ML17304A070

After Action Report/Improvement Plan, Drill Date - September 7, 2017, Radiological Emergency Preparedness (REP) Program

ML17304A070
Person / Time
Site:	Waterford
Issue date:	10/10/2017
From:	US Dept of Homeland Security, Federal Emergency Management Agency
To:	Office of Nuclear Reactor Regulation
References
Download: ML17304A070 (24)

Text

I I

I I

I I

I I

I I

Waterford 3 Steam Electric Station I

I After Action Report/

I Impr()vement Plan I

Drill Date - September 7, 2017 I

Radiological Emergency Preparedness (REP) Program I

I Published: October 10, 2017 11

!1 I

Unclassified 11 Radiological Emergency Preparedness Program After Action Report/Improvement Plan 2017 Waterford 3 Steam Electric Station I

I I

II I

I I

I This page is intentionally blank.

I I

I I

I I

I I

2 I

I

I I

I Table of Contents Page I

Contents I Executive Summary .. ............................... ...... .............................................................. ....................... 4 Section 1: Exercise Overview................................................................................................................. 5 I 1.1 Exercise Details ............................................................................................................ 5 1.2 Exercise Planning Team Leadership ............................................................................ 5 1.3 Participating Organizations .......................................................................................... 6 I Section 2: Exercise Design Summary ................................................................................................. 7 2.1 Exercise Purpose and Design .......................................................................................... 7 2.2 Exercise Objectives, Capabilities, and Activities ........................................................ 7 I 2.3 Scenario Summary ................................................................................................... 7 Section 3: Analysis of Capabilities ......................................................................................................... 8 3.1 Exercise Evaluation and Results .................................................................................. 8 I 3.2 Summary Results ofDrill Evaluation .......................................................................... 9 3.3 Criteria Evaluation Summaries .................................................................................. 10 3.3.1 RiskJurisdictions .................................................................................................... 10 I 3.3.3 PrivateJurisdictions ................................................................................................ 10 Section 4: Conclusion ........................................................................................................................... 11 Appendix A: Exercise Evaluators and Team Leaders ....................................................................... 12 I Appendix B: Acronyms and Abbreviations ......................................................................................... 13 Appendix C: Exercise Plan ........................................................................................................................ 15 I

I I

I I

I I 3 I

I I

Executive Summary I

On September 7, 2017, an out of sequence Medical Services drill was conducted for the I

Waterford 3 Steam Electric Station (Waterford 3), located near Taft, St. Charles Parish, Louisiana. Personnel from the U.S. Department of Homeland Security/Federal Emergency I

Management Agency (DHS/FEMA) Region VI, evaluated all activities. The purpose of the drill was to assess the level of preparedness of local responders to react to a simulated I radiological emergency at Waterford 3. The previous Medical Services drill was conducted on August 25, 2015. I Personnel from the State of Louisiana, Waterford 3, Ochsner Clinic Foundation, St. Charles Parish Hospital Emergency Medical Services participated in the drill. Evaluation areas I

demonstrated included: Emergency Operations/Facilities, Protective Action Implementation, and Support Operations/Facilities. Cooperation and teamwork of all the participants was I evident during the drills and DHS/FEMA wishes to acknowledge these efforts.

This report contains the final evaluation of the out of sequence drill. The participants I

demonstrated knowledge of their emergency response plans and procedures and adequately demonstrated them. There were no Findings or Plan Issues identified as a result of the I evaluation.

I I

I I

I I

4 I

I

I I

I Section 1: Exercise Overview I 1.1 Exercise Details Exercise Name I 2017 Waterford 3 Steam Electric Station Radiological Emergency Preparedness (REP)

Program Evaluated Exercise I Type of Exercise Medial Services Drill I ExerciseDate(s)

September 7, 2017 I Program Department of Homeland Security (DHS) Federal Emergency Management Agency (FEMA) REP Program I Scenario Type Radiological Emergency I 1.2 Exercise Planning Team Leadership I Nan Williams RAC Chair I FEMA Region VI Technological Hazards Branch 800 N. Loop 288 I Denton, Texas 76209 940-898-5398 Nan.Calhoun@fema.dhs.gov I

Linda Gee I Federal Evaluation Team Lead FEMA Region VI Technological Hazards Branch I 800 N. Loop 288 Denton, Texas 76209 940-898-5368 I Linda.Gee@fema.dhs.gov I 5 I

I I

Toni Booker I

State Planning Team Lead Louisiana Department of Environmental Qua! ity Environmental Scientist I

602 N. Fifth Street Baton Rouge, Louisiana 70802 225-219-3627 I

Toni .Booker@ la.gov Gina Taylor I

Utility Planning Team Lead Waterford 3 Steam Electric Station Senior Emergency Planner I

172265 River Rd Killona, Louisiana 70057 504-739-6903 I Gtaylo3@entergy.com I

1.3 Participating Organizations Agencies and organizations of the following jurisdictions participated in the 2017 I Waterford 3 Steam Electric Station drill :

State Jurisdictions: I Louisiana Department of Environmental Quality Risk Jurisdictions:

St. Charles Parish Hospital Emergency Medical Services I Private Organizations:

Ochsner Clinic Foundation I

I I

I I

6

I I

I Section 2: Exercise Design Summary I 2.1 Exercise Purpose and Design The DHS/FEMA Region VI Office evaluated drill conducted on September 7, 2017 I to assess the capabilities of local emergency preparedness organizations in implementing their Radiological Emergency Response Plans and Procedures to I protect the public health and safety during a radiological emergency involving Waterford 3 Steam Electric Station (Waterford 3). The purpose of this report is to I present the results and findings on the performance of the offsite response organizations during a simulated radiological emergency.

I 2.2 Exercise Objectives, Capabilities, and Activities I Exercise objectives and identified Capabilities/REP Criteria selected to be exercised are discussed in the Exercise Plan, Appendix C.

I 2.3 Scenario Summary I The drill scenario was developed to evaluate the response of drill participants to an incident requiring evacuation of the public from the Emergency Planning Zone I surrounding Waterford 3. The scenario provides for an out of sequence Medical Services drill.

I The Medical Services drill was developed to evaluate the response of drill participants to an incident at Waterford 3 requiring the transportation, treatment, and I decontamination of a radiologically contaminated injured individual. The Medical Services drill scenario provided for the evaluation of Ochsner Clinic Foundation and I St. Charles Parish Hospital Emergency Medical Services.

I I

I 7 I

I I

I Section 3: Analysis of Capabilities 3.1 Exercise Evaluation and Results I

This section contains the results and findings of the evaluation of all jurisdictions and functional entities that participated in the September 7, 2017 evaluated drills to test the offsite emergency I

response capabilities of local governments in the Emergency Planning Zone surrounding Waterford 3. I Each jurisdiction and functional entity was evaluated based on their demonstration of Capabilities and their equivalent REP criteria as delineated in the FEMA REP Program Manual dated January2016.

I 3.2 Summary Results of Drill Evaluation I The matrix presented in the table on the following page presents the status of all exercise evaluation area criteria which were scheduled for demonstration during these drills by all participating jurisdictions and functional entities. Exercise criteria are I

listed by number and the demonstration status is indicated by the use of the following letters:

I M - Met (No Level 1 or Level 2 Findings assessed, and no unresolved ARCAs from prior exercise)

I 1-Level 1 Finding(s); formerlyDeficiencyassessed I 2 - Level 2 Finding(s); formerly area requiring corrective action assessed or an unresolved Level 2 Finding from a prior drill or exercise I

P - Plan Issue I

I I

I 8

I I

I I

I Table 3.2 - Summary of Drill Evaluation I DATE: September 7, 2017 u r/J

~

SITE: Waterford 3 ]

.,.... ~"'"'"

u I M: Met, 1: Level 1 Finding, 2: Level 2 Finding, P: Plan Issue, N: Not Demonstrated I:: ..c:

"'u u

..c:

0 Ci5 I Emergency Operations Management Alert and Mobilization Facilities lal lb!

I Direction and Control Communications Equipment Equipment and Supplies to Support Operations lei Id!

lei M M Protective Action Decision Making I ~

WnrlcPr Pv~o orp rnntml Dose Assessment & PARs & P ADs for the Emergency Event

'Jol 2b l Dose Assessment & PARs & PADs for the Emergency Event 2b2 I PADs for the Protection of persons with disabilities and access/functional needs Radiological Assessment and Decision-making for the Ingestion 2cl 2dl Exoosure Pathway I Radiological Assessment & Decision-making Concerning Post-Plume Phase Relocation Reentrv. and Return Protective Action Implementation 2el I Implementation of Emergency Worker Exposure Control Implementation of KI Decision for Institutionalized Individuals and the Public 3al M M 3bl Implementation ofProtective Actions for persons with disabilities and I access/functional needs Implementation ofProtective Actions for persons with disabilities and access/functional needs 3cl 3c2 Implementation of Traffic and Access Control 3dl I Implementation of Traffic and Access Control Implementation oflngestion Pathway Deci.sions 3d2 3el Implementation oflngestion Pathway Decisions 3e2 I Implementation of Post-Plume Phase Relocation, Reentry, and Return Decisions Field Measurement and Analysis 3fl I RESERVED Plume Phase Field Measurement and Analyses Plume Phase Field Measurement and Analyses 4~1 4a2 4a3 Post Plume Phase Field Measurements and Sampling 4bl I Laboratory Operations Emergency Notification and Public Info 4cl Activation of the Prompt Alert and Notification System Sal I RESERVED Activation of the Prompt Alert and Notification System 5a2 5a3 I 9 I

I I

3.3 Criteria Evaluation Summaries I

3.3.1 Risk Jurisdictions I 3.3.1.1 St. Charles Parish Hospital Emergency Medical Services I In summary, the status of DHS/FEMA criteria for the Risk jurisdiction is as follows:

a . LEVEL 1 FINDINGS: NONE I

b. LEVEL 2 FINDINGS: NONE c . PLAN ISSUES: NONE I

d . PRIOR ISSUES - RESOLVED: NONE I

e. PRIOR ISSUES - UNRESOLVED: NONE I

3.3 Criteria Evaluation Summaries I 3.3.3 Private Jurisdictions I

3.3.2.1 Ochsner ClinicFoundation In summary, the status of DHS/FEMA criteria for the Private jurisdiction is as follows:

I

a. LEVEL 1 FINDINGS: NONE

b. LEVEL 2 FINDINGS: NONE I

c. PLAN ISSUES: NONE I d . PRIOR ISSUES - RESOLVED: NONE

e. PRIOR ISSUES - UNRESOLVED: NONE I

I I

10 I

I

I I

I Section 4: Conclusion I Based on the results of the drill, the offsite radiological emergency response plans and preparedness for the State of Louisiana and the affected local jurisdictions are deemed adequate to provide reasonable assurance that appropriate measures can be taken to protect the health and I safety of the public in the event of a radiological emergency. Therefore, 44 CFR Part 350 approval of the offsite radiological emergency response plans and preparedness for the State of Louisiana site-specific to Waterford 3 Steam Electric Station will remain in effect.

I I

I I

ii I

1 I

I I

I I

I I

I 11 I

I I

I Appendix A: Exercise Evaluators and Team Leaders I

Regional Assistance Committee (RAC) Chair: Nan Williams Section Chief: Denise Bordelon Site Specialist: Linda Gee I

LOCATION St. Charles Parish Hospital Emergency Medical Services EVALUATOR

• LindaGee AGENCY FEMARVI I

Ochsner Clinic Foundation Scott Hallett FEMA HQ I

Tim Pflieger FEMARVI

• Team Leader

• Linda Gee FEMARVI I I

I I

I I

I I

I I

12 I

I

I I

I Appendix B: Acronyms and Abbreviations I \crom 111 AAR After Action Report

\ll*anin~

CFR Code of Federal Regulations I CPA Control Point Attendant CPM Counts Per Minute I DRD DHS Direct Reading Dosimeter Department of Homeland Security FEMS Emergency Medical Services I EOC Emergency Operations Center EW Emergency Worker I EPZ FEMA Emergency Planning Zone Federal Emergency Management Agency I HPT KI Health Physics Technician Potassium Iodide MGP Mirion Technologies II mR MS-1 Milliroentgens Medical Services Drill I OCF PRD Ochsner Clinic Foundation Permanent Record Dosimeter R Roentgen I REA REAC/TS Radiation Emergency Area Radiation Emergency Assistance Center/Training Site I REP RSO Radiological Emergency Preparedness Radiation Safety Officer TLD Thermo luminescent Dosimeter I Waterford 3 Waterford 3 Steam Electric Station I

I I

I 13 I

I I

I I

I I

I I

I

.This page is intentionally blank I I

I I

I I

I I

14 I

I

11 I

I Appendix C: Exercise Plan I

I WATERFORD 3 STEAM ELECTRIC STATION 2017 MS1 DRILL I

I I September 7, 2017 I

Evaluated Organizations I

OCHSNER CLINIC FOUNDATION I ST CHARLES PARISH AMBULANCE SERVICE I

I I

APPROVAL:~___ Jo~h~n_S~i~a~no~r~e~ll~i/~~~~~~~~~~~~~

I EMERGENCY PLANNING MANAGER I

I 11 15 II

I I

I I. INTRODUCTION In the interest of assuring the health and safety of the general public near the Waterford 3 Steam Electric Station, in the event of a radiological emergency, Waterford 3 I,

periodically conducts drills jointly with the Federal, State and local agencies.

This manual contains the scenario of activities and supporting data describing the Waterford 3 Emergency Preparedness Medical Services drills.

I This scenario was developed by postulating events that will require response by offsite organizations.

During this drill, the support organizations will respond to the simulated events and conditions that have been selected to provide the level of activity necessary to meet the scenario objectives.

Ochsner Clinic Foundation (Ochsner Medical Center) and St Charles Parish Ambulance will participate in this drill.

Drill participants will have no prior knowledge of the sequence of events. The drill I

scenario will allow those individuals and agencies assigned to respond during a radiological emergency to demonstrate their performance according to current emergency preparedness plans and procedures.

I The scenario is a mechanism by which selected drill controllers will initiate and evaluate the activities of the drill participants. The individual drills will be initiated as shown below and expected to last approximately three hours.

I Participating organizations are shown in Section IV, Guidelines, of this manual.

I A. SCHEDULE

1. Thursday September 7, 2017 I 08:00 Ochsner Clinic Foundation I

I I

I I

16 I

I

I I

II. EXTENT OF PLAY I A. EVALUATION AREA 1: EMERGENCY OPERATIONS MANAGEMENT I Sub-Element 1.e - Equipment and Supplies to Support Operations I Criterion 1.e.1: Equipment, maps, displays, dosimetry, potassium iodide (Kl) and other supplies are sufficient to support emergency operations. (NUREG-0654/FEMA-REP-1 , H.7, 10; 1.7, 8, 9; J.10.a, b, e; J.11, 12; K.3.a; K.5.b)

I 1. Locations Ochsner Medical Center and St Charles Parish Ambulance I 2. Extent of Play Correction-on-the-spot will be conducted at these locations at the I discretion of and concurrence between the evaluator and the controller.

Caution should be exercised to insure that exercise play is not interrupted.

I 3. ARCAs None I B. EVALUATIONAREA3: PROTECTIVEACTIONIMPLEMENTATION II Sub-Element 3.a - Implementation of Emergency Worker Exposure Control Criterion 3.a.1: The OROs issue appropriate dosimetry and procedures, and manage radiological exposure to emergency workers in accordance with the plans and procedures.

I Emergency workers periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart. (NUREG-0654/FEMA-REP-1, J.10.e; K.3.a, b; K.4)

I 1. Locations I 2.

Ochsner Medical Center and St Charles Parish Ambulance Extent of Play I a. Area dosimetry may be used at the hospital.

b. Correction on the spot, at the discretion of and concurrence

I between the evaluator and the controller, may be acceptable at these locations.

3. ARCAs I None I 17 I

I I

Sub-Element 6.d- Transportation and Treatment of Contaminated Injured Individuals I Criterion 6.d.1: The facility/ORO has the appropriate space, adequate resources and trained personnel to provide transport, monitoring, decontamination and medical services to contaminated injured individuals. (NUREG-0654/FEMA-REP-1, F.2; H.10; K.5.a, b; L.1, 4)

I

1. Locations I

St Charles EMS, Ochsner Medical Center

2. Extent of Play I Attachment J - Aeromedical Transportation of a Radioactively Contaminated Patient of Radiation Accident Plan will remain in place since this procedure is applicable to the patient transportation from utility.

I However, Louisiana Peacetime Radiological Response Plan does not include the use of Ochsner Flight Care and it will not be demonstrated.

a. All surgical procedures, X-rays, blood samples, starting of IV's, I

etc., will be simulated.

b. Ambulance travel times will be simulated.

I

c. Ambulance will be pre-staged at a location where simulated contaminated patient loading will be demonstrated. I

d. The lead controller initiates the drill by contacting the St Charles Ambulance Service and reporting a contaminated injured employee at the Waterford 3 site. (simulated location). I

i. Simulated contaminated patient will be loaded into the ambulance and transported to the Ochsner Medical Center REA.

I ii. If for some reason , the EMS unit is called into service in response to an actual event, the patient transportation will take place using an alternate vehicle.

I

e. Ochsner Medical Center will be contacted by Lead Controller reporting a contaminated , injured employee being transported to I

their location from the Waterford 3 site.

i. The simulated estimated time of arrival (ETA) will allow the hospital to completely mobilize.

I

f. Information provided by the ambulance crew during transportation of the patient will be provided by cue cards.

I I

18 I

I

I I

g. After approximately 30 minutes, the ambulance will arrive at the I hospital entrance with the packaged patient. The patient will be a contaminated injured plant employee.

h. Correctjon-on-the-spot, at the discretion of and concurrence I between evaluator and controller, may be acceptable at this location.

I D. GENERAL EXTENT-OF-PLAY <EOPl I 1. With regard to last minute additions or changes to any previously approved Extent-of-Play, all suggested changes must be forwarded to the RAC Chair for approval.

I 2. The goal of all offsite response organizations (ORO) is to protect the health and safety of the public. This goal is achieved through the execution of appropriate plans and procedures. It is recognized that I situations may arise that could limit the organizations in the exact execution of these plans and procedures.

3. In the event of an unanticipated situation , OROs are permitted to exercise flexibility in the implementation of their plans and procedures in order to successfully achieve the objective of protection of public health and safety and protection of the environment.

4. As a statement of fact, no ORO will deliberately deviate from its plans and procedures with the intent of avoiding responsibility.

E. REFERENCES REP Program Manual Part Ill : REP Program Demonstration

'I 1.

Guidance I

I I

I I

I 19 I

I I

Ill. OBJECTIVES I The following general objectives and guidelines have been developed for the Offsite Drills, which are scheduled as shown below.

A. Ochsner Medical Center- September 7, 2017 I

1. Demonstrate the capability to alert and fully mobilize personnel for both emergency facilities and field operations.

2. Demonstrate the capability to activate and staff emergency facilities for emergency operations.

3. Demonstrate the capability to communicate with all appropriate emergency personnel at facilities and in the field.

4. Demonstrate the capability to continuously monitor and control radiation exposure to emergency workers.

5. Demonstrate the adequacy of the equipment, procedures, supplies, and personnel of medical facilities responsible for treatment of contaminated, I

injured, or exposed individuals.

B. St Charles Parish Ambulance Service- September 7, 2017

1. Demonstrate the capability to communicate with all appropriate I

2.

emergency personnel at facilities and in the field .

Demonstrate the capability to continuously monitor and control I

radiation exposure to emergency workers.

3. Demonstrate the adequacy of vehicles, equipment, procedures and personnel for transporting contaminated, injured or exposed I

individuals.

I I

I I

I I

20 I

I

I I

I IV. GUIDELINES To define the scope and extent of participation by organizations and participants, the I following guidelines are established in order to meet the objectives listed in Section Ill of this manual.

1. The offsite drills will be conducted as follows:

I a) September 7, 2017 (1) Medical Drill I 2. Participation is limited to St Charles Parish Ambulance Service Staff, Ochsner Medical Center Emergency Room Staff, 1 Waterford 3 Plant Sr. HP Technician and the Drill Control Team. No otherWaterford 3 plant staff will participate.

I 3. Communications between Waterford 3 plant and Ochsner Medical Center are simulated by the Drill Control Team.

4. A St Charles EMS unit will be requested to pre-stage at Ochsner Medical Center at I 5.

approximately 08:00.

A simulated contaminated injured plant employee and a Health Physics Technician are staged at the Ochsner Medical Center at the beginning of the drill.

6. The drill is initiated by the Drill Control T earn requesting the dispatch of the St.

Charles Hospital Ambulance Service to transport the patient to Ochsner Clinic Foundation. The Drill Control Team then contacts Ochsner Medical Center simulating a report of a medical emergency.

7. All communications are preceded and ended with "THIS IS A DRILL."

8. The simulated medical emergency continues until the patient is decontaminated and treated by the Ochsner Medical Center medical staff.

9. A critique is conducted immediately following the termination of the drill.

I 10. Drill specific guidelines will be addressed in their individual appendices.

I I

I I

I I 21 I

I I

OCHSNER MEDICAL CENTER ST. CHARLES AMBULANCE SERVICE I

V. NARRATIVE

SUMMARY

I At approximately 07:45 AM , a Mechanical Maintenance Technician at Waterford 3, who has been repairing a leak on the "A" Low Pressure Safety Injection Pump, slips and falls down breaking her left leg below the knee and striking her forehead on a pump support. During I

the fall, the technician's left leg came into contact with contaminated water collected from the pump.

I The Drill Control Team simulates the Control Room response and UNT-007-018, First Aid and Medical Care, is implemented. Response by the Emergency First Aid Team is simulated and primary surveys of the patient are performed I At approximately 08:00, the St Charles Ambulance Service is (simulated) dispatched to Waterford 3 to transport patient to Ochsner Medical Center.

After requesting EMS, the Drill Control Team calls the Ochsner Medical Center to report the I

simulated medical emergency. The patient's primary survey information (vital signs) is provided .

The EMTs will provide radio updates to Ochsner Medical Center during simulated transportation of the patient.

At approximately 08:30, the ambulance will arrive at Ochsner Medical Center. The patient will be taken into the REA, decontaminated and treated for the simulated injuries. After the patient has been removed from the REA and the proper removal of protective clothing has been demonstrated, the medical drill will be terminated. A critique of the events will be conducted.

Any required x-rays or required samples may be simulated by hospital personnel after demonstrating knowledge of requirements and processes.

I I

I 22

I I

I (A)VI. SEQUENCE OF EVENTS I TIME EVENT DRILL ACTIVITY 07 :30- Drill preparations are made. The Drill Control Team assemble at Ochsner I 7:45 CC-1 Medical Center. The patient is "made up" and the Drill personnel are briefed .

I 08:00 CC-2 Drill initiated by the Drill Control Team.

The Drill Control Team notifies the Medical Center that a medical emergency involving a contaminated person has occurred and they will be the receiving hospital.

I CC-3 CONTINGENCY If St Charles Ambulance Service is unable to participate, patient transportation will conducted by alternate vehicle and EMS response will be I CC-4 CONTINGENCY simulated .

If Ochsner Medical Center is unable to participate, the medical emergency drill will be I 08:05 Simulated ambulance leaving the terminated .

Drill Control Team notifies the Medical Center CC-5 WF3 Site that the ambulance has left the site and is in I 08:20 Simulated patient transport to route.

Ambulance notifies the Medical Center they have CC-6 Ochsner Medical Center 10 min ETA The patient's condition will not I change during transportation to Ochsner Medical Center.

08:30 Patient arrives at Medical Center. The patient is taken to the REA. The hospital I CC-7 personnel decontaminate the patient and begin treatment of the injury.

CC-8 HP Tech Surveys Ambulance HP Tech surveys ambulance and releases after I CC-9 Doffing PPE no contamination found.

When the patient is ready to be admitted to the hospital personnel will demonstrate doffing PPE.

I CC-10 Drill terminated . Critique conducted.

When all objectives are completed the medical response drill will be terminated.

I I

I I 23 I

I I

DRILL TEAM ASSIGNMENTS I A. Ochsner Medjcal Center MS-1 Lead Controller - Aaron Ertel I

Patient Transfer Controller- Gina Taylor REA/Medical Controller - TBD Mobilization/Buffer Zone Controller - Don Vincent I

DRILL TEAM INSTRUCTIONS I

A. All Drill Control Team members for the Offsite Drill will be briefed by the Lead Controller prior to conducting the drill. I B. All Drill Control Team members will report as follows:

1. Ochsner Medical Center I

a. 07:30 September 7, 2017 C. All Drill Control Team members will take accurate, complete notes of the activities observed during the drill.

I D. The Drill Control Team will conduct a critique of the drill, with the participants, immediately following the termination of the drill. I E. The Drill Control T earn members will debrief with the Lead Controller after returning to the Waterford 3 plant I

I I

I I

I I

24 I

I