ML20149D971

Voided Matls Licensing Action for License SNM-244 for Dept of Army.Control:119084

ML20149D971
Person / Time
Site:	07000263
Issue date:	03/15/1994
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	NRC
References
119084, NUDOCS 9405260039
Download: ML20149D971 (18)

Text

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'IO: License Fee Managatent Branch m Region I  ;

SUR7ECT: VOIDED APPLICATION Control Number: 119084 )

Applicant: Department of the Army l Date Voided: 3/15/9'r i Reason for Void: Roquest withdrawn by licensee for license no. SNM-244 (070-00263) .- -

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Attachment:

-Official Record Copy of Voided Action.

FOR IJNB USE ONLY

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l Final Review of VOID Coupleted:

Refund Authorized and processed '

No Refund Due I

l Fee Exanpt or Fee Not Required i Caments: Log canpleted Processed by:

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100170 OFFICIA1. RECORD COPYs" ED l

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PDR ADOCK 07000263

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O O March 15,1994 License No. 20-01010-04 SNM-00244 SUB-00238 Docket No. 030-04593 070-00263 040-02253 Control No. I19083 119084 118747 MEMORANDUM TO: Files FROM: John D. Kinneman, Chief l Site Decommissioning Section 1 Division of Radiation Safety and Safeguards

SUBJECT:

VOID .OF IJCENSE ACTION FOR ARL'S PART 20- '

EXEMPTION REQUEST.

In a memorandum, dated December 6,1993, Region I requested NMSS to approve the U.S.

Army Research Laboratory's (ARL) request for an exemption to the. Revised 10 CFR 20. In a telephone conversation between myself and a representative from NMSS, NMSS requested that-we have ARL provide information comparable to the Cintichem Environmental Assessment for the ARL facility. Region I issued a deficiency letter to ARL based on NMSS's request. .This item is closed for NMSS unless Region I forwards additional infomiation to NMSS. NMSS was contacted by telephone to verify that this item was closed for NMSS. On February 8,1994, ARL withdrew their exemption requc st.

L-J n D. K meman, Chief Si Decommissioning Section ivision Of Radiation Safety and Safeguards OFFICIAL P.ECOP.D COPY '

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O A l d U g' DEPARTMENT OF THE ARMY U.S. ARMY RESEARCH LABORATORY i ARSENAL STREET I _ga I

@ REPLYTOTHE ATTENTION OF WATERTOWN, MASSACHUSETTS 0217261 8 February 1994 g

Commander License No. SUB-238 20-01010-04 SNM-244 Mr. John D. Kinneman Chief, Research Development l and Decommissioning Section j Division of Radiation Safety and Safeguards j U.S. Nuclear Regulatory Commission / Region I  !

475 Allendale Road King of Prussia, PA 19406-1416 l l

Dear Mr. Kinneman,

l Reference our letters of 17 September and 8 November 1993_ requesting a l waiver to the implementation of 10 CFR 20.

l Reference your request of 14 January 1994 for additional information in ,

order to complete a brief environmental assessment. '

As Peter Cornetta indicated during his 31 January 1994 conversation with Mr.

Mark Bouwens, we are no longer pursuing an exemption to the implementation of the new 10 CFR 20 regulations. The impact of passing time has prompted a 1 reassessment of our needs.

Weighing the amount of work remaining and assessing the application of the new regulation versus the old at the time of estimated approval has lead to the decision that reverting back to the old regulations would not be cost effective or productive.

In fact we now have our new procedures in place and have been functioning in compliance with these new regulations. If further information pertaining to this action is desired, Peter Cornetta may be reached at (617) 923-5225.

j Sincerely, J' . STIEFEL

, CM Acting Commander f

OmCIAL RECORD COPY E

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Q U ja1419 License Nos. 20-01010-04 SNM-00244 SUB-00238 '

Docket Nos. 030-04593 ,

070-00263 040-02253' '

Control Nos. 119083 119084 118747 L ,

Department of the Army U.S. Army Research I2boratory SLCMT-DDM(5-10c)' -

ATTN:leffery I. Stieffel . '

Captain, CM -

- Acting Commander

l. 405 Arsenal Street Watertown, Massachusetts 02172-0001 l-

Dear Captain Stieffel:

l This is in reference to.your request in a letter dated September 17, 1993 to amend License

! q No. SUB-00238 to exempt your activities from the new 10 CFR 20. LWe have determined that i - in order to complete the action on this request we must prepare a brief Environmental

• Assessment. ' In order to prepare this assessment, we need the following additional information:

1. Estimate the cost to implement the requirements in-10 CFR 20.1001-20.2401.

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. 2. 3 Briefly describe the implementation of your'ALARA program over the'last' year and -

ll discuss how your policies;and proceduresf have maintained _ occupational mdiation exposures as low as is reasonably achievable. Specify the administrative limits.which i

. you place on external and internal exposure and state whether they have been exceeded.

3.

Estimate the percentage of the remediation activities that are completed.

4.

Describe the current status of the remediation activities at the facility. Briefly list.the activities remaining. .

5.

Estimate the fraction of radioactive contamination that has been removed from'the i facility and estimate the quantity of radioactive material remaining.at the facility.

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I OFFICIAL RECORD COPY - 01/14/94 - 'l

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t Include radioactive material which is present as contamination on surfaces and in the l soil in excess of release criteria.

6.

Estimate the dose equivalent to the potentially worst case exposed member o .

during 1993 and 1994 as a result of the activities conducted under your licenses including the facility remediation. i 7.

What was the maximum whole body dose equivalent and the maximum airborne exposure to any individual worker during 1993?

1 8.

Estimate the maximum whole body dose equivalent and the maximum airborne e that will be received by any one worker in 1994, i

9. l Estimate the average worker whole body dose equivalent expected for 1994,.  !

10.  !

Estimate the total whole body dose equivalent for remediating the facility and th fraction of that total which has been delivered to date.

I We will continue our review upon receipt of this infonnation. Please reply in dup attention at the Region I office and refer to hiail Control Nos. 119083,119084, and 118747.

The reviewer for this license action is hiark R. Bouwens. If you have any quest this letter please call the reviewer at (610) 337-6910.

l Sincerely,

% sal Signed Ey '

i od= D. Ihncman:  !

John D. Kinneman, Chief Decommissioning Section Division of Radiation Safety and Safeguards l CC; i

Peter Cornetta, Radiation Protection Officer U.S. Army Materiel Command l

ATTN: AMCSF-P (Mr. John Manfre)

! 5001 Eisenhower Avenue

) Alexandria, Virginia 22333-0001 i

OFFICIAL RECORD COPY - 01/14/94 l

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O O U.S. Army ARL 3 Department of the Army Corps of Engineers, New England Division ATTN: Richard D. Reardon, Director of Engineering 424 Trapelo Road Waltham, Massachusetts 02254-9149 Commander Department of the Army Corps of Engineers, New England Division ATTN: CENED-PD-L (Mr. Dennis Waskiewicz) 424 Trapelo Road Waltham, Massachusetts 02254-9149 Commander U.S. Amiy Toxic and Hazardous Materials Agency ATrN: CETHA-BC (Mr. Salvatore Torrisi)

Aberdeen Proving Ground, Maryland 21010-5401 Commonwealth of Massachusetts Depanment of Health ATTN: Robert Hallisey Director Radiation Control Progmm 150 Tremont Street Boston, Massachusetts 02111 U.S. Environmental Protection Agency ATTN: Ms. Anne Fenn JFK Federal Building (PAS)

Boston, Massachusetts 02203 Commonwealth of Massachusetts Department of Environmental Protection Bureau of Waste Site Clean-Up ATrN: Ms. Anne Malewicz 1 Winter Street, Fifth Floor Boston, Massachusetts 02108 OFFICIAL RECORD COPY - 01/14/94

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O O U.S. Anny ARL 4 U.S. Anny Research Laboratory '

Adelphi Laboratory Center '

ATrN: AMSRL-OP-RK-S (M. Borisky) 2800 Powder Mill Road Adelphi, Maryland 20783 Watertown Main Library

-ATrN: Reference Department 123 Main Street Watertown, MA 02172 I

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4 OFFICIAL RECORD COPY - 01/14/94 4

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.a ' REGIONAL ThNICAL ASSISTANCE REQUESThM i

Date: December 6.1993 l l

Mail or E-Mail to: CarlJ. Paperiello (CJP1), Mail Stop: GH3-OWFN, if E-mail, cc: CLE Division of industrial and Medical Nuclear Safety, NMSS From: James H. Joyner (JHJ) (Name and E-mailinitials) Region I Chief, Facilities Radiological Safety and Safeguards Branch Licensee: U.S. Armv Research Laboratorv License No.: SUB-238 O ControlNo. 118747 (if applicable)

D Latter dated: Sentember 17.1993 (ifapplicable)

D Suggested change in licensing procedure (enclosed): j l

l D Problem / issue: The Denartment of the Army reauested an exemntion from imniementation of the Revised 10 CFR Part 20 for the U.S. Army Research Laboratory in Watertown. Massachusetts (Watertowr Arsenal).

O Action Required: Anorove an exemntion from the Revised 10 CFR Part 20 for the U.S. Army Research Laboratory. License Nos. 20-01010-04. SNM-244. and SUB-238.

Recommended Action (with revisions): D Approve or D Reject Remarks:

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Headquarter Reviewer: l RegionalReviewer: Mark R. Bouwens R5 viewer Code: J8 Reviewer Phone No.: (215) 337-6910 FAX No.: L215) 337-5368 l Request Needed by: 12/20/93 (date) Form TAR-10 l O7FICI AL RF. CORD EDPY .%,10 8'83 I

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December 6,1993 License No. SUB-238 i Docket No. 040-02253 l Control No. 118747 i

MEMORANDUM FOR: Carl J. Paperiello, Director Division of Industrial and Medical Nuclear Safety, NMSS FROM: James H. Joyner, Chief -

Facilities Radiological Safety

and Safeguards Branch Division of Radiation Safety and Safeguards, RI

SUBJECT:

TECHNICAL ASSISTANCE REQUEST: U.S. ARMY RESEARCH LABORATORY (WATERTOWN ARSENAL)

! The active ponion of the Watertown Arsenal site [U.S. Army.Research Laboratory (ARL),

, Watertown, Massachusetts) is composed of about 14.6 hectare (36 acms) located along the nonh branch of the Charles River approximately 7 miles west of Boston, Massachusetts. Work with various radioactive materials has been conducted at various locations within the Arsenal since l at least 1946. This work has been under AEC and NRC license since Febmary 6,1958. The Depanment of the Army (Army) began remediation activities at ARL under an NRC approved t Decommissioning Plan in July 1992 and the facility is scheduled by the Army for closure by 1996. The primary contaminant on the site is depleted uranium _(DU).

l The Army requested an exemption fmm the implementation of the Revised 10 CFR Pan 20 for .

l ARL, License No. SUB-238. The majority of the remediation of the site has been completed; i however, the Army expects that some remediation activities will not be completed until after December 31,1993. The Army requested the waiver to avoid additional expenses that will be incurred by retraining employees and developing a radiation protection program to meet the requirements of the Revised 10 CFR Pan 20. An acceptable radiation safety pmgram is in place -

l and provides' adequate protection to workers and the public. The radioactive material remaining i' on-site is mostly isolated DU contamination which is not likely to produce exposures to workers or the public even approaching the current or Revised 10 CFR Part 20 dose limits.

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OFFICIAL RECORD COPY - 12/06/93 l

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i U.S. Army MTL TAR 2 l

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l We have reviewed the Army's request and conclude it should be approved based on the following:

1. Remediation of the site is almost complete; there will be little handling of radioactive material in 1994 and 1995.

2. The inventory of radioactive material on-site is very small. l

3. The Army expects to request tennination of License Nos. 20-01010-04 and SNM-244 (Docket Nos. 030-04593 and 070-00263) in February 1994.

4. The Army will complete decommissioning activities at the facility and submit the final  ;

Termination Survey by May 1994.

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5. Region I inspected the decommissioning activities at ARL from November 30,1992 to December 3,1992 and October 4-6, 1993. Dosimetry records and results of effluent sampling showed adequate control of exposures to workers and members of the public.

No safety concerns or violations were identified. Exposures recc,rded were well below the limits in the Revised 10 CFR Pan 20.

6. An exemption to the Revised 10 CFR Pan 20 was (or will be) issued for decommissioning activities at the Shoreham Nuclear Power Station, Unit ), License No. NFP-82. Reference letter, dated November 5,1993, from Clayton L. Pittigiio, Jr., NRC, to Arthur J. Bortz, long Island Power Authority.

However, the approval of the Army's request should incorp following conditions.

1. The exemption will be for the three active licenses at th ;ility. We have requested that ARL provide a formal request for an exemption to ..._ ..evised 10 CFR Part 20 for License Nos. 20-01010-04 and SNM-244 (Docket Nc,s. 030-04S3 and 070-00263). i l

2. The exemption will continue until license termination.

3. Remediation activities at the ARL facility must contime toward completion of the l decommissioning of the facility and license termination.

4. The approval is for decommissioning activities at the ARL facility, Mall Property, and GSA Property.

5. We will make clear that the dose limit of not more than 100 millirem to a member of the public in 10 CFR 20.1301 may be usea to evaluate contamination remaining at any of the sites.

OFFICIAL RECORD COPY - 12/07/93 l

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U.S. Anny MTL TAR 3 i There is no benefit to workers or public by requiring the implementation of the Revised l 10 CFR Part 20 at this facility. We recommend you concur in the issuance of an exemption to l

the Revised 10 CFP. Part 20 for the U.S. Army Research Laboratory, License Nos.

20-01010-04, SNM-244, and SUB-238.

We appreciate your assistance with the issues at this SDMP Site.

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l James H. Joyner, Chief j l Facilities Radiological Safety J

, and Safeguards Branch l Division of Radiation Safety and Safeguards cc:

J. Austin, NMSS i

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1 OFFICIAL RECORD COPY - 12/06/93 i

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E REPtYTO THE ATTENTION oF 17 September 1993 g M

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License-No. SUB-238 Docket No. 40-02253 Control No. 113651 tir. John D. Kinneman i Chief, Research Development, and Decommissioning Section Division of Radiation Safety and Safeguards U.S. Nuclear Regulatory Commission / Region 1 475 Allendale Road King of Prussia, PA 19406-1416

Dear Dr. Kinneman,

Request your agency approve a waiver to implementation of the new 10 CFR 20 at the Watertown site. The limited period of application of 10 CFR 20 at Watertown would not justify the expense or the effort involved in making such a change.

While it is our intent to complete decontamination activities prior to the end of this year, unforseen requirements such as may be involved with the remediation of the contaminated pipe extending from under Building 43 out under Arsenal Street, the possibility of difficulties arising during the mixed waste processing in Building 43, and tasks associated with the GSA site cleaning may extend beyond our control into next year.

Furthermore, extensive radiation protection procedures covering regulations under the old 10 CFR 20 were written at considerable expense to the Army by our contractor, Scientific Ecology Group. As you are aware, preparations for the implementation of tiie new 10 CFR 20 involve retraining of radiation workers as well as detailed radiation protection program development tasks relating to topics such as ALARA, record keeping, exposure determination, waste disposal, i planned special exposures surveys and new rules on precautionary measures, etc. l Additional expenditure in these areas would not contribute significantly to a l reduction in personnel exposure due to the nature of the radioactive  !

contamination involved and we expect to terminate our byproduct and other j special nuclear materials licenses shortly.  !

Your consideration and assistance in this matter is appreciated. i j

' ~

Sincerely,

/

. U IN 9 leutenant Col ael, Ordnance Corps Commanding ggg7 SEP 2 31993 "SECMON COPY'- -

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@, REPLYTO THE ATTENTION OF AMENAL STREET WATERTOWN, MASSACHUSETTS 02172-0001 J ...

6 December 1993 7 00 gyOf Commander Mr. John D. Kinneman Chief, Research Development, and Decommissioning Section Division of Radiation Safety ar.d Safeguards U.S. Nuclear Regulatory Coms. u !oa/ Region I 475 Allendale Road King of Prussia, PA 19406-1416

Dear Mr. Kinneman,

Reference our letters _of 17 September and 6 November 1993 concerning a request for a waiver to the implementation of the new 10 CFR 20 regulations.

Further discussions between Mr. Mark Bouwens and Mr. Peter Cornetta have prompted this letter to also include License Numbers 20-01010-4 and SNM-244 in the request for a waiver to the implementation to of the new 10 CFR 20 r egu '.a tio ns .

Sinc rely, '

mes T. Naught eutenant Co on ., Ordnance Corps ommanding 1

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PARTMENT OF THE ARMY Q l U.S. ARMY RESEARCH LADORATORY ga O,ACPLYTOTHE ATTENTION O' ARSENAL STREET WATERTOWN, MASS ACHUSETTS 02172-0001 8 November 1993

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License No. SUB-238 Docket No. 40-02253 l i

Mr. John D. Kinneman Chief, Research Development and Decommissioning Section Division of Radiation Safety and Safeguards U.S. Nuclear Regulatory Commission / Region I 475 Allendale Road l King of Prussia, PA 19406-1416 i

Dear Mr. Kinneman:

l i

l The additional information requested by your of fice concerning our request for a waiver to the implementation of the new 10 CFR 20 and how it would effect l individual members of the public is included here.

The radioactive sources in our posession that have significiant ambient radiation fields associated with them aret 1) the Sci PuBe source; 2) three, 500 mci plutonium foils; and 3) the reactor beam tubes. The PuBe source is stored in a steel container that is filled with paciffin. The ambient field measured f rom the container due to the x-ray and neutron emissions is 5 mrem /hr.

on contact and not measurable outside the cement walls of the facility. The dose rate on contact with the steel container holding the 500 mci Pu-239 foils is approximately SmR/hr. These sources are locked in our calibration facility as stated in license number SNM - 244. Compliance with 20.1302 is satisfied by the results of monthly surveys of this building which indicate background levels of radiation and also meet the requirement (20.1301) that the effective dose j equivalent to individual members of the public should not ex eed 0.1 Rem in a }

year and that the dose in any unrestricted area from external sources does not i exceed 0.002 Rem in any one hour. l These plutonium sources are being stored-awaiting shipment to the Department of Energy. Access is restricted in accordance with license SNM-244 and our '

Radiation Safety program, thus keeping exposures as low as reasonably achievable. Finally the beam tubes (enclosed in lead) that are being stored inside LSA boxes will be cut, marked, encapsulated and shipped this month. l Further questions concerning compliance with " Dose limits for Individual Members of Public" may be directed to Peter Cornetta at (617) 923-5225. I Sincerely,

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~ames T. Naughton I f ieutenant Colone ,

I rdnance Corps W Commanding j I

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DEPARTMENT OF THE ARMY @

U.f'!MY RESEARCH LABORATORY V ARSENAL STREET

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REPLY TO THE ATTENTION OF 17 September 1993 l Commander g([o M License-To. SUB-238 Docket No. 40-02253 Control No. 113651 l

Mr. John D. Ydnneman Chief, Research Development, and Decommissioning Section

Division of Radiation Safety and Safeguards l U.S. Nuclear Regulatory Commission / Region I l 475 Allendale Road j King of Prussia, PA 19406-1416

Dear Dr. Kinneman,

i l Request your agency approve a waiver to implementation of the new 10 CFR 20 l ct the Watertown site. The limited period of application of 10 CFR 20 at l Watertown would not justify the expense or the effort involved in making such a

change.

l While it is our intent to complete decontamination activities prior to the i snd of this year, unforseen requirements such as may be involved with the I

remediation of the contaminated pipe extending from under Building 43 out under Arsenal Street, the possibility of difficulties arising during the mixed waste processing in Building 43, and tasks associated with the CSA site cleaning may

sxtend beyond our control into next year.

1 Furthermore, extensive radiation protection procedures covering regulations under the old 10 CFR 20 were written at considerable expense to the Army by our contractor, Scientific Ecology Group. As you are aware, preparations for the implementation of the new 10 CFR 20 involve retraining of radiation workers as well as detailed radiation protection program development tasks telating to  ;

topics such as ALARA, record keeping, exposure determination, vaste disposal, planned special exposures surveys and new rules on precautionary measures, etc.

Additional expenditure in these areas would not contribute significantly to a reduction in personnel exposure due to the nature of the radioactive contamination involved and we expect to terminate our byproduct and other special nuclear materials licenses shortly.

Your consideration and assistance in this matter is appreciated.

Sincerely,

/

'ieutenant wfo fCol (gel, Ordnance Corps

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j- Commanding gyg SEP 2 3 1993 l- SECTION COPY' i

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INFORMATION FROM LTS BETWEEN. .

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LICENSE FEE MANAGEMENT BR A NC;i, ARM  : PROGRAM CODE: 22111 AND  : STATUS CODE: 0

() REGIONAL LICENSING SECTIONS  : FEE CATEGORY: EX 14 10

EXP. DATE: 19971231 l

FEE COMMENTS: _____________________

l i[)  : DECOM FIN ASSUR REQD: Y  ;

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() LICENSE FEE TRANSMITTAL i 1

A. REGION i C)

1. APPLIC AT ION ATTACHED APPLICA9T/ LICENSEE: ARMY, DEPARTMENT OF THE C) R E C EI V E3 DATE: 931207 '

1 DOCKET N O: 7000263 CONTROL NO.: 119034

() LICENSE NO.: SNM-244 ACTION-TYPE: AMENDMENT

() 2. FEE ATTACHED AMOUNT:

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() B. LICENSE F EE MANAGEMENT BRANCH (CHECK WHEN MIL E STONE 03 IS ENTERED /__/)

1. FEE C ATEGORY AND AMOUNT: _________________________________________

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2. CORRELT FEE PAID. APP LIC ATION M AY BE PROCESSED FOR:

AMENDME1T ______________

C) RENEWAL ______________

LICENSE ______________

l C) 3. OTHER __________________________________

' C) sIGNEo _________________________________

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