ML20154A102
| ML20154A102 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 08/30/1988 |
| From: | Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | |
| Shared Package | |
| ML20154A090 | List: |
| References | |
| NUDOCS 8809120059 | |
| Download: ML20154A102 (22) | |
Text
_
S BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of Docket Nos. 50-277 PHILADELPHIA ELECTRIC COMPANY 50-278 APPLICATION FOR AMENDMENT OF PACILITY OPERATING LICENSES DPR-44 DPR-56 Eugene J.
Bradley 2301 Market Street Philadelphia, Pennsylvania 19101 Attorney for Philadelphia Electric Company khk9120039qgggr e
anu;,
vis' L
5 t
BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of Docket Nos. 50-277 PHILADELPl!IA ELECTRIC COMPANY 50-278 APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSES DPR-44 DPR-56 Philadelphia Electric Company, Licensee under Facility Operating Licenses DPR-44 and DPR-56, for the Peach Bottom Atomic Power Station (PDAPS) Unit No. 2 and Unit No.
3, respectively, hereby requests that the Technical Specifications contained in Appendix A to the Operating Licennes be amended.
Proposed changes to the Technical Specifications are indicated by the vet ical bars in the marginn of the attached pages 67, 71a, and 93a.
1-
I i
Introduction The original voltage regulation study for Peach Bottom was performed prior to licensing of Unis 2 in 1974.
The study was based on a combination of manual and time-shared computer calculations.
Voltage transients were considered only down to the 4.16kV level in that study, which was consistent with industry practice at that time.
In 1979, in response to an NRC request concerning the adequacy of station electric distribution voltages for Peach Bottom, additional voltage studies were performed.
These studies were performed assuming steady state conditions at all voltage levels but did not address the effects of motor starting trancients since they were expected to last only a few seconds.
Modifications were designed and implemented based on that assumption.
Because of industry experience gained in the area of voltage regulation which was disseminated by NRC Information Notices, and the availability of more sophisticated calculation techniques, Licensee elected to perform a revised voltage regulation study for Peach Bottom which considers tcansients down to the 480V level.
As a result of the revised study, deficiencies in the degraded voltage protection scheme were identified.
The purpose of this Application is to propose changes to the Technical Specifications to correct the deficiencies.
The proposed changes in this Application are grouped into two categories.
The Category A changes address the degraded grid protective relays, and involve increasing the time delay for the 4.16kV bus or the emergency power system to transfer to an._
s alternate power supply and decreasing the voltage setpoint on the instantaneous undervoltage relays on the 4.16kV buses (Modification 5002).
Category B changes address the Emergency Core Cooling System (ECCS) loading sequence (Modification 2564).
Each category of changes includes a System Discussion, Description of Changes, Safety Discussion and a No Significant Hazards Consideration.
The Application concludes with a common Environmental Impact Assessment.
Attached to this Application are the following; Pigures 1 and 2, proposed Technical Specification pages and Supplemental Information.
4 System Discucslon - Category A A simplified single line diagram of the Peach Bottom electrical distribution system is shown on the attached Figure 1.
The two independent offsite power sources are referred to as the No. 2 and No. 3 start-up sources.
The 4.16kV bus feeder breakers provide the interface between the two offsite power sources and ths plant safety-related AC power distribution system.
Each of the four 4.16kV buses, identified as the 4kV emergency buses at the bottom of Figure 1, in each unit can be powered by either of the two offsite power supplies.
Normally, each of the two oftsite power sources supplies two 4.16kV buses in each unit.
}
Each of the 4.16kV buses can also be powered from a safety-related diesel generator.
!4 1
Each startup source to each 4.16kV bus is equipped with an instantaneous undervoltage protective relay.
Each relay is presently set to initiate at 90% of nominal voltage on the 4.16kV 5
i t
bus.
The purpose of these relays is to ensure that adequate levels of voltage are provided to the motors and control components which are powered from the'480V motor control centers i
(MCCs) which are fed from the 4.16kV buses.
Certain control l
components are specified to operate at +/-10% of nominal voltage to preclude damage from low voltage.
A simplified diagram of the 4.16kV bus which includes its 480V load center is shown on the r
(
j attached Pigure 2.
i The degraded grid protective relays shown on Figure 2 as I
UV-1 initiate time delay relays which transfer the 4.16kV bus to j
an alternate supply source if the normal supply source does not
[
recover to the instantaneous relay reset value (currently 93%) in i
i a set period of time.
Each of the four 4.16kV buses on each unit 5
has two instantaneous relays, one associated with each of the two i
j offsite power sources, The control circuit logic to the time i
l delay relays distinguishes between an undervoltage condition
(
without a safety injection signal and one concurrent with a safety injection signal.
Without a safety injection signal, a time delay relay will initiate the transfer 60 seconds after l
initiation of the instantaneous relay if the voltage does not recover.
The 60 seconds allows time for the tap changers on the l
i l
offsite source transformers to adjust the voltage or for the
[
i operator to take manual actions (i.e. shed loads) to improv*e the l
voltage.
With a safety injection signal, another time delay relay will initiate the transfer bus 6 seconds after initiation j
l of the instantaneous relay if the voltage does not recover.
The t
i I
purpose of the 6 second delay is to minimize the time that 4
i I '
safety-related equipment is exposed to the undervoltage r
condition, yet allow the voltage to recover from the dips caused by acceleration of the large safety-related motors.
In either case, if the voltage of tne normal supply has not recovered before the time delay relavs initiate the transfer, the associated source breaker is tripped and the bus is loaded onto an alternate power supply.
The alternate supply for any 4.16kV bus is, in order of preference, the remaining offsite power f
source, then the emergency di<sel generator.
The revised voltage regulation study identified tnat under the scenario of a safety injection signal on one unit while operating with only one of twa j
i offsite power sources (permitted for 7 days by Limiting Condition
)
for Operation 3.9.D.1), the existing 6 second time delay setting i,
is inadequate.
The existing 6 seconds would not allow sufficient l
acceleration time for the core spray pump motors.
Therefore, even after a 6 second delay, the core spray pump motors, which I
are currently started simultaneously, will not be at rated speed (based on design acceleration versus voltage values) thereby not
)
allowing voltage recovery on the 4.16kV buses, a:'d all four l
4.16kV bus feeder breakers will trip, thus loading each bus ento 4
l its associated diesel generator.
Description of Changes - Category A 4
Licensee proposes the following changes.
T I
(1)
Revise Table 3.2.B on page 71a to designate the trip level setting for the instantaneous relays as i
"89% of rated voltage 1 0.30% of setting (3702 l
l volts 1 11 volts)" instead of "901 (+/-2%) of rated i l
t voltage", and replace the "(ITE)" in the trip function column with "(27N)".
(2)
Revise Table 3.2.8 on page 71a to designate the trip level setting for the time delay relays as "9 second (+/-7%) time delay" instead of "6 second
(+/-5%) time delay".
(3)
Revises BASES section 3.2 on page 937 to reflect the 891 setting of the instantaneous relay.
(4)
Revise BASES section 3.2 on page 93a to reflect the 9 second time delay.
Safety Discussion - Category A Change Request (1) is proposed to improve the protection provided by the undervoltage protective relays which sense the voltage leval on the offsite power sources to the 4.16kV buses.
This Change Request involves replacing the existing instantaneous relay (ITE) with one with improved setpoint accuracy (27N).
The proposed trip level setting is 89% of rated voltage 10.30% of Smitir.g.
The present setting of the existing relays is 90% 12%
of rated voltage.
Although this is a decrease in the setpoint value, the protection to the 480V control components poweret et the MCCs is improved due to improved operational tolerances of the new relays.
The setpoint of the existing relay was selected to assure adequate voltage to loads and control components on the 4601 system.
Although the proposed setpoint is below the ilot manufacturers' design tole:ance, field tests have been performed to determine actual pick-up voltage valuea for sizes 1, 2,
3 and 4 notor contactors and other safety-related control co.nponents that could experience this voltage.
This range covers the contactor sizes used in the 480V powered MCCs at Peach Bottom.
The field measured pick-up voltage for this range of sta.-ters is less than 75% of nominal voltage.
Licensee concludes that the proposed setting with improved tolerance will provide sufficient voltage protection to all loads powered from the 430V MCCs.
Change Request (2) is proposed to prevent a spurious transfer of the 4.16kV buses to the diesel generators under the design basis condition of a safety injection signal on one "nit with only one offsite power source available.
A safety injection is the automatic plant response to a loss of coolant accident
( LCCA ), and requires the starting of the ECCS pumps.
Because of
.arge demands on the 4.16kV buses incurred from pump motor acceleration, a LOCA load sequence on a single offsite power so.cce is the most limiting design basis accident for the emergency s/Jcem.
Licensee proposes to increase the time delay on the 4.16kV bus from 6 seconds to 9 seconds to allow sufficient time for the 4.16kV bus to recover from the normal motor acceleration transJ the cote spray pumps.
Under single offsite source opr.
nditions and the existing load
=;
sequencing scheme, the core spray pump motor voltage is 81.4 percent (0.814 pu) resulting in a design value core spray acceleration time in excess of 17 seconds.
This long acceleration time exceeds the existing 6 second delay and, therefore, would result in the 4.16kV bus being separated from _.
the available offsite source and loaded onco the associated diesel generator.
Under the prcposed revised load sequencing schen,e discussed in the Cate ory B changes, the minimum ecte spray motor terminal voltage is such that che worst case core spray pump acceleration time is w.tnin 9 seconds.
Therefore, the i
proposed 9 second setting of the inctantaneous degraded voltage relay (27tJ) is adequat" to ensure that the core spray motors will accelerate under a dep-aded voltage condition and the undervoltage relays wil) reeet prior to causic.g the feed breakers to tr!p.
The time E lay meets the intent of NRC Branch Technical s
Position PSD-1 whi tt=tes that the time delay should be sufficient duratic
- or 'something longer tnan that of a motor starting transient-Change Requests (3) and (4) revine the Bases to atrarately reflect Change RequeGts (1) and (2), respectively.
Consistency between the Bases and their corresponding upec;fications is necessary to avoid misinterpretations and to enhance the understanJirg of the intept of the requirements.
tio significant If azards Consideratic'T - CategoryJ (1)
The proposed Category A charges,do not involve a sfgnit! cant increase in the probability or consequencep f any accident previously evaluated.
o The Category A changes are proposed to improve the protection erovided by the undervoltage protective relaya.
Although the proposed setpoint is lower than -
the existing setpoint, protection to the 480V control b
l-components powered from the MCC s is improved due to improved operational tolerances of the proposed replacement relaya.
Increasing the setting on the time delay relay'from 6 seconds to 9 seconds will ensure that 6
the 4.16.kV buses will not be spuriously transferred to i'
the diesel generators in the event of a design basis accident with only one Offsita power source available, j
f These proposed changes do not affect the probabi.'ity or i
1 i
consequences of any accidents previously evaluated, but r
ensure that the 4.16kV buses will not be spuriously I
l transferred to the diesel generators thereby ensuring the validity of the existing accident analysis; l
specifically, a loss of coolant accident with off-site l-j power available.
t i
l i
l (2)
The proposed Category A chan_ges do not create the possibility of a new or different kind of accident from i
1 t
f, any previously evaluated.
[
b l
The proposed changes to the relay settings do not i
l involve a redistribution of loads on safety-related 4
I buses or affect the electrical separation or redundancy i
]
of any safety-related trains or components.
The 4
proposed changes improve the undervoltage protective scheme and allow the 4.16kV buses to sustain a normal motor acceleration tr.snsient without a spurious transfer to an alternate power scurce.
The Category A changes do i
-9 I
i
O not alter the intent of the relays, and do not create the possibility of a new or different kind of accidLnt from any previously evaluated.
(3)
The proposed Category A changes do not rG3 ult in a significant reduction in,a margin of safetv.
The Category A chaages are proposed to enhance safety.
Although the proposed 891 setting does not assute 90%
voltage at the MCC contactors as suggested by manufacturers' design tolerances (+10%), field tests have been performed which indicate that the actual pick-up voltage is less than 75% of nominal voltage.
Increasing the time delay settings allows puinp motors to accelerate without an unnecessary transfer to an alternate power supply.
The changes do not involve a significant reduction in any margin of safety.
System Discuss'.on - Category B The Peach Bottom 'mergency Core Cooling System in designed to meet the acceptance criteria defined in 10 CFR 50.46 to ensure fuel integrity for the entiro spectrum of postulated LOCAs.
The ECCS is actuated by either of two diverse indications of a LOCA: reactor vessel low water level or primary containment (drywell) high pressure.
The ECCS consists of the High Pressure Coolant Injection (HPCI) System, the Automatic Depressurization System (ADS), the Core Spray (CS) bystem and the Low Pressure Coolant Injection (LPCI) mode of the Residual Heat Removal (RHR)
System.
The four CS pumps and the four RHR pumps are powered from the 4.16kV buses.
(The HPCI pump is turbine-driven and there are no pumps in the ADS).
In the event of a LOCA with off-site power available, the RHR and CS pumps are loaded sequentially onto the 4.16kV buses to preclude severe voltage transients from the simultanecas starting of the pumps.
The present loading sequence for the RHR and CS pumps in the event of a safety injection signal with offsite power available is as follows:
time =
0 ueconds Initiation of safety injection signal Start various 4SCV safety-related loads Start RHR pumps A and B 5 seconds Start RHR pumps C and D 10 seconds Start CS pumps A, B, C, and D 1
As described previously, this loading sequence results in vcitcge dips on the 4.16kV and 480V buses which are unacceptable in consideration of the degraded grid protective relay settings due to core spray pump motor acceleration time.
Therefore, Licensee proposes the following loading sequence for a scfety injection signal with offsite power available:
i time =
0 seconds initiation of safety injection signal I
f Start various 480V safety-related loads j
2 seconds Start RHR-pumps A and B I
8 seconds Start RHR pumps C and D 13 seconds 3 tart CS pumps A.and C h
23 seconds Start CS pumps B and D I
3-These tilaas were selected to minimize voltage transient I
l effects on the plant electrical distribution system &nd connected
[
l loads.
The timer change from 0 to 2 seconds for the A and B RHR 3
pumps is introduced to allow 480V control and connected load accelerations prior to the RHR pump motor starts.
The timer change from 5 to 8 seconds for the C and D kHR pumps is j
introduced to allow 2 seconds for the 430V control and connected i
j load accelerations plus an additional second to provide the 480V i
loads with a slightly longer time available for acceleration.
i The CS statting sequence is modified most significantly to split 1
the fcur motor starts into two segments of twa pumps each, which minimizes transient voltage effects and improves CS acceleration I
time.
The time between and following CS motor starts is l
!.ntroduced in recognition of the acceleration requirements of j
these particular motors.
- j In addition to the proposed ECCS loading sequence, Licensee will further improve the voltage regulation of the 480V
- )
Joad centero during a motor starting transient by a combination of plant modifications which revise the load shedding or sequencing of tha Emergency Service Water pumps, the Emergency Cooling Water pump, the RHR compartment coolers, the cooling towers and the diesel generator vent supply fans.
Licensee plans to perform these ahanges pursuant to 10 CPR 50.59 since none involves an unreviewed safety question or a change to the Technical Specifications.
Description of Changes - Category B:
Licensee proposes the following changes:
(1) Revise Table 3.2.B on page 67 to designate the initiation setpoint for the A and C : ore spray pumps to be "13 sec. +/-
7% of setting" and the initiation setpoint for the B and D core spray pumps to be "23 sec. +/-7% of setting".
(2) Revise Table 3.2.B on page 67 to designate the initiation setpoint for the A and B LPCI pumps to be "2 sec. :/-7% of setting" and the initiation setpoint for the C and D LPCI pumps to be "8 sec. +/-71 of setting".
(3) Revise Table 3.2.B on page 67 of the Unit 3 Technical Specifications only to delete the asterisk next to the ADS Bypass Timer and the footnite which reads "Effective whers modification associated with this amendment is complete."
Safety Discussion - Category B:
Licensee proposes Change Requests (1) and (2) to improve the degraded grid voltage protection on to the 480V buses and to accommodate CS motor start transients in the event of a design basis accident while operating with only one offsite power source available.
The proposed Category B changes to the RHR and CS loading sequence do not affect the loading sequence of the diesel generators in the event of a LOCA coincident with a loss of offsite power.
The Appendix K (ECCS Evaluation Models) analysis was used to determine bounding allowable starting times for the RilR and CS pumps.
The proposed timer settings are within the limiting starting times assumed in the Aprendix K analysis.
For Change Request (1), Licensee concluded that the proposed increases in the core spray timer settings are within the Appendix K analysis.
Success of the core spray system i
requires two factors:
- 1) pump ready for rated flow and 2) injection valve open to permit full flow.
Pump ready for rated flow is defined as the pump being at design full speed.
Full flow through the injection valve is defined as valve full open.
There are two conditions required to support worst case valve openings reactor pressure is at the low end of its low pressure permissive (400-500 psig) and power is available to the valve operator.
The limiting Appendix K scenario for CS is a 100%
break in the reactor recirculation discharge line.
Under this scenario, the low pressure perml154ve occurs 47 seconds following occurrence of the LOCA.
Power to the valves must be established prior to this time.
(Power to these valves is not interrupted in l
e this scenario.) The valve stroke time is 12 seconds.
The earliest that the injection valve can be opened, therefore, is 59 seconds, and the pumps must be ready for full flow prior to this time.
The series of events contributing to the establishment of the pumps ready for rated flow are the sensor times for detection of the LOCA (3 seconds), the time for power to be available at the emergency bus (this time is zero since offsite power is available for this scenario), the time for power to be available to the pump motor (pump timer relay setting) and pump motor acceleration time (dependent upon motor terminal voltage) which is less than 9 seconds at the voltage level resulting after tne plant modifications previously described are completed.
As stated previously, the.\\ppendix X analysis assumes the time available to start and accelerate the CS pumps from the offsite sources is 59 seconds.
Taking into account the above equipment operational time requirements, the CS timer setting must be less than 47 seconds (59 seconds minus 3 seconds for detection and a maximum of 9 seconds for acceleration).
Thus, the 13 and 23 second timer settings proposed by this Application are within the analyzed condition.
Por Change Request (2), Licensee has similarly concluded that the proposed increases in RHR pump timer settings are in accordance with the Appendix K analysis.
Success of the low pressure coolant injection (LPCI) mode of the RHR system requires three factors:
- 1) pump ready for rated flow, 2) injection valve open to permit full flow a a 3) full closure of the recirculation discharge valve.
The limiting Appendix K scenario for LPCI is a %
e 1001 break in the reactor recirculation suction line.
Under this scenario, 57 seconds are available for the RHR pumps to start and accelerate to rated speed.
The 57 seconds are derived from the time to reach the 1e.v pressure permiscive to close the reactor recirculation discharge /alve (30 seconds to 200-250 psig) plus the full stroke closure time of the recirculation discharge valve (27 seconds).
The series of events for the RHR pumps ready for rated flow are identical to the series of events for the CS pumps except that the kHR pump acceleration time is 3.1 seconds at the worst case voltage level pumping into an operating system.
Taking into account the sensor and acceleration delays, th RHR timer setting must be Aess than 50.9 seconds (57 seconds minus 3 seconds for detection and 3.1 seconds for acceleration).
- Thus, the 2 and 8 second timer settings proposed by this Application are within the analyzed condition.
Neither ChLnge Request involves additional loading onto the DC system.
The RHR pumps and CS pumps are presently equipped with either auxillary or time delay relays.
The existing relays for the B and D CS pumps and the A and B kHR pumps must be replaced to accommodate tne proposed setting of 23 seconds and 2 seconds respectively.
The power consumption of both the existing and replacement relays is 6 watts each.
Therefore, no additional load is incurred by these relays.
All replaccinent and additional relays resulting f rom Change Requests (1) and (2) vill be located in existing safety-related panels, the panels are located in a mild environment.
The control relays provided will equal or exceed the ratings of,
i the existing relays and meet the applicable design requirements for environmental and seismic qualification.
Change Request (3) is proposed to the Unit 3 Technical Specificat'ons only to delete a footnote which is no longer required since the modification associated with the ADS bypass timer (Modification 633) was completed for Unit 3 on February 24, 1996.
Removing the footnote will eliminate the need to check the status of the modification to determine the applicability of the specification.
Licensee proposes this administrative change to enhance safety by reducing the effort required to interpret the specification.
l Licensee concludes that the proposed revised loading sequence will ensure adequate voltage for motor acceleration during a design basis accident with only one offsite power source available, and the proposed changes do not adversely affect the existing Appendix K analysis or DC power system reliability.
No Significant liazards Consideration - Category Bt 1
(1)
The proposed Category B changes do not involve a significant increase in the probability or consequences i
of any accident previoucly evaluated.
s The Category B changes are proposed to ensure the validity of the existing accident analyses; specifically, a design basis LOCA with offsite power available.
Revising the timer settings for the RHR and CS pumps will improve the voltage at the 400V levels e
during a motor acceleration transient and also prevents spurious transfer of the 4.16kV buses to the diesel generators in the event of a safety injection while operating with only one off-site power source availablu, Therefore, the proposed changes do not increase the probability or consequences of an accident previously evaluated.
(2)
The proposed Category B changes do not create the possibility of a new or different kind of accident from any previously evaluated.
The proposed changes to the CS and RHR systems only involve changes to load sequencing when offsite power is available.
The proposed changes do not involve the CS or RiiR syrtem piping configurations, pumps, valves or system redundancies.
The replacement timers required for the preposed load sequencing equal or exceed the retings for the existin; timers, and do not affect the environmental or seismic goalification of the panels in which they will be installed.
Failure of any timer can only affect one reduncant train of equipment.
Therefore, the possibility of a new or different kind of accident is not created, j
(3)
The proposed Categon B changes do not result in a significant reduction in a margin of safety.
l _
The proposed changes do not adversely affect the safety margin assumed in the 10 CPR Appendix K analysis for enaur;ng fuel integrity for the entire spectrum of postulated LOCA s.
The limiting Appendix K sconario for core spray requires the CS pumps to be at rated flow 59 seconds after a LOCA to ensure the exit'ing margin of safety.
Under the proposed changes, the latest that the CS pumps will achieve rated flow is 35 seconds (3 seconds for detection of the LOCA plus 23 seconds for the longer of the CS timer delays plus a maximum of 9 seconds for motor acceleration).
The lireiting Appendix 1
K scenario for the los pressure coolant injection mode of residual heat removal requires the RHR pumps to be at rated flow 57 seconds after a LOCA to ensure the existing margin of sofety.
Under the proposed changes, t
the latest that the RHR pumps will achieve rated flow is 14.1 seconds (3 seconds for detection of the LOCA plus 8 seconds for the longer of the RHR timer delays plus 3.1 seconds for motor acceleration).
Therefore, although the Category B changes delay the availability of the CS and hdR pumps at rated flow, they do not result in a sigaificant reduction in the margin of s.ifety for core coolant delivery.
l Environmental Impact Assessment t
J Thece proposed amendmenta revise the eettings on the 4.16kV bus relays and revise the loading sequence for a safety l !
injection signal with offsite power available.
The Licensee has determined that these amendments involve no increase in the amounts and no change in the types of any effluents that may be released offsite, and has also determined that there is no increase in the individual or cumulative occupational exposure.
Therefore, there is no environmental consideration involved and consequently an environmental report is not submitted.
==
Conclusion:==
The proposed changes were analyzed to determine how they would affect the accident analyses contained in Section 14 of the PBAPS Updated Final Safety Analysis Report.
In addition, a determination of No Significant Hazards Consideration was completed, i
The Plant Operations Review Committee and the Nuclear Review Board have reviewed these proposed changes to the Technical Specifications and have concluded that they do not involve significant hazards considerations or an environmental consideration and will not endanger the health and safety of the public.
Licensee requests that the proposed changes be ?ifective I
upon completion of Modifications 2564 and 5002.
Respectfully submitted, PHILADELPHIA ELECTRIC COMPANY kJ bWuk (1JVice Predident i
COMMONWEALTH OF PENNSYLVA!1IA ss.
COUt4TY OP PllILADELPIII A J. W. Gallagher, being first duly sworn, deposes and says:
That he is Vice President of Philadelphia Electric Company, the Applicant herein; that he has read the foregoing Application for Amendment of Pacility Operating Licenses, and knows the contents thereof; ano that the stateraents and matters set forth therein are true and correct to the best of his knowledge, information and belief.
% $_Uf" O
O Vice President Subscribed and sworn to betore me this # day of August, 1988 c; : < > + s' & n'.
Js.jt v
(
N0tary Public AJo miV.M W e0JN Nc4=v Puemo, PMe, PMe. CS.
Ms Cunmium Empres JuN 28,1991
_