration of the proposed Condition BCompletion Time of 24 hours."Duke Energy has in place an Administrative Procedure, "Heat and Cold Stress," based on anindustry standard, that evaluates activities which expose workers to adverse environmentalconditions and provides means and methods to avoid heat stress related health incidents.Control Room activities can be considered "Light work: sitting or standing with moderate arm ortrunk movement, monitoring equipment, minimal walking." Per the Procedure's "Stay TimeChart," there are no stay time limits for light work up to a wet bulb globe temperature (WBGT) of90°F. Stay time is defined as the recommended amount of time that a worker is expected tosafely work in a moderate to high heat environment.Control Room temperature is measured as a dry bulb temperature, meaning the impacts fromhumidity are not accounted for as they are with WBGT. Low humidity impacts dry bulbtemperatures positively, thus the WBGT will equate to a lower temperature than the measured U.S. Nuclear Regulatory CommissionMNS-1 6-023Enclosure 1Page 2 of 3dry bulb. Conversely, very high humidity (90-100%) impacts dry bulb temperatures negatively,thus the WBGT will equate to a higher temperature than the measured dry bulb.During a loss of cooling event in the Control Room, there would not be an appreciable increasein humidity as temperature rises since mnost of the Control Room heat load is in the form ofsensible heat. Latent heat, which drives humidity, accounts for only a fraction of the total roomheat load. Thus, high humidity levels in the Control Room are not a concern for MNS or CNS.This means that the currently measured dry bulb temperature would be comparable to theWBGT, and there are no mandated stay time restrictions as long as the Control Roomtemperature remains 90°F or less.From a human factors perspective, based on the above considerations, the proposed changewill have no adverse impact on Control Room Operators. The effects of rising temperature inthe Control Room should not impede the Operators' ability to take actions required to safelyoperate the nuclear power unit.Duke Energy also has readily available instruments that easily measure WBGT. These areavailable close to the Control Room and do not require any specific qualifications. Their set-upand use are described in the "Heat and Cold Stress" procedure. As such, an exactdetermination of Control Room WBGT can easily be determined.In addition, Operator shifts are limited to 12 hours. Supplemental staffing can be provided toallow Operators to periodically rotate during shifts if the need arises.NRC Question 2The submittal indicates that the current licensed design temperature of the Control Roomequipment is 90°F or less, verified every 12 hours. This value was determined assuming that atleast one train of the Control Room Area Chilled Water System was available for active removalof heat. When in the proposed Condition B, the ability to remove heat from the Control Roomwould be significantly reduced. Although it appears that the increased frequency of verificationof Control Room temperature (i.e., every 4 hours) is meant to account for this, the submittaldoes not address why it is adequate. Please provide a quantitative justification for the 4 hoursurveillance interval and how the 90°F limit remains valid given potentially increased ControlRoom heat-up rates.Duke Energy Response to Question 2The four hour monitoring frequency of Control Room temperature when in the proposedCondition B was predominately based on remaining consistent with NRC approved TSTF-477Rev.3 and draft TSTF-553. As the Control Room is continuously occupied, any temperaturechanges would be immediately recognized by the Operators.MNS and CNS have in place "Abnormal Procedures" (AP) to take mitigating actions whenControl Room temperature reaches 80°F and take actions to shutdown the affected Units iftemperature rises above 90°F.
U.S. Nuclear Regulatory CommissionMNS-1 6-023Enclosure 1Page 3 of 3The MNS AP is entered by Operators on symptoms such as: Control Room temperatureincreasing, chill water supply temperature increasing (alarms at 55°F), or Control Room supplyair temperature increasing (alarms at 75°F). Once the AP is entered, MNS Control Roomtemperature is monitored continuously.The CNS AP is entered by Operators on symptoms such as: Control Room temperatureincreasing, Control Room Air Handling Unit (AHU) low flow alarm, Control Room Chiller "off'alarm or "critical trouble" alarm. If the CNS Control Room reaches 80°F, temperature ismonitored continuously until one train of Control Room Area Chilled Water System (CRACWS)is restored.In summary, MNS and CNS enter the applicable AP for "Control Room High Temperature" priorto any significant increase in Control Room temperature or early symptoms of CRACWSequipment malfunctions. Once the APs are entered, Control Room temperature is continuouslymonitored with specific actions to be taken at 80°F and 90°F. These AP actions satisfy theintent of proposed Action B.1 and the associated Completion Time of four hours.As stated in Section 3.6 of the LAR, the most likely application of proposed Condition B and theassociated Required Actions is when both CRACWS trains are inoperable but one train isfunctional with the ability to cool the Control Room. In this case, the Control Room temperaturewould remain constant at a normal value, and the 90°F limit is not challenged.For CNSNRC Question 3The submittal indicates that the current licensed design temperature of the Control Roomequipment is 90°F or less. The submittal also indicates that, while the temperature control bandfor MNS is 75°F to 900°F, the band for CNS is 72°F to 850°F. Please clarify the apparentdiscrepancy between the CNS licensing basis and system design.Duke Energy Response to Question 3The current licensed design temperature for the CNS Control Room is 90°F. This is theTechnical Specification (TS) limit as defined in CNS TS 3.7.11. This represents the temperatureat which CNS will take action to shut down both Units. The 90°F limit does not represent themaximum temperature at which equipment in the Control Room will operate, nor does itrepresent the temperature at which CNS operates the Control Room. The CRACWS "designset point" (temperature at which the Control Room is maintained) is 74°F. In a large system,however, there is always a range of temperatures over which a system will operate. Thesubmittal addresses this potential range by using the values stated in the TechnicalSpecification Bases for CNS TS 3.7.11 which is 720F -85°F.Although the operating range of 72°F- 85°F is the administrative limit, 90°F remains the TS limitas defined in CNS TS 3.7.11. It should be noted that CNS maintains the Control Room at 740°F.Actions will be taken anytime the Control Room temperature reaches 800F or above. Thisprovides margin to the LCO limit of 900°F.
DUKE Steven D. Capps~ Vice PresidentENERGY° McGuire Nuclear StationDuke EnergyMG01VP I112700 Hagers Ferry RoadHuntersville, NC 27078o: 980.875.4805f: 980.875.4809Steven.Capps@duke-energy.comSerial No. MNS-16-023March 16, 2016 10 CFR 50.90U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001
 
==SUBJECT:==
Duke Energy Carolinas, LLC (Duke Energy)McGuire Nuclear Station (MNS), Units 1 and 2Docket Numbers 50-369 and 50-370,Renewed Facility Operating License NPF-9 and NPF-17Catawba Nuclear Station, Units 1 and 2Docket Numbers 50-413 and 50-414Renewed Facility Operating License NPF-35 and NPF-52Response to Request for Supplemental Information Needed for Acceptance ofRequested Licensing Action Regarding License Amendment Request for ControlRoom Chilled Water System Technical Specifications
 
==REFERENCES:==
: 1. Letter from Steven D. Capps (Duke Energy) to NRC (Serial: MNS-16-002), datedJanuary 7, 2016 (ADAMS Accession Number ML16029A077), Proposed TechnicalSpecifications (TS) Amendment TS 3. 7.10, "Con trol Room Area Chilled Water System"(MNS), and TS 3. 7.11, "Control Room Area Chilled Water System" (CNS)2. NRC letter from G. Edward Miller to Steven D. Capps (Duke Energy), datedMarch 1, 2016 (ADAMS Accession Number ML1 6055A333), McGuire Nuclear Station,Units 1 and 2 and Catawba Nuclear Station, Units 1 and 2 -Supplemental InformationNeeded For Acceptance of Requested Licensing Action RE: License AmendmentRequest for Control Room Chilled Water System Technical Specifications (TAC Nos.MF7224, MF7225, MF7226, and MF7227)
U.S. Nuclear Regulatory CommissionMNS-1 6-023Page 2By letter dated January 7, 2016 (Reference 1), Duke Energy submitted a License AmendmentRequest (LAR) for Technical Specifications (TS) TS 3. 7.10, "Con trol Room Area Chilled WaterSystem" (MNS), and TS 3.7.11, "Control Room Area Chilled Water System" (CNS).The NRC staff reviewed the LAR and determined that supplemental information is neededregarding the acceptability of the proposed LAR in terms of regulatory requirements and theprotection of public health and safety and the environment. By letter dated March 1, 2016(Reference 2), the supplemental information was requested. The supplemental informationrequires submission by March 17, 2016. The Duke Energy responses to the supplementalinformation are provided in the Enclosure to this letter.The conclusions of the original Significant Hazards Consideration and EnvironmentalConsiderations contained in the January 7, 2016, LAR (Reference 1) are unaffected as a resultof this supplemental response.Pursuant to 10 CER 50.91, a copy of this LAR supplement is being provided to the appropriateStates of North and South Carolina officials.There are no regulatory commitments contained in this letter or its enclosure.If you have any questions or need additional information on this matter, please contactLee A. Hentz at (980) 875-4187.I declare under penalty of perjury that the foregoing is true and correct. Executed onMarch 16, 2016.Sincerely,Steven D.
 
==Enclosure:==
Response to Supplemental Information U.S. Nuclear Regulatory CommissionMNS-1 6-023Page 3cc: (with enclosure)Catherine HaneyRegional AdministratorU.S. Nuclear Regulatory Commission -Region IIMarquis One Tower245 Peachtree Center Ave., NE Suite 1200Atlanta, GA 30303-1 257G.A. Hutto Ill (Catawba)Senior Resident InspectorU.S. Nuclear Regulatory CommissionCatawba Nuclear StationJ. ZeilerSenior Resident Inspector (McGuire)U.S. Nuclear Regulatory CommissionMcGuire Nuclear StationG.E. MillerNRC Project Manager (McGuire)U.S. Nuclear Regulatory CommissionOne White Flint North, Mail Stop 8-G9A111555 Rockville PikeRockville, MD 20852-2738J.A. WhitedProject Manager (Catawba)U.S. Nuclear Regulatory CommissionOne White Flint North, Mail Stop 8 B1A11555 Rockville PikeRockville, MD 20852-2738S.E. Jenkins ManagerRadioactive & infectious Waste ManagementDivision of Waste ManagementSouth Carolina Department of Health and Environmental Control2600 Bull St.Columbia, SC 29201W.L. Cox, IlISection Chief, Division of Environmental HealthRadiation Protection SectionNorth Carolina Department of Environment and Natural Resources1645 Mail Service CenterRaleigh, NC 27699 U.S. Nuclear Regulatory CommissionM NS-1 6-023Enclosure 1Page 1 of 3Response to Request for Supplemental Information Needed for Acceptance of RequestedLicensing Action Regarding License Amendment Request for Control Room Chilled WaterSystem Technical SpecificationsBy letter dated January 7, 2016 (Agencywide Documents Access and Management SystemAccession No. ML 16029A077), Duke Energy Carolinas, LLC (Duke Energy or the licensee),submitted a license amendment request for McGuire Nuclear Station, Units 1 and 2 (MNS 1 and2) and Catawba Nuclear Station, Units 1 and 2 (CNS 1 and 2). The proposed amendment wouldmodify the Control Room Area Chilled Water System Technical Specifications to allow a finitetime to address a loss of both trains provided Control Room temperature remains below 90°F.The NRC staff has reviewed your application and concluded that the information delineatedbelow is necessary to enable the staff to make an independent assessment regarding theacceptability of the proposed amendment in terms of regulatory requirements and the protectionof public health and safety and the environment.For MNS and CNSNRC Question 1With both trains of the Control Room Area Chilled Water System inoperable, the effects of heatstress due to the rising temperature, under some circumstances, may impede the operators'ability to take actions required to safely operate the nuclear power unit. From a human factorsperspective, please describe any effects that the proposed change may have on the controlroom operators. In this description, include a justification that any impacted persons will still beable to successfully perform their job role.Duke Energy Response to Question 1This question was further clarified during the March 1, 2016, conference call between the NRCStaff and Duke Energy: "What would be the impact on the Control Room Operators if theControl Room remained at or near 90°F for the duration of the proposed Condition BCompletion Time of 24 hours."Duke Energy has in place an Administrative Procedure, "Heat and Cold Stress," based on anindustry standard, that evaluates activities which expose workers to adverse environmentalconditions and provides means and methods to avoid heat stress related health incidents.Control Room activities can be considered "Light work: sitting or standing with moderate arm ortrunk movement, monitoring equipment, minimal walking." Per the Procedure's "Stay TimeChart," there are no stay time limits for light work up to a wet bulb globe temperature (WBGT) of90°F. Stay time is defined as the recommended amount of time that a worker is expected tosafely work in a moderate to high heat environment.Control Room temperature is measured as a dry bulb temperature, meaning the impacts fromhumidity are not accounted for as they are with WBGT. Low humidity impacts dry bulbtemperatures positively, thus the WBGT will equate to a lower temperature than the measured U.S. Nuclear Regulatory CommissionMNS-1 6-023Enclosure 1Page 2 of 3dry bulb. Conversely, very high humidity (90-100%) impacts dry bulb temperatures negatively,thus the WBGT will equate to a higher temperature than the measured dry bulb.During a loss of cooling event in the Control Room, there would not be an appreciable increasein humidity as temperature rises since mnost of the Control Room heat load is in the form ofsensible heat. Latent heat, which drives humidity, accounts for only a fraction of the total roomheat load. Thus, high humidity levels in the Control Room are not a concern for MNS or CNS.This means that the currently measured dry bulb temperature would be comparable to theWBGT, and there are no mandated stay time restrictions as long as the Control Roomtemperature remains 90°F or less.From a human factors perspective, based on the above considerations, the proposed changewill have no adverse impact on Control Room Operators. The effects of rising temperature inthe Control Room should not impede the Operators' ability to take actions required to safelyoperate the nuclear power unit.Duke Energy also has readily available instruments that easily measure WBGT. These areavailable close to the Control Room and do not require any specific qualifications. Their set-upand use are described in the "Heat and Cold Stress" procedure. As such, an exactdetermination of Control Room WBGT can easily be determined.In addition, Operator shifts are limited to 12 hours. Supplemental staffing can be provided toallow Operators to periodically rotate during shifts if the need arises.NRC Question 2The submittal indicates that the current licensed design temperature of the Control Roomequipment is 90°F or less, verified every 12 hours. This value was determined assuming that atleast one train of the Control Room Area Chilled Water System was available for active removalof heat. When in the proposed Condition B, the ability to remove heat from the Control Roomwould be significantly reduced. Although it appears that the increased frequency of verificationof Control Room temperature (i.e., every 4 hours) is meant to account for this, the submittaldoes not address why it is adequate. Please provide a quantitative justification for the 4 hoursurveillance interval and how the 90°F limit remains valid given potentially increased ControlRoom heat-up rates.Duke Energy Response to Question 2The four hour monitoring frequency of Control Room temperature when in the proposedCondition B was predominately based on remaining consistent with NRC approved TSTF-477Rev.3 and draft TSTF-553. As the Control Room is continuously occupied, any temperaturechanges would be immediately recognized by the Operators.MNS and CNS have in place "Abnormal Procedures" (AP) to take mitigating actions whenControl Room temperature reaches 80°F and take actions to shutdown the affected Units iftemperature rises above 90°F.
U.S. Nuclear Regulatory CommissionMNS-1 6-023Enclosure 1Page 3 of 3The MNS AP is entered by Operators on symptoms such as: Control Room temperatureincreasing, chill water supply temperature increasing (alarms at 55°F), or Control Room supplyair temperature increasing (alarms at 75°F). Once the AP is entered, MNS Control Roomtemperature is monitored continuously.The CNS AP is entered by Operators on symptoms such as: Control Room temperatureincreasing, Control Room Air Handling Unit (AHU) low flow alarm, Control Room Chiller "off'alarm or "critical trouble" alarm. If the CNS Control Room reaches 80°F, temperature ismonitored continuously until one train of Control Room Area Chilled Water System (CRACWS)is restored.In summary, MNS and CNS enter the applicable AP for "Control Room High Temperature" priorto any significant increase in Control Room temperature or early symptoms of CRACWSequipment malfunctions. Once the APs are entered, Control Room temperature is continuouslymonitored with specific actions to be taken at 80°F and 90°F. These AP actions satisfy theintent of proposed Action B.1 and the associated Completion Time of four hours.As stated in Section 3.6 of the LAR, the most likely application of proposed Condition B and theassociated Required Actions is when both CRACWS trains are inoperable but one train isfunctional with the ability to cool the Control Room. In this case, the Control Room temperaturewould remain constant at a normal value, and the 90°F limit is not challenged.For CNSNRC Question 3The submittal indicates that the current licensed design temperature of the Control Roomequipment is 90°F or less. The submittal also indicates that, while the temperature control bandfor MNS is 75°F to 900°F, the band for CNS is 72°F to 850°F. Please clarify the apparentdiscrepancy between the CNS licensing basis and system design.Duke Energy Response to Question 3The current licensed design temperature for the CNS Control Room is 90°F. This is theTechnical Specification (TS) limit as defined in CNS TS 3.7.11. This represents the temperatureat which CNS will take action to shut down both Units. The 90°F limit does not represent themaximum temperature at which equipment in the Control Room will operate, nor does itrepresent the temperature at which CNS operates the Control Room. The CRACWS "designset point" (temperature at which the Control Room is maintained) is 74°F. In a large system,however, there is always a range of temperatures over which a system will operate. Thesubmittal addresses this potential range by using the values stated in the TechnicalSpecification Bases for CNS TS 3.7.11 which is 720F -85°F.Although the operating range of 72°F- 85°F is the administrative limit, 90°F remains the TS limitas defined in CNS TS 3.7.11. It should be noted that CNS maintains the Control Room at 740°F.Actions will be taken anytime the Control Room temperature reaches 800F or above. Thisprovides margin to the LCO limit of 900°F.}}

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