ML16154A643
| ML16154A643 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 07/22/1994 |
| From: | Harmon P, Skinner P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML16154A644 | List: |
| References | |
| 50-269-94-21, 50-270-94-21, 50-287-94-21, NUDOCS 9408090248 | |
| Download: ML16154A643 (11) | |
See also: IR 05000269/1994021
Text
AREo
UNITED STATES
o
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W., SUITE 2900
ATLANTA, GEORGIA 30323-0199
Report Nos.:
50-269/94-21, 50-270/94-21 and 50-287/94-21
Licensee:
Duke Power Company
422 South Church Street
Charlotte, NC 28242-0001
Docket Nos.: 50-269, 50-270, and 50-287
License Nos.: DPR-38, DPR-47, and DPR-55
Facility Name: Oconee Units 1, 2, and 3
Inspection Conducted: June 15-July 16, 1994
Inspectors:
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P. E. Harmon, Senior Resident Inspector
Date Signed
W. K. Poertner, Resident Inspector
L. A. Keller, Resident Inspector
P. G. Humphrey, Resident Inspector
Approved by:
Act n1=Da
- P.
H. Skinner, Actinf ChiefDt
in'
Reactor Projects Branch 3
SUMMARY
Scope:
This special inspection was conducted to review the circumstances
surrounding the inadvertent lockout of the Keowee overhead
emergency power path on June 14, 1994.
Results:
One apparent violation was identified involving a single failure
vulnerability for the Keowee Units that existed from initial
construction until the completion of-a modification on June 23,
1994. Specifically, loss of all or part of the non-seismically
qualified, non safety-related air system for Air Circuit Breakers
(ACBs) 1 through 4, could have resulted in an automatic lockout of
the emergency overhead power path. This combined with a single
failure that would deenergize the underground emergency power path
would have resulted in a complete loss of on-site emergency power.
In addition to the single failure vulnerability, several
additional concerns were identified during the inspection effort:
Operability determinations were not conducted in a manner
commensurate with the safety significance of the emergency
power supplies. The initial failure occurred on June 14,
1994, but the applicable Technical Specification Limiting
Condition for Operation was not entered until June 22.
9408090248 940722
ADOCK 05000269
a
2
During that period, active work on the air system was
suspended for three days over a weekend. In addition,
the resident inspectors expressed concern to the operations
staff about the apparent single failure vulnerability
of the air system design as early as June 15, but a
formal/documented operability evaluation was not initiated
until June 22.
Numerous single failure vulnerabilities in the emergency
power system have been identified in the past. These
prompted programmatic efforts to identify and correct all
potential single failure vulnerabilities. As evidenced by
this event, these programmatic efforts have not been
completely successful.
The design basis and features of the ACB protective
circuitry for Keowee were not well documented or completely
understood by the plant staff.
Testing of the air system for ACBs 1 through 4 was not
adequate to identify the failure of safety-related check
valves to prevent excessive blowdown of the air reservoirs
associated with ACBs 3 and 4.
Components and systems supplied and designated as "skid
mounted" are considered exempt from the licensee's
controlled drawing program, even when those systems and
components are safety-related. In particular, the breaker
air system did not have a drawing associated with it.
Valve identification tags are not provided for skid-mounted
equipment, even when valves and systems are safety-related.
Maintenance on the air system was not adequate to identify
corrosion buildup in the internals of one of the pressure
regulating valves. The malfunction of this valve, due to
corrosion buildup, contributed to the June 14 lockout event.
REPORT DETAILS
1.
Persons Contacted
Licensee Employees
- B. Peele, Station Manager
S. Benesole, Regulatory Compliance Manager
- D. Coyle, Systems Engineering Manager
J. Davis, Engineering Manager
- B. Dolan, Safety Assurance Manager
- W. Foster, Superintendent, Mechanical Maintenance
- J. Hampton, Vice President, Oconee Site
- D. Hubbard, Component Engineering Manager
C. Little, Superintendent, Instrument and Electrical (I&E)
- G. Rothenberger, Operations Superintendent
- R. Sweigart, Work Control Superintendent
- L. Wilkie, Safety Review Manager
Other licensee employees contacted included technicians, operators,
mechanics, security force members, and staff engineers.
- Attended exit interview.
2.
Background
The Oconee design basis requires that the Keowee Emergency Power System
be capable of supplying power via two independent and separate paths to
all three units of the Oconee Nuclear Station. These paths are referred
to as the overhead path and the underground path. The design basis also
requires that the Keowee Emergency Power System meet the system
functional design basis for design basis events while sustaining a worst
case single failure; and that it not lose its capability to perform
intended safety functions during and following a maximum hypothetical
Keowee Unit 1 can be aligned to the overhead path via Air Circuit
Breaker (ACB)-1, or the--underground path via ACB-3. Keowee Unit.2 can.
be aligned to the overhead path via ACB-2, or the underground path via
ACB-4. ACBs 1-4 are identical 13.8 kV Westinghouse type CA 1500
compressed air circuit breakers. The type CA circuit breaker is
essentially electro pneumatic in operation. These breakers utilize
compressed air at a pressure of 150 pounds per square inch (psi) as a
means for mechanically opening and closing breaker contacts, as well as
for arc suppression during breaker opening operation. Operation of a
breaker utilizes approximately 25 psi of air for an opening cycle and 2
psi during a closing cycle. Keowee has routinely operated with one or
both units generating to the grid. An Engineered Safeguards signal will
automatically divorce the Keowee Units from the grid by opening ACB 1
and 2.
The compressed air system supplying the ACBs consists of two air
compressors, each with an attached header supply tank, feeding a common
2
air header for all four ACBs.
Each air compressor maintains its header
supply tank between 260 and 300 psi.
A pressure regulator associated
with each air compressor maintains header pressure at 150 psi.
Each
ACB has its own reservoir, check valve, and two pressure switches
located on the breaker skid. The reservoir, check valve, and pressure
switches are classified QA Condition 1 and are seismically qualified.
All portions of the air system upstream of the check valves (i.e., the
compressors, their pressure regulators, and the air header) are not
safety-related or seismically qualified. Each check valve is located in
the air piping between the incoming air line and the breaker reservoir
so that a loss of air supply to the breaker will cause the check valve
to close; thereby, preventing air from flowing out of the breaker
reservoir. According to the valve vendor, the acceptable leakage past
the check valve is 5 psi per hour. The two pressure switches have
sensing lines located between the reservoir and check valve. Each
pressure switch has two sets of electrical contacts and employs a
bellows and spring arrangement to "make" or "break" these contacts at
predetermined pressures. If the air reservoir pressure for any of the
four ACBs dropped below 118 psi while that breaker was in service (i.e.,
the breaker and its disconnects closed), then one set of contacts off
the first pressure switch (PS1) would open causing a lockout of the
overhead path (i.e., ACBs 1 and 2 would trip open, and could not be re
closed until the lockout condition cleared). If the air pressure
reduced to 112 psi on any ACB, then both sets of contacts on the second
pressure switch would open and deenergize control power for that
individual breaker; thereby, making it impossible to close or trip the
breaker electrically. The Keowee operator rounds sheet ensures that ACB
air pressure is between 140 -160 psi.
Therefore, ACB air pressure could
be as low as 140 psi without corrective action being taken.
3.
June 14, 1994 Lockout Event and Related Issues
On June 14, at approximately 1:20 p.m., an automatic protective lockout
of the Keowee overhead path occurred. At the time, Keowee Unit 2 was
operating and generating power to the grid via ACB-2, and Keowee Unit 1
was in standby aligned to the underground path via ACB-3.
Technical
Specification (TS) Limiting Condition for Operation (LCO).3.7.1 was
entered due to the overhead path being unavailable. The underground
path was subsequently tested and determined operable within one hour, as
required by TS 3.7.2. The test was performed per OP/0/A/1106/19, Keowee
Hydro At Oconee, utilizing enclosure 3.6, Operability Verification. The
test was performed satisfactorily. The lockout condition was cleared
and the LCO exited at 5:23 p.m.
Subsequent investigation by the licensee revealed that the cause of the
lockout was low air pressure on ACB-3. This occurred when ACB-1 was
being returned to service after completion of a preventive maintenance
activity. Specifically, its air accumulator was being filled from the
common air header for ACBs 1 and 3. The licensee determined that a
combination of leakage past the check valve associated with ACB-3 and a
faulty pressure regulator resulted in a drop of accumulator air pressure
for ACB-3. The problem associated with the regulating valve was due to
'3
corrosion buildup on the valve's internals which resulted in the valve's
discharge pressure being lower than the required 150 psi (licensee
estimated discharge pressure was approximately 120 psi).
Both pressure
regulators were subsequently refurbished following the event.
The
inspectors noted that prior to this event the regulating valves had not
undergone any preventive maintenance.
The inspectors reviewed the incident and performed an inspection of the
Keowee facility the following day. The licensee had replaced the check
valve associated with ACB-3 as a result of the lockout event and
subsequent testing which revealed excess leakage past the seat. The
inspectors observed that there were no obvious visual indications of
degradation on this check valve. The inspectors requested the results
of the previous leak testing of the ACB check valves. The licensee
informed the inspectors that these check valves were not in their ASME
Section XI Program and were not specifically tested for leakage.
However, they were periodically inspected to verify that the check valve
disc moved freely and that there was no visual evidence of wear or
corrosion. Additionally, the entire skid was periodically tested for
leak tightness by closing the individual isolation valve for the
specific ACB and measuring the subsequent pressure drop over time. The
inspectors noted that this test would only be effective in verifying the
overall skid integrity and would not measure the leakage past the check
valve. Consequently, the check valves had never been adequately tested.
The inspectors also noted that there was not a controlled drawing for
the ACBs'compressed air supply system and that the subject check valves
and the skid isolation valves did not have identification tags. The
licensee pointed out that the issue of testing these check valves was
addressed during the Electrical Distribution System Functional
Inspection (EDSFI), conducted January 25 - March 5, 1993 (NRC Inspection
Report 50-269,270,287/93-02). The report noted procedural weaknesses;
but based on discussions with licensee personnel, concluded that the
licensee's practices were adequate to identify a malfunctioning check
valve.
On June 15, the inspectors questioned the design basis for a low
pressure condition on one of the underground.feeder breakers resulting
in a lockout of the overhead path. This appeared to violate the
required independence of the overhead and underground paths. The
inspectors noted that while the 112 psi pressure switch protective
setpoint was part of the vendor's breaker design, the 118 psi pressure
switch setpoint had been added by the licensee (evidently during
construction of the hydro units).
The licensee could not provide the
inspectors the rationale behind the 118 psi lockout. The inspectors, at
that time, expressed concern regarding the testing of the subject check
valves, given their importance to safety. The inspectors communicated
to the licensee that if one or more of these check valves did not meet
its functional requirement, then Keowee was apparently susceptible to a
single failure rendering both emergency power paths inoperable. The
specific scenario communicated to the licensee was a lockout of the
overhead path (resulting from a seismically induced failure of the non-
4
safety, non-seismic air header with leaking ACB check valves) combined
with a single failure that takes out the underground feeder path.
The licensee agreed to look into these issues, but felt that even though
they could not readily explain the purpose of the lockout in question,
the current Keowee design would meet all design basis requirements.
After a review of all applicable design basis documentation and internal
discussions with personnel experienced with the Keowee design, the
licensee was still unable to determine the intent behind having a low
air pressure condition on an underground feeder breaker result in a
lockout of the overhead path. On June 16, the licensee informed the
inspectors that they intended to test the ACBs' check valves on June 20
to verify that the check valves would meet the 5 psi per hour criteria.
The inspectors were also informed that the licensee was considering a
long-term modification to the ACB protective circuitry to delete the
lockout of the overhead path on low ACB air pressure.
On June 20, the licensee began testing the check valves. The check
valves for ACBs-1 and 3 met the acceptance criteria (the check valve for
ACB-3 had been replaced on June 15), but the check valve for ACB-4 was
found to have unacceptable leakage. The parts necessary to repair the
check valve for ACB-4 were initially unavailable; therefore, the
licensee delayed testing the check valve for ACB-2 until repairs were
completed on the ACB-4 check valve. At this point, the inspectors again
expressed concern about the operability of Keowee and questioned why the
licensee was not under the TS LCO until the testing was completed and
all discrepancies resolved. The licensee responded that they did not
have to assume the remaining ACB-2 check valve would not pass the leak
test. Furthermore, it was indicated that they did not have to assume
the non-safety, non-seismic air header would fail during a seismic
event. On June 22, the check valve for ACB-2 successfully passed its
leak test.
On June 22, the licensee entered TS LCO 3.7.2.a.1 for an inoperable
overhead emergency power path. The licensee stated that they entered
the LCO as a conservative measure because the operability was
"indeterminate".
On June 23, the licensee made a 10CFR50.72b.ii.b one
hour call which stated:
"The electrical power system for Oconee is presently vulnerable to
single failure due to reliance on a non-safety system. It was
discovered that an interlock exists which under certain conditions
could lockout the Keowee main transformer. If the air pressure
which operates the Air Circuit Breakers becomes low, a relay will
lockout the overhead power path.
Portions of the air supply to
the ACBs are non-safety. This has resulted in the technical
inoperability of the overhead power path for an indeterminate
time".
The basis for declaring the system inoperable was essentially the same
as the scenario postulated by the inspectors, but with the additional
observation that even if the check valves in question did not leak
5
excessively, the system was not single failure proof. This was due to
the fact that if a Keowee Unit was generating to the grid, and an
Engineered Safeguards signal occurred, the overhead ACB path breakers
would cycle and use up 27 psi of the associated reservoir's supply.
This loss of 27 psi of air, combined with acceptable system leakage (< 5
psi per hour) would result in an eventual lockout of the overhead path.
Subsequent to the notification made to the NRC, the inspectors
determined that the allowable operating range of the ACB air system
(140 - 160 psi) could potentially cause a lockout of the overhead power
path regardless of the status of the air system. Assuming that the air
pressure in a breaker's accumulator was at the low end of the allowable
pressure band (i.e., 140 psi), opening an ACB to remove a Keowee unit
from the utility's grid would rapidly deplete 25 psi pressure in the
reservoir. It is not known whether the 1 inch supply line (assuming it
was available) could have replenished the reservoir's pressure prior to
reaching the 118 psi setpoint.
On June 23, the licensee completed a temporary modification
(TM-1151) which blocked the initiation of the overhead lockout. The LCO
was subsequently exited at 6:36 p.m. The single failure vulnerability
discussed above is identified as Apparent Violation
50-269,270,287/94-21-01:
Single Failure Vulnerability for the On-Site
Emergency Power System Associated with the Keowee Air Circuit Breaker
Protective Circuitry.
The inspectors concluded that the temporary modification was adequate to
remove the single failure vulnerability in question. However, the
protective circuitry associated with the 112 psi setpoint (fails the
breaker "as-is") was still in place. Therefore, the check valves on the
ACB skids still perform an important function. The licensee indicated
that future annual preventive maintenance activities associated with the
ACBs would include adequate testing of these check valves.
4.
Recent History of Design Issues/Studies at Keowee
Keowee was originally constructed as a hydro unit without full quality
assurance programs which are applied to nuclear power plants. Therefore
there were few programmatic controls in place to control and capture the
design basis. From 1989 until January 1993, there were approximately 12
Licensee Event Reports (LERs) submitted regarding Keowee design
deficiencies. Most of these design deficiencies were original
design/construction problems identified during programmatic reviews by
the licensee. As a result of questions raised by these events, and as
part of the corrective actions to ensure that design vulnerabilities had
been identified, the licensee performed a design study of the Keowee
Hydro facility. This study, Keowee Single Failure Analysis, Calculation
OSC 5096, was completed January 1993. The study applied the single
failure criteria as stated in Section 8.3.1.2 of the Final Safety
Analysis Report.
6
The EDSFI found that the licensee had not adequately analyzed potential
single failures within the hydro unit governor control systems. The
EDSFI also identified several other potential single failure
vulnerabilities which had not been sufficiently analyzed (Inspection
Report 269,270,287/93-02).
LER 269/92-14 and NRC Inspection Report 269,270,287/92-24 identified a
relay (Westinghouse MG-6) which had not been properly maintained or
tested. One of these relays had failed and would not have performed its
function. As a result, the Keowee overhead path had been inoperable for
an indeterminate time. Part of the licensee's corrective action for
this issue was to complete the Design Basis Documentation program and to
strengthen the testing program to identify post maintenance, post
modification, or incipient failures in the various safety systems.
5.
Exit Interview
The inspection scope and findings were summarized on July 18, 1994, with
those persons indicated in paragraph 1 above. The inspectors described
the areas inspected and discussed in detail the inspection findings
addressed in the summary and listed below. The licensee did not
identify as proprietary any of the material provided to or reviewed by
the inspectors during this inspection.
Item Number
Description/Reference Paragraph
50-269,270,287/94-21-01
Apparent Violation: Single Failure
Vulnerability for the On-Site Emergency
Power System Associated with the Air
Circuit Breaker Protective Circuitry
(paragraph 3).
ENCLOSURE 2
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ENCLOSURE 2
Federal
Feghter
/ VaL 57.. No. 133 1 Friday. My 10 199 / Notices
us pnor revsews for the Yankee Nuclear
guides currently being developed or
A o
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Power Station. The plant was
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unprovements in all published guides
SertarRu
of the Commission. U.S.
before the requirement for issuance of a
are encouraged at any urns. Written
Nuclear Reulatory Commission.
Final Environmental Statement.
comments may be submitted to the
Washington. DC 205. AlTN:
gence and Pero ns Consuited
Regulatory Publications Branch.
Docketing and Service Branch.
Division of Freedom of Information and
Hand deliver comments to: One White
The NRC staff reviewed the licensees
Publications Serices. Office of
Flint North. 11555 Rockville Pike.
request and did not consult other
Admnistration. U.S. Nuclear Regulatory
Rockville. MD between 7:45 a.m. to 4:15
agencies or persons.
Commission. Washington. DC 20555
p.m.. Federal workdays.
Finding of No Significant ipact
.Reguiatory
guides are available for
Copies of comments may be examined
Finn CofNon iadete i
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inspection a the Commisasion' Public
at the NRC Public Document Room. 2120
The Comanssion has d
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Document Room. 2120 L Stree NW-
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to prepare an envaronmental impact
Washington. DC. Copies of issued
statement for the proposed exemption.
guides may be purchased from the
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Based upon the foregoing environmental
Government Printing Office at the
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current GPO price. Information on
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proposed action will not have a
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Documents. U.S. Government Printing
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For further details with respect to this
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dated May 22.1992, which is available
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guides may also be purchased from the
The NRCs current policy on
Commaston's Public Document Room.
National Technical Information Servac
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120 L Street. NW. Washington. DC
on a standing order basis. Details on
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20555. and at the local public document
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room at Greenfield Community College.
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Procedure for Enforcement Actions."
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ENCLOSURE 2
Fedwina Raio
J VoL 57. No. 133 / Friday, July 10. 1M
/ Nodome
MS76
O
L
Criteria for Sels1
Oe
three catepins of Linr
will be
subject to persomi wceenng that
WamfEN
Coi
e
conuinoal operating reactom.
sigm banne
sers. *&inu ot alarger
Enforcement conferences will not be
hospuials andi other licess. Wh
thanl ir be pamed. and tha
open to tAe MAWli if the aniorcemmn
WWl cousai of the remaining types ai
disruptive persons may be remved.
acio usin Comaiptas
-
Lesit.Ec
-mlofngwWl con
(1) Would be taken qarn
an
I. Ainonamd
Ope ftafmstt
condtict the efroiut
onflerence
iividual. or if the action. Ihougo not
Corn euce
ros
an accerdaoca with regional
take agins anindvidal. urn oa As oon atit i deermnedtha an practime The eaforsmat
coerence
wtake aan
inndividual. cotted 04
a ta
eerie
ht
will continue to be a meoag betwe
wneter A
I*+/-M C~nmited
enforcement confettence will be Open to
the NRC and the licensee While the
wro"OIXpublic observanoz6 the NRC will orally
enforcement conference Is Open for
(2) Involves Aphcfiant paanl
n~
the licnse
that the enfoaicemnt
public observonm. it is not open for
failures where the NRC Wa requested
cofrec tvil be open to publicpuicerael.
that the individual4s) involved be
observation as part of the agency's tria
pi
p
-r
mjnpemm
present at the conference;
prgr
and mad the licensee a copy of
ronPerson aendn ope e tha 41
t
(3)1Is based on the findings of an NRC
thi Fedeal Rs0~to noudce that outlines
apparence voan
mmdoed
a(Iten
Offce f Ivesgeons(01 reortor the program. Licensees wifl be asked to
enfor-sent coafsa
are subject to
(4) Involves safeguardsif formatin
estimate the number d participants it
frhrrve
n
a
esbett
Privacy Act inforatinon. ot otherute
rve
uxorannwhckcol b aerd
will brimg to the menfwwment conference
chnepc
to any reuing
infrmtio wichcold e onsised so that the NRC can schendule an
enfoss mal
acton and (2) dhe
proprietary.
appropriately sized confeenc room.
steensoveworepssnsf
Enforcement conferences involving
The NRC will also, motdy epism
staen
ts o m adeb r emploes at
mfedical mzsadminiatratons or
State liaison officers that en
openin n ma
confRCempees rt
ovarexowes will be open assuming
enforcmn
cofsune~
be been
oack tenforcemnt conerns
the
the conferenc. can be conducted
schedtiled and that it is open to public
lakeprs
a
no otwiW
torbles
without disclosing the sirpoeed
observation.
rern fad' to proidon buelefo.
ind~vdual's name. In addition.
The NRC
Intends to announce open
In
~
adiont rin comnsan
enforcinot c R Imroe will nost be
enforcuent , 6
r
to the pubeS
i
the guysidalc prora thi n o
di ers
open to the public ff thu cF, Im
will
normally at least 10 workzag days in
atte i
n op n nfamenticonperns
be cndutedby elehon oradvance of the enforceumt conference
w be0 provided an apporemwt to
conference will be conducted at a
thog
the olowg u
stimt ritenco
noymosl
relatkiey smal Licensee's facilty.
(1)PNodm
-posetds
k
sumito
Werigion @3...l Thne
muza
Finally. with the approal afth
dwDcma
001
otereogofc.raea
mt
Executive Director for Operations.
(2) Tod1.e
tophne
a *agw
n
will subsequently be fiortwded to the
enforcement conferences wil not be
(3) Toil-free electonac buliom boerd
Director of the Ocs of infrm
for
open to the public in Specal Cam sesnlL
review end considerain
where good mai has bmei shamn altar
Ps;&q establishmeant of the toll-fre
Doted at 8Ae,
i.
t
an h dad muy
balanci ta h s~of public
meA s
MYSm.
the public my cell
IU.
observation against the potential ipact
(poll 492-4M1 to obtain a reVCftn of
For the itueifs asy Cmau
a.
on the agencys anIurmnt action In a
upcof
GPM emamoeme
I. 006li
particular case.
coal ereuces. The NRC will ise another seawuryfahe C
The NRC will strive to conduct open
Federa Regis~
eter ntnah b toil-fre VF Dor 93la
pgd 740f US eaa
enforcement conferences dum@ the
message wete
an eeabmd.
MLL
-OO 109
two~yea mel p~m
an owdam
TO 410011st do NRC to
mub
____________
with the follwing three vaws
approPhate wrefnsilm
to 4 Frt
(1) Apom
as2 pent of ean
public obsurvedof
d
I
a
conuctd by the £4RC wil be open io
atteing!, puuar~lr~
pubic obsurvanm
coe1
q eshomM notify 6s, toividud
m ug
~
m
faR
(2) At loast m open
Id
idendibd in Ow
nef *
msom
du
W
F
conference will be coanmamd i sk &
an
f the opemfu
I
oo
n ~
m .
the regonal offices and
I
m e as i
then Ine b~ir
92n
(3) Open entatm
mi commee
days Poer so the
I
will be conducted wftha imulsy o
oen.M
I
~s
types of licensesm
U4m
To avad pol- mi Wa
e Is
6
A um
seecinA p110ms. ed In am lo met
the three goals sIe &bow @=Wy
Immooodemmwith
msa
luM ~
9110100h
inin n ame dmue aqerns o
to
noa~be MM #do
NBC -- e--1m 44. U.S Cdim,
Nae=
l
iemee wbe
sen in do
@3meon.
M u
o " pbic
momsaemad a
public defthe &W gren&
allowed aess lo the NBC wgid
raised klni
-,i-e,
toad
Howeve. in cee where de
is am
offama to sand "Maen
u
m
forma R1 35-7 Is dAppbmdm fo
ongoing adibetey pmsWAt
Iofmne in aio4
dwith
Redof e(Rdi
Dednm
oOM or G IM tv"os -i Standard Opmung" roaemes for
(CSj.COPMito
avWU
coFea do es
edinis
m ad 10
Provldhq fewmity8-o 9qHM
Fe, NR
IInhel BMWd
so ma
aed baiwe
the subjec meflraof
6"be~
11diaa&
&is~~
V Is~
Mulibe
pse
ia dofawom
adliliao my ale be opened For
Nevey er2.
1
3m
) 2MI
'MThese comdmg~mwn. uM@ekebe