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=Text=
=Text=
{{#Wiki_filter:Boyle, Patrick I Q From: Boyle, Patrick Sent: Friday, September 16, 2011 2:43 PM To: Khanna, Meena  
{{#Wiki_filter:Boyle, Patrick                               IQ From:                     Boyle, Patrick Sent:                     Friday, September 16, 2011 2:43 PM To:                       Khanna, Meena


==Subject:==
==Subject:==
RE: ACTION today: RE: interview request This is well beyond the scope of my normal duties, knowledge area and expertise.
RE: ACTION today: RE: interview request This is well beyond the scope of my normal duties, knowledge area and expertise. My first thought was to not respond. However, I decided to make a good faith effort with the understand management will thoroughly scrub my responses. These are great Q's and A's for the communication plan. See my responses in RED The first question has me on thin ice since I have not seen the AIT report and the Region really has the call on if the licensee is doing enough inspections. The second question already has the answer that-the NRC will not speculate since we have not received and evaluated the report from the licensee. I believe Dominion has adjusted their readiness date as well. The third question is addressed by issuing an order that outlines what must be completed prior to restart. The order will be informed by the AIT and the Dominion re-start readiness report with input from the appropriate NRR Technical, staff RES staff, NRO experts, and Region Support.
My first thought was to not respond. However, I decided to make a good faith effort with the understand management will thoroughly scrub my responses.
Original
These are great Q's and A's for the communication plan. See my responses in RED The first question has me on thin ice since I have not seen the AIT report and the Region really has the call on if the licensee is doing enough inspections.
        -----Message----
The second question already has the answer that-the NRC will not speculate since we have not received and evaluated the report from the licensee.
From: Khanna, Meena Sent: Friday, September 16, 2011 1:57 PM To: Boyle, Patrick
I believe Dominion has adjusted their readiness date as well. The third question is addressed by issuing an order that outlines what must be completed prior to restart. The order will be informed by the AIT and the Dominion re-start readiness report with input from the appropriate NRR Technical, staff RES staff, NRO experts, and Region Support.----- Original Message----
From: Khanna, Meena Sent: Friday, September 16, 2011 1:57 PM To: Boyle, Patrick  


==Subject:==
==Subject:==
FW: ACTION today: RE: interview request----- Original Message---
FW: ACTION today: RE: interview request Original
From: Khanna, Meena Sent: Friday, September 16, 2011 1:52 PM To: Manoly, Kamal  
        -----Message---
From: Khanna, Meena Sent: Friday, September 16, 2011 1:52 PM To: Manoly, Kamal


==Subject:==
==Subject:==
FW: ACTION today: RE: interview request----- Original
FW: ACTION today: RE: interview request Original
'ýFrom: McCoy, Gerald \\'-Sent: Friday, September`
        -----Message----(* 'ý From: McCoy, Gerald \\'-
16, 2011 1:08 PM To: Khanna, Meena  
Sent: Friday, September` 16, 2011 1:08 PM To: Khanna, Meena


==Subject:==
==Subject:==
RE: ACTION today: RE: interview request I'm not sure these are really questions best addressed by the region.Gerald J. McCoy Chief, Reactor Projects Branch 5 Division of Reactor Projects, Region 2 United States Nuclear Regulatory Commission Office: 404-997-4551
RE: ACTION today: RE: interview request I'm not sure these are really questions best addressed by the region.
---Original Message-----
Gerald J. McCoy Chief, Reactor Projects Branch 5 Division of Reactor Projects, Region 2 United States Nuclear Regulatory Commission Office: 404-997-4551
From: Khanna, Meena Sent: Friday, September 16, 2011 1:07 PM Information in this record was deleted To: Franke, Mark; McCoy, Gerald in accordance witp the Freedom of Information i Act, exemptions W F01A. -CJ3 _  
--- Original Message-----
From: Khanna, Meena Sent: Friday, September 16, 2011 1:07 PM                     Information in this record was deleted To: Franke, Mark; McCoy, Gerald                             in accordance witp the Freedom of Information i Act, exemptions W F01A.         -CJ3           _


==Subject:==
==Subject:==
FW: ACTION today: RE: interview request Mark and Gerry, could we pIs discuss the questions below and draft some responses, together, if possible.
FW: ACTION today: RE: interview request Mark and Gerry, could we pIs discuss the questions below and draft some responses, together, if possible. I will call Scott to see when this needs to be completed.. .thanks!
I will call Scott to see when this needs to be completed.. .thanks!Meena----Original Message-rr-From: Howe, Allen \I\q" Sent: Friday, September 16, 2011 12:45 PM To: Khanna, Meena; Wilson, George Cc: Wert, Leonard; Glitter, Joseph  
Meena
---- Original Message-rr-From: Howe, Allen \I\q" Sent: Friday, September 16, 2011 12:45 PM To: Khanna, Meena; Wilson, George Cc: Wert, Leonard; Glitter, Joseph


==Subject:==
==Subject:==
ACTION today: RE: interview request Meena/George  
ACTION today: RE: interview request Meena/George - lets caucus and get back to Scott. We will need to involve RII.
-lets caucus and get back to Scott. We will need to involve RII.Allen-Original Message----
Allen Message---- r'
r'From: Guitter, Joseph \,. \" Sent: Friday, September 16, 2011 12:26 PM To: Howe, Allen Cc: Khanna, Meena; Wilson, George; Wert, Leonard  
          -Original From: Guitter, Joseph     \,.\"
Sent: Friday, September 16, 2011 12:26 PM To: Howe, Allen Cc: Khanna, Meena; Wilson, George; Wert, Leonard


==Subject:==
==Subject:==
FW: interview request Importance:
FW: interview request Importance: High Pat is out today and I just saw this. When do you think we will be able to get back to Scott? I think we should point them to the AIT report for the response to the first question. My initial thoughts on some of the other questions are indicated in brackets. Do we have enough detail in our communications plan at this point to answer the questions? I'm guessing not.
High Pat is out today and I just saw this. When do you think we will be able to get back to Scott? I think we should point them to the AIT report for the response to the first question.
--- Original Message---- ,q.-
My initial thoughts on some of the other questions are indicated in brackets.
From: Burnell, Scott \iJ "
Do we have enough detail in our communications plan at this point to answer the questions?
Sent: Friday, September 16, 2011 9:28 AM To: Guitter, Joseph; Hiland, Patrick
I'm guessing not.---Original Message---- ,q.-From: Burnell, Scott \iJ " Sent: Friday, September 16, 2011 9:28 AM To: Guitter, Joseph; Hiland, Patrick  


==Subject:==
==Subject:==
FW: interview request Importance:
FW: interview request Importance: High Joe, Pat; I just need quick answers to these. If I recall correctly, we're still waiting for Dominion's formal submissions before we determine the need for any additional questions, and Jack was pretty clear that we're not going to be in a position to approve restart by the 22nd. Thanks.
High Joe, Pat;I just need quick answers to these. If I recall correctly, we're still waiting for Dominion's formal submissions before we determine the need for any additional questions, and Jack was pretty clear that we're not going to be in a position to approve restart by the 22nd. Thanks.Scott----Original Message-----
Scott
From: BRIAN WINGFIELD, BLOOMBERG/
---- Original Message-----
NEWSROOM:
From: BRIAN WINGFIELD, BLOOMBERG/ NEWSROOM: [mailto:bwingfield3@bloomberg.net]
[mailto:bwingfield3@bloomberg.net]
Sent: Friday, September 16, 2011 9:24 AM To: Burnell, Scott; Ledford, Joey, Hannah, Roger
Sent: Friday, September 16, 2011 9:24 AM To: Burnell, Scott; Ledford, Joey, Hannah, Roger  


==Subject:==
==Subject:==
RE: interview request Sure. A few of my questions:
RE: interview request Sure. A few of my questions:
: 1. Is the NRC satisfied that Dominion's inspections so far are sufficient?
: 1. Is the NRC satisfied that Dominion's inspections so far are sufficient? Is NRC concerned that Dominion is doing too many visual inspections, particularly regarding spent fuel? How does NRC guarantee that 2
Is NRC concerned that Dominion is doing too many visual inspections, particularly regarding spent fuel? How does NRC guarantee that 2 Dominion's inspections are satisfactory?
 
[Refer to the AIT report.] I have not seen the AIT report. The response to this question should be informed by that report. In answer to the press we can state that the NRC has an interest in additional inspections, such as ultrasonic testing or dye penetrate tests that would be more revealing than a visual inspection.
Dominion's inspections are satisfactory? [Refer to the AIT report.] I have not seen the AIT report. The response to this question should be informed by that report. In answer to the press we can state that the NRC has an interest in additional inspections, such as ultrasonic testing or dye penetrate tests that would be more revealing than a visual inspection. I do not know if those have been done or are planned. However, the NRC has not fully assessed the testing and the restart inspection team will make that determination.
I do not know if those have been done or are planned. However, the NRC has not fully assessed the testing and the restart inspection team will make that determination.
: 2. Dominion says it will have Unit 1 "physically" ready for re-start by Sept. 22? Is that too ambitious? What is a likely re-start timeframe? (Even a ballpark estimate is OK.) [Don't think we should speculate on this other than to say that even ifthe licensee is physically ready, NRC will need time to complete its review, It is premature to estimate what that time will be until we have fully evaluated the licensees restart readiness review. In other words, the NRC starts its review once the licensee says that it is ready. How long it takes depends on how long it will take to respond to NRC questions.) It is possible for Dominion to complete its scope of tests demonstrating that the equipment needed for operations is capable of operating in accordance with its current licensing basis by a time near September 22nd. The question that remains is what additional testing that should be done prior to restart and the NRC has not made this determination yet. Dominion must demonstrate to the NRC that the plant is safe to operate so the NRC cannot state a timeframe. It is dependent on the requirements and resources Dominion dedicates to the effort. (not for public disclosure, but even if we knew exactly when the plant would restart, that information would be privileged to the licensee, similar to outage planning details).
: 2. Dominion says it will have Unit 1 "physically" ready for re-start by Sept. 22? Is that too ambitious?
: 3. From NRC's perspective, what happens in the process after Dominion says the plant is ready to re-start?
What is a likely re-start timeframe? (Even a ballpark estimate is OK.) [Don't think we should speculate on this other than to say that even if the licensee is physically ready, NRC will need time to complete its review, It is premature to estimate what that time will be until we have fully evaluated the licensees restart readiness review. In other words, the NRC starts its review once the licensee says that it is ready. How long it takes depends on how long it will take to respond to NRC questions.)
(I.e. what needs to happen from a regulatory perspective?) [ See above. Discuss letter that we expect from Dominion and key elements of the restart plan.] the NRC will issue an order stating what conditions are required prior to the plant returning to operations. This will be based in part on the letter to the NRC stating the planned and completed tests, analysis and inspections performed at the plant and the NRC staff's evaluation of those tests, analyses, and inspections.
It is possible for Dominion to complete its scope of tests demonstrating that the equipment needed for operations is capable of operating in accordance with its current licensing basis by a time near September 22nd. The question that remains is what additional testing that should be done prior to restart and the NRC has not made this determination yet. Dominion must demonstrate to the NRC that the plant is safe to operate so the NRC cannot state a timeframe.
: 4. Dominion has said North Anna is the "test case" for GI-1 99. Do you agree? How important is the North Anna review to the entire GI-199 process? Could the GI-199 process delay re-start for North Anna?
It is dependent on the requirements and resources Dominion dedicates to the effort. (not for public disclosure, but even if we knew exactly when the plant would restart, that information would be privileged to the licensee, similar to outage planning details).3. From NRC's perspective, what happens in the process after Dominion says the plant is ready to re-start?(I.e. what needs to happen from a regulatory perspective?)
: 5. It may take a year or more--please correct me if I'm wrong here-to update seismic risks at nuclear plants as part of the G1-199 process. Ifthat's the case, how does NRC know the seismic analysis at North Anna, which is now ongoing, is going to be sufficient?
[ See above. Discuss letter that we expect from Dominion and key elements of the restart plan.] the NRC will issue an order stating what conditions are required prior to the plant returning to operations.
: thanks, Brian Message -----
This will be based in part on the letter to the NRC stating the planned and completed tests, analysis and inspections performed at the plant and the NRC staff's evaluation of those tests, analyses, and inspections.
          -Original From: Scott Burnell <Scott.Burnell@nrc.gov>
: 4. Dominion has said North Anna is the "test case" for GI-1 99. Do you agree? How important is the North Anna review to the entire GI-199 process? Could the GI-199 process delay re-start for North Anna?5. It may take a year or more--please correct me if I'm wrong here-to update seismic risks at nuclear plants as part of the G1-199 process. If that's the case, how does NRC know the seismic analysis at North Anna, which is now ongoing, is going to be sufficient?
To: Joey.Ledford@nrc.gov, Roger.Hannah@nrc.gov, BRIAN WINGFIELD (BLOOMBERG/ NEWSROOM:)
thanks, Brian-Original Message -----From: Scott Burnell <Scott.Burnell@nrc.gov>
At: 9/16 8:24:20 Brian; Can you give us a better idea of what you'd like to cover? That'll help us figure out who's best-equipped to answer. Thanks.
To: Joey.Ledford@nrc.gov, Roger.Hannah@nrc.gov, BRIAN WINGFIELD (BLOOMBERG/
Scott
NEWSROOM:)
---- Original Message -----
At: 9/16 8:24:20 Brian;Can you give us a better idea of what you'd like to cover? That'll help us figure out who's best-equipped to answer. Thanks.Scott----Original Message -----From: BRIAN WINGFIELD, BLOOMBERG/
From: BRIAN WINGFIELD, BLOOMBERG/ NEWSROOM: [mailto:bwingfield3@bloomberg.net]
NEWSROOM:
Sent: Thursday, September 15, 2011 4:49 PM To: Burnell, Scott; Ledford, Joey; Hannah, Roger
[mailto:bwingfield3@bloomberg.net]
Sent: Thursday, September 15, 2011 4:49 PM To: Burnell, Scott; Ledford, Joey; Hannah, Roger  


==Subject:==
==Subject:==
Re: interview request 3 Thanks.Roger/Joey:
Re: interview request 3
If you can help out at all, I'd be grateful.best, Brian Original Message From: Scott Burnell <Scott. Burnel@nrc.gov>
 
To: Joey. Ledford@nrc.gov, Roger.Hannah@nrc.gov, BRIAN WINGFIELD (BLOOMBERG/
Thanks.
NEWSROOM:)
Roger/Joey: If you can help out at all, I'd be grateful.
At: 9/15 16:48:23 Hi Brian;I've asked Eric and Jack for their availability, but perhaps the folks in Atlanta who are running the North Anna inspection might be a decent alternative?
best, Brian Original Message From: Scott Burnell <Scott. Burnel@nrc.gov>
Roger and Joey would be able to help you there. Thanks.Scott Sent from an NRC Blackberry Scott Burnell-..
To: Joey. Ledford@nrc.gov, Roger.Hannah@nrc.gov, BRIAN WINGFIELD (BLOOMBERG/ NEWSROOM:)
Original Message From: BRIAN WINGFIELD, BLOOMBERG/
At: 9/15 16:48:23 Hi Brian; I've asked Eric and Jack for their availability, but perhaps the folks in Atlanta who are running the North Anna inspection might be a decent alternative? Roger and Joey would be able to help you there. Thanks.
NEWSROOM:  
Scott Sent from an NRC Blackberry Scott Burnell-..
<bwingfield3@bioomberg.
Original Message From: BRIAN WINGFIELD, BLOOMBERG/ NEWSROOM: <bwingfield3@bioomberg. net>
net>To: Burnell, Scott Sent: Thu Sep 15 16:43:38 2011  
To: Burnell, Scott Sent: Thu Sep 15 16:43:38 2011


==Subject:==
==Subject:==
interview request Scott, Would Eric Leeds or Jack Grobe be available for a phone interview tomrorrow to talk about NRC review of North Anna and GI-199? I'm planning a story for next week and would like to get fresh comment from NRC staff if possible.My schedule is open tomorrow.Thanks, Brian Brian Wingfield Bloomberg News 1399 New York Ave., NW Washington, D.C. 20005 202-654-7318 offtie (b)(6) ell 4}}
interview request Scott, Would Eric Leeds or Jack Grobe be available for a phone interview tomrorrow to talk about NRC review of North Anna and GI-199? I'm planning a story for next week and would like to get fresh comment from NRC staff if possible.
My schedule is open tomorrow.
Thanks, Brian Brian Wingfield Bloomberg News 1399 New York Ave., NW Washington, D.C. 20005 202-654-7318 offtie (b)(6)             ell 4}}

Latest revision as of 09:41, 12 November 2019

Email from P. Boyle, NRR to M. Khanna, NRR Action Today: Interview Request
ML12038A251
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 09/16/2011
From: Patrick Boyle
Office of Nuclear Reactor Regulation
To: Meena Khanna
Office of Nuclear Reactor Regulation
References
FOIA/PA-2011-0357
Download: ML12038A251 (4)


Text

Boyle, Patrick IQ From: Boyle, Patrick Sent: Friday, September 16, 2011 2:43 PM To: Khanna, Meena

Subject:

RE: ACTION today: RE: interview request This is well beyond the scope of my normal duties, knowledge area and expertise. My first thought was to not respond. However, I decided to make a good faith effort with the understand management will thoroughly scrub my responses. These are great Q's and A's for the communication plan. See my responses in RED The first question has me on thin ice since I have not seen the AIT report and the Region really has the call on if the licensee is doing enough inspections. The second question already has the answer that-the NRC will not speculate since we have not received and evaluated the report from the licensee. I believe Dominion has adjusted their readiness date as well. The third question is addressed by issuing an order that outlines what must be completed prior to restart. The order will be informed by the AIT and the Dominion re-start readiness report with input from the appropriate NRR Technical, staff RES staff, NRO experts, and Region Support.

Original


Message----

From: Khanna, Meena Sent: Friday, September 16, 2011 1:57 PM To: Boyle, Patrick

Subject:

FW: ACTION today: RE: interview request Original


Message---

From: Khanna, Meena Sent: Friday, September 16, 2011 1:52 PM To: Manoly, Kamal

Subject:

FW: ACTION today: RE: interview request Original


Message----(* 'ý From: McCoy, Gerald \\'-

Sent: Friday, September` 16, 2011 1:08 PM To: Khanna, Meena

Subject:

RE: ACTION today: RE: interview request I'm not sure these are really questions best addressed by the region.

Gerald J. McCoy Chief, Reactor Projects Branch 5 Division of Reactor Projects, Region 2 United States Nuclear Regulatory Commission Office: 404-997-4551

--- Original Message-----

From: Khanna, Meena Sent: Friday, September 16, 2011 1:07 PM Information in this record was deleted To: Franke, Mark; McCoy, Gerald in accordance witp the Freedom of Information i Act, exemptions W F01A. -CJ3 _

Subject:

FW: ACTION today: RE: interview request Mark and Gerry, could we pIs discuss the questions below and draft some responses, together, if possible. I will call Scott to see when this needs to be completed.. .thanks!

Meena


Original Message-rr-From: Howe, Allen \I\q" Sent: Friday, September 16, 2011 12:45 PM To: Khanna, Meena; Wilson, George Cc: Wert, Leonard; Glitter, Joseph

Subject:

ACTION today: RE: interview request Meena/George - lets caucus and get back to Scott. We will need to involve RII.

Allen Message---- r'

-Original From: Guitter, Joseph \,.\"

Sent: Friday, September 16, 2011 12:26 PM To: Howe, Allen Cc: Khanna, Meena; Wilson, George; Wert, Leonard

Subject:

FW: interview request Importance: High Pat is out today and I just saw this. When do you think we will be able to get back to Scott? I think we should point them to the AIT report for the response to the first question. My initial thoughts on some of the other questions are indicated in brackets. Do we have enough detail in our communications plan at this point to answer the questions? I'm guessing not.

--- Original Message---- ,q.-

From: Burnell, Scott \iJ "

Sent: Friday, September 16, 2011 9:28 AM To: Guitter, Joseph; Hiland, Patrick

Subject:

FW: interview request Importance: High Joe, Pat; I just need quick answers to these. If I recall correctly, we're still waiting for Dominion's formal submissions before we determine the need for any additional questions, and Jack was pretty clear that we're not going to be in a position to approve restart by the 22nd. Thanks.

Scott


Original Message-----

From: BRIAN WINGFIELD, BLOOMBERG/ NEWSROOM: [1]

Sent: Friday, September 16, 2011 9:24 AM To: Burnell, Scott; Ledford, Joey, Hannah, Roger

Subject:

RE: interview request Sure. A few of my questions:

1. Is the NRC satisfied that Dominion's inspections so far are sufficient? Is NRC concerned that Dominion is doing too many visual inspections, particularly regarding spent fuel? How does NRC guarantee that 2

Dominion's inspections are satisfactory? [Refer to the AIT report.] I have not seen the AIT report. The response to this question should be informed by that report. In answer to the press we can state that the NRC has an interest in additional inspections, such as ultrasonic testing or dye penetrate tests that would be more revealing than a visual inspection. I do not know if those have been done or are planned. However, the NRC has not fully assessed the testing and the restart inspection team will make that determination.

2. Dominion says it will have Unit 1 "physically" ready for re-start by Sept. 22? Is that too ambitious? What is a likely re-start timeframe? (Even a ballpark estimate is OK.) [Don't think we should speculate on this other than to say that even ifthe licensee is physically ready, NRC will need time to complete its review, It is premature to estimate what that time will be until we have fully evaluated the licensees restart readiness review. In other words, the NRC starts its review once the licensee says that it is ready. How long it takes depends on how long it will take to respond to NRC questions.) It is possible for Dominion to complete its scope of tests demonstrating that the equipment needed for operations is capable of operating in accordance with its current licensing basis by a time near September 22nd. The question that remains is what additional testing that should be done prior to restart and the NRC has not made this determination yet. Dominion must demonstrate to the NRC that the plant is safe to operate so the NRC cannot state a timeframe. It is dependent on the requirements and resources Dominion dedicates to the effort. (not for public disclosure, but even if we knew exactly when the plant would restart, that information would be privileged to the licensee, similar to outage planning details).
3. From NRC's perspective, what happens in the process after Dominion says the plant is ready to re-start?

(I.e. what needs to happen from a regulatory perspective?) [ See above. Discuss letter that we expect from Dominion and key elements of the restart plan.] the NRC will issue an order stating what conditions are required prior to the plant returning to operations. This will be based in part on the letter to the NRC stating the planned and completed tests, analysis and inspections performed at the plant and the NRC staff's evaluation of those tests, analyses, and inspections.

4. Dominion has said North Anna is the "test case" for GI-1 99. Do you agree? How important is the North Anna review to the entire GI-199 process? Could the GI-199 process delay re-start for North Anna?
5. It may take a year or more--please correct me if I'm wrong here-to update seismic risks at nuclear plants as part of the G1-199 process. Ifthat's the case, how does NRC know the seismic analysis at North Anna, which is now ongoing, is going to be sufficient?
thanks, Brian Message -----

-Original From: Scott Burnell <Scott.Burnell@nrc.gov>

To: Joey.Ledford@nrc.gov, Roger.Hannah@nrc.gov, BRIAN WINGFIELD (BLOOMBERG/ NEWSROOM:)

At: 9/16 8:24:20 Brian; Can you give us a better idea of what you'd like to cover? That'll help us figure out who's best-equipped to answer. Thanks.

Scott


Original Message -----

From: BRIAN WINGFIELD, BLOOMBERG/ NEWSROOM: [2]

Sent: Thursday, September 15, 2011 4:49 PM To: Burnell, Scott; Ledford, Joey; Hannah, Roger

Subject:

Re: interview request 3

Thanks.

Roger/Joey: If you can help out at all, I'd be grateful.

best, Brian Original Message From: Scott Burnell <Scott. Burnel@nrc.gov>

To: Joey. Ledford@nrc.gov, Roger.Hannah@nrc.gov, BRIAN WINGFIELD (BLOOMBERG/ NEWSROOM:)

At: 9/15 16:48:23 Hi Brian; I've asked Eric and Jack for their availability, but perhaps the folks in Atlanta who are running the North Anna inspection might be a decent alternative? Roger and Joey would be able to help you there. Thanks.

Scott Sent from an NRC Blackberry Scott Burnell-..

Original Message From: BRIAN WINGFIELD, BLOOMBERG/ NEWSROOM: <bwingfield3@bioomberg. net>

To: Burnell, Scott Sent: Thu Sep 15 16:43:38 2011

Subject:

interview request Scott, Would Eric Leeds or Jack Grobe be available for a phone interview tomrorrow to talk about NRC review of North Anna and GI-199? I'm planning a story for next week and would like to get fresh comment from NRC staff if possible.

My schedule is open tomorrow.

Thanks, Brian Brian Wingfield Bloomberg News 1399 New York Ave., NW Washington, D.C. 20005 202-654-7318 offtie (b)(6) ell 4