ML20217C072
| ML20217C072 | |
| Person / Time | |
|---|---|
| Site: | North Carolina State University |
| Issue date: | 03/18/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20217C038 | List: |
| References | |
| 50-297-98-201, NUDOCS 9803260279 | |
| Download: ML20217C072 (18) | |
See also: IR 05000297/1998201
Text
,
- ~
-
4...
..
U. S. NUCLEAR REGULATORY COMMISSION
, OFFICE OF NUCLEAR REACTOR REGULATION
Docket No: 50-297
' License No: R-120
Report No: 50-297/98 201
Licensee: North Carolina State University
Facility: PULSTAR Reactor
Location: North Carolina State University, Raleigh, NC
Dates: January 20 - 23,1998
Inspector: Craig Bassett, Senior Non-Power Reactor inspector
..
Approved by: Marvin M. Mendonca, Acting Director
Non-Power Reactors and Decommissioning
Project Directorate
L
j
>
l
'I.
I
.
i
,
i
I
ENCLOSURE 2 _
i
-9803260279 980318
PDR ADOCK 05000297 i
'
G. PDR . . ,
F
'
-
e
,
.-
EXECUTIVE SUMMARY
~
North Carolina State University
Report No: 50-297/98-201 1
The primary focus of this routine, announced inspection was the on-site review of selected
aspects of the licensee's Class 11 non-power research reactor operation including:
organization and staffing; review and audit functions; procedures; radiation protection and
, ALARA programs; effluent and environmental monitoring; the shipment of radioactive i
material; the safeguards and security program; and the material control and accounting
program.
Changes, Organization, and Staffing
)
e The licensee's organization and staffing remain in compliance with the requirements
specified in the Technical Specifications.
Review and Audit Functions-
e Audits were being conducted by the Radiation Protection Committee (RPC) and the
Reactor Safety and Auditing Committee (RSAC) in compliance with the requirements
' specified in the Technical Specifications (TS).
Procedures
e One apparent violation (VIO) was identified for failure to meet the intent of TS 6.3.b
and Special Procedure 2.1 to have changes to methods and/or acceptance criteria used
to complete work reviewed and approved by the RPC.
Radiat5n Protection Program
o Surveys were being completed and documented acceptably to permit evaluation of the
radiation hazarda that might exist.
. e Postings met the regulatory requirements although one non-cited violation (NCV) was
-
noted for failure to post current copies of NRC Form 3 in accordance with
- Personnel dosimetry was being worn as required and doses were well within the
licensee's procedural action levels, and NRC's regulatory limits.
- Radiation monitoring equipment was being maintained and calibrated as required.
- ' The Radiation Protection and ALARA Programs satisfied regulatory requirements.
4
Effluent and Environmental Monitoring
- Effluent monitoring satisfied license and regulatory requirements and releases were
within the specified regulatory and TS limits.
r
! t4
7 .
..
>.
2-
Transportation of Radioactive Materials '
e Ra' ioactive
d material was transferred to the Campus RPO for shipment and/or disposal .
. according to procedure.
- . Safeguards and Security
e The NRC-approved security program at the facility was acceptably carried out.
- Material Control and Accountability
o ' No deficiencies were identified in the licensee's Material Control and Accounting
program,
i
.'
'
..
.
.
REPORT DETAILS
Summary of Plant Status
The licensee's one megawatt (1 MW) PULSTAR research reactor continues to be operated !
in support of undergraduate instruction and IEboratory experiments, reactor operator
training, and various types of research. During the inspection, the reactor was being
started-up, operated, and shutdown as required to support training and research.
1. Changes, Organization, and Staffing (69001)
a. Inspection Scope
The inspector reviewed the following regarding the licensee's organization and
staffing to ensure that the requirements of TS Section 6.1 were being met:
- the organizational structure, !
. management responsibilities, and j
= staffing requirements for safe operation of the research reactor facility. ;
I
b. Observations and Findings !
Through discussions with licensee representatives the inspector determined that
management responsibilities and the organization at the facility had not changed 'I
since the previous NRC inspection in June 1997 (Inspection Report No. 50-297/97-
201). The inspector determined that the Associate Director, Nuclear Reactor
Program (NRP), retained direct control and overall responsibility for management of I
the facility as specified in the TS. The Associate Director reported to the Chancellor
of the university through the Director, NRP; the Head of the Department of Nuclear
Engineering; and the Dean of the College of Engineering.
]
Through review of records and logs and through discussions with licensee
personnel, the inspector determined that the staffing at the facility was acceptable
to support the work and ongoing activities. The staffing met the requirements of
the TS.
c. Conclusions
The licensee's organization and staffing remain in compliance with the requirements
specified in the TS.
2. Review and Audit Functions (69001)
a. Inspection Scope
The inspector reviewed the following to ensure that the audits and reviews
stipulated in the requirements of TS Section 6.2 were being completed:
- Radiation Protection Committee (RPC) meeting minutes,
e Reactor Safety and Audit Committee (RSAC) meeting minutes,
- NRP Administrative Procedures, and
.-
t
,
.
2
.
TS duties specified for the RPC and the RSAC including the committoes' review
and audit functions.
b. Observations and Findings
Section 6.2 of the TS requires that the Radiation Protection Committee meet at
. least six times per year to review safety aspects of facility operation. The Reactor .
. Safety and Audit Committee was required to meet at least four times per year with
intervals between the meetings not to exceed six months.
The inspector reviewed the RPC's and RSAC's meeting minutes from October 1995
to the present. These meeting minutes showed that each committee met as
required by the TS with a quorum being present. .The inspector also noted that the
RPC and the RSAC had considered the types of topics outlined by the TS.
It was noted that both committees completed audits of generally different but
complimentary aspects of the reactor facility operations and programs. The
inspector noted that, since me last NRC inspection, audits had been completed in
those areas outlined in the TS. Audits were varied so that all aspects of the
licensee's safety program were reviewed every two years. The inspector noted that
- the audits and the resulting findings wars detailed and that the licensee's responses
and corrective actions were acceptable.
. c. Conclusions
Audits were being conducted by the RPC and the RSAC according to the
requirements specified in the Technical Specifications.
3. Procedures (69001)
a. - Inspection Scope
.
The inspector reviewed the following to ensure that the requirements of TS Section
~ 6.3 were being met concerning written procedures:
. - selected operations procedures,
.= selected safety procedures, and -
.
' the process used by the licensee to revise, review, and approve all facility
procedures,
b. - Observations and Findings
TS Section 6.3.a.8 (dated December 27,1984 -in effect at the time the changes
discussed below were initiated) required that procedures be written, updated
periodically, and followed for radiation control. TS Section 6.3.b required that
substantive changes to procedures be made only with the approval of the Radiation
Protection Council (Committee).
Special Procedure 2.1, " Review and Approval of Proposed Design and Procedure
Changes," Revision 4, dated August 1,1994, (in effect at the time the changes
-
, discussed below were initiated) Section 4.5 defined a procedure change (PC) as a
1
1
-
\
.
i
.
3 ;
1
change of intent to a written instruction that defined the policies and practices used
to complete work, such as a change of purpose, method, or acceptance criteria (i.e.,
not editorial or temporary changes). Section 5.3 of the procedure required that a PC
(e.g., a substantive change to a TS required procedure) be reviewed by the
Associate Director of the facility and by the RSAC and be approved by the RPC.
During this inspection, the inspector noted that the licensee's written procedures
concerning health physics (HP) and radiation protection activities had been revised
extensively since the last inspection in May of 1996. Previously the licensee had
approximately 31 HP procedures. Following the extensive revision in July of 1996,
the 31 procedures had been replaced by two main HP procedures with 10
implementing " instructions." Also, about eight of the original HP procedures had
been changed into surveillance procedures. According to the licensee, the resulting
two new HP procedures were those that contained safety-related activities and dealt
wit'n or outlined requirements stipulated in the regulations, the TS, and/or the facility
license. The new " instructions" were merely used to specify steps to follow in !
fulfilling the requirements in the procedures.
The inspector also noted that, while the original 31 HP procedures were required to
be reviewed by the RSAC and approved by the RPC, only the two new HP
procedures and the new surveillance procedures required such review and approval.
The reason for this was that one of the new HP procedures gave authority to the
Reactor Health Physicist (RHP) to develop, review, and approve " instructions."
Therefore, the new instructions that had been written did not require a review by
the RSAC and approval by the RPC but coulu be written, reviewed, and approved
solely by the RHP. However, the inspector noted that the new instructions
contained a section that stipulated the method to be used to complete work and a
section that outlined the acceptance criteria Because of this, tha inspector
concluded that the new " instructions" were essentially procedures. Therefore, a
change to one of these new " instructions" should also require a review by the RSAC
and approval by the RCP as stipulated by the licensee's TS and Special Procedure ,
2.1. I
The inspector determined that the procedural revisions and the development of the ,
"i .structions" did not comply with the requirements in the TS and in Special !
Procedure 2.1 that were in effect at that time. The problem was that new
instructions could be developed that could include changes to the method and/or the
acceptance criteria used to complete work. However, these changes would only
have been reviewed, approved, and implemented by the RHP and would not have ,
'
been subject to a review by the Associate Director nor the review and approval
J
process of the RPC.
in the summer of 1997, licensee management had felt that the new process for i
developing and approving HP " instructions" may not be in compliance with the
intent of the TS. Following a review of the new procedures and " instructions" by a !
former RSAC Chairman in August 1997, the licensee revised Special Procedure 2.1
to require changes to " instructions" to be reviewed by the Senior Reactor Operator
(SRO) and the RHP. Special Procedure 2.1, Rev. 5, dated December 5,1997, also
required the Associate Director of the facility to approve such changes and the
changes were to be forwarded to the RSAC for inclusion in their next scheduled '
meeting agenda. The inspector determined that, even with this revision to Special
L i
n .
.,.
- *-
jQ
'
.-
l.
l 4
i
Procedure 2.1, it still did not comply with the requirements in the TS because . I
instructions could be developed that included changes to the method and/or the
l acceptance criteria used to complete work but would not be required to be subject
i to the' review and approval of the RPC.
t
Following the inspection, the licensee (Associate Director) committed to conduct a
review of the instructions. After the review was completed, the Associate Director.
indicated, by a telephone call to the NRC on February 3,1998, that the
L " instructions" would be revised, changed back into procedures, and would be
. reviewed by the RSAC and approved by the RPC.
The licensee was informed that failure to meet the intent of TS 6.3.b and Special
l - Procedure 2.1 to have changes to methods and/or acceptance criteria (used to
- complete work) reviewed and approved by the RPC was an apparent violation (VIO
50-297/98-201-01),
c. Conclusions
! One apparent violation was identified for failure to met the intent of TS 6.3.b and
Special Procedure 2.1 to have changes to methods and/or acceptance criteria (used
to complete work) reviewed and approved by the RPC.
4. Radiation Protection Program (89001)
a. Inspection Scope
The inspector reviewed the following to verify compliance with 10 CFR Part 20 and
the applicable licensee TS requirements and procedurest
. ~ health physics survey records,
, e radiological signs and posting,
e dosimetry records,
e calibration records and periodic check records for radiation monitoring
instrumentsi !
. ~the Radiation Protection Program, and
. the ALARA Program.
'
l The inspector also toured the licensee's facility to note any changes that may have
'
been made and observed the use of dosimetry and radiation monitoring equipment. l
Licensee personnel were interviewed as well. ]
b Observations and Findings
(1) Surveys
Weekly, monthly, and other periodic contamination and radiation surveys were
completed by the RHP and the Radiation Protection Office staff as required by
TS and licensee procedures. Results were evaluated and corrective actions
taken when readings or results exceeded set action levels. ,
l
l
y .
lt. . . . W' <
- .g. ..
.
[('2) Postings and Notices
l . o
L 10 CFR 19.11 requires the licensee to post current copies of various documents
p including the regulations in 10 CFR 20, the facility license, procedures, and any
l . notice of violation as applicable.; if posting such documents is not practicable,
l the licensee may post a notice that describes the document and states where it :
l ,
may be examined; The licensee is also required to post a current copy of -
L NRC Form-3.
l _.
. .
j Postin'gs at the entrances to the controlled areas, including the reactor control
p room, were acceptable for the hazards present. The facility's radioactive .
material storage areas were properly posted. No unmarked radioactive material'
was noted.
Copies of current notices to workers required 'by 10'CFR Part 19, with the .
execption of NRC Form-3,' were posted in appropriate areas in the facility. The
copies of NRC Form 3 that were posted were noted to be somewhat outdated.
? ,
When this issue was pointed out, the licensee promptly posted current copies of -
NRC Form-3 provided by the inspector.
'
The licensee was informed that failure to post current copies of NRC Form 3
l- _
was an apparent violation of 10 CFR 19.11. 'However, this failure was a
violation of minor significance and is being treated as a Non-Cited Violation,
.~
consistent with Section IV of the NRC Enforcement Policy (NCV 50-297/98-201-
02).
^
"(3) Dosimetry
L The licensee used a National Voluntary Laboratory Accreditation Program
(NVLAP) accredited vendor to process personnel thermoluminescent dosimetry.
-
L -An examination of the records for the past two years through the date of the
'
inspection showed that all exposures were well within NRC limits and licensee
action levels.' Most of the records suggested no exposure above background.
- Dosimetry was acceptably used by facility personnel.
l '(4) Radiation Mo'nitoring Equipment
i
Selected radiation monitoring equipment had the acceptable up-to-date j
I ~
'
l -. : calibration sticker attached. The calibration of portable survey meters was
L 4 typically completed by Radiation Protection Office personnel. Calibration
~
frequency met procedural requirements and records were maintained as required.
L '
!
,. z. - L(5) Radiation Protection Program i
L '
p
l- The. licensee's Radiation Protection Program was established in the new
- procedure, HP 1,' ". Radiation Protection Program," with an effective date of
January 1,1998. As noted previously, the procedure had been reviewed and
' approved by the RSAC and the RPC. The program included requirements that all
'
Jpersonnel who had unescorted access to the facility receive training in radiation
~
protection, policies, procedures, requirements, and facilities. The program l
appeared to be acceptable.
_
l
!'
l
iL . 1
I
i
,
,
'~
- .
..
.
6 i
The licensee's Respiratory Protection Program was being carried out as outlined
in the procedure and the associated instruction. Training was being conducted,
bioassays were being completed, annual personnel physicals were being .
conducted, and tho' equipment was being checked and maintained as required. 2
i
The inspector reviewed the Radiation Work Permits (RWPs) that had been
written and used during the past two years. It was noted that the controls
specified in the RWPs were acceptable and' applicable for the work being done. l
The RWPs had been reviewed and approved as required.- j
. ..
)
(6) ALARA Program ?
- The ALARA Program was also outlined and established 'n the licensee's new.
procedure, HP 1, Radiation Protection Program," with an effective date of
January 1,- 1998. The ALARA program provided guidance for keeping doses as -
low as reasonably achievable and was consistent with the guidance in
(7) Facility Tours l
The inspector toured the control room,' pool' area, and selected support
laboratories and areas. Control of radioactive material and control of access to
radiation areas were acceptable.
c. Conclusions
Surveys were being completed and documented acceptably to permit evaluation of
the radiation _ hazards that might exist. Postings met regulatory requirements. One 1
NCV was identified for failure to post a current copy of NRC Form 3. Personnel j
' dosimetry was being worn as required and doses were well within the licensee's J
procedural action levels and the NRC's regulatory limits. Radiation monitoring !
. equipment was being maintained and calibrated as required. The Radiation l
Protection Program and the ALARA Program satisfied regulatory requirements. l
1
5. Effluent and Environmental Monitoring (69001) j
a. Inspection Scope
The inspector reviewed the following to verify. compliance with the requirements of
.10 CFR 20 and TS Sections 4.4 and 6.7.4:
~
e the licensee's environmental monitoring program,
- annual reports,
e release records, and
e counting and analysis records.
b. Observation and Findinos ;
~The inspector noted that the licensee had made some modifications to the
-
' environmental monitoring program since the last inspection. Following a study,
conducted by a committee established by the RPC, the licensee had decided to
.
.
l.
!
,.
I 7
l
l scale back the program for taking and analyzing milk and vegetation samples in the
areas surrounding the reactor facility. Also, air sampling was to be completed at a
reduced frequency. The decision to scale back the program and reduce the
frequency of air sampling was based upon a review of various data from previous
years that showed that such action would not reduce the effectiveness of the
program. The reduced sampling would continue to give the licensee assurance that
no measurable radioactivity was being released from the facility. The inspector
determined that the action was allowed by the TS and did not conflict with
. requirements stipulated therein.
The inspector determined that gaseous releases continued to be calculated as
required, were adequately documented, and were well within the annual dose
i constraint of 10 CFR 20.1101 (d), Appendix B concentrations, and TS limits. Liquid
l releases were approved by the RHP after analyses proved that the releases would
l - meet regulatory requirements for discharge into the sanitary sewer.
c. Conclusion .
L
Effluent monitoring satisfied license and regulatory requirements and releases were
within the specified regulatory and TS limits.
'
6. Transportation (86740)
a. Inspection Scope
. The inspector interviewed licensee personnel and reviewed various records to verify
compliance with procedural requirements for transferring licensed material.
L
j. ~ b. Observations and Findings
Through records reviews and discussions with licensee personnel, the inspector
determined that the licensee continued to transfer solid waste to the Campus RPO
for shipment and/or disposal. The transfers appeared to be in compliance with
procedure. ]
I
c. Conclusions .
4
Radioactive material was transferred to the Campus RPO for shipment and/or
disposal according to procedure.
.11. Physical Security (81401, 81402, 81431) I
a. inspection Scope-
To verify compliance with the licensee's NRC-approved Physical Security Plan (PSP)
l- and to assure that changes, if any, to the plan had not reduced its overall
'
effectiveness, the inspector reviewed:
- logs, records, and reports,
- . the security organization,
- key control,
I
.
~
..a q
,;,..
..
$ .8
- * - intruder detection and physical barriers,
' a ' . access controls, and -
a procedures. .
~ b. ' Observations and Findings
The' inspector determined that the licensee's physical protection program confo'rmed
to NRC requirements and to the licensee's PSP and implementing procedures.
c. Conclusion
'
'
x
.The NRC approved security program at the facility was acceptably carried out.
.12. ' Material Control and Accounting (86102)
a. inspection Scope
To verify compliance with 10 CFR 70,~the inspector reviewed:
- storage areas, .
.
- procedures for tracking the quantity, identity, and location of Special Nuclear
Material (SNM),
e assignment of responsibilities,
- ' annual inventory results, and -
- - associated records and reports.
L b. Observations and Findings
!
- The design of item r
- ontrol areas ensured that physical and administrative control of
SNM would be maintained. Licensee procedures for tracking SNM were acceptably
~
1
carried out. Written statements of responsibility and authority were established for I
positions with responsibility for SNM. Records showed that physicalinventories ,
were conducted at least annually as required by 10 CFR 70.51(d). 1
l
l< Nuclear Material Transaction Reports (DOE /NRC Form 741) and Material Status
. Reports (DOE /NRC Form 742) had been submitted by the licensee as required by .j
l
l Exhibits I and 11 (attached to this report) summarize the licensee's uranium and- )
plutonium material balances from October 1,1995, through September 30,1997. 1
i
!
L .,
p,. .
.. . . .
. ...
l- 9
I c. Conclusion
No deficiencies were identified in the licensee's Material Control and Accounting
program.
l . 7. Exit interview
l The inspection scope and results were summarized on January 23,1998,.with
l
' members of licensee management. The inspe:: tor described the areas inspected and
l discussed in detail the inspection findings.
No dissenting comments were received from the licensee. The licensee did not identify
as proprietary any of the material provided to or reviewed by the inspector.
L
.
.8
l
\
!v
I
l
i
t
a
"l
.
r
a.
'
! 7.; ,
l
l5 ]
. . .
l
i
PARTIAL LIST OF PERSONS CONTACTED
~
'
ILicensee
S.' Bilyj Manager, Reactor Operations : !
L ; D. Dudziek, Nuclear Engineering Department Head
.
,
i
L
.L DuFour, instrument Maker
.K. - Kincaid, Chief of Reactor Maintenance '
C.' Mayo, Director,' Nuclear Reactor Program -
P. Perez, Associate Director, Nuclear Reactor Program
W Weaver, Manager, Nuclear Services l'
l , G. . Wicks, Reactor Health Physicist-
L
L ' Campus' Environmental Health and Safety Center
L-
!' TA. Armisto, Radiation Protection Supervisor
N. Couch, Campus Radiation Safety Officer
- ;
l W. Morgant Manager, Radiation Projects -
'
! T Public Safety Office-
f '
T. Wright l Assistant Director, Public Safety :
, -l
INSPECTION PROCEDURES USED .l
l~
'~
- IP 69001 . Class 11 Non-Power Reactors ' .
- lP.81401 : - ' Plans, Procedures, and Reviews !
IP 81402: Reports of Safeguards Events , l
-'
. IP 81431: : Fixed Site Physical Protection of Special Nuclear Material of Low Strategic ~
.
Significance
L IP 85102: Material Control and Accounting - Reactors
IP 86740: Inspection of Transportation Activities
ITEMS OPENED, CLOSED, AND DISCUSSED .
L Opened
50-297/98 201-01 'VIO Failure to met the intent of the TS and Special .
Procedure 2.1 to have changes to methods and/or !
i. acceptance criteria used to complete work reviewed and 'l
'
approved by the RPC.-
,
50-297/98-201-02- NCV Failure to' post a current copy of NRC Form 3 as required by
l' s 10 CFR 19.11.
L .. i
- Closed :
50 297/98-201-02 NCV Failure to post a current copy of NRC Form 3 as required by
!
l
-
p
-
, .. .
-
.g..
~
, - LIST OF ACRONYMS USED'
.ALARAL ' As low as reasonably achievable
, .CFR Code of Federal Regulations ;
HP. Health physics
.IP:
'
' Inspection Procedure
MW ' Megawatt ,
'.c-'
NCV. Non-Cited . Violation - .i
NRC' Nuclear Regulatory Commission j
1NRP Nuclear Reactor Program '
- NSIC . Nuclear Safety Information Center- . !
-NVLAP . National Voluntary Laboratory Accreditation Program i
PC . Procedure change'c ~ l
PDR- Public Document Room - I
~ PSP. Physical Security Plan I
'RHP Reactor Health Physicist . 1
RPC Radiation Protection Committee !
RPO. Radiation Protection Office i
.. RSAC Recctor Safety and Auditing Committee !
, RWP... Radiation Work Permit
SRO Senior Reactor Operator 3
TS- Technical Specification '
!
!
-
.i
,
!
!
l
!
!
,
\
l
J
r-
.
,
e:.-
4
L. . -
l
i- EXHIBIT I
l-
l- NORTH CAROLINA STATE UNIVERSITY
i
PULSTAR RESEARCH REACTOR FACILITY
l ' Docket No. 50-297 License No. R-120
I~
l
l . Material Balance for Period: October 1,1995 - September 30,1997
I'
'
Reporting identification Symbol: - ZPY Report Units: Grams
l High Enriched Uranium Plutonium
Element isotope Element Isotope
Beginning Inventory: 5 5 678 660
' (October 1,1995)
Receipts: l
l, Production: 0 0 24 24 a
l Material to Account for: 5 5 ZQ2 133
i . ,
Removals:
Shipments: 0 0 0 0
l Fission and
Transmutation: 0 0 0 0
l -.
l Inventory Difference: 0 0 0 0
-Decay: 0 0 0 ,
O
j' Total Removals: 0 0 0 0
l-
'
..
Ending inventory:
. (September 30,1997) 5' '5' _702 " ,,,,ggd* *
l l
l l
. !
- = Fission chambers- )
= Contained in the fuel and the licensee's PuBe sources l
l
!
-
.
i
r ,
..
?; e
l'
!
l-e .
. EXHIBIT ll
NORTH CAROLINA STATE UNIVERSITY
PULSTAR RESEARCH REACTOR FACILITY
Docket No. 50-297 License No. R 120
l
Material Balance for Period: October 1,1995 - September 30,-1997
Reporting identification Symbol: : ZPY , Report Units: Grams
Low Enriched Uranium -
, Element isotope
Beginning Inventory: 432,563- 16,567
(October 1,1995)
Receipts: 0 0
Material to Account for: 432.563 16.567
Removals: -
Shipments: 0 -0
Fission / transmutation: 0 0
Total Removals: -76 50
Ending inventory:
(September 30,1997) 432.487 16.517
i
u
'
.
- *
s
O
P N e p
N I
n T S i
t 9 S
C O v r
o s TI e R U
L
A T e
n c O p
i
t AT m e
p
I
T
.
M E
t e V e
c
l
e TE S o 8 E .S
S
h
o
d
u S t
i : UM e r
t R N N
u
e u r
e u o S q
T E A c
e g s n :
.
r P M l
h m P F N a - - -
O E e
b
a a r a o n a
t
h n m 6 o d U s R : r
c e d a 9 c u :
.
2 T R
k
f
y c y
r 0
0
e
d
r
e O ni t l
m
i
t N
N
o e
g
r r
o s e / 1 e t 1
0
t
a O t u
r o a C r o : 0 .
h l
a
l
C e :
m
e
t
e o h
a D C t
o
O t d m N v 1 a a r
D i u e U t
e 1 r y
E m n l o _
n" e m m _
i :
S e s b p i
t I
l
i
n C _
s e r c
c
t
r n r o
c 2
t
e B L U
a
o u t : :
a a S
n
t
a
c
t
i
o
s
S
e
d
u y
m
T s
s
e
s
t
3 2 1 N
I
T
t
a
t
W -
i
n C A r
e U p t N e =
n s o P s n e t a U
e
d " n S
L
P r
t
i
mL 5 n %
t
t
r
a F e 3 l eea i
v
c o u v : :
e
h
a t
r
y n
i
e V d 0 r
n a t c w l R si
g k
e o
,
t
i e e D t
y
e o
t
s
s t t
n d p - - - O
h h
e a a
l
o l
C
t
o e l
n O n
s 0 K
r
p e A
r
d
l
a
b
E
T P
m
e
l
a q e m
o
l
e O
c u a S 2 N
t
h e ri : n
r e RI n O W
o o e ll o v l I E
R
.
v e Ts :
d f m A Sp
s s
o
e
n C e
d
r
i
t e 9 OR
a ntc PE
I
a t y
n s 3 u b
l
m 0 s y L i
t o 7
d
/
e o e e
v 0 ir
a NC I
o
r
p
r
f
.
C
t
h e
l
s TN
o T o e l l
R S N OS
a c S :
E U E ,R P
c 3 d R U V E
c e 6 e a
l
B
p
e d
u
.
3
1 :
d
i 4
I
E M WFCUT
t r . a l W I
T EI
T LO
a e b t
P E
I
n s i
o R T
c .
a P C n S e D E E FAFN
e n u s D
T d l
o P o
pl l p B
c h o s r o Y B
r
i e l
e o e D n : Y SILI LL
t
e i
n
f
S D c t
e m
s
a
TO
r
i s p t
u c e b OY W
a t
n
l
e
t e
N &-
i l
u
r
u c l
O o t
c i r n N N O S C L U
s
e a N g r v r
a YVP
d
t
i
o
l .
C o g i E
n
P
r C o .
.
W- a -NS
t
o
l
o m
l
C ( Y
o s l
o R DS
nOT
3
c
e D de r
D = =
c
o w m 4
d = = o
e
r
d
u
- t
t
e
e
=
=
n DMRE
m e r
e e . t
pl
e
s i
n YNA
t
e
s A (I
m 2 eon cTF _
t
e t
r
.
,1 a s - Y aAS )
l
e c - aE
CtS N
_
w v t c E t N
o h o cai(F A ooE eT
r ei e r
npW
.k w E
d
a
nl l
N dR
)
_
_
e c n bi n O
t
i hI Y
d o c e t
. n
ur eT F
_
n e eeE
.
a s oh O _
_
n e w
be l
M R
d e i
t
t
aE S M
a
p
s
n h nA
i
?
p
r
a
d
T
S
eN
d
l
o e f
r .O
v c 6 oi
e .
d h
a 3
. mfo l
D D
A
b n b Ep A T
y g .
I e T E
t e Cm l- E
h s )
S n : :
e t g
R o a F
a v n e
di a
r *
l
b
r
a i
o E u
t
i
u ( E a N
o s 1
l
- r
v u
n h 1 i
t
l
cl
P e 0 e 4 e
r a
.
a
o l C m l 1 r
t
e h
t
h .
9 R
c p a 9 e
r
a T 8 a P
ti
c h ct A
o yh e
n si t
E o G
o.* r E
C c s A R
o s e
m M N g 1
a .O u
m )x l
ti a O
t
e
t
i F
e o
n 2
e
e
s
w
c N
O
n
I
s T S
TI
I
t
e
t
h
e
N i
n
s T S
TI
I
t
e
p
i
t AT m O p
i
t AT m
e
- V e V e
l f
e TE l
S
c
t
i
- UM S
e
a
c
i
S
c
t
i
e
T E
UM S
e
u o S q l
ti u o S q
n : .
y n : .
m P N ,
m 6 P F N
r s' r a
m o U .o u m 9 o
i
l
U .o
a c n :
c a 0 c u
r n :
r
y e t
i
l h r
y 0 e e C i
t l _
d a 1 d
/
C
o
u
r
e
1
l
s
e
/
C
o
u
r
e
t
o
o
1
- 0 -
m N n m N o
s 2
u U
t
r u t U
m m n l a m m n l
n
_
e e a _
b ti c b ti
_
_
n
I
n
I
e t
e e e c t
e
t :
r 2 s t :
r u
r
2
s :
m s r
m
- t
o
- e
S
T n T
U y c S t
U y _
A p o C A c p _
L n e n o P L o n e
P t
i
- t
r
n
t S P o
i
t :
l r y 3 l
F :3 ol a F :
u el r
y u o N -
. n d
,
n f
c l
t c N
l _
t
i a o ti
o r
e t o R C
n l
a h n C l
a s e a F
l
A
.
r
e
l
A o
r
V
r l T q r l
e h u e m-
a S e i
r a 3 S
e e :
e
v v
_
l
i
e c m e
r e e r
C t
i
n n C i
t
a y s t 3 a y
u e s 0 u
s L
e
e o s L
e
I
. e v s f e v
F
S
C e u 1
.
C e
o l
b o
l
D
s 0 3
- _
A
_
d e d _
e
l
q C 1
e l
T
_
_
u F
e R A .
l n ll
l E
1
S
t
yl 9 S N
C u .
P C u T
ol p p 1 l
o p R
s pl o ,1 s p Y
I
e e s l
e e
l
t t F
o m e h D c m O
u
t e d e t
u e R
n c l
n M
I
O
r
t u
r
ci l
O
r
t
N e N -
g
.
o
r
e n N g.
o C
n s
C C O
. .
- t e :
I
o l c e l
o l N
d
e p
o f
a D de 4
T
I
_
- i
e
i
l
e
N
,
s d
ll
U
t t
.
A
h o T
a p
I
! t O
o N
E w s E
cai(F A e
r
t
cai(F A
e a
nl l
N c nl l
N _
_
s u bi n
bni
e t O u r e O .
_
.
p r t
.
oh pl e oh _
be l n be l
_
_
t ei t t _
.
aE d c aE
nA
i
b o iA
n
e y p e .
dN l
y dN l
_
f
r .
O t
h o f
r .O
_
oi e f
oi
mfo l
i
n N mfo l
Ep s R Ep
I e p C l e
Cn - e F Cn -
Si c o Si
)
gn
l
t
o r ) n
g
l
a .r m- a
1 (
1 n l
3 1 n l
1
E' a 1
E'
0 E
t 0 E
C l' v C l
h i l a
r h i
'
l
a
r
t
e
i
o a
r
t
e
a u a m
c
t
.m l
l
s c
t
. l
l
e
r T
l
o e
r T
s h c s h
e a
t e
M
a E
i
o M
a E P
x A n x A a
) s } g
N i
n N e
.O O
.
2
o
_f
-
, 2
_
.