ML18039A213
| ML18039A213 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 12/23/1997 |
| From: | Abney T TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18039A214 | List: |
| References | |
| TAC-M96431, TAC-M96432, TAC-M96433, NUDOCS 9801050320 | |
| Download: ML18039A213 (24) | |
Text
Enclosure ITS Section 3.7 Plant Systems Enclosure Contents
~ Response to NRC questions
~ Summary Description of ITS/ITS BASES Changes
~ ITS Revised Pages
~ ITS Bases Revised Pages
~ CTS Mark-up Revised Pages
~ Justifications for Changes to CTS (DOCs) Revised Pages
~ NUREG-1433 BWR/4 STS Mark-up Revised Pages
~ NUREG-1433 gWR/4 STS BASES Mark-up Revised Pages
~ Justification for Changes to NUREG-1433 (JDs) Revised Pages
~ No Significant Hazards Considerations Revised Pages
~ Cross-Reference Matrix Correlating Changes Between the CTS, ITS, and NUREG-1433.
ITS SECTION 3.7.1 RESIDUAL HEAT REMOVAL SERVICE WATER (RHRSW)
SYSTEM ITEM 3.7.1-1A CTS 3.5.C.1 and 3.5.C.2 specify Actions for the RHRSW pumps and not for the RHRSW subsystems. ITS 3.7.1 deletes the separate Actions for the pumps and includes pumps with the Actions for the RHRSW subsystems in REQUIRED ACTION A and then defaults to only reference the RHRSW subsystems in the other REQUIRED ACTION statements. STS 3.7.1 includes Actions for the RHRSW pumps and Actions for the RHRSW subsystems. The change is based on the facility having four redundant loops; and servicing three units. While redundancy exists, ITS 3.7.1 Actions deviate from the STS and CTS Actions. Provide a justification for deviation from the CTS limits. The CT for one subsystem inop seems excessive, justify. Why have 7-day AOTs been eliminated?
CTS table not fully or accurately reflected in ITS. This change is less restrictive, not Admin.
TVA RESPONSE Subsequent to the ITS submittal, it was determined that CTS did not ensure the required number of operable RHRSW pumps were availab1e for all plant conditions. This condition was reported in Licensee Event Report 50-259/97004. A separate CTS/ITS submittal (TS-395), which includes a general revision to ITS 3.7.1, is being made to remedy this problem.
We believe that the changes to the REQUIRED ACTIONS in the subject revision will also address this NRC comment.
ITEM 3.7.1-2A CTS 3.5.CD 1 requires Actions for the RHRSW pumps and not for the RHRSW subsystems. The ITS deletes the separate Actions for the pumps and includes pumps with the Actions for the RHRSW subsystems in Action A and then defaults to RHRSW subsystems in the other REQUIRED ACTION statements. ITS 3.7. 1 Actions deviate from the CTS and STS Actions. To compensate NOTES 1 6 2 are added, and are conditions/
requirements without action or CTs. It appears that NOTES 1
& 2 are inadequate substitutes for mods to the conditions.
NOTE 2 is inadequate even as is; it applies in conjunction with NOTE 1, and this is not apparent. Provide justification for these deviations from the CTS. This change is less restrictive, not Admin.
ITS SECTION 3.7.1 RESIDUAL HEAT REMOVALSERVICE WATER (RHRSW)
SYSTEM TVA RESPONSE See the response to item 3.7.1-1A. The TS-395 submittal should resolve this comment, since the change deletes NOTES 1 and 2 and changes the REQUIRED ACTION statements in ITS 3.F 1.
ITEM 3.7.1-3 CTS 3.5.1 Table 3.5-1 requires a total of five and seven OPERABLE RHRSW pumps with two and three units fueled respectively. ITS 3.7.1 changes the required number of RHRSW pumps for two and three unit fueled operations to three and four respectively. This change is based on the CTS 3.5.1. Table 3.5-1, being overly conservative since the required number of pumps with two and three units fueled is in excess of what is needed to provide worst-case single failure protection. The justification is not clear that these changes agree with the assumptions made for the safety analyses. Provide additional discussion and justification that demonstrates this change is within the safety analyses.
TVA RESPONSE See the response to item 3.7.1-1A. The TS-395 submittal should resolve this comment, since the change makes the ITS requirements match the new CTS which agree with the safety analyses.
ITEM 3.7.1-4 CTS 3.5.C, Table 3.5-1, provides a 30-day allowed outage time based on the availability of equipment in excess of normal redundancy requirements and the low probability of an event occurring during the 30-day period. CTS 3.5.C requires a total of four and six OPERABLE pumps (for the two unit and three unit fueled configuration). ITS 3.7.1 reduces the number of RHRSW pumps required OPERABLE when two or three units are fueled to three and four pumps respectively, yet retains the AOT of 30 days. The change is based on three unit fueled configuration worst-case single failure. being the failure of the DG or 4KV shutdown board which supplies power to the suppression pool cooling return line valve on the accident unit. The justification is not clear that this change agrees with all the assumptions made in the safety analyses.
ITS SECTION 3.7.1 RESIDUAL HEAT REMOVALSERVICE WATER (RHRSW)
SYSTEM ITEM 3. 7. 1-4 (continued)
Provide additional .discussion and justification that demonstrates this change is within the safety analyses; specifically address the CT of 30 days (vs 7 days in the STS).
TVA RESPONSE See the response to item 3.7.1-1A. The TS-395 submittal should resolve this comment, since the change makes the ITS requirements match the new CTS which agree with the safety analyses.
P ITS SECTION 3.7.2 EMERGENCY EQUIPMENT COOLING WATER (EECW) SYSTEM AND ULTIMATEHEAT SINK (UHS)
ITEM 3.7.2-1A STS 3.7.2 includes Actions for the (EECW) pumps and Actions for the (EECW) subsystems. CTS 3.5.C.1 and 3.5.C.2 require Actions for the (EECW) pumps and not for the subsystems.
The ITS deletes the separate Actions for the pumps and references pumps with the Actions for the subsystems in CONDITION A and then defaults to referencing the subsystems in the other Action statements. The change is based on the facility having four redundant RHRSW loops; and servicing three units. While redundancy exists, ITS 3.7.2 Actions deviate from the STS and CTS Actions. Provide a justification for deviating from the CTS limits. The CT for one subsystem inop seems excessive, justify. Why have 7-day AOTs been eliminated? CTS table not fully or accurately reflected in ITS. This change is Less Restrictive, not Admin.
TVA RESPONSE There are 12 RHRSW pumps at BFN which provide service for all three units. Of these, four pumps can be aligned only to the EECW function, four pumps can be aligned only to the RHRSW function, and the remaining four pumps can be aligned to either function. These pumps are referred to as "swing" pumps.
CTS contains a table (Table 3.5-1) which includes both the RHRSW function and the EECW function. ITS separates these into two separate specifications, 3.7.1 (RHRSW) and 3.7.2 (EECW). This separation is further complicated by the fact that the CTS table allows substitution of one function for the other, as long as the total number of pumps available remained constant (utilizing the cross-connect feature of the four swing pumps). As explained in DOC M3, this flexibility was purposely not carried over into ITS, since it was difficult to translate into NUREG-1433 format.
CTS requires that three EECW pumps be operable for no action completion time to be applicable. This is consistent with ITS LCO 3.7.2. The 30-day CTS Table 3.5-1 completion time was deleted from ITS as explained in the paragraph above and documented as a more restrictive change, DOC M3. The 7-day completion times in CTS Table 3.5-1 require two EECW pumps operable and are consistent with ITS 3.7.2 ACTION A.
Therefore, the pump requirements for the various completion times in CTS and ITS are the same, except as discussed in DOC Ll and DOC M3. So this change is appropriately classified as administrative.
ITS SECTION 3.7.2 EMERGENCY EQUIPiVIENT COOLING WATER (EECW) SYSTEiM AND ULTIMATEHEAT SINK (UHS)
TVA RESPONSE (continued)
While Note (A) of CTS Table 3.5-1 was not carried forward to ITS, it was identified as a less restrictive change and is adequately explained in DOC L1.
The references to subsystems are being deleted from ITS 3.7.2 (and associated bases) and replaced with terms which are more descriptive of the BFN specific design characteristics (e.g. system, pumps, loops). This is because the BFN minimum design requirements are two EECW pumps (either both from the same header or one from each header), which would require a minimum of three pumps to accommodate a single failure. DOC A3 and justification P2 have likewise been revised to remove reference to "subsystems".
ITEM 3.7.2-2A CTS 3.5.C Note (A) to CTS Table 3.5-1 requires that at least one OPERABLE pump be assigned to each header. The design criteria does not require an OPERABLE pump from each header.
ITS 3.7.2 is::~less restrictive in that it does not require the two subsystems (pumps) to be from separate headers.
Either two pumps on one header or one pump on each header are capable of providing the required cooling to safety related components on the three units. The justification for A3 states that RHRSW pumps can be aligned for EECW service. It appears the CTS Table 3.5-1 indirectly addresses RHRSW-EECW cross-connect capability. Is there a cross-connect capability? If so, how is that reflected in the ITS?
TVA RESPONSE As explained in the response to 3.7.2-1A, EECW has a cross-connect capability associated with four RHRSW pumps. These four pumps can be aligned for RHRSW or EECW service, but can only be aligned for service to either EECW or RHRSW at one time (i.e., they cannot be aligned for both EECW and RHRSW service simultaneously). This capability is reflected in CTS Table 3.5-1 in the 30-day action times. For the EECW function, the 30-day CTS Table 3.5-1 completion time was deleted from ITS as explained in response to item 3.7.2-1A and was documented as a more restrictive change, DOC M3.
Regarding Note (A) of CTS Table 3.5-1, it was not carried forward to ITS, but was identified as a less restrictive change and adequately explained in DOC Ll. See the response to item 3.7.2-1A for additional details.
ITS SECTION 3.7.2 EMERGENCY EQUIPMENT COOLING WATER (EECW) SYSTEM AND ULTIMATEHEAT SINK (UHS)
ITEM 3.7.2-3A CTS 4.5.C.l.a requires testing the RHRSW pumps assigned to automatic service on the EECW headers each time the diesel generators are tested. ITS SR 3.7.2.3 requires verifying each required EECW pump actuates on an actual or simulated initiation signal. The ITS changes the surveillance frequency to every 18 months. Also, it is not clear that the diesel generator testing specified in the CTS is comparable to the testing required in the ITS. This change appears to be a less restrictive change. The change in SR frequency is not addressed. Provide justification for the new SR frequency. Provide a justification for changing the testing method.
TVA RESPONSE Since the EECW system provides cooling to the diesel generators, selected EECW pumps will automatically start whenever the diesel generators are started, if they are not already running. Proposed ITS SR 3.7.2.3 will require all automatic start signals for the EECN pumps to be tested every 18 months.
Since the operations staff routinely verifies all required EECW pumps start (if not already running) whenever the diesel generatorschangers are started, the CTS requirement is more accurately considered an operational requirement. However, we agree that the CTS requirement is not a specific requirement in ITS, therefore we have re-categorized the change as less restrictive and a new DOC L3 has been added to justify the ITEM 3.7.2-4A In the ITS the CT for restoring an inoperable EECN pump is 7 days, vs 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in the STS. The extended CT justification is based upon the 7-day CT for restoring an inoperable DG.
The 7-day CT for a DG is a deviation from the STS. The CT for the EECW pump is based upon the CT for the supported DG (both CTs are deviations from the STS). If the DG CT remains 7 days, then the EECW pump CT can remain 7 days.
TVA RESPONSE The DG completion'time (CT) in ITS 3.8.1 will remain 7 days to be consistent with CTS. Therefore, the EECW pump CT will remain 7 days.
ITS SECTION 3.7.2 EMERGENCY EQUIPNIENT COOLING WATER (EECW) SYSTEM AND ULTIMATEHEAT SINK (UHS)
ITEM 3.7.2-5A CTS 3.2.B requirements for RHRSW (EECW) pump timers, located in CTS Table 3.2.B/4.2.B, are included in the ITS Requirements, Actions, and 1TS 3.7.2 SRs for "EECW System and UHS." ITS SR 3.7.2.3 ensures the pump actuates on an actual or simulated signal and includes a test of the EECW timer function. The details of that test are moved to plant procedures. Changes to procedures are controlled by the licensee controlled programs. The plant procedures and control process is not identified. Provide identification of the procedures and change control process.
TVA RESPONSE The CTS 3.2.B specific timing requirements for EECW pump timers will be located in the Technical Requirements Manual (TRM). The actual test of the timers will be part of proposed SR 3.7.2.3.
The Bases of ITS SR 3.7.2.3 have been revised to be more specific on this item and DOC LA3 has been revised to clarify this, disposition. Changes to the BASES will be controlled by the Bases Control Process described in ITS Section 5.5.10. Changes to the TRM are governed by the 10 CFR 50.59 process.
ITS SECTION 3.7.3 CONTROL ROOM EMERGENCY VENTILATION(CRE<V)
SYSTEM ITEM 3.7.3-1A CTS 4.7.E.4 requires verifying the dampers listed in CTS Table 4.2.G operated properly during a simulated system automatic actuation test. ITS 3.7.3 moves the details relating to methods of performing the SR to the ITS Bases or plant procedures. Changes to the Bases are controlled by the provisions of the ITS Bases Control Process in ITS Chapter 5.10. Changes to the procedures are controlled by the licensee controlled programs. It is not clear where the details are moved to (Bases or Procedures) and what controls are used to control changes to the requirements. Provide a discussion and justification of where the requirements are moved to and how changes to these requirements are controlled.
TVA RESPONSE ITS SR 3.7.3.3 verifies that on an actual or simulated initiation signal, each CREV subsystem starts and operates.
The dampers associated with proper CREV operation. would be considered peart of the CREV subsystem and would be tested under SR 3.7.3.3. However, in response to the NRC concern, the SR 3.7.3.3 BASES will be revised to specifically indicate that dampers associated with proper CREV operation will be checked as part of SR 3.7.3.3. Changes to the Bases are controlled in accordance with ITS 5.5.10 and reviewed for 10 CFR 50.59 applicability.
ITS SECTION 3.7.4 CONTROL ROOM AIR CONDITIONING (AC) SYSTEM ITEM 3. 7. 4-1 ITS 3.7.4 is added that was not included in the CTS. ITS 3.7.4 implements Actions for the Control Room Air Conditioning (AC) system. While implementi'ng the Control Room AC System requirements, ITS 3.7.4 modifies the STS 3.7.5 Actions to include a new condition B and then deletes the STS 3.7.5 Conditions D and E. Adding Condition B and deleting STS Conditions D and E takes credit for additional Air Conditioning systems that are available at the site. By including ITS 3.7.4 Condition D, when there are two inoperable control room air conditioning subsystems, the plant has 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to place an alternate air conditioning system in operation and 7 days to return one system to operation. It is not clear that these additional air conditioning systems are suitable substitutes, from a safety standpoint, as the Control Room AC Systems. It is not clear that the system design and the requirements specified in the FSAR are met by the ITS. Provide discussion and justification for deviating from the STS. Are BFN Units 1, 2, & 3 reflected in ITS, It seems unit 3 is neglected?
Would Unit 3 have Condition B?
TVA RESPONSE Unit
'he BFN 1 and 2 control rooms are in a common large room and are cooled by two 100% capacity air handling units located on the east side of the control building (Unit 1 side). The Unit 3 control room is in a separate room from the Units 1/2 control room and is located on the opposite side of the control building. The Unit 3 control room is cooled by two separate 100% capacity air handling units located on the west side of the control building (Unit 3 side). The Unit 1/2 control room is connected to the Unit 3 control room by a hallway. The relay room (located between the Unit 1/2 and the Unit 3 control rooms) also has two safety-related air handling units associated with it.
If normal cooling is lost to the Unit 1/2 (or Unit 3) control room, cooling can be provided from the Unit 3 (or Unit 1/2) cooling units, or the relay room air handling units by altering the ventilation lineup. There are also additional cooling sources available (e.g. emergency chiller, temporary ventilation, etc.) such that loss of both air handling units for a specific control room is not as significant as the model NUREG-1433 BWR-4 plant.
ITS SECTION 3.7.4 CONTROL ROOM AIR CONDITIONING (AC) SYSTEM TVA RESPONSE (continued)
From a safety significance standpoint, BFN has addressed the loss of cooling to the main control rooms in the Multi-Unit PSA (submitted to NRC on April 14, 1995) and concluded, loss of cooling to the main control room is risk insignificant".
Based on the above discussion, the addition of BFN ITS Section 3.7.4 CONDITION B and deletion of STS section 3.7.5 CONDITIONS D and E are appropriate for the BFN design due to the ready availability of alternate air conditioning systems. As noted in DOC Ml for BFN ITS 3.7.4, this is a new specification not currently required by CTS and, hence, is a more restrictive change. The STS ACTIONS and CONDITIONS were modified to be consistent with the BFN specific HVAC design features.
BFN Units 1, 2, and 3 are adequately reflected in ITS and CONDITION B for Unit 3 is appropriate for BFN ~
10
ITS SECTION 3.7.6 SPENT I<UEL STORAGE POOL WATER LEVEL ITEM 3.7.6-1A ll ~
CTS 3.10 AC includes Actions and Surveillance Requirements for spent fuel pool water temperature and chemistry. ITS 3.7.6 moves these requirements to plant controlled documents. The spent fuel pool water temperature and chemistry requirements are moved to plant procedures and/or program governing fuel pool temperature and chemistry restrictions. While this change is consistent with the STS, the procedures were not identified. Provide a justification that describes the procedures that include the spent fuel pool water temperature and chemistry controls.
TVA RESPONSE The CTS 3/4.10.C.2 and 3/4.10.C.3 requirements will be relocated to the TRM. Changes to the 'TRM are governed by the 10 CFR 50.59 process. DOC R1 has been modified to clarify this disposition.
ITEM 3.7.6-2A CTS 4.10.C.l includes details on performing the spent fuel pool water 14vel Surveillance Requirement. ITS 3.7.6 moves the details relating to methods of performing Surveillance Requirements to the Bases or procedures. Changes to the procedures are controlled by the licensee controlled programs. The specific plant procedures and change control process were not identified. Provide a justification that describes the procedures and the controls on changes to the procedures.
TVA RESPONSE The spent fuel pool low level alarm is monitored continuously in each unit control room by alarm XA-78-51, "Fuel Pool System Abnormal". The Alarm Response Procedures (1-ARP-9-4 (Unit 1); 2-ARP-9-4C(Unit 2); and 3-ARP-9-4C (Unit 3)) associated with this alarm requires actions to check the spent fuel pool weir settings and add make-up water if the alarm is valid. Changes to the Alarm Response Procedures are governed by plant administrative procedures, which include a review for 10 CFR 50.59 applicability.
11
0 ITS SECTION 3.7.7 MAINCONDENSER OFFGAS ITEM 3. 7. STS6-1 The 1TS does not include STS 3.7.6. The STS requirement is deleted because it is not included in the CTS and plant experience found the condenser offgas release rate low enough that there is not a problem. Past performance is not an indication of future acceptability. Further, deleting this STS requirement is not justified based on plant design or operational constraints. Provide a discussion and justification for deviating from the STS based on a discussion of applicability of TS Criteria listed in 10CFR50.36(c).
TVA RESPONSE As stated in the STS APPLICABLE SAFETY ANALYSIS section, "The main condenser offgas limits satisfy Criterion 2 of the NRC Policy Statement". Criterion 2 is concerned with a process variable, design feature, or operating restriction that is an initial condition of' Design Basis Accident (DBA) or transient analysis that assumes' failure of or presents a challenge to the integrity of a fission product barrier. A Main Condenser Offgas System failure event described in-'the STS APPLICABLE SAFETY ANALYSIS is neither a DBA or transient analysis described in the BFN FSAR Chapter 14, Plant Safety Analysis, and, therefore, does not satisfy Criterion 2 of the NRC Policy Statement for BFN. Since this event is not part of the current BFN design or licensing basis, and is not covered by CTS, include STS 3.7.6 in BFN ITS.
it is not appropriate to 12
SUMMARY
DESCRIPTION of ITS CHANGES ITS SECTION 3.7 TVA is submitting a proposed supplement to TS-362 for Section 3.7, PLANT SYSTEMS. This supplement makes several changes associated with NRC comment's on Section 3.7
(
Reference:
NRC Request for Additional Information Regarding Improved Standa'rd Technical Specifications, dated June 12, 1997, TAC NOS. M96431, M96432, M96433), incorporates changes resulting from internal TVA reviews, and incorporates Owner's Group Technical Specification Task Force (TSTF).items approved by NRC subsequent to the original submittal of TS-362. A synopsis of the ITS changes is provided below.
ITS 3.7.1 and BASES ITS 3.7.1 and the associated BASES have been extensively revised to correct a non-conservatism in CTS related to the number of RHRSW pumps required to be operable. This change is being submitted separately as TS-395 as a beyond scope change.
SR 3.7.2.2 The references to a "subsystem" are being deleted'and replaced with terms which are more descriptive of the BFN specific design characteristics (e.g., system, pump, loop).
This change is being made in response to an NRC comment.
SR 3.7.3.4 and Associated BASES In SR 3.7.3.4 and the associated BASES, added "on a STAGGERED TEST BASIS" to the frequency. These changes were made as a result of an internal TVA review and are based on operational experience This change is consistent with NUREG-1433.
LCO 3.7.5 and Associated BASES Incorporated Average Planar Linear Heat Generation Rate (APLHGR) correction. factor for an inoperable main turbine bypass system. The limits will be listed in the Core Operating Limits Report (COLR). Discussions with the fuel vendor indicate that an APLHGR adjustment factor will likely be needed for future core reloads in a manner similar to that in LCO 3.7.5 for Minimum Critical Power Ratio (MCPR).
ITS 3.7.2, A licable Safet Anal ses BASES Corrected reference numbers to correct typographical error.
These changes were made based on an internal TVA review.
Page 1
SUMMARY
DESCRIPTION of ITS CHANGES ITS SECTION 3.7 SR 3.7.2.3 BASES Added a requirement that the SR include a functional test of the initiation logic and EECW pump timers, and a calibration of the EECW pump timers. This change is in response to an NRC comment.
3.7.3, Back round BASES Revised to clarify system flow paths. Specific changes make clear that the HEPA filter bank is in a suction line common to both trains and that the system has an inlet separate from the normal ventilation system. These changes were made based on an internal TVA review.
3.7.3, A licable Safet Anal ses BASES Revised to clarify system operation. Specific changes make clear that the source of air is outside air and that the system does not recirculate air. These changes were made based on an internal TVA review.
3.7.3 BASES Deleted all references to Regulatory Guide 1.52 to match a change previously made to ITS Section 5.5.7, Ventilation Filter Testing Program. These changes were made based on an internal TVA review.
SR 3 ' '.3 BASES Added a requirement to verify that dampers necessary for CREV operation function as required. This change is in response to an NRC comment. Corrected references to other SRs.
SR 3.7.3.4 BASES Clarified that the'est will verify that the system will maintain a positive pressure in the control room with respect to outdoors, rather than other areas of the plant.
This change is in response to an NRC comment.
3.7.4, Back round BASES Revised to clarify the components which make up the Control Room Air Conditioning System. These changes were made based on an internal TVA review.
Page 2
SUMMARY
DESCRIPTION of ITS CHANGES ITS SECTION 3.7 3.7.4, LCO BASES Revised to clarify the components which make up the Control Room Air Conditioning System. These changes were made based on an internal -TVA review.
3.7.6, A licable Safet Anal ses BASES Corrected reference to NRC Policy Statement criteria to incorporate a generic change (TSTF-139) to NUREG-1433.
The following changes affect the Unit 3 BASES only:
3.7.4, Back round BASES Deleted the Emergency Chiller as an alternate means of cooling the Unit 3 control room. This change was made based on an internal TVA review and reflects actual plant design.
3.7.4, Actions B.l, B.2.1, B.2.2 BASES Deleted the Emergency Chiller as an alternate means of cooling the Unit 3 control room. This change was made based on an internal TVA review and reflects actual plant design.
PQgc 3
0 BROKVNS FERRY NUCLEAR PLANT - IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.7 LIST OF REVISED PAGES UNIT I ITS (Revised pages marked *Rl)
NOTE: Section 3.7.1 is not included. A beyond scope change (TS-395) is being submitted separately, which revises all of that section.
Replace pages 3.7-4 through 3.7-15 with pages 3.7-6 Rl through 3.7-18 Rl.