ML20059A191

Application for Amend to License DPR-65,requesting Rev to TS 3.8.1.1 by Rewriting Action Statements for LCO

ML20059A191
Person / Time
Site:	Millstone
Issue date:	12/17/1993
From:	Opeka J NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20059A194	List: B14696, Proposed Tech Specs Rewriting Action Statements for LCO ML20059A191
References
B14696, NUDOCS 9312300049
Download: ML20059A191 (10)

Text

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December 17, 1993 Docket No. 50-336-B14696 Re: 10CFR50.90 U.S. Nuclear Regulatory Commission Attention: Document Control Desk -

Washington, DC 20555 Gentlemen:

Millstone Nuclear Power Station, Unit No. 2  ;

Proposed Revision to Technical Specifications Electrical Power Systemi Introduction Pursuant to 10CFR50.90, Northeast Nuclear Energy Company (NNECO) hereby proposes to amend Operating License DPR-65 by incorporating the changes identified in  ;

Attachments 1 and 2 into the Technical Specifications of Millstone Unit No. 2.

In submittals dated April 28, 1993,"' and July 26, 1993,i2' NNECO committed to submit a proposed license amendment which would request that the action statements for the limiting conditions of operation - (LCO)- associated with Millstone Unit No. 2 Technical Specification 3.8.1.1 be revised. This proposed  :

license amendment is being submitted to comply with these commitments. On December 7,1993, the schedule for submittal of the proposed license amendment was discussed with the NRC Staff, and a December 17, 1993, submittal date was- <

mutually agreed to by NNECO and the NRC Staff..

l NNEC0 proposes to rewrite the action statements for the LCOs associated with '  !

Millstone Unit No. 2 Technical Specification 3.8.1.1. - The proposed revisions are the results of lessons learned in response to the condition described in the .

submittals dated April 28, 1993, and July 26, 1993. The intent of the proposed changes is to reduce the number of unloaded emergency-diesel generator (EDG) ,

starts required to be performed to demonstrate operability in accordance with the '

LCOs of Technical Specification 3.8.1.1. A detailed discussion.of the proposed changes is presented below. The marked-up technical specification pages are (1) S. E. Scace letter to the U.S. Nuclear Regulatory Comnission, " Facility Operating License No. DPR-65, Docket No. 50-336, Licensee Event _ Report i 93-007-00," dated April 28, 1993.

(2) J. F. Opeka letter to the U.S. Nuclear Regulatory Commission, " Millstone .

Nuclear Power Station, Unit No. 2, Inspection Report No. 50-336/93-81,  !

Reply to Notice of Violation," dated July 26, 1993.

1 m2 nov oes 270043 ( l l 9312300049 931217 h- jb PDR ADDCK 05000336 1 P PDR g

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1 U.S. Nuclear Regulatory Commission B14696/Page 2 December 17, 1993 provided in Attachment 1, and the retyped technical specification pages are '

provided in Attachment 2. i Backaround In response to Information Notice No. 84-69,* NNECO evaluated Millstone Unit No. 2's practice of loading one EDG in parallel with the grid while the other EDG was declared inoperable. This evaluation almost entirely focused on the issue that the EDGs would not be paralleled with the grid during adverse weather conditions that could jeopardize EDG paralleling operations. The potential risks under these conditions were recognized and acknowledged. However, the counter concern was the potential risk cited by the engine vendor of oil fouling of the engine from unloaded runs. This vendor concern, coupled with the Millstone Unit No. 2 Technical Specification requirement that the EDG be paralleled to the grid for a 60 minute loaded run each month, led NNECO to conclude that performing loaded runs was appropriate, independent of the operability status of the second EDG. On this basis, past practice was considered appropriate until the recent electrical distribution system functional inspection (EDSFI).

The EDSFI was conducted during the period between March 15 and April 2,1993.

The inspection team identified that paralleling an EDG to the grid while the remaining EDG was inoperable was considered a condition adverse to quality.

The Millstone Unit No. 2 condition, regarding the potential of paralleling the '

operable EDG with the offsite electrical power grid while the other EDG was inoperable, was reported under Licensee Event Report 93-007-00 on April 28, 1993.

To resolve this condition, changes to the appropr W e operating procedures and '

surveillance procedures were implemented to pW4!t paralleling the only operable EDG to the offsite power grid. These cha me wre implemented following discussions with the EDG vendor which confirmed urn unloaded EDG runs can be performed with certain considerations without degrading EDG operability.

On June 25, 1993,* the NRC Staff issued the inspection report for the EDSFI.

It contained a notice of violation regarding the paralleling of an EDG to the grid while the remaining EDG is inoperable. NNEC0 responded to this notice of violation in the July 26, 1993, submittal. The submittal delineated the reason for the violation, the corrective actions' that had been taken and. the results achieved, the corrective actions that were required to avoid further violation, the date when full compliance would be achieved, and the generic implications.

(3) E. L. Jordan letter to All Nuclear Power Reactor Facilities Holding an Operating License (0L) or Construction Permit (CP), "IE Information Notice No. 84-69: Operation of Emergency Diesel Generators," dated August 29, 1984, (4) M. W. Hodges letter to J. F. Opeka, " Notice of Violation, NRC Inspection Report No. 50-336/93-81," dated June 25, 1993.

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l U.S. Nuclear Regulatory Commission i B14696/Page 3 December 17, 1993 In the submittal dated July 26, 1993, NNECO committed to provide a license '

amendment which would propose a revision to the action statements of Millstone Unit No. 2 Technical Specification 3.8.1.1. ,

Description of ProDosed Chanaes j

NNECO proposes to rewrite the action statements for the LCOs associated with Millstone Unit No. 2 Technical Specification 3.8.1.1. The intent of the proposed changes is to reduce the number of unloaded EDG starts required to be performed to demonstrate operability in accordance with the LCOs of Technical Specification 3.8.1.1, NNECO proposes to split action statement 3.8.1.1.a into two independent action statements that will separately address the inoperability of an offsite alternating current (AC) circuit and the inoperability of an EDG. The proposed >

action statements are:

"With one offsite circuit inoperable, demonstrate the OPERABILITY of the remaining A. C. sources by performing Surveillance Requirement 4.8.1.1.1 within I hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter. If either diesel generator has not been successfully tested within the past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, demonstrate its OPERABILITY by performing Surveillance Requirement 4.8.1.1.2.a.2 separately for each such diesel generator within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. ,

Restore the offsite circuit to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in t COLD SHUTDOWN within the following 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />." j "With one diesel generator inoperable, demonstrate the OPERABILITY of the A. C. offsite sources by performing Surveillance Requirement 4.8.1.1.1 '

within I hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter; and if the diesel  :

generator became inoperable due to any cause other than preplanned  :

preventative maintenance or testing, demonstrate the OPERABILITY of the remaining 0PERABLE diesel generator by performing Surveillance Requirement 4.8.1.1.2.a.2 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> *; restore the diesel generator to OPERABLE  !

status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in COLD SHUTDOWN within the 411owing '

36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />."

The "*" refers to a footnote that NNECO is proposing to add. The footnote ,

will require the completion of the EDG operability test regardless of when the inoperable EDG is restored to an operable condition.

To support the splitting of action statement 3.8.1.1.a into two separate action statements, each of the action statements of Technical Specification 3.8.1.1 will  ;

have to be renumbered. -

NNEC0's proposed rewrite of action statement 3.6.1.1.b includes:

Revising the statement regarding the demonstration of EDG operability. l The proposed action statement will require that the remaining EDG be j demonstrated operable by performing Surveillance Requirement 4.8.1.1.2.a.2 l

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f U.S. Nuclear Regulatory Commission B14696/Page 4 December 17, 1993 within eight hours, if the other EDG becomes inoperable for any cause other than preplanned preventative maintenance or testing.

Adding a reference to the proposed footnote requiring the completion of the EDG operability test regardless of when the inoperable EDG is restored i to an operable condition.

Rewriting the statement regarding the demonstration of operability for the-remaining inoperable offsite AC source or EDG as follows (note that this statement refers to the proposed action statements): " Restore the other q A. C. power source (offsite circuit or diesel generator) to OPERABLE status in accordance with the provisions of Section 3.8.1.1 Action Statement a or b, as appropriate with the time requirement of that Action Statement based on the time of initial loss of the remaining inoperable ,

A. C. power source." r Adding the following (note that this statement refers to the proposed actionstatements): "A successful test of diesel generator OPERABILITY per 1 Surveillance Requirement 4.8.1.1.2.a.2 performed under this Action Statement for an OPERABLE diesel generator or a restored to OPERABLE diesel generator satisfies the diesel generator test requirement of Action Statement a or b."

NNECO's proposed rewrite of action statement 3.8.1.1.c includes:

Revising the action statement regarding demonstration of operability of two EDGs. The current action statement requires that.the operability of each of the EDGs be demonstrated within one hour and at least once per eight hours thereafter. The proposed action statement will require that both EDGs be demonstrated operable within eight hours.

Rewriting the statement regarding the actions to take after one of the inoperable offsite sources has been restored to an operable status as follows (note that this statement refers to the proposed action statements): "Following restoration of one offsite source, follow Action Statement a with the time requirement of that Action Statement based on the time of initial loss of the remaining inoperable offsite A. C.

circuit."

Adding the following (note that this statement refers to the proposed action statements): "A successful test (s) of diesel generator OPERABILITY per Surveillance Requirement 4.8.1.1.2.a.2 performed under this' Action Statement for the OPERABLE diesel generators satisfies the diesel-generator test requirement of Action Statement a."

NNEC0's proposed rewrite of action statement 3.8.1.1.d includes:

Rewriting the statement regarding the actions to take after one of the inoperable EDGs has been restored to an operable status as follows (note that this statement refers to the proposed action statements): "Following 2

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U.S. Nuclear Regulatory Commission B14696/Page 5 December 17, 1993 restoration of one diesel generator unit, follow Action Statement b with l the time requirement of that Action Statement based on the time of initial loss of the remaining inoperable diesel generator."

Adding the following (note that this statement refers to the proposed l action statements): "A successful test of diesel generator OPERABILITY per 1 Surveillance Requirement 4.8.1.1.2.a.2 performed under this Action -

Statement for a restored to OPFRABLE diesel generator satisfies the diesel generator test requirement of Action Statement b."

Safety Assessment Proposed action statement 3.8.1.1.a provides the actions to be taken with one offsite circuit of the required AC electrical power sources. inoperable. The actions required when one EDG is inoperable are being separated from this action i statement and incorporated into an individual action statement (proposed action statement 3.8.1.1.b).

The performance of Surveillance Requirement 4.8.1.1.2.a.2 to demonstrate EDG operability will be done once within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of declaring the offsite circuit inoperable unless the EDG was previously tested within the past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The existing requirement is to perform Surveillance Requirement 4.8.1.1.2.a.2 within one hour and at least once per eight hours thereafter regardless of the. time at which the last test was performed. ,

Following the loss of an offsite circuit, EDG operability tests are performed to '

verify the availability of a backup power source. The EDGs are designed and are intended to be standby power sources. The present Technical Specifications require that both EDGs be tested initially within the first hour and every eight hours thereafter, regardless of how recently a test has been successfully completed. In a 72-hour period, an initial test within one hour and a follow-up test every eight hours thereafter results in a total of nine EDG tests. This ,

contradicts manufacturer recommendations that the EDGs be tested with a maximum frequency of once per seven days and introduces accelerated EDG wear. However, it is understood that when an offsite power source is lost, EDG availability becomes relatively more important and the EDGs should be tested if they have not been successfully tested in the past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. If an EDG has been successfully tested in the past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, an additional test does not provide any substantial assurance of EDG availability over that provided'in the previous successful EDG operability test. EDG testing within the initial 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> will, in addition to ,

providing assurance of starting capability,' provide additional time for ,

inspection and prelube and other warmup procedures recommended by the  ;

manufacturer to minimize the mechanical stress and wear on the EDGs.  !

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U.S. Nuclear Regulatory Commission  !

B14696/Page 6 l December 17, 1993  ;

l Furthermore, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> permits sequential testing of the EDGs rather than the  !

simultaneous testing of both. These proposed changes are consistent with Generic letter 84-15.*

Repetitive testing increases the likelihood of an EDG failure rather than ,

providing continued assurance of starting capability, especially since loss of an offsite source does not directly imply a failure of the EDGs. Based on the above, the tests required for one inoperable EDG are being separated from this ,

action statement.

Proposed action statement 3.8.1.1.b provides the actions to be taken in response to declaring an EDG inoperable for any cause other than preplanned preventative maintenance or testing. The performance of Surveillance Requirement 4.8.1.1.2.a.2 will be done once within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to demonstrate the operability ,

of the remaining EDG. This test is required to be performed regardless of when the inoperable EDG is restored to operability. However, the remaining operable EDG need not be challenged if the EDG had been rendered inoperable due to preplanned maintenance or surveillance testing. The existing action statement requires the remaining EDG to be demonstrated operable within one hour and at ,

least once per eight hours thereafter.

The reason for performing an EDG operability test following the loss of the other EDG is to ensure that the remaining EDG will be available and capable of starting as designed. Specifically, an operability test of the remaining EDG provides assurance that the remaining operable EDG is not subject to the same failure (i.e., common mode failure). Rather than relying on previous surveillance testing, operability testing within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is proposed consistent with the guidance provided in Generic Letter 84-15. The proposed change does not require the operable EDG to be challenged if the inoperable EDG was rendered inoperable due to preplanned maintenance or surveillance testing. This demonstration of operability is consistent with the Combustion Engineering Owners' Group Restructured Standard Technical Specifications, and the Technical Specifications for the Haddam Neck Plant and Millstone Unit No. 3.

Repetitive operability testing every eight hours following the initial confirmation of EDG availability is unwarranted. Fast starts contribute to premature engine wear.; thus, repetitive operability tests within the 72-hour action statement are not consistent with continued assurance of EDG starting ,

capability. To be consistent with the philosophy of reducing excessive testing and thereby enhancing EDG reliability, only one operability start is proposed as confirmation of the remaining EDG's availability. Testing within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> -

provides timely assurance of starting capability while providing additional time for inspection prior to testing. i b

(5) D. G. Eisenhut letter to All Licensees of Operating Reactors, Applicants for an Operating License, and Holders of Construction Permits, " Proposed Staff Actions to Improve and Maintain Diesel Generator Reliability <

(Generic letter 84-15)," dated July 2,1984. -

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l U.S. Nuclear Regulatory Commission B14696/Page 7 December 17, 1993 I

Proposed action statement 3.8.1.1.c provides the actions to take when one offsite circuit and one EDG become inoperable. Surveillance Requirement 4.8.1.1.2.a.2 will be performed to demonstrate the operability of the remaining EDG within eight hours of declaring one EDG inoperable for any cause other than preplanned preventative maintenance or testing. The EDG operability test is required to be '

performed regardless of when the inoperable EDG is restored to an operable status. The existing requirement is to perform Surveillance Requirement 4.8.1.1.2.a.2 to demonstrate operability of the remaining EDG within one hour and at least once per eight hours thereafter.

Performing an EDG operability test within eight hours of declaring an offsite source and an EDG inoperable provides adequate assurance of the availability of the remaining EDG while eliminating unnecessary starts. A successful EDG operability test performed pursuant to this action also satisfies the subsequent requirement to verify EDG operability within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> under proposed action 3 statements 3.8.1.1.a and 3.8.1.1.b. Additionally, the performance of the test within eight hours provides the requisite assurance while providing additional time for inspection prior to testing.

Proposed action statement 3.8.1.1.d provides the actions to take when two offsite power circuits are declared inoperable. Operability of both EDGs will be demonstrated within eight hours by sequentially performing Surveillance Requirement 4.8.1.1.2.a.2. The existing action statement required both EDGs to be demonstrated to be operable within one hour and at least once per eight hours thereafter, unless the EDGs are already operating.

Proposed action statement 3.8.1.1.d is consistent with proposed action statements 3.8.1.1.a, 3.8.1.1.b, and 3.8.1.1.c with respect to eliminating unwarranted EDG starts. As noted in the discussion for action statement 3.8.1.1.a, loss of an offsite circuit does not suggest that either diesel has become less reliable than '

noted by its previous surveillance test. Given the significance of losing both offsite circuits, one operability test per EDG within eight hours provides ,

adequate assurance of EDG reliability. A successful EDG operability test >

performed pursuant to this action statement also satisfies the subsequent  :

requirement to verify EDG operability within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> under proposed action l statement 3.8.1.1.a. This change is also consistent with the guidance provided in Generic Letter 84-15.

Proposed action statement 3.8.1.1.e provides the actions to take when both EDGs are declared inoperable. With two EDGs inoperable, the operability of the offsite AC circuits must be demonstrated within one hour and at least once per eight hours thereafter. One EDG must be restored to an operable status within ,

two hours or shutdown procedures are initiated. Once an EDG is restored to an operable status, the requirements of proposed action statement 3.8.1.1.b are followed with the applicable time requirements of that. action statement. l Proposed action statement 3.8.1.1.e's requirements for demonstrating the I operability of two offsite circuits, and for restoring a single EDG to an  ;

operable status are the same as the existing technical specification action i statement regarding the inoperability of two EDGs. However, once an EDG has been i

U.S. Nuclear Regulatory Commission B14696/Page 8 December 17, 1993 restored to an operable status, proposed action statement 3.8.1.1.e requires that the requirements of proposed action statement 3.8.1.1.b be followed within the ,

cpplicable time requirements of that action statement. A successful EDG operability test performed pursuant to this action statement also satisfies the subsequent requirement to verify EDG operability within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> under proposed action statement 3.8.1.1.b. This proposed change is consistent with proposed action statements 3.8.1.1.b and 3.8.1.1.c with respect to eliminating unwarranted EDG starts. ,

The proposed changes to revise the LCO action statements for Technical Specification 3.8.1.1 will ensure that the operability of the AC sources is demonstrated with reasonable assurance. Also, the reliability of the EDGs will .

be enhanced by reducing the potential for numerous unloaded EDG starts during an LC0 period. Therefore, the proposed changes do not negatively impact public health and safety. i Sianificant Hazards Consideration In accordance with 10CFR50.92, NNECO has reviewed the attached proposed changes and has concluded that they do not involve a significant hazards consideration.

The basis for this conclusion is that the three criteria of 10CFR50.92(c) are not compromised. The proposed changes do not involve a significant hazards consideration because the changes would not:

1. Involve a sianificant increase in the orobability or consecuences of an accident previously evaluated.

The proposed changes to rewrite the action statements for Technical Specification 3.8.1.1 will decrease the wear on the EDGs by reducing the number of required starts. These changes will also allow adequate time '

for the completion of manufacturer recommended EDG engine prelube and -!

warmup procedures. They ensure that the operability of the AC sources is 4 demonstrated with reasonable assurance. Also, the reliability of the EDGs  :

will be enhanced by reducing the potential for numerous unloaded EDG starts during an RO period. The proposed changes could reduce the number ,

of- required unloaded EDG starts from nine to one. Therefore, these  !

proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated. ,

2. Create the possibility of a new or different kind of accident from any ,

accident previously evaluated.

The proposed changes to rewrite the action statements for Technical '

Specification 3.8.1.1 do not alter the method of operating the plant, nor ,

do they introduce any new-failure modes. The proposed changes affect EDG  ;

testing frequency only, they have no impact on any accident analysis. The i proposed changes provide assurance that the EDGs will be able to power i their respective safety systems if required. Also, they do not involve any physical alterations to plant equipment or procedures which would  !

introduce any new or unique operational modes or accident precursors. l i

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I U.S. Nuclear Regulatory Commission l B14696/Page 9 l December 17, 1993 Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated. -

3. Involve a sianificant reduction in a marain of safety.

j The proposed changes to rewrite- the action statements for Technical l Specification 3.8.1.1 do not affect the capability of. the EDGs to perform their function. The intent of the changes is to increase the overall EDG reliability, by reducing the wear resulting from excessive and unwarranted testing. The proposed changes do not involve a significant reduction in  !

a margin of safety.

Moreover, the Commission has provided guidance concerning the application of .

standards in 10CFR50.92 by providing certain examples (March 6,1986,51FR7751) i of amendments that are considered not likely to involve a significant hazards consideration. While the proposed changes requested by this submittal are not enveloped by any of the examples, the proposed changes to rewrite the LC0 action statements for Technical Specification 3.8.1.1 will provide reasonable assurance i that the AC sources can perform their function as required. Also, the reliability of the EDGs will be enhanced by reducing the potential for numerous unloaded EDG starts during an LC0 period.

1 Environmental Consideration NNECO has reviewed the proposed license amendment against the criteria of  !

10CFR51.22 for environmental considerations. The proposed changes do not involve a significant hazards consideration, do not increase the types and amounts of l effluents that may be released offsite, nor significantly increase individual or cumulative occupational radiation exposures. Based on the foregoing, NNECO concludes that the proposed changes meet the criteria delineated in '

10CFR51.22(c)(9) for a categorical exclusion from the requirements for an  ;

environmental impact statement.

1 The Millstone Unit No. 2 Nuclear Review Board has reviewed this proposed i amendment and has concurred with the above determination. j In accordance with 10CFR50.91(b), we are providing the State of Connecticut with  !

a copy of this proposed amendment. i l

U.S. Nuclear Regulatory Commission  !

B14696/Page 10 December 17, 1993 -

Should the NRC Staff have any questions regarding this. submittal, please contact us.

• Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY  !

< b bad +-

J. F. OpekaJ 7J  : t Executive Vice President cc: T. T. Martin, Region I Administrator G. S. Vissing, NRC Project Manager, Millstone Unit No. 2 .

P. D. Swetland, Senior Resident Inspector, Millstone Unit Nos.1, 2, and 3 ,

Mr. Kevin T.A.' McCarthy, Director -

Monitoring and Radiation Division ,

Department of Environmental Protection 79 Elm Street 1- P.O. Box 5066 .

Hartford, Connecticut 06102-5066  ;

Subscribed and sworn to before me l this /'7 day of /_db' eem/*d,1993

(' ) M/Nf>S <hbut b 4 otary Public N  ;

Date Commission Expires- d!?/7[

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