ML20237D281
Text
S
' \\,
s.
\\
i>NITED STATES 8
$g '
NUCLEARMOULATOPY COMW35 ION s
[
f w.omwoTow, n. c. mes
%......A t
APR 171986 f; '
MEMORANDbFOR Thomas & Murley, Regional Administrator, RI r
THRU:
James O Taylor, Director Officf(of Inspection and E ar ment FROM:
Edward L. Jordan, Directo g
\\
Division of hergency Preparedness and Engineering Response Office of Inspection and Enforcement
\\
p '.
It
(
o w
'i
SUBJECT:
SURVEY.S# LICENSEES FOR INTERFACE WITH THE EMERGENCY RESPONSE DATA SYSTEM 9
t The policy issue of how best to obtain data from stu: clear power facilities during emergencies was presented to the Commiss%n in SECY-84-481 (eng!osed).
The Commission approved the Emergency Response.0ata System (ERDS) option.
Briefly, the EROS design concept includes the following:
1.
Parameter inputs to ER0!/kuId be obtained from an existing comhuter f
system at the plant (e.g., SPDS, plant computer, EOF data systems, etc.).
2.
Data will be transr.itted to the NRC Operations Center via modem over a commercial telepholla 1tna or a dedicateo line maintained by NRC (e.g.,
ENS).
s 3.
AprocessingsystemmaintainedbytheNRCwillreceiv$thedatastreamvia modem. The system will be designed to receive all verted data streams and will reformat the data into a consistent format. The reformatted data will be outputted to.og appropriate video display and printer.
j m
4.
The parameter lis't wdaid include those necessary to ensure that appropri-ate action is being taken with respect to offsite recommendations. The-(,
1 list would be lim 3ted to those parameters involving plant status and 9"
radiological and met 4Wological conditions.
Licensees will h.' be required to backfit their systems' to include addi-
/
5.
S i tional paras.eters to match the NRC parameter list.
Data that is not 3
prailable from the electronic data stream can be provided by voice commu-
^
s I nication over ext. ting phone lines.
.h/
4 7
4 3
Contact:
J. B. Hickman, IE '
]
492-4155 y y; 9
i
)
8712230268 871210 J
a PDR FDIA n
i SHOLLYB7-737 PDR t3 O =g
- L.
-s ; _ L
.n.
Thomas E. Murley -
nU 6.
Th4 updating frequency of the licensees' systems will determine transmis-sion frequency to NRC.
If more frequent updates are required than those provided electronically by a xrticular liMnsee, the increased frequency will be accomplished (for e very limited subset of parameters) by voice I
communications over eW,tDg telephone lines.
L 7.
The licensr.e will have cenplete control over data transmission.
ERDS would be " witched on" by the licensee in the early stage of a declared emergency.
This data transmission concept has been presented to several licensees at AIF and other meetings, anc has t,een generally well receivad.
ERDS provides the potential for improving NRC response and coordination with licensees while hessening the burden on licensees in supplying data to NRC.
Two tests of the EWS concept have been conducted, with McGuire and LaSalle, and in both cases tyroversts in the quality of the assessmer,t and is tha reduction of verbal duta communications were noted.
At this point we are in the survey and daign phan of ERDS implementation.
A l
contract has been awarded to visit or coraact all sites, obtain information on the licensees data systems, and design tie ERCS system.
In order to accomplish this ef fort we will need some regional support to schedule the site visits.
Therefore, I am requesting that you send the enclosed letter to all licensees in ycur region by April 18, 1986, and designate an indi<1ctual as a contact
(']
foir.t to work with rrabers of :ny suff.
A n u ber of my staff will participate r
h each site visit ad will be respxutio?a for the interface of the contractor with tne licensee.
Your contact point should establish initial contact with the licensee, oVtain utility concurrence; for 'tht proposed visit, identify a ut.ility point of t.ontact, and provide the traditional " good guy" letter identi-fyfgg thr visitbg surveyor.
Questions of policy regarding ERDS should be directed to Ken Perkins at 492-7361. Questinns on planning the site visits snculd be directed to khn Hickman at 4924155.
cugiuj54n.3nyt
- z. O Jor M Edww d L. Jordan, Director Dfrision of Emergency Preparedness ano' Engineering Response Office of Inspection and Enforcement
Enclosures:
As stated Distribution:
DCS KPerkins EBr r:0.
DEPER R/F SSchwattz JPartlow IRB R/F EJorde BGrimes
)
<JHickman a RYolleer JAxelrad RPriebe JTaylcr
- See previous concurrence
- IRB:DEPER IE *IRB:DEPER: IE *IRB:DEPER:IE *DD:DEPER:IE R:IE i O JBHickman:nis RFPriebe KEPerkins SASchwartz ELJordan 4/04/86
' 4/10/86 4/10/86 4/1U36 4////86 0:
E D:IE JUaylor8 g 4e' 7
11mer 4 ({,36 4/g/86
\\
l
To Power Reactor Licensees O
This letter is to inform you of an emergency communications capability that the NRC is considering establishing with licensed nuclear power facilities and an upcoming site visit by an NRC contractor to obtain information on how such a system would interface with your facility.
The emergency communication capability being considered is called the Emergency Response Data System (ERDS).
The ERDS concept has been determined by the NRC l
to be a design which best addresses the requirements of the NRC with minimal impact on the licensee. The development of the ERDS concept began with an assessment of what is the NRC's role in an emergency at a licensed nuclear facility. The Commission determined that the NRC's primary role is one of monitoring the licensee to assure that appropriate recommendations are made with respect to offsite protective actions.
To fulfill this role the NRC requires accurate, timely data on four types of parameters:
(1) core and coolant system conditions must be known well enough to assess the extent or likelihood of core damage; (2) conditions inside the containment must be known well enough to assess the likelihood of its failure; (3) radioactivity release rates must be available promptly to assess the immediacy and degree of public danger; and (4) the data from the plant's meteorological tower is necessary to assess the distribution of potential or actual impact on the public.
A list of the particular parameters considered necessary to these assessments is included as Enclosure 1.
O experience with the voice-oniy emergency co-unications iink, currentiv uti-lized for data transmission, has demonstrated that excessive amounts of time are needed for the routine transmission of data and for verification or correc-tion of data that appear questionable.
Error rates have been excessive; initiations have been slow; frequency of updates have been unreliable.
In addition, the current system creates an excessive drain on the time of valuable experts at the NRC and at the facility. When errors occur, they frequently create false issues which, at best, divert experts from the real problems for serio'usly long periods of time.
At worst, incorrect data may cause the NRC to i
respond to offsite officials with inaccurate or outdated advice that results in l
the implementation of inappropriate protective actions.
Several options were considered for upgrading the data acquisition capabilities l
at the Operations Center. The options included various means of acquiring the data:
manually, automatically using existing systems, or automatically using new systems. Appropriate options for transmitting the data to the Operations Center were considered:
electronically formatted data, image "acsimile, or by voice through specially qtelified communicators.
The criteria used to compare these options involved accuracy, reliability, timeliness, completeness, cost (in dollars and expert personnel), and backfitting requirements.
The NRC determined that automatic transmission of selected parameters from licensees' existing electronic data systems is most capable of providing acceptably complete and reliable data on a timely basis at reasonable cost with the minimum potential for burdening licensees in an emergency. Most licensees either already have developed or are developing O
electronic data systems for their emergency response facilities (ERFs).
Because the role of the licensees' ERFs is similar to the role of the NRC during emergencies, the licensees' data systems already include most of the parameters desired by NRC. Those few parameters which are not included in any particular licensee's system can be communicated by voice over the Emergency
f Notification System (ENS), thus avoiding backfitting requirements on the licensee to include additional parameters on their electronic data systems.
Data would be accepted in whatever format the licensee uses and reformatted at r
the Operations Center, as necessary.
Because of the diversity of data systems 5
utilized by the licensees, the best means for extracting the NRC's parameters from each system would be determined on a case-by-case basis.
The licensees would have control over transmission and would use the system only during emergencies. This option is the Emergency Response Data System (ERDS).
The design concept for the ERDS is outlined in Enclosure 2.
Previous discussions with several licensees and two tests of the ERDS concept which were conducted with Duke Power and Commonwealth Edison have indicated that the ERDS concept has the potential to significantly improve the NRC incident response function and our response relationship with licensees.
Therefore, to determine more specifically the factors that would effect imple-mentation of an ERDS we have initiated an effort to survey the equipment and facilities at licensees' sites and determine the hardware and software require-ments of such a system.
You should designate an individual to act as a contact point for this effort and have that individual contact (fill in name of regional contact) of this office within the next two weeks.
A site visit by a NRC Headquarters staff member accompanied by a NRC contractor will be arranged.
The visit is an information gathering process.
It is oriented toward determi-nation of:
The availability of a particular set of PWR or BWR parameters in digital form.
O The verification and validation method, if any.
Characterization of the available data feed point (s).
Access will be needed to documentation and knowledgeable individuals typically from instrumentation and control, technical, telecommunications, and computer system cadres within the plant staff.
Further information on the parsonnel and information desired is provided in Enclosures 3, 4, and 5.
Should you have any questions on this site visit please contact (Fill in name and number of regional contact).
Should you have any question on the ERDS concept in general please contact Ken Perkins of the Incident Response Branch at NRC Headquarters.
He can be reached at 301-492-7361.
Sincerely, DivisionofReactorProjects O
J
m
[]}
PWR PARAMETER LISTS Primary Coolant Pressure System Temperatures - hot leg Temperatures - co?d leg Temperatures - core exit thermocouple Subcooling margin Pressurizer level RCS charging / makeup flow Reactor vessel. level (when available)
Reactor coolant flow Neutron flux - startup range Secondary Coolant Steam generator levels System Main feedwater flows Auxiliary / Emergency feedwater flows Safety Injection High pressure safety injection flows Low pressure safety injection flows Safety injection flows (Westinghouse)
Borated water storage tank level Containment Containment pressure Containment temperatures Hydrogen concentration Containment sump levels O
Radiation Monitoring Reactor coolant radioactivity System Containment radiation level Condenser air removal radiation level Effluent radiation monitors Process radiation monitor levels Meteorological Wind speed Wind direction Atmospheric stability =
O
BWR PARAMETER LISTS Reactor Coolant Reactor pressure O
svste-aeector vessei ievei Feedwater flow Neutron flux-Startup range Safety Injection RCIC flow HPCI/HPCS flow Core spray flow LPCI flow Condensate storage tank level Containment Drywell pressure Drywell temperature l
Hydrogen & 0xygen Concentration Drywell sump level Suppression pool temperature Suppression pool level Radiation Monitoring Reactor coolant radioactivity level Systems Primary containment radiation level Condenser off gas radiation levels Effluent radiation monitor Process radiation levels Meteorological Wind speed Wind direction Atmospheric stability 4
1 l
l l
i O
p i
4
EMERGENCY RESPONSE DATA SYSTEM (ERDS)
O DESIGN CONCEPT Data Acquisition Parameter inputs to ERDS would be obtained from an existing computer system (e.g. SPOS, plant computer, E0F data systems, etc.) at the plant.
Data Transmission DatawillbetransmittedtotheNRCOper5tionsCenterbymodemtocommer-cial telephone line or a dedicated line maintained by NRC (e.g. ENS).
Data Collection A processing system maintained by the NRC wiil receive the data stream by modem.
Thr. system will be designed to receive all varied data streams and to reformat the data into a consistent format.
The reformatted data will be output to CRTs and printer.
Parameter List The parameter list would include those parameters necessary to ensure that appropriate protective action is being taken with respect to offsite recommendations.
The list wou d be limited to those parameters involving plant status, radiological and meteorological conditions.
O ticensees will not be required to backfit their systems to include addi-tional parameters to provide data on NRC's parameter list.
Data that is not available from the electronic data stream can be provided by voice over existing phone lines.
Transmission Frequency T.he updating frequency of the licensees' systems will determine transmis-sion frequency to NRC.
If more frequent updates are required than thosa provided electronically by a particular licensee, the increased frequency will be accomplished (for a very limited subset of parameters) by voice over existing telephone lines.
Control The licensee will have complete control over data transmission.
EROS would be " switched on" by the licensee in the early stage of a declared emergency.
I$
(:)
PERSONNEL AND REFERENCE MATERIAL j
~
i It is recognized that the key disciplines necessary to support the ERDS survey will represent different departments and j
organizational relationships unique'to each utility surveyed (e. g., Corporate vs. Plant Site Engineering staff).
It is believed that most of the appropriate personnel will be the same as those on the project teams for SPDS and Emergency Response Facility Data Acquisition System development.
The appropriate utility nanager to coordinate the ERDS site
-l survey is likely to be the same individual who is responsible for SPDS, RGl.97 or. ERF upgrade programs.,
The approximate man-hours for each site survey are based on a 2 to 2 day survey for a single unit cite or a 2 unit site where both units are identical and a common Data Acquisition System has been installed at a common TSC or EOF.
Personnel Approximate Person or Discipline Man-Hours Required
)
ERDS Survey Coordinator 8 - 12 NSSS System Expert 4-6 Plant I&C Expert 2-4 Computer Hardware Expert (for ERDS signal source (s))
4-6 Computer Applications Expert 4-6 Emergency Planning Coordinator 1/7. - 1 l
Telecommunications Expert 2-4 Meteorologist or Environmental Engineer 1/2 - 1 Radiological Monitoring System Expert 1
RGl.97, RVL,IS, SMM Instrucent Expert 1
.o.
1
It is understood that many of the areas of expertise listed above may be represented by a single individual (e.g.,
One
/~T I&C engineer may be able to address instrument characteristics kJ and display conventions for RVLIS, SMM, Radiological, and Meteorological instruments).
Reference Material FSAR Any locally generated Plant Data Book (Compilation of System Design Data)
Systems Training Manuals Tables or graphs for engineering unit conversion (e.g.,
feet to gallons for containment sumps)
Data System Design documen,ts and block diagrams Hardcopy printouts of Data Acquisition System displays emU 2
- -- O
Ehn~c]ogueu o
}
JO l
k l
This attachment consists of three samples from the parameter-specific section of the ERDS survey instrument.
The three samples are as follows:
Generic Checklist:.This four page checklist is repeated i.
.for each of the 29 PWP, parameters and,25 BWR parameters.
Some questions in the checklist do not apply to every_
paraneter (e.g., questions on engineering unit = conversion factors would not be applicable to parameters such as IIot Leg Temperature which is always expressed in degrees Farenheit).-
j Parameter-Specific Checklist for Atmospheric Stability (applicable to both PWRs and BWRs).
Parameter-Specific Checklist for BWR Iow Pressure Coolant Injection Flow O
I L
.l l
O I
i GENERIC CHECKLIST:
1.
Is this parameter available as a digital signal at l
the-('s, preferred host location, the pickoff point determined in v
Appendix 1, Section 27 A.
If not, what is best alternative host location?
2.
At 'che host location, is this-parameter available as a processed signal (i.e. validated, averaged, range checked, etc.) or only as one or more unprocessed discrete signals?
3.
Describe the following attributes of the instruments supplying either the discrete data points or the inputs to the processed variable:
l A.
Sensor type?
B.
Instrument failure mode for:
1.
Loss of power (offsite & onsite AC, but static inverter battery systems survive); does the control room instrument display survive?):
2.
Instrument in test?
3.
If instrument is placed in test, does the preferred host location recognize instrument in test?
4 O
2
i i
C.
Number of ooporoto locatiens acnitored (i.e. loop 1, loop 2, loep 3, ote)?
()
1 f
i D.
How many ranges of instrumentation are provided for each location monitored?
(
E.
For each of these ranges, describe instrument range:
1
)
I j
F.
Reference point of each instrument range (e.g. BWR level; ref.
to bottom head or feedwater sparger or-steam l
separator shroud; PWR RVLIS; etc.)?
G.
Number of instruments within each range for each location monitored (e.g. PWR loop 2: Th; 2 NR & 1 WR etc.)?
4 I
H.
For those cases where data does not read out at the host l
location in final required units, what is the engineering
)
conversion factor for each range (i.e. tank level measured in feet, factor to convert to gallons)?
?
O 3
NOTE:
If convorcien facter 10 not c 010p10 censtcnt,.you cay requiro o copy of tha curvo. (For oxccple, in the coco of an irregularly shaped RWST tank where level data is provided in feet, you must obtain a copy of the tank
()
capacity curve to allow the ERDS system to convert to gallons).
levels Not applicable.
Conversion is a constant, value is:
Conversion is not a constant, curve attached.
Conversion is not a constant, not obtained.
curve not required or
{
1.
Engineering units for each range?
4.
If parameter is a processed value, describe the following attributes of how the above instrument inputs are processed to arrive at a single value:
A.
Does the processed variable take inputs from more than one instrument range?
1.
If yes, then describe method used to switch between ranges.
B.
Foz each range of the parameter available, identify the instruments whose signals are combined to provide the processed parameter?
l 1
4
C.
Dascribe the validotion ochsce usod for range chocking, error checking and cvoraging the input pareceters?
O A
l O
1 i
e O
5
PARAMETER: ATMOSPHERIC STABILITY
\\
SPECIFIC CHECKLIST:
1.
IF THE SITE EMPLOYS MORE THAN ONE METEOROLOGICAL' TOWER FOR REASONS OF TERRAIN (AS OPPOSED TO REDUNDANCY), THEN COLLECT THE DATA BELOW FOR BOTH TOWERS.
l
- 2. WHAT IS THE LOCATION OF EACH OF THE TOWERS WITH RESPECT TO THE PLANT POWER BLOCK?
)
l
- 3. WHAT IS THE HEIGHT OF THE LOWER TEMPERATURE DETECTOR?
1 4.
WHAT IS THE HEIGHT OF THE UPPER TEMPERATURE DETECTOR?
(
- 5. WHAT IS THE DISTANCE IN METERS BETWEEN THE LOWER AND UPPER TEMPERATURE DETECTORS?
k 6.
DOES THE HOST COMPUTER CONVERT THE DELTA T INTO A DEGREES CENTIGRADE PER 100 METERS VALUE?
i i
i 6
}
l
S@G0@MWU 8 i
' f"N 1
v OVERVIEW OF COMPUTER AND TELECOMMUNICATIONS SYSTEM INFORMATION NEEDS Computer Systens Related 1
The computer systems related portions of the survey instrument i
focus on the following general areas of investigation:
l l
Characterization of each utility computer system that is i
a potential data feeder to ERDS:
l its hardware and system sof tware environment its data communication technical details Characterization of the potential siting locations for NRC-provided hardware.
Characterization of the documentation available that describes the plant-specific details of the engineering i
evolution of a parameter value (as it-travels from a O
sensor through analog and digital logic and computer systems to a reactor operator's eyes).
)
Telephony-Related-The telephony-related portions of the survey instrument focus-on the following general areas of investigation:
Characterization of potential site-related engineering difficulties associated with the utility providing a dial-up phone line accessible to, and suitably configured for, the NRC-provided ERDS computer hardware.
Characterization of potential operating procedures for i
utility personnel creating and maintaining the dial-up phone connection between the site and NRC headquarters.
l l
l l
SPECIFIC CHECKLIST:
- 1. HOW MANY TRAINS OF RHR ARE AVAILABLE?
O
- 2. HOW MANY RHR PUMPS PER TRAIN?
- 3. WHAT IS THE DESIGN CAPACITY OF EACH RER PUMP?
i
- 4. WHAT IS THE SHUTOFF HEAD OF THE RER PUMPS?
-J
- 6. IS THE RHR SYSTEM SHARED WITH ANOTHER UNIT?
A.
IF So, DESCRIBE LINEUP?
i e
O 7
3/8 G '
4 a
I EMERGENCY RESPONSE DATA SYSTEM ( EROS)
System Concept:
The Emergency Response Data System. concept is a di rect el ect r oni c data line to the el ectroni c dat a streams of nucl ear power f acili ti es for use onl y duri ng emergenci es at the f aci li ti es. The data to be-t ransmi t ted woul d be a l i mi t ed set.most li kel y avail abl e on thei exi sti ng emergency dat a comput er s at~ t he si t es. NRC. woul d accept the data i n the f ormat and at the update. frequency most conveni ent to the li censee and the li censee woul d control acti vati on of the system.
Current Status:
An ERDS Requi rement s Anal ysi s i s currentl y i n progress pri mari l y bei ng conduct ed by a contractor. The contract i s expect ed t o extend t hrough 1986 wi t h compl et i on near the end of the year. fhe r equi rement s anal ysi s ef f ort consi st s of vi si t s to the li censees by NRC staff to reflect agency poli cy and by contractor staff to-det ermi ne the desi gn of the data systems on site and the avai l abi li t y of the data to be provi ded to the NRC. A system desi gn wi ll be N
devel oped as well as det ai l ed equi pment speci f i cat i ons and cost est i mat es. Several vi si t s have already t aken. pl ace, speci fi call y to Commonweal th Edi son and Northeast Ut i l i ti es. Si t e vi si ts are schedul ed f or si x licensees i n Regi on V and Two i n Regi on 11 during April.
Pr obl ems:
The scheduli ng of the si t e vi si t s wi t h t he licensees has proceeded sl ower than was ori gi nal l y ant i ci pat ed. Thi s has been due in part to di f fi cul ti es i n cont acti ng the appropri at e i ndi vi dual in the li censee's organi zati on and i n determi ni ng a mut uall y agr eeabl e t i me frame for the vi si t.
Now that the i ni ti al scheduli ng probl ems have been resol ved i t is anti ci pated that f uture vi si ts can be arranged whi l e the current ones are bei ng conduct ed. The t ot al del ay appears to have been about three months. Whether t hi s t i me can be made up duri ng the project has yet to be det ermi ned.
H
'I
,i e'
a l
Proj ect ed I mpl ement at i on:
.I i mpl ement at i on of the ERDS system is expected to begi n near the end of the current requi rements anal ysi s ef f ort. Although the requi r ement s anal ysi s wi l l more accuratel y determi ne the cost of.
i mpl ement ati on current esti mat es are:
Si te Costs: ( Based on 114 uni t s)
Total Hardware e $6. 5 K/ uni t 740 K Sof t ware a $21. 8 k/ uni t
$2,486 K Desi gn e $3. 2 K/ uni t 367 K.
I mpl ement at i on e $10.1 K/ uni t
$1,155 K Headquarters Costs:
Hardware 58 K Sof t ware 270 K Desi gn and I mpl ement at i on 395 K Total
$5,471-K O-O
m ~ - ~ -
'o UNITED STATES
!"3.,
g NUCLEAR REGULATORY COMMISSION g
WASHINGTON. O C. 20555 o
f W
0.....f
[
315 Bb (fy t
fEMORANDUM FOR: James M. Taylor, Director Office of Inspection and Enforcement FROM:
T. A. Rehm Assistant for Operations E00
SUBJECT:
IE 1986 FIRST QUARTER PROGRAM REVIEW The IE Prcgram Review meeting is scheduled for Tuesday, April 1,1986 at 9:00 a.m. in room 6507 MN8.
In addition to any issues you identify for this review, please be prepared to discuss any issues, problems or potential problems associated with:
1.
Discuss progress in the conduct of SALPs for major fuel fabrication facilities.
(Program Guidance III.1) 2.
Have any significant results or patterns developed in trending of'SALP reports?
p) 3.
What plans are being considered to apply the team inspection approach
(
)4 using the Davis-Besse Lessons Learned to more reactors (i.e., more than the three already conducted)? (Program Guidance III.1) 4.
Now that the Shoreham EP exercise has been held, what are the next steps? y g
Also discuss same for Seabrook.
(Program Guidance III.1)
Sc, idhat; progress isibe'isisideNiEODSN$d[$$liins@sgp h
6.
What progress is being made in providing EP licensing guidance to the regions?
7.
How are IE and NRR interfacing on the Safety System Outage Modification Inspections?
8.
What is being learned from the Vogtle Readiness Review Program? Are there any problems? What about the WNP-3 readiness review? When will
'[
program procedures be finalized and issued? (Program Guidance III.1 and IV.B.2) 9.
What progress is being made on the maintenance technictl integration f
plan? Any issues in developing plant performance indicators? How well is coordination working? Have specific responsibilities been established for each organization (e.g., NRC Manual Chapter 0143)?
0 60 / k r, r # o n g ?)(')
n L,<
/I*fy'5/(/h j
o
t,
O
- 10. What were the results of the regions survey of licensee actions for the additional three INP0 SOERs? (Program Guidance 111.15) 11.
Summarize progress in the development of GIMs to satisfy IE needs jp regarding the tracking of plant specific implementation and verification inspection? (Program Guidance IV.A.4)
(12.
How is IE incorporating the results of the RES nuclear plant aging research program in the formulation of the NRC activities for restart of construction at deferred plants?
- 13. What were the results of discussions with INP0 and NUMARC on Fitness for
[
Duty.
14.
Progress on important to safety rulemaking.
T. A. Rehm-Assistant for Operations, ED0 cc:
V. Stello J. W. Roe O-J. Sniezek
- 8. Capra P. Rabideau M. Federline J. Blaha E00 Office Directors
's l
1 0-
.