ML20214Q229

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Insp Rept 99901069/86-01 on 861020-24.Violation Noted:Part 21 Requirements Not Specified on Listed Purchase Orders. Nonconformance Noted:Level III Examiner Records Did Not Contain Statement Re Satisfactory Completion of Training
ML20214Q229
Person / Time
Issue date: 11/17/1986
From: Conway J, Merschoff E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20214Q171 List:
References
REF-QA-99901069 99901069-86-01, 99901069-86-1, NUDOCS 8612050046
Download: ML20214Q229 (14)


Text

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t CRGANIZATION: ROCKWELL INTERNATIONAL FLOW CONTROL DIVISION SULPHUR SPRINGS, TEXAS REPORT INSPECTION INSPECTION NO.: 99901069/86-01 DATE:

10/20-24/86 ON-SITE HClfRS: 28 CORRESP0FDENCE ADDRESS:

Rockwell International Flow Control Division ATTN: Pr. J. J. Osberg Vice President, Plug Valve Products 1511 Jefferson Street, P. O. Box 501 Sulphur Sp.-ines, Texas 75482 ORGANIZATIONAL CONTACT: Thomas W. Schlemm, OA Manager TELEPHONE NUMBER:

(214) 885-3151 NUCLEAR INDUSTRY ACTIVITY: Manufacturer of globe and check valves.

/

<s[s7dz ASSIGNED INSPECTOR:6n J. T. Conway, R ive Inspection Section (RIS)

Date OTHER INSPECTOR:

T. Tinkle, Co ltant yh n

APPROVED BY:

Ellis W. Merschoff, Chie IS, Vendor Program Branch Date INSPECTION BASES AND SCOPE:

A.

BASES:

10 CFR Part 50, Appendix B and 10 CFR Part 21.

B.

SCOPE: The purpose of this inspection was to conduct an evaluation of the implementation of the 0A program in the areas of training, control of special processes, reporting of defects, control of purchased material, nondestructive examination, control of measuring and test equipnent, and audits.

PLANT SITE APPLICABILITY: Not' identified.

i 2050046 861118 99903h6 99 ENVROCI PDR

ORGANIZATION: ROCKWELL INTERNATION FLOW CONTROL DIVISION r

SULPHUR SPRINGS, TEXAS REPORT IMSPECTION N0.: 99901069/86-01 RESULTS:

PAGE 2 of 11 A.

VIOLATIONS:

1.

Contrary to Section 21.31 of 10 CFR Part 21, a review of documenta-tion packages for Section III nuclear valves revealed that while 10 CFR Part 21 was imposed on Rockwell International (RI) by their customers. RI did not specify that 10 CFR Part 21 requirements would apply on Purchase Orders (P0) L6612 to Sherwin, M6635 to RI-Tulsa, L1119 and P1539 to Weldstar, and L4482 to Hylevel Screw Products.

(86-01-01) l B.

NONCONFORMANCES:

1.

Contrary to Criterion V of Appendix B to 10 CFR Part 50, Subsection 1.1 of the Quality Assurance Manual (OAM), Subsection NCA-4134.6 l

of the ASME Code, Section 7 of ANSI N45.2-1977 and Subsections 5.1.7 and 6.2.3 of the CAM, it was noted that:

(86-01-02) a.

Revision A dated January 31, 1984 to RMP No. 61176 " Primer Coating of Carbon Steel Valves for Nuclear Service (Mobil i

zinc)" was not at the coating station.

b.

Revision B dated April 8,1986 to RMP No. 61360 " Combination GTAW Root Fuse and SMAW Filler Welding of P-1 Materials" was

~

not in manuals No.11 (Nuclear Assembly and Test Supervisor) and No.17 (Plant Metallurgist).

c.

PMP No. 61369, Revision C " Procedure for Welding of Permanent Attachments on Stainless Steel Univalves and Hermavalves for Nuclear Service" was in manual No. 11, but a DRF dated November 12, 1985 indicated that LMP No. 61369 was obsolete.

RMP No. 61150, Revision A " Assembling and Testing)Rcckwell-d.

Edward Hermavalves with Leakoff (for Westinghouse " was missing from manual No. 4 assigned to the QA Department.

2.

Contrary to Criterion V of Appendix B to 10 CFR Part 50, Subsection 10.5.1 of the CAM, and Section 9.6.1 of SNT-TC-1A, a review of qualification records for nondestructive examination personnel revealed that the records for the Level III examiner did not contain a statement indicating satisfactory completion of training in accord-ance with QA Instruction No. 40-03-12.

(86-01-03)

ORGANIZATION: ROCKWELL INTERNATION FLOW CONTROL DIVISION SULPHUR SPRINGS, TEXAS REPORT INSPECTION NO.: 99901069/86-01 RESULTS:

PAGE 3 of 11 3.

Contrary to Criterion V of Appendix B to 10 CFR Part 50, Subsection 12.2.1 of the QAM, and Sections 15.2 and 15.3 of QA Procedure 761-40-04-12, a stationary Ph measuring instrument (RI Asset No.

61-3149) was found to be out of calibration and not identified with a REJECT tag or label.

(86-01-041 4.

Contrary to Criterion V of Appendix B to 10 CFR Part 50 and RMP No. 61150, nuclear stainless valves (Assembly Lot H-7510) were hydrostatically tested on October 16, 1986, using Grade B rather than Grade A water.

(86-01-05) 5.

Contrary to Criterion V of Appendix B to 10 CFR Part 50 and Subsection 7.1.4 of the QAM, P0 M4454 was issued to Page Wilson for hardness test samples on August 6,1986, but Page Wilson was not on RI's Approved Vendor List.

(86-01-06) 6.

Contrary to Criterion V of Appendix B to 10 CFR Part 50 and Subsection 9.3.1.5 of the QAM, hardness test results on stem and disc material for nuclear valves on assembly lot numbers H, 4175, 6866, 7011, 7191, 5824, and 5726 were not recorded on an Inspection Card.

(86-01-07) 7.

Contrary to Criterion V of Appendix B to 10 CFR Part 50 and Section 6 of ANSI N45.2, documented instructions / procedures did not exist for the accomplishment of specific inspection requirements (i.e., hardness checks) on the "In-process Heat Treatment" report.

(86-01-C8)

C.

UNRESOLVED ITEMS:

None.

D.

STATUS OF PREVIOUS INSPECTION FINDINGS:

None. This was the first NRC inspection at this facility.

E.

OTHER FINDINGS AND COMMENTS:

1.

Control of Measuring and Test Equipment (M&TE)

The inspector reviewed Section 12 " Control of Measuring and Test Equipment" of the QAM and Procedure No. 761-40-04-12 relating to the calibration control of MSTE. An inspection was made to determine the calibration status of various reasuring instruments

t ORGANIZATI0t.:

ROCKWELL INTERNATION FLOW CONTROL DIVISION SULPHUR SPRINGS, TEXAS REPORT INSPECTION N0.: 99901069/86-01 RESULTS:

PAGE 4 of 11 found in the heat treatment area, welding areas, and the nuclear test areas. The measuring instruments on the heat treatment furnaces are calibrated in situ by a Field Service representative from Honeywell. These instruments were recently calibrated during the period June 23-25, 1986. The Rockwell hardness tester (Podel SDR-P) in the heat treatment area was serviced by Wilson Instruments on December 3,1985 as noted by a sticker on the tester.

The Pressure Gage Calibration Cards for gage X612 were located in the nuclear test area.

It was noted on the card for Assembly Lot H7087 that the gage was calibrated at 1:30 on November 22, 1985, prior to testing and was calibrated at 12:00 on November 23,

.1985, after testing. The calibration sticker for the in-line Ph fneter (RI Asset No. 61-3149) at the demineralized water station in the nuclear test area had a calibration due date of April 1985.

The instrument did not have a REJECT label affixed (see Nonconformance 86-01-04). This matter was brought to the attention of the OC Supervisor who stated that the instrument was not being used. He further stated that the portable, digital Ph meter (Serial No. AAIV) located on a stand next to the in-line Ph meter was being used for Ph measurements of water for hydrostatic testing of valves.

The following Instrument Calibration Cards were checked during an inspection of the Metrology Laboratory:

Item S/f!

Calibration Oue Date Digital Ph Meter AAIU Nov 85 Pressure Gage X547 Feb 87 DC Amps / Volts ADCD Apr 87 DC Amps ADCF Apr 87 Cas Regulator 75028 Oct 87 Dead Weight Tester 13504 Mar 87 Ph Meter 61-3149 Apr 85 Vall Thickness Gage ACNR(NWT-6)

Jan 87 Vall Thickness Gage ACMQ (NWT-4)

Jan 87 The calibration status of the in-line Ph meter in the nuclear test area was discussed with the metrologist. He stated manufacturing had advised him that the meter was not being used. A note to this effect was found on the instrument calibration card. The calibra-tion history for wall thickness gage NWT A was reviewed. The record shows NWT-4 was in calibration when used on October 1,1982 for Assembly Lot H4602 (Body Serial No. LND-57, 59, and 77).

CRGANIZATION: ROCKWELL INTERNATI0M FLOW CONTROL DIVISION SULPHUR SPRINGS, TEXAS REPORT INSPECTION NO.: 99901069/86-01 RESULTS:

PAGE 5 of 11 The Basic Paintenance Agreement (BM-0109) with Honeywell covering the June 86 calibration services for the heat treatment furnace instrumentation was reviewed. The calibration certification indicates Honeywell used a Model 72-311 Biddle (S/N 78940) which was calibrated on May 16, 1986, by the same Honeywell representative providing the calibration services to RI. The certificaticn stated the standard was traceable to the National Bureau of Standards.

RI P0 L7969 was issued to obtain the calibration services under BM-0109.

The meteorologist stated his normal practice is to observe in situ calibration work. However, documentation to support this statement was not available for the June 1986 Honeywell calibration services.

2.

Test Control A pallet of nuclear stainless valves (S/N CD-356 through CD-362) was located in the nuclear test area.

Documentation identified the valves as Assembly Lot H7510.

Investigation revealed the valves were being built for Westinghouse and had completed hydrostatic testing within the past few days. The Hydrostatic Test Report for this order was located in the QA Department and reviewed. The valves were'hydrostatically tested on October 16, 1986 per RMP 61150, and the chemistry results for water used during the testing indicated a conductivity reading of 4 umho/cm.

A review of RMP 61150 noted that Grade A water (maximum ccnductivity of 2 umho/cm) is required for hydrostatically testing stainless valves, and Grade B water (maximum conducti_vity of 20 umho/cm) should be used for carbon steel valves. The test report indicated that the stainless valves on Assembly Lot H7510 were hydrostatically testing).

used Grade B rather than Grade A water (see Nonconformance 86-01-05 The matter was brought to the attention of the QC Supervisor who took immediate action to reject these valves.

3.

10 CFR Part 21 Compliance The inspector reviewed QA Procedure 761-40-52-03 "10 CFR 21:

Reporting of Defects and Noncompliance" dated June 27, 1986. The procedure indicates the Product Engineering Manager shall designate on engineering control documents those items which have critical functions in terms of Section 21.3 of Part 21, and the Purchasing Manager shall state in P0s for critical items that conformance with 10 CFR 21 is required.

Furthermore, the QA Manager is to create a file of all plant transactions involving 10 CFR 21 and is to document all transactions of the 10 CFR 21 Evaluation Committee.

ORGANIZATION:

ROCKWELL INTERNATION FLOW CONTROL DIVISION SULPPUR SPRINGS, TEXAS REPORT INSPECTION NO.: 99901069/86-01 RESULTS:

PAGE 6 of 11 A review of QA Procedure 761-71-04-03 noted that this document identifies valve and valve parts which have critical functions in terms of Section 21.3 of 10 CFR 21. The valve parts which have critical functions are the body, bonnet, cover, disk, bonnet bolting, stem and actuator.

It was also noted that drawings for parts with critical functions shall have a note added to the drawing which reads 10 CFR 21 applies, and Material Specifications (RMC) for parts which have critical functions shall contain a statement which reads 10 CFR 21 applies.

The QA Manager stated that files did not exist for 10 CFR 21 trans-actions since there had been no transactions, and the 10 CFR 21 Evaluation Comittee had never met. A Bill of Material for Assembly Lot H7510 was reviewed, and it referenced Drawing A-21602682 for stainless steel Permavalves, and the drawing invoked 10 CFR 21. The following RMCs were selected for review and found to invoke 10 CFR 21:

RMC 26076, Rev. D, dated July 28,1986, "Austenitic Type 308 Welding Electrodes for Nuclear Service."

RMC 26075, Rev. E dated July 28,1986, "Austenitic Type 312 Welding Electrodes for Nuclear Service."

RMC 70007, Rev. E, dated July 28, 1986, " Carbon Steel Forgings for Nuclear Service."

A number of RI P0s were reviewed to determine if RI was invoHng 10 CFR Part 21 on vendors.

It was noted that RI failed to impose Part 21 reouirements on P0s L6612 dated August 22, 1985 to Sherwin for liquid penetrant (PT) materials; M6635 dated October 8,1986 to RI-Tulsa to calibrate gage blocks; L1119 dated February 1, 1985 and P1539 dated August 29, 1983 to Weldstar for welding electrodes; and L4482 dated March 30, 1981 to Hylevel Screw Products for disks.

(see Violation 86-01-01)

Three locations prescribed by Section 1.3 of QA Procedure 76-40-52-03 for 10 CFR Part 21 posting were checked. The required notice was found in the Nuclear Production Lab, the QA Department, and the bulletin board adjacent to the cafeteria.

Posting prescribed for the Product Engineering area was not checked.

1 ORGANIZATION: ROCKWELL INTERNATION FLOW CONTROL DIVISION SULPHUR SPRINGS, TEXAS PEPORT INSPECTION NO.: 99901069/86-01 RESULTS:

PAGE 7 of 11 4.

Indoctrination / Training of QA Personnel QA Instruction 40-71-00 " Indoctrination and Training of Quality Assurance Personnel" was reviewed. This instruction requires the results of indoctrination and training activities to be documented and filed. Topics, dates, duration of meetings, and names and job titles of attendees are to be recorded. The indoctrination and training records for the following three individuals were reviewed with the OC Supervisor:

ID No.

Function Period GS121 Wall Thickness Measurements Dec 83-Mar 84 GS135 Wall Thickness Measurements Dec 85 LT44 Leak Tester Nov 85 The indoctrination and training records for GS121 and GS135 contained only two entries and both were dated July 29, 1983.

However, a detailed review of QC Department Communication /

Training Meeting Reports in the possession of the QC Supervisor indicated that both individuals had attended numerous training sessions over a period of years.

5.

0A Audits The inspector reviewed QA Procedure 761-40-22-08 "Cuality Assurance Audit Programs" and QA Procedure 761-40-64-04 " Qualification of Quality Assurance Program Audit Personnel." A review of the internal audit records indicated that each section of the OAM was audited annually, and the last internal audit was completed in June 1906. Selected portions of the audit findings were reviewed.

The qualification records for the individuals who performed the audit were reviewed, and all were found to be qualified as an auditor or lead auditor at the time of the audits.

6.

Nondestructive Examination (NDE)

The NRC inspector reviewed CA Instruction 40-03-12 " Training, Examination and Certification of Nondestructive Testing Personnel" and the qualification and certification records of eight NDE person-nel (two-Level III, four-Level II, and two-Level I) to determine that individuals performing PT examinations were qualified and certified to SNT-TC-1A. The instruction indicated that training and examination 1

j

ORGANIZATION: ROCKWELL INTERNATION FLOW CONTROL DIVISION SULPHUR SPRINGS, TEXAS REPORT INSPECTION NO.: 99901069/86-01 RESULTS:

PAGE 8 of 11 were to be in accordance with SNT-TC-1A. Copies of tests and annual eye examinations were on file for each individual. With the exception of a statement showing satisfactory completion of training in accord-ance with QA Instruction 40-03-12 for one Level III examiner, the qualification records of the eight NDE personnel appeared to be in accordance with ENT-TC-1A (see Nonconformance 86-01-03).

7.

Control of Purchased Material and Services The inspector reviewed Section 7 " Control of Purchased Items and Services," QA Instruction 40-64-00 " Review of Purchase Order and Vendor Furnished CMTRs" vendor audit reports, and Approved Vendor Lists (AVL) to assure that items / services were being purchased from qualified vendors. The reports selected for review included audits of Texas Bolt in March 84, Consolidated Castings in August 84, and Sherwin in February 85. A review of past AVLs on file in the OA Department indicated that a number of vendors hold an ASME Ouality System certificate (QSC) for materials.

Three QSC vendors were selected to determine if copics of the QSCs were on file. The Supervisor of QA Engineering provided copies of current QSCs for each of the vendors and stated that RI only retains copies of current OSCs.

The inspector reviewed approximately(27 P0s issued to 12 vendors to assure that quality requirements e.g., ANSI N45.2 and 10 CFR Part 21) were passed on to suppliers / manufacturers of items /

services pertaining to valves destined for nuclear service. The P0s reviewed included:

four to Texas Forge and three to Trinity Forge for SA 105/182 bodies, two to Consolidated Castings for disks, three to Coulter Steel and Forge for SA 479/696 bar, four to Crucible Steel for SA 564 bar, one to Sherwin for PT material, one to Teledyne-McKay and two to Weldstar for welding electrodes, two to Page Wilson and one to Honeywell for material and calibration services, two to Texas Bolt for SA 193 fasteners, and two to Hylevel Screw Products for A565 disks.

It was noted that P0 M4454 dated August 6,1986 was issued to Page Wilson for test blocks for the Rockwell hardness tester. A review indicated Page Wilson was not on the AVL when the P0 was issued (see Nonconformance 86-01-06). This matter was discussed with the Supervisor of QA Engineering who stated that Page Wilson's QA Program had not been audited.

9

.m

t ORGANIZATION:

ROCKWELL TNTERNATION FLOW CONTROL DIVISION SULPHUR SPRINGS, TEXAS REP 0itT INSPECTION NO.: 99901069/86-01 RESULTS:

PAGE 9 of 11 8.

Documentation Packages (DP)

The inspector reviewed 13 documentation packages and 10 P0s from six customers for Section III, Class 1 and 2. globe and check valves. The 10 P0s from 1981 through 1985 from Georgia Power (two), Carolina Power & Light (two), Texas Utilities Generating Company (two), Portland General Electric (one), Florida Power &

Light (two), and Tennessee Valley Authority (one) were for valves two inches smaller and referenced techriical specifications,10 CFR Part 21 and Section III of the ASME Code. The DP consisted of a Ouality Verification Documentation List (0VDL); a RI Certification Package which included a Code Data Report, Certificate of Compliance (CofC) for wall thickness measurements, Metallurgical and Valve Test Certification, and a Final Acceptance Plan; Certified Material Test Reports (CMTR); NDE Records; Heat Treatment Reports; Hydro-static & Functional Test Report; Cleaning Records; Travelers; and a Certificate of Seismic Qualification.

The QVDL certified that the documents for nine categories (e.g.,

hydrotest, beat treat, etc.) met the quality verification require-ments of the specification. The CMTRs were from various manufac-turers for body forgings, bonnets, disks, stems, and weld wire.

The NDE records showed that body, bonnet and disk material were all PT examined. The record identified the Level I and II examiners, the procedure and chemicals used, and the date of the examination.

The heat treatment records included a "In-Process Inspection Heat Treatment" document and time / temperature charts.

It was noted that hardness checks were recorded on the heat treatment document (see Nonconformance 86-01-07).

14. Welding The inspector reviewed Volumes I,11 and III of the Nuclear Welding Control Manual assigned to the Plant Metallurgist. Volurre I contained Welding Procedure Specifications (WPS), Procedure Qualification Records (POR), and welder's Qualification Tests. Five welding PMos selected for review included 61038 "GTAW Canopy Seal Weld," Revision J; 61046 "SMAW Fillet Seal Weld", Revision T; 61093 " Nuclear Proiection Resistance Weld," Revision D; 61105 "GTAW Canopy Hermavalve," Revision 0; and 61149 "GTAW Canopy Sealweld E308,"

Revision B.

The RMP included the WPS and POR. The welder's Performance Qualification Records for the five WPSs ncted above were also reviewed.

It was noted that welder No. 51 was cualified to four of the procedures, welder No. 55 to two procedures and welder Nos. 60 and 70 to one procedure each.

ORGANIZATION: ROCKVELL INTERNATION FLOW CONTROL DIVISION SULPHUR SPRINGS, TEXAS REPORT INSPECTION.

NO.: 99901069/86-01 RESULTS:

PAGE 10 of 11 Volume 11 contained Welder Symbols and the Qualification Status of each welder for a particular process (e.g., SMAW, GTAW, etc.). The Cualification Status records documented the process, date, job No., welder's signature, and supervisor's signature. These records have been maintained on a monthly basis from 1972 to the present.

Volume III contained the visual requirements and welder training program.

Each welder is given an eye examination on an annual basis. The welder / operator training program consists of a nuclear department tour and classroom sessions on " welding" and RMPs. A refresher training program is given annually to each qualified welder. A review of Nuclear Welding Training Sessions records for welder Nos. 51, 55, 60, and 70 indicated that each individual was trained on an annual basis.

During an evaluation of the manufacturing facility, it was noted that welding RMPs were retained in individual folers in a metal cabinet.

The QC Supervisor told the NRC inspector that the Manufacturing Supervisor was responsible for releasing specific RMPs and weld wire for a particular nuclear job. The inspector reviewed three log books for 308, 316, 7018 weld material used on nuclear valves. Document-ation identified the job No., welder, amount of material released and retained, and it was signed by the Manufacturing Supervisor.

15. Plant Tour The inspector toured the RI manufacturing facility at various times during the inspection in the company of RI officials.

Items wit-nessed included:

receiving area and inspection; heat treatment area which uses batch and vacuum furnaces; cleaning area which included electrolytic and diaphragm cleaning processes and electroless nickel plating process; bar;tock storage; welding areas which included projection resistance welding, manual surfacing, and thermal upsetting; machining of bodies and parts; finished part stores which included storage of weld material; nuclear inspection area incorporating PT, wall thickness measurements on forged body, and final inspection; assembly area made up of seat polishing, valve assembly, and hydrostatic testing; coating area; gage calibration; metallurgical laboratory; tool crib; and shipping area.

16. Document Control While evaluating the manufacturing facility, a number of RMPs at various stations were selected to assure that current procedures were at work stations. Three RMPs (Hos. 61036,61048,and61153)

ORGANIZATION: ROCKWELL INTERNATION FLOW CONTROL DIVISION SULPHUR SPRINGS, TEXAS REPORT INSPECTION NO.: 99901069/86-01 RESULTS:

PAGE 11 of 11 were reviewed at the heat treatment station.

It was noted that the procedures were prepared by the Plant Metallurgist and approved by

~

the QA Manager and the Chief Product Engineer. At the PT station, RMP Nos. 61050 and 61152 had been approved by the Level III examiner, the QA Manager, and the Product Engineering Manager. RMP Nos.

61160 and 61093 were reviewed at the final inspection and projection welding stations, respectively. At the cleaning station, RMP Nos.

61065, 61056 and 61189 were reviewed. The 10 RMPs noted above were consistent with the applicable revision contained in controlled manual No. 4 assigned to the QA Manager.

At the coating station, four RMPs (Nos. 61077, 61083, 61176, a'nd 61191) were reviewed.

It was noted that Revision A of 61176 was not at the station. RMP Nos. 61057, 61109, 61146, and 61150 were reviewed at the testing station. Although Revision A of 61150 was at the station, it was missing from the OA department's controlled manual No. 4.

At the laboratory st:ticr., six welding RMPs (Nos. 61038, 61046, 61105, 61149, 61360, and 61369) were reviewed. The welding procedures had been approved by the Plant Metallurgist, QA Manager, and Production Engineering Manager.

It was noted that Revision B to No. 61360 was not in the manuals assigned to the Nuclear Assembly and Test Supervisor and the Plant Metallurgist, and Revision C to No. 61369 was in manual No. 11 (Nuclear Assembly and Test Supervisor) but RMP No. 61369 was obsoleted in November 1985.

(See Nonconformance 86-01-02)

F.

PERSONS CONTACTED:

  • T. Schlemm, QA Manager
  • R. Wolff, Supervisor QA Engineering
  • E. Clifton, QC Supervisor
  • R. Spears, Principal Nuclear Engineer
  • D. Kowalczyk, Manufacturing Operations Manager F. Jisha, Manager, Product Engineering R. Johnson, Metallurgist B. Lewis, QA Documentation Technician

!!. Swann, QA Documentation Technician P. Baxley, Metrologist

  • H. Beuford, ANI
  • M. Bronson, Materials Engineer, QA
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