ML20009C137
| ML20009C137 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 07/13/1981 |
| From: | Earley A HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | SHOREHAM OPPONENTS COALITION |
| Shared Package | |
| ML20009C138 | List: |
| References | |
| NUDOCS 8107200315 | |
| Download: ML20009C137 (25) | |
Text
/
AGBy jgt 16 gcigle July 13, 1981 b
u.5.Mn5 NITED STATES OF AMERICA q,/
CLEAR REGULATORY COMMISSION ff cocyssa
'a s
M ro g,7,
..j
,?ur iuLi 6 68f. ' 3 Before the Atomic Safety and Licensing Boar Onade " ".w'N&
y 9g3 ;.:.
4 C :.cl I 1 the Matter of
)
y LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322
)
(Shoreham Nuclear Power Station,)
Unit 1)
)
RESPONSE OF LONG ISLAND LIGHTING COMPANY TO SOC'S JUNE 24 INTERROGATORIES AND REOUESTS FOR PRODUCTION OF DOCUMENTS LILCO responds to those Shoreham Opponents Coalition Interrogatories and Requests, dated June 24, 1981, that comply with pertinent rules of practice.
Objections are noted to the rest.
The case law and regulations supporting the objections have already been set out in LILCO's June 29, 1981 response to earlier SOC interrogatories.
They are not repeated here.
i As indicated below, some of the Comp ny's replies appear in the accompanying summary disposition papers.
SOC Contention 1 1.
As explained in LILCO's attached Motion for Summary Disposition of SOC Contention 1, this contention involves the narrow issues of the adequacy of the generic ten and fifty mile emergency planning zones for Shoreham.
Thus, this question is beyond the scope of the contention.
8107200315 810713 DR ADOCF 05000 pd
2.
See 1.
3.
.See 1.
4.
See 1.
5.
See 1.
6.
See 1.
7.
Yes.
8.
As explained in LILCO's attached summary disposition papers on SOC Contention 1, the ten and fifty mile EPZ's were set generically by the NRC in its emergency planning rulemaking.
After considering all relevant factors, the Commission determined that the EPZ's were consistent with its
" decision to have a conservative emergency planning policy."
See 45 Fed. Reg. 55406 (1980).
The emergency planning regulations do not require, and LILCO has not performed, any l
generic or site-specific studies to confirm the conclusions reached in the rulemaking.
LILCO has, however, considered local conditions such as demography, topography, land characteristics, access routes, and jurisdictional boundaries l
l in setting the exact boundaries of the EPZ's.
The results of i
that censideration are set out in section 3 and section 6 of l
the Shoreham Emergency Plan.
SOC was provided with a copy of l
l this document on June 17, 1981.
See letter of Charles A.
l Daverio to Stephen C.
Latham, dated June 17, 1981.
l.
I i
l 1
,._-.w,..
,..,ym,,.
.,#y.-w v--
e
t t
3-9.
The precise boundaries of the EPZ's for Shoreham are set out in the Shoreham Emergency Plan.
10.
See 8.
11.
Yes.
12.
See 8.
13.
See 9.
14.
See 8.
15a.
The information has been assembled under the supervision and direction of Charles A.
Daverio.
15b.
No decision will be made until it becomes clear what part of SOC Contention 1, if any, will be the subject of hearings.
-See the Daverio credentials included with the attached Daverio Affidavit.
Mr. Daverio works for LILCO and has had this information assembled to deal with SOC Contention 1.
It has not otherwise appeared in " report" form.
See 15b.
SOC Contention 2 la.
Yes.
Ib.
See summary disposition papers on SOC Contention 2.
2.
As explained in LILCO's summary disposition papers regarding SOC Contention 2, the NRC considered a core
" melt-through" accident in the emergency planning rulemaking.
er p--
y 9
,+N y.
y
-,--e
+m y
--+- +
e
^
,,,_cw ra w--,--
. The NRC concluded that the final rule was adequate to protect the health and safety of the public if such an accident occurred.
The Applicant believes that if the emergency requirements set out in the rule are met, the public will be protected in the extremely unlikely event of core mult-through and subsequent release to a " liquid pathway."
3.
LILCO is uncertain as to which regulatory criteria SOC is referring.
4.
See 2.
5.
LILCO's attached Motion for Summary Disposition of SOC Contention 2 discusses in detail the scope of this contention.
As admitted by the Board, the contention involves only the adequacy of emergency plannning requirements for the fifty mile EPZ.
It does not address the specifics of the emergency plans adopted by the Applicant or by state and local authorities.
Thus, this question goes beyond the scope of the contention. In any event, the Applicant has explained why releases to the liquid pathway are adequately addressed in existing emergency planning requirements.
See the attached Affidavit of Brian R.
McCaffrey.
6.
See 5.
7.
See 5.
8.
See 5.
. 9.
LILCO has not completed any qualitative or quantitative assessments of the potential consequences of releases through the liquid pathway due to a core melt at Shoreham.
As explained in LILCO's Motion for Summary Disposition of SOC Contention 1, the Company has engaged a consultant to perf
, an accident consequence analysis. Also, as noted in response to quostion 2, the NRC has already considered the potential impacts of core melt accidents in setting the emergency planning requirements.
LILCO believes that the existing emergency planning requirements adequately protect the public health and safety in the extremely unlikely event of a core melt accident.
See attached Affidavit of Brian R. McCaffrey.
10.
See 5.
lla.
The information has been assembled under the supervision and direction of Charles A Daverio.
lib.
No decision will be made until it becomes clear what part of SOC Contention 2, if any, will be the subject of hearings.
See the Daverio credentials included with the attached Daverio Affidavit.
Mr. Daverio works for LILCO and has had this information assembled to deal with SOC Contention 2.
It has not otherwise appeared in " report" form.
. 13a-b.
See 11 b.
SOC Contention 3 1.
Yes, as explained in the attached summary disposition papers regarding SOC Contention 3.
la.
See 1.
2a.
See the attached summary disposition papers regarding SOC Contention 3.
2b.
No answer is appropriate because the question goes beyond the scope of SOC Contention 3.
3a-d.
No answer is appropriate because the questions both go beyond the scope of SOC Contention 3 and are overbroad in any event.
4.
There is no question 4.
5.
This question makes no sense in the absence of question 4.
6.
Read the portion of SER pages 7-13 cmitted from the SER passage quoted in this question to see what the Staff actually said.
Then find the answer in the attached summary disposition papers regarding SOC Contention 3.
7a-b.
No answer is appropriate because the questions both go beyond the scope of SOC Contention 3 and arc overbroad in any event.
To the limited extent that Regulatory Guide 1.97, Pavision 2, is touched by questions 7a-b, see the attached summary disposition papers regarding SOC Contention 3.
a 8.
Not unless required by the NRC.
See LILCO's response below to SOC's June 24, 1981 questions concerning SOC Contention 8.
In this regard, to avoid further redundancy and confusion, it would be well to deal with thermocouples in one place.
SOC Contention 8 seems to be the most logical place.
9a.
The information has been assembled under the supervision and direction of Brian R. McCaffrey.
9b.
No decision will be made until it becomes clear what part of SOC Contention 3, if any, will be the subject of hearings.
See the McCaffrey credentials included in the attached summary disposition papers regarding SOC Contention 3.
Mr. McCaffrey works for LILCO and has had this information assembled to deal with SOC Contention 3.
It has not otherwise appeared in " report" form.
lla-be See 9b.
SOC Contention 6(a)(i) 1.
Shoreham's constructior. QA/QC program complies with pertinent requirements for reasons indicated in the Gerecke l
i Affidavit, attached as Exhibit 4 to the summary disposition papers regarding SOC Contention 6(a)(i).
2.
Given the limited nature of SOC Contention 6(a)(i),
these requests are grossly overbroad.
They constitute an i
impermissible fishing expedition.
l l
l t
. 3.
See 1.
4-7.
Overbroad -- fishing expedition.
8.
See the attached Gerecke Affidavit.
9-11.
Overbroad -- fishing expedition.
12-14.
See the attached Gerecke affidavit.
15.
Overbroad -- fishing expedition.
16.
Overbroad -- fishing expedition, except as covered in the attached Gerecke affidavit.
17.
Overbroad -- fishing expedition.
18a.
The information has been assembled under the supervision and direction of T.
Frank Gerecke.
18b.
No..: cision will be made until it becomes clear what part of SOC Contention 6(a)(.i), if any, will be the subject of hearings.
See the Gerecke credentials included in Exhibit 4 to the attached summary disposition papers regarding SOC Contention 6(a)(i).
Mr. Gerecke works for LILCO and has had this information assembled to deal with SOC Contention 6(a)(.).
It has not otherwise appeared in " report" form.
20.
See 18b.
.g.
SOC Contention 8 In General The Shoreham reactor has been designed to comply with GDC 13 of 10 CFR Part 50, Appendix A.
The installation of j
in-core temperature measuring devices would not be necessary or useful in meeting this requirement.
The most likely and technically feasible way to achieve in-core te.mperature monitoring capability would be the installation of core exit thermocouples.
But as explained bela--
core exit thermocouples provide no useful additional inft a the operator and thus result in no significant enhancement of the operator's ability to protect the plant or public.
Rather, the combination of existing or planned (as a result of Regulatory Guide 1.97, ?.evision 2) plant
+
instrumentation is sufficient to detect inadequate core cooling without in-core or core exit thermocouples.
This is true for all possible loss of primary system coolant events independent of ECCS operational combinations.
Further, the introduction of thermocouples in a SWR would be a significant and costly design l
l problem that would subject plant personnel to increased radiation exposure.
i The potential usefulness of in-core or core exit f
I thermocouples has been evaluated for scenarios which could lead to uncovering the core. During each phase of such events, l
l thermocouples vould provide no new useful information and might i
t i
e
. even be confus'.ng to the operator.
Existing instrumentation, and operating procedures provide significant diverse indication and mitigation for each phase of the event.
Prior to Uncovering the Core In general, a BWR operates under saturated conditions with very strong natural circulation inside the reactor pressure vessel.
Studies have sacwn that as long as the core remains covered with water, adequate core cooling is assured.
Therefore, cladding breach will not occur until the core is uncovered.
Because of this inherent feature of the BWR, water level is the primary measure of the existence of core cooling during accident situation.
Thus, reactor water level is the key parameter for BWR's on which both automatic and operator actions are based.
Shoreham has highly reliable and redundant reacter water level measuring systems.
Shoreham also has symptom based inventory control emergency procedure guidelines that direct the operator to use the multiple coolant injection and spray systems.
i Shoreham has multiple sources of water injection to the reactor core from below (flooding).
Core flooding is accomplished by both high pressure and low pressure systems.
Not only is there redundancy of systems, but also there is redundancy of pumping capability within the systems.
In i
addition to flooding systems, there is a Core Spray (CS)
L--
+
. system.
This system supplies a water spray directly onto the core from above.
In all, there are at least 12 pumps that can supply spray and flooding to the core.
During the time prior to uncovering the core, core exit thermocouples would indicate, at most, saturation temperature corresponding to the reactor vessel pressure.
Since reactor vessel pressure is already measured, saturation temperature is known.
The core exit thermocouple reading, however, would be erratic due to the subcooling effect of ECCS (core spray and LPCI).
The use of core exit thermocouples would not provide useful additional information for the plant operatnr and the erratic readings might be confusing.
The Uncovered Core After the core is uncovered, the potentia? for cladding breach exists, and, depending on the duration and amount of ccre uncovery, the potential exists for creating local flow blockage as a result of core damage.
Loss of reactor vessel water level indicates the core is uncovered and alerts the operator to the potential for cladding perforations.
i Automatic and operator manual actions would already be underway to restore water level to cover the core.
As noted before, BWR's, including Shoreham, are uniquely provided with symptom based emergency guidelines for reactor inventory control.
l I
Continued monitoring of water makiup system performance i
l parameters, coupled with the eventual return of reactor water i
level provides the capability for monitoring core cooling.
l
. In addition, there are many other parameters available to the operator that are reliable indicators of actual fuel clad breach, and thus inadequate core cooling.
These include high steam line radiation, high off gas radiation levels high area radiation levels in the containment, high hydrogen concentration in the containment, and high radioactivity in reactor or suppression pool water.
Core exit temperature measurement would not provide an unambiguous indication of eitber the potential for or actual clad damage.
This results because Shoreham's safety-grade Core Spray system would continue to supply water over the top of the core even though the core might be uncovered in a bulk sense.
Even if only one core spray pumps functioned (one of two provided), the core exit temperature, whether measured locally or in bulk, would not be superheated.
Core spray need only provide 200 gallons per minute of the minimum design flow rate of 9250 gpm to remove any superheating in the steam.
In summary, during fuel heat-up following the uncovering of the core there would be only one condition at Shoreham for which core exit temperature measurement would provide unambiguous and definitive information.
This would occur only in the highly unlikely event that, following a loss of water inventory, no normal, energency, or alternate water makeup systems would be available to replenish coolant inventory to the pressure vessel.
In this case, the water in
. the core region would boil off and the steam would become superheated.
Under such ccnditions, maasurement of steam superheat anywhere above the core region would indicate core heatup and a low water level.
However, this condition would occur onlv after the operator had already been alerted to the low water level condition.
The operator would also have indication of ECCS system functions and whether injection were available.
The operator guidelines provide safe actions in the event of loss of reactor water level indication and loss of injection.
Recoverv Phase The recovery phase covers the interval after the operator has restored the water level in the core region.
If there were no significant core damage, core exit temperature measurement would not provide any additional aseful information.
The NRC Staff argued in Draft 2 of Regulatory Guide 1.97, Revision 2 that useful information would be provided by in-core thermocouples if 5-10% of the core were damaged.
The Staff contended that high core exit temperature readings would indicate localized propagating core damage (PCD) and quic'e the operator in long term decision making.
This is not true. Once water level was restored in the core, core damage would not propagate to the rest of the core. And studies show that localized heating of a damaged channel would not cause superheating that would be detectable at the i
. thermocouples.
Thus, thermocouples would not provide any additional useful information.
More detailed information about core the.mocouples is contained in the attached G9neral Electric rep.t entitled
" General Electric Evaluation *.*of the Need for BWR Core Thermocouples."
1.
Yes.
2a.
Yes.
2b.
See 2a.
2c.
See the general response above.
3.
No.
3a.(1)-(3) See the general response above.
3a.(4)
Yes.
3a.(5)
See LILCO's response to NUREG-0737, a copy of which was sent to SOC on June 17, 1981.
See letter of Charles A.
Daverio to Stephen C.
Latham, dated June 17, 1981.
3a.(6)
See the general response above.
4a-b.
The Applicant's position, both individually and as a member of the Licensing Review Group, is that core thermocouples are not necessary to comply with 10 CFR Part 50, Appendix A, GDC 13.
4c.(1)
See the general response above and the attached General '..actric report.
4c.(2)
See 4a-b.
5.
See the general response above.
1
. 6a.
The information has been assembled under the supervision and direction of David J.
Robare.
6b.
No decision will be made until it becomes clear what part of SOC Contention 8, if any, will be the subject of hearings.
7a-f.
See the Robare credentials included with the attached Robare Affidavit.
7g-h.
Mr. Robare works for General Electric and has had this information, including the attached report entitled
" General Electric Evaluation of the Need for BWR Core Thermocouples" assembled to deal with SOC Contention 8.
General Electric has produced other information for the NRC on this issue but it has not been presented to LILCO in " report" form.
l SOC Contention 9 l
1.
The systems to which Regulatory Guide 1.47 applies are listed in FSAR figure 7.1.1-2.
For each system to which it applies, the Shoreham design complies with Regulatory Guide 1.47 except for:
l (a) system inoperative alarms for the l
scre+;nwell pumphouse vent systems relay, the emergency switchgear room exhaust air systems, the battery room vent systems, the RBSWS chiller I
l t
i
I equipment room vent systems and 1
diesel rooms emergency vent system; and (b) the portion of the compressed air system serving the SRV's.
The alarms listed in (a) above can not be manually activated in the control room.
Since the auto alarm function monitors all metheds of inoperability, a manual switch is not necessary.
The portion of the compressed air system serving the SRV's does not have a unique system inoperative alarm.
Instead, motor operated valven in this system are monitored by system degraded alarms and valua loss of control alarms that can detect if the system has been deliberately rendered inoperative.
2.
LILCO believes that Regulatory Guide 1.47 applies t' I
the systems indicated in FSAR figure 7.1.1-2.
3.
A revision to these figures is currently being prepared.
The change will be issued as an FSAR amendment that will be sent to SOC.
4.
The "x" indicates that Regulatory Guide 1.47 is applicable to the system.
4a.
Yes.
. 4b-c.
Except as indicated in 1 above, the systems to which Regulatory Guide 1.47 is applicable have system inoperative alarms that meet section C.3 of the Guide.
System descriptions and diagrams are contained in FSAR Chapter 7.
5.
Certain indications of a bypassed or disabled condition are important to the safe operation of Shoreham.
See FSAR figure 7.1.1-2 for those systems to which LILCO feels Regulatory Guide 1.47 applies.
6.
See 5.
7.
See FSAR section 7 and FSAR response 223.23.
8.
The review of systems and components to determine which are important to safety begins with the design basis of the plant and continues throughout the life of the plant.
The FSAR is updated periodically to reflect any changes.
9.
Yes.
9a-b.
Regulatory Guide 1.97, revision 2 changed the classification of various instruments.
See LILCO's responses and summary disposition papers regarding SOC Contention 3 for w
the Company's response to Regulatory Guide 1.97, revision 2.
loa.
The information has been assembled under the supervision and direction of Brian R. McCaffrey.
10b.
No decision will be made until it becomes clear what part of SOC Contention 9, if any, will be the subject of hearings.
. lla-f.
See the McCaffrey credentials included in the summary disposition papers regarding SOC Contention 3.
Mr. McCaffrey works for LILCO and has had the information assembled to deal with SOC Contention 9.
It has not otherwise appeared in " report" form.
See 10b.
SOC Contention 12 (Part Two) la.
This contention is limited to the issue of downcomer bracing.
For the reasons explained in LILCO's attached Motion for Summary Disposition of SOC Contention 12 (part two), the Company believes that this issue has been resolved satisfactorily.
To the extent that this question involves other Mark II issues, it goes beyond the scope of the contention.
Ib.
See LILCO's attached summary disposition papers regarding SOC Contention 12 (Part Two). All documents relied upon there are a matter of public record.
2.
See LILCO's attached summary disposition papers.
3a-c.
As written, these questions go beyond the scope of the contention.
To the extent they ask for information concerning downcomer bracing, the answers can be found in the attached summary disposition papers regarding SOC Contention 12 (part two).
m
. 4-6.
See LILCO's attached summary disposition papers regarding SOC Contention 12 (part two) for a description of the impact of decoupling the downcomer bracing from the pedestal and suppression pool wall.
6.
See the attached summary disposition papers regarding SOC Contention 12 (part two).
7.
No answer is appropriate because the question goes beyond the scope of SOC Contention 12 (part two) and is overbroad in any event.
8.
See 7.
9.
See 7.
10a.
The infc.mation has been assembled under the supervision and direction of Brian R. McCaffrey.
10b.
No decision will be made until it becomes clear what part of SCC Contention 12 (part two), if any, will be the subject of hearings.
See the McCaffrey credentials included in the summary disposition papers regarding SOC Contention 3.
Mr. McCaffrey works for LILCO and has had this information assembled to deal with SOC Contention 12 (part two).
It has not otherwise appeared in " report" form.
See 10b.
SOC Contention 12 (Part Three) 1-13.
No answers are appropriate because SOC has no admitted contention on hydrogen generation.
SOC Contention 15 la.
Yes.
Ib.
At time of fuel load.
See Safety Evaluation Report (SER) at 4-11.
2.
No.
3.
See 2.
4.
Overbroad -- fishing expedition.
5.
No.
6.
Procedures will be developed to address the concerns in IE Eulletin 79-26 consistent with the schedule in the SER.
7.
No.
At the present time, LILCO believes procedural modifications contained in the Bulletin are sufficient.
8.
New instrumentation for Reactor Coolant System Soluble Boron Concentration is required under Regulatory Guide 1.97, Revision 2 by July 1983.
Full details on the system's capabilities are not yet available.
9a.
The information has been assembled under the supervision and direction of Brian R. McCaffrey.
9b.
No decision will be made until it becomes clear what part of SCC Contention 15, if any, will be the subject of hearings.
e
. 10a-f.
See the McCaffrey credentials included in the attached summary disposition papers regarding SOC Contention 3.
Mr. McCaffrey works for LILCO and has had this information assembled to deal with SOC Contention 15.
It has not otherwise appeared in " report" form.
See 9b.
SOC Contention 16 In General The Shoreham design, analysis and documentation are in full compliance with 10 CFR Part 50, Appendix K, Section I.
The fuel clad swelling and rupture model concerns addressed in NUREG-0630 have been evaluated by General Electric.
A report entitled, " General Electric Fuel Swell and Rupture Model Experimental Data Review and Sensitivity Studies May 12, 1981" was submitted by General Electric (R. H.
Buchholz) to the NRC (L.
S.
Rubenstein) on May 15, 1981.
A copy is attached.
This report was prepared in response to the NRC request to:
a) provide supplemental calculations using the NUREG-0630 model and, b) to revise the cladding models of both CHASTE-05 and CHASTE-06 to conform to recent experimental date.
fp
. It provides (1) a discussion of the experimental data used to develop the General Electric and NUREG-0630 cladding swelling and rupture models, and (2) the results of sensitivity studies performed using the General Electric heatup model (CHASTE), which show the impact of the NUREG-0630 model on calculated peak cladding temperatures.
It also shows that the NUREG-0630 perforation strain versus temperature curve is not applicable to BWR's due to non-prototypicality of the experimental conditions used to generate the curve.
Even so, substitution of a bounding NUREG-0630 curve into the current GE ECCS analysis produces a negligible effect on the peak clad temperature (PCT).
Therefore, the current strain model is valid for BWR's and should :entinue to be used for all ECCS analyses.
This report also shows that the GE hoop stress versus rupture temperature curve is more valid than the corresponding NUREG-0630 curve at temperatures above 1600 F.
A sensitivity study using a combination of the two curves (adjusted curve) resulted in a negligible PCT impact of 10 F.
Specific Replies to Questions 1.
Yes.
See the general response above.
2a-b.
Clad swelling and rupture modeling was performed for LILCO by the General Electric Company.
A description of the models used appears in " General Electric Company Analytical Model for Loss-of-Coolant Analysis in Accordance with 10 CFR 50
. Appendix K," NEDO-20566, Volume 1, January 1976.
Further information on the models is included in the general response above and the attached General Electric letter. As noted in NUREG-0630, General Electric has not performed flow blockage modeling.
t 3.
See the general response above.
4a-b.
See the general response above.
Sa.
The information has been assembled under the supervision and direction of David J.
Robare.
Sb.
No decision will be made until it becomes clear what part of SOC Contention 16, if any, will be the subject of hearings.
6a-f.
See the Robare credentials included with the attached Robare Affidavit.
6g-h.
Mr. Robare works for the General Electric Company and has had this information assembled to deal with SOC Contention 16.
It has not otherwise appeared in " report" form to LILCO.
General Electric has, however, submitted reports to the NRC concerning clad swelling and rupture.
These reports are referenced in NUREG-0630 and the attached General Electric letter.
7a-b.
See Sb.
e s
. SOC Contention 17 la-f.
FSAR figure 7.1.1-2 indicates to which Shoreham systems LILCO believes IEEE 279-1971 is applicable.
The indicated systems are in compliance with section 4.16 of IEEE 279-1971.
To the extent this question asks about compliance with other sections of IEEE 279-1971, it is beyond the scope of the contention.
2.
See 1.
A description of how each system complies with section 4.16 of IEEE 279-1971 is included in FSAR Chapter 7.
3.
See 1 and 2.
4.
The review of Shoreham's design to determine the applicability of the NRC's requirements including Section 4.16 1
of IEEE 279-1971, is a continuing process.
The latest assessment of Shoreham's compliance is included in the FSAR.
5.
See the attached LILCO response to Items 1 and 5 of I&E Bulletin 79-08.
6a.
The information has been assembled under the supervision and direction of Brian R.
McCaffrey.
6b.
No decision will be made until it becor.es clear what part of SOC Contention 17, if any, will be the subject of hearings.
7a-f.
See the McCaffrey credentials included in the summary disposition papers regarding SOC Contention 3.
c.
. j 7g-h.
Mr. McCaffrei works for LILCO and has hud the
{
information assembled to deal with SOC Contention 17.
Except as indicated above, it has not otherwise appeared in " report" form.
Respectfully submitted, LONG ISLAND LIGHTING COMPANY
-Y e
/
3 i ~
e q: ' s..
j, j
,. i_.
'W.' Taylor Reveley,-III
/
Anthony F.
Earley, Jr.
/
Hunton & Williams P.
O.
Box 1535 707 East Main Street Richmond, Virginia 23212 Dated:
July 13, 1981 4
l l
{
\\
l
\\
l l
W_-