They like to call the Atlantic Coast Conference basketball tournment the second season. Each league team starts over. Even the last-place team knows it can earn a bid to the NCAA tournament with three victories.

But in judging what will happen starting Thursday at Capital Centre, it is instructive to look closely at this year's first season. It leaves one observer with a number of predictions, many of them undoubtedly misguided. The bottom line on this tournament is this:

One team, Georgia Tech, is awful and has no chance to win a game. Four teams -- Wake Forest, Duke, Clemson and N.C. State -- are competitive but are extremely unlikely to win the tournament. One team, Maryland, has a dark horse shot at winning. And two teams, Virginia and North Carolina, belong in Saturday night's final.

Tech (0-14 in the ACC, 4-22 overall) came no closer than eight points in any of its regular-season conference games. The Yellow Jackets are slow, small, shoot horribly and are in the league only because their association with it gives the ACC another lucrative TV market. So they will be on the floor Thursday at 1:30 p.m., ripe for annihilation by Virginia.

Working from the bottom up, each of the next three teams -- seventh-seeded N.C. State, No. 6 Clemson and No. 5 Duke, is capable of pulling first-day upsets. But none of the three has the depth or experience to win three games here.

State (4-10, 14-12) will play second-seeded North Carolina at 7, The Wolfpack twice lost to the Tar Heels during the regular season by three points after leading late in the second half.

Coach Jim Valvano's team has shown a remarkable knack for staying with superior teams for 37 minutes, then doing a disappearing act at the end. Saturday, the Wolfpack built such a big lead -- 22 points -- that it managed to hold on to beat Wake Forest by one.

The key man for State is point guard Sidney Lowe. The 6-foot De Matha graduate runs the offense, penetrates, shoots occasionally from outside and is the catalyst for the running game. But even if Lowe plays one of his best games, the Wolfpack cannot compete with the Tar Heels unless big men Craig Watts, Thurl Bailey and Art Jones rebound well.

Clemson has the best chance for an opening-day upset, against Wake Forest in the 11 a.m. opener. The Tigers (6-8, 20-9) have been the league's mystery team. They went through one stretch where they shot 43 percent from the floor for four games, then hit 63 percent their next four.

The Tiger's key man is 6-10 senior Larry Nance, who, like his team, has been fabulous awful. Clemson Coach Bill Foster has depth and uses nine or 10 men. So his team is probably less dependent on a particular star than any other in the field.

Clemson beat the Deacons in their last meeting and lost to them by two in Winston-Samem earlier. Wake has made it past the first round once in the last seven years and Clemson has the talent to win. But it won't matter. The Tigers probably will face Carolina the next night and that is a game the Tar Heels won't lose.

Duke (6-8, 15-11) faces the unusual disadvantage of playing a favored team that has a revenge motive. Duke prevented Maryland from winning the tournament, 73-72, a year ago and Duke won in heart-stopping fashion, 55-54, last month in Durham.

This is a very different team from the one that has played in the final three straight years, winning twice. Center Mike Gminski is gone and so is Bill Foster, the coach who built the program.

But Eugene Banks and Kenny Dennard remain and new Coach Mike Krzyzewski has built a solid team around them the last six weeks. The Blue Devils won eight of their last 12 and were in three of the four losses until the last 30 seconds. They have no center and Mike Tissaw, the 6-8 forward playing there, has a sprained ankle, meaning Allen Williams, a smaller 6-8 forward, may have to start.

Duke does have discipline and if it can keep Maryland from running, it is capable of winning. But the Devils cannot beat Virginia and that is their semifinal opponent unless hell freezes over.

Wake Forest (9-5, 21-5) is seeded third and Coach Carl Tacy's team has beaten every league opponent at least once.

The Deacons have been a spotty team the last month, and the one absolute requisite for success here is consistency. If Wake can survive against Clemson it will have an excellent chance to upset North Carolina because it plays the Tar Heels tougher than anyone.

The major reason for that is Frank Johnson, who is 7-4 against Carolina in his four playing years. Like Lowe, this point guard is his team's catalyst, only he has better supporting characters, notably junior center Jim Johnstone, who may be the most improved player in the league, and forward Alvis Rogers.

Wake is capable of winning here. But it won't.

The same could be said of Maryland by a braver person. Everyone knows the Terrapins are capable of winning. They could also be written off because of their lackluster (8-6, 18-8) regular season.

But certain intangibles make the Terps a legitimate dark horse. One is the fact that Virginia and Carolina, the teams they would probably have to beat the last two nights, have already beaten them twice. If these Terrapins are good at anything, it is holding grudges.

Buck Williams can be expected to be psyched the entire tournament. He hates Duke, wants revenge on Ralph Sampson for last Saturday's stomping and can't stand losing to North Carolina.

But Williams will need plenty of help, especially against Sampson. Albert King will have to equal his fabulous tournament of a year ago and Greg Manning will have to be his usual self, which means Maryland must run. Filnally, Earnest Graham must shoot well and rebound for Maryland to pull back-to-back upsets.

Now, the finalist.

North Carolina (10-4, 22-7) has come through one of the nation's toughest schedules and should be primed. UNC's front line of 6-10 freshman Sam Perkins, 6-8 Al Wood is as good as any in college. Worthy can be the most dominating player in the tournament if the back spasms that kept him out of the Duke game Saturday are gone.

Carolina should lose the final to Virginia, in overtime. But don't bet the ranch. The Tar Heels had the Cavaliers (13-1, 24-2) in deep trouble twice and let them escape. Carolina Coach Dean Smith is fond of telling people how hard it is to beat a team three times in one season. No one has done it to him since N.C. State's championship team in 1974.

But this Virginia team is capable of it. Sampson is the main weapon but players like Jeff Lamp, Lee Raker and the overlooked Jeff Jones, can play on any team. And the Cavaliers know they can come from behind against UNC and know they can handle this year's version of the four corners.

The Cavaliers will have a tough time with Maryland and could be upset. If you are simply looking for a superb final, hope that doesn't happen. Because if Carolina and Virginia play the last night, the potential is there for a game close to the classic 1974 Maryland-State final or last year's Maryland-Duke championship.