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| {{Adams | | {{Adams |
| | number = ML20195C861 | | | number = ML20207G607 |
| | issue date = 06/07/1988 | | | issue date = 08/16/1988 |
| | title = Insp Repts 50-369/88-13 & 50-370/88-13 on 880502-06.One Violation & Two Unresolved Items Noted.Major Areas Inspected:Nrc Diagnostic Evaluation Team Rept Findings & Action on Previous Insp Findings | | | title = Ack Receipt of 880708 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-369/88-13 & 50-370/88-13.Addl Comments Re Calibr of Stopwatches Considered as Minor Part of Violation Listed |
| | author name = Blake J, Girard E | | | author name = Herdt A |
| | author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) | | | author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| | addressee name = | | | addressee name = Tucker H |
| | addressee affiliation = | | | addressee affiliation = DUKE POWER CO. |
| | docket = 05000369, 05000370 | | | docket = 05000369, 05000370 |
| | license number = | | | license number = |
| | contact person = | | | contact person = |
| | document report number = 50-369-88-13, 50-370-88-13, NUDOCS 8806220300 | | | document report number = NUDOCS 8808240177 |
| | package number = ML20195C836
| | | document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE |
| | document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS | | | page count = 1 |
| | page count = 10 | |
| }} | | }} |
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| {{#Wiki_filter:UNITED STATES | | {{#Wiki_filter:- |
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| | AUG 16198B Duke Power Company ATTN: Mr. H. B. Tucker, Vice President Nuclear Production Department 422 South Church Street Charlotte, NC 28242 Gentlemen: |
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| | SUBJECT: REPORT NOS. 50-369/88-13 AND 50-370/88-13 Thank you for your response of July, 8, 1988, to our Notice of Violation issued on June 9,1988, concerning activities conductea at your McG' ire facilit We have evaluated your response and found that it meets the requirements of 10 CFR 2.201. We will examine the implementation of your corrective actions during future inspection While we accept your response, there are some additional comments we would like to make concerning the calibration of stopwatches, which we considered a minor part of the violatio There is no question that in most instances human error will greatly exceed any inaccuracy produced by a stopwatc However, it is our understanding that as stopwatch batteries near depletion inaccuracy may become much larger than you repor It is for this reason that our citation referred to your failure to have the watches checked or maintained to preclude battery depletion rather than simply questioning the lack of any calibration. Periodic calibration is an acceptable means of assuring. stopwatches are adequately checked and maintaine We appreciate your cooperation in this matte |
| NUCLEAR REGULATORY COMMisslON g^
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| O\ REGION 11 hs
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| ~t 101 MARIETT A STREET, ATLANTA, GEORGI A 30323
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| Report Nos.: 50-369/88-13 and 50-370/88-13 Licensee: Duke Power Company 422 South Church Street Charlotte, NC 28242 Docket Nos.: 50-369 and 50-370 License Nos.: NPF-9 and NPF-17 Facility Name: McGuire : and 2 Inspection Conducted: May 2-6, 1988 Inspector: [~
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| E. H. Girard~ Date Signed Approved by: _/ v d GO J laRs, Chief D6te' Signed at ials and Processes Jection i sion of Reactor Safety SUNMARY Scope: This routine, unannounced inspection was conducted on site and at the corporate offices in the areas of NRC Diagnostic Evaluation Team Report findings and action on previous inspection finding Results: The inspector observed that the licensee's Performance Group was relatively unresponsive to NRC inspector identified concern Repeated questioning was required to obtain information needed to determine that procedures and hardware performed properl Examples of this unresponsiveness are described in Paragraphs 3.a, 3.c and One violation was identified involving inadequacies in the licensee's methods of measuring stroke times, (Paragraph 3.d). Two new unresolved items were identified based on information described in a NRC Diagnostic Evaluation completed early in 1988. The unresolved items involve apparent deficiencies in ,
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| the licensee's inservice testing program for pumps and valves (Paragraph 2.b) l and their failure to provide testing for many safety-related relief valves (Paragraph 2.b).
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| | Sincerely, 8808240177 880816' |
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| | PDR ADOCK 05000369 O PNU Alan R. Herdt, Chief-Engineering Branch Division of Reactor Safety cc: T. L. McConnell, Station Manager : |
| j 8806220300 880609 PDR ADOCK0500g9 j O
| | Senior Resident Inspector - Catawba bec: NRC Resident Inspector DRS, Technical Assistant ; |
| | | D. Hood, NRR Document Control Desk State of South Carolina __ |
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| | EGirard:sh la e ehles 08/fl/88 ,/ 8/ Ige/88 08//d/88 IU XfoI |
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| REPORT DETAILS a
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| i Persons Contacted Licensee Employees
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| * Atherton, Production Specialist III, Compliance, McGuire Nu Station (MNS)
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| T. Cook, Mechanical Maintenance, MNS - .
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| D. Gabriel, Technical System Manager, Nuclear Production Department (NPD)
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| : G. Gilbert, Assistant to Station Manager, MNS | |
| *B. Hamilton, Superintendent of Technical Services, MNS S. Hart, Mechanical Maintenance Engineering, NPD !
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| *T. McConnel, Station Manager, MNS
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| *S. Morales, Associate Engineer, Performance, MNS B. Nardoci, Licensing Engineer J. Oswald, Lead Engineer, Performance, MNS R. Pierce, General Supervisor - Unit 1. Instrumentation and Electrical, MNS W. Rixson, Corporate Manager of Project Control
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| *D. Smith, Test Engineer, Performance, MNS
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| *J. Snyder, Performance Engineer, Performance, MNS NPC Resident Inspector j
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| * Orders, Senior Resident Inspector
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| * Attended exit interview NRC Diagnostic Evaluation Team Report Findings (92701) Units 1 and 2 This inspection initiates Region II followup of the NRC diagnostic evaluation of licensee performance for McGuire Nuclear Statio The diagnostic evaluation referred to was conducted between November 1987 and January 1988 and a report of the evaluation was transmitted to the
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| iicensee in a letter dated April 8, 1988. The report describes strengths I
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| and deficiencies identified in the licensee's performanc The NRC l transmittal letter requested the licensee to provide a written response to the report.
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| l In the current NRC inspection the inspector examined the status of the j licensee's preparation of a written response and of their corrective
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| actions for the more important of the reported deficiencies: Status of Written Licensee Response i The inspector ascertained that the licensee had selected a nine-man corporate team to prepare a written response to the NRC diagnostic l
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| evaluation repor The licensee's team was headed by the corporate Manager of Project Control and the McGuire site was represented by ,
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| 1 the Assistant to the Station Manager. The inspector interviewed both of these individuals and obtained the following status information:
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| - Each member of the team had been provided a copy of the inspection repor The NRC had not specified a date for response submittal and, as yet, none had been set by the licensee. It was expected that a schedule might be determined at the next team meeting, which wa '
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| scheduled for May 12, 1988
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| - The site was preparing a preliminary response addressing the deficiencies described in the NRC repor ,
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| b. Status of Corrective Actions An NRC management review of the diagnostic evaluation determined that two of the areas of deficiency identified recuired partir Sar attention in Regional inspection Those deficiencies involved
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| inadequacies in the licensee's ASME Section XI inservice testing (IST) program for pumps and valves and the licensee's failure to require periodic testing of any of their safety-related relief valves other than main steam and pressurizer relief va';ves. The inspector discussed these deficiencies with licensee management and was provided the following information:
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| Section 3.3.3.1 of the NRC Diagnostic Evaluation Report
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| described IST program check valve testing deficiencie These
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| : deficiencies are referred to in Licensee Event Report 369/88-33-01 (4/18/88). The inspector questioned licensee test ;
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| j! and engineering personnel regarding specific actions taken t
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| relative to this matter and received the following information:
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| Procedures for forward and reverse testing check valves 1SA-5, 2SA-5, 1SA-6 and 2SA-6 had been or were being set up as described in Problem Investigation Report 0-M87-0301A (copy reviewed by inspector).
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| I Licensee engineering personnel had completed an . interim , | |
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| review of their IST of check valves as documented in l Memorandum MBME-88-066 (3/4/88). Initially, 60 check
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| valves per unit (120 total) were identified as requiring .
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| further review to determine whether closure testing was l required. As described in the memorandum,14 of the 60 )
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| were determined to required closure testing and closure i testing was recommended (but stated "not required") for
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| , another approximately 30 valve ,
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| Licensee personnel stated that their IST program had been corrected to include additional required check valve testing and that their new program would be mailed to the
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| 'NRC for review on May 6, 198 Section 3.3.3.1 of the NRC report also indicated that Auxiliary Feedwater System valves CA-1 through CA-6 appeared to have been : | |
| erroneously omitted from the licensee's IST program. Licensee Performance personnel informed the NRC inspector that these valves were not required to be in the IST program and that they thought that the matter of these valves had been resolved to the satisfaction of the NRC team who performed the diagnostic q
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| inspectio Section 3.3.3.2 of the NRC report, in part, noted conflicts between manual and Operator Aid Computer methods used by the licensee in stroke timing valve This matter had been previously identified by Region II and its resolution is described in Paragraph 3, belo Section 3.3.3.4 of the NRC report noted that the licensee had used an IST program relief request before its approval, which is contrary to the requirements of Technical Specification 4.0.5.a.. The request provided for a change from quarterly to cold shutdown testing of two valves. Licensee personnel noted that the applicable ASME requirements permitted the use of cold
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| shutdown testing when valves could not be tested quarterly. It
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| is the NRC inspector's understanding that NRC reviewers currently do not require licensee's to submit relief requests to j change from quarterly testing of valves to cold shutdown testing g a when there is an adequate basis. Instead, the reviewers require -
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| j that justification for cold shutdown testing be provided in the licensee's IST program for their review and evaluation. If this ,
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| is the case, the licensee's failure to submit a relief request for the cold shutdown testing may not represent a deficienc Section 3.3.3.6 of the NRC report stated that the licensee testing was deficient in that they required no routine testing for safety-related relief valves other than main steam and l pressurizer relief valve The report also indicated that
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| during the diagnostic evaluation the licensee had committed to
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| develop a testing program for safety-related relief valve '
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| On-site licensee management indicated they were unaware of a commitmen However, licensee Perfonnance personnel informed the inspector that it was their understanding that a relief ;
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| valve testing program would be developed by October 198 j 1 ;
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| j The inspector informed the licensee that the IST program deficiencies described in the NRC diagnostic evaluation report represented a '
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| I possible violation of NRC requirements but that, pending an NRC review of their response and an assessment of the safety significance, it would ' be identified as unresolved item 369, 370/88-13-01, IST Program Deficiencies. The matter of relief valve testing was r,imilarly designated as an unresolved item and was identified 369, 370/88-13-02, Relief Valve Testin The NRC requirements applicable to testing of safety-related valves will be reviewed aloag with the licensee's response in determining whether the matter represents a violatio The inspector informed the licensee that, while the perceived deficiencies in their IST program and relief valve testing were considered of primary importance, other weaknesses and deficiencies described in the diagnostic report could represent potential enforcement items and should not be neglecte These other matters will t,e examined by Region II in subsequent routine inspection . Actiun 'on Previous Inspection Findings (Closed) Unresolved Item (369, 379/86-26-08): Written Criteria for Evaluation of Erratic Valve Action This item identified the inspector's concern that the licensee had no written criteria covering their evaluation of valve test information for identification of erratic or abnormal valve action. The licensee has a compilation of valve stroke time data accessible through computer, which they state is used to aid in identifying erratic or abnormal valve operation from stroke time testing. The identifi-cation and reporting of erratic or abnormal valve operation is required by ASME Section XI (80W80), which is the applicable Code for the licensee's valve testing progra The licensee's Performance Test Engineer had previously informed the NRC inspector that written criteria covering the use of the computer valve data base was in preparation and would be completed by the end of 1987. This date was not met and the inspector brought the matter to the Station Manager's attention or January 8, 1988, As stated in NRC Inspection Report No. 50-369, 370/88-01, the Station Manager requested Performance personnel to prepare procedural changes to resolve the inspector's concern within two month In the current inspection the NRC inspector questioned the licensee Performance Test Engineer regarding their action on this matter. The inspector was provided an untitled draft Performance Directive which he understood was to be implemented shortly. Four months had passed since Inspection 369,370/88-01 and the licensee still had no approved criteria ~1 dressing the inspector's concern The inspector reviewed the subject Performance Directive and found that it appeared to address most of his previourly stated concerns
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| with one significant exception - it did not appear to contain adequately based criteria for establishing when changes in valve stroke time were deemed large enough to consider abnormal. The applicable Code does not define abnormal and the licensee has elected to use proposed Code limits beyond which increased testing frequency is specified. Based on a licensee relief request, the limits would not apply to valves with stroke times of five seconds of less. The Performance Test Engineer stated that the limits will be re-evaluated later this year and changed if determined necessary. In addition, other licensee engineering personnel infonned the inspector that they are participating in an Electric Power Research Institute sponsored review that will examine stroke timing criteria specified by the Cod While the inspector still has concerns regarding the adequacy of licensee action in this matter, he is satisfied that these will be addrested in subsequent routine NRC inspection of the licensee's valve testing program. The original item is considered close (Closed) Unresolved Item (369, 370/87-16-01): IST Program Requirements for PORVs and Block Valve This item expressed concern that the licensee did not provide for complete ASME Section XI testing of both power operated relief valves and block valves in their inservice testing progra The inspector discussed the matter with responsible licensee personnel and is satisfied that the required testing is-provided for in the licensee's IST program. The program was found to be in preparation for submittal to the NRC in a May 6,1988 mailing. On this basis, the item is considered close (Closed) Unresolved Item (369, 370/87-16-02): Bases for Setting Maximum Stroke Time This item expressed concern that the licensee had not used adequate bases in setting maximum stroke times. ASME Section XI requires the licensee to set valve stroke time limits but does not state how the limits are to be determined. The licensee apparently elected to use TS and system requirements (only) in setting the limits. As a consequence, the limits they specify are often greatly in excess of times representative of valve failur Although the inspector provided the licensee with NRC criteria for determining maximum stroke times during Inspection Report No. 50-369, 370/87-16, the Performance Test Engineer indicated that no action had been taken on this matter as ye "
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| The NRC reviewer responsible for evaluation of the licensee's IST program informed the inspector that this matter would be addressed in the evaluation. The inspector understands this evaluation is to begin shortly. Therefore, the NRC inspector considers it unnecessary for him to address this item further. The item is hereby close _ _ . , _ - _ _ . - .. . .
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| " (Closed) Unresolved Item (370/87-37-01): Valve Failed to Operat ;
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| This item identified concerns with regard to the valve stroke timing, r As of the last NRC inspection of this item, the concerns requiring resolution were as follows:
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| (1) Although valve 2RN-231 apparently failed to indicate the correct movement to open in its first actuation during testing, the licensee considered that the valve performed acceptably. The Performance Test Engineer stated that this type a valve had a history of not tripping the second limit switch. A Work Request (WR) was issued to check the valve within two weeks. The NRC inspector questioned whether that long a delay in verifying correct valve operation was acceptable. The Unit was operating in Mode 1 at the time of-the test and the valve in question was
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| the decay heat removal pump 28 cooler isolation valv The inspector has since reviewed the completed WR and found that l
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| it only states ; hat the valve was cycled five or six times and
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| .i functioned properly.
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| I (2) TS 4.0.5 requires inservice testing in accordance with ASME ;
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| , Section X The testing specified by Section XI includes :
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| periodic stroke timing of power operated valves and comparison of each time obtained with the previous value. When changes are ,
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| observed that exceed specified limits Section XI requires ;
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| actions, such as increased test frequency, to aid in assuring valve operabilit For example, test frequency must be
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| increased or corrective action taken if a valve with a stroke time over 10 seconds experiences a stroke time increase (from i the previous test) of 25% or mor )
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| By implication, stroke time tests must be performed in a manner l which assures that times obtained for comparison are not unduly t affected by changes in measurenent method or timing device i inaccurac Licensee procedures for nuclear service
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| water system valves)(e.g. , PT/1 or 2/A/4403/02 permitted the use of c computer was unavailable) stopwatches for stroke timing. For a given valve, computer and stopwatch obtained times may differ i up to approximately 10% because the computer and stopwatch 1 measurements may be terminated at indications from different ,
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| valve limit switches. According to licensee personnel, the l locations of these limit switches may differ by up to 10% of l Jl
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| valve disc travel (or about 10% of stroke time). The licensee
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| ) did not account for this error in their procedures or practice l 1 As a consequence, when timing methods were changed licensee j 4'
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| determinations of stroke time changes could have been up to 10% !
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| 7 in error and the need for actions required by Section XI could
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| have gone unrecognized. It should be noted that (according to licensee personnel) the limit switches referred to have a maximum 10% difference for a given valve and the influence on stroke time measurement may be significant less than 10% if the switches are close together. In an example observed by the inspector, valve 2RN-279 stroked in 50.0 seconds per 0AC and 54.3 seconds per stopwatch, a 4.3 seconds or 8.6% dif ferenc (3) The licensee did not calibrate or otherwise provide assurance that the accuracy of the stopwatches used for stroke timing was maintaine With regard to (1) above, at the end of NRC Inspection 369,370/87-37, the licensee agreed to provide the NRC inspector with data supporting their contention that valves like 2RN-231 had a history of not trippino the second limit switch. The inspector requested the data at the beginning of Inspection Report No. 369, 370/87-40 but it was never provide The NRC inspector again asked for the data during Inspection 369, 370/88-01 but it was not provided and the inspector comented adversely on the licensee's responsiveness during the exit meeting. When the inspector requested infonnation relative to (1)
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| during the current inspection, the Performance Test Engineer provided him a typed statement that indicated there had been problems with limit switches tripping and properly indicating on the subject type of valve (the statement neither provided or referenced supporting records), described valve operation with reference to an attached but illegible circuit drawing, and stated the valve was scheduled to be replaced (replacement documentation was referenced). The data was inadequat Subsequently, the inspector discussed the valve further with Instrumentation and Electrical Maintenance personnel. The valve and a legible copy of the circuit drawing were reviewed during the discussion and similar hardware was examined. On the basis of this information the inspector was satisfied that valve 2RN231 had operated properly, except for indication, and since it was to be replaced there was no further need for concer With regard to (2) above, the inspe:: tor was informed that tests were being conducted to establish the difference between 0AC and stopwatch stroke times for each valve for which both timing methods were permitte With regard to (3), the inspector was informed that requirements to assure maintenance of stopwatch accurey had been institute (2) and (3) above are considered to represent deficiencies in the licensee's program for inservice testing valves, in that the licensee had not assured that changes in valves stroke times exceeding TS or Code limits could be recognize This represents noncompliance with
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| TS 4.0.5 requirements for conformance with' ASME Code Section XI and is identified as Violation 369, 370/88-13-03, Stroke Timing i
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| Deficiencies.
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| f The original unresolved item is considered close ;
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| ! (Closed) Inspector Followup Item (369, 370/87-16-03): Methods of '
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| Stroke Timing.
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| This item was identified for followup verification that the licensee had completed procedural changes to assure that valve stroke timing would be started with switch actuation. The inspector discussed this i matter with responsible licensee personnel and was informed that the procedural changes were completed. Further NRC verification will be accomplished in routine inspections. This matter is considered closed, (Closed) Inspector Followup Item (370/86-14-03): Verification of '
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| Snubber Test by Qualified Personnel.
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| Data relative to this item has been previously reviewed as described ]
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| i in NRC Inspection Report No. 369, 370/87-16. During the current I inspection the inspector discussed the matter with responsible i licensee personnel and determined that the item should be closed, l
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| , Exit Interview
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| . The inspection scope and findings were summarized on May 6,1988, with those persons indicated in Paragraph I above. The inspector described the areas inspected and discussed in detail the inspection findings listed below. Dissenting comments were not received from the license Item Number Status Title / Reference Paragraph
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| 369, 370/88-13-01 Open Unresolved Item - IST program
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| (Paragraph 2)
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| ; 369, 370/88-13-02 Open Unresolved Item - Relief j Valve testing (Paragraph 2) !
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| ! 369, 370/88-13-03 Open Violation - Stroke timing 1 deficiencies (Paragraph 3.d)
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| 369, 370/86-26-08 Closed Unresolved Item - Written criteria for evaluation of
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| erratic valve action
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| ! (Paragraph 3.a.) l l 369, 370/87-16-01 Closed Unresolved Item - IST program requirements for l PORVs and block valves i j (Farcgraph3.b.)
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| i 369,370/87-16-02 Closed Unresolved Item - Bases fnr
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| setting maximum stroke times 1 (Paragraph 3.c.)
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| 369, 370/87-16-03 Closed Inspector Followup Item -
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| Methods of str;- 'iming (Paragraph 3.e)
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| 370/87-37-01 Closed Unresolved Item - Vu >
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| failed to operate (Par .7 1 3.d.)
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| 370/86-14-03 Closed Inspector Followup Itt Verification of snubber Test by qualified personnel (Paragraph 3,f.)
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| Proprietary information is not contained in this repor i
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