ML20076M892

Proposed Tech Specs Revising Current Tech Spec to Correct Administrative Errors

ML20076M892
Person / Time
Site:	North Anna
Issue date:	03/18/1991
From:	VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:
Shared Package
ML20076M888	List: ML20076M881 ML20076M892
References
NUDOCS 9103260104
Download: ML20076M892 (16)

Text

.. . . .

,t B

Attachment 1

-l Proposed -Technical Specification Change North Anna Unit 1 t

Virginia Electric and Power Company ,

l.

I: '

9103260104 910318 PDR ADOCK 05000338 P PDR ,

1 J

'REACTIVITYCOf#ROL SYSTEMS BORATEDWATERSOURCES OPERATING LIMITING CONDITION FOR OPERATION 3.1.2.8 Each of the following borated water sources shall bo OPERABLE:

a. A boric acid storage system and associated heat tracing with:

1. A contained borated water volumo of betwoon 6000 and 16,280 gallons,

2. Betwoon 12.950 and 15,750 ppm of boron, and

3. A minimum solution temperature of 115'F.

b. The refueling water storago tank with:

1. A contained borated water volume of betwoon 466,200 and 487,000 gallons,

2. Between 2300 and 2400 ppm of boron, and

3. A solution temperaturo betwoon 40*F and 50*F.

APPLICA9ILITY: MODES 1,2,3 and 4.

6CIl0N:

a. With the boric acid storage system inoperable, restore the storago system to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or bo in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and borated to a SHUTDOWN MARGIN equivalent to at least 1.77% Ak/k at 200*F:

restore the boric acid storage system to OPERABLE status within the next 7 days or be in COLD SHUTDOWN within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />,

a. With the refueling water storage tank inoperable, rostoro the tank to OPERABLE status within one hour or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE REQUIREMENTS 4.1.2.8 Each borated water source shall be demonstrated OPERABLE:

NORTH ANNA UNIT 1 3/4 1 16 l

REACTIVITYCONTROL SYSTEMS EMSES . -

ii

• 4 s .+ ' - . - . . . . . ,. .

3/4.1.2 BORATION SYSTEMS (Continued)

The limits on contained water volume an.i ooron concentration of the RWST onsure a pH value of betwoon 7.7 and 9.0 for the solutio'. recirculated within the containment after a LOCA.

This pH minimizes the evolution of lodite and minimizos the offect of chlorido and caustic stress corrosion on mechanical systems and components.

At least one charging pump must remain operable at all timos when the opposito unit is in MODE 1,2,3, or 4. This is required to maintain the charging pump cross connect system operational.

314.1.3 MOVABLE CONTROL ASSEMBLIES The specifications of this section (1) ensure that acceptable power distribution limits are maintained, (2) ensure that the minimum SHUTDOWN MARGIN is maintained, and (3) limit the potential offects of rod misalignment on associated accident analysos. OPERABILITY of the movable control assemblies is established by observing rod motion and dolormining that rods are positioned within i 12 stops (Indicated position) of the respectivo demand stop counter position. The OPERABILITY of tho individual rod position indication system is established by appropriato periodic CHANNEL CHECKS, CHANNEL FUNCTIONAL TESTS, and CHANNEL CAllBRATIONS. OPERABILITY of the individual rod position indicators is required to dolormino control rod position and thereby onsuro compliance with the control rod alignment and insertion limits. The OPERABLE condition for the individual rod posluon indicators is defined as being capable of indicating rod position within i 12 stops of the associated domand position indicator.

For power levels below 50 porcent of RATED THERMAL FOWER, the specifications of this section permit a maximum one hour in ovory 24 stabilization period (thermal" soak time") to allow stabillzation of known thermal drift in the individual rod position indicator channels during which time the indicated rod position may vary from demand position indication by no "

more than i 24 stops. This *1 in 24" facturo is an upper limit on the frequency of thermal soak allowances and is available both for a continuous one hour period or one consisting of several discrete intervals. During this stabilization period, greator rollance is placed upon the demand position indicators to determine rod position, in addition, the 124 stop/ hour limit is not applicable when the control rod position is known to be greator than 12 stops from the rod group step counter domand position Indication. Abovo 50 percent of RATED THERMAL POWER, rod motion is not expectted to induce thermal transients of sufficient magnitudo to excood the individual rod position indicator instrument accuracy of 't 12 steps. Comparison of the demand position indicators to the bank insertion limits with verification of rod position by the individual rod position indicators (after thermal soak following rod motion below 50 percont of l RATED THERMAL POWER) is sufficient verification that the control rods are above the insortion l limits, l

l NORTH ANNA UNIT 1 B 3/4 14

d ELECTRICAL POWER SYSTEMS SURVEILIANCE REQUIREMENTS w= -- i 4.8.1.1.2 (continued)

7. Verifying the diosol generator operates" for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. During the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of this test, the diosol generator shall be loaded to an indicated j target value of 2950 kw (between 2900 3000 kW)"' and during the re;nalning 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> of this test, the diosol generator shall be loaded to an indicated 2500 to 2600 kw.'" Within 5 minutes after completing this 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> test, perform Surveillance Roquirement 4.8.1.1.2.d.4.

8. Verifying that the auto connected loads to each diesel generator do not exceed i the 2000 hour0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> rating of 3000 kw.

9. Verifying tho diesel generator's capability to:

a) Synchronize with the offsito power source while the generator is loaded with its omorgency loads upon a simulated restoration of offsite power, b)Transfor its loads to the offsito power source, and c)Proccod through its shutdown sequence.

10. Verifying that the following diosol generator lockout features provent diosol generator starting only when required:

a)Remoto Local Selection Switch a) Emergency Stop Switch

e. At least once per 10 years or after any modifications which coLid affect diosol generator Interdependence by starting " both diosol 00norators simultaneously, during shutdown, and verifying that both diesel generators accelerate to at least 900 rpm in less than or equal to 10 seconds.

"This test shall be conducted in accordance with the manufacturer's recommendations regarding engine prelube and warmup procedutos, and as applicable regarding loading recommendations.

'"This band is meant as guidance to avoid routine overloading of the engine. Loads in excess of this band for special testing under direct monitoring of the manufacturer or niomontary variations due to changing bus loads shall not invalidate the test.

NORTH ANNA UNIT 1 3/4 8 3c i

l I __-

~ REFUELINGOPERATIONS FUEL BUILDING VENTILATION SYSTEM t.lMmNG CONDITION FOR OPERATION .

3.9.12 A fuel building ventilation system shall bo OPERABLE and discharging through at least one auxiliary building HEPA filter and charcoal absorber assembly.

APPLICABILITY:

a. During irradiated fuel movement within the spent fuel pit, or

. b. During crano operation with loads over irradiated fuoi in the spent fuel pit.

ACTION: ,

a. With a fuel building ventilation system inoperable, Irradiated fuel movement within the storage pool or crano operation with loads over tho spont fuel pit may

. proceed provided the fuel building ventilation system is in operation and discharging through at least ene train of HEPA filtors and charcoal absorber assemblies,

b. With no fuel building ventilation system OPERABLE, suspend all operations involving movement of irradiated fuel within the spent fuel pit or crano operation with loads over the spent fuel pit until at toast one fuel building -

ventilation system is restored to OPERABLE status,

c. The provisions of Specifications 3.0.3,3.0.4 and 4.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS e s

-4,9.12 The above required fuel building ventilation system shall be demonstrated OPERABLE and discharging through at least one auxiliary building HEPA filter and charcoal absorbor

assembly: .

a. At least once per 31 days by initiating flow through the HEPA filter and charcoal

. absorber assembly for 15 minutos

b. At least once per 18 months during system operation, by' verifying a 1/8 inch vacuum, water gauge, relative to the outsido atmosphoro, and-

c. By perfonnance of the Surveillance Requirements of Specification 4.7.8.1 b, c, d, eandf.

NORTH ANNA UNIT 1 3/4 9 12 rrar-- -e--ww+< -w * .-+w w * -~+--v---n-- -,r<r*-w r-- w - w - , * - - -rwrr,- --e~c- ww we-me em ,

e Attachtnent 2 i.

I

.O o i

Proposed' Technical Specification Change North Anna Unit 2 P t

W T

t L

Virginia: Electric. and Power : Company .

P

, , . _ . - - . . . - . .-u,, , _ ..m., - . . . . _. . _ _ . . _.. . ,_ . . , _ . . . _

REACTIVITYCCNTROLS" STEMS FLOW PATHS OPERATING UMITING CONDITION FOR OPERATION .. ....-

3.1.2.2 At least two of the following three boron injection flow paths shall be OPERABLE:

I

a. The flow path from the boric acid tanks via a boric acid transfer pump and a l charging pump to the Reactor Coolant System.

b. Two flow paths from the roluoling water storage tank vial charging pumps to the Reactor Coolant System.

I APPLICABILITY: MODES 1,2,3, and 4#.

ACTION:

With only one of the above required boron injoction flow paths to the Reactor Coolant System OPERABLE, restore at least two boron injection flow paths to the Reactor Coolant System to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY and borated to a SHUTDOWN MARGIN equivalent to at least 1.77% della k/k at 200'F within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />; restoro at least two flow paths to OPERABLE status within the next 7 days or bo in COLD SHUTDOWN within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE REQUIREMENTS 4.1.2.2 Each of the above required flow oaths shall be demonstrated OPERABLE:

a. At least once per 7 days by verifying that tho temperature of the heat traced portion of the flow path from the boric acid tanks is greator than or equal to 115'F when it is a required water source.

1. Only one boron injection flow path is required to bo OPERABLE whenever the temperature of one or more of the RCS cold logs is less than or equal to 340*F.

NORTH ANNA UNIT 2 3/4 19

• ^

' ~. ,

~. ,

r . ;: f ,#

_i , L*=

.g - REACTP/ITYCONTROLSvSTEMSs BORATEDWATERSOURCES OPERATNG:

- UMITNG CONDITION FOR OPERATION

- 3.1.2. 8 . Each of the following boraed wata sources shall be OPERABLE:

- a. A boric acid storage system and associated heat tracing with; o

1. A contained borated wator volume of between 6000 and 16,280 gallons,  !

2.- Between 12,950 and 15,750 ppm of boron, and

3. A minimum solution temperature of 115'F.

i

b. The refueling' water storage tank with;

__1. ' A contained borated water volume of between 466,200 and 487,000

'- - gallons,

2. = Between 2300 and 2400 ppm of boron, and l

'3l  : A solution temperature between 40*F and 50*F.

APPLICABILITY:. MODES 1,2,3 and 4.

ACTICN. ,

aEWith the boric acid storage system inoperable, restore the storage system to TOPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next

= 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and borated to a SHUTDOWN MARGIN equivalent to at least 1.77% Ak/k

at 200*Ft-

. restore the boric acid storage system to OPERABLE status within the next 7. days ,

or be in COLD SHUTDOWN within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />,  !

i a.7With the refueling water storage tank inoperable, restore the tank to OPERABLE. ,

' status whhin one hour or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and lin COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />, i e

ir ^L SURVEILLANCE REQUIREMENTS 3

i4.1.2.8f Each bo' rated water source shall be demonstrated OPERABLE: 4 k

L ENORTH ANNA - UNIT 2 3/4-- 1 14 i

b

REACTIVITYCOWROLSYSTEMS L%SES 3/4.1.2 BORATION SYSTEMS (Continued) j The limits on contained water volume and boron concentration of the RWST onsure a oH value of between 7.7 and 9.0 for the solution recirculated within the containment after a LOCA.

- This pH minimizes the evolution of lodino and minimizes the effect of chloride and caustic stress corrosion on mechanical systems and components, At least one charging pump must remain operable at all times when the oppasito unit is - '

In MODE 1,2,3, or 4. This is required to maintain the charging pump cross connect system operational.

i T41.3 MOVABLE CONTROL ASSEMBLtES -

The specifications of this section (1) ensure that acceptablo power distribution limits are maintained,-(2) ensure that the minimum SHUTDOWN MARGIN is maintained, and (3) limit ~

the potential effects of rod misalignment on associated accident analysosi OPERABILITY of the movable control assemblies is established by observing rod motion and determining that rods are msitioned within i 12 steps (Indicated position) of the respective demand stop counter position. The OPERABILITY of the individual rod position indication system is established by

. appropriate periodic CHANNEL CHECKS, CHANNEL FUNCTIONAL TESTS, and CHF 'EL '

CAllBRATIONS OPERAdlLITY of the individual rod position indicators is roc to determine control rod position and thereby ensure compliance with the control rod alignmd.it and insertion limits. The OPERABLE condition for the Individual rod position Indicators is defined as being capable of indicating rod position within i 12 steps of the associated demand position indicator.

. For power lovels below 50 percent of RATED T_HERMAL POWER, the specifications of this  ;

section permit a maximum one hour in overy 24 stabilization period (thermal" soak timo") to

allow stabilization of known thermal drift in the individual rod position !ndicator channcis during which time the indicated rod position may vary from demand position indication by no

= more than i 24 steps; This "1 in 24" feature is an upper limit on the frequency of thermal

. soak allowances and is available both for a continuous one hour period or one consisting of l fsoveral discrete intervals. During this stabilization period, greater reliance is placed upon the j demand position indicator to dolormine rod position.' In addition, the i 24 step / hour limit is :

not applicable when the control rod position is known to be greator than 12 steps from the rod group step counter demand position indication. Above 50 percent of RATED THERMAL POWER.

rod motion is not expected to incuce thermal translents of sutilcient magnitudo to exceed the individual rod poshion indicator instrument accuracy of i 12 stops. Comparison of the domand-  ;

1 position indicators u the bank Insertion limits with verification of rod position by the individual rod positkin indicators (after thermal soak following rod motion below 50 percent of a

, RATED THERMAL POWER) is sufficient verification that the control rods are above the Insertion limits; l

-NORTH ANNA - UNIT 2 B 3/4 1 4 i

~

m'  : .

.- 4 4

r ISOLATED LOOP STARTUP LIMITING CONDITION FOR OPERATION

.w 3 r

3.4.1.5: : A reactor coolant loop cold leg stop valve shall remain closed until:

. a. The isolated loop has been operating on a recirculation flow greater than or equal to 125 gpm for at least 90 minutes and the temperature at the cold leg of the.-  ;

e isolated loop is within 20*F of the highest cold leg temperature of the operating ,

- loops.

_ b.- The_ reactor is suberitical by at least-1.77 percent Ak/k.

i.

APPLICABILITY:-' ALL MODES.'

ACTION:

?With the requirements of the above specification _not satisfied, suspend startup of the isolated- a

-loop.

I 4 F

F E ISURVEILLANCE REQUIREMENTS

' 4.4.1!5.1.?The Isolated loop cold leg temperature shall be determined.to be within 20'F'of the- 'j. -

E

.hichest cold leg temperature of the operating loops within 30 minutes prior to opening the cold '

leg stop. valve. -

[1 L '4.4.1.5.2 The reactor-shall be determined to be subcritical by at least 1.77 percent Ak/k -l=

- within 30 minutes prior to opening the' cold leg'stop valve. ...

h

..- r

. NOR1H ANNA UNIT 2 3/4 4-5

?____.... =2 :_ .- . . . . ..- . , . . . . . . - . . - - .. , , ,e

-ll ' 3 - .

=.

-i

-g.

-f:

f Attachment 3 it e, .. s n ,-(.-,

l

.t I

j .t .

. ;t Discussion- of' Proposed Changes l E North Anna Units 1 and- 2 ,

t s

,3 r

I( t t

i-1 Virginia Electric and Power Company-

- \

t l, =

t 1

~ ~~ _ . , ,.

<w .

DISCUSSION OF PROPOSED CHANGES This request has been submitted to correct certain administrative errou ir the North Anna Technical Specifications. The corrections proposed are corrections to numerical values which were inadvertently overlooked during prior amendments. Because the values are non conservative with respect to the correct values, or a source of potential confusion, it was censidered appropriate to revise the items at this time. Other administrative errors which have resulted in moro conservative values than required, or which are purely grammatical / editorial corrections, will be addressed during

• implementation of the MERITS specifications.

31.2.2 (Unit 2 Only,1 Flow Paths: Limitino Condition fot Joeration The required shutdown margin was inadvertent!r changed from 1.77% to 1% delta k/k in the Unit 2 specification. This was a typographs el error included in Amendment 54

.to the Unit 2 license. TS 3.1.2.2 is revised to show the correct value of 1.77%. The shutdown margin is stated correctly in the Unit 1 technical specifications.

- TS 3.1:2.8 (Both Units)

~ Borated Water Sources: Limitina Condition for Ooeration The refueling water storage tank (RWST) is-required to contain a-borated water volume of between 475,058 and 487,000 gallons. The RWST minimum volume is changed _from 475,058 gallons to 466,200 gallons. This change was previously evaluatea in our submittal dated March 2,1988 (Serial No. 87 385), and approved by ,

NRC letter dated December 14,1988. _ The change to the correct value of 466,200 gallons in TS 3.1.2.8 should have occurred at that time.

3/4.1.2 (Both U.Qlld Reactivity C J ol Systems: Bases

- The Bases for the boration system states that the limits on contained water volume and .

boron _ concentration of the RWST ensure a pH value of between 8.5 and 11.0 for the

. solution recirculated within the containment after a LOCA. The pH value was changed -

from between "8.5 and 11.0" to "7.7 and 9.0" in our submittal dated December 19,

.1985 (Serial No.85-718),' and. approved by NRC letter dated August 22,1986. The change to the correct lvalue of between 7.7 and 9.0_should have occurred at that time.

The word "also" is deleted in the sentence for clarity.

L

- 3.4.1.5 (Unit 2 Oniv)

Isolated Loco Startuo: Limitina Condition for Ooeration The Limiting Condition for Operation on page 3/4 4 5 was originally numbered. as 3.4.1.3, and the corresponding surveillance requirements as 4.4.1.3.1 and 4.4.1.3.2.

Those numbers are incorrect and cause confusion with the similarly numbered LCO and SR on page 3/4 4-3 and 3/4 4-4. The correct numbers for page 3/4 4 5 are

- 3.4.1.5, 4.4.1.5.1 and 4.4.1.5.2, respectively.

[

- 4.8.1.1.2 (Unit 1 Only)

Electrical Power Systems Surveillance Recuirements Unit 1 Technical Specification 4.8.1.1.2, item 7 on page 3/4 0 3c contains an error.

The current surveillance requirement states that "...the diesel generator shall be loaded to un indicated target value of 2950 kw (between 290--3000 kw)..." The value of 290 is incorrect and should be changed to 2900. The correct diesel generator target value is between 2900 and 3000 kw.

4.9.12 (Unit 1 Ontv)

Fuel Buildino Ventilation System: Surveillance Reauirements Unit 1 Surveltlance Requirement 4.9.12 on page 3/4 9 -12 requires flow through the HEPA filter and charcoal absorber assembly for 5 minutes. That is incorrect. The correct value is 15 minutes. The Unit 2 surveillance requirement is stated correctly. In spite of the error, compliance with the correct specification has been maintained. The procedure for implementing the surveillance requirement is 1-PT 95.1, " Fuel Building Ventilation System 15 Minute Run," which contains the correct time interval.

cr- . -.

a

., m i

. l j.. ,

1 l

.i~'

t Attachment 4

?

b

(

i

i. :

.No' Significant Hazards: Consideration Determination North Anna Units 1 and 2 f

.s

.f k s l

t Virginia. Electric' and Power -Company

-1 p .

i

e p-10_ CFR 50.92 Significant Hazards Consideratione Determination The proposed technical specification change has been submitted to correct certain administrative errors-in the North Anna Technical Specifications. The corrections proposed are corrections to numerical values which were inadvertently overlooked during prior amendments. . Because the values are non conseivative with respect to the correct values, or a source of potential confusion, it was considered appropriate to revise the items at this time. Other administrative errors which have resulted in more conservative values than required, or which are purely grammatical / editorial corrections,'will be addressed separately. The proposed changes include:

-- Correcting-the value for shutdown margin in a Unit 2 specification dealing with operable boron injection flow paths

. - Correcting the value for the minimum borated water volume in the Refueling Water Storage Tank- in Unit 1 and 2 specification dealing with operable borated water

- sources

• Correcting the Bases that describe the pH limits on contained water volume and boron concentration in the RWST -

i Correcting the numbering for a Limiting Condition for Operations and Survellfance Requirement in the Unit 2 specifications on isolated loop startup to eliminate confusion with a similarly number specification elsewhere-in the Technical i

Specifications

+ . Correcting the target value for loading the emergency diesel generators in the Unit 1 specifications on electrical power systems, and

-- _ Correcting the time interval for demonstrating the operability of the Unit 1 HEPA filter and charcoal absorder aseembly.

It has'been determined that the proposed changes do not involve a significant hazards consideration as-defined in 10 CFR 50.92. This determination was based on the following points.

1. The proposed change does not involvo _a significant increase in the probability

-or consequences of an accident previously evaluated. The proposed changes have no adverse impact upon potential accident probability or consequence.

No new or unique accident precursors are introduced by these changes to the technical specification requirements. In fact, the administrative corrections _ to -

the technical specifications may act _ to decrease any potential accident 3robab;lity or consequence that might have occurred as a result of inaccurate nformation that is currently in the Technical Specifications.

..3- .

Likewise, the consequences of the accidents will not increase as a result of

' administrative correction of the Technical Specifications.

2. The proposed change does not create the possibility of a new or-different kind of accident from any accident previously evaluated. The proposed changes to the Technical- Specifications have been previously evaluated and approved,.

Therefore, the changes herein are only administrative chunges. Operation with- l I

these changes does -not create a probability for any. accident which has not m . already_been evaluated in the Updated Final Safety Analysis Report (UFSAR).

The risk of these changes creating the probability for any new accident has been l previously considered by the NRC.

3. The proposed changes do not involve a significant reduction in a margin _of safety. The results of the UFSAR accident analyses continue to bound operation under- the proposed changes. The proposed changes to the Technical Specifications have been previously evaluated and approved by NRC, therefore l the changes herein involve no reduction in a margin of safety and are only administrative; changes.

Based on the above,-we~ conclude that the proposed changes do not result in a significant hazards consideration as defined in 10CFR50.92. )

e

\

- r ,-.-

_ _ _ , , - , <,.. , --e , -