ML20127M824
| ML20127M824 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 01/25/1993 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20127M822 | List: |
| References | |
| NUDOCS 9301290021 | |
| Download: ML20127M824 (11) | |
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4, UNITED STATES l'
n NUCLEAR REGULATORY COMMISSION
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WASHINGTON, D. C. 20555
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ENVIRONMENTAL ASSESSMENT BY THE OFFICE OF NUCLEAR REAQ10R REGULATION RELATING TO THE EXPANSION OF THE SPENT FUEL P001 FACILITY OPERATING LICENSE NOS. DPR-39 AND DPR-48 COMMONWEALTH EDISON COMPANY ZION STATION. UNITS 1._AND 2 DOCKET NOS. 50-295 AND 50-391
1.0 INTRODUCTION
1.1 Description of Proposed Action By letter dated January 15, 1997, Commonwealth Edison Company (Ceco, the licensee) requested an amendment to Facility Operating License Nos. DPR-39 and DPR-48 for Zion Station, Units 1 and 2, to allow the expansion of the capacity of the spent fuel pool.
Further information was provided in the form of answers to staff questions by letters dated October 2 and 16, 1992.
The amendment would specifically authorize the licensee to increase the capacity of the spent fuel pool from the currently approved capacity of 2079 storage cells to the proposed capacity of 3012 storage cells', including six (6) defective fuel container cells. The proposed expansion would be achieved by removing the current spent fuel racks from the pool and replacing them with new racks (i.e., reracking) in which the cells for the spent fuel assemblies are more closely spaced.
The proposed arrangement would make use of free standing racks.
There is one spent fuel storage pool at Zion Station shared by both units.
The existing racks in the pool have 2112 fuel stoiage cells.
In the 1994 time frame, the station will no longer have 1ill core discharge reserve.
Consequently, Ceco proposes to replace tne existing spent fuel racks for Zion Station with racks of a high density design. These free standing racks will have the capacity for storage of 3012 fuel assemblies, including six (6) defective fuel storage cells. The proposed configuration will include two-discrete regions, requiring administrative control over placement of fuel within region two based upon a combination of initial enrichment and burnup.
These administrative controls will be incorporated into the plant Technical Specifications (TS) as part of the related license amendment.
These spent fuel storage racks provide smooth full length square storage cells of stainless steel in a welded honeycomb structure.
Each storage cell utilizes boral neutron absorbing poison panels.
Each rack is supported on the pool floor by a minimum of four support legs welded to the bottom of the rack.
9301290021 930125 PDR ADOCK 05000295 P
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.x 1.2 Need for increased Storace Capacity Zion Station, Units 1 and 2, received full power operating licenses on April 6, 1973 and November 14, 1973, respectively. At the time _of licensing, the shared spent fuel pool contained sufficient storage capacity to accommodate up to 340 fuel assemblies.
In 1976, the Nuclear Regulatory Commission (hRC) authorized the reracking of the pool to increase the capacity to 868 fuel assemblies (Amendment Nos. 23 and 20).
In 1980, NRC again approved reracking of the pool to increase the storage capacity to 2112 fuel assemblies (Amendment Nos 52 and 49).
To maintain full core discharge capability beyond 1994, the licensee recently proposed to replace the existing racks with high density racks which will have 3012 storage _ cells, including-six defective fuel storage cells.
The Nuclear Waste Policy Act of 1982 (NWPA) provided for limited away-from-reactor storage, and stipulated that a spent fuel repository would be available by 1998.
Since the NWDA does not require a repository before this date, it is not clear whether there will be any place to ship spent fuel through the mid-1990's. Therefore, in the interim, Ceco needs to provide more storage capacity.
1.3 Alternatives Commercial reprocessing of spent fuel has not developed as originally anticipated.
In 1975, the NRC directed its staff to prepare a Generic Environmental Impact Statement (GEIS) on spent fuel -storage.
The Commission directed the staff to analyze alternatives for the handling and storage of spent light water power reactor fuel with particular emphasis on developing long-range policy. The GEIS was to consider alternative methods of spent fuel.
storage, as well as the possible restri< tion or termination of the generation-of spent fuel through nuclear _ power plant shutdown.
A " Final Generic Environmental Impact Statement on Handling and Storage of Spent Light Water Power Reactor Fuel" (NUREG-0575), Volumes 1-3 (the FGEIS) was issued by the NRC in August 1979. The finding of the FGEIS is that the environmental impact costs of interim storage are essentially negligible, regardless of where such spent fuel is stored. A comparison of the impact custs of various alternatives reflects the advantage of continued generation-of nuclear power versus its replacement by coal-fired power generation.
Continued nuclear generation of power versus its replacement by oil-fired generation provides an even greater economic advantage.
In the bounding case considered in the FGEIS, that of shutting down the reactor when the existing spent fuel storage capacity is filled, the cost of replacing nuclear stations before the end of their normal lifetime makes this alternative uneconomical.
The storage of spent fuel as evaluated in NUREG-0575 is considered to be an interim action, not a final solution to permanent disposal.
One spent fuel storage alternative considered in detail in the FGEIS is the expansion of the onsite fuel storage capacity by modification of the existing-spent fuel pools.
Applications for more than 100 spent fuel pool expansions
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. have been received, and have been approved or are under review by the NRC.
The finding in each case has been that the environmental impact of such increased storage capacity is negligible.
However, since there are variations in storage design and limitations caused by the spent fuel already stored in some of the pools, the FGEIS recommends that licensing reviews be done on a case-by-case basis to resolve plant-specific concerns.
The continuing validity and site specific applicability of the conclusions in NUREG-0575 have been confirmed in the Environmental Assessments for the Hope Creek, H.B. Robinson, and Oconee plants' independent spent fuel storage installations.
The licensee has considered several alternatives to the proposed action of the spent fuel pool expansion.
T'ne staff has evaluated these and certain other alternatives with respect to the need for the proposed action as discussed in Section 1.2 of this assessment.
The following alternatives were considered:
(1) Shipment of spent fuel to a permanent federal fuel storage / disposal facility.
(2) Shipment of fuel to a reprocessing facility.
(3) Shipment of fuel to another utility or site for storage.
(4) Reduction of spent fuel generation.
(5) Construction of a new independent spent fuel storage installation.
(6) No action taken.
Each of these alternatives is discussed below.
(1)
Shioment of Snent Fuel to a termanent Federal Fuel Storace/ Disposal Facility Shipment to a permanent federal fuel storage disposal facility is a preferred alternative to increasing the onsite spent fuel storage capacity. The Department of Energy (DOE) is developing a repository under the Nuclear Waste Policy Act of 1982 (NWPA). However, the facility is not likely to be ready to receive spent fuel until the year 2003, at the earliest. Whereas the generic DOE contract still re': acts a 1998 fuel pickup date, the most recent DOE announcement was that
..ie repository will be ready no sooner than the year 2010.
As an interim measure, shipment to a Monitored Retrievable Storage (MRS) facility is another preferred alternative to increasing the onsite spent fuel storage capacity.
DOE, under the NWPA, has recently submitted its MRS prq.osal to Congress.
Because Congress has not authorized an MRS and because one is not projected to be available until 1998, this alternative does not meet the near-term storage needs of Zion Station, Units 1 and 2.
Under the NWPA, the federal government has the responsibility to provide not more than 1900 metric tons capacity.for the interim storage of spent fuel.
The impacts of storing fuel at a Federal Interim Storage (FIS) facility fall within those already assessed by the NRC in NUREG-0575.
In passing NWPA,
. Congress found that the owners and operators of nuclear power stations have-the primary responsibility for providing interim storage of spent nuclear fuel.
In accordance with the NWPA and 10 CFR Part 53, shipping of spent fuel to a FIS facility is considered a last resort alternative. At this time, the licensee can not take advantage of FIS because existing storage capacity is not maximized. Therefore, Ceco has been diligently pursuing this application for the spent fuel pool expansion at this i.ime. The alternative of shipping spent fuel to a FIS is not available.
(2)
Shioment of fuel to a Reorocessina Facility Reprocessing of spent fuel from Zion is not viable bacause, presently, there is no operating commercial reprocessing facility in the United States, nor is there the prospect for one in the foreseeable future.
(3)
Shioment of Fuel to Another Utility or Site For Storaae The shipment of spent fuel from Zion to the storage facility of another utility company could provide short-term relief for the storage capacity problem. However, the NWPA and 10 CFR Part 53 clearly place the-responsibility for the interim storage of spent nuclear fuel with each owner.
or operator of a nuclear pwer plant. Moreover, transshipment of spent fuel to, and its storage at, another site would entail potential-environmental impacts greater than those associated with the proposed increased storage at the Zion site.
Therefore, this is not considered a practical or reasonable alternative.
The alternative of shipping spent fuel from Zion to one of the other five _ Ceco nuclear sites 'for storage has also been evaluated.
Differences in fuel design and the availability of only marginal capacity for near-term storage at the other sites (in consideration of DOE progress' on a long-term storage facility) preclude implementation of this approach. As noted above, transshipment may '
also entail environmental impacts greater than those -associated with the proposed increased storage at the Zion site. Therefore, this is not considered a practical or reasonable alternative.
(4) Reduction of Soent Fuel Generation Improved usage of fuel in the reactor and/or operation at a reduced' power level would extend the life of the fuel in.the reactor.
In the case of-extended burnup of fuel assemblies, the fuel cycle would be extended and fewer.
offloads would take place. However, the current storage capacity would still be quickly exhausted as discussed in Section 1.2.
Operation at reduced power would not make effective use of available resources and would result in economic penalties.
(5) Construction of a New Independent Soent Fuel Storace Installation (ISFSI)
Additional storage capacity could be developed by building a new, independent spent fuel storage installation (ISFSI) similar either to the existing pool or
. a dry storage installation. The NRC staff has generically assessed the impacts of the pool alternative and found, as reported in NUREG-0575, that "the storage of light-water reactor spent fuels in water pools has an insignificant impact on the environment." A generic assessment for the dry storage alternative has not been made by the staff. However, assessments for the dry cask ISFSI at the Surry Power Station and the dry modular concrete ISFSI at the H.B. Robinson Steam Electric Plant Unit 2, the Oconee Nuclear Station and the Calvert Cliffs Nuclear Power Plant resulted in Findings of No Significant Impact. While these alternatives are environmentally acceptable, such a new storage facility, either at Zion or at a location offsite, would require new site-specific design and construction, including equipment for the transfer of spent fuel.
NRC review, evaluation and licensing of such a facility would also be required.
It is not likely that this entire effort would be completed in time to meet the need for additional capacity as discussed in Section 1.2.
Furthermore, such construction would not utilize the' existing expansion capabilities of the existing pool and, thus, would waste resources.
(6) No Action Taken If no action were taken, i.e., the spent fuel pool storage capacity remains at 2112 locations, the storage capacity would become exhausted in the very near future and Zion Station, Units 1 and 2, would have to be shut down.
Such termination of operations would result in no further generation of spent fuel, thereby eliminating the need for increased spent fuel storage capacity. The impacts of terminating the generation of spent fuel by ceasing the operation of existing nuclear power plants (i.e., ceasing generation of electric power) when their spent fuel pools become filled was evaluated in NUREG-0575 and found to be undesirable. This alternative would be a waste of an available resource for Zion Station, Units 1 and 2, and is not considered viable.
In summary, the only long-term alternative that could provide an alternative solution to the Zion spent fuel storage capacity problem is the construction of a new independent spent fuel storage installation at the Zion site or at a location away from the site.
Construction of such an additional spent fuel storage facility could provide long-term increased storage capacity for Zion.
However, it is not likely that this alternative could be implemented in a timely manner to meet the need for additional capacity for Zion Station, Units 1 and 2.
Further, this alternative would waste resources.
1.4 Fuel Reorocessina History Currently, spent fuel is not being reprocessed on a commercial basis in the United States. The Nuclear Fuel Services (NFS) plant at West Valley, New York, was shut down in 1972 for alterations and expansion.
In September 1976, NFS informed the Commission that it was withdrawing from the nuclear fuel reprocessing business. The Allied General Nuclear Services (AGNS) proposed plant in Barnwell, South Carolina, is not licensed to operate. The General Electric Company (GE) Morris Operation (formerly Midwest Recovery Plant) in Morris, Illinois, is in a decommissioned condition.
. In 1977, President Carter issued a policy statement on commercial reprocessing of spent nuclear fuel, which effectively eliminated reprocessing as part of the relatively near-term nuclear fuel cycle.
Although no plants are licensed for reprocessing fuel, the storage pools at Morris and at West Valley are licensed to store spent fuel.
The storage pool at West Valley is not full, but the licensee (the current licensee is New York Energy Research and Development Authority) is presently not accepting any additional spent fuel for storage, even from those power generating facilities that had contractual arrangements with West Valley.
(In fact, spent fuel is being removed from NFS and returned to its owners.)
On May 4, 1982, the license held by GE for spent fuel storage activities at its Morris operation was renewed for another 20 years; however, GE is com..itted to accept only limited quantities of additional spent fuel for storage at this facility from Cooper and San Onofre Unit 1.
2.0 RADI0 ACTIVE WASTES Zion Station, Units 1 and 2, contain radioactive waste treatment systems designed to collect and process the gaseous, liquid, and solid waste that might contain radioactive material.
The radioactive waste treatment systems were evaluated in the Final Environmental Statement (FES) dated December 1972.
There will be no change in the waste treatment systems described in the FES because of the proposed spent fuel pool (SFP) rerack.
2.1 Radioactive Material Released to the Atmosphere The principal radioactive materials that are considered with respect to nonaccident releases are the noble gases, the halogens, and tritium. Of these, the only radioactive gas of any significance is Krypton-85 (Kr-85).
This is the principal radioactive gas that is associated with the long-term storage of the additional spent fuel assemblies.
It is released through fuel cladding defects.
Experience has shown that after spent fuel has decayed 4 to 6 months, there is no longer any significant release of fission products, including Kr-85, from stored spent fuel. To determine the average annual release of Kr-85, we assume that all of the Kr-85 released to the SFP will be released prior to the next refueling. That is, the release is associated with a batch of discharged fuel, and not with the total inventory of the SFP.
The enlarged capacity of the pool, therefore, has no effect on the calculated average annual amounts of Kr-85 released to the atmosphere each year.
The other gases are of little radioactive significance.
With respect to the halogens,1-131 is the principal contributor.
Iodine-131 releases from spent fuel assemblies to the SFP water _will not be significantly increased by the expansion of the fuel storage capacity, lodine-131 inventory in the fuel will decay to negligible levels between refuelings.
Hence, any significant releases are associated with a given full discharge batch, rather than with the entire inventory of the SFP, so that SFP expansion does not affect 1-131 releases.
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7-A relatively small amount of tritium is produced during reactor cperation by fissioning of the reactor fuel.
It is released by diffusion through the fuel and zircaloy cladding.
Tritium is released from the fuel while the fuel is hot, that is, during reactor operation and, to a limited extent, shortly after shutdown.
Since its release is diminished to insignificant levels, expanding the SFP capacity will not significantly increase the tritium activity in the SFP.
Another ef fect on airborne activity is the potential for increased evaporation due to storing additional spent fuel assemblies in the SFP.
However,- this effect is not expected to be significant for the following reasons:
(1)
While the analyses associated with the rerack indicate an increase in fuel pool water temperature for certain scenarios, this increase is not expected to significantly increase the annual release of tritium and iodine due to evaporation from the SFP.
The increases in calculated bulk temperature from those previously calculated are generally attributable to conservatism in the analytical assumptions.
The contribution to the total heat load of the pool from the long-term storage of decayed fuel is minimal when compared to that resulting from the current offload.
Furthermore, the gaseous effluent from the SFP will be collected by the spent fuel building ventilation system and proce; sed prior to release to the environment.
Therefore, the annual release of tritium or iodine by evaporation from the SFP is not expected to increase significantly.
(2)
On an annual basis, most airborne releases frem Zion Station, Units 1 and 2, are due to leakage of reactor coolant which contains tritium and radioactive iodine in higher concentrations than the SFP.
Therefore, even if there were a higher annual release from the SFP, the potential increase in the releases of tritium and iodine would be small compared to the amount normally released from the station and that which was previously evaluated in the Environmental Statement.
Aside from the above considerations, the station is limited in its total releases of gaseous activity by the Radiological Effluent Technical Specifications.
The concentration of radionuclides in the pool water is decreased by processing through the SFP cleanup demineralizer and by decaying of short-lived isotopes.
The activity is highest during refueling operations when reactor coolant water is introduced in the pool, and decreases as the pool water is processed through the demineralizer.
Thereafter, the activity concentration has been and should continue to be, dependent on the demineralizer resin replacement, with no long-term build-up.
The increase of radioactivity, if any, due to the proposed SFP modification should be minor, since the cleanup system can remove radioactivity continuously from the.SFP water and, thus, keep it at acceptable levels.
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-8 In view of the ab've, the staff has assumed, for dose calculation purposes, o
that there will be no significant increase in the release of tritium or radioiodine due to evaporation from the SFP.
2.2. Solid Radioactive Wastes The staff does not expect any significant_ increase in the amount of solid waste generated from the SFP cleanup system due to the proposed modification.
Solid radioactive wastes from the SFP can result from the discharge of spent resins and filter cartridges from the SFP cleanup system.
The necessity 'for resin and filter replacement is determined primarily by the requirement for water clarity. Water clarity problems are caused by the frequency of refueling operations and should be independent of the nun.ber of spent fuel assemblies stored.
During the reracking operation, a small amount of additional resin may be generated by the pool cleanup' system oc a one ' time basis as a result of the expected effects of physical activity in the pool.
Thus, the expanded capacity of the storage pool is not cxpected to significantly alter the frequency of resin or filter cartridge replacement above that which is currently experienced.
Therefore, the proposed reracking of the SFP will not significantly alter the environmental impact due to solid radioactive wastes.
2.3 Radioactive Material Released to Receivina-Waters There should not be a significant increase in.the: liquid. release of radionuclides from the plant as a result of the proposed modifications.
Since-the SFP cooling and cleanup systems operate as a' closed system, only water originating from cleanup of SFP floors and filter-demineralizer backflush need be considered as potential sources of radioactivity.
It is expected that neither the quantity nor activity of the floor cleanup water-will change as a result of these modifications.
The SFP filter-demineralizer resin removes radioactive materials from the SFP water.
These spent resins are periodically; backflushed with water.
The amount of radioactivity in the SFP filter demineralizer resin may increase slightly due to.the additional spent fuel in the pool, but the resultant liquid effluent -(from-backflushing) will_ be processed prior to release to the environment.
After processing, the amount of radioactivity released via liquid effluent to. the environment as a result of the proposed modification would be negligible.
3.0 RADIOLOGICAL IMPACT ASSESSMENT /0CCUPATIONAL EXPOSURE This section contains the staff's evaluation of the estimates of the additional radiological impacts on the plant workers from the proposed modification of the SFP and subsequent operation of the SFP with expanded capacity.
The occupational exposure associated with implementation of the proposed modification of the SFP is estimated by the licensee to be less than 12' person-rems.
This dose is less that 3 percent of the average annual occupational dose of 468 person-rems per year for dual unit operating PWRs in
. the United States (U.S. NRC 1992).
The small increase in radiation dose should not affect the licensee's ability to maintain the individual occupational doses within the limits of 10 CFR Part 20, and is as low as is reasonable achievable.
Normal radiation control procedures (U.S. NRC 1981) and Pegulatory Guide 8.8 (U.S. NRC 1978) should preclude any significant
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occupational radiation exposures.
Based on present and projected operations in the SFP area, we estimate that the proposed operation of the modified SFP would add, at most, only a small fraction to the total annual occupational radiation dose at this facility.
Thus, we conclude that the implementation of the proposed modification and storage of spent fuel in the modified SFP will not result in any significant increase in doses received by workers.
3.1 Conclusions Based on its review of the proposed expansion of the SFP at Zion, the staff concludes that:
(1)
The potential offsite radiologichl doses resulting from the postulated, fuel handling accident (design basis accident) will remain well within the guideline values of 10 CFR 100.11.
(2)
The estimated additional nonaccident radiation doses to the general public are much less than those incurred during normal operation of Zion Nuclear Power Station.
(3)
The licensee has taken appropriate steps to ensure that occupational dose will be maintained as low as is reasonably achievable and within the limits of 10 CFR Part 20.
The total occupational dose estimated to be associated with the proposed modification of the expanded spent fuel pool is less than 12 person-rems, which is less than 3 percent of the average annual occupational dose for operating dual unit PWRs in the United States.
On the basis of the foregoing evaluition, it is concluded that there would be no significant additional environmental radiological impact attributable to the proposed reracking and modification to increase the spent fuel storage capacity at Zion Station.
We have concluded, based on the considerations discussed above, that there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, with regard to radiation doses to the public and plant workers.
. i.0 NON-RADIOLOGICAL IMPACT The new spent fuel racks will be fabricated by U.S. Tool and Die Company in Pittsburgh, Pennsylvania. They will be shipped by truck to the Zion site for installation in the pool. This is not expected to impact terrestrial resources not previously disturbed during the original construction.
The only nonradiological effluent affected by the spent fuel pool expansion is the additional waste heat rejected from the plant.
The resultant worst case heat load rejected to the environment through the cooling systems due to the 6
increased spent fuel storage is 49 x 10 BTU / hour.
This represents less than 0.05 percent of the total plant heat loss to the environment.
Thus, the increase in rejected heat will have negligible impact on the environment. No impact on aquatic biota is anticipated.
The licensee has not proposed any change in the use or discharge of chemicals in conjunction with the expansion of the fuel pool.
The proposed fuel pool expansion will not require any change to the NPDES permit.
Therefore, the staff concludes that the nonradiological environmental impacts of expanding the spent fuel pool will be insignificant.
5,0 SEVERE ACCIDENT CONSIDERATIONS s
The staff, in its related Safety Evaluation to be published at a later date, has addressed both the safety and environmental aspects of a fuel handling accident.
A fuel handling accident may be viewed as a " reasonably foreseeable" design basis event which the pool and its associated structures, systems, and components (including the racks) are designed and constructed to prevent.
The potential offsite radiological doses resulting from the postulated fuel handling accident will remain well within the guideline values of 10 CFR 100.11.
The environmental impacts of the accident were found to be insignificant.
6.0
SUMMARY
The Final Generic Environmental Impact Statement (FGEIS) on Handling and Storage of Spent Light Water Power Reactor Fuel concluded that the cost of the various alternatives reflects the advantage of continued generation of nuclear power with the accompanying spent fuel storage.
Because of the differences in SFP designs, the FGEIS recommended environmental evaluation of SFP expansions on a case-by-case basis.
For Zion Station, Units 1 and 2, the expansion of the storage capacity of the spent fuel pool will not create any significant additional radiological effects or measurable nonradiological environmental impacts.
The potential offsite radiological doses resulting from the postulated fuel handling accident (design basis accident) will remain well within the guideline values of 10 CFR 100.11. The estimated additional nonaccident radiation doses to the general public are much less than those incurred during normal operation of
4
. Zion Station.
The occupational radiation dose for the proposed modification of the expanded spent fuel pool is estimated by the staff to be less than three percent of the average annual occupational radiation exposure for a facility of this type. lhis small increase-in radiation dose should not affect the licensee's ability to maintain individual occupational dose at the Zion Station within the limits of 10 CFR Part 20, and as low as is' reasonably achievable. The expected increase in annual occupational radiation exposure due to normal operation with the expanded spent. fuel pool is negligible.
The only nonradiological effluent affected by the SFP expansion is the additional waste heat rejected.
The increase in total plant waste heat is insignificant.
Thus, there is no significant environmental impact attributable to the waste heat from the plant due to the SFP expansion.
6.1 Alternative Use of Resourqgi This action does not involve the use of resources not previously considered in connection with the Nuclear Regulatory Commission's Final Environmental Statement, dated December 1972, related to the operation of the Zion Station, Units 1 and 2.
6.2 Aaencies and Persons consulted The NRC staff reviewed the licensee's request.
No other agencies or persons were consulted.
7.0 BASIS AND CONCLUSIONS FOR NOT PREPARING AN ENVIRONMENTAL IMPACT STATFMENT The staff has reviewed the proposed spent fuel pool modification to Zion.
Station, Units 1 and 2, relative to the requirements set forth in 10 CFR Part 51.
Based upon the environmental assessment, the staff has concluded-that there are.no significant radiological or nonradiological impacts associated with the proposed acticn and that the proposed license amendment will not have significant effect on the quality of the human environment.
Therefore, the Commission has determined, pursuant to 10 CFR 51.31, not to prepare an environmental impact statement for the proposed amendment.
Principal Contributor: Clyde Y. Shiraki Dated:
January 25, 1993 2
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