IR 05000267/1983006
| ML20024C102 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 05/13/1983 |
| From: | Holley W, Murray B, Westerman T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20024C099 | List: |
| References | |
| 50-267-83-06, 50-267-83-6, NUDOCS 8307120259 | |
| Download: ML20024C102 (13) | |
Text
{{#Wiki_filter:- . . APPENDIX U. S. NUCLEAR REGULATORY COMNISSION
REGION IV
NRC Inspection Report: 50-267/83-06 License: DPR-34 Docket: 50-267 Licensee: Public Service Company of Colorado (PSCo) P. O. Box 840 Denver, CO 80201 Facility Name: Ft. St. Vrain Nuclear Generating Station (FSV) Inspection At: Platteville, Colorado Inspection Conducted: February 28-March 4,1983 ho/f'3 Inspector: b . - Dite W.' L. Holl y Refliatiorf Speciayst, Facilities ' Radiation rotection Section Approved: b4 h///JteM1 k/d[h3 ~ Blaine Murray, Chief [[ Facilities Radiation D'a te ' Protection Section bl// C//s/83 T. F. Westermali,T,hief, Reactor Project Section A Dite Inspection Summary Inspection Conducted February 28-March 4,1983 (Report 50-267/83-06) Areas Inspected: Routine, unannounced inspection by a regional based inspector of the licensee's radwaste program including: liquid and gaseous radioactive effluent releases; records and reports of radioactive effluents; effluent control instrumentation; procedures for controlling the release of effluents; testing of air cleaning systems; reactor coolant quality; licensee audits of radwaste activities; radiochemistry organization; health physics organization; and solid radioactive waste. The inspection involved 33 onsite hours by one .NRC inspector.
Results: Within the areas inspected, no violations or deviations were identified.
One new unresolved item is discussed in paragraph 3.
. 8307120259 830523 PDR ADOCK 05000267 g PDR
- u , . ,' . - > _ _.A .,
. Details PersonsContactedfFSV) 1.- Principal: Licensee Personnel
- D. W. Warembourg, Manag'er, Nuclear Production
- T.; Borst,' Radiation Protection Managar M. 'J. Ferris, Quality Assurance Coordinator. _
~C.1H. Fuller, Technical Services Engineering Supervisor
- J. W. Gahm, Quality Assurance Manager
- F. D. Hill, Station Manager V. J. McGaffic, Chief Radiochemist P. F.' Moore, Quality Assurance Technical Support Supervisor T.,E.'Schleiger, Health Physics Supervisor
.
- L. Singleton, Quality Assurance Operations Supervisor
- H. R. Starnes, Construction Coordinator W. E. Woodard, Plant Health Physicist Other Personnel
- M. W. Dickerson, Senior. Resident Reactor Inspector,- USNRC The NRC inspectors also interviewed several other licensee employees including health physics technicians, radiochemistry technicians, and administrative personnel.
- Denotes those present during the exit interview March 4, 1982.
. 2.
Licensee Action on Previous-Inspection Findings (0 pen) Unresolved Item (267/8128-01): Reactor Building Exhaust Filters: - This item wa-identified in NRC Inspection Report 50-267/81-28 and involved - documentation not being available to determine if filters had'been tested to meet the requirements of the Technical Specifications. See paragraph 10 for' additional details. This item remains open.
(0 pen) Open Iliem (267/8128-01):. Gaseous Iodine / Particulate and Liquid Monitors: This item was identified in NRC Inspection Report 50-267/81-28 and involved the' lack of.a comprehensive calibration and testing program .that satisfies the recommendations of ANSI N323-1978.
See paragraph 8 for additional details. This item remains open.
(0 pen)Open' Item (267/8128-02): Control Room Filter and Technical Support Center Filters:- This item was identified in NRC Inspection Report 50-267/81-28 and involved the licensee not including these systems in a. routine surveillance program.
See paragraph 10.b for additional details. ~This item remains open.
, .
. __ .. __ _.
. .
' (O' pen)OpenItem(267/8221-03): Primary Coolant Sample Lines /NUREG-0737, Item II.B.3, "Postaccident Sampling Capability: This item was identified ' in NRC Inspection Report 50-267/82-21 and involved the licensee not determining the' potential for line blockage, activity plate-out, or sample.
distortion. 'This item remains open.
(0 pen):0 pen Item.(267/8221-05):. Reactor Building Ventilation Exhaust Monitor: This item was identified _in NRC Inspection Report 50-267/82-21 and involved the_ licensee not determining the effect of_ entrained moisture on the zeolite cartridge adsorbers-in the iodine sampling system of the . reactor building ventilation exhaust effluent stream. This determination had not been completed. This item remains open.
(0 pen) Unresolved Item (267/7815-01): Use of Reactor Buildinc Sump for Processing Radioactive Liquids: 'This item was identified in FRC Inspection Report 50-267/78-15 and discussed in NRC Inspection-Report 50-267/81-28 which involved the licensee using the reactor building sump.as a part of the radwaste system.
See paragraph 6.a for details. This item remains open.
3.
30 pen Items Identified During This Inspection (0 pen)UnresolvedItem(267/8306-01): ~ Incomplete Surveillance Reports: . . The station manager's -signature did not appear on certain surveillance.
reports which deviated from established surveillance' procedures. f:e paragraph 9 :for details.
4.
~ Scope of Inspection The purpose of this inspection was to review the' licensee's radwaste ~ . program for the period December 1,1981, through February 1,1983.
t 5.
Organization r The following chart shows-the FSV Quality Assurance (QA), Health Physics (HP),'and. Radiochemistry (Rad Chem)-organizations that affect the radwaste program. _ The' HP organization was reviewed during the period of . August 30-September 3,1982 (see NRC Inspection Repcrt 50-267/82-21),and ' was; found satisfactory. ' There had not been any changes in.the intervening , period. The radiochemistry organization was reviewed during this
. inspection.
!- , i i - t i ,
._,_,.w._,,.--,_,-..,,__.J.~,-_,_.-,--..-, a .. -. ,-,-,,,--,--__..,._.-,,.-,-...._,..-.-_..__.m - <
.
Vice President Electrical Production . Quality Manager Assurance Nuclear Manager Production Supervisor Radiation Quality Protection Assurance Manager Operations QA Auditor QA Technical Health Physics Rad-Chem Coordinator Support Supervisor Supervisor Supervisor __ QA Computer .__ ] Health Physicist l I Radiochemist 1 Engir.eer Specialist __ QA QA __ Health Physics Rad-Chem Technicians Engineers Technicians Technicians QA _, Technicians No violations or deviations were identified.
6.
Radioactive Effluent Releases a.
Liquid The NRC inspector examined the liquid effluent release program to determine compliance with items 4.8.2 and 5.8.2 of the Technical Specifications.
Anunresolveditem(267/7815-01) initially reported in Report 50-267/78-15 and subsequently reported in Report 50-267/81-28 involved the use of the reactor building sump as part of the radwaste syste i . .
The primary NRC concern has been that the reactor building sump was being used as.part of the radwaste system. However, the reactor building sump was not included in the FSAR as an integral part of the radwaste system. During previous discussions the > licensee has stated that the system problems which resulted in ' past use of the sump had been corrected and this type of use would not be necessary in the future. However, due to chemical contamina-tion of the demineralizer system in late 1982 which reduced the associated decontamination factors, the licensee has resorted to reuse of.the. sump to dilute liquid waste prior to discharge in order to stay within Technical Specification limits. This item . (267/7815-01) is considered unresolved pending: Analysis of thc. radiological hazards involved in using the . reactor building sump as a part of the radwaste system.
Provide' for-proper monitoring of the effluent released from the . sump which includes the collection of representative effluent ~ samples.
Re't sion to the FSV FSAR by July 1, 1983, to include the reactor-i . building sump as a part of the radwaste system.
No violations or deviations were identified.
b.
, Gaseous The NRC inspector examined the gaseous effluent release program to determine compliance with items 4.8.1 and 5.8.1 of the Technical Specifications.
-No violations or deviations were identified.
, Records and Reports of Radioactive Effluents 7.
The NRC inspector reviewed records and reports required by 10 CFR 50.36a(a)(2). The licensee's semiannual reports conform to the format recommended in Regulatory Guide 1.21.
No violations or deviations were identified.
8.
Effluent Control Instrumentation The NRC inspector reviewed records and procedures regarding calibration results, response tests, operational checks, and alarm' set-points for the various liquid and gaseous-effluent monitors to determine compliance with items 4.8.1, 4.8.2, 5.8.1, and 5.8.2 of the Technical Specifications.
.. - -. _ _ _ _ _ _ _ _._ _ _ _. _ _ - - _. _ _ _ _. _. . . _ _ _ _ _ _ _
. .
Theoenitem(267/8128-01) identified in NRC Inspection Report 50-267/81-28-invo ve the lack of'a comprehensive calibration and testing program for GaseousIodine/ Particulate (RT-7325-1and2)-andLiquidMonitors(RT-6212 and RT-6213) which would satisfy ANSI N327-1978. The licensee had completed the necessary work except for revising SR 5.8.2c-Q, " Radioactive Liquid Activity Monitor Calibration," and was developing a new results procedure which would complete the calibration and testing program. The estimated completion date for this item is June 30, 1983. This item remains open.
No violations or' deviations were' identified.
9.
~ Procedures for Controlling the Release of Effluents The following Surveillance Reports and Release Permits were reviewed during this inspection: Surveillance Reports: SR 5.2.11-W, " Primary Reactor. Coolant Radioactivity Analysis" ' SR 5.2.12-W, " Primary Reactor Coolant Chemical Analysis" SR 5.3.7-W, " Secondary Coolant Activity" SR 5.4.9-W, " Area and Miscellaneous Process Radiation Monitors Functional-Test" SR 5.5.3a-SA, " Reactor Building Exhaust Filters" ~SR 5.5.3bc-A, " Reactor Building Exhaust Filters" SR 5.5.3de-SA, " Reactor Building Exhaust Filters - Charcoal Filter Samples" SR 5.8.labc-M, " Radioactive Gaseous Effluent System Test" SR 5.8.1cd-Q, " Radioactive Gaseous Effluent System Calibration'.' SR 5.8 le-A, " Radioactive Gaseous Effluent Flow Recorders Calibration" SR 5.8.lf-W, " Radioactive Gaseous Effluent Vent Iodine / Particulate Filter Analysis" SR 5.8.2a-A, " Radioactive Liquid Effluent System" SR 5.8.2bc-M, " Radioactive Liquid Effluent System Instrumentation" SR 5.8.2c-Q, " Radioactive Liquid Effluent Activity Monitor. Calibration"
. . . s
Liquid Release Permits.(January 1,- 1982, through January.31,1983). Form (c) 372-02-2535 ' Gaseous' Release ~ Permits (January 1,1982, through January 31,1983) Form (c) 372-02-25366 The licensee's release permits l indicate that the following' items are verified as part of releases made from the various hold-up tanks: Compliance with TechnicalLSpecifications .. Total activity released . Total volume released . Duration of release . . Response test of effluent monitors . Dilution flow rate: .- .
- .
Maximum allowable' release rate Effluent monitor set-point . Total activity released' . Authorization signatures . ~ The licensee's surveillance. procedures require that the station manager review and acknowledge, by his signature, any surveillance report where.the results . deviate from established surveillance acceptance criteria. These deviations could includa such items as the test not conducted within the established frequency, results not within established acceptance criteria, etc.
If a particular test' results did -not satisfy a test requirement, a supplemental report is~ attached ~to the surveillance report which includes the reason-as to why the test results 'did not satisfy the surveillance criteria.
During the review of selected reports including: SR 5.4.7-11, " Area and Miscellaneous Process Radiation Monitor Functional Test,"'SR 5.8.labc-M, " Radioactive' Gaseous Effluent System Test," and SR 5.8.2bc-M, " Radioactive Liquid Effluent System," the NRC inspector noted that the station manager had ' -not signed all surveillance reports where test'results deviated from the ' established. criteria. The NRC inspector did not have enough time to review all surveillance results to determine 'if the lack of station manager signatures were only isolated cases or.an indication of the lack of management oversight and the failure to follow procedures regarding a general program area.
~ Thisisconsideredanunresolveditem(267/8306-01) pending a thorough review on a subsequent inspection.
No violations or deviations were identified.
- - - - - - - - - -
. .
10.
Testing of Air-Cleaning Systems a.
Technical Specification Systems The NRC inspector reviewed the air-cleaning systems' surveillance results to determine compliance with Technical Specification, items 5.5.3a, b, c, d, and e.
Technical Specification SR 5.5.3.d states, " Flow distribution across the HEPA and charcoal filter will be tested with initial operation of the system and following any structural medification to the filter housings. Air distribution shall be demonstrated within 20 percent across the HEPA and charcoal filter when tested in accordance with ANSI N510-1975." The unresolved item (267/8128-01) in Inspection Report 50-267/81-28 involved the lack of documentation that would demonstrate that the filters had been initially tested in accordance with Technical Specification SR 5.5.3.d.
The NRC inspector determined that the licensee had performed the necessary tests after September 1982. The licensee had requested the necessary documentation from the vendor who performs initial tests.
This unresolved item (267/8128-01) remains open pending the review of this documentation.
b.
Nontechnical Specification Items The NRC inspector determined that the licensee had initiated the development of procedures which will provide surveillance of the control room and technical support center filter systems. This lack of surveillance was considered an open item (267/8128-02) in Inspection Report 50-267/81-28. Upon implementation of the proposed procedures, the filter systems and surveillance program should satisfy the recommendations of Regulatory Guides 1.52 and 1.140.
No violations or deviations were identified.
11.
Reactor Coolant Quality The NRC inspector examined the analyses of the reactor coolant to determine compliance with Technical Specifications 4.2.8, 4.3.8, 5.2.11, 5.2.12, and 5.3.7.
Documents Reviewed Radiochemistry Procedure (RCP)-22, " Primary Coolant Radioactivity . Surveillance for Technical Specification SR 5.2.11-W" Radiochemistry Procedure (RCP)-23, " Analysis of Secondary Coolant . Radioactivity for Surveillance Requirement SR 5.3.7-W" No violations or deviations were identified.
- - _ _ - _ _ _ _ _ _ - _ _ _ _. _ ._. _ _ _ _ _ _ _ __ - _ _ _ _ _. _-___-__ _ _____ _-- ______-__ ____-
. . (
12.
.ladioactive Solid Waste The NRC inspector reviewed the licensee's program to determine compliance with 10 CFR 71, a.
Shipments Documents Reviewed Health Physics Procedure (HPP)-68, "FSV Irradiated Reflector Block . Shipping" Attachment HPP-68A, " Package Activity Worksheet" . Attachment HPP-688, " Chem-Nuclear Systems, Inc., Straight Bill of . Loading" Attachment HPP-68C, " Vehicle Radiological Survey Form Incoming & . Outgoing Services" Attachment HPP-68D, " Washington State Dept. of Social & Health . Services for Level Radioactive Waste Shipment Certification Form" Attachment HPP-68E, " Driver's Instructions for Exclusive Use Vehicles" . Attachment HPP-68F, " Prior Notification of Shipment of Low-Level . Solid Waste to Beatty, Nevada, or Hanford, Washington Attachment HPP-68G, " Radioactive Waste Shipment & Disposal Form" . Attachment HPP-68H,'"For Completing U.S. Ecology's Radioactive Waste . Shipment and Disposal Form" Attachment HPP-681, " Radioactive Material Removal Record" . HPP-26, " Radioactive Material Control and Handling" . HPP-30, " Radioactive Material Classification, Packaging, and Labeling"- . Reflector _ Block Shipping Papers, RB-83-01 through RB-83-08 . State of Washington Radioactive Materials License No. WN-I-019-2, . Amendment No. 15 South Carolina Radioactive Waste Transport Permit No. 0175-05 83-X . The licensee's records indicated that eight shipments consisting of irradiated fuel blocks were made between January 18-February 14, 1983.
No violations or deviations were identified.
..- -,,, - . - -. - - _ _. .. _. .. -
E . .
b.
Radioactive Waste Activity The lack of an adequate procedure to accurately estimate the radioactive contents of drums containing radioactive waste was discussed in NRC Inspection Report 50-267/80-13. The NRC inspector noted that Procedure HPP-26 had been issued to correct this problem.
No violations or deviations were identified.
13.
Audits The inspectors examined audits conducted by the licensee's QA department of radwaste and radiochemistry activities for the period January 1-December 31, 1982.
The inspection and audit functions of the licensee's QA program are accomplished by the performance of monitoring activities and audits, which result in quality assurance monitoring manual (QAMM) reports, quality assurance audits (QAA), and nuclear facility safety committee (NFSC) audits.
Various QAMMs, QAAs, and NFSCs are performed every 2 years.
The following audits were reviewed: QAMM P3-1, " Gas Waste System Operability" . QAMM P3-2, " Radioactive Waste and Disposal" . QAMM P3-5, " Radioactive Waste System Oparability" . i NFSC-A-82-1, " Technical Specification Compliance Audit, September . 1982.
These audit reports indicated that timely corrective action was completed for those deficiencies identified in the reports.
The NRC inspector noted that QAMM P3-3, " Gas / Liquid Waste Releases," had not been performed in the past 2 years.
Upon discussing this with the licensee, the NRC inspector determined this item had been included as open item (267/8304-02) in Inspection Report 50-267/83-04. This inspection was a QA inspection performed by the Division of Resident, Reactor Project and Engineering Programs.
The NRC inspector expressed concern to the licensee about the lack of expertise.regarding radwaste activities for teams conducting the radwaste audits.
No violations or deviations were identified.
14.
Reportable Occurrences (R0s) The NRC inspector reviewed R0s documented by the licensee regarding radwaste activities for the period January 1,1982, through January 31, 1983. The following R0s were reviewed:
, - ,
- 4
.: ,
, ,
, ~ "82-004', February 2,1982": Unauthorized radioactive. liquid waste release, , gross beta gamma level in excess of Technical Specification LC0 4.8.2(c) . limits.
(Improper valve line'up) > "82-009, March 6, 1982": - Unsampled gas _ waste release, contrary to Technical Specification LC0 4.8.1(a).- (Failure to close valve) "82-022, May 21, 1982": Two unauthorized gas waste releases contrary to-Technical Specification LC0 4.8.1.
(Malcperation of a' clearance point valve for a gas waste compressor and unanticipated gas leakage during maintenance activities on-a gas waste compressor) '"82-041, October 11,-1982": Trip set-point for radioactive liquid effluent monitors, RIS-6212, during calibration was found to be less conservative than required and is'a degraded mode of Technical Specification LC0.4.8.2(d) ~ per FSV_ Technical Specification AC 7.5.2(6)2.
"82-042,,0ctober 13,~1982": Unsampled, unplanned radioactive gaseous release to atmosphere which was less than maxirium permissible concentration.
This event constituted a degraded mode of LC0 n.8.1 and was reported per-AC.7.5.2(6)4 of the FSV Technical Specifications.
(Blank flange had a leaking seal.)
"83-002, January 4,1983": Proportional sampler was inoperable; therefore, daily samples were not taken during seven liquid releases made automatically from reactor building sump. This was a degraded mode of Technical.
Specification.LC04.8.3(f).
The NRC inspector verified that the action taken by the licensee regarding the above R0s was in compliance with the Technical Specification requirements.
No violations or deviations were identified.- 15.
Plant Tour The NRC inspector toured the plant on March 2,1983.
Particular attention was given to the radwaste system, effluent monitors, and the reactor i - building sump. The NRC inspector observed the detector locations and their associated readout instrumentation in the control room. The NRC inspector verified that the following monitors and recorders were in i service and operating: RT'6314-1&2, " Waste Gas Effluent Particulate and Iodine Monitors" i RT 46211, " Waste Gas Compressor Cooling Water Monitor"
- RT 46212,'" Waste Gas Compressor Cooling Water Monitor" RT-7324-1&2, " Reactor Plant Ventilation Exhaust Gas Monitors"
' . , ' RT. 73437-1&2, " Reactor Building Vent Stack Monitors" i ' ' , . .
. . - - -.. -.. .. --.. I
- . -
. , .
! RT 9302, " Gas Beta Monitor" RT 21251, " Low Pressure Separator Drain Line Monitor" - RIS 6212 " Radioactive Liquid Waste Effluent Monitor Recorder" RIS 6212, " Radioactive Liquid Waste Effluent Monitor Recorder" , RIS 6314-1&2, " Waste Gas-Effluent Particulate and Iodine Monitor Recorders"
RIS'7324-1&2, " Reactor Plant Ventilation Exhaust Gas Monitor Recon ders" RIS 7325-182, " Turbine Building Particulate and Iodine Monitor Recorders" ' RIS 9301, " Primary Coolant Beta Gas Monitor Recorder" < RIS 21251, " Low Pressure Separator Drain Line Monitor Recorder"
RIS 46211, " Waste Gas Compressor Cooling Water. Monitor Recorder" RIS 31193, " Air Ejector Exhaust Monitor Recorder" ' RIS 73437-1&2, " Reactor Building Vent Stack Moi.itor Recorders.
- -
No violations or deviations were identified.
16.
Unresolved Items . Unresolved items are matters about which more 'information is required in order to ascertain whether they are acceptable items, items of non-
compliance, or deviations. The unresolved item disclosed during this inspection is discussed in paragraph 9.
,
17.
Exit Interview- , i The NRC inspector met with the representatives (denoted in paragraph 1) at the conclusion _ of the inspection on March 4,1983. The NRC inspector summarized the scope and findings of the inspection.
J
s
.
y--f-- yt g yi-s- , - - -g --w-P-9yy-r--w $w.
ye+ - yy gr,-y
' ---pgym yy-yyyr,-v y --p y M g-" y m 9, y ve p -wwy w9, gr-r-,y2- ^"yyr-e-gn,og-y - ,-gag gy iy v, g eqyww p
? Pa N +A iN3ptCToatNe,w est e, e,e mee me . U.S. NUCLEAR REGULATOMY COMMIS$10N seh FonM7et ' A N ' m E vee win ( / / INSPECTOR'S REPORT Office of Inspection and Enf orcement g,' ,g m,y / ms.ECTom5 DEPORT NE xT INSPEC DATE " DOCaET NO te ogts'OR LICENSE LICEN5f tivf NDOR 9,p NO ter PmODUCTil13 eets! no sgo go yn dL O 5 h O b Eb
I O O b) A i-h // -df ohm /
g M - MODtFT C - D - DELFTE D - - REP ACE R L ,I dd6.'MisMA - h2 MM i ORGANIZATION CODE OF RE3 0NIMO CONDUCT.
sNSPECTION PERFOaMED Bv PixOD OF INVE STEAT10N mv5PECTON T' ~ ev-Weest Memoser RecorMc * hr coor)
FROM TO
1 - REGCN AL OFFICE ST AFF ] OmEE ' REGON D'visON BAANC++ g h MO DAv l vn MO DAY VR 2 - RE51 DINT WSPECTOm M7 MldQ Q] j Q pl2 3 - PERFORMANCE APPRAISALTEAM y'*** ?TQf ssT W:Q[n :- 7;Q a% ',f** Q : -R, p p y f7M;z,= yggd.QQg _- - ___ - ,, _ Yt PE OF ACTivlTV CONDvCTEDIChecs one ben oravi f e - mouiRV l RECONAL ACTON [ 02 - SAFETY _ 06 - MOUT. VISIT _ 10 - PLANT SEC.
_ ' 4 INVESTIGAT10N ' " "* 07 - SPECLAL 11 - WVENT. VER 03 - fNCIDf AT 1 NaCFOaM595 U - SMlPMENT/ EXPORT , OF - VENDOP os - ENFOaCEMENT K , mEGIONAL OFFICE LETTER
MAT. ACCT 13 - IMPOni OE - MGMT AUD<T r % v }, q Q-}-,gllRb g WWQQ - 3..fgg M "- - u Q "* 7 f % T - y% _,3 pT CONT AIN 2 790 l LETTEh 0m mE PORT TRANSMITTALDATE - TCT AL NvueE R thf 0ACEMENT CONFERENCE R E PO.NF OR M ATCN .N5mi gN.Lgaig wh* OF voLATiDNS AND MELD NRC FORM 591 REPO#T SENT DEVIATONS A B C D on MEG TOMQ FOa LffTint5$UED ACTON / 1 - CLI Aa l MO 2 - WOLATION DAv VR l MO DAY I YR C D A' 8 C D A B C' D l6 3 - DivlATON A 1 vES 1 vE5 1015 AI3 FW e - vcLATION & OtviATON g g,, , , ' A .k kh dd8 E N Shk MODute INFO *MATON MODULE 6NFO#UATON MODULE REO FOLLOWUP r
, f MODULE #EO FOLLOWUP h MODULE NuwsEm eNSP EgE3'sI8 e gg MODULiNUUffRIN5' dg f
!s
5 8e 5 9%5 sEr s g! 3 :
3e r r 58 5 r h% sse . $ Syggr yia
- p3 E
i d .
- F :s ae t
- 2*!saiEff 0ia $ !% 8i y c I Ft EI d o . e . i ESE
- e f 2 5
- !
- : ?
I 55
- F
$ 3 E arsay rBE
- s I z5
$ Ei s $
_ I s
? f 15 ! t d E le iI 029 .65 liii iiiiI ' ^ i i i i i $i f ST417 t ols e i ' i i I.
il i i liil a i i i i i
i, i, i li il liil c i i i i i
ii ii i li il liil o , i .. i o i, i, i li il ti i - iliil 0,02 liil ^ i i i i i ( S 0l7iOi lD
- i i,
i i li il e i liil a i i i i i
i i i i i li il liil
i i i i i i i i, i li il - l,,I o , i i i i o ,, ,, , li il D o,2 liil iI,il ^ ii i i i T T Pl7:0hlt i , i i e , ^ a i liil ii i i i li il '
i i , i i li il liil ii i i i c i, i, i I, il liil o e i i i . i, i, i , i i i i li il liil ili l ^ iliil e i ^ i i i i i le il = >
liil i i i i i a i, i, i i i
i(,i l l i i i il i I - i I l i i l i I i o g g _ e oncts stOufNtt n - g g g g g l g l l g g g i - ow-m
- u,,, 4 o,, u c-y,3,9 ic eent, mwww
" wh ATION O8 Df ys&fiON + _ }}