ML20210G248

From kanterella
Jump to navigation Jump to search
Insp Rept 99900075/86-01 on 860210-14.Violation & Noncompliance Noted:Failure to Post Current 10CFR21 & No Documented Evidence That Listed NDE Procedures Reviewed by Vendor,Respectively
ML20210G248
Person / Time
Issue date: 03/31/1986
From: Conway J, Merschoff E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20210G199 List:
References
REF-QA-99900075 NUDOCS 8604020391
Download: ML20210G248 (13)


Text

{{#Wiki_filter:". i i ORGANIZATION: PACIFIC VALVES LONG BEACF, CALIFORNIA REPOPT INSPECTION INSPECTION NO.: 99900075/86-01 DATE: 2/10-14/86 ON-SITE HOURS: 28 CORRESPONDENCE ADDRESS: Pacific Valves ATTN: Mr. Reid Armstrong Vice President, Engineering 3201 Walnut Street Long Beach, California 90807 ORGANIZATIONAL CONTACT: Mr. Robert Argent, CA Manager TELEPHONE NUMBER: (213) 426-2531 NUCLEAR INDUSTRY ACTIVITY: Approximately 2 percent of valve sales. ASSIGNED INSPECTOR: . 6%t[Ch 3*Ib R fd.)T. Conway, Reac ve Inspection Section (RIS) Date 1

                                               %)

OTHER INSPECTOR (S): i "~ ../ -

                                                      /                                                                                 <-

4 APPROVED BY: '! h i ~ /U-E. W. Merschoff, Chief, RIS, Vendor Program Branch

                                                                                                                                         / /'-

Date INSPECTION BASES AND SCOPE: A. BASES: 10 CFR Part 21 and 10 CFR Part 50, Appendix B. B. SCOPE: The purpose of this inspection was to review manufacturing records and gather data on design changes, recommended maintenance programs and vendor / licensee interface pertaining to swing-type check velves. PLANT SITE APPLICABILITY: Failed swing-type check valves - San Onofre Unit 1 (50-206); Failed stop check valves - Turkey Point Units 3 and 4 (50-250/251'. 9604020391 860331 PDR GA999 ENVPACV 99900075 PDR

l ORGANIZATION: PACIFIC VALVES LONG BEACH, CALIFORNIA REPORT INSPECTION NO.- 99900075/86-01 RESULTS: PAGE 2 of 11 A. VIOLATIONS:

1. Contrary to Section 21.6 of 10 CFR Part 21, copies of Section 206 of the Energy Reorganization Act and Procedure No. QSP-0004
              " Identifying and Reporting Defects Under 10 CFR 21" were not posted, and an outdated copy of 10 CFR Part 21 was posted. (86-01-01)
2. Contrary to Section 21.31 of 10 CFR Part 21, a review of documen-tation packages for Section III swing-type check valves revealed that while 10 CFR Part 21 was imposed on Pacific Valves (PV) by their customers, PV did not specify that 10 CFR Part 21 require-ments would apply on purchase orders 46330N and 46360N to Pacific Southern Foundries (PSF), 50396 to Sun-Ray Testing (SRT), 49956N to A&G Engineering, 56698N to Poly Cast, and 58159 to Jorgenson Steel.
             ~(86-01-02)

B. NONCONFORMANCES:

1. Contrary to Criterion V of Appendix B to 10 CFR Part 50 and Sections 5.7.1.1 and 5.7.1.2 of the Quality Assurance Manual (QAM), there was no documented evidence that NDE procedure QCS 300, Revisions K and N; FSP-0900, Revision 0; FSP-0901, Revision 1; and heat treat precedure FSP-0950, Revisions 0 and 2 from PSF were reviewed and approved by PV. (86-01-03)
2. Contrary to Criterien V of Appendix B to 10 CFR Part 50, Sections 7.2 and 9.2 of STD No. QAS-6, and Sections 7.4.1 and 7.4.2.1 of the GAM, a review of qualification records for nine NDE persorrel, three each from PV, PSF, and SRT revealed the following: (86-01-04)
a. There was no documented evidence that M. Hess from SRT was qualified to a level III examiner when he qualified PV's J. Sewell to a Level III-licuid penetrant testing (PT) in February 1984.
b. Qualification records were missing for R. Nielson from PSF who performed magnetic particle testing (MT) in May 1982.
c. The qualification records of the three PV examiners did not contain a statement indicating satisfactory completion of training in accordance with STD No. QAS-6.

ORGANIZATION: PACIFIC VALVES LONG BEACH, CALIFORNIA REPORT INSPECTION NO.- 99900075/86-01 RESULTS: PAGE 3 of 11

3. Contrary to Criterion V of Appendix B to 10 CFR Part 50 and Sections 5.3.8 and 11.5.2 of the QAM, it was noted that vendor audits were conducted by M. Merrill in September 1983 and K. Cranek in April 1985, but they were not cualified as auditors until July 198a and October 1985, respectively. (8F-01-05)

C. OPEN ITEMS: None. D. STATUS OF PREVIOUS INSPECTION FINDINGS: Not addressed during this inspection. E. OTHER FINDINGS OR COMMENTS:

1. San Onofre Unit No. 1 (SONGS-1) Incident The NRC inspector discussed the five swing-type check valves that failed in the feed water systen at SONGS-1 with the V-P Engineering, the Chief Design Engineer and the OA Manager. Upon learnina of the
            # ailed valves, PV sent a Customer Service Representative to the reactor site to get the Serial Number (S/N) of the affected valves.

The tag containing the S/N for the 4" valve was missing, but the S/Ns for the three 10" valves were 47754, 47755, and 47756; and the 12" valve was identified with S/N 48345. The inspector was told that manufacturing records did not exist for commercial valves manufactured prior to the first Section III valve fabricated in 1975. The only record was PV's Valve Serial Number Log dated 1957'tc 1966. The log contained model numbers along with S/Ns and the date that a valve underwent hydro testing. A review of this log indicated that the three 10" valves were hydrotested on Decerber 7, 1965, and the 1?" valve was tested on December 30, 1965. However, there is no irdication where the valves, which were manufactured as commercial grade WCB, were shipped. The NRC Incident Investigation Team.(IIT) that evaluated the event at SONGS-1 was told that the valves were purchased by Bechtel from Atlar. tic Richfield Hanford Ccmpany. Neither Southern California Edison nor Bechtel contacted PV regard-ing check valve deteriorations (i.e., discs, hinge supports, er.d hinge pins were replaced in the failed valves at 50NGS-1 in 1975 and 1977) until January 1986 when Bechtel called PV reauesting spare parts for eight check valves and a proposal for design enhancements for the swing-type check valves. Initially, Bechtel was satisfed with

ORGANI7ATION: PACIFIC VALVES LONG BEACH, CALIFORNIA PEPORT INSPECTION MO.- 00900075/86-01 RESULTS: PAGF 4 cf 11 PV's proposed changes which included adding stellite to the wear surfaces of the disc and hinge support, enlarging the diameter o' the hinge pin, and changing the configuration of attaching the disc to the hinge support. However, Bechtel later told PV that they were going to replace the failed valves with Atwood Morrill swing-type check valves which have a one piece disc / hinge assembly. NUREG-1190 documented the IIT's findings at SONGS-1, and it was noted that the three 10" main feedwater regulator check valves were inspected in 1975 and 1977, and new internals were installed in all three check valves. The NPC inspector was told by PV management that records did not exist to show that spare parts for PV swing-type check valves were ever ordered or shipped to SONGS-1.

2. Swing-Type Check Valves In 1975, PV received their "N" and "NPT" stamps, and to date approximately 226 swing-type check valves have been manufactured to the requirements Section III, Class 1, 2 & 3 of the ASME Code.

Since the initial nuclear check valve was shipped in January 1976, PV has not made any chances in material for individual components or design configuration. Tack welds are not used, and the attactment of the disc to the hinge support is with a nut that is pinned to the threaded stem of the disc. Since 1970, a copy of PV's Maintenance Manual has been sent to customers with the finished valves. Section C " Pacific Swinq Check Valves" of the Manual addresses Installation, Operating Instructions, Maintenance, anu Preventive Maintenance. There is a caution not to exceed the pressure and temperature linits of ANSI B16.34, but specific examination periods for maintenance activities are not identified in the Manual. Starting in 1978, PV cautioned owners in Catalog No. 400 regarding the use of swing check valves in certain environments. Under

            " Service P.ecommendations" it was noted that service in systems involving rapid and frequent flow reversals, pulsation or excessively turbulent flow should be avoided; and the incation of        ,

swing-type check valves away from fittings within the piping system could minimize or eliminate potential problems. It was also recom-mended that suspect problem systems be reviewed with PV before selecting and purchasing a particular swing-type check valve. For all the nuclear orders of Section III swing-type check valves, PV could not recall any discussions or correspondence with customers

ORGANIZATION: PACIFIC VALVES LONG BEACH, CALIFORNIA REPORT INSPECTION NO - 99900075/86 n1 RESULTS: PAGE 5 of 11 pertaining to operational environments within a piping system. The purchase orders (PC) and technical specificatiuns did not identify the specific flew conditions, and the P0 only listed a valve size, model number and class. For best performance, the catalog also recommended that swing-type check valves cperate within a flow range sufficient to hold the valve fully open, but not so high that it produces excessive turbulence. To correctly size a valve, the seat port velocity at the operating flew rate should be. calculated, and it should fall within the velocity range noted by the following formula: 55 [$ V (fps) $ 240 di Where k equals the souare root of specific volume of flow medium at operating conditions. The NRC inspector was told that PV service representatives norrrally distribute the catalog to their customers. Feedback from custcmers pertaining to problems with PV valves is directed to the Field Services organizatien who maintains a file of custcmer inquiries or complaints and subsequent action taken by PV. PV could not identify in their files any inciderts where nuclear or comrrercial customers had notified PV of swing-type check valve failures and in particular any that were similar to those failures at SONGS-1. It was also noted that PV does not perform any trend analysis en failure data received from their customers.

3. Welding The NRC inspector reviewed the qualification records of seven welders and seven welding procedures used for the narufacture of nine nuclear check valves and related spare parts. A review of Welder Performance Continuity Records and Oualification Test Records of Welder Mos.10, 12, 13, 21, 30, 32, and 34 indicated that all the welders were qualified to weld with the applicable Welding Precedure Specification (WPS). A review cf seven Procedure Qualification Records indicated that the WPSs used to weld the seal rings into the body, to apply the hard-facing on the sealing surfaces and for repair welding were all qualified, and test specimens had been satisfactorily tested by either Continental Testing or Dickson Testing.

CRGANIZATION: PACIFIC VALVES LONG BEACH, CALIFORNIA REPORT INSPECTION NO.- 99900075 /86-f11 RESULTS: PAGE 6 of 11 The inspector evaluated the weld material control area. Electrodes for nuclear work were retained in two furnaces. One furnace (S/N 23916) contained 14 different type rods and was designated for the "1st shift." A calibration sticker was on the front door and indicated that Golden State Calibration & Service Corrpany had calibrated the temperature recorder (current reading of 240 F) on December 10, 1985. The second furnace (S/N 23978) was for "2nd shif t" and contained a similar calibration sticker. The second furnace contained six different size rods. Both furnaces were padlocked, and the keys are ccntrolled by the Weld Shop Supervisor. 4 10 CFR Part 21 Procedure QSP-0004 relating to the identification and reporting of defects and failures was reviewed, and the implementation of the procedure in regard to posting requirements was evaluated by inspecting the shop areas. It was noted that an outdated copy of 10 CFR Part 21 was the only document posted in several areas (see Violation 86-01-01). A review of PV 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 were stamped "Nuciear:" (See Violation 86-01-02)

              - 46330N (Decenber 1, 1981) and 46360N (January 5, 1982) to PSF for castings (body, bonnet, and disc)
              - 50396 (October 6, 1982) to SRT for radiographic testing (RT)
              - 49956N (August 10, 1982) to A&G Engineering for fasteners
              -   56698N (September 10,1984) to Poly Ca.t for hard-coating plasma powder
              - 58159 (March 5,1985) to Jorgensen Steel for bar and plate
5. NDE The NDC inspector reviewed the qualificatior and certification records of nine NDE personnel, three each from PV, PSF, ard SRT, to determine whether the individuals perforning NDE were certified to SNT-TC-1A.

The written practice (STD No. QAS-6) of PV fer all phases of training and certifying NDE personnel was also reviewed, and it appeared to be consistent with SNT-TC-1A.

ORGANIZATION: PACIFIC VALVES LONG PEACH, CALIFORNIA REPORT INSPECTION NO.- 99900075/86-01 RESULTS: PAGE 7 of 11 One level III examiner from SPT performed RT on nuclear valve components in October and December 1982. The other two examiners administered and graded the examinations of PV's J. Sewell to a Level II-RT and MT and a Level III-PT. The qualification records on file at PV for the examiner who performed RT and the Level III-PT and MT indicated that they both met the requirements of SNT-TC-1A. It was noted that J. Sewell was certified in February 1984 to a Level III-PT, but the records en file at PV indicated that Hess was not certified to a level III-PT until August 1984 (See Nonconformance 86-01-0aa ). The three examiners from PSF performed RT and MT on valve components (body, bonnet and disc) used on Section III swing-type check valves. With the exception of records for R. Neilson who performed PT in May 1982 of a bonnet on shop job (S/J) No. 1000066N, PV had sufficient records to verify that the other examiners meet the qualification requirements of SNT-TC-1A when they performed a specific NDE (See Nonconformance 86-01-04b). The NDE examiners from PV included two Level IIIs ar.d one Level II certified to PT. The current Level III at PV was also certified to a level II in MT and RT in February 1984. With the exception of a missing statement pertaining to training in accordance with STD No. QAS-6, the records including eye examinations, training, written tests ard certifications appeared to satisfy the requirements of SNT-TC-1A (see Nonconformance 86-01-0ac ). Five NDE procedures were reviewed. Two procedures from PV addressed RT (QSP-0045) and PT (QSP-0047) of valve components. The PT (QCS-300), PT (FSP-0900), and MT (FSP-0901) of steel castings was covered in PSF procedures. It was noted that the PSF procedures were not reviewed and approved by PV's CA department (see Nonccnformance 86-01-03). During a walk-through of the RT ' station, it was observed that the densiteneter is calibrated against a density strip (No. 1498) on an annual basis, but the reference standard (strip) had not been calibrated since 1981 as documented on a Density Strip Calibration Report from Dupont.

ORGANIZATION: PACIFIC VALVES LONG BEACH, CALIFORNIA REPORT - INSPECTION No_- 09cnn075/86-01 RESULTS: PAGE 8 of 11

6. Audits The NRC inspector reviewed applicable sections of the RAM, two procedures, seven external audit reports and the qualification records of four auditors to assure that items and services were being purchased from qualified vendors, and PV personnel were trained and qualified to perform audits.

PV's activities pertaining to five manufacturers who supplied itens for safety-related swing-type check valves were evaluated. Audits were conducted by PV of Poly Cast (one) who supplied hard-coating material, PSF (three) who supplied castings, and SRT (three) who performed NDE. Checklists were used or all the audits which were conducted in 1983, 1984, and 1985, and the results were documented in a Vendor Quality System Evaluation report. The other two manufacturers - E.M. Jorgenson (wrought products) and A&G Engineering (fasteners) - were Quality System Certificate (Materials) holders and were not audited by PV. The QA records for the four personnel who conducted the external audits consisted of Auditor Qualification Records, a written examination addressing material contained in ANSI /ASME NQA-1 and related codes and regulations, and a Pecord of Lead Auditor Qualification. It was noted that SRT was audited by M. Merrill in September 1983 and K. Cranek in September 1985, but QA records indicated that they were not qualified to laad auditors until July 1984 and October 1985, respectively (see Nonconfornarce 86-01-05).

7. Stop Check Valve Failures - Turkey Point Between November 1985 and January 1986, numerous failures were
experienced in stop check valves located in the stean supply system to the auxiliary feedwater pumps at Turkey Point Unit Nos. 3 and 4.

The failure mode was degradation of the disc and disc rut assembly due to low stream flow conditions caused by a leaking motor-operated valve (M0V) in the system. In seven valves, the vibration and chattering of the disc assembly resulted in 3 broken disc guide stud which caused the disc to become locked in the valve thus preventing full closure and full opening of the valve. The broken stud was also free to travel causing further damage. i l l

ORGANIZATION: PACIFIC VALVES LONG BEACH, CALIFORNIA REPORT IF.SPECTION NO.- 99900075/86-~01 RESULTS: PAGE 9 of 11 The failed valves were ordered by Florida Power & Light (FP&L) on P0 No. 65380-27088P dated May 24, 1983 to be fabricated in accord-ance with specification PTP-1000-4.55.5 and Section III/ Class 2 requirements of the Code. Twelve carbon steel valves (3" 660S WE-80-X) were manufactured by PV on S/J No. 3A0038N, and the valves were sent to FP&L in October 1983. With regards to the failures in November 1985, PV's Manager, Field Services (MFS) supervised the replacement of damaged parts in five valves in Unit No. 3. The MFS told the NRC inspector that the spare parts (e.g., disc assembly, seat ring) were identical (material and configuration) to the original components in the valve. When the reactor went operational, the MFS observed the re-worked valves and noted that the internals were still chattering, and the valves were very noisy. It is PV's opinion that the valves are failing because of the turbulence problem caused by the leaking MOV.

8. Nuclear Orders - Check Valves The NRC reviewed the QA records for three nuclear orders and five spare part orders of swing-type check valves. Records consisted of P0s and technical specifications from the customer and PV Cata Packages (DP). Eight P0s, five of which were for spare parts, referenced technical specifications and the requirements of Section III of the Code and 10 CFR Part 21. A DP consisted of Data Peports for the pressure retaining parts (i.e., body, bonnet, and disc), Production Work Order (i.e. , traveler), hydrostatic test report, certified material test reports (CMTR), heat treet reports with time / temperature charts, casting repair reports, welding and hard facing records, NDE reports, wall thickness measurements, and visual examiration checklists. The CMTRs were for pressure retaining castings, welding material, and fasteners; and the NDE reports were for MT, PT and RT.

The three most recent nuclear orders were from: (a) Stone & Webster (S&W) on P0 No. 2362.050-651 dated May 7,1981 for Millstere Unit No. 3; (b) S&W on P0 No. 2282.050-676 dated September 17, 1981 for Millstone Unit No. 3; and Gibbs & Hill (G&H) P0 No. 5021-1-6.6-044 dated October 23, 1984 for Susquehanna. The May 1981 order from S&V was for carbon steel valves, and the other order was for stainless steel valves. The G&H order was for valves to be installed at the Diesel Generator "E" facility.

                                                                                      .}

ORGANIZATION: PACIFIC VALVES LONG BEACH, CALIFORNIA REPORT INSPECTION NO.. occ00075/86-01 RESULTS: PAGE 10 of 11 Data obtained on the three nuclear orders is as follows: S/J No. Quality-Model No. Approx. Date Shipped 1W0066N 2-10" 180-7-WE-X 10/82 1W0163M 10-2)" A-180-14-FF-X 11/82 2-3" A-180-14-FF-X 11/82 2-8" G-680-7-WE-X 12/82 4WO340N 2-10" 380-15-WE-40-X 10/85 Spare part orders for nuclear valves included items such as seat ring, wedge, stem, eyebolt, gasket (bonnet), hinge pin, disc, nut washer (disc), and segment ring. The five orders were from the following customers and were manufactured under the noted S/J No.: Customer PO No. (date) S/J No. S&W 2362.050-651-30 4WO284N (9/19/85) S&W 2282.050-676 4W0032N (7/17/84) Omaha Public 536874 480269N Pcwer District (9/17/84) Duke Power P25624-73 SWO143N (4/25/85) Kansas Gas & 53239 5H03690 Electric (11/7/85) The S/J Instructions for both valve and spare part orders originated in the Project Enginepring Department and included requirements for pressure retaining and non-pressure retaining components, and weld filler metal; list of procedures; and documentation reautred with the shipment.

ORGANIZATION: PACIFIC VALVES LONG BEACH, CALIFORNIA PEPORT INSPFCTION NO.- 99900075/P6-01 REstfLTS: PAGE 11 of 11 F. PERSONNEL CONTACTED

       *R. Argent, QA Manager
       *R. Armstrong, V-P, Engineering J. Sewell, NDE - Level III F. Hernandez, Gage Technician G. Brown, Chief Design Engineer F. O'Brien, Manager - Design Engineering R. McConnell, Manager - Field Services G. Hay, Weld Shop Supervisor
  • attended exit meeting
                       -.~c._.___._ _.-. _ . - --, _ - _ _ - - - _ - - . - y - - ~ . - . - , _ - -               _ _ , - - _

ItJSPEcTo R t b u k'I'( On cvs_r #10. "'Ii SCOf'E Doc tJt4ENTS F x Atin dE D R cront tio. M 0I enc,c I o s:- L-I;og5 gy,L7 "Tf*" F lasv. { DruE Tt RE /50BJacT I 9AA _ _ 1 7-IC 84- Cs a c4 i i x _ _p., , u e.a ; p.I,1 m,,i c

         ~L       fro             M cca+             l Sff(t "Inr.c t.ac_:1 A tecri.x m <eis                             c' u'e.t        w < r~<: zo 3                                                                 % A tia .vt,.. t g % , et.;._ h g r_ fro.

h o1R Y a c t _ _ _. ... _ _ o ff-Ioe ~S-W3 fi o bfdfde c_ fcS7,_dg. f{ } [fQL, igg j'yJ{$

        $              o         hf.DToo                 Y *i- {              b%O (Edi.T/ A s i T65 ii46 ef TI f d (<'pM,", d 5                                            __

b fde i W 0%i I 4 - 1L-5 9 2 4 MAdra C 7.c. f,1u.cq Ti 4 4.a d sic w <.-h I,a<.is " o (")f fC4 E  ! d 98 C[slel[<fe L. 76iisd6- C4 D i ~ L. Ml_6_fdf.T1 ___ , , _ . _ _ _ , 8 6 ef- m41 'hi 'so u o T (2c#eam,_ te m Aarra q th awc' , i' ft'c by ow 7-K_ Yukt& %gdccA__3rAr of cAsi,Jcs " _ ic_ oht 9a At ramv puesle 4- Aum reas

   ]/_ fcc                       6W - 4        lL T- zI-8
  • R9E @ahmu19aa,E.gr -a t Gr rmar<.a Gocareg jh_3c([_._

[h _? SM , _ ALW\CA LO YCA: 005 & N'EL OC;.'$ I3 jcc tzfL c2c2- Lo I " ( W a u 7 4p u u(tas e4 ? * ' (

  • s?= m r <-). <unD e.w "_ _ .

_hl _o N?S~Wiffi<}- O ll'iacts,L7ip &\__ _)_Qu'pfattaq'y_(cg',l([ cg t l' \ l5 CCe 41-c2c:: I

                                                                      Hacmaac; (c M,.L_ f z.wp, aw *

! TYPE OF Doc, DWG- DPod t

  • 8G L T R .- 1. E T T f_ R SPEC- SPCC t l IC f4Tiod Q - C T*<C A pro- PcocEDuRE -

rgtg - q f\ till*J O A L - CD - Q t notuMEMT -

         .o.- PiercierW E nonFR                                   __

l% l l i i  : ' t ' j l% l i i i I i t W il I  : t e W . t

                                                                                                                                  }

l

                                  \ w; m'.
                                                                     ;                                                                                    ;                                               i
                                                      ,                                 ;                                         2                                                                                                      i o                       i                                    :
                                                                                        '                            i                                    .

0 o - 9a i 7 s , i l , a

    @          '                y,z         N_                      :

i l i i i i i j

                                                                                                                                                                                                                                                     +

4 @i i i tr u. l i l' l

           .6$ 0 j

o dif 1 l l i  ! l l Cg L V.M. l 1 i  ! l-l l l

                                                                  .                   I                                                                                                                i              i                            !
               -                                                                      '                                                                                                                                              i f^ ;-f                       :                                                                                                      ;              1              e j                                                                                    '              '              ,

j 7, w t 7-~ l .

                                                                                                                                               '                         g              l i                                                                                                                                              '

h - c' W l* **t l

                                                                                                                  .                                                                                                                                 i
        $&0                         '                                                1                           i 3                 i                  '                                                                                   ,

i VD' Q C U C ,,  ! , I i ' I ' I , n

        ~     g C.                                               '                  ;                                                         6                                                       I 1                       --                         #1 U              \                            A,                                                                                                      6 4                  !

l l Y N.' j t v

                                                                                                                                                                 #.                    l 4'

Mk N;

                                               )'
                                                                                               -m f

[tM S 9 v s"i d v C 3 1

                                                                                              ~                 , ~                        u                    ._4                   i         3I                  f, a a        3:? 1'                                   '( L                                ;
                                                                                                                             .Y
                                                                                                                             ; 4        4                         %
                                                                                                                                                                                       ' %                          i          e                 i

_2 I C '. \ 4l1

                                                                                                                         -3           Y yl5p                              l s

O e x 3 %4 eke ';l ' J ll c T

                                                                                                                                                                                                                                               /
                                     .s                                                                   aNM                                                                                 ;g                               l 3 9[ 4,t.i 4 g                                                                                                     9                                                                   .u v, t
                                                                                                                                        )s h$

3 w  !

                                                                                                                                                                                               %                   ,          %X g                                                  1 j-                                                                                        j I

f'3\3

                                                                                                                                                                                                                                            /,,

34 h Jj2 97

                                                                                                                                                                                                                                 -s h

m W jg M d.%'5 Ti M -f 2 bi ' ~' Y- Y * -

                                                                                                             )

y M " 0 kl ^d5 2 6

                                                                                                                                                                     )                                                                      J h                 6
                                                                                                                                                       -b      JV                 )
                                                                                                                                                                                             ]                D             3 2

U C e g i

                                              ,al R
                                                                          +                q.
                                                                                          %o.

ga a 4 s 4 e gI

                                                                                                                                           .,          d
                                                                                                                                                                 \

m m u, p' % g y

                                                                                                                                                                                                                                        ,A i

O h-

                                         \          s .

s-h' se b. h s-.t -# /* q

                                                                                                                                                                                                                                                                           >i g

ygg! % b b'

                                                                                                              }

1 h,) e 7' p . 't  ?  % [" 'U l w k h Yi 9 h g , y 44l d I

  • p k

t/s 5 7 N $

    .A
                                       ."7
                                                                          ..                         d                  NS                         40-        hI                             t$                k             Df s4 0

I l l l D

      >                                l           f                                                                                                                                                                                                     oc,
".l  ! HS
                                                                                                                                                                                                                                                         .,a O 6                   *I~                            #2-                Q                                                                   4               #'                           I          -#'

j v Id M u V- [ +c O g-IF .b r N j S 37 "i 'O 'tr - T

                                                                                                    'd
                                                                                                      'A W d*d I
                                                                                                                                                   % M           N
                                                                                                                                                                                      .J> *' HV
                                                                                                                                                                                               %/               8

[- V o CW .J 2 c Wh 9

    /                     r ,

{ A O 9% f' I h ' h , Is' .. g $ O au 2 v S t

                                                  ;                           I f                                         C                                                                                                                      .0 I   e 2uC2ac  -yce ce o                     5       V                                                        g 01           9                           g)                                                                 0      20 GGc:cs     0 u

3e Q o sd " a

                                                                                                                        %* q      e{,%e K u,              D  - o                         o                    u uc-uc0:

L b

   --       $>        54 I

g p!

                                                                 %l%

N 99 Y MTM Y eV o:C-so u

                                                                                                   ~l9 i

l s ~ I ~ - o - Ml Y 'J O t s-{ V E si e % e M rs, .A nn".

                                                                                                                                                                                                                                                            , - -}}