ML20195G193

Summary of 990421-21 Meeting with NRC Senior Mgt Re Agency-Focus & Regional-Focus Removal Evaluation Factors

ML20195G193
Person / Time
Issue date:	06/11/1999
From:	Tracy G NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:	Kilgore L NRC OFFICE OF THE SECRETARY (SECY)
References
NUDOCS 9906150266
Download: ML20195G193 (65)

Text

S l p rerug y & UNITED STATES f

j NUCLEAR REGULATORY COMMISSION

~~

WASHINGTON, D.C. 20666 4001 June 11,1999 MEMORANDUM TO: Linda Kilgore Public Document Room LL-6 FROM: Glenn M. Tracy, Chief M-Regional Operations and Program Management Section, OEDO

SUMMARY

OF THE NRC SENIOR MANAGEMENT MEETING APRIL 20 AND 21,1999 Attached for public release is information regarding the NRC Senior Management Meeting held April 20 and 211999. Attachment 1 is a summary of the April 1999 NRC Senior l

Management Meeting. The Agency-Focus and Regional-Focus Removal Evaluation Factors  !

are provided in attachment 2.

g Attachments: as stated I cc: Document Control Desk e

T)r

<3f.iO g g rF G 0"I 9906150266 990611 PDR ORG NE ED PDR a

I i

t ATTACHMENT 1 NRC Senior Management Meeting Minutes ,

April 20-21,1999 l Region IV

k

Background

Following the June 1985 loss of feedwater event at Davis-Besse, one resulting NRC action was that senior NRC managers periodically meet to discuss the plants of greatest concern to the agency and to plan a coordinated course of action.- The NRC senior managers held their twenty-sixth such meeting in Region IV on April 20-21,1999. The previous meeting was held in Region lli in July 1998. This most recent meeting was structured to review the status of the

' Watch List plants identified at the last meeting and to review the performance of other plants to determine those facilities warranting either agency or regional-focus monitoring by the NRC.

In preparation for the meeting, the NRC's Office of Nuclear Reactor Regulation (NRR) in conjunction with the four regional offices, the Office of Enforcement (OE), the Office of I investigations (01), and the Office of Research (RES), prepared background documents on the plants to be discussed. Inputs for each operating reactor plant included a summary of the most recent Plant Performance Review (PPR), a discussion of current operating experience and licensee performance, current NRC and licensee activities, performance indicator data, risk insights, and enforcement, allegation, and investigation information. To enhance the application of information summaries, pro / con charts and agency and regional-focus evaluation matrices were developed. This inf ormation was distributed to attendees prior to the meeting. It l provided the basis for review and discussion of each plant's performance.

In reviewing the reactor plants ths.t potentially warrant or are currently receiving agency-level attention, the NRC managers utilized the following definitions;

- Realonal-Focus. Plants requiring the direct attention and/or involvement by the Regional Administrators to coordinate NRC resources and maintain cognizance of licensee performance (e.g., issuance of a confirmatory action letter (CAL), implementation of the inspection Manual j Chapter 0350 process, enactment of a regional-level inspection beyond the NRC's routine i inspection program).

Acencv-Focus. Plants requiring the direct attention and/or involvement by the Executive Director for Operations (EDO) and/or Commission to coordinate NRC resources and maintain cogriizance of licensee performance (e.g., issuance of an order, enactment of agency-level oversight or inspection).

Recommendations will be made during senior management meetings to enable the agency to focus on the plants and issues of greatest concern.

2 Summarv of Decisions The following summary lists conclusions reached by the senior managers at this meeting and from the previous meeting for nuclear power plants and for materials licensees:

NUCLEAR POWER PLANTS Meeting Dates Aaencv-Focus Reaional-Focus Routine Oversiaht APRIL 20-21,1999 Millstone 2 Millstone 3 Crystal River 3 D.C. Cook Clinton Salem 1&2 LaSalle 1&2 Dresden 2&3 -

Quad Cities 1&28 Meetina Dates Cateoorv 38 Cateaorv 28 Cateaorv 18 Trendino Letter JULY 14-15,1998 Millstone Millstone 3 Crystal River 3 Quad Cities 1&2 1&2' Clinton Salem 1&2 D.C. Cook LaSalle 1&2 Dresden 2&3 MATERIAL LICENSEES Meeting Dates Facilities for Priority Attention APRIL 20-21,1999 None JULY 14-15,1998 None (1) As of the time of the April 1999 SMM, approval of the restart of Millstone Unit 2 remained under consideration by the Commission.

(2) During the April 1999 SMM, the' senior managers determined that the adverse trend at Quad Cities had been arrested.

(3) Former SMM Cateoories:

Cateoorv 1. Plants removed from the list of problem facilities. Plants in this category have taken effective action to correct identified problems and to implement programs for improved performance. No ,

further NRC special attention is necessary beyond the regional office's current level of monitoring to  !

ensure improvement continues.

Cateaorv 2. Plants authorized to operate that the NRC will monitor closely. Plants in this category have been identified as having weaknesses that warrant increased NRC attention from both headquarters and the regional office. A plant will remain in this category until the licensee demonstrates a period of improved performance.

Cateoorv 3. Shutdown plants requiring NRC authorization to operate and which the NRC will monitor  ;

closely. Plants in this category have been identified as having significant weaknesses that warrant maintaining the plant in a shutdown condition until the licensee can demonstrate to the NRC that adequate programs have been established and implemented to ensure substantial improvement. The I Commission must approve restart of a plant in Category 3 status.

(4) in July 1998, the senior managers did not review considerations for decreasing or maintaining the level of agency attention at Millstone Units 1&2, given their Category 3 standing. On July 21,1998, Northeast Nuclear Energy Company submitted a letter stating their decision to cease operations at Millstone Unit 1. In an SRM dated July 22,1998, the Commission directed the staff to no longer list Millstone Unit 1 as a Category 3 facility.

j

3 SPECIFIC DISCUSSION OF FACILITIES The following facilities have been categorized as Routine Oversight (i.e., Plants regulated under the auspices of Inspection Manual Chapter 2515 Inspection program). ]

CRYSTAL RIVER Backaround Discussion:

Crystal River (CR3) was first discussed during the June 1996 SMM. The staff's concerns for l CR3 were focused on poor control of design issues, non-conservative interpretation of certain NRC regulations, and weaknesses in operator performance, corrective actions, and management oversight. The plant shut down in September 1996, as a result of turbine generator problems, and remained shutdown as additional hardware problems and performance issues surfaced. CR3 was placod on the Watch List as a Category 2 plant at the January 1997 SMM, and as problems continued to be identified, a CAL was issued in March 1997. The CAL required NRC concurrence before the licensee could restart the unit. At the January 1998 SMM, senior managers acknowledged improvements at CR3; however, the facility had not yet achieved a period of sustained operational performance, as it had remained  !

shutdown for an extended period, in addition, the senior managers noted that there were several design and licensing basis issues which were unresolved. Therefore, the senior managers decided that CR3 should continue to be designated as a Category 2 facility. CR3 was released from the CAL in January 1998, restarted, and reached full power in February 1998. During the July 1998, SMM the senior managers concluded that CR3 had taken effective action to correct their identified problems and to implement programs for improved performance. Accordingly, the senior managers concluded that CR3 met the criteria for removal from the Watch List and designated CR3 as a Category 1 facility.

Since the July 1998 SMM, overall performance at CR3 has been good. Management has maintained high performance standards and continued to implement improvements. The l

corrective action program has a low threshold and plant staff have been effective in identifying problems. Performance enhancements were implemented in several areas, particularly in departments that were not closely examined during the extended 1997 outage such as training, ,

health physics, and chemistry. Licensee initiative and commitment to address these issues '

have been demonstrated.

4 Operations has demonstrated effective leadership over plant activities. The implementation of the work control center and a 12 week rolling schedule improved the coordination of operations with other groups. Individual operator performance was strong, with very few personnel errors  !

identified. The licensee has attributed several recent deficiencies in the implementation of )

technical soecification requirements to problems with tracking programs and is addressing those issues.

Implementation of the maintenance improvement plan, adherence to goals and schedules, and quality performance of preventive maintenance activities were indicative of continuing maintenance improvements. Effective corrective actions have been demonstrated in the resolution of several surveillance testing issues.

J

4 Engineering support for the preparation of license amendment submittals, root cause evaluations, and resolution of safety-related issues have been effective. Engineering

. programs and processes were upgraded to better maintain accurate design basis documents.

Problem identification has been superior as demonstrated by the high standards set by Design Review Boards. Progress has been made on major modifications to address several longstanding safety system performance and licensing issues.

Overall, plant support programs continue to be effectively implemented and maintained.

SMM Discussion:

CR3 was a Category 1 facility following the last SMM.

The senior managers concluded that CR3 had taken effective action to correct their identified problems and to implement programs for improved performance. As a result, CR3 will continue to receive a routine level of oversight under the auspices of the NRC inspection program.

SALEM 1 & 2 Backaround Diacussion:

Salem Units 1 and 2 were first discussed at the January 1990 SMM and have been subsequently discussed at every SMM since June 1994. Both units were shutdown in May and June,1995, respectively to correct longstanding equipment deficiencies, poor material condition, weak management oversight, and ineffective corrective actions. As a result of the January 1997 SMM, the Salem units were designated as a Category 2 Watch List facility. On August 6,1997, the NRC concluded that Public Service Electric and Gas Company (PSE&G) improved performance sufficiently to warrant modification of the 1995 CAL and allow restart of l Unit 2. At the January 1998 SMM, senior managers acknowledged substantial improvements at i Salem; however, the facility continued to be designated as a Category 2 facility since sustained j successful performance had not been demonstrated. During the July 1998, SMM the a,enior

~

managers noted that Salem met all the criteria for removal from the Watch List, including the demonstration of sustained, successful plant performance, and designated Salem as a i Category 1 facility. l Since the July 1998 SMM, overall performance at Salem has been positive considering the i significant challenges PSE&G faced in recovering both units from a three-year outage. l Management oversight has been strong as evidenced by their review of ongoing activities and effective problem identification, analysis, and correction. Management maintained a low threshold of reporting problems throughout the plant. As a result, plant problems were promptly identified and corrected, and the corrective action program continued to be effective.

i Operating results have been good. Operating personnel have demonstrated high operational standards and a sound safety ethic, including conservative decision making, generally effective command of control room activities, and good teamwork. Salem Unit 1 was restarted in April 1998 and operated continuously until February 28,1999, when the inadvertent draining of turbine lube oil resulted in a reactor trip. This 314 day period of sustained operation

F l-5 represented a record for Salem. Salem Unit 2 had three forced outages, which totaled four

weeks, to address equipment problems related to service water, pressurizer safety valves, and reactor coolant pump seals. Additionally, there were several operational events caused by

. personnel errors, including two declarations of Unusual Events (reactor coolant system leak and loss of control room annunciators).

L Engineering effectively supported day-to-day operations. The performance of maintenance

and system engineering have improved. Design engineering performed acceptably, although L some problems were found involving design evaluations. Resolutions of identified issues were l- generally appropriate. Strong oversight of engineering activities was evident with notable j improvements in the implementation of engineering programs.

Material condition remained good and the large backlog of corrective maintenance work items was effectively managed. Risk assessments for on-line work were sound. On occasion, equipment operability has been impacted by work execution problems. While work execution l . problems is a continuing issue, the errors typically did not result in plant transients. The organization, however, remained challenged by problems in the maintenance work control process, by the large backlog of corrective maintenance activities, and by frequent unplanned equipment outages resulting in technical specification action statement entries.

Plant support programs continued be effectively implemented and maintained.

SMM Discussion:

Salem was a Category 1 facility following the last SMM.

The senior managers concluded that Salem had taken effective action to correct their identified problems and to implement programs for improved performance. As a result, Salem will continue to receive a routine level of oversight under the auspices of the NRC inspection program.- ]

DRESDEN 2 & 3 Backaround Information:

Dresden was first placed on the NRC Watch List in June 1987, removed in December 1988,  ;

and again placed on the Watch List in January 1992. Significant contributors to the decision to l place Dresden on the Watch List a second time included weaknesses in: procedure quality and 1 adherence, communications, execution of management expectations, plant material condition, l supentision and control of work activities, work performance, and engineering and licensing ,

.I support.' During the June 1996 SMM, senior managers concluded that an independent special l team should be formed to evaluate the performance of Dresden Station. This evaluation was  ;

j conducted in the Fall 1996 and the results were presented to the senior managers at the l l, January 1997 SMM. This team concluded that safety performance had significantly improved in  ;

l. plant operations while the level of improvement in engineering had not yet resulted in fully effective problem identification and resolution. The team also concluded that the results of improvement initiatives in radiological protection, maintenance, and self-assessment were  ;

1 l.

I

6

- mixed. Further, significant weaknesses in engineering, design control, and surveillance testing were identified.

l During the June 1997 SMM, improvement in the Unit 3 operational performance and material condition was noted, but se*r agency managers remained concemed about continued l operational challenges on Unit 2 created by equipment deficiencies, engineering, work control, '

procedural adherence, and mair tenance issues. NRC senior managers recognized sustained improved performance at Dresden during the January 1998 SMM; however, concerns regarding the continued evidence of cyclic performance by Comed plants and the adequacy of corporate oversight and involvement in plant operations and problem resolution resulted in Dresden's continued designation as a Category 2 facility.

During the July 1998 SMM, the senior managers focused on the fact that six scrams had occurred at the facility since the previous meeting and debated about insights that could be drawn concerning the overall performance of the site. It was noted that safe dual-unit operations had been achieved since the previous SMM and that the scrams were generally the result of historical problems. Additionally, it was acknowledged that operator performance during the scrams was good. Even though the number of scrams was high, plant equipment responded as designed, thus minimizing the challenge to operators. In addition, based on the lack of equipment problems during these transients, NRC senior managers gained greater confidence in the reliability of mitigating equipment and discussed their view that the risk significance of the scrams was low. Further, the managers noted improvements in engineering and material condition and good performance in the plant support area.

The senior managers concluded that Dresden had taken effective action to correct its identified problems and to implement programs for improved performance. As a result, no further NRC special attention was deemed necessary beyond the regional office's current level of monitoring to ensure continued improvement, including the continued assessment of Comed corporate support for its nuclear facilities through the NRC's Comed Performance Oversight Panel (CPOP) process. Dresden was classified as a Category 1 facility.

Since the last SMM, both Dresden Units have operated at or near full capacity with the exception of several power reductions to support maintenance work. Overall performance at  ;

the facility has been acceptable, and entering 1999, both units had been operating for extensive i periods without significant operational problems. In 1999, both units have set new Dresden I continuous run records (250 days for Unit 2 as of 4/16/99 and 249 days for Unit 3) and Unit 3-established a new Comed-wide refueling outage record of 26 days in February 1999.

Performance in the operations area has been both steady and acceptable. Various equipment problems challenged operators and down power maneuvers were effectively implemented to address the deficiencies. However, it was noted that instances occurred in June through  ;

August of 1998 where operators failed to recognize technical specification entry requirements and action statements and several examples of inattention to detail were noted. Corrective actions for these problems have been effective. i i

Overall maintenance performance continued to be acceptable and some areas of improvement were noted. Additionally, improvements have been noted in the planning and execution of safety-related equipment outages and maintenance activities. However, instances of personnel l errors and material condition problems, some of a longstanding nature, were observed to affect l

1

7 1

plant operation. For example, an improper maintenance restoration on the circulating water  ;

system required the operators to perform a rapid load reduction.

I Performance in engineering was improved. In particular, the implementation of engineering j department self-assessments, corrective actions, and the quality of engineering products improved during the period. Engineering also contributed to improvements in plant material condition. However, instances of weakness in engineering support to operations were

~

identified. it was also noted that root cause investigations have been effective with one notable exception involving the post-accident monitoring system. In addition, some weaknesses were identified in the implementation of the temporary alteration program.

Performance in plant support was consistent.' Programs in the plant support area including as-low-as-reasonably-achievable (ALARA) planning, radiological controls, chemistry, radiological environmental monitoring, security and fire protection were generally effective with occasional lapses in program implementation and oversight. Self-assessments were thorough and self-critical and corrective action progress was tracked effectively. However, isolated problems were noted in personnel performance and material condition.

SMM Discussion:

Dresden was a Category 1 facility following the last SMM.

The senior managers noted that Dresden 2 and 3 performance remained acceptable.

Operational challenges were reduced, contributing to extended power runs. A Unit 3 outage was conducted well. The senior managers noted Dresden had continued to implement ,

performance improvements. - As a result, Dresden will receive a routine level of oversight under the auspices of the NRC inspection program.

LASALLE 1 & 2 Backaround information:

. LaSalle was issued a trending letter in January 1994, due to concerns regarding radiological work practices, declining material condition, declining personnel performance, and NRC staff concems about the licensee's ability to pursue and resolve root causes for these issues. By January 1995, the licensee's initiatives were found to be effective in arresting these adverse trends and the licensee was sent a letter informing them of this observation and urging the continuation of improvement initiatives. Improvement in plant material condition and engineering effectiveness was limited during 1995 and the first six months of 1996. The significant amount of emergent work and difficulties in planning and executing maintenance hindered progress in implementing the station material condition improvement plan during the last six months of 1996. In June 1996, a risk-significant event occurred involving the injection of large quantities of expandable foam sealant into the safety-related service water tunnel. The NRC issued a $650,000 civil penalty to the licensee for violations associated with this event.

Following the January 1997 SMM, LaSalle was placed on the NRC Watch List as a Category 2

. facility. At the SMM in July 1998, the senior managers noted that the licensee had made significant progress towards resolving historical performance problems. However, as a result of

8 the extended outage on both units, the available performance indicators provided limited insights regarding performance trends. As a result, the senior managers decided that LaSalle would remain a Watch List Category 2 facility.

Since the last SMM, both units at the facility have resumed power operations. Unit 1 commenced restart on August 1,1998. _ The unit was shutdown on August 4,1998, to address equipment problems and on August 19,1998, during power ascension and testing, operators manually scrammed Unit 1 in response to a feedwater transient. Subsequently, Unit 1 achieved 100 percent power on August 26,1998, and with the exception of a planned maintenance and testing outage, has remained at or near 100 percent power. Unit 2 commenced restart on April 9,1999, and was conducting power ascension testing at the time of the SMM.

During both the January and July 1998 SMMs, it was noted that overall performance at LaSalle had shown signs of improvement commensurate with the status of the Restart Plan. Since the last SMM, improvements have continued and overall performance at the facility has improved.

The plant staff has continued to make progress in enhancing station performance. This included completion of all necessary activities to allow closure of the 1997 CAL. Overall, human performance was significantly improved due to initiatives implemented during the extended shutdown. The corrective action program was generally effective and identified and resolved safety issues. Also, extensive actions taken during the extended shutdown addressed the more significant material condition problems impacting the facility. Programs in the plant support area have been generally effective; however, occasional problems in implementation have been observed and some inconsistency in personnel performance remains. Additionally, some emergent equipment problems identified during the Unit 1 startup and while the unit has been operating, indicated the need to continue material condition improvement efforts.

Performance in the Operations area improved. In general, plant management and operators performed well, including during Unit 1 startups and shutdowns. Operators were knowledgeable of plant conditions, attentive to the main control room panels, and cognizant of activities that could affect plant performance. Also, operators performed duties in a deliberate manner with good command and control. In addition, operators addressed emergent ,

equipment problems and abnormal conditions appropriately. However, some instances of j

_ operator knowledge and performance deficiencies indicated the need to continue to address  !

human performance. A special initiative inspection was conducted to assess readiness for i restart of Unit 2 and dual unit operations. The inspection identified careful and deliberate operations and good command and control, with a few minor exceptions. The unit operated well during the extensive testing program.

Performance in the Maintenance area improved. Material condition improvements were generally effective and maintenance personnel performed adequately during maintenance and l surveillance testing activities. However, some minor performance deficiencies were identified and troubleshooting activities were not always effective. Although technical specification  !

surveillance tests _and the majority of plant maintenance activities were scheduled and  !

performed as required, weaknesses in the work control process challenged the station's ability to continue to improve material condition. In the weeks prior to restart of Unit 2, the licensee

' was able to significantly improve the work control process. The remaining challenge will be to sustain this without contractor support. The Unit 2 restart demonstrated that the licensee had effectively incorporated lessons leamed from the Unit 1 restart with respect to equipment modifications and testing.

R l

9 Overall engineering performance improved. Engineering personnel continued to demonstrate the ability to identify problems involving technical design issues and engineering deficiencies.

~

. Original plant design deficiencies were effectively addressed during the plant shutdown.

Engineering personnel effectively supported the testing during the startup of the units from the

. extended outage.

-The corrective actions to address problems have been effective as was engineering support to operations. One exception to this observation is associated with engineering support with respect to the failure of a main turbine stop valve during a surveillance test. A special initiative inspection was conducted to focus on the rigor of calculations, including the use of engineering judgement, to support modifications implemented during the Unit 2 outage. This inspection

showed good design, installation, and testing of modifications for Unit 2.

Performance in the plant support area was consistent. Security, ALARA planning, and radiological controls programs were generally effective, although occasional problems in program implementation occurred. Personnel performance in the plant support area declined, with problems in radiation worker performance still evident. Specific incidents were thoroughly investigaba and comprehensive self-assessments were completed; however, the corrective

action program was not fully effective in addressing the continuing problems. In the plant support area, an initiative inspection was conducted to review corrective actions for poor radiation worker and radiation technician performance. The inspection showed that the

. licensee has taken significant steps to restructure the radiation protection department.

SMM Discussion:

LaSalle was a Category 2 facility following the last SMM.

The senior managers' discussions were focused on the improved performance observed since the last SMM. Unit 1 startup activities were well managed and a subsequent plant scram and forced outage were effectively controlled. Overall, the licensee took effective corrective actions to apply the lessons learned during the restart of Unit 1 to Unit 2 activities. The trend of

- performance indicators showed clear improvement in performance and recent Plant Issues

' Matrix entries were noted to be more positive. A decline in radiological protection program implementation was observed; however, a recent followup inspection confirmed that the licensee had initiated appropriate corrective actions to address the deficiencies identified.

The evaluation matrix was utilized in determining the appropriate agency response to the identified performance concerns. All evaluation factors were considered to have been met with the exception of demonstrating sustained successful plant performance. The question that remained to be addressed in this area was the ability to manage two units at power. The senior managers determined that, based on Unit 1 performance and Unit 2 restart inspection results, additional focused inspections of dual unit operations were not necessary.

Although some areas for improvement remained, the senior managers determined that sufficient progress had been made to warrant reduction of NRC attention to routine inspection.

As a result, LaSalle will receive a routine level of oversight under the auspices of the NRC inspection program.

l i

l l

.i

7 10 QUAD CITIES 1&2 Backaround Information:

Quad Cities was first discussed at the June 1991 SMM and at each SMM since June 1993 with the exception of the June 1997 SMM. Following the January 1994 SMM, the NRC sent the licensee a trending letter to express concem over the continuing decline in overall performance.

After the June 1994 SMM, the NRC sent the licensee a follow-up trending letter expressing continuing concem. During the first half of 1995 overall performance improved. Following the -

June 1995 SMM, NRC managers concluded that the declining trends at the Quad Cities Station had been arrested. ' During 1996, Quad Cities displayed slow improvement in operations performance, material condition, procedural adherence, trending, and accountability. The last Systematic Assessment' of Licensee Performance (SALP) period (report issued January 30, 1998) found the conduct of nuclear activities at the plant to have declined. The plant was discussed again during the January 1998 SMM. The senior managers agreed that a trending letter was the appropriate regulatory tool to convey the agency's concerns.

Unit 2 was shutdown on September 27, and Unit 1 on December 20,1997, to address concems regarding the ability to safely shutdown the units in the event of a fire. A CAL was issued to the licensee in January 1998 concerning the fire protection (Appendix R) issues. Previously, substantial problems wers identified with the procedures for 10 CFR 50 Appendix R Fire Protection, inservice inspection and inservice testing programs, understanding and application of the design basis, operability determinations and 10 CFR 50.59 evaluations, continued missed surveillance testing, and untimely and inadequate corrective actions. On May 22,1998, licensee improvement efforts in these areas culminated in closure of the CAL and the licensee subsequently began startup of both units.

By June 1998, the performance of the corrective action program had improved; however, a lack of rigor resulted in the licensee's failure to address some long-standing issues. The engineering organization appeared to be burdened by efforts to resolve Appendix R issues.

Quad Cities' performance was mixed with slow improvement in some areas. However, there were not sufficient operational data or inspection insights available to assess the overall performance trend at Quad Cities. Furthermore, it was not clear that Comed's efforts had resulted in measurable performance improvements at Quad Cities. Long-term corrective i actions associated with reducing the core damage frequency resulting from postulated fires j were still being implemented and remained an area of NRC focus. j i

At the July 1998 SMM, senior managers noted mixed plant performance. Subsequent to the restart, there were several power reductions and two scrams due, in part, to material condition issues. Operational performance demonstrated improvement since the extended outage. ,

Also, while the material condition of the plant improved and the maintenance backlog was l reduced, there were maintenance errors and concerns with emergency diesel generator reliability. Consequently, the senior managers could not conclude that the adverse  !

performance trend had been arrested at Quad Cities due to the limited operational data since the last SMM.

Overall, since July 1998, performance at Quad Cities has been acceptable and reactor operations have been conducted well with in adequate safety focus. Response to plant

11 transients resulting from equipment problems has been good. ' However, configuration control problems and equipment failures continue to be areas of concem. A refueling outage for Unit 1 was completed December 5,1998, in 28 days and self-imposed safety and radiological goals ~

were achieved during the outage. At this time, this was the shortest refueling outage in Comed history, and subsequent good operating performance by Unit 1 indicates the outage work was performed successfully.

Performance in operations and maintenance has improved. There were a large number of challenges, including one automatic reactor scram, several operational transients, numerous ,

equipment problems, and a Unit 1 refueling outage. Operators, plant equipment, and plant  !

personnel performed well in response to these challenges. However, operator errors, I particularly related to configuration control problems, continued to occur at a relatively high rate and remained a station concern. Operator knowledge was generally high, although a deficiency in understanding the feedwater flow transmitter contribution to the reactor level control system -

resulted in a reactor scram. Improvement in execution of the surveillance test program was noted with no missed surveillance tests since February 1998. Weak areas in the conduct of operations included a continued high number of operational challenges as a result of deficient equipment and personnel errors.

Equipment problems included an erratic feedwater regulating valve, erratic intermediate range monitors, a degraded recirculation pump seal, and various turbine equipment deficiencies.

Problems also surfaced with failure to apply vendor manual information for the scram discharge volume level transmitters and the feedwater regulating valve hydraulic controller. A loss of an offsite power source and various turbine generator equipment problems were the result of poor quality of maintenance activities. The quality of maintenance activities also caused an increase in radiation dose to workers, and added to a low work completion rate. In contrast, licensee efforts to reduce the maintenance backlog were successful and resulted in a decrease from over 1000 work items in June 1998 to less than 400 at year end. The licensee restructured the outage organization, and emphasized teamwork and communications during the Unit 1 outage.

Implementation of corrective actions to address past problems had improved, but some

- longstanding problems continued.

In the area of fire protection, the licensee's efforts to better understand the plant systems and electrical cable routing, coupled with hardware modifications and procedural improvements have resulted in substantial improvement in this area and a significant decrease in risk.

Implementation of the modification process and the 10 CFR 50.59 process has shown improvement. Since restart, the program at Quad Cities for identifying, resolving, and preventing problems has become much more effective. However, instances were identified where engineering personnel did not properly address emergency diesel generator start failures and qualification of commercial grade relays.

I Performance in plant support was consistent and, overall plant support performance remained I effective. Radiation protection and chemistry programs were properly implemented; however, some performance and housekeeping deficiencies were noted. The emergency preparedness program has been effectively maintained in a state of operational readiness. Overall performance during the 1998 biennial emergency preparedness exercise was effective.

Post-exercise critiques were self-critical, identifying appropriate strengths and weaknesses.

Security force performanco and equipment were generally effective, although vulnerabilities in vital area barrier and response capabilities were identified. Management controls, while I

l

,. . l

12

_ generally effective in identifying and resolving problems, did not fully resolve previous problems involving vehicle control and maintenance support, barrier integrity, and response requirements.

SMM Discussion-Quad Cities was a trending facility following the last SMM.

The senior managers considered the following factors from the plant performance evaluation template, in determining the appropriate agency response to the identified performance concems:

ARGUMENTS FOR MAINTAINING AGENCY ATTENTION Effectiveness of Licensee Self-Assessment The areas of self-assessment, the corrective action program, and the nuclear oversight organization have been the subjects of increased management attention and have shown improvements over the past year. The licensee is more proactive and thorough in its problem identification and resolution.

The engineering and technical support inspection team concluded that since the restart, Quad Cities had implemented an effective program for identifying, resolving, and preventing problems.

. ~ Operational Performance (Frequency of Transients)

Reactor operations, following restart of both units in May 1998, were generally conducted well with an adequate safety focus. Following scrams on June 27 &

28,1998, the subsequent simultaneous restart of both units at the end of June was performed without problems. All unit startups were performed well with 1 good communications and attention to operator activities. Response to plant transients resulting from equipment problems was also good. '

Since October 1,1998, both units have operated well. Unit 1 completed a record 28 day refueling outage in early December 1998. At the time, this was the shortest refueling outage in Comed history. Subsequent good operating performance by Unit 1 for about 100 days indicates the outage work was performed successfully.

.- Human Performance Significant improvement with implementation of the surveillance program. No missed technical specifications surveillances since February 1998.

i

- Strong teamwork and communications during the unit 1 refueling outage contributed to completing the outage in 28 days, at the time a record for Comed and a substantial achievement for Quad Cities, which had averaged over 100 i days for the past 4 outages.

i

13 Material Condition (Safety System Reliability / Availability)

The non-outage corrective maintenance backlog has been substantially reduced from over 1000 work requests in June 1998 to less than 400.

Completed further improvements in plant material condition (upgraded recirculation pump seals on both units, reduced the number of operator work-arounds, corrected some longstanding problems with Unit 1 High Pressure Core Injection, and implemented some fire protection hardware fixes).

- Engineering and Design Further fire risk analysis was performed by the licensee and periodic meetings have been held to review the licensee's activities in this area. Through better understanding of plant capabilities, the licensee determined that much of the equipment which was previously presumed to not be available would be free of fire damage.

The licensee completed another IPEEE whose results for fire (6.6E-05 per reactor-year) were improved (from SE-03), demonstrated the use of more -

realistic risk models, and included some hardware fixes.

l An engineering and technical support (E&TS) inspection, completed November 6,1998, concluded that the engineering and technical support provided by the design and system engineering groups was effective. In particular, implementation of ttle modification process and the 10 CFR 50.59 process, since re-start of the units after the extended shutdown, had shown improvement. l ARGUMENTS FOR INCREASING AGENCY ATTENTION

. Effectiveness of Licensee Self-Assessment It was noted that day-to-day use of problem identification forms was not as widespread as expected by licensee management.

Corrective actions for configuration control and out-of-service errors have not yet been fully effective. Configuration control and out-of-service errors continue to occur at a reduced frequency.

. Operational Performance (Frequency of Transients)  !

- Both units incurred scrams within 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of each other on June 27 and 28, 1998. The Unit 1 scram was due to a scram discharge volume level transmitter failure coincident with a surveillance test that had inserted a half scram. The Unit 2 scram was due to a turbine trip attributed to loose connections on a i transformer which actuated protection circuits during a local electrical storm l l

Areas of weakness continued to be configuration control problems, equipment  ;

14 failures, and out-of -service problems. These issues all contributed to the September 30 scram on Unit 1 which occurred when non-licensed operators isolated the "A" reactor feedwater flow detector for maintenance. This resulted in a full flow signal to the feedwater control system, causing a reactor vessel level transient that scrammed the unit.

. Human Performance The licensee continued to have problems with out-of service errors. Examples included: starting a Residual Heat Removal Service Water pump with a diver in the area, and releasing work without realizing it would render a primary containment valve inoperable.

Maintenance errors contributed to all of the reactor scrams.

Configuration control was identified as a continuing problem by the station. A significant example occurred when an improper valve line up during a swap of shutdown cooling trains resulted in draining about 7,000 gallons from the vessel to the torus.

. Material Condition (Safety System Reliability / Availability)

Although improved, material condition problems resulted in frequent issues for the station. The feedwater control system and turbine control systems have presented many problems which impacted operations.

Corrective actions have not been completed for some recurring equipment problems including: hydrogen addition tripping during condenser flow reversal, off-gas system combustion outside of the recombiner, and an erratic feedwater regulating valve.

- Engineering and Design Although substantial improvements have been made in fire protection, compensatory measures are still required to ensure compliance with Appendix R.

Since the last SMM, overall performance at Quad Cities has improved. Material condition and configuration treragement problems continue to challenge operators, but to a lesser extent than previously c,osented. Unit 1 operated at power throughout the period with the exception of a scram due to an operator error and a shutdown for a successful 28-day outage. Unit 2 operated at power during the period with the exception of an emergent outage to correct a recirculation pump seal failure and a scheduled 7-day maintenance and surveillance outage.

During the Unit 2 outage an improper valve lineup resulted in draining about 7,000 gallons of coolant from the vessel to the torus. Adequate fuel cooling was maintained throughout the event.

The senior managers considered the factors from the plant performance evaluation template in

15~

determining the appropriate agency response to the identified performance concems. Further engineering analyses, system modifications, and procedure enhancements had significantly reduced the risk from fire at the station; however, extensive fire protection compensatory measures still remain in effect at the site. The licensee's self-assessment processes, corrective

. action program, and effectiveness of nuclear oversight have improved over the past year. The licensee is more timely and thorough in its problem identification and resolution. Successful outages and a significant reduction in non-outage corrective maintenance backlog improved material condition. Plant transients caused by equipment problems have also been reduced.

Improved scheduling and completien of technical specification surveillances have been observed.

Although continued improvements remain to be made, particularly in the areas of configuration control, fire protection and material condition,' the senior managers concluded that the adverse performance trend has been arrested. As a result, Quad Cities will receive a routine level of oversight under the auspices of the NRC inspection program.

The followJng facilities have been categorized as Regional-Focus ( e.g., Plants requiring direct attention and/or involvement by the Regional Administrator).

MILLSTONE 3 Backaround information:

Beginning in 1991, the Millstone units have been discussed at every senior management meeting except June 1993. In the June 1995 SMM only Unit 2 was discussed. All three Millstone units, each of which ceased operating at some point during 1995-96, were designated as Category 2 plants on the Watch List following the January 1996 SMM. After the June 1996 SMM, the Commission identified all three Millstone units as Category 3 Watch List plants, which required that the units individually receive Commission approval to restart. Northeast Nuclear Energy Company (NNECO) later submitted a letter on July 21,1998, stating their decision to cease operations at Millstone Unit 1. The Commission subsequently directed the staff to no longer list Millstone Unit 1 as a Category 3 facility.

In August 1996, in response to inaccuracies in the Updated Final Safety Analysis Report and design configuration issues, the NRC issued a Confirmatory Order directing NNECO to establish an independent Ccrrective Actions Verification Program (ICAVP) to verify the adequacy of NNECO's efforts to establish adequate design basis and design controls. With the permanent shutdown of Unit 1, the requirement to perform an ICAVP at Unit 1, as stipulated in the ICAVP Order, was no longer necessary. As such, the staff has determined that with the permanent shutdown of Unit 1, NNECO was not required to perform an ICAVP at Unit 1. Additionally in October 1996, the NRC issued a second Confirmatory Order directing that before the restart of any unit, NNECO must develop and submit to the staff a comprehensive plan for reviewing and dispositioning safety issues raised by its employees, and ensuring that employees who raise safety concerns can do so without fear of retaliation. The order also required that the licensee hire an independent contractor to monitor the effectiveness of this new program.

1 4

I 16 The' staff addressed enforcement issues at the Millstone site since late 1995, combining regional issues with those from a speaal inspection conducted in 1996. Over 80 items were identified, ranging from engineering design issues to Office of Investigation findings from wrongdoing cases. Several Severity Level lli violations and a civil penalty of $2.1 million was -

issued for these findings in December 1997.

I

' On June .15,1998, after the staff provided its assessment that the licensee had taken ' J appropriate corrective actions to support the restart of Unit 3, the Commission provided its restart authorization for Millstone Unit 3.' Accordingly, the Watch List status of Unit 3 was changed from Category 3 to Category 2 following the July 1998 SMM. The EDO was designated as the senior manager responsible for approving commencement of actions to restart Unit 3. : On June 29,1998, the licensee submitted a letter indicating its readiness to enter Mode 2. On the same day, the NRC's Millstone Restart Assessment Panel completed all  !

of its activities associated with the execution of NRC Manual Chapter 0350 process and -

completed its review of all of the key technical and programmatic issues captured in the Unit 3 restart assessment process (RAP) and recommended that the EDO provide approval for NNECO to restart Unit 3. By letter dated June 29,1998, the EDO authorized NNECO to commence restart actuties. On June 30,1998, Unit 3 entered Mode 2.

Following the July 1998 SMM, the functions of the Special Projects Office (SPO) were merged into the NRC line organization. The SPO had been established within the NRR to provide specific management focus on licensing and inspection activities associated with the Millstone units. Oversight of inspection activities returned to Region I and oversight of licensing activities, including the activities related to the employee concems program and safety conscious work environment were returned to the NRR projects organization. Oversight of the ICAVP process remained under the cognizance of NRR's Associate Director for Technical Review.

Unit 3 resumed critical operations on June 30,1998, after a shutdown of over two years. Since

- June 1998 there have been three manual reactor trips from full power, one automatic trip from full power caused by an unexpected main steam isolation valve closure, and one forced outage to repair auxiliary feedwater isolation valves. Two of the manual trips were associated with high conductivity at the dircharge of the condensate pumps due to salt water intrusion. The third was in anticipation of a loss of condenser vacuum due to fouling of the circulating water system during a storm.

Unit 3 performance has been acceptable. ' Operators have characteristically made safe,  !

conservative decisions regarding plant operations and have worked to raise the standards for operations._' However, several Unit 3 operational events resulting from procedural or equipment ,

deficiencies challenged the operators with the plant transients noted above. The operators' l responded well to these events. Management extended the shutdown following the main steam isolation valve failure and associated plant trip to address equipment deficiencies which were i burdening operators. 1 Maintenance and engineering work since the resumption of Unit 3 operation has been performed well. Management has prioritized work as needed to support safe conduct of Unit 3

operations. Progress has been made in addressing the backlog of issues deferred at the time of restart. ' However, a large station workload associated with preparing for the Unit 2 restart and the Unit 3 refueling outage, and the backlog of corrective actions constitute a significant,  ;

y continuing challenge. Steps have been taken to improve station work control and planning N

r 17 L processes but progress has been slow. Performance of plant support organizations continued J

to be good. t i I The conduct of engineering was generally good, but the large workload associated with the restart of Unit 2 and Unit 3 deferred items limited support for operations following restart of Unit

3. This contributed to the Unit 3 plant events described above. In addition, several modifications performed late in the Unit 3 outage during final system testing and preparation for restart were not thoroughly engineered and resulted in equipment damage in one case. The

- lCAVP for Unit 3 completed at the beginning of the period indicated that efforts to reestablish compliance with the licensing and design bases were effective.

Radiation protection activities at Unit 3, including the ALARA program, were generally effective.

The radioactive liquid and gaseous effluent, environmental monitoring and plant security programs continued to be effectively implemented and maintained. Improvements have been made in the Unit 3 fire protection program. However, the NRC identified inadequate corrective actions to resolve high-impedance fault problems on certain vital power panels.

On January 12,1999, the staff recommended lifting the October 1996 safety conscious work environment / employee concems program order in SECY-99-010. The basis for this recommendation was discussed in a January 19,1999 meeting with the Commission.

Inresponse to a subsequent SRM, the staff provided the Commission information on future inspection plans to assess the status of the safety conscious work environment and employee concems program. On March 9,1999, the Commission approved the staff's recommendation to close the safety conscious work environment / employee concerns program order, and requested the staff to provide its future plans to continue monitoring the safety conscious work environment and employee concerns program by May 28,1999. By letter dated March 11, 1999, the Director of NRR closed the safety conscious work environment / employee concems program order requiring an independent, third party, oversight. j On March 9,1999, NNECO was issued a Severity Level ll Notice of Violation and proposed j imposition of Civil Penalty. This violation was as a result of investigations by the NRC Office of Investigations, NNECO employee concems program organization and Little Harbor Consultants  !

that determined that two contractor employees in the Motor Operated Valve Department at  !

Millstone had been retaliated against in August 1997 for engaging in protected activities.  !

Although NNECO senior management was slow in recognizing and responding to early indications of retaliation, subsequent to the employee concerns program and Little Harbor Consultants investigations, NNECO took significant actions to reverse the terminations, as well as improve the climate at the Millstone station to ensure that a work environment exists such that employees feel free to raise safety concerns. Additionally, in response to the results of investigations that various employees and supervisors had been subject to retaliation for 4 engaging in protected activities, the Commission appointed a Millstone Independent Review Team to conduct an independent review and make recommendations. The Millstone Independent Review Team completed its assessment and provided its report to the Commission on March 12,1999. Based upon the report, the Commission issued three Severity i

' Level ll violations after concluding that discrimination had occurred. The Commission  ;

authorized the staff to exercise discretion and to refrain from issuing a civil penalty in this case in recognition of the substantial action that NNECO has taken to address the general and widespread employee concems and discrimination problems.

p' m i

i

[

,7 18 SMM Discussion:

Millstone 3 was a Category 2 facility following the last SMM.

The senior managers considered the evaluation matrix in determining the appropriate agency response to the identified performance concems.i Recent performance at Millstone was characterized by slow but steady improvement. The senior managers discussed the number of operational challenges experienced since the restart of Unit 3, the robustness of the corrective action program, employee concems, safety conscious work environment and the existing backlog of work. The discussion concentrated on determining whether Unit 3 performance met the criteria necessary to be designated as a routine oversight or regional-focus plant or whether additional attention was required.

The senior managers determined that Millstone Unit 3 had not met several of the criteria for retuming to routine inspection oversight, including the demonstration of sustained, successful plant performance. Specifically, while the licensee has characteristically made safe, conservative decisions regarding plant operations and has worked to raise standards, the number of operational issues following Unit 3 restart was an area of concem. This included several plant trips and entries into technical specification statements requiring initiation of shutdowns over the six months following restart that were related, in part, to previously identified problems and equipment concems. The licenses took steps to address these concems with some positive results noted recently in operations, but additional time is needed to judge the effectiveness of licensee efforts.

The senior managers noted that progress had been made in addressing the backlog of issues deferred at the time of restart. However, a large station workload associated with preparing for -  !

Unit 2 restart and the Unit 3 refueling outage and the backlog of corrective actions constitute a l significant continuing challenge. At the same time, the licensee will be completing the irnplementation of a major reorganization. While progress has been made in developing a i safety conscious work environment and handling of employee concems, heightened monitoring of these areas are warranted. It was noted that, as directed by the SRM associated with the Commission briefing on the status of third party oversight of the Millstone Station employee concems program and safety conscious work environment, the staff intends to provide the Commission its plans for monitoring the safety conscious work environment and employee j concoms program by May 28,1999. The senior managers determined that Unit 3 warrants  !

oversight as a regional-focus plant. 1 i

CUNTON i  ;

Background Information:

Clinton Power Station was first discussed during the January 1997 Senior Management  !

Meeting due to an overall decline in plant performance during 1996. The decline was clearly l

' demonstrated in September 1996 events associated with a reactor recirculation pump seal failure which revealed significant deficiencies including problems with procedural adequacy and

i 19 adherence, the degree of rigor in conducting operations, and engineering support to operations. i Based on the results of the January 1997 SMM, Clinton Power Station received a trending lettori The licensee's poor performance.in operations continued during the next six months. A

- number of procedural adherence violations continued to occur. In addition, similar poor performance was noted in radiation protection. While the material condition of the plant improved as a result of a concerted effort by the operations,~ maintenance, and engineering staffs, surveillance program weaknesses and inattention to detail during maintenance activities continued to contribute to equipment performance problems. Furthermore, weak engineering support for the station, incomplete and untimely root cause evaluations and corrective actions,

- and design errors hindered equipment performance.

During the June 1997 SMM, NRC senior managers were concemed that the licensee had not developed a comprehensive response to the NRC's January 1997 trending letter. While the licensee had implemented a number ci short-term corrective actions, it had not developed a long-term approach to address performance deficiencies. It was not clear to the senior managers that the licensee had a full understanding of the depth and scope of the reasons for the performance issues at Clinton. Therefore the senior managers determine 1 that allowing the

, licensee to perform an integrated Safety Assessment (ISA), in lieu of conducung an NRC Diagnostic Evaluation Team inspection, was an appropriate approach to better understand the reasons for the decline in the licensee's performance and develop applicable long term corrective actions.

The licensee conducted an ISA from August through October 1997 to review its performance.

The NRC reviewed the effectiveness of the ISA with a Special Evaluation Team (SET). The ISA identified significant weaknesses in the areas of operations, engineering, maintenance and plant support. The SET confirmed the ISA's findings.

During the January 1998 SMM, NRC senior managers were concemed with the lack of progress by the licensee in developing a comprehensive plan to address performance j deficiencies. Despite being shutdown for a considerable length of time, there had not been substantive progress made in addressing the major performance issues at Clinton. NRC senior managers were also concemed with the licensee's continuing problems associated with procedural inadequacies, a cumbersome work process, operator performance, and ineffective self-assessment activities. Following the January 1998 SMM, Clinton Power Station was placed on the NRC Watch List as a Category 2 plant. In January 1998, PECO Energy Company

- (PECO) was selected by lilinois Power to provide management services for Clinton for the next l 3 years. Since that time, most key managers at Clinton have been replaced.

While some performance improvement from January 1998 to June 1998 was noted, licensee performance remained inconsistent and processes for improvements were not yet self- 1

- sustaining. The licensee struggled .with managing the large backlog of condition reports and  !

many problems remained unresolved. A new work control process was implemented, but was not yet effective in ensuring proper prioritization and accomplishment of work. Performance

. Improvement initiatives addressing these and other areas were contained in the licensee's Plan-for-Excellence. However, the Plan was not yet fully implemented.

During the July 1998 SMM, the senior managers considered the Watch List removal matrix in i

I i'

m .. . _ .. . _ __ .. . -. - -- -

20

~ determining the appropriate agency response to the performance concems. In reviewing the Watch List removal matrix, the senior managers focused on the numerous criteria that the plant had not yet achieved. The senior managers discussed the licensee's organizational changes r and decision to extend the shutdown in order to complete human performance and hardware improvements, such as those associated with the electrical breaker and degraded voltage i concems. It was noted that while management oversight at the facility had improved and a new comprehensive recovery plan and corrective action program had been developed, equipment

. condition and human performance problems continued to surface since the last SMM, indicating that these programs were still in the early stages of implementation. The senior managers determined that there was a continued need for high level NRC attention at this site and that '

Clinton Power Station would remain a Watch List Category 2 facility.

Since the last SMM, Clinton Power Station has remained shut down. Steady progress has been made to address restart items; however, resolution of some items was delayed because of insufficient implementation of the licensee's corrective action plans. As a result, additional NRC follow-up inspection activities have been warranted. The three areas of most concem with the performance at Clinton have been operator performance, corrective action program implementation, and the resolution of engineering design issues.

Performance in plant operations remained consistent. Recurring issues such as the failure to document compensatory actions for disabled annunciators, unfamiliarity with existing control room deficiencies, technical specification compliance problems, emergency operating procedure implementation problems during drills, and weak self-assessments indicate that much improvement is still necessary in the operations area.

Performance in the maintenance area improved as the period progressed. Early in this period, l both programmatic and human performance deficiencies existed in the maintenance functional l area. In addition, the maintenance rule program was not adequa%y implemented.  !

Improvement has been noted in all of these areas during the past several months. The l adequacy of and adherence to procedures and the scheduling and completion of surveillance l tasks has significantly improved. Engineering department performance has improved especially with regard to issue identification. Reviews and assessments of selected systems' design bascs have identified multiple examples of engineering deficiencies. In particular, the System Design and Functional Validation review and the fire protection re-validation project were comprehensive and effective in identifying programmatic issues.

Radiation protection and chemistry department performance improved during the assessment period. Improvements in radiological planning and communications were observed during the I replacement of emergency core cooling system strainers. In addition, the chemistry staff's adherence to sampling and quality control procedures improved.

Although many corrective action program deficiencies were identified during recent inspections conducted to assess the licensee's readiness to restart the plant, the corrective action program is considered adequate to support plant restart. Licensee and NRC assessments indicate that in a number of instances, root cause evaluations were inadequate in identifying the correct root cause and effectively addressing the particular issue'. However, no recent instances of

h I ,

21-significant recurrent problems have been ?dentified. This level of effectiveness was considered

adequate to close the NRC Demand for Information concoming the effectiveness of the -

corrective action program.

The NRC Manual Chapter 0350 Oversight Panel for the Clinton station continued to assess progress on corrective actions necessary for safe plant restart. At the time of the SMM, the licensee was preparing for plant start-up. As of April 16,1999, all restart items had been

. resolved.

SMM Discussion: .1 i

Clinton was a Category 2 facility following the last SMM.

With PECO providing significant management and technical support as a contractor, the licensee continues to make progress implementing its Plan-for-Excellence and preparing for restart. Improved performance was noted in the areas of radiological protection and quality of j

maintenance activities. Recent NRC Manual Chapter 0350 Restart Panel activities have l focused on the areas of operations, corrective actions, and resolution of design problems.  !

While licensee activities were successful in resolving longstanding problems with setpoint calculations, completing System Design and Functional Validation activities, and accomplishing degraded grid voltage modifications, continued problems were observed with the corrective

~ action program and operations areas. Recent NRC restart inspection activities identified recurring deficiencies with operator performance that required remediation and mentoring by i l

contractor personnel in the control room. Similarly, NRC inspection of the corrective action program identified recurring deficiencies with the resolution of problems. These recurring problems delayed completion of the restart inspections pending licensee enhancements to  !

improve performance. Senior managers remained concemed that although licensee  !

performance appeared adequate to warrant restart, NRC monitoring and inspection should be  ;

continued to assure that long-term performance remains acceptable after restart.  !

4 The senior managers considered the evaluation matrix in determining the appropriate agency

' response to the identified performance concems at Clinton. The responses to several of the i factors were negative or unknown. Some of the recurring problems in the operations and

. corrective actions areas involve a lack of management oversight and involvement, similar to the  ;

root causes identified during the Integrated Safety Assessment and Special Evaluation Team, i but to a lesser extent. Susta!ned successful plant performance has also not been .

demonstrated. Senior managers were concemed that the potential reduction of enhanced PECO management and technical support after restart, as well as the transition which would be associated with any future change in station ownership, may necessitate increased inspection and monitoring activities. Based on these concems, the senior managers concluded that there l was a continued need for regional level oversight at the Clinton facility.

i

22'

The following facilities have been categorized as Agency-Focus (e.g., Plants requiring direct attention and/or involvement by the EDO and/or Commission).

MILLSTONE 2 -

packground Information Rofer to the Millstone 3 discussion for historical background information.

As previously stated, NNECO management's decision to focus resources on Unit 3 recovery and restart activities significantly delayed the Unit 2 recovery efforts. Unit 2 remained shutdown throughout the period since the last SMM.

The Unit 2 ICAVP was conducted to independently verify, beyond the licensee's normal quality assurance and management oversight, that their corrective actions had (1) identified and satisfactorily resolved existing nonconformances with the design and licensing bases; (2) documented and utilized the in,ensing and design bases to resolve nonconformances; and (3) established programs, processes, and procedures for effective configuration management in

. the future.

Parsons was selected by NNECO and approved by the NRC to conduct the ICAVP at Unit 2.

Implementation of the Unit 2 ICAVP was carried out using a three-tiered approach as described in SECY-97-003, " Millstone Restart Review Process," and specified in an NRC-approved audit plan prepared by Parsons. On April 9,1999, the staff provided the Commission its-assessment of the Unit 2 ICAVP and recommendations regarding authorization of restart of Millstone Unit 2 in SECY-99-109. The staff concluded that:

1. NNECO had satisfied the requirements of the August 1996 Order. The Unit 2 ICAVP has been performed to the satisfaction of the staff and the results of the ICAVP and the staff's oversight provide confidence that Unit 2 is in compliance with its design and licensing bases.

2. NNECO has in place configuration control programs that, if properly implemented, will be effective in maintaining conformance with the unit's design and licensing bases.

3. NNECO has an adequate corrective action program at Unit 2, as demonstrated by the effectiveness of the corrective actions to resolve ICAVP related issues.

- 4. The ICAVP area has been adequately addressed to support restart of Unit 2.

The NRC increased oversight of Unit 2 corrective actions following the restart of Unit 3 and when NNECO concentrated its efforts to resolve issues associated with Unit 2 restart. Based on the results of the Operational SafetyTeam inspection, the Corrective Action Program Team Inspection, inspections of 0350 Significant items List issues and routine Resident inspections, )

operational activities associated with plant restart have generally been conducted well. While there were a number of operator errora during the initial restoration of equipment to service, actions taken to provide better support to control room staff have reduced errors significantly.

l 23 l

Maintenance activities have been performed well. However, implementing the new on-line work

. control process during startup remains a challenge. Engineering support for operations has been effective. The corrective action program has improved.

The backlog of items deferred at startup and other corrective action issues is large and has strained resources. However, licensee management has effectively reprogrammed resources

~

and priorities to implement corrective action program improvements over the long term.

Activities associated with Unit 2 restart, the Unit 3 refueling outage, backlog reduction efforts and management reorganization present significant challenges.

The corrective actions implemented by the licensee for the enforcement items issued between 1996 and 1999 have been evaluated by the staff and have been determined to be adequate.

On April 14,1999 the staff, along with Parsons and NNECO, briefed the Commission on issues related to the restart of Unit 2. The staff provided a summary of independent NRC actions supporting the staff's decision making on Unit 2 restart. As of the April 1999 SMM, the Commission had not made its decision regarding the restart.

SMM Discussion:

Millstone 2 was a Category 3 facility following the last SMM.

The senior managers noted that Unit 2 required Commission approval for restart. The senior managers discussed the performance of Unit 2 and reviewed the evaluation matrix. Unit 2 will continue to receive agency-levd oversight.

D.C. COOK Backaround Information D.C. Cook was first discussed at the July 1998 SMM. The SALP report issued in March 1998, indicated a significant decline in licensee performance in the area of engineering. An NRC Architect Engineering (A/E) team inspection, conducted from August through September 1997, resulted in the identification of significant design control and design basis issues. After further I review of these issues, the licensee identified that the units had operated outside the design ]

basis on multiple occasions and further determined that several safety systems were inoperable including the refueling water storage tank, residual heat removal system, and portions of the service water, instrument air and component cooling water systems. The NRC identified that

. the installation of fibrous material inside the containment and the potential blockage of

- ventilation holes in the containment recirculation sump which could have rendered the

- emergency core cooling system inoperabje, also exemplified engineering program deficiencies in design changes and licensing basis reviews. The licensee shutdown both units in September

.1997 to address these and other related concerns.

During the July 1998 SMM, the discussions of the senior managers primarily focused on the risk significance of the engineering and design issues identified at D.C. Cook. Specifically, the deficiencies associated with the ice condenser, the containment recirculation system, and the l

v 24 containment hydrogen abatement systems were of particular concem to the senior managers.

The senior managers also noted that the performance indicators and Licensee Event Report

' data revealed a declining performance trend in the first quarter of 1998. The senior manageis acknowledged the risk significance of the containment deficiencies and other material condition problems identified in the PlM.

The senior managers concluded that the licensee and NRC may in fact not fully understand the extent of problems at D.C. Cook. While it was initially thought that the problems may be limited to the engineering and surveillance areas, the senior managers decided that additional information was necessary before such a determination could be validated. The NRC response to the licensee's ongoing programmatic and functional area assessments and plant system verification reviews was discussed and senior management concluded that special inspection activities were warranted in these areas.

The senior managers acknowledged that there has been a slow decline in the observed performance at D.C. Cook for some time and that, combined with the risk-significant engineering issues at the site, there was a need to communicate this decline to the licensee.

Thus, the senior managers agreed that a trending letter was appropriate to corwey the agency's concerns with D.C. Cook's performance. In conjunction with the trending letter, a Commission meeting was held on November 30,1998, with the NRC staff and licensee corporate management.

Overall, the licensee has made limited progress towards resolving the performance problems that resulted in the decision to maintain both units shutdown since September 1997. Late in 1998, the licensee realized that previous improvement initiatives were not achieving the desired goals. The licensee recently demonstrated that it is committed to aggressively evaluating its processes and programs to define the breadth and depth of problem areas. The corrective actions process review and the engineering assessment were two examples of insightful self assessments performed by third party teams chartered by the licensee. As a result of these and other self-assessment initiatives, important licensee prograrnmatic activities such as engineering support, maintenance planning, and root cause evalur! dons were suspended near the end of the assessment period while management planned to revise those programs and processes and retrain the individuals responsible for those factions. The licensee had planned to restart Unit 1 in March 1999, but recently delayed the restart pending the completion of enhanced system readiness reviews and associated ccirective actions to ensure safety system operability at restart.

Overall performance in the operations area has declined at the facility. Problems continued in the areas of human performance and procedural quality. While there were some examples of proper questioning attitudes and attention to detail, there were also some significant personnel errors. For example, contrary 1o site p;ocedures and the Updated Final Safety Analysis Report, operators started a second residual heat removal pump with the reactor coolant system vented to atmosphere. Also, following an electrical trip of a centrifugal charging pump, the operating crew attempted to restart the motor contrary to station procedures and despite indications of damage to the component. Performance issues were also identified with respect to the quali+y and timeliness of the licensee's operability evaluations. In addition, based on observations of several operating crews, !! was noted that overall operator performance during simulator scenarios was weak. A contributing factor to the simulator performance problems was inadoquate documenthtion for the emergency operating procedures. Self-assessment efforts in i l

e

25 operations showed improvement; however, operations management continued to demonstrate a weakness in taking timely and effective corrective actions.

. Generally, maintenance activities were performed in a thorough and professional manner and

~s ignificant efforts were mado to improve the material condition of several important systems.

However, weaknesses in the work control process and engineering support resulted in continued examples of equipment deficiencies which included steadily increasing leakage between the two units' chemical and volume control systems and cross-tie leakage between redundant divisions of the component cooling water system. Additionally, the plant preparations for cold weather were weak resulting in multiple challenges to plant operators. Also, evaluation of the maintenance and testing of motor-operated valves revealed a number of valves that could not be demonstrated operable, including several requiring physical modifications to ensure they would function under design conditions.

The engineering staff had a narrow perspective with a limited application of industry bench '

marking.- This contributed to the failure to adequately maintain the plant's design basis and the degradation of safety-related systems and components. As a result of these issues, the licensee implemented system readiness reviews which were intended to bound the safety impact of engineering deficiencies. Due to wsaknesses in the development and implementation of the system readiness review program, the reviews failed to identify notable deficiencies in some safety-related systems. The NRC's motor operated valve inspection and the licensee's Safety System Functional Inspection of the auxiliary feedwater system revealed component and system operability concems that had not been identified during the system readiness reviews.

The licensee subsequently commissioned independent assessments of the engineering area to identify the problems with engineering staff performance and the system readiness review process. To address the findings of these assessments, a comprehensive retraining effort for system engineers was initiated and the scope of the system readiness review effort was expanded. On a February 11,1999, a public meeting was held at NRC headquarters offices to outline the licensee's proposed Expanded System Readiness Review Program. The expanded

- system readiness reviews, which are in progress, have been effective in identifying significant operability concems with safety systems. These actions demonstrated appropriate management use of independent engineering assessments to address engineering staff lapses in the understanding and maintenance of the design basis. Further, the content of current licensee event reports suggests that the engineering staff have lowered their threshold for identification of design basis issues and are demonstrating increased understanding of the design basis. However, these improvements are due, in part, to the large influx of contract engineering staff.

Overall the plant support programs were well implemented. The radiation protection, chemistry, and radiological environmental monitoring programs were effective and self-assessment activities were good. Security performance was also good, but there were problems with some routine activities and issues related to the depth and scope of self-assessments.

The NRC Manual Chapter 0350 Oversight Panel for the D.C. Cook station continues to hold frequent public meetings with licensee management to assess progress on corrective actions necessary for safe plant restart.

26 SMM Discussion:

D.C. Cook was a trending facility following the last SMM.

The senior managers considered the following factors in determining the appropriate agency response to the identified performance concerns:

i ARGUMENTS FOR MAINTAINING AGENCY ATTENTION  !

Effectiveness of Licensee Self-Assessment There were some indications that the licensee's self-assessment process improved. For example, the licensee performed thorough self-assessments of the MOV program and the radiation protection area. i The licensee commissioned several independent assessments which identified l significant programmatic problems in engineering, training, and corrective actions. Although the licensee staff currently has difficulty identifying and resolving problems, licensee management was quick to bring in outsiders to help find problems and coach the staff.

An independent assessment of the licensee's Corrective Action Program ,

i identified several programmatic weaknesses. The licensee placed a stop work directive on the performance of root cause analyses until additional training and management directions could be provided. In addition, guidance was provided l to line management as part of the Corrective Action restructuring effort.

In addition to the Expanded System Readiness Reviews, the licensee is implementing functional area and programmatic reviews to assess the overall effectiveness of the plant organization.

. Operational Performance (Frequency of Transients)

The licensee maintained both units shut down in an extended outage since September 1997 in order to address equipment, personnel performance, and programmatic deficiencies. Although some minor in-plant events have occurred, no significant events occurred during the latest assessment period.

. Human Performance

- Human performance during this assessment period was consistent with the previous period. In response to the occurrence of personnel errors, the licensee was taking action to affect sustained, improved performance through the implementation of Departmental Leadership Plans.

. Material Condition (Safety System Reliability / Availability)

- The licensee made sign 3icant progress in improving the material condition of the 4

27 ice condensers and the containment spray systems. The Expanded System Readiness Reviews have been effective in identifying material condition issues that will be considered for resolution prior to restart.

. Engineering and Design The licensee commissioned independent engineering assessments and decided to expand the scope of the system readiness review effort. This action demonstrated appropriate management utilization of independent engineering assessments to identify / correct engineering staff weaknesses in understanding and maintaining the facility design basis.

Based on the content of current licensee event reports, it appears that the engineering has a lower threshold for identification of design basis issues and an increased understanding of the plant design basis.

ARGUMENTS FOR INCREASING AGENCY ATTENTION

. Effectiveness of Licensee Self-Assessment The licensee's staff has yet to demonstrate consistently that they can find and correct their own problems without outside help.

. Operational Performance (Frequency of Transients)

The in-plant activity level has come to an almost complete halt as the licensee stood down most engineering support, root cause investigations, and maintenance planning. The licensee had difficulty conducting more than a minimum number of activities at one time.

. Human Performance In spite of the low activity level, personnel errors continued to occur. For example, following an instantaneous over current trip of the Unit 1 West Centrifugal Charging Pump the operating crew attempted to restart the motor even though there was indication of damage to the electrical circuit and the action was in conflict with annunciator procedural requirements. In maintenance there were three examples of work performed on the wrong unit or equipment.

l

. Material Condition (Safety System Reliability / Availability)

- Material condition remained poor during this assessment period. With the Expanded System Readiness Reviews partially completed, the licensee has identified greater than 4000 material condition deficiencies. Recent problems included a steadily increasing cross tie leakage between the Unit 1 and Unit 2 Chemical and Volume Control Systems; cross tie leakage between the east and west trains of the Unit 1 Component Cooling Water System; and normal and l

28 emergency boric acid flow paths blocked with solidified boric acid. In addition, there are'potentially 44 inoperable motor operated valves.

. Engineering and Design

' Although a comprehensive Restart Plan has been implemented, inspections that followed the licensee's system readiness review process continued to identify design basis issues that impacted system operability. The licensee has initiated ,

an Expanded System Readiness Review process using contract support and is )

discovering additional problems.

The senior managers focused on the issues concoming the adequacy of the design bases for the two units. Significant operability concems with the Auxiliary Feedwater System and Motor-Operated Valves were identified by independent contractors and the NRC that were missed by the licensee's System Readiness Review assessments. As a result, the licensee placed its ,

restart plans on hold and refocused its engineering program using outside resources to i establish an Expanded System Readiness Review Assessment of safety systems. To date the j review efforts have identified significant operability concems with safety systems and created an extensive backlog of corrective actions for restart, several of which may require license amendments to resolve.

The senior managers considered the factors from the plant performance evaluation template in determining the appropriate agency response to the identified performance concems. The ongoing Expanded System Readiness Review efforts appear to be thorough; however, NRC l validation of these assessments has not been completed. The senior managers were concerned that further problem discovery and actions to resolve the issues have been I necessary after multiple extent-of-condition reviews. However, the senior managers emphasized that currently the licensee appears to be appropriately responding to these significant issues. The licensee is utilizing extensive extemal expertise and contractor support to identify long-standing design problems, instituting program changes to prevent recurrence,

{

and delaying restart until an integrated solution is developed to resolve the identified issues. q l

in determining what further NRC oversight should be provided, the senior managers also' l considered current NRC activities and expected actions that will be needed to fully assess and support the restart of D.C. Cook. To date, a Commission meeting with licensee executives has been conducted and several site visits by NRC executives have occurred. The NRC Manual ,

Chapter 0350 Restart Panel, directed from Region lil, has been providing adequate oversight '

during the Expanded System Readiness Review initiative. As licensing issues are identified, a significant amount of resources from NRR may be required to support safety evaluations and license amendments. Based on these activities, the senior managers considered that the licensee was currently receiving agency-level oversight. Since the licensee was still in the problem discovery phase of its restart plan, the senior managers concluded that continued i agency-level oversight was appropriate; however, no additional action was required by the NRC l

' at the present time to redirect licensee activities. The staff will continue to monitor and inspect licensee performance through the NRC Manual Chapter 0350 Restart Panel process and evaluate whether additional action is necessary in the future. The staff will also ensure the Commission remains informed of licensee recovery efforts.

29 p Additional Topics Discussed:

1. Commonwealth Edison Performance Overslaht Panel The senior managers discussed the status of the Commonwealth Edison (Comed) system-wide performance oversight activities conducted by the NRC staff. The Comed CPOP was

' established in June 1997 to review Comed'a commitments for improvement in response to an NRC Request for information made pursuant to 10 CFR 50.54(f). Since then, Comed system- ,

wide performance has been discussed at both the SMM and periodic Commission Meetings. '

Comed has implemented 13 strategic reform initiatives to improve overall performance at all of its sites and at the corporate office. I At a meeting held on March 2,1999, members of the NRC staff and representatives from Comed briefed the Commission on the progress and improvements at Comed nuclear facilities.

Both Comed and NRC assessments recognized improved performance in problem areas without a corresponding decline in other performance areas. In a subsequent SRM dated March 26,1999, the Commission requested further information from the NRC staff as to the criteria to be used to determine when the NRC would normalize inspection resources at Comed facilities and discontinue the CPOP.

Since the July 1998 SMM, the senior managers noted that overall performance had improved at the Comed sites and that problems were being identified and addressed without significant NRC interaction. It was noted that the NRC inspection plans for the Comed facilities included primarily routine inspection activities with only a limited amount of regional initiative inspection.

The senior managers discussed seven criteria proposed by the CPOP for discontinuance of its oversight activities. The NRC staff had previously concluded that the 13 Strategic Reform initiatives address the five apparent causes for cyclic performance identified in the NRC request j for information that initiated the system-wide focus. The seven criteria are intended to ensure j

' that (1) strategic reform initiative work plans bounded the apparent causes and were effectively  ;

implemented, (2) safety performance at all Comed sites had improved to an acceptable level, and (3) Comed self-assessment capabilities would permit early identification of and intervention ,

on declining performance at a site. The senior managers discussed the proposed criteria and I noted that with the improved performance observed at the Comed, the NRC review of the

. Comed strategic reform initiative effectiveness assessments was the only major activity to be completed. <

2. EDO's Openino Comments l

The EDO welcomed the serhor managers in attendance and noted that since the last SMM, the staff has worked on a number of key activities and that there have been numerous accomplishments that built on ongoing initiatives. Although there have been a number of successes, there remain many challenges including the management of the agency during the transition while implementing the initiatives. The EDO welcomed the Chairman, noting that this was the last SMM during the Chairman's term and expressed the staff's appreciation for her leadership and guidance.

l E

30

3. Chairman Jackson's Remarks Chairman Jackson noted a number of the agency's recent accomplishments, as well as challenges that remain. These achievements were t,naracterized on four levels including:

regulatory issues, process and program changes, framework changes and achievements of vision. The Chairman noted that the challenge before us is to finish and perpetuate the initiatives that we are working on and to be mindful of the message that we send to both our internal and extemal stakeholders.

4. Other Toolcs of Discussion

- Overview of SMM Process Revisions and Format

- Staff Response to the inspector General Survey

- Planning, Budgeting and Performance Management

- Arthur Anderson Review of NRR

- Federal Advisory Committee Act

- Human Resource issues

- Pace of New Activities / New Programs

- Performance Assessment and the SMM of the Future

- Program and Staffing Trends / A Look Ahead - Future NRC

- Burden of Proof in Harassment and intimidation

- May 6,1999 NRR/ Regional Administrator Meeting Topics I

{

g l f: j

.t

\

l l

l l

I l

i ATTACHMENT 2 Senior Management Meeting Agency-Focus and Regional-Focus Removal Evaluation Factors Millstone Clinton LaSalle l

l, l

l 1

I.

1 i o 1 l

l'

L n

t n e A s o h a r h wvea ecn t

foi o it f N ei t ui e ,t , h e oe O v dssd 8 dg t I

S sdeeha sdathc t wte e e eya i oanpcr c

t nu aoeinio a c cn nsm i

I C lanoan e o nas r vdet gh i t n r c r rhuel r aus Covte ce mne ve E t n I t ioo l

l nt cir a D- e e pi t onaiv c ue i

f m

esmar e edfoJ r an sdes seri r e eiv E

R alinn o olup ca l ekr bodf

,f r i rid a efiour ct c ss e e t

c P

dcp nese r e ae vk aw e oeeeneee ph R on r ed/ihr t

pe wr pdeR t r go c nsoew t

f ude r ef be hnr t i i S e e t

s emi ca vdst ia is n ,iCn f c

T N

hncie t

adrhef o cr af eeaf rt ,a hoe e dts seelatn0 s upu e5 i0 y eoTs.a t e s sdv0 E imt f t n hedun a saR ed cs _

n M t r c nou essese ar at ielal s pd r cieive4 uf o sothid rpI f _

M efrdu dsivpu eet ne un a a n i

de n s ac hdedo rdinT isivdni ct a w t

c O i po sbi s den iS A C o t ll ci t

a t l

o ebaf v o deO s raefy ngm lbroiactal e an T iem)ssae l

e weet nsm rii taprde st a e e as s s

hc unRn mh v evwe na e ha st vm wer Ci o T e io sdcg er a e( t n i

v n ectc dang sgr sec es L enw o l or ri i

i st a

hmir or e nl r a o "n.

a at em it orr u pPio os pb e ddiet dp r y hl teevr n e t c t e ea eradc n of is" a eapnsb l n clu rdr nt h u se eg so o eahTeS c e h r, t egreI s a ro

.h _

e gd nr c s ,t t n ninesp s A

g devOie nri s i . ePeu ns ic nrsaosel,o

.te n e es csiuef or sc i ohnVdtsPei2 f t oe cien eisri i

c l irl t i 9ts l rdagc Uh ceAeen ni t m

i t eivtoddc9l t

hcdodde9i l edn eor pe o NweIxChdU t i TAar aad1 M hdo Tacmps 2 r f

T I s E N t S n N U l a O _

E P P -

N f S s s s 2 o E e e e 3 O

R Y Y Y T l a -

S v -

L L

o t I m n M e e v

R n e r d o r p

o e s

it c o f

s a t s

r e

s e s e

v t

o s a

i t

c r

u c e s a ly r r

a S h o e F R g c m n u O

e o d d t n

o T t r

o e ie i

t C c h in ic a A e r

t f e . f u F r o ra e dd e f u

l a N y p s .

C s l -

O al o e r

v d a d E

I T n e eev us A a a r lc e lcm U d dd ne L e e n n isb l A c ae V

i f

i t

n a ee no iop r E n m vb t e iss cf d

r o na ao i f eh ee ivnc r

e e h s p em r

pa t

cerer u

a ka r C mg r u r

e o or o ce o W Cp t

Cr o

R 9

9

/ 1 4

r b

L A d g~ s h'

e n gs N

O t

a i

s' r ed cn it w n inons 'e n C R

s a

I S cic n die ho eur a s doese t

e it pi s i

i t

o Noht f e

I t c c n el,s C naic t o serec a t iu cme n e a l

a o cl i imv nCe l

E e vmg r dr u cdctodc o ninu a a et f

en D ndo o e i l

it Rv iot se der m w n ti r E- haais r aesmsrt s nne e . cNi t ge pi rnea agemhs Al ace dpo em R

P s wr od,P . uardogslos ef cr t e e nrr a of x ce r e p'sn C t

as r t eriek c re gor e o tct u v i

ic oo s,den p aie ga l wdo ss m piv a p ancs sat shna t t i

eeiE r stcE ahaioc t amnibn ,oanet ede r

rdh e

r pa nat ,md e S Pes aW ddgcAga rt eimer t

de Cf oat e .

gul de ot r r pevat e T CrdwS eC en oa z bo aieenb ot l l ptalaibdlp N E r ar pemtvr u on as nei e a Pncla y.

fo sr r

etecanam dt r E

M

/

Eacd f ee egrteie gev a l

Voib Ai d a sed o M Wlyre n r ct gr c i v t nt shodedc O Caoi r ad a y er gi e lnoiga Cleip nt sa l

l I pse igger eso e s sl sh C Stic v mivoo er nlertnet Cm Rosauc ec snh buk l bo nf ic cl ut cr i i e

f n eitr r r t dao nt ss d i es t eee eos ciw Ncs ig a ue edhaiwt n sot abac u ft cdw tcdsyy e i

ufe etnhr mrit osfe etr 3et pn h l inn st l Pue n ri e asi s meigu t u t

,le Lo e eeaAv a s Vsraio A~s Caea t k

gi s evnabd lonal ohp oUns at ne Tw I

mc sit rdnh aeit emt

.e a ndh h I hhrt u s,e nig ba eoeta dnu o ci t t ac mts ninr,mesre t ad ee a p

Ss ate u f n e hesteon r nr ie i e piahi a no n eif l

O 2 ' n,tni is t ndat swiz iat t

i t

o s s n n

emc o hie eemt t t v s msna ed ev e re srh ce o o it i amhogi o d usgn nt ciac t t c c gi t e

eicis pl ce ie re nr ro pi or osl l

aio2t ucy Uef t

t i r oe2heig n a uc se ns hr t i epng h tpi sn tacnla o or Wocaim mr pinfU se re oa nb hsgo AiUrel i

it nhoacb f TInSp ir l n e e adr

=

E S

N O

P S s s 3 E e e o 3 R Y Y N t

u o

y n r

r a i o

c is t n u o m e l

o t

a e s s r g b e e

c o s R r r a u p o n h m s o e l e

S e .

it c b r s c n o R t a a r O n m P T ea i r e m r

C cg v o d n

o i it f r

A f

f r c e a F up e p s n r r

t n

N do o c

t n e O ei t a m a c t .

l

_ I T ed p s A ca he s U l o ev t t t n l

u e ae f s

L lai s s s

_ A sc t

hm t

e A-V ae hr r dle c c

E o iep . f l

ud e si m t f nc se S e

mge it ,t aly dr a d

en st n et s et 2 ga ise inn vn oe a- r Ciic ao rd _

E N

ng an Rf u f

t sm ue pi v

O Mlo Ns Sd I mE -

T S _

L

_ L I I I

_ M

L A e s P N c ien m ,Cf O n a

t h nt d

e sra nE o o I

S e sn s t nmg io/e Ec h t n

ee o

,t m a t c c I

C r o mee et c ef r omip t r awe n u m,deeel d d i E f r gar c et ecd sevs D- e ade nsgnA ivSve i

aeeea p f onep i t n na aQ t dt nl e i

E d s au3 enidc cd ene emster R nmd n w sMgamain anc f

n n r av dt P a g

at eneh da hso it r

ol g c or s i

owcmri aeoy s e onSh rt i pl t mlal pd us t n . f t o noio n r t n

id e

vo ssiCig ast a pnf aoo a i te s ke s sl S ct au hle ha rRr s e ct cn t .

apnCc T ri t t cs cf nduNe ong v u sop ne e h yio t fi

.i n N

t t n s em so it af dod i

sism nie l

o al eig s n f a nnr e t zts oaat E oi f e ct ehel a i

ani t idpgs M c n n lau ri s mtanmnh nn o g it M a ee aog nd i i C0le e a u g0 c m t

nigsmizio a c n neochichd r t O

C ie eb v e ddohn cienis v

gan5u olydi 40nle r

e p efncc moot eo agmt e we n _

e acr io p ne oe sd r

t c v e a wimdt of t

t eu ,t m ds ylvt eo na

,i ot rh r

os cm t r it ye ac pn sdeBvee ri rhi .iv h gimlcI it s

r ehsOne n T caiy i

e

, Sidle i v f

ni0m u

nb og s

a53e 0g av nr r

ola min e vedt oi esm t i aa -

ea vr ogect c vt iest i

c n cf it uen l

g pnn a e r Onihn t e sinn eosdhe r ivTof s i a r t

is o eins nr Raaao ep t

c r

anct it it e c

f n

e endmt e l e aet nvyc hf o b e

nimhc eeak mcir vy r eer st s -

cmgopneg l

hr l r

eo o n yee rt t i sd ul eu Nviw u en nsie el v/e ns a

s rl r rl u

a t e ur ha gh pa dme o gb s ctaipr6c ois ,

mic nmiee mnr l eogat o nib e ps o e ri c e er pe9t od Cin Ccal o ot oicv hTioPLa vn nl is r mese idan Tgpso1 hr auv9 E

S N

O -

P S s s s s s 4 E e e e e e 3 R Y Y Y Y Y s

s e o t h

n et t g e ide h i v r. c c s it c e n v o

r a n i s

r e

e r y v f

f ea n pm e l lu om e t sr v .

t e e am pfo O f e c nl ebo en i

r ply ur t

a oe oe r p d n

r aa mr ep smr l ud ae pm r gf a gd S vt u pit t o h s n mo an R eti a a gt o af r eep na a

O T

dt s n n t on i isr e n i

t a

t t mns C ai dd emt v . z nd eio A r n iee o se sn i

n ee t t F oe f t ic yem a mv ero aa r r N

t ie nb t

n err e t e sse a r gp oe pp O

o f aag O am r o mev do o -

g c I

i sf - a n t ni ct n T t a l n a g A ah inn d dens a e mn ea vl -

U h ea i ip t s a e m m t v n

aie ts on t

L bl e cn A e e eve a h ei _

r v i t ni t ct lpc V

E ec ale nca a e or a

n da f t f

e n e ma eev st en rf f p a no sm ue uer s M at a he v n sdc o l _

eit sm e d ed mc s e an e e t e at eloo are t

y ad v e vit i

y g it yan s o ri s nu 2 r r go t en a n e r om p nil edso l

E oc lae e p r m _

N f

aa umi c oo cne mCc rf t i i -

O Po Sm Qis t L i Lar T

S _

L L

I 1

1 1

M 1 e

a L

A .t sn e ve s t

N dl u s ne i o s O e s a ec l ncl l

i an n

e e yivn t

I S ae h e aeof i c a t i e c I cr n

iet c ge . eg s h vif ot t

esa sutPen doen b n e

C i u h n h n h n.

k yb t

i l wt t ;i e d E t t i t innt a n eCse .ds v i v

D- m ylaeke e e daie nneni l

eis a e mle pk a c s et r heoml ihErPdm h E ogs o r mn ei t /p cd baeuWEl Ce R oeb t e

t t s in cr u aoiv wn o nsiaeeWiEem s l

zgs e n n P sl og yi no w/noPsC e

c r ae eei nu aan nrt a e er ha galip eCnWi o t s hr rf cssut epaean t l l So nhe r

p s it Cot S

mwysdl a sbr e a i

e bnf coer saesef f

eo nr ho mw o ai z nt o mfoaSi t 0 5

m a

r T t e e s aeivebm l e amyee ri cc eno e d eht r at 3 g o

N t i

cnl t l hr r c oeidibwyeagtca t

t e 0 r E n euiuv ao cair ef vl d C p mqanr eswe r

M cr ne oe wm,t e o el i evae t

M d M eet apetchnnin o u ton ohepav t n

r eorsnop e n a

O C

gd c d se e n gl a napvo n s mer r

mgotahzi

,i easisrig eh he e i h t

t n

n _i x ro c he a r o oinls t i nn ,d t t rb r a

e soAst a e ep ycg f r ,i e l p

oignaiar a wdl psg r e l d mcdmb l r nnida r n a

dion n nsjnrh .

a ooc nr gn mde ew i n

u e eaa n e u a wmsAaltr u m t e a omiet t cr neenleho ontesn s ht vmfoit m in ord Por fr at s c e

.t r o

predere gd r aaus ebol e ih gii ait m sshec t u

c t s

aednnew m rte u piniTe ascha n i

i npn eoho gtstammtrP r s ee e a i

hhgt eiotn r n n sns ge e a t

n

. ghmt a

i sma ndd un9 e

pd ee9 snt e e

m e

u ,awmio ca eoin f i n9 ia Vpwa gdhi c ie v t n a1 2lp o h smppniimrCit et on nei g o a ol eit f g l r hal a eh e i r ee g sioegonnp ay im t t nUc o p

Aatrhfo i s p u ptmionrhiCoM t

Tt hfombWV m l

f s I E

S N n O w o

P n S k s s 5 E n o e e 3 R U N Y Y an s t s

a o _

s r s i t' n d m

tele sv ae lpd

, e r o o h e -

oe l i

at s s t _

f l e w- r in .

dl a n

ht C ee it d d at a sR r ivn e nd eN it c u t

c -

ioo d id ao r e _

t ct o se l f

e es ns gd S ir r oa cer n isv e r s

R ded r c nl o a O gn en es d T nu gi ic e e C o r s nt ona l r v A t i l dy o r

F st e orr nl r p s

eha N

t e na ae np n s m o or t l O dic p n wt o

i s

I vi m et a it p i a

T oh c t A r t e o mh es pg e r a h U p C et gs e k sn ni d c

L mr a o t

n a n e n a sse A id i s a ewno e Ci n V n m E t m mn f

o t t t nea ef z yi s

s Ca k R Nn d C f r

o r

t a l a

ms ai e Re e er n s n n at e p a s Nwn o o 2 gag r A o r gi t ice i l

l a

aeo C in f

in lp t i r R nin E nl c ve igmd e N a u e eat t o d v Mnt h N Sha Sc A O O -

T -

S L . -

L V .

I I V M _

L A s N s e le m ae t r

O r

o yh lt t es uo f or e t

o f

ulih t f o

t m .vh i

f e oo hgiet d hy I

a nf c el S c r gat r gl nor n a e.hne I

c yt C

i d

,f e a uf iwlg r n

( )s e v e i

n eed iaw iwt r olayn E

D i

rl pe t

es o t o on e dr ehul rs i

om hemm r h e agup llo c d s t qaa ca -

E- c t am t s nsd f o a ss euer l ed n

R a f oet x e ea rht o an st r t e y .

eehc r ut itr c r n eu -

P yr s c yy or r it ds n m u ds s r

t r o le ai ef _

o n aFo9 n ei adi l t t li r p ep d e d aisepn sg nn f 1 l poba i

f t r a _

o usy o c r r , i e M s8 . ,

en ee dy g ek -

hm aic p d t ic a S

T f du9 e9 t idhcd t

ei r .

t ar lt r en r

p o o smaidin n p l i bm l

e m N

E t o

n t

es1 oins dawnT pn

,e et a pteic n w

h g eioa i cutqsac lio h in t

e nyi e gl t l. ui obi f o it l

e f l ou M w he/nve aner armf oedig n t _

M m n c2 dtu ni oab gs f

ns i

O s s

e gi e atn ict s wtst e ri ev s l

a t

,i otct ss ie o ed e bleU s e bos h n eiar t i nc _

C o gd 4

s st efod mpo s r r sd as nc s ser ar oio n ancr

,t e u orr t o it no ar u ode en an sPt ;ug a haf sidd oueb nt e eg t

c . es _

y p e to t r f

f dsdc et iannt o and r lusibt be t

a s

n oup neevu c oiate e ee car o ninec it r ul l lacna r

eer _

h w eiss e e isr erru einSm dt r t

r t aisn it ig cf n my e

eau rk c t

so t

t )

na gl i ane r is wts d e ht ne o t aihpAe a7 ninosP oe Sb l

at s ne ivv oV l

acbe ne hs enr r

eie o ug oen t

la ef u

cmTmEo hot. cdp k r o n99 e 1 or odiAt lyt n hc t v h a/6 it tr c o pvl r e aC itor ama lrgt hio t ah a ge m tgeaQal r n nt t 9

e p mr oI r eeur a le , ub o is nblpE u s9 p

sp i eiC s v et ps noe haaidf f r s e imr E Sic p1 _

uu e e i

n u nb5 R ye h p s Ao2N O s gt o Wlot sTh T DnthfoRd S (n t r

ha h Pf f i

i .

E S

N n O w o

P n S s k s s s s s 6 E e n e e e e e 3 R Y U Y Y Y Y Y f f lt s o o u

k k s d c c n e n a a g o r e l l n it r t r

a a ig a o g y y t a z s

in' b b n e

, in r v d d )d ic a o o e e d r e g t

a r

p t

a t

a i

v e

e n sse r

o c r r er t S

i d im t

s t

s t o gd n R n n n n n yd e o o e w da m i .

O e tr a e T c ie e m m r sy C nv e e a ul g ae t d d s dt e a n

A a s s ina F mR r

c a a le m r ir a N oe id d d o po m O fr cn i n e es . b o icrp s e s v vr r t P a o r o i

I

l. f T

A mh a o r rr p a ic pa d e

. r p s. pe e n e v U so y mm c io pn L gf r r

o i e imro n e

t a se o r

A ne sl st r r t e p a ar t

V it P is ab e e nb m E a ho r a e rt n

h t ep h e ep h

d p o lpv i

s Pa n cl co a s , a a Ll e na nt e i e.

h h AP m an an r u

r o is ( e Se h e c mio r t ma ri c d t

la n e m e s

2 t nt r o ar of e u wl n E emf o f fr n i

c ob e co r e eg o no N er n ep r im r ic P

i O rf E' Po Ps S Kp L T

R i

t i

M

L A r yr e s y N e p

l r u t r it e O p ad ee o l a h I

S u e c ef f

u q

t ~

y w I

C ne ah hohe rte f o

b l l

o e a t

E n t t p . s d D eot i nfo ee gh s e' ho E-mt emda n r at l e

pe t

a t t es a u R gue t gb et u te ms e l a taie P atee bmt oac e t nrl an v ui v at r p i xe ec e lait maa m hneund c r n el i d n

vc eak o i her i a

S t nm c n

wgus

,ar cn de h i

vt d t

oeis cr T

N e se c l eio o r y et dn e eaz E eo e mAht a t c pb e zni i t em M Rt b e sd l

p i

l

.de ev g n. ng sp e r .

t r e m t

unn i

M nt a O ioa o r oi r niv om pr o sam i i it h Ptiuit c eo c am C el ed0e wl o t

a n ne it pd 5f rf r n t ne e Al est t i s

eem s dme3fe a

r orr0 y it op e b

l Ra r n gcuCl c s hgn t

nor p c l

a e es s Paepm e t

a hv ai UgcMr n e p y ha t ml hf ,osu scn e eioren r

r aehe in ia E t ekj t

nn u evt g f a P sd eol dnao e n o I inia r mia e ta n zi o cs o i h

snde e bu r

es e 2 t

i l

n ee vl r

vit r s gI,eab a n oiu P '0 n T e mc U

. t onas .

lecd r arl p

mroolege e pv h9he9aSv a noo hR iee ut eC hl h l i T1 cOh Ar TN Wcs oc E

S N

O P

S s s s s 7 E e e e e 3 R Y Y Y Y l.

la m r a r

e v

g o o r

p t

e s a i s

u q y e la S d n a a R d e O e s u

T r e a C d c A i s t F -

n o N o o r

c .

O e e v

d I

T r e A a i t

c m U s e r o .

L

~

e r

f f f r

d e

A u e e s V d e

n p u E c a n n o s a e e r

p h e e b b e e s s e

s e

s a a 2 h h n n A A E e e N i c i c R R O L L P P T

S L

L I

M c

_ L A dr 0 N y-bdlr e y

a m0 a3 ) lo O w s r s gr 5 r t I

din ao- aR en S

I et it et o h

h t o or e gC n

o ho C mtnons u cs dtnpv o n(l a

it e t c c

E ir mei ahnn D f er ae r ndemg onr anis ge eigo .

rf n ,

iss st u eoihe r

d e t isi o t

E- cear oor ork a c e t . r pivt d e d gtc e eur i vdma R spsf pr r pnt a; t P a,edepo ae r et e s dra ni nnit e acg ri cni f hi nradi neave dof nrdo nn t

gs e n n t

it obhiu t t

cs nioeo it co na ca o c a as sri ses aisevcicc grnr0ei el n;m rl eae o e he rf oo n o o p05av at sis t

swmset v imo cc e is citci n0hma se n S a sro nd saf,r e ck e t ar e cr eg ph mu eh e. a 4s mb ct rcI,wrag o r odTl ns mSv a T e gin cpn e .ov i

i T mseic r

or oh r

p gI i os _

t N a apl aer c u snOreper n sf i mh E r ekhtd no A M ga r at o eyn eieeg dhdci i r sh eeePdic r

st el M iTw- . a nh edsbTehEsgu l

e r pmWba oa Cs/ n O

v e ed n ehc g ce as ./ ei e C t

nb l

sue

.l o ieie n t

cfieasEr s L eor ndp t swhi uimhmWddde t

l mpoel o t an s d t l

de sn ev sb se l ,

a s ih t e secmfo na eitdie r oSyn Ca s n

o e sf o use ssl rd acv al i

e ieh 89 v ese cg pd o

r l a io l

sw s e bcf 9 a ea nit i

g vla n nh vno ier h rr ic an c t

o pcl an e a a 1

_ t i c u o pf e ieue ge iy _

sbdi bi s a ss cecPt ve i _

f v

R ee) lsrOeb r i

vdign i

f ena sidapAutbiP t

eVs .

spPa e e t r af ec hoi m v . r eif ias cpo ee cridf f i sCs cC e 3 o 'e IuN na n t l ao pt n

e ebeips e saoE no I

, s r/rE _

r ew,ohe s rl eedr s T f nlo gd s r m e v est edhe vit vn n mse c onh cW I

s el cfo .(eestoev e eu e uet r nief N t sdsnoo e u pi d icn cee ssS oC U n a

i l

eCtyecr sao r sip r

eedcsnnr o rit l

e et gd hs / isr u p n aeed E l P h Rasd TNpaiinm f t

edcao h r nRcse cr n

_ N f Abaahc Tla aCrilniaa 8 3 _

O o _.

T l E _

a S S _

L v N _

L o O I

m P M

e S E s s s R R e e e Y Y r Y. _

f o

s e v

s e

r i r t

o ' t c

e u

s c ly r a a d h r o e e g F t u c d

. m _

n c o de t n .

e r ep es o r o n i l o i i

t S

R r

o ht f ee ic m e a O C e dv f

f ub l

l u T d r

a yd e sor _

a C n s l

r an ep _

v A a a ee df E F d e r

uo _

e a lc be lce N

O i

f i e d s n inc n I

T t

n c n a ha se nr A e a e o u r vm d

U L

i e

m r isa it c

a e cr A s o n r g

he ro f

u r .

et V a ed v e n E pes ep it C k s r pn cv ee o ae r r t

mio r p o es ot c o R Wsa Ca Ct o 9

9

/ I 4

e

L A n r )

kdn N

O sho t o e vt l

e v r e

oe e t

o rb ae te uc ced e I

ea s i de o na gl v yee t

tmdr nh S t teh npndst

,l ol seps I

C E

t vh' i

t cnnAgses t cr e os uai w n t

eitnimec o ie so t en r

s uso a e

ion s h D eee r o rel ui t

n melu epugs edobmdoa l ri tneiho v c an e

c mm.lmee r ckngd e u r

E- o l pmer asoorerh p erl it r p c R y "g pe3a P r e

glpeaihe a

nmt bt,pects ar m

i no ehbri t

i eein f 3.

0. t o htniver t

h aig yet ht ed 3t,eUs t

omto ogmnop ne e l tnboent ndn (a l

vl i

r l

i b

d l ao o e i d yk s nahdon ns ,se et ucs no ca istacds oaelnc i o pW a f o aeihonot t i u no ab t n

prc nt t r geiyst f

f u hiemit f aissd ct r

uuoe n sii sic ssnaten t t nt o?

a i

f i smoo c aet a r i

r onvl e rcl io t i S

i eb a seel elecr T a s p o e pd t e i rdp n coh mogi s o e tykt pt nep e N srdsnt u nt s f sa ope E t a da e neer o ne'ee ar r pewc maimr t aos ae c la

,coh ct n et nt i

M dn M eie ac sm3ams ei t t

zen gt onbeone r

ar l

v ,

sh s c e

iae nl h e m ght o s, r r O es uoUaac rt r vnnge i pcpti oie t v co cr pinn C 'noni m sc l ebo els o f

tetr it uc es s or gni na aqam f l l

pt,r ae igoMr astr t

i dt das hri emr a e or mh cir o i u n s e pl mddms t

ef t

aSf sef ,ncdeb ec a er mra s gr /o i e ne aretn es oe e ,

e amr vsshosns.

s pn dsv i

t enc tineweu coc as e nin wa ee us f

ogar emoiecg2 men r r p n gh de t

es eiosmcm r

r t

r r apaluio sr e n i t

nlosssst gag n Uat nvr c o r

n e osdf,etc v alomia c e i ri ol pf e sp kc s pi l

r o ohn eeu t a c poyv soie edpe l

l s i

sbeerh a s ecwme ber t i a dd trigr eve os 'e ef ar t

e hcehefoe t e f

f ht tehodt n pd rr esl uyeenu hsevt abse sa ns ivt et ev eifnud n n gl l f

o o mdeoo aev t ivt a i eb l

et r t sicr e l a .

c r odr r xf i t ent icisst a rd ocaGuiau i

ct i pep t r r estiis ioce ordnl n pt tee l

l hi cft er soeoa r

i epr r et sowc . on v i Waecaenpa f osf env f huohsemt Tsct i l r o co Ste hdtisbl eeetem i 9

3 E

S N n

- O w P o -

S n E s s k R e e n Y Y U _

s _

e v

a _

n h m _

t i

c o e l e

e c b _

n i

r r

t c a o _

t n

eo c a d m P r _

i ee ivt o r

d S ice f g t n f n -

R f n ce r e a O u sra e r m p t T d g-r ol e t n C en cp n e a

A F

t alo c t hi em l p m s

ouo t y lu s -

N l l t t an l

f . et sn O a sd se I

sr y

• he t i se T ar s di c et cct ar Ad A hacma ief f f-l i

v U t f u us eE L nor ss sn,o Sn A et g it s V

E mso e er cp ai s dm e e do eit 3 gr s m a id n vu au n i r a n ol r o _

E noio Cg t ps N Ro r se mRe ast ue Mre ac O Np Sb I -

T _

S _

L -

L I 1 1

M -

7

L A nn e e N ooy Q O e dtia i l l s 3t h t

r a st

,h I

v edr f

sis euo r osno eenad S a e ysde d sht I

ccUhe r t at tvt uan e e t

C h at gd c gth s tu s i

E s cf e c oign on Be apnr n e D- e a i aia r .

ait c n wn o nsmm ns m r f r s esis~

de E a r ocr t r oosser adlaf R g o

cfiomn

,imeo esf iehr a t i

m e pla cgn P se c i mer s ss pl e ast uao sf ut

,s mi t in nei no r

p r opaoa r ctnc s h i e alavnet a t r

o t s af ec ev f no umtaa r r t

a cop pdi stnmeirdai s

vt emew,e dmee n pp Aa awoo c

i et w s d

i dsaic-ni i_ s oie f yena t l i r u savi v sa e ,

shone s

n elysnrt r r feef r oog reihe oi ct ac o i

S e cala nn dceo nt nt er t c h3er T

c aasirf of SntadsPo eah e wio t r p a ane noheso n

N a meeo rhgs n r

emh t t ir dsUs s

, nt g nei E m r fot at o l edmi cisasgetavs e t t

nemrk M o rdnci enaea t

l uasca nt r oc iotut oa arpreg m it M f r

Nt esidaifaoef i t O e p a m pi t r

n n

+

si t ai n edselemi p e , t f C h seece a i ne stnt oio t i d

a n f t l t

usih t heVa ei B t

nf t l

t e e t

n e ps emtsmic osnaT n tu s g d sn"usA dieh S g

n ereem. c aor s r s se coN i meot e

r e e vf t d

i k c sLms n

i s .am hd a e acf d t

i gof r eay l a

c ae iz c h gl r e gell v el,lan bt r na a pd i ni a r nogob i

sdeO vwrtoaot nmed ai t d mera un ri t

n gri r o o ph p rp e

vos a r tstih ed r ag id t

o cgse Opal ,ce e aer ri esr ehtnina e t et s ce tni ninh r esupr sic n n e at u edatnmgc icfi a

eae v s N pfo ov pe edo ncioir n t ei t m e ei p ne l chr a s" O oteto sd vt s etr r s u) gh icv e ceo t

i n g eer l l c vir ci e

r n ao n ses eey s .NBr Apet i nsdic nt a iue t l r oiap ovf h inc i

t r e oe niudtrhe at c ht Sih l

e atsu niedn el pnla Cb Maiatsdoim s t oNnWdriN B( u oen Sasap l

0 4

E S

N O

P S

E s s s s R e e e e Y Y Y Y te en d e ae t e d r a

ub c e n s lae r - d a hgs ean m t fl v v r o n ea c o ad ee to d s ete i

d h i t

a t v ns an dn r

eisvi z tnro S r o ea ovt co i n ep R oit i

f l e et a mm O

T ic t

na it n

ele v t yf e e ecn f g r

ei gg C o ev dt f ada O an nv mi i

ge n i

A s n . t ae d a rmt n t

F t he a cr nm nlyoe n e mihc N md i

t r ee aere m f eve t

na O

I so t c b g r.

e ae em cip g e go ao T n r nn t n eof an ar lpt A efo aan np d de U

L ms es smam e

ard uisa am MIt nt aic e t

A l e en u tey ssrovtnm e e eh emn V .

s al ama E med vt e sie i r y pm apmt yss r a eg si t

r om 3 aiu rt t oi erpat i pso t

n sr o p cr o E gct o

i r ffets f

ap la uep u rosr ee cv r yf r N so ol e l

LO i

O Pei n Sain Ogac Cfu p T

S L

L I

t i

l M

L A r .

e

%i r

N 3ie

.t sr oe s h

c n

o t

u o ged h O nh r t c nr t

,e I t dp n uo

iet c sg oyu ishs h a ia elt sv

'c es i

S i e p tcic r n t i cirt e vule eid I

C Uarphd ef h r ai3d t ewo ri r f s

e c gi inian t t

e e n et are n eivia t E l h

D- hahdnia iswie d r t gp ni r udr on eer sin etciet ot ,

t dan nvit f f E r t sgai ot nn sa .b n oDla n e gU iapt t y o l

d a,mwdat r nage snm R f i t

sd al su cla i

ev hreoio mn eeo none cgs of iocndt i i P s ehnregn u m so nahtiyt eine r nt ta o t

i i plo a e e uiaiaraiynpm c sl t icehon af s ctc et t l

ri osbaetare e okc on nt f ht oda i

r owe cl isa r l r

f o gokls es ev ecnagn f t xe 3. p m r n i aamr e pd

sspebtaie a

n s r o asen oheui ad oiof v gm od w e h ngk i r e rc 0. o epc taodh nt t

iahgeaydus t i f et , cie t

dr r l

l t

ia nt t so3f af sr a isat s S r eivss l

eie s n lc u gfaolaie esdcpe e r s hr nsnwd eo i3a o n e es A ercg .

prsit crt urhe t

T inr ee nea r s nht i

sulos N oevfepvt oioo t b at ait t t p ocdiwnok i r E g n s mioaicdie nt on het nc l

neesc o M dOfepeeia i

e ef n encoUiceap i

u r vt M e wra ensPich r drt es t t at e epr cr nevnm ei hoecf t

, p g ort etsgn virbe r el O nle o ie sn rsos hun r u etkmhc s e oe ndhaio C ecb r n 8 )c s 9it aiwef l itnnnt jio eg t hdt n om dcioaud it aNerolet yniem mnde nc nai eo u rdl 9acmdedt v o redn e nu t

ndawb b t i r 1

mini t l oc oehf o gtr anfopas yohe ug t

sa at ,opeeq rdnu asn de n

a o ,e l uu c h hac 4 e t

Jatet s n o t.u.w i

s icsiecdcme adr ueae t

r a diuoibdsr matagsnt so ena in1 o i l

t )+ mlaiwn. e af nt t n(

he adf plve i pd s n t mor c roarSshea a i

i a nis t tr dn aniur n oonn s dn t

msho cne i

i vu ie eh dccrf nl nTnl i o t

s ass aoic eit a no a yino t

eat j s ec o aecc i

it elar ien oyar r eik t tnle neklet l st ihf e sdtsynthea . r utnit ou psr eear o e wsr or sn e r t elM ho l pe 3n eut icwg onew m seo n evmg n r v ndi e i ota bl e r pi y s it nma a le d en"epcog f e a g yt g

rf i odei age t r ot s ah U 3ornrhodi n a ,oitr u ur aoi zgct t cel ei g ap cp cinniinn ee/welbr aa por o sr nm esihakhw e(i nmr sea l l

csiw t

cieh s idoia ne ssle n inp d t iae Mtefopr i ewmc Theaomt o hat dh pgacr e o St rapSbr ar e m

1 4

E S

N O

P S

E s s R e e 'o Y Y N

~

s s r

ni et n in t otan i

da srr t

nn ctho e it na ei o i r ca dhiiz ow c i mtu~ r a ge an t

el e v os nkg gh t S t eloe avr or r oo r n es o

R r n t

sw e l

O T

oim pd e s yh e t e o ne ss n .

et et l t nio C r nlb df n p A o tar o c iai v mea nkt n

F ehp vgid oss r r le o met e N i pav C ewt g gl a O

t c rsn mlee I

T eevs' a a cl l

t s

c a

nin na A

U f

f eon t e n ula t m av mhg aio st o t n aa s L

A a nit hea esdr s Csr e V e me r me oo e s Ra d s Nt e d

e sgo ep etst n s 3_ nat gor s A r ola a E enn af n dd e C in pe r N

O caa Lmlp i a an Mhu R

N Sthn e ec i

T S

L .

L I V I

.M

L A s r 0 N

l ia o 0 o s r, f

5 - t n

O n o

aeoe t

. 3t i ly 0

4 rmini dgo I

S hdt r t d9 ai s I

C it a s oc;9 it lsl n sn) Comice t t

E D-izl n eur v

it s nenpe1 osd ed9Um f e i oP iV dpeo t

Mfdr alaet e r pl sp n

e gis e ea y stot i d dan urf sim v rpis hr e a

gl e s. o r o

misn snAICawfedmCc E r n M e R t P onnt e

r eonmwi t

i ea nc i sm5o

(

0oenteRw 0l sa l

dn eriNo en i

e mieaio det t

ic C e git n

ooi n an dima0 f

r e g e g4 a m pteie f l t

n gsf iwa f e nn s ri sioCetes t t r n

nistnuhleeis at lat t mh e 6oP n rMi hf i iLua l

o3 o

o it muleeh l

i s af sho clao n oeic a mt gf 8i c

t oi niWo8n f

c 9ini w9tcon r

t S ts o e t nC ieptaesivy .

e1 AnU T

N r rl o bwtet ei lrWlcn .o ic o

aie gh t

ar s cpwel yt e uuniser f ur Jnoa on E

j f et l si ir t i ct amhlePir m u c pC ngd o a oe eive t nais M

M a i

t nhm/sEied rdane nlc afi gM e caVurnedimi vl t r ut r r f

nl l i

O gewoEaed n e oepoh f dei t tit ont i s ns g i C i t

nh nt t , cwtngo t h vi dusc s c oe ot n el c6 Aa pet rCs n

e inat it yS s e p oin1 ell snn emooM noeCeir k ,t mozof eiin o pdeh b r e v s 2venoam nigt ic wiilpo en t v

t n ih lpc u as al e l sTirnesmc ee d shi,es t m d r gi,r eiui l wiw n l

s sr a,ea st ph n ni e e.iopC 3tyi tnoa ei r t ieona nr n t ns pi v eaeoon i

ct et r olemt t it nr e,ot c _

baisct aCio en r ponne hhi t icht nz .c t

0 p

mceUaioomina

,dr scpaag f

t r i

sfaiTniinPa hn g .

ee mdgaCde 0supen 5o 3c eefeoees snol a a n mi f r n e snogmoEn eis e ar C i,s set oieige vim r n t

saia ePn a Mtrideit l t cl t nic .

eths n it aneinrWl esc p et a )LInpa mer r r ep9il m9id n _

icio wpmbt So h f hsI eS e cocc1 opoo9an l Tr(h t t a r 2 4

E -

S N _

O .

P .

S .

E s R e Y

t y _

r gp e no r isp n

es cg S in l i R dd O nn af i T nd C on A ia t

c F

N e e do peo t O sl t nps r IT ime Cod A

U Rcn L Ner u r A t n ao V asd E icee 3 f it v E nvo ii l gt s i

N ic e O Sar T

S L

L I

M

L A r e N ,o t t o e s m O st r g na hsR l a o e r e a

ei n mpe I t S rRE i f s t r

n o t .

I aec EEL f

n8 n

e e9 C yd n eosll ,n vLf aeo s9 E 3et v t

o n ods t un r pe1 D- r r nr otoc u ea r 'e rsma 3eeeb t o orpy v r la pd et dv eem it e g i ca %~ d n el u E

R o oPmt t iapnenr e r oo st r n gf o t

nr r ae diSmwJ Uu oe vn oh nvlo) a iar P r atntnegacoe o l eei n fe rere csin ar nd edn lil p rf o e a ntm a e (T r vti nhruf re ,Ta f

dt he f

or owh n omt ser ar t

oicimeahn w t

e e gl ls ehibic i

n ene t o

r n e

udf ht

, r ef i v niene t

et t t

s s or ns noknhsg g

soa bs e eaier l

t r ct r t

l i

Mat r

isirhmlu e

n pt e usouie minr3 f

S t sye,dpe eri arloaa gfouatr tn hi l

o n e net rdoc emr cut ci n ee ra e sedpeeU t

T n cr cia bm nthith a yl s cde N

E dte a nciye cidioint ir p , ebm sao r dit ndinal ose asiet i ,i cle cf n i n ut o ao nh enidsdimuam er t l M he ahlyd M p e r ql eleie t bivh nheWnduh r t eint eret O seAa uc eb ot n at ocdar o n .h eh pe oiait a e e rifoh t ir C s al s3 ht rl cs t .

icr rt teet ar i t t r as vgsf cal ahp n

emonhstn ai e loo,aanf a t d ed eu"s d r t n r i v eg ei hec se e o gU i owiv ncd Vl ytn yis onwk sef i bf ero ,tc eio a r i eui seef aps r

euptr af o I

l l eie a se wec odi st essn t

,l t

h e nwncd ee eou ng s l a t vmript t

a pE e m seRn odi ied se s ciart s oin sivmgsf l eSe r s aresLmSt pciden e s e n l er o notapit t y

r8.d n r am c

o edRol ce f oki n e m s.

t r

i e9eeiCei v9uhsRsqc u ue ee .l rl b

rihere ccoptea st ehaNirseneo pl scpb aai t e e1 ahr a ot ar a sf o isr l

Palrbat i n er" f yyit l p e e vsol Leama Avt Sesr seo s sisdy

,vt pent ec nowne elm t nf l r e ont s onuioaoutomevi r p r,l acr rdrr merb el oahwdi y et l c e o o lnsasomregnwt t t ulaovu

- fr hetur e e er vuoe enrur T b pP o b c d r cp Olah t isivapr nhh e oois 3

. 4 E

S N

O P

S E s s R e e Y Y

. e sh g t sim n aar t o n rf a d d S

ePs vLl u t

e t

R oAs r a O pS er ic T s d nrowe n n C

A i o imt s e c i

s a esv

,i F

t a a r hr r e h N e et c sa toR y O d r s amdne n o c o i

I T

i c t A n meina is d .

U o h n L C f ot rh em c r t e nr A l a r n einf o et V n mgn 3

E i o llpd emP are ei cv t at r cot r r o E

i d elef r n or vf eel a f p N d n O A OrPP Ei m T

S L

L .

I V

M O

- L A r n t el e.d nve e

s eio w h N b ytndt f ly ,

e i h c d O el m n,c a eic r l

simwhet e v e te v n ais ia dh e

I S

I uwnr n oiee v vu s n epr odei r ecf om ieost tr nr r f r sal m ,n a et t e

nrs t

o eorde c f

d e

C ad no etedcle y)s u goh t eo l nh mtaavobap enr E r r c e t D-

,t desdgat shc u ege noicd f

nAopuadye eo vrl aoo t

.s r m ur r at gmda a sn eh al f e o ceu t

o pd h n ueh E e cr a ;s toe r t e v t

, ckind it ar . m gi e lymeab l

- R a aeha niall r snbsaie ge i

c oenr r ri ak t

pe n t it ero i r doesinfi cet ti s P yd o i u en t el r e n ciea sapro oiaipp f r l er cbr t hedew outhbo t

cppsodhd xr f s er a g l

l aspai ne an eto a gb r t uiniw a g pow m e,t ccr sp) ntr din nnf ut oeoqnroeee ,iv i

mon r n t r n st r n a oo eer naeo t ac ef f e i cl e siodcvret r r ,

oe e eil epancebok a r ei r laetaisdr c

ipr r i a ct ar sam nt se cet rn ae wwn al e r vbo noe cveeiel o yf oepicl f i r e

a ag chnimon t

eo pbaa vedenacnmiouonminoe hn .

nhapl n n ot ol oHam S

so r

- t miv ce aoailvy pd o eiet,u n s uno - ycas r r r r el , .he T

N t

sd hniene t t c dt ht t t s da soia t aaednt u ss t g sa E

o e) eis pi h l a e mt scco s ,t nd t ve ant hecla (n a rm supe l

o o nsn nnio rel e ee e nf of ofi r nt e e micr potrcielea a e y, re r r (b tioonpe i

M a v ym M i t

s s nhe uuddr edcticie ut i

,t e sl a osur edamge r nf i eo s n t l er t r el O tn a eTvdt eda net n coder b o ph taepe pl en o t n wr is s i t epnc C i ec ,t a obai mg,38vot ras r

olyh o s i e a piut il i t e .

. tar a o civr r pf f nh aia c u o qis y t ait et f r

. 0.9 r t nlt so. r dt t c e ca s,e al a ee xb et eynr caion g u i

e (e 39e s saumf cs hir ndvepsvht e v f ue ,

t r esS - n elpse o 1 v

f e a eiuro tc s et nne d nt e i n s ou esnt r ne or r pif gi r p gT id cto ati oslebe sdmt t rdnaas s,er npn r

oeie ni ps s i e l e u gt r soa mnem his iev c cpn or es pno of s sur a s r hel i t ge ict dhdonhs i

ee s

ol lf t it i nin u u i

r e rl pyeAedt t

r r os mfoed t es pd l at e s u o mh ni rt r t a ,i wic slac arl ,

et it n hst l,efo enl o cpal el bor r i on . pnaepor obrema lasuiddlbgn r rdt t

it latir s esa t

it e t

c o 'tssk esr perbag ciieor pmxn dpe u odadn he spu ar oinur8 pnr ewnntsah r eo ee a e e r vjeuf g t r n neu eie e et Ti t pl d9 9 i

f e oo dciu cit rt obdo a n eio nisb or cr o a r .nia rd1 xta c 3el a m ph i t nt setr ue-ereennneait dt r s,ow h as t ebudsahi ei sm,dseTl w t

cd hy t r

posiniedrdt d ci n

a p rr U pr o reopt r re e l desy nr c .en eioint t t io v e em o oug l

aehnl t o oe ut r toftc enhl ais cd n dir f f ih dmie l

n ccr aor e sf ues u nff t d OnoiasAiurehu AofoheCaefuu f

n sc Wcdabrer oece t pctoh t r j l 4

4 E

S N n O w P o S n E k n

s s R e e U Y Y d d t

e t e

a r a r

t t t s

n s

ns o

o n

m. oror e es mr ee r

a S dm dr s R se so m O alb at a e T do de r l b

C er vp ep v o r

A ol oo p F r a rt N

pn pn e c

O it mio ima ic n I

sa sf e r

T ae an i

e A hp hg h U e o e is d L cf cf a A no no e V ak ak r u

E mc r a mc r a dt n 3

E ol fr a ol fr a e de c

oi N ey ey r v O Pb Pb Pe T

S L

L I

M

L

_ A d N e ee sc e _e

_ vt O u t v

a gha n t

a a e de 5s.stloi I r d v se S o n 8incre y stode s yh e n vnr e

t l I

C al r aa ads t ndt c osisee t e E e p m "n g 9 roc 1jf au n gl a s t

a ineele ow ese uiided i u mtap s exceau nbs

( r t D- n r ,

.aq ps s atoon E oou r n i m gd e ir e t seim r vio t

n 0i t i R dnebr a de ase(

seyc i

t ea sted a fooic r

5 3mrt ehqsnc e p ee P sat noe

- nrbe pumn e e f

enee yuge ps n Oouh Cf rdt a d ihr va ar et m hc eb cwds ssee e r nb Mrtaoea ceinwiohs ssemivb csr e h t elaa l pinr u eanu s - , rl vt he et r t onn oi -

3msedeae ier ehvv t

on ce cv a hes l o d lan dri tac t

r e npt Uonb dt l t da emnh r dleOih s f o3niet osu be ap .ontu r

aitot tr ii t o sr

,c n uo eo csp et r S drl i

t a psm8eb eda e nz ne i T dt o ao9l .

s uim ant pU r a aper e3 a nd st,e e n N a , . m )L w c 9 o nf e a n sg e ce o ei st nlpsy eP s nVt ans cg gro an pobost y- mt r

E h n

,1 M

I nr cEmtnMeni I se i

l nri es eesro r,Ue ds i

.ko= ekiov aecbu socetSec hat n M l r

sems m no

,t O rolic ct n mtaMri l a ec eh ocoW_o(

nhl el sr t

,e e edo c of vael,vt C b atoe v

asser set j ss sch ni nt f

onma gl e o n i sd s s a y, d,bgwl a

_ r edee mrhsiet i sy n u gi t a ,l e ai nor He a apT s n m n b t t peiu nr n f. aa sre ntcdt i

v ostud t d a u e se ed in e.ae nr au wseure teois bur .

O s u oe o

n ae nhar nwdecit at p a ce but g

ec n o cmp oqontr n qc se c soin iyr c r rl o l l not oenr et i

v noe er t nop r ne ot aer r vo r

e sne a a ebdAcale u uun t

ca l

aind uu t

t smLcinogac i r t

h h eeet t r co s .

qsSa es sbpe eiv l

mros es m pI eiSeri)d t

awRmv l

e di .dn r ur psCf ue aLnieotomp i ei pt s n t

sst v ,e l bqo i

n a n) I i

wi idce f t o e 7 n. ter laSo i

n eiod l e ndn 3t sr t b

t ind oef r iRpt e k9or e r u gd n u e e n gi,o pa deNia s s a9i sot i l n ee pc t t t p diudo nt o a Unia t i grdserf e i s/t 1 ar op edh i cf nt u od idn nte unhedr p6 s p u i

einw d cusnt n e pnq n e e haoe iacg l

et cyao d t

e99epe ol c) su P i (b pb r f aa e eod r

Tt cn AMilnibwma S1 r t huh t st n+el 5 4

E S

N O

P S

E s s s s R e e e e Y. Y Y Y

)

i c

r e

n ely t n

ge ya t e ri m d t r sp e e r

g

'S dr uo a d e

R np n is O

i p a n r a o m o T n c C

A l

. i fie ce i t

s e

r F a cb d a e

pev e s N m v o e O t s a r I a t r

p u T r e nh dl l.

as m e ar A p pm cro e l i U o s v L s , e ano po A i r

. l

e. oe bd h: ita V

o i

( r e z ete E t a n pss ea s

nqu 3 ci l

u wge n e n cga r

E e c e N m ood n gd i ir id O S Kaa Lo La T

S L

L I -

M _

L A n t n

N edo sdn e l a m l

i a - f a h

O vebie ddt a o T n ar t e y8 8 It o lp ogm i i I

S t

cdnvst i d t r .t ec cnt h s er

_ i

_ I eaot p i et o 3uda nood C r ccis nhar e 3sa ut oh1 at r eiot r s bn t

e pbe l

r e r nn n oi a nn i

E a r v dhn dt n e o e D ct ut opao ede ntoqtat l

t i , o h ph e r awiL

,e ec Uct e nide l

E-R hnv t

aemaher ecn ntl s recmpesur aa urt u c eo u 2,ihi vt e r

nhain eis ca no n

P n l mes e e o ftu af r t 1 e r on e

t ot me sn s

grdkr i

oa ce . s pi ne vf t

l ,t ogasn s .gsi m e,s fssg r

l ee pt ph l

sCsG e

vRe l i l

M i

n, n l ti o wp r

o e t

o c a (e y i t o eiann eNao rf t oloart A a nla i

arfi- l L e pt at ar oe sn na s nhmn t

spif nlet s i

enR .

aegs nat nir ee sv ee v r s iTot e nneogkpePf t t r et a f

dthi e c 3 yt e ae d i cn eee S

T e

r o Sdv .ne ut e at uaiUaf e s a. i a cr s n e ). e e e

t l

nnfe pi s t i

mmwde ue semst e sn nte i hv i smt gh t

v clp12 n en a N t s n t n at o er el E at mninctm s,a ctct e e opi nc e beks dmec oicp M e r ofea t

i or suhusf s uv se ct ae '

i hl if Le M emeiioroeaTyr t

nr e t f

pe Alet n n .h v eva O a vouid g cict .i l o e nlal e a m Ruhio ,it PRi w8aro t s t o t emt EP i rf l C ho ea l s r gvf seuio9m zf l

tvt 8afeb a bei t

ge 9z f e t

ep ae oisa sco9ier mI i i

l r 1 r sn t

nce9rf l sms yi umi y u ec"s hef t

t es aibu3 o d npsno hosi t

f i

v ial l

nn1 oeb i

nthws i

l ah l t nniue s dealaa ucut c yl ee l

nt oet f scmEnEn "a eis e t daie vc abu n o vresobahal f i

,d e pop U_e I i diet eaiuh n eec r a ehn st it wmaol aesl, e d laot b l t l 3a r eh r emit t

vt i t dy uinvimhf a w oe o )s c ioiv e ndal l art eh t

i nd ehtt t dncn i

t sdni nad l

Uitsaha i

c s,cr t c ent eiararheOp oe c vt e anht siaia e a nd o e gless e r too esfon et ht de r pt v n ot d csnunn er r cev n i o n e c e. he ri t o gea cdn s undoo i

erocegeugcovect i

t n n et pa e p e s. in 3. e "t a b ed s nien Eelahc as i

n i ojn r es F be p s ur gt e t l l

s ni t ss 0. d n m tsur e Mdmg i i r r c n oe oe3ie vr r n srt ua lur ecter a e

I esr kkfini r ner v eip ct cx pssSoruf e aTpcieirien r n

v s T (ida2 oeact i hnev0 haoo i

ove iLaer Thwwces 6 4

E S

N O

P S

E s s s R e e e Y Y Y i

s s

y a

l n

a e

s u

S a c

R t o

O o T r C e d A w e F t c m r

N f e o d O

I f

e f

r e e s

T n p u A a n n U s e e L a e e A h b b V e .

s s E em sa h a h a

3 nr E eg~' A A N ir co R R O Lp P P T

S L

L I

M

L l e d n A lewnc l

e ) an I g .

N d I Fe e ri -

I P nme O e u Dv a i t

I S e ale sl o lcl y

( ecn e d g e v n,ol op bo r _

in xin inlu n s ah no n t

I n sc n C

E t

uoE dla sf ao f

itodmTat er .e n erFeadn nmVnri r rpr i) is eie t _

D- ot i

couepws r abo n v eeo oikbf Dh wdoo E

r T, eFs et s mri f r c eisa o

r spu en t nt vp(

r eeSrpaIndsedai it f _

Esnis lseo p r R sivi c e _

f l nsi P ndeoh vs e adonmh .oa t

Sinadnr l r I o moerbsateehniosscb Pneap a cue t r AmaAer ahs e r r p Se e e rht Fra gmn pd m ve uAi e ca oiey r ch a S I .ep doia o a sSide f e nt d e etssmAn t r T nr c sI e emio-o N n a pt o nwsehhieVopuie- ct i

t E h t ivn e o .

s o nfedy -

yat e c csi mnnionct vlae eda a l

n M biml it se ame i .

eoet nongn ee a o M dnshibn sl s Dik t cai fcst i a n ethcmd a i

t O ieiet Eo e he eat nnimlar icmioridsan ect it n _

ot n es t

c C f a l

s yF r c eeme o n n asb P pi it t r A . v ee aaf r r r au s r e _

eifod eeePdeF l

E oiedgeehFndmbd t

r e e t .

l e d gl ie ephih ye cbi emrovpc e deda c agv s v

e nr s oTi nde f t t

l prr ve pS esin a legnioo au L edele e nh eoalbn r

ch et p rhss roidndnhe o

. i l

enee9i bas v8 datg 'es st t apc te elug cciTcdeh c a e se ,nd9eFiEn e i h ainin s n n gi n v ncs1 h s gt f e .eanh l

s aw t f nisn a o eell i nl vdad e Doe l

o hiol i a yt Pne sc m wr s em emeai cyeimicmh cx erc sse i

t t g ash ic eir vet ri f e ee o) rEr uet r e t l eeEl bjco enicat aer autsn ntspr l

N R u sspf Fbdhp l

r e eysoroao sn (Fawi iia sPedi t

m h oier ol Tcit nh cceiSiFpmp d n r O

I m T o r

A f T s E S t S -

R n N _

a O _

E l P P _

W S s s f E O o R Y e

Y e

P l a

N v -

O o T m N e I

L R n C r d o

o f

e s

it c _

s a s

r e e _

s o s i v

t t a c c ly e r

a d h r F S e g o c

n R t

c u o d o O e r

r o e -

i t T r in a C o h t f e

u A C e dd l

a F d r

a ly ep _

N n v al o s r O a a E I d e eev T e r a lc e _

A i f dd _

U i t e c n n -

L n n ae -

A e a ee V d I

m vb .

E e r iss -

s f o na eh u r e h a p ema C k r

pr _

t mg o a -

o e o or _

R W Cp -

9 9

/ .

4 1

le d e

r a i

h t n eegy e e r r ey o v a dW gwe r adh et nl oiI cf t

wsit st c n ie ele lpeel b l d e se sr ese L

A ianlo f

wvi t nce r ud .sene essr re lp a 'e ai ct t t nh p e 'e l ic aot es ea nn t

N n rl eiv el ac os pe ot n cronoic sn de aov irtah e p rc s gd n o si ieo l

O st e f

ae f

n einw ic t epeici t i f I

S in et ygr e e e n i

v su umi sa sct se s f dh tpccf i ee s ulie en eoe s st imli t ro I

nisnps r dct ,

e sgs pd g C eie r ,a ee tosiu t t E a de n oh i D- m/v d gi it

,esb y cnot n drEcssam eeFi h o n ewfe f

mdlat anpeg u t n ne I it r E en t cla aio t n t

ahPdn re c een t

t r go e t n . so x

R P

S T

si eat sef ee r

usr ev eqne f ct mIe wdh loar t e o chumeaidim r st qe s pnt e o N r n i pa h e .

or m r ecloet _

lat n n r gbt l Pofoe noadnch i E di d gl t o ohlyor a nasl dt ovr i t t M anaeFeT e e n ep ot it c s ao s ep M n y erers .h E el oio bcl a n o s mm l i c e r edc ap el ar o O o levh evei enednS t

eton dvie aI,bssie l

l sorFwule ve ent eDmn s C it lo u it t

cn gda ruma r

s nd a v

hsrbn nae e r e u s n visiea it t cn ss enh d

eds gtr oot m s

e fein lyes c e e noc nS cA st ial l oh t si t ee r no t

,ot n e r

f ol abo eieiniat nwl e i n r cicl o ed r as upa onc t r r d

n si csi itsoI cr,edCl r e l

noac c geisnsdo t

a e adece u vh ef iw,o . yn r mrioed e a h ncc i

ph ncct h o et t o t l dt d r es oni r nisr a t n eeeceay t swtntaynot e e n a u 'e ae r acr at i

o et i b r oesl it ei las em mdegs a s dm t

it a

c nssnimc, emnafeme d .

de t

n Hmrbpsmoe sie a i t f r

hdsoAe ge np .idsm r ae v

f e

c cnr ceg ers a i

t .l ni r i e t f

it iecfecdafi l l i

ri v icr pi v h ome t uf i ot ioaedr t

n e e bl i i oegv o es negno l t l iu siar f

f t amtnmt ai t

nmp h nl eet i t r sr oedr edo d

i hrhi Tpt sl rder e pi SeolptehCcb rt t l

oe lt Aitdhar cnap c e E

S N n n O w w P o o S n n 8 E s k k 4 e n n R Y U U t

n y e r r

v a e

r c p

o s o t i

t s

s e m e

r c

r a r

u u . g s os o a sm e

r r a e p r n S m R t t g n o o O n ier it c

T e icp a C ic f f n e N A i

f f

u uo st i

i v

O F s c t c

da e I

T N e te e r .

A O d .

av rd T I us ci o e S T lcm loc t

ct A ne t n R U isb l

lare r ae E L n or so hm t

W A op ac dle V i t h e iep O E cf t g f m

P ao n e n si mra it ee aly ivnc N - st n O eg T

t cerer gn se N r r u ao nl i

Ciic _

o ce I f L at u Rf u C Cr Mo Ns _

g r 6

9 m9 n t n n n as t a -

9 19 s a1 e e o i

gi nn e l

u 9 f o si nh te h e e r 9 f o sot sbabs v em ct it .

edmeht eic nrc 1

L f t si e eh oestoara me sst a r A r o e e ss sugpt t

e i . r gv N be r s a ovn nt e d )s foioa t cMtokahmyseie a st sn vet s fores ecie an n -

O mt r e orpi o wa on cast edakstcaet rr ds yht ic a I

S ea dsic ee t spmia de datoit f f

I t

p u el t

tn a fectn revv9 a e r o m acro nenigin C eq c a n R ei9t c 9 w y e s r 'e senwl rf e g E Sd e sf niet t r eR r

aNh edsi D- e n mhaeio e1 sat rcoso b f o is nef s cn oe nr nnnie 8,smaa echta n t E c e eh eifnio gd it it ocyc r

e ,t sst re icaTp t

i e n s, i r o sd R S lpet inc o n en el e e lyuaet ded s i

ss mse s c es c a a ce deahc eo AC 'surapi it sntwev P T int r ori .

nse n u N ne hisc it i e a qlyna ciabnec re ea t

E wh t ni cui2vRrEdsiut uest eet -

al la w dtcNeR ar t

ol i b det osnsdvs M

desr or nb een di t r d evdn e t n heea e r e FA ndceyoio shciainci M

t n uu t li f O h eToa1 p

t rhmCI a nmicct r i i

t n a r r ef l, , oiet n f C sde o .t cl oToerhdtoI osfed er ee er e ec i

l e s s oeC it t oide dt ea voe r s et c se sv )

eEdt

.f t et

.l a pf Ctnr ss oeicm n men evbwde e nr inip a(h e anReet g ew go m u sao l

dacr o s yd A t Rt h e n aic c t mNcivc ee senra e a n oe n mtn si adpnieCudeef sf nmet i

l t nnH ais er ,

r n au ea hn aioam(deln l

d ph eddr e e erd aI t

r i t ur s t vos a v so an t

eedcqes ecea o umos cl ci wi sift r a m.eiu eent s lvaco ew hs t

e snt neto s n n n yd d i T fehceepw na ev t a t un asat e o o h a t i vi eooee e ve .fe sm l

it i pis m e is trH r

i nr t em miesssic icr t t cvt

,i is s t

sa ua c r rd o y y aclysc t er e.

efoee lpr e vc etce9cmene eer l

t t r g r t l he es r r

ofe p9 e b s e sh t do peeiar u pfamdno s T pi c a pE ni s9f hemodrf uselo 1 esabcoap f

f dr TR Asin acis t i E

S N

O P

S s 9

E 4 R

o o e N N Y d

t e r n t u e e i t n e s n b i n tea s e ne iam r

a t ply h m ae oe e e lub pm r

c l b ae v

e va n pi t S a o r aa R

O m

r P d h ns ton i T o d an dd C

f r n r o iee e a oi t f t N A p t ic t ic t

ne O F t n na err I

T N n a

e oe do A O l p m s mvi t i

g c _

T S

I T lu s e

t hea cr ndn _

A f s s r.

t r iea R U s s e so bl E L e A d t c n e e v W A c f- v i

eo f r ae _

V c . l ms l _

O E ud se eE st en P ,t S n es ue _

dr a d o le n e sm _

N e me is e i

et s t O in n v u ai v y g T ao or o l

rt t a N t sm o s gc en I

L ue e o rf e f

aa C Sd I m R Pe f

Sm 1

1

f n

e g o sls e l

s l s

o e egsiio a nns A h neb r ek .

lc e t hnst ha e h

t ov on era t

L oiv vu t

dsi et cu c i t ie t

all nya owio t A t t r t f :e w f te ec N ac e grde , s e sdn n e

i f t l cast z ei hc oKd e

_ O I

S oar r leqc uo s a p h ,

ddamsem lednlenc e t evev arl po x

eee t

af a ha sg n

I ve ut w a i piona v o r oo ce ao r r C ede op ooemtcmr oiv nn dns E l ah t r gd e nt kdad dia r p pei r te anle e D- is yf hl o t cemn n om f

oSy c eer amech cr cut E

l hn at t a er i iolinf Ta s urehe a os gi i n k er nf R S ms is g smet ape lahv P T dien r n a e nt h icTs .

N iein fi me eid vi hmb e o s ema s sstefur p yedoni n i

mpt gl e ml ri,n ve E

M i v o vo c c a ph r t asit at a o aelt l l ashlot c oesl nvi e nddt i

ndt yr e M ee c dr e t

e pc l

p i ds v ea en eens t t siwina l

O i ef f faian n nns emo me vh lph at ae hz t

aa o na t C ede s em iaerdet ht i Hil d re isnhe msg e g s, lpde a et t mn dvr nt or amrha o t

odha a uo t n nmd i

wot a cf e net s a erg s. fso s cg wio e effep e eP ha ot e o mst s t t t t msn saaie uer l

ai ce t

n b o .gmd n ec oo oi t

t ndr ce dl lsitv n f er sut d enocd le b

o wm.e m a r no mpeondn ura a ena h n

r eac maf un r s s c a es eeshl e ras a el o f

su ngr uet g au ylys t

pe o o sbn s e gcst Pt s anis se w w ost a i y adt t i nen crp alym nade .ecis euE dn e v Pen ce-d nie viea nt amisFiei ai r l

evF l

yas t h ri r t n t i r s a ee mrfoisPwit s rdo iui mdast u ecDo oos n visc l t t ef ni ica -

u ns eianh i i cf et he r insey ef r et hc es T pieee ef ei itn r a hr t

a Qga tdhhisdi t liePd l r Tfon ice ot E

S N

O P

- S s s s s 0

_ E 5 R e e e e

_ Y Y Y Y s

- o h t

sle r

et ide t

h g ev t e c g is sl v n r

o i s e ol l

_ r a r y v f a pm e l lu e om dt na sr v f t e pfo O c nl ebo ad ur oe d e r n mr no oo r p n aa ep smr t

it gf a gd crs t o h n mo an ee ird S gt s o af r eep na a s dn R is n i

gu O r e t

a z

t t mn ns T emt v .

i n

nd ee eio oi C o se sn a mv t t aa r t t a N A F yem g ero r r oe sh eaagse s st t

O r gp pp ec I

T N f O am ni r

o o idih A O sfa n t a g ct n vt T I de l

n mn ea o e S T A ns a e i vlp rk pr R U ae m m e

t v ne it cn o .

E L e v'e g lai ei m a wn o pch ci t W A V

nca a e or t

a n da f t f

e ne etyi a t O E rf f p a no sm t

t f ez P suer o M at a he v n .

nai n es a N sdc anad e d e ted et mr g O e v at eloo e vi e ar y n s ri s t gleo nil nu T it l y n o om ace N lae a e e c

r p p r m eds o nuh U

Cc o o ant C

umi Qis t t

L Im i i cne Lar Mai n _

l l

I

t oy h n t c t b nl hs au e n n lp a e r .

e a t h o eo u E ht nth a o is f

L t g ds em d t en i

t n es l o d e F A uige ba n t

r c P N

f or er r e c e t ale n s int t eeoio r a ogts O e uhn icb it nna vv aadc9et t .

t s r pifni I

S cc t aa dor ynoiad i hh ee9r n geo n npnotcme I

C a er rerm i ac s t r sl v p9 t e ae os1 nc nb n lt r me a e r a se E ma r pnfco ua ,h m sr e t it s n siei 8 spf

,l aer iu rieo n

iat D- o mae r swdTr eivr a f

e omp r ede e ensc rt ys2e o t

nst n E

R S pcr oa r r t n ar d gd s

.t ri t cl r ehh s na eirf nct s oe cu e P T ll of s ohtae s ndt a n pd a o e . t csesm N deainoa l t rna pooaMeenm l

t r a

rde a it c er ei l E ir e ep M

enpt vess e ev pl e mdor n s a rt o c pR n gi cve lesm f

M ot u s obrea nw dp es f

gageeol aratcn r ei O e risoc e i n seos r aios e s nnevf c sh e rte h e vn rt e e didnioboe f a o s C t k e e f

o y yi e tci er nt t i c t a s. n gr rl le d cn a c eof ar ae r n ms eeieden n ice e t

n o ple nt a nj i r i ic iwi s rc eaeih ahet v smipsiei dcl st ext mu r ct f ni c n t

wor engm st a nn h enh enf e sqsf sea ieon e f iot ieeig osdn otene sat cicu a ptoom sl se edwdnlad sat iicopc t

c aMteAr t x e lor s nf er a dh o

nn,ed g s e nt t et i g e o yhn ,et cr n a a ela aah a .lpd r

.i m t eoina espmt n isnd e mos o pla Te r nd l

.m t

ht ad a m oge wa,imnam z r h n t e emedm n aa nteot e nde fr iss ees nn eafostn t

lecham i

l t r e h e a o pE g i

t gl r

l el csioev icpneitr t no medidn t p i

vi r pd e edd r

t gr ea f

r e Oopthl p Whh t t r

mFo pi P p r l l

oencda m A c b u a A pi l h nd Taa E

S N n O w P o S n 1 E k 5 R

o n o N U N l

t nl d la aan e r o r

e lpo a o t

v o

eig s s ht er iee r t c

s t

id le rd ee ivn tc u f

e r

ds a o r s

ias r nre g d o oc in e t a

S cn i sv c R r nl o i O

et n ga ice se d n

T nr l r

I e

C ora dy' c N A e low r lr n O F t e nt ae np s a t a n N o or m I l T p nh o r A O m et it p c

i t o e .

T S

I T o mse es a r

f r

e c A C e gss pg sn e Pa n R U t n ae ni d f E L e nn id i s om Cifn r

W A ak n t o

V m mae R d o ef s e r O E s Nn C P s C w n. t np N

e R gio t a n e l

a eg s Nnt c n cn O s at o ei T A r iva ice l i r v N oal f ip t o C i nh e n i d

t s r I

L R es v igmo d op C N Sale Sc A Mim V

I V

d 3 mn e us e ah ha wo b r t n .

d s ht noI el yei a2 n a t vt aa. oehlahw

,y d a es e t u do r r t r t r t r d he geda gr r oht s L

A no f

o na yha s a o hgour st edl oost et nnni i

l N

igr ee t

csd ct at sos hne ut pen r u ,i r eam f une ua uFahn o . c fso s se innug ,a c a sm O etaodon nie qd o a t h n nitodslsf t

I r e s ri n S iCs nii a o e wcip l

t t r r g oa m e fei lo t

huo i odetor u I

C E

nea Ece cr r epr ee diain aitniflo d vi t

ncctar sher r ou st wp eq cdr salur gr a d e

n laevo e wo elon e i ene D- s,anet aho e rd uidnd o op ioloo alo prt uIn f a pir w E n e h d r, c s d eoe dt t

o t s s w,drou s R S ot t n entn ud e d dr t t end va e ebfeiie t he iehr s oen so su s nnior i

T t n c ian P aida r ae ,em ooncl t

aofscag ctn ciPa t

N E eMsnwr p soo fos ms rt pdditst eil f i ninns et eud cforke o r in mnnEp a odaOe t

r M OdehHr nsc e e s de in fod eis e ncbndwh ol i n lp ai mt o M dase .ps nu an bcda n a ew it miaa xl ne ne cts ux t

O e 3 at o g sa ,iri n s r n at soted nCt h s o t

ede demh C

nnbem t

ayR pi r iP s s ve u ioo cmun e hne na a er aDn l r si navnlew P

L gePn o pde w on r o t c s uiv t

n v mSio sa t

o iops pdiaic ime e9i a n ntn or a ey-ymf l bte o oieg er . it a ent At 9amr e Sa9idspiarp t

eoeop vit hc lpar e nof Cn n cpn oig ich t f c of i yn a 7 C1 a aeh a o f i let ei m iat ig t

hior r s .ie t i eg c n avs rl _

9t ryr 9or , e pi r t cloe ei l i t a ht t t e anh eCriha ) ac eie purbuin t punnagcyctw r

r vh ,h hrge at Dto fet dd t sdmeey qci _

1 epri an n e oe ccWdt up Ssd,e n urf n n

r

,n e s o o e,fo( e r nga ladnr f ea uSeuben eegs ri et ne nat gr oea c

.s e ht dpu,l t g n gi oe onlr ice ni ataoto m i

f _

Jt Fnti n nomoini e n e gi e s ieir ht er ne t l t hl a hn amo n sht a ci eiakr loidan r l

c e enr e er TPTemec edt ed Dasdin vex cdacc Epel c ooudho d Tiwodw e pd i E

S N

O P

S s 2 E 5 R e o o o Y N N N f f o o k k e d n c c ht e l a la i

n t r a a g y y d b b e inv t

c d d le o

r t e t e

f e

p a r a r

r i m t s

t s

S s n n n R a a o o O d d m m T e v e e e d d C o r

t a s s N A p ic a a O F m d d n d .

I T N i s.

sg i

e v

es vr A O s oo

=

an T I a o r r rr S T hi t h p s. pe A e c r a y imm mr R U nP r

o e io E L t sl st W A aL mA i s ab a ar V rS h ho r he O E o t n

ep ep P. f t r n e cl na co N ee pc m ano nt an O

T l

e e c mi r t ma ri c N

lar rt r o ar oif es o f r fr n U vo ep e f

n eg C Om E Po Ps i

d s g s r

ny a nec ao h s l t rt g P ys t

n htyn is si n uc ed u O breca y ge es .eped der e L o E l

r r mr A r ddf i e e edE ;cswe N

h T d en i n p n gdF eon e e izug o Ea aP tapyeri s n O t n s yis r e

p u ebrud I

S t

nde al hprasa l

n Onnaie C

q ergd d u I

C l a pse em s eh o n Emst s h

dateel c E e ap l mn it c o Pseg . al pc yemr oi n D- ee ngce h ourgin8 t

hpm n n t 9 h opo t n u i t ion 9 l

lat E t si wspmy l

i f

C cr e1 r R - S inroly eff e ear o t e nyer esspr0t 7 r P T ka t e r ri v bt e sh t

a c o a nei1 es l

t a t a c dlapu gs nys e N d o etc st d e s E

M wped . ana hal v r

e u lpyemr e a )uter l M

gof n g ,f ei o epra c

l e

s s s if nesib t t agn d F e rt 0ao a o0mt s n 0, i o r b r O ionde ndu o i

g t

csn ay xi C gi n p n e ia nd ae n a ,k i

l edri3or na on a r

nia l pt cn n ig t rt udt up r p oar sh e Tn oo i

ri e a n ot emie t an deee o pd e dt mtn oi ePta b r o cepes nt i csba s nl aai cm.t s nme e on a wv ,i e ob hec t

aix d e e s s a j a p ec (g e er r

s n e et a lagne r h m a slioi v e omnl u a oh r mc st lp d nit l

ieiol o o e 'e e k eb g a hata n l t t

irt i r e a at a t

a n ehcr o d

n e cad cmt o cd l u e an s i t st aet e e r n i ae t u n r,b h oifvia csl i

nag n pepe r

s x vo is m a e

ad et s mlt hup sg ee e ger lcvg t d t t i e niu ni ne ui icn er r umin ewar at qr xe u r eep h

e h

e he saei hoh uq Slchm Trteeh t eb t

lperd i t i T T Th cDre E

S N

O P

S s s s s 3

E e e A

/ e e 5

R Y Y N Y Y e

h t l.

t o lar d e v

e o

. s t

n s e e e t d d r

t a u

i v d n q e a e e t

n m d o

n e e g a S e d R e b a e O r n r a e a e T s v a m id C m h s s N A s t n O F le i o

I N b m d e c T o r e v e A O p la

. l b o r a

T I T e n o r p

S A c o r p s n i m e R U e t

a gn i r u

E L A

r e

r e no i s

a d W p igtc e V h o aa h c O E d a f e n .

o P s ds e r e ei si o p i

i t N r r o f a nt a e O

T d u t la it n s e 's ez ici e

s N e u n n dC l

c e a e I

L o r im i

l R h r g c U

l C P S AN To

s o e

s esis a nt e s s st ian h ly d e wdes r s oRl e

cCsyC e h ic Tan w o sa L ae r eo d n A

N wur d s pN naRu N c r h w5a - dseh t

u udo sei t r s hi sc O aiho a dr e 2 Een s 9 6. t eh sAse I

hei t t e nt a icc dRep S rh woir s u ana 92 dl ih ePs s sn ot sr ae c I 1 f p C n ou ew t

n e hcele ai jf E aompcei f i

) h D mne st si n isFnT5 a 9 mhir eru E-R S f

oibmon sl t

ol urloer oeg ics i

l sD yC e a(

d6 9 1

l e

p ww e mgsc P T N

e ssr o pb r foo eo l

f nymEn i n imn dua rn ae i

E yeopet s rh . acr6 nfof is r M la rf n ev sd byceed Eer PueFl os y n d gt a son etembnf i a

M q pDn dmpa -

I ri O aisc eclyen udat t

es t n i

n fet yC a arl e

par em C sear r assidn e logst f

uf no de nae e r eoen aeach c etgsnei egudf maqe i

vrhe neyuse r e pT c e o mewE t r o

i l sl oac ew dk e s

e oduu r eafslt er h r f asoE s .r _

e dbhE sis r

g s .

ar eg _

per susP6 t _

n a

t l nut e soc csAeom e h InE

- hein t i v u h

c c r r e

eocn.wn uont seb o

,l e eosc ecah s

i a62 nir ei it elncd s

l a r s esioar l, met niup t t n ahwd ede e5t te3 n oaet s.

ic lae soeaq y f edeae icnzui n lce s9i o t e wn9mF rl nnvuetr l i l

ay qi ek laeiv h

c ebe sea de oe1 buD t t

e Ov pU ro c at v af h in eisn a hh ic n sC Tsl i h sndc Tiaaar E

S N

O .

P -

S s s s 4 E 5 R e e e Y Y Y .

m a

r g

o r

p s

is y

la n

a S e R s O u T a C c t

N A o O F o r

I T N e d A O i v e T I T

t c m S A f e r o d R U f e

f r e E L e s A n p u W V a n n O E s e e P a e e h b b N e s s O e a a T s h h N n A A I e L c R R C U P P

m L f B 's A l e dt n w d h N s 8 e E n c n

a ed e 0 i v s a O

I e

es s n mte 0-7

. re m oee aene e

S t l n a o i el v pin 9 In )f osCb I

C senw a 'e r ptet cr oms) (4t s a ne efolair ri v asi s E icn s apoaL n 5. n d ih v nnn eieo D-l mPe lan s af e a emceAa0aiih mvina(P5l rCl et a pift w vt h e c e E ot r rl ic ea a )s nt csosiertrd)dndnd r it t

se de sar e v ep R f a t e c1 a re ctea et aEe disde e aiw t

t him P dshi n e T g :e )p rooShesmu l

c o eess t t aR e r 3 )c rpen t

LenR olcr C n aee pivtar deer c S .t a l i srd T Ce Rvmt sase; 5 )7la sio0(i wmta r sot e N Snt 5sdc 3 'n n oio e c n i sact t t acip r r e Nse nr n

E M yenbea l

o nr enrdaoA0o a onLi pa mp; oar t

r cyr se ahnio t e c dam deal cle o M b depeer hr v u gf ot eive di l erd m p sho st pE s laefoe r n adm i

t O r ie pd f Tfr snl s A

c C f imfeo t i i e egn nemhh r

.pniaasiCl

'e a a t

nSwes e l ei Pt iss noide a haeLsRe r tr l a ecnecn et i rPnfe nla ert l

t r t cd r

e oid g adh v

d ia ets diamn6h na e) tic o uwpa f e a t s n e e gl Cnnms f et eae L enr n m ui gt n d i s  ; is ehaooe orhnn rhtiMmcser adn Resvn beafoocf ) sst a soe l

a n et sdner2) v ne aps;4sOo eemvf et w Cms eR o CwoTneeeSd a cht 'e b c eal i

s o a et wcnN ,ept.c et r e n sde l

i hmenPdn;eCe n n eh e

g s smt viosRia eo it s vd e nsl ne m icbT eletaoaiaNerhonaer r t e e s r erd -

i r ot ipecirl t ori ee l ir ca .

R u spspenl s

s sm iaiRmpoehocsTt e f

e cdds vf op hcnde aaar ee sdmim es e her m i Tda o

r f

2 E s S

& t n N 1

l a O E P P L S s s f E L o R Y e

Y e

A l S a A v L o m

e R n r d o

f o e s

it c

s a s

r e e s v t

o s a it c~ _

c ly e _

a d r

r F S e h

g o c

u -

n R t c

e o d o O r r

o e i

t T r in a C o ht f e

u A C e dd e l F d r

a a N n l y p v a s r al o E O a eev I

d e T e r a lc e A i f dd _

U e n an i

t L n c e .

A e n ee V d a E

I m ivb -

e r ss s o na -

u f r eh a e p

h em C k r

pa r t

o a mg o e o or R W Cp 9

9 4 1

gd n e m ne . 2a v gf m w a id d ip l

n ol l y er or e er isg hi v s

e ve t

n sn t i

t c s

. iwge nwr a hof veo e l oiorhohs t e l loi st odeTf d Use s ue t

nrr it ehr l sbpt p rTs e t

- c RTp nta sr,m.n t

r e mm eo sn loe s f aa7n .de e n .o n ps ve o mC i it t wdai9sm s9ua e hos e nlaide e nn d omi ousei v pu o ge e e vitser n9 i

t c ac Ag r a t

c sicavt a t acitho r e c ubr p sa m ahmoo t

n sge aict r ne t

uihaf c n s o

r w1o al e pd ayh ts n t

t c ar a e e T pet e oev i h a us cepeme a s pf f odi a m hpaot c ex e ocuMas

. so dpce e r t t t xt r v pi r a n t

i cn eor t

ec msen ms h I

sin u so aii eon nlea gc nunnm t dn Ew1 oit xh n esise sl s

asT g osoer o ampn8ee .

,ddee ri r oc o rt t .c sc t ivm r ,it c r e .nt gcdeo o na ser s,tscmf U9nt om t

Ca c a e sce v 'e n oor r r a moie rt ci v sdo a erf r so e a aee gp r

da%.1 er n g0o0e 9ic aeps mxtfp r o ppo edat ne esp e ef f v n ets S

T gt e a i

n csm l anBo r o v

n a ee c en n geing nt c ain t l apr1 p gt of r

r gsiei ureea o r sst no N ienr hr r eo eiwpsir t

r vr be o aheMv r o l n ou at E is ocf vce t o eitci hgr r l eiprAhr rt M l bcl i r e eaimmc s e vi e c vl a cio s ct .p wstedur eyc e2t a era el nie smo e elerrts aet cr ,nm ie M ae ep dvRrboc hh t s t vdei yt t ar p O

t sh h d t ei t u r ocu s , m a orde r emml ainRso C e eivn e t

ia cnt t

eofu pfond enr e ml airvu veroturr sU e cn sv o it r ri c r yf n o cot ri - miaoes stsf e .

aodr r ep n ie coAfoio t

c uig odn t

acB r

gpwiee s n aye r w s p s o g9 i

vwe.6hi 9tsnhe es hpnm t sdo so c

umfi sie in ee e n nio shivodt eas ina l t

eal r

n ss oseist r

pdnv enry e tr e v s apa1 t ur l a hv t i it

,odi t t nt ca o e e s i

t n I e haRea t

aia s swdn t w%o0 e pi tt i b ewc st n dnt ,s,de ee edt cvr me e i t

.r g vs e r eia1n0dme e ,a lior nyesw icr d u s oce

,nis t tx n uer tor ol r out l ne o np nteiit 1 n es1 I

f t ad a it e t

iaiu r uiec e na i

cot cs e epCfoipei l v f us hctcf e n n nn aBar hm TiaaaI bmirce l Srteo TfoAen f

oelae Uat dh n pS liUU c E

S N

O P 6 S s s s 5 E e e e o R Y Y Y N t

n y e

v r

r e a r

p c n o e o t is e t

s b s e m e

r c

r a r

s a

u u . g h s os o e a sm e

r r a e p c m r n n t g o a t

n n er o it m S e i cp c r o

R i

a ic i f f n e r O f f

f uo i v e p

I u st c it C s da c t n

A e e e r a r .

d ave t l F us od p N l cm cit ct e lu O ine loc e t n I

l lar r ae f s

s T sb so hm A no o r ac t

dle e c

U ip c L

t cf he t g iep ud A ao nn f

si m se e ea ,t ve it V mr aly dr a E in c eg

- st n et s t

cerer gn se inn ao i i Cifc ao r

r u oc nl at u Rf u t

sm ue Cer Mo Ns Sd

8 l[g 3 ld c d I:! sh .

fd- I g E *] h" fE -

j -l*a $si3 *.

sg ag li. g a s

ih ]esii,f s 1

q .gN 11 sin s e a{n 3gfes 31 ~a g*85 a.q[*$ D !f $

isea 5's8 Ih ID $$la@uitg ~f=il st. - is "hk e]l e

scag ] E n. '2 egg o

$gg e m .c .e-gc&l'.lg.8 - -

g g ..

b "

b#lui 3 b I b t,ef 5 " a.

le sgilsli sin plishe.!

si 1 p$b;l,j

sse-e I 3l! ifliif ?3 9 1 Ilgz

!d{ilj3lljll*khh!f!!!l]!h!!!

ll bill lIl l O

1 Y

.2 sE lE sj h as m;

2. Es .

8 E 5- 33 $ $ Y. l t

g 1l-E .*

51

$8 gg 6 Y flEl 3!

$ 911 l310 1 se s5g w

B j ! .li !8

_a 1 *1 l-15 13' 42 fel 85s

=i

d d n s .

e g e i n t c o ne nti o t

d g n u t

s ie l

a le n ehtgt a i o d dn r

ust csi t iat t r

. a nimis isges u

t t

a n oeeh cr egovi nt eo t

dne ai r t

ncpc ea dt d

ee cinge olt r

a vhnd et s dsubspci ah i rt t i

el g! f s pr de er oa f un o tolpa n rsa rt an a ne emewec hev v i pk r

n dene ivh iv s eTloly mr r o lelc va eo iema e ,el etswt e r etohaOoeo r xr a s .sg o

fr s f

s dg t v

i st chea cmauiep gvoi r g a sls r rf ashoo ewm r awe we r no e ne eeor nsn r r no aent srt pne t f oc at ul codge r t n ivds ereraa fl in t fbrtpeio toc Maiutat cd i e inp nd o

i aa z e n ro oal a r vNt mew, r e pcroitcgosf ia t t i l tar e imnr n nde n c cin al t eco z ao engpins laoihpneiwa vnt e v S is gf bo nr r i ooct e l Pc rTxuep l oas e T n n a

gi 'o r

o ep r

sntrcduv ao e d donf .

emee r pmsew r

r N

te d hiSreedml n a a s n edmwh ne t m ro orgHo E

t f o os o rt t i f oa ae t n .givt la l

f c 's s eer M es t

r v o neen on naiyat r s c p p s.

pron dstaeredee

. r M et cored t

et n O

t a

rh e r pl a danr i

st as heu pue t qd t c en vc a nkrd r t

a ntn e m C ot pf cmpe o e nm acrl r e isne e

rl apo isWa od ma r l opcb al r o Ppxtedaosn I

i f c o f t f i o o d Pmfohh

.h eer gwh en i r c s n nt -

i t -

eht e hi tcfan

.t e

r nnp a an w icgeu f t eg ee Vaporont,en pcie t

cint n .

ce Vwea o ats emisec i

hi nl o pd i

lar e sc t v

,e ise n gh it n n eant aioa m egenguzine smitcie navt i

en nr t

a e st e age n nsda t t ao am s in iaen imvnidrzimg t it t t i t ol t S

ia t oen rdado a Siamiclepaic t n t sm sf mro t

ic di t esl e n pi g a fe a r n e enmgr h ea or ar ni b ue di r ac hue Tbd ha l T pi e o I mvr n pm Tmmcoctohmd eaf e St hh p ae r

E S .

N _

O -

P 8 S s s s s E e e e e 5 R Y Y Y Y t s e h sle r

t t

h is g ev t e nid aw a r sl l p-i s e ol l C

r e ly v om f a dt h eR v lu e .

t e na t N

f nl ad s O e c ebo rd _

r n no ee d

n aa mr ep oo ds ia a smr gd t

i t crs s nre n mo an ee r oc cn o af r eep ana id dn r i

mns i

t a

t gu et n _

S z t

nd eio ns ga nr _

R i ee oi n t t rt ora -

mvo sha O a aa t e

l T g r

er gp r r oe pp st t e

ow nt C O am r o ec l p t a A ni o ct n di ih nh .

F t n a g vt m et _

N e mn ea o rk e o mse _

O m t v n

i e

i t

vl p pr o C e gss e cn m t

a wn ae I

T g ai ei o n nn pch l

A a f t etyit e .

e n f

U n a ak .

L a da no sm e t t f ez m s mae _

A a nain s Cw V

E M

ed at ted he v n .

es mr a g s e Rg -

e e et eloo s v at ri e vi t e

gleo ar A s Nn n o r ivi n

ep or om p

s nil nu ace C oat n c r m edso nuh R inh e Cco o cne ant est im Li i

Lar Mai n N Saa t

l l

I V

I

s r n e ed is o @

a b be t s i h

ne ne au a f

t dr y eat lps as r o l c n2 t ce e l iu ot a t nrd tawh sd t

ns t dn d h wd i

r a ate i

r 'e t a o ae serefo rf et s oi e a T ;d n redit nU in ot pc eist it i tag h t s s r atfr laeo u r in r p ntr ar octehe eo i

e rn leLim c c s of i

zi nrs cetol lata ir enAt n r sn c o t ee rf mn ,ts r

l h g

t n pR ipP svaCefonel orset ari ae 0it a r essh 5

l n ne ep dr io amvn

.i MSa uP t esoia gv . 3eeir r t 7iet rt t r eoh a 9 r o ts o 0 thns it nt oeh9epcedtar e or w g9lbepesmr ar 1i r o wcn icot f odo ns t , t sn9 e dn sr eioss1 r

ne i dtane na9 ha t

te pl a pt cin r l

bsn u o i n c U pH e m i a iPol 1 y

s evm t

e ei in u r t alesepoivhwtoicdf a8m i

o ne ede cnl aet n .

r a r era dc o hwept t usn c ot i2shef ata t e eh pT ur e or C ssn f n ni lamluss na e r _

t f p l asie mere aCot ni oTesd bn aeSu c a ol O b at lcnm a

u ,it m n ah v me nc 3 e S

T u ei n ala n on n a ve eNurUtc s s r n.

e>wau l

i t l iod le r o aLr e eth a r msomdr m dey F N cme s c o i r ne ehlofo pt K scr ed r f er wf a s er t r e aoh pf oorhg e s a of t

inee M pd f r gT E gh st eipct eiagml n

yr i

csneape si pts ohc vor Pe M yat Des aeh t .

l l

n e hhTtris id boelas eist Opaetrhe ee La2 M u au t

n eet r ft oc nnr n e cp ACy r O

f d .e dcteanr oi su h t vt e n n S so C

t e min te nc enl t e pi t g t Elaaass Andl on a a 6ag t

eonmapsi ect inil a d pt u aT dio o ygn amem t no lpt i orormmrf i r l

. t niSnl t cr m 9gt 9 na e ~

ooc mt ac or f a mrde eaFoaliouI 1

o S n, ef rf o co uts i t er f h i

ntr c r rC c lelape e eesreheaioorb l

s st o r f r 9 e p eHtaah e ,

r e i

dy t s pf a9 t

r t o n2 t ply n

e boid n ea her a Cla P C ph l r s r,a2se1 s p9 s

s et ddao l

cus R StrRg T baw e 'e ef oiec o eemh ineni n avoa t ge a n e v nnc7 t

n .t t ,

c nta ois NaaNi1 pes esn msletnbeUr oi ts t OEr ee eeUd al r rt ec d i pn po e e Lt seeic t wror aep i e eoicde dpdri eds aCn hr eh e n TfoRTnUatchcohmfoeraA i l r hcr wnl Tlipt aoiAtmde h hn a Taw E

S N

O P 9 S s s s 5 E e e e .

R Y Y Y m

l l

d a

e r o r

e e m

a o t

v o h _

ssr t t

in ie e c it d vn le f

d e

it c u e r

t c

a ro s r

le f

gd n t o e r

ie a sv ic s _

nlo a _

S es ic e d

I n d e

l r v _

R dy e o .

O nl c r T ae r n p np s a C n m A o orp o m r

i.

sgs F it c

i t o .

an es a f e N

O pg r e e cn r hi e

t a

I sn ni d Pa c r T id i s

f om nP A Ci n aL r

U n t ef o mA L R f

d o sre rS A Nn C o V t a l t

np fr t n

a e E n e at n eg cn pce ice o ei r v l

e a

l f l i r

- ip n

t i t o rt io gm d d

s op r

es vo Sc A Mim Om V

- i

e e s s t na d a am r

c h m i eht in s 6 yt le 2 t r sg et ,e c e.e t

asa sh 9

9 le re sr bet o yin eo b dp u c s t alenn 1 v el mert it haawpoU Rr p sex au e na n a vooe a wir e i s

a s t

u eiin t t le e ot r

cpnnf o h)T hn t t ii n t nor t

nm c o emho san rt bl ecu e a r nt s awa r nnh t ac o I

,yr aJ tohHoeoi f r omiw p rd t c t l psmp er a e eisee ai(tamcw e wgr e e e r t r edf at iea it l

l gt aediivh ne v v r l

lae n nra fahtu oomduer t t t t Sv peipo aa a etnceec nqse ocn l i

niorh yb a r s e L s 8s nt aenp bom e a r err n u u a p s 9 doamssiceO da rd sm r a emoi ed urTemr epu t

n w s wec 9e a i i oe c ne h ts ndmor ancdele no iga c e 1 r s o yf it l rt dorde s ems l

r ri ner et h sdt hit u cs cinae r t

e ea iel f lyfon it n a n ut ngia a r ra pandvoe e er s r eo h sr es S dt l naEne gx s u uoee yntei dhagd da t

T nro er gic ue ic o nt vp l einsOat h a p Anihayeo r N den e e n.is f vsI s l

E e,pu i

e anlgA m ra wt t it snh er sp o .sf e r uoo M c s eead h bgg t cmis e ssHu9 n oin s e gd e u e e c uht ge mHds i

n a se n dlt s M ohelay io sr aseo n ce r

eaele O

at n n t it brb e . f 9 gv a onema ct ula pd ic r, e p la9 t .

ela ewn vdn de ic C u u 1 ao r ,t kcf onnS r

t p n

e n dweivee nosf t at s ne n ud t u e r r sewe ah ir t

r l r

s plada eehn g i

pdn a nioLct eit ia h n adr i er hamutc n w gi i

et aeco t i r t it p iv mT oeuft eo en ri pwreswA us e n s e a ct h dt ps df o ed et eeti ri e eo t -

s ngn.t sr a s e nia sea dastelai n ecamch snpe nl n d eies se v sw t

oine ndnim o

t e h af r e ndnf ed o ade na emInpm.e l

aAa r . mlenc enen i

ivt t

aoi r r s s it eag la clupnbve ic l 1 l eei t rt oeiyoc sir cl t

i c r o

mr odb s

nd vnce ool i epn e or it bnduur t t e l n

.i sf emu r s i

ic pmo oic iode er Vrteh bps e Ut u encdodp nor i coc l

ehax cor she ef hel T r a a eouo pP w p n n b r t pr ef mehe ipTd

~E S

N O

P 0 S s s s s 6 E e e e e -

R Y Y Y Y f f o o d

k k n c c e l a la r

t a a g y y t n b b n i

v d d e o

r e e d i

p t

a t

a v t

r r e t

im s s t o

n n n n a o o e d m m r S e e e a R t a d d s O ic s s m T d a a le C n d e

d es . b A i s v vr o r

F a o r oo r rr p

N h y

p s. pe e c

O r mm imro n I

T t o i e sl st e r

A U

is h ho ab a ar e L t ep r hepe h d

A n cl co a V e na nt e -

E m an an r u

e mio ma c

r o f r

oar r

t ri c oif fr n d

e c -

epe o f

n eg r E

i Po Ps P

df . s a g sgc n om e l n eri et ule u p 2 u atr r t a n o o it i

n ss s ce eobe heoh ah it t nn epn t

r en iay i ml grt t

o oa e io vUe r

t r e

y c geEst et npodmt n n cl p f

oeb r p

a hst h o ag os sc e l l t dv odo g e r n i nbaha gor ashate o r oet s n h n eve o cehst sNere getar sr e apnwe r eir g geswa osaSa t

cewy c

i s si yc t et g

a eTga c

e r

u .ud d rdu ei vh it is sspm aue n inGl sdpuret o

r el n ne n n .inh a a et dgeeda e

er al it b a

gdt re e m mgnd ct acoo yi ea o e f it aen h dgs s r ek n ocan our ot t int i s dwrd v rf on i

a n

edelaci c nniema cotwmtue ei rleas r

l t t t r no afr hgna p opes ec r l a

r s e

oo deti pe )e lpe cno s deua ea rt sl pa duimo l na i

f r nr r eof a oMrh i

smchoea t

- T d pe ot a e f ivtr z i

u et nl ndaip reeqoi o u nn t v

eh scu sdeat ene i n s a n r

S nmao t r aeetuhcude a hoi t

t si sa a n ecs s ds T

ai sc n t e i c sier n af kGc yd gs mtxd ue a ee e . e N

l a epa eb sinisEmi t indopwg r r n eisn cg t

nis yicc emuaGaelobie f n da oo es E

M nhxh o

iTet t

o l

a nper el i de,cdsidKdf i l

udngh ni sde l de th t hnrlo e pk o mly ea M a eb aShab ae ns o ga nla .

c,seema nt atcsEbr s gi c nwia c n ersc a lpa r

e lsiSqmnt us i i

vi l u e.Totbnedad r

O poo r g f goo ewsesb m ueuln be C n s t rf naa nCv r ie ot ani f r a t a

.hafl d

l i d c pd aslch eesh aef a dl lomha eTh g e du s

isri ee u t a t eo mlc di ch y aol aa r prd t ciei psweeohi r

it nbrn,oo p t r hf b dna po i

.dn ah hc o ooe o o e (sth laeet s i f se s t e e gz e nt ne e e r e et e

soo t

a eyns t c . or t t aia sl edv etu pif s c l

r prdMuuhsnndh n aemiss sr t t uhl ean e eapda BS oh gi q c ennu neent a ntan es a enee r r uu n r mt r vmiot t

s e g) u e w i p pfcooo ers ri s mh net ae pngod u ic 1 f ciddd ee icv n moa ioir s t a nr i ee o f cor t l eenEohslemmsd l

in cc el ef e r t a ersnmw hein ng e t

oor ep r hof ehoo ad e av rioe i

Ttofepoep icheGr Lwb(hfot hTccwa t Pt opmf l

TUier sbpp h

Ti m E

S N

O P 1 S s s s s s 6 E e e e e e R Y Y Y Y Y e

h t

l.

o . m a

l n a t

d it o r e

r g

e s a v o o r

s z p _

in e e

r a t s _

d g a i s .

d r u y o q a e la n t n d n e e a a e m d e b e e s e g r u S v a e a R a n id c O h a s t T s n o m o o C m s c r A . le it e e v

F la b r N n o d e a i t

c O io r

p v s e e t

gn

. o r r f

f I

T a p u e A

r e ii no d n U p gt c m e a aa i

L o s c s A ds f a o a V is iei t h r

p h r

E o i a f

t s e e e t

a n e e e lu e 's s n

s n

s n

dC i e e e m l R ic ic c lAN i

S L L iL

\

s i

e e e a l

a e i n

g v hs l

- s m o r icn nha oT e p he c r

n .d f

ot p a n ata 6e wl i a sn we c ihecaed 9h doie niv eiTn f 9T 1 aar yt r n .

ng .ia i n5 - mel apn t _

iiam gs e e ,r e i sE . r gt c o e _

) t ar s1 E on e . -

i l lyf E r a rt 0 u sirsd r

a oE 1

danb

,eha rt o n yP acI n

pl so k pap sywe i l r S

r asdw i

Ee Puqga n ri ndao amn B oAee~

T I wgrigc N nen t w.no ev t i E afri m on dioe _

e a r t r r p _

M iene der ego hd uups M vra eh e et maf e r s engi n O Rsby o r

mp asiCr C i n th s b s. f a s uoR o asle rdf e o ari t inhe t

c i v pe r s honN f on As n yls et eose emma eon elae ec s c e

s a rks n vimnb l n aor n gi i

aea a or h t

t i

ct vf t edp ce e icrpeg t

e c eroop nn r e iwe l l o xmtac c r ppe eoth eklie r hh hsnt _

Ceir a Tsi n Tios r E

S N

O P

S s s 2 E e e 6 R Y Y L_

S R

O T

C . _

A d e

F -

N m r

O o d I

T f

r e e s

A p u U n n L e e A e e V b b E s s a a h h A A R R P P a: