ML20249B504

Forwards Request for Addl Info on Proposed License Amend to Convert Current TS for Wolf Creek Nuclear Generating Station,Unit 1 to Improved Standard TS

ML20249B504
Person / Time
Site:	Wolf Creek
Issue date:	06/17/1998
From:	Thomas K NRC (Affiliation Not Assigned)
To:	Maynard O WOLF CREEK NUCLEAR OPERATING CORP.
References
TAC-M98738, NUDOCS 9806230234
Download: ML20249B504 (17)

Text

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June 17, 1998 Mr. Otto L. Maynard President end Chief Executive Officer  !

Wolf Creek Nuclear Operating Corporation l Post Office Box 411 Burlington, Kansas 66839

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION ON THE PROPOSED l

CONVERSION TO THE IMPROVED STANDARD TECHNICAL )

SPECIFICATIONS FOR WOLF CREEK NUCLEAR GENERATING j STATION, UNIT NO.1 (TAC NO M98738) l

Dear Mr. Maynard:

i The Nuclear Regulatory Commission steff is reviewing the Wolf Creek Nuclear Operating Corporation's proposed license amendment to convert the current technical specifications for Wolf Creek Nuclear Generating Station, Unit No.1 to the Improved Standard Technical Specifications. Wolf Creek Nuclear Operating Corporation provided their proposed license amendment request by letter dated May 15,1997.

The staff has reviewed selected portions of the application. Based on its review, the staff has determined that additional information is needed in Section 3.1, Reactivity Control Systems and Section 3.2, Power Distribution Limits, as discussed in the enclosure. Since you worked with three other utilities in preparing your submittal, the enclosure contains the request for additional information (RAI) questions for all four utilities. However, you need only reply to the RAI questions associated with the Wolf Creek Nuclear Generating Station, Unit No.1 as identified in the table within the enclosure.

To assist the staff in maintaining its review schedule,- please respond to the questions pertaining to Wolf Creek Nuclear Generating Station, Unit No.1 within 30 days of the date of this letter. If you have any questions regarding the RAI, please contact me at (301)415-1362. If all four utilities would like to have a common discussion, a single meeting, or phone call, it can be coordinated by contacting the NRR Lead Project Manager, Timothy J. Polich at (301) 415-1038.

Sincerely, ORIGINAL SIGNED BY WILLIAM BATEMAN FOR:

Kristine M. Thomas. Project Manager Project Directorate IV-2 Division of Reactor Projects lil/IV Office of Nuclear Reactor Regulation Docket No. 50-482 DISTRIBUTION:

Docket; OGC \

Enclosure:

Request for,Additionalinformation PUBLIC ACRS k) a; 10 PDIV-2 Reading PGwynn, RIV l EAdensam (EGA1) WJohnson, RIV f o\

cc w/ encl: See next page WBateman WBeckner KThomas EPeyton 9, Document Name: WCITS.RAI NGilles OFC dp42) A PD4-2 TSB DD$

NAME MbaibEN WBeckner Nkb gg ~~*

DATE- 6/h/98 6 /jU/ 98 6 /l1/98 OFFICIAL RE CORD COPY-9906230234 990617 PDR ADOCK 050004 2 a -r

D e Mr. Otto L Maynard June 17, 1998 cc w/ encl:

Jay Silberg, Esq. Chief Operating Officer Shaw, Pittman, Potts & Trowbridge Wolf Creek Nuclear Operating Corporation -

2300 N Street, NW P. O. Box 411 Washington, D.C.- 20037 Burlington, Kansas 66839 Regional Administrator, Region IV Supervisor Lkansing U.S. Nuclear Regulatory Commission Wolf Creek Nuclear Operating Corporation 611 Ryan Plaza Drive, Suite 1000 P.O. Box 411 Arlington, Texas 76011 Burlington, Kansas 66839

! Senior Resident inspector. U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Resident inspectors Office P. O. Box 311 8201 NRC Road Burlington, Kansas 66839 Steedman, Missouri 65077-1032 Chief Engineer Utilities Division Kansas Corporation Commission 1500 SW Arrowhead Road Topeka, Kansas 66604-4027 Office of the Govemor State of Kansas Topeka, Kansas 66612 Attomey General Judicial Center 301 S.W.10th 2nd Floor Topeka, Kansas 66612 County Clerk Coffey County Courthouse Burlington, Kansas 66839 Vick L. Cooper, Chief Radiation Control Program

' Kansas Department of Health and Environment :

Bureau of Air and Radiation Forbes Field Building 283 -

Topeka, Kansas 66620 l

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FOUR LOOP GROUP (FLOG) IMPROVED TS REVIEW COMMENTS

. SECTION 3.1 - REACTIVITY CONTROL SYSTEMS 3.1-1 3.1.1 Ehutdown Margin (SDM)(Wolf Creek & Callaway)

DOC 01-02-M CTS 3/4.1.1 Applicability ITS 3.1.1 Applicability Comment: According to the Conversion Comparison Table,' MODE 2 with Keff < 1.0" and

" MODE 5" are added to the Applicability section of TS 3.1.1 for Wolf Creek and Callaway. All of the FLOG ITS Sections 3.1.1 have these applicability requirements included in the iTS and not in the CTS. An inadaquate Justification for these changes is provided. Provide a discussion explaining / justifying these changes.

FLOG Response:

3.1-2 3.1.1 Shutdown Margin (SDM)(Comanche Peak and Diablo Canyon)

DOC 01-06-A CTS 3/4.1.1 Applicability ITS 3.1.1 Applicability Comment: According to the Conversion Comparison Table, " MODE 2 with Keff < 1.0" and

" MODE 5" are added to the Applicability section of TS 3.1.1 for Comanche Peak and Diablo Canyon. All of the FLOG ITS Sections 3.1.1 have these applicability requirements included in the ITS and not in the CTS. Provide a discussion for Comanche Peak and Diablo Canyon explaining / justifying these changes.

FLOG Response:

3.1-3 3.1.1 Shutdown Margin (SDM)(All FLOG Plants)

DOC 01-10-M CTS SR 4.1.1.1.1 ITS SR 3.1.1.1 l Comment: The justification for modifying applicability of SR 3.1.1.1 is inadequate; it only refers to consistency with NUREG-1431. Also, it is not apparent why this change is not applicable to Wolf Creek and Callaway.

FLOG Response:

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f 3.14 3.1.2 Core Reactivity (Comanche Peak & Diablo Canyon)

DOC 05-06-A JFD 3.1-2 CTS SR 4.1.1.1.2 ITS SR 3.1.2.1 Comment: The note to the core reactivity SR in the STS states that ".. predicted reactivity values may be adjusted (normalized) ...", while the note in the ITS states,".. predicted reactivity values shall be adjusted (normalized) ...". The ITS use of the word "shall" is based upon the CTS use of the word. The Bases supporting this SR adds a parenthetical phrase stating "... normalization (adjustment, only if necessary)...", indicating that the STS wording is preferable. Using the word "shall" implies that an adjustment must always be may, regardless of Qe necessity. Adopt the STS wording to the SR 3.1.2.1 Note.

i FLOG Response:

I 3.1-5 l- 3.1.2 Core Reactivity (Comanche Peak)

ITS Bases 3.1.2 Comment: The ITS Bases pages'have the incorrect title in the page headers (SDM vs Core Reactivity). Correct the headers to ITS Bases 3.1.2.

FLOG Response:

3.1-6 CTS 3/4.1.2 Boration Systems (Comanche Peak and Diablo Canyon)

DOC 06-01-R Comment: The Discussion of Change (DOC) needs to specify where the CTS specification is being relocated. Correct the DOC.

FLOG Response:

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1 3.1-7 .

CTS 3.1.2.2 Flow Parth - Operating (Comanche Peak & Diablo Canyon)

DOC 07-01-R .

Comment: The DOC needs to specify where the CTS specification is being relocated. Correct  !

the DOC A relocated screening form is not provided for this relocated specification.

FLOG Response:

3.14 CTS 3.1.2.3 Charging Pump - Shutdown (Comanche Peak & Diablo Canyon) '

DOC 08-01-R Comment: The DOC needs to specify where the CTS speerfication is being relocated. Correct the DOC.

FLOG Response:

3.14 DCPP SR (on charging pump operability verification) (Diablo Canyon)

DOC 08-02-M Comment: Conversion Comparison Table indicates that the SR on charging pump operability verification is "already in CTS," and the DOC does not specify where. Identify in an updated DOC where the SR is in the CTS and where it will appear in the ITS.

FLOG Response:

3.1-10 ,

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CTS 3.1.2.4 Charging Pump - Operating (Comanche Peak & Diablo Canyon)

DOC 09-01-R ,

Comment: The DOC needs to specify where the CTS specification is being relocated. Correct the DOC.

FLOG Response:

3.1-11 CTS 3.1.2.5 Borated Water Source - Shutdown (Comanche Peak & Diablo Canyon)

DOC 10-01-R Comment: The DOC needs to specify where the CTS specification is being relocated. Correct the DOC.

FLOG Response:

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CTS 3.1.2.5 Borsted Water Source - Operating (Comanche Peak & Diablo Canyon)

DOC 11-01-R Commect: The DOC needs to specify where the CTS specification is being relocated. Correct the D O C.

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FLOG Response:

3.1-13 ITS 3.1.4 Rod Group Alignment Limits (Comanche Peak)

DOC 12-07-A ITS 3.1.4 Bases Comment: The DOC states, for Required Action B.2.6, that "the ITS Bases discuss the accident analysis affected by rod misalignment." The associated Bases do not list the accident analyses that require re-evaluation, similar to that provided by the other Four Loop Group plants. List in the Bases the accident analyses that require re-evaluation.

FLOG Response:

3.1 14 CTS 3.1.3.1 Movable Control Assemblies (Wolf Creek)

DOC 12-12-LS-13 CTS 3.1.3.1, Action 4 Comment: The CTS mark-up applies DOC 12-12-LS-13 to CTS 3.1.3.1 Action 4, which is incorrect. Correct the CTS mark-up/ DOC.

FLOG Response:

3.1-15 ITS 3.1.4 Rod Group Alignment Limits CTS 3/4.1.3 Movable Control Assemblies (All FLOG Plants)

DOC 12-14-M Comment: The ITS has changed the wording of the TS from "trippability" to " operability," and references TSTF-107 which is not yet approved (though it is expected to be approved with the OGs next revision of TSTF-107. The result is that the FLOG plants have inconsistently incorporated generic changes into the Bases (i.e., the Bases paragraphs for B.2.1.1 and B.2.1.2). This change is a less restrictive change in that it precludes LCO 3.0.3 entry for

. unforeseen inoperabilities. TSTF-107 needs to be discussed / approved at the next TSTF OG/NRC Meeting, and the FLOG will then need to incorporate the resulting generic TS l'

requirements.

FLOG Response:'

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-3.1-16 ITS 3.1.4 Rod Group Alignment Limits (All FLOG Plants)

ITS 3.1.4 Bases Generic Changes l

Comment: Generic Bases changes need to be discussedfjustified. For example, the Bases Background discussion on the DRPl system has been revised and needs to be explained.

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FLOG Response:

3.1 17 ITS 3.1.4 Rod Group Alignment Limits (Comanche Peak)

DOC 12-19-LS-18 CTS SR 4.1.3.1.2 (rod motion SR frequency)

. ITS SR 3.1.4.2 Comment: Justification for changing SR frequency must be based upon plant specific reasons (i.e.,~ on operating experience), and not solely on consistency with the STS. Provide adequate justification for changing frequency of control rod motion SR from 31 to 92 days.

FLOG Response:

3.1-18 ITS 3.1.4 Rod Group Alignment Limits (Comanche Peak)

DOC 12-20-A CTS SR 4.1.3.1.3 (rod drop time SR frequency)

ITS SR 3.1.4.3 Comment: In DOC 12-20-A the ITS SR 3.1.4.3 is incorrectly referred to as SR 3.1.5.3.

Correct DOC.

FLOG Response:

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3.1-19 ITS 3.1.7 Rod Position Indication CTS 3.1.3.2 Position Indication Systems - Operating (Wolf Creek ? Callaway)

DOC 13-05-A & 13-09-LS-23 & 13-06-A JFD 3.1-7 & 3.1-12 Comment: The ITS retains Conditions and associated Required Actions from the CTS addressing more than one inoperable digital rod position indicator (DRPI) per group, which is not addressed in the STS. However, not all associated CTS Required Actions have been retained in the ITS; the Required Achons to take manual control of the rods and to record n

reactor coolant temperature every hour have not been retained. These actions, in one case affect rod movement and in the other case provide an indication that the rod (s) position may i

have changed, and therefore have a bearing on SDM and therefore should not be deleted if the overall condition of more than DRPI per group is inoperable is retained. Either retain the CTS requirements completely, adopt the STS requirements, or provide a better Justification for the

. ITS proposals. The STS wording of the note permitting separate condition entry should be l retained with the STS Conditions and Required Actions.

FLOG Response:

3.1 20 ITS 3.1.7 Rod Position Indication CTS 3.1.3.2 Position Indication Systems - Operating (Comanche Peak & Diablo l

Canyon)

DOC 13-08-LS-20 & 13-09-LS-23 & 13-06-A l JFD 3.1-7 & 3.1-12 Comment: The ITS adopts Conditions and associated Required Actions from the Callaway's CTS, addressing more than one inoperable digital rod position indicator (DRPI) per group, which is not adWessed in either the STS or the CTS. Furthermore, not all associated CTS Required Actions have been retained in the ITS; the Required Actions to take manual control of the rods and to record reactor coolant temperature every hour have not been retained. These actions, in one case affect rod movement and in the other case provide an indication that the rod (s) position may have changed, and therefore have a bearing on SDM and therefore should not be deleted if the Callaway condition of more than DRPI per group inoperable is retained.

Either retain the CTS requirements and adopt the STS requirements, or provide a better justification for the ITS proposals of adopting the Callaway CTS requirements. This change is based upon proposed change WOG-73, Rev 1; which eventually may become a TSTF change request. What is the status of WOG-73, Rev 17 The STS wording of the note permitting separate condition entry should be retained with the STS Conditions and Required Actions.

FLOG Response:

3.1 21 CTS 3.1.3.3 Position Indication Systems - Shutdown (Comanche Peak & Diablo Canyon)

DOC 14-01-R Comment: The DOC needs to specify where the CTS specification is being relocated. Correct the DOC. A relocated screening form is not provided for this relocated specification.

FLOG Response:

3.1 22 CTS 3.1.3.4 Rod Drop Time (Diablo Canyon)

DOC 15-01-R Comment: The DOC needs to specify where the CTS specification is being relocated. Correct the DOC. A relocated screening form is not provided for this relocated specification.

FLOG Response:

3.1-23 ITS 3.1.6 Control Bank Insertion Limits CTS 3.1.3.6 Control Rod insertion Limits (Wolf Creek)

DOC 17-04-LS-8 JFD 3.1-3 Comment: Required Action C.1 in the STS, and in the related actions of the CTS and the TS of the other FLOG Plants, all require the plant to enter Mode 3. The ITS Required Action C.1 requires the plant to be placed in Mode 2 with Keff<1. Maintain consistency with the STS and the CTS.

FLOG Response:

3.1-24 ITS 3.1.4 Rod Group Alignment Limite (All FLOG Plants) )

JFD 3.1-5 & 3.1-6 Comment: Rewording of LCO and Condition A approved, contingent upon OG resubmittal of change request TSTF-107 (revision) as discussed with TSTF.

FLOG Response:

3.1-25 ITS 3.1.4 Rod Group Alignment Limits (All FLOG Plants)

JFD 3.1-16 Comment: Inclusion of SR 3.2.1.2 to Required Action B.2.4 is approved; ensure OG submit WOG-105 as a TSTF change request.

FLOG Response: -

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3.1 26 ITS 3.1.8 Physics Tests Exceptions - Mode 2 (Comanche Peak) l JFD 3.1-20 Comment: The Conversion Comparison Table Indicates that this change is applicable to Comanche Peak, however, the STS mark-up does not have it included. Include change in STS mark-up and in ITS.

FLOG Response:

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3.1-27 ITS 3.1.1 Shutdown Margin (All FLOG Plants)

JFD 3.1-18 Comment: This modification adds a Mode change restriction from Mode 6 to Mode 5, as discussed in CN 1-02-LS-1 of 3.0. The discussion pnmded is inadequate to evaluate the necessity of the mode chang; restriction. In general, throughout the submittal, justifications for notes prohibiting mode changes are inadequate. Provide explanations / justifications that j present specific conditions that would necessitate the note.

FLOG Response:

3.1-28 Relocated specifications (All FLOG Plants)

Comment: Comanche Peak, Wolf Creek, and Callaway have not provided relocated screening evaluations / forms for any of their specifications relocated to licensee controlled documents.

Diablo Canyon has not prov!ded relocated screening forms for all of their specifications relocated to licensee controlled documents. Provide necessary relocation screening evaluations #orms.

FLOG Response:

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SECTION 3.1 RAI APPLICABILITY

}

l RAI# DIABLG COMANCHE WOLF CREEK CALLAWAY CANYON PEAK 3.1-1 X X 3.1-2 X X ,

3.1-3 X X X X 3.1-4 X X I i

3.1-5 X 3.1-6 X X 3.1-7 X X 3.1-8 X X 3.1-9 X l 3.1-10 X X 3.1-11 X X 3.1-12 X X 3.1 13 X 3.1-14 X 3.1-15 X X X X 3.1-16 X X X X 3.1-17 X 3.1-18 X 3.1-19 X X 3.1-20 X X 3.1-21 X X 3.1-22 X 3.1-23 X 3.1-24 X X X X 3.1 25 X X X X 3.1-26 X

. 2 1

1 RAI# DIABLO COMANCHE WOLF CREEK CALLAWAY CANYON PEAK 3.1-27 X X X X 3.1-28 X X X X l

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FOUR LOOP GROUP (FLOG) IMPROVED TS REVIEW C@MMENTS

. SECTION 3.2 - POWER DISTRIBUTION LIMITS 3.2 1 ITS 3.2.3 Axial Flux Difference CTS 3/4.2.1 Axial Flux D4ference (Comanche Peak)

DOC 01-05-M l ITS Required Action D.1 Comment: If the required power reduction, resuking from accumulated AFD penalty minutes, is not accomplished within the required completion time, the ITS had a note iequiring a reduction in power to less than 15% RTP regardless whether the AFD was within limits. TSTF- .

112, Rev.1 deleted the note requiring the automatic reduction in power to < 15% RTP.

Review and evaluate TSTF 112, Rev.1, and determine if this TSTF change can be adopted by Comanche Peak.

l FLOG Respo ise:

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3.2-2 ITS 3.2.3 Axial Flux Difference CTS 3/4.2.1 Axial Flux Difference (Diablo Canyon)

DOC 01-07-LG Comment: The DOC / Conversion Comparison Table needs to specify where the CTS requirement is being relocated. Correct the DOC.

FLOG Response:

3.2 3 ITS 3.2.1 Heat Flux Hot Channel Factor CTS 3/4.2.2 Heat Flux Hot Channel Factor (All FLOG Plants)

DOC 02-06-A JFD 3.2-12 ITS SR 3.2.1.1 & 3.2.1.2 Frequency l

Comment: The ITS SR frequency has been changed from the STS frequency of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This is based upon the incorrect justification that the CTS would allow 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> based upon ITS SR 3.0.3, since the CTS does not specify a frequency. Adopt the STS SR frequency of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

FLOG Response:

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L 3.2 4 iTS 3.2.2 Nuclear Enthalpy Rise Hote Channel Factor CTS 3/4.2.3 Nuclear Enthalpy Risc Hot Channel (All FLOG Plants)

DOC 02-07-A JFD 3.2-13 .

SR 3.2.2.1 NOTE and related Bases.

Comment: Justify the need for the nota related to permitting power ascension after shutdown to a level at which a power distribution map is obtained. It appears that this note is unnecessary, considering the phrasechgy of the SR Frequency ("Once after each refueling prior Thermal Power exceeding 75% RTP"). Explain the need for this note. The SR 3.2.2.1 Bases also mentions *(leaving Mode 1)" which appears to be the incorrect mode.

l FLOG Response:

' 3.2-5 ITS 3.2.1 Heat Flux Hot Channel Factor CTS 3/4.2.2 Heat Flux Hot Channel Factor (Callaway)

DOC 02-13-LG ITS 3.2.1 Bases Comment: The Callaway definition of extended operation has been moved to the Bases; where in the Bases? What is the need for this definition in the Bases?

FLOG Response:

3.2-6 ITS 3.2.4 Quadrant Power Tilt Ratio CTS 3/4.2.4 Quadrant Power Tilt Ratio (All FLOG Plants)

DOC 04-01-A JFD 3.2-05 ITS Required Action A.5 Comment: The ITS proposes to change the STS wording for Required Action A.5 from

" Calibrate excore detectors to show zero QPTR,* to " Normalize excore detectors to eliminate tilt," based upon WOG-95 (and rsjected TSTF-25). A preferred wording would be that proposed in the Comanche Peak CTS mark-up, Talibrate excore detectors to show zero Quadrant Power Tilt." What is status of WOG-957 FLOG Response:

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3.2 7 ITS 3.2.1 Heat Flux Het Channel Factor CTS 3/4.2.2 Heat Flux Hot Channel Factor (Callaway & Wolf Creek)

JFD 3.2-17 ITS SR 3.2.1.1 Frequency l Comment: The ITS SR 3.2.1.1 Frequency does not adopt the STG of "within [12) hours" based upon the justification that the CTS does not specify a time limit. The STS uses a bracketed time for accomplishing the SR, meaning that a plant specific number can be utilized. Utilize a plant specific number based upon plant expe%nce, or other relevant justification, if the 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is unrealistic. A time limit must appear in the frequency in place of the brackets.

FLOG Response:

3.2-8 ITS 3.2.4 Quadrant Power Tilt Ratio CTS 3/4.2.4 Quadrant Power Tilt Ratio (Wolf Creek)

JFD 3.2-18 DOC 04-10 LS14 J Revised ITS based upon CTS Comment: JFD 3.2-18 justifies numerous changes to the STS based upon CTS requirements, some of which are unacceptable. The unacceptable STS changes are:

1. The editorial change to the Required Action A.1 Completion Time and the associated change to Required Action A.2.

2. Thie qualification of"after acnieving equilibrium conditions ..."in Required Action A.3 Completion Time.

3. The qualification of"after achieving equilibrium conditions ..."in Required Action A.7 Completion Time.

In each of the above instances, provide adequate justification for the change or adopt the STS l' version of the specification.

FLOG Response:

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l l 3.2 9 ITS 3.2.3 Axial Flux Difference CTS 3/4.2.1 Axial Flux Difference (Wolf Creek)

JFD 3.2-19 ITS SR 3.2.3.1 Comment: The iTS deletes the STS words "for each OPERABLE excore channel," based upon a literal compliance concem. The concem is adequately addressed by the Note follov/ing the LCO, and is a generic change. The words are included to ensure mat the AFD is verifed with all the excores. Submit a TSTF change request providing adequate justification for the proposed change, or adopt the STS version of the SR.

FLOG Response:

3.2 10 l ITS 3.2.4 Quadrant Power Tilt Ratio CTS 3/4.2.4 Quadrant Power Tilt Ratio (All FLOG Plants)

JFD 3.2-15 ITS SR 3.2.4.2 Comment: JFD 3.2-15 justifies numerous changes to the STS one of which is unacceptable.

JFD 3.2-15 is based upon TSTF-109, which has been rejected. The unacceptable STS change is: The modification of the note to SR 3.2.4.2, and in particular the addition of the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowance in the Note to SR 3.2.4.2. Provide adequate justification fo; this change or adopt the STS version of the Note.

FLOG Response:

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. SECTION 3.2 RAI APPLICABILITY RAI # DIABLO COMANCHE WOLF CREEK CALLAWAY CANYON PEAK 3.2-1 X 3.2-2 X 3.2-3 X X X X 3.2-4 X X X X 3.2-5 X X X X X l3.2-6 _,

3.2-7 X X 3.2-8 X 3.2-9 X 3.2-10 X X X X i

I f  !