ML20138P452
| ML20138P452 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak, 05000000 |
| Issue date: | 08/03/1984 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20138M609 | List:
|
| References | |
| FOIA-85-59 NUDOCS 8511070156 | |
| Download: ML20138P452 (23) | |
Text
,
I W ALLEGATIONS CONCERNING COMANCHE PEAK PROTECTIVE C0ATINGS d/3B0 It is alleged that the Comanche Peak coatings systems are not DBA qualified. Here are some examples:
- 1. Paragraph 4.3.1.2 of Procedure Number CCP-40 states " Imperial coatings may be applied in the following sequential order: #115/1201/11S/1201 or 11S/1201/11/1201." Imperial letter dated May 8,1978, VBR 7697 to Mr.
Kelly Williams, second paragraph, states: "Although the resu' tant systems
- 11S/1201/11S/1201or.j115/1201/11/1201 have not been qualification tes-ted, there is no reason to believe that they are not viabie systems."
Thus these two systems have not been DBA qualified. -
- 2. Specific sequencing of coatings for systems are not required. For ex-ample, NRC No. C83-01752 dated 6/23/83, Disposition section, first para-graph, states: " Table A2 in Appendix A of AS 31 specifies acceptable coat-ing systens, i.e., primer and final coat product identification and vendors." It then goes on to say that full sequencing is not identified.
"This table does not identify full system sequencing or application para-meters. Does a system's sequencing change for a repair? Why? Has the repai" sequence been DBA qualified?
-4. OCA, No.17,142, Rev. 2, allows Carboline 305 to be applied over another manufacturer's epoxy coating. Has this systent'been DBA qualified?
- 4. DCA, No. 12, 374, Rev. 1, allows incrganic zinc primer (Carboline CZ-11) to be top coated by Imperial 1201. Has this system been DBA qualified?
- 5. Procedure No. CCP-30A, Rev. 2, pige 2 of 13, paragraph 1.3.1 allows the
- application of Carboline 305 ove the primer Dimetcote 6 by Ameron. Has this system been DBA qualified?
- 6. Procedure No. CCP-40, Rev. 5, pale 5 of 13, paragraph 4.1.1.3 states: "Re-i pair of embedded foreign objects such as nails, rebar chairs, bolts, wood, or plastic shall be repaired per the fol, lowing guidelines before ap-plication of NUTECH 115 surfacer." Have these systems been DBA qualified?
B511070156 851016 PDR FOIA bM-~ I )
CARDE85-59 PDR V
hl
ALLEGATIONS CONCERNING COMANCHE PEAK PROTECTIVE C0ATINGS NOTE: Allegations 1 through 6 are concerned with the protective coating sys-tems not being qualified, for example for environmental (irradiation) con-ditions and DBA conditions, under ANSI 101.2-1972. (See letter to Doyle Hun-nicutt from V. Lettieri dated January 16,1984.)
- 7. NCR No. C83-01986 discusses the cracking and flaking of concrete coatings systems (NUTEC 11,115,1201). The disposition section of this NCR states " cracking of coatings is due to excessive stresses in the coating during drying and curing." The allegation is that repairing these cracks ~
will not remedy the condition which caused the cracks. .
Paragraph 4.1.3 of Procedure Number CCP-30, Rev. 11, states: ... shadows
- 8. ~
or tight residue of primer wnich may remain in the profi1e of the previously prepared substrate is acceptable." The allegation questions the integrity of an inorganic zinc primer which has been applied over a steel substrate with metallic zinc residue in the profile of the steel.
The concern is that there will be coating adhesion problems, and that the zine is isolated from the carbon steel sub3trate; thus the necessary galvanic action will fail to occur.
- 9. It is alleged that three coats of inorganic zi,nc primer have been applied at Comanche Peak to obtain the required dry film thickness. Paragraph 3.2.4 of Instruction Number QI-QP-11.4.5, Rev. 27, states: "Only two (2) overcoats shall be applied." It is alleged that this system would lack chemical attraction or intercoat adhesion with itself. Is this three coat primer system qualified, for example for environmental (irradiation) conditions and DBA conditions, under ANSI N101.2-19727 This is another example of the coatings systems not being qualifled.
'~
s-
- 10. _ Paragraph 3.2.2.3 of Instruction Number QI-QP-11.4-5, Rev. 27, page,8 of 27 states: " Surfaces that have been power tooled with '3M Clean-N-
~
Strip,' 80 grit or coarser ' flapper wheels,' sanding discs, ' roto peans,'
or equivalent to provide acceptable surface profile. It has been alleged that:
- a. The coating system applied to surfaces prepared using the above specified power tool methods are not qualified, for example for en-vironmental (irradiation) conditions and DBA conditions under ANSI N101.2-1972. <
~
b'. The above mentioned methods provide a smoothing or pnlishing action, rather than a penetrating action as obtained with sandblasting or with a needle gun. ,.
- c. The profile that is obtained using the above-mentioned methods occurs in a sparse pattern and not a densely packed pattern.
- 11. It is alleged that UCA Ho.18, 489, Rev.1, allows a primer thickness of 0.5 mils. If this is so, is a coating system having a primer coat of 0.5 mil thickness qualified, for example for. environmental (irradiaticn) con-ditforis and DBA conditions, under ANS1 101,2-1972?
- 12. If maximum limits are used, paragraph 4.3.1.2 of Procedure Number CCP-40, Rev. 5., allows a 102 mil thick coating system for 115/1201/11S/1201.
Is this system thickness qualified, for example for environmental (ir-
- radiation) conditions and DBA conditions, under ANSI 101.2-19727
- 13. .It is alleged that the coatings applied to areas such as the reactor core cavity will not maintain their integrity due to neutron and gamma ex- .
posure. It is further alleged that water and flaked-off paint will flow out of the reactor core cavity in the case of a LOCA. Are the coating systems applied to these area qualified under ANSI 101.2-1972, especially for environmental and DBA conditions? Wnich areas are qualified and which areas are not? If coatings in the cavity will come off with ir-
, radiation, will this cause a problem post-LOCA?
9
- o. . .
-14. a. It has been alleged that after a NCR is written, anyone can sign off on it.
- b. It has been alleged that NCRs cannot be written, and that irs must be written with "unsats." It is alleged that NCRs must be dispositioned by an engineer, while irs can be dispositioned by anyone. What prevents items identified on an IR from becaning lost, the problem not being resolved, or generic items not being identified?
- c. . *** ADDED 7/31/84 ***
It is alleged that a past QC Supervisor voided many 's. .
wa ;p
- 15. a. It is alleged that Paragraph 4.4.3.0 of Procedure Number CCP-30, Rev. ~
11, allows CZ-11 or Carboline 191 to be applied over existing Pheno-line 305 topcoat and left intact.,,without sanding back to a " mottled" transition. ' '
- b. It is also. alleged that this paragraph allows Pnenoline 305 to be ap-plied over Reactic 1201 and vice-versa.
Are these coating systems qualifted, for example for environmental and 08A conditions, under ANSI 101.2-1972?
- 16. As a result of numerous allegations regarding improper pressure bethg ap-plied to QC inspectors, NRC Office of Investigations has written violations in this area and proposed two civil _ penalties. Are there any coating material deficiencies in the plant resulting from the improper -
pressure applied to QC inspectors (e.g., pressure not to write unsat re-ports or NCRs, threats to lose job, use of verbal instructions to QC inspectors vs. written instructions, lack of support from QC management in technical disputes with construction, confusing instructions which do ,,
not support unsats, such as QI-QP-11, 4-5, Rev. 27, page 5 of 27, Note 4
'andpage19of27 paragraph 3.7.5.b).
17 It is alleged that the " air acceptability test" results are invalid be-cause cigarette butts are placed into the cheater valve of the spray gun prior to the test 'and removed after the test. ' Further, it is alleged that construction and QC management was aware of this practice.
f
..- D Note: For Allegations 1 tnrough 17 see inspection report 50-445/84-03; 50-446/84-01, Attachment 1.
- 18. It is alleged that QC inspectors are not allowed to identify visual de-fects such as cracking or blistering during backfit inspections.
I i
- 19. It is alleged that Instruction Number QI-QP-11.4-23 and QI-QP-11.4-24 are very vague regarding the way the backfit inspections are to be conducted.
1 20. It is alleged that adhesion testing of the protective coatings are not performed properly. The QC inspectors are instructed not to cut around
{ the adhesion test dollies when conducting adhesion te.sts. - The
- instructions that come with the machine tell you to do so (and Specifica-tion AS-31 references these instructions).
- 21. It is alleged that Brown & Root is doing the calibration on these adhesion testers, and they are not using a corrected value curve (which should have been supplied with each unit).
) ings with adhesion testers without receiving formal training.
I, 23. It is alleged that the Coatings QC Program at CPSES is inferior to the i same programs at other nuclear power plant projects. One reason is that standard inspection practices, used at other sites, are not used at CPSES.
! For example, a sample adhesion test used by a QC inspector regularly at another site, was not allowed at CPSES by one of the QC lead men. This is the ASTM tape adhesion test.
- i i
e V
s
..w_. . . ., , - . , . , - , - - , , , ,- , , _ , ,m- ,-m. .~, -y-,-_-,_,.~#_me, -
, - - - + , , _ _ . - - ~
. 6 24.
It is alleged that Q coatings have been placed over rusty, scaly un-prepared metal surfaces inside pipe supports made of tube steel without end-caps.
In these cases, the protective coating gets on the rusty inside of the tube. This coating material could later crack, scale, come off the pipe, and then travel to the sumps.
- 25. It is alleged that a seal coat was accepted prior to the finished coat being applied, when in fact the seal coat should have been rejected. The area in question is just outside the Skimmer Pump Room, in Reactor Con-I tainment Building-Unit 1, on the steel liner plate. The stains on the -
liner plate in the opinion of the inspector were not acceptable per pro-cedure and should have caused the seal coat to be rejected for finish coat application. The QC inspector brought' the condition -to management's at-tention and requested their opinion. Management stated that the stains were in fact rust stains and acceptable, while the QC inspector felt it was obvious that the stains were not rust and unacceptable. The QC in-spector stated:
"The reason I accepted this was because I feared auerse action would be taken against me if I rejected it." The QC Inspector goes on to say that this area has the finish coat on it now and none of the stains are visible.
26.
It is alleged that Design Change Authorization'(DCA) documents are not controlled.
27.
It is also alleged that DCAs at CPSES are originated and approved totally by engineering. QA/QC has no input in the review and disposition of DCAs.
28.
It is alleged that DCAs are used frequently and conveniently to cover up a ,
condition for which a Nonconformance Report (NCR) should be written. The alleger estimated that 40% of the DCAs are for NCR conditions.
l l
l v i .
- - - t *
- 29. It is further alleged that DCAs are written to overcome a problem area which will take considerable time for repairs. In other words, the DCAs are used to facilitate the completion of a job even though this means that accepted procedures will not be followed.
- 30. It is alleged that on numerous occasions DCAs have been issued to down-grade the surface preparation from an SP-10 to an SP-6 standard prepara-tion. It is further alleged that DCAs are also written to downgrade Specification AS-31 requirements in containment to AS-30, which is the
~
non-safety specification. The downgrading of an SP-10 to an SP-6 surface preparation is an example of DCAs being written to downgrade from an AS-31 to an AS-30 requirement.
- 31. It is further alleged that QC management interpreted an SP-6 on a DCA to mean "do the best you can". For example, when difficult access areas were involved, QC management allegedly stated to the QC inspectors, if you can-not get to an area, do not worry about it.
- 32. It is alleged that after a reading list was signed by QC inspectors, the document that they read was removed and replaced by a different document, yet the reading list coversheet remained the same.
- 33. It is alleged that many problems at CPSES with coatings are due to a QC Coatings Lead Inspector's (Individual K) lack of experience in QC. An -
example of this was when he identified the rust on an A-frame in the core area as being D-6 residue.
e T
ALLEGATIONS CONCERNING COMANCHE PEAK PROTECTIVE C0ATINGS (NOTE: For allegations 1 through 33, see letters dated ' January 16 and 24, 1984, and February 16, 1984, Vincent Lettieri to Doyle M. Hunnicut)
- 34. It is alleged that the requirements of ANSI /ASME N45.2.2-1978 were not .
met for material storage.
- 35. It is alleged that Comanche Peak has problems in the area of workmanship, quality of work, painter qualification, and indoctrination. It is 01so alleged that documentation requirements were not being met, for example 4
documentation of painter qualifications and in-process work. .
' i.h) /, ( ~; 36. It is alleged that the traceability of coatings materials was not always maintained. .
- 37. It is alleged that for the backfit program, areas that were stated to have satisfactory primer documentation ended up having 10 mils of primer on the.n, 'whi'cn exceeded the allowed maximum.
It is also alleged tnat none of the maps showing areas of adequate primer documentation were correct, for the backfit program. Additionally, it is alleged tnat the documentation for the backfit program was forged and falsified. Furthermore, it is alleged that a QC inspector for the night shift wrote up acceptable inspection reports for the dome area without ever performing the inspections. *** ADDED 7/31/84 *** Also, it is al- 01 N, leged several QC Inspectors would " buy off" anything. On several occa- I
'/ sions at least one QC Inspector conduct'ed his coatings i ection from A .y g several floors below where the paint was located. FW
- 38. It is alleged that high dry film thicknesses (DFT's) of CZ-11 are power
- ground to an acceptable DFT. It is further alleged that this would burn-ish or polish the zinc, and possibly result in poor adhesion of the top l
coat.
l
(
l
- 39. It is alleged that old Phenoline 305 (between 1 and 2 years old) is being top coated with new Phenoline 305 with little or no surface preparation (solvent wipe).
l
C j 40. Instruction Number QI-QA-11.4-5, paragraph 3.2.2.d, rev. 27, dated
- 11/8/83, page 7 of 27 states
- "Verify that the blasted or power tooled !
- surface has been brushed or vacuumed to the extent required for final
. surface inspection." It is alleged this has never been performed on power tool cleaned surfaces. It is further alleged that in lieu of fol-lowing the procedure, the surfaces are being blown down with compressed air or wiped with a cloth rag. The concern with using compressed dir is f that the surface becomes contaminated with oil and/or water. The concern with a cloth rag is that the surface becomes contaminated with lint.
i
- 41. It is alleged that when wiping a surface immediately prior to repairing that surface, the paint is wiped with a foreign cleaning solution. This l foreign cleaning solution is alleged to be a hospital' disinfectant con-l taining two (2) percent chlorides. The concern is that this hospital disinfectant is not allowed by procedure and could cause stress corrosion l cracking of stainless steel. ,
i j 42. It is alleged that duct tape nas been placed over Richmond Inserts, leav-l ing a hole benind the duct tape. Also, foam rubber was left inside the Richmo'nd Insert. It is then alleged that 115 and 1201 are applied over
- the duct tape. The end result is_what appears to be a solid wall, but in l reality is'a wall with holes in it covered wit'h duct tape, ils and 1201.
! ' 4 3. It is alleged that zinc primer was not sufficiently cured before a top
- coat was applied. It is also alleged -that the procedures were not fol-
- lowed to determine if the zinc primer was properly cured.
44.- It is alleged that the " nickel" test was not performed properly due to - ,
instructions received from QC' supervisors. It is alleged that QC super-
! visors _ instructed QC inspectors .to lay the nickel flat on the surface of
- the coating; then to lightly rub the nickel, as lightly as the inspector could, across the coating,-to keep just enough pressure on the nickel .so that it would not fall out from under the fingers.
i
~ - - , -
3 - - - ,-y 3 , --y,, v.,.,~.._~ ~,,,,-,..r. .e - w.,,.,9 -- yr..,-.-r- , , , , , --,~..,w. ,- ny v,, #c,,,
4 0
- 45. It is alleged that repairs of defects have been accomplished with no re-7 inspection of these defects. For example, a repair is made, someone com-es along and walks in that repair, you have accepted that area as satis-factory with footprints, contamination, sand, etc., and it is never re-inspected. It is further alleged'that this repair is not given a final i inspection of the type that would have been performed had it been a re-
- gular production type job.
46.S It is alleged that during tooke gauge tests, it was observed that rust was seen on steel substrate, and grease, grime, filth, and other con 3 taminants on.c ncrete substrate. , ,
l
- h. 6f.l M C A Iachc d ko A .:5I y
- 47. It is alleged that for an installation hanger for the steam generators, in violation of a written instruction, QC inspectors were instructed to perform approximately 25 elcometer adhesion tests.
.s It is alleged that coatings have been applied over seismic joints. - These joints are filled with foam and were not to be coated.
- 49. It is alleged that overspray into areas that had previously been inspected has been allowed and is commonplace.
- 50. It is alleged that coatings have been applied without the benefit of j quality control inspection, s
- 51. It is alleged that Phenoline 305 was thinned to a 50/50 mix with thinner.
This 50/50 mix, when dried, became as brittle as glass'. The Phenoline
'305 became so brittle that it was not possible to obtain a tooke gauge' reading. It lost its impact resistance and abrasion resistance. .
- 52. 'It is alleged that coatings have been placed over raw concrete that had no surface preparation.
- 53. It is alleged that QC inspectors were not to write Requests for Informa-tion or -Clarification.
a i
, - - - - , - - - . - - , - - ~ , y,- ,-, , - , - . , - - , - - , , , , - - - , . , . . , - - , >
n v, , . .- , - - n - . -
i
- l. 1 a L 54 It is alleged that during the Backfit Program, onl'y the first unsatis-factory reading was recorded, even if the following readings were either higher or lower, meaning further out of the acceptable range. It is further alleged that the trend analysis was adversely affected by not including the actual readings.
- 55. It is alleged that areas identified during the Backfit Program as being outside of the acceptable range for applied coatings were not removed as required.
- 56. It is alleged that original documentation related to the Backfit Program was destroyed by QC management.
- 57. It is alleged that in Unit 2, elevation 860, the room directly off the elevator had an area coated that was covered with filth, weld spatter, tobacco juice, and other unsuitable material.
- 58. QC Inspector procedures such as QI-QP-11.4-1 state: " Adequate lighting is defined as the minimum light produced by a (2) cell battery flashlignt."
It is
- alleged that the minimum is zero light. It is alleged that QC inspectors were to perform their inspections at arm's length, and if the light was bright, that wasn't the minimum. Rather, it was the maximum and they should obtain a weaker flashlight.
- 59. It is alleged that a QC Inspector accepted substandard coatings on the liner plate, below and above the polar crane rail at azimuth 270' to 0*.
- 60. It is alleged that QC Inspectors were selectively sent to various .
inspections so that the coatings would pass inspection. For example, production calls for QC Inspection. When the inspector arrives, he is told they are not ready. He returns to the QC office. On the way he meets a second inspector proceding to the area he was just told was not
/
ready for inspection. In this way, production selects the QC inspector they want. It is also alleged that QC management would reassign an in-spector to a different task if he was going to reject a coating applica-tion. It is further alleged that QC management would send two inspectors to inspect an area, yet only one would sign the inspection report. It is alleged that the inspector not signing the report would not perform as thorough an inspection because he did not want t anger QC management, especially since the inspector did not have to sign the report.
- 61. a. It is alleged that Comanche Peak is utilizing instructors toat are not properly qualified to instruct. That is Level 1 inspectors ,
training other Level 1 inspectors rather than Level 2 inspectors pro-viding training to Level 1 inspectors.
- b. It is also alleged that possibly Level 1 inspectors are actually pro-viding the training, then a Level 2 inspector signs that he provided the training. It is further alleged that there are only two Level 2 inspectors on site.
c.
(%# ItfurtherallegedthatmanagementisMaare W eA w w ~ +r, m 4 L. t ir f th_fact tha some
% Lao of-3 i gu . o cne yL instectors are not properly traine'd4 Iney have not fre'd' - ~CJ work by the unqualified QC inspectors and have not yet issued a non-conformance report regarding., unqualified)QC inspectors inspecting protective coatings.
- 62. (NRC Task Number AQO-4)
W Q is g ar_ doc h.um/
is alle that CPSES has no test program or desig[n criteria for
,,,j. tect v The test data that CPSES has'is meaningless b '
u , g, m t e is no design hite.ria which provjdes'the test pro es, test con-4 e.m e. ditions, test equipment, et D -
urther alle that all test data he as provide by the coati mhnufacture is co sce(acceptable,without
,3r _ .
g g- verification, and cha es are easily ma o the coating' procedures for g w, the convience.cf the construction . company. As a result, changes in dry n . .. , ..
/ -
- A -
6%c \
. . ..o o ,
film thichness (DFT) ranges and surface preparation, for example, are not y qualifled as required by ANSI /ASME N45.2 paragraphq4,3 " Design Verifica-tion". It is also alleged that the integrity of th'e coating systems at CPSES has been compromised, due to the failure to accurately verify modi-fications to the application methods in the procedures. Some of these changes have been based on opinions, assumptions and guesses.
' [i!Ns#50hgedthatsomepaintusedatCPSESinServiceLevelIwascon-taminated with grease and oil, prior to application, and was applied c, u e-anyway.
e D
9 e I v
e e g
0[nts#9Aasmu
*## ama tru/es
@ YkO /Ata allqa ubi04 ada SWa/%aupm42p An x ach+de ad.1ta W
~C 6 adiusk s k9s aqd du/tk@ bp Aa um maa9 % > w satsaa avdM aq asadik aeb.
-"_ ~
j EMc#1 P4o/M l
Codc, 3 Nn. 3SE k o 410f q b'IO Q 1 5_6 M\WS. [ a h k Q r Te X % 2. 3 psA oafcdda.meR- Arv%d,s-#6shp -wJINQdM
~
Coh Tue.iddt 0 - We_us 9 .C. oats Vcoc d u Wek/Leiben
- a. 6 -hprasow
- b. M s b \td(06.
c.. nee 1 8 M m[6,.n)s % M. ux-su , - sqczhm o.JL46 ,
- a. 15pb'Kwoch (T %%voks - Am
- b. Nor-Oce6nvoave3 9
- c. b c Ad6nzah(nc e s UtR) #)
t, .
&& 5 %
7 . Tru e /Q b ew (CEL) - %d 3
-Nodo 5ow$/ ' ;!\3 -
Mh E-Q Alh b _ _ _ - - - - - . - _ _ - - . - . - _ . - - _ - - - - - _ - - - - - - - - . - - - - - _ - - - - - - - - - - - - - .
'/,
c%,ir, u J J i i 1- w
+
4 / O M althea >5 in'4(% D b /L dwa/ /
~
~f /DeJ;ciesseil Q,A,-Gi ( ly AU -c, g nr
['" 5 E .c 'tl$ v hE 'ln % \ ! ; .N "a ' i _A%ahon ' W $ * *2 % ~Ylll,j Ek 'bdAd d Rena,/<S_
, V A
4' K+ ff {% l g _3
$ N 4
XY {Y' I E x+ xt-W I X Xi-6 '
% K 7 _2
^
M - 3 " X+ X g s 9 A X lo X+ %t 11 x x MX 6e -
/3 x x+ k x
IA a- $ 6 i g 4- K l i c-x 1 g gt g lo- - g+ K g E hX ,
~
16 ~. g -,_ x
/7 y yyg 1 l'8 x x Xf
!!4 I X4 g '= __ %0 % 11 X x+. g W !21 -_ A3 Xt - y -- lA , X, % : f y ig y
+- g4 4 -
1 - 17 g - y,. - 1 1l Xt - x m y n. 9 S
.x' x _
X 19 X, m
-}-- P a_n cic3 aerion itewj ga e b gor n 4 To m u l
mm -w-a--
., s
(. a Tcr a nr u /I R' A 4 a U / 'l J J- t /Pra dural G 1. '
/f ' /Oef.csenci'"'y c q l, t' - ,
JE ' s .r s v+ f r.,cov+n e d= t f a kn
~
m nd, ?
~
AlIm L W S * *e krNi W?$N_g&4 4 t ,f' .2 8ena,./c 5 31 V X XI-3A _>i._ _8Ys'____ 33 X+ 34 _ _ _ _ _ _ .Ys. Y 36 _Dt+ L+ - _ _ _ x 3 7 ol c. l it % ME $ _ __ $ as x1._______ - 37 lt.31 _ __ 46 % _ 1 t __.c. @ _ _ At 1t =L_. D__ R Xt _ 43 Kt W 4A R X E _ 45 _. Xt _ _ _ _ _ _ i 46 x D ME _ _G_ A, x ____-
- 4 x+ -
tW N1 - 50 y k+E___t___ tR fi $ & _f__ lEl
+n
_s1 - se 53 - X _E X_ _l 54 u s to oz x.+_ g gr umA to ex. x y g g f4 Y X _ 57 X- N bill 1 M 'X Xt l __ _ __ _. s9 f b "* To xK 1
$ g_ g _ g@ t ___
61 _ n - V - 4 _ ____ E l l
g - c _+, 3 b 66b k Mof h IO Q _ ,$_6 MBy.$.. Qw \ a
-i
- 2. bkfd-Ted?c6 pBA Qud6ude C4.m-ie.Iier/(Kw3(s33\ dish 3T 3 e2 -
~ WdTbdMZMi Coah. Tauebdds -
We_n s 4 .C. oat Procdur Weh/Le_%er( a. b, M s 6 - h prusom ~ b c.. n g l @ \\rud to.[C_w.n m& ls
- a. m m a w +s 4.
stem MA 044r a . 1 .1 , p h h e o A C r s m & p hs-Jokyc.1 .
- b. Nor-Cednvoave.
- c. h e c- heets Utk Adbnzex(rxA ')
t, .
&A 5 %
7 . Tus /Q Ed %(CEL)- % d3
-Hod g sow 5/ 'n!\3 -
4 A rn
,y ,--n---- r ,- --.
M o~.heu>s
'f*
& won i1 aw 4 / #f in'4(% D J J
/-
& /Pr A rJ /gmG' y C / Oa f a u ei jg'"'llc" j E '.,c, gnT
~
ir .? I Fn
- yWb' \"y! .D w+- l/-l -
. If
--W o St Q ? }h Abga]%,n Y$ & $h.di A Y't)dd V 'g '
Renu.cleS_ f til i t l x+ I. 6 -M to 3 xt 4 Il4.c W W f wt x 1xe x+- W 6 x
~
7 m! x , a - 2 " X+ x Y -s 9 to x - x ' s+ s+ x x n ' Mx 11 #w x
/3 x+ 3pl x .
li a-b 4 .
-F- K ~.
C-x 0 ,
)(t x K -
!* $ l
+- X ~
%+ yet n
16 ~ x - 17 -
'8 y y y- g l x x yf 19 10 X+ X+A li
% x u x, 3 -
21 WWP %t 13 . - X k 3 X %. + -
# 5- ~
L x in Y ' 3 g ~~~ yi - .s lil Xt - x m x n-9
~
) '
.x x -
X (D X 1% Da_uiz
-}-- t aeITon itcw jg a e6 7cvj (>r au4 Tafeu
, , . , , 4
.' (. aTea nr u /I R- A 4 a U l ') -
J J-
/i -t u _,ca/ /f~mG t-y+ .r e ap,r.s
~
k[SO y d ws e g d' SL* * % + ~t - c .! ; Wo N U 4- [ D (I Allmhon & 6 /$ @b @wk 5, si V x y - 3 _A_ _8r K+ _ _ _x _ _ 33 34 - t _ _ _ _ __. 1. Y _ @ 1+ _ _ _ _ 36 i X_ n o.ul
%+- x x 1 My $ _ _ B ss -
37 lt i+ _ _ _ 46 % __ Et __ . @ _ _ __ 4i Xt _ X. _. _ @ _ _ 41 Xt _ _. _ _ _ _ A3 Xt W 44 % X 85 _ 45 _ Xt _ __ __ _ _ _ 4/r X - iD ME _ _ 47 x _ 19 __ _ __ _ _ __ A9 %t - _
#1 A9 + t _ _ -
50 y E _______ t M su $L4 L _ _ _ dB _ _ & n . se tR 53 - x _ BX _ _ 5 f4 1"#4 T * %+ %
$g fr ue we er. x y 0 W 4 x x -
57 x. S S4 1 _
" X @ Xt _.
f? -
% B i g_ g 40 **
- To ' y a
x & _ _ - M - M _. E __ _ _ _ _ _ E . _ _
^
[ n > 2 E .; ' roli[s1 Coh, Nn. $sERC2r+ochsG-rouo d.ss%wg. Q a. t a t h k 6 t Te # % c
- 2. PBA Coat-Q ualsfdew. (am - Lehc/(esbs-
~
W o_l D 4'.l' M 3 Tau _.d,d4_ e 2 'b - 4 ' Wens _
.c. cats Vcocutu -
w & /t_& cn
- a. 6 m h pru er
- b. CJ,3 Pt w
- d. \D sot mt E%d3 6 4 C5 e_ka 7.kcahm/a c..L9 <. a ~
M. Ln.t_usyah.heoks ah m 4 -Ko 4 e r y c & P ~ks- 4 6sca
~
- b. Ncw-Cednvoav.e.
- c. h e c.
eeks (ER h(.I_vt.) Aaonzah(r)xAD
^
L, . tb 7 % QUGc$ %(CEL) - %d 3
-HJ g sovinte MhE-E1 A rn
N M aItkeuJs '
'f*
6Mir,u i i 1- :r 4 / O in'4(% D J J t Pra
/e /u.-dural -, /ppy
,,,66*g y"
~
5+
$',crLd :- 1 i f V+51,aln r b U v 'f*f ;
x . 4 !! w e y ~ ujd Allahn Y S o-W w qh.W tll S "(' d d
, V 'g '
f, C Renus/< S__ 2
, g x+ I 25 i iPI to 3 t&
4 xt xe W W 5 x we W x+- 6 x
~
x R - 7 _ ; s - X+ X g s e io x x ' x+ m g# ' 11 x x MX tv -
/3 x x+ h x $
d G . t- % 6 tr
' x j r g x X S
#3 S X i X+ yt lG x -
M -
/7
~
y y yc g -
'8 x x yf 19 !
X+ X+X li i10 Il X X $ Xt- W R WWF
- 13 l
. %t -
- 4 x x- +- g
,a 5- - X is t \L 7 g ~ ~ y+ - 1 Til )4 -- 1 x m x >a-9 x
) x -
X M X m
-} - Pa.naicM orITon itemy ga as7cv r edT'am 1 , i , , 1 i
(, etTe tt Dr* ts /I R* $ 4 a b / ')
- l J J- t- al z.
- i' ase,c,,c, +/~gs 6e n4 ' qk x y o/--
sjnd > g
~
$9l<';y+'/l>r 4 !!
> x ww. s as
- A%dron W.S* $ Ni W"[_f! O_ .
Ihm,/c5 x xv si V . 31 _A_ _ B r _ ._ _ . ._ _ 33 X+ 34 - t _ _ _ _ _ X. Y _ O 1+ _ _ _ _ 36 + 1. v aa u- 1 nw a _ _ e 35 x 1. _ _ _ _ 37 lt .:si _ E 46 % _. 12 _ - _
<< 1 _ 1. _ E __ _
u nKt W _ _ _ _ _ _
.43 44 % X 89 _
As Xt _ _ _ _ _ mg su x _ a _ _ _ 47 x __ N _ _ _ _ _ e n - - - A9 .
+ _ t _ _ _
So Y &__ T '11 Et si $. 1 _ _ _ Q5 _ _ n . e -
+a I3 -
x lR 1 _ J f4 had to oE gp g 2 _ g
-g g rr sa % c x x __
a v x x- a w s, 1 _ _ n x p xt _. g _ _ _ f? - x R t g g _- f o "*d T ' a v L _ _ M _ E _. _ _ _ _ _ E ..
. . - .}}