ML20212P608

Requests ASLBP Reschedule Prehearing Conference Originally Set for 860903,so Issues Being Posed Fully Understood & Proceeding Appropriately Organized.Related Correspondence

ML20212P608
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	08/28/1986
From:	Irwin D HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:	Kline J, Margulies M, Shon F Atomic Safety and Licensing Board Panel
References
CON-#386-549 OL-5, NUDOCS 8609030207
Download: ML20212P608 (13)

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Morton B.

Margulies, Esq., Chairman Dr. Jerry R.

Kline Mr. Frederick J.

Shon Atomic Safety and Licensing Board Panel

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U.S. Nuclear Regulatory Commission 4

East-West Tower, Room 402-A 4350 East-West Highway v

Bethesda, Maryland 20814

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'i ss a n Long Island Lighting Company (Shoreham Nuclear Power Station, Unit.1)_...--,.

(Docket No. 50-322-OL-5)

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Gentlemen' LILCO has received the.Intervenors' 300-page reply, dated l

August 25, to LILCO's and the NRC Staf f's separate responses to.-

Intervenors' proposed contentions.

LILCO has also received the Board's order, issued the next day, postponing sine die the prehearing conference scheduled for September 3.

LILCO under-stands the Board's apparent conclusion that assimilating the 658 pages of pleadings now before it (462 of them from Intervenors) j' is impossible as a practical matter between now and September 3..

It is crucial that the Board have adequate opportunity at the outset to understand the issues being posed, while the chance ex-ists to shape the proceeding appropriately.

LILCO will reserve its substantive responses to the manifold issues raised by Inter-venors' reply until the to-be-rescheduled prehearing conference, l

absent a request from the Board for an earlier written response.

In the meantime, LILCO does ask that the Board reschedule the prehearing conference at the earliest feasible date after September 3, for the following reasons:

i l

1.

This proceeding, which the Commission commanded to be expedited, is already in danger of being substantially delayed.

Over seven months have now passed since the pertinent 12-hour ex-

):

l eccise took place, over five months since the official FEMA B6090'.)207 860828 PDR AaOCK 00000322 OS'd 3

4 4

Huwrow & WII.I.IAMs August 28, 1986 Page 2 report on it was published, and nearly three months since the Commission, in CLI-86-ll, commanded that this proceeding be con-ducted on an expedited basis.

2.

Delay to date, and the potential for far further delay, are the direct result of Intervenors' actions.

First, in Juna when this Board initially attempted to organize the proceeding, Intervenors claimed an inability to understand the litigation's bases and secured a delay in the submission of their contentions until August 1.

Next, they hindered the actual shaping of issues by filing a set of proposed contentions on the exercise that is significantly longer than the actual FEMA report ' ort the exercise, even though the contentions mention hardly a factitha't~is not contained in the FEMA report. The length of their submission forced upon LILCO and the Staff a three-day extension of their response period.1/ Now, Intervenors have filed a " reply" to those responses that is nearly twice as long as the contentions themselves.

Thus Intervenors have heaped upon ghis Board nearly 500 pages of contentions and related argument._2f 3.

LILCO deserves an opportunity to receive a merits judg-ment on an operating license. Shoreham is ready to help meet Long Island's electric needs: indeed, earlier this week during contin-ued low power testing the plant generated 10 net megawatts of commercially usable electricity, enough to light some 10,000 homes (see attached news clips.)

Further, Long Island needs a resolution of the Shoreham controversy.

On August 11, James i

Larocca, President of the Long Island Association, wrote a let-j ter, attached, to the President of the United States about i

1/

Even so, the Staff was working within a truncated time frame since under the Rules of Practice the Staff's response deadline to pleadings is normally 5 days later than that of other parties, thus building in an opportunity, not afforded here, to review all other parties' pleadings before filing its response.

See 10 CFR l

55'2.714(c), 2.730(c).

2/

Intervenors' papers include, in 162 pages, 50 contentions in about 175 subparts, or about one subcontention for every 3.77 minutes of the February 13 exercise.

These contentions, taken together with Intervenors' 300-page reply to LILCO's and the NRC Staff's separate responses to them, occupy nearly three-quarters of the bulk of paper which the Board has found indigestible by September 3.

L

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4 HuwroN & WILLIAMS August 28, 1986 Page 3 Shoreham.

That letter includes the following passages, which bear recitation:

For years, Long Island has been embroiled in a controversy concerning its completed but unlicensed Shoreham nuclear power plant.

The extended and complex public controversy has now entered a critical phase.

While the Nu-clear Regulatory Commission has continued its licensing consideration of the plant, both the State of New York and Suffolk County each have initiated steps to acquire the Long Island Lighting Company, with the intention of forcing Shoreham to be, abandoned.

While political figures, lawyers and oth-era have benefited greatly from the prolonged conflict, the residents and businesses on Long Island have been severely shortchanged.

At present, the situation has degenerated to a point where intercession to speed NRC completion of its proceedings is clearly jus-tified.

We are writing on behalf of the Long Is-land Association, the region's largest busi-ness and civic organization, with approxi-mately 3,000 member firms employing almost 400,000 people.

Because both the national and regional interests are in harmony, we share an interest in having the NRC process completed.

Surely after more than a decade there is enough in-formation available to NRC to render its judg-ment.

We are not seeking your intervention in the making of that judgment, but rather in di-recting the NRC to move ahead to a conclusion of its proceedings, to resolve the issue one way or another.

If the plant is to be li-censed, we need to know.

If it is not to be licensed, both the region and the nation need to act immediately to offset the critical loss of this generating capacity from our system

(

4 6

HtiSrow & WII.I.IAMs August 28, 1986 Page 4 and our economy.

But unquestionably, we are at a point where continued irresolution is the worst of all possible worlds.

4.

This Board has previously declined to entertain LILCO's suggestions for special procedures to expedite this proceeding, indicating that it believed the normal rules provided sufficient means to regulate its progress.

Tr. 16087-88 (July 8, 1986).

While LILCO agrees witn the Board's assessment of the potential efficacy of the normal rules, bitter experience has taught LILCO that proceedings conducted completely pursuant to them can re-quire literally years when opponents are well financed and deter-mined: excluding " inactive" periods, the basic safety phase of this proceeding, involving 12 litigated issues, required 116 days of hearings spanning 13 months; the diesel generator phase, en$ quired 47 days of hearings involving four principal issues, re spanning 15 months; the'offsiniJ rgency..planniAga M,n r W p~m <

c involving 33 litigated issue groups',;. required;80 hearing-daysM y spanning 12 months.

Only the expedited low power proceeding > red-

'e quired fewer; and while its initially. precipitous pace - - not adav"

~ ~.

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vocated for repetition here by LILCO L-was interreupted by a lawsuit, the revised procee' ding was.-still completed in-22 hearingrl '.'a days spanning 4 months.

Whil~e LILCO-agrees with the Board thati

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the normal Rules of Practice can provide a sufficient framework for a decision within a reasonable Lime, constant vigilance and

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the imposition of limits of ale:. types may prove necessary, and soon.

LILCO will be prepared-to discuss appropriate measures at the prehearing conference._3/

3/

In this regard, brief rev'iew of the initial stages of the original emergency planning proceeding in 1983 may be instruc-tive, since they involve numerous situations similar to those de-veloping here.

In the original proceeding, the Lic3nsing Board issued an initial Order requiring Intervenors to file draft pro-posed emergency planning contentions'four weeks from the date they received the modified LILCO offsite emergency plan (revised to eliminate previously assumed County participation),

i.e., by' June ?.3, 1983.

Final proposed contentions were to be done two weeks later.

Soon after receipt of the LILCO plan, the County requested a six-to ten-week extension of their filing deadline.

When the Board denied this request, Intervenors filed their ini-tial submission, consisting of 146 separately numbered draft con-tentions on 196 pages, on the due date, June 23.

Following a (footnote continued) l

- - _ ~ - -

-~_-

s HUNTON & WILLIAMS August 28, 1986 Page 5 Thus, for the reasons outlined above, LILCO respectfully re-quests the Board to schedule the prehearing conference, original-ly set for September 3, for the earliest practicable date there-after.

. Respectfully submitted, Donald P.

Irwin One of Counsel for Long Island Lighting Company cc:

Docketing and Service Section Counsel for all Parties (continued from previous page)

July 13 prehearing conference, Intervenors reorganized their con-l tentions and filed them in final form on July 26, 1983.

By this j

point the contentions numbered 97, most of them with subparts, consuming 177 pages'of text.

LILCO's response to them, filed one week later (August 2), was 68 pages long; the Staff's response, filed on the same day as LILCO's, was 48 pages long.

Suffolk County's reply, filed August 8, was 127 pages long.

The very next day, August 9, the Board held a previously scheduled second prehearing conference, and on August 19 issued an Order ruling on i

I the admissibility of contentions.

That Order admitted 58 of the j

contentions wholly and another 16 in part, and denied only 23 i

outright.

It also set out a schedule projecting commencement of l

hearings, following discovery and summary disposition practice, by November 14, 1983.

Intervenors, however, soon succeeded in significantly broadening and protracting the discovery phase of the proceeding, rendering the originally projected schedule unre-i alistic.

LILCO, in order to get actual hearings started, eventu-ally agreed to (1) divide the issues into two principal phases l

according to their general readiness for trial, and (2) with l

minor exceptions, drop the summary disposition process.

Hearings ultimately began on December 6, 1983 and ran through August 29, l

1984, reconvening briefly in late June 1985.

l i

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_p-Shoreha, m Generates Power for 1st Time By Rick Brand Shoreham nuclear-power plant generated g

O power for the first time yesterday, prod enough P

electricity d low-power testa to about pg,g g, h t g g M*SM'ertdated y

10,00014ng Isl homes.

h 807 megawatt plant, which began construe-ponerbegna, "

9 a-

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'Imag of p(the M rw W steine 24-hour test ofits three turbines and giant genep engRS maissed W M Q A 2..

ator b not power production was 10 megawatts; g

WhemenatenUL ~

the lant needs 9 megawatts to operate.

1 seger n.

t's very significant" said John T-=d, f

.assubanehE' Island f fahd-- Co.'s vice president for nuclear et5st.7:CT.

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saira, because it abowe that all aspects of the r

p,ptuned M* J are ready... If God were to come down say P

is ese

... you have a license, we could start our power

,;y 41EBcI M h afttu k ni-i le ina oo uario

,,,,,gg,g===- >f playeddown significance theevent,callingita s-citystunt that does nothing a

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h 25 W

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.a.ma. to o er.t. Shoreham at,to help LIILO g

g,,... ;y uu u.

ennae has b,en held up psoding fxieral approval of e

. suest" t g g,

the evacuation plan the company submitted to the g

eagesdess NuclearRegula r-=lamian af'ar the state and aWilelsen-tDsugermelledaftesis c

Sufibik County to partacipate in emergency sAsr a usAsPWuel bugiassus Q{faQ, f, p

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quelsmes,b,meltW 0 continues to play games with Is.

r gt:Phstafessbeesuso afh outsh landers," Cuomo said in a statement.

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eq 33 very week we hear reports thousands of 7,$siaal4p3%

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as gensassesissener h

le --.

House agrees: Ieng Island enanot be evacuated.

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'Iberefore Shoreham should never open."

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It's both outrageous and irrelevant,"said county 14gis. Wayne Prospect (D.Diz Hills). "It's outra.

soons because it further contaminates the plant, and it's irnlevant boca closer to lia===ng.,,use it takes LIILO not one inch eration of electricity is not required by the federal agency in kw-poww heta.

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LI140 has had a lla,na='6am the NBC last During kw.poww heting up u now,12120 has I

"""'" to test Shoreham at 5 percent of power.

aaaa= W on b wtba ofik nuclem-t higherpo volssSd the plant into commercial tion. Paramarcial produsu b sten bp tima y g

d, tion would allow the u to gradually put powm b generskr.

to rates that of the Ian s $4.6 biulon east LILCO aMdata concede that power on that h state lic Ca==i==ian ruled was dose not usuallyoscur untila plant 12 to15 j

prudently incurred.

percent power, but added that the aa==pany wanted Eugene Gantshorn, a spohm===n for the Atomic to the turbine and generatore into operation to i

Industrial Forum, an industry trade group, said that sure they work properly.

ucing power at levels below 5 percent power is "We were very ennoarned that we might have unusual" and has been done at only one or two some problems sitting there that we were not aware of the other 100 licensed nuclear plants around the of," Isamard said. "Now there are no unknowns." He country.

amid testing the generator new abould save IJILO Clare Miles, an NRC spokaswoman, said b gen.,

--Continued on Page 21

NEWSP,AFER lt M g

-Continued fireen Page 2 yesterday morning that the erankshaA set to the thee in later tests, should the plant get a Adi-power messaanry 1,800 revolutione per minute to generate

license, and the power supply was synchronised to Plant odBenale, however, say they do set plea to e power grid. At the tier, the plant was oper-eentinue to operate the plant because running it at sting at 4.5 percent power.

such low power levele le i==81da=* and could short.

b plant Bret produesd power at 12:49 a.m. as en the usual 18 month life of the plant's nuclear about50LIICO eemsultante thanGener-fhol. Inw-peyer testing will anatinus er two to a! Electric, the man.', -

ufbeturer efthe plant; and ensi-three weeks including some flarther turning of the ' asere then Stone and Webster, Snoreinam's sentree-turbines but not the generator, odBasale said.

tor, looked on.

Imenard said the plant staf started trying to rua "We just looked at each other quietly at first and the generator and turbines 10 daye but a pueb.

then mailed " said Imenard. '"Fhen aAer everything less with acoilina relay switch dels the test.He seemed to b working Ane, a ro,und of applause said it took several days toleolate

• prehleen and beske out br the plant operatore."

replace the part.

Plant edReinle awoke LII40 chairman William N actual -- - ?-M= of electrici come, he Catasesinos at his Mill Neck estate to tell him the said, aAer the t stasbegna going a 90-news. "His see answered the phone," Imonard said.

' list ofpro teste at 9 a.m.

y. N "He enhed me ifit wee impertent. I said it was very bogen to tra the crankshaA cenaseted to haportant." Lemmast thes ;put Steiger en the phone the generator about 1 p.m. But it was not until aerfy to odleially labra C"- ~

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f NEWSPAPER ffDRS DATE h

PAGE 3

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ShorehamFutsPower Into Lilco's Network

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HICK 5VILLE, L.I., Aug. 28 - The Shoreham nuclear power plant still does not have an operating Ilconse.

But today, for the first time, the om.

battled reactor supplied electrictly to

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-e f Long Island homes. And

~~

o it was all within the rules.

"It's a milestone," Lynne Abra.

ham, a vice pres 6 dent of the W Is.

land Lighting Company, Shoreham's owner, said. "It's just a low. power test but it is the first time and it is going fine."

She sand the was producing 18 for its own needs menawatts, an(for those of 000 homes.

Governor Cuomo has said the

$4.8 billion Shoreham plant is unsafe and should never open. Both the state, and suffolk County, where the plant is, have enacted legislation aimed at taking over Linco and closing the I has applied for a Federal commercial operating license for Shoreham, ano low. power testing is permitted while the request is being considered.

The executive coordinator of the Shoreham u Coallm. M Bredes, caled the tests "a pubhc relations gimmick."

m ist Shoreham is inevitable. Shoreham is going to get a Heense," she said.

"Well, none of that is certain."

I l

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f Shoreham 'ghts up its 1st L.L customers By MICHAEL HANRAHAN i

i omer e sw w The controversial Shoreham nuclear power plant produced commercial electricity for the first time yesterday. The event came 19 years and almost $5 billion after work on the plant began.

The Long Island Lighting full power.

munity Electric Corp.-was Co.'s nuclear facility pro.

In a related development, found to be preempted by the

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duced its first commercial the Suffolk County Legisla. state-created Long Island electricity at 12:49 a.m.

ture made a final bid to real. Power Authority.

yesterday, and will continue ise its takeover plan for The Supreme Court ver.

I j

to generate electricity for 24 Shoreham by filing an dict was unanimously upheld Frida hours as part of its low, appeal with the State Court sion, y by the Applelate Divi.

but the county still has i

power testing program, of Appeals.

"The electricity was pro.

The county had been re. one chance left with the duced when the plant's main strained from selling $7.3 bil. Court of Appeals, turbine and generator were lion worth of bonds by the "If we lose this one, the i

initially synchronized with State Supreme Court because ball game is over," said Greg-

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the LILCO grid," said LILCO the organ it created to take cry Blass, prediding officer spokesman William Thoretz. over Shoreham-the Com-of the Suffolk Legislature.

The synchronization test

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la one of the final tests to l

make the plant ready for p.

l commercial operation.

l For 10,000 homes

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l "The plant generated 19 D>

't.

I megawatts of electricity,"ex.

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plained Thoreta "which was

=gf 13 sufficient to supply nine N

power needs... the balance W

s megawatts for the plant's 4

gs of 10 megawatts provided Ar

" 4 S

5, electricity for 10,000 Long 1sland homes."

4 Shoreham has the capac.

ity to produce 820 megawatts

@) b" of electricity at full power.

Out of that,11 megawatts 3

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would be needed to run the plant.

"The commercial produc..

tion of electricity is not a-secessary part of the low.

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needed for a license," ex.

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g power testing program plained Thoreta. "But we

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wanted to test it anyway."

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p-

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4 The second round of low m-4T,rde e e$n ic[

sM l tions made since the plant completed 6% power testing last October. The plant has a license to test at up to S7. of l

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i

b o LongIsland AssocioNon,Inc, g

60 Houppouge Dood Commocle. Long Isaond, NY 11725 516 4994400 kBL 7,N.?dRE A August 14, 1986 The President

• i

• The White House V

Washington, D.C.

20500 Dear Mr. Presidents r

For years, kng Island has been embroiled in a controversy concerning its completed but unlicensed Shoraham nuclear power plant. The extended and complex pub!!c controversy has now entered a critical phase. While the Nuclear Regulatory Commission has continued Itflicensing consideration of the plant, both the State of New York and Suffolk County each have initiated steps to acquire the Long Island Lighting Company, with the intention of forcing Shoreham to be abandoned.

While political figures, lawyers and others have benefited greatly from the prolonged conflict, the residents and businesses on Long Island have been severely shortchanged. The Long Island Lighting Company is occa-sionally unable to meet summer peak demand for energy. Businesses and our nearly three million residents routinely face the threat of power cutbacks and voltage reductions, while paying some of the highest electric rates in the country. While the controversy continues, neither the short-term or long-term questions of generating capacity or alternative sources of energy for Long Island are being addressed. Further, each month of delay adds $40 to

$50 million in additional costs for the plant which ratepayers will bear, with-out any corresponding energy benefit being produced.

At present, the situation has degenerated to a point where intercession to speed NRC completion of its proceedings is clearly justified.

We are writing on behalf of the kng Island Associalton, the region's l

largest business and civic organisation, with approximately 3,000 member i

firme employing almost 400,000 people.

Our interests involve promoting the sconomic well-being of Long faland and protecting and enhancing the quality of life. Our region is enjoying extraordinary economic growth, with low un-employment and high personal income. Frankly, we want this economic health to continue and are deeply concerned that the extended controversy and lack of resolution on the electric power issue will do severe harm to the region --

harm which will be felt over the next several decades or more.

We are aware of the constraints on the ability of the Executive Branch to intercede in a matter before a regulatory body, and we are not requesting such action of you.

Rather, we believe that there are, in addition to very important regional issues, broad national policy issues which require your attention.

I Swna lcol Island Since 1926

l Page 2 The Shoreham issue has been a source of controversy since the early 1970's and is apparently many years away from a final resolution. The Long Island Association is deeply concerned that a resolution of this controversy may be delayed indefinitely, to the grave detriment of our region. After almost fifteen years of consideration, Shoreham must be resolved. one way or another.

Our regional economy simply cannot withstand further delay and inaction.

During this lengthy process, federal jurisdiction has become increasingly subordinate to state and local actions of a highly politicized nature.

Shoreham has clearly become a test case of the ability of the federal government to esercise its legal jurisdiction with regard to the use of nuclear power in this country. From a national perspective, failure to protect that jurisdiction may in this instance have a dramatic impact upon the nuclear alternative in meeting our energy supply needs for decades to come.

\\

Long Island is' virtually 100% dependent upon foreign on to produce its electricity, a fact which became dramaticauy clear during the oil crises of the 1970's. At that time, and continuing today, federal energy policy has been to protect the country's energy needs from the actions of foreign governments by producing as much energy as possible from domestic sources. Nuclear power was chosen for Long Island on the strength of that national policy.

Because both the national and regional interests are in harmony, we share an interest in having the NRC process completed.

Surely after more than a decade there is enough information available to NRC to render its judgment.

We are not seeking your intervention in the making of that judgment, but rather in directing the NRC to move ahead to a conclusion of its praesedings, to resolve 4'

the issue or.e way or another. If the plant is to be licensed, we need to know.

If it is not to be ucensed, both the region and the nation need to act immediately to offset the critical loss of this generating capacity from our system and our economy.

But unquestionably, we are at a point where continued irresolution is I

the worst of all possible worlds.

Surely it is not inappropriate for the White House to require a regulatory agency to conclude its work in a timely fashion.

That is au we are asking.

l Thank you for your consideration of our views.

Respectfully, "AW h 4 ; ---

M r

James L. Larocca i

President Ji.Liam l

l 1

i

a LILCO, August 28,1986 i

CERTIFICATE OF SERVICE In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)

Docket No. 50-322-OL-5 I hereby certify that copies of a letter to the Licensing Board from Donald P.

Irwin, dated August 28, 1986 were served this date upon the following by Federal Express as indicated by an asterisk, or by first-class mail, postage prepaid.

Morton B. Margulies, Chairman

• Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 East-West Towers, Rm. 407 4350 East-West Hwy.

Bernard M. Bordenick, Esq.

• Bethesda, MD 20814 Oreste Russ Pirfo, Esq.

Edwin J. Reis, Esq.

Dr. Jerry R. Kline

• U.S. Nuclear Regulatory Commission Atomic Safety and Licensing 7735 Old Georgetown Road Board (to mailroom)

U.S. Nuclear Regulatory Commission Bethesda, MD 20814 East-West Towers, Rm. 427 4350 East-West Hwy.

Herbert H. Brown, Esq.

• Bethesda, MD 20814 Lawrence Coe Lanpher, Esq.

Karla J. Letsche, Esq.

Mr. Frederick J. Shon

• Kirkpatrick & Lockhart Atomic Safety and Licensing Eighth Floor Board 1900 M Street, N.W.

U.S. Nuclear Regt'latory Commission Washington, D.C. 20036 East-West Towers, Rm. 430 4350 East-West Hwy.

Fabian G. Palomino, Esq.

• Bethesda, MD 20814 Special Counsel to the Governor Executive Chamber Secretary of the Commission Room 229 Attention Docketing and Service State Capitol Section Albany, New York 12224 U.S.14uclear Regulatory Commission 1717 H Street, N.W.

Mary Gundrum, Esq.

Washington, D.C. 20555 Assistant Attorney General 2 World Trade Center Atomic Safety and Licensing Room 4614 Appeal Board Panel New York, New York 10047 U.S. Nuclear Regulatory Commission Washington, D.C. 20555

b %

Spence W. Perry, Esq.

William E. Cumming, Esq.

General Counsel Associate General Counsel Federal Emergency Management Federal Emergency Management Agency Agency 501 C Street, S.W., Room 840 500 C Street, S.W.

Washington, D.C. 20472 Room 840 Washington, D.C. 20472 Mr. Jay Dunkleberger New York State Energy Office Ms. Nora Bredes Agency Building 2 Executive Coordinator Empire State Plaza Shoreham Opponents' Coalition Albany, New York 12223 195 East Main Street Smithtown, New York 11787 Stewart M. Glass, Esq.

Regional Counsel Gerald C. Crotty, Esq.

Federal Emergency Management Counsel to the Governor Agency Executive Chamber 26 Federal Plaza, Room 1349 State Capitol New York, New York 10278 Albany, New York 12224 Stephen B. Latham, Esq.

• Martin Bradley Ashare, Esq.

Twomey, Latham & Shea Eugene R. Kelly, Esq.

33 West Second Street Suffolk County Attorney P.O. Box 298 H. Lee Dennison Building Riverhead, New York 11901 Veterans Memorial Highway Hauppauge, New York 11787 Jonathan D. Feinberg, Esq.

New York State Department of Dr. Monroe Schneider Public Service, Staff Counsel North Shore Committee Three Rockefeller Plaza P.O. Box 231 Albany, New York 12223 Wading River, NY 11792 I

m Donald P. Irwin Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: August 28, 1986

,