ML19280A255
| ML19280A255 | |
| Person / Time | |
|---|---|
| Issue date: | 08/21/1980 |
| From: | Minogue R NRC OFFICE OF STANDARDS DEVELOPMENT |
| To: | |
| Shared Package | |
| ML19280A256 | List: |
| References | |
| FRN-43FR56677, FRN-45FR71761, RULE-PR-20, TASK-CC, TASK-SE SECY-80-392, NUDOCS 8009100225 | |
| Download: ML19280A255 (17) | |
Text
e UNITED STATES NUCLEAR REGULATORY COMMISSION August 21, 1980, WASHINGTON, D. C. 20s55 SECY-80-392, CONSENT CALENDAR ITEM F_or:
The Commissioners From:
Robert B. Minogue, Director Office of Standards Development Thru:
Executive Director for Operations
Subject:
FINAL RULEMAKING ON BURIAL 0F SMALL QUANTITIES OF RADIONUCLIDES:
DELETION OF 10 CFR S 20.304 Purcose:
To obtain Commission approval of final rulemaking deleting 10 CFR 20.304.
Category:
Minor policy question.
Issue:
Should licensees be required to obtain specific approval prior to bury-ing small quantities of radionuclides?
Backcround:
NRC regulations (10 CFR g 20.304) currently allow licensees to bury small quantities of radionuclides anywhere withcut notification or specific approval from NRC.
The Commission has proposed deletion of 10 CFR S 20.304 (43 FR 56677, December 4, 1978, Enclosure "A").
When the staff recommended this deletion (SECY-78-536), it pointed out that:
1.
There is a slight possibility that a person accidentally disturbing such a burial could receive radiation doses in excess of NRC limits.
2.
Many State officials have expressad concern to NRC cver the permis-siveness of S 20.304.
3.
There are many uncertainties essociated with assessing the risk of burials under 3 20.304.
4.
Deletien of S 20.3C4 would contribute to the protection of the public health by improving the NRC'c
...iable data regarding amounts and locations of buried radicactive materials.
Contact:
John Hickey, SD 443-5966
.8'0 0 9 1 0 0 26
t The Commissioners 2
Deletion of S 20.304 would have the effect of requiring all proposed burials to receive prior NRC review and approval under S 20.302, which now applies to disposal of larger quantities of radionuclides.
Licensees currently using S 20.304 would have to apply for this approval, or use an alternative disposal method such as shipment of waste to commercial burial grounds.
Discussion:
Thirty-eight sets of comments were received concerning the proposed deletion of 6 20.304.
Seventeen commenters favored deletion, fourteen opposed deletion, and seven took no clear position.
The major comments opposing deletion of S M.304 are summarized as follows:
1.
Burials under 6 20.304 do not represent a public health problem.
2.
Shipment of waste to commercial burial grounds would be too expensive.
3.
There is some risk associated with shipments to commercial burial grounds, and in any case, the commercial burial grounds are already overburdened.
4.
The criteria for obtaining prior approval of burials pursuant to S 20.302 should be outlined.
The staff had anticipated all of these issues prior to recommending deletion of 6 20.304.
Having reviewed all public comments, we maintain that (1) licensees should either obtain prior approval for waste burial or use an alternative disposal method such as shipment of waste to commercial burial grounds and (2) deletion of S Pu.304 would not place an unreasonable burden on licensees or commercial burial grounds.
The enclosed proposed Federal Register notice of deletion of S 20.304 (Enclosure "B") contains a discussion of all major comments received on the proposed rule.
The final Value/ Impact assessment (Enclosure "C") includes a discussion of all comments.
The staff originally estimated that fewer than 100 licensees (out of about 8,000 NRC licensees and 12,000 Agreement States 1icensees) are performing 6 20.304 burials.
All NRC licensees were notif~.ad directly of the proposed deletion of S 20.304, and only 10 sent in comments stating that they used S 20.304.
Therefore, the staff maintains its original assessments from SECY-78-536 that fewer than 100 licensees will be af#ected by deletion of 6 20.304, and that the impact on staff resources for processing applications for specific approvals of burials will be minimal.
About 12,000 Agreement States licensees will be indirectly affected by the final rule.
Agreement State licensees are not subject to NRC regu-lations, but must comply with individual State regulations, which
The Commissioners 3
must be compatible with NRC regulations.
Agreement State officials were among the first to suggest deletion of 20.304, and they have con-sistently supported deletion.
Several Agreement States have already deleted 20.304-type provisions from their regulations without waiting for action by NRC.
We expect the remaining States to make compatible changes in their regulations after NRC takes final action.
Recommendation:
That the Commission:
1.
Aporove publication in the Federal Register of a notice of deletion of 10 CFR S 20.304 (Enclosure "B").
2.
Note that the amendments will not affect radioactive material already buried, generally licensed and exempt material, or licen-sees who already have specific license conditions to perform burials pursuant to 10 CFR S 20.302.
3.
Note that all NRC licensees and Agreement States will be notified of this action.
Licensees using 9 20.304 will have three months to make alternative disposal arrangements or to comply with pro-visions of 6 20.302.
4.
Note that deletion of 6 20.304 will not have a significant impact on the environment, and an environmental statement or appraisal need not be prepared.
5.
Note that clearance of the amendment by the General Accounting Office is required.
A preliminary value-impact assessment and report justification analysis have been approved by the Paperwork Reduction Subgroup of the Standing Committee on Regulatory Effec-tiveness.
The updated assessment (Enclosure "C") will be used as the basis for obtaining GA0 clearance.
6.
Note that the Senate Committee on Environment and Public Works, the House Committee on Interior and Insular Affairs, the House Committee on Government Operations, and the House Committee on Interstate and Foreign Commerce will be informed of this action.
Coordination:
The Offices of Nuclear Material Safety and Safeguards, State Programs, Inspection and Enforcement, and Nuclear Reactor Regulation concur in the recommendation to delete 10 CFR g 20.304.
The Office of Public
The Commissioners 4
Affairs recommends that ns public announcement be issued.
The Execu-tive Legal Director has no legal cbjection.
.hrkdl3, W s Robert B. Minogue, Di r
Office of Standards Development
Enclosures:
"A" Proposed Rule, Published 12/4/78 "B" - Proposed Federal Register Notice Deleting a 20.304 "C" - Value-Impact Assessment Commissioners' comments or consent should be provided directly to the Office of th9 Secretary by c.o.b. Monday, September 8,1980.
Commission Staff Office comments, if any, should be submitted to the Commissioners NLT August 29, 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 comment, the Commissioners and the Secretariat should be apprised of when comments may be expected.
This paper is tentatively scheduled for affirmation at an Open Meeting during the Week of September 15, 1980.
Please refer to the aporopriate Weekly Commission Schedule, when published, for a specific date and time.
DISTRIBUTION Commissioners Commission Staff Offices Exec Dir for Operations ACRS Secretariat
56677 proposedrules m.
_ _,m ms_. -.. ~
~
_, ~...
(7590-01-M]
Appendix C of Part 20:(b) burialis at grounds and by improving the NRC's a minimum depth of four feet: and (c) available data regarding amounts and NUCLEAR REGULATORY successive burials are separated by dis-locations of radioactive materials COMMI5510N tances of at least six feet and not more buried elsewhere.
than 12 burials are made in any year.
Examples of public comments which DO CTR Pen 20]
Section-20.302 of 10 CFR Part 20 would be particularly helpful to the STANoalos Poa PsoftC71CN AGAINST specifies the method for obtaining ap-Commission are: information on the RAD, ANON proval of proposed burials other than numbers of burials currently being those allowed by I:0.304 conducted pursuant to 120.304. the swiel.s 5 a ovenHvin.# t.diennndu Section 20.304 has not been amend. quantities and types of radionuclides AOENCY. U.S. Nuclear Regulatory ed since its adoction in 1957, although buried, estimates'of the potential risk Commission.
there have been amendments to Ap.
to the public health from such burials, pendix C of 10 CFR Part 20, which is and estimates of the costs to Ucensees ACTION: Proposed rule.
referenced in I:0.304. The preposed if l 20.304 were deleted.
SUMMARY
- The Nuclear Regulatory amendment discussed below was devel-If. after consideration of the factors -
Commission (NRC) is considering oped as part of an ongoing Commf t-relating to this matter including com-amending its rcgulations to require sion effort to review existing regula-ments or suggestions submitted in re-NRC licensees to obtain Commission tions on disposal of low. level radioac-sponse to this notice of proposed tule approval prior to burial of amm!! quan, tive waste.
making. the Commission decides to titles of radionuelldes. The proposed Because burials under I:0.304 may promulgate the rule in effective form, amendments T ould contribute to the be performed without specific NRC a period of three (3) months would be protection of the publ!c health by en.
approval the Commission does not provided for I!censees currently con-couraging the shipment of small quan. have exact data on such burials. How-ducting disposal by burial in soil pur-titles of radioactive wa.ste to licensed ever, based on informal discussions suant to 1 20.304 to make alternative burial grounds and by improving the 5'.th NRC inspectors and State off!. disposal arrangements or to comply NRC's avanable data regarding cials, the Commission staff has esti. with the provisions of I:0.302.
amounts and locations of radioactive mated that relatively few licensees These amendments would not ze-materials buried elsewhere. The (less than 100 out of several thousand quire any action concerning material amendments would not affect material NRC and Agreement State Ucensees) already buried under the present pro-already buried. or generally Ucensed have performed burials under 120.304 visions of 120.304.
and exempt material.
over the last few years. Examples of 11-It is not the intent of the proposed censees performing burials include ma-amendments to change procedures re.
DATES: Comment period expires Feb-tertals licensees (such as some univer-garding the disposal of materials or ruary 2.1979.
sities) who possess relatively small products transferred to per:ons ADDRESSES: Written comments quantities of radionuclides.
exempt or generally licensed.
should be submitted to the Secretary Representatives of several State The proposed amendments consti-of the Commission. U.S. Nuclear Reg-agencies have expressed concern to tute a procedural change which is not ulatory Comm% tion. Washington. D.C.
the Commission over the practice of likely to have a substantial impact on 20555. Attention: Docketing and Serv-allowing licensees to bury small quan-the method or number of burials of ra-Ice Branch.
tities of radionuc1! des without not!!!- dfonuclides. Information available to FOR FURTHER INFORMATION cation or prior approval of the Com-the Commission indlestes that.only a CONTACT:
mission or its Agreeznent States. These few !!censees would be affected by the State representatives suggest th:.5 the amendments. However, it is possible Mr. John W.
Hickey. Office of risk of allowing such burials may be that as a result of Commission review Standards Development. U.S. Nucle-unacceptable.
of individual burial proposals or as a at Regulatory Commission. Wash-The Commission agrees that the ex-result of increased shipments to !!.
Ington, D.C. 20555 (pnone: M9-443-isting practice should be revised, and censed burial grounds the potential 5966).
M would like to obtain public comments emtronmental impact will be reduced.
SUPPLEMEN'I*ARY INFORMATION: before making a decision on whether Therefere. the Commission has deter-Not!ce is hereby given that the Nucle. to allow continued disposal of radioac-mined that an environmental impact at Regulatory Commission proposes to tive material under I 20.304 without statement pursuant to the National ucand the rtrulat.cos in 10 CFR Part prior regulatory review. The proposed Environmental Polley Act of 1969 need
- 20. "Staccatas Ier Protection Against amendments would limit burials to not te prepared in connection with Radiation." to revise the provisions for two circumstances: t1J v/here the !!-
the promulgation of these amend-disposal of small quantitles of licensed censee has obtained prior Commissicn mem.:. because their adoption will not radioactive material by burial in soil.
approval as provided in 10 CFR significantly affect the quality of the Section 20.304. 10 CFR Part 20. cur-3:0.302 or (2) where ths licensee human environment.
rently provides that no licensee shan transfers such material to authori:ed Pursuant to the Atomic Energy Act dispose of Ucensed =sterial by burial recipients
( e.g.,
licensed burial of 1954. as amended, the Energy Reor-in soil unless: (a) the total quantity of grounds). The effect of the proposed ganlaation Act of 1974, a.s amended.
licensed and other radioactive materi-amendments may be to contribute to and sect!an 553 of title 5 of the United als buried at any one locat!on and time the protection of pubile health by en-States Code, notice is hereby given does not exceed, at the time of burial. couraging the shipment of even sman that adoption of the foilowing amend-1.000 times the amount specified in quantities of waste to 11:ensed burial ments tn 10 CFR Part 20 is contem-rt:t2At arcistra. VCt. 43. NO. 233-MCNoAY, CECIM512 4,1973 9
En h w e A,,
s plated. All interested persons who $ 20.401 Records of surveys, radiation Arrcena C monitonng. and disposal.
desire to submit written comments or
+
e suggestions for consideration in con.
nection with the proposed rule should NoTL-For purposes of 100.003 where send them to the Secretary of the (b) Each licensee shall maintain rec.
there is involved a combmation of isotopes in knout 2 amounu. the limit for the comes.
Cormittion. C.S. Nuclear Regulator 7 ords in the same units used in this nauen should be denved as fot: owr Deter.
Commission. Washington. D.C. 20555 part, showing the results of surveys re-nne, f r esen is t ce in the combmanon.
Attention: Docketing and Service quired by $ 20.001(b). monitoring re-Branch. by february 2.19 79.
quired by if 20.205(b) and 20.205(c).
fne ce tr t1NNeS$ ot[e$ $
and disposals made under !! 20.302, tablished for the specte isotope when not in combination. The sum of sucts ratios for f 20.304 (Deletedl 20.303. and deleted 20.304.s a:3 the isotopes in the combinauen may not
- 1. Section 20.304. Disposci by burial ge3 exceed "1* (1.e "umty").
in sof t. is deleted.
' 2. Section 20.301(c) is revised to read ISectjen 161, b. and ! Pub. L.83-703, 68 as follows:
(3) Records of disposal of licensed Stat. 94s: Sec. 201. Pub. I.93-438, 88 Stat.
material made pursuant to $$ 20.302.
1:43. (42 U.S.C. 2:01. 5841).)
50.301 General requirement.
20.303, and deleted 20.304 ' shall be Dated at Washington, D.C. this :Sth maintained until the Commission au.
day of November 1978.
thorizes their disposition.
For.the Nuclear Regulatory Com-(c) As provided in f 20.303. appI! cable
- 4. A footnote is added to section to the disposal of licensed material by 0.401 to read as follows:
mission.
release into san!tary sewerage systems.
Surec. J. CHII.E.
or in ( 20.106 (Radioactivity in ef.
'Sectien 20.304 provided for bunal of Secretary of the. Commission.
small cuanuties of licensed materials in set!.
fluents to unrestricted areas).
Nottee of its deletion appears in (Feders!
[TR Doc. 78-33746 Filed 12178; 8:45 aml
- 3. Section 20.401(b) and subpara-Rmter pase and date to be imemd).
graph (3) of paragraph (c) are amend.
$. The note following Appendix C of ed to read as fo!!ows:
10 CFR Part 20 is amended to read as follows- '
[7590-01]
NUCLEAR REGULATORY COMMISSION
[10 CFR Part 20]
STANDARDS FOR PROTECTION AGAINST RADIATION Burial of Small Quantities of Radionuclides AGENCY:
U.S. Nuclear Regulatory Commission ACTION:
Final Rule
SUMMARY
The Nuclear Regulatory Commission (NRC or Commission) is amending its regulations to delete 10 CFR S 20.304, which currently provides that licensees may bury certain small quantities of radionuclides without prior approval.
Licensees currently performing burials pursuant to S 20.304 will have 90 days to halt burials and apply for specific approval to resume burials pursuant to 10 CFR S 20.302, or use alternative disposal methods, such as transfer of waste to licensed commercial burial grounds.
DATES:
The effective date of deletion of 10 CFR S 20.304 is (90 days after publication).
Note:
The Nuclear Regulatory Commission has submitted this rule to the Comptroller General for such review as may be appropriate under the Federal Reports Act, as amended, 44 U.S.C. 3512.
The date on which the reporting requirement of thiu rule becomes effective, unless advised to the contrary, accordingly, reflects inclusion of the 45-day period which that statute allows for such review (44 U.S.C. 3512(c)(2)).
1 Enclosure "B"
[7590-01]
FOR FURTHER INFORMATION CONTACT:
Mr. John W. Hickey, Office of Standards Development, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555 (phone:
301-443-5966).
SUPPLEMENTARY INFORMATION:
On December 4, 1978, the Nuclear Regulatory Commission proposed to delete 6 20.304 of 10 CFR Part 20, " Standards for Protection Against Radiation" (43 FR 56677).
Section 20.304 allows licensees to bury certain small quantities of radionuclides without prior NRC approval.
As discussed in the notice of proposed rulemaking, several State representatives have suggested that the risk from burials of radioactive waste allowed by 6 20.304 may be unacceptable.
The quantities of radio-nuclides allowed to be buried pursuant to $20.304 are 1,000 times greater than exempt quantities.
Such quantities pose a small risk if they are properly buried and left undisturbed, particularly if they are dispersed through a large volume of waste material.
However, 9 20.304 imposes no concentration limits, and the quantities as concentrated " point sources" are potentially large enough to cause excessive radiation exposures if the radioactive material is mishandled, improperly buried, or disturbed after burial.
For example, S 20.304 allows burial of up to one milli-curie of cobalt-60.
As a point source this quantity delivers a dose rate of over 100 millirems per hour at a distance of 10 centimeters.
If a burial site were disturbed, and a person came into contact with one milli-curie of cobalt-60 for an extended period, an overexposure could occur.
The Commission has concluded that it is inappropriate to continue generic authorization of burials pursuant to $20.304 without regard to such factors 2
Enclosure "B"
[7590-01]
as location of burial, concentrations of radioactive material, form of packaging, and notification of NRC.
Therefore, the Commission will require that licensees obtain prior approval for new burials of the type currently allowed by 6 20.304, and accordingly 5 20.304 is being deleted from NRC regulation:.
Prior review of burials will result in improved records regarding amounts and locations of future burials of radioactive material, and provide greater assurr.qce that buried material will not present a health hazard at a later date.
Thus the risk of exposure of individuals accidentally disturbing buried radioactive waste would be reduced.
The Commission staff estimates that fewer than 100 licensees (out of about 20,000 of NRC and Agreement State licensees) are performing burials-allowed by 9 20.304.
NRC licensees will have 90 days to halt burials and apply for specific approval to resume burials pursuant to 10 CFR 9 20.302, or use alternative disposal methods such as transfer of waste to licensed commercial burial grounds.
The NRC staff will provide information to licensees as appropriate related to obtaining approval for buricis.
Deletion of 10 CFR S 20.304 will not affect material already buried, generally licensed and exempt material, or licensees who have already obtained specific approval to perform burials pursuant to 10 CFR 9 20.302.
Agreement State licensees will not be directly affected by the final rule, because they are subject to individual State regulations rather than NRC regulations.
However, Agreement State officials have been con-sistently supportive of deletion of 20.304, and the Commission anticipates that those States which have not already done so will make changes in their regulations compatible with deletion of 20.304.
3 Enclosure "B"
[7590-01]
As discussed in the notice of proposed rulemaking, the Commission has determined that an environmental impact statement need not be prepared because deletion of 10 CFR 6 20.304 will not significantly affect the quality of the human environment.
Public Comments In reaching the decision to delete 6 20.304, the Commission considered public comments received on the proposed rule change.
These comments and the impact of deletion of 6 20.304 are discussed in the value-impact assessment, which is available for inspection or copying for a fee at the NRC Public Document Room, 1717 H Street, Washington, D.C. 20555.
The major public comments received are discussed below.
Thirty-eight sets of public comments were received on the proposed deletion of 6 20.304.
Seventeen commenters favored deletion, fourteen opposed deletion, and seven took no clear position.
The major comments opposing deletion are:
(1) burials pursuant to 6 20.304 do not represent a public health problem, (2) disposal of wastes at commercial burial grounds is not a good alternative because it is too expensive, it carries its own risks, and the commercial sites are overburdened, and (3) NRC has not adequately outlined requirements for obtaining specific approvals for burials.
1.
Public health risk.
Several comments from institutions perform-ing burials pursuant to 6 20.304 provided information on their operations, indicating that their burial sites are safe because they are owned by the licensee, fenced and marked, located in areas of low risk of ground water contamination, or contain short-lived radionuclides in waste with 4
Enclosure "B"
[7590-01]
low specific activity.
Nevertheless, as discussed previously, the radio-nuclide quantities involved are potentially large enough to cause signifi-cant radiation exposures, if they are concentrated point sources, and the Commission has decided that case-by-case review of proposed burials is appropriate.
2.
Commercial burial grounds.
Many commenters incorrectly inter-preted the proposed rule to mean that local burial would be prohibited, and that all waste would have to be shipped to commercial burial grounds.
The Commission is not requiring that all radioactive waste affected by deletion of S 20.304 be shipped to commercial burial grou.tds.
Licensee proposals for waste disposal will be reviewed on a case-by-case basis, including consideration of risk and economic costs.
This is consistent with 10 CFR S 20.1(c) which provides that licensees should make every reasonable effort to maintain radiation exposures as low as is reasonable achievable, where "as low as is reasonable achievable" includes taking into account economics of improvement in relation to benefits to the public health and safety.
Several licensees performing burials pursuant to S 20.304 com-mented that it would be too expensive to ship wastes to commercial burial sites, and that in any case the sites are already overburdened.
Estimates of the extra costs and volumes of waste involved ranged from $400 to $21,000 and 70 to 2000 cubic feet per year.
It should be noted that:
(1) the staff estimates that fewer than 100 licensees are performing burials pursuant to S 20.304, (2) until recently about 3,000,000 cubic feet of radioactive waste were being shipped annually to commercial sites, and (3) many insti-tutions similar to those using 6 20.304 are using commercial disposal sites.
Therefore, while certain licensees may wish to dispose of high-5 Enclosure "B"
[7590-01]
volume, slightly contaminated waste by local burial for justifiable economic reasons, in many cases licensees could ship low-volume waste to commercial sites at reasonable cost without adding significantly to the total volume accepte' at the sites.
The Commission recognizes problems associated with closures or reduced capacity of ccmmercial burial grounds.
This issue affects all licensees disposing of low-level radioactive waste, not just burials pur-suant to S 20.304.
The Commission staff will, of course, take into account the status of commercial burial sfi.es in making any ?icensing decisions regarding disposal of radioactive waste.
3.
Criteria for disposal.
As discussed in the notice of proposed rulemaking, the Commission is reviewing existing policy on disposal of low-level radioactive waste and developing new regulations.
These will be published in separate notices of proposed ru7emaking.
Until new regulations are developed, applications for waste disposal will be reviewed according to 10 CFR S 20.302, which requires licensees to submit information describing the waste material, the levels of radioactivity involveo, the proposed conditions of disposal, the environment of the disposal site, and procedures to be observed to minimize the risk of unexpected or hazardous exposures.
Effective Rule Pursuant to the Atomic Energy Act of 1954, as amended, the Energy Reorganization Act of 1974, as amended, and section 553 of title 5 of the United States Code, the following amendments to Title 10, Chapter I, Code of Federal Regulations, Part 20, are published as a document subject to codification.
6 Enclosure "B"
[7590-01]
s 20.304 1.
Section 20.304, Disposal by burial in soil, is deleted.
2.
Section 20.301(c) is revised to read as follows:
5 20.301 General requirement.
=
=
c.
As provided in 6 20.303, applicable to the disposal of licensed caterial by release into sanitary sewerage systems, or in S 20.106 (Radio-activity in effluents to unrestricted areas).
3.
Section 20.401(b) and subparagraph (3) of paragraph (c) are amended to read as follows:
6 Records of surveys, radiation monitoring, and disposal.
m a
(b) Each licensee shall caintain records in the same units used in this part, showing the results of surveys required by 5 20.301(b), coni-toring required by sf 20.205(b) and 20.205(c), and disposals made under ss 20.302, 20.303, and deleted 20.304.1 (c) n n
s x
s (3) Records of disposal of licensed material made pursuant to ss 20.302, 20.303, and deleted 20.3041 shall be maintained until the Co mission authorizes their disposition.
4.
A footnote is added to sectior. 20.401 to read as follcws:
7 Enclosure "B"
[7590-01]
2Section 20.304 provided for burial of small quantities of licensed materials in soil.
Notice of its deletion appears in (Federal Register page a,1d date to be inserted).
5.
The note following Appendix C of 10 CFR Part 20 is amended to read as follows:
APPENDIX C NOTE.
For purposes of S 20.303, where there is involved a combina-tion of isotopes in known amounts, the limit for the combination should be derived as follows.
Determine, for each isotope in the combination, the ratio between the quantity present in the combination and the limit otherwise established for the specific isotope when not in combination.
The sum of such ratios for all the isotopes in the combination may not exceed "1" (i.e., " unity").
(Section 161, b. and i., Pub. Law 83-703, 68 Stat. 948; Sec. 201, Pub. Law 93-438, 88 Stat. 1243, (42 U.S.C. 2201, 5841).)
Dated at this day of 1979.
For the Nuclear Regulatory Commission.
Samuel J. Chilk Secretary of the Commission 8
Enclosure "B"