ML20039C915

Request for OMB Review & Supporting Statement Re 10CFR34.11, Application for Byproduct Matl License - Use of Sealed Sources in Radiography, NRC Form 313R.Estimated Respondent Burden Is 2,900-h Annually

ML20039C915
Person / Time
Issue date:	12/11/1981
From:	Donoghue D, Scott R NRC OFFICE OF ADMINISTRATION (ADM)
To:
Shared Package
ML20039C911	List: ML20039C910 ML20039C913 ML20039C915
References
NUDOCS 8112310095
Download: ML20039C915 (8)

Text

r RE'UEST FZR CMB REVIEW (Und:r th: Pap;rwork R: duction Act and Ex:cutiv2 Ord:t 12291)

Imp;rt nt - Read instructions (SF-83A) before completing this Office of Information and Regulatory Affairs form. Submit the required number of copies of SF-83.together Office of Management and Budget with th; material for which review is requested to:

Wa shington. D.C. 20503

1. D:pirtment/ Agency and Bureau /Offsce originating request 3.Name(s) and telepnone number (s) of person (s) who can best answer questions regarding request U.S. Nuclear Regualtory Commission B. O'Connell (301) 427-4211 2.6-dsgst Agency / Bureau number (firstpart of 11-digit Treasury

4. 3-d\\g\\t functional code (last part of 11-digit Treasury Account Account No.)

No.)

b l._

__0._ _2_

0 D._

_.2_ l _Q._

5. Tit l2 of information Collectson or Rulemaksng C. Is this a rutemaking submission under Section 3504 fh) of Application for Byproduct liaterial License -

P.L. 96 511 ? (Check one)

Use of Sealed Sources in Radiography

' Cll No (Section 3507 submission) 10 CFR 34.11, NRC 313R.

2 0 Yes. NPRM. Expected cate of pubbcation:

6. A. Is any information collectoon (reporting or recordkeeping) 3 0 Yes. final rute. Expected cate of pubtscation.

involved? (Check one)

Effective cate:

1 Q( Yes and proposal is attached for review D. At what phase of rulemaking is this submission made?

OU' 2 O Yes but proposat is not attached - skip to question D.

3 O No - skip to Question D.

1)(X Not applicable B. Ar2 the respondents primanly educationalagencies or 2 0 Major rule.at NPRM stage Institutions oris the purpose related to Federal education 3 0 Major Fina\\ rule for which no NPRM was published programs ?

4 O Major Final rule, af ter publication of NPRM O Yes

)(J No 5 O Nonmajor rule.at NPRM stage

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6 O Nor:maior rule. at Final stage COMPLETE SHADED PORTION IF INFORMATION COLLECTION PftOPOS AL IS ATTACHED

7. Currsnt (or former) OMB Number

8. Requested 1_2. Agen,cy report form n_urnber(s_)

Expiration Date 3150-0023 NRC 313R Expir: tion Date

13. Are respondents only Federal agencies?

4/30/82 4/30/85 O Yes Q No

9. Is proposed information collection listed in

14. Type of request (Check one) th information collection budget?

O Yes O No.

1 O preliminary plan 1 o. Wsli this proposed information collection 2 O new (notpreviously approved or espired more than 6 months c;use the agency to exceed its information

. ago) coll ction budget allowance? (if yes, attach O Yes

[X No 3 0 revision i

amendment request from agency head.)

e O extension (ediustment to burden only) j

11. Number of report forms submitted for approval 5 % extension (no change)

One (})

6 O resnstatement (expired within 6 months) 15.

16 Classifscation of Change in Burden (explain in supporting statement) c r.opro2imate sire of umwn usamose)

N/A No.of Responses - No of Reporting Hours Cost to the Pubbc k sitsof sempie

a. In inventory

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c. Estem;ted number of

b. As proposed l l respondents or -

record k eepers per ye*'

c. Dif ference (b-a) s ggg

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d Aeoorts annuetty by each Explanation of difference (indicate as many as apply) r:spondent prem 25)

I Adjustments f $*j*,"3c,[3d

d. Correction-erior i

iS 400 7

e.Correctiori-reestimate :1 i

i5

' f E: tem;ted ewerage

' number of hours -

+

+

+$

g, g g g g }$g

[D'""'""

varies F

Program changes.

Tg Estimitedtotalhours l

of cnnues t uroe"'"

g. Increase

+

+

+$

F* scil Year

~ " " " "

pes 00

h. Decrea se

-S 8112310095 811214 i

PDR ORG EUSOMB Standard Form 83 (Rev.3 81)

PDR For Use Beginning 4/1/81

17. Abstfact-NMds cnd Usss (50 w:rds orpss)

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'Provides basic data for agency revid and licensing of the use of sealed sources in industrial radiography.

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.18. Rslitsd report form (s) (give OMB number (s),IRCN(s),

20. Catalog of Federal Domestic Assistance Program Number

., intzrnslagency report form number (sj o_r. symbol (s))_ _,,,

N/A 2t srnan business omganization gYes

? No NRC 313M NRC 313I 19.Typ3 of affected public (Check as manyas apply)

22. Type of activity of affected public-indichte 3-digit Standard

'"Y"*'

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• 1 O Individuals orhouseholds 10, check O Multiple or. O All 2 O state orlocalgovernments 3 O farms Q-businesses or otherinstitutions (except farms)

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R 1

23. Brisf description of affected public (e.g,"retailgrocery stores,"" State education agencies "" households in 50 largest SMShs")

Users of sealed source industrial radiography

24. Purpose (Check as many as apply. If more than one, indicate

26. Collection method (Check as many as apply); -

predominant by an asterisk)

. C3 mail self-administered '

p 1 O applicatior; for benefits

~ 2 O'other self-administered"

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2 O program evaluation 30 telephoneinterview

_ TO gsneralpurpose statistics 4O personalinterview.

4 E rsgulatory or compliance 50 recordkeeping requirement-5 O program pianning or management Required retention period:

years ~ - -

6 O rasearch 6 0 other-describe 25.Frsquency of Use

- 27. Collection agent (Check one) 10 'Nontecurring 1)q requesting Department / Agency R$ curring (check as many as apply) 2 O other Federal Department / Agency '

2)Q on occasion 6O semiannually 3 O private coMractor 3 O weekly 70 annually 4 0 recordkeeping requirement.._ _

J 4 O monthly 80 biennially 5 0 other-describe:

5 0 quarterly 90 other-describe:

28. Authority for agency for information collection or

30. Do you promise confidentiality?.

ruismaking-indicate statute, regulation, judicial decree.

(if yes. explain basis forpledge~

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ttc. 30 cyg 34 in supporting statement.)

O Yes X3 No '

Atomic Energy Act 1954

31. win the proposed information co!!ection create a new or become part of an existing Privacy Act system of records?.

29. Respondent's obligation to repty (Check as many as apply)

!:1yes. attach FcderalRegister notice orproposed draft of XXXvoluntary notice.)

O Y'es XXXNo 2 O recuired to obtain or retain benefit

32. Cost to Federal Government of 3 0 mandatory-cite statute.not CFR (attach copy of._.

Information collection or rulemaking SR0;00n statutory authority)

COMPLETE ITEMS 33 THRU 35 ONLY IF RULEM AKING SUBMISSION -

' 33. Compliance costs to the public l 34. Is there a' regulatory imp &ct

35. ls there a statutory or judicial analysis attached?

deadline affecting issuance?

0 Yes' O No O Yes. Enter date:

O No CERTIFIC ATION SY AUTHORIZED OFFICI ALS SUBMITTING REQUEST-We certify that the information collection or rutemaking submitted for rOvitw is necessary for the proper performance of the agency's functions that the proposal represents the minimum public burden and Federal cost consistsnt with need, and is consistent with applicable OMB and agency policy directives. Signature and title of:

APPROVING PouCY o*FICIAL FOR AGENcv DATE suBMITTI G OFFI 4AL DATE 8h N

a 1

ahue /

t en c t 7

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SUPPORTING STATEMENT FOR NRC FORM 313R 10 CFR Parti 34.3-Justification Section 34.11 of 10 CFR Part 34 contains the specific. licensing requirements for use of sealed sources for performance of industrial radiography.

10 CFR Part 34 sets forth radiation safety requirements for persons using sealed sources for ra.diography.

In order for a person to be licensed to perform radiography,he/she must complete NRC Form 313R, " Application for Byproduct Material License - Use of Sealed Sources in Radiography" Section 34.3.

If the information in the application is satisfactory, NRC Form 374, " Materials License," is issued.

The NRC staff will review the information submitted on NRC Form 313R to determine whether an applicant for a license has training, experience, equip-ment, facilities, and procedures for the use of byproduct material that are adequate to protect the public health and safety.

There is no source for the required information other than applicants.

NRC is the only Federal agency that requires the submission of information on radiation safety programs for the use of^reagtor.-produced-isotopes-

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(byproduct material) in radiography.

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This application is submitted for the initial license, for amendments, and for renewals every five years.

The application process requires that applicants and licensees perform a comprehensive review of their entire radiation safety program to assure that all activities will be or are being conducted safely and in accordance with NRC regulations. The review and submission of the information required on the application form is essential to NRC's determination of whether the applicant has training, experience, equipment, facilities and procedures for the use of byproduct material that are adequate to orotect the public health and safety.

Description of Infonnation Collection It is estimated that approximately 30. applications for new licenses, 300}

applications for license amendments, and 70 applications for license renewals will be submitted to NRC annually on NRC Form 313R.

Applicants will fill in the information requested on NRC Form 313R and submit the original and one copy to NRC.

r The submitted applications are maintained in a secure docket file room. They are released to the public on request after screening for and removing all personal and proprietary information,. Files are maintained by name of licensee, not. by name of individual.

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, Time Schedule for Information Collection and Publication Applicants for new licenses,.for amendments, or for renewal of existing licenses will submit NRC Form 313R. New applications or amendment applica-tions may be submitted at any time.. Renewal applications are required to be submitted every five years.

Requests for additional information to complete or clarify the information submitted in the application or to rectify..

deficiencies in proposed programs would be issued as necessary. ~ The NRC

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expects that an average of one additional information request per submittal will be.needed, and that this request would normally be issued within three months of the initial submittal.

Responses to requests for additional informa-tion would normally occur within two months, and the NRC would normally take appropriate licensing action within about one month of the availability of all required information.

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Consultations Outside the Agency There have been no consultations outside the agency since the initial GA0 clearance of the form.

Estimate of Compliance Burden Estimated Number Applicant Burden Total Annual Submitted Annually Per Submittal (Hrs)

Burden (Hrs)

New 30 40 1,200 Amendment 300 1

300 Renewal 70 20 1,400 Total 400 2,900 Estimate of Cost to Federal Government The cost to the Federal Government is estimated to be approximately $80',000 annually for approximately 3,50n staff hours.

Enclosure:

NRC Form 313R

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t Form RC 13R U.S. NUCLEAR REGULATORY COMMISSION structions WH 12~El 10 CFR 34 lNSTRUCTIONS FOR P EPARING APPLICATION FOR' BY PRODUCT MATERIAL LI ENSE SE OF SEALED SOURCES'lN RAD 10 GRAPHY 5

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FORM NR 313R An Applicant for a " Byproduct Material nse** to possess and use NRC Regulatory Guide 10.6.contains additional information (drm of scaled sources for regarding Commission regulations applicable to the use of sealed reactor-produced radioisotopes in k

radiography must complete -ORM 'R 413R, and must attach to the sources in radiography. A copy of the guide may be obtained by 4

completed form the additio ormation indicated. Two copies of writing to the address specified above. The applicant is encouraged the entire application should be sent to the Director, Division of Fuel to obtain a copy of the guide and to use it in preparing the license Cycle and Material Safety. Office of Nuclear Material Safety and application.

Scguards, U.S. Nuclear Regulatory Commission, Washington, D.C.

20555.

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EXPLANATION OF FORM NRC 13R l

f hrm Se.

6 Information which has been previously submitted to the I

I (s) Identify the legal entity in whose name thelicense should Commission may be referred to by date of the document l

be issued and who is to be legally responsible for possession transmittin5 that information.

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and use of the sealed sources of byproduct material.

conducting radiography. Where*

• room or rooms have (b) Self4xplanatory.

been constructed for this purpose, a sketch should be in.

(cliCheck appropriate block indicating organizational strue-cluded which describes dimensions of the room, including ture of applicant. If applicant is other than an individual, wall thickness and materials of construction; areas adjacent the appropriate section on the reverse side of the form must to, above, and below the facility; area security safeguard's be completed. Use supplemental sheets to provide any ad-such as locks, posting signs, warning lights, and interlocking ditional information which is necessary to explain the legal systems; position of operator relative to source exposure point; structure of the applicant.

and source positioning limitations which may be necessary to maintain control of radiation levels external to the facil.

2 Self-explanatory.

ity. The applicant should determine the anticipated rad:-

ati n levels in areas adjacent to the facility in order to 3 List all locations at which the scaled sources will be used establish the necessary control over areas in which rad _iation and/or stored. If use will be made at temporary or " field.,

levels may exceed the limitations contained in Part 20, sites, the name of each State in which the sealed sources Secti n 20.105(b).

will be used on a temporary basis should be included.

The name and location at which sealed sources will be (6) Describe the radiation detection instrumentation which used on a permanent basis should be identified by the will be used. Each instrument should be identified by the street address, city and State.

name of its manufacturer and model number; the type of radiation detected; the sensitivity range in mr/hr; the num-4 List the information called for at the head column for each ber of such instrumcnts available; and the intended use.

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model scaled source to be used for radiography. Follow The applicant should refer to the radiation survey instru-the alphabetical key,ing system provided on any supple-

,,,,,,q,.rements of Part 34. Section 34.24.

mental sheets which are attached to the appl,ication.

(c) Describe the procedures to be followed for calibration 5 (a) and (b) of radiation survey instruments. If instruments wilt be cali.

Specify the radiographic exposure devices and source changers brated by an outside service organization, that organization which will hold the scaled sources identified in item 4. Each should be identified by name and address. The applicant device and source changer should be alphabetically keyed t should refer to Part 34, Section 34.24 for instrument cali-the appropriate source listed in item 4. If an exposure device bration frequency requirements.

or source changer is to be custom fattricated, a complete description of its design and construction should be attached.

(d) Identify the organization that will supply film badges The limits on levels of radiation for radiographic exposure and list the make and model number of pocket dosimeters devices and source changers set forth in Part 34, Section 34.21 or pocket chambers to be used. Refer to Part 34, Section should be considered.

34.33 and Part 20 Section 20.202.

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4 g*

item No.

(s) Attach a copy of the operating and emergency proce-(i) The applicant who desires to conduct his own leak tests dures in the form in which they will be supplied to radio-should describe the procedures he has established for per-graphic personnel Specific requirements on the content forming such tests. This must include a description of the of operating and et.nergency procedures are contained in Part method of performing the test (e.g., points on equipagent to

34. Be sure to include instructions to personnel on all ap-be smeared and method of taking the smear); theinstrumenta-plicable items in Section 34.32.

tion which will be used for measuring the quantity of radio-(f) Attach a schedule or description of the program for train-active material which may have been removed by the test; ing of radiographers and. radiographers' assistants. The and the pertinent emperience of the person who w,ll per-i schedule or description must contain the information required f rm. the test and analyze the results. Applicants not desir-by Part 34 regarding training programs and must bein suffi-ing to conduct their own leak test may have such tests cient detail to demonstrate that individuals completing the Performed by persons specifically authorized by the Com-mission to do so.

The applicant should refer to Part 34 program will meet th' requirements for radiographers and e

radiographers' assistants set forth in Part 34. Refer to Sec.

Section 34.25 for specific leak testing requirements.

tions 34.11 and 34.31.

(g) Describe the internal inspection system or other manage-

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ment control which will be exercised to assure that Com-mission regulations; license provisions; and the operathg 7 LICENSE FEES and emergency procedures are followed by radiogra)hers The Commission charges fees for Gling of applications for and radiographers' assistants. Refer to Part 34, Section licenses as specified in Section 170.12. Title 10, Code of Fed.

34.1 I(d).

eral Regulations. Part 170.The applicant should refer to Sec-(A) Attach a description of the overall organizational strue-tion 170.31. Schedule of fees for materials licenses, to deter-ture pertaining to the radiography program as it will be con-mine ahat fee should accompany the application. No action ducted under the license. This must include specific dele.

can be taken on applications until fees are paid. Checks or gations of authority ar.d responsibility for operation of the money orders should be made payable to the U.S. Nuclear Regu.

program. Refer to Part 34, Section 34.11(c) latory Commission.

LT. s. oOYERNMENT PRDrrDio OFFICE :1s73 o s05.Ist 4

b PRIVACY ACT STATEMENT Pursuant t 5U

. Sh2a(e)(3), enacted into law by section 3 of the Privacy Act of 1974 (Public Law 93 57 e fo'lo g

is fur ed lto individuals who supply information to the Nuclear Regulatory Commission on Forms 'F,C 13,

• j statement 313h, or N 3R. This information is maintained in a system of records designated as NRC-3 and described at 40 Federal Register g5 (October 1,1975).

1. AlHHORITY Sections 81 and 161(b) of the Atomic Energy Act of 1954, as amended (42 U.S.C. 2111 and 2201(b)).

2. PRINCIPAL PURPOSE (S) The information is evaluated by the NRC staff pursuant to the criteria set forth in 10 CFR Parts 30-36 to determine whether the application meets the requirements of the Atomic Energy Act of 1954, as amended, and the Commission's regulations, for the issuance of a byproduct materiallicense or amendment thereof.

3. ROUTINE USES The information may be used: (a) to provide records to State health departments for their information and use; and (b) to provide information to Federal, State, and local health officials and other persons in the event of incident or exposure, for their information, investigation, and protection of the public health and safety.The information may also be disclosed to appropriate Federal, State, and local agencies in the event that the information indicates a i

violation or potential violation of law and in the course of an administrative or judicial proceeding. In addition, this "T rmation may be transferred to an appropriate Federal, State, or local agency to the extent relevant and necessary for RC decision or to an appropriate Federal agency to the extent relevant and necessary for that agency's decision about a

Og ou. A copy of the license issued will routinely be placed in the NRC's Public Document Room,1717 H Street, N.W.,

Washington, D.C.

4. WHETHER DISCLOSURE IS MANDATORY OR VOLUNTARY AND EFFECT ON INDIVIDUAL OF NOT PROVIDING itEORMATION Disclosure of the requested information is voluntary. If the requested information is not furnished, however, the application for byproduct materiallicense, or amendment thereof, will not be processed.

5. SYSTEM MANAGER (S) AND ADDRESS Director, Division of Fuel Cycle and Material Safety, Office of Nuclear Material Safety and Safeguards, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555.

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pg 2 V fres u n 0 - t 2.

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n (p.-[gl NR e3r3R US.NDCLEAR REGULATORY COMMISSION

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APPLICATION FOR BYPRODUCT MATERIAL LICENSE-(

Appfoved by GW5-hh]hy USE OF SEALED SOURCES IN RADIOGRAPHY (SEE ATTACHED FOR$NF[Q 313R INSTRUCTIONS AND NRP REGULATORY GUIDE 10.6-USE SUPPLEMENTAL l

[

SHEETWHERE NECESSARY)BE SUR2 ALL ITEMS ARE COMPLt:TED AND THAT ALL NECESSARY ATTACHMENTS ARE FURNISHED. IF ANY PORTION OF THE APPLICATION IS NOT APPLICABLE SPECIFICALLY SO STATE.

DEFICIENT OR INCOMPLETE APPLICATIONS MAY BE RETURNED WITHOUT CONSIDERATION. LICENSE FEE REQUIRED, SEE ITEM 7 OF INSTRUCTIONS.

l(e) NAME AND ADDRESS OF APPUCANT AND TELEPHONE NUMBER

2. THIS IS AN APPLtcATION FOR: (Check appropham imm)

A. O NEW LICENSE B. O AMENDMENT TO LICENSE NO.

1(a) TELEPHONE NO.: Area Code (

)

3. LOCATION (5) WHEtt SEALED SoutCE$ WIu SE USED AND/OR STotED. (if ee.

1(c) APPUCANT l$i An indevidwel A perenership A Corporehen Aa gg gg g g Uaccorporeied Associehoa Othee If appliceae is other then ea iadevid.

wel, the nephceble seeen en the reverse ede mws' be ce*ple'ed.

4. SEALEO SOURCES TO BE USED IN RADIOG RAPHY (Attach supplementary pages,if necessary)

MAX MUM ACT VITY SOURCE MODEL NUMBER N AME OF M ANU F ACTU RE R NUMBER OF SOURCES Elemen ad Mss: N 1 A.

A.

A.

A.

A.

S.

B.

B.

B.

B.

C.

C.

C.

C.

C.

5(a) RADIOG R APHic EXPOSU RE DEVICES ( Attach supplementary pages. lf necessary)

MODEL NUMBER N AME OF M ANUFACTU RER (/nclude description if custom made)

A.

A.

8.

B.

C.

C.

5(b) RADIOGR APHIC SOURCE CH AN GERS (Attach supplementary pages,if necessary)

MODEL NUMBE R N AME OF M ANU F ACTU RE R (Include descrip tion if custom made/

A.

A.

8.

B.

C.

C.

6. THE FollOWING INFORMATKuI15 ATTACHED AS A PART OF THt5 APPUCATION (Ched oppeeness blods and eaecA infermohon celled for in she eashct.eas..* shes 8er=.)

Not Appl <eble Afeoched Prowsevely $4m.#eegr (e) Descr pt:ea of radiogrophic fecepti.e (lattrwoien 6-e).

y (b) Descripe.ea of red.etesa detenen instrumenes to be weed (lashvcrien 6-bl.

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y (c) lastrwmeat celibrehen procedwees flastrweben 6-c) y (d) Perseaael meestering eqwipment (lastrechen 6-4).

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ea (e) Opemmag ead emergency procedures (las=wch-6-e).

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en '""

(f) Trein ag progrom (laserwoon 6-f).

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]y i,i ir~mei -pe,.a e,s em.r e.or m.-o.- c.a,.eiimserwoon 6-g' O

O en '""'

e th) 0 erell ergeniaeheael serveture (laserween 6-h).

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y) Leek eeshag p,ecedures tias rwe.a 6-a.

aa (sam)

CERTIFICATE (This item must be completed by applicant)

7. TMt APPUCANT AND ANY OFFICIAL EnECUTING TMr5 CERTIFICATE ON SEMALF OF THE APPLICANT MAMED IN ETEu l. CERTIFY TMAT TH15 APPLICATION 15 PREPARED IN CON.

FOtulTY WITH TITLE 10. CODE OF FEDERAL REGULAT:ON$. PART 30. AND THAT Au INPORMATION CONTAINED HEREIN.lNCLUDING ANY $UPPLEMENTS ATTACHED HERETO.

l$ itVE AND COetECT TO THE sEST OF OUR KNOWLEDGE AND SEllEP.

UCENSE FEE ENCLOSED s gy:

(Sign a ture)

(Type or print name of certifying of ficial)

D ATE (Title of certifying official)

WARNING.-l 8 U 5.C. 5echen 9 001. Act of Jwne 23.19483 42 Stee.149, makes e e cam.nel e# ease se mene a wilitwafy felse sietea+at er represeatet.ea se ear deper'mese er esency of.. Unwed se es es se say me n r..,hia its i e.ed.chen.

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LEGAL STRUCTURE OF APPLICANT

!! opplicoat is o corporation, complete items 8 through 11s if applicoat is o portaership, complete items 12 through 14, if applicoat is on unincorporated (ssociation or o legal entity other then o portnership or corporation, complete items 13 ond 16. Aftoch sepotute sheets where space provided proees in.

odoquete.

CORPORATION

s. stoCs of APPUCANT CORPORAflON NO. OP SMAtf5 NO. OP SMatts NO. OP SHAR!$.

TOTAL NUptte 07 AUTHORIZED ISSUED SUBSCtlBED (e) Stockholders (b) Svbectibers

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9. In s pel. coat corpore 6ea d.rectly or indirecety coaerelled by eaether corporatiaa or other legal entity?

. YES

. ).N...

. NO e eas.e,

,ts g e nome. rid odd,ess of e.t., ce,peret.ea e,.*e ieget eat.tr.ad dese,ibe he. s.ch ceawei esists.ad ise.s. eat the,.ef.\\

10. (o) IJeahey by aeme end oddress ear iadi..dvel, carperehen, or other legel enhty (fl e=a.ag to percent er a. ore of the stock of appl. cent corporehen issved end owMosad.ag er (2) s*bser b.ag to 10 percoat er more of she avrherised but vains ed eseck of the carperehen.

(b) Ident.fy by some end oddress all oNicers end d. rectors of the corporehen.

I1. Ideahiy the $sete, D serict, Terrdery, er possess.ea wader the le=s of which the applicoat is incorporemd.

PARTNERSHIP

12. Nome end oddess of eech ind.v.dwet se legal eaMy o.a.ag e pennersh.p. ate.est ia the oppleceaf.

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13. $ rete the percent of e=ae<sh p of the oppl. cent partnersh.p held by each of the.adev dwels or legel echties fested.a item 12.

14. Identify the $sete, D.sergt, Teredery, or possessica wader the le=s of wh.ch the opplcoat partneesh.p is oreeneaed.

OTHER

s. osserse m. no,.

of n.. oppi<.at.ad ed.ahfy the s eie, o.str.ct, te,reery, e, penses.iea.ader the ie.s.6.6.ch.t is e, sea.,ed, i s ssete she setet a.-her of a.e-.heri er perseas heid.ag ea e-aersh p ea the appl eoat,.deah'y eech by aema ead add <ess, ead sad ce* the e-aersh.* a'eres' 'heree'.

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