ML20094A102

Revised Testimony of Gc Minor on Emergency Planning Contentions 85 & 88 Re Offsite Recovery & Reentry.Prof Qualifications Statement & Certificate of Svc Encl

ML20094A102
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	08/01/1984
From:	George Minor MHB TECHNICAL ASSOCIATES, SUFFOLK COUNTY, NY
To:
Shared Package
ML20094A076	List: ML20094A071 ML20094A102
References
OL-3, NUDOCS 8408030112
Download: ML20094A102 (18)

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l UNITED STATES OF AMERICA NUCLEAR REGULATCFY COMMISSION Before the Atomic Safety and Licensing Board

)

In the Matter of )

)

LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3

) (Emergency Planning)

(Shoreham Nuclear Power Station, )

Unit 1) )

)

)

REVISED TESTIMONY OF GREGORY C. MINOR ON BEHALF OF SUFFOLK COUNTY REGARDING CONTENTIONS 85 AND 88 Q. Please state your name, address, and position.

A. My name is Gregory C. Minor. I am a founder and Vice-President of'MHB Tech ical' Associates, 1723 Hamilton Ave-nue, San Jose, California, and am a principal consultant for the firm. A summary of my experience and professional qualifi-cations is appended to this testimony as Attachment 1.

Q. What is the purpose of this testimony?

A. The purpose of this testimony is to address Emergency Planning Contentions 85 and 88 regarding off-site recovery and reentry. Specifically, this testimony addresses the adequacy of the LILCO Plan with respect to recovery and reentry of the area surrounding the Shoreham Nuclear Power Station

("Shoreham") following a radiological emergency.

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V Q. Please state Contentions 85 and 88.

A. Contention 85 and proposed Contention 88, as modified to reflect Revison 4 of the LILCO Plan, and their preamble read as follows:

Preamble to Contentions 84-91. The LILCO Plan proposes that short-term and long-term recovery and reentry operations will be performed by LILCO personnel following a radiological emergency at Shoreham (Plan, at 3.10-1 and 3.10-2; OPIP 3.10.1). For the reasons specified in Contentions 84-91, Intervenors contend that contrary to the emergency planning standards of 10 CFR Sec-tion 50.47(b)(13) and NUREG 0654,Section II.M, the LILCO Plan fails to include gen-eral plans for recovery and reentry, including the development of necessary pro-cedures and methods that are capable of being implemented.

Contention 85. The LILCO Plan at 3.10-1 states that after site conditions are controlled, the Director of Local Response will appoint a Recovery Action Committee

_ which will"" plan' and implement actions for the restoration of the affected areas to their pre-emergency conditions." (Id.) The LILCO Plan thus provides merely that plan-4 ning for recovery and reentry will commence after the appointment of the Recovery Ac-tion Committee; at this time, no such plan exists. This is contrary to the require-ment of 10 CFR Section 50.47(b)(13) that ,

"[g]eneral plans for recovery and reentry 1 are developed," (emphasis added), and NUREG

'6E4 Section II.M.

Contention 88. The LILCO Plan fails to state the dose criteria that will provide tha basis for a determination that it is st Je for the public to reenter previously evacuated areas. Thus, the Plan fails to comply with 10 CFR Section 50.47(b)(13) and NUREG 0654,Section II.M.

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. Q. Do you agreeJwith Contention 85 and proposed Conten-tion 88, as modified to reflect Revision 4 of the LILCO Plan?

JL. Yes, I do.

Q. Where does LILCO describe its proposals related to

-recovery and reentry? -

A. Recovery and reentry are discussed in Section 3.10 of the LILCO Plan, at 3.10-1 and 3.10-2. The implementing proce-dures for recovery and reentry are contained in OPIP 3.10.1,

" Recovery / Reentry," which refers to Attachment 1 of OPIP 3.6.6,

" Ingestion Pathway Protective Actions." I used Revision 4 of the LILCO' Plan as the basis for this testimony.

O. Why is the provision of the LILCO Plan referenced in Contention 85 contrary to the requirements of NUREG 0654, Sec-tion II.M, as stated in that Contention?

A. . Criterional of S$ction II.M states that the responsi-i ble organization (in this case, LILCO), "shall develop general plans and procedures for reentry and recovery and describe the means by which decisions to relax protective measures .. . are reached," considering both existing and potential conditions.

The LILCO Plan, however, does not include even a general plan for recovery and reentry.

First, the Plan states that "a Recovery Action Committee will be appointed . . . " and that the Committee a

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"will . . . plan and implement actions for the restoration of the affected areas to their pre-emergency conditions." Plan, at 3.10-1. This does not constitute a plan for recovery; it is merely a plan for the creation of a, committee whose charter will presumably include planning for and implementing recovery actions.

Second, the Plan does not address necessary recovery ac-tivities'which should be considered in an effort to reduce dose rates in contaminated areas, thereby permitting LILCO to lift as soon as possible any protective action (s) initiated as a re-sult of an emergency at Shoreham. Of course, any decisions re-lated to recovery actions or lifting of protective measures would presumably be based upon an evaluation that the actions would not result in undue risk to the public. In this regard, factors to be considered should' include effectiveness of decontamination activities including radioactive waste dispos-al, security for contaminated areas, and the adequacy of food i and water supplies. The LILCO Plan, however, does not specify how such factors would be taken into consideration and, if nec-essary, implemented by LILCO. As a result, the Plan provides no assurance that necessary recovery actions would be imple-mented.

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Third, OPIP 3.10.1 states that the Manager of Local Re-sponse, as the chairman of the Recovery Action Committee (OPIP 3 .10 .'1, at 2), is to " ensure [ J" that surveys of contaminated areas are conducted "to determine the means of decontamination or other disposition." OPIP 3.10.1, at 6. OPIP 3.10.1, howev-er, fails to describe any of the means of decontamination or disposition of contaminated materials Which will be considered, or any criteria to be used in deciding between these alterna-tives.

Q. Please summarize your conclusions with regard to Con-tention 85.

A. I conclude that Contention 85 is valid. The LILOO f

Plan and implementing procedures fail to include several'compo-nents of even a general plan for recovery and reentry, as required-by 10 CFN 50.47(b)(IS)'and NUREG 0654,Section II.M.

O. What is the basis for your agreement with Contention 88?

A. In my opinion, LILCO has failed to develop adequate means for deciding Whether protective measures initiated as a result of an emergency at Shoreham should be relaxed or lifted.

The reasons for my opinion in this regard are discussed above.

In addition, LlLCO's Plan fails to state the dose criteria that would provide the basis for a determination that it would be i

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safe for the public to reenter previously evacuated areas.

Thus, it must be concluded that LILCO has fallad to comply with the applicable NRC regulations and guidelines identified in Contention 88 governing reentry following a radiological emer-gency.

Revision 4 of the Plan includes a dose criteria of 500 mR as a threshold for designating areas as contaminated.

See OPIP 3.10.1, at 3. However, the Plan fails.to specify any dose level acceptable for reentry by the public. I am aware of the fact that Revision 4 of the Plan has added a new imple-menting procedure -- OPIP 3.10.2. However, OPIP 3.10.2, as written, does not provide an accurate means for calculating total population dose or dose to a given sector of the popula-tion. Further, if OPIP 3.lO.2.is meant by LILCO to be used as a means for determining dose rates or projected dose in an area to be reentered, in my opinion it is neither accurate nor reli-able for this purpose, since the procedure relies on inaccurate data sources for estimating the affected population of the EPZ or zones within the EPZ. In addition, OPIP 3.10.2 is not supported by other portions of the LILCO Plan, including other implementing procedures, and therefore the data needed to cal-culate total population dose may not even be available to LILCO.

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O. Does this conclude your testimony?

A. Yes, it does.

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I PROFESSIONAL QUALIFICATIONS OF GREGORY C. MINOR

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GREGORY C. MINOR MEB Technical Associates l

. 1723 Hamilton Avenue Suite K

• San Jose, California 95125 i (408) 266-2716 EXPERIENCE: ,

4 1976 to PRESENT l Vice-President - MEB Technical Associates, San Jose, California

.k Engineering and energy consultant to state, federal, and private l organisations and individuals. Major activities include studies of safety and risk involved in energy generation, providing technical consulting to l

legislative, regulatory, public and, private groups and expert witness in

, behalf of state organizations and citizens' groups. Was co-editor of a l critique of the Reactor-Safety. Study (WASH-1400) for the Union of concerned l ~

Scientists and coiauthor~of a risk analysic of Swedish reactors for the i j Swedish Energy Commission. Served on the Peer Review Group of the NRC/TMI Special Inquiry Group ('logovin Committee). Actively involved in the 3 Nuclear Power Plant Standards Comittee work for the Instrument Society of 4

America (ISA).

j 1972-1976 1

4 Manager, Advanced Control and Instrumentation Engineering, General Electric Company, Nuclear Energy Division, San Jose, California l Managed a design and development group of thirty-four engineers and support personnel designing systems for use in the measurement, control and

!. operation of nuclear reactors. Involved coordination with other reactor i design organisations, the Nuclear Regulatory Commission, and customers, j both overseas and domestic. Responsibilities included coordinating and .

i managing and design and development of control systems, safety systems, and '

l new control concepts for use on the next generation of reactors. The

! position included responsibility for standards applicable to control and l instrumentation, as well as the design of short-tern solutions to field ,

l problems. The disciplines involved included electrical and mechanical l . engineering, seismic design and process computer control / programming, and equipment qualification. -

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. . . l o 1970 - 1972 1

Manager, Reactor Control Systems Design,' General Electric Company, Nuclear '

Energy Division, San Jore, California Managed a group of seven engineers and two support personnel in the design and preparation of the detailed system drawings and control documents

• i relating to safety and emergency systees for nuclear reactors. *

, Responsibility required coordination with other design organizations and '

interaction with the customer's engineering personnel, as well as regulatory personnel. i 1963 - 1970  !

! Design Engineer, General Electric Company, Nuclear Energy Division, San Jose, California  !

! Responsible for the design of specific"nontrol and instrumentation systems [

! for nuclear reactors. Lead design respon'sibility for various subsystens of .

. instrumentation used to measure neutron flux in the reactor during startup  !

, and intermediate power operation. Performed lead system design function in l l the design of a major system for measuring tha power generated in nuclear j reactors. Other responsibilities included on-site checkout and testing,of a complete reactor control system at an experimental reactor in the j i~1 Southwest. Received patent for Nuclear Power Monitoring System. l 1960 - 1963 _

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Advanced Engineering Program, General Electric Company; Assignments in '

Washington, California, and Arizona i  !

j Rotating assignments in a variety of disciplines: ,

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l' Engineer, reactor maintenance and instrument design, KE and D

! reactors Hanford, Washington, circuit design and equipment I -

maintenance coordination.~

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Design

• engineer, Microwave Department, Palo Alto, California. Worked l

on design of cavity couplers.for Microwave Traveling Wave Tubes (TWT). '

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• Design engineer, Computer Department, Phoenix, Arizona. Design of

, core driving circuitry. -

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Design engineer, Atomic Power Equipment Department, San Jose, i

California. Circuit design and analysis. ,

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l Design engineer, Space Systems Department, Santa Barbara, California.

Prepared control portiono 'f satellite proposal. '

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- Technical Staff - Technical Military Planning operation. (TEMPol,  !

Santa Barbara, California. Prepara analyses of missile exchanges.

During this period, completed three-ycar General Electric program of extensive education in advanced engineering principles of higher mathematics, probability and analysis. Also completed courses in Kepner-Tregoe, Effective Presentation, Management Training Program, and various technical seminars.

EDUCATION University of California at Berkeley, BSEE, 1960. '

! Advanced Course in Engineering - three-year curriculum, General Electric l Company, 1963. ,

! Stanford University, MSEE, 1966.

HONORS AND ASSOCIATIONS

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Tau Beta Pi Engineering Honorary Society  !

Co-holder of U.S. Patent No. 3,565-760, " Nuclear Reactor Power  ;

i Monitoring System," February, 1971.

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l , .- Member: American Association for Advance of Science. .

.. .. I Member: Nuclear Power Plant Standards Committee. Instrument Society of America. .

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l PERSONAL DATA t

j Born: June 7, 1937 4 Harried, three children

] Residence: San Jose, California ,

i PUBLICATIONS AND TESTIMONY ,

i j 1. G. C. Minor, S. E. Moore, " Control Rod Signal Multiplexing," IEEE j 4-Transactions on Nuclear Science, Vol. NS-19, February, 1972. '

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! . 2. G. C. Minor,. W. G. Milme, "An Integrated Control Roan System for a 1 1 Nuclear Power ' Plant," NEDO-10658, presented at International Nuclear

} Industries Fair and Technical Meetings, October, 1972, Basie, l Switzerland. '

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3. The above article was also published in the German Technical Magazine, NT, March, 1973.

4. Testimony of G. C. Minor D. G. Bridenbaugh, and R. B. Hubbard before l

.the Joint Committee on Atomic Energy., Hearing held February 18, 1976, and published by the Union of Concerned Scientists, Cambridge, Massachusetts.

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5. Testimony of G. C. Minor, D. G. Bridenbaugh, and R. B. Hubbard before the California State Assembly Committee on Resources Land Use, and . j Energy, March 8, 1976.

6. Test'inony of G. C. Minor and R. B. Rubbard before the California State j

Senate Comnittee on Public Utilities, Transit, and Energy, March 23, -  !

2-1976.

7. Testimony of G. C. Minor regarding the Grafsnrheinfeld Nuclear Plant, -

l March 16-17, 1977, Wursburg, Germany. l t

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8. Testimony of G. C. Minor before the Cluff Lake ' Board of Inquiry, l

! Regina Saskatcheven, Canada, Department 21, 1977.

! 9. The Risks of Nuclear Power Reactorat A Review of the NRC Reactor '

Safety Study WA5B-1400 (avaEG-75/0140), R. Kendall, et al, edited by I G. C. Minor and R. B. Bubbard for the Union of Concerned Scientists,

. August, 1977. . .

Barseback Risk Assessment, HER

, 10. Swedish Reactor Safety Studyt Technical Ass.ociates, January, 1978. (Published by Swedish Department

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o, f Industry as Docusient Sd1 1978:1) l

11. Testimony by G. C. Minor before the Wisconsin Public Service Commission, February 13, 1978 Loss of Coolant Accidents: Their

• Probability and' Consequence. -

12. Testimony by G. C. Minor before the California Legislature Assembly

• Committee on Resources Land Use, and Energy, AB 3108, April 26, 1978,

. Sacramento, California.

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i 13. Presentation by G. C. Minor before the Federal Ministry for Research ,

! and Technology (BMFT). Meeting on Reactor Safety Research, Man / Machine

! Interface in Nuclear Reactors, August 21, and September 1, 1978, Sonn, l

• Germany. ,

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! 14. Testimony of G. C. Minor D. G. Bridenbaugh, and R. B. Hubbard, before

,i the Atomic Safety and Licensing Board, September 25, 1978, in the l matter of Black Fox Nuclear Power Station Construction Permit i

Hearings, Tulsa,'Cklahoma.

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• 15. Testimony of G. C. Minor, ASLB Hearings Related to TMI-2 Accident.

1ancho Seco Power Plant, on behalf of Friends of the Earth', September 13, 1979.

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16. Testimony of G. C. Minor before the Michigan State Legislature,

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• Special Joint Committ:ee on Nuclear Energy, Implications of Three Mile l Island Ascident for Nuclear Power Plants in Michisan_, October 15, '

1979.-

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17. A Critical view of teactor' Safety, by G. C. Minor, paper presented 'to

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I the American Association for the Advancement of Science, Symposium on i

Nuclear Reactor Safety, January 7, 1980, San Francisco, California.  ;

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18. The Effects of Asins on Safety of Nuclear Power Plants;, paper.

presented at Forum on Swedish Nuclear Referendum, Stockholm, Sweden, i March 1, 1980.,

19. Minnesota Nuclear Plaats Gaseous Emissions Study, MMB Technical  ?

! Associates, September, 1950, prepared for the Minnesota Pollution

Control Agency, Roseville, MN.

] , 20. Testimony of G. C. Minor and D. G. Bridenbaugh before the New York j State Public Service Ccumission, Shoreham Nuclear Plant Construction '

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Schedule, in the matter of Long Island Lighting Company Temporary Rate

Case, September 22, 1980. ,

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21. Testimony of G. C. Minor and D. G. Bridenbaugh before the New Jersey Board of Public Utilities, oyster Creek 1980 Refueling Outage  !

1 Investigation, in the matter of Jeresey Central Power and Light Rats 1 Case, February 19, 1981.

T' i 22. Systems Interaction and Sinsle Tailure Criterion, MMB Technical

] Associates, January,1981, prepared for and available from the Swedish i

Nuclear Power Inspectorate, Stockholm, Sweden.

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23. Systems Interaction and Sinale Failure Criterient Phase II Report, MKB Technical Associates, February 1982, prepared for and available l

. - from the Swedish Nuclear Power Inspectorate, Stockholm, Sweden.  ;

j 24. Testimony of G. C. Minor and D. G. Bridenbaugh on PORV's and l l Pressuriser Heaters. Diablo Canyon Operating License hearing before '

l- ASLS, January 11, 1982.

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25. Testimony of.C. C. Minor and R. B. Hubbard on Emergency Res>onse Planning. Diablo Canyon Operating License hearing before AS:.5, January

{ 10, 1982.

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< 26. Testimony of G. C. Minor, R. B. Hubbard, M. W. Goldsmith, S. J.

Rarwood on behalf of Suffolk County, before the Atomic Safety and Licensing Board, in the matter of Long Island Lighting Company, ,

'Shorehan Nuclear Power Station, Unit 1, regarding Contention 73, Safety Classification and Systems Interaction, April 13, 1982.

27. Testimony of G. C. Minor and D. G. Bridenbaugh on behalf of Suffolk  ;

County, before the Atomic Safety and Licensing Board, in the matter .of Long Island Lighting company,-Shoreham Nuclear Power Station, Unit 1, regarding Suffolk County Contention 11. Passive Mechanical Valve Failure, April 13, 1982.

i 28. Testimony of G. C. Minor and R. B. Rubbard on behalf of Suffolk -

County, before the Atomic Safety and Licensing Board, in the matter of

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j Long Island Lighting Company, Shoreham Nuclear Power Station, Unit 1, i regarding Suffolk County Contention 27 and SOC Contention 3 -

j Post-Accident Monitoring, May 25, 1982. .

! 29. . Testimony of G. C. Minor and D. G. Bridenbaugh on behalf of Suffolk County, before the Atomic Safety and Licensing Board, in the matter of Long Island Lighting Company, Shoreham Nuclear Power Station, Unit 1, j regarding ,$uffolk County Contention 22. SRV Test Program, May 25 j 1982.

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30. Testimony of G. C. Minor and D. G. Bridenbaugh on behalf of Suffolk -

j County, before the Atomic Safety and Licensing Board, in the matter of Long Island Lighting Company, Shoreham Nuclear Power Station, Unit 1,

. regarding 'Suffolk County Contention 28(a)(vi) and 50C Contention 7A(6), Reduction of SEV Challenges, June 14, 1982.

1 31. Testimony of G. C. Minor on behalf of Suffolk County, before the j Atomic Safety and Licensing Board, in the matter of Long Island ~

i Lighting Company, Shorehen Nuclear Power Station Unit 1, regarding

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Environmental Qualification, January 18, 1983.

l 32. Testimony of G. C. Minor and D. G. Bridenbaugh before the Pennsylvania j

Public Utility Commission, on behalf of the Office of Consumer 4

Advocate, Regarding the Cost of Constructing the Susquehanna Steen j -

Electric Station Unit I, Ret Pennsylvania Power and Light, March 18,

1983.

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. 33. Supplemental testimony of G. C. Minor, R. B. Hubbard, and M. W.

Goldsmith 'on behalf of Suffolk County, before the Atomic Safety and

Licensing' Board, in the matter of Long Island Lighting Company,

! Shorehan Nuclear Power Station, Unit 1, regarding Suffolk County l

) Contention 75 Safety Classification and Systems Interaction, March i 23, 1983. ,

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34. Testimony before the District Court Judge in the case.of Sierra Club et al. vs. DOE regarding the Clean-up of Uranius Mill' Tailings. ' June 20, 1983.* ,

35. systems Interaction and Single Failura Criterion: Phase 3 Report, MEB Technical Associates, June, 1983, prepared for and available from the Swedish Nuclear Power Inspectorate, Stockholm, Sweden. .

36. Systematic Evaluation Program: Status Report and Initial Evaluation, MEB Technical Associates, June *,1983, prepared for and available from the Swedish Nuclear Power Inspectorate, Stockholm, Sweden.

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• 9/E UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board

)

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 l I hereby certify that copies of (1) Suffolk County's Motion to Admit Proposed Modified Emergency Planning Contention 88 and Suffolk County's Revised Testimony on Emergency Planning i

Contentions 85 and 88 and (2) Revised Testimony of Gregory C.

l Minor on Behalf of Suf folk County Regarding' Contentions 85 and 88 have been served to the following this /it day of August, 1984 by U.S. mail, first class, except as otherwise noted.

!

• James A. Laurenson, Chairman James B. Dougherty, Esq.

l Atomic Safety and Licensing Board 3045 Porter Street, N.W.

U.S. Nuclear Regulatory Commission Washington, D.C. 20008 l Washington, D.C. 20555 l

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• Dr. Jerry R. Kline Marc W. Goldsmith l Administrative Judge Energy Research Group, Inc.

Atomic Safety and Licensing Board 400-1 Totten Pond Road U.S. Nuclear Regulatory Commission Waltham, Massachusetts 02154 i Washington, D.C. 20555 l **W. Taylor Reveley, III, Esq.

• Mr. Frederick J. Shon Hunton & Williams Administrative Judge P.O. Box 1535 Atomic Safety and Licensing Board 707 East Main Street U.S. Nuclear Regulatory Commission Richmond, Virginia 23212 Washington, D.C. 20555 Mr. Jay Dunkleberger i New York State Energy Office Edward M. Barrett, Esq. Agency Building 2 General Counsel Empire State Plaza Long Island Lighting Company Albany, New York 12223 250 Old Country Road Mineol,a, New York 11501 l

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Mr. Brian McCaffrey Stephen B. Latham, Esq.

Long Island Lighting Company Twomey, Latham a Shea Shoreham Nuclear Power Station P.O. Box 398 P.O. Box 618 33 West Second Street North Country Road Riverhead, New York 11901 Wading River, New York 11792 Joel Blau, Esq. MHB Technical Associates New York Public Service Commission 1723 Hamilton Avenue The Governor Nelson A. Rockefeller Suite K Building San Jose, California 95125 Empire State Plaza Albany, New York 12223 Hon. Peter F. Cohalan Suffolk County Executive Martin Bradley Ashare, Esq. H. Lee Dennison Building Suffolk County Attorney Veterans Memorial Highway H. Lee Dennison Building Hauppauge, New York 11788 Veterans Memorial Highway Hauppauge, New York 11788 Stuart Diamond Business / Financial Atomic Safety and Licensing New York Times Board Panel .

229 W. 43rd Street U.S. Nuclear Regulatory Commission New York, New York 10036 Washington, D.C. 20555 -

Docketing and Service Section Atomic Safety and Licensing t Office of the Secretary Appeal Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory 1717 H Street, N.W. Commission Washington, D.C. 20555 Washington, D.C. 20555

• Bernard M. Bordenick, Esq. Jonathan D. Feinberg, Esq.

Edwin J. Reis, Esq. Staff Counsel U.S. Nuclear Regulatory Commission New York State Public Washington, D.C. 20555 Service Commission 3 Rockefeller Plaza

• • Stewart M. Glass, Esq. Albany, New York 12223 Regional Counsel, Federal Emergency Management Nora Bredes Agency Executive Director 26 Federal Plaza, Room 1349 Shoreham Opponents Coalition New York, New York 10278 195 East Main Street Smithtown, New York 11787

• Eleanor L. Frucci, Esq. Spence Perry, Esq.

Atomic Safety and Licensing Associate General Counsel Board Panel Federal Emergency Management U.S. Nuclear Regulatory Commission Agency Washington, D.C. 20555 Washington, D.C. 20472 l

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• • Fabian Palomino, Esq.

Special Counsel to the Governor Executive Chamber State Capitol Room 229 Albany, New York 12224

-Y Michael S. Miller

' KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER 4 PHILLIPS 1900 M Street, N.W., Suite 800 Washington, D.C. 20036 Dated: August /, 1984

• By Hand

• • By Federal Express .

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