ML20141G192

Insp Rept 99900053/86-01 on 860106-10.Violation Noted: Failure to Notify Listed Customers That Part 21 Requirements Apply to Listed Components.Nonconformance Noted:Failure to Document Weld Repairs

ML20141G192
Person / Time
Issue date:	02/20/1986
From:	Conway J, Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20141G124	List: ML20141G119 ML20141G145 ML20141G166 ML20141G192
References
REF-QA-99900053 NUDOCS 8602260178
Download: ML20141G192 (25)

Text

~ -

i .

ORGANIZATION: ANCHOR DARLING VALVE COMPANY WILLIAMSPORT, PENNSYLVANIA REPORT INSPECTION INSPECTION N0.: 99900053/86-01 DATE: 1/6-10/86 DN-SITE HOURS: 96 CORRESPONDENCE ADDRESS: Anchor Darling Valve Company ATTN: Mr. A. E. Caron President 701 First Street Williamsport, Pennsylvania 17701 ORGANIZATIONAL CONTACT: Mr. George W. Knieser, QA Manager TELEPHONE NUMBER: (717) 327-4824 NUCLEAR INDUSTRY ACTIVITY: Approximately 35 percent of valve sales ASSIGNED INSPECTOR: ,  %- ,

2 -Za &

T. Conway, Rea ive Inspection Section (RIS) Date OTHER INSPECTOR (S): J. Harper, RIS L. Vaughan, Program Coordination Section

, APPROVED BY:

E. erschoff, Ch 4 h f,lR'IS, Vendor Program Branch 1 to.g4 Date INSPECTION BASES AND SCOPE:

A. BASES: 10 CFR Part 50, Appendix B and 10 CFR Part 21.

B. SCOPE: This inspection was made as a result of the receipt of 10 CFR Part 50.55(e), Licensee Event, and 10 CFR Part 21 reports from: (1)

Public Service Electric and Gas Company and Northeast Utilities on missing lock welds, (2) Washington Public Power Supply System and Comonwealth Edison on failure of air check valves to seat, (3) Long Island Lighting Company on components breaking off in swing check valves. and (4) Anchor Dartino on unqualified terminal blocks.

PLANT SITE APPLICABILITY: Missing lock welds - Hope Creek (50-354), Millstone Unit 3 (50 423); Air check valves - Byron Unit 1 (50-454), WNP Units 1/4 (50-460/513); Swing check valves - Shoreham (50-322); Terminal blocks - seven plants.

8602260178 860225 PDR GA999 ENVANDV 99900053 PDR

- e - , , - . - . . , _ - . .-- , ,- - , . - -

ORGANIZATION: ANCHOR DARLING VALVE COMPANY WILLIAMSPORT, PENNSYLVANIA REPORT INSPECTION NO.- 99900053/86-01 RESULTS: PAGE 2 of 14 A. VIOLATIONS:

Contrary to Section 21.31 of 10 CFR Part 21, a review of documentation packages for Section III nuclear valves revealed that while 10 CFR Part 21 was imposed upon Anchor Darling (AD) by their customers AD referenced Section III requirements but did not specify that 10 CFR Part 21 requirements would apply on P0s C-432, C-433, A-1770, and A-1778 to Cann & Saul Steel; Y-2303 to Sandvik; Y-2489 and C-970 to Teledyne McKay; C-2348 to General Copper & Brass; A-3015 to R.E.C.;

A-1496 to Dodge Foundry & Machine; and A-664 to Precision Technology.

(86-01-01)

B. NONCONFORMANCES:

1. Contrary to Criterion V of Appendix B to 10 CFR Part 50 and Sections 10.4.5.1 and 10.4.5.2 of the Quality Assurance Manual (QAM), there was no documented evidence of a Rework Ticket for two defects repaired on a Weld Repair Record dated September 4, 1985 for the globe body on Shop Order No. E-6534; and a Repair Welding and Hardfacing Record dated October 31, 1985 did not contain a sketch for the disc on Shop Order No. E-6534. (86-01-02)

2. Contrary to Criterion V of Appendix B to 10 CFR Part 50 and Section 6.5 of STD No MQCS-2, a member from QA had not signed, initialed, or stamped the MRBA block on Material Rejection Notice (MRN)

No. 9419 dated April 3, 1985, relating to the bonnet on Shop Order No. E-6534-001. (86-01-03)

3. Contrary to Criterion V of Appendix B to 10 CFR Part 50, Section 5.3.4 of STD No. QAS-9, and Section 9.6.1 of SNT-TC-1A, a review of qualification records for seven nondestructive examination (NDE) personnel (one-Level III and six-Level II) revealed that the qualification records did not contain a statement indicating satisfactory completion of training in accordance with STD No.

QAS-9. (86-01-04) 4 Contrary to Criterion V of Appendix,B to 10 CFR Part 50, Section 9.4.4 of the QAM, and Section 3.0 of STD No, MPDS-7, there was no documented evidence that a file of Final Approved Vendor Procedures existed for Section III valves on Shop Order Nos. E-6534, E-6516, and E-3256, and the file for E-3326 did not contain a copy of Cann &

Saul heat treat Procedure No. 1023, Revision 4 which was used on the bonnet material.

ORGANIZATION: ANCHOR DARLING VALVE COMPANY WILLIAMSPORT, PENNSYLVANIA REPORT INSPECTION NO - 99900053/86-01 RESULTS: PAGE 3 of 14

5. Contrary to Criterion V of Appendix B to 10 CFR Part 50 and Sections 5.4.2, 5.4.3, and 5.4.3.1 of STD No. QAS-10, during an inspection of the shop and the calibration laboratory, it was noted that two spring gages (S/N 0154 and 0395) were not labled properly to indicate that they had been calibrated; and the balance scales, surface plate, and dead weight tester were not correctly labled to indicate that they had been taken out of service. (86-01-06)

6. Contrary to Criterion V of Appendix B to 10 CFR Part 50, Section 4.4.4.1 of the QAM, and Section 5.1.1 of STD No. MQCS-2, during an inspection of the shop, it was noted that acceptable seat rings (i.e., 24" - 900 HT E6585-1, 14" - 300 HT P8023-122, 16" - 300 HT P8023-144, and 28" - 150 HT P8157-1) were in a nonconforming material hold area with nonconforming material. (86-01-07)

7. Contrary to Criterion V of Appendix B to 10 CFR Part 50 and STD No.

M-240, it was noted that dedicated stainless steel burr wheels located in a cabinet for grinding equipment were not marked in yellow. (86-01-08)

8. Contrary to Criterion V of Appendix B to 10 CFR Part 50, Section 10.4.4.3 of the QAM, and Sections 5.4, 5.2.2, and 5.2.3 of STD No.

EMS-1 during an inspection of the manufacturing and welding material storage area, it was noted: (86-01-09)

a. An unmarked box of Sandvik electrodes (E308L-16 in three different sizes) was left in the weld area after the completion of a job.

b. Unmarked stellite rods were not in containers in the welding material storage area.

c. Bare wire remaining on a wire feeder after usage was not covered.

d. The temperature in an oven containing E309L electrodes (LotNos. 12039-1-1 and 90194-1-3) was below 225 F on two occasions (150 F in the morning and 180 F in the afternoon of the same day). ,

1

9. Contrary to Criterion V of Appendix B to 10 CFR Part 50, Sections l 9.4.2.5 and 9.4.2.1 of the QAM, and Sections 4.4.5 and 4.2.7 of l STD No. MQCS-2, a review of the Approved Vendor List (AVL) dated January 6, 1986 and six vendor audit reports for Cann & Saul Steel, Quaker Alloy Coating, Dodge Foundry & Machine, Effort Foundry, ,

R.E.C., and LTV Steel indicated the following: (86-01-10) I i

1 l

l l

ORGANIZATION: ANCHOR DARLING VALVE COMPANY WILLIAMSPORT, PENNSYLVANIA I REPORT INSPECTION NO.- 99900053/86-01 RESULTS: PAGE 4 of 14

a. Vendor corrective action as indicated on VMDRs was not audited for implementation by Quality Assurance,

b. The restriction (i.e., Effort Foundry be re-audited prior to acceptance of any Category 1 material), resulting from the January 1985 vendor audit was not identified in the AVL.

c. R.E.C. located in Mt. Vernon, NY was not audited within the twelve month frequency.

10. Contrary to Criterion V of Appendix B to 10 CFR Part 50 and Section 6.5.4 of STD No. MQCS-2, a review of the QA Department MRN Log Book and purchasing vendor files for 373 VMDRs issued during 1985, noted that 19 were still open having passed the ten working day requirement for a response. (86-01-11)

11. Contrary to Criterion V of Appendix B to 10 CFR Part 50 and Section 1.6 of the QAM, a review of training and indoctrination records for manufacturing personnel indicated no objective evidence of training on the QAM revisions dated November 1, 1984 and December 3, 1985 for the Manufacturing Manager, Engineer, and Planner; Assembly Department Supervisor; Store Supervisor; and Machine Foreman. (86-01-12)

12. Contrary to Criterion V of Appendix B to 10 CFR Part 50 and Section 6.7 of Procedure No. OPER-1, a review of Tech Staff files identified 17 Abnormal Occurrence Reports (A0R) issued in 1985, but only three A0Rs (Nos. ABW-85-7, ABW-85-10, and ABW-85-14) had an evaluation performed and documented on Form OPER-1-2. (86-01-13)

C. UNRESOLVED ITEMS:

None.

D. STATUS OF PREVIOUS INSPECTION FINDINGS:

1. (Closed) Nonconformance (Item 8, 84-01): AD, when notified by Namco Controls that certain Model EA-180 limit switches had been assembled with the wrong cover gasket material, did not identify the discrepant gasket material on a Material Rejection Notice, describe the corrective action to prevent recurrence and disposition of the discrepant gasket material, or secure approval of the material review board.

ORGANIZATION: ANCHOR DARLING VALVE COMPANY WILLIAMSPORT, PENNSYLVANIA REPORT INSPECTION NO.- 99900053/86-01 RESULTS: PAGE 5 of 14 The NRC inspector verified that AD had notified their customer (i.e.,

Bechtel for Susquehanna, SNUPPS, and Palo Verde nuclear facilities) on Document Nos. CAW-7458, -7453, and -7457 dated February 18, 1980 that they were supplied limit switches with the wrong gasket material.

E. OTHER FINDINGS OR COMMENTS:

1. Cracked / Missing Tack Welds During installation of AD swing check valves at Palo Verde in December 1984, it was discovered that tack welds were missing on the set screws in.the hinge support on several valves. Since that time similar tack weld problems (e.g., cracks / missing welds) have occurred on: hinge pin bushings at Millstone Unit No. 3 (ref.

Northeast Utilities letter dated April 25,1985) and at Summer (ref.

morning report dated October 11,1985), and hinge support pieces at.

Shoreham (ref. morning report dated November 7,1985).

The NRC inspector examined AD assembly drawings for manufacturing swing check valves. Tack welding was called out on capscrews, hinge supports and set screws. The design of the bushings was changed such that tack welding is no longer required, and the disc nut was called to have a stainless steel pin inserted (rather than tack welding) and peened at both ends to prevent backing off.

AD also established a new procedure, No. EPS-159 " Inspection of Valve Assemblies" dated December 1985.

In the shop area, it was noted that EPS-159 forms were being used.

These forms assure that when tack welding is required, it is completed and inspected by QA. AD feels that the design change and Procedure No. EPS-159 will prevent the occurrer.ce of tack welding problems in the future.

2. Air Check Valves The NRC was notified in March 1985 by Commonwealth Edison (Bryon) in a 10 CFR 21 report and in June 1985 by Washington Public Power Supply System (WNP Unit Nos.1 & 4) in a 10 CFR 50.55(e) report of air check valves failing to seat properly. The valves, which were manufactured by Parker-Hannifin (PH) and supplied by AD, may degrade the capability for closing mainstream isolation valves or feedwater isolation valves.

A

ORGANIZATION: ANCHOR DARLING VALVE COMPANY WILLIAMSPORT, PENNSYLVANIA REPORT INSPECTION NO.- 99900053/86-01 RESULTS: PAGE 6 of 14 AD notified the NRC of 11 other plants to which similar valves were supplied, and the NRC issued Information Notice No. 85-35 in April 30, 1985. The NRC inspector reviewed nine letters sent to five architect / engineers and #our licensees in which AD indicated that testing of the pnuematic check valves by both PH and AD determined that the valves seal reliably under a sudden (guillotine) loss of air supply but do not seal reliably under a gradual loss of air supply. AD recommended that an alternate pneumatic check valve (Model No. 8F-C8L-10-55) be used for a slow decay of air supply.

The new valve was tested by PH (ref. March 28, 1985 letter from PH to AD) and qualified to IEEE Standards 323, 344, and 382 (ref.

Environmental Qualification Report dated October 1985). It was noted that AD sent replacement valves to eight of the affected plants. As of the date of the inspection, South Carolina Electric and Gas (Summer), Louisiana Power and Light (Waterford Unit No. 3),.

and Arizona Public Service (Palo Verde Unit Nos.1, 2, & 3) had not requested replacement valves from AD.

3. Terminal Blocks On September 5,1985, AD notified the NRC of a potential problem related to terminal blocks supplied as spare parts. The NU2 terminal blocks are manufactured by Connectron out of nylon and polysulfone materials, and only the polysulfone material has been IEEE qualified for application in terminal boxes furnished with AD hydraulic actuators installed on safety related valves. The NRC inspector reviewed AD P0 No. C-2953 dated September 19, 1985 to Connectron for terminal blocks, and it was noted that the P0 did not specify that the material should have been polysulfone.

To prevent recurrence, AD has assigned a code number fo; the procurement of spare (replacement) NU2 terminal blocks made of polysulfone. It was also noted that AD notified all the affected customers of this potential problem. The customers included Commonwealth Edison (Byron Unit'Nos.1 & 2 & Braidwood Unit Nos.

1 & 2), Union Electric (Callaway), Kansas Gas and Electric (Wolf Creek), Washington Public Power Supply (WNP Unit Nos. 1 A 3), and South Carolina Electric and Gas (Summer).

4. Check Valve Failures In November 1985, Long Island Lighting Company (LILCo) described the failure of two steam exhaust line check valves at Shoreham in Licensee Event Report No. 2636. Upon disassembling the valves, a bolt and flapper from upstream valve no. 2 were lodged in valve

[

ORGANIZATION: ANCHOR DARLING VALVE COMPANY WILLIAMSPORT, PENNSYLVANIA REPORT INSPECTION NO.- 99900053/86-01 RESULTS: PAGE 7 of 14 no.1, and a flapper from valve no. 3 located further upstream was found lodged in the internals of valve no. 2. In July 1982, the NRC issued Information Notice No. 82-26 pertaining to check valve failures in which, similar to the Shoreham failures, valve components separated and eventually lodged in downstream piping.

With regards to pump turbine exhaust check valves, AD investigated operating conditions to determine the cause of damage to the valves.

It was determined that two forms of periodic testing are potential modes of failure. When the pump turbine is subjected to a fast start, the disc slams into the full open position. Repeated impact of the disc against the body puts a strain on the hinge assembly and leads to eventual hinge failure. When the pump turbine throttle is partially opened, it causes the disc to flutter on the seat, and this cyclic action causes cracking in both disc and seat ring sealing surfaces. The results of an AD research program to overcome these failures led to a specially designed lift check valve utilizing a light weight disc and a dual seat design (primary seat of stellite and secondary seat of a radiation resistant polymer) incorporated in the disc.

In response to an inquiry, AD notified Stone & Webster in January 1982 of the special lift check valve and enclosed a copy of the information sheet entitled " Pump Turbine Exhaust Check Valves."

The NRC inspector was told that all AD service representatives had copies of this information sheet for distribution to their customers. The informatica sheet documents AD findings and recommendations with regards to swing check valve failures. In an August 1983 letter to Ebasco, AD recommended that the swing check valves be replaced by lift check valves at Waterford Unit No. 3 as had previously been done by Arkansas Power & Light. The NRC inspector was also told that or a verbal recommendation by AD, LILCo purchased lift check valves as replacements for the swing check valves in 1982, but as far as AD could determine, they had not been installed.

5. Control of Measuring and Test Equipment (M&TE)

The NRC inspector reviewed applicable procedures and calibration status cards on selected M&TE to determine the adequacy and implementation of the calibration control system. The following M&TE were checked for current calibration: calibration wires, charpy impact tester, gage blocks, gas welding regulators, hardness tester, weld rod ovens, micrometers, spring scale, tensile tester, l

l l

s ORGANIZATION: NCHOR DARLING VALVE COMPANY WILLIAMSPORT, PENNSYLVANIA REPORT INSPECTION NO.- 99900053/86-01 RESULTS: PAGE 8 of 14 torque wrenches, vernier calipers, depth gages, hydraulic pressure gages, surface plate, pressure gage comparator, and thread plug gages.

All calibrations that were current were verified to be traceable to the National Bureau of Standards. Personally owned M&TE such as micrometers were verified to have been calibrated by the prescribed procedure.

It was noted that calibration labels were not being used as intended for thread plug gages which are to be calibrated after 25 uses as documented on a calibration schedule sheet (Form QC-77-1). Instead of changing all the calibration labels on all of the thread plugs to reflect the currently used calibration schedule (after evey 25 uses),

AD has only changed the labels as they use the thread plug gages.

The other example of calibration labels not being used properly was with equipment that had been taken out of the calibration cycle.

The balance scale, surface plate and dead weight tester are no longer used and were taken out of the calibration cycle. Yet, they have not been labeled "Do Not Use." Upon examination of the spring '

gages in the shop area, the calibration label did not indicate the correct date of the last calibration and the calibration due date.

(see Nonconformance 86-01-06)

6. Control of Nonconforming Material During an inspection of the manufacturing area the NRC inspector noted that the nonconforming hold area contained seat rings (24" - 900 heat E6685-1, 14" - 300 HT P8023-122, 16" - 300 HT P8023-144, 28" - 150 HT P8157-1) that were not identified with nonconforming red hold tags. The acceptable seat rings were not segregated from the other nonconforming materials in the area.

In addition, the boundaries of the hold area were not obvious as the hold area was immediately adjacent to an area where acceptable material was present. (see Nonconformance 86-01-07)

7. Control of Special Processes The NRC inspector examined the welding shcp area and weld metal dispatcher room. It was noted that one-half empty box of three different sizes of welding electrodes was found in a welding area where welding was not taken place. Uncovered bare wire was also noted on a welding spool at a welding station. In the weld dispatch room a few bare unmarked stellite rods were left out of their original box on the shelf.

1

ORGANIZATION: ANCHOR DARLING VALVE COMPANY WILLIAMSPORT, PENNSYLVANIA REPORT INSPECTION No - 49900053/86-01 RESULTS: PAGE 9 of 14 An examination of welding rod ovens in the weld material dispatch room indicated that five of six ovens were maintained at the proper temperature. The oven with E309L 5/32" dia (Lot Nos. 12039-1-1 and 90194-1-3) electrodes was operating at approximately 150*F when the NRC inspector checked it at approximately 10:30 am. At approximately 2:00 pm, the same oven was operating at approximately 180*F. Upon questioning the authorized welding metal dispatcher about the oven temperature, he acknowledged to the QA Manager and the NRC inspector the incorrect temperature reading. With regards to the oven having the low temperature readings, the QA Manager questioned the Welding Engineer who comented that he was aware of the problem, and repairs were scheduled to be made. (see Nonconformance 86-01-09)

While inspecting the weld area, the NRC inspector observed a case containing burr wheels stored in a stainless steel cabinet with other tools dedicated for stainless steel grinding. The burr wheels were not appropriately marked in yellow. (see Nonconformance 86-01-08)

The NRC inspector reviewed a document entitled " Record of Welding Qualifications" which is authorized by the Welding Engineer on a monthly basis. This document identifies a welder to a Welding Procedure Specification (WPS) which is cross referenced to an "M" No. which applies to the welder's performance qualifications.

The testing of qualification test specimens for Procedure Qualification Records (PQR) and welder qualification tests are performed by a technician who also does the internal calibration of M&TE. The Welding Enoineer, who is also the Inspection Supervisor, signs off the PQRs and welder cualification tests.

Welder performance qualifications for five welders (Nos. 6, 22, 33, 44, and 77) were reviewed against six WPS (including applicable PQRs) to which they had welded.

8. NDE The imC inspector reviewed the qualification and certification records of NDE personnel (one-Level III and 11-Level II) to determine whether the individuals performing NDE were certified to SNT-TC-1A. The written practice (STD No. QAS-9) of AD for all phases of training and certifying NDE personnel was also reviewed, and it appeared to be consistent with SNT-TC-1A. With the exception of a missing statement pertaining to training in accordance with

ORGANIZATION: ANCHOR DARLING VALVE COMPANY WILLIAMSPORT, PENNSYLVANIA REPORT INSPECTION NO.- 99900053/86-01 RESULTS: PAGE 10 of 14 STD No. QAS-9, the records including eye examinations, training, written tests and certifications appeared to satisfy the require-ments of SNT-TC-1A. (see Nonconformance 86-01-04)

An evaluation of activities at four NDE stations was undertaken to assure that current procedures are being used and all equipment is calibrated. The stations observed were radiography (RT), liquid penetrant (PT), magnetic particle (MT)-wet, and the upgrading station which is MT-dry. All the NDE procedures reviewed at each station were current with the master document retained in the Engineering file.

At the MT station (wet), it was noted by calibration stickers that MT Unit URESCO No. 3505 (S/N 810679) and ultraviolet light No. J-221 were serviced and calibrated by Nutley Equipment on October 21, 1985.

The calibration report from Nutley was reviewad and found acceptable.

Records also indicated that an intensity check of the light was done daily, and a check of the chemical bath was performed twice a shift.

At the upgrading station, the MT Unit No. CRO-10 (S/N 751312) and powder blower No. XB-2A (S/N 76101) were also serviced and calibrated by Nutley Equipment on October 21, 1985. The densitometer (S/N 1402B) at the RT station is calibrated against a density strip No. 762 on a monthly basis as noted on a chart attached to the instrument.

However, it was noted a Density Strip Calibration Report from Dupont for strip No. 762 was dated August 22, 1979, and the reference standard (strip) had not been calibrated since 1979.

9. Corrective Action 1

The NRC inspector reviewed applicable sections of the QAM, Procedure No. MQCS-2 and the QA department MRN log book. The procedure allows purchasing 10 working days to completely process a Vendor Material Discrepancy Report (VMDR) and receive a response from the vendor.

AD issued 373 VMDRs during 1985. At the time of this inspection, the MRN log book listed 39 incomplete VMDRs. Of the 39 incomplete VMDRs, a second letter was sent for 37 VMDRs, and telephone calls were made for eight requesting vendor action / response for the second and third time. A review of purchasing files and the vendor's folder was also conducted, which resulted in the locating of 19 complete VMDRs.

However, as of January 9, 1986, 19 VMDRs were still open pass the required ten working days completion date. The open VMDRs are 3697, 9967, 9972, 10129, 10130, 10171, 10207, 10227, 10229, 10230, 10248, 10258, 10269, 10239, 10279, 10280, 10281, 10282, 10284. (see

!!onconformance 86-01-11)

ORGANIZATION: ANCHOR DARLING VALVE COMPANY WILLIAMSPORT, PENNSYLVANIA REPORT INSPECTION NO - 99900053/86-01 RESULTS: PAGE 11 of 14

10. External Audits The NRC inspector reviewed applicable sec+. ions of the QAM, one procedure, ten vendor audit reports, two vendor folders, four P0s, and the AVL to verify vendor audits and evaluations are being performed as required. A review of vendor audits conducted in 1984 and compared to those conducted in 1985 noted that a standard checklist is used to conduct vendor audits, but the checklist has not been revised to include verifying the implementation of vendor correction actions as stated in VMDRs.

It was noted that the last audit conducted by AD on R.E.C. was October 1982, at which time R.E.C. located in New Rochelle, NY was an ASME Certificate holder. The company moved from New Rochelle, NY to Mt. Vernon, NY between January 1984 and November 1984. AD was aware of the move, but had no documented evidence of when the move .

actually took place. Four P0s(Nos. 610, A-3015, C-922 and A-2875) were issued between November 1984 and April 1985 to R.E.C., Mt. Vernon, NY for the procurement of Category 1 material (material identified as traceable and pressure retaining). However, the AVL identified R.E.C.

as a Category 2 supplier (requires identifying material to specification and grade only). A minimum of 12 months had expired since R.E.C. made the move to Mt. Vernon, NY. Since an ASME Certificate is nontransferable from one location to another, the certificate issued in New Rochelle was void in Mt. Vernon. R.E.C.

also informed AD in a letter dated October 18, 1985 that they would not be renewing their ASME certificate.

During the inspector's examination of the vendor audit reports and the AVL dated January 6, 1986, it was noted that a restriction was placed on Effort Foundry Co., Bath, PA during the audit conducted in January 1985. - The note called for Effort Foundry to be re-audited prior to the acceptance of any Category 1 material. However, this restriction was not listed in the AVL dated January 6,1986, and Effort Foundry was listed as a s'upplier of Category 1 material. (see Nonconformance 86-01-10)

11. Training and Indoctrination The NRC inspector reviewed applicable sections of the QAM and training and indoctrination records for seven auditors, Purchasing Manager, two buyers, six QA inspectors, four Project Engineers, Manager of Contract Administration, two Contract Administration personnel, Engineering Manager, Manufacturing Manager, Manufacturing Planner, Manufacturing Engineer, Upgrading Manager, Assembly Department

ORGANIZATION: ANCHOR DARLING VALVE COMPANY WILLIAMSPORT, PENNSYLVANIA REPORT INSPECTION NO.- 99900053/86-01 RESULTS: PAGE 12 of 14 Supervisor, Store Supervisor and the Machine Foreman. A0 could not provide documented evidence that the Manufacturing Manager, Manufacturing Engineer, Manufacturing Planner, Assembly Department Supervisor, Store Supervisor and the Machine Foreman had received indoctrination and training of QAM revisions issued November 1,1984 and December 3, 1985. (see Nonconformance 86-01-12)

12. 10 CFR Part 21 The NRC inspector reviewed applicable sections of the QAM, one procedure, and 17 Abnormal Occurrence Reports (A0Rs) issued during 1985. The reports (Nos. ABW-85/1-17) were documented on form OPER-1. Each A0R is required to be investigated and evaluated to determine whether it is " substantial to safety," "not substantial to safety" or " undeterminable." The evaluations are also required to be documented on form OPER-1-2 a'nd attached to form OPER-1. Of the 17 AORs examined, only three (listed below) had been evaluated and documented on form OPER-1-2 and attached to form OPER-1. (see Nanconformance 86-01-13)

AOR (date) Item ABW-85-7 (April 27, 1985) Operator failed and overtorqued the valve bending the discs ABW-85-10 (October 17,1985) Hydraulic actuator accumulators could not be charged hydraulically ABW-85-14 (November 6, 1985) Disc nut not pinned and hinge supports, hinge support capscrew, and set screws not tack welded It was noted that copies of Section 206 of the Energy Reorganization

, Act of 1974, 10 CFR Part 21, STD No. CGS-5 " Method for Employees to Report Discrepant Conditions," and Procedure No. OPER-1 " Notification and Resolution of Abnormal Occurrences Report" were posted in the personnel department office. A review of documentation packages which included AD P0s to vendors for components used in the manufacture of safety-related nuclear valves revealed that the requirements of 10 CFR Part 21 were not referenced or identified on the following P0s which all referenced Section III of the ASME Code: (see Violation 86-01-01)

ORGANIZATION: ANCHOR DARLING VALVE COMPANY WILLIAMSPORT, PENNSYLVANIA REPORT INSPECTION NO.- 99900053/86-01 RESULTS: PAGE 13 of 14 No. (Date) Vendor Y2303 (September 19,1983) Sandvik Y2489(October 12,1983) Teledyne McKay C970 (March 12, 1985) Teledyne McKay C432 (January 23,1985) Cann & Saul C2348 (July 31, 1985) General Copper & Brass C433 (January 23,1985) Cann & Saul A3015 (November 16,1984) R.E.C.

A1496 (May 29, 1984) Dodge Foundry & Machine A1778 (June 22, 1984) Cann & Saul A1770 (June 21, 1984) Cann & Saul A664 (February 22,1984) Precision Technology The QA Manager indicated that AD did not impose Part 21 requirements on any P0 prior to January 1985.

13. Documentation Packages (DP)

The NRC inspector reviewed DPs (Shop Order Nos. E-6534, -3326, -5836,

-6516, and -3256) for nuclear valves ordered by Florida Power & Light (Turkey Point Unit Nos. 3 & 4), Bechtel (South Texas), Stone & Webster (Shoreham), Southern California Edison (SONGS), and Pacific Gas &

Electric (Diablo Canyon). DPs consisted of customer P0, Shop Order Instructions (501), Material / Drawing List; drawings; Production Release Tickets (PRT); weld repair records; Material Rejection Notices (MRN); Inspection Records (IR) for components (e.g., body, bonnet and disc); test data; P0s to manufacturers / suppliers; and Certified Material Test Reports (CMTR), Certificate of Conformances, and heat treat charts from manufacturers / suppliers.

All the customer P0s referenced 10 CFR Part 21 and Section III/ Class 1, 2, or 3 of the ASME Code. The S0I identified the customer data, AD

ORGANIZATION: ANCHOR DARLING VALVE COMPANY WILLIAMSPORT, PENNSYLVANIA REPORT INSPECTION NO.- 99900053/86-01 RESULTS: PAGE 14 of 14 data (valve list and procedures), components to be procured, and manufacturing and QA requirements. The PRT identified all activities (e.g., machining, welding, inspection) to be performed on all the components including valve assembly, test, cleaning and packaging.

The activities on the PRT were initiated / stamped and dated by an operator or inspector. A detailed review of weld repair records and MRNs indicated that on Shop Order No. E-6534 two defects were repaired, but there was no documented evidence of Rework Ticket (see Nonconformance 86-01-02), and a member from QA had not signed off on MRN No. 9469 (see Nonconformance 86-01-03).

Although MT and PT examinations are documented on an IR with an inspector's initial and a reference to a procedure, there is no specific report identifying the equipment and/or material used or documenting the test results of NDE. A review of CMTRs from manufacturers indicated that two CMTRs from Cann & Saul did not reference that the item was manufactured in accordance with Section III of the ASME Code. One CMTR dated March 29, 1985 was for disk naterial for Class 1 and Class 2 valves, and the other CMTR was dated August 29, 1985 for bonnet material for Class 3 valves.

F. PERSONS CONTACTED:

• J. Chappell, Manager-Engineering

• G. Knieser, OA Manager

• W. G. Knecht, Technical Director L. Snyder, QA Engineer B. Stannert, QA Engineer D. Wright, QA Engineer T. Wolf, Welding Engineer S. Moon, Welding Material Dispatcher M. Miller, Purchasing Manager C. Gordon, Buyer D. Murray, Buyer H. Patterson, Manager of Contract Adninistration J. Wingate, Manufacturing Manager F. Bensinger, Product Specialist

• Attended Exit Meeting

roscecron ldleWL4 on c.w.r oo. ifT 000 ff score 4 occone,4r3 exat4 ,in o Rccoor rio. g -e(

pnc,e I o s: 1. -

158[ gWT kN

• I lREV. DMTE Tt TLE /SuB.)aCT N i ST LIN bi~i./ _ kS_{_USANCE NNhld L _. _ _.__,_________ _

1- feo 6GS s It/gt_ " k L N.c Eqtegcs),_kpth Ascu p d M &us #

3 bo M @s- L U //-2t-35 " Amcdad. Dik,'el (Mt ,1 onk "

4- rrg -

lo/es

' Icm ewm wM_4hddA btle kda& # cec-i n*6_

s tse  %{ec % M w Q M a % tag kL %ah el kaA.

1 oTa 4 luer % m ) ~ s 4 m e s s e ,e s< g w Li n._ ...

1 fi'o TAD 9 b '2 {Su % 4 druc & E n n $sk @aso w _{_ M a S h Ca tc k d ' _' _

O

._ _ 1 . . ._ .M . . _

6 _ b5 5 __

$ f% Mse \ p ela. n

" ne>GCatw t lesaL&L J %wt O~u~m hptt " - -

ofn io _f9tsde sk km,

~

11 ch S d h w w a e sti k k s -(c 5 h k . - - . _ _ . . . ._-

it oTu .

%tMi lmb k 1 <wt m4_ _ _ . _ _ . _ _ . _ . . . . .

I3 ffa %S-tIo C .

'liki& 0* b A f3veh* tiku

- e 5%s bMighAsk LG%d ?_ -.

g .

N y OTH '

_ l0-11-l'g &4-((e4 Qas'yruf)hyy & g { } ( A{i bt& fi k 1

O I J

]5 $fo QAS-II 6Iz-z.-:1 "\Hakl+;at laky & kva "

TYPE f F DOC

• DW r. - DRAW PJ G LT R. - t.E T TE R.

SPEC- SPEtt FIC ATto*I 8 Tri - OTMA PRO- procEOuRE ete - Q A M A*JO Al- -

p - Q C DOCUHEdT -

.n. - VettestrM n onFR ~

-. + __ 4 -- - h.m-9 I  != i j i  : . .

! 4. l l  ! i s i  ; i i  :.

j u  : '

! i i  :

M l l l T l ' : i I W s t l l  ! t '~  ! .  !  : i 8 o d

! i l  ! Ql ,  ! j  !  :

' i Q '

iM i i i W I

.e 4c

' I

! I I l i

D l k

u i . m

"! hiL ' '

s

o.  !

lj

- d m R l

2$ I N ,& Q .* _ - O i kl .

.wP.

ss o = c. e- a V ..

aei  ;

! i

.4 w.

1' I

w Jt

, Y'

} 9,', 4[ +1 s M; s, .)gj 3 p, ; s 4e Ag i s e ii da 44 de i

s 4#J%24 j F,A a

w .aF G -

4 <,

4l 2- J u1  ::s +

vN J3 4 -8e Si *i  :  :

2

)

- G! I i V i x

d. b; 'M~ N wN j

e . i 4'

~

4 1, 3 a

- e w

.2 Ag u e~

b #W 9 ,,, 3 b g / 'sMae Q = 2 4 8

O

R $ [ d tE 4M9 - 1 -

• 3

{

ut

- h, wN 6, d., gg u4 Q ,

Q N

f N @ N $ k M Wb a 14  :. 4 ,; J sa 88 8l ll r D 9  % 9 N l p

? n 5 w a v .

c) 2 $ g { y g q -

g 51 d, 4 a '

?:, $!

t @d M a 's ,3 ,w, . e

% e p

2 *

• G M,3 "J h

• 0 2uC2 $

a y q I

1. a Y-s -

t- 3 cd ~a gj wd w r

4. 4 a a

pnaaa y a, b w

na b x t se st a a # a $e  ;!isii%

i

. i

i

! $~ t i t.

y n- n, -

t.i * -

'L s k g' l L +U! et 5 k

g-

}c; -

q.y l C[ ~3 w: I .-

j'

. Alt g' i , .  ;

u iL u s

i s ,' r (d m*2! k: e;t i

8 S" l c! ( s C ' I

' (' -,:k, t

.e i  ; t s

'Y;

,E ji qi 3,i $ib.'a t i

t u

O i

fLs !

i (v $ %o t

b3 (  ! hl v  ;

> q j$

n .

i si t 'is k 4! 'M 6 3 L 0 s

E @

9'l

. C i p

gtw 3 3 Li t  %

S g' P ; p'w ',

l o t t- a  % '

l eao t- ci o .

ri e, e +t i ( hs< ',

,Ul k d kI D! $

s >+

h i

t.i g,'

2 ?

w 1' & 2u m  %

i y, ci a. c,., ,i e

( 2'l s u

V o k x -

i w

'g 9 0 g d  %'

g i

j F- s di c g,

g t< N b

{O G I h {i W

$1 a

g s 4 o $ l D # w 2 ki e

z s s t

eiO I L < h s t L.

x q, (m

.; R i

a wa x

.d. v i }k ' % ; x o 0 We tl

! y& q !g 10 i i E

x "

RI Ni

'i I35 N \ N R A g

E', Lc (n q y w' I .:

h 5 (iiAv 't ,

3 s

3 l

i I

g 5 5

k k k D

$ h1 x 4

$ 4 h@ t i 4 r

2 .

>. c . R R t

R i,

f'u M

si o c s

• u!*3s ,

0@ uk s

3 C

s ,%

o

$ k A D y k

• t _T o y b M y w N e^, 4 c s my w' w?

s w# , ,,

5 A '

u 3 w* l l h w 2 S s, h I 1,,,,,'

s ui i i, i in i i o nms  ;

]

M w 4

? $ m' Ei m e t^ 7 Q .

ig i Eli< A e $ SG

^ l i 4 1 J a t '

ik.n l $ P R M A t ..cyff; a

q e I s2de!j: =

wy. g%f(N' s

6 ,

8  !' '-  :  :. g

3o v a3=i  :  ::: i S esc.$$5 A5h,f ,e,y,e,:,e.

c.

i i i U cd b.

-~?

_ _ _ _ _ _ . _ - - - -~

l I h '

MI j

p i3vt M nj t tjt t! d, d '

it $  ! I F i d A ji . t  !

@ll, o q""

] 14 l A c l*

Q e o-r l

l 3,

g' g 3

' l4;[;

l hc '

l[AIl4 G

-5

. i -

g' Lsl tr- d , D , ' i ,.' i$ s i t , v' N

q \

l gg, O

i

• Id E T V - R! le i

• I s, h! I

[/3Sy O

d'i l k  ! ,

7 d

• l= +'Q 'e' i t'

[hb.['

w' e f, d W

• l4 ' 3  :

D l

$ $ h,  ;

n!

'uj A t ,

I hb j ti I 4!g hl I l

i 0 WI Dil 4 i  ;

u b y kh N'

k

^

a,i b b v i

)

M \$.

i q,

4

'U k r,

R h h 4 d N

n g

e kb

> gl ,,

PN N i 4 v V-  %

\  %\ y Z\ %g s y

s

.L \C  %

4 ,:'l fl ~ l d '

o N i

@  % st 8, .'. ,

? L L 4, C O $  % O N d M f, k g y N 3'd j 's l*

• l

? a y  ??v

+9.d)id) w u .

i - , X, R, E 2

X e E g

vi

1. ! D i

's I

I I

g O

b .

h

> , M',

b' f IN g

%l 4- g .sM g! D,d 4 2,

, 4 o

4 M i j (,

W %v i

- ul g M U M D ( O( j 0 i hi '

w v'! S I y

e a s- .-- 4 hi 4 '4

% s k ~( l t s t lu i

i N o

; 7 s O 1 2 D e s N Q ( ,

1. tl  ; y M $

i S

E l tI O q 4 d e, s '

$ .k 'k k \ \

t 's ? st \ \

i t \ l 1 ~

n , , , ,'

}

V Tr sl ml W x v IlI \ll i i i i ill D @%  !

b Nc M N A g -

, , , N, h,

Ig *

• o 8 '

t  ; .a T M \  ; l 1

(

3

@m k C'h l i:

2 (k 4.12 c

> t V .. e,h$$ Y W

'

• 0 2go2 c8 4 @

0 5U E w 1 4 s  :. i ki e bEfy 1

. . t b t 5 f

$w%

x i , s; o t e, u, e, :, c, e, A% M  ! .

i

? NE#

TdSPECTOR La D, VAUGHAN paeye.r ao. _ lfl40co S~3 scope DOC OMENTS E X Arie d E D Rcrostr tio. N-oi PAGE 3 0 5: 7 1;*"

, $gwT

• N o".

dI asV. DnvE T ftE /SuB,)GCT

• ~~

vnur FAv r_sc._%-3-!G 00uGt.c Disc wgb pycg__z,qva.zm,oc,_

-g p5 -

. it

" gb/_9 .

y , it o // " is t' Efs - - -

to it ag, z,s .- 5-3 o is " o E~ r 3 " - "

gc;cvs-s-j " " " "

PF0 QA S-5 F 3/ar)L7 q). A . ertz s on n rc- 9)ont./F/cA n no RCQ L*/R W r^uTS "

AQ -~

/985 n o n r70 a o oxcirtc a v 'os'J fon

__y_s,seger,p3 AQ ~ ~

198G " "

a- T. c M A PPrL L-A q_ _

/9RS __l'_ _ _ __ - _ _ '_L _ _ _G, y KAy t~ s r2 A G) -

t785 ti

_ '/ // 1 c. g/9p 7i_ n y-AQ -

_ _ _ _ _ _ - _ 't__ is __ p.q. 374gp_cp_yt AQ ^

'98-5^

D W. Lu_f?Ir-2 0 ._.. _

AQ - -

!?b5 l'

!) I' 3 . b . gn. y p e.- f. . . . .

NC G"W ~

D Q G_ _ QA, /t0TrJ'NA L. Aup!7 C//C'l~ }<C / S7 /10OITS f fCxUb!T$

ABR h&-i-M -

cisc,is.icctus,cu is r c e n a.c i;syir cj,c_rce_i,gr__T_ Qu pers,1 ac_ge, p,,Q _

~

, N Q($-]-OX _ --j CACllA5//do /NIGCNA'- A DDQ CM r(KU5'T / tjDl75 4 f es4Ll D/75) .

TYPE OF doc; D4C - DRAdeMG L T R - t.E T T E R SPEC- SPEttFIc ATiod PRO- P toc G DU R L P J - F e,c h v 0e' To RCCO/3 fg.C r Ppg C/ D'A G MN A' D ## #

- A ubf70R O U o4L if~/ C./.' T/ofd S C 'O sn - Q h t1hn d h t- AA -]VJNudL huD/7 RCPot?J n - q c occuestor -

m. - voccl4 ASE o RDFR _ . _ .

a

'EtJSPECToR 4_. D. vat /GiV#N oo custT v30. #00T3 scope DOC OME t4TS E)( A til PJ E D RcPost.T r40. 8[ _ - O I pnoc 4- o s: ~1 17 Ng,,y %ons.a r asv. I envE Ta nE / subject I 98 y. * /N 1c RATA l- A U DI *T

~ ~

c HCc M t o 5"7 A A 8_ n_qcs.-i-ca -

12e s is nsu ucs_croi,/,,c,..ws_,.3u7_agai,,a c. 3,<<ap _(nuo,rs s ,c.Aubig_

b & C*>~/-0Y L)f Q&OI/VG AJTCAh Al- /10?)17 '*//f't"fl l W (AILDfYf 4 5C/fL/DIT 00 W S-1 U 'd# TQ. A. STAnDjifD_ _Ecr m 7 r n JrQ . guy _/y # _ _ _ _

ff0 MCS- II M Vl3lELT '~O. A l

C VAL vATIO Al OE OgicD ff~NDof S " ~ ~ ~ ~ ~ " ~ ~ ~

LA7CJr frlit.5 f or.) /s j.2.,t 3,rg l 3 Q) A)W f%l? AS/W"" S{'t'7. /// 2>/ V E C O A_JS*7 p (fr~ r / c s.) o l .

Pro mcg-j 7 r

__ ?l2s/SY *p e c cist/ N 6 2/>;Pl~c7toH s -7ANMPD ' --.

$0 WfCSX N I' I h)ONCQh!fopM/NG MMCRfAL. Akb /yg 8 b)SPnSJ7/OA) pro npDS-s P 7_g.ay- *ProwacnOJ7 con 7Pou fo p P90c MCo*T or fE AT 'l fSO OWS~l Y lh/6h u7/f/ CA *T/G b' A b pcsocL)7/o/J c>r ABpaPAMi. c3<'.c l)yCy4,^,'

fc3 Y(N$ g l

Pcil/Eb2C.D._ _ Qi A * /'2[ZN __ Los Gocp___f o r i<7 Q Q _ ___ _ _ _

VF -

^

fcv(etaco acnoo12 r<o i'Dce_- cs n n 4 s_mit srcCx_<.R. _ eqvcysibLtp,LM.

VF - - - " " "

I ~ Ouaen s w <sms. ortcRn wa,B.

'l~ PAL &Ck JDD057(ML. __ygMp?goM;_fk NV ~ '~~~

i_ 7y 57FEL Co.. .- _ .. .. __ </.1/ .- cA G O r .... I.'. '--..

~

__ _f'~ \tJILL'*4ft1S POV2 FQ OfJOf Y C-

VJIll/A f 0 0 f A TYPE Of doc.*

DSJC - Dend8*JG 1.T R. - L E T T E R secc- SPEct 5~lcano*3 peo- ProcEDueE

- ANAt/A L A UDf 7 g rpc)R7

' A _4._p A M o/c an - 9 A tin ** o A t- VE_ - XCeQCLE. F/ c C i

n - q c ooco. wor -

I i

o. - Poet H8WE o RDFR _

.- . . .. _ _. = - - - _ _ _

INSPECTO R C- 2) , VAGGMAN StoPE Do cW T 83 0 . W ooOT3 DOCGriE NTS EX Alit 4 E D Rcronx tio. N -oi PAG E S 0 6: ~i 1;;" 'g,1& y  % 5"r asv.' onre Tart.E /sosaacT UF - -

inyearo,yggag rennea -. oopsr avan __m Nyuy,_ex yF -

- - r c.a. rcevngcu ca yF ~ ~

" " e si a g zarx ,

- FARKcP hxmagtM_co. 0 7 ccs o,_ty i .

VF - ~

- Errow foor PPY TtJ=-

' BATH. FM.

VF - - - " " " -

unives FOcc cot 2r onenso% IM.

. VF ~~ ^ "

- 54ivD/4C7E'S_ Sc?n, fj' g L A_ ,. f f?,_ _ .

VF ~ ~

- A pl Ken DCm 57r' CL cn 7/pG . wrcpygg5ALy i

VF -

~ ~ "

--.".-.---..-------.-.------RfC -

- c o g r.- - - .

-m7

--- . - - prp p ON) As y VF ~

~~ ~

SAivDytk <cBf.

scMnTog PA' Y or

~

VI

_ _ _ _ , _ . _ _ . _ 0 NN N ND %IL L M(JI CN VF - -

or rcock Gewne PG@-

to ct? M K, Ap J y7 - - - " o " __ . _ _ .

miu_s staxsrece yo. pypuas cD l'1 [9 tvd RN #14 chc u ffg' ([J'CFf ~~fi~fci(?1 $ t'ggw-p5C ;

a _Wtl ABYt-8._Q $ _ ISSClt*D Dul?/N G THf. YCAF TYPE OF DOC; l'*! R S _ , __ _

D4G - DRhd MG L T R - L.E T T E R SPEC- SPEct FIchTeoeJ f efWr peo- ecoccoueC g//.C sts - Q h tA hM0h t.

vcn vrWDM L '%rfort o - q c oocoeitor -

w RMpf t.- Oc.COf ACMCS -

., G.- VslCCSthSG GRDFR ~

'.ErJSPECT@R c . .D. 'v4)G//AN scope _ occustr Jo. NNOOo 5 7 DOC dtiE NTS E xtt 4*dED RCrostr t . 85 -OI awn PAG E O 5: '"7 g m y Nr stEV.' DnTE TTLE / sus,)acT

? O. t C~6/O -

2l'755 iS7ycb 7'o _ rec _coRf _phcSygy_ Fg- _qq ,~~/ggp3.s '

p.a . p.ga,5 -

thh4 . i,

" * *  !! /t

" + 'i

p_o_ c 9p -

3/7/8.G tr  !! 't  !! ll r, " "

If

• /.28&

f. O. ;9y -

tr l'  !! It ll

 !! l' "

L *TR -

to/18/nj fron gcc <crP To A/b aor/M T!ch Tc- DFW AMC crW!<ATF I ~ ~

_'_' /CCV/E U2 CD ~

o/

/NDOC7/'.iAJf7/cvJ_4 7f/j/N /MG_ft roSEC fbf (p.[ W fa

, _ y ri // y !M'#MS ri

.. Q A A U Pl.GT fl

' if

!! ll If

. --.. ..--_._ ?UYi!N/AG N C@

I! -

- .-  !!  !? 'l it c,9,g ,,gpg

_ ,, re l' il q, -

" yI ti  ;( PGA UF gr Sc'NTfd? A20s..

q, y, t, ,y MAtsoFA @f2/NC, fr. .- .

NA-.N 6fdl. . .

_ ,, i,. ,, ,, m "*W" 6 rr l'L A /Jjdf(

,, M Anwe'itte_itG rr f b )G/NWA

_ y, ,' ), // O I'G f^ D %

TYPE O F D oC. ; /" G & . . _ .

Dwe. - DetW HG LTR-spec- SPEctV8Cstsod pro- ProcEOuet HT a(ETTE N p x'7 R. fthAT/04' W 7 ggfn,M' fr e of#5 ~

Att - q h s t AH O A L.

n - q c ooconstar -

o. - s'ocenasst nenre -

! INSPEcTo R 4. M. Vdf/CdMN SCOPE D o c F:vi.T Jo. WO co S 3 DOC OMEeJTS E XArisd E D R c ro n t rio. 6 (p _ -0/

PAG E 7 OF 7 14*3, * 'M *,l,,1 *gu r ,,,,t ,,,g 7,rg.g js,g,,c7

^T 4T .

n n

~

,, , WVlD 0 //$kO ?{lN U10/! g, 0_ S.'ll!O(_l_&..

y Al.SQ f.?N "

.[L?$ $_S?.( SU

- C_. ..

' ,, y 4 5 CPBG' .~P7

^

WLCfCISOA .

(f - ==~~

f ff // ll {/

is1Ac H/h C 11 RTU__A_t]

) // // // f/

• f / 0 5 f"f W h V h

- - ~

I

__ ._ \ _ i .. _

TVPE OS"DeC* - . . . . . . .. .

DMG - DRAdIMG LT R - (ETTE SPEC- SPEctE~lcMiod M - /x.Do R/AA 7'/oN pro- ProcEOueE _ f T[A/N/8b CONS 433 . q A tt AM O A L. -

n - q c oocuestor -

O. - PalCCHASE ORDFR -

(

j vt ,

!  ! Q ;'% NN'5,  ! .ki lqi vl I .9 e o

$Na

L &! f J (q,! 'lls c

[

o B i

l@),  !

ys [

9'  !

di v s q'i'd;g:

N.; i c! %q l q' @

h c lg  ! ' '

i e e

ti' ' (K! s O:c! _. @' '

g 1

\

si .

.\

$ [vi l' 4 sti n! rMI ;D NOf *k i  ;

ds (

k O l %j [ )l O y

I ldhk(,VI l

l I

d h 7

N p b H

few } 'fSt dk'j,[@k g '

h N( ' h4 S I

A i l dj g y* i p' 0 80 C y C

• R., 4 4

eN a - t N yI E . i i : 4 i

s C 'N i ? si O Cg C.

'B w .k !

t i I,y, 'j l1 \

S n i

n) l *1 3

i e s *

, i c s v

e v  ;

q i: o ,

kTyi }l q% .e

' h$ d 3) r d.b 6-A l 'i l e

$dN *

• I s

' gT \d < 7 e

$vlSeh.8  :' i j ia d *T S {g$ Y, h'M is 14 n. M;ia ') nd A, ~d s 1; i

a

,l ,

a e a 2 c nt 8

(

I - %5 'J 2 \.*- N 4 , # ,

4

~ ql +<

f, 4

,L ,h D %l

'X.

(

0 '

d

• • k %,

uf l 3 A:E;) i

'c! . s 9

q t *- -

v w

o Q a

_j Q T 4'Il c 4k '

E

-,f-d 2 e- 1

-@ c -

W G

ds fl y Q . A, ej e

3 I '$y [$ %Q w 0

=,i II L,

'[3 < -

O k 7-- IU r, D y h,4A Y N n$ Q ,k E5 8  %44g S A ,e 4

.s h V M, ri h b }

• x h.d d h-b \; b d y 5 k NL, 5 g ,

,% l

% 3 1 I 8IIIIl I C 9

Iw 6 hy 4 1

O' i ) I l \ ll g h suc 2

g  %,

q, ,

I W

e pg o 5 , q, g 7 g Q .,, , ,

,p

% w

,, , 4y # g 7, g

l:d S ^ D N '"g'<- g 2 '

D' ce g * '

M$E Y C5 V

c: 1 --

e ce ce' e

+ 1. .

• 2:

D o

3 ps M -

I

.$ Q g64 d d EW $  % .A 1 ,, ygswg.J '2 e d -d 2b O2 {w 8 o g y ,; a < o 5UUg$

C 4 D t!

cwgr6 8 dh-ha O

U S.gE E es O a d "O e g Ca h

• gut 05c

!g8 q n- v 6 4 , ,iTO .

t s

%_v e e g s , e e c- W,t- j Q . W

, e .

- _ _ _ _ - _ _ _ . _ _ _ _ - . - - - - - - - - - - ' ~

l l k i f.e!

! 4 g d

" lQ I l $ 24 l4l Al  ! 'N w T }

qt il -

i  :

5' a-D j i m

! i; s ,Q4 Ld,.d.

4 M. - $syh iy e

Q y

i j i al w a41 1 fg!

J ,,,

s t(* bf s i

?

y

?d d

~

' I g

dl 41 .4

.t w

PL

-i

4%

,I l

hQ 'J.

o h,

n, A h I i

~ (.

f; M'n k. Yr Dl v v!

~

ni ba !k hh*

I e d yj Vl j % i

$p iI i

• y 2

Y l' d s d a f *!; i N

s! l  ; h bwu x i- i Q: i ] a}r b .a ,

d'i h' r M Qs s.

'S; i}' ,!: di eee e wg b i

j;,

t n

n N

p, j ',: sy u

S.

4

!:v . 2 L:

i i

x, ,

0: ' t 2 ', > x ) ei s s

(

K ,! '

n h; lt,, y ij y* -

s

[) M 'C,, ' 4

'4 ,$l I 'i i S h

Q ,

• D'.

t4 il i 2

,f N ,A Q 2 5

'N QI

? -t sq w Ul.m\

} %

c, x s. J

", y  %.

b F- ~ -2; 2$ .' 'O ,' $ 1 e

' z ,

U N N g  %> w ,,S N' 1

'J t$

9 44 W 'i r*,[ ..*% Vf'J

.i 4 s , )

o L

C i

' 'j -)

i X

p

==- , Y \, ) kk { h 0 (f 511 h M, l  ?

j; .s

, *Is% g, s

? 'd 3 e

9 2 -

~+en. A- .

2 YN C'i [ c ! h> el I d C l

i  ;

NN( c -[ N 'i W 4 5 5k f*. Y

] k Nl% ?.q4l 0 [k'M ? e.1.[d C- 2-m' j Shi N g

'J

?

[

is I

s NO M

$ ), - 3 h t

.Y $

$ 'T h M .h" -

~

' 'I ,% *d .- "f '

b ef d o 9( H'I -:8. u 2 % 4

~

c 1 m ~~Q.

h V W s W Whl

'h-$ d k --

k ,t l ./ -:-

I t g gg

-- Q I

) p

.a

%. ^)

{ N -h D @ h ,

g

[ /'

,r, N b' b 5 S W *2 Q  %  ;. -  :: q( '

e' C o '"C g,

8 o ). h og

%; C (ey ( (  % y e.',-

k C Q GC hC

> l **cUgoIW uh ~ Y 2502bc q., cl n~ c.

m n

o o 8 50*8%*8 cw n y 2 g 4%

>9 u , c o a yE 4 O

'.g8 'a s f 2s R. M 4, cd.

qh 2 4 S EStf42 el el l i h I a-Q l j

e