ML19320C662
| ML19320C662 | |
| Person / Time | |
|---|---|
| Issue date: | 07/01/1980 |
| From: | James Shea NRC OFFICE OF INTERNATIONAL PROGRAMS (OIP) |
| To: | |
| Shared Package | |
| ML19320C663 | List: |
| References | |
| TASK-CA, TASK-SE SECY-80-318, NUDOCS 8007170523 | |
| Download: ML19320C662 (5) | |
Text
' '
S July 1, 1980 SECY-80-318 COMMJSSIONER ACTION For:
From:
James R. Shea, Director
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Office of International Programs Thru:
Acting Executive Director for Operations
Subject:
APPROVAL 0F A PROPOSED LICENSE TO EXPORT HIGH-ENRICHED URANIUM TO JAPAN (LICENSE APPLICATION NO. XSNM01408)
Purpose:
Commission review of proposed issuance of subject license to Nissho-Iwai American Corporation.
Review Dates:
60-day period expires on August 18, 1980.
120-day period expires on October 17, 1980.
Discussion:
In November 1978, Nissho-Iwat filed an application for a license to export 47.162 kilograms of uranium, enriched to 93.3%, containing 44.003 kilograms of U-235 to Japan for use in the Japan Materials Testing Reactor (JMTRJ, the Japan Research Reactor No. 2 (JRR-2),
and the Japan Research Reactor No. 4 (JRR-4).
By letter dated January 25, 1980, the staff was informed that the material, in the form of uranium metal, will be fabricated into fuel elements by Nuclear Fuel Industries Limited in Japan.
The material will be distributed in the following quantities:
35.624 kilograms
{33.238 kilograms U-235)~ to the JMTR; 10.584 kilograms (9.875 kilograms U-235) for the JRR-2; and 0.954 kilograms (0.890 kilograms U-235)~ for the JRR-4.
The 50 megawatt thermal JMTR, which began operation in 1968, is Japan's principal reactor for testing materials in a high neutron 4
flux. The JRR-2, which began full operation in 1962, is a 10 megawatt thermal reactor used for neutron physics, materials irradiation, and isotope production. The JRR-4, a 1 megawatt thermal pool type reactor which began operation in 1965, is used for reactor physics and shielding experiments.
In response to our November 22, 1978 request for views, the Executive Branch has (1) concluded that issuance of the proposed license would not be inimical to the comon defense and security of the United States, if the license were conditioned to provide that the material, for the international portion of shipment, shall be transported by all-cargo military aircraft or in quantities not to exceed 15 kilograms of U-235 per flight by comercial cargo aircraft or 5 kilograms U-235 if transported by sea; (2) confirmed
Contact:
nice Dunn Lee, IP (49-27984)
O The Commissioners Discussi~on:
that the material will be subject to all the terms and conditions (Continued) of the US-Japan Agreement for Cooperation; (3) noted that Japan has adhered to the provisions of the Agreement for Cooperation with the United States; and (4) advised that there were no material changed circumstances since submission of its detailed analysis of April 30, 1979 on a proposed export to Japan (see XSNM01435 SECY-79-14B).
Among other things, the Executive Branch memorandum notes that:
0 The President has approved the proposed export and since it involves projects and facilities with which the U.S. has previously supplied HEU, no new U.S. commitment to supply HEU would be created by NRC approval of this case.
0 In conformance with policy direction to minimize unirradiated HEU inventory, the quantity under this export request, in conjunction with material requested under application XSNM-1340 (which is being forwarded separately for Commission consideration), is limited to that expected to be sufficient for not more than two and one-half years of reactor operation from the time of the export. This is considered a reasonable period to allow for export, transportation, and fabrication of fuel and maintenance of fresh fuel reserve sufficient to assure the continuous and economic operation of the reactor.
O In mid-1979 the JMTR had about 63 kilograms of U-235 (93%
enrichment) in the conversion / fabrication process.
Since the JMTR requires approximately 35 kilograms of U-235 per year for normal operation, this amount would permit about one and one-half years operation, or through 1980. There-fore, the material requested in the application at hand for the JMTR, and that requested in application XSNM01340 for the JMTR (a total of approximately 59 kilograms of U-235) would allow normal operation through.l982 O
The JRR-2 requires about'10 kilograms of U-235 (93% enrichment) per year to ensure normal operation.
The JRR-2 has 11 kilograms of U-235 in the conversion / fabrication process and another 6 kilograms in fabric-ted, unirradiated fuel element form. This amount would allow the operation of the JRR-2 for approximately one and one-half years, or through 1980. The material requested for the JRR-2 in ap)lications XSNM01340 and XSNM01408 (a total of 20 kilograms of J-235) would allow for normal operation l
through 1982.
l l
The Commissioners 0 The JRR-4 has 1 kilogram of HEU in the conversion /
fabrication process and 0.3 kilograms in fabricated, unirradiated fuel element form.
Since the JRR-4 requires
)
about 1 kilogram of U-235 (93% enrichment) per year for normal operation, this amount would allow operation through 1980. The material requested in the application
~ ~ ~ hniilor~thi JRRJ,~and that reauestid~ in XSNM01340 at h
~
~~
(a total of 2 kilograms of U-235) would allow normal operation thr6tigT1982. ~~-~ ~~~ ~ ~ ~~-~~ -~~
~
~
Although Executive Branch views initially were received on January 30, 1980, actiors on this case and several other proposed HEU exports to Japan and EURATOM weredelayed pending clarification by the Executive Branch, at our request, of matters relating to transportation of the proposed exports, and in particular the Executive Branch's requirements regarding shipping conditions on the license, which raised problems for our staff.
On June 19, 1980, the staff received additional comments from the Executive Branch which amended its views on conditioning the license. Since the Executive Branch has now been in. formed by the license applicant that the material will be transported directly to Japan by sea in tranches of 5 kilograms or less, and it understands NRC has no objection to this mode of transportation, the Executive Branch believes that a license condition requiring specific modes of transport is no longer necessary. This pro-cedure is satisfactory to the staff.
(The Commission will note that this shipping issue is addressed generically and in greater detail in a separate staff paper (SECY-80-193, classified, dated April 18, 1980)).
The staff has examined the question of whether it would be possible to operate the JMTR, JRR-2, and JRR-4 facilities on uranium of lower enrichment. Argonne National Laboratory (ANL) completed its technical and economic analysis of the possibility of converting these reactors to reduced enrichment fuels. Based on independent studies at ANL and the Japan Atomic Energy Research Institute (JAERI), the owner and operator of the reactors, both ANL and JAERI agree that all three reactors can be converted to 45% enrichment fuel when this high density fuel is available. We are informed that JAERI is planning a five year program with the goal of a full core demonstration with 45% fuel in all three reactors in mid-1983. ANL and JAERI are also planning a joint program to study the feasibility of using less than 20% enriched fuel in the three reactors.
The Comissioners International The staff has little information on the effectiveness of IAEA Safeguards and safeguards implementation at the Nuclear Fuel Industries fabrication Foreign Physical facility, the Japan Materials Testing Reactor (JMTR), and Japan Security Review: Research Reactors 2 and 4 (JRR-2 and JRR-4). All of these are covered by IAEA facility attachments and have been under IAEA safeguards for several years.
With respect to physical security, the staff has reviewed the program in Japan and found it adequate for the purposes of this export.
A supplemental report (CNSI) regarding physical security was forwarded to the Commission on March 28, 1980 as SECY-80-167.
For the purposes of this export, the licensee and the consignee have decided to transport the material in less than 5 kg quantities.
==
Conclusion:==
The staff believes that there are no material changed circumstances concerning exports to Japan which would affect the Commission's considerations of licensing criteria and which have occurred since issuance of export licenses (e.g. XSNM01271, SECY-80-120A, and XSNM01435 SECY-79-14C) for material to Japan after Commission review.
3 Accordingly, the staff believes that this proposed license to Japan i
should be issued. This procedure is authorized by 1110.44(a)(2) of Part 110 and is based on section 126(a)(2) of the AEA as amended by the Nuclear Non-Proliferation Act of 1978.
1 The following documents are forwarded for Commission review of the subject application:
(1). application cf November 3,1978 and 1
request for amendment dated January 25, 1980 (Appendjx A);
(2) Executive Branch views of January 29 and June 18,1980(Appendix B); and (3) copy of proposed license (Appendix C).
This action involves no new resource requirements.
Recommendation:
That the Commission authorize the issuance of the proposed license to Nissho-Iwai American Corporation.
Coordination:
DELD has no legal objection. NMSS views are presented in the context of the International Safeguards and Foreign Physical Security Review.
Jame
. Shea, Director Offi of International Programs
Enclosures:
As stated i
The Commissioners NOTE: Commissioner comments should be provided directly to the Office of the Secretary, by c.o.b.
Thursday, July 10, 1980 Commission staff office comments, if any, should be submitted to the Commissioners j
NLT July 8, 1980
, with an information copy to the Office of the Secretary.
If the paper is of such a nature that it requires additional time for analytical review and conments, the Commissioners and the Secretariat should be apprised of when comments may be expected.
DISTRIBUTION:
Commissioners Commission Staff Offices Executive Dir. for Opers.
Secretariat A
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4 T..".J.S. ATOMIC ENERGY COMMIS$10N
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,se, 10 CF R 30,40 Washington, D.C. 20545 as.googy, APPLICATION FOR LICENSE TO EXPORT
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BYPRODUCT, SOURCE, OR SPECIAL NUCLEAR MATERIAL gy Submit in Triplicate Carefully Read Instructions on Back
- 1. D ATE OF APPLICATION
- 2. APPLIC ANT'S REFERENC E NO.
- 3. COUNTRY OF ULTIM ATE DESTIN ATION November 3, 1978 UI'"*> NIAC-78-1103 Japan
- 4. N AmeE OF A PPLIC AN T
- 5. ULTIMATE CONSIGNEE IN FOREIGN COUNTRY Nissho-Iwai American Corporation mee -d address >
STREET AcoREss Japan Atomic Energy Research Institute i
1211 Avenue of the Americas 1-1-13, Shinbashi Minato-ku ciTv, STATE. ANo zlP cooE Tokyo 105 New York, NY 10036 h
- e. INTERMEDIA 5 E CONSIGN EE IN F'OREIGN COUNTRY (Cite nef
- 7. IF PURCH ASER IN FOREIGN COUNTRY l$ OTH ER TH AN
'!!j and addre:s. If same as raf tsmate etssesigner, stsste "Se re. ")
ULTIMATE CONSIGNEE, GIVE N AME ANO ADDRESS.
mNUKEM GmbH and.
Nuclear Fuel Indus-U/ sa' 3" "S*"' ~>
MM Hanau,amehdies>@@9 -tries, Ltd.
Same
/ FWest GermIny 23-5, NishishinbashL i
I (Co vev+or) Me_f 3-Chome Minato-ku, Tokyo 107 (Fabricator) 4 thiso M wee 4 f ar L
- 8. (a) ou ANTITY TO 8E sNIPPEO (b) COmen00ITY DEsCRIPTIOW(Incisode chemical and pr%. sical fornn for special nuclee marrial smd fSee instructions on back) b&uct maternal also specify isotopic content: if in a device, idertify the devece, mesulactwer.
=
eut nmdal number.)
5 47.162 KgU Uranium in the form of Uranium Hexafluoride enriched to a l
44.003 KgU-235 maximum of 93.30 percent.
l0 (c) SNl* PING ANO PACKINO PROCEDURES (Required for specid rxaclee maternd. See instructions on baa-k.)
?!.
\\ The shipment will be packagdin accordance with 10 CFR part 71. i =-{ S.
- 9. END USE OF CO aMOC' TIES COVERED BY THis APPLICATION: (Descrthe fully. stat ng uhag uill be prodaced or maredfactwed, uhgg ser:nce udit be rendered, or the nature of the reseech that unit be performed.) (See,gpstructions on back for special nuclear materud.)
gj Will be (gQed as fuel for the Japan Materi'als Besting Reactor (JMTR) in the Oarai y Research Establighment, Oarai, Ibaragi, Japan, the Japan Research Reactor No. 2 (JRR-2) d in the Tokai Research Establishment, Tokai, Ibaragi Japan and the Japan Research y Reactor No. 4 (JRR-4) in the Tokai Research Establishment, Tokai, Ibaragi Japan. 3 i 8d !'. 51k
- 10. The applicant, and any official esecuting this certificate on behalf of the applicant named in item 4. certify that this application
'l is prepared in ccaformity with Title 10. Code of Federal Regulations. Parts 30 and 36 (if for byproduct material) or Part 40 (if' (i for source material), or Part 70 (if for special nuclear material), and Part 71 (for transport of radioactive material, if applicable) i and citat all informancion contained herein, including any supplements attached hereto, ss true and correct to the best of their knowledge and belief. ij f/,/J "7 f % Nissho-Iwai American Corporation !!^ RECEtVEU [ /.7 4 Q $p tc de ]m,(ed n item 4> capplic n U.S. NRC.' -9. y r f W pr."TD=b p M 1 l y4- / d 3p 578 Hoy 8 Pli I 31 ceneral Manager y F.5ll. (Title of certifyeng officid ashorszed to act on bebdf of t' V / Dwe ih y Q.b
- plicent) 7' (+),YS Y
?.' ',~ ? *. NET yg s i Weening: 18 U.S.C. Section 1001'; AttNI[$$ 25,1948: 62 5 tot. 749: maku et a criminal offense to make a willfvily false U amont er represer;tetion to any department or agencT of the, United States as to our matter within its ivrisdiction
^d ~.. m ~ .e. .~ N
- f. 'g Japan Atomic Enerhy Research Institute
[ e 11-13.Shinhoshi Minato-ku, Tokyo 103 4M / TeleWm:(03)303 6111 Teles:)MRI J24396
- g/
j Cable:JAERINIPPON TcKYO Our ref.: To whom it may concern: End Use Statement The undersigners certify that a quantity of 47162 kgs of uranium (93 3 % U-235 enriched) in form of UF6 containing 44.003 kgs of U-235 which will be furnished to us under a Short-Tenn Fixed-Commitment Contract with US-DOE will be used by us as follows for the fuel of Japan Materials Testing Reactor (JMTR) in our Oarai Research Establishment, Oarai, Ibaragi, Japan Research Reactor No. 2 (JRR-2) in our Tokai Research Establishment, Tokai, Ibaragi, . Japan and Japan Research Reactor No. 4 (JRR-4) in our Tokai Research Establishment, Tokai, Ibaragi, Japan. 35 624 kgs of uranium for JMTR .3 3, J J g A fl J JS 10 584 kgs of uranium for JRR-2 9,%76 0 954 kgs of uranium for JRR-4 O,890 'Ihe enriched UF6 shall be converted into uranium metal by NUKDi GmbH, D-6450 Hanau 11, Federal Republic of Germany and fabricated into fuel elements by Nuclear Fuel Industries Ltd., 23-5, Nishishinbashi 3-chome, Minato-ku, Tokyo, Japan. We authorize Nissho-Iwai American Corporation,1211 Avenue of the Amercas, New York, U.S. A. to apply for the export license. r JAPAN A'IOMIC ENERGY RESEARCH INSTITUTE 4 i f 6244 cM 19 1 b Head, Division of Contracts 1978 HOV 8 Phi I 32 Tde Reseerik heeEEheenq g fiskanslii Res. orch Estehlishw corsi Research fatabanNnent TekeWe therekagn 369.U.,,, Tekoseksh. Ovamelen 37012 oarei.,ned=, IberokMen 311 13 1 Tele,heaes (0273) 46-121l Telephone (029267) 4111 1
.E 1 CHECICIST FOR USE IN REVIEW OF REQUESTS FOR HIGHLY ENRICHED URANIUM TO DETERMINE TECleiICAL AND ECONOMIC JUSTIFICATION g ygg e@YSMt.PPV, r1974 Japan Research Reactor No.2 (JRR-2) EA'POR,T/gPORT 1. Name of Facility: Of ** f 10.584 KgsU ni 2. Quantity of Uranium Requested (Kgs): 3 Enrictament in the Isotope U-235 (%): 43% Toll enriching le. Sale or Toll Enriching: Apprcx. 4.7 Kgs U-235 5 Current Core Leading (Kgs of U-235): 10 MWth 6. Current Power Level (MWth): 7 Criticality and Full Operating Power Dates and Power Rating (If request involves Criticality (October, 1960), I MWth (March, 1961), new facility): 3MWth (November, 1961), 10 MWth (December, 1962) Convertor: NUKEM GmbH (West Germany) 8. Name of Convertor and Fa.bricator of Fuel: Fabricator: Nuclear c'\\:el Industries, Ltd. (Japan) 9 Brealedown of Fuel Inventory (Kgs of U-235): Annount of U-235 in Fabrication outside USA Incluv.ing Scrap a. Allowances: Approx.12.1 Kgs U-235 b. Annount of U-235 in Storage in Completed, Unirradiated Fuel Elements: Approx 9.9 Kgs U-235 c. Assount of U-235 in core: Approx. 4.7 Kgs U-235 d. Assount of U-235 in Spent Fuel Storage within the Community Including Chemical Reprocessing Plants, and the Reprocessing Schedule for Such Material. , Approx. 11.4 Kgs U-235, Approx. 7.6 Kgs U-235 in 11.4 Kgs U-235 in August, 1978 at USDOE Savannah River Plant Asmount of U-235 Lost and/or Consumed During Operation of Above Facility: e. Approx.1.9 Kgs U-235/ year 0.195 Kgs U-235 f. Assount of U-235 per Fuel Element: g. Average Core Life: Approx. 6 :non s i Average Lead Time for Conversion and Fuel Fabrication if Conversion and h. Fabrication is to be Done Abroad: l Approx. 3-4 years (
,/ IlE", MA$h.-2089-NT 4 w. s. Nissholwai AYesican COrpQrition sockereiser center 1211 Avenue of the Arnericas November 3,1978 New Y;rk. N.Y.10036 212/730-2000 For information Direct Number 730-2255
- h, Mr. Neil Moore Export / Import and International Safeguards Telex Numbers:
Office of International Programs RCA 232641/233567 Nuclear. Regulatory Commission ITT4?04oS Twx 7 o.sai-6252 Washington, DC 20555 WUI 620-912 Attn: Mr. Neil Moore Br~nch Offices Subj ect: Export License Application for Enriched Uranium San Fr!,ncisco Los Angeles Pcrtland Seatti-) Chicago gy5to"
Dear Mr. Moorre:
St. Louis $C"g'S' Enclosed please find the Export License Application, End Use Statement and Checklist for use in review of requests for highly Enriched Uranium to determine technical and economic Justification. We would.ippreciate your earliest review on the captioned application. Very truly yours, l P l 8.__. N. Tsuji Assistant Manager Machinery Project Development Dept. NT:eh. Enclosure cc:
- 1) Atomb
- 2) Mr..Dixon B. Hoyle, Directo.
- 3) Mr. Su::uki, Japanese Embassy RECENED O.S.NRC se Q }}Q] 0 N
leg _ ,. 16 Q(hch ]h9N?S v.'*!!l.';IT . '.h "lbMU
'Nissho lwai our Ref: MACeJ 2348 KY American January 2S,1980 Rockefeller Center 1211 Avenue of the Amencas New York. N.Y.1oo36 0l $$n7odaEn Mr. N. Moore g g /f M cirect Number Nuclear Regulatory Commission 2255 Office of International Programs 7735 Old Georgetown Road TrJex Numbers: Bethesda, MD 20014 RCA 232641/233s67 ITT420405 TWX 710-581-6252 WUI 620 912 Re: Export License Application Number XSNM-1408 m o 12suo/12329 Applicant's Reference No. NIAC-78-1103 Brinch Offices: San Frcncisco h$$th"n$"'*
Dear 3tr. Moore:
Seitti2 Nus*t!$ This is to advise you that this material will now be transported j,[oji, from the United States directly to Japan, in the form of Uranittm Ancnorage metal Therefore, please remove NUKEM, GmbH, W. Germany as ^"*"*2 Inters:nediate Consignees. This raaterial will -be fabricated by Nuclear Fuel Industries, Ltd., Tokyo,, Japan and will be supplied to us by the U.S. DOE. Please also list the following as Intermediate Consignee (for Transport purposes only): Nissho-Iwai Company, Ltd. Tokyo Head Office 4-5 Akasaka, 2-Chome Minato-ku, Tokyo 107, Japan. Thanking you in advance for your help and cooperation. Very truly yours, NISSHO-IWAI AMERICAN CORPORATION %::rl':n U 3..'i!.:[ __._/___.___ ___C__f u 0___M C_______ K. Yn==na, nager 13g g l b !) 0 '- Nuclear Machinery 6 Fuel Department KY:ml [ cc:
- 1) MACPJ Letter File
., y. ( b
- 2) HHM-0193
)cp d e ce ' ' q '7 c
- 3) Tokyo, ATOMN e
.....o un::: EE 65; DEPARTMENT OF STATE M 4 JAPAN = "a8"a. o.c. nosso .r.,giyg0 XSNM01340 & M ' ' - *E XSNM01408 EE mas umi BUREAU OF OCEANS AND INTEREAM ONp G l ENVIRONMENTAL AND SCIENTIM XI'IEIRb I U.. xsNmo13Yo+ m c=- XS/Y Al UI V0 S 5 JAN 2 S 1980.h~.m.- /WGns n mE.;.unsrcaos NE k f, 'af%w .nu se M MEMORANDUM FOR JAMES R. SHEA lifi NUCLEAR REGULATORY COMMISSION m 5S u:S Enclosed is an Executive Branch review of two license
- E applications for expo,rt of highly-enriched uranium to Japan, M
one via the Federal Republic of Germany for conversion. In Q accordance with the Nuclear Non-Proliferation Act of 1978 igg ( P.L. 95-24 2), the Executive Branch considered how the re-Nii1 quirements of Section 126 a.(1) of the Atomic Energy Act, as amended, are met, including the specific criteria of Mg Sections 127, and 128, as well as certain additional factors, gi envisaged by Section 126 a. (1). pg hb The Executive Branch, on the basis of its review of
- gg these applications, has concluded that the requirements of
'we the Atomic Energy Act, as amended by P.L. 95-242, have been met and that the proposed exports would not be inimical to the common defense and security of the United States, pro-v2.ded that the material proposed for export shall, for the (Mi international portion of shipment, be transported by all-5% cargo military aircraf t or in quantities not to exceed 15 A kilograms U-235 per flight by commercial cargo aircraf t or ?? 5 kilograms U-235 if transported by sea. It is the view W of the Executive Branch that the licenses should be con- 'it ditioned accordingly. N A detailed analysis for Japan was submitted April 30, ligg 1979 for NRC app 3 ication No. XSNM01435. In' regard to the Isiz export to the FRG, a EURATOM member state, as intermediate mm consignee, a detailed analysis for the FRG and the ~ European IN$ Community was submitted November 27, 1979 for application m;: No.,XUOgp h,7, @ - Mggs m 57.s r I%Q_J@ dypWYWM'3"4"#iPNi#yterial change in circum-3jsince those submissio b Es the FRG) have adhered to E-e DUPLICATE DOCUMENT jfor Cooperation with the N#X ^ sttive Branch recommends . =.. = 4 l Entire document previously 3 cense. w entered into system under: j Q ANO OO 3 ihlp I No. of Pacies : l~ uw.an~a {h a .4 m, yn
"a,=.7 < W'4G /, i W 3 DEPARTMENT OF STATE Wasnington, O.C. 20520 BUREAU OF OCEANS AND INTERNATIONAL "NVIRONMENTAL AND SCIENTIFIC AFFAIRS .a JUN 18 1980 N3O g /SY0 Mr. James R. Shea Director /h [ OfYice of International Programs US Nuclear Regulatory Commission gg (( M2, Bethesda, Maryland 20555 , y.~. - ~ g-Dear Mr. Sheta 9 This is in reference to my memorandur. dated January 29, 1980 conveying a favorable Executive Branch recommendation with respect to the authorization of two exports of highly- = enriched uranium to Japan (applications XSNM01340 and XSNM01408). In that recommendation we expressed the view that the licenses should be conditioned to require transport of the highly-enriched uranium for the international portion of the shipment by all-cargo military aircraft, or by '.=: commercial c'hrgo aircraft in quantities not to exceed 15 kilograms or by sea in quantities not to exceed 5 kilograms. =; We have now been informed by the license applicant that there will be no intermediate consignee outside of Japan for either export and that the material is to be obtained in metallic form from Oak Ridge and transported m directly to Japan by sea in tranches of 5 kilograms or less. .c =3 Since we, understand that the NRC staff has no objection to l the foregoing mode of transportation, the Executive Branch .-j is of the view that a license condition requiring specific ~~ modes of transport is no longer necessary. ]... Please let me know if you should have any cluestions
==; regarding our posit.'on on this matter. +5 rd... ..m..g. Sincerely, , e.,
- &i
-b a ,,w j/f' W - g., [c ', 2 Louis V. N,senzo/
- O y",
p~., Deputy Assistant Secretary .. = - ..: ?..U
- -".51DF70E ll
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