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Category:SAFETY EVALUATION REPORT--LICENSING & RELATED ISSUES
MONTHYEARML20211H7921999-08-13013 August 1999 Safety Evaluation Supporting Amend 126 to License DPR-54 ML20198G8271997-08-22022 August 1997 Safety Evaluation Supporting Amend 125 to License DPR-54 ML20045B9051993-06-16016 June 1993 Safety Evaluation Re Order Approving Decommissioning Plan & Authorizing Decommissioning of Rsngs,Unit 1,SMUD.Concludes That Reasonable Assurance That Health & Safety of Public Will Not Be Endangered by Decommissioning Option,Provided ML20029B6721991-02-22022 February 1991 Safety Evaluation Supporting Proposed Rev to Emergency Plan & Granting Exemption from 10CFR50-54(q) Requirements ML20059G9621990-09-10010 September 1990 Safety Evaluation Supporting Amend 115 to License DPR-54 ML20247B3611989-07-17017 July 1989 Safety Evaluation Supporting Amend 112 to License DPR-54 ML20245E1161989-06-20020 June 1989 Safety Evaluation Supporting Amend 111 to License DPR-54 ML20245A1991989-06-0909 June 1989 Safety Evaluation Supporting Amend 110 to License DPR-54 ML20248B6321989-06-0505 June 1989 Safety Evaluation Supporting Amend 108 to License DPR-54 ML20248B9361989-06-0505 June 1989 Safety Evaluation Supporting Amend 107 to License DPR-54 ML20248B9621989-06-0505 June 1989 Safety Evaluation Supporting Amend 109 to License DPR-54 ML20247P1761989-05-30030 May 1989 Safety Evaluation Accepting Generic Ltr 83-28,Item 4.5.2 Re on-line Testing of Reactor Trip Sys ML20247K7261989-05-23023 May 1989 Safety Evaluation Supporting Amend 105 to License DPR-54 ML20247M9231989-05-23023 May 1989 Safety Evaluation Supporting Amend 106 to License DPR-54 ML20247K6871989-05-16016 May 1989 Safety Evaluation Supporting Amend 104 to License DPR-54 ML20246F4671989-05-0404 May 1989 Safety Evaluation Re Inservice Testing Program & Requests for Relief Re ASME Class 1,2 & 3 Pumps & Valves.Program Acceptable ML20245F9041989-04-18018 April 1989 Safety Evaluation Supporting Amend 103 to License DPR-54 ML20248E9371989-03-29029 March 1989 Safety Evaluation Supporting Amend 102 to License DPR-54 ML20155D3131988-09-28028 September 1988 Safety Evaluation Supporting Amend 100 to License DPR-54 ML20151L5511988-07-14014 July 1988 Redistributed Safety Evaluation Supporting Amend 99 to License DPR-54 ML20151A2771988-07-13013 July 1988 SER Supporting Util Actions to Prevent Failure of Ammonia Tanks Which May Result in Incapacitation of Control Room & Technical Support Ctr Personnel ML20195C5571988-06-0808 June 1988 SER Supporting Util Responses to Generic Ltr 83-28,Item 2.1 (Part 1) Re Equipment Classification (Reactor Trip Sys Components) ML20195C9311988-06-0808 June 1988 SER Accepting Util Response to Generic Ltr 83-28,Item 2.1 (Part 2) Re Vendor Interface Programs (Reactor Trip Sys) ML20150F2851988-03-28028 March 1988 Safety Evaluation Supporting Resolution of Tdi Diesel Engine Vibration Problems at Facility ML20148J8611988-03-17017 March 1988 Safety Evaluation Supporting Amend 98 to License DPR-54 ML20153B2911988-03-15015 March 1988 Safety Evaluation Supporting Amend 97 to License DPR-54 ML20055E3041988-02-12012 February 1988 Safety Evaluation Supporting Util 871223 & 880111 Proposed Changes to Tech Specs,Including Reducing Lower Limits of Detection for Liquid Radioactive Effluents ML20149L6961988-02-12012 February 1988 Safety Evaluation Supporting Amend 95 to License DPR-54 ML20149L2761988-02-0909 February 1988 Safety Evaluation Supporting Amend 94 to License DPR-54 ML20148C7321988-01-0505 January 1988 Safety Evaluation Supporting Amend 93 to License DPR-54 ML20237B4141987-12-0707 December 1987 Safety Evaluation Supporting Amend 92 to License DPR-54 ML20236X1771987-12-0303 December 1987 Safety Evaluation Supporting Amend 91 to License DPR-54 ML20236X1111987-11-13013 November 1987 Safety Evaluation Supporting Amend 90 to License DPR-54 ML20236Q2461987-11-10010 November 1987 Safety Evaluation Supporting Util & Related Submittals Re Design Mods to Emergency Electrical Distribution Sys (Ref Tdi Diesel Generators) ML20236J2671987-11-0303 November 1987 Safety Evaluation Supporting Amend 89 to License DPR-54 ML20245C7831987-10-27027 October 1987 Safety Evaluation Supporting Amend 88 to License DPR-54 ML20245C7051987-10-27027 October 1987 Safety Evaluation Supporting Amend 87 to License DPR-54 ML20236G8791987-10-23023 October 1987 Safety Evaluation Supporting Amend 86 to License DPR-54 ML20236D1361987-10-23023 October 1987 Safety Evaluation Supporting Util 870826 Request to Use Repair & Replacement Program Contained in ASME Section XI 1983 Edition Including Addenda Through Summer 1983 ML20238D4151987-09-0303 September 1987 Evaluation of Engineering Rept ERPT-E0220 Re Reactor Regulation of Util Approach to Compliance W/Reg Guide 1.75 for New Diesel Generator Installation at Plant.Licensee Approach to Demonstrating Compliance Acceptable ML20238B1771987-08-27027 August 1987 Safety Evaluation Supporting Amend 85 to License DPR-54 ML20236E3731987-07-24024 July 1987 Safety Evaluation Supporting Existing & Proposed Mods to Meteorological Program & W/Planned Improvements,Facility Will Satisfy Min Meteorological Emergency Preparedness Requirements of 10CFR50.47 & 10CFR50,Apps E & F ML20205T3021987-03-31031 March 1987 Safety Evaluation Supporting Amend 84 to License DPR-54 ML20205R7871987-03-26026 March 1987 Safety Evaluation Concluding Util 831104 Response to Generic Ltr 83-28,Item 4.5.2, Reactor Trip Sys Reliability On-Line Testing Permits on-line Functional Testing of Sys,Including Diverse Trip Features of Reactor Trip Breakers ML20205C3951987-03-13013 March 1987 Safety Evaluation Re Fracture Toughness Requirements for Protection Against PTS Events (10CFR50.61).Util 860123 Submittal Re Matl Properties & Fast Neutron Fluence of Reactor Vessel Acceptable ML20206B6561987-03-13013 March 1987 Corrected SER Re Fracture Toughness Requirements for Protection Against PTS Events (10CFR50.61).Util 860123 Submittal Re Matl Properties & Fast Neutron Fluence of Reactor Vessel Acceptable ML20205J0971987-03-11011 March 1987 Safety Evaluation Re Sys Selected for Facility Sys Review & Test Program.Sys Constitutes Adequate Scope for Sys Review & Test Program ML20211P2601987-02-19019 February 1987 Safety Evaluation Accepting Util 860116 Request for Amend to License DPR-54,redefining Fire Area Boundaries Required to Be Operable to Separate safety-related Fire Areas & Reassessing Adequacy of Components in Fire Area Assemblies ML20210D1011987-02-0303 February 1987 Safety Evaluation Supporting Issuance of Amend 83 to License DPR-54 ML20215N6881986-11-0404 November 1986 Safety Evaluation Supporting Util Responses to Generic Ltr 83-28,Item 4.4 Re Improvements in Maint & Test Procedures for B&W Plants 1999-08-13
[Table view] Category:TEXT-SAFETY REPORT
MONTHYEARML20211H7921999-08-13013 August 1999 Safety Evaluation Supporting Amend 126 to License DPR-54 ML20195D1901999-05-0606 May 1999 Annual Rept ML20195H8571998-12-31031 December 1998 1998 Annual Rept for Smud. with ML20155D4801998-10-27027 October 1998 Amend 3 to Rancho Seco DSAR, Representing Updated Licensing Basis for Operation of Permanently Shutdown & Defueled Rancho Seco Nuclear Facility During Permanently Defueled Mode ML20248C4301998-05-0606 May 1998 Annual Rept, Covering Period 970507-980506 ML20249A7831997-12-31031 December 1997 1997 Smud Annual Rept ML20198G8271997-08-22022 August 1997 Safety Evaluation Supporting Amend 125 to License DPR-54 ML20217D3271997-07-30030 July 1997 Update of 1995 Decommissioning Evaluation for Rancho Seco Nuclear Generating Station ML20140A6371997-05-0606 May 1997 Annual Rept, Covering Period 960507-970506 ML20140G4481997-05-0101 May 1997 Part 21 Rept Re Potential Defect in Component of Dsrv & Dsr Enterprise Standby Diesel Generator Sys.Recommends That Springs Be Inspected on Periodic Basis,Such as During Refueling Outages ML20137W8151997-03-20020 March 1997 Amend 1 to Post Shutdown Decommissioning Activities Rept ML20141J2711996-12-31031 December 1996 Smud 1996 Annual Rept ML20138L1231996-11-13013 November 1996 Smud Rancho Seco Incremental Decommissioning Action Plan, Rev 0,961113 ML20129E7151996-10-14014 October 1996 Defueled SAR for Rancho Seco ML20029D3561994-03-31031 March 1994 Update of 1991 Decommissioning Cost for Rancho Seco Nuclear Generating Station ML20059H6821994-01-17017 January 1994 Revised Rancho Seco Quality Manual ML20058K3841993-12-0909 December 1993 Part 21 Rept Re Potential Defect in Component of Dsrv & Dsr Enterprise Standby DG Sys,Regarding Potential Problem W/ Subcover Assembled Atop Power Head ML20056E5171993-08-31031 August 1993 Technical Review Rept, Tardy Licensee Actions ML20045B9051993-06-16016 June 1993 Safety Evaluation Re Order Approving Decommissioning Plan & Authorizing Decommissioning of Rsngs,Unit 1,SMUD.Concludes That Reasonable Assurance That Health & Safety of Public Will Not Be Endangered by Decommissioning Option,Provided ML20059K1981993-05-0606 May 1993 Annual Rept, Covering Period from 920501- 930506,consisting of Shutdown Statistics,Narrative Summary of Shutdown Experience & Tabulations of Facility Changes, Tests & Experiments,Per 10CFR50.59(b) ML20034F7031993-02-25025 February 1993 Amend 1 to Enterprise Rept 162 Re Defect on Starting Air Distributor Housing Assembly,As Followup to 930115 Final Rept.Addl Listed Part Numbers Discovered Which Are Higher Level Assemblies of Housing ML20128C9641993-02-0202 February 1993 Informs Commission of Status of Open Issues & Progress of Specified Facilities Toward Decommissioning ML20127H2301993-01-15015 January 1993 Part 21 Rept Re Potential Defeat in Component of Dsrv & Dsr Enterprise Standby DG Sys.Starting Air Distributor Housing Assemblies Installed as Replacement Parts at Listed Sites ML20036C0601992-12-31031 December 1992 1992 Annual Rept for Smud ML20126B0421992-12-17017 December 1992 Final Part 21 Rept Re Potential Problem W/Steel Cylinder Heads.Initially Reported on 921125.Caused by Inadequate Cast Wall Thickness at 3/4-inch-10 Bolt Hole.Stud at Location Indicated on Encl Sketch Should Be Removed ML20125C7161992-12-0707 December 1992 Part 21 Rept Re Possibility for Malfunction of Declutching Mechanisms in SMB/SB-000 & SMB/SB/SBD-00 Actuators. Malfunction Only Occurs During Seismic Event.Balanced Levers May Be Purchased from Vendor.List of Affected Utils Encl ML20127P5861992-11-23023 November 1992 Followup to 921005 Part 21 Rept Re Potential Defect in SB/SBD-1 Housing Cover Screws.Procedure Re Replacement of SBD-1 Spring Cover Bolts Encl.All Fasteners Should Be Loosened & Removed.List of Affected Utils Encl ML20126E6771992-08-0303 August 1992 Rev 7 to Rancho Seco Quality Manual ML20029A7511991-02-28028 February 1991 Suppl to Special Rept 90-13:on 901224,25,29 & 910113,listed Meteorological Instrumentation Inoperable for More than 7 Days.Work Request Initiated & Instrumentation Channels Declared Operable on 910116 ML20029B6721991-02-22022 February 1991 Safety Evaluation Supporting Proposed Rev to Emergency Plan & Granting Exemption from 10CFR50-54(q) Requirements NL-90-451, Monthly Operating Rept for Oct 1990 for Rancho Seco Nuclear Generating Station1990-10-31031 October 1990 Monthly Operating Rept for Oct 1990 for Rancho Seco Nuclear Generating Station ML17348B5061990-10-0909 October 1990 Part 21 Rept Re Zener Diode VR2 on Power Supply Board 9 1682 00 106 Possibly Being Installed Backwards ML20059G9621990-09-10010 September 1990 Safety Evaluation Supporting Amend 115 to License DPR-54 NL-90-443, Monthly Operating Rept for Aug 1990 for Rancho Seco1990-08-31031 August 1990 Monthly Operating Rept for Aug 1990 for Rancho Seco ML20217A5711990-08-28028 August 1990 Final Engineering Rept,Assessment of Spent Fuel Pool Liner Leakage NL-90-439, Monthly Operating Rept for Jul 1990 for Rancho Seco Nuclear Generating Station1990-07-31031 July 1990 Monthly Operating Rept for Jul 1990 for Rancho Seco Nuclear Generating Station 05000312/LER-1990-002, :on 900614,Step 6.9.3.1 of Liquid Waste Discharge Permit Checked R-15017A as Inoperable & Two Independent Samples Not Performed.Caused by Personnel Error. Caution Will Be Added to Step 6.9.21990-07-20020 July 1990
- on 900614,Step 6.9.3.1 of Liquid Waste Discharge Permit Checked R-15017A as Inoperable & Two Independent Samples Not Performed.Caused by Personnel Error. Caution Will Be Added to Step 6.9.2
ML20055F8591990-07-16016 July 1990 Special Rept 90-11:on 900613,06,25,18,21 & 28,fire Barriers Breached More than 7 Days & Not Made Operable in 14 Days. Corrective Actions:Operability of Fire Detectors Verified on One Side of Breached Barriers NL-90-423, Monthly Operating Rept for June 1990 for Rancho Seco Nuclear Generating Station1990-06-30030 June 1990 Monthly Operating Rept for June 1990 for Rancho Seco Nuclear Generating Station NL-90-355, Monthly Operating Rept for May 1990 for Rancho Seco Nuclear Plant1990-05-31031 May 1990 Monthly Operating Rept for May 1990 for Rancho Seco Nuclear Plant ML20055C6291990-05-21021 May 1990 Special Rept 90-08:on 900419,fire Pump Batteries Inoperable When Surveillance Procedure SP.206 Not Performed by Due Date.Caused by Test Frequency Incorrectly Changed from Weekly to Monthly.Surveillance Schedule Revised ML20055C6301990-05-21021 May 1990 Special Rept 90-09:on 900424,25,30,31 & 0502,fire Barriers Inoperable for More than 7 Days,Per Tech Spec 3.14.6.2 Requirement.Hourly Fire Watches Established & Penetrations & Doors Returned to Operable Status ML20058B6521990-05-0404 May 1990 Rev 0 to ERPT-M0216, Property Loss Study for Rancho Seco Nuclear Generating Station in Long Term Defueled Mode ML20042E6921990-03-30030 March 1990 Special Rept 90-06:on 900301,06 & 14,listed Fire Barrier Penetrations That Failed Surveillance Test Not Restored to Operable Status within 7 Days as Required by Tech Spec 3.14.6.2.Operability of Fire Detectors Verified ML20042E6931990-03-30030 March 1990 Special Rept 90-07:on 900228,high Temp Detector Circuit for Zone 53 Not Restored to Operable Status within 14 Days When Circuit Failed Surveillance Test SP.345 & Would Not Alarm. Fire Watch Established.Detector Found Operable on 900316 ML20033G6031990-03-30030 March 1990 Rev 1 to Defueling Training Programs for NRC License Candidates ML20033G6011990-03-30030 March 1990 Rev 1 to Defueled Requalification Training Program for NRC Licensed Operators NL-90-054, Monthly Operating Rept for Feb 1990 for Rancho Seco Nuclear Generating Station1990-02-28028 February 1990 Monthly Operating Rept for Feb 1990 for Rancho Seco Nuclear Generating Station ML20006F4181990-02-0909 February 1990 Special Repts 90-1,90-2,90-3 & 90-4:on 900110,16,18,19,30 & 31,fire Barriers Breached for More than 7 Days.All Fire Barrier Penetrations & Fire Doors Returned to Operable Status NL-90-035, Monthly Operating Rept for Jan 1990 for Rancho Seco Nuclear Generating Station1990-01-31031 January 1990 Monthly Operating Rept for Jan 1990 for Rancho Seco Nuclear Generating Station 1999-08-13
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SAFETY EVALUATION BY THE OFFICE,0F NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO. 90 TO FACILITY OPERATING LICENSE NO. DPR-54 SACRAMENTO MUNICIPAL UTILITY DISTRICT RANCHO SECO NUCLEAR GENERATING STATION DOCKET NO. 50-312
1.0 INTRODUCTION
On August 13, 1986, the Commission issued to Sacramento Municipal Utility District (the licensee) Amendment 82 to Facility Operating License
.No. DPR-54. This amendment incorporated Low Temperature Overpressure Protection (LTOP) criteria into the Technical Specifications (TS).
Subsequently it became evident that Amendment 82 was deficient in not providing for venting and surveillance testing of the LTOP system. 'By letter dated April. 23, 1987 the licensee request an amendment to correct this deficiency in Amendment 82. Additionally, the licensee requested specific minimum flow rate' criteria for the emergency heating, ventilation,.
and air conditioning (HVAC) system in the Nuclear Service Electric.
Building (NSEB).
The LTOP and HVAC TS changes were evaluated separately and are addressed below. The Safety Evaluation (SE) related to LTOP included under Section 1
2.0 and the HVAC SE is ' included under Section 3.0.
2.0 Evaluation Relating To Technical Specification Changes For The Low Temperature Overpressure Protection As stated above, License Amendment No. 82 dated August 13, 1986 incorporated requirements for the operation of the Low Temperature Overpressure Protection System (LTOPS) into the Rancho Seco.TS. However, I
inadvertently, these new TS did not allow filling and venting the reactor coolant system (RCS) or for periodic maintenance. To make these allowances-l and to more clearly define the LTOPS enabling operation, SMUD proposed in its April 23, 1987 submittal to add five subsections to TS 3.2.2. and two paragraphs.to its Bases. These subsections are 3.2.2.1.1, 3.2.2.2.1, L
3.2.2.2.2, 3.2.2.2.3, and 3.2.2.5.1.
one of the added paragraphs in the i
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Base injection lines filling; the other concerns concerns the maintenance and surveillance testing of the Core Flood System.
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Subsection 3.2.2.1.1 would define the LTOPS enabling operation.
Subsections. 3.2.2.2.1, 3.2.2.2.2 and 3.2.2.2.3 would make=it possible to i
fill and vent the. injection lines without violating the TS and subsection 5
3.2~.2.5.'1 would. allow maintenance and surveillance testing on the Core 1
Flood System.
For the filling and venting'of the injection lines, only one of the motor.
operated valves in the High Pressure Injection (HPI) system may open at-any time. During the filling and venting, all HPI-Makeup pump breakers.
shall be racked out and tagged. Nitrogen overpressure in the Makeup tank.
provides the motive force for fluid flow during the filling and' venting.
This overpressure is limited by a relief valve on the Makeup. tank. This is set at 100 psig, which is insufficient to cause a low temperature overpressurization.
q When the Core Flood Tank pressure is below 500 psig, which is the setpoint for the Low Temperature Overpressure Protection System, water from this tank cannot cause a low temperature overpressurization.
Since there is no need to. maintain the core flood discharge valves closed, the licensee proposed to revise TS to allow the: discharge valves to remain open or be opened below 500 psig.
The staff finds that there are sufficient precautions in the proposed subsections to make a low temperature overpressurization highly unlikely l
during the filling and venting of the injection lines and during.the I
maintenance and testing of the Core Flood System. Therefore, the staff concludes that the Sacramento Municipal Utility District's proposed changes to Rancho Seco Technical Specification 3.2.2 are acceptable.
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3.0 EVALUATION RELATING TO TECHNICAL SPECIFICATION 4.31, " NUCLEAR SERVICE ELECTRICAL SUILDING EMEE6tNGY HEALING VENTILATION AND AIR LONDlIIONING" By letter dated April 23, 1987, the licensee proposed an amendment to l
revise Technical Specification 4.31, " Nuclear Service Electrical Building i
Emergency Heating Ventilation and Air Conditioning". The purpose of the proposed revision is to establish a minimum flow rate requirement for Nuclear Service Electrical Building (NSEB) emergency Heating Ventilation and Air Conditioning (HVAC) air handling unit to be used in place of the present value with its minimum /maxirrum to tolerance. The proposed revision would change the wording from "...a flow rate of 24,500 cfm 10 i
percent" to "...a minimum flow rate of 24,500 cfm," and would revise the wording in the Bases from "The air flow of 24,500 cfm..." to "The minimum air flow of 24,500 cim..".
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- i NSEB houses nuclear service batteries, switchgear, battery chargers, and the necessary electrical equipment required to support.the TSC, control room, and the HVAC system.
The NSEB is served by nonnal-essential (backup) ventilation systems. The normal system consists of two air conditioning units, two normal:
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return exhaust fans, two ventilators, and one unit heater. The essential system is made up of two condensing units and two direct expansion coils with a supply fan. The minimum design capacity of the NSEB essential HVAC fan is 24,500 cfm. The licensee stated that the proposed change would ensure that the surveillance standards for the NSEB emergency HVAC unit agree with technical specification bases for system performance.
The licensee stated the following in the support of the proposed change for the NSEB Emergency HVAC air handling unit to maintain the minimum flow rate of
-24,500 cfm:
"This air flow rate was selected to limit the temperatures in the NSEB building to 80 F maximum. Air flow is verified once per 31 days by initiating flow through the essential air handling unit. This amendment changes the tolerance on the unit by eliminating the t[10] percent condition and. requiring a minimum of flow rate of 24,500 cfm as specified in technical specification bases. A higher flow rate will enhance the i
capability of the system to maintain the designed temperature in the NSEB
[to ensure adequate cooling]. Any noise resulting from hi l
is not a factor since it is not a normally occupied area. gher flow rates Therefore, this change has no effect on the safety function of the NSEB air handling unit."
Additionally, the licensee stated that this change has no effect on the safety function of the NSEB Emergency HVAC, and it does not introduce a new failure mode, involve any accident previously evaluated, nor reduce any margins of safety.
The staff has reviewed the above change and supporting rationale and concludes
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that the proposed charge to the NSEB HVAC surveillance standard more clearly I
specifies the required flow rate, and it eliminates the tolerance in flow rate, which agrees with technical specification base.
Based on the above, the staff concludes that the proposed change places a minimum flow requirement, which is more ennservative in nature, on the NSEB emergency HVAC system and will not have any adverse effects on plant opera tion. The staff, therefore, finds the proposed NSEB Emergency HVAC system technical specification change acceptable.
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4-r 4.0._ CONTACT WITH STATE OFFICIAL I
The NRC staff has advised the Chief of the Radiological Health Branch, State Department of Health Services, State of California, of the proposed determination of no significant hazards consideration. No comments were received.
5.0 ENVIRONMENTAL CONSIDERATION
The amendment involves changes in the installation or use of facility components located within the restricted area.
The staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupation radiation exposure. The Commission has previously
. issued proposed findings that the amendment involves no significant hazards consideration, and there has been no public comment on such finding. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR Sec. 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of the amendment.
6.0 _ CONCLUSION Based upon our evaluation of the proposed changes, we have concluded that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted _in compl1ance_with:the. Commission's -
regulation' and'(3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of'the public.
We, therefore, conclude that the proposed changes are acceptable.
Principal Contributors:
E. Lantz J. Raval Dated:
November 13, 1987 i
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