ML20083A459
| ML20083A459 | |
| Person / Time | |
|---|---|
| Issue date: | 03/31/1995 |
| From: | Joy D NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| References | |
| NUREG-0430, NUREG-0430-V14, NUREG-430, NUREG-430-V14, NUDOCS 9505100290 | |
| Download: ML20083A459 (18) | |
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l NUREG-0430 l
Vol.14 1
Licensed Fuel Facility Status Report Inventory Difference Data July 1,1993-June 30,1994 U.S. Nuclear Regulatory Commission ja mae d'
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51 950330 0430 R PDR
AVAILABILITY NOTICE
- Availability of Reference Materials Cited in NRC Publications Most documents cited in NRC publicat5cns will be available from one of the following sources:
f 1.
The NRC Public Document Room, 2120 L Street, NW., Lower Level, Washington, DC 20555-0001 i
2.
The Superintendent of Documents U.S. Government Printing Office, P. O. Box 37082, Washington, DC 20402-9328 3.
The National Technical Information Service, Springfield, VA 22161-0002 Although the listing that follows represents the majority of documents cited in NRC publica-tions, it is not intended to be exhaustive.
Referenced documents available for inspection and copying for a fee from the NRC Public Document Room include NRC correspondence and internal NRC memoranda; NRC bulletins, circulars, information notices, inspection and investigation notices; licensee event reports; vendor reports and correspondence; Commission papers; and applicant and licensee docu-ments and correspondence.
The following documents in the NUREG series are available for purchase from the Government Printing Office: formal NRC staff and contractor reports, NRC-sponsored conference pro-ceedings, international agreement reports, grantee reports, and NRC booklets and bro-chures. Also available are regulatory guides, NRC regulations in the Code of Federal Regula-tions, and Nuclear Regulatory Commission Issuances.
Documents available from the National Technical information Service include NUREG-series reports and technical reports prepared by other Federal agencies and reports prepared by the Atomic Energy Commission, forerunner agency to the Nuclear Regulatory Commission.
Documents available from public and special technical libraries include all open literature.
Items, such as books, journal anicles, and transactions. Federal Register notices, Federal and State legislation, and congressional reports can usually be obtained from these libraries.
Documents such as theses, dissertations, foreign reports and translations, and non-NRC con-ference proceedings are available for purchase from the organization sponsoring the publica-tion cited.
Single copies of NRC draft reports are available free, to the extent of supply, upon written request to the Office of Administration, Distribution and Mail Services Section, U.S. Nuclear Regulatory Commission Washington DC 20555-0001.
Copies of industry codes and sta.ndards used in a substantive manner in the NRC regulatory process are maintained at the NRC Lhrary, Two White Fhnt North,11545 Rockville Pike, Rock-ville, MD 20852-2738, for use by the public. Codes and standards are usually copyrighted and may be purchased from the originating organization or, if they are American National Standards, from the American National Standerds Institute,1430 Broadway, New York, NY 10018-3308.
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NUREG-0430 Vol.14 Licensed Fuel Facility Status Report i
I l
l Inventory Difference Data j
July 1,1993-June 30,1994 Manuscript Completed: January 1995 Date Published: March 1995 D. R. Joy Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 1
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i ABSTRACT The Nuclear Regulatory Commission is committed to an annual publication of 1
licensed fuel facilities' inventory difference (ID) results, after Agency review of the information and completion of any related investigations.
Information in this report includes ID results for active fuel fabrication and/or recovery facilities.
l Acronyms and/or abbreviations used in this report are identified on page vii.
The various terms and acronyms used in this publication are defined on pages 1 through 4.
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iii NUREG-0430 l
CONTENTS fHe
-Abstract -................................
iii Abbreviations / Acronyms vii
- De fi ni ti on o f Terms............................ ' l Introductory Discussion..........................
5 Tabulation of Inventory Differences.....................
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ABBREVIATIONS / ACRONYMS C.L.
Confidence level CFR Code of Federal Regulations FKG FormulaKilogram(s)
HEU High-enriched uranium ID Inventory difference LEID Limit of error of an inventory difference LEU Low-enriched uranium NRC.
Nuclear Regulatory Commission Pu Plutonium SEID Standard error of an inventory difference SM Source material SNM Special nuclear material SSNM Strategic special nuclear material U-233 Uranium-233 U-235 Uranium-235 Pu-238 Plutonium-238 Pu-239 Plutonium-239 Pu-241 Plutonium-241 i
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1 vii NUREG-0430
DEFINITION OF TERMS 1.
Isotope: A nuclide of a chemical element (such as uranium or plutonium) whose atoms all have the same number of neutrons, as well as the same number of protons, within their nuclei. That is, all isotopes of a given element must have the same number of protons within the nuclei of their atoms, but the number of neutrons per nucleus varies between isotopes.
It is the number of protons plus neutrons within an atom's nucleus that defines its mass number. U-233, U-235, and U-238 are three isotopes of uranium (the latter two being found in naturally occurring
{
uranium ores) having 141, 143, and 146 neutrons, respectively, within the nucleus of each of their atoms.
2.
Fissile Isotope (or Nuclide): A nuclide species that is capable of giving rise to a self-sustaining chain reaction (of nuclear fission) when present in sufficient mass and concentration. U-233, U-235, Pu-239, and Pu-241 are the only fissile nuclides contained in "special nuclear material" (SNM), which also consists of other uranium and plutonium isotopes.
3.
Source Material (SM):
(1) Natural uranium or thorium, or depleted uranium, or any combination thereof, in any physical or chemical form, or (2) ores that contain by weight 0.05 percent or more of (i) uranium, (ii) thorium, or (iii) any combination thereof. SM does not include SNM.
4.
Special Nuclear Material (SNM):
(1) Plutonium, uranium-233, uranium enriched in the isotope uranium-235, and any other material that the U.S. Government, pursuant to the provisions of Section 51 of the Atomic Energy Act of 1954, as amended, determines to be SNM; or (2) any material artificially enriched in any of the foregoing. SNM (of any type) does not include SM.
5.
High-Enriched Uranium (HEU): Any uranium-bearing material whose uranium isotope content is 20 percent or more U-235 by weight (relative to total uranium element content).
6.
Low-Enriched Uranium (LEU): Any uranium-bearing material whose uranium isotope content is less than 20 percent, but greater than 0.72 percent, U-235 by weight (relative to total uranium element content).
7.
Natural Uranium: Any uranium-bearing material whose uranium isotopic distribution has not been altered from its naturally occurring state.
Natural uranium is nominally 99.283 percent U-238, 0.711 percent U-235, and 0.006 percent U-234.
8.
Depleted Uranium: Any uranium-bearing material whose combined U-233 plus U-235 isotopic content is less than 0.70 percent by weight (relative to total uranium element content).
9.
Strategic Special Nuclear Material (SSNM): Uranium-235 contained in HEU, uranium-233, or plutonium. NOTE: All SSNM is SNM, but not all SNM is SSNM.
1 NUREG-0430 1
l
10.
Effective Kilogram of SNM:
(1) For plutonium and U-233, their weight in kilograms; (2) for uranium with an enrichment in the isotope U-235 of 1.00 percent (0.01 weight fraction) and above, its element weight in kilograms multiplied by the square of its enrichment expressed as a L
decimal weight fraction; and (3) for uranium with an enrichment in U-235 below 1.00 percent, but above 0.71 percent, its element weight in kilograms multiplied by.0001.
11.
Formula Kilogram (FKG):
1000 formula grams of SSNM computed by the following equation:
Grams = (grams U-235 contained in HEU) + 2.5 (grams U-233)
+ 2.5 (grams plutonium) 12.
Formula Quantity:
SSNM in any combination in a quantity of 5000 formula grams or more, as computed by the same equation as given above in definitTon No.11.
(NOTE:
In unirradiated form, this quantity of SSNM is sometimes referred to as a Category I quantity of material.)
13.
SNM of Moderate Strategic Significance:
(1) Less than a formula quantity of SSNM, but more than 1000 grams of U-235 contained in HEU, or more than 500 grams of U-233 or plutonium, or more than a combined quantity of 1000 formula grams when computed by the equation:
Grams = (grams U-235 in HEU) + 2.0 (grams U-233 + grams Pu) or (2) 10,000 grams or more of U-235 contained in LEU enriched to 10 percent or more (but less than 20 percent) in the U-235 isotope.
(NOTE:
In unirradiated form, either of the forementioned two quantities is sometimes referred to as a Category 11 quantity.)
14.
SNM of Low Strategic Significance:
(1) Less than an amount of SNM of moderate strategic significance, but more than 15 grams of (i)
U-235 contained in HEU, (ii) U-233, (iii) plutonium, or (iv) any combination thereof; (2) less than 10,000 grams, but more than 1000 grams of U-235 contained in LEU enriched to 10 percent or more (but less than 20 percent) in the U-235 isotope; or (3) 10,000 grams or more of U-235 contained in LEU enriched above natural, but less than 10 percent, in the U-235 isotope.
(NOTE:
In unirradiated form, any of the above three quantities is sometimes referred to as a Category III quantity.)
15.
Inventory Difference (ID): The arithmetic difference between a book inventory and the corresponding hysical inventory, calculated by subtracting ending inventory (El from the combination of beginning l
inventory (BI) plus additions to inventory (A) minus removals from inventory (R). Mathematically, this can be expressed as:
ID = (BI + A - R) - El or ID = BI + A - R - EI
]
16.
Limit of Error of the ID (LEID):
Twice the standard error of the estimated measurement uncertainty associated with the ID, or in other words, twice the square root of the measurement variance associated with the 10.
17.
Standard Error of the ID (SEID):
(a) For. licensees subject to 10 CFR 74.31, SEID is equal to the square root of the sum of both measurement and non-measurement variances associated with an ID.
(b) For licensees subject to 10 CFR 74.59, SEID is equal to the square root of the measurement variance (only) associated with an ID.
18.
Detection Quantity (DQ): A site-specific SNM quantity for Category III licensees whose processing activities are limited to SNM of low strategic significance. The DQ is normally a function of annual throughput, but for low-throughput LEU facilities, the DQ need not be less than 25 kilograms of U-235. The DQ can also be described as a goal quantity, the loss or theft of which must be detected with a 90 percent or better) probability, whenever a physical inventory is taken.
19.
Detection Threshold (DT): An ID alarm limit that will be exceeded (with 90 percent or higher probability) by an ID (resulting from the taking of a physical inventory) whenever there has been an actual loss of a detection quantity. The DT is a function of both the DQ and SEID, as shown in the following equation:
DT = DQ - 1.3 (SEID) 20.
The ID Was Within Its Expected Range: The 10 was less than (1) 200 grams plutonium or U-233, (ii) 300 grams U-235 contained in HEU, or (iii) 9000 grams U-235 contained in LEU, as appropriate, and/or was less than its associated LEID or SEID.
21.
The ID Was Within Its Regulatory Limit: The ID exceeded both (1) 200 grams U-233 or plutonium, 300 grams U-235 contained in HEU or 9000 grams U-235 contained in LEU (as appropriate), and (2) its associated LEID or SEID, but was less than 1.5 times the limit for LEID (for 10 CFR 70.51 licensees) or less than the ID limit (for 10 CFR 74.31 and 74.59 licensees). For 10 CFR 74.31 licensees, the ID limit is the site-specific detection threshold quantity, which is considerably larger than SEID.
For 10 CFR 74.59 licensees, the ID limit is 3 times SEID.
22.
The ID Exceeded Its Regulatory Limit: The ID exceeded its applicable regulatory limit and was thus subject to both licensee and NRC investigations to determine the cause(s) of the excessive value (regardless of whether the ID was negative or positive).
23.
Negative ID: A situation that occurs when the amount of SNM on hand, as determined by the physical inventory, exceeds the amount of SNM being carried on the books (records). That is, there appears to be a gain in material. Mathematically, a negative ID is written as "-ID," or shown in parentheses. A negative ID is also referred to as an "ID gain."
24.
Positive ID: A situation that occurs when the amount of SNM on hand, as determined by the physical inventory, is less than the amount of SNM being carried on the books (records). That is, there appears to be a loss of material. Mathematically, a positive ID is written as
"+10," or is shown without any designation of sign. A positive ID is also referred to as an "ID loss."
25.
Plant: For SNM control and accounting purposes, a plant is defined as a set of processes or operations (on the same site, but not necessarily all in the same building) coordinated into a single manufacturing, R&D, or testing effort. Most licensees have only one plant in this context.
A scrap recovery operation serving both onsite and offsite customers, or more than one onsite manufacturing effort (plant), would be treated as a separate plant.
26.
SNM Material Type Categories: For inventory and accounting purposes, SNM is classified into six material type categories (not to be confused with Categories I, II, and III quantities). The six categories are uranium in cascades, LEU, HEU, uranium-233, plutonium, and plutonium-238.
For each category, SNM is accounted for on both a total element and isotope basis. The element and isotope for each category are as follows:
CATEGORY ELEMENT IS0 TOPE Uranium in Cascades Total Uranium U-235 LEU Total Uranium U-235 HEU Total Uranium U-235 Uranium-233 Total Uranium U-233 Plutonium Total Plutonium Pu-239 + Pu-241 Plutonium-238 Total Plutonium Pu-238 NUREG-0430 4
INTRODUCTORY DISCUSSION LICENSED FUEL FACILITY STATUS REPORT --- INVENTORY DIFFERENCE RESULTS An inventory difference (10), also referred to as material unaccounted for (MUF), is the difference between the quantity of special nuclear material (SNM) that a licensee's accounting records show should be on hand and that which a licensee's physical inventory shows is actually on hand.
Both quantities (i.e., book and physical) are subject to measurement uncertainties, recording errors, etc.
The ID information presented is for active, licensed facilities that are authorized to possess and use, in an unsealed form, at least 1 effective kilogram of SNM.
The U.S. Nuclear Regulatory Commission uses a graded approach in applying safeguards requirements for such licensees, depending on the strategic significance of the SNM authorized for possession, and the level and frequency of monitoring programs required for timely detection of losses.
Licensees authorized to have significant quantities of strategic SNM --- i.e.,
high-enriched uranium (HEU), plutonium, or uranium-233 --- are required to conduct physical inventories at least every 6 months.
Facilities authorized to possess and use 1 or more effective kilograms of SNM of moderate strategic significance conduct inventories every 6 months, whereas licensees whose holdings are restricted to SNM of low strategic significance perform physical inventories every 12 months.
It is important to understand the distinction between the low strategic significance of low-enriched uranium (LEU) and the higher strategic significance of HEU and plutonium.
LEU used to fabricate fuel assemblies for commercial power reactors is enriched to a level of 1 to 5 percent in the U-235 isotope. At this level of enrichment, the uranium is (under certain conditions) capable of sustaining a chain reaction, but is not capable of generating a nuclear explosion (regardless of its quantity and configuration).
NRC safeguards requirements covering LEU are graded to reflect its low strategic significance. They include a formal structured system for material control and accounting and basic industrial security measures. On the other hand, because of the higher stretegic significance of HEU and plutonium (which under certain circumstances could be used for the fabrication of a nuclear explosive device), NRC requires licensees to provide substantial physical protection of these materials. Additionally, more rigorous controls and accounting programs are imposed.
Physical protection of strategic SNM includes safeguards measures such as barriers, intrusion alarms, armed guards, and offsite police response.
Internal systems to control the movement of strategic SNM and to monitor its presence are also required.
Non-zero ids, both positive and negative, result from a combination of factors such as measurement variability (i.e., measurement uncertainty), measurement errors (i.e., measurement mistakes), changes in the quantity of unmeasured equipment holdup, and recordkeeping errors. An unmeasured loss (either accidental or deliberate) or theft would give rise to a unidirectional (mathematically positive) impact on an ID, so as to make a negative ID less negative (or change it to positive) or a positive ID more positive. Generally speaking, the more complex a facility's process operations are (especially when dealing with chemical operations), the greater the uncertainty associated with an ID value becomes.
5 NUREG-0430 L
Although an ID larger t M lts overall measurement uncertainty may signal an abnormal situation (requ. ring determination of the cause), the fact that an ID falls within its associated limit of error --- even a zero ID value ---
provides no automatic or conclusive proof that a loss or theft of SNM has not occurred. Hence, NRC relies on information provided not only by the material accounting system, but also by the internal control system, the physical security system, NRC inspections and evaluations, and NRC and licensee investigations.
The concept of the limit of error of the inventory difference (LEID) is a method that licensees subject to 10 CFR 70.51 and NRC use to determine the significance of the ID.
LEID is a calculated estimate of the measurement uncertainty (at the 95 percent confidence level [C.L.]) that is associated with the facility's ID. That is, ID should be within the range of zero plus or minus LEID 19 times out of 20, if measurement uncertainty is the only contributor to non-zero ids.
For 10 CFR 70.51 licensees, an ID that exceeds its associated LEID may be an indication of processing problems, biased or otherwise inaccurate measurements, bookkeeping errors, or a loss or theft of material. NRC accordingly requires licensees to take increasingly stronger investigative actions depending on how much the ID exceeds both LEID and minimum quantities specified in 10 CFR 74.13(b) --- namely, 200 grams of plutonium, 300 grams U-235 contained in HEU, or 9000 grams U-235 contained in LEU.
If the ID exceeds its LEID, but does not exceed the minimum quantity, no formal investigation is required.
The concept of the standard error of inventory difference (SEID) is a method that NRC and licensees subject to either 10 CFR 74.31 or 74.59 use to determine the significance of an ID.
For 10 CFR 74.31 licensees, SEID is a calculated estimate of the total uncertainty (at the 67 percent C.L.) due to both measurement and non-measurement contributors. Thus, for 10 CFR 74.31 licensees, ID should tend to be less than SEID 2 times out of 3, or less than twice SEID 19 times out of 20.
For 10 CFR 74.59 licensees, SEID is the calculated estimate of the measurement uncertainty (at the 67 percent C.L.)
that is associated with an ID. Hence, for 10 CFR 74.59 licensees, ID should be less than SEID 2 times out of 3, and less than twice SEID 19 times out of 20, if non-zero ids result only from measurement uncertainty.
For 10 CFR 74.31 licensees (whose operations are limited to SNM of low strategic significance), ID must exceed its threshold quantity (a site-specific value that is considerably larger than SEID) before investigative actions are required. For 10 CFR 74.59 licensees, investigative actions are required whenever an ID exceeds both (i) 200 grams plutonium or U-233, or 300 grams U-235, and (ii) 3 times SEID.
The ids for this reporting period (July 1,1993 through June 30,1994) are indicated in the " Tabulation of Inventory Differences" that begins on page 7 of this report. An expianation of the significance, and when appropriate, the contributing factor (s) for ids deemed excessive are included in the last column of the table.
Physical inventories are required for each SNM category (LEU, HEU, U-233, plutonium, and Pu-238) within each plant.
For those licensees having more than one plant on the same site, the ID value listed, for a given SNM category, is the total site net ID.
Tabulation of Inventory Differences SNM Inventory Explanation License Docket SNM Inventory Di fference
[See definitions Licensee No.
No.
Category Date (Grams U-235)
- 20, 21, a 22]
Babcock & Wilcox - NNFD 42 70-27 HEU 07/31/93
+ 1,893 The ID exceeded its (Lynchburg,Va.)
regulatory limit.
- The SEID was unusually low (<5%
of maximum allowable) and thus the regulatory limit (3 times SEID) was very low.
HEU 12/31/93
+ 1,952 The ID was within its expected range.
HEU 03/31/94
- 133 The ID was within its expected range.
HEU 05/31/94
+ 860 The ID was within its u
expected range.
LEU 07/31/93
+ 55 The ID was within its expected range.
LEU 12/31/93
+ 25 The ID was within its expected range.
LEU 05/31/94
- 57 The ID was within its j
l expected range.
l t
B&W Fuel Company 1168 70-1201 LEU 07/19/93
+ 4,346 The ID was within its l
(Lynchburg,Va.)
l E
expected range.
l a
i2 Combustion Engineering 33 70-36 LEU 07/27/93
+ 22,819 The ID was within its 8
(Hematite, Missouri) regulatory limit.
Tabulation of Inventory Differences [ Cont.]
Inventory Explanation SNM License Docket SNM Inventory Difference
[See definitions EE Licensee No.
No.
Category Date (Grams U-235)
- 20, 21, & 22]
5' Combustion Engineering 1067 70-1100 LEU 09/01/93
+ 6,484 The ID was within its regulatory limit.
5' (Windsor, Conn.)
E GA Technologies 696 70-734 HEU 07/12/93
- 18 The ID was within its expected range.
(La Jolla, Calif.)
HEU 09/13/93
+ 13 The ID was within its expected range.
HEU 11/08/93
+ 114 The ID was within its expected range.
HEU 01/10/94
+ 111 The ID was within its expected range.
HEU 03/14/94
+ 93 The 10 was within its a>
expected range.
HEU 05/09/94
-2 The ID was wiyhin its expected range.
LEU 09/13/93
-1 The 10 was within its expected range.
LEU 03/14/94
- 106 The ID was within its expected range.
1
Tabulatien of Inv ntary Differences [ Cent.]
SNM Inventory Explanation License Docket SNM Inventory Di fference
[See definitions Licensee No.
No.
Categary Date (Grams U-235)
- # 20, 21, & 22]
General Electric Co.
1097 70-1113 LEU 08/15/93
+ 1,487 The ID was within its (Wilmington,N.C.)
expected range.
Nuclear Fuels Services 124 70-143 HEU 06/29/93
- 1,805 The ID was within its (Erwin,Tenn.)
regulatory limit.
HEU 10/25/93
+ 226 The ID was within its expected range.
HEU 04/25/94
- 1,914 The ID was within its regulatory limit.
LEU 06/20/94
- 246 The ID was within its expected range.
e Siemens Power Corp.
1227 70-1257 LEU 07/1470
+ 4,919 The ID was within its expected range.
Westinghouse Elec. Corp.
1107 70-1151 LEU 07/01/93
- 11,953 The ID was within its expected range.
LEU 06/30/94
+ 14,448 The ID was within its expected range.
E i??28
NOC FoMu 235 U.S. NUCLEAR PEGULATORY COMMIS$ TON
- 1. REPCRT NUMBER Ra74 lin, 1"lT*""' *l,",,"u"Ch'"I' ""-
m noi. nn BIBLIOGRAPHIC DATA SHEET rs,,,,,,,,uc,,,,,,,,,,w, men; NUREG-0430 Vol. 14
- 2. TITLE AND SUBTITLE Licensed Fuel Facility Status Report Inventory Difference Data a.
oATE REPORT PuBLiSsEo July 1, 1993 - June 30, 1994 I
uom u Aa March 1995
- 6. AUlHOR(S)
- 6. TYPE OF REPORT D. R. Joy Status Summary Report
- 7. PE RIOD COVE R L 0 linctume Ourena July 1993 - June 1994 8 PE R F ORMING ORG ANIZ AT SON - N AME AND ADDR E SS tar NMc. orovedr ownsen. orta ar Resoon. v.s Nackar Reputerory commnasen. ond martonn nodress;rs conrrn ror. prove thPHe and oldehng SdorF8d Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
- 9. SP,ONSO,R tNG OR G ANIZ ATtON - N AME AND ADDR E SS tro NRC. tver "Some m ahrrar ; or centra tor. prove NRC Dwoon. O*In or Regen, U s. Nuchar Reputatory commossen,
. m.mr..de o Same as 8, above
- 10. SUPPEEMENT ARY NOTES
- 11. ABST R ACT (2do were or hasJ l
NRC is committed to the periodic publication of licensed fuel facility inventory l
difference data, following agency review of the information and completion of any I
related NRC investigations.
Information in this report includes inventory difference data for active fuel fabrication facilities possessing more than l
one effective kilogram of special nuclear material.
s
- 12. KE Y WOH DS 'Dt SC H T10H 5 (1,sr worm or paren W v esser reseerraws ** Jart rear rae rnser.. s 13 AV A*L Abou t v st At tetN1 unlimited nuclear h 41 m ilities, inventory difference, physical inventories,
,,mun, n ct.
,,c.,,0, s
special Juiieor taterial accounting unclassified cin. ne,-u unclassified Ib. NUMBE H OF PAGES e
- 16. PRICL e
1 NRC P OMM 33b Q49)
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Printed on recycled paper Federal Recycling Program
NUREG-4430, Vol.14 LICENSED FUEL FACILITY STATUS REPORT MARCH 1995 NUCLEAR REGULATORY COMMISSION FIRST CLASS Mall POSTAGE AND FEES PAfD WASHINGTON, D.C. 20555-0001 USNRC PERMIT NO. G-67 OFFICIAL BUSINESS PENALTY FOR PRIVATE USE 4300
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