ML20035A235
| ML20035A235 | |
| Person / Time | |
|---|---|
| Issue date: | 12/24/1992 |
| From: | Kammerer C NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Alkema K UTAH, STATE OF |
| References | |
| NUDOCS 9303250025 | |
| Download: ML20035A235 (13) | |
Text
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\\o UNMID STATES Qj g
8 NUCLEAR REGULATORY COMMISSION
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December 24, 1992 a
Mr. Kenneth Alkema Executive Director Department of Environmental Quality 288 North 1460 West Salt Lake City, UT 84114-4850
Dear Mr. Aliema:
This is to inform you of our additional concerns and quer,tions regarding the State's rationale for its exemption of Envirocare from the site ownership requiremera. As discussed in my September 2,1992 letter to you, I indicated that I wo9d contact you so that we may bring this issue to closure. The staff has completed their review of the Land Ownership Exemption document dated May 8,1992, the final revision of Section 10 of the Envirocare License Amendment Application dated July 15, 1992, and the final Trust Agreement.
In its request to the NRC for an amended Agreement, the State made a commitment to implement a regulatory program for land disposal of low-level radioactive waste (LLRW) that would be adequate to protect public health and safety and compatible with that of the NRC. Historically, LLRW disposal operators have been unprepared for the type and magnitude of maintenance problems that have arisen during and after site closure, and have been unable to cope, even to the point of abandoning the site. These maintenance problems have led to economic and social resource commitments that were not originally anticipated. Sufficient funds were not available to repair the maintenance problems, and there was no one who was clearly responsible for the site that
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was abandoned. NRC regulations,10 CFR Part 61, upon which the Utah regulations are based, were designed to avoid the maintenance problems which led to economic resource and responsibility issues, and the economic and responsibility issues themselves.
The requirements for government ownership and for financial surety are an integral part of the LLRW regulatory requirements which specifically attempt to prevent maintenance problems, and economic and responsibility issues, during and after site closure. Requirements for site characterization, waste form and packaging, and site design and operation, are provided in an attempt to avoid the type of maintenance problems which plagued Maxey Flats, et al.
The land ownership and financial assurance requirements work with those requirements listed above, to provide assurance of public health and safety once the site is closed. The trust agreement provided by Envirocare is designed to assure protection of the public health and safety, with funding for surveillance, monitoring and funding to provide for third party closure in P
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Kenneth Alkema 2
DEC 2 41992 k
the event that Envirocare " unilaterally withdraws" from site operations.
In theory, this is designed to result in a similar situation to that furnished by government ownership, for the period of active institutional control. But as noted in the enclosure, this does not address the lack of clear ownership and any changes necessary with respect to licensing procedurcs. Also, the trust fund that Utah proposes as a replacement for government land ownership is already required in existing regulations in addition to land ownership, not in place of it.
Furthermore, as the State has noted, the government land ownership requirement is based in part on the likelihood that government will outlast private entities, providing long-term control of a site. This is a key issue with respect to both active and passive institutional controls.
In the Draft EIS for 10 CFR Part 61 it states that the most significant concepts for long-term passive institutional control are those of control of the land by a governmental organization, land-use restrictions in the form of titles or deeds, and multiplicity of records. Although active institutional controls cannot be relied upon for more than 100 years, this does not preclude the importance of passive institutional controls with respect to the continued protection of the health and safety of the public, continued control of the site, protection of the inadvertent intruder, and protection of disposal site integrity. The Land Ownership Exemption rationale should show how the substitute mechanism would provide adequate controls comparable to governmental land ownership, or that the hazard present at this site is significantly less than that contemplated by Part 61 because of the nature of the waste being disposed of, and therefore, the public health and safety will be adequately protected without the land ownership provision.
Also, since we issued our review letter, the NRC has received a petition from US Ecology, Inc. for Review and Suspension or Revocation of Utah's Agreement State Program for Failure to Require State or Federal Site Ownership at the Envirocare of Utah, Inc. Low-Level Radioactive Waste Facility filed by letter dated September 21, 1992. This Petition requests the NRC to revoke or suspend Utah's Agreement State status under section 274 of the Atomic Energy Act for failure to require Federal or State land ownership at the Envirocare of Utah, Inc. LLRW disposal facility. As a basis for the US Ecology request, the Petition alleges that (1) under both Utah's Agreement State program and the Federal LLRW regulatory program,: LLRW may not be disposed of on privately-owned land unless the State in which the site is located or the Federal Government has formally expressed a willingness to accept title to the facility at site closure; (2) the Envirocare site is located on privately-owned land; and (3) neither Utah nor the U.S. Department of Energy has agreed to or expressed any willingness to accept title to the site.
Please note that the receipt of the Petition was published in the Federal Reoister on November 13, 1992, and I have enclosed a copy for your review and response as appropriate.
I will be issuing a determination on the US Ecology request within a reasonable time after receipt of your response and my review of these issues.
l
h Kenneth Alke:a 3
In order for me to carry out sty responsibilities with respect to this Petition, and to resolve the issues I have raised in the past, I have enclosed additional coments and a request for information, based on our review of information supplied by both the State and the licensee on the issue of land ownership.
It is requested that your response be given the highest priority.
We realize that responding to the entire letter.will take considerable however we feel that a quick response to items 2, 3 and 4 could occur w. time, ithin the next 30 days or earlier.
I look forward to your timely responses and please do not hesitate to call me t
if you have any questions.
I can be reached at 301-504-2321.
S ncerely b
h Carlton Kamerer, Director i
Office of State Programs i
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SPECIFIC COMMENTS AND ISSUES RESULTING FROM THE REVIEW OF THE LAND OWNERSHIP EXEMPTION RATIONALE 1.
The report on " Evaluation of the Potential Public Health Impacts Associated with Radioactive Waste Disposal at a site near Clive, Utah" developed for the State by Rogers and Associates Engineering Corporation determined the radionuclide concentrations to limit effective whole-body dose equivalents to applicable levels as defined by the regulations.
The license does not authorize all radionuclides that were evaluated in the report.
please provide technical analyses, including dose to the public, based on the actual types, quantities, concentrations and half-lives of the radionuclides in the waste to be received under the present license which would support the State's decision that the site is to be left open to unrestricted use following the 200 year active institutional control period.
These analyses should support your determination that government ownership is not warranted based on the doses received by the public, including an inadvertent intruder. It would be expected that by using the parameters of the site, and accurate information on the source term, the predicted dose to the public is well below that specified in the regulations.
2.
Please provide a description of the control of the land in the absence of governmental control. The description should include what land-use restriction there will be in the forms of legal instruments such as restrictions on titles and deeds and transfer of site records to the appropriate State and county municipalities.
3.
The regulations provide that the responsibility for the disposal site is naintained by the licensee for at least five years following closure.
Following closure and the period of post-closure observation and maintenance, the license may be transferred to the site owner under conditions specified in R447-25-16 of the Utah Low-Level Radioactive Waste Disposal Rules.
Since there is to be no government ownership, it is not clear what the licensing process will be or who the licensee will be following the nominal five year post-closure period.
Please indicate 1) who the State expects to be the licensee following the post-closure period; 2) who the State expects to be the licensee should Envirocare abandon the site; and 3) what the i
licensing procedures will be following the five year post closure period.
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J In addition, under Section 151(a) (2) of the Nuclear Waste f(
Policy Act (Public Law 97-425), the NRC may be required to review and approve Agreement State financial arrangements for long-term monitoring and maintenance of a specific site before the site operator can be relieved of its licensed i
responsibility.
4.
The Land Ownership Exemption Rationale references existing Utah State laws which could provide the means to control the disposal site.
These laws address issuing
'sers to enforce law and rules, civil penalties, criminal pryceedings and the State's ability to impound radioactive material if it poses an imminent threat or danger to the public health.
We do not understand the relevance of these provisions to ownership of the site, to the responsibility for the site after 100 year active institutional control period, and the possible abandonment of the site by the present owner.
If the State is committing to step in and take over the site, the rationale should specifically state this commitment.
I Please address this in response to item 3 above.
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b COMMENTS ON THE FINAL TRUST AGREEMENT AND SECTION 10 OF THE LICENSE AMENDMENT APPLICATION The latest closure plan as submitted by the licensee and approved by the State was not available during the review of Section 10.
Since the cost estimates are related to the closure plan, many of the issues raised may be resolved with the submission of the approved closure plan.
We request that the closure plan also be provided in addition to responding to the issues and questions raised below.
A.
In Section 10, the follcwing questions on the cost estimates for site closure were raised:
1.
There are no cost estimates or plans for the transfer of site records to the appropriate municipality, county, county zoning board, State officials, local and i
Federal agencies etc. (10 CFR 61.80(e)). Please submit this information from the licensee.
Also identify in addition to the cost of these transfers, who the agencies are in Utah at the present time who will receive these records.
2.
There are no cost estimates or plans regarding the placement of monuments, trench markers or warning signs.
Please nubmit this information.
3.
Current excavation and construction costs indicate that the estimate provided may underestimate the actual cost of activities, even though Envirocare states that the
" costs are based on actual costs charged...for similar work."
Cost estimates should be based on independent regional contractor estimates.
Comparisons to standard engineering manuals for cost estimating would be useful.
4.
Section 10 did not contain drawings with adequate details to evaluate the dimensions and amounts provided for the fencing, excavation, radon barrier, rock barrier, etc.
Please submit detailed drawings that will enable the NRC staff to evaluate the dimensions and amounts provided for the fencing, excavation, radon barrier, rock barrier, etc.
B.
In the cost estimates for the active institutional control period:
1.
Envirocare has planned for four wells to be sampled twice each year for five years, then annually.
The environmental monitoring plan should be based on site history and stability, and may prove to be either more 3
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or less strenuous than what is currently estimated.
This number of wells appears low in recognition of the
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larger number of wells required by the State in review of the license application.
The NRC staff would have expected the fund arrangement to be calculated using a more conservative estimate of the number of wells requiring monitoring during inspections, and the frequency of those inspections.
Please submit the justification by the licensee, and the rationale for acceptance by the State of Utah, for four wells in light of the number of wells required during the operational period of the site and the stated frequency for monitoring.
2.
Funding is provided for annual post-closure inspections, but no funding is provided for items of routine custodial activities, or repairs, if necessary, such as removing debris, control of vegetation, fence repair or replacement of monitoring equipment, or ninor repair of disposal unit covers.
Please submit the cost estimates from the licensee for items of routine custodial activities, or repairs, if necessary, such as removing debris, control of vegetation, fence repair or replacement of monitoring equipment, or minor repair of disposal unit covers.
3.
No funding is provided for contingencies in Section 10.
Although specific costs cannot be calculated for possible future contingencies or activities such as replacement of a large portion of a disposal unit cover, some provision should be made for this type of event.
Please submit the information on funding for future contingencies as submitted by the licensee.
C.
The trust fund addresses only the periods of site operation, closure and 100 years after closure.
The fund is dissolved after 100 years, and any remaining noney returned to Envirocare.
This is standard; however, if the surety arrangement is designed to compensate for lack of land-ownership, it seems that some mention of the passive institutional centrol period should be made.
Please submit either the licensee's or the State of Utah's description of the passive institutional control period and the activities envisioned during this time period.
D.
On page 8, Schedule A, paragraph 2 is the " current closure cost estimate" but no dollar amount is listed.
(Note that there was a dollar amount of $233,582.20 listed on the Draft Trust Agreement.)
This schedule should be revised to include the dollar amount.
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E.
The last sentence of paragraph 10.6.5 reads, "to cover 300,000 cubic yards of contaminated material, 141,808 cubic
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yards of radon barrier would be necessary."
The original numbers in Section 10 submitted with the Draft Trust Agreement were 465,000 CY and 165,000 CY respectively.
It is unclear what the relation is between the quantities of contaminated material and radon barrier.
The revised July 15, 1992 Section 10 does not appear to be consistent with the previous varsion with respect to this issue.
Please clarify the relation between the quantities of contaminated material and the raden barrier.
F.
In Section 10.6.10, General Cleanup, the second paragraph on page 10-5, states that, "An additional 100 [ soil] tests have been included on Table 10.1..."
Table 10.1 lists only 50 soil tests, and this is a decrease from the original quantity of 100 in the previous version of Section 10.
Please indicate the correct number and have the licensee revise Section 10 for consistency.
G.
On page 10-11, for both item 5, Gamma Radiation Monitoring, and item 6, Radon Monitors, the cost per quarter has dropped significantly from the previous version of Section 10.
The cost per quarter for Gamma Radiation Monitoring, has dropped from $22/qtr to $1.10/qtr, and for Radon Monitors, it has decreased from $35/qtr to $1.10/qtr.
Both of these decreases are very large.
Please explain the significant decrease in monitoring cost.
Editorial Comments and Arithmetic Errors in the Trust Agreement and Section 10.
Trust Agreement 1.
In section 19 on page 6, hypothecated is misspelled.
2.
In Schedule B on page 9, there is a math error:
$258,140 + $972,860 = $1,231,000 Dot $1,213,000.
Section 10 1.
The third paragraph on page 10-1 contains the first use of the abbreviation LARW, however, it is not spelled oLt.
2.
The third paragraph in Section 10.0.1 (page 10-2) submitted with the Draft Trust Agreement, had a final sentence which said:
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"It is anticipated that the only time contaminated I
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naterial will be stockpiled loose is when it is dumped out loose under the rollover and when it is stored on the approved storage pad."
i It is unclear why this sentence was deleted.
It seems I
to be informative and useful.
3.
The surety agreement discussed in Section 10 and cost j
estimates as a whole had several arithmetic inconsistencies in the draft documents that were not i
corrected in the final document.
These are as follows:
There is quite a bit of confusion regarding quantities l
A, B, C and D.
a.
On page 10-2, paragraph 3, quantity C is listed as 278,000 cubic yards (CY) ; however, elsewhere in the document, (pages 10-2, and 10-3), the amount is listed as 283,000 CY.
l This amount (283,000 CY) is used in all calculations.
I b.
At the bottom of page 10-2, quantities A, B,
l C and D are added.
The sum is 300,000 CY.
i Quantities A, B, C,
and D, when summed, equal l
330,000.
It should be made clear that quantities A, and B are I
part of quantity C, and that the equation should be:
C t
+ D S 300,000.
In addition, we suggest that paragraph 3, on pages 10-1
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and 10-2 should read, "The total amount of 1
radioactively contaminated material on-site but not I
covered with sufficient radon barrier and rock erosion barrier (material in temporary embankment, in storage, I
and not unloaded) must be less than 283.000 cubic yards (quantity C.)
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4.
The second paragraph of Section 10.3, page 10-4, f
references construction drawings for the "the first i
465,000 cubic yards."
This is the same as in the Section 10 that was submitted with the Draft Trus*
Agreement, although every other occurrence of "465,000
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CY" that appeared in the previous version of Section 10
'l has been replaced with "300,000."
It is not clear whether this "465,000 CY" was left in place
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intentionally or in error.
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5.
It is unclear why all of the dimensions in Section 10.5 were changed.
It is possible that it is because the f
limit on contaminated material on site that is not
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co=pletely covered with radon and rock barrier is 300,000 CY rather than the original 465,000.
If so, this indicates that the reference to "465,000 CY" in Section 10.3 is a mistake.
See 4 above.
6.
At the top of page 10-7, on line 5, there is an asterisk after CY, but there is no corresponding explanatory asterisk.
7.
In the fourth line of the first full paragraph on page 10-7, that twenty percent of the total of " material in storage, not unlosded and from the cleanup of the site..." is listed as 6000 CY.
However, these numbers add up to 9400 CY.
[(material in storage)+(not unloaded)+(clean-up)]
- 20%
[25,000 CY
+
5,000 CY
+
17,000 CY)
- 20% =
9,400 CY I
Note that this does not change the $0.52 end result of the calculations.
8.
On page 10-10, the total for Environmental Monitoring / Water Sampling is $4,216/yr.
This number is listed incorrectly as $4,206, and halved incorrectly as
$2,103 on page 10-12 in Sections D and E.
This led to incorrect totals of $8,206 in Sections D and E (should be $8,216) and $6,103 in Section E (should be $6,108),
and throughout Table 10.2.
9.
On page 10-10 in Section E,
$8,206 is listed as the cost for the "Second Through Sixth Years," however, in Table 10.2 it is only listed for the second through fifth years.
Similarly, in Section E on page 10-10,
$6,103 is listed for the " Seventh Through One-hundredth Years, but in Table 10.2, this amount is listed for years six through one hundred.
These discrepancies should be corrected.
10.
In item 5, on page 10-11, Gamma Aadiation Monitoring was changed from "(TLD Badges)" to "(Ion Chambers)"
however, in item C on the same page, it is listed as Gamma TLD's.
This discrepancy should be corrected.
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11.
All of the items listed in Table 10.3 have explanatory paragraphs within the body of the text except for Reclamation.
The licensee should provide an explanatory paragraph as to what reclamation consists
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Federal Register'l Vol. W7. No. 220 / Frklay. Nwomber 13. feet / Notices 53S41 member named below as farin advance hiermation noendal deta.soeb as salae6ee.
puling on requests for the opportunity to
.cs is practicable ao that cppropriate and pe'eonal mformatton ---
.-4 present oral (tatements and the time arrangements can be made.
Andinduals associated with the pergoenla.
During the initial portion of the allotted therefor can be obtained by a meetmg the subcommPtee,algwith w,%*'g* 'g
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yeepaid telephone call to Mr. George other committee members or stan who m
. Sete (telepbone 301/4R2-3s04) between
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may be present. may eachange
,g 8 am. and 4.30 p.m. (EST). Persons planrdag to attend this meeting are 4
t prehmmary views regardmg matters to g,
arged to contact the above named be considered during the balance of the Com.m h ga m t @ cer kndividual ode or two days before the meetty (FR Doc as-peer FM ts-tFat; a45 as:]
ocheduled meeting to be advised of any De subcommittee wf!! then bear owne esos 7"S***
p*esentations by and hold discussions changes in achedule, etc., that may have with representsuses of the NRC alaf!
scourred.
and other mterested persons regardmg NUCLEAR REGULATORY DemomeM tm this res itw.
COMMLSSJON Geerys Sega.
Further information regarding topics rechnico/Assissant se the Director. 05,a of to be discussed. the scheduhng of bo6 ear Safety Researdi Rev6ew Nuclear Angularo y Ac.corch.
sessions. whether the meeting has been Committoedirasta subcormdttee; cancelled or rescheduled. the Meetbg (nt Doc ss-est2 rilmd is-12 al tas am]
Chairman's ruling on requests for the
,,2,,,,,,,,,,
opportun ty Io p esent oral statements De NSRRC Weste Submmmittee will and the time allotted therefor can be bold a meeting on December 1.1992,in obtained b3 a prepaid telephone call to the Parkland Room. Crowne Plasa M oeofStsk W 6 R*o*iiof P
htr GeorFe Sege (telephone 301/492-Hohday Inn.1750 Rockville Pike.
Petition 3Wl beta een 8 a m. and 4.30 p.m.
RockviDe* MD 2085*'
(E. 5 T ) Persons planning to attend this I.
P' I Notice is bereby given that. by letter me etmg e e uged to contact the above pu eat dn dated September 21.1992. Anthony J.
ramcd ndmdsal one or two days ne agenda for the subject meeting
% mps n.Esq..on behalf of US before the scheduled rneetmg to be wiU be as follows'.
Ecology. Inc filed a ** Petition of US Ecology. inc. for Review and Suspension adused of ar3 chages in schedule, etc Tuesday. December 2. m72-&30c.m -3 or Revocation of Utah's Agreement that rna3 has e occu red.
p.m.
State Program for Failure to Require D.ied Naember s tw:
ne subcommittee will review the State or Federal Site Ownership at the Geoere sete.
High in el Waste Performance Envirocan of Utah. Inc. lew-level 7ec ract 443. stent 4 rAc Dr.ector. cw,cc or Assessment Research Program and an Radioactive Watte Facihty" with the
%cirer Aep/cron AesewA overview update of the H:gh level U.S. Nuclear Regulatory Commission in Dot s.:-: 515 Filed 11-12-4:1 a45 amj Waste Research Program A detailed staff. The Petition requests the NRC to sw.c coor nmc,
agenda will be made available at the revoke or suspend Utah s AFreement a
meeting State status under section 274 of the Oral statements may be presented by Atotnic Energy Act for failure to require N ATIONAL SCIENCE FOUNDATION merobers of the public with the Federal or State land ownership at the concurrence of the Subcommittee Envirocare of Utah. Inc low-level Spectat Emphas;s Pane 4 h Research, ChairTnan: written staternents will be rydioactive waste (LLRW) disposal Evatusilon, and D.nemhatiorr; accepted and made available to the facihty. As a basis for the request. the i
Weetmg subcommittee. Transcripts or recordmgs Petition alleges that:
1 of the meeting will not be made.
(1) Under both Utah's Ag eement Questions may be asked only by State program and the Federal LLRW A
c.
A (Pub SG-.463' n amended) the National Science members of the subcommittee and the regulatory program. LIJth may not be ycundation announces the following staft Persons desiring to make oral disposed of on priva ely-owned isnd statements should notdy the NRC staff unless the state in which the site is member named below as far in advance located or the Federal govemment has Dcra cnd Time December R1m e 30 2,
a m to 5 p m-as is practicable so that appropriate formally expressed a wilhngness to strangements can be made, eccept title to the facihty at site closure; During the initial portion of the Cer er 3 3D are t t burg meedng the submh along with privately owned land; and (2)The Envirocare site is located on Type of Merters Closed Cor: torr Fr.sen Ms beter'y Hunter.
other committee members or staff who Dmsion c! Rescerth. Erslue non. a nd may be pmsent may exM -
(3) Neither Utah nor the United States
-Department of Energy has agreed to or D:sse..r.eten rm 1227.Netmal $arnee prenminary views regarding matters to i
axpressed any withngness to accept htle i
Foundation.1aac G St NW., Wastungton, DC be considered durmg the balance of the 20%0 Telephor>e (2::2135?-7D64 meeting.
to the site' I
e Pu par o' Meeting To provide adrice and ne subcommittee will then hear e NRC will take appropriate action l
i eccowendstirm conce nmg proposals presentations by and hold discussions on the Peuhon widin a nasonaue time.
I subm.tted to NSF for finsntist support Arenda To rev ew and esaluate researd' with representatives of the NRC stag A COPY of the Petwon is avade ble for nvposals subrrmed c the App!1catier.s and other interested persons regardmg inspection and copying in the e
g Commission's Public Document Room.
, E,$t
.TfeY,$d7
- n pr F
r infortcation re6arding topics 2120 L Street NW Washmgton. DC Ae:sor fcr Closmg The p opoos!s brir.g to be chacussed. the scheduhng of E37.
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reurmed mclude mforrnation of a propnetary sessions.whether the meeting has been Deted st Rod ville.Merytand, this tuh day or cerAdent st rature. mdudic.g te:Lnnal canceled or rescheduled. the Chairman's of Novembef.1992 l
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s3M2 Federal Renfrier / Vol. 57. No. 220 / Friday. Nevernber 13. tas2 / Noticea For the % clear Regv.1 story
Omes of PersammeW.
4w ;l arader sectica12 of the
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p Vandy L. M. Ass.
Douglas A. Brook.
hchange Ack-Form 14 Q affects y
Assaient AmesurhrSasse A,. : : n Aethy Drrecse.
appretimately 3.238 filars a.nd *esults in PrrTmn Offa o/So*' h555"*
(f1t Doe ts-pets I%d1Mbat.tes as6) 190 5 burden hours.
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[FR Doc. as-rst! Ned n-ibat 448 as) an,,, s ccca mass ev.s (s) Foren to-KSB which is an optional og
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a.nnual report for smali business issuers y,
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OFDCE OF PEN EdAMGEMENT (7) Form 10-QSB which is an optional R
Forma Under Redew by Osca of quarterty report Ned by amall businers D6 rector" Adelsory Cva es een Laur laanagameed and &adget isspers tmder the Exchange Act-Forgi S
Enf orcement and Protecttee Agency Clearanca 05cas-Kenneth to-QSB affects approximstely 3.518 1:
Occupat6ons; Opern Beeting Fogssh (202) 272-2142.
filers and reenits in 131.5 burden hours; g
Upon wntten request copy ava!!able (8) Form SB-2 which is a registration C
ac a c t 0 5 ce of,r. ",
from: Securities and hchanas form under the Securities Act filed by l (
Mansgement.
ComMuion. Omce c.f Fahnga, small business lasuer -Form SB-2 is I
acnoot Norice of open roeeting.
Information and Consumer Affairs, filed by approximately 384 filers and
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Washington. DC 20549.
resdts in s15 burden hours:
i i sussaaAAn Accor6cg ta the provisiana g,g, w (9) Form to which is used to register 1
of section 10 of the Federal Advisory g g,wa,g u,yr,, g g.'O 44 accurities under the Exchange Act-Committee Act [P I. SS-4t,3). nelloe is Regulataan ba:--rue h ro.:
Form to affects approximately 110 filers hereby given that the ninth enecting of Regulanon FB-Ne % !?O-3r0 and results in 11980 burden bours.
the Drector's Advisory Committee on Forrn WK-.De No, rus (10) Torm 51 which is a registration I,a w Enfortement and Protect >>e Form m-O-Ea w rus statement under the Securities Act-Fm WKS M eNo.r wet Occupations will be held at the teme and Form S-1 a!Tects approximately 1.039 piace shown below.
$'[
'M$7 filers and results in 1.295 burden hours; earr November te 1s1to am.
Fonn W-FJe h 2? M1 (11) Tom M which is used y register Form 51--rde h rua under the Secunties Act securitsea e Act.: Weshington lillten and Towers-Fomi be-File h ro-:c7 issued in business combination 1919 Connectcvt Avente.N.W.
Form bu-Fde h rM4 transactions-Form S-4 affects Washingtm DC.
Notice is hereby given pursuant to the approximately 506 filers and results in Due to the rapidly approachm.g Paperwork Re:hretton Act of 1900 (44 1.245 burden houis; and statutory desdhne for comrdetien of this U.S.C. 3501 et seg ), that the Securities (12) Form S11 which is voed to study. less than 15 days notice is given.
and Schsnre Commission register under the Securities Act A c rwo A:The focus of the November
("Cornmission") hos submitted for OMB secunties of certain real estate l
18th meetng will be the sohcitir.g of the approval proposed revisions to:
companies-Form S11 affects view: of the Adv:sory Corsmittee (1) ReFulation 14A which sets forth approximately 340 fders and results in membe*n on the O'fice of Personnel rules govemir*g the policitation of 270 burden hours.
ManaFerrent sta!I proposal forjaw proxies-Reguls tion 14 A affects The estimated averste beden hours enforcement pay and t!sssification approximstely R.000 filers and causes are made solely for purposes of the reform before OFM rnales a final fuers so incur an average estimated Paperwork Reduction Act and are not decision on its recommendation, burden of 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br />; derived from a comprehensive or even a
[2) Regulation S X which prevides representstive survey or study of the ron rwrrwa swonuAnow cocAcT:
Ph !L C. Tc,;ey. D reclor. La w instructions for filing forms under the costs of thrmssion rules or forms.
3 Enfortement and Protective Secunties Aet of1833.Securfries Cencral comments regarding the Occupations Task Force. Omc4 of Excharpe Act of1934 (" Exchange Act"}
estimeted burden hours should be Cor pensation Policy.Perscnnel and the Energy Policy and Conservetion di.ected to Gary Waxman at the Act of 1976-Regda tion S-K is aselgrwd address below. Any comments one b& har b adminMu concerning the accuracy oN.a e Ma F ent ro e 7 convenience since it does not chroct!Y estimated average burden bours for 1
E Street NW. N, shington, DC e hrb b a de m m@ @ t'm'*h & M "2'
(3) Rerulation SB wuch prwides forms should be di*ected to Kenneth A.
Cum tsctcA*'y secosuaanosc The instructions for fding forms under the Fogs sh. Deputy Executive Ihrector.
meeting is open to the pubil:. If tima Securities Act and Exchange Act by Secunties and Exchange Commission.
permits. an opporturJry wtL! be provided small businesa issuer >-Regulstion SB 450 Tif th Street. NW., Wa shington. DC for mernbers of the public in attendance is assigned one burden 1our foe 20M9 and Gary Waxman. [PRA Profeet et the meeting to provide the'r views.
administrattre conveniencs eines it doe 9 Nos. 3235-CD59. r%3. 00'0. 07?1. 0416.
Persons wishing to address the Advisory not directly impose burden bours on C064. 0418. CDf.5. 03e7. C324 a.nd 0420),
Comerartee ornity at the meeting should respondents:
Clearance 05cer of Management and submit a written requert no } ster than (4) Forss to-K widiis an a-1 Budget. toom 1208. New hecative the close of bee %ers on November 16.
report f. led by Issoets of secanties Osca BJ&ng, Washington. DC 25G3.
1992. The regocet must incide the nerne registered ander section 12 ed the D'd C"*'
end eddress of the person wishing to Excherme Act-Form 10 K affects cppear. the ce pecity in wMeh the apprrrrmtely E.221 filers and results in M "* E E* 1-cppearsace will be mede. a short 1.711 burden bours:
S*C
- E-sumrxary of the sntended presentat6ces.
(5) Form to-Q wieck la a speetterty (FR Dec. :: Fans Fu d 1Ms.4:r. Hs se!
j and the amourt of ti:ne desered.
repcet fdad by tanvers of secantime owns enes see-ow f
j
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