ML20206R366

Responds to NRC 860515 Performance Appraisal Team/Safety Sys Functional Insp Rept 50-289/86-03.Corrective Actions:Single Failure Analysis on Air Supply Sys to Emergency Feedwater Valves Being Finalized

ML20206R366
Person / Time
Site:	Three Mile Island
Issue date:	06/27/1986
From:	Hukill H GENERAL PUBLIC UTILITIES CORP.
To:	Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
5211-86-2099, NUDOCS 8607070126
Download: ML20206R366 (13)

Text

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.4 GPU Nuclear Corporation r Nuclear  :::, ors:r8o Middletown, Pennsylvania 17057-0191 717 944 7621 TELEX 04 2386 Writer's Direct Dial Number:

June 27, 1986 5211-86-2099 Office of Inspection and Enforcement Attn: J. M. Taylor, Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Taylor:

Three Mile Island Nuclear Station Unit 1 (TMI-1)

Operating License No. DPR-50 Docket No. 50-289 Response to NRC Performance Appraisal Team Report This letter is written in response to your May 15, 1986 Performance Appraisal Team (PAT)/ Safety System Functional Inspection Report (50-289/86-03). A two-week extension to the original 30 day response was granted by Mr. L. J. Callan on June 13, 1986.

This letter addresses some of the key specific and programmatic issues. The Report identified several specific deficiencies in the design and configuration control area, and requested a response describing the actions taken and planned to improve the overall activities related to design changes and plant modification, and corrective actions for the Two Hour Backup Instrument Air System and Remote Shutdown Panel isolation. This letter specifically responds to these items.

Section A of this letter addresses the Two Hour Backup Instrument Air System and Remote Shutdown Panel isolation, Section B addresses other Specific Issues, and Section C addresses Generic Issues which includes configuration control and plant modifications.

A. Key Specific Issues

1. Two-Hour Air Supply for Emergency Feedwater System The system configuration was corrected prior to startup from the SM Cutage to allow the system to withstand a single active failure identified during the PAT inspection. A safety evaluation and procedural changes were completed before TMI-l returned to power.

This was reported to the NRC by phone and by License Event Report 8607070126 860627 ~)

PDR ADOCK 03000289 40 G PDR 0

GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation ' '

i 5211-86-2099 86-07 (forwarded April 25, 1986). With three independent sources for supplying air to the EFW system, the piping arrangement was overly complex. The corrective action was to simplify the design by isolating piping that was not seismically qualified.

A comprehensive Single Failure Analysis on the air supply system to

, the EFW valves is being finalized. Preliminary results show that the.

system will perform its safety design function during design accidents with a single active failure. This Single Failure Analysis is i

scheduled to be completed and documented by July,1986.

2. Remote Shutdown Panel - Power Supply Isolation The PAT finding involved two examples of inadequate circuit isolation i per 10 CFR 50 Appendix R requirements. One was in the Remote Shutdown Panel and was installed to meet GPUN commitments regarding TMI-l restart and was not required to meet 10 CFR 50 Appendix R requirements until startup from the 6R Outage. The other example was a portion of the Appendix R Modification engineering which had not yet undergone 1

the associated circuit review.

1 i The PAT finding was not applicable to the existing Remote Shutdown l Panel which is operational, acceptable for service and satisfies existing isolation requirements. Engineering to add circuit isolation has been issued for incorporation during the 6R Outage.

GPUN is committed to be in compliance with 10CFR50 Appendix R by the end of the next refueling outage (6R). One of the previously defined ongoing efforts in the Appendix R design program not initiated at the time of the PAT inspection is the completion of an a:;sociated circuit review. This had been established as one of the final portions in the design review process. This associated circuit review will result in j a high degree of confidence that all the alternate shutdown circuits are properly isolated from the effects of circuit failures caused by

, fire.

The cases identified by the NRC during the PAT Inspection are specific examples of circuit isolation that we expect would have been identified in the course of the planned circuit review.

, B. Other Specific Issues i

1. Post Modification Functional Testing Items II.A.2.b and III.D.2.b & c of the Report deal with verification

! of the failure position for EFW flow control valves and atmospheric i dump valves. The findings indicate that initial testing of the l failure modes was not performed and that routine surveillance testing

is also not performed.

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4 GPUN considers the first part of the finding in II.A.2.b to be in j error, since the Test Procedure TP 248/2, Rev. O did require the '

verification of correct failure mode. It should be noted that the e original performance of this test (conducted December 9,1983) was i

unsuccessful; however, after replacing appropriate check valve springs i with ones of greater preload, the test was successfully performed.

The re-test (conducted January 25, 1984) documents successful testing j and is available for review.

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The routine testing of valves in II. A.2.b and III.D.2.b & e is j currently being reviewed by Plant Engineering. This review is to l determine what testing or inspection is appropriate and the best method to achieve the desired results. We expect to complete this j review and issue needed procedure revisions if appropriate by the end j of 1986.

l To improve interfacing end communication of test requirements, GPUN l wi11' require the assigned test _ engineer to discuss with the designer ,

1 (in addition to more formal, existing documentation) design 1 j requirerents and asr.mptions, as well as proposed testing and

i acceptance criteria to confirm design bases. The applicable procedures are being revised to reflect this requirement and are expected to be issued by September,1986.

2. Temporary Shielding 4

All temporary shielding was removed from TMI Unit 1 prior to startup j from the SM Outage. However af ter startup, one temporary shielding i installation was completed. This installation was made only af ter an l engineering evaluation which included a Safety Evaluation was

! performed.

I GPUN is currently performing a comprehensive review of the existing procedure requirements and controls for installation of shielding.

k' This review has determined that a procedure revision is necessary.

l This procedure revision will include the following points:

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An engineering evaluation will be performed prior to each installation of temporary shielding. For temporary shielding l during an outage, generic procedure instructions may apply.

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To ensure that plant conditions are maintained consistent with possible restrictions imposed by a' temporary shielding engineering

evaluation, the shif t supervisor shall provide approval for i

proposed temporary shielding installations.  ;

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The engineering technical evaluation will consider the piping  !

l size, code allowables, seismic constraints, and system operating

, parameters. The Procedure will also require that shielding  ;

! fastening requirements are satisfied. '

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The Safety Evaluation will follow established GPUk procedure requirements. However, additional questions specific to shielding installation following INP0 recommended good practices will be incorporated in the procedure revision.

3. Electrical Protection The Report identified several issues in the Electrical Protection area. These issues include pump motor overcurrent protection, battery sizing, breaker coordination, associated circuit coordination, fuse change modification, grounding practices and minimum motor starting voltages for valves. GPUN has reviewed each of the issues as follows:

a) PUMP MOTOR OVERCURRENT PROTECTION:

Specific action taken includes the resetting of the relay on the EFW Pump Motor to take into account long term thermal degradation of the motor. This was done af ter an analysis of data supplied by the manufacturer and existing data, and was completed prior to startup from the SM Outage.

In order to provide confidence in the coordinated protection for nuclear safety related motors, GPUN will perform a comprehensive review and verification of protective relay settings for all large (4KV) motors. This review is expected to be completed by the end of 1986. So far GPUN has completed reviewing the Electrical Protection for all Nuclear Safety Related 4KV Motors. The following summarizes the results. The Decay Heat Punp Motor timesetting for the overload relays was lowered. The Makeup Pump Motors were reviewed and found to be satisfactory. The Reactor Bulding Spray Motors were reviewed and the overcurrent pickup was reduced from 140% full load current to 117% for a more sensitive response. The Reactor Building Cooling River Water Pumps were reviewed and found to be satisfactory, b) BATTERY SIZING:

The battery calculation is being revised to reflect the lowest expected temperatures for winter operation. The surveillance procedure which checks the battery cell temperatures will be revised to include limits on cell temperature and actions to be taken if cell temperature is not within the limits.

These actions along with periodic load tests will assure that battery capacity is maintained above that required for the design condition.

1 5211-86-2099 c) BREAKER COORDINATION:

A fault on the power canel feeding the ICS and EFW Instrumentation will cause a static transfer switch to transfer the power source from the inverter to a regulated power supply. A review during the PAT inspection indicates that the breaker coordination is acceptable. GPUN is design verifying this review. A detailed coordination study wfll be performed to document the acceptability of inverter bus breakers, d) ASSOCIATED CIRCUIT C0 ORDINATION:

The finding in III.A.2.d stated the associated circuit overcurrent protection coordination review performed during Appendix R evaluation did not consider the effect of the remaining electrical loads on the buses, while comparing the incoming main circuit with the largest associated circuit.

The industrial practice for short circuit current calculation and coordination studies is not to consider the load current (IEEE Standard 242-1975).

I In response to the PAT finding, an evaluation of the overcurrent protection coordination curves was made and checked for the effect of other electrical loads by adding the load current to the characteristic current of the largest associated circuits. We found that the overcurrent protection is properly coordinated even with the shutdown loads on the bus for electrical buses except l A-ES and 1B-ES motor control centers for breakers rated over 400A. This is consistent with the previous review. These bus motor control centers are large motor control centers serving many loa ds. Large circuit breakers are also utilized for the feeder circuits. Overcurrent protection coordination cannot be achieved for one large load (the substation feeder) which is protected with circuit breakers rated 500A. The 500A breaker has been replaced with a smaller rated breaker correcting this problem.

The results of this evaluation indicated the addition of load current does not alter the conclusion of the overcurrent coordination review.

e) FUSE CHANGE MODIFICATION:

The fuse change modification was done based on informally issued engineering documents. The fuse changes that were accomplished are being design verified in accordance with GPUN procedures to l assure that the use of unverified design input did not result in a design error. Preliminary results indicate that which was done is satisf actory.

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$ 5211-86-2099 f) GROUNDING PRACTICES:

GPUN plans to further standardize future engineering and design methods for grounding and shielding of instrumentation and control

(ISC) equipment. Tne standard design methods will provide i uniformity and the grounding / shielding practices are intended to

j' 1) reduce internal system electrical noise; 2) reduce electrical noise entering the system; 3) provide an optimum common point for 4

zero ground reference when two or more systems communicate, and 4) '

i ensure personnel safety. GPUN intends to issue engineering and i design standards which incorporate concepts and principles of the i following document:

j - Division of Reactor Development and Technology, U.S. Atomic Energy Commission, RDT Standard Cl-1T, " Instrumentation and Control Equipment Grounding and Shielding Practices",

January 1973.

g) MINIMUM MOTOR STARTING VOLTAGE FOR VALVES:

The original analysis performed in 1979 for the minimum motor starting voltage of safety-related valves was based on the bus voltages. The motor terminal voltages were assumed from the bus voltages and the analysis has not been updated since 1979 to include the additional valves. Preparations for a new voltage j analysis to update the previous analyses were started prior to the

! PAT inspection to address other concerns at TMI-1 and will also be 1 used to address the concerns of the PAT inspection. This analysis

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is expected to be completed by the end of 1986.

l 4. Drawing Accuracy 1 .

l GPUN is committed to the expeditious update of Control Room Drawings.

A check of the TMI-1 Plant Configuration Control List on June 17, 1986

{ identified 6 of the approximately 2,100 Control Room Drawings with 1 changes outstanding for more than 30 days. We are revising these j- drawings on a top priority basis in order to satisfy our commitment to update these drawings expeditiously.

j The two Control Room P8ID's listed in the PAT Report as being out of j date were reviewed on May 29, 1986, and found to have all outstanding change documents incorporated.

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] The 17 drawings, listed in the PAT Report as having inconsistencies  ;

, and errors, have been reviewed in order to determine the cause of the '

) deficiencies. Where appropriate, action to correct the specific l drawing deficiencies is being initiated. In our judgment, the causes

for the 17 drawing deficiencies can be broken down as follows

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! Draf ting Checking Errors 8 l Not a Drawing Deficiency 5 i Lack of Standard Direction i on Drawing Content 1 Split Design Respontibility 3

5211-86-2099 4 Regarding the draf ting checking errors, one major contributor to these checking errors was a lack of cross references on construction drawings to other affected as-built drawings. GPUN issued instructions to its design organizations several months ago i emphasizing the importance of providing these cross references and also directing that whenever practicable construction drawings are to ,

be markups of existing as-builts. Both of these actions will minimize drawing errors from this source in the future.

For most of those items where we do not believe a drawing deficiency

, exists, this is due to the drawino content being consistent with GPUN normal practice.

Regarding the lack of direction on drawing content, GPUN has an

! ongoing effort to update drawing standards in order to better define the required format and content. As a part of this effort, we will include directions on the content of logic diagrams.

The three deficiencies related to split design responsibility were all related to missing seismic boundaries on drawings. Split design 4

responsibilities was used on occasion in the past to expedite the modification progress. The current and planned future practice at GPUN is to not split design responsibilities between two organizations in order to eliminate the type of communication problems these three

- drawing deficiencies illustrate.

5. Quality Classification List. (QCL) i In October 1985 GPUN began the development of a TMI-l component level Quality Classification List (QCL) and is scheduled to complete the list for Nuclear Safety Related (NSR) and Regulatory Required (RR) components by the end of 1986. The QCL will be a computerized listing (including basis) for each NSR/RR System Component including the EFW System and Two Hour Backup Instrument Air System. Until such time as

, the component level QCL is issued, the existing QCL in the GPUN Procedure will be used. The Two Hour Backup Instrument Air System (852.6) has been specifically identified on the QCL as a Category 1 (Important to Safety) System.

6. Mini-Mods Program l

l The issues identified by the Report were in two areas, 50.59 Safety Evaluations and Installation Specifications. Specific action has been taken on both items.

The identified Safety Evaluations are being revised to identify the

. FSAR changes required. Also, additional direction has been given on

updating the FSAR. A procedure revision has been initiated to clarify

! this requirement.

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5211-86-2099 The Report also identified a concern with compliance with the procedure requirements for installation specifications. The inspector felt that the procedure mandated addressing each point listed in the Procedure Task Requirements outline. The guidance had been that these were suggested points to address. If the item was not pertinent to the modification, then it need not be addressed. The procedure is being revised to more clearly specify that each item is to be addressed.

In addition, a QA audit of the " mini-mod" program has recently been completed. The results of the audit indicated that no programatic deficiencies existed. However, the results did confirm the need to clarify the procedure and indicated that the need for FSAR updates were isolated cases. The level of detail provided by the " mini-mod" task documents to describe the design aspects was found to be consistent with the complexity of the modification.

7. Design Change Process i

a. Use of Job Ticket i It is reported that this finding derives from review of Change Modification Request (CMR) #0515M and Job Ticket #CH269, Disconnection of Instrument Air Tubing from IA-Vil25 to EF-Y8A.

This CMR evaluation states "the work shall be completed under general job ticket guidance and is not considered to be a modification as regulated by GPUN Procedure EMP-019". As such, the PAT finding is partially correct in that this work was done by job ticket (as directed by Plant Engineering), however, the disabling of the air operator for EF-V8A had been the subject of several previous design reviews, safety evaluations and docketed correspondence to the NRC and little or no (further) design review

was required. Because of reviews backfitted on the Emergency Feedwater System which determined that the EF-V8A/B/C valves' flow switches and solenoid valves were not environmentally qualified, a commitment was made to the NRC to block these recirculation valves in the open position. Several analyses and tests were done to conclude that the reduction in delivered EFW flow caused by the open recirculation paths is still acceptable since it provides adequate steam generator heat removal capacity to support accident safety analysis requirements. These analyses were referenced on CMR #0515M.

The design reviews for the modification, defeating the air-operator on EF-V8A/B/C by blocking these valves open, were adequately and completely done at that time, and were previously accepted by the NRC. Disconnecting and capping an air supply to the EF-V8A operator (whose action had previously been defeated with appropriate engineering evaluation and direction to fulfill a

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5211-86-2099 1 commitment to the NRC) was adequately reviewed and directed by Change Modification Request #0515M and Job Ticket #CH-269 in 3

accordance with GPUN Administrative and Design Change Procedures.

Performance of this work was adequately documented by Job Ticket

, #CH-269 and CMR #0515M and FCN #038336, which was initiated on

[ March 25, 1986 to revise the affected drawing for this minor

tubing deletion.

! In summary, GPUN believes there was no violation of its own administrative and design review procedures and that the design review for this minor tubf ag deletion was adequate.

, b. Temporary Jumpers The finding on re-evaluation of lif ted leads, jumpers, and temporary modifications every 12 months was reviewed. The '

question of this finding should be whether the re-evaluation was

performed correctly and documented. It has been determined that the re-evaluations are being performed according to procedure

! requirements. However instead of completing a new Safety Evaluation / Design Review form the past practice was to re-sign the 2 existing form. The practice of re-signing has been determined to

] be satisfactory and the procedure will be revised to reflect this.

l c. Procurement of Quality Instrument Air 1 Two specific actions were taken relative to this item. First a j Quality Deficiency Report (QDR) was initiated for this item.

1 Prior to initiating the QDR, QA determined with Plant Engineering j concurrence, through conversation and written correspondence, that +

j the quality of air actually received from the vendor exceeded the j required design dewpoint and filtration requirements and thus.was

satisfactory for its intended use. ,

a 4 The second action then was to revise the Purchase Order i i requirement relative to the quality requirements which would .;

i ensure adequate controls on future procurements. This also has i been completed, i

I In addition to the above actions, the broader question of f procurements meeting design requirements was reviewed. We believe that this was an isolated case.

8. Operations and Maintenance Areas u

i a. Maintenance - EFW Pump Discharge Check Valvy

! The procedure for the EFW system flow test is being revised to l 1 resolve the concern about potential back leakage through idle pump check valves,

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5211-86-2099 In addition, the report states that Mechanical Maintenance Task MM-000031 had not been conducted yet for EF-V11 A/B and 13. This is true. However, it should be noted that in 1980 EF-Vil A/B and 13 were disassembled to resolve problems with Crane tilting disc check valves. All three of these valves were found to be in excellent condition and were rully operable. These valves see very little service. Almost all the service they see is related to mLnthly IST pump and valve testing or cold shutdown flow path testing. Therefore, very little wear is expected to occur for these valves.

Furthermore, the EF-V12A/B valves which are identical to EF-V13 were also inspected in 1980-81. These valves were also found to be in excellent condition. Therefore, in the approximate 7 years of service, including four operating fuel cycles and initial Startup testing prior to the 1980 disassembled inspection of all 5 check valves in the EFW pump discharge flowpath, no significant discrepancies were identified on any of these valves. Because of the minimal amount of operation and cycling (leading to wear) and the high-quality non-corrosive water that comprises the environment for these valves, the next disassembled inspection of these valves is expected to confirm the excellent condition of their internals,

b. Out of Specification Log Entries This item has been brought to the attention of each member of the operating shif ts and as a result, an improvement has been seen in this area. To ensure our continued success in this area, additional documentation of Operations Engineering review has been added to the daily A/0 log sheets. Additionally, review of log sheets has been emphasized in the off-duty management tour program.

c. Surveillance Test of Turbine Driven EFW Pump Since the PAT inspection a test was performed that demonstrated that the EFW Turbine driven pump (EF-P-1) would not overspeed or have other speed control difficulties due to the potential condensate buildup in the steam supply lines over a period of time in which operators did not manually verify the lack of condensate.

In accordance with Procedure STP-1-86-0014, the appropriate steam traps were tagged to prevent manual blowdown. In fact, caps were placed on leaking blowdown valves to prevent any questions concerning initial conditions. Blowdown of the appropriate steam traps did not occur for 28 hrs, and 40 minutes.

r 5211-86-2099 EF-P-1 was started without any indication of speed control problems due to condensate. EF-P-1 exhibited a stable acceleration to 3800 rpm and stable operation at 3800 rpm for longer than any time required to flush potential condensate from the steam supply line. Accordingly, it is concluded that there was no EF-P-1 speed control problem due to condensate in the steam supply line.

In addition, MPR Report WO 915 dated March 1986 analytically concludes that the system piping configuration could not collect sufficient condensate to cause an EF-P-1 overspeed control problem.

Based on the results of our testing and the MPR report, we I consider this item resolved. We do plan to continue to blow down the steam traps routinely as recommended by the manufacturer in order to ensure the best routine operating conditions for this equipment,

d. Two-Hour Backup Instrument Air Leakage The operators verify each shif t that the system pressure is greater than 1500 psig. Any significant leakrate that would require a more frequent verification that system pressure is maintained 1500 psig would also cause an investigation and repair of tWe leaks. Also maintenance has performed " snoop" tests for leakage and tightened fittings as appropriate.

e. Maintenance of Motor Operated Valves (MOV's)

GPUN has been in the process of testing M0V's. As required by IE Bulletin 85-03, EFW and HPI M0V's require specific action relating to design and testing. However, GPUN was not limiting the testing of M0V's to these two systems. Over 50 valves have already been tested using M0 VATS testing and additional valves will be tested in the 6R Outage. Along with this testing, the types of issues identified in the PAT Report will be addressed.

C. Generic Issues GPUN has reviewed the Report on an overview basis to determine the generic areas that may need further attention. The areas identified are design verification methodology, control of design interface criteria, updating of control documents, proper translation of design parameters into procurement documents, extent of compliance with the details of procedures and the use of the best available information in the design process.

To determine if the PAT findings were isolated cases or indeed were generic to other systems, GPUN is performing 0A audits of other modifications. The results of the QA audits have not yet been fully developed. However, some preliminary findings indicate the following: i s

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5211-86-2099 1. Design Verification Methodology The PAT finding concerning the implementation of design verifications being a weakness appears to be valid. Although we believe that our procedures on how to do individual design verifications are good, it appears there is insufficient guidance to explain when design verification is required and how it is to be implemented. The end result was inconsistent implementation between individuals, sections and organizations.

It had always been our intent that design verification would be a combined project level assessment with selected document-by-document review. This philosophy is consistent with ANSI N45.2.11 Paragraph 6 l and ensures 'he design is looked at as a whole. We are currently revising the procedures to provide more specific requirements regarding design verification.

2. Control of Design Interface Criteria An issue which arises from many of the specific findings of the PAT inspection is how design criteria are controlled, especially the transmission and control of such criteria. GPUN has taken action in the past few years to improve the formality of control of design criteria. These include the requirement to hold one design review (Preliminary Engineering Design Review-PEDR) and a second overall review (Operability. Maintainability, Constructability Review-0MCR) on each plant modification (unless waived in writing by the responsible department director); the requirement that any change to a design document made by GPUN personnel be formally transmitted to the responsible engineering organization, if not GPUN; and the requirement that at the close of each job the responsible engineering organization review all changes which have been made during construction to insure that the original design criteria remain valid, i

GPUN has recently re-notified major engineering contractors in writing that they should not accept informal guidance regarding design criteria for plant modifications which they are engineering, but rather must insist that such criteria be transmitted formally.

3. Updating of Control Documents A Revision to the GPUN drawings procedure was recently approved. This revision establishes priority levels for initiating drawing

! revisions. The plan is to subdivide the over 60,000 drawings at TMI-1 into four separate priority categories with varying drawing revision requirements. For example, a revision priority 1 drawing "must be i revised expeditiously (scheduled immediately - target for completion is 30 days) to incorporate any outstanding change document." After l review, we have determined that many of the 75 documents discussed in III.A.3.d of the Report will be classified a revision priority 3 which will allow six or more change documents to be outstanding ,

2 because of their infrequent use. Thus, the outstanding posting status t

• e p 5211-86-2099 for many of these drawings will no longer be procedurally deficient.

Those which are deficient are being corrected. The recoding of the TMI-1 Plant Configuration Control List, with the drawing revision priorities, has commenced and is scheduled for completion during 1986. In the interim, the CARIRS Configuration Control Data Base will be periodically interrogated to identify documents with outstanding changes. The documents will either be revised or their revision priority identified in CARIRS on an exception basis.

We agree with the PAT finding in Paragraph III.A.3.e that additional procedural guidance on the use of CARIRS would help to eliminate -

confusion and improve understanding by users. The procedure is being revised to include user responsibilities, access authorization and methods and access training. Since detailed instructions on search strategies are frequently updated, they will not be proceduralized but will remain part of ongoing training.

4. Training Training sessions will be conducted for appropriate personnel this summer to cover the lessons learned. These training sessions will include the items from the PAT inspection and items identified in the GPUN QA audits as generic areas of concern. The main thrust of these required training sessions will be to re-emphasize the importance of the work being performed as well as the commitment to improving our overall procedural compliance.

In summary, the PAT Inspection identified weaknesses in several areas. GPUN has initiated action to resolve all of the issues identified. In most cases, action commenced immediately upon identification of the issue. The above presents details on many issues and taken as a whole indicates the continuing commitment by GPUN to safely operate TMI-1. This inspection has received the attention of senior GPUN management and actions identified will be followed through as noted.

Sincerely,

. . k 11 Vice President & Director, THI-1 HDH/DVH/sb:0605A cc: T. E. Murley R. Conte

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