IR 05000413/1990024
| ML20062A102 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 09/27/1990 |
| From: | Hopkins P, William Orders, Shymlock M, John Zeiler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20062A098 | List: |
| References | |
| 50-413-90-24, 50-414-90-24, NUDOCS 9010190077 | |
| Download: ML20062A102 (12) | |
Text
{{#Wiki_filter:k{
i z ' ., j , - israiu4'o
- l UNITED STATES
, -- NUCLEAR REGULATORY COMMISSION ~ p ,. y [ REGION il ,n , '"- 4 gf y, 101 MARIETTA STREET,N.W.
.
g-ATLANTA, GEORGI A 30323 . *? 5^
- ssy,.
. Report Nos.:. 50-413/90-24:and 50-414/90-24 ,.,. ' Licensee:' Duke Power Company.
. P.O. Box ~1007 , Charlotte ~, N.C.
28201-1007 Docket Nos.:~ 50-413 and 50-414 License Nos.: NPF-35 and NPF-52 ~ Facility Name: Catawba Nuclear Station Units 1 and 2
- Inspection Conducte :
A gust 3, 1999 September 5,~1990 . < Inspectors:- [ ' (.4d, k' A 7-9# b< - . <s W. T. O ders,, Senior-Re i t Insgettor Date Signed- -1 &g.f)_ ,/2f f '2 ?' h . P. C. Hopkins, ResiMent I spe ry ~ Date Signed g,l V" A Y YO J. Zeiler, Resident Ihspect ' Date. Signed L' Approved by:- M M7/$7db h86-96 . e M.B.,Shymlockphief.
Date Signed
. Projects Sectiort3A
- l
' Division of Reactor Projects , .R p 3UMMARY, - Scope :'- .This routine, resident' inspection was conducted in'the. areas of-plant ~
- operations;' surveillance; observation; t maintenance' observation; review of licensee eyent reports; followuptof,previously identified items; and
' refueling. outage: activities ' ' ) i Results: One - violation,was. identified invo1Ving two examples : of failure to follow procedures.~ The <two' examples involved a Shift Supervisor. and j.
L-Control Room'0perator who fai. led to ensure that audible count rate was
present in 'the Control Room and Lin Containment when Unit 2.' commenced i core' alterations for loading fuel.
Paragraph 5.b.
Lj ' , i One/ Non-Cited, Violation was identified involving-the failure to
. establish procedures. to' control the alignment -of-the Diesel. Generator
> fuel oil ' storage tanks during reduced. inventory situations.
Paragraph
2.e.
'
.l' l fe
! '
9010190077 901003 PDR ADOCK 05000413 - O PDC ,
en y + e
- ,-
,
c -- e,- )
! j ,
2 .. . c.
A strength was identified involving the-recently established program.of - pre-test "Tailqate" meetings held between testing groups and operations personnel.. "'.ailgate Packages", provided by the testing-group for these = meetings, ' have: become more detailed,.providing operations . personnel with greater understanding-of the the tests will have-on plant systems and components.- The effectiveness of, this program was , evidenced by the successful and relatively-trouble-free completion of the Unit 2 Engineered Safety Features Actuation Test.
Paragraph 3.c..
h ' A strength was also-noted in the licensee's origination of the HVAC.
, Review Committee which was created to resolve problems in the Annulus ! Ventilation (VE) System.
.The program which 'was.L designed by, the ' a connittee to analyze the problems with VE has become the model for completing design basis reviews of ventilation systems.. These' efforts
will; undoubtedly have positive effects on plant operational' status, ~ i Paragraph 6.
,
. . i-i " ly ,
t . ? ' Ii t t )
-)
m.
m _ - , i i t f !;; i
. h, -.S , . . ..e t b, e.1 J Q
. REPORT DETAILS ', -
l ' '1.
Persons' Contacted & Licensee Employees < m B.~ Caldwell,t Station Services Superintendent-6.
'R.- Casler,' Operations Superintendent > 'T.:.Crawford,JIntegrated' Scheduling Superintendent _ ' ' ,
- J. Forbes, Technical Services Superintendent-i
,
- R. Ferguson, Shift Operations Manager
'R.fGlover, Performance Aanager
T. Harrall, Des.ign-Engineering e y
- L. Hartzel1~,' Compliance Manager P
R.. Jones,' Maintenance Engineering Services Engineer > ~ *V King, Compliance F. Mack,: Project; Services Manager
W.:McCollum, Maintenance Superintendent ' .. - *T.1 Owen ; Station Manager ! , '
- Other licensee employees contacted included technicians, operators,
, ' mechanics, security force members, and office-personnel.
, NRC Resident Inspectors '
- W. Orders:
- P.'Hopkins
-*J. Zeiler'
' Other NRC Personnel %
- M..Shym1'ock-
$ '
' * Attended exit meeting.
2.
Plant Operations Review (71707 and 71710)
- a.
.The inspectors reviewed plant operations throughout the report period' l to verify. conformance with regulatory requirements, Technical
,. ' Specifications (TS), and administrative controls.
Control Room logs, i " the ' Technical Specification Action - Item Log, and the removal and restoration log were routinely reviewed.
Shift turnovers were observed
to; verify 1that they were conducted in accordance with approved
- -
procedures. Daily plant status meetings were routinely attended.
j ,
k
.'l4 - i u . . . . >
- . . . . . + .. . ...
' , The -inspectors verified by observation and interviews that measures taken to assure physical-protection of the facility met current- , requirements.
Areas inspected included thel security organization, the i establishment and maintenance of gates, doors, and isolation zones in the proper conditions, and -that access control and badging were proper and procedures followed.
... In addition to the areas discussed above, the areas toured, were observed for. fire prevention and protection activities and radiological control practices.
The inspectors also reviewed Problem Investigation - - Reports to determine if the licensee was appropriately documenting- problems and implementing corrective' actions. ' i , b, Unit 1 Summary ? Unit l' started the report period in Mode 1, at 100 percent power.and ' remained in Mode 1 throughout the period with no major problems. , c.
Unit 2 Summary
Unit 2 began the report period in Mode 6, continuing the refueling i outage which. began on June 10. The outage was relatively unremarkable with no extraordinary modifications or maintenance performed.
The
unit regained -Mode 5,on August 17.
The Engineered Safety Features (ESF) Actuation ' Test was successfully completed on August 26 with l relatively few problems.
Mode 4 was entered on September 3, and current plans are to have the unit back on line by September 16.
d.,1 Unit 2 Mid-loop Operations
h During:the Unit 2 refueling outage, the inspectors witnessed operating J L, conditions during periods of reduced. ReactorrCoolant (NC) System ~ l inventory, paying special attention to the entrance into and operating . in mid-loop operations.
Administrative controls and controlling procedures governing mid-loop ' operations were reviewed in detail < ,. l previously and the results documented in NRC Inspection Report 50-4134 l 414/90-11.
, The inspectors verified that required instrumentation was installed and operating reliably to monitor NC ' system level and temperature"during - ,' reduced inventory conditions.
Completed ' procedures for Containment u closure were reviewed to ensure that Containment integrity was achieved L' before entry into these conditions.
The inspectors verified that the > licensee maintained at least two means of supplying inventory to the NC system to mitigate 1the consequences oof a loss of normal Residual Heat
Removal cooling.
Further, the licensee avoided operations that could i have led to NC system perturbations.
-
e w -
' + < > a - '
. .
. r
y ,
e
, -, e._ Diesel Generator-Fuel Oil Supply Availability ~ On' August 22, while conducting a routine safety system walkdown of the ~ .. ._ ' J~ Unit 2 Diesel Generators (DGs), the inspectors noticed that the 2A and 28 DG Engint Fuel Oil Systems were in what appeared to be an abnormal alignment.
Specifically, one of the two main fuel oil storage tanks feeding each DG-was -isolated by its manual -outlet valve.
A similar t alignment was found on Unit 1 DGs.
The inspectors discussed the
observation with the licensee.
It was noted that in-this alignment, ! only one storage tank, with a capacity of 45,000 gallons of fuel,;would be available automatically to supply fuel to_ its respective DG engine-during accident situations.
The inspectors also noted that there did not appear to be clear procedural guidance.to align the isolated tank during an emergency.
.' Each DG engine is provided with a se)arate fuel oil storage and transfer system.
Two underground fue' oil storage tanks provide a combined' capacity sufficient to operate the DG engine at full load for ' seven days.
< Technical Specifications 3.8.1.1.b and 3.8.1.2.b requires that in Modes 1 through 6,. at least one DG be operable with a separate fuel oil-storage system containing a minimum of 77,000 ga~ilons of fuel to provide for a seven-day supply of fuel oil for each engine..In the licensee's present fuel oil system alignment, the second fuel oil storage tank would have to be manually aligned to its respective diesel engine to meet the seven day requirement.
After a review of the DG Fuel Oil system as dese"ibed u: the FSAR, and i ' discussions with NRR/PSB, it was' concluded that although it would be _; prudent to have both fuel oil storage tanks aligned during normal' operation, it seems reasonable to allow single tank align'nent,' as long as adequate _ administrative controls 'are in place to, ensure that the second tank is aligned correctly when'needed.
- The inspectors reviewed OP/2/A/6550/01, Diesel Generator Fuel' Oil System Operation, Enclosure 4.2,- which provides control of the normal
. alignment of the fuel storage tank isolation valves.
The enclosure ensures-that _one of the -storage tank's isolation valves are open during - normal operation.
However, the procedure did not provide controls to ensure that the second storage ' tank would be aligned when needed.
Also, review of the low level annunciator responses for the fuel oil storage tanks -indicated that there were no provisions for directing- , personnel to swap to the second storage tanks when the level in the + .normally aligned tanks are low.
Before the end of the report period, the licensee had initiated efforts to enhance station procedures and the annunciator responses to ensure control of the supply of fuel oil from the fuel oil storage tanks.
w
a , s.
- ,r -. - . . s .- .4 .- . This issue was identified as a violation of the requirements of Technical Specification 6.8.1 whiche requires in part that written-procedures be established, implemented and maintained: covering operation of safety related equipment. 'However, after review of-the circumstances' relative to this-issue and the criteria specified -in Section V.A. of the NRC Enforcement Policy it was determined that this violation will not be cited. This is documented as Non-Cited Violation ~ -(NCV) 413, 414/90-24-01: Failure to Establish Procedures to Control-Alignment of the DG Fuel Oil Storage System.
3.
Surveillance Observation (61726) During the. inspection period, the inspector verified plant operations a.
were in; compliance with various TS requirements.
Typical of-these requirements were confirmation of compliance with the TS for reactor coolant chemistry, refueling water tank, emergency power systems, safety injection, emergency safeguards systems, control room ventilation, and direct current electrical power sources.
The inspectors verified that surveillance testing was performed in accordance with the approved written procedures, test instrumentation was calibrated, limiting conditions for operation were met, appropriate . removal and restoration of the affected equipment was accomplished, . test results ' met ~ acceptance criteria and were reviewed by personnel-other than the individual directing the test, and that any deficiencies identified during the testing were properly reviewed -and resolved by appropriate management personnel, b.. The-inspectors witnessed or reviewed the following surveillances: PT/1/A/4350/02B Diesel Generator 1B Operability Test PT/1/A/4200/02A Monthly Outside Containment Integrity Verification PT/1/A/4200/06A Boron injection Valve Lineup Verification PT/1/A/4200/62 RN to NW Flow Verification PT/1/A/4600/02A Mode 1 Periodic. Surveillance Items PT/1/A/4600/01 RCCA Movement Test PT/1/A/4250/02B.
Weekly Main Turbine Valve Movement PT/1/A/4450/13B Unit 1 Auxiliary Feedwater Pump Room'C02
' Weekly Test PT/1/A/4550/04 Diesel Generator Fuel Oil-Storage Tank Water Inspection PT/1/A/4450/09A Spent Fuel Ventilation System Train A Operability Test PT/2/A/4200/02H Containment Closure Verification (Part V) PT/2/A/4350/03 Electrical Power Source Alignment Verification PT/2/A/4450/09B Spent Fuel Ventilation System Train B 0,erability Test I. i . . ' ... . . ..
j
' PT/2/A/4550/04 Diesel Generator Fuel _011 Storage Tank Water Inspection PT/2/A/4600/19E-Premode 5 Periodic. Surveillance. Items 'PT/2/A/4600/02E Mode 5 Periodic Surveillance Items
PT/2/A/4350/02A Diesel Generator l2A Operability Test i PT/2/A/4200/09 Engineered Safety Features Actuation Periodic Test-L PT/2/A/4350/02E CA, CF, and Turbine Interlock Periodic Test : ! c.
Engineered Safety Features Actuation TestL i The Resident Inspection staff witnessed the' performance of the' Catawba , Unit 2 Engineered Safety. Features Actuation ~ Periodic Test.. The- -{ inspection efforts included but were not ' limited to the. verification - that:- the' procedure had undergone the proper review and received i - ! the necessary approval, the procedural ~ test requirements. were consistent with- - regulatory requirements, licensee commitments, and administrative controls minimum test crew requirements were met ) - test prerequisites were completed -- required data was recorded for final review and analysis by f - l proper' personnel
system component restoration to normal operation. was - - accomplished.upon completion of surveillance testing or as
' required by TS ! ' the qualifications of the inJividuals participating in the- ! , - test were appropriate, and . the' test.results and data appear' adequate ' - '$ The test is divided into.three main sections; a simultaneous LOCA and Blackout, a LOCA without a Blackout and a Blackout without a LOCA.
J A In the first section, the test verifies that ESF components actuate . correctly to their safety position within their required time limits in response to a _ Safety Injection, Phase A Isolation, Phase B Isolation, and'a Blackout, as well as verifying the proper operation of the D/G.
t The next section is-essentially a repeat of the first, except there is no blackout _of the_ essential _ switchgear.
! i %
y , . !h , , 's-o , -.e . , , .- . m
u .. - - The last _ major section of the test verifies proper D/G starting, load-shedding, and load sequencing in rcsponse to a blackout.. q Throughout the test, correct valve, movements, response times, and system responses are verified.
It should' be noted that this is the first time this test-has been - performed since the procedure was re-written to facilitate running it at the' conclusion of the refueling outage as opposed to the beginning: of an outage.
' < ' It should also be noted that the licensee has implemented a program of pre-test " tailgate" meetings.
The purpose of the meeting is to have participants in major test evolutions briefed prior to the start of a test such that each knows what to expect, and to raise any questions or.
CoHcerns., it is believed that the combination of the revised procedure and the tailgate meetings led to the successful and relatively trouble freeJ , completion of this test.
NoEviolations or deviations were identified.
4.- Maintenance'0bservations(62703) ' . a.
Station maintenance-activities of selected systems and components were.. , L observed / reviewed _ to ascertain that they were conducted in accordance i
- with _ the requirements.
The inspectors ' verified. the following: ' activities wereL accomplished using approved procedures;. functional stesting ; and/or calibrations ' were performed prior to returning ~ ~ '. components or systems ~ to service; quality ~. control records were . maintained; a:tivities _ performed were : accomplished by' qualified
, L pers.onnel; and materials used were properly certified.
Work requests .j , C H were. reviewed'to determine the status of outstanding jobs and to assure that priority was assigned to safety-related equipment: maintenance
L which may effect system performance.
, V b.
The= inspectors witnessed or reviewed the following maintenance , activities: Ei 47025 OPS Investigate / Repair Chiller Failure to Start , 06605 MNT Inspect / Replace. Fan Belt and Filter on Incore Instrument Air Handling Unit 2A " 54015' OPS Investigate / Repair Compressor Failure on ITB-AHU-4 28267 OPS Investigate / Repair Auxiliary Building ? ' Ventilation Problem - 'No violations or deviations were identified.
, ... J m '
_ - < t , y . ' ' ] y .- . '
. , ( 5; ReviewofLicenseeEventReports(92700) r a.
The below listed Licensee Event Reports (LER) were reviewed to l determine if the information provided met' NRC requirements.
The ! r - determination -included: adequacy of description, verification of- ! compliance with Technical Specifications and regulatory requirements - corrective action taken, existence of potential generic L problems, reporting ~ requirements satisfied, and the relative safety significance =of each event.
Additional inplant reviews and discussion with plant ' personnel, as-appropriate, were conducted.
The -following LERs are y closed: .LER 413/89-07 Failure of the Turbine Driven Auxiliary ' Feedwater Pumps Due to Stress Corrosion _ l Cracking of the Final Stage Shaft Sleeve.
-l
LER 413/89-12 Potential Relief Path From Containment Sump .i to the Refueling Water Storage Tank During j n Cold Leg Recirculation.
LER1413,414/89-10 Technical Specification" Required Unit ~ Shutdown Due to Control-Room Area Air Handling l Unit Motor Malfunction.
LER 413/89-21: Technical Specifications Required-Power i Reduction Due to Failure of Two Refueling-Water Storage Tank Level-Channels Caused by Lightning.
LER_413/89-27 Technical Specification Requires Unit Shutdown-Due to an Inoperable Chemical and i Volume Control System Centrifugal Charging _- ' Pump.
LER 413/89-29 Potential Inoperability of Component . ] ' Cooling Isolation Valves Due' to Age Hardened Elastomeric Seat Material, j f-LER 413/89-28 Technical Specification. Violation as a ' , Result of Loss of Train A Main Steam Isolation for Steam Generator Power Operated Relief q Valve Due to a Failed Fuse,
l.ER414/89-21 Technical Specification Violation for ) Greater than 15 Percent Power Reduction
Without lodine Sample due to Inappropriate l Action.
! ,
$ L
h . . -..
. . -
-. - < . b.
-Source Range Neutron Flux Monitor Inoperability.
On July 22, at approximately 11:59'p.m., the on-duty Shift. Supervisor, who was working to prepare the unit for core reload, verified and documented by sign-off in operating procedure OP/2/A/6100/02, Controlling Procedure for Unit Shutdown, that two Source Range Neutron Flux Monitors -(SRNF) were operable with audible indication in the
Control-Room and in Containment.
Approximately an hour and a ; half , later at approximately 1:37 a.m.,: the on-duty Control Room Operator ' (CRO) likewise verified and documented by sign-off -in procedure PT/2/A/4600/19F, Pre-mode 6-Periodic Surveillance Items, that the SRNF Monitors were operable with audible indication in the control room and-containment.
At 5:26 a.m.- that same morning, the unit commenced core reload.
'At' - approximately 7:15 a.m., the oncomMg Shift Supervisor (shift change-nl was at 7:00 a.m.)' questioned the Contal Room Operators about the lack , of audible. SRNF count rate indication i.1 the Control. Room.
A subsequent-investigation revealed that the P.NF Monitor's audio, multiplier switch was in the off position, which rendered the audio . ! function of the monitors inoperable.
The switch was immediately placed.
I in the appropriate. position to obtain the' required audible count rate.
It was subsequently learned that on July 10, 1990, with Unit 2 - i defueled, both trains of the Baron Dilution Mitigation System (BDMS) ' had-been 'placed in the -" defeat" mode and were declared inoperable . due. to both trains. reading less than.the required-one-half decade above , the-steady-state count rate. Both trains remained inoperable from this date through the commencement of core reload on July 23.
_ The inspectors discussed this incident with both the Shift Supervisor
and Control Room Operator involved.
Both had failed to recognize that ' the SRNF Monitor's audio multiplier switch had been placed in the off-position. - In _ this position, continuous visual. indication in the Control Room was still-present, but' audible ~ indication in the Control
Room and in Containment was disabled.
The inspectors,were told that the audio output had apparantly been turned off after the' unit had been , defueled during which time the SRNF. Monitors were not required. It is , hypothesized that someone turned the switch off due to the annoyance of the audible background count' rate heard in the Control Room.
, Technical ' Specification 3.9.2.1 requires two trains of the Boron Dilution Mitigation System (BDMS) be operable and operating when the i unit is in mode 6.
-If one or both trains of BDMS is inoperable, both Source Range Neutron Flux (SRNF) Monitors are required to be operable with continuous indication in the Control Room, as well as audible ', indication in the Control Room and in Containment.
' - -
~ ' Y -' -
a.
, . - y . e .t ,
. .Techiiical _ Specification 6.8.1 requires in part - that procedures be established, implemented and maintained covering plant operations. = The' Shift Supervisor failed to follow operating procedure OP/2/A/6100/02 in.
' that the sign off in the procedure indicated that the' verification of the required audible' SRNF indication was operable when in fact it was not.
Similarly, the CR0 failed to follow PT/2/A/4600/19F in that the sign off in the procedure verified-that the required audible - indication was operable when in fact it was not.
This issue is considered a violation of, the requirements of TS 6.8.1 and represent , two examples.which collectively constitute Violation 414/90-24-02: t Failure.to Follow Procedures.
' L '6.
.HVAC Review Committee Catawba has-experienced several significant problems involving ventilation systems during the past year. As a result of these problems the licensee has formed a committee to identify, mitigate and/or prevent future problems.
The-basic a)proach of the comittee includes but ~ is not limited to~ validating tie analysis presented in the Final Safety Analysis Report (FSAR) for each selected system and then ensuring that periodic testing of the system adequately challenges the design basis.
The design basis 1 review was first performed on the annulus ' ventilation system (VE). - Each component in the VE system was scretinized including . postulating different failure modes.
The effects of eacn of these failures
- was then compared against a pre-established set of iimiting failures for the system's operating modes.
The'results of the review indicated among other things a need to improve the periodic testing designed to verify the integrity of the annulus pressure boundary.
Based on the analysis performed on the VE system, the Review Conri+ tee h: 3 been tasked with performing similar analyses of the Auxiliary Bv.lding, Control Room, Annulus, Fuel Pool, Containment Purge, and Containment Air . Return _ Ventilation Systems This initiative is considered a strength, 7.
Exit Meeting The inspection scope and findings were sunearized on September 5, 1990, with s those persons-indicated '.n paragn ph 1.
The inspector described the areas inspected and' discussed in detaii the inspection findings listed below. No dissenting comments were received from the licensee.
The licensee did not identify as proprietary any of the materials provided to or reviewed by the ~ inspectors during this inspection.
! k) _ ,_
w_,.x.
- - - $c - . - - - - - - - m - - - - - . . > ' ', (f.f,.4, +f;'_ s,H, . ,. -r . . .h +3 e - ,
t j 'y ' ,
- s
, ~' t"# gQ %
. ', ^~ lg 'y g '-_ >. - -. T -- _p - h,
- j,,
, - - - < ' -y _ n . qpe ,,,
- Q ".
.. < - +
y)
- <
- -. : . , _ -; + , y, ; ;- ).. , '
- _ > e . , , ,- [,8-r[ l -[ -,. <
- .
- ...
t } g } ,- '" I . "
. - r <4
- , s
.'I m.. +. q,
- :
- 10;
. ., , , , . e.... !- .3t - .. -ci -# , / , ['. .n m [c r:$w~n,~ . [ItemNumber- - Description'and-Reference i ' A , i y Failureto Establish Procedures to Control ! l <- - ^ ' ' ' 413J414/90-24-01. ' =Alignment Lof' the-. DG Fuel 011 Storage SystemsU l ze , , . Paragraph 2 e-
' , . . ,_\\ I ) ,r.i'_' g-b . - - Failure to Follow' Shutdown an'd Surveil' lance? A ~ M - , . .s' - VIO 414/90-24-02L ~'
. ' ' Procedures. Paragraph 5.b j . ,
i, e-a.
v - ef r , w , - -f, p r r p.f.... _ t +b - \\ n - a
,
' s t ! ' ' ) i + f ..l.
- s
't h N ,' .y I.'1 l y
- i
- !'-
,g .[t
- , ' -m?y
- , ',
e f. - l.f, ' i ... < h '-._.\\ - ., ; i o ~ il g , . . L 'i{l
4 -
.'.k e .h h- ' k.a
a: ' r- . . . o - g/
, , ' y-i I.
,1 a ,,. i 3.. ' i=
. 4- , ,- v.
,- i - [ h ' ' -5[, ,
,p - ,
i
,... t t @ gh i > , ' , ' ..:,1 ' ; !.'; ' S
- ; p:.,
" , r. ,, .[ s , . IGj ' , n i' , ,, ,
- '.
V
I# y.p <j.1 ' .:4,; .., ' , j .9 i ;.. ' . . . ..s , . g.
' y.. .,
- .' -.
. > < y p;i, * * k j.,jf.;$[',
.d l} . + W,l% o , ' ' ' + ? y,C_ U ? v l' n s , . c. r a - + s , hi, 5.I,' .} lq n,, ,
T$ ' y i , hf I
' i
, .g ,_ , x<, ' w.. g n". _, . . . jp sq <, - n $ [ , ., ' j yb . !/ f.1' . [ p{..i :,' r. 3 ' .,r } t .., . $
- L^
,_s , ! e ('. r, 4, e.
p + ,., I \\ ' t > \\ . .. a i ' ' '
, -.. E o i i N 5' - 4 '...a
- ,;
- ! '. t. e i.: * ' ;..-ff.
.,, y I
f* . V.
. , .II';I =
1 -,., - ss . I I + ! , i 'N I 1, k i.-,
- t 3$ f:)h,.1If
~ ,
-)
5' _ l , !_;.a g.
- i
?... i ,i Qu y :.'... i '.V- .' _, _ _ __, k }}