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Category:SAFETY EVALUATION REPORT--LICENSING & RELATED ISSUES
MONTHYEARML20217K3301999-10-19019 October 1999 Safety Evaluation Supporting Amend 195 to License DPR-61 ML20206C8761999-04-28028 April 1999 Safety Evaluation Supporting Amend 194 to License DPR-61 ML20238F2131998-08-28028 August 1998 SER Accepting Defueled Emergency Plan for Emergency Planning for Connecticut Yankee Atomic Power Co ML20202D1621998-06-30030 June 1998 Safety Evaluation Supporting Amend 193 to License DPR-61 ML20217K2101998-03-27027 March 1998 Safety Evaluation Supporting Amend 192 to License DPR-61 ML20198M8101997-10-14014 October 1997 SER Accepting Proposed Revs to Util Quality Assurance Program at Facility ML20141K4201997-05-22022 May 1997 Safety Evaluation Supporting Amend 191 to License DPR-61 ML20058F1151993-11-23023 November 1993 Safety Evaluation Supporting Amends 170,69,169 & 86 to Licenses DPR-61,DPR-21,DPR-65 & NPF-49,respectively ML20059G6411993-11-0101 November 1993 Safety Evaluation Supporting Amend 169 to License DPR-61 ML20059G5261993-10-27027 October 1993 Safety Evaluation Supporting Amend 168 to License DPR-61 ML20057E2011993-10-0404 October 1993 Safety Evaluation Supporting Amend 167 to License DPR-61 ML20057E1921993-10-0404 October 1993 Safety Evaluation Supporting Amend 166 to License DPR-61 ML20058M9051993-09-29029 September 1993 Safety Evaluation Supporting Amend 165 to License DPR-61 ML20058M9291993-09-29029 September 1993 SE Re SEP Topics III-2 & III-4.A, Wind & Tornado Loadings & Tornado Missiles. Licensee Estimated Reactor Core Damage Frequency Reduced Signficantly Such That Likelihood of Core Damage Reasonably Low ML20057A3501993-09-0202 September 1993 Safety Evaluation Supporting Amend 164 to License DPR-61 ML20057A3551993-09-0202 September 1993 Safety Evaluation Supporting Amend 163 to License DPR-61 ML20056G2891993-08-25025 August 1993 Safety Evaluation Supporting Amend 162 to License DPR-61 ML20056D7061993-07-26026 July 1993 Safety Evaluation on SEP VI-4 Re Containment Isolation Sys for Plant.All Penetrations Either Meet Provisions of or Intent of GDCs 54-57 Except for Penetration 39 ML20128E3291993-02-0404 February 1993 Safety Evaluation Granting Util Request for Authorization to Use Portion of Section XI of 1986 Edition of ASME Code for Visual Exams VT-3 & VT-4 to Be Combined Into Single VT-3 ML20128D5231992-11-25025 November 1992 Safety Evaluation Accepting 120-day Response to Suppl 1 to Generic Ltr 87-02, Verification of Seismic Adequacy of Mechanical & Electrical Equipment in Operating Reactors,Usi A-46, ML20210E1891992-06-12012 June 1992 Safety Evaluation Considers SEP Topic III-5.B to Be Complete in That If Pipe Breaks Outside Containment,Plant Can Safely Shut Down W/O Loss of Containment Integrity ML20062B7411990-10-22022 October 1990 Safety Evaluation Supporting Amend 132 to License DPR-61 ML20059H3101990-09-0606 September 1990 Revised Safety Evaluation Clarifying Individual Rod Position Indication Testing Exception & Bases for Approving Test Exception ML20059A8021990-08-14014 August 1990 Supplemental Safety Evaluation Accepting Electrical Design of New Switchgear Room at Plant ML20056A5641990-08-0303 August 1990 Safety Evaluation Concluding That Pressurizer Has Sufficient Fracture Toughness to Preclude Fracture of Head W/Flaws Remaining in Component & Pressurizer Acceptable for Continued Svc ML20055G5441990-07-19019 July 1990 Safety Evaluation Supporting Amend 128 to License DPR-61 ML20055G5561990-07-19019 July 1990 Safety Evaluation Supporting Amend 129 to License DPR-61 ML20055E2361990-07-0202 July 1990 Safety Evaluation Supporting Amend 126 to License DPR-61 ML20247K2531989-09-11011 September 1989 Safety Evaluation Supporting Amends 123 & 41 to Licenses DPR-61 & NPF-49,respectively ML20247E3761989-09-0707 September 1989 Safety Evaluation Supporting Amends 122,34,143 & 40 to Licenses DPR-61,DPR-21,DPR-65 & NPF-49,respectively ML20247A4841989-09-0505 September 1989 Safety Evaluation Supporting Amend 121 to License DPR-61 ML20245J0121989-08-14014 August 1989 Safety Evaluation Accepting Extension of Surveillance Intervals ML20247E6551989-07-20020 July 1989 Safety Evaluation Supporting Amend 120 to License DPR-61 ML20247E6841989-07-18018 July 1989 Safety Evaluation Supporting Amend 119 to License DPR-61 ML20246L2571989-06-26026 June 1989 Safety Evaluation Supporting Amends 118,33,142 & 36 to Licenses DPR-61,DPR-21,DPR-65 & NPF-49,respectively ML20246A8541989-06-23023 June 1989 Safety Evaluation Concluding That Large Containment at Plant Results in Slow Hydrogen Accumulation Rate & Ensures That Sufficient Time Available to Implement Addl Hydrogen Control Features After Accident.Requirements of 10CFR50.44 Met ML20244C4451989-06-0101 June 1989 Safety Evaluation Supporting Amend 117 to License DPR-61 ML20248B3001989-05-31031 May 1989 Safety Evaluation Supporting Amend 116 to License DPR-61 ML20245J0751989-04-25025 April 1989 Safety Evaluation Supporting Amends 114,30,141 & 33 to Licenses DPR-61,DPR-21,DPR-65 & NPF-49,respectively ML20245E8941989-04-21021 April 1989 Safeguards Evaluation Rept Supporting Amend 113 to License DPR-61 ML20235Z0881989-03-0707 March 1989 Safety Evaluation Supporting Amend 112 to License DPR-61 ML20196D8641988-12-0606 December 1988 Safety Evaluation Supporting Amend 109 to License DPR-61 ML20205M5731988-10-26026 October 1988 Safety Evaluation Supporting Amends 108,25,134 & 26 to Licenses DPR-61,DPR-21,DPR-65 & NPF-49,respectively ML20204G8641988-10-18018 October 1988 Safety Evaluation Supporting Licensee Analysis of Consequences of Steam Generator Tube Rupture Accident at Facility Followed by Minimization of Water in Affected Steam Generator After Tube Rupture ML20155G4801988-09-28028 September 1988 Safety Evaluation Supporting Amends 107,23,132 & 24 to Licenses DPR-61,DPR-21,DPR-65 & NPF-24,respectively ML20151T7641988-08-0909 August 1988 Safety Evaluation Supporting Amend 106 to License DPR-61 ML20150A9551988-07-0101 July 1988 Safety Evaluation Supporting Amend 105 to License DPR-61 ML20155F9811988-06-0101 June 1988 Safety Evaluation Supporting Amend 104 to License DPR-13 ML20155G5031988-05-26026 May 1988 Safety Evaluation Supporting Amend 103 to License DPR-61 ML20153G9671988-04-28028 April 1988 Corrected Safety Evaluation Supporting Amend 97 to License DPR-61 1999-04-28
[Table view] Category:TEXT-SAFETY REPORT
MONTHYEARML20217K3301999-10-19019 October 1999 Safety Evaluation Supporting Amend 195 to License DPR-61 ML20206C8761999-04-28028 April 1999 Safety Evaluation Supporting Amend 194 to License DPR-61 CY-99-047, Ro:On 981217,identified Unsuccessful Dewatering of Cnsi HIC, Model PL8-120R,containing Resins.Caused by Apparent Failure of Dewatering Tree.Other HICs Have Been Procured,Recertified & Returned to Plant for Use1999-03-23023 March 1999 Ro:On 981217,identified Unsuccessful Dewatering of Cnsi HIC, Model PL8-120R,containing Resins.Caused by Apparent Failure of Dewatering Tree.Other HICs Have Been Procured,Recertified & Returned to Plant for Use ML20206F1971998-12-31031 December 1998 Annual Rept for 1998 for Cyap. with CY-99-027, Annual Rept for 10CFR50.59, for Jan-Dec 1998.With1998-12-31031 December 1998 Annual Rept for 10CFR50.59, for Jan-Dec 1998.With ML20198G9101998-12-22022 December 1998 Proposed Rev 2 of Cyap QAP for Haddam Neck Plant. Marked Up Rev 1 Included ML20238F2131998-08-28028 August 1998 SER Accepting Defueled Emergency Plan for Emergency Planning for Connecticut Yankee Atomic Power Co CY-98-136, Ro:On 980727,flow Blockage Occurred & Caused Pressure in Sys to Increase,Resulting in Relief Valve Lifting & Pipe Vibration,Which Caused Leaks to Develop.Caused by Nearly Closed post-filter Inlet Valve.Repaired 2 Leaks in Line1998-08-12012 August 1998 Ro:On 980727,flow Blockage Occurred & Caused Pressure in Sys to Increase,Resulting in Relief Valve Lifting & Pipe Vibration,Which Caused Leaks to Develop.Caused by Nearly Closed post-filter Inlet Valve.Repaired 2 Leaks in Line ML20237B7461998-07-22022 July 1998 1998 Defueled Emergency Plan Exercise Scenario Manual, Conducted on 980722 ML20202D1621998-06-30030 June 1998 Safety Evaluation Supporting Amend 193 to License DPR-61 CY-98-068, Follow-up to Verbal Notification on 980413 of Film on Discharge Canal.Investigation Continuing.Samples Collected for Petroleum Analyses & Biological Characterization at Intake Structure & Discharge Canal.Replaced Sorbent Booms1998-04-15015 April 1998 Follow-up to Verbal Notification on 980413 of Film on Discharge Canal.Investigation Continuing.Samples Collected for Petroleum Analyses & Biological Characterization at Intake Structure & Discharge Canal.Replaced Sorbent Booms CY-98-045, Ro:On 980212,0219,0225 & 0312,separate Sheens of Approx One Cup of oil-like Substance Was Observed at Discharge Canal. Cause Has Not Been Clearly Identified.Called in Vendor Spill to Install Sorbent Booms to Absorb Sheen.W/One Drawing1998-04-13013 April 1998 Ro:On 980212,0219,0225 & 0312,separate Sheens of Approx One Cup of oil-like Substance Was Observed at Discharge Canal. Cause Has Not Been Clearly Identified.Called in Vendor Spill to Install Sorbent Booms to Absorb Sheen.W/One Drawing ML20217F0611998-03-31031 March 1998 Historical Review Team Rept ML20217A0001998-03-31031 March 1998 Monthly Operating Rept for Mar 1998 for Haddam Neck Plant ML20217K2101998-03-27027 March 1998 Safety Evaluation Supporting Amend 192 to License DPR-61 CY-98-046, Follow-up to 980311 Verbal Notification of Film on Discharge Canal.Cause Not Yet Determined.Film Is Contained & Will Be Absorbed by Containment & Sorbent Booms That Were in Place in Discharge Canal1998-03-12012 March 1998 Follow-up to 980311 Verbal Notification of Film on Discharge Canal.Cause Not Yet Determined.Film Is Contained & Will Be Absorbed by Containment & Sorbent Booms That Were in Place in Discharge Canal ML20216D6531998-02-28028 February 1998 Monthly Operating Rept for Feb 1998 for Haddam Neck Plant ML20217D7381998-02-28028 February 1998 Revised MOR for Feb 1998 Haddam Neck Plant CY-98-012, Monthly Operating Rept for Jan 1998 for Connecticut Yankee Haddam Neck Plant1998-01-31031 January 1998 Monthly Operating Rept for Jan 1998 for Connecticut Yankee Haddam Neck Plant CY-98-010, Annual Rept for 10CFR50.59,Jan-Dec,19971997-12-31031 December 1997 Annual Rept for 10CFR50.59,Jan-Dec,1997 ML20198N6681997-12-31031 December 1997 Monthly Operating Rept for Dec 1997 for Haddam Neck Plant ML20217P4861997-12-31031 December 1997 1997 Annual Financial Rept, for Cyap ML20199L5891997-12-24024 December 1997 Independent Analysis & Evaluation of AM-241 & Transuranics & Subsequent Dose to Two Male Workers at Connecticut Yankee Atomic Power Plant ML20203K4271997-11-30030 November 1997 Monthly Operating Rept for Nov 1997 for Haddam Neck Plant ML20199B1141997-10-31031 October 1997 Monthly Operating Rept for Oct 1997 for Haddam Neck Plant ML20198M8101997-10-14014 October 1997 SER Accepting Proposed Revs to Util Quality Assurance Program at Facility ML20198J8811997-09-30030 September 1997 Monthly Operating Rept for Sept 1997 for Haddam Neck Plant ML20210P8721997-08-31031 August 1997 Post Decommissioning Activities Rept, for Aug 1997 ML20217Q3171997-08-31031 August 1997 Addl Changes to Proposed Rev 1 to QA Program ML20210U9301997-08-31031 August 1997 Monthly Operating Rept for Aug 1997 for Haddam Neck Plant CY-97-082, Special Rept:On 970708,routine Surveillance Testing of Seismic Monitoring Sys Instrumentation Revealed,Data Was Not Being Reproduced by Portion of Playback Sys.Station Presently Pursuing Replacement of Seismic Monitoring Sys1997-08-14014 August 1997 Special Rept:On 970708,routine Surveillance Testing of Seismic Monitoring Sys Instrumentation Revealed,Data Was Not Being Reproduced by Portion of Playback Sys.Station Presently Pursuing Replacement of Seismic Monitoring Sys ML20210L0521997-07-31031 July 1997 Monthly Operating Rept for July 1997 for HNP ML20149E4451997-06-30030 June 1997 Monthly Operating Rept for June 1997 for Haddam Neck Plant ML20141A0041997-05-31031 May 1997 Independent Assessment of Radiological Controls Program at Cyap Haddam Neck Plant Final Rept May 1997 ML20140H5241997-05-31031 May 1997 Monthly Operating Rept for May 1997 for Haddam Neck Plant ML20141K4201997-05-22022 May 1997 Safety Evaluation Supporting Amend 191 to License DPR-61 ML20141D4141997-04-30030 April 1997 Monthly Operating Rept for Apr 1997 for Connecticut Yankee Haddam Neck ML20138G5901997-04-25025 April 1997 Proposed Rev 1 to Cyap QA Program for Haddam Neck Plant ML20137W8051997-03-31031 March 1997 Monthly Operating Rept for Mar 1997 for Haddam Neck Plant ML20137H3031997-03-31031 March 1997 Rev 2 to Nuclear Training Loit/Lout Audit Reviews ML20137C6281997-03-14014 March 1997 Redacted Version of Rev 1 to Nuclear Training Loit/Lout Audit Reviews ML20137A0801997-02-28028 February 1997 Monthly Operating Rept for Feb 1997 for Haddam Neck Plant ML20135C5101997-02-26026 February 1997 1996 Refuel Outage ISI Summary Rept for CT Yankee Atomic Power Co B16268, Special Rept:On 970205,declared Main Stack-Wide Range Noble Gas Monitor Inoperable.Caused by Inadequate Calibr Methods. Will Revise Calibr Procedure to Technique to Demonstrate Accuracy & Linearity Over Intended Range of Monitor1997-02-19019 February 1997 Special Rept:On 970205,declared Main Stack-Wide Range Noble Gas Monitor Inoperable.Caused by Inadequate Calibr Methods. Will Revise Calibr Procedure to Technique to Demonstrate Accuracy & Linearity Over Intended Range of Monitor ML20135E3221997-02-13013 February 1997 Independent Review Team Rept 1996 MP -1 Lout NRC Exam Failures ML20134L2751997-02-0303 February 1997 Draft Rev to GPRI-30, Spent Fuel Storage Facility Licensing Basis/Design Basis ML20138K5721997-01-31031 January 1997 Monthly Operating Rept for Jan 1997 for Haddam Neck Plant.W/ ML20134L2791997-01-10010 January 1997 Rev 0 to QA Program Grpi ML20134L2911997-01-0808 January 1997 Rev 0 to UFSAR Rev Grpi ML20134L2721996-12-31031 December 1996 Commitment Mgt Grpi 1999-04-28
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- o,, UNITED STATES
!. a NUCLEAR REGULATORY COMMISSION
- 7. j WASHINGTON D C 20656
's,...../'SAFETYEVALUATIONBY_THEOFFICEOFNUCLEARREACTORREGULATIO RELAT,Ep,_TOAMENDMENTNO.106 TO FACILITY OPERATING LICENSE NO. DPR-61 C0hhECTICUT YAhkEE ATOMIC POWER COMPANY HADOAM NECK PLANT DOCKET NO. 50-213
- 1. BACKGROUND The Connecticut Yankee Atomic Power Company (CYAPCO), the licensee, and the staff have discussed the issue of environmental qualification of certain equipment and the mitigation of high energy line break (HELB) accidentsoutsidecontainment(Reference 1). Pursuant to 10 CFR 50.90 the licensee proposed to amend the Operating License by incorporating changes into the plant Technical Specifici; ions (Reference 2). The proposed change revises Technical Specification 4.12, High Energy Piping System, by expand-ing the augmented inservice inspection (ISI) program to include break locations on steam supply lines to the auxiliary feedwater (AFW) pumps.
The licensee provided changes to and clarifying information in Reference 3.
The staff concluded in Referente 1 that the proposed augmented inservice inspection for the auxiliary steam supply lines would meet all applicable regulatory criteria and would resolve all staff concerns associated with environment qualification and HELB issues for the Haddam Neck Plant. The staff also concluded that implementation of the updated program would pro-vide reasonable assurance of the continued integrity of the high energy piping and breaks need not be postulated at the monitored locations as part of HELB licensing basis. The objective of this Safety Evaluation is to review the Referenced submittals provided by CYAPCO.
!!. SUMARY OF INFORMATION The licensee fonaalized the conceptual resolution with the subject proposed license amendment. The AFV pump steam supply piping contains 47 welds based p PDC
i on a walkdown of the piping with the insulation removed during the 1987 refueling outage. The licensee provided an updated drawing showing these additional welds, A revised table describes the location, piping configur-ation, nominal size and method of inspection of welds included in the aug-mented ISI program. Based on the examination results from the 1987 refueling outage the licensee provided the following clarifications:
- 1) First Ten Year Inspection Program.
The Hadd0m Neck Technical Specification Section 4.12, which governs the augmented ISI program, specifically requires nondestructive exami-nation (NDE) of the subject piping during every 31/3 year period for the first 10-year interval. This is consistent with tr,e previously approved augmented ISI program governing the main steam and feedwater piping. The Haddam Neck ISI work plan has been modified to reflect this requirement.
- 2) Type of Inspection --Volumetric and Surface.
L The augmented ISI program for high energy piping systems is being performed in accordance with ASME SJction XI requirements, which defines NDE techniques, examination requirements, and acceptance criteria for each item being inspected. Under the requirements of ASME Section XI, Class 2 piping that is less than or equal to 1/2 inch nominal wall thickness only requires a surface examination. The augmented inspection program for the main steam drain (MSD) system requires that a volumetric and surface examination be performed where practical /possible. The NSD system piping is all less than 1/2 inch nominal thickness and a surface examination would fulfill the require-ments of Section XI. However, a volumetric (ultrasonic) examination is !
being performed as a best effort examination in order to increase the level of confidence in the integrity of the piping. This is being done in spite of the piping sizes, gecmetric configuration of the ,
welds, and the as-welded surface conditions. !
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-3 A surface examination was performed on each of the 47 welds. An attempt was also made to perform a full volumetric ultrasonic examination on each of the welds. However, the ultrasonic examination could not be performed on two of the welds (#28 and #47) which have geometric con-figurations which physically prevent an ultrasonic examination. A circumferential scan was performed on only five (5) welds of the re-maining welds because the small pipe radius causes the transducer to lift off the surface. Each of the 45 welds received an axial scan to identify circumferential indications. The scans were limited to the pipe side of the welds in most instances and the extrados of the elbow.
A 45" skewing technique was used to identify axial indications and replaced the circumferential scan which is difficult to perform on small-bore piping.
ASME Section XI requires that the ultrasonic technique examine the lower 1/3 of the weld and its heat affected zone (HAZ). The techni-ques used for the MSD piping examined the entire weld volume and its HAZ. Also, to increase the scanning sensitivity, the calibration technique uses a 1/32 inch side drilled hole reflector versus the ASME 5ection XI required 10 percent of the thickness notch reflector.
The ultrasonic examination performed on the MSD piping goes beyond the ASME Section XI requirements and a level of confidence of dpproxi-mately 90 percent has been achieved to ensure the piping structural integrity.
Monthly Inspection The license amendment requires a monthly visual examination of each weld. CYAPCO plans to walk down the piping without removing the lagging to perform the monthly visual examination. This piping con-sists of 3" and 4" piping which taps off the 24" mair steam lines and provides steam to the Terry turbines which in turn drive the AFW pumps.
An augmented ISI program already exists as a method of precluding the postulation of a rupture in the 24" main steam lines and the 12" feed-
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water lines. The proposed inclusion of this small bore piping does not change the method of inspection which has been in effect for the past ten years.
The main steam lines, as well as the subject small-bore piping, are maintained at a temperature of 500*F and a pressure of 900 psig when in operation. Under these conditions, a leak in the piping will become obvious, despite the fact that the insulation will remain on the piping.
Steam or dripping water will be noted by the operators during the visual inspections inside the Terry Turbine Building once per shift as part of the normal plant walkdowns.
III. STAFF EVALUATION The staff has reviewed the information in the Referenced documents. The existing augmented ISI program applies to certain welds in the main steam and feedwater systems. The proposed additional weld locations are contained in 26", 3" and 4" pipe systems with nominal wall thicknesses of .276",
.300" and .337", respectively. The licensee has attempted a full volumetric ultrasonic examination on each weld in the program and has identified the limitations to examination resulting from the existing design, geometry and materials of construction. The geometric condition prevented an ultra-sonic examination of two welds: #28, a pipe to flange weld and #47, a reducer to valve weld. The volumetric examination of other welds could be performed only from the pipe side of welds to fittings. The as-welded profile of most of the welds precludes effective examination from the weld crown for reflectors transverse to the weld. A 45' skewing technique was substituted for the detection of axial reflectors.
5-The objective of the proposed revision to Technical Specification 4.12 is to provide assurance of the continued integrity of the rain steam, feedwater, and steam supply to auxiliary feedwater system piping welds, identified in Tables 4.12-1 and 4.12-P. The staff has detemined that the limitations to inspection reported by the licensee are typical of constraints to ultrasonic e> amination of spall dianeter, thin-walled piping systems. Since the Haddam Peck Plant was built prior to adoption of ASPE Section XI, complete acces-sibility for inspection was not provided during the original plant design to the extent required by the current Code. The basis for Technical Specifica-tien 4.12 is that inspecticns will be conducted to the extent practical within the liniitations of design, geonetry and naterials of construction of the components. The staff finds that proposed augmented ISI program on the steam supply lires to the auxiliary feedwater pumps will exceed the extent and frequency of exan:inations required for these welds by the current edition of ASPE Section XI. The staff finds that the proposed addition of welds represents a program that is equivalent or superior to the existing augmented inservice inspection program. Based on the above, the staff concludes that the implenentation of the augrented ISI for the AFW piping will provide reasonable assurance of continued integrity of the AFW high energy piping.
Therefore, because breaks in the AFW piping at the monitored locations no longer need to be postulated, all issues regarding environnental qualifica-tion of certain equipment affected by AFW line breaks ud the mitigation of HELB accidents outside containnent are resolved.
IV. ENVIRChPENTAL CONSIDERATION This amendnent changes a requirenant with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The staff has detemined that the anendment involves no significant increase in the arounts, and no significant change in the types, of any effluents that inay be released offsite, and that there is no significant increase in individual or curulative occupational radiation exposure. The Conrissien has previously published a proposed finding that the anendnent involves no significant hazards consideration and there has l
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been no public comment on such finding. Accordingly, the amendoent meets the eligibility criteria for categorical exclusion set forth in 10 CFR 651.22(c)(9). Pursuant to 10 CFR 651.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
V. CONCLUSION We have concluded, based un the considerations discussed above, that (1) there is reasonable assurance that the health end safety of the public will not be endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Commission's regulations, and the issuance of the amendment will not be inimical to the commun defense and security or to the health and safety of the public.
4 Dated: August 9, 1988 '
Principal Contributor: M. Hum I
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