ML20076G871
| ML20076G871 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 08/29/1983 |
| From: | Lanpher L KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL-3, NUDOCS 8309010158 | |
| Download: ML20076G871 (22) | |
Text
8/29/83 UNITED STATES OF AMERICA SOCKET,ED USNR' NUCLEAR REGULATORY COMMISSION A
5 Before the Atomic Safety and Licensing Board 1~,=-_.,_
)
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-3
)
(Emergency Planning)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
4
)
SUFFOLK COUNTY UPDATE OF OBJECTION TO SPECIAL PREHEARING CONFERENCE ORDER In the Suffolk County Objection to Special Prehearing Conference Order (the " Objection"), dated August 23, 1983, the County made certain representations regarding the recent diesel generator problems at the Shoreham plant and the potential impact of those events on the schedule.
Late last week the County received updated information from LILCO which affects two of the statements made in the Objection.
This pleading is filed to update the Objection with the more current data which the County now possesses.-1/
First, in footnote 5 of the Objection the County stated that it had learned that a second diesel crankshaft had indications of a failure.
It now has been confirmed that 1/
Under the Board's August 24 Order, other parties but not the County are permitted to file pleadings in reply to the County's Objection.
The instant County filing is proper since it is not a " reply" but rather brings to the Board's attention altered facts which may affect the Board's consideration of the Objection.
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- all three diesel crankshafts.have cracks.
See LILCO Status Report on Diesel Generator Crankshaft Matters, Exhibit 1 hereto, at pages 1-2.
Second, on page 7 of the Objection, the County reported from an August 18, 1983 LILCO Press Release that LILCO's most favorable date for Shoreham readiness to load fuel was the first quarter of 1984.
LILCO reported on August 25 as follows:
At the present time, as a result of the crankshaft failures and indications, it is LILCO's current judgment that under the most favorable known circumstances, Shoreham will not be ready to load fuel until sometime late in the first quarter of 1984 or early in the second quarter of 1984.
Exhibit 1 at page 5 (emphasis supplied).
Respectfully submitted, David J. Gilmartin Patricia A.
Dempsey Suffolk County Department of Law Veterans Memorial Highway Hauppauge, New York 11788 v/*
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Herbert H.
Brown Lawrence Coe Lanpher Karla J.
Letsche KI RKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M Street, N.W.,
Suite 800 Washington, D.C.
20036 Attorneys for Suffolk County August 29, 1983 i
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EXHIBIT 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
LONG ISLAND LIGHT.TNG COMPANY
)
Docket No. 50-322 (OL)
)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
STATUS REPORT ON DIESEL GENERATOR CRANKSHAFT MATTERS LILCO submits this Status Report on Diesel Generator Crankshaft Matters pursuant to the Board's Memorandum and Order Deferring Filing of Testimony and Commencement of Hearings on Diesel Generators dated August 16, 1983.
As LILCO previously reported to the Board promptly on Saturday, August 13, 1983, a failure occurred in the crankshaft of emergency diesel generator 102 in the vicinity of the no. 7 cylinder.
Further investigation of the failure indicated that the crankshaft had experienced a crack that severed the shaft.
As reported in LILCO's letter to the Board dated August 22, 1983, indications were found on the crankshaft of emergency diesel generator 103.
Subsequent investigation confirmed that this crankshaft contained a crack approximately 2" long and l
1/2" deep.
Examination of the crankshaft of emergency diesel generator 101 has revealed an indication similar to the indica-tion found on the crankshaft of emergency diesel generator 103.-
The Staff and County were advised of these facts.
The indica-tion on the crankshaft of diesel generator 101 has since been determined to be a crack 1 1/2" - 2" long and approximately 360 mils deep.
Additional examination of the crankshaft.of emer-gency diesel generator 101 ha; also revealed indications in the vicinity of the no. 3 and no. 5 cylinder journals.
Examination of the crankshaf ts on diesel generators 101 and 103 is still in progress.
Investigation of the cause or causes of the failure of the crankshaft of emergency diesel generator 102 is underway and will be conducted in accordance with a master plan which generally describes steps to be taken during the investigation and remedy of the crankshaft failure.
The master plan also de-scribes organizational responsibilities for this effort.
A copy of the master plan, which was approved yesterday, has been made available to the Staff and the County and for the Board's information is attached to this Report.
The plan was prepared prior to confirming the existence of cracks on the crankshafts of diesel generators 101 and 103 and therefore does not reflect that information.
This Status Report will supplement the --. -
information provided in the master plan with respect to emergency diesel generators 101 and 103.
As the plan indicates, LILCO will use the resources of appropriate LILCO organizations, Stone & Webster Engineering Corp., Transamerica Delaval and appropriate contractors to carry out the steps outlined in the diesel generator master plan.
In addition, as the plan also reflects, Failure Analysis Associates (FAA), a highly qualified and experienced organiza-tion in the field of failure analyses, will conduct the inves-tigation to determine the cause or causes of the crankshaft failure on diesel generator 102 and the cracks in the crank-shafts of diesel generators 101 and 103.
FAA, engineering and metallurgical consultants, have substantial experience investigating mechanical, structural and materials failures both in nuclear and non-nuclear applications.
The master plan calls for moving emergency diesel gen-erator 102 from the diesel room to the turbine building where a clean area with controlled access will be established.
Transamerica Delaval personnel will then disassemble the engine to permit removal of the failed crankshaft.
At present, dis-connection of diesel generator 102 from its auxiliary equipment has been completed and prepar~ations for removing the engine from the diesel generator room are underway.
Once the engine -
l has been placed in the turbine building and disassembled, the crankshaft will be sent to an appropriate facility off site for_
completion of failure analyses by or under the supervision of FAA.
A similar process will be used to investigate the cracks on the crankshafts of diesel generators 101 and 103.
LILCO currently intends to replace the existing 13" X 11" crankshafts with 13" X 12" crankshafts on all three engines.
Arrangements are now being made for shipment of the crankshafts to the site.
The investigation being conducted will also determine whether the installation of these new crankshafts will remedy the problems experienced in the old crankshafts or whether other remedies will be required.
LILCO is not certain at this time whether the replacement of the three crankshafts will resolve the problems encountered with the diesel generators or whether some other remedial measures may be required.
Crankshaft replacement is currently planned to take place in the turbine building where the engines will be reas-(
l sembled.
Once reassembly is complete, the engines will be re-turned to the diesel room where they will be installed and reconnected to auxiliary equipment.
As described in the master plan, appropriate testing of the diesels will then be conducted.
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As noted, the investigation into the cause or causes of the crankshaft failure in diesel generator 102 and the cracks found in the crankshafts of diesel generators 101 and 103 has commenced and is underway.
The cause or causes of these cracks and failures have not been identified.
LILCO expects that the crankshaft for emergency diesel generator 102 will be removed from the engine in approximately two weeks and that preliminary information concerning the failure analysis may be available two weeks thereafter.
Thus, FAA estimates that a final report on the failure analysis will be completed 4-6 weeks from the date of this Status Report.
A copy of this FAA report will be made available to the Board and parties.
This estimate of 4-6 weeks will be revised if necessary.
At the present time, as a result of the crankshaf t failures and indications, it is LILCO's current judgment that under the most favorable known circumstances, Shoreham will not be ready to load fuel until sometime late in the first quarter of 1984 or early in the second quarter of 1984.
More precise i
estimates of the time it will take to complete the investiga-l tion and to repair and test all three diesel generators must necessarily await receipt of further information from the f ail-ure analysis.
Needless to say, LILCO will continue to take whatever steps are appropriate that would permit an earlier fuel load.
, )
5 Given this situation, LILCO does not believe it would be productive to conduct any litigation oa diesel generator issues until issuance of FAA's failure analysis report.
Litigation of diesel generator issues prior to completion of that report would interfere with LILCO's efforts to investigate and remedy the crankshaft matters because key personnel at LILCO, Stone & Webster and Transamerica Delaval would be in-volved in discovery and testimony at the same time they would be involved in the crankshaft efforts.
Accordingly, LILCO re-spectfully requests that litigation of diesel generator co'nten-tions be held in abeyance pending issuance of the FAA final report which is expected in approximately 4-6 weeks.
LILCO re-spectfully suggests that the Board and parties review and consider the matter of scheduling litigation of the diesel gen-erator contentions after the issuance of the FAA final report.
LILCO understands that the Staff supports deferral of any consideration of diesel generator issues.
The substance of this status report was provided to the County late Tuesday and l
we understand that the County also supports deferral.
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Respectfully submitted,
~
LONG ISLAND LIGHTING COMPANY S.
Ellis, III
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nthony F. Earley, 4r.
Hunton & Williams Post Office Box 1535 Richmond, Virginia 23212 DATED:
August'25, 1983
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/Q SHOREHAM NUCLEAR POWER STATION EMIRGENCY DIESIL GENERATOR 102 ERAh7stiArT TKILURE ANALYSIS /MASTE_R PLAN I.
PURPOSE:
The purpose of this master plan is to describe the organization and organizational responsibilities for implementing the investigation into and recovery from the crankshaft failure on the Emergency Diesel Generator 102 at the Shoreham Nuclear Power Station.
This master plan includes a description of those activities associated with the failure analysis; the disassembly of the Emergency Diesel Generator to allow for the investigation of the failed componentar the review of the implications of this failure on the reliability of the other two diesel generators $101 and #103; and the identification of required retesting to ensure reliable diesel generator operation following repairs.
It must be emphasized that the master plan is necessarily Revisions to the approach will be preliminary in nature.
made, if necessary, as information is obtained during the actions sat out in this plan.
This master plan has been put in place by the organisation described herein, has been reviawed by represent.atives of LILCO Project Engineering, LILCO Startup, the Shoreham l
Joint Test Group, Operational Quality Assurance and the Vice-President of Nuclear.
In addition, this plan has been developed with the assistance of TransAmerica DeLaval Inc. of Oakland, California and Failure Analysis Associates of Palo Alto, California.
II.
ORGANI5ATION:
c As a result of the failure of the crankshaft on Emergency Diesel Generator 102, an organization has been put in pla'ce consisting of the'necessary expertise to assess the cause or causes of the crankshaft failurcs to recover from that failure and l
perform suitable retesting following recovery and to determine the irplications of thia failure on diesel ganarators 101 and 103.
The essential areas of expertise are shown in Attachment No. 1 Organizationa'l Interface Diagram and consist of the followingt a.
Startup Personnel b.
Engineering Personnel o.
Scheduling Personnel 4
d.
Vendor Representatives (TDI) 1
A O W 10 t
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Plant Staf f Maintenance Support Personnel
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Failure Analysis Consultants g.
Operational Quality Assurance and TDI QA Personnel In addition to the organization shown on the attachment, support from the LILCO Cffice of Nuclear es well as the entire Long Island Lighting Company are available, such as the Purchasing, Engineering, Maintenance Services and Quality Assurance Departments, t
A.
LILCO 8tartup LILco startup under the direction of the Startup Mbnager has the primary line responsibility for implementing and scheduling the entire effort on the three diesel engines since the Energency Diesel Generators are still under Startup jurisdiction.
Repir Rework Requests initiated by Test Engineers will be the base dccument for the rework with 1
Maintenance Work Requesta (MWR's) being used to support administrative requirements of the maintanance contractor, Catalytic Inc. and other maintenance support organizations.
Implementing maintenance and test procedures will be generated by Project Engineering, startup and TDI and will be provided to the field via the above base documents.
B.
MAINTENANCE Catalytic Inc., a supplemental maintenance contractor j
to the LILCO Plant Staff paintenance section, will prepare the equipment for removal of diesel generator 102 from the Diesel Generator Room by disconnecting A.
p'i the piping, electrical and other appropriate connections to the engine and generator in accordance with Diesel Generator 102 Disconnection Checklist and implomanting work request documents.
f..
Gerosa Inc., a rigging and hauling contractor, will jack and skid the diesel engine out of the room and transport the equipment to the Turbine Building turbine deck, Elevation 63'.
TransAmerica DeLaval Inc. (TDI), the diesel engine manufacturer, will perform the disassembly and rebuilding of the engine.
Additionally, the generator will be inspected under the cognizance of its manuf acturer (Portec) to determine if it sustained any damage.
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f TDI representatives will observe all activities associated with this investigation and will provide technical direction.
TDI will provide required replacemant parts.
C.
LILCO Prciect_Encineering LILCO Project Engineering (LPO) assisted by the Stone
& Webster Site Engineering Office (SEC) will provide engineering support and is reapcnsible for the failure analysis.
To accomplish these tasks LP0 will use its own resources supplemented by stone & Webster Engineering Corporation, TDI, Failure Analysia Associates and cther consultants as required.
Failure Analysis Associates has been charged to take whatever steps are necessary to determina the cause or causes of the fallure.
D.
@ ality Assurance Operational Quality Assurance will previde the required Quality Assurance ccvarage in accordance with the LILCO Quality Assurance Program.
TDI QA representatives will be present during the period of engina, disassembly and raansembly by the TDI work provid(e suppcrt to the 00A organizatien for quality forca.
The LILCO Quality Assurance Department will assurance matters.)
E.
Shift C'o:'tpliment
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E6 ring t.his investigation and the subsequent recevery the on shift compliment will consist of the following 8tartup Test Engineer Engineering Representative TDI Representative Failure Analysis Asscciates Representative 00A Representative Maintenance support Supervisor The Test Ingineer will be the Shift Director and is j
responsible for implementing the activities designated to be accomplished during that shift.
A pro shift I
meeting will he held to insure proper coversge is available and to review those activities with the shift cereplir.ent.
F.
Stop Work Authcrity OQA nas the actnority to "STOP WORK" based en the QA manual.
Persuant to the memoranda frem the Startup Manager, Attacheent 92 and 43 the on shift FAA representative and TDI representative have been authcrized to step work through the Test Engineer.
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Review and Audit The overall werk effort will be under the review and audit of the Joint Test Group as described in the Shoreham Startup Manual.
III.
DIESEL GENERATOR 102 CRANUHAFT FAILURE ANALYSIS AND CRANKSHAPT DE_5_IGN ADEQUACY ASSESSMENT 1
A.
Failure Analysis Conduct an investigation of, and develop a detailed failure analysis for the Diesel Generator 102 crankshaf t to determine causes for failure.
This effort consists of the fo11cwing.
1)
Attendance, inspection and documentation of Diesel Generator 102 during teardown and reassembly.
2)
Appropriate analysis of the failed crankshaft.
3)
Review maintenance and operational history.
3.
Crankshaft _ Design Conduct an inspection and assessment of the adequacy of the existing (13" x 11") and replacement (13" x 22") TransAmerica DeLaval crank Shafts for Diesel Generators 101, 102 and 103.
This effort consists of the following 1)
Review of the TDI design calculations.
2)
Performance of independent calculations, as required.
3)
Performance of operational torsional vibration tests at various speeds and engine loads on the existing 13* x 11' crankshafts in diesel generators 101 and 103 and on the l
replacement 13" x 12" crankshaft for hg diesel-generator 102.
IV.
DIESEL OENERATOR REWORK & INSPECTION c-A.
Inspections & Tests - Diesel Generator 102 The inspections and tests on diesel generator 102 includs but may not be limited to the fo11 ewing:
1.)
The connecting rod for cylinder no. 7 vill be pulled to allcw for inspection / examination for cylinder liner damage.
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2.)
Main bearings IB, 9,10 & 11 adjacent to the l
failure vill be pulled to inspect for damage to l
the bearing, bearing shell and bedplate.
This will be performed as soon as possibis to allow evaluation of damage.
3.)
Analysis of engine oil, jacket water shd bearing metal will be performed.
l 4.)
An ovorall engine inspection during detailed disassembly for crankshaft removal will be i
performed.
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A generator inspection will be performed.
WOTE:
Itam 1 and 2 abose to be accomplished prior to removing the diesel generator from the room.
B.
Inspection and Tests -_ Diesel Generator 101 and 103 The inspections and tests on diesel generator 101 and 103 include but may not,be limited to the following 1.)
1004 visual inspection of crankshaft webs and dye pnetrant tests where appropriate.
2.)
ne connecting rods on cylinder 6, 7 6 5 will be pulled to perform 1004 LP and UT of the connecting rod journal.
3.)
T'orsional vibration testing of the crankshaft in the 101 a 103 will be performed following the above inspections per procedura provided by TDI.
C, Diesel Generator 102 Rework LILCQ has overall responsibility for the Diesel Generator 102 rework effort.
The startup Test Engineer on shift will supervise the various aspects of the work described below, i
Catalytic personnel will remove pipe, tubing and electrical connections, discennect the turbochargerr and disconnect the generator in preparation for jacking and skidding the engine out of the room.
Gerosa personnel will rig and jack the engine, skid it out of the room and move it around via flat bed to the turbine building truck bay.
The entire engine will be l
lifted via the turbine building crane and set inside an existing caged-in area on the turbine building l
deck.
A clean room will be set up and access control will be established.
TDI personnel will perform the disassembly allowing the appropriate inspections to take place.
The TDI Service Representative will be the responsible supervisor for the TDI workman.
The generator will also be inspected for damage while on the turbine deck.
LILCO and TAA inspections will be performed during this work.
Once removed, the damaged shaft will be sent off site for failure analysis.
TDI personnel will rebuild the engine under the supervision of a TDI Service Representative *ar.d following reassembly, the engine will be transported back into the diesel generator room by Gercsa personnel.
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/C) c Catalytic personnel will reconnect all apertanances.
At this point ratesting will begin.
V.
RETESTING DIESEL GENERATOR 102 Upon completion of the Emergency Diesel Generator 102 rework and reinstallation, the Preop test program for this engine will be reperformed as follows, All components disturbed by the rework will be s.
subjected to appropriate C&IC, including calibrations, electrical wire checks, and pneumatic tubing connection reverifications.
h.
The Lube 011, Jacket Water, Fuel Oil and Air Start system will be reflushed as required.
c.
Initisl engine run-in per TDI direction.
d.
The Mechanical Preop test will be reperformed in its
- entirety, s.
The two Electrical Preop tests will be reperformed.
f.
Following completion of the above and review and concurrence by the JTG, the Qualification Preop test will be reperformed.
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2 ATTACHMENT 42 August 18, 1983 R. T. Purcell M. Milligan J. Notaro STOP WORK AUTHORI2ATION - DIESEL _ ENGINE 102 FAILURE Shoreham Nuclear Power Station Unit 1 W. O. No. 44430/48923 During the investigation of the Diesel Generator 102 failure the duly authorized failure Analysis Assooiste Representative on shift has the authority to stop work as long as the stop work order does not cause a personnel safety concern.
i This stop work authorization is being given to ensure that the Failure Analysis Associates people are in a position to ensure that they get the maxieum information from the failure investigation.
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Upon issuing a stop werk order the railure Analysis Associate Representativa shall notify the undersigned of this action immediately.
- 2. J. Youngling Startup Manager EJY:eca 4
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- 5. Pollock
- 3. Riv'ello W. Museler W. Steiger A. Muller G. Rogers - FAA l
J. Kammeyer-SEQ
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R. T. Purcell M. Mill'.gan J. Notaro STOP 'dORK AUTMORI2ATION FOR TPANS AM. ERICA DELAVAL INC.
DIESEL ENGINE 102 FAI~LRE Shoreham Nuclear FSwer Station - Unit 1
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W.
O. No. 4443C/48923 During the investigation cf the Diesel Generator 102 failure, the duly authori.:cd Transamerica Delaval Inc. Repres'entative on shift has the authority to stop work, as long as the stop work order does not cause a personnci safoty concern.
This step work authcrization is being given to ensure that Delaval personnel are in a position to ensure that they obtain the maximum O
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a-Upon issuing a step work order,'t.he Tranzamerica Delaval Representative shall notify the'undersig.ed of this action immediately.
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Startup Manager EJY:eo.T.
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Pollock J. Rivelle W. Museler W. E.
Stcigor A. Muller FAA G.
Rocers SEO J.
Kn..:neye r L. McMugh TDI O
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board I
j In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-3
).
(Emergency Planning)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
CERTIFICATE OF SERVICE I hereby certify that copies of SUFFOLK COUNTY UPDATE OF OBJECTION TO SPECIAL PREHEARING CONFERENCE ORDER, dated August 29, 1983, were served to the following by U.S. mail, first class, except as otherwise indicated, this 29th day of August 1983.
l
( ) James A.
Laurenson, Chairman Ralph Shapiro, Esq.
Atomic Safety and Licensing Board Cammer and Shapiro U.S. Nuclear Regulatory Commission 9 East 40th Street Waching ton, D.C.
20555 New York, New York 10016
(*) Dr. Jerry R. Kline Howard L. Blau, Esq.
Atomic Safety and Licensing Board 217 Newbridge Road i
U.S. Nuclear Regulatory Commission Hicksville, New York 11801 l
Washington, D.C.
20555 W. Taylor Reveley, III, Esq. (#)
go)
Mr. Frederick J.
Shon Hunton & Williams Atomic Safety and Licensing Board P.O. Box 1535 U.S. Nuclear Regulatory Commission 707 East Main Street l
Washing ton, D.C.
20555 Richmond, Virginia 23212 I
l Edward M.
Barrett, Esq.
j General Counsel Mr. Jay Dunkleberger i
l Long Island Lighting Company New York State Energy Office l
250 Old Country Road Agency Building 2 Mineola, New York 11501 Empire State Plaza Albany, New York 12223 Mr. Brian McCaffrey i
Long Island Lighting Company Stephen B.
Latham, Esq.
l 175 East Old Country Road Twomey, Latham & Shea Hicksville, New York 11801 33 West Second Street Riverhead, New York 11901 l
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i Nora Bredes Docketing and Service Section Executive Director Office of the Secretary Shoreham Opponents Coalition U.S. Nuclear Regulatory Comm.
195 East Main Street Washington, D.C.
20555 Smithtown, New York 11787 Hon. Peter Cohalan Marc W. Goldsmith Suffolk County Executive Energy Research Group, Inc.
H.
Lee Dennison Building 400-1 Totten Pond Road Veterans Memorial Highway l
Waltham, Massachusetts 02154 Hauppauge, New York 11788 MHB Technical Associates Eleanor L.
Frucci, Esq.
1723 Hamilton Avenue Atomic Safety and Licensing Suite K Board Panel San Jose, California 95125 U.S. Nuclear Regulatory Comm.
Washington, D.C.
20555 Joel Blau, Esq.
New York Public Service Comm.
Ezra I.
Bialik, Esq.
The Governor Nelson A.
Rockefeller Assistant Attorney General Building Environmental Protection Bur.
Empire State Plaza New York State Dept. of Law Albany, New York 12223 2 World Trade Center New York, New York 10047 David J. Gilmartin, Esq.
Suffolk County Attorney Atomic Safety and Licensing H. Lee Dennison Building Appeal Board Veterans Memorial Highway U.S. Nuclear Regulatory Comm.
Hauppauge, New York 11788 Washington, D.C.
20555 Atomic Safety and Licensing Jonathan D. Feinberg, Esq.
Board Panel Staff Counsel, New York State U.S. Nuclear Regulatory Commission Public Service Commission Washing ton,
D.C.
20555 3 Rockefeller Plaza Albany, New York 12223 (0) Bernard M.
Bordenick, Esq.
David A.
Repka, Esq.
Stewart M. Glass, Esq.
U.S. Nuclear Regulatory Commission Regional Counsel Washington, D.C.
20555 Federal Emergency Management Agency Stuart Diamond 26 Federal Plaza, Room 1349 Environment / Energy Writer New York, New York 10278 4
]
NEWSDAY i
Long Island, New York 11747 James B.
Dougherty, Esq.
3045 Porter Street, N.W.
Washington, D.C.
20008,
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i Spence Perry, Esq.
Associate General Counsel Federal Emergency Management Agency Washington, D.C.
20472 Mr. Jeff Smith Shoreham Nuclear Power Station P.O.
Box 618 North Country Road Wading River, New York 11792
/
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Lawrence Coe Lanpher KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M Street, N.W.,
Suite 600 Washington, D.C.
20036 DATED: August 29, 1983
(*) By Hand
(#) By Federal Express,. - _ _ _ _ _. _ _ _ _ _. -.. - _
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