ML19326B894

From kanterella
Revision as of 17:59, 18 February 2020 by StriderTol (talk | contribs) (StriderTol Bot change)
(diff) ← Older revision | Latest revision (diff) | Newer revision → (diff)
Jump to navigation Jump to search
Requests OL Amend Revising Byproduct Matl Limits to Accommodate Calibr Requirements.Marked Up FSAR Changes Encl
ML19326B894
Person / Time
Site: Arkansas Nuclear Entergy icon.png
Issue date: 08/16/1978
From: Cavanaugh W
ARKANSAS POWER & LIGHT CO.
To:
References
NUDOCS 8004180622
Download: ML19326B894 (14)


Text

..

,o_, '

Qos(1s/k REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

DISTRIBUTION FOR INCOMING MATERIAL 50-313 REC: REID R W. ORG: CAVANAUGH W DOCDATE: 08/16/78 NRC AR PWR & LIGHT DATE RCVD: 08/23/78 DOCTYPE: LETTER NOTARIZED: YES COPIES RECEIVED

SUBJECT:

LTR 1 ENCL 40 FORWARDING LIC NO DPR-51 APPL FOR AMEND: TECH SPEC PROPOSED CHANGE CONCERNING REVIGION TO APPLICANT"S BYPRODUCT MATERIAL QUANTITY FOR CAL 1BRATING SUBJECT FACILITY"S RADIATION MONITORS. NOTARIZED.. W/ATT.

PLANT NAME: ARKANSAS - UNIT 1 REVIEWER INITI AL: XJM DISTRIBUTOR INITIAL:4 anoo************* DISTRIBUTION OF THIS MATERIAL IS AS FOLLOWS ******************

GENERAL DISTRIBUTION FOR AFTER ISSUANCE OF OPERATING LICENSE.

(DISTRIBUTION CODE AOO1)

FOR ACTION: BR_rHIEF ORB #4 BC**W// kNCL INTERNAL: FI *W/ ENCL NRC PDR**W/ ENCL i a u x*W/2 ENCL OELD**LTR ONLY HANAUER**W/ ENCL CORE PERFORMANCE BR**W/ ENCL AD FOR SYS & PROJ**W/ ENCL ENGINEERING BR**W/ ENCL REACTOR SAFETY BR**W/ ENCL PLANT SYSTEMS BR**W/ ENCL EEB**W/ ENCL EFFLUENT TREAT SYS**W/ ENCL -

J. MCGOUGH**W/ ENCL EXTERNAL: LPDR'S RUSSELLVILLE, AR**W/ ENCL TERA **W/ ENCL NSIC**W/ ENCL ACRS CAT B**W/16 ENCL

~

S000$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$

$ CHECK NBR$*5.177 $

$ AMOUN T: $1,200.00 $

0- CHECK AND COPY OF TRANSMITTAL LTR ADVANCED $

0 TO W. MILLER (LFMD) (OS/23/78) UPON RECIEPT $

$$$$$$$$$$$$$$$$$$$t$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$

)

)

l DISTRIBUTION: LTR 40 ENCL 39 CONTROL NDR: --732350MN SIZE: 2P+11P t)9 'y oco******************************** THE END *********************************

1 8 00418 0. f g'

3 m

,,. - ~~~e ~- '

m '

.c;d;m'4 ; _ 1 . . "-

ARKANSAS POWER & LIGHT COMPANY POST OFFICE BOX 551 UTTLE ROCK, ARKANSAS 72203 (501) 371-4422 WILLIAM CAVANAUGH 111 August 16, 1978 Executwe Director Generacon & Construccan 1-088-10 Director of-Nuclear Reactor Regulation ATTU: Mr R. W. Reid, Chief Operating Reactor Branch #2 U. S. Nuclear Regulatory Commission Washington, D. C. 20555  ?

Subject:

Arkansas Nuclear One - Unit 1 Docket No. 50-313 License No. DPR-51 Operating License Amendment (File: 1510)

Gentlemen:

Attached is a proposed change to the Arkansas Nuclear One-Unit 1 opera-ting License for your review and approval. Discussed below is the basis for our proposed change. -

Presently, Paragraph 2b of our operating license restricts the quantity of. byproduct material we may possess or use. A Krypton 85 source exceeding the limits of our operating license is required to calibrate (in accordance with our commitment to Region IV), area and process ra-diation monitors. We are proposing these changes to the operating license.to accommodate these calibration requirements.

~

In accordance with Regulatory Guide 170.3 the appropriate changes vill be made to the Unit 1 FSAR and incorporated in the next amendment. A

=arked up copy of these changes is enclosed.

We have determined that this amendment is of a pro forma nature and is strictly administrative. Accordingly our fee for a class II Amendment request as defined by.10CFR170.22 is enclosed in the amount of $1200.00.

Ve truly yours ,, . _ ,

s ) J

,A , .m. ew William Chzaffuagh n $ I Executive Director ' ~'

Generation and Construction WC/ MOW /JTE/ev i

VEMBEA MioOLE south UTIUT:ES SYSTEM Y Y$ l I

i. )

a STATE OF ARKxiSAS ) ,

) SS COUNTY OF PULASKI )

William Cavanaugh III, being duly svorn, states that he is Executive Director, Generation & Construction, for Arkansas Pcver & Light Company; C

that he is authorized on the part of said Company to sign and file with the Nuclear Regulatory Commission this Supplementary Information; that he has reviewed or caused to have reviewed all of the statements contained in such information, and that all such statements made and matters set forth therein are true and correct to t '_e best of his knowledra, inf r a-tion and belief.

William Cavanta@ III 1

SUBSCRIBED AND SWORN TO before me, a Notary Public in and for the County and State above named, this ' day of %Y _1978.

t Notary Public

- htr Con: mission Expires:

k._

c 7-

1. The receipt, possession, and use of source, byproduct and special nuclear material as authorized by this license will be in accordance'vith the Commission's regulations in 10 CFR Parts 30, 40 and 70, including 10 CFR Section 30.33, 40 32, 70.23 and 70 31.
2. Facility Operating License No. DPR-51 is hereby issued to the Arkansas Power and Light Company to read as follows:
a. This license ~ applies to Arkansas Nuclear One, Unit 1, a pressurized water reactor and associated equipment (the facility), owned by the

. Arkansas Power and Light Company. The facility is located in Pope County, Arkansas and is described in the " Final Safety Analysis Report" as supplemented and amended (Amendments 1 through 45) and

. the Environmental Report as supplemented and amended (Supplements 1 through 5).

b. Subject to the conditions and requirements incorporated herein, the Commission hereby licenses Arkansa. Power and Light Company:

(1) Pursuant to Section 10hb of the Act and 10 CFR Part 50,

" Licensing of Production and Utilization Facilities," to possess, use, and operate the facility at the designated location in Pope County, Arkansas in accordance with the procedures and limitations set forth in this license; (2) Pursuant to the Act and 10 CFR Parts 30, h0 and 70 to receive, possess and use at any time any byproduct, source .

and special nuclear material as reactor fuel, sealed neutron

' sources for reactor startup, sealed sorces for reactor in-I strumentation and radiation monitoring equipment calibration, and as fissicn detectors in amounts as required for reactor operation; (3) ~ Pursuant to the Act and 10 CFR Parts 30, ho and 70, to receive, possess, and use in amounts as required any by-product, source, or special nuclear material without '

restriction to chemical or physical for=, for ssmple analysis or instrument calibration or associated with t

radioactive apparatus or components, (h) Pursuant to the Act and 10 CFR Parts 30 and 70, to possess,

-but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

c. This license shall be deemed to contain and is subject to the con-ditions specified in the following Commission regulations in 10 CFR

' Chapter I: Part 20, Section 30 3h or Part 30, Section h0.hl of Part h0, Sections 50.5h and 50 59 of Part 50, and Section 70 32 of Part 70; is subject to all applicable provisions of the Act and to the the rules, regulations, and orders of the Commission now or here-after in effect; anu is subject to the additional conditions speci-fled or incorporated below:

1 L

3 12 MISCELLANEOUS BADICACTIVE MATERIALS SOURCES ipplicability

. Applies to byproduct, source, and special nuclear radioactive material sources.

Objective To assure that leakage from byproduct, source, and special nuclear radioactive material sources does.not exceed allowable limits.

' Specification.

3.12.1 The source leakage test performed pursuant to Specification h.1h shall be capable of detecting the presence of 0.005 uCi of radio-active material on the test sample. If the test reveals the pre-sence of 0.005 uCi or more of removable contamination, it shall immediately be withdrawn from use, decontaminated, and repaired, or be disposed of in accordance with Commission regulations.

Sealed sources are exempt from such leak tests when the source contains 100 uCi or less of beta and/or gamma emitting material or 5 uCi or less of alpha emitting material.

3.12.2 A Special Report shall be prepared and submitted to the Commission within 90 days if scuree leakage tests reveal the presence of 1 0.005 microcuries of removable contaimination.

3.12.; ^ complete inventory of licensed radioactive materials in possession ~

shall be maintained current at all times.

i I

1

.i

~

'h.lk RADI0 ACTIVE MATERIALS SOURCES SURVEILLANCE Applic' ability Applies'to leakage testing of byproduct, source, and special nuclear radio-active material sources.

~

Objective To assure that leakage from byproduct, source, and special nuclear radio-active material sources does not exceed allowable limits.

Specification Test for leakage and/or contanination shall be performed by the licensee or by other persons specifically authorized by the Comnission or an agree-ment State, as follows:

1. Each sealed source, except startup sources subject to core flux, contain-ing radioactive material, other than Hydrogen 3, with a half-life

. greater than 30 days and in any form other than gas shall be tested for leakage and/or contanination at intervals not to exceed six months.

2. The periodic leak test required does not apply to sealed sources that are stored and not being used. The sources excepted from this test shall be tested for leakage prior to any use or transfer to .

another user unless they have been leak tested within six months prior to the date of use or transfer. In the absence of a certifi-cate from a transferer indicating that a test has been made within six months prior to the transfer, sealed sources shall not be put into use until' tested.

3 Each sealed -startup sourc shall be tested within 31 days prior to being subjected to core flax and following repair or maintenance to the source.

3

~

~

16.9 RECORD RETENTIOT 6.9 1 The following records shall be retained for at least five years:

a. Records and logs of facility operation covering time interval at each power level.
b. Records and logs of principal maintenance activities, inspections.

- repair and replacement of principal items of equipment related to nuclear safety. '

c; :All Reportable Occurrences submitted to the Commission pursuant to Specification 6.12 3

d. Records of surveillance activities, inspections and calibrations required by the Appendix.A Technical Specifications.
e. Records of reactor tests and experiments.

1

f. Records of changes made to procedures required by Specifi-cation 6.8.1.
g. Records of radioactive shipments.
h. Tesc results, in units of microcuries, for leak tests performed on licensed sealed sources.
i. Results of annual physical inventory verifying accountability of .

licensed sources on record.

6.' 9. 2. The following records shall be retained for the duration of the Facility Operating License:

a. Records and drawing changes reflecting facility design modifica-tions made to systems and equipment described in the Final Safety Analysis Report.
b. Records of new and irradiated fuel inventory, fuel transfers and assembly burnup histories.
c. Records of facility radiation and contamination surveys.
d. Records of radiation exposure for all individuals entering radiation control areas.
e. Records of gaseous and liquid radioactive material released to the environs.
f. Records of transient or operational cycles for those facility com-ponents designed for a limited number of transients of cycles.
g. Reevrds of training and qualification for current members of the

. plant staff.

( #NQ - / )

L

( O.3 4-2-4 RADI0 ACTIVE MATERIALS SAFETY t I

i t . 2.1

{

12. ' .1- MATERIALS SAFETY PROGRAM  ;

ti.2.t.I 12.!.1.1 Special Nuclear Material Arkansas Power 6 Light Company has implemented a " Nuclear Fuel Safeguards and Accountability System" to atsure control of the special nuclear material under title to, er in the possession of, the Company. The use, storage and control of the special nuclear material at the operating

  • station is done accorling to the operating procedure entitled " Control and Accountability Procedure for Nuclear Fuel". This procedure is part I of the Company's fuel accountability program, and the procedure references the operating procedures that are used in receiving, handling and storing the fuel assemblics containing the special nuclear material. i Special nuclear material contained in unirradiated fuel assemblies is stored in ncn-critical arrays in either the new or spent fuel pools, both of

.e which re . ._.are r y MSeismic t o e . v,, Class I structures as described in Section Ti.' %e

- a - ft - 1, , , gj ,,,t A ,,; 2 g ;;;;7j;, ' IMSt.

npnmund fuel handline and-l W 4 r pre h t. s ...d uf m n; the L 1 ..; N iing l

,.c.y t p. nn t . ,e Anerv; w-4-% -W--< ,1,3raad,'o /c d fuel assemblies will

/t i be handle 1 and stored under water, as described in Section Wand license d shipping casks will be used to move the fuel from the site. 3 ,g,y,2 9

  • I _21-.-1-?

.: u.4 M ~4 t'e _* t re r c~_'rcer c er % cte- <* *+tm N. , ^

The neutron so' -u.ied for reactor startup consist ~

cncapsulated to form ce pellets lete neutron sou et.- Th ,e neutron sources are handled, assembled and st _ _ . 1 water according to the provisions of the " Neutron Source Hand .

roc '!-

The sources are stored in {

either the shipping c - or the neutron sourc er until the sources are loaded into assemblies. The fuel assemblies ining the neutron so inse

  • s are then returned to the spent t'uel storagD ra . or p cedure.into the reactor under the control of tne initial fuel loa t g

//. 3 . / 2. ,

12.A.1.3 Other Scaled Sources, - o C-The Radiological Safety Progran is described in Section ,1gand is fur.her clarified in the Radiation Protection Manual and procedures. In addition, sealed sources (with the exception of the startup source) containing a i sufficient quantity of radloactive material to creato a high radiation  :

area will be locked in a shield or in the shielded position when not in use.  !

When will beinposted use and and unattended locked. the rooms in which these sources are used i f. 3. 2.

12. 2- FACILITIES AND EQUIPMENT 1132.I

-12.4.2.1 Facilities t

The Radiochemistry lab has been constructed for ease of decontamination, os-p Amendment No. 5iS:- {

_y __..---2 , . _.-A.

t t

^R

_.._.2-

=.

l s

. s. .

^

.. . s The lab is designed.for the preparation and analysis of reactor coolant samples. There is a stair.less steel lined fume hood in the Radiochemistry Laboratory with a designed exhabst flow of 800 cfm. Two exhaust fans draw air from the fume hood, Radiochemistry Lab, Sample Room and Counting Room as well as other areas in the Auxiliary Building. One fan will start automatically if 'he other fan stops. If both fans fail, an alarm will sound in the Control Room. Drains from the fume hood and sinks are con-nected to the liquid vaste storage system provided in the plant. Additional information on labora .ory facilities is given in S4ction 21a.GI 11 3 . 1 . I .1 12r4v7el .-1 Present Facilities, Control and Use II.1. 2. 4

+ L (, e A - 4 A. At present so have two Cs-137 instrument calibration sources.

One source is 100 millicuries with permanent collimator and is electrically operated. A cart and track arrangement was built to make use of the inverse square law for obtaining the i desired exposure. The other source is a 50 Curie source.

This source has a self-contained exposure cavity with a lead glass viewing window and is mechanically interlocked to prevent personnel exposure during use. The desired exposure is obtained by placing lead attenuators in the beam, .

i Both sources are locked in the shielded position when not in use. <d5G2C These sources are used by and the storage areas controlled by Health Physics personnel. Whenever the sources are in use and unattended, the areas in which they are located are locked. When the 100 millicurie source is in use, the area is posted as a radiation area.

There are two rooms being used for instrument calibrations. One -

is located adjacent to the Unit 1 Health Physics office and the other is in the Unit 1 Turbine Building basement. D^ t ' r:;;; m s -

undr '!rl" D u h - t--i " - - T h d d.' g (3

, B.

There are two calibration sources used to check and calibrate the out of ccre detectors. One is a 4.71 Curie Pu-Be source and the other is a 500 millicurie Co-60 source. When not in use both sources are locked in their storage containers and the keys are controlled by Health Physics. Presently, Health Physics ,

personnel are present whenever the sources are handled. Inst rument Department personnel may handle the neutron source in the future after they are accustomed to the handling technique. Handling the tources requires the issuance of a Special Work Permit.

C.

Smaller check squpggs g;q used to check or calibrate some radiation instruments. W.f 70 microcurie Co-60 and a 39 millicurie Cs-137 source used to check the instaIIed radiation monitors. The beam is co111 mated and directed into a cylindrical cavity that fits down over the detector. This cavity acts as a beam stop. These sources are stored under ) alth physics control but may be used by other plant personnel in addi..on to Health Physics for checking area monitors.

(Personnel will be familiar with the use of the sources before they are allowed to handle them.)

-1:354EG.

Amendment No. er- {

ll-2 2-b  :--.; C - '"'

+

o . 3. 2 . s . 2.

12.4.2.1.2 Future Facilities, Control and Use A.

The 500 mi11icurie Co-60 scur'ce may be used as a calibration source for

!.3 W i--S--

portable instruments in the future. If so, it will be used in a suit-able configuration to limit personnel e::posure and will be used by llealth Physics personnel.

Il*3 2-(*I A B. The calibration sources described in 12.2.2.eri.4 above may be moved to Unit 2. If so, they will be in rooms or areas controlled by Health ig yua ( n Physics.

f l . 7, 2. 2.

1&*n%2 Portable Survey and Menitoring Instruments ll .*1. i *C Information on radiation survey instrumentation is given in Section 12 ~.2--3.

A description or portable survey and monitoring instruments and their use is given below. 'ihese instruments or their equivalent will be used.

RADIATION DETECTION INSTRUMEhTS Min. Window No. Radiation Sensitivity 'Ihickness Tvpc of Instrument Avlb.* Detected Range (mg/cm ) Use

1. Portable Gi Count 4 gar:ma, beta 0-280K cpm 30 or <2 Monitor- '

Rate (Batt) ing

2. Portable GM Survey 2 beta, gamma 0-1000 R/hr 30 Survey y 8

(Batt) 3 y. ,.

3. GI Monitoring 4 . alpha, beta 0-50K cpm 30 or <2-Monitor- .

Instrument (AC) gamma ing

4. Gas Flow Propor- 2 alpha, beta 0-500K cpm <2 Contamina-tional Survey tion Survey

. Meter (Batt) -

5. Portable Ionization 2 gamma, beta 0-500 R/hr <2 Survey Survey Meter (Batt)
6. Portable Ionization 2 beta, gamma 0-1000 R/hr 30 Survey  ;

Survey Meter (Batt) l

7. Portable Ionization 1 alpha, beta 0-300 mR/hr <2 Survey Survey Meter (Batt) gamma .
8. Portable BF l' fast neutron 0-500K cpm Survey Neutron Flux Survey slow neutron Meter (Batt)
9. BF3 Portable REN 1 neutron 0-500 cR/hr Survey Counter (Batt)
  • All for use in Units 1 and 2.

I N ;3- Auendment No. SD y.g 3:.; :?; 127',

~

lY . ,

~ l

n - 2. 2 '

12J.2.3 Portable Air Monitoring Equipment Portable air monitors consist of four air samplers that are capable of con-tinuously monitoring and recording particulate and gaseous activity. These monitors can be set to alarm on high particulate or gasecus activity. In addition, these monitors can be equipped with an iodine coIIection cartridge that can be counted in the laboratory. (Particulate and gaseous activities of 3 x 10 11 and 1 x 10-7 pCi/ce, respectively, can readily be detected in 49-s low background areas.

In higher background areas, particulate and gaseous iMG77 activities of 3 x 10-10 and 1 x 10-6 pCi/ce, respectively, can be detected.)

Tko portable air samplers are also available to obtain airborne grab samples for particulate, gaseous or iodine. (For normal sample and counting times ,

activities cf 2 x 10-10, 5 x 10-10 and S x 10-7 pCi/cc are readily detected for particulates, iodine and noble gases, respectively. By increasing collection and/or counting times lower levels of activity may be detected.)

n.:.4 4 12,4r2r4 Laboratory Counting Equipment Laboratory counting equipment includes internal gas flow proporational counter scalers, thin wir.dow GM counter scalers and gamma spectroscopy equipment.

l1. : . ? . :7 12.4.2.5 Installed Area Radiation Monitoring System os. *G .

The Area Radiation Monitoring System is described in Section 14:4:4 it. J. J . G 21 -

12,4rar6 Installed Process Radiation Monitoring System "

II. o . 3 . 4 .

The Process Radiation Monitoring System is described in Section lisa.

II . :.r . 7 12.4.2.7 Personnel Monitoring Devices i s . t . 9. l .

The personnel monitoring equipment is described in Section 12.3.3.1.

11. 5 1 14,4r3 PERSONNEL AND PROCEDURES

' n.! 3.] '

1-2 r4r3rrl Personnel The site Nucicar Engineer is designated as the Nuclear Materials Custodian and is responsible for the physical accountability of the special nuclear material and provides the storage, movement and loading sequences to mini-mise the handling of the fuel assemblies. The Supervisor of Plant Opera-tions is responsible for the safe movement and handling of fuel assemblics according to written plant procedures. Plant operations personnel trained in the use of fuel handling equipment aro used in moving the material and on-site Shift Operating Supervisors are responsible for fuel handling 39 operations of their shift.

g q ,i,3, -m , 1 . ' '

l Section -13.1.2l2,gives the description of the positions for the liealth Physics Supervisor and Radiochemis try Supervisor. The qualifications of the llealth Physics Supervisor and Radiochesistry Supervisor are given in SetTion--1 L I M ,, . ,

ih fr' < ~ E : x \,

Rrt:4-Amendment No. OF Juveisaq= ann

v' f.

. .. m '

3 -

a

/ / . 3.12 12.*.~.2 Procedures .

All new or temporary employees shall receive a radiation protection orien-l tation prior to their assignment of work in the Controlled Access Area.

'Ihe orientation will include instruction in the Radiation Protection Manual.

Visitors must be escorted within the Controlled Access Area or other radia-tion and/or contamination areas unless they have completed the required radiation protection orientation.

Radiological safety rules and guidelines are specified in the Arkansas Nuclear One Radiation Protection Manual and associated procedures. Instruc-tions contained in these procedures require that personnel:

1. Familiarize themselves with radiological safety practices and procedures;
2. Contact Health Physics for any additional radiological safety informa-tion they need;
3. Be signed in on a valid Radiation Work Permit (or Special Work Permit) before working with or around radiation or radioactive materials;
4. Be aware of proper procedures to follow in an emergency;
5. Protect themselves and others from overexposure to external radiation; 49.-
6. Minimize the uptake of radioactive materials; 3&B
7. Prevent the spread of contamination;
8. Wear assigned personnel monitoring equipment within the plant;
9. Follow requirements and instructions on radiation work permits;
10. Assure themselves that adequate monitoring has been performed prior to starting a job;
11. Notify Health Physics of malfunctioning of any radiation protection equipment.
12. Monitor themselves prior to leaving the Controlled Access or other contaminated areas;
13. Utilize time, distance and shiciding as practicable to minimize exposure;
14. Bag contaminated waste;
15. Maintain their exposure as low as practicable;

~-

16. Notify the Shift Operating Supervisor and Health Physics as soon as possible of incidents involving radiation or contamination.

m ir

'N Amendment No . W 11-14 6 Jn2^ - ""5 N

- . a

= * = .

q

. . . w.

Other general radiological safety rules are:

1. .Rere will be no eating, smoking, drinking or preparation of food or drink in contaminated areas.

2.

M 9="

No materials or equipment shall be removed from the Controlled Access -91 r8-or other contaninated areas unless released by Health Physics.

3. The limit for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per week exposure to unevaluated mhtures of beta-gamma ll . 3, <}-

emitting air particulate activity is 1 x 10-g pCi/ce.

IW REQUIRED MA16ttIALS At present there are no plans to have any radioactive materials onsite that exceed the limits specified below:

Material Form and Use Possession Limit A. Any byproduct, As reactor fuel; as sealed As required for source and special sources for reactor start up; reactor operation nuclear material as scaled sources for reactor instrument and radiation n - n ,1.-

monitoring equipment cali-bration; and as fission detectors P. Any byproduct, Any form for semple analysis 100 millicuries each

+>urce or special of instrument calibration

.uclear material isotope; any by- ~

product material re- t "' '

g,o ..r.: v' . w

,8100 milligrams each

/ isotope; any source

/ or special nuclear material I

\ #

\~ 2 C on,e: K R y,v. V- E -

n oa: re t... n : 7" e,vecmr v .revecc

~P'

// - <>... . . . . ,- s. c u se, ta s o( 8'n rca - E .S~ . , , < < gu ca .- 7 c r2c .: c <> r '< w ,.< : r . ...;. , ;-

,n , z,; . ; .,, . , ., ,. .

?'A '

/*ftlW7 N c, ;; ,)z.g ,j j ,- ,,, ,, _ ,

/.^- T' Si ' & ~ /t. z tc ; ,. . 3 ,*

_ * -s,,,,,,, ,

jp p o a t. ,s r(a '/ . .

d',' .

s.

. . . . ..**3'. .

' If lp ,) ,'

./ ,1 s'

, f .

M epprer smal* l f NY GN& &TrL E ww. f36 A f?fD Mu4eur'ieS, n Amendment No. &

M. _v . _ __ _-, -

.,,-e.

y ," ~ ~

. . . ./ e 7 -

.a =/=g a r A

~r ~~ __N. - - ~ ,. _. _, s _

'OACC<Du Rc'3 Jr/ N& 7 x e~ fu t'< HANo 4 sN $ c'QviPmcx7--> As a

MJ <P/ 43 4'd e,/ C c e7 o,s 9. 6 2.' 2 ,

J---N: crR T 4 TNa~ Et a n' CcA/n)"vsdG VAf TC Cunar Ca - ly 7 gauge ( ,,, v4,g 7df Ce N PACC <f 7"& /* NcAstw hwtroc ospac e ,

h l lf "

J t  !

  • an