ML020440321

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Transmittal of Revised Emergency Plan Implementing Procedure RA-EP-02010 (Revision 2) Pages 1 - 4, 12 -16, 17 - 22 for Davis-Besse Nuclear Power Station
ML020440321
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 01/15/2002
From:
FirstEnergy Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML020440321 (16)
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Text

_JV __4ý PAGE TRANSMITTAL/RECEIPT ACKNOWLEDGMENT DATE IPAGE /d ED 7676-2 TO

=4 COPY NO. I /IS A;L TRANSMITTAL NO4_

LOCATION/MAIL STOP NO. FROM DOCUMENT(S) TRANSMITTED DESCRIPTION El SAFEGUARDS INFORMATION - HANDLE AND CONTROL IN ACCORDANCE WITH NG-IS-00001 El COMPLETE SET/MANUAL PER TABLE OF CONTENTS/INDEX REVISION El NEW OR REVISED DOCUMENT(S)

LI CHANGE DOCUMENT(S)

El OTHER I NUMBER TED OF TED 5--INSERT 2-REMOVE AND DESTROY. IF COPIES ARE RETAINED. OF I

MARK ACCORDINGLY COPY Z~ATTACH ICP COPIES

[REMOVE AND RETURN TO DOCUMENT CONTROL WITH THIS TRANSMITTAL NO. L OTHER NO ISSUED

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4 As the recipient of any transmitted document(s) listed you are responsible for their control and maintenance. I Rs transmittal Torrn is required to be signed, dated, and returned to:

DAVIS-BESSE NUCLEAR POWER STATION ATTENTION: DOCUMENT CONTROL 5501 N. State Route 2 Oak Harbor, Ohio 43449 Mail Stop HNo/,** _._-- * , --

cancelled, I acknowledge receipt of this update notification and/or the document(s) listed and certify that: 1. Resulting superseded, voided, or incorporated documents have been marked accordingly; 2. Changes have been inserted or attached as required;

3. Removed documents have been destroyed or returned as directed.

NOTE: DESTROY SAFEGUARDS INFORMATION BY SHREDDING. i flAT*

RECIPIENT (Signature) f-ý'oý 5"

Page 1 of 36 Davis-Besse Nuclear Power Station EMERGENCY PLAN IMPLEMENTING PROCEDURE RA-EP-02010 (Supersedes RA-EP-02010, RI)

Emergency Management REVISION 02 Prepared by: i 06 , /C 2e (51 Date Sponsor:

Date Approved by: 7244- --9A Director - Engineering & Services Date z--IV, /

Approved by: L P t/ anager Date' Effective Date: t?,/ 9 9 __

Procedure Classification:

X Safety Related LEVEL OF USE:

Quality Related IN-FIELD REFERENCE

___ Non-Quality Related

EMERGENCY MANAGEMENT 2 RA-EP-02010 Revision 02 Change E-1 T'TT T IZ rT17TM nrTTXIJ PDAC1ýT7 Page Change No. Page Change No. Page 1 Change No.

1 23 2 E-1 24 E-1 3 E-1 25 4 E-1 26 5 27 E-1 6 28 E-1 7 29 E-1 8 30 E-I 4

9 E-1 31 10 E-1 32 E-1 II E-1 33

.4-12 E-1 34 E-1

+

13 E-1 35 E-1 14 E-1 36 15 E-1 16 E-1 i

17 E-1 i

18 19 20 E-1 21 E-1 i

22 E-1

EMERGENCY MANAGEMENT 3 RA-EP-02010 Revision 02 Change E-1 TABLE OF CONTENTS Page 1.0 PUR P O SE ............................................................................................................................................. 4

2.0 REFERENCES

...................................................................................................................................... 4 3.0 DEFINITIONS ...................................................................................................................................... 5 4.0 RE SPONSIBILITIES ............................................................................................................................ 5 5.0 INITIATING CONDITIONS ....................................................................................................... 5 6.0 PROCEDURE ....................................................................................................................................... 6 6 .1 Activation ................................................................................................................................. 6 7.0 FINAL CONDITIONS .......................................................................................................................... 6 8.0 RE COR D S ........................................................................................................................................... 6 ATTACHMENT 1. Emergency Management Guidelines for Emergency Director .............................. 7 ATTACHMENT 2. Emergency Management Guidelines for Emergency Plant Manager .................. 12 ATTACHMENT 3. Emergency Management Guidelines for Emergency Offsite Manager ................ 17 ATTACHMENT 4. Emergency Management Guidelines for Company Spokesperson ....................... 23 ATTACHMENT 5. Emergency Management Guidelines for Emergency Assistant Plant Manager ..... 27 ATTACHMENT 6. Overview of Assembly/Evacuation/Accountability ........................................... 31 ATTACHMENT 7. AEOF Activation and Operation ......................................................................... 32 ATTACHMENT 8. Guidelines for Shift Turnover .............................................................................. 34 COMMITMENT S ...................................................................................................................................... 36

I :IvmIGK'ANLC MANAUtGIVLIN 14 RA-EP-02010 Revision 02 Change E-1 1.0 PURPOSE This procedure establishes a reference aid for key Emergency Response Organization personnel that consolidates the action steps of each individual during the first phase of any emergency response. It is intended to supplement the individual's familiarity and compliance with the plan and implementing procedures by providing a memory key and guideline for the manager's initial responses.

2.0 REFERENCES

2.1 Developmental 2.1.1 Davis-Besse Nuclear Power Station Emergency Plan 2.1.2 Corporate Emergency Response Plan 2.2 Implementation 2.2.1 NG-IS-00004, Fitness for Duty Program 2.2.2 RA-EP-00600, Emergency Facility and Equipment Maintenance Program 2.2.3 RA-EP-01500, Emergency Classification 2.2.4 RA-EP-01600, Unusual Event 2.2.5 RA-EP-01700, Alert 2.2.6 RA-EP-0 1800, Site Area Emergency 2.2.7 RA-EP-01900, General Emergency 2.2.8 RA-EP-02000, Medical Emergencies 2.2.9 RA-EP-021 10, Emergency Notification 2.2.10 HS-EP-02230, Dose Assessment Center Activation and Response 2.2.11 RA-EP-02245, Protective Action Guidelines 2.2.12 RA-EP-02520, Assembly and Accountability 2.2.13 RA-EP-02530, Evacuation 2.2.14 RA-EP-02620, Emergency Exposure Controls and Potassium Iodide Distribution 2.2.15 RA-EP-02710, Reentry 2.2.16 RA-EP-02720, Recovery Organization 2.2.17 RA-EP-02800, Preparation and Transport of Contaminated Injured Personnel 2.2.18 RA-EP-02950, JPIC Activation and Response 2.2.19 DB-OP-00002, Operations Section Event/Incident Notifications and Actions 2.2.20 Davis-Besse Emergency Plan Telephone Directory

EMERGENCY MANAGEMENT 12 RA-EP-02010 Revision 02 Change E-1 Emergency Management Guidelines For Emergency Plant Manager ALTERNATES: As listed in Emergency Plan Telephone Directory, Section 3 DUTY LOCATION: Technical Support Center PRIMARY DUTY: Coordination and conduct of:

1. Plant Operations
2. Plant Assessment
3. Emergency classification associated with plant parameters.
4. Onsite actions to mitigate and terminate the emergency event.
5. Provide input to protective action recommendations based upon plant parameters.

NON-DELEGABLE RESPONSIBILITIES:

1. IF delegated by the Emergency Director, THEN the responsibility of authorizing emergency dose and distribution of Potassium Iodide (KI) cannot be re-delegated.
2. Reentry operations into evacuated areas shall be approved by the Emergency Plant Manager.

DIRECT REPORTS:

1. Emergency Assistant Plant Manager
2. Emergency Radiation Protection Manager
3. TSC Engineering Manager
4. OSC Manager
5. Emergency Security Manager
6. Recovery Advisor.

Attachment 2 Page 1 of 5

EMERGENCY MANAGEMENT 13 RA-EP-02010 Revision 02 Change E-1 RESPONSE TO CLASSIFIED EVENTS This procedure is provided as a guide to assist in performing the various activities associated with an Emergency Response in the event of an incident at the Davis-Besse Nuclear Power Station. Refer to the appropriate emergency classification heading and carry out the actions identified under it.

Unusual Event RA-EP-01600 A. IF a meaningless "Group" pager display appears on your pager, THEN call the Computerized Automated Notification System to verify that an emergency does not exist at the station.

B. Upon being notified of an Unusual Event (1111 on your pager), call the Computerized Automated Notification System to indicate you have been notified.

C. Contact the Control Room and discuss the nature of the incident with the Emergency Director (Shift Manager).

1. Review the existing plant conditions and verify that the appropriate Emergency Classification has been made.
2. Determine any need for additional manpower or logistical support that may aid the Emergency Director (Shift Manager) in correcting the situation.
3. Through discussion attempt to determine the length of time anticipated until downgrading is possible.
4. Using the Emergency Director Turnover Data Sheet, ED 8122, review each of the areas listed on the sheet with the Emergency Director (Shift Manager) and complete the form.

NOTE D.

The Davis-Besse Public Affairs Duty Officer (PADO) telephone number is found on the ED/EPM/EOM pocket call card and in the Emergency Plan Telephone Directory.

D. Call the Davis-Besse Public Affairs Duty Officer voice mail box and provide a brief summary of the event, and a point of contact for requesting additional information.

Attachment 2 Page 2 of 5

EMERGENCY MANAGEMENT 14 RA-EP-02010 Revision 02 Change E-l RESPONSE TO CLASSIFIED EVENTS Unusual Event RA-EP-01600 (Cont.)

E. Contact the on-call Emergency Director and review the information outlined on the Emergency Director Turnover Data Sheet, ED 8122.

1. Review the actions being taken to resolve the situation and provide an estimate of how long the station will be in this emergency classification prior to downgrading.
2. Exchange telephone numbers and points of contact for future discussions as the situation develops.

F. Continue to monitor the progress of the situation through follow-up discussions with the Emergency Director (Shift Manager).

G. No further action is required in response to an incident at this classification level.

Alert RA-EP-01700, Site Area Emergency RA-EP-01800 &

General Emergency RA-EP-01900 A. Upon being notified of an Alert (2222 on your pager), Site Area Emergency (3333 on your pager), General Emergency (4444 on your pager), call the Computerized Automated Notification System to indicate you have been notified and provide the system with your estimated travel time (in minutes) to the Technical Support Center.

NOTE B.

The Davis-Besse Public Affairs Duty Officer (PADO) telephone number is found on the ED/EPM/EOM pocket call card and in the Emergency Plan Telephone Directory.

B. Call the Davis-Besse Public Affairs Duty Officer voice mail box and provide a brief summary of the event, and a point of contact for requesting additional information.

C. Report to the Technical Support Center (TSC).

D. Upon arrival at the TSC, contact the Control Room and discuss the nature of the incident with the Emergency Director using the Emergency Director Turnover Data Sheet, ED 8122, as a guide.

1. Determine the immediacy of the need to shift the responsibilities of the Emergency Director to either yourself or the Emergency Assistant Plant Manager in the absence of the on-call Emergency Director or one of his alternates.
a. IF it is necessary to relieve the Shift Manager of the Emergency Director responsibilities and the Emergency Assistant Plant Manager has not arrived, THEN proceed to the Control Room and relieve the Shift Manager as Emergency Director.

Attachment 2 Page 3 of 5

EMERGENCY MANAGEMENT 15 RA-EP-02010 Revision 02 Change E-1 RESPONSE TO CLASSIFIED EVENTS Alert RA-EP-01700, Site Area Emergency RA-EP-01800 &

General Emergency RA-EP-01900 (Cont.)

b. IF the Emergency Assistant Plant Manager (EAPM) has arrived, THEN you may remain in the TSC, and the EAPM may relieve the Shift Manager as Emergency Director as needed.
c. IF the on-call Emergency Director has been delayed, but adequate staffing has arrived to activate the TSC and ECC, THEN activate the TSC and ECC and relieve the Control Room of Emergency Director responsibilities.
d. The Emergency Director shall remain in the Control Room until the TSC and ECC have been activated.
2. IF you are not required to proceed to the Control Room, THEN review the existing plant conditions and verify that the appropriate Emergency Classification has been made.

E. Upon the arrival of the Emergency Director and Emergency Offsite Manager, review the current status of the situation. Assist the Emergency Director in preparation for shifting the responsibilities from the Control Room.

F. Activation and management of the TSC is the responsibility of the TSC Engi neering Manager. Upon being notified of the activation of the TSC by the TSC Engineering Manager, ensure that the following individuals are informed:

1. Emergency Director
2. Emergency Offsite Manager
3. Emergency Assistant Plant Manager
4. Emergency RP Manager
5. OSC Manager NOTE F.6 Announcements that are intended for the emergency organization in the DBAB are to be made using the ERF Public Address system. Only the north end of the DBAB 1st floor is covered by this system. The Protected Area cannot be contacted using this system.
6. Make a general plant announcement.

Attachment 2 Page 4 of 5

EMERGENCY MANAGEMENT 16 RA-EP-02010 Revision 02 Change E- 1 RESPONSE TO CLASSIFIED EVENTS Alert RA-EP-01700. Site Area Emergency RA-EP-01800 &

General Emergency RA-EP-01900 (Cont.)

G. With the activation of the TSC you are responsible for the coordination and conduct of all activities associated with plant operations. These responsibilities include:

1. Continuously monitoring plant conditions/radiological conditions and ensuring that the Emergency Director remains apprised of specific plant conditions which impact the Emergency Classification and Protective Measures (onsite and offsite).
2. Assuming the responsibility, if delegated by the Emergency Director, for authorizing emergency radiological dose in excess of 10 CFR 20 limits and also the distribution of Potassium Iodide to onsite personnel. These responsibilities may not be delegated to any other individual.

H. When directed by the Emergency Director, coordinate with the Emergency Security Manager to accomplish assembly and accountability of all personnel within the protected area. REFER TO Attachment 6, Overview of Assembly/Evacuation/Accountability for overview of these activities.

Notification of American Nuclear Insurers (ANI) is required at an Alert, Site Area Emergency and General Emergency classification.

REFER TO Section 2 of the Emergency Plan Telephone Directory for contact names and telephone numbers. After notifying ANI, contact the Corporate Risk Department.

J. For events which involve damage to Davis-Besse property, advise Nuclear Electric Insurance. Refer to Section 2 of the Emergency Plan Telephone Directory for telephone numbers.

K. Periodically meet with the Emergency Director and Emergency Offsite Manager to review the status of the situation and progress toward resolution.

L. Periodically conference with the following individuals to review actions being implemented and to ensure a coordinated response by each group:

1. Emergency Assistant Plant Manager
2. Emergency RP Manager
3. TSC Engineering Manager
4. OSC Manager
5. Emergency Security Manager M. Ensure that periodic updates are given to the onsite organization as appropriate, using the ERF PA system.

N. Ensure that the TSC Administrative Assistant maintains a log of all actions and decisions made during the course of the response.

0. You are responsible for determining when stabilization of plant conditions has occurred. REFER TO RA-EP-02710, Reentry, for guidance in this area. You are also responsible for informing the Emergency Director of conditions that support recovery.

Attachment 2 Page 5 of 5

EMERGENCY MANAGEMENT 17 RA-EP-02010 Revision 02 Change E-1 Emergency Management Guidelines For Emergency Offsite Manager ALTERNATES: As listed in Emergency Plan Telephone Directory, Section 3 DUTY LOCATION: Emergency Control Center PRIMARY DUTIES:

1. Communications and information flow with corporate, offsite and regulatory agencies.
2. Overview of EALs associated with radiological releases.
3. Making recommendations to the Emergency Director concerning PARs.
4. Inputs to the Emergency Director concerning EALs and classification of the event.

DIRECT REPORTS:

1. NRC Liaison
2. ECC Operations Advisor
3. Dose Assessment Coordinator
4. Emergency Planning Advisor
5. Emergency Facilities Services Manager Attachment 3 Page 1 of 6

18 RA-EP-02010 Revision 02 Response To Classified Events This guideline is provided to assist in performing the various activities associated with an emergency response in the event of an incident at the Davis-Besse Nuclear Power Station. Refer to the appropriate emergency classification heading and carry out the actions identified under it.

Unusual Event RA-EP-01600 A. IF a meaningless "Group" pager display appears on your pager, THEN call the Computerized Automated Notification System to verify that an emergency does not exist at the station.

B. Upon begin notified of an Unusual Event (1111 on your pager), call the Computerized Automated Notification System (CANS) to indicate you have been notified.

C. If you suspect that CANS is not functioning properly, direct an individual to go to the TSC Library and check CANS.

D. Contact the Emergency Plant Manager, review the items listed on the Emergency Director Turnover Data Sheet, ED 8122. If the Emergency Plant Manager cannot be contacted, then contact the Emergency Director in the Control Room.

E. Contact the on-call Emergency Planning Advisor:

1. Provide an update on the cause and status of the Unusual Event.
2. Request the on-call Emergency Planning Advisor contact Ottawa and Lucas County EMA officials and verify that initial notifications were received and any questions were answered.

F. Contact the Ohio Emergency Management Agency Duty Officer listed in Section 2 of the Davis-Besse Emergency Plan Telephone Directory and verify that the initial notifications were received and any questions answered.

G. Verify that the Senior Vice President - Nuclear has received follow-up information on the Unusual Event.

H. Continue to monitor the progress of the situation through follow-up discussions with the Emergency Director as the situation warrants.

1. Upon downgrading, contact the personnel that were called in Steps F and G and ensure any questions are answered and the situation is understood.

J. Send personnel to the station, as appropriate, to collect the various logs, records, reports, etc.,

for review.

Attachment 3 Page 2 of 6

19 RA-EP-02010 Revision 02 Alert RA-EP-0 1700, Site Area Emergency RA-EP-0 1800 &

General Emergency RA-EP-01900 A. Upon being notified of an Alert (2222 on your pager), Site Area Emergency (3333 on your pager), General Emergency (4444 on your pager), call the Computerized Automated Notification System to indicate you have been notified and provide the system with your estimated travel time (in minutes) to the Emergency Control Center.

B. Report to the Emergency Control Center (ECC).

C. Contact the Emergency Plant Manager, review the items listed on the Emergency Director Turnover Data Sheet, ED 8122. If the Emergency Plant Manager cannot be contacted, contact the Emergency Director in the Control Room.

D. Verify the minimum required ECC staffing in the following functional areas:

1. Emergency Offsite Manager
2. Emergency Planning Advisor
3. Dose Assessment Coordinator and Dose Assessment Staff
4. NRC Liaison
5. State and County Communicator E. Declare the ECC activated when minimum staffing has arrived, the offsite communication links are functioning, and the current plant situation is understood.

F. Make the following or similar announcement on the Emergency Response Facility Public Address (ERF PA) System:

"THE EMERGENCY CONTROL CENTER IS ACTIVATED AT (TIME). (NAME) IS THE EMERGENCY OFFSITE MANAGER."

G. Notify the Emergency Assistant Plant Manager of ECC activation.

H. Monitor the status of key ECC tasks by using the Problem Analysis Board, as needed.

I. As appropriate, direct the Emergency Facility Services Manager or assigned individual to communicate with the supplementary JPIC personnel which assemble in the Energy Education Center (EEC) during normal working hours. Consider having the EEC establish a communicator on the Public Information Loop Telephone System.

J. Periodically conduct briefings with personnel in the ECC and Dose Assessment Center on emergency status. Use the Emergency Director Turnover Data Sheet, ED 8122, for information, as applicable.

Attachment 3 Page 3 of 6

EMERGENCY MANAGEMENT 20 RA-EP-02010 Revision 02 Change E- I Alert RA-EP-01700. Site Area Emergencv RA-EP-01800 &

General Emergency RA-EP-01900 (Cont.)

K. Contact the Perry Plant Control Room and advise them that Davis-Besse is in a classifiable emergency and request that they activate their corporate support group.

Provide them an ECC phone number to be used as a contact phone number when they have established their organization. Typically, this will be the Policy Loop Communicator's phone number.

L. When advised by the Dose Assessment Coordinator that a release is in progress or imminent, coordinate isolation of the DBAB ventilation and water supply with the Emergency Facility Services Manager.

1. Announce "THERE WILL BE NO EATING, DRINKING, SMOKING OR CHEWING UNTIL FURTHER NOTICE" over the ERF PA system, and ensure the JPIC is notified.
2. Make an ERF PA announcement to use water sparingly while the potable water is isolated.
3. Advise the Emergency Director to relocate the JPIC, if it is onsite.

M. Assist in determining an evacuation route to the offsite assembly area in accordance with RA-EP-02520, Assembly and Accountability.

N. Ensure a Davis-Besse Technical Liaison arrives at the state and both county EOCs.

0. Review protective actions with the Dose Assessment Coordinator and make recommendations to the Emergency Director, as necessary, in accordance with RA-EP-02245, Protective Action Guidelines.

P. Ensure the NRC Liaison uses the NRC Event Notification Worksheet, ED 7843, to inform the NRC of any change in emergency classification in accordance with DB-OP-00002, Operations Section Event/Incident Notifications and Actions.

Q_ When directed by the Emergency Director to establish the Alternate Emergency Operations Facility (AEOF), perform the following:

1. Notify the Bay Shore management that the Alternate Emergency Operations Facility (AEOF) is being activated by contacting Bay Shore Security. Notify the Emergency Security Manager in the TSC that the AEOF is being activated and direct him/her to make appropriate arrangements to address AEOF security needs.
2. Inform the offsite authorities that the AEOF is being established at the Bay Shore Power Station Training Center.

Attachment 3 Page 4 of 6

EMERGENCY MANAGEMENT 21 RA-EP-02010 Revision 02 Change E- I Alert RA-EP-01700, Site Area Emergency RA-EP-01800 &

General Emergency RA-EP-01900 (Cont.)

3. Determine which functional areas from the ERO should attend this conference. As a minimum, it is suggested that the following functional areas be included:

"* Emergency Director

"* Emergency Offsite Manager

"* Radiation Protection Management

"* Operations Management

"* Technical Communicator

4. Use the Emergency Plan Telephone Directory to call out the desired additional personnel and direct them to report to the Alternate EOF to consult with offsite officials. REFER TO Attachment 7, AEOF Activation and Operation to set up the facility.
5. Notify the Company Spokesperson and the JPIC Manager that the Alternate EOF is being established.
6. Begin collecting information and data to fax to the AEOF once it is activated.

R. When notified that an NRC Incident Response Team (IRT) will be dispatched.

1. Advise the following individuals:

"* Emergency Director

"* Emergency Plant Manager

"* Company Spokesperson

"* Emergency Security Manager

2. Direct the Emergency Facilities Services Manager to set up NRC work areas.

NOTE R 3.

Personnel who are being called-in shall comply with NG-IS-00004, Fitness for Duty Program guidelines.

3. Call-in additional personnel as needed to prepare a technical briefing for the NRC and to perform support and liaison activities for the IRT.

S. Ensure a release pathway diagram and plume exposure footprint are faxed to the State and both county EOCs, as appropriate.

T. Assist the Emergency Director in assessing the need for and implementing a shift turnover, if needed.

Attachment 3 Page 5 of 6

CU suAn fllA fXfI ACr KlT J'.IVZItV.J I ivl~iA Ur.ix MAJIZiN,2 1 22 RA-EP-02010 Revision 02 Change E- 1 Alert RA-EP-01700, Site Area Emergency RA-EP-01800 &

General Emergency RA-EP-01900 (Cont.)

U. If radiation monitoring assistance is needed, then request the corporate support group:

1. Contact appropriate utilities.

REFER TO the Emergency Plan Telephone Directory, Section 2.

2. Contact the Department of Energy Radiological Assistance Program.

REFER TO the Emergency Plan Telephone Directory, Section 2.

V. If assistance is requested for bringing personnel or vehicles to the site:

1. Plan an entry route considering wind direction, release condition, and road blocks.
2. Arrange for vehicles, if needed, through the corporate support group.

W. Request that the Dose Assessment Coordinator assess radiological conditions in preparation for Recovery activities.

X. Direct deactivation of the ECC when conditions warrant, including:

1. The Emergency Director and Emergency Plant Manager agree that continued offsite dose assessment and Protective Action functions are no longer necessary for responding to the existing plant conditions.
2. Prior to announcing the deactivation, the Company Spokesperson shall be fully briefed on plant status and planned recovery actions.

Y. Instruct ECC staff to collect all pertinent material for documentation, and return their areas to pre-emergency status.

1. All equipment and supplies have been replaced in accordance with RA-EP-00600, Emergency Facility and Equipment Maintenance Program.
2. Electrical equipment has been de-energized, as appropriate.

Z. Review ECC records for completeness.

AA. Perform assigned recovery duties in accordance with RA-EP-02720, Recovery.

Attachment 3 Page 6 of 6

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