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Home My WebLink AboutBPMC Meeting - February 28, 1992 11. > FILE COPY ELT Ti — es BRADLEY LAKE PROJECT MANAGEMENT COMMITTEE February 28, 1992 CALL TO ORDER In the absence of Chairman Kelly, Dave Highers called the Bradley Lake Project Management Committee meeting to order at 10:35 a.m. in the Training Room of Chugach Electric Association, Anchorage, Alaska to conduct the business of the Committee per the agenda and the public notice. ROLL CALL Alaska Energy Authority Charlie Bussell, Designated Representative Chugach Electric Association David L. Highers, Designated Representative Golden Valley Electric Association Mike Kelly, Designated Representative and Chairman (Note: Mr. Kelly joined the meeting at 10:55 a.m.) City of Seward Paul Diener, Designated Representative Homer Electric Association Norman L. Story, Designated Representative Matanuska Electric Association Ken Ritchey, Designated Representative Municipal Light and Power Hank Nikkels, Alternate Representative Others Present: Ron Saxton, Ater, Wynne, Hewitt, Dodson & Skerrit Myles C. Yerkes, Homer Electric Association Dave Fair, Homer Electric Association Dave Calvert, City of Seward David Burlingame, Chugach Electric Association John Cooley, Chugach Electric Association Tom Lovas, Chugach Electric Association Bradley Evans, Chugach Electric Association BPMC Meeting Minutes February 28, 1992 Page 2 of 6 Joe Griffith, Chugach Electric Association Bob Hufman, AEG&T Bob Price, Municipal Light and Power Tim McConnell, Municipal Light and Power Moe Aslam, Municipal Light and Power Brent N. Petrie, Alaska Energy Authority Stanley E. Sieczkowski, Alaska Energy Authority David R. Eberle, Alaska Energy Authority Denise Burger, Alaska Energy Authority PUBLIC COMMENT There being no public comment, the meeting continued to the next agenda item. AGENDA COMMENTS The meeting agenda was approved without comment or objection. APPROVAL OF MINUTES The minutes of the January 13, 1992 meeting were approved as submitted, without comment or objection. TECHNICAL COORDINATION SUBCOMMITTEE REPORT Dave Burlingame distributed minutes of the February 20, 1992 Technical Coordination Subcommittee (TCS) meeting (Attachment 1). Mr. Burlingame reported that the SVC contract is proceeding on schedule and expected to be ready for on-line testing November 1992 and commercial operation March 1993. Mr. Burlingame stated that, currently, the Bradley Lake Project is running at 90 megawatts. AEA and Stone & Webster Corporation (SWEC) are investigating potential concrete/rock damage and believe any damage to be minimal. Bradley Lake will continue to operate until the planned shutdown for tunnel de-watering March 25, 1992. Dispatcher guidelines are expected to be ready for approval at the next BPMC meeting. Reporting on the microwave upgrade, Mr. Burlingame stated Alascom (among other telephone utilities) has been successfully lobbying to block state funding for the needed upgrade. AEA and the TCS recommended the utility managers help to "undo" the lobbying efforts of the telephone utilities. Mr. Burlingame reported results of the Fuji exciter tests performed February 24, 1992 indicate the problem was not the Fuji exciter. Testing demonstrated that the instrument used to measure the response of the exciter (Digital System Monitor or DSM) was the x BPMC Meeting Minutes February 28, 1992 Page 3 of 6 problem. Additionally, the finding suggests that the utility models are wrong. The impact of the model corrections is currently being evaluated by PTI. In response to inquiry by Mr. Highers, Mr. Burlingame stated right-of-entry agreements needed to be completed with HEA and CEA in order to proceed with SVC contract work (scheduled to commence March 16, 1991). Mr. Bussell noted that, barring any delay by the utilities, the agreements should be completed and signed by Friday, March 6, 1992. INSURANCE SUBCOMMITTEE REPORT Mr. Petrie reported that the insurance costs for this year were approximately $119,000.00 less than budgeted. This amount will be carried over to next year's budget. BUDGET SUBCOMMITTEE REPORT Mr. Ritchey distributed copies of the Bradley Lake FY93 Draft (Operating) Budget (Attachment 2). Mr. Ritchey noted the bottom line amount of the FY93 draft budget, $2,672,143.00 compares closely to the FY92 budget of $2, 207,000.00, particularly when taking into account the FY92 budget was for a ten (not twelve) month period. Disagreement continues within the budget subcommittee on the item of AEA Administration Expenses ($423,226.00). Further discussion on this issue is planned. The budget subcommittee expects to have a budget proposal ready for adoption at the March BPMC meeting. Mr. Ritchey stated that preliminary cash flow estimates based on the draft FY93 budget amount would be $1,174,000.00 monthly (all utilities combined), a decrease of approximately $100,000.00 over last year. Less than anticipated FY92 expenditures and plans to reduce the operating reserve account to 20% were reasons sited for the decrease. OPERATION AND DISPATCH SUBCOMMITTEE REPORT Mr. Sieczkowski reviewed the status of operating agreements: Allocation and Scheduling Agreement: Exhibit A has been recommended for approval. Copies will be provided at the next BPMC meeting. Dispatch Agreement: Sent out for signatures. Transmission Maintenance Agreement: Draft will be forwarded to HEA by March 4, 1992. Facilities Interconnected Agreement: Draft will be forwarded to HEA and CEA by March 4, 1992. BPMC Meeting Minutes February 28, 1992 Page 4 of 6 10. SVCS Daves Creek and Soldotna Agreement: Draft will be forwarded this week. Mr. Sieczkowski reported the Operations and Dispatch (O&D) Subcommittee meeting was held January 28, 1992. Representatives of the National Weather Service demonstrated their program at the meeting. Mr. Sieczkowski stated AEA will place into service the necessary communications equipment to utilize Weather Service sites (to aid in allocation). Other communication issues discussed at the meeting included affirmation of the need to continue working with the Division of Information Services to obtain approval for the microwave system, and the approval of the Reservoir Model. The approved Reservoir Model will be presented at the next BPMC meeting. In response to inquiry by Mr. Evans, Mr. Sieczkowski stated that proposed test charges had been sent out to the utilities for comment. Comments received by AEA will be discussed at the next O&D Subcommittee meeting. Mr. Evans expressed concern over the Bradley Lake communication and remote site data collection system. Mr. Evans stated that, under the current conditions, the Riverflow Forecast Model could only provide a crude estimation of project capabilities, thereby diminishing the effective use of the Reservoir Model. Mr. Sieczkowski noted AEA was aware of the need to provide the most current and reliable information to the utilities, resulting in AEA's purchase and installation of the new communications equipment. Dave Eberle further explained that the equipment was available, however, after its installation, another system came on line at Susitna with the same frequency, directly interfering with the Bradley radio system. Replacement of the radios at Bradley is the only solution to this problem and is expected to be completed by this summer. Mr. Eberle, referring back to the upgrade of the microwave system, requested the utilities contact Legislative Budget & Audit (LB&A) Committee members to support completion of the state's microwave. The alternative ( funding of a second microwave system by the utilities) would result in greater costs to the electric utilities and consumers. REVIEW OF PROJECT STATUS Mr. Eberle reported that all construction contracts have been closed-out with the exception of Enserch and Bechtel. Enserch, notified that the concrete/rock debris in the tunnel may be a potential warranty problem, will participate in the inspection of the tunnel. Bechtel will be available to assist with contract issues, if additional work is required by Enserch after tunnel inspection. On a trial basis, AEA and the utilities agreed to increase Bradley output from 65 megawatts to 90 megawatts. After an uneventful test run at 90 megawatts and subsequent inspection mid-February, it was determined to continue operating at the 90 megawatt output level. Mr. Eberle outlined the de-watering schedule. Plant shutdown will occur March 25, 1992. De-watering is estimated to take five to six days permitting a preliminary inspection about March 31, 1992. Assuming the initial inspection through the penstock shows a substantial BPMC Meeting Minutes February 28, 1992 Page 5 of 6 accumulation of material, the head cover will be removed to allow vehicle access into the tunnel for a complete inspection. Allowing most of April for any clean up or repairs and re-watering of the tunnel, Bradley Lake is expected back on line around April 27, 1992. However, if major problems are identified within the tunnel during inspection, decisions to determine the best procedure (i.e. close tunnel and repair at a later date, or repair immediately and delay going back on line) will be made at that time. Mr. Eberle noted that construction of the Soldotna substation transmission line will take place this summer, as originally planned. Other options being discussed with HEA and ABB were dropped. 11. OLD BUSINESS A. ADOPTION OF THE BRADLEY LAKE DISPATCHER GUIDELINES SUMMARY As previously noted under item 6, Dispatcher Guidelines will be ready for consideration at the next BPMC meeting. PROPOSED MOTION REGARDING RISK/BENEFIT ANALYSIS Mr. McConnell distributed a memorandum stating the phrasing and intended purpose of the proposed motion (Attachment 3). After some discussion, it was generally agreed that the concept of the motion was good and should be incorporated into BPMC guidelines, however no formal motion was necessary. Mr. Highers added clarification, stating the new guideline would refer mainly to defining (assessing) the impact of technical issues rather than all issues brought before the BPMC for consideration. 12. NEW BUSINESS A. APPROVAL OF COMMITTEE EXPENSES Mr. Saxton noted that new Section 31 costs had been submitted for reimbursement since the last BPMC meeting, however only those brought before the January 13, 1992 BPMC meeting for approval would be considered today. Mr. Petrie distributed copies of the Section 31 costs (Attachment 4) noting that the zero dollar amount listed under ML&P should have instead been listed under MEA. Mr. Kelly motioned, seconded by Mr. Ritchey, the BPMC approve reimbursement of the Section 31 costs as corrected. The motion was unanimously approved by roll call vote. INCREASE BRADLEY OUTPUT LIMIT TO 90 MEGAWATTS Mr. Kelly recommended changes in the Bradley output level be approved by the BPMC. _Mr. Kelly motioned, seconded by Mr. Ritchey, the BPM approve an interim 90 megawatt Bradley output subject to Kenai export limits BPMC Meeting Minutes February 28, 1992 Page 6 of 6 13. 1 defined by the TCS meeting of February 20, 1992.! After discussion of appropriate phrasing the motion passed by unanimous roll call vote. In response to inquiry by Mr. Kelly, Mr. Saxton confirmed that approval of future changes to the Bradley output level could be made by polling BPMC members and did not have to wait for a formal meeting. MODIFICATION OF BRADLEY MINIMUM OPERATING LEVELS Mr. Story requested this issue be set aside for 30 to 60 days to allow HEA additional time to complete studies and discussions. Noting HEA has been experiencing a heavy workload, Mr. Story assured the BPMC HEA was anxious to settle this issue. Mr. Kelly motioned to table modification of the Bradley minimum operating level until the April BPMC meeting. Seconded by Mr. Story, the motion passed by unanimous roll call vote. SPINNING RESERVES/UNDERFREQUENCY LOAD SHEDDING - UPDATE Mr. Lovas stated the Reliability Criteria Committee of the Alaska Systems Coordinating Council (ASCC) was tasked to undertake the development of railbelt interconnected utility operating reserve criteria. The Reliability Criteria Committee will meet March 5, 1992 to establish a timetable/plan for development of this criteria. It is anticipated that the ASCC will be able to make reliability criteria recommendations to the BPMC this fall (1992). HEA BRADLEY ECONOMY SALES TO GVEA - UPDATE Mr. Kelly stated there was nothing to report at this time. GVEA, HEA, and CEA have met and discussed various proposals and expect to meet again prior to the next BPMC meeting. COMMUNICATIONS A. SCHEDULE NEXT MEETING March 26, 1992 (Thursday) 10:00 a.m. CEA Training Room Mr. Kelly reintroduced discussion on utility action in support of state funding for the microwave system upgrade, suggesting AEA draft a letter for utility signature. Mr. Kelly recommended the BPMC send one letter (signed by all the utility managers) to "Move to set the Kenai export limit to 31 MW with only Bradley Lake generation on-line or to 47 MW with Bradley and Cooper Lake until PTI completes a study with Bradley Lake at 90 MW with 45 MW HEA load, 5 MW Seward load. After completion of the study, the TCS will review the results and determine if the overvoltages are acceptable. In all other generation cases, Bradley Lake is limited to 90 MW." TCS meeting February 20, 1992. BPMC Meeting Minutes February 28, 1992 Page 7 of 6 the Legislative Budget & Audit Committee (Representative Ron Larson, Chairman) and that each utility send an additional follow up letter. 14, ADJOURNMENT There being no further business, the committee adjourned at 12:10 p.m. Th Mike Kelly, Chai Attest: Charlie Bussell, Secretary 02/27/92 09:28 9075620027 CHUGACH ELEC Peo ALBLA Qoo2/004 ATTACHMENT NO. 1 CHUGACH ELECTRIC ASSOCIATION, INC. Anchorage, Alaska February 27, 1992 TOs: TCS Members FROM: David W. Burlingame, Secretary SUBJECT: TCS Meating Minutes - February 20, 1992 Meeting The following are the draft meeting minutes fcr the above referenced neeting: svc Status - SWEC reported the design of the SVC's at Daves Creek and Soldotna are proceeding on schedule. Construction at Daves Creek is scheduled to begin March 16, 1992. The SVC's are due to be energized mid-November to begin operational testing. Commercial operation is scheduled for March. ABB has been awarded approximately $260,000 in extra costs to settle all known claims. The settlement includes items related to the installation of 2nd harmonic filtering requirements at Daves Creek and Soldotna, draving standards, it requirenents and HEA getaway at Soldotna. : AEA advised the importance of outlining a test plan for ABB to test the svc control system against. Fach utilities was requested to formulate a list of test plans for the SVC systems and FAX the list te AEE aud uil other weilieies by. deli 1, 1992., There will be a meet among the utilities at 1:00 on April 6, 1992 at Chugach to consolidate the test plans. a 8, 1992 to develop the testing sequence. AEA requested the utilities’ select one representative to witness Se ee Ss Sees So Soe: reject or make any changes required as found during the testing. tha utilities gumevally egreed Cluayach would be the representative, ee a rr ; was Ite as to whether ‘PTI should attend the testing, Bererelerereen rereeeee eer eee eee ee It was pointed out that PIT did not provide any inertia data to ABB toe the tant voultinaniant. ABB has indicated they will model the inertia of the Anchorage and Fairbanks systems if given the information. They did not indicate any additional Bin which would be associated with this change. i Lake Status -. Bradley Lake has been operating under relaxed voltage criteria since April 14, 1992. ARA dewatered the unit 2 chamber after 3 days cf 90 MW operation to inspect the unit for - damage due to rocks and concrete and could find no damage. A piece i 02/27/92 = 09:26 9075620027 CHUGACH ELEC. 2+ AEA 002/004 ATTACHMENT NO. 1 CHUGACH ELECTRIC ASSOCIATION, INC. — pyu/i 4,4 ny aa/ He, Anchorage, Alaska February 27, 1992 - Un prurbas i : veh pk TO: TCS Members é ORIGINAL AT RUMEN FROM: David W. Burlingame, Secretary SUBJECT: TCS Meating Minutes - February 20, 1992 Meeting The following are the draft meeting minutes for the above referenced neeting: svc Status - SWEC reported the design of the SVC's at Daves Creek and Soldotna are proceeding on schedule. Construction at Daves Creek is scheduled to begin March 16, 1992. The SVC's are due to be energized mid-November to begin operational testing. Commercial operation is scheduled for March. ABB has been awarded approximately $260,000 ih extra costs to settle all known claims. The settlement includes items related to the installation of 2nd harmonic filtering requirements at Daves Creek and Soldotna, drawing standards, protection requirements and HEA getaway at Soldotna. j AEA advised the importance of outlining a test plan for ABB to test the svc control system against. Each utilities was requested to formulate a list of test plans for the svc systems and FAX the list to AEA and all other utilities by: April 1, 1992. There will be a meeting among the utilities at 1:00 on April 6, 1992 at Chugach to consolidate the test plans. A meeting will be held with ABB April 8, 1992 to develop the testing sequence. AEA requested the utilities’ select one representative to witness the tests and that this representative be empowered to accept, reject or make any changes required as found during the testing. The utilities generally agreed Chugach would be _ representative, but no mctien or vote was taken. It owas questioned as to whether PTI should attend ‘tHe testing, sg dhiowover, reason was overruled and they will ane wae * ee wad pointed out that PTI did not provide any inertia data to ABB "te for thegtest verification. ABB has indicated they will model the ieee of. the Anchorage and Fairbanks ‘Systems if given the aketarn tions. “They did ok indicate any additional costs which oe: be associated — this change. s Mae | att esi tans Statiie -. Bradley Lake has been o perating’ ‘under relaxed vel criteria since apeil 14, 1992. awa dew dewatered the unit 2 spatter: 3 day® of 90 MW operation to ‘inspect the unit for a5 site a ns and concrete and could firid iG -damage. A piece | "ae ae | | usr gt/8Z (UNS ZB 9075620027 CHUGACH ELEC. +e AEA 003/004 of concrete was found wedged in the scroll case of the unit and 1/3 of a 5 gallon bucket of concrete pieces were found. SWEC has confirmed that any failure sequence would most likely involve jamming of the needles and would not be a severe or catastrophic failure. Based on the SWEC information and AEA's inspection, AEA stated they have little concern with the operation of the unit. The tunnel should be dewatered as soon as possible to take advantage of any warranty provision which may be in effect. : | Bradley Lake is tentatively scheduled for an outage March 25 - April 26, 1992 to dewater and inspect the tunnel. The committee suggested the outage be coordinated with the O&D subcommittee and also suggested the 2 week outage on the Bradley - Soldotna line to relocate the getaways be coordinated with the shutdown of Bradley Lake. AEA will attempt to. coordinate both of the outages concurrently at the earliest, possible date. HEA will confirm as to whether they have the crew structure to perform the work in that time frame. . ; Dispatcher Guidelines - The guidelines were not acted on. all utilities should bring any and all requested changes to the next meeting. This item will be an action item at the next TCS meeting. Kenai Export Limits - The committee discussed the new export limits which have been implemented since the last TCS meeting. There was some confusion as to exactly what the export limits are based on the cases which were run. It was agreed the cases run by PTI to date do not completely allow the upper restrictions on Bradley Lake to be removed. The TCS requested PTI run one additional case with Bradley at 90 MW and the Kenai Load on minimums to evaluate the effects of a Kenai export of approximately 40 MW. In the interim, the TCS unaminously approved the following motion: Motion Move to set the Kenai export limit to’ 31 MW with only Bradley Lake generation on-line or:to 47 MW with Bradley and Cooper Lake until PTI completes a study with Bradley Lake at 90 MW with 45 MW HEA load, 5 MW Seward load. After completion of the study, the TCS will review the results and determine if the cvarvoltages are acceptable. In all other generation cases, Bradley Lake is limited to 90 MW. : ! DIvcoM - AEA is having difficulty upgrading the State microwave systems between Bradley Lake and Soldotna due to the lobbying efforts of Alascom and other telephone utilities. AFA stated that if the utilities want the systems upgraded, they need to lobby the state representatives to approve the budget transfers. DECWET - All utilities need to submit any point comments on the proposed DECNET points by March 7, 1992. AEA has agreed to make a certain number of status points available to HEA through the remote ~ MECRI/9Z «=U 2T 9075620027 CHUGACH ELEC. ae AEA @o004/004 display of Bradley Lake located in Homer. It was noted the status points displayed in Homer will not be real time, but will be delayed by some time factor. SWEC will confirm what the time delay for the system is. - i : . Exciter Tests ~ Fuji and SWEC are expected to be on-site the week of February 24, 1992 to perform tests on the Fuji exciter to determine if the exciter is frequency responsive. BRADLEY LAKE FY93 DRAFT BUDGET FERC — sou SERIO 7 a sora HYDRAULIC POWER GENERATION Supervision, Engineering and Administrative Support - 3.2 FTE Hydraulic Operation Expenses Inspection of Three Diversions Snow measurement, SCS Siesmic Monitoring, UAF Climatologic - NOAA Weather Service Semi-Annual Dam Settlement Survey Conservation Studies for Fish and Game Electric Operation Expense SCADA Technical Maintenance Hydraulic Power Generation Operation Expense Mechanical vibration and balance testing, consumables such as oil and filters, die checks and pressure nitrogen cylinder recharges. Helicopter Transportation for Project Facility Inspections Barge Rental to Transport Materials and Dock Fees Project Site Contract Transportation - Scheduled Fixed Wing Service to Site Commercial Transportation Technical and Operations Training Software Upgrade Modification and Training Divcom Maintenance Fee Project radios, pagers, and telephones Maintenance of Structures Routine Supplies, Materials and Maintenance Items Page 1 of 3 FY93BUDB.XLS 12:22 PM 2/16/92 2 *ON LNSWHOVLLY BRADLEY LAKE FY93 DRAFT BUDGET ACCOUNT DESCRIPTION ACCOUNT TOTAL Maintenance of Electric Plant Electrical Spare Parts Contract Labor for Testing Protective and Revenue Meters, Generators, Transformers, Maintenance of Misc. Hydraulic Plant Mechanical Spare Parts Misc. Maintenance Contracts Maintenance of Hydraulic Plant O&M Personnel 4.2 FTE Fuel Stock Fuel for Bradley Vehicles, Loaders, Graders System Control and Load Dispatching TRANSMISSION EXPENSES Labor - CEA 1 FTE Training - CEA Dispatchers Economic Dispatch Program (10 yr. Armortization ) - CEA Bradley Junction Substation Switchyard Inspection and Tests - HEA Maintenance of Overhead Lines ADMINISTRATIVE, GENERAL AND REGULATORY EXPENSES Transmission Line Inspection and Maintenance - HEA Administration and General Expenses a. Bradley PMC Costs PMC Travel Cost Subcommittee Travel Cost Meeting General Expenses 6 PMC Meetings each year in Anchorage 12 Subcommittee Meeting each year PMC Adminstrative Support b. Administration AEA Overhead - 61% of Direct Personnel Services Page 2 of 3 FY93BUDB.XLS 12:22 PM 2/16/92 BRADLEY LAKE FY93 DRAFT BUDGET = ACCOUNT DESCRIPTION Attorney Fees (AEA & Utilities) Professional Audit Services '$1M Deductible b. Boiler and Machinery $50K Deductible jc. General Liability One-Sixtfe bt AEA State Policy Premium |d. Watercraft & Aviation One Sixth of AEA State Policy Premium 'e. Directors and Officers Liability Liability Insurance for the Directors and Officers of the PMC Regulatory Commission Expenses a. FERC Land Use Fees FY92 Billing $97,000 Administrative Fees Estimate ging Five Year Inspection ineerii ultant (est. $75,000 in FY96) b. Permitting AEA Permits Specialist TOTAL FY93 BRADLEY O&M BUDGET 2,672,143, 672,143 Page 3 of 3 FY93BUDB.XLS 12:22 PM 2/16/92 \ | ATTACHMENT NO. 3 NZ Municipal Light & Power 1200 East First Avenue Anchorage, Alaska 99501-1685 (907) 279-7671, Telecopiers: (907) 263-5204, 277-9272 DATE: February 27, 1992 TO: Bradley Lake Project Management Committee FROM: Tom Stahr, General Manager, Anchorage ML&P SUBJECT: Risk /Benefit Considerations (Agenda Item 11B of the Jan 13,1992 Bradley Lake PMC Minutes) AML&P wishes to propose the following motion in order to allow the PMC to more expeditiously determine if approval of a subcommittee’s recommendation passes the test of prudent utility practise: "Normally, a subcommittee presenting a recommendation for approval by the PMC will include with its recommendation a brief (one page if possible) summary assessment of the most compelling risk/benefit factors bearing on the recommendation." We feel this motion would make more evident to the PMC the rationale for the subcommittee’s conclusions (benefit), and would force an even more balanced approach to subcommittee work (benefit). If desired, an individual subcommittee member could elaborate in what ever depth it chose (analysis, study, etc.) in support of the majority opinion or in rebuttal (benefit? /risk?). Putting Energy Into Anchorage KVR O£f# 200d WVEP:OT 26-82-20 a EGR POSES Nn sree till aimee: S ATTACHMENT NO. 4 rahe? v dane | - September me § — 3, L001 As Submitted 0 Aterr Wyane UNREIMBURSED BRADLEY LAKE COSTS Il a Z #11200 295 L06 eALIMOHLMY ADMSNS WY! QE:OL ! 2682-2 | :A@ LN3S Oc# €00d WVEV:OT 26-82-20 vy8S8T9GL06 ag ea ae 7 *vE=a Y ‘. te ti “ ‘ % & Y ce apenas ssi... , 1991. MATANUSKA: Indudes cost information from August 15, 1991 through December 15, 1991. ATER WYNNE: [ncindes legal fecs and costa froma October 15. 1991 through GVEA: Inchades cost informauon from October. 1991 through HOMER: No costs submitted. CHUGACH: No orete submitted. MLG&P: No wets submitied. SEWARD: Ko cosie submitted. 1 2. 3. 4 5 6. 7. = u € #54200 295 106 ALIMOHLAY ADMINS WY: GESOL § 2h-82-2 | :A@ LN3S