ML20149L012
| ML20149L012 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 02/17/1988 |
| From: | Gill A, Walker H Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20149K949 | List: |
| References | |
| OL-1, NUDOCS 8802240072 | |
| Download: ML20149L012 (17) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION J
, BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL,, BOARD
, in the Matter of )
)
PUEllC SERVICE COMPANY OF ) Docket Nos. 50-443-OL-1 NE% liAMPSHIRE, et al. ) 50-444-OL-1
)
(Stdreek Station, ) (On-site Emergency Planning linits 1 and 2) ) and Safety Issues)
JOINT AFFID,AVIT OF AA'"ITPA L,jf GILL AND HARO,LD WALKER Harold Walker and Amr'itpal S. Chi, being first duly sworn, affirm that the answers to the following questions are true and correct to the best of their knowledge and belief:
Q1: Centlemen, picase state your name, employer, and occupatlors.
A1: (Walker) My name is Harold Walker. I am employed by the United States Nuclear Regulatory Commission a s- a Reactor Engineer in Section 8 of the Plant Systems Branch, Division of Engineering and Systems Technology, Office of Nuclear Reactor Regulations.
(Gill) My name is Amrltpal S. Gill. I am employed by the United States Nuclear Regulatory Commisslors as a senior electrical engineer in the Electrical Systenis B ranch , Division of Engineering and Systems Technology, Office of Nuclear Reactor Regulations.
I Q2: Centlemen, please describe your duties.
3 h!R ADO 0
r A2: (Walker) As a Reactor Engineer I ari responsible for reviews in the area of nuclear power plant protections against various hazards, including the environmental qualification of electrical eculpment
. Important tc safety for nuclear power plants as outlined in 10 C.F.R. ! 50.49. I have served as the NRC Staff's principal review er of Applicants' electrical equipment environmental qualification prcgram for approximately the past six years. As part of .ny responsibilities, I previously testified in the proceeding corcerning NECNP Contention 1.B.2, in August 1M3 and September 1986 A statement of my professional qualifications is attached to this affidevit.
(Gilt) As a senior electrical engineer, I am responsible for reviews and evaluations of the electrical power systems ano associated instrumentation and controls needed for safe operation and safe shutdow n of nuclear facilities . A more detailed statement of my professional qualifications is attached to this affidavit.
03: Centlemen, what is the purpose of your joint affidavit?
A3: (Walker, Gill) This affidavit addresses the claims made by intervenor New England Coalition On Nuclear Pollution (NECNP) in its "Motion To Reopen The Record And Adtrit New Contention" which j was filed on February 2, 1988. Our affidtvit also addresses the claims made in support of that motion in the affidavit of Robert D.
Pollard, in brief, this affidavit will explain why: (1) the RC-59
coaxial cable used by Acolicants at the Seabrook Station meets the environmental qualification standards set forth in 10 C.F.R. 6 50.49
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and (2) Mr. Pollard is incorrect in asserting that the "measured
, insulation resistance of the RG-59 test specimens fell below the required insulation resist 4nce during the environtrental qualification tests".
Q4: Centlemen, the contention which NECNP requests be admitted states:
Applicants have f alleci to comply with the Commission's environmental qualification requirements, 10 C.F.R.
6 50.49 and Appendix A to 10 C.F.P. Part 50, with respect to RC-59 coaxial cable.
Accordirig to NECNP, the basis for this contention is that " R C-5 9 cable failed to meet its requirement for insulation resistance during equiprrent cualification te sting. " Do you agree with NECNP that Applicants have failed to comply with the Comrnission's environmental qualifications with respect to RC-59 cable?
A4: (Walker) No, I do not agree with NECNP. As I explain in this affidavit, my review of the relevant environmental qualification file (NECNP Ex. 4) leacts me to conclude that RG-59 cable will meet its specified performance requirements when subjected to the conditions predicted to be present during a postulated design basis event as rt Juired by 10 C.F.R. I 50.h9.
05: Mr. Walker, please identify and explain the environmental qualification requirements applicable to RC-59 coaxial cable.
-4_
A5: (Walker) The Commission's environmental qualification requirements are set forth in 10 C.F.R. 5 50.49. In general, section 50.49 requires that three categories of electric equipment "important to sa fety" be qualified for their application and sets forth specified performance requirements for establishing environmental qualification methods ano qualification parameters. The three categories of equipment to which Section 50.49 applies are: (1) safety-related elect:-ic eculpment; (2) non-safety-related electric eculpment whose failu re under postulated environmental condif fons could prevent satisfcetory accomplishment of safety functions by safety-related equipment; and (3) certain post-accident monitoring equipment. 10 C.F.R. 5 50.49(b)(1). HUREG-0588 "Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment" and Regulatory Guide 1.89 (RG 1.89) set forth the methods by which an applicant can establish that it s "important to safety" electrical equipment satisfies the requirements of section 50.49. With respect to electrical cable, such as RG-59 coaxial cable, the qualification standard is IEEE Standard 383-1974, "lEEE Standard for Type Test of C! ass 1E Electric Cables. Field Splices, and Connections For Nuclear Power Generating Stations". This standard is endorsed by j NUREC-0588 and the NRC Staff considers the environmental qualificatien requirements of 10 C.F.R. 50.49 to have been satisfied
. If the cable is satisfactorily tested in accordance with IEEE 383-1978 l
l j 00: Mr. Walker, what is the IEEE-383 standard and what does it require?
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f A6: (Walker) As previcusly stated at AS, IEEE 383-1974 is an "lEEE l Standard for Type Test of Class 1E Electric Cables, Field Splices, and Connections for Nuclear Power Generating Stations". The NRC ,
considers the environmental qualification requirements of 10 C.F.R. 50.49 to have been satisfieo for cable if the cable is satisfactorily tested in accordance with IEEE 383-1074. In general, the testing required by this standard includes thermal aging, gamma irradiation, and expcsure to a loss-of-coolant accident (LOCA).
G7: Mr. Walker, was the RC-59 cable tested in accordance with IEEE-383?
A7: (V'alker ) Yes it was.
08: On what do you base your answer?
AB: My answer is based on r*v review of NECNP Exhibit A, which was scraitt ed in evidence in the onsite errergency plannirig and safety issues hearing held in October 1986. Reference 2 of NECNP Ex. 4 is entitled: "Qualification Tests of Electrical Cables in a Simulated Steam-Line-Break and Locs of Coolant Accident Environment: 100 Day Duration, RC-11/u and RC-59/u Coaxial Cables." These qualification tests were performed by the Franklin Institute Research Laboratory,
. Inc. (FIRL) of Philadelphia, Pennsylvania. At page 2 of Reforence 2, the FIRL states:
The objective of this test program was to demonstrate the ability of coaxial type electrical cables to perform satisfactorily during a test program including thermal aging, gemma irradiation , ano exposure to a simulated
F i
s steam line break (SLB) and loss-of-coolant accident (LOCA). The program was based on guidelines provided in IEEE Std 323-1974 and IEEE Std 383-1974.
09: What were the results of the tests conducted on the RG-59 coaxial j
. 9 cable?
1 A9: (Walker) The tests shcwed that the RC-59 coaxial cable met all environmental test requirements. The tests were conducted by the Franklin Institute Research Laboratory, Inc., a reputable and respected testing laboratory which is well qualified to conduct environmental qualification tests of the type here involved. It conducted these tests in the period March through August 1982, and reported in January 1983 Its conclusion that:
One thermally aged soecirren and one unaged specimen of the RC-11/a and oG-59/a types of coaxial cable (4 specin ens total), insulated with XLPE and !acketed with Exane, met the acceptance criteria by maintaining their electrical load during a 190-day .. simulated SLR/LOCA expcaure, passing a final hend test a rour$d rrandrels havir.g a diameter 40 times the cable diameters, and -
5-minute ac high-potential-withstand tests at 9.44 ard 4.9f, kv, respectively, which are ec'ual to 80 v per- mil of insulation. The cable Jackets were not cracked after the Fend test.
NECNP Ex. 4, Ref. 2, p.1 (Footnbtes deleted]
It is noted that the Franklin Institute Research Laboratory is a subsidiary of Franklin Institute of Philadelphia, PA.
, Q10 Why do you state that the tests cenducted on the RC-59 cable showed it rret environmental qualification requirements?
I I
f
gy i.
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I ' I! A10. (Walker) In accordance with Regulatory Guide 1.89 (NUREG-058A is
< the original edition of M 1.89), qualification is a verification of a design limited to demonstrating that an item of the electric equipment
- is capable of performir[g its safety function under significant environmental stresses resulting from design basis accidents in order to avoid common mode failure. RG 1.89 also states that it is essential that safety-related electric equipment be qualified to demonstrate that it can perform i t t, safety function under the environmental service conditions in which it will be required to function and for the length of time its function is required and that non-safety-related (lectric equipment covered by paragraph ,
50.43(b)(2) be able to withstand environmental stresses uused by design basis eccidents under which its failure coi. m 3revent sr.tisfactory accomplishment of safety functions by saic.y-related equipment. The specific environment for which an individual itera of electric equipment must be q'uaufled depends on the installed location creo the conditions under which it is reoutred to perfor ra its safety fd, ction, i.e. , functional requirements.
s The functional requirements for RG-59 as determined by the opplicant are noted or p. 6 of 10 of NECNP Ex. 4. There are two h
requirements.
The first references p. 2 of the attached 1983 Franklin Institute
\
l Report "Qualification of Tests of Electrical Cables in Simulated Steam Line B reak and Loss of Coolant Accident Environments: 100 Day l
l t
r J! ',,
f
. Dura'tlen RC-11/u ' and RG-59/u Coaxial Cable" (Reference 2). The acceptance criteria identified in the Franklin Report is thet it remain
., ene rg,1 zed "with client soecified potential and current" during the en'/iconmental quailfication test. This was assumed to be satisfied if the total leakage / charging current rate did not exceed approximately 1.0 smp. The test report demonstrates that the acceptance criteria were met throughout the test (Ref. 2, p.17).
The second functional equirement of NECNP Ex. 4 is that contained in note 7, which indicates that although there are no specific performance requ ements identified in the Franklin test report, the cable was sub!ected to a high potential withstand tert and insulation resistance was rieasured througl'out .the test; that a minimum insulation resistance (IR) of 160 megohms per 30 feet of cable was indicated (for test en RC-11); and that the applicant has verified that this minimum IR value is acceptable for use to assure environmental qualification of cabfe at Seabrook. (NECNP Ex. 4,
- p. 9). It should be noted that for RG-59 cable the minimum IR eaNe remained at or above 300 megohms throughout the test including the perloa when tereperatu re was 346* F and the table i
had been irradiated. Sesed on my knowledge and e'.perience,
. i do no know of any applications in ruclear power ssfety
. related appIlcations which require cable to have an IR value as h.'gh as 300 mcgohms under LOCA test conditions to assure that it will function as required.
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O-The test acceptance criteria that cable not experience total leakage / charging current in excess of approximately 1.0 amp at any-time during the test is a reasonable test criteria to use in
- environmental qualificatinn tests for cable in order to meet the requirements of IEEE 36J-1974. Of course, the applicant must assure that for all plant specific applications covered by 10 C.F.R.
I 50.49, conditions are encompassed by the test data, in this case, the applicant has done so. NECNP Ex. 4, Ref. 9.
Q11. Did you also examine the test report of the Franklin Institute Research Laboratory, Inc. (NECNP Ex. 4, Ref. 2), and the Applicants' environmental qualification file on the RC-59 coaxial cable (NEONP Ex. 4), to see if appropriate tests were conducted and reported which could lead to the conclusions regarding the environmental qualification of RG-59 cable?
All . (t"alker) Yes. The tests are set out in the Franklin Institute report. This report, NECNP Ex. 4 Ref. 7, at 9-10, set out the test procedures, the nature of the radiation, steam, chemicals, and humidity to which the cable was exposed. T hese tests were appropriate for determining the environmental qualification of the
, cable. Further, tha test results were reported in detall which showed the resistance of the cable, that no cracks or other I irregularities were observed and that there was no apparent visual i
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damagt to the _ cables. M5ECNP Ex. 4, Ref. 2, at 12-13: Table 2; Appendices C and D.
3 Q12: Mr. Gill, do you agree with Mr. Walker's answers?
A12: (Cill) Yes I do.
Q13: Centlemen, NECNP contends that the RC-59 cable failed the qualification test because its insulation resistance during the second transient of the steam / chemical spray, high humidity test fell to 300 megohms which, according to NECNP is substantiallv less than the architect / engineer's specification of 10,000 megohms 0 1000 feet for RG-5c coaxial cable, is NECNP correct in this assertion?
A13: (Cill, Walker) No. NF.CNP supports its assertions that the cable failed the qualification tests on the basis cf an affidavit of Robert Pollard. Motion at 4 Mr. Pollard premises his assertion on the basis that the RG-59 cable did not meet the insulation resistance purchase requirements for the RC-59 cable of 10,000 megohms at 1000 feet since insulation resistance fell to 300 megohms dt:-ing the environmental qualification tests. Pollard affidavit, 1 2. The conclusion Mr. Pollard draws is incorrect. The insulation resistance values of 10,000 megohms at 1000 feet is not relevant to the
. insulation values to be measured during an environmental qualification test for the RC-59 cable. The specification cited by Mr. Pollard of insulation resistance of 10,000 megohms at 1,000 feet is not an environme.ntal qualification specification. Pather,
4 specification of insulation resistance per 1000 foot of cable is a common practice in th( electrical cable industry for a wide variety of J
uses. It simply identifies resistance normal ambient conditions at the
. manufacturers facility prior to being exposed to conditions of use including safety-related use in nuclear power plants.
i' Q14: Mr. Gill, Mr. Pollard, states at paragragh 4 of his affidavit that "the measured insulation resistance of the P.G-59 [ cable] must be corrected for the length of the test specimen in order to compare it to tFe required insulation resistance." Do you understand what Mr.
Pollard mears and if so, do you agree with hirr?
A14: (Gill) I understand Mr. Pollard to be suggesting that the measured insulatier resistanc(. value of the RG-59 specimen durino the t.nvironmental qualification test was obtained on the basis of a cabte only fifteen feet in length. He further states that these measurec' values should be corrected tc provide an coulvalent insulation resistance value for 1,000 feet in length in order to compare it with the vendor specification insulation resistance value of 10,000 megohms at 1,000 feet. Mr. Pollard's assertion that the insulation resistance value of 10,000 megohms must be met during the environmental qualification test is incorrectly premised. As I l [ explained above, the 10,000 megohrr s at 1.000 feet value has no relevance to the insulation _ resistance values measured during the environmental qualification tests. in the case of RG-59 cable, the specimen length used for the qualification test was 30-feet ,
although only 15 feet were subjected to the test conditions. The J
insulaticn resistance values measured and shown in NECN Reference 2, Table 2, page 14 are for 30 feet of RG-59 cable, not 1,000 feet.
it shoulc' be noted that a cable test specimen of 30 feet lerigth is acceptable under the IEEE-383-1974 .
For these reasons, Mr.
Pollard similarly is incorrect when he states at paragraph 8 of his affidavit that "RG-11 coaxial cable is not environmentally qualified [,]"
Exhibit 4 Indicates that RC-11 coaxial cable meets the requirements of section 50.49 as v. ell.
015:
Centlemen, does this complete your affidavit?
A15: (Gill, Walker) Yes it does, jf.fi ) :5 '-
J Haroid M'alker 1
$ 2J Arnriipal > Gill Subscribc(f to and sworn before me this LOday of February 1988
_ spyy- k.$t</_/7L_)
, My Commission, expires July 1,1990 h
STATEMENT OF PROFESSIONAL OUALIFICATIONS OF
. AMRITPAL S. GILL J
e I am a Senior Electrical Engineer in Section B of the Electrical Systems Branch, Division of Engineering and Systems Technology , Office of Nuclear Reactor Regulation, United States Nuclear Regulatory Commission.
My duties include serving as a principal reviewer in the area of electrical power systems ard the associated instrumentation and controls needed for sale operation and safe shutdown of nuclear reactors. Prior to this assignrrent, I was an electrical engineer in the Electrical, instrumentation and Control System Branch where I reviewed safety issues relating to electrical components, equipment and systems needed for safe operation and shutdown of nuclear facilities. Prior to being assigned to the Electrical Instrumentation and Control Systems Branch, I was an electrical engir.eer in the Power System Branch where my duties included performing technical reviews, analyses and evaluations of the adequacy of electrical equipment, apparatus and components for sa fe operation and sefe shutdown of nuclear power plants. I have been performing these
, duties since joining NRC in 1902.
I hold a B.E. degree in electrical engineering and M.Sc. degree in electrical engineering. I am a registered professional engineer in the State of Maryland. I am an associate professor and lecturer (part-time) at George Wcshington University wher e I teach electrical engineering courses to gracuate and practicing engineers. I have written a text book, Electrical Equipment Testing and _ Maintenance, published by Reston Publishing Co. (Prentice Hall),1982.
Prior to joininc the NRC, I worked for 17 yeers in the private sector, including an electrical power corrpany where , my duties included the selection ena development of specifications for electricci systems, equip-ment and apparatus. I also performed evaluations and testing of ofectrical equipment and components used for electrical systems.
e
t STATEMENT OF PROFESSIONAL QUALIFICATION OF HAROLD WALKER
! am a Peactor Engineer in Section 8 of the Plant Systems Branch, Division of Engineering and Systems Technolog y, Office of Nuclear P,eactor Regulation, United States Nuclear Regulatory Commission. My duties include serving as t. principal reviewer in the area of nuclear plant prctection to assure against various hazards and certain aspects of containment, radioactive waste processing and other support systems essigned to the B ranc h. Prior to this assignment I was a Mechanical Engineer in the Electrical, Instrumentation and Control Systems Branch where I reviewed the integrity, operability and functional capability of mechanical and electrical equipment, mechanical compenents, and supports neer'ed for safe operation and safe shutdown of nuclear facilities.
Prior to beino assignec to the Electrical Instrumentation and Control Systems Branch, I was a Mechaqlcal Engineer in the Equipment Qualifica-tion Branch where my dutit.s included performing technical reviews, analyses and evaluations of the adecuacy of the environmental qualifica-tion of efectrical and mechanical equiprrent whose failure, due to such environmental conditions as terrperature, humidity, pressure and radiation, could adversely affect the performance of safety systems. I was previously a Materials Engineer in the Materlats Engineering Branch where my duties and responsibilities involved the review and evaluation of-materials pe.r formance from the stanc: point of operability and functional capabihty and integrity ender normal, abnormal, and acciaent loading conditions, and analyzing fracture toughness of reactor vessel materials, including specific data to assure that the traterials will behave in a non-brittle manner.
Prior to my position in the Materials Engireering Branch, I was a Materials Engineer in the Engineering Branch, Division of Operating Reactors . My duties and responsibilities included the review of operatino problems to determine whether safety requirements were being satisfied and to assure that operating prcblems were corrected, with due regard for safety and environmental protectir,n.
Frior to my position in the Er.gineering Branch, I was a ACRS Fellow at the Advisory Committee on Reactor Sa feguards . My duties included collecting and consolidating inferrration pertaining to non-destructive
, testing riethods.
. I hold a B.E. degree in mechanical enoineering from the City College of
, the City University of New York and I have taken graduate courses at the University of Pittsburgh, Prior to joining the NRC, I was an engineer at Westinghouse Research Corporation in Pittsburgh , Pennsylvania where my duties included the application of the state of the art fracture mechanics as well as the study of structural integrity of materials in various environments and under various loading conditions.
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e 00CKETED USNRC t!NITED STATES OF AMERICA NUCLEAR PEGULATORY COMMISSION '88 FEB 19 P3 :32 BEFORE TliE_ ATOMIC SAFETY AND LICENSING APPEA$fdCTARDiFEig
-y L MCf.
In the Matter of )
) Docket Nos. 50-4c3 OL-01 PUBLIC SERVICE COMPANY OF ) 50-444 OL-01 NEYi H AMPSHIRE, e_t t g. ) On-site Emergency Planning
) and Safety issues (Seabrook Station, Units 1 and 2) )
CERTIFICATE OF SERVICF I hereby cer tify that copies of "NRC STAFF RESPONSE TO NECNP MOTION TO REOPEN RECORD AND A DMIT NEW CONTENTION" in the above-captioned proceeding have been served on the following by deprsit in the United States mall, first class or, as indicated by an asterisk, by coposit in the Nuclear Regulatory Commission's internal mail system, this 17th day of February 1986.
Sheldon J. Wolfe, Esq., Chairman
- Atomic Safety and Licensing Adr'Inistrative Judge Roaro*
Atemle Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Dr. Jerry Harbour
- Docketing and Service Section*
Administrative Judge Office of the Secretary Atomic Safety ano Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Dr. Emmeth A. Luebke Thomas G. Dignan, Jr., Esq.
Administrative Judge Robert K. Cad, lli, Esq.
5500 Friendship Boulevard Ropes & Gray Apartment 1922N 225 Franklin Street
- Chevy Chase, Maryland 20815 Boston, MA 02110 3
Atomic Safety and Licensing H. J. Flynn, Esq.
Appeal Panel
- Assistant General Counsel U.S. Nuclear Regulatory Commission Federal Emergency Management Agency Washington, DC 20555 500 C Street, SW p- %ashington, DC 20472 l
o Philip Ahren, Esq. Calvin A. Canney Assistant Attorney General City Hall Cffice of the Attorney General 126 Daniel Street
- State House Station Pcrtsmouth, NH 03801 Augusta, .ME ~ 04333 s Mr. Angle Machiros, Chairman
, Carol S. Sneider, Esq. Board of Selectmen Assistant Attorney General 25 High Road Office of the Attorney General Newbury, MA 09150 One Ashburton Place,19th Flocr Roston, MA 02108 George Dana Bisbee, Esq. Allen Lampert Assistant Attorney General Civil Defense Director Office of the Attorrey General Town of Brentwood 25 Capitol Street 20 Franklin Concord, NH 03301 Exeter, NH 03833 Ellyn R. Weiss, Esq. William Armstrong Diane Curran, Esq. Civil Defense Director Parrecn & Weiss Town oF Exeter 2001 S Street, NW 10 Front Street
- Suite 430 Exeter, NH 03833 Washington, DC 20009 Robert A. Backus, Esq. Gary W. Holmes, Esq.
Backus, Meyer S Solomon Holmes & Ellis 110 Lowell Street 47 Winnacunnet Road Manchester, NH 03106 Hampton, NH 038C Paul McEachern, Esq. J. P. Nadeau Matthew T. Brock, Esq. Board of Selectmen Shaines & McEachern 10 Central Street 25 Maplewood Avenue Rye, NH 03870 P.O. Box 360 Portsmouth, NH 03801 Judith H. Mizner, Esq. '
Charles P. Graham, Esq. Silverglate, Gertner, Paker, f.icKay, Murphy & Graham Fine S Good 100 Main Street 88 Board Street Arresbury, MA 01913 Besten, MA 02110
- Sandra Gavutis, Chairman Robert Carrigg, Chairman Board of Selectrnen Board of Selectmen RFD #1, Box 1154 Town Office Kensington, NH 03827 Atlantle Avenue North Hampton, NH 03870
e V.'llliam S. Lord Peter J. Matthews, Mayor Beard of Selectmen City Hall Town Hall - Friend Street Newburyport, MN 09150 Amesbury, MA .01913 e Mrs. Anne E. Goodman, Chairman Michael Santosuosso, Chairman Poard of Selectmen Board of Selectmen 13-15 Newmarket Road South Hampton, NH 03827 Durham, - N P 03824 Hon. Cordon J. Humphrey United States Senate 531 Hart Senate Office Building V>ashington, DC 20510
('1 6
(,_.e L* i m -' / [""
. Edwin J. Reis Deputy' Assistant General Counsel 4
I e