ML20073C690
| ML20073C690 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 04/08/1983 |
| From: | Mark Miller KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8304130269 | |
| Download: ML20073C690 (17) | |
Text
b Q'~E TfD UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'83 m ;g p9 95 Before the Atomic Safety and Licensing Board
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In the Matter of
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LONG ISLAND LIGHTING COMPANY
)
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Docket No. 50-322 (OL)
(Shoreham Nuclear Power Station,
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Unit 1).
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MOTION TO COMPEL LILCO TO FILE A WRITTEN REPORT CONCERNING THE TELEDYNE ENGINEERING SERVICES DESIGN REVIEW OF SHOREHAM Suffolk County hereby requests the Board to issue an order compelling LILCO to file with the Board and all parties within five (5) days from the date thereof a written report (a) detailing the status of the design review being conducted by Teledyne Engineering Services ("Teledyne"), (b) explaining the reasons for the delays in the issuance of the Teledyne final report and estimating the date of such report, and (c) describing all contacts and communications between LILCO and Teledyne with respect to the review.
On March 15, 1982, LILCO met with the Director of the Office of Nuclear Reactor Regulation ("NRR").
At that meeting, LILCO presented an overview of Shoreham's QA program which, according to LILCO, provided " confidence" that the kind of problems which had been found in the quality and construction of other nuclear plants were not present at Shoreham.
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However, by letter dated April 16, 1982, LILCO informed the NRC that it had commissioned Teledyne to conduct a design review of one system in the Shoreham plant.
LILCO asserted that its decision to commission Teledyne emphasized Shoreham's " commitment to quality."
It acknowledged, however, that Teledyne also had been hired "to address the NRC concerns raised as a result of recent design and construction problems at other facilities."
A copy of LILCO's April 16, 1982 letter is attached hereto as Exhibit 1.
Although the scope of the Teledyne review is limited to one core spray loop system, LILCO claims that the review is
" representative of the controls applied to the design, construc-tion and verification of all plant systems."
See Exhibit 1.
For this reason, Suffolk County believes that the Teledyne review.
is directly relevant to the QA/QC contentions in this proceeding.~1/
LILCO's own QA/QC testimony agrees with this position, asserting the Teledyne review will add additional assurance to shoreham's QA program.
Thus, among other things, the review is examining the installed piping, components and supports of the core spray loop system in order to determine whether the QA program properly monitored and documented the design, procurement and installation procedures used for that system.
LILCO Exhibit 21, at 128-30.
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Contention 12, for example, alleges that LILCO has not adequately demonstrated that the QA program for the design and installation of structures, systems and components for Shoreham was conducted in compliance with 10 CFR Part 50, Appendix B.
In addition, Contentior. 15 contends that the Shoreham QA/QC program has involved inadequate review and physical inspection to verify compliance with 10 CFR Part 50, Appendix B.
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Suffolk County has previously made known its position that the Teledyne review is highly relevant to these licensing proceedings.
- See, e.g.,
Tr. 20,123.
Indeed, during the course of the QA/QC hearings, the County sought to cross-examine tne LILCO witness panel on the subject of the Teledyne effort.
That' examination was limited by the unavailability of the Teledyne report.
See Tr. 12,532-33.
At no time, however, wa.s the County's line of questioning challenged on the basis of its relevancy to the matters in contention.
To the contrary, the County was led
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to believe that, once Teledyne's review was complete, it would l
l be entirely appropriate to inquire into the findings and conclusions 2/
of the final. report.
In this regard, the Staff also indicated l
its desire to review extensively the Teledyne report.
See Tr. 17,557-58.
The Teledyne review and final report were scheduled for completion last August, but still the report has not been issued.
This delay of some eight months has clearly disadvantaged the County.
This Board, at the urging of LILCO and the Staff, has now effectively closed the record on the County's QA/QC contentions.
l See Tr. 20,309.
For that reason, any request for a hearing on 1
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The County notes the careful consideration given by the Board and the parties to the Torrey Pines. Technology ("Torrey Pines")
review of Shoreham's construction.
Certainly, Teledyne's review of the Shoreham design control program, albeit limited to only cne system, is no less relevant to the County's' QA/QC contentions, especially in light of the fact that Torrey Pines assumed for the purposes of its review that the plant's j
design was adequate.
l the Teledyne review effort will be held to a standard "very 1
close to the reopening standard."
Tr. 20,307.-3/
Under this standard, it will apparently be incumbent on the County to demonstrate the significance of the Teledyne final report to the QA/QC issues in evidence.
Only if that initial and subjective i
burden is met will the Board then consider whether to allow examination into the Teledyne review effort.
See Tr. 20,307-09.
The County's review of the preliminary findings and other limited data thus far made available by Teledyne has indicated that the County's concerns about the safety _and QA/QC significance of Shoreham's design may be justified.
The County's review, however, has necessarily been restricted.by the failure of Teledyne to complete and issue its final report. -For this-reason, the County has requested the Board to encourage the prompt completion of the report so ths'. the findings of the 3
report can be included in the Board's overall findings on the adequacy of Shoreham's QA/QC program.
See Tr. 20,126.
The Board, however, has declined this request.
Further, the County's desire to obtain any information-possible concerning the Teledyne review has been frustrated by the Staff.
On three occasions during the last few weeks, the 1
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While the Board has stated that this standard is not meant to be a " burden" to the County, noting that the County cannot be held accountable for the delay in issuance of the Teledyne report (see Tr. 20,307), the Board's decision nevertheless does require a more rigorous standard for the County than would be the case if the Teledyne report had been timely issued.
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1 Staff has scheduled, and then cancelled, meetings with LILCO and Teledyne to discuss Teledyne's review effort and its preliminary findings of Shoreham's design.-4/
Most disturbing of all, on March 29, 1983, the County j
was informed by the Staff that there would be no Staff meeting with LILCL and Teledyne until the final report was completed and issued by Teledyne.
The County was advised that this postponement and change in Staff position were made at the request of the.
l management of LILCO and Teledyne.
Thus, at this time, there is still no final report, and any opportunity for the County to obtain additional information about the Teledyne review effort j
has been further restricted by LILCO.
The unexplained de'.ays in the issuance of the Teledyne report, the mysterious cancellation of meetings, and the manner in which information regarding these matters has been blacked out, raise important issues regarding the review.
Without 4
impugning the motives of LILCO or Teledyne or in any way suggesting improper contact between them, the County believes 4
that it, the Board, the Staff and other parties would benefit by.
an explanation of these matters.
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The Staff's initial meeting was scheduled for March 1, 1983.
That meeting was later cancelled and rescheduled for March 17, 1983.
However, shortly before the March 17 meeting was to be.
held, it was cancelled and rescheduled to March 30, 1983.
This meeting was also cancelled and, at this. time, the Staff has not determined when the meeting will be rescheduled.
The Staff's notices for the March 1, March 17 and March 30 meetings are attached hereto as Exhibit 2..
1 Accordingly, the County respectfully requests the Board to order LILCO to prepare and #ile the report heretofore described.
Respectfully submitted, David J.
Gilmartin Patricia A. Dempsey Suffolk County Department of Law Veterans Memorial Highway Hauppauge, New York 11788 bbt Ykf!!v Herbert H.
Brown Lawrence Coe Lanpher Michael S. Miller Kirkpatrick, Lockhart, Hill, Christopher & Phillips 1900 M Street, N.W.
Washington, D.C.
20036 Attorneys for Suffolk County April 8, 1983
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EXHIBIT 1 m
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fgg@S LONG ISLAND LIGHTING COM PA'NY k__,. /N/J.f.HNAM!/ -}
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April 19, 1982 SNRC #689 Mr. Harold R.
Denton,. Director Office of Nuclear ReaUor Regulation U.S. Nuclear Regulatory Commission Washington, D.C'.
20555
,As.surance of Shoreham Design an~d Construction, QA Control Shoreham Nuclear Power Station - Unit 1 Docket No. 50/3221.
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Dear Mr. Denton:
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-v On March 15, 1982, my Staff and I met with you to present an ove'rview of LILCO's' Quality Assurance Program and to highlight the basis for ur confidence that the recent problems which have been found 'in the quality of design and construction at other:
plants are not inherently present in the Shoreham Project.
Enclo-sures A through E to this lette'r, document for you the material whi~ch was presented at that meeting and respond to requests for additional information and clarification of several topics.
To further W asize Shoreham's commitment to quality and to address the NRC Tcerns raised as a. result of recent design and construction probe. o at other facilities, we have decided to a
proceed with an independent' review that will be representative of the controls applied to the design, construction and verification of all plant systems.
The scope of this review will encompass a full Core Spray Loop and is described in Enclosure F.
We have contracted with Teledyne Engineering Services to undertake this effort on the basis of their technical depth, resources, experience with similar workscopes at LaSalle and Diablo Canyon, and their independence from the design, construction and quality assurance of Shoreham Nuclear Power Station.
We anticipate forwarding to you a detailed Program Plan by May 10, 1982 and having all work completed
. prior to exceeding a 5% power level.
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EXHIBIT 1
,. LONG LSLAND IJGHTING COMPANY SNRC #689 Mr. Harold R. Denton April 19, 1982 Page Two a
Independent of the referenced review to be undertaken, my confidence that Shoreham has been engineered, designed, and constructed properly )hd that the plant that now sits at the Shoreham site does reflect the plant shown on our design drawings '
and in-ou.r design calc'ulations is based upon the following l
- rationale:
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The organizations which have designed and built
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Shoreham have a long and successful record in
. projects of this type.
LILCO selected a large broad based,. nuclear experienced architect engi-neering firm ll Stone & Webster Engineering Corporation,(SWEC), at the beginning of the proje6t to provide the lead and directly manage and control virtually all the design and engi-1 f:
neering.
Dur Nuclear Steam Supply vendor, General Electric Company, interfaces directly with SWEC on T
Shoreham design and has also been a leader in the i
deve.lopment o'f nuclear power.
Both of these organ-izations have rigorously applied design control l
,.3 programs since 1969 and are audited extensively, 4
internally and externally, by LILCO and other
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utilities.
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The Shoreham design and construction has been effectively organized and controlled through the l
project ranagement conc.ept within SWEC and.LILCO.
l This project management concept has provided for the centralization of design responsibility within SWEC and the close monitoring of this effort by l
LILCO Project personnel.
It is our belief that the application of these comprehensive management con-trols has resulted in a final product which will not suffer from problems which have " fallen through 1
a crack."
The LILCO QA involvement with design, engineering 3.
and construction activities has been widespread, comprehensive and administrative 1y independent.
LILCO has always acknowledged that the satisfactory perfon.;ance of QA/QC functions requires manpower commitments by ourselves and Stone & Webster Engi-neering Corporation.
More than two thousand (2,000) audits have been conducted on design and construction i
activities during the past nine (9) years.
Problens have been identified and the appropriate corrective and preventive actions taken.
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LdNG 4dLAND L.lGHT1NG COMPANY i
SNRC $689
' Mr. Harold R. Denton April 19, 1982 Page Three Further confidence in Shoreham's quality has -been
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4.
- gained through the results of reviews and audits
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performed bytoutside sources such as third party design reviews and investigations, third party Shoreham audits and special NRC investigations.
has been subjected throughout its history to very careful scrutiny not only because of our own con-cern for plane safety, but frankly because of the pressures of.the anti-nuclear movement upon the various regulatory agencies.
I do not believe that any plant has been more closely watched than the Shoreham Pla'nt and I do not believe that any plant g,
has received such consistent " good marks" as a result of this scrutiny.
Finally, LILCO and SWEC are conducting additional
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These quality verification programs at this time.
programs spadjthe verification of implementation of licensing commitments, designg changes, piping analysis, piping' and support configurations,
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electrical raceway qualifications, documentation These programs packages and drawing updating.
represent a substantial manpower commitment dedi-cated to design and construction verification and will provide LILCO management with added assurance of Shoreham's quality.
It is my understanding that LILCO will be required to submit to you, sixty (60) days prior to Fuel Loading, a final statement assuring that the plant is designed and built safely and The basis for our in accordance with the licensing conditions.
conclusions in this statement will be the summarization of facts presented in this submittal, the satisfactory results of the numerous quality verification programs for design and construction which are and the conclusions presently being conducted by LILCO and SWEC, reached from the in Engineering Services.
L. Smith of my Staff is available at (516)'929-6700, Extension 255 for any additional information you or your Staff require, Mr. J.
i
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Yours very truly, m.cAu M. S. Pollock Vice President-Nuclear Enclosures cc:
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UNITED STATES.
EXHIBIT 2
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<-NUCLEAR REGULATORY COMMIS.vN
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- ,4 FEB 15 E83 Docket No. 50-322 MEMORANDUM FOR:
A. Schwencer, Chief Licensing Branch No. 2 Division of Licensing FROM:
- R. Caruso, Project Manace.-
Licensing Branch No. 2, DL
SUBJECT:
FORTHCOMING MEETING WITH LONG ISLAND LIGHTING COMPANY (LILCO) AND TELEDYNE ENGINEERING SERVICES (TELEDYNE)
DATE & TIME:
Tuesday, March 1,1983 9:00 AM - 4:00 PM LOCATION:
Room P-110 Phillips Building Bethesda, MD PURPOSE:
To discuss trie Independent' Design Verification Program Findings for Shoreham.
PARTICIPANTS-:
NRC LILC0 Tel edyne R. Caruso J. Smith, et al.
D. Landers, et al.
R. Bosnak E. Sullivan 4 44' R. Caruso, Project Manager Licensing dranch No. 2 Division of Licensing cc:
See next page EXHIBIT 2
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Shoreham Mr. M. S. Pollock Vice President - Nuclear Long Island Lighting. Company
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1/5 East Old Country Road Hicksville, New York -11801 i
MHB Technical Associates
- cc:
Howard L. Blau, Esquire Blau and Cohn, PC.
1723 Hamilton Avenue, Suite K San Jose, California 951.25 217 Newbridge Road Hicksville, New York 11801 Stephen Latham, Esquire Mr. Jay'Dunkleberger Twony, Latham & Shea New Yod State Energy Office Post Office Box 398 33 West Second Street Agency Building 2~
Riverhead, New Yod 11901 -
Empire State F1aza Albany, New York 12223 Matthew J. Kelly, Esquire Energy Research Group, Inc.
Staff Counsel 400-1 Totten Pond Road New York State-Public Service Commission Waltham, Massachusetts 02154 Three Rockefeller Plaza Albany, New York 12223 Mr. Jeff Smith Shoreham Nuclear Power Station Ezra I. Bialik, Esquire Post Office Box 618 Assistant Attorney General Wading River, New Yod,11792 Environmental Protection Bureau.
New York State Department of Law W. Taylor Reveley, III, Esquire 2 World Trade Center Hunton & Williams New Yod, New York 10047,
Post Office Box 1535 R,ichmond, Virginia 23212 Resident Inspector Shoreham NPS, U.S'. NRC Ralph Shapiro, Esquire Post Office Box B Cam:rer & Shapir o Rocky Point, New York 11778 9 East 40th Street New Yod, New York 10016 Herbert H. Brown, Esquire -
Ki rkpatrick, Lockhart, ' Hill, Mr. Brian McCaffrey Christopher & Phillips Long Island Lighting Company 1900 M Street, N.W.
175 E. 01 d Country Road Washington, D.C.
20036 Hicksville, New York 11801 Lawrence Coe Lanpher, Esquire Honorable Peter Cohalan Kirkpatrick, Lockhart, Hill, Suffolk County Executive Christopher & Phillips County Executive / Legislative Bldg.
1900 M Street, N.W.
Veteran's Memorial Highway Washington, D.C.
20036 Hauppauge, New York il788 Karla J. Letsche, Esquire David Gilmartin, Esquire Kirkpatrick, Lockhart, Hill, Suffolk County Attorney Christopher & Phillips County Executive / Legislative Bldg.
1900 M Street, N.W.
Veteran's Memorial Highway' Washington, D.C.
20036 Hauppauge, New York 11788
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Shoreham 2-
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Lawrence Brenner, Esq.
Administrative Judge Atomic Safety & Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Dr'. James L. Carpenter Administrative Judge l
Atomic Safety & Licensing Board l-U. S. Nuclear Regulatory Coimmission Washington, D..C.
20555
's Dr. Peter A. Morris
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Administrative Judge Atomic Safety & Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C.
20555 O
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nrary UNITED STATES i
E isUCLEAR REGULATORY COMMISSION o
WASHINGTON, D. C. 20555 g
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MAR 1 5 igg 3 Docket No. :
50-322 MEMORANDUM FOR:
A. Schwencer, Chief Licensing Branch No. 2, DL FROM:
R. Caruso, Project Manager Licensing Branch No. 2, DL
SUBJECT:
FORTHCOMING MEETING WITH LONG ISLAND LIGHTING COMPANY (LILCO) AND TELEDYNE ENGINEERING SERVICES (TELEDYNE)
DATE & TIME:
Wednesday, March 30, 1983
- 10:30 am - 4:00 pm LOCATION:
Room P-ll4 Phillips Building Bethesda, MD PURPOSE:
To discuss the Independent Design Verification Program findings for Shoraham.
PARTICIPANTS:
NRC LILCO Tel edyne R. Caruso J. Smith, et.al D. Landers, et.al R. Bosnak E. Sullivan J. Knight 1t W. Haass J. Gilray
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. Caruso, Project Manager Licensing Branch No. 2, DL cc:
See next page
- This meeting was originally scheduled for Thursday, March 17, 1983 l
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-Shoreham Mr. M. S. Pollock Vice President - Nuclear Long Island Lig_hting. Company
/
175 East Old Country Road
, Hicksville, ;few York 11801
) ~ cct Howard L. Blau, Esquire MHB Technical Associates Blau and Cohn, PC.
1723 Hamilton Avenue, Suite K San Jose, California 951.25 217 Newbridge Road Hicksville, New York 11801 Stephen Latham, Esquire j
Mr. J ay 'Dunkleberger Twomey, Latham & Shea New York State Energy Office Post Office Box 398 Agency Building 2 33 West Second Street Empire State F1az'a Riverhead, New Yod 11901 Albany, New York 12223 Matthew J. Kelly, Esquire Energy Research Group, Inc.
Staff Counsel 400-1 Totten Pond Road New York State Public Service Commission Waltham, Massachusetts 02154 Three Rockefeller Plaza Albany, New York 12223 Mr. Jeff Smith Shorenam Nuclear Power Station Ezra I. Bialik, Esquire _
Post Office Box 618 Assistant Attorney General Wading River, New York '11792 Environmental Protection Bureau.
1 New York State Department of Law I
W. Taylor Reveley, III, Esquire 2 World Trade Center I
Hunton & Williams New York, New York 10047 Post Of fice Box 1535 R,ichmond, Virgi nia 23212 Resident Inspector Shoreham NPS, U.S'. NRC l
Ralph Shapiro, Esquire Post Office Box B Camme r & Shapiri:,
Rocky Point, New York 11778 i
9 East 40th Street i
New Yod, New Yod 10016 Herbert H. Brown, Esquire Ki rkpatrick, Lockhart, ' Hill,
i Mr. Brian McCaf frey Christopher & Phillips Long Island Lighting Company 1900 M Street, N.W.
175 E. 01 d Country Road Washington, D.C.
20036 Hicksville, New York 11801 Lawrence Coe Lanpher, Esquire Honorable Peter Cohalan Kirkpatrick, Lockhart, Hill,
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Suffolk County Executive Christopher & Phillips County Executive / Legislative Bldg.
1900 M Street, N.W.
Veteran's Memorial Highway
~ Washington, D.C.
20036 l
Hauppauge, New York 11788 Karla J. Letsche, Esquire David Gilmartin, Esquire.
Kirkpatrick, Lockhart, Hill, Suffolk County Attorney Christopher & Phillips County Executive / Legislative Bldg.
1900 M Street, N.W.
Veteran's Memorial Highway' Washington, D.C.
20036 Hauppauge, New York 11788.
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1 Shoreham -
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Lawrence Brenner, Esq.
t Administratf 7e Judge Atomic Safety & Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C.
20555 1
Dr'. James L. Carpenter Administrative Judge Atomic Safety & Licensing Board U. S. Nuclear Regulatory Coimmission Washington, D.. C.
20555 Dr. Peter'A. Morris Administrative Judge Atomic Safety & Licensing Board U. S. Nuclea' Regulatory Commission Washington, b. C.
20555 i.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFfRE THE ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of
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LONG ISLAND LIGHTING COMPANY
)
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Docket No. 50-392 (0.L.)
(Shoreham Nuclear Power Stati]n,
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Unit 1).
)
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CERTIFICATE OF SERVICE I hereby certify that copies of Suffolk County's Motion.to Compel LILCO to File a Written Report Concerning the Teledyne Engineering Services Design Review of Shoreham, dated April 8, 1983, have been served upon the following this 8th day of April, 1C83 by first-class mail, postage prepaid.
Lawrence J.
Breiner, Esq.
Ralph Shapiro, Esq.
Administrative Judge Cammer and Shapiro Atomic Safety and Licensing Board 9 East 40th Street U.S.
Nuclear Regulatory Commission New York, New York 10016 Washington, D.C.
20555 Howard L.
Blau, Esq Dr. James L. Carpenter 217 Newbridge Road Administrative Judge Hicksville, New York 11801 Atomic Safety and LicensinJ Board U.S.
Nuclear Regulatory Comdussion W.
Taylor Reveley III, Esq.
Washington, D.C.
20555 Hunton & Williams P.O.
Box 1535 707 East Main St.
Dr. Peter A. Morris Richmond, Virginia 23212 Administrative Judge Atomic Safoty and Licensing Board U.S.
Nuclear Regulat"ry Commission Mr. Jay Dunkleberger Washington, D.C.
2?555 New York State Energy Office Agency Building 2 Edward M.
Barrett. Esq.
Empire-State Plaza General Counsel Albany, New York 12223 Long Island Lighting Company 250 Old Country Poad Mineola, New York 11501 Stephen B.
Latha:0. Esq.
Twomey,-Latham 6 Shea Mr. Brian McCaffrey P.O.
Box 398 Long Island Lighting Company 33 West Second Street 4
175 East Old Country Road Riverhead, New York 11901 Hicksville, New York 11801
e.
- Mtrc W. Goldsmith Mr. Jeff Smith Energy Research Group, Inc.
Shoreham Nuclear Power Station 400-1 Totten Pond Road P.O.
Box 618 Waltham, Massachusetts 02154 North Country Road Wading River, New York 11792 Joel Blau, Esq.
MHB Technical Associates New York Public Service Commission 1723 Hamilton Avenue The Governor Nelson A.
Rockefel.er Suite K Building San Jose, California 95125 Empire State Plaza Albany, New York 12723 Hon. Peter Cohalan Suffolk County Executive David J. Gilmartin, Esq.
H.
Lee Ler.nison Suffolk County Attornt Building H.
Lee Dennison Building Veterans Memorial Highway Veterans Memorial Highway Hauppauge, New York 11788 Hauppauge, New York 11788 Ezra I.
Bialik, Esq.
Atomic Safety and Licensing Assistant Attorney General i
Board Panel Environmental Protection Bureau U.S.
Nuclear Regislatory Commission New York Stat.e Department of Washington, D.C.
20555 Law 2 World Trade Center Docketing and Service Section New York, New York 10047 Office of the Secretary U.S.
Nuclear Regulatory 'ommission Atomic Safety and Licensing Washington, D.C.
20555 Appeal Board U.S.
Nuclear Regulatory Bernard M.
Bordenick, Esq.
Commission Dav'd A.
Repka, Esq.
Washington, D.C.
20555 U.S Muclear Regulatory Commission Washington, D.C.
20555 Matthew J.
Kelly, Esq.
Staff Counsel, New York Stuart Diamond State Public Service Comm.
Environment / Energy Writer 3 Rockefeller Plaza NEWSDAY Albany, New York 12223-Long Island, New York 1J747 Stewart M.
Glass, Esq.
Daniel F.
Brown, Esq.
Regional Counsel Atomic Safety and Federal Emergency Management Licensing Board Panel Agency U.S.
Nuclear Regulatory Commission 26 Federal Plaza Washington, D.C.
20055 New York, New York 10278-James B.
Dougherty, Esq.
3045 Porter Street, N.W.
Washington, D.C.
20008
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Michael S. Miller KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS DATE:
April 8, 1983 1900 M Street, N.W.,
8th Floor Washington, D.C.
20036
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