ML20138Q480

Insp Rept 99900876/85-01 on 850812-16.Nonconformance & Violations Noted:Same Employee Identified as Both Salesperson & QA Coordinator & No Objective Evidence to Indicate Formal QA Training Program Established

ML20138Q480
Person / Time
Issue date:	11/22/1985
From:	Harper J, Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20138Q465	List: ML20138Q464 ML20138Q473 ML20138Q476 ML20138Q480
References
REF-QA-99900876 NUDOCS 8512270244
Download: ML20138Q480 (15)

Text

{{#Wiki_filter:. ORGANIZATION: JOSEPH T. RYERSON & SON, INC. PHILADELPHIA, PENNSYLVANIA REPORT INSPECTION INSPECTION NO - 99900876/85-01 DATE(Sl! Anoust 12-16. 1985 ON-SITE H0!!PS 91 CORRESPONDENCE ADDRESS: Joseph T. Ryerson & Son, Inc. ATTN: Mr. Francis W. Thorley General Manager 5200 Grays Avenue, Box 7349 Philadelphia, Pennsylvania ORGANIZATIONAL CONTACT: Mr. Raymond DeLuca, QA Manager TELEPHONE NUMBER: (215) 724-0700 PRINCIPAL PRODUCT: Steel, aluminum, plastics NUCLEAR INDUSTRY ACTIVITY: Less than 1% of Joseph T. Ryerson & Son, Inc. business is supplying nuclear grade material. ASSIGNED INSPECTOR: K [ mm h-2z- # J.' C. Harper, Reactive Ins ection Section (RIS) Date OTHERINSPECTOR(S): N. J. Miegel, RIS T. F. Burns, Brookha n National Laboratory (BNL) u[ APPROVED BY: m ~E.W.Merschofyfief,RIS,VendorProgramBranch Date INSPECTION BASES AND SCOPE: A. BASES: 10 CFR Part 21 and 10 CFR Part 50 Appendix B, B. SCOPE: This inspection was made as a result of a 10 CFR Part 21 notification made by Calvert Cliffs Nuclear Power Plant on May 28, 1985 concerr.ing a shipment of type 316 stainless steel rather than the 17-4 PH stainless steel ordered. The inspection addressed the areas of material traceability as well as the adequacy and implementation of J. T. Ryerson (Philadelphia) Quality Assurance Program in accordance with Appendix B to 10 CFR 50. PLANT SITE APPLICABILITY: Calvert Cliffs, 50-317, 50-318, Susquehanna 50-387, 50-388, Limerick 50-352, 50-353, Palo Verde-50-528 50-529, 50-530 8512270244 851224 PDR GA999 EMVJTRYI 99900876 FOR

ORGANIZATION: JOSEPH T. RYERSON & SON, INC. PHILADELPHIA, PENNSYLVANIA REPORT INSPECTION Nn

• 444nnR76/R5-01 RESULTS:

PAGE 2 of 10 A. Inspection Issues The inspection was conducted in response to a Part 21 report received fru.n Baltimore Gas and Electric, which stated that Joseph T. Ryerson & Son, Inc. - Philadelphia, PA (J. T. Ryerson) had supplied the Calvert Cliffs Nuclear Power Station with Type 316 stainless steel rather than the 17-4 PH stainless steel ordered. The 17-4 PH stainless steel was to be used for body to bonnet studs for the pressurizer spray valves. B. Inspection Findings 1. Violations: a. Contrary to Section 21.6 of 10 CFR Part 21, J. T. Ryerson did not meet the posting requirements of 10 CFR Part 21. This is a Severity Level V violation (85-01-01). b. Contrary to Section 21.31 of 10 CFR Part 21, J. T. Ryerson failed to specify 10 CFR 21 as an applicable requirement on purchase orders for " Basic Components" issued to Morris Wheeler & Company, Inc. (J. T. Ryerson work order No. 9W16/648A2 dated 1/13/84) and.eh?qh Testing Laboratory (J. T. Ryerson work order No. 9W14648/C dated 1/13/84). This is a Severity Level V violation (35-01-02). 2. Nonconformances: a. Contrary to Criterion I of Appendix B to 10 CFR Part 50, and J. T. Ryerson document " Critical Reauirement Material Instruction," (J. T. Ryerson No. 9W14648A1, dated 1/13/84) the same employee was identified by signature as both the salesperson and the QA coordinator (85-01-03). b. Contrary to Criterion I of 10 CFR Part 50, Appendix B, the Quality Assurance Manager a't the Philadelphia facility is also designated as the " Credit / Office Manager". As Credit /0ffice Manager, he is responsible for the financial aspects o,f claims settlement (85-01-03).

ORGANIZATION: JOSEPH T. RYERSON & SON, INC. PHILADELPHIA, PENNSYLVANIA REPORT INSPECTION N0.: 99900876/85-01 RESULTS: PAGE 3 of 10 c. Contrary to Criterion II of Appendix B to 10 CFR Part 50, and Section 4.8 of the J. T. Ryerson QAh, there was no objective evidence to indicate that a formal QA training program for employees assigned quality related duties had ever been established and/or implemented (85-01-04). d. Contrary to Criterion VII of Appendix B to 10 CFR Part 50 and Section 5.1 of the J. T. Ryerson QAM, J. T. Ryerson procured material and/or services from two firms that were not listed on the "Ryerson Quality" sources for Critical Applications (85-01-05). e. Contrary to Criterion VIII of Appendix B to 10 CFR Part 50, Section 5.2 of the J. T. Ryerson QAM, and Form 856.07-8 " Receiving and Identification", there were several bundles of material in stock without receiving tags (85-01-06), f. Contrary to Criterion VIII of Appendix B to 10 CFR Part 50, Section 5.2 of the J. T. Ryerson QAM and the " Receiving Instruction Manual" loose plates were observed by the inspector which were not marked with the size, grade, or heat number as required (85-01-06). g. Contrary to Criterion VIII of Appendix B to 10 CFR Part 50, and J. T. Ryerson policy and procedure 18.400.07, Sections I and II, material was in stock without a color code marking, with incorrect color code markings and the color coded end of some stock was not accessible without removing the material from the rack (85-01-07). h. Contrary to Criterion X of Appendix B to 10 CFR Part 50, foreman and operators who were responsible for production functions were also delegated the responsibility for the receiving inspection (85-01-08). i. Contrary to Criterion XVII, Appendix B of 10 CFR Part 50, the data recorded on various discrepancy reports were insufficient to identify the discrepant item, its or,igin/ vendor, disposition, QA review and approval of the disposition, and accomplishment of the corrective action. Furthermore, DRs are routinely voided without explanation and are not identified as accountable documents (85-01-09).

C ORGANIZATION: 10SEPH T. RYERSON & SON, INC. PHILADELPHIA, PENNSYLVANIA REPORT INSPECTION N0.: 99900876/85-01 RESULTS: PAGE 4 of 10 j. Contrary to Criterion XVIII of Appendix B to 10 CFR Part 50 and Sections 6.1 and 6.4 of the J. T. Ryerson QAM (85-01-10): 1) There was no objective evidence that corrective action, followup, and close out of all deficiencies noted in the 1984 management audit of J. T. Ryerson Philadelphia had been completed. 2) The 1985 internal audits completed as of August 16, 1985 were performed by a lead auditor not yet quali-fied per ANSI N45.2.23. C. Unresolved Items None. D. Other Findinas and Comments On May 28, 1985, Baltimore Gas & Electric notified the NRC that the Calvert Cliffs Nuclear Station received a shipment of Type 316 stainless steel rather than the ASTM A-564, Type 630, Condition A, 17-4 PH stainless steel ordered. The material was to be used for body to bonnet studs on the CV-100 E&F pressurizer spray valves. The heat involved was #656045 and was ordered from the J. T. Ryerson - Philadelphia Plant. However, the shipment of the questionable material originated from the Joseph T. Ryerson - Chicago facility according to the original P.O., Order No. 67864-GX. 1. 10 CFR Part 21 Requirement J. T. Ryerson upgraded stock material to meet the requirements of ASME III, Class 2 by sending material samples to the Lehigh Testing Laboratory for chemical and mechanical testing. However, the J. T. Ryerson purchase order requirements to Lehigh Testing Laboratory did not indicate the applicability of 10 CFR Part 21. The work was completed by Lehigh and the results used in the certifications were supplied by J. T. Ryerson to the purchasers. The two subaect purchase orders examined were:

ORGANIZATION: JOSEPH T. RYERSON & SON, INC. PHILA00 PHIA, PENNSYLVANIA REPORT INSPECTION NO.- 99900876/85-01 RESULTS: PAGE 5 of 10 P.O. Item Date For 8031-F-61459 SA 5156R 70-BAR 7/12/83 Philadelphia Electric 6064 SA 240 Typ. 316L 12/8/83 Arizona Public Service Violations 85-01 and 85-02 and Nonconformance 85-01-05 were identified in this area of the inspection. 2. Quality Assurance Program Organization The Quality Assurance Manager at each J. T. Ryerson plant is assigned the function and responsibilities of the Credit / Office Manager at his location. The responsibilities of the Credit /0ffice Manager include activities which are directly related to cost and schedule requirements such as settlement of claims with suppliers and purchasers of J. T. Ryerson products (paragraph 4.3.2.2 of J. T. Ryerson QAM) as well as customer credit obligations. During this inspection, it was noted that the demands on the Credit /0ffice Manager were predominantly in the area of settlement of claims and cost / schedule requirements. Minimum time was spent in the Quality Assurance Area. Virtually all of the quality related functions were delegated to the Quality Assurance Coordinator. The participation of the Quality Assurance Manager in this inspection was minimal. Nonconformance 85-01-03 was identified in this area of the inspection. 3. Training Section 4.8 of the J. T. Ryerson QAM was reviewed and current (August 19,1985) employee training programs at J. T. Ryerson were discussed with the General Superintendent and the QA Coordinator. Personnel training in quality as'surance and quality related concerns was performed on an as-needed basis determined by either the General Superintendent or the QA Coordinator. Attendance at training sessions was not recorded prior to August 8,1985. The inspector reviewed an attendance record for a training session held on August 15, 1985. This training covered color coding, receiving and heat numbers. Thirty-one employees attended the session. Nonconformance 85-01-04 was identified during this area of the inspection.

ORGANIZATION: JOSEPH T. RYERSON & SON, INC. PHILADELPHIA, PENNSYLVANIA REPORT INSPECTION NO.: 99900876/85-01 RESULTS: PAGE 6 of 10 4. Independence of Inspection Personnel There are no qualified " inspection" personnel or " inspectors" in the Quality Assurance organization at the Philadelphia facility of J. T. Ryerson. The inspection functions at the plant are performed by the foremen, stockmen, and/or unloaders. The J. T. Ryerson QAM provides for additional quality related activities in Section 5.5 when the order is identified as " nuclear" or " safety related". This Section is titled " Order Processing Control-Critical Requirement Orders." These processing requirements are additional requirements to the normal " commercial" items when involved in processing material orders. However, these additional steps do not effectively separate the quality and production functions to the extent required by Criterion X of 10 CFR 50 Appendix B. The actual inspection is still carried out by production personnel as detailed in paragraphs 5.2.2.2, 5.5.2.3, and 5.5.2.4 of the QAM. The additional activities involve a verification function by the Quality Assurance Coordinator rather than an actual physical inspection (except as provided for "special requriements" in paragraph 5.5.2.5). It appears that more specific physical involvement by quality assurance or quality control personnel is necessary to maintain the independence of the inspection activity. Nonconformance 85-01-08 was identified during this area of the inspection. 5. Discrepant Material Control Program An examination was made of a total of 89 discrepancy reports (DR) during the inspection. Numerous deficiencies were noted regarding the way these documents are controlled and processed by J. T. Ryerson. Those deficiencies are: Item ors Involved a. No vendor identified 7 b. No recommended disposition 16 c. No statement of problem 1 d. No disposition accomplished 22 e. DR was " voided" without explanation 17 f. Signed by unidentified person for QA Mgr. 1 In addition, the DR generally lacked such information (blocks were without entries) as: J. T. Ryerson order number, mill invoice

o ORGANIZATION: JOSEPH T. RYERSON & SON, INC. PHILADELPHIA, PENNSYLVANIA REPORT INSPECTION NO.: 99900876/85-01 RESULTS: PAGE 7 of 10 number, mill order number, shipping point, date shipped, car number or carrier process number, shipping notice number, packing number, and heat number. The Quality Assurance Coordinator reviews each DR and signs as approving the disposition in the capacity of " Claim Manager." This is the only individual who acts with approval authority on the recommended disposition, and it is unclear whether the action taken is a result of financial considerations (Claim Manager) or quality considerations (Quality Assurance Coordinator). A provision is made on the DR for disposition action by the " National Quality Assurance Coordinator (NQAC)" who is headquartered in the J. T. Ryerson General Offices in Chicago, Illinois. However, no copies with this signature were available for examination at the Philadelphia facility. It is questionable that any real useful purpose is accomplished by the NQAC approval since it is a long "after the fact action." This was evident since DRs 185820 and 185922 (original copies) were still in Philadelphia (without NQAC approval) but were signed off as "dispostion accomplished" on 9/14/84. Discussions with J. T. Ryerson quality assurance personnel revealed that the DR is not considered an " accountable document." Therefore the actual status of individual DRs was'not always clear. For example, DRs would be issued in bulk (15-25 copies) to various production department personnel who would then issue them on an as-needed basis when a discrepant condition was identified. Thus, many DRs were listed as issued in the DR log without further information. This particular practice was not documented in the J. T. Ryerson QAM or in their policy and procedure instructions. The J. T. Ryerson CAM does not make provision to "V0ID" a DR once it is initiated. However, this action was routinely performed. Since January 1985 a total of seventeen DRs were noted as " VOID" without explanation for this action. It was not clear which individual m'ade the determination to "V0ID" the discrepancy reports. Proper use and control of the discrepancy report system will provide meaningful data to enable material suppliers such as J. T. Ryerson to evaluate the effectiveness of their own internal operations and monitor the quality level being supplied by its vendors. Nonconformance 85-01-09 was identified during this area of the inspection. l i l

0RGANIZATION: JOSEPH T RYERSON & SON, INC. PHILADELPHIA, PENNSYLVANIA REPORT INSPECTION NO.- 99900876/85-01 RESULTS: PAGE 8 of 10 6. QA Resolution of Discrepant Conditions The QA Hanager at the Philadelphia facility is given the responsibility to resolve discrepant conditions with the " source." At J. T. Ryerson, the QA Manager has had a minimum involvement in the resolution process. In fact, he is rarely involved with the discrepancy reporting and resolution activity. The QA Manager functions as the Credit /0ffice Manager at this facility. This latter responsibility has, to a large degree, removed him a considerable distance from the day-to-day quality assurance activities. This area of multiple responsibilities has resulted in a situation where it is unclear whether the quality function is being performed as intended by the J. T. Ryerson Quality Program. Nonconformance 85-01-03 was identified during this area of the inspection. 7. Failure of Color Code Identification System J. T. Ryerson has a very detailed color code system used to maintain material identification in its stnrage facility. Personnel at individual J. T. Ryerson plants are not permitted to make any changes in the color code system (Policy and Procedure 18.400.01, III, A, 2) and are directed to affix the assigned color code to materials prior to placing them in storage (Policy and Procedure 18.400.07, I, B, j). The implementation of this system was observed and determined to be inadequate. This conclusion was the result of the following observations: a. Approximately 30% of aluminum structural shapes in storage were unmarked and some aluminum bar was unmarked. b. Numerous items (bars, tubes', shapes) were marked with additional colors as a result of inventory activities. c. Carbon steel bars and rod material were marked with the incorrect color code. Some carbon steel bars and rod material were unmarked, d. Marking of sheet steel was inconsistent (some marked, most not marked).

ORGANIZATION: JOSEPH T. RYERSON & SON, INC. PHILADELPHIA, PENNSYLVANIA REPORT INSPECTION NO.- 99900876/85-01 RESULTS: PAGE 9 of 10 Specific Examples 4130 annealed bar - no color affixed 4140 hex stock - wrong color affixed 1" 8620 round stock - wrong color affixed 5/8" cold drawn round stock - no color affixed 8" 6061 aluminum bar - no color affixed ASTM A607 sheet - marked green / white ASTM A607 sheet - no color affixed The identification and control of materials within the J. T. Ryerson warehouse is absolutely vital to assure that the material shipped is what the customer has ordered. This activity at J. T. Ryerson is governed by the two documents Policy and Procedure 18.400.01 and 18.400.07, and they appear adequate. Assurance can be provided that the system is operating correctly by. marking the materials in accordance with the established color codes upon receipt (before placement in storage) and purging the existing stores of unmarked and unidentifiable materials. Nonconformances 85-01-06 and 85-01-07 were identified during this area of inspection. 8. Mixed Sheet Material In Storage J. T. Ryerson has not stated how it will identify sheet steel. This action is necessary since the current practice is inconsistent and various plant personnel opinions exist regarding " unwritten policy". Sheet material was observed in storage which was color coded and stenciled with identification. Other sheet material was found in close proximity to marked material which lacked any identification. In fact, two stacks of material were found with both marked and unmarked material. In addition, stainless steel (300 series) sheet was found intermixed with aluminum (unidentified as to type or grade) sheet. Specific Examples Stack #1 2 sheets 304 stainless - identified 1 sheet 316L stairless - identified 2 sheets aluminum - unidentified several sheets - 3003 H14 aluminum - identified several sheets - 5454 H32 aluminum - identified

1 1 ORGANIZATION: JOSEPH T. RYERSON & SON, INC. PHILADELPHIA PENNSYLVANIA i REPORT INSPECTION NO.: 99900876/85-01 RESULTS: PAGE 10 of 10 Stack #2 Several sheets 310 stainless - identified Several sheets 304 stainless - identified Several sheets 5052 aluminum - identified Several sheets 5005 aluminum - identified 9. Internal Audits Internal audit reports for 1985 completed as of August 16, 1985 were reviewed. Audit reports of Project Engineering Warehouse and Merchandise Department dated from 1980 through 1984, and the J. T. Ryerson management audits for 1982, 1984 and 1985 were also reviewed. Objective evidence of these audits, such as the auditor's handwritten notes, were available for all reports. The head auditor's qualifications were also verified. The 1984 management audit identified five items which the auditor identified as minor deviations. There was no objective evidence of corrective action, followup and closecut for these items. The J. T. Ryerson QAM makes no distinction between minor deviations requiring no action and major deviations, those which require formal corrective action. J. T. Ryerson personnel acknowledged this condition but could not elaborate on the occurrence. Nonconformance 85-01-10 was identified during this area of the inspection. 10. Plant Tour A tour of the J. T. Ryerson facility was made to assess the quality aspects of their activities. The activities observed were shipping and receiving, placement of material in storage, cutting and packaging. The storage areas were neat, clean, and free of extraneous material. Operations observed appeared to be well planned and progressing in an orderly fashion.

PERSONS CONTACTED JOSUd I. Uv4Sca

• fa,d Dates f /NOO J

~ Company (019 k Docket / Report No. 999 00 f-rT - F b R-1 Inspector 7Eo,fi cet //s,2pg4, f j j fX'Y Page L of { G NAME(Please Print) TITLE (Please Print) ORGANIZATION (Please Drinti ~( l}ntete hbr Enc,. Nec v .N b [k MN NGL / d k U$ Q QL Joh a LL&w WIA Moa ku,w a i $Y w~ f>?// /ws w, I ( %,ei luo,&wau Gea. e / c / i.. e e,. f2,,,,,,, l t > C -2 ' (, '//J % l .~/ f. o,,,, g.a, ff $as w b dCm & n., L/ D h a l t I t

PERSONS CONTACTED Company +b Dates 'N M h f 8 $ ' Docket / Report No. 99900 h[ Inspector f d Oi a 3gg 8 5 -C %_L ~ {t\\ Ti.Mv6 \\ llas) Pa9e of L, i NAME(Please Print) TITLE (Please Print) ODGANIZATIONIDiease Printi

d. (4. ff2cf/,4 A be-k (ed us,v /tt Och~ Sin d,,,,

Ck &lA d ire u, - G,.,,, i I i

5harn, dama Asw mar on M m Pawsm e

ll } Y+ bl&nd 'In 67/A' 2pA %I 'ThSN WE+[v A len .o 3.7. k 16$a Esa a 0 42Ladj 1C. Ibaren 0LT~ ek~~ //T Ah2G e w ___,____7_

!"$Wi 9 F? If : f\\ l \\ gn s 9 d c,1 d 9,, '4 4 ns g l3 s di i 8, a s w ) 30 , 1 N. Q, 4M ~ a .o u - 'O D N h'i h4N . f Y. I 'd l X$3 ( i (W.~: i si l ( O i i %n i(. g G d g=,h;i" % p ci .N N R ( ". Ji i n

• 't i

,i ,N os \\n u V t s y V l \\J M O .t hj[pq i g $$ d 1 g )I l-I l d 0 Y 2 .o. 3 S' - N 'I a 9 i A 'c s t

.e t N Nw u

a .i yh$ ik1 't h & d o me e N 1 ae a b m m-W ! Nd W D M [j y= D 3 d -,[d f j Eh [1 {j ygl I e h g y o i x v t ( (- L. W c s e 1 N N 3 h ( 4, h., gd s Q. > N c. _h F g 3 s, e U N ( g }y 7 JN y.L 1 5 p t s v W < Y Lg e T $s g h' o %) (os G, O 4 9 .n 'G siI s n-s ul N 'e p 2 }

l 7

L m. + m t A. 1 7 I N .t s 7f C.} ( k N NM T \\' g ~ u 3 ,4 L. 9% 'q g g' g A p$ p* 8 g m'. h, 'e d 0 D d c W s s 2 Q '? ,3 4. t. t 2 L [ Q C t 3 *J w {i N S 7 T l Q T Y Q }5 w f J C s 3' y Q 4 1 3_0(,R b o 7 g i 'y N c e e 3 a 'a dg u y -dW4q%9 E tR d, dk 3 o .v y s D, - -h. ~O f ~~E. w s ~$-.,. j hw, 4 Uh kb h d W c s m gp r eq t s i s f y e s .i,,ii q..% M I I 'I Q< \\ l I ~Y ~G e d S. Y &( Q y 7 ef J N 4 e i u o. o 4 . e w a .g k ) W D t' d 4 2 S L E 9 6 ~ C (2 g4, s. 2 3 -a 2' -4 a R.- d y et ~ o wa ~ s s ,,,j h S f Q S N >=W 510 ~ . k] eye w 33bh C V p. L. 2 0 2LO25e 0 um 'c weo= B C C Jo eou o of Q ) o 4 D ' <d. E..- nj C Q Q Q cw e u u c e, s y g f5 y E. W c4 gh D E U 4 A c-1o W v'ee D O e ,h-I D Y,' %r r'4 ~> , w i

Q(N /l l I i l } 2 1 i i t l b l i\\ ( l j l t. s% y q s ~ k f f l I W i f 2N N I l 'dk I' f g 6 l %g l m 3 o i t. I N) I I e ,s s 1 h ~ \\, l.L f I i

b.

ts 4! q .M a o r

s! b

.o j. TI Ns db Si i \\. 2 oT. g 7-b A e i n-! g i j $W k 3 h N.$ gl k l U$$ 7. 5i b'DM e 4 $j W ! @$ {6 g Sj 4 j l' 4' )9 8sE i qv 'e g< x e ,t i ~ m m es s dV 1 % <r ) e'r~ t a T k s s s 1 = e k 2 4 % h 1 U Dq y Q I \\L ks b l S 3 g GL IJ g W ,g ~ q 4 A w 3 s s tY! i. \\k d. 3 N' 3 7 O 4

• J s

l N m ,I W N C 4 3 ,9 D. Ls +/; M i g (i a h 1 2 k' T a1 a .a J) %l t w 'u -j V k 4 j )! N: N D j w a ? X l -b lg k ck, d N SlO $6 $D 4 I e-e 1 g 4 p wa q 2 g W k g y, E E W I-G ] ( k r .t 3 4 i, 5' J i j \\. 3j =a _ ch.p -g

l 2

o ~ -9 u O +. e, 4 y v 1, : o Cs g\\ e ~ ~ 8 q@G -1 ~- & ci (({

• ~ ~ ' "

de i 4 'c w g&m 'h +r c f Y -Q D,& $l 5 5 l \\- y g D 7' ~ vl ~ 's A Q 'a c c Q e ---T Ni k Q h 5. kN( -J ( a a s, x ~ s Y 'I ii!I l l d 6jk l l W ,l g e e T

2 O

c 2 W P N C w r rd 'o O l-T O e 2 2 o -s U Y g I g.,j 7 o -i d V w w e5ggf. y I 0 2CO23$ ch E E WE533185 g& G T.

s a

t e s g g {1-krH Hj H H Q *e n on" H h HQo yg 2 2 a 2 a a (' 2 2 2 ga twat 8 tj 4 O d CC04 I d N Tt 3-" D i 2 U ud b -2 ba 3 N 5 7$WC VM M ll 8 H W 5, ~l cN es ~ N N cGO% j N; ri g gg n, w

= N M f *2! i l Q to !%D I l i' + , !fl i i i +1 g s M !hA $y i Q 'M Ol

• I

) l i I p i- %I l i j rs) v y .gf s 1 Q l CQI 3 7l l I N WV O l %~ 3 d l \\ .T l b-- v\\ 4, [ l ,d %. b N f h, y a

na

+ v I t A ( 4 N ) l W l ' I.s N i .^ i q u$! l eeo o$, n 4, i i oyC i J i o a: C- .o. d 3 ml i - s ost A 3. ^' I L-b D g o "d % c1 ' 4 : 2 m m e 2 e dj, h j i:-a= 7 m' }# } h ^b i b-l -), $1 49 1 ( o ty b/ 4 a -j ,d 8, N + ig gm 4 .q> ,3 x a e e + v) 5 y L 'k y )p 4, <9 l s j .9 s s s J-i 4 4'y di y f J li d. 'J d I sv 4 t 3' _ %l $' g ! M g) i G s N, e 4,' O J 3 Ny-k,l l% v' d '4 4 3 k v ~ .J Q V 2. s ' ' - p d Ll f' ei lj T q* '~

• w i

4 s ( a i g c m

s

- ~6" 4',q.j d b 2 0 -3& J ~ w mm I a p S n 4 y i} N 9 t)

• a

') O b i g mr e m e e e-t jc ws g ) ,/g W.5 x, t^ f c 'y a HJ l -{ f 4 e s c i ,,,,ii V W J 4 4 I l l H,g e 2JLjJ g u ~ 6 '1 .m a 'h .3 Tt , yv g, ^ W ff E,J 6 V ]4 'l 7 C u t p j p i .4 o bg U h 'o v W c k1 w o r g e vo g w p 2 V 2uc2ve f 1t u o -wee = O "2 u p g c i., l' '~- t i $o is 4 + e ~ce sg i;Z$sh 1a n, e-nr 7! 2 ~ e n -s V r ..}}